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ENVIRONMENT RESEARCH CENTRE
ENVIRONMENTAL & SOCIAL ASSESSMENT FRAMEWORKMaldives Environmental Management Project
February 3, 2008
This ESAF provides a guidance framework to the Project
Management Unit, and Project Implementing Agencies on the approach
and processes to ensure that environmental and social aspects,
impacts and mitigation are integrated into the Project.
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TABLE OF CONTENTS
I.
Introduction ..................................................................................................................................... 3
II. Project Objectives and
Components ............................................................................................ 4
III. Environmental Policies, Laws, Regulations, Notifications and
Traditional Rights ............. 11 IV. Environmental
Review Capacity of the Ministry of Energy, Environment and Water
(MEEW) and adequacy of the Environmental Clearance
Process ................................................ 14
V. World Bank Environmental and Social Safeguard Policies and its
Relevance to the Maldives Environmental Management Project, and
Compliance with Applicable World Bank Policies, Guidelines and
Procedures ..................................................................................... 14
VI. The Need For an Environmental and Social Assessment
Framework ................................... 22 VII. The
Process for Site and Technology Selection for the Regional Waste
Management
Facility ............................................................................................................................................... 24
VIII. Island Waste Management
Centers ....................................................................................... 28
IX. Monitoring and
Evaluation ....................................................................................................... 29
X. Environment and Social Assessment and Management
Framework ...................................... 30 XI.
Framework
Management ........................................................................................................... 34
Annex 1: Environmental and Social Action Plan for
IWMC’s ..................................................... 49
Annex 2: Standard Site Selection
Procedures ................................................................................ 55
Annex 3: Design
Specifications ....................................................................................................... 64
Annex 4: Island Waste Management Planning
Manual ................................................................ 86
Annex 5: Generic Terms of Reference for the preparation of an
Environmental Impact Assessment (EIA)
statement. ........................................................................................................... 97
Annex 6: Environmental and Social Impacts Screening
Checklist ............................................ 102
Annex 7: Community Mobalisation Work
Plan ........................................................................... 104
Annex 8: Community Centered Development (CCD)
Procedures ............................................. 111
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I. Introduction The Maldives
Environmental Management Project (the
Project) aims to improve and
develop a socially and environmentally
sustainable system of solid waste
management that reduces the associated
environmental and public health risks
in the North Central Region
which can be subsequently
replicated and scaled up across
the country. It also aims
to strengthen capacity
for environmental management in the
Maldives. These objectives will
be achieved through the following
components: (1) a regional solid
waste management program for the
North
Central Region, with Island Waste Management Centers (IWMCs) located in participating islands, supported by a regional waste transfer and transport system for residual waste from the IWMCs and a regional waste management facility for residue management; (2) the capacity building component addresses some of the human resource constraints and informational impediments to improved environmental management.;
and (3) Technical assistance for
a Regional Strategic
Environmental Assessment
to assess the impact of human activities, global warming and other factors on the local environment in the North Central Region.
Overall, the project
activities would result in
improved environmental management in the Maldives.
However, considering
the pristine and fragile ecosystem
in the Maldives, the regional
solid waste management component could
generate adverse environmental impacts
even though the net environmental
impact of the component would be
strongly positive. It is
unlikely that activities undertaken in
Capacity Building for Environmental
Management and the Regional
Strategic Environmental Assessment for
the North Central Region will
result in adverse environmental
or social impacts. In fact,
both components will lead to
improved environmental planning
and management in the Maldives.
The regional solid waste component
could generate adverse environmental
impacts, especially over the short
term, although
the net environmental and
social impacts are expected to be beneficial.
Projects and Programs financed with
IDA resources need to
comply with World Bank Operational Policies. Therefore, components and sub‐components eligible for funding under this project will be required to satisfy the World Bank’s safeguard policies, in addition to conformity with environmental legislation
of the Government of the
Republic of the Maldives (GoM).
The proposed project is classified
as Safeguards Category “A” by
the World Bank, which means that
the project has
the potential to have significant and possibly
irreversible adverse environmental and/or social
impacts. A detailed Environmental Assessment will be conducted
for the
regional solid waste management component in accordance with OP/BP 4.01 to identify and mitigate potential adverse environmental and social impacts of the project.
Based on the lessons learned from islands with no formal solid waste management and also from the experience
of the existing Island Waste
Management Centers (IWMCs), which
have
been constructed for solid waste management at the island level, it is clear that community participation is
essential for effective operation and
long term sustainability of the
IWMCs.
Community consultations and their
leadership in taking responsibility
for waste management
in the respective islands, particularly with regard to the role the community would play
in the selection of recycling and resource recovery activities to be undertaken at the IWMCs has been shown to lead to effective management
of these facilities. Therefore,
the specific activities to be
undertaken at IWMCs supported under
the project will be decided by
the community when preparing Island
Waste
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Management Plans
(IWMPs) which will be an activity during project
implementation. The
type of regional waste management
facilities, including the options for
technological choices—engineered landfills where
the level of engineering needed
for containment of pollution will
depend on
the pollution potential of the waste arriving at the site; incineration which will be based on the calorific value of the residual waste; or waste to energy through stream recovery—can be decided only after the
IWMPs identify the amount and
nature of the waste being
transported to the RWMF.
In addition, the unique ecosystem in the Maldives poses significant problems in identifying appropriate locations
for siting the RWMF, which
is unlike in any other country.
Public opposition due to
the NIMBY syndrome could preclude
the use of an inhabited
island as a site for
the RWMF.
The high population density in most inhabited islands could further contribute to problems in siting a RWMF in an
inhabited island.
Islands with compatible land uses
such as industrial
islands could possibly serve as a site for a RWMF. Alternatively, an uninhabited island in the North Central Region could be a potential site
for a RWMF.
However, virtually all uninhabited
islands are densely vegetated and surrounded
by a continuous reef system,
both likely to contain high
terrestrial and
marine biodiversity. If there is no alternative but to choose one of the 180 uninhabited islands in the North Central Region, access for waste transfer barges or
landing craft will necessarily
include excavation of a channel
for navigation through the coral
reef system surrounding the islands.
A decision
to excavate a reef for a navigation channel has to be taken only after a careful assessment of the health of the reef ecosystem surrounding the island. Since the Maldives has very little data on the quality of its reef ecosystems, an assessment of the reefs of potential uninhabited islands is a pre‐requisite to the decision making process.
Therefore, an environmental assessment
in accordance with OP/BP 4.01 and
the requirements of the GoM
cannot be carried out during
project preparation. This
Environmental and
Social Assessment Framework (the Framework) has been prepared by the Environment Research Center on behalf of the Government, in lieu of a project specific EA and will serve as a template for undertaking project specific EAs once the details of the specific works have been identified. GoM clearance and World Bank approval of the environmental assessments for the regional waste management facility and
the island waste management centers
is a pre‐requisite for disbursements
of funds for
the respective sub‐components under the project.
