assessment and 1- review in sub.saharan...

Post-UNCED SeriesTOWARDS ENVIRONMENTALLY SUSTAINABLE DEVELOPMENT

IN SUB-SAHARAN AFRICA

Building Blocks for AFRICA 2025 Paper No. 7

21118September 1995

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Envi'ronmentalAssessment and 1-

Review inSub.Saharan Africa

Jean-Roger Mercier

FILE COPYSZiiX Environmentally Sustainable Development Division * Africa Technical Department

Envirn,nntal Sustainablp- Di (AFTES)

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Building Blocks forEnvironmentally Sustainable Development in Africa

Paper No. 7

Environmental Assessment and Reviewin Sub-Saharan Africa:

An Africa Region/World Bank Perspective

by Jean-Roger Mercier

Environmentally Sustainable Development DivisionAfrica Technical Department

The World Bank

September 1995

The "Building Blocks' in this series are part of the continuing discussion inaugurated atthe UNCED Conference in Rio on building environmentally sustainable development in Africa.The conclusions in these papers are not definitive; nor do their views and interpretations neces-

sarily reflect the opinions of the World Bank or any of its affiliated institutions.The main author is Jean-Roger Mercier, coordinator for the Environmental Assessment

and Review Team of the Africa Region at the World Bank. Contributions and substantial com-ments have been received from his colleagues Shimwaayi Muntemba, Valentina Okaru, Edel-traut Gilgan-Hunt, Kristine Ivarsdotter, Inger Bertilsson,. M. Robert Goodland, Robert Robe-lus, Robert Clement-Jones, Fran,ois Falloux, Robert "Gus" Tillman, and Cyprian Fisiy. The

editors were Pamela S. Cubberly and Lawrence Mastri.

Foreword

Which environmental issues make development unsustainable in Sub-SaharanAfrica and how do African societies perceive and address these issues? How has theWorld Bank helped its Africa borrowers to integrate environment into their developmentstrategies and programs? And what must the Bank do to help African countries achieveenvironmentally sustainable development (ESD)?

Inspired by the 1992 Earth Summit in Rio, the Bank has launched a reflectionprocess to answer these questions. In its reflection the Bank is guided by the message ofRio: without improved environmental management, development will be undermined, andwithout accelerated development in poor countries-which describes most of Sub-SaharanAfrica-the environment will continue to degrade.

This process seeks to define the Bank's medium-term agenda for helping its Sub-Saharan Africa borrowers attain ESD. It aims at enriching Bank staff's dialogue withAfrican counterparts about improving the conception and implementation of Bank ESDprograms. The process should also gain the interest of a much wider audience, includingan array of prominent institutions, African and non-African, public and private,universities and NGOs, and bilateral and multilateral agencies. It should encourage adebate on environmental issues which would forge wide support for new Africaninitiatives toward ESD.

Space and time determine the process. Environmental issues are location-specificand therefore require integrating the geographic dimension. With respect to time, theprocess has focused on both past and future historical perspectives. The future timehorizon is 2025, i.e., 30 years, corresponding roughly to a generation. Backward, theprocess focuses on the past decade, and the Bank's association with Africa, in order tomeasure the full magnitude of environmental issues.

Within this process, about 20 thematic 'building blocks" have been compiled,each addressing a specific facet of ESD issues. These "blocks," prepared by specialistsfrom inside and outside the Bank, fall into five categories: population, environmentalknowledge, urban environment, natural resource management, and strategic instruments.The building blocks series has been the basis for the preparation of a World Bankdiscussion paper: Toward Environmentally Sustainable Development in Sub-SaharanAfrica-a World Bank Perspective, which will be published in 1995.

Jean-Roger Mercier is an Environmental Assessment Specialist in AFTES.

Francois FallouxPrincipal Environmental Advisor

Environmentally Sustainable Development DivisionTechnical Department

Africa Region (AFTES)

Table of Contents

Acronyms & abbreviations iv

Executive Sumnary vii

1. The Environmental Assessment & Review (EAR) Procedure in the AfricaRegion of the World Bank 2The Operational Directive 4.01. and the procedure 2How OD 4.01. has been operationalized within the World Bank in the Africa Region 4How OD 4.01 has been operationalized in the countries 7Selected aspects of EA preparation 9Influence of EAR on project design and implementation 11Changing features of the Bank portfolio in Sub-Saharan Africa 13Conclusion: strengths and weaknesses of the EAR procedure 14II. Lessons learned and likely future directions 15Progress in the field 15The environmental assessment preparation process 15The environmental review process 16Likely future directions 16III. Recommendations and Action Plan 18Recommendations 18A short term action plan: a two year time frame for implementing the recommendations 19Proposed Modus Operandi: priority on networking 22

Bibliography 23

List of Boxes1. A Short Ad Hoc World Bank Glossary 12. The Africa Region Technical Department Environmental Training Workshop Program inAfrica 83. Summary of the Review of Public Participation in EA Preparation of Bank-Financed Projectsin SSA 104. Examples of influence of EA on Bank-financed project design in SSA 125. Areas for Inunediate Priority Action Identified at the 1995 African Ministerial Meeting onEnvironmental Assessments 176. Strategic EA Preparation and Application 18

List of Tables

Table 1: EA Preparation cost as a proportion of project cost 6

Annexes1. Primary World Bank texts giving guidance on environmental issues2. Environmental Screening for World Bank financed projects3. Detailed results of a quantitative review of EA project screening4. Environmental legislation and assessment capacity in SSA

Page iv

Acronyms and abbreviations

AFTES Africa Technical Environmentally Sustainable Development DivisionAMCEN African Ministerial Conference on EnvironmentAREMIS Africa Region Environmental Monitoring Information SystemARPP Annual Review of Project PerformanceAT Appropriate TechnologyCAS Country Assistance StrategyCEM Country Economic MemorandumCESP Country Environmental Strategy PaperEA Environmental AssessmentEAR Enviromnental Assessment and ReviewEAP Environmental Action PlanEDI Economic Development Institute (in French: IDE, Institut de Developpement

Economique)EIA Environmental Impact AssessmentEIS Environmental Information SystemEMEMP Environmental Mitigation, Evaluation and Mitigation PlansEMP Environmental Management ProgramEPA Environmental Protection AgencyER Environmental ReviewESP Environmental Support ProgramEU European Union (formerly European Economic Communities)FAO Food and Agriculture Organization (of the United Nations)GIS Geographic Information SystemIAIA International Association for Impact AssessmentIBRD International Bank for Reconstruction and DevelopmentICZM Integrated Coastal Zone ManagementIDA Intemational Development Association (World Bank group)IEPS Initial Executive Project SummaryIFC International Finance Corporation (World Bank group)IMF International Monetary FundIUCN World Conservation Union (formerly Intemational Union for the

Conservation of Nature)LEAP Local Environmental Action PlanMELISSA Managing the Environment in Sub-Saharan AfricaMIGA Multilateral Guarantee AgencyMOS Monthly Operational SummaryNEAP National Environmental Action PlanNEPA National Environmental Protection ActNGO Nongovernmental OrganizationOD Operational DirectiveOED Operations Evaluation DepartmentOMS Operational Manual StatementOTA Office of Technology Assessment (US)PEAR Project and Environmental Assessment ReviewPER Public Expenditure ReviewPPF Project Preparation FundRED Regional Environmental Divisions

Environmental Assessment and Review in Sub-Saharan Africa

Page v

SAR Staff Appraisal ReportSSA Sub-Saharan AfricaTORs Terms of ReferenceUN United NationsUNCED United Nations Conference on Environment and DevelopmentUNDP United Nations Development ProgramUSAID United States Agency for International DevelopmentWB World Bank


...at a glance

LESSONS LEARNED: FUTURE DIRECTIONS:* Environmental assessment (EA) pro- * More and better environmental as-

cedures have been accepted by bor- sessments and analyses of specific androwers and World Bank staff alike. sectoral projects

* Management of involuntary resettle- * Tighter integration of EA Mitigationment improved when an EA was pre- Plans into project design, implemen-pared. tation, and costs

* Coordination among donors on EA is * Improved Information Managementstill inadequate. for Project Environmental Monitoring

* In most borrowing countries there are * More supervision of projects withinsufficient financial, institutional, potentially significant environmentaland human resources to conduct EA impacts and intensified post-EA fol-properly. low-up

* Geographic, economic, and global * Better in-country legislation, proce-dinensions are yet to be fully inte- dures, and capacity to implement andgrated into EA. supervise EAs

* Environmental health issues do not * More and better public participationreceive enough attention. in EA at al levels

* Supervision of Environmental Mitiga- * Better monitoring of actual environ-tion Plans is still insufficient. mental impacts and better dissemina-

* Project-specific EA is inadequate to tion of resulting informationaddress most environmental issues in * Development of substitutes or com-Africa. plements to EAs (environmental eco-

nomics, green accounts, and environ-mental indicators)

Page vii

Environmentally Sustainable Development Strategy for Africa



Executive Summary

More than anywhere else in the world, Sub-Saharan Africa relies on itsenvironmental resource base, both from an economic and social point of view.Its environment is at risk, however, due to interdependent issues (heavy relianceon natural capital, poverty and population growth, urbanization and migra-tions, and difficult economic transitions).

-Toward Environmentally Sustainable Development in Sub-SaharanAfrica: a World Bank Agenda (World Bank 1995).

