PROJECT EXECUTIVE SUMMARY
GEF COUNCIL WORK PROGRAM SUBMISSION
AGENCY’S PROJECT ID: 3664/CHN10/00043092
GEFSEC PROJECT ID: 2932
COUNTRY: People’s Republic of China
PROJECT TITLE: Alternatives to DDT Usage in the
Production of Antifouling Paint
GEF AGENCY: United Nations Development
Programme (UNDP)
OTHER EXECUTING AGENCY(IES): N/A
DURATION: 4 years
GEF FOCAL AREA: Persistent Organic Pollutants
GEF OPERATIONAL PROGRAM: OP14 Program
for Reducing and Eliminating Release of Persistent
Organic Pollutants with linkages to International
Waters through OP10
GEF STRATEGIC PRIORITY: SP2 Implementation
of Policy/Regulatory Reforms and Investments
Pipeline Entry Date: 14 October 2005
ESTIMATED STARTING DATE: October 2006
IA FEE: US$ 1,071,450
FINANCING PLAN (US$)
GEF PROJECT/COMPONENT
Project
11,610,000
PDF A
PDF B
295,000
PDF C
Sub-Total GEF
11,905,000
CO-FINANCING*
GEF Agency
Government
3,750,000
Bilateral
NGOs
Others
8,500,000
Sub-Total Co-financing:
12,250,000
Total Project Financing:
24,155,000
FINANCING FOR ASSOCIATED
ACTIVITIES IF ANY: N/A
LEVERAGED RESOURCES IF ANY: N/A
*Details provided under the Financial
Modality and Cost Effectiveness section
CONTRIBUTION TO KEY INDICATORS OF THE BUSINESS PLAN: Elimination of 250 MT/year of DDT
emissions from production of antifouling paint. Related regulations, standards and action plans will be
established or revised, supported by capacity development, to create an enabling policy environment to
sustain the phase out
RECORD OF ENDORSEMENT ON BEHALF OF THE GOVERNMENT(S):
Mr. Jinkang Wu, Director, International
Date: December 29, 2005
Financial Institution Division IV, International
Department, Ministry of Finance
Approved on behalf of the UNDP. This proposal has been prepared in accordance with GEF
policies and procedures and meets the standards of the GEF Project Review Criteria for work
program inclusion
Maryam Niamir Fuller
Officer-in-Charge,
UNDP-GEF
Date: 24 March 2006
Suely Carvalho, Chief, Montreal Protocol Unit
and Principal Technical Adviser for POPs,
EEG/BDP, UNDP Project Contact Person
Tel. and email: Tel. and email:+1 212 906 6687
suely.carvalho@undp.org
PROJECT SUMMARY
a)
Project rationale, objectives, outputs/outcomes, and activities.
The binding objective of the project is to eliminate the use of DDT in production of antifouling paint by
conversion to non-toxic and environmentally friendly alternatives. In addition, the prospective objective
of the project is to establish a long-term mechanism to protect marine environment and human health
from pollution of harmful antifouling systems by supporting China to sign International Convention on
the Control of Harmful Antifouling Systems on Ships (the IMO Convention) based on the technologies,
experience and instruments obtained from phase out of DDT antifouling paint.
Annually, China consumes about 65,000 MT of antifouling paint. Surveys conducted during the PDF-B
phase shows that China has 300,000 fishing ships widely distributed along its 18,000 km. coastline, which
consume 10,000 MT antifouling paint, approximately half, i.e. 5,000 MT is DDT based and the other half,
5,000 MT is organotin based TBT antifouling paint. It is estimated by the China Maritime Bureau that
commercial ships navigating in domestic sea territory consume about an additional 20,000 MT TBT
based antifouling paint with a working life of 3 years. In addition, another 35,000 MT of TBT-free self
polishing antifouling paint was used on ocean-going commercial ships.
Antifouling paints containing DDT are mainly used on sea fishing ships. The 300,000 medium and small
size ships in China, half of which apply DDT based antifouling paint, with the balance using TBT based
antifouling paint. Because DDT is a Persistent Organic Pollutant, it can damage sea organisms and sea
ecosystems, and be accumulated in the bodies of sea organisms when it is released into sea from the
antifouling paints coated on the ships’ surface.
Based on current information on antifouling paint production in China, the residual amount of DDT in
antifouling paint produced amounts to approximately 5% by weight. Use of DDT in this manner is not
considered a permitted use under the Stockholm Convention, and there are no specific exemptions
available to continue such production and use. As such, China is obliged to take action to address the use
of DDT as additive in the production of antifouling paint.
Approximately 4% of total DDT production in China is used as additive for the production of antifouling
paint. The annual quantity of DDT based antifouling paint produced is approximately 5,000 MT. The
residual DDT in antifouling paint production is one of the main sources of DDT pollution in China. It is
estimated that 250 MT of DDT per annum is emitted through antifouling paint usage in China,
corresponding to roughly 5% by weight DDT content in the product.
Under this project, China will take measures to eliminate the use of DDT as an additive for antifouling
paints, and to establish and promote the use of sustainable alternatives to DDT/TBT-based antifouling
paints. To achieve project objectives, the measures to be taken include:
1. Establish institutional setting and mechanism for project implementation;
2. Establish a management information system;
3. Establish or revise regulations, standards and incentives necessary to support phase-out of
DDT-based paints;
4. Build capacity to create an enabling environment for phase out of DDT/TBT based
antifouling paint and promotion of alternatives.
5. Carry out activities to promote the production, distribution and use of alternatives, including
selection of alternative products and/or technologies and activities to establish domestic
production of such;
6. Educate key stakeholders and the general public through publicity campaigns and outreach
2
activities
7. Monitor and evaluate project implementation and results.
Outcomes and activities include the following:
Outcome 1 will establish project management institutions and coordination mechanism, build their
operational capacity based on the existing institutional settings. A national expert team will be established
to provide technical and consulting support to project implementation. Training will be conducted to
improve the managerial and technical capabilities for effective project implementation and management.
A study tour abroad is envisioned to incorporate experience and lessons on the selected alternative
technologies into the implementation of the project.
Outcome 2 will establish a Management Information System (MIS) for data collection, processing and
analysis of data, information transmission and sharing, and will establish a website to disseminate project
information and results to the public. A mechanism will be established to ensure long-term information
flow to facilitate reporting requirement, after completion of the project.
Outcome 3 will establish or revise regulations, standards, and an action plan supported by capacity
building to create an enabling policy environment for phase out of DDT based antifouling paint and
promotion of sustainable alternatives. Some of the actions planned include establishment and promotion
of a voluntary certification and labeling program in the antifouling paint sector, revision of the
compulsory rules of inspection of ship products, and sustaining DDT phase out. It is planned to
strengthen the capacity of related departments to effectively implement and enforce the regulations,
standards and action plan. The successful experience achieved from the phase out of DDT will assist to
accelerate the phase out of TBT and support China to accede to the IMO Convention.
Outcome 4 will facilitate the conversion from DDT based antifouling paints to alternatives. Activities
under this outcome include testing, selection and acquiring alternative technologies, selection of
demonstration enterprises, production and distribution of alternatives, and conducting environmental
sound management of DDT at contaminated sites and on equipment used for DDT based antifouling paint
production. Experience and results on phasing out DDT based antifouling paint reduction will be used to
accelerate the phase out of TBT based paint. Three antifouling systems have been preliminarily selected
for consideration for this project based on extensive literature review and field survey during the PDF-B
phase.
a)
Other organic booster biocides accredited by international authorities. IMO and environmental
authorities of some countries have approved a list of organic booster biocides for use in production
of antifouling paints. This technology is mature, while the environmental performance is largely
dependant on the organic booster biocides selected. The key to apply this antifouling system is to
select those biocides similar to Sea Nine 211 that is environmentally friendly and can have high
efficiency with even a low content. The high price of the products in using this technology is the
required import of the biocides. Domestic production of these biocides by introducing the foreign
technologies can greatly reduce the cost and price. During the first year of the project
implementation, antifouling paint manufacturers using these biocides will participate in the unified
on-ship patch test so that the desired biocides based antifouling paint products will be identified for
adoption in this project.
b)
Capsaicine or capsainoids has strong repelling effect, but it does not kill sea organisms. Thus, it has
sound ecological benefits. Capsaicine or capsainoids based antifouling paint has been tested on ships
for many cases, and the effect has been proven to be acceptable. The key problem with this less
mature technology is the prohibitively high cost associated with the extraction of capsaicine or
capsainoids from natural crop that prevents its commercialization. The current price of naturally
3
extracted capsaicine or capsainoids is 30,000 to 40,000 RMB per kg. The key to apply this
antifouling system is to chemically synthesize the Capsaicine or capsainoids by artificial means and
reduce the raw material cost. PDF-B phase survey has found that quite a few research institutes, both
in China and abroad, have successfully developed the chemical synthesis of capsaicine of high purity
in laboratory. The price can be reduced to only 500 RMB per kg. in scale production. Test effects
from board experiments show an even better efficiency than antifouling paint based on capsaicine
extracted from natural hot red pepper. It can be safely foreseen that chemically synthesized
capsaicine based antifouling paint will also have a better efficiency than the natural product based
antifouling paint. During the first year of project implementation, necessary technical and financial
support will be provided to producers to apply this technology from laboratory experiment to scale
production in the factory.
c)
Alkali silicate antifouling paint. Fouling sea organisms generally grow best in slightly alkali
environment with pH between 7.5 and 8.0. Alkali silicate is used as film formulation substance in
antifouling paint, which can be cheap and non-toxic. The on-ship experiment showed that the effect
is acceptable in other sea areas except in South Sea. But this antifouling system has poor
physiochemical property and has only a short working life of not more than one and a half year. The
key to apply this antifouling system is to improve the physiochemical property by adding proper
amounts of regulator agent, booster agent, and hydrolysable crylic acid rosin into the matrix. It was
found during the PDF-B phase that a number of research institutes in China have successfully
overcome these weaknesses, but the improved product has not been produced in a meaningful scale
to replace the lower end antifouling paint products due to the barriers of conventional choice and use
of DDT or TBT based antifouling paints among the fishermen. During the first year of project
implementation, this technology will be supported to reach scale production. This technology does
not foresee a significant economic barrier to commercialization. It is particularly suitable for use by
fishing boats with only one year interval of activity in North Sea and East Sea
It is anticipated that during project implementation, some other alternative technologies that can better
match the selection criteria will also be considered and promoted to ensure that the best suitable and
sustainable technologies will be adopted. Through policies, technological and market instruments,
improved production capacities and expanded demand of alternatives, production of alternatives can thus
be sustained.
Outcome 5 will involve activities in environmental education and awareness-raising to promote the
environmental awareness of the key stakeholders and the public, and improve their understanding of the
harm of DDT/TBT based antifouling paints and the benefits of alternatives. Activities will include
preparation of publicity materials for environmental education and awareness raising purpose targeting
the professional and sectoral audiences and the public through multiple media of TV, radio station,
newspaper, magazine, journal, Internet, CD-ROM, and printing materials. It is also envisioned to
demonstrate and promote to fishermen the benefits of using alternatives and to provide incentives to endusers to promote the alternatives for its sustainable use. In addition, efforts will also be undertaken to
influence the consumption behaviour of the important and large end user group. NGOs will be mobilized
to conduct community based environmental education and awareness-raising, and to hold training
workshops for the governmental agencies.
Outcome 6 will establish and utilize the necessary tools to facilitate effective monitoring and evaluation
on progress of project implementation and achievement of results.
b)
Key indicators, assumptions, and risks
The key measurable binding indicators of the project include elimination of 250 MT/year of DDT
production at the Tianjin Chemical Plant, no remaining DDT content in antifouling paint, reductions in
4
DDT emissions in marine environmental media and organisms, commercial availability of alternative
products and technologies in the marketplace and enactment of laws and regulations supporting phase out
of DDT-based antifouling paints.
Prospective indicators will include reduced amount of TBT used in antifouling paint, reduction of TBT
contents in marine environmental media and the harms.
In order to realize the project objectives, risks in the following aspects must be taken into account:
i.
ii.
iii.
iv.
v.
vi.
vii.
alternative technology
small and medium sized enterprises
legislations and enforcement
market change
stakeholder participation
TBT based antifouling paint or other cheap and harmful antifouling systems
Hard to change consumption behaviours
The Project Logical Framework provides a detailed analysis of the risks and assumptions.
2.
COUNTRY OWNERSHIP
a) COUNTRY ELIGIBILITY
China signed the Stockholm Convention on Persistent Organic Pollutants in May 2001, and the congress
ratified the Convention in June 2004. The Convention entered into effect on November 11, 2004. China is
eligible for GEF funding under para 9(b) of the GEF Instrument.
b) COUNTRY DRIVENNESS
Implementation of the Stockholm Convention is in conformity with China State Policy on Environmental
Protection. Recommendations on the development of the 11th Five-Year Plan of National Economic and
Social Development by the Central Government of the Communist Party of China emphasized the
concept of scientific innovation-oriented development, resource-efficient, environmentally friendly in
building a harmonious society. Substantial measures shall be taken to resolve significant issues that affect
economic development and particularly those that threaten human health. In December, 2005, the State
Council issued The State Council’s Decision to Realize Scientific Development and Strengthen
Environmental Protection. It also indicates that hazards due to POPs have gained attention in China, and
that the State will establish and implement long-term environmental protection mechanism to control
POPs through international cooperation and communication.
The PDF-B grant phase of the development of the National Implementation Plan (NIP) in China as a first
step to comply with the Convention was implemented by the Foreign Economic Cooperation Office
(FECO) of the State Environmental Protection Administration (SEPA) under a letter of agreement with
UNIDO. The GEF Council Meeting approved the full size project in May 2003 and endorsed the project
document in September 2004. The full NIP project was initiated on September 21, 2004. The NIP
development work should be completed in June 2006. The NIP will be submitted to GEF and will serve
as the overall guidance to implement the Convention in China in the future.
As part of process for the preparation of the NIP, with the support of the Government of Italy and
implemented by UNDP/UNOPS, investigation of the production, distribution, use, import/export and
5
obsolete/stockpile situation of 9 kinds of POPs pesticides was conducted. Based on the investigation and
assessment, a Strategy for Phase out of POPs Pesticides in China was drafted in June 2004. The Strategy
was reviewed and revised several times by related ministries involved in the implementation of the
Stockholm Convention, after receiving valuable comments and inputs from international and national
stakeholders at a June 2004 workshop. Based on the Strategy and its annex documents, key information
was used to develop this follow-up project proposal. The Strategy will become a part of NIP for China to
implement Stockholm Convention on Persistent Organic Pollutants. The Strategy includes an overall
deployment on DDT elimination and substitution, in which the application of DDT as biocide additive in
antifouling paint is required to be completely eliminated within 2 years from 2006.
3.
PROGRAM AND POLICY CONFORMITY
a) FIT TO GEF OPERATIONAL PROGRAM AND STRATEGIC PRIORITY
The proposed project is consistent with both capacity-building and on-the-ground interventions of the
GEF’s Operational Program on POPs (OP-14) to promote/effect transition to environmentally sound
alternatives to reduce and eliminate POPs emission. The project design is also consistent with GEF’s
Contaminant Based Operational Program (OP-10) in the focal area of International Waters, focusing on
adoption of methods, techniques, pilot projects, innovative technologies, institutional arrangement, and
economic instruments to demonstrate removal of barriers by taking best practices to prevent discharge of
key contaminants including global contaminants and ship contaminants.
b) SUSTAINABILITY (INCLUDING FINANCIAL SUSTAINABILITY)
The sustainability of this project will be guaranteed from the following aspects:
i)
ii)
iii)
iv)
intensive mobilization of all related stakeholders throughout the process;
demonstration of the effectiveness of environment-friendly alternative technologies/ products;
support capacity building at both national and local levels;
formulate laws, regulations and rules to control and manage DDT based antifouling paint and
promote alternatives, and provide incentives for enforcement.
c) REPLICABILITY
The project’s impact on the policy framework, capacity building in key local institutions, the identified
alternatives, and the development of tools and methodologies addressing the environmental problems of
POPs, as well as approaches developed under the project, will be disseminated and implemented through
the Technical Coordination Group (TCG) established under the CIO of SEPA for adaptation by other
POPs activities in China.
It is expected that the experience gained through this project can be applied to similar or related projects
within China, including eventual elimination of other DDT-based operations such as Dicofol production
(PDF-B already approved), which when implemented, will phase out about 85% of DDT produced by the
Tianjin Chemical Plant. The mechanisms for establishing the regulatory framework, as well as
establishing a procedure for introduction and commercialization of alternative technology will be able to
be applied not only in China, but in other countries with diverse populations and large geographic areas.
The education, publicity and outreach campaign developed will be easily adaptable to other applications
as well.
This project will conduct strategic study at the latter stage of implementation to replicate the experience
and lessons obtained from this project to phase out TBT-based antifouling paints.
6
The involvement of GEF, UNDP, as well as close cooperation with other international implementing and
executing agencies and bilateral governments will ensure that a successful project approach can be
replicated in other countries that face similar POPs elimination problems.
d) STAKEHOLDER INVOLVEMENT
Major national and local government, scientific institutions, and private sectors concerned with
elimination of DDT used as additive in antifouling paint production in China have already participated
actively in developing the Strategy under the Sino-Italian POPs project, and have been extensively
involved in the PDF-B project preparation phase. Implementation of the full-size project foresees
involvement of all major stakeholder groups at all phases of the project.
The lead national agency responsible for project implementation is SEPA. The National Technical
Coordination Group (TCG) consists of the following 11 agencies: State Environmental Protection
Administration, National Development and Reform Commission, Ministry of Foreign Affairs, Ministry of
Finance, Ministry of Commerce, Ministry of Science and Technology, Ministry of Agriculture, Ministry
of Public Health, Ministry of Construction, General Administration of Customs, State Electricity
Regulatory Commission. Three Local project Management Offices will interface with fishermen and ship
enterprises along the coastline. Other stakeholders will be involved as members of the Steering
Committee, Project team and National Expert Team as appropriate. Some of these additional
stakeholders include General Administration of Quality Supervision, Inspection and Quarantine, National
Certification and Accreditation Administration, State Administration of Work Safety, Fishery
Management Bureau of Ministry of Agriculture, National Fishing Boat Inspection Bureau, Maritime
Safety Administration of Ministry of Communication, National Standardization Technical Committee
State Oceanic Administration, and the local governmental agencies.
e) MONITORING AND EVALUATION
Project monitoring and evaluation will be conducted in accordance with established UNDP and GEF
procedures and will be provided by the project team and the UNDP Country Office (UNDP-CO) with
support from UNDP/GEF. The Logical Framework Matrix (Annex B) provides performance and impact
indicators for project implementation along with their corresponding means of verification. The project
will be subject to Annual Project Implementation Reviews (PIRs) and related documentation, the Annual
Project Report (APR), Tripartite Review Meetings (TPR), as well as mid-term and final evaluations.
Tripartite Review Meetings will be held at least once every twelve months, with the first meeting
scheduled within the first 12 months after project implementation start. The APR will be submitted at
least 2 weeks prior to the TPR meeting. Quarterly meetings with UNDP-CO will be scheduled to monitor
project progress. The Project Coordinator, in conjunction with the UNDP-GEF extended team, is
responsible for preparation of required reports. The Logical Framework Matrix provides Performance and
Impact indicators for project implementation along with their corresponding means of verification. These
will form the basis on which the project’s Monitoring and Evaluation system will be built. The project’s
indicative M&E workplan is as follows:
Indicative Monitoring and Evaluation Work plan and Corresponding Budget
Budget US$
Type of M&E
Excluding project team
Responsible Parties
Time frame
activity
Staff time
Within first six
Inception Workshop
 Project Coordinator
50,000 months of project
start up
7
Inception Report

