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SOCIAL FUND FOR DEVELOPMENT Planning and International Cooperation Group

Environmental Policies Program

Environmental Management Plan (EMP)

For

Enhancing Access to Finance for Micro and Small Enterprise

October 2009

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LIST OF ACONYMS AND ABRIVIATIONS EA Environmental Assessment

EDD Environmental Development Department

EDU Environmental Development Unit

EEAA Egyptian Environmental Affairs Agency

EFPs Environmental Focal Points

EMP Environmental Management Plan

EMU Environmental Management Unit

EPP Environmental Policies Program

ES Environmental Screening

ICG International Cooperation Group

LAD Local Area Development

HQEFP Head Quarters Environmental Focal Point

MD Social Fund for Development Managing Director

MEM Monitoring of Environmental Measures

MES Micro Credit Enterprise Sector

MSEA Ministry of State for Environmental Affairs

PICG Planning & International Cooperation Group

PMG Planning & Monitoring Group

REFP Regional Environmental Focal Point

ROs Social Fund for Development’s Regional Offices

SEDO Small Enterprise Development Organization

SFD Social Fund for Development

SMEs Small and Micro Enterprises

TOR Terms of Reference

WB World Bank

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TABLE OF CONTENTS

List of Acronyms and Abbreviations

1. INTRODUCTION 5

1.1 Background 5 1.2 Purpose of The Environmental Management Plan (EMP) 6 1.3 Environmental Assessment (EA) 7

2. POLICY, LEGAL, ADMINISTRATIVE & ENVIRONMENTAL

FRAMEWORK 7 2.1 Regulatory Framework for Environmental Impact 7

2.1.1 MSEA/EEAA Institutional Setup 7 2.1.2 SFD Environmental Program 8

2.2 National Environmental Legislatures 9 2.3 World Bank Environmental Policies 9 2.4 Sub-project Cycle 10

3. POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND MITIGATION PROCEDURES 14 3.1 Negative Environmental Impact & Mitigation Procedures 14

4. ENVIRONMENTAL ASSESSMENT & REVIEW PROCEDURES 16 4.1 Environmental Screening 16 4.2 EEAA Environmental Classification 16

5. PREVIOUS DONORS SUPPORT AND NEEDS FOR CAPACITY BUILDING 17

5.1 Previous Donor Support 17 5.2 Future Needs for Capacity Building 19

6. ENVIRONMENTAL MONITORING & AUDITING 21

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ANNEXES 23 ANNEX A – ENVIRONMENTAL MITIGATION MEASURES FOR MICRO AND SMALL ENTERPRISES WITH POTENTIAL NEGATIVE EFFECTS ON THE ENVIRONMENT 23 ANNEX B – ENVIRONMENTAL SCREENING FORM FOR MICRO AND SMALL SUB-PROJECTS 29 ANNEX C – COMPARISON BETWEEN THE WORLD BANK AND EEAA ENVIRONMENTAL CLASSIFICATIONS 32 ANNEX D – PROPOSED ROLES AND RESPONSIBILITIES FOR DIFFERENT PARTIES THROUGH THE SUB-PROJECT CYCLE 34 ANNEX E – TRAINING PROGRAMS AND CPACITY BUILDING NEEDS ESTIMATED BUDGET 38

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1. INTRODUCTION

1.1 BACKGROUND

This operation provides a credit line through SFD, the apex body for micro and small enterprise finance. SFD would on-lend on commercial terms to eligible NGOs (serving microenterprises) and banks (serving small enterprises). The envisaged allocation of the Bank loan would entail 50 percent to micro enterprises, and 50 percent to small enterprises. This approach is about finding pathways to bring NGOs and potential MFIs into the financial system, helping microenterprises graduate to small modern formal enterprises, and promoting commercial bank lending to small enterprises. Participating NGOs and banks would be selected by the SFD based on institutional capacity, portfolio size and quality, and most importantly, willingness to leverage significantly the volume of credit lines made available by the project.1

Financing from SFD would be disbursed in tranches based on regular monitoring of an agreed set of performance indicators covering disbursement, outreach, quality of portfolio, and proportion of women clients.SFD loans would charge an interest rate to cover SFD repayment to the Bank, its operational expenditures, and foreign exchange risk. SFD has a proven track record as an apex financier of banks and MFIs, with excellent disbursement and reported portfolio quality levels on its microfinance and small enterprise finance portfolio. The design of the credit line will incorporate lessons learned in previous operations in Egypt and elsewhere with respect to pricing, project evaluation, and targeting of end-clients. In order to achieve a significant and sustained development of micro and small enterprises in Egypt, this operation will be complemented by business support services and advisory work on business development. These are offered by the Non-financial Services Unit at SFD, the Small Enterprises Unit at EBI, or through technical assistance and advisory work under other Bank activities and other donors.

The Social Fund for Development (SFD) was established in 1991 according to a presidential decree with the initial goal of creating a safety net to protect vulnerable groups from adverse effects of the economic reform and structural adjustment program. Since then, the SFD’s mandate has evolved to more specifically cover the: (a) creation and finance of micro and small enterprises that are capable of providing sustainable job opportunities, (b) provision of basic infrastructure and public utilities necessary to support project/enterprise development, and (c) promotion of a supporting environment conducive to the improvement of standards of living. The Social Fund for Development (SFD) was established in 1991 according to a presidential decree with the initial goal of creating a safety net to protect vulnerable groups from adverse effects of the economic reform and structural adjustment program. Since then, the SFD’s mandate has evolved to more specifically cover the: (a) creation and finance of micro and small enterprises that are capable of providing sustainable job opportunities, (b) provision of basic infrastructure and public utilities necessary to

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support project/enterprise development, and (c) promotion of a supporting environment conducive to the improvement of standards of living. SFD leads the national program for micro and small enterprises, and currently provides finance to microenterprises and small enterprises. This represents an important clientele, but the numbers financed to date are still modest by comparison with the potential universe of borrowers Moreover, small enterprises served by SFD have on average a very small number of employees. Banks provide some financing to small firms but the volumes are very minimal (amounting to less than one percent of total loans), and primarily through SFD funding and the associated generous guarantee. Banks are still reluctant to engage their own resources to small enterprises finance because of the factors mentioned above.

