Integrating EMP into the Project Operational Manual

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Integrating EMP into theProject Operational
Manual

• World Bank Safeguard Training Workshop
• Dushanbe, Tajikistan
• September, 2009

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Project Operation Manual (POM)

• Reference for all aspects of project
  implementation who does what, when and how
• Usually prepared after project Appraisal, before
  Effectiveness, updated as needed
• 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
• Need to specify procedure for amending it

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Why Have a POM?

• 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

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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
• EMP or Environmental Guidelines
• Disbursement procedures (including for
  Sub-grants)
• Procurement procedures
• Financial management accounting
• Monitoring Reporting (Table of Progress
  Impact Indicators)
• Annexes
• Work Plan (updated annually)
• Application Reporting formats
• Terms of Reference (PIU, major consultancies)

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Integration of EMP in POM

• EMP as a chapter of POM
• EMP as an annex to POM
• Elements of EMP inserted throughout OM where
  relevant
• Recommended - 1 3 or 2 3

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Small Grants Program

• 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 sub-projects Category B (Category A
  sub-projects specifically excluded)
• Framework EA/EMP covering the whole project sets
  out procedures for site-specific EA/EMP for
  sub-projects

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Example Small Grant Programs
Kazakhstan
Kyrghyz Rep.
Croatia
Serbia
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Example Croatia Conservation and Rural
Revitalization Program

• Program objective demonstrate positive linkages
  between Protected Areas/biodiversity conservation
  and rural development (economic opportunities
  from sustainable use awareness-raising and
  education)
• Grant size Euro 2,000 25,000

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Eligibility Screeningof proposals
Evaluation/selection of eligible proposals
5
Submission of proposals
4
6
(Assisted) preparation of applications
Sub-Project approval
6
3
Agreement on work plan, contract signing
Training Workshops for Applicants
2 2
sub-project cycle
7
1
Program Advertisement
First tranche disbursement
8
Final report accounting
11
9
Progress report, Accounting, verification
10
Second tranche disbursement
10
Example Incorporation of EMP in POM Procedures
Small Grants Programs

• Awareness Training - advice to prospective
  applicants on eligible/ineligible activities,
  potential environmental issues e potential
  impacts and mitigation measures for different
  types of sub-projects
• Grant application identify potential
  environmental issues and proposed mitigation
  measures
• Screening of application review of eligibility
  of proposal, excluding any with high
  environmental risk
• Grant evaluation selection EA screening,
  evaluation of env. issues and proposed
  mitigations indicate whether specific EA/EMP
  required
• Preparation/signing of Grant contract
  Environmental mitigation measures included in
  Sub-project contract Includes specific
  environmental provisions for procurement,
  contracting
• Procurement includes environmental provisions in
  bidding documents, specifications, contracts
  (including penalties for non-compliance)
• Grant disbursement/Progress reporting
  environmental measures maybe triggers for
  disbursement PIU verifies environmental measures
  implemented and are effective
• Monitoring reporting on Grant Implementation
  includes EMP compliance, environmental indicators

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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