mongolia · mongolia on 238 deposits and mines in 76 soums of 20 aimags and one ulaanbaatar...
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FINAL REPORT
ENKHBOLD Sumiya, National ESMP Specialist
Ulaanbaatar, Mongolia
September, 2017
CONTRIBUTION TOWARDS THE ELIMINATION OF MERCURY IN
THE ARTISANAL AND SMALL-SCALE GOLD MINING (ASGM)
SECTOR: FROM MINERS TO REFINERS PROJECT
MONGOLIA
ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
(ESMP)
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Contents
1. Brief Project Description and Framework of ESMP .......................................................... 4
2. Background ....................................................................................................................... 5
2.1. Artisanal mining in Mongolia .................................................................................... 5
2.2. Gold deposits in Mongolia ........................................................................................ 9
3. Policy, Legal, and Administrative Framework ................................................................. 10
3.1. Policy Framework ................................................................................................... 10
3.2. Legal and Administrative Framework ..................................................................... 12
3.3. Laws, Regulations, Guidelines and Standards ......................................................... 14
4. Environmental and Social Risk Screening ....................................................................... 16
5. Environmental and Social Impacts .................................................................................. 24
5.1. Positive Environmental and Social Impacts ............................................................ 25
5.2. Negative Environmental and Social Impacts ........................................................... 28
6. Potential Impacts and Mitigation Measures ................................................................... 39
7. Environmental and Social Risk Monitoring ..................................................................... 44
8. Capacity Development ................................................................................................... 47
9. Communication .............................................................................................................. 48
10. List of Document Consulted........................................................................................ 49
11. Annexes ...................................................................................................................... 51
Annex 1. Terms of Reference for National Environmental and Social Management Plan
Specialist............................................................................................................................. 51
Annex 2. Template for Environmental Management Plan.................................................. 57
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List of Figure, Table and Pictures
Figure 1. Mineral resource typr and location operated by artisanal miniers. .......................... 6
Figure 2. number of Artisanal and Small-scale Miners by Province ........................................ 7
Figure 3. Main operating areas of artisanal and small-scale miners. ...................................... 7
Figure 4. Number of artisanal miners. ..................................................................................... 8
Table 1. Registered gold deposits in Mongolia. ........................................................................ 9
Table 2. Gold sold to Mongola Bank ........................................................................................ 9
Table 3. Environmental and social risks, potential impacts and severity. .............................. 29
Table 4. Environmental and Social Risks and Mitigation Measures ....................................... 41
Table 5. Environmental and Susainability Monitoring .......................................................... 45
Picture 1. Ms. Enkhtuya, Head of the local ASGM operating in Sangiin stream of Yeruu
Soum, Selenge Province. ........................................................................................................ 18
Picture 2. Front and side look of “guitar gun” ...................................................................... 18
Picture 3. Process of sluicing and panning of gold ore in placer mining ............................... 19
Picture 4. ASGM camps in Sujigt hard rock mining site......................................................... 21
Picture 5. Mr. Batbaatar’s camp and mining shaft, he has been working on last 1.6 years. .. 21
Picture 6. “Mandal Khishig Khairkhan” ore processing plant, onwed by local ASGMs in Mandal Soum ......................................................................................................................... 22
Picture 7. Privately owned ore processing plant in Mandal Soum ......................................... 22
Picture 8. Shaking table installed in machine. Private a a side of milling plant ..................... 23
Picture 9. “HAMO” ore processing plant in Bor-nuur soum ................................................. 24
Picture 10. Shaking table uninstalled and set aside................................................................ 28
Picture 11. Land degradation in small-scale mining area, Sangiin river, Yeruu soum, Selenge
province .................................................................................................................................. 31
Picture 12. Abandoned small-scale mining area, Khuder soum, Selenge province ................ 32
Picture 13. Deforestation near Sujigt hard rock mining site, Bor-nuur soum, Tuv province .. 32
Picture 14. Colored Khuder river, Selenge Province ............................................................. 34
Picture 15. Ground water used for ore processing and no recycling of waste water. Gold ore
processing plant, Bor-nuur soum ........................................................................................... 35
Picture 16. Hard rock mining site, Bor-nuur soum, Tuv province .......................................... 37
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1. Brief Project Description and Framework of ESMP UNIDO and UNEP, in association with the Ministry of Environment, Green Development and
Tourism of Mongolia are currently co-implementing a GEF child project (under the
programme: Global Opportunities for Long-term Development of ASGM Sector: GEF GOLD)
entitled Contribution towards the elimination of mercury in the ASGM sector: from miners to
refiners. The programme’s objective is to reduce the use of mercury in the ASGM sector
through (i) facilitation of access to finance for the introduction of low and non-mercury
technologies to artisanal miners and mining communities and through (ii) the development of
sustainable ASGM gold supply chains. The Mongolia child project is one of the eight child
projects in the programme with its specific objective to contribute to the elimination of mercury
in ASGM by applying a value chain approach from the miners to the refiners.
The project is a 5 year technical assistant project anticipated to begin in beginning of 2018.
Over a period of five years, the project aims at the following four components:
1. Legal framework and formalization: Review of policy and legal framework
supporting formalization of the sector;
2. Financing: Introduction of financing schemes allowing miners to adopt and
subsequently invest in mercury free technologies in a sustainable manner and access
international gold markets more directly;
3. Technology transfer: Upscale mercury free technologies and support the development
of health programmes for the ASGM sector; and
4. Knowledge management: Develop a communication strategy in order to replicate the
project activities in the participating countries and contributing to the global knowledge
management platform established under the global child of the GEF GOLD
programme.
The project has been classified as “Risk level B” according to Environmental and Social
Safeguards Policies and Procedures of UNIDO, where an environmental and social
management plan (ESMP) is needed during the preparatory phase of the project to integrate
environmental and social sustainability elements into project design. The basis of this rating is
that the project consists largely of technical assistance activities, likely impacts will be few in
number, site-specific, and few if any will be irreversible.
The objective of the ESMP is to ensure that the implementation of the GEF GOLD Child project
will be carried out in an environmental and socially sustainable manner. During the prepratory
phase, screening for environmental and social impacts carried out to identify any adverse
impacts that might be associated with the project so as to avoid, minimize and mitigate such
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impacts. This ESMP provides the project implementers with an environmental and social
screening process that will enable them to identify, assess and mitigate potential environmental
and social impacts of the project.
The locations and types of detail activities of the project are not defined yet, and therefore
potential impacts cannot be precisely identified. Therefore, this report summarizes the initial
scoping of broader environmental and social (E&S) issues related to ASGM activities in hard
and placer gold mining areas in Selenge and Tuv provinces of Mongolia. These broader E&S
issues and proposed mitigation measures needed to be examined in detail during GEF GOLD
Child project implementation.
This ESMP builds on the earlier documents, prepared for GEF GOLD Child project,
findings of existing information provided by ASGM Umbrella organization, relevant
publications and previous studies conducted by different international organizations. Extensive
consultations were held with local government, artisanal miners, ASGM Umbrella organization
and local people in mining areas to identify negative environmental and social impacts of the
project. These consultations were made through field visits conducted in ASGM hard rock and
placer gold mining sites in Bornuur Soum of Tuv Province, Mandal and Yeruu Soums of
Selenge Province.
The draft ESMP of the project was presented during GEF GOLD Mongolia-Philippines
Working Meeting and Launch held in Ulaanbaatar on 21-22 June, 2017 and National validation
workshop organized on 29 August 2017 to involving all relevant stakeholders of Mongolia and
representatives of Philippe, the representatives of relevant ministries, ASGMs, ASGM umbrella
organizations, NGOs and other stakeholders. Participants were given time for questions and
comments on the potential negative environmental and social impacts and proposed mitigation
measures.
2. Background
2.1. Artisanal mining in Mongolia
An abrupt transition of the society in the 1990ies led to the halt of numerous state-owned
factories and institutions aggravating unemployment and poverty around the country and
conditioning certain societal layers to earn their lives by virtue of manual exploration of mineral
resources. In the early 2000 harsh natural phenomena in the face of dzud and drought wrecked
thousands of herders, whose livelihoods were totally dependent on livestock and farming and
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was detrimental to the increase of poor households and unemployed, who had no choice but to
turn into individual miners to generate income somehow.
It is generally believed that the first occasion of such individual mining was recorded in the
area nearby Boroo Gold mining site in Bayangol soum of Selenge aimag in 1997. Since that
time in 1999 groups of individual miners have begun mining gold on the mine sites and
technological wastes abandoned by gold mining companies in Zaamar soum of Tuv aimag.
Individual miners usually mine mineral resources such as gold, coals, fluorspar, salt for direct
income in their respective soums or in the areas with easy access exposures. Majority of
individual miners operate in Bayankhonogr, Uvurkhangai, Dornogobi, Khentii, Tuv, Selenge
and Darkhan-uul aimags. (See Map 1) Primary types of mineral resources mined by artisanal
and small-scale miners around the country are gold, coal, fluorspar, wolfram, tin, limestone,
precious stones, salt.
Figure 1. Mineral resource typr and location operated by artisanal miniers.
According to the survey made by the National Statistical Office 3.4 thousand (25.3%) from
13.4 thousand citizens surveyd are located in the western region, 4.0 thousand (29.7%) in the
khangai region, 4.4 thousand (32.9%) in the central region, 0.4 thousand (2.7%) in the eastern
region, and 1.3 thousand (9.4%) in Ulaanbaatar (See Map 2).
The centralization of artisanal and small-scale miners has a tendency to depend on the type of
available mineral resources, whereas the plurality of artisanal and small-scale miners are
localized in Bayankhongor, Tuv, Uvs, Selenge and Khuvsgul aimags and Ulaanbaatar city,
where the highest amount of deposits of prevailing minerals such as gold and coal is available.
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In contrary in the eastern region aimags, where deposits of fluorspar and wolfram are
dominating, the number of artisanal and small-scale miners is lesser.
Figure 2. number of Artisanal and Small-scale Miners by Province
Source: National statistical office
Figure 3. Main operating areas of artisanal and small-scale miners.
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In connection with high gold rate at the market, its easy cash potentiality and convertibility
most miners participating in artisanal and small-scale miners operate in hard rock and placer
gold mining. According to the survey report made by the National Statistical Office of
Mongolia on 238 deposits and mines in 76 soums of 20 aimags and one Ulaanbaatar district,
78.2 percent of total artisanal and small-scale miners operate in gold mining.
Since 1990 total gold mining has been gradually increasing reaching its peak in 2006 when an
estimated number of artisanal and small-scale miners amounted 100,000. However due to
changes made in respective legal framework regulations gold mining and marketing in 2007-
2012 have dropped and thus shifted into illegal trading. Such illegality created difficulties to
accurately determine number of artisanal and small-scale miners and gold mining and related
data and information were bias. According to the report from the Mineral Resources and
Petroleum Agency of Mongolia (MRPAM) as of 2015 over 30000 individuals are seasonally
involved in gold mining around the country.
Figure 4. Number of artisanal miners.
Within the period from 2006 to 2009 number of artisanal and small-scale miners decreased
twofold from 65.6 thousand to 29.8 thousand, as a result of introducing Windfall tax, which cut
gold mining operation and made to shift into informal. The government approval of the
Regulation 308 “Extraction operations of minerals from small-scale mining” in 2010 promoted
the increase of the number of formalized artisanal and small-scale miners and resumed their
operation.
As of today in total 6200 individuals from 69 formalized NGOs and 429 partnerships, legally
and stably operating, are official members of ASM Federation.
65.6
59.3
48.9
29.834.8
40
30
0
10
20
30
40
50
60
70
2006 2007 2008 2009 2010 2013 2015
Ир
э т
, я
а
О
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2.2. Gold deposits in Mongolia
According to data available at Mineral Resources and Petroleum Agency of Mongolia
(MRPAM) as of September 2014 in total 117 hard rock, 664 alluvial gold deposits and 1763
gold exposures have been identified around Mongolia. From total gold exposures 15 percent
are hard rock and 85 percent compose placer gold, which indicates that almost 90 percent of
gold resources are composed of hard rock deposits (MRPAM, 2014). Gold 2025 baseline
survey conducted by MRPAM quotes that in 7-8 years the operation at placer gold mining is
likely to shrink down or cease due to decrease in its deposits and less probability to discover
new ore. In 2014 27.6 tons of placer gold, 224.2 tons of hard rock gold, 1101.3 tons of other
metals containing gold and all in all over 2000 tons of gold reserves were registered.
A survey “Socio-economic and livelihood study of artisanal and small-scale miners” revealed
that ASMers on average produce 0.4 grams per day, working approximately 20 days/month for
four months of the year. Consequently a paper “Policy recommendations on artisanal gold
supply chain and its contribution to macroeconomic development” specifies that based on these
figures it can be estimated that the number of gold mined are 2.1 thousand tons in 2006, 1.9
thousand tons in 2007, 1.6 thousand tons in 2008, 0.9 thousand tons in 2009, 1.7 thousand tons
in 2010, 1.3 thousand tons in 2013 and 0.9 thousand tons in 2014. During 2006-2009 the amount
of gold produced by artisanal and small-scale miners declined, however resumed from 2010.
