1

Environmental Management Plan Checklist and Format

for Low-Risk Topologies

For low-risk topologies, an alternative to the commonly used “full text” EMP format is to have a checklist approach. The goal is to provide a more streamlined approach to preparing EMPs. This checklist-type format is a “pragmatic good practice” approach to be user friendly and compatible with safeguard requirements.

The checklist-type format attempts to cover typical mitigation approaches to common low-risk topologies with minimal temporary localized impacts. It is anticipated that this format provides the key elements of an Environmental Management Plan (EMP) to meet World Bank Environ-mental Assessment requirements under World Bank safeguard policies (see Annex 2).

The EMP template (Annex 1) format has two parts:

• Part I: constitutes a descriptive part (“site passport”) that describes the project specifics in terms of physical location, the institutional and legislative aspects, the project description, in-clusive of the need for a capacity building program and description of the public consultation process. This section could be up to two pages long. Attachments for additional information can be supplemented if needed.

• Part II: includes the environmental and social screening in a simple Yes/No format (Section A) followed by proposed mitigation measures for any given activity (Section B) and a tem-plate for a monitoring plan for activities during project construction and implementation (Sec-tion C). It retains the same format required for standard World Bank EMPs.

Application of the EMP-Checklist to the ESME Kenya

For low-risk topologies, the practical application of the EMP-checklist would include the filling in of Part I to obtain and document all relevant site characteristics and activities. In Part 2 the type of foreseen activities, would be checked and the resulting provisions listed in Annex 2 high-lighted (e.g. by hatching the field or copy pasting the relevant text passages into the special pro-visions of the tender documents).

The entire filled in tabular EMP is additionally attached as integral part to the works contract and, analogous to all technical and commercial terms, has to be signed by the contract parties.

For the monitoring of the OGL distributor’s safeguards due diligence, attention should be given early to Part C of the EMP Checklist, the monitoring plan. This should be developed specifically for each OGL distributor and in necessary detail, defining clear criteria and parameters which can be included in the Grant Agreement, which reflect the adoption of environmental sustainabil-ity measures and which can be observed/measured/ quantified/verified by GVEP during grant implementation. Part C would thus be filled in during the design process to fix key monitoring criteria which can be checked during and after implementation for compliance assurance.

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

wb371432Typewritten TextE4410

wb371432Typewritten Text

wb371432Typewritten Text

2

ANNEX 1: Format for Environmental Management Plan

Environmental Management Plan (EMP)

Energy Small and Medium Enterprise Project

Kenya

(28th

November 2013)

PART I: Activity Description

1. Introduction

The $30 million Energy Small and Medium sized Enterprise (ESME) support in Sub-Saharan Africa Trust Fund (SATF), has the objective of fostering local private sector entrepreneurship and investment in the provision of energy services in remote, un-served and under-served regions within a number of Sub Saharan African countries. The aim is to support the establishment and development of stable and viable privately run enterprise and business models that will increase access to reliable, sustainable, and affordable modern energy services in peri-urban areas, small towns, and rural areas within the selected countries.

To implement this project, the Government of Russia (GoR) asked the World Bank to manage this trust fund and to closely collaborate with the Global Village Energy Partnership (GVEP) International. This agreement was formalized with the signing of an Administration Agreement between the World Bank and the GoR on March 19, 2009 for the ESME support in SSA project. In 2012, the project’s closing date was extended to 31st August 2014 and the Administrative Agreement is being amended to give GVEP the responsibility of implementation agency in Ken-ya and Senegal.

To ensure adequate environmental and social management during the project implementation in Kenya and Senegal by GVEP as implementation agency, and to comply with the national envi-ronmental laws and the World Bank’s Safeguards Policy, this Environmental and Social Man-agement Framework (ESMF) was developed as part of project preparation and GVEP will be responsible for its implementation.

2. Project objective

The development objective of this project is to support additional financing and Technical Assis-tance to Small and Medium Entreprises (SMEs) in selected countries Sub-Saharan Africa (SSA) countries to strengthen their capacity in providing energy services to poor communities in SSA. Specifically, this project will finance activities to increase access to modern energy services in rural and peri-urban areas isolated from the main infrastructure networks in selected African countries through the increased involvement of the local private sector SMEs in the decentralized supply of energy services. There will be a particular focus on building the capacity of the local private sector and community based organizations to develop and manage energy service deliv-ery and utilization.

3

3. Project description

In Kenya, the project will focus on support for distributors of off-grid lighting (OGL). The amount of this financial support is 1.1 million. A “working capital grant facility” will be availed to existing credible OGL distributors to enable them to meet their working capital needs and, both obtain sufficient stocks to meet their projected demand, and build a sustainable continuous cycle of supply for their products.