Project Team
Measurement of
Means of Verification
for Project Purpose
Indicators

Project Team
Included in IW
Immediately
following IW
100,000
Start, mid and
end of project
Annually prior to
APR/PIR and as
100,000 defined in
Annual Work
Plans
Measurement of
Means of Verification
for Project Progress
and Performance

Regional field officers and
local IAs
APR and PIR

Project Team
None Annually
TPR and TPR report


Project team
UNDP-GEF
None
Steering Committee
Meetings



Project Coordinator
UNDP CO
UNDP-GEF
Quarterly Progress
Report

Project team
Every year, upon
receipt of APR
Following IW
and subsequently
80,000
at least once a
year
None Each quarter
Technical reports

National consultants
30,000
Mid-term External
Evaluation

External Consultants
Final External
Evaluation

External Consultants
Terminal Report

Project team
Lessons learned

Project team
Audit

Independent Audit Entity
40,000
60,000
20,000
To be determined
by Project Team
and UNDP-CO
At the mid-point
of project
implementation.
At the end of
project
implementation
At least one
month before the
end of the project
None Annually
Visits to field sites
 UNDP Country Office
(UNDP staff travel
 UNDP-GEF (as
costs to be charged to
appropriate)
IA fees)
 Government representatives
TOTAL indicative COST
Excluding project team staff time and UNDP staff and
travel expenses
8
20,000 Annually
20,000
520,000
Annually, as
required
Table 2: Impact Measurement Template
Key Impact
Indicator
Baseline
Amount of DDT produced
by Tianjin Chemical Plant
1,600 MT
Amount of alternatives
produced
Price of
alternatives
0
Other biocide
based
Capsaicine
based
Content of DDT in
antifouling paint
45-60
RMB/kg
87-140
RMB/kg
5% in DDT
based
antifouling
paint by
weight
Number of ships using
alternatives
Target (at
Year 4)
Reduced at
least 250 MT
per year
Sampling
frequency
Site visit and
investigation
Annually
Location
Tianjin
Chemical
Plant
Enterprises
and end
users
Market and
end users
Market and
end users
At least 5,000 Thematic
MT
investigation
Every two
years
25-35
RMB/kg
25-35
RMB/kg
Market
survey
Market
survey
Every two
years
Every two
years
Laboratory
analysis
Annually
Manufactures and
market
Sampling
investigation
Every two
years
All 9
coastal
provinces
0
At least
150,000 start
using DDT
based
antifouling
paint
0
Means of
Verification
Among the key impact indicators, DDT/TBT contents in ambient air and sea water can have a significant
decrease with the reduced use of DDT and TBT based antifouling paints during project implementation.
As regard other indicators like DDT/TBT levels in organisms, it is unlikely to decrease over the life of the
project in a significant way. In this case, this project will establish a baseline against which longer term
progress can be gauged.
4.
FINANCIAL MODALITY AND COST EFFECTIVENESS
a) FINANCIAL MODALITY
Full-sized Project financing, excluding PDF-B GEF resources of $295,000 approved, is $23,860,000, of
which $11,610,000 is requested from GEF and $12,250,000 represents co-financing as described below.
Co-financing Sources
Name of Cofinancier (source)
Government of China
Classification
Type
Amount (US$)
Status*
Cash
3,750,000
Confirmed
Bilateral Country
Government
Implementing
Agency
Government
Private Industry
Private sector
In-kind
8,500,000
Confirmed
UNDP
Sub-Total Co-financing
12,250,000
9
In-kind co-finance from enterprises will cover required site preparation, production equipment, analytical
instruments, raw materials, employee salary, enterprise R & D and training, and advertisement expenses.
Letters of commitment to providing co-finance are annexed to Annex E of the Executive Summary.
During the PDF-B, the CIO has had extensive communication with antifouling paint manufacturers and
achieved positive response from them in providing co-financing to the project. The CIO published a call
for expression of interest in its official website (www.chinapops.org), and notified all the antifouling paint
manufacturers in China by email, telephone and meeting. So far, 7 enterprises have submitted their
commitment to providing co-financing. Their in-kind contributions in fixed assets have also been verified
by independent asset evaluation entities. During project implementation, 3 to 5 enterprises will be
selected to provide a total co-financing of 68 million RMB, or equivalent of 8.5 million USD for
production and promotion of alternatives in this project.
b) COST EFFECTIVENESS
The use of DDT based antifouling paint will render costs in the following aspects:




