ENVIRONMENT RESEARCH CENTRE
ENVIRONMENTAL & SOCIAL ASSESSMENT FRAMEWORKMaldives Environmental Management Project
February 3, 2008
This ESAF provides a guidance framework to the Project Management Unit, and Project Implementing Agencies on the approach and processes to ensure that environmental and social aspects, impacts and mitigation are integrated into the Project.
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TABLE OF CONTENTS
I. Introduction ..................................................................................................................................... 3 II. Project Objectives and Components ............................................................................................ 4 III. Environmental Policies, Laws, Regulations, Notifications and Traditional Rights ............. 11 IV. Environmental Review Capacity of the Ministry of Energy, Environment and Water (MEEW) and adequacy of the Environmental Clearance Process ................................................ 14 V. World Bank Environmental and Social Safeguard Policies and its Relevance to the Maldives Environmental Management Project, and Compliance with Applicable World Bank Policies, Guidelines and Procedures ..................................................................................... 14 VI. The Need For an Environmental and Social Assessment Framework ................................... 22 VII. The Process for Site and Technology Selection for the Regional Waste Management Facility ............................................................................................................................................... 24 VIII. Island Waste Management Centers ....................................................................................... 28 IX. Monitoring and Evaluation ....................................................................................................... 29 X. Environment and Social Assessment and Management Framework ...................................... 30 XI. Framework Management ........................................................................................................... 34 Annex 1: Environmental and Social Action Plan for IWMC’s ..................................................... 49 Annex 2: Standard Site Selection Procedures ................................................................................ 55 Annex 3: Design Specifications ....................................................................................................... 64 Annex 4: Island Waste Management Planning Manual ................................................................ 86 Annex 5: Generic Terms of Reference for the preparation of an Environmental Impact Assessment (EIA) statement. ........................................................................................................... 97 Annex 6: Environmental and Social Impacts Screening Checklist ............................................ 102 Annex 7: Community Mobalisation Work Plan ........................................................................... 104 Annex 8: Community Centered Development (CCD) Procedures ............................................. 111
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I. Introduction The Maldives Environmental Management Project (the Project) aims to improve and develop a socially and environmentally sustainable system of solid waste management that reduces the associated environmental and public health risks in the North Central Region which can be subsequently replicated and scaled up across the country. It also aims to strengthen capacity for environmental management in the Maldives. These objectives will be achieved through the following components: (1) a regional solid waste management program for the North Central Region, with Island Waste Management Centers (IWMCs) located in participating islands, supported by a regional waste transfer and transport system for residual waste from the IWMCs and a regional waste management facility for residue management; (2) the capacity building component addresses some of the human resource constraints and informational impediments to improved environmental management.; and (3) Technical assistance for a Regional Strategic Environmental Assessment to assess the impact of human activities, global warming and other factors on the local environment in the North Central Region. Overall, the project activities would result in improved environmental management in the Maldives.
However, considering the pristine and fragile ecosystem in the Maldives, the regional solid waste management component could generate adverse environmental impacts even though the net environmental impact of the component would be strongly positive. It is unlikely that activities undertaken in Capacity Building for Environmental Management and the Regional Strategic Environmental Assessment for the North Central Region will result in adverse environmental or social impacts. In fact, both components will lead to improved environmental planning and management in the Maldives. The regional solid waste component could generate adverse environmental impacts, especially over the short term, although the net environmental and social impacts are expected to be beneficial.
Projects and Programs financed with IDA resources need to comply with World Bank Operational Policies. Therefore, components and sub‐components eligible for funding under this project will be required to satisfy the World Bank’s safeguard policies, in addition to conformity with environmental legislation of the Government of the Republic of the Maldives (GoM). The proposed project is classified as Safeguards Category “A” by the World Bank, which means that the project has the potential to have significant and possibly irreversible adverse environmental and/or social impacts. A detailed Environmental Assessment will be conducted for the regional solid waste management component in accordance with OP/BP 4.01 to identify and mitigate potential adverse environmental and social impacts of the project.
Based on the lessons learned from islands with no formal solid waste management and also from the experience of the existing Island Waste Management Centers (IWMCs), which have been constructed for solid waste management at the island level, it is clear that community participation is essential for effective operation and long term sustainability of the IWMCs. Community consultations and their leadership in taking responsibility for waste management in the respective islands, particularly with regard to the role the community would play in the selection of recycling and resource recovery activities to be undertaken at the IWMCs has been shown to lead to effective management of these facilities. Therefore, the specific activities to be undertaken at IWMCs supported under the project will be decided by the community when preparing Island Waste
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Management Plans (IWMPs) which will be an activity during project implementation. The type of regional waste management facilities, including the options for technological choices—engineered landfills where the level of engineering needed for containment of pollution will depend on the pollution potential of the waste arriving at the site; incineration which will be based on the calorific value of the residual waste; or waste to energy through stream recovery—can be decided only after the IWMPs identify the amount and nature of the waste being transported to the RWMF. In addition, the unique ecosystem in the Maldives poses significant problems in identifying appropriate locations for siting the RWMF, which is unlike in any other country. Public opposition due to the NIMBY syndrome could preclude the use of an inhabited island as a site for the RWMF. The high population density in most inhabited islands could further contribute to problems in siting a RWMF in an inhabited island. Islands with compatible land uses such as industrial islands could possibly serve as a site for a RWMF. Alternatively, an uninhabited island in the North Central Region could be a potential site for a RWMF. However, virtually all uninhabited islands are densely vegetated and surrounded by a continuous reef system, both likely to contain high terrestrial and marine biodiversity. If there is no alternative but to choose one of the 180 uninhabited islands in the North Central Region, access for waste transfer barges or landing craft will necessarily include excavation of a channel for navigation through the coral reef system surrounding the islands. A decision to excavate a reef for a navigation channel has to be taken only after a careful assessment of the health of the reef ecosystem surrounding the island. Since the Maldives has very little data on the quality of its reef ecosystems, an assessment of the reefs of potential uninhabited islands is a pre‐requisite to the decision making process.
Therefore, an environmental assessment in accordance with OP/BP 4.01 and the requirements of the GoM cannot be carried out during project preparation. This Environmental and Social Assessment Framework (the Framework) has been prepared by the Environment Research Center on behalf of the Government, in lieu of a project specific EA and will serve as a template for undertaking project specific EAs once the details of the specific works have been identified. GoM clearance and World Bank approval of the environmental assessments for the regional waste management facility and the island waste management centers is a pre‐requisite for disbursements of funds for the respective sub‐components under the project.