To integrate enviromnental concerns into economic development better, the environ-mental assessment (EA) procedure was introduced into the World Bank group in 1989 andstrengthened in 1991. Environmental assessment is a process of evaluating a project's envi-ronmental impact and identifying ways to improve the project environmentally by preventing,minimizing, mitigating or compensating for adverse enviromnental impacts. This procedure atthe same time established the environmental review of projects and programs cofmanced by theBank. This review covers the entire project cycle, from preparation to completion. Six yearsafter introduction of EAs, a majority of African countries have adopted, or are adopting, theprocedure, and the environmental assessment procedure has been internalized in the WorldBank group.

During the last six years, the Bank has cofinanced 500 or so projects in Sub-SaharanAfrica (SSA). They have all gone through environmental review, 3 percent through full-fledgedenvironmental assessment and 34 percent through enviromnental analysis, a lesser version ofenvironmental assessment. The remaining projects were subject to initial environmentalscreening and are part of the general environmental monitoring of the Bank's portfolio.

Mobilizing the borrowers and the World Bank staff in EAR has required cooperationamong several groups inside and outside the institution and, although the resources required toconduct EAs are few compared with the requirements of engineering studies, finding the hu-man, technical, and financial resources required for EA preparation and for the implementationof their operational recommendations has been problematic. The Regional Environmental Divi-sions have played a critical role in assisting governments and Bank operational staff to integratethe environment better into their project design and implementation.

The Africa Region contributed directly to EA capacity building in SSA through a seriesof hands-on practical workshops as well as through technical assistance to projects linked withimplementing National Environmental Action Plans (NEAPs).

Environmental Assessment and Review in Sub-Saharan Afnica

Page viii

Although clearly not a perfect procedure, EA has shown its capacity to maintain a fruit-ful dialogue among the various stakeholders of environmental management in SSA, as well asto control major impacts of projects (for example, involuntary resettlement). The main lessonslearned can be summarized as follows:

* Progress on EAs in SSA has been significant. Borrowers have accepted the Bank'sEA procedures, and more than half of the countries have, some EA legislation, al-though human and technical resources are lagging behind most of the time. Coordi-nation among donors is still far from satisfactory, and experience in monitoringenvironmental impacts in the field is limited.

* The EA preparation process is generally hampered by a lack of proper financial in-struments and insufficient dialogue in the field among assessors, governments, andother stakeholders. The general weakness of national institutions and scarcity oftrained African EA specialists have added to the difficulties. EA preparation has notincluded enough decision-making tools, such as Geographic Information Systems(GIS) and economics. Nevertheless, EAs have permitted improved management ofinvoluntary resettlement and contributed to improved project design through in-creased capacity building and monitoring.

* At present, the environmental assessment process is fully effective for a limitedsection of the Bank's portfolio. However, EAs have not been sufficiently integratedinto structural adjustment instruments as well as strategic documents, such asCountry Assistance Strategies (CAS). There are insufficient resources for the fieldsupervision of Bank-financed projects.

Future EAR work in the Africa Region will lead to more transparency due to moregenerous public disclosure standards inside the Bank as well as stricter environmental controlsinside both the borrowing countries and the Bank.

To better respond to these new conditions and to make up for the shortcomings of theprocedure, the overarching goal of the team in charge of environmental review in the AfricaRegion will be to maximize its contribution to sustainable development in the field in SSA. Themain objectives include:

* Increased information flows among the various stakeholders* Improved quality of environmental assessments and of monitoring in the field* More proactivity in promoting environmentally sustainable development

In the short run (over the next two years), the team in charge of environmental assess-ments and review will put its major efforts into the following activities:

* Assistance to capacity and institution building for EA in SSA for both the public andthe private sector,

* Improved communication, tools, and methods (notably internal awareness building,networking, strategic environmental assessments - from sectoral environmental assess-ments all the way to the integration of the environment in public expenditure reviews -,improved monitoring systems, use of environmental economics and GIS, and environ-mental risk analysis)

* Promotion of "win-win" solutions (clean technologies, local environmental actionplans, renewable energy, and environmentally sustainable tourism).




This report is a contribution of the environmnental review team for World Bank activi-ties in the Africa Region. It is part of the initiative on "Environmentally Sustainable Develop-ment Strategy for Africa," a follow-up to the United Nations Conference on Environment andDevelopment (UNCED) in June 1992.

The paper describes how the environmental assessment (EA) and environmental reviewfunctions are shared between the World Bank and its borrowers, draws lessons from observa-tion of six years of operation of these functions, and proposes directions for future work.

Box 1: A SHORT AD Hoc WORLD BANK GLOSSARY

ENVIRONMENT: The natural and social conditions surrounding all organisms, particularly humankind,including future generations. Enviromnental concerns encompass the natural environment (air, water andland) and human ecology and health and safety, and sociocultural issues such as cultural heritage, indige-nous peoples, new land settlement, involuntary resettlement, and induced development.ENVIRONMENTAL ASSESSMENT (EA): The process of evaluating a project's environmental impact andidentifying ways to improve the project environmentally by preventing, minimizing, mitigating or com-pensating for adverse environmental impacts. EA is the responsibility of the borrower, but the Bank mayprovide technical advice.ENVIRONMENTAL ANALYSIs is until late 1995 a softer version of the environmental assessment. Envi-ronmental analysis is performed on activities that are less likely to lead to detrimental environmentalimpacts than those submitted to environmental assessment. From 1996 on, the term environmental analy-sis should be replaced by "Category B (see further) environmental assessment".ENVIRONMENTAL ASSESSMENT (EA) REPORT: The report submitted by the borrower presenting theanalysis and findings of the EA. An EA report is always prepared for Category A projects and is called a"Category A EA report". An EA report is sometimes prepared for Category B projects and is called a"Category B EA report". An EA report is not required for Category C projects. The EA report is theborrower's property.ENVIRONMENTAL REVIEW is the World Bank internal analytical process that accompanies the environ-mental assessment process (which is the responsibility of the borrowing country) by ensuring qualitycontrol through proper screening, preparation and incorporation of recommendations, as well as techncialassistance, e.g., for the drafting of terms of reference and the identification of appropriate resource per-sons. In practice, Environmental Assessment and Environmental Review functions are so closely linkedthat the Environmental Assessment And Review Procedure is thereafter presented as the intricate combi-nation of both processes.ENVIRONMENTAL SCREENING is part of the Environmental Review process and results in the ranking ofactivities into Enviromnental Categories. Category A projects (the most likely to generate negative envi-ronmental impacts, mainly large scale projects with significant physical impacts) go through the full EAprocess. Category B projects are an intermediate category of projects going through limited EA, andCategory C projects, mainly technical and financial assistance projects are deemed not to generate sig-nificantly negative environmental impacts and, as such, are not subjected to the same thorough review asthe previous two categories of projects.ENVIRONMENTAL MITIGATION PLAN: the operational output of the environmental assessment report.The environmental mitigation should contain all the details on the measures to be integrated into the proj-ect design, as well as assess the costs and benefits of such measures and allocate responsibilities for theimplementation of these measures.


I. THE ENVIRONMENTAL ASSESSMENT AND REVIEW (EAR)PROCEDURE IN THE AFRICA REGION OF THE WORLD BANK

More than anywhere else in the world, Sub-Saharan Africa relies on itsenvironmental resource base, both from an economic and social point of view.Its environment is at risk, however, due to interdependent issues (heavy relianceon natural capital, poverty and population growth, urbanization and migra-tions, and difficult economic transitions).

-Toward Environmentally Sustainable Development in Sub-SaharanAfrica: a World Bank Agenda (World Bank 1995)

The development community as a whole agrees that appropriate tools and methods arerequired to improve environmental management in Africa and that environmental assessmentsform part of the arsenal of such tools and methods.

Operational Directive 4.01. and the Procedure

The Operational Directive (OD) 4.01. of October 1991, the ruling text for EAs, statesthat "the purpose of EA is to improve decision making and to ensure that the project optionsare environmentally sound and sustainable."

The concept of sustainable development was first defined by the World Commission onEnvironment and Development during the late 1980s. There was a general consensus that sus-tainable development needed to be economically, environmentally, socially, and technologicallysustainable. Although World Bank procedures have historically looked into economic sustain-ability in detail, ensuring that project options are environmentally sound and sustainable re-quired the integration of new dimensions into project design and implementation.

World Bank staff were first mandated to incorporate environmental concerns in theirproject preparation process in an Operational Manual Statement (OMS) 2.36. "EnvironmentalAspects of Bank's Work" in May 1984. Operational Directive (OD) 4.00. (published in Octo-ber 1989) made environmental assessments and related types of environmental analysis of Banklending operations compulsory for the first time in World Bank procedures as well as spellingout implementation of such analyses. OD 4.00. was superseded by OD 4.01. two years later.

Most African governments and experts are more familiar with the environmental impactassessment (EIA) than with the environmental assessment concept. Mauritius was the firstcountry to introduce EIA regulations and procedures officially in their legal and administrativeprocedures by the end of the 1980s.

For all practical purposes, EIAs are conducted by borrowing governments after a proj-ect is screened and deemed environmentally risky (see category A and B projects, defined be-low); however, the EA as required by the OD goes way beyond the EIA procedure also manda-tory under other national or multinational legislation. The main differences are (a) the broadrange of issues, including social ones and (b) the time "depth" of the EA procedure, whichextends beyond the typical one-shot EIA mandated in Europe and the United States.