The fishermen will pay 75 million RMB for 5,000 MT DDT based antifouling paint per annum by
assuming a conservative unit price of 15 RMB per kg.
Economic loss of aquatic product export will be incurred by the excessive DDT contents. The
increase rate of aquatic product export in 2005 was reduced by 14% as compared with that in 2004,
mainly due to the over residual of pesticides. While it is hard to quantitatively determine the impacts
of DDT usage in antifouling paint to the aquatic product quality, it should be a significant factor due
to direct release of DDT into coastal waters and accumulation in aquatic products.
The long-term exposed groups under DDT will pay for health treatment. For instance, Tianjin
Chemical Plant will provide the DDT production staff with 1 month health leave with pay. Due to
the special damages such as disruption of reproductive, neural and endocrine systems DDT can cause
to people under long-term and accumulative exposure, in no way the cost of medical care can be over
estimated.
Long-term accumulative contamination of soil and water during production and use of DDT and
DDT based antifouling paint will also cause damages to the sensitive species, and even trigger
species extinction. The cost of species extinction and rehabilitation of damaged ecosystem will be
too huge to calculate.
The implementation of this project will of course continue to make the fishermen ever using DDT based
antifouling paint pay 75 million RMB or even slightly higher amount for alternatives, but will also
generate the benefits in the following aspects:
 Reduce the economic loss of aquatic product export related with DDT usage in antifouling paint,
 Reduce or eliminate the cost for health treatment of DDT exposed groups, and
 Reduce the cost for cleaning of contaminated environment and rehabilitation of damaged
ecosystems,
In addition, considerable economic and social benefits can be generated from the promotion of technically
feasible, economically acceptable, and environmentally friendly alternatives. As the prospective objective
will address TBT based antifouling paint through establishment of a long-term mechanism, the financial
sustainability of the alternatives industry will be further guaranteed by the expanded market. The market
can be further expanded by exporting competitive alternatives to the neighboring coastal countries.
Based on the local benefits, the phase out of DDT based antifouling paint will reduce the total volume of
DDT that will spread to each corner of the global environment and cause damage to the health human
beings in other regions and the biosphere.
10
It is clear that the cost-effectiveness of this project should not be simply calculated by the unit phase out
cost of DDT per kg due to the nature of the domestic and global benefits intrinsically not easy to
calculate. In summary, the project implementation will achieve a high cost-effectiveness even though it is
not easily quantified.
5.
INSTITUTIONAL COORDINATION AND SUPPORT
a) CORE COMMITMENTS AND LINKAGES
As implementing agency for the Sino-Italian project that developed the Strategy for the Phase-out of
POPs Pesticides in China, UNDP has developed close cooperation and linkage with SEPA and works
closely with the Stockholm Convention Implementation Office. Throughout the implementation of the
Sino-Italian project, UNDP participated actively in all working levels with the NIP Development Leading
Group, and coordinated closely with all relevant government departments and stakeholders, and interacted
with other Implementing and Executing Agencies in the development of the Strategy for Phase out of
POPs Pesticides in China. For the implementation of this project, as follow-up activities to the priority
areas identified in the Strategy and as a high priority action identified in the NIP, UNDP will continue its
established close working relationship with all IAs and EAs and the GEF Secretariat.
b) CONSULTATION, COORDINATION AND COLLABORATION BETWEEN IAS, AND IAS AND
EAS, IF APPROPRIATE.
As one of the implementing agencies active in POPs activities in China, UNDP participates actively and
coordinates closely with all other GEF IAs and EAs such as UNIDO, UNEP, FAO, the World Bank,
Development Banks, bilateral governmental agencies, international and national associations. UNDP
participates actively in POPs workshops and seminars organized by the Government and other IAs, in
addition to being an active member in the TCG. For all workshops concerning UNDP’s POPs activities,
UNIDO, UNEP, World Bank, FAO and other bilateral governments are invited to participate. UNEP,
UNIDO, the World Bank, WHO, FAO, donor governments like Italy, Norway, Sweden, Norway,
Germany, USA, national stakeholders from NIP Leading Group, industrial associations, enterprises and
civil societies participated extensive in the international workshop that took place in June 2004 to discuss
the draft Strategy for Phase out of POPs Pesticides in China and provide valuable comments to enable
UNDP to finalize the Strategy and the draft proposal on alternatives to DDT used in antifouling paint
production.
c) PROJECT IMPLEMENTATION ARRANGEMENT
The project will be implemented under National Execution (NEX) modality. The Convention
Implementation Office (CIO) in the Foreign Economic Cooperation Office (FECO) of SEPA is
responsible for daily management of the project under the direction and guidance of a Deputy Director
General in FECO. SEPA, as the lead national agency, would fully consult and collaborate with all the
stakeholders to guarantee their full involvement and participation. The NIP Development Leading Group
established under the China’s GEF co-financed POPs National Implementation Plan (NIP) development
will provide guidance and supervision for this project and coordinate it with various related ongoing
projects. UNDP will be the GEF Implementing Agency, responsible for monitoring and evaluating project
objectives, activities, output and emerging issues. UNDP will manage the GEF fund based on the
UNDP’s established procedures on GEF-funded projects. Other relevant IAs and EAs, such as UNIDO,
FAO etc. will be fully consulted on technical issues.
11
ANNEX A: INCREMENTAL COST ANALYSIS
A. PROJECT BACKGROUND
DDT is still being used as booster biocide in antifouling paint in China. DDT based antifouling paint is
mainly used by medium and small sized fishing ships for its immediate and strong antifouling effect and
low price. PDF-B survey shows that China has 300,000 fishing ships widely distributed along its coast
extending 18,000km, which will consume 10,000 MT antifouling paints every year, half of which is DDT
based paint and the other half is organotin based antifouling paint. About 250 MT DDT will be used for
production of DDT based antifouling paint per annum. As of 2002, the accumulative total of DDT used
for this purpose since 1950s has reached 10,000 MT. During intergovernmental negotiations of the
Stockholm Convention and after China signed the Convention, China has launched large scale campaigns
to raise awareness of the public and the related industries on the harms of POPs, including DDT, and the
Government’s intention to phase out these POPs. Producer, dealers and some better-off end users of DDT
based antifouling paint have actively switched to other alternatives, including TBT-based anifouling paint.
As a result, From 2002 to 2005, DDT used for antifouling paint production has seen a decrease but still
reached cumulative 1,000 MT as the bulk of end users, mainly fishermen, have to stick to the use of DDT
based antifouling paint due to their limited affordability of other alternatives.
Coastal environmental quality monitoring from year 2000 to 2005 detected residues of DDT and its
degradation derivatives DDD and DDE which are also persistent and toxic in sea water and sediments.
The concentration of DDT in the sediments in some areas in the sea exceeded Class I or II standards of
marine environment quality. The excess DDT concentrations in sediment and sea organisms is directly
related to their extensive usage in DDT based antifouling paint. The use of DDT as pesticide in
agriculture was banned 20 years ago. DDT residues on land, soil, and food have fallen to trace levels.
Therefore, release of DDT from antifouling paint on fishing boats and ships can be considered a new and
a main source of DDT found in marine environment.
DDT is listed in Annex B of Stockholm Convention. According to Article 3, Provision 1 of the
Convention, the Parties shall limit the production and use of the chemicals listed in Annex B. The
Acceptable purpose or specific exemption for the production and use of DDT are limited to disease vector
control and intermediate for production of Dicofol. DDT as an additive in production of antifouling paint
is not considered a permitted use. Meanwhile, according to Article 10 and 11 of the Convention, the
parties shall encourage and develop activities to research, develop and monitor POPs and their
alternatives as well as other potential POPs.
Orgnotine (mainly TBT) based antifouling paints are also widely used by fishing ships and commercial
ships navigating within China’s sea territory. TBT is a high efficiency and low price antifoulant. TBT is
stable in environment and can also be biologically accumulated and enriched. Its harms to environment
include acute death, chronic toxication, deformation, and imposex that can cause reproductive problems
and population decline or extinction. TBT can also disrupt the endocrine system. It is regarded as one of
the most toxic substances that are introduced into the sea, and much research indicates that TBT has
caused significant harm to the marine environment and sea organisms.
Though TBT is not a pollutant to be addressed by POPs Convention, it is the subject of International
Convention on the Control of Harmful Antifouling Systems on Ships (the IMO Convention). IMO
adopted the Convention on October 5, 2001. The IMO Convention is aimed at reducing or eliminating the
negative impacts to the marine environment and human health caused by harmful antifouling systems on
ships. It also establishes a mechanism to prevent one harmful antifouling system from being replaced by
another harmful antifouling system. Due to the lack of feasible alternatives, TBT is still widely used in
China.
12
GEF Instrument states that GEF can provide support to other environmental treaties for which GEF is not
the financial mechanism. TBT as a persistent toxic pollutant can be addressed by GEF projects according
to the Operation Program 10 – Contaminant Based Operational Program in the focal area of International
Waters. Based on the technologies, experience, and instruments obtained from DDT based antifouling
paint phase out can be replicated to phase out TBT so as to support China to accede to the IMO
Convention as a long-term mechanism to protect marine environment and international waters from
pollution caused by harmful antifouling systems on ships.
Antifouling paints are developing towards non-toxic and environmental friendly direction. Biocide free
antifouling technologies such as electrical macromolecule film, fluorine carbon resin coating, organic
silicon resin, and bionic antifouling paint are being actively developed and tested. There is a good
prospect of application of these technologies, but they need a long time to become commercialized in
marketplace.
After PDF-B survey and analysis, 3 antifouling paint formations are selected for consideration to replace
DDT/TBT antifouling paints.
a)
Use other organic booster biocides that are accredited by international authorities to replace
DDT/TBT.
b)
Capsaicine or capsainoids is used as repellant to replace DDT.
c)
Alkali silicate antifouling paint.
The first year of the project will be used to support the above technologies to overcome barriers to
commercialization so that they can meet the requirements to replace DDT in a technically feasible,
economically viable, and environmentally friendly way.
As a signatory party to Stockholm Convention, China is planning to use 10 years to phase out and
eliminate DDT before 2014 according to Strategy for Phase out of POPs Pesticides in China. This project
to phase out DDT usage in antifouling paint production will act as the first step to phase out and eliminate
DDT production and use in China. Established legal and institutional framework, effective economic and
policy instruments, improved technical capacity, and strengthened environmental awareness will continue
to support the ensuing phase out and elimination actions after the completion of the project.
B. INCREMENTAL COST ASSESSMENT
Baseline
DDT based antifouling paint has been in use for more than 30 years in China. Though it is presently used
to a much lesser extent than in the past, its consumption remains relatively stable among the target group
– owners of fishing ships of medium to small sizes. This group is characterized by a relatively low level
of education, environmental awareness and income. The fishermen tend to be resistant to change,
especially where higher cost is involved. Under the prevailing situation, it is not foreseeable that their
income will grow in the near future. All alternatives available in market, mostly copper based, are of
higher price and their prices will keep rising with the market prices of copper in the near future. There is
also debate on the environmental performance of these alternatives, and many scholars call for a cautious
approach in selection of alternatives.
Without the support of this GEF project, the fishermen will continue using DDT based antifouling paint,
unless alternatives having better antifouling effects, sound environmental performance, and lower cost are
made available in the marketplace. Due to lack of specific legal prohibition on use of DDT for production
13
of antifouling paint, manufacturers will continue exploit the market as long as demand exist. Even if such
laws and regulations were formulated and promulgated, its implementation would face challenges or even