II. Project Objectives and Components This project has two development objectives. The first seeks to improve and develop a socially and environmentally sustainable system of solid waste management that reduces the associated environmental and public health risks and can be replicated and scaled up across the country. The second aims to strengthen capacity for environmental management in the Maldives, by addressing some of the human resource constraints and informational impediments to improved environmental management. It aims to have decision‐making processes of relevant government agencies make use of trained professionals and scientific information to assess, design and implement responses to environmental risks. The proposed project would have four components: (1) a regional solid waste management program for the North Central Region; (2) capacity building for environmental management; (3) technical assistance for a regional strategic environmental assessment enhancing environmental management through the collection and use of data and (4) project management and project communications.
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Component 1: Regional Solid Waste Management Program Solid waste remains the most visible environmental threat to the tourism industry. The management of solid waste is especially challenging in the Maldives, much more so than other small island states. With a highly dispersed population spread across numerous islands there is little scope for harnessing scale economies and the costs of delivering services are high. In addition with restricted endowments of land, the space available for disposing of waste is limited calling for the waste stream to be minimized through incentives for resource recovery such as recycling and composting. Finally, a fragile marine ecosystem requires that special attention be given to the choice of technology and system design to mitigate adverse impacts, with further cost implications. To address these risks and challenges stringent criteria need to be applied for site selection, engineering, technology choice and management within the context of human resource constraints in the Maldives. Reflecting the Maldives’ uniquely challenging geography and fragile ecology, the program would operate at multiple levels, building upon synergies between these levels: The construction of Island Waste Management Centers (IWMCs) would provide facilities for island communities to reduce the volume of waste requiring final disposal by sorting, recycling and composting, while temporarily storing residual waste in a safe and environmentally responsible manner. A Regional Waste Management Facility (RWMF), built on an uninhabited island or an island with compatible land use, would serve as the destination for residual waste from the islands. These would be supported by allied services such as waste transfer and transportation facilities, technical assistance, community programs, financial systems all of which would be guided by stringent environmental criteria. The facilities would be designed and built to the highest appropriate standards that is economically viable, to reduce the risk of contamination from solid wastes. Special attention would be paid to medical wastes and toxic wastes which would require special handling and management. The project would support a regional solid waste management program in the North Central Region, which is currently under‐served by waste management facilities. The program is likely to be undertaken in one or more of the four atolls—Baa, Raa, Noonu and Lahviyani—in the North Central Region of the country. The “catchment” or group of atolls and islands to be served will be defined during project implementation based on a comprehensive technical, financial and environmental feasibility study. The factors that would influence the choice of catchment include economies of scale required for the delivery of a viable waste management service, the distribution of population, the geography and environment of the archipelago, and the distribution of (current and planned) resort development. Once the catchment has been identified, there will be detailed assessments of current and future needs, technological choices for waste management and a thorough environmental and social impact assessment. Environmental factors would be given high priority over economic considerations in determining both location and design of the system. The project would include the following subcomponents: Sub‐component 1.1: Technical Assistance for Feasibility Studies, Technical Designs, Environmental Impact Assessment Studies, Contract Documentation and Capacity Building Maldives confronts distinct problems in the safe management and disposal of wastes that are not encountered elsewhere in the world and this calls for considerably greater assessment and scrutiny of options to address the technical, economic, social and unique environmental challenges. Accordingly, this sub‐component would finance a social assessment which will be conducted using participatory rural appraisal (PRA) techniques to identify ways and means of fully involving the community in waste management within the islands. A technical, financial and environmental feasibility study will be conducted to select the most suitable waste management option, taking into
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account the technological and site location issues. The study will be conducted in two phases. The first phase of the study will (i) develop potentially suitable waste management system options (including sensitivity analysis) in order to inform the Best Practical Environmental Option (BPEO) selection process; and (ii) conduct a scoping investigation of short listed islands on which the proposed Regional Waste Management Facility (‐ies) may be located. The second phase will involve undertaking (i) selection process for the preferred regional waste management system option; and (ii) a detailed technical and financial feasibility study for the preferred regional waste management option at the finally selected site. The trigger for moving from Phase I to Phase II will be the successful selection and agreement of the preferred regional waste management system option and final site location. Inputs from the Regional Strategic Environmental Assessment (RSEA) component will complement this analysis. The selection of the appropriate technology and location will be based on an iterative process where environmental aspects play a determining role. The environmental impact assessment will be a part of the BPEO process which will influence the conceptual and detailed engineering designs of the RWMF, which will prepared under this sub‐component. In addition, technical assistance would be made available for facilitating public‐private partnerships for regional waste transfer and operation of the RWMF; including preparation of a contractual framework and bidding documentation and to ERC, the participating Atolls Offices and the Island Waste Management Committees in environmental monitoring and evaluation. The Environmental Impact Assessments (EIA) for the RWMF and Environmental Management Plans for the Island Waste Management Centers (IWMCs) would be prepared in accordance with the processes laid out in this Environmental and Social Assessment Framework that has been prepared for the project. A program for regular environmental monitoring will be established to allow for greater emphasis to be placed on the interconnectivity of background environmental data collection and impact data collection through the development of ongoing environmental monitoring programs. The data collection will be linked with the Regional Strategic Environmental Assessment process by which the scope of the environmental impacts on the affected environment can be more thoroughly examined and more robust methods of predictive and verification analysis can be utilized. The science‐ and evidence‐based approach in this project and the detailed attention given to environmental factors is unprecedented in the Maldives and its implementation will serve as a model for the development of future RWMFs in the country. Sub‐component 1.2: Development of Island Waste Management Plans This sub‐component will finance the preparation of island waste management plans (IWMPs). The aim of this sub‐component is to engage communities to lead and participate in developing IWMPs. Intervention in the islands will commence with an extensive public awareness program and communication campaign on environmental issues in general and solid waste in particular to encourage the island community to participate in environmental management. This will be followed by the use of Participatory Rural Appraisal (PRA) techniques to understand the social structure and physical layout of communities, patterns of leadership, formal and informal island networks, economic activities, transportation, patterns of waste disposal, willingness to pay for improved SWM, entry points for community mobilization, and the kinds of incentives to which individuals and communities are likely to respond. Community‐level recycling and resource recovery would be promoted at IWMCs in order to reduce the volume and pollution potential of the residual waste requiring transport to RWMFs. The current systems of waste collection within the island would be assessed and alternatives will be agreed with the community as needed. Transport to the RWMF would also be examined to develop a sustainable system with the right incentives for community participation. NGOs with prior experience in community level waste management will mobilize communities to participate in waste‐segregation and door‐to‐door collection programs and will play
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a role in community awareness raising through information sharing, education and communication programs. Sub‐component 1.3: Construction of Island Waste Management Centers This component will finance the construction of IWMCs as a focal point for island waste management activities, based on the extent and type of community‐level recycling and resource recovery programs in the Island Waste Management Plans. The number of centers to be built will be determined following the Social Assessment conducted under sub‐component 1.1. The community would be involved in managing, operating and maintaining the IWMCs either directly or with the assistance of contract labor. The final footprint of the individual IWMCs would depend on the population size, commercial and industrial activities on the island and expectations of the local community. While the longer term objective is to get community level waste segregation, it is likely that co‐mingled solid waste will be brought to the IWMC and would be separated into organic wastes, recyclables, hazardous (including medical) wastes and residuals requiring final disposal. Site separated waste will be treated appropriately to reduce the volume and pollution load of the residue for ultimate disposal at the RWMF. This sub‐component would also include funding for collection equipment and transport facilities for waste to be brought to the IWMCs, in islands that require it, and for operation of the IWMCs on a declining basis. The Island offices and community contributions will account for operation and maintenance costs after the second year. Communities would retain ownership and responsibility for maintenance of IWMCs and replacement of equipment will be a joint responsibility of the Island Office and the community. Sub‐component 1.4: Waste Transfer System to the Regional Management Facility This sub‐component would finance the procurement of barges or landing craft for the transfer of waste to RWMFs, and of recyclables to markets. Island communities would be expected to contribute some fraction of the costs, with cross subsidies from participating tourist resorts or other local enterprises and the Government to render the system economically sustainable.1 In keeping with the National SWM Policy, private‐sector participation in the operation of the waste transfer service would be explored.
