ANCILLARY & INDUCED ACTIVITIES AND INDIRECT & CUMULATIVE IMPACTS SAFEGUARDS TRAINING WORKSHOP ESRA ARIKAN, AGI KISS MAY 2013.

ANCILLARY & INDUCED ACTIVITIESAND

INDIRECT & CUMULATIVE IMPACTS

SAFEGUARDS TRAINING WORKSHOP

ESRA ARIKAN, AGI KISSMAY 2013

Ancillary/Linked Activities : Supporting investments needed for project to meet its objectives, although not financed under the project (would not be done in absence of the project) -- e.g. Transmission lines, pipes, roads, borrow pits, etc. include some photos)

Induced Activities: Take place because the project is implemented, (usually) not part of project objective but predictable result – e.g. Informal settlement along a new road; overgrazing around watering holes, etc.

Indirect Impacts: Impacts arising from Induced Activities Cumulative Impacts: overlapping (additive or synergistic)

impacts of the project and other projects in the same area, which utilize or affect the same environmental or social systems

DEFINITIONS

OP 4.01 Annex A (Definitions): Project area of influence: The area likely to be affected by the project, including all its ancillary aspects, such as power transmission corridors, pipelines, canals, tunnels, relocation and access roads, borrow and disposal areas, and construction camps, as well as unplanned developments induced by the project (e.g., spontaneous settlement, logging, or shifting agriculture along access roads).

OP 4.01 Annex B (Contents of EIA Report): “[EIA] …Concisely describes the proposed project and its geographic, ecological, social, and temporal context, including

any offsite investments that may be required (e.g., dedicated pipelines, access roads, power plants, water supply, housing, and raw material and product storage facilities).”

EA Sourcebook #2 (EA Screening): “One of the requirements of a full EA is that other current and proposed development activities within the project area

and more spontaneous activities spurred by a project (such as migration of people into an area opened up by a road project) must be taken into account. Such cumulative or induced impact may sometimes be the primary determinant of the appropriate level of EA.

OP 4.12 “…policy applies to all components of the project that result in involuntary resettlement, regardless of the source of

financing. It also applies to other activities resulting in involuntary resettlement, that in the judgment of the Bank, are (a) directly and significantly related to the Bank-assisted project, (b) necessary to achieve its objectives as set forth in the project documents; and (c) carried out, or planned to be carried out, contemporaneously with the project. [NOTE: judgement in definition of “contemporaneous”]

IFC Performance Standard 1: “Associated facilities” are those activities or facilities that: a) are not funded as part of the project; and (b) would not have been constructed or expanded if the project did not exist and without which the project would not be viable

References in WB Operational Policies

the watershed within which the project is located; any affected estuary and coastal zone; off-site areas required for resettlement or compensatory tracts; the airshed (e.g., where airborne pollution such as smoke or dust may

enter or leave the area of influence; migratory routes of humans, wildlife, or fish, particularly where they

relate to public health, economic activities, or environmental conservation;

areas used for livelihood activities (hunting, fishing, grazing, gathering, agriculture, etc.)

Areas used for religious or ceremonial purposes of a customary nature.

Examples of Project “Area of Influence) (OP 4.01, Annex A)

Agricultural field

Thermal Power Plant Project and its Ancillary Aspects

Road

Workers’ camp

Road

Resettlement site

Power plant

Dominant windNew sub-station

Quarry& disposal site

Coal handling facility

Landfill for ash disposal

Neighborhood Village

Ash storage facility

Case Study – Road Network

B

Interchange 1

Interchange 2C

Bank-assisted project is to improve the regional transport system, 3 components: (a) Civil works from B to C; (b) 2 interchanges; (c) feeder roads to interchanges

WB will finance 40% of civil works from B to C; EBRD will finance 40% of interchanges; client will finance the rest

EBRD will also finance 100% of a road from A to B, which is essential for achieving the objectives of WB assisted project

WB safeguard policies apply to all components of WB assisted project, and all their ancillary facilities, regardless of source of financing;

Road from A to B is a linked project (related activity)

A

Feeder road

Project Example – Ancillary Investments (Inspection Panel case)

Ghana-Nigeria: West African Gas Pipeline Project (P082502) – 2006 (IDA and MIGA Guarantees)

Project Development Objective: (a) to improve the competitiveness of the energy sectors

of Ghana, Benin, and Togo by promoting the use of cheaper and environmentally cleaner gas from Nigeria in lieu of liquid fuels for power generation and other industrial and commercial uses; and

(b) to foster regional economic and political integration that would support economic growth.

