THE PROJECT FOR INSTITUTIONAL DEVELOPMENT OF AIR QUALITY MANAGEMENT IN THE SOCIALIST REPUBLIC OF VIETNAM PROJECT COMPLETION REPORT

Transcription

1 MINISTRY OF NATURAL RESOURCES AND ENVIRONMENT (MONRE) THE SOCIALIST REPUBLIC OF VIETNAM THE PROJECT FOR INSTITUTIONAL DEVELOPMENT OF AIR QUALITY MANAGEMENT IN THE SOCIALIST REPUBLIC OF VIETNAM PROJECT COMPLETION REPORT MAY 2015 JAPAN INTERNATIONAL COOPERATION AGENCY (JICA) NIPPON KOEI CO., LTD. SUURI-KEIKAKU CO., LTD. GE JR

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3 MINISTRY OF NATURAL RESOURCES AND ENVIRONMENT (MONRE) THE SOCIALIST REPUBLIC OF VIETNAM THE PROJECT FOR INSTITUTIONAL DEVELOPMENT OF AIR QUALITY MANAGEMENT IN THE SOCIALIST REPUBLIC OF VIETNAM PROJECT COMPLETION REPORT MAY 2015 JAPAN INTERNATIONAL COOPERATION AGENCY (JICA) NIPPON KOEI CO., LTD. SUURI-KEIKAKU CO., LTD.

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5 Tay Ninh Binh Duong Vinh Phuc Ho Chi Minh Hanoi Dong Nai Phu Tho Hoa Binh Hung Yen Long An Ha Nam Location Maps of the Project Tien Giang

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7 SOCIALIST REPUBLIC OF VIETNAM The Project for Institutional Development of Air Quality Management in Vietnam Table of Contents Page CHAPTER 1 GENERAL Background and Objectives Project Design Agreed in the Record of Discussions on March 26, Approach for Project Implementation Technical Approach Operational Approach Overall Implementation Flow and Actual Schedule of the Project CHAPTER 2 ACTIVITIES AND ACHIEVEMENTS OF THE PROJECT Output 1: Technical and Institutional Development as Preparedness for the Law on Environmental Protection (LEP) Amendment Amendment of LEP Results and Key Findings of Survey on Air Quality Management (AQM) Activities at the Central Level Results of Technical Cooperation Products Output 2: Roadmap to Develop the Air Quality Management Plans of Hanoi City and Ho Chi Minh City (HCMC) Results and Key Findings of Survey on AQM Activities in Hanoi City and HCMC Sharing Technical Knowledge of Output 1 with the Two Cities for Formulating the Roadmap under Output Results of Roadmap Formulation Other Activities Support to PCD for Emissions Inventory Development of the Selected Subsectors Support to CEM for Improving Flue Gas Measurement Provision of Policy Recommendations for Drafting the New Decree on Waste and Scrap Management Coordination with Other JICA-related Projects, JICA Advisors, and Other Donors Activities Capacity Assessment Objective and Method of Capacity Assessment Summary of Capacity Assessment Results and the Project Activities based on CA Improved and Enhanced Capacity through the Project Activities Process of Document Legalization CHAPTER 3 INPUT TO THE PROJECT Inputs of the Vietnamese Side Counterpart Personnel (CP) Operational Expenses Borne by the Vietnamese Side Provision of Facilities Inputs of the Japanese Side

8 3.2.1 Dispatch of Experts Equipment Procured Operational Expenses Borne by the Japanese Side CHAPTER 4 PROJECT MANAGEMENT ACTIVITIES JCC Meeting Overall Workshop TWG Meeting Other Activities for the Project Management and Operation Meeting with Hanoi DONRE Meeting with Ho Chi Minh DONRE Others Subcontract Works Conducted under the Project CHAPTER 5 LESSONS LEARNED AND RECOMMENDATIONS Lessons Learned Recommendations List of Attachments Attachment 1: Record of Discussions on the Project on March 26, 2013 Attachment 2: Minutes of Meeting for the Project on March 9, 2012 Attachment 3: Minutes of the First Joint Coordination Committee Meeting on November 28, 2013 Attachment 4: Decision No. 2524/QD-BTNMT on 12 December 2013 Approving Project Document Attachment 5: Minutes of the Second Joint Coordination Committee Meeting on September 25, 2014 Attachment 6: Minutes of the Final Joint Coordination Committee Meeting on March 13, 2015 Attachment 7*: Technical Working Group Meeting Materials Attachment 8: Terms of References for Subcontract Surveys Attachment 9*: Materials Offered from JET for Technical Instruction and Consultation Attachment 10*: Materials Offered from JET for Mini-WS in Ho Chi Minh City, and Hanoi City Attachment 11*: Materials Offered from JET for 1 st Overall WS on November 11, 2014 Attachment 12*: Materials Offered from JET for Final Overall WS in March 2015 Attachment 13*: Comparison Table between LEP 2005 and Revised LEP 2014 Attachment 14: Thematic Brief for Technical Improvement of Existing Legal Documents Attachment 15: Thematic Brief on Registration System Attachment 16: Thematic Brief for Point Pollution Source Control Attachment 17: Technical Cooperation Product of Emission Inventory Development Attachment 18: Roadmap to Development Air Quality Management Schemes of Hanoi City Attachment 19: Roadmap to Development Air Quality Management Schemes of Ho Chi Minh City Attachment 20: Organizational Chart of MOT, MOIT, MOC, MOST, MOH *Note: Attachments 7 and from 9 to 13 are available only in electronic version and are enclosed in the CD.

9 List of Figures Page Figure Overview of the Whole Process Proposed for AQM and Positioning the Output 2 of the Project Figure Operational Structure of the Project Figure Overall Implementation Flow Figure Organizational Chart of MONRE Figure Organizational Chart of VEA and Divisions under PCD Figure Organizational Chart of Hanoi DONRE Figure Organizational Chart of Hanoi EPA Figure Organizational Chart of HCMC DONRE Figure Organizational Chart of HEPA Figure [Re-depicted] Overview of the Whole Process Proposed for AQM and Positioning Output 2 of the Project Figure Example of Proposed Questionnaire (for Cement Factory) Figure Procedure for Developing the LEP Amendment (1/2) Figure Procedure for Developing the LEP Amendment (2/2) Figure Procedure and Actual Schedule for Developing the Draft Decree on Waste and Scrap Management List of Tables Page Table Project Purpose, Outputs, and Activities Defined in RD Table Agencies Related to the Project Implementation Table Air Quality Related Projects by JICA and Other Donors Table Actual Schedule of the Project Table Comparison Table of Air Quality Related Parts of LEP 2005 and Revised LEP (LEP 2014) Table Summary of Functions, Mandates, and Current Actions on AQM of the Concerned Ministries Table Summary of Functions and Mandates of CEM and PCD Related to AQM Table Overlapping Tasks Among Targeted Organizations Table Long List of Potential TB Titles under the Project Table Results of the Series of Technical Instruction and Consultation for Preparedness of TB Formulation under Output Table Key Findings from the Series of Technical Instruction and Consultation Table Final TB Topics Prepared Table Mandates and Cooperation Mechanism Related to Air Quality Management (AQM) among the Units under Hanoi DONRE Table Organizational Information on Hanoi EPA Table Total Expenditures for Environmental Protection of Hanoi EPA Table Facilities Related to Air Quality Management (AQM) at Each Department of the Hanoi PC Table Summary of Cooperation with Central Ministries and with other Departments under the Hanoi City PC on Air Quality Management (AQM) Table Summary of Cement Industry and Chemical Fertilizer Companies in Hanoi City Table Summary of Cement Factories, Steel Industry, and Chemical Fertilizer Companies within 30 km Outside the Administrative Boundaries of Hanoi Table Summary of Issues and Difficulties in Air Quality Management (AQM) of Department under the Hanoi City PC

10 Table Mandates and Cooperation Mechanism Related to Air Quality Management (AQM) among the Units under HCMC DONRE Table Organizational Information of HEPA Table Budget of HEPA for AQM in the Last Five Years Table Facilities Related to Air Quality Management (AQM) at Each Department of the HCMC PC Table Summary of Cooperation with Central Ministries, with Other Departments under HCMC PC on Air Quality Management (AQM) Table Power Plants in HCMC and the Area Within 30 km from the Boundary of HCMC Table Chemical Fertilizer Industry in HCMC and the Area Within 30 km from the Boundary of HCMC Table Cement Industry in HCMC and the Area Within 30 km from the Boundary of HCMC Table Steel Industry in HCMC and the Area Within 30 km from the Boundary of HCMC Table Summary of Issues and Difficulties in Air Quality Management (AQM) of Departments under the HCMC PC Table Results of the Mini-Workshops Table Roadmap for Development of AQMPs for Hanoi City and HCMC Table Supporting Activities for Inventory Provided by JET Table Number of Target Factories for Each Selected Subsector Table Number of Responding Target Factories Table Summary of Results from Questionnaire Survey for Cement Factories Table Estimated Emission Amount from Cement Factories Table Summary of Meeting with HUTDP Table Summary of Meeting with the Project for Clean Air for Small Cities in the ASEAN Region Table Outline of Capacity Assessment Table Organizational Information on KKPL/PCD Table Questions and Results of Capacity Assessment Table Direction of the Project Activities based on CA Table Summary of Simplified CA Results on Hanoi EPA and Subordinate Divisions Table Summary of Simplified CA Results on HEPA and Subordinate Divisions Table List of JCC Members Table List of Core TWG Members Table Operational Expenses Borne by the Vietnamese Side Table Inputs of the JICA Expert Team Table Assignment Schedule of the JICA Expert Team (JET) Table List of Equipment Procured by JET Table Operational Expenses Borne by the Japanese Side Table Discussion Results of the JCC Meetings Table Overall Workshops Table List of TWG Meetings Table List of Meetings with Hanoi DONRE Table List of Meetings with Ho Chi Minh DONRE Table Subcontract Works under the Project

11 Abbreviations ADB APC AQM ASEAN CA CD CEM CEMS CENMA CP DOH DOIT DONRE DOPS DOST DOT DPCR DPI GOV GO GIZ HCMC HEPA HUTDP ICR ISO JCC JET JV KKPL LEP MP MM MOH MOIT MOJ MONRE MOPS MOST Asian Development Bank Air Pollution Control Air Quality Management Association of Southeast Asian Nations Capacity Assessment Capacity Development Center of Environmental Monitoring Continuous Emission Measuring System Center for Environmental and Natural Resources Monitoring and Analysis Counterpart Department of Health Department of Industry and Trade Department of Natural Resource and Environment Department of Public Safety Department of Science and Technology Department of Transportation Draft Department of Planning and Investment Government of Vietnam Government Office German Agency for Technical Cooperation Ho Chi Minh City Ho chi Minh City Environmental Protection Agency Hanoi Urban Transport Development Project Inception Report International Organization for Standardization Joint Coordinating Committee JICA Expert Team Joint Venture Division of Pollution Control for Air and Recycling Materials (Vietnamese: Phòng Kiểm soát ô nhiễm không khí và nhập khẩu phế liệu) Law of Environmental Protection Master Plan Minutes of Meeting Ministry of Health Ministry of Industry and Trade Ministry of Justice Ministry of Natural Resource and Environment Ministry of Public Safety Ministry of Science and Technology

12 MOT MPI NA OJT PC PCD PCR PMU the Project PRR QCVN R/D SATREPS TB TCVN TSP TWG US EPA VAST/ IET VDPF VEA Ministry of Transport Ministry of Planning and Investment National Assembly On-the-Job Training People's Committee Pollution Control Department Project Management Unit the Project for Institutional Development of Air Quality Management in Vietnam Progress Report Vietnamese National Technical Regulation (Vietnamese: Quy chuẩn Việt Nam) Record of Discussions Science and Technology Research Partnership for Sustainable Development Thematic Brief Vietnamese National Standard (Vietnamese: Tiêu chuẩn Việt Nam) Total Suspended Particulate Technical Working Group United States Environmental Protection Agency Vietnamese Academy of Science Technology/ Institute of Environmental Technology Vietnam Development Partnership Vietnam Environmental Administration

13 CHAPTER 1 GENERAL 1.1 Background and Objectives Environmental pollution is getting evident in Vietnam due to rapid industrialization in the recent decade. Air pollution is becoming an issue in urban areas, especially in mega cities like Hanoi City and Ho Chi Min City (HCMC). There is a concern that air pollution can trigger a variety of health problems on people, unless effective countermeasures are put in place. According to the investigation conducted by the Department of Natural Resources and Environment (DONRE) of HCMC, the concentration of Total Suspended Particulates (TSP) monitored in February 2009 in the seventh district showed 2.5 times more than the national environment standard of Vietnam, and in the twelfth district it showed 4.8 times more than the standard. Regarding exposure to benzene, the concentration in the twelfth district in 2010 showed 2.5 times more than the standard. The air quality monitored in Hanoi City also showed a similar tendency, e.g., i) for the annual average of PM10 concentration, it is three times more and ii) for benzene concentration, it is 2.5 times more than the standard. It is recognized that the concentration of these pollutants would be much higher during rush hours along the trunk roads in mega cities. Thus, effective countermeasures are urgently needed to reduce the impacts of air pollution. The Law on Environmental Protection (LEP) in 2005 (before revision) insufficiently prescribes the terms of air pollution control and air quality management, which would lead to a worsening air pollution. While the Ministry of Natural Resources and Environment (MONRE), which is an agency primarily responsible for environmental management and improvement in Vietnam, was established and reorganized recently compared with the other ministries. Such situation puts these issues e.g., insufficient experiences and knowledge for administrative management of air quality or pollution and necessity of continuous monitoring and data accumulation of ambient air quality, to be tackled by MONRE. In order to discuss these issues, the Government of Vietnam (GOV) requested a technical cooperation project to the Government of Japan (GOJ), including the introduction and application of administrative experiences of Japan in coping with the air pollution from the 1960s, which will contribute to the realization of practical execution of air pollution control and air quality management in Vietnam. Upon this request, a preparatory study was conducted in March 2013, and the Record of Discussions (RD) shown in the attachment was agreed and signed between the Vietnam Environment Administration (VEA) of MONRE and Japan International Cooperation Agency (JICA) to figure out the project design of the technical cooperation for institutional development of VEA/MONRE in terms of air quality management and air pollution control. The amendment of LEP had been under deliberation in the National Assembly of Vietnam during The amendment was approved on June 23, 2014, and the revised LEP was effectuated from the beginning of The Project for Institutional Development of Air Quality Management in Vietnam (hereinafter referred to as the Project) was commenced in September 2013 under such deliberation process of the LEP amendment, with due considerations given to the planning and execution of Project activities to pursue the prospects of LEP revision. 1.2 Project Design Agreed in the Record of Discussions on March 26, 2013 The Project design is summarized below, and the RD on March 26, 2013 and Minutes of Meeting (MM) on March 9, 2012 are compiled in the attachment. Table Project Purpose, Outputs, and Activities Defined in RD Item Project Purpose Output Description To enhance the institutional capacity of air quality management in Vietnam. 1. Laws and regulations related to air quality management are structured for effective enforcement. 1-1

14 2. A roadmap is proposed to make (a) plan(s) to meet item 1a, article 122 of LEP, Provincial-level People s Committee shall be responsible for performing state management of environmental protection in localities according to the following provisions: a/ To promulgate according to their competence environmental protection regulations, mechanisms, policies, programs and plans; Activities 1. Supporting LEP revision by adding a chapter for the air quality management. 2. Specifying areas for possible decrees/ decisions/ circulars on air quality management and making the road map for effective enforcement. 3. Raising awareness and developing capacity for actions of air quality management including information sharing workshops among a wide range of stakeholders. 4. Identifying possible areas of JICA s support and supporting necessary preparation including consultation with relevant stakeholders such as the Provincial Government to make (a) plan(s) to meet item 1a, article 122 of LEP. Remarks: The LEP mentioned above indicates the one before revision in June Source: Record of Discussions on the Project for Institutional Development of Air Quality Management in Vietnam, agreed between MONRE and JICA on March 26, 2013 The main counterpart (CP) of the Project is the Pollution Control Department (PCD) of VEA/ MONRE. Meanwhile, various stakeholders in relevant administrative agencies are involved in the course of Output 1 and Output 2 activities. The agencies involved as main actors of the Project are summarized below indicating the roles and contributions to the Project. Table Agencies Related to the Project Implementation Central Agencies PCD/MONRE VEA/MONRE MOT, MOIT, MOPS, MOH, MOST Hanoi City, HCMC DONRE People s Committee DOT, DOIT, DOPS, DOH, DOST, DPI Others University, Research Institute, VAST/ IET, etc. Source: JICA Expert Team PCD is the department in VEA primarily responsible for developing the national policy, strategy, or legislation on environmental pollution. PCD is the main CP of the Project, and the Division of Pollution Control for Air and Recycling Materials (Phòng Kiểm soát ô nhiễm không khí và nhập khẩu phế liệu: KKPL division) in PCD is the focal point for technical transfer and institutional capacity development through the Project. VEA is the superior administration of PCD, and supervises the Project implementation. VEA also takes a role to coordinate the Project implementation with the related central ministries/administrations as well as the people s committees of Hanoi City/HCMC. These ministries have mandates related to air pollution control and air quality management within their jurisdictions. PCD needs the cooperation and coordination of these ministries in the consultation and information sharing especially in the course of Thematic Briefs (TBs) preparation under the Output 1 activities. DONREs of Hanoi City and HCMC are the departments responsible for developing the roadmaps under Output 2 of the Project, in coordination with other departments related to air quality management and air pollution control. Additionally, these DONREs are the primary contact points in Hanoi City/HCMC that promote linkage with PCD or VEA necessary for Project implementation. People s committees (PCs) of Hanoi City and HCMC have the initiative to involve the related departments under PCs jurisdiction in the course of developing the roadmap under Output 2. These departments have mandates related to air pollution control and air quality management within their jurisdictions. DONREs need the cooperation and coordination of these departments in the course of developing the roadmap under Output 2. DPI is also identified as a related department under the Project from the viewpoint of budget planning and allocation in the cities in order to conduct actions based on the roadmap. Universities, research institutes, etc., working in the field of air pollution/quality, are the cooperative agencies/organizations. Information exchange and consultations are conducted in the course of Project implementation as necessary. 1-2

15 1.3 Approach for Project Implementation Technical Approach (1) Joint Formulation of Thematic Brief with PCD on the Practical Air Quality Management Activities by Technical Assistance/Advisory and Coordination Support to Agencies While Vietnam suffers from environmental pollution which emerged along with the recent economic and industrial development, the government has revised the Law on Environmental Protection (LEP) for the second time in June Along with the amendment process, it is necessary to promulgate new or revised decrees, decisions, and circulars. PCD/MONRE, at the center of the air quality management in Vietnam, needs to prepare new decrees/circulars as well as to revise the existing ones based on sufficient and accurate understanding on the relevant technical knowledge supporting the administration. Moreover, PCD/MONRE needs to thoroughly understand the validity and legitimacy of these decrees/circulars and be able to explain such texts to other agencies, to ensure the cooperation and coordination of the Ministry of Transport (MOT) and the Ministry of Industry and Trade (MOIT), which play vital roles in air pollution control in the country. Given these backgrounds, the JICA Expert Team (JET) works with the counterpart PCD/ MONRE to achieve the technology transfer and capacity development through the following activities and supports: 1) Throughout the process of formulating the Thematic Briefs (TBs), the CP is introduced to the laws, regulations, by-laws, and environment-related standards in Japan in the field of air quality control, as well as the legal and technical background which led to their formulation. TB is a technical document which supports the CP to thoroughly understand the validity and legitimacy of the regulations related to Air Quality Management (AQM). The aim in developing these TBs is to promote a substantial understanding on environment-related decrees/circulars. The created TBs are developed into a technical archive of PCD. TBs will be the draft legal documents or explanation reports to be attached as legal documents. 2) As for the topic on TB formulation, PCD and JET have been discussing the priority areas of concerns/issues for AQM. PCD and JET thus jointly initiated the formulation process of TBs, with reference to the higher priority of decrees/circulars or technical matters. In the course of the discussion to identify the priority areas, the linkage of activities between Output 1 and Output 2 are considered. In this process, JET is facilitating the joint works for augmenting the linkages between PCD and DONREs in Hanoi City/HCMC. 3) JET acted as the facilitator for relevant information sharing and discussion (such as mini-workshops) with PCD and concerned ministries or departments during the joint formulation stage of TBs and their drafts. Through this activity, the PCD, ministries/departments, and JET are expected to have mutual understanding on the importance of: i) coordination among different agencies and ii) consistency among various decisions/decrees/circulars to be enacted by the related ministries/departments. Some of the products generated under Output 1 are expected to be integrated in the process of institutionalization in MONRE. JET provides technical and scientific supports, but the administrative procedure for legalizing the documents is the responsibility of the Vietnamese side. Therefore, the Project needs the strong commitment and ownership of the Vietnamese side. (2) Presentation of the Roadmap for Planning and Implementation of Integrated Air Quality Management Scheme towards Enforcing the Regulations and Standards in DONREs The LEP gives the authority and responsibility to DONRE in each city and province to execute the national policies, laws, and regulations regarding environmental management and protection. Nevertheless, DONREs are facing various issues in such execution including: 1) 1-3

16 organization of air quality management policies, 2) technical capacity, 3) planning and implementation of programs, 4) coordination with relevant agencies, and 5) human resource development and securing necessary budget/funding. DONREs are facing difficulties in developing air quality management programs that are consistent with the superior goals (5-year plans for socio-economic development in each city or province) and relevant programs (transportation, urban development, industry promotion, etc.). Also, it is necessary for DONREs to execute the air quality management activities in an integrated and organized approach according to the priorities of relevant policies and based on the coordination among different departments under the people s committees of city/province. Under such circumstances, the Project proposes roadmaps that will serve as a guide on how to formulate the Air Quality Management Plan in Hanoi City and HCMC with DONREs of the two cities as the main CP. An overview of the whole process proposed for AQM and positioning the product of Output 2 of the Project is shown below. Roadmap to Develop AQM Plan (Product of Output 2 of the Project) The Superior Related Plans Five years plan, Urban plan, Traffic management plan, Industrial promotion plan Vision of Air Quality Management Goals setting (Target year) (Numerical target) Consolidation and Revision of the legal system Organization Revision and Reinforcement Enhancement and Integration of Air Quality Management Technology Point Source Mobile Source Ambient Air Awareness/Budget/Human resources Long list of Measures Analysis of Effects, Practicability and Impacts Determination of the Prioritized Measures Role and Cooperation of Each Department Overall Schedule for Implementing Measures by the Target Year Detailed Implementation Plan of Prioritized Measures Implementation of the Measures Review of the Implementation Plan Achievement of the goals Clarification of mandate of related departments Collaboration framework of DONRE and each department Budget planning and allocation Human resources Management and Development etc. Monitoring and Evaluation Air Quality Management (AQM) Plan Implementation of AQM Source: JICA Expert Team Figure Overview of the Whole Process Proposed for AQM and Positioning the Output 2 of the Project (3) Capacity Development of Pollution Control Department through Joint Formulation of TB The Project focuses on the involvement of the Pollution Control Department (PCD) under VEA/MONRE as the main CP. Hence, the direct beneficiaries of the technical capacity development (CD) of the Project are the officials of PCD. To realize the CD of PCD staff, capacity assessment (CA) was conducted to the officials at the commencement of the Project. Capacity assessment was implemented by interviewing the officials with JET. Although it was revealed that various capacity issues were brought out through the CA process by the officials, it is not feasible to deal with all the issues raised. As such, the CD of the Project focuses on the capacity areas/issues which can be resolved through the joint 1-4

17 formulation and on-the-job training (OJT) of TBs (from Output 1) and roadmaps (from Output 2). The details are as follows: a) PCD receives direct transfer of technology on the technical background and knowledge in the course of joint TB formulation related to the decrees/circulars on air quality management and air pollution control in Vietnam, by applying the experiences and knowledge of Japan in these fields. The TBs will be an organizational knowledge in PCD through the establishment of a technical archive. b) PCD and other agencies enhance communication for strengthening coordination among themselves at the TB joint formulation and/or its draft stage, through mini-workshops and other medium depending on the needs. c) JET facilitates the linkages between PCD and DONREs of Hanoi City/HCMC during the roadmap creation process, in order to: i) enhance PCD to understand the actual administrative activities on air pollution control at DONREs and ii) understand the priority policies/actions and crucial constraints to be tackled at DONREs in the air quality management fields. (4) Coordination with Other JICA-related Project, JICA Advisor, and Other Donors Activities Currently, various donors are implementing assistance and projects in air quality related fields in Vietnam. Such donors have organized the Vietnam Development Partnership Forum (VDPF) to discuss various development issues in the country, including those of AQM. As JICA has been continuously dispatching policy advisors to MONRE, close cooperation and information exchange with the Project are enhanced. The Project also has collaborated with the JICA s Science and Technology Research Partnership for Sustainable Development (SATREPS) projects in Vietnam. The Project aims at establishing coordination with JICA-related technical cooperation and other projects funded by other donors, in order to realize effective technology transfer and fruitful outcomes of the Project. The possible coordination with other projects is as follows: Table Air Quality Related Projects by JICA and Other Donors Donor/ Organization Assistance/ Project Titles World Bank Hanoi Urban Transport Development Project German Agency for Technical ASEAN- Germany Technical Cooperation on Clean Air Cooperation (GIZ) Science and Technology Research Partnership for Sustainable Development (SATREPS) Government of Austria Multi-beneficial Measure for Mitigation of Climate Change in Vietnam and Indochina Countries by Development of Biomass Energy Provision of chassis dynamometers to the three national universities, soft loans to MOT for installing chassis dynamometers Vietnam Provincial Environmental Governance Foreign Affairs, Trade and Development, Government of Canada Asian Development Bank (ADB) and Clean Air Asia others ADB Ha Noi Metro Rail System Project (Line 3) Ho Chi Minh City Metro Rail System Project (Line 2) Source: JICA Expert Team Operational Approach According to the RD of the Project, the chief executing agency of the Project is the PCD of VEA/MONRE. For establishing TBs (Output 1) and roadmap (Output 2), however, VEA needs to have the cooperation of other agencies involved in air/environment quality control. The Joint Coordinating Committee (JCC) and the Project Management Unit (PMU) act primarily as the organizers for maintaining the coordination among the relevant agencies. JCC, 1-5

18 who holds high-level decision-making authority in the Project, is headed by the Deputy Director General of VEA on behalf of the Vice Minister of MONRE, as the Chairman. It consists of the heads of PCD, Department of International Cooperation from the Vietnamese side, and JET and JICA Vietnam Office from Japanese side. As for the organizational body to carry out the actual execution of TBs and roadmap formulation and to receive technological transfers and CD directly from JET, two types of technical working group (TWG) were proposed to be organized, namely, the Core TWG and Expanded TWG. Under the initiative of PMU including the Vice Director of VEA (signatory to the RD) and the General Manager of PCD, a Core TWG is organized with the head and officials of KKPL 1. Core TWG is basically holding regular meetings for continuous operation of the Project, and is directly receiving technology transfer from JET. The MOT, MOIT, the Ministry of Public Safety (MOPS), the Ministry of Science and Technology (MOST), and DONREs in Hanoi City/HCMC assigned their focal persons for air quality management as members of an Expanded TWG also involving Core TWG members. Based on the themes and technical matters in the discussion, the Expanded TWG has held mini-workshops under the initiative of PMU with the relevant agencies/officials for sharing and discussion on the proposed TBs and joint formulation of the roadmaps. The following figure shows the operational structure of the Project. Advice Hanoi People s Committee Ho Chi Minh People s Committee Report Instruction (Roadmap Development) Coordination Hanoi DONRE Advice Ho Chi Minh DONRE DOT, DOIT, DOPS, DOST, DOH, DPI, etc. Coordination Collaboration Expanding TWG Collaboration Joint Coordination Committees (JCC) Project Management Unit (PMU) VEA Vice Director Dr. Tung PCD Deputy Director Dr. Loi ISD Deputy Director Dr. Cuong KKPL Division Head Mr. Duc Report Core TWG Decision making PCD KKPL Division Mr. Hung (Vice Director, PCD) Mr. Duc (TWG Leader) Staff of KKPL Division MOT, MOIT, MOPS, MOST, MOH, MPI etc. Universities, Research Institutes, NGO etc. (Cooperating Agencies) Coordination Collaboration Coordination Advice Technology Transfer /CD Project Operation JICA Vietnam Office Instruction Report JICA Experts Team JCC Joint Coordination Committee DOH Department of Health TWG Technical Working Group DPI Department of Planning and Investment VEA Vietnam Environmental Administration MONRE Ministry of Natural Resource and Environment PCD Pollution Control Department MOT Ministry of Transportation DONRE Department of Natural Resource and Environment MOIT Ministry of Industry and Trade DOT Department of Transportation MOPS Ministry of Public Safety DOIT Department of Industry and Trade MOST Ministry of Science and Technology DOPS Department of Public Safety MOH Ministry of Health DOST Department of Science and Technology MPI Ministry of Planning and Investment Source: JICA Expert Team Figure Operational Structure of the Project 1 KKPL means Phòng Kiểm soát ô nhiễm không khí và nhập khẩu phế liệu in Vietnamese. 1-6

19 1.4 Overall Implementation Flow and Actual Schedule of the Project The overall implementation flow of the Project is shown in Figure in due consideration of the revised schedule. The actual schedule of the Project is shown in Table Year Month Preliminary Analysis of Existing Information Common Activities Output 1:Technical and Institutional Development as Preparedness for LEP Amendment Output 2:Roadmap to Develop Air Quality Management Schemes of Hanoi City and HCMC Preparation for Inception Report (ICR) Capacity Assessment (CA) Identification of the current status, progress, and issues of amending LEP Preparation for Thematic Brief (TB) as the basis of amended LEP, decision and circulars concerned Understanding the revision process among the concerned departments Subcontract Survey Study of current status of Air Quality Management schemes of Hanoi city and HCMC Formulation of Roadmap Provision of Policy Recommendations and Ensure Effectiveness Recommendations for New Decree Workshop / Preparation for Progress Report (PRR) Preparation for Thematic Brief (TB) as the basis of amended LEP, decision and circulars concerned Provision of Policy Recommendations and Ensure Effectiveness Recommendations for New Decree Understanding the revision process among the concerned departments Formulation and promotion of Roadmap Workshop / Preparation for Draft (DPCR) Finalization of (PCR) Joint Coordination Committee Workshop Mini Workshop Source: JICA Expert Team * * * * * * * * Reports ICR *PRR *DPCR *PCR : Mini-WS held as Technical Instruction and Consultation Figure Overall Implementation Flow 1-7

20 Table Actual Schedule of the Project Item Common Activities Preliminary Analysis of Existing Information Preparation for Inception Report (ICR) Preparation for Inception report (draft), and explanation and discussion Finalization of ICR and Obtaining a consensus Capacity Assessment (CA) Preparation for questionnaire Hearing survey to PCD staffs (at commencement) Hearing to PCD staffs (upon termination) Preparation for Progress Report (PRR) Preparation for Draft (DPCR) Finalization of (PCR) Joint Coordination Committee Mini-Workshop include Technical Instruction and Consultation Overall Workshop Subcontract Survey Discussion and Finalization of TOR for subcontract survey with PCD and DONRE in Hanoi city and HCMC Bid, Selection, and Contract Subcontract survey and supervising 2.Activities for Output 1: Technical and Institutional Development as Preparedness for LEP Amendment Identification of the current status, progress, and issues of amending LEP Review of actual condition and problems on the "Amendment of the LEP" Confirmation of the diversion and progress of the "Amendment of LEP" Preparation for Thematic Brief (TB) as the basis of amended LEP, decision and circulars concerned Confirmation of amendment and development of decisions, decree and circular based on amended law Developing a TB list, Discussion with PCD and other related organization Preparation, Finalization and share of the TB and the discussion Understanding the revision process among the concerned departments Surveying current activities on Air Quality Management of central ministries (Subcontract Survey) Support for coordination of amendment of LEP, decrees, decision and circular Provision of Policy Recommendations and Ensure Effectiveness Recommendations for New Decree 3.Activities for Output 2: Roadmap to Develop Air Quality Management Schemes of Hanoi City and HCMC Study of current status of Air Quality Management schemes in Hanoi city and HCMC Discussion with DONRE in Hanoi and Ho Chi Minh (Preparation for developing a roadmap) Simplified capacity assessment (Subcontract survey) Surveying current activities of air quality management in Hanoi and Ho Chi Minh (Subcontract survey) Assessment of challenges in air quality management in Hanoi city and HCMC Formulation of Roadmap Formulation of Roadmap framework Draft roadmap preparation Initialization of roadmap Promotion of roadmap Source: JICA Expert Team 1-8