Sub‐component 1.5: Construction and Operation of the Regional Waste Management Facility This sub‐component would finance the construction of one or more RWMF(s) on uninhabited islands or islands with compatible land use, as the case may be, taking the environmental risks into account. The selection of the preferred regional waste management option will be based on a detailed analysis of potentially suitable technology, selection of which will be influenced significantly by the characteristics of the location of the site. These attributes will be evaluated through a weighted process, which is biased towards environmental safeguards, that would finally select the waste management technology and the site through the process described briefly in sub‐component 1.1 known as the Best Practical Environmental Option (BPEO). Land is a premium in the Maldives, even on islands with compatible land use such as industrial islands, while virtually all uninhabited islands are surrounded by continuous coral reefs without harbor access, resulting in the identification of a suitable site to locate the regional waste management facility being a challenge. Due to this constraint, the waste management option selected may be driven by the environmental impacts of the site. Therefore, it is proposed that facilities considered would include engineered controlled 1 The team encountered resistance to the institution of new taxes or fees on resorts from the Ministry of Tourism and Civil Aviation. Currently many resorts transport their residual waste at their own expense to the Malé landfill on Thilafushi. However, they are often able to take advantage of vessels returning to Malé after delivering supplies so that there is savings of transport costs to resorts. It is likely that a contribution by resorts to a reliable pick-up and transfer service would be welcomed and would possibly even yield a net saving for the resorts.
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landfills, incineration of combustible residues and viable waste to energy options designed to reduce the risk of contamination on the island, the surrounding waters and the atmosphere over a 20‐year horizon. The population to be served by the project would be defined when the catchment is identified by the two phase technical and financial feasibility study to be undertaken during implementation. Regardless of the option selected, a disposal site for residue or ash will be needed. The disposal site would be engineered so that the risk of contamination is minimized. Since a majority of the waste will be municipal solid waste, the disposal of the residue wastes or ash in an engineered controlled site is unlikely to pose serious environmental management problems. A section of the RWMF site would be secured and fully contained for disposal of small amount of medical and toxic wastes. The RWMF will be operated by the private sector through a public private partnership, in accordance with the National Policy on solid waste management. Sub‐component 1.6: Biodiversity Offsets to Compensate for Use of an Uninhabited Island for the RWMF If the regional waste management facility has to be located on an uninhabited island, where establishment of the facility would result in adverse impacts to the island ecosystem such as loss and/or damage to terrestrial and marine biodiversity, the project would undertake specific measures to offset the loss of biodiversity and island habitat, should this occur. In keeping with the Bank’s OP 4.04 on Natural Habitats, biodiversity offsets could be a part of the regional solid waste management component. In case such damage is unavoidable, an area with a pristine coral reef and marine environment could be identified based on the work undertaken in the reef surveys of the TA for Regional Strategic Environmental Assessment component, and protected under the project. This would be done through the creation of a program for focal island ecosystems for community based environmental management. Component 2: Capacity Building for Environmental Management The environmental agencies and regulators in the Maldives have a broad mandate, but their capacity to manage growing environmental pressures does not match the needs of a fragile environment on which the economy depends. The proposed project is designed to at least partly fill the staffing gaps and capacity needs areas relating to the project itself. It is recognized that it would be next to impossible to build a large, permanent cadre of environmental specialists with a reach extending over the entire archipelago and across all the sectors. The stress would therefore be on developing (i) a core of competent specialists and generalists in MEEW, other relevant ministries (Planning, Fisheries, Tourism, Atoll Administration and Construction) and in the private sector (particularly NGOs and the tourism sector) to guide the environmental assessment and decision‐making process; (ii) a cadre of service providers to carry out monitoring and field surveillance activities making full use of modern technology to carry out their job, and (iii) a network of private citizens and stakeholders (e.g. fishermen, hotel and dive operators, boat operators and others) with the training needed to serve as the “eyes” and “ears” of the Ministry. Priority would be given to training existing government staff and to others for whom there is a reasonable expectation that their skills could be utilized in the near or medium term. Component 3: Technical Assistance for Regional Strategic Environmental Assessment The objective of this component is to assess the impact of human activities, global warming and other factors on the local environment in the North Central Region of the Maldives. The exercise would gauge changes in key variables such as reef health, biodiversity, beach erosion, all of which eventually impact on the fortunes of tourism and fisheries – the main engines of economic growth. The evidence would allow an opportunity to adopt policies that may slow down or arrest processes that are destructive of the natural capital of the Maldives. The mechanism by which this exercise
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could yield the desired results would be by presenting reliable evidence and focused analysis that could lead to changes in attitude and practice by decision makers and the public in general. For purposes of the proposed project, the regional strategic environmental assessment would provide a framework to demonstrate the utility of incorporating environmental parameters in development decisions. The exercise would be useful in making more informed decisions about key development concerns that are currently faced by the government such as: (i) siting of economic activities (such as tourist resorts, industry, recreational dive sites, fishing grounds, protected areas, “safe islands,” industrial plants, siting of regional waste management facilities and other infrastructure); (ii) natural hazard and risk assessments (including the presence of coral reefs serving as natural buffers in same), focusing particularly on coral reefs, beach erosion, bleaching events and others (iii) identification and eventual reduction of stressors affecting coral reefs, (iv) identification and creation establishment of marine protected areas. This component would place particular emphasis on ensuring that the country’s critical marine assets generally and its coral reefs and underlying natural processes specifically are more fully considered in the aforementioned planning and decision‐making processes. There is little experience in the conduct of RSEA’s in the islands, accordingly this component would proceed on a cautious basis, beginning with an intense process of information collection that would engage communities, raise their awareness and provide inputs for a RSEA. Concurrent with the collection and analysis of data, the project would foster discussion and debate among stakeholders by examining alternative scenarios for regional development. The geographical scope of the component would be the North Central Region composed of Raa, Baa, Lhaviyani and Noonu2 atolls, the latter only partially covered due to its division by an administrative boundary to the north. This region is comprised of a