Integrating Environmental Management Plans into Project Operational Manuals Agi Kiss Safeguards Training Workshop, Chisinau, Oct 28-31, 2008

Project Operational (Implementation) Manual 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 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)? 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 into 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 Programs

General 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 Project-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 Revitalization 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

Advertisement of program 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 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 Committee Project 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-projectssome 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 application Requirements for EA or alternative procedures (Annex) Monitoring requirements (Annex) Institutional responsibilitiesMoC, SC, LAB, MEP Proceduresgrant 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 formsfor grant application, evaluation, implementation plan, monitoring – include sections for environmental aspects CRRG Project Operational Manual Structure

Incorporation 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 Small 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