Integrating Environmental Management Plans into Project Operational Manuals

1. Integrating Environmental Management Plans into Project Operational Manuals Agi Kiss Safeguards Training Workshop, Chisinau, Oct 28-31, 2008

2. Project Operational (Implementation) Manual • Reference for all aspects of project implementation: who does what, when and how • Usually prepared after project Appraisal, before Effectiveness • Emphasis on decision-making processes; “fiduciary” aspects (procurement, financial management & accounting, environment); monitoring & reporting • Prepared by Client (consultants), approved by Govt. (higher level); Acceptable to WB • Cited in Legal Agreement, legally binding commitments • Need to specify procedure for amending it

3. 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 • Disbursement procedures (including for Sub-grants) • Procurement procedures • Financial management & accounting • Monitoring & Reporting (Table of Progress & Impact Indicators) • Annexes: • Work Plan (updated annually), • EMP or Environmental Guidelines • Application & Reporting formats, • Terms of Reference (PIU, major consultancies)

4. Why Have a POM (PIM)? • 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

5. Alternative Approaches for Integrating EMP into POM • EMP as a chapter of POM • EMP as an annex to POM • Elements of EMP inserted throughout POM where relevant • 1 & 3 or 2 & 3 Separate Chapter/Annex = easy reference “Pros” of each: Integrated = environment is fundamental, not an add-on; Not only Environmental Staff

6. Example: Small Grants Programs

7. General Description 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 Category B (i.e., Category A sub-projects specifically excluded) Framework EA/EMP covering the whole project sets out procedures for site-specific EA/EMP for sub-projects

8. Guidance from Project-level Environmental Framework • Eligibility criteria for sub-projects (positive and/or negative list) • Environmental Assessment screening criteria & procedures (e.g. A, B, C) and associated EA requirements • Procedures and responsibilities for preparation and approval of sub-project EAs and EMPs • Environmental issues and mitigation measures for different types of sub-project activities • including procurement and contract provisions • Monitoring & reporting requirements (EMP implementation) • Environmental impact indicators and monitoring

9. Example: Croatia Conservation and Rural Revitalization Program • Program objective: demonstrate 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

10. (Written notification/explanation) Eligibility Screening of proposals Evaluation/selection of proposals Submission of proposals (3 rounds) Revisions (Assisted) preparation of applications Project approval Workshops for Applicants CCRRP sub-project cycle Agreement on work plan, contract signing Advertisement of program First tranche disbursement Final report & accounting Second tranche disbursement Progress report, accounting & verification

11. Institutional Structures • Ministry of Culture(and Nature Protection) • Project Implementation Unit • National level “Headquarters” – overall implementation, reporting • Local level (3) – day to day support, verification & monitoring • Small Grants Committee Project policy and oversight • Local Advisory Boards (local officials, NGOs) • Sub-project evaluation and selection • Review progress reports • Ministry of Environmental Protection • Enforce environmental regulations, permits • TA, expert review - upon request

12. CRRG Project Operational Manual Structure

13. Incorporation of EMF in Procedures • Applicant training workshops: • environmental objectives; potential impacts and mitigation measures for different types of sub-projects • Preparation of applications: • - Environmental issues and mitigations identified in application form • Screening of proposals: • - LAB/MEP reviews eligibility of proposal, excluding any with high environmental risk • Proposal evaluation/selection…revisions, approval: • Environmental mitigations refined as required (Local Env. Authorities on LAB advise) and included in Implementation Plan • Agreement on Work Plan/ Signing of Sub-Project Contract with Recipient • Environmental mitigation measures included in Sub-project contract • Includes specific environmental provisions for procurement, contracting • Progress reporting/verification for second (and further tranche of funding • Environmental measures may be among triggers for disbursement; PIU verifies environmental measures implemented and are effective • Final report & accounting • includes EMP compliance, environmental indicators

14. 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