be impeded by the very broad and sparse market against under-staffed enforcement forces. As a result,
DDT will continue being released into marine environment, accumulated, transported and transformed in
various environmental media, and will continue to cause damage to global environment and human health.
5,000 MT DDT based antifouling paint will cost 10 million USD per year if the unit price remains at
around 2 USD per kilogram. 4 years’ implementation will give rise to 40 million USD, which constitutes
the direct baseline cost. The indirect baseline cost may be caused by the medical treatment of people
exposed and the environmental treatment of contaminated sites. The indirect baseline cost is estimated to
far exceed the direct baseline cost.
China still uses about 20,000 MT TBT based antifouling paints. Without this project, the lack of feasible
alternatives and the barriers to commercialize alternatives will remain. The environmental problems
caused by TBT antifouling paints will become more significant than today.
Global Environmental Objective
The binding objective of this project is to reduce production of 250 MT DDT per annum used for
production of DDT based antifouling paints by converting to technically feasible, economically viable,
and environmentally friendly alternatives.
The prospective objective of this project is to establish a long-term mechanism to protect the marine
environment from pollution of harmful antifouling systems by supporting China to sign International
Convention on the Control of Harmful Antifouling Systems on Ships (the IMO Convention) based on the
technologies, experience and instruments obtained from phase out of DDT antifouling paint.
Alternative
The GEF alternative very likely provides the only possibility that very promising and already available
alternative technologies to DDT/TBT based antifouling paints can be sustainably deployed. With the GEF
project, already available technologies will be catalyzed to provide environmentally friendly alternatives
that will be promoted for rapid commercialization. Demonstrational enterprises will be selected to
produce these alternatives toward phase out of DDT based antifouling paint.
Cost of production of alternatives constitutes the majority of the co-finance of the project, and GEF
financial support will be mainly used to overcome the barriers to rapid commercialization of these
alternatives. The Executive Agency of the project, FECO/SEPA has successfully leveraged 8.5 million
USD in-kind co-financing from the private sector. The central government will provide 3.75 million USD
as co-financing in cash to establish a safeguarding policy environment and improve the institutional
capacity. Some bilateral sources such as foreign governments and enterprises have expressed strong
interests in providing co-financing.
The experience of phase out of DDT based antifouling paint under this project will create favorable
conditions to accelerate the phase out of TBT based antifouling paint, and to support China to accede to
the IMO Convention and implement the obligations. The promoted competitive alternatives will continue
to take over the TBT antifouling paint market. The marine environment and international waters will be
thus better protected.
Summary of Costs
14
Incremental Cost Matrix
Cost/Benefit
Domestic Benefits
Global Benefits
Outcome 1:
Institutions and
mechanism for
project
management and
coordination
Outcome 2:
Management
information system
(MIS) and
information
management
Baseline (B)
Fishermen will continue to use high
efficiency and low price DDT based
antifouling paint, causing DDT pollution to
local coastal waters and sea organisms and
economic loss. Health loss or threats will
also impact the producers and users due to
occupational exposure to DDT and DDT
based antifouling paints.
Harms of DDT will be spread to the whole
globe and impact the health of the whole
human beings through long-distance
transportation, transformation, and
accumulation.
Only the CIO will pay part of its attention
to DDT usage in production of antifouling
paint under the framework of Strategy for
Phase out of POPs Pesticides in China. No
special institutional settings will be
established for the challenging phase out of
DDT usage. The baseline cost for this
outcome will be 560,000 USD.
General and sparse information was
collected and stored during development of
Strategy for Phase out of POPs Pesticides
in China into the Sino-Italian MIS. Data
and information on TBT will be collected.
The baseline cost will be 200,000 USD.
Alternative (A)
High efficiency and environmentally friendly
alternatives will be used on medium and small
sized fishing boats to reduce DDT release into
the sea and improve quality of marine
environment. Occupational exposure of DDT
will be reduced to safeguard occupational
health.
Harms of DDT that will be spread to the whole
globe and impact the health of the whole human
beings through long-distance transportation,
transformation, and accumulation will be
reduced.
Activity 1
Establish project management
institutions and build their operational capacity.
Act. 1.1 Establish project management
institutions and coordination mechanisms based
on the existing institutional settings.
Act. 1.2 Establish a national expert team to
provide technical and consulting supports to
project implementation.
Act. 1.3 Conduct trainings to improve
managerial and technical capabilities for project
management.
Act. 1.4 Conduct study tour abroad to learn
advanced experience and technologies.
Activity 2
Establish an MIS and website
Act. 2.1 Establish an MIS for the project.
Act. 2.2 Establish a mechanism for data
collection and processing, information
transmission and sharing.
Act. 2.3 Establish a website to disseminate
project information to the public.
15
Increment (A-B)
Barriers to
commercialization of
these sustainable
alternatives will be
removed.
Most activities in the
alternative scenario will
be incremental, and will
need an incremental cost
of 1,090,000 USD.
All activities in the
alternative scenario will
be incremental, and need
a cost of 700,000 USD.
Cost/Benefit
Baseline (B)
No special regulations and standards
regarding the limit on DDT use will be
established or revised. Some general
standards and methods may be modified to
address TBT in response to the IMO
Convention, and this will involve a baseline
cost of 790,000 USD.
Alternative (A)
Activity 3
Establish or revise regulations,
standards, and action plan supported by
capacity building to create an enabling policy
environment for phase out of DDT based
antifouling paint and promotion of sustainable
alternatives.
Act. 3.1 Establish or revise related regulations,
standards, and rules.
Act. 3.2 Revise compulsory rules of inspection
of ship products.
Act. 3.3 Establish and promote a voluntary
certification and labeling program in antifouling
paint sector.
Act. 3.4 Sustain DDT phase out by reducing
potential risk of TBT use in antifouling paint.
Act. 3.5 Strengthen the capacity of related
departments to effectively implement and
enforce regulations, standards and action plan.
Increment (A-B)
Most activities will not
occur or only occur to a
minimal extent if without
this project. The
incremental cost will
involve 700,000 USD.
The conversion from DDT/TBT based
antifouling paints will not be possible to
take place in the short and medium term in
the baseline scenario, and already
technically available alternatives cannot be
commercialized spontaneously. But costs
associated with the production, use and
disposal of DDT antifouling paints should
constitute the baseline cost at 10.5 million
USD.
Activity 4
Adopt multiple means of
technological support, policy induction, market
regulation, and awareness raising and
education to promote the conversion from
DDT/TBT based antifouling paints to
alternatives.
Act. 4.1 Test, select and acquire alternative
technologies.
Act. 4.2 Select demonstration enterprises.
Act. 4.3 Produce, distribute and promote
alternatives.
Act. 4.4 Conduct environmental sound
management of DDT at contaminated sites and
on the equipment.
The incremental cost will
be the expense spent to
remove the barriers to
commercialization of the
sustainable alternatives
by adopting the multiple
means in the alternative
scenario, which is
estimated to be about 6.8
million USD.
Outcome 3:
Enabling policy
environment
Outcome 4:
Conversion from
DDT/TBT based
antifouling paints to
alternatives
16
Cost/Benefit
Outcome 5:
Environmental
education and
awareness raising
Baseline (B)
Producers, dealers, users and disposal staff
will only have very limited awareness of
the harm of DDT based antifouling paint on
the environment and their own health. The
local authorities will not pay due attention
to the problem. The CIO may allocate a
small amount of resources to raise
awareness for this DDT use from other
DDT or POPs phase out projects. The
baseline cost is estimated to be 200,000
USD.
No monitoring and evaluation will be
involved if without this project. Thus, the
baseline cost is zero.
Outcome 6:
Monitoring and
evaluation
Total Cost
USD 12,250,000
Alternative (A)
Activity 5
Conduct education to promote
environmental awareness of the key
stakeholders and the general public, improve
their understanding of the harm of DDT/TBT
based antifouling paints and the benefits of
alternatives.
Act. 5.1 Prepare publicity materials to conduct
environmental education and awareness raising
purpose targeting government officials,
personnel in the industrial field and the general
public through multiple media of TV, radio,
newspaper, magazine, journal, Internet, CDROM, and printing materials.
Act. 5.2 Mobilize NGOs to conduct
community based environmental education and
awareness raising.
Activity 6
Effective monitoring and
evaluation activities on project implementation
and achievement of results.
Act. 6.1 Conduct meetings for project
inception, review progress and project results.
Act. 6.2 Launch field investigations and
inspections to monitor and evaluate progress of
project implementation.
Act. 6.3 Prepare various progress reports to
monitor project progress and performance.
Act. 6.4 Conduct annual project audit.
Increment (A-B)
Most of the activities in
the alternative scenario
will be incremental and
need a cost of 1.8 million
USD.
USD 23,860,000
USD 11,610,000
17
All the cost occurred for
this Outcome will be
incremental cost, at a cost
of 520,000 USD.
ANNEX B: PROJECT LOGICAL FRAMEWORK
Project Strategy
Objectively verifiable indicators
Goal
DDT based antifouling paint is to be substituted by technically feasible, economically viable, and environmentally friendly
alternatives so as to help China fulfill the obligations under Stockholm Convention to control the use of DDT and protect the
environment and human health.
Objectively Verifiable Indicators
Objective
Binding objective: Use of 250
MT DDT per year in the
production of DDT based
antifouling paints will be
stopped.
Prospective objective: A longterm mechanism is to be
established to protect the marine
environment from pollution of
harmful antifouling systems by
supporting China to sign
International Convention on the
Control of Harmful Antifouling
Systems on Ships (the IMO
Convention), based on the
technologies, experience and
instruments gained from the
phase out of DDT based
antifouling paint.
 Annual production of 250 MT DDT used as
additives will be reduced at Tianjin
Chemical Plant.
 Zero DDT should be detected in antifouling
paint.
 Residual or enrichment of DDT in the
marine environmental media and sea
organisms will be found to decrease.
Sources of Verification
 Tender documents to request for
proposals of procurement of
technical service and capital
equipment.
 Phase out and substitution
actions will be supported
by the nation, society and
sector.
 TORs for recruiting consulting
services.
 Barriers can be effectively
removed with necessary
support of the project.
 Work plans.
 Alternatives which are technically feasible,
economically competitive, and
environmentally friendly will be developed,
produced and distributed.
 Barriers to commercialize the alternatives
will be removed.
 Laws, regulations and standards will be
revised or established.
 Experience in phasing out DDT antifouling
paint will be replicated to phase out
organotin based antifouling paints.
 Concentration of organotin in the marine
media will be reduced.
18
Assumptions and Risks
 Revised or newly promulgated laws,
regulations and standards.
 Thematic study reports.
 M & E reports.
 Alternatives production
can become financially
sustainable after the
completion of the project.
 Implementation and
enforcement of policy and
management mechanisms
can continue to work
effectively after the
completion of the project.
Outcome 1
Institutions and
mechanism for project
management and coordination
Activity 1
Establish project
management institutions and
build operational capacity.
Act. 1.1 Establish project
management institutions and
coordination mechanisms.
Act. 1.2 Establish a national
expert team to provide technical
and consulting supports to
project implementation.
Act. 1.3 Conduct trainings to
improve managerial and
technical capabilities for project
implementation.
Act. 1.4 Conduct study tour
abroad.
 A cross sectoral Steering Committee will be
established at the national and local levels.
 A cross sectoral project team will be
established at the national level for daily
project management and coordination.
 3 local Project Management Offices (PMOs)
will be established drawing upon resources
from related departments.
 CTA, NTA and other consultants recruited.
 Government research agencies or private
consulting firms will be selected to provide
technical and consulting services.
 Materials for technical and management
training will be compiled.
 Name list of Steering Committee.
 Agendas and minutes of Steering
Committee meetings.
 Name list of the national project
team, responsibility defined and
work reports.
 Name list of the local PMOs,
responsibility defined, work plan
finalized and work reports.
 TORs for CTA, NTA and other
consultants.
