environmental management planning: an integrated, results-oriented process discussion material for...

Environmental Management Planning:

An integrated, results-oriented process

Discussion MaterialFor the Moldova Safeguards Training Workshop

October 28-31, 2008

By Victor B. LokshaECA Safeguards Team

Europe and Central Asia RegionThe World Bank

Environmental Management Plan (EMP) and EIA: How are they related?

• EIA is analysis of issues and recommendations

• EIA is documented in an Environmental Assessment Report (EA Report)

• EMP is an action plan

• EMP is based on results of EIA

Environmental Management Plan (EMP): What is its Role?

• Summarize environmental impacts identified in the EA report

• Identify impacts that must be mitigated• Describe mitigation measures• Describe monitoring and reporting

arrangements• Describe assignment of responsibilities and

schedules • Provide costs estimates for mitigation and

monitoring measures

The Bank’s EA Policy (OP 4.01): What does it say about EMPs?

• Implementation of EMP is an integral part of overall project implementation

• For Category A projects, EMP is an essential feature of EA (but a separate EA report is still required)

• For Category B projects, the EA may be limited to EMP (no separate EA report)

• The requirement of EMP is included in the Loan Agreement

• EMP is an important part of the project’s Operation Manual

• The borrower must report on compliance with EMP• Specific requirements for EMPs are set out in Annex C

of OP 4.01

Project Identification

Environmental Impact Assessment

Detailed Design

Supervision of Construction/Implementation

Preparation

Planning/Feasibility

Monitoring

Operation

Environmental Management Plan

The Place of EMP Within the Project Cycle: Basic approach according to World Bank , Option 1

Environmental Impact Assessment


Preparation


Monitoring

Operation

The Place of EMP Within the Project Cycle: Basic approach according to World Bank, Option 2


Detailed Design

Preliminary Environmental Impact Assessment

Detailed Design


Preparation


Monitoring


Operation

EIA and Project Cycle: Standard Practice in Many ECA Countries

Final Environmental Impact Assessment

Environmental Permit

Construction Permit

Preliminary Environmental Impact Assessment

Detailed Design


Preparation


MonitoringSupervision of Constr./Implementation

Operation

Integration of EMP into Standard ECA Practice


Bidding Documents

Environmental Permit

Construction Permit

Final Environmental Impact Assessment

One EMP or multiple EMPs?

• Some projects require several EMPs:– Site-specific EMPs

• Typical for projects with several components or subprojects on different sites

– Impact-specific EMPs, when particular impacts require special attention, e.g.:

• EMP for hazardous waste management• EMP for oil spill prevention and response

– Recipient-specific EMPs targeted to particular ecosystems or their elements, e.g.:

• EMP for protecting fish population from impact of hydro power development

• To guide preparation of multiple EMPs, Generic or “Framework” EMP is developed first

Who prepares the EMP?

• EMP is part of the EA done by the borrower

• The borrower often puts a PIU in charge of tasks such as EMP

• Consultants assist the borrower/PIU• For construction projects, EMP may be

developed by:– Design engineering consultant – Construction or EPC contractor

EPC contractor = Engineering, Procurement, and Construction contractor

Who prepares the EMP? (cont’d) Who supervises its implementation?

• For a construction project:– Depending on project structure, design

engineering consultant may prepare detailed (site-specific, impact-specific) EMPs

– Construction contractors may be asked to develop the EMPs further, even prepare their own EMPs as appropriate

– Construction supervising engineer oversees compliance of contractors with EMP(s)

Integration of EMP into Project Design:Let’s See Some Details!

Detailed Design / Engineering

Bidding Documents

Prefeasibility study

Feasibility study

Preliminary EIA

Generic Environmental Management Plan

Detailed EMPs:

Site-specific / Impact-specific

Tasks often assigned to Design Engineering Consultant

Core tasks of the Design Engineering Consultant

Integration of EMP into Project Design, cont’d

Detailed Design / Engineering

Bidding Documents

Prefeasibility study

Feasibility study

Preliminary EIA

Generic Environmental Management Plan

Detailed EMPs:

Site-specific / Impact-specific

Required For Appraisal

Required for appraisal if details of investments are known

What Does the Bank Typically Require to See and When?

EA Report

The Bank’s due diligence obligations for EMP

• Advice for preparation and then No-Objection for the EMP

• Sometimes No-Objection requirement may be waived: – For low risk activities, and/or– If implementing agency has a good track

record

• Supervision of implementation of EMP

EMP Format

• There is no established format for EMP• Some commonly used formats include:

– Tabular – Verbiage/Text– Combination of text and tabular (most common)

• Self-standing (separate) document vs part of EA report

• Sometimes can be incorporated in Operational Manual (no separate EMP)

Typical Contents of the Verbal/Introductory Part of an EMP

• Summary of impacts• Description of mitigation measures• Description of monitoring program• Institutional arrangements, including

training• Implementation schedule and reporting

procedures• Cost estimates and sources of funds

Project Activity

Potential Environm

ental Impacts

Proposed Mitigation

Measures(s)(incl. Legislation

& regulations)

Institutional Responsibilities(incl. Enforcement and coordination)

Cost

Estimates

Pre-Construction

Phase

1)

2)

3)

…

Construction

Phase

1)

2)

3)

…

Operation and

Maintenance

Phase

1)

2)

3)

…

Environmental Management PlanA. Mitigation

Example: Environmental Management PlanFor a Power Plant Construction Project in X-land

A. Mitigation: Construction PhaseProject Activity Potential

Environmental Impacts

Proposed Mitigation Measures Institutional Responsibili

ty

Costs

Use of land within power plant construction area, along gas pipeline route,

and along the transmission line 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 pay a special fee to the local environmental fund.

