1. Introduction to Environmental Management Plan (EMP)
Safeguard Training Workshop
Dushanbe, Tajikistan
September 28, 2009
Ruxandra Floroiu (Environmental Engineer)

2. The Role of EMPs
An Action Plan that indicates which of the EA report recommendations and alternatives will actually be adopted and implemented;
The most important link to incorporate environmental factors into the overall project design;
Identifies linkages to other SG policies relating to the project;
Ensures environmental mitigation measures and their practical monitoring become a legal responsibility of the Borrower (LoA)

3. OP/BP related to EMPs
For Category A projects, EMP is an essential feature of EIA (or a separate EIA report is required);
Some Category B projects may require only an EMP (if environmental issues are relatively minor and routine, not site-specific); other Category B projects may require EA reports with “tailor made” mitigation aspects;
The implementation of EMP is included in the LoA;
EMP should be an important part of the POM;
The Borrower must report on compliance with EMP;
Specific requirements for EMPs are set out in Annex C of OP 4.01 (not necessary to follow the format)

4. Who prepares the EMP?
EMP is part of the EA prepared and financed by the Client;
The Client often places an existing PIU in charge of tasks such as EMP, EA, EMFs;
The Client may hire local/international Consultants to assist the PIU in preparing EMP

5. According to OP 4.01 a good EMP includes…
Summary of predicted adverse environmental and social impacts related to project;
Description of mitigation measures and plan;
Description of monitoring activities and plan;
Institutional arrangements including training;
Implementation schedule and reporting procedures;
Estimated related costs and sources of funds

6. The Content of EMPs should…
address all relevant environmental (and social) issues identified in the respective EIA report;
be comprehensive, detailed but easily understood so that:
the Borrower knows exactly what is to be done and who is responsible;
World Bank team knows exactly what to look for during supervision to determine whether implementation is in compliance with the Legal Agreement and OPs

7. The EMPs Format No established format;
Typical introductory text part followed by tabular format of specific mitigation measures (Mitigation Plan) for identified possible environmental impacts and of related monitoring activities (Monitoring Plan);
Self-standing document vs. part of the EIA report;
Incorporated in the POM (as chapter, annex or inserted throughout the POM);
For Category A projects, mitigation measures and their implementation are often described in more detail in the introductory part

8. Mitigation Plan
Defines the key environmental (and social) issues which should be managed;
Describes specific mitigating measures to manage each possible impact, including specific actions to be achieved;
Identifies the authorities responsible for mitigation implementation;
Includes associated estimated costs

9. Mitigation Plan cont.
Identification of appropriate mitigation measures is critical;
Based on the expertise and experience of the consultant preparing the EMP, and on sources such as the Pollution Prevention and Abatement Handbook;
Mitigation measures should be feasible and practical;
Mitigation measures should be easily observed and checked
Bad example: “The construction contractor will assure equipment does not produce excessive noise
Good example: “The construction contractor will assure all equipment maintains noise levels at or below 75dB [A] at 1 meter from the source (in accordance with National Regulation XYZ/123) by utilizing equipment which is designed and maintained to meet this standard

10. Environmental Mitigation Plan
Project Activity
Potential Environmental Impacts
Proposed Mitigation Measures(s)
(including legislation/
regulations)
Institutional Responsibility
(including enforcement/ coordination)
Cost
Estimates
Pre-Construction Phase 1) 2) 3)
Construction
Phase
Operation and
Maintenance

11. Example: Environmental Mitigation Plan
For a Power Plant Construction Project in X-land
Construction Phase
Project Activity
Potential Environmental Impacts
Proposed Mitigation Measures
Institutional Responsibility
Costs
US$
Use of land within power plant construction area, along gas pipeline route, and along the transmission line route
Damage to vegetation
Appropriate clearing techniques (hand clearing, not mechanized clearing) will be utilized. Any trees of protected species will be relocated. In case relocation is not possible, the project developer will agree with the MoEnv on a practical compensation to protect specific trees
Contractor/Plant Operating Company
“5000”
Loss of fertile topsoil and soil erosion
Fertile topsoil will be removed, stored in an isolated area away from construction activities, and covered with plastic to prevent runoff/erosion. Upon construction completion, topsoil will be returned and the area revegetated with plants similar to the original vegetation/native to the area.
Construction works
Air pollution by dust
When necessary, construction site will be sprayed with water, particularly during hot, dry, windy conditions.
2000
Noise from construction works
Construction will be confined to normal work-hours (8AM to 6PM). If construction must be conducted before/after these hours, local public will be notified at least one week in advance. -