21 CHAPTER 2 ACTIVITIES AND ACHIEVEMENTS OF THE PROJECT 2.1 Output 1: Technical and Institutional Development as Preparedness for the Law on Environmental Protection (LEP) Amendment Amendment of LEP The Government of Vietnam has amended its LEP, which was approved in the 7th session of the 13th National Assembly on June 23, The new Section 4 Protection of Air Environment of Chapter 6 Environmental Protection of Water, Land, and Air prescribes protection of the air environment and air pollution control. Also the new Article 102 prescribes management and control of dust and gas emissions as part of waste management (which was in Article 83 in LEP 2005). Moreover, the new LEP clarifies and enhances the control of industrial emission sources, e.g., major industrial emission sources shall be registered, measured, and inventoried. In addition, the new LEP clarifies that industrial emission sources of high flow rates shall be installed with automatic and continuous emission monitoring equipment. A comparison table between parts of LEP 2005 and the revised LEP related to air quality is shown in Table The complete comparison table with track changes is provided as Attachment 13 of this report. In the course of monitoring the progress of discussion in the National Assembly for amending the LEP, the Division of Pollution Control for Air and Recycling Materials (KKPL)/Pollution Control Department (PCD) and the JICA Expert Team (JET) analyzed the revisions in the areas concerning air pollution, and identified relevant issues for the sake of the Project activities especially for formulating of thematic briefs (TBs). These analyses were done considering the following main aspects: History and records of several draft LEP versions from the commencement of the Project. There was a big change between the 5 th draft LEP (September 2013) and the 5.2 th draft LEP (March 2014). The 5.2 th draft LEP described that each industrial emission source shall be registered as pollution source, measured, and inventoried in terms of its flow rate characteristics and specifications of emissions. In addition, industrial emission sources are required to install continuous emission monitoring systems (CEMS). Items should be described with consideration of the bylaws which will be developed for air pollution control and air quality management. These analyses contributed to prepare the TB long list and to examine the priority TBs. In addition, JET and KKPL/PCD discussed and reviewed the recommendations for air pollution contents of the draft of the new Decree on Waste and Scrap Management under LEP 2014 as described in Section In the beginning of 2014, the decree had been planned to be submitted as the final version to the Prime Minister in the middle of November The details are described in Section 2.6 Process of Documents Legalization. Table Comparison Table of Air Quality Related Parts of LEP 2005 and Revised LEP (LEP 2014) No description No description No description LEP 2005 LEP 2014 CHAPTER VI: ENVIRONMENTAL PROTECTION OF WATER, LAND, AND AIR Section 4. Protection of air environment Article 62. General provisions on air environmental protection 1. All emission sources emitting into the environment must be assessed and controlled. 2. Organizations, individuals involving in production, business, service activities emitting emission which bring adverse impacts to the environment shall have the responsibility to reduce and treat (the emission) to ensure quality of air environment. 2-1

22 LEP 2005 LEP 2014 Article 63. Ambient air quality management The state management agencies for environmental protection shall be responsible for monitoring and evaluation of ambient air quality and public disclosure of information; in case the ambient air is polluted, warning and settlement shall be executed in a timely manner. Article 64. Air pollution control 1. All emission sources must be determined in terms of flow rate, characteristics, and specifications of emission. 2. The appraisal and approval of projects and activities which emit emission shall be based on the assimilative capacity of the air environment to ensure not bringing any adverse impacts to human health and the environment. 3. Manufacturing, business, service establishments having high flow rate industrial emission sources shall have their pollution sources registered, statistically managed, inventoried and shall develop the database for flow rate, characteristics and specifications of emission. 4. Manufacturing, business, service establishments having high flow rate industrial emission sources shall install automatic and continuous emission monitoring equipment and shall be permitted for emitting by competent state management agencies. 5. The Government shall regulate this article in detail. CHAPTER VIII: WASTE MANAGEMENT CHAPTER IX: WASTE MANAGEMENT Section 5 Management and Control of Dust, Gases, Section 5 Management and Control of Dust, Gases, Noise, Vibration, Light, and Radiation Article 83. Management and control of dust and gas emissions 1. Organizations and individuals engaged in production, business and services activities emitting dust and gases shall have to control and treat dust and gas emissions up to environmental standards. 2. Use of fuels, materials, equipment, and means emitting noxious gases into the environment shall be restricted. 3. Means of transport, machinery, equipment and construction works emitting dust and gases must be equipped with gas filters and reducers, dust shields or other covers to reduce dust up to environmental standards. 4. Dust and gas emissions containing hazardous elements must be managed according to hazardous waste management regulations. Article 84. Management of greenhouse gases and ozone layer-depleting gases 1. The Ministry of Natural Resources and Environment shall be responsible for calculating greenhouse gas emissions nationwide so as to implement treaties to which the Socialist Republic of Vietnam is a contracting party. 2. Transfer, buying, and selling of greenhouse gas emission quotas between Vietnam and foreign countries shall be stipulated by the Prime Minister. 3. The State encourages production, business, and service establishments to minimize greenhouse gas emissions. 4. Production, import, and use of ozone layer-depleting compounds shall be prohibited in accordance with treaties to which the Socialist Republic of Vietnam is a contracting party. Noise, Vibration, Light, and Radiation Article 102. Management and control of dust and gas emissions 1. Organizations and individuals engaged in production, business and services activities emitting dust and gases shall control and treat dust and gas emissions meeting environmental technical regulations. 2. Means of transport, machinery, equipment, and construction works emitting dust and gases must be equipped with gas filters and reducers, dust shields or other covers to reduce dust to meet environmental technical regulations. 3. Dust and gas emissions containing hazardous elements exceeding allowable limits must be managed according to provisions of law on hazardous waste management. (Deleted and moved to the following new Chapter and new Article) CHAPTER IV: ADAPTATION TO CLIMATE CHANGE Article 41. Management of greenhouse gases 1. The contents of greenhouse gas management include: a) Developing the national greenhouse gas inventory system; b) Implementing activities to reduce greenhouse gases in accordance with the social and economic situation; c) Sustainable management of forest resources, maintaining and increasing the carbon sequestration capacity of forests and developing the ecosystem; d) Executing inspection and check the compliance of regulations on greenhouse gas inventory and reduction; e) Building and developing the carbon-credit market domestically and joining the international carbon-credit market; and f) International cooperation in greenhouse gas reduction. 2. The Ministry of Natural Resources and Environment 2-2

23 LEP 2005 LEP 2014 shall assume the prime responsibility, coordinate with related ministries, agencies to execute greenhouse gas inventory, develop the national greenhouse gas management report in accordance with international treaties to which the Socialist Republic of Vietnam is a member. Source: JICA Expert Team Results and Key Findings of Survey on Air Quality Management (AQM) Activities at the Central Level (1) Purpose of the Survey on AQM Activities at the Central Level Given the status and progress with regard to the amendment of the LEP and the field of AQM at the state level, KKPL/PCD and JET assessed whether the concerned departments or ministries are facing difficulties in the revision process, especially of the technical aspects. JET provided technical suggestions to and assisted in coordination with KKPL/PCD for this assessment. It is necessary for the Project to assess and understand the mandates, current activities regarding air quality management and air pollution control, institutional status, and future policy plans among the concerned central government ministries/departments. This also leads to understand how each ministry or department is involved in the revision process of LEP and what issues may arise after the new LEP is enacted. This analysis is required for determining collaboration and coordination between PCD and other related ministries/departments. Collection of information from the central government ministries/departments was carried out by a local consultant as the Project survey. The target ministries and departments and the terms of reference (TOR) for the survey were finalized with discussion with KKPL/PCD. The results and key findings of the survey on AQM activities at the central level are described below. (2) Results and Key Findings of the Survey 1) Summary of the Survey Several issues and difficulties in AQM activities at the national level were identified by the Project activities. For example, in terms of mandates/functions described on regulations, unclear and overlapping allocations of mandates/functions are observed among agencies. Also, there is little information sharing among agencies. Therefore, it is necessary to grasp the current level of AQM activities carried out by agencies and to identify the overlap of mandates. Among the Ministry of Natural Resources and Environment (MONRE), Ministry of Transport (MOT), Ministry of Industry and Trade (MOIT), Ministry of Science and Technology (MOST), and Ministry of Public Safety (MOPS) (environmental police), there are many overlaps related to AQM activities. Detailed results are described in the following section. Upon receiving the results of these identifications, the suggested solutions were discussed among KKPL/PCD, JET, and the local consultant. These suggested solutions were utilized for: i) discussion on the amendment of the LEP and the new Decree on Waste and Scrap Management and ii) formulation of TBs and emission inventory. 2) Functions, Mandates, and Current Actions on AQM of Concerned Ministries The functions, mandates, and current actions on AQM of the six concerned ministries are summarized in Table In addition, the organizational charts of MONRE and the Vietnam Environment Administration (VEA) are shown in Figure and Figure 2.1-2, respectively. Also, the organizational charts of other ministries are shown in Attachment

24 Table Summary of Functions, Mandates, and Current Actions on AQM of the Concerned Ministries Ministry Item Description 1) MONRE 1, 2 (VEA 3 ) Function / Mandate MONRE is the leading central body governing environmental management. Article 140 of Chapter 14 of LEP 2014 (No: 55/2014/QH13) outlines the responsibilities of MONRE with regard to state administration of environmental protection. All ministries, ministry-level agencies, and other government bodies cooperate with MONRE in carrying out environmental protection within their sectors. The government spends 1% of the state budget expenditure for environmental protection activities 4 but there is limited data on the compliance with this law and how much is used for air quality management. VEA, an agency under MONRE, carries out the functions of advising and assisting the Minister of MONRE in environmental management and legal enforcement on a national scale, and manages and implements environmental public services. The Center for Hydro-Meteorological and Environmental Station Network, under the National Hydro-Meteorological Service of MONRE, is operating nine automatic air quality monitoring stations in the whole Vietnam. According to the survey implemented by the Project, the tasks for operating air monitoring stations are demarcated between the center and the Center for Environmental Monitoring (CEM). In particular, the center is in charge of background monitoring stations, which exist in places under no-impact conditions, and CEM is in charge of impact monitoring stations, which exist in places along the road and/or near pollution sources. Key departments and agencies within VEA are as follows: a) The Department of Policy and Legislation (DPL), which assists MONRE in policy making and developing environmental regulations, strategies, and plans. b) The Department of Appraisal and Environmental Impact Assessment (DAEIA), which manages the EIA and appraisal system. c) The Center for Environmental Monitoring (CEM) 5, which implements national environmental monitoring including air quality monitoring. CEM has prepared reports on environmental quality within the framework of VEA s functions and mandates, e.g., State of Environment 2013 s topic is Air Environment, published in 2014 d) The Department of Pollution Control (PCD), which focuses on control, prevention, and reduction of environmental pollution in soil, water, and air; hazardous chemical management; prevention, response, and mitigation of environmental pollution/contamination caused by natural disasters or environmental accidents. 1 Resolution No. 02/2002/QH11 dated August 5, 2002 by the National Assembly on the establishment of the Ministry of Natural Resources and Environment, and followed by Decree No. 91/2002/NĐ-CP dated November 11, 2002 of the government, defining the functions, duties, authority, and organizational structure of the Ministry of Natural Resources and Environment. 2 Decree No. 25/2008/ND-CP dated March 4, 2008 of the government, stipulating the functions, duties, authority, and organizational structure of the Ministry of Natural Resources and Environment, and followed by Decree No. 21/2013/ND-CP dated March 4, 2013 of the government, defining the functions, tasks, powers, and organizational structure of the Ministry of Natural Resources and Environment. 3 Decree No. 21/2013/ND-CP dated March 4, 2013 of the government followed by Decision No. 25/2014/QD-TTg dated March 25, 2014 of the Prime Minister, defining the functions, duties, and authority of the Vietnam Environment Administration. 4 Decision No. 34/2005/QD-TTg dated February 22, 2005 of the Prime Minister, promulgating the government s action program for implementation of the Politburo s Resolution No. 41-NQ/TW dated November 15, 2004 on environmental protection in the period of accelerated national industrialization and modernization. 5 Decision No.188/QD-TCMT dated March 23, 2010 of the Director General of the Vietnam Environment Administration, providing functions, tasks, power, and organizational structure of the Center for Environmental Monitoring. 2-4

25 Ministry Item Description The organizational charts of MONRE and VEA are shown in Figure and Figure 2.1-2, respectively. 2) MOT Current Action Function / Mandate 6 Current Action As the leading agency for helping the government in environmental management of the environment, MONRE has carried out a lot of activities on pollution control, as follows: To strengthen the control of air pollution, noise, chemical emission, and transboundary pollution. To complete the system of standards and regulations, and to enhance management of environmental monitoring network of the national local level and ministries. To carry out research for control of air and chemical emissions, environmental accidents, industrial zones, villages and rural environment, and environmental protection in food safety management. To continue to improve the legal framework, and the system of legal documents in the field of environmental pollution control including those on ambient air protection. To work closely with the provincial departments of environmental protection in pollution control. To carry out research and to advise the leaders of the departments and ministries of assigned functions and tasks of control of environmental pollution in general and air pollution in particular between ministries and relevant agencies to ensure harmony and unity. To provide technical safety standards, and environmental protection for motor vehicles. To evaluate strategic environmental assessment and environmental impact assessment reports for investment construction projects for transport infrastructure and industrial production facilities. To coordinate with MONRE and other relevant ministries, ministerial-level agencies, government agencies, and the provincial People s Committee (PC) to direct, guide, and inspect the implementation of the LEP relating to the construction of transport infrastructure and transport operations. To provide for the issuance of the certificate of environmental standards for motor vehicles in road, rail transport, inland waterways, maritime and aviation. The Department of Environment has the following tasks and authority over environmental management sectors: a) Act as a leader in building the five-year and annual plan and environmental protection programs of the ministry. b) To develop mechanisms and policies for protecting natural resources, the environment, energy efficiency and conservation, climate change, technology transfer and capacity development for environmental protection. c) To conduct inspection and certification of environmental standards, technical regulations, and energy labels for motorized transport by road, rail, inland waterway, maritime, and civil aviation. d) To regulate the operating conditions of the inspection establishment, and environmental protection laboratory for motor vehicles. e) To implement international cooperation activities related to environmental protection of transportation as assigned by the Minister. The organizational chart of MOT is shown in Attachment 20. There are 105 car inspection stations established all over the country and the National Motor Vehicle Test Center (NETC). In the period, MOT in collaboration with the authorities at the local level organized annual monitoring and inspection of buses and passenger cars by mobile testing devices in order to test and detect vehicles that do not meet the conditions on emissions. In 2012, the Prime Minister issued a roadmap for the application of biofuel and environmentally-friendly fuel. According to this roadmap, from 12/2012 gasoline blended with E5 biofuel was produced, blended, and sold for use of road motor vehicles nationwide. 6 Decision No. 1160/QD-BGTVT dated April 5, 2013 of the Ministry of Transport, regulating functions, tasks, authority, and organizational structure to advise and assist the Minister of Transport - Department of Environment. 2-5

26 Ministry Item Description MOT is studying the development of software for alert systems that automatically update cars having their reached expiry date in order to warn the inspection unit to handle them accordingly. 3) MOIT Function / Mandate 7 Current Action 4) MOC 9 Function / Mandate 10 To perform the functions of state management of industry and trade, including the sectors of engineering, metallurgy, electricity, new energy, renewable energy, oil and gas, chemicals, industrial explosives, mining industry and mineral processing, consumer goods, food processing, commercial and domestic markets, export and import, border trade, etc. To provide guidance, supervise and carry out inspection of the implementation of the provisions of the law on industrial safety techniques and environmental protection under the state management of MOIT. To provide leadership and coordination with MONRE and other ministries that are involved in directing the development of environmental industries as stipulated by law. To provide guidance on the implementation of environmental monitoring, resources and waste statistics, building and managing environmental database system for the ministry s management. To lead and coordinate with relevant agencies to guide and organize the implementation of programs, tasks, and projects related to climate change under the ministry s management. MOIT established the Industrial Safety Techniques and Environment Agency to perform the functions of state management and law enforcement on technical safety and environmental protection in industry and trade. The organizational chart of MOIT is shown in Attachment 20. To promote the inspection and control of environmental pollution due to industries. To organize monitoring teams for environmental protection works at production facilities. The above works were carried out mainly at production facilities and state enterprises which might cause serious air pollution (2008: works were implemented in 35 establishments, 2009: 36 establishments, 2010: 40 establishments, 2011: 26 establishments, 2012: 20 establishments). 8 Industrial production establishments have indicated concerns in processing technologies for industrial emission treatment, and efficiency of dust filtration equipment in major plants, especially of foreign direct investment (FDI) funded plants, by instruction of MOIT. To implement Vietnam's commitment to the Montreal Convention Protocol implied in January To coordinate with MONRE and MOIT in the appraisal process of issuance of license and reporting of environmental impact assessment (EIA) of development projects under the administration of MOC. To direct and guide the integration of planning and environmental protection programs into construction activities. To direct and guide the implementation of establishment of strategic environmental assessment (SEA) reports and EIA reports, appraisal of reports on EIA under the authority, monitoring impacts to the environment due to construction activities, management and control of waste, noise, vibration, light, radiation, prevention, response to environmental accidents, environmental pollution, environmental rehabilitation in areas under MOC, such as infrastructure development. The Department of Science, Technology and Environment acts as the focal unit with regard to pollution problems in MOC. Their functions/mandates are related to scientific research and technological development, application of 7 Decree No. 95/2012/ND-CP dated November 12, 2012 of the Prime Minister, stipulating the functions, duties, authority, and organizational structure of the Ministry of Industry and Trade. 8 Report on the Investigation and Survey for Developing the National Action Plan on Air Pollution Control, Vietnam Environment Administration, Decree No. 62/2013/ND-CP dated June 25, 2005 of the government, stipulating functions, duties, and organizational structure of the Ministry of Construction. 10 Decree No. 107/2012/ND-CP dated December 20, 2012 of the government, stipulating the functions, duties, and organizational structure of the Ministry of Transport. 2-6

27 Ministry Item Description advanced techniques, technology transfer, standards, metrology and quality goods, industrial property, technical barriers in trade, environmental protection and information on science and technology. The main functions/mandates on environmental management are as follows: a) To provide guidance on integration of planning and environmental protection programs in the strategy, planning, program for development and to support the preparation of SEA and EIA reports. b) To monitor environmental impacts caused by the operation of the construction industry, to provide the situation EIA report of the construction industry, and to carry out management and control of waste, noise, vibration, light, radiation, preventing, response to environmental incidents, remedies for environmental pollution, and environmental restoration in areas. c) To carry out research and propose for new issuance or adjustment of technical regulations, national standards for the environment, and to submit to MOC for issuance within their authority of the technical regulations on environmental quality and waste management in the areas. The organizational chart of MOC is shown in Attachment 20. 5) MOST 11 Current Action Function / Mandate Current Action Control of emission sources from construction activities in Vietnam in recent years has made the following progress: To reduce dust caused by transportation trucks carrying earth and sand. To reduce dust generation from construction activities and from other activities such as mining and selling of construction materials. To develop a greenhouse gas mitigation action plan in the cement manufacturing industry. MOST performs the state management function with regard to science and technology, including scientific and technological activities, development of the scientific and technological potential, intellectual property, quality measurement standards, atomic energy, radiation and nuclear safety, and management of public services. Regarding pollution control works, MOST is responsible for issuance of standards, national technical regulations, procedures, and economic technical norms. The agencies under MOST have functions and duties 12 such as development and promulgation of Vietnamese National Technical Regulations (QCVN 13 ) for air pollution control, management of system for technical standards and regulations of Vietnam, evaluation and publication of national standards, and guidance on development and evaluation of national technical regulations. The Vietnam Standards and Quality Institute under the Directorate for Standards, Metrology and Quality assumes the major responsibilities regarding QCVN. The organizational charts of MOST and the Vietnam Standards and Quality Institute are both shown in Attachment 20. MOST led the drafting of the clean technology use strategy until 2020, with a vision to 2030, which was approved by the government under Decision No. 2612/QD-TTg dated December 30, Specifically, the strategy focuses on the development and application of standards and technical regulations on clean technology in energy-consuming industries which may cause serious pollution to the environment such as textile dyeing, manufacture of fertilizers and pesticides, steel production, mining and mineral processing, thermal power, paper manufacturing, cement production, and sugar production. The specific objectives of the strategy are as follows: a) By 2020, 100% of new investment projects in the fields above meet the standards and technical regulations on clean technologies, and 60-70% of the production facilities operating in the industries mentioned above complete the development and implementation of technological innovation roadmap 11 Decree No. 20/2013/ND-CP dated February 26, 2013 of the government, defining the functions, tasks, powers, and organizational structure of the Ministry of Science and Technology. 12 Decision No. 104/2009/QD-TT dated August 12, 2009 of the Prime Minister, stipulating the functions, tasks, powers, and organizational structure of the Directorate for Standards, Metrology and Quality. 13 QCVN means Quy chuẩn Việt Nam in Vietnamese. 2-7

28 Ministry Item Description towards using clean technology. b) By 2030, 100% of the production facilities in the industries adopt the 6) MOH Source: JICA Expert Team Function / Mandate Current Action standards and technical regulations on clean technology. To lead and coordinate with MONRE, MOC, and other relevant authorities in issuing regulations, standards, and national technical regulations on environmental protection in health activities. To evaluate the SEA report and EIA report for the projects subjected to the approval of the Ministry of Health (MOH). To direct and guide the implementation of i) monitoring of environmental impacts from the operation of the health sector, and ii) management and control of pollution and health environmental restoration due to medical waste generation. To collect, store, and provide environmental information related to the areas under the jurisdiction of MOH as prescribed by law, such as the National Technical Regulation on Emission of Health Care Solid Waste Incinerators (QCVN02/2013/BTNMT). To direct and guide the implementation of measures to protect human health from the impacts of climate change, pollution, and other adverse environmental factors. To provide leadership and to guide in the implementation, inspection, and supervision of legal documents, national technical regulations on the management and disposal of medical waste, and environmental protection in health activities. The organizational chart of MOH is shown in Attachment 20. No notable current actions except above mandated. Among the units under VEA/MONRE, there are two agencies whose mandates are directly related to AQM, namely, the Center for Environmental Monitoring (CEM) and the Department of Pollution Control including the Division of Pollution Control for Air and Recycling Materials (under PCD). Table summarizes their functions/mandates. Table Summary of Functions and Mandates of CEM and PCD Related to AQM Unit Center for Environmental Monitoring (CEM) 14 Department of Pollution Control (PCD) 15, including Division of Pollution Control for Air and Recycling Materials (KKPL Division) Source: JICA Expert Team Description - Assists the Director General of VEA in organizing and implementing national environmental monitoring including air quality monitoring. - Develops, manages, and maintains an environmental database and inventory which include data from automatic air monitoring stations. - Applies science and technology in environmental monitoring. - Prepares reports on environmental quality within the framework of VEA s functions and mandates, e.g., State of Environment 2013 s topic is Air Environment published in 2014 by CEM. - Acts as the focal point in implementing the national master plan of the environmental monitoring network. - Assists the Director General in implementing state management tasks on the environment in the aspect of controlling, preventing, and mitigating air pollution. - Protects the environment in the aspect of hazardous chemical management. - Handling and remedying environmental pollution including air pollution caused by natural disasters or other incidents. 14 Decision No. 188/QD-TCMT dated March 23, 2010 of the Director General of the Vietnam Environment Administration, providing functions, tasks, powers, and organizational structure of the Center for Environmental Monitoring. 15 Decision No. 948/QD-TCMT dated August 18, 2009 of the Director General of Vietnam Environment Administration, providing functions, tasks, powers, and organizational structure of the Pollution Control Department. 2-8

29 MINISTRY OF NATURAL RESOURCES AND ENVIRONMENT LEADERSHIP BOARD Department of International Cooperation Vietnam Administration of Seas and Islands Ministry Inspectorate Department of Planning Department of Science and Technology General Department of Geology and Minerals General Department of Land Administration Ministry Office Institute of Strategy and Policy on Natural Resources and Environment Department of Legislation Department of Finance Department of Emulation, Reward and Communication Department of Organization and Personnel Vietnam Environmental Administration (VEA) Department of Information Technology Department of Survey and Mapping Vietnam Department of Meteorology, Hydrology and Climate Change Natural Resources and Environment Newspaper Natural Resources and Environment Magazine The National Hydro-Meteorological Service National Center for Water Resources Planning and Investigation Department of Water Resources Management National Remote Sensing Center Source: Survey results of the Project (May 2014) Figure Organizational Chart of MONRE 2-9

30 Ministry of Natural Resources and Environment (MONRE) Vietnam Environment Administration Department of Policy and Legislation (DPL) Department of Appraisal and Environmental Impact Assessment Center for Environmental Monitoring Department of Planning and Finance Department of International Cooperation and Science and Technology Department of Personnel Organization Department of Biodiversity Conservation Department of Waste Management and Environment Promotion Institute of Environmental Management Science Center for Environment Training and Conservation Center for Environmental Information and Data Inspection Department Department of Pollution Control (PCD) Center for Environmental Consultancy and Technology Transfer Administration Office Environment Magazine Administr ation Office Division for Control of Soil and Water Pollution Division of Pollution Control for Air and Recycling Materials (KKPL) Monitorin g Division Division for Control of Chemical Emission and Environm ental Risk Regional Branch for Provinces in Southeaste rn Area of South Vietnam Regional Branch for Provinces in Southwest ern Area of South Vietnam Regional Branch for Central and West Plateau Provinces of Vietnam Source: Survey results of the Project (May 2014) Figure Organizational Chart of VEA and Divisions under PCD 2-10

31 3) Issues and Difficulties in Air Quality Management (AQM) at the National Level AQM at the national level, so far, remains with many inadequacies and inefficiencies. The issues and difficulties in AQM identified through the survey are as follows: There are numerous legal documents on AQM. However, the lack of responsible authority in some areas has led to low efficiency of coordination among the central agencies and local ones. The functions of the ministries regarding AQM as specified in LEP 2014 as well as in decrees, decisions, circulars, etc., of the government sometimes do not match the specified functions, duties, and authority of the respective ministries, which cause difficulty in the organization to efficiently perform the assigned tasks from the viewpoint of human resource allocation. MOT, which manages road traffic activities accounting for 70% of the amount of dust pollution in the air, is assigned to control emissions of road traffic vehicles 16, as well as to develop, issue, and announce national technical regulations on emissions of Euro 3, Euro 4, and Euro 5 motor vehicles 17. However, in the most recent decision 18, this task is not included in the functions of the Department of Environment. Environmental protection duties are not very visible in MOT s activities. In particular, AQM works are mentioned very little in the functions and duties of MOT. The lack of specific AQM documents such as the Clean Air Act, environmental regulations and standards (including those on ambient air) for industries, and regulations for a main focal agency for coordinating all matters related to pollution control have made it difficult for the government to carry out AQM. MOT currently focuses mostly on the inspection of weight and quality of transport vehicles in order to ensure traffic safety. MOT has not focused its investment in emissions control (including measurement equipment and activities to control exhaust emissions from traffic vehicles). MOIT manages many industries responsible for heavy toxic gas substances polluting the environment, but the functions and tasks of the ministry as well as its subordinate units clearly lack specific responsibilities regarding environmental protection, especially regarding air pollution. Most of the ministries, excluding MONRE, have not yet paid attention to the issue of air pollution control, but are rather interested in the control of solid waste and waste water, as well as production activities of their own sectors. There are many overlapping tasks related to air pollution control among the sectors. Overlapping tasks among the target organizations are summarized in Table Major findings of overlapping tasks were identified as follows: There are numerous legal documents on AQM. However, unclear and overlapping allocations of the responsibilities are observed among agencies. The assignment of responsibilities for inspection and administrative sanctioning of polluting facilities still suffers from many overlaps from the central level to the local level. Consequently, it occurs that inspectors at different levels simultaneously come to 16 Decision No. 855/QD-TTg dated June 6, 2011 of the Prime Minister, approving the project environmental pollution control in transport activities. 17 Decision No. 49/QD-TTg dated September 1, 2011 of the Prime Minister, regulating the roadmap for application of emission standards for cars and two-wheeled motorcycles produced, assembled, and imported newly. 18 Decision No. 1160/QD-BGTVT dated May 4, 2013 of the Ministry of Transport, stipulating the functions, duties, authority, and organizational structure of the organizations involved in assisting the Ministry of Transport. 2-11

32 check and sanction one enterprise that made environmental pollution violations, causing frustration to the enterprises. This situation is due to the lack of close collaboration between the inspection agencies of both central and local governments, and due to lack of information sharing between them. Over the past years, the Prime Minister has assigned MOT to steer the activities to control urban air pollution including air pollution from vehicle traffic; MOIT to control pollution at industrial parks (IPs) and industrial clusters (ICs); and MONRE to manage the quality of ambient air and greenhouse gases. With such a fragmented assignment arrangement, there is no authority responsible for processing final consolidation, causing difficulty in coordination for AQM. There is a lack of regulations on the collection and sharing of data on air pollution control among the concerned ministries and between the central and local levels. This situation obstructs coordination and linkage among the agencies, causing to waste resources due to repetitive and unfollowed-up activities. 2-12

33 No. Tasks (1) MONRE Table Overlapping Tasks Among Targeted Organizations (2) MOT 1 Ambient air pollution control X X Review, develop, and promulgate related national standards in accordance with the implementation of the roadmap to apply emission standards for traffic vehicles Develop TCVN and QCVN on air Emissions control of road motor vehicles Regulate granting of environmental standard certificates for road transport, railway transport, inland waterways, maritime, and air aviation Develop and promulgate standards and technical regulations on air pollution Monitoring and announcing air quality (3) MOIT (4) MOC (5) MOST X X X X X X X X X X X (6) MOH (7) Environ mental Police Departm ent MPS X X - (8) Environmen tal Police Regulating Documents Department DONRE LEP 2014, Chapter 4, Article 41: MONRE is assigned to control greenhouse gases (GHGs). Decision No. 328/2005/QĐ-TTg dated December 12, 2005, approving the national environmental pollution control plan until 2010: MOT is assigned to control air pollution from urban and transportation. Decision No. 249/2005/QĐ-TTG dated October 10, 2005: MOST is assigned to regulate the roadmap to apply emission standards for road traffic vehicles LEP 2014, Chapter 11, Article 118, Item 2: MONRE shall promulgate national environmental technical regulations. Stipulated by the state in the functions and duties of the ministries. Decision No. 855/QĐ-TTg dated June 6, 2011, approving the project pollution control in transport activities ; this task is assigned to MOT. LEP 2014, Chapter 4, Article 41: MONRE is assigned to control GHGs. Decree No dated May 4, 2013 on the functions and duties of MOT. Decree No. 21/2013/NĐ-CP dated March 4, 2013, regulating the functions and duties of MONRE: to guide and implement the registration, verification, granting, and claiming environmental permits and certificates. Decision No. 25/ 2014/ TT-CP dated March 25, 2014, regulating the functions, duties, authority, and organizational structure of VEA under MONRE. 2-13

34 No Tasks Manage the appraisal of strategic environmental assessment reports; the appraisal and approval of environmental impact assessment reports; registration of environmental protection commitments on a national scale in accordance with the law and develop a database of environmental impact assessment Develop specific regulations on applicable emission standards for vehicles Inspecting and sanctioning polluting facilities (1) MONRE (2) MOT (3) MOIT (4) MOC (5) MOST (6) MOH X X X X X X X X X Note: X means that the organization has the task described in the left column. Source: Survey results of the Project (May 2014) (7) Environ mental Police Departm ent MPS (8) Environmen tal Police Department DONRE X X X Regulating Documents Decision No. 25/ 2014/ TT-CP dated March 25, 2014, regulating the functions, duties, authority, and organizational structure of VEA under MONRE LEP 2014, Chapter 2, Sections 1, 2, 3, and 4: regulating ministries and ministerial level agencies and agencies under the government to organize appraisal boards or recruit consulting services for appraisal of EIA reports for projects under their decision and approval authority, except interdisciplinary and inter-provincial projects. MOST: Decision No. 249/2005/QĐ-TTG dated October 10, 2005, regulating the roadmap to apply emission standards for road traffic vehicles. MOT: Decision No. 855/QĐ-TTg dated June 6, 2011, approving the project pollution control in transport activities ; assigning this function to MOT MONRE: LEP 2014, Chapter 11, Article 118, Item 2: MONRE shall promulgate national environmental technical regulations. Decree No. 179/2013/NĐ-CP dated November 14, 2013, regulating the sanctioning of administrative violations in the domain of environmental protection: Inspection units at different levels are assigned to impose sanctioning. Decision No. 5687/2007/QĐ-X11(X13) dated September 28, 2007, regulating the functions, duties, authority, and organizational structure of the Environmental Police Department under the Police Department of central cities and provinces. 2-14

35 4) Suggested Solutions to Issues and Difficulties in Air Quality Management (AQM) The suggested solutions to issues and difficulties in AQM were discussed among PCD, JET, and the local consultant from the aspect of the system of legal documents, the divisions and personnel working on air pollution control, information sharing, and so on. The main solutions to issues and difficulties in AQM are as follows: To develop and promulgate the air environmental protection plan to establish the relations and responsibilities of the agencies involved in AQM; in particular, to understand the current status of AQM at the national level and provincial/city level, and to set the key milestones for AQM. Under the stipulation of LEP 2014, the focal points should be clearly identified for the operation of air pollution control according to a specific domain assigned to each ministry. All ministries shall be responsible for the coordination and transfer of results to MONRE. To review, supplement, or amend the national technical regulations and environmental standards related to control air pollution. There should be policies for specialized training and professional capacity building of AQM for KKPL/PCD under VEA, and to strengthen human resources to ensure a sufficient number of managers in air pollution control for each area of air pollution, traffic air pollution control, and industrial air pollution control; construction and health air pollution control; and emissions of greenhouse gases from agricultural activities, etc. To promote communication and awareness-raising for leaders, policy makers, and the community on air pollution issues through press, radio, television, and the internet. To frequently announce the state of air pollution to raise the awareness and consciousness of the community on AQM. To develop a mechanism for sharing information on the urban air environment, enhancing community participation in environmental protection activities in general and air quality protection in particular. MONRE shall publish data and comparisons of annual air quality in order for the people to know if the air quality is getting better or worse Results of Technical Cooperation Products In consideration of the amendment of the LEP and the survey results as described above, KKPL/PCD and JET discussed and formulated several TBs. To formulate the TBs, the following steps were conducted. At the mid-period and the end of the formulation, KKPL/PCD and JET organized an overall workshop to share the progress/results of TBs for related agencies. 1) Preparation of and discussion on the long list of TB titles between KKPL and JET. 2) Organizing technical instruction and consultation for preparation of the TBs based on the topics listed on the long list. 3) Discussion and confirmation on the final title of TBs and contents. 4) Joint formulation of selected TBs by KKPL and JET and sharing the results. The detailed contents and activities of each step are described below. 2-15

36 (1) Long List of TB Titles Discussed between KKPL and JET In reference to the progress of amending the LEP and approved version of LEP 2014, and while determining the necessity of revision of bylaw documents such as decisions, circulars, standards, etc., a long list of potential TB titles proposed and confirmed by KKPL/PCD and JET as the first step as shown in Table Table Long List of Potential TB Titles under the Project Duty of MONRE/ DONRE Environmental Monitoring/Environ mental Standard Inspection of Point Source/ Measurement/ Countermeasure Intended Legal Documents Circular 16/2009/ TT-BTNMT QCVN 05/2013/ BTNMT Circular 16/2009/ TT-BTNMT QCVN 05/2013/BTNMT Circular 16/2009/ TT-BTNMT QCVN 05/2013/BTNMT Decision 16/2007/QD-TTg Decision 16/2007/QD-TTg Circular 16/2009/TT-BTNMT QCVN06/2009/BTN MT Decision 16/2007/QD-TTg Circular 25/2009/TT-BTNMT QCVN19, 20, 21, 23 and 30/2009/BTNMT 2-16 Theme Quality management standard of monitoring data-1; Standard for effective data for continuous auto air quality monitoring stations - Requirement for minimum number of hourly data in order to calculate 24 hours average. - Requirement for minimum number of hourly data in order to calculate yearly average. Quality management standard of monitoring data-2; Standard for screening outliers for continuous auto air quality monitoring stations. - How to exclude troubled/abnormal data? - How to deal with data during calibration procedure? Introduction of air quality standards of particulate matter (PM) Particulate matter is the biggest issue of air pollution in Vietnam. - Among various sizes of particulate matter, PM 2.5 is the most hazardous size for human health in the classification of diameter. Standard/criteria for allocating/installing automatic air quality station. - What air quality indicators should be monitored? - What is the objective of monitoring? - Where should air quality be monitored? - How many auto air quality monitoring stations are to be distributed? - How to deal with electric power failure? - Where to install wind direction and wind speed sensor? Reference information for maintenance cost of automatic air quality monitoring station - Yearly cost of repair, spare parts replacement, and consumables. - Cost estimation by age of equipment. In order to start practical and periodic monitoring of hazardous substances in ambient air, some actions are recommended to be taken. - Prioritizing hazardous air pollutants in QCVN 06/2009/BTNMT. - Study on analysis methods referring to the International Organization for Standardization (ISO), the United States Environmental Protection Agency (USEPA) method, and the Japanese Industrial Standards (JIS) of Japan. - Study on the World Health Organization (WHO) and other countries hazardous air pollutant standards. Introduction of information sharing mechanism of air quality monitoring data among various agencies which implement air quality monitoring - CEM/VEA/MONRE, National Centre for Hydro-Meteorological Forecasting (NCHMF)/MONRE, CENMA/Hanoi DONRE, University of Civil Engineering, VAST/IET, HEPA/HCMC DONRE, University of Science and Technology HCMC, etc. Introduction of standards for oxygen concentration of flue gas in Emission Standard (QCVN 19, 20, 21, 23, and 30) - Factories/enterprises can avoid penalty and fine on inspection by dilution flue gases with air.

