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“Drilling Down”: Understanding Environmental Management (Mitigation and Monitoring) Plans and Estimated Costs. Safeguard Training Workshop Zagreb, Croatia May 6, 2009 Ruxandra Floroiu (Environmental Engineer). The Role of EMPs.

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“Drilling Down”: Understanding Environmental Management (Mitigation and Monitoring) Plans and Estimated Costs

Safeguard Training Workshop

Zagreb, Croatia

May 6, 2009

Ruxandra Floroiu (Environmental Engineer)


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The Role of EMPs (Mitigation and Monitoring) Plans and Estimated Costs

  • 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)


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OP/BP 4.01 - related to EMPs (Mitigation and Monitoring) Plans and Estimated Costs

  • 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)


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Who prepares the EMP? (Mitigation and Monitoring) Plans and Estimated Costs

  • EMP (freestanding or as part of the EA) is 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


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According to OP 4.01 a good EMP includes… (Mitigation and Monitoring) Plans and Estimated Costs

  • 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


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The Content of EMPs should… (Mitigation and Monitoring) Plans and Estimated Costs

  • address all relevant environmental (and social) issues identified in the respective EIA report;

  • be comprehensive and 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


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The EMPs Format (Mitigation and Monitoring) Plans and Estimated Costs

  • No established format;

  • Typical introductory text part followed by tables 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


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Mitigation Plan (Mitigation and Monitoring) Plans and Estimated Costs

  • 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


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Mitigation Plan cont. (Mitigation and Monitoring) Plans and Estimated Costs

  • 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


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Environmental Mitigation Plan (Mitigation and Monitoring) Plans and Estimated Costs


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Example (Mitigation and Monitoring) Plans and Estimated Costs: Environmental Mitigation Plan

For a Power Plant Construction Project in X-land

Construction Phase


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Example: Environmental Mitigation Plan (Mitigation and Monitoring) Plans and Estimated Costs

For a Power Plant Construction Project in X-land

Operation Phase


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Monitoring Plan (Mitigation and Monitoring) Plans and Estimated Costs

  • 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


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Environmental Monitoring Plan (Mitigation and Monitoring) Plans and Estimated Costs


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Example: Environmental Monitoring Plan (Mitigation and Monitoring) Plans and Estimated Costs

For a Power Plant Construction Project in X-land

Construction Phase


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Example: Environmental Monitoring Plan (Mitigation and Monitoring) Plans and Estimated Costs

For a Power Plant Construction Project in X-land

Operation Phase


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EMP Institutional Arrangements (Mitigation and Monitoring) Plans and Estimated Costs

  • How the overall environmental management system works during the project implementation (construction and operation phases) and Who is responsibleto 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


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EMP Institutional Strengthening (Mitigation and Monitoring) Plans and Estimated Costs

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


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Public Role in EMP Monitoring – example of good practice: (Mitigation and Monitoring) Plans and Estimated CostsYiba Highway Project (Hubei Province, ChinA): SMS messaging

  • SMS messaging based Safeguards Compliance Monitoring System (SCMS): (example of beneficiary participation in project monitoring):

    • Provides environment and resettlement information to public (one can download EMP, RAP, safeguard booklets)

    • Records 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)

    • Provides a mechanism for complaints to be automatically forwarded to appropriate parties

    • Serves to collect project data for ISR and ICRs in real time


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SMS Messaging for EMP Monitoring (Mitigation and Monitoring) Plans and Estimated Costs


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Role of EMP Supervision (Mitigation and Monitoring) Plans and Estimated Costs

  • 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


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Issues related to EMP Supervision (Mitigation and Monitoring) Plans and Estimated Costs

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


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Solutions to adequate EMP Supervision (Mitigation and Monitoring) Plans and Estimated Costs

  • Assignment of a dedicated Environment Specialists to PIU is good practice;

  • Use of Environmental Specialists in Bank teams in the project cycle as early 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 updating of mitigation measures, institutional assignments, etc. as required


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Integration of WB EA requirements with Typical ECA national procedures

World Bank

NATIONAL LEGISLATION

Identification/

Preparation

Pre/Feasibility Study

Preliminary EIA

incl. mitigation measures

EA/EMP

Appraisal

Detail Design

Bidding Docs

Final EIA

Env. Permit

(Monitoring)

Construction Permit

Implementation


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