II. Project Objectives and Components
This project has two development objectives. The first seeks to improve and develop a socially and environmentally
sustainable system of solid waste
management that reduces the
associated environmental and public health risks and can be replicated and scaled up across the country. The second aims to strengthen capacity for environmental management
in the Maldives, by addressing some of the human resource constraints and informational impediments to improved environmental management. It aims to have decision‐making processes of relevant government agencies make use of
trained professionals and scientific
information to assess, design and
implement responses
to environmental risks. The proposed project would have four components: (1) a regional solid waste management program for
the North Central Region; (2)
capacity building for
environmental management; (3)
technical assistance for a regional strategic environmental assessment enhancing environmental management through the collection and use of data and (4) project management and project communications.
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Component 1: Regional Solid Waste Management Program Solid
waste remains the most visible
environmental threat to the tourism
industry.
The management of solid waste is especially challenging in the Maldives, much more so than other small island states. With a highly dispersed population spread across numerous islands there is little scope for
harnessing scale economies and the
costs of delivering services are
high. In addition
with restricted endowments of
land, the space available
for disposing of waste is
limited calling for the waste
stream to be minimized through
incentives for resource recovery such
as recycling and composting.
Finally, a fragile marine ecosystem
requires that special attention be
given to
the choice of technology and system design to mitigate adverse impacts, with further cost implications. To
address these risks and challenges
stringent criteria need to be
applied for site
selection, engineering, technology choice and management within the context of human resource constraints in the Maldives. Reflecting
the Maldives’ uniquely challenging
geography and fragile ecology, the
program would operate at multiple levels, building upon synergies between these levels: The construction of Island Waste Management Centers (IWMCs) would provide facilities for island communities to reduce the volume
of waste requiring final disposal
by sorting, recycling and
composting, while temporarily storing
residual waste in a safe and
environmentally responsible manner.
A Regional
Waste Management Facility (RWMF), built on an uninhabited island or an island with compatible land use, would serve as the destination
for residual waste from the
islands.
These would be supported by allied services such as waste transfer and transportation
facilities, technical assistance, community programs,
financial systems all of which would be guided by stringent environmental criteria.
The facilities would be designed
and built to the highest
appropriate standards that is
economically viable, to reduce the
risk of contamination
from solid wastes.
Special attention would be paid
to medical wastes and toxic wastes which would require special handling and management. The project would support a regional solid waste management program in the North Central Region, which
is currently under‐served by waste
management facilities. The program
is likely to
be undertaken in one or more of the four atolls—Baa, Raa, Noonu and Lahviyani—in the North Central Region of the country. The “catchment” or group of atolls and
islands to be served will be defined during
project implementation based on a
comprehensive technical, financial and
environmental feasibility study. The
factors that would influence the
choice of catchment
include economies of scale required for the delivery of a viable waste management service, the distribution of population, the geography and environment of
the archipelago, and
the distribution of
(current and planned) resort development. Once the catchment has been identified, there will be detailed assessments of current
and future needs, technological
choices for waste management and
a thorough environmental and social
impact assessment. Environmental
factors would be given high priority over economic considerations in determining both location and design of the system. The project would include the following subcomponents: Sub‐component 1.1: Technical Assistance for Feasibility Studies, Technical Designs, Environmental Impact Assessment Studies, Contract Documentation and Capacity Building Maldives confronts distinct problems
in
the safe management and disposal of wastes
that are not encountered elsewhere in the world and this calls for considerably greater assessment and scrutiny of
options to address the technical,
economic, social and unique
environmental
challenges. Accordingly, this sub‐component would
finance a social assessment which will be conducted using participatory
rural appraisal (PRA) techniques to
identify ways and means of fully
involving the community in waste
management within the islands. A
technical, financial and
environmental feasibility study will be conducted to select the most suitable waste management option, taking into
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account the technological and site location issues. The study will be conducted in two phases. The first
phase of the study will (i)
develop potentially suitable
waste management system
options (including sensitivity analysis)
in order to inform the Best
Practical Environmental Option
(BPEO) selection process; and (ii)
conduct a scoping investigation of
short listed islands on which
the proposed Regional Waste Management Facility (‐ies) may be located. The second phase will involve undertaking (i) selection process for the preferred regional waste management system option; and (ii) a detailed technical and financial feasibility study for the preferred regional waste management option
at the finally selected site.
The trigger for moving from
Phase I to Phase II will
be
the successful selection and agreement of the preferred regional waste management system option and final site location. Inputs from the Regional Strategic Environmental Assessment (RSEA) component will complement this analysis. The selection of the appropriate technology and location will be based on an
iterative process where environmental aspects play a determining
role. The environmental impact
assessment will be a part of
the BPEO process which will
influence the conceptual and detailed
engineering designs of the RWMF,
which will prepared under this
sub‐component.
In addition, technical assistance would be made available for facilitating public‐private partnerships for regional
waste transfer and operation of
the RWMF; including preparation of
a
contractual framework and bidding documentation and
to ERC,
the participating Atolls Offices and
the
Island Waste Management Committees in environmental monitoring and evaluation. The Environmental Impact Assessments (EIA) for the RWMF and Environmental Management Plans for
the Island Waste Management Centers
(IWMCs) would be prepared in
accordance with the processes
laid out
in this Environmental and Social Assessment Framework that has been prepared for
the project. A program for
regular environmental monitoring will be established
to allow
for greater emphasis to be placed on the interconnectivity of background environmental data collection and
impact data collection through the
development of ongoing environmental
monitoring programs. The data collection will be
linked with the Regional Strategic Environmental Assessment process by which the scope of the environmental impacts on the affected environment can be more thoroughly
examined and more robust methods
of predictive and verification
analysis can
be utilized. The science‐ and evidence‐based approach in this project and the detailed attention given to environmental
factors is unprecedented in
the Maldives and its
implementation will
serve as a model for the development of future RWMFs in the country. Sub‐component 1.2: Development of Island Waste Management Plans This sub‐component will finance the preparation of
island waste management plans (IWMPs).
The aim of this sub‐component
is to engage communities to
lead and participate
in developing IWMPs. Intervention
in the islands will commence
with an extensive public awareness
program and communication campaign on
environmental issues in general and
solid waste in particular
to encourage the island community to participate in environmental management. This will be followed by the use of Participatory Rural Appraisal (PRA) techniques to understand the social structure and physical
layout of communities, patterns of
leadership, formal and informal
island networks, economic activities,
transportation, patterns of waste
disposal, willingness to pay for
improved SWM, entry points for community mobilization, and the kinds of incentives to which individuals and communities
are likely to respond.
Community‐level recycling and resource
recovery would be promoted at
IWMCs in order to reduce the
volume and pollution potential of
the
residual waste requiring transport to RWMFs.
The current systems of waste collection within the
island would be assessed and alternatives will be agreed with
the community as needed. Transport
to
the RWMF would also be examined
to develop a sustainable
system with the right incentives
for community participation.