 Training materials for technical and
management training.
 Work plan for study tour abroad.
 Plan for study tour abroad will be developed
and mission report will be drafted and share
to build capacity.
Outcome 2
Management
 A comprehensive evaluation will be
information system (MIS) and
conducted on the management information
information management
systems of the departments of fishing boat
Activity 2
Establish an MIS
inspection, commercial ship inspection, and
and website for the project
hazardous chemicals management, and
Act. 2.1 Establish an MIS.
marine environment management.
Act. 2.2 Establish a mechanism
 Needs of data and information, software and
for effective information
hardware to implement this project will be
transmission and sharing.
assessed.
Act. 2.3 Establish a website to
disseminate project information
 Data exchange protocol will be developed to
to the public.
support information collection, processing
19
 Smooth coordination and
sound cooperation can be
achieved among sectors
and between central and
local levels.
 Various stakeholders can
reach consensus and
recognition of the project
objectives and activities.
 Qualified CTA, NTA and
other consultants can be
recruited and fielded in
time.
 Trainees can be well
organized and mobilized.
 Countries with advanced
technologies and
experience are cooperative
to host the study tour and
share information.
 An on-line operational project MIS.
 An on-line operational project
website.
 Documentation series for MIS
development.
 The needed data can be
made available.
 The hardware and software
configuration of the MIS
for Sino-Italian
Cooperation Project on
Pesticidal POPs can be
extended to accommodate
the MIS for this project.
and transmission among sectors and between
central and local PMOs.
 Database and base model will be developed
to collect and process technical, socioeconomic, and environmental data in MIS.
 A project website will be developed,
maintained and promoted.
Outcome 3
Enabling policy
environment
Activity 3
Establish or
revise regulations, standards,
and action plan supported by
capacity building to create an
enabling policy environment for
phase out of DDT based
antifouling paint and promotion
of sustainable alternatives.
Act. 3.1 Establish or revise
related regulations, standards,
and rules.
Act. 3.2 Revise compulsory
rules of inspection of ship
products
Act. 3.3 Establish and promote
a voluntary certification and
labeling program in the
antifouling paint sector.
Act. 3.4 Sustain DDT phase out
by reducing the potential risk of
TBT use in antifouling paint.
Act. 3.5 Strengthen capacity of
related departments to effectively
implement and enforce
regulations and standards.
 General Specification for Antifouling Paint
on Ship Bottom will be revised taking into
account environmental indicators.
 Method to Detect DDT Content in
Antifouling Paint and Paint Film will be
developed.
 Regulation to Ban DDT Usage for
Antifouling Production Paint and Prohibit
Ships to Use DDT Based Antifouling Paint
will be drafted and made into effect.
 Rule for Inspection of Ship Products and
Rule for Inspection of Fishing Boat Products
will be revised.
 Rule for Voluntary Certification and
Labeling of Antifouling Paints will be
developed.
 Revised General Specification for
Antifouling Paint on Ship Bottom.
 Method to Detect DDT Content in
Antifouling Paint and Paint Film.
 Regulation to Ban DDT Usage for
Antifouling Production Paint and
Prohibit Ships to Use DDT Based
Antifouling Paint.
 Rule for Inspection of Ship Products
and Rule for Inspection of Fishing
Boat Products.
 A Voluntary Certification and
Labeling Program for Antifouling
Paints.
 Dossier for China to accede to the
IMO Convention.
 Dossier for China to accede to the IMO
Convention will be prepared.
 Action Plan for China to Implement the IMO
Convention will be developed.
 Capacity of various departments will be
strengthened.
20
 Action Plan for China to Implement
the IMO Convention.
 Regulations, standards, and
policies can be approved
and made into effects by
related administrative
departments.
 Voluntary certification and
labeling program can exert
complementary functions
with compulsory
inspection rules to promote
the alternatives.
 Active cooperation and
smooth coordination can
be achieved among
different departments.
Outcome 4
Conversion
from DDT based antifouling
paints to alternatives.
Activity 4
Adopt multiple
means of technological support,
policy induction, market
regulation, and awareness
raising and education to
promote the conversion from
DDT/TBT based antifouling
paints to alternatives.
Act. 4.1 Test, select and acquire
alternative technologies.
Act. 4.2 Select demonstration
enterprises.
Act. 4.3 Produce, distribute and
promote alternatives.
Act. 4.4 Conduct environmental
sound management of DDT at
contaminated sites and on
equipment.
 R & D institutes able to synthesize
 Dossier of request for proposal and
 Results from applied
alternative biocides, active chilly ingredients,
bidding proposals.
research can be completed
or other environmentally friendly
on time to be used by the
 Technologies for synthesizing
antifoulants that will be selected.
project.
alternative biocides, active chilly
 Applied researches will be conducted to
ingredients, or other environmentally  Issues of intellectual
promote the maturity of the alternative
friendly antifoulants.
property rights can be
technologies for use by the project.
effectively addressed in
 Technologies for full scale
time for existing
 On-ship coating experiment and scale-up
production of alternative antifouling
alternative technologies or
production experiment will be conducted.
paints.
products that can be
 Alternatives will prove to be technically
 Feasibility study reports and EIA
promoted by this project.
feasible, environmentally friendly and can be
reports.
 Application and EIA
produced at scale of economy.
 Approval documents from
reports for alternative
 Antifouling paint manufacturers having
Government
production projects can be
strong technical and managerial competence
approved by authorities.
 Certificates and labels granted to
and sound business plan will be selected.
enterprises.
 Active cooperation among
 Feasibility study and EIA will be conducted
enterprises, dealers and
 Enterprise records of production and
according to related construction project
users can be achieved.
sale.
approval procedures in China.
 Alternative production
 Handbooks to apply alternatives.
 Full scale production of alternatives will be
industry can be
 Feasibility study reports on disposal
started.
commercialized after the
of DDT based antifouling paint
completion of the project.
 Handbook to apply alternatives will be
equipment and part of DDT
compiled and distributed.
 Medium and small sized
production equipment.
enterprises can be well
 Incentives will be provided to mass
supported and guided to
production and purchase.
produce alternatives and
 Part of DDT production equipment will be
provide distribution and
closed and disposed at Tianjin Chemical
after-sale services.
Plant.
Outcome 5
Environmental
education and awareness
raising
 A qualified director will be invited to direct a  Film of DDT/TBT based antifouling
film.
paints and marine environmental
21
 Good quality publicity
materials of various forms
Activity 5
Conduct
environmental education to
promote the environmental
awareness of the key
stakeholders and the public,
improve their understanding of
the harm of DDT/TBT based
antifouling paints and the
benefits of alternatives.
Act. 5.1 Prepare publicity
materials for environmental
education and awareness raising
purpose targeting government
officials, personnel in the
industrial field and the public
through multiple media of TV,
radio, newspaper, magazine,
journal, Internet, CD-ROM, and
printing materials.
Act. 5.2 Mobilize NGOs to
conduct community based
environmental education and
awareness raising.
 A TV special for marine environmental
protection and antifouling systems will be
made.
 Special programs will be made on local radio
stations.
 A special column will be arranged in a
professional journal.
 Contents introducing marine antifouling
system will be added to the textbook for
environmental education in local middle and
primary schools.
 The project website will be regularly
updated.
protection.
 News reported on media.
 Materials for training of
administrative staff of local
government agencies.
 Materials for training of NGOs in
universities and civil society.
 Focal points of the communities.
 Contents in middle and primary
school textbooks introducing
antifouling paints and marine
environmental protection.
 Articles in special column of
professional journal.
 2 press conferences will be held for
milestone events.
 Nation wide traveling exhibition will be
launched to disseminate the project results.
 A fund raising activity will be organized for
deformed children suffering from toxic
antifouling paints.
 Joint exhibitions will be held with local
marine exhibition halls.
 NGOs, universities and civil society will be
mobilized to popularize knowledge about
antifouling paints and raise their
environmental awareness in community
level.
 Focal points in communities and fishermen
organizations will be established for longterm alternative promotion and
environmental awareness raising.
22
 Plan for joint exhibition with local
marine exhibition halls.
 Work plan for nation wide
exhibition.
and targeting various
audiences can be produced
in time.
 Active public participation.
 Environmental education will be conducted
systematically in local middle and primary
schools.
 Training materials will be compiled and
training workshops held for the local
administrative staff from departments of
economic trade, fishery, navigation, and
environmental protection.
Outcome 6
Monitoring and
evaluation
Activity 6
Effective
monitoring and evaluation on
project implementation and
achieved results
Act. 6.1 Conduct regular
meetings to review progress and
project result review.
Act. 6.2 Launch field
investigations and inspections to
monitor and evaluate progress of
project implementation.
Act. 6.3 Prepare progress
reports for measurement of
Means of Verification to monitor
project purpose indicators,
project progress and
performance.
Act. 6.4 Conduct annual
project audit.
 Inception meeting, annual steering
committee meetings, annual project review
meetings and tripartite project review
meetings will be held.
 Meeting minutes or memorandum.
 Special inspections on enforcement of
regulations, rules, and standards will be
launched.
 Reports of independent project
evaluation.
 Independent mid-term and final project
evaluations will be held.
 Memorandum or minutes of meeting for
each field mission, annual progress and
experience review reports, and the final
project result and experience review reports
will be prepared.
23
 Annual project reviews.
 Final project review.
 Materials for monitoring
and evaluation can be
provided sufficiently in
advance of the actual
inspections, investigations,
and various review
meetings.
 The related staff at national
and local levels for
implementing the project
can be available for
making presentations
assisting field
investigations.
 There is open, transparent,
and effective
communication between
the M & E staff and the
project implementation
staff.
ANNEX C: DETAILED PROJECT BUDGET
Project Title: Alternatives to DDT Usage in the Production of Antifouling Paint
GEF Outcome /
Atlas Activity*
Outcome 1:
Establish Project
Management
Institutions and
Build Operational
Capacity
GOC
Amount
(USD) 2006
150,000
Amount
(USD) 2008
150,000
Amount
(USD) 2008
100,000
Amount
(USD) 2009
50,000
Total (USD)
All Years
450,000
GEF
250,000
200,000
150,000
150,000
750,000
GOC
GEF
Private Industry
GOC
20,000
80,000
20,000
60,000
20,000
40,000
20,000
40,000
80,000
220,000
10,000
20,000
30,000
GEF
Private Industry
GOC
GEF
Private Industry
20,000
20,000
40,000
80,000
80,000
Activities
Source of Funds
Activity 1.1
Establish
project management
institutions and
coordination mechanisms
Activity 1.2
Establish a
national expert team
Activity 1.3
trainings
Conduct
Activity 1.4
Conduct
study tour abroad
Private Industry
Sub-total
Activity 2.1
Establish
MIS and strengthen
information support
Outcome 2:
Establish MIS and
Website
Activity 2.2
Data
collection, analysis,
transmission and sharing.
Activity 2.3
a website
Outcome 3:
Establish
Sub-total
Activity 3.1
Establish
or revise related
regulations, standards, and
rules.
GOC
GEF
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
GOC
GEF
530,000
550,000
310,000
260,000
1,650,000
10,000
30,000
20,000
10,000
70,000
50,000
100,000
50,000
200,000
50,000
200,000
50,000
100,000
200,000
600,000
10,000
10,000
5,000
5,000
30,000
170,000
100,000
100,000
290,000
100,000
100,000
275,000
165,000
900,000
200,000
200,000
Private Industry
24
Project Title: Alternatives to DDT Usage in the Production of Antifouling Paint
GEF Outcome /
Atlas Activity*
Establish or Revise
Regulations,
Standards, and
Action Plan
Activities
Activity 3.2
Revise
compulsory rules of
inspection of ship
products.
Activity 3.3
Establish
and promote a voluntary
certification and labeling
program
Activity 3.4
Sustain
the results of DDT phase
out
Activity 3.5 Strengthen
capacity and enforcement
GOC
Amount
(USD) 2008
20,000
GEF
30,000
30,000
20,000
20,000
20,000
20,000
Source of Funds
Outcome 4;
Adopt Multiple
means of
Technological
Support, Policy
Induction, Market
Regulation, and
Awareness Raising
and Education to
Promote
Conversion
Activity 4.2
Select
demonstration enterprises
and business plan
improvement
Activity 4.3 Production
and distribution of
alternatives.
Activity 4.4
Conduct
environmental sound
management of DDT
contaminated sites and
equipment.
Sub-total
Activity 5.1
Prepare
Amount
(USD) 2008
Amount
(USD) 2009
Total (USD)
All Years
20,000
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
Sub-total
Activity 4.1
Test,
select and acquire
alternative technologies.
Amount
(USD) 2006
GOC
GEF
Private Industry
GOC
GEF
75,000
100,000
75,000
50,000
300,000
50,000
75,000
75,000
150,000
75,000
150,000
