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United Nations Development Programme (UNDP)Stora Enso Guangxi Forest and Industrial ProjectSummary Integrated Environmental and Social Impact Analysis

Final Report27 April 2012

UNDP Stora Enso Guangxi Forest and Industrial Project Summary Integrated Environmental and Social Impact Analysis Final Report


Table of ContentsAcronyms 1

Executive Summary 3

Plantation Estate 3

SEGX Mill Integrate 4

Conclusions 7

1. Introduction 9

1.1 Overview 9

1.2 Stora Enso in China 9

1.3 Regulatory Context 10

1.4 Past Studies and Public Engagement 13

1.5 Report Purpose and Objectives 15

1.6 Report Structure 16

2. Project Description 17

2.1 Overview 17

2.2 Project Location 18

2.3 SEGX Plantation Estate 19

2.4 Description of Planned Mill Operations 28

2.5 Comparison of Expected Mill Emissions with BAT 35

3. Social and Environmental Setting 37

3.1 Overview 37

3.2 Economic Development 37

3.3 Social Setting 39

3.4 Physical Setting 42

3.5 Existing Land Uses 43

3.6 Biodiversity 43

3.7 Water Quality 45

3.8 Air Quality 47

3.9 Existing Infrastructure 47

3.10 Amenity 48

4. Social and Environment Impacts 49

4.1 Overview 49

4.2 Social Impacts 49

4.3 Economic Effects 52

4.4 Plantation Estate Potential Environmental Impacts 54

4.5 SEGX Mill Environmental Impacts 58

Cover Photo: Making a quick call while tending buffalos, China

Taken by Jarmo Hietaranta

By courtesy of Stora Enso



Table IndexTable 1 Key legislation and guidelines 10

Table 2 Summary of the General Features of the project 17

Table 3 SEGX Contracted and Offered Land (August 2010) 20

Table 4 UNDP (2006) Survey Details 23

Table 5 UNDP-GHD 2010 Survey Scope (refer Appendix D for results) 24

Table 6 Residual Solid Waste from the pulp mill process (SE, 2010) 32

Table 7 Expected distribution of passages 33

Table 8 Effluent loadings per ton of pulp compared to IPPC and IFC guidelines for long term average 35

Table 9 Emissions to air from recovery boiler and lime kiln compared to IPPC and IFC Guidelines for pulp

production 36

Table 10 Power Boilera Emissions Compared to IFC Guidelines for Thermal Power Plants 36

Table 11 Guangxi Proportion of PRC Total Biodiversity 43

Table 12 Marine Reserves and Conservation Zones within 100 km of SEGX Mill Site (TRIWTE, 2009) 44

Table 13 Water Quality Classification 46

Table 14 Seawater Quality Standards (GB3097-97) 47

Table 15 Estimated SEGX direct employment at full scope operation 53

Table 16 Marine Discharge Area of Influence based on RIEPG (2008) 58

Table 17 Effluent Quality for Different Phases of the project compared to standard limits and specification

for technical design of effluent treatment 59

Table 18 Sources of Existing and Future Cumulative Impacts 62

Table 19 Proposed transport risk mitigation and management strategies 66

Table 20 Construction Phase Environmental Management Plans and Systems 67

Table 21 Groundwater and surface water indicators 69

Table 22 Soil erosion and quality indicators 70

Table 23 Limits and Recommended Sampling Schedule for Point Source Air Emissions 72

Table 24 Ambient Air Quality Monitoring Schedule 72

Table 25 Proposed baseline Water Quality Monitoring, Ambient Pre-operation 74

Table 26 Indicative core parameters to be monitored in discharge (IFC (2007), IPPC (2001), RPDC (2004)) 74

4.6 Cumulative Impacts 61

5. Mitigation Management Plan 65

5.1 Forestry Operations 65

5.2 Industrial Facility 67

5.3 Social Impact Mitigation and Management 68

6. Social and Environmental Monitoring Plan 69

6.1 Groundwater and surface water 69

6.2 Erosion prevention and sediment control 70

6.3 Terrestrial flora and fauna 70

6.4 Transport Monitoring Plan 71

6.5 Air Quality Monitoring Plan 71

6.6 Marine Water Quality 73

6.7 Social, land use and economics monitoring 75

7. Summary and Conclusions 76

7.1 Plantation Estate 76

7.2 SEGX Mill Integrate 77

7.3 Conclusions 79

7.4 Recommendations 80

8. References 82

Stora Enso Guangxi Forest and Industrial Project – Summary IESIA | GHD | 1UNDP Stora Enso Guangxi Forest and Industrial Project Summary Integrated Environmental and Social Impact Analysis Final Report

AcronymsAD Air driedADB Asian Development BankADt Air-dry tonsAOX Absorbable Organic HalideASEAN Association of Southeast Asian NationsAQMS Air Quality Monitoring SystemBAT Best Available TechnologyBGEZ Beibu Gulf Economic ZoneBHKP Bleached Hardwood Kraft PulpBHC Beihai CompanyBHR Beihai Region (department in SEGX Forestry organization)BCS Broad Community SupportCAF Chinese Academy of ForestryCERC China Eucalyptus Research Center, Zhanjiang, GuangdongCNCG Concentrated Malodorous GasesCNY Chinese Yuan (also referred to as RMB)CoC Chain of CustodyCOD Chemical Oxygen DemandCTMP Chemi-thermomechanical PulpCRAES Chinese Research Academy of Environmental SciencesCSR Corporate Social (and Environmental) ResponsibilityDOC Dissolved Organic CarbonEHS Environmental, Health, SafetyEIA Environmental Impact AssessmentEIA 2008F Environmental Impact Registration FormEIS Environmental Impact StatementEMS Environmental Management SystemESIA Environmental and Social Impact AnalysisESP Electrostatic PrecipitatorsFFI Fauna and Flora InternationalFPIC Free Prior and Informed ConsentFSC Forest Stewardship Council GDP Gross Domestic ProductGMO Genetically Modified OrganismGZAR Guangxi Zhuang Autonomous RegionHDF High Density Fibre BoardHFO Heavy fuel oilIESIA Integrated Environmental and Social Impact AssessmentIFC International Finance CorporationIFC-EHS IFC-Environmental Health and Safety GuidelinesIESIA Integrated Environmental and Social Impact AssessmentIPPC Integrated Pollution Prevention and ControlIOSP Integrated Operational Site PlanISO International Standards OrganisationKraft A chemical pulping process using an alkaline sodium hydroxide and sulphide containing solution

for digestion of wood chipsMDF Medium Density FibreboardMEP Ministry of Environmental ProtectionMWR Ministry of Water ResourcesNDRC National Development and Reform CommissionPRC People’s Republic of ChinaRITF Research Institute of Tropical Forestry, Guangzhou, GuangdongRPDC Resource Planning and Development Commission, Tasmania, AustraliaSE Stora EnsoSEGX Stora Enso GuangxiSEPA State Environmental Protection AdministrationSFA State Forestry AdministrationSIA Social Impact AssessmentSLRA State Land Resources AdministrationSS Suspended SolidsTFRICAF Tropical Forestry Research Institute of Chinese Academy of ForestryTMP Thermo-mechanical PulpTRS Total Reduced Sulphur compoundsTSID Tie Shangang Industrial DistrictTSP Total Suspended ParticlesToR Terms of ReferenceUNDP United Nations Development Programme

a annumADt Air Dried TonneADt/a Air Dried Tonne per annumha hectareskWh kilowatt hourm metresm3 cubic metersMm3 million Cubic metersMW megawattsNm3 Volume of one cubic at standardised temperature and pressureoC degrees Celsiusy year

Figure Index

Figure 1 Guangxi Zhuang Autonomous Region and Project Prefecture Level Cities 18

Figure 2 SEGX Plantation Estate 19

Figure 3 Beihai and Tieshangang Industrial Zone (RIEPG, 2008) 29

Figure 4 Simplified Diagram of the Pulp Mill Process 29

Figure 5 Schematic Diagram of Mill Logistics 34

Figure 6 Proposed Mill Site Location and Industrial District 39

Figure 7 Location of Marine Reserves Within Tieshan Port Area (RIEPG, 2008) 45

Figure 8 Tieshan Port Water Quality Objectives (SCSIO, 2010) 47

Figure 9 Estimated job creation during construction phase SEGX pulp mill 53

Figure 10 Cumulative Impacts Matrix 64

AppendicesAppendix A Social Impacts Complementary Review and Assessment

Appendix B Transport Complementary Review and Assessment

Appendix C Water Quality Complementary Review and Assessment

Appendix D Air Quality Complementary Review and Assessment

| GHD | Stora Enso Guangxi Forest and Industrial Project – Summary IESIA Stora Enso Guangxi Forest and Industrial Project – Summary IESIA | GHD | 2 3

Executive SummaryStora Enso Guangxi (SEGX), a subsidiary of Stora Enso (SE), has proposed the development of a Kraft pulp, paper and board

mill and associated forestry plantation estate (collectively the project) in southern Guangxi Zhuang Autonomous Region (Guangxi), People’s Republic of China. The proposed scope of the project includes a Kraft pulp mill with 900,000 air-dry

tonne per annum capacity and a paper and board production mill with a capacity of 900,000 tonne per annum, supplied with wood fibre sourced from approximately 130,000 hectares of Eucalyptus plantation on a total land area of 160,000 hectares.

The project received relevant environmental approvals from the Chinese Ministry of Environmental Protection on 4 December 2008, based on separate environmental impact assessment reports for the mill and the plantation operations, prepared by Chinese design institutes.

As part of the project development and approval process, several studies, assessments and special subject reports have been completed, assessing the potential social and environmental effects of the project in addition to the two environmental impact assessment reports prepared for regulatory approval.

This summary integrated environmental and social impact analysis (IESIA) report provides a third party consolidation of the past studies and independent review for the project, including a description of potential environmental and social impacts. The report has been peer reviewed by two independent UNDP consultants and by an in-house GHD professional with knowledge of the industry and China. We note certain circumstances in China presented constraints to accessing some external domestic information and limited the extent to which some potential impacts could be assessed. Site surveys and inspections were conducted in October 2010 and July 2011 as part of this analysis. However, although attempts have been made, it has not been possible to verify all data independently as part of the consolidation and reporting process. This report seeks to address some of the specific gaps in previous studies with complementary assessments included as Appendices A – D. Further recommendations are made for additional assessments and ongoing monitoring.

Plantation EstateSEGX commenced operations in Guangxi in 2002, with a target of establishing about 160,000 hectares of land base and about 130,000 hectares of plantation estate (based on Eucalyptus plantation) by the time the SEGX mill starts production. The total wood consumption for the proposed 900,000 ADt/a pulp mill will be approximately 3.4 Mm3 of Eucalyptus wood. It is anticipated that all of the wood will eventually be supplied from SE’s own plantations.

As of August 2010, SEGX had contracted a total of 84,627 hectares of land with an additional 41,258 hectares offered by city governments, a total of 125,885 hectares. The contracted plantation land exists as both connected and isolated parcels of forestry land, inter-mixed with other (non-SEGX) forestry plantation operations, villages and other land uses.

Forestry plantations have been a dominant land use in southern Guangxi for many decades. The total area of land designated for commercial forestry in Guangxi is 7.8 million hectares, of which SEGX is seeking to lease approximately 2 %.

Plantation estate land currently contracted by SEGX is spread over 27 counties. Of the total area of currently contracted and offered land of 125,885 hectares, 36,154 hectares (29%) is social land and 89,731 hectares (71%) is state land. The majority of the social land is located within Beihai and Yulin counties. State lands are located within five prefecture level-cities: Beihai, Yulin, Nanning, Qinzhou and Chongzuo.

Past studies have shown the development and operation of SEGX’s plantation estate is likely to be associated with the following key social and environmental benefits:

» Increased employment and skills development: employment on SEGX plantations was about 4,400 people in 2005 and was estimated to reach 12,400 to 14,400 full-time jobs once the plantation operations reached full scale.

» Potential to improve industry practice in forestry operations: SEGX brings significant forestry experience, advanced breeding and propagation techniques, international standards in planting and harvesting operational equipment, and stand management plans that have been developed with consideration for international best practice, many of which are in advance of contemporary local practices in Guangxi. Specifically, some of these practices and techniques include: (i) restrictions on site selection based on environmental sensitivity, including defined buffer zones around rivers (20 m and 50 m for major tributaries); (ii) use of mechanized planting practices rather than excavated trenches; (iii) planting along contour lines rather than along the slope line which is common local practice; (iii) a planting density of 1,250 stems per hectare

DisclaimerThis Report has been prepared by GHD for United Nations Development Programme China (UNDP) and may only be used

and relied on by UNDP for the purposes agreed between GHD and the UNDP as set out in section 1.5 of this Report and the contract between GHD and UNDP.

GHD otherwise disclaims responsibility to any person other than UNDP arising in connection with this Report. GHD also excludes implied warranties and conditions, to the extent legally permissible.

The services undertaken by GHD in connection with preparing this Report were limited to those specifically detailed in the Report and the contract and are subject to the scope limitations set out in both.

The opinions, conclusions and recommendations in this Report are based on conditions encountered during GHD site visits and information reviewed by GHD in the preparation of the Report as referenced in the Report.

GHD has not verified the information reviewed for the Report and does not accept liability in connection with such unverified information, including errors and omissions in the Report that may have been caused by errors or omissions in that information. GHD specifically disclaims liability arising from any of the information, or assumptions GHD has made from that information, being incorrect.

GHD has no responsibility or obligation to update this Report other than as agreed with the UNDP and consistent with GHD contractual arrangements with UNDP. GHD takes no responsibility where the Report may be impacted by events or changes occurring subsequent to the date that the Report was prepared.


mills. The design is in line with Chinese regulations, European guidelines and comparable international standards associated with new kraft mills in other parts of the world.

Based on a comparison of the expected emissions for the pulp mill with those considered representative of best available technology (Table ES-1 through ES-3), the mill is expected to meet, and in some cases go beyond, international guidelines used to define best available technology.

Table ES-1: Effluent loadings per ton of pulp compared to IPPC and IFC guidelines for long term average

Parameter

SE Pulp Mill (standalone)a Env.

Approvalb m3/ADt, kg/ADt

GB 3544-2008c Standalone Pulp mill

m3/ADt, kg/ADt

IPPC-BATd (2001) Pulp mills m3/ADt,

kg/ADt

IFC-EHS Pulp mills (2007)

m3/ADt, kg/ADt

Flow 25 50 30 to 50 50

BOD5 0.5 1.0 0.3 to 1.5 1.0

COD 2.5 5 8 to 23 20

TSS 1.25 2.5 0.6 to 1.5 1.5

AOX 0.15 n.a. 0 to 0.25 0.25

Total nitrogen 0.2 0.75 0.1 to 0.25 0.2

Total phosphorus 0.02 0.04 0.01 to 0.03b 0.03a) Standalone pulp mill corresponds to Mill Project Phase 1. b) Calculated from RIEPG 2008 Oct 2008, table 3.4-5, Nov 2008 amendment specific flow revised to 25 m3/Adt, c) Specific loads calculated from GB 3544-2008, standard only states specific flow and concentrationsd) After biological effluent treatment.e) Due to the higher content of phosphorus in the pulp wood some Eucalyptus pulp mills cannot achieve these values if P is in excess of the need of the biological treatment plant. Emission will be determined by P-content of the wood. No phosphorus needs to be added to the wastewater treatment plant.

Table ES-2: Emissions to air from recovery boiler and lime kiln compared to IPPC and IFC Guidelines for pulp production

ParameterSE Pulp Mill

Technical designa parameters, kg/Adt

SE Pulp Mill (standalone) Env. Approvalb kg/ADt

IPPC-BAT (2001) Pulp mills

kg/ADt

IFC-EHS Pulp mills (2007) kg/ADt

SO2 (as SO2) 0.7 1.8 0.4 to 0.8 0.8

NOx (as NO2) 2 - 1.0 to 1.5 1.5

TSPc 0.3 0.4 0.2 to 0.5 0.5

TRSd (as H2S) 0.06 0.06 0.1 to 0.2 0.2

a) Technical design parameters for SO2 and TRS, the long term averages may be lower, see ref. b) Calculated from RIEPG 2008 Oct 2008, table 3.4-7 amendment, 900,000 ADt production, 354 operating d/a c) Total suspended particlesd) Total Reduced Sulphur Compounds

Table ES-3: Power Boilera Emissions Compared to IFC Guidelines for Thermal Power Plants

ParameterSE Preliminary Technical

designa parameters mg/Nm3

Maximum Concentration Env. Approvalb

mg/Nm3

IFC-EHS (2008) Guidelinesmg/Nm3

SO2 (as SO2) 200 319 900 to 1,500

NOx (as NO2) 300 300 510 to 1,100

TSPc 30 41 50

TRSd (as H2S) n.a. n.a. -a) Design data are preliminary only. Power Boiler is part of phase 2 and 3 scope, one operational unit added for each phaseb) RIEPG 2008, Table 3.4-6, amendedc) Total suspended particlesd) Total Reduced Sulphur Compounds

Past assessments have shown that mill operations have the potential to bring both positive and negative social and environmental issues to the region.

rather than the common practice of 2,222 per hectare; (iv) establishing plantations as clonal blocks to offer uniformity in management; and (v) optimizing and restricting the use of fertilisers and herbicides, with no chemical application allowed within 50 m of a water course or pond. Working with the local government and alongside local forestry operations, SEGX has the potential to increase the awareness and management of potential environmental impacts associated with forestry plantation estates in southern Guangxi.

While SEGX has developed and continues to improve a framework of systems, policies and practice standards based on corporate best practice and applicable international standards that are tailored to the Guangxi conditions, potential adverse environmental and social impacts from the development of the project have been identified, including the following key potential impacts:

» Community engagement and land rental issues: Community surveys have highlighted concerns regarding some land leasing agreements and forestry operations including: (i) fair and prompt payments/compensation; (ii) lack of free, prior and informed consent of landowners; (iii) conflict over land tenure/ownership; (iv) employment opportunities; (v) transportation impacts (noise, dust, road conditions); and (vi) protection of workers’ rights. SEGX has recognised that its land agreement and rental systems require continual improvement, and in 2009 commenced a revision of its land rental process to improve certainty of land tenure and to provide a greater level of transparency to the rental process, including implementing a dispute reporting and intervention procedure in the form of a hotline and grievance channel and seeking to develop local community sustainable development pilot projects. SEGX has also recognised that whilst it has implemented a number of community communication mechanisms, these are not well known and utilised by the rural communities potentially affected by the forestry operations.

Recommendations arising from this review to improve management of social impacts include; (i) continue to work with the Beihai government to encourage assessment of environmental and social issues when nominating lease land for SEGX consideration: (ii) continual improvement of the contract assessment process to minimise land disputes; (iii) continual improvement in the negotiation process to ensure consultation and agreement with leaseholders rather than administrators; (iv) greater communication of contract agreement, pricing framework, payment frequency and payment methods to leaseholders to minimise the potential for inappropriate or unauthorised payments; (v) greater monitoring of negotiations and payments, possibly through an auditing process; (vi) improved communication and communication tools as part of encouraging a long-term relationship with local communities; (vii) encouraging local communities to report incidents or issues as part of a performance monitoring network; and (viii) examine opportunities to increase local workforce participation in plantation and other roles (dust suppression, security).

Whilst recognising that SEGX is somewhat constrained by the relationships with various government agencies and the processes required of a foreign company working in China, a collaborative approach to continuous improvement is critical to achieving positive project outcomes.

» Potential environmental impacts associated with large-scale forestry operations: Potential environmental impacts identified include; (i) potential impacts on biodiversity due to lack of interconnection of biodiversity corridors, generally existing within buffer-zones around environmentally sensitive areas; (ii) potential impacts to water quality and quantity, most significantly from application of chemicals and increased sediment runoff; and (iii) potential impacts from increased transport of wood, primarily noise and dust generation and impacts to roads. Further potential environmental impacts are identified and discussed within the report. SEGX has developed management, mitigation and monitoring plans aimed at addressing these issues, including initiating a forestry biodiversity monitoring program and water and soil quality monitoring.

SEGX Mill IntegrateThe mill site is located in the Tieshangang Industrial Zone, Beihai Prefecture, Guangxi, about 2 km from the coastline and about 40 km east from Beihai City. The site covers a total land area of 250 ha.

The SEGX mill will utilise the Kraft pulping process, which entails chemical treatment steps for converting wood into pulp fibres with high brightness and cleanliness. The mill design incorporates the principles of modern and efficient mills seeking to reduce energy, chemical consumption and maintenance costs, and to minimise effluent and air emission loads through the application of modern technology. Production systems are designed using modern clean technology to minimize emissions. Treatment systems have been included in the mill design to eliminate some of the emissions and reduce the remainder to low levels. As with most Kraft pulp mills built since 2000 the emissions will be dramatically lower than levels associated with historical pulp


ConclusionsThe SEGX proposal is a major and complex project that will have a range of positive and negative impacts on the natural and social environment. SE is bringing a high level of corporate governance, systems and environmental management to the project, well in advance of contemporary local industries. These practices range from defining worker accommodation and labour rights to the implementation of industry best practice emissions control.

SEGX faces many challenges in implementing these practices, particularly working as a foreign company within the framework of land leasing, social compensation and managing cumulative impacts in accordance with local government policy and standard practice. SEGX is developing this project in cooperation with the Guangxi government and that has required the implementation and continual improvement of various processes, particularly in relation to lease acquisition with the Beihai city government.

Whilst having secured environmental approvals for the project from the Chinese regulators, additional work is required by SEGX in the implementation and development of design, management systems and monitoring programs to meet recognised international performance standards and SE’s corporate policies. Continued effort is required by SEGX to meet these goals.

With respect to IFC performance standard 1 (2006), the past and ongoing assessments address the key objectives of the standard. However there are some areas which require ongoing improvement and would benefit from additional studies as detailed below.

IFC performance standard objective Conclusion

Identify and assess social and environment

impacts, both adverse and beneficial, in the

project’s area of influence.

Past studies have identified the potential social and environmental impacts associated

with the project. However, the assessment of these impacts is varied in detail and in

some cases is inconsistent with international standards expected for these types of

assessments as reported by UNDP-Hatfield (2008). SEGX has acted to address these

inconsistencies, including commissioning; (i) a forestry biodiversity study (FFI 2011):

(ii) additional ocean water quality and pollution dispersion modelling study (SCSIO

2010, TRIWTE, 2009); (iii) additional air quality monitoring (BEMC, 2010); (iv) a detailed

technical description of the mill operations (SEGX, 2010a); and (v) this summary IESIA.

Additional initiatives include the development of an Integrated Operational Site

Planning (IOSP) handbook for forestry operations that includes a site-specific screening

checklist (SEGX, 2010b). Even so gaps in detailed baseline monitoring and cumulative

impacts assessment remain.

Avoid, or where avoidance is not possible,

minimize, mitigate, or compensate for adverse

impacts on workers, affected communities,

and the environment.

SEGX has implemented mitigation measures in the design of the mill facility that are

expected to achieve BAT emission standards, developed an Integrated Operational Site

Planning (IOSP) handbook to manage potential impacts associated with its plantation

estate and is undertaking ongoing improvement of the SEGX social engagement

and land leasing program to avoid or minimize adverse impacts on workers, affected

communities and the environment. The effectiveness of these programs will be

contingent on their continued implementation, ongoing monitoring and continual

improvement.

With regard to positive impacts, the mill operation is likely to create new skilled work employment opportunities for local residents, along with other, non-direct, employment opportunities in related businesses including restaurants, hospitality, local shops and transport. Using industry standards, total direct and indirect employment of the mill, plantations and supporting industries at full scale will be in the order of 30,000 people. In addition, there is potential for skills development of local staff, technology exchange, and improvement in environmental management and monitoring for all industries within the Tieshangang Industrial Zone.

While SEGX has demonstrated expected operational emissions within Best Available Technology (BAT) and developed a series of risk management and operational procedures, potential negative social and environmental impacts are difficult to avoid. The key potential adverse impacts identified as part of past assessments include:

» Potential impacts on water quality: Potential impacts on marine water quality could result from wastewater discharge from the mills via the ocean outfall, which will use a submerged multi-port diffuser. Past studies have concluded that, based on assessment of the baseline environment and hydrodynamic modelling of the marine discharge, the project would only have a minor impact on marine organisms and a slight impact on the environmental objectives for the adjacent marine reserves (RIEPG, 2008; TRIWTE, 2009). These studies have found that the discharge would not damage the stability of the marine ecosystem and would not impact on designated fishing areas. However, some deficiencies with respect to international best practice have been identified in the technical assessments (UNDP-Hatfield, 2008) and partly addressed in follow-up modelling (TRIWTE, 2009) and, as such, further modelling and assessment of potential impacts associated with the ocean outfall are recommended to be developed..

» Potential impacts on air quality: Background air quality monitoring completed for the proposed SEGX mill site in 2007 and 2010 did not detect any pollutants above the standards for Class 1 pollutants (Ambient Air Quality Standard GB3095-1996), H2S or odour. While this background monitoring program was more limited (duration and seasonal coverage) than would normally be done under international best practice, it provides a baseline indication of Class 1 air quality at the mill site prior to facility development.

Based on the air quality modelling of emissions expected from the proposed mill operations, past reports have concluded that the maximum average concentration of SO2 and NO2 are expected to be within the applicable air quality standards, with the predicted maximum ground level concentration of pollutants SO2, NO2 and inhalable particulates significantly below the applicable evaluation standard (RIEPG 2008). However, some deficiencies have been identified in modelling applied to air quality with regard to international best practice.

» Cumulative Impacts: Existing and future activities within the Tieshangang Industrial Zone have the potential to contribute to cumulative environmental impacts, in particular impacts on water and air quality. The existing or proposed industries include a polypropylene facility, crude oil storage, coal fired power station and a stainless steel plant. All have the potentially to contribute to negative environmental impacts on water and air quality. This gives rise to two potential issues; (i) further work on water and air quality modelling is recommended to assist SEGX in any potential future disputes of pollutant impacts related to other neighbouring industries; and (ii) the potential cumulative impacts associated with these industries on the environment is an important consideration that has not yet been assessed in the past reports reviewed as part of this assessment. In this regard, ambient water and air quality monitoring programs would ideally be integrated with those operated by others facilities within the Industrial Zone to enable an efficient and coordinated program.

» Social Effects: The initial establishment of the mill site resulted in resettlement of 1,236 villagers from the site to a new area approximately 2 km away. The resettlement, managed by Beihai City, along with resettlement of villagers from other areas of the Tieshangang Industrial Zone not related to SEGXs’ operations, included monetary compensation and an on-going allowance for each person affected in accordance with local government policy. Based on community surveys of the affected people, issues of inadequate compensation and lack of new employment opportunities have been identified. SEGX has implemented measures to monitor the process of compensation and employment opportunity. However SEGX cannot directly supervise it, as local government policy determines the extent of SEGX’s involvement. SEGX has maintained regular contact with the affected people and continues to communicate openly with them regarding their issues and potential solutions. Once SEGX has financially committed to the project there will be further opportunities to undertake activities which may include: (i) preferential employment opportunities at the mill; (ii) training to develop new skills including skills to access indirect related employment opportunities such as hospitality business opportunities; (iii) ongoing regular consultation; and (iv) community development opportunities such as education support and urban park land and recreational zone development.


1. Introduction1.1 Overview

Stora Enso in Guangxi (SEGX) has proposed the development of a Kraft pulp, paper and board mill and associated forestry plantation estate (collectively the project) in southern Guangxi Zhuang Autonomous Region (Guangxi), People’s Republic of China (PRC). The proposed scope of the project includes a Kraft pulp mill with 900,000 air-dry tonne per annum (ADt/a)

capacity and a paper and board production mill with a capacity of 900,000 tonne per annum, supplied with a fibre sourced from approximately 130,000 hectares of Eucalyptus plantation on a total land area of 160,000 hectares.

SEGX’s plantation operations in Guangxi commenced in 2002 with the intent of establishing a sustainable fibre base for the proposed mill operations. As of August 2010, SEGX had contracted 84,600 hectares of land, with an additional 41,200 hectares offered by city governments, totalling 125,800 hectares.

The project received relevant environmental approvals from the Chinese Ministry of Environmental Protection (MEP) on 4 December 2008, based on separate environmental impact assessment (EIA) reports for the mill and the plantation operations, prepared by Chinese environmental institutes (RIEPG 2008 and CRAES 2008 respectively).

As part of the approval process, project design, SEGX environmental management systems and corporate social responsibility commitments, and interested third parties, several internal and independent studies, supporting documents and special subject reports have been undertaken assessing the potential social and environmental effects of the project in addition to the two EIA reports prepared for regulatory approval.

To evaluate the project with respect to leading international environmental and social impact assessment standards, Stora Enso collaborated with UNDP to commission an independent third party review of the key reports in 2008, which provided recommendations to strengthen the impacts assessments, address baseline information gaps and strengthen ongoing stakeholder consultation (UNDP-Hatfield, 2008).

This Summary Integrated Environmental and Social Impact Analysis (IESIA) Report provides an independent third party consolidation of over 60 previous reports, studies and reviews related to the project and its potential environmental and social impact, and seeks to review and address some of the specific gaps identified in previous studies with complementary assessments, in water quality, air quality, transport, and social assessment included as Appendix A to D of this report. The complementary studies identify some areas for further data requirements and present recommendations for ongoing assessments.

The summary process has not attempted to validate the results of previous studies, neither is it intended to replicate significant volumes of detail from past reports. Rather the report aims to provide a concise summary of the project details, existing environment, and a consolidated review and evaluation of key potential social and environmental impacts associated with the project in accordance with relevant international guidelines.

1.2 Stora Enso in ChinaStora Enso (SE) is a global paper, packaging and wood products company producing newsprint and book paper, magazine paper, fine paper, consumer board, industrial packaging and wood products. In 2009 the SE group had some 27,000 employees and 88 production facilities in more than 35 countries worldwide and is a publicly listed company in Helsinki, Finland, and Stockholm, Sweden.

SE has been active in the Chinese market since the mid-1980s as a supplier of paper, board and pulp products. In 1998 the company bought out the majority shareholder in the Suzhou fine paper mill and in 2008 SE started production of super calendered paper in a joint venture with Shandong Huatai Paper. SE also owns two core board plants which are situated in Hangzhou and Foshan.

SEGX was established in 2002 as a foreign owned enterprise in Guangxi, with the mission to establish a sustainable fibre base to supply raw material to the proposed integrated pulp and paper mill. At the time of writing, SEGX was 100% owned by Stora Enso Pulp and Paper Asia AB, with a planned joint venture to be established with a state owned enterprise as appointed by Guangxi government. .

Since 2002, SEGX has been developing a Eucalyptus plantation base in the Guangxi. The company is currently seeking to expand its dealings in Guangxi, where it will use the existing forestry operations as a fibre source for the proposed Project.

Ensure that affected communities are

appropriately engaged on issues that could

potentially affect them.

This is an area for diligent management and continuous improvement. Social

surveys note community criticism of SEGX’s engagement with regard to the project

development. In response, SEGX is working with the local government and with directly

affected communities to provide information on project activities, timelines and new

developments. Prior and informed consent is required for all land lease contracts and

SEGX is working with the government and directly with the community to maintain

broad community support for the project. This work is supported by ongoing studies

and programs such as the recently commissioned social engagement study that

includes social surveys; ongoing socio-economic monitoring and proposed sustainable

development village based pilot projects.

Promote improved social and environment

performance of companies through the

effective use of management systems.

SEGX is required to operate in accordance with SE’s global corporate social responsibility

policy and code of conduct. SEGX forestry operations operate under an environmental

management system including an IOSP Handbook. Improved social systems are

being developed for the forestry operations. Environmental management systems for

the mill project are not yet developed, but will be put in place prior to construction.

SEGX operations in Guangxi have the potential to increase the awareness of social

and environmental performance issues within local government and enterprises, by

information exchange, leading by example and operating to international standards of

environmental and social management systems.


» Law of the People’s Republic of China on Prevention of Environmental Pollution Caused by Solid Waste, 1996

» Law of the People’s Republic of China on Prevention of Environment Noise Pollution, 1998

» Law of the People’s Republic of China on Evaluation of Environmental Effects, 2003

» Law of the People’s Republic of China on Promotion of Cleaner Production, 2002

» Energy Conservation Law of the People’s Republic of China, 2007.

With regard to requirement for environmental impact assessment, Article 16 of the Environmental Impact Assessment Law of the People’s Republic of China (2003) stipulates that an EIA is required for any capital construction project producing significant environmental impacts. The Management Guideline on EIA Categories of Construction Projects (2008) classifies projects into one of the following three categories: (i) Category A: projects with significant adverse environmental impact; (ii) Category B: projects with adverse environmental impacts which are of lesser degree and/or significance than those of Category A; and (iii) Category C: projects unlikely to have adverse environmental impact.

The SEGX Project was classified as Category A and required a full EIA report. This report was prepared separately for both the plantation and proposed mill operations, and subsequently approved by the PRC Ministry of Environmental Protection (MEP) in 2008 as summarised below in Box 1.

Box 1: Environmental Approval - As part of the process of achieving MEP environmental approvals for the project, SE engaged several certified Chinese Institutes to undertake the required assessment studies for the plantation and the proposed mill operations separately. An EIA Report (RPIEG, 2008) was prepared for the Mill Project, supported by separate studies on the potential impact of wastewater discharge from the proposed mill on the marine environment (SCSIO, 2007) and hydrological modelling of the wastewater dispersion at the proposed ocean outfall (RPIEG, 2008). A separate EIA was prepared for the plantation operations (CRAES, 2008), supported by key and important reference information included in the ESIA report completed by UNDP (UNDP, 2006). The two EIA reports were submitted to MEP for regulatory review in March 2008, and the first hearing was held. In June 2008, the authorities issued new regulations for mill effluents and SEGX was asked to incorporate the new requirements into the mill EIA report. This was completed, a follow up hearing on the amended report was held in October, and the approval for the Mill EIA and connected Forest Base EIA was granted on 4 December 2008 (MEP PRC, EE [2008] No. 491).

The approval describes the overall requirements and specifies how and by whom implementation and control of the permit should be enforced. With respect to details of performance requirements and emission limits it refers to the EIA report documentation and supplements to this. In addition to this there are standards and regulations on national level for all aspects of the mill and forest operations with which the company’s operations should comply. The key standards and regulations are cited in the EIA reports and comprise an integral part of the approval.

In addition to MEP approval, the State Forest Administration (SFA) issued approvals and conditions in 2008, as did the Ministry of Water Resources (MWR) and the State Land Resources Administration (SLRA). At the time of writing, final approval for the project from the National Development and Reform Committee (NDRC) was pending.

As part of the approvals granted, MEP indicated the project complied with the Chinese development policies for the papermaking industry, the 11th Five-Year Plan and the 2010 special planning for national forest paper integration construction (MEP, 2008), along with the following national standards: Emission Standard of Air Pollutants for Thermal Power Plants (2003); Emissions Standard for Industrial Enterprises Noise at Boundary (2008); Standard for Pollution Control on Hazardous Waste Storage (2001); Standard for Pollution Control on the Security Landfill Site for Hazardous Wastes (2001); and Standard for Pollution Control on the Storage and Disposal Site for General Industrial Solidwaste (2001).

1.3.2 International Finance Corporation (IFC) Guidelines

The IFC is a financier of SEGX’s current plantation operations and, as such, IFC is a stakeholder in SE’s operations and IFC environmental and social assessment guidelines, policies and performance standards are applicable. IFC and other international financing institutes may be potential financiers in the mill project. The IFC performance standards (2006) include eight performance standards covering aspects of sustainable development and these have been used as a guide for this review and assessment.

The IFC publishes a set of EHS Guidelines, which provide relevant industry specific reference documents outlining examples of good international industry practice and performance levels which are considered to be reasonably achievable in new

Within the framework of the 11th 5-year plan, development of the forestry industry received support from the Chinese government, both on a national and regional level. The proposed project subscribes to all national industry policies, as well as independent international environmental and social standards.

1.3 Regulatory ContextThe project is subject to several levels of regulatory requirements, guidelines and internal corporate policy, which require potential environmental and social impacts to be assessed in detail, mitigated where possible and management plans developed, implemented and monitored. Different regulations and guidelines require varying levels of assessment detail, different levels of emissions limits and different levels of tolerance for potential impact. The following regulatory and guiding standards (Table 1) are considered to comprise the key local regulatory and bench mark requirements for the project with respect to environmental and social performance. The subsequent section expands on these key regulations and guidelines.

Table 1 Key legislation and guidelines

Key Legislation and

GuidelinesComment

National and local laws

and regulations

Chinese law requires an EIA for the planned project. The Environment Impact Assessment Law of the People’s

Republic of China (2003) is the primary EIA legislation, triggering requirement for environmental assessment

for any construction project with the potential to result in significant environmental impacts. The EIA Law 2003

draws in relevant national emissions standards for air, water and soil pollution along with relevant standards for

land, forest and waste management and energy conservation legislation.

IFC Guidelines

The IFC is a financier of current SEGX plantation operations. As such IFC is a stakeholder in the project, and its

guidelines are directly applicable to the environmental and social impact analysis and management. Published

IFC performance standards and guidelines considered as part of this review and past assessments include:

» Performance Standard 1: Social and Environmental Assessment and Management System

» Guidance Note 1: Social and Environmental Assessment and Management System

» IFC-EHS Guidelines for Forest Harvesting Operations

» IFC-EHS Guidelines Pulp and Paper Mills

SE EMS and CSR

Commitments

SE has a well-developed set of sustainability and social responsibility principles, summarised in an SE Code of

Conduct, which apply to all projects and employees globally, in a bid to promote consistently sustainable and

ethical business operations. These policies include environmental management systems (EMS), corporate social

responsibility (CSR) commitments and project specific principles and provide a valuable guide and bench mark

for the potential impacts associated with this project.

1.3.1 National and Local Laws and Regulations

China legislative requirements with regard to environmental approvals and operational compliance are covered by an extensive framework of laws, regulations, standards and specifications. Requirements with regard to social impact assessment are less developed, especially when compared to international standards. The following provides a list of the key laws applicable to environmental impact assessment. Further listing of applicable regulations, guidelines and specifications is provided in past studies (CRAES, 2008; RIEPG, 2008).

» Environment Protection Law of the People’s Republic of China, 1998

» Environment Impact Assessment Law of the People’s Republic of China, 2003

» Land Administration Law of the People’s Republic of China, 1998

» Law of the People’s Republic of China on Water and Soil Conservation, 1991

» Forest Law of the People’s Republic of China, 1998

» Law of the People’s Republic of China on the Prevention and Control of Water Pollution 1996

» Air Pollution Prevention Law of the People’s Republic of China, 2000


with stakeholders in active and constructive dialogue.

» A policy to operate according to SE values, policies and principles everywhere around the globe, respecting different cultures, customs and values of the societies where SE operates. SE policy is that projects and operations must comply with and, when necessary, go beyond the requirements of national legislation and regulations.

» SE addresses sustainability throughout its value chain, and expects its suppliers and partners to comply with SE policies and principles related to sustainability.

» To minimise impact on the environment, SE considers a life cycle approach and uses applicable control technologies. SE must use raw materials, energy and other resources efficiently. SE seeks to use products produced from renewable raw materials that are recyclable and safe to use. SE must verify the origin of wood and fibre, and will only procure them from legal and acceptable sources and promote sustainable forestry.

» SE must adhere to ethical business practices in all their activities. The policies honour and support globally accepted human and labour rights and seek to create a healthy and safe workplace for all of their employees.

SE has expressed its commitment to meeting and, when relevant and necessary, exceeding the requirements of Chinese national and local laws, regulations and standards with regards to environmental protection and monitoring (SE, 2010a). Specific to this project, SE has established a variety of sustainability initiatives that follow the company’s philosophies and standards, including (SE, 2010a): (i) training in Environmental Management Systems (EMS), Code of Conduct and Corporate Social Responsibility (CSR) for all staff from the start of the project; (ii) ensure that a reliable, transparent ESIA has been developed and is in place; (iii) all necessary environmental permits have been obtained; (iv) social and environmental sustainability requirements implemented in the supply chain; (v) systems in place to secure that contractors/suppliers are following human and labour rights; (vi) Environmental and Social Impact Monitoring Plan established and implemented; and (vii) a forest management plan is in place.

To support its sustainability policy, SE has also established a set of specific principles that are valid for the company’s operations and which shall also be implemented in all projects (http://www.storaenso.com/responsibility/our-approach/policies), including: (i) Principles for Sustainable Wood and Fibre Procurement and Land Management; (ii) Principles for the Development of Forest Certification; (iii) Principles for the Implementation of EMS; (iv) Transport Environmental Principle; and (v) Principle on Genetically Modified Organisms (GMOs). These principles, if applied rigorously, will strongly support the reduction and management of potential environmental and social impacts associated with the project.

1.4 Past Studies and Public EngagementThe nature of the project presents a complex and challenging set of potential and actual environmental and social effects and, as such, many technical studies, assessments, public consultation programs, community engagement and support efforts have been undertaken by SEGX, independent consultants and others as part of the development of the project. Among these studies and reports are:(i) two EIA reports prepared as part of the MEP approvals process for the project as detailed above (CRAES, 2008; RIEPG, 2008): (ii) an ESIA of the plantations conducted by UNDP China in 2006, which identified major challenges in the social dimensions, while potential environmental impacts where seen as manageable through appropriate operational control and monitoring (UNDP, 2006); and (iii) an independent review of the EIAs with regard to IFC and other international best practice (UNDP-Hatfield, 2008), which identified gaps to be addressed in the existing assessments to meet IFC guidelines. In addition to these assessments, periodic reviews have been made by the IFC analysing the SEGX future plans and actions.

The gaps identified by UNDP-Hatfield (2008) included updated social impact assessment reflecting the full scope of the current and planned project, additional studies on environmental impacts on marine environment, assessment of impacts of changes to transport, and impacts on biodiversity associated with the plantation, among other things. The key findings from the UNDP-Hatfield report are important to note with regard to assessing the proposed project against international best practice, IFC guidelines and SE policy and are summarised in Box 2.

facilities through the implementation of existing technologies or management strategies. These guidelines identify potential environmental, occupational health and safety and community health and safety impacts. Two of these guidelines are directly applicable to the project: (i) EHS Guidelines for Forest Harvesting Operations (IFC, 2007a); and (ii) EHS Guidelines for Pulp and Paper Mills Guidelines (IFC, 2007b). This report has used these EHS Guidelines as a basis for evaluation of the project and previous studies.

As part of, and in addition to, these guidelines and standards, the IFC expects clients to gain broad community support (BCS) for projects likely to generate significant adverse impacts on local communities through the engagement of free (of intimidation and or coercion), prior (timely disclosure of information) and informed (relevant, understandable and accessible information) consultation (FPIC). BCS is defined as a collection of expressions by affected communities in support of the proposed business activity. IFC note that BCS may still be attained where some groups or individuals object to a project (IFC, 2006).

The IFC (2006) also provides some well-developed community engagement guidelines which are applicable to the social effects associated with the project. To support the subsequent section on social impact assessment, it is useful to summarise the key IFC guideline processes for community and stakeholder engagement.

Disclosure of Information: Any expected potentially adverse impacts identified as a part of the social and environmental assessment of the project should be disclosed to the community and key stakeholders at an early stage. The community and stakeholders should also be informed of details such as the duration, nature and scale of the project. Sufficient information should be made available to the potentially affected community and stakeholders in accessible and understandable formats, with the use of appropriate vectors for providing information (e.g. local print media, radio broadcasts). If there are going to be ongoing effects/impacts to the community and stakeholders as a result of the project, then continuing provision of information should occur (IFC, 2006; 2007).

Consultation/Engagement Process: The underlying purpose of community engagement as a part of any project is to establish a relationship with the potentially affected community, with the aim of allowing the project to proceed with support. The engagement process should take into account the communities’ views, interests and concerns on the project and also specific needs of the community. The consultation/engagement process should be undertaken using the FPIC principles (IFC, 2006; 2007).

Grievance Mechanism: SE should implement grievance mechanisms in order to deal with community concerns relating to the project’s environmental and/or social performance. These mechanisms should be in place throughout the life of the project and should be made clear to communities and key stakeholders during the engagement process (IFC, 2006; 2007).

Along with the IFC guidelines, several other relevant international standards and guidelines have been considered as part of this summary IESIA and during past independent reviews of project environmental and social studies, including: (i) Asian Development Bank (ADB) Environmental Assessment Guidelines, (ii) European Union (EU) Directive 97/11/EC, specifically Annex IV, (iii) Canadian Federal Government, the Canadian Environmental Assessment Act; (iv) Forest Stewardship Council International Centre. FSC Social Strategy: Building and Implementing a Social Agenda. Version 2.1 2003; and (v) Community, company grievance resolution: A guide for the Australian mining industry, Oxfam Australia.

1.3.3 Stora Enso Policy

SE has an established set of sustainable and socially responsible policies and principles, summarised in a Code of Conduct that applies to all projects and employees globally, to ensure consistently sustainable and ethical business operations. SE strives to implement internationally recognised management systems and seeks certification for its different operations including: (i) FSC and CoC certification; (ii) ISO 14001 Environmental Management; (iii) OHSAS 18001 Occupational Health and Safety; and (iii) ISO 9001 Quality Management.

The SE policies, tying into the IFC guidelines, have been applied in the subsequent sections to evaluate the proposed project design and implementation to date and the SEGX approach to addressing some of the environmental and social challenges that have arisen. Some of the key aspects of SE policies relevant to the proposed project include the following:

» A commitment to managing and developing its business in a sustainable manner, balancing its economic, environmental and social responsibilities to maintain a sustainable business and create benefits for stakeholders.

» An ambition to continually improve sustainability performance, including transparent communication and engagement


as being a lower priority for SEGX until a firm investment decision has been reached on the full project. Also, cumulative impact assessment for the mill project with other planned operations in the Tieshangang Industrial Development zone remains outstanding. A strategic environmental assessment was made for Tieshangang Industrial Development Zone by the authorities after 2009. This report was however not available for this ESIA review.

The reference section of this report presents an extensive list of documents, reports, community engagement programs and related material that has been drawn on as part of this Summary IESIA. In particular, the following have been considered as key Project documents:

» UNDP-Hatfield, 2008; Independent Review of Environmental Assessments of Stora Enso’s Proposed Pulp, Paper and Board Mill Project and Associated Forest Plantations in Guangxi, China, prepared by UNDP-Hatfield in 2008;

» UNDP, 2006; Environmental and Social Impact Analysis - Stora Enso Plantation Project in Guangxi China, prepared for Stora Enso in February 2006.

» RIEPG, 2008; The 900,000 Ton Pulp and 900,000 Ton Paper and Cardboard Project of Stora Enso (Guangxi) Pulp & Paper Co., Ltd, Environmental Impact Report. Research Institute of Environmental Protection of Guangxi Zhang Autonomous Region, 2008.

» CRAES, 2008, Stora Enso (Guangxi) Forest, Pulp paper Company Ltd 900000 T/a of Pulp, 900000 T/a of Paper and Paper Board Project, Raw Material Forest Base, Environmental Impact Assessment, Chinese Research Academy of Environmental Sciences, 2008

» Guangxi Forestry Institute, 2007, Analysis on Sustainable Development and Silviculture Technique of Eucalyptus Plantation in Guangxi, China

» TFRI, 2007, “Impact of Stora Enso’s Eucalypt Plantation Industry in Guangxi on Regional Water Resource and Ecosystem Sustainability- A Study Report”, Tropical Forestry Research Institute of Chinese Academy of Forestry, 2007

» SE, 2010, “Guangxi, Mill project study - Technical Description, Pulp Mill design”, Compilation based on material from Tiger Project Feasibility Study made for the UNDP, IESIA Summary project, June 2010

» SE, 2009a, Sustainability Report 2009

1.5 Report Purpose and ObjectivesThe aim of this Summary IESIA is to consolidate previous environmental and social studies undertaken for the project into a single public summary report. The report also seeks to address specific gaps in previous studies with supporting complementary studies. The overarching objectives of the analysis are summarized as follows.

» Create an independently reviewed public summary IESIA report for the proposed project.

» Engage different stakeholders in the environment and social assessment process.

» Conduct complementary studies to address gaps in previous environmental and social impact assessments. The complementary studies include: (i) review and update of the Social Impact Assessments documentation to include and reflect the full scope of current and planned operations and areas for SEGX’s activities; (ii) complementary assessment of effluent discharge to the marine environment and review of air quality assessment; (iii) an outline Environmental Monitoring Programme for air and water quality; and (iv) logistic and transport environmental and social impact analysis and recommendations for mitigation of impacts.

The Summary IESIA is not intended to be a comprehensive or extensive assessment of all potential environmental and social impacts associated with the planned project; rather it focuses on the key potential environmental and social impacts identified in past studies and provides guidance for monitoring, management and mitigation of those impacts.

The process of analysing and summarising previous studies and assessments completed as part of this Summary IESIA has not attempted to validate all the data and results of previous studies, neither is it intended to replicate significant volumes of detail from the reviewed reports. As such, this report is not intended to meet the requirements of a full IESIA.

The impact assessment does not extend to cover potential cumulative and associated environmental and social impacts associated with the Tieshangang Industrial Zone including related infrastructure, sediment dredging and new port development.

As a foreign company operating in China, SEGX has restrictions as to the mapping and spatial data it can access and reproduce. This report therefore does not include detailed mapping of the plantation estate and transport routes nor detailed mapping of the Tieshangang Industrial Zone.

Box 2: Existing ESIA Gaps Relative to International ESIA Standards - The primary objective of the UNDP-Hatfield (2008) review process

was to assess the two key EIA reports prepared for the project (CRAES, 2008; RIEPG, 2008 draft version dated November 2007) and the

UNDP Plantation ESIA (2006) report against international standards. In this case, the IFC guidelines including performance standards was

selected. The review team did not undertake site visits and based their conclusions solely on the review of existing documentation. The

RIEPG 2008 reference was reviewed by UNDP-Hatfield as a draft report, which did not include information on the multiport effluent diffuser

that was included in the final version.

The report separated conclusions between the forestry plantation and the planned mill operations, as summarised below. In May 2005, IFC

granted a loan to SE in China. One objective of the plantation project ESIA (UNDP 2006) was to meet social and environmental requirements

of multilateral lending institutions, such as the IFC, for project support.

Forestry Plantations: The primary gaps with respect to IFC guidelines identified for the forestry plantation ESIA included:

» Lack of site-specific biophysical and spatial data,

» Potential impacts of transportation were not considered, and

» Potential cumulative effects of the plantation and other relevant developments were not considered.

Proposed Mill: Several inconsistencies were identified between the EIA report for the Mill and relevant IFC guidelines. However, it was

noted that this did not necessarily reflect deficiencies in the report with respect to Chinese national standards and approvals, as IFC

guidelines were not required to be considered as part of the assessment. The primary gaps with respect to IFC guidelines included:

» Data and assessment methodology inconsistencies and lack of internationally accepted approaches to quantify impacts and

modelling. UNDP-Hafield (2008) noted the following examples as absent in the Mill EIA report assessment: identification and

assessment of valued ecosystem components, quantification of the magnitude, extent, and duration of residual effects and

assessment of cumulative effects of this and other projects.

» Deficiencies in the project description, including: (i) limited information on the proposed design of the submarine multi-port

effluent diffuser (required for accurate effluent-dispersion modelling); (ii) lack of a consolidated list of all air emissions and their

characteristics (required for modelling); and (iii) lack of descriptions of project elements beyond the mill complex, such as associated

transportation.

» Insufficient quantity and quality of baseline information for land use, transportation, climate and air quality, oceanography and

marine water quality, marine mammals and socio-economic characteristics of local communities.

» Qualitative conclusions on environmental impacts, where international standards would require quantitative conclusions supported

by adequate baseline data and modelling.

To strengthen existing studies and meet IFC guidelines, the UNDP-Hatfield (2008) report recommended developing a revised set of stand-

alone documents specifically covering:

» Consolidated baseline data and collection of additional baseline data in accordance with international standards, specifically for: (i)

marine water quality (particularly depth-stratified and seasonal data); (ii) seasonal meteorology (particularly winds); (ii) habitat use,

abundance and ecology of local marine mammals; (iii) existing transportation networks and their use; and (iv) demographic and

economic data describing local communities

» Revised air-quality modelling

» Revised effluent-dispersion modelling. As noted above, the November 2007 draft was subsequently strengthened with additional

information on the effluent dispersion; however modelling was limited to 2 dimensional modelling

Some of the gaps and deficiencies relative to international best practice in the previous EIA studies as outlined in Box 2 have been addressed with complementary studies completed as part of this report with other gaps addressed by SEGX directly and in separate studies commissioned by SEGX. As a result, this report does not intend to address all gaps identified in the UNDP-Hatfield (2008) report.