12. Example: Environmental Mitigation Plan
For a Power Plant Construction Project in X-land
Operation Phase
Project Activity
Potential Environmental Impacts
Proposed Mitigation Measures
Institutional Responsibility
Costs
US$
Liquid Fuel Combustion
Air emissions of NOx, SO2, CO, particulate matter, and volatile organic compounds (VOCs)
Low-NOx burners and water injection to control NOx;
Firing only low-sulfur (<0.1% by wt.) distillate fuel oil to control SO2;
Good combustion control to control CO, PM and VOCs;
Stack height at least 45 m to facilitate dispersion.
Power plant operator
Power plant supply and installation (S&I) contractor
0.8 million
Equipment Operation
Noise from equipment
Acoustic enclosures for the combustion turbines to ensure that noise does not exceed 80 dB(A) at 1 m
S&I contractor
150,000

13. Monitoring Plan
Defines selected indicators for ensuring that mitigation measures are being implemented in an effective way (e.g., if there is a mitigating measure to control noise during construction, the monitoring plan should include noise measurements during construction);
Ensures the project is complying with National environmental regulatory requirements and WB Safeguard requirements;
Addresses concerns which may rise during the public consultation;
Identifies authorities responsible for monitoring;
Includes estimated related costs

14. Environmental Monitoring Plan
Proposed Mitigation
Measure
Parameters
to be Monitored
Location
Measurements
(incl. Methods & equipment)
Frequency of Measurement
Responsibilities
(incl. review and reporting)
Cost (equipment
& individuals)
Pre-
Construction
Phase
Construction Phase
Operation and Maintenance Phase
Total Cost for all Phases

15. Example: Environmental Monitoring Plan
For a Power Plant Construction Project in X-land
Construction Phase
What
Where
How
When/By whom
Costs US$
Potential Environmental Impacts
parameter is to be monitored?
is the parameter to be monitored?
Damage to vegetation
Clearing techniques and relocation procedures utilized; record of compensation provided as agreed with MoEnv
Power plant site, pipeline and transmission line routes
Visual and by comparison with pre-construction photo survey
Monthly throughout construction period;
Contractor/ Supervisor Engineer -
Loss of fertile topsoil and soil erosion
Soil storage procedures and location
Soil storage sites
Visual
Weekly during site preparation and construction period
Contractor
Air pollution by dust
Dust level
All active construction sites
During construction Contractor/ Supervisor Engineer
Noise from construction works
Noise level, dB[A]
Measurements by a licensed organization using certified measurement devices
During construction,
“Estimated standard costs”

