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3.5 Potential Cumulative Impacts

The major environmental concerns, as described in Section 3.3 are water and soil pollution, soil erosion, and the consequences and secondary effects that erosion will cause.

Considering the small size of most sub-projects, it would be easy to dismiss the negative effects that each project might have on the environment. For instance, it is anticipated that small farmers will request modest loans for the purchase of basic farm inputs of seed, fertilizers, pesticides and fuel, and for livestock. Such a loan to a single farmer would present little environmental concern and a large number of such small loans spread throughout the country would have a relatively negligible effect. However, if by chance a large number of requests for loans originated from the same area, and more importantly from the same watershed, the cumulative effect of all of the small (negligible) effects could be significant.

Cumulative effect is important in spatial terms, as indicated above, and also over time. For instance, a loan for seed purchase in itself has no negative impact, and in fact, has much the opposite with an increased production and return to the farmer. However, the same loan provided for more than two years in a row could promote poor crop and land management and disrupt a relatively current good agricultural management system characterized by long rotations. By avoiding a crop rotation program the farmer can deplete the fertility and organic content of his soil and further promote soil erosion. Over time there would be a cumulative effect.

Farmers should not be denied grants and credits on the basis of their location, but if monitoring of patterns indicates concentrations of loans (e.g. fertilizers) in one watershed, the PMU environmental specialist should alert the PFIs and local environmental authorities and the PMU office for special monitoring of the situation. If the cumulative effects have the potential to become severe, lending for the activity should be suspended.

Another example applied to small and medium enterprises is the application of loans for rehabilitation or for the start-up of new businesses. With agro-processing and other agribusinesses, the environmental concerns usually focus on air emissions and effluent discharge. In the case of air emissions, there are usually standards in place that guide the concentration of various emissions at the stack. Although each industrial activity may have emission controls well within established national standards, cumulatively, all of the enterprises in one region (e.g. in a small closed valley with poor air circulation) could significantly contribute to the deterioration of overall air quality, resulting in an impact on human health. Similarly for water quality, a number of enterprises releasing effluents into a water body could cumulatively affect the quality of the water in a significant manner even though each enterprise may be releasing very small amounts of effluent that meet set standards.

The other aspect of cumulative effects of the overall project is the accumulation of a large number of very small impacts over the full range of grant and credit-funded activities. That is, the cumulative impact of all of the small impacts as a result of a number of loans for fertilizer purchase, added to the cumulative impact of all of the small impacts from the livestock purchase sub-project, added to the cumulative impact of all of the small impacts from the non-farm enterprises. The overall cumulative impact could be significant. Since many of these activities can have an effect on water quality, the overall effect on water quality could be significant.

In a comprehensive examination of cumulative effects, analysis would be made of all of the other activities taking place that have impacts. For instance, other programs that could be providing agricultural lines of credit or agricultural grants, forestry programs that could be contributing to soil erosion, and in the same vein, road construction activities and other general construction that could add to the soil erosion problem. Although the ADCP-2I cannot be concerned about the impacts of other projects, it is important to place the Project and the effects that it does have on the environment within the context of the overall development paradigm..

In order to prevent the risk of adverse cumulative environmental effects, a brief environmental analysis will be made of the portfolio every year by the PMU environmental specialist and reported to the relevant authorities in the Ministry of Ecology and Natural Resources and the World Bank.

3.7 Mitigation

For agricultural activities mitigation should not necessarily entail expensive inputs and much can be achieved towards the minimizing of residual impacts through applying appropriate, efficient and safe farming techniques. For instance when implementing the subprojects requiring pest management, the EMP will recommend the application of Integrated Pest Management practices. The PMP is referred for the provisions for encouraging safe pesticide handling and disposal. That would allow mitigating not only impact on the environment but significantly reduce costs for plants treatment since the major quantity of pesticides is quite often consumed with no need and does not contribute to gain the required output.

Legislative requirements fulfillment should be the obligatory provision. The Ministry of Agriculture (MoA) is in a position to advise farmers on the proper handling and application of pesticides and fertilizers, including application rates and timely application. Application of those permitted pesticides is also significant. The Government of Azerbaijan is committed to ensuring compliance with POPs Convention to eliminate the use of insecticides listed under POPs. Further, in compliance with World Bank O.P. 4.09 on Pest Management, which states “The Bank does not finance formulated products that fall in WHO classes IA and IB, or formulations of products in Class II, if (a) the country lacks restrictions on their distribution and use; or (b) they are likely to be used by, or be accessible to, lay personnel, farmers, or others without training, equipment, and facilities to handle, store, and apply these products properly.” The Project will ensure no Class 1A and 1B products are used, and wherever and whenever possible, proper trainings are conducted wherever Class II products may be used. 

MoA can also advise on effective cultivation techniques (including the size of tractors and the type of equipment to be engaged) that will reduce the threat of soil erosion. The advanced agricultural practice will contribute to the additional mitigation of impact (e.g. organic farming or zero tillage) which would have not only environmental advantages but allow growing with the lowest costs and get the environmentally clean products. These methods do not cause wind erosion and on the contrary contribute to increase the natural soil fertility. The application of driven livestock methods will allow significantly reduce the impact of livestock pasturing on soil and increase the pasture productivity.

Adherence to national water and air quality standards will be monitored by local environmental agencies to ensure that these environmental components are protected. Techniques to be used in extraction and manufacturing sectors are often a matter of choice, albeit mostly economic. The environmental requirement will have to be considered when such choices are made. Such consideration will be the responsibility of the proponent and he/she will be required to absorb the economic cost of the environmental mitigation.. . Suggested mitigation for the various potential impacts is provided in Annexes 7. Guidance for preparation of mitigation plans is attached at Annexes 2 and 3 (Tables A-2.3, A-3.1, A-3.2). Measures to ensure proper environmental management in laboratories are specified in Section 4.3.1 below. Also, guidelines for laboratory waste management according to international good practice are listed in Annex 8.

To further ensure that environmental concerns are given proper consideration, the PMU will hire an environmental expert (Environmental Specialist, TOR outline is attached in Annex 7A) who can advise on environmental aspects of grants and credit line to agribusinesses, as well as conduct overall project environmental monitoring. Similarly the PMU Environmental Specialist will provide advice and monitoring to PFIs regarding environmental screening of grant and small credit applications.