SEGX has acted on these recommendations to address the gaps identified, including commissioning: (i) a forestry biodiversity study (FFI, 2011); (ii) additional ocean water quality and pollution dispersion modelling study (TRIWTE, 2009); (iii) additional air quality monitoring (SCSIO, 2010); (iv) a detailed technical description of the mill design (SEGX, 2010); and (v) this Summary IESIA, along with development of an Integrated Operational Site Planning (IOSP) Handbook for the forestry operations, including a site-specific screening checklist (SEGX, 2010b). However, gaps in detailed baseline monitoring remain and have been indicated


2. Project Description2.1 Overview

The Project includes a large-scale mill that will produce pulp, paper and/or paperboard and associated Eucalyptus tree plantations that will supply the raw material to the mill. The general features of the project are summarised in Table 2.

Table 2 Summary of the General Features of the project

Parameter Unit Value

Total Proposed Investment RMB 23 billion RMB, total project cost, plantation and mill investment

Targeted forest base ha 160,000 ha of which 130,000 will constitute the plantation estate fibre base

Annual production scope tons/aTotal application scope 1,800,000 tons of pulp, paper and board. Phase 1 - Pulp mill; 900,000 ADt/a, Phase 2 - Board mill 450,000 t/a, Phase 3 - Paper mill; 450,000 t/a

Project commencement Year 2002 start of plantation establishment

Start of mill production Year Forecast, 2015 with pulp mill as first phase, followed by board and paper production in subsequent years

Current total plantation area ha Approximately 125,800 as of August 2010, under SEGX management or offered for lease

Wood raw materialEucalypt hybrids predominantly E. urograndis

(from E. grandis and E. urophylla)

Wood consumption for pulp production Mm3 sub Approximately 3.4 million m3 solid under bark

Mill process water source From Hepu reservoir system, via centralized supply by pipeline to Tieshan Port Industrial District

Mill Water consumption Mm3/a In phase 1, 25. For the total application scope, phase 3, 40.

Effluent outfall location Tieshan Port in Beibu Gulf

Production mode days Minimum 354 days/a, continuous operation with annual maintenance shutdown

Raw material and product transport

The Mill will be established in a new industrial port development and connected to road, rail and ocean transport infrastructure. Trucks dominate the wood and chemicals deliveries while majority of product transport will be by ship.

Employment (Refer Table 15)

Forest operation and wood supply:

SEGX direct jobs: 1,270

SEGX permanent direct outsource jobs: 5,900

Mill integrate, full application scope:

SEGX direct jobs: 1,200

SEGX permanent direct outsource jobs: 200

1.6 Report StructureThis report is structured as follows:

» Section 1: Introduction – outlines a brief introduction to Stora Enso, a summary of the objectives and limitations of this report, a summary of the regulatory and legal context and a list of the key past studies and assessments.

» Section 2: Project Description – describes the project, including location, the plantation estate, the mill and provides a BAT evaluation.

» Section 3: Social and Environmental Setting – outlines a summary of the social, economic and environmental characteristics of the project area, including socio-economic data, existing land use, biodiversity and ambient water and air quality baseline data.

» Section 4: Social and Environmental Impacts – provides an assessment of the potential key social and environment impacts associated with the project, including a discussion of cumulative impacts.

» Section 5: Mitigation Management Plan – includes social and environmental development and investments.

» Section 6: Environmental and Social Monitoring – outlines management strategies to help ensure a socially and environmentally responsible project development.

» Section 7: Summary and Conclusions.

» Appendices - includes complementary studies undertaken as part of this Summary ISEIA, addressing gaps in transportation, air quality, water quality and social impact assessments.


Environment approval Approval received December 2008 for the Mill Application scope and connected Forest Base

Treated effluent load, approval level

Flow

BOD5

COD

TSS

AOX

Total nitrogen

Total phosphorus

m3/d

t/d

t/d

t/d

t/d

t/d

t/d

Weighted for application scope production, phase 3

92,660

1.85

8.34

2.78

0.38

0.74

0.07

The Project was initiated in 2002 when SEGX began work to develop a plantation estate in Guangxi to secure the raw material supply. SEGX aims to plant about 130 000 hectares with Eucalyptus trees, over a total contracted plantation estate of 160,000 hectares.

The proposed mill is in the final planning stages and will be developed in three phases. Phase 1 will include a Bleached Hardwood Kraft Pulp (BHKP) mill. Phase 2 will include a board mill and phase 3 will see the addition of a paper machine to the mill.

The following section provides a summary description of the project, including details of the planned mill operations for the application scope, the technology applied and potential emissions, along with a description of the plantation estate, the approach to land contracting and plantation operations. Information presented here is largely based on past studies and information provided by SEGX. Where appropriate, comparison has been made with BAT and international best practice.

2.2 Project LocationProject forestry operations, mill site, and transport infrastructure linking the two are collectively referred to throughout this report as the project area. The project area is located in the southern part of Guangxi (Figure 1). Guangxi is divided into fourteen Prefectures, with the project forest operations spread between eight (listed in order of land area contracted: Beihai, Yulin, Nanning, Qinzhou, Chongzuo, Guigang, Fangchenggang and Wuzhou). The total area of land designated for commercial forestry in Guangxi is 7.8 million ha (UNDP, 2006). The project will lease approximately 2% of this available commercial forestry land.

Figure 1 Guangxi Zhuang Autonomous Region and Project Prefecture Level Cities. (Adapted from: http://en.wikipedia.org/wiki/Beihai)

The mill site is located within Beihai Prefecture, highlighted in Figure 1, in the Tieshan Port District, and will be part of the Tieshangang Industrial Zone1, a newly developed port and industrial zone.

2.3 SEGX Plantation Estate SEGX forestry operations in the Guangxi started in 2002 and the target is to establish a 160,000 hectares land base and about 130,000 hectares plantation estate (based on Eucalyptus plantation) by the time the SEGX mill starts production (SE, 2010). The total wood consumption for a 900,000 ADt/a pulp mill will be approximately 3.4 Mm3 of Eucalyptus wood. It is anticipated that all of the wood will eventually be supplied from the SEGX’s own plantations.

As of August 2010, SEGX had contracted a total of 84,627 hectares of land with an additional 41,258 hectares offered by city governments, being a total of 125,885 hectares (Figure 2). The contracted plantation land exists as both connected and isolated parcels of forestry land, inter-mixed with other (non-SEGX) forestry plantation operations, villages and other land uses. While covering a large total area, the plantations do not exist in large consolidated blocks; rather they are scattered throughout each Prefecture. As described in Section 3, forestry plantations have been the dominant land uses in Southern Guangxi for many decades. The majority of forestry land contracted by SEGX had previously been used for forestry operations by Chinese operations.

Plantation estate land currently contracted by SEGX is spread amongst 27 Counties2. Of the total area of currently contracted and offered land of 125,885 hectares, 36,154 hectares (29%) is social land and 89,732 hectares (71%) is state land (as shown in Table 3). The majority of the social land is located within Behiai and Yulin Counties. State lands are located within five city areas: Beihai, Yulin, Nanning, Qinzhou and Chongzuo.

Figure 2 SEGX Plantation Estate

1.The Tieshangang Industrial Zone is also referred to as the Tieshangang Port and Industrial Zone or Tieshan Port and Industrial Zone in various literature and past studies. 2. The 27 Counties are Beihai, Hepu, Beiliu, Bobai, Fumian, Luchuan, Rongxian, Xingye, Yuzhou, Binyang, Nanning, Shanglin, Wuming, Lingshan, Pubei, Qinzhou, Chongzuo, Fusui, Ningming, Dongxing, Fangcheng, Gangkou, Shangsi, Guigang, Guiping, Pingnan, and Tengxian.

http://en.wikipedia.org/wiki/Beihai


recorded.

State land: under the commitment of Guangxi government, 8 state forest farms will provide forest land to SEGX. The land planning department checks the suitability of the offered land for Eucalyptus plantations based on the Land Use Plan (LUP) Criteria, which includes physical and social criteria. Land which does not fulfil the criteria is either rejected or only accepted as non-Eucalyptus area for meeting the 20% requirement of the State Forest Administration for non-Eucalyptus species.

The regional planning team and the district manager, the sustainability team and the harvesting team check physical land criteria and social risk connected to the offered land. This checking includes, but is not limited to, questions such as;

» Can we operate on this land in the future?

» Has any villager raised any objection of land ownership?

» What does the surrounding environment of the land look like?

» Has there been any conflict or violence in this area?

» What is the general condition of the land, road network, adjacent villages, remoteness of location etc?

When the regional risk checking is done, the land contracting and transfer will be processed and assessed by the legal counsel under the condition that both parties agree on the land value evaluation outcome.

BOX 3; Principal steps in land contracting process for social land. [LUP; Land use plan criteria, for sustainable fibre base in state and social lands]:

Table 3 SEGX Contracted and Offered Land (August 2010)

State land (by Forest Farms) Contracted State Lands (ha)

Offered State Lands (ha) Total (ha)

Bobai Forest Farm 9,743 8,298 18,041

Dongmen Forest Farm 6,742 1,510 8,251

Gaofeng Forest Farm 4,553 12,250 16,803

Liangfengjiang Forest Farm 400 573 973

Liuwan Forest Farm 1,948 3,995 5,943

Paiyangshan Forest Farm 3,574 1,733 5,306

Qinlian Forest Farm 20,710 3,548 24,259

Qipo Forest Farm 4,124 6,032 10,156

Total 51,794 37,937 89,732

Social Land (by County)

Beihai 22,378 3,137 25,515

Yulin 7,012 102 7,114

Qinzhou 797 22 819

Fangchenggang 707 60 767

Guigang 1,510 - 1,510

Wuzhou 429 - 429

Total 32,833 3,321 36,154

2.3.1 Land Contracting

Property rights in China as they relate to this project include: (i) ownership (ownership rights can be either in the hand of the state or the village collective); (ii) user rights - land use rights for farming, housing, business; (iii) timber rights - right to grow and harvest timber; and (iv) timber use rights - right to use forestry lands for secondary uses such as resin tapping, livestock grazing and other non-timber uses.

In 2003, SEGX signed an agreement entrusting Guangxi Gaofeng Group to lease social forest lands on behalf of the government. As a state-owned stock company, Guangxi Gaofeng Group contracted with forestry farmers to lease forest lands based on a condition assessment and the price at that time. Guangxi Gaofeng Group handed over the contracts signed with farmers to SEGX in 2005.

In 2006, to further develop the wood supply base of the plantation and SEGX mill, the Beihai government established the Beihai City Forestry Investment Development Limited Company (BHC) to work with SEGX. The BHC was entrusted by the Beihai government in signing land agreements with SEGX and forest farmers.

SEGX developed a social land contracts management process to govern the land contracting process, which was implemented from September 2006 and has been continually improved over recent years. Box 3 outlines the principal and common steps of SEGX’s social land contracting process.

SEGX has established processes for the acquisition of state land and social land respectively. The detailed content of the process is adapted to the governance of the land to be leased, whether it is state land or social land. All steps of the process are also


several stakeholders to discuss survey questions. A small survey module focused on; (iii) households in migrant villages of origin (in Yunnan and Northwest Guangxi); and (iv) small groups in these villages (Table 4).

Table 4 UNDP (2006) Survey Details

Location Survey Code Target Group No of

Respondents

Project area (village land) A

Households in villages renting private land to Stora Enso, some of whom are also renting collective land to Stora Enso

244

Non-Project area (village land) B

Households in villages targeted for land rental to Stora Enso in the future or households in non-project areas

196

Project Area (state forest farm) C

Households of state farm workers on state farms renting land to Stora Enso. Interviewees have worked on Stora Enso land

181

Project Area (state forest farm) E

Households of state farm workers on state farms renting land to Stora Enso. No member of the households has worked on Stora Enso land.

143

Non-Project area (state forest farm) F

Households of state farm workers on state farms that are either targeted land rental areas for Stora Enso or non-project areas.

68

Project Area (state forest farm) D

Households in villages not renting to Stora Enso and living near a state forest farm that is renting to Stora Enso. Interviewees have worked on the state forest farm.

136

Non-Project area (state forest farm) G

Households in villages not renting to Stora Enso and living near a state forest farm that is either targeted for future rental or non-project area

32

Project area (village or state forest farm) H Migrants working in project areas, either in villages or

on state forest farms 50

Migrant place of origin I

Households in Yunnan and Northwest Guangxi villages of origin of migrants working on Stora Enso land

100

UNDP (2009), Participatory Impact Assessment Report: Individual interviews and group discussions were undertaken for the 2009 UNDP Participatory Impact Assessment. Surveys were conducted in Hepu county (Beihai municipality), Bobai county (Yulin) and Cao-Jiang and Dan-Tian village (Hepu) and Xi-Ling village (Bobai). Surveys included 60 household representatives (including 10 women) and interviews with Beihai Forest Investment Company, Hepu Forestry Bureau, Ningtan Forestry Station (Bobai county), and Xin-Gui Forest Company.

The results of these interviews and discussions were synthesized into a Social Impact Assessment (SIA) to capture the social impact of plantations from changes in land use policies. The report focused on the following aspects: (i) impact on local livelihoods especially local food security and cash generation at the community level; (ii) impact on the local livelihood capital, such as the natural, physical and human capital; and (iii) impact on local capacity building.

Stora Enso (2009), Social Research Survey: In-depth interviews were conducted at town government, village committee and village levels. The interviews focused on stakeholder’s opinions about SEGX, communication with the company and community development projects. The research covered 11 towns and townships, 31 village committees and 45 nature villages. Officials of 10 town governments, members of 24 village committees and 201 villagers were interviewed.

CAU (2010), Survey Report on the Forest Land Disputes: The China Agricultural University undertook preparation of a Survey Report on the Forest Land Disputes between Qinlian State Forest Farm and neighbouring villagers. The project research team conducted a 14-day field survey in a total of 25 natural villages neighbouring Qinlian Forest Farm in 4 counties (Hepu, Pubei, Qinnan and Lingshan). 253 questionnaires were completed including 232 households and 21 village leaders. Interviews were also conducted with relevant government departments and forest farms. The following

Social land (Beihai region): the social land is mainly located at Beihai region (BHR) and most of the social land has to date been acquired by Beihai Company (BHC).

When a new area of land is offered to SEGX by BHC, the Beihai regional planning department applies the LUP criteria to assess the suitability of the offered land as a fibre base. Additional criteria apply to certain areas or villages where leases are not considered due to high social risks that are identified and agreed beforehand with BHC. Risks are related to unclear land ownership and unclear land rental agreements signed by the village communities in the last 10 to 15 years.

After the physical site inspection by the planning department, the contract management team goes to the site to check the legal situation of the original contract with the land use right holder. In parallel the district management team studies the social risk of the offered land.

This checking includes, but is not limited to:

» Legal screening based on set criteria

» Interview the land owner for the land transaction history and any reasons for objections

» Existing conflict record and potential conflict over the forest operational cycle

» Historical conflict and violence cases

» Rental situation of the land owner.

» General condition of the surrounding land, such as roads, nearby villages, remoteness of location, social information etc.

The lawyer provides a report of the offered land based on 19 defined legal criteria and classifies it according to its legal status. Contracts are classed as “green” if contracts are legal and verified; “yellow” if contracts have some legal issues but they can be easily resolved and “red” if contracts have serious legal issues that are difficult to resolve.

The district manager checks the existing conflict data records and, based on the knowledge of the area plus the communication with the land owner and the information from related parties, reviews the social situation of the land.

Together this results in a land assessment report and a recommendation on whether the land can be operated or not and what potential social risk exists. Only when the district manager recommends acceptance of the offered land and the legal team gives a green status can the respective contract can be signed by the regional manager. The contracts with “yellow” or “red” status after the legal screening are returned to BHC for correction.

Social land (outside Beihai): Outside Beihai region, the social land acquisition approach is similar however the land acquisition is managed directly between SEGX and the holder of the land use rights.

2.3.2 Stakeholder Consultation

SEGX has undertaken significant efforts to engage with stakeholders, in particular the local community and villagers, in recent years. This is a very important and challenging part of the project development, and is in part a requirement for the land contracting process for social land3. During initial stages of the project development stakeholder consultations were conducted primarily through the Guangxi Gaofeng Group and the BHC. More recently SEGX has increased its direct engagement, consultation and communication with local stakeholders, through community surveys, socio-economic surveys and monitoring programs, local meetings and a local newsletter distribution. The following outlines key social surveys and impacts assessments completed for the project. Outcomes from these surveys have been used to identify impacts associated with the project along with generic impacts identified in literature.

UNDP (2006): As part of the 2006 ESIA a survey of communities and stakeholders was undertaken by UNDP. The assessment included questionnaire surveys and in-depth interviews with stakeholders at provincial, county and community levels. The questionnaire-based survey had several modules. The largest module consisted of a 1,000 household component in Guangxi, including households of local villagers, state farm workers and migrant workers. Other, smaller modules included surveys of: (i) leadership (both township governments and state forest farm management); and (ii) small groups (both in villages and on state forest farms), the latter consisting of gatherings of

3. The PRC Rural Land Contracting Law 2002 requires the consent of two-thirds of villagers or member-owners, or two-thirds of villager representatives and the approval of township government.


Box 4: Eucalyptus Forestry Plantations (adapted from UNDP, 2006) - Eucalypts, largely native to Australia, are among the world’s

most successful exotic trees, providing social and environmental benefits and resources for major wood fibre industries in many

countries. More than 16 million ha of plantations have been established globally, and have grown vigorously as exotics in other countries,

demonstrating a tolerance of a wide range of environmental conditions.

Eucalypts have been in China for over 120 years and in Guangxi for most of this time. The choice of eucalypts as a preferred plantation

species in southern China is no accident and has been based upon many years of scientific assessment and community experience, which

has demonstrated that they consistently outperform plantations of other species such as pines and acacias on most sites. Rates of growth

of eucalypt trees are often much faster in exotic locations than are experienced in their native forests, and usually very much faster than

local indigenous species. Though they grow fast, their evolutionary background still means they usually consume less nutrients and

water than indigenous species for production of the same amount of biomass.

In addition to this robust physiological adaption to a wide range of site conditions, eucalypts have several other attractive features which

have made them popular exotics:

» Ease of propagation: Eucalypts are easy to propagate. The seeds of the popular species are small (typically 600 000 per kilogram)

and are orthodox in behaviour and able to stored easily for long periods. These features have made them easy to distribute between

growers and countries. Despite their ease of propagation, eucalypts have demonstrated a very low potential to become weeds and

threaten local biodiversity through invasion of natural ecosystems.

» Capacity to grow fast: Typically, eucalypt plantations produce over 20 m3/yr and can be managed in short (<12 year) rotations).

On highly productive sites in Brazil, growth rates of over 50 m3/ha/yr have been recorded. This capacity to grow fast offers attractive

economic rates of return to farm level and industrial growers. Many popular species have the capacity to coppice offering productive

second rotation crops.

» Capacity to grow straight: Eucalypts demonstrate an apical dominance which results in straight growth and straight stems that are

easy to harvest and process and useful for a wide range of products and applications.

» Capacity to offer a wide range of wood and non-wood products: Eucalypts can produce a wide range of useful wood and non-

wood products. In addition to environmental and non-wood products such as site and habitat protection, carbon sequestration,

tannins and leaf oils, industrial chemical additives, adhesives and fodder additives, eucalypts provide many wood products –

construction timbers, furniture, farming tools, transmission poles, railroad sleepers, fuel wood, charcoal, honey, pulp and paper,

rayon, fibreboard and plywood.

Eucalypts are a preferred fibre source for a number of different pulps. Bleached Eucalypt Kraft Pulp (BEKP), made through the chemical Kraft process, is of high quality and is in strong demand internationally for the production of high quality printing and writing papers, as well as tissue, and also for the surface layer in board products.

2.3.5 Plantation Operations

SE has long and successful experience in establishing and managing commercially sustainable eucalypt plantations in a number of countries. Based on this experience and supported by a program of research and development, SE has prepared a detailed corporate management plan for its Guangxi plantation eucalypt operations which offers clear standards and operational guidelines which are consistent with SE corporate principles for sustainable wood and fibre procurement and land management (UNDP, 2006). SEGX is now certified according to OHSAS 18001, ISO 14001 and 9001 (www.storaenso.com/about-us/organisation/china/plantations/Pages/default.aspx).

The following presents a brief outline of the key operational aspects of SEGXs approach to Eucalyptus plantation management in Guangxi, including site selection, Eucalyptus propagation and breeding, site preparation and planting, stand management, use of chemicals and fertilizers and harvesting and transport. This summary has relied heavily on information presented in UNDP (2006).

Site Selection: SEGX aims to select lands that are existing forestry land, have slopes below 15°, exist within blocks of 100 ha, are accessible by existing roads, are close to the planned mill site and have clear legal title. Areas of natural forest or in other environmentally-sensitive areas are not selected for plantation establishment. There is no evidence to suggest that the plantation program will cause loss of human habitation or create the need for involuntary resettlement. To protect against environmental degradation the IOSP Handbook restricts forestry plantation establishment in sensitive

villages were surveyed: Hepu - Yongkang, Yongkang, Da Tianping, Da Tianmian, Ya Daliao, Bai Fenling; Qinnan - Qiao Touping, Tong Guwo; Pubei - Huangwu, Xin Tianchong, Changbu, Liang Toujiang; and Lingshan - Niu Jingyang, Shang Lianggen, Wu Jiaolu, Shi Bandong, Shui Lutian, Gao Gongtian, Da Shatou, Maotian, Huang Niyun, Dan Shuiwan, Qishan, Banqiao.

UNDP-GHD (2010, included as Appendix D), Southern Guangxi Project Report on Social Impact Analysis: This survey was completed as part of the IESIA and involved discussions with key agencies and local communities (focus groups) and the collection of a range of secondary statistical data for the project area. Key informant interviews involved discussions with village leaders, county agencies, enterprise managers and business people. Information collection included focus group discussions, rapid appraisals and surveys with stakeholders regarding issues such as social and economic impacts of the plantation (Table 5). Secondary data collection included contract templates, project management introduction and review of previous reports.

Table 5 UNDP-GHD 2010 Survey Scope (refer Appendix D for results)

Target groups Assessment method Location Participants

Guangxi Forestry Group Corporation Interview Nanning 5

Beihai Forestry Bureau Interview Beihai 2

Office of Beihai Beibu Gulf Economic zone Interview Tieshangang 1

Township forest station Interview Zhakou Township 1

Township Government Interview Zhakou Township 1

Resettlement Community Focus group Nanle community 14

Villagers Focus group Baisha Township 54

Villages leaders interviews Villages 19

Village group leaders Interview Villages 8

Contractors Interview Plantation site 2

Migrant workers Focus group Plantation site 8

Total 115

2.3.3 Rental Terms

Land rental price is often a very sensitive issue and farmers and villagers may sometimes have unrealistic expectations. SEGX is committed to paying rents in accordance with the market prices for forest land in Guangxi, valued by an official valuation house, following common practices. However, the market prices for forestry land have changed over time. As the forest industry has developed in Guangxi land prices have gone up, with market price development from 2004 towards 2008-2009, starting from 30-40 RMB/mu moving towards 70-80 RMB/mu. The rental price is also influenced by individual site soil characteristics and growth potential, steepness of slopes and distance from the mill.

In general, the duration of land lease agreements already in place is 15 years and rental prices are subject to escalation every 5 years.

2.3.4 Wood Species

The main wood species that will be used in the project are hybrids of Eucalyptus grandis and Eucalyptus urophylla, or Eucalyptus urograndis (Stora Enso 2010a). UNDP (2006) provides a detailed assessment of these Eucalyptus species and the history of their introduction into China, as summarised in Box 4.


Plate 2 Photo shows a variety of plantation ages, farming land and native vegetation buffers around farming land.

Stand management: SEGX has well developed stand management practices for weed control, protection from fire and insects and monitoring for pests and diseases. With respect to environmental impacts, the use of chemicals and fertilisers is the primary potential concern. To manage the risk of environmental impacts associated with chemicals and fertilisers, the SEGX IOSP Handbook forbids the use of herbicides closer than 50 m from a water course or pond. Chemical pesticides are not used as standard SEGX stand management practices.

SEGX does not use internationally banned pesticides or herbicides. The inorganic fertilisers used in their Guangxi plantations are commonly available and widely used in China. UNDP 2006 did not identify any environmental issues relating to the transport, storage or application of fertilizers by SEGX. The only herbicide reported used in Stora Enso’s plantations was glyphosate, a compound which is widely used in global agriculture and which, if used correctly, is considered benign. While SEGX has detailed management plans concerning glyphosate, UNDP (2006) noted that how these directions are communicated to contractors and field supervisors was unclear. Considering the local context, monitoring of storage, use and disposal of waste will be important to ensuring compliance.

Within the SEGX nursery, a broader suite of chemicals is used. The directions for storage and use of nursery chemicals are consistent with international practice and with SEGX obligations for the environment and occupational health and safety. Appropriate safety equipment and clothing has been brought from Finland where it is not available locally.

Integrated Operational Site Planning: The IOSP Handbook provides SEGX staff with an operational planning framework in compliance with SEGX policies and guidelines. It addresses potential environmental and social effects at the planning stage and prompts the documentation of potential issues.

Harvesting and transport: Due to the different types of terrain over the SEGX plantation estate, it is proposed that harvesting of Eucalyptus trees will be done by a combination of manual and mechanised operations. Approximately 70% of harvesting will be mechanised or semi-mechanised (Plate 3). All debarking will take place on site to return the bark to the soil to improve soil composition and reduce erosion.

The transportation of the wood to the mill will be outsourced, with an average transportation distance from plantation to mill of approximately 170 km. Stora Enso will also be investing in wood depots and the necessary machinery to operate these depots.

areas such as: (i) average slope greater than 25 degrees for state lands in Bobai, Payangshan and Liuwan Forest Farm and for social lands in Gongguan and Quzhang; (ii) average altitude is over 500 m in Gaofeng and over 600 m in other areas; (iii) soil depth is less than 50 cm; and (iv) and/or rock content is over 30 % if soil depth is 50-100 cm.

Eucalyptus propagation and breeding: SEGX has adopted a central nursery at Shankou as the basis for the supply of planting material. The nursery operates under strict quality control and schedule of planting stock. Recognising the need for tree improvement, SEGX has invested in research and development where tree breeding is strongly orientated towards wood quality and pulp yield per hectare. SEGX’s tree breeding program is based on conventional techniques of field testing, selection, open pollination for pure species development, controlled pollination for hybrid development and rooted cutting propagation for cloning. SEGX has no activities in the field of GMO (genetically modified organisms).

SEGX has been an active member of China Eucalyptus Breeding Alliance (CEBA) since its establishment in 2006. SEGX has additional collaborative Eucalyptus breeding programs with CAF (CERC and RITF) and Dongmen Forest Farm. Local species development is carried out in collaboration with GX Forest Research Institute, whereas acacia development is done solely by the company.

Stora Enso’s principles on GMO can be accessed on:

http://www.storaenso.com/responsibility/our-approach/policies

Site preparation: SEGX operational instructions call for planting along the contour lines, four (4) metres apart. This represents an improvement from previous practices of ripped lines and planting along the slope line rather than contour. Ripped lines along the slope line have been shown to cause significantly higher rates of soil erosion. On steep sites that are unsuitable for mechanised operations, planting holes are prepared manually. As the planting program expands, the use of excavators for spot cultivation on steep slopes will be considered. SEGX proposes the use of commonly available inorganic fertilisers (special compound fertilizer fused with calcium magnesium phosphate) in its site preparation process. Application will be adjusted to meet site needs. As detailed in the IOSP Handbook, the use chemicals and on-ground open spreading fertilizers and limestone is forbidden within 50 m of a water course or managed agricultural land.

Planting: SEGX uses a density of 1,250 stems per hectare (at 4 x 2 metres) which is consistent with practices in Brazil, Australia and South Africa and is lower than typical Chinese planting densities, which are around 2,222 trees per hectare. The SEGX proposed density allows for the option of mechanical harvesting at rotation’s end at Year 7. Planting is linked to soil moisture and guidelines call for watering-in should conditions become too dry. Plantations are established as clonal blocks to offer uniformity in management. The optimal period for planting is considered to be between March and April. It is anticipated that mechanized planting could account for 50% of the planting in the long run.

Plate 1 Mechanized planting

As detailed in the IOSP Handbook, an environmental buffer zone (non-fibre base plantation) must be developed around environmentally sensitive areas (Plate 2), such as water bodies (20 m buffer), trunk river (specified to be Nanliujiang, Beiliujiang, Zuojiang and Maolingjiang Rivers )(50 m buffer), and farm land (0-15 m buffer depending on the case).

http://www.storaenso.com/responsibility/our-approach/policies


and then paper production, with the resources for these extensions already planned. An agreement for the acquisition of the mill site land has been signed with the Beihai government and the people previously living within the boundaries of the mill site area have been resettled to a new residential area in Tie Shangang.

The regional physical infrastructure in Beihai City has sufficient capacity to absorb the requirements of the mill. Trunk road connections, power transmission, water supply and railway connections are already in place or under construction. The first phase of the Tieshangang harbour development is completed and can serve the mill both during construction and operation.

Figure 3 Beihai and Tieshangang Industrial Zone (RIEPG, 2008)

2.4.2 SEGX Pulp Mill Process Description

The SEGX mill will utilise the Kraft pulping process, which entails chemical treatment steps for converting wood into pulp fibers with high brightness and cleanliness. The Kraft pulping process will be used to meet necessary pulp quality demand of the products in phase 2 and 3 and for market pulp. A simplified diagram of the SEGX pulp mill process is provided in Figure 4.

It is anticipated that the mill will operate 354 days per year and will require 3.4 Mm3 of wood for the first five years of operation. Close to 4 million tonnes of raw materials will be handled annually, with average daily production targeting 2,542 t (Stora Enso, 2010a). The mill is expected to be operational within 26 months of an investment decision.

Figure 4 Simplified Diagram of the Pulp Mill Process

Plate 3 Mechanized harvesting. Bark and branches are left on site to reduce erosion and nutrient loss

The plantation operational practices adopted by SEGX in Guangxi are more advanced than the typical Chinese practices, and offer more consideration and safeguards against potential negative environmental impacts and health and safety risks.

2.3.6 Plantation Estate Workforce

The employment on SEGX plantations in 2009 was about 750 direct persons and 2,500 indirect (contract) labour and was estimated to reach 12,400 to 14,400 full-time jobs once the plantation operations reached full scale (UNDP, 2006). UNDP (2006) note four types of households that benefit from work on SEGX Plantations: (i) households in villages currently renting land to SEGX; (ii) households of project area state forest farm line staff; (iii) households in villages not renting land to Stora Enso, but located on or near a state-owned forest farm renting land to SEGX, with a household member having worked on SEGX land on the forest farm; and (iv) migrant workers that work on SEGX land in Guangxi.

Adequate skilled and semi-skilled labour is available in the area; however some skills will need to be sourced outside of Guangxi. In addition, contractors may source labour teams from outside the local area or outside Guangxi.

2.3.7 Transport

The following materials will be transported over the road system to the plantation areas. Transportation of logs to the mill site is discussed in the following section describing the mill.

» Fertiliser, which is typically applied at the rate of 1.37 t/hectare

» Limestone, which is typically applied at the rate of 1.50 t/hectare

» Seedlings, which are used at the rate of 1,250 seedlings/hectare

It is proposed that these materials will be transported from various sites to the plantations using small farm type trucks. Of these materials, seedling transportation will have the least impact on the road networks as the loads are relatively light. The total tonnage/year of these materials is estimated to be up to 60,000 tonnes.

2.4 Description of Planned Mill OperationsThe application scope of the SEGX mill for which the company received their environmental approval in December 2008 is: (i) pulp mill 900,000 ADt/a BHKP; (ii) packaging board 450,000 t/a; and (iii) printing / writing paper 450,000 t/a. The project is anticipated to proceed stepwise starting with the pulp mill investment. The following section provides an overview of the mill operations, focusing on the pulp mill design as the first step in the mill development.

2.4.1 Mill Location

The mill site is located in the Tieshangang Industrial Zone, Beihai Prefecture, Guangxi (Figure 3). The mill site is about 2 km from the coastline and about 40 km east from Beihai City. The land area of the site is 250 ha. The site area is considered large enough for a 1 million t/a SEGX mill and future production lines including paper and board. The plan is for the mill to extend into board


The pulp mill will use close to 25 M m3/a of water, with consumption approaching 40 M m3/a once the board and paper production is operational. The pulp mill water demand will be in the range 28-30 m3/Adt and the average discharge volume will be 25 m3/ADt. This discharge rate is comparable to that of operating modern eucalypt kraft pulp mill (Veracel 2009, Ecometrix 2010).

The mill design incorporates closed counter current brown-stock pulp washing and screening and reuse of secondary (evaporator) condensates for pulp washing and lime mud washing. White water from the drying machine will be used for pulp washing in the bleach plant. In addition, clean sealing waters will be recovered where possible. Cooling water is recirculated in cooling towers to keep fresh water consumption down.

2.44 Wood Supply

Debarked logs will be transported to the mill by truck, with rail and/or barge transport as potential options in the future. The log storage area at the mill will store approximately 130,000 m3, which equates to 10-15 days of production. The yearly wood consumption for production of 900,000 ADTt/a of BEKP is estimated to be 3.4 Mm3.

2.4.5 Power Supply

The pulp mill will be self-sufficient with regards to power and steam generation for the mill’s needs. Steam from the recovery boiler covers both the heat (10.87 GJ/ADt) and power (680 kWh/ADt) demands of the pulp mill (Stora Enso, 2010a).

Black liquor is the fuel source for the recovery boiler and heavy fuel oil will be used in the lime kiln.

During normal operating conditions the recovery boiler provides all the energy and power needed. Small oil fired auxiliary boilers will be installed for use in start-up situations. The local 220 kV power grid would serve as a backup power source if necessary, however it is anticipated that the mill will be selling electricity back into the grid until the paper and board production is added.

In phases 2 and 3, with investment in board and paper production capacity, power boilers will be part of the scope for the energy supply. The capacity of these is based on the premise that the complete mill integrate will be self-sufficient with respect to power and heat production. The power boilers will use coal and mill waste as fuel sources. The boilers are expected to be of the circulating fluidized bed type, (CFB).

2.4.6 Chemical Usage

It is estimated that the pulp mill will use around 160,000 tonnes of chemicals per year. Bulk chemicals such as sodium hydroxide, hydrogen peroxide, alum and sulphuric acid will be sourced in Guangxi or from the neighbouring Guangdong province. Sodium chlorate is available from Sichuan province (Stora Enso, 2010a).

2.4.7 Treatment Systems

While SEGX has designed the systems to minimise the formation and discharge of emissions, some cannot be avoided. Treatment systems adopted as part of the mill include the following key aspects and waste minimisation processes, considered to be representative of industry best practice. These descriptions have drawn from SE (2010d).

» Air Emission Controls: important features for emission controls in the planned mill design are;

– Collection and incineration of all concentrated malodorous gases (CNCG) and control of SO2 emissions from the recovery boiler and lime kiln. The CNCG will be burnt in the recovery boiler with a flare serving as back-up, emissions of total reduced sulphur compounds (TRS) from the recovery boiler will be mitigated by efficient combustion control and by firing high dry solids (DS) black liquor (80% DS). Incineration of the recovery boiler’s dissolving tank vent gases in the recovery boiler further reduces the TRS emissions. TRS emissions of the lime kiln are mitigated by maintaining sufficient excess oxygen in the flue gas and by controlling the residual soluble sodium in the lime mud fed to the kiln. Also so called diluted non condensable and odorous gases (DNCGs) will be collected and burnt in the recovery boiler.

– SO2 emissions from the recovery boiler are controlled by firing high dry solids liquor and maintaining a high smelt bed temperature. NOx emissions from the recovery boiler will be reduced by ensuring proper mixing and air distribution in the boiler and NOx emissions from lime kiln will be reduced by using a low NOx burner design.

– Flue gases from the recovery boiler and lime kiln will be cleaned with efficient electrostatic precipitators to maintain low dust emissions. The sizing of precipitators will ensure that particulate limit values can be met even when one chamber

The mill design incorporates the principles of modern and efficient mills seeking to reduce energy, chemical consumption, maintenance costs, and minimise effluent and air emission loads with application of modern technology. Production systems are designed using modern clean technology to minimize emissions. Treatment systems have been proposed as appropriate to eliminate some emissions and reduce the remainder to low levels. As with most Kraft pulp mills built since 2000, the emissions will be dramatically lower than levels associated with historic pulp mills. The design is in line with Chinese regulations, European guidelines and comparable international standards associated with new Eucalyptus pulp mills in other parts of the world.

The process of converting the woodchips to BHKP will be completed in twelve general steps as described below (SE, 2010):

Wood Yard – At the wood yard the delivered wood logs are processed into wood chips. The chips are screened from fines (sawdust and small wood pieces). The accepted chip fraction is fed to the digester for cooking. The reject fines and dust and other wood residues are sold for fuel or, in the case where there is a power boiler at the mill, used as biofuel to generate heat and power.

Cooking – Chips are mixed with ‘white liquor’, a solution consisting of caustic soda and sodium sulphide, to dissolve the lignin in the wood, leaving cellulose fibre.

Washing - The cellulose fibre is separated from the dissolved lignin and the cooking liquor by washing the fibre pulp. As much of the lignin as possible is washed from the pulp before the next washing stage. Practically all of the chemicals used in the cooking process are recovered in this initial wash and recycled. The filtrate (now called black liquor) from the washing is fed in a counter current mode from the last to the first wash stage and is eventually fed to the evaporation for subsequent burning in the recovery boiler (see below).

Oxygen Delignification – Part of the remaining lignin will be removed from the fibre through the use of oxygen and caustic soda.

Bleaching – Common bleaching agents including chlorine dioxide, oxygen and hydrogen peroxide that are utilised to eliminate all residual lignin and colour from the pulp, leaving white pulp.

Pulp Drying - The pulp will be dried, baled, wrapped and packed in units of 2 tons each and stored ready for sale.

Evaporation – Water is removed from the black liquor by evaporation to bring the black liquor to a sufficient dry solids concentration for use as a fuel in the recovery boiler;

Recovery Boiler – The black liquor is burnt in the recovery boiler to generate steam. The inorganic cooking chemicals from the black liquor solution are recovered from the recovery boiler for reuse in the digester. The steam will be used to heat the processes and to dry the pulp. Excess electrical energy can be sold to the external electricity grid.

Recausticising – The solution of inorganic chemicals from the recovery boiler (called green liquor) is reacted with burnt lime to produce white liquor (for the digester) and lime mud which is recycled into burnt lime in the lime kiln.

Lime Kiln – The lime mud is burnt in the lime kiln before being used in the recausticising process. Lime is an essential ingredient in the regeneration of soda (sodium carbonate) into caustic soda (sodium hydroxide) which is used in the cooking process.

Power Boilers – Using fines from the woodchip mill and other biofuel materials, steam and electrical energy can be produced for the pulp mill and for the external electricity grid. In the SEGX pulp mill project there is no power boiler. Only when the board mill and then the paper mill are installed will there be power boilers that will use biofuels but also coal to a large extent.

Bleaching Chemical Preparation – Pulp mills produce some of their bleaching chemicals on site. For the production of chlorine dioxide, sodium chlorate is reacted with methanol and vitriol (sulphuric acid).

2.4.3 Water Supply and Usage

The raw water source is the Hepu Reservoir system from which water is supplied to all the users in Tieshangang Industrial Zone through a pipeline. At the mill the water will be treated before use in the production processes and further treated also for use as potable water. Connection to the municipal water system will be kept as back up measure only for potable water.


Solid waste not reused in the pulp process should be processed to enable recycling where suitable, given local conditions and regulations.

Primary and tertiary sludge will be mixed and dewatered together and will subsequently be landfilled. For wood waste alternative uses will be as biofuel or composting for use as plant substrate/soil improvement. Secondary sludge is mixed into black liquor and burned in the recovery boiler, hence the zero amount shown in the table above.

Residuals, including lime kiln ESP ash and recovery boiler ESP ash, may, depending on their composition, be recycled into products for soil improvement such as pH control or buffering, after suitable treatment. This can include dregs and grits provided that the properties will be such that they meet the classification as suitable for the intended purpose. In case they do not they will be sent to land fill. The base assumption is that these residuals will be sent to landfill.

Other smaller residual flows such as sludge from the digester area and from the sand separator will be dewatered and sent to landfill. Fibrous rejects may be sold for lower grade paper or board production.

When power boilers are built for phase 2 and 3 of the planned project, fines from chip screening, wood waste, fibrous rejects and residuals such as effluent treatment sludge are planned to be burnt in the power boilers. With the introduction of coal fired power boilers ashes will add to the residual waste from the mill. The CFB boiler produce ashes containing also limestone and sand and there are potential uses for these ashes in building materials and for road construction.

Non-process waste will be separated at the source for secure handling and to facilitate maximum recovery of recyclable materials. This kind of non-process waste is primarily generated from maintenance activities and workshops, laboratory, offices and canteen. Non-hazardous waste that cannot be recycled will be landfilled. Hazardous waste such as oils and lubricants will be disposed of according to Chinese regulations.

2.4.9 Transportation

The pulp mill will use 3.4 million m3/a of solid wood/year, requiring up to 10,000 m3/day to be delivered to the mill site at Tieshangang from the four regions, Beihai, Qinlian, Yulin and Nanning. The total fibre base delivery, along with transport of products and other raw materials, will amount to over 4 million t/a and a total number of movements (in and out of the mill site) per day of around 1000 for the pulp mill operations. The expected distribution of those movements is shown in Table 7.

Table 7 Expected distribution of passages

Item Single pass travel

Product transport (pulp) 100

Wood trucks 250-300Chemical trucks

Tanker trucks; Trucks with solid materials, container buld or big

bags

10-15

Waste transports 20-30

Fuel oil trucks (á 30 t) 5

Other raw materials, maintenance equipment 5-10

Exported and imported material flows are depicted in Figure 5, and will be channelled through a logistics centre in the nearby Tieshangang port. The logistics centre will act as a hub for a large part of the mill’s cargo flows. All pulp will be transported to the logistics centre to be stored there. The proposed logistics centre would be located somewhere between 5 and 8 km from the mill. Facilities in the logistics centre in the port would be run, and equipment owned, by an outside operator.

is out of order. The total suspended particles (TSP) emissions from the lime kiln and the recovery boiler comprise primarily lime dust and sodium compounds (CaCO3, CaO, Na2SO4 and Na2CO3). This TSP is not known to cause any adverse impact, provided that the ground level concentrations comply with the standards. The cleaned flue gases will be discharged to the atmosphere via one common stack but in separate inner flues. The preliminary stack height will be 120 m and the exit velocity is expected to be about 20 m/s. The height of the stack has been approved by Chinese authorities within the EIA assessment process.

» Sanitary and storm water treatment systems: The total amount of sanitary sewage (including canteen effluent and shower water) is estimated to be approximately 180 m3/d and the peak design flow is about 90 m3/h. The sewage will be collected in a separate sewer system from the social and other sanitary facilities, offices and the canteens. It will be settled in a standard septic tank system and pumped to secondary treatment in the mill process effluent treatment plant. Hence, treated sewage will be discharged to the sea mixed with the treated process effluent. In this way the small amount of nutrients in the sewage will be utilized as nutrient make-up for process effluents.

Storm water drains from the mill site will be divided into two separate systems. Clean storm water from the building roof and comparable areas, which do not involve any contamination risk, will be discharged directly to the main storm water sewer network which will be connected directly to the storm water collection system located outside the mill site.

Storm water from other areas at the mill site, from certain main roads and areas close to specific process areas where there will be a risk of contamination, will be led to a separate sewer network. This combined stream will be collected into a storm water basin, where suspended solids and floating debris can be separated especially from the first flush waters generated by rain. The pond also provides some oil separation. If the collected storm water is deemed to be contaminated, it will be pumped to the process effluent treatment facilities. If the water is clean, it will be pumped to a clean storm water drain for discharge out from the mill.

» Process Effluent Treatment: The effluent treatment plant, treating all production process effluents from the pulp mill and at the later phases also effluents from on the board and paper mills comprises primary, secondary biological and tertiary chemical effluent treatment and sludge dewatering. The mill employs an activated sludge treatment process, adapted to the characteristics of Kraft pulp mill effluent. It includes an emergency spill basin, the appropriate chemical addition systems and the necessary control and discharge monitoring systems.

» Submerged offshore diffuser: Treated effluent will be pumped to the discharge pipeline and discharged into the Tieshan Port through an offshore, submerged, multi-port diffuser. The discharge location is assigned by the authorities subject to the EIA process and environmental approval.

» Odorous gas control: All non-condensable gases, which contain e.g. reduced sulphur compounds, will be collected from sources, such as tanks, wells and effluent drains in the fibre line and recovery area and will be burnt at high temperature in the recovery boiler. In addition possible release of diffuse and fugitive TRS emissions from the production areas are mitigated by using enclosed structures and proper ventilation. To ensure the reliability of the odorous gas (NCG) handling and elimination system, a number of redundancies will be provided.

2.4.8 Solid Waste Handling

The amounts of residuals for the pulp mill are estimated as shown in the table below.

Table 6 Residual Solid Waste from the pulp mill process (SE, 2010)

Type act.t/a tDS/a

Effluent treatment, primary sludge 35,010 12,253

Effluent treatment, bio-sludge 0 0

Effluent treatment, tertiary sludge 53,852 13,463

Pulp mill process residual solids 35,357 24,750

Power boiler ashes 0 0

Miscellaneous waste 3,540 1,770

Wood waste 73,870 40,628

Total 201,628 92,865

(Reference: Pöyry, February 2007. Assumed moisture content for primary sludge 65%, secondary sludge 80% and tertiary sludge 75%. Solid waste MC estimated

at 30% moisture and miscellaneous waste 50% and wood waste 45% MC.)


2.5 Comparison of Expected Mill Emissions with BAT The air and water emissions limits from the mill based on RIEPG (2008) are summarized in Tables 8, 9 and 10 with reference to BAT standards. Based on this comparison the mill is expected to meet, and in some cases go beyond, IPPC-BAT (2001) and IFC-EHS (2007) guidelines used to define BAT. The mill meets the key requirements of BAT comparison including:

» Based on emission levels from the IPPC-BAT (2001) and IFC-EHS (2007) guidelines, it was found that the mill will comply with the emission levels achievable with the use of BAT, as summarized in Table 8, 9 and 10. In addition, a comparison between the proposed mill emission rates and other modern bleached Eucalyptus Kraft pulp mills in Uruguay and Brazil (EcoMetrix, 2010) shows that the proposed emission rates for the mill are generally comparable with the performance levels of these other mills.

» The environmental regulating body in China, MEP, has a permitting process to ensure the national standards will be met. The mill will comply with Chinese laws, regulations and standards, as demonstrated by environmental approvals received in 2008. Those approvals specify concentration-based and loading-based discharge and atmospheric emission limits and set requirements for routine emissions and environmental monitoring and reporting.

» The mill design incorporates modern process and treatment technologies considered to meet BAT. The mill design seeks to effectively control the production processes in a way that pollutants are not generated where practical, including using elemental chlorine-free bleaching to eliminate the generation of hazardous organic chlorine compounds in the bleaching of the final pulp and minimising (with a target of zero) the losses of black liquor effluents to the mill central effluent treatment facilities. The overall mill design employs measures to mitigate environmental emissions at source by using in-plant control measures to recover, recycle and reuse water, fibre, chemicals and energy (refer to Section 2.4.7 and SE, 2010).

» The mill incorporates operational, monitoring and control practices considered BAT, including a system of online monitoring of emissions. SEGX has developed, or is in the process of developing, operating plans to address environmental monitoring, wastewater, atmospheric emissions, solid waste, hazardous materials, noise, transportation, community engagement, public disclosure and grievance mechanisms. In addition to this, SEGX is in the process of developing a staff training and capacity building program to build personnel skills, awareness and sense of responsibility for a high level of operational management.

Table 8 Effluent loadings per ton of pulp compared to IPPC and IFC guidelines for long term average

Parameter

SE Pulp Mill (standalone)a Env.

Approvalb m3/ADt, kg/ADt

GB 3544-2008c Standalone Pulp mill

m3/ADt, kg/ADt

IPPC-BATd (2001) Pulp mills m3/ADt,

kg/ADt

IFC-EHS Pulp mills (2007)

m3/ADt, kg/ADt

Flow 25 50 30 to 50 50

BOD5 0.5 1.0 0.3 to 1.5 1.0

COD 2.5 5 8 to 23 20

TSS 1.25 2.5 0.6 to 1.5 1.5

AOX 0.15 n.a. 0 to 0.25 0.25



Figure 5 Schematic Diagram of Mill Logistics

The average transport distance from plantation to the mill site for the current estate is 170 km. Because many of the public and forest roads will be narrow and not suitable for the use of large trucks, SE intends to use small farm type trucks, with a payload capacity of 6 - 8 tonnes, to transport logs from the forest to depots where the logs will be transferred onto larger trucks for delivery to the SEGX mill. It is considered that the use of the smaller trucks on the narrow public roads will minimise the damage to the roads, reduce the social impact and make the transportation task safer.

SE calculates that approximately 15% of the annual supply of wood to the pulp mill can be delivered directly from the forest to the mill on large trucks. 85% of the wood will delivered by small trucks to depots and then by large trucks to the pulp mill.

All transport will be by contractors, however all contractors will have to work to SEGX requirements which includes health and safety, environment, social, labour conditions and legal requirements such as the over loading of trucks.

The wood flow for the SEGX Mill will initially come from plantations in four Prefectures:

» Beihai, which is the closest region, just north of the mill site;

» Qinlian, which is north and west of the mill site;

» Nanning, northwest of the mill site; and

» Yulin, northeast of the mill site.

The two closest regions, Beihai and Qinlian, will account for approximately 50% of the wood requirement and Nanning and Yulin will each account for approximately 25%.

Within the 4 regions there are 15 districts. The plantations are not located in large consolidated areas; rather they tend to be scattered throughout the regions and districts.

Other transportation options being considered include:

Rail: It has been estimated by SEGX that up to 25% of the wood for the pulp mill could ultimately be delivered by rail once the rail line is completed to the pulp mill site at Tieshangang. This form of transportation is now being investigated by SEGX, however the investigation to date has found a number of potential issues, including: (i) there is limited space at railway depot sites for storing and handling logs; (ii) large quantities of coal will be transported by railway so there is a chance that the logs could become contaminated by coal dust; (ii) the railway companies do not currently have the right type of wagons for the transport of logs; and (iii) the logs have to be “double handled” thereby adding costs. Due to high risk in rail transportation, timeliness, cleanliness and access to depots, SE has decided to put this option on hold.

Barging: There is potential that some wood could be delivered to the SEGX mill at the Tieshangang Industrial Zone by barge using rivers and the sea as the transportation passages. The potential of using barges to transport logs to the SEGX mill site is currently being investigated by SEGX, however it may not be a viable option due to shallow waters and bridges that are too low.


3. Social and Environmental Setting3.1 Overview

The following section presents a summary of the economic, social, physical and environmental setting of the project Area. Focus is given to the potentially sensitive ecosystems and associated biodiversity, water quality and air quality characteristics, along with community benefits and concerns regarding the project. Some baseline data is presented from

past studies and assessments.

3.2 Economic DevelopmentGuangxi is one of 12 less developed provinces and autonomous regions in the PRC, with its economy supported in large part by its extensive agricultural and forestry base. In 2010, Guangxi had a GDP of CNY 950 billion and a GDP per capita of CNY 15,800. In 2005, the gross output value of agriculture and forestry in Guangxi was CNY 145 billion, of which CNY 6.2 billion came from commercial forestry (UNDP 2006). Agriculture and forestry sector industries include rice, sugarcane, vegetables, animal husbandry, fish farming, native trees and introduced forest plantations of eucalypts, pines and acacias. In recent years there has been a strong government push to attract more industrial sector investment in Guangxi. As part of this push the PRC government approved (2008) the development of the Beibu Gulf Economic Zone (BGEZ).

Guangxi has been emerging as an important national multimodal transport gateway to link southwest PRC with neighbouring countries in the greater Mekong subregion and increase PRC’s trade with the Association of Southeast Asian Nations (ASEAN). To foster increasing trade with ASEAN, the PRC government has commenced development of the southern coastal area of under the BGEZ, with a vision to become a regional hub for logistics, business services and information, comparable to the economic powerhouses of the Pearl River Delta, the Yangtze River Delta, and the Bohai Economic Circle. The development of the BGEZ includes three coastal heavy industry zones (i) Qinzhou Port Industrial Zone; (ii) Qisha Industrial Zone; and (iii) Tie Shangang Port Industrial District. The BGEZ is an important development with respect to the SEGX Project and provides the location for the pulp mill site and some of the supporting transport, water supply, power and water treatment infrastructure.

The most important economic development aspects with regard to the project are the forestry industry and the development of the Tieshangang Industrial Zone, each of which is summarised below.

3.2.1 Guangxi Forestry Industry

Forestry is a major industry sector in Guangxi. Some 13.6 million hectares (57%) of Guangxi’s total land area is classified as forest land, of which 7.8 million hectares is set aside for commercial forests (Cossalter and Barr, 2005). Of the 7.8 million hectares of land classified as commercial forestland in Guangxi, 5.5 million ha is used for timber plantations.

