gulana hajiyeva wb safeguards training workshop almaty, december 2012
DESCRIPTION
Strategic Environmental (and Social) Assessment WB (as of March 2011); EU & some national laws: for policies, plans and programs; not a substitute for project-specific EA Regional or sectoral EA: when the project is likely to have sectoral or regional impacts Environmental Impact Assessment WB -full EIA for Category A projects, narrower scope for Category B ( “limited EA”); National laws - contents specified in law/provision; Some countries - “Preliminary EA” to determine whether further EIA is required; Cumulative Impact Assessment (within EIA or supplementary document) Environmental Audit for ongoing activitiesTRANSCRIPT
Good Practices for the Preparation of Environmental and Social Impact Assessment
Instruments Environmental Impact Assessment, Environmental
Management Framework, and Environmental Management Plan
Gulana HajiyevaWB Safeguards Training WorkshopAlmaty, December 2012
Overview of different type of EA Instruments
Environmental Assessment
a process
a document/report
an input to decision making
OP 4.01 - mainly when/how EA should be done to provide necessary information about likely outcomes
Other OPs - more detailed “how to” and guidance on acceptable versus unacceptable outcomes
Strategic Environmental (and Social) Assessment WB (as of March 2011); EU & some national laws: for policies, plans and programs; not a substitute for project-specific EA
Regional or sectoral EA: when the project is likely to have sectoral or regional impacts
Environmental Impact Assessment WB -full EIA for Category A projects, narrower scope for Category B ( “limited EA”); National laws - contents specified in law/provision; Some countries - “Preliminary EA” to determine whether further EIA is required; Cumulative Impact Assessment (within EIA or supplementary document)
Environmental Audit for ongoing activities
EA Instruments as per OP 4.01 (Safeguard Documents for Project Appraisal)
Hazard/Risk Assessment When environmental/social risks are uncertain/not predictable (e.g. possible dam breakage, toxic spill); Complement to EA or Audit
Environmental and Social Management Framework: WB (as of March 2011) for project consisting of a program and/or series of sub-projects…impacts cannot be determined until the details have been identified; (FI and other); Not present in national laws
Environmental Management Plan: element of EA, or free-standing if no EA required; Checklist EMP option
Related documents but different:• Country Environmental Analysis/Country Social Analysis (Poverty and
Social Impact Analysis)• Safeguard Diagnostic Review (for Use of Country Systems Pilot:
“Equivalence Analysis” and “Acceptability Assessment”
EA Instruments as per OP 4.01
Identifies and assesses potential risks and benefits based on proposed activities, relevant site features, consideration of natural/human environment, social & transboundary issues
Compares environmental pros and cons of feasible alternatives
Recommends measures to eliminate, offset, or reduce adverse environmental impacts to acceptable levels (sitting, design, technology offsets)
Proposes monitoring indicators to implement mitigation measures
Describes institutional framework for environmental management and proposes relevant capacity building needs
ENVIRONMENTAL IMPACT ASSESSMENT
Well written Executive Summary Adequate assessment of project area of influence Comprehensive and duly updated baseline information Complete analysis of feasible alternatives Detailed discussion of indirect, cumulative, and
transboundary impacts assessment Ensuring proper consultation process and public
participation/disclosure of EA Realistic assessment of, and support for Borrower’s
capacity in the area of EM and EA Proper coordination between the project design and EIA
and EMP recommendations, including update of EIA and EMP when technical changes are required
Key Features of Good Quality E(S)IAs
Clarity on objectives (analysis/conclusions and recommendations, not just data; practical and realistic EMP, etc.)
Clarity on scope and contents (all project activities and associated activities; all project stages; direct & indirect & cumulative impacts; analysis of alternatives; social/environment interface; clear and feasible EMP; etc.). List known issues to be addressed, plus provision for consultant to identify others
Clarity on methodology/level of effort (site visits, formal surveys, modeling, consultations, etc.)
