1. World Bank Safeguard Workshop Training
Environmental (and Social) Impact Assessment Instruments Environmental Impact Assessment, Strategic Environmental Assessment, Environmental Management Framework, and Environmental Management Plan
World Bank Safeguard Workshop Training
May/June ,2012
Ruxandra Floroiu
Senior Environmental Engineer, ECA Region, World Bank

2. Overview of different type of EA Instruments
a process
Environmental Assessment
a document/report
an input to decision making
OP mainly when/how EA should be done to provide necessary information about likely outcomes
Other OPs - more detailed “how to” and guidance on acceptable versus unacceptable outcomes

3. EA Instruments as per OP 4
EA Instruments as per OP 4.01 (Safeguard Documents for Project Appraisal)
Strategic Environmental (and Social) Assessment WB (as of March 2011); EU & some national laws: for policies, plans and programs; not a substitute for project-specific EA
Regional or sectoral EA: when the project is likely to have sectoral or regional impacts
Environmental Impact Assessment WB -full EIA for Category A projects, narrower scope for Category B ( “limited EA”); National laws - contents specified in law/provision; Some countries - “Preliminary EA” to determine whether further EIA is required; Cumulative Impact Assessment (within EIA or supplementary document)
Environmental Audit for ongoing activities

4. EA Instruments as per OP 4.01
Hazard/Risk Assessment When environmental/social risks are uncertain/not predictable (e.g. possible dam breakage, toxic spill); Complement to EA or Audit
Environmental and Social Management Framework: WB (as of March 2011) for project consisting of a program and/or series of sub-projects…impacts cannot be determined until the details have been identified; (FI and other); Not present in national laws
Environmental Management Plan: element of EA, or free-standing if no EA required; Checklist EMP“ option
Related documents but different:
Country Environmental Analysis/Country Social Analysis (Poverty and Social Impact Analysis)
Safeguard Diagnostic Review (for Use of Country Systems Pilot: “Equivalence Analysis” and “Acceptability Assessment”

5. ENVIRONMENTAL (IMPACT) ASSESSMENT
Identifies and assesses potential risks and benefits based on proposed activities, relevant site features, consideration of natural/human environment, social & transboundary issues
Compares environmental pros and cons of feasible alternatives
Recommends measures to eliminate, offset, or reduce adverse environmental impacts to acceptable levels (sitting, design, technology offsets)
Proposes monitoring indicators to implement mitigation measures
Describes institutional framework for environmental management and proposes relevant capacity building needs

6. E(S)IA – Terms of Reference (ToR) Good TOR + Qualified Personnel = useful and approvable E(S)IA
Clarity on objectives (analysis/conclusions and recommendations, not just data; practical and realistic EMP, etc.)
Clarity on scope and contents (all project activities and associated activities; all project stages; direct & indirect & cumulative impacts; analysis of alternatives; social/environment interface; clear and feasible EMP; etc.). List known issues to be addressed, plus provision for consultant to identify others
Clarity on methodology/level of effort (site visits, formal surveys, modeling, consultations, etc.)
Clarity on deliverables (note value of inception Report)
Provide for sufficient time and resources (for data collection, consultation, document revision, etc.)
Specific expertise required (technical specialties; EIA experience)
Time Frame; budget and/or expected person-months
Scoping step: role of public consultation; involvement of social specialist ;
Line up financing for E(S)IA while preparing ToRs

7. Environmental Assessment Process
Govt. EIA approval vs. WB No Objection:
Sequential process (Govt first or WB first) Parallel process; Iterative process
1. SCOPING/TOR: define project & issues
2. DATA COLLECTION:
Alternatives
Permits, EMP, contractual requirements
Siting
Scale
Design/
technology
Location/baseline (assets & trends; status & processes; env & social)
Project (type, scale,
inputs, outputs) NO
“EIA DECISION”
YES (with conditions)
8. FINALIZATION & SUBMISSION
Operational (good practice)
7. REVISION of draft including public consultation
Prevent, Minimize
Mitigate, Compensate, Monitor
3. POTENTIAL IMPACTS ANALYSIS (significance, likelihood)
4. IDENTIFICATION /EVALUATION OF POSSIBLE MITIGATION MEASURES
5. IDENTIFICATION OF RESIDUAL IMPACTS
6. RECOMMENDATIONS (acceptability;
pre-conditions; mitigation, monitoring)

