Energy use. The project’s main users of energy include; (i) irrigation pumps diesel engines; (ii) diesel fueled agricultural machinery (iii) vehicles’ gasoline engines and; (iv) grid electricity-powered gin machines and compressors. (v) two natural gas fired seeds dryers and one humidification mistral; (vi) gas boilers for space heating.
Greenhouse gas emissions (GHG). The Project is expected to produce annual GHG emissions in the region of 110,000 tons CO2-e. Sources of GHG emissions include; (i) application of fertilizers (~80,000 CO2-e, t/year).; (ii) mobile sources including fuel consumption by agricultural machinery (gasoline engines) and diesel pumps (~20,000 CO2-e tons/year); (iii) emissions from electricity: (~9,100 CO2-e, t/year including 8,500 CO2-e, t/year for irrigation activities and 600 CO2-e, t/year for ginning); and (iv) natural gas used in heating equipment of the gin plants and boilers 5,000 tons CO2-e /yeartons CO2-e /year). Going forward, Indorama Agro will quantitative monitoring of GHG emissions from its operations and report these to IFC annually. There will be a number of GHG emissions-reducing factors in the Project including use of fuel efficient and modern equipment, reduced cultivation due to modern farming practices, reduced farming operations due to simultaneous farming activities under single operation and prevention of farm residue burning due to adoption of shredding and mulching of post-harvest stalks.
Air Emissions and Ambient Air Quality. Potential environmental risks and impacts on air emissions and quality during the construction and operational phases arise from four main sources; (i) dust, (ii) products of diesel combustion in mobile sources such as farming equipment and mobile irrigation pumps, (iii) fertilizers and pesticides aerosols, and (iv) gin plants’ emissions which may contain cotton fiber, dust and chemicals used in seeds treatment. The primary pollutants of concern are nitrogen oxides (13kg NOx/h) and sulphur oxides (trace levels). Monitoring results across different locations as reported in the ESIA show that levels of NOx, CO, SO2, are within the national limits. However, ambient dust levels exceed the national standards due to the naturally high levels of dust in the atmosphere from multiple sources. Mitigation measures for air emissions during the operational phase shall include emissions management as per IFC EHS guidelines for Air Emissions and Ambient Air Quality through; (i) removal of cotton dust by air aspiration and filtration systems; (ii) trapping sulfuric acid fumes from seed treatment process; (iii) ensuring the design and operation of gas boilers meet national regulations; (iv) height of gas boilers stacks to ensure maximum dispersion of emitted pollutants; (v) continuous monitoring and timely repair of fuel tanks, pipelines and locking accessories. Going forward, as per ESAP #1, the Project will develop an environmental monitoring plan (EMP) for the construction and operation phases, including quantitative monitoring of pollution emissions from significant stationary sources, and records kept of fuel consumption (natural gas, diesel, gasoline). During the ginning period and heating season, regular monitoring of air quality shall be provided at the boundaries of gin plant sites. Indorama Agro shall adopt generic good practice dust mitigations during different phases of the project (e.g. construction, operations, decommissioning) to be monitored in line with national laws and regulations as well as WBG General EHS Guidelines.
Water use and efficiency. The Project relies on water resources for different purposes including irrigation of agricultural crops (e.g. cotton, wheat, mung bean) and for soil leaching (mostly in fields with high soil salinity in which the drainage system had deteriorated). Other water resources use include domestic and operational activities (e.g. preparation of agrochemical solutions, fire-suppression systems, vehicles washing, household needs, and ginning operations).
Agricultural water use represents the largest foreseen consumption by Indorama’s activities primarily depending on two main sources; Amu Darya river [supplying water to Qashqadaryo region (Kasbi and Nishon districts)] and Sirdaryo river [supplying water to Syradarya region (Oqoltin and Sardoba districts)]. The Project cropland makes up less than 5% of irrigated land in Qashqadaryo Region and 8% of irrigated land in Sirdaryo Region. It is foreseen that Indorama's agricultural activities will be the largest single consumer of irrigation water across the four districts. According to the ESIA, the Project impact on Amu Darya River due to reduction of abstraction volume for irrigation can be assessed as insignificant beneficial, and on Syr Darya River -as minor beneficial. However, the ESIA did not estimate water supply and delivery at the farm level due to lack of data.