Clarity on deliverables (note value of inception Report) Provide for sufficient time and resources (for data collection,
consultation, document revision, etc.) Specific expertise required (technical specialties; EIA experience) Time Frame; budget and/or expected person-months
Scoping step: role of public consultation; involvement of social specialist ;
Line up financing for E(S)IA while preparing ToRs
E(S)IA – Terms of Reference (ToR)Good TOR + Qualified Personnel = useful and approvable E(S)IA
Environmental Assessment Process
2. DATA COLLECTION:
-Location/baseline (assets & trends; status & processes; env & social) - Project (type, scale, inputs, outputs)
3. POTENTIAL IMPACTS ANALYSIS (significance, likelihood)
4. IDENTIFICATION /EVALUATION OF POSSIBLE MITIGATION MEASURES
SitingScaleDesign/technology
Alternativ
es
Prevent, MinimizeMitigate, Compensate, Monitor
Operational (good practice)
5. IDENTIFICATION OF RESIDUAL IMPACTS
6. RECOMMENDATIONS (acceptability; pre-conditions; mitigation, monitoring)
“EIA DECISION”
7. REVISION of draft including public consultation
NOYES (with conditions)
Permits, EMP, contractual requirements
1. SCOPING/TOR: define project & issues
Govt. EIA approval vs. WB No Objection:Sequential process (Govt first or WB first) Parallel process; Iterative process
8. FINALIZATION & SUBMISSION
Environmental Assessment Process
2. DATA COLLECTION:
-Location/baseline (assets & trends; status & processes; env & social) - Project (type, scale, inputs, outputs)
3. POTENTIAL IMPACTS ANALYSIS (significance, likelihood)
4. IDENTIFICATION /EVALUATION OF POSSIBLE MITIGATION MEASURES
SitingScaleDesign/technology
Alternativ
es
Prevent, MinimizeMitigate, Compensate, Monitor
Operational (good practice)
5. IDENTIFICATION OF RESIDUAL IMPACTS
6. RECOMMENDATIONS (acceptability; pre-conditions; mitigation, monitoring)
“EIA DECISION”
7. REVISION of draft including public consultation
NOYES (with conditions)
Permits, EMP, contractual requirements
1. SCOPING/TOR: define project & issues
Govt. EIA approval vs. WB No Objection:Sequential process (Govt first or WB first) Parallel process; Iterative process
8. FINALIZATION & SUBMISSION
E(S)IA in the Project CycleParallel tracking of safeguards studies and technical design:
Interests of affected
stakeholders
WB policies and
international good practice
Objectives of developer,
techno-economic
requirements
Consultancies for
Environmental / Social /
Assessments
Consultancies for techno-economic
studies and designs
EARF / ESIA / EMP / RPF / RAP
FS, design stages
Project Identification Preparation Implementation
Due diligence(mitigation
and monitoring) measures ensured during
construction &
operation
Full E(S)IA Report: Required Content (OP 4.01)
Executive (Non-technical) Summary
Significant findings and key recommended actions;
Residual risks
Policy, Legal and Administrative framework
Whether national framework is sufficient to provide desired results and where incremental measures are needed to meet WB requirementsWhether project as proposed will comply with national laws/regulations; Institutional framework for implementation
What would the Board need to know to evaluate risks?Summarize key acts and conclusions here; explain in main textDo not cut-and –paste the entire body of national laws verbatimEmphasize gaps and how to fill themInclude assessment of institutional structure and capacity for implementation & enforcementDo not replicate design/FS
Section
What it should tell us
Keep in mind…
Project description
Relevant aspects of project context
Key elements of project; environmental and social impacts
Include off-site investments regardless of financing
Environmental and Social Management Framework: Purpose
Provides guidance to sub-borrowers (sub-project sponsors) and FIs to ensure the EA process is carried out in compliance with national legislation and OP 4.01 Provides an environmental and social screening process to allow for identification, assessment and mitigation of potential impacts by proposed works at the time the detailed aspects are known
Used as a reference document for assessing the potential environmental and social impacts of investment alternatives
Serves as guidelines for the development of sub-project/site-specific Environmental Management Plans (EMPs), Environmental Assessments (EAs), due diligence reports, environmental audits, etc
Is an integral part of the project Operational Manual and applicable to all FIs investments, regardless of its funding source or implementing agency
MAIN OBJECTIVES: Establish procedures for screening all proposed
sub-projects for their potential adverse environmental and social impacts
Specify measures for managing, mitigating and monitoring environmental impacts during project operation
Outline training and capacity-building arrangements needed to implement the EMF provisions
Environmental and Social Management Framework
When specific investments cannot be identified prior to project Appraisal (un-known subprojects are proposed during project implementation):
Financial Intermediary (FI) operations Trenched sectoral investment programs (incl.
