World Bank Safeguard Training Ankara March 31, 2010.
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Implementation of Environmental Management
Frameworks and Environmental Management Plans : Their
Integration in Project Operational Manual
World Bank Safeguard TrainingAnkara
March 31, 2010
Simple and practical framework and guidelines work
Subproject design is enhanced by the use of guidelines
Sustainability measures incorporated in the design Increase awareness of local governments and
communities Need to build capacity at all levels Buy in of proponents on the added value of
safeguards beyond compliance is critical Costing for mitigating measures is always an
issue, hence mainstreaming in the design ensures incorporation
EMF Implementation Experience
Building capacity of local governments and communities
Enhancing the capacity of Fis
Incorporating estimated costs of EMP mitigation measures in subproject cost
Improving environmental screening
Intensifying supervision and monitoring
Challenges of EMF Implementation
Challenges of EMP Implementation
1. Unrealistic/inadequate monitoring indicators
2. Infrequent site visits and inadequate review and evaluation of monitoring aspects and reports
3. Failure to revise the EMP in response to project changes during implementation
4. Inadequate follow-up on of agreed actions
5. Ineffectiveness of proposed institutional capacity measures
Practical Solutions
Assignment of dedicated Environment Specialists to FI is good practice
Practical, specific and measurable environmental indicators
Bidding and Contracting Documents should include EMP provisions on mitigation/monitoring
Active monitoring is needed, including site visits Updating of mitigation measures and
institutional assignments as required
Assess the quality of EMP implementation and supervision
Identify any systematic issues to be addressed Recommend practical measures to address them Apply the measures to existing projects (to the
extent possible) and to future operations Disseminate results (dialogue with Borrowers;
“ECA Learning Brief;” staff & Borrower training
Objectives
Methodology: Desk Review + Site visits
EMP Implementation ExperienceExample: South Caucasus Highways Infrastructure
Projects Thematic Review
Georgia• East-West Highway Improvement Project 1 (EWHIP 1)• EWHIP 2• EWHIP 3• Secondary and Local Roads Improvement Project (SLRP) –
(numerous small project roads)• Additional Financing Projects
Armenia• Life-line Roads Improvement Project (LRIP)
• Numerous small project roads (1- 6 km)
Azerbaijan• Azerbaijan Highway I• Azerbaijan Highway II (Category A Project)• Azerbaijan Highway II-Additional Financing I & II (Multiple road segments under each project)
Projects Reviewed
Desk Review Findings
Most Projects screened/categorized correctly
Most EIAs well prepared
Timely disclosure and public consultations carried out
EMPs: comprehensive but mitigation measures overly generic
Little tie-in of EMP with the design
Little tie-in of EMP with the contract documents
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Site Visit Findings
Contractors routinely failed to implement many aspects of EMPs, particularly relating to:
◦ Sourcing of materials (management & restoration of
borrow sites)◦ Disposal of construction wastes◦ Management of construction sites (e.g. drainage, erosion,
impacts on surface waters)◦ Air quality precautions (e.g. covering truck loads, dust
suppression)◦ Construction camp conditions
Inadequate supervision by contractors, supervision consultants, Roads Agencies and WB Project Teams
Looking behind the scenes
Beautifully paved road
But what is on the other side of that wall?
EIA identified area as prone to landslides Design did not take this adequately into account Poor design led to land slides and destruction of houses (Notice
partially washed out village road)
EIA not incorporated into design:
Waste Material Handling & Disposal
Asbestos material dumped in a local landfill
Concrete waste dumped on bank of river which supplies water to nearby towns
Waste material being dumped haphazardly on nearby land
Dumped waste material from tunnel excavation, burying fragile ground
cover
Mining gravel from riverbed
Poor waste management at Contractor’s camp
Example of good practice
Water spray used to control dust from aggregate crusher plant
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Why so many problems?
