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EN4001 Environmental Impact Assessment & Monitoring PDF

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Document Details

TolerableGyrolite5918

Uploaded by TolerableGyrolite5918

Nanyang Technological University, Singapore

Dr. Lim Tuti Mariana

Tags

environmental impact assessment environmental management EIA environmental studies

Summary

This document provides teaching materials for Environmental Impact Assessment & Monitoring, specifically covering Week 5.1 on EIA process, mitigation, monitoring, auditing, and EIA reports. The lesson objectives are detailed, along with the importance of various aspects of mitigation.

Full Transcript

EN4001 Environmental Impact Assessment & Monitoring Week 5.1: EIA Process - Mitigation, Monitoring, Auditing and EIA Report Teaching materials are provided by Dr. Lim Tuti Mariana Week Content EIA Procedure: Mitigation, Implementation &...

EN4001 Environmental Impact Assessment & Monitoring Week 5.1: EIA Process - Mitigation, Monitoring, Auditing and EIA Report Teaching materials are provided by Dr. Lim Tuti Mariana Week Content EIA Procedure: Mitigation, Implementation & Monitoring, Report & 5 Auditing, Review and Decision Making, Planning & Management 6 EIA Impact Assessment Methodologies + Tutorial 1 7 EIA Impact Assessment of Air Environment + Tutorial 2 Recess 8 QUIZ; group project discussion 10/9/24 2 2 Introduction and Objectives Contents Lesson Objectives Mitigation At the end of this lesson, you should be able to: Explain the mitigation concepts and methods in Implementation EIA and why they are necessary. and Follow-up: Explain the strengths, weaknesses and Monitoring appropriateness of different mitigation options. Auditing Identify the appropriate mitigation measures for Importance of a range of particular impacts. EIA Report Explain the importance of implementation and Components of follow-up works of monitoring and auditing. EIA Report Explain the importance of the EIA report. Shortcomings of List the components of the EIA report. EIA Report List the shortcomings of the reports. Distribution of Explain how EIA reports are distributed. EIA Report 3 Mitigation in EIA The diagram below explains the process of mitigation in EIA: Mitigation EIA and project design Included in EIA A critical component of EIA process report and should work for early identification of implemented mitigation opportunities during the impact management To prevent To keep stage adverse impact impacts that To incorporate them do occur to into consideration of an acceptable alternatives and level design option 10/9/24 4 Mitigation Objectives The objectives of mitigation are: Ø Find better alternatives and ways of doing things Ø Enhance the environmental and social benefits of a proposal Ø Avoid, minimise or remedy the adverse impacts Ø Ensure that residual adverse impacts are kept within acceptable levels 10/9/24 5 Main Elements of Mitigation Shown below are the hierarchical actions of the mitigation process: Common, Alternative sites or technology preferable Impact Avoidance - to eliminate impacts Actions during design, construction Impact and operation - to minimise or Minimisation eliminate impacts Impact Compensation Used as a last resort to offset impacts Rare, Undesirable 10/9/24 6 Mitigation Objectives Shown below are the hierarchical actions of the mitigation process: Common, preferable Impact ImpactAvoidance Avoidance Impact avoidance is the most effective step when applied at the early stage of project planning. Impact For example: Minimisation Modifying project design or production processes Impact Treating at source or reduce Compensation wastes by recycling Discharging waste to less Rare, sensitive areas Undesirable Restricting hours of operation or public access 10/9/24 7 Main Elements of Mitigation Shown below are the hierarchical actions of the mitigation process: Common, preferable Impact Avoidance For example: Landscaping to blend structure into local environment Impact Using silt traps, silt curtains Minimisation during dredging Providing sound insulation or Impact air conditioning to reduce Compensation noise or dust Reducing scale of operation Rare, Creation of buffer zones Undesirable 10/9/24 8 Main Elements of Mitigation Shown below are the hierarchical actions of the mitigation process: Common, Remedy: preferable Impact Avoidance Rehabilitation Re-stocking Impact Afforestation Minimisation Oxygenation of water Compensation: Creation of lost facilities or Impact Compensation jobs elsewhere Paying money to affected Rare, parties Undesirable Relocation of affected families or villagers 10/9/24 9 Approaches to Mitigation Listed below are the main approaches to mitigation: Developing better Making changes Carrying out Giving compensation alternatives to project impact monitoring such as monetary, in- planning and and management kind, site remediation design or resettlement plan 10/9/24 10 Approaches to Mitigation Developing better alternatives Listed below are some approaches to mitigation: Broad range alternatives are generated at the earliest stage of planning and design when