37 Duty of MONRE/ DONRE against Source Intended Legal Documents Amended Article 132 of LEP Circular 25/2009/TT-BTNMT QCVN 19, 20, 21, 23 and 30/2009/BTNMT Theme - A standardized oxygen concentration is introduced only by QCVN 22/2009/BTNMT. - The concept of standardized oxygen concentration is common knowledge in the European Union (EU), the United States of America (USA), and Japan. Introduction of self-monitoring system to private sectors - Promotion of self-monitoring system. - Introduction of regular reporting to DONRE/MONRE. In the technical regulations on organic substances of QCVN 20/2009/BTNMT, hundreds of organic substances are listed in the table as targets. - The number of target substances is too much for practical regulation. - Prioritizing hazardous organic air pollutants is necessary such as the first target group, second target group, and third target group. - Study on analysis methods of target pollutants referring to ISO, US EPA method, and JIS of Japan. Regarding emission standards of QCVN 22/2009/BTNMT (power plant) and QCVN 23/2009/BTNMT (cement plant), revision of area coefficient criteria is necessary. Circular 25/2009/TT-BTNMT QCVN 22, 23/2009/BTNMT Inventory (Point and Mobile Emission Sources) Circular 25/2009/TT-BTNMT TCVN 5977/2005 TCVN 6750, 7172, 7142 Decree 80/2006/NĐ-CP; 29/2011/NĐ-CP; Circular 08/2009/TT-BTNMT, etc. None None International standard methods for dust measurement: - Introduction of Isokinetic Sampling. Revision for practical and effective control of air pollution source: - Introduction of onsite calibration upon factory emission measurement. - Enforcing regular calibration of portable measuring instrument for flue gas. - Introduction of continuous emission measuring system (CEMS) for major sources (power plant, cement factory, and iron foundry). Additional provisions to strengthen the installation and operation of air pollution control systems, continuous emission monitoring, etc.: - Review and revise the specification to prepare, submit and approval of environmental impact assessment, especially validation to confirm the air pollution treatment system. - Additional provisions for automatic continuous monitoring system of industrial emissions for the specified factories (e.g., point sources of the prioritized sector with large-scale capacity, etc.). - Additional regulations on emissions troubleshooting related to air pollution incidents. Considering introduction of system of pollution protection managers and an agreement of pollution protection. Introduction of point source emission inventory: - Study and introduction of methodology for point source emissions inventory based on the Emission inventory 2-17

38 Duty of MONRE/ DONRE Fuel Quality Control for Industry Mobile Sources / Emission Regulations for Cars and Motorcycles Data Information Management and Cooperation among Related Ministries Source: JICA Expert Team None Intended Legal Documents TCVN 6776:2005, TCVN 5689:2005 Decision909/2010/Q D-TTg None Decision49/2011/QD- TTs Circular 30/2009/TT-BGTVT Decree 29/2011/NĐ-CP; Circular 26/2011/NĐ-CP, etc. None Theme development guidelines in Vietnam (March 2011, Ministry of Environment of Japan). Introduction of mobile source inventory. Additional regulations on fuel quality for industry sector and factories to control air pollution from point sources. - Assessment of current TCVN. - Preparation of the list of fuel which would cause severe air pollution. - Regulations on import, sales, registration, etc., on fuel containing chemical, e.g., sulfur. - Reporting mechanism to authorities to pursue the track (import, sales, transfer, consumption, etc.). Regulatory enhancement to control individual unit of automobiles. - Garage for automobile inspection in order to strengthen regulations on exhausted gas from each automobile. - Workshop equipment and technological standards. Share of the results from chassis dynamometer test, emission coefficient (g/km) for car/motorcycle in Vietnam. Regulation on concentration of benzene in gas exhaust from motorcycles (especially two-cycle engines). Development of regulations for database building, information sharing, reporting related to air pollution and ambient air: - Database of national industrial emissions. - Information systems for ambient air quality. - Regulations on reporting and information sharing on emissions and ambient air quality. - Regulations on the use of AQI to provide information to the community. - Regulations on the provision of ambient air quality information. Promotion of cooperation among related ministries: -Introduction of inter-ministry meetings. - Identification of duplicate/non-covered jurisdictional areas on air pollution control, and demarcation of mandates among the related ministries. (2) Technical Instruction and Consultation for Preparation of the TBs In order to proceed with prioritizing the TB topics among the long-listed themes, KKPL/PCD and JET programmed a series of technical instruction and consultation as one of the Project activities under Output 1. These series were programmed with the aim of: i) introducing Japanese experience, technology, tools, and systems for AQM or APC, ii) clarifying the substantial needs and priorities of the long-listed themes through cultivating the technical and administrative knowledge of counterparts and staff of the related departments of VEA, and iii) consulting applicability of technical instructions offered in to Vietnam s situation and problems as solutions in AQM and APC. Thus, the series of technical instruction and consultation for preparedness of TB formulation under Output 1 has been conducted among KKPL/PCD, related departments of VEA, related departments under Hanoi/HCM DONREs, and JET. The results of the series are shown in Table below. All materials offered by JET for each technical instruction and consultations are shown in Attachment 9 of this report. 2-18

39 Table Results of the Series of Technical Instruction and Consultation for Preparedness of TB Formulation under Output 1 Technical Instruction and Consultation Conducted Date and Participants Japanese Air Pollution Control System [Part 1] - Jan. 3, 2014 (Friday) - finished Japanese legal structure for air pollution control - 15 people, PCD, DPL, CEM, ISEM, and ISD [Part 2, Session 1] - Jan. 16, 2014 (Thursday) - finished Development of emissions inventory of point sources in - 14 people, PCD, DPL, CEM, ISEM, and ISD Japan [Part 2, Session 2] Development of emissions inventory of point sources focusing on methodology of estimation of emission amount Environmental Monitoring and Air Quality Standards [Part 3] Circular 16/2009/ O&M of the station/ monitoring data management and interpretation [Part 4] Decision 16/2007/ Standard and criteria for distributing automatic air quality monitoring station Emission Standard and Management of Point Sources [Part 5] QCVN for Emission Standard: Relationship between regional coefficient (Kv) and stack height of emission source [Part 6] Circular 25/2009 and new circular for emission monitoring under preparation/ flue gas measurement/ dust measurement/ standardized oxygen concentration of flue gas measurement/ promotion of standardized oxygen concentration [Part 7] Soft-component approach for point source control - Pollution control managers system - Agreement on pollution control [Part 8] Decree 80/2006 and Circular 08/ Practical and effective control and measurement at sources - Continuous emission monitoring at sources (CEMS) Supplement Seminar for CEM Circular 25/2009 and new circular for emission monitoring under preparation/ flue gas measurement, dust measurement, standardized oxygen concentration of flue gas measurement/ promotion of standardized oxygen concentration Source: JICA Expert Team - Feb. 26, 2014 (Wednesday) - finished - 19 people, PCD, DPL, CEM, ISEM, ISD, Vietnam PCB management project and Hanoi EPA - Mar. 14, 2014 (Friday) - finished - 16 people, PCD, DPL, CEM, ISEM, Hanoi DONRE, and Clean Air Asia (Research Assistant of Clean Air Sri Lanka) - Mar. 28, 2014 (Friday) - finished - 10 people, PCD, CEM - Apr. 8, 2014 (Tuesday) - finished - 22 people, PCD, DPL, ISEM, ISD in VEA - JICA Vietnam - Apr. 24, 2014 (Thursday) - finished - 18 people, PCD and office of VEA, CEM, Hanoi EPA, JICA Vietnam office, one student employee from Brandenburg University of Technology (Germany) - May 7, 2014 (Thursday) - finished - 11 people, PCD, ISD and Hanoi EPA - Apr. 15, 2014 (Tuesday) - finished - 15 people, CEM Through this series of technical instruction and consultation, the various needs of the Vietnamese side were identified. The contents and key findings of the series of technical instruction and consultation are shown in Table In consideration of these key findings, JET proposed the final TB list to be formulated under Output 1 and finalized with KKPL/PCD. Table Key Findings from the Series of Technical Instruction and Consultation Technical Instruction and Consultation Conducted Japanese Air Pollution Control System [Part 1] Japanese legal structure for air pollution control 2-19 Key Findings New understanding of collaboration/task demarcation scheme for air pollution control in Japan i) between different ministries

40 Technical Instruction and Consultation Conducted [Part 2, Session 1] Development of emissions inventory of point sources in Japan [Part 2, Session 2] Development of emissions inventory of point sources focusing methodology of estimation of emission amount. Environmental Monitoring and Air Quality Standards [Part 3] Circular 16/2009/ O&M of the station/ monitoring data management and interpretation [Part 4] Decision 16/2007/ Standards and criteria for distributing automatic air quality monitoring station Emission Standard and Management of Point Sources [Part 5] QCVN for Emission Standard: Relationship between regional coefficient (Kv) and stack height of emission source [Part 6] Circular 25/2009 and new circular for emission monitoring under preparation/ flue gas measurement/ dust measurement/ standardized oxygen concentration of flue gas measurement/ promotion of standardized oxygen concentration. [Part 7] Soft-component approach for point source control - Pollution control managers system - Agreement on pollution control [Part 8] Decree 80/2006 and Circular 08/ Practical and effective control and measurement at sources - Continuous emission monitoring at sources (CEMS) Source: JICA Expert Team Key Findings ii) between national and local authorities Intensive discussion on methodology of emission amount estimation to use emission factors. How to initiate (obligatory) cooperation of polluters? Advice/ instruction through OJT-basis emissions inventory development would be effective. To support the activities for development of emissions inventories was requested strongly by the Vietnamese side. Impacts on CPs regarding lifetime of equipment, necessity of budget for O&M and renewal. Less effectiveness of TB support, because budgetary constraints are more severe than technical constraints for distribution of stations. However, it is understood that lifetime and renewal program and budgeting plan are very important for sustainable environmental monitoring. New knowledge for CPs on max ground concentration site and stack height. However, correction of Kv concept in QCVN might trigger conflict for site selection of thermal power plants in VN. Materials offered in this part would be integrated into the new circular of VEA for isokinetic sampling of emission source. New knowledge and understanding of importance of standardized oxygen concentration in flue gas. Hindrance of substantial suspicion to polluters (factories). However, institutional aspect of the pollution control manager system seemed attractive for the Vietnamese situation. It would be difficult for VEA to administer the combustion process control. More technical discussion would be effective on CEMS in combination with pollution control agreement. (3) Final Title of TBs and Contents KKPL/PCD and JET examined the priority of TB titles to be formulated under Output 1 based on the results of the series of consultation and findings/participants opinions. Although various needs for formulating the TB among the long-listed themes were identified in the course of the above examination, PCD and JET prioritized the TB titles as shown in Table 2.1-8, with the following justifications: Although the emission standards on air pollutants are widely designated in several QCVNs, the enforcement of the standards is not satisfactorily conducted by the environmental management authorities at both central and local levels. Such situation is due to the context of incompatibility between the requirements of QCVNs and technical/administrative capability of the authorities to fulfill the requirements. Thus, the improvement of QCVNs related to air pollutants emission from the stationary sources will be necessary to realize practical enforcement by the authorities. Contents of the TB structured, presented as a technical instruction for enterprises in implementing registration of pollution sources (how to register, collect, archive, and 2-20

41 evaluate data appropriately, etc.). In Article 64: Air Pollution Control of the revised LEP 2014, it is prescribed that Manufacturing, business, service establishments having high flow rate industrial emission sources shall have their pollution sources registered, statistically managed, inventoried and shall develop the database for flow rate, characteristics and specifications of emission. In addition, provision on registration of stationary pollution sources has been added into the Draft Decree on Waste and Scrap Management. VEA is responsible for promulgating such technical regulations in the future. The revised LEP 2014 focuses point source control of air emission under cooperation between the environmental management authorities and the business owners. And the LEP implies the introduction of CEMS as one of the essential approaches for point source control. Since such approach will be the first challenge in the APC and AQM fields in Vietnam, the introduction of CEMS should be well prepared including promotion of a cooperation mechanism between the authorities and business owners. In addition, the mechanism to control point sources of factories through pollution control managers is also an effective way for APC and AQM. Table Final TB Topics Prepared Topic Explanation (a) Technical [Improvement of existing QCVN] Improvement of Application of standardized oxygen concentration in flue gas. Existing Legal Modification of emission standards. Documents QCVN 22/ 2009, 23/ 2009, 51/ 2013, 06/ And 20/ plus QCVN 19/2009, 30/2010,34/2010,02/2013 (b) Thematic Brief [Thematic brief on registration system and data management for stationary on Registration pollution sources] System Introduction of registration system Legal background of information systems for stack emission Information collection method from existing reports regulated by existing regulations on reporting of emissions (c) Thematic Brief [Thematic brief on practical control of point pollution sources] for Point Source TB for introducing CEMS to major/big polluters in the selected Control subsectors in combination with the pollution control agreement mechanism, and pollution control manager (PCM) system. Source: JICA Expert Team (4) TBs Prepared by the Project 1) Technical Improvement of Existing Legal Documents and Improvement of Existing QCVNs i) Objectives of the TB for Improvement of Existing QCVN Emission from factories is controlled by a regulation, i.e., Vietnam National Technical Regulations (QCVN), by obligating the limitation of a concentration at an outlet of stack in Vietnam. QCVN is succeeding the Vietnam National Standards (TCVN) since 2009, and the regulations are superior to the standards because the former have legal force in Vietnam. The evidence and basis to regulate the emissions concentration of flue gas from factories is QCVN. On the other hand, it is QCVN 05/2013/BTNMT and QCVN 06/2009/BTNMT that correspond to the environmental standards of developed countries, although the meaning of environmental standards is somewhat different from developed countries. This TB is prepared to provide updated technical and scientific information and recommendations for revising the existing QCVNs related to control point pollution sources, and QCVN 05/2013/BTNMT and QCVN 06/2009/BTNMT related to environmental standards. 2-21

42 ii) Summary of the TB for Improvement of Existing QCVN KKPL/PCD and JET formulated the TB with due consideration of the revised LEP 2014 and objectives described above. The TB for improvement of existing QCVN is enclosed as Attachment 14, and its table of contents is given below. Table of Contents of TB for Improvement of Existing QCVN 1. Recommendations to QCVN Related to Emission of Factories 1.1 Common Recommendations to QCVN Related to Emission of Factories Next Targets to be Achieved in More Introduction of Standardized Oxygen Concentration 1.2 Recommendations to Individual QCVN Related Emission of Factories National Technical Regulation on Industrial Emission of Inorganic Substances and Dusts (QCVN/19/2009/BTNMT) National Technical Regulation on Industrial Emission of Organic Substances (QCVN 20/2009/BTNMT) National Technical Regulation on Emission of Chemical Fertilizer Manufacturing Industry (QCVN 21/2009/BTNMT) National Technical Regulation on Emission of Thermal Power Industry (QCVN 22/2009/BTNMT) National Technical Regulation on Emission of Cement Manufacturing Industry (QCVN 23/2009/BTNMT) National Technical Regulation on Emission of Industrial Waste Incinerators (QCVN 30/2010/BTNMT) National Technical Regulation on Emission of Refining and Petrochemical Industry (QCVN 34/2010/BTNMT) National Technical Regulation on Emission of Steel Manufacturing Industry (QCVN 51/2013/BTNMT) National Technical Regulation on Emission of Health Care Solid Waste Incinerators (QCVN 02/2013/BTNMT) 2. Recommendations to Each QCVN Related to Ambient Air Quality 2.1 QCVN of Interest National Technical Regulation on Ambient Air Quality (QCVN 05/2013/BTNMT) National Technical Regulation on Maximum Allowable Concentration of Hazardous Substances (QCVN 06/2009/BTNMT) 3. Summary of Recommendations 3.1 Summary of Recommendations Attachment 1: Proposed Draft for Revision of QCVNs Attachment 2: Standardized Oxygen Concentration and Categorized Emission Standards in Japan 2) Thematic Brief on Registration System and Data Management for Stationary Pollution Sources i) Objectives of the TB on Registration System The contents of this TB structure is presented as a technical instruction for enterprises in implementing registration of pollution sources (how to register, collect, archive, and evaluate data appropriately, etc.). The new LEP clarifies, according to Chapter VI: Environmental Protection of Water, Land and Air, Section 4 Protection of Air Environment, Article 64 Air Pollution Control, that manufacturing, business, and service establishments having high flow rate industrial emission sources shall have their pollution sources registered, statistically managed, inventoried and shall develop the database of flow rate, characteristics, and 2-22

43 specifications of emission. In addition, provision on registration of stationary pollution sources has been added into the Draft Decree on Waste and Scrap Management. VEA is responsible for promulgating such technical regulations in the future. Therefore, this TB provides introducing of the registration system being used in Japan, legal background of information systems for stack emission, information collection method from existing reports regulated by existing regulations on reporting of emissions. ii) Summary of the TB on Registration System KKPL/PCD and JET formulated the TB with due consideration of the revised LEP 2014 and objectives described above. The TB on registration system is enclosed as Attachment 15, and its table of contents is given below. Table of Contents of TB on Registration System 1. Introduction of Registration System in Japan 1.1 Law Related Registration of Air Pollutants Emitting Facility in Japan 1.2 Registration System Related to AQM in Japan 2. Existing and Expected Reporting System for Air Pollutants Emitting Facility in Vietnam 2.1 Existing Available Information of EIA Process in Vietnam 2.2 Information from Planed Circular 3. Recommended Contents for Registration Related AQM 4. Data Management of Registration System 4.1 Arrangement of Registration Data 4.2 Utilization of Reference Number for Data Management 5. Recommendation 3) Thematic Brief on Practical Control of Point Pollution Sources i) Objectives of the TB on Practical Control of Point Pollution Sources This TB is prepared to provide the technical and general information for practical control of point pollution sources. This TB is divided into three parts, one is for CEMS, one is for pollution control agreement (PCA), and the other is for pollution control manager (PCM) system from the aspects of technical control to use the facilities and institutional control by system of point pollution sources. The new LEP clarifies, according to Chapter VI: Environmental Protection of Water, Land and Air, Section 4 Protection of Air Environment, Article 64 Air Pollution Control, that industrial emission sources which are at high flow rate shall install CEMS. The PCA in Japan which makes effectively the function of CEMS is introduced in Part B of this TB. In addition, Article 68 Environmental Protection of Production, Business and Service Establishment of Chapter VII Environmental Protection in Manufacturing, Business and Service Activities of the new LEP described that big polluters having potentially serious impacts to the environment shall have i) professional units or employees in charge of environmental protection and ii) their environmental management system. The concept of the PCM system in Japan contributes to such kind of idea for industrial pollution control. - CEMS: Continuous emission monitoring system (CEMS) plays an important role in the field of air pollution control. More specifically, CEMS provides real-time information of concentration of pollutants being emitted from large point sources and is used as a tool to check whether concentration of stack gas meets the emission standard. It can also be used to help facilities for the operation of air pollutant treatment system such 2-23

44 ii) as flue gas desulfurization (FGD) system, denitrification (De-NOx) system, and dust collecting system. - PCA: Pollution control agreement (PCA) is concluded between environmental authorities of local governments and enterprises. These agreements were designed to take measures against local environmental problems, and initiated and developed by local governments. Signing enterprises agree to special standards related to their performance, their technology including CEMS, and their management which have been developed by local environmental authorities. PCA is a useful tool for communications between enterprises and local government - PCM: Pollution control manager (PCM) system is aimed to promote the development of pollution control system for enterprises with the obligation of establishing a pollution control organization. The pollution control manager of this pollution control system is required to have national qualifications. Summary of the TB on Practical Control of Point Pollution Sources KKPL/PCD and JET formulated the TB with due consideration of the revised LEP 2014 and objectives described above. The TB on Practical Control of Point Pollution Sources is enclosed as Attachment 16, and its table of contents is given below. Table of Contents of TB on Practical Control of Point Pollution Sources Part A: Continues Emission Monitoring System (CEMS) to Major/Big Polluters in the Selected Subsectors A-1 Necessity and Importance of Installing CEMS A-1.1 CEMS Related Regulation in Japan A-1.2 Application of CEMS in Japan A-1.3 CEMS Related Regulations in Vietnam A-2 General Technical Specifications of CEMS A-2.1 Composition of the CEMS of Gaseous Pollutants A-2.2 Composition of the CEMS of Dust A-2.3 Type of Continuous Emission Monitoring Analyzers A-2.4 Data Acquisition System and Data Logger A-3 Application Examples of CEMS in Vietnam A-3.1 Cement Factory A-3.2 Thermal Power Plant A-3.3 Steel Industry A-4 Installation, Operation and Maintenance of CEMS A-4.1 Selection of the Stack Gas Analyzer A-4.2 Securement of Working Location and Condition A-4.3 Initial Cost of CEMS A-4.4 Operation of CEMS A-4.5 Maintenance for CEMS Part B: Introducing of Pollution Control Agreement in Japan and Recommendations to Vietnam B-1 Introduction on PCA in Japan B-1.1 Background B-1.2 Parties Involved in PCA B-1.3 Scope of PCA B-1.4 Features of PCAs in Japan B-1.5 Advantages and Disadvantages of PCA B-2 Lessons from the Story of PCA in Japan: Conditions to Implement PCA B-2.1 Needs of PCA B-2.2 Preparation of PCA B-2.3 Implementation of PCA B-3 Current Situation of Vietnam for Issues Concerned 2-24

45 B-3.1 B-3.2 Current Situation of Vietnam for Issues Concerned Suggestive Strategy for Applying the Concept of PCA System into Vietnam Part C: Pollution Control Manager System in Japan and Reference for the Case of Vietnam C-1 Background of the Pollution Control Manager System Applied in Japan C-1.1 Japan s Experience with Environmental Pollution C-1.2 Pollution Session of the Diet November, Diet No.64 (1970) C-2 Limitation of Regulatory Approach and Establishment of Act on Improvement of Pollution Prevention Systems in Specified Factories in Japan C-2.1 Necessary Elements and Investments for Pollution Control C-2.2 Limitations of Regulatory Approach and Breakthrough to Pollution Control C-2.3 Establishment of Act on Improvement of Pollution Prevention Systems in Specified Factories C-3 PCM System and Authorization for Effectuation of PCM System in Japan C-3.1 Concept of PCM System for Specified Facilities C-3.2 Authorization Mechanism for Effectuation of PCM System C-3.3 Work Tasks of Pollution Control Organization C-3.4 Effect of PCM System C-4 Regulations Related to PCM System in Vietnam C-4.1 Previous LEP and Other Current Regulations C-4.2 New LEP 2014 C-5 Basic Items Proposed in the Formulation of Vietnam PCM System C-5.1 Legal Items to be Studied C-5.2 Determination of Target Companies/Factories C-5.3 Role and Work Tasks of Pollution Control Organizations C-5.4 Qualification (Examination/ Training/ Standard Materials) C-5.5 Management Structure for System Formulation 2-25

46 2.2 Output 2: Roadmap to Develop the Air Quality Management Plans of Hanoi City and Ho Chi Minh City (HCMC) Results and Key Findings of Survey on AQM Activities in Hanoi City and HCMC (1) Study of Current Status of Air Quality Management (AQM) in Hanoi City and HCMC 1) Discussion with the DONREs of Hanoi City and HCMC KKPL/PCD and JET held a series of meetings with the DONREs of Hanoi City and HCMC to discuss the current issues on AQM and formulating the roadmap for AQM activities. The roadmap should be tailored to fit with the actual conditions of Hanoi City and HCMC. For preparation of an effective roadmap for AQM, it is necessary to obtain data and information from the Department of Transport (DOT), which is in charge of controlling mobile pollution sources (such as control of gas emission), the Department of Industry and Trade (DOIT), which is in charge of controlling point sources of industrial sectors, and other relevant agencies. For the roadmap formulation, it is essential to have cooperation, coordination, and role sharing between DONREs and other related departments such as DOT and DOIT. This is to say that the process of formulating the roadmap is expected for DONREs to gain cooperation from the other departments. 2) Survey of Current Activities for Air Quality Management (AQM) in Hanoi City and HCMC The current activities on AQM in Hanoi City and HCMC were surveyed by the Project. In formulating an effective roadmap for developing AQM schemes, the surveys did not only cover DONRE but also DOT, DOIT, and other organizations involved in air pollution control. The outlines of the surveys are described in Chapter 4, and the TOR of each survey are shown in Attachment 8. (2) Results and Key Findings of Survey on AQM Activities in Hanoi City 1) Organizational Overview of Hanoi DONRE Related to Air Quality Management (AQM) The organizational chart of Hanoi DONRE is shown in Figure The mandates, organizational structure, and staffing of Hanoi DONRE are specified in Decision No. 36/2010/QD-UBND of the Hanoi City People s Committee (PC), dated August 16, Accordingly, Hanoi DONRE is a specialized agency of the Hanoi City PC, and at the same time, under the direction of MONRE. The functions and mandates of Hanoi DONRE are to advise and assist the municipal PCs in performing state management in the field of natural resources and the environment, including land resources, water resources, mineral resources, geology, environment, hydrometeorology, geodesy and cartography; implementation of public services in areas under the jurisdiction of the department. The units under Hanoi DONRE with tasks directly related to AQM include the Hanoi Environmental Protection Agency (EPA), Inspection Division, Department of Water Resources and Hydrometeorology, and Environmental Monitoring Center, as shown in Table EPA has the fundamental roles for air pollution control. Basic organizational information on Hanoi EPA prepared by the local consultant is summarized in Table 2.2-2, and its organizational chart is shown in Figure

47 Leadership of DONRE: 1 Director and 5 Deputy Directors Divisions/Sections of DONRE - Office - General Planning Division - Land Statistics and Registration Office - Division of Water Resources and Hydrometeorology - Division of Surveying and Mapping - Division of Mineral Resources - Inspection Division - Division of Land Management - Legislation Division Units under DONRE - Hanoi Environmental Protection Agency (EPA) - Hanoi Environmental Protection Fund (EPF) - Land Registration Office in Hanoi - Hanoi Land Service and Land Development Center - Hanoi Center for Environmental and Natural Resources Monitoring and Analysis (CENMA) - Ha Noi Center for Resource and Environment Engineering - Center for Information Technology Resources and Environment in Hanoi - Project Management Unit VLAP - Management Board of the Construction Project Note: The words in bold in the boxes above are the divisions/units having activities related to AQM. Source: Survey results of the Project (August 2014) based on the Website of Hanoi DONRE Figure Organizational Chart of Hanoi DONRE Table Mandates and Cooperation Mechanism Related to Air Quality Management (AQM) among the Units under Hanoi DONRE Hanoi Environmental Protection Agency (EPA) Inspection Division 21 Mandates 19 (See Table also): - To assist the Director of Hanoi DONRE and the Hanoi City People s Committee in implementing state management tasks in the field of environmental protection in the city area. - To chair or participate in domestic and international cooperation projects in the area of environmental protection upon the assignment of the Director of DONRE. Cooperation mechanism with related parties: 20 - Hanoi EPA works under the leadership and direction of the Director of DONRE and professional instruction, checking in terms of environmental protection of the Vietnam Environment Administration, MONRE - The EPA is the focal point/coordinates with related agencies in solving environmental problems at inter-sector and inter-provincial levels including air pollution problems - The EPA works with citizens, communities to spread, promote laws on environmental protection as assigned by the Director of DONRE Mandates: - Assisting the Director of Hanoi DONRE in implementing administrative and specialized 19 Decision No. 816/QD-UBND, dated September 18, 2008, of the Hanoi City People s Committee, providing the establishment of the Hanoi Environmental Protection Agency, Hanoi DONRE. 20 Decision No.123/QD-STNMT, dated November 6, 2008, of the Director of the Hanoi Department of Natural Resources and Environment, providing the Code of Conduct for the Hanoi Environmental Protection Agency, Hanoi DONRE. 21 Decision No. 358/QD-STNMT, dated August 21, 2009, of the Director of the Hanoi Department of Natural Resources and 2-27