Guangxi forest resources fall under two land ownership categories: State-owned land and collectively-owned land (Cossalter and Barr, 2005). State-owned lands are managed through a network of State-owned forest farms. Based on 1999 figures, Guangxi had 151 State-owned forest farms whose total area represented 9% of the provincial total. At this time there were approximately 10,000 village collective forest farms and in the order of 20,000 family-run forest farms in Guangxi province (Cossalter and Barr, 2005). Of the forestry land under commercial management, 91% is on collective owned lands.

Cossalter and Barr (2005) reported the main land use types in Guangxi from the Guangxi Forestry Bureau Data of the 1999 Provincial Forest Inventory. Of these, forestry made up 57% and farmland 30% of the total land use. The definition of forestry land includes natural vegetation, plantations and orchards.

In 2004, 134,545 hectares of fast growing plantations were established in Guangxi, with Nanning, Guigang, Laibin, Yulin, Qinzhou, Beihai and Fangchenggang prefectures most involved in this programme (Cossalter and Barr, 2005). Based on the 1999 Guangxi Forest Inventory, Cossalter and Barr (2005) estimated that there was approximately 3.66 million hectares in the Guangxi potentially suitable for plantation establishment in addition to the total area of forestry resource of 13.6 million hectares. The 2008 SEGX Forestry EIA (CRAES, 2008) suggests that by 2006 there were 600,000 hectares of eucalypt plantations within Guangxi.

The annual increase in Eucalypt plantation area was 1-3% between 1977 and 1995, 21% between 1995 and 2000 and 51.7% from 2000 to 2005 (Guangxi Forestry Institute, 2007).

Table 9 Emissions to air from recovery boiler and lime kiln compared to IPPC and IFC Guidelines for pulp production

Parameter

SE Pulp Mill Technical designa parameters, kg/

Adt



kg/ADt


SO2 (as SO2) 0.7 1.8 0.4 to 0.8 0.8

NOx (as NO2) 2 - 1.0 to 1.5 1.5

TSPc 0.3 0.4 0.2 to 0.5 0.5

TRSd (as H2S) 0.06 0.06 0.1 to 0.2 0.2a) Technical design parameters for SO2 and TRS, the long term averages may be lower, see ref. b) Calculated from RIEPG 2008 Oct 2008, table 3.4-7 amendment, 900,000 ADt production, 354 operating d/a c) Total suspended particlesd) Total Reduced Sulphur Compounds

Table 10 Power Boilera Emissions Compared to IFC Guidelines for Thermal Power Plants




mg/Nm3


SO2 (as SO2) 200 319 900 to 1,500

NOx (as NO2) 300 300 510 to 1,100

TSPc 30 41 50

TRSd (as H2S) n.a. n.a. -a) Design data are preliminary only. Power Boiler is part of phase 2 and 3 scope, one operational unit added for each phaseb) RIEPG 2008, Table 3.4-6, amendedc) Total suspended particlesd) Total Reduced Sulphur Compounds

Note; A new boiler standard, GB 13233-2011 is being implemented that changes in the emission limits for the power boiler. As a consequence the PB will be equipped with SNCR, selective non catalytic reduction of NOx to the level below 200 mg/Nm3.


Plate 4: Tieshangang Industrial Zone development with gantry cranes in the background. The foreground is reclaimed land. Key Infrastructure is already in place within the Tieshangang Industrial Zone

Figure 6 Proposed Mill Site Location and Industrial District

3.3 Social SettingOf the total population in Guangxi of about 50 million people (2004), 40 million live in rural areas. Average net income per capita in rural areas is CNY 2,300 compared to an average for all Chinese rural households of 2,936 (2004 figures). Compared with neighbouring southeast provinces, Guangxi is poor and poverty alleviation in the countryside is one of the local government’s priorities. Rural people have a high dependence on forests for employment, fuel wood and other products.

Beihai City is the closest major centre to the project area and is one of the four cities in the BGEZ, which include Beihai, Nanning, Qinzhou and Fangchenggang. Beihai is a prefecture level City, with a long history as an important seaport on the north shore of the Gulf of Tonkin. By the end of 2009, the registered population in Beihai City totalled at 1.5897 million people (ADB, 2010a). Development and growth has been rapidly accelerating in Beihai over the past decade, largely driven by increased trade. Between 2006 and 2020, Beihai is predicted to be the world’s fastest growing city (City Mayors, 2011). Beihai City administers one county and three districts: Hepu County, Haicheng District, Yinhai District and Tieshan Port District. The SEGX mill is located within the Tieshan Port District.

3.3.1 Urban Rural Divide

By the end of 2005, the total population of the project Area was 8.8 million, which included 1.2 million of urban population and 7.6 million of rural population (CRAES, 2008). In the same year urban per-capita average disposable income was CNY 8,917,

The forestry sector supports a significant wood processing industry, which includes (Cossalter and Barr, 2005):

» Sawmills (3,904 sawmills with a total capacity of 3.2 million m3/year in 2004);

» Wood panel mills (156 mills with a total capacity of 2.75 million m3/year in 2004);

» Pulp and paper (over 200 pulp and paper mills with a capacity of 960,000 t of paper and 320,000 ADt of various grades of pulp);

» Woodchips (213 chip mills with a total capacity of 1.3 million bone dry metric tonnes per year in 2004); and

» Plywood (37 furniture grade plywood mills with total capacity in 2003 of 141,000 m3/year and a large number of household scale mills).

The wood processing industry is primarily concentrated in the south and south-east of Guangxi.

In addition to the above industries there has been rapid growth in the development of Medium and High Density Fibreboard (MDF and HDF). In 2003 there was an existing MDF capacity in Guangxi of 795,000 m3/year with an additional capacity of 830,000 m3/year under construction. A HDF plant with 300,000 m3/year was also under construction at that time.

Forest-pulp-paper integrated projects are identified by the Guangxi authorities as the cornerstone for the development of a modern, viable and sustainable industry in Guangxi. Industrial development within the BGEZ is complemented by agricultural, ecological, service industry, transport, energy and social services (Nanning Municipal Government, 2010).

Guangxi’s ambitious forestry development plans are supported by China’s central government, which has also set ambitious capacity expansion targets for China’s pulp, paper and wood processing industries. To achieve these targets a series of aggressive development policies have been set in motion, backed by central government policy directives and funding, to speed the development of China’s pulp, paper and wood processing industries. These policies are premised on the following objectives:

» Reduce China’s dependence on imported wood fibre, paper and processed wood products by developing the domestic wood fibre base through: 1) Development of fast-growth, high-yield plantations; 2) Reduction of high taxes and fees on plantations, so as to stimulate investment; 3) Tariff reductions on imports of raw materials and processing machinery; and 4) Protection of China’s forestry base.

» Encourage foreign investment in the wood fibre, pulp, paper and wood processing sectors through a variety of financial and tax incentives.

3.2.2 Tieshan Industrial Zone Development

The planning boundary of the Tieshan Port Industrial Zone (TPIZ) starts from the Nankang river in the west, Shitoufu village in the east, Beihai-Tieshan class-I highway in the north and Tieshan port area in the south, with a total area of 131 km2. The planned population is 300,000 by 2025. The development orientations of the TPIZ include logistics, trade, chemical, pulp and paper, manufacturing and power industries. There will be green belts surrounding the TPIZ and green barriers between the functional areas within the industrial zone (Figure 6). It is planned to initially build four 100,000 t berths to service an annual port throughput of 12 million tonnes. Stage one of the project will see the construction of two berths, allowing throughput of 6 million tonnes including 1 million tonnes of break bulk and 5 million tonnes of bulk cargo. The ultimate development proposal for the port is for 36 berths with an annual throughput of over 90 million tonnes, including 600,000 containers (ADB, 2012).

There are three keystone enterprises that plan to establish operations within the TPIZ. The flagship investor is the state-owned Sinopec Group, one of the top 50 global oil companies. Sinopec proposes to complete a 200 thousand tonne-per-year polypropylene plant that produces plastic intermediates by September 2011 (Liao et al, 2010). Sinopec also proposes to build a 3.2 million cubic meter commercial crude oil storage base at the Tieshan Port (Liao et. al, 2010). The Chengde Stainless Steel Co. Ltd, a private company, is proposing to build an integrated stainless steel plant. The third project is the SEGX pulp and board mill (Nanning Municipal Government, 2010).

At the time of writing, works were well advanced on Stage 1 of the Tieshan Port construction with excavation of berths 1 and 2, construction of the wharf and installation of 9 gantry cranes. Reclamation of large areas behind the wharf and storage yards, access roads and other infrastructure is currently progressing, as shown in Plate 4.


In August 2009 an independent national social development specialist conducted a Social Impact Assessment (SIA), as reported in UNDP-Deng 2009, to capture the social impact of plantations from changes in land use policies. The report focused on the following aspects: (i) impact on local livelihoods, especially local food security and cash generation at the community level; (ii) impact on the local livelihood capital, such as the natural, physical and human capital; and (iii) impact on local capacity building.

The study was conducted by a desktop review of existing policy documentation, technical design review and field inquiry with local farmers whose forests have been acquired by SEGX. The report presented the following key findings:

» The Chinese government has issued a new policy reform regarding collective forests in China (The Conceptual Guideline for Promoting the Institutional Reform of Collective Forest, official document No 10-2008, by CCPCC and State Council). Based on this policy all the collective forest land whose land tenure is clear should be allocated to households where applicable. Guangxi provincial government issued the policy reform of collective forests in Guangxi province on January 23, 2009.

» Livelihood analysis focused on the sources and diversification of cash generation in the SEGX project area. Land acquisition by SEGX plays an important role in cash generation for the local communities and has a positive impact in diversifying the sources of cash generation; however it was not indicated as one of the top three most important income sources at the time of survey.

» Overall, the impact of land acquisition by SEGX is positive and SEGX is accepted by the communities in the project area. The main concerns for the local communities were:

– Rural road maintenance (as indicated by a mixed gender group in the Cao-Jiang village and an all-male group in Dan-Tian village);

– Ecosystem protection, including soil erosion control and preventing poisoning of fish ponds by eucalypts; and

– The annual payment rate for land rental by SEGX. However, the proposed revision of the rental payment rate every 5 years due to inflation was seen as a positive.

» Questionnaire responses indicated that there was no negative impact from land acquisition by SEGX on local resource security and no general disagreement to lease the land to SEGX. The majority of respondents were satisfied with payment methods and the majority recognized that cash generation from leasing the land to SEGX resulted in the same or higher income than alternative land uses.

» Local communities have expectations of SEGX. In particular, the need for more local employment opportunities to contribute not only to the sustainable cash generation for the community but to improve the relationship between the communities and SEGX. Local communities are also able to help SEGX with forest management such as forest fire and illegal logging control.

» SEGX has been accepted by local communities and there is a better relationship compared to other local forest companies, due to the higher rental fees, regular adjustment of rates, timely payment scheme and social engagement programs for the communities.

» There have been no impacts on local culture and tradition, as well as no negative impacts to local food security, natural and human capital.

» Local communities have also seen improvements in their capacity in nursery skills and tree planting, as well as forest management.

Key negative impacts identified included: (i) a perception of damage to rural roads from the transportation associated with SEGX activities and comments regarding a lack of input on maintaining the rural road by SEGX; (ii) a perception that few local villagers have been employed by SEGX compared with external employees. Local communities have limited access to employment opportunities; and (iii) women and poorer groups have not been recognized and highlighted as one of the key target groups in the community by SEGX.

In light of the key findings, the report recommended that SEGX continue management of potential risks identified above, as well as offering more local employment opportunities and providing more social development support and active information sharing. Building capacity for SEGX staff on working with the community and corporate social responsibility activities is also necessary in future.

while the average per-capita income in rural areas was CNY 2,495. As with many other parts of the PRC and many parts of the world there is a large disparity in urban and rural incomes within an area.

3.3.2 Minority Groups

Guangxi is home to a population of over 16 million ethnic minorities, dominated by the Zhuang ethnic group. The Zhuang group is the biggest ethnic minority group in China totalling around 17 million people.

3.3.3 Migrant Workers

Migrant workers provide a large contribution to the work force in the agricultural, forestry and industrial sectors in Guangxi. Generally, migrant workers are from areas that are poorer and they are typically willing to work for lower salaries, as well as perform harder physical labour, than many Project Area inhabitants (UNDP-GHD 2010, Appendix A).

Migrant workers engaged in SEGX’s current forestry operations come primarily from Northwest Guangxi and Yunnan, Guizhou, Sichuan and Hubei Provinces. Contractor management and the conditions for the migrant workers engaged by the sub-contractors is a key element of SEGX’s sustainability commitments.

3.3.4 Impacts of the Tieshan Port Industrial Zone development

The TPIZ area used to be of a rural character with livelihoods based mainly on farming and aquaculture. Several thousands of people are being relocated within the TPIZ to new residential centres to make room for the establishment of industrial projects and the new port.

3.3.5 Outcomes from Social Studies, Plantation Estate

Several social studies and impact assessments have been carried out by SEGX, as detailed in Section 1. The social research carried out in December 2009 by the Sustainability Department at SEGX, highlighted the following key findings and conclusion which were generally representative of other surveys: (i) villager’s income resources are limited and fragile; (ii) the public knows little about SEGX; (iii) communication is weak between SEGX and grassroots levels from town government, village committees to villagers; and (iv) the most important development priorities are road construction and water supply. Some issues identified in the study included:

» Generally, villagers have a negative attitude towards eucalypts. The main issues noted associated with eucalypts were perceptions of their potential to lower the water table, shed toxic leaves, block sunlight falling on adjacent crops and cause water pollution and increased soil erosion.

» Stakeholders from village committees and villagers noted some dissatisfaction with their land lease rental payment rates. Primary complaints related to low rental payments and delayed rental payment. It was not clear from the study if this refers to cases where land is rented directly to SEGX or through other entities, village collective or BHC. The actual cases are not presented nor are the people involved and responsible parties identified in the study.

» Seventy per cent of government officials and villagers interviewed suggested that SEGX should have regular face to face meetings with them to solve problems systematically.

» Village committees felt that SEGX did not communicate with them other than during conflicts. However, 16.7% of village committees think communication channels are useless or not necessary and that doing something good for the community is the best way to communicate. Sixty per cent recommended face to face communication.

» Most villagers know nothing about SEGX except that it is a “Finnish Company”. Sixty two per cent of villages have seen public notices but villagers suggest public notices should be pasted in the village shops by SEGX staff, not given to the village committee. Villagers are highly interested in contract issues and work in the forest land. Villagers in 3 nature villages suggest that SEGX should notify them before spraying pesticides and herbicides. However, it is noted that chemical pesticides are not used as standard SEGX stand management practices and SEGX does not use internationally banned pesticides or herbicides.

» Roads, drinking water and irrigation are one of the highest priorities. These priorities indicate how SEGX may address community development in the future.

SEGX has taken the findings of these and similar studies seriously and is working to improve communication and engagement with local villagers to address concerns.


linked to the geological formation and slope and aspect, with varying clay content. Based on results presented by CRAES (2008), about 3% of the project Area shows evidence of moderate to severe soil erosion.

Some 57 per cent of land (13.6 million ha) in Guangxi is classified as forest land. Land with forest cover is 9.8 million ha, or 41 per cent of total land area of Guangxi. The area classified as commercial forest land totals 7.8 million ha (57 per cent of the 13.3 million ha classified as forestland). The original native forests of the province were mainly tropical rainforests in the valleys and seasonally dry rainforest on slopes below 500 m.

Tieshangang Industrial Zone and the associated Tanshan Port are located within Beibu Gulf, which is one of the five largest bays in the Guangxi coastal area. Tieshan Port itself is a narrow long bay in the form of a terrace and drowned valley. The mouth of the bay is approximately 32 km wide, 40 km long from north to south, and 4 km wide from west to east. Tieshan Port is approximately 340 km² in area (refer Figure 7 and Figure 8).

3.5 Existing Land UsesThe main land uses within the project Area broadly listed in order of land area use (largest to smallest) include forestry, grasslands, agricultural activities, residential and urban areas, nature and water catchment reserves, road and rail infrastructure, industrial uses and aquaculture.

Within the Guangxi forestry sector a Sino-foreign Joint-venture (Jingui Pulp & Paper Company Ltd) currently manages a major paper pulp forest base in areas neighbouring the project Area.

In 2005, Eucalypt plantations covered 2.25% of the total province land, 4.26% of the total forest area and 19.48% of the total timber production plantation (Guangxi Forestry Institute, 2007). Pine and Chinese fir were the dominant plantation species with 19.3% and 13.4% of the total forestry area respectively.

Up to 70 km of the coastline within the Tieshan Port is utilised for aquaculture, including cultivation of sea pearls and oysters, various fish and pawns destined for commercial sale at domestic restaurants and markets. The aquaculture activities general take place in large constructed ponds adjacent to the coastline. Constructed evaporative salt pans are also common in the area.

3.6 BiodiversityThe landscape in Guangxi is dominated by human activity and the present day biodiversity is, compared to its original natural state, degraded due to long term human influence and impact. Nevertheless, Guangxi has a rich biodiversity and is classified as the third largest biodiversity province in China (UNDP, 2006) and is considered one of the most botanically rich provinces in China. In excess of 280 families, over 1,670 genera and nearly 8,000 species of plants have been identified in Guangxi (CRAES, 2008).

Table 11 Guangxi Proportion of PRC Total Biodiversity

Taxon China’s Total Guangxi’s Total Proportion (%)

Vascular plants 27,142 8,354 30.8

Mammals 581 166 28.6

Birds 1,244 483 38.8

Reptiles 376 157 41.8

Amphibians 284 84 29.6

Fish 3,862 700 18.1

Source: Guangxi Provincial Forestry Department, 2005 in: UNDP, 2006

3.6.1 Flora

There are 116 listed threatened species located within Guangxi. Cathaya argyrophylla, often referred to as the “plant panda” because of its scarcity and historical significance, has been found in Guangxi. Other key species include Jianmu found in Longzhou, Abies nephrolepis from Ziyuan, Shorea chinensis of Napo, south hemlock from the Mao’ershan Mountain, Hopea chinensis from the Shiwan Mountains and Alsophila spinulosa (CRAES, 2008; UNDP, 2006).

As detailed by CRAES (2008), there are three predominant native vegetation types in the project area: (i) Hill and mountain monsoon forest area in south-east Guangxi; (ii) Stone mountain monsoon forest area in south-west Guangxi; and (iii) Stone

3.3.6 Forestry Land Dispute Conflict

The China Agricultural University (CAU) conducted a study entitled the Study on Utilizing Foreign Capital to Promote the Development of Forestry Industrialization of the Fast-growing Forests in Southern China, attempting to determine local villagers’ views on the forest land disputes through field surveys. The survey report on the land disputes between the Qinlian State Forest Farm and nearby villagers was finalised in August 2010 and detailed conflicts with the local villagers as a result of land allocation in China over the last several decades. The majority of people interviewed in the study claimed the land ownership should belong to the villagers, with 32% also saying the land acquisition of the forest did not make sense to them and 9% saying that there were also problems with unclear mountain boundaries.

According to the report, the land was transferred to the state-owner Qinlian State Forest Farm in 1964 without local villager consent or discussion, leaving villagers protesting that they did not have enough land to make a living and that utilization of natural resources was their right as traditional owners. Of the 218 people interviewed there were four predominant attitudes being: (i) Almost 25% of those interviewed believed that they needed to take back the forest lands and believe that the government will not return the lands taken; (ii) Almost 18% wanted control over the lands but are still willing to rent them out to forestry companies; (iii) Almost 19% were indifferent but would like the additional income; and (iv) 7% wish for compensation for the loss of livelihood.

Actions by villagers have included threats, removal of seedlings and blocking workers from entering the plantation, as well as petitions to the government and villagers occupying the forestlands by planting their own trees.

According to the survey, 35% of the villagers view the government as ignoring the disputes, 28% believe the government is keeping a neutral position and 26% say the government will not return the land to the villagers. In addition the survey revealed that 41% of the villagers believe that having the forest farm had resulted in ecological damage and water and soil contamination from the eucalypt trees. Finally, 30% of villagers believe the lands should be returned so they can plant on them themselves and 14% said they expect to earn more from the land and lease it at market price.

While the report identified that it was difficult for a foreign owned company to assist in resolving local disputes, the following measures were suggested as action plans for SEGX: (i) attempt to compromise with the villagers or consider alternative forestry locations; (ii) improve local infrastructure such as roads and irrigation systems; (iii) increase community involvement and interaction; (iv) develop programs promoting forestry development and forestry technology promotion; (v) engage local people in the projects; and (vi) undertake community education specifically with regard to prejudice towards eucalypt species.

In its 2009 Sustainability Report (SE, 2009c), SE reported a number of instances since 2005 of conflict over land ownership in Guangxi which resulted in injury and in one instance death. These incidents did not directly involve SE’s own staff but in one specific case did involve a contractor working on SE’s plantation.

SEGX has taken active steps to adopting the recommendations from this study, including consideration of alternate forestry locations, increased engagement with the local community through meetings and a regular local newsletter, initiating a dispute resolution action plan, including a dispute reporting and intervention procedure in the form of a hotline and grievance channel, and seeking to develop local community development pilot projects.

3.4 Physical SettingGuangxi is located in coastal southern China, borders Vietnam, and adjoins the provinces of Yunnan, Guizhou, Hunan and Guangdong. It has an area of 237,600 km2, almost the size of the United Kingdom.

Guangxi has a dominant subtropical monsoon climate, which varies with latitude and altitude. Summers are hot and humid and winters relatively cooler and dry. Annual average temperature is 17- 22oC, with a maximum 23-29 oC in July and 6-14 oC in January. Annual sunshine time varies from 1400-1,800 hours. Average annual rainfall in Guangxi is 1,500 mm and varies from 1,100-1,200 mm in the western basin areas to 2,060-2,780 mm in the southeast areas. Average rainfall in southern Guangxi’s Behai, one of the main project areas, exceeds 2,000 mm.

Guangxi is generally a mountainous region, dominated by karst topography. However, the southern areas are flat and undulating. CRAES (2008) identified three distinct geomorphological regions within the project Area: (i) Rolling hills located in southeast Guangxi; (ii) Tablelands located in south Guangxi; and (iii) Karst Mountains located in southwest Guangxi.

The geology and associated soil types vary throughout the project Area. The geology of the project Area includes granite, sandstone and limestone, with more recent alluvial and fluvial sediment deposits. Soil type and depth profile is variable and


Figure 7 Location of Marine Reserves within Tieshan Port Area (RIEPG, 2008)

SEGX Mill Site

» Guangxi Hepu Dugong Nature Reserve is located in Hepu County, Beihai City. At its closest the reserve is approximately 4.2 km from the SEGX proposed marine discharge location. The reserve covers a total area of 35,000 hectares and has a coastline of 43 km. The reserve is the only nature reserve in China with dugong as the major protection target. The reserve protects other state-level 1 species, including the Indo-Pacific hump-backed dolphin, and animals under state-level 2 protection such as the finless porpoise, turtle, and Chinese soft shelled turtle. The reserve includes large areas of sea grass.

» Shankou National Mangrove Nature Reserve was established by the State Council in September 1990. The reserve is composed of the eastern and western shores and surrounding sea areas of Shatian Peninsula in the southeast of Hepu County. The Reserve borders the Zhanjiang Mangrove Reserve in Guangdong Province and includes the three towns of Shankou, Shatian and Baisha.

The total area of the Shankou Reserve is 8,000 hectares, comprising approximately 4,000 hectares sea area and 4,000 hectares land. The coastal line of the reserve is 50 km and it includes 730 hectares of mangrove. At its closest, the reserve is approximately 4.5 km from the proposed marine discharge location.

Mangrove species within the Reserve include 7 families and 8 genera including Rhizophora stylosa, Bruguiera gymnorhiza, Kandelia candel, Avicennia marina, Aegiceras corniculatum, Excoecaria agallocha, Acanthus ilicifolius, Lumnitzera racemosa and Acrostichum aureum.

3.7 Water Quality Existing surface and marine water quality within the project Area is a key baseline indicator for the monitoring and evaluation of potential environmental impacts associated with the project. The following section provides a summary of existing water quality data from previous assessments and studies, with reference to the relevant Chinese water quality classification standards.

3.7.1 Surface Waters

As a result of the subtropical climate and associated high annual rainfall the project Area has abundant surface water resources for forestry production, agricultural irrigation, industrial use and domestic use. There are 12 river system of note within the project area, namely the Zuojiang River, Yongjiang River, Yujiang River, Nanliujiang River, Datongjiang River, Jiuzhoujiang River, Rongjiang River, Beilunhe River, Jiangpingjiang River, Fangchengjiang River, Mingjiang River and Maolingjiang River. These rivers belong to the Pearl River System and valleys of rivers located in the coastal areas of south Guangxi. Among them Nanliujiang, Wulijiang, Qinjiang and Maolingjiang Rivers of Yulin Prefecture, as well as Beilunhe river of Fangcheng Prefecture, belong to the river valleys of the coastal rivers of southern Guangxi and enter the Beibu Gulf. Other rivers of the project Area belong to the Pearl River System (CRAES, 2008).

Mountain evergreen, deciduous broad-leaf forest and mixed forest in mid Guangxi.

As a result of human activity, native vegetation remnants have been heavily modified and most vegetated areas have been succeeded by tropical monsoon forests, evergreen broad-leaf forests or managed forests. Remnant vegetation within steep ravines is often the only undisturbed community (CRAES, 2008). In addition, the landscape is highly fragmented by roads, urbanisation and agriculture, with the majority of the natural rainforests located in protected areas (UNDP, 2006).

3.6.2 Fauna

Guangxi has 944 recorded fauna species, including 84 amphibians, 157 reptiles, 536 birds and 166 mammals (UNDP, 2006). Of these species, 195 are listed under National or Provincial criteria (CRAES, 2008). CRAES (2008) provides an extensive summary of the fauna present within the project Area.

3.6.3 Marine Fauna

Beibu Gulf has more than 500 species of fish, 200 species of shrimps, nearly 50 species of cephalopods and more than 20 species of crab in addition to other marine species (CRAES, 2008).

There have been 1,760 marine species recorded along the coast in Guangxi (within 20 m water depth), comprising of 172 species of marine plants and 1,588 species of marine fauna (SCSIO, 2007). These included 122 fish species, of which 30 are considered commercial fisheries species. Other commercial species include pearls, oysters, hard clams, prawns, ark shells, Samoan crabs and groupers. In 2008, commercial fisheries (including fish farms) in the Beihai area covered 37,400 hectares with a total output of 332,000 tons. The commercial value was up to CNY 3 billion.

Protected marine species sighted off the Guangxi coast line include the dugong, Indo-Pacific hump-backed dolphin, finless porpoise, turtle, and Chinese soft shelled turtle. Large areas of sea grass which support significant marine species biodiversity are also present in reserves.

3.6.4 Terrestrial Natural Reserves

There are seven National status nature reserves in Guangxi and 10 regional reserves. The National reserves are Fangcheng (9,195 ha) protecting the Golden camellia, Nonggang (10,080 ha) and Damingshan (16,994) ha protecting diverse mountain mixed forest ecosystems, Shiwan Mountains (approximately 58,200 ha) protecting the north tropical monsoon rainforest and evergreen forest, Shankou (8,000 ha) protecting mangroves and Beilunhe River Mouth (3,000 ha) protecting mangroves. The majority of these reserves are located in Beihai, Fangchenggang, Yulin and Chongzuo counties (CRAES, 2008). These reserves cover 6.7% of the total land area within the province; however there are many communities that use these nature reserves for wood products, especially firewood. These national reserves are also affected by agricultural encroachment, livestock grazing and logging (UNDP, 2006).

3.6.5 Marine Reserves and conservation zones

Several marine reserves and conservations zones exist within the area of the project, as summarised in Table 12 (TRIWTE, 2009), most notably the Guangxi Hepu Dugong Nature Reserve and the Shankou National Mangrove Nature Reserve which exist less than 15 km from the planned Mill effluent discharge site (shown in Figure 7 and described below).

Table 12 Marine Reserves and Conservation Zones within 100 km of SEGX Mill Site (TRIWTE, 2009)

Type Description

Conservation areas

Shankou National Mangrove Nature Reserve

Hepu (Shatian) National Dugong Nature Reserve

Yingpan Sea Water Cultivating Area

Suixi Sipunculus nudus conservation Area

Juvenile parargyrops edita and shrimp conservation area

Reproduction area

Fucheng-Yingpan sipunculus nudus multiplication area

Shatian sipunculus nudus multiplication area

Anpu port - Qishui port shallow sea shellfish multiplication area


Figure 8 Tieshan Port Water Quality Objectives (RIEPG, 2008)

Table 14 Seawater Quality Standards (GB3097-97)

Class I Class II Class III Class IV

pH value 7.8-8.5 7.8-8.5 6.8-8.8 6.8-8.8

DO 6 5 4 3

CODMn (mg/L) 2 3 4 5

Inorganic nitrogen (mg/L) 0.20 0.30 0.4 0.5

Labile phosphate (mg/L) 0.015 0.03 0.03 0.045

Petroleum (mg/L) 0.05 0.05 0.3 0.5

Cyanide (mg/L) 0.005 0.005 0.1 0.2

Volatile Hydroxybenzene (mg/L) 0.005 0.005 0.01 0.05

3.8 Air QualityBackground air quality monitoring completed for the proposed SEGX mill site in 2007 (RIEPG, 2008) and 2010 (BEMC, 2010) did not detect any pollutants above the standards for Class 1 pollutants (Ambient Air Quality Standard GB3095-1996), H2S or odour. Values reported for SO2 and NO2 were similar in both monitoring programs and were generally low at <20% of the hourly and daily standard for NO2 and about 3% and <20% respectively of the hourly and daily averaged standard for SO2. The results for odour show non-detects for all samples at all sites.

The background air quality is important baseline data which helps to determine whether there are any elevated levels of pollutants existing already within the air-shed which may affect the objectives and targets of the proposed industries at the industrial port. In this case no significant elevated pollutant levels were noted, however, suggestions and improvements to the existing air quality monitoring data set are presented in Appendix C, along with a review of the suitability of the monitoring programs and methods applied.

3.9 Existing Infrastructure

3.9.1 Roads

The roads that will be used in the project can be put into four categories; highways, access roads, forest roads and plantation roads. For the first 3 years of harvesting, SEGX estimate that approximately 600 km of access roads will be used.

Highways: The highways in the Guangxi province are high quality and in many cases are four lane concrete highways (First Class Highways). There is currently a large works program proposed to further improve the highway system in

Along with providing ecosystems for freshwater ecology, the rivers are also used for drinking water supply for villages, towns and cities within the project area. CRAES (2008) identified 53 urban drinking water reservoirs or direct extractions of drinking water from rivers within the project Area.

Surface water quality is routinely monitored within the rivers, lakes and reservoirs of Guangxi by the Provincial Water Resources Department and has been assessed against the Environmental Quality Standard GB3838-2002, broadly summarised in Table 13.

Table 13 Water Quality Classification

Grade Use Classification

I The source of the water body and national nature reserve

Drinking water quality

IIClass one water source protection area for centralized drinking water supply, natural habitat for rare species of fish, and spawning grounds for fish and shrimps.

III Class two water source protection area for centralized drinking water supply, sanctuaries for common species of fish, and swimming zones

IVMainly applicable to water bodies used for general industrial water supply and recreational waters in which there is no direct human contact with the water (non-physical)

Polluted

V Mainly applicable to water bodies used for agricultural water supply and for general landscape requirements. Polluted

V+ Essentially useless Highly Polluted

Source: PRC Environmental Quality Standard GB3838-2002

CRAES (2008) presents water quality monitoring results based on monitoring of the 12 rivers noted above during wet and dry seasons of 2007 and concludes that water quality from all sample locations, with only a few minor exceptions, meet or exceed Class III water quality standards (GB 3838-2002) and are within the following ranges: pH 6-9, permanganate 6 mg/l, BOD5 less than 4 mg/l, NH3-N less than 1 mg/l, and phenols less than 0.005 mg/l.

The CRAES (2008) findings are consistent with those reported by the China National Monitoring Centre (World Bank 2006) for waterways within Guangxi. Water quality grades for 2004 within the Xi River catchment in Guangxi are predominantly Grade I-III (World Bank, 2006).

In addition to these surface water monitoring results CRAES (2008) conducted limited groundwater monitoring and analysis, including 6 locations within the project Area, using existing groundwater drinking wells as sample sites. The results of groundwater monitoring showed some cases of low pH (<6) water, however other parameters were within the Class III water quality standards (GB 3838-2002) range as listed above.

While these studies do not represent a detailed assessment of spatial or temporal variance in water quality, they provide some indication of a generally healthy surface water system. It is understood that local authorities monitor surface water quality at regular intervals but SEGX and CRAES do not have access to this data.

3.7.2 Marine Waters

Past technical reviews, in particular SCSIO (2007), RIEPG (2008), and SCSIO (2010), conclude that the marine area near the Tieshangang Industrial Zone is relatively sensitive and also supports a significant fisheries industry. Based on limited existing marine water quality monitoring data, the water and sediments appear to be in a good condition, with marine water quality analysis showing results within the highest quality standard (Class I Seawater Quality Standards (GB3097-97)), and the marine ecological environment seems to be relatively stable. However, a detailed water quality baseline monitoring program has not been implemented and firm conclusions on marine quality cannot be developed from available existing data.

Water quality analysis within the Tieshan Bay area has been reported in RIEPG (2008) and in SCSIO (2010), based on a sampling programs undertaken in March and May 2007 and in May 2010. The monitoring programs were developed based on the Chinese Standard HJ/T2.3 – 93: Technical Guidelines for Environmental Impact Assessment (Water Quality) and include samples collected during flood and ebb tides. Appendix D provides a full review of the water quality monitoring programs undertaken to date.

As part of the Tieshangang Industrial Zone development, marine water quality objective zones have been developed ranging from Class 2 to Class 4 (GB3097-97), as shown in Figure 8 (SCSIO, 2010) with reference to Table 14. The proposed mill effluent discharge with be located within a Class 3 water quality zone.


4. Social and Environment Impacts4.1 Overview

This section details the key potential environmental and social impacts associated with the project, based on the environmental impact assessments and technical reviews previously undertaken, the complementary studies undertaken as part of this report and additional international literature relating to forestry and industrial projects.

As discussed previously, detailed environmental impact assessments have been undertaken for the project and approved by the relevant Chinese Ministries. This report consolidates, updates and builds, on this information. It is not intended that this section provides a detailed assessment of impacts in the form of an impact assessment study; rather it provides an overview of key potential impacts.

The IFC EHS Guidelines for Forest Harvesting Operations and Pulp and Paper Mills have been used as the basis for this review. The review also considers cumulative impacts at the Tieshangang Industrial Zone.

4.1.1 Key Social and Environmental Impacts

The key potential environmental and social impacts from forestry operations identified from the IFC guidelines include habitat alteration and loss of biodiversity, water quality, soil productivity, hazardous materials management and visual impact. The potential community health and safety impacts include impacts to water resources, fire occurrence, transportation and pesticide exposure. The guidelines recommend implementation of general ambient air and surface water quality guidelines and an environmental monitoring program.

The key potential environmental and social impacts from pulp and paper mills identified from the IFC guidelines include wastewater discharge impacts, air emissions, solid waste and noise. The potential community health impacts include chemical storage, use and transport, odours, and traffic. The guidelines recommend compliance with emission and effluent guidelines for pulp and paper mills, tracking resource use (energy and water) and environmental monitoring programs.

Based on a combination of the above potential impacts the key considerations addressed in this section include the following.

» Social impacts, including on local communities

» Habitat alteration and loss of biodiversity

» Water resources and quality impacts

» Air quality and odours

» Transportation and traffic

» Amenity (including visual impact, noise and dust)

» Hazardous materials management (including chemicals, pesticides and waste)

» Fire

4.2 Social ImpactsThis section considers potential impacts on local communities from the development and operation of the project. Impacts relate to the management of the plantation estate and the development and operation of the industrial facility in the Tieshangang Industrial Zone.

Lands included in the SEGX forestry estate include a hierarchy of administrative and social elements. These include (in descending order): Provincial Government, Cities, Counties, Townships, administrative villages and natural villages. Potential social impacts will predominantly affect villages and individual households. The number of households and populations of individual villages vary. Villages can be located within or adjacent to the plantation estate, or along access roads. Farming lands will also be incorporated within the plantation estate.

Village livelihood is predominantly based around agriculture. This can include cropping, livestock or aquaculture. Household income is frequently supplemented by residents working in other centres as migrant labour. Land rentals for such things as

Guangxi and it is anticipated that by the time the SEGX mill is completed all highways that will be used by the project will be of a very high standard (CRAES, 2008).

The Beihai-Tieshan Port First Class Highway has been built, leading all the way to the port. A first class highway from Yulin to Tieshan Port is under construction which will connect with highways from Beihai to Nanjing and Guangdong Province.

The Beitie First Class Highway has been constructed as the main entrance to the Tieshan Industrial Zone.

Access Roads: Access roads are public roads of a varying standard that provide access to the plantation forest areas, as well as villages and farms. If these access roads cannot be upgraded then they will only be used by small farm trucks carrying 6 - 8 tonnes for transportation of the wood to depot site(s).

Forest Roads: Forest roads are classified as roads that go through the plantation forest areas and also include some public roads. SEGX proposes to upgrade these roads as per the standard outlined in Appendix B. Some of these roads are used by the public.

Plantation Roads: Plantation roads are small roads that are constructed to access particular areas of a plantation and are not public roads. These roads are simple, not all weather roads and are constructed for the purposes of plantation tending and protection.

3.10 AmenityThe amenity associated with plantation estates will vary with population, land use intensity and geography, however most locations will be characterised by a rural and forested landscape. Human influenced landscapes will dominate, whether villages, farming lands or plantation forests. Topography will vary from lower slopes to steep hills and mountainous terrain.

The amenity associated with the Tieshan Industrial Zone is currently transforming from a coast and agricultural landscape to one of a major industrial precinct, of which SEGX will be one tenant. Views of the area up until recently included a range of rural settings, with open fields and crops interspersed with villages and other buildings. Extensive areas of aquaculture have largely reshaped the coastal landscape. The Zone is now characterised by new road and industrial infrastructure (power stations and lines and wastewater treatment plants), cleared sites and construction activity. New, small scale commercial ventures are also establishing in the area to support this activity.

The region does however feature areas of significant local and regional amenity. For example, Silver Beach is located in the southern coast of Beihai City, 8 km from Beihai centre and approximately 45 km to the west of the Tie Shangang Industrial District. Silver Beach is renowned as “the first beach in China”, for its “long and flat beach, fine white sand, clean and mild water, soft wave and no sharks” (South China Sea Institute of Oceanology of Chinese Academy of Sciences, 2007).


made apparently collectively by the village or town leaders but without the involvement or knowledge of all parties. Contracts have also evidently been signed where details of the rental amount or rental payments have not been clearly documented and communicated. Some cases referred in surveys include leaseholders not being aware of rental agreements until forestry contractors have arrived to undertake work on the land.

The process of lease negotiations is complex and not well monitored. SEGX has recognised that there are significant issues and has initiated changes to the contract assessment process. SEGX is continuing to develop the relationship with BHC and land contractors to promote a more structured inclusive and transparent process.

Employment opportunities: Comments in a number of surveys have concerned the lack of opportunity for local communities to benefit from employment on SEGX plantations. This contrasts to other surveys which identified that wages for plantation workers were not sufficient to attract local workers.

SEGX engages contractors to supply labour. Contractors may source labour from outside local areas and outside Guangxi. Unless there are incentives to employ local workers, contractors are unlikely to preference local workers over established migrant work teams.

Transport Impacts: Impacts from the transportation of wood and other material within the plantation estate are addressed in Section 4.4. These primarily relate to dust, noise, road damage and safety issues and have been identified by SEGX as key areas of focus for management of its transport operations.

Protection of workers’ rights: Surveys indicated a relatively low proportion of local workers have been successful in gaining employment within the SEGX plantation estate. Possibly as a result of this low local workforce, workers’ rights and conditions (other than rates of pay) did not have prominence in the survey results.

Worker’s rights are a key issue within the industry. SEGX has instigated a number of initiatives to protect workers’ rights and conditions including: (i) minimum camp conditions including specified shelter, sanitation and cooking arrangements which are advertised at the camp sites; (ii) defined labour rights which are advertised at the camp sites; and (iii) demanding insurance for workers and checking that they receive at least the minimum wage.

4.2.2 Social Impacts Associated with the SEGX Mill

Local communities have been relocated from the Industrial District, including the SEGX site, by the Chinese government (summarised in Box 5). This resettlement process has occurred in the context of the larger resettlement process associated with the TPIZ as detailed in Section 3.3.4. The matter of compensation and benefits is the responsibility of, and is wholly managed by, the Beihai Government. As a result of the relocation communities have transformed from an agricultural existence to an urban lifestyle. Most families have lost their lands and have no other source of income. Some have retained access to some or all of their lands. SEGX recognises that, whilst the resettlement of these communities is the responsibility of the Beihai government, SEGX may contribute to the well-being of the community.

Box 5: Nanle Village Resettlement Process: The establishment of the SEGX mill site included resettlement of local residences

from the Nanle Village to a newly established resettlement housing area located approximately 2 km from the SEGX site. The

resettlement process was managed by the government in accordance with government policy. The resettlement process

was implemented between 2006 and 2009. This included a total of 1,409 relocated people from Nanle Village of whom 1,236

resided within the 250 ha area of the SEGX mill site. The resettlement process was managed by the Beihai City Government, as documented in the Implementation Particulars of

Land Acquisition and Relocation for Beihai Forestry, Pulp and Paper Integration Project, and the Relocation Settlement Plan for

Beuihai Forestry, Pulp and Paper Integration Project. The process included initial consultation and meetings with all affected

people, followed by agreement on resettlement contracts in accordance with local government policy for land resettlement

and housing resettlement. Based on interviews conducted as part of the complementary survey works detailed in Appendix

D, compensation received by affected people included RMB 70,000 per person for land, with an extra RMB 2,000 per mu

for crops and RMB 360 per square meter for housing. An ongoing allowance of RMB 100 per month has been provided to

affected people without jobs (affected people provided with jobs are not entitled to this allowance). The Nanle Primary

School and Village Community Office building was also relocated.

forestry generally make up a small proportion of total income.

Whilst data on the number of households affected by the plantation estate are not available, UNDP (2006) estimates that with a 120,000 hectares wood fibre estate, there will be approximately 133,000 households and 650,000 people affected by land rental. There may be in the order of 10 million people located within the counties in which land rental will occur.

Over a four year period, approximately 1,800 surveys and interviews have been undertaken through a range of proponent and external organisations. These surveys have captured all levels of Government and community hierarchies and covered areas representative of plantation and industrial development. Findings from these surveys are discussed in the following sections and in Appendix A.

4.2.1 Social Impacts Associated with the Plantation Estate

As SEGX is only acquiring existing forestry lands for the plantation estate there is unlikely to be any significant new impacts associated with changes to land use or relocation of households or farming land to make way for plantation development. As detailed in Section 2, approximately 29% of the current plantation estate is located on social land and 71% on state land. In having contracted over 84,000 hectares of land, SEGX has already contracted over half its target plantation estate. With an additional 41,000 hectares offered by Government, over 78% of the 160,000 hectares approved in the application scope will have been achieved. As such, impacts are both actual and potential over a significant area.

The results of the various surveys conducted as part of the forestry operations and ongoing land contracting, as detailed in Section 2, show common potential social impacts as reported for similar forestry projects in other developing countries. However, while common to other projects, these social issues are no less challenging to address. The key potential impacts on communities as part of this type of land contracting and forestry operation have been highlighted to include: (i) fair and prompt payments/compensation; (ii) lack of free, prior and informed consent of landowners; (iii) conflict over land tenure/ownership; (iv) employment opportunities; (v) transportation impacts (noise, dust, road conditions); and (vi) protection of workers’ rights.

Fair and prompt payments/compensation: Whilst it varies from village to village, rental of forestry land can make up a significant proportion of household income and can provide additional income derived from otherwise unproductive land (land with insufficient soil or too steep for agriculture). In other cases where there is an alternative use for the land, there may be an opportunity cost associated with forestry rental. In both cases it is important that households receive fair and prompt payment for forestry land.

A common concern raised in surveys is the transparency, amount and timeliness of rental payment.

Given the often complex relationship between SEGX and the leaseholders, which may involve BHC, contractors and town and village administrators, land tenure negotiations are not directly held between SEGX and the villagers, but can be held between any combinations of parties involved. As such, there is the potential for confusion, inefficiencies and the risk of inappropriate or unauthorised payments being sought.

Stora Enso is developing this project in cooperation with the Guangxi government and processes have been put in place with BHC and contractors as part of this arrangement. These processes and relationships require continual improvement, particularly in the management of land contractors operating as middle men.

Concerns as to the level of payments is a complex issue of market price, land constraints, transparency of negotiations and the expectations of leaseholders. Greater transparency as to the pricing arrangements may address some of this issue.

Conflict over land tenure / ownership: There have been land ownership conflicts in relation to SEGX plantations in the past, which have resulted in injury and in one instance a death. SEGX commenced a revision of their land leasing process in 2009, as outlined in Section 2.3.1 and Box 3, and a review of all existing contracts. Where required, contract amendments have been negotiated to address issues and SEGX has reported that new contracts now meet these standards.

A number of these conflict issues have resulted from land leased without the leaseholder’s consent. This is discussed further below.

Lack of free, prior and informed consent of leaseholders: There have been reported instances where contracts have been signed for land without the involvement and/or consent of the leaseholder. Decisions may also have been


Table 15 Estimated SEGX direct employment at full scope operation

SEGX direct jobs SEGX permanent direct outsourced* jobs Comments

Forest operation and wood supply chain 1,270 5,900 Estimated by SEGX from 2009 scenario forest base

fully established and mill in operation

Mill intergrate, full application scope (900,000 ADt pulp/a, 450,000 t board/a, 450,000 t paper/a)

1,200 200

The division into direct and permanently outsourced staff is tentative.

RIEPG (2008) estimate that the SEGX mill is likely to produce over 1,400 new job opportunities, which is similar to the number estimated by SE.

Total 2,470 6,100

SE has support and sales offices and several production units in China with which the Guangxi operations will share some corporate support facilities.

* SE notes that the extent of outsourcing of company activities long term depends on the availability of contractors and the quality of the

service providers in the area of operation.

Using rough industry standards of an additional 2.5 permanent jobs created in upstream and downstream value chains, total direct and indirect employment of mill, plantations and supporting industries at full scale will be in the order of 30,000. This is comparable to the estimate made by UNDP (2006) of 30,000 to 35,000 direct and indirect jobs at full scale operations. The new jobs produced by the SEGX forestry and mill operations will help to relieve current social burdens and employment pressures, and also improve people’s living standards.

The construction phase of the SEGX mill is estimated to employ some 6,000 workers at the peak phase of construction as shown in the following Figure. These employment estimates are based on manpower needed for the construction of a greenfields pulp mill of similar size.

Figure 9 Estimated job creation during construction phase of the SEGX pulp mill

SEGX has confirmed through its own surveys and meetings with affected people that compensation was received and

ongoing allowances are being paid. SEGX paid Beihai government for the mill site land area according to a separate

agreement that includes aspects of the establishment of the mill site and its infrastructure. There is no provision in the

agreement that specifies a certain amount as committed to compensation for the resettlement. The total cost for the

resettlement and compensation and what funds the government used for this purpose is not known to SE.

Surveys have identified a number of issues raised by the resettled communities (Appendix A), including: (i) the suitability of compensation; (ii) the suitability of benefits; (iii) lack of and delays in job opportunities (both with SEGX and others); (iv) lack of training opportunities; (v) concerns with provision of services; and (vi) concerns with the lack of amenity.

Resolution of these issues is primarily the responsibility of the Government. There are however opportunities once the project has commenced for SEGX to extend its involvement with the resettled community. These activities might include: (i) ongoing consultation; (ii) community development opportunities (green space, recreation); (iii) training; and (iv) employment.

SE has indicated that it expects that, during peak construction, there will be some 6,000 people working on the site and also people associated with the necessary support functions/businesses around the site. Similar challenges to ensure decent workers’ conditions, as detailed for the forest operations, will exist for the mill site.

Vocational training programmes will be implemented to recruit young secondary, high school and university graduates to develop their skills as pulp and board mill operators, shift foremen, superintendents and engineers. Staff housing and other social facilities will not be built near the mill initially, as it is envisaged that mill personnel will live in Beihai.

4.3 Economic EffectsThe total investment for the plantations and the mill integrate full application scope is estimated to be approximately CNY 23 billion, including construction investment of CNY 21 billion and working capital of close to 2 billion RMB (CRAES 2008, RIEPG 2008).

CRAES (2008) notes that there is around 4.2 million people in the rural labor force near the project Area, including close to 50% female workers. However, the rural average per-capita farmland is only 0.71 mu, which only requires a total of 622,000 labors each year. CRAES (2008) argues that there is a surplus in rural areas of about 3.5 million laborers and concludes that the labor resources are sufficient for the project and would likely welcome and benefit from the creation of jobs associated with the project. However, this assessment does not include an evaluation of skill capacity of this excess labor force nor does it consider the potential negative impact on employment associated with the possible displacement of existing paper industry facilities which employ 33,123 labors.

RIEPG (2008) highlighted that the project is of great significance with respect the potential for enhancement of the standard of equipment and technology used within the pulp and paper making industry in Guangxi, as well as the grade improvement of the paper and cardboard products. In addition, the taxes turned over each year after the project is put into production may help increase the local financial revenue, enhance the economic strength of Beihai City and promote the development of local public welfare programs (SEGX is providing direct funding to local communities where possible within the government framework, to support local welfare programs. SEGX plans to increase its support with training to develop skilled workers once the mill facility is online).

The employment on SEGX plantations was about 4,400 persons in 2005 (UNDP, 2006). SE estimate that the plantation and mill (full scope application) will directly provide around 8,570 jobs, as shown in the following Table.


the risk of negative impacts to biodiversity. CRAES (2008) highlights that as a result of SEGX’s practices: (i) there will be no direct loss of native forests as a result of plantation establishment; (ii) there will be no change to overall land use within Guangxi given the already extensive forestry resources; (iii) there will be some loss of understorey diversity where understorey occurs within the previous forestry plantations; (iv) there will be no direct impact on areas of conservation significance; (v) that existing forestry areas are not suitable habitat for fauna species of conservation significance such as the white-headed leaf monkey, leopard, clouded leopard, spotted deer, forest musk deer and Indian python. These species are already restricted to more remote and mountainous areas where human presence is low; and (vi) there will be no significant direct impact on fauna from clearing and indirect impacts on migratory/movement corridors are expected to be minimal.

4.4.2 Water Quality Impacts

Potential water resource impacts may result from changes to surface and groundwater availability and quality. Potential plantation impacts would primarily be indirect, as a result of increased erosion (and subsequent sedimentation of waterways) as well as contamination of runoff as a result of fertiliser and herbicide use. The issue of perceived eucalypt toxicity by some villagers is also discussed below.

Potential Impacts from Herbicides and Fertilisers: SEGX currently limits application of herbicide to glyphosate for weed and coppice control. Herbicide application is not permitted within 50 m of waterways or ponds as required under the SEGX IOSP Handbook (Stora Enso, 2010), reducing the risk of contamination of surface water bodies.

Fertilisers used include limestone and nitrogen/phosphorous/potassium blends (N/P2O5/K2O) applied by hand or machine as solids. Other chemical and fertilizer on-ground use (spreading) is forbidden in 50 m buffer zone (horizontal distance) along water courses, ponds and managed agricultural land (SEGX, 2010), again reducing the risk of contamination of surface water bodies.

SEGX applies fertiliser prior to planting by placing fertiliser in the prepared hole. A second fertilisation program may be run during the seedling tending phase of growth. The first top dressing is applied 1-2 months after planting and then a second top-up at 7-8 months. The necessity for further top-ups will be determined from soil sampling at individual sites (CRAES, 2008)

Potential Impacts from Eucalyptus Water Requirements: Xu (2007) provides an assessment of the potential impacts on water and ecosystem impacts from SEGX’s Eucalypt plantations. This includes a detailed global review of studies assessing impacts on water quality and quantity, including field studies undertaken in China. The report concluded that:

» Water uptake for fast growing plantations will be higher than those for some other land uses, for example grasslands, but are similar to other plantation species.

» Based on estimated evapotraspiration rates, higher water balance impacts are not expected for Eucalypt plantations over other plantation species;

» Any impacts on local and regional water yield is expected to be low given that the SEGX plantations will be within areas already utilised for forestry;

» Studies in India, South Africa and Brazil on the impacts of Eucalypt plantations generally identified that these plantations had similar evapotranspiration rates and impacts on soil moisture uptake to that of native forests;

» Water quality impacts from Eucalypt plantations were identified in some studies as being an improvement over agricultural uses due to reduced erosion and chemical application; and

» Plantations should not be encouraged in areas with a lower than 1200 mm annual rainfall or where there is insufficient soil depth.

