1. Gulana Hajiyeva Environmental Specialist World Bank Moscow Safeguards Training, May 30 – June 1, 2012

2.  Because environmental compliance can often not be seen as a priority in Borrower’s country  It is always better and easier to prevent environmental risk rather than rectify the consequences  Project’s environmental footprint and social effects are eventually positive for Borrower’s country

3.  New aspects can emerge during project implementation  Changes of project design can require reconsideration of initial provisions of EIA/EMP/EMF

4.  Borrower’s responsibilities are defined in legal agreements, with direct references to safeguard management plans  Bank’s responsibilities are defined in Safeguard Policies (part of Operational Procedures), Bank Procedures and legal agreements

5.  Implementation of EMP = integral part of project implementation  Borrower’s Obligation to implement EMP is included in the Loan Agreement  EMP = important part of the project’s Operation Manual  The borrower must report on compliance with EMP  Bank bases supervision of project’s environmental aspects on findings & recommendations of the EA, on EMP, measures set out in the legal agreements, and other project documents  NOTE: EMF effectively serves as project-level EMP for FI or other programmatic operations BP 13.05 (Project Supervision): Task Team: ascertains that the borrower has included the agreed implementation arrangements in Project Implementation Plan ascertains the extent of compliance with loan covenants, including those related to environmental and social safeguards

6. Effective supervision starts with preparation of comprehensive EIA/EMP/EMF EIA/EMP defines:  Country context and legislative framework;  Impacts, mitigation measures, implementation responsibilities, timeframe, indicative cost of mitigation  Capacity building measures  Measurable indicators of the implementation of the above

7. EMF defines:  Country context and legislative framework;  Potential set of activities eligible for project support;  Potential environmental risks/ project area sensitivities;  Process for addressing environmental concerns of each sub-activity

8.  Reference for all aspects of project implementation: who does what, when and how  Should be prepared prior to project effectiveness (or even sooner!)  Updated as needed (Need to specify procedure for amending it)  Emphasis on decision-making processes; “fiduciary” mechanisms (procurement, financial management & accounting, environment); monitoring & reporting  Prepared by Client (Implementing Agency); approved by Govt. (higher level); acceptable to WB  Cited in Legal Agreement, legally binding commitments

9. Implementation and Monitoring Evaluation Annual reporting (include safeguard performance) Periodic site visits, audits, if appropriate (include safeguard performance) World Bank Supervision Third Party Assessment Appraisal and Approval PIU undertakes environmental screening, use of checklist

10. Borrower is responsible for:  Implementation of agreed technical and institutional measures specified in safeguard management plans  Monitoring and evaluation of environmental and social impacts and risks associated with the project  Report on the status of the implementation of agreed actions, as part of regular project monitoring

11. Bank team is responsible for:  Ensuring proper coverage of safeguard compliance aspects in Bank’s regular supervision of project progress – review the status of implementation of EMP/EMF  Assisting and guiding the Borrower in addressing the issues identified by the supervision

12.  Depending on availability of environmental expertise in Borrower’s organization, hiring an environmental specialist  Ensuring environmental provisions and expertise are covered by supervision consultancy and construction contract  Establish regular reporting by supervision consultant and contractor  Undertaking regular visits to project sites and report to the Bank on the status and any new / unexpected issues  Duly follow up with contractors and consultants on environmental compliance and ensure enforcement

13.  Safeguards specialist keeps track of complaints and maintains grievance mechanisms;  Safeguards specialist conducts site visits to supervise and monitor implementation;  Safeguards specialists in the PIU can cover more of the project activities, and determine the adequate sample activities for supervision;  Not to be confused with World Bank environmental or social safeguards specialists that work closely with the PIU specialist!

14.  The Borrower (PIU) furnishes regular project progress reports to the Bank, with separate safeguards chapter  Safeguard report is prepared based on the inputs by contractors and project consultants and PIU dedicated staff’s own observations  Quarterly reporting, or more frequently if new issues emerge, or sensitivities occur

15.  Through regular supervision missions  Review of documentation: sub-project proposals, contractor and consultancy contracts, specific environmental management plans, project overall environmental report and monitoring plan  The need to improve Borrower’s capacity – further to the assessment at the project preparation stage  Next steps on safeguard compliance to be agreed between the Bank and the Borrower upon the end of each mission

16.  Environmental Management Framework is developed during project preparation to determine potential environmental risks and procedures to be followed for each sub- activity.  EMF is applied when project activities and locations can not be exactly described in advance but can only be determined in the course of project implementation within an established menu of eligible activities

17.  Specific environmental impacts are addressed by specific EMPs for each site of sub-project, including site assessment, mitigation measures and monitoring plan. When reporting on the compliance, the Borrower can follow the format of specific EMPs Note: EMP checklists is an option which can be used for small scale ‘low B’ activities with clearly define and limited area

18.  Depending on project’s nature and overall number of sub-projects, the Borrower determines the frequency of supervision visits and the number of sub-projects to be visited;  Typically, all category B sub-projects have to be visited.

19. What the PIU should look at:  Whether mitigation measures specified in specific EMPs are followed for each sub- projects in a timely manner  Whether all required licenses and permits are duly obtained  Whether there are no unexpected issues which would require urgent attention

20.  Findings of all site visits of the PIU as well as summary of issues and agreed time-bound plan on resolution of issues should be summarized in PIU site visit monitoring reports which can be shared with concerned parties and are the basis for subsequent monitoring  PIU Environmental Specialist and M&E Specialist should coordinate efforts – measurable environmental indicators are part of overall project M&E

21.  The Bank team visits sub-projects selected to include activities of various types/environmental categories, and geographic locations.  The Bank also meets with lending institutions to see whether they adequately follow decision making procedures, and make relevant judgments on environmental sustainability of submitted proposals What is considered:  Complete set of proposal documentation, and specific EMPs  Staff of lending institutions is interviewed to ensure there is a full understanding of environmental requirements to be met, and EMF procedures are duly followed

22. You are a PIU Environmental Specialist, and when visiting the construction site, you witness the pictures below. For each please determine:  What is the problem  What would be the adequate mitigation  Which party would be responsible for the mitigation;  Who and how would ensure that mitigation is properly implemented  What is the right way to record the problem, keep track of its solution, and who should be reported/consulted