The responsibility for implementing the OD 4.01. are clearly established in paragraph3: "Like economic, institutional, and engineering analyses, EA is part of project preparationand is, therefore, the borrower's responsibility." Paragraph 15 states "Though EA preparationis the responsibility of the borrower, the Bank's task manager assists and monitors the EAprocess with support from the Regional Environment Divisions (RED)."

Environmental assessment and review thus involves cooperation among several groupsoutside and inside the World Bank:

* The borrowing country, which has responsibility for conducting an environmentalassessment of its project wherever required and making sure that the project's envi-ronmental impact will not exceed the regenerative or assimilative capacities of theenvironment.

* The World Bank:

1. Its operational staff has the responsibility to bring assistance to the governmentin conducting EA and also to monitor preparation and implementation of theEA. Not only does the task manager but all other operational staff whose dutyis to cooperate closely with the task manager have to do the job in person.

2. The Regional Environment Divisions (RED) have responsibility for (a) provid-ing support to task managers by providing expertise in screening the project,preparing terms of reference for EA, providing access to other informationsources for environmental assessment, and advising on the quality and rele-vance of the environmental assessment work; and (b) reviewing the process onan ongoing basis and clearing the project on envirornental grounds at variouscritical stages of project preparation. This is referred to as environmental re-view and is the responsibility of a multidisciplinary group inside the TechnicalDepartment of the Bank's Africa Region.

3. The Central Environmental Divisions (a) provide overall support to borrowersand World Bank staff on EA policy, guidelines, strategies, and the best conductof EA procedures, notably by advising on methodologies and carrying out peri-odical reviews of procedures and their implementation; and (b) stimulate cross-regional fertilization.

4. The Operations Evaluation Department (OED) carries out project completion(ex-post) analysis and assesses the actual environmental impacts of projectsbased on actual recorded data.

5. The Economic Development Institute participates in capacity building in closecoordination with operational staff and the RED, for example, in the field ofEA.

The World Bank has decided to intensify its outreach efforts (Bank Procedure 17.50. ofSeptember 1993); the various stakeholders now have the latitude to learn about environmentalassessment of Bank-financed projects early in the preparation stage. The executive summariesfor all environmental assessments and analyses are attached to the public information docu-ments (PID) that are sent to the Public Information Center (PIC)-where they are available tothe general public-and continuously updated as preparation proceeds.

In addition, the so-called Pelosi Amendment, now in effect, requires that environmentalassessments be sent to the executive directors of the Bank at least 120 days prior to Board pres-entation, a delay that allows concerned groups to gain adequate knowledge about the projectand its likely environmental impacts.


The major steps in the EA process (end of paragraph 15 of OD 4.01.) include (a)screening, (b) selecting an environmental category (see Box 1) based on the Initial ExecutiveProject Summary (IEPS), (c) notifying the Board through the Monthly Operational Summary(MOS), (d) preparing Terms of Reference (TORs) for the EA, (e) preparing the EA, (9 review-ing the EA and incorporating environmental measures into the project, (g) supervising the proj-ect, and (h) evaluating the project afterward.

The environmental assessment report, as a decision-making tool, typically contains allor part of the following elements:

* Policy, legal and administrative framework* Description of the proposed project* Baseline data* Significant environmental impacts* Analysis of alternatives* Mitigation management plan* Environmental management and training* Environmental monitoring plan (EMP)* Appendixes, including a list of environmental assessment preparers, and references,

and a record of interagency/forum/consultation meetings

The checklist of potential issues for an EA (see annex A of the OD) includes not onlythe entire range of types of degradation of natural resources as well as man-made resourcesusually considered part of the environment, but also social issues, such as indigenous peoples,induced development and other sociocultural aspects, occupational health and safety, and invol-untary resettlement. The latter is of such paramount importance to the Bank that it is regulatedby a separate OD (4.30.).

All projects that are considered for cofinancing by the World Bank go through envi-ronmental screening during their initial stages, while some of the projects have to go throughan environmental study. Structural adjustment lending is subject to a different procedure, underOD 8.60. (Structural Lending Policy of December 1992).

Although the borrower and the Bank are expected to cooperate closely during the entireproject cycle, it is convenient to use the simple distinction made by the International FinanceCorporation (IFC) for conducting their own procedures: that the borrower be responsible for

. the environmental assessments (with assistance from the Bank) and Bank staff be primarily re-sponsible 4for enviromnental review.

Thirty or so internal regulations (see annex 1) deal with environrmental work at theWorld Bank. This shows the complexity of the EAR procedure for operational staff and theneed for close cooperation between environmental and non-environmental specialists in theborrowing governments and the Bank.

How OD 4.01. has been operationalized within the World Bankin the Africa Region

OD 4.01. and related texts have been operationalized as a mandatory procedure withinthe Bank. Within the Africa Region Technical Department, a small group of whom forms thecore team that helps the task managers comply with project screening, environmental assess-ment and review, and, to some extent, project supervision. This core team is organized to deal


with the three major issues of EA-natural resources, pollution control, and sociocultural as-pects-as well as with major procedural tasks, including drafting terms of reference, ensuringpublic participation, and capacity building. Additional expertise is recruited from the Bank'sinternal staff resources for specific tasks as required.

Each operational department in the Africa Region has environmental specialists chieflyconcerned with assisting environmental management and planning in the borrowing countries.These environmental specialists are, as of mid-1995, attached to the Agriculture and Environ-ment Divisions, a structural arrangement that has created problems in the practical implementa-tion of the horizontal approach required for environmental work.

The participation of these specialists in the environmental assessment and review proc-ess is done more on an ad hoc basis. Communication among environmental specialists in theAfrica Region is conducted through regular information exchanges, notably through the GroupTeam on Environment (GTE). Coordination with work by the International Finance Corpora-tion (IFC) in Africa is achieved through periodic meetings and colleague-to-colleague ad hoccontacts.

Bank-wide project screening is one of the most powerful features of the EAR process,as it allows a dialogue (a) between environmental specialists and their operational colleagues,irrespective of the sectors and countries, and (b) on practical cases in which hard choices mustbe made to maximize the environmental sustainability of each activity.

One of the most visible effects of this screening is to sort the projects, based on thecriteria established by OD 4.01., into four main categories:

* Category A projects, which are likely to have significant, sensitive, irreversible, ordiverse negative environmental impacts, must go through a full EA.

* Category B projects, which have less likely significant, few if any irreversible, andnot sensitive, numerous, or diverse negative environmental impacts, require an envi-ronmental analysis, a simpler version of EA.

* Category C projects, with no adverse or negligible, insignificant or minimal, nega-tive environmental impacts, require no further EA or environmental analysis.

* Category U projects are Structural Adjustment Loans or Credits that get a particularenvironmental treatment, which can be summarized as follows ". . . Bank staffshould review the environmental policies and practices in the countries. The designof adjustment programs should take into account the findings of such reviews andidentify the linkages between the various reforms in the adjustment program and theenvironment. . ." (OD 8.60.)

The basis for operating the screening is briefly summarized in annex 2.

A quantitative analysis of EAR achievements since the publication of OD 4.00. is pre-sented in more detail in annex 3 and summarized below.

Category A projects (those undergoing thorough environmental assessments) have aver-aged about three per year in the Africa Region, that is, less than 5 percent of Bank lendingactivities since creation of the procedure in 1989. This compares with 10 percent of projectsBank-wide and appears to reflect the specific Bank portfolio in SSA, with particular emphasison maintenance and upgrading of facilities for "hard" investments and a high proportion of"soft" (financial, institution building, and structural adjustment) investments. A sharp increasein these projects in the pipeline of upcoming projects is expected during the FY 1996-97 pe-riod, with an average of seven category A projects per year.


Energy and agriculture, the sectors most frequently represented in category A projects,have an equal share of projects (approximately 40 percent of projects in each (infrastructurelags behind with approximately 24 percent of the projects). The relative importance of energyprojects, however, is much stronger in terms of project costs (60 percent for energy, 25 percentfor infrastructure and 15 percent for agriculture).

Category B projects (which require a simpler environmental analysis) on average repre-sent 34 percent of Bank lending activities in SSA, also a smaller-although less disproportion-ate-than Bank-wide activities (48 percent of category B projects).

Most of the category B projects for the Africa Region (during the 1990-98 period) arein the transportation (35 percent of projects by cost) and agricultural (20 percent of projects bycost) sectors; energy is represented in less than 5 percent of projects by cost.

The Second Environmental Assessment Review perforned by the the Bank's Environ-ment Department showed that the quality and comprehensiveness of environmental analysis(category B projects) conducted in the region were less than satisfactory, as in other regions ofthe Bank. Seventy-seven percent of projects in the Africa Region (versus 78 percent in Bank-wide operations) have zero-to-moderate environmental analysis.

Category C projects, as required by OD 4.01., are found in the following sectors: edu-cation and population, health, nutrition, institutional development, technical assistance, andmost human resources projects.

Preparing environmental assessments requires resources for the country to comply withthe OD requirements. These resources are modest in relative terms, as empirical evidenceshows on a few selected projects for which the information is readily available.