4. Anticipated environmental footprint The overall environmental impact of introducing OGL is likely to be positive because these products will replace inferior lighting alternatives, mainly kerosene and torches (currently avail-able at rural markets) that typically use non disposable batteries and in general have short life span (weeks to months). However, the OGL themselves will use disposable batteries and the environmental impact can therefore be further improved through (i) technology – increasing bat-tery life and use of safer materials, and (ii) developing incentives for the disposal of batteries.

5. Policy, legal and administrative framework

The mandate of the Ministry of Environment and Mineral Resources is to monitor, protect, con-serve and manage the environment and natural resources through sustainable exploitation for socio-economic development aimed at eradication of poverty, improving living standards and ensuring that a clean environment is sustained now and in the future. However, the National En-vironment Management Authority (NEMA), established under the Environmental Management and Coordination Act (EMCA) No. 8 of 1999, is the principal instrument of government in the implementation of all policies relating to the environment. According to national law, the busi-ness of solar lanterns distribution does not require any environmental studies.

6. Relevant world bank policies

The ESME project in Kenya will provide financial support to OGL Distributors to help them scale up their businesses. GVEP International will work with existing modern off-grid lighting product distributors to enable them to meet their working capital needs, to obtain sufficient stocks, expand their distribution networks, carry out their own marketing campaigns and other activities that will allow them to grow their businesses and meet their projected demand. Alt-hough it is anticipated that the ESME project in Kenya will have mostly positive environmental impacts, the improper disposal of the solar lanterns’ used batteries could have site specific nega-tive impacts and therefore the World Bank Operational Policy 4.01 on Environmental Assess-ment was triggered and the project was classified as EA category B. Sub-projects that could po-tentially trigger policies on Safety of Dams, Natural Habitats, Forestry, Pest Management, Cul-tural Property, Indigenous People, Involuntary Resettlement, Projects on International Waters and Projects in Disputed areas will not be funded under the project.

7. Implementation arrangements

The funds will be channeled through GVEP. GVEP will receive funds from the ESME Trust Fund administrated by the World Bank, and will pass on these funds to the OGL grantees that win the competition. The subprojects proposed will be analyzed by GVEP using this ESMF in-strument in order to ensure the compliance of the national law and the World Bank safeguard policies. The subprojects will be implemented by OGL distributors. The main teams that will be involved in the implementation of the ESME-K in-kind support for RE projects program are

4

GVEP, the Evaluation Committee and the OGL distributors who will be sub-grantees. The World Bank will supervise the project implementation, including the compliance with the WB environmental and social safeguards. The Evaluation Committee will be primarily responsible for approving grant recipients. It will consist of representatives from the private sector, business and technical experts, and other representatives agreed upon by GVEP and the World Bank. The EC will elect a Chair from amongst its members.

8. Environmental screening, assessment and management

The EA for Category B subprojects examines the potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. Therefore, this EMF sets out to estab-lish the EA process to be undertaken for the sub-projects under the proposed ESME Kenya, which environmental impact will be assessed according to the completed EMP checklist form.

9. Potential Environmental Impacts

Activity Potential Negative Impacts Mitigation Measures

Sale of solar lanterns Improper disposal of used batteries or of broken panels could lead to exposure to harmful chemicals or seepage of toxic chemicals into the groundwater.

-Educate users on proper maintenance of lanterns and proper disposal of used batter-ies. - Provide incentives for users to return used batteries to dis-tributor or reseller. -Put in place a hazardous waste management plan to properly dispose of returned used batteries

10. Environmental Management Approach

For all sub-project proposals the attached EMP checklist will be completed and a mini-waste management plan prepared to address the adequate disposal of the used batteries.

11. Monitoring and reporting

Each sub-project will have its own monitoring and reporting requirements, which will be consol-idated and reported through the GVEP Manager to the Bank on a regular basis.

5

Part II : EMP Checklist for Activities

Section A: (a) INSTITUTIONAL & ADMINISTRATIVE

Country

Project title

Scope of project and activity

Institutional ar-rangements

(Name and con-tacts)

WB (Project Team

Leader)

Project Management Local Counterpart and/or Recipi-ent

Implementation arrangements

(Name and con-tacts)

Safeguard Supervision

Local Counterpart Su-pervision

Local Inspec-torate Super-

vision

OGL Distributor

(b) SITE DESCRIPTION

Name of site Describe site loca-tion

Attachment 1: Site Map [ ]Y [ ] N

Who owns the land?