Water allocation and distribution from main canals and reservoirs is controlled and managed by the state through the Ministry of Water Resources. Based on annual water availability, Basin Irrigation System Authorities (BISA) and district irrigation departments (DID) manage water supply by setting limits and an irrigation quota allocated for different Water Consumer Associations (WCA) including Indorama and other water users. While Indorama’s agricultural activities will ensure compliance with the water limits set out by the state for each district and hydro-module zone, the main challenge encountered by Indorama and other water users is related to the reliability and sufficiency of water release by the government to the agricultural fields especially during the cotton growing season from March to September. Other challenges include the amount of water wasted due to over-irrigation by other existing water users as well as the poor state of repair of irrigation infrastructure allowing significant water leaks and losses. The ESIA states that under different scenarios of water supply variations (e.g. dry seasons, wet seasons or normal seasons), the absolute water losses in both regions are unchanged from year to year based on runoff estimations, suggesting poor control of water supply. Furthermore, irrigation water consumption is not metered.
To address these issues, Indorama plans to adopt efficient irrigation techniques, improve irrigation infrastructure to enhance water delivery to fields, and is also considering drainage water reuse across the four districts. The Project targets to enhance water availability through a number of measures including; reducing water transmission losses; laser levelling of fields, the introduction of efficient irrigation systems optimal for each location (overhead lateral irrigation, pivot, fluming and syphon systems), improved drainage systems to address salination issues, thus eliminating the need for water for leaching; improved irrigation scheduling and use of sensor based irrigation (SBI) to eliminate excess and under-crop irrigation; and improved soil organic matter to increase soil water holding capacity. To address periods of potential water shortage, water reservoirs will be established as an adaptation measure for water storage to compensate for dry seasons or periods of reduced water flow. Based on initial results of cotton farming in 2019, the improvements in water delivery infrastructure (rehabilitation works (desilting and cleaning, installation of new gates to regulate water flow)) minimized water conveyance losses. These improvements in irrigation infrastructure are therefore expected to have positive impacts on water availability and will also reduce potential negative impacts on other water users.
Indorama adopts modern precision irrigation techniques to enhance agricultural water use efficiency, and is also assessing the potential impacts of its irrigation requirements on other water users, especially in areas inherently under water stress. Irrigation water use efficiency for Indorama’s agricultural operations using different irrigation methods is estimated to increase water productivity per hectare across its agricultural operations as well as the current average cotton yield from 2.5 t/ha to 5 t/ha. These estimations are in line with results of field experiments undertaken by Indorama in each province to compare yields under conventional irrigation (CI) and sensor-based irrigation (SBI). Initial results indicate that the total amount of irrigation water applied at the SBI site is 38% less than that in the CI site, even though the SBI site was irrigated four times, while the CI site received only three irrigations. Applications at the SBI also resulted in less (by 51%) run-off irrigation water from the cotton field, while the seed cotton yield was 19% higher at the SBI site as compared to the CI site. At both experiment sites (Sirdaryo and Qashqadaryo regions) sensor-based irrigation (SBI) resulted in higher water productivity (by 15% and 53%, respectively) over the conventional irrigation practice. Furthermore, as farmers start copying Indorama’s practices, with time they may also improve their water use efficiency. As set out under ESAP # 3.1.b Indorama will provide IFC with the monitoring records, of its water requirements and water use for cotton plantations, including metering data across the four project districts. These results will be reported to IFC on an annual basis.
In terms of impact of Indorama’s project on other water users, it is foreseen that distribution of irrigation water across the project areas will prioritize the requirements of farmers and smallholders, whereas Indorama will be last user to receive its water allocations. In addition, irrigation infrastructure improvements are expected to enhance water availability for other water users in the project areas. Based on focus groups with farmers and local residents conducted in December 2019 it was noted that before the start of the Indorama company operations in the Qashqadaryo and Sirdaryo regions, farmers faced periods of shortage in irrigation water (notably during summer season), however after the repair, cleaning of irrigation channels and trays by Indorama, water began to flow in sufficient volume. Despite these reports, it is important to highlight that the ESIA did not address water balance analysis at the field/farm level which may vary for different crops under different climate scenarios across each of the four districts in Qashqadaryo and Sirdaryo. Hence additional water balance assessment studies are required to precisely indicate water availability and/or reliability and volume of water release by the government at the ‘farm level’ in each of the four districts. The results of the water balance assessment will also help Indorama identify areas of potential shortage and liaise accordingly with the` government. As set out under ESAP # 3.1.a, to promote efficient and sustainable use of agricultural water in the project’s four districts, and to ensure Indorama’s operations have minimal impact on other users, Indorama will develop and implement a “Water Resources Management Action Plan” (with a timeline for action items) based on findings and recommendations of Water Balance Model notably in areas of water shortage. These results shall be communicated with the respective ministries in Uzbekistan and other stakeholders to plan for annual water allocations for irrigation purposes in each of the four districts.
