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

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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