48 Hanoi Environmental Protection Fund (EPF) Hanoi Center for Environmental and Natural Resources Monitoring and Analysis (CENMA) 22 Source: JICA Expert Team inspection tasks in environmental areas Cooperation mechanism with related parties: - The Inspection Division works closely with related agencies and officials under Hanoi DONRE to check and ensure compliance to policies, laws, and instructions in the area of natural resources and environment. - The Inspection Division collaborates with Hanoi DONRE in organizing meetings with related parties, and communicates with citizens, organizations, and communities to receive and settle complaints and denunciations, and to spread and promote legal knowledge as assigned. Mandates: - Receives funding from the state budget and other financial sources to provide financial assistance, loans for projects, programs, prevention activities, and remedying environmental pollution, degradation, and incidents in the city areas. - Mobilizes, attracts, and implements fund-raising activities for projects, activities, and tasks relating to environmental protection in the city area. Cooperation mechanism with related parties: - The EPF works and coordinates closely with domestic and foreign financial organizations in mobilizing and allocating funding for environmental protection, pollution control activities, etc. - The EPF provides loans for individuals, organizations, enterprises carrying projects/programs that suit the requirements and functions of the EPF. Mandates: - Assists the Director of Hanoi DONRE in analyzing, and organizing the development of natural resources and environmental monitoring network including air quality monitoring network. - Organizes the development and implementation of activities and programs in the field of natural resources and environment monitoring. Cooperation mechanism with related parties: - CENMA cooperates closely with state management agencies, other divisions, units under Hanoi DONRE, and related organizations and individuals while implementing its mandates/tasks. - CENMA pays special attention to developing volunteer networks and cooperation with domestic and international organizations in scientific and technological areas. - CENMA cooperates with foreign donors in implementing investment and assistance programs related to environmental and natural resources monitoring and analysis, under the direction of the Hanoi City PC and the Director of DONRE. Table Organizational Information on Hanoi EPA Item Organizational Information on Hanoi EPA Mandate (See also Table 1) Performs the functions of state management of environmental protection, 2.2-1) environmental inspection, and supervision for Hanoi City 2) Pollution control 3) EIA evaluation 4) Project management and communication Staff Budget See Table Organizational Structure See Figure Source: Survey results of the Project (August 2014) Total 54 personnel (50 staff and 4 leadership cadres): - General Division: 15 personnel - Division for Evaluation and EIA: 9 personnel - Pollution Control Division: 16 personnel - Project Management and Communication Division: 10 personnel Environment, providing the mandates, tasks, and personnel of the Inspection Division. 22 Decision No.125/QD-STNMT, dated November 6, 2008, of the Director of the Hanoi Department of Natural Resources and Environment, providing mandates, power, organizational structure, personnel, and working relationship of the Hanoi Center for Environmental and Natural Resources, Hanoi DONRE. 2-28

49 People s Committee of Hanoi City Hanoi Department of Natural Resources and Environment (Hanoi DONRE) Hanoi Environmental Protection Agency (Hanoi EPA) 1 Director and 3 Deputy Directors General Division Division for Evaluation and EIA Pollution Control Division Project Management and Communication Division Source: Survey results of the Project (August 2014) Figure Organizational Chart of Hanoi EPA According to the National State of Environment Report 2012, the budget for environmental protection allocated to EPA has been increasing year by year in accordance with the proposed cost estimates in order to provide favorable conditions to units and divisions to complete their assigned tasks and other environmental protection activities in the localities. However, with the role of a consulting agency to support DONRE under the Hanoi City PC in state management for environmental protection of the city, this budget allocated for environmental protection activities still accounts for a very low percentage (only 2.56%), as shown in Table Table Total Expenditures for Environmental Protection of Hanoi EPA Total Expenditures for Environmental Protection of Hanoi EPA (real cost) Year Percentage (%) of total expenses in the Total Cost (VND in millions) total state budget allocated for Hanoi in 1 year , % , % , % Total 47, % Source: Survey results of the Project (August 2014), Compiled by Hanoi EPA period, SOE2012 2) Policy, Plan, and Program Related to Air Quality Management in Hanoi City The policies, plans, and programs in Hanoi City related to environmental management including air quality and pollution control are summarized as follows: i. Plan No. 75/2012/ KH-UBND, Plan on Management of Industrial Environment Pollution in Hanoi City up to 2015 and drafting up to 2020: To promote advocacy, 2-29

50 awareness and responsibility for the management of industrial pollution. In addition, Hanoi City has a plan to develop environmental pollution control manager systems. ii. Decision No. 8044/QD-UBND, dated December 31, 2013, Project on Key Tasks for Hanoi Environmental Protection Activities: It is very essential to implement this decision, in order to: i) integrate and synchronize all environmental protection solutions and measures in the approved planning and ii) prevent early on the hot environmental pollution issues. The tasks for air pollution due to dust pollution as caused by construction and traffic activities are described in this decision. To solve air pollution problems in Hanoi City, this decision describes to equip the air quality monitoring network of the city in accordance with Decision No. 355/QĐ-UBND, dated January 13, 2012, of the Hanoi City PC, approving the planning of fixed air observation network in the area of Hanoi up to iii. Decision No. 1081/QD-TTg, dated July 6, 2011, of the Prime Minister approving the master plan on socio-economic development of Hanoi City through 2020, with orientation toward 2030: - The average annual economic growth rate will be 12-13% in , 11-12% in , and % in To promote, develop, and combine sustainable socio-economic development with conservation of natural resources and protection of the eco-environment. To closely combine socio-economic development with promotion and consolidation of national defense, security, and assurance of political security and social order. - To build and develop Hanoi i) to be a prosperous, beautiful, civilized, modern, and typical city, and ii) to perform the functions of a major political, cultural, scientific, technological, commercial, and economic center of the whole country. - To build synchronous and modern urban infrastructure and a sustainable environment. - To develop Hanoi into a green, clean, beautiful and civilized city. To upgrade and build its technical urban infrastructure systems to be complete and modern, basically meeting socio-economic development requirements. To develop mass transit systems, striving to put into operation at least two urban railway lines in By 2020, mass transit will meet 35-45% of public travel demand. iv. Others: - The 150/KH-UBND Plan of Hanoi City PC on the implementation of the 95-KH/TU Plan, dated July 26, 2013, of the Hanoi City PC on the implementation of the Resolution of the Seventh Conference of the Central Executive Committee (XI) to actively respond to climate change, enhanced resource management, and environmental protection. - The 86/KH-UBND Plan for communication on industrial pollution management in the area of Hanoi to Decision 55/2009/QD-UBND, dated March 17, 2009, of the Hanoi City PC, promulgating the regulations to ensure an orderly, safe, and sanitary environment during construction works in Hanoi. - Decision No. 249/2005/QD-TTg stipulates the regulations for applicable roadmap of emission standards for motor vehicles. - Decision No. 02/2005/QD-UB, dated January 10, 2005, stipulates the regulations on the implementation of measures to reduce dust in the construction sector in the area of Hanoi. 3) Functions of Other Departments Related to Air Quality Management (AQM) There are several departments under the Hanoi City PC who have roles and mandates related to AQM administration. 2-30

51 i) Although DOT has no specific units responsible for AQM, DOT performs administrative activities related to air pollution control especially in the transportation sector including transport infrastructure development. The Division of Urban Transportation Management under DOT indirectly carries out air pollution control through its own mandates on traffic management. The registration center for motor vehicles also conducts emissions inspection of vehicles by applying the emissions standards for registered vehicles. ii) Under DOIT is the Division of Safety Engineering and Environment. This division is generally responsible for managing environmental protection likely caused by the industrial sector, including industrial air pollution control, although the mandates on AQM of the division have not been clearly defined. iii) There are also several departments which have administrative functions related to AQM or air pollution control within their jurisdictional fields/sectors, such as the Department of Science and Technology (DOST), Department of Construction (DOC), and Department of Public Security (DOPS). 4) Facilities Related to Air Quality Management (AQM) A few laboratories and equipment related to AQM are deployed in the departments under the Hanoi City PC. Table Facilities Related to Air Quality Management (AQM) at Each Department of the Hanoi PC Departments DONRE (CENMA /Hanoi EPA) DOIT DOT Others Facilities Related to Air Quality Management (AQM) Two automatic monitoring stations (Both have not operated since 2013 because they have reached the end of their working life and there is no action/budget for their renewal.) 1. Nam Thang Long Monitoring Station for Air Quality 2. Thuong Dinh Monitoring Station for Air Quality Measurement parameters: PM10, SO 2, NO 2, NO x, NO, CO, O 3 Analytical laboratory Conduct flue gas measurement at factories, industrial areas, and roads on demand No monitoring stations and laboratories on AQM No monitoring stations and laboratories on AQM Registration center for motor vehicles 33-01S Hanoi, located in Ha Dong District DOST has a center for research, technology transfer, and analysis with laboratories and equipment to analyze and assess air quality, emissions, and air pollution compliance with standards such as QCVN 05:2013 and QCVN 06:2009, including emissions parameters at source. Source: Survey results of the Project (August 2014) and summarized by JET 5) Cooperation with Central Ministries and with Other Departments under the Hanoi City PC on Air Quality Management (AQM) Cooperation with other organizations is important in the aspect of AQM and air pollution control. Each department has some relationship with other governmental agencies as described in Table Table Summary of Cooperation with Central Ministries and with other Departments under the Hanoi City PC on Air Quality Management (AQM) Departments DONRE Cooperation Organization Central Ministries 2-31 Summary of Cooperation Cooperation with central ministries on AQM, including integrated environmental management programs such as on climate change prevention. Coordination for meetings among relevant ministries such as MONRE and MOIT.

52 Departments DOIT DOT Others Cooperation Organization Other Departments under Hanoi City PC Central Ministries Other Departments under the Hanoi City PC Central Ministries Other Departments under the Hanoi City PC Central Ministries Other Departments under the Hanoi City PC Summary of Cooperation Coordination with VEA/MONRE and PCD under MONRE for the study, program, and project on AQM. Coordination with VEA/MONRE and district DONREs in Hanoi City in organizing the World Environment Day. Coordination with VEA/MONRE in organizing inspection teams that would monitor air quality and inspect factories. Management of projects related to AQM in collaboration with MOT such as the Urban Transport Project, which is funded by the World Bank. Investment in industrial waste incinerator projects funded by NEDO, currently implemented in Nam Son with the participation of MONRE. Coordination with MONRE in providing comments on circulars, regulations, national reports on air quality, etc. before issuance of these documents and reports. Coordination with DOIT and DOC in inspection programs for monitoring air quality and inspecting factories. Coordination with DOT in monitoring air quality of transport projects in Hanoi. Coordination with DOIT, DOT, and district DONREs in Hanoi in organizing the World Environment Day. Collaboration with other relevant agencies to solve environmental damage problems. Coordination with MOIT in implementing energy-saving programs and green growth in industrial activities, households activities, etc., with direct linkage to air pollution management contributing to reduction of emissions. Coordination for meetings with DONRE, and organizing the World Environment Day, annual inspection programs, etc. Cooperation with MOT on AQM such as organizing meetings and studies aimed at decreasing traffic jams in Hanoi. Coordination with MOT in planning and development of road infrastructure such as highway systems, overpasses at intersections, and roundabouts, and contributing to reduce congestion and traffic jams on roads in order to reduce emissions that pollute the air. Organizing the World Environment Day, and annual inspection programs. Coordination with relevant departments under the Hanoi City PC for education, advocacy, and information dissemination of normative rules related to transportation in Hanoi. Cooperation with DONRE on AQM such as meetings and studies aimed at decreasing traffic jams in Hanoi, organizing the World Environment Day, inspection programs, the Urban Transport Project funded by the World Bank, etc. <DOC> Coordination with MOST and MOC for meetings and scientific studies on manufacturing, and application of new building materials. <DOST> Coordination for meetings and scientific studies, organizing the World Environment Day, inspection programs, etc. <DOST> Coordination with DONRE and DOC in researching new technology and standards regulations. Dissemination of information about new technology, etc. <DOC> Coordination with DOST and DONRE for meetings and scientific studies on manufacturing and application of new building materials. Source: Survey results of the Project (August 2014), summarized by JET 2-32

53 6) Stationary Source Information in Hanoi City and Other Provinces around the City i) Hanoi Area A summary of information on the cement industry and chemical fertilizer manufacturing in Hanoi City is shown in Table There are no steel factories and power plants in Hanoi City. Table Summary of Cement Industry and Chemical Fertilizer Companies in Hanoi City No. Name of Factory Main Products Location I Chemical fertilizer manufacturing 1 Bao Lam Chemical fertilizer Company Limited Manufacture of fertilizers and nitrogen compounds Duong Lieu, Hoai Duc District, Ha Noi Tan Truong Sinh Production Trading Manufacture of fertilizers and 2 And Services Corporation nitrogen compounds Dong Hamlet Huong Tung Commercial Limited Manufacture of fertilizers and 3 Liability Company nitrogen compounds Dang Xa Hamlet 4 Canh Dong Vang Limited Liability Company Commercial Manufacture of fertilizers No. 3 Alley, Cau Buou Ward 5 Da Quoc Gia Pesticide Corporation Manufacture of fertilizers An Lac 6 Van Dien Fused Magnesium Phosphate Fertilizer Joint Stock Company 300,000 ton/year of FMP, and 150,000 ton/year of NPK Van Dien Town, Thanh Tri II Cement factories Van Mieu Son Tay Cement - Paper Pho Hang Street, Phu Corporation Thinh Ward, Son Tay 1 Vinaconex Concrete and Building Corporation Manufacture of cement Manufacture of cement of 100,000 ton/year Chuong My District, Hanoi 2 Nam Sơn Manufacture of cement pf Chương Mỹ District, 3 350,000 ton/year Hanoi Tien Son Ha Tay Cement Corporation 400 ton of clinker/day Hong Quang, Ung Hoa 4 District, Ha Noi Source: Survey results of the Project (August 2014) ii) Other Provinces around Hanoi City (within 30 km from the boundary line of the city) Hanoi City is adjacent to eight provinces, namely, Thai Nguyen in the north, Bac Giang in the northeast, Bac Ninh, Hung Yen in the east, Henan in the south, Hoa Binh in the southwest, Phu Tho in the west, and Vinh Phuc. There is no power plant within a scope of 30 km from the administrative boundaries of Hanoi City. The nearest power plant is Pha Lai Thermal Power Joint Stock Company. But Pha Lai Thermal Power Plant located in the territory of Chi Linh Town, Hai Duong Province, about 56 km far from Hanoi City. A summary of information on cement factories, the steel industry, and chemical fertilizer manufacturing (name, location, capacity, main activities etc.) located within 30 km outside the administrative boundaries of the city is shown in Table Table Summary of Cement Factories, Steel Industry, and Chemical Fertilizer Companies within 30 km Outside the Administrative Boundaries of Hanoi TT Factory Name Business / Main Product Location I Cement factories 1 Huu Nghi 1 250,000 ton/year Viet Tri City, Phu Tho Province 2 Huu Nghi 2 350,000 ton/year Viet Tri City, Phu Tho Province 3 Huu Nghi 3 450,000 ton/year Viet Tri City, Phu Tho Province 4 Song Thao 910,000 ton/year Thanh Ba, Phu Tho Province 5 Thanh Ba 350,000 ton/year H. Thanh Ba, Phu Tho Province 6 Hoa Binh 350,000 ton/year Luong Son, Hoa Binh Province 2-33

54 TT Factory Name Business / Main Product Location 7 But Son 1 1,400,000 ton/year Kim Bang, Ha Nam Province 8 But Son 2 1,600,000 ton/year Kim Bang, Ha Nam Province 9 X ,000 ton/year Kim Bang, Ha Nam Province II Steel industry Thai Nguyen Iron and Making steel billet and rolling Steel Joint Stock steel: 1,000,000 ton/year 1 Company (TISCO) Duc Phat Construction Steel production and processing 2 Company Limited of steel products Steel production and processing Hoang Loc Co. Ltd 3 of steel products Ching Hua Structural Steel production and processing 4 Steelwork Co. of steel products Factory of AUSTNAM Steel production and processing 5 Co. Ltd of steel products III Chemical fertilizer manufacturing Lam Thao Super Phosphate, NPK fertilizer: Phosphate and 800,000 ton/year 1 Chemicals Company Source: Survey results of the Project (August 2014) Cam Gia Ward, Thai Nguyen City Dinh Tram IP, Lot no. B1-B2, Viet Yen, Bac Giang Da Hoi, Chau Khe, Tu Son Town, Bac Ninh Province Que Vo IP, Que Vo District, Bac Ninh Lot no. 43, Quang Minh IP, Vinh Phuc Province Lam Thao Town, Lam Thao District, Phu Tho Province 7) Issues and Difficulties in AQM Activities Through the survey, the issues and difficulties in AQM of departments under the Hanoi City PC were identified. The issues and difficulties are summarized in Table Table Summary of Issues and Difficulties in Air Quality Management (AQM) of Department under the Hanoi City PC Departments Summary of Issues and Difficulties Each unit has unclear responsibilities and overlapping mandates in terms of regulations related to AQM in Hanoi City. Specifically, according to the Hanoi City PC s Decision No. 36/2010/QD-UBND, dated August 16, 2010, on regulating the functions, tasks, powers, organizational structure, and staffing of DONRE, there are no mentioned details on AQM by Hanoi DONRE. The policies, plans, programs, and reports related to AQM in Hanoi City are very common and general. The overlapping functions or unclear duties assigned should hardly give specific and detailed solutions to each unit. DONRE Lack in number and lack of staff qualifications: DONRE and Hanoi EPA should increase their qualified staff. According to the results of the interview survey by the local consultant, DONRE needs ten qualified staff that are engineers, have a bachelor s degree, or professionally-trained in AQM. Lack of state budget: All activities of DONRE depend on the state budget. Therefore the lack of state budget would lead DONRE to lack capital to provide subsidies to enterprises for AQM. With the many tasks at hand, the limited budget should be improved. There is a lack of specific interdisciplinary circulars on AQM. Each unit has unclear responsibilities in terms of regulations related to AQM. So far, the only document on environmental management of DOIT is the Joint Circular No. 31/2009/TTLT-BCT-BTNMT dated April 11, It is essential to formulate and organize the implementation of cleaner production strategies, programs, and projects in the field of environmental protection in Hanoi City. DOIT There is a lack of budget for solutions and implementation of AQM activities. DOIT needs to develop a database in order to understand the situation of AQM and to evaluate the effectivity of solutions of DOIT and others on AQM. It is necessary for DOIT to collaborate with departments of the Hanoi City PC for data sharing with DONRE. Educational awareness for AQM is not strong enough, although that for environmental protection is one task of DOIT. Each unit has unclear responsibilities in terms of regulations related to AQM such as the functions of DOT on environmental protection in transport activities under Decision No. DOT 17/2008/QD-UBND dated September 29, The regulations of DOT on AQM need more details with regard to the capacity of law enforcement officers, setting of better wages, and rewards. 2-34

55 Departments Summary of Issues and Difficulties Generally, the number and qualifications of staff are not enough. However, DOT cannot determine the necessary number of staff because such depends on the specific tasks assigned in each period and budget allocation timing. DOT cooperates with MOT to find solutions to decrease traffic jams, for example, fuel conversion, and new standards of vehicles and emissions. Source: Survey results of the Project (August 2014), summarized by JET (3) Results and Key Findings of Survey on AQM Activities in HCMC 1) Organizational Overview of HCMC DONRE Related to Air Quality Management (AQM) The organizational chart of HCMC DONRE is shown in Figure The mandates, organizational structure, and staffing of HCMC DONRE are specified in Decision No. 121/2003/ QD-UB of the HCMC PC, dated July 18, HCMC DONRE has the function of advising and assisting the municipal PCs in performing state management over the city in the field of natural resources and the environment, including land resources, water resources, mineral resources, geology, environment including air quality, hydrometeorology, geodesy and cartography; integrated and unified management of marine and island issues; and implementation of public services in areas under the jurisdiction of the department. The units under HCMC DONRE with tasks directly related to AQM include the Ho Chi Minh Environmental Protection Agency (HEPA) (including the Center for Environmental and Natural Resources Monitoring and Analysis), Inspection Division, and Ho Chi Minh City Environmental Protection Fund (HEPF), as shown in Table HEPA has the function of advising the Director of HCMC DONRE, whom issues, promulgates, and approves legal documents, programs, plans, and projects concerning environmental protection in the city. HEPA implements legislation, programs, plans, projects, and proposals on environmental protection, which are approved and issued by the central government, HCMC PC, or Director of DONRE. HEPA has the fundamental task of air pollution control. Basic organizational information on HEPA is summarized in Table , and its organizational chart is shown in Figure

56 Source: Survey results of the Project (July 2014) Figure Organizational Chart of HCMC DONRE Table Mandates and Cooperation Mechanism Related to Air Quality Management (AQM) among the Units under HCMC DONRE Ho Chi Minh Environmental Protection Agency, including the Center for Environmental and Natural Resources Monitoring and Analysis 23 Inspection Division Mandates (See Table also): - Assists HCMC DONRE in implementing environmental protection and managing tasks in various areas, including pollution control, public awareness raising, environmental monitoring, etc. - Be the focal point or coordinate with related agencies in solving environmental problems at the inter-sector and inter-provincial levels. Cooperation mechanism with related parties: - HEPA assists the Director of DONRE in the following areas: developing and organizing the implementation of legal documents, programs, plans, planning, projects, proposals at the local level; strategic environmental assessment report appraisal; supervising, checking, handling violent actions in the area of environmental protection; and other assigned tasks. - HEPA works closely with and provide professional guidance to district-level DONREs. - HEPA cooperates with the Inspection Division in inspection activities, and handling violation actions for environmental protection. - HEPA works with communities and citizens in order to promote, spread, and raise knowledge and awareness about environmental protection. - HEPA collaborates with domestic and foreign counterparts in implementing cooperation projects/programs. Mandates: - Assists the Director of HCMC DONRE in implementing administrative and specialized inspection tasks in environmental areas. 23 Decision no. 04/2012/QD-UBND dated January by HCMC People s Committee providing the transformation of organization model of HCMC Environmental Protection Agency- HCMC Department of Natural Resources and Environment. 2-36

57 HEPF 24 Source: JICA Expert Team - Proposes competent authorities to handle illegal actions in the field of natural resources and environment. Cooperation mechanism with related parties: - The Inspection Division advises the Director of DONRE in performing inspection, and settlement of complaints and denunciations in the field of natural resources and environment. - The Inspection Division coordinates with the provinces to solve environmental problems at the inter-provincial scale. - The Inspection Division communicates with citizens, organizations, and communities to receive, handle, and settle complaints and denunciations. Mandates: - HEPF is a state financial organization under HCMC DONRE and supervised by the Ho Chi Minh Department of Finance in terms of state financial management. - Provides financial assistance to individuals, organizations, and enterprises in conducting programs, projects, and activities in the area of environmental protection, thorough treatment of serious pollution sources, etc. - Provides preferential loans for environmental protection projects, which suit the requirements and functions of HEPF for domestic or foreign financial organizations, in accordance with the law. Cooperation mechanism with related parties: - HEPF coordinates closely with domestic or foreign financial organizations and donors in mobilizing and allocating funds for environmental protection, pollution control activities, etc. - HEPF provides loans to individuals, organizations, and enterprises in carrying out projects and programs that suit the requirements and functions of HEPF. Table Organizational Information of HEPA Item Organizational Information of HEPA Mandates (see 1) Performs the functions of state management of environmental protection, environmental also Table 2.2-9): inspection, and supervision for HCMC; 2) Pollution control; 3) EIA evaluation; 4) Project management and communication; and 5) Surface water monitoring, statistical survey of traffic emission sources, etc. (Center for Environmental and Natural Resources Monitoring and Analysis (CENMA) under HEPA) Public Servants Total of 106 personnel (74 public servants, 1 director, and 2 deputy directors): - Environmental Pollution Inspection and Supervision Division (Pollution Control Division): 1 head, 3 deputy heads, 13 employees - Evaluation and Assessment Division: 1 head, 3 deputy heads, 8 employees - Environmental Fee Division: 1 head, 2 deputy heads, 9 officers - Planning and Human Resources Division: 18 employees - Environmental Information and Media Division: 12 employees - Center for Environmental Monitoring and Analysis: 32 public servants (include 1 director) Budget See Table Organizational See Figure Structure Source: Survey results of the Project (July 2014) 24 Website of HCMC DONRE %E1%BB%8B+tr%E1%BB%B1c+thu%E1%BB%99c+&ItemID=46&Mode=1 2-37

58 Center for environmental monitoring and analysis N o Source: Survey results of the Project (July 2014) Figure Organizational Chart of HEPA The budget allotted for AQM in the last five years is summarized in Table according to information from the Planning and Administration Division of HEPA. Table Budget of HEPA for AQM in the Last Five Years (Unit: VND in millions) Work Contents Air quality monitoring at road sites Monitoring of air pollution by radioactive in HCMC Monitoring levels of benzene, toluene, and xylene (BTX) in air in HCMC Operation, maintenance, and purchase of spare parts of automatic air monitoring stations Air quality monitoring using semi-automatic method at automatic air monitoring locations (damage) Air emissions inventory for traffic activities in HCMC (mobile sources) Air emissions inventory for industrial activities in HCMC (point sources) , , , , , , Total 1, , , , , , ,188.4 Source: Survey results of the Project, and information provided by the Planning and Administration Division, July

59 2) Policies, Plans, and Programs Related to AQM in HCMC The policies, plans, and programs in HCMC related to environmental management including air quality and pollution control are summarized as follows: i. Decision No. 27/2011/QD-UBND of the HCMC PC issued on the Implementation Resolution Plan of the City Party Program 9th pollution reduction for the period of : It describes about prevention and limitation of pollution, and improving and restoring the quality of the environment. It requires striving to achieve the indicators until the end of 2015, including 50% reduction of the level of air pollution and noise from vehicle activities, etc. ii. Action Plan No. 34-CTrHD/TU, dated November 27, 2013, of the Standing Committee of HCMC for the implementation of Resolution No. 24-NQ/TW of the 7th Conference of the Central Executive Committee of XI in response to climate change and for enhancing management of natural resources and environmental protection: This plan includes key objectives related to air pollution, such as, by 2020, 90% of industrial emissions across the city are treated to meet environmental regulations. iii. Socio-Economic Development of HCMC to 2020 and Vision to 2025 in HCMC: - To develop HCMC as a civilized, modern, and urban city. HCMC should be a leader in industrialization and modernization, by largely increasing its economic contribution to the region and the country. - The average economic growth rate over the period of reached %/ year, over the period of at %/year, and the period of at 8.5-9%/year. The economic structure is to be shifted toward services and industry from agriculture. - To develop a modernized transportation network of roads, railways, waterways, and airways. - To gradually improve the efficiency of electricity use, to maintain the elasticity coefficient (the ratio between the growth rate of commercial electricity and gross domestic product growth at less than 1), and to strive for reduction of it to less than 0.8. The rate of power capacity from renewable energy will increase to 2-3%. iv. Others: - Decision No. 188/2004 /QĐ-TTg, dated November 1, 2004, of the Prime Minister, approving the master plan for industrial development in HCMC toward 2010 with vision to Decision No. 2426/QĐ-UBND, dated August 18, 2004, of the HCMC PC, approving the master plan for development of the chemical industry in HCMC toward 2010 with vision to Decision No. 2013/QĐ-UBND, dated April 21, 2011, of the HCMC PC, approving the list of planning projects for development of major sectors and products toward 2020 with vision to ) Functions of Other Departments Related to Air Quality Management (AQM) There are several departments under the HCMC PC who have roles and mandates related to AQM administration. i) DOT has several divisions related to AQM. The Planning and Investment Division (PID) and three registration centers for motor vehicles under DOT carry out some activities related to AQM. PID is responsible for preparing plans related to the transportation sector for DOT. The three registration centers are as follows: (1) Registration center for 50-01S motor vehicles; (2) Registration center for 50-02S motor vehicles; and (3) Registration center for 50-03S motor vehicles. In vehicle exhaust check, the registration centers apply the emissions standards requested by the government. 2-39

60 ii) Under DOIT is the Division of Safety Engineering and Environment. This division is generally responsible for managing environmental protection likely caused by the industrial sector, including industrial air pollution control, although the mandates on AQM of the division have not been clearly defined. iii) There are also several departments which have administrative functions related to AQM or air pollution control within their jurisdictional fields/sectors, such as DOST, DOC, and DOPS. 4) Facilities Related to Air Quality Management (AQM) A few laboratories related to AQM are deployed in the departments under the HCMC PC. Table Facilities Related to Air Quality Management (AQM) at Each Department of the HCMC PC Departments DONRE (CENMA /HEPA) Facilities Related to Air Quality Management (AQM) Nine automatic monitoring stations have been installed before However, all of them are no longer working because they have reached the end of their working life and there is no action/budget for their renewal. No. Station Name Address Purpose 1 Quang Trung (QT) Dist. 12 Urban background 2 Zoo (ZO) Dist. 1 Urban background 3 District 2 (D2) Dist. 2 Residential 4 Tan Son Hoa (TS) Phu Nhuan Dist. Residential 5 Thong Nhat (TN) Tan Binh Dist. Urban/Traffic 6 Binh Chanh (BC) Binh Tan Dist. Urban/Traffic 7 DOSTE (DO) Dist. 3 Urban/Traffic 8 Hong Bang (HB) Dist. 5 Urban/Traffic 9 Thu Duc (TD) Thu Duc Dist. Urban/Industrial Currently, there are six semi-automatic monitoring stations. No. Station Name Address Purpose 1 Hang Xanh (HX) Binh Thanh Dist. Urban/Traffic 2 Phu Lam (PL) Dist. 6 Urban/Traffic 3 Dinh Tien Hoang Dien Dist. 1 Urban/Traffic Bien Phu (DTH) 4 Go Vap (GV) Go Vap Dist. Urban/Traffic 5 An Suong (AS) Dist. 12 Urban/Traffic 6 Nguyen Van Linh Huynh Dist. 7 Urban/Traffic Tan Phat (TT) Conduct flue gas measurement at factories, industrial areas, and roads on demand. No analytical laboratory. DOIT No monitoring stations and laboratories on AQM. No monitoring stations and laboratories on AQM. DOT Three registration centers for motor vehicles, namely, (1) 50-01S motor vehicles, (2) 50-02S motor vehicles, and (3) 50-03S motor vehicles. DOST: The Center of Analytical Services and Experimentation (CASE) of HCMC can analyze and assess air quality, emissions, and air pollution compliance with QCVN 05:2013 and QCVN 06:2009, including emissions parameters at source such as dust, O Other 2, CO 2, CO, SO 2, NOx, NO, NO 2, H 2 S, and CxHy. They can also monitor ambient air quality and working environment: dust, O 2, CO 2, CO, SO 2, NOx, NO, NO 2, H 2 S, NH 3, O 3, CxHy, organic compounds (THC and VOC), and noise; and analyze the trace of heavy metals (As, Hg, Cd, Pb, Cr, Zn, Mn, Fe, etc.). Source: Survey results of the Project (July 2014), summarized by JET 2-40

61 5) Cooperation with Central Ministries and with Other Departments under the HCMC PC on Air Quality Management (AQM) Cooperation with other organizations is important in the aspect of AQM and air pollution control. Each department has some relationship with other governmental agencies as described in Table Table Summary of Cooperation with Central Ministries, with Other Departments under HCMC PC on Air Quality Management (AQM) Departments DONRE DOIT DOT Cooperation Organization Central Ministries Other Departments under the HCMC PC Central Ministries Other Departments under the HCMC PC Central Ministries Other Departments 2-41 Summary Coordination with VEA /MONRE in organizing inspection teams to check and monitor environmental pollution enterprises in industrial zones and plants which have exhaust emissions in HCMC. Coordination with MONRE in providing comments on circulars, regulations, national reports on air quality, etc., before issuance of these documents and reports. Coordination with the Police Department and Crime Prevention on Environment of MOPS in checking and monitoring environmental pollution in industrial zones and plants which have exhaust air emissions in HCMC. Collaboration with the Institute of Environment and Resources (the agency under the Ministry of Education and Training) to join the inspection team and monitor environmental pollution in industrial zones and air emissions from enterprises in HCMC. Coordination with the Management Board of the HCMC Export Processing and Industrial Zone Authority (HEPZA). HEPZA is responsible for emission sources in export processing zones (EPZs) and industrial parks (IPs). DONRE collaborates with the Police Crime Prevention Division (PCTP) under the Police Department of HCMC in conducting inspection and supervision of the observance of the environmental protection law at manufacturing enterprises and service businesses in the city. HEPA collaborates with other relevant agencies for environmental protection such as DOIT and DOT. DONRE collaborates with the HCMC Health Department in studying the impacts of air pollution to human health in HCMC HEPZA collaborates with other departments under the HCMC PC especially with DONRE in assessing the environmental impacts and environmental protection projects in EPZs and IPs. Coordination with MOIT in implementing energy-saving programs and green growth in industrial activities, household activities, etc. These activities have been linked indirectly to air pollution management for reducing emissions. The Technical Safety and Environment Division under DOIT cooperates with DOIT and other departments, organizations, and central ministries in inspecting or checking the activities related to safety and the environment as assigned under the provisions of law. DOIT collaborates with the departments of the HCMC PC in examining the measures for responding to incidents of fire, chemical leakage, etc. DOIT collaborates with HEPA under DONRE in inspection activities relating to measures for chemical incidents. Frequency of collaboration is about once or twice a year. DOIT advises and proposes the establishment of IPs, EPZs, etc., in with respect to environmental aspects in general and air environmental protection. Coordination with and request to DONRE to prepare reports on the implementation of works related to general environmental protection and AQM. Coordination with MOT in road infrastructure development such as construction of highway systems, construction of overpasses at intersections and roundabouts, and contributing to reduce congestion and traffic jams on road in order to reduce emissions that pollute the air. Collaboration with the Vietnam Register under MOT in organizing registration and technical inspection of transport vehicles and construction equipment in the city. Coordination with relevant departments under the HCMC PC for education, advocacy, and information dissemination of normative rules related to