NGOs with prior experience in
community
level waste management will mobilize communities to participate in waste‐segregation and door‐to‐door collection programs and will play
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a role
in community awareness raising through
information sharing, education and communication programs. Sub‐component 1.3: Construction of Island Waste Management Centers This
component will finance the
construction of IWMCs as a
focal point for island
waste management activities, based on
the extent and type of
community‐level recycling and
resource recovery programs in the Island Waste Management Plans. The number of centers to be built will be determined
following the Social Assessment conducted under sub‐component 1.1. The community would be
involved
in managing, operating and maintaining
the IWMCs either directly or with
the assistance of contract labor.
The final footprint of the
individual IWMCs would depend on
the population size, commercial and
industrial activities on the island
and expectations of the
local community. While the longer term objective is to get community level waste segregation, it is likely that
co‐mingled solid waste will be
brought to the IWMC and would
be separated into
organic wastes, recyclables, hazardous (including medical) wastes and residuals requiring final disposal. Site separated
waste will be treated appropriately
to reduce the volume and
pollution load of the residue
for ultimate disposal at the
RWMF. This sub‐component would
also include funding
for collection equipment and transport facilities for waste to be brought to the
IWMCs, in islands that require
it, and for operation of the
IWMCs on a declining basis.
The
Island offices and community contributions will account for operation and maintenance costs after the second year. Communities would
retain ownership and responsibility
for maintenance of IWMCs and
replacement
of equipment will be a joint responsibility of the Island Office and the community. Sub‐component 1.4: Waste Transfer System to the Regional Management Facility This
sub‐component would finance
the procurement of barges or
landing craft for the
transfer of waste to RWMFs, and
of recyclables to markets.
Island communities would be expected
to contribute some fraction of the costs, with cross subsidies from participating tourist resorts or other local enterprises and the Government to render the system economically sustainable.1
In keeping with the National
SWM Policy, private‐sector participation
in the operation of the waste
transfer service would be explored.
Sub‐component 1.5: Construction and Operation of the Regional Waste Management Facility This sub‐component would finance the construction of one or more RWMF(s) on uninhabited islands or islands with compatible land use, as the case may be, taking the environmental risks into account. The
selection of the preferred regional
waste management option will be
based on a
detailed analysis of potentially suitable technology, selection of which will be
influenced significantly by the characteristics of
the location of the site.
These attributes will be evaluated
through a weighted process, which
is biased towards environmental
safeguards, that would finally select
the waste management technology and
the site through
the process described briefly
in sub‐component 1.1 known as the Best Practical Environmental Option (BPEO). Land is a premium in the Maldives, even on islands with compatible land use such as industrial islands, while virtually all uninhabited islands are surrounded by continuous coral reefs without harbor access, resulting
in the identification of a suitable
site to locate the regional
waste management facility being a
challenge. Due to
this constraint, the waste management option selected may be driven by the environmental
impacts of the site. Therefore,
it is proposed that facilities
considered would include engineered
controlled 1
The team encountered resistance to the institution of new taxes or
fees on resorts from the Ministry of Tourism and Civil Aviation.
Currently many resorts transport their residual waste at their own
expense to the Malé landfill on Thilafushi. However, they are often
able to take advantage of vessels returning to Malé after
delivering supplies so that there is savings of transport costs to
resorts. It is likely that a contribution by resorts to a reliable
pick-up and transfer service would be welcomed and would possibly
even yield a net saving for the resorts.
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landfills, incineration of combustible residues and viable waste to energy options designed to reduce the risk of contamination on the island, the surrounding waters and the atmosphere over a 20‐year horizon.
The population to be served
by the project would be
defined when the catchment
is identified by the two phase
technical and financial feasibility
study to be undertaken
during implementation. Regardless of the option selected, a disposal site for residue or ash will be needed. The
disposal site would be engineered
so that the risk of
contamination is minimized. Since
a majority of the waste will be municipal solid waste, the disposal of the residue wastes or ash
in an engineered controlled site
is unlikely to pose serious
environmental management problems.
A section of the RWMF
site would be secured and fully
contained for disposal of small
amount
of medical and toxic wastes. The RWMF will be operated by the private sector through a public private partnership, in accordance with the National Policy on solid waste management. Sub‐component 1.6:
Biodiversity Offsets to Compensate for Use of an Uninhabited Island for the RWMF If
the regional waste management
facility has to be located on
an uninhabited island,
where establishment of the
facility would result in adverse
impacts to the island ecosystem
such as
loss and/or damage to terrestrial and marine biodiversity, the project would undertake specific measures to offset the loss of biodiversity and island habitat, should this occur. In keeping with the Bank’s OP 4.04
on Natural Habitats, biodiversity
offsets could be a part of
the regional solid
waste management component. In case such damage is unavoidable, an area with a pristine coral reef and marine environment could be identified based on the work undertaken in the reef surveys of the TA for Regional Strategic Environmental Assessment component, and protected under the project. This would be done through the creation of a program for focal island ecosystems for community based environmental management. Component 2: Capacity Building for Environmental Management The environmental agencies and regulators in the Maldives have a broad mandate, but their capacity to manage growing environmental pressures does not match the needs of a fragile environment on which the economy depends. The proposed project is designed to at least partly fill the staffing gaps and
capacity needs areas relating to
the project itself. It is
recognized that it would be next
to impossible to build a
large, permanent cadre of environmental
specialists with a
reach extending over the entire archipelago and across all the sectors. The stress would therefore be on developing (i)
a core of competent specialists
and generalists in MEEW, other
relevant ministries (Planning, Fisheries,
Tourism, Atoll Administration and
Construction) and in the private
sector
(particularly NGOs and the tourism sector) to guide the environmental assessment and decision‐making process; (ii) a cadre of service providers
to carry out monitoring and
field surveillance activities making
full use of modern technology to
carry out their job, and (iii)
a network of private citizens
and stakeholders (e.g. fishermen, hotel and dive operators, boat operators and others) with the training needed to serve as the “eyes” and “ears” of the Ministry. Priority would be given to training existing government staff and to others for whom there is a reasonable expectation that their skills could be utilized in the near or medium term. Component 3: Technical Assistance for Regional Strategic Environmental Assessment The objective of
this component is to assess the
impact of human activities,
global warming and other
factors on the local environment
in the North Central Region of
the Maldives.
The exercise would gauge changes
in key variables such as reef health, biodiversity, beach erosion, all of which eventually impact on the fortunes of tourism and fisheries – the main engines of economic growth. The evidence would allow an opportunity to adopt policies that may slow down or arrest processes that are destructive of
the natural capital of the Maldives.