8. E(S)IA in the Project Cycle
Parallel tracking of safeguards studies and technical design:
Project Identification
Preparation
Implementation
Interests of affected stakeholders
EARF / ESIA / EMP / RPF / RAP
Consultancies for Environmental / Social / Assessments
Due diligence
(mitigation and monitoring) measures ensured during construction & operation
WB policies and international good practice
Consultancies for techno-economic studies and designs
FS, design stages
Objectives of developer, techno-economic requirements

9. Full E(S)IA Report: Required Content (OP 4.01)
Section
What it should tell us
Keep in mind…
Executive
(Non-technical)
Summary
Significant findings and key recommended actions;
Residual risks
What would the Board need to know to evaluate risks?
Summarize key acts and conclusions here; explain in main text
Policy, Legal and Administrative
framework
Where national framework is sufficient to provide desired results and where incremental measures are needed to meet WB requirements
Whether project as proposed will comply with national laws/regulations; Institutional framework for implementation
Do not cut-and –paste the entire body of national laws verbatim Emphasize gaps and how to fill them
Include assessment of institutional structure and capacity for implementation & enforcement
Do not replicate design/FS
Project description
Relevant aspects of project context
Key elements of project; environmental and social impacts
Include off-site investments regardless of financing

10. Common Problems with E(S)IAs
No (or poor) Executive Summary
Inadequate assessment of project are of influence
Inadequate or outdated baseline information
Inadequate analysis of feasible alternatives
Inadequate discussion of indirect, cumulative, and transboundary impacts assessment
Lack of meaningful consultation and public participation/disclosure of EA
Inadequate assessment of and support for Borrower’s capacity in the area of EM and EA
Failure to update the EIA and EMP after project design or when technical changes are required

11. Strategic Environmental Assessment
“Upstream” planning tool (input to sectoral or regional planning process)
Helps identify more vs. less sustainable development pathways
Can be OP 4.01 Instrument for programmatic investment
even if Category A projects are included
special emphasis on cumulative impacts
Must include SUBSTANCE, not just process (not same thing as EMF)
Relatively new instrument; limited guidance, limited capacity and experience

12. Strategic Environmental Assessment
1. SEA Directive 2001/42/EC of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment
Objective:
to provide for a high level of protection of the environment
to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development
by ensuring that
an Environmental Assessment is carried out of certain
plans and programmes which are likely to have significant
effects on the environment

13. Strategic Environmental Assessment
2. SEA Protocol on Espoo Convention UNECE Convention on EIA in a Transboundary Context (July 2010)
Objective:
sets out the obligations of Parties to assess the environmental impact of certain activities at an early stage of planning
It lays down general obligation of States to notify and consult on all major projects that are likely to have a significant adverse environmental impact across boundaries

14. Challenges to prepare high quality SEA
the scale and timing of SEA
the rigid approach to the scoping
the timing of stakeholders engagement
limited awareness of SEA process; thus, need to clarify early the SEA benefits
the capacity and resources for implementation
identification of stakeholders/main champion
environmental data availability and quality
undertaken in parallel with the planning and preparation of a project , program, strategy or plan rather than after

15. Environmental and Social Management Framework: Purpose
Provides guidance to sub-borrowers (sub-project sponsors) and FIs to ensure the EA process is carried out in compliance with national legislation and OP 4.01
Provides an environmental and social screening process to allow for identification, assessment and mitigation of potential impacts by proposed works at the time the detailed aspects are known
Used as a reference document for assessing the potential environmental and social impacts of investment alternatives
Serves as guidelines for the development of sub-project/site-specific Environmental Management Plans (EMPs), Environmental Assessments (EAs), due diligence reports, environmental audits, etc
Is an integral part of the project Operational Manual and applicable to all FIs investments, regardless of its funding source or implementing agency