62 Departments Others Cooperation Organization under the HCMC PC Central Ministries Other Departments under the HCMC PC transportation in HCMC. Source: Survey results of the Project (July 2014), summarized by JET Summary <DOC> Coordination with MOC in implementing energy-saving programs in the construction sector. Coordination with MOC in implementing waste treatment programs toward reducing air emissions. Coordination with the Inspection Department of MOC and Inspection Division of HCMC DONRE in the implementation of programs, inspection plans, projects, and construction in the area, as assigned by the HCMC PC. <DOST> Coordination with MOST in implementing cleaner production programs in the manufacturing and industry sectors. <DOC> Collaboration with DONRE in checking activities related to environmental protection, such as air emissions, wastewater, and solid waste. Frequency of coordination is about once or twice a year. 6) Stationary Source Information in HCMC and Other Provinces around HCMC Data and information on stationary sources were collected from HCMC DONRE, DOIT, and the other provincial departments in the selected subsectors such as power plant, chemical fertilizer industry, cement industry, and steel industry. The collection of data/information covered the area of HCMC as well as within 30 km from the boundary of HCMC. The collected information are summarized in Table , Table , Table , and Table Table Power Plants in HCMC and the Area Within 30 km from the Boundary of HCMC No Location Quantity 1 Ho Chi Minh City 2 plants 2 Binh Duong Province - 3 Dong Nai Province 10 plants 4 Long An Province - 5 Tay Ninh Province - 6 Ba Ria-Vung Tau Province 4 plants Source: Survey results of the Project (July 2014) Table Chemical Fertilizer Industry in HCMC and the Area Within 30 km from the Boundary of HCMC No Location Quantity 1 Ho Chi Minh City 22 plants and companies 2 Binh Duong Province 15 plants and companies 3 Dong Nai Province 21 plants and companies 4 Long An Province 4 plants and companies 5 Tay Ninh Province 4 plants and companies 6 Ba Ria-Vung Tau Province 2 plants and companies Source: Survey results of the Project (July 2014) Table Cement Industry in HCMC and the Area Within 30 km from the Boundary of HCMC No Location Quantity 1 Ho Chi Minh City 51 companies 2 Binh Duong Province 2 companies 3 Dong Nai Province 1 company 2-42

63 No Location Quantity 4 Long An Province 1 company 5 Tay Ninh Province 1 company 6 Ba Ria-Vung Tau Province 1 company Source: Survey results of the Project (July 2014) Table Steel Industry in HCMC and the Area Within 30 km from the Boundary of HCMC No Location Quantity 1 Ho Chi Minh City 375 companies and factories 2 Binh Duong Province 248 companies and factories 3 Dong Nai Province 26 companies and factories 4 Long An Province 22 companies and factories 5 Tay Ninh Province 12 companies and factories 6 Ba Ria-Vung Tau Province 10 companies and factories Source: Survey results of the Project (July 2014) 7) Issues and Difficulties in AQM Activities Through the survey, the issues and difficulties in AQM of departments under the HCMC PC were identified. The issues and difficulties are summarized in Table Table Summary of Issues and Difficulties in Air Quality Management (AQM) of Departments under the HCMC PC Departments Summary of Issues and Difficulties Environmental protection is a considerable issue which has been integrated into the action plan at the central level. Therefore, it is vital to set action plans, programs, and proposals which assign specific tasks and coordinate the implementation among sectors and departments. Each unit has unclear responsibilities and overlapping mandates in terms of regulations related to AQM in HCMC. According to Decision No. 121/2003/ QD-UB, dated July 18, 2003, of the HCMC PC on regulating the functions, tasks, powers, organizational structure, and staffing of DONRE, there are no mentioned details on AQM by HCMC DONRE. The policies, plans, programs, and reports related to AQM in HCMC are very common and general. The overlapping functions or unclear duties assigned should hardly give specific and detailed solutions to each unit. DONRE Human resources in terms of quantity and qualifications are not enough for AQM. However, HCMC DONRE has no plans for additional professional training on AQM for their staff. HCMC DONRE has no data about AQM of the relevant ministries and the neighboring provinces. Therefore, it is necessary to have cooperation with other related organizations. Due to damaged monitoring stations, the information and data collected through the survey are not accurate. Until 2009, there were nine automatic air quality monitoring stations in HCMC. However, these automatic monitoring stations were damaged several years ago. Currently, there are no movable automatic air monitoring stations and all data accumulated from the results of six semi-automatic monitoring stations. Each unit has unclear responsibilities and overlapping mandates in terms of regulations related to AQM. Human resources in terms of both quantity and qualifications are not enough for AQM. DOIT has no clear goals for AQM in the next five or ten years. DOIT has no clear functions for coordination with other management agencies in DOIT HCMC related to environmental issues. DOIT has no data about AQM of the relevant ministries and the neighboring provinces. DOIT has no plans for additional professional training on AQM for their staff. There are no distinct policies for realizing close coordination with the related departments for controlling or reducing environmental pollution. Each unit has unclear responsibilities and overlapping mandates in terms of regulations DOT related to AQM such as the functions of DOT on environmental protection in transport 2-43

64 Departments Summary of Issues and Difficulties activities. The regulations of DOT on AQM need more details with regard to the capacity of law enforcement officers, setting of better wages, and rewards. Human resources in terms of both quantity and qualifications are not enough for AQM. DOT has no clear plans and goals on AQM. DOT cooperates with MOT to find solutions to decrease traffic jams, for example, fuel conversion, and new standards of vehicles and emissions. The main causes of air pollution in HCMC are from two activities, namely, transportation activities and industrial activities. In urban areas, air pollution is mainly caused by transportation activities. Therefore, to protect public health and to maintain a clean air environment in the city, transportation master planning is essential to be initiated. There are no distinct policies for realizing close coordination with the related departments for controlling and reducing environmental pollution. For example, there is no coordination among the related departments on construction works for canal upgrading which aims at environmental improvement. Awareness-raising activities are limited i) for people in traffic control and ii) for enterprises in environmental protection of business activities. Source: Survey results of the Project (July 2014), summarized by JET Sharing Technical Knowledge of Output 1 with the Two Cities for Formulating the Roadmap under Output 2 KKPL/PCD and JET organized a series of technical instruction and consultation for preparedness of TB formulation under Output 1. KKPL/PCD and JET held a total of eight lectures from January to May 2014, as described in the previous section. Apart from the series, mini-workshops were held at HCM DONRE in April 2014 and at Hanoi DONRE in September 2014 in order to: i) share essence technical knowledge of Output 1 with the two cities for formulating the roadmaps under Output 2, and ii) have better cooperation and timely exchange of opinions among DONREs, PCD/MONRE, and JET. The details of each mini-workshop, such as topics, agendas, and invitees, along with the Project progress and needs were discussed among KKPL/PCD, DONREs of the two cities, and JET. The results of the mini-workshops are summarized in Table , and the materials are shown in Attachment 10 of this report. Table Results of the Mini-Workshops No. 1 2 Venue and Period Mini-works hop in HCMC April 11, 2014 Mini-works hop in Hanoi City September 8, 2014 Source: JICA Expert Team 2-44 Topics 1) Emissions Inventory Development of Point Sources in Japan 2) Methodology to Estimate Amount of Emission (1. Source Testing, 2. Emission Factor, 3. Mass Balance) 3) Flue Gas Measurement and Standardized Oxygen Concentration of Flue Gas Measurement (1. Flue gas measurement in HCMC, 2. Issues/difficulties in developing emission sources inventory, 3. Others) 4) QCVN for Emission Standards (Relationship between Regional Coefficient (Kv) and Stack Height) 5) Environmental Standards and Automatic Air Quality Monitoring Station (Distributing Criteria, O&M, and Data Management) 6) Discussion 1) Legal structure for air pollution control in Japan 2) Emissions inventory: Method for developing emissions inventory 3) Automatic air monitoring 4) Application of continuous air monitoring system 5) Discussion Participants 41 people - KKPL, PCD - Inspection Division (HCMC DONRE) - Environmental Monitoring and Analysis Center (HEPA) - Pollution Control Division (HEPA) - EIA and Appraisal Division (HEPA) - 3 Districts DONRE 30 people - KKPL, PCD - Hanoi EPA - Hanoi Project Management Board/ Hanoi DONRE - Inspection Division (Hanoi DONRE) - CENMA DONRE

65 2.2.3 Results of Roadmap Formulation (1) Premise Environmental pollution is getting more evident in Vietnam due to rapid industrialization in the recent decade, and air pollution has become an issue in urban areas, especially in mega cities such as Hanoi City and HCMC. It is concerned that air pollution would cause damage to public health, unless effective countermeasures are implemented. The Vietnamese government has revised the LEP for the second time in June 2014 in order to tackle and control environmental pollution, including air pollution, by introducing a more effective and enforceable administrative approach. The revised LEP gives authority and responsibility to the DONRE of each city/province to execute national policies, laws, and regulations regarding environmental management and protection. In addition, the LEP defines the mandate to develop environmental protection planning, including air pollution control and AQM, not only at the national level but also at the city/provincial level. Although instruction from the government regarding environmental protection planning has not yet been provided to cities/provinces as of the end of the Project, it is essential and meaningful for Hanoi City and HCMC to prepare formulating the protection plan focusing on air pollution control and AQM, by taking the chance of the Project in cooperation with JICA. Under such understanding, the Project has proposed a roadmap to develop the AQM plan in Hanoi City and HCMC with the DONREs of the two cities as the main counterparts. The position of the roadmap under Output 2 of the Project is shown in Figure below. The figure shows an overview of the whole process of AQM planning and implementation. In the course of examining the roadmap, the following key findings in the two cities that were derived from the previous sections have been especially paid attention to: Importance of coordination and collaboration among departments under the PC concerned with AQM or air pollution control, which would be reflected to the structure of formulating the AQM plan in the cities and Importance of grasping the current status of ambient air quality and major air pollution sources for formulating the AQM plan, which would be reflected to the scheduling arrangement to accommodate the necessary measurement of air pollutants. 2-45

66 Roadmap to Develop AQM Plan (Product of Output 2 of the Project) The Superior Related Plans Five years plan, Urban plan, Traffic management plan, Industrial promotion plan Vision of Air Quality Management Goals setting (Target year) (Numerical target) Consolidation and Revision of the legal system Organization Revision and Reinforcement Enhancement and Integration of Air Quality Management Technology Point Source Mobile Source Ambient Air Awareness/Budget/Human resources Long list of Measures Analysis of Effects, Practicability and Impacts Determination of the Prioritized Measures Role and Cooperation of Each Department Overall Schedule for Implementing Measures by the Target Year Detailed Implementation Plan of Prioritized Measures Implementation of the Measures Review of the Implementation Plan Achievement of the goals Clarification of mandate of related departments Collaboration framework of DONRE and each department Budget planning and allocation Human resources Management and Development etc. Monitoring and Evaluation Air Quality Management (AQM) Plan Source: JICA Expert Team Implementation of AQM Figure [Re-depicted] Overview of the Whole Process Proposed for AQM and Positioning Output 2 of the Project (2) Roadmap Generated under Output 2 After sharing and evaluating the key findings compiled in this section among PCD/MONRE, DONREs of Hanoi City and HCMC, and JET, the formulation of the roadmaps for the AQM plan (AQMP) of each city was initiated, with due consideration to the revised LEP The report titled Guidance for Formulating Air Quality Management (AQM) Plan for Hanoi City/HCMC is one of the technical cooperation outputs generated under the Project, and it is enclosed as Attachments 13 and 14, with the table of contents below. The summary of the roadmap in chart form is shown in Table Table of Contents of Guidance for Formulating Air Quality Management (AQM) Plan for Hanoi City/ HCMC Chapter 1 Introduction 1.1 Background 1.2 Objectives of the Report Chapter 2 Overview of City, Air Quality Status, and Air Quality Management (AQM) 2.1 Overview of City 2.2 Current Air Pollution Status and Air Quality 2.3 Legal Framework for Air Quality Management Chapter 3 Roadmap to Develop AQM Plan (AQMP) for City 3.1 Proposed Contents of AQM Plan 3.2 Structure for Developing AQM Plan in City 3.3 Stakeholders to be Involved in the Course of Formulation of AQMP 3.4 Key Activities to Develop AQMP 3.5 Roadmap for Formulation of AQMP 2-46

67 Table Roadmap for Development of AQMPs for Hanoi City and HCMC Stage 1 Stage 3 Stage 4 Stage and Activity for AQMP Stage 2 (18 months) Implication of resource (3 months) (3 months) (6 months) Development mobilization and expenditure* 1st Quarter 2Q 3Q 4Q 5Q 6Q 7Q 8th Quarter 9th Q 10th Q Stage 1: Administrative Arrangement Stage 1 Establishing PMU and study team Setting preliminary vision and goals by holding stakeholder meeting with study team Preparing working plan and working schedule by study team Stage 2: Collecting Baseline Data Stage 2 Implementing emission inventory and measurement for main air pollution point sources Implementing emission inventory and measurement for air pollution due to transportation activities Analysis of solid waste management program Analysis of construction activities and other non-point sources Air quality monitoring Stage 3: Analysis of Situation Stage 3 Setting socio-economic scenario and target year Analysis of pollution load and ambient air status at current reproduction and targetyear estimation Estimation of GHG emission: current and future trend Setting vision and goals by stakeholder meeting Stage 4: Preparation of AQMP Stage 4 Proposing technical mitigation measures and programs Proposing administrative measures and budgetary plan Selection of priority measures Preparation of AQMP and implementation schedule of AQMP Sending AQMP to stakeholders for comments, holding stakeholder workshops for discussion External expertise: 5 MM Direct expense: 10% of above External expertise: 20 MM Direct expense: 40 % of above (inclusive of measurement and equipment consumable) External expertise: 15 MM Direct expense: 20 % of above (inclusive of application of computer simulation) External expertise: 10 MM Direct expense: 10 % of above *: Implication of resource mobilization and expenditure is prepared based on the consultant's experience and judgment under the condition that domestic resources are only mobilized. In such case, the monetary requirement to be allocated as the project budget by the PC roughly amounts to USD 250,000 or USD 300,000. Source: JICA Expert Team 2-47

68 2.3 Other Activities Support to PCD for Emissions Inventory Development of the Selected Subsectors (1) Background of Supplementary Technical Advice/Support for Inventory Works of PCD in the Selected Subsectors Under direct assignment of the head of VEA, KKPL/PCD has been trying to develop emissions inventories of air pollutants since November 2013 in the selected subsectors of thermal power plants, cement industry, and steel industry. This activity of emission inventory development of air pollutants is the first challenge of the Vietnamese government by itself. Therefore, it is necessary that highly-experienced experts provide advice and support this work. JET has enough experience of developing emissions inventories in some Asian countries including Vietnam in order to review and check the reliability of collected information in terms of air pollution control. Thus, OJT-based support for emissions inventory development is considered to be effective for this challenge of KKPL/PCD. The main objectives of this emissions inventory survey are as follows: To investigate and to prepare questionnaires for surveys in the selected subsectors of the steel industry, cement industry, and thermal power plant; To investigate and to implement field surveys in emission sources of the steel industry, cement industry, and thermal power plant; To identify fuel consumption and types of production technology which cause emissions; To identify industrial emission sources; To grasp the conditions of air pollution control, equipment, and emission monitoring; To integrate the collected information and to review and evaluate data reliability; To develop emissions inventories of the selected subsectors; and To study the challenging issues and difficulties in air pollution control. (2) Summary of Supporting Activities 1) Target Enterprises and Information Collecting Methods The target subsectors are thermal power plants, the cement industry, and steel industry, which are identified as heavy air polluters in Vietnam. PCD selected 24 enterprises with thermal power plants, 48 enterprises in the cement industry, and 26 enterprises in the steel industry. KKPL/PCD prepared questionnaires for the development of emissions inventories, and distributed them to target enterprises in JET started to provide the necessary advice to KKPL/PCD from June KKPL/PCD and national experts of JET tried to collect missing information through direct approach to enterprises, by going to enterprises and implementing interview survey, indirect data collection, and calling the enterprises. 2) Support the Development of the Draft Circular on Implementation of Industrial Emissions Inventory KKPL/PCD is drafting a circular on the implementation of an industrial emissions inventory. It requires experience and technical knowledge on the development of emissions inventories. KKPL/PCD expects to get the necessary knowledge through the activities of emissions inventory development as supported by JET. In addition, JET and PCD organized one workshops on November 11, 2014 and March 20, 2015 for the introduction of the draft circular that will guide the implementation of industrial emissions inventory. 2-48

69 3) Major Supporting Activities JET started to advise KKPL/PCD about necessary ideas for emissions inventory development for the selected subsectors from the end of June 2014 to the end of the Project. The main support activities are as follows: Technical advice and comments on the questionnaires prepared by KKPL/PCD for the three industrial sectors; Technical advice and comments on the replied questionnaires for the three industrial sectors; Technical advice at the field survey for some emission sources of the steel industry, the cement industry, and thermal power plants; Technical advice and comments on the industrial emissions inventory report prepared by PCD and national experts; Technical advice on developed emissions inventory in the selected subsectors; and Suggested solutions to emission inventories development in the next survey. The sequence of supporting activities done by JET is shown in Table Table Supporting Activities for Inventory Provided by JET Date Description of Activity Participants 26 Jun Discussion about the terms of reference including schedule and KKPL/PCD and JET questionnaires 04 Jul Technical discussion in accordance with the questionnaires KKPL/PCD and JET 15 Jul Discussion about the local experts and overall schedule KKPL/PCD and JET 22 Jul Technical discussion about the questionnaires for thermal power plants and the steel industry KKPL/PCD, local experts, and JET 23 Jul Technical discussion about the questionnaire for the cement industry KKPL/PCD, local experts, and JET 29 Jul Field survey of the Xuan Thanh cement factory (Ha Nam Province) based on the questionnaire KKPL/PCD, Ha Nam DONRE, national experts, and JET 04 Aug Discussion about the working report and discussion schedule KKPL/PCD and JET of collected questionnaires 07 Aug Technical discussion about reviewing and checking the reliability of the collected steel industry questionnaires KKPL/PCD, national experts, and JET 08 Aug Technical discussion about reviewing and checking the reliability of the collected cement industry questionnaires KKPL/PCD, national experts, and JET 11 Aug Technical discussion about reviewing and checking the reliability of the collected thermal power plant questionnaires KKPL/PCD, national experts, and JET 04 Sep Field survey of the Quan Trieu cement factory (Thai Nguyen Province) based on the questionnaire KKPL/PCD, Ha Nam DONRE, national experts, and JET 04 Sep Field survey of Thai Nguyen Iron and Steel JSC (TISCO) (Thai Nguyen Province) based on the questionnaire KKPL/PCD, Ha Nam DONRE, national experts, and JET 19 Sep Field survey of Quang Ninh Thermal Power JSC based on the questionnaire KKPL/PCD, Ha Nam DONRE, national experts, and JET 11 Nov Overall workshop KKPL/PCD and JET 15 Nov Technical comments and advice on the draft final report on the JET cement industry 20 Nov Technical comments and advice on the draft final report on JET thermal power plants 25 Nov Technical comments and advice on the draft final report on the JET steel industry 06 Jan Technical comments on the final report on the cement industry JET 22 Jan Technical advice on emissions inventory development in KKPL/PCD and JET Vietnam 27 Jan Technical discussion about the proposed questionnaires of JET KKPL/PCD and JET 30 Jan Technical discussion about the improved questionnaires of JET KKPL/PCD and JET Source: JICA Expert Team 2-49

70 (3) Summary of Emissions Inventory Development 1) Methodology for Emissions Inventory Development Emissions inventory development for the selected three subsectors was conducted in the following method: Collection of data and information from available legal documents (laws, decrees, circulars, etc.) environmental reports, previous study results, and internet sources. Collection of data and information through questionnaire survey. If the information in the returned questionnaire is not sufficient or unanswered, additional field survey and direct interview or confirmation by phone with the persons in charge of environmental management is conducted. Develop emissions inventory using Microsoft Excel. PCD and JET discussed about the format many times and made it effective. Consultation with the national experts of JET: The national experts of JET asked for opinions and ideas, and invited JET and PCD to join the surveys as well as comment on the survey reports and interview results. Integration of the all implementation results and emissions inventory development report. Estimation of emission amount using emission factor and reliable data. The basic mathematical formula for estimation of the emission amount based on the emission factor is as follows: E = A EF(1-ER/100) Wherein, E : Emission amount (kg/year) A : Activity data (ton fuel or ton product/ year) EF : Emission factor (kg/ton fuel or kg/ton product) ER: Emission reduction efficiency (%) The number of target factories for the survey is as shown in Table Table Number of Target Factories for Each Selected Subsector Number of Sector Target Factories (Factory) Thermal Power Plant 24 Cement Factory 48 Steel Industry 26 Source: JICA Expert Team 2) Summary of Results of Emissions Inventory i) Number of Answered Questionnaires During the emissions inventory survey, about 80% of target factories answered the questionnaire. The number of target factories that answered the questionnaire is as shown in Table

71 Sector Table Number of Responding Target Factories Number of Target Factories Number of Responding Factories Percentage of Answer (%) Thermal Power Plant Cement Factory Steel Industry Source: JICA Expert Team ii) Example of Collected Information PCD and JET received the answers to the questionnaires from the factories. The results of the survey of cement factories are summarized in Table as an example. All results are compiled and provided in Attachment 17. In the survey, 35 of the 44 cement factories that were given the questionnaire replied with their answer. Together with three questionnaires collected during the field survey by PCD and JET, the total number of answered questionnaires received was 38 (ratio of feedback: 38/47, i.e., 80.9%). The ratio of feedback for individual questions are shown in Table Table Summary of Results from Questionnaire Survey for Cement Factories Question/Information No. Requested 1 Year of establishment (note: some information provided by PCD) 2 Production of clinker in 2012 (million ton) Summary of Answers - Before 1975: 2/44 (4.5%) - From 1976 to 1990: 4/44 (9.1%) - From 1991 to 2000: 10/44 (22.7%) - From 2001 to 2010:12/44 (27.3%) - From 2011 until now: 2/44 (4.5%) - No information: 14/44 (31.8%) - Less than 0.5: 11/44 (25.0%) - From 0.5 to 1.0: 4/44 (9.1%) - From 1.0 to 1.5: 5/44 (11.4%) - From 1.5 to 2.0: 5/44 (11.4%) - From 2.0 to 2.5: 1/44 (2.3%) - From 2.5 to 3.0: 2/44 (4.5%) - Over 3.0: 5/44 (11.4%) - No information: 11/44 (25.0%) 3 Type of fuel - Coal only: 22 - Coal + FO: 8 - Coal + other: 5 - Coal + FO + other: 5 6 Characteristics of fuel - Ash content: majority ranges from 15% to 24% with exceptionally high from 29% to 32% at Nghi Son Cement Factory - Volatile: mainly 7-8%, lowest is 5% in Hoang Thach cement, highest values are 38% and 41.2% at Holcim Cement Factory and Thanh Cong III Factory. 7 Production technology - Dry + rotary kiln: 43 - Blast + semi dry kiln: 01 8 Specification of kiln - Length: from 11 m to 85 m, but mainly from 50 m-70 m - Diameter: from 3.2 m to 5.3 m, average is 4.2 m - RPM: from 0.36 rpm to 4.8 rpm - Inclination: from 3% to 4% - Burning temperature: from 1250 o C to 1500 o C, but mainly at 1450 o C - Country of origin: China, Germany, Japan, Denmark but the majority are made in China (24/44 factories) 9 Operational regime Most of factories operate 24 hours a day, 7 days a week, 10 months a year (2 months for maintenance), but some factories operate only 18 to 21 hours a day. 10 Emission treatment facility ESP: 2-51

72 No. Question/Information Requested Summary of Answers - 17/44 factories reported (22 factories have no answer) - Efficiency: mostly >99%, some lower (95-98%) - Temperature varies from 60 o C to 400 o C - Emission velocity: mostly from 0.66 to 1 m/s, some higher >1.2 m/s Bag filter: information is not summarized because of the inconsistency of information provided. 11 Stack information Stack height, number of responses: 66 - Taller than or equal to 50 m: 33 - Taller than 50 m but lower than 100 m: 14 - Taller than 100 m: 19 Stack diameter, number of responses: 66 - Smaller than or equal to 2 m: 15 - Larger than 2 m but smaller than 4 m: 41 - Larger than 4 m: 10 Stack temperature: - Lower than or equal to 100 o C : 21 - Higher than 100 o C but lower than 200 o C: 25 - Higher than 200 o C: 4 (Note: some plants reported the stack temperature as a range, such as o C or o C, etc.) 12 Emission monitoring - Number of work platform reported as Yes : 36 CEMS - Number of CEMS reported as Working : 17 - Number of CEMS that monitor dust: 9 - Number of CEMS that monitor SO 2 : 8 - Number of CEMS that monitor NOx: 9 - Number of CEMS that monitor CO: 9 13 Emission monitoring results Not summarized because of the inconsistency of data provided Source: JICA Expert Team iii) No. Estimated Amount of Emissions The amount of emissions from the target cement factories were estimated using the mathematical formula described before. The estimated amount of emissions from cement factories is presented in Table The results and estimated amount of emissions of the selected subsectors are shown in Attachment 17. Table Estimated Emission Amount from Cement Factories Name of Cement Factory Questionnaire Result: Amount of Clinker (ton/year) Estimated Results: Amount of Emissions in 2011 (kg/year) Estimated Results: Amount of Emissions in 2012 (kg/year) Dust NOx Dust NOx 1 155, ,451 39, ,215 53, , ,000 7,500,000 1,920, ,000 48,000,000 16,125, , ,987 4,463,147 1,499,338 3,724,717 1,251, , , , , , , , ,379 12,361,094 1,384,185 9,549,677 1,069, , , , , , , , , ,577 1,358, , , ,000 38, , ,001,469 3,075 3,841,880 6,453,158 3,936 6, , , , , , , ,033,009 19,833,773 2,220,

73 No. Name of Cement Factory Questionnaire Result: Amount of Clinker (ton/year) Estimated Results: Amount of Emissions in 2011 (kg/year) Estimated Results: Amount of Emissions in 2012 (kg/year) Dust NOx Dust NOx 13 1,076,769 3,028,528 20,673,965 2,315,053 38,765 6,511, ,980,000 38,144 6,407, ,595,367 1,716, ,207 3,430, ,703 3,690, ,701,923 1,651,456 2,178,461 3,659,134 2,113,864 3,550, , , , ,450,000 2,560,000 15,680,000 5,267,500 16,384,000 5,504, ,000 70,000 89, ,500 89, , , ,657 1,338, ,698 1,629, , ,192,334 1,260 22,892,813 2,563,518 24,192 2, ,690,936 2,843, ,440 5,785, ,948 6,113, ,207,953 2,420,752 42,392,698 4,747,099 46,478,438 5,204, ,149, ,906 22,078,195 2,472,298 18,065,395 2,022, ,914 1,788, , ,165 2,289,668 3,845, ,850,000 3,024,000 7,296,000 6,127,500 7,741,440 6,501, , , ,000 1,397, ,000 1,505, ,216,363 3,636, ,678 6,915, ,169 7,817, ,260,000 1,251,000 48,384 2,709,000 48,038 2,689, ,137 24, , ,767,747 1,324,000 11,313,581 3,800,656 8,473,600 2,846, ,200,000 1,260, ,600 2,580, ,280 2,709, ,700,000 1,760,000 8,704,000 3,655,000 9,011,200 3,784, ,426,573 1,423,073 9,130,067 3,067,132 9,107,667 3,059, ,000 1,634,622 17,644,800 1,975,850 31,384,742 3,514, ,661 16,524,691 1,850, ,566 1,215, ,865 2,140, ,089 2,612, , , , , , ,500 Note: Factory names are not shown in this table due to confidentiality. Source: JICA Expert Team (4) Summary of Technical Notes and Advice 1) Preparation of Questionnaire Sheet and Implementation of Questionnaire Survey i) Issues and Difficulties During the questionnaire survey including the preparation stage, JET encountered the following issues and difficulties: There are not enough columns to fill the facilities information in the questionnaire, e.g., there are five boilers according to the floor plan of the facility. However, there is only one cell for answering the question on boilers and stacks. There are no columns to fill for answering emission concentration, emission flow rate, and annual working hours. There are also no columns to fill for answering the number of stacks, and operation hours including operation starting/stopping time. There are columns necessary for filling the answers on emission measurement equipment, parameters, frequency, and measured organization. However, the flue gas measurement report was not requested to be attached. In addition, some factories misunderstood the question about ambient air concentration of factory. 2-53

74 ii) Lack of information about linkage between treatment system and stack, e.g. there are two stacks, but the information on the treatment system is only one. Thus, it is difficult to understand if same treatment systems are installed or one treatment facility is working for two boilers. The questions on amount of fuel consumption and origin of fuel have not been filled. There is no column to fill the stack number that is connected to the clinker. Some factories had no exhaust gas measurement results, no emissions flow rate, and no annual working hours. Also, the results of calculation of annual emissions were wrong. Technical Notes and Advice In response to the above issues and difficulties, JET provided suggested solutions as technical notes and advice to the counterparts. The main technical notes and advice are as follows: To call the factory and confirm all necessary information. For example, KKPL/PCD and/or the national experts of JET should call the factory and confirm all necessary data, such as if there are five boiler facilities according to the floor plan of the facility, and if there is only one answer of boiler. To call the factory and explain the purpose of the questionnaire again, and to explain that the necessary data is emission from their stack and not ambient air. In addition, the frequency of measurement and oxygen concentration of emissions are necessary to be collected. Furthermore, it is necessary to confirm if the unit used is mg/nm 3 or mg/m 3. To check the number and unit of the size of the kiln and clinker production volume filled by the factory. In addition, if there are blank answers, it is necessary to call the enterprises and confirm the missing information. JET explained the calculation of annual emissions (i.e., annual emissions = concentration of emission x volume of emission flow x annual working hours). In addition, it is necessary to consider the unit. If units are different with one questionnaire, KKPL/PCD and/or the national experts of JET should call the factory and confirm the units. To ask the factories to send their flue gas measurement reports. In addition, it is necessary to confirm if the unit used is mg/nm 3 or mg/m 3. It is necessary to link among combustion system (boiler or clinker furnace), process, treatment system, and stack. There is no column to fill for answering annual fuel consumption of each facility. It is necessary to add a column for such to the questionnaires. There is no column to input O 2 concentration of boiler. It is necessary to add a column for such to the questionnaires. It is necessary to use a unit unified with the Vietnamese standard (QCVN) for emission concentration (mg/nm 3 ) and flow rate of emission (Nm 3 /h) in the stack. As for the steel industry, it is better to make the questionnaire one by one, such as 1) Coke oven, 2) Sinter plant, 3) Pelletizing plant, 4) Blast furnace, 5) Steelmaking, and 6) Reheating furnace. These suggestions for the questionnaires have been reflected on the proposed questionnaires provided by JET. The proposed questionnaires are given in Attachment 17, Technical Cooperation Product of Emission Inventory Development. Figure is one example of the 2-54

75 proposed questionnaire. JET and PCD made this questionnaire with sample answers. The sample answers will contribute to the checking and confirmation of the actual answer. Figure Example of Proposed Questionnaire (for Cement Factory) 2-55

76 2) Development of Emissions Inventory i) Issues and Difficulties For development of emissions inventories, JET encountered the following issues and difficulties: a) Emission Factor For development of emissions inventories, JET emphasized that the data from actual sampling and analysis shall be used for calculation of the emission amount. However, actual emissions data, such as concentration of target pollutants (mg/nm 3 ) and/or flow rate of emissions (mg/nm 3 ), were not available. Thus, the emission factors were used to estimate the emission amount. During the activities with PCD and JET, PCD used the emission factors described in a document of the World Health Organization (WHO) 25. This document was published more than 20 years ago (in 1993). These emission factors are not set based on the capacity and specifications of facilities in Vietnam. These emission factors are not reliable enough to be applied in Vietnam and the accuracy is not good. Thus, it is necessary to find or make suitable emission factors for the factories in Vietnam. b) Measured Emission Amount and Estimated Emission Amount The emission amount from using actual measurements and the one from applying emission factors result in different values. It is necessary to confirm the information of flow rate of emission (Nm 3 /h) in the stack, results of measurement data (mg/nm 3 ) in the stack, and operation time of facility (hour/year). ii) Technical Notes and Advice In response to the above issues and difficulties, JET suggested solutions as technical notes and advice to the counterparts. The main technical notes and advice are as follows: a) Technical Aspect To accurately grasp the emission amount from all factories in Vietnam, it is necessary to increase the number of inventoried factories, including not only the target factories in the selected subsectors but also the other subsectors such as the chemical industry and petroleum refining industry. The emission factors in the Global Air Pollution Forum Air Pollutants Emission Inventory Manual 2012 (GAP Forum Manual 2012), Air Pollutant Emission Inventory Guidebook 2013(EMEP/EEA 2013), and US EPA AP-42 can be applied to estimate the emission amount. Stack gas measurement should be implemented in accordance with international standards. To use the results of measurement, original Vietnamese emission factors should be prepared in the future. b) Factory Owner s Aspect Many factories implement their activities as an economic priority. It is necessary to assign a person in charge of environmental management in the factory to manage emitted air pollutants and to operate CEMS. In order to conduct effective environmental management, the factory should grasp characteristics of emission sources. In addition, it is recommended to assign a person who has enough knowledge and experience to answer accurately the questionnaire of the air pollution inventory for smooth and effective emissions inventory development. 25 Source: Assessment of Sources of Air, Water and Land Pollution: A Guide to Rapid Source Inventory Techniques and Their Use in Formulating Environmental Control Strategies. Part one: Rapid Inventory Techniques in Environmental Pollution. Geneva, 1993, WHO. 2-56

