ECA Safeguards Training May 12-13, 2011

1. Introduction to Environmental Management Plans (EMP): Purpose, Structure and Content, Implementation and Monitoring ECA Safeguards Training May 12-13, 2011 Alexei Slenzak Senior Operations Officer, Environment Europe and Central Asia Region The World Bank

2. ESMF vs EMP:FI perspective • Most of FI projects develop EMFs • FI advises sub-borrowers on EMP requirements • FI reviews and approves EMP (following review by environmental authority). In some cases WB gives No Objection (specified in the EMF) • FI monitors EMP implementation through site visits (construction supervision contractor) • FI prepares quarterly/annual reports on EMP implementation

3. EMF DOES NOT REPLACE EMPs

4. Environmental Management Plan (EMP) and EIA: How are they related? • EIA (~OVOS) is analysis of issues, alternatives and recommendations • EIA is documented in an Environmental Assessment Report (EA Report) • EMP is an action plan • EMP is based on results of EIA • EMP indicates which of the recommended mitigation and monitoring measures will be implemented

5. Environmental Management Plan (EMP): What is its Role? • Summarize environmental impacts and identify those to be mitigated • Describe mitigation measures, monitoring and reporting arrangements • Assign responsibilities and implementation schedules • Estimate costs for mitigation and monitoring measures

6. 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 • For some Category B (B-)projects, the EA may be limited to EMP (no separate EA report) • The borrower must report on compliance with EMP • Specific requirements for EMPs are set out in Annex C of OP 4.01

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

8. Who prepares the EMP? • EMP is prepared by the borrower • The borrower often puts a PIU in charge of preparation of EMP • Consultants assist the borrower/PIU • For construction projects, site-specific EMPs (based on general EMP) may be developed by: • Design engineering consultant • Construction or EPC contractor EPC contractor = Engineering, Procurement, and Construction contractor

9. Who implements the EMP? • Key responsibility stays with sub-borrower • Depending on sub-project phase (construction, operation) activities are implemented mainly by contractors/subcontractors and sub-borrower • Monitoring of compliance is done by sub-borrower, environmental, health authorities

10. 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

11. Typical Contents of the Verbal/Introductory Part of an EMP(background) • 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

12. Environmental Management Plan A. Mitigation

13. Environmental Management Plan B. Monitoring

14. Example: Environmental Management Plan • For a Road Safety Improvement Project (Ukraine) • Mitigation: Construction Phase

15. Example: Environmental Management Plan For a Road Safety Improvement Project (Ukraine) B. Monitoring: Construction Phase

16. Report from Supervision Engineers ARoad Safety Improvement Project (Ukraine) Mitigation measures Implemented Mitigation measures All operations are within the existing road corridor. Topsoil/vegitation removal kept to a minimum compatible with the approved construction drawings. Topsoil is stockpiled and reused. • Avoiding unnecessary removal of native plant species; • Clear-cut shall be-re-vegetated as soon as possible in order to prevent soil erosion; • Agricultural lands rehabilitation.