1.2 PURPOSE OF THE ENVIRONMENTAL MANAGEMENT PLAN (EMP)

This EMP was prepared for the World Bank project “Enhancing Access to Finance for Micro and Small Enterprise”. The primary objective of the proposed Environmental Management Plan (EMP) is to identify the environmental requirements needed to ensure that all micro and small sub-projects are in compliance with the SFD’s environmental inclusion procedures and WB’s environmental safeguard policies. A clear and concise EMP will ascertain that all potential environmental impacts are being addressed effectively for the successful design, appraisal, and implementation of sub-projects. The 2006 EMP – which was cleared by the World Bank - prepared for Local Area Development program (LAD) was used as a reference document for preparing this EMP in hand. However, it was revised and modified to cater the specific focus and relevance of the proposed project. Also the EMP was updated to include the more recent developments and versions of national environmental legislations as well as the existing capacity and institutional structure of the SFD.

The ultimate objective of the EMP is to mitigate the adverse environmental impacts identified in each sub-project. The EMP will consist of three main parts:

• Implementation of mitigation measures; • Strengthening the capacities of the SFD Regional and Head Quarters

Environmental Focal Points (REFPs & HQEFPs). • Monitoring and evaluation of mitigation measures identified during sub-project

assessment and environmental review.

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1.3 Environmental Assessment

Environmental assessment (EA) is a tool that enables the EFPs to assess the negative impacts on the environment and to identify and evaluate the applicability of mitigating measures for potential negative environmental impacts. EA also ensures that:

• The project under consideration is environmentally sound and sustainable;

• Any environmental consequences are recognized early in the development stage and incorporated into the project design;

• The project is implemented with full awareness of environmental factors.

2 POLICY, LEGAL, ADMINISTRATIVE & ENVIRONMENTAL FRAMEWORK

2.1 Regulatory Framework for Environmental Impact

2.1.1 MSEA/EEAA Institutional Setup

In June 1997, the responsibility of Egypt’s first full time Minister of State for Environmental Affairs was assigned as stated in the Presidential Decree no.275/1997. From thereon, the new ministry has focused, in close collaboration with the national and international development partners, on defining environmental policies, setting priorities and implementing initiatives within a context of sustainable development.According to the Law 4/1994 for the Protection of the Environment, the Egyptian Environmental Affairs Agency (EEAA) was restructured with the new mandate to substitute the institution initially established in 1982. At the central level, EEAA represents the executive arm of the Ministry.

The Principal Functions of the Agency Include:

. Formulating environmental policies.

. Preparing the necessary plans for Environmental protection and Environmental development projects, following up their implementation, and undertaking Pilot Projects.

. The Agency is the National Authority in charge of promoting environmental relations between Egypt and other States, as well as Regional and International Organizations.

The Administrative Council of the Agency is in accordance with the "Environment Act of 1994" composed of the Minister of Environmental Affairs as Chairman and the

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following as members:

. The Chief Executive Officer of the Agency, who also acts as Vice Chairman.

. Representatives from the ministries concerned with environmental experts, Non-Governmental Organizations (NGOs), the State Council, the Public Business Sector, the Universities and Scientific Research Centers.

An Environmental Protection Fund (EPF) will in accordance with the "Environment Act of 1994" be set up at the Agency. The Fund will receive the amount specifically allocated to it in the General State Budget by way of support, donations and grants presented by national and foreign organizations concerned with environmental protection, fines and compensation awarded by courts of law or via out-of-court settlements for damage caused to the environment, as well as revenues from the protectorates fund. The financial resources of the Fund shall be exclusively used for the purpose of realizing its objectives.

The Agency will offer incentives to institutions and individuals engaged in activities and projects directed to environmental protection purposes.

2.1.2 SFD Environmental Program

The environmental program was first established in order to respond/comply with a World Bank’s request and loan agreement under SFD III. It was firstly established as an Environmental Development Unit (EDU) in November 1998. The Unit evolved several times, were it became successfully the Environmental Development Department (EDD), then the Environmental Policies Program (EPP). After completion SFD III agreement, SFD decided to keep the EPP as part of the institutional structure of SFD.

After merging the Planning & Monitoring Group (PMG) with the International Cooperation Group (ICG) in January 2009, the EPP has become a central, crosscutting program operating under the Planning & International Cooperation Group (PICG).

The EPP is staffed with the following personnel:

a. Program Director; b. 2 program assistants/coordinators responsible of;

i. Headquarters Environmental Affairs; ii. Regional environmental affairs;

c. 32 Environmental Focal Points (EFPs) from regional offices and headquarters;

d. Administrative Assistant/Secretary.

EPP mandate according to the MD decree no. 37/2004:

• Formulation of environmental policies and ensuring the mainstreaming of such policies into SFD’s activities;

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• Monitoring the implementation of SFD’s Environmental Management Plan and Guidelines Manual into SFD’s Program;

• Formulation of training programs and monitoring the implementation; • Preparation of environmental, policies and monitoring implementation; • Conduct environmental auditing to ensure application of the environmental safeguard

policies; 1. Participate in the Appraisal Committee to ensure the mainstreaming of environmental

policies and guidelines; 2. Coordinate with the Ministry of State for Environmental Affairs; 3. Preparing studies/manuals to promote environmental best practices and compile

annual progress reports.

2.2 National Environmental Legislatures Law 4 for the Protection of the Environment Law 4/1994, has a greater role with respect to all governmental sectors as a whole. The law has been designated as the highest coordinating body in the field of the environment that will formulate the general policy and prepare the necessary plans for the protection and promotion of the environment. It will also, follow-up the implementation of such plans with competent administrative authorities. The laws and regulations covering the governmental sector that can be grouped according to the pollutant emissions from various activities. The Environmental Protection Law has defined the responsibilities of the agency in terms of the following: • Preparation of draft legislation and decrees pertinent to environmental management. • Collection of data both nationally and internationally on the state of the environment. • Preparation of periodical reports and studies on the state of the environment. • Formulation of the national plan and its projects. • Preparation of environmental profiles for new and urban areas, and setting of

standards to be used in planning for their development. • Preparation of an annual report on the state of the environment to be prepared to the

President. o Environmental Law no 4/1994 and its Executive Regulation, for the

Protection of the Environment. o Some provisions of the Executive Regulation of Law 4/1994 were amended

by Prime Minister’s Decree No. 1741 of 2005. o Some provisions of Law 4/1994 were amended by Law 9/2009

2.3 World Bank Environmental Policies

World Bank Safeguard Policies

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The WB’s safeguard policies are used to ensure that the people and the natural environment are not negatively affected by any development process undertaken by the Bank, and in the case that any harm is anticipated, that such harm is mitigated so that the net result is a positive developmental impact on the people and area being served. The safeguard policies are intended to serve, foremost, as guidelines for SFD staff in the identification, preparation, and implementation of WB funded programs and projects with a focus on minimizing negative environmental impacts. The table below highlights the key principles underlining the World Bank’s environmental safeguard policies. World Bank Environmental Safeguard Policies Policy Key Principles Environmental Assessment (OP/BP 4.01)

� All projects proposed for WB financing require an EA to ensure that they are environmentally sustainable.