Geographic de-scription

(c) LEGISLA-

TION

Identify national & local legislation & permits that apply to project activity

(d) ENVIRONMENTAL MANAGEMENT APPROACH

Include mini-waste management plan and other measures to help prevent inadequate disposal of used batteries

(e) PUBLIC CONSULTATION

Identify when / where the public consultation pro-cess took place

(f) INSTITUTIONAL CAPACITY BUILDING Will there be any capacity building?

[ ] N or [ ]Y if Yes, Attachment 2 includes the capacity building program

6

Section B: ENVIRONMENTAL & SOCIAL SCREENING

Will the site activity include/involve any of the following potential issues and/or impacts:

Activity and potential issues and/or impacts Status If YES see additional

references:

1. Building rehabilitation • Site specific vehicular traffic • Increase in dust and noise from demolition and/or construction • Construction waste

[ ] YES [ ] NO Activity Box A& B below

2. New construction • Excavation impacts and soil erosion • Increase sediment loads in receiving waters • Site specific vehicular traffic • Increase in dust and noise from demolition and/or construction • Construction waste

[ ] YES [ ] NO Activity Box A& B below

3. Individual wastewater treatment system • Effluent and / or discharges into receiving waters

[ ] YES [ ] NO Activity Box A& C below

4. Historic building(s) and districts • Risk of damage to known/unknown historical or archaeological sites

[ ] YES [ ] NO Activity Box A& D below

5. Acquisition of land1 • Encroachment on private property • Relocation of project affected persons • Involuntary resettlement • Impacts on livelihood incomes

[ ] YES [ ] NO Activity Box A& E below

6. Hazardous or toxic materials2 • Removal and disposal of toxic and/or hazardous demolition and / or construction waste • Storage of machine oils and lubricants • Procurement or use of pesticides – or formulated products that are in the World Health

Organization (WHO ) Classes IA and IB, or formulation so products in Class II3

[ ] YES [ ] NO Activity Box A& F below

1 Land acquisitions includes displacement of people, change of livelihood encroachment on private property this is to land that is purchased/transferred and affects peo-ple who are living and/or squatters and/or operate a business (kiosks) on land that is being acquired. 2 Toxic / hazardous material includes and is not limited to asbestos, toxic paints, removal of lead paint, hazardous pesticides etc. 3 Reference: World Health Organization “Recommended Classification of Pesticides by Hazard and Guidelines to Classification” (IOMC, 2000-2002)

7

7. Impacts on forests, natural and/or protected areas • Conversion of forested land, protected areas, or natural habitats for biofuel crops • Encroachment on designated forests, buffer and /or protected areas • Disturbance of locally protected biodiversity habitat

[ ] YES [ ] NO Activity Box A& G below

8. Handling / management of medical waste • Clinical waste, sharps, pharmaceutical products (cytoxic and hazardous chemical

waste), radioactive waste, organic domestic waste, non-organic domestic waste

• On site or off-site disposal of medical waste

[ ] YES [ ] NO Activity Box A& H below

9. Traffic and Pedestrian Safety • Site specific vehicular traffic • Site is in a populated area

[ ] YES [ ] NO Activity Box A& I below

10. General land and water issues • Contributes to irreversible land degradation, and /or siltation in waterways • Includes impoundments in waterways (generally for water extraction) • Groundwater extraction

[ ] YES [ ] NO Activity Box A& J below

ACTIVITY BOX PARAMETER GOOD PRACTICES MITIGATION MEASURES CHECKLIST

A. General Condi-tions

Notification & Worker Safety

(a) Consult with the Task Team Lead and World Bank Safeguard Coordinators4 to discuss activities and the due diligence requirements

(b) The local construction and environment inspectorates and communities have been notified of upcoming activities

(c) The public has been notified of the works through appropriate notification in the media and/or at publicly accessible sites (including the site of the works)

(d) All legally required permits (to include not limited to land use, water use, resource use, dumping, sanitary inspection permit) have been acquired for proposed activity

(e) All work will be carried out in a safe and disciplined manner designed to minimize impacts on the environment and neighboring residents

(f) Workers’ personal protective equipment (PPE) will comply with international good practice (al-ways hardhats, as needed masks and safety glasses, harnesses and safety boots)

(g) Appropriate signposting of the sites will inform workers of key rules and regulations to follow. B. General Rehabili-tation and /or Con-struction Activities

Air Quality (a) During interior demolition use debris-chutes above the first floor (b) Keep demolition debris in controlled area and spray with water mist to reduce debris dust (c) Suppress dust during pneumatic drilling/wall destruction by ongoing water spraying and/or in-

4 Regional Safeguard contact: http//safeguards

8

ACTIVITY BOX PARAMETER GOOD PRACTICES MITIGATION MEASURES CHECKLIST

stalling dust screen enclosures at site (d) Keep surrounding environment (side walks, roads) free of debris to minimize dust (e) There will be no open burning of construction / waste material at the site (f) There will be no excessive idling of construction vehicles at sites

Noise (a) Construction noise will be limited to restricted times agreed to in the permit (b) During operations the engine covers of generators, air compressors and other powered mechani-

cal equipment should be closed, and equipment placed as far away from residential areas as pos-sible

Water Quality (a) The site will establish appropriate erosion and sediment control measures such as e.g. hay bales and / or silt fences to prevent sediment from moving off site and causing excessive turbidity in nearby streams and rivers.