These conclusions are also supported by a report prepared by the Guangxi Forestry Institute on an Analysis on Sustainable Development and Silviculture Technique of Eucalyptus Plantation in Guangxi (Guangxi Forestry Institute, 2007).

Potential Impacts from Eucalypt Toxicity: An assessment undertaken in Tasmania, Australia, in 2010 (Batley et al, 2010) specifically looked at the issue of water borne toxins derived from Eucalypt plantations. Concerns had been raised by a local community about possible health risks from Eucalyptus nitens plantations within their water supply catchment.

The pulp mill construction will include all utilities for water and effluent treatment and heat and power generation. The adding of board and paper mill units may then commence from an established mill site and require comparatively less manpower in a construction phase.

The majority of the project construction workers will be contractors, to be assigned by the investing owner company or employed or contracted by the construction companies or equipment suppliers. This work force will be temporary from the viewpoint of the specific project although some contractor’s workforces will be permanently employed by the contractor and move from job to job. It is expected that some of the specialized workforce will relocate from different assignments and projects outside Guangxi and, while not being migrant workers in general, they are nevertheless a transient work force that moves from project to project.

In addition the project will indirectly result in the creation of new jobs in associated services such as restaurants, local shops, accommodation and cleaning.

4.4 Plantation Estate Potential Environmental Impacts

4.4.1 Biodiversity Impacts

This section considers the potential impacts on biodiversity from the plantation establishment and operations. As described in previous sections, the landscape in Guangxi is mostly dominated by human activity, with rice fields, sugar plantations and timber forests dominating the landscape in most areas. Therefore, biodiversity has been altered from its natural state as a result of many decades of human development in the region. There are a number of potential biodiversity impacts associated with establishment of plantation forests, including direct impacts from clearing and indirect impacts associated with water quality (sedimentation from erosion, contamination from fertiliser and chemical application) and habitat fragmentation.

The plantation estate will primarily consist of introduced species. Whilst the biodiversity of the natural forests are much higher than eucalypt plantations, there is no evidence that the eucalypts have any direct impact on biodiversity at either genetic or species level and there are no indications of Eucalyptus species moving outside the plantation boundaries (UNDP, 2006).

Deforestation for agricultural purposes began in Guangxi over 100 years ago. Species such as Pinus elliottii and acacias have been grown in the region since the 1960s to recover forest land and to promote rehabilitation of degraded areas. The recent increase in the production of timber has not significantly altered the landscape or impacted on areas that have been allocated for conservation purposes (UNDP, 2006). In addition, the project areas accounts for only 0.7% of the total land area in Guangxi and 2% of the commercial forestry estate (Cossalter and Barr, 2005). As a consequence, changes to landscape or biodiversity as a result of the establishment of the project plantations are unlikely.

A bird survey report completed in 2011 by Fauna and Flora International (FFI, 2011) identified some impact to bird species numbers and bird population numbers in Eucalyptus plantations compared to natural forest in Guangxi. FFI indicated that both species and numbers of birds in Eucalyptus plantations were less than in well reserved natural forests, secondary forests and pinus massoniana plantation. However, they also noted that species and numbers of birds were higher in Eucalyptus plantations than in farmlands and nature reserve habitats. FFI indicated the reasons for the reduced species and numbers of birds in Eucalyptus plantations was due to the relatively simple habitat in the plantations and the lack of heterogeneity of plant species.

Land to be developed as part of the SEGX plantation estate is only selected from existing forestry lands. As a result no native vegetation or agricultural land will be cleared as part of development of the estate. This significantly reduces the biodiversity impacts of the project as no land use changes should occur.

The SEGX IOSP Handbook specifically excludes harvesting in unsuitable topographic areas including waterways, ridges, gullies, narrow valleys and specific low and wet lands (Stora Enso Guangxi, 2010), reducing the risk of land degradation. In addition the IOSP Handbook incorporates a range of practices to mitigate impacts on the natural environment, in line with international best practice, including: (i) avoiding conversion of natural or protected forest to plantations; (ii) locating plantations at least 1 km away from nature reserves; (iii) ensuring that 20% of plantations are non-Eucalyptus; (iv) maintaining buffer zones around watersheds, gullies, narrow valleys and specific low and wet lands and others land uses; (v) preserving natural or original vegetation on ridges area with steep slopes (>25-35 degree), or around waters; and (vi) avoiding traditional slash and burning practice.

The management and mitigation measures developed and implemented as part of SEGX operational practices have reduced


occur approximately only every 6 years. Outside these key activity periods, activity will be minimal and associated with regular maintenance, such as weed control and fertiliser application.

4.4.5 Solid and Hazardous Waste Impacts

It is common practice to use fertilisers and other chemicals on plantations to protect the trees from insects and disease, as well as promoting growth. Chemical use for eucalypt plantations is considerably less than other agricultural uses (Jenkin cited in UNDP, 2006). Pesticides are not regularly required within the plantations.

The SEGX plantations will spray Glyphosate to control weeds. This method of control is more effective than hand weeding. Even so, hand weeding will be used in sensitive areas (Stora Enso, 2010). Herbicide is not applied within 50 m of a waterway.

Within the company plant nursery a broader suite of chemicals is used including:

» Rooting hormone: Rootone

» Fungicides: Carbendazim, Thiophanate-methyl, Sodium p(dimethylamino)benzenediazo sulfonate and Pyrimethanil

» Pesticides: Bacillus thuringiensis, Imidacloprid and Acetamiprid

» Herbicides: Glyphosate

» Sterilizing liquids: 75% alcohol, Potassium permanganate and Sodium hypochlorous

All chemicals are subject to the appropriate management plan and wastewater is recycled to prevent pollution of local water sources.

Management controls for plantation operations include: (i) effective communication of the existing Glyphosate Management Plan to contractors and employees; (ii) implementation of the Safe Handling Procedures Manual at the company nursery facilities to deal with nursery chemical safety standards; (iii) all staff concerned are trained in chemical safety and equipment in place for spills; and (iv) spill procedures, training and equipment for handling oil spills from machines and vehicles.

4.4.6 Fire Impacts

With villages and individual households located in close proximity to plantations, plantation fires pose a direct safety risk and potential risk to life and property. Smoke can be a safety hazard, especially to traffic and road users. There is the potential for temporary and permanent health effects associated with smoke inhalation.

Flora and fauna species have evolved with different response strategies to fire, with those species not adapted to fire having typically greater vulnerability to impacts. Direct and indirect ecological impacts can include: (i) loss of habitat and food resource; (ii) direct mortality; (ii) loss of refuge and increased risk of predation; (iii) loss of habitat connectivity; and (iv) reduction in range for more mobile species.

Fire conditions occur when a number of conditions occur simultaneously. Factors that influence the severity of fire weather conditions include: (i) fuel moisture; (ii) fuel quantity; (iii) fuel characteristics and distribution (which may be affected by grazing, firewood collection, breakdown of organic material); (iv) rainfall which will effect understorey and dryness of fuel,;(v) relative humidity – the lower the humidity, the drier the fuel; (vi) air temperature which can dry fuel; (vii) wind strength; and (viii) variation of wind with height can affect the transport of sparks and create unusual and erratic wind conditions.

Observations from Australian plantations (Geddes, 2006) suggest that fires in young eucalypt plantations are not intense or rapidly spreading as there is generally little ground fuel, a managed understorey and there is a separation of ground and aerial fuel, reducing the risk of crown fires. Weed and coppicing control reduce understorey fuel and therefore fire risks.

Weed Control: Effective weed control is a significant consideration with regards to fire management in the Guangxi area. Control of weeds helps to minimise the risk of fire, especially as many of Stora Enso’s plantations are adjacent to other farm lands. Active fire prevention measures include the establishment of fire breaks around plantations and between the eucalypt plantations and neighbouring croplands. In addition to weed control, SE has identified the control of leaf litter and undergrowth as a major fire control measure. The risks associated with leaf litter are higher during the growing phase of the plantation and risks diminish once forests are established (UNDP, 2006).

Fire Management: SEGX has implemented a range of Fire Management procedures for the forestry plantations that include: (i) prohibit burning as part of site preparation; (ii) fire breaks established and strategic alignment of roads to

An independent panel of water experts was established to review the issue and released their report in June 2010. The findings of the assessment concluded that there are no threats from water runoff or water foams on ecosystems and human health from E. nitens plantations.

The assessment’s main line of inquiry related to the toxicity and composition of oils contained in eucalypt species as this is one of the natural defences the species have developed against insects and herbivores. The panel reviewed available information and spoke to published authors.

The panel referred to several investigations that have examined the impact on river fish and invertebrates when exposed to highly concentrated eucalypt leachate. McMaster and Bond (2008) found that ‘blackwater events’ caused by leachate from Red Gums (E. camaldulensis) entering isolated pools during dry summers had no impact on fish even when dissolved organic carbon (DOC) concentrations were ~50 mg/L (typical concentrations of DOC are <10 mg/L).

Other research referred in the assessment included investigations into the toxicity of E. globulus leachate on a range of organisms, including blackflies, midges and freshwater shrimp, and found that aeration had a notable impact on toxicological response. The author did suggest that oils and derivatives and phenolics in the pure leachates have the potential to affect the digestive capacity of invertebrates in non-native ecosystems (Batley et.al, 2010).

Given the extensive development of Eucalyptus plantations globally over an extended period of time, it is unlikely that toxic leachates would have been experienced without being widely reported.

With over 30% of Guangxi under commercial forests, the surface water quality within the province is predominantly within the top three water quality classes and considered suitable for drinking water supply. This would suggest that current forestry practice in relation to fertilisers or herbicides is not resulting in significant water quality impacts.

Controls and training in regards to the use of herbicides and fertilisers, including buffers to sensitive areas, significantly reduce the risk of off-site impacts. The correct and safe management, transport, storage and application of these substances will minimise risks to workers and neighbouring communities.

4.4.3 Transportation Impacts

The potential impacts on the local communities (such as safety, dust and noise) from project transport and logistics are associated with the transportation of logs. Regular and tailored communication and interaction with the local people will be essential in minimising these impacts. A summary of potential issues and risks is provided below:

» There are a number of narrow, poorly constructed roads that trucks must traverse in order to deliver logs to the SEGX mill;

» Wear and tear of existing roads may result in degradation of the roads and increase the likelihood of accidents;

» Log transportation will be by contractors and there is a risk that they may not adhere to SEGX’s regulations involving safe driving behaviour and road speed limits;

» Congestion may occur from too many trucks on the road, resulting in inconvenience to local road users and/or road accidents; and

» Overloading of trucks may result in accidents, break downs or logs falling off trucks.

4.4.4 Amenity Impacts

Key amenity issues associated with the plantation estate are likely to include dust and noise.

Dust may become a significant problem when trucks are travelling through villages or areas where there are unsealed roads and large populations, impacting upon local communities. Dust may also be a sign of deteriorating roads and soil structure in some areas, especially in dry months.

Noise may be a significant problem due to the anticipated high numbers of trucks movements through some village areas.

Forestry is an existing part of the cultural and physical landscape of Guangxi. Approximately 57% of the province is forest. Eucalypt plantations make up a minor proportion of this existing forestry. All SEGX forest estate lands are existing plantations and, as such, noise and dust are factors of pre-existing operations on these lands.

High activity periods in any given plantation will be campaign based around harvesting and planting activities which will


The standard GB 3097-1997 does not include limits for AOX and dioxin concentrations in sea water. No quality criteria are yet defined for these parameters for the receiving waters. AOX and dioxin in the discharge are regulated within the effluent standard limits GB 3544-2008. The incremental concentration footprint from the effluent for AOX at 0.1 mg/L and for dioxin at 0.1 pgTEQ/L is less than 0.1 km2. There are no known background data for the bay.

Effluent quality parameters related to the technical design specification for the effluent treatment plant are provided in the Technical Description, Pulp Mill Design (SE, 2010), and in Table 16. The list of analytical parameters corresponds to the standard GB 3544-2008 (Effluent standards for new pulp, paper and board production). Specified discharge values are quoted as being systematically lower than the limits determined by the standard. A review of the hydrodynamic modelling can be found in Appendix C.

Table 17 Effluent Quality for Different Phases of the project compared to standard limits and specification for technical design of effluent treatment

PollutantUnit

GB 3544-2008, standard

RIEPG 2008, Environmental approval limits

Technical Description, (SE 2010)

Limits for Integrated pulp and paper millsd

Phase1; pulp milla

Phase 2; +board mill

Phase 3; +paper mill

Effluent treatment design spec. averaged in phase 3

pH 6-9 6-9 6-9 6-9 6.5-8

Colour times dilution 50 <50 <50 <50 <50

Suspended solids, TSS mg/L 30 <50 <30 <30 26.6

BOD5 mg/L 20 <20 <20 <20 6.5

CODCr mg/L 90 <100 <90 <90 <85

NH3 mg/L 8 <6 <6 <6

Ntot mg/L 12 <8 <8 <8 3

Ptot mg/L 0.8 <0.8 <0.8 <0.8 0.3

AOXb mg/L 12b <5 <4 <3.5 <3

Dioxinb pg TEQ/L 30b <6.19 <5.03 <4.32 e

Chlorate mg/L not defined <3.5

Specific discharge flowc m3/t 40 25/ADt +13.9/t +9/t 18-19

Notes: a) COD 100 mg/L corresponding to GB 3544-2008 limits for standalone pulp mills

b) GB 3544-2008 refer AOX and dioxin as before effluent treatment, RIEPG and SE 2010 refer to treated treatment

c) Specific discharge flow for phase 1,2 and 3 refer to the final approved levels, see amendment to RIEPG November 2008

d) The technical design specification refers to average values while GB 3544-2008 refers to daily discharge limits.

e) Dioxin level controlled trough process design not effluent treatment, hence not in tech. spec. Effluent monitoring reported for the UMP Fray

Bentos eucalypt pulp mill in Uruguay with similar design as the one in this project reports dioxin as < 1 pg. TEA/L effluent.

There are several other facilities in addition to the proposed SEGX Mill that are likely to have an impact on the surrounding marine environment within the Tieshangang Industrial Zone. The key enterprises within the industrial zone include a Sinopec polypropylene manufacturing facility, the Chengde Stainless Steel manufacturing plant, a coal fired power plant and a large scale industrial port. Other industries will be developed in the zone, however a complete list of current and planned projects and the relevant information on emissions has not been available for this review. It is critical that these activities are well identified so that the background monitoring and the data interpretation encompass the associated impacts. The Tieshan Port functional zoning (figure 8) show the environmental target limits for the respective marine areas with reference to the classes in the standard GB 3097-97. This plan introduces a capped approach for the control of the industry impacts on ambient waters of the area. It was referred to in RIEPG (2008) but no detailed assessment conclusions were presented. Neither the RIEPG (2008) nor the TRIWTE (2009) considered cumulative impacts from proposed industries in their modelling of discharge to the Tieshan Port. However, in RIEPG (2008), the maximum load of all industries in the outfall location B3 was calculated from the marine water quality standard corresponding to the functional zoning decided for the overall Beibu Bay Development Plan. It is assumed that some consideration of cumulative impact predictions were made as part of the development of marine water quality standard

also act as firebreaks; (iii) weed management and undergrowth control; (iv) Fire Protection and Response Strategy; (v) Fire Communication Program (including community engagement); (vi) suppression equipment and trained staff available; and (vii) establish a fire prevention team and develop a detailed responsibility system according to the relevant laws and regulations.

4.5 SEGX Mill Environmental Impacts

4.5.1 Water Quality Impacts

Potential impacts on marine water quality could result from wastewater discharge from the mill via the ocean outfall. As detailed in Section 2.4, the SEGX Mill effluent water will be pre-treated prior to discharge, including primary, secondary biological and tertiary chemical treatment and is expected to meet international Best Available Technology (BAT) standards. The discharge pipeline will include an ocean outfall approximately 4 km off-shore, at a depth of over 10 m.

Potential impacts from effluent discharge include increased chemical oxygen demand (COD), suspended solids (SS), adsorbable organic halogen (AOX) where the halogen is chlorine and levels of nutrients as different compound of nitrogen and phosphorous, as outlined in Appendix C.

The pulp and paper industry processes use, and can give rise to, organic compounds of natural and synthesized origin that can then be present in the effluent. These arise from the degradation of wood components (lignin and resins) and the addition of surfactants or other chemicals during the process. The improvement in the bleaching process in modern mills and their treatment of the effluent decreases the likelihood of some of the most well-known compounds (such as dioxin and furans) generated in the process entering the marine environment.

Potential organic compounds present in the effluent can be broken down in the following main categories (TRIWTE, 2009): (i) organic acids, including: chloroacetic acids, resin acids (for pine only) and fatty acids; (ii) natural chlorinated phenols; (iii) chlorophenols, chlorinated guaiacols and catechols; (iv) sterols; (v) miscellaneous aromatic compounds; (vi) polychlorinated aromatic compounds; and (vii) miscellaneous organic compounds including hydrocarbons, aldehydes, ketones and chlorinated hydrocarbons.

RIEPG (2008) concluded that, based on the assessment of the baseline environment and hydrodynamic modelling of the marine discharge, the project would only have a minor impact on marine organisms and a slight impact on the environmental objectives of the adjacent marine reserves. The report found that the discharge would not damage the stability of the marine ecosystem and would not impact on designated fishing areas, based on the fact that the discharge will “quickly meet the water quality standards”. However, this is not quantified and there are gaps in the RIEPG (2008) assessment, as identified by UNDP-Hatfield (2008).

The hydrodynamic modelling defines the potential environmental footprint of the discharge against defined water quality grades based on the standard GB 3097-1997. Data presented in the environmental impact assessment (RIEPG, 2008) indicate that the ocean water quality in the planned discharge zone corresponded to Grade 1. The functional zoning of the marine area for the development of the Tieshan Port Industrial District states the objective for water quality in the discharge zone to be within Grade 2. Table 15 considers the potential environmental footprint for the parameters COD, nitrogen and phosphorous based on the preliminary loads estimated for phase 3, the complete mill application scope.

Table 16 Marine Discharge Area of Influence based on RIEPG (2008)

Pollutant

Sea Water Quality, GB 3097-1997 Reference

>Grade 1, mg/L

Max area of influence, km2

>Grade 2, mg/L

Max area of influence, km2

RIEPG 2008, Table

CODMn 2 0.0146 3 0.0008 7.4-5

Suspended solids 10 (added incremental) local, at diffuser 7.4-14

Nitrogen 0.2 0.2647 0.3 0.0145 7.4-19

Phosphorous 0.015 0.0156 0.03 0.0029 7.4-22

Based on the above, the maximum area of influence from the above parameters is less than 1 km2. The adjacent conservation areas are located over 4 km from the outfall location.


Working on the assumption that the odour emission will be predominantly H2S, the 10 ug/m3 H2S contour roughly equates to 5 OU, which is generally considered as a conservative measure of the potential onset of odour complaints if exposure is repeated. If the contours are the hourly 100% ile, then they represent an exposure of just 1 hour in 1 year and would be unlikely to result in complaints as these peak levels typically only occur at night when dispersion is poor and people are generally asleep.

RIEPG (2008) concluded that there would be not be a significant impact on air quality as a result of construction or operation of the industrial facility. The RIEPG (2008) assessment did not include the cumulative assessment from potential new industries proposed as part of the Tieshangang Industrial Zone.

Existing and future activities within the Tieshangang Industrial Zone have the potential to contribute to cumulative environmental impacts, including impacts on air quality. The other existing and proposed industries in the Zone, including the proposed polypropylene plant, crude oil storage, coal fired power stations and stainless steel plant have potential to emit hazardous products and emissions, resulting in air pollution. These emissions are expected to be of potentially moderate to high impact in terms of air quality, depending on the process and the controls used.

4.5.3 Amenity Impacts

There will be significant changes to the amenity of the immediate surrounds as a result of the development of the Tieshangang Industrial Zone. The SEGX mill development will result in impacts on local or regional amenity, however these should be considered in the context of the industrial zone development.

The significant impacts relate to the cumulative impact resulting from the overall development of the Tieshangang Industrial Zone, rather from the SEGX plant in isolation.

Given the separation distance to major centres such as Beihai, it is unlikely the SEGX mill itself will result in significant impact on amenity values in the context of the developments expected over time in the industrial zone.

4.5.4 Solid and Hazardous Waste Impacts

Hazardous materials will be used in the operation of the SEGX Mill. Hence hazardous goods management must be a key element in the management of the site and should form part of hazard identification risk assessment undertaken as part of the facility design process. The pulp and board manufacturing process is well understood and established systems already exist within the company to manage such issues.

Appropriate storage (including controls such as security, bunding and ventilation) and management systems must be in put in place as part of the facility design and operational procedures. Education of the workforce should be a key element of these procedures.

Hazardous goods will be transported to the site, posing another potential risk. SE may not be in full control here as the transport may be done by others and will be in public areas. To minimise risk, SE needs to ensure that transport of any hazardous goods is undertaken by appropriately licenced transport contractors and should conduct its own inspections to ensure that all required precautions are in place during transport.

Emergency response plans should be developed and implemented based on HAZOP risk assessment, addressing potential risks associated with hazardous materials.

Overall, assuming that all hazardous materials are transported, stored and used properly following manufacturer’s instructions and other requirements, and appropriate staff and contractor training in materials handle ling and storage is provided by ES, it is not expected that there will be significant risk to the public or workers from hazardous materials.

4.6 Cumulative ImpactsExisting and future activities within the Tieshangang Industrial Zone (as detailed in Table 17) have the potential to contribute to cumulative environmental and social impacts, along with other activities being undertaken in the project area. SEGX will not have any direct control over these external activities by others; however SEGX may be able to:

» Modify plant activities to help reduce cumulative impacts;

» Work with other parties in reducing overall impacts via a coordinated monitoring system integrating all present industries; and

corresponding to functional zoning, however the EIA report for the Guangxi Beibu Bay Development Plan has not been made available for this review and therefore this cannot be confirmed.

4.5.2 Air Quality Impacts

Potential impacts associated with the mill on air quality, including odour, are considered separately for the construction and operational phases.

Mill Construction Phase: Potential pollutants generated during construction have been identified as dust, nitrogen oxides, carbon monoxide, and hydrocarbons. The following activities could potentially impact upon air quality during construction of the proposed mill: (i) loading and transportation of construction materials; (ii) earthworks, including levelling of the ground and laying of pipes, resulting in the generation of dust; and (iii) concrete mixing.

Dust Generation: It is anticipated that the main dust generating construction activities, such as earthworks, will last for approximately five months and major concrete pours will last for approximately six to nine months. In terms of sensitive receivers there are five local villages that may be impacted by dust emissions during construction (Po Kotang, Xinwupo, Haishanba, Beimu salt site, and Yaxin), however mitigation measures will be implemented on site to reduce the level of impact (refer to Section 5).

Vehicle/Machinery Emissions: Several types of vehicles and machinery will be used during the construction phase including diesel vehicles and trucks, excavators and compressors. This will result in short term and localised increases in emissions. Vehicles and machinery will need to be serviced regularly and monitored during use to minimise impacts on air quality.

Hazardous Materials/Dangerous Substances: Construction will involve the storage, handling and use of hazardous materials and dangerous goods, which may include odorous substances. Provided these substances are used in accordance with the manufacturer’s standards/instructions then impacts should be minor. Hazardous materials emergency plans should be developed following a decision to proceed with the SEGX Mill.

Smoke/Odour: It is expected that there will be some smoke and odour generated from the canteens used to supply the construction workers with food, however is in anticipated that this will result in short term and localised air quality impacts only.

Mill Operational Phase: The major emission sources identified for the operational phase include an alkali recovery boiler, power station boilers and a lime kiln (TSP, SO2, NOx Cl2 and TRS emissions). Residual ClO2 measured as Cl2 emissions are also specified for the bleaching workshop. The electrostatic precipitators have been sized so that the in-stack particulate concentration meets the criterion of 50 mg/m3, as specified in the Emission Standard of Air Pollutants for Thermal Power Plants (GB13223 – 2003). The corresponding in-stack limits for SO2 and NOX are expected to be met.

Based on the outcomes of air quality modelling for the ultimate development of the SEGX site, RIEPG (2008) concluded that the maximum hourly average concentration of SO2 and NO2 are 0.0629 mg/m3 and 0.0405 mg/m3 respectively, accounting for 12.6% and 16.9% of the standard limit. The grid maximum value of hourly average Cl2 concentration is 0.0003 mg/m3 (0.3% of the standard limit).

The predicted maximum ground level concentration of pollutants for the ultimate development of the project; SO2, NO2 and inhalable particulates, account for 19.6%, 13.8% and 3.2% of the evaluation standard respectively.

The values of average daily concentration from discharged air pollutants at each sensitive receptor were modelled as being relatively low (RIEPG, 2008). The contribution of daily concentration of inhalable particulates was low, while SO2 maximum daily concentration was predicted as 0.0114 mg/m3 at one village site, accounting for 7.6% of the standard value. The contribution value of NO2 accounts for 5.9% of the standard value.

The pollutant accounting for the largest share of standard value after being added with background concentration is inhalable particulates, due to a relatively high monitoring background value of this pollutant. The concentration values of air pollutants at each sensitive point, even when added to background values, do not exceed the standard values.

The RIEPG (2008) assessment included modelling of potential odour using H2S as an indicator. The modelled peak (presumed at 100% ile) H2S levels used a 1 hour average. The emissions criterion in China for H2S is 0.01 mg/m3, or 10 ug/m3, and the plot shows excursions of approximately 500 m to the SEGX plant and approximately 300 m from the SW and NW site boundaries.


Use of an interaction matrix to identify the relationship between two quantities is a proven approach in identifying potential cumulative impacts (Hegmann et al, 1999; CEQ, 1997; Walker and Johnston, 1999). A matrix approach was used to indicate the likely relationships between the different activities and environmental and social values, using the colour and size of arrows to indicate the anticipated severity and frequency of the impacts as per Figure 9.

The frequency and severity of potential impacts were based on consideration of: (i) the nature of the activities and potential for causing harm; (ii) the likely regulatory and internal management controls (there are likely to be higher controls for an industry targeting best available technology and major industry and less so for smaller industry); (iii) the risk of environmental harm (there is likely to be better design, redundancy and management processes in place for major industry); and (iv) the likely frequency of harmful events.

In broad terms, a modern pulp and paper mill is considered to be a major industrial facility, but one with high levels of environmental management control and relatively benign waste streams and emissions. SEGX is proposing to implement better standards than those required under National Standards in terms of operating procedures and management systems. Emissions and discharges to the marine and air environments will be constant but of relatively low impact.

Other major industries will also have environmental management practices in place, but typically not to the same level as that governed by SEGX’s internal practices. The types of industries including polypropylene production, crude oil storage, coal fired power stations and stainless steel production have air and water emissions. These emissions will be constant and of potentially moderate to high impact.

Other smaller industries will be less likely to have environmental management practices in place or will be less likely to be as closely regulated. These industries could involve hazardous products and emissions, and have a lower likelihood of monitoring and management controls for any releases to the environment. Emissions to air and water will be of lower volume but could have high impacts.

Agricultural activity is likely to have minimal environmental management practices in place and is expected to be poorly regulated. In particular Agricultural practices could involve the use of hazardous material (pesticides, herbicides etc.) which may be poorly managed. Emissions to air and water are likely to be of low volume but could occasionally have high localised impact.

Urban development will generally have lower impact relative to these other activities; however issues such as wastewater discharge have the potential to be of constant and high volume with a moderate level of regulation and environmental management. Emissions to air will be from multiple sources, each low in volume but could cumulatively be significant. Emissions to water will include stormwater and treated wastewater discharge, the latter which will be constant and could be of moderate impact. Stormwater discharges will be irregular but could contain peaks of pollution as well as significant amounts of general litter.

The arrows represent potential pathways between activities and environmental values, i.e. the potential impacts. Green indicates a low severity impact, orange indicates a moderate severity impact and red indicates a high severity impact; note this ranking is relative rather than empirical. In addition, the greater the width of the arrow, the higher the frequency with which that impact occurs. Note this is not necessarily the same as the likelihood of the impact occurring, although it stands to reason that the more often an activity is carried out, the greater the probability of an impact occurring if no control measures are put in place.

Some environmental values may be impacted severely but infrequently, while others may be impacted more regularly but to a lesser degree.

» Participate in the coordination mitigation programs.

A complete cumulative impact assessment was not within the scope of this study. Specific information about other industries in the TIDZ, operating or planned, has not been possible to obtain and key reports on strategic environmental assessment for the TIDZ were not accessible in the public domain. Whilst it is not possible to quantify these impacts as part of this assessment, it is possible to identify some of these potential cumulative impacts in order to guide future mitigation and monitoring programs.

In order to provide a qualitative assessment of potential cumulative impacts, an approach broadly based on an internationally recognised 11-step process (Council of Environmental Quality, 1997) has been adopted here in modified form in order to allow a high level identification of cumulative impact risk. The full assessment, which may be considered for a future study commissioned collectively by industries in the Tieshangang Industrial Zone, could include the following steps: (i) scoping to identify the environmental values of each affected area; (ii) identify relevant activities (both SEGX and external); (iii) select indicators for each environmental value, e.g. turbidity could be an indicator for water quality; (iv) define the carrying capacity for each indicator in terms of space and time; (v) agree the limits of acceptable change; (vi) use or extrapolate historical baseline information to define a reference condition for each site; (vii) characterise the cause-effect relationships between activities and indicators; (viii) determine the magnitude and significance of cumulative impacts; (ix) propose mitigation measures; (x) monitor impacts; and (xi) enable adaptive management as required.

For the purpose of this assessment, key environmental and social values have been identified, along with activities which may result in impacts. This information is based on existing studies but could be further developed to integrate and direct future monitoring and management plans. As such, the environmental and social values surrounding the Tieshangang Industrial Zone include: (i) Shankou National Mangrove reserve; (ii) Hepu National Dugong reserve; and (iii) Clean Water: The Beihai region is known for its clean water and Class 1 and 2 Water Quality Objective areas are in proximity to the proposed outfalls; (iii) Clean Air: The Beihai region is known for its clean air quality in China. With limited major industry, the region presently has low levels of airborne pollutants; (iv) Fisheries: The Beihai region is a major commercial fishing area; (v) Tourism: Beihai and Guangxi are known as local tourism destinations with clean air and water; and (vi) Amenity: The locality has predominantly rural/coastal characteristics.

Potential activities which may impact on the above environmental values include industrial, agricultural and urban activities. Based on the information by RIEPG (2008) and other sources, existing and future impact sources identified are summarised in Table 17.

Table 18 Sources of Existing and Future Cumulative Impacts

Sector Source of Existing and Future Cumulative Impact

Industrial

» Tie Shangang Port

» Integrated Pulp Mill and board and paper facility: Stora Enso

» 200,000 tpa polypropylene plant and a 3.2 million cubic metre (20 million barrel)

commercial crude oil storage base: Sinopec

» Integrated stainless steel plant: Chengde Stainless Steel Co. Ltd.

» Power Plant: SDIC Beibuwan Electrical Power Co. Ltd

» Paper and Sugar: Guangxi Huajing Paper group Co. Ltd Beihai Sugar Making Brand

Company

» Alcohol Plant: Beihai Tieshan Port Longteng Alcohol factory

» Pottery Factory: State owned Chijiang Huaqiao pottery factory

Domestic sources» Existing and proposed residential development

» Wastewater treatment plants

Agriculture» Grazing

» Aquaculture


5. Mitigation Management PlanThe objectives of Mitigation Management Plans (MMPs) in relation to eliminating or reducing impacts should include:

» Avoidance – aspects of projects or activities that could cause adverse impacts. These are most effective when considered at the earlier stages of a project.

» Prevention – measures that prevent the occurrence of negative impacts;

» Preservation – prevention of actions that may negatively impact on a resource or attribute;

» Minimisation – limiting or reducing the degree of an impact;

» Rehabilitation – repairing or enhancing affected resources;

» Restoration – restoring an affected resource to how it was prior to the impact; and

» Compensation – create or enhance a resource to compensate for what is lost.

5.1 Forestry OperationsSEGX has developed sustainability requirements for operational level site planning for forestry operations as detailed in the IOSP Handbook. This Handbook requires site planning staff to carry out site inspections, collect relevant information and to develop the site operational plans according to the sustainability requirements. Proper mitigation measures are to be developed and implemented with purposes of mitigating adverse environmental and social impacts. The sustainability requirements include:

Buffer zones: details of buffer zones and management rules for specific land uses, including waterways and agricultural and degraded land.

Slope: includes management adapted to steepness of slope with suitable planting and harvesting methods and retention of existing vegetation (forestry activity excluded) in areas with slope steeper than > 35 degrees.

Topographical situation: retention of existing vegetation in defined areas.

Native species: retention of important stands in operations areas.

Burning: sets limits on burning, excludes from buffer areas (burning is already not allowed under SEGX IOSP, unless approved by Regional Manager and then only on special occasions).

Soil conditions: retention of vegetation within certain areas, no disturbing of heavily eroded areas other than for rehabilitation.

Cultural features: avoid disturbing cultural places, including graves.

Chemical and fertilizer use: defines application exclusion distances to vegetation buffers, waterways and restricts use on windy or rainy days.

Road building and maintenance: must consider water and soil protection. When decommissioning roads restoration is made with vegetation to minimize erosion risk.

Social aspects: communications with local communities.

Collection of baseline data to inform decision making is a key component of the IOSP Handbook.

5.1.1 Biodiversity

SEGX has incorporated a range of practices to mitigate impacts on the natural environment, including: (i) avoiding conversion of natural or protected forest to plantations; (ii) locating plantation at least 1 km away from nature reserves; (iii) ensuring that 20% of plantations are non-Eucalyptus species; (iv) maintaining buffer zone around watersheds, gullies, narrow valleys and specific low and wet lands and other land uses; (v) reserving natural or existing vegetation on ridge areas with steep slopes (>25-35 degree) or around waters; (vi) providing a wildlife protection guide to all workers to improve awareness of biodiversity issues; (vii) implementation of fire management systems; and (viii) avoiding traditional slash and burning practices.

SEGX has developed a Land Use Plan (LUP) for land acquisitions as well as forestry operations. The LUP establishes the criteria

Figure 10 Cumulative Impacts Matrix

Based on this assessment, the environmental values most likely to experience a greater cumulative impact associated with the development of the Tieshangang Industrial Zone will be water quality and to a lesser extent air quality and habitat preservation.

Regulation and monitoring with therefore play a key role in identifying, controlling and managing potential impacts. Integration of a monitoring program with other industries will be important in protecting these values.


Transport risk Mitigation and Management Strategy

Noise

» Trucks should be regularly maintained and checked to ensure that they are not responsible

for excessive noise;

» Adequate spacing of truck movements should assist with keeping noise levels to a practical

minimum, especially in village areas; and

» Community consultation will be encouraged to ensure locals can contact SEGX if noise or

other problems arise. SEGX has established a hotline for this purpose and advertises its

services to the local communities.

5.1.4 Fire

A strong community engagement culture is essential to fire control measures. Management measures should take into account the need for community and stakeholder cooperation (UNDP, 2006). Community cooperation is also a significant concern when fires occur in the existing plantations. In order to strengthen forest fire prevention, the forestry institutions of all cities, towns, forestry farms and branch farms are equipped with a wireless paging system such as an interphone (CRAES, 2008).

Effective weed control is a significant consideration with regards to fire management in the Guangxi area. Control of weeds helps to minimise the risk of fire, especially as many of SE’s plantations are adjacent to other farm land use such as crops. Active fire prevention measures at present include the establishment of fire breaks around and between the eucalypt plantations and neighbouring croplands. In addition to weed control, SE has identified the control of leaf litter and undergrowth within plantations as a major fire prevention measure.

SEGX has implemented a range of Fire Management procedures for the forestry plantations including: (i) prohibiting burning as part of site preparation; (ii) establishing fire breaks and strategic alignment of roads to also act as firebreaks; (iii) weed management and undergrowth control, (iv) Fire Protection and Response Strategy; (v) Fire Communication Program (including community engagement); (vi) suppression equipment and trained staff available; and (vii) established a fire prevention team and develop a detailed responsibility system according to the relevant laws and regulations.

5.2 Industrial FacilityAs detailed in Section 2.4 and 2.5, design features representing best available technology (BAT, IPPC 2001) have been incorporated into the SEGX mill to avoid or mitigate potential negative impacts on the environment. No detailed management plans have yet been presented by SEGX for the mill construction or operations pending decision for the investment. As part of the construction and operation of a major industrial facility, SE must ensure that a range of management plans and systems are put in place by SEGX. These would typically include the measures set out in Table 20.

Table 20 Construction Phase Environmental Management Plans and Systems

Management Tool Aspects

Construction Environmental Management Plan

» Noise

» Dust

» Air Quality

» Traffic and Transport

» Water Quality

» Hazardous Goods

» Waste Management

Hazard Management Plan » Based on a hazard identification and risk assessment

Environmental Management System based on

ISO 14001, including Environmental monitoring

program

» Outlining responsibilities, monitoring requirements and

frequency and response actions

which define sustainable fibre base in state and social lands respectively.

SEGX has also recently implemented a biodiversity monitoring program (FFI, 2010). The program is planned to run for 7 years. The first report presented the following recommendations to mitigate negative impacts on biodiversity in the Eucalyptus plantations: (i) decrease the size of single block of Eucalyptus plantations and diversify the planting timing, plantation pattern and Eucalyptus clones in the same area; (ii) mitigate the damage on the understory of eucalyptus plantations, especially burning, or if conditions permitted, never burning before planting; and (iii) the secondary forest fragments in Eucalyptus plantations (even if only small areas) are helpful to conserve local biodiversity, providing a shield, migration and dispersal effect. Preserving these secondary forests is more important than establishing buffer zone around the Eucalyptus plantations.

5.1.2 Soil erosion, surface water and groundwater protection

SEGX has recently implemented a soil, surface water and groundwater monitoring program as part of its impact mitigation practices. Initial recommendations for improvement of practices coming from the monitoring include: (i) mechanical planting should be established along contours; (ii) vegetation in open spaces should be maintained to reduce runoff and soil and water loss; and (iii) soil from newly constructed roads that is loosely placed on the surface or on sloped areas is easily eroded by wind and water. Slope protection, surface stabilization and improved maintenance of gutter flow was proposed.

SEGX has committed to implementing the recommendations of the initial phase of monitoring. The monitoring program will continue over the course of one full plantation rotation (approximately 7 years) and more monitoring recommendations to improve impact mitigation are expected to be identified and implemented.

5.1.3 Transport

SEGX is proposing a number of mitigation and management strategies to address the potential issues and risks with transport, as summarised in Table 18.

Table 19 Proposed transport risk mitigation and management strategies

Transport risk Mitigation and Management Strategy

Safety

» Roads are to be repaired immediately if damage has made an area unsafe. Small trucks are to

be used on certain roads to transport logs to depot sites to prevent damage and congestion

by larger vehicles. The larger trucks will then transport the logs from the depot sites to the

mill;

» Wear and tear of local roads will need to be monitored and community members should

be encouraged to notify SEGX if significant degradation occurs or if they consider there is a

safety risk;

» All contractors are to go through appropriate training to ensure they have an understanding

of SEGX’s policies regarding safe road use and speed limit adherence. Accordingly, drivers

may need periodic reviews to ensure they are complying with the rules/standards.

Community members should also be encouraged to notify SEGX if any trucks are not

operating in a responsible manner;

» Long distance transport from the depots with the larger trucks (including semi trailers) to the

mills must be coordinated from a local truck dispatcher via GPS to ensure that trucks are on

time and not causing congestion. This may also assist with driver safety, prevent theft and

discourage drivers from speeding; and

» Trucks are to be weighed upon entering the mill site to ensure they are not overloaded and

contractors made aware of the safety consequences of overloading the vehicles and the

requirement to not overload..

Dust » Roads must be watered down as required to prevent dust becoming a problem, especially in

drier months.


6. Social and Environmental Monitoring PlanSEGX has developed, and is currently implementing, various social and environmental monitoring plans, particularly with respect to its forestry operations. This section provides a summary of these monitoring plans and outlines a framework for additional plans to be developed.

General over-arching principles of the framework for social and environmental monitoring plans include: (i) social and environmental monitoring plans should include performance indicators which can be reviewed to indicate whether the performance objective has been achieved; (ii) monitoring must occur on a regular basis as a means of establishing whether performance targets have been met; and (iii) monitoring results should be collated, interpreted and reported as part of an annual report.

It is recommended that a social and environmental monitoring program for the forestry and mill project be prepared, including several related plans incorporating the following elements:

» Groundwater and surface water quality

» Erosion prevention and sediment control

» Terrestrial flora and fauna

» Transport

» Air quality, including dust and emissions

» Marine water quality

» Marine flora and fauna (not included as part of this report)

» Social, land and marine use and economics

A long-term monitoring program is needed to support continuous improvement in forest management practices in Guangxi. The monitoring program is also is expected to enhance local stakeholders’ understanding of the potential impacts on biodiversity as well as the effect of existing forest management practices on soil and water. Relevant experience and lessons-learned can be extended to other practitioners and policy makers for sustainable development of the industry and biodiversity conservation in Guangxi.

6.1 Groundwater and surface water SEGX’s current monitoring program includes groundwater and soil monitoring, undertaken by the Forestry Academy of Guangxi University. The monitoring is confined to the forestry plantations and does not include the mill site. The key indicators are summarised in table 21 below..

Surface water analysis and evaluation was based on environmental quality standards for surface water GB3838-2002, water quality standard for drinking water sources CJ3020-93 and standard for irrigation water quality GB5084-92.

Ground water analysis and evaluation was based on environmental quality standards for underground water GB/T 14848-93.

Table 21 Groundwater and surface water indicators

Indicator Monitoring Frequency

Groundwater quality

» Physical properties

» Chemical properties

» Pesticide and herbicide concentrations

» Biannual, wet season and dry

season each year

Surface water

» Physical properties

» Chemical properties

» Pesticide and herbicide concentrations

» Biannual, wet season and dry

season each year

It is suggested that this monitoring plan be strengthened, including establishing clear performance objectives and indicators.

5.3 Social Impact Mitigation and ManagementAs detailed in Section 3.3 and 4.2, the project must consider the social and socio-economic setting of the area because of its potential to cause social impacts. Social impact mitigation measures and management improvements have been outlined in several past studies. SEGX should actively seek to improve its performance with regard to impacts on social economic conditions. Some measures implemented by SEGX include:

» Consultation: Consultation with the local villages within the project area, including (i) a stakeholder communication newsletter that informs the community on SEGX activities and provides information on the forestry operations, etc. The newsletter has been updated every 2 months since the beginning of 2010 and distributed in the communities and to state forest farms and government agencies with an interest in SE plantation operations; (ii) frequent face-to-face meetings with the local community to improve communication; (iii) implementation of a grievance redress mechanism through a complaints local telephone hotline; and (iv) a biodiversity photo exhibition to increase community awareness of biodiversity values.

As a result of peer review of this summary ESIA report, the following recommendations for improvement to the SEGX consultation programs are made in response to the peer reviewer comments. The consultation programs should be further institutionalised and extended, as they provide important opportunity for engagement with local stakeholders. Extension of current programs might include:

– Regular stakeholder meetings (monthly or quarterly);

– Broadcast information via public loudspeaker; this is a preferred means of information dissemination in many communities in Southern PRC;

– Post information on black-boards in village offices; and

– Disseminate information via leaflets to each household, presenting information in a simple, easy to understand, form.

» Improved training and employment opportunities: SEGX seeks to employ locally based staff and offers training opportunities. Some locally based field workers have been employed through contractors and others (as field fire fighters and patrollers) have been engaged by SEGX. Relevant training has been provided in accordance with SE policies.

» Community development support: Since 2004 SE has given support to the surrounding community development activities. The local community has, or may, benefit from community development support in the form of infrastructure construction, donation to local schools, health and sanitation support and support to cultural events and facilities and community cooperation. To the end of Sept 2011 the company’s Community Development Fund allocated funds to 142 community development projects.

» Support to students: In 2010, SEGX started to provide subsistence contribution to 24 school students from households of recovered leprous families and additionally 60 students in poor economic circumstance in the rural area of Hepu county through cooperation with Beihai Citizen Volunteer Association; a local NGO dedicated to rural education improvement, caring for the elderly, HIV/AIDS care and environment conservation.

» Better understanding community socio-economic needs: A socio-economic survey of the project area has been commissioned by SEGX, to be completed in 2011/2012. This will provide baseline data for future socio-economic impact monitoring and to better understand the communities socio-economic development needs within the project area.

» Rural development support: SEGX is looking to support sustainable development within local communities. These programs will be developed in cooperation with the Business School of Guangxi University through establishment of pilot projects show-casing innovative community development programs. It has initially been proposed that 4 local villages would be selected for the pilot programs.

5.3.1 Land leasing

As a result of peer review of this summary ESIA report, the following recommendations for improvement to SEGX land leasing are made in response to the peer reviewer comments. The land leasing process in China is complex and in practice many of the leaseholders may not fully understand the contract conditions, especially when the village cadres or other stakeholders manage the land leasing process. In response to the issues raised concerning the leasing of social land, it is recommended that SEGX consider:

» Diversification of land use within SEGX plantations allowing farming of cash crops.

» Flexibility of SEGX’s requirement for ownership of land leasing rights to secure the fibre supply, allowing social land to remain under village control but still provide the required fibre base to SEGX.

» Provision of contract review service support for local villages to assist them to understand the leasehold contract terms and conditions.


6.4 Transport Monitoring PlanThe following monitoring strategies are recommended in regards to logistics and transport:

» Regular monitoring should be conducted by SEGX to ensure compliance with its values and regulations. Drivers should be monitored by their supervisors, with anonymous reviews or surveys conducted regularly to ensure drivers are driving safely and according to speed limits;

» Weigh bridges to be used to ensure trucks are not overloaded and to prevent both accidents and unnecessary wear on vehicles;

» Drivers must be aware of their responsibility to record incidents, so that the number of incidents can be monitored and safety measures implemented where required;

» All trucks should be regularly serviced and vehicle checks conducted by each staff member at the start of their shift before they take responsibility for their vehicle for the day;

» Monthly inspections should be conducted by survey crews to determine the condition of the forest roads and the levels of dust lift-off and road degradation. It may also be necessary to install dust stations in order to identify peak periods of dust formation. Likewise, regular reviews of noise levels in local villages should be conducted to identify peak noise times and how this impacts the local communities; and

» The communities can be empowered to report unacceptable transport activities to SEGX. Trucks could be numbered to facilitate identification of individual drivers. In addition the community could also be encouraged to report commendable or courteous drivers.

6.5 Air Quality Monitoring Plan

6.5.1 Baseline Ambient Air Quality Monitoring Program

Baseline ambient air quality monitoring in the Beihai region was restricted to seasonal campaign monitoring over a period of two weeks in 2007 at the mill site, supplemented by similar campaign monitoring conducted in 2005 for the Beihai Power Station and for the Tieshan Oil Refinery. A 2010 monitoring round was also completed. The Class 1 constituents of SO2, NO2, PM10 and TSP were monitored, as well as H2S and odour.

While the monitoring campaigns were timed to capture typical diurnal variations and the seasonal range in air quality, the datasets are still inadequate to fully characterise the variations in the measured parameters that could be expected to occur on site.

RIEPG (2008) indicates that a typical baseline ambient air quality monitoring programme that could be expected to be put in place for a project of this size would entail the installation of a minimum of one Air Quality Monitoring Station (AQMS). This would be fitted with:

» A logging anemometer to measure wind speed V, wind direction θ, standard deviation of θ, ambient temperature at 10 m and 1.5 m height and a net radiation sensor;

» Gas analysers to measure SO2, NO2 and TRS; and

» Particulate sensors for PM10 (and perhaps PM2.5) capable of reading and logging near real-time data (TEOMs or BAMs).

Whilst such a station is not inexpensive, it will provide invaluable data on background ambient air quality so that this and other future industry developments can have a firm basis on which to determine compliance to the air shed air quality objectives. Gas analysers have a non-detect value of approximately 1 ppb for these gases and the particulate sensors have a typical non-detect threshold of approximately 5 μg/m3 The anemometer wind speed sensor should be capable of wind speed measurements down to 0.2 m/s, with wind direction to the same threshold. Thresholds of this order will allow plume trajectories to be determined during light wind events when off-site impact (at least for near ground level sources) is enhanced.

The AQMS should be installed and operating in time to obtain a clear 12 month dataset prior to the commencement of mill operations and be available as: (i) unvalidated data on a website; and (ii) quarterly reporting of validated data as time – series and tabled giving the numbers of exceedences of the relevant air quality criterion on the same website.

The AQMS should also be deployed past the construction phase, given that there appears to be no AQMS at present in the Tieshangang or Beihai areas.

A performance indicator for surface water might be to limit the discharge of contaminated surface-water to the surrounding environment; with an associated performance indicator such as; surface water monitoring indicates no significant impacts to surface water. Significant impacts may then be specified with an understanding of baseline conditions and ecosystem services to be protected.

6.2 Erosion prevention and sediment controlSEGX’s current monitoring program includes soil erosion and soil quality monitoring undertaken by the Forestry Academy of Guangxi University. The monitoring is confined to the forestry plantations and does not include the mill site. The key indicators are summarised in the following table.

Table 22 Soil erosion and quality indicators

Indicator Monitoring Frequency

Soil erosion

» Water content

» Sediment weight

» N, P and K concentration of solid and

water

» Continuous monitoring

Soil quality» Physical and chemical properties

» Pesticide and herbicide residues » Two times in one year

Plantation biomass and carbon

sequestration

» Physical and chemical properties

» Pesticide and herbicide residues » Two times in one year

This soil erosion monitoring program is focused on the forestry plantation. An erosion and sediment control plan should be developed for the construction phase of mill project, which should address:

» Safeguarding of topsoil by stripping and stockpiling prior to construction.

» In areas where no permanent structures are to be installed, 10-15 cm of topsoil will be placed on the surface to promote vegetation growth.

» Supplementary seeding with native grasses/pastures (as appropriate) may be utilised in areas of particularly high risk of erosion e.g. steep slopes.

» As far as practicable, land will be progressively disturbed during construction to ensure minimum exposure of the disturbed land to the influence of weather conditions (e.g. rainfall and wind).

» Erosion control structures design, such as diversion banks and berms to limit topsoil movement, are provided as necessary.

» Topsoil stockpile design to prevent excessive loss by wind and water erosion.

» Ensuring that erosion and sediment control measures are constructed in high risk areas.

» Installation of pre-construction drainage where necessary. Design drainage outfalls to divert flow and control runoff and to ensure adequate scour protection. This may include utilising riprap (rocks held with wire mesh), revegetation and/or geotextile materials.

6.3 Terrestrial flora and fauna The biodiversity monitoring program (see Section 4.4.1) will be undertaken in three stages: (i) baseline survey in 2010; (ii) regular monitoring and awareness building in 2011-2015; and (iii) reporting and review of SEGX’s existing management strategy in 2016 in the light of the monitoring results.

The key indicators for the biodiversity baseline survey 2010 included bird species diversity and bird species population density. The biodiversity monitoring program used data from the Nonggang National Nature Reserve as a bench mark for comparison.


6.6 Marine Water QualityAs with the ambient air quality assessment to date, the background marine water quality assessment is insufficient to provide SEGX with a sufficiently rigorous and long term dataset to assist in the design of the marine outfall. The following is recommended to assist SEGX in developing an appropriate ambient marine water quality programme.

6.6.1 Site Selection

The selection of the monitoring sites so that the data collected gives a good representation of the characteristics of the area is critical. The sites should: (i) be representative of the area; (ii) consider the impact of adjacent industries and water based activities; (iii) be located in and out of the planned mixing zone; (iv) include a control or reference site; (v) consider available pre-disturbance data: and (vi) be accessible in most weather conditions.

6.6.2 Monitoring and Frequency When conducting the monitoring program three periods should be considered; pre-construction, construction and operation. Analytes and parameters monitored should address the specificities of each phase. The sampling points selected need to consider tides, currents and winds and depth profiles should be undertaken for pH, salinity, turbidity and temperature.

At this stage the data available is limited to 3 events. Additional background monitoring will be required to improve the reliability of the calculated ambient conditions. In addition, information on the strategy used to identify background conditions and derive ambient and local trigger values needs to be provided.

Trigger values are conservative assessment levels rather than pass/fail compliance criteria. If a trigger value is exceeded there may be a risk of negative impact to environmental values of the ecosystem. This may ‘trigger’ either immediate action to address the likely causes of the value not being met or further investigation to determine whether the trigger value is too conservative for local conditions or the local conditions influence the ambient levels and toxicity of the contaminant of concern. Local conditions vary naturally between waterways and it is necessary to tailor trigger values to local conditions. As more data becomes available through additional monitoring, the reliability of these values will increase.

A critical aspect is that the background data collected should cover all potential seasonal variations. This is one of the reasons why the ANZECC & ARMCANZ guidelines (2000) recommend that:

“A minimum of two years of contiguous monthly data at the reference site is required before a valid trigger value can be established. “ (Volume 1, Section 7.4.4.1).