Table 1. Registered gold deposits in Mongolia.
Type of Gold Deposit 1991 1997 2014
#
deposit
Reserve,
tonn
#
deposit
Reserve,
tonn
#
deposit
Reserve,
tonn
Placer 156 90.3 498 206.25 608 27.6
Hard rock 15 50.2 31 127.8 75 224.2
Gold and other metal
containing deposit
- - - - 17 1101.3
Total 171 140.4 529.0 334.05 699 1353.1
Source: Mineral Resources and Petroleum Agency of Mongolia (MRPAM), 2015
Table 2. Mongolbank’s gold purchase
Year 2010 2011 2012 2013 2014 2015
1 Total purchase 2.1 3.3 3.3 6.0 12.7 12.9
2 Artisanal miners and Individuals 0.004 0.243 0.014 0.005 3.2 5.9
3 Number of artisanal miners and
Individuals
7 179 11 3 1102 1723
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4 Percetage of artisanal miners and
Individuals
0.2 7.4 0.4 0.1 25.5 45.7
In 2013 three ASMers/individuals sold 5 kg of gold, in 2014 1102 ASMers/individuals sold 3.2
tones and as of October 2015 in total 1723 ASMers/individuals sold 5.9 tons of gold to Mongol
Bank. Gold sold by ASMers/individuals in 2015 is by 2.7 tones or by 80 percent higher than it
was in 2014.
According to MRPAM, since the approval of the Government Resolution 308 in 2010, by the
first quarter of 2015 in total 976.13 hectares of land or 72 fields in 27 soums from 12 aimags
were allocated for ASM purpose. ASM Federation quotes that MRPAM issued permissions for
85 fields by the end of 2016. According to informal sources of the Ministry of Mining and
Heavy Industry the number of lands increased to 120 in 2017.
3. Policy, Legal, and Administrative Framework
3.1. Policy Framework
Individuals have started engaging in gold mining since 1990. At that time due to unavailability
of relevant legal regulations and informality from the state in general such groups of people
were called as informal gold miners or individual gold miners, or informal employers. The
formalization and policy support has become possible with the adoption of the revised Minerals
Law and the approval of the Government Resolution on 308, which defined the determination
of artisanal and small-scale mining as “the mineral exploration activity of individuals organized
in the form of unregistered partnerships as stated in 481.1, cooperatives stated in 36.4, and
partnerships stated in Article 35 of the Civil Code, to extract minerals from economically
inefficient deposits with non-industrial reserves, fields or prospects derived from industrial and
technological wastes, on the land allocated for the purpose stated in Clause 16.1.11 of the Law
on Land.” As stated, artisanal and small-scale miners should be organized into unregistered
partnerships in order to legally engage in the extraction of minerals.
Afterwards the approval of the Resolution 308 the Regulation for Minerals Extraction by
Artisanal and Small-Scale Mining was issued. According to this Regulation people who have
the right to extract minerals by ASM and formally organized into partnerships need to conclude
a tripartite cooperation agreement with license holding mining company and local government.
Such tripartite agreement contains all aspects of cooperation such as the purpose of agreement
and the themes related to the official and legal trading of mined gold to official legal bodies.
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In May 24, 2017 the Resolution 308 was repealed by the Government Resolution 151 and
Regulation was amended accordingly. The main changes in the Regulation include:
Registered partnerships had to apply for new land through soum level governor, who submit
the request on making conclusion to MRPAM. By the newly approved regulation the soum
governor shall submit the request on making conclusion of a specific area to aimag Governor.
Number of partnership or unregistered partnership members shall not be less than 9 (A
partnership shall have a minimum of five members – previous regulation); Artisanal mining
legal entity organized into partnership or cooperative may use not more than 2 mechanisms
with the engine capacity up to 3500 sm³ for minerals extraction operation (previous regulation
- The use of machinery with an engine capacity exceeding 500cm³ for the extraction of
minerals); An area to be used for artisanal mining purpose shall not exceed 5 hectares; to make
a contract with the applicant Artisanal mining entity on extraction of minerals by artisanal
mining with duration till mineral resources extracted completely (previous regulation - the
governor shall make a contract with the applicant partnership on the exploitation/extraction of
minerals from the small-scale mine for the duration of one year); artisanal and small-scale
miners are obliged to conduct rehabilitation activities.
According to the Law on Personal Income Tax for Citizens with Indefinite Income from Private
Business and Services every artisanal and small-scale miner is charged with monthly 53000
MNT as tax.
In October 10, 2013 Mongolia joined the Minamata Convention on Mercury and further ratified
its implementation by the Parliament in April 30, 2015. From 2008 Mongolia totally banned
the use mercury in any form in mining extraction, production and processing. The Law on
Hazardous and Toxic Chemicals, amended by the Mongolian Parliament in 2006, regulates all
aspects concerning the export, import and transportation of toxic chemicals across the borders
of Mongolia and production, storage, trade, transport, use, removal and control on thereof.
According to this Law The State Administrative Central Organization in charge of environment
shall exercise all powers upon coordination of activities related to hazardous and toxic
chemicals.
The Government of Mongolia approves the list of prohibited and restricted hazardous and toxic
chemicals. Mercury and its organic and non-organic compounds are included in the List of
chemicals restricted on the territory of Mongolia, approved by the Government resolution 176
issued in 2011. In addition, the Order 135, issued by the Minister of Environment in 2008,
prohibits the use of mercury in mining extraction, production and processing.
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The Article 3.1.2 of the State Policy on the Mineral sector, which was approved by the
Parliament resolution 18 in 2014, stipulates “To support cooperation and legal organization of
artisanal miners by the state policy and by improving related legislative regulation”.
Currently there are no concrete independent policy documents that support artisanal and small-
scale mining solely; such regulations are embedded into concerning laws and regulations as
amendments and through regulations. For instance:
The Law of Mongolia on Amending the Minerals Law
Law on on Amending the Minerals Land Law
Law on Personal Income taxation of individuals with indefinite income
ASM regulation
Orders of the Chief of MRPAM to approve rules, instructions, forms and agreement
templates.
Frugal rehabilitation methodology.
3.2. Legal and Administrative Framework Ministry of Mining and Heavy Industry, The Ministry of Environment, government
implementation agency MRPAM are the main government institutions in charge of regulating
mining sector’s policy, activities and related environmental issues upon respective functions.
The Ministry of Environment, through validating environmental impact assessment in the scope
of its functions, apart from monitoring and supervising mining impact on environment and
natural resources is in charge of elaborating mining rehabilitation plans and relevant
environmental regulations and standards.
The Ministry of Mining and Heavy Industry, as the state administrative institution in charge of
determining gold sector policy, monitors and supervises policy implementation and is in charge
of ensuring coordination of involved stakeholder institutions.
The Minerals Authority supports efforts for development of State policy in development of
geology and mining sector, offer efficient and fair services to investors and consumers, acting
as an implementing Agency under the Ministry of Mining and through implementation of State
policy assist in efforts to increase the effects deriving from minerals for the benefit of national
economic development, within the context of the Minerals Law, Law on Land, procedure for
their implementation, Government action plan and Ministry of Mining policy paper MRPAM
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provides relevant information on artisanal mining, implementation of policy document,
provision of services for special licenses.
In line with the ‘Procedure on artisanal mining’, Governors and Citizen’s Representative
Khural at soum and district levels are regarded as the primary level state organizations directly
engaged in activities related to mining and trading by artisanal miners, forming agreements
with artisanal miners and partnerships. Local Citizen’s Khural exercise the right to take part in
the activities of artisanal miners through providing assistance in defining mineable locations
and their coordinates through sending permission to the Minerals Resources Authority and
monitor implementation.
Based on the decision from the state administrative organization and the soum Citizen’s Khural,
Governors relate to artisanal miners through signing of tripartite agreement for artisanal mining
using an approved sample form.
In addition, the role of the governor is to monitor whether the process of local and international
projects taking place in respective soums and the involvement of concerned stakeholders are in
line with existing legal regulations effective in Mongolia and in case of failure or malfunction
to undertake necessary legal measures to redress the situation.
According to the Treasury Law of Mongolia Bank of Mongolia is responsible for buying and
selling, storing the gold and refining.
By law Bank of Mongolia buys gold from entities, artisanal and small-scale miners and
middlemen. Bank of Mongolia has the right to store gold at its own facility or at commercial
banks.
Bank of Mongolia is verifying assay result of smelted and refined gold at the precious metal
lab. Assay inspection department is arranging the gold payment and also charging 2.5% of gold
royalty rate and transferring to the Taxation department’s gold sellers’ account.
Gold price is set by Bank of Mongolia based on the previous day’s LBM gold price quotation,
less USD 3 per ounce as the refining charge and converted to Mongolian MNT according to
the USD/MNT exchange rate, announced by Bank of Mongolia. Smelted and unrefined gold is
sold at a price 0.2-0.25% lower than the world gold price. The above price margin is covering
storing, transportation and refining cost of the Bank of Mongolia. Gold smelting and assaying
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is possible only in Ulaanbaatar city; it takes about 2-3 days to undergo all procedures and only
after gold is delivered to Bank of Mongolia.
3.3. Laws, Regulations, Guidelines and Standards
Below are law articles and regulations, which regulate ASM operation:
The Law of Mongolia on Amending the Minerals Law
The following terms used in this law shall mean as specified below:
4.1.23 defines 'conducting artisanal mining' as follows: the mining activities of individuals
organised as a 'cooperative' as set forth in Article 36.4, a 'partnership' as set forth in Article 35
or as an 'unregistered partnership' as set forth in Article 481.1, of the Civil Code, involving a
deposit where it is unprofitable to produce a mining plant or an area formed up by industrial
waste”
“11.1.23. Receive an official request from soum or district governors; issue opinion on whether
the selected land area overlaps wholly or partly with any part of a restr icted or prohibited area
for mineral exploration and mining, reserved land for special needs or any area subject to a
valid exploration license; and set the size and boundar ies of the land, according to Clause
12.1.5 of this law”
“12.1.5. Submit requests to the government author ity for the opinion stated in Clause 11.1.23
of this law with regard to the selected land area to be allocated for the purposes specified in the
Clause 16.1.11 of the Law on Land”
“66.1.9. The following penalties shall be imposed on those who breach the Regulation on
Extraction of Minerals from Small-Scale Mines: A citizen shall be fined by tugrug equal to 5-
10 times the minimum level of the monthly wage; an official 10-20 times the minimum level
of the monthly wage; a legal entity 30-40 times the minimum level of the monthly wage”.
Article 2:
The relations with respect to the extraction of minerals from small-scale mines shall be
governed by a regulation and the regulation shall be approved by the government.”
Article 3:
Replace article 11.1.22 with 11.1.23, replace the word “without special licenses” in 7.3 with
“without special license other that ASM permission”. (11.1.23. Receive a official request from
soum or distr ict governors; issue opinion on whether the selected land area overlaps wholly or
partly with any part of a restr icted or prohibited area for mineral exploration and mining,
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reserved land for special needs or any area subject to a valid exploration license; and set the
size and boundar ies of the land, according to Clause 12.1.5 of this law)
7.3. Conducting exploration or mining without a valid license is prohibited except in the case
of small-scale mining. The collecting and mining of natural stones and gemstones shall be done
with licenses as with other conventional minerals
Article 4:
The current law shall become effective once the Law on Amending Land Law, enacted in July
01, 2010, enters into force.
Law on Amending Land Law:
Amendment 1
To add Clause 16.1.11 into Article 16: land allocated for ASM purpose. (16.1.11 Land allocated
for small-scale mining purposes).
Amendment 2:
In Article 16.2 to add a word “district” after “soum”; to add “16.1.11” after 16.1.7 (16.2.
Aimags, the capital city, soums or distr icts may take land areas for their local special needs
within their jur isdiction for the purposes specified in Clauses 16.1.1, 16.1.6, 16.1.7 and 16.1.11
of this law)
Law on Amending Land Law PIT Law:
Amendment 1:
In the Article 5.1 to add the following table as a line 16 as indicated below:
Amount of monthly rate imposed to people with indefinite income
№
Type of
business
service
In
Ulaanbaatar
city
In Nalaikh, Baganuur,
Darkhan-Uul, Orkhon and
soums with permanent border
points
Other
aimag
center
soums
In other
places
16 Small-scale
miners - 53000 53000 53000
Amendment 2:
The Law shall become effective from October 21, 2010.
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ASM Regulation
The purpose of this Regulation is to regulate relations with respect to the extraction of minerals
from small-scale mines. It shall be applicable for small-scale mining of all types of minerals
except water, ore bearing radioactive elements, petroleum, and natural gas. The regulation
covers all aspect of ASM in terms of concluding an cooperation agreement, mining area for the
extraction, application for the conclusion of contracts, responsible parties, roles and duties of
relevant stakeholders, locations of gold production and processing, commercialization of
extracted mineral resources, application procedure for land and its allocation, prohibited
activities for the extraction in ASM. It also includes points related to penalties and special
conditions if partnerships haven’t undertaken environmental rehabilitation in accordance with
established guidelines.
