Purpose, Content and Implementation of

Environmental Management Plans (EMPs)

ECA Safeguards Training for PIUsAnkara

May 16-17, 2011

Esra Arikan

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

For Category A projects, EMP is an essential feature of EIA (or a separate 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?

EMP is part of the EA prepared and financed by the Client; In case of FI Projects the EMP should be prepared by the sub-borrower

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…

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…

address all relevant environmental issues identified in the respective EIA report;

be comprehensive, 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

No established format; Typical introductory text part followed by

tabular format 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 throught the POM);

Mitigation Plan

Defines the key environmental 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;

Presents associated estimated costs

Environmental Mitigation Plan

Project

Activity

Potential Environmental Impacts

Proposed Mitigation

Measures(s)(including

legislation/ regulations)

Institutional Responsibilit

y(including

enforcement/ coordination)

CostEstimate

s

Pre-Constructio

n Phase

1)2)3)

Construction

Phase

1)2)3)

Operation and

Maintenance

Phase

1)2)3)

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 PlanFor The Foundry Construction Phase

Project Activity Potential Environmental Impacts

Proposed Mitigation Measures Institutional Responsibili

ty

CostsUS$

Use of land within the plant

construction area, and along the access

road 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 agree with the MoEnv on a practical compensation to protect specific trees

Contractor/Plant Operating Company

“5000”

Use of land within the plant

construction area, and along the access

road 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.

Contractor/Plant Operating Company

“5000”

Construction works Air pollution by dust

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

Contractor/Plant Operating Company

2000

Construction works Noise from constructio

n works

Construction will be confined to normal work-hours (7AM to 7PM). If construction must be conducted before/after these hours, local public will be notified at least one week in advance.

Contractor/Plant Operating Company

-

Project Activity

Potential Environmental

Impacts

Proposed Mitigation Measures Institutional Responsibility

CostsUS$

Coal Combustion

Air emissions of NOx, SO2, CO, particulate matter

Low-NOx burners and water injection to control NOx;Firing only low-sulfur (<0.1% by wt.) coal to control SO2;Good combustion control to control CO, PM and VOCs;Stack height at least 45 m to facilitate dispersion.

Power plant operatorPower 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 70 dB(A) at 100 m

Power plant operatorS&I contractor

150,000

All operation phases

Workers Health and Safety

Personnel protective equipment will be used (gloves, glasses, safety belts)WHS training will be provided to workers monthlySafety engineer will be assigned to the site

Power plant operator

50,000

Example: Environmental Mitigation PlanFor the FoundryOperation Phase

Monitoring Plan

Defines selected indicators for ensuring that mitigation measures described in the Mitigation Plan are being implemented in an effective way (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; Presents estimated related costs

Proposed MitigationMeasure

Parameters

to be Monitored

Location

Measurements

(incl. Methods & equipment)

Frequency of

Measurement

Responsibilities

(incl. review and reporting)

Cost (equipment

& individuals)

Pre-Constructio

nPhase

Construction Phase

Operation and

Maintenance Phase

Total Cost for all

Phases

Environmental Monitoring Plan

Example: Environmental Monitoring Plan

For the FoundryConstruction Phase

 What Where How When/By whom Costs

US$

Potential Environmental Impacts

parameter is to be monitored?

is the parameter to be monitored?

is the parameter to be monitored?

is the parameter to be monitored?

Damage to vegetation

Clearing techniques and relocation procedures utilized; record of compensation provided as agreed with MoEnv

Plant site, pipeline and access road line routes

Visual and by comparison with pre-construction photo survey

Monthly throughout construction period;Contractor/ Supervisor Engineer

-

Loss of fertile topsoil and soil erosion

Soil storage procedures and location

Soil storage sites

Visual Weekly during site preparation and construction periodContractor

-

Air pollution by dust

Dust level All active construction sites

Visual During construction Contractor/ Supervisor Engineer

-

Noise from construction works

Noise level, dB[A] All active construction sites

Measurements by a licensed organization using certified measurement devices

During construction,Contractor

“Estimated standard costs”

Example: Environmental Monitoring PlanFor the FoundryOperation Phase

What Where How/Costs When/by whom

Potential Environmental 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)

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 plant

By continuous monitoring equipment supplied with the power plant; costs are part of the self-monitoring plan for the plant – could be easily estimated

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

Noise from construction works

Noise level, dB[A]. Applicable limits are 70 dB(A) at 100 m

At 100 meter from the border of the site (closest end to a residential area)

Measurements by a licensed organization using certified measurement devices; national standard costs

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

Workers Health and Safety

Usage of personnel protective equipmentRecords of WHS training

At the site Visual by checking the practical usage of equipment and checking adequate among of equipment exists.Records of the trainings will be checked and if necessary improvements will be done

Equipment: daily by safety engineer

Training records: monthly by safety engineer

EMP Institutional Arrangements

How the overall environmental management system works during the project implementation (construction and operation phases) and Who is responsible to implement it;

Who will supervise the implementation of Mitigation Plan;

Who will collect the data (from the 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

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

Implementation (enforcement) of EMPs has often been problematic…

1. Unrealistic/inadequate monitoring indicators;2. Infrequent site visits by team members;3. Inadequate review and evaluation of monitoring

aspects and reports;4. Failure to revise the EMP in response to project

changes during implementation;5. Inadequate follow-up on Borrower

implementation of agreed actions (from previous mission);

6. Ineffectiveness of proposed institutional capacity measures

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 soon 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 fresh revision of mitigation measures, institutional assignments, etc.

Integration of EMP in POM

1. EMP as a chapter of POM2. EMP as an annex to POM3. Elements of EMP inserted

throughout OM where relevant

Recommended - 1 & 3 or 2 & 3

THANK YOU…