16. Environmental an Social Management Framework
MAIN OBJECTIVES:
Establish procedures for screening all proposed sub-projects for their potential adverse environmental and social impacts
Specify measures for managing, mitigating and monitoring environmental impacts during project operation
Outline training and capacity-building arrangements needed to implement the EMF provisions

17. Environmental and Social Management Framework: When to use the EMF
When specific investments cannot be identified prior to project Appraisal (un- known subprojects are proposed during project implementation):
Financial Intermediary (FI) operations
Trenched sectoral investment programs (incl. SWAPS)
Area development projects (rural, municipal, etc.)
Social Funds
Small Grants Programs

18. ESMF: KEY FEATURES
Used when specific investments CANNOT be identified prior to Appraisal (FI or other program of sub-projects)
No provision for EMF in OP 4.01 (evolved to formalize Borrower & WB responsibilities for OP 4.01 compliance of subprojects vis a vis screening, EA/EMP preparation & implementation, monitoring, capacity building, Prior Review
Focus on screening criteria, processes, responsibilities
No set format; may or may not include technical content
Can explicitly exclude high risk subprojects
Pelosi Amendment applies if Category A subprojects expected
Category A subproject EIAs are submitted to WB Board
Sometimes Environmental & Social Management Framework – but DOES NOT REPLACE the RPF (unless written to incorporate RPF as set out in OP 4.12)

19. ESMF Procedures: Content
Brief description of project components including description of type of activities eligible for financing
Operating requirements (diagnosis of legal and institutional framework, applicable safeguards)
Environmental/social baseline at national/state level
ESMF screening procedures (criteria, process, environmental due diligence process, EA/EMP documentation)
Implementation arrangements
Public consultation and disclosure process/procedures
Environmental mitigation measures
Monitoring and reporting arrangements
Training and capacity building recommendations
Various annexes

20. PROJECT (FI) ESMF (project level) Prepared by primary Borrower (FI)
Sets out requirements & responsibilities for sub-project-specific EA
Acceptable to WB
Disclosure and one National level consultation on ESMF
Preparation, consultation and disclosure prior to Project Appraisal
Sub-project
(Modernization of cement production
Plant, Category B)
PROJECT (FI)
Sub-project
(Poultry waste utilization system, cat. B)
Sub-project
(Development of mineral resources open pit mines Category A)
Sub-project-specific EA or EMP (sub-project level)
Prepared by sub-borrower/grant recipient (sub-project implementer), during project implementation
EA/EMP disclosure and local level consultation prior to finalizing document
FI responsible for quality/clearance and for monitoring implementation
WB prior review of some Category B

21. ESMF Sub-project Screening, Review, Approval Process
Screening form to be filled out by sub-project proponent
Sub-project name, location (map), type of activity, physical data, environmental information, likely environmental impacts, environmental screening category (A, B or C), mitigation of pollution, environmental studies required (EIA/EMP), public consultation/disclosure required.
Screening Criteria – site-specific environmental risks and impacts; land zoning requirements, environmental license/permit; “negative” list of investments not allowed for financing under the project
Reviewer decides the level of impact to be assessed through EIA (category A or B) or EMP/EMP Checklist (category B)
Subproject approved on the basis of environmental and social review findings (or denied/approved with some changes)
Disclosure/public meeting – function of subproject EA category
assists implementing agencies in screening financed activities for potential impacts and provides guidelines to implement measures once sub-projects have been identified and locations selected

22. ESMF Sub-project Screening, Review, Approval Process
Identification of sub-project
Application preparation and its submission to FI
EA/EMP financing and preparation
Collection of necessary permits/licenses
Obtain clearances from local/regional environmental authorities
Implement the sub-project in line with EMP
Reports to FI on any EMP non-compliance
EA screening for World Bank requirements
Review of sub-project application
Appraisal of sub-project
Monitor environmental compliance based on EMP
Training of sub-project staff
Reports to the Bank on any EMF non-compliance
Maintains records of safeguard documents for all sub-projects
Sub-project proponent Role
Financial Intermediary Role

