ENVIRONMENTAL SCREENING AND CATEGORIZATION WB Safeguards workshop

April-May 2012Agi Kiss

Screening/Scoping – determine what are likely potential issues, including what (other SG) policies triggered, decide what type and level of assessment is needed

Assessment – confirm and evaluate the significance of issuesBaseline (valued ecological components)Likely impacts Acceptable changes from baseline

Mitigation – identify measures to avoid/reduce/compensate for negative impacts including the expected results (e.g. standards to be achieved); identify who is responsible and confirm they have the capacity and resources

Monitoring – verify that mitigation measures are being implemented and that they are achieving the expected results (if not, need to modify them)

Environmental Management Process

Refer to other SG Policies

Most EA laws start with a process for determining the need for EIA based on an “up front” evaluation of a project’s potential environmental (and related social) impacts …

Full EIA required

Some env. review required

No env. review required

Potentially major Impacts; complex issues; likely need for significant mitigation

Moderate impacts; straightforward issues; likely need for some easily implemented mitigation

Clearly minimal or no impacts; very simple or no mitigation required

Screening/Classification Approaches:

“Project list approach “ (e.g., EU EIA Directive and harmonized national laws): Activities listed in Annex I: EIA mandatory Activities in Annex II = Initial environmental report; determination to be made whether full EIA requiredActivities not in Annex I or II: no environmental report or EIA required

Activities placed in Annex I or II based on type and scale (e.g., Hydropower plant with installed capacity over 25 MW; Poultry operation with > 50,000 head)

Benefits: clear, objective, easy to implement even with limited expertiseNegatives: inflexible, insufficient consideration of site conditions, context

“Criteria Approach” (e.g. World Bank Safeguard Policies): projects classified based on potential for negative impacts, taking into account project type and scale, sensitivity of location, the nature and magnitude of its potential environmental impacts.

Benefits: flexible, more likely to capture “outliers” with higher than usual risksNegatives: subjective, can be confusing, dependent on expertise & experience

World Bank’s Environmental Screening/EA Categories and key decision criteria

Category A

• significant adverse impacts that are sensitive, diverse, or unprecedented, or that affect an area broader than the sites or facilities subject to physical works

• conversion/alteration of natural habitats

• significant quantities of hazardous materials

• major resettlement

Category B(Compared with Category A):

• potential impacts less adverse & more limited, fewer, site-specific, likely reversible • Mitigation measures can be more easily designed/implemented

Category Cexpected to have no adverse environmental impacts, or only minimal impacts easily and fully mitigated through routine measures

Category FI

project provides funds to a bank, credit institution, etc. for on-lending at FI’s own risk (OP/BP 8.30 – FI lending)

Sub-projects to be screened and categorized as A, B or C and handled accordingly

Requirements and procedures set out in Environmental Management Framework

WB has tried to provide additional guidance available, e.g.

“Indicative List of Category A Projects”*

•Large-scale infrastructure: ports and harbor development, transport (rail, road and waterways), large- scale water resources management (river basin development, water transfer); dams and large reservoirs, hydropower and thermal power, extractive industries and oil and gas transport;

•Large-scale agriculture, irrigation, drainage and flood control, aquaculture; agro industries, and production forestry;

•Major urban projects involving housing development, water treatment, wastewater treatment plants, solid waste collection and disposal;

•Industrial pollution abatement, hazardous waste management, industrial estates, manufacture and large-scale use of pesticides; and

Projects that, regardless of scale or type, would have severe adverse impacts on critical or otherwise valuable natural or cultural resources.

*(from WB/OPCS Guidelines for Environmental Screening and Classification , 2007)

Small-scale infrastructure projects: power transmission and distribution networks, rural electrification, mini (run of the river with no major water impoundments) or micro-hydropower projects, small-scale clean fuel fired thermal power plants, renewable energy (other than hydropower), energy efficiency and energy conservation, rural water supply and sanitation, road rehabilitation, maintenance and upgrading; telecommunications, etc.;

Health care service delivery, HIV-AIDS, education (with limited expansion of existing schools/buildings), repair/rehabilitation of buildings when hazardous materials might be encountered (e.g., asbestos, stored pesticides); and

Small-scale irrigation, drainage, agricultural and rural development projects, rural water supply and sanitation, watershed management and rehabilitation, and small-scale agro-industries, tourism (small-scale developments).