SWAPS) Area development projects (rural, municipal, etc.) Social Funds Small Grants Programs
Environmental and Social Management Framework:
When to use the EMF
Used when specific investments CANNOT be identified prior to Appraisal (FI or other program of sub-projects)
No provision for EMF in OP 4.01 (evolved to formalize Borrower & WB responsibilities for OP 4.01 compliance of subprojects vis a vis screening, EA/EMP preparation & implementation, monitoring, capacity building, Prior Review
Focus on screening criteria, processes, responsibilities No set format; may or may not include technical content Can explicitly exclude high risk subprojects Pelosi Amendment applies if Category A subprojects
expected Category A subproject EIAs are submitted to WB Board Sometimes Environmental & Social Management
Framework – but DOES NOT REPLACE the RPF (unless written to incorporate RPF as set out in OP 4.12)
E(S)MF: KEY FEATURES
ESMF Procedures: Content
1. Brief description of project components including description of type of activities eligible for financing
2. Operating requirements (diagnosis of legal and institutional framework, applicable safeguards)
3. Environmental/social baseline at national/state level4. ESMF screening procedures (criteria, process,
environmental due diligence process, EA/EMP documentation)
5. Implementation arrangements6. Public consultation and disclosure process/procedures7. Environmental mitigation measures8. Monitoring and reporting arrangements9. Training and capacity building recommendations10. Various annexes
PROJECT (FI)
Sub-project(Development of mineral resources open pit mines
Category A)
ESMF (project level)Prepared by primary Borrower (FI)Sets out requirements & responsibilities for sub-project-specific EAAcceptable to WBDisclosure and one National level consultation on ESMFPreparation, consultation and disclosure prior to Project Appraisal
Sub-project-specific EA or EMP (sub-project level)Prepared by sub-borrower/grant recipient (sub-project implementer), during project implementationEA/EMP disclosure and local level consultation prior to finalizing documentFI responsible for quality/clearance and for monitoring implementationWB prior review of some Category B
Sub-project(Modernization of cement production
Plant, Category B)
Sub-project(Poultry waste utilization system, cat. B)
Screening form to be filled out by sub-project proponentSub-project name, location (map), type of activity, physical data, environmental information, likely environmental impacts, environmental screening category (A, B or C), mitigation of pollution, environmental studies required (EIA/EMP), public consultation/disclosure required.
Screening Criteria – site-specific environmental risks and impacts; land zoning requirements, environmental license/permit; “negative” list of investments not allowed for financing under the project
Reviewer decides the level of impact to be assessed through EIA (category A or B) or EMP/EMP Checklist (category B)
Subproject approved on the basis of environmental and social review findings (or denied/approved with some changes)
Disclosure/public meeting – function of subproject EA category
ESMF Sub-project Screening, Review, Approval Process
Important Aspects of Good Quality ESMF
Adequate assessment of national EA requirements, identification and filling of gaps
Proposed EA procedures are clear, comprehensive and adequate for envisaged sub-projects
Screening allows for proper categorization of sub-projects, screening criteria are well defined, ineligibility criteria provided
Capacity of FIs and other responsible parties should be realistically assessed, appropriate measure identified to improve capacity as needed
POM contains references to ESMF; environmental sustainability is one of sub-projects proposal evaluation
Challenges of ESMF Preparation
From World Bank side From FI side
EMF not recognized in national legislation (no national mechanism to approve it)
Enhancing the capacity of FIs
Good quality EA/EMPs
Differences between national and WB EA screening criteria, environmental standards
Meaningful public consultation and timely public disclosure
Incorporating estimated costs of EMP mitigation measures in sub-project cost/budget
Environmental Management Plans (EMP) An Action Plan that indicates which of the EA report
recommendations and alternatives will actually be adopted and implemented
Part of EIA or freestanding The most important link to incorporate environmental
factors into the overall project design; Identifies linkages to other SG policies relating to the
project Ensures environmental mitigation measures and their
practical monitoring become a legal responsibility of the Borrower (LoA)
EMP Contents Summary of predicted adverse environmental and
social impacts related to project;
Description of mitigation measures and plan
Description of monitoring activities and plan
Institutional arrangements including training
Implementation schedule and reporting procedures
Estimated related costs and sources of funds
Note: the content of the EMP can be revised during project implementation based on changes in design or based on lessons learned
EMPs are an outcome of ESIA process
For Category A projects, EMP is an essential feature of EA report (or a separate report is required);
Some Category B projects may require only an EMP (if environmental issues are relatively minor and routine, not site-specific); other Category B projects may require EA reports with “tailor made” mitigation aspects;
The implementation of EMP is included in the LoA;
EMP should be an important part of the POM;
The Borrower must report on compliance with EMP;
Specific requirements for EMPs are set out in Annex C of OP 4.01 (not necessary to follow the format)
EMP as per OP/BP 4.01
EMP is part of the EA prepared and financed by the Client; In case of FI Projects the EMP should be prepared by the sub-borrower
The Client often places an existing PIU in charge of tasks such as EMP, EA, EMFs;
The Client may hire local/international Consultants to assist the PIU in preparing EMP
Who prepares an EMP?