4. Environmental and Social Risk Screening
Over a period of five years, The GEF GOLD CHILD project aims to following outcomes:
1. Formalization
The project aims to aid the government in formulating economic incentives that will help
persuade miners to formalize. This will be accomplished through building the capacities
of relevant stakeholders, and reviewing existing relevant policies and regulations to ensure
that they are aligned with the needs and the capacities of small-scale mining communities.
2. Market Access
The project aims to aid national governments in the creation of ASGM funds to support
miner formalization as well as improved market mechanisms to facilitate better
partnerships between the private sector and the ASGM communities. A key component of
the project is to improve miner access to relevant national institutions and formal markets.
3. Improved Practices
The project will also support the improvement of mining practices and working conditions
through the promotion of mercury-free alternatives. Additionally, the project hopes to help
miners gain valuable knowledge that can help them improve their lives. This includes
improved knowledge on legal, administrative, management, and environmental practices
for both women and men ASGM stakeholders.
4. Communication
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The project aims to improve outreach activities across ASGM stakeholders by improving
communication mechanisms and providing valuable information and updates through trade
journals, and web-based services.
The expected outcomes of the current project is to create conditions for the eradication of the
illegal use of mercury by artisanal and small-scale miners by acquiring knowledge and
exercising an environmentally-friendly and more appropriate gold extracting technologies. As
a result it is potential to drastically eliminate the adverse impacts of mercury on human health
and the environment.
This section of the document summarizes the initial scoping of broader environmental and
social issues in the selected ASGM mining areas. Small-scale gold mining areas are active in
many parts of Mongolia, from Gobi desert in south, high mountain areas in west and forest land
in the north. Mining sites in in Bornuur soum of Tuv Province, Mandal, Yeruu, Khuder soums
of Selenge Province were visited and these areas are oldest and well known ASGM areas in
Mongolia.
ASGMs are undertaken using simple methods and basic equipment due to lack of capital to
acquire new and modern equipment compared to formal mining companies. Mining activities
usually undertaken to recover easily accessibly deposits closer to the surface. As gold deposit
get deeper, mining becomes difficult and expensive, requiring significant capital and time,
which is beyond the capacity for majority of ASGMs.
ASGMs are active in both placer and hard rock mining and environmental and social issues are
slightly different depending on technologies and equipment used in gold extraction.
Field mission in placer gold mining
The main purpose of the mission was to explore mercury-free extraction practice in placer gold
mining deposit, interview with artisanal miners and to identify main environmental risks in the
selected sites. The field mission was carried out during 15-18 August by Mr. Enkhbold Sumiya,
ESMP expert. ASM Umbrella Federation suggested to visit placer gold mining sites in Bugant
and Yeruu soums of Selenge province. These sites are located at headwaters of Bugant and
Yeruu river basin and have been exploited number of years by ASGM as well as licensed
mining companies.
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Artisanal miners mainly work during the period of May to October; usually operate with 4-6
members. All camp had a hand made water gun (local name “guitar gun”) for sluicing of ore,
crawler excavator with 1.2-1.4 m3 capacity bucket, 2 water pumps and a car for transporting
people and fuel (Picture 1 ,2)
Picture 1. Ms. Enkhtuya, Head of the local ASGM operating in Sangiin stream of Yeruu Soum,
Selenge Province.
Her group has 6 members – 2 excavator operators, 2 assistants and a cook). She rents excavator
from a company in Ulaanbaatar. Rent cost vary between 12-18 million MNT (approx.. 4900-
7300USD) per month including a operator. Medium capacity excavator uses 200 litre diesel for 12
hours.
In these region, ASGMs a handmade water gun (guitar gun) for sluicing and it captures the
fairly course gold grains. It was not possible to assess recovery rate and content of the fine-
grained gold in the ore. Artisanal miners claim that the guitar gun is best suited this placer gold
deposit compared to other sluicing equipment they have tried before.
Picture 2. Front and side look of “guitar gun”
Mining camp operated by Mr. Ayush was agreed to show process of extracting gold using guitar
gun on his site. It was apparent that gold was extracted without using mercury. ASM Umbrella
19
Federation also claims that mercury does not used in placer gold mining deposits in Northern
Mongolia (Picture 3).
Picture 3. Process of sluicing and panning of gold ore in placer mining
During the field mission 5 artisanal mining camps were visited, most of the miners were very
sensitive to outsiders and refused to talk or pictures taken. ASGM are very much aware that
they need land license and contract with local government to operate. Some interviewers say
that central and local governments are too slow and it is very time consuming process to obtain
all necessary permits. Instead local miners operate illegally. Due to their illegal status, many
small-scale miners are harassed by officials and often they caught and fined. After lengthy talk
explaining purpose of the trip and promises not share any information with local enforcement
organizations, 2 mining camps were agreed to give interviews and take pictures of their
equipment and techniques used for gold extraction.
ASGM operate randomly to explore gold in their areas. Due to uncertainy on quantities minable
and also locations of the ore, it is very risky for them cuasing many of them to leave behind
unrestored land and causing environmental impacts.
20
Field mission in hard rock mining
The use of mercury in Mongolia spans the last century with a long and controversial history.
First recorded use of mercury in gold production has been linked with a German-Russian-
Mongolian joint venture named Mongolor that began using mercury in 1913 for hard rock gold
amalgamation. Mongolor operated in the Boroo river basin, today known as Mandal soum
(administrative unit for village), a territory in Selenge province. A crack in the amalgamating
tank in 1956 released a large amount of mercury and formed a significant anthropogenic
mercury deposit in the Boroo river basin. Based on the 2000 field observations, the authors
suggested that upon the extent of mercury panning and mining in the area by informal miners
that up to 10 tons of mercury were present in the Boroo area. Following a detailed assessment
in the Boroo river basin area it was revealed that the production‘s ruins were most exposed to
the pollution with mercury concentrations reaching 117 mg/kg or more than 50 times the
regulatory limit (2 mg/kg for soil). Contaminated water was detected 10 km downstream from
the accident site. In the sediment samples, mercury content was found to be an alarming 10-
25,000 times higher than the permissible level. This can potentially be attributed to mercury
build up from irrigation with contaminated water from the nearby river. This research
concluded that since the accident 50 years ago, the mercury contamination has been spreading
over 40 km in the river and 2-3 tons of mercury are estimated to persist in the broader vicinity
of the Boroo site.
After nearly 60 years, the legacy of the Boroo mercury accident remains one of the worst
environmental accidents in Mongolian history and poses significant levels of risk to the
environment and the public health of communities throughout the Selenge watershed. More
specifically, the Boroo river flows through the main agricultural region of the country and
drains into the Kharaa river where the most fertile agricultural land exists. Today, large
quantities of wheat and vegetables are produced in the area and many farmers continue to use
potentially contaminated water to meet irrigation requirements. Small agricultural systems in
this area supply the agricultural products not only for the local residents but also for larger
urban centers such as Ulaanbaatar and Darkhan, extending the potential health risks from
contaminated crops far beyond the origin of the Boroo site.
Planned field mission carry out between 05 - 09 June, 2017 from Ulaanbaatar (capital city) to
Bornuur tunkhel 113 km – Mandal Soum (former Zuunkharaa) 94 km then back to Bornuur -
Ulaanbaatar. Sites I have visited located in Boroo river basin, which has relatively long history
of ASGM activity and mercury contamination.
21
We have visited Sujigt hard rock mining site used by local ASGMs in Bor-nuur soum. The site
located within the edge of Centerra Gold Mongolia Co.,Ltd licensed area - #194A. Centerra
Gold Mongolia is foreign invested and one of the biggest and oldest gold mining company in
Mongolia (Picutre 4).
Picture 4. ASGM camps in Sujigt hard rock mining site
There are 20-30 ASGM working in Sujigt site in laws few years. We welcomed by Mr.
Batbaatar, local ASGM and also he is a member to local ASGM organization (Picture 5).
Picture 5. Mr. Batbaatar’s camp and mining shaft, he has been working on last 1.6 years.
In hard rock mining shafts are dug using with simple tools by hand and depth various depending
on the richness of the site. Explosive materials are prohibited for ASGMs. In hard rock mining
22
site land degradation is rather limited compared with placer gold mining. Mining safety is a
concern. The lack of personal protective equipment and poor secure of roofs and walls of
tunnels increases risk of injury.
Extracted ore is carried to the surface by hand and broken to centimeter sized rock at the site.
Then transported to nearest milling plant for further processing. There are 3 ore processing
plant in Mandal and Bor nuur soums (Picture 6, 7)
Picture 6. “Mandal Khishig Khairkhan” ore processing plant, onwed by local ASGMs in Mandal Soum
Picture 7. Privately owned ore processing plant in Mandal Soum
Local ASGMs bring their ore for milling and they pay small fee for using facility based on
amount of ore by bag or kg. The crushing ore into sand sized using milling machines called
“bigun teerem” and sluiced. Each processing plant has 2 milling machines with sluicing line.
Ground water used for ore processing. Water consumption is high, no water use agreement is
made, and water pond is not insulated as it should be by the standard, water cleaning technology
is non-existent.
23
As to the use of chemicals, although it was stated that nitric acid is used for gold catching, there
were no special permission obtained to store this substance, and no records of its use, volume,
storing and disposal were found.
After milling and sluicing, gold rich ore “black powder – schlich” recovered from the rubber
carpet installed bottom of the sluicing line. Then mercury used recovering gold from black
powder. It is mixed with black powder, then burned with a blowtorch to evaporate mercury in
the air. Use of mercury is common among ASGMs, because it is easy to apply, hide and buy
from black market.
Shaking table is only available mercury-free technology to recover gold from black powder for
small scale miners. Both plants have shaking tables, however, it was not operating during our
visit. Operators explained that it was too difficult to fine tune the equipment (Picture 8).
Picture 8. Shaking table installed in machine. Private a a side of milling plant
“HAMO” ore processing plant was established in February 02 2009 with the support from SDC.
Processing plant has 8 milling machines with sluicing lines, however, most of them are out of
use and only 2 milling machines are operating. Milling machines are manufactured in China
24
and it is prohibited to import in few years ago by the decision of Government in order to stop
use of mercury in ASGM (Picture 9).
Picture 9. “HAMO” ore processing plant in Bor-nuur soum
Ground water used for sluicing. Concrete sealed ponds established for recycling waste water.
No water counter is installed. Washing ore consumes a lot of water, some research suggest that
about 200 litres of water used for a 50 kg of ore.
5. Environmental and Social Impacts
The purpose of the field mission was to develop ESMP for the Environmental and Social
Management Plan for the Contribution towards the Elimination of Mercury in the ASGM
sector: from Miners to Refiners project for Mongolia part. The Environmental law and Law on
Environmental Impact Assessment prescribe details procedure and requirement for mining
projects. However, current law and regulatory framework is not designated for the small-scale
or artisanal mining activities. In the case of the GEF Child project, the location of proposed
activities have not selected yet at this time. Therefore the potential environmental and social
25
impacts of the project activities cannot be identified and assessed according to existing laws
and regulations. This ESMP provides list of potential environmental and social impacts of the
project that are identified through an environmental and social screening process in selected
ASGM sites.
Extensive consultations were held with local government, artisanal miners, ASGM Umbrella
organization and local people in mining areas to identify negative environmental and social
impacts of the project during preparation of this report. These consultations were made through
field visits conducted in selected sites in Selenge and Tuv province of Mongolia. Review of
existing information and publications and previous studies conducted by different international
organizations.
The draft ESMP of the project was presented during a project inception workshop held in
Ulaanbaatar on 21-22 June, 2017 involving all relevant stakeholders of Mongolia and
representatives of Philippine and National validation workshop organized on 18 September
2017 to the representatives of relevant ministries, ASGM, ASGM umbrella organizations and
other stakeholders. Participants were given time for questions and comments on the potential
negative environmental and social impacts of the project and proposed mitigation measures.
The ESMP provides the project implementers with an environmental and social screening
process that will enable them to identify, assess and mitigate potential environmental and social
impact of the project activities.
The ESMP outlines a) list of potential negative environmental and social impacts with a rating
b) proposed mitigation measure that can be applied and adopted.
5.1. Positive Environmental and Social Impacts The technical assistance and strengthening of the ASGM sector through GEF GOLD CHILD
project will provide significant change towards reducing and eliminating mercury use in the
country as well as formalization of the sector.
Based on proposed activities, the project will positively impact the ASGM sector through
improved regulatory framework for small-scale miners, better formalization of artisanal mining
sector, creation of harmony between relevant ministries, local government and ASGM, creation
of opportunities to access better technologies, world market, financial assistance and increased
awareness and capacity to manage and monitor environmental and social issues in ASGM
sector.