“Indicative List“ of Category B projects:

“Indicative Lists” are not equivalent of EU Annexes!

Identifying Category A Projects: Relevant Information

Project type: some sectors/industries presumed to be Category A regardless of scale (unless demonstrated otherwise)

Project scale: some sectors/industries are only Category A at large scale, due to area of land take, input materials required, waste volume generated, etc. (thresholds set based on experience)

Project location: some investments are acceptable only in non-sensitive locations (social, cultural, environmental significance and vulnerability)

Types and magnitudes of activities: some projects in generally “non-risky” sectors can include specific activities which are risky

“Sensitive issues”: some projects are in sectors or include activities which raise concerns at a wider (e.g. international) level, beyond the risks and potential impacts of the specific project, and their risks must be seen in that context

Types and magnitude of impacts: Broad, irreversible, beyond project site, etc.

Identifying Category A Projects

Type of Project

Scale of project

Project Activities

Project location

Geographic location Environmental significance and sensitivities

Nature of impacts

Magnitude of impacts

Directly financed

Associated

Knowledge and Experience

Blue = information readily available during at time of project screening

Red = information less likely to be available prior to doing some environmental assessment

Sensitive issues

Sensitive issues

Technical knowledge and experience helps to move info from red zone to blue zone

Another way to approach EA screening: consider the purpose of EA classification – i.e., to determine the nature of environmental assessment to be done:

Category A: full, comprehensive EIA following all the requirements specified in OP 4.01 for Category A Category B: Some type of environmental assessment/review/plan is required, but limited in scope and flexible in structure, reflecting corresponding the limited environmental impacts of the project and the anticipated relatively straightforward mitigation

Category C: No environmental review is required.

The judgment required: which of the above is needed (sufficient) to evaluate and manage the environmental risks presented by the project?

EIA Screening: Category A vs. B Approach 1: Difference between Category A and B -- breadth and depth of EA requiredCategory A requires full EIA including: • Stakeholder consultation on TOR/scoping (as well as on draft EA)• Assessment of offsite, cumulative and indirect impacts • Analysis of environmental pros and cons of feasible alternatives (site, technology, scale, etc.)• Up-to-date, detailed baseline data on site conditions (biological, hydrological, etc.) • Institutional analysis (responsibilities, capacity)• Independent preparation to ensure unbiased analysis and consideration of alternatives

Approach 4: How many other SG policies apply? (especially Natural Habitats, Forests, Dam Safety)

Approach 3: Scale sale and irreversibility criteria (e.g.: physical resettlement of 100+ households; new dam > 15m and/or new reservoir > 3 mill m3; total volume of earthworks >100,000 m3; land “take” > 1000 ha, etc.)

Approach 2: high risk activities e.g.: production/use/storage/disposal of significant quantities of hazardous material; large scale burning of fuel or other pollution-emitting processes; construction of new permanent roads, etc.

(NOTE: Figures are illustrative – not WB policy)

Category A ExamplesPlovdiza Dam, Bulgaria

Storage of Chemicals, Kosovo

Rijeka Port, Croatia

“Low B”Requires only EMP, Checklist EMP orapplication of regulations/ standards

“High B”Requires some level of EA

Significance and duration of potential impactsSensitivity of the siteComplexity of issuesEase/reliability of mitigation

Wide range

The problems with Category B:

EA requirements poorly defined in OP 4.01

EIA Screening: “High” B vs. “Low” B vs. C“High B” requires a limited EA to provide site-specific information (e.g. due to environmentally sensitive site, or need to better define and understand potential issues) “Low B” requires has some routine environmental management issues which require only well-defined, standard mitigation and monitoring measures “C” requires no management of environmental issues beyond easily implemented, zero/low cost “good practice” (e.g. appropriate disposal of left-over paint)

Civil works: New construction:

Might be Category A if: industrial purpose; in/near natural habitat, on former industrial /toxic siteMight be “High B” if: on site with particular environmental sensitivity (e.g. adjacent to a river, shallow ground water, heavily populated area with likely land acquisition issues, development with implications for natural resource use

Rehabilitation:Might be “High B” if scale/type of works would require extensive excavation, large quantities of material/generate large amount of debris & trashMight be “Low B” if require significant excavation, demolition and waste disposalProbably “C” if only remodeling, repair, repainting, rewiring, etc.