No established format; Typical introductory text part followed by
tabular format of specific mitigation measures (Mitigation Plan) for identified possible environmental impacts and of related monitoring activities (Monitoring Plan);
Self-standing document vs. part of the ESIA report;
Incorporated in the POM (as chapter, annex or inserted through the POM);
EMP Format
Environmental Mitigation Plan◦Defines the key environmental (and social)
issues which should be managed◦Describes specific mitigating measures to
manage each possible impact, including specific actions to be achieved
Mitigation measures should be feasible and practical; Mitigation measures should be easily observed and
checked
◦ Identifies the authorities responsible for mitigation implementation
◦ Includes some associated estimated costs
Environmental Monitoring Plan◦Defines selected indicators for ensuring that
mitigation measures are being implemented and are effective (e.g., if there is a mitigating measure to control noise during construction, the monitoring plan should include noise measurements during construction)
◦Ensures the project is complying with National environmental regulatory requirements and WB Safeguard requirements
◦Addresses concerns which may rise during the public consultation
◦ Identifies authorities responsible for monitoring
◦ Includes estimated related costs
Mitigation Plan:what must be done
Monitoring Plan:to determine whether measures are implemented & effective
EMP: Typical Mitigation and Monitoring Tables
EMP specifies all linkages (with RAP/Community and Contractors, regulatory agencies and institutions)
Mitigation measures are specific and detailed Mitigation and/or monitoring measures are feasible
and practical Proper assessment of institutional capacity,
identification of capacity building measures Monitoring indicators are clear and mainly
measurable Monitoring targets are specific Proposed mitigation and monitoring measures are
duly costed
Key Features of Good Quality EMPs
Example: Environmental Mitigation PlanFor The Foundry Construction Phase
Project Activity Potential Environmental Impacts
Proposed Mitigation Measures Institutional Responsibili
ty
CostsUS$
Use of land within the plant
construction area, and along the access
road route
Damage to vegetation
Appropriate clearing techniques (hand clearing, not mechanized clearing) will be utilized. Any trees of protected species will be relocated. In case relocation is not possible, the project developer will agree with the MoEnv on a practical compensation to protect specific trees
Contractor/Plant Operating Company
“5000”
Use of land within the plant
construction area, and along the access
road route
Loss of fertile
topsoil and soil erosion
Fertile topsoil will be removed, stored in an isolated area away from construction activities, and covered with plastic to prevent runoff/erosion. Upon construction completion, topsoil will be returned and the area revegetated with plants similar to the original vegetation/native to the area.
Contractor/Plant Operating Company
“5000”
Construction works Air pollution by dust
When necessary, construction site will be sprayed with water, particularly during hot, dry, windy conditions.
Contractor/Plant Operating Company
2000
Construction works Noise from constructio
n works
Construction will be confined to normal work-hours (7AM to 7PM). If construction must be conducted before/after these hours, local public will be notified at least one week in advance.
Contractor/Plant Operating Company
-
Project Activity
Potential Environmental Impacts
Proposed Mitigation Measures
Institutional Responsibilit
y
CostsUS$
Coal Combusti
on
Air emissions of NOx, SO2, CO, particulate matter
Low-NOx burners and water injection to control NOx;Firing only low-sulfur (<0.1% by wt.) coal to control SO2;Good combustion control to control CO, PM and VOCs;Stack height at least 45 m to facilitate dispersion.
Power plant operatorPower plant supply and installation (S&I) contractor
0.8 million
Equipment
Operation
Noise from equipment
Acoustic enclosures for the combustion turbines to ensure that noise does not exceed 70 dB(A) at 100 m
Power plant operatorS&I Contractor
150,000
All operation
phases
Workers Health and Safety
Personnel protective equipment will be used (gloves, glasses, safety belts)WHS training will be provided to workers monthlySafety engineer will be assigned to the site
Power plant operator
50,000
Example: Environmental Mitigation PlanFor the FoundryOperation Phase
Example: Environmental Monitoring Plan
For the FoundryConstruction Phase
What Where How When/By whom Costs
US$Potential Environmental Impacts
parameter is to be monitored?
is the parameter to be monitored?
is the parameter to be monitored?
is the parameter to be monitored?