total of 224 islands of which 44 are inhabited and 11 have tourist resorts. The total population is an estimated 42,000. As population pressure and commercial demands grow, there may be increasing pressure on to the reclassify some of these islands to support economic development, particularly tourism. Consumption is also likely to increase as will the risk of contamination from solid and liquid wastes and possible damage from divers. It is important that full information be available to ensure that informed decisions can be taken. The ERC would serve as the implementing agency of the RSEA, with coordinated inputs from other relevant agencies. It would oversee work carried out by all participants and would provide a forum for evaluating development scenarios. A regional committee would be formed with representatives from each of the targeted atolls and some island communities reflecting a cross‐section of community sizes and characteristics. The regional committee would examine various scenarios for the development of the region based on data produced by the Project and other sources. The committee would include Atoll Chiefs and be assisted by a professional facilitator with experience in Strategic Environmental Assessment. The assessment would go through multiple iterations to assure realism and to allow time for consultations with constituent communities. The strategic assessment would issue periodic reports (at least one per year) on the development of the Atolls in the North Central Region with policy recommendations for the government and proposals for further studies and mobilization. The central focus of the RSEA process will be how to assure the continued development of the island communities of the North Central Region in the face of major changes in their environment, namely climate change, resource depletion, infrastructure development, increased consumption, and resort development.
2 Noonu atoll is only partially covered due to its division by an administrative boundary to the north
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To be credible and useful the RSEA would need to be grounded in scientific information and evidence of trends. Accordingly this component would support a parallel process designed to fill critical information gaps in four priority areas identified by GoM and build the technical capacity to sustain the process. Beach Erosion: Erosion of beaches affects well over 90 % of the country’s inhabited islands and is likely to increase in severity over time with climate change associated effects (e.g., sea level rise higher intensity storm surges). It is unclear, but planning decisions in the absence of better data may be a significant source contributing to the problem. On several islands, a significant increase in beach erosion is linked by the islanders to the construction of harbours and sea walls. However, this linkage has not been established conclusively. This activity led by ERC would involve interested local communities in assessing and monitoring beach erosion process events and selected factors contributing to erosion in the North Central Region. These activities would be complemented with a comparative analysis of serial remote sensing images to provide a better understanding of sources and processes contributing to the problem of beach erosion. The study would contribute to the development of planning guidelines (e.g., set‐back zones, coastal zoning, use of natural features for harbor development, jetties for loading and unloading cargo, etc.), and indirectly provide inputs to support increased understanding and quantifying spatial and temporal variations in erosion throughout the Maldives and the causes of erosion. As data are collected and analyzed, regional workshops would be held to examine alternatives to current practices that could lead to a reduction in erosion. Coral Reefs: The project would support community‐based coral reef monitoring supplemented by technical studies focusing on coral spawning and recruitment, coral reef resilience to effects of climate change and recovery from past 1998 coral reef bleaching event. Community‐based management plans for the selected reefs would be supported under this activity. The focus would be on assessing the role of reefs in assuring natural protection against climate risks. This activity will be led by the Marine Research Centre (MRC). Mangroves: Mangroves are an important part of the terrestrial flora of the Maldives. They play a key role in stabilizing the soil and as a buffer against storm surges. The Environmental Research Center (ERC) of the Ministry of Environment, Energy and Water (MEEW) led a successful effort in community awareness and mobilization in mangrove management in Huraa Island in Male Atoll. This effort, conducted in collaboration with the Island Development Committee, led to the declaration of the site as a protected area. Under this sub‐component, this model will be replicated in various islands in the North Central Region. Bait Fishery: The bait fishery is a critical element of the Maldives tuna fishing industry, the second largest export industry of the country. Bait fish are caught in lagoons and reefs close to shore. Technical Assistance would be provided to assess the status of the bait fishery, launch a community‐based monitoring program and provide critical inputs into the formulation of a national bait fishery management plan. Spatial Planning: Currently little weight is given to environmental factors in land‐use planning decisions. The Project would build capacity (technical and human) in the relevant ministries and agencies to promote the integration of environmental parameters in land use planning and land allocation decisions. It would support the purchase of high resolution remote sensing imagery for the North Central Region together with the necessary hardware and software. Training and
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technical assistance would be provided to key agencies (Ministry of Planning and National Development, ERC, MEEW and MRC among others) to build the necessary expertise. To support these activities and assure sustainability and continuity the Project support essential equipment required to generate this information this would include the purchase of hardware and software for GIS analysis, a research vessel, water quality monitoring equipment and current meters.
III. Environmental Policies, Laws, Regulations, Notifications and Traditional Rights The following paragraphs highlight the salient features of select laws which have a particularly important bearing on the design and implementation of the regional solid waste management component and the implementation of the component will comply with the requirements of the following: • National Solid Waste Management Policy • Technical Minimum Standard (TMS01) for the Operation of Large‐scale Dumpsites • Law No. 4/93: The Environment Protection and Preservation Act • Environmental Impact Assessment Regulation, 2007 • By‐law, Cutting Down, Uprooting, Digging Out and Export of Trees and Palms from one island to
another
• Law No. 20/98: Uninhabited Island Management Law • Law No. 5/87: Law on Fisheries • Traditional rights to land National Solid Waste Management Policy GoM announced a National Solid Waste Management Policy on February 3, 2008. The Policy has been prepared to reflect the current status of solid waste management in the Maldives. The policy contains strategic principles that create the underlying logical and philosophical structure of the policy. They also represent universally accepted practices in waste management:
• Polluter pays principle • Integrated solid waste management • Waste management hierarchy • Best Practical Environmental Option (BPEO) • Best Available Technology Not Entailing Excessive Costs (BATNEEC) • Equity • Proximity principle • Private Sector Participation (PSP)
The overall policy framework for solid waste management is condensed into the following five Principle Objectives:
• Establishing and activating waste management governance; • Creating waste producers’ duties and responsibilities; • Establishing waste management infrastructure; • Activating the waste management system; and • Influencing consumer choices and waste management practices.
