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Environmental Assessment Instruments E nvironmental I mpact A ssessment , Environmental Framework, and Environmenta

Environmental Assessment Instruments E nvironmental I mpact A ssessment , Environmental Framework, and Environmental Management Plan. World Bank Safeguard Training Ankara, Turkey March 30 ,2010. Environmental Safeguard Documents ( required for Project Appraisal). Category A:

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Environmental Assessment Instruments E nvironmental I mpact A ssessment , Environmental Framework, and Environmenta

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  1. Environmental Assessment Instruments Environmental Impact Assessment, Environmental Framework, and Environmental Management Plan World Bank Safeguard Training Ankara, Turkey March 30 ,2010

  2. Environmental Safeguard Documents (required for Project Appraisal) • Category A: • Full Environmental Impact Assessment (EIA), or • Strategic Environmental Assessment (SEA) • Category B: • Limited Environmental Assessment (EA), or • Environmental Management Plan, or • Environmental Management Framework, or • Environmental Audit, or • Hazard or Risk Assessment • Category FI: • Environmental Management Framework

  3. 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

  4. CommonProblems with EIAs • No (or poor) Executive Summary • Inadequate information on methodology and data sources • Inadequate or inappropriate baseline information • Inadvertent use of “red flag” phrases (“sensitive habitat”) • No (or inadequate) analysis of feasible alternatives • No (or inadequate) discussion of indirect, cumulative, and transboundary impacts • Unclear what mitigation is required, what is recommended • Issues raised in EIA, not addressed in EMP

  5. 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

  6. Environmental Management Framework: Purposes • Identify, characterize, evaluate potential environmental risks of expected project investments (EA Category; FI with A and/or B) • Identify which SG Policies apply to overall project • Describe/compare applicable national laws/regulations & WB policies – identify gaps and gap-filling measures • Provide clear and practical operational guidance for project implementers (FI, sub-borrowers) • Assign responsibilities for implementation and monitoring of sub-project level EMPs • Serve as the “Environmental Safeguard” document for disclosure/consultation prior to Appraisal, and for Legal Agreement

  7. Environmental 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 • Tranchedsectoral investment programs (incl. SWAPS) • Area development projects (rural, municipal, etc.) • Social Funds • Small Grants Programs

  8. Environmental Management Framework: Contents • Overview of project • Applicable national legislation and WB policies (comparison) • Implementation arrangements • EA procedures and processes • Sub-project descriptions or eligibility criteria (selection, design, contracting, monitoring, evaluation) • Sub-project EA screening process and guidance (Category A, B, or C): criteria, responsibilities, procedures, guidelines for screening social safeguards • EA/EMP preparation guidelines: • EA/EMP templates for each Category (A,B): format, contents, and step-by-step procedures for preparation, disclosure/consultation, approval) • Maybe “generic” EA/E(S)MP for common types of investments (to be tailored to individual sub-projects) • Monitoring and evaluation: general environmental and social compliance monitoring indicators; reporting templates

  9. EMF (project level) Sets out requirements & responsibilities for sub-project-specific EA Disclosure and in-country consultation national level Preparation, consultation and disclosure prior to Project Appraisal PROJECT Sub-project Sub-project Sub-project Sub-project-specific EIA, EA or EMP Sets out environmental issues and mitigations and monitoring for subproject EA disclosure and consultation at local level(2 for Category A sub-projects) Prepared during project implementation

  10. Key Actors: Financial Intermediary (FI) • Preparation, In-country disclosure & consultation on EMF & RPF • Prepare Operational Manual; integrate EMF into it • Sub-project EA screening (together with sub-borrowers • Identify EA instruments required • Review sub-project applications for compliance with national and WB requirements • Monitor subproject compliance with environmental mitigation and monitoring plans • Maintain records, files and documents for all subprojects • Report to the Government & Bank on EMF non-compliance

  11. Key actors: Sub-borrower • Submit subproject concept to FI • Preparation, disclosure and consultation on sub-project EA/EMP, and RAP • Submit EA/EMP, RAP to FI for review • Obtain required permits/licenses • Obtain clearance from local/regional environmental authorities • Implement sub-project EMP, including supervision of contractors • Report to FI on EMP non-compliance

  12. Key actors: Government Agencies • Review and clear sub-projects EAs according to national/local regulatory requirements • Issue permits and licenses • Environmental monitoring and inspections

  13. Key actors: World Bank • At Appraisal evaluates: • Adequacy of relevant national EA requirements; gap-filling • Adequacy of proposed EA procedures for sub-projects • Capacity of FI and others responsible • Arrangements and capacity to implement EMF, and measures in project to strengthen as needed • During Implementation: • Prior review/NOB of Category A (sometimes also Category B) sub-project EIAs • Spot-checking of EMF & sub-project EMP implementation, including site visits EMF FI assessment

  14. EnvironmentalManagementFramework:KEY FEATURES • Used when specific investments CANNOT be identified prior toAppraisal (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 outin OP 4.12)

  15. Common Environmental Framework • EF not recognized in national legislation, no national mechanism to approve • Differences between national and WB EA screening criteria, environmental standards • FI lacks capacity for EA screening, environmental monitoring • EF developed specifically for WB-financed project; Implementing Ministry adopts without formal approval • More stringent criteria apply (may require “double” screening) • Capacity building within project and/or outsourcing (limit direct WB involvement to high risk subprojects); Category A sub-projects excluded ISSUES SOLUTIONS

  16. 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)

  17. 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

  18. 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 associated estimated costs

  19. 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

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

  21. Common Problems of EMPs • 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

  22. EMP Checklist: Eligibility Criteria • Category “low B” Project • Environmental issues known and limited to small scale construction/rehabilitation works(Checklist EMP can be applied to one project component, with regular EMP or EA applied to others) • 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

  23. EMP Checklist: Structure and Function

  24. 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

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

  26. EMP Checklist: How it works

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

  28. EMP Checklist: How it works

  29. EMP Checklist: Example Part D Monitoring Measures

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