Damage to vegetation
Clearing techniques and relocation procedures utilized; record of compensation provided as agreed with MoEnv
Plant site, pipeline and access road line routes
Visual and by comparison with pre-construction photo survey
Monthly throughout construction period;Contractor/ Supervisor Engineer
-
Loss of fertile topsoil and soil erosion
Soil storage procedures and location
Soil storage sites
Visual Weekly during site preparation and construction periodContractor
-
Air pollution by dust
Dust level All active construction sites
Visual During construction Contractor/ Supervisor Engineer
-
Noise from construction works
Noise level, dB[A] All active construction sites
Measurements by a licensed organization using certified measurement devices
During construction,Contractor
“Estimated standard costs”
Example: Environmental Monitoring PlanFor the FoundryOperation Phase
What Where How/Costs When/by whomPotential
Environmental Impacts
parameter is to be monitored?
is the parameter to
be monitored?
is the parameter to be monitored?
is the parameter to be monitored?
Air emissions of NOx, SO2, CO, and particulate matter (PM)
The applicable standards are: (1) NO2 ≤ 400 mg/m3; (2) SO2 ≤ 850 mg/m3; (3) CO ≤ 150 mg/m3; (4) PM ≤ 100 mg/m3
At the stack of the plant
By continuous monitoring equipment supplied with the power plant; costs are part of the self-monitoring plan for the plant – could be easily estimated
Initial test at commissioning and annual subsequently. Continuous for NOx and CO. Plant management
Noise from construction works
Noise level, dB[A]. Applicable limits are 70 dB(A) at 100 m
At 100 meter from the border of the site (closest end to a residential area)
Measurements by a licensed organization using certified measurement devices; national standard costs
Once before commissioning of the plant and annually when the plant is in operation
Workers Health and Safety
Usage of personnel protective equipmentRecords of WHS training
At the site Visual by checking the practical usage of equipment and checking adequate among of equipment exists.Records of the trainings will be checked and if necessary improvements will be done
Equipment: daily by safety engineer
Training records: monthly by safety engineer
How the overall environmental management system works during the project implementation (construction and operation phases) and Who is responsible to implement it;
Who will supervise the implementation of Mitigation Plan;
Who will collect the data (from the Monitoring Plan); Who will analyze the data to produce information; Who will prepare reports (and how often) indicating
how recommended actions are being taken, Who will receive the reports and act upon them
(e.g. dismiss contractor, withhold contractor payment, authorize expenditures to correct problems etc) – must have the needed authority
EMP Institutional Arrangements
Checklist EMP: Rationale 2007 review of SG implementation in health &
education sectors indicated: ◦ Most of the projects Category “low B”◦ Environmental impacts usually related only to small scale
construction / building rehabilitation◦ EMPs existed on paper but were long, complex, impractical –
and mostly ignored… in most cases, no environmental site management
Recognition that issues for small scale construction/rehabilitation are fairly standard… no need to continually “re-invent the wheel”
Conclusion: need a streamlined, practical instrument, which would be standardized, easy to prepare, implement and monitor, specifically tailored to small scale infrastructure
Category “low B” Project
Environmental issues known and limited to small scale construction/rehabilitation works*
Area of impact clearly defined & limited: either within an existing “footprint” or relatively small new areas known not to have major environmental or social issues
Checklist EMP – Eligibility Criteria
EMP Checklist: Structure and Function
• Basic information on project activities• Environmental baseline information
1: Datasheet
• Grouped according to various themes or impact types
• Themes / types to be checked as applicable
2: Potential impacts list
• Each checked item from Section B triggers specific mitigation measures / parameters and specific, concrete activities to be implemented on site
3: Mitigation measures list
• Focuses on reasonable, meaningful, practical monitoring parameters and activities
4: Monitoring plan
Parts 1 & 2: description of sub-project and identification of potential impacts: for use by screener/approver
Part 3: identifies issues and associated mitigation measures: becomes part of construction contract
Part 4: monitoring/supervision plan to verify effective mitigation: for use by construction site supervisor and PMU
How EMP Checklist is used
39
EMP Checklist: How it worksSubproject Example: Town A
40
EMP Checklist: How it works
EMP Checklist: How it works
NOTE: Section A always applies
EMP Checklist: How it works
43
EMP Checklist: Monitoring Measures for selected potential impacts and mitigation
measures