� Used by the WB to identify, avoid, and mitigate the potential negative environmental impacts associated with WB lending operations.

� Instruments used to perform the EA may include an EA, regional or sectoral EA, an environmental audit, a hazard or risk assessment, and an environmental action plan.

2.4 Sub-project Cycle

This Section will identify the entities concerned with incorporating the EMP into the SFD’s project and sub-project cycle, as well as describe in detail all the parties that shall be responsible for implementing this EMP and ensuring its successful operation. The SFD’s sub-project cycle is illustrated in Figure (1). As in any project cycle, project identification is the first step, which includes identifying the project activities and outputs, and sub-project type, after which the project idea is formulated into feasibility study. The second step is project appraisal and approval. The third step is project implementation in which the project beneficial executes the project, while the SFD supervises the process of implementation. Finally, the last step in the cycle is monitoring, evaluating, and reporting the sub-project’s performance after implementation to determine whether it is keeping with its set objectives.

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Environmental Assessment Process within SFD Sub-Project Cycle The role of EPP will be to incorporate the environmental dimension into the SFD

sub-project cycle. This means that the EPP will be responsible for ensuring that the different environmental issues are considered at the preparation and implementation phases of the SFD sub-project cycle. In addition, HQEFPs and REFPs shall play an important role in monitoring and evaluating the sub-project’s adherence to environmental policies and standards. The REFPs, in particular will bear the greatest responsibility throughout the sub-project lifecycle to ensure the successful implementation of the EMP.

Main elements (steps) of the SFD’s operating system are summarized as follows:

1. Environmental screening and recording of outcomes 2. Environmental classification of sub-projects 3. Environmental review and assessment of sub-projects 4. Appraisal and approval of sub-projects 5. Implementation of sub-projects 6. Monitoring, evaluation, reporting of sub-project’s progress

Environmental Screening and Recording of outcomes Environmental screening is performed during the initial phase of the SFD’s sub-project cycle during which the sub-project is identified formulated and screened. This process helps identify - early in the sub-project cycle - the sub-projects with likely negative environmental impacts so that effective mitigation measues are developed for them.

Figure (1) Sub-Project Cycle

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Accordingly, the sub-project benificial, shall first submit an application to the REFP in the regional office. The REFP shall screen and record the screening process outputs. The REFP shall submit the proper environmental review form – A or B - to the EMU representative to conduct the environmental review for approval or modification in case there were environmental concerns associated with the sub-project that require the preparation of further review. (this topic is further discussed under section 4.1)

Environmental Assessment of Sub-Projects Once screening of the sub-projects is done, a decision on the appropriate category of classification has to be made. For (A) classified sub-projects, besides the completion of the EEAA’s (A) Form, no further environmental review is needed. A limited or partial environmental review shall be required for (B) sub-projects that may potentially pose negative environmental impacts. The sub-project proposal should include abatement measures and any other requirements to ensure compliance with environmental policies and safeguards.

Appraisal and Approval of Sub-Projects The next phase, as per the sub-project cycle, is to appraise and approve the chosen sub-projects. The SFD’s regional office manager shall first examine the sub-project’s eligibility in accordance with SFD’s operational guidelines and mandate. Once this has been cleared, the REFP, with the help of the HQEFP, shall review and verify that all the required sub-project documents, and approvals (including EEAA’s approval) have been completed. In case of sub-projects with potential negative effects, the EPP and/or the HQEFPs should submit any comments and any proposed mitigation and control measures to the appraisal committees for consideration. There are three possible outcomes from the appraisal phase, namely:

� acceptance of the sub-project, � request for modifications, additional information, or complete or partial revisiting

of the sub-project documentation, or � rejection of the sub-project.

Upon approval by the appraisal committees, the sub-project shall move to the implementation and then operation phases. In case there are some requested modifications or additions, the sub-project will go back to the regional office where it will be given back to the benificial for completion and amendment. If the sub-project is diapproved, it may also go back to the regional office for a final revisting and investigation of the reasons of diapproval. It is worth mentioning that if the sub-project location is changed, the sub-project benificial is required to modify the study and submit a new environmental review form for the new area, and the EPP will need to appraise the sub-project once again to ensure

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that the required mitigation measures are considered within the sub-project feasibility study and budget.

Implementation and Operation of Sub-Project Following project approval, the next step in the sub-project cycle is implementation. During the implementation phase, the sub-project benificial shall be responsible for guaranteeing compliance with environmental safeguard policies and with the mitigation measures referred to in the environmental approval (review form). These measures shall be monitored through quarterly reports prepared by the REFP, who will be responsible for performing periodic follow-up to ensure that the sub-project is in compliance. In the mentioned quarterly reports, it is important to incorporate the mitigation measures, supervision plans, and monitoring arrangements specified in the EMP, problem areas and corrective actions has also to be addressed. The SFD is going to develop a standard set of environmental clause to be included in each contract/agreements, which will be further customized according to the different natures of sub-projects. It should be noted that the SFD’s newly established regional one stop shops “Services Complexes” shall be responsible for facilitating the process of obtaining permits, approvals, and various paper work from different competent administrative authorities on behalf of beneficiaries of micro and small enterprises nationwide.

Monitoring, reporting and evaluation of Sub-Projects The final phase of the sub-project cycle is the monitoring and evaluation of the sub-projects. Throughout the implementation and operation phases, sub-project monitoring shall be undertaken on a periodic basis by the REFPs. Monitoring will be undertaken mainly to verify that the sub-project activities have been effectively implemented with respect to quantity, quality, timeliness and adherence to the measures set by the environmental policies. The REFPs shall establish a system in which the data collecetd from the quarterly reports is fed into a software program. This will allow the focal points to internally monitor the sub-project’s progress and evaluate its performance. The REFPs shall also be responsible for presenting a quarterly progress resport on the performance of all the sub-projects under his/her direct supervision. The EPP shall compile the different progress reports from all the regional offices into an annual report that describes the status of environmental compliance with the regulations and environmental safeguard policies. This report shall be submitted to the SFD’s Managing Director (MD) and Policies Committee for review.