The mechanism by which this exercise
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could yield the desired
results would be by presenting
reliable evidence and focused analysis
that could lead to changes in attitude and practice by decision makers and the public in general. For
purposes of the proposed project,
the regional strategic environmental
assessment would provide a framework
to demonstrate the utility of
incorporating environmental parameters
in development decisions. The exercise would be useful in making more informed decisions about key development
concerns that are currently
faced by the government such as:
(i)
siting of economic activities (such as tourist resorts,
industry, recreational dive sites, fishing grounds, protected areas, “safe
islands,” industrial plants, siting
of regional waste management
facilities and
other infrastructure); (ii) natural hazard and risk assessments (including the presence of coral reefs serving as natural buffers in same), focusing particularly on coral reefs, beach erosion, bleaching events and others (iii) identification and eventual reduction of stressors affecting coral reefs, (iv) identification and creation establishment of marine protected areas. This
component would place particular
emphasis on ensuring that the
country’s critical marine assets
generally and its coral reefs
and underlying natural processes
specifically are more fully considered
in the aforementioned planning and
decision‐making processes. There is
little experience in the conduct of RSEA’s in the islands, accordingly this component would proceed on a cautious
basis, beginning with an intense
process of information collection
that would
engage communities, raise their awareness and provide
inputs for a RSEA.
Concurrent with the collection and
analysis of data, the project
would foster discussion and debate
among stakeholders
by examining alternative scenarios for regional development. The geographical scope of the component would be the North Central Region composed of Raa, Baa, Lhaviyani and Noonu2 atolls, the latter only partially covered due to its division by an administrative boundary to the north. This region
is comprised of a total of 224
islands of which 44 are inhabited and 11 have
tourist resorts.
The total population
is an estimated 42,000.
As population pressure and commercial demands grow, there may be increasing pressure on to the reclassify some of these islands
to support economic development,
particularly tourism. Consumption is
also likely to increase as will
the risk of contamination from
solid and
liquid wastes and possible damage
from divers. It is important
that full information be available
to ensure that
informed decisions can be taken. The ERC would serve as the
implementing agency of the RSEA, with coordinated
inputs from other relevant agencies. It would oversee work carried out by all participants and would provide a forum for evaluating development scenarios. A regional committee would be formed with representatives from
each of the targeted atolls and
some island communities reflecting a
cross‐section
of community sizes and characteristics.
The regional committee would examine various scenarios for the
development of the region based
on data produced by the Project
and other sources.
The committee would include Atoll Chiefs and be assisted by a professional facilitator with experience in Strategic
Environmental Assessment. The
assessment would go through multiple
iterations to assure realism and
to allow time for
consultations with constituent communities.
The
strategic assessment would issue periodic reports (at least one per year) on the development of the Atolls in the
North Central Region with policy
recommendations for the government
and proposals
for further studies and mobilization.
The central
focus of the RSEA process will be how to assure the continued development of the island communities of the North Central Region in the face of major changes
in their environment, namely climate
change, resource depletion,
infrastructure development, increased consumption, and resort development.
2
Noonu atoll is only partially covered due to its division by an
administrative boundary to the north
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To be credible and useful
the RSEA would need to be
grounded in scientific information
and evidence of trends.
Accordingly this component would
support a parallel process designed
to fill critical information gaps
in four priority areas
identified by GoM and build the technical capacity to sustain the process. Beach Erosion:
Erosion of beaches affects well over 90 % of the country’s
inhabited islands and is likely
to increase in severity over
time with climate change
associated effects (e.g., sea level
rise higher intensity storm surges). It is unclear, but planning decisions in the absence of better data may be
a significant source contributing to
the problem. On several
islands, a significant increase
in beach erosion is linked by the islanders to the construction of harbours and sea walls. However, this linkage has not been established conclusively. This activity led by ERC would involve interested local communities
in assessing and monitoring beach
erosion process events and selected
factors contributing to erosion in the North Central Region. These activities would be complemented with a comparative analysis of serial remote sensing
images to provide a better understanding of sources and processes
contributing to
the problem of beach erosion.
The study would contribute to
the development of planning guidelines (e.g., set‐back zones, coastal zoning, use of natural features for harbor development,
jetties for
loading and unloading cargo, etc.), and
indirectly provide inputs to support
increased understanding and quantifying
spatial and temporal variations in
erosion throughout the Maldives and
the causes of erosion.
As data are collected and analyzed,
regional workshops would be held to examine alternatives to current practices that could lead to a reduction in erosion. Coral Reefs:
The project would support community‐based coral reef monitoring supplemented by technical
studies focusing on coral spawning
and recruitment, coral reef
resilience to effects of climate
change and recovery from past
1998 coral reef bleaching event.
Community‐based management plans for the selected reefs would be supported under this activity.
The focus would be on assessing the role of reefs in assuring natural protection against climate risks. This activity will be led by the Marine Research Centre (MRC). Mangroves: Mangroves are an important part of the terrestrial flora of the Maldives. They play a key
role in stabilizing the
soil and as a buffer against
storm surges.
The Environmental Research Center
(ERC) of
the Ministry of Environment, Energy and Water
(MEEW) led a successful effort
in community awareness and mobilization in mangrove management in Huraa Island in Male Atoll. This effort, conducted in collaboration with the Island Development Committee, led to the declaration of the
site as a protected area.
Under this sub‐component,
this model will be replicated in
various islands in the North Central Region. Bait Fishery:
The bait fishery is a critical element of the Maldives tuna fishing industry, the second largest
export industry of the country.
Bait fish are caught in
lagoons and reefs close to
shore. Technical Assistance would be provided to assess the status of the bait fishery, launch a community‐based monitoring program and provide critical inputs into the formulation of a national bait fishery management plan. Spatial
Planning: Currently little weight is
given to environmental factors in
land‐use planning decisions.
The Project would build capacity
(technical and human) in the
relevant ministries and agencies to
promote the integration of
environmental parameters in land use
planning and land allocation decisions.
It would support the purchase of high resolution remote sensing
imagery for the North Central
Region together with the necessary
hardware and software. Training
and
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technical assistance would be
provided to key agencies (Ministry
of Planning and
National Development, ERC, MEEW and MRC among others) to build the necessary expertise. To
support these activities and assure
sustainability and continuity the
Project support
essential equipment required to generate this
information this would
include the purchase of hardware and software for GIS analysis, a research vessel, water quality monitoring equipment and current meters.
III. Environmental Policies, Laws, Regulations, Notifications
and Traditional Rights The following paragraphs
highlight the salient features of
select laws which have a
particularly important bearing on the
design and implementation of the
regional solid
waste management component and the
implementation of the component will
comply with the requirements of
the following: •
National Solid Waste Management Policy •
Technical Minimum Standard (TMS01) for the Operation of Large‐scale Dumpsites •
Law No. 4/93: The Environment Protection and Preservation Act •
Environmental Impact Assessment Regulation, 2007 •
By‐law, Cutting Down, Uprooting, Digging Out and Export of Trees and Palms from one island to
another
•
Law No. 20/98: Uninhabited Island Management Law •
Law No. 5/87: Law on Fisheries •
Traditional rights to land National Solid Waste Management Policy GoM announced a National Solid Waste Management Policy on February 3, 2008.