26
E&S risks Root cause Impact Severity
Illegal use of
mercury in gold
processing
- Non compliance
- Lack of financial resource
to use alternatives
- Lack of access to mercury
free processing facilities
- Lack awareness of risks
of using mercury!
- Land and water
pollution
- Air pollution by
fumes
- Health impacts
HIGH
A baseline assessment published in 2006 by the International Labor Organization (ILO)
indicated that the use of mercury was restricted largely to hard rock sites in Selenge and Tuv
provinces. Mercury was used in the amalgamation process to separate the gold from the ore,
posing multiple health risks arising from skin exposure to metallic mercury, inhalation of
mercury vapor, and severe environmental contamination.
At hard rock sites in Bornuur, near Mandal soum, it was found that 60 % of children working
at artisanal and small scale mining camps were directly involved in amalgamation with
mercury, woman and children often taking a lead role in the roasting process. An overwhelming
percentage of those surveyed were unaware of safety and health measures and standards that
are required for mining activities and oblivious to the risks associated with mercury. The two
primary sources of mercury used in hard rock operations came from illegal import and mercury
collected from the Boroo river basin by the illegal miners.
During the years 2008-2009, the Government of Mongolia implemented a decontamination
campaign on mercury polluted sites at the national level. However, in spite of these efforts the
Boroo river still remains contaminated with scattered mercury hot spots. Furthermore, the
cumulative impacts of illegal mining and mercury amalgamation in the Selenge and Tuv
provinces remain uncertain.
Recognizing the direct correlation between mercury and the mineral sector (both formal and
informal), Mongolian authorities adopted a zero mercury policy in 2008. The use of mercury
in mineral processing was formally banned and a paid information campaign among residents
to report illegal chemical (cyanide and mercury) storage and usage was announced. In the same
year national authorities mobilized efforts to remediate several contaminated sites polluted by
illegal use of hazardous chemicals. Based on a situational analysis in 2011, over 300 kg of
mercury were collected under this initiative. Also, in 2009 “Procedure(s) for Export, Import,
27
Transboundary Movement, Production and Trade of Toxic and Hazardous Chemicals” were
approved by the joint order of Ministers of Environment and Foreign Affairs, serving as a
mechanism to control the regulation of the export, import, transboundary movement,
production and trade of mercury containing compounds but national mercury management
remains an ongoing challenge.
A national mercury emissions inventory was developed in 2011 by MNET in cooperation with
the United Nations Institute for Training and Research (UNITAR) with financial support from
the US Environmental Protection Agency (US EPA). The inventory was based on United
Nations Environmental Programme (UNEP) toolkit for identification and quantification of
mercury releases, which served as a background document for the creation of a national
mercury risk management plan prepared by the Ministry also in 2011 in coordination with
UNITAR and the United States Environmental Protection Agency (US EPA). Estimated annual
mercury releases in Mongolia are 548.4 tons with gold extraction identified as the largest
contributor to national mercury emissions.
Artisanal and small-scale miners tend to widely use mercury in gold processing as it is
economically cheap, simple to use and its metal retaining capacity is high. In 2007 a Working
group consisting of representatives from Specialized Inspection Agency, The Ministry of
Environment, The Ministry of Industry and Trade, National Emergency Agency and State
Investigation department undertook a monitoring of the use and storage of hazardous and toxic
chemicals at entities, individuals and institutions operating mining activity on the territory of
Mongolia. As a result in total 147 wheel mills that use mercury for gold extraction were
confiscated from individuals and demolished
Currently a shaking table is widely used as a mercury-free alternative technology for gold
extraction. However as the probability to find affordable shaking tables with higher gold
retaining capacity is low artisanal and small-scale miners hardly buy it as an alternative. Cheap
shaking tables that are easily available at the market are hardly used by miners due to very low
gold retaining capacity and questionable quality and high maintaining cost (usually made in
China) (Picture 10).
28
Picture 10. Shaking table uninstalled and set aside.
Unless the practice of systematic monitoring of ore processing plants and efficient technologies
are not promoted, a clandestine use of mercury is being frequently observed in the face of cheap
tools and equipment under the name of mercury-free processing plant.
5.2. Negative Environmental and Social Impacts
During screening and scoping conducted in the placer and hard rock gold mining areas have
identified many significant impacts that are generated by ASGM activities. The impacts range
from biophysical impacts to socio-economic impacts. The main issues were impact of the
mining activities on natural habitat including vegetation, forest, surface and ground water, soils
and air. Other concerns included direct and indirect impacts to the local community with
regards to health, employment, income, and safety (Table 3).
The project however, does not attempt to address all issues raised relevant to ASGM. These
should be further considered in the site specific detail Environmental Impact Assessment (EIA)
and Environmental Protection and Restoration Plan (EPRP) to be conducted during
implementation of the GEF GOLD CHILD project.
The report compiled broader environmental and social risks that are common to ASGM mining
areas. E&S risks categorized into as land degradation, environmental pollution and social
issues. Land degradation can occur during all project phases. The scale and form of degradation
differ from project activities and type of deposit. Environmental pollution refers to destruction
of environmental component such as water, air and soil. There are many other social issues
can be associated with ASGM activities, however, major common social problems are included
in the list (Table 3).
29
Table 3. Environmental and social risks, potential impacts and severity.
E&S RISKS IMPACTS RATING
I. LAND DEGRADATION
1. Abandonment of mine sites - Accidents to people and animals
- Visual impacts
- Degraded aesthetic value of the
land
HIGH
2. Deforestation surround mine site - Deforestation
- Soil erosion and loss of soil
fertility
- Loss of flora and fauna
HIGH
II. ENVIRONMENTAL
POLLUTION
3. Uncontrolled use of ground and
surface water. Mining and ore
processing within or near surface
water
- Surface and ground water
pollution
- Deterioration of aquatic system
- Depletion of groundwater
HIGH
4. Discharge of tailings and
contaminated effluents to the
environment.
- Surface and ground water
pollution
HIGH
5. Improper handling of chemicals
HNO3 - Nitric acid , Nа2B4O7 -
Sodium borate
- Surface and ground water
pollution
- Air pollution by fumes
- Human health
HIGH
6. Emission of air pollutants - Air pollution MEDIU
M
7. Improper handling of mined
materials (ore and waste rocks)
- Acid rock drainage
- Loss of soil fertility
- Air pollution
MEDIU
M
III. SOCIAL ISSUES
8. Improper handling of chemicals - Chemicals accidents and
injuries
- Human health
HIGH
30
9. Permission of sites - Conflicts and competition for
land ownership (120 sites)
HIGH
10. Occupational Health and Safety
Issues (lack of training, poor
ventilation, lack of safety equipment,
and out dated/old equipment)
- Accidents and injuries
- Loss of manpower
HIGH
11. Involvement of woman and
children in mining
- Gender Related Issues
- Exposure to accidents and
injuries
- Women discrimination
- Drop out of school
MEDIU
M
12. Increase number of artisanal
miners
- Competition/pressure on
available natural resources
MEDIU
M
13. Overpopulation at ASGM sites - Increased pressure on natural
resources
- Limited access to social services
- Insecurity and violence
MEDIU
M
Land degradation
Small-scale mining can cause great damage on land, particularly if they are located near
ecologically important areas such as headwaters of river, national and local protected areas.
The land degradation is a common phenomenon at many uncontrolled, unmonitored mining
sites. Miners leave behind disturbed landscapes consisting of unstable piles of waste,
abandoned excavations and vast stiches of barren land. Excavated pits are typically left unfilled
and abandoned to become polluted water pond. If mined site is not restored, environmental
impact is high and long term. Topsoil is removed during mining, and the land is degraded in a
degree of not capable of supporting plant growth and being left to exposed to erosion.
The removal of fertile layer of the soil to extract gold at placer mine damages land, causes
inevitable changes in soil biological structure and raises the risk of pollution and degradation.
Mining operations with disorganized land use impose a huge impact on human health and
occupational safety and cause environmental degradation; in most cases such lands are
31
abandoned without rehabilitation and this situation creates conflicts between mining
companies, government and local communities (Picture 11, 12).
Picture 11. Land degradation in small-scale mining area, Sangiin river, Yeruu soum, Selenge
province
It is common that the lands used for ASM purpose are also abandoned without rehabilitation.
As quoted in ASM regulation a partnership prior of handing over the land to local government
shall implement technical as well as biological rehabilitation in accordance with the
methodology, have it signed by local environmental inspector and only after that hand over the
land to the Commission established by the soum Governor. However, as the methodology to
undertake rehabilitation on ASM degraded lands is not approved and formalized and no legal
framework to conduct EIA is established, the fulfillment of this requirement remains
unsatisfactory.
32
Picture 12. Abandoned small-scale mining area, Khuder soum, Selenge province
During mining activity forest resources are being seriously destroyed and usually exploited for
fire making. It is inevitably required to define level of damage caused by ASM activity,
however so far no appropriate conditions are created with this respect (Picture 13).
Picture 13. Deforestation near Sujigt hard rock mining site, Bor-nuur soum, Tuv province
33
Risks Causes Impacts
1. Abandonment of
mine sites
- Inadequate awareness on legal
requirements
- Best practices and rehabilitation
methodology for small scale
mining sites
- Accidents of people
and animals
- Visual impacts
2. Deforestation surround mine site
for fuel wood, building of
temporary shelters and support of
mine shafts;
- Inadequate financial resources
to afford construction materials,
heating and cooking
- Deforestation
- Soil erosion
- Loss of flora and
fauna
Environmental pollution
If mining area is located near or headwaters of river, the drainage system is adversely affected
by small-scale mining operations. Rivers and streams are polluted by solid suspensions and
chemicals, which are commonly discharged into water bodies during sluicing process and
amalgamation. This in turn leads to siltation and coloration of surface water and potentially
pollute ground water resource (Picture 14).
The main technology to extract gold at placer ore is the use of water. It is considered this
technology to wash gold with water is less harmful as no chemicals are used. However it
drastically affects water flow, resources and quality. The tailings scattered to river banks and
sides increase deposits and slime in river water thus affecting its quality and composition.
Water is used at every step of gold processing, and this affects water resources. This is definitely
one of sensitive issues in regions where level of underground water is lower, the surface water
network is weak and hydrological conditions are unsatisfactory. Tailings have a feature to
penetrate into soil thus polluting it, degrading soil structure and consequently causing
underground water pollution.
34
Picture 14. Colored Khuder river, Selenge Province
The fact that water supply wells do not have passport and not equipped with water counters
clearly demonstrates that ore processing plants do not control at all the use of clean water they
use in processing. They may have a technological standard to reuse water strained from tailing
but it is impossible to determine amount of water that is reused, how much water is evaporated
from tailing reservoir, and how much is penetrated into soil. It is presumable that different
amounts of minerals and heavy metals are dissolved in tailing water. Consequently, as no
control and laboratory analysis are made on tailings, it is impossible to deny that such poisonous
liquid do not pollute soil, vegetation and water banks (Picture 15).
35
Picture 15. Ground water used for ore processing and no recycling of waste water. Gold ore
processing plant, Bor-nuur soum
Use and Handling of Chemicals
Depending on ore quality gold extracted through processing to some extent contains impurity,
so smelting of it with nitrogen acid is unavoidable. According to classification of hazardous
and toxic chemical substances nitrogen acid regarded to particularly toxic substances [5.1.1C],
6.1D, 6.9B, 8.1A, 8.2A, 8.3A, 9.1D. Therefore, it is most probable that its use, storage and
disposal may cause serious risks to the environment and human health. Nitrogen acid is highly
mordant and therefore, obliges certain storing requirements.
The nitrogen acid used for gold smelting afterwards releases NO2 which is poisonous and has
a strong smell. It is an air polluting gas which affects human lungs tissues in the event of
inhaling, increases the risk of airborne infections, causes breathing disorder and intoxication,
aggravates cardiovascular diseases.
In addition gold smelting with nitrogen acid releases a certain amount of acidic liquid. The
stockpiling of it without proper neutralization demonstrates a total lack of knowledge and
control. This as well increases the risk of poisoning for humans and animals.
36
Immediate Cause Causes Root Impacts
3. Uncontrolled use of
ground and surface water.
Mining and mineral
processing within/near
water sources.
- Non compliance
- Inadequate
awareness on water
sources protection
- Lack of monitoring
and enforcement of
regulations
- Surface and ground
water pollution
- Deterioration of aquatic
system
- Depletion of
groundwater
4. Discharge of tailings
and contaminated
effluents to the
Environment.
- Current EIA system is
designated for formal mining
- Inadequate financial
resources for mine wastes
management;
- Inadequate awareness on
handling of effluents.
- Surface and ground
water pollution
5. Improper handling
of chemicals (transport,
storage and use)
- Non compliance
- Inadequate awareness on
chemicals handling and
use
- Poor chemical
management
- Surface and ground
water pollution
- Air pollution by
fumes
- Human health
6. Emission of air
pollutants
- Non compliance
- Inadequate financial
resources for management
and control of air
pollutants
- Inadequate awareness on
air pollution prevention
and control.
