Training Workshop for Financial Intermediaries
and Implementing Agencies
May 2011
Ruxandra Floroiu
Senior Environmental Engineer,
ECA Region, World Bank
OP 4.01 – allows use of ESMF as EA safeguard instrument when:
“a project consists of a program and/or series of sub-projects, and the
impacts can not be determined until the program or sub-project details
have been identified” = before project appraisal

EA Category FI – subprojects (most identified after project appraisal)
are financed through a Financial Intermediary (“FI”) – requirements and
procedures set-out in an ESMF

manage potential adverse impacts through a guide consisting of a set
of methodologies, procedures and measures to facilitate adequate
environmental management (risk management and impacts) related to
the works financed under the project and whose specific location is
unknown or may change during project implementation

social aspects are briefly addressed (not as in RPF) - ESMF
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Provides guidance to sub-borrowers (sub-project sponsors) and FIs to ensure the
EA process is carried out in compliance with national legislation and OP 4.01
Provides an environmental and social screening process to allow for identification,
assessment and mitigation of potential impacts by proposed works at the time the
detailed aspects are known
Used as a reference document for assessing the potential environmental and social
impacts of investment alternatives
Serves as guidelines for the development of sub-project/site-specific Environmental
Management Plans (EMPs), Environmental Assessments (EAs), due diligence
reports, environmental audits, etc
Is an integral part of the project Operational Manual and applicable to all FIs
investments, regardless of its funding source or implementing agency
MAIN OBJECTIVES:
 Establish procedures for screening all proposed sub-projects for their potential
adverse environmental and social impacts
 Specify measures for managing, mitigating and monitoring environmental impacts
during project operation
 Outline training and capacity-building arrangements needed to implement the EMF
provisions
Brief description of project components including description
of type of activities eligible for financing
2. Operating requirements (diagnosis of legal and institutional
framework, applicable safeguards)
3. Environmental/social baseline at national/state level
4. EMF screening procedures (criteria, process, environmental
due diligence process, EA/EMP documentation)
5. Implementation arrangements
6. Public consultation and disclosure process/procedures
7. Environmental mitigation measures
8. Monitoring and reporting arrangements
9. Training and capacity building recommendations
10. Various annexes
1.
EMF (project level)
Prepared by primary Borrower (FI)
Sets out requirements & responsibilities
for sub-project-specific EA
Acceptable to WB
Disclosure and one National level
consultation on EMF
PROJECT
(FI)
Sub-project
Preparation, consultation and disclosure
prior to Project Appraisal
Sub-project
(Akfirat sewage system, cat. B )
(Meski water supply, cat. B)
Sub-project
(KaYseri landfill, cat. A)
Sub-project-specific EA or EMP (sub-project level)
Prepared by sub-borrower/grant recipient (sub-project implementer), during project
implementation
EA/EMP disclosure and local level consultation prior to finalizing document
FI responsible for quality/clearance and for monitoring implementation
WB prior review of some Category B

Screening form to be filled out by sub-project proponent
Sub-project name, location (map), type of activity, physical data,
environmental information, likely environmental impacts,
environmental screening category (A, B or C), mitigation of pollution,
environmental studies required (EIA/EMP), public
consultation/disclosure required.
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Screening Criteria – site-specific environmental risks and impacts;
land zoning requirements, environmental license/permit; “negative”
list of investments not allowed for financing under the project
Reviewer decides the level of impact to be assessed through EIA
(category A or B) or EMP/EMP Checklist (category B)
Subproject approved on the basis of environmental and social
review findings (or denied/approved with some changes)
Disclosure/public meeting – function of subproject EA category
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Identification of sub-project
Application preparation and its
submission to FI
EA/EMP financing and
preparation
Collection of necessary
permits/licenses
Obtain clearances from
local/regional environmental
authorities
Implement the sub-project in
line with EMP
Reports to FI on any EMP noncompliance
Sub-project proponent
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EA screening for World Bank
requirements
Review of sub-project
application
Appraisal of sub-project
Monitor environmental
compliance based on EMP
Training of sub-project staff
Reports to the Bank on any
EMF non-compliance
Maintains records of safeguard
documents for all sub-projects
Financial Intermediary
Key Safeguard Actors in EMF
World Bank
Project
Team and
Safeguard
Specialists
World Bank
Safeguard
Compliance
Republic of Turkey
Ministry of
Environment and
Forestry
• Conduct supervision
• Provide safeguard assistance
and training
•Ensure policies are followed
•Conduct reviews
•Review and clear sub-projects
according to national and
local regulatory requirements
• Issue environmental permits
•E-permit (since 2010) for new facilities
8
Integrating Flow Charts to Guide PFIs
Example of EIA Review Flow Chart for SME Credit Line Projects in Turkey
Annex II
Annex I
PC
already
done
No Annex
EIA
Necessary
EIA Positive
PIF(Project Info File)
No Environmental
Documentation
EIA NOT
Necessary
(**)
WB – A
Category or in
other ineligibility
list
WB – B
Category
WB – B
Category
Yes
Installation of new
buildings and extension
of existing buildings
No
Eligible
Eligible
Ineligible
EA with EMP, or
EMP alone
EMP / Checklist
EMP
WB requires
EA/EMP and PC
Public
Consultation
Public
Consultation
WB – C
Category
Eligible
No Environment
Documentation
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WB Appraisal evaluates:
◦ adequacy of relevant national EA requirements;
EMF
gap-filling
◦ adequacy of proposed EA procedures for sub-projects
◦ capacity of FI and others responsible
◦ measures in project to strengthen EA
FI
arrangements/capacity as needed
assessment