Project financed: (a)a new pipeline system (678 km long) to transport natural

gas from Nigeria to Ghana, Togo, and Benin; (b)spurs to provide gas to power generating units in Ghana,

Benin, and Togo;(c)conversion of existing power generating units to gas; and(d) as needed additional compression investments

Environmental Safeguards Instruments prepared: Regional EIA, country-specific EIAs

Requesters’ claims:

(1) Requesters from Nigeria’s Delta Region were concerned with the Project’s impact on gas flaring reduction and with the safety of an existing pipeline (Escravos-Lagos Pipeline System in Nigeria) to which the Project was to be linked.

E-L Pipeline = pre-existing Ancillary investment

Specific complaints included: EIA for WAGP should have included effects of the Project on the existing pipeline (E-L

pipeline unsafe due to history of poor maintenance and accidents) low compensation rates for the land they had to give up for the E-L pipeline; in area where the E-L pipeline goes under the sea the construction process hurt their

fishing enterprise.

(2) In addition: Requesters from Nigeria and Ghana claimed direct issues with the proposed project including inadequate consultation regarding the Project’s economic viability, the pipeline’s safety and the adequacy of proposed emergency response measures, and its impacts on coastal fisheries, inadequacy of compensation for land acquisition, etc.

Inspection Panel Case

Conclusions of Inspection Panel Investigation

Management and Task Team’s position- -EA did not include ELPS because it was not part of the Project’s area of influence * :

The existing pipeline has been in operation since the early 1990s. It would not be subject to any changes as a result of the implementation of WAGP.

ELPS pipeline has substantial customers other than WAGP and thus ELPS pipeline does not depend on WAGP for its continued operation.

Panel findings – Project should be viewed in broader context of Nigeria’s and the region’s hydrocarbon economy and its social and environmental dimensions:

OP 4.01 states the EIA should include “the area likely to be affected by the project, including all its ancillary aspects, such as power transmission corridors, pipelines,…”

While WAGP is not responsible for the operation of ELPS pipeline, operation of the ELPS pipeline is essential for gas to flow through the WAGP. Thus ELPS is integral to the success of the WAGP initiative.

The project could induce environmental and socioeconomic secondary impacts both “upstream” and “downstream” of the Project – e.g. industry may increase oil and gas development (drilling new wells) in order to supply additional natural gas through WAGP. This could lead to expansion of ELPS capacity/infrastructure . Therefore, gas supply system upstream of WAGP is within Project’s Area of Influence within the meaning of OP 4.01.

The Regional EIA properly flags these (upstream gas supply issues, but no analysis of their nature and scope had yet been carried out.

An Environmental Audit of ELPS should be carried out

Despite not being disclosed, Integrity Study led to safety inspection of ELPS pipeline and detection/correction of some problems, i.e. To an improvement in its safety

*(Nevertheless, Project preparation included an “integrity study” to evaluate safety of existing upstream & downstream structures including the ELPS pipeline and concluded it was safe). Integrity study was not included in EIA and not disclosed.

Ancillary, Induced and Linked Activities should be identified and addressed in EIA. OP 4.12: explicitly applies to all, including contemporaneous linked activities

OP 4.01: explicitly applies only to “ancillary” activities which are considered part of the project

Evolved practice:“Ancillary” activities:

If carried out specifically to serve the project, are treated as part of the project -- WB policies apply directly (e.g. ETL’s serving WB-financed power facilities should comply with OP 4.04, even if not financed by WB)

If already in place and/or not specifically built to serve the project – carry out “due diligence” audit to determine whether there are any serious environmental or social issues (e.g.: operating without required environmental licenses, pending legal actions, evidence of unaddressed serious negative impacts, etc.)

“Induced” activities: depending on predictability/severity, address through EMP (may involve actions/agreements beyond the scope of the project).

“Linked” activities: By definition, important for project objectives but not part of project for which WB is providing financing – carry out “due diligence” and work with Borrower/Financers to address any issues identified.

If any Ancillary, Induced or Linked activities have impacts that are highly likely and serious and no agreement is reached to resolve them, WB may decide not to finance the project in question (“reputational risk”)

Application of OP 4.01 vs. “Due Diligence”

EU Directives EIA Directive (85/337/EEC) (97/11/EC) (2003/33/EC)

(2009/31/EC) (2011/92/EU) Strategic EIA Directive (2001/42/EC) Water Framework Directive (2000/60/EC) and Habitats

Directive (92/43/EEC)

World Bank Safeguard Policies OP 4.01 OP 4.01 Annex A - Definitions OP 4.01 Annex B – Category A Table of Contents of an

EIA OP 4.01 Annex C – EMP

IFC Performance Standards and Guidance Notes

(2012) PS 1 – Environmental and Social Risk and Impact

Assessment Guidance Note 1

CUMULATIVE EIA IN INTERNATIONAL STANDARDS

What is Cumulative Impact Assessment?