77 c) MONRE and DONRE s Aspect (Administrative Aspect) Developing the emissions inventory is an important step in the AQM process. Emissions inventories are utilized to determine significant air pollution sources, plot clear emission trends over time, prepare policies for AQM, and so on. It is necessary for government officials to understand how to develop emissions inventories by themselves. On the other hand, it is not easy to develop a comprehensive emissions inventory. Developing an emissions inventory needs time and human resources. In Japan and other developed countries, officers of the central government do not develop emissions inventories by themselves. Rather, specialists or special institutes develop emissions inventories and update them continuously. Therefore, it is recommended that developing or updating emissions inventories is entrusted to an external institute of VEA, scientists, or researchers, and the requirement of budget allotted to emissions inventory development is essential Support to CEM for Improving Flue Gas Measurement (1) Background of Supporting Activities In order to conduct effective and feasible air pollution control for enterprises as a state management agency, it is necessary to grasp the total amount of air pollutant emissions from each factory by emissions inventory. Also in order to attain meaningful and precise emissions inventory, accurate industrial emission monitoring/flue gas measurement is indispensable. By chance, CEM, under the umbrella of VEA, is drafting circulars on industrial emissions monitoring. It requires very detail, technical, and experience-based descriptions. Therefore, JET together with KKPL/PCD decided to support their activity. (2) Support to Isokinetic Sampling JET conducted a supplemental seminar on flue gas measurement, dust measurement, and standardized oxygen concentration of flue gas measurement in April From the discussion at the seminar, it was found out that more technical support to CEM is necessary, although CIDA provided training and equipment through a project in In order to put the provided equipment to practical and effective use, JET explained how to apply isokinetic sampling equipment, and provided answers to the questions of CEM/VEA. (3) Support to Drafting Circulars on Industrial Emission Monitoring Upon the request of CEM, JET contributed to develop draft circulars and provided technical advice on the draft circular especially for Annex 6 on portable flue gas analyzer. In addition, the Vice Director General of VEA/MONRE directly asked JET about the situation in Japan. The contents of the advice were as follows: - Judgment results of environmental violation in Japan identified by CEMS; - Reliability of TESTO (portable air quality/flow measuring and analyzing equipment); - Portable analyzer must be calibrated or checked by standard gas on site at factories with frequency of at least 1 time/1 site/1 day prior to the measurements. If the target factory is changed in the same day, the analyzer must be calibrated and checked again prior to the measurements; - Calibration parameters are NO, SO 2, and CO; - Standard gases in the cylinder used in the field should ensure minimum accuracy of 5%; - Minimum measurement period is 10 min/measurement, with data recorded every 15 s; - If measurement data exceeds the QCVN national technical regulation of emission, the measurement analyzer must be checked by standard gas after the measurement; and - If measurement data is less than 120% of the QCVN, MONRE/DONRE would not issue the penalty. 2-57

78 2.3.3 Provision of Policy Recommendations for Drafting the New Decree on Waste and Scrap Management Following the approval of the revised LEP 2014 at the National Assembly of Vietnam, VEA/MONRE started to draft the new Decree on Waste and Scrap Management, by appointing the Waste and Environment Improvement Department (WENID) as secretariat. The new decree intends to cover various fields in terms of waste defined in LEP 2014, including air pollution or emissions. The decree was planned to be enacted at the beginning of 2015, simultaneously with LEP 2014, although the final approval of the Prime Minister on the decree is still under process as of February 2015 (at the time of preparation of this report). KKPL/PCD contributed to the drafting works at the initial stage, since air pollution control is one of the major mandates of KKPL/ PCD. JET assisted in policy formulation for air pollution control which is to be incorporated into the new decree through joint works with KKPL/PCD. Among others, KKPL/PCD together with JET organized a free discussion meeting on the draft decree on September 5, 2014 under the authority of the Deputy Director of PCD. Invited in the meeting were MOIT, WENID, CEM, Da Nang EPA, JICA Vietnam, and national experts from universities/ institutes/ industrial associations. The agenda for the meeting is as shown below. Agenda of the Free Discussion Meeting on the Draft Decree on Waste and Scrap Management (September 5, 2014) Introduction Presentation Free Discussion Objectives of the Meeting Outline of Provisions and Articles on Air Pollution Control in the New Decree (Draft) Deputy Director of PCD KKPL/PCD All Participants Comments from the JICA Expert Team JET Closing Conclusions and Remarks Deputy Director of PCD Since scrap management (import and export) in Vietnam is also one of the administrative mandates of KKPL/PCD, the discussion included such aspects of the new decree in addition to the above. Besides, KKPL/PCD and JET attended the workshops for the draft decree held by WENID on June 12, 2014 in Hai Phong and on June 20, 2014 in Da Nang Coordination with Other JICA-related Projects, JICA Advisors, and Other Donors Activities The Project aims to establish coordination with other JICA-related projects and projects funded by other donors in order to realize effective technology transfer and fruitful outcome of the Project. (1) Coordination with JICA Advisors and Other JICA-related Projects 1) Coordination with JICA Advisors From October 2012 to the end of June 2014, a policy advisor dispatched from the Ministry of the Environment of Japan (MOEJ) worked at MONRE. For identification of the current status, progress, and issues of amending the LEP, JET and the advisor had several opinion exchange 2-58

79 meetings. Especially, regarding the new Decree on Waste and Scrap Management, JET and the advisor contributed to input the policy recommendations especially on the part of air pollution control in the decree. In the meantime, the advisor attended some topics of the Technical Instruction and Consultation under Output 1, and gave useful information from the aspect of the officer of the Japanese ministry. The new policy advisor was dispatched from November 2014 as the previous advisor s successor. JET met and had opinion exchange meetings even the advisor was in Japan, at the government building of MOEJ in October After the advisor came to Vietnam, JET has maintained constant communication with the advisor. 2) Coordination with Other JICA-related Project The Project collaborated with JICA s Science and Technology Research Partnership for Sustainable Development in Vietnam (SATREPS-Vietnam). On July 25, 2014, JET exchanged information and opinions with the SATREPS-Vietnam team from Osaka Prefecture University regarding the air pollution situation in Vietnam and air quality monitoring data in HCMC. The SATREPS-Vietnam team provided various recommendations to the Project activities. JET took them into consideration after the meeting with the Project. After discussion between the Project and JICA s SATREPS-Vietnam teams, air quality monitoring data were provided as internal information. JET learned from the internal information and utilized such for the Project activities especially for Output 2. (2) Coordination with Other Donors Activities 1) Hanoi Urban Transport Development Project (HUTDP) Funded by the World Bank Hanoi DOT/Hanoi City PC invested in the HUTDP under a loan from the World Bank and Vietnamese counterpart fund. Mobile emission sources have been contributing to air pollution in Hanoi City. Basically, mobile emission sources are managed by DOT. Therefore, cooperation between DONRE and DOT is very important for AQM activities. That is to say, it is important to have opinions and technical exchanges between the Project and HUTDP for formulating the roadmap of the Project activities. There are four sub-components relating to AQM, namely, AQM equipment, environmental monitoring, mobile source emissions inventory, and exposure study. The opinion exchange meeting with the members of HUTDP is summarized in Table Table Summary of Meeting with HUTDP Date Oct. 28, :00-15:30 Place Office of HUTDP <Planning Division of the HUTDP Management Unit> Hearing Targets Objectives of the Hearing Proceedings 1 Deputy head and two staff To understand the activities and share lessons from the sub-components relevant with AQM, and to discuss the possibility of harmonization between the JICA project and HUTDP. 1. Explanations of the JICA Project for institutional development of AQM in Vietnam. 2. Explanations of reasons for contacting (Referential documents were shared). 3. Hearing with the divisions about the project. Summary of the Findings <Summary of the project> Hanoi DOT/Hanoi City PC invested in the HUTDP under the loan from the World Bank and Vietnamese counterpart fund. A project management unit (PMU) has been set up and assigned by Hanoi DOT to execute the operation of HUTDP. Therefore, the PMU on behalf of Hanoi DOT directly cooperates with the other departments under the Hanoi City PC for the implementation of HUTDP. The project has three major components with 80 sub-components. The three major components are as follows: 1. Construction of bus rapid transit (BRT); 2. Institutional development for urban transportation (DOT, Department of Public Security and Traffic Inspectors); and 3. Construction of Ring Road No. 2. There are four sub-components relating to AQM. The activities and current progress of each sub-component are presented below. 1. IS 12: AQM equipment 2-59

80 2. IS 05: HUTDP environmental monitoring 3. IS 01a: Mobile source emission inventory 4. IS 01b: Exposure study < Requested by the JICA Project > Data sharing is requested, especially for the results of the air quality survey to the Planning Unit. Share of the TOR of 01a is requested. Invitation of PCD to the training courses organized by HUTDP is requested. < Requested By HUTDP > Early involvement of Hanoi DONRE in the JICA Project in order to facilitate information sharing and cooperation between the two projects. Source: JICA Expert Team JET and/or the national staff of JET joined the kick-off workshop and training on mobile emission sources in Hanoi City organized by HUTDP on January 8 and 9, The objective of this training was to train officials about the method of mobile emission sources inventory in Hanoi. The training program was conducted by an expert from the Norwegian Institute for Air Research and his national staff. The managers and staff of Hanoi DONRE also participated in the above workshop. It is recommendable for Hanoi DONRE to enhance its collaboration with HUTDP in order to realize effective activities for AQM planning or environmental protection planning (AQM field) based on the roadmap under Output 2. 2) The Project for Clean Air for Small Cities in the ASEAN Region Funded by GIZ This GIZ project invested by GIZ contains subprojects in Vietnam. One major component was developing a roadmap for a clean air plan (CAP). They developed a roadmap for CAP in Bacn Ninh Province in November 2012 and Can Tho City in September In Hanoi, an opinion exchange meeting with the members of the Project for Clean Air for Small Cities in the ASEAN Region was organized as summarized in Table Table Summary of Meeting with the Project for Clean Air for Small Cities in the ASEAN Region Date Nov. 1, :00-16:00 Place Office of National Coordinator of the Project <-ASEAN-German Technical Cooperation-The Project for Clean Air for Small Cities in the Hearing Target Objectives of the hearing Proceedings ASEAN Region funded by GIZ> One national coordinator for Vietnam To understand the activities and image of the roadmap in the Project for Clean Air for Small Cities in the ASEAN Region, especially in the activities for developing a roadmap towards a clean air plan for Bac Ninh, Vietnam. 1. Explanation of the JICA Project for institutional development of AQM in Vietnam. 2. Explanation of the reasons for contacting. 3. Hearing about the project, especially the development of a roadmap toward a clean air plan for Bac Ninh Province. Summary of the Findings < Summary of the project > The Project for Clean Air for Small Cities in the ASEAN Region (the GIZ Project) invested by GIZ contains subprojects in Vietnam. One major component is to develop a roadmap for a clean air plan (CAP). <Targets> Two cities, Ba Ninh City and Can Tho City, which MONRE and GIZ have been selected for implementing the subprojects. <Roadmap development> Started last year and completed by roadmap mission from GIZ after fact finding. Air pollution from dumpsites has been considered with the request from the People s Committee of Bac Ninh City, which needs rehabilitation or closed old dumpsites. <Development of clean air plan> Started first in Bac Ninh Province in September After about one year of baseline surveys, a detailed plan will be developed. <Requested by the JICA Project and national coordinator of the project > It is requested to share useful information for the projects. <Advice from the national coordinator of the project > It is better to utilize the action plan on AQM of each DONRE. 2-60

81 Hanoi DONRE will implement the HUTDP sub-component 01 to develop the inventory from December 2013, which will be supported by the Norwegian company NILU. Source: JICA Expert Team The person in charge to develop the one for Can Tho City is the same person to implement the survey in HCMC of the Project, Head of Air Pollution and Climate Change Department of Institute for Environment and Resource, Vietnam National University HCMC (IER). Therefore, during the survey, JET, IER, and HCMC DONRE had a series of discussions for roadmap formulation. The survey in HCMC under the Project will be a trigger to foster more opportunities of joint works hereafter between HCMC DONRE and IER as an external expertise resource for substantiating the roadmap of Output 2. 3) The Project for Strengthening Capacity on Natural Resources and Environment Policy and Law Development and Implementation Supported by the United Nations Development Programme (UNDP) UNDP launched the captioned project from the beginning of 2013 with ISPONRE as counterparts, and held the inception workshop on December 12, KKPL/PCD, JET, and the JICA Vietnam office attended the workshop, and found out that this project has a component for improving legal framework for curbing air pollution. Although after this workshop, KKPL/PCD and JET have not heard any remarkable progress on the UNDP-ISPONRE project. There may be an opportunity for collaboration between this project and with KKPL/PCD from in terms of institutionalizing the outcomes under Output 2 of the Project. 4) The Project for the Establishment of the Pollution Control Manager System in Vietnam The Japan Environmental Management Association for Industry (JEMAI) implemented this project under a contract with the Ministry of Economy, Trade, and Industry (METI) of Japan from 2011 to The first year was a feasibility study for the establishment of PCM system in Vietnam. It focused on the area of Hanoi City. The feasibility study report was disclosed at METI s website. JET and KKPL/PCD discussed about the PCM system in Vietnam based on this report and utilized it to make the TB on Practical Control of Point Pollution Sources. From the second year to the final year (total of four years) of the JEMAI study, support was mainly provided to the Vietnam Academy of Science and Technology/Institute of Natural Products Chemistry (VAST/INPC). JET had exchange opinions about the PCM system in Vietnam with the team of JEMAI. This discussion contributed to the finalization of the TB on Practical Control of Point Pollution Sources. 2-61

82 2.4 Capacity Assessment Objective and Method of Capacity Assessment Capacity assessment (CA) for evaluating the present capacity on the policy, social system, organization, and personnel concerning or involved in air pollution control and AQM were conducted at the commencement of the Project. The CA was carried out in accordance with JICA s approach on capacity development. The targets of the CA include the Division of Pollution Control for Air and Recycling Materials (KKPL) of PCD, as the main counterpart of the Project. The DONREs of Hanoi City and HCMC, which are participating in the roadmap formulation process, were also targeted for CA in order to identify the current status and challenges through the simplified CA. The CA at the national level (KKPL/PCD) was conducted by JET, and the simplified CA for the DONREs of the two cities were conducted by the local consultant. Both CA at the national level and city level were conducted by interviewing individual personnel of the counterparts in charge of AQM and their superiors (management level) at the organizational level. The outline of the CA is shown in Table Table Outline of Capacity Assessment Item (1) Capacity Assessment at the National Level (KKPL/PCD) (2) Capacity Assessment for DONREs of Two Cities (Simplified CA) Source: JICA Expert Team Target Organization PCD/KKPL DONREs in Hanoi City and HCMC Implementing Agency JICA Expert Team Subcontract base Objective Identification of current capacity, advantages and disadvantages, recommendations for solving challenges through the Project activities, and monitoring capacity change. Identification of the current status and challenges (simplified CA) Method Interview survey Interview survey (with questionnaire sheet) Summary of Capacity Assessment Results and the Project Activities based on CA (1) Results of Capacity Assessment The basic organizational information collected through the interview survey of KKPL/PCD by JET is shown in Table Table Organizational Information on KKPL/PCD Item Organizational Information on KKPL/PCD Establishment Established as the division for air pollution, waste and toxic chemical disposal incidents in 2009 when PCD was established. Transformed to the Division of Pollution Control for Air and Recycling Materials (KKPL) in Budget Budget is distributed every year upon regular and typical tasks assigned, including budget for air pollution control, 10% of the annual budget was cut in 2013 due to the expenditure saving policy of the government. Personnel VEA decides the number of employees. The personnel and manager of KKPL are assigned by the Director of PCD. Current Activities Conduct emission inventories for the selected major industrial sectors, to be completed in Make a guideline for developing emissions inventories for industries. Develop the National Action Plan on Air Pollution Control up to 2020 (planned to be approved by the Prime Minister in 2014). Revision of the LEP. Handle air pollution incidents as assigned by VEA. Source: JICA Expert Team 2-62

83 JET interviewed the key personnel of KKPL in order to understand the capacity of KKPL in terms of AQM at the commencement of the Project, from individual, organizational, and institutional aspects. It is important to conduct CA jointly with KKPL/PCD, in the sense of reaffirming their capacity. The results of organizational CA collected from the staff of KKPL are synthesized and summarized in Table The results of individual CA contain personal information; therefore, JET utilized such information for the activities and are not described in this report to protect personal information. Table Questions and Results of Capacity Assessment Topic Sub-topic Basic Information and Basic Skill Goal of organization Role of organization Activity Resource Technical Skill Staff s technical skills, training Goal of organization and evaluation method of achievement Strategy and planning to achieve the goals Role of the organization in the process of legal document issuance Output of organization Current activity Planned activity Human resources Budget Technical skill level and its balance of staff Questions/ Assessment Target Contents Are there any evaluation indicators of achievement KKPL's goals, improvement of legal systems for proper management practices, in the field of AQM? Are there any plans for achieving the goals? And what kind of plan does KKPL have? How does KKPL contribute to the development of legal documents? How does KKPL contribute to QCVN development? What are KKPL's outputs in the field of AQM? What are the current major activities and their schedule? What are the main planned activities? Is there any human development system in KKPL? If yes, what kind of system is it? How much is the annual budget? And what is the percentage of the budget allocated to AQM activities? How different are the technical skills among KKPL staff, especially in the field of AQM? And how are 2-63 None Answer of KKPL/PCD 1) Development of the National Action Plan up to 2020 considering AQM. And its approval by the Prime Minister until ) Development of regulation for AQM. Legal document issuance process is as summarized below, and KKPL/PCD is involved in 3) and 4) of the following process: 1) Each department proposes/suggests legal documents; 2) Approval of PCD, VEA; 3) KKPL/PCD is instructed to create/modify a legal document; 4) KKPL/PCD grasps the current situation, summarizes the issues/difficulties, and gathers information from other ministries and agencies; and 5) Approval of PCD, VEA, MONRE First, the Division of Monitoring and Environmental Standard develops a draft QCVN. Then, KKPL makes comments. And, MOST checks the contents. Finally, MONRE s leaders approve the QCVN. KKPL also can propose/suggest a draft QCVN. Initial database, evaluation reports. Air Environment: 1) The Project for Institutional Development of Air Quality Management by JICA. 2) Implementation of development of emissions inventories for target subsectors in Vietnam within ) National Action Plan on Air Environmental Pollution Control. Others: 1) Pollution control during the import and use of scraps, plastic bags. 2) Environmental management in the industrial zone. 1) To propose/suggest, and develop legal documents related to AQM. There is only freshmen training. It is better for the staff to participate in the training, but it is difficult due to budget and manpower shortage. Upon tasks assigned by PCD leaders every year. It is necessary to raise the technical level of staff. Only technical transfer to freshmen/women is implemented.

84 Topic of technical skill and knowledge Implementati on ability/ coordination ability (in the case of National Action Plan Development) Sub-topic Training External Environment Obstacles for achieving the goal Relation with external organizations Job assignment system Self-study support Understanding of the current schedule of the planned departments and staff Cooperation with the planned departments staff in the implementation stage Planning stage Implementation stage Cooperation with other divisions Source: JICA Expert Team Cooperation with other departments Cooperation with other ministries or agencies Questions/ Assessment Target Contents the skills transferred to other staff? Is there any training system for new staff or staff who starts to support the work in the field of AQM? If yes, what kind of system does KKPL have? Is there any other training system to improve technical skills on AQM? Is there any job assignment system among ministries of other governmental organizations? Is there any opportunity to study outside the division such as study abroad, seminar, training, etc.? Does KKPL have legal documents necessary to improve technical skills and increase technical knowledge by self-study? Is there any system to encourage self-study? Does KKPL have ideas about detailed activities, needed capacity, and incentives for planned departments and staff so that the National Action Plan could be surely implemented by them? Does KKPL understand the current situation and activities of the planned organizations and staff? Can KKPL develop an idea for coordination with the planned departments and staff in the implementation stage? What are the obstacles in the planning stage? What are the obstacles in the implementation stage? How does KKPL cooperate with other divisions? How does KKPL cooperate with other departments? How does KKPL cooperate with other ministries/agencies and private companies? Answer of KKPL/PCD Support to training participation as much as possible. For example, there is one record that one staff of KKPL was dispatched to Hong Kong for about one year to participate in the training organized by Clean Air Asia. There are only a few cases of temporary job transfer among ministries. KKPL has the necessary legal documents. None No idea so far because the plan is being developed and has not been approved yet. The implementation of specific activities will be considered after the National Action Plan has been approved. The staff of KKPL have grasped the activities within departments under MONRE, but have not grasped the activities related to AQM of other ministries. It is possible to develop an idea for coordination with planned departments, for example, to hold advisory meetings and discussions with experts, and to exchange opinions about the contents of the plan at the provincial level with DONREs and other organizations. Lack of human resources and budget. Reason: It is not receiving sufficient human resources and budget allocation because MONRE s upper management has more interest in water quality and waste than in air pollution. KKPL proposes a number of projects every year. However, it is not accepted because of the reason that is not necessary now. It is difficult to ensure human resources and budget. Authority/mandates overlap with other ministries, sharing of authority/mandates is ambiguous. To exchange information and opinions as needed. It is relatively easy to cooperate. When KKPL needs information from other departments, KKPL exchanges through workshops and exchanges through letters in general or friend-basis sharing. To ask information through letters to other ministries. To request an investigation by a consultant contract. (2) Project Activities based on the CA Results at the National Level (KKPL/PCD) Through the CA implemented by JET described above, it was found out that KKPL/PCD needs to obtain technical knowledge and experience in terms of AQM. However, due to the limited budget and human resources, there are only a few opportunities to develop their own capacity on AQM. JET implemented the CA and modified the direction of instructional 2-64

85 methods described on the ICR at the commencement of the Project. The direction of the Project applied based on the CA is shown in Table Table Direction of the Project Activities based on CA Topic Assessment Results and Direction of the Project Activities Basic Information and Basic Skill <Strategy and planning to achieve the goals, evaluation method of achievement> There are work plans for the short term and long term. Through capacity development Goal of organization of the Project, JET supports prioritization and lists the works to be achieved towards the goal of KKPL through the creation of the TB list. < Role and output of the organization in the process of legal document issuance> KKPL/PCD proposes legal documents within its assigned functions and mandates, and is involved in opinion exchange for legal documents proposed by other organizations (departments). Role of organization Through the capacity development of the Project such as TB preparation, the staff of KKPL will be able to acquire the necessary technical knowledge, such as standardized oxygen concentration in flue gas and regional coefficient. Such technical knowledge would contribute to the capacity of KKPL staff to propose and suggest legal documents. <Current and planned activities> The key activities of KKPL/PCD in terms of AQM field during the Project have been revised in the LEP 2005, development of the National Action Plan and development of emission factors, inventories and its guideline of the target selected subsectors. Activity Through the capacity development of the Project, JET provided technical advice and technical assistance for the development of the National Action Plan and emissions inventories. As for emissions inventory development, consideration to standardized oxygen concentration as well as review/check of the reliability of the collected questionnaires are enhanced. <Human resources and budget> The number of staff and amount of budget are not sufficient, and the knowledge on AQM of each staff is also not sufficient. Resource In addition to the capacity development of the Project, JET shall implement the activities that contribute to ensure necessary budget to AQM such as operation and maintenance cost of the automatic air quality monitoring stations. Technical Skill <Technical skill level and its balance of staff> Technology level for AQM of each staff is to be improved for the development of the Staff s technical legal system. skills Through capacity development of the Project, JET together with KKPL devotes its effort to improve the level of technical skill related to AQM of each staff, and to improve the self-directed learning environment in a sustainable way. Implementation ability/ coordination ability (in the case of National Action Plan Development) External Environment Obstacles for achieving the goal Relation with external organizations <Understanding of the current schedule of the planned departments and staff> The National Action Plan is designed to determine the outline of the AQM plan and air pollution control plan in Vietnam. After the National Action Plan is approved, it is expected to develop detailed plans as many projects listed on the National Action Plan proposed by KKPL. Through capacity development of the Project, coordination capability and capacity to implement projects planning for new projects have been focused. In addition, JET supports KKPL for better development of the National Action Plan. <Planning and implementation stage> Human resources and budget are not sufficient because AQM has not been prioritized by MONRE. In addition, the authority/mandates have been overlapping with other ministries. Therefore the tasks of KKPL have not been identified clearly. Through capacity development of the Project, JET need to transfer technical knowledge to make feasible plans of projects for air environment. Moreover, by clarifying the authority/mandates of other ministries and agencies, prioritization of VEA/MONRE to the field of AQM will be improved. <Cooperation with other divisions/departments/ministries/agencies> Cooperation within KKPL is sufficient. On the other hand, cooperation outside of KKPL is not sufficient. Because it is necessary to make an official letter or appointment bureaucratically, information sharing and cross-sectoral approach of the AQM field are necessary to be improved. Through workshops and seminars in the Project, there are many opportunities to exchange opinions and information with other ministries and departments. Therefore, the cooperation mechanism with other ministries/agencies has been enhanced through 2-65

86 Topic Source: JICA Expert Team the Project. Assessment Results and Direction of the Project Activities (3) Summary of CA Results for the DONREs of Two Cities (Simplified CA) 1) Results of CA for the DONRE of Hanoi City In order to understand the capacity, current status, and challenges of AQM in Hanoi EPA, a simplified CA was conducted as a subcontract survey under the Project. Hanoi EPA is planning the objectives of AQM in 5-10 years but it is in the process of development and appraisal. Therefore, Hanoi EPA could not provide this document in detail. The general objectives are to reduce air pollutant emissions from businesses, and to enhance communication, observation, and monitoring implementation. The results of the simplified CA are summarized in Table Table Summary of Simplified CA Results on Hanoi EPA and Subordinate Divisions Topic Answers from Hanoi EPA and Subordinate Divisions Hanoi EPA is planning the objectives of AQM in 5-10 years. But it is in the process of development and appraisal; therefore, they could not provide this document in detail. The general objectives are to reduce emissions from businesses, and enhance communication, observation, and monitoring implementation. Goal and Plan Sub-divisions under Hanoi EPA have no plans on AQM in 5-10 years due to not being tasked in detail. An AQM plan of DONRE and EPA is not approved yet. Sub-divisions under Hanoi EPA will perform the functions and duties when assigned by its superior. Hanoi EPA has 20 engineers, and six bachelor s degree holders related to or participated in managing air quality, of which 19 staff has specialized training related to AQM. Resources Only about 2% of the budget is allocated for this task. No database has been completed, and monitoring equipment is not enough to implement the task. Hanoi EPA needs to strengthen their staff s skills on AQM. Needs It will be better to increase the number to 30 engineers and 10 bachelor s degree holders. All 40 staff need specialized training on AQM. Strengthen training intensively for personnel of AQM, and find solutions to strengthen and upgrade equipment. Countermeasure Hanoi EPA will comply with the plan of DONRE and the policy/planning of the Hanoi City PC. Source: Survey results of the Project 2) Results of CA for DONREs in HCMC In order to understand the capacity, the current status and challenges for AQM in HEPA, a simplified CA was conducted as a subcontract survey under the Project. HEPA has goals for AQM for the next five or ten years based on Action Plan No. 34-CTrHD/TU, dated November 27, 2013, of the Party Committee of HCMC, and the implementation of Resolution No. 24-NQ/TW of the 7th Conference of the Central Executive Committee of XI in response to climate change, resource management, and environmental protection. The results of the simplified CA are summarized in Table Table Summary of Simplified CA Results on HEPA and Subordinate Divisions Topic Answers from HEPA and Subordinate Divisions HEPA has goals for air quality management for the next five or ten years. The goals are based on Action Plan No. 34-CTrHD/TU, dated November 27, 2013, of the Party Committee of HCMC on the implementation of the Resolution No. 24-NQ/TW of the Goal and Plan 7th Conference of the Central Executive Committee of XI in response to climate change, resource management, and environmental protection. The key objective related to air pollution is as follows: by 2020, ensure 90% of air emissions in industrial zone/cluster across the city are treated to meet environmental 2-66

87 Topic Answers from HEPA and Subordinate Divisions regulations. The Planning and Administration Division has their own goals for AQM for the next five or ten years. The goals are to plan and build a network of air quality monitoring for HCMC. There are three divisions/center under HEPA which have the function of AQM, as follows: (1) Environmental Pollution Inspection and Supervision Division under HEPA. Resources (2) Centre for Environmental and Natural Resources Monitoring and Analysis (CENMA). (3) Evaluation and Assessment of Environmental Quality Division. More staff is needed because their number is not enough. There are about 90% of tasks completed on time and before schedule, and about 10% of tasks related to AQM behind schedule. HEPA needs more data related to air emissions for stationary sources (for the industrial sector) and information about air quality monitoring in HCMC and provinces around HCMC, such as Long An, Tay Ninh, Binh Duong, Dong Nai, and Ba Ria Vung Tau. Needs Currently, HEPA do not have enough air emissions inventories and information about air quality monitoring in HCMC and surrounding provinces for studying/assessing the impacts by each source category on air pollution in HCMC. The competency/capacity of staff on AQM needs to be improved. They need five engineers, six bachelor s degree holders, and three technicians for conducting AQM. HEPA needs 18 engineers, 16 bachelor s degree holders, and 16 technicians for conducting AQM and for achieving the goals in the long term. HEPA will recruit more staff as needed. HEPA will send their staff to getting more professional training on AQM. Countermeasure HEPA do not have plans to prepare the above needs because HEPA has no detailed roadmap for such. When HEPA prepares a detailed roadmap, HEPA will be able to prepare for the needs. Source: Survey results of the Project Improved and Enhanced Capacity through the Project Activities (1) Individual Capacity Improvement Relating to AQM JET observed, in the course of the Project implementation, that the individual capacity of staff of KKPL/PCD improved as follows: The staff of KKPL acquired technical knowledge through TB preparation and a series of seminars called technical instruction and consultation, with topics such as i) standardized oxygen concentration in flue gas, ii) scientific background of regional coefficient, and iii) system for point source control. Such technical knowledge would contribute to the capacity of KKPL staff to propose and suggest the National Action Plan in the next term, as well as legal documents such as decrees and circulars, by themselves. The staff of KKPL received technical advice and technical assistance from JET to contribute for the development of industrial emissions inventories. Consideration to emission load calculated by emission factor and/or measured data as well as reviewing/checking the reliability of the collected questionnaires are important. Also JET and KKPL/PCD discussed the questionnaire items, process for industrial emission, human error to input information, and so on. This knowledge is based on the experiences of JET. Not only the staff of KKPL, but also the staff/officials of another organization (CEM) under VEA had technical support in finalizing legal documents concerning i) isokinetic sampling of dust, ii) error and accuracy of portable flue gas analyzer, and iii) importance of on-site calibration of flue gas analyzer. Not only the staff of KKPL, but also the officials of PCD/DONREs realized how important it is to maintain automatic air quality monitoring stations and to plan renewal considering the life of air quality analyzer with sufficient budget necessary 2-67

88 for such preparedness. This knowledge would contribute in preparing the budgetary plan for air quality monitoring stations. The staff of KKPL as well as key departments under VEA had various opportunities in the course of the Project activities to cultivate their knowledge on the mechanism and interrelationship of the legal system to realize air pollution control. The technical introduction and consultation (Part 1) was provided to seize the opportunity of initiating such discussion on legal system development and interrelationship, and the cultivation of knowledge has been enhanced in the whole time during the Project. The technical knowledge obtained from the above will increase the capacity of the staff working in the AQM field in VEA, especially in KKPL/PCD, in order to ensure the accountability of administrative duties and mandates toward the internal/external stakeholders with firm technical background and persuasiveness. (2) Institutional and Administrative Improvement of Main Counterparts Bodies JET observed, in the course of the Project implementation, that i) the presence of KKPL/PCD in VEA is remarkably rising as the focal point of administration of air pollution control, and ii) KKPL/PCD greatly contribute for the smooth operation of the Project. It can be said that the capacity of KKPL/PCD in elaborating legal/administrative documentation has been improved, through i) practical involvement of technical expertise into drafting documents, and ii) substantial coordination by ironing out the interests raised from the various departments/organizations concerned. 1) Institutional Aspects The capacity of the main counterpart bodies in terms of the following institutional aspects capacities have been improved: KKPL/PCD developed and finalized the National Action Plan for Air Pollution Control to 2020 in Vietnam under the initiative of VEA, and the plan was approved by the Prime Minister. The plan defines the strategy and mandates of VEA/MONRE in this field, and essential roles to achieve the goals of the plan are committed by KKPL/PCD. As mentioned earlier, KKPL/PCD plays a key role for the preparation of the draft Decree on Waste and Scrap Management under LEP 2014, in close collaboration with WENID. KKPL/PCD developed and input the provisions on air pollution control into the decree, including integration of expertise standpoints through examining technical and financial feasibility by making such opportunities as free discussion meetings with reliable experts and administrative authorities concerned. KKPL/PCD is preparing the draft circular for emissions inventory for stationary pollution sources. Through the Project implementation, KKPL/PCD implemented the emissions inventory survey and collected information from selected subsectors. These experiences will contribute to development of circulars. Through the prioritization activities for the TB list, the works to be achieved toward the goals of KKPL became obvious. 2) Administrative Aspects The capacity of the main counterpart bodies in terms of the following administrative aspects have been improved: In the stage of preparing and organizing the series of technical instruction and consultation under Output 1, KKPL/PCD has devoted its maximum efforts to involve the other departments/bodies of VEA related to air pollution control, such as CEM and DPL, into the series of consultation. These efforts will no doubt contribute to the next stage of performing the activities as VEA controls/reduces air pollution 2-68