- Air pollution
37
7. Improper handling of
mined materials (ore and
waste rocks)
- Poor mine design and
planning
- Lack of monitoring and
enforcement of
regulations
- Acid rock drainage
- Loss of soil fertility
- Air pollution
- Deterioration of soil
quality
Safety
Artisanal and small-scale miners admit that they operate in an environment which hardly meets
basic requirements of occupational safety and health and comfort. They do monotonic manual
labor in a dark, cold and narrow place which is not appropriate for the body and are under a
high risk to slipper, stuck, be hit, get crushed or cut with sharp or movable tools (Picture 16).
Picture 16. Hard rock mining site, Bor-nuur soum, Tuv province
38
Research papers quote that despite artisanal and small-scale miners, especially members of
formalized ASM NGOs and partnerships, get involved in various training on occupational
safety and health, they lack a common understanding and are hardly capable of exercising
gained knowledge and information in practice. Therefore, cases of accidents at mining sites due
to breaches of occupational safety rules tend not to decrease.
According to artisanal and small-scale miners the reasons of breaches of occupational safety
rules include:
Mining operation at non-permitted areas due to the lack of proper management and
organization
Individuals involved in ASM activity lack the knowledge about occupational safety
and mining in general, lack of appropriate tools and techniques
Improper competition for mineral resources
According to mining rescue team the following breaches of occupational safety rules lead to
accidents:
Too high or steep angle inclination of shafts
Horizontal area of digging place is too small or too big
Poor binding
Lack of ventilation system or non-standard
No reserve exit or dead end
Digging area is too long
Distance between digging places is too close
No adherence to safe distance during parallel digging
Digging areas are too close to each other, competitive digging of layers
Risks Causes Impacts
8. Improper handling of
chemicals
- Inadequate awareness on
chemicals handling
- Non-compliance
- Chemicals accidents
and injuries
9. Permission of sites - Non-compliance
- Inadequate consultation
to other land users
- Conflicts and
competition for land
ownership
39
10. Occupational Health
and Safety Issues
- Inadequate financial
resources
- Inadequate health
services/outreach at the
mining communities due
to remoteness of area
- Accidents and injuries
- Loss of manpower
11. Involvement of
woman and children in
mining
- Inadequate health
- services/outreach at the
mining communities due
to remoteness of area
- Lack of employment
opportunity
- Gender Related Issues
- Exposure to accidents
and injuries
- Women
discrimination
- Drop out of school
12. Increased number of
artisanal miners
- Lack of employment
opportunity and income
generation activities
- Competition/pressure
on available natural
resources
13. Overpopulation at
ASGM sites
- Limited availability of
permitted mining sites
- Lack of employment
opportunity and income
generation activities
- Increased pressure on
natural resources
- Limited access to
social services
- Insecurity and
violence
6. Potential Impacts and Mitigation Measures This section describes broader environmental and social risks, which are common to most of
ASGM areas, identified during scoping. Also proposed mitigation measures and agents
repsobinsible for implementation (Table 4). Additional site specific risks might be identified
during the project implementation through process of detail EIA and development of EPRP.
Some of the activities supported by the GEF GOLD CHILD project is likely to have potential
adverse environmental risks and impacts. Within the framework of Component 2 of the project,
national government planned to create ASGM fund to allow miners to invest in mercury-free
technologies. Infrastructures and ore processing plants supported through this fund are subject
40
to a detail EIA according to Mongolia law on Environmental Impact Assessment and relevant
regulations.
Other site specific activities to improve mining practise needs a environmental baseline study
within the permitted areas and to develop Environmental Protection and Restoration Plan
(EPRP) according to the requirement specified in the “Government Regulation on Artisanal
and Small-scale Mining” #151, approved on 24 May, 2017.
In the regulation artisanal and small-scale miners are responsible for develop and implement
an Environmental Protection and Restoration Plan. The EPRP should include following but
not limited; land restoration, protection of surface water, handling of chemical and explosive
materials, waste management and occupational health and safety. With support of SDC, the
Asia Foundation has developed a Template for Environmental management plan at Soum level.
This template include a management plan for land-use, water, biodiversity and habitat, social-
economic and cultural heritage site as well as monitoring and consultation of local stakeholders.
This template can be used to develop EPRP for selected sites. Details of the Template please
see Annex 3.
41
Table 4. Environmental and Social Risks and Mitigation Measures
E&S risks Mitigating Measure
Technical
Details Location Timeline Responsibi
lity
Cost of
Mitigati
on
Land degradation and
abandonment of mine
sites
Deforestation
- Develop and implement of the
Environmental Protection and Restoration
Plan (EPRP)
- Ensure detailed mine closure plan
- Ensure technical and biological restoration
of sites after mining completed
- Ensure that topsoil is being stripped in new
working areas and stockpiled for future
rehabilitation.
- Encourage use of alternative construction
materials and heating
- Encourage reforestation activities in the
EPRP
- Land restoration
methodology and
guideline for
artisanal mining,
approved by
Ministry of
Environment and
Tourism (MET)
- Government
regulation on
Artisanal Mining
#151
Selected
mining areas
All time of
operations
ASGM,
Project
Manageme
nt unit
(PMU),
local
inspector
and
Environme
ntal
Agency
Cost
details in
EPRP
Uncontrolled use of
ground and surface
water. Mining and
ore processing within
or near surface water
Discharge of tailings
and contaminated
effluents to the
environment.
Improper handling of
mined materials (ore
and waster rocks
- Ensure that water being used for processing
is recycled.
- Monitor water pumping from groundwater
wells
- Detail EIA for processing/milling plants
- Development and implementation EPRP
and Environmental monitoring protocol for
soil and water resources
- Promote and enhance pavement of sluicing
areas and containment of effluents.
- Liquid spills of lubricant, fuel and oil
should be attended in order to minimize
land & groundwater contamination.
- Regulation and
methodology for
EIA approved by
MET
- Templete for
Environmental
Management
Plan
At the
subproject site
both for mining
and processing
All time of
operations
ASGM,
PMU, local
inspector,
Environme
ntal
Agency,
consultant
company,
MET
Cost
details in
EIA
42
- Encourage and facilitate conducting of
studies to the proposed rocks to be mined
in order to proper development of waste
rock dumping strategies to minimize acid
rock formation impacts.
- Ensure waste rocks and tailings are
disposed in designated areas.
Improper handling of
chemicals HNO3 -
Nitric acid , Nа2B4O7
- Sodium borate
- Ensure that all chemicals are being stored
in a propser manner to reduce interaction
with environment
- Ensure that all chemicals spillages are
being contained and cleaned
- Dispose all obsolete chemicals in
consultation with experts
- Ensure that all chemicals have material
safety data sheers and the chemical
containers are well labeled
- Complete chemical risk assessment and
implement recommendations
- Use of protective equipment when handling
chemicals
- Use of chemicals in equipped laboratories
in compliance with national standards and
requirements
- Frequent monitoring and inspection of
laboratories and disposal sites.
- Chemical risk
assessment and
mitigation
measures
according to EIA
requirement
- Standards on
hazardous and
toxic chemicals At the
subproject site
for processing
(milling plants)
All the time of
operations
ASGM,
PMU and
local
inspector
Cost
details in
EIA
Emission of air
pollutants
- Promote and facilitate wet mining
technologies to reduce dust emissions
At the
subproject site
both for mining
and processing
All the time of
operations
ASGM,
PMU -
Permission of sites - Requirement of land permits and contract
with local govermernt.
- Government
regulation on Mining areas
Before mining
activity
Local
governmen-
43
- Environmental base line study, EPRP and
EIA, where approporiate
Artisanal Mining
#151
- Templete for
Environmental
Management
Plan
t, Mining
Agency,
ASGM,
PMU
Occupational Health
and Safety Issues.
Noise generation
during mining and
processing of ore
from use of drillers,
blasters and milling
equipment could pose
direct hazard to
workers and
surrounding
communities
- Health monitoring of ASGM
- Increase awareness among ASGM regarding
health risks of mercury
- Promote formalization of the ASGM and
project support restricted to formalized
ASGMs
- Ensure appropriate training and safe
facilities for workers
- Provision and wearing of appropriate
personal protective equipment
- Government
regulation on
Artisanal Mining
#151
- Templete for
Environmental
Management
Plan
Mining areas,
At the
subproject site
both for mining
and processing
All time of
operations
ASGM,
PMU, and
local
inspectors
Cost
details in
EPRP
and EIA
Involvement of
woman and children
in mining
- Gender assessment and mainstreaming plan
needed to be developed and implemented
- Child labor is illegal
Mining areas,
At the
subproject site
both for mining
and processing
All time of
operations
ASGM,
PMU -
44
7. Environmental and Social Risk Monitoring Environmental monitoring needs to be carried out during the implementation of the project.
The overall objective of environmental and social monitoring is to ensure that mitigation
measures are implemented and that they are effective. Environmental and social monitoring
will also enable response to new and developing issues of concern. Environmental monitoring
will be carried out to ensure that all project activities comply and adhere to environmental
provisions and standard specifications, so that all mitigation measures are implemented.
The proposed monitoring program is summarized in Table 5. The table lists the risks,
parameters to be measured, monitoring methods and procedures used, timing/frequency of
measurement, detection limit, definition of thresholds, sampling/monitoring location, and
responsibility.
45
Table 5. Environmental and Susainability Monitoring
E&S risks Parameters to be
measured
Monitoring
methods Frequency Detection limit and Thresholds Location Responsibility
Land degradation
Rehabilitation of
mined site, waste
rock and tailings
dumps
Monitring after
rehabilitation Annually
Land restotation method and
guidline for astisanal minners
approved by MET
At the
subproject
site for
mining
Mined site
ASGM, PIU,
Local
government,
inspector and
Environmental
Agency
Deforestation Forest density/ha Forest land, ha Annually -
Mining site
with forest
area
ASGM, PIU and
Local inspector
Water pollution
pH,Ca2+, Mg2+,
NH4+, Na+, K+ Fe3+,
SO42-, HCO3
-, Cl-,
NO2-, NO3
-, heavy
metals (Cr, Pb, Cd,Ni
Zn),
Sampling and
analyze according
to national
standard
Bi annually
MNS 900: 2005 Environment, Health protectin,
Safety. Drinking water.
Hygienically requirements,
assessment of the quality and
safety
МNS 6148:2010 Water quality. Maximum limit
of substance contaminating the
ground water
Mining and
processing
area
ASGM, PIU,
Local
Environmental
Agency
Soil pollution Heavy metals (Cr,
Pb, Cd,Ni Zn)
Sampling and
analyze according
to national
standard
Bi annually MNS 5850:2008
Soil quality. Soil pollutants
elements and substance
Mining and
processing
area
ASGM, PIU and
Local
Environmental
Agencyamd
Chemical
laboratories
Mercury contaminiation Mercury on soil and
water Ppm, mg/l Bi annually MNS 5850:2008
Mining and
processing
ASGM, PIU and
Local
46
Soil quality. Soil pollutants
elements and substance
МNS 6148:2010
Water quality. Maximum limit
of substance contaminating the
ground water
area Environmetnal
Agency and
Chemical
laboratories
Emission of air pollutants In door and outdoor
air quality
Sampling and
analyze according
to national
standard
Annually MNS 4585:2016
Air quality. General technical
requirement
Mining and
processing
area
ASGM and PIU
Noise generation during
mining and processing
Noise generation
(During working
hours and non-
working hours)
Sampling and
analyze according
to national
standard
Annually
MNS 5002:2000
Occupational safety and health.
Noise. Requirements for general
safety
Mining and
processing
area
ASGM and PIU
47
8. Capacity Development
The exucting agency of the project in Mongolia is the Artisanal Gold Council nad Ministry of
Environment and tourism of Mongolia. The Executing agency is resopnsbile for the overall
management of the financial and human resources of the project and will take guidance from
the GEF implementing agennciesm Project Steering Committee (PSC). A Project
Management Committee (PMC) will be created to address the immediate issues and concerns
of the project. The PMC will also endorse all documents that will be submitted to the PSC and
provide guidance to the Projec Manager (PM).
The Project Management Unit (PMU) will be in charge of the day-to-day management of the
project. This will be composed of a Project Manager and other project staff. Bi-annual
monitoring of the project implementation will be under the resposbility of PM and Monitring
& Evaluation Officer of the Project.
Environmental and Social Risks and Mititigation measres and Sustainability Monitiring of this
ESMP will serve as a starting point for M&E. During the implementation site specific baseline
assessment and Environmental Protection and Restoration Plan will be developed and put to
implementation. ESMP plans should be monitored bi-annually as integral part of project
monitoring and evaluation. This will be carried out by the project M&E officer. The
environmental and social consultants needed to provide specific technical advice and also
provide necessary trainings to M&E officer, local inspector, environmental agencies and
ASGM in regard to specific environmental and social issues identified in this report.