In the case of the Tieshan Port marine environment and the mill discharge outfall, it is recommended that this monitoring frequency be increased to a sampling event every 2 weeks for the first year and then reduced to a monthly sampling event for the second year unless more sampling is required to obtain reliable ambient measurements. This will generally enable the collection of sufficient data to establish ambient background conditions, and is in line with similar ambient monitoring programs for new kraft pulp mills.

6.6.3 Analytes and Parameters

The parameters selected should be representative of the discharge inherent to the different phases. The water discharged from the site during the construction phase will not present the same characteristics as the wastewater discharged during operations and these differences should be taken into consideration when setting up the monitoring program for the project . Parameters and frequency of monitoring for an ambient monitoring programme to develop a baseline data set are provided in Table 25.

6.5.2 Dust Monitoring Program

In response to the proposed dust monitoring for the construction phase, it is recommended that a Dust Management Plan (DMP) also be developed and implemented, that will outline mitigation measures when pre-determined dust trigger levels are exceeded. A continually operated TSP real time monitoring program is recommended during the construction phase. The criterion value should be used as a trigger for implementation of mitigation measures. The instrument could also be retained for the operational phase and be an essential part of an operational DMP.

It is recommended that ambient monitoring be continued into the operational phase using gas analysers and real-time dust sensors.

6.5.3 Emissions Source and Ambient Air Monitoring

In terms of emission source monitoring, the three boiler stacks should each be monitored in near-real time for products of combustion, namely NO, NO2, SO2 and PM, as well as for H2S (Alkali Recovery stack only), as described in the mill project study document. This will allow the mill operators to monitor the on-going performance of the main boilers.

Based on the comments above, a suggested schedule for Point Source monitoring during plant operations and for ambient air quality monitoring before and during construction and thereafter in operation is given in tables 23 and 24 below.

Table 23 Limits and Recommended Sampling Schedule for Point Source Air Emissions

Emission Source Pollutant Units Testing Frequency

Recovery Boiler

PM mg/NDm3 Monthly initially then less frequently depending on results *

TRS mg H2S/NDm3 Continuous

NOx mg NO2/NDm3 Continuous

SO2 mg S/NDm3 Continuous

Lime Kiln




Power Boiler


NOx

mg NO2/MJ fuel input Continuous

mg NO2/NDm3 Continuous


Notes: *Particulate material is measured indirectly through opacity measurement continuously in-stack. Compliance monitoring and calibration to be made

manually at regular intervals of particulate material.

Table 24 Ambient Air Quality Monitoring Schedule

Parameter Frequency of Sampling Averaging Time Allowed

Exceedance Source

SO2 (Sulphur dioxide) Continuous 500 mg/Nm3 1 hr (moving av) None BG 3095-1996

Total Reduced Sulphides (TRS) Continuous 10 mg/Nm3 3 min (moving av) None TJ 36-79

NO2 Nitrogen Dioxide Continuous 240 mg/Nm3 1 hr (moving av) None BG 3095

PM10

Particulate Matter <10 mmContinuous 150 mg/Nm3 24 hr None BG 3095

Odour 3 monthly 20 odour units - none GB 14554-93


6.7 Social, land use and economics monitoring

SEGX has identified the importance of community involvement in the monitoring of community, social and economic impacts as a basis for improving its CSR. This is displayed in (i) a social economic monitoring program that will be implemented in 10 administrative villages in the plantation project area to monitor changes in livelihood of local people. A social-economic baseline survey program recently commenced including 74 townships within the project area; (ii) information hotline is established as a community redress mechanism to receive and collect complaints and information which will be regularly analysed; and (iii) ongoing regular dialogue with community members.

However, the peer review of this summary ESIA report noted that social survey information can be influenced by the opinions of village leaders if it is not undertaken effectively. It is recommended that social surveys include an element of random sampling. For example, the interviewees may be selected at random from a list of all village members. This provides greater certainty around the representativeness and accuracy of the survey data. In addition, the peer review noted that the contract review implemented by SEGX focuses on the legal process and does not include review of the farmer’s level of understanding of the contract conditions. It is recommended that the review process be extended to include direct communication with, and engagement of, the local leaseholders to confirm their level of understanding of, and agreement to, the land lease contracts.

SEGX has made active steps to improve land leasing procedures, including the development and implementation of a land leasing legal process review checklist for all land lease contracts. The checklist has been used to review and monitor the appropriateness of land leasing contracts in the forestry plantation and is understood to be going to be used to monitor any future land lease contracts.

An independent social-economic follow up survey was commissioned to Guangxi Academy of Social Science for a period of 3 years starting in 2009. The purpose has been to follow up on the livelihood of the people relocated from the mill site aiming to create a knowledge base of the situation and development needs of the relocated people to improve the company’s understanding of how to best engage with community members.

It is recommended that SEGX consider the establishment of a Community Reference Group to operate during the construction, commissioning and operation phases to better enable the preparation of a meaningful and realistic community consultation framework and to facilitate an ongoing interface with the community. The Community Reference Group would also enable mitigation or remediation measures to be considered and agreed with local representatives. The Community Reference Group should also include representatives of local business and industry to ensure that all community interests are represented.

Table 25 Proposed baseline Water Quality Monitoring, Ambient Pre-operation

Phase Analytes No. of Locations Monitoring frequency

Ambient Environmenta

Temperature, pH, salinity, DO Depth profile

Monthly

COD

Chlorate

Dioxins 2,3,7,8-TCDD and Furans 2,3,7,8-TCDF in sediment b

2-chlorosyringaldehyde

Trihalomethane including chloroform

Oil and grease (visual)

Samples collected 0.5 m below surface and 1 m from bottom


Other analytes that may be considered in the ambient water quality monitoring program include:

Inorganic nitrogen

Orthophosphate

Volatile phenols

Sulphide

Chlorinated phenols –Total

Heavy metals (if any)

Monthly

Notes: a) These sampling recommendations pertain only to the receiving environmental immediately outside the mixing zone. Sampling sites should be

selected as part of the design of the monitoring program in consultation with the relevant regulatory authorities and, in the case of this project, in

consultation with associated industries discharging in close proximity to the mill effluent diffuser.

b) Dioxins and furans may be monitored in sediment rather than water, as they accumulate in sediment over time and are unlikely to exist in

detectable concentrations in water. The monitoring frequency recommended for dioxins and furans is once yearly.

The Resource Planning and Development Commission, Tasmania, Australia (RPDC) guidelines provide a list of indicative core parameters and their recommended monitoring frequency in the discharge, as shown in Table 26 below.

Table 26 Indicative core parameters to be monitored in discharge (IFC (2007), IPPC (2001), RPDC (2004))

Parameter/analyte Monitoring frequency

Volume discharge DailyTemperature, pH, Salinity, Dissolved Oxygen, Colour DailyTSSa DailyBOD Three times weeklyCOD DailyAOX Weekly Oil and grease (visual) Daily

Dioxins 2,3,7,8-TCDD Variable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

Furans 2,3,7,8-TCDFVariable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

ChlorateVariable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

Trihalomethane including chloroformVariable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

Notes: a) Improved technology and best practice for BKPM has significantly reduced the amount of TSS discharged from a modern mill. While monitoring TSS in the effluent provides a measure of operational efficiency, there is little value in monitoring TSS outside the pre-determined mixing zone, particularly in marine waters. TSS from modern discharges is not expected to have unacceptable environmental impacts.


informed consent of landowners; (iii) conflict over land tenure/ownership; (iv) employment opportunities; (v) transportation impacts (noise, dust, road conditions); and (vi) protection of workers’ rights. Land agreement and rental systems require continual improvement and in 2009 SEGX commenced a revision of its land rental process to improve certainty of land tenure and to provide a greater level of transparency to the rental process. SEGX is implementing a dispute resolution action plan, including a dispute reporting and intervention procedure in the form of a hotline and grievance channel, and seeking to develop local community development pilot projects. Whilst SEGX has implemented a number of community communication mechanisms, these are not well known and utilised by the rural communities potentially affected by the forestry operations.

When the estate begins providing wood for the mill, SEGX will contract transport contractors directly and implement a greater level of control over this activity.

Recommendations to improve management of social impacts include: (i) continue to work with the Beihai government to encourage assessment of environmental and social issues when nominating lease land for SEGX consideration; (ii) continual improvement of the contract assessment process to minimise land disputes; (iii) continual improvement in the negotiation process to ensure consultation and agreement with leaseholders rather than administrators; (iv) greater communication of contract agreement, pricing framework, payment frequency and payment methods to leaseholders to minimise the potential for inappropriate or unauthorised payments; (v) greater monitoring of negotiations and payments, possibly through an auditing process; (vi) improved communication and communication tools as part of encouraging a long-term relationship with local communities; (vii) encouraging local communities to report incidents or issues as part of a performance monitoring network; and (viii) examine opportunities to increase local workforce participation in plantation work and other roles (dust suppression, security).

Whilst recognising that SEGX is somewhat constrained by circumstances relating to administrative mechanisms of the various government agencies and the processes required of a foreign company working in China, a collaborative approach to continuous improvement is critical to achieving positive project outcomes.

Potential environmental impacts associated with large-scale forestry operations: Potential environmental impacts identified include: (i) potential impacts on biodiversity due to lack of interconnection of biodiversity corridors, generally existing within buffer-zones around environmentally sensitive areas; (ii) potential impacts to water quality, most significantly from application of chemicals and increased sediment runoff; and (iii) potential impacts from increased transport of wood, primarily noise and dust generation and impacts to roads.

Further potential environmental impacts are identified and discussed within the report. In general, SEGX has developed suitable management, mitigation and monitoring plans to address these issues, including initiating a forestry biodiversity monitoring program.

7.2 SEGX Mill IntegrateThe mill site is located in the Tieshangang Industrial Zone, Beihai Prefecture, Guangxi, about 2 km from the coastline and about 40 km east from Beihai City, covering a total land area of 250 ha.

The SEGX mill will utilise the Kraft pulping process, which entails chemical treatment steps for converting wood into pulp fibres with high brightness and cleanliness. The mill design incorporates the principles of modern and efficient mills seeking to reduce energy, chemical consumption and to minimise effluent and air emission loads through the application of modern technology. Production systems are designed using modern clean technology to minimize emissions. Treatment systems are included in the mill design to eliminate some of the emissions and reduce the remainder to low levels. As with most Kraft pulp mills built since 2000, the emissions will be dramatically lower than levels associated with historical pulp mills. The design is in line with Chinese regulations, European guidelines and comparable international standards associated with new Eucalyptus pulp mills in other parts of the world.

Based on a comparison of the expected emissions for the pulp mill with those considered representative of best available technology (Table SC-1 through SC-3), the mill will meet, and in some cases go beyond, international guidelines used to define best available technology.

7. Summary and ConclusionsThe purpose of this report is to consolidate environmental and social studies undertaken for the project and to address

specific gaps in previous studies as outlined in the Terms of Reference.

It is clear that for any project of the scale of that proposed by SE will have environmental and social impacts. This report has reviewed a large number of technical assessments undertaken by SE and independent organisations in consolidating information on the project and potential impacts for the purposes of this report. The review scope did not include validation of any data and results of these studies and the contents of all reports have been taken as being accurate.

The two elements of the project, the Plantation Estate and the Industrial Facility, have distinct issues and impacts and have therefore been considered separately against international guidelines and industry Best Practice. Whilst SE has achieved approval from Chinese government regulators for the project, it has recognised that to meet the standards applied by the company worldwide and also meet the expectations from international stakeholders regarding company behaviour, a broader approach to governance, design and management is required.

7.1 Plantation EstateSEGX forestry operations in the Guangxi province started in 2002 with the target of establishing a 160,000 hectares land base and about 130,000 hectares plantation estate (based on Eucalyptus plantation) by the time the SEGX mill starts production. The total wood consumption for a 900,000 ADt/a pulp mill will be approximately 3.4 Mm3 of Eucalyptus wood. It is anticipated that all of the wood will eventually be supplied from SE’s own plantations.

As of August 2010, SEGX had contracted a total of 84,627 hectares of land, with an additional 41,258 hectares offered by city governments, giving SE access to a total of 125,885 hectares. The contracted plantation land exists as both connected and isolated parcels of forestry land, inter-mixed with other (non-SEGX) forestry plantation operations, villages, and other land uses. Forestry plantations have been a dominant land uses in southern Guangxi for many decades.

Plantation estate land currently contracted by SEGX is spread over 27 counties. Of the 125,885 hectares to be developed as plantations, 36,154 hectares (29%) is social land and 89,731 hectares (71%) is state land. The majority of the social land is located within Beihai and Yulin Counties. State lands are located within five prefecture level-cities: Beihai, Yulin, Nanning, Qinzhou and Chongzuo.

The development and operation of SEGXs’ plantation estate is likely to be associated with the following key social and environmental benefits:

» Increased employment and skills development: employment in SEGX plantations was about 4,400 persons in 2005 and was estimated to reach 12,400 to 14,400 full-time jobs once the plantation operations reached full scale.

» Potential to improve industry practice in forestry operations: SEGX brings significant forestry experience, advanced breeding and propagation techniques, planting and harvesting operational equipment and stand management plans that have been developed with consideration for international best practice and are well in advance of contemporary local practices in Guangxi. Some of these techniques include: (i) restrictions on site selection based on environmental sensitivity, including defined buffer zones around rivers (20 m and 50 m for major tributaries): (ii) use of mechanical planting and planting along contour lines, rather than ripped lines along the slope line which is common local practice; (iii) planting density of 1,250 stems per hectare, rather than the common practice of 2,222 per hectare; (iv) establishing plantations as clonal blocks to offer uniformity in management;; and (v) minimised and restricted use of fertilisers and herbicides, with no chemical application allowed within 50 m of a water course or pond. Working with the local government and alongside local forestry operations, SEGX has the potential to increase the awareness and management of potential environmental impacts associated with forestry plantation estates in southern Guangxi.

While SEGX has developed and continues to improve a framework of systems, policies and practice standards based on its corporate best practice and tailored to the Guangxi conditions to manage environmental and social impacts associated with plantation land management, some potential impacts have been identified including the following key potential impacts:

» Community engagement and land rental issues: Community surveys have highlighted concerns regarding land leasing agreements and forestry operations including: (i) fair and prompt payments/compensation; (ii) lack of free, prior and


» Potential impacts on water quality: Potential impacts on marine water quality could result from wastewater discharge from the plant via the ocean outfall, which will use a submerged multi-port diffuser. Past studies have concluded that, based on assessment of the baseline environment and hydrodynamic modelling of the marine discharge, the project would only have a minor impact on marine organisms and a slight impact on the environmental objectives of the adjacent marine reserves (RIEPG, 2008; TRIWTE, 2009). These studies have found that the discharge would not damage the stability of the marine ecosystem and would not impact on designated fishing areas. However, some deficiencies with respect to international best practice have been identified in the technical assessments (UNDP-Hatfield, 2008) and, as such, further modelling and assessment of potential impacts associated with the ocean outfall is recommended to be f developed.

» Potential impacts on air quality: Background air quality monitoring completed for the proposed SEGX mill site in 2007 and 2010 did not detect any pollutants above the standards for Class 1 pollutants (Ambient Air Quality Standard GB3095-1996), H2S or odour. While this background monitoring program was more limited (duration and seasonal coverage) than would normally be done under international best practice, it provides a baseline indication of Class 1 air quality at the mill site prior to facility development.

Based on the air quality modelling of emissions expected from the proposed mill operations, past reports have concluded that the maximum average concentration of SO2 and NO2 are expected to be within the applicable air quality standards, with the predicted maximum ground level concentration of pollutants SO2, NO2 and inhalable particulates significantly below the applicable evaluation standard RIEPG (2008). However, some deficiencies have been identified in modelling applied to air quality with regard to international best practice.

Cumulative Impacts: Existing and future activities within the Tieshangang Industrial Zone have the potential to contribute to cumulative environmental impacts, in particular impacts on water and air quality. The existing or proposed industries include a polypropylene facility, crude oil storage, coal fired power station and a stainless steel plant. All have the potentially to contribute to negative environmental impacts on water and air quality. This gives rise to two potential issues; (i) further work on water and air quality modelling is recommended to assist SEGX in any potential future disputes of pollutant impacts related to other neighbouring industries; and (ii) the potential cumulative impacts associated with these industries on the environment is an important consideration that has not yet been assessed in the reports reviewed as part of this assessment.

» Social Effects: The mill site development proposal has resulted in the resettlement of 1,236 villagers from the site to a new area approximately 2 km away. The resettlement, managed by Beihai City along with resettlement of villages from other areas of the Tieshangang Industrial Zone not related to SEGXs’ operations, included monetary compensation and an on-going allowance for each person affected in accordance with local government policy. Based on community surveys of the affected people, issues of inadequate compensation and lack of new employment opportunities have been identified. SEGX has implemented measures to monitor the process of compensation and provision of employment opportunities. However SEGX cannot directly supervise these processes as local government policy determines the extent of SEGX’s involvement. SEGX have maintained regular contact with the affected people and continue to communicate openly regarding their issues and potential solutions.

7.3 ConclusionsThe SEGX proposal is a major and complex project that will have a range of positive and negative impacts on the natural and social environment. SE is bringing a high level of corporate governance, systems and environmental management to the project, well in advance of contemporary local industries. These practices range from defining worker accommodation and labour rights to the implementation of industry best practice emissions control.

SEGX faces many challenges in implementing these practices, particularly working as a foreign company within the framework of land leasing, social compensation and managing cumulative impacts in accordance with local government policy and standard practice. SEGX is delivering the project in cooperation with the Guangxi government and that has required the implementation and continual improvement of various processes, particularly in relation to lease acquisition with the Beihai city government.

Whilst having secured environmental approvals for the project from the Chinese regulators, additional work is required in the implementation and development of design, management systems and monitoring programs to meet recognised international standards and SE’s corporate policies. Continued effort is required to meet these goals.

With respect to IFC performance standard 1, the past and ongoing assessments address the key objectives of the standard. However some areas require ongoing improvement and would benefit from additional studies as detailed below.

Table SC-1: Effluent loadings per ton of pulp compared to IPPC and IFC guidelines for long term average

Parameter

SE Pulp Mill (standalone)a Env. Approvalb m3/ADt, kg/ADt

GB 3544-2008c Standalone Pulp mill m3/ADt, kg/ADt

IPPC-BATd (2001) Pulp mills m3/ADt, kg/ADt

IFC-EHS Pulp mills (2007) m3/ADt, kg/ADt

Flow 25 50 30 to 50 50

BOD5 0.5 1.0 0.3 to 1.5 1.0

COD 2.5 5 8 to 23 20

TSS 1.25 2.5 0.6 to 1.5 1.5

AOX 0.15 n.a. 0 to 0.25 0.25



Table SC-2: Emissions to air from recovery boiler and lime kiln compared to IPPC and IFC Guidelines for pulp production

ParameterSE Pulp Mill

Technical designa parameters, kg/Adt



kg/ADt


SO2 (as SO2) 0.7 1.8 0.4 to 0.8 0.8

NOx (as NO2) 2 - 1.0 to 1.5 1.5

TSPc 0.3 0.4 0.2 to 0.5 0.5

TRSd (as H2S) 0.06 0.06 0.1 to 0.2 0.2a) Technical design parameters for SO2 and TRS, the long term averages may be lower, see ref. b) Calculated from RIEPG 2008 Oct 2008, table 3.4-7 amendment, 900,000 ADt production, 354 operating d/a c) Total suspended particlesd) Total Reduced Sulphur Compounds

Table SC-3: Power Boilera Emissions Compared to IFC Guidelines for Thermal Power Plants




mg/Nm3


SO2 (as SO2) 200 319 900 to 1,500

NOx (as NO2) 300 300 510 to 1,100

TSPc 30 41 50

TRSd (as H2S) n.a. n.a. -a) Design data are preliminary only. Power Boiler is part of phase 2 and 3 scope, one operational unit added for each phaseb) RIEPG 2008, Table 3.4-6, amendedc) Total suspended particles

d) Total Reduced Sulphur Compounds

Past assessments have shown that mill operations have the potential to bring both positive and negative social and environmental issues to the region. Similar to the plantation estate operations, the mill operation is likely to create skilled work employment opportunities for local residents, along with other, non-direct, employment opportunities in related businesses including restaurants, hospitality, local shops and transportation. Using industry standards, total direct and indirect employment from mill, plantations and supporting industries at full scale will be in the order of 30,000 people. In addition, there is potential for skills development of local staff, technology information exchange and improvements in environmental management and monitoring for all industries within the Tieshangang Industrial Zone, particularly with regard to cumulative environmental impacts.

In addition, potential negative social and environmental impacts exist, with the key potential impacts identified being:


» Secondary forests have been shown to fragment Eucalyptus plantations, assist in the conservation of local biodiversity, and are considered more important than establishing buffer zones around Eucalyptus plantations. Preserving these secondary forests is recommended to be prioritised in SEGX operations.

» A long-term monitoring program is recommended to support continuous improvement in forest management practices. The monitoring program is also is expected to enhance local stakeholders’ understanding the potential impacts on biodiversity as well as the effect of existing forest management practices, soil and water. Future environmental monitoring as part of current forestry operations should include the following elements: (i) groundwater and surface water quality, (ii) erosion prevention and sediment control, and (iii) terrestrial flora and fauna in addition to current bird surveys. Relevant experience and lessons-learned could be extended to other practitioners and policy makers for improved sustainable development of the industry and biodiversity conservation in Guangxi.

» Improved management of social issues, including:

» Continue to work with the Beihai government to encourage assessment of environmental and social issues when nominating lease land for SEGX consideration. A collaborative approach to continuous improvement between SEGX, government and stakeholders is critical to achieving positive project outcomes.

» Continual improvement of the contract assessment process to minimise land disputes, including provision of contract review service support for local villages to assist them understand the leasehold contract terms and conditions. It is recommended that the review process extend to include current contracts and direct communication and engagement with the local leaseholders to confirm their level of understanding and agreement to the land lease contracts.

» Continual improvement in the negotiation process to ensure consultation and agreement with leaseholders rather than administrators, and greater monitoring of negotiations and payments, possibly through an auditing process.

» Improved communication and communication tools as part of encouraging a long-term relationship with local communities. The consultation programs should be further institutionalised and extended, as they provide important opportunity for engagement with local stakeholders. Extension of current programs might include: (i) regular stakeholder meetings (monthly or quarterly), (ii) broadcast information via public speaker, this is a preferred means of information dissemination in many communities in Southern PRC, (iii) post information on black-boards in village offices; and (iv) disseminate information via leaflets to each household, presenting information in a simple easy to understand form.

» Consideration for diversification of land use within SEGX plantations allowing farming of cash crops.

» Flexibility of SEGX’s requirement for ownership of land leasing rights to secure the fibre supply may be considered, allowing social land to remain under village control but still provide the required fibre base to SEGX.

» Examine opportunities to increase local workforce participation in plantation and other roles (dust suppression, security).

» With regard to the mill site, it is recommended that SEGX consider the establishment of a Community Reference Group particularly during the mill community during the construction, commissioning and operation phase, to enable meaningful and realistic community consultation framework to be prepared, and facilitate an ongoing interface with the community. The Community Reference Group would also enable mitigation or remediation measures to be explored and agreed with local representatives. It should be noted that the Community Reference Group should also include representatives of local business and industry.

» Building capacity for SEGX staff on working with the community and corporate social responsibility activities.

» Once SEGX has financially committed to the mill project, it is recommended that it undertake further activities which may include: (i) preferential employment opportunities at the mill for local people; (ii) training of local people to develop new skills including skills to access indirect related employment opportunities such as hospitality business opportunities; (iii) ongoing regular consultation; and (iv) community development opportunities such as education support, urban park land establishment and recreational area developments.

IFC performance standard objective Conclusion

Identify and assess social and environment

impacts, both adverse and beneficial, in the

project’s area of influence.

Past studies have adequately identified the potential social and environmental impacts

associated with the project. However, the assessment of these impacts is varied in detail

and in some cases is inconsistent with international standards expected for these types of

assessments as reported by UNDP-Hatfield (2008). SEGX has acted to address these gaps,

including commissioning: (i) a forestry biodiversity study (FFI 2011); (ii) additional ocean

water quality and pollution dispersion modelling study (TRIWTE, 2009, SCSIO 2010,); (iii)

additional air quality monitoring (BEMC, 2010); (iv) a detailed technical description of the

mill design (SE, 2010); and (v) this summary IESIA, along with development of an Integrated

Operational Site Planning (IOSP) handbook for forestry operations that includes a site-

specific screening checklist (SEGX, 2010). Even so, gaps in detailed baseline monitoring

and cumulative impacts assessment remain.

Avoid or where avoidance is not possible,

minimize, mitigate or compensate for

adverse impacts on workers, affected

communities, and the environment.

SEGX has implemented mitigation measures in the design of its mill facility that are

expected to meet best available technology emission standards, developed an IOSP

handbook to manage potential impacts associated with its plantation estate and is

undertaking an ongoing improvement of its social engagement and land leasing

program to avoid or minimize adverse impacts on workers, affected communities and the

environment.

Ensure that affected communities are

appropriately engaged on issues that could

potentially affect them.

SEGX is working with the local government and with directly affected communities to

provide information on project activities, timelines and new developments. Free prior and

informed consent is required for all land lease contracts and SEGX continues to work with

the government and directly with the community to maintain broad community support

for the project. This work is supported by ongoing studies and programs such as the

recently commissioned social engagement study that includes social surveys; ongoing

socio-economic monitoring and proposed sustainable development village based pilot

projects. This is an area for diligent management and ongoing improvement.

Promote improved social and environment

performance of companies through the

effective use of management systems.

SEGX operates in accordance with SE global corporate social responsibility policy and

code of conduct. SEGX has a well-developed environmental management system and

is developing improved social systems. SEGX operations in Guangxi have the potential

to increase the awareness of social and environmental performance issues within local

government and enterprises by information exchange, leading by example and operating

to international standards of environmental and social management systems.

7.4 RecommendationsTo build on the understanding of potential environmental issues and appropriate mitigation measures associated with SEGX current and proposed operations, and promote diligent management and ongoing improvements in social performance, the following recommendations are presented for SEGX consideration.

» Improvement of environmental baseline data and assessment of potential impacts including:

» Further baseline assessment of marine water quality and ambient air quality are recommended. This baseline information will assist SEGX in developing monitoring plans, mitigation measures and will provide a baseline for any potential future disputes of pollutant impacts related to other neighbouring industries. More detail on monitoring program recommendations are provided detailed in Section 6.

» The potential cumulative impacts associated with industries with the Tieshangang Industrial Zone on the environment is an important consideration that has not yet been assessed. In this regard, ambient water and air quality monitoring programs would ideally be integrated with others facilities within the Industrial Zone to enable an efficient and coordinated program.

» With regard to forestry operations, decreasing the size of single block of Eucalyptus plantations along with diversifying the planting timing, plantation pattern and Eucalyptus clones in the same area should be considered.


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8. ReferencesADB, 2010, PRC: Guangxi Beibu Gulf Cities Development Project - Beihai City Zhulin Urban Road and Related Infrastructures Component, Resettlement Plan, Asian Development Bank, 2010

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http://english.nanning.gov.cn/n725531/n751804/n752421/n1556201/7855550.html

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| GHD | Stora Enso Guangxi Forest and Industrial Project – Summary IESIA84

Appendix AGHD

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© GHD 2012

This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited.

Document Status

Rev No. Author Reviewer Approved for IssueName Signature Name Signature Date

Draft (v.2) R LuptonL Glade-Wright

B Skarratt B Skarratt 24/12/2010

Draft (v.3) D Horn 29/7/2011Draft (v.6) D Horn 19/1/2012Final D.Todd

R LuptonL Glade-Wright

P Murphy D Horn 24/4/2012

Appendix AComplementary Assessment: Stakeholder Survey

Appendix A Complementary Assessment: Stakeholder Survey | 1| 2

Appendix A Complementary Assessment: Stakeholder Survey

Table of Contents1. Introduction 3

1.1 Purpose of the Report and Objectives 3

1.2 SEGX in China 3

1.3 Past Studies and Public Engagement 3

2. Complementary Stakeholder Survey Methodology 5

2.1 Interviews with Key Informants 5

2.2 Participatory Focus Group Discussion 5

2.3 Secondary Data Collection 5

3. Previous Studies 6

3.1 Summary of Social Assessments undertaken in 2006 and 2008 6

3.2 Summary of Social Research undertaken in 2009 7

4. Current Social Management Practices 10

4.1 SEGX Plantation Estate 10

4.2 Forestry Land Contracts 10

4.3 Mill Site Resettlement 13

5. Land Lease Complementary Survey 14

5.1 Leasing Process and Current Issues 14

6. Plantation Estate Social Impact 18

6.1 Communication Barriers 18

6.2 Contract Management 18

6.3 Forestry Work Force 18

7. Mill Site Social Impact 21

7.1 Compensation for Resettlement 21

7.2 Future Social Impact Management Strategies 24

8. Conclusion and Recommendations 26

8.1 Conclusions 26

9. References 28

AnnexesAnnex B: Program of the survey on social impact analysis in Beihai, Guangxi 29

Annex A: Basic information of interviewees of the focus group discussion in the new relocation

community of Nanle Village 30

Annex C: Checklist to the Villagers on Forestland Lease 31

Annex D: Questionnaire for the Immigrants after Resettlement 32

Annex E: Interview Outline for Village Leaders on Forestland Land lease and Plantation 35

Annex F: Interview Outline of the leader of Forestry Bureau of Beihai, Guangxi 37

Annex G: Interview Outline for Managers in the Community of Resettlement 38

Annex H: Checklist to Group Discussion for the Immigrants after Resettlement 39

Cover Photo taken by Jarmo Hietaranta


| Appendix A Complementary Assessment: Stakeholder Survey2 Appendix A Complementary Assessment: Stakeholder Survey | 3

1. Introduction1.1 Purpose of the Report and Objectives

Stora Enso Guangxi (SEGX) has proposed the development of a Kraft pulp, paper and board mill and associated forestry plantation estate (collectively the project) in southern Guangxi Zhuang Autonomous Region (Guangxi), People’s Republic of China (PRC). The proposed scope of the project includes a Kraft pulp mill with 900,000 air-dry tonne per annum (ADt/a)

capacity and a paper and board production mill with a capacity of 900,000 tonne per annum, supplied with a fibre based sourced from approximately 130,000 hectares of Eucalyptus plantation on a total land area of 160,000 hectares.

SEGXs’ plantation operations in Guangxi commenced in 2002, with the intent of establishing a sustainable fibre base for the proposed mill operations. As of August 2010, SEGX had contracted 84,600 hectares of land with an additional 41,200 hectares offered by city governments, totalling 125,800 hectares.

Social Impact Analysis (SIA) is an essential part of Stora Enso’s sustainability and risk management procedure. This SIA was conducted as a complementary study to the Summary Integrated Environment and Social Impact Analysis (Summary IESIA, GHD 2012). The objective of this SIA was to assess that the SEGX project has been carried out in a sustainable manner, and assess its impact on stakeholders, especially on rural community in the light of international environmental and social standards. The SIA seeks to demonstrate how SEGX is addressing social issues as part of the project, as well as the project management system and its social impact since 2006. This SIA includes a review of past social impact assessments completed in 2006 and 2008, and provides updated information as follows:

» Analysis of land lease program carried out by the Beihai Government, and SEGXs impact on affected communities;

» Analysis of the mill site resettlement program and the social package offered by local government for the people who have been resettled from the mill site; and

» Presents suggestions for SEGX on how to improve existing and future social management, including how to monitor the outcomes of the project.

1.2 SEGX in ChinaStora Enso is a global paper, packaging and wood products company producing newsprint and book paper, magazine paper, fine paper, consumer board, industrial packaging and wood products. The SE group has some 27,000 employees and 88 production facilities in more than 35 countries worldwide, and is a publicly traded company listed in Helsinki, Finland, and Stockholm, Sweden.

SE has been active in the Chinese market since the mid-1980s as a supplier of paper, board and pulp products. In 1998 the company bought out the majority share in the Suzhou fine paper mill, and in 2008 SE started production of super calendared paper in a joint venture with Shandong Huatai Paper. SE also owns two core board plants which are situated in Hangzhou and Foshan.

SEGX was established in 2002 as a foreign owned enterprise in Guangxi, with the mission to establish a sustainable fibre base to supply raw material to the proposed integrated pulp and paper mill. At the time of writing, SEGX was 100% owned by Stora Enso Pulp and Paper Asia AB, with a planned joint venture to be established with a state owned enterprise as appointed by Guangxi government. .

Since 2002, SEGX has been developing a Eucalyptus plantation base in the Guangxi. The company is currently seeking to expand its dealings in Guangxi, where it will use the existing forestry operations as a fibre source for the proposed Project.

Development of the forestry industry is currently receiving support from the Chinese government, both on a national and regional level. The proposed Project subscribes to all national industry policies, as well as independent international environmental and social standards.

1.3 Past Studies and Public EngagementThe nature of the project presents a complex and challenging set of potential and actual environmental and social effects, and as such many technical studies, assessments, public consultation programs, community engagement and support efforts have been undertaken by SEGX, independent consultants and others as part of the development of the project. Among these studies and reports are the (i) two EIA reports prepared as part of the MEP approvals process for the project detailed above (CRAES, 2008; RIEPG, 2008), (ii) an ESIA of the plantations conducted by UNDP China in 2006, which identified major challenges in the

Table IndexTable 1 Public Consultation and Participation for Social Analysis Study 6

Table 2 Total Forest Farm and Social Land Contracted and Offered 12

Table 3 Basic Information of the Five Villages in Zhakou 17

Table 4 Household Situation of the Participants in Group Discussion - Najiang Village 18

Table 5 Income Structure of Najiang Village 18

Table 6 Income Structure of Dongfeng Village in 2009 (RMB) 19

Table 7 The number of local workers working for SEGX 23

Table 8 Resettlement Compensation Use 25

Table 9 Income of farmer households before and after resettlement (2006 and 2009) 26

Table 10 Expenditures of affected people before and after resettlement in 2006 and 2009 26

Table 11 Positive impacts of the resettlement 27

Table 12 Negative impacts of the resettlement 27

Table 13 Farmer planning to restore production and living for the future 27

| Appendix A Complementary Assessment: Stakeholder Survey Appendix A Complementary Assessment: Stakeholder Survey | 4 5

2. Complementary Stakeholder Survey Methodology

In order to have a basic understanding of the social impact issues in the project area, a complementary social impact analysis survey was carried out by Dr Wang Dehai in August 2010 for key stakeholders. This survey involved discussions with key agencies, local communities, and the collection of a range of secondary statistical data for the project area. A combination of

different approaches and methods was used, which included key informant interviews, participatory focus group discussions, and the collection and analysis of secondary data.

2.1 Interviews with Key InformantsThe key interviews included rural village leaders, provincial and county functional agencies, enterprise managers and business people. Interview guidelines were prepared and an emphasis was placed on:

(a) Inclusion of the agencies concerned with addressing project management issues; and

(b) Inclusion of the agencies or businesses that were likely to be directly affected by the implementation of the project.

2.2 Participatory Focus Group DiscussionRapid appraisal activities were conducted among different stakeholders in order to assess the general social and economic conditions of the affected communities and to identify any key social issues that were of concern to the affected people, especially among the male and female residents in local communities.

A summary of the consultation activities, including key informant interviews, focus group discussions and sample household surveys is presented in Table 1.

Table 1 Public Consultation and Participation for Social Analysis Study

Target groups Assessment method Location Unit number Participants

SEGX Guangxi interview Beihai 1 12

Guangxi Forestry Group Corporation interview Nanning 1 5

Beihai Forestry Bureau interview Beihai 1 2

Office of Beihai Beibu Gulf Economic zone interview Tieshangang 1 1

Township forest station interview Zhakou Township 1 1

Township Government interview Zhakou Township 1 1

Resettlement Community Focus group Nanle community 1 14

Villagers Focus group Baisha Township 9 54

Villages leaders interviews Villages 9 19

Village group leaders interview Villages 8 8

Contractors1 interview Plantation site 2 2

Migrant workers Focus group Plantation site 1 8

Total 35 127

2.3 Secondary Data CollectionIn order to facilitate social analysis, information was also collected by UNDP as well as SEGX. This included the contract templates, project management introduction and a review of various reports on social and environmental concerns in relevant area of the project.

social dimensions, while potential environmental impacts where seen as manageable through appropriate operational control and monitoring (UNDP, 2006), and (iii) an independent review of the EIAs with regard to IFC and other international best practice (UNDP-Hatfield, 2008), which identified gaps to be addressed in the existing assessments to meet IFC guidelines.


3.1.3 Perceptions of Slowness

Some villagers are concerned about SEGX being slow to develop the land. They worry they will not receive rental payments. Particularly when SEGX does not develop the land for some time after rental, their concerns tend to grow. UNDP (2006) findings indicate that in some cases rental payments have been delayed because of slowness in determining exact land areas and borders. These issues are not unique to SEGX, and are typical of land boundary issues in rural China.

3.1.3 Employment opportunity and migrant workers

Once SEGX operations have reached a steady production rate, employment is estimated to be between 12,400 and 14,400 full-time jobs. SEGX plantation work presents an opportunity near to home for those locals that do not wish to migrate for work, though may not offer as many months per year of work as migration work. Across survey groups, results indicated that respondents are not dissatisfied with their working conditions as compared to the alternatives, but nor do they believe their working conditions are particularly good compared to other options.

Minorities are more prevalent among migrant workers on SEGX leased land than among other land leasers and they are well-integrated with the Han Chinese.

UNDP (2006) show that contractors rarely have formal written contracts with the workers that they hire but have verbal agreements instead. Workers have a lack of access to emergency services for cases such as urgent illness, injury, or exposure to natural disasters, although these serious on-the-job health and safety problems are uncommon. Wage requirements are generally met and labour disputes have not become an important issue for workers involved in SEGX plantation development.

3.1.4 Needs for Community Development

The most important development priorities of surveyed groups in project area included: irrigation, roads, medical services, and drinking water. Results indicated that interest in getting a loan is high among affected groups in the project area and higher than the proportion that believe they can get a loan through existing channels.

Health services and education are priorities for large proportions of the project area respondents. The improvement of community medical services could be integrated into SEGX’s corporate policy for its field workers’ health and safety. Education is also a sector in which needs in the area are strong and which is conducive to development projects. While village respondents put a low priority (among other options) on telecommunications and the internet, it might be beneficial to develop village tele-centres to communicate with stakeholders. The concept would call for the installation of a computer with internet connection (when possible) in the project area’s natural villages. Villagers could use the centre to access information on SEGX, communicate with the company, and view materials on eucalypt plantations. Meanwhile, these centres could also function as a social gathering venue for entertainment, market information for their household agricultural and other products, information on employment opportunities.

3.1.5 Associated Risks

UNDP (2006) indicated that both households leasing land and SEGX face particular risks: households are concerned about degraded soil quality and non-payment of rent. SEGX may face risks of breach of contract by farmers, conflicts over land use rights, unauthorized use of SEGX land by locals, and fertilizer theft.

3.2 Summary of Social Research undertaken in 2009The social research carried out in December 2009 by the Sustainability Department at SEGX, highlighted the following key findings and conclusion which were generally representative of other surveys: (i) villager’s income resources are limited and fragile; (ii) the public knows little about SEGX; (iii) communication is weak between SEGX and grassroots levels from town government, village committees to villagers; and (iv) the most important development priorities are road construction and water supply. Some issues identified in the study included:

» Generally, villagers have a negative attitude towards eucalypts. The main issues noted associated with eucalypts were perceptions of their potential to lower the water table, shed toxic leaves, block sunlight falling on adjacent crops and cause water pollution and increased soil erosion.

» Stakeholders from village committees and villagers noted some dissatisfaction with their land lease rental payment rates. Primary complaints related to low rental payments and delayed rental payment. It was not clear from the study if this refers to cases where land is rented directly to SEGX or through other entities, village collective or BHC. The actual cases are not presented nor are the people involved and responsible parties identified in the study.

3. Previous Studies

Several social studies and impact assessments have been carried out by SEGX. The following section provides a summary of some of the key studies.

3.1 Summary of Social Assessments undertaken in 2006 and 2008The 2006 report undertaken by the UNDP during the period of 9 May to 15 September 2005 (UNDP 2006) presents the findings, analysis, and recommendations of the ESIA on SEGX’s forest plantation project in Guangxi. Some issues regarding the study are summarized as follows.

3.1.1 Information Flow and Gap

UNDP (2006) indicated that 133,000 households would be affected by SEGX’s forestry land leasing when the project reaches full scale. it is noted that the rural population in project area has a low dependence on forestry for income.

A critical need exists to improve the flow of information from the SEGX to local affected villagers and other stakeholders to ensure greater transparency in the process. A striking finding of the survey is that stakeholders have a strong desire for information about SEGX and its plantation project. The survey results also show that while stakeholders do have some information on SEGX’s project, they rarely received it directly from SEGX.

Although the scientific review and expert testimonies conducted by UNDP (2006) do not suggest negative environmental impacts, the larger scale survey and fieldwork found that people appear genuinely worried about potential environmental impacts of eucalypts on human, local fauna, crops, soil, and water. Some of the ecological concerns voiced may actually have been a means of indirectly expressing overall dissatisfaction with the land leasing contracts.

UNDP (2006) notes that the leasing of collective land to SEGX has been voluntary and in congruence with the individual land use rights of farmers to whom such land has been allocated. However, in making the collective leasing decision, the majority of affected village households expressed a feeling of either not having been given full information or not having been given full choice.

State Farm staff in project areas, as a group, do not strongly support land leasing to SEGX, and are not involved in the decision to rent, so are therefore not very aware of rental terms.

Although village households, collective members, and State Farms are expected to benefit from land leasing, UNDP (2006) findings indicate that their benefits are limited. In terms of opportunity cost, most of the land rented in village areas was not being put to highly productive uses, so leasing this land is likely to generate more income per mu than continuation of past use. In terms of alternative future uses, the opportunity cost is more difficult to evaluate, particularly for the long-term (+30 years) and also if we consider the unpredictability of future markets for fruit, sugarcane, eucalypt, and other products.

3.1.2 Land Rental Decision Making Process

In terms of village land use rights, land rental in village areas includes both private and collective land. The UNDP (2006) found participation in the decision to rent collective land to be weak. The majority of project village households surveyed indicated a small group of people had represented their community in making the collective leasing decision. Generally, findings suggest that farmers had made a rational choice to rent out their land, despite the possibly lower income per mu relative to other options, because of certain constraints such as the financial strength, know-how, and economies of scale needed to develop the alternatives.

The UNDP (2006) team also revealed that dissatisfaction with the rental process on collective land may originate not as a result of actions made by SEGX, but in the decisions over whether or not to rent collective land and how collective rental income was spent. In contrast to the findings on private land rental, in which households are indeed the final decision-makers, the analysis found that participation in decisions over community land was weak.

SEGX also rents land from State Forest Farms. Results indicate that State Farm staff in project area, do not strongly support land rental to SEGX, are not involved in the decision (though their involvement is not legally required), and are not aware of rental terms.


and human capital.

» Local communities have also seen improvements in their capacity in nursery skills and tree planting, as well as forest management.

Key negative impacts identified included: (i) a perception of damage to rural roads from the transportation associated with SEGX activities and comments regarding a lack of input on maintaining the rural road by SEGX; (ii) a perception that few local villagers have been employed by SEGX compared with external employees. Local communities have limited access to employment opportunities; and (iii) women and poorer groups have not been recognized and highlighted as one of the key target groups in the community by SEGX.

In light of the key findings, the report recommended that SEGX continue management of potential risks identified above, as well as offering more local employment opportunities and providing more social development support and active information sharing. Building capacity for SEGX staff on working with the community and corporate social responsibility activities is also necessary in future.

» Seventy per cent of government officials and villagers interviewed suggested that SEGX should have regular face to face meetings with them to solve problems systematically.

» Village committees felt that SEGX did not communicate with them other than during conflicts. However, 16.7% of village committees think communication channels are useless or not necessary and that doing something good for the community is the best way to communicate. Sixty per cent recommended face to face communication.

» Most villagers know nothing about SEGX except that it is a “Finnish Company”. Sixty two per cent of villages have seen public notices but villagers suggest public notices should be pasted in the village shops by SEGX staff, not given to the village committee. Villagers are highly interested in contract issues and work in the forest land. Villagers in 3 nature villages suggest that SEGX should notify them before spraying pesticides and herbicides. However, it is noted that chemical pesticides are not used as standard SEGX stand management practices and SEGX does not use internationally banned pesticides or herbicides.

» Roads, drinking water and irrigation are one of the highest priorities. These priorities indicate how SEGX may address community development in the future.

SEGX has taken the findings of these and similar studies seriously and is working to improve communication and engagement with local villagers to address concerns.

In August 2009 an independent national social development specialist conducted a Social Impact Assessment (SIA), as reported in UNDP-Deng 2009, to capture the social impact of plantations from changes in land use policies. The report focused on the following aspects: (i) impact on local livelihoods, especially local food security and cash generation at the community level; (ii) impact on the local livelihood capital, such as the natural, physical and human capital; and (iii) impact on local capacity building.

The study was conducted by a desktop review of existing policy documentation, technical design review and field inquiry with local farmers whose forests have been acquired by SEGX. The report presented the following key findings:

» The Chinese government has issued a new policy reform regarding collective forests in China (The Conceptual Guideline for Promoting the Institutional Reform of Collective Forest, official document No 10-2008, by CCPCC and State Council). Based on this policy all the collective forest land whose land tenure is clear should be allocated to households where applicable. Guangxi provincial government issued the policy reform of collective forests in Guangxi province on January 23, 2009.

» Livelihood analysis focused on the sources and diversification of cash generation in the SEGX project area. Land acquisition by SEGX plays an important role in cash generation for the local communities and has a positive impact in diversifying the sources of cash generation; however it was not indicated as one of the top three most important income sources at the time of survey.

» Overall, the impact of land acquisition by SEGX is positive and SEGX is accepted by the communities in the project area. The main concerns for the local communities were:

– Rural road maintenance (as indicated by a mixed gender group in the Cao-Jiang village and an all-male group in Dan-Tian village);

– Ecosystem protection, including soil erosion control and preventing poisoning of fish ponds by eucalypts; and

– The annual payment rate for land rental by SEGX. However, the proposed revision of the rental payment rate every 5 years due to inflation was seen as a positive.

» Questionnaire responses indicated that there was no negative impact from land acquisition by SEGX on local resource security and no general disagreement to lease the land to SEGX. The majority of respondents were satisfied with payment methods and the majority recognized that cash generation from leasing the land to SEGX resulted in the same or higher income than alternative land uses.

» Local communities have expectations of SEGX. In particular, the need for more local employment opportunities to contribute not only to the sustainable cash generation for the community but to improve the relationship between the communities and SEGX. Local communities are also able to help SEGX with forest management such as forest fire and illegal logging control.

» SEGX has been accepted by local communities and there is a better relationship compared to other local forest companies, due to the higher rental fees, regular adjustment of rates, timely payment scheme and social engagement programs for the communities.

» There have been no impacts on local culture and tradition, as well as no negative impacts to local food security, natural


lands remaining will be delivered after the third-party forest land assets evaluation.

» Social Land Contract: In 2003, the SEGX signed an agreement and entrusted Guangxi Gaofeng Group with the lease of social forest lands on behalf of the government. As a state-owned stock company, Guangxi Gaofeng Group contracted with forestry farmers to lease forest lands at 23-75 RMB per Mu, according to the assessment of the condition of forest lands and the price level at that time. Guangxi Gaofeng Group handed over the contracts signed with farmers to the SEGX later in 2005.

In 2006, to promote the building of the wood supply base of the plantation and pulp mill, the Beihai government decided to establish the Beihai City Forestry Investment Development Limited Company (BHC) to make contracts with SEGX. The BHC represented the Beihai government to sign the overall agreement with SEGX, as well as establishing land lease contracts with forest farmers. For example, from the interview with village leaders of Natan Village, we learned that, if the farmers in Natan Village would like to rent their lands, they need to first contract with the BHC. The private land lease contracts are in triplicate, respectively held by the farmers, the town government and the BHC.

» Forest Land Leasing Contract in 2009: In 2009, SEGX Forestry Limited (Party B) changed the contracting process to contract with the village group (Party A) directly. According to the contract, the new contract is effective after being signed by each party and approved. There are 4 originals of the contract, each held by Party A, Party B, the Forestry Bureau of the county or the district and the township government.

– Existing Forest Purchasing Contract: In addition to the above land lease contracts, timber can be purchased directly from land owners. Party A (the village committee /farmers) and Party B (Guangxi SEGX Forestry Co., Ltd.) signed a contract entitled the ‘Existing Forest Purchasing Contract’. This contract stipulates that to support the Pulp and Paper mill in Guangxi, Party A agrees to transfer the ownership of the wood and the right to use of the forest land to Party B, for use as a wood supply base.

Party B is to pay both the purchasing price and rental of forest lands for the ownership of the wood and the right to use the forest lands. In addition, SEGX has made a commitment to use the lands in accordance to the law.

– Tending Contract: The tending contract of the forest lands is signed by SEGX and the contractors such as individual farmers, the township government or the forestry station.

4.2.3 Implementation of the SEGX Contracting Process

As detailed in part above, SEGX has established processes for the contracting of state land and social land respectively. The detailed content of the process is adapted to the governance of the land to be leased, whether it is state land or social land. All steps of the process are also recorded.

State land: under the commitment of Guangxi government, 8 state forest farms will provide forest land to SEGX. The land planning department checks the suitability of the offered land for Eucalyptus plantations based on the Land Use Plan Criteria, LUP that include physical and social criteria. Land which does not fulfil the criteria is either rejected or only accepted as non-Eucalyptus area for meeting the 20% requirement of the State Forest Administration for non-Eucalyptus species.

The SEGX regional planning team and the district manager, sustainability team and the harvesting team check physical land criteria and social risk connected to the offered land. This checking includes but is not limited to questions as:

– Can SEGX operate on this land in the future?

– Has any villager raised any objection of land ownership?

– What does the surrounding environment of the land look like?

– Has there been any conflict or violence in this area?

– General condition of the land, road network, adjacent villages, remoteness of location etc.

When the regional risk checking is done, the land contracting and transfer will be processed and assessed by the legal counsel under the condition that both parties agree on the land value evaluation result.

Social land (Beihai region): the social land is mainly located at Beihai region (BHR) and most of the social land has to date been contracted by Beihai Company (BHC).

When a new area of land is offered to SEGX by BHC, the Beihai regional planning department applies the LUP criteria to assess the suitability of the offered land as fibre base. Additional criteria apply to certain areas or villages where leases are not considered due to high social risks that are identified and agreed beforehand with BCH. Risks are related to unclear land

4. Current Social Management Practices4.1 SEGX Plantation Estate

Plantation estate land currently contracted by SEGX is spread amongst 27 Counties (the 27 Counties are Beihai, Hepu, Beiliu, Bobai, Fumian, Luchuan, Rongxian, Xingye, Yuzhou, Binyang, Nanning, Shanglin, Wuming, Lingshan, Pubei, Qinzhou, Chongzuo, Fusui, Ningming, Dongxing, Fangcheng, Gangkou, Shangsi, Guigang, Guiping, Pingnan, and Tengxian). Of the

total area of currently contracted and offered land of 125,885 hectares, 36,154 hectares (29%) is social land and 89,732 hectares (71%) is state land (as shown in Table 2). The majority of the social land is located within Behiai and Yulin Counties. State lands are located within five city areas: Beihai, Yulin, Nanning, Qinzhou and Chongzuo.

Table 2 Total Forest Farm and Social Land Contracted and OfferedForest Farm Contracted Lands (ha) Offered Lands (ha) Total (ha)Dongmen Forest Farm 6,742 1,510 8,251Gaofeng Forest Farm 4,553 12,250 16,803Liangfengjiang Forest Farm 400 573 973Liuwan Forest Farm 1,948 3,995 5,943Paiyangshan Forest Farm 3,574 1,733 5,306Qinlian Forest Farm 20,710 3,548 24,259Qipo Forest Farm 4,124 6,032 10,156Total 51,794 37,937 89,732Social Land (by County) Contracted Social Lands (ha) Offered Social Lands (ha) Total (ha)

Beihai 22,378 3,137 25,515Yulin 7,012 102 7,114Qinzhou 797 22 819Fangchenggang 707 60 767Guigang 1,510 - 1,510Wuzhou 429 - 429Total 32,833 3,321 36,154

4.2 Forestry Land Contracts4.2.1 Land contracts management processes

Property rights in China as they relate to this project include: (i) ownership (ownership rights can be either in the hand of the state or the village collective), (ii) user rights - land use rights for farming, housing, business, (iii) timber rights - right to grow and harvest timber; and (iv) timber use rights - right to use forestry lands for secondary uses such as resin tapping, livestock grazing and other non-timber uses. For this project SE is seeking to obtain timber rights.

In 2003, SEGX signed an agreement entrusting Guangxi Gaofeng Group to lease social forest lands on behalf of the government. As a state-owned stock company, Guangxi Gaofeng Group contracted with forestry farmers to lease forest lands based on a condition assessment and the price at that time. Guangxi Gaofeng Group handed over the contracts signed with farmers to SEGX in 2005.