Under the Principle Objectives are 12 policies and numerous strategies that systematically apply the strategic principles.
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Technical Minimum Standard (TMS01) for the Operation of Large‐scale Landfill This document has the objective of establishing a Technical Minimum Standard (TMS01) for the operation of present landfills in handling, recycling and disposal of waste on a daily basis. The TMS01 will help prevent potential impacts to the environment and public health risks through the sound and environmentally safe management of waste. In addition, the TMS01 will encourage private sector participation by widening opportunities for recycling. Law No. 4/93: The Environment Protection and Preservation Act The Environmental Protection and Preservation Act of the Maldives is concerned with the protection of the natural environment and resources including land, water, flora, fauna, beaches and reefs. Islands with special ecological characteristics have been identified, protected and conserved as no‐take zones under this Act. The Act makes reference to prohibited waste activities like disposing of wastes in the marine environment, disposing of hazardous, toxic or radioactive waste in the territorial waters of the Maldives, and trans‐boundary movement of such wastes elsewhere. Environmental Impact Assessment Regulation, 2007 The Law No. 4/93 on Environmental Protection and Preservation stipulates under Article 5, any development work or project should have an Environmental Impact Assessment consented to by the Ministry of Environment, Energy and Water. The regional solid waste management component will therefore undertake EIAs for the regional waste management facility and Initial Environmental Examinations (IEE) for the Island waste management centers.
An Environment Impact Assessment must be conducted to consider the effects of a development proposal for the following factors:
• Fauna and flora, and living components of the environment; • Soil, water, air, climate, the landscape, and the non living components of the environment; • Material assets and cultural heritage; • Impacts on the project from the environment; and • Impact of human interactions with the project and the environment.
This regulation also deals with the selection of sites or islands for economic and social development by relevant authorities. By‐law ‐ Cutting Down, Uprooting, Digging Out and Export of Trees and Palms from one island to another Pursuant to the Environmental Protection and Preservation Act of the Maldives, the Ministry of Environment, Energy and Water has developed this by‐law in order to educate and guide developers about acceptable practices for the management of trees and palms.
The by‐law prohibits the cutting down, uprooting, digging out and export of trees and palms from one island to another unless there is no other viable alternative. It also requires that for every tree or palm removed at least 2 should be replanted on the same island. The by‐law also provides particular protection to the following:
• coastal vegetation extending 15 metres into the island; • all trees and palms growing in mangrove and wetland areas; • all trees and palms growing in Government protected areas; and • trees and palms that are abnormal in structure.
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Law No. 20/98: Uninhabited Management Law By law, all reefs and their associated habitats are owned by the state. Under this law uninhabited islands are leased out by the government to private individuals or companies. All uninhabited islands and the management of their resources are legally mandated to the Ministry of Fisheries, Agriculture and Marine Resources (MFAMR). The Ministry keeps records of all uninhabited islands along with details of their lessees. The Ministry also keeps known records of ecological characteristics and land cover on such islands. Contracts are drawn up between lessees and are monitored and maintained by the MFAMR. It includes a condition that two trees must be planted to replace every coconut palm or timber tree felled. A timber permit from MFAMR is required for cutting trees on uninhabited islands. Law No. 5/87: Law on Fisheries Coral reef and coastal marine resources are managed by the MFAMR and regulations for the management of reef resources. All types of fisheries and marine activities are permitted and regulated by the MFAMR under this law. Landuse Planning and Management Land management on inhabited islands (apart from the capital island, Malé) comes under the purview of the Ministry of Atolls Development (MoAD). Land‐use planning of inhabited islands is guided by the Ministry of Planning and National Development and Ministry of Housing and Urban Development. Land allocations and registrations are finalized by the MoAD with consultations and necessary approvals from both the MPND and the MHUD and sometimes also from line ministries. There are no traditional governance structures in the Maldives for coastal land and resource use. Local island and atoll offices play a major role, however, in the planning stages of land allocation and management on their respective islands. Locally formed and selected Island Development Committees and Atoll Development Committees play a critical advisory role in land management on inhabited islands. Registered plots of land for housing can be obtained free by any citizen, on demand, on formally inhabited islands where government infrastructure is established. No fees of any sort are levied on land plots allocated for housing purposes. Technically, any citizen over the age of 18 can obtain a plot of land freely in the Maldives for housing purposes. Plots of land on inhabited islands are leased for industrial activities from which the government earns rent. An exception is the recently formed state‐owned enterprise which has acquired reclaimed land for commercial property development. Traditional Rights to Land A large proportion of uninhabited islands are managed under a traditional system called Varuvaa. Under the Varuvaa system land is leased out to individuals not to undertake major economic activities, but to obtain benefits from the island in terms of the coconuts they generate from the islands. However, lessees undertake annual crop cultivation on islands where cleared agricultural land is available. The rents of Varuvaa islands are fixed by the number of mature coconut palms on the island. It should be emphasized that some of these islands may not even have any coconut palms and as such may not generate any effective income.
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The land tenure systems on inhabited islands are complex. Homestead plots are given free of charge. Plot sizes depend on the availability of land, with an average size of 50 x 100 feet. Trees grown on homestead plots belong to the owner and the homestead allotment is inheritable. Goi land refers to a particular area of the inhabited island with special vegetative characteristics. Coconut palms and tree species grown on goi land belong to the government. Goi land is rented to the highest bidder by the Ministry of Atolls Development. The lessee rents smaller plots for farming. In general, the lessee gets 12.5 percent of the income generated by farmers. Faalabba is a land area generally located close to residential areas. Islanders grow coconut palms and tree species with the permission of the Island Office. Half of the trees grown belong to the person who planted them and the other half is the property of the state. Most islands have communal land for the cultivation of annual crops. No rent is charged for cultivation on this land and no standard regulation exists for its use. On some islands plots change hand every year, whereas on other islands farmers can hold the plots as long as they continue cultivation. The complexity of land tenure systems on inhabited islands has serious implications for the development of agriculture.