Table 1: EA Preparation cost as a proportion of project cost

Sample Projects EA Preparation Total Project PercentageCost (1, ,OOs of cost (millions of EA (cost/project cost)

US$) US$)Ghana Thermal 250 400 0.06Tanzania Forests Resources 131 26 0.5Kenya Energy Sector 510 1,000 0.05Gambia Port 92 20 0.5Guinee Bissau Petroleum 20 20 0.1Malawi Power V 180 231 0.08

Source: World Bank

Despite only representing a minute fraction of project cost, however, EA preparationrequires that the borrowing country disburse resources before the Bank loan/credit is madeavailable (indeed even before the decision is made that the Bank loan/credit will ever be madeavailable). This is a generic problem for engineering and other preparatory studies as well.

In the case of environmental assessments, the search for the financial resources requiredto recruit consultants and conduct the indispensable fieldwork has been a problem. In the caseof the EA for Malawi Power V, identified as the first major EA effort in the Africa Region,trust funds were used to cover EA preparation expenses. In the vast majority of cases, projectpreparation funds (PPF), a prefinancing lending mechanism available to World Bank borrow-


ers, are used to finance the EA; however, these PPF are also used for a variety of other pre-paratory works; limitations for EA use may occur either because of the amount required ex-ceeding a PPF maximum or because the project does not get financed by the World Bank.

Another issue with larger financial implications is the cost of implementing the Envi-ronmental Mitigation Plans that are produced by environmental assessments (which may be ashigh as 30 percent of initial project costs according to the African Development Bank); no suchstatistics have been produced for Bank lending activities.

The operational directives are clear about financing of the resettlement plan, whichmust be borne by the borrower. Other mitigating measures should be an integral part of theproject and, as such, financed under the same rules as the initial project of which they are part.

Projects with environmental assessments in the Bank's portfolio have typically beenlarge-scale projects with long implementation delays; most of them are not yet even at the con-struction stage, and the possible environmental impacts of these projects cannot yet be observedin the field.

To date, the priority of the environmental review function has been on the preparationwork, with fewer resources being devoted to supervision of mitigation plans and follow-up.This can be traced back to the limited resources available in the RED to conduct such supervi-sion. Present efforts aiming to systematically integrate environmental specialists in supervisionmissions (through their integration into the supervision plan in the project documents and aclose watch on yearly budget allocations in the operational divisions) will yield dividends in acouple of years because it should logically increase environmental input during supervision.

How OD 4.01. has been operationalized in the countries

The requirement for World Bank-cofinanced projects to go through environmental as-sessments has not been a major impediment on the borrower's side; the results from the latestborrower survey conducted by the Bank in 1995 shows that even African Government represen-tatives believe that (a) environmental issues are of high priority in their countries and (b) theWorld Bank should do more to help countries deal with these issues.

In fact, since 1989 and partly because of the preparation of NEAPs (as of mid-1995,twenty-two SSA countries out of the forty-eight had adopted a NEAP and most others werebusy preparing one), many African countries have adopted-or are currently adopting-legislation that calls for EA or EIA of private and public investments on their territories.

Annex 4 presents the status of that legislation in the forty-eight Sub-Saharan Africacountries (as of the end of 1994) according to an internal World Bank review. It shows thatonly one country has no EA statute or EA enactment, whereas fourteen (29 percent) have en-acted environmental legislation, two (4 percent) have established an EA statute, and twenty-one(42 percent) have drafted environmental codes. A qualitative description of EA legislation andprocedures for most Sub-Saharan countries has been produced by the countries themselves inthe process of preparing for the 1995 Africa High-Level Ministerial Meeting on EA in Durban,South Africa, and is now available at UNEP and at the World Bank.

Environmental assessments as a scientific predictive tool require a reality check throughthorough monitoring of the evolution of the state of the environment in a given country, so thatthe predictive value (cause-effect model) of the EA can be improved over time. Unfortunately,data collection and management in general and in the environmental field in particular is stillpoor in most of the African countries, forcing EA drafters to rely most of the time on applyingfirst principles (a logical deductive process, for example, draining wetlands should eventually


reduce the local biodiversity) or using knowledge from outside Africa rather than hard data andfield-validated models.

Several African countries are engaged not only in the field of envirorunental data col-lection and management but also in the conceptual task of processing this information into indi-cators useful to decision makers to help them make the hard choices required for more sustain-able development. These indicators, once based on high quality information, are in effect theonly available tools for a reality check in the EAR procedure, an essential ingredient for envi-ronmental management.

The Africa Region Technical Department made its contribution to EAR capacity build-ing in the countries by organizing training sessions in half a dozen countries. The attendancewas high, and participants were extremely active and enthusiastic (see box 2).

Box 2: The Africa Region Technical Department EnvironmentalTraining Workshop Program in Africa.

The Africa Region Technical Department concluded in 1993 that a need existed in the region notonly for training in EA procedures per se but also for better introduction and interpretation of WorldBank environmental assessment requirements to the relatively large group of local project staff and gov-ernrment officers in Africa involved in one way or another with World Bank projects.

With financial resources from a Norwegian trust fund, the Africa Region Technical Departmentinitiated a pilot EA workshop program in the region to be implemented during fiscal 1994 and 1995.

Key features include the following:

* Workshops must be located at or near a World Bank-supported project in which an EA had been orwas going to be conducted; at least part of this project must be available for a field work session.

* Participants must have a professional-level educational background in any field and some responsibil-ity or link to either past, present, or future EA work. They may come from the government, projectstaff, or local private consultant firms. No political appointees or persons irrelevant to EA work areaccepted, and representation must be spread over a broad set of institutions.

. The number of participants is optimally around twenty to twenty-five.* Selection of the participants is the responsibility of an identified counterpart institution in the country,

but the World Bank continues to hold final authority for approval.

The first workshops took place in Kaduna (Nigeria, October 1993), Tsavo (Kenya), Ibadan(Nigeria), Arusha (Tanzania), and Malawi; the workshops were linked to EAs related to Bank-financedprojects (for example, Forestry III and Multi-State Roads for Nigeria, Mombasa Coastal Water Supplyfor Kenya, Makuyuni to Ngorongoro Road-Rehabilitation for Tanzania); and were attended by thirty tofifty trainees each.

Lessons learned included that (a) the workshop had to last at least five days to allow for presen-tations and discussion, (b) the number of lecturers should be minimal, (c) adequate professional diversitywas required to stimulate the necessary multisectoral interaction to solve problems adequately, (d)strengthening environmental economics and social impact assessment should be covered in the agenda, (e)local "ownership" secures better local adaptation and integration with national work, and that 09 omittingthe group work reduced the efficiency of the training.

Fiscal year refers to July I to June 30, for example, 07/01/94 to 06/30/95 for fiscal 1995.


By and large, Sub-Saharan African countries are now equipped or being equipped withproper environmental assessment regulations. The availability of human and technical capacityfor implementing these regulations, however, is a limiting factor despite these legal achieve-ments.

Another specific feature of environmental assessments in the vast majority of Sub-Saharan African countries is the absence of practical land use planning and other zoning regu-lations as well as environmental standards. Whereas many industrialized countries (and likewiseSouth Africa) use EA as a tool to check the projects' consistency with existing zoning regula-tions, the average Sub-Saharan African country does not, especially in rural areas but also incities. For instance, a public works project that will affect urban land in an industrialized coun-try will need immediate changes in local land use planning and compensation to the owners,while in some SSA countries, this will largely go unnoticed unless an EA has been conductedand its implementation closely monitored. Likewise, in the absence of practical environmentalstandards, the implementation of mitigating measures in most SSA countries will depend in parton the good will and availability of resources of the borrowing governments.

Selected Aspects of EA Preparation

The application of the Environmental Assessment O.D. has been uneven. The followingaspects have been given poor treatment:

* use of environmental economics* concern for environmental health* public participation* analysis of alternativesThe handling of involuntary resettlement, however, has been considerably improved by

the application of the O.D.

The use of environmental economics, although explicitly required in OD 4.01. is stillweak. A review of twenty-eight environmental assessments or analyses has shown that few ofthese EAs included any quantification of the environmental impacts and an even fewer numberhad actually monetarized. Ideally, this use of environmental economics should cover two dis-tinct aspects:

* Quantification and valuation of the positive and negative environmental impacts* Assessment of the costs and benefits of the measures proposed in the Environmental

Mitigation Plan of the EA.

The themes integrated in the EA have not always been comprehensive. Examples ofsuch shortcomings include climate change risk analysis as well as environmental health. In thelatter case, an internal Bank review of infrastructure projects (1984-1994) concluded that "theanalysis was inconclusive for the 124 (of 203) projects which contained EAs. None went intodepth on cross-sectoral environmental health linkages." (Listorti 1995).

Public participation, also an integral part of EA preparation, should take place at leasttwice during the process: initially after the scoping exercise is over and later on when the draftEA has been produced. Public participation activities should consist of more than surveys ofaffected people and involve other stakeholders, taking notes of audience recommendations, andconsidering their integration into project design and implementation. Public participation in EApreparation has been reviewed in the Africa Region (see box 3).


Box 3: Summary of the Review of Public Participation in EA Preparationof Bank-Financed Projects in SSA

The search for alternative approaches on how to combat poverty in SSA has encouraged seeingthe public in a different light-from passive beneficiaries to effective actors within the development proc-ess (for example, the Declaration of Arusha 1988). Failed projects have been instrument in reinforcingthe need for public participation in development efforts, for example, through EA, but other factors(empowering communities, fragility of the resource-base, indigenous knowledge, and role of women asmajor nature caretakers) also played a critical role.

Participation in EAs, as in the rest of development activities, covers a broad spectrum of inter-ventions, ranging from co-option to devolution of power/community control.