17. Report from Supervision Engineers BRoad Safety Improvement Project (Ukraine) • 3.2 Landscaping, Tree cutting and re –planting • 3.2.1 A number of issues have arisen with regard to the tree cutting and tree replanting. • 3.2.2 The programme of road side tree felling for 2010 and 2011 avoided the bird nesting season. It was noted in the last report that similar arrangement are to be put in place for 2012 and this needs to be confirmed in writing. • 3.2.3 In the process of obtaining the required permits for tree cutting, on Contract 1 Altcom received advice from the State Environment Department that replacement planting should not be less that the number of trees cut. This is consistent with the project Bill of Quantities (BoQ) for tree replanting, so this requirement is in accordance with the Contract. • 3.2.4 In the first report of the Environmental Specialist submitted in July 2010, it was noted that although the BoQ contained proposals for the replacement of trees cut down, there was no landscape plans for either contract to show the Contractors in which locations and in which manner the new trees should be planted. It was recommended that a replanting scheme for the replacement trees be drawn prior to the replanting taking place. • 3.2.5 In response, Altcom engaged a specialist organisation to prepare proposals for tree planting. The completed document provided a general scheme, which had slight variations, depending upon the soil conditions in the area, one for boggy soil, another scheme for loamy soil. It also shows the outer line of planting as small shrubs and plants, the taller trees being in two lines closer to the highway. • 3.2.6 Site inspection confirms that some replanting has undertaken in the autumn of 2010 on Contract 2 and the new plants were growing. However it was observed that some of the planting was in the proximity of an overhead power line. It is to be assumed that the plants already placed in these locations are only shrubs. However this needs to be confirmed. It would not be wise to plant larger trees close to the power lines because of maintenance problems in the future. • 3.2.7 Records received by the Engineer show that the number of trees cut on Contract 1 exceeds that allowed for in the BoQ. Trees currently felled total 4769. In addition, Altcom estimate that a further 6,668 trees will need to be felled before completion of the road works, bringing the total cutting programme to over 11,000 trees. In contrast, the BoQ specifies only 3633, replacement trees, so additional tree planting will need to be undertaken to meet the requirement that one tree is planted for every tree cut down. (Photographs in Appendix A) • 3.2.8 An additional problem has been identified by Altcom and in a letter to the Engineer dated 28 October 2010 explained that they were unable to find sufficient space for compensatory planting. They requested that they be given permission to plant trees in other locations, subject to agreement with the local authorities. This issue has not yet been resolved but has, in any case, be overtaken by events, in that a full landscape plan is now being drawn up by Kharkiv National Automotive and Road University (see paragraphs below) and that will identify a new planting scheme, determine a new quantity of trees to be replanted and also identify additional locations for planting off site, if necessary. • 3.2.9 Furthermore, after a site visit attended by Kyiv Road Maintenance Department, the State Road Administration, Kyiv oblast, the Road Maintenance Department and the Traffic Police, it was agreed that additional tree cutting should be carried out. The Committee formed to look at the issue gave the reason for this additional works as the significant numbers of old and dying trees that could fall and endanger traffic, particularly old poplars, willows and other trees affected by mistletoe. • 3.2.10 Much of this additional cutting for Contract 1 has already been completed. It appears to have been concentrated around road junctions, so it would also appear that part of the reason for the agreement to remove these trees is to do with sight lines and visibility splays, although this reason is not given in the Act. • 3.2.11 The balance of tree cutting and tree planting on Contract 2 indicates that the number of trees cut to date total 8124. This excludes any further trees that may need to be removed on traffic grounds as described above. The BoQ specifies the planting of 10,816 replacement trees, so the ratio of tree cutting to tree planting may just remain in balance at the end of the contract. • 3.2.12 A decision has subsequently been taken by Ukravtodor that landscape design plans should be commissioned for all current road rehabilitation contracts along the M03, with the primary aim of providing adequate protection of the road from snow. The preparation of such plans will be carried out by Kharkiv National Automotive and Road University and should be completed by August 2011. • 3.2.13 Completion of the new landscape plans should provide the opportunity to re-assess the re-planting requirements for both Contract 1 and 2. At present the number of replacement trees specified in Contract 1 does not meet the current replacement target. For Contract 2 the replanting requirement may also exceed the quantity allowed for when measured against a new landscape design. A new tree replacement schedule will therefore need to be agreed for both contracts to enable tree planting to be carried out in Autumn 2011.

18. Supervision of EMPs • Implementation of EMPs often becomes problematic • Hiring environment specialist by PIU is good practice • Monitoring/Reporting Program should cover environmental indicators • Legal Coverage/Bidding and Contracting Documents • Intensive supervision (review of mitigation plan, institutional assignments, etc.) is needed

19. Concluding Remarks • EMPs provide a critical link between the EA report required for Bank’s appraisal and environmental compliance during project implementation/operation • 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 …, but only when they are part of the contract! • Supervision of EMP implementation is an integral part of the Bank’s project supervision process • EMF does not replace EMP

20. Thank You!