IV. Environmental Review Capacity of the Ministry of Energy, Environment and Water (MEEW) and adequacy of the Environmental Clearance Process Under Law No. 4/93 Environmental Preservation and Protection Act, the Ministry of Environment, Energy and Water (MEEW) has the responsibility for enforcing EIA regulations, specified under the Environmental Impact Assessment Regulations. The Maldives has a reasonably good experience of implementing the Environmental Impact Assessment process. The Act, as stipulated under Article 5, requires EIAs for any development work or project which has to be approved by the Ministry of Environment, Energy and Water. MEEW has delegated this function to the Environment Research Center (ERC). ERC invites two independent reviewers who are considered experts in the field of the relevant project to submit comments on the quality of the EIA, including the level of environmental analysis undertaken to identify the environmental impacts and concerns of the proposed project and the adequacy of the mitigation measures proposed. The review comments form the basis of the EIA evaluation by ERC and consent is granted with conditions. While technical capacity at ERC is reasonably good, the proposed project will provide training to improve this capability further. The EIA review process appears to be adequate at this stage because independent reviewers used to review the EIA has the required technical expertise to evaluate the EIA satisfactorily. ERC has the responsibility of monitoring implementation of the EIA clearance conditions. Although monitoring EIA clearance conditions could be further strengthened, the Project will support two independent environmental audits in year 2 of operation of the regional waste management facility and at project closure. In addition, clearance of all EIA, IEE/EMPs by the World Bank is a disbursement condition for the respective activities. In order to ensure transparency in the EIA process, the ERC website has all EIAs and the status of evaluation of the EIA at any given time. The EIA clearance conditions are also placed in the website so that civil society can be aware of the environmental and social mitigation measure that are required to be in place during project construction and implementation.
V. World Bank Environmental and Social Safeguard Policies and its Relevance to the Maldives Environmental Management Project, and Compliance with Applicable World Bank Policies, Guidelines and Procedures The World Bank Operational Policies that may require consideration under this Project are as follows:
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• OP/BP/GP 4.01 Environmental Assessment • OP/BP/GP 4.36 Forestry • OP/BP/GP 4.04 Natural Habitats • OP 4.07 Water Resource Management • OD 4.30 Involuntary Resettlement • OP/BP 4.37 Safety of Dams • OP 4.09 Pest Management
The World Bank Performance Standards that may require consideration under this Project are as follows:
• Performance Standard 1: Social and Environmental Assessment and Management System • Performance Standard 2: Labor and Working Conditions • Performance Standard 3: Pollution Prevention and Abatement • Performance Standard 4: Community Health, Safety and Security • Performance Standard 5: Land Acquisition and Involuntary Resettlement • Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource
Management • Performance Standard 7: Indigenous Peoples • Performance Standard 8: Cultural Heritage
The World Bank Environmental Health and Safety (EHS) Guidelines that may require consideration under this Project are as follows:
• Environmental • Occupational Health and Safety • Community Health and Safety • Construction and Decommissioning • Infrastructure
Having considered the applicability of the above policies, performance standards and guidelines, it has been concluded that the operational policies require to be triggered under this Project are OP/BP/GP 4.01 ‐Environmental Assessment and OP/BP/GP 4.04 ‐ Natural Habitats. The Performance Standards triggered under this Project are Performance Standard 1: Social and Environmental Assessment and Management System and Performance and Standard 3: Pollution Prevention and Abatement. The Environmental Health and Safety (EHS) Guideline triggered under this Project is Industry Sector: Waste Management Facilities. Relevance of OP/BP/GP 4.01 on Environmental Assessment and OP/BP/GP 4.04 on Natural Habitats to the Project The purpose of an environmental assessment (EA) is to identify environmental and social consequences of proposed project or subproject components, in order to:
• Ensure the identification of potential environmental issues and social concerns early in the implementation of a proposed project to incorporate necessary safeguards in project design, and determine appropriate mitigation and compensation measures;
• Minimize risks to the project proponent; • Avoid delays and extra costs which may subsequently arise due to unanticipated
environmental and social problems; • Ensure that the concerns of residents and affected communities are addressed; and • Identify the potential for maximizing environmental resource management and socio‐
economic benefits to local communities within the scope of the project.
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The EA should cover physical/chemical, biological, socio‐economic and cultural issues that are likely to arise during the design, construction and operational activities at the Regional Waste Management Facility (RWMF) and Island Waste Management Centres (IWMC’s). Although activities contained in the Island Waste Management Plans that may be financed under the project are unlikely to cause any irreversible environmental impacts, they should be subject to screening criteria in order to determine their reference to EA processes. By reducing the volume of waste that is currently dumped in the ocean the Regional Solid Waste Management Component will have long term beneficial environmental impacts. There is potential for impacts on the environment during the construction and operation of the RWMF and IWMC’s. Any adverse impacts that may arise from these activities need to be identified and addressed through the EA process. Potentially the most serious impacts are likely to occur in the construction and operation of the RWMF. Based on past experience in the Maldives, it is not possible to build the RWMF on inhabited islands due to high population densities, coupled with community opposition. The only available alternative is to construct the RWMF on uninhabited islands or in islands with compatible land use such as industrial island.. Considering the nature, magnitude and scale of potential environmental impacts of the regional solid waste management component, the World Bank has classified the proposed operations as Safeguards category ‘A’. The development of a waste management facility is a Schedule D activity under the Maldives Environmental Impact Regulations, 2007 and will, therefore, require a Full Environmental Impact Assessment. It is unlikely that there will be uninhabited islands with adequate land area to construct a regional solid waste landfill for waste disposal for a 20‐year period. Reclamation of a shallow lagoon surrounding the island is a possible option for expanding the land area in the selected island. Considering the fragile ecosystems in the Maldives, this could result in loss of some areas of coral reef, with potentially irreversible impacts of the marine ecosystem. Considering the environmental damage and the cost incurred for reclamation, there is no likelihood that the project will support this option. In order to minimize the adverse impacts on the coral reef system in an uninhabited island, site selection is critical. Priority would be given to the condition of the reef surrounding the island. Every attempt would be made to select a degraded reef ecosystem, preferably beyond rehabilitation, where the impacts of excavation for a navigation channel for accessing the island will be less significant. An alternative to this may be to incorporate incineration or waste to energy as a regional waste management option into the project. A landfill component for ash disposal would still be required and although impacts on habitat may be significantly reduced, although release of contaminants into the atmosphere will increase significantly. Although the waste stream is approximately 70% organic, it has been observed that not all organic matter is easily degradable. Woody vegetation comprises a large fraction of the organic waste stream and is probably combustible. Separation of the degradable organics for composting at the island level will reduce the moisture content and increase the calorific value of the residue, making incineration or waste to energy possibly a viable option worth considering. Adverse environmental impacts arising from the construction and operation at IWMC’s are not likely to be significant. Approximately 100 IWMC’s have been constructed across the Maldives under previous projects and none have progressed beyond an Initial Environment Examination level decision. Generic Environmental and Social Action Plans (Environmental Management Plans) have
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been developed for siting, constructing and operating IWMC’s [Annex 1]. Standard site selection procedures [Annex 2], designs and specifications [Annex 3] and island waste management planning manual [Annex 4] have been developed to support the Action Plan or EMPs. It is possible that OP/BP 4.04, Natural Habitats may be triggered depending on the final site selection, facility design, and the specific activities that would be carried out at the facility. During the operation phase, poor design or improper management could result in leakage of wastes or leachate into the immediate habitat. World Bank OP 4.04 on Natural Habitats states that the Bank does not support projects that, in the Bank’s opinion, involve significant conversion or degradation of critical natural habitats. Compliance with OP/BP/GP 4.01 Environmental Assessment – Principle Project Components Environmental Assessments will be conducted under provisions of the Government of Maldives’s Environmental Impact Regulations, 2007 and in accordance with the World Bank’s OP/BP 4.01 to identify and mitigate potential adverse environmental impacts arising from the construction and operation of the RWMF and IWMC’s. The Terms of Reference (TOR) for the environmental assessments will be cleared by the World Bank. For the IWMC’s, in order to comply with the World Bank’s OP/BP/GP 4.01, it is proposed to carry out investigations at the level of an environmental analysis, based on a scoping exercise that will identify significant potential impacts and record any pertinent baseline data. The environmental analysis will cover ecological, archaeological, water quality, visual and noise amenity, air quality and social considerations. The form of the scoping exercise shall be compatible with the Generic Terms of Reference for the Preparation of an Environmental Impact Assessment (EIA) prepared in accordance with the provisions of the Environmental Impact Regulations, 2007 [Annex 5].