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3 POTENTIAL SIGNIFICANT ENVIRONMENTAL IMPACTS AND MITIGATION PROCEDURES

3.1 Negative Environmental Impact & Mitigation Procedures

Micro and small enterprise have limited-if any-negative impact on the surrounding environment. The small portion of these enterprises that might have potential negative effect include; agrochemical production, metal plating, textiles, brick making, automobile repair shops, tanneries and small-scale mining. The key impacts associated with these micro and small sectors are:

• Improper disposal and growing use of harmful substnces such as pesticides and chemicals.

• An ever-increasing number of micro and small enterprises competing for diminishing resources and space.

• In urban areas, the inappropriate lication of micro and small enterprises and subsequent contribution to overcrowding and pressure on infrastructure such as water and sanitation services.

(in the following page an example of potential negative impacts for micro and small sub-projects)

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Environmental Impacts Associated with Some Micro and Small Enterprises

Sector Environmental Impact

Tannaries

Textile dying and crafts Agriculture and aquaculture

Brick making

Metalworking and electroplating Ceramics manufacturing Mining Automobile and motor repair shops

Foundries

Paint and print shops Food processing (grains, sugar milling, edible oils, milk processing, coffee) Wood processing (fumitory, construction materials) Livestock operations Household chemical products (soap, detergents) Small-scale transportation Leather works (shoes, leather products) Mattress industry Lime kilns

Release of and exposure to toxic effluents.

Release of and exposure to toxic effluents; use of toxic products. Misuse of agro-chemicals; land degradation, non-point source pollution. To soil erosion; exposure to particulate matters and fumes; release of ashes into waterways. Release of toxic effluents. Use of glazes based on heavy metals and corosive acids. Toxic effluents. Inappropriate disposal of used oils, batteries, sludge, and other toxic wastes. Air pollution from gases, metal fumes, organic solvents and dust; solid wastes. toxic effluents and wastes. Potenciallydangerous wastewater and organic wastes; air pollution (particulate matter); odor.

Use of toxic materials (glues and paints) in production process.

Giochemical effluents; human exposure to diseases. Toxic, corrosive effluents.

Air pollution from old and poorly maintained vehicles. Solid wastes; chemical handling; toxic effluents (dyes, chemicals).

Solid wastes Air pollution, solid wastes.

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4 ENVIRONMENTAL ASSESSMENT & REVIEW PROCEDURES 4.1 Environmental Screening (refer to Annex B)

This step is performed to help assessing which of the proposed micro or small sub-projects present potential negative impact on the environment. The screening form also help in classifying the proposed sub-project into one of three categories that are going to be explained in the following sections. If the screening process indicated potential negative impact, an environmental review form need to be used to assess the sub-project’s activities and its impact on the surrounding environment and to address what mitigation measures should be taken into consideration during the implementation and operation of the sub-project. The screening form will help SFD consider several variables, including the nature of proposed activities, their magnitude, scale, location, duration and extent of impact, and the environmental context.

4.2 EEAA Environmental Classification (refer to Annex C)

Classification (A) � Projects having minor environmental impacts. � The project proponent is required to fill “Environmental Screening Form A”. � There is no requirement for any environmental assessmnt or follow-up. � Examples of such projects include: training, insitutional capacity building,

awareness, and provision of training centers with equipment.

Classification (B) � Projects having limited environmental impacts. � The project proponent is required to fill “Enviornmental Screening Form B”. � The project proponent may be required to conduct a scoped EIA on certain

identified impacts/processes. � Category (B) sub-projects represent the highest percentage amongst SFD’s total

sub-projects. Examples of such projects include: construction of health units, clinics, medical research centers, roads, bridges, and water supply projects.

Classification (C)

� Projects having significant environmental impacts. � The project proponent is required to conduct an integrated Environmental

Assessment and periodic follow-up to ensure that the project is complying with environmental specifiations and laws.

� Examples of such projects include: sanitary dumpsites, health care waste management in urban and rural areas, and sanitary drainage in urban and rural areas.

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5. PREVIOUS DONOR SUPPORT & NEEDS FOR CAPACITY BUILDING

5.1 Previous Donors Support

a. European Commission EC grant of LE 21 million:

On-the-job training was provided to EPP –Environmental Development Department EDD at that time-on project proposal preparation, contracting and implementing projects including; removal of municipal solid waste accumulation in eight governorates, training on operation and maintenance of desalination units in North Sinai, municipal solid waste management in South Sinai, residual agricultural waste management in Behaira and improving environmental and health conditions in Sharquia.

b. Netherlands grant of LE 2.6 million:

1. Implemented 36 awareness workshops-in 27 governorates and

headquarters-for audience who included; executive and popular councils representatives, technical directorates representatives, civil society, SFD funded project managers, SFD regional managers and employees. Topics included; environmental development, environmental laws and legislatives, solid waste management, environmental awareness, air and water pollution, municipal & industrial wastewater treatment in addition to region-specific problems. 1000 participant benefited from the above mentioned awareness campaign.

2. Preparation of environmental guidelines for the main SFD programs, including: public works, community development, small projects, human resource development and technical support center. Three workshops were conducted to incorporate the guidelines into SFD programs, participants included; program manager, consultant representative, EDD manager and responsible officer, EEAA representative and two regional offices representatives.

c. World Bank technical support:

1. World Bank offered training program “Cost of Environmental Degradation” to EDD manager and members (total five participants), the program lasted for one week.

2. World Bank grant of L.E. 750 K: Two projects were implemented through SFD III agreement funded by the; 1. first project: “Mainstreaming of Environment into the SFD Project

Cycle & Capacity Building of SFD and its Clients”: three training modules were prepared through this project and five workshops were conducted to train participants on environmental management in its different phases (planning-implementation-follow-up and monitoring),

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119 participants received the training including; EFPs, RBOs and EMUs representatives, projects managers and NGO’s representatives for projects funded by SFD.

2. Second project: “Institutional Capacity Building & Environmental Management in Luxor City”: newly graduate youth were involved in this project by forming “ National Working Teams” (NWTs), were each team consisted of 3 members - from local university graduates -the team members were trained by the consultant on data collection, entry and analyses. A strategic planning unit (SPU) was created through the project and staff was selected from the NWTs and trained to operate and update the GIS software that was produced as one of the project deliverables. 30 local youth graduates benefited from this program.