Lack of ownership: ◦ Roads Departments play minimal role in processing the EA reports for WB-
financed projects (leaving it to Bank staff to work with EA consultants)◦ Local supervision consultants don’t see environment as major issue
(“business as usual”)◦ International supervision consultants not doing their job – fail to report to
Roads Agencies◦ Roads Agencies ignore reports of environmental problems
Lack of clear responsibility: ◦ EMPs too generic◦ EMP provisions not included in contracts, so not legally binding
Lack of capacity: Roads dept. have limited Environmental & Social staff and little incentive to strengthen
Excessive WB involvement increases WB supervision costs and stress on WB staff - Environmental & Social staff in field responsible for too many projects to do regular site visits
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Recommendations More detailed EMPs, more specific, informative and monitorable
mitigation measures (e.g. drawings of septic tanks for camps) Ensure EMP incorporated in designs and bidding documents
(with realistic assessment of costs)◦ Specific costed actions in Bill of Quantity◦ Umbrella provision (non-competitive)
Hire independent “Environmental Auditor” for monitoring (don’t leave it to general supervision consultant)
Increase and clarify Borrowers’ responsibility – insist on “staffing up” as needed. (WB should not be “first stop” for consultants)
Training for Roads Agency staff, contractors staff, consultants – starting with Project Launch workshop
Highlight environmental issues in Aides Memoires/cover letters Build fines and penalties for non-compliance into contracts and
enforce them
sub-project cycle
IDENTIFICATION
PRE-FEASIBILITY
(Assisted) preparation of applications
Submission of priority proposals
Eligibility Screening
Evaluation/selection of proposals
Sub-Project approval
Agreement on work plan, contract signing
Start of works
EMP implementation
OPERATION
SUPERVISION
FEASIBILITY/DESIGN
Pre-FS Form
Environmental PermitConstruction Permit
Monitoring of works
Progress reports
EIA Preparation
Incorporating EMF into Project Cycle
Project Implementation CycleSubproject Identification and Planning Process
ImplementationProcurement Procedures
Financial Management ProceduresInstitutional Arrangements
Project Operational Manual (POM)
Environmental Review and Implementation ProceduresScreening Form
Environmental and Social Impact Mitigating Measures Monitoring Checklists
Sub-loan eligibility criteria: description of eligible/ineligible investments, potential environmental issues
Sub-loan application: identify potential environmental issues and proposed mitigation measures;
Sub-loan screening, evaluation & selection: EA screening, evaluation of env. issues and proposed mitigations; indicate whether specific EA/EMP required
Preparation/signing of subproject loan agreement: Includes requirement to implement EMF
Procurement: includes environmental provisions in bidding documents, specifications, contracts
Sub-loan disbursement/Progress reporting: environmental measures maybe triggers for disbursement; PIU verifies environmental measures implemented and are effective
Monitoring & reporting on sub-loan Implementation: includes EMP compliance, environmental indicators
Incorporation of EMF aspects in POM Procedures
EA Screening/categorization criteria National and World Bank EA requirements Relevant environmental standards Environmental issues and mitigation measures for
each type of subproject to address impacts and enhance sustainability of subprojects
Measures for consideration and/or mainstreaming in subproject design, site selection, EMP formulation and implementation
Public disclosure and consultation procedures Monitoring, evaluation and reporting
arrangements
Environmental Guidelines – Chapter or Annex to POM
TAJIKISTAN
COMMUNITYAGRICULTURE AND WATERSHED
MANAGEMENT PROJECT
The Project covers a total of 36 thousand square km. in Surkhob, Zarafshan, Vanjob and Toirsu Watersheds. The area includes 390 thousand hectares of agricultural land
with a total population of 550 thousand people (42% of total mountain population)
Component I: Rural Production Investments Component II: Institutional Support and
Capacity Building Component III: Project Management
Project Overview
Farm productivity investments - input for annual crops, horticulture, livestock, processing, distribution, leasing, credit facilities
Land resource management – land groups apply soil conservation, moisture management, investments such as horticulture, woodlots, fodder
Rural infrastructure – drinking water, small irrigation, rural track rehabilitation, small power generation
Rural Production Investments
Financially and commercially feasible;
Socially inclusive and considerate;
Institutional feasible;
Environmentally sound and sustainable: subprojects should meet Project requirements for sustainable land management;
Improve agricultural productivity
Subproject Underlying Principles
Minor impacts from small works will follow proper design standards
Before approval, authorities will verify subprojects comply with relevant national local environmental laws and regulations and be consistent with Bank policy and procedures
Projects will be reviewed by different authorities depending on the overall project cost
As a condition of disbursement, the PMU was required to hire an Environmental Specialist.
$50,000 was allocated for training and equipment to enhance environmental assessment and management of government, civil society and project related staff
Additional key attributes
Initial awareness raising and communication
Indicative descriptions of potential rural production investment activities
Group process and eligibility guidelines Village and CIG implementation
arrangements Responsibilities of Project Management
Unit, Project Coordination Unit, contracted facilitators and specialists, and line agency personnel
Project Operational Manual
Tools for participatory analysis Indicative list of detailed questions on
feasibility and eligibility to be addressed in subproject proposals
Format for subproject proposal Memorandum of Understanding (MOU) to be
signed by PIU & Beneficiary Checklist for review of subproject proposal and
village submissions by project committees Suggested Terms of Reference for NGO
contracts
Project Operational Manual Annexes:
Will the subproject generate any wastes during construction or operation (air, liquid or solid)? If so, how will these be handled? What are the proposed measures:
To prevent, minimize or treat wastes? For ultimate disposal of any waste residues?
Does the subproject create risk of impact on any endangered plant or animal species (e.g., introduction of invasive exotic weeds, conversion of
natural habitats)? If so, what has been done to prevent or minimize these impacts?
Have alternative site and design options been evaluated and the least risky option selected?
Is compensation proposed (creation/management of equivalent natural habitat?)
Does the subproject create risk of impact on any surface or ground water sources? (e.g. pollution, siltation, excessive abstraction)? If so:
Have the impacts on other water users been assessed? Have potentially affected other users been consulted? Has adequacy and sustainability of water supply been ascertained? Have measures provided for source protection?
Example Annex: Environmental Soundness & Sustainability
(sample questions - paraphrased)
What is the EA instrument required for this subproject (e.g., EMP, limited environmental assessment plus EMP)?
Has the EA instrument received environmental clearance (at the raion/national level)?
Is the capacity for implementing and monitoring the EMP adequate?
Have EMP costs been accounted for?
Example Annex: Environmental Soundness & Sustainability (contd.)
SUBPROJECT # - 254 AREA - 624 ha BENEFICIARY # – 4353 hh
HORTICULTURE/TERRACING
BEFORE NOW
HORTICULTURE/TERRACING
TERRACING
DRINKING WATER SUPPLY
Community investments in practice
SOLAR ENERGY FOR HEATING WATER
Community investments in practice
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