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Integrating EMP into the Project Operational Manual. World Bank Safeguard Training Workshop Dushanbe, Tajikistan September, 2009. Project Operation Manual (POM). Reference for all aspects of project implementation: who does what, when and how
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Integrating EMP into theProject Operational Manual World Bank Safeguard Training Workshop Dushanbe, Tajikistan September, 2009
Project Operation Manual (POM) • Reference for all aspects of project implementation: who does what, when and how • Usually prepared after project Appraisal, before Effectiveness, updated as needed • Emphasis on decision-making processes; “fiduciary” mechanisms (procurement, financial management & accounting, environment); monitoring & reporting • Prepared by Client (Implementing Agency); approved by Govt. (higher level); acceptable to WB • Cited in Legal Agreement, legally binding commitments • Need to specify procedure for amending it
Why Have a POM? • Provides clear, detailed, definitive guidance and procedures for implementing the project – follow the rules & all will be well • Facilitates efficient project monitoring and supervision • Simplifies Legal Agreement (only one reference needed to cover all Client/WB agreements) • Provides continuity in case of staff changes
Typical Contents of POM • Project objectives, description, components • Applicable laws, regulations, rules • Sub-project eligibility criteria (beneficiaries, locations, activities), or “Menu” of eligible projects • Sub-project application, evaluation, selection process • Institutional structures/responsibilities • EMP or Environmental Guidelines • Disbursement procedures (including for Sub-grants) • Procurement procedures • Financial management & accounting • Monitoring & Reporting (Table of Progress & Impact Indicators) • Annexes: • Work Plan (updated annually) • Application & Reporting formats • Terms of Reference (PIU, major consultancies)
Integration of EMP in POM • EMP as a chapter of POM • EMP as an annex to POM • Elements of EMP inserted throughout OM where relevant Recommended - 1 & 3 or 2 & 3
Small Grants Program Provides small grants to individuals or groups for enterprise development (sub-projects) Typically based on applications, sometimes competitive Grants typically finance small works (rehabilitation, small-scale construction), equipment, inputs, TA Usually sub-projects Category B (Category A sub-projects specifically excluded) Framework EA/EMP covering the whole project sets out procedures for site-specific EA/EMP for sub-projects
Example: Small Grant Programs Kazakhstan Kyrghyz Rep. Croatia Serbia
Example: Croatia Conservation and Rural Revitalization Program • Program objective: demonstrate positive linkages between Protected Areas/biodiversity conservation and rural development (economic opportunities from sustainable use; awareness-raising and education) • Grant size: Euro 2,000 – 25,000
Eligibility Screeningof proposals Evaluation/selection of eligible proposals 5 Submission of proposals 4 6 (Assisted) preparation of applications Sub-Project approval 6 3 Agreement on work plan, contract signing Training Workshops for Applicants 2 2 sub-project cycle 7 1 Program Advertisement First tranche disbursement 8 Final report & accounting 11 9 Progress report, Accounting, verification 10 Second tranche disbursement
Example – Incorporation of EMP in POM Procedures: Small Grants Programs • Awareness & Training - advice to prospective applicants on eligible/ineligible activities, potential environmental issues e; potential impacts and mitigation measures for different types of sub-projects • Grant application: identify potential environmental issues and proposed mitigation measures; • Screening of application: review of eligibility of proposal, excluding any with high environmental risk • Grant evaluation & selection: EA screening, evaluation of env. issues and proposed mitigations; indicate whether specific EA/EMP required • Preparation/signing of Grant contract: Environmental mitigation measures included in Sub-project contract; Includes specific environmental provisions for procurement, contracting • Procurement: includes environmental provisions in bidding documents, specifications, contracts (including penalties for non-compliance) • Grant disbursement/Progress reporting: environmental measures maybe triggers for disbursement; PIU verifies environmental measures implemented and are effective • Monitoring & reporting on Grant Implementation: includes EMP compliance, environmental indicators
Common Problems in Implementing EMP in Small Grants Programs • Insufficient understanding or appreciation of issues on part of applicants; inadequate up-front education and advice • Insufficient use of environmental consultants for screening, EA, monitoring • Inadequate coverage of environmental responsibilities in beneficiary contracts • Inadequate coordination between environmental and procurement specialists in PIU • Monitoring only process and inputs rather than impacts; vague or unclear indicators and targets