“Drilling Down”: Understanding Environmental Management (Mitigation and Monitoring) Plans and Estimated Costs

1. “Drilling Down”: Understanding Environmental Management (Mitigation and Monitoring) Plans and Estimated Costs Safeguard Training Workshop Zagreb, Croatia May 6, 2009 Ruxandra Floroiu (Environmental Engineer)

2. The Role of EMPs • An Action Plan that indicates which of the EA report recommendations and alternatives will actually be adopted and implemented; • 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)

3. OP/BP 4.01 - related to EMPs • For Category A projects, EMP is an essential feature of EIA (or a separate EIA 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)

4. Who prepares the EMP? • EMP (freestanding or as part of the EA) is prepared and financed by the Client; • 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

5. According to OP 4.01 a good EMP includes… • 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

6. The Content of EMPs should… • address all relevant environmental (and social) issues identified in the respective EIA report; • be comprehensive and detailed but easily understood so that: • the Borrower knows exactly what is to be done and who is responsible; • World Bank team knows exactly what to look for during supervision to determine whether implementation is in compliance with the Legal Agreement and OPs

7. The EMPs Format • No established format; • Typical introductory text part followed by tables 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 EIA report; • Incorporated in the POM (as chapter, annex or inserted throughout the POM); • For Category A projects, mitigation measures and their implementation are often described in more detail in the introductory part

8. 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; • Identifies the authorities responsible for mitigation implementation; • Includes associated estimated costs

9. Mitigation Plan cont. • Identification of appropriate mitigation measures is critical; • Based on the expertise and experience of the consultant preparing the EMP, and on sources such as the Pollution Prevention and Abatement Handbook; • Mitigation measures should be feasible and practical; • Mitigation measures should be easily observed and checked • Bad example:“The construction contractor will assure equipment does not produce excessive noise • Good example: “The construction contractor will assure all equipment maintains noise levels at or below 75dB [A] at 1 meter from the source (in accordance with National Regulation XYZ/123) by utilizing equipment which is designed and maintained to meet this standard

10. Environmental Mitigation Plan

11. Example: Environmental Mitigation Plan For a Power Plant Construction Project in X-land Construction Phase

12. Example: Environmental Mitigation Plan For a Power Plant Construction Project in X-land Operation Phase

13. 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

14. Environmental Monitoring Plan

15. Example: Environmental Monitoring Plan For a Power Plant Construction Project in X-land Construction Phase

16. Example: Environmental Monitoring Plan For a Power Plant Construction Project in X-land Operation Phase

17. EMP Institutional Arrangements • How the overall environmental management system works during the project implementation (construction and operation phases) and Who is responsibleto implement it; • Who will supervise the implementation of Mitigation Plan; • Who will collect the data (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

18. EMP Institutional Strengthening Monitoring equipment to be provided (purchase or rental) as needed to implement the Monitoring Plan • Domestic or imported equipment (specify number of units, type, cost) Training • For mitigation actions and for monitoring (could be included with equipment purchase) • For general environmental management • Specify details of type of training, number/identity of staff to be trained, duration, location, costs, Consultant services and/or Special Studies • TORs and costs should be included as annex

19. Public Role in EMP Monitoring – example of good practice:Yiba Highway Project (Hubei Province, ChinA): SMS messaging • SMS messaging based Safeguards Compliance Monitoring System (SCMS): (example of beneficiary participation in project monitoring): • Provides environment and resettlement information to public (one can download EMP, RAP, safeguard booklets) • Records information on environment and resettlement performance against indicators (e.g., pollution of waterways, damage to sensitive area, compensation rates, how long it takes for people to receive compensation, etc) • Provides a mechanism for complaints to be automatically forwarded to appropriate parties • Serves to collect project data for ISR and ICRs in real time

20. SMS Messaging for EMP Monitoring

21. Role of EMP Supervision • To determine if the Borrower carries out the project in conformity with safeguard policies and legal agreement; • To identify problems as they arise during project implementation and recommend to the Borrower actions/activities to resolve them; • To identify the key risks to project sustainability • To recommend appropriate risk management strategies to Client

22. Issues related to EMP Supervision Implementation (enforcement) of EMPs has often been problematic… • Unrealistic/inadequate monitoring indicators; • Infrequent site visits by team members; • Inadequate review and evaluation of monitoring aspects and reports; • Failure to revise the EMP in response to project changes during implementation; • Inadequate follow-up on Borrower implementation of agreed actions (from previous mission); • Ineffectiveness of proposed institutional capacity measures

23. Solutions to adequate EMP Supervision • Assignment of a dedicated Environment Specialists to PIU is good practice; • Use of Environmental Specialists in Bank teams in the project cycle as early as possible; • Monitoring and Reporting Program needs to cover practical environmental indicators; • Bidding and Contracting Documents should include EMP provisions on mitigation/monitoring; • Active supervision is needed, including updating of mitigation measures, institutional assignments, etc. as required

24. Integration of WB EA requirements with Typical ECA national procedures World Bank NATIONAL LEGISLATION Identification/ Preparation Pre/Feasibility Study Preliminary EIA incl. mitigation measures EA/EMP Appraisal Detail Design Bidding Docs Final EIA Env. Permit (Monitoring) Construction Permit Implementation

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