Project A site

Project A zone of impact

Important Env. Asset - VEC

Important Cultural Asset - VEC

Existing Facility B site

Facility B zone of impact

Zone of impact of planned/reasonably foreseeable development or trend

Zone of Impact of directly linked or induced development

VEC EXAMPLES

ENVIRONMENTAL ISSUE VEC

AIR Closest settlementFlora/Fauna

WATER QUALITY and QUANTITY

Other water users – such as fish farm owner, farmers

ECOLOGY Aquatic species, ..

EIA and “CEIA”

• Minor risk • Few other significant impact sources • Easily understood impacts and interactions

• Major risk• Numerous other significant impact sources

• Complex impacts and interactions

Cumulative impacts section of EIA prepared without in-depth CEIA exercise

In-depth CEIA exercise needed(should be simultaneous and interactive with rest of EIA)

EIA should identify potential cumulative impact issues and associated risks:

Discussion of Cumulative Impacts

within EIA

VECs may be general and LACs may be presented in qualitative terms

Usually rely on existing data

Usually use relatively simple analytical tools (e.g. impact matrix)

In-depth Cumulative Impact

Assessment

VECs should be specific and LACs mostly expressed in quantitative terms

Often requires collection of additional baseline and impact-related data

Use more sophisticated and quantitative analytical tools (mathematical or computer modeling of alternative scenarios, dose/response curves, GIS/land use mapping, etc.)

Projects to be Considered underCumulative Assessment

Afşin A Santralı

Afşin B Santralı

Under construction;• Adatepe• Klavuzlu• Dağdelen• Kandil• Sarıgüzel• Hacınınoğ

lu

Planned HEPP• Karakuz• Kavaktepe• Hasanali• Dogutlu• Geben• Kısık

Operation• Kartalkaya• Ayvalı• Menzelet• Sır

Other Existing• Afşin A Plant• Afşin B Plant• Göksu

Irrigation

Other Planned• Afşin C, D, ve

E Plants

Why Do CEIA?Because a proposed project is likely to have

significant impacts on regional “Valued Ecosystem Components” which are also impacted by other actions/trends (sources)Because the impacts from different sources (stressors) can interact in additive or synergistic ways, not always easy or straightforward to predict, requiring in-depth analysis

Because the most feasible and cost-effective mitigation measures might not lie within the context of the proposed project

Because impacts from other stressors can undermine the project’s objectives and/or result in unexpectedly severe impacts

Because looking at the broader picture might reveal new opportunities for better overall outcomes

What information is needed to determine whether EIA for Project A needs to take Facility B into account?

Distance between A and B …. are there circumstances where this information might be enough?

Located within same ecological system (river/lake basin, watershed, airshed, wildlife home range) …..

what information is needed to know this? what sources can provide it?

Overlapping zones of impact – impact on the same VECs ….

what information is needed to know this? what sources can provide it?

When to do CEIA?

Starting point: Project A has potential off-site impacts (e.g. air or water emissions, erosion/sedimentation, noise, etc.) which cannot be eliminated through realistic mitigation measures

How to do CEIA:Assessment Framework

1. Scoping:

• Identify issues/assets of concern, at a regional scale – (information sources: spatial plans, experts, public consultation)

• Select appropriate Valued Ecosystem Components and determine Limits of Acceptable Change for those VECs

• Identify spatial and temporal boundaries for the study based on VECs

• Identify other stressors (existing and expected future actions and trends) that may affect the same VECs

• Identify potential impacts of project and of other stressors – together they make up the cumulative impacts

(Red text indicates how CEIA differs from EIA)

3. Potential mitigation measures:• Identify potential mitigation measures – for proposed project and where possible, measures to reduce impacts of other stressors

• Evaluate feasibility and costs, develop realistic mitigation plan -- including costs and institutional responsibilities (some of which may be outside scope of the project)

2. Data Collection and Analysis:• Collect baseline data relevant to VECs and potential impacts -- literature, consultation, data collection

• Assess likely effects of the project on VECs

• Assess likely effects of other stressors on VECs

• Evaluate potential cumulative (additive, synergistic) effects to assess total impact; use scenarios and modeling as appropriate

4. Evaluate residual impacts: Compare to pre-determined Limits of Acceptable Change/ objectives/thresholds

5. Follow-up (multi-stakeholder) Monitoring of VECs and mitigation measures (project and other stressors)

Adaptive management – process to make changes based on monitoring

THANK YOU…