Contractor/Plant Operating Company

US$ 5000

Use of land within power plant construction area, along gas pipeline route,

and along the transmission line 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.


US$ 5000

Construction works Air pollution by dust

When necessary, construction site will be sprayed with water, particularly during hot, dry, windy conditions.


US$ 2000

Construction works Noise from construction

works

Construction will be confined to normal work-hours (8AM to 6PM). If construction must be conducted before/after these hours, local public will be notified at least one week in advance.


-

Project Activity

Potential Environmental

Impacts

Proposed Mitigation Measures Institutional Responsibility

Costs

Liquid Fuel Combustion

Air emissions of NOx, SO2, CO, particulate matter, and volatile organic compounds (VOCs)

•Low-NOx burners and water injection to control NOx;•Firing only low-sulfur (<0.1% by wt.) distillate fuel oil 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 80 dB(A) at 1 m

•Power plant operator•S&I contractor

$150,000


A. Mitigation: Operation Phase

Proposed Mitigation

Measure

Parameters

to be Monitored

Location Measurements

(incl. Methods & equipment)

Frequency of Measurement

Responsibilities

(incl. review and reporting)

Cost (equipment

& individuals)

Pre-

Construction

Phase

Construction Phase

Operation and

Maintenance Phase

Total Cost for all Phases


B. Monitoring


B. Monitoring: Construction Phase

What Where How When


Impacts

parameter is to be monitored?

is the parameter to be monitored?



Damage to vegetation

Clearing techniques and relocation procedures utilized; record of fees to environmental fund

Power plant site, pipeline and transmission line routes

Visual and by comparison with pre-construction photo survey

Monthly throughout construction period

Loss of fertile topsoil and soil erosion

Soil storage procedures and location

Soil storage sites Visual Weekly during site preparation and construction period

Air pollution by dust

Dust level All active construction sites

Visual During construction

Noise from construction works

Noise level, dB[A] All active construction sites

Measurements by a licensed organization using certified measurement devices

During construction


B. Monitoring: Operation Phase

What Where How When


Impacts

parameter is to be monitored? is the parameter to

be monitored?

is the parameter to

be monitored?

is the parameter to

be monitored?

Air emissions of NOx, SO2, CO, and particulate matter (PM)

Emissions of air pollutants: (1) NOx calculated as NO2; (2) SO2; (3) CO; (4) 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 power plant

By continuous monitoring equipment supplied with the power plant

Initial test at commissioning and annual subsequently. Continuous for NOx and CO.

Air emissions of NOx, SO2, CO, and particulate matter (PM)

Ground level concentrations: (1) NOx; (2) SO2; (3) PM. The applicable environmental standards are: (1) NOx: Annual average ≤ 40 μg/m3; Max 24-hour average ≤ 150 μg/m3; Max 30-min average ≤ 500 μg/m3 (2) SO2 Annual average ≤ 40 μg/m3; Max 24-hour average ≤ 150 μg/m3; Max 30-min average ≤ 500 μg/m3 (3) PM Annual average ≤ 50 μg/m3; Max 24-hour average ≤ 125 μg/m3; Max 30-min average ≤ 280 μg/m3

In adjacent residential areas and/or nearest air quality monitoring stations

By buying data from the local air quality monitoring station

Once before commissioning of the plant and annually when the plant is in operation

Noise from construction works

Noise level, dB[A]. Applicable limits are 80 dB[A] on-site and 65 dB[A] off-site.

At 1 meter from operating turbines and in nearest residential areas

Measurements by a licensed organization using certified measurement devices

Once before commissioning of the plant and annually when the plant is in operation

Follow-up and Supervision of EMP Implementation

• EMPs should be periodically reviewed, especially when:– Environmental impacts are associated with the

operational rather than construction phase (Example: power plant or mining operations);

• Revisions to EMP may be necessary when:– Final EIA produced after project appraisal renders

the original EMP obsolete or irrelevant;

• Site-specific EMPs produced after project appraisal need to be checked during project supervision

Supervision of EMPs

• Implementation (enforcement) of EMPs has often been problematic

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

• Monitoring/Reporting Program needs to cover environmental indicators

• Legal Coverage/Bidding and Contracting Documents

• Active supervision is needed, including reshaping mitigation measures, institutional assignments, etc.

Concluding Remarks• EMPs provide a critical link between the EA report

required for Bank’s appraisal and environmental compliance during project implementation/operation

• Integration of EMP into ECA countries’ evolving national EIA procedures is an elaborate but essential task

• Quality of EMP preparation and its integration into project design and operation has a strong impact on the quality of environmental compliance on the ground

• EMP requirements are legally binding on the construction/installation contractors…, but only when they are in their contract!

• Supervision of EMP implementation is an integral part of the Bank’s project supervision process

Thank You!

environmental management planning: an integrated, results-oriented process discussion material for...

Documents

implementation of emp

place of emp

environmental impacts

framework emp

requirement of emp

action plan emp

emp specific requirements

hazardous waste management