the process is still flexible and becomes lesser at the later stage. Site or design alternatives can be reconsidered for later stage of design. Developing better Making changes Carrying out Giving alternatives to project impact monitoring compensation planning and management such as monetary, in-kind, site remediation or resettlement plan 10/9/24 11 Approaches to Mitigation Making Listed below are somechanges to project approaches planning design to mitigation: Enable impact avoidance and minimisation: address impacts throughout the life cycle of the project and identify the best practicable ways and means to mitigate them. Developing better Making changes Carrying out Giving Potential alternativesimpacts of climate to project change have to be considered in mitigation impact monitoring compensation planning and design.planning and management For example, to address such as monetary, increased or reduced in-kind, site precipitation. remediation or resettlement plan 10/9/24 12 Implementation and Follow-Up The key objectives of implementation and follow-up are: Ø To confirm that the conditions of project approval are implemented satisfactorily Ø To verify that impacts are within predicted or permitted limits Ø To take action to manage unanticipated impacts or other unforeseen changes Ø To ensure that environmental benefits are maximised through good practice Ø To learn from experience in order to improve the EIA process and practice 10/9/24 13 EIA Implementation and Follow-Up Terminology Shown below are the terminologies of EIA implementation and follow up: Term Surveillance and supervision Surveillance and supervision Surveillance of the implementation of EIA terms and conditions can be undertaken by Monitoring regular or periodic site inspections to check on compliance, observe progress and discuss issues. Auditing Supervision implies a more intensive direction of the environmental performance of on-site Evaluation activities, ensuring they are carried out in accordance with the environmental management Post project analysis plan and or contract specifications. Source: 11-1 Key Objectives of EIA implementation and follow up. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/course/index.html?page_id=89.html 10/9/24 14 EIA Implementation and Follow-Up Terminology Shown below are the terminologies of EIA implementation and follow up: Term Monitoring Surveillance and supervision Monitoring refers to the collection of data through a series of repetitive measurements of Monitoring environmental parameters (or, more generally, to a process of systematic observation). Auditing The main types of EIA monitoring activities are: baseline monitoring, effects monitoring and Evaluation compliance monitoring. Post project analysis Source: 11-1 Key Objectives of EIA implementation and follow up. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/course/index.html?page_id=89.html 10/9/24 15 Implementation and Follow-Up - Monitoring Monitoring is the basis of EIA implementation and follow up. The key objectives of the monitoring process are: To provide information to aid impact management To better understand the cause-effect relationship To improve the impact prediction and mitigation methods 10/9/24 16 Implementation and Follow-Up - Monitoring Monitoring is used to: Establish baseline trends and conditions Measure the impacts that occur during project construction and operation Carry out compliance check against the agreed conditions and standards Facilitate impact management, for example, warning of unanticipated impact Determine the accuracy of impact prediction and effectiveness or mitigation measures 10/9/24 17 Implementation and Follow-Up - Monitoring Monitoring is used to: ü Establish baseline trends and conditions ü Measure Sound the impacts baseline that occur is a critical during reference pointproject construction for effectiveand operation monitoring as it can establish the basis for ü Compliance corrective check againstactions if the condition agreed actual and impacts are unanticipated or worse than standards the predicted values. ü Facilitate impact management (warning of unanticipated impact) ü Determine the accuracy of impact prediction and effectiveness or mitigation measures 10/9/24 18 Implementation and Follow-Up - Monitoring Shown below are the approach and reporting of the EIA monitoring process: Approach Reporting Compare pre and post Monitoring data needs to be project situations by the interpreted and reported to measuring relevant non-scientific audience. Hence, environmental impacts the report should be in plain against baseline conditions. language and appropriate technical standards Data Collection Collection of monitoring data is expensive. There fore, only necessary information is targeted to manage impacts by considering which one is significant. The data should be identified as early as possible in the EIA process to optimise contribution of monitoring data to 10/9/24 EIA implementation and follow-up. 19 EIA Implementation and Follow-Up Terminology Shown below are the terminologies of EIA implementation and follow up: Term Auditing A systematic process of examining, documenting Surveillance and supervision and verifying that EIA procedures and outcomes correspond to objectives and requirements. Monitoring This process can be undertaken during and or after Auditing project construction, and draws upon surveillance reports and monitoring data. Evaluation The main types of EIA related audits are: implementation audits, impact audits, compliance Post project analysis audits and effectiveness or policy audits Source: 11-1 Key Objectives of EIA implementation and follow up. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/course/index.html?page_id=89.html 10/9/24 20 Implementation and Follow-Up - Auditing EIA auditing process is a review process similar to financial accounting with an added level of interpretation focusing on performance factors. The main techniques of the process include the following: Techniques Examination of records and documentation Site inspection to check Interviews with relating to impacts, that environmental management and line measures and controls actions taken to staff to collaborate manage them and are operating as factual information and aspects of performance described and intended probe areas of concern 10/9/24 21 Implementation and Follow-Up - Auditing In any EIA process, audit is used to: Identify the impacts of project implementation Verify whether or not the conditions of approval have been implemented Test the accuracy of impact predictions Check the effectiveness of mitigation measures Improve compliance and performance of EIA practice Audit is done on ad-hoc basis. 10/9/24 22 Implementation and Follow-Up - Auditing Shown below is an example of environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SAR. Background Background Environmental monitoring and audit (EMA) programmes are Project carried out to ensure that the measures recommended in the EIA are actually implemented and appropriate actions are EMA Programme taken in cases where the impact exceeds the established limit. Summary of results Key Lessons Source: Chek Lap Kok Airport. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/wiki/index.php/Chek_Lap_Kok_Airport.html#Project 10/9/24 23 Implementation and Follow-Up - Auditing Shown below is an example of environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SAR. Background Project The Chek Lap Kok Airport was built between 1991 and Project 1997 at a total cost of US$ 20 billion. It involved the reclamation of approximately 1,250 ha site and facility development and related projects and infrastructure, EMA Programme including a new town of 20,000 (Tung Chung), and a 34 km high speed rail and road expressway to the city centre. Summary of results Major areas of concern in site construction and operation included air quality, noise, water quality, waste and Key Lessons ecological damage resulting from dredging, dumping and reclamation. Source: Chek Lap Kok Airport. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/wiki/index.php/Chek_Lap_Kok_Airport.html#Project 10/9/24 24 Implementation and Follow-Up - Auditing Shown below is an example of environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SAR. Background EMA Programme An EMA system was instituted to follow up on the Project implementation of EIA measures. The monitoring component focused on aspects of particular EMA Programme concern, including water quality, air emissions, noise and dust levels. Summary of At the airport reclamation site, the initial water quality results monitoring network was inadequate and had to be relocated to provide a more realistic set of auditing criteria. Key Lessons Source: Chek Lap Kok Airport. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/wiki/index.php/Chek_Lap_Kok_Airport.html#Project 10/9/24 25 Implementation and Follow-Up - Auditing Shown below is an example of environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SAR. Background EMA Programme (cont’d) The audit component compared actual and predicted Project impacts, and the effectiveness of environmental instruments, such as clauses included in licenses, contract EMA Programme specifications and planning and land lease conditions. The programme was carried out by developing a reference Summary of manual and database, monthly and quarterly reports on results compliance and performance, respectively, and policies and procedures to be followed in the event of breaches and Key Lessons non-compliance. Source: Chek Lap Kok Airport. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/wiki/index.php/Chek_Lap_Kok_Airport.html#Project 10/9/24 26 Implementation and Follow-Up - Auditing Shown below is an example of environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SAR. Background Summary of results The audit of the effectiveness of environmental instruments Project concluded that not all EIA recommendations were included in contracts, many specifications were too general, and EMA Programme means of enforcing or inducing compliance were insufficient. Summary of An underlying issue was the variance between the project results as designed and as constructed, compromising many EIA measures and requiring renegotiation of mitigation. Key Lessons Source: Chek Lap Kok Airport. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/wiki/index.php/Chek_Lap_Kok_Airport.html#Project 10/9/24 27 Implementation and Follow-Up - Auditing Shown below is an example of environmental monitoring and audit of the Chek Lap Kok Airport, Hong Kong SAR. Background Key Lessons EIA documents must be prepared with the EMA Project requirements in mind, for example, auditable predictions and well-defined mitigation measures, with provision for EMA Programme their renegotiation if design and construction vary. In addition, these measures should be translated into Summary of practicable, enforceable specifications. The regulatory results agency should have the necessary legal authorities for this purpose. Key Lessons Source: Chek Lap Kok Airport. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/wiki/index.php/Chek_Lap_Kok_Airport.html#Project 10/9/24 28 EIA Implementation and Follow-Up Terminology Shown below are the terminologies of EIA implementation and follow up: Term Evaluation Surveillance and supervision Ex-post evaluation involves a policy-oriented review of the effectiveness and performance of the EIA process. Monitoring It is concerned with the overall “balance sheet” of Auditing an EIA, looking at what it achieved, which aspects were influential, and how the process could be Evaluation improved. Post project analysis The guiding concepts are based on the following key aspects: effectiveness and performance. Source: 11-1 Key Objectives of EIA implementation and follow up. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/course/index.html?page_id=89.html 10/9/24 29 EIA Implementation and Follow-Up Terminology Shown below are the terminologies of EIA implementation and follow up: Term Post project analysis Usually, a post-project analysis is undertaken once the Surveillance and supervision project has been constructed and is about to enter the operational phase. Monitoring The term implies a focus on project specific EIA experience, such as in relation to dams, highways, waste Auditing disposal sites or power generation. Evaluation In this context, post-project analysis can include aspects of effectiveness and performance review, using impact and mitigation data from surveillance, monitoring and Post project analysis auditing. Source: 11-1 Key Objectives of EIA implementation and follow up. (n.d.). Retrieved December 15, 2015, from http://eia.unu.edu/course/index.html?page_id=89.html 10/9/24 30 Role of EIA Implementation and Follow-Up Shown below is a diagram on the role and position of monitoring and management in EIA: Strategic Planning Proposal Screening and Scoping Existing Baseline data monitoring Impact assessment Monitoring and impact management for implementation Information and operation Decision to an EMS Terms and (example: conditions of ISO 14000) Surveillance compliance checking approval Baseline effect compliance monitoring Implementation Proactive activity monitoring/assessment Ongoing Impact management EIA audit and post auditing 10/9/24 Design reassessment project analysis 31 EIA Implementation and Follow-Up Terminology EIA Monitoring Activities Listed below are some approaches to mitigation: Baseline Monitoring Activities taken during pre-project period: to determine baseline trends and conditions to establish reference points for changes to be measured Effects Monitoring Activities taken Developing betterduring project Making constructionCarrying changes and implementation out to detect Giving alternatives to project to the project. changes which are attributed impact monitoring compensation planning and management such as monetary, Compliance Monitoring in-kind, site remediation or Periodic sampling or continuous measurement to ensure that regulatory resettlement plan requirements and standards are being met. 10/9/24 32 EIA Implementation and Follow-Up Terminology Listed below are some approaches to mitigation: Effect and compliance monitoring are reactive approach as they detect violation Effects Monitoring after it occured. Activities taken during project Thus it is construction and important to set implementation predetermined to detect changes which are attributable actions to theonproject. which are triggered a threshold Developing better Makingbased on the results changes of these Carrying out monitoring. Giving alternatives to project impact monitoring compensation Compliance Monitoring Pro-active and adaptive planning approach should and management bemonetary, such as Periodic sampling or continuous measurement used through supervision or to ensure regular that in-kind, site and standards are being met.remediation regulatory requirementsinspection. or resettlement plan 10/9/24 33 EIA Implementation and Follow-Up Terminology EIA Related Audits Listed below are some approaches to mitigation: Types of audits Description Implementation To verify that EIA implementation met the conditions of audits project approval. Impact audits To determine the impact of the project and the accuracy of EIA predictions. Developing better Making changes Carrying out Giving alternatives Compliance audits to Toproject impact are verify that project impacts monitoring compensation complied with planning environmental standards and management and such as monetary, regulatory requirements. in-kind, site remediation or Effectiveness or To check the feasibility of mitigation measures and the resettlement plan policy audits consistency of EIA practice. 