The World Bank's present concern for participation resulted from external prodding but also in-ternal processes. The World Bank EA legislator clearly wanted to encourage public participation, bothfor information dissemination and for influencing project design, at all critical stages of the EA process.

Public participation in EA of Bank-financed projects appears to have increased between the firstreview conducted in 1992, which established that only 33 percent of the thirty-five EAs reviewed in-cluded some form of public participation. The proportion rose to nearly 60 percent in the 1995 review(out of a sample of twenty-three EAs); however, the target should be for all EAs to be participatory; thishas not yet been achieved for reasons internal to both the Bank (both structurally and culturally) and theborrowing countries.

The future holds much promise for public participation as its role in development activities ispromoted inside and outside the Bank and as it is closely scrutinized in the Africa Region of the Bank.

For more details on the review and in-depth discussion of the issue, interested readers can referto documents by Cynthia C. Cook, Paula Donnelly-Roark, and Shimwaayi Muntemba (see bibliography).

The analysis of alternatives, a critical part of the EA that screens the options availableto achieve the target of the initial project, has also been poorly conducted in the EAs reviewed.Examples of good alternatives analysis include the comparison made of a series of possible sitesfor a hydro dam in the Malawi Water Supply (Zonkwa Reservoir) EA. The analysis showed thatthe proposed site held more water as a wetland than a reservoir would, dampened the effect offloods, and provided good wildlife habitat. The EA recommended an alternate site downstreamthat was accepted. However, such good analysis of alternatives is not conducted often enough.

The preparation of a resettlement plan for any project involving the involuntary dis-placement of more than 100 to 200 persons is now a "zero-tolerance" condition for Board pres-entation in any Bank-financed activity. In the past, the few failures to do so have resulted incorrective action and, except in a few cases (the most noteworthy one being the Lesotho High-lands Water Supply project), borrowers and Bank staff cooperate to (a) try to minimize thenumber of persons to be involuntarily displaced, (b) achieve resettlement under the best possi-ble conditions, and (c) assist the displaced people as well as possible to restore their income-earning capacity once resettled.


1

Influence of EAR on Project Design

Several levels of review of the EAR process have already been done. The Central Envi-ronmental Department of the Bank has conducted its second Bank-wide EA Review, which iscurrently being circulated for final review.

Several SSA-specific reviews have been conducted. For the purpose of a study of envi-ronmental economics in EA, twenty-eight EAs (including eighteen category A, nine category B,and one-now defunct-category D) were reviewed. During preparation of the Regional Re-medial Action Plan (RRAP) for resettlement and rehabilitation, twenty-five projects with reset-tlement activities were reviewed. In the context of the Annual Review of Project Performance(ARPP) 1994-a periodical in-depth analysis based on the supervision of Bank-financed activeprojects-eight task managers were asked to rate the implementation of Environmental Mitiga-tion Plans of EA; a sample of five projects with EAs were systematically screened to look intothe issue of EA influence on project design.

The specific SSA features emanating from this series of reviews are that:

* EAs are generally of high analytical quality in data collection and management and* EAR has been effective in the management of projects involving involuntary reset-

tlement.

The following shows the percentage of problem projects according to the environmentalcategory.

EA Problemcategory Projects (percent)A 25B 44Other 50

Note: Percent is expressed in terms of problem projects versus total number of projects in the same EA category.

* EA work has been a factor in major changes in the design of some Bank-financed projects,ranging from withdrawal of the Bank from a project (for example, large dam constructionprojects such as Garafiri in Guinea, Adjarala in Togo, and Manatali on the Sene-gal/Mauritania border) to changes in site selection (for example, the Malawi Water SupplyProject where a wetland was the initial site selected before EA).

* There is room for increased compliance of EA preparation work with the OD after six yearsof implementation. In particular:

1. The use of environmental economics at key stages of EA preparation (assessing thecosts attributable to environmental degradation and assessing the costs and benefitsof the EMP) is extremely limited. The identification of impacts is well done, quan-tification is hardly ever done, and monetarization is near nonexistent, a clear depar-ture from the OD's requirements.

2. Popular participation in EA preparation is not yet generalized.3. Development of ownership by governments is low, and the tendency is to present

the consultants' reports and mitigation plans as the government's without any re-flection on the implications thereof.

* Frequent changes in task management make it difficult to track the implementation of themitigation plans.


Box 4: Examples of EA influence on Bank-financed projects

Nigeria Fadama Irrigation- This project went through environmental analysis as a Category Bproject. The major change was that the project dropped a component on surface water irrigation and onlydid tubewell or washbore irrigation. EA also resulted in a US$ 2 Million groundwater monitoring pro-gram which is ongoing.

Kenya Energy Sector - The EA caused several changes. It recommended that the new plant nothave perimeter fencing that would exclude wildlife and livestock, so only well heads and extractors willbe fenced and animals can wander freely though the field. EA also determined that the condensate wouldnot be as sweet as the first geothermal station so that surface disposal was not sound. The new field willhave the condensate reinjected into dry wells. The EA for this project also determined that water extrac-tion from Lake Naivasha was greater than the amount authorized by extraction permits. While the geo-thermal station would be a relatively small user, the other users represent a threat to the lake. The EAalso pointed out that a Japanese funded water project was extracting water from the rivers feeding thelake and diverting it to Nakuru without EA. As a result of the geothermal EA, the managing director ofthe power company raised the extraction issue in the Council of Ministers and the second phase of theJapanese project was stopped until an EA could be completed.

Kenya Ewaso Ngiro - This EA has not be officially submitted to the Bank because the damswill not be financed under the loan now under preparation, but the EA work is essentially complete.After the project was roughly defined, a series of EA unit teams did preliminary EA work. Based ontheir recommendations, the project was redesigned and another round of EA work was completed. Thebiggest change was the substitution of a weir for a dam and reservoir on the Mara River which wouldhave taken a large amount of prime wildlife habitat. The EA also resulted in a "hands-off" flow throughthe weir that could not be interrupted so that the Maasi Mara Reserve and tourist facilities would be guar-anteed water throughout the year. The EA also designed in amenity flows for the Eswao Ngiro dams.

Botswana Tuli Block Roads - The EA and archeological survey found an important archeologi-cal site which caused a route change. The EA also introduced some significant stream protections wherethe road transversed waterways.

Gambia Third Port - The EA provided a better alternate route from port even though it in-volved a small amount of resettlement. The new route is less dangerous for the inhabitants and it will alsoreduce the disruption from port traffic.

Malawi Power V - The EA for the transmission route found a corridor that would reduce in-trusion on wildlife habitat and the amount of involuntary resettlement.

It seems important, however, to look at the influence issue. Are EAs genuine planningand decision-making tools that have an impact on project design and implementation? Answer-ing this question properly requires that detailed investigations are conducted to compare projectdesign before and after EA and separate the influence of EA from other causal factors in anarea where project design fluctuates significantly during the two to four years that it takes for atypical project to be prepared.

Empirical evidence on the five selected projects (Tanzania Forest Management, NigeriaFadama Irrigation, Ghana Thermal Power, Malawi Power V, and Gabon Forestry / Environ-ment) shows the following:


* Part of the EA recommendations are usually integrated into project design. It seems moreare when these recommendations are packaged into an EMP, spelling out the responsibilitiesfor implementation and identifying the financial resource needs.

* No recipes exist for designing EMPs, nor for selective adoption of all or part of theseEMPs.

* The need remains for putting in place a tracking system for the reviewer to be able toevaluate the proportion of EMPs that are in effect integrated into project design.

* The borrower's role in selecting which of the EMP actions should be implemented remainsmarginal.

* The sections of the EMPs that stand the most chance of being adopted are those that dealwith capacity and institution building, environmental monitoring, and further studies and re-search.

* However, some major physical investments (for example, substituting an air cooling systemfor a water cooling system for the Takoradi Thermal Power Plant in Ghana have also beendecided on the basis of the EA recomrnendations.

A more qualitative review of Bank-financed projects produced the following list ofchanges attributable to environmental assessment.

Changing Features of the Bank Portfolio in Sub-Saharan Africa

A systematic comparison of the Bank's active and completed projects in Sub-SaharanAfrica during the 1981-85, 1986-90, and 1991-1995 periods reveals the following trends:

* The cost in current US$ of an average Bank-financed project in 1991-1995 (US$70 million)was significantly smaller than in 1986-1990 (US$74 million).

* The variability in project size got larger and larger over the 1981-1995, meaning that thespectrum of project size went increasing (relatively more large and small projects and alesser number of "average" projects)

* Over the whole 1981-1995, Bank financing was increasing from 47% to 52% of the projectcost.

* The average annual number of projects financed by the Bank during the whole 1981-1995remained constant, around 85 projects per year.

* There was a shift in the broad distribution of lending activities per sector, the most notice-able changes being a decreasing emphasis on agriculture and a growing emphasis on multi-sectoral lending.

Three leading 1981-1985 1991-1995sectors _______

Sector Proportion of Sector Proportion ofloans/credits loans/credits

Agriculture 28.2% Multi-sectoral 23.0%Transportation 18.5% Agriculture 13.6%Multi-sectoral 16.8% Transportation 10.6%

Total 63.5% Total 47.2%

* The portfolio is much more diversified in recent years, as 8 sectors (out of 15) have morethan 5% of the lending program during 1991-1995, compared with 5 during 1981-1985.