Existing Organizational Setup and Management Procedures for the EPP The EPP shall be responsible for ensuring that the SFD’s operations and activities comply with environmental safeguard policies and legislations. Organizationally, the EPP shall continue to be affiliated to the Planning and International Cooperation Group of the SFD. Instead of depending on big number of permanent staff within the EPP, the EFPs is currently depending on HQEFPs and REFPs. Training and capacity building of EPP staff and EFPs on the headquarters and regional levels should overcome any gaps in the existing organizational structure. This structure shall facilitate the implementation of the assignments, guarantee the smooth flow of work, while avoiding any overlapping of responsibilities and will attempt to clarify lines of authorities and coordination methodologies between different departments.

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Figure (2) illustrates the existing organizational structure of the EPP.

5.2 Future Needs for Capacity Building

Although the SFD’s EMP provide sufficient framework for complying with the environmental laws and regulations, there is always a need for improvement and technical support, especially in the areas of technical assistance and capacity building for the micro and small enterprise-lending program. It is believed that technical assistance and capacity building would improve the performance and build upon achievements of SFD/EPP and would secure sustainable benefits to the micro and small enterprise lending program, and other SFD activities in general. Capacity building programs that could benefit SFD’s environmental staff are outlined hereinafter: • Environmental Strategic Planning:

Currently, the corporate strategy and environmental strategy are separate documents.

The separation between the two strategies makes it hard to incorporate the environmental dimensions on the agreements level. The existing mechanism provides adequate procedures to incorporate the environmental aspects on the sub-project level only, while in the corporate level it is essential to integrate those aspects from the very beginning (agreement level). Having this integration at all levels will insure the proper analyses,

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conclusion and action towards environmental impacts that would take place as a result of implementing micro and small enterprise activities.

This activity is to include revising the corporate (SFD) strategy and to prepare an updated version of the strategy that integrates the environmental policies and safeguards in all components of the strategy (vision, mission, objectives…etc.). This activity should be outsourced with assistance and supervision from EPP. Participation is going to be acquired from all SFD groups. The hired consultant shall be requested to offer training and capacity building to EPP and EFPs staff along the preparation of the strategy. • Annual Reporting on the Environmental Effectiveness of the EMP for SFD’s

Programs, especially as it relates to the micro and small enterprises:

At present, when a subproject is submitted to SFD for funding, the assessment of the project proposal-in most cases-is limited to the geographical (physical) boundaries of the project; it is not a common practice to take the interaction between the project and the surrounding environment into consideration. Reporting on the environmental effectiveness of the EMP - specially the base line reporting - would secure the minimum level of consideration of the reaction that would take place between the sub-project and the surrounding environment. Acquiring this valuable information before deciding on funding a sub-project will help taking the right decision, mitigating any negative impacts and increase the positive impacts of the sub-projects on the surrounding environment and society.

In this activity participants from different levels would be trained, following staff and activities are suggested:

a) Regional offices EFPs are going to: 1. Be trained to prepare baseline reports for areas where projects are going to be

implemented, these reports to be used as reference to evaluate the effect of implemented activities.

2. Use the forms - regarding the progress of activating the environmental policies - and compile data from the field and on the subproject level (quarterly progress reports).

b) Headquarters EFPs are going to be trained to include environmental data on the groups level (quarterly progress reports).

c) EPP Director and members are going to be trained on compiling data from regional and headquarters EFPs and preparing the “State of Environment for SFD Funded Projects” final annual report.

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• Environmental auditing:

o Target participants are EPP staff and selected EFPs on the central and regional levels.

o The selected members are going to be trained to be certified environmental auditors.

o These auditing skills are going to be so valuable for continuous modification of the EPP operation and enhancing the mitigation measures for potential negative impacts of micro and small enterprise sub-projects.

6. ENVIRONMENTAL MONITORING & EVALUATION Monitoring, reporting and evaluation of Sub-Projects The final phase of the sub-project life cycle is the monitoring and evaluation of the sub-projects. Throughout the implementation and operation phases, sub-project monitoring shall be undertaken on a periodic basis by the REFPs. Monitoring will be undertaken mainly to verify that the sub-project activities have been effectively implemented with respect to quantity, quality, timeliness and adherence to the measures set by the environmental policies. The REFPs shall establish a system in which the data collecetd from the quarterly reports is fed into a software program. This will allow the focal points to internally monitor the sub-project’s progress and evaluate its performance. The REFPs shall also be responsible for presenting a quarterly progress resport on the performance of all the sub-projects under his/her direct supervision. The EPP shall compile the different progress report from all the regional offices into an annual report that describes the status of environmental compliance with the regulations and safeguard policies, including problem areas and lessons learned. This report shall be submitted to the SFD’s Managing Director (MD) and Policies Committee for review and as a tool for decision making. (Refer to the monitoring indicators table hereinafter)

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Monitoring Indications and Frequency of Conducting Monitoring for Micro and Small Sub-projects

Environmental Impact Monitoring Indicator Monitoring Frequency

Air Pollution Noise Odors Dust Smoke Pollutants (i.e.CO, NOx. And SO2) Asbestos Paint containing lead

Annually

Water Pollution Electrical Conductivity BOD – COD E-Coli Nitrates

Annually

Soil Pollution Oil Wastewater Solid Waste

Annually

Cultural Heritage and Property

Number of identified cultural property within sub-project vicinity Administrative procedures to ensure safeguarding of cultural property

Annually

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ANNEXES

Annex A – Environmental Mitigation Measures for Micro & Small Enterprises with Potential Negative Effects on the Environment

Activity Environmental Impact Mitigation measures

Food processing, except dairy products, oils, and sugar

Textiles, leather, footwear

Paper articles, printing, and photography

Manufacture of jewelry and glass

� Less water availability � Risk of food poisoning � Increase in solid wastes

� Noise � S� I

� O

� Chemical and lead contamination

� P

� Chemical contamination � Health risks for operators

and surrounding community

� Conserve water � Enforce strict hygiene practices;

use raw materials free from chemical residues; minimize use of preservatives and coloring agents; manage organic waste

� Require use of masks and ear plugs by exposed operators

� Follow special timetables to reduce impact on neighbors

� Follow strict maintenance and lubrication practices for the moving parts of equipment

� Use suitable ventilation systems in workshops, including fans and extractors

� C� E

� E

� Require use of protective equipment, such as masks and gloves

� I

� E

� E� A

� R

� P

� U

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Manufacture an repair of household appliances, musical instruments, except batteries

restaurants

Inshore fishery

� Noise � Contamination from metal

particles and substances, such as glue, oils, solvents, and coolants

� Waste dumped into sewers

� Biological and chemical contamination from food handling

� Increase in solid and liquid wastes

� Increase in demand for potable water and power

� Accidents from improper use of electric devices

� Contamination of beaches and ports from fuel and oil spills and organic waste

� Deterioration of habitats and species

� Suitable manage substances, including safe storage and use of masks, gloves, and protective clothing