The Policy has been prepared to reflect the current status of solid waste management
in the Maldives. The policy contains
strategic principles that create the
underlying logical and philosophical
structure of
the policy. They also represent universally accepted practices in waste management:
• Polluter pays principle •
Integrated solid waste management •
Waste management hierarchy •
Best Practical Environmental Option (BPEO) •
Best Available Technology Not Entailing Excessive Costs (BATNEEC) •
Equity • Proximity principle •
Private Sector Participation (PSP)
The overall policy framework for
solid waste management is condensed
into the following
five Principle Objectives:
•
Establishing and activating waste management governance; •
Creating waste producers’ duties and responsibilities; •
Establishing waste management infrastructure; •
Activating the waste management system; and •
Influencing consumer choices and waste management practices.
Under the Principle Objectives are 12 policies and numerous strategies that systematically apply the strategic principles.
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Technical Minimum Standard (TMS01) for the Operation of Large‐scale Landfill This
document has the objective of
establishing a Technical Minimum
Standard (TMS01) for the operation
of present landfills in handling,
recycling and disposal of waste
on a daily basis.
The TMS01 will help prevent potential
impacts to the environment and public health risks through the sound
and environmentally safe management of
waste. In addition, the TMS01
will
encourage private sector participation by widening opportunities for recycling. Law No. 4/93: The Environment Protection and Preservation Act The Environmental Protection and Preservation Act of the Maldives is concerned with the protection of
the natural environment and resources
including land, water, flora, fauna,
beaches and
reefs. Islands with special ecological characteristics have been
identified, protected and conserved as no‐take zones under this Act. The
Act makes reference to prohibited
waste activities like disposing of
wastes in the marine environment,
disposing of hazardous, toxic or
radioactive waste in the
territorial waters of
the Maldives, and trans‐boundary movement of such wastes elsewhere. Environmental Impact Assessment Regulation, 2007 The
Law No. 4/93 on Environmental
Protection and Preservation stipulates
under Article 5,
any development work or project should have an Environmental Impact Assessment consented to by the Ministry of Environment, Energy and Water. The regional solid waste management component will therefore
undertake EIAs for the regional
waste management facility and Initial
Environmental Examinations (IEE) for the Island waste management centers.
An Environment
Impact Assessment must be conducted
to consider
the effects of a development proposal for the following factors:
•
Fauna and flora, and living components of the environment; •
Soil, water, air, climate, the landscape, and the non living components of the environment; •
Material assets and cultural heritage; •
Impacts on the project from the environment; and •
Impact of human interactions with the project and the environment.
This regulation also deals with the selection of sites or islands for economic and social development by relevant authorities. By‐law ‐ Cutting Down, Uprooting, Digging Out and Export of Trees and Palms from one island to another Pursuant
to the Environmental Protection and
Preservation Act of the Maldives,
the Ministry
of Environment, Energy and Water has developed this by‐law in order to educate and guide developers about acceptable practices for the management of trees and palms.
The by‐law prohibits the cutting down, uprooting, digging out and export of trees and palms
from one island to another unless there is no other viable alternative. It also requires that for every tree or
palm removed at least 2 should
be replanted on the same
island. The by‐law also
provides particular protection to the following:
•
coastal vegetation extending 15 metres into the island; •
all trees and palms growing in mangrove and wetland areas; •
all trees and palms growing in Government protected areas; and •
trees and palms that are abnormal in structure.
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Law No. 20/98: Uninhabited Management Law By law, all reefs and their associated habitats are owned by the state. Under this law uninhabited islands are leased out by the government to private individuals or companies. All uninhabited islands and the management of their resources are legally mandated to the Ministry of
Fisheries, Agriculture and Marine
Resources (MFAMR). The Ministry keeps
records of all uninhabited islands
along with details of their
lessees. The Ministry also keeps
known
records of ecological characteristics and
land cover on such
islands. Contracts are drawn up between
lessees and are monitored and maintained by the MFAMR. It includes a condition that two trees must be planted to replace every coconut palm or timber tree felled. A timber permit from MFAMR is required for cutting trees on uninhabited islands. Law No. 5/87: Law on Fisheries Coral reef and coastal marine resources are managed by the MFAMR and regulations for the management of reef resources. All types of fisheries and marine activities are permitted and regulated by the MFAMR under this law. Landuse Planning and Management Land
management on inhabited islands
(apart from the capital
island, Malé) comes under
the purview of
the Ministry of Atolls Development
(MoAD). Land‐use planning of inhabited
islands is guided by
the Ministry of Planning and National Development and Ministry of Housing and Urban Development. Land allocations and registrations are
finalized by the MoAD with consultations and necessary approvals from both the MPND and the MHUD and sometimes also from
line ministries. There are no
traditional governance structures in
the Maldives for coastal land and
resource use. Local island and atoll offices play a major role, however, in the planning stages of land allocation and management
on their respective islands. Locally
formed and selected Island
Development Committees and Atoll Development Committees play a critical advisory role in land management on inhabited islands. Registered plots of
land for housing can be obtained
free by any citizen, on demand, on
formally inhabited
islands where government infrastructure
is established. No fees of any sort are
levied on land plots allocated
for housing purposes. Technically, any citizen over
the age of 18 can obtain a plot of land freely in the Maldives for housing purposes. Plots
of land on inhabited islands
are leased for industrial activities
from which the government earns
rent. An exception is the
recently formed state‐owned enterprise
which has
acquired reclaimed land for commercial property development. Traditional Rights to Land A
large proportion of uninhabited
islands are managed under a
traditional system called Varuvaa. Under
the Varuvaa system land is
leased out to individuals not
to undertake major
economic activities, but
to obtain benefits from the
island in terms of the coconuts
they generate from
the islands. However, lessees undertake
annual crop cultivation on
islands where cleared
agricultural land is available. The rents of Varuvaa islands are fixed by the number of mature coconut palms on the island. It should be emphasized that some of these islands may not even have any coconut palms and as such may not generate any effective income.
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The land tenure systems on inhabited islands are complex. Homestead plots are given free of charge. Plot sizes depend on the availability of
land, with an average size of 50 x 100 feet. Trees grown on homestead plots belong to the owner and the homestead allotment is inheritable. Goi land refers to a particular area of the
inhabited
island with special vegetative characteristics. Coconut palms and tree species grown on goi land belong to the government. Goi land is rented to the highest bidder by the Ministry of Atolls Development. The lessee rents smaller plots for farming. In general, the lessee gets 12.5 percent of
the income generated by farmers.
Faalabba is a land
area generally
located close to residential areas. Islanders grow coconut palms and tree species with the permission of the Island Office. Half of the trees grown belong to the person who planted them and the other half
is the property of the state. Most
islands have communal
land for the cultivation of annual crops. No rent
is charged for cultivation on this
land and no standard
regulation exists for
its use. On some islands plots change hand every year, whereas on other islands farmers can hold the plots as long as they
continue cultivation. The complexity of
land tenure systems on inhabited
islands has
serious implications for the development of agriculture.
IV. Environmental Review Capacity of the Ministry of Energy,
Environment and Water (MEEW) and adequacy of the Environmental
Clearance Process
Under Law No. 4/93 Environmental Preservation and Protection Act,
the Ministry of Environment, Energy and Water (MEEW) has the responsibility
for enforcing EIA regulations, specified under the Environmental
Impact Assessment Regulations.