In 2006, to further develop the wood supply base of the plantation and SEGX mill, the Beihai government established the Beihai City Forestry Investment Development Limited Company (BHC) to work with SEGX. The BHC were entrusted by the Beihai government in signing land agreements with SEGX and forest farmers.

SEGX developed a social land contracts management process to govern the land contracting process, which was implemented from September 2006, and has been continually improved over recent years. Box 2 outlines the principal and common steps of SEGX’s social land contracting process.

4.2.2 Categories of Forestland Contracts

Land lease contracts of the SEGX include two types: social forest land contract and state-owned forest farm contract.

» State-owned Forest Farm Contract: When SEGX started their business in Guangxi, they made a work agreement with the Guangxi government. According to the agreement, the Guangxi government is to provide SEGX with 2,400,000-Mu forestland as the wood supply base. So far, the state-owned forest farms have not contracted with SEGX.

The Guangxi Forestry Group will hold a 15% share of the project as the Chinese side cooperative partner.

According to the project plan, state-owned forest lands make up 75% of the whole 2,400,000-Mu forest lands. So far, the Forestry Group has already signed over 776,000-Mu of all 1,450,000-Mu forest lands to SEGX, and nearly half of the forest


4.3 Mill Site Resettlement The proposed SEGX pulp and board mill site is located in Xinggang town, Tie Shangang, Behai (as shown in Figure 2). The land lease and resettlement has been completed and involved 26 villager groups in 5 administrative villages, Nanle village, Binchi village, Chuanjiang village, Pitou village and Xiejia village. These villager groups have been directly affected by the project, and other villager groups in the township are indirectly affected by the project.

Four village administrative groups did reside within the 250 ha mill site land in Tieshangang that was acquired by Stora Enso for the pulp and board mill. These village groups were Nanle, Binchi, Xiejia, Potou and Chuanjiang in Xingang Town of Tieshan Port District. Along with the 274 mu of lands in Honghuagen Village leased for the construction of new houses and resettlement of the 4 village administrative groups, there were 4,029 mu of land leased in total, which was in accordance with the original land lease plan. The resettlement process include approximately demolition and reconstruction of approximately of 50,000 square meters of brick-wood houses and more than 4,000 square meters of brick-concrete houses. The office building for Nanle Village Committee, the Nanle Primary School, two base stations for communications, one brick factory and 1,345 graves were relocated. In total, 1,236 people within 467 households were affected.

As of 2011, the resettlement process had been completed including house construction and service infrastructure (water, power, roads, communication, effluent treatment). The principal problem remaining was delay of the SEGX mill project. Affected people lost their land and employment as a result of the resettlement, and some were counting on the SEGX mill for future employment. The government has held regular vocational training and encouraged other enterprises to hire the affected people, however the affected people have not benefited from much from these efforts.

ownership and unclear land rental agreements signed by the village communities in the last 10 to 15 years.

After the physical site inspection by the planning department the contract management team goes to the site to check the legal situation of the original contract with the land use right holder. In parallel the district management team studies the social risk of the offered land.

This checking includes but is not limited to:

– Legal screening based on set criteria

– Interview the land owner for the land transaction history and any reasons for objections

– Existing conflict record and potential conflict over the forest operational cycle

– Historical conflict and violence cases

– Rental situation of the land owner.

– General condition of the surrounding land, such as roads, nearby villages, remoteness of location, social information etc.

The lawyer provides a report of the offered land based on 19 defined legal criteria and classifies it according to its legal status. Contracts are classed as “green” if contracts are legal and verified; “yellow” if contracts have some legal issues but that can be easily resolved and “red” if contracts have serious legal issues that are difficult to resolve.

The district manager checks the existing conflict data records and based on the knowledge of the area, plus the communication with the land owner and the information from related parties reviews the social situation of the land.

Together this result in a land assessment report and a recommendation on whether the land can be operated or not and which potential social risk that exists. Only when the district manager recommends to accepted the offered land and the legal team gives a green status the respective contract can be signed by the regional manager for signing. The contracts with “yellow” or “red” status after the legal screening are returned to BHC for correction.

Social land (outside Beihai): Outside Beihai region, the social land leased approach is similar however the land leased is managed directly between SEGX and the holder of the land use rights.

BOX 1: Principal steps in land contracting process for social land. [LUP; Land use plan criteria, for sustainable fibre base in state and social lands]:

Land offer to SEGX

Good againstLUP?

Check, good?

Legal, social and risk review

Measure and valuate land

Negotiate, agree terms and sign

Return , to adjust or rejectYES

NO

YES

OK

Return , to correct or reject

NO

SEGX Holder of land use right

Contract


– Improvement of Transportation: The farmers suggested improving roads. The scale of the road traffic has increased since 2003, but the quality of the forestry land transportation has not improved. SEGX is expected to invest funds to maintain and build new forestry roads in the Project area.

5.1.2 Najiang Village

Participants of group discussion included 3 village leaders and 10 village group leaders.

The Najiang Village includes 550 households and a population of 3,240 people. The labour force constitutes 1,450 people, of which 850 are male and 600 female. Table 4 represents the household situation of the people in Najiang Village.

Table 4 Household Situation of the Participants in Group Discussion - Najiang Village

Number of Households

Households with forestland

Households with collective

forestland

Land lease Households

Forest land for family

Forest land for

collective

Land lease for ESGX

Migrant workers

13 11 2 6 183 180 263 0

Table 5 shows that the interviewees include representatives of private and collective land. There are no migrant workers.

Within Najiang Village there is 2,900 mu of forestry lands, among which 2,000 mu are individual owned and 900 mu are collective owned.

In 2009, the Najiang Village income per capita was RMB 2,200, according to the village leader. The income structure of Najiang Village is presented in Table 5.

Table 5 Income Structure of Najiang Village

Income categories Livestock Najiang workers employed outside Najiang Crop farming Forestry

Income proportion 45% 25% 20% 10%

Table 6 indicates that forestry accounts for 10% of the income of Najiang Village, suggesting the Village derives relatively little benefit from leasing their lands to SEGX.

In 2007, Baisha Township Government announced at a meeting attended by Najiang village committee leaders and individual farmer representatives, that SEGX would lease land owned by the Najiang villages. Following the announcement, BHC representatives (acting on behalf of SEGX) and Baisha Township Government representatives visited the villages to present and sign land lease contracts. Where or not the land belonged to individual farmer households or to the collective, the contracts were signed with between BHC on behalf of SEGX and village group representatives. It was said that 7 original copies of the contract were signed, and kept by SEGX, the township government, and other Government parties. The survey team could not find a copy of the contract in Najiang Village.

The land lease price ranged from RMB 50 per mu to RMB 150 per mu, varying based on the land condition, terrain, existing trees, and other factors. The lease was established for 20 years period. No information was provided with regard to a contracted process for increasing land lease prices on a regular basis in accordance market price increases.

According to the interviewees, they have not received regular rent for leased land since leased to SEGX. Partial payment of RMB 34,000 was received in 2009, which was distributed by village committee secretary to local villages. According to the contract terms, land lease rental is paid through the village committee account, then issued to village groups and finally to each household.

The interviewees indicated that many of the areas leased were undeveloped mountains, which did not develop any income. After being leased to SEGX, the land brought in income and in this sense, leasing these lands to SEGX has improved the economic welfare of the villages.

Five individual farmers within the Najiang Village were identified that had not leased their lands to SEGX. These farmers has been offered land lease contracts, however they declined because their lands were geographically separate from the other SEGX leased land. In addition, they preferred to plant sugarcane and cassava crops, rather than lease the lands for forestry due to potential for higher income per mu. According to the interviewees, sugarcane and cassava crops can earn between RMB 600 to RMB 900 per mu, significantly higher than forestry land lease returns. These farmers believed that some of the lands leased to SEGX could have been used to plant sugarcane and cassava.

The interviews also showed that there is a lack of clarity and agreement on areas of individual verse collective land ownership within Najiang Village. This disagreement is causing friction between the village leaders and individual farmers. Some farmers reported that they only knew how many pieces of lands they had, but not how many mu. Adding to this friction, in many cases

5. Land Lease Complementary Survey

In August 2010, the survey team visited one township and four administrative villages to undertake interviews: Zhakou Township, Najiang Village, Dongfeng Village, Langen Village, and Natan Village. The surveys included a total 63 villagers, made up of 26 village leaders and village group leaders. Among the villagers interviewed, 91% of them leased their land to SEGX.

The following provides a summary of the finding from each village.

5.1 Leasing Process and Current Issues5.1.1 Zhakou Township

The survey in Zhakou Township involved five villages. Fifteen village leaders from these five villages participated in the focus group discussion, including eight administrative village leaders, five leaders of small village groups of Zhakou Village, one technician of the forestry station of the township and one associate leader of the township. The basic information of the five villages is shown in Table 3.

Table 3 Basic Information of the Five Villages in Zhakou

VillageName

Total Households People Land lease

Households (%)

Ownership of the Land Contractor Migrant workersIncome

2009Individual HH Collective Farmers

HHVillage

committeeTotal HH People

Xinliao 475 2140 50 0 √ √ 0 25 40 3280Zhakou 605 2700 60 0 √ 0 √ 40 60 3300

Qingfeng 878 3950 20 √ 0 √ 0 30 45 3290Shanbei 338 1520 60 √ 0 √ 0 35 50 2840Genkeng 515 2320 70 √ 0 √ 0 55 75 3100

Total 2811 12630 260 3 2 4 1 185 270 15810Average 562 2526 52% 60% 40% 80% 20% 37 54 3162

Table 4 shows the average annual income of the villages in Zhakou Township is RMB 3,162. 52% of the total farmer households have leased their land to SEGX. 7.4% of the total farmer households utilise migrant workers on the lands that SEGX has leased.

In June 2003, the Guangxi Gaofeng Group came to the township and villages to discuss land lease issues. At that time, the Guangxi Gaofeng Group was interested in leasing land in hilly terrain for 30 years for RMB 13 per mu per annum. The rental was to be adjusted with the change of the local land prices after every 5 years. According to the village leaders, the Guangxi Gaofeng Company leased 80% of the land from individual farmer households, and 20% of land from the village collectives.

Contracts were signed by individual farmer households and village collectives, with a total of 7 contracts for five villages. Contracts were signed with individual farmer households in all of the villages, with the exception of Zhakou Village, where the contract is held by the village collective.

In 2005, the Zhakou Township Government transferred these land lease contracts from the village groups and individual farmer households to BHC acting on behalf of SEGX (a small number of individual farmer householders contracts where transferred directly to SEGX). The transfer was made without discussion with all parties and did not include discussion with some of the individual farmer households. The individual farmer households did not have the opportunity to negotiate their lease price. In 2009, SEGX raised the lease price from RMB 13 to RMB 30 per mu. However, the individual farmer households still considered this to be lower than the market rate, noting that other private contractors were paying between RMB 70 to RMB 80 per mu in 2009.

The prevailing sentiment with amongst farmers is that they lacked the opportunity to communicate directly with SEGX. The direct line of communication is through BHC and there is doubt on the effectiveness of this channel of communication with SEGX. Due in part to the lack of direct communication, disputes have occurred in regard to measurement discrepancies in forestry land boundaries that remained unverified and unsettled at the time of this survey.

The following recommendations are made to address some of the land lease issues identified in Zhakou Township:

– Rental returns: Rental for leased land should reflect and conform to the change of the market prices for leased land.

– Timeliness in rental payments: SEGX take measures to ensure rental payments to the farmers are made on the due date. Measures may include simplifying payment procedures.

– Improve communication: Specifically between SEGX and farmers in the rural community. They prefer to sign the contract directly with SEGX and have more involvement in decisions.


The group noted that some of the leased land remains un-used, that if this land is not intended for forestry plantation, then they are interested to use it for other purposes.

A general concern, likely to be based on lack of knowledge of the facts of Eucalyptus, was the perception that planting eucalyptus will affect the water resources, the smoke from burning Eucalyptus is poisonous, and the Eucalyptus will have a negative influence the ground water, poisoning drinking water, and it was even note that the potential for birth defects was a common concern relating to Eucalyptus impacts. The group requested monitoring of water quality and communication of the results.

The interviewees noted there has been delays in the payments for leased land, even with repeated requests of the Baisha Township Government. These delays have been difficult to address, the problems compounded by the Baisha Township Government acting as a third party between the village and SEGX.

A final comment was made that, although the contracts were agreed and signed by the village group leaders and agreed with the farmer households, they did not receive copies of the contracts after signing, and now indicate they have limited understanding of the terms and rights. The group indicated that they intend to appeal to the higher Government authority, and express their dis-satisfaction with regard to the lack of transparency.

5.1.5 Natan Village

Six village leaders and three villagers from the Natan Village took part in the survey discussions. The Natan Village include 896 farmer households. The farmer per capita net income per year is RMB 2,550. Natan Village receives several sources of income, primarily from aquaculture including clams, sandworms, and shrimps. Forestry is not a significant source of income.

The forest land leasing process in Natan occurred in stages, commencing in 2006 with the leasing of 100 mu to BHC. The interviewees could not confirm, however they thought that BHC had leased the land on behalf of SEGX. By December 2009, 700 mu of forestland has been leased to the company, of which 200 mu was collectively owned land and 500 mu was individual farmer households owned land.

In the process of establishing the land lease contracts, the farmer households signed contracts with the BHC directly, with a 15 year term, and the land lease rental rate reviewed every 5 years. The contracts were signed in triplicate, with households, the Township Government and BHC holding one copy each.

Among all farmer households interviewed, the agreed land lease rental varied between RMB 30 to RMB 120 per mu.

The villages expressed concerns regarding the potential for increased fire risk, potential for pollution of water resources, and reduction of groundwater table as a result of the Eucalyptus plantations.

the individual farmers did not have a copy of the SEGX land lease contracts, and therefore are not clear about leased land areas and the total rental to be issued.

5.1.3 Dongfeng Village

Seven farmers from Dongfeng Village participated in the interviews, representing 6 village groups. Dongfeng Village includes 26 village groups with 2,500 farmer households and a total population of 7,000. Dongfeng village owns 4,000 mu of forest land and 3,600 mu farm land. Before 1980, the lands and forests were distributed to each household, but in 1981, all lands were collected back to the village. So far, all of the forest lands in the village are collectively owned.

Dongfeng Village net income per capita in 2009 was about RMB 3,000. Table 6 provides a summary of sources of income for the Dongfeng Village in 2009.

Table 6 Income Structure of Dongfeng Village in 2009 (RMB)

Income categories Livestock Migrant workers Crop farming Forestry Net income per capita

Income 5,000,000 2,500,000 4,000,000 800,000 3000

The land leasing process to SEGX within Dongfeng Village has occurred in stages, commencing in 2003. The leasing process has followed has been undertaken between communications between BHC and the village committee. The village committee relays the land leasing contract information to the individual farmers during meetings. The individual farmers were aware that an agreement of two-thirds of the farmers was required to agree a contract to lease the land. The interviews highlighted that the Township Government had assigned land lease targets for each Village, with specific land area targets required to be accomplished each year between 2004 and 2010.

As with other villages, disagreement on individual verses collective ownership of some areas of land were identified within Dongfeng Village.

The land lease agreements were kept by the village group leaders. Individual farmers indicated that they did not know the details of the lease agreements.

By 2010, ten village groups have leased their lands to via BHC to SEGX. Prices varied between RMB 40 to RMB 80 per mu, with a lease term of 15 years.

5.1.4 Langen Village

Ten residents from the Langen Village took part in the survey discussions. Langen Village is part of the Baisha Township, Hepu County, and includes a population of 3,018, within 420 farmer households, spread between five village groups: Langen, Xincun, Shagangpu, Jiaogendong and Gangwayao.

Langen Village owns approximately 1,700 mu of farmland, of which two thirds are paddy fields, one third is dry land, and 360 mu is forest land, all of which is collectively owned.

According to the Langen Village head, per capita net annual income was in the order of RMB 1,300 in 2009. The primary source of income comes from Langen residence working outside the region, as migrant workers in factories in Guangzhou, Shenzhen and Zhuhai. Other sources of income are associated with local livestock, crops, crab farming, fishing and other types of aquaculture.

In 2006, Langen village group signed a contract with the Baisha Township Government to lease collectively owned forestland under a 20 year term, which was then in turn leased to SEGX. The other village groups, had previously leased their forest land to a private agency, and they were unsure if it had been on-leased to SEGX. Based on these interviews, residents from the Langen village group were the only group that could confirm that its forest land was contracted to SEGX. The lack of awareness of SEGX involvement was highlighted by some of the interviewees who noted that they were not even convinced that SEGX existed. This clearly demonstrates a miscommunication on the part of SEGX, the ultimate lease holder for the lands within Langen Village.

The process of communication of the contract terms undertaken for the Langen village group included the Baisha Township Government representatives holding a meeting with Langen village group representatives. The members of the village group then asked the local farmer household opinions. According to the interviewees, over 70% agreement was received from the farmer households. Following this agreement, the contract was signed between the village group and the Baisha Township Government. The township government then subleased the land to SEGX.

The interviewees expressed a desire to have closer communication and contact with SEGX. It was suggested that SEGX could consider providing training for their local villagers on the new techniques for planting and tending Eucalyptus.


Table 7 shows the number of workers who are contracted to SEGX based on the villages interviewed.

Table 7 The number of local workers working for SEGX

Village name

Total households

Number of people Labor force

Workers contracted to SEGX

Total HH % of total HH

Number of people

% of total labor force

Xinliao 475 2140 963 25 5 40 4

Zhakou 605 2700 1215 40 7 60 5

Qingfeng 878 3950 1778 30 3 45 3

Shanbei 338 1520 684 35 10 50 7

Genkeng 515 2320 1044 55 11 75 7

Natan 896 4031 1814 0 0 0 0

Najiang 550 3240 1458 0 0 0 0

Dongfeng 2500 7200 3240 0 0 0 0

Langen 400 2600 1170 0 0 0 0

Total 7157 29701 13365 185 3 270 2

Table 10 indicates that local workers contracted to SEGX only account for 2% of the total local labour force, while the migrant workers accounted for more than 30%. In addition, it is indicated that the distribution of the local workers who contracted to SEGX is uneven distributed between different villages.

6.3.2 Migrant Workers from Other Provinces

Survey interviews were focused on eight migrant workers who participated in the group discussions, of which three were female. They were form the Shiyakou Village, a mountainous, remote and underdeveloped region in Yunnan Province. The workers surveyed all belong to the Miao ethnic group, with an average age of 38 years old . They have only 3.3 years of schooling on average, and 40% of them are illiterate, with most of them unable to speak mandarin.

6.3.3 Labor management

The migrant workers group started their work for SEGX through one of the local contracting agencies in February 2010, working on 470 mu in Maotian Village, and later 100 mu in Shiwan Village before the end of August 2010 (time of the interviews). The major work activities include weeding, digging holes, fertilizing, planting, watering and other tending activities in the field.

SEGX provided a 1-2 day on the job training for the migrant workers for at the beginning of their contract. Three SEGX technicians provide daily supervision, The workers are seen to be competent at the job as a result of their farming experience from Yunan Province, however they had not had any past experience with eucalyptus planting.

The migrant workers cook their own food with the wood fuel from the leased land. SEGX entrusts the contracting agency to provide the migrant workers with Accidental Injury Insurance which costs 100 RMB worker every six months. The migrant workers are satisfied with SEGX, which has provided good quality tents with bathrooms, good living conditions and labour protection.

There is a team leader in each group who is responsible for contract signing and wage distribution on behalf of each group. As long as there are job opportunities, the boss will introduce them to the new worksites. Each of them has a mobile phone. The phone is important for them to look for new worksites, as they frequently change workplaces.

The migrant workers go home to Yunan when the busy seasons of the year is over in Guangxi. Normally, they will go home in February or March and August each year. Figure 3 shows the seasonal calendar of the migrant workers.

Figure 3 the seasonal calendar of the migrant workers

6. Plantation Estate Social Impact6.1 Communication Barriers

As previously indicated, the forestland contract was signed with farmers in the past either by Guangxi Gao Feng Group before 2005, or by Beihai Forest Investment Company afterward on behalf of the local government. Before 2009, no contract was signed between SEGX and the farmer households directly. During the procedure of the forestland lease,

there is not any connection between farmer households and SEGX.

During land leasing process, the chain of communication where by the farmer and households contact SEGX must go through the local village leader (and in some cases there are 2 or more levels of village leaders), and followed by a contractor (eg BHC), and finally SEGX. The farmers and households who have leased the forestland speak only directly to the village group leader. The do not have any direct communication with SEGX. Therefore, there is a large communication gap between SEGX and the farmers and households.

Villagers interviewed felt that there was a lack of response to their questions and concerns. The villages interviewed expressed a desire to sign contracts directly with SEGX, because they feel a lack of direct communication to SEGX under the current process, where by the can only express their concerns through BHC. The villagers interviewed expressed a level of uncertainty with regard to if their ideas and suggestions are reaching SEGX.

Villagers interviewed from Langen Village noted that nobody from SEGX had been to their village, except SEGX staff who came to plant trees in 2007.

6.2 Contract Management 6.2.1 Lack of Transparency

The results from the surveys show that there is a lack of transparency on contract management in the project area. The farmers who leased the forestland were not informed fully about the content of the contract. In many cases, the individual farmers and/or the village group leader did not review the land lease contract, which has led to misunderstandings about the contract terms, including different interpretations of the contract conditions between various stakeholders.

6.2.2 Outstanding payment

Many cases show that the farmers had not received the payments, following the partial payment received at the beginning of contract implementation.

6.2.3 Lack of Communication and Follow up

No mechanism has been established for monitoring and following up subsequent to the contract establishment. For example, in some cases the land was leased but the trees were not planted for a period of time leading to confusion as to what was planned for the land, or in other cases the land ownership became unclear to local farmers after the land became leased. To resolve some of these issues, some local farmers indicated that they have requested to discuss the contract issue again with SEGX, however they have not been able to contact the company.

As a result of a lack of communication between farms and SEGX, some local farmers have stopped SEGX workers fertilizing the leased land. According to one of the contractors interviewed, there are some households who don’t agree with the planting, and have responded by removing workers temporary sheds from the land. The contractor believes that this situation is not helped by the local government, who receives payment from SEGX however in some cases the money has been reported not to reach the farmer households.

When the local households prevent fertilizing and planting, the migrant contractors inform SEGX, and SEGX contacts the local government to address the problem. In the meantime, the contractors have had to move their temporary sheds and fertilizers to other locations, and await further information from SEGX. According to anecdotal evidence from the contractor’s experiences, about 20%-30% of the leased forestry land has similar situations

6.3 Forestry Work Force6.3.1 Local Workers

As described above, the number of workers from the local farmer households who are working for SEGX is relatively limited.


7. Mill Site Social Impact The initial establishment of the mill site resulted in resettlement of 1,236 villagers from the site to a new area, Nanle Village,

approximately 2 km away. The resettlement, managed by Beihai City along with resettlement of villages from other areas of the Tieshangang Industrial Zone not related to SEGXs’ operations, included monetary compensation and an on-going allowance for each person affected in accordance with local government policy.

The survey process undertake as part of this assessment included a site visit to Nanle Village, and a interviews with 11 village representatives (9 male, 2 female) in a group discussion environment.

The resettlement process commenced in May 2007 and was completed in November 2009. The resettlement was initiated by the Beihai City government, first announced during a village meeting which included participation of the village group leaders, Beihai City government and representatives from the PRC Communist Party. Subsequent meetings included participation from all local villagers. The village group leaders visited affected households to discuss issues and the resettlement process. In March, 2008, the resettlement activities commenced. The relocation process occurred in stages over a two year timeframe.

7.1 Compensation for Resettlement The findings from the survey indicated that all affected people lost their agricultural land as a result of the resettlement process. About half of the interviewees pointed out that their housing area (m2) decreased as a result of the resettlement process.

According to the interviewees, the resettlement compensation agreement included (i) a flat rate of RMB 70,000 per person for to compensate for land lost, (ii) an additional RMB 2,000 per mu for agricultural crops, and (iii) RMB 360 per m2 house area. It was noted that this criteria was established by the government, and there was negotiation of compensation rates. The affected people express that they believed the amount of compensation was not reasonable and they were not able to recover their lifestyle based on this compensation.

In addition to these one off compensation payments, affected people who remain unemployed in Nanle Village receive RMB 100 per month from the government. However, affected people who have been given employment are not entitled to this allowance.

7.1.1 Spending the resettlement compensation

The survey showed that almost all of the affected people used the resettlement compensation payment to build new houses with in Nanle Village. In addition, about half of the interviewees used some of their compensation payment to cover their living expenses, and some paid for schooling and medical expenses, as detailed in Table 8.

Table 8 Resettlement Compensation Use

Items Productive investment

Living cost

Schooling expenses

Medical expenses

New houses building

Vehicle purchase Others

% of HH 9% 55% 36% 36% 100% 9% 0

Most of the affected people were at the stage of rebuilding their livelihood. The resettlement had a significant impact on the expenditure structure of the affected people and may continue to affect them for some time.

7.1.2 Nanle Village Income and Expenditure

The survey found that 91% of the interviewees earned much less in 2009 than in 2006 because of the loss of the income from crops and livestock. It was reported that most of affected people lived on subsistence allowance from the Government (RMB 100 per month) following the resettlement process. The income of the affected people in 2006 and 2009 is given in Table 11, which shows income of each family was in the order of RMB 70,000 in 2006, and reduced to around RMB 10,000 by 2009. Since the main source of income for the affected people was aquaculture before resettlement, the loss of this source has had the most impact.

6.3.4 Payment

The migrant worker payments operate on the Piece Wage System, where the migrant workers will be paid 175 RMB when they finish planting one mu of land (in accordance with their agreement). They can finish one mu in about two days. Breaks are allowed for during periods of heavy rain. The migrant workers usually work 8 hours a day, six days a week.. All of the members in the group work together in the field and the payment for each person will depend on the days contributed. The salary is paid by the contracting agency at end of each day when the work is finished. The contracting agency has a separate contract with SEGX. No delay in wage payment has occurred so far according to the migrant workers.

The average monthly wage of migrant workers is RMB 1,500. This is lower compared with the local villager’s wages working on SEGX leased land which range from RMB 2,000-3,000 per month, according to the migrant workers. While these wages are low, the monthly costs for migrant workers are about RMB 500 per person, leaving around RMB 1,000 each month remaining.

6.3.5 Expectations of the migrant workers

The migrant workers interviewed said that they would like to continue to tend the forest if the work is offered to them. Normally they change jobs only because of the relatively low wage. They hope they would have a long term job with SEGX and more job security.


Establishment of green belts (areas of public vegetation) are planned, however are yet to be established.

7.1.5 Attitude of Villagers toward the resettlement

When inquiring about the positive impacts of the project to the community, many of affected people interviewed agree that the resettlement has improved the living environment. During the interview, they also said the resettlement that let them changed from traditional life style to the modern one with improved living conditions. Several of the interviewees mentioned that the project improved the drinking water condition, and made it more convenient. Table 11 provides details of affected people’ comments on the positive impacts of the resettlement.

Table 11 Positive impacts of the resettlementImprovement of living environment 64%

Improvement of drinking water condition 45%

Improvement of sanitary condition 36%

Improvement of traffic condition 27%

Increased employment opportunity 27%

Improvement of education 27%

Obtained compensation 27%

Promoted regional economy development 9%

Reduced the gap between urban and rural areas 9%

When asked about the negative impacts on the community, most interviewees put farm land reduction at the pot of their list. Many of the interviewees said that it was difficult to find jobs and there was a lack of efficient transportation to areas with employment prospects, and lack of employment assistance facilities. The negative impacts are shown in Table 12, which highlights that the farmers are most concerned with lost farming land and the lack of opportunity for employment after resettlement.

Table 12 Negative impacts of the resettlement Farmland shrinking 91%

Employment difficulty 64%

Water facilities damaged 18%

Roads are damaged 9%

Sewage pollution 18%

Compensation for agriculture is not available 18%

7.1.6 Plans to Restore Production and Living

With regard to future plans, several respondents intended to start a new business. Currently, the delays in the SEGX Project resulted in a delay to potential employment opportunities to the resettled people. In the circumstances that the government and companies operating within Tieshan Industrial Zone cannot provide any solutions, the farmers would like to report the difficulties to higher authorities to help them find employment outside the community. Table 13 shows the respondents’ plans to restore their production and living.

Table 13 Farmer planning to restore production and living for the futureIndicators Percent of the selectionStart own business 45%

With the minimum subsistence allowances as same as urban residents 36%

Working in transportation 27%

Investing pension insurance 18%

Work at the SEGX pulp mill 18%

Expanding scale of livestock 9%

Reserving lands of village for the service industry 9%

Others 18%

7.1.7 Social Risks

Due to the negative impacts associated with the resettlement outcomes, many Nanle Villagers have submitted complaints with the Tie Shangang District Government. These complaints were collectively documented in submissions entitled: Living Problems of Landless Farmers in Nanle Village, and Report on Living Condition of Landless Farmers of Nanle Village. These materials indicated

Table 9 Income of farmer households before and after resettlement (2006 and 2009)

Items 2006 (RMB)

2009(RMB)

Crops 5,136 0

Livestock 55,909 0

Processing activities 1,800 0

Service 822 1,309

Wage 5,909 3,764

Others 909 4,622

Total 70,485 9,695

After moving, the expenditure of affected people changed also. The expenditure of the affected people in 2006 and 2009 is showed in Table 10.

Table 10 Expenditures of affected people before and after resettlement in 2006 and 2009

Item 2006(RMB)

2009(RMB) Change (%)

Crops 2231 0 -100

Livestock 24018 0 -100

Processing 445 0 -100

Living 15163 26727 76

Education 7027 7182 2

Medical Care 855 827 -3

Transport 1370 2800 104

Communication 1218 1818 49

Social contacts 2545 2545 0

Other 1255 1345 7

Total 56,127 43,244

Table 12 shows that the affected people do not need to pay for crops, livestock and agricultural processing. However, expenditure for education and medical care remain about the same, and expenditure other items has increased, most notably transport, communication and living expenses.

7.1.3 Housing

The former houses in which most of the interviewees lived were single storey, flat roofed structures constructed of brick and wood. Their new homes in Nanle Village are 2 to 3 storey brick and concrete structures. In general, their housing standard has been improved as a result of the resettlement.

Prior to resettlement, the survey indicated the average family house area was 232 m2 (often including more than one house). Following resettlement, the average family house areas was 215 m2, equating to a 7% decrease.

7.1.4 Infrastructure

Nanle Village is serviced with municipal water supply, where as their previous residence was not serviced with piped water supply. The cost for water is RMB 0.8 RMB per m3. There are three health care centres in the new community. Concrete roads extend throughout the new community.

The Nanle Primary School was established in 2009, and the interviewees said the educational condition and teachers were much better than prior to resettlement. It was indicated that it was now more convenient for children to go to school. Public cemeteries and temples have been established to respect the local customs.

Villagers use gas and wood for heating in winter after moving. Fuel wood was available in the forest lands before resettlement. Following resettlement it can only be purchased in the market. The cost of fuel wood is still much lower by comparison to electricity or gas.

Nanle Village includes a piped sewerage system and centralised treatment system. However, the sewerage pipes were noted to commonly be blocked, resulting in sewerage discharge to areas of the village.


» Support to sports and cultural events in the community (by SE, facilitation by BHC) as part of community involvement and support activity;

» Support to education, scholarship to students and school equipment as part of community involvement and support activity;

» Facilitate job seeking and employment with employment agency activities and public sector job opportunities directed to affected people;

» Transfer affected people to urban houses;

» Social Security Allowance/Benefit that meet basic subsistence needs;

» Partial guarantee for business loans taken by affected people ;

» Areas within Tie Shangang Zone where affected people can set up shops and other businesses at low cost; and

» Follow up on business development with bi-annual visits (Years 2 and 3) and monitoring and coaching.

that the Nanle Villagers have had difficulties in daily life since the resettlement, and hope the Government will take measures to solve the problem.

The affected people have expressed their generally dissatisfaction with the resettlement policy, have indicated a lack of trust towards the local government and SEGX.

7.2 Future Social Impact Management StrategiesSEGX, together with IFC representatives, have developed a draft plan for livelihood restoration for people affected by the mill site establishment. This draft plan dated 30 June 2010 is preliminary and implementation is dependent on negotiations with Beihai Government and a final decision by SEGX on the mill investment.

The overall objective identified in the plan, is “to support the affected people to restore and develop sustainable livelihoods and facilitate the adaptation to an urban environment”. The livelihood restoration plan (LRP) is estimated to be implemented over a 3 year period.

The SEGX operations will result in approximately 3,500 affected people. The plan targets the working age population which is approximately 50% of the entire group. Affected people are defined in this plan as “people who earlier lived within the mill site boundaries and those who lost farm land as a consequence of the establishment of the mill site and whose remaining land is now <0.3 mu ( 200 m2)”.

The indicators to measure effectiveness of the plan are:

» Level of annual net income compared to baseline;

» Fulfilment of social security support compared to the level defined by law and minimum subsistence level;

» Sustainable local natural resource management; and

» Additional result component is the APs access to and participation in the local development activities especially the opportunities for vulnerable groups.

To ensure effective implementation of the plan, there must be ongoing cooperation between SE and Beihai authorities, as well as surveys and analysis, trainings and development programs to be carried out by partner organizations, relevant companies and institutes. Appropriate vocational schools and teachers must be engaged to provide training for small to medium enterprise (SME) consultants in the field who are engaged to identify opportunities, facilitate business development and education.

The following are key activities proposed to be undertaken as part of the draft plan:

» Skill and aspirations survey among affected people;

» Gender analysis of differential impact of LRP on men, women and also on socially vulnerable groups and subsequent development of mitigation plan;

» Independent livelihood survey on affected people’s income, expenses and assets;

» Identify and document major job and business opportunity streams, and locally appropriate technologies with estimate of total jobs and income generated;

» Design training and entrepreneur development program for affected people;

» Provide entrepreneur development including business management coaching (Year 1); and organizing one technology/innovation fair per year. Target goals are to establish 30 business entities, organize three fairs and maintain an entrepreneur profile database;

» Targeted vocational training matched to business and job opportunities followed by job placement with a result for affected people to build skills and complete diplomas issued by technical colleges;

» Supporting businesses in the process for securing RCC and bank loans;

» Support businesses in the process for securing RCC and bank loans;

» Joint management of development plan;

» Meetings with the AP community for follow up, inputs and handling of grievances as part of community involvement and support activity;

» Facilitate job seeking and employment in SE mill construction work or mill support functions;


business opportunities,

» Ongoing regular consultation,

» Community development opportunities such as education support, urban park land and recreational zone development,

» SEGX consider the establishment of a Community Reference Group within the mill community particularly during the construction, commissioning and operation phase, to enable meaningful and realistic community consultation framework to be prepared, and facilitate an ongoing interface with the community. The Community Reference Group would also enable mitigation or remediation measures to be explored and agreed with local representatives. It should be noted that the Community Reference Group should also include representatives of local business and industry.

8. Conclusion and Recommendations 8.1 Conclusions

8.1.1 Plantation Estate

Community surveys have highlighted concerns regarding some land leasing agreements, noting: (i) fair and prompt payments/compensation, (ii) lack of free, prior and informed consent of landowners, (iii) conflict over land tenure/ownership, (iv) employment opportunities, (v) transportation impacts (noise, dust, road conditions), and (v) protection

of workers’ rights. SEGX have recognised that their land agreement and rental systems require continual improvement, and in 2009 commenced a revision of their land rental process to improve certainty of land tenure and to provide a greater level of transparency to the rental process, including implementing a dispute reporting and intervention procedure in the form of a hotline and grievance channel, and seeking to develop local community sustainable development pilot projects. SEGX have also recognised that whilst it has implemented a number of community communication mechanisms, these are not well known and utilised by the rural communities potentially affected by the forestry operations.

Recommendations arising from this review to improve management of social impacts include:

» Work with the township government to encourage assessment of social issues when nominating lease land for SEGX consideration,

» Improvement of the contract assessment process to minimise land disputes

» Improvement in the negotiation process to ensure consultation and agreement with leaseholders rather than administrators

» Greater communication of contract agreement, pricing framework, payment frequency and payment methods to leaseholders to minimise the potential for corruption,

» Greater monitoring of negotiations and payments, possibly through an auditing process,

» Improved communication and communication tools as part of encouraging a long-term relationship with local communities,

» Encouraging local communities to report incidents or issues as part of a performance monitoring network,

» Examine opportunities to increase local workforce participation in plantation and other roles (dust suppression, security),

» Diversification of land use within SEGX plantations allowing farming of cash crops may be considered,

» Flexibility of SEGX’s requirement for ownership of land leasing rights to secure the fibre supply may be considered, allowing social land to remain under village control but still provide the required fibre base to SEGX,

» Provision of contract review service support for local villages to assist them understand the leasehold contract terms and condition,

» Regular stakeholder meetings (monthly or quarterly),

» Broadcast information via public speaker, this is a preferred means of information dissemination in many communities in Southern PRC,

» Post information on black-boards in village offices, and

» Disseminate information via leaflets to each household, presenting information in a simple easy to understand form.

8.1.2 SEGX Mill IntegrateThe initial establishment of the site resulted in resettlement of 1,236 villagers from the site to a new area approximately 2 km away. The resettlement, managed by Beihai City along with resettlement of villages from other areas of the Tieshangang Industrial Zone not related to SEGXs’ operations, included monetary compensation and an on-going allowance for each person affected in accordance with local government policy. Based on community surveys of the affected people, issues of inadequate compensation and lack of new employment opportunities have been identified.

Once SEGX has financially committed to the project, there will be further opportunity to undertake activities which may include:

» Preferential employment opportunities at the mill,

» Training to develop new skills including skills to access indirect related employment opportunities such as hospitality


AnnexesAnnex B: Program of the survey on social impact analysis in Beihai, Guangxi

Data Venue Activities in the field

4th of August a.m. Beijing Departure

Evening Nanning Arrival

5th of August Guangxi government, Department of forestry Request for support

6th of Augusta.m. SEGX Company Discussion and Planning for the mission

p.m. SEGX Company Planning

6th of August Zhakou Township of Hepu County in Beihai Group discussion in Zhakou Township

7th of August

a.m. Baisha Township of Hepu County in Beihai

Group discussion in Najiang Village

Group discussion in Najtan Village

p.m. Baisha Township of Hepu County in Beihai

Group discussion in Dongfeng Village

Group discussion in Langen Village

9th of August

a.m.Nanle Community of the resettlement in Tieshangang District of Beihai

Group discussion in Nanle Community in Tieshangang

p.m.SEGX Company and Shiwan Township of Hepu County in Beihai

Interview with the 2 contractors

Group discussion of the migrant workers

10th of August

a.m. Beihai Forestry Bureau Interview with director and staff

noon SEGX Company Interview with staff

p.m. Office of Behai Beibu Gulf Economic Zone Interview with the director

11th of August Guangxi Forest Group Interview with director and staff

12th of August Nanning Departure

9. References

CRAES, 2008: Stora Enso (Guangxi) Forest, Pulp paper Company Ltd 900000 T/a of Pulp, 900000 T/a of Paper and Paper Board Project, Raw Material Forest Base, Environmental Impact Assessment, prepared for Stora Enso (Guangxi) Pulp & Paper Co. Ltd., Chinese Research Academy of Environmental Sciences, 2008.


UNDP, 2006, Environmental and Social Impact Analysis - Stora Enso Plantation Project in Guangxi China, prepared for Stora Enso in February 2006.

UNDP-Hatfield, 2008, Independent Review of Environmental Assessments of Stora Enso’s Proposed Pulp, Paper and Board Mill Project and Associated Forest Plantations in Guangxi, China, prepared for United Nations Development Programme.

UNDP-Deng, 2009, Participatory Impact Assessment Report, Eucalyputs Plantation, UNDP Report.


Annex C: Checklist to the Villagers on Forestland Lease

1 Basic information(area of land rent out, the former use of land, property of land, hireling of the project, business opportunity, livelihood structure and its diversity)

2 Who made the decision of land rental in family? What is the gender division in wood planting?

3 What is the change in income?(the former income condition, the former planting pattern in forest and income, the present income condition and its source, the situation of working out)

4 What is your structure of livelihoods? What is the change in your quality of life?(structure of livelihoods, public service, planting in forest, change in income)

5 Land lease procedures, contract, rental and implementations

6 What was your preference? (if you were of your own accord to lease your land to company? Why or why not? If not, what made you agree latter)

7 Is there any land not rent, and what is it used for? Do you want to rent it?

8 What are the policies to support, and what kind of compensation is offered?

9 Do you have any knowledge about SEGX through some way? Do you know any influence from this company on the community in its project of planting trees?

10 What is the mode of land rental?(directly to the company, middleman, subcontracting)

11 How much is the rent and the way it is paid?

12 What are the approaches of cooperation?(farm by yourself, shareholding, land lease)

13What is the condition of employees(the chance of getting job, special training, salary, the kind of job, life guarantee, work time, accommodation condition, what to do in spare time, ability development, safety)

14 How are the outsiders getting along with the local villagers?

15 What are your present problems and development plan?

16 What are your suggestion and expectation?

Annex A: Basic information of interviewees of the focus group discussion in the new relocation community of Nanle Village

Name Gender Age Mobile phone Ethnic Group Education Level Family Size Time of

Male 45 Han High School 4 2008

Male 48 Han Middle School 6 2009








Female 30 Han Middle School 4 2007

Female 35 Han Primary School 4 2008


A. Concrete and brick B. Brick and wood C. Civil D. Simple

7. What do you use the compensation for? (multiple choice)

A. Production investment

B. Living expenses

C. Education expenses

D. Medical care expenses

E. New house building

F. Purchase of vehicle

G. Others: ___________(please write)

8. What do you want to do to recover production and normal life?(multiple choice)

A. Increase agricultural yeilds

B. Work out

C. Do business

D. Do transportation

E. Enlarge the scale of breeding

F. Work in the forest-pulp-paper factory

G. Be entitled with to urban basic living

H. Buy old-age insurance

I. Hope that village arranges land for tertiary industry

J. Receive special training

K. Others: ____________(please write)

9. What are the main kind of road in your village?

A. Mud B. Blacktop C. Gravel D. Line(related to the promotion of agricultural machinery)

E. Unpaved F. Others

10. What is the source of water in your house?

A. Well B. River C. Spring D. Simple tap water facility built by yourself E. Tubed tap water F. Others

11. What kind of fuel do you use? A. Firewood B. Biogas C. Electricity D. Coal gas

12. Is there any clinic in village? A. Yes B. No

13. Where will you go if you are sick?

A. Clinic in village B. Health center in town C. Hospital in city D. buy and take some medicine E. Others: ___________(please write)

14. Is there any primary school in the village now? A. Yes B. No

15. What are the positive impacts for you and village brought by the project? (multiple choice)

A. Improvement of traffic

Annex D: Questionnaire for the Immigrants after Resettlement We are investigators from China Agricultural University; we have a commission here to investigate the resettlement work of the immigrants in the Forest-Pulp-Paper Project in Beihai in order to help the relevant agencies with the resettlement work. We promise that the information we get from you will only be used in the external monitoring and evaluation report of the immigrants, and it will be under tight wraps. Thanks a lot for your cooperation!

1. Please fill in with your information

Name Gender Age Mobile Ethnic group Level of education Number of families

2. Household income in 2006 (RMB)

—Planting: ___________

—Breeding: ___________

—Cottage processing industry: ___________

—Service industry: ___________

—Salary(including working out): ___________

—Lease of property,share portfolios: __________

—Grant and loans: ___________

—Others: ___________

3. Household expenses in 2006(RMB)

—Planting(seeds, fertilizer, pesticide, electricity, gas): ___________

—Breeding(pups, feed stuff, medicine, electricity, gas): ______________

—Processing, transportation and marketing: ______________

—Food and electricity in daily life: __________

—Clothing: __________

—Education: __________

—Medical care: __________

—Traffic: __________

—Communication: __________

—Social contact: __________

—Others:__________

4. Before moving, the land you had was_________ mu, the number of houses was_________, the area of house was_________m²;

After moving, the land you have is_________ mu, the number of houses is_________, the area of house is_________ m².

The followings are choice questions, please tick “√” on the choice that fits you.

5. Which situation fits your family now?

A. Land was expropriated B. Houses were demolished C. Both of A and B

6. What is the structure of your house now?


Annex E: Interview Outline for Village Leaders on Forestland Land lease and Plantation

1. Respondent information

Name Gender Work unit Position Mobile

2. Interview content

The level and structure of local livelihood

The original land use and the proportion ( paddy field, dry land, forest land, desert land, etc)

The number and other conditions about tenant farmers; the type of lease (the proportion of collective and private land respectively)

Conditions about the lease intermediary agent and agency in rural areas (intermediaries of rent guarantee and sublease)

Is there potential conflict between local farmers and migrant workers?

The livelihood structures and land lease conditions of the rich and poor.

How to persuade farmers to lease land? How to keep land contiguous? What work has been carried out?

How to make decision to lease collective land to company? The conditions of income distribution and use. How to ensure the process of land lease transparent and public?

The collective land condition before it is leased. The land use which currently hasn’t been leased.

Rent payment method and process.

What is the cooperation mode of the forestation with company presently?

Is there forestry cooperation organization in community? The number of participants and development conditions.

How to communicate with SEGX? What about the information feedback mechanism?

What compensation policy does the community enjoy? What kind of measures does the SEGX take to help the community? Do these measures to take care of the disadvantaged groups? The detailed information about the carried activities.

What is the influence the project has on the household life and production? How to overcome?

Current problems

Development suggestions

1)

Group Interview Outline of Forest Migrant Workers

1 Basic information. (Which year did you enter the forest to work? How you got the job information? Why did you choose to work for SEGX? Do you want to continue to work here after the expiration date of job contract?)

2 How about the hiring situation? (Work intensity, job training, wages, welfares, type of work, social ensure, working hours, accommodation, leisure activities, job training, security, etc.)

3 How to fix the criteria of Wage? (by time or by the workload which you have done) Is your wage increasing year by year? How much?

B. Increased employment

C. Increase of household income

D. Promote regional economy

E. Narrow the gap between city and rural areas

F. Get compensation to build new houses

G. Improvement of living condition

H. Improvement of education condition

I. Improvement of sanitary condition

J. Improvement of drinking condition

K. Others(please write) ___________

16. What are the possible negative effects brought by the project? (multiple choice)

A. Farmland shrinking and decrease of income

B. Employment difficulty and hard life

C. Water conservancy was damaged

D. Roads in community are damaged

E. Environment pollution(noise, sewage, air)

F. Compensation for agriculture is not available

G. Others: _____________(please write)

17. Are you satisfied with the given standard of compensation of land expropriation and moving in this project?

A. Satisfactory B. Basically satisfactory C. Dissatisfactory

If you choose C, please give the reason why you choose: __________________.

18. What are the difficulties you meet after moving?

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19. What are your suggestion and requirement to the government and company?

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Annex F: Interview Outline of the leader of Forestry Bureau of Beihai, Guangxi

1. Information of respondents

Name Gender Department Position Mobile 2. Content of the interview

Questions Record

Overview of the project development (the stages of project, inspection, monitoring, feedback mechanism, progress, etc.)

The scope and range of forest land in planting and renting of SEGX(Written Material is better)

How much of forest land has been expropriated and rented in this project since 2008? How is the main distribution situation? How many households and population involved?

Please list the new policies and activities which have been adopted since 2008.

How about the final report and reporting materials of this project?

What cooperation has been implemented with SEGX during the process of project implementation? How? What about the result?

How to obtain the basic information of the community? Did you have baseline survey or not? Are there other development projects?

How to determine the standard of Land expropriation compensation? How to grant the compensation? What is the basis?

What is the conflict resolution mechanism? (How did the Beihai Forestry Bureau organize the work of contracting forest land? What were the biggest difficulties and challenges during this process? And how to deal with? In this process, did SEGX take some measures to help?)

How does Beihai Forestry Bureau treat the SEGX’s aim of sustainable development? In practice, can SEGX achieve this requirement?

How do you think about SEGX’s forest management system? Your suggestions for improvement.

What support measures for vulnerable groups do you have?

What are the problems and challenges now?

Please list your expectations and suggestions.3. Request for material

Statistic Yearbook of 2009

Rural Statistic Ledger of 2009 (Annual Report)

Rural Economic Statistics of 2009 (Table of Villages )

The detailed Implementation Rules of Land Expropriation and Relocation for the integrated Pulp and Paper Project, Beihai, Guangxin.

The Work Plan of Land Expropriation and Relocation for the integrated Pulp and Paper Project, Beihai, Guangxi.

The Work Plan of Relocation for the integrated Pulp and Paper Project, Beihai.

The Explanation on the Release of Tables of the average annual Output Value of all agricultural Land, from 2003 to 2006, Beihai Government.

The Notice on the Release of the average annual Output Value of all agricultural Land, from 2004 to 2006, Beihai Government.

The Reply for Regulating the Compensation Standard of Land Expropriation and Demolition of Beihai City, Beihai Government.

4 What extent did you know about SEGX after you work for the company? How do you evaluate the development concepts and management systems of SEGX?

5 How about the relationship between migrant workers and local people? Is there any conflict or not?

6 Do you have any accompanying family members? How to arrangement them? Talk about their living conditions. How often can you go back home for visiting relatives?

7 How to solve the labor disputes if it happened?

8 What is your future development plan?

9 What are your current problems and challenges?

10 Please list your expectations and suggestions.

2) The Outline of the Interview to the Leader of Forest Farm

1. Information of the Interviewees

Name Gender Workplace Position Mobile

2. Content of Interview

Questions Notes

How has the forest farm developed since 2008? How mant workers are there? Where is the benefit from? What is the income level of the formal workers?

Where did the forest lands come from (the area and proportion of the leased lands)?

How many households leased the lands? What is the type of them? (What is the proportion of collective lands and private lands respectively?)

What is the number of workers of diferent types (peasants and migrant workers)?

Where are the migrant workers from and what’s the difference between them and local peasants? What are the recruitment channels?

Is there any difference in treatment between the previous state forest farm workers and the migrant workers?

What are the living and working conditions of the forest farm workers (work intensity, employment training, income level, wellfare, living security, working hours, accomodation, recreation, capacity improvement, working security, ect.)?

How did the forest farm communicate with SEGX? Is there a special communication channel?

When SEGX rent the forest farm, how did the leaders and workers react? How to decide to lease forest land to the company? Has it affacted the previous workers’ live and work?

How much can you earn by leasing forest lands and sub forest lands? How to use the income?

How were the lands used before being leased? What is the function of the unleased lands?

Is the forest farm satisfied with the SEGX’s present policies? If not, why? Could you give us some suggestions?

What are the existing problems?

What are your suggestions


Annex G: Interview Outline for Managers in the Community of Resettlement

1. Interviewee information

Name Gender Enterprise Position Mobile2. Interview content

Questions Notes

When did the resettlement start? Scale? How to help the evacuees to settle down?

How to get resettlement expenses? How to use it?

Did the government have any preferential policy? Was it implemented?

Is the moving progress smooth? Is there anyone who doesn’t want to migrate? Why? How to resolve such problems? How is their life now?

Any aid for vulnerable group?

The number of individuals who have changed from agricultural to non-agricultural status? Influence on farmers?

The area of land expropriation? The number of demolition houses and family that effected?

How is migrate households’ life? Do they have jobs? What fields are they mainly engaged in? Do migrate households adapt to the new life now? Any difficulties? What measures have been taken by the community to help?(e.g. infrastructure, the qualities of the new house, skill training, custom, religion, environment, transportation)

The management of the resettlement village? Governance structure? The election process of cadres? How to coordinate? The way of information transfer?

What did SEGX do before the resettlement? Are you satisfied with it or not？

What measures did SEGX take for resettlement? Are these measures effective?

Compensation standards? Release procedure? Satisfaction? How to coordinate with the company for compensation?

Any expectations for SEGX?

Existing problems?

Development proposals?

Annex H: Checklist to Group Discussion for the Immigrants after Resettlement

1 Basic information(time of moving, the area of land, number of families moving)

2 What is your attitude to moving?(Did you want to move? What did you worry about? Did your rights have been protected?)

3 What is the moving process? (how did the villagers committee manage this? Does the relevant information open?)

4 What about the compensation?(the standard of compensation-- what about different kind of soil, the process of distribution, the way of depreciation, and are you satisfied with the amount)

5 What is the influence of moving?(infrastructure, living environment, social communication, religion, life style, income)

6 How do you communicate with SEGX?(the ways of communication before and after moving )

7 Is there any development in your living condition and livelihood (level of income, incomes structure, change of land, the condition of houses, the condition of employment, traffic transportation)

8 Do you know much about the resettlement policy and the standard of resettlement?(the approaches through which you get the information, the policy publicizing, persuasion, the degree of open)

9 What have been done for resettlement?(compensation, house building, change from rural to urban residents, basic living allowances, service export, vocational training) What has the community done?

10 What is your attitude to the work of resettlement and what will you do to reach recovery of life and production after moving?