Water Stewardship Program. In addition, to address the risks associated with the volumes and reliability of water deliveries from the government to Indorama’s farmland and to other water users within the project area, Indorama will submit a plan and a timeline to implement a water stewardship program and to engage with different stakeholders through the existing Water Consumer Associations (WCA) including government and water users in line with ESAP item # 3.2. Indorama shall in coordination with the Ministry of Water Resources and the existing WCA, actively participate in the water stewardship program to ensure allocation of sufficient water resources without compromising access by other users in all districts. This program will address two priority issues which affect different water users with varying degrees; (i) Reliability and volume of releases from government delivery channels, and (ii) Transmission losses between the main canals and field. This program will be based on findings of the water balance model and the ongoing monitoring of water distribution for the agricultural operations.
For Indorama’s ginning operations, the Project facilities will be connected to water and sewerage utilities from main supply lines or wells. The depot and gin plant in Kasbi district will be connected to the water supply networks operated by the local water utility “Kasbi Suvokova”. Drinking water for domestic and other needs of the depot and gin plant in Sardoba district will be supplied from artesian wells to be drilled at the gins and depots sites. For vehicles depots for washing agricultural machinery and other vehicles water recycling systems will be installed. Going forward, and as set out under ESAP items # 1, Indorama is required to report and monitor the amount of industrial water use in the established ginning facilities and processing including wastewater generated as by-products. In addition, in line with ESAP # 3.3, Indorama will check water quality for drinking and domestic uses, and if necessary, treat it in line with WHO drinking water standards.
Drainage and wastewater. The Project is using the existing drainage network which includes collectors, open drainage ditches and underground pipes. Most existing drainage infrastructure is deteriorated and requiring rehabilitation, which was undertaken by the company in Kasbi and Sardoba districts during 2017 and 2018, partially including collector networks and closed-horizontal underground pipes. In terms of drainage water pollution, a key risk is the deterioration of water quality in recipient bodies due to increased minerals content as a result of wash-out of agrochemicals (fertilizers and pesticides) and salts from soil leaching. Water testing for pesticides did not detect presence of these chemicals in drainage water as they are applied in small amounts, and also are rapidly degraded due to high temperature conditions. In Qashqadaryo, recipient water bodies include Kashka Darya river and Deuhana lake. Given the poor initial quality of water in the Kashka Darya River and Deuhana Lake, sensitivity of these receptors to the pollution impact has been assessed as medium in the ESIA. In Sirdaryo, recipient water bodies include Aidar-Arnasay closed lake system comprised of Aydarkul lake, Tuzkan lake and smaller East-Arnasay lakes fed by the irrigation drainage water, and part of flood water from Shardara Reservoir. The impact on receptors caused by potential increase of salt and agrochemicals levels in drainage water due to reclamation and leaching of abandoned and salinised fields at the initial stage of the Project operation is assessed as significant adverse, with a trend toward reduction to minor, provided that a reasonable approach is adopted for application of fertilizers and pesticides. Going forward, as per ESAP item # 1, a Soil and Drainage Water Monitoring Plan shall be developed to prevent pollution by ensuring the quality of drainage waters not to exceed maximum allowable concentrations for discharge of wastewater in line with good international industry practice (GIIP), as set out in WB EHS Guidelines on water and sanitation. In addition, in line with ESAP item # 3.4 to reduce negative impacts on drainage water quality, Indorama will develop and implement strict instructions on preparation of fertilizers, pesticides and other agrochemicals solutions and will audit storage areas for these substances. Indorama will also undertake accurate identification of crops needs.