Infrastrucutre development supported by the project is subject to Law on Environmental
Impact. Environmental and social issues, Environmental Management plan, Monitoring will
be implemented using existing system. Ministry of Environment and Tourism is responsible
for approving EIA and annual report and monitoring of Environmental management plan.
Some of the project activities may not require detail EIA. According to Government
Regulations on Artisanal and Small-scale mining, Environmenal Protection and Rehabilitation
Plan (EPRP) should be developed and activities monitored by Local Environmental Agencies
and Local Government. EPRP includes many of the environemtal and social risks compiled in
this report. Please see suggested template for EPRP for site specific activities. However,
48
development and implementation of such plan is new to ASGMs, local inspectors,
environmental agencies and governments.
All those are responsible for development, management and implementation of the EPRP shall
be adequately trainined and capacity building assessment and plan needed for all involved
stakeholders.
9. Communication During development of EPRP, affected communities and stakeholders will be consultated about
potential environmemtal and social risks and proposed mitigation measures. Final EPRP,
which consulted with local communities and reviewed by project, will be part of the contract
with local government. Implementation of the contract will be annually reviewed and updated
by local government, environmental agencies and project team.
Detail EIAs approved by MET is published on the web-based Environmental database, which
maintained by MET. Also permitted mining areas for small-scale mining are available on the
website of Mineral Resources and Petrolium Authority of Mongolia. However, local people
may not have reasonable access to the relevant website, other hand recent decision and
information may not available at these website rather soon. Therefore, project team need to
develop communication strategy and plan to effectively communicate informations and
decisions, including EPRP and environmental baseline studies to the local community, national
and international project stakeholders.
This commincation strategy and plan will be integral part of the Component 4 – Knowledge
management of the project. This component of the project concerns the dissemination of the
project successes and lessons learned both at the national and international level, nad integrating
these with global componenet on knowledge management of the GOLF programme. All EIA,
EPRP, mitigiation plans, environmental baseline study report, results of all stakeholder
consultations and other documents will be made available in a timely manner in apl ce
accessible to national and international stakeholders.
49
10. List of Document Consulted
1. A review of Environmental and Social Impact in the Mining Sector, Mongolia, World
Bank, May 2006
2. Artisanal Mining Sector of Monoglia, SAM project, 2011 (Mongolian)
3. Basline study for “Gold 2025” programme, 2016 (Mongolian)
4. Best Practices of Artisanal Mining, SDC 2017 (Mongolian)
5. Best practices of Land Restoration by Artisanal Miners, 2010-2014, SDC
6. Conclusions and Discussion on Artisanal Mining and Human Rights, Mongolia,
ASGM Umbrella Organization, 2014 (Mongolian)
7. Draft Project Document on Contribution Toward the Elimination of Mercury in the
Artisanal and Small-scale Gold Mining Secotr: From Miners to Refiners
8. Environmental and Social Management Plan for the VCM Project, UNIDO, 2015
9. Gender Assessment of Small-Scale Mining in Mongolia, Asia Foundation, 2013
10. Global Opportinties for Long-term Development of ASGM Secotr- GEF GOLD,
GEF-6 Program Framework Document (PFD), 25 July, 2016
11. Handout for Land Resotoration of Artisanal Mining, Field Guide, SDC, Asian
Foundation, Ministry of Mining, 2017 (Mongolian)
12. Impementation of the Laboratory Test and Preparation for Pilot Demonstartion
Activities Report, Reduce exposure of Mercury to Human Health and the
Environment by Promoting Sound Chemical Management in Mongolia Ulaanbaatar,
2016
13. Implementation of the Monitoring Network Activities and Site Characterization
Report, Reduce exposure of Mercury to Human Health and the Environment by
Promoting Sound Chemical Management in Mongolia, October 2015
14. Informal Gold Mining in Mongolia, A Baseline Survey Report Covering Bornuur and
Zaamar Soums, Tuv Aimag, International Labour Office, 2006
15. Legal Environment for Artisanal Mining, SDC, 2015 (Mongolian)
16. Livelihood study for Artisanal Miners, Ulaanbaatar, SDC, 2011 (Mongolian)
17. Mid-term (3-5) Environmental management plan, SDC, Asian Foudantion, 2016
18. Nee Sun Choong Kwet Yive and Enkhbold Sumiya, Independent Terminal
Evaluation, Reduce Exposure of Mercury to Human Health and the Environment by
Promoting Sound Chemical Management in Mongolia, January 2017
19. Policy recommendations on ASGM and contribution to macro-economics, Union of
Mongolian Exporters, Ulaanbaatar, 2015 (Mongolian)
20. “Regulation on Artisanal Mining” Government Resolution, #151, 24 May, 2017
(Mongolian)
50
21. Report on Artisanal and Small-scale Miners, Ulaanbaatar, 2012 (Mongolian)
22. Report on Environmental Audit of Mercury-free Gold Ore Processing Plnat,
Environmental Compliance LLC, 2015
23. Responsible Mining in Mongolia: Enhansing Positive Engagement, Sustainable
Minerals Institute, University of Queensland, Asutralia, 2015
24. SDC Experiences with Formalization and Responsible Environmental Practices in
Artisnal and Small-scale Gold Mininig in Latin America and Asia (Mongolia), SDC,
2011
25. Small-scale Mining in Mongolia – A Survey Carried out in 2004, Peter W. Uitterdijk
Appel
26. Study on Artisanal Mining and Children, World Vision Mongolia, 2012 (Mongolian)
27. Study report on “The Health Impact Assessment of Mercury on Astisanal and Small-
scale miners”, National Center for Public Health, SDC, 2014
28. Study Report on Artisanal Mining in Mongolia and Gender Equality, SDC, Asia
Foundation, October 2013 (Mongolian)
29. Sustainable Artisanal Mining Project (SAM), Project Document for Phase 4, 2015-
2018, SDC Mongolia
30. UNIDO Environmental and Social Safeguards Policies and Procedures (ESSPP), 21
January, 2015, UNIDO/DGAI.23
51
11. Annexes
Annex 1. Terms of Reference for National Environmental and Social
Management Plan Specialist
UNITED NATIONS INDUSTRIAL DEVELOPMENT ORGANIZATION
TERMS OF REFERENCE FOR PERSONNEL UNDER INDIVIDUAL SERVICE AGREEMENT (ISA)
Title: National Environmental and Social Management
Plan (ESMP) Specialist
Main Duty Station and Location: Home based and 1 field mission (Mongolia)
Mission/s to: To be arranged separately
Start of Contract (EOD): 1 August 2017
End of Contract (COB): 30 September 2017
Number of Working Days: WAE 30 days
ORGANIZATIONAL CONTEXT
UNIDO is committed to promoting inclusive and sustainable industrial development
(ISID) to harness the full potential of i dustry’s o tri utio to i the a hieve e t of sustainable development, and (ii) lasting prosperity for all. Within the first thematic
pillar, UNIDO is dedicated to supporting environmentally sound and sustainable
development in the full range of its project activities. In order to meet this goal, UNIDO
has adopted a set of Environmental and Social Safeguard Policies and Procedures
ESSPP . These stre gthe UNIDO’s a ou ta ility to the ou tries a d o u ities it aims to support; stakeholders in the development processes; and the broader
development cooperation and donor community.
PROJECT CONTEXT
UNIDO and UNEP, in association with the Ministry of Environment, Green Development and
Tourism of Mongolia and the Department of Environment and Natural Resources of the
Philippines are currently co-implementing a GEF child project (under the programme: Global
Opportunities for Long-term Development of ASGM Sector: GEF GOLD) entitled Contribution
52
towards the elimination of mercury in the ASGM sector: from miners to refiners. The
progra e’s o je tive is to redu e the use of er ury i the ASGM se tor through i facilitation of access to finance for the introduction of low and non-mercury technologies to
artisanal miners and mining communities and through (ii) the development of sustainable
ASGM gold supply chains. The Mongolia and Philippines child project is one of the eight child
projects in the programme with its specific objective to contribute to the elimination of
mercury in ASGM by applying a value chain approach from the miners to the refiners.
Over a period of five years, the project aims at the following four components:
a) Legal framework and formalization: Review of policy and legal framework supporting
formalization of the sector;
b) Financing: Introduction of financing schemes allowing miners to adopt and
subsequently invest in mercury free technologies in a sustainable manner and access
international gold markets more directly;
c) Technology transfer: Upscale mercury free technologies and support the
development of health programmes for the ASGM sector; and
d) Knowledge management: Develop a communication strategy in order to replicate the
project activities in the participating countries and contributing to the global
knowledge management platform established under the global child of the GEF GOLD
programme
Based on UNIDO’s Environmental and Social Safeguards Policies and Procedures, the project
has been categorized as risk level B where an environmental and social management plan
(ESMP) is needed during the preparatory phase of the project to integrate environmental and
social sustainability elements into project design. Likely impacts will be few in number, site-
specific, and few if any will be irreversible. It is expected that appropriate management and
mitigation measures will be defined and/or internationally recognized design criteria and
standards incorporated. The project is expected to build necessary human and institutional
capacities at all levels in order to achieve the expected outputs. Therefore, the project seeks
to hire a (national) ESMP Expert to develop such a plan, consist of the identification of risks
and mitigation measures of the proposed activities and how they should be monitored. In
addition, the plan should include a section on how to assess and develop implementation
capacity, including a communication strategy. The ESMP should be designed to suggest cost-
effective measures to minimize, mitigate, or eliminate adverse impacts of the activities of the
project. Measures to enhance beneficial impacts should also be recommended. The structure
of the ESMP is detailed below.
STRUCTURE OF ESMP
The ESMP will consist of a set of mitigation, monitoring and institutional measures, including
policies, procedures and practices – as well as the actions needed to implement these
measures –to achieve the desired social and environmental sustainability outcomes. The
report is expected to include the following sections:
Sections Description
53
Define environmental
and social impact
mitigation
actions/measures
Avoid, prevent or eliminate environmental and social risks
and adverse impacts, wherever technically and financially
feasible; for proposed projects involving existing facilities,
remediation may need to be undertaken instead of, or in
addition to, mitigation;
Where it is not technically or financially feasible to avoid,
prevent or eliminate risks and impacts, identify measures and
actions to mitigate, minimize or reduce impacts so that the
project operates in compliance with applicable international,
national and local environmental and social laws and
regulations or achieves acceptable levels of impacts
otherwise defined and agreed;
Where it is not technically or financially feasible to mitigate,
minimize or reduce risks and impacts, identify measures to
offset the y e ha i g the proposed proje t’s positive environmental and social impacts;
Where avoidance, mitigation and offset measures are not
technically or financially feasible, identify compensatory
measures to balance the residual adverse impacts.
Detail environmental
and social monitoring
to be conducted during
project
implementation
Provide information about actual versus predicted
environmental and social impacts;
Measure the effectiveness and evaluate the success of
mitigation, remediation and enhancement measures;
Evaluate compliance with applicable international, national,
and local policies laws, regulations, safeguards,
performance standards, policies and procedures;
Allow corrective action to be taken when needed.
Specifically, the ESMP will detail the:
Mitigation measure being monitored;
Parameters to be measured;
Sampling and analytical or other monitoring methods to be
used, including staff, procedures and detection limits (where
appropriate);
Sampling or monitoring locations;
Frequency or timing of measurements;
Definition of thresholds that will signal the need for
corrective actions.
Develop a plan to
assess and build
capacity to implement
the environmental and
social management
plan and other
environmental and
Recommend management arrangements for the project,
including structure, roles, responsibilities, and authorities;
Designate specific personnel, including management
representative(s), with well-defined and clearly
communicated lines of responsibility and authority;
Require sufficient oversight and human and financial
resources be provided on an ongoing basis to achieve
effective and continuous environmental and social
management throughout the life of the proposed project.
54
social components of
the project
Develop a plan to
communicate progress
with implementation
and effectiveness of
the management plan
Close consultation with project stakeholders ensured;
Include a section that outlines a plan to communicate
implementation progress on issues that involve ongoing risk
to or impacts on the project stakeholders, and on issues
that the consultation process or grievance mechanism has
identified as of concern to those stakeholders.
If the review and evaluation of the ESMP result in material
changes in, or additions to, the mitigation, monitoring or
capacity development measures or actions described in the
ESMP on issues of concern to the stakeholders, the updated
measures or actions will also be developed in close
consultation with stakeholders and disclosed.
Design report format accessible to the stakeholders.
DUTIES
The (National) ESMP Specialist will execute his/her duties in close collaboration with the
UNIDO project manager and the national stakeholders. Within the duration of the assignment,
the ESMP Specialist is expected to carry out the following tasks in the table below.