11 What are the existing problems?(the environment of the living place, the quality of the newly built houses, the fairness of the compensation distribution given by village group)

12 What are your suggestion and expectation?

| Appendix A Complementary Assessment: Stakeholder Survey40

GHD

GHD House, 239 Adelaide Tce. Perth, WA 6004

P.O. Box 3106, Perth WA 6832

T: 61 8 6222 8222 F: 61 8 6222 8555 E: [email protected]

© GHD 2010


Document Status

Rev No. Author

Reviewer Approved for Issue

Name Signature Name Signature Date

Appendix BComplementary Assessment: Logistics and Transport Impact Assessment

Appendix B Transport Complementary Review and Assessment | 1| 2

Appendix B Transport Complementary Review and Assessment

Table of ContentsExecutive Summary 1

1. Introduction 3

1.1 Project Background 3

1.2 Mapping 3

2. Stora Enso in Guangxi 4

2.1 Management Structure 4

2.2 Stora Enso Sustainability Commitment 4

3. Resource 5

3.1 Plantation Distribution 5

3.2 Harvest Age and Quantity 5

4. Log Transportation 6

4.1 Roads 7

4.2 Railway 9

4.3 Barging 9

5. Proposed Truck Types 10

5.1 Small Trucks – Forest to Depot 10

5.2 Highway Trucks 10

6. Transport of Other Materials 12

7. Key Issues and Risks, and Proposed Management Strategies 13

7.1 Key Issues and Risks 13

7.2 Proposed Management Strategies 13

7.3 Monitoring 14

Cover Photo: Planting eucalyptus, Hong Shi Ding, China



| Appendix B Transport Complementary Review and Assessment Appendix B Transport Complementary Review and Assessment |2 3

Executive Summary

Stora Enso Guangxi (SEGX) has proposed the development of a Kraft pulp, paper and board mill and associated forestry plantation estate (collectively the project) in southern Guangxi Zhuang Autonomous Region (Guangxi), People’s Republic of China. The proposed scope of the project includes a Kraft pulp mill with 900,000 air-dry tonne per annum capacity

and a paper and board production mill with a capacity of 900,000 tonne per annum, supplied with a fibre based sourced from approximately 130,000 hectares of Eucalyptus plantation on a total land area of 160,000 hectares.

Within Guangxi, the plantation base will be in four Regions being, Beihai City, Qinlian, Yulin and Nanning.

As part of the Summary Integrated Environmental and Social Impact Analysis Report (GHD, 2012), this complementary assessment forms a Logistic and Transport Impact Assessment Annex, and assesses the potential impacts resulting from the transportation of logs from the plantation forest areas to the proposed pulp mill as well as other related transport activities.

The main form of transportation will be by truck, however railway transport and barge transport are also being investigated. Delivery of up to 10,000 m3 of logs/day to the pulp mill site will result in more than 300 truck movements per day. The transport of logs from the forest to the pulp mill will be on four road types:

» Highways;

» Public Access Roads;

» Forest Roads (these can often be public roads); and

» Plantation Roads.

It is expected that there will be no significant environmental or social impacts resulting from trucks using the highways. However it is anticipated that there is likely to be impacts on the community by trucks using the narrow and often poorly constructed access and forest roads. It is likely that the main impacts will be safety, dust and noise.

To minimise the impact of the vehicular transport operation, SEGX plans to mainly use small farm trucks to transport logs to a depot site, and then reload them onto larger trucks for transport to the pulp mill.

Other transportation to and within the Tieshangang Industrial District will occur on highways or dedicated internal roads within the Industrial District. Impacts on these road networks are expected to be minor.

It has been observed that Stora Enso’s Sustainability Department, which is responsible for Environment, Sustainability Communication and Social Environment, is proactive and has resources and strategies in place to minimise the social and environmental impacts of Stora Enso’s log transport and harvesting operations.

Stora Enso is committed to community engagement and the employment of local people. A “hotline” is in place where the public can contact Stora Enso 24 hours a day, 7 days a week to express their concerns.

During a 2010 site visit it was observed that SEGX is committed to environmentally and socially sound operations and is taking steps to have management systems such as ISO9001, ISO14001 and Forest Stewardship Council (FSC) certification in place by the end of 2011.

Stora Enso is also committed to training their staff as well as contractors and their employees to ensure that all people engaged in the forestry operations understand what their responsibilities are in regards to minimising safety risk as well as environmental and social impact.

The decision as to what type of trucks will be used and the location of depots has not been finalised at this stage, however Stora Enso is aware of the operating restrictions and is actively investigating the truck transport options to ensure that the best and most efficient transport systems are used.

Based on an understanding of Stora Enso’s proposed management strategies, it is recommended that such practices will significantly reduce potential social and environmental issues associated with forestry activities, and they are in line with or exceed similar practices elsewhere in Asia.

1. Introduction1.1 Project Background

Stora Enso is a global company producing fine papers, newsprint, book and magazine paper, consumer board, industrial packaging and wood products. The SE is a public company and is registered on the stock exchanges in Stockholm and Helsinki. The Group has 27,000 employees working in 88 production facilities in 35 countries.

In China, Stora Enso currently operates a fine paper mill at Suzhou and a newsprint and magazine paper mill at Dawang. In 2002, Stora Enso established Stora Enso Guangxi (SEGX) with headquarters in Nanning and operational headquarters for plantation establishment and management in Hepu.

SEGX plans to establish 160,000 ha of forestry base which will be mainly Eucalyptus cones. The final plan is to build an integrated pulp and paper mill in the Tieshangang Industrial District near Beihai City which will process the wood from the plantations and produce 900,000 ADt/yr of Bleached Hardwood Kraft Pulp (BHKP). A plantation estate of 130,000 ha is required to supply the pulp mill.

The largest areas of forestry base are on State Forest Farms in four regions, Beihai City, Qinlian, Yulin and Nanning .

This report supplements the Summary Integrated Environmental and Social Impact Analysis Report (GHD, 2012), and seeks to assess the potential impacts associated with the transportation of logs from the forest, and also includes the delivery of fertiliser and limestone to the plantation areas and consideration of transport impacts within the Tieshangang Industrial District. This report focuses on the log transport, particularly within the forest estate, and on the smaller road networks that service these areas. Experience on similar forestry projects elsewhere in Asia has shown that these are the areas of greatest potential transport impact. Once transporting vehicles are utilising major road networks, issues are not likely to be significant.

Review Process

The process for this review has been completed in two stages, these being:

» A review of past reports completed in February 2006 and April 2008; and

» A visit in June 2010, providing updated information from SEGX management and a visit to forest sites to develop an understanding of the potential impacts that forestry operations could have on the environment and the community.

Although the area and the activity that was observed was small and the visit short, a reasonable understanding of the project and what social and environmental impacts could potentially result from the project was developed.

1.2 MappingAs a foreign company operating in China, Stora Enso has restrictions as to the mapping and spatial data it can access and reproduce. This report therefore contains minimal mapping of plantation reserves and transport routes. Stora Enso is developing a land data management system which includes collection of geophysical and spatial data for their forest plantations. This will be used to develop land and resource management strategies for future management of the plantation estates and associated infrastructure, including roads.


2. Stora Enso in Guangxi2.1 Management Structure

The project has an operational office in Hepu, near the proposed pulp mill site in the Tieshangang Industrial area, as well as 4 Regional offices and 14 District offices.

The District management report to the Regional Manager, who in turn reports to the Managing Director. Also reporting to the Managing Director is: the Legal Department, Government Liaison, Land Management, Wood Production, Wood Supply, Human Resources & Administration, Finance & Internet Technology and Sustainability.

The plantation operation did in 2009 have 750 direct employees as well as a contractor work force of 2,500.

The plan is that all work such as planting, plantation management, road works, harvesting and transport will be done under a contract system. Contractors are currently being trained, with 10 having been trained in business management to date.

2.2 Stora Enso Sustainability CommitmentStora Enso is committed to forestry operational excellence and has implemented, or plans to implement the following:

» Produce integrated operational site plans that are adapted to specific site conditions;

» Use International management systems such as ISO 9001, ISO 14001 and attain forest certification under the FSC scheme;

» Change land acquisition procedures to improve legal procedures and have a target to distribute the wealth more fairly;

» Have a tree breeding program to target tree growth, pulp yield, typhoon and pest resistance;

» Debark the trees in the field thereby leaving nutrient behind for future crops of trees and improving the soil characteristics;

» Have a “No Burn” policy for all forestry operations;

» Have site specific fertiliser regimes to mitigate nutrient losses; and

» Provide training for contractors to ensure that they have a sound understanding of business principles as well as a working knowledge of Stora Enso’s requirements in terms of occupational health and safety, the environment and social responsibilities.

It is the opinion of the author that Stora Enso is committed to plantation management and operational excellence. The Company has very good management systems in place and has set targets to improve these systems.

Stora Enso has trained 10 contractors thus far, and has plans for further training of contractors in business management, health and safety and environmental awareness.

It was observed that the following systems are in place and are being utilised by Stora Enso:

» A Safety Management System compliant with ISO9001;

» An Environmental Management System compliant with ISO14001;

» A Standard Operation Procedures Manual for most tasks;

» The Sustainability Department appears to be effective and dedicated;

» A Dispute Resolution Policy and Procedure that deals with social issues quickly and effectively; and

A comprehensive GIS system is in place to monitor and make the plantations and forestry operations more efficient.

3. Resource

The resource for the project is primarily Eucalyptus hybrids with 20% of the area planted with other species such as pine and Acacia. It is a requirement under SEGX forestry operation guidelines that 20% of the land area be planted with species other than Eucalyptus to break up a monoculture planting.

As of August 2010, SEGX had contracted a total of 84,600 ha of land with an additional 41,200 ha offered by city governments, a total of 125,800 ha. Stora Enso intents to reach 120,000 ha fibre base by mill start-up.

3.1 Plantation DistributionThe wood flow for the pulp mill initially will come from plantations which are in four Regions:

» Beihai - which is the closest region, just north of the mill site;

» Qinlian - which is north and west of the mill site;

» Nanning - northwest of the mill site; and


The two closest regions, Beihai and Qinlian, will account for 50% of the wood requirement and Nanning and Yulin will each account for 25%.

Within the four Regions there are 15 Districts. The plantations are not in large consolidated areas, they tend to be scattered throughout the Districts and Regions.

Stora Enso is not able to access topographical and infrastructure mapping data within China. As such, the have collated some publically available spatial data which they complement with internal data gathering. As such, it is not possible within this report to present detailed mapping of plantation and road networks.

3.2 Harvest Age and QuantityThe objective is to harvest 3.4 million m3/a of the plantation Eucalyptus trees when they are six years of age. Given the growth rate, basic density and pulp yield, Stora Enso research has shown that this will give the maximum fibre yield per hectare.


4. Log Transportation

The pulp mill will use 3.4 million m3/a of solid wood/year, requiring up to 10,000 m3/day to be delivered to the mill site at Tieshangang from the four regions, Beihai, Qinlian, Yulin and Nanning. The total fibre base delivery, along with transport of products and other raw materials will amount to over 4 million m3/a and a total number of passages (in and out of the

mill site) per day of around 1000 for the pulp mill operations. The expected distribution of passages is shown in Table 1.

Table 1 Expected distribution of passagesItem Single pass travelProduct transport (pulp) 100Wood trucks 250-300Chemical trucks 10-15Waste transports 20-30Fuel oil trucks (á 30 t) 5Other raw materials, maintenance equipment 5-10

Exported and imported material flows is depicted in Figure 1, and will be channelled through a logistics centre in the nearby Tieshangang port. The logistics centre will act as a hub for large part of the mill’s cargo flows. All pulp will be transported to the logistics centre to be stored there. The proposed logistics centre would be located somewhere between 5 and 8 km from the mill. Facilities in the logistics centre in the port would be run and equipment owned by an outside operator.

sea land

pulp by truck (b/b)

pulp by rail (in container)

pulp in break bulk

DE

DIC

ATE

DB

ER

TH

pulp in container Pulp in containers

Pulp in break bulk

CO

MM

EN

BE

RTHwood logs/chips wood logs/chips

Pulp Mill

LCw

areh

ouse

Oil

Forest

Pulp wood depots

Round wood

Chemicals

residuals, waste

Figure 1 Schematic Diagram of Mill Logistics

The average transport distance from plantation to the mill site for the estate is 170 km. Because many of the public and forest roads will be narrow and not suitable for the use of large truck’s SE intends to use small farm type trucks, with a payload capacity of 6 - 8 tonnes, to transport logs from the forest to depots where the logs will be transferred onto a large truck. The logs will then be double-handled, and transferred onto larger trucks to be delivered to the SEGX mill. It is considered that the use of the smaller trucks on the narrow public roads will minimise the damage to the roads, reduce the social impact and make the transportation task safer.

SE calculates that approximately 15% of the annual supply of wood to the pulp mill can be delivered directly from the forest to the mill on large trucks and 85% of the wood will delivered by small trucks to depots, and then by large trucks from the depots to the pulp mill.

All transport will be by contracts, however all contractors will have to work to SEGX requirements which includes health and safety, environment, social, labour conditions and legal requirements such as the over loading of trucks.

The wood flow for the SEGX Mill will initially come from plantations in four Prefectures:

» Beihai, which is the closest region, just north of the mill site;

» Qinlian, which is north and west of the mill site;

» Nanning, northwest of the mill site; and


The two closest regions, Beihai and Qinlian, will account for approximately 50% of the wood requirement and Nanning and Yulin will each account for approximately 25%.

Within the 4 regions there are 15 districts. The plantations are not located in large consolidated areas, rather they tend to be scattered throughout the regions and districts.

Even with the concept of using depots and small trucks, it is suggested that the use of narrow public roads will have a potential social impact and will be the catalyst for most of the issues involved in transporting wood to the pulp mill. The following potential issues have been identified:

» Even with small trucks being used on the narrow public roads there will be a safety issue if truck drivers are not vigilant and don’t drive at a safe speed, especially when driving through villages.

» Many of the public roads are of a poor construction standard so at times even the small trucks could damage the road and interfere with local traffic. This could upset the local communities.

» During dry periods, dust will be an issue around villages and at the depot sites.

» At times there will be trucks working 24 hours each day, so noise will be an issue around villages and around the depot site.

Mitigation Strategies

» It is important that all contractors are trained so that they have an understanding of Stora Enso health and safety, social and legal requirements.

» The most important way to deal with the local communities is to communicate on a regular basis so that, if there are any issues, they are dealt with quickly. The Stora Enso “Hotline” is one positive mechanism for communication, but local people should also be briefed on Stora Enso plans before the operations start.

» If roads are damaged they must be repaired quickly so that the disruption to local traffic is minimised.

» If dust becomes an issue around villages or around a depot, the area should be watered down to minimise the generation of dust. Contracting local people to implement dust management has worked in other areas.

» Employ as many local people as possible so that they become a part of the Company.

Trucks must be coordinated not only for transport efficiency but to ensure that trucks do not “bunch up” in areas, causing safety issues. The use of a truck dispatcher and Global Positioning Systems (GSP) on trucks will assist in the control of trucks.

4.1 RoadsThe roads that will be used in the project can be put into four categories; highways, access roads, forest roads and plantation roads. As detailed previously, Stora Enso do not have access to mapping information for local road networks and are consequently unable to reproduce accurate maps of plantation, forest and access roads.

For the first 3 years of harvesting, Stora Enso estimate that approximately 600 km of access roads and 400-600 km of forest roads will be required (Figure 2 and 3).


Figure 2 Road Specifications

Figure 3 Plantation Road, Forestry Road and Village Road (respectively)

4.1.1 Highways

The highways in Guangxi are of a very high quality and in many cases are four lane concrete highways. There is currently a big works program proposed to further improve the highway system in Guangxi, and it is anticipated that by the time the Stora Enso pulp mill is completed, all highways that will be used by the project will be of a very high standard.

4.1.2 Access Roads

Access roads are public roads of a varying standard. These roads provide access not only to the plantation forest areas, but also to villages and farms.

As mentioned previously, most of these roads are not suitable for the use of large trucks and it is intended that if these roads cannot be upgraded, small farm trucks carrying 6 - 8 tonnes will be used to transport logs to a depot where the logs will be reloaded onto large trucks.

As many of these roads go through or near villages it is anticipated that there will be social issues associated with dust, noise, health and safety.

The Stora Enso Sustainability Department anticipate that the use of these roads by log trucks will be one of the biggest social issues they will have to deal with.

Stora Enso, through it’s Sustainability Department, plans to be proactive in dealing with community concerns that arise from log trucks using public roads. This requires communicating with the community to inform them of Stora Enso’s plans and managing community concerns.

4.1.3 Forest Roads

Forest roads are roads that go through the plantation forest areas and can also be public roads. Stora Enso plan to upgrade these roads as per the standard outlined in Figure 2..

As these roads are used by the public it is anticipated that there could be impacts on the community from dust, noise, health and safety.

4.1.4 Plantation Roads

Plantation roads are small roads that are constructed to access particular areas of a plantation (i.e they are not public roads). These roads are simple, not all weather roads and are constructed for plantation tending and protection.

The author is of the same opinion as Stora Enso that Access Roads and Forest Roads have the potential for social impacts. The author is of the opinion that Stora Enso has the experience and capacity to deal with the issues through it’s Sustainability management practices.

4.2 RailwayIt has been estimated by SEGX that up to 25% of the wood for the pulp mill could ultimately be delivered by rail once the rail line is completed to the pulp mill site at Tieshangang. This form of transportation is now being investigated by SEGX, however the investigation to date has found a number of potential issues, including: (i) there is limited space at railway depot sites for storing and handling logs, (ii) large quantities of coal will be transported by railway so there is a chance that the logs could become contaminated by coal dust, (ii) the railway companies do not currently have the right type of wagons for the transport of logs; and (iii) the logs have to be “double handled” thereby adding costs. Due to high risk in rail transportation, timeliness, cleanliness, access to depots SE has decided to put this option on hold.

4.3 BargingThere is potential that some wood could be delivered to the SEGX mill at the Tieshangang Industrial Zone by barge using rivers and the sea as the transportation passages. The potential of using barges to transport logs to the SEGX mill site is currently being investigated by SEGX, however it may not be a viable option due to shallow waters and bridges that are too low.


5. Proposed Truck TypesStora Enso is a global pulp and paper company and has considerable experience and knowledge in the handling and transporting large volumes of logs and other materials.

Although a final decision has not been made on what type of trucks will be used for the project, there has been a considerable amount of discussion and investigation to find the best type of truck for this project.

Because many of the public roads are narrow and not suitable for large trucks, it is most likely that small farm trucks will be used in most cases to deliver logs from the forest to depots near the highway. The logs will then be double-handled, and transferred onto a larger truck to be delivered from the depots to the pulp mill.

The use of the smaller trucks on the narrow public roads will minimise the damage to the roads, reduce the social impact and make the transport task safer.

5.1 Small Trucks – Forest to DepotThese trucks are common in Guangxi and there are a number of makes of this type of truck. As these trucks are very common, they are more likely to be accepted by the community on the narrow roads, rather than larger trucks. These trucks are capable of carrying 8 tonnes of logs (Figure 4).

Figure 4 Farm Truck Specifications

5.2 Highway TrucksStora Enso is considering a number of options for the large highway trucks. These will primarily be used to transport logs from the depots to the pulp mill, however where possible they will be used to transport logs directly from the forest to the pulp mill. Transporting directly to the pulp mill from the forest will be cheaper as there is no double handling as is necessary at a depot.

Two options that are being considered by Stora Enso are semi trailers type trucks and 6x4 trucks. These trucks have a payload of 18 – 35 tonnes depending on the configuration of the truck and the length of the logs (Figure 5 and 6).

Figure 5 6 x 4 Forest Truck Specifications

Figure 6 Semitrailer Specifications

The types of trucks being considered for the project are trucks that are common in the forestry industry around the world. The type of trucks used for each phase of the transportation task will depend on the standard of road, the potential impact of that truck on the road, and the potential impact of that truck on the community.

The author agrees with the concept proposed by Stora Enso to use small farm trucks, where necessary, to deliver logs to a depot. This will reduce the risk of large trucks damaging the roads and will minimise the social impact of the transport operations.


6. Transport of Other Materials

Other materials that will be transported over the road system to the plantation areas are:

» Fertiliser typically applied at the rate of 1.37 t/ha;

» Limestone typically applied at the rate of 1.50 t/ha; and

» Seedlings at the rate 1,250 seedlings/ha.

It is proposed that these materials will be transported from various sites to the plantations using small farm type trucks. Of these materials, seedling transport has the least impact on the road networks as the loads are relatively light and will not contribute to significant road impacts.

The total tonnage/year of these materials is estimated to be up to 60,000 tonnes.

It is the opinion of the author that the transport of these materials to the forest areas should not have a considerable social or environmental impact providing truck drivers are adequately trained and drive safely.

The plantations are spread out over a considerable area and as such, transport activity will not be concentrated and the impact on any one location will consequently be slight. Activities associated with replanting and fertilising for particular plantations will occur in specific campaigns so that any associated transport activities will not be continuous but rather will occur infrequently.

7. Key Issues and Risks, and Proposed Management Strategies and Monitoring

7.1 Key Issues and RisksThe key issues for this project involve community interaction and the effect of the log transportation on the people who live in the impact areas. Stora Enso is committed to facilitating community feedback in order to run a low impact operation. There are a variety of issues involved in the transportation of logs to the pulp mill. These include:

» Safety

– There are a number of narrow, badly made roads that the trucks must traverse in order to get the logs to the pulp mill.

– Wear and tear of existing roads may result in degradation and increase likelihood of accidents.

– Log transport will be by contractors and there is a risk that they may not adhere to Stora Enso’s regulations involving safe driving behaviour and road speed limits.

– Congestion may result from too many trucks on the road, resulting in inconvenience to local road users and even road accidents.

– Overloading of trucks may result in accidents, break downs or logs falling off trucks.

» Dust

– Dust may become a significant problem when trucks are travelling through villages or areas where there are unsealed roads and large populations, resulting in problems with the local communities.

– Dust may also be a sign of deteriorating roads and soil structure in some areas, especially in dry months.

» Noise

– Noise may be a significant problem due to the anticipated high numbers of trucks travelling through village areas.

– Trucks will be travelling 24 hours a day, which may result in resentment from the local communities when their sleeping patterns are disturbed.

7.2 Proposed Management StrategiesStora Enso has taken these potential transport issues and risks into account when planning this project, and a number of mitigation strategies have been put into place as outlined below:

» Safety

– Roads are to be repaired immediately if damage has made an area unsafe. Small trucks are to be used to transport logs to depot locations to prevent damage and congestion by larger vehicles. The larger trucks would then transport the logs from the depots to the mill.

– Wear and tear of local roads will need to be monitored and community members should be encouraged to notify Stora Enso if significant degradation occurs.

– All contractors are to go through appropriate training to ensure understanding of Stora Enso’s policies regarding safe road use and speed limit adherence. Accordingly, drivers may need periodic reviews to ensure they are complying with the rules. Community members should also be encouraged to notify Stora Enso if any trucks are not operating in a responsible manner.

– All trucks must be coordinated from a local truck dispatcher via GPS to ensure that trucks are on time, and not causing congestion. This may also assist with driver safety, prevent theft and ensure drivers are not speeding.

– Trucks are to be weighed upon entering the mill to ensure they are not overloaded and contractors made aware of the significance of overloading the vehicles.

» Dust

– Where required, roads must be watered down to prevent dust becoming a problem, especially in dryer months.

» Noise

– Adequate spacing of trucks should assist with keeping noise levels to a minimum, especially in village areas.

– Community consultation will be encouraged to ensure locals can contact Stora Enso if noise or other problems arise.


Stora Enso has established a hotline for this purpose and advertises its services to the local communities. In addition, if local people are employed by the mill or by Stora Enso’s contractors, they are less likely to be bothered by noise or other nuisance factors.

7.3 MonitoringRegular monitoring should be conducted by Stora Enso to ensure compliance with its values and regulations. Drivers should be monitored by their supervisors, with anonymous reviews or surveys conducted regularly to ensure drivers are driving safely and according to speed limits. Weigh bridges can be used to ensure trucks are not overloaded and prevent both accidents and unnecessary wear on vehicles.

In addition, drivers must be aware of their responsibility to record incidences, so that the number of road incidences can be monitored and safety measures implemented if problems do arise. All trucks should be regularly serviced and vehicle checks conducted by each staff member at the start of their shift before they take responsibility for their vehicle for the day.

Monthly inspections should be conducted by survey crews to determine the condition of the roads, and the levels of dust and road degradation. It may also be necessary to install dust stations to be monitored and recorded in order to identify peak periods of dust formation. Likewise, regular reviews of noise levels in local villages should be conducted to identify peak noise times and how this impacts the local communities.

The communities can be empowered to report unacceptable transport activities to Stora Enso. Trucks could be numbered to facilitate identification of individual drivers. In addition, the community could also be asked to report commendable or courteous drivers

GHD

Level 2, 102 Cameron Street Launceston Tasmania 7250 T: (03) 6332 5500 F: (03) 6332 5555 E: [email protected]

© GHD 2010


Document Status

Rev No.

AuthorReviewer Approved for Issue


0Stephen Manson

B Skarratt B Skarratt 20/08/2010

FinalStephen Manson

B Skarratt / D.Todd

* D.Todd *

Appendix CComplementary Assessment: Water Quality Review and Assessment

Appendix C Complementary Assessment: Water Quality Review and Assessment | 1| 2

Appendix C Complementary Assessment: Water Quality Review and Assessment

Contents

1. Introduction 3

1.1 Water Quality Sections 3

1.2 Mistranslations 4

1.3 Recommendations 4

2. Review of Past Water Quality Assessments 5

2.1 Background 5

2.2 Effluent 5

2.3 Background Water Quality 7

3. Environmental Impact Assessment: Discharge Modelling 13

3.1 Background 13

3.2 Hypothesis 13

3.3 Scenarios 13

3.4 Parameters 13

3.5 Results 13

3.6 Conclusions 14

4. Environmental Monitoring Program 15

4.1 Existing Water Quality Monitoring Program 15

4.2 Proposed Water Quality Monitoring Program and Recommendations 16

Cover Photo: Planting eucalyptus, Hong Shi Ding, China



| Appendix C Complementary Assessment: Water Quality Review and Assessment Appendix C Complementary Assessment: Water Quality Review and Assessment |2 3

Table Index

Table 1 Seawater Quality standard as reproduced from RIEPG, 2008 6

Table 2 Effluent standards for new pulp, paper and board production, GB3544-2008. 7

Table 3 Effluent quality for different phases of the project 7

Table 4 Parameters monitored in the various studies 12

Table 5 GB3097-1997 Sea water quality standards (RIEPG, 2008) 14

Table 6 Monitoring Campaigns Undertaken 15

Table 7 Summary of RIEPG (2008) Water Quality Monitoring – Ambient Environment and Discharge* 20

Table 8 Proposed baseline Water Quality Monitoring, Ambient Pre-operation 24

Table 9 Indicative core parameters to be monitored in discharge (IFC (2007), IPPC (2001), RPDC (2004)) 25

Figure Index Figure 1 Layout of observation stations of water quality and sediments (SCSIO, 2010) 12

1. Introduction

This report provides a review of the water quality impact assessment of the Environmental Impact Assessment report (RIEPG, 2008) for the proposed pulp and paper plant in Guangxi, to be built and operated by Stora Enso. Gaps identified in the approach and the data analyses were reported. A Water Quality Monitoring Programme, which aims at defining

ambient water quality prior to the plant construction and after operation, has been proposed.

This review is structured into three sections:

Chapter 2 Review of effluent characteristics and background water quality

Chapter 3 Review of the Environmental Impact Analysis using a discharge model

Chapter 4 Review and modification to the proposed EMP

1.1 Water Quality SectionsBackground water quality is addressed in different sections of several reports. These are listed below:

» UNDP-Hatfield, 2008: Independent Review of Environmental Assessments of Stora Enso’s Proposed Pulp, Paper and Board Mill Project and Associated Forest Plantations in Guangxi, China, prepared by Hatfield Consultants, 2008.(Environmental impact analysis (discharge modelling) Section 3.4)

» RIEPG, 2008: Environmental Impact Report. The 900,000 ton pulp and 900,000 ton paper and cardboard project of Stora Enso (Guangxi) Pulp and Paper Co. Ltd. Research Institute of Environmental Protection of Guangxi Zhuang Autonomous Region, October 2008. (Effluent characteristics discussed in section 3.4 AOX emission in bleached wastewater in section 3.4.6.1, Dioxin emission in bleached wastewater in section 3.4.6.2, Background water quality is discussed in section 4.2, Monitoring program is discussed in Section 21, Impacts on the environment discussed in Section 9)

» SCSIO, 2010: Stora Enso (Guangxi) Forestry-Pulp-paper Integrated Project, Special report – Survey and Evaluation of the Marine Environment, Prepared by South China Sea Institute of Oceanology of Chinese Academy of Sciences, July 2010

» Stora Enso, 2010, “Guangxi, Mill project study -Technical Description, Pulp Mill design”, Compilation based on material from Tiger Project Feasibility Study made for the UNDP, Integrated ESIA project, June 2010 (Effluent characteristics discussed in section 2.3.2)

» Study Report on Impact of Stora Enso Beihai project on Ecological Environment of Beibu Gulf. Prepared by South China Sea Institute of Oceanology of Chinese Academy of Sciences. November 2007 (Section 3.1)

» Stora Enso, 2009, Annual report, Corporate Governance Report, and Sustainability Report

» TRIWTE, 2009: Tianjin Research Institute of Water Transport Engineering, Ministry of Communications, 2009. Detailed Study on Recommended Effluent Discharge Point B3 of Stora Enso Guangxi Forestry, Pulp & Paper Project (Draft).

» Ministry of Environmental Protection, 2008, Approval of the Environmental Impact report no 491

» Ministry of Water Resources, March 2008, Water and Soil Conservation Report of Mill Site, Approval Reply Letter

» Bell Bay Pulp Mill Draft Integrated Impact Statement Volume 1

» Chinese Research Academy of Environmental Sciences, 2008, Stora Enso (Guangxi) Forest, Pulp paper Company Ltd 900000T/a of Pulp, 900000T/a of Paper and Paper Board Project, Raw Material Forest Base, Environmental Impact Assessment

Several water quality guidelines have been used in this review:

» RPDC, 2004. Recommended Environmental Emission Limit Guidelines for any New Bleached Kraft Pulp Mill in Tasmania, Volume 2. Published by Resource Planning and Development Commission.

The RPDC guidelines were prepared by the Tasmanian government to provide guidance for new Pulp and paper mill project. These guidelines provide environmental emission limits to cover all accepted technologies described in the guidelines, or their equivalent.

The objectives of these guidelines are:

(a) to ensure protection of the environment from emissions generated by any new bleached eucalypt kraft (BEK) pulp mills; and


(b) to clarify for Tasmanian government agencies, industry and potential investors the minimum environmental emission limit requirements for any new BEK pulp mill in Tasmania.

» ANZECC & ARMCANZ, 2000. Australia and New Zealand Fresh and Marine Water Quality. Published by Australia and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand.

These guidelines aim at providing guidance on achieving the sustainable use of water resources by protecting and enhancing their quality while maintaining economic and social development. They are a relevant source of information on how to assess water quality backgrounds by developing the correct monitoring plan and using the correct toxicity testing.

1.2 MistranslationsSeveral mistranslations and misunderstandings have been noted during this review. The following have been assumed:

» “active phosphate” for “soluble reactive phosphorus”» “petroleum” for “oil and grease” » “Sewage” for “discharge” » “AOx” for “AOX”

1.3 RecommendationsThis report contains a number of recommendations from the author based on the review of RIEPG (2008) and assessment typically undertaken in assessing the environmental impacts of a major marine discharge. These recommendations could be implemented by Stora Enso as part of the next phase of the project to provide baseline information and to inform detailed design and operational management practices.

2. Review of Past Water Quality Assessments2.1 Background

RIEPG (2008) provides the primary assessment of the potential impact of effluent discharge on the receiving marine environment. For this purpose it is critical to:

» Have a good understanding of the characteristics of the effluent to be discharged so that its constituents can be properly monitored and its toxicity assessed; and

» Have strong monitoring background data that takes into consideration the natural background, the seasonal variations and the limitation of analytical methods.

Through the study, 2 types of guidelines need to be considered:

» Seawater quality; and

» Effluent.

The guidelines used in RIEPG (2008) for seawater quality are the GB3097-97 Seawater Quality Standard listed in Table 1.5-2 of RIEPG (2008). The different classes are specific to different water quality targets that need to be achieved depending on the area.

Table 1 Seawater Quality standard as reproduced from (RIEPG, 2008)Class I Class II Class III Class IV

pH value 7.8-8.5 7.8-8.5 6.8-8.8 6.8-8.8

DO 6 5 4 3

CODMn (mg/L) 2 3 4 5

Inorganic nitrogen (mg/L) 0.20 0.30 0.4 0.5

Labile phosphate (mg/L) 0.015 0.03 0.03 0.045

Petroleum (mg/L) 0.05 0.05 0.3 0.5

Cyanide (mg/L) 0.005 0.005 0.1 0.2

Volatile Hydroxybenzene (mg/L) 0.005 0.005 0.01 0.05

The guideline for the effluent standard is the Standard GB3544-2008 provided in Table 7-1 of the Stora Enso Guangxi, June 2010 report and is reproduced in Table 2, below.

Table 2 Effluent standards for new pulp, paper and board production, GB3544-2008.

Mill Type Pulp millsIntegrated pulp and paper mills

Paper millsMonitoring position of Pollutants Discharged

1 pH 6-9 6-9 6-9

Total wastewater outfall of the mill

2 Colour (times dilution) 50 50 503 SS (mg/L) 50 30 304 BOD5_(mg/L) 20 20 205 CODCr (mg/L) 100 90 806 NH3 (mg/L) 12 8 87 Ntot (mg/L) 15 12 128 Ptot (mg/L) 0.8 0.8 0.89 AOX (mg/L) 12 12 12 Wastewater outfall of workshops or production

facilities10 Dioxin (pgTEQ/L) 30 30 30

11Special discharge effluent flow, Ton/Ton (Pulp)

50 40 20Consistence between water distribution measurement and monitoring location of pollutants

2.2 Effluent

2.2.1 Characteristics of the Effluent

Information on the predicted characteristics of the effluent is given in Section 3.4, Table 3.4-5 of RIEPG(2008). The list of analytes considered in RIEPG(2008) corresponds to the one provided by the standard GB3544-2008 (Effluent standards for new pulp, paper and board production), and predicted discharge values are quoted as being systematically lower to those recommended by the standard.

Further information is provided in the Technical Description, Pulp Mill design (2010), 4th table in section 2.3.2.


Table 3 Effluent quality for different phases of the project

Analyte Phase 1 Phase 2 Phase 3

Tertiary treated effluent

(Technical Description, 2010)

Guideline value-

GB3544-2008

Integrated pulp and paper mills

1 pH 6-9 6.9 6.9 6.5-8 6-92 Colour (times dilution) <50 <50 <50 ≤50 503 SS (mg/L) <50 <30 <30 26.6 304 BOD5_(mg/L) <20 <20 <20 6.5 205 CODCr (mg/L) <100 <90 <90 <85 906 NH3 (mg/L) <6 <6 <6 87 Ntot (mg/L) <8 <8 <8 3 128 Ptot (mg/L) <0.8 <0.8 <0.8 0.3 0.89 AOX (mg/L) <5 <4 <3.5 <3 1210 Dioxin (pgTEQ/L) <6.19 <5.03 <4.32 30

11

Special discharge

effluent flow, Ton/Ton

(Pulp)

40

Chlorate <3.5

2.2.2 Potential Organic Compounds in the Effluent

The pulp and paper industry is renowned for the extensive number of organic compounds that can be potentially present in the effluent, due to the resin breakdown, the addition of surfactants or other chemicals usage such as ClO2 during the process. The improvement of the bleaching process and the treatment of the effluent will decrease the likelihood of some of the most well known compounds (such as dioxin and furans) entering the marine environment.

RIEPG (2008) report discusses briefly the presence of AOX and dioxins in bleached wastewater in sections 3.4.6.1 and 3.4.6.2 but no mention is made of other compounds potentially present. This should still be discussed.

Potential organic compounds present in the effluent can be broken down in the following categories:

» Organic acids, including: chloroacetic acids, resin acids (for pine only) and fatty acids;

» Natural chlorinated phenols;

» Chlorophenols, chlorinated guaiacols and catechols;

» Sterols;

» Miscellaneous aromatic compounds;

» Polychlorinated aromatic compounds; and

» Miscellaneous compounds including hydrocarbons, aldehydes, ketones and chlorinated hydrocarbons.

As an indication, the RPDC guidelines (2004) recommend the monitoring of some additional compound such as:

» Chlorinated dioxins and furans

» Chlorate

» 2,3,7,8-TCDD and 2,3,7,8-TCDF

» Chlorinated phenols (total and 2-chlorosyringaldehyde)

» Trihalomethanes including chloroform

GHD makes the following recommendations in regard to potential for organic compounds in the effluent:

» The presence or absence of potential organic compounds in the discharge should be discussed more thoroughly.

» The discussion should include supporting references from publications that have been internationally recognised.

2.2.3 Potential Toxicity of the Effluent

Another critical point is the toxicity of the effluent on the discharge environment. This is not clearly discussed in RIEPG(2008) though some information is provided in Section 9; “Ecological and Environmental Impact Analysis”. Specific paragraphs of the section are dedicated to the impact of COD, TSS, AOX, dioxin and nitrogen and phosphorus salts on marine ecology. Some

toxicity information mostly unreferenced1 can be found combined with two dimensional modelling results previously presented in Section 7. The combination of these two subjects makes for a confusing section.

Effluent toxicity should be approached as a totally separate section addressing the toxicity of the different constituents on the local flora and fauna species. This should be followed by an investigation of the toxicity of the effluent as a whole.

The RPDC (2004) guidelines recommend that effluent toxicity tests such as Microtox tests should be undertaken. Microtox tests have the advantage of being easy and fast to perform but are not very precise. A more detailed ecotoxicological study should be undertaken such as : “Direct Toxicity Assessment” (DTA) or “Whole of Effluent Toxicity” (WET) study.

DTA and WET studies consider the toxicity of the whole effluent as opposed to the toxicity of each constituent of in the effluent. The toxicity tests can be run on species endemic to the site (DTA) or on set species. Site-specific trigger values specific to the effluent and the type of test organisms used can then be derived. The DTA process is well described by the ANZECC and ARMCANZ guidelines (2000), while WET process can be found on the US EPA website2.

In regard to the potential toxicity of the effluent, it is recommended that:

» A literature study on the toxicity of the effluent and its constituents on the local flora and fauna should be included in RIEPG (2008). This section should be supported by documents and studies properly referenced.

» “Direct Toxicity Assessment” (DTA) and “Whole of Effluent Toxicity” (WET) should be discussed and one of these studies undertaken, so that a site specific trigger value for the effluent can be set.

2.3 Background Water Quality

2.3.1 Methodology

A good understanding of the ambient water quality and its seasonal variations is a critical part of an environmental impact assessment study. Ambient concentrations for each chemical that might be present in the waste stream need to be determined. This is of particular importance when natural backgrounds are high or when toxicity trigger values are yet to be determined.

The baseline data collected can also be used to derive local trigger values for some compounds when ambient levels are higher than the guideline value. This approach is the one recommended by the ANZECC & ARMCANZ (2000) guidelines. For the purpose of deriving ambient values and local trigger values, a sufficient amount of data needs to be collected and it should characterise seasonal variations. It is generally accepted that 2 years of monthly data is required.

The derivation of ambient values and local trigger values depend on the local regulations. As an indication, the ANZECC & ARMCANZ guidelines define the ambient value as the 50th percentile of the samples collected while the trigger values are usually defined as the 80th percentile.

Information on the strategy used to identify background conditions and derive ambient and local trigger values needs to be provided.

2.3.2 Additional Sources of Pollution

Activities other than the proposed Pulp and Paper Plant are likely to have an impact on the environment surrounding the plant. It is critical that these activities are well identified so that the background monitoring and the data interpretation encompass the associated impacts. Potential sources of pollution in the Tieshan Port district other than the Pulp and Paper mill have been identified in section 2.5 of RIEPG (2008). These include:

» Industries

– Power Plant: SDIC Beibuwan Electrical Power Co. Ltd

– Paper and Sugar: Guangxi Huajing Paper group Co. Ltd Beihai Sugar Making Brand Company

– Alcohol Plant: Beihai Tieshan Port Longteng Alcohol factory

– Pottery Factory: State owned Chijiang Huaqiao pottery factory of Guangxi Zhuang Autonomous Region

» Domestic source: 168,800 inhabitants in 2006

1. Quotes such as “According to a foreign report on….” 2. USEPA. Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, Fifth Edition, October 2002. (http://water.epa.gov/scitech/swguidance/methods/wet/upload/2007_07_10_methods_wet_disk2_atx.pdf)


» Ships: 7700 vessels in 2006

» Mariculture: 320 km2

» Projects: Heavy oil chemical project of Beihai Taibang Energy Co.

This list does not include future planned developments within the Tie Shangang Industrial Development. RIEPG (2008) provides data on the COD and Ammonia-N content of each activity’s discharge. The list of constituents should be extended to include typical organics compounds and heavy metals as these might need to be considered in the monitoring program.

It is recommended that a cumulative assessment of existing and proposed developments be undertaken to better understand the total impact of the industrial zone on the receiving marine environment. To conduct this type of cumulative impact assessment, further details on the types and concentrations of contaminants present in the discharge from the industrial zone would be required, in addition to a map clearly showing the position of the activities and the discharge location.

2.3.3 Monitoring Sites

Water quality has been sampled at different sites during various monitoring campaigns. In RIEPG (2008), a list of 15 monitoring sites, labelled from #1 to #15 is provided, while a list of 10 sites, labelled from #1 to #10, is provided SCSIO (2010). Coordinates are provided for each site; but there is some confusion due to the same sampling sites being labelled differently from one report to the other, while other labelled with the same number have different coordinates. As an example, sampling site 5# in RIEPG (2008) has the same coordinates as sampling site 1# in SCSIO (2010).

It is understood that the selection of the monitoring sites locations was based on the guidelines HJ/T2.3-93 and takes into account the tides and winds which affect the water movements in the vicinity of the plant effluent discharge.

In the lists provided, it does not appear that control sites or reference sites have been selected. These sites are critical when investigating the impact of a discharge on an environment.

A control site is similar in all relevant aspects to the impact site except that it is not subject to the disturbance and a reference site is deemed to represent standards (ANZECC and ARMCANZ, 2000a). In both cases such sites are critical in assessing the impact of the discharge on the environment and should be included in the monitoring program.

It is recommended that the following should be considered for the ongoing development of the monitoring program:

» A summary list of the monitoring sites should be presented preferably in a table format;

» The monitoring sites should retain their same labelling through the different studies;

» Control and/or reference sites should be selected. The characteristics of these sites should be similar to those used in the monitoring program; and

» Reasons for the selection of the sites should be clearly explained.

Figure 1 Layout of observation stations of water quality and sediments (SCSIO, 2010)

2.3.4 Parameters Monitored

The parameters monitored should be characteristic of the Pulp and Paper mill discharge and reflect the potential impact it could have on the environment. Parameters monitored during the 2 monitoring studies that have been undertaken are listed in Table 4.

Table 4 Parameters monitored in the various studiesRIEPG (2008) SCSIO (2010)

pH value X X

Salinity X X

Total Suspended Solids X X

Dissolved Oxygen X X

CODMn X X

BOD5 X X

Nitrate-N X

Nitrite-N X

Ammonia-N X

Inorganic-N X X

Soluble Reactive Phosphorus X X

Volatile Phenol X X

Copper X

Lead X

Zinc X

Cadmium X


RIEPG (2008) SCSIO (2010)

Total Chromium X

Mercury X

Arsenic X

Petroleum (Oil and Grease) X X

Sulfide X XIt is recommended that the parameters monitored be limited to those that are characteristic of the discharge and present a risk to the environment.

2.3.5 Analytical Methods

Seawater analysis is generally difficult owing to the saline nature of the water causing matrix interference with some analyses. Specific attention should be brought to the laboratories undertaking the work and the methods they used.

The analytical methods used have been listed in table 4.2-2. All references made are to Chinese methods and it would be appropriate to link these to the equivalent Standard Methods3 or any other approved international methods.

Limits of Reporting (LOR) should be reported for each method, with specific consideration brought to Limits of Reporting in seawater.

COD is an appropriate parameter to monitor in the discharge but not so much in seawater. Indeed, the analysis of COD in seawater is not considered reliable due to the interaction of the halogens (chloride, iodide and bromide) with the dichromate to produce the elemental form of the halogen and chromic ion. Hence, monitoring COD in seawater will not be a reliable parameter to follow the extent of the discharge in the bay.

It is recommended that to link analytical Chinese methods to the equivalent APHA Standard method or any other approved international method. In addition it is recommended that only COD be monitored in the discharge.

2.3.6 Analytical Laboratory

RIEPG (2008) and subsequent reports do not mention the laboratories used. The laboratories used should have known expertise in marine water analysis to provide reliability in the results. It is recommended that the laboratories used and their QA/QC accreditations should be properly referenced.

Laboratories used should be clearly stated as well as their accreditation. The laboratory selected should be accredited with GLP (Good Laboratory Practice), which is administered by the OECD (Organisation for Economic Co-operation and Development). The laboratories selected should have a rigorous QA/QC system in place so that data validity cannot be questioned.

2.3.7 Standards

Standards should only be used as a reference when it has not been possible to derive a local trigger value. The Chinese standards “GB3097-1997 Sea water quality standards” are referred to in each report reviewed as being those adapted to this study. They are reproduced in several sections; however there are numerous inconsistencies which include typographical (number) errors (such as the Cyanide concentration for Class III in section 1.5.2 of RIEPG (2008)) and mistranslations.

Other guidelines reported include: HJ/T2.3-93 Technical Guidelines on Environmental Impact Assessment, Surface Water Environment

Table 5 GB3097-1997 Sea water quality standards (EIR, section 1.5.2)

Class pH Value DO CODMn (mg/L)

Inorganic Nitrogen (mgN/L)

Labile Cyanide (mg/L) Volatile

I 7.8-8.5 6 2 0.20 0.015 0.05 0.005 0.005II 7.8-8.5 5 3 0.30 0.030 0.05 0.005 0.005III 6.8-8.8 4 4 0.40 0.030 0.30 0.10 0.010IV 6.8-8.8 3 5 0.50 0.045 0.50 0.20 0.050

3 Standard Methods for the Examination of Water and Wastewater, 21st Edition, 2005. Published by American Public Health Association (APHA), the American Water Works Association (AWWA), and the Water Environment Federation (WEF).

2.3.8 Monitoring Frequency

The monitoring undertaken is limited to the campaigns listed in the table below, that is: 2 campaigns totalling 4 sampling events over 4 years. Some confusion occurred as there was no mention of the year in which RIEPG (2008) sampling was conducted; however based on the comments made in the sediment sampling section it is assumed that it was undertaken in 2007.

There is no question that the number of samples collected through time is insufficient and that a gap of 4 years between sampling campaigns is too large. A strong baseline dataset requires at least monthly sampling that will capture seasonal variation both at the surface and at depth. This limited dataset will not allow undertaking any statistical analysis which would allow for the derivation of a background value and local trigger values.

Depth at which samples were collected is not mentioned, such information is critical in environments that are affected by currents and 3 dimensional movements. The discharge pipeline will be located at depth so collecting samples at depth assists greatly in acquiring an understanding of the variation of water quality between surface and depth if there is any. Basic information on the bathymetry of the bay should also be included to justify the selection of the sites.

Table 6 Monitoring Campaigns Undertaken

Report Tide Dates Tide Number of sites

EIR (2008)

Spring Tide

28 March 2007

29 March 2007

30 March 2007

Measurements taken at flood tide and ebb tide

15 Sites

Neap Tide

8 May 2007

9 May 2007

10 May 2007


15 Sites

SCSIO (2010)Spring Tide May 2010


10 Sites

Neap Tide May 2010Measurements taken at flood tide and ebb tide

10 Sites

Based on this assessment, it is recommended that (i) sampling dates be recorded more rigorously, (ii) sampled be collected at the surface (1 m below surface) and at depth (2-3 m above sea floor), (iii) the monitoring should at least be undertaken monthly over a period of 2 years, (iv) undertake depth profiles for the main physico-chemical parameters (pH, turbidity, DO, temperature), and (v) the sampling should include duplicates and blank samples.

2.3.9 Data Analysis

Results are discussed in section 4.2.6 of RIEPG (2008) and in section 2.1 of SCSIO (2010). Results have been presented in a table format which is difficult to review and interpret. Monitoring data are typically presented in a graph format which allow for better assessment of the data. Tables included in the main report should be limited to statistical interpretation.

Sites which refer to same water quality standards should be grouped together. Once more, the use of numbers to label the sites is not recommended. Comparing data from RIEPG (2008) with data from SCSIO (2010) is confusing as the same numbers have been used for different sites.

In both reports, the water quality at each site is compared to the Sea Water Quality Standard GB3097 and terms such as “standard breach” or “reached the prescribed criteria” are used throughout the discussion. Such terms should not be used as they are specific to compliance monitoring and do not relate to the establishment of a baseline.

The data seems to have been overlooked, for example no discussion is provided on the possible causes of high nutrient levels for the Spring tide ebb in May 2010. Values recorded at that site were 10 times higher than at other sites and some discussion should be provided such as the possibility of a close discharge, local contamination and whether the sample been reanalysed. Likewise, no comment is made on the fact that nitrates at ebb tides for both spring and neap tides are systematically higher than at flood tides.

Table 2.5 of SCSIO (2010) presents a statistical analysis of the data. These statistics were undertaken on all sites combined but tidal events are still separated. The validity of a statistical interpretation undertaken on such a low number of data is questionable. No discussion is provided. Additionally, data presented is as average

http://www.apha.org/

http://www.awwa.org/

http://www.wef.org/


Average values have been calculated. It is usually considered more appropriate to use the 50th percentile (median) rather than the average when deriving ambient values. Median values are more appropriate to use on sets of data that are skewed such as the one reported in SCSIO (2010). Another value of interest is the 80th percentile of the dataset which is recommended by the ANZECC & ARMCANZ guidelines to derive local trigger values.

The results for the evaluation method are presented in Table 4.2-5 to 4.2-12 of RIEPG (2008). There is no discussion specific to these tables and considering the restricted set of data, the usefulness of the method can be questioned.

The following recommendations are provided for improved data presentation and future assessment:

» Clarify data presentation

» Present data in a graph format with neap and high tide on the same graph

» Interpret data: calculate average, median and various percentiles

» Present summary data in the report and the rest in Appendix

» Discuss results in light of data collected, geographical separation, neighbouring industry and water movements and not only by comparing it to the standards

3. Environmental Impact Assessment: Discharge Modelling

3.1 BackgroundModelling was undertaken to assess the environmental impact of the discharge on the environment. A first discharge modelling study was undertaken in 2007 and is presented in RIEPG (2008) (Section 7). This environmental impact analysis utilised a two dimensional oceanographic dispersion model developed by the Tianjin institute. Two dimension models do not represent all mechanisms involved in water movements, in particular the vertical layered distribution. Following comments by Hatfield (Section 3.4, p.25) a second model was developed by the Tianjin institute which includes three dimensions.

The review of this new report was difficult as the document is arduous to read and often highly cryptic due to poor English and constant mistranslations. Nevertheless some outcomes were identified. This review has not included a revision of the mathematical elements of the model due to the difficulty in understanding the material presented and how it has been applied.

3.2 HypothesisSeveral hypothesis were identified as follows

» The diffuser is set at 2.5-3 m above seabed in a 10 m water column;

» The model considers water dynamics (currents and flows); and

» The model considers that pollutants are conservative.

3.3 ScenariosThe model has been run for two different scenarios though these cannot be clearly identified:

» “Prediction of environmental impact by engineering sewage outlet before the construction of the new port (original shoreline)”

» “Prediction of environmental impact by engineering sewage outlet with the new port construction shoreline”

Condition 1 and 2 refer to the composition of the discharge and are defined in Chapter 3 in TRIWTE (2009).

3.4 ParametersThe parameters modelled include:

» COD;

» Total nitrogen;

» Total phosphorus; and

» AOX.

This list is limited. It should include salinity which will reflect the impact of freshwater input on the system and turbidity.

Note: Section 5.3.1.3-D, relates to the modelling of COD at the point of discharge. The diffusion study refers to the utilisation of a conversion ratio of 2.5 between CODCr and CODMn. There is no scientific ground for such a ratio to be applied. Both methods should provide similar results. However, as explained previously, it is widely known that analysis of COD in seawater is not reliable.

3.5 ResultsThe results have been presented in two formats: table and graphs, for different scenarios and conditions. Clear explanation of these scenarios and conditions could not be found and there are definite uncertainties on what has been modelled.

Tables and graphs present the results on a three layers basis: surface, middle and bottom. No indication is provided on the distance separating the three layers.