The Maldives has a reasonably good experience of implementing the Environmental Impact Assessment process. The Act, as stipulated under Article 5, requires
EIAs for
any development work or project which has
to be approved by
the Ministry of Environment, Energy and Water.
MEEW has delegated this
function to the Environment Research Center (ERC). ERC invites two independent reviewers who are considered experts in the field of the relevant project to submit comments on the quality of the EIA, including the level of environmental analysis undertaken to identify the environmental impacts and concerns of the proposed project and the adequacy of the mitigation measures proposed. The review comments form the basis of the EIA evaluation
by ERC and consent is granted
with conditions. While technical
capacity at ERC
is reasonably good, the proposed project will provide training to
improve this capability further.
The EIA review process appears
to be adequate at this
stage because independent
reviewers used
to review the EIA has the required technical expertise
to evaluate the EIA satisfactorily.
ERC has the responsibility of monitoring
implementation of the EIA clearance conditions.
Although monitoring EIA clearance conditions could be
further strengthened, the Project will
support two
independent environmental audits in year 2 of operation of the regional waste management facility and at project closure.
In addition, clearance of all EIA,
IEE/EMPs by the World Bank
is a disbursement condition for the respective activities. In order to ensure transparency in the EIA process, the ERC website has all EIAs and the status of evaluation of the EIA at any given time.
The EIA clearance conditions are also
placed in the website so that
civil society can be aware of
the environmental and
social mitigation measure that are required to be in place during project construction and implementation.
V. World Bank Environmental and Social Safeguard Policies and
its Relevance to the Maldives Environmental Management Project, and
Compliance with Applicable World Bank Policies, Guidelines and
Procedures The World Bank Operational
Policies that may require
consideration under this Project are
as follows:
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15
• OP/BP/GP 4.01 Environmental Assessment •
OP/BP/GP 4.36 Forestry •
OP/BP/GP 4.04 Natural Habitats •
OP 4.07 Water Resource Management •
OD 4.30 Involuntary Resettlement •
OP/BP 4.37 Safety of Dams •
OP 4.09 Pest Management
The World Bank Performance
Standards that may require
consideration under
this Project are as follows:
•
Performance Standard 1: Social and Environmental Assessment and Management System •
Performance Standard 2: Labor and Working Conditions •
Performance Standard 3: Pollution Prevention and Abatement •
Performance Standard 4: Community Health, Safety and Security •
Performance Standard 5: Land Acquisition and Involuntary Resettlement •
Performance Standard 6: Biodiversity
Conservation and Sustainable Natural
Resource
Management •
Performance Standard 7: Indigenous Peoples •
Performance Standard 8: Cultural Heritage
The World Bank Environmental Health and Safety
(EHS) Guidelines that may
require consideration under this Project are as follows:
• Environmental •
Occupational Health and Safety •
Community Health and Safety •
Construction and Decommissioning •
Infrastructure
Having considered the applicability of the above policies, performance standards and guidelines,
it has been concluded that the
operational policies require to be
triggered under this Project
are OP/BP/GP 4.01 ‐Environmental
Assessment and OP/BP/GP 4.04 ‐
Natural Habitats. The Performance
Standards triggered under this
Project are Performance Standard 1:
Social
and Environmental Assessment and Management System and Performance and Standard 3: Pollution Prevention and Abatement. The Environmental Health and Safety
(EHS) Guideline triggered under this Project is Industry Sector: Waste Management Facilities. Relevance of OP/BP/GP 4.01 on Environmental Assessment and OP/BP/GP 4.04 on Natural Habitats to the Project The
purpose of an environmental
assessment (EA) is to identify
environmental and
social consequences of proposed project or subproject components, in order to:
• Ensure the
identification of potential environmental
issues and social concerns early
in the implementation of a proposed project to incorporate necessary safeguards in project design, and determine appropriate mitigation and compensation measures;
•
Minimize risks to the project proponent; •
Avoid delays and extra costs
which may subsequently arise due
to unanticipated
environmental and social problems; •
Ensure that the concerns of residents and affected communities are addressed; and •
Identify the potential for maximizing
environmental resource management and
socio‐
economic benefits to local communities within the scope of the project.
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The EA should cover physical/chemical, biological, socio‐economic and cultural issues that are likely to
arise during the design, construction
and operational activities at the
Regional
Waste Management Facility (RWMF) and Island Waste Management Centres (IWMC’s). Although activities contained
in the Island Waste Management
Plans that may be financed under
the project
are unlikely to cause any irreversible environmental impacts, they should be subject to screening criteria in order to determine their reference to EA processes. By
reducing the volume of waste that
is currently dumped in the ocean
the Regional Solid Waste Management Component will have
long term beneficial environmental
impacts. There is potential for
impacts on the environment during the construction and operation of the RWMF and
IWMC’s. Any adverse impacts
that may arise from these
activities need to be identified
and
addressed through the EA process. Potentially
the most serious impacts are
likely to occur in the
construction and operation of
the RWMF. Based on past experience in the Maldives, it is not possible to build the RWMF on inhabited islands due
to high population densities,
coupled with community opposition.
The only available alternative
is to construct the RWMF on uninhabited
islands or in
islands with compatible
land use such as industrial
island..
Considering the nature, magnitude and scale of potential environmental impacts
of the regional
solid waste management component,
the World Bank has classified
the proposed operations as Safeguards category ‘A’. The development of a waste management facility is a
Schedule D activity under the
Maldives Environmental Impact Regulations,
2007 and
will, therefore, require a Full Environmental Impact Assessment. It
is unlikely that there will be uninhabited
islands with adequate
land area to construct a regional solid
waste landfill for waste disposal
for a 20‐year period.
Reclamation of a shallow
lagoon surrounding the island is
a possible option for expanding
the land area in the selected
island. Considering the
fragile ecosystems in the Maldives,
this could result in
loss of some areas of coral reef, with potentially irreversible impacts of the marine ecosystem. Considering the environmental damage and the cost incurred for reclamation, there is no likelihood that the project will support this option. In order to minimize the adverse impacts on the coral reef system in an uninhabited island, site selection is critical. Priority would be given to the condition of the reef surrounding the island. Every
attempt would be made to select
a degraded reef ecosystem, preferably
beyond rehabilitation, where the impacts of excavation for a navigation channel for accessing the island will be less significant. An
alternative to this may be to
incorporate incineration or waste
to energy as a
regional waste management option into the project. A landfill component for ash disposal would still be required and although impacts on habitat may be significantly reduced, although release of contaminants into the atmosphere will increase significantly. Although the waste stream is approximately 70% organic, it has been observed that not all organic matter is easily degradable. Woody vegetation comprises a large
fraction of the organic waste
stream and is probably combustible.