50,000
75,000
250,000
450,000
400,000
750,000
615,000
750,000
300,000
175,000
1,490,000
1,500,000
1,750,000
1,250,000
3,000,000
50,000
50,000
100,000
Private Industry
GOC
GEF
Private Industry
GOC
GEF
1,500,000
3,200,000
200,000
400,000
1,000,000
3,200,000
200,000
200,000
500,000
2,100,000
100,000
100,000
3,000,000
8,500,000
500,000
700,000
7,350,000
50,000
4,600,000
50,000
2,800,000
50,000
17,300,000
200,000
Private Industry
GOC
2,550,000
50,000
25
Project Title: Alternatives to DDT Usage in the Production of Antifouling Paint
GEF Outcome /
Atlas Activity*
Outcome 5:
Conduct
Environmental
Education to
Promote Awareness
Outcome 6:
Monitoring and
Evaluation
Activities
publicity materials to
promote environmental
education and awareness
raising
Activity 5.2
Mobilize
NGOs to promote
environmental education
and awareness
Sub-total
Activity 6.1
Conduct
meetings to review and
monitor progress of
project activities
Activity 6.2
Launch
field investigations and
inspections to facilitate
M&E
Activity 6.3
Prepare
progress and monitoring
reports
Activity 6.4
Conduct
annual project audit
Source of Funds
GEF
Amount
(USD) 2006
300,000
Amount
(USD) 2008
300,000
Amount
(USD) 2008
200,000
Amount
(USD) 2009
200,000
Total (USD)
All Years
1,000,000
200,000
200,000
200,000
200,000
800,000
550,000
550,000
450,000
450,000
2,000,000
50,000
80,000
60,000
50,000
240,000
50,000
50,000
40,000
40,000
180,000
20,000
20,000
20,000
20,000
80,000
10,000
20,000
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
GOC
GEF
Private Industry
Sub-total
Total Government of China Contribution
Total GEF Allocation
Total Private Industry Contribution
Total Budget excluding PDF-B approval
PDF-B GEF Resources
PDF-B Co-financing
10,000
120,000
160,000
120,000
120,000
520,000
1,255,000
3,065,000
0
4,320,000
1,555,000
4,760,000
3,200,000
9,515,000
570,000
2,285,000
3,200,000
6,055,000
370,000
1,500,000
2,100,000
3,970,000
3,750,000
11,610,000
8,500,000
23,860,000
295,000
70,000
Total Project budget including PDF-B approval
GOC = Government of China
24,225,000
26
ANNEX D: RESPONSE TO PROJECT REVIEWS
a) CONVENTION SECRETARIAT COMMENTS AND IA/EXA RESPONSE
None
b) STAP EXPERT REVIEW AND IA/EXA RESPONSE
Professor Paul K.S. Lam, Professor (Chair) of Biology
Department of Biology and Chemistry
City University of Hong Kong, Tat Chee Avenue, Kowloon, Hong Kong SAR
28 March 2006
1. General Overview
This project addresses an important area related to the ecological and human health risks associated with the
environmental release and occurrence of DDT, particular in regards to its use as an additive in antifoulants.
Not withstanding some apparently negative comments, there are many positive aspects in the proposal to which the
reviewer offers his full support. The review opted to concentrate on areas that need attention, and, perhaps,
improvement. Comments are intended to improve the proposal so that it will have an even greater impact.
Overall, the reviewer supports his initiative.
Comment: no response necessary
2. Specific comments, observations and questions
STAP Comments
Responses to STAP Comments and Corresponding
Changes in the Document
Alternative technologies
Comment 1) The proponents have done a throughout
literature review on the available technologies for
developing alternatives to DDT-based antifouling
paints. It is proposed that three technologies are
relevant in this context. However, it appears that the
range of alternative technologies is limited and that
there is still a lot of room for further development in
this area. More research is clearly needed although it
may not be part of the present proposal. A more
detailed risk-benefit analysis on the various
technologies (with relevant key references given)
would be instructive, and should be included in the
proposal to establish the feasibility and credibility of
the proposed project
Besides literature review, extensive field surveys to
R&D institutions were conducted during PDF-B phase
to learn state-of-the-art technologies and development
trend. Survey of available alternatives in the market was
also carried out to investigate commercialization status.
A special workshop of experts was organized to
brainstorm on suitable alternatives for this project. An
international survey by phone, e-mails, and
teleconferences was also conducted to learn international
experience in developing sustainable alternatives. Based
on the results of these works, a thematic report on
alternatives and analysis of their applicability was
extensively reviewed and concluded with the selection in
principle of three candidate alternative technologies. In
the revised project document under Part V, Section IV
(including Table nos. 6, and 7) and on Page 3 and 4,
under Outcome 4 of the Executive Summary, only the
important findings and conclusions are extracted to
highlight the selection of these suitable and sustainable
alternatives.
As China ratified the Stockholm Convention, it is legally
binding for China to phase out DDT. Since China has
not yet acceded to the IMO Convention, TBT antifouling
system is not subject to control at the moment. It is
anticipated that the experience and capacity built on
eliminating DDT as additive in antifouling paint in this
project will contribute to China’s subsequent effort in
phasing out TBT-based antifouling paint and other
Comment 2) Linkage between DDT- and TBT-based
antifouling paints is not clear in the proposal…. It
should be noted that one possible outcome may be that
fisherman will turn to TBT-based paint when DDTbased formulations are under stricter control or
“eliminated” This scenario should be explored and
covered in the proposal.
27
harmful antifouling systems. This need to strengthen the
linkage of the phase out of DDT and the need to
eliminating the risk in switching to TBT after strict
control of DDT is further elaborated throughout the
revised project document and Executive Summary.
Global environmental benefits
Comment: Concern with the major challenge of
implementation of the new technologies/products on a
large enough scale to effect an appreciable change in
existing and future environmental levels of DDT. This
proposal considers the best-case scenario only. It is
necessary also to consider contingency plans in the
event that the alternative technologies turned out to be
not useful or the proportion of fishermen taking up the
offer is too small – the worst-case scenario
There is some probability for the worst-case scenario to
take place and the probability will be more likely to be
triggered by other factors than high-level technologies.
Full mobilization and buy-in of the end users, especially
the fishermen, of the new products will be crucial to
guarantee the success of the project. Significant efforts
have been included under activities 4.3 and 5.2 in the
revised project document, and Outcomes 3, 4 and 5 in
pages 3 and 4 of the Executive Summary to fully
mobilize end users, influence their consumption
behaviours, forge partnership and promote alternatives
including incentive schemes, to assure the sustained
acceptance of the alternatives.
Replicability
Comment: It has to be emphasized that China is a
country with a huge population and many unique
socio-economic characteristics not shared by many
nations.
a direct transplantation of the current
proposed work to another country will unlikely be
productive or useful
Replicability of this project exists in 2 aspects: i)
Experience in phasing out DDT to be replicated to phase
out of TBT and other harmful antifouling systems in
China and other similar regions and countries; ii)
Experience in phasing out 5% of DDT used as additive
to be replicated to the phase out of the remaining DDT
in China and other similar regions and countries. While
direct transplantation may not be realized as China is the
only country still using DDT as additive in the
production of antifouling paint, alternatives tested and
produced locally at a more reasonable cost, will definite
benefit other countries in the region. See Sustainability
and Replicability under Part II of the project document
and Replicability in Section 3 of the Executive
Summary.
Sustainability
Comment 1): On a number of occasions, proponents
stated that support of GEF is essential in
implementation this project. This does call into
question the sustainability of the project after the
funding from GEF has expired. The proponents need to
spell out clearly (a) what part of the long-term work
requires GEF support; and (b) how China will be able
to sustain the efforts upon expiry of funding from this
project.
In the proposal, it was stated that the project “will
select, through open bidding process those
manufacturers that are technically and economically
competitive and with sound business plans to produce
and promote alternatives in the target market”. It is
important to realize that the success of this project will
depend crucially on the participation and cooperation of
small and medium sized enterprises, as well as
“backyard” factories. Some clear strategies need to be
developed to ensure an active involvement of all parties
concerned
The GEF support is essential to the project mainly due to
the incremental nature that generates global
environmental benefits based on the needs of domestic
sustainable development. The global environmental
benefits after the completion of the project will be
sustained by i) established policy to ban DDT based
antifouling paint and to protect marine environment and
human health from pollution of harmful antifouling
systems based on the technologies, experience and
instruments obtained from phase out of DDT based
antifouling paint, ii) strengthened capacity to implement
the established policy, and iii) commercialized
alternatives to play a dominant role in the market place.
These same factors, together with China’s subsequent
phase out actions on TBT based antifouling system, will
also ensure sustainability of the phase out of DDT based
antifouling paint, leading to the establishment of an
environmentally sustainable antifouling system to ensure
the sustainability of domestic benefits
28
Comment 2): The suggestion that “Favorable policies
have been implemented by the state to encourage the
development of ocean-going fishing and fishing in open
seas, and reduce the number of small-sized fishing ships
in coastal waters by encouraging fishermen adopt
alternative sources of livelihood” is unrealistic in a vast
developing country like China. The only way forward is
to get them on board.
As reflected in the revised project document, besides
compulsory phase out of DDT based antifouling paint,
the project will create a bigger market for the
alternatives by subsequently targeting at phase out of
TBT based antifouling system. The small and medium
sized enterprises can grasp this opportunity based on
their local advantages on direct distribution to and
interactions with the end users. They will be supported
by this project to convert to production and distribution
alternatives through technical trainings on available
technologies. They will also be encouraged to form
consortium to bid on participation and financial support
to produce alternatives. Outreach efforts will
demonstrate and promote to fishermen the benefits of
using alternatives, including through community based
activities and dealers, and incentive scheme.
Involvement of Stakeholders
Comment: The current proposal does mention the
involvement of various stakeholders.
the most
important group that will require special attention is the
fishermen (the end-users). Given that China is a big
country, and most of the end-users belong to a group
which is “characterized by a relatively low level of
education, environmental awareness and income”, the
proponents need to have a detailed plan to work with the
fishermen and convince them to adopt the new
technologies and used the new products. , this is vital to
the success of this project. Indeed, this project requires
the support of feasible and affordable technologies,
timely and appropriate legislation and a strong
commitment to law enforcement. Environmental
improvement in this case can only be driven by the
above factors, without which the project has a very low
chance of success.
Capacity Building
Comment: There are plans for capacity building in
the proposal. The plan is relatively clear for scientists,
government officials, but is less clear for the “men on
the ground”. These are the people that will ultimately
determine the success or failure of the project. Not
enough information is there to convince this reviewer
that something really different will be introduced in
this project. Setting up of local offices and organizing
workshops will certainly help, but will not be
sufficient to mobilize many millions of fishermen and
fishing boat owners to make that change. Illegal use
will be a challenge unless a real substitute for DDTbased antifouling paint is found which is technically
feasible, economically viable, and environmentally
friendly. There are always some risks in developing
technologies of this nature, and help may be needed
from the wider scientific community in this regard.
Interaction with end-users
Comment:
Costs
involved
setting
up
committees/offices, organize workshops/conference
should be kept to a minimum so that more resources
This project pays particular attentions to those
characteristics with this group of end users. Firstly, the
price of the alternatives will be carefully considered and
efforts will be deployed to decrease the cost through
technological improvements and other means through
the support of the project to a level acceptable to the end
users. Secondly, innovative cultural and community
based programs/strategy of demonstration, education,
incentives and partnership will be developed to promote
and convince the end users to accept the alternatives.
PART II of the project document describes more details
on these actions.
Capacity will be strengthened with community based
NGOs, local government departments and institutions,
local partnerships that will interact activities and interact