For the RWMF, in order to comply with the World Bank’s OP/BP/GP 4.01, it is proposed to carry out the EIA in two sequential stages. At the Pre‐feasibility Study phase, investigations at the level of an environmental scoping of shortlisted islands identified with inputs from the Regional Strategic Environmental Assessment process. The scoping exercise will identify significant potential impacts and record any pertinent baseline data, but does not involve an assessment of the data and impact at this time. The environmental analysis will cover ecological, archaeological, water quality, visual and noise amenity, air quality and social considerations. The environmental scoping of shortlisted islands will provide inputs into the Best Practicable Environment Option (BPEO) process. The results of the environmental scoping analysis will be reported at the pre‐feasibility reporting stage and will inform the Final EIA Terms of Reference.
The full feasibility study will be undertaken when: (i) through the BEPO process and has selected the preferred BPEO option, and (ii) the final site selection process has been undertaken which will be informed by the preferred waste management system selection. The full EIA will involve predictive analysis of impacts resulting from the selection of the preferred technology at the preferred site. The Terms of Reference for the final EIA, and the Final EIA will be subject to World Bank safeguards unit review and clearance. Compliance with OP/BP/GP 4.01 Environmental Assessment – Activities undertaken at the IWMCs As specific activities to be undertaken at the IWMCs are yet to be identified, activity specific environmental issues cannot be identified at this stage. In such circumstances, OP/BP/GP 4.01 requires that arrangements be made whereby the project implementing agency undertakes the
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functions of activity screening, Environmental Assessment, review and implementation of Action Plans or EMPs, as determined appropriate. All activities included in the island waste management plans will be the subject of an environment and/or social review as the key management tool for identifying and assessing risk of environmental and social impacts. An outcome of the above environmental and/or social reviews will in most cases be an Action Plan or EMP that is activity specific. While most activities are expected to have generic environmental and/or social impacts that are manageable through environmental management and impact mitigation measures, there may be some activities that may carry a higher risk of environmental and social impacts. Screening processes for activities identified in the IWM Plans will be undertaken with reference to Checklist for Screening of Environmental and Social Impacts of IWM Plan activities [Annex 6]. The screening process is the first step in the EA process. The objective of the screening process is to rapidly identify those IWM Plan activities which have little or no environmental or social issues so that they can move to implementation. Most of the proposed activities are likely to focus on island based waste management activities including, but not limited to, primary waste collection services, island waste management center operation, waste transfer activities, composting, metal recovery, septic sludge removal etc. Although most such sub‐components are unlikely to cause any significant environmental impacts, the screening criteria will determine which activities will require further consideration under the provisions of the Maldives Environmental Impact Regulations, 2007 and the World Bank’s OP/BP 4.01. The Relevance of Performance Standard 1: Social and Environmental Assessment and Management System and Performance Performance Standard 1 underscores the importance of managing social and environmental performance throughout the project life cycle. An effective social and environmental management system is a dynamic, continuous process initiated by project and involving communication between the project implementation agency and the local communities directly affected by the project. A good management system appropriate to the size and nature of a project promotes sound and sustainable social and environmental performance, and can lead to improved financial, social and environmental project outcomes. Compliance with Performance Standard 1: Social and Environmental Assessment and Management System and Performance Taking into account the relevant findings of the Social and Environmental Assessment and the result of consultation with affected communities, the implementing agency will establish and manage a program of mitigation and performance improvement measures and actions that address the identified social and environmental risks and impacts (the environmental management plan). The EMP program will address the following components:
• Summary of Impacts • Description of Mitigation Measures • Description of Monitoring Programs • Institutional Arrangements • Implementation Schedule and Reporting Procedures • Cost estimates and sources of funds • Community Engagement and Consultation; • Disclosure; and
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• Grievance mechanism.
