Environmental Management Planning: An integrated, results-oriented process

1. Environmental Management Planning:An integrated, results-oriented process Discussion Material For the Moldova Safeguards Training Workshop October 28-31, 2008 By Victor B. Loksha ECA Safeguards Team Europe and Central Asia Region The World Bank

2. Environmental Management Plan (EMP) and EIA: How are they related? • EIA is analysis of issues and recommendations • EIA is documented in an Environmental Assessment Report (EA Report) • EMP is an action plan • EMP is based on results of EIA

3. Environmental Management Plan (EMP): What is its Role? • Summarize environmental impacts identified in the EA report • Identify impacts that must be mitigated • Describe mitigation measures • Describe monitoring and reporting arrangements • Describe assignment of responsibilities and schedules • Provide costs estimates for mitigation and monitoring measures

4. The Bank’s EA Policy (OP 4.01): What does it say about EMPs? • Implementation of EMP is an integral part of overall project implementation • For Category A projects, EMP is an essential feature of EA (but a separate EA report is still required) • For Category B projects, the EA may be limited to EMP (no separate EA report) • The requirement of EMP is included in the Loan Agreement • EMP is an important part of the project’s Operation Manual • The borrower must report on compliance with EMP • Specific requirements for EMPs are set out in Annex C of OP 4.01

5. The Place of EMP Within the Project Cycle: Basic approach according to World Bank Preparation Planning/Feasibility Operation Monitoring , Option 1 Environmental Impact Assessment Environmental Management Plan Project Identification Detailed Design Supervision of Construction/Implementation

6. The Place of EMP Within the Project Cycle: Basic approach according to World Bank, Option 2 Preparation Planning/Feasibility Environmental Management Plan Detailed Design Operation Monitoring Environmental Impact Assessment Supervision of Construction/Implementation

7. EIA and Project Cycle: Standard Practice in Many ECA Countries Preparation Final Environmental Impact Assessment Planning/Feasibility Environmental Permit Project Identification Operation Supervision of Construction/Implementation Monitoring Preliminary Environmental Impact Assessment Construction Permit Detailed Design

8. Integration of EMP into Standard ECA Practice Preparation Final Environmental Impact Assessment Planning/Feasibility Environmental Permit Project Identification Construction Permit Operation Supervision of Constr./Implementation Monitoring Preliminary Environmental Impact Assessment Environmental Management Plan Detailed Design Bidding Documents

9. One EMP or multiple EMPs? • Some projects require several EMPs: • Site-specific EMPs • Typical for projects with several components or subprojects on different sites • Impact-specific EMPs, when particular impacts require special attention, e.g.: • EMP for hazardous waste management • EMP for oil spill prevention and response • Recipient-specific EMPs targeted to particular ecosystems or their elements, e.g.: • EMP for protecting fish population from impact of hydro power development • To guide preparation of multiple EMPs, Generic or “Framework” EMP is developed first

10. Who prepares the EMP? • EMP is part of the EA done by the borrower • The borrower often puts a PIU in charge of tasks such as EMP • Consultants assist the borrower/PIU • For construction projects, EMP may be developed by: • Design engineering consultant • Construction or EPC contractor EPC contractor = Engineering, Procurement, and Construction contractor

11. Who prepares the EMP? (cont’d) Who supervises its implementation? • For a construction project: • Depending on project structure, design engineering consultant may prepare detailed (site-specific, impact-specific) EMPs • Construction contractors may be asked to develop the EMPs further, even prepare their own EMPs as appropriate • Construction supervising engineer oversees compliance of contractors with EMP(s)

12. Integration of EMP into Project Design:Let’s See Some Details! Preliminary EIA Prefeasibility study Generic Environmental Management Plan Feasibility study Tasks often assigned to Design Engineering Consultant Detailed EMPs: Site-specific / Impact-specific Detailed Design / Engineering Core tasks of the Design Engineering Consultant Bidding Documents

13. Preliminary EIA Prefeasibility study Required For Appraisal Generic Environmental Management Plan Feasibility study Required for appraisal if details of investments are known Detailed EMPs: Site-specific / Impact-specific Detailed Design / Engineering Bidding Documents Integration of EMP into Project Design, cont’d What Does the Bank Typically Require to See and When? EA Report

14. The Bank’s due diligence obligations for EMP • Advice for preparation and then No-Objection for the EMP • Sometimes No-Objection requirement may be waived: • For low risk activities, and/or • If implementing agency has a good track record • Supervision of implementation of EMP

15. EMP Format • There is no established format for EMP • Some commonly used formats include: • Tabular • Verbiage/Text • Combination of text and tabular (most common) • Self-standing (separate) document vs part of EA report • Sometimes can be incorporated in Operational Manual (no separate EMP)

16. Typical Contents of the Verbal/Introductory Part of an EMP • Summary of impacts • Description of mitigation measures • Description of monitoring program • Institutional arrangements, including training • Implementation schedule and reporting procedures • Cost estimates and sources of funds

17. Environmental Management Plan A. Mitigation

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

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

20. Environmental Management Plan B. Monitoring

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

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

23. Follow-up and Supervision of EMP Implementation • EMPs should be periodically reviewed, especially when: • Environmental impacts are associated with the operational rather than construction phase (Example: power plant or mining operations); • Revisions to EMP may be necessary when: • Final EIA produced after project appraisal renders the original EMP obsolete or irrelevant; • Site-specific EMPs produced after project appraisal need to be checked during project supervision

24. Supervision of EMPs • Implementation (enforcement) of EMPs has often been problematic • Assignment of a dedicated Environment Specialists to PIU is good practice • Monitoring/Reporting Program needs to cover environmental indicators • Legal Coverage/Bidding and Contracting Documents • Active supervision is needed, including reshaping mitigation measures, institutional assignments, etc.

25. Concluding Remarks • EMPs provide a critical link between the EA report required for Bank’s appraisal and environmental compliance during project implementation/operation • Integration of EMP into ECA countries’ evolving national EIA procedures is an elaborate but essential task • Quality of EMP preparation and its integration into project design and operation has a strong impact on the quality of environmental compliance on the ground • EMP requirements are legally binding on the construction/installation contractors…, but only when they are in their contract! • Supervision of EMP implementation is an integral part of the Bank’s project supervision process

26. Thank You!