integrating environmental management plans into project operational manuals agi kiss safeguards...

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