DUTIES CONCRETE/ MEASURABLE
OUTPUTS
EXPECTED
DURATION LOCATION
Part 1: Preparation
Desk review of existing literature and
studies; exchange with Mongolia main
project stakeholders (including project
team) on scope, approach, work plan,
and deliverables on the assignment
Inception Report: (scope,
work plan, deliverables,
structure of ESMP)
4 days Home based
Review relevant UNIDO, UN
Environment and GEF documents on
the requirements for ESMP
Part 2: Collection and analysis of data
Conduct a detailed environmental and
social analysis of the project
particularly in the area and region of
intervention. This includes review of
relevant national policy, legal and
administrative framework documents
on artisanal and small scale gold
mining in the country and institutional
Draft outline of ESMP
Report incl. E&S risks and
mitigation measures, plan
for interviews, meetings
and methodology and tools
for data collection (e.g.
survey, questionnaire)
4 days Home based
55
DUTIES CONCRETE/ MEASURABLE
OUTPUTS
EXPECTED
DURATION LOCATION
arrangement of relevant stakeholders
involved in the project
Identify E&S risks and mitigation
measures: Identify potential
environmental and social risks,
mitigation measures, technical details
of the mitigation technology, process,
equipment, design and operating
procedures, location, timeline,
responsibility, and cost of mitigation
during project preparation and
implementation
Develop E&S sustainability
monitoring plan that can be used to
track and monitor potential E&S
impacts (plan should include
parameters to be measured,
monitoring methods and procedures
used, timing/frequency of
measurement, detection limits,
definition of thresholds, monitoring
location and responsibility)
Conduct interviews with project main
stakeholders
Documentation on
interviews and meetings;
recordings of survey/
questionnaire
7 days (incl.
travel days)
Field
mission
Analysis of the interviews and data
collected.
Produce first draft of ESMP (to be
shared within 2 weeks after field data
collection)
First draft ESMP
3 days Home based
Part 3: ESMP for the Project
Complete the ESMP
(recommendations on capacity
development, management actions
and methods to enhance the benefits
of the project) based on the E&S
impact analysis and the mitigation
measures identified
Second draft ESMP incl.
estimated costs and
resources needed for its
implementation 3 days Home based
Conduct validation workshop of the
E&S impact analysis report and
present the ESMP to main project
stakeholders
Final ESMP Report
Total assignment duration 21 days
REQUIRED COMPETENCIES
56
Core values:
1. Integrity
2. Professionalism
3. Respect for diversity
Core competencies:
1. Results orientation and
accountability
2. Planning and organizing
3. Team orientation
Managerial competencies
(as applicable):
1. Strategy and direction
2. Judgement and decision
making
MINIMUM ORGANIZATIONAL REQUIREMENTS
Education:
The ESMP Expert should have an advanced university degree in environmental science,
natural resources management or other relevant disciplines. A minimum of 10 years of
relevant professional experience is desirable.
Technical and Functional Experience:
The ESMP Expert should have:
- Proven experience in chemicals management, preferably in Mongolia
- Excellent knowledge of methodologies necessary of Environmental and Social
Management Plans in the context of artisanal and small scale gold mining
- Sound knowledge of environmental mitigation and monitoring plans
- Sound knowledge of legislation and donor policies that will affect the environmental
Management of the project;
- Strong communication skills and ability to liaise with various stakeholders, including
government officials.
Languages:
Fluency in written and spoken English is required. Knowledge of local language is an asset.
Reporting:
Progress and problem reporting required as well as the working documents and draft/final
reports should be submitted in English electronic form to UNIDO. Should any delay occur or
expected circumstance arises, the expert(s) should notify UNIDO in writing in a timely manner.
1
Annex 2. Template for Environmental Management Plan
TEMPLATE FOR ENVIROMNETAL MANAGEMENT PLAN AT SOUM
LEVEL
MID – TERM (3 to 5 year) OF......................
SOUM, ................... AIMAG
Contents
GLOSSARY OF TERMS .................................................................................................................................... 2
1 INTRODUCTION...................................................................................................................................... 3
1.1. RATIONALE FOR DEVELOPING SEMP ............................................................................................... 3
1.2. SOUM ENVIRONMENTAL MANAGEMENT PLAN: GOALS AND OBJECTIVES ........................................... 3
1.3. SCOPE OF SOUM ENVIRONMENTAL MANAGEMENT PLAN .................................................................. 4
1.4. SWOT ANALYSIS ON SOUM ............................................................................................................. 4
1.5. GENERAL INTRODUCTION OF THE SOUM ........................................................................................ 5
1.5.1 Vision and mission of the soum ....................................................................................................... 5
1.5.2 Environment .................................................................................................................................. 5
1.5.3 Economy ........................................................................................................................................ 5
1.5.4 Cultural values associated with the environment............................................................................... 5
1.5.5 Review of relevant soum level management plans ............................................................................ 6
1.6. ENVIRONMENTAL IMPACTS AND THE RELATIONSHIPS BETWEEN THE KEY ENVIRONMENTAL
STAKEHOLDERS ......................................................................................................................................... 6
2 ENVIRONMENTAL ACTION PLAN (EAP) .................................................................................................. 10
2.1. Soum Environmental Action Plans .................................................................................................. 10
2.2. Annual Environmental Action plans................................................................................................. 13
2.3. Responsibilities of the key environmental stakeholders for the soum environmental management plan
implementation ........................................................................................................................................ 13
2.4. Capacity building of the key environmental stakeholders ................................................................. 14
3 MONITORING AND EVALUATION OF THE SOUM ENVIRONMENTAL MANAGEMENT PLAN .......................... 14
4 CONCLUSION ....................................................................................................................................... 16
Developed by The Asia Foundation and Sustainability East Asia through 2015 - 2016
2
GLOSSARY OF TERMS
Abbreviation/ Term Description
ASM Artisanal and Small scale Mining
Environmental aspect An environmental aspect is the way your activity, service, or product impacts the
environment.
Environmental impact An environmental impact is a change to the environment that is caused by
environmental aspect.
Environmental
stakeholder
Environmental stakeholders are those stakeholders who directly manage or operate
within the physical environment to sustain their livelihoods (e.g.
herders/pastureland users, Large-scale Mines and Artisanal and Small-scale miners
(ASMrs), agricultural operators, forest managers, water managers, wildlife/cultural
tourism, Protected Area Administrators, etc).
High value biodiversity
and cultural/historical
features
key environmental and cultural attributes for which the soum is renowned (valuable
habitats, species, paleontological sites, cultural sites, rock engravings,
archaeological and historical sites, etc).
ISO 14001 Environmental Management Systems standard
KES Key Environmental Stakeholders
Key species A key species is a plant or animal that plays a unique and crucial role in the way an
ecosystem functions.
LMC Local Multi-Stakeholder Council
NGO Non-Governmental Organization
Protected area A protected area is a clearly defined geographical space, recognized, dedicated and
managed, through legal or other effective means, to achieve the long term
conservation of nature with associated ecosystem services and cultural values.
PUG Pasture User Group
SEMP Soum Environmental Management Plan
Significance of impact Extent of the influence of impact on state of environment on short, medium and
long term
SWOT Strengths, Weaknesses, Opportunities and Threats Analysis
3
1 INTRODUCTION
This document is the Environment Management Plan (EMP) for ............. soum of ........... aimag. The EMP has
been designed to be developed within the framework of Guidelines for development of Environmental
Management Plan (approved by MEGDT on ...........); Environmental Management Systems standard ISO14001
and to be tailored to the specific features of ………… soum. This is part of ISO 14000 series of standards related
to environmental management that exists to help organizations minimize negatively impact on the environment
from their activities, comply with applicable laws, regulations and continually improve in achieving these
objectives. The EMP identifies the main economic activities, that occur in the territory of …….. soum, and the
environmental impacts associated to those activities, outlines the inter-relationships between relevant
environmental stakeholders who manage/use common resources and identifies the responsibilities of different
types of stakeholders, control measures and procedures, reporting and monitoring measures.
1.1. RATIONALE FOR DEVELOPING SEMP
This soum level environmental management plan is produced out of necessity to assist the local communities’ in
effectively managing environmental issues at the soum level by integrating existing different management plans
and engaging multi-stakeholders in this process. This plan should help achieving vision and mission of the soum.
1.2. SOUM ENVIRONMENTAL MANAGEMENT PLAN: GOALS AND OBJECTIVES
The main goal of the SEMP is to manage the sustainable use of natural resources, through the production of an
efficient environmental management plan, that identifies key environmental stakeholders (KES) that should be
represented on the soum Local Multistakeholder Council (LMC). The Local Multi-Stakeholder Council (LMC) with
representatives of the KESs will use this EMP procedure to clarify roles and responsibilities in the process of
developing, implementing, monitoring, evaluating, and reporting of the SEMP. The objectives to achieve the
goals are shown below.
• Map the relevant environmental stakeholders operating within the soum; environmental stakeholders
are those stakeholders who directly manage or operate within the physical environment to sustain their
livelihoods (e.g. herders/pastureland users, Large-scale Mines and Artisanal and Smallscale miners
(ASMrs), agricultural operators, forest managers, water managers, wildlife/cultural tourism, Protected Area
Administrators, etc).
• Identify the key environmental responsibilities and roles of competent authorities;
• Identify the main relationships between the relevant stakeholders in terms of potentially/actual conflicting
environmental resource use;
• Identify negative impacts on the environment due to the different economic activities of the soum
environmental stakeholders;
• Identify key environmental and cultural attributes for which the soum is renowned (valuable habitats,
species, paleontological sites, cultural sites, rock engravings, archaeological and historical sites, etc).
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• Identify stakeholder relationships (high-low risk assessment) with key environmental/cultural attributes for
which the soum is renowned.
• Establish/incorporate specific control measures compliant with Mongolian and international legal
requirements, to avoid and mitigate the environmental impacts and conflicts;
• Enable, through LMC-based dialogue, a discussion and analysis of the issues/conflicts and an identification
of the solutions/negotiations/ to such issues/conflicts; and
• Enable, through LMC-based dialogue, a discussion of the issues/conflicts and develop a guideline to
manage such issues/conflicts.
1.3. SCOPE OF SOUM ENVIRONMENTAL MANAGEMENT PLAN
This EMP is designed to identify and assess the impact of soum stakeholders’ economic activities on the local
environment and on each other’s interests where management of common natural resources are involved.
The economic activities, covered by this EMP, include, but are not limited to:
• Livestock husbandry;
• Crop farming;
• Forestry;
• Large-scale Mining (LSM);
• Artisanal and Small-scale Mining (ASM); and
• Construction and Infrastructure Development.
1.4. SWOT ANALYSIS ON SOUM
Purpose of the SWOT analysis is to develop a better awareness of the situation in terms of preparedness of the
soum to develop a SEMP. It will help NGOs and LMCs to plan and prepare before they develop the SEMP. NGOs
and LMCs (those who are developing SEMP) would collect information, raise awareness or build positive
relationship with authorities so that SEMP developing process is effective. Matrix below depicts SWOT analysis as
in example:
Table 1.1 SWOT analysis of the soum
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Strengths:
• Availability and support of local authority and
community to develop SEMP
• Protected Area administration located nearby,
etc.
• LMC with strong representative stakeholders,
PUGs, ASM NGOs, etc.
Weaknesses:
• Financial and capability limitations
• Lack of data on important environmental
values, wildlife, etc.
Opportunities:
• Well documented data base
• New enterprises under development etc.
Threats:
2016 Elections
1.5. GENERAL INTRODUCTION OF THE SOUM
1.5.1 Vision and mission of the soum
In vision statement, soum would indicate what the soum wants to become and set defined direction of the soum’s
growth while in mission statement it would state main purpose and focus of the soum.
1.5.2 Environment
Information on natural resources such as land, water, habitats, high biodiversity values and mineral resources
should be described here. Protected Areas, both national and local, river basin areas should be described.
Climate, geography etc.
1.5.3 Economy
This section will describe economic activities taking place in soum. Mapping of natural resource users (land, water,
biodiversity and mineral resource) should be done. Presence, if any, of LSM mining licenses and ASM
partnerships/activities should be documented.
1.5.4 Cultural values associated with the environment
Heritages such as scenic natural features and historical/cultural heritage sites should be mapped.
Figure 1.1 Map of the attributes of soum significance and economic activities
LMC members should do natural resource mapping and economic activities mapping to determine locations of the
high value biodiversity features, natural and cultural heritages, protected areas and other natural resources.
On top of this map, they should also place economic activity locations.
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Natural resource and economic activity mapping:
Insert map, show soum’s land use planning, water and other resources, protected areas, high value
biodiversity features and economic activities.
1.5.5 Review of relevant soum level management plans
Reviewing of existing soum level management plans (also special protected area management plans) will inform
the LMC with existing control measures for environmental management. This will serve as cross-reference for the
SEMP. Existing Soum Annual Land Management Plans (SALMPs); ASM Rehabilitation Management Plans; other
plans produced by specific stakeholder groups should be covered. List of all relevant existing management plan
is presented here:
Table 1.2 Existing relevant plans
1 Soum annual land management plan
2 ASM rehabilitation management plan
3 Soum governor’s action plan
4 Soum mid-term and long term development plan
5 Soum emergency plan
6 Non-formal plan to improve legal knowledge of Soum citizens
7 Management plan of Strictly Protected Area management plan and Annual action plan
8 Buffer zone management plan of SPAs
9 Environmental management plan of citizens and legal entities who uses natural resources
10 River basin management plan
11 Forest management plan
12 Tourism management plan
13 Hunting management plan
1.6. ENVIRONMENTAL IMPACTS AND THE RELATIONSHIPS BETWEEN THE KEY
ENVIRONMENTAL STAKEHOLDERS
There are a number of considerations for assessing environmental impacts/conflicts, when developing this SEMP,
including but not limited to:
• the type of economic activities within the territory of …………soum (refer to section 1.5.3);
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• the location of these activities in relation to protected areas, communities and water and other resources;
and
• potential impacts on the environment and community (including waste generation, pollution, emissions,
harm to ecosystem services and to ecosystems, among others).
