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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)

the role of emps
The Role of EMPs
  • 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)
op bp 4 01 related to emps
OP/BP 4.01 - related to EMPs
  • 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)
who prepares the emp
Who prepares the EMP?
  • 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
according to op 4 01 a good emp includes
According to OP 4.01 a good EMP includes…
  • 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
the content of emps should
The Content of EMPs should…
  • 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
the emps format
The EMPs Format
  • 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
mitigation plan
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;
  • Identifies the authorities responsible for mitigation implementation;
  • Includes associated estimated costs
mitigation plan cont
Mitigation Plan cont.
  • 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

Example: Environmental Mitigation Plan

For a Power Plant Construction Project in X-land

Construction Phase


Example: Environmental Mitigation Plan

For a Power Plant Construction Project in X-land

Operation Phase

monitoring plan
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

Example: Environmental Monitoring Plan

For a Power Plant Construction Project in X-land

Construction Phase


Example: Environmental Monitoring Plan

For a Power Plant Construction Project in X-land

Operation Phase

emp institutional arrangements
EMP Institutional Arrangements
  • 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
emp institutional strengthening
EMP Institutional Strengthening

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)


  • 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
Public Role in EMP Monitoring – example of good practice:Yiba 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
role of emp supervision
Role of EMP Supervision
  • 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
issues related to emp supervision
Issues related to EMP Supervision

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
solutions to adequate emp supervision
Solutions to adequate EMP Supervision
  • 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
integration of wb ea requirements with typical eca national procedures
Integration of WB EA requirements with Typical ECA national procedures

World Bank




Pre/Feasibility Study

Preliminary EIA

incl. mitigation measures



Detail Design

Bidding Docs

Final EIA

Env. Permit


Construction Permit