Implementation of Environmental Management

Frameworks and Environmental Management Plans : Their

Integration in Project Operational Manual

World Bank Safeguard TrainingAnkara

March 31, 2010

Simple and practical framework and guidelines work

Subproject design is enhanced by the use of guidelines

Sustainability measures incorporated in the design Increase awareness of local governments and

communities Need to build capacity at all levels Buy in of proponents on the added value of

safeguards beyond compliance is critical Costing for mitigating measures is always an

issue, hence mainstreaming in the design ensures incorporation

EMF Implementation Experience

Building capacity of local governments and communities

Enhancing the capacity of Fis

Incorporating estimated costs of EMP mitigation measures in subproject cost

Improving environmental screening

Intensifying supervision and monitoring

Challenges of EMF Implementation

Challenges of EMP Implementation

1. Unrealistic/inadequate monitoring indicators

2. Infrequent site visits and inadequate review and evaluation of monitoring aspects and reports

3. Failure to revise the EMP in response to project changes during implementation

4. Inadequate follow-up on of agreed actions

5. Ineffectiveness of proposed institutional capacity measures

Practical Solutions

Assignment of dedicated Environment Specialists to FI is good practice

Practical, specific and measurable environmental indicators

Bidding and Contracting Documents should include EMP provisions on mitigation/monitoring

Active monitoring is needed, including site visits Updating of mitigation measures and

institutional assignments as required

Assess the quality of EMP implementation and supervision

Identify any systematic issues to be addressed Recommend practical measures to address them Apply the measures to existing projects (to the

extent possible) and to future operations Disseminate results (dialogue with Borrowers;

“ECA Learning Brief;” staff & Borrower training

Objectives

Methodology: Desk Review + Site visits

EMP Implementation ExperienceExample: South Caucasus Highways Infrastructure

Projects Thematic Review

Georgia• East-West Highway Improvement Project 1 (EWHIP 1)• EWHIP 2• EWHIP 3• Secondary and Local Roads Improvement Project (SLRP) –

(numerous small project roads)• Additional Financing Projects

Armenia• Life-line Roads Improvement Project (LRIP)

• Numerous small project roads (1- 6 km)

Azerbaijan• Azerbaijan Highway I• Azerbaijan Highway II (Category A Project)• Azerbaijan Highway II-Additional Financing I & II (Multiple road segments under each project)

Projects Reviewed

Desk Review Findings

Most Projects screened/categorized correctly

Most EIAs well prepared

Timely disclosure and public consultations carried out

EMPs: comprehensive but mitigation measures overly generic

Little tie-in of EMP with the design

Little tie-in of EMP with the contract documents

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Site Visit Findings

Contractors routinely failed to implement many aspects of EMPs, particularly relating to:

◦ Sourcing of materials (management & restoration of

borrow sites)◦ Disposal of construction wastes◦ Management of construction sites (e.g. drainage, erosion,

impacts on surface waters)◦ Air quality precautions (e.g. covering truck loads, dust

suppression)◦ Construction camp conditions

Inadequate supervision by contractors, supervision consultants, Roads Agencies and WB Project Teams

Looking behind the scenes

Beautifully paved road

But what is on the other side of that wall?

EIA identified area as prone to landslides Design did not take this adequately into account Poor design led to land slides and destruction of houses (Notice

partially washed out village road)

EIA not incorporated into design:

Waste Material Handling & Disposal

Asbestos material dumped in a local landfill

Concrete waste dumped on bank of river which supplies water to nearby towns

Waste material being dumped haphazardly on nearby land

Dumped waste material from tunnel excavation, burying fragile ground

cover

Mining gravel from riverbed

Poor waste management at Contractor’s camp

Example of good practice

Water spray used to control dust from aggregate crusher plant

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Why so many problems?

Lack of ownership: ◦ Roads Departments play minimal role in processing the EA reports for WB-

financed projects (leaving it to Bank staff to work with EA consultants)◦ Local supervision consultants don’t see environment as major issue

(“business as usual”)◦ International supervision consultants not doing their job – fail to report to

Roads Agencies◦ Roads Agencies ignore reports of environmental problems

Lack of clear responsibility: ◦ EMPs too generic◦ EMP provisions not included in contracts, so not legally binding

Lack of capacity: Roads dept. have limited Environmental & Social staff and little incentive to strengthen

Excessive WB involvement increases WB supervision costs and stress on WB staff - Environmental & Social staff in field responsible for too many projects to do regular site visits

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Recommendations More detailed EMPs, more specific, informative and monitorable

mitigation measures (e.g. drawings of septic tanks for camps) Ensure EMP incorporated in designs and bidding documents

(with realistic assessment of costs)◦ Specific costed actions in Bill of Quantity◦ Umbrella provision (non-competitive)

Hire independent “Environmental Auditor” for monitoring (don’t leave it to general supervision consultant)

Increase and clarify Borrowers’ responsibility – insist on “staffing up” as needed. (WB should not be “first stop” for consultants)

Training for Roads Agency staff, contractors staff, consultants – starting with Project Launch workshop