For each of these topics the EMP will (i) define measurable outcomes such as performance indicators, targets, or acceptance criteria, (ii) estimate resources, (iii) allocate responsibilities and, (iv) be responsive to changes resulting from unforeseen events, and the results of monitoring. Environmental Management Plan(s) Where specific mitigation measures and actions are necessary for the project to comply with applicable laws and regulations and to meet the requirements of relevant Performance Standards, an EMP will be prepared. Measures and actions that address identified impacts and risks will favor the avoidance and prevention of impacts over minimization, mitigation wherever technically and financially feasible. Where risks and impacts cannot be avoided or prevented, mitigation measures and actions will be identified so that the project operates in compliance with applicable national laws and regulations etc, and meets the requirements of relevant Performance Standards. Community Engagement and Consultation The Project will be based on a strong participatory approach. The implementing agency will make all reasonable efforts to consult relevant stakeholders in the preparation and implementation of the Project activities. The consultations will be carried out in a way which is appropriate for cultural, gender based and other differences among stakeholders. The implementing agency will initiate these consultations as early as possible, and provide relevant material in a timely manner prior to consultation. The views and needs of the vulnerable groups will be given due consideration. Prior to commencing activities under the regional solid waste management component a social assessment will be conducted to understand the social structure and physical layout of communities, patterns of leadership and relations with formal and informal island networks, economic activities, transportation, current patterns of waste disposal, willingness to pay for improved solid waste management, entry points for community mobilization, and the kinds of incentives to which individuals and communities are likely to respond. It is proposed that the Social Assessment will extend beyond the solid waste management component of the overall project and will provide input into the Regional Strategic Environmental Assessment. Outputs from the Social Assessment will provide inputs into the Environmental and Social Assessments and into the other two components of the Maldives Environmental Management Project. The success of the solid waste management component depends on ensuring community involvement from the early planning stages and participation in the decision making process. Community mobilization will be undertaken early in the project to ensure that the community takes the lead in the participatory planning process resulting in the development of Island Waste Management Plans for each participating island. With inputs from the Social Assessment the community mobilization process will identify those island which will receive island based waste management infrastructure and equipment and which islands can support sub‐project activities. Community mobilization work plans have been developed [Annex 7]. Specific waste management activities to be undertaken at island level as identified in the IWM Plans will be decided by the communities during project implementation. This in turn will determine the composition of waste that is delivered to the RWMF. Community Centered Development (CCD) procurement procedures have also been developed which fully engage the community in the tendering, bid assessment, contracting, contractor oversight and monitoring of IWMC [Annex 8].
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If affected communities are subject to risks or adverse impacts from the project components, the implementing agency will undertake a process of consultation in a manner that provides the affected communities with opportunities to express their views on project risks, impacts, and mitigation measures, and allows the implementing agency the opportunity to consider and respond to them. The implementing agency will ensure that the affected communities are consulted in a meaningful way and be allowed to participate actively in the consultation process. The following overarching best practice principles will apply to consultations undertaken during project preparation and implementation:
(i) prior disclosure of relevant and adequate information, including draft documents and plans;
(ii) begin early in the Social and Environmental Assessment process; (iii) focus on the social and environmental risks and adverse impacts, and the proposed
measures and actions to address these; (iv) be carried out on an ongoing basis as risks and impacts arise; and (v) be undertaken in a manner that is inclusive and culturally appropriate.
Community views on the Project will be broadly canvassed during the Project period. Community consultation processes will be scaled up during the Participatory Rural Appraisal (PRA), and affected communities will be identified and consulted during the EA processes. For communities adversely impacted by the Project or its components, consultation will be iterative and their views will feed into the decision‐making process on matters that directly affect them. The management program will identify entry points for iterative consultation of communities identified as being adversely impacted by Project activities. Disclosure Disclosure of relevant project information will help affected communities understand the risks, impacts and opportunities of the Project. The implementing agency will publicly disclose all Social and Environment Assessment documentation, the management program and action plan(s) for public review and comment in appropriate locations in the Project area. The documentation will also be made available on the implementing agencies web site. Newspaper and other media outlets will alert the community to the availability of the documentation. The website will also enable the community opportunity to provide comment electronically. Documentation will also be made available at IDA’s Public Information Center in accordance with BP 17.50 requirements of disclosure. Grievance Mechanism If the implementing agency anticipates ongoing risks to or adverse impacts on affected communities, the implementing agency will establish a grievance mechanism to receive and facilitate resolution of the affected communities’ concerns and about the implementing agency’s environmental and social performance. The EMP and its management program will establish a mechanism to address concerns raised promptly that is readily accessible to all segments of the affected communities, at no cost and without retribution. Monitoring and Reporting The management program will establish procedures to monitor and measure the effectiveness of the EIAs and EMPs conducted under the project. The implementing agency will use mechanisms, such as inspections and audits, where relevant, to verify compliance and progress toward the
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desired outcomes and will engage qualified and experienced independent experts to verify its performance. The implementing agency will document results of monitoring and mitigation measures, and reflect the necessary corrective and preventive actions in amended management programs. The client will implement these corrective and preventive actions, and follow up on these actions to ensure their effectiveness. The management program will also schedule periodic reporting to external monitoring and reporting missions that describe progress with implementation of the Project, including performance against performance indicators, targets, or acceptance criteria, and estimate resources defined in the management program. The Relevance of Standard 3: Pollution Prevention and Abatement to the Project Performance Standard 3 recognizes that increased industrial activity and urbanization often generate increased levels of pollution to air, water, and land that may threaten people and the environment at the local, regional, and global level. On the other hand, along with international trade, pollution prevention and control technologies and practices have become more accessible and achievable in virtually all parts of the world. This Performance Standard outlines a project approach to pollution prevention and abatement in line with internationally disseminated technologies and practices. In addition, this Performance Standard promotes the private sector’s ability to integrate such technologies and practices as far as their use is technically and financially feasible and cost‐effective in the context of a project that relies on commercially available skills and resources. Compliance with Standard 3: Pollution Prevention and Abatement to the Project During the design, construction, operation of the IWMC’s and RWMF the implementing agency will consider ambient conditions and apply pollution prevention and control technologies and practices (techniques) that are best suited to avoid adverse impacts. Where avoidance is not feasible the implementing agency will minimize or reduce adverse impacts on human health and the environment while remaining technically and financially feasible and cost‐effective. The project‐specific pollution prevention and control techniques applied will be tailored to the hazards and risks associated with emissions. The implementing agency will avoid the release of pollutants or, when avoidance is not feasible, minimize or control the intensity or load of their release. The implementing agency will consider Best Practice Environment Option (BPEO) processes in determining the appropriate RWMF control technology. The process will take account of the following principles when making decisions about the most appropriate pollution control mechanism to be applied at the RWMF:
• Integrated waste management; • Waste hierarchy; • Financial viability; • Technical feasibility; • Best Appropriate Technology Not Entailing Excessive Cost; • Community willingness to accept technology; • Other local issues such as compatibility with climate change adaptation mechanisms; and • Acceptable and applicable performance levels and measures.
The Relevance of Industry Sector EHS Guideline: Waste Management Facilities
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These guidelines apply to the design, construction and operation of facilities for the management of hazardous and non‐hazardous wastes, including landfills and incinerators, and take account of World Bank Operational policies. Compliance with Industry Sector EHS Guideline: Waste Management Facilities
During the design, construction, operation of the IWMC’s and the RWMF the implementing agency will consider the following:
• the location of sites to minimize potential risks from earthquakes, tidal waves, and floods; • the certification of building designs used by a struct
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