Environmental Management Planning: An integrated, results-oriented process Discussion Material For the Moldova Safeguards Training Workshop October 28-31, 2008 By Victor B. Loksha ECA Safeguards Team Europe and Central Asia Region The World Bank

Environmental Management Plan (EMP) and EIA: How are they related? EIA is analysis of issues and recommendations EIA is documented in an Environmental Assessment Report (EA Report) EMP is an action plan EMP is based on results of EIA

Environmental Management Plan (EMP): What is its Role? Summarize environmental impacts identified in the EA report Identify impacts that must be mitigated Describe mitigation measures Describe monitoring and reporting arrangements Describe assignment of responsibilities and schedules Provide costs estimates for mitigation and monitoring measures

The Bank’s EA Policy (OP 4.01): What does it say about EMPs? Implementation of EMP is an integral part of overall project implementation For Category A projects, EMP is an essential feature of EA (but a separate EA report is still required) For Category B projects, the EA may be limited to EMP (no separate EA report) The requirement of EMP is included in the Loan Agreement EMP is an important part of the project’s Operation Manual The borrower must report on compliance with EMP Specific requirements for EMPs are set out in Annex C of OP 4.01

Project Identification Environmental Impact Assessment Detailed Design Supervision of Construction/Implementation PreparationPlanning/Feasibility Monitoring Operation Environmental Management Plan The Place of EMP Within the Project Cycle: Basic approach according to World Bank, Option 1

Environmental Impact Assessment Supervision of Construction/Implementation Preparation Planning/Feasibility Monitoring Operation The Place of EMP Within the Project Cycle: Basic approach according to World Bank, Option 2 Environmental Management Plan Detailed Design

Preliminary Environmental Impact Assessment Detailed Design Project Identification Preparation Planning/Feasibility Monitoring Supervision of Construction/Implementation Operation EIA and Project Cycle: Standard Practice in Many ECA Countries Final Environmental Impact Assessment Environmental Permit Construction Permit

Preliminary Environmental Impact Assessment Detailed Design Project Identification Preparation Planning/Feasibility Monitoring Supervision of Constr./Implementation Operation Integration of EMP into Standard ECA Practice Environmental Management Plan Bidding Documents Environmental Permit Construction Permit Final Environmental Impact Assessment

One EMP or multiple EMPs? Some projects require several EMPs: –Site-specific EMPs Typical for projects with several components or subprojects on different sites –Impact-specific EMPs, when particular impacts require special attention, e.g.: EMP for hazardous waste management EMP for oil spill prevention and response –Recipient-specific EMPs targeted to particular ecosystems or their elements, e.g.: EMP for protecting fish population from impact of hydro power development To guide preparation of multiple EMPs, Generic or “Framework” EMP is developed first

Who prepares the EMP? EMP is part of the EA done by the borrower The borrower often puts a PIU in charge of tasks such as EMP Consultants assist the borrower/PIU For construction projects, EMP may be developed by: –Design engineering consultant –Construction or EPC contractor EPC contractor = Engineering, Procurement, and Construction contractor

Who prepares the EMP? (cont’d) Who supervises its implementation? For a construction project: –Depending on project structure, design engineering consultant may prepare detailed (site-specific, impact-specific) EMPs –Construction contractors may be asked to develop the EMPs further, even prepare their own EMPs as appropriate –Construction supervising engineer oversees compliance of contractors with EMP(s)

Integration of EMP into Project Design: Let’s See Some Details! Detailed Design / Engineering Bidding Documents Prefeasibility study Feasibility study Preliminary EIA Generic Environmental Management Plan Detailed EMPs: Site-specific / Impact- specific Tasks often assigned to Design Engineering Consultant Core tasks of the Design Engineering Consultant

Integration of EMP into Project Design, cont’d Detailed Design / Engineering Bidding Documents Prefeasibility study Feasibility study Preliminary EIA Generic Environmental Management Plan Detailed EMPs: Site-specific / Impact- specific Required For Appraisal Required for appraisal if details of investments are known What Does the Bank Typically Require to See and When? EA Report

The Bank’s due diligence obligations for EMP Advice for preparation and then No- Objection for the EMP Sometimes No-Objection requirement may be waived: –For low risk activities, and/or –If implementing agency has a good track record Supervision of implementation of EMP

EMP Format There is no established format for EMP Some commonly used formats include: –Tabular –Verbiage/Text –Combination of text and tabular (most common) Self-standing (separate) document vs part of EA report Sometimes can be incorporated in Operational Manual (no separate EMP)

Typical Contents of the Verbal/Introductory Part of an EMP Summary of impacts Description of mitigation measures Description of monitoring program Institutional arrangements, including training Implementation schedule and reporting procedures Cost estimates and sources of funds

Project Activity Potential Environm ental Impacts Proposed Mitigation Measures(s) (incl. Legislation & regulations) Institutional Responsibilities (incl. Enforcement and coordination) Cost Estimates Pre- Construction Phase 1) 2) 3) … Construction Phase 1) 2) 3) … Operation and Maintenance Phase 1) 2) 3) … Environmental Management Plan A. Mitigation

Example: Environmental Management Plan For a Power Plant Construction Project in X-land A.Mitigation: Construction Phase Project ActivityPotential Environmental Impacts Proposed Mitigation MeasuresInstitutional Responsibili ty Costs 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 pay a special fee to the local environmental fund. Contractor/ Plant Operating Company US$ 5000 Use of land within power plant construction area, along gas pipeline route, and along the transmission line route 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. Contractor/ Plant Operating Company US$ 5000 Construction worksAir pollution by dust When necessary, construction site will be sprayed with water, particularly during hot, dry, windy conditions. Contractor/ Plant Operating Company US$ 2000 Construction worksNoise 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. Contractor/ Plant Operating Company -

Project Activity Potential Environmental Impacts Proposed Mitigation MeasuresInstitutional Responsibility Costs 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 Power plant operator S&I contractor $150,000 Example: Environmental Management Plan For a Power Plant Construction Project in X-land A.Mitigation: Operation Phase

Proposed Mitigation Measure Parameters to be Monitored LocationMeasurements (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 Environmental Management Plan B. Monitoring

Example: Environmental Management Plan For a Power Plant Construction Project in X-land B. Monitoring: Construction Phase WhatWhereHowWhen 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 fees to environmental fund Power plant site, pipeline and transmission line routes Visual and by comparison with pre- construction photo survey Monthly throughout construction period Loss of fertile topsoil and soil erosion Soil storage procedures and location Soil storage sitesVisualWeekly during site preparation and construction period Air pollution by dustDust levelAll active construction sites VisualDuring construction Noise from construction works Noise level, dB[A]All active construction sites Measurements by a licensed organization using certified measurement devices During construction

Example: Environmental Management Plan For a Power Plant Construction Project in X-land B. Monitoring: Operation Phase WhatWhereHowWhen 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 Initial test at commissioning and annual subsequently. Continuous for NOx and CO. Air emissions of NOx, SO2, CO, and particulate matter (PM) 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 Once before commissioning of the plant and annually when the plant is in operation 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 Once before commissioning of the plant and annually when the plant is in operation

Follow-up and Supervision of EMP Implementation EMPs should be periodically reviewed, especially when: –Environmental impacts are associated with the operational rather than construction phase (Example: power plant or mining operations); Revisions to EMP may be necessary when: –Final EIA produced after project appraisal renders the original EMP obsolete or irrelevant; Site-specific EMPs produced after project appraisal need to be checked during project supervision

Supervision of EMPs Implementation (enforcement) of EMPs has often been problematic Assignment of a dedicated Environment Specialists to PIU is good practice Monitoring/Reporting Program needs to cover environmental indicators Legal Coverage/Bidding and Contracting Documents Active supervision is needed, including reshaping mitigation measures, institutional assignments, etc.

Concluding Remarks EMPs provide a critical link between the EA report required for Bank’s appraisal and environmental compliance during project implementation/operation Integration of EMP into ECA countries ’ evolving national EIA procedures is an elaborate but essential task Quality of EMP preparation and its integration into project design and operation has a strong impact on the quality of environmental compliance on the ground EMP requirements are legally binding on the construction/installation contractors …, but only when they are in their contract! Supervision of EMP implementation is an integral part of the Bank ’ s project supervision process

Thank You!