89 administratively. In addition, such initiative is gradually maturing the presence of KKPL/PCD as the leading body of VEA on air pollution control in Vietnam. KKPL/PCD has been facilitating the activities of Output 2 with close communication with the DONREs of Hanoi City and HCMC, via the People Committees and VEA. Facilitation includes supervision and management of surveys implemented by the Project, planning and conducting of mini-workshops, initiation and enhancement of brainstorming for formulating the roadmaps under Output 2, etc., jointly with the DONREs. JET has been observing that the DONREs of the two cities are gradually recognizing the reliability and dependability of KKPL/PCD in the administrative functions of air pollution control. Consequently, KKPL/PCD will be acknowledged steadily by the DONREs as the focal point in VEA in this field. (3) Improvement of Organizational Cooperation Mechanism Not only AQM but also overall environmental management requires effective organizational cooperation mechanisms for interministerial cooperation including cooperation within a ministry (VEA/MONRE), intergovernmental cooperation between the national level (MONRE) and city/provincial level (DONRE), and cooperation between the ministry (MONRE) and other organizations (e.g., universities, institutes). Such kind of organizational cooperation mechanisms has been improving through the Project implementation. It can be concluded that the capacity of KKPL/PCD in playing the key roles of coordination among various organizations related to the AQM field has improved, considering the achievement of enhancing the organizational cooperation mechanism through the Project as demonstrated or implied below. 1) Interministerial Cooperation within VEA/MONRE JET together with KKPL/PCD decided to support CEM s activity of drafting circulars on industrial emission monitoring. PCD and CEM had already built a good relationship before the Project started, but through this supporting activity, their cooperation, especially on the activities related to AQM, has been improved. In addition, JET and KKPL/PCD had the chance of sharing their opinions through the Project activities. DOST of MOIT participated in the Free Discussion Meeting on the Draft Decree on Waste and Scrap Management (September 5, 2014). 2) Intergovernmental Cooperation between the National Level (MONRE) and City/Provincial Level (DONRE) The DONREs of Hanoi City and HCMC are among the Project counterparts. Thus, through the Project activities, PCD and the DONREs had opportunities to communicate closely. Also, the Vice Director of Da Nang EPA joined the Free Discussion Meeting on the Draft Decree on Waste and Scrap Management (September 5, 2014). Through the activities of emissions inventory development together with JET, KKPL/PCD facilitated the inventory surveys with Ha Nam DONRE, Thai Nguyen DONRE, Quang Ninh DONRE, Kien Giang DONRE, Quang Binh DONRE, Hai Duong DONRE, Hai Phong DONRE, Da Nang DONRE, and Tay Ninh DONRE. In addition, PCD/KKPL invited seven provincial and city DONREs and had exchanges of opinions about the Project and the draft circular on emissions inventory. Through these activities, intergovernmental cooperation between the central level (MONRE) and provincial/city level (DONRE) have been improved. 3) Ministry (MONRE) and Other Organizations (e.g., universities, institutes) Through the survey implemented by the Project, KKPL/PCD facilitated and had good communication with the local consultant, the Institute for Resources, Environment and Community Development (RECO), the Institute of Water Engineering and Environmental Technology (IWEET), and the Institute of Environment and Resources (IER). In addition, the Center for Environmental Engineering and Chemical Safety, Vietnam Steel Association, 2-69

90 Institute for Environmental Science and Technology of Hanoi University of Technology, Vietnam Clean Air Partnership (VCAP), Ho Chi Minh University of Natural Resources and Environment, and Institute for Tropical Technology and Environmental Protection participated in the Free Discussion Meeting on the Draft Decree on Waste and Scrap Management (September 5, 2014). The 1 st Overall Workshop (November 11, 2014) was attended by the University of Natural Science of the Vietnam National University, VCAP Viet Nam, Vietnam Steel Enterprise, University of Natural Science, Pha Lai Thermal Power JSC, Environment Center, and Vietnam Institute of Geosciences and Mineral Resources. In the course of further administration of AQM under KKPL/PCD, it is suggested to utilize and promote these improved organizational cooperation mechanisms. 2.5 Process of Document Legalization (1) Amendment of the LEP The amendment of the LEP was approved in the 7th Session of the 13th National Assembly on June 23, The new LEP consists of 20 Chapters, and 170 Articles stipulating the environmental protection activities; policies, measures, and resources to protect the environment; rights, obligations, and responsibilities of agencies, organizations, households, and individuals in environmental protection. The new LEP took effect from January 1, The agency in charge of drafting the LEP amendment is MONRE, while the appraisal committee is the Science, Technology and Environment Committee of the National Assembly. Figure and Figure show the procedure of development of the LEP amendment since it was proposed by the Vietnamese government until it was passed by the National Assembly. 2-70

91 1. Review the implementation of legislation, assess the legal documents related to the LEP (amendment) bill; implement survey, situation analysis of social relationships related to the policy contents of the LEP bill; 2. Study the information, data related to the LEP bill; 3. Prepare the outline of the LEP bill; 4. Collect comments of agencies, organizations, individuals and other objects directly affected by the legal documents; 5. Prepare the statement and documents related to the LEP bill; 6. Coordinate with agencies, organizations concerned to prepare the drafts of guiding documents, instruction for implementation; 7. Making comparison, taking account the international conventions that the Socialist Republic of Vietnam signs or participates Proposing agency: Government of Vietnam (GOV) Appraising agency: Science, Technology and Environment of the National Assembly (NA) Establishment of Drafting Committee (MONRE) Drafting the LEP MOJ examines the LEP bill MOJ examines these issues: a) The necessity of the LEP bill; governing scope and entities of the LEP; b) The compatibility of the LEP bill with the directions, approaches and policies of the party; constitutionality, legality and consistency of the text with the legal system; c) The feasibility of the text; d) The compliance to the procedure of drafting the LEP; đ) The use of language, the drafting techniques; Comments from localities, if any, including the local Group of Delegates to the NA. The Secretary of the Group is responsible for collecting comments (by meetings or letters), summarizing the comments, and submitting to the drafting agency (MONRE). MONRE examines, comments, and revises the LEP bill accordingly, and proposes to GOV GOV examines and comments on the LEP bill, and proposes to the NA Ministries, ministerial-level agencies, state agencies in charge of commenting on the LEP in the fields of their tasks, duties and powers - The drafting agency (MONRE) presents the statement of the LEP bill - Government office reports the comments from members of GOV and comments from examination of the Government Office - GOV considers, discusses, and votes by majority to propose the LEP bill to the NA Figure Procedure for Developing the LEP Amendment (1/2) 2-71

92 The National Council examines these issues: 1) The necessity of the LEP; governing scope and entities of the LEP; 2) The compatibility of the LEP bill with the directions, approaches and policies of the Party; constitutionality, legality and consistency of the text with the legal system; 3) The compliance to the procedure of drafting the LEP; and 4) The feasibility of the text. GOV proposes the LEP bill to the NA National Council, NA Committee examines the LEP bill The Standing Committee of the NA comments on the LEP bill The NA reviews and comments on the LEP bill in the first session meeting The Standing Committee of the NA leads revision of the LEP bill following the comments of the NA - The NA discusses basic contents and major outstanding issues which are still being debated about the LEP bill. - The Standing Committee of the NA directs the Secretaries to compile comments of the Delegates to the NA and prepares basic contents of the bill to propose to the NA as the basis for revision. Hearing comments from people, sectors for major bills Hearing comments at the conference of special Delegates to the NA Standing Committee of the NA submits the revised Law bill after reflecting the comments MONRE examines the GOV, Legal Committee of the NA, MOJ and other agencies review the comments of the Delegates to the NA to support Standing Committee of the NA in revising the draft LEP Discussion at the meetings of local Delegates to the NA The NA reviews and passes the LEP bill amendment on June 23, The President announces the LEP Source: JICA Expert Team, compiled from the Law 17/2008/QH12 on the Promulgating of Legal Documents Figure Procedure for Developing the LEP Amendment (2/2) 2-72

93 (2) New Decree on Waste and Scrap Management The new Decree on Waste and Scrap Management is being developed pursuant to the approval of the LEP amendment. In January 2014, Decision No. 101/2014/QD-BTNMT, on approving the development and promulgation program of legal documents in 2014 within the state management scope of MONRE, prescribed legal documents was issued which listed the new Decree on Waste and Scrap Management as one of the legal documents In March 2014, Decision No. 371/2014/QD-BTNMT, on the establishment of the composition board and editorial team in charge of developing the new Decree on Waste and Scrap Management, prescribed the composition board and editorial team for the Decree on Waste and Scrap Management was issued with the name of person/position. The composition board consists of 12 members including the Vice Minister of MONRE, Vice Director of VEA, and Chairman of the Project. The editorial team consists of 14 members include JCC members of the Project. In June 2014, WENID organized some workshops in Hai Phong, Da Nang, and other cities, to explain the draft decree and collect comments. PCD and JET joined these workshops. After that, the draft Decree on Waste and Scrap Management was disclosed to the citizens through VEA s website. On September 5, 2014, KKPL/PCD and JET organized a free discussion meeting on the draft decree focusing on the air pollution control parts under the authority of the Deputy Director of PCD. MOIT, WENID, CEM, Da Nang EPA, JICA Vietnam, and national experts form universities/ institutes/ industrial associations were invited. It was planned to submit the final version of the draft decree to the Prime Minister by November 15, However, there are some points that need to be solved before finalizing it, such as the overlapping mandates of MONRE and MOC regarding solid waste management. Therefore, enthusiastic discussion was continued until the beginning of In January 2015, as instructed by the Prime Minister, the government office made consultations with governmental members about the draft decree. As of February 2015, the draft Decree on Waste and Scrap Management is on the desk of the Prime Minister for approval. Figure shows the general procedure, with key actions and actual schedule, for developing the draft Decree on Waste and Scrap Management. The actual process was more flexible and complicated. There were many discussions with related ministries, and public comments from the citizens were collected. 2-73

94 Month & Year January 2014 New decree was listed in Decision No. 101/2014 /QD-BTNMT MONRE requests the degree pursuant to the LEP amendment GOV approves the request, and the Prime Minister (PM) assigns the agency in charge (MONRE) GO leads, cooperates with MOJ with participation of agencies concerned to examine the request March 2014, Decision No. 371/ 2014/QD-BTNMT MONRE assigns WENID as the agency in charge June 2014 WS for explanation and collected comments July 2014 Public comments; Disclosed on VEA s website 5 September 2014 Free discussion meeting by PCD and JET November 2014 Continuous discussion January 2015, Collected comments from governmental members February 2015, The Decree is on the desk of the PM WENID leads the drafting procedure Drafting committee and editorial group Drafting the Decree DPL (VEA) and DOL (MONRE) examines the draft MOJ examines the draft GOV GOV votes to approve the Decree (by majority) The PM signs the Decree Comments from internal department (PCD, ISD, etc.) and other ministries, ministerial-level agencies, objects affected by the Decree. Comments can be collected by letter, from meetings, workshops, portals, etc. The Chairman of the Government Office organizes the meetings between MONRE, GOV, MOJ, other ministries, and ministerial-level agencies concerned to discuss outstanding major issues (if any). GOV organizes one or two meetings through the following procedure: 1) Rep. of MONRE presents the draft Decree 2) Rep. of GO raises the topics to be discussed 3) Rep. of agencies concerned comments on the draft Decree 4) GOV discusses the draft Decree Source: JICA Expert Team, compiled from the Circular 46/2014/TT-BTNMT on the Promulgation of Legal Documents under the Scope of State Management of MONRE Figure Procedure and Actual Schedule for Developing the Draft Decree on Waste and Scrap Management 2-74

95 CHAPTER 3 INPUT TO THE PROJECT 3.1 Inputs of the Vietnamese Side Counterpart Personnel (CP) In order to ensure the proper management of the Project, the Joint Coordinating Committee (JCC), Core Technical Working Group (Core TWG), and Expanded Technical Working Group (Expanded TWG) were established based on the official decisions of the Vietnamese side. (1) Joint Coordinating Committee (JCC) The JCC was established based on the Records of Discussion (RD) signed between the Ministry of Natural Resources and Environment (MONRE) and the Japan International Cooperation Agency (JICA) on March 26, Following the required composition of JCC as determined in the RD, the actual committee members assigned from various relevant organizations and agencies are shown in Table Table List of JCC Members Name Position in JCC Position and Organization Vietnamese Side (1) Assoc. Prof. Dr. Bui Cach Tuyen Chairperson Deputy Minister of MONRE, Director General of VEA (2) Mr. Mai Thanh Dung Member Director of PCD, VEA, MONRE (3) Mr. Nguyen Phuoc Hung Member (4) Mr. Hoang Minh Son Member Manager of Bilateral Cooperation Division/ICD/MONRE Deputy Director of Policy and Legislation Department, VEA (5) Mr. Tran Van Khuong Member Deputy Director of DOL, MONRE (6) Dr. Nguyen Minh Cuong Member Deputy Director of ISD, VEA Japanese Side (7) Mr. Norihiko Inoue Member Chief Advisor of the JICA Expert Team (8) Mr. Keiichi Takahashi Member (9) Mr. Fumihiko Okiura Member (10) Mr. Tadashi Suzuki (November 2014) Member (11) Mr. Eiji Egashira (August 2014) Member Deputy Chief Advisor of the JICA Expert Team Senior Representative of the JICA Vietnam Office Senior Representative of the JICA Vietnam Office Senior Project Formulation Advisor of the JICA Vietnam Office Mr. Naohiro Yoshida (August 2014 ) Member Representative of the JICA Vietnam Office Source: JICA Expert Team Total: 11 persons (2) Core TWG Under the JCC, the Core TWG was established to hold regular meetings for the continuous operation of the Project, and is directly receiving technology transfer from the JICA Expert Team (JET). The Core TWG organization is composed of the Vice Director and other officials of KKPL division as shown in Table

96 Name (1)Mr. Nguyễn Đức Hưng (2) Mr. Đặng Văn Lợi (- September 2014) Table List of Core TWG Members Position and Organization Vice Director, PCD Director, Department of Environmental Impact Appraisal and Approval (3) Mr. Nguyễn Hoàng Đức Manager of KKPL/PCD, VEA (4) Mr. Nguyễn Trường Huynh Vice Manager of KKPL/PCD, VEA (5) Mr. Trương Mạnh Tuấn Official of KKPL/PCD, VEA Source: JICA Expert Team Total: 5 persons (3) Staffs of VEA and DONREs who have participated in technical transfer activities During the Project activities, a wide range of technical knowledge and experiences related to air quality management (AQM) have been discussed and exchanged between JET and VEA/DONREs staffs. There were 30 officials from the Pollution Control Department (PCD), 19 officials from the Center of Environmental Monitoring (CEM), and 13 officials from other units under VEA. Twenty-six officials from Hanoi City DONRE and 32 officials from Ho Chi Min City (HCMC) DONRE have participated in technical transfer activities for the Project Operational Expenses Borne by the Vietnamese Side The following counterpart budget for the Project has been provided by MONRE. Table Operational Expenses Borne by the Vietnamese Side Contribution from the Vietnamese side No. Activities (VND 1,000) TOTAL 1 Conducting surveys in some agencies at the central and provincial level to collect information about air pollution control in Vietnam 19,400 20, Collecting and analyzing international experiences (translating 2 materials, documents from English to Vietnamese, and developing 12,000 15, reports) 3 Rent and operating expenses of office, salary for staff implementing the Project activities 111, , Organizing meetings and workshops, finalizing mid-term report of the Project, and organizing JCC meetings and meeting with experts 33,350 40, Developing reports on Project implementation and management expense of counterpart fund 23,370 25, TOTAL 200, , ,000 Source: Decision No. 2524/QD-BTNMT on December 12, 2014 approving Project Document Provision of Facilities The following facilities for the Project have been provided by MONRE: Office space for the Project in Hanoi; Electricity services fee in the Project office; and Other necessary facilities for Project implementation. 3-2

97 3.2 Inputs of the Japanese Side Dispatch of Experts Table shows the names of the experts, their expertise, and the duration of their assignment from the commencement until the end of the Project. In addition, the assignment schedule of JET is presented in Table Table Inputs of the JICA Expert Team Name (1) Mr. Norihiko Inoue (2) Mr. Keiichi Takahashi (3) Mr. Natsuji Sawaki (4) Mr. Hiroshi Nakano Position Chief Adviser/ Air Quality Law and Regulation Deputy Chief Adviser/ Air Quality Management Planning Air Quality Management Technology Air Quality Management/ Coordinator (5) Ms. Aya Mizuno Coordinator (2) Total Contract Non-contract Total M/M Contract 7.87 Non-contract 0.13 Contract Contract 5.90 Contract 8.23 Contract 0.50 Non-contract 0.80 Contract Non-contract 0.93 Note *: Non-contract assignment indicates the assignment in Vietnam paid for by JET. Total M/M includes the M/M allocated for the works in Japan. Source: JICA Expert Team 3-3

98 3-4 Work in Vietnam Work in Japan 1 2 Chief Adviser/ Air Quality Law and Regulation Deputy Chief Adviser/ Air Quality Management Planning 3 Air Quality Management Technology 4 Air Quality Management/ Coordinator 5 Coordinator (2) 1 2 Chief Adviser/ Air Quality Law and Regulation Deputy Chief Adviser/ Air Quality Management Planning 3 Air Quality Management Technology 4 Air Quality Management/ Coordinator 5 Coordinator (2) Position Sub Total (Vietnam) Sub Total (Japan) : Work in Vietnam : Work in Vietnam (additional) : Work in Japan Name Table Assignment Schedule of the JICA Expert Team (JET) Norihiko INOUE Keiichi TAKAHASHI Natsuji SAWAKI Hiroshi NAKANO Aya MIZUNO 5 10 Norihiko INOUE 5 5 Keiichi TAKAHASHI 1 1 Natsuji SAWAKI Hiroshi NAKANO Aya MIZUNO Joint Coordination Committee (JCC) Workshop (WS) Report ICR ICR: Inception Report, PRR: Progress Report, DPCR: Draft, PCR: Source: JICA Expert Team Tet PRR Tet DPCR 5 PCR VN Work Total Japan Work The Project for Institutional Development of Air Quality Management in Vietnam

99 3.2.2 Equipment Procured The total amount of VND 233,549,500 is allocated for the needed equipment for the Project. Table List of Equipment Procured by JET No. Name Description Qty 1 Desktop computer 2 Laptop computer HP DNA(CPU Intel Core i7-3770, Intel HD4000) Product No.: ASUS P8H77-M Serial No.: D9M0A Monitor: HPLV1911 OS: Microsoft Windows 7 Pro 64-bit Application: Microsoft Office Pro 2013 HP Elite Book 8470p Serial No.: CNU321C27J HP ProBook 440G0 Serial No.: 2CE33723J6 3 Projector Sony VPL EX242 Serial No.: Phone/FAX Panasonic KX TG1311 FX Serial No.: 0JBQCO Photocopier Canon IR 2520 Product No.: EXH47658 Serial No.: (21)FQU Laser printer Canon Laser Shot LBP7200cdn Product No.: Serial No.: FAF431 6 Portable scanner 7 UPS 7 Hub for Lan cables Source: JICA Expert Team Canon Scan P-215EN Product No.: M Serial No.: FUA62144 Cost (VND in millions) APC UPS offline DES-1016A Serial No.: QS1B Total Operational Expenses Borne by the Japanese Side The operational expenses borne by the Japanese are shown in Table The total amount of VND 5,401.2 million was allocated for the Project s operational expenses by JICA. Table Operational Expenses Borne by the Japanese Side Cost No. Items (VND in millions) 1 Subcontract Surveys 1,763.5 Breakdown (Survey for Air Quality Management under Hanoi City People s Committee) (570.1) (Survey for Air Quality Management under Ho Chi Minh City People s Committee) (595.7) (Survey for Air Quality Management by the National Level Other Than VEA (Vietnam Environmental (597.7) Agency)) 2 National Experts/Staff (Including transportation fee, accommodation fee, per diem) 1, Other Direct Costs (including WS organization, travel cost for JET and CP, etc.) 1,857.4 Total (1+2+3) 5,401.2 Note : The surveys implemented by the Project for HCMC and Hanoi City were agreed to be paid in USD. The costs for national experts/staff and other direct costs were agreed to be paid in JPY. These items are calculated using JICA s exchange rate in January Source: JICA Expert Team 3-5

100

101 CHAPTER 4 PROJECT MANAGEMENT ACTIVITIES 4.1 JCC Meeting In order to ensure the smooth implementation of the Project activities, a Joint Coordinating Committee (JCC) was established in accordance with the Records of Discussion (RD) signed on March 26, In the RD, it is mentioned that JCC will meet at least once a year or whenever necessity arises. The functions of the JCC are described as follows: (1) To monitor the progress of the Project activities, (2) To review and examine the framework of the Project, and (3) To discuss and advise on major issues that arise during the Project period. The major discussion results of the JCC meetings are summarized in Table Table Discussion Results of the JCC Meetings Actions of Counterpart (CP) No. /Date Theme Major Comments and Requests by JCC and the JICA Expert Team (JET) First JCC Meeting (27 November 2013:VEA Meeting Room No.10) Second JCC Meeting (25 September 2014:VEA Meeting Room A805) -Discussion of the draft inception report (ICR) Discussion of the plan of operation and Project activities -Discussion of the draft PRR - Report the Project achievements in the 1st half of the Project - Propose activities in the 2nd half of the Project 1) JCC agreed with the general contents of the draft ICR. JCC entrusted KKPL/PCD and JET with the task of finalizing the ICR by the end of December 2013 after reflecting the main comments from the participants. 2) JCC officially agreed with the roles, functions, operation mechanism, and components of JCC and PMU. In addition, the Chairmanship of JCC was taken by Dr. Hoang Duong Tung, Deputy Director General of VEA on behalf of the Vice Minister to realize the substantial decision making on the Project implementation. 3) There will be more activities to promote the progress of the Project through various means such as seminars, meetings, and s. 4) The theme and contents of prioritized TBs for the sake of institutional development of air quality management will be discussed with relevant organizations, especially KKPL/PCD and JET, in consideration of MONRE/VEA s roadmap for revising the by-law documents. Then, the TB will be developed as the technical and scientific basis or as the substantial contents for the by-law documents to be drafted (decree, circular, etc.). 5) JCC agreed with the involvement of DONREs as key counterparts for the Project, especially for Output 2. 1) JCC appreciated the achievements, outcomes, and progress of the Project. 2) JCC appreciated other cooperation activities of the Project in the revision of LEP, development of decree, capacity development for PCD, DONREs in Hanoi City and HCMC, technical support to CEM/VEA, report of survey on AQM situation at the central level and local level to figure out the needs and overcome the weaknesses. 3) PCD should consider which of the draft legal documents should be formulated with priority. Hanoi City and HCMC DONREs are requested 1) JET finalized the ICR in December 2013 reflecting all comments in cooperation with KKPL/PCD. 2) JET agreed to this request. 3) CP, mainly KKPL/PCD, and JET continue to have activities to promote the progress of the Project. 4) JET and KKPL/PCD will discuss TBs with relevant organizations. 5) KKPL/PCD shall take the coordinating role to facilitate DONREs and JET participation to implement Output 2. 1) CP and JET continue to implement the Project activities. 2) CP and JET continue to implement the Project activities. 3) CP should consider which of the draft legal documents should be formulated with priority and continue to discuss the TBs with the 4-1

102 No. /Date Theme Major Comments and Requests by JCC Third JCC Meeting (13 March 2015: VEA Meeting Room A805) -Discussion on; a) Achievements of the Project b) Distribution of draft project completion report (DPCR) and project outputs c) Institutionalizati on perspective of the Project s output to strictly follow the schedule of the roadmap development, as clearly defined in the roadmap; what to do and when to finish, point out the necessary cooperation procedures/mechanisms among departments under PPC. 4) Because it was late for the JICA s deadline of submission for the needed survey, JET and KKPL/PCD should prepare a quick proposal for the next cooperation project with JICA. The detailed proposal should be developed later, during examination time by the two governments. 1) The JCC highly appreciates the efforts of both the Vietnamese side and the Japanese side in implementing the Project activities. 2) After the end of the Project, received outputs will be effectively utilized by MONRE. 3) The JCC appreciates other cooperation activities of the Project: i) revision of LEP, development of legal documents (Decree on Waste and Scrap Management, Circular on Industrial Emission Inventory), ii) capacity development for PCD, Hanoi DONRE, and HCMC DONRE, and iii) technical support to CEM/VEA, etc., which contribute to an effective state environmental management in Vietnam. 4) In general, the JCC agreed with the contents of the DPCR. Technical working group was requested to finalize DPCR and the Project outputs by reflecting the comments of all participants. The JCC requested the Project Team to submit the final PCR and outputs including technical products to VEA. Actions of Counterpart (CP) and the JICA Expert Team (JET) JET members. 4) JET and KKPL/PCD should prepare a quick proposal for the next cooperation project with JICA. 1) No actions for this comment. 2) At first, in 2015, MONRE will review, revise, and promulgate six QCVNs based on the Project s outputs and recommendations. Also, the five remaining QCVNs will be under development, revision, and promulgation plan of 2016 by VEA. MONRE reconfirmed its commitment in utilizing the Project's outcomes and will keep JICA updated with the progress of integration of the Project s outputs into the legal system 3) No actions for this comment. 4) The JET should print the report in Japan and deliver/submit it to JICA HQ. VEA can distribute it to the concerned departments/agencies in MONRE and DONREs, for expanding and utilizing the Project outputs effectively. Source: JICA Expert Team 5) This Project shall officially end upon the completion of the PCR. 5) No actions for this comment. 4.2 Overall Workshop The overall workshops (WSs) were held during the Project to share findings, outcomes, and lessons derived through the Thematic Briefs (TBs)/roadmaps preparations, with the relevant stakeholders involving the related ministries and departments. The 1st and 2nd overall WSs were held on November 11, 2014 and March 13, 2015, respectively, as shown in Table Table Overall Workshops No. /Date Main Topics Main Comments/ Conclusions 1st WS (11 November 2014: Song Hong Resort, a) Share the project s achievements, discuss the state s management experiences in air pollution control and solutions - VEA highly appreciates the achievements, outcomes, and progress of the Project. - VEA encourages PCD, JET, and two DONREs to disseminate the achieved reports and results to 4-2

103 No. /Date Main Topics Main Comments/ Conclusions for capacity development in terms of air pollution control in Vietnam; b) Introduce and collect opinions about the draft circular guiding the implementation of industrial emission inventory. Vinh Phuc Province) 2nd WS March (20 March, 2015: Daewoo Hotel, No. 360 Kim Ma, Ba Dih, Hanoi Source: JICA Expert Team Explanation on the results of the Project (TBs and others), information sharing, and recommendations for the development of emission inventory in Vietnam. Recommendation for inheriting, expanding, and improving the Project s outputs in Vietnam. other provinces to broaden the achievement of the Project. - The termination of the Project is approaching while there are a number of tasks and activities to be finished. VEA expects all concerned parties to actively participate in the Project activities and maintain the Project progress. - Regarding the 2nd phase of the Project, VEA would want more participation of the provinces and concerned parties. - Regarding the development and revision of the draft circular, VEA suggests drafting board to review carefully, eliminate wording errors, inappropriate forms, and analyze and reflect opinions of participants into the draft circular. - VEA highly appreciates the efforts of both the Vietnamese side and the Japanese side in implementing the Project activities. - JICA Vietnam appreciates VEA for its core coordination with a leading role of its affiliated unit, PCD, and other Vietnamese institutions for cooperating with JET and actively participating in the Project activities. - The Project outcomes will be effectively utilized for further mandate. - Draft industrial emission inventory will be examined by integrating comments raised in this WS. - VEA expected that VEA and JICA will have the next cooperation for better institutional activities of air quality management for both MONRE and DONRE activities. 4.3 TWG Meeting Under the initiatives of the Vice Director of VEA and the General Manager of PCD, a Core TWG is organized with the head and officials of KKPL division. Core TWG meetings were held during the Project implementation period a total of 33 times. Meeting materials are shown in Attachment 7. Discussion items in each meeting are described in Table Table List of TWG Meetings No. Date Discussion Item 1 30 Sept Project explanation, introduction of the JICA Expert Team, requests and comments by KKPL/PCD 2 13 Oct Project activities, answers to the comments by KKPL/PCD 3 21 Oct Oct Nov Nov Project activities, proposed operational structure of the Project, long list of potential TB titles, subcontract works - Schedule of the 1st JCC meeting, long list of potential TB titles, proposed operational structure of the Project, workshop and mini-workshop, subcontract works - Schedule of the 1st JCC meeting, draft inception report including long list of potential TB titles, proposed operational structure of the Project, subcontract works - Schedule of the 1st JCC meeting, contents to be discussed, draft inception report including long list of potential TB titles, subcontract works 7 05 Dec Finalization of ICR and distribution schedule of ICR, first meeting with the two DONREs 8 23 Dec Terms of reference (TOR) and schedules for subcontract surveys, roadmap preparation and first meeting with the two DONREs, TB formulation 9 09 Jan Contents of technical introduction and consultation for TB formulation, subcontract surveys 4-3

104 No. Date Discussion Item Apr Jun Jul Jul Jul Aug Aug Aug Aug Sep Sep Sep Oct Nov Nov Nov Jan Jan Jan Jan Feb Mar Mar Mar Source: JICA Expert Team - Supplementary technical advice/support to VEA proposed, emission inventory works of PCD in the selected subsectors, advisory support to CEM/VEA on isokinetic sampling at the stack - Support activity of emission inventories development including TOR and activity schedule, questionnaire improvement. - Support activity of emission inventories development, especially technical discussion in accordance with the questionnaires - Support activity of emission inventories development (arrangement of local experts, overall schedule) - Project administration discussion, Output 1/ list of final TB, Output 2/ mini-ws in Hanoi City, roadmap formulation, other activities/ emission inventories preparation, draft decree on waste, flue gas measurement, draft circular on flue gas measurement - Review and check the reliability of the collected questionnaires for the steel industry - Technical instruction of emission inventories development - Review and check the reliability of the collected questionnaires for the cement industry - Technical instruction of emission inventories development - Review and check the reliability of the collected questionnaires for the thermal power plant - Technical instruction of emission inventories development - Discussion of the final TB topics to be furnished in Output 1 - Schedule arrangement of milestones of the Project activities. - Organize a meeting on the draft decree on waste management oriented to air pollution control - Discussion on the contents of progress report - Draft the progress report - Discussion and confirmation of the 2 nd JCC meeting (contents, time schedule, and other logistical issues.) - Check the draft minutes of meeting of the 2 nd JCC Meeting, finalization of progress report - Discussion of the1st overall workshop and workshop on the draft decree on waste - Brainstorming on the next cooperation project -Signing the draft minutes of meeting of the 2 nd JCC Meeting - Discussion of the 1st overall workshop and workshop on the draft decree on waste - Brainstorming on the next cooperation project - Discussion of the 1st overall workshop and workshop on the draft decree on waste - Discussion and finalization of TB titles - Discussion on the emission inventories development for selected subsectors - Discussion on the topic of TB, especially for registration systems or emission inventory development - Discussion on the emission inventories development for selected subsectors - Discussion on the topic of TB, especially TB for CEMS, and TB for QCVN - Discussion on the report from the emission inventories experts - Explanation of dispatch schedule of JET before/after the New Year - Discussion on the Project implementation until the end of the Project - Discussion on the institutionalization plan of each output - Explanation and discussion about latest TBs and technical note of emission inventory development - Confirmation about the status of the draft decree on waste - Explanation and discussion about emission inventory development - Detailed explanation on the emission inventory usage - Discussion and explanation on the suggestive emission factor for the next emission inventory survey - Discussion on the Project implementation until the end of the Project, final JCC, and final WS - Discussion on the institutionalization plan of each output - Discussion about TB for registration system and questionnaires for emission inventory survey - Explanation and discussion about emission inventory development - Detailed explanation on the questionnaires for emission inventory usage - Discussion on the institutionalization perspective of the Project outcomes - Discussion on the 3rd JCC meeting and final overall WS - Discussion on the draft project completion report (PCR) preparation and schedule (This meeting was held by KKPL/PCD, JET, and JICA Vietnam) - Discussion on the institutionalization perspective of the Project outcomes - Sharing the procedure of QCVN revision. (This meeting was held by KKPL/PCD, JET, and JICA Vietnam) - Discussion on the 3rd JCC meeting and final overall WS - Discussion on the draft project completion report (PCR), finalization schedule - Discussion on the final overall WS (arrangement, contents, etc.) - Discussion on the revision of TBs and finalization schedule 4-4