Category B Project examples

Rehabilitation of tertiaryirrigation canal, Serbia

Hospital rehabilitation,Turkey

Wastewater TreatmentPlant Rehabilitation,Ukraine

It’s not Category C if…

• …the project will/might/could finance new construction or building rehabilitation* (beyond minimal painting, wiring, etc.)

• …the project provides Technical Assistance or other support which could lead directly to activities which would trigger SG policies

• …any of the above are financed by WB, or Government or other co-financers (covered by overall Project financing plan)

Caution: apparent C projects may include “sleeper” B category activities (sometimes even A category)

OP 4.04: Natural Habitats and Critical Natural Habitats

• Does promote and support natural habitat conservation and improved land use through integration of natural habitat conservation into national and regional development, and the rehabilitation of degraded natural habitats;

• Does not support projects that involve significant conversion or degradation of critical natural habitats

• Does not support projects involving the significant conversion or

degradation of natural habitats unless:

there are no feasible alternatives for the project and its siting, and

comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs

(Reminder) The World Bank:

Definitions*• Natural Habitat : land and water areas where

o the biological communities are formed largely by native plant and animal species, and

o human activity has not essentially modified the area's primary ecological functions

• Critical Natural Habitat:* subset of Natural Habitats which have very high biodiversity value, e.g.: – required for survival of endangered, threatened or migratory species;– have special significance for endemic species or species with limited ranges;– support high concentrations of individuals of congregatory species;– Have unique assemblages of species or are associated with key evolutionary

processes– Support biodiversity of highly significant social, economic or cultural importance

to local communities; OR– Are strictly protected under national laws and/or international agreements

* Paraphrased combination of WB and IFC definitions

Significant conversion/degradation: elimination or severe diminution of integrity of NH caused by a major, long-term change in land or water use (or short term change with a long recovery time) or by severe pollution. Can result directly or indirectly from the project

Appropriate conservation/mitigation: measures to eliminate or reduce adverse impacts to levels within socially defined limits of acceptable change. May include:

full or strategic partial site protection; restricting conversion or modification to non-essential elements of ecosystemhabitat restoration/species re-introductionestablishment and maintenance of an ecologically similar (equal value) protected area of suitable size and contiguity.(Mitigation measures should always include provision for monitoring/evaluation and adaptive management based on the results)

• Identify geographic/ecological Zone of Influence of the project; • Determine whether ZoI includes any likely Natural Habitat

• If yes, carry out desk and site assessment and consultations to determine:

– baseline biodiversity and ecological values;– whether it qualifies as Critical Natural Habitat or Natural Habitat

• If project could effect (non-critical) Natural Habitat:– EA is required, involving special expertise;– Ensure consultations involve suitable stakeholders (NGOs, resource user groups)

OP 4.04 – Screening and Application Steps

Some Indicators of Natural Habitat:• vegetation entirely or mostly comprised of wild plant species• no large scale livestock presence• water body with little or no surrounding development• few or no permanent residences or other significant structures or infrastructure (except small dirt roads and tracks roads)• no significant economic activity other than moderate harvesting of wild species• no significant sources of pollution (sufficient to impair ecosystem functions)• above conditions cover ecologically significant area (varies by ecosystem)

Remember: Mother Nature is watching!

EA Screening and Classification ExerciseExample: Project = construction of

community sports facilities

Further details to trigger at least 3 SG policies:Main stadium will be built on land currently occupied by a small apartment building (Policy triggered: ?)Facilities will include a golf course with irrigation system drawing from a river which flows into neighboring country (Policy triggered: ?)Golf course will require ongoing maintenance including management of weeds and insect pests (Policy triggered: ?)At one site it is proposed that a small wetland area be drained for construction of a football field (Policy triggered: ?)

To make it into Category A:

Project is actually to construct all-new facilities for 2016 OlympicsConstruction is planned to be done on an abandoned industrial site with hazardous waste issues