� Suitable maintenance and lubrication of equipment

� Insulate the noisiest equipment � Establish special hours of work

that do not disturb the neighbors � Minimize the use of toxic

substances � Require that operators use

protective gear, such as earplugs � Establish contingency plans for

work accidents � Reuse and recycle raw materials � Provide trash collection and

disposal services in localities where micro and small enterprises are installed

� Require use of masks and gloves, continuous cleaning of old containers, and hygienic practices

� Was products thoroughly; do not use foods that fail to comply with health authority requirements

� Recycle; dispose of trash in authorized dumps; minimize use of packaging

� Employ basic water and energy conservation practices

� Train staff on industrial safety practices

� Establish contingency plans for work accidents

� Establish order and cleanliness in operations; carefully maintain motors

� Observe fisheries regulations, such as closed seasons

� Observe strict regulations governing location

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Livestock farming and slaughter

Dairy product manufacturing

Tanning and dying leather

Manufacture of carpets and rugs, textile dying, and printing

Battery manufacture and repair

� Chemical contamination from ingestion of fodder, water, or other contaminated food

� Odors and biological contamination by insects and rodents

� Waste and contaminated water in slaughterhouses

� Biological contamination from pathogens, chemical residues, or heavy metals

� Organic, solid, and liquid waste

� Odors

� Chemical contamination from heavy metals such as chrome, mercury, and sulfides

� Biological contamination � Strong odors

� Chemical contamination from organic and synthetic waste

� Increase in waste

� Contamination from acids and heavy metals

� Risk of explosions and fires

� Employ comprehensive feeding management with minimum use of chemicals

� Require use of protective equipment, such as gloves and masks, and follow strict hygiene standards

� Recycle

� Practice good hygiene in milking and bottling; pasteurize milk

� Recycle whey in agricultural operations or barnyard animals; recycle water used in cooling and cleaning; treat liquid waste to neutralize it and reduce the organic load

� Require adequate supervision during disposal of whey and washing equipment

� Minimize the use of chemicals; recycle liquid waste; minimize the amount of water used in processes; install small treatment plants

� Carefully manage organic sludge

� Require use of protective equipment in the shop; minimize the use of toxic substances; manage volatile gases

� Re-circulate and manage waste; recycle

� Require use of safety equipment � Install efficient ventilation

systems that do not pose risks to surrounding neighborhoods

� Establish contingency plans and adequate training for operators

� Carefully manage gases produced � Promote safe recycling systems;

bolster public trash collection and disposable services

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Sawmills, manufacture of furniture and other wood products

Manufacture of straw hats

Gas storage and distribution

Manufacture and sale of chemicals, including medicines

� Noise � Pollution � Increased waste

� Contamination from sulfur gases used in bleaching and strengthening straw

� Injuries and incorrect work posture

� Poisoning or asphyxia of operators, clients, and neighbors from gas leaks

� Risk of fire and explosions

� Contamination of operators, neighbors, and clients from residues, waste, and gases produced in mixing, bottling, and packing processes

� Risk of fires and explosions

� Residues including toxic substances

� Management and certification � Maintain equipment � Insulate � Require use of protective

equipment, such as masks, gloves, and ear plugs

� Recycle; minimize waste production

� Employ safety practices, including requiring the use of protective equipment, such as masks, gloves and protective clothing

� Install adequate ventilation systems

� Design suitable areas for work

� Strictly monitor tank conditions with continuous inspections

� Install adequate ventilation around tanks

� Use care in handling cylinders � Establish contingency plans for

fires, explosions, and work accidents

� Regularly check function of fire extinguishers

� Require use of protective equipment, such as masks, gloves, and protective clothing; post warning signs in work and sales areas

� Install suitable ventilation equipment

� Establish contingency plans for fires, explosions, and work accidents, and regularly check function of fire extinguishers

� Install independent waste minimization system; reuse and recycle scrap

27

Manufacture of ceramics, porcelain, plaster, and tiles

Manufacture of clay, brick, and tile for the construction industry

Construction work, including handling and processing plastering, concreting and lime components

� Contamination from the use of lacquers, paints, dyes, glues, and finishes containing toxic materials, particularly lead

� Increased waste � Risk of fires and explosion

in the firing process

� Erosion caused by extraction of clay soils

� Deterioration of the rural landscape

� Flow reduction and pollution of public watercourses

� Chemical contamination from firing gases

� Air pollution from dust from handling and processing construction materials

� Solid and liquid waste

� Require use of protective equipment, such as masks and gloves

� Avoid using lead in manufacturing products; use vegetable dyes when possible; use labels to identify each substance; establish contingency plans for work accidents, fire, and explosions

� Minimize waste; reuse and recycle; seal industrial waste in proper containers

� Employ strict industrial safety practices; regularly check function of fire extinguishers

� Manage land and water carefully to avoid spills; use land reclamation techniques, including conservation of plant cover, land filling, remodeling topography, water storage, and recycling

� Plant foliage to mask the excavations

� Employ water management techniques, such as canals and sedimentation ponds; establish agreements with potential users of public watercourses

� Require use of protective equipment, such as masks, gloves and protective clothing

� Use filters and electric kilns to reduce impact on nearby residents

� Keep materials moist whenever applicable, use of gloves and masks

� Use drainage and recirculating system for processing water; separate solids and liquid waste; install settling tanks in the facility to protect the sewer system

28

Manufacture of rubber products

Manufacture of metal products, except for electroplating

Automobile and motorcycle repair

� Contamination from combustion process

� Increased waste production

� Risk of fires

� Air pollution from smelting, welding, and painting process

� Pollution of water, soil, sewer systems from spills of solvents, paints, or metals

� Noise from cutting, lathing, and polishing processes

� Contamination from toxic substances, oil, fuel, and lubricants

� Noise from operating vehicles, hammering, and polishing

� Traffic congestion due to obstruction of public space by improperly parked vehicles

� Install air extractors and filters � Require use of protective

equipment, including masks, hard hats, and gloves

� Introduce practices for reuse, recycling, or sale to other manufacturers

� Establish contingency plans for fires and regularly check function of fire extinguishers

� Employ industrial safety measures, and require use of protective equipment, such as hard hats, masks, gloves, and ear plugs reduce noise by regularly adjusting and lubricating machinery; establish suitable working hours