Separation of
the degradable organics for composting at the island level will reduce the moisture content and increase the
calorific value of the
residue, making incineration or waste
to energy possibly a viable option worth considering. Adverse environmental impacts arising from the construction and operation at IWMC’s are not likely to
be significant. Approximately 100
IWMC’s have been constructed across
the Maldives under previous projects
and none have progressed beyond
an Initial Environment Examination
level decision. Generic Environmental and Social Action Plans
(Environmental Management Plans) have
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17
been developed for siting,
constructing and operating IWMC’s
[Annex 1]. Standard site
selection procedures [Annex 2], designs and specifications [Annex 3] and
island waste management planning manual [Annex 4] have been developed to support the Action Plan or EMPs. It
is possible that OP/BP 4.04,
Natural Habitats may be triggered
depending on the final
site selection,
facility design, and the specific activities that would be carried out at the
facility. During the operation
phase, poor design or
improper management could result in
leakage of wastes or leachate
into the
immediate habitat. World Bank OP 4.04 on Natural Habitats states that the Bank does not support projects that,
in the Bank’s opinion,
involve significant conversion or degradation of critical natural habitats. Compliance with OP/BP/GP 4.01 Environmental Assessment – Principle Project Components Environmental Assessments will be
conducted under provisions of
the Government of Maldives’s Environmental
Impact Regulations, 2007 and in
accordance with
the World Bank’s OP/BP 4.01
to identify and mitigate potential
adverse environmental impacts arising
from the construction and operation
of the RWMF and IWMC’s.
The Terms of Reference (TOR)
for the
environmental assessments will be cleared by the World Bank. For the IWMC’s, in order to comply with the World Bank’s OP/BP/GP 4.01, it is proposed to carry out investigations at the level of an environmental analysis, based on a scoping exercise that will identify significant potential
impacts and
record any pertinent baseline data.
The environmental analysis will cover ecological, archaeological, water quality, visual and noise amenity, air quality and social considerations.
The form of the scoping
exercise shall be compatible with
the Generic Terms
of Reference for the Preparation of an Environmental Impact Assessment (EIA) prepared in accordance with the provisions of the Environmental Impact Regulations, 2007 [Annex 5].
For the RWMF, in order to comply with the World Bank’s OP/BP/GP 4.01, it is proposed to carry out the EIA in two sequential stages. At the Pre‐feasibility Study phase, investigations at the level of an environmental
scoping of shortlisted islands
identified with inputs from the
Regional
Strategic Environmental Assessment process. The scoping exercise will
identify significant potential
impacts and record any pertinent baseline data, but does not involve an assessment of the data and impact at this time.
The environmental analysis will cover ecological, archaeological, water quality, visual and noise amenity, air quality and social considerations. The environmental scoping of shortlisted islands will provide inputs into the Best Practicable Environment Option (BPEO) process. The results of the environmental scoping analysis will be reported at the pre‐feasibility reporting stage and will inform the Final EIA Terms of Reference.
The full feasibility study will be undertaken when: (i) through the BEPO process and has selected the preferred BPEO option, and
(ii) the
final site selection process has been undertaken which will be informed by the preferred waste management system selection. The full EIA will
involve predictive analysis of impacts resulting from the selection of the preferred technology at the preferred site. The Terms of Reference for the final EIA, and the Final EIA will be subject to World Bank safeguards unit review and clearance. Compliance with OP/BP/GP 4.01 Environmental Assessment – Activities undertaken at the IWMCs As
specific activities to be undertaken
at the IWMCs are yet to
be identified, activity
specific environmental issues cannot
be identified at this stage. In
such circumstances, OP/BP/GP
4.01 requires that arrangements
be made whereby the project
implementing agency undertakes the
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18
functions of activity screening,
Environmental Assessment, review and
implementation of
Action Plans or EMPs, as determined appropriate. All activities
included in the
island waste management plans will be the subject of an environment and/or social review as the key management tool for identifying and assessing risk of environmental and social impacts. An outcome of the above environmental and/or social reviews will in most cases be an Action Plan or EMP that is activity specific. While most activities are expected to have generic environmental and/or social impacts that are manageable through environmental management and impact
mitigation measures, there may be
some activities that may carry
a higher risk
of environmental and social impacts. Screening processes
for activities identified in the
IWM Plans will be undertaken with reference to Checklist for Screening of Environmental and Social Impacts of IWM Plan activities [Annex 6].
The screening process is the first step in the EA process. The objective of the screening process is to rapidly
identify those
IWM Plan activities which have
little or no environmental or social
issues so that they can move to implementation. Most of the proposed activities are likely to focus on island based waste management activities
including, but not
limited to, primary waste collection services, island waste management center operation, waste
transfer activities, composting, metal
recovery, septic sludge removal etc. Although most such sub‐components are unlikely to cause any significant environmental
impacts, the screening criteria will
determine which activities will require
further consideration under the provisions of the Maldives Environmental Impact Regulations, 2007 and the World Bank’s OP/BP 4.01. The
Relevance of Performance Standard 1:
Social and Environmental Assessment
and Management System and Performance Performance
Standard 1 underscores the importance
of managing social and
environmental performance throughout the project
life cycle. An effective social and environmental management system is a dynamic, continuous process initiated by project and involving communication between the project
implementation agency and the local
communities directly affected by
the project. A good management
system appropriate to the size
and nature of a project
promotes sound and sustainable
social and environmental performance, and can
lead to improved financial,
social and environmental project outcomes. Compliance
with Performance Standard 1: Social
and Environmental Assessment
and Management System and Performance Taking into account the relevant findings of the Social and Environmental Assessment and the result of
consultation with affected communities,
the
implementing agency will establish and manage a program
of mitigation and performance
improvement measures and actions that
address
the identified social and environmental risks and impacts (the environmental management plan). The EMP program will address the following components:
• Summary of Impacts •
Description of Mitigation Measures •
Description of Monitoring Programs •
Institutional Arrangements •
Implementation Schedule and Reporting Procedures •
Cost estimates and sources of funds •
Community Engagement and Consultation; •
Disclosure; and
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19
• Grievance mechanism.
For each of these topics the
EMP will (i) define measurable
outcomes such as
performance indicators,
targets, or acceptance criteria,
(ii) estimate resources, (iii) allocate
responsibilities and, (iv) be responsive to changes resulting from unforeseen events, and the results of monitoring. Environmental Management Plan(s) Where
specific mitigation measures and
actions are necessary for the
project to comply with applicable
laws and regulations and to meet the requirements of relevant Performance Standards, an EMP will be prepared. Measures
and actions that address identified
impacts and risks will favor
the avoidance and prevention of
impacts over minimization, mitigation wherever
technically and financially
feasible. Where risks and
impacts cannot be avoided or prevented, mitigation measures and actions will be identified so that the project operates
in compliance with applicable national
laws and regulations etc, and meets the requirements of relevant Performance Standards. Community Engagement and Consultation The Project will be based on a strong participatory approach. The implementing agency will make all reasonable efforts
to consult relevant stakeholders in
the preparation and implementation of
the Project activities. The
consultations will be carried out
in a way which is appropriate
for cultural, gender based and
other differences among stakeholders.
