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Integrating Environmental Integrating Environmental Management Plans Management Plans
into into Project Operational ManualsProject Operational Manuals
Agi KissAgi KissSafeguards Training Workshop, Chisinau, Oct 28-31, Safeguards Training Workshop, Chisinau, Oct 28-31,
20082008
Project Operational (Implementation) Project Operational (Implementation) ManualManual
• 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
Typical Contents of POMTypical 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)
Why Have a POM (PIM)?Why Have a POM (PIM)?• 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
Alternative Approaches for Integrating EMP Alternative Approaches for Integrating EMP into POMinto POM
1. EMP as a chapter of POM
2. EMP as an annex to POM
3. Elements of EMP inserted throughout POM where relevant
4. 1 & 3 or 2 & 3
“Pros” of each:
Separate Chapter/Annex = easy reference
Integrated = environment is fundamental, not an add-on; Not only Environmental Staff
Example: Small Grants ProgramsExample: Small Grants Programs
General DescriptionGeneral Description
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
Guidance from Guidance from Project-level Environmental FrameworkProject-level Environmental Framework
• Eligibility criteria for sub-projects (positive and/or negative list)• Environmental Assessment screening criteria & procedures
(e.g. A, B, C) and associated EA requirements• Procedures and responsibilities for preparation and approval of
sub-project EAs and EMPs• Environmental issues and mitigation measures for different
types of sub-project activities– including procurement and contract provisions
• Monitoring & reporting requirements (EMP implementation)• Environmental impact indicators and monitoring
Example: Croatia Conservation and Rural Example: Croatia Conservation and Rural Revitalization ProgramRevitalization 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
Advertisement of program
Workshops for Applicants
Submission of proposals (3 rounds)
Eligibility Screening of proposals Evaluation/selection
of proposals
Revisions
Agreement on work plan, contract signing
First tranche disbursement
Progress report, accounting & verification
Second tranche disbursement
Final report & accounting
CCRRP sub-project cycle
(Written notification/explanation)
(Assisted) preparation of applications Project approval
Institutional StructuresInstitutional Structures
• Ministry of Culture (and Nature Protection)– Project Implementation Unit
• National level “Headquarters” – overall implementation, reporting• Local level (3) – day to day support, verification & monitoring
• Small Grants CommitteeProject policy and oversight
• Local Advisory Boards (local officials, NGOs)– Sub-project evaluation and selection– Review progress reports
• Ministry of Environmental Protection– Enforce environmental regulations, permits– TA, expert review - upon request
Eligibility criteria (beneficiaries) individuals & groups, geographic location
Eligibility screening criteria (sub-projects some linkage to biodiversity. E.g., organic farming and agro-processing, indigenous plants/livestock, eco-tourism, sustainable grazing, renewable energy, environmental education programs, etc
Environmental guidelines (overview): Excluded activities (Annex 1/Category A)Environmental information in initial applicationRequirements for EA or alternative procedures (Annex)Monitoring requirements (Annex)
Institutional responsibilities MoC, SC, LAB, MEP
Procedures grant initiation, application evaluation, selection, implementation, monitoring/reporting
Annexes: Project level EA/EMP :Guidelines for projects where no
EA/EMP required
Environmental criteria, issues, mitigation measures (overview and requirements for sub-projects not requiring specific EA/EMP)
Templates and standard forms for grant application, evaluation, implementation plan, monitoring – include sections for environmental aspects
CRRG Project Operational Manual Structure
Incorporation of EMF in ProceduresIncorporation of EMF in Procedures• Applicant training workshops:
– environmental objectives; potential impacts and mitigation measures for different types of sub-projects
• Preparation of applications:
• - Environmental issues and mitigations identified in application form
• Screening of proposals:• - LAB/MEP reviews eligibility of proposal, excluding any with high environmental risk
• Proposal evaluation/selection…revisions, approval:– Environmental mitigations refined as required (Local Env. Authorities on LAB advise) and included in
Implementation Plan
• Agreement on Work Plan/ Signing of Sub-Project Contract with Recipient– Environmental mitigation measures included in Sub-project contract– Includes specific environmental provisions for procurement, contracting
• Progress reporting/verification for second (and further tranche of funding – Environmental measures may be among triggers for disbursement; PIU verifies environmental
measures implemented and are effective
• Final report & accounting– includes EMP compliance, environmental indicators
Common Problems in Implementing EMP in Common Problems in Implementing EMP in
Small Grants ProgramsSmall 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