Waste management (a) Waste collection and disposal pathways and sites will be identified for all major waste types ex-pected from project activities.

(b) Mineral construction and demolition wastes will be separated from general refuse, organic, liquid and chemical wastes by on-site sorting and stored in appropriate containers.

(c) Construction waste will be collected and disposed properly by licensed collectors (d) The records of waste disposal will be maintained as proof for proper management as designed. (e) Whenever feasible the contractor will reuse and recycle appropriate and viable materials (except

asbestos)

C. Individual wastewater treatment system

Water Quality (a) The approach to handling sanitary wastes and wastewater from building sites (installation or re-construction) must be approved by the local authorities

(b) Before being discharged into receiving waters, effluents from individual wastewater systems must be treated in order to meet the minimal quality criteria set out by national guidelines on ef-fluent quality and wastewater treatment

(c) Monitoring of new wastewater systems (before/after) will be carried out D. Historic build-ing(s)

Cultural Heritage (a) If the building is a designated historic structure, very close to such a structure, or located in a designated historic district, notify and obtain approval/permits from local authorities and address all construction activities in line with local and national legislation

(b) Ensure that provisions are put in place so that artifacts or other possible “chance finds” encoun-tered in excavation or construction are noted, officials contacted, and works activities delayed or modified to account for such finds.

E. Acquisition of land

Land Acquisition Plan/Framework

(a) If expropriation of land was not expected and is required, or if loss of access to income of legal or illegal users of land was not expected but may occur, then consult with Task Team Lead and /or Regional Safeguard Coordinator

(b) The approved Land Acquisition Plan/Framework (if required by the project) will be implemented F. Toxic Materials Asbestos management (a) If asbestos is located on the project site, mark clearly as hazardous material

9

ACTIVITY BOX PARAMETER GOOD PRACTICES MITIGATION MEASURES CHECKLIST

(b) When possible the asbestos will be appropriately contained and sealed to minimize exposure (c) The asbestos prior to removal (if removal is necessary) will be treated with a wetting agent to

minimize asbestos dust (d) Asbestos will be handled and disposed by skilled & experienced professionals (e) If asbestos material is be stored temporarily, the wastes should be securely enclosed inside closed

containments and marked appropriately (f) The removed asbestos will not be reused

Toxic / hazardous waste management

(a) Waste (i.e., used batteries) are transported by specially licensed carriers and disposed in a li-censed facility.

(b) Temporarily storage on site of all hazardous or toxic substances will be in safe containers labeled with details of composition, properties and handling information

(c) The containers of hazardous substances should be placed in an leak-proof container to prevent spillage and leaching

(d) Paints with toxic ingredients or solvents or lead-based paints will not be used Pesticides (a) Follow recommend and minimum standards as described in the United Nations Food and Agri-

culture Organization (FAO) International Code of Conduct on the Distribution and Use of Pesti-cides (Rome, 2003)

(b) Promote use of ecologically based biological or environmental pest management practices (inte-grated pest management IPM)

G. Affects forests and/or protected areas

Protection (a) All recognized natural habitats and protected areas in the immediate vicinity of the activity will not be damaged or exploited, all staff will be strictly prohibited from hunting, foraging, logging or other damaging activities.

(b) For large trees in the vicinity of the activity, mark and cordon off with a fence large tress and protect root system and avoid any damage to the trees

(c) Adjacent wetlands and streams will be protected, from construction site run-off, with appropriate erosion and sediment control feature to include by not limited to hay bales, silt fences

(d) There will be no unlicensed borrow pits, quarries or waste dumps in adjacent areas, especially not in protected areas

(e) Forested areas/natural areas and protected will not be converted for bio-fuel crop production. H. Disposal of medi-cal waste

Infrastructure for medi-cal waste management

(a) In compliance with national regulations the contractor will insure that newly constructed and/or rehabilitated health care facilities include sufficient infrastructure for medical waste handling and disposal; this includes and not limited to: � Special facilities for segregated healthcare waste (including soiled instruments “sharps”, and

human tissue or fluids) from other waste disposal: a. Clinical