Highlight environmental issues in Aides Memoires/cover letters Build fines and penalties for non-compliance into contracts and

enforce them

sub-project cycle

IDENTIFICATION

PRE-FEASIBILITY

(Assisted) preparation of applications

Submission of priority proposals

Eligibility Screening

Evaluation/selection of proposals

Sub-Project approval

Agreement on work plan, contract signing

Start of works

EMP implementation

OPERATION

SUPERVISION

FEASIBILITY/DESIGN

Pre-FS Form

Environmental PermitConstruction Permit

Monitoring of works

Progress reports

EIA Preparation

Incorporating EMF into Project Cycle

Project Implementation CycleSubproject Identification and Planning Process

ImplementationProcurement Procedures

Financial Management ProceduresInstitutional Arrangements

Project Operational Manual (POM)

Environmental Review and Implementation ProceduresScreening Form

Environmental and Social Impact Mitigating Measures Monitoring Checklists

Sub-loan eligibility criteria: description of eligible/ineligible investments, potential environmental issues

Sub-loan application: identify potential environmental issues and proposed mitigation measures;

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

Preparation/signing of subproject loan agreement: Includes requirement to implement EMF

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

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

Monitoring & reporting on sub-loan Implementation: includes EMP compliance, environmental indicators

Incorporation of EMF aspects in POM Procedures

EA Screening/categorization criteria National and World Bank EA requirements Relevant environmental standards Environmental issues and mitigation measures for

each type of subproject to address impacts and enhance sustainability of subprojects

Measures for consideration and/or mainstreaming in subproject design, site selection, EMP formulation and implementation

Public disclosure and consultation procedures Monitoring, evaluation and reporting

arrangements

Environmental Guidelines – Chapter or Annex to POM

TAJIKISTAN

COMMUNITYAGRICULTURE AND WATERSHED

MANAGEMENT PROJECT

The Project covers a total of 36 thousand square km. in Surkhob, Zarafshan, Vanjob and Toirsu Watersheds. The area includes 390 thousand hectares of agricultural land

with a total population of 550 thousand people (42% of total mountain population)

Component I: Rural Production Investments Component II: Institutional Support and

Capacity Building Component III: Project Management

Project Overview

Farm productivity investments - input for annual crops, horticulture, livestock, processing, distribution, leasing, credit facilities

Land resource management – land groups apply soil conservation, moisture management, investments such as horticulture, woodlots, fodder

Rural infrastructure – drinking water, small irrigation, rural track rehabilitation, small power generation

Rural Production Investments

Financially and commercially feasible;

Socially inclusive and considerate;

Institutional feasible;

Environmentally sound and sustainable: subprojects should meet Project requirements for sustainable land management;

Improve agricultural productivity

Subproject Underlying Principles

Minor impacts from small works will follow proper design standards

Before approval, authorities will verify subprojects comply with relevant national local environmental laws and regulations and be consistent with Bank policy and procedures

Projects will be reviewed by different authorities depending on the overall project cost

As a condition of disbursement, the PMU was required to hire an Environmental Specialist.

$50,000 was allocated for training and equipment to enhance environmental assessment and management of government, civil society and project related staff

Additional key attributes

Initial awareness raising and communication

Indicative descriptions of potential rural production investment activities

Group process and eligibility guidelines Village and CIG implementation

arrangements Responsibilities of Project Management

Unit, Project Coordination Unit, contracted facilitators and specialists, and line agency personnel

Project Operational Manual

Tools for participatory analysis Indicative list of detailed questions on

feasibility and eligibility to be addressed in subproject proposals

Format for subproject proposal Memorandum of Understanding (MOU) to be

signed by PIU & Beneficiary Checklist for review of subproject proposal and

village submissions by project committees Suggested Terms of Reference for NGO

contracts

Project Operational Manual Annexes:

Will the subproject generate any wastes during construction or operation (air, liquid or solid)? If so, how will these be handled? What are the proposed measures:

To prevent, minimize or treat wastes? For ultimate disposal of any waste residues?

Does the subproject create risk of impact on any endangered plant or animal species (e.g., introduction of invasive exotic weeds, conversion of

natural habitats)? If so, what has been done to prevent or minimize these impacts?

Have alternative site and design options been evaluated and the least risky option selected?

Is compensation proposed (creation/management of equivalent natural habitat?)

Does the subproject create risk of impact on any surface or ground water sources? (e.g. pollution, siltation, excessive abstraction)? If so:

Have the impacts on other water users been assessed? Have potentially affected other users been consulted? Has adequacy and sustainability of water supply been ascertained? Have measures provided for source protection?

Example Annex: Environmental Soundness & Sustainability

(sample questions - paraphrased)

What is the EA instrument required for this subproject (e.g., EMP, limited environmental assessment plus EMP)?

Has the EA instrument received environmental clearance (at the raion/national level)?

Is the capacity for implementing and monitoring the EMP adequate?

Have EMP costs been accounted for?

Example Annex: Environmental Soundness & Sustainability (contd.)

SUBPROJECT # - 254 AREA - 624 ha BENEFICIARY # – 4353 hh

HORTICULTURE/TERRACING

BEFORE NOW

HORTICULTURE/TERRACING

TERRACING

DRINKING WATER SUPPLY

Community investments in practice

SOLAR ENERGY FOR HEATING WATER

Community investments in practice