• where key stakeholders have competing interests in common resource use, there is the potential for conflict
The following economic activities and associated environmental issues should be considered during the
Environmental Management Plan development. These environmental impacts include, but are not limited to,
those presented in Table 1.3.
Table 1.3 Environmental impacts of the economic activities in the soum
Main economic activities Impacts Significance of the
impacts
Affected
stakeholders
Livestock husbandry
Crop farming
Forestry
Large scale mining (LSM)
Artisanal mining (ASM)
Construction and
infrastructure development
Brief description of negative and complicated impacts should be provided. Description should provide answers to
following:
1. What is the cause of environmental impact?
2. Where specifically is impact located within soum?
3. Which economic activities are specifically responsible/involved?
4. What is needed to resolve this?
5. What could be done to resolve this?
Table 1.4 Relationship between stakeholders on environmental issues
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Stakeholder/
stakeholder
Herder Farmer Small scale
miner
Large scale
miner
Forest user
group
Herder Positive
Farmer Complicated
Small scale
miner
Large scale
miner
Negative
Forest user
group
Neutral
Interrelationships between different natural resource user stakeholders are depicted as in example above.
Explanation of the colour code is depicted in table below. Using the matrix, relationships between stakeholders
on environmental issues in general can be noted in the appropriate cells, and the cells can be highlighted with
different colours with respect to their significance. The significance can be evaluated as negative, positive, neutral
or complicated, and highlighted with red, blue, green and yellow, respectively. For negative (red) relationships
immediate action should be taken. Same principle applied for environmental impacts. Negative are very high and
high level risks of environmental impact and immediate action should be taken.
Table 1.5 Colour code scheme for impact significance and interrelationship status
Impact significance/
Interrelationship status
Colour code
Negative (very high and high
risk)
Red
Complicated / Mixed
(moderate and low risk)
Yellow
Neutral Green
Positive Blue
Once risk level and interrelationship status are determined, brief description of red (negative= very high and high
risk) and yellow (complicated/mixed = moderate and low risk) relationships and impacts should be documented
which provides rationale for addressing these issues. Description should contain answers to following:
6. What is the environmental conflict and future risk? What is the issue between stakeholders?
7. Where specifically is issue located within soum?
8. Which stakeholders are specifically responsible/involved?
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9. What is needed to resolve this?
10. What could be done to resolve this?
Table 1.6 Local government roles and responsibilities with respect to environmental stakeholders
Conflicting
Stakeholders/
Responsible
authority
Governor CRK Environmental
inspector
… …
Herder vs Large
scale mining
Farmer vs Small
scale miner
Herder vs ASM
Note: this matrix shows identity and responsibility of relevant government officials who have the duty to engage with relevant
stakeholders to manage conflict between parties. As many government officials can be written in the column. Extent/strength
of role ranges between (+) …. (+++++)
Table below describes relationship between stakeholder and habitat, high value features on which they have
impact. But firstly LMC should identify key values, main habitats, natural heritages and cultural sites etc. For
example, a range of the most important habitats could be selected and assessed, if necessary informed by
specialist knowledge (such as Protected Area Managers, Environmental Inspectors, Rangers, wildlife - ecotourism
operators/biologists.
Table 1.7. Relationship between stakeholder and environmental attribute/aspect of soum
significance
Stakeholder/
natural
features
Key species (1 or
more: Snow Leopard;
Argali; Ibex, Red
Deer; Takhi; etc)
Khongor Els & River in
Sevrei soum; Bodonch
river valley
Great Gobi B Protected Area
Herders
Farmers
Large scale
miners
Cell can be coloured red if, for
example, LMC decides that
large scale mining is depleting
the water resource. Issue
should be described in detail.
Whether it is national
importance or local importance
should be stated.
Information on Table 1.5, 1.6 and 1.7 is important. These depict what the issue is, where the impact is and who
is responsible for engaging with stakeholders to manage those issues. Description providing answers to following
question is important for addressing the issue:
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1. What is the conflict or future risk?
2. What is the relationship/issue between stakeholders and environmental attributes/aspects identified as
high/medium risk issues?
3. Is there a need for more specific information relating to any of the above issues?
4. Where specifically is the issue located in soum?
5. Which stakeholders are specifically responsible/involved?
6. What is needed to resolve this?
7. What could be done to resolve this?
When such information is documented, analysed, discussed and actions identified and agreed, they can be inserted
into the following thematic action plan tables below:
2 ENVIRONMENTAL ACTION PLAN (EAP)
2.1. Soum Environmental Action Plans
The LMC is responsible for working through the steps identified in the tables/matrices above (Tables 1.3-1.7) in
order to identify the environmental impacts and conflicts within the KES. Where relationships are identified as high
risk, negative or conflicting, discussion and documentation in necessary to determine what the issue is, why it is a
problem and who will be engaged to try and resolve this (both duty-bearers and stakeholders). Through LMC
discussion and/or based on negotiations with KESs, an Environmental Action Plan compliant with Mongolian and
international legal requirements, should be developed to mitigate/avoid the environmental impacts/conflicts.
Thematic Action Plans can be specific to each environmental aspect as shown in Table 2.1-2.5, and an effort
should be made to capture as many relevant issues requiring actions as is relevant and possible. These should be
listed, reviewed and updated on an ongoing basis throughout the lifetime of the soum EMP, and will evolve as key
mitigation actions are achieved over time, or as new issues arise.
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Table 2.1 Land-use management plan
Impacts/
Conflicts Mitigation Actions
Duration and Frequency of
Implementation
Relevant
Laws, Guidelines
and
Standards
Cross
reference to
relevant
management
plan
Total Expenditure (mil.tugriks)
Responsi
ble KES
Actions for
avoiding:
1. ….
2. ….
3. ….
Actions for
mitigating
:
4. ….
5. ….
6. …..
Table 2.2 Water management plan
Impacts/
Conflicts Mitigation Actions
Duration and Frequency of Implementati
on
Relevant
laws, Guidelines
and
Standards
Cross
reference to
relevant
management
plan
Total Expenditure (mil.tugriks)
Responsi
ble KES
Actions for
avoiding:
1. ….
2. ….
3. ….
Actions for
mitigating
:
4. ….
5. ….
6. ….
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Table 2.3 Biodiversity and habitat management plan, including Protected Areas
Impacts/
Conflicts Mitigation Actions
Duration and Frequency of
Implementation
Relevant Laws,
Guidelines and
Standards
Cross reference
to relevant
management
plan
Total Expenditure (mil.tugriks)
Responsi
ble KES
Actions for
avoiding:
1. ….
2. ….
3. ….
Actions for
mitigating
:
4. ….
5. ….
6. …..
Miscellaneous environmental aspects include issues and impacts related to hazardous and non-hazardous waste
generation, treatment and disposal, air emissions and pollution as well as public health and safety.
Table 2.4 Miscellaneous environmental aspects management plan
Impacts/
Conflicts Mitigation Actions
Duration and
Frequency of Implementat
ion
Relevant Laws,
Guidelines and
Standards
Cross reference
to relevant
management
plan
Total Expenditure (mil.tugriks)
Responsi
ble KES
Actions for
avoiding:
1. ….
2. ….
3. ….
Actions for
mitigatin g:
4. ….
5. ….
…..
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Table 2.5 Socio-economic and Cultural (including archaeological, historical) heritage
management plan
Impacts/
Conflicts Mitigation Actions
Duration and Frequency of Implementati
on
Relevant
Laws, Guidelines
and
Standards
Cross reference
to relevant
management
plan
Total Expenditure (mil.tugriks)
Responsible
KES
Actions for
avoiding:
1. ….
2. ….
3. ….
Actions for
mitigatin g:
4. ….
5. ….
…..
2.2. Annual Environmental Action plans
From the Thematic Action Plans presented above, covering all relevant areas of concern, a list of priority
actions can be discussed by the LMC to be submitted to the soum for consideration, discussion and approval
on an annual basis. This list of actions, supported by relevant information as indicated in the plans identified
below, will be considered the annual Environmental Action Plan, and will include priority actions from
Landuse management, water management, biodiversity and Protected Areas management, cultural heritage,
etc. The purpose of this step is to enable focused priority setting discussion. What this means is that the EAP
tables above can capture the comprehensive list of mitigation actions that are relevant to the soum, short-
medium to longer term, while the Annual EAP takes forward those priority actions which can be reasonably
addressed within one year, or ongoing longer-term actions that need to be addressed and profiled annually.
The master EAP, which sits within the SEMP, provides a Term of Reference for each annual EAP, and can be
updated over time.
2.3. Responsibilities of the key environmental stakeholders for the soum environmental
management plan implementation
The roles and responsibilities of both the government and non-government KESs (including the competent
authorities) in the developing and implementing process of SEMP are appointed through the LMC discussions
and consultations. The overall picture of the responsible KES and related action plan is shown in Table 2.6.
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Table 2.6 Responsibilities of the key environmental stakeholders for the SEMP
Responsible
KES Land use Water
Habitat and
biodiversity
Miscellaneous
environmental
aspects
Socio-economic
(including cultural
heritage)
Government
Non-government
2.4. Capacity building of the key environmental stakeholders
To achieve an effective implementation of the SEMP, a periodic capacity building should be conducted for all
the KES involved on the SEMP development. Thematic areas of concern and interest may require further
attention, such as workshops on environmental impacts on large-scale mining or ASM, or on inter-relationships/
impacts of livestock and Protected Areas and threatened species. Such priorities, opportunities and gaps for
capacity-building should be listed, and general information on the capacity building of the KES is shown in Table
2.7.
Table 2.7 Capacity building of the key environmental stakeholders
# Capacity building Capacity building
team
Duration,
frequency
Participants
3 MONITORING AND EVALUATION OF THE SOUM ENVIRONMENTAL
MANAGEMENT PLAN
The SEMP is an evolving living document that will require continual improvement as new information becomes
available, and as new issues arise or become apparent. Thus an effective, transparent and equitable monitoring
and evaluation of the implementation of the plan is crucial. The SEMP is updated yearly, on the basis of the
results of action plan implementation. The monitoring and evaluation should consider the following questions.
1. Are the goals and objectives being achieved;
2. The percentage of environmental impacts/conflicts avoided and/or mitigated through the action plans;
3. The degree of impact avoidance/mitigation achieved for each specific issue addressed;
4. Percentage of total success of the SEMP;
5. What aspects of the SEMP were successful/unsuccessful;
6. Problems encountered that were not included in the SEMP;
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7. If the budget was sufficient;
8. Suggestions, improvements and plans to be more budget efficient;
9. If the action plans need to be revised; and
10. If the SEMP needs revision with respect to its goals and objectives.
The LMC is responsible for the development of the SEMP and introducing it to the Citizens’ Representative
Khural (CRKh); if deemed appropriate the SEMP is approved by the CRKh. In particular, annual Environmental
Action Plans (EAPs) produced through the SEMP are to be approved by the soum CRKh. The LMC is also
responsible for the monitoring and evaluation of the SEMP implementation. The responsible KESs and their
capacity building program are showed in Table 2.6 and 2.7, respectively. To monitor and evaluate the
effectiveness of the SEMP implementation and/or the efficiency of the responsible KESs, separate monitoring
KESs should be appointed. These monitoring KESs will be appointed through the LMC discussion process. These
monitoring KESs will be expected fill in Table 3.1.
Table 3.1 Monitoring of SEMP
Activity KES
Responsible
for activities
SEMP activity
Implementation
status (%)
Capacity building
delivered
Expenditure
effectiveness
Monitoring
KES
For a successful SEMP implementation, a grievance mechanism should also be established. Any stakeholder can
approach the responsible KES regarding the relative environmental issues/conflicts. The grievance mechanism
and its reporting (if any actions taken regarding the grievance) is shown in Table 3.2.
Table 3.2 Grievance mechanism of the SEMP
# Responsible
KES
Responsible action plan Grievance Actions taken
The SEMP final reporting is done by both the responsible KES and their monitoring KES. All of their
communication should be transparent and records should be documented in the ……….Soum File. The final
results of the reporting should be compiled in Table 3.3.
Table 3.3 Reporting of SEMP
# Management plan
activity reports
KES who prepared the
report
Date report was reviewed by LMC
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4 CONCLUSION
Write summary of result of SEMP implementation and whether it helped soum to achieve its mission, vision.