23. Key Safeguard Actors in ESMF
World Bank
Project
Team and
Safeguard
Specialists
Conduct supervision
Provide safeguard assistance and training
World Bank Safeguard Compliance
Ensure policies are followed
Conduct reviews
Ministry of Environment/
Ministry of Natural Resources of the Russian Federation
Review and clear sub-projects according to national and
local regulatory requirements
Issue environmental permits 5 3

24. Role of WB in ESMF preparation and implementation
WB Appraisal evaluates:
adequacy of relevant national EA requirements; gap-filling
adequacy of proposed EA procedures for sub-projects
capacity of FI and others responsible
measures in project to strengthen EA arrangements/capacity as needed
WB Supervision:
Prior review/NOB of Category A (sometimes also Category B) sub-project EIAs (unless FI assessment indicates this is unnecessary)
Spot-checking of EPF implementation, including site visits
ESMF
FI assessment

25. Subproject Implementation based on ESMF
FI has main responsibility for preparing and monitoring the application and use of ESMF. During sub-project supervision the FI:
Responsible for assessing the capacity of sub-borrowers to comply with EMP and more generally to do proper environmental and social management
Performs sub-project site supervision visits to confirm EMP implementation
Consults local environmental authorities for EMP requirements including current permits
Ensures the sub-borrower carries out required public consultations and does it in proper way including reviewing minutes of those consultations
Verifies with sub-borrower the overall environmental performance of the investment including any critical mitigation measure taken and significant environmental incident
Prepares quarterly/annually reports on results of EMP actions

26. Challenges of ESMF Preparation and Implementation
EMF not recognized in national legislation (no national mechanism to approve it)
Enhancing the capacity of FIs
Good quality EA/EMPs
Differences between national and WB EA screening criteria, environmental standards
Meaningful public consultation and timely public disclosure
Improving environmental screening
Intensifying monitoring
Incorporating estimated costs of EMP mitigation measures in sub-project cost/budget
Timely Progress Reporting on EMP implementation aspects
From World Bank side
From FI side

27. Environmental Management Plans (EMP)
An Action Plan that indicates which of the EA report recommendations and alternatives will actually be adopted and implemented
Part of EIA or freestanding
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)

28. EMP Contents
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
Note: the content of the EMP can be revised during project implementation based on changes in design or based on lessons learned

29. EMP as per OP/BP 4.01 EMPs are an outcome of ESIA process
For Category A projects, EMP is an essential feature of EA report (or a separate 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 (not necessary to follow the format)

30. Who prepares an EMP?
EMP is part of the EA prepared and financed by the Client; In case of FI Projects the EMP should be prepared by the sub-borrower
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

31. EMP 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 ESIA report;
Incorporated in the POM (as chapter, annex or inserted through the POM);

32. Environmental 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
Mitigation measures should be feasible and practical;
Mitigation measures should be easily observed and checked
Identifies the authorities responsible for mitigation implementation
Includes some associated estimated costs

33. Environmental Monitoring Plan
Defines selected indicators for ensuring that mitigation measures are being implemented and are effective (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

34. EMP: Typical Mitigation and Monitoring Tables
Mitigation Plan:
what must be done
Monitoring Plan:
to determine whether measures are implemented & effective

35. Common Problems of EMPs
EMP must specify all linkages (with RAP/Community and Contractors, regulatory agencies and institutions)
Mitigation measures too general, insufficient detail
Mitigation and/or monitoring measures not feasible or not practical
Inadequate institutional capacity, insufficient capacity building measures
Monitoring indicators not measurable
Monitoring targets missing or too general
Lack of cost estimates
Too long and elaborate to be implemented

36. Example: Environmental Mitigation Plan
For The Foundry
Construction Phase
Project Activity
Potential Environmental Impacts
Proposed Mitigation Measures
Institutional Responsibility
Costs
US$
Use of land within the plant construction area, and along the access road 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 (7AM to 7PM). If construction must be conducted before/after these hours, local public will be notified at least one week in advance. -

37. Example: Environmental Mitigation Plan
For the Foundry
Operation Phase
Project Activity
Potential Environmental Impacts
Proposed Mitigation Measures
Institutional Responsibility
Costs
US$
Coal Combustion
Air emissions of NOx, SO2, CO, particulate matter
Low-NOx burners and water injection to control NOx;
Firing only low-sulfur (<0.1% by wt.) coal 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 70 dB(A) at 100 m
S&I Contractor
150,000
All operation phases
Workers Health and Safety
Personnel protective equipment will be used (gloves, glasses, safety belts)
WHS training will be provided to workers monthly
Safety engineer will be assigned to the site
50,000

38. Example: Environmental Monitoring Plan
For the Foundry
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
Plant site, pipeline and access road 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”

39. Example: Environmental Monitoring Plan Potential Environmental Impacts
For the Foundry
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)
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 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
Noise from construction works
Noise level, dB[A]. Applicable limits are 70 dB(A) at 100 m
At 100 meter from the border of the site (closest end to a residential area)
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
Workers Health and Safety
Usage of personnel protective equipment
Records of WHS training
At the site
Visual by checking the practical usage of equipment and checking adequate among of equipment exists.
Records of the trainings will be checked and if necessary improvements will be done
Equipment: daily by safety engineer
Training records: monthly by safety engineer

40. 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 (from the 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

41. Checklist EMP: Rationale
2007 review of SG implementation in health & education sectors indicated:
Most of the projects Category “low B”
Environmental impacts usually related only to small scale construction / building rehabilitation
EMPs existed on paper but were long, complex, impractical – and mostly ignored… in most cases, no environmental site management
Recognition that issues for small scale construction/rehabilitation are fairly standard… no need to continually “re-invent the wheel
Conclusion: need a streamlined, practical instrument, which would be standardized, easy to prepare, implement and monitor, specifically tailored to small scale infrastructure

42. Checklist EMP – Eligibility Criteria
Category “low B” Project
Environmental issues known and limited to small scale construction/rehabilitation works*
Area of impact clearly defined & limited: either within an existing “footprint” or relatively small new areas known not to have major environmental or social issues

43. EMP Checklist: Structure and Function
1: Datasheet
Basic information on project activities
Environmental baseline information
2: Potential impacts list
Grouped according to various themes or impact types
Themes / types to be checked as applicable
3: Mitigation measures list
Each checked item from Section B triggers specific mitigation measures / parameters and specific, concrete activities to be implemented on site
4: Monitoring plan
Focuses on reasonable, meaningful, practical monitoring parameters and activities

44. How EMP Checklist is used
Parts 1 & 2: description of sub-project and identification of potential impacts: for use by screener/approver
Part 3: identifies issues and associated mitigation measures: becomes part of construction contract
Part 4: monitoring/supervision plan to verify effective mitigation: for use by construction site supervisor and PMU

45. EMP Checklist: How it works
Example: Country X Real Estate & Cadastre Project (XRECP)
Introductory information (to be filled in prior to Appraisal):
Project will finance rehabilitation of 15 Cadastre office buildings, all currently in use
(sub-projects)
No new construction or extension of facilities – all works within existing footprint
All buildings located in urban areas on commercial streets with moderate to heavy traffic
Some may be registered historical buildings
Rehabilitation will be interior & exterior including: repair or replacement of roofs & windows, rewiring, removal/replacement of insulation, masonry repairs, replacement of floors, repair/replacement of plumbing, painting
A site-specific Checklist EMP form will be completed for each Sub-project and will be attached to the construction contract

46. EMP Checklist: How it works
Subproject Example: Town A

47. EMP Checklist: How it works

48. EMP Checklist: How it works
NOTE: Section A always applies

49. EMP Checklist: How it works

50. EMP Checklist: Monitoring Measures for selected potential impacts and mitigation measures

51. Exercise:
List the key elements for project description section of EIA for a project to construct a hydropower plant with dam and reservoir
List all environmental impacts that you can identify for the construction and operation of a hydroelectric power plant (HPP)
Group A: Impacts during construction and filling
Group B: Impacts during operation
(Make your own assumptions regarding project location and context)