Integrating EMP into Operational Manual

Safeguard Training WorkshopZagreb, Croatia

May 7, 2009

Ruxandra Floroiu (Environmental Engineer)

Reference for all aspects of project implementation: who does what, when and how

Usually prepared after project Appraisal, before Effectiveness

Emphasis on decision-making processes; “fiduciary” aspects (procurement, financial management & accounting, environment); monitoring & reporting

Prepared by Client (consultants), approved by Govt. (higher level); Acceptable to WB

Cited in Legal Agreement, legally binding commitments

Need to specify procedure for amending it

Project Operation Manual (POM)

Provides clear, detailed, definitive guidance and procedures for implementing the project – follow the rules & all will be well

Facilitates efficient project monitoring and supervision

Simplifies Legal Agreement (only one reference needed to cover all Client/WB agreements)

Provides continuity in case of staff changes

The need of POM

Project objectives, description, components Applicable laws, regulations, rules Sub-project eligibility criteria (beneficiaries,

locations, activities), or “Menu” of eligible projects Sub-project application, evaluation, selection

process Institutional structures/responsibilities Disbursement procedures (including for Sub-grants) Procurement procedures Financial management & accounting Monitoring & Reporting (Table of Progress & Impact

Indicators) Annexes:

Work Plan (updated annually) EMP or Environmental Guidelines Application & Reporting formats Terms of Reference (PIU, major consultancies)

Typical Contents of POM

1. EMP as a chapter of POM2. EMP as an annex to POM3. Elements of EMP inserted

throughout OM where relevant

Recommended - 1 & 3 or 2 & 3

Integration of EMP in POM

Provides small grants to individuals or groups for enterprise development (sub-projects)

Typically based on applications, sometimes competitive

Grants typically finance small works (rehabilitation, small-scale construction), equipment, inputs, TA

Usually Category B (i.e., Category A sub-projects specifically excluded)

Framework EA/EMP covering the whole project sets out procedures for site-specific EA/EMP for sub-projects

General Description (Small Grants Program)

Example: Small Grant Programs

Program objective: demonstrate linkages between Protected Areas/biodiversity conservation and rural development (economic opportunities from sustainable use; awareness-raising and education)

Grant size: Euro 2,000 – 25,000

Example: Croatia Conservation and Rural Revitalization Program

sub-project cycle

Program Advertisement

Workshops for Applicants

(Assisted) preparation of applications

Submission of proposals

Proposals Eligibility Screening

Evaluation/selection of proposals

Sub-Project approval

Agreement on work plan, contract signing

First tranche disbursement

Progress report, Accounting, verification

Second tranche disbursement

Final report & accounting

Workshop Training - advice to prospective applicants on eligible/ineligible activities, potential environmental issues e; potential impacts and mitigation measures for different types of sub-projects

Grant application: identify potential environmental issues and proposed mitigation measures;

Screening of application: review of eligibility of proposal, excluding any with high environmental risk

Grant evaluation & selection: EA screening, evaluation of env. issues and proposed mitigations; indicate whether specific EA/EMP required

Preparation/signing of Grant contract: Environmental mitigation measures included in Sub-project contract; Includes specific environmental provisions for procurement, contracting

Procurement: includes environmental provisions in bidding documents, specifications, contracts

Grant disbursement/Progress reporting: environmental measures maybe triggers for disbursement; PIU verifies environmental measures implemented and are effective

Monitoring & reporting on Grant Implementation: includes EMP compliance, environmental indicators

Example – Incorporation of EMP in POM Procedures: Small Grants Programs

Insufficient understanding or appreciation of issues on part of applicants; inadequate up-front education and advice

Insufficient use of environmental consultants for screening, EA, monitoring

Inadequate coverage of environmental responsibilities in beneficiary contracts

Inadequate coordination between environmental and procurement specialists in PIU

Monitoring only process and inputs rather than impacts; vague or unclear indicators and targets

Common Problems in Implementing EMP in Small Grants Programs