* Contrary to popular perception, the absolute number and proportion of structural adjust-ment loans and credits in Sub-Saharan Africa was much larger during the 1985-1990 period(11 per year on an average) than during the 1991-1995 period (8 per year on an average).


The implication for environmental assessment and review in the Africa Region is that(i) the procedure has to adapt to a changing reality (e.g., in terms of project size and sectors)and that (ii) projects get smaller in constant terms. This is an indication that project-specific EAto help protect the environment in the borrowing countries may have become less relevant overthe years and that nonlending activities of the Bank, as well as direct interventions to helpcountries implement their own EAR procedures, may become an increasingly critical activity.Also, the repeated warning that most of the negative environmental impacts may be expectedfrom structural adjustment loans and credits has not yet been substantiated by the Bank's critics.

Conclusion: Strengths and Weaknesses of the Environmental Assessmentand Review Procedure

Strengths: the EAR procedure as it is presently regulated and implemented includes thefollowing:

* Helps include the environmental agenda in the dialogue between the governments and theWorld Bank

* Has produced noticeable and beneficial changes in Bank-financed project design in the past* Helps operationalize environmental planning procedures (for example, National Environ-

mental Action Plans) in the borrowing countries- Serves as a reminder of the need for borrowing countries to comply with their international

duties, including international conventions they have ratified and transborder issues (notablyin the water sector)

Weaknesses: the EAR procedure as it is presently regulated and implemented includesthe following:

* Does not give direct leverage over major environmental issues in Africa (for example, largescale deforestation trends in SSA cannot be reversed, let alone halted, through the applica-tion of the present project-specific World Bank EA procedures)

* Only gives the opportunity to integrate environmental and social scientists on some projectsand after the initial screening (environmental categorization) has occurred

* "A single project-level EA has little leverage beyond the influence of the single project.Project-level EA is usually a piecemeal and retail activity with regard to sectoral or regionalplanning." (Goodland and Tillman 1995)

* Is based on a predictive analysis, which has few hard data to back it up because of the lackof proper environmental monitoring in SSA

* Generates quite a few gray areas, for example, which environmental category should beused for urban water supply schemes

* Does not provide any effective mechanism for determining whether or not the Bank's EAregulations and procedures are fully consistent or compatible with the laws, policies, andprocedures of a given borrower

* Limits itself to a corrective action on the pressure put on the environment (for example, byminimizing the air pollution generated by a thermal power plant) and sometimes improvingthe response capacity of the local and national agencies involved, without really contributingto an improvement of the state of the environment (for an excellent application of the pres-sure-state-response model, see "Monitoring Environmental Progress" World Bank 1995)


II. LESSONS LEARNED AND LIKELY FUTURE DIRECTIONS

Progress in the Field

* African countries, by and large, have accepted Bank EA procedures in Bank-financed projects, although not without resistance in several instances.

* African countries have made progress in developing their own EA legislation andhuman capacity, some by adapting Bank EA procedures to their national context;however, nearly half the countries still have yet to finalize the development of suchlegislation. The vast majority of Sub-Saharan African countries have difficulty im-plementing legislation for lack of proper human, technical, and financial resourcesas well as relevant institutional setup.

* A general lack of coordination exists between Bank procedures and the initiatives ofother donors and international organizations.

* At this stage, the Bank still has limited experience in monitoring *implementationof mitigation plans and assessing their environmental impact afterward. This re-flects (a) the weaknesses of national and local environmental monitoring and EIScapacities and (b) insufficient communication between the Bank and the field.

The EA Preparation Process

- Neither clear financial instruments to finance large-scale EA work in the field noradditional resources for staff to help prepare, monitor, and evaluate EAs exist.These may be major impediments in developing EA, in particular for category Bprojects. Many EAs (for example, for category B projects) have been carried out byhiring consultants in limited numbers. In many cases, teamwork with nationalcounterparts and discussion with the various stakeholders were insufficient.

D EA preparation in countries has been made difficult by the general weakness of na-tional and local institutions in charge of environmental management as well as bylack of trained African EA specialists.

* Considerable progress has been made in the management of involuntary resettle-ment issues, partly thanks to the early warning system provided by EA.

* In most cases, EAs have not been used to facilitate the choice among project alter-natives. Nevertheless, EAs have contributed to improving project design throughincreased capacity building and monitoring.

* EAs have not been included in economic analysis, and economics has been inade-quately integrated into EA preparation. In almost all the cases, environmental riskdue to climate variability has not been taken into account; however, exceptions ex-ist, such as the Mauritius Port Project, in which climate change has been factored.Environmental health has not be given adequate attention.

EnvironmentalAssessment and Review in Sub-Saharan Africa

* Geographic Information System (GIS) technology has rarely been used in EA workdespite its "natural" spatial dirnension. Although it is probably too early to general-ize, the use of GIS should not be the exception.

The Environmental Review Process

* The percentage of category A and B projects in the World Bank's portfolio in Sub-Saharan Africa (37 percent) has been relatively lower than in other parts of theworld (56 percent). Although this reflects the nature of Bank lending in SSA, it hasalso resulted in a lesser degree of environmental integration into project design.

* Although the majority of SALs include some enviromnental considerations, as re-quired to do so by a separate OD, they are still not subject to environmental as-sessment. This is also true of important documents/procedures such as country as-sistance strategies (CAS), country economic memoranda (CEM), public expenditurereviews (PER), and other economic and sector work (ESW).

* Although the environmental review of project preparation has been done thor-oughly, many gaps remain regarding (a) the supervision of ongoing category Aprojects and (b) the environmental review of nonlending activities, notably studiesand other policy advice activities.

Likely Future Directions

Elements likely to influence the future of EAR functions in the Bank during the comingyears include:

* Publication of the new Operational Policy/Bank Procedures/Good Practices on Environ-mental Assessments, which among other things gives more precise and stringent guidelinesfor preparing the EA for category B projects.

* Promotion of a new preparation cycle in World Bank operations, moving toward smallerprojects using a two-stage approach (pilot phase followed by expansion of activities), as wellas toward more continuous cooperation between governments and the Bank.

* New directions given by the Bank management (for example, priority to poverty alleviation,rapid response ).

* Impetus given on EA- and EIA-related work at the latest Africa Ministerial Meeting in Dur-ban, South Africa, in late June 1995 (see box 5).


Box 5: Areas for Immediate Priority Action Identified at thel 995 AfricanMinisterial Meeting on Environmental Impact Assessments

"We, the African Ministers and govermnent representatives responsible for the environment. . .identified the following areas for immediate priority action:

(a) promoting the use of EIA as a continuous planning tool and the strengthening of institutional and legalframeworks for this purpose to ensure the enforcement of EIA by fully integrating this tool, includingbiophysical and socioeconomic aspects, from the early stages of policies, plans, programs and projectformulation, implementation, monitoring the commissioning and evaluation"

(b) sensitizing policy and decision makers....

(c) establishing (an EIA database, a geographic information system, information exchange, a network ofexperts)....

(d) promoting cooperation (exchange of experiences and developing guidelines)....

(e) promoting cooperation between developed and developing countries....

"(f) promoting capacity building, based primarily on the use of African expertise and institutions, andurging our countries to:

- develop curricula and other training programs to incorporate environmental education and EIA atall levels of education and training,- encourage governmental and non-governmental organizations active in enviromnental manage-ment to participate in all related capacity-building activities, as well as in regional training programs,- enhance public awareness and popular participation, particularly NGOs, women, youth andcommunity level organizations in the development and use of EIA, and- encourage all environmental movements active in the region to promote the development and useof EIA in all their activities . . ."

Source: Extracts from the communique cosigned by all ministerial delegations present at the Africa High-Level Ministerial Meeting on EAs in Africa, held in Durban, South Africa, June 1995.

Activities already launched to address several of the above issues in Africa include thefollowing:

* Direct assistance to EAR institution and capacity building, including operational support inthe framework of an environmental management project (either as a follow-up of the NEAPsor as a stand-alone project, for example, in Nigeria)

* Preliminary study on a strategy for EA capacity building (jointly between the World Con-servation Union and the World Bank)

* Regional initiative on the increased use of economics in EA* Regional initiative on identifying and disseminating good practices in EA and resettlement

management


111. RECOMMENDATIONS AND ACTION PLAN

Recommendations

To respond to these new conditions better and make up for the shortcomings of the pro-cedure, the overarching goal of the team in charge of environmental review in the Africa Re-gion will be to maximize its contribution to sustainable development in thefield in SSA. Its mainobjectives include:

* increased information flows among the various stakeholders* improved quality of the environmental assessment and review* more proactivity in the promotion of environmentally sustainable development.

In general, the following recommendations call for (a) faster and more intensive infor-mation flows among the various stakeholders and partners in EA preparation and review, (b)better communication between these two groups, (c) promotion of strategic environmental as-sessment (see box 6) and (d) a proactive attitude toward development specialists to proposethem more sustainable alternatives to their original project design.

Box 6. Strategic EA Preparation and Application

Strategic EAs (SEAs)-4hose which look at programs, policies, treaties, and other nontraditionalareas-are the newest style of EA work. Strategic EA is the application of EA above the project level.

SEAs include:

Sectoral EASEA of programs and policiesSEA of treatiesSEA of privatizationSEA of transnational corporationsSEA of structural adjustmentNational-level SEASEA for environmentAl sustainabilityInternalization of extemalitiesLifestyle changes for sustainabilitySEA of global issues

Source: Goodland and Tillman 1995.