10/9/24 34 EIA Implementation and Follow-Up Terminology Implementation audits to verify Common that EIAdifficulties implementation met the in monitoring conditions and auditing of Listed below project are some approaches to mitigation: approval. Impact audits Common difficulties encountered for monitoring to determine Effects Monitoring theand impact of the project and the accuracy of auditing: EIA predictions. Activities taken during Limited project baseline information construction and implementation to detect changes Qualitative and non-auditable to the impact Compliance audits which are attributable project. Developing better prediction Making changes complied to verify that project impacts with Carrying out environmental Giving alternatives to Late changes to project project impact design and compensation monitoring Compliance standardsMonitoring and regulatory planning requirements. mitigation and management such as monetary, Periodic sampling Effectiveness or continuous or policy audits Long measurement to ensure lead time before certain trends and that in-kind, site remediation or regulatory requirements and impacts standards are can be identified being met. to check the feasibility of mitigation measures andresettlement the plan consistency of EIA practice. 10/9/24 35 EIA Implementation and Follow-Up Terminology EIA Ex-post Evaluation Guiding Concepts Listed below are some approaches to mitigation: Effectiveness the extent to which the EIA process has achieved its purpose(s). Depending on how these are defined, an effectiveness review can be conducted against the terms of reference, the information provided to decision-makers or principles and criteria of EIA good practice (see Section 1 – Introduction and Overview of EIA). Developing better Making changes Carrying out Giving alternatives to project impact monitoringcompensation planning and management such as monetary, Performance in-kind, site the success of the EIA process as measured by its outcomes and results. remediation or Surveillance, monitoring and auditing data are necessary for this purpose. resettlement plan 10/9/24 36 Summary of EIA Implementation and Follow-Up l i an ce Comp ring Effects to Surveillan ce moni and supe rvision monitoring p l i cabl e n su r e ap E Measur e g u l atory ental r e rd s and Oversee adhere environm a stand ments are nce g e d ue to re to and chan requi implementation project i n g met of b e terms and cond ition he Check t ss effectivene n of mitigatio measures 10/9/24 37 Summary of EIA Implementation and Follow-Up r o je ct p P ost a l y s is Audit Evaluation an ua t e the Eva l e sul t s of ll r Verify overa t implementa Review the projec ment and and op tion of effectiveness devel learnt for terms and c f onditions performance o lesson rojects ith p Measure EIA process w future effectivenes s and respect to a t compliance with specific projec regulatory standards an d requirement 10/9/24 38 Introduction to EIA Report EIA report is a document reporting the findings of the EIA process. Some examples of EIA reports are: Ø Environmental Impact Statement (US) Ø Environmental Statement (EU) Purpose: to provide a coherent statement of the potential impacts and the measures taken to reduce and remedy them. 39 Introduction to EIA Report An EIA report typically has four sections: 1. An introduction with the purpose and need of the 2. A description of proposed action the affected environment 3. A range of alternatives 4. An analysis of the environmental impacts 10/9/24 40 Introduction to EIA Report Proponent: prepare and carry out the proposal in an environmentally and socially responsible way. Responsible authority: make an informed decision including setting terms and conditions for approval. Public: understand the proposal and its potential impacts on people and the environment. A successful report must be actionable, which means it can be carried out by the proponent to achieve environmental sustainability. 10/9/24 41 Components of EIA Report Contain information as specified in legislation, procedure or guidance Include contents in accordance with terms of reference established during the scoping process The components (headings and items) of an EIA report include: Executive or non-technical summary Need and objective of the proposal Reference to applicable legislative, regulatory and policy frameworks Description of the proposal include implementation stage (construction, operation and decommissioning) Comparison of the proposal and its alternatives Description of the project setting including the relationship to other proposals, current land-uses and relevant policies and plans for the area. 10/9/24 42 Components of EIA Report The components (headings and items) of an EIA report include: Description of baseline conditions and