World Bank Safeguard Training
Ankara, Turkey
March 30 ,2010
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Category A:
◦ Full Environmental Impact Assessment (EIA), or
◦ Strategic Environmental Assessment (SEA)
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Category B:
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Limited Environmental Assessment (EA), or
Environmental Management Plan, or
Environmental Management Framework, or
Environmental Audit, or
Hazard or Risk Assessment
Category FI:
◦ Environmental Management Framework
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Identifies and assesses potential risks and benefits based on
proposed activities, relevant site features, consideration of
natural/human environment, social & transboundary issues
Compares environmental pros and cons of feasible alternatives
Recommends measures to eliminate, offset, or reduce adverse
environmental impacts to acceptable levels (sitting, design,
technology offsets)
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Proposes monitoring indicators to implement mitigation
measures
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Describes institutional framework for environmental
management and proposes relevant capacity building needs
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No (or poor) Executive Summary
Inadequate information on methodology and data
sources
Inadequate or inappropriate baseline information
Inadvertent use of “red flag” phrases (“sensitive
habitat”)
No (or inadequate) analysis of feasible alternatives
No (or inadequate) discussion of indirect, cumulative,
and transboundary impacts
Unclear what mitigation is required, what is
recommended
Issues raised in EIA, not addressed in EMP
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“Upstream” planning tool (input to sectoral or
regional planning process)
Helps identify more vs. less sustainable
development pathways
Can be OP 4.01 Instrument for programmatic
investment
◦ even if Category A projects are included
◦ special emphasis on cumulative impacts
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Must include SUBSTANCE, not just process (not
same thing as EMF)
Relatively new instrument; limited guidance,
limited capacity and experience
• Identify, characterize, evaluate potential environmental risks of
expected project investments (EA Category; FI with A and/or B)
• Identify which SG Policies apply to overall project
• Describe/compare applicable national laws/regulations & WB
policies – identify gaps and gap-filling measures
• Provide clear and practical operational guidance for project
implementers (FI, sub-borrowers)
• Assign responsibilities for implementation and monitoring of
sub-project level EMPs
• Serve as the “Environmental Safeguard” document for
disclosure/consultation prior to Appraisal, and for Legal
Agreement
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When specific investments cannot be
identified prior to project Appraisal (unknown subprojects are proposed during
project implementation):
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Financial Intermediary (FI) operations
Tranched sectoral investment programs (incl. SWAPS)
Area development projects (rural, municipal, etc.)
Social Funds
Small Grants Programs
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Overview of project
Applicable national legislation and WB policies (comparison)
Implementation arrangements
EA procedures and processes
◦ Sub-project descriptions or eligibility criteria (selection, design,
contracting, monitoring, evaluation)
◦ Sub-project EA screening process and guidance (Category A, B, or
C): criteria, responsibilities, procedures, guidelines for screening
social safeguards
◦ EA/EMP preparation guidelines:
 EA/EMP templates for each Category (A,B): format, contents,
and step-by-step procedures for preparation,
disclosure/consultation, approval)
 Maybe “generic” EA/E(S)MP for common types of investments (to
be tailored to individual sub-projects)
Monitoring and evaluation: general environmental and social
compliance monitoring indicators; reporting templates
PROJECT
EMF (project level)
Sets out requirements &
responsibilities for sub-projectspecific EA
Disclosure and in-country
consultation national level
Sub-project
Sub-project
Preparation, consultation and
disclosure prior to Project Appraisal
Sub-project
Sub-project-specific EIA, EA or EMP
Sets out environmental issues and mitigations and monitoring for
subproject
EA disclosure and consultation at local level(2 for Category A subprojects)
Prepared during project implementation
•Preparation, In-country disclosure & consultation on EMF
& RPF
•Prepare Operational Manual; integrate EMF into it
•Sub-project EA screening (together with sub-borrowers
•Identify EA instruments required
•Review sub-project applications for compliance with
national and WB requirements
• Monitor subproject compliance with environmental
mitigation and monitoring plans
•Maintain records, files and documents for all subprojects
• Report to the Government & Bank on EMF non-compliance
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Submit subproject concept to FI
Preparation, disclosure and consultation on subproject EA/EMP, and RAP
Submit EA/EMP, RAP to FI for review
Obtain required permits/licenses
Obtain clearance from local/regional environmental
authorities
Implement sub-project EMP, including supervision of
contractors
Report to FI on EMP non-compliance
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Review and clear sub-projects EAs according
to national/local regulatory requirements
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Issue permits and licenses
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Environmental monitoring and inspections
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At 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
FI
◦ Arrangements and capacity to implement
assessment
EMF, and measures in project to
strengthen as needed
During Implementation:
◦ Prior review/NOB of Category A (sometimes also
Category B) sub-project EIAs
◦ Spot-checking of EMF & sub-project EMP
implementation, including site visits
