Environmental Management

Planning:
An integrated, results-oriented process
Discussion Material
For the Moldova Safeguards Training Workshop
October 28-31, 2008

By Victor B. Loksha
ECA Safeguards Team
Europe and Central Asia Region
The 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 Banks 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 projects Operation
Manual
The borrower must report on compliance with EMP
Specific requirements for EMPs are set out in Annex C
of OP 4.01

The Place of EMP Within the Project Cycle:

Basic approach according to World Bank , Option 1
Preparation

Planning/Feasibility

Environmental
Impact
Assessment

Environmental
Management
Plan

Project
Identification

Detailed Design
Operation
Supervision of
Construction/Implementation
Monitoring

The Place of EMP Within the Project Cycle:

Basic approach according to World Bank, Option 2
Preparation

Planning/Feasibility

Environmental
Impact
Assessment

Environmental
Management
Plan

Operation

Monitoring

Detailed
Design

Supervision of
Construction/Implementation

EIA and Project Cycle: Standard Practice in Many ECA Countries

Preparation
Final
Preliminary
Environmental
Environmental
Impact
Impact
Assessment
Assessment

Planning/Feasibility

Project
Identification

Environmental
Permit
Construction
Permit

Detailed Design

Operation
Supervision of
Construction/Implementation
Monitoring

Integration of EMP into Standard ECA Practice

Preparation
Final
Preliminary
Environmental
Environmental
Impact
Impact
Assessment
Assessment

Planning/Feasibility

Project
Identification

Environmental
Permit
Construction
Permit

Operation

Monitoring

Environmental
Management
Plan

Detailed
Design
Bidding Documents

Supervision of
Constr./Implementation

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? (contd)

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:

Lets See Some Details!
Preliminary EIA

Prefeasibility study

Generic
Environmental
Management Plan

Feasibility study

Detailed EMPs:
Site-specific / Impactspecific

Detailed
Design /
Engineering

Bidding Documents

Tasks
often of
Core tasks
assigned
to
the Design
Design
Engineering
Engineering
Consultant
Consultant

Integration of EMP into Project Design, contd

What Does the Bank
Typically Require to
See and When?

Preliminary
EA ReportEIA

Prefeasibility study

Generic
Environmental
Management Plan

Feasibility study

Required
For
Appraisal

Required for
appraisal if
details of
investments
are known

Detailed EMPs:
Site-specific / Impactspecific

Detailed
Design /
Engineering

Bidding Documents

The Banks due diligence

obligations for EMP
Advice for preparation and then NoObjection 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

Environmental Management Plan

A. Mitigation
Project
Activity

Potential
Environm
ental
Impacts

Proposed
Mitigation
Measures(s)
(incl. Legislation
& regulations)

PreConstruction
Phase

1)
2)
3)

Construction
Phase

1)
2)
3)

Operation and
Maintenance
Phase

1)
2)
3)

Institutional
Responsibilities
(incl. Enforcement
and coordination)

Cost
Estimates

Example: Environmental Management Plan

For a Power Plant Construction Project in X-land
A. Mitigation: Construction Phase
Project 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.

Contractor/
Plant
Operating
Company

US$
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

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.

Contractor/
Plant
Operating
Company

Example: Environmental Management Plan

For a Power Plant Construction Project in X-land
A. Mitigation: Operation Phase
Project
Activity

Potential
Environmental
Impacts

Proposed Mitigation Measures

Institutional
Responsibility

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

Costs

Environmental Management Plan

B. Monitoring
Proposed
Mitigation
Measure
PreConstruction
Phase

Construction
Phase

Operation
and
Maintenance
Phase
Total Cost for
all Phases

Parameters
to be
Monitored

Location

Measurements
(incl. Methods
& equipment)

Frequency of
Measurement

Responsibilities
(incl. review and
reporting)

Cost
(equipment
& individuals)

Example: Environmental Management Plan

For a Power Plant Construction Project in X-land

B. Monitoring: Construction Phase

Potential
Environmental
Impacts

What

Where

How

When

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 fees to
environmental fund

Power plant site,

pipeline and
transmission line
routes

Visual and by
comparison with preconstruction 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

Example: Environmental Management Plan

For a Power Plant Construction Project in X-land

B. Monitoring: Operation Phase

Potential
Environmental
Impacts

What

Where

How

When

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 g/m3; Max 24-hour
average 150 g/m3; Max 30-min average 500
g/m3 (2) SO2 Annual average 40 g/m3; Max 24hour average 150 g/m3; Max 30-min average 500
g/m3 (3) PM Annual average 50 g/m3; Max 24hour average 125 g/m3; Max 30-min average 280
g/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] onsite 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 Banks 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 Banks project supervision process

Thank You!