Gulana Hajiyeva WB Safeguards Training Workshop Almaty, December 2012

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.


“5000”

Construction works Air pollution by dust

When necessary, construction site will be sprayed with water, particularly during hot, dry, windy conditions.


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.


-

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?



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?



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


NOTE: Section A always applies


43

EMP Checklist: Monitoring Measures for selected potential impacts and mitigation

measures