The three layered graphs have been placed on a map background. This set up is meant to reflect the extent of the plume compared to the coast. This presentation results in microscopic layers being plotted and colour variations representing


concentration variation cannot be visualised. Extracting the graphs from the map background would be of benefit to general understanding of the report.

3.6 ConclusionsGiven the difficulties in reviewing the available information detailed above, it is not possible to derive meaningful conclusions from the information presented in RIEPG(2008) and 2010 reports as to the level of effects from the proposal. As also concluded by Hatfield (2008), the predicted low environmental effects are likely to be reasonable, however based on the information provided, it is not possible to conclude this with any certainty. Whilst some of the issues raised in previous reviews (Hatfield 2008) have been addressed, fundamental flaws remain in relation to the presentation of the model setup, assumptions, outputs and interpretation.

The development of a more robust or at least better documented model, coupled with an appropriately design monitoring program, will provide Stora Enso with a powerful and valuable environmental management tool to assist in project design and operation. Should Stora Enso proceed to the next stage of project commitment, it is recommended that a detailed baseline monitoring program be implemented (as detailed in the following Section) in conjunction with a revised 3 dimensional hydrodynamic model to inform detailed design and operational parameters.

The following recommendations are made:

» Information should be provided on the strategy used to justify the model.

» Hypotheses should be clearly stated at the start of the section.

» Different scenarios should be explained.

» Future major industries should be included in the modelled scenarios.

» Uncertainties on the modelling of COD due to the unreliability of COD analysis in seawater should be highlighted.

» The use of a 2.5 ratio between CODCr and CODMn is not appropriate.

» Salinity and Turbidity should be added to the parameters modelled.

» The discharged concentration used for the model should be justified.

» A summary table should be included for each scenario.

» A clear statement should be provided of the distance between the three layers.

» The plume graphics should be removed from the map background and enlarged, this will also favour their readability.

4. Environmental Monitoring Program4.1 Existing Water Quality Monitoring Program

The Environmental Protection Management and Monitoring System is presented in Section 21 of RIEPG (2008) and the information provided is summarised in Table 21.3-1.

Monitoring programs for surface water, air, groundwater, noise are combined in one table. This layout is confusing. Though the monitoring programs might have some commonality in that they need to capture information on the state of the environment before impact and after, their design varies widely from one discipline to the other in regards to the parameters to monitor, sampling points and guidelines to consider.

The program also considers two periods, namely: construction and operation. These two periods vary broadly in the type of contaminants that will be discharged into the environment and a clear separation of these two periods should be made. Additionally, the program does not consider environmental monitoring prior to operation.

During the construction period, monitoring points will be located in marine areas close to the discharge of construction wastewater. During the operation period, the location of the monitoring points will be as presented in Section 4.

The following recommendations are made for future water quality monitoring, with reference to the table below:

» Three periods should be considered: pre-operation, construction and operation;

» The sampling points selected should consider tides, currents and winds;

» Analytes and parameters monitored should address the specificities of each phase;

» Depth profiles should be undertaken for pH, salinity, turbidity, temperature;

» The program should consider sampling at the surface and at depth; and

» A map indicating the location of the construction water discharge outlet along with indicative location of corresponding sampling points should be incorporated in the report.

Table 7 Summary of RIEPG (2008) Water Quality Monitoring – Ambient Environment and Discharge*Phase Analytes No. of Locations Monitoring frequency

Construction

Temperature

pH

Suspended solids

Dissolved Oxygen

Chemical Oxygen Demand

Inorganic Nitrogen

Soluble Reactive Phosphorus

Oil and Grease (Petroleum)

Where appropriate

Quarterly

- spring tide

- neap tides

Operation – Ambient Environment

Temperature

pH

Salinity

Suspended solids

Colour

Dissolved Oxygen


Adsorbable Organic Halide (AOX)

Inorganic Nitrogen

Soluble Reactive Phosphorus

Volatile phenols

Sulfide

Oil and grease

Where appropriate

Twice a year,

Once during low flow and once during high flow during 3 days



Discharge -

pH

Colour


Biological Oxygen Demand

Ammonia Nitrogen

Adsorbable Organic Halide (AOX)

Suspended solids

Volatile phenols

Sulfide

Oil and grease

Once every Quarter 3 samples collected during 1 day

* Table 7 assumes that the following mistranslation were made in RIEPG (2008): (i) “suspended substances” for “suspended solids”, (ii) “active

phosphate” for “soluble reactive phosphorus”, (iii) “petroleum” for “oil and grease”, and (iv) “chroma” for “colour”

4.2 Proposed Water Quality Monitoring Program and Recommendations

4.2.1 Site Selection

The selection of the site is critical, so that the data collected gives a good representation of the characteristics of the area. The sites should:

» Be representative of the area;

» Consider the impact of adjacent industries and boating activities;

» Be included in and out of the planned mixing zone;

» Include a control or a reference site;

» Consider pre-disturbance data available; and

» Be accessible in most weather

4.2.2 Analytes and Parameters Monitored The parameters selected should be representative of the discharge inherent to the different phases. Undeniably, the water discharged from the site during the construction phase will not present the same characteristics as during the operation and these differences should be taken into consideration when setting up the monitoring program for the site’s entire life, from pre-construction to operation.

The RPDC guidelines provide a list of indicative core parameters and their recommended monitoring frequency in the discharge. Though these are meant to characterise a typical discharge, these can be used as a basis to build up a representative monitoring program.

Typically samples should be collected at the surface (0.5-1 m below the surface) and at depth (1 m from the bottom).

Depth profiles should be undertaken for pH, Turbidity, Salinity, Temperature and Dissolved Oxygen.

4.2.3 Organic Compounds and EffluentWhen documenting the presence or absence of potential organic compounds in the water discharge, the report should be thorough and refer to publications that have been internationally recognised. Effluent toxicity should be approached as a totally separate section addressing the toxicity of the different constituents on the local flora and fauna species. This should be followed by an investigation of the toxicity of the effluent as a whole.

Microtox tests should be undertaken as well as more detailed ecotoxicological studies such as a “Direct Toxicity Assessment” (DTA) or “Whole of Effluent Toxicity” (WET) study. The “Direct Toxicity Assessment” (DTA) and “Whole of Effluent Toxicity” (WET) should be discussed and one of these studies undertaken, so that a site specific trigger value for the effluent can be set.

A literature study on the toxicity of the effluent and its constituents on the local flora and fauna should be included in RIEPG (2008). This section should be supported by documents and studies properly referenced.

4.2.4 PollutionA cumulative assessment of existing and proposed developments should be undertaken to present more details on the contaminants present in the discharge. In addition RIEPG(2008) should provide a map clearly showing the position of the activities and the discharge location in the document itself and not as an attached document.

4.2.5 QualificationsAnalytical Chinese methods should be linked to the equivalent APHA Standard method or any other approved international method. Laboratories used, as well as their QA/QC accreditations, should be properly referenced.

4.2.6 Monitoring and Frequency Monitoring programs should be designed and presented separately for each discipline (surface water, air, groundwater and noise etc). When conducting the monitoring program, three periods should be considered, being pre-operation, construction and operation. Analytes and parameters monitored should address the specificities of each phase. The sampling points selected need to consider tides, currents and winds and depth profiles should be undertaken for pH, salinity, turbidity and temperature.

A map indicating the location of the construction water discharge outlet along with indicative location of corresponding sampling points should be incorporated in the report.

At this stage the data available is limited to 2 events, additional background monitoring will be required to improve the reliability of the calculated ambient conditions. In addition, information on the strategy used to identify background conditions and derive ambient and local trigger values needs to be provided.

As more data becomes available through additional monitoring, the reliability of these values will increase.

A critical aspect is that the background data collected should cover all potential seasonal variations. This is one of the reasons why the ANZECC & ARMCANZ guidelines (2000) recommend that:

“A minimum of two years of contiguous monthly data at the reference site is required before a valid trigger value can be established. “ (Volume 1, Section 7.4.4.1).

In the case of the Guangxi site, it is recommended that this monitoring frequency be increased to a sampling event every 2 weeks for the first year and then reduced to a monthly sampling event. This will enable the collection of sufficient data to calculate indicative ambient background conditions.

4.2.7 Data Analysis and Modelling

The following recommendations were identified with regards to data analysis of the project water quality:

» Clarify data presentation;

» Present data in a graph format with neap and high tide on the same graph;

» Interpret data: calculate average, median and various percentiles;

» Present summary data in the report and the full data in the Appendix;

» Discuss results in light of data collected, geographical separation, neighbouring industry and water movements and in addition to comparison to the standards;

» Information should be provided on the strategy used to justify the model;

» Hypotheses should be clearly stated at the start of the section;

» Different scenarios will need to be explained;

» Future major industries should be included in the modelled scenarios;

» Uncertainties on the modelling of COD due to the unreliability of COD analysis in seawater should be highlighted;

» The use of an appropriate ratio between CODCr and CODMn;

» Salinity and Turbidity should be added to the parameters modelled;

» The discharged concentration used for the model should be justified; and

» A summary table should be included for each scenario.


4.2.8 Proposed Monitoring Plan

Based on the available information, GHD has the following monitoring recommendations:

» The summary list of the monitoring sites should be presented preferably in a table format;

» Monitoring sites should retain their label through the different studies;

» Control and/or reference sites should be selected. The characteristics of these sites should be similar to those used in the monitoring program;

» Reasons for the selection of the sites should be clearly explained;

» Limit the parameters monitored to those that are characteristic of the discharge and present a risk to the environment;

» Record sampling dates rigorously;

» Collect samples at the surface (1 m below surface) and at depth (2-3 m above sea floor);

» Undertake depth profiles for the main physico-chemical parameters (pH, turbidity, DO, temperature); and

» Include duplicates and blank samples.

A plan for the monitoring of ambient environmental conditions is proposed in Table 8. This plan has been based on the information currently available, however, it should be tailored as more information on the characteristics of the effluent becomes available and data is collected.

Table 8 Proposed baseline Water Quality Monitoring, Ambient Pre-operation



Temperature, pH, salinity, DO Depth profile

Monthly

COD

Chlorate

Dioxins 2,3,7,8-TCDD and Furans 2,3,7,8-TCDF in sediment b

2-chlorosyringaldehyde

Trihalomethane including chloroform

Oil and grease (visual)

Samples collected 0.5 m below surface and 1 m from bottom


Other analytes that may be considered in the ambient water quality monitoring program include:

Inorganic nitrogen

Orthophosphate

Volatile phenols

Sulphide

Chlorinated phenols –Total

Heavy metals (if any)

Monthly

Notes: a) These sampling recommendations pertain only to the receiving environmental immediately outside the mixing zone. Sampling sites should be

selected as part of the design of the monitoring program in consultation with the relevant regulatory authorities, and in the case of this Project in

consultation with associated industries discharging in close proximity to the SEGX mill effluent diffuser.

b) Dioxins and furans may be monitored in sediment rather than water, as they accumulate in sediment over time and are unlikely to exist in

detectable concentrations in ambient water unless discharge limits are exceeded. The monitoring frequency recommended for dioxins and furans

is once yearly.

The Resource Planning and Development Commission, Tasmania, Australia (RPDC) guidelines provide a list of indicative core parameters and their recommended monitoring frequency in the discharge, as shown in Table 9 below.

Table 9 Indicative core parameters to be monitored in discharge (IFC (2007), IPPC (2001), RPDC (2004))

Parameter/analyte Monitoring frequency

Volume discharge Daily

Temperature, pH, Salinity, Dissolved Oxygen, Colour Daily

TSSa Daily

BOD Three times weekly

COD Daily

AOX Weekly

Oil and grease (visual) Daily

Dioxins 2,3,7,8-TCDD Variable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

Furans 2,3,7,8-TCDFVariable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

ChlorateVariable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

Trihalomethane including chloroformVariable frequency to be stipulated by regulators subsequent to monitoring following commissioning and start up

Notes: a) Improved technology and best practice for BKPM has significantly reduced the amount of TSS discharged from a modern mill. While monitoring

TSS in the effluent provides a measure of operational efficiency, there is little value in monitoring TSS outside the pre-determined mixing zone, particularly in

marine waters. TSS from modern discharges is not expected to have unacceptable environmental impacts.

| Appendix C Complementary Assessment: Water Quality Review and Assessment20

GHD

201 Charlotte Street Brisbane QLD 4000 GPO Box 668 Brisbane QLD 4001 T: (07) 3316 3000 F: (07) 3316 3333 E: [email protected]

© GHD 2010


Document Status

Rev No.

AuthorReviewer Approved for Issue


Draft V Levy B Skarratt * B Skarratt *

FinalB Skarratt / D.Todd

D.Todd *

Appendix DComplementary Assessment: Air Quality Review and Assessment

AppendixD Complementary Assessment - Environmental Impact Report Air Quality Review and Assessment | 1| 2

AppendixD Complementary Assessment - Environmental Impact Report Air Quality Review and Assessment

Contents1. Introduction 2

2. Review of RIEPG 2008 Air Quality Assessment 3

2.1 Background Air Quality 3

2.2 Site-Representative Meteorology 5

2.3 Air Quality Criteria 6

2.4 Source Emission Rates 6

2.5 Air Quality Model 6

2.6 Odour 7

3. Baseline Ambient Air Quality Monitoring 8

4. Proposed Environment Monitoring Plan 9

4.1 Comments on Proposed Monitoring 9

4.2 Suggested Schedule of Monitoring 10

5. References 11

Table IndexTable 1 Ambient Air Quality Guidelines 6

Table 2 Summary of Monitoring Air Quality – Ambient and Mill Sources 9

Table 3 Emission Limits and Sampling Schedule for Point Source Air Emissions 10

Table 4 Ambient Air Quality Monitoring Schedule 10

AnnexA Beihai Municipal Environmental Monitoring Center Monitoring Report 2010 12

Cover Photo: Eucalyptus nursery in Nanning, Guangxi, China



| AppendixD Complementary Assessment - Environmental Impact Report Air Quality Review and Assessment AppendixD Complementary Assessment - Environmental Impact Report Air Quality Review and Assessment |2 3

1. Introduction

This report provides a review of past air quality impact assessments conducted for the proposed pulp and paper plant in Guangxi Zhang Autonomous Region (Guangxi) to be built and operated by Stora Enso Guangxi (SEGX). The primary references reviewed as part of this assessment were:

» Research Institute of Environmental Protection of Guangxi Zhang Autonomous Region, 2008. The 900,000 Ton Pulp and 900,000 Ton Paper and Cardboard Project of Stora Enso (Guangxi) Pulp & Paper Co., Ltd, Environmental Impact Report.

» Beihai Municipal Environmental Monitoring Center Monitoring Report 2010 No. 034

Gaps in the impact data and / or analysis were identified, and a proposed air quality monitoring programme to more adequately measure ambient air quality both prior to plant construction and after operation has been defined. The proposed Environmental Management Plan (EMP) was also reviewed, and modifications were suggested.

This complementary assessment report is structured into three sections:

Section 2: Review of RIEPG, 2008

Section 3: Proposed ambient air quality monitoring programme

Section 4: Review and modification to the proposed EMP

Where sections, tables or figures of the EIA report (RIEPG, 2008) are cited they have been written in italics.

2. Review of RIEPG 2008 Air Quality Assessment2.1 Background Air Quality

The background air quality is an important aspect, as the degree to which the air-shed already has elevated levels of one or more of the Class 1 [viz NO2, SO2, CO and particulates (PM10)] pollutants, will define the available compartment between background and the air quality objective / standard, and will potentially constrain the additional emissions of those

pollutants into the air-shed from proposed new industries.

The assessment of background air quality is described in Section 4.1 of RIEPG, 2008. A total of nine monitoring sites ranging up to 8 km distance from the proposed pulp mill site were chosen for monitoring. Figure 1 shows the location of these sites relative to the mill site and the coastline. Class 1 pollutants (NO2, SO2, TSP and PM10) were monitored at these sites, while a minor cluster of six sites (see Table 4.1.2) were placed on the mill site boundaries and at two nearby villages. The levels of hydrogen sulphide (H2S) and odour were measured at these minor stations.

Monitoring at both site arrays was done on a campaign basis, with one week of monitoring in both summer and winter of 2007. On each monitoring day, Class 1 pollutants were measured six times (0200, 0700, 1000, 1400, 1600 and 1900 hrs) with a sampling duration of 45 minutes.

H2S was sampled on the same schedule, while odour samples were taken at two hour intervals (1000, 1200, 1400 and 1600 hrs). The results are presented in Tables 4.1.5 and 4.1.6 for winter and Tables 4.1.8 and 4.1.9 for summer. Measured values are presented at each site by the seasonal range only so no conclusions can be drawn as to spatial variability or influence of other sources. Values for SO2 and NO2 are generally low at <20% of the hourly and daily standard for NO2 and ~3% and <20% respectively of the hourly and daily averaged standard for SO2. The results for PM10 were higher from 50 – 60% of the standard for winter / summer respectively.

The results for odour (Tables 4.1.6 and 4.1.8 for winter and summer) show non-detects for all samples at all sites. In retrospect, the attempt to measure ambient odour by dynamic olfactometry meant that for all but situations where the monitoring site was directly downwind of a local odour sources, a value of odour level <10 OU could be expected.

The sister results for H2S show upper limits at up to 0.005 mg/m3 with the higher values seen at the two village sites. The odour detection threshold for H2S is taken as 0.7 µg/m3 using AS 4323.3 protocols (equivalent to CEN 13725:2003), so that the upper limit would be equivalent to ~7 odour units. Background odour levels of this order are common, though not able to be readily measured by other than research olfactometers.

An additional monitoring campaign was completed during August the winter of 2010 (BEMC, 20120), which was not reported in RIEPG, 2008. A total of four monitoring sites ranging up to 7 km distance from the proposed pulp mill site were chosen for monitoring (Figure 1). Class 1 pollutants (NO2, SO2, TSP and PM10) were monitored at these sites, while a minor cluster of four sites were placed on the mill site boundaries (Figure 1). The levels of H2S and odour were measured at these minor stations.


Figure 1 Air Quality Monitoring Sites

On each monitoring day, Class 1 pollutants were measured four times, over the period 9–15 August. H2S and odour were sampled to the same schedule, although only over the period 9-11 August 2010.

Monitoring results for Class 1 pollutants are presented in Annex A for 2010. Measured values are presented at each site by hourly average concentration (NO2 and SO2) and daily average concentration (NO2, SO2, TSP and PM10). Values for NO2 and SO2 are generally low ranging up to 8% and 15% of the hourly and daily averaged standard for NO2 and 2% and 4% of the hourly and daily averaged standard for SO2. The results for TSP and PM10 were higher ranging up to 27% and 25% of the daily averaged standard. Due to the non-continuous nature of the monitoring, no conclusions can be drawn as to spatial variability

or influence of other sources.

The results for odour (Annex A), similar to the previous campaigns, show non-detects for all samples at all sites. The results for H2S show a upper concentrations of 0.016 mg/m3 at the north west corner of the mill border, 27% of the standard for the plant area.

The results from the additional campaign of ambient monitoring during 2010, although indicative due to its non-continuous nature, indicates that standards for Class 1 pollutants, H2S and odour are met at all monitoring sites.

2.1.1 Evaluation

The sampling programme was apparently limited by the lack of access to continuous gas analysers and real-time particle sensors which would have allowed the full variation of ambient air quality to be measured. This limitation is significant for the case of PM10 – a full spectrum of ambient measurements may well show there are 24 hour periods when the background levels of PM10 exceed the adopted standard.

The attempt to measure odour / H2S was useful in the sense that at the proposed mill site both parameters were mainly below detection levels, suggesting that the above detect readings at the two village sites were the result of sources local to village activities.

2.2 Site-Representative MeteorologyIt is critical to access site-representative meteorology so that any dispersion modelling can correctly simulate plume trajectories. Further, on sites near or at a land/sea interface, the mixing mechanisms applying to stack plumes emitting into or above the internal boundary layer at the sea breeze interface can be important to characterise so that fumigation events can be correctly modelled.

2.2.1 Wind Speed and Direction – Seasonal Variation

Section 8.1 identifies a meteorological station at Beihai City located some 40 km to the south west of the mill site. No details are given, either of the anemometer or of the logged data. The test of site representativeness was done using campaign meteorological data at (i) the Beihai Power Station, 6.5 km NE from the mill site, and (ii) the Beihai Oil Refinery located 4 km SW of the mill site. These data sets were not synchronised with the former dataset, one providing data in ‘early 2005’ and the other providing data for ‘August 2005’. No information is given on the anemometers used or the frequency of logging wind speed and direction.

The tabular presentation of incidence of wind direction at each station and the mean wind speed for each direction sector makes it difficult to make a quantitative analysis to determine the degree of correlation between Beihai City meteorology and the near-mill site meteorology. Normally this can be done by means of vector correlation. This has the advantage that the mean rotation of wind direction ΔΘ and mean amplification on wind speed α are needed to maximise the correlation can be determined. Then, provided ΔΘ ≤ 30o and 1.1 > and α > 0.9, the Beihai data could be corrected by these factors and with some confidence be used to represent wind conditions at the mill site. If the source data is capable of being analysed in this fashion then it should be done.

A limited correlation is presented for the two week period August 14 – 28, 2005 (the summer period investigation for the Beihai Oil Refinery) and Figure 8-1-1 shows the daily mean wind speeds at each station. Table 8.1-2 gives the result of the velocity component analysis and although the correlation coefficients are deemed acceptable, there is a substantial difference in each station’s component (i.e. b does not approach 1 and a does not approach 0). Given this, it seems that Beihai City meteorological data (if not corrected by the relation given in Table 8.1-2) cannot be considered to be representative of the mill site.

2.2.2 Wind Speed and Direction Profiles

Profiling is presented at three hourly intervals for a day in spring and a day in summer. These are selected from a vertical profile set taken at Tieshan Port in the spring and summer of 2005. No information is given on the sensors used to profile wind speed and direction, though the profiles shown in Figures 8.1-5 and 8.1-6 suggest a sonde was used.

2.2.3 Sea Breeze – Land Breeze

The report shows a low occurrence of sea breezes for a coastal site, with an incidence from 26.8% in autumn to 15.5% in spring. The typical duration is 7-10 hours for sea breeze and 7-9 hours for the land breeze. This data appears to be taken from Beihai City which has a different coastline aspect than does the mill site.


Later in Table 8.1-13, similar data on occurrence duration and mean wind speed are given at Tieshan port, with a commentary that suggests that indeed the land/sea breeze system is different and less pronounced than that at Beihai.

2.2.4 Inversions

Finally, the Tieshan port wind and temperature profile data is examined to characterise the incidence and strength of ground-based and elevated temperature inversions, see Table 8.1-15 – yet this table is titled as being from Beihai for spring and summer. Further, the body of the table instead shows data for spring and autumn. Unfortunately, the text description is unclear, leading to confusion in the reader’s mind as to whether or not the data is representative of the site.

2.2.5 Temperature Boundary Layer

The text here describes the formation of a thermal internal boundary layer (TIBL) but is of little use as a TIBL was not observed during the spring/summer campaigns in 2005.

2.3 Air Quality CriteriaThe Tieshan area is required to meet the Class 2 air quality criteria for the ubiquitous pollutants namely SO2, NO2, PM10 and TSP as specified in China Standard BG 3095 – 1996.

As seen in Table 1 these are comparable to the current WHO interim targets, though not to the air quality guidelines as updated in 2005. The WHO guidelines and interim targets are those specified by the International Finance Corporation (IFC) of the World Bank.

Table 1 Ambient Air Quality Guidelines

Pollutant Averaging PeriodChina WHO

Guideline µg/m3 Guideline µg/m3 Target µg/m3

SO2

10 min 5001 hr 500 - -

24 hr 150 20 125 *annual 60 -

NO2

1 hr 240 - -24 hr 120 200

annual 80 40

PM101 hr - -

24 hr 150 50 150 *annual 100 20 70 *

PM2.524 hr - 25 75 *

annual - 10 35 *

TSP24 hr 30 - -

Annual 20 - -

* Interim target 1

2.4 Source Emission RatesData on emission and discharge sources are given in Sections 3.4.2 and 3.4.5 under Project Overview. It would be useful to repeat in condensed form the source release geometry and emission rates in a Table within Section 8 so that this input to the modelling process was readily available to the reader.

Tables 3.4-6 and 3.4-7 specify flow-rate, emission rates for Dust, SO2, NOx Cl2 and TRS for each of the major sources namely, alkali recovery boiler, power station boilers and limekiln. Cl2 emissions are also specified for the bleaching workshop.

Stack diameters, stack heights as well as exhaust temperatures and velocities are also given in footnotes to Table 3.4-7. However no building geometry is specified, and it may be that the main stack height of 120m is sufficiently clear of built forms that this aspect (plume/ building wake interaction) is not required to be modelled.

2.5 Air Quality ModelSection 8.2.1 outlines the diffusion model used in predicting air quality downwind of the proposed mill, and specifies the parameter options selected. It is stated that the UK Gaussian plume model ADMS (Atmospheric Dispersion Model System) was adopted. However, the text then details the equations (presumably used in the ADMS algorithms) for several aspects of plume rise and dispersion.

The lack of any tabling of any ADMS parameter settings, of detailed information on the Beihai meteorological data and the lack of any contour plots of the predicted distribution of ground level concentrations for SO2, PM10, NO2, Cl2 and odour makes it impossible to verify the tabled predictions of these constituents at the nominated receptors.

The regular ‘lobes’ of contour extension at 22.5 degree intervals ( ie 16 lobes) on most of the figures strongly suggests the wind direction was only read to the nearest compass point ( ie NNW). Hence at 100%ile ( absolute maximum), the contours should be read by placing radial envelopes covering the lobe array for a given concentration. In other words, the apparent reduced impact at in-between directions is an artefact caused by aggregating directions into 16, 22.5 degree segments. It is therefore not possible to infer values between compass points.

It is unclear whether the equations given in the text were directly used in spreadsheets to predict receptor peak concentrations, rather than the use of the ADMS (Version 4.2 is current) model. While ADMS V4.2 is certainly capable of modelling the significant processes at play in the dispersion and transport of emitted pollutant plumes from the proposed mill site, there is no transparency given in the text guiding the reader as to how the calculation of peak concentration were made. As an example, it is not clear whether hourly meteorological data is available from the Beihai City meteorological station – nowhere are details given.

There is also no mention of direct modelling of emissions from nearby industry. For example, in Section2.5.1 the SDIC Beibuwan Power Station in Tieshan is cited as accounting for 86% of all SO2 emissions from the Tieshan Port District. In such cases the predicted pattern of pollutant concentration is more accurate when nearby major sources are also included (rather than assuming they are accounted for in the measured background). Table 2.5-1 lists all the significant industry emissions from industrial premises in the Beihai and Tieshan Port districts.

2.6 OdourDirect measurement of odour by dynamic dilution olfactory techniques is generally considered to be the most useful technique in assessing the significance of odour emissions from industrial sources as this inherently takes into account all chemicals in the emissions and does not rely on odour thresholds for individual chemicals. However it is not possible to conduct such tests for a facility that has not yet been built hence the analysis relied on the calculation of odour quotients to make judgements regarding the likelihood of odour events and whether they are likely to be annoying.

The assessment included modelling of potential odour using H2S as an indicator. Figure 8.2.20 shows modelled peak (presumed at 100%ile) H2S levels at 1 hour average. The emissions criterion in China for H2S is 0.01 mg/m3, or 10 ug/m3, and the plot shows excursions of approximately 500 m to the SE and approximately 300 m from the SW and NW site boundaries.

To place this in some context, the predicted H2S concentrations have been converted below into approximate odour units based on an approximate conversion.

If the odour emission was pure H2S, then its odour threshold of 0.7 ug/m3 could be used to convert H2S to odour contours. Odour from pulp mills is however a complex mixture of reduced sulphides of which H2S is typically a substantial component.

The sulphur-containing Total Reduced Sulphur (TRS) compounds each have a characteristically low odour threshold and they can be released in varying proportions from both natural and industrial processes; including microbial degradation, oil refining and the Kraft wood pulping process. Based on previous studies (GHD, 2006) it is possible to use the dose-response relationship for H2S, which is the most extensively studied of the TRS compounds, to characterise the effects of exposure to TRS mixtures. This approach has been considered by various government authorities to regulate malodorous TRS compounds.

The odour threshold is the concentration of a gaseous substance, expressed in µg/m3, which will be discerned from odourless air by at least half of an odour panel. The odour threshold per definition has an odour concentration of 1 odour unit/ m3.

Data from odour measurements undertaken in the 1980s at the Maryvale Mill in Gippsland, Australia gives an odour threshold for Total Reduced Sulphur (TRS) as 1.4 ppb (CMPS&F, 1997). Assuming most TRS is H2S, then using the molecular weight of H2S (34) gives a TRS threshold of 2 ug/m3. On that basis, the predicted H2S contours can be halved to give predicted odour levels. In this case the 10 ug/m3 H2S contour becomes 5 OU which is generally considered as a conservative measure of the potential onset of odour complaint if exposure is repeated. But if the contours are the hourly 100% ile, then they represent an exposure of just 1 hour in 1 year, and would be unlikely to result in complaint as these peak levels typically occur at night when dispersion is poor and people are asleep.


3. Baseline Ambient Air Quality Monitoring

The review conducted in Section A of this report established that available ambient air quality data in the Beihai region was restricted to seasonal (summer and winter) campaign monitoring over a period of two weeks in 2007 and 2010 at the mill site, supplemented by similar campaigns monitoring conducted in 2005 for the Beihai Power Station and for the Tieshan

Oil Refinery. The Class 1 constituents of SO2, NO2, PM10 and TSP were monitored as well as H2S and odour.

Sampling on each day was conducted at two hour intervals and spanned most of the 24 hour cycle.

While the monitoring campaign was timed to capture typical diurnal variations and the seasonal range in air quality, the dataset is still inadequate to fully characterise the variations in the measured parameters that could be expected to occur. A typical baseline ambient air quality monitoring programme that could be expected to be put in place for a project of this size would entail the installation of a minimum of one Air Quality Monitoring Station. This would be fitted with:

» A logging anemometer to measure wind speed V, wind direction θ, standard deviation of θ, ambient temperature at 10 m and 1.5 m height and a net radiation sensor.

» Gas analysers to measure SO2, NO2 and TRS, and

» Particulate sensors for PM10 (and perhaps PM 2.5) capable of reading and logging near real-time data (TEOMs or BAMs).

While such a station is not inexpensive, it will provide invaluable data on background ambient air quality so that this and other future industry developments can have a firm basis on which to determine compliance to the airshed air quality objectives. Gas analysers have a non-detect value of ~ 1 ppb for these gases, and the particulate sensors have a typical non-detect threshold of ~ 5μg/m3. The anemometer wind speed sensor should be capable of wind speed measurement down to 0.2 m/s, and wind direction to the same threshold. Thresholds of this order will allow plume trajectories to be determined during light wind events when off-site impact (at least for near ground level sources) is enhanced.

The Air Quality Monitoring Station should be installed and operating in time to obtain a clear 12 month dataset prior to the commencement of Mill operations, and be available as; (i) unvalidated data on a website, and (ii) quarterly reporting of validated data as time – series and tabled giving the numbers of exceedences of the relevant air quality criterion,

The AQMS should also be deployed past the construction phase, given that there appears to be no AQMS at present in the Tieshangang or Beihai areas.

4. Proposed Environment Monitoring Plan

Section 21 (RIEPG 2008) outlines the proposed Environment Management and Monitoring Plan, and an elaborate supervision and implementation schedule is laid out, specifying the organisation that is responsible for each facet of the plan. In relation to air quality, the monitoring of ambient air quality is specified for both construction and operation phases, with

monitoring of source emissions specified for the operation phase only. Table 2 summarises the proposed monitoring to measure the mill’s impact on the air environment.

Table 2 Summary of Monitoring Air Quality – Ambient and Mill Sources

Phase

Ambient Source

Constit. No. of Locations

Monitoring

frequency

Campaign

DurationConstit. Location

Monitoring

frequency

Campaign

Duration

Construction TSP 2(1) 4 / year 5 days - - - -

Operation

NO2

2(2) 1 / year

5 days

18 hrs/day

12 hrs/day for PM10

NO2 Lime kiln

4 / year

1 day

3 samples / day

SO2

PM10

Alkali recovery

SO2

PM10

H2SNO2

Power Plant

PM10SO2

colour

4.1 Comments on Proposed Monitoring

4.1.1 Ambient – Construction Phase

Here only TSP is nominated to be measured once every 3 months, with a five day campaign. While this may comply with regulations, it will not provide timely feedback to contractors when dust levels rise above criteria (150 μg/m3). If the monitoring is able to provide feedback in real-time, then a Dust Management Plan can prescribe mitigation measures to be applied any time a ‘trigger’ dust concentration is exceeded.

This is commonly done using light-based instruments such as Dustrak, Grimm etc. that can be operated by battery with a solar panel to provide recharge. The proposed campaign-based monitoring is clearly unable to provide this type of feedback. The choice of two monitoring sites, each at the nearest sensitive receptors is appropriate.

A continually operated TSP real time monitoring program is recommended during construction phase. The criterion value should be used as a trigger for implementation of mitigation measures. The instrument can also be retained for the operational phase and be an essential part of an operational Dust Management Plan.

4.1.2 Ambient – Operation Phase

Table 2 shows that RIPEG, 2008 propose that ambient air quality is measured only once per year in a five day campaign. Such sparse sampling serves little purpose as: (i) a compliance during 5 days in 365 says nothing as to the compliance status on other days, (ii) the data is also not sufficient to determine whether there is a detectable increase in background levels since the mill operations have commenced. As with the construction phase monitoring, the data is too sparse to form reliable mean or 70 percentile background levels.

It is recommended that ambient monitoring be continued into the operational phase using gas analysers and real-time dust


sensors – as detailed in Section 2.

4.1.3 Emission Sources – Operation Phase

The campaign monitoring specified in Table 1 (Annex A) is presumably in compliance with licence monitoring requirements. This monitoring does not give feedback to mill operators in relation to the on-going performance of the main boilers. For SO2 and NO2, real-time monitoring and logging of in-stack concentrations is necessary so that the potential for formation of photochemical smog in the air-shed, or incidence of acid rain is minimised at all times.

The three boiler stacks should each be monitored in near-real time for products of combustion, namely NO, NO2, SO2 and PM, as well as for H2S (Alkali Recovery and lime kiln stack).

4.2 Suggested Schedule of MonitoringBased on the comments above, a suggested schedule for Point Source monitoring during plant operations, and for ambient air quality monitoring before, during construction and thereafter in operation is given in Tables 3 and 4 below.

Table 3 Emission Limits and Sampling Schedule for Point Source Air Emissions

Emission Source Pollutant Units Testing Frequency Comments

Recovery boiler PM mg/NDm3Monthly initially

then less frequent depending on results

Manual testing

TRS mg H2S/NDm3 Continuous



Lime Kiln PM mg/NDm3Monthly initially


Manual testing



Power Boiler PM mg/NDm3Monthly initially


Manual testing

NOx

mg NO2/MJ fuel input Continuous

mg NO2/NDm3


Table 4 Ambient Air Quality Monitoring Schedule

ParameterFrequency of

SamplingConcentration

LimitAveraging

TimeAllowed

ExceedanceSource

SO2 Sulphur dioxide Continuous 500 mg/Nm3 1 hr (moving av) NoneBG 3095-

1996Total Reduced Sulphides (TRS)

Continuous 10 mg/Nm33 min (moving

av)None TJ 36-79

NO2 Nitrogen Dioxide Continuous 240 mg/Nm3 1 hr (moving av) None BG 3095PM10

Particulate Matter <10 mmContinuous 150 mg/Nm3 24 hr None BG 3095

Odour 3 monthly 20 odour unit - none GB 14554-93

5. References

BEMC 2010, Beihai Environmental Monitoring Center, Monitoring Report 034.

CMPS&F, 1997. Briefing Paper on Appropriate Ambient Odour Objective for Proposed Paper Mill at Tumut. Prepared for Meeting with NSW EPA Tuesday, 30 September, 1997.

GHD, 2006. Proposed Pulp Mill – Bell Bay. Impact on Air Quality: Report - Draft IIS.



Annex A

Beihai Municipal Environmental MonitoringCenter Monitoring Report 2010

Stora Enso Guangxi Integrated Mill project EIA –Environmental baseline update, 2010 – summer

Air qualityParameters, SO2, NO2, TSP and PM 10Positions 4, see map

Odor analysisParameters according to standard GB14554-93 Emission Standard for Odor PollutantsLevel 2, methods see Mill EIA section 4.1.2 Volume I.Positions 4, see map

GroundwaterParameters; pH, total hardness, COD Mn, sulfates, volatile phenols, ammonia nitrogen, ,nitrate, nitrite, total dissolved solids, chloride, total coliforms and total bacteriaPositions 3, see map

NoisePositions 8, see map

Made by; Beijing Light Industry Environmental Protection Institute, BLIEPIOcean environment; by South China Sea Institute of Oceanology, SCSIO, GuangzhouWater parameters; salinity, pH, suspended matter, dissolved oxygen, chemical oxygendemand, biochemical oxygen demand, volatile phenol, inorganic nitrogen, active phosphate,sulfides, petroleum. Standards; GB 3097-1997 following Norms for Ocean Monitoring (GB17378.4-1998).

Sediment parameters; following GB 18688-2002, see Mill EIA section 4.3The updated survey will include also biological production parameters, plankton etceteras.Sampling points 8, see map for preliminary positions, final selection will be made by SCSIO


北海市环境监测中心站


监测报告北（其）字[2010]第034号

项目名称: 斯道拉恩索项目环境现状监测委托单位: 轻工业环境保护研究所监测类别：委托监测报告日期：2010年8月24日

北海市环境监测中心站

第2页共12页

监测报告说明

1、委托单位在委托前应说明监测目的，凡是污染事故调查、环保验收监

测、仲裁及鉴定监测需在委托书中说明，并由我单位按规范采样、监

测。由委托单位自行采样送检的样品，本报告只对送检样品负责。

2、本报告无本站公章和及骑缝章无效。

3、本报告出具的数据涂改或缺页无效。

4、对本报告有异议的，应于领取报告之日起十五日内向我站提出逾期不

予受理。但对不能保存的特殊样品，本站不予受理。

5、本报告未经同意不得用于广告宣传。

6、未经同意，不得部分复制本报告。

地址：北海市北海大道198号邮编： 536000传真： 0779-3030151联系电话： 0779-3030151


第3页共12页

一、监测信息

任务来源受轻工业环境保护研究所委托，我站于2010年8月9-15日对铁山港区斯道拉恩索项目（拟建）的环境空气、地下水和声环境进行监测。

委托方信息

名称轻工业环境保护研究所

地址北京市海淀区西三环北路27号北科大厦邮编 100089联系人岳冰联系方式 13691307766

受检方信息

名称斯道拉恩索项目环境现状监测地址北海市铁山港区邮编 ——

联系人 —— 联系方式 ——监测类型 ■委托监测 □监督性监测 □自送样 □其它

样品说明

样品来源现场采样采样时间 2010年8月9-15日

采样依据

噪声：《工业企业厂界环境噪声排放标准》( GB12348-2008)、《声环境质量标准》(GB 3096-2008)环境空气：《空气和废气监测分析方法》中国环境科学出版社，第四版地下水：《地下水环境监测技术规范》HJ/T64-2004

样品类型 □废水 □地表水 ■地下水 □废气 ■环境空气 ■噪声 □土壤 □底质 □固体废弃物 □其它（）

样品分析说明

现场分析项目噪声现场监测

时间 2010年8月9-10日

实验室分析项目

环境空气：总悬浮颗粒物（TSP）、可吸入颗粒物（PM10）、二氧化硫(SO2)、二氧化氮(NO2)、硫化氢（H2S）、臭气浓度

采样时间 2010年8月9-15日

分析完成时间 2010年8月9-16日、23日

地下水：pH值、总硬度、硫酸盐、挥发酚、氨氮（NH3-N）、高锰酸钾指数（CODMn）、硝酸盐、亚硝酸盐、溶解性总固体、氯化物、总大肠菌群、细菌总数

采样时间 2010年8月9-11日

分析完成时间 2010年8月9-12日

分析条件说明现场分析条件和实验室分析条件符合本监测机构规定的条件要求。

第4页共12页

二、分析方法及仪器设备

项目分析方法/依据检出限仪器设备

名称型号编号

噪声《声环境质量标准》（GB3096-2008）

— 多功能噪声仪 AWA5680 172

环境空气

TSP 重量法(GB/T15432-1995) 0.001 mg/m3 电子天平 MA110 020

PM10 重量法(GB/T15432-1995) 0.001 mg/m3 电子天平 MA110 020

NO2

盐酸萘乙二胺分光光度法(GB/T 15436-1995)

0.005 mg/ m3 光栅分光光度计 722 006

SO2

盐酸副玫瑰苯胺分光光度法(GB/T 15262-1994) 0.003 mg/m3 分光光度计 SP-722E 161

H2S亚甲基蓝分光光度法

（GB/T14678-1993）0.001 mg/m3 分光光度计 SP-722E 161

臭气浓度三点比较式臭袋法（GB/T14675-1993） —— 嗅觉试验法采

样器 5L —

地下水

pH值 pH计法(GB17378.4-2007) — 实验室pH计 pHSJ—4A 123

总硬度EDTA滴定法《水和废水监测分析方法》中国环境科学出

版社，2002年第四版，P4155mg/L 滴定管 50ml 1-0700002

硫酸盐离子色谱法HJ/T84-2001 0.09mg/L 离子色谱仪 761compact IC 146

挥发酚 4-氨基安替比林分光光度法(GB/T 7490-1987) 0.002 mg/L 分光光度计 SP-722E 161

氯化物离子色谱法HJ/T84-2001 0.02mg/L 离子色谱仪 761compact IC 146

硝酸盐氮离子色谱法HJ/T84-2001 0.08mg/L 离子色谱仪 761compact IC 146

NH3-N 纳氏试剂分光光度法（HJ 535-2009） 0.025mg/L 分光

光度计 SP-722E 161

CODMn 酸性法(GB/T11892-1989) 0.5mg/L 滴定管 50mL 1-0400005

亚硝酸盐氮离子色谱法HJ/T84-2001 0.03mg/L 离子色谱仪 761compact IC 146

溶解性总固体

重量法(GB/T11901-1989) —— 电子天平 MA110 020

总大肠菌群多管发酵法《水和废水监测分析方法》中国环境科学出

版社，2002年第四版，P704—— 生化培养箱 SPX-150B 560

细菌总数培养法《水和废水监测分析

方法》中国环境科学出版社，2002年第四版，P695

—— 生化培养箱 SPX-150B 560


第5页　共12页

三、Surrounding air inspection results

1. SO2、 NO2、PM10 and TSP

unit：mg/m3

time

Sampling location 1# : Beimu

Hourly averag concentration Daily average concentration

SO2 NO2 PM10 TSP SO2 NO2

Aug.9

<0.003 <0.005

0.030 0.078 <0.003 0.012<0.003 0.007

<0.003 0.008

<0.003 0.009

Aug.10

<0.003 <0.005

0.031 0.078 0.004 0.0110.003 0.006

0.005 0.007

<0.003 0.008

Aug.11

0.004 <0.005

0.031 0.079 <0.003 0.0100.004 0.006

<0.003 0.006

<0.003 0.007

Aug.12

0.006 0.006

0.037 0.071 0.005 0.0110.004 <0.005

<0.003 0.007

0.004 0.009

Aug.13

0.004 <0.005

0.035 0.073 <0.003 0.010<0.003 0.005

<0.003 0.007

<0.003 0.009

Aug.14

<0.003 0.006

0.035 0.073 <0.003 0.011<0.003 0.006

<0.003 0.007

<0.003 0.008

Aug.15

<0.003 <0.005

0.031 0.076 0.005 0.0090.006 0.005

<0.003 0.006

0.004 0.006

第6页共12页

unit：mg/m3

time

Sampling location 2# Huang Xiao

Hourly ave. concentration Daily average concentration


Aug.9

<0.003 0.005

0.028 0.076 <0.003 0.010<0.003 0.005

<0.003 0.007

<0.003 0.007

Aug.10

<0.003 0.005

0.028 0.076 <0.003 0.010<0.003 0.005

<0.003 0.007

<0.003 0.008

Aug.11

<0.003 0.005

0.030 0.078 0.004 0.011<0.003 0.007

0.005 0.008

<0.003 0.008

Aug.12

<0.003 <0.005

0.033 0.081 <0.003 0.009<0.003 0.005

<0.003 0.005

<0.003 0.007

Aug.13

<0.003 <0.005

0.030 0.074 <0.003 0.009<0.003 <0.005

<0.003 0.005

<0.003 0.007

Aug.14

<0.003 0.005

0.033 0.074 0.004 0.0100.005 0.006

<0.003 0.007

<0.003 0.008

Aug.15

0.006 <0.005

0.033 0.073 0.005 0.009<0.003 0.005

<0.003 0.007

<0.003 0.007


第7页共12页

Unit：mg/m3

time

Sampling location 3# Ban Jiu chong village



Aug.9

<0.003 0.005

0.037 0.078 0.005 0.011<0.003 0.005

0.003 0.006

<0.003 0.008

Aug.10

<0.003 0.005

0.033 0.078 <0.003 0.010<0.003 <0.005

0.004 0.006

0.003 0.008

Aug.11

<0.003 0.005

0.031 0.079 <0.003 0.011<0.003 0.006

<0.003 0.006

0.005 0.008

Aug.12

<0.003 <0.005

0.037 0.076 0.005 0.0100.006 0.006

<0.003 0.006

<0.003 0.007

Aug.13

<0.003 0.007

0.035 0.079 <0.003 0.012<0.003 0.006

<0.003 0.007

<0.003 0.008

Aug.14

<0.003 0.006

0.037 0.076 0.006 0.012<0.003 0.007

<0.003 0.007

<0.003 0.008

Aug.15

<0.003 0.006

0.031 0.074 0.004 0.011<0.003 0.006

<0.003 0.007

<0.003 0.008

第8页共12页

unit：mg/m3

time

Sampling location 4#: Chi Bin



Aug.9

0.004 0.006

0.034 0.074 <0.003 0.011<0.003 0.006

<0.003 0.007

0.008 0.008

Aug.10

<0.003 0.005

0.035 0.071 <0.003 0.010<0.003 0.006

<0.003 0.007

<0.003 0.007

Aug.11

<0.003 0.006

0.035 0.071 0.004 0.010<0.003 0.006

<0.003 0.007

<0.003 0.006

Aug.12

<0.003 0.006

0.037 0.073 <0.003 0.011<0.003 0.006

<0.003 0.007

<0.003 0.008

Aug.13

<0.003 0.006

0.031 0.079 0.005 0.0110.006 0.007

<0.003 0.006

0.003 0.008

Aug.14

<0.003 0.005

0.033 0.076 0.003 0.0100.004 0.006

<0.003 0.007

<0.003 0.008

Aug.15

<0.003 0.006

0.035 0.074 <0.003 0.011<0.003 0.007

<0.003 0.007

<0.003 0.008


第9页　共12页2. Results of hourly average concentration of H2S and ordrous gases

unit：H2S: mg/m3，ordrous gases: non-dimensional

Time

Northeast corner, mill border

Southwest corner, mill border

Southeast corner, mill border

Northwest corner, mill border

H2S Ordrous gases H2S Ordrous

gases H2S Ordrous gases H2S Ordrous

gases

Aug.9

0.009 <10 0.014 <10 0.011 <10 0.016 <10

0.011 <10 0.014 <10 0.012 <10 0.009 <10

0.012 <10 0.015 <10 0.011 <10 0.009 <10

0.012 <10 0.015 <10 0.009 <10 0.013 <10

Aug.10

0.009 <10 0.011 <10 0.008 <10 0.012 <10

0.011 <10 0.012 <10 0.009 <10 0.014 <10

0.008 <10 0.012 <10 0.009 <10 0.011 <10

0.010 <10 0.012 <10 0.008 <10 0.010 <10

Aug.11

0.010 <10 0.012 <10 0.009 <10 0.014 <10

0.008 <10 0.011 <10 0.009 <10 0.012 <10

0.009 <10 0.012 <10 0.008 <10 0.013 <10

0.007 <10 0.012 <10 0.009 <10 0.012 <10

3. Remarks：(1) when it is lower than the check limit of the instrument, then it will be expressed < xx

(2) Surrounding air data is the same as local weather report

Date Weather condition Wind direction Wind

speed（m/s）Air

pressure（kpa） Temperature（℃） humidity（%）

Aug.9 fine Southwest 2.3 100.9 33 60

Aug.10 fine Southwes 2.3 101.0 33 60



Aug.13 fine Southeast 2.0 100.9 32 65

Aug.14 fine South 2.2 100.9 33 60

Aug.15 fine Southwest 2.1 100.8 33 65

第10

页共

12页

四. I

nspe

ctio

n re

sults

of u

nder

grou

nd w

ater

U

nit：

Col

iform

bac

teri

a an

d to

tal b

acte

ria:

pcs

/L，

othe

rs: m

g/L

Insp

ecti

on

tim

eIn

spec

tion

po

int

Insp

ecte

d it

ems

pHTo

tal

hard

ness

sulp

hate

shy

drox

yben

zene

chlo

ride

sTo

tal

reso

lvab

le

solid

sN

H3-N

COD

Mn

NO

3-NN

O2-N

Calif

orm

bact

eria

Tota

l ba

cter

ia

Aug

.9

Beim

u6.

3835

.32.

40.

002L

1.3

700.

577

0.5L

0.08

L0.

03L

<3

21

Hai

shan

ba6.

4917

.60.

09L

0.00

2L3.

457

0.40

50.

5L0.

08L

0.03

L<

319

Beim

u-

wor

king

are

a6.

4251

.712

.10.

002L

52.3

700.

448

0.5

6.15

0.03

L<

319

Aug

.10

Beim

u6.

3633

.34.

70.

002L

1.6

700.

652

0.5L

0.08

L0.

03L

<3

18

Hai

shan

ba6.

5017

.63.

60.

002L

3.2

550.

394

0.5L

0.08

L0.

03L

<3

17

Beim

u-

wor

king

are

a6.

4456

.88.

70.

002L

50.0

650.

502

0.6

6.04

0.03

L<

320

Aug

.11

Beim

u6.

3631

.83.

40.

002L

1.9

680.

620

0.5L

0.08

L0.

03L

<3

17

Hai

shan

ba6.

5118

.42.

60.

002L

2.9

530.

437

0.5L

0.08

L0.

03L

<3

17

Beim

u-

wor

king

are

a6.

4256

.110

.90.

002L

48.7

640.

512

0.6

5.80

0.03

L<

318

Rem

arks

：(1

) whe

n it

is lo

wer

than

the

chec

k lim

it o

f the

inst

rum

ent,

then

it w

ill b

e ex

pree

sed

< x

x

(2

) Sur

roun

ding

air

dat

a is

the

sam

e as

loca

l wea

ther

repo

rt

Dat

eW

eath

er

cond

itio

nA

ir

pres

sure

（kp

a）te

mpe

ratu

re（

℃）

Wat

er te

mpe

ratu

re（

℃）

Wat

er d

epth

（m

）

Beim

uha

isha

nba

Beim

u- w

orki

ng a

rea

beim

uha

isha

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Beim

u- w

orki

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ug.9

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100.

933

2523

2420

3818

Aug

.10

fine

101.

033

2423

2420

3818

Aug

.11

fine

101.

034

24.5

23.5

2520

3818


第11页　共12页

五、Inspection results of noiseInspection date Points and name Inspection time Measured data

Leq [dB(A)]

Aug.9

1# outside of mill west border, 1m

Day time 48.2

Night time 40.9


Day time 48.5

Night time 41.5

3# outside of mill north border, 1m

Day time 49.3

Night time 43.3


Day time 49.9

Night time 42.7

5# outside of mill east border, 1m

Day time 46.2

Night time 43.8


Day time 46.5

Night time 44.1

7# outside of mill south border, 1m

Day time 47.0

Night time 41.8


Day time 47.3

Night time 42.1

Aug.10


Day time 49.5

Night time 41.1


Day time 50.4

Night time 41.4


Day time 46.6

Night time 42.7


Day time 47.3

Night time 43.1


Day time 48.2

Night time 42.0


Day time 47.5

Night time 42.5


Day time 48.7

Night time 43.3


Day time 48.4

Night time 42.8

第12页　共12页

六、Sketch map of the inspection points

Remark：“▲” stands for inspection points for noise.

Farm

land

N

Farm land

Tiger Mill site

▲1#

1#

▲2#

1#

Farm land

& forest land

Salt land

▲6#

1#

▲5#

1#

▲3#

1#▲4#

1#

▲8#

1#▲7#

1#

Below blank


| AppendixD Complementary Assessment - Environmental Impact Report Air Quality Review and Assessment28

GHD

180 Lonsdale Street Melbourne, Victoria 3000 T: (03) 8687 8000 F: (03) 8687 8111 E: [email protected]

© GHD 2010


Document Status

Rev

No.Author

Reviewer Approved for Issue


T Pollock B Skarratt B Skarratt 5/10/2010

Final T PollockB Skarratt /

D Todd* D Todd *