trends Review of the public consultation process Consideration of identified main impacts and their predicted characteristic, proposed mitigation measures, residual effects and any uncertainties and limitations of data and analysis Evaluation of the significance of the residual impacts for each alternative to identify best option Environmental management plan describing how proposed mitigation and monitoring measures (included in an annex or separate document) Appendices containing supporting technical information, description of methods used, references and others 10/9/24 43 Executive or Non-Technical Summary Executive or non-technical summary: critical component Often being the only part read by decision makers and people, hence it should be short and concise (seven pages or less) Focus on the key information and options for decision making For distribution to the public as information brochure 10/9/24 44 Executive or Non-Technical Summary Typical executive summary contains: The proposal and its setting Terms of reference for the EIA The results of public consultation The alternatives considered Major impacts and their significance Proposed mitigation measures The environmental management plan Any other matters that need decision making 10/9/24 45 Shortcomings of EIA Report Report should be easily understood, objectives, factual and consistent Many contributors and tight deadlines may cause difficulty to achieve good EIA report Shortcomings and Deficiencies of EIA reports and Reporting Examples Shortcoming EIA Reporting Example Source: Netherlands EIA Commission An EIA report substantiates the need for offshore The need for a exploratory drilling in a remote and sensitive Arctic Sound project cannot be primarily in terms of energy security and economic justified development. The broader opportunity costs of opening the area to development are overlooked. The objective and An EIA report on a proposed by-pass road identifies the alternatives are objective as relieving traffic congestion, failing to consider too narrowly broader transport issues and alternatives. 46 stated 10/9/24 Shortcomings of EIA Report Shortcomings and Deficiencies of EIA Reports and Reporting examples Shortcoming EIA Reporting Example Source: Netherlands EIA Commission The description of the An EIA report describes the proposed construction of an industrial plant but proposal does not cover omits information about construction of a pipeline and other facilities to the key features transport and handle raw materials and finished products to and from the plant. Selection of alternatives The EIA report on a car racing circuit in a coastal dune landscape only considers does not take into alternatives meeting motor sport requirements, visitor ‘needs’ and public safety account environmental regulations. It overlooks environmental considerations, such as noise aspects abatement, protection of land surface and dune ecology. An EIA report describes the proposed construction of a coal-fired power plant Key problems affected by using surface water as cooling medium. It does not divulge that the surface the proposal are not water body is already used by other industrial activities for this purpose to the described limit of its cooling capacity. Sensitive elements in the An EIA report for a pipeline project does not indicate that the proposed affected environment are alignment will dissect certain areas of ecological value. overlooked 10/9/24 47 Shortcomings of EIA Report Shortcomings and Deficiencies of EIA Reports and Reporting examples Shortcoming EIA Reporting Example Source: Netherlands EIA Commission Environmental target An EIA report for an extension of an airport describes the impacts up to values and standards are the standard of 25 per cent of people seriously affected by aircraft not properly taken into noise, whereas the target value aims at 10 per cent of people seriously account affected. An EIA report for a sanitary landfill indicates that the soil types in the Alternatives do not comply area are very diverse, ranging from sand and clay to peat. The with environmental alternatives do not take into account the large differences in regulations and standards compaction and subsidence of these soil types, with subsequent failure of underlining and drainage systems. An EIA report for a sanitary landfill does not describe a system for Appropriate mitigating collecting methane gas produced in the landfill, even though measures are not greenhouse gas emissions contribute to climate warming and should be considered capped at current levels. Good EIA reporting should address these shortcomings. 48 10/9/24 Distribution of EIA Report EIA reports should be made available to the public and distributed widely particularly to those who have interest or are affected by the proposal. Special measures are required for proposals that affect the poor and non-literate community. Presentation of the findings can be: Local media, radio or television Community report Newsletters and information sheets Walk-in and storefront displays Feedback through the local chief 10/9/24 49

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