WB Supervision:
◦ Prior review/NOB of Category A (sometimes also
Category B) sub-project EIAs (unless FI assessment
indicates this is unnecessary)
◦ Spot-checking of EPF implementation, including site
visits
FI has main responsibility for preparing and monitoring
the application and use of EMF. During sub-project
supervision the FI:
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Responsible for assessing the capacity of sub-borrowers to comply
with EMP and more generally to do proper environmental and social
management
Performs sub-project site supervision visits to confirm EMP
implementation
Consults local environmental authorities for EMP requirements
including current permits
Verifies with sub-borrower the overall environmental performance of
the investment including any critical mitigation measure taken and
significant environmental incident
Prepares quarterly/annually reports on results of EMP actions
Incorporating EMF into Sub-Project Cycle
Submission of priority proposals
Evaluation/selection of proposals
Eligibility Screening
FEASIBILITY/DESIGN
(Assisted) preparation
of applications
Pre-FS Form
EIA/EMP Preparation
Sub-Project approval
Environmental Permit
Construction Permit
PRE-FEASIBILITY
IDENTIFICATION
sub-project cycle
Agreement on work
plan, contract
signing
SUPERVISION
Start of works
OPERATION
Monitoring of works
EMP implementation
Progress reports
review of eligibility of
proposal, excluding any
Eligibility
Screening
with high environmental
of
proposals
risk
Submission of proposals
5
4
6
identify
potential
environmental issues
(Assisted)
preparation
and proposed mitigation measures
Sub-Project approval
3
of applications
6 Environmental mitigation
Advice
to prospective applicants on eligible/ineligible
Training
activities, potential environmental
2 2 issues e; potential
Workshops
for
impacts and mitigation measures for different types of
Applicants
sub-projects
Program
Advertisement
1
EA screening, evaluation of
env. issues and proposed
Evaluation/selection
of
mitigations; scope of EA/EMP,
eligible
if requiredproposals
sub-project cycle
Agreement
work
measures
included inon
Sub-project
plan,
contract
signing
contract;
includes
specific
provisions for environmentally
7
sound procurement,
contracting
First
tranche
Procurement: include
environmental
provisions in bidding
documents,
8 disbursement
specifications, contracts (including
penalties for non-compliance)
Final reports,
on
Final
reportISR
& report
accounting
EMP compliance and
11
env./social impacts
10
Sub-borrower
monitors
according to
Progress
report,
Env. Monitoring Plan, reports to PIU;
9 Accounting, verification
PIU verifies, reports to Borrower & WB
environmental measures
Second
tranche
disbursement
may
be triggers
for
disbursement
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EMF not recognized in
national legislation (no national
mechanism to approve it)
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Enhancing the capacity of FIs
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Good quality EA/EMPs

World Bank
Differences between national
and WB EA screening criteria,
environmental standards
Meaningful public consultation
and timely public disclosure
Improving environmental
screening
Intensifying monitoring
Incorporating estimated costs
of EMP mitigation measures in
sub-project cost/budget
Timely Progress Reporting on
EMP implementation aspects
Financial Intermediary