Environmental Management
Framework: KEY FEATURES
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Used when specific investments CANNOT be identified prior to
Appraisal (FI or other program of sub-projects)
No provision for EMF in OP 4.01 (evolved to formalize Borrower &
WB responsibilities for OP 4.01 compliance of subprojects vis a
vis screening, EA/EMP preparation & implementation,
monitoring, capacity building, Prior Review
Focus on screening criteria, processes, responsibilities
No set format; may or may not include technical content
Can explicitly exclude high risk subprojects
Pelosi Amendment applies if Category A subprojects expected
Category A subproject EIAs are submitted to WB Board
Sometimes Environmental & Social Management Framework – but
DOES NOT REPLACE the RPF (unless written to incorporate RPF as
set out in OP 4.12)
ISSUES
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EF not recognized in
national legislation, no
national mechanism to
approve
SOLUTIONS
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Differences between
national and WB EA
screening criteria,
environmental standards
FI lacks capacity for EA
screening, environmental
monitoring
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EF developed specifically for
WB-financed project;
Implementing Ministry adopts
without formal approval
More stringent criteria apply
(may require “double”
screening)
Capacity building within
project and/or outsourcing
(limit direct WB involvement to
high risk subprojects);
Category A sub-projects
excluded
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An Action Plan that indicates which of the EA report
recommendations and alternatives will actually be
adopted and implemented
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Part of EIA or freestanding
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The most important link to incorporate
environmental factors into the overall project design;
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Identifies linkages to other SG policies relating to the
project
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Ensures environmental mitigation measures and
their practical monitoring become a legal
responsibility of the Borrower (LoA)
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Summary of predicted adverse environmental
and social impacts related to project;
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Description of mitigation measures and plan
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Description of monitoring activities and plan
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Institutional arrangements including training
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Implementation schedule and reporting
procedures
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Estimated related costs and sources of funds
◦ Defines the key environmental (and social) issues
which should be managed
◦ Describes specific mitigating measures to manage
each possible impact, including specific actions to
be achieved
 Mitigation measures should be feasible and practical;
 Mitigation measures should be easily observed and checked
◦ Identifies the authorities responsible for mitigation
implementation
◦ Includes associated estimated costs
◦ Defines selected indicators for ensuring that
mitigation measures are being implemented and are
effective (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
◦ Includes estimated related costs
EMP: Typical Mitigation and Monitoring Tables
Mitigation
Plan:
what must be
done
Monitoring
Plan:
to determine
whether
measures are
implemented &
effective
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Mitigation measures too general, insufficient detail
Mitigation and/or monitoring measures not
feasible or not practical
Inadequate institutional capacity, insufficient
capacity building measures
Monitoring indicators not measurable
Monitoring targets missing or too general
Lack of cost estimates
Too long and elaborate to be implemented
EMP Checklist: Eligibility Criteria
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Category “low B” Project
Environmental issues known and limited to small
scale construction/rehabilitation works
(Checklist EMP can be applied to one project
component, with regular EMP or EA applied to
others)
Area of impact clearly defined & limited: either
within an existing “footprint” or relatively small
new areas known not to have major
environmental or social issues
EMP Checklist: Structure and Function
1: Datasheet
2: Potential
impacts list
• Basic information on project activities
• Environmental baseline information
• Grouped according to various themes or
impact types
• Themes / types to be checked as
applicable
3: Mitigation
measures list
• Each checked item from Section B triggers
specific mitigation measures / parameters
and specific, concrete activities to be
implemented on site
4: Monitoring
plan
• Focuses on reasonable, meaningful,
practical monitoring parameters and
activities
EMP Checklist: How it works
Example: Country X Real Estate & Cadastre Project (XRECP)
Introductory information (to be filled in prior to Appraisal):
• Project will finance rehabilitation of 15 Cadastre office buildings, all currently in
use
(sub-projects)
• No new construction or extension of facilities – all works within existing footprint
• All buildings located in urban areas on commercial streets with moderate to
heavy
traffic
• Some may be registered historical buildings
• Rehabilitation will be interior & exterior including: repair or replacement of roofs
& windows, rewiring, removal/replacement of insulation, masonry repairs,
replacement of floors, repair/replacement of plumbing, painting
• A site-specific Checklist EMP form will be completed for each Sub-project and
will be attached to the construction contract
EMP Checklist: How it works
Subproject Example: Town A
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EMP Checklist: How it works
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EMP Checklist: How it works
NOTE: Section A always applies
EMP Checklist: How it works
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