Environmental (and Social) Impact Assessment

Instruments

Environmental Impact Assessment, Strategic Environmental Assessment,

Environmental Management Framework, and Environmental Management Plan

World Bank Safeguard Workshop Training

May/June ,2012Ruxandra Floroiu

Senior Environmental Engineer, ECA Region, World Bank

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

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

NO

YES (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

Where 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 text

Do 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

No (or poor) Executive Summary Inadequate assessment of project are of influence Inadequate or outdated baseline information Inadequate analysis of feasible alternatives Inadequate discussion of indirect, cumulative, and

transboundary impacts assessment Lack of meaningful consultation and public

participation/disclosure of EA Inadequate assessment of and support for

Borrower’s capacity in the area of EM and EA Failure to update the EIA and EMP after project

design or when technical changes are required

Common Problems with E(S)IAs

“Upstream” planning tool (input to sectoral or regional planning process)

Helps identify more vs. less sustainable development pathways

Can be OP 4.01 Instrument for programmatic investment◦ even if Category A projects are included◦ special emphasis on cumulative impacts

Must include SUBSTANCE, not just process (not same thing as EMF)

Relatively new instrument; limited guidance, limited capacity and experience

Strategic Environmental Assessment

1. SEA Directive 2001/42/EC of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment

Objective: to provide for a high level of protection of the environment to contribute to the integration of environmental

considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development

by ensuring that an Environmental Assessment is carried out of certainplans and programmes which are likely to have significant effects on the environment

Strategic Environmental Assessment

2. SEA Protocol on Espoo Convention UNECE Convention on EIA in a Transboundary Context (July 2010)

Objective: sets out the obligations of Parties to assess the

environmental impact of certain activities at an early stage of planning

It lays down general obligation of States to notify and consult on all major projects that are likely to have a significant adverse environmental impact across boundaries

Strategic Environmental Assessment

the scale and timing of SEA the rigid approach to the scoping the timing of stakeholders engagement limited awareness of SEA process; thus, need to

clarify early the SEA benefits the capacity and resources for implementation identification of stakeholders/main champion environmental data availability and quality undertaken in parallel with the planning and

preparation of a project , program, strategy or plan rather than after

Challenges to prepare high quality SEA

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 an 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)

ESMF: 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 EA

Acceptable to WB

Disclosure and one National level consultation on ESMF

Preparation, 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 implementation

EA/EMP disclosure and local level consultation prior to finalizing document

FI responsible for quality/clearance and for monitoring implementation

WB 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

ESMF Sub-project Screening, Review, Approval Process

Sub-project proponent Role Financial Intermediary Role

Identification of sub-project Application preparation and

its submission to FI EA/EMP financing and

preparation Collection of necessary

permits/licenses Obtain clearances from

local/regional environmental authorities

Implement the sub-project in line with EMP

Reports to FI on any EMP non-compliance

EA screening for World Bank requirements

Review of sub-project application

Appraisal of sub-project Monitor environmental

compliance based on EMP

Training of sub-project staff

Reports to the Bank on any EMF non-compliance

Maintains records of safeguard documents for all sub-projects

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World BankProjectTeam andSafeguard Specialists

Key Safeguard Actors in ESMFKey Safeguard Actors in ESMF

Ministry of Environment/

Ministry of Natural Resources of the

Russian Federation

• Review and clear sub-projects according to national andlocal regulatory requirements

• Issue environmental permits

• Conduct supervision• Provide safeguard assistance and training

•Ensure policies are followed •Conduct reviews

World Bank Safeguard Compliance

Role of WB in ESMF preparation and implementation

WB Appraisal evaluates:◦ adequacy of relevant national EA requirements;

gap-filling◦ adequacy of proposed EA procedures for sub-projects ◦ capacity of FI and others responsible ◦ measures in project to strengthen EA

arrangements/capacity as needed

WB Supervision:◦ Prior review/NOB of Category A (sometimes also

Category B) sub-project EIAs (unless FI assessment indicates this is unnecessary)

◦ Spot-checking of EPF implementation, including site visits

ESMF

FI assessment

FI has main responsibility for preparing and monitoring the application and use of ESMF. During sub-project supervision the FI:

Responsible for assessing the capacity of sub-borrowers to comply with EMP and more generally to do proper environmental and social management

Performs sub-project site supervision visits to confirm EMP implementation

Consults local environmental authorities for EMP requirements including current permits

Ensures the sub-borrower carries out required public consultations and does it in proper way including reviewing minutes of those consultations

Verifies with sub-borrower the overall environmental performance of the investment including any critical mitigation measure taken and significant environmental incident

Prepares quarterly/annually reports on results of EMP actions

Subproject Implementation based on ESMF

Challenges of ESMF Preparation and Implementation

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

Improving environmental screening

Intensifying monitoring Incorporating estimated costs

of EMP mitigation measures in sub-project cost/budget

Timely Progress Reporting on EMP implementation aspects

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 must specify all linkages (with RAP/Community and Contractors, regulatory agencies and institutions)

Mitigation measures too general, insufficient detail Mitigation and/or monitoring measures not feasible

or not practical Inadequate institutional capacity, insufficient

capacity building measures Monitoring indicators not measurable Monitoring targets missing or too general Lack of cost estimates Too long and elaborate to be implemented

Common Problems of 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 whom

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?

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

EMP Checklist: How it worksExample: Country X Real Estate & Cadastre Project (XRECP)

Introductory information (to be filled in prior to Appraisal):

• Project will finance rehabilitation of 15 Cadastre office buildings, all currently in use (sub-projects)• No new construction or extension of facilities – all works within existing footprint• All buildings located in urban areas on commercial streets with moderate to heavy traffic • Some may be registered historical buildings • Rehabilitation will be interior & exterior including: repair or replacement of roofs & windows, rewiring, removal/replacement of insulation, masonry repairs, replacement of floors, repair/replacement of plumbing, painting• A site-specific Checklist EMP form will be completed for each Sub-project and will be attached to the construction contract

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EMP Checklist: How it worksSubproject Example: Town A

47

EMP Checklist: How it works

EMP Checklist: How it works

NOTE: Section A always applies

EMP Checklist: How it works

50

EMP Checklist: Monitoring Measures for selected potential impacts and mitigation

measures

Exercise:

List the key elements for project description section of EIA for a project to construct a hydropower plant with dam and reservoir

List all environmental impacts that you can identify for the construction and operation of

a hydroelectric power plant (HPP)

Group A: Impacts during construction and fillingGroup B: Impacts during operation

(Make your own assumptions regarding project location and context)