Sanitary wastewater will be collected in septic tanks and removed for treatment by contractors. Such wastewater will be required to meet the contractor’s technical conditions and requirements to material in septic tanks. No standards for material in septic tanks are set at the national level. For industrial activities, the Project will connect depots and gin plants to domestic wastewater collection systems. In absence of central sewerage systems, domestic wastewater will be collected in septic tanks and subsequently removed for treatment by specialized contractor. The Project will construct storm water collection systems at the vehicle depots and two gin sites. These facilities should include grit removal and oil trapping to comply with the national requirement. Treated storm water will be discharged to drainage collectors. Going forward as per ESAP # 3.5, Indorama will follow good international industry practice (GIIP), as set out in EHS Guidelines to ensure sanitary and industrial wastewater disposal is compliant with IFC’s requirements, as the minimum level of mitigation in the absence of national legislation or applicable international guidance.
Management of solid and hazardous wastes. Hazardous waste includes pesticides, fertilizers, oils, lubricants, fuels, solvents waste, contaminated packaging, cleaning materials, used batteries, mercury lamps and cement as well as other chemicals related to the plants care, such as those for cotton defoliation. Negative environmental impacts may be associated with soil and groundwater contamination due to accidental spills or leaks of hazardous substances by storage tanks, losses during transportation, usage of excessive volumes of chemicals associated with agricultural activities and inappropriate disposal of waste. Hazardous wastes (oil, mercury lamps, waste pesticides and fertilizers) will be transferred to licensed contractor for neutralization and final disposal at landfill. Impacts from waste can be suitably mitigated by following a project-specific waste management plan to ensure zero discharge, particularly handling and final treatment or disposal options of hazardous substances through the mechanism of recollecting used products, re-processing and re-cycling.
Non-hazardous and solid waste include; agricultural waste, which will be reused in agricultural fields to improve and regenerate soil structure through organic matter; Off grade cotton seeds will be sold to cotton oil producers; Cotton fiber waste will be sold for production of cellulose; Domestic waste will be transferred to licensed contractors for disposal in landfill;; Metal scrap will be transferred for recycling. The quantity of wastes from Indorama Agro operations will be determined at further stage of design development, based on the Project design characteristics. Going forward, as set out in ESAP #1 a Waste Management Plan (WMP) for construction and operations phases shall be prepared and will incorporate mitigation measures for disposal of both hazardous and solid/non-hazardous waste as required by national regulations and good practice, including those set out in IFC EHS General Guidelines for hazardous, solid and liquid waste.
Agrochemicals Use and Management. Considering the Project’s crop fields size of 50,000 ha, Indorama will apply Crop Protection Products (CPPs) through integrated pest management and targeted application of chemicals. Fertilizers and anti-pest treatment application will take place up to four times a year. There are three main types of fertilizers used including; Ammonium nitrate 34% (twice a year: 600 kg/ha) Ammonium Phosphate 46% (once/twice a year: 300 kg/ha) and Potassium Chloride (once a year: 100 kg/ha). The Project will promote digital mechanized production management via digital machine offering variable rate application of fertilizers, seeds, and pesticides. Application of fertilizers and pesticides will be undertaken by tractors using vertical precision sprayers (dispensing from 2m height to soil surface) to ensure the targeted application of chemicals and reduced water usage.
Potential negative environmental impacts of uncontrolled application of pesticides and fertilizers may include soil contamination and/or pollution of drainage water and recipient water bodies. Considering that pesticide packages are small (100 to 550 grams) and that fertilizers and pesticides are supplied as dry solids, leakage to the environment is unlikely. Through the seedling program, the Project will improve the quality of seeds and varieties to increase yields and crop resistance to pests, thus reducing the need to apply CPPs, while Nitrogen fixation via mung beans will reduce the need for Nitrogen application for cotton. Going forward, as set out in ESAP item #3.6, to avoid soil contamination, Indorama shall ensure hazardous materials are suitably stored to prevent leaks and spills with adequate bundling will be provided for all fuel and chemicals storage and fertilizers and pesticides solutions are prepared in application machinery tanks or at a dedicated site with impermeable paving and a drainage system. In addition, as per ESAP item #3.7 Indorama will Develop an Emergency Action Plan to respond to accidental discharge of petroleum products, pesticides and other agrochemicals into soil, drainage collectors and irrigation canals.