16. Example: Environmental Monitoring Plan Potential Environmental Impacts
For a Power Plant Construction Project in X-land
Operation Phase
What
Where
How/Costs
When/by whom
Potential Environmental Impacts
parameter is to be monitored?
is the parameter to be monitored?
Air emissions of NOx, SO2, CO, and particulate matter (PM)
Emissions of air pollutants: (1) NOx calculated as NO2; (2) SO2; (3) CO; (4) PM. The applicable standards are: (1) NO2 ≤ 400 mg/m3; (2) SO2 ≤ 850 mg/m3; (3) CO ≤ 150 mg/m3; (4) PM ≤ 100 mg/m3
At the stack of the power plant
By continuous monitoring equipment supplied with the power plant; costs are part of the self-monitoring plan for the plant – could be easily estimated
Initial test at commissioning and annual subsequently. Continuous for NOx and CO. Plant management
Ground level concentrations: (1) NOx; (2) SO2; (3) PM. The applicable environmental standards are: (1) NOx: Annual average ≤ 40 μg/m3; Max 24-hour average ≤ 150 μg/m3; Max 30-min average ≤ 500 μg/m3 (2) SO2 Annual average ≤ 40 μg/m3; Max 24-hour average ≤ 150 μg/m3; Max 30-min average ≤ 500 μg/m3 (3) PM Annual average ≤ 50 μg/m3; Max 24-hour average ≤ 125 μg/m3; Max 30-min average ≤ 280 μg/m3
In adjacent residential areas and/or nearest air quality monitoring stations
By buying data from the local air quality monitoring station; national standard costs
Once before commissioning of the plant and annually when the plant is in operation. Plant management
Noise from construction works
Noise level, dB[A]. Applicable limits are 80 dB[A] on-site and 65 dB[A] off-site.
At 1 meter from operating turbines and in nearest residential areas
Measurements by a licensed organization using certified measurement devices; national standard costs
Once before commissioning of the plant and annually when the plant is in operation

17. EMP Institutional Arrangements
How the overall environmental management system works during the project implementation (construction and operation phases) and Who is responsible to implement it;
Who will supervise the implementation of Mitigation Plan;
Who will collect the data (Monitoring Plan);
Who will analyze the data to produce information;
Who will prepare reports (and how often) indicating how recommended actions are being taken,
Who will receive the reports and act upon them (e.g. dismiss contractor, withhold contractor payment, authorize expenditures to correct problems etc) – must have the needed authority

18. EMP Institutional Strengthening
Monitoring equipment to be provided (purchase or rental) as needed to implement the Monitoring Plan
Domestic or imported equipment (specify number of units, type, cost)
Training
For mitigation actions and for monitoring (could be included with equipment purchase)
For general environmental management
Specify details of type of training, number/identity of staff to be trained, duration, location, costs,
Consultant services and/or Special Studies
TORs and costs should be included as annex

19. Public Role in EMP Monitoring - good practice: SMS messaging
SMS messaging based Safeguards Compliance Monitoring System (SCMS)
Provides environment and resettlement information to public (one can download EMP, RAP, safeguard booklets)
Record information on environment and resettlement performance against indicators (e.g., pollution of waterways, damage to sensitive area, compensation rates, how long it takes for people to receive compensation, etc)
Provide a mechanism for complaints to be automatically forwarded to appropriate parties
Serves to collect project data for ISR and ICRs in real time
It's an innovative approach to getting the public involved in monitoring implementation of EMP, developed forthe Yiba Highway Project in Hubei Province, China. This system seeks to ensure the successful implementation of the environmental management plan (EMP) and resettlement action plan (RAP) by informing all project-affected persons of their rights and entitlements, and creating a forum wherein complaints will be received and acted upon in a timely manner.

20. SMS Messaging for EMP Monitoring

21. Role of EMP Supervision
To determine if the Borrower carries out the project in conformity with safeguard policies and legal agreement;
To identify problems as they arise during project implementation and recommend to the Borrower actions/activities to resolve them;
To identify the key risks to project sustainability
To recommend appropriate risk management strategies to Client

22. Issues related to EMP Supervision
Implementation (enforcement) of EMPs has often been problematic…
Unrealistic/inadequate monitoring indicators;
Infrequent site visits by team members;
Inadequate review and evaluation of monitoring aspects and reports;
Failure to revise the EMP in response to project changes during implementation;
Inadequate follow-up on Borrower implementation of agreed actions (from previous mission);
Ineffectiveness of proposed institutional capacity measures

23. Solutions to adequate EMP Supervision
Assignment of a dedicated Environment Specialists to PIU is good practice;
Use of Environmental Specialists in Bank teams in the project cycle as soon as possible;
Monitoring and Reporting Program needs to cover practical environmental indicators;
Bidding and Contracting Documents should include EMP provisions on mitigation/monitoring;
Active supervision is needed, including fresh revision of mitigation measures, institutional assignments, etc.