� Install filters and extractors � Ensure cleanliness and order in

shops and suitable handling of materials

� Recycle waste � Establish contingency plans for

fires, explosions, and work accidents; regularly check function of fire extinguishers

� Employ energy-saving measures

� Employ industrial safety procedures, and require use of protective equipment, such as earplugs

� Practice waste management techniques that minimize water use; sell scrap

� Work in closed installations and follow strict work hours to reduce impact on neighbors

� Observe regulations governing urban zoning and protection of public spaces

29

30

Annex B – Environmental Screening Form For

Micro & Small Sub-projects

(This form is to be used ONLY for industrial and production activities) Code number :……………………………………………………………………………… Name of REFP :……………………………………………………………………………. Place and date of processing :……………………………………………………………… Is this category of MSE, in general, expected to have potential negative impacts? ……………………………………………………………………………………………… ……………………………………………………………………………………………… ………………………………………………………………………………………………

A. GENERAL INFORMATION 1. Name of & owner 2. Address 3. Activity 4. Location of the enterprise (city, markaz, mother village, satellite village…etc.) 5. Area : (a) rural (b) urban (c) semirural 6. Zone : (a) industrial (b) residential (c) commercial

B. GENERAL DESCRIPTION OF THE ENTERPRISE

7. Number of employees (including family members) 8. Use of the premises : (a) workshop-hose (b) workshop-store (c) workshop

only 9. Products manufactured in order of importance 10. Services provided for clients 11. Machinery and equipment used (number of units, types, age in year) 12. The company performs the following activities : gluing, painting, polishing,

dying, stamping, smelting, welding, applying lead, typesetting, diluting acids, tanning, washing, rinsing, washing, galvanizing, etc. (mark the performed activity)

C. POSSIBLE IMPACTS ON PERSONNEL AND FAMILY

13. What raw materials and other inputs are used (glues, solvents, catalysts, preservatives, etc.)? What quantities are used each month?

14. Do you know if any of the products used contain toxic substances? If so, what are the products and the toxic substances they contain?

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15. Are combustibles kept out of the sun? 16. What other precautions do you usually take at your workplace to prevent

injury to health? 17. Do your employees use protective gear (mark the equipment used)? (a) masks

(b) goggles (c) earplugs (d) hard hats (e) gloves (f) protective clothing (g) respirators (h) boots

18. Do you have first aid equipment? Yes ( ) No ( ) 19. Who knows how to use the first aid equipment? 20. Do you have a properly charged fire extinguisher? Yes ( ) No ( ) 21. Do you and your employees know how to use it? Yes ( ) No ( ) 22. If you use substances that could be harmful to health do you keep them in a

safe place out of the reach of children? Yes ( ) No ( )

D. IMPACT ON WATER RESOURCES 23. Is there potential for contaminating ground water with oil or chemical spills

from your operation? 24. Could your operation result in degradation or contamination or ground or

surface water? 25. Does your used water contain contaminating substances? Please list them

(none, alkalines, acids, coloring agents, oils, poisonous substances, etc.) 26. How do you dispose of your liquid waste (acids, oils, toxic substances, etc.)?

a. Pour it untreated down the drain b. Treat it prior to pouring them down the drain c. Dump it on the ground d. Place it in the garbage in sealed containers e. Reuse it f. Sell it or give it away for recycling

27. If you have a system for the treatment of liquid waste or used water, please describe it.

28. Where do you dispose of waste? (a) down the drain (b) in a ditch or river 29. Do you create areas of standing water?

E. POSSIBLE IMPACT ON CONSUMERS

30. Do the products you make contain any toxic substance that could pose a risk to consumer health? If so, have you affixed a warning to the packaging? Have you posted warning notices in your premises?

31. Are your inputs, products, or processes registered with the competent authorities? (permits for certain substances)? Please list them.

F. POSSIBLE LOCAL NOISE, AIR AND SOIL IMPACTS 32. Is there housing nearby? Yes ( ) No ( ) 33. Do you produce noise that disturbs your neighbors? Yes ( ) No ( ) 34. Do you have a noise-reduction system? 35. Does your operation produce gas or foul odors that affect neighbors? If so, do

you use any system to attenuate them? Please describe. 36. Do you work during the night? Yes ( ) No ( )

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37. Do you have trash collection? Yes ( ) No ( ) 38. If not, how do you dispose of your trash? (a) burn it (b) bury it (c) dump it in a

river 39. Does your trash contain chemical waste? Yes ( ) No ( ) 40. Do you reuse or sell any of your scrap or waste? Yes ( ) No ( ) 41. Could your operation result in degradation or contamination of soils? Yes ( )

No ( )

G. CLEANER PRODUCTION 42. Do you follow standard “good housekeeping” procedures that reduce waste,

minimize accidents, and reduce costs? Yes ( ) No ( ) 43. Have you assessed your facility for cleaner production possibilities? Yes ( )

No ( ) 44. Are you aware of the cost of waste produced by your operations, and the

potential cost savings of reducing the waste? Yes ( ) No ( ) 45. Is your enterprise using substantial amounts of resources that are becoming

less and less available, and more and more expensive (e.g., clean water, fuel wood, etc.)? Yes ( ) No ( )

H. COLLECTIVE IMPACTS

46. Are there other facilities in the nearby community that are also polluting the air, water or soil? Yes ( ) No ( )

I. ADDITIONAL INFORMATION OR COMMENTS

……………………………………………………………………………………… ……………………………………………………………………………………… ………………………………………………………………………………………

I formally declare the above information to be true.

__________________________________________________________________ (Signature of the micro/small benificial)

COMMENTS BY THE REGIONAL OFFICE

……………………………………………………………………………………………………...... ……………………………………………………………………………………………………….. ……………………………………………………………………………………………………….. _______________________________________________________________________________ (Signed by the REFP)

33

Annex C - Comparison between the World Bank and EEAA Environmental Classifications

Project

Category EEAA Classification World Bank Classification

Category A A proposed project is classified as Category A (White List) if it is likely to have minor environmental impacts. The project proponent has to fill in the Environmental Screening Form A.

A proposed project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive (i.e. irreversible). These impacts may affect an area broader than the sites or facilities subject to physical works. EA for a Category A project examines the project’s potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the “without project” situation), and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. For a Category A project, the borrower is responsible for preparing a report, normally an EIA (or a suitably comprehensive regional or sectoral EA) that includes, as necessary, elements of the other instruments.