105 4.4 Other Activities for the Project Management and Operation Meeting with Hanoi DONRE During the Project, meetings with Hanoi DONRE were held eight times in total, as shown in Table After the JCC officially agreed with the involvement of DONREs as the key counterparts of the Project, especially for Output 2, there were series of meetings organized among Hanoi DONRE, KKPL/PCD, and JET. Table List of Meetings with Hanoi DONRE No. Date Discussion Item 1 25 Dec Mar May Jul Sep Project explanation, introduction of the JICA Expert Team, preparation for drafting the roadmap including subcontract work (continuation of the discussion about TOR through and by phone) - Kick-off meeting of subcontract survey. Meeting was held among HNI EPA, KKPL/PCD, JET, and the local consultant in Hanoi City - Discussion on the interim report of subcontract survey. Progress of subcontract survey and further schedule of survey - Discussion on the draft final report of subcontract survey. Discussion on the drafting of the roadmap, confirmation of key plans/policies, next step for drafting the roadmap - Discussion on the current air quality situation and air quality management in Hanoi City as discussions in the mini WS for sharing technical essence of Output 1 with Hanoi City in the formulation of the roadmap 6 25 Sep Discussion on the progress of the roadmap and its plan formulation in the 2 nd JCC meeting 7 11 Nov Discussion on the progress of the roadmap and its plan formulation in the 1 st overall workshop - Discussion on the contents of the final roadmap 8 10 Mar Discussion on the contents of DPCR and Project s outcome Source: JICA Expert Team Meeting with Ho Chi Minh DONRE During the Project, meetings with Ho Chi Minh DONRE were held nine times in total, as shown in Table After the JCC officially agreed with the involvement of DONREs as key counterparts for the Project, especially for Output 2, there were a series of meetings organized among Ho Chi Minh DONRE, KKPL/PCD, and JET. Table List of Meetings with Ho Chi Minh DONRE No. Date Discussion Item 1 26 Dec Project explanation, introduction of the JICA Expert Team, preparation for drafting the roadmap including subcontract work (continuation of the discussion about TOR through and by phone) 2 27 Feb Discussion about the subcontract bidding and contract procedure and the Project activities 3 05 Mar Apr May Jul Kick-off meeting of subcontract survey. Meeting was held among HNI EPA, KKPL/PCD, JET, and the local consultant in HCMC. - Discussion on the current air quality situation and air quality management in HCMC as discussions in the mini WS for sharing technical essence of Output 1 with HCMC in the formulation of the roadmap - Discussion on the interim report of subcontract survey. Progress of subcontract survey and further schedule of survey - Discussion on the draft final report of subcontract survey. Preparation of the draft roadmap, key plans/policies, next step for drafting the roadmap 7 25 Sep Discussion on the progress of the roadmap and its plan formulation in the 2 nd JCC meeting 8 11 Nov Discussion on the progress of the roadmap and its plan formulation in the 1 st overall workshop 9 11 Mar Discussion on the contents of the final roadmap, - Discussion on the contents of DPCR and Project s outcome Source: JICA Expert Team 4-5

106 4.4.3 Others There were several meetings held between JET and VEA top managers like the Deputy Director General, who is a signatory on the Records of Discussion (RD) of the Project, for the purpose of discussing/sharing the Project activities and supporting the development of some circulars related to AQM. The close cooperation between JET and VEA managers has been contributing towards the effective and smooth administration of the Project. 4.5 Subcontract Works Conducted under the Project The Project allocated the following works to the subcontract consultants. The processes of tender and contract with the subcontractors followed the JICA Subcontract Guidelines (April 2014). Outline of the subcontract works under the Project are shown in Table Details of the survey are described on the terms of reference of the survey, as shown in Attachment 8 of this report. Table Subcontract Works under the Project No. Subcontract Works Components 1 Survey for Air Quality - Data collection on the current status of air pollution/quality Management under the Hanoi - Identification of issues and difficulties on air quality City People s Committee management/control activities in Hanoi City - Simplified CA on the air quality control of DONRE in Hanoi City [Subcontractor] Institute of Water Engineering and Environmental Technology (IWEET) 2 Survey for Air Quality Management under the Ho Chi Minh City People s Committee 3 Survey for Air Quality Management by the National Level Other Than VEA (Vietnam Environmental Agency) Source: JICA Expert Team [Survey Period] From February 2014 to July Data collection on the current status of air pollution/quality - Identification of issues and difficulties on air quality management/control activities in HCMC - Simplified CA on the air quality control of DONRE in HCMC [Subcontractor] Institute For Environmental and Resources (IER) [Survey Period] From February 2014 to June Data collection on the current activities of air quality control by the central government agencies - Identification of issues and difficulties on air quality management/control activities in the central level [Subcontractor] Institute For Resources, Environment and Community Development (RECO) [Survey Period] From January 2014 to April

107 CHAPTER 5 LESSONS LEARNED AND RECOMMENDATIONS 5.1 Lessons Learned (1) Project Approval of the Ministry of Natural Resource and Environment (MONRE) Although the Project approval was officially announced by the minister of MONRE on December 24, 2013, the key counterparts (CPs) of the Division of Pollution Control for Air and Recycling Materials (Phòng Kiểm soát ô nhiễm không khí và nhập khẩu phế liệu: KKPL)/ Pollution Control Department (PCD), and the JICA Expert Team (JET) made the initiation of the Project operation upon the first mobilization of JET to Vietnam in September 2013, that is before official approval of the Project. Owing to the efforts of PCD and the Vietnam Environmental Administration (VEA) for the Project, it can be said that the substantial approval by MONRE for PCD/VEA-JICA cooperation was acknowledged prior to JET mobilization, and the smooth initiation was realized, including the establishment of Project Management Unit in VEA, appointment of CPs for joint works with JET, budget allocation for PCD, and VEA for the Project operation, the preparation of JET office, etc. As widely recognized, Project approval is indispensable in Vietnam for operating the Japan International Cooperation Agency (JICA) technical cooperation project, in order to authorize the Project in MONRE and to realize resource mobilization such as human resources and budget from CP organization into the cooperation project. It is recommendable for the MONRE-JICA cooperation project to obtain approval from the Vietnamese side prior to actual commencement of a project, even if the approval would be under substantial status and awaiting the official announcement. (2) Regular Meetings in TWG During the Project period, the Core technical working group (TWG) meetings, mainly composed of the key CPs of KKPL and JET, were frequently held on a regular basis as well as on an ad hoc basis if required. These meetings contributed significantly to effective and smooth operation of the Project for sharing the progress of the activities among TWG members. Issues and obstacles prohibiting smooth Project implementation were also discussed, and solutions by both KKPL/PCD and JET were materialized. In addition, the meetings often functioned as opportunities for technical transfer for the key CPs. This function stimulated positive behavior of the CPs to even learn air quality administrative topics, which may be considered to be out of the Project scope. In order not only to promote the Project achievements but also to nurture the Project ownership among the CPs and Japanese side, regular meetings involving the key Project members were suggested. (3) Commitment and Initiative of Decision Makers in VEA and PCD The Deputy DG of VEA and Director/Deputy Director of PCD have been providing the initiatives in the Project administration from the beginning and during the Project period. DDG of VEA supervised the Project operation during the critical phase, and DD of PCD sometimes led and attended the Project activities even for the field works such as the visit to a big-scale factory for inventory. Such attitude of top managers of PCD and VEA have also been motivating the joint work of key CPs and JET, as well as participation in the Project of the other departments in VEA. Presence of KKPL has also increased in MONRE. The above experience of the Project shows that the commitment and initiative of top managers or decision makers of counterpart organizations are important not only for smooth administration of the Project but also for enhancement of the effectiveness of the Project achievements. 5-1

108 (4) Coordination with Internal Departments in VEA and External Bodies In the course of the Project implementation, KKPL/PCD facilitated the coordination and collaboration with the other departments in VEA such as ISD, CEM, DPL, WENID, etc. Among others, KKPL/PCD successfully involved the above internal departments of VEA and organized a series of Technical Introduction and Consultation under Output 1. In this regard, DONREs of Hanoi City and HCMC also participated in the Output 1 activities through mini-wss facilitated by KKPL/PCD for sharing the technical and institutional essence. In addition, inter-ministry coordination was initiated by KKPL/PCD at the chance open-discussion meeting for the Decree on Waste and Scrap Management in September The external expertise were provided by people such as experts from universities and research institutes, private sector associations who are possible big air polluters, and DONREs of medium-scale cities. Such collaboration and coordination developed by KKPL/PCD internally and externally are recommendable to be enhanced from now on, in order to contribute to the sustainability of the Project achievements as well as fulfillment of mandates of KKPL/PCD. (5) Approach of TB Formulation The Project was designed for formulating the thematic briefs (TBs) under Output 1. Considering the status surrounding the Project such as LEP revision process in National Assembly at the initial stage, the key CPs of KKPL/PCD and JET widely discussed together how to tailor the Output 1 design into the actual activities. Thus, the Project employed the following approach: i) Preparing the long list of potential TB titles considering the possible necessity of developing/updating the bylaws (decisions, circulars, etc.) while pursuing the progress of LEP revision; ii) Organizing a series of technical instructions and consultations among KKPL/PCD, other departments concerned, and JET, by categorizing the potential long list above into eight sessions, in order to develop the institutional and technical knowledge; iii) Finalizing the priority topic list for TB preparation in accordance with the principles and requirements of the revised LEP, considering the perspective and practicability of institutionalization in post-project stage; and, iv) Preparing three TBs through joint works by KKPL/PCD and JET, as one of the technical cooperation products. This approach (known as TB Approach ) has been successfully functioning for: a) identifying and clarifying the institutional requirements or preparedness of KKPL/PCD according to the revised LEP, b) enriching the technical and institutional archives of KKPL/PCD even on the topics which were not nominated as the priority ones, c) finalizing TBs as the technical cooperation products convincingly between CPs and JET, and d) gradually concentrating the time and resources of both sides by focusing on the most prioritized requirements of institutional capacity development to be realized in the Project. The abovementioned TB approach would be effective and successfully applicable for future MONRE-JICA cooperation projects especially on the projects aimed at institutional capacity development in environment management field. (6) Flexibility of the Project Operation Both the CPs and JET regarded the flexibility of the Project operation/activities as important. The activities related to the emission inventory preparation as well as the technical instruction to CEM for flue gas measurement are one of the flexible supports provided within the Project. Advisory input for drafting the Decree on Waste and Scrap Management, which was not designed in the original Project plan, also showed the flexible operation of the Project. 5-2

109 As long as the Project activities planned originally would not be affected negatively, the flexibility of the Project operation contributes to: i) expand the achievements of technical transfer and ii) function as a bridge between key CPs and other departments. 5.2 Recommendations (1) Sustainable Capacity Development Through the Project activities, various technical and institutional instructions on air pollution control were shared among CPs, JET, and other key stakeholders in Vietnam. The Project frequently provided the opportunities among the Project-related individuals to exchange opinions as well as to brainstorm technically and institutionally on the effective/enforceable approaches to air pollution control. The technical products, which will be basic and effective tools for air pollution control and air quality management (AQM), have also been generated during the Project such as TBs, roadmaps, emission inventory framework under the support activities, relevant materials employed in a series of technical introductions and consultations, and survey results by subcontract works. The skills and experiences gained from the above are indispensable in fulfilling the mandates of CPs for AQM, especially for KKPL and PCD of VEA. The above achievements are the essential elements for developing its capacity as the nation s environment management authority. Its capacity cannot be maintained and polished without the continuous efforts to cultivate the capacity obtained. Therefore, it is recommended for KKPL and PCD/VEA to promote sustainable capacity development by incorporating the outcomes and achievements of the Project into the daily duties and activities together with proper management of human resources and budget arrangement. In the course of the above endeavor whenever necessary, it is suggested to promote the request and dialogue of the next technical cooperation between Vietnamese and Japanese sides to expand the Project s fruits for further enforcement of air pollution control administration in both the national and city/provincial levels in order to realize the principles and requirements of the LEP revised in June (2) Integration of the Project Outcomes into Institutional System 1) Thematic Briefs (TBs) The Project generated three thematic briefs (TBs) as one of main technical cooperation products under Output 1, namely, i) improvement of the existing QCVN, ii) registration system and data management for stationary pollution sources, and iii) practical control of point pollution sources. These TBs are positioned as the products or the potential achievements to be institutionalized by VEA in the post-project stage. The following summarizes the perspectives and recommendations for VEA to pursue the institutionalization of the TBs for air pollution administration hereafter. Title and Explanation of TB [Improvement of existing QCVN] Contents: Application of standardized oxygen concentration in flue gas. Modification of emission standards. QCVN 22/2009, 23/2009, 51/2013, 06/2009 and 20/2009. plus QCVN 19/2009, 30/2010, 34/2010, and 02/2013 [Registration System and Data Management for Stationary Pollution Sources] Contents: Introducing the registration system Legal background of information systems for stack emission Information collection method from existing reports regulated by existing regulation. Regulations on reporting on emissions Perspective and Recommendation for Institutionalization TB is submitted under the form of draft QCVNs for easy application and revision. QCVN 19/2009, QCVN 22/2009, QCVN 23/2009, QCVN 06/2009, and QCVN 20/2009 are going to be replaced this year. Other QCVNs could be revised and modified, if necessary, afterward. This TB will be an explanation report to be attached as a dossier requesting the appraisal, approval and promulgation of legal documents. Registration system will be administrated by encouraging voluntary activities and attitudes from enterprises. The official guidance to instruct the registration will be prepared based on the essence of this TB. 5-3

110 Title and Explanation of TB [Practical control of point pollution sources] Contents: Introducing CEMS, as defined in the revised LEP, to major/big polluters in the selected subsectors The soft approaches supporting the pollution source control are combined, such as pollution control agreement mechanism, and pollution control manager (PCM) system. Perspective and Recommendation for Institutionalization This TB will be an explanation report attached as a dossier requesting the appraisal, approval and promulgation of legal documents. The legal documents on CEMS are recommendable to be prepared according to the contents of this TB, since the revised LEP defines the concept of introducing the CEMS to the big air polluters. 2) Roadmaps for Hanoi City and HCMC As mentioned in Section of Chapter 2, the LEP revised in June 2014 defines the mandates of city/province on environmental protection planning. During the Project duration, the instruction from the government regarding environmental protection planning has not yet been announced. However, air pollution control or AQM will no doubt be one of the major components of planning in the cities/provinces. The roadmaps generated in Output 2 of the Project provides the guidance for formulating the AQM Plan in Hanoi City and HCMC, thus these cities are expected to initiate the formulation of AQM Plan from now on. Once the governmental instruction regarding environmental protection planning is announced, it is recommended for these cities to integrate the formulated AQM Plan into the city environmental protection planning. At the time of formulation of the AQM Plan according to the roadmap or of preparing the protection planning after receiving the government instruction, due consideration should be paid on the following aspects by DONREs of Hanoi City and HCMC as well as PCD/VEA: a) It will be necessary to set the target year, target area, and contents as well as to examine the existing plan (socio-economic development plan, environmental master plan, transport master plan, other infrastructure programs, development program master plan, etc.) b) It is recommendable for the people s committees (PCs) of the two cities to instruct DONREs and related departments to initiate the formulation of AQM Plan according to the roadmap, with the allocation of adequate budget as implied in the roadmap. It is also essential to show and provide the initiatives of PCs for enhancing the cooperation and participation of the Department of Transportation (DOT), Department of Industry and Trade (DOIT), and other agencies into the process of preparing the environmental protection planning on air pollution control. Such initiative and facilitation by PCs will also be indispensable at the implementation stage of environmental protection planning on air pollution control through effective collaboration among DONREs and related departments. Development of the system of regular interchange of personnel between DONREs and the other departments would be one of the possible solutions to foster and realize the effective collaboration among departments under PCs. (3) Preparedness for Enforcement of New Decree on Regulations of Waste and Scrap Management At the time of this report preparation, the new Decree on Regulations of Waste and Scrap Management is under the process of obtaining final governmental approval. In addition, the decree includes the air pollution control to be enforced under the authority of KKPL/PCD of VEA. The decree will be a fundamental administrative tool for air pollution control under the revised LEP. Thus, the following aspects are recommendable to KKPL/PCD and VEA for further development of the bylaws or technical guidelines, in order to make the decree enforceable. The legal and institutional structure for air pollution control is recommended to be hierarchical, meaning that: i) targets, goals, and commitments of the state should be 5-4

111 declared in the basic law (e.g., LEP); ii) principles, strategies, and guide of the state should be clarified in bylaws (e.g., decree); and iii) approaches, methodology, numerical regulations, and other ruling tools should be identified in sub-ordinances (e.g., decisions, circulars, and official notices). Such hierarchy will also be effective to realize the flexibility of legislation based on the socioeconomic variation as well as to realize the enforceability of legislation by the administrative frontline (e.g., DONREs). In this viewpoint, the decree is appreciated to imply the subsequent issuance of bylaws or sub-ordinances. It is also appreciated that the decree stipulates the registration of factories (possible large air polluters) as well as the task of the state (MONRE and DONREs) to develop the emission inventory of stationary pollution sources. Since these two administrative measures should have a close linkage with each other, it is recommendable to cultivate and adjust such aspects in the stage of preparing the bylaws/sub-ordinances in order to realize effective air pollution control. The LEP 2014 stipulates the loading capacity (carrying capacity) of ambient air environment, although such approach would be difficult during the actual operation of air pollution control. Alternatively, the approach of Area-wide Total Pollution Load Control would be recommendable, which contributed remarkably to the reduction of air pollution emission in various regions in Japan. It would be difficult to develop the mobile source inventory as stipulated in the decree. However, it would be meaningful to compile the data on mobile sources through the categorization of vehicles by age, size, engine types, etc. Such information will be the base from which to estimate or predict the emission load from mobile sources by applying a reasonable emission factor in Vietnam, which will contribute to planning and realizing the pollution control/reduction from the mobile sector. Besides, in the course of the preparation of the decree, it was found that the demarcation of mandates between MONRE and MOC regarding solid waste management (SWM) would be unclear, even though SWM is not in the scope of the Project. It is suggested for VEA and MOC to enhance close communication to clarify their mandate and demarcation on SWM in the further institutional arrangement hereafter. (4) Recommendations for DONREs of Hanoi City and HCMC The Hanoi Department of Transportation (DOT)/Hanoi City PC invested in the Hanoi Urban Transport Development Project (HUTDP) under a loan from the World Bank and Vietnamese counterpart fund. There are four sub-components relating to air quality management: i) AQM equipment, ii) environmental monitoring, iii) mobile source emission inventory, and iv) exposure study. Mobile emission source has contributed to the air pollution in Hanoi City. DONRE of Hanoi City will formulate an environmental protection plan as prescribed in LEP The roadmap of the Project requires them to make an environmental protection plan. Mobile source control is one of the important topics for AQM by DONRE. Therefore, it is recommended that DONRE and DOT cooperate and for DONRE to have continuous involvement in HUTDP of Hanoi City. In regard to DONRE of HCMC, the person in charge of the development of the GIZ roadmap for Can Tho City was from the same institute who implemented the subcontract work in HCMC of the Project. This institute has many experiences in implementing air quality monitoring and in developing such plans for AQM. It is recommended to maintain good communication between DONRE and the institute. (5) Other Recommendations 1) Initiation of Collaboration with UNDP Project The Project for Strengthening Capacity on Natural Resources and Environment Policy and Law Development and Implementation founded by the United Nations Development 5-5

112 Programme (UNDP) has one component for policy formulation. One expected result under this component is the development of improved legal framework for curbing air pollution. The main counterpart of this project is the Institute of Strategy and Policy on Natural Resources and Environment (ISPONRE). It is recommended to keep communication lines open between PCD and ISPONRE. 2) Emission Inventory KKPL/PCD drafted a circular on the implementation of industrial emission inventory. The experience of supporting activities to PCD for emission inventory development of the selected subsectors under the Project contributes to the development of this circular. Several recommendations for development of emission inventory were discussed between KKPL/PCD and JET. In addition, these recommendations are described in Subsection Summary of Technical Note and Advice of this report and Attachment 17 as technical notes and advices. Especially, proposed questionnaires, which are attached in Attachment 17, are recommendable to be applied for future activities for emission inventory development. 3) National Action Plan for Air Pollution Control to 2020 The enactment of Clean Air Law is planned in the National Action Plan (NAP) for Air Pollution Control to 2020 developed by KKPL/PCD. The NAP defines the concept of the law, and is targeting the enactment of the law before The Project outputs, such as TBs, roadmaps, and technical cooperation product, will contribute to the development of Clean Air Law. Furthermore, the knowledge shared in the series of technical instructions and consultations under Output 1 will also provide the various hints to KKPL/PCD for preparing the law, especially on the legal system and structure of air pollution control in Japan. Therefore, it is recommended to the Vietnamese side to utilize the Project outputs as much as possible for developing the Clean Air Law. 5-6

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115 Attachment 1 Record of Discussions on the Project on March 26, 2013

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127 Attachment 2 Minutes of Meeting for the Project on March 9, 2012

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133 Attachment 3 Minutes of the First Joint Coordination Committee Meeting on November 28, 2013

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141 Attachment 4 Decision No. 2524/QĐ-BTNMT on December 12, 2013 Approving the Project Document

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143 B(>TUNGUYENVAMOI1RUONG S6: 2 S 2 q /QD-B1NMf C(>NG HOAxAH(>I cmjnghi'a V$'NAM D{>c l~p - Tv do - H~nh phuc Ha N<)i, ngay L2 thcing 12 niim 2013 QUYETDJNH v~ vi~c phe duy~t Van ki~n d\f an "Tang CU'Crng th~ ch~ quan Iy ch t lrrgng khong khi" BO. TRUONG BO. TAI NGUYEN VA MOI TRUONG Can cu Nghi dinh s6 21/2013/ND-CP ngay 04 thang 3 nam 2013 cua Chinh phu quy dinh chuc nang, nhi~m V\l, quysn h?n va ca c~u t6 chuc cua B<) Tai nguyen va Moi truang; Can cu Nghl dinh s6 38/20131ND-CP ngay 23 thang 4 nam 2013 cua Chinh phu vs quan ly va SU d\lllg ngu6n h6 trq phat trisn chinh thuc (ODA) va ngu6n v6n vay liu dai cua cac nha tai trq; Can cu QuySt dinh s6 1396/QD-BTNMT ngay 22 thang 7 nam 2009 cua B9 truemg B<) Tai nguyen va Moi truang ban hanh Quy chs xay d\ffig, quan ly va thµc hi~n cac chuang trinh, dv an, ho?t d()ng SU d\lng ngu6n tai trq nu6c ngoai thu(>c thfun quysn quan ly cua B9 Tai nguyen va Moi truang; Can cu cac Cong ham s6 3268/BKH-KTDN ngay 19 thang 5 nam 2010 va s6 5807/BKIIDT-KTDN ngay 03 thang 8 nam 2012 cua B<) KS ho<;lch va Dfiu tu gui D?i su quan Nh~t Ban t?i Vi~t Nam; Xet ds nghi cua T6ng C\lC Moi truang t?i cac Van ban: s6 1451/TCMT KSON ngay 05 thang 9 nam 2013, s6 1640/TCMT-KSON ngay 04 thang 10 nam 2013 va s6 1982/TCMT-KSON ngay 22 thang 11nam2013 vs vi~c thfun dinh va phe duy~t Van ki~n dv an "Tang cuang ths chs quan ly ch~t luqng khong khi"; Xet Bao cao th~m dinh dv an "Tang cuang ths chs quan ly ch~t luqng khong khi" va ds nghj cua V\l truemg V\l KS ho?ch, QUYETDJNH: f>i~u 1. Phe duy~t dv an "Tang cu6ng ths chs quan ly ch~t luqng khong khi" (Van ki~n dv an kem theo) v6i cac n()i dung chu yeu sau: 1. Ten dv an: Tang cuang ths chs quan ly ch~t luqng khong khi. 2. Ten nha tai trq: Ca quan hqp tac qudc t Nh~t Ban (HCA). 3. Ca quan chu quan: B<) Tai nguyen va Moi truang. 4. Chu dv an: TBng C\lC Moi trubng. 5. Dia dism thvc hi~n: Ha N<)i va thanh ph6 H6 Chi Minh. 6. Thai gian thvc hi~n: 1,5 nam. 7. M\lc tieu va kst qua chu ysu:, 7.1. M\lc tieu: Nang cao nang Ive xay d\lllg chinh sach va tb chuc quan ly chat luqng khong khi t?i Vi~t Nam.

144 7.2. qua chu y~u: Bao cao xay dµng cac khoan trong Lu~t Bao v~ moi truemg sua dbi quy dinh v~ quan l:y moi tru0ng khong khi co tinh kha thi va ', lo trlnh ban hanh cac van ban du6i lu~t ve quan ly chat lm;mg khong khi; Bao cao vs 19 trinh xay dl)'ng k~ ho~ch ki~m soat o nhi6m khong khi ti;ti Ha N{>i va thrum ph6 H6 ChJ Minh. 8. Kinh phf thµc hi~n : 8.1. V6n vi~n trg kh6ng hoan l<;ti cua JICA: Yen Nh~t (JPY), tmmg duong khoang d6ng (chuysn d6i theo ty gia 1 JPY = 205 ddng). Kinh phi vi~n trq do phia JICA quan ly va chi tieu van dbi tmg: d6ng, trong do: - van dbi tmg b~ng hi~n v ~t tuang ducmg d6ng. - Vdn ddi {mg b~ng tisn m~t ddng tir ngu6n v6n sµ nghi~p moi truang, b6 tri trong k~ ho<;tch va dµ toan ngan sach nha nuoc hang nam cua T6ng C\lc Moi truang. lµc thi hanh kb ru ngay ky. Charm Van Di~u 2. Quy~t dinh nay c6 hi~u phong B(>; Vl,l tru6ng cac V\}: KS hrn;1ch, Tai chinh, Hqp tac qu6c ts, TB ch(rc can b9; TBng C\lC truemg T6ng C\lC Moi truang va Thu tru6ng cac co quan, don vj c6 lien quan chiu trach nhi~m thi hanh Quyst dinh nay.i. Noinh9n: - Nhu Di~u 2; - BQ tr116ng Nguy n Minh Quang (d~ b/c); - Van phong Chinh phu; - Ngan hang NM nu&c; - Cac BQ: KH&DT, TC; - LtrU: VT, KH. ~ }ujl--- Bui Cac Tuy~n 2

145 VAN KIEN. DU. AN Tang crremg th~ ch~ quan ly chat lrrq'llg khong khi I \ \!., Ha N{H, 2013

146 N(>I DUNG VAN KI~N DV AN HO TRO KY THUAT SU DUNG VON ODA (Kem theo Quyit ajnh s6:i ~ 2'f truimg B9 Tai nguyen va Moi tru&ng) IQD-BrNMTngily fz_;himg l.2. nam 2013 cua Bo A? 1, THONG TIN CO BAN VE DV AN I. Thong tin CO' ban v~ dtf an 1. Ten dg an: Tang cu0ng th~ chs quan ly ch~t luqng khong khi 2. Ten nha tai trq: Co quan hqp tac qubc ts Nh~t Ban (IlCA) 3. Ca quan chu quan: B(> Tai nguyen va Moi truang Vi~t Nam a. Dia chi lien l~c: Sf> 10 Ton Th t Thuyet, Ha N(>i, Vi~t Nam b. s6 di~n tho~i: /Fax: (84-4) Don vi ds xu t dµ an: C\lC KiSm soat 0 nhiem, T6ng C\}C Moi truang a. Dia chi lien l~c: Si> 10 Ton Tu t ThuySt, Ha N(>i, Vi~t Nam b. SB di~n tho~i: /Fax: s. Chu d\f an: Tbng c\lc Moi trucrng a. Dia chi lien l~c: SB 10 Ton Th~t Thuy8t, Ha N(>i, Vi~t Nam b. s6 di~n tho~i: /Fax: (84-4) Tum gian <lg kisn thµc hi~n <lg an: s 7. Dia di~m thµc hlen dg an: Thanh ph6 Ha N{>i va Thanh phd H6 Chi Minh J..., II. B01 can h va ' Slf can ). th.,c.t 1e cua., d '1 an, Cilng v6i qua trinh phat trisn kinh ts - xa h(>i, d~c bi~t la t6c d(> cong nghi~p hoa, do thi hoa nhanh ch6ng dang lam bien dai ch~t luqdg moi trubng khong khi xung quanh. Theo bao cao danh gia trong giai do~ , dien bi Sn chat lugng moi truimg kh6ng khi t~i m t s6 do thi 16n ctia Vi ~t Nam ( di ~n hinh la m(>t s6 thrum phi> nhu: Ha N9i, Thanh phb Hb Chi Minh, DBng Nai... ) co XU hu6ng suy giam. Tuy nhien, v n ds 0 nhi6m chu y~u la. bv.i va bl;li min (TSP va PMlO), d~c bi~t t~i cac khu V\fC dang tjong qua trinh xay d\l'llg va cac nut giao thong, nai c6 luu luc;mg phuang ti~n giao thong 16n. Ph n 16n cac khu V\l'C nay, n6ng d9 bµi va b\li min vuqt qua tieu chuk cho phep kha cao> khoang tir 1,5-2,5 lftn., Vao nhfrng gia cao diem 41i cac nut giao thong, n6ng d{> bt,ti thubng vuqt ngu5ng tieu chufut cho phep. 0 cac khu V\fC t~p trung ho~t d9ng san xugt cong nghi~p c(ing la noi c6 ham luqng b\li cao vugt muc cbo phep. Cac thong s& khac d:~c trung cho o nhi8m khong khi nhu Nita dioxit (N02), Carbon 2

147 monoxit (CO), Sunfua dioxit (80 2 ).. m~c du ci1ng co xu hu6ng gia tang trong thai gian gk day, nhung nhin chung vfui a trong tieu chudn cho phep. Tru6c nhfrng vfui ds 6 nhiem moi truang khong khi, ChiSn luge bao v~ moi trubng qu6c gia dsn nam 2010 tfun nhin 2020 dsn ChiSn luge bao v~ moi truemg qu6c gia d~n nam 2020 tam nhin 2030; ChiSn luge Phat trisn b8n vfrng cua Vi~t Nam nam dsn ChiSn luge Phat tri~n b8n vfrng cua Vi~t Nam nam ; Nghi quy~t 35/NQ-CP ngay 18 thang 3 nam 2013 cua Chinh phu VS IDQt s6 Vful d~ c&p bach trong llnh V\fC bao V~ moi truang Va Quy~t djnh sfj 1287/QD-TTg v8 vi~c phan cong nhi~m V\l trisn khai thµc hi~n Nghi quy~t s6 35/NQ-CP ngay 18 thang 3 nam 2013 cua Chinh phu v~ m{>t s6 vfui d~ c~p bach trong linh V\fC bao v~ moi trubng da dua ra m(>t s6 giai phap di.uh hu6ng XU ly 6 nhiem khong khi, xac dinh nhu kism soat co hi~u qua ngufin thai cua cac phucmg ti~n giao thong v~ tai theo tieu chuftn da dugc ban harm; co chinh sach khuysn khich cac phucmg ti~n giao thong cong CQng, phuang ti~n giao thong Slr d\lflg nang lm;mg s~ch, khong gay 6 nhi~m... Trong nam va 2013, B{> Tai nguyen va Moi truang dang nghien Clru va dµ thao K~ ho~ch hanh d{mg qu6c gia vs kism soat 0 nhism khong khi d6 trinh Chinh phu xem xet ban hanh trong nam Tuy nhien vi~c thµc hi~n giai phap m9t each co hi~u qua con nhisu vfui d~ tra ng~i. Do la sv chflng cheo vs trach nhi~m quan ly chit luqng khong khi; t6 chuc bq may quan ly moi truemg kh6ng khi con m6ng, thi@u can b(:l... Cac van ban phap lu ~t m~c du da d~ c~p d~n quan ly va bao v~ moi truang khong khi nhung nhfrng hu6ng dblquy dinh Cl) th ~ con thisu. Sµ quan tam cua cac cfip, cac nganh chua tb\fc Sl,l' di vao chi8u sau, the hi~n qua vi~c bb tri kinh phi, d~u tu cho cong tac quan ly moi truemg khong khi cling nhu ngu6n lgc cho kiem soat 0 nhi~m khong khi con h~n ch~. Ben c~ d6, y thuc, trach nhi~m bao v~ moi truang cua cac co so san xu t chua cao, vi~c XU ly khi thai a nhisu noi con mang n~g tinh hinh thuc. Vi~t Nam c~n SI)' hfl trg d~c bi~t la cac hb trg ky thu~t tu mroc phat tri n, quan ly ch~t luqng k:hong khi t6t hi~n nay d~ giai quy~t vfu1 d~ tr& ng,p d u tien trong quan Iy ch~t Im;mg k:hong khi, do Ia v~n d~ chinh sach ths ch~ trong quan ly ch t lm;mg khong khi. Tru6c nhu c u thµc ti~n d6, dµ an ''Tang cu0ng th~ ch~ quan ly chat Im;mg khong khl,, aa duqc B9 Tai nguyen va Moi truemg ph6i hc;rp v6i co quan hqp tac qu6c t~ Nh~t Ban JICA xay d\lllg va dugc Chinh phu hai nu6c dbng y cung ph6i hgp trj~n khai th\tc hi~n. Dµ an se h6 trg BC) Tai nguyen va Moi tnrang nang cao nang Ive ho~ch d!nh chinh sach va tang cuang h ~ thdng ths ch~, quan ly vs moi tnrang khong khi thong qua v i~c hfi trg sua ct6i va xay d\lllg 19 trinh thµc thi h~ thbng phap lu ~t vs ki@m soat 6 nhism khong khi. Ngoai ra, m9t s6 So Tai nguyen va Moi truang cfing dugc moi tham gia cac ho~t d(mg t~p hu:in va chia se kinh nghi~m vs thµc thi ki~m soat o nhism moi truemg 3