The following recommendations will guide future operational work:

* A shift is needed from reactive to proactive mode in EA preparation and review byimproving the overall quality of category A and B projects.

* Strategic environmental assessments, e.g., for SALs should be tested on a sampleof operations, and the Africa Region should promote sector EAs in a sample ofcountries on a demand-driven basis by using the experience acquired, for example,in the Asia region (in the energy sector).


* EAs should include environmental economics methods and tools to help rank proj-ect design options.

* The need exists to improve the quality and relevance of EAR by (a) increasing andimproving public participation in EA preparation and supervision, (b) integratingmore analytical tools (GIS should be used as both a tool for analysis and an instru-ment for facilitating presentation and communication with the stakeholders. Analy-sis of environmental risk, particularly related to climatic variability, should be sys-tematically included in EA work) and (c) having more operational EMPs. This hasimplications for the EA team composition.

* Proper resources (financing and time frame) should be budgeted to support EAwork as well as review by Bank staff and to monitor implementation of the mitiga-tion plans.

* EAR should make better use of local knowledge (indigenous institutions, grassrootscommunities/groups, and local leaders).

* The Bank, in association with other donors and UN agencies, should help countriesdevelop adequate EA legislation for those that are not yet equipped to do so. EAcapacity building should be expanded by joining forces with the Economic Devel-opment Institute (EDI), NGOs, and other donors. Harmonization of borrower andWorld Bank EA regulations and procedures should be conducted continent-wide.

* Influence of EAR on project design and implementation should be regularly moni-tored, and that influence should increase over time

Short-Term Action Plan: A Two-Year Time Frame for Implementing theRecommendations

The team in charge of environmental review in the Africa Region Technical Depart-ment along with its colleagues in the operational departments must enter a learning process.The following activities will be the engine of this process.

EA in SSA Capacity and Institution Building

The communique of the African High-Level Ministerial Meeting on EA (AMCEN-Durban, South Africa, 1995 - see box 5) clearly states that the vast majority of African coun-tries ask for strong support for environmental assessment and review capacity and institutionbuilding. This is true both for countries with experience and established procedures (for exam-ple, Mauritius, Namibia, and South Africa) and for other countries that need start-up assistancebecause they lack the basic resources at present.

The World Bank, in a coordinated effort with other donors, the private sector and inter-ested NGOs (for example, the World Conservation Union [IUCN] and the Association of Afri-can Universities) should provide this assistance in SSA.

This will also be combined with an initiative to harmonize EAR procedures in the bor-rowing country with those in the Bank, a task that has already been undertaken between theBank and Russia and is required to increase the efficiency of the process. This harnonization


effort will start on a pilot basis with one or two countries at the request of the interested gov-ernments.

Part of the effort includes identification and dissemination of good practices on EAR inSSA, as well as integration of lessons learned from EA and resettlement good practices review,emphasizing analysis of alternatives, public participation, and use of appropriate tools (for ex-ample, environmental economics and EIS/GIS). This will take the form of educational tools,including a handbook on EA in SSA.

EAR Communication, Tools and Methods

The operational departments of the Bank will cooperate more closely once communica-tion has been further organized on the costs and benefits of applying EAR to project prepara-tion and supervision. This sensitization will be conducted as a priority with the objective ofexchanging information and views about (a) the strong demand for assistance to EA capacityand institution building presented by the African governments in Durban and (Z) the basis forand implications of the new OP/BP/GP on environmental assessments.

The strategic environmental assessment concept will be promoted as internal sensitiza-tion progresses. The first goals will be to conduct more sectoral EAs with a possible focus onthe energy and water sectors, depending on national demands. The second target will be coun-try assistance strategies and public expenditure reviews.

Practical tools, such as EAR and environmental supervision checklists (to be used byenvironmental specialists as well as task managers during preparation, review, and supervisionof category A and category B projects) have already been prepared in draft form for the AfricaRegion and will need to be tested and refined by field use. The checklists will contain preciseindications on the need for integrating environmental health and climate risk assessment con-cerns.

Participation will be systematically encouraged during EA preparation and during proj-ect implementation. The model of Participation Plan that the Latin America RED uses to en-courage all Task Managers to introduce participation in their project and to check with them thereasons why they would not use this participatory approach will inspire the strategy of the Af-rica Region in this respect.

These efforts will be linked with the environmental monitoring systems being developedin the field in SSA by the operational departments (for example, the Rural Resources Manage-ment Project in Niger where an elaborate long-term environmental monitoring system has beenin place since 1993), by the Africa Technical Department (for example, development of Envi-ronmental Information Systems for the five countries of the Congo Basin), as well as with theproduction of relevant sustainable development indicators.

Also among the catalogs of tools to offer to the borrowing countries and operationalstaff, creative financing mechanisms will be investigated and referenced and the correspondinginformation updated.

A major tool will be further development and maintenance of an Africa Region Envi-ronmental Information Monitoring System (AREMIS), a data base on Bank lending operationsmaintained since 1989. AREMIS will contribute to better timing, planning, and monitoring ofthe Bank's portfolio and project pipeline in SSA. The use of AREMIS will be extended to allinterested colleagues inside the Africa Region of the Bank.


The results of all these approaches will be condensed in a manual of procedures forEAR in SSA, the first version of which should be prepared by the end of fiscal 1996.

Win-Win Solutions Promotion Strategy

The EAR function has already been described as an opportunity to enter into dialoguewith our operational colleagues and suggest project components and policies for integration thatare good both for the economy and the environment. Four priority areas have been selected tolaunch this series of initiatives:

* Clean technologies for their potential to both decrease pollution and improve na-tional and local technology management, emphasizing reduction of water pollution(surface and groundwater).

* Renewable energy, with nontraditional forms (solar, wind, pico-, and micro-hydro)as an enabling technology for sustainable rural development in the framework ofdecentralized rural electrification as well as traditional forms (wood fuels) as a de-forestation-slowing activity. The objective is that renewable energy technologiesshould be used as "off-the-shelf" equipment for all practical procurement purposesin Bank-financed projects in Africa, as well as to help introduce renewable energytechnologies in the energy sector policies and programs of the borrowing countrieswherever these are the least-cost options.

* Environmentally sustainable tourism, because of the huge potential for it in Afri-can countries, the diversification opportunities that tourism represents, and the ma-jor long-term contribution it can make to a sustainable nature conservation policyand local development. Efforts in the Africa Region will concentrate mainly ontourism policy and capacity-building levels in partnership with the IFC for practicalimplementation and at the subregional levels (for example, the Indian Ocean).

* Local Environmental Action Plans, because of the need for decentralizing envi-ronmental management for more rapid response and local ownership. This will beconducted in relation to administrative decentralization and will establish a link withIntegrated Coastal Zone Management-ICZM-in many countries. An initiative tomanage the environment locally in Sub-Saharan Africa (MELISSA) will belaunched to try to coordinate activities in this field, starting with urban areas.

Related Activities Helping Increase Knowledge of Bank Activities

These will include active participation in the Annual Review of Project Performance(ARPP) for the environmental aspects and the drafting of a status report on the environmentalactivities of the Africa Region of the World Bank. The latter will be undertaken in close coop-eration with the Group Team on the Environment of the region.


Proposed Modus Operandi: priority on networking

The EAR function will continue functioning by calling on resources in the AfricaTechnical Environmentally Sustainable Development Division (AFTES) from both inside andoutside the core team. This will be most efficiently done when the AREMIS tracking system isfully in place, because it will act as an early warning system allowing improved task assign-ment.

Links with groups outside the Bank will have to be reinforced in the following ways:

* With African Governments (a) to help set up and reinforce environmental assessmentlegislation, teams, and procedures, (b) to continue and reorient the EA capacity-buildinginitiative in promoting the role of local organizations, eventually taking over the presentrole played by AFTES and EDI in this respect, and (c) to help countries develop theirNational Environmental Infornation Management Systems.

* With other donors as cooperation between the Bank and borrowers increasingly uses amultidonor approach (from concertation through cofinancing, including sequential financ-ing). Cooperation has started among regional development banks, UN agencies, bilateraldonors, and the Bank; efforts should be made to go beyond this and enter an operationalphase in extending the network linking the Bank group and other donors and speeding upcommunication inside this network.

* With advocacy and other international NGOs through both regular and ad hoc consulta-tions, since misconceptions must be corrected but also since feedback from these groupscan be important signals in helping improve the quality of environmental assessments,monitoring of environmental impacts in the field, and overall relevance to sustainable de-velopment of the Bank's portfolio in Sub-Saharan Africa.

* With private consultants to improve their understanding of our precise objectives, expec-tations, and procedures and to be able to assess the quality and reliability of their work.

Increased Linkages Inside the Bank

The linkages with other groups inside the Bank will have to be reinforced in the follow-ing ways on the following grounds:

* With colleagues in charge of public and private sector activities in SSA throughregular meetings for mutual exchange of information and professional advice.

* With the groups in charge of external affairs and the World Bank's resident mis-sions to help identify quickly possible environmental problems in the field and en-sure external dissemination of the current works of the environmental review team.

* With the Central Environmental Department through regular participation in theProject and Environmental Assessment Review (PEAR) meetings to both get advicefrom the relevant experts on difficult issues and inform them of recent develop-ments in the Africa Region of the Bank.