Category B A proposed project is classified as Category B (Grey List) if it is likely to have substantial environmental impacts. The proponent has to fill out Environmental Screening Form B. The procedure consists of two stages: (1) screening (filling out Form B) possibly followed by (2) a scoped EIA on certain identified impacts/processes.

A proposed project is classified as Category B if it’s potential adverse environmental impacts on human populations or environmentally important areas—including wetlands, forests, grasslands, and other natural habitats—are less adverse than those of Category A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigation measures can be

34

designed more readily than for Category A projects. The scope of EA for a Category B project may vary from project to project, but it is narrower than that of Category A EA. Like Category A EA, it examines the project’s potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance.

Category C A proposed project is classified as Category c (Black List) if it is likely to have significant environmental impacts. The establishments / projects in the Black List are required to complete an EIA due to their potential impacts

A proposed project is classified as Category C if it is likely to have minimal or no adverse environmental impacts. Beyond screening, no further EA action is required for a Category C project.

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Annex D - Proposed Roles and Responsibilities for the Different Parties throughout the Sub-Project Cycle

Execution Parties Identification, Preparation,and Planning Phase Appraisal and Approval Project Implementation Monitoring and

EvaluationEPP � Provide technical

support to SFD’sdifferent departments onenvironmental issuesthrough supplying themwith the relevant lawsand legisaltions as wellas the environmentalsub-project classificationlists (A-B).

� Provide information onbest practices forenvironmentalmanagement and control

� Participate in the sub-project assessmentcommittees to assess: (1)the potentialenvironmental impactsduring the constructionand operation phases ofthe sub-projects, (2)mitigation measuresandenvironmentalmonitoring, (3)environmentalmanagement plan for thesub-project, if available.

� Recommend the

� Make sure all sub-projectdocumentation iscomplete.

� Submit comments,if any, on sub-projectdocumentation tothe appraisalcommittees.

� Provide technicalsupport andtraining to SFDdepartments andbeneficiaries(sponsoringagencies /implementingagencies) on themeans by whichthey can conductself-screening ofenvironmentalindicators.

� Disseminateinformation onenvironmentalissues and anyother relevant sub-projectdevelopments.

� Draft an annualreport thatdescribes the sub-projects’ status ofenvironmentalcompliance withWB and EEAAenvironmentalpolicies andlegislatures.

36

Execution Parties Identification, Preparation,and Planning Phase Appraisal and Approval Project Implementation Monitoring and

Evaluationcommittees approval onthe sub-projects whichenvironmentally complywith the WB policiesandSFD’s standards andaccepted legislativeframework.

Different SFDDepartments

� Utilize the informationand publicationsprovided by EPP forpromoting environmentaland social awarenessamongst SFDbeneficiaries (sponsoring/ implementingagencies).

� Whenever necessary,direct SFD Beneficiaries(sponsoring /imlementing agencies)to EPP for additionaltechnical support onenvironmental issues.

� Present the sub-projectrelevant documentation(form A or B) to EPP toensure compliance withenvironmental standards.

37

Execution Parties Identification, Preparation,and Planning Phase Appraisal and Approval Project Implementation Monitoring and

EvaluationSFD RegionalOfficesAnd servicescomplexes

� Utilize the informationand publicationsprovided by EPPforpromoting environmentalawarenessamongst SFDbeneficiaries (sponsoring/ implementingagencies).

� Whenever necessary,direct SFD Beneficiaries(sponsoring /implementing agencies)to EPPfor additionaltechnical support onenvironmental issues.

� Present thesub-projectrelevant documentation(form B) to EPPtoensure compliance withenvironmental standards.

� Ascertain the sub-project’s eligibilityin accordance withSFD’s operationalguidelines andmandate.

� Review and verifythat all requiredsub-projectdocumentation hasbeen completed(i.e. A or B forms).

� Prepare thequarterly progressreports, log therelevantinformation in software.

� Recommend to thebeneficiaries(sponsoring /implementingagencies) the EPPas a source ofadditionaltechnical supportfor self-monitoringof environmentalindicators.

� Disseminateinformation onenvironmentalissues and anyother relevant sub-projectdevelopments.

� Services Complexin differentregional officeswill support andfacilitate for SMEbeneficiariesobtaining permits,approvals, and

� Use the annualenvironmentalreport as amonitoring tool toimproveenvironmentalstatus of futuresub-projects.

� Inclde correctiveactions taken inthe quarterlyprogress resport.

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Execution Parties Identification, Preparation,and Planning Phase Appraisal and Approval Project Implementation Monitoring and

Evaluationdocuments fromcompetentadministrativeauthorities.

EEAA and itsRegional Branches

� Provide relevantinformation onenvironmental laws,regulations, andmeasures.

� Provide updated lists forthe environmentalclassification of sub-projects(A,B) to SFDEFPs to enable them toappropriately classifytheir sub-projects.

� Provide assessmentforms (A) and (B).

� Provide the EPPwithcasestudies of bestpractice impactminimization andmitigation measures.

� Review form (B) � Grantenvironmentalapprovals to SFDbeneficiaries(sponsoring /implementingagencies).

� Assist in raisingthe awarenessofSFD beneficiaries(sponsoring /implementingagencies)concerningenvironmentallaws andregulations.

� Support regionaloffices inmonitoringenvironmentalcompliance.

ESMP / ESGM SFD - ESPS

39

Annex E - Training Programs & Capacity Building Needs Estimated Budget

Training / CapacityBuilding Activity

ParticpatingStakeholder(s) Skills to be Acquired Scheduling Cost Estimate

in LEPossible

Funding Sources

EnvironmentalStrategic Plannign

• EPPDirector andStaff

• Include environmentalsafeguards and policesinto thecorporatestrategy

• Continuously updatingthe environmentalstrategy according tonew inputsandregulations

The first inclusionof environmentalsafeguards andpolicies to startasap. With regularupdating activities

LE 200,000 SFD

Annual and baselinereporing

• EPPDirector andstaff

• REFPs• HQEFPs

• Prepare base linereports for sub-projectswith potential negativeimpacts

• Comple and analysequarterly progressreports into annualreport

Prior toimplementationphaseof the sub-projects

LE 150,000 SFD

Environmentalaudinting

• EPPDirector andstaff

• REFPs• HQEFPs

• Perform environmentalauditing for micro andsmall sub-projects withpotential negativeeffects

• Perform desk reviewand recommendcorrective actions

Duringimplementation andoperation phases

LE 250,000* SFD

Estimated Total Program Costs = LE 600,000

ESMP / ESGM SFD - ESPS

40