The implementing agency will
initiate these consultations as early as possible, and provide relevant material
in a timely manner prior to consultation. The views and needs of the vulnerable groups will be given due consideration. Prior
to commencing activities under the
regional solid waste management
component a
social assessment will be conducted to understand the social structure and physical layout of communities, patterns of
leadership and relations with
formal and informal
island networks, economic activities, transportation,
current patterns of waste disposal,
willingness to pay for improved
solid waste management, entry points
for community mobilization, and the
kinds of incentives to
which individuals and communities are
likely to respond. It
is proposed that the
Social Assessment will extend beyond the solid waste management component of the overall project and will provide input into
the Regional Strategic Environmental
Assessment. Outputs from the Social
Assessment will provide inputs into the Environmental and Social Assessments and into the other two components of the Maldives Environmental Management Project. The
success of the solid waste
management component depends on
ensuring community involvement from
the early planning stages and
participation in the decision making
process. Community mobilization will be undertaken early in the project to ensure that the community takes the
lead in the participatory planning
process resulting in the development
of Island Waste Management Plans
for each participating island. With
inputs from the Social Assessment
the community mobilization process will
identify those island which will
receive island based waste management
infrastructure and equipment and which
islands can support sub‐project
activities. Community mobilization work plans have been developed [Annex 7]. Specific waste management activities to be undertaken at island level as identified in the IWM Plans will be decided by the communities during project implementation. This in turn will determine the composition
of waste that is delivered to
the RWMF. Community Centered
Development (CCD) procurement procedures
have also been developed which
fully engage the community in
the tendering, bid assessment, contracting, contractor oversight and monitoring of IWMC [Annex 8].
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If affected communities are subject
to risks or adverse impacts from
the project components, the implementing
agency will undertake a process
of consultation in a manner
that provides the affected communities
with opportunities to express their
views on project risks, impacts,
and mitigation measures, and allows the implementing agency the opportunity to consider and respond to them. The
implementing agency will ensure that the affected communities are consulted
in a meaningful way and be allowed
to participate actively in the
consultation process. The
following overarching best practice
principles will apply to
consultations undertaken during project
preparation and implementation:
(i) prior disclosure of
relevant and adequate information,
including draft documents
and plans;
(ii)
begin early in the Social and Environmental Assessment process; (iii)
focus on the social and
environmental risks and adverse
impacts, and the proposed
measures and actions to address these; (iv)
be carried out on an ongoing basis as risks and impacts arise; and (v)
be undertaken in a manner that is inclusive and culturally appropriate.
Community views on the Project will be broadly canvassed during
the Project period.
Community consultation processes will be scaled up during the Participatory Rural Appraisal (PRA), and affected communities will be
identified and consulted during
the EA processes. For communities adversely impacted by
the Project or
its components, consultation will be
iterative and their views will
feed into
the decision‐making process on matters
that directly affect
them. The management program will
identify entry points for iterative
consultation of communities identified
as being
adversely impacted by Project activities. Disclosure Disclosure
of relevant project information will
help affected communities understand
the
risks, impacts and opportunities of
the Project. The
implementing agency will publicly disclose all Social and
Environment Assessment documentation, the
management program and action plan(s)
for public review and comment in appropriate locations in the Project area. The documentation will also be made available on the implementing agencies web site. Newspaper and other media outlets will alert
the community to the availability
of the documentation.
The website will also enable
the community opportunity to provide
comment electronically. Documentation
will also be
made available at IDA’s Public Information Center in accordance with BP 17.50 requirements of disclosure. Grievance Mechanism If the implementing agency anticipates ongoing risks to or adverse impacts on affected communities, the implementing agency will establish a grievance mechanism to receive and facilitate resolution of the affected communities’ concerns and about the implementing agency’s environmental and social performance.
The EMP and its management
program will establish a mechanism
to address concerns raised promptly
that is readily accessible to
all segments of the affected
communities, at no cost
and without retribution. Monitoring and Reporting The management program will establish procedures
to monitor and measure
the effectiveness of the EIAs and EMPs conducted under
the project. The
implementing agency will use mechanisms, such
as inspections and audits, where
relevant, to verify compliance and
progress toward the
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21
desired outcomes and will engage
qualified and experienced independent
experts to verify
its performance. The implementing agency will document results of monitoring and mitigation measures, and reflect the necessary corrective and preventive actions
in amended management programs. The client will implement these corrective and preventive actions, and follow up on these actions to ensure their effectiveness. The management program will also schedule periodic reporting to external monitoring and reporting missions that describe progress with
implementation of the Project,
including performance against performance
indicators, targets, or acceptance
criteria, and estimate resources
defined in
the management program. The Relevance of Standard 3: Pollution Prevention and Abatement to the Project Performance
Standard 3 recognizes that increased
industrial activity and urbanization
often generate increased levels of
pollution to air, water, and
land that may threaten people
and the environment at the
local, regional, and global
level. On the other hand,
along with
international trade, pollution prevention
and control technologies
and practices have become more
accessible and achievable in virtually
all parts of the world. This
Performance Standard outlines a
project approach to pollution
prevention and abatement in line
with internationally
disseminated technologies and practices.
In addition, this Performance
Standard promotes the private
sector’s ability to
integrate such technologies and practices as
far as their use
is technically and
financially feasible and cost‐effective in the context of a project that relies on commercially available skills and resources. Compliance with Standard 3: Pollution Prevention and Abatement to the Project During the design, construction, operation of the IWMC’s and RWMF the
implementing agency will consider ambient conditions and apply pollution prevention and control technologies and practices (techniques)
that are best suited to avoid
adverse impacts. Where avoidance is
not feasible the implementing agency
will minimize or reduce adverse
impacts on human health and
the environment while remaining
technically and financially feasible
and cost‐effective. The
project‐specific pollution prevention and control techniques applied will be tailored to the hazards and risks associated with emissions. The
implementing agency will avoid the
release of pollutants or, when
avoidance is not
feasible, minimize or control the intensity or load of their release. The implementing agency will consider Best Practice
Environment Option (BPEO) processes
in determining the appropriate RWMF
control technology. The process will take account of the following principles when making decisions about the most appropriate pollution control mechanism to be applied at the RWMF:
• Integrated waste management; •
Waste hierarchy; • Financial viability; •
Technical feasibility; •
Best Appropriate Technology Not Entailing Excessive Cost; •
Community willingness to accept technology; •
Other local issues such as compatibility with climate change adaptation mechanisms; and •
Acceptable and applicable performance levels and measures.
The Relevance of Industry Sector EHS Guideline: Waste Management Facilities
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These guidelines apply to the design, construction and operation of facilities for the management of hazardous and non‐hazardous wastes, including landfills and incinerators, and take account of World Bank Operational policies. Compliance with Industry Sector EHS Guideline: Waste Management Facilities
During the design, construction, operation of the IWMC’s and the RWMF the
implementing agency will consider the following:
•
the location of sites to minimize potential risks from earthquakes, tidal waves, and floods; •
the certification of building designs used by a struct