1. Gulana Hajiyeva WB Safeguards Training Workshop Almaty, December 2012

2. Environmental Assessment a process a document/report an input to decision making an input to decision making OP 4.01 - OP 4.01 - 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.  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.  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.  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.  Well written Executive Summary  Adequate assessment of project area of influence  Comprehensive and duly updated baseline information  Complete analysis of feasible alternatives  Detailed discussion of indirect, cumulative, and transboundary impacts assessment  Ensuring proper consultation process and public participation/disclosure of EA  Realistic assessment of, and support for Borrower’s capacity in the area of EM and EA  Proper coordination between the project design and EIA and EMP recommendations, including update of EIA and EMP when technical changes are required

7.  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

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

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

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

11. Executive (Non- technical) Summary Significant findings and key recommended actions; Residual risks Policy, Legal and Administrative framework Whether 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 What would the Board need to know to evaluate risks? Summarize key acts and conclusions here; explain in main text 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 Section What it should tell us Keep in mind… Project description Relevant aspects of project context Key elements of project; environmental and social impacts Include off-site investments regardless of financing

12.  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

13. 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

14.  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

15.  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) E(S)MF: KEY FEATURES

16. 1. Brief description of project components including description of type of activities eligible for financing 2. Operating requirements (diagnosis of legal and institutional framework, applicable safeguards) 3. Environmental/social baseline at national/state level 4. ESMF screening procedures (criteria, process, environmental due diligence process, EA/EMP documentation) 5. Implementation arrangements 6. Public consultation and disclosure process/procedures 7. Environmental mitigation measures 8. Monitoring and reporting arrangements 9. Training and capacity building recommendations 10. Various annexes

17. PROJECT (FI) Sub-project ( ) (Development of mineral resources open pit mines Category A) 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-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 Sub-project (Modernization of cement production Plant, Category B) Sub-project () (Poultry waste utilization system, cat. B)

18.  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

19.  Adequate assessment of national EA requirements, identification and filling of gaps  Proposed EA procedures are clear, comprehensive and adequate for envisaged sub-projects  Screening allows for proper categorization of sub- projects, screening criteria are well defined, ineligibility criteria provided  Capacity of FIs and other responsible parties should be realistically assessed, appropriate measure identified to improve capacity as needed  POM contains references to ESMF; environmental sustainability is one of sub-projects proposal evaluation

20. From World Bank sideFrom FI side  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  Incorporating estimated costs of EMP mitigation measures in sub-project cost/budget

21.  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)

22.  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

23.  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 4.01 (not necessary to follow the format)

24.  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

25.  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);

26. ◦ 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

27. ◦ 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

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

29.  EMP specifies all linkages (with RAP/Community and Contractors, regulatory agencies and institutions)  Mitigation measures are specific and detailed  Mitigation and/or monitoring measures are feasible and practical  Proper assessment of institutional capacity, identification of capacity building measures  Monitoring indicators are clear and mainly measurable  Monitoring targets are specific  Proposed mitigation and monitoring measures are duly costed

30. Example: Environmental Mitigation Plan For The Foundry Construction Phase Project ActivityPotential Environmental Impacts Proposed Mitigation MeasuresInstitutional 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” Use of land within the plant construction area, and along the access road 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 “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 2000 Construction worksNoise 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. Contractor/ Plant Operating Company -

31. Project Activity Potential Environmental Impacts Proposed Mitigation MeasuresInstitutional 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 Power plant operator 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 Power plant operator 50,000 Example: Environmental Mitigation Plan For the Foundry Operation Phase

32. Example: Environmental Monitoring Plan For the Foundry Construction Phase WhatWhereHowWhen/By whomCosts 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 sitesVisualWeekly during site preparation and construction period Contractor - Air pollution by dust Dust levelAll active construction sites VisualDuring construction Contractor/ Supervisor Engineer - Noise from construction works Noise level, dB[A]All active construction sites Measurements by a licensed organization using certified measurement devices During construction, Contractor “Estimated standard costs”

33. Example: Environmental Monitoring Plan For the Foundry Operation Phase WhatWhereHow/CostsWhen/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 siteVisual 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

34.  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

35. 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  Conclusion: need a streamlined, practical instrument, which would be standardized, easy to prepare, implement and monitor, specifically tailored to small scale infrastructure

36.  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

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

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

39. 39 EMP Checklist: How it works Subproject Example: Town A

40. 40 EMP Checklist: How it works

41. NOTE: Section A always applies

42. EMP Checklist: How it works

43. 43