* With EDI for all capacity building-related activities.



a World BanklAfrica Region Perspective

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ANNEX 1.PRIMARY WORLD BANK TEXTS GIVING GUIDANCE

ON ENVIRONMENTAL ISSUES

General texts

OD 4.01. Environmental Assessments (EA)OD 4.02. Environmental Action Plans (EAP)OD 9.01. Procedures for Investment Operations Under the Global Environment FacilityOP/GP/BP 8.41 Institutional Development Fund (IDF)OD 14.70 Involving Nongovernmental Organizations in Bank-Supported ActivitiesOD 2.00 Country Economic and Sector Work (CESW)OD 2.11 Country Assistance Strategies (CAS)OD 2.20 Policy Framework Papers (PFP)OD 4.15 Poverty ReductionOD 7.50 Projects on International WaterwaysOD 8.40 Technical Assistance (TA)OD 8.60 Adjustment Lending PolicyOP/GP/BP 10.00 Investment Lending: Identification to Board PresentationOP/GP/BP 10.04 Economic Evaluation of Investment OperationsOD 105 Project SupervisionOP/GP/BP 155 Implementation Completion ReportingBP 17.50. Disclosure of Operational InformationEnvironmental Assessment Sourcebook

Green Issues

OD 4.0 Agricultural Pest ManagementOD 4.07. Water Resources ManagementOP/GP 4.36 ForestryOD 4.OOB Environmental Policy for Dam and Reservoir ProjectsOP Note N° 11.02 Wildlands: Their Protection and Management in Economic Devel-opment (to be renamed Natural Habitats and soon to be OD 4.01. Annex B)

Red Issues

OD 4.20 Indigenous PeopleOD 4.30 Involuntary ResettlementOP Note No. 11.02)Management of Cultural Property in Bank-financed Projects

Brown Issues

Handbook on Roads and the EnvironmentRoad Maintenance and the Environment, Road Maintenance InitiativeIndustrial Pollution Prevention and Abatement Technical Manual (under preparation)

Environmental Assessment and Review in Sub-Saharan Afnica

ANNEX 2ENVIRONMENTAL SCREENING FOR WORLD BANK FINANCED

PROJECTS(source: World Bank draft Operational Policy 4.01.)

Types of Projects and Their Typical Classifications

Bank and international experience shows that projects in certain sectors or ofcertain types are normnally best classified as illustrated below. These examples are onlyillustrative; it is the extent of the impacts, not the sector, that determines the extent of theenvironmental assessment and, hence, the category.

Category A Projects/Components

a) Damns and reservoirsb) Forestry production projectsc) Industrial plants (large-scale) and industrial estates, including major rehabilitation ormodificationd) Irrigation, drainage, and flood control (large-scale)e) Aquaculture and mariculture (large-scale)f) Land clearance and levelingg) Mineral development (including oil and gas)h) Port and harbor developmenti) Reclamation and new land developmentj) Activities involving resettlementk) River basin developmentI) Thermal and hydropower developmentm) Manufacture, transportation, and use of pesticides or other hazardous and/or toxicmaterialsn) New construction or major upgrading of highways or rural roads

Category B Projects/Components

a) Agro-industries (small-scale)b) Electrical transmissionc) Irrigation and drainage (small-scale)d) Renewable energye) Rural electrificationf) Tourism

KEY:

NEAP STATUS: ENV. STAIUTE IMPROVED NATIONALAND EA LEGISLATION EA-CAPACIIY

1. No NEAP A. Neither Env. Stat. a. No national capacity2. NEAP under Preparation nor EA enactment b. Some capacity that needs3. NEAP Completed B. Enacted env. legisl. to be further developed4. NEAP preappraisal C. Established EA statute c. Improved capacity including

D. Draft Env. code in prep. through Bank-supported capacityor in draft bill


g) Rural water supply and sanitationh) Watershed projects (management or rehabilitation)i) Protected areas and biodiversity conservationj) Rehabilitation or maintenance of highways or rural roadsk) Rehabilitation or modification of existing industrial facilities (small-scale)

Category C Projects/Components

a) Educationb) Family planningc) Healthd) Nutritione) Institutional developmentf) Most human resources projects


ANNEX 3: DETAILED RESULTS OF A QUANTITATIVE REVIEW OF EA PROJECTSCREENING

Achievements during FY 94 (July 1, 1994 through June 30, 1995)

Out of the sixty-eight projects that went to the Board during fiscal 1994 (two regionaland sixty-six country projects) in the Africa region, twenty-six (representing 40 percent of proj-ects and 45 percent of credits/loans) were either in category A (two projects) or B (twenty-fourprojects).

Enviromental Number of WB/IDA credits/loans Main sectorscategory projects (millions of US$)

A 2 89.5 EnergyB 24 702 IN, AGR, HR, Energy, PrivatizationC 36 798.5 All

Uncategorized 6 262.3 Structural AdjustnentsTotal 68 1,855

IN: Infrastructure, mainly transports and urban development hereAGR: Agriculture/Rural DevelopmentHR: Human Resources

Category A projects since 1989

According to available statistics on past and future projects, the evolution of Cate-gory A projects is as follows (projects by fiscal year of effectiveness).

FISCAL YEAR 1990-91 1992-93 1994-95 1996-97 1998-99

NUMBER 6 5 6 14 6

CREDITS/LOANS 415 402 403 886 275(millions of US$)

This represents a total of 37 projects, out of which 17 were either completed orunder implementation by the end of FISCAL 1995.


The distribution of category A projects according to their status is described below:

STATUS COMPLETED ACTIVE RESERVED STAND-BY

NUMBER 2 24 4 7

CREDITS/LOANS 233 1,642 196 310(millions of US$)

Eventually [meaning unclear in this context], the distribution of category A projectsaccording to their sectors is analyzed below:

SECTOR ENERGY AGRICULTURE INFRA- TOTALSTRUCTURE

NUMBER 14 14 9 37

CREDITS/LOANS 1,445 336 601 2,382(millions of US$)

DIstilbuton of Category A projects per sector Distrlbution of Catgory A projects per sector(number of projects) (credltaloans)

-~~~~~~~~~[ |7Enc7rgyl |Enorgyl

IAaric.I *Agricultur.O In rm= O InfrastrucL

The Second Environmental Assessment Review performed by the Central Environ-mental Department of the Bank has shown that the quality and comprehensiveness of environ-mental analysis (category B projects) conducted in the region was far from satisfactory, as inother regions of the Bank, as shown in the following table.


Category B Environmental AnalysisEA Approaches (Fiscal 1993 and 1994)

Region Zero Min. Ref. Mod. Full Total

AFR 4 8 9 19 12 52EAP 0 5 6 8 13 32ECA 0 2 4 4 0 10LAC 1 5 9 13 4 32MNA 0 6 1 3 2 12SAS 0 3 3 11 4 21

Total 5 29 32 58 35 159(Proportion of Zero to Moderate: 77 percent for AFR and 78 percent in total)

KeyZero: Nothing, that is, a clear departure from the OD 4.01. requirementsMin.: Minimal mention of enviromnentRefs: Refers to other projects/studies or to existing or planned guidelines, standards,

procedures, regulations, manuals, and so on.Mod.: Moderate level of environmental analysis (limited impact analysis and/or

mitigation or management plan, for example, in the form of an annex to the SARon an independent report)

Full: EA/EIA (full report) in project file

Situation of the Africa Region compared with other Bank's regions

According to the second Bank-wide EA Review, the Africa Region compares with therest of the Bank as follows (projects approved during the fiscal 1991-95 period).

Portfolio Africa Other regions DifferenceCategory A 3 percent 10 percent - 7 percentCategory B I 34 percent 46 percent -12 percentOthers 63 percent 44 percent + 19 percent

As can be seen, the Africa Region lags behind the others in terTns of the actual envi-romnental assessment performed on Bank-financed projects.


ANNEX 4ENVIRONMENTAL LEGISLATION AND ASSESSMENT CAPACITY IN SSA

Source: Valentina Okaru (AFTES) January 1995

Environmental EA CapacityLegislation

Countries A B C D a I b I cAngola XBenin XBotswana X X -

Burkina Faso X XBurundi X XCameroon - XCape Verde - - - X ICentral African Republic X - X -

Chad _ X X _Comoros I - X =Congo - X - X -

Cote d'lvoire XDjibouti X XEquatorial Guinea _ - XEthiopia - XEritrea - X - =Gabon X XThe Gambia X XGhana - X X - X -

Guinea X XGuinea-Bissau X XKenya - X X XLesotho X - XLiberia |Madagascar X XMalawi X XMali X XMauritania _ XMauritius - X X - X -

Mozambique - - XNamibia I XNiger - - - = XNigeria X X - XRwanda X XSao Tome and Principe X XSenegal - X - X -

Seychelles X I XSierra Leone X - XSomalia X - XSouth Africa X XSudan X X -

Swaziland X - XTanzania - X XTogo x x

Uqanda X - XZaire = =X _X =Zambia X XZimbabwe X

KEY:

NEAP STATUS: EN.STATUTE IMPROVED NATIONALAND EA LEGISLATION EA CAPACITY

1. No NEAP A. Neither Env. Stat. a. No national capacity2. NEAP under Preparation nor EA enactmnent b. Some capacity that needs3. NEAP Completed B. En acted env. legisl. to be further developed4. NEAP preappraisal C. Established EA statute c. Improved capacity including

D. Draft Env. code in prep. through Barl:-supported capacityor in draft bill


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