with the end-users, especially the fishermen. Substantial
efforts will be deployed to targeting the end-users in
promoting and demonstrating the benefits of
alternatives, to change their consumption behaviours
with affordable price structure and incentives, as
elaborated in the revised project document. The plan will
be further fine tuned during project implementation to
address the vast and diverse socio-economic background
the project will cover.
As reflected in the revised project document, the major
components of the budget are allocated to achieving
regulatory measures to ensure success and sustainability
29
can be diverted to implementing the project at the
ground level – interacting with fishermen and fishing
boat owners. Rather than overseas study tour, it may be
more profitable, if necessary, to invite relevant people
to come to China to share experiences so that more
local people can benefit
of the phase out of DDT based antifouling paint, through
the promotion and production of suitable and
environmentally sustainable alternatives, including
China’s subsequent actions to achieve phase out of TBT
based antifouling system, and through extensive
environmental awareness education targeting the endusers. The largest budget goes to the selection,
acquisition and technological improvements of
alternative technologies and the reduction of production
costs so that the fishermen can accept the alternatives
without extra economic burden. Substantial amount will
also be devoted to addressing and interacting with the
fishermen to promote the alternatives and address their
consumption behaviour on alternatives.
c) GEF SECRETARIAT AND OTHER AGENCIES’ COMMENTS AND IA/EXA RESPONSE
i)
GEF Secretariat Concept Agreement Review on PDF-B Phase
November 1, 2005
Comments
Responses
Sustainability
Comment: Sustainability outlined in a very conceptual
way
The regulatory mechanism established and the technical
and managerial capacity strengthened will lay a strong
foundation and provide experience and lessons for
eliminating other applications of DDT. Sustainability of
this project will be guaranteed from the following
aspects: i) intensive mobilization of all related
stakeholders throughout the process; (ii) demonstration
of the effectiveness of environment-friendly alternative
technologies/ products; (iii) support capacity building at
both national and local levels; (iv) formulate laws,
regulations and rules to control and manage DDT based
antifouling paint and promote alternatives, and provide
incentives for enforcement. The successful experience
will also assist to accelerate the phase out of TBT
antifouling paint, support China to accede to IMO, to
establish a long-term mechanism to protect marine
environment and human health.
Replicability
Comment: There seems to be little scope for
replication, as China is the only country having
reported such a use of DDT
It is expected that the experience gained through this
project can be applied to similar or related projects
within China, including eventual elimination of other
DDT-based operations such as Dicofol production
(PDF-B already approved). The mechanisms for
establishing the regulatory framework, as well as
establishing a procedure for introduction and
commercialization of alternative technology will be able
to be applied not only in China, but in other countries
with diverse populations and large geographic areas.
The education, publicity and outreach campaign
developed will be easily adaptable to other applications
as well.
30
This project will conduct strategic study at the latter
stage of implementation to replicate the experience and
lessons obtained from this project to phase out TBTbased antifouling paints, that can serve as an example to
other countries in the region
Stakeholder Involvement
Comment: Evident of stakeholder involvement in
project preparation. Stakeholder involvement in project
implementation
Major national and local government, scientific
institutions, and private sectors concerned with
elimination of DDT used as additive in antifouling paint
production in China have already participated actively in
developing the Strategy for Phase out of POPs Pesticides
under the Sino-Italian POPs project, and have been
extensively involved in the PDF-B project preparation
phase. Implementation of the full-size project foresees
involvement of all major stakeholder groups at all
phases of the project.
Monitoring and Evaluation
Comment: M&E not outlined
Indicative M&E workplan and corresponding budget has
been included in the Monitoring and Evaluation section.
The Logical Framework Matrix also provides
performance and impact indicators for project
implementation along with their corresponding means of
verification. These will form the basis on which the
project’s Monitoring and Evaluation system will be
built.
Financing Plan
Comment: Estimated budget of US$25 million does
not seem to be supported by the list of proposed
activities. Incremental costs analysis should take into
account of real domestic benefits
Total FSP budget of 23.86 million USD will support
activities to establish institutional setting and
mechanism, build capacity for effective project
management. In addition, it will establish or revise
regulations, standards and incentives necessary to
support a sustainable phase-out of DDT-based paints
through the production, distribution and use of
sustainable alternatives. GEF resources of 11.61 million
USD will be used to overcome the barriers to rapid
commercialization of the alternatives, establish or revise
policies, regulations and standards to create enabling
policy environment to sustain the conversion to
eliminate 250 MT per year of DDT usage. A total of
12.25 million USD co-financing by the Government of
China and the private sector will cover cost of
production of alternatives, to account for the domestic
benefits.
Consultation, Coordination, Collaboration between IAs and IAs and EAs, if appropriate
Comment: Consultation and coordination in particular During preparation of FSP, IAs and EAs such as UNEP,
with Agencies that might have relevant expertise, IMO UNIDO, as well as international institutions in
and UNIDO (RENPAP)
developed countries have been extensively consulted,
especially on existing availability and experience of
alternatives. Collaboration and coordination with IMO
will be further strengthened especially taking into
consideration that the successful experience will assist to
31
accelerate the phase out of TBT antifouling paint ,
banned under IMO
Terms of Reference
Comment 1: Relevant stakeholders outside of
FECO/SEPA to be engaged in project preparation
Major national and local government, scientific
institutions, and private sectors concerned with
elimination of DDT used as additive in antifouling paint
production in China have already participated actively in
developing the Strategy for Phase out of POPs Pesticides
under the Sino-Italian POPs project, and have been
extensively involved in the PDF-B project preparation
phase. Implementation of the full-size project foresees
involvement of all major stakeholder groups at all
phases of the project.
Under FSP, FECO/SEPA has successfully leveraged 68
million RMB, or equivalent of 8.5 million USD from
private sector. The central government will provide 30
million RMB, or equivalent of 3.75 million USD as cofinancing, therefore a total of 12.25 million USD cofinancing has been secured against the total FSP budget
of 23.86 million USD.
Comment 2: Insufficient level of co-financing
ii)
UNEP comments on PDF-B
19 December 2005
Comments
Responses
DDT usage in antifouling paint production
Comment: China is the only country reported this use
of DDT, there should be a wealth of experience to tap
into before doing research in developing alternative
products
During PDF-B phase, experience of developed countries
has been tapped into. Available alternative technologies
and products have been researched and evaluated. Initial
comparative assessment of candidate technologies and
possible improvements has been conducted, and criteria
for selection has been defined, to be employed during
FSP phase
Involvement of existing production enterprises
Comment: More focus should be given in the
inception phase to involving existing production
facilities and enterprises s they are key-players.
Distributors should also be included
Major national and local government, scientific
institutions, and private sectors concerned with
elimination of DDT used as additive in antifouling paint
production in China have already participated actively in
developing the Strategy for Phase out of POPs Pesticides
under the Sino-Italian POPs project, and have been
extensively involved in the PDF-B project preparation
phase. Implementation of the full-size project foresees
involvement of all major stakeholder groups at all
phases of the project.
Role of end-users
Comment: Role of fishermen not obvious. Training on
application technology of alternative products is
doubtful
FSP has been redesigned to establish project
management institutions and build operational capacity
to ensure effective implementation. End-users will be
targeted through promotion of reasonable costed
alternatives and through policies and regulations on
DDT based antifouling paint
32
Regulatory measures
Comment: Regulatory controls should be developed
as a matter of urgency under component 2 on capacity
building and policy making, with target dates or
deadlines for phase-out
One important outcome of FSP is an enabling policy
environment through establishment or revision of
regulations, standards and action plans, and supported by
capacity building, to create an enabling policy
environment for phase-out of DDT based antifouling
paint and promotion of sustainable alternatives. The
successful experience will also assist to accelerate the
phase out of TBT antifouling paint
Environmental burden
Comment: Environmental burden due to DDT in paint
should be calculated and described more clearly
Survey data conducted during PDF-B phase has been
extrapolated to DDT usage of 250 MT per year as
additive in the production of approximately 5,000 DDT
based antifouling paint
Incremental cost analysis
Comment: 25 million USD in incremental costs seem
to be on the high side for the replacement of a 5%
component (total 180 MT/year)
iii)
Total FSP budget of 23.86 million USD will support
activities to establish institutional setting and
mechanism, build capacity for effective project
management. In addition, it will establish or revise
regulations, standards and incentives necessary to
support a sustainable phase-out of DDT-based paints
through the production, distribution and use of
sustainable alternatives. GEF resources of 11.61 million
USD will be used to overcome the barriers to rapid
commercialization of the alternatives, establish or revise
policies, regulations and standards to create enabling
policy environment to sustain the conversion to
eliminate 250 MT per year of DDT usage. A total of
12.25 million USD co-financing by the Government of
China and the private sector will cover cost of
production of alternatives, to account for the domestic
benefits.
GEF Secretariat Concept Agreement Review on Work Program Inclusion
April 10, 2006
Comments
Responses
Alternative technologies / products
Comments: The discussion of available alternatives
and their advantages/disadvantages and what to do
about it is unclear in the Executive Summary, as well
as in the Project Brief. The three proposed alternatives
seem to have major disadvantages. Is the project to
improve on these alternatives at the table in annex
suggested?
More detailed description of the development status of
the alternatives is made in f) Candidate Alternative
Technologies, Part V, Section IV in the Project Brief, as
well as in page 3 and 4 under Outcome 4 of the
Executive Summary to verify their availability in a
technical sense. It can now clearly see that the
disadvantages associated with the alternatives are lack of
testing and application to move from laboratory scale
experiment to scale production in factory, as well as the
currently high price of (imported) alternatives. This can
be overcome with the support of this project within the
first year of project implementation.
- The statement that GEF alternative will support "very
promising and already available technologies" is not
supported by the earlier description of the limitations
of the alternatives.
33
“Very promising and already available technologies” has
a two-fold meaning. First, “very promising” refers to the
environmental soundness and the room for technological
improvement and cost reduction. Second, “already
available” refers to the mature status of research and
development of these alternative technologies at least in
laboratory experiments and trials. In fact, most of these
alternatives technologies have achieved successful patch
test results. (Page 3 and 4, Outcome 4 of the Executive
Summary)
Amounts of DDT and non-DDT based antifouling paints
Comments: The IC analysis notes that production of During intergovernmental negotiations of Stockholm
DDT based antifouling paint has decreased since 2002, Convention and after China signed the Convention,
in favor of what, TBT?
China has launched large scale campaigns to raise
awareness of the public and related industries on the
- 10,000 and 20,000 of antifouling paint are quoted as harms of POPs, including DDT, and the Government’s
being used per year.
intention to phase out these POPs. Producer, dealers and
some better-off end users of DDT based antifouling
paint have actively switched to other alternatives (TBT
based and other alternatives). As a result, from 2002 to
2005, DDT used for antifouling paint production has
seen a decrease but still reached cumulative 1,000 MT as
the bulk of end users (mainly fishermen) have to stick to
the use of DDT based antifouling paint due to their
limited affordability of those other alternatives.
10,000 and 20,000 MT antifouling paints are quoted as
being used per year respectively following the
justifications below:

