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Integrating EMP into Operational Manual

Integrating EMP into Operational Manual. Safeguard Training Workshop Zagreb, Croatia May 7, 2009. Ruxandra Floroiu (Environmental Engineer). Project Operation Manual (POM). Reference for all aspects of project implementation: who does what, when and how

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Integrating EMP into Operational Manual

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  1. Integrating EMP into Operational Manual Safeguard Training Workshop Zagreb, Croatia May 7, 2009 Ruxandra Floroiu (Environmental Engineer)

  2. Project Operation Manual (POM) • Reference for all aspects of project implementation: who does what, when and how • Usually prepared after project Appraisal, before Effectiveness • Emphasis on decision-making processes; “fiduciary” aspects (procurement, financial management & accounting, environment); monitoring & reporting • Prepared by Client (consultants), approved by Govt. (higher level); Acceptable to WB • Cited in Legal Agreement, legally binding commitments • Need to specify procedure for amending it

  3. The need of POM • Provides clear, detailed, definitive guidance and procedures for implementing the project – follow the rules & all will be well • Facilitates efficient project monitoring and supervision • Simplifies Legal Agreement (only one reference needed to cover all Client/WB agreements) • Provides continuity in case of staff changes

  4. Typical Contents of POM • Project objectives, description, components • Applicable laws, regulations, rules • Sub-project eligibility criteria (beneficiaries, locations, activities), or “Menu” of eligible projects • Sub-project application, evaluation, selection process • Institutional structures/responsibilities • Disbursement procedures (including for Sub-grants) • Procurement procedures • Financial management & accounting • Monitoring & Reporting (Table of Progress & Impact Indicators) • Annexes: • Work Plan (updated annually) • EMP or Environmental Guidelines • Application & Reporting formats • Terms of Reference (PIU, major consultancies)

  5. Integration of EMP in POM • EMP as a chapter of POM • EMP as an annex to POM • Elements of EMP inserted throughout OM where relevant Recommended - 1 & 3 or 2 & 3

  6. General Description (Small Grants Program) Provides small grants to individuals or groups for enterprise development (sub-projects) Typically based on applications, sometimes competitive Grants typically finance small works (rehabilitation, small-scale construction), equipment, inputs, TA Usually Category B (i.e., Category A sub-projects specifically excluded) Framework EA/EMP covering the whole project sets out procedures for site-specific EA/EMP for sub-projects

  7. Example: Small Grant Programs

  8. Example: Croatia Conservation and Rural Revitalization Program • Program objective: demonstrate linkages between Protected Areas/biodiversity conservation and rural development (economic opportunities from sustainable use; awareness-raising and education) • Grant size: Euro 2,000 – 25,000

  9. Proposals Eligibility Screening Evaluation/selection of proposals Submission of proposals (Assisted) preparation of applications Sub-Project approval Agreement on work plan, contract signing Workshops for Applicants sub-project cycle Program Advertisement First tranche disbursement Final report & accounting Progress report, Accounting, verification Second tranche disbursement

  10. Example – Incorporation of EMP in POM Procedures: Small Grants Programs • Workshop Training - advice to prospective applicants on eligible/ineligible activities, potential environmental issues e; potential impacts and mitigation measures for different types of sub-projects • Grant application: identify potential environmental issues and proposed mitigation measures; • Screening of application: review of eligibility of proposal, excluding any with high environmental risk • Grant evaluation & selection: EA screening, evaluation of env. issues and proposed mitigations; indicate whether specific EA/EMP required • Preparation/signing of Grant contract: Environmental mitigation measures included in Sub-project contract; Includes specific environmental provisions for procurement, contracting • Procurement: includes environmental provisions in bidding documents, specifications, contracts • Grant disbursement/Progress reporting: environmental measures maybe triggers for disbursement; PIU verifies environmental measures implemented and are effective • Monitoring & reporting on Grant Implementation: includes EMP compliance, environmental indicators

  11. Common Problems in Implementing EMP in Small Grants Programs • Insufficient understanding or appreciation of issues on part of applicants; inadequate up-front education and advice • Insufficient use of environmental consultants for screening, EA, monitoring • Inadequate coverage of environmental responsibilities in beneficiary contracts • Inadequate coordination between environmental and procurement specialists in PIU • Monitoring only process and inputs rather than impacts; vague or unclear indicators and targets

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