The PDF-B survey shows that China has 300,000
fishing ships widely distributed along its 18,000
km coastline, which consumes 10,000 MT
antifouling paints annually, half (5,000 MT) of
which is DDT based, while the remaining 5,000
MT is TBT based antifouling paint

It is estimated by China Maritime Bureau that
commercial ships navigating in domestic sea
territory will consume about 20,000 MT TBT
based antifouling paints annually with a working
life of 3 years, this is in addition to TBT used in
fishing ships, therefore total consumption of TBT
based antifouling paint is 25,000 MT per year

In addition, there are 35,000 MT consumption of
TBT/DDT free antifouling paint by ocean-going
commercial ships, making the total antifouling
consumption of 65,000 MT per year (Page 1,
Executive Summary)
Cost-effectiveness
Comments: Can the claim that the environmental and
health damage from DDT in antifouling paint far
exceed the baseline cost be substantiated? (Besides the
substantive point which is of interest to me, it is a
strange way to word this)
No systematic evaluation has been done regarding the
socio-economic and environmental impacts of DDT uses
since 1950s. Marine environmental quality degradation,
aquatic product quality degradation and yield decrease,
and human health damage are caused by interactive
factors including marine eutrophication, over harvest,
34
The cost effectiveness section needs strengthening.
and many other complicated factors, of which DDT use
in antifouling paint is only one of the most important
factors. There is a lack of thematic data and research to
this use. Therefore, it is not possible to precisely
evaluate the cost of environmental quality degradation
and human health damage by using such methods as
shadow price, opportunity cost, preventive payment, or
medical care cost. Also, the benefits from using
alternatives will also be difficult to evaluate. However,
some practical estimation are made based on the data
gathered from the PDF-B phase and literature review,
and the results show the implementation of this project
will achieve a significant cost-effectiveness. Part V,
Section IV in the Project Brief provides more details
regarding the analysis of cost-effectiveness.
During the project implementation, M & E activities will
gather the needed data for a more precise and
comprehensive evaluation of the project costeffectiveness. See also Section 4 b) of the Executive
Summary
Sustainability
Comments: Please elaborate on sustainable production
phase out (quota system for example)
Due to the urgency to stop this DDT usage in the
production of antifouling paint, the project does not rely
on a quota system, but adopts multiple means including
policies, technological and market instruments to switch
the production of DDT based antifouling paint to the
production of alternatives swiftly in the beginning phase
of project implementation, with the market instruments
to play the decisive role in the latter stage and to sustain
the production of alternatives after the completion of the
project based on the established regulatory systems and
improved capacities from the project, and the
opportunity for profit by the manufacturers. (Outcomes
3 and 4, page 3 of Executive Summary)
Indicators and targets in Log Frame
Comments: The Log Frame includes numerous
indicators and targets. Probably too many to be useful
as a tool to access whether, ultimately, the project is a
success or not. It would be useful to pull out some sort
of "results" table with a limited number of the most
meaningful quantifiable indicators and targets, one/two
per component.
Some most meaningful indicators are extracted from the
Log Frame in the Executive Summary and added to
Table 2 in the Project Brief as key impact indicators.
Only the main "Party" responsible for the particular
M&E activity is kept in Table 1 - for M&E work plan in
the revised Project Brief.
The table for M&E work plan looks comprehensive but
includes too many "responsible parties" To be
meaningful, that column should only list the main
"Party" responsible for the particular M or E activity,
not all the people involved.
Longer term monitoring and evaluation
Comments: It is unlikely that levels in organisms will
be seen to decrease over the life of the project (4 years)
in a significant way as suggested, but the project
Activity 2.2 under Outcome 2 in the Project Brief has
been revised to include the establishment of a
mechanism to ensure long-term information flow to
35
should established a baseline against which longer term
progress can be gauged. This implies that the Chinese
authorities establish a monitoring protocol and commit
to reported to the COP under Art. 16 on reductions in
environmental levels of DDT in the coastal zone as a
result of the phase out of DDT used as antifouling
paint.
facilitate reporting requirements, after completion of the
project. (Outcome 2, page 3 of Executive Summary)
Co-financing
Comments: The contribution expected from the
private sector needs to be better described to provide
justification for the claim of US$8.5 million cofinancing from the enterprises.
During the PDF-B phase the CIO has had extensive
communication with antifouling paint manufacturers and
achieved positive response from them in providing cofinancing to the project. The CIO published a call for
expression of interest in its official website
(www.chinapops.org), and notified all the antifouling
paint manufacturers in China by email, telephone and
meeting. So far, 7 enterprises have submitted their
commitment to providing co-financing. Their in-kind
contributions in fixed assets have also been verified by
independent asset evaluation entities. During project
implementation, 3 to 5 enterprises will be selected to
provide a total co-financing of 68 million RMB, or
equivalent of 8.5 million USD, for production and
promotion of alternatives in this project.
In-kind co-finance from enterprises will cover land
acquisition and plant construction, production
equipment, analytical instruments, raw materials,
employee salary, enterprise R & D and training, and
advertisement expenses. Letters of commitment to
providing co-finance are annexed to Annex E of the
Executive Summary.
Education and awareness raising
Comments: Nearly 2 Millions "incremental costs" for
funding education and awareness raising" seems
extremely high.
DDT based antifouling paint is sold to local paint stores,
ship maintenance plants or individual fisherman and thus
it would be risky if these key stakeholders are not fully
involved in phasing out of DDT based antifouling paint.
The risk may be increased with the 12 million
stakeholder fishermen sparsely distributed along the
coastal provinces. It would therefore be hard to realize
the project’s objectives without improving the awareness
and promoting consumption choice of this group
towards more environmentally friendly products.
2 million USD will cover the expense of activities to
conduct extensive interactions with the stakeholders,
especially the end users. A major part of the budget will
be used by NGOs in civil society, local universities and
non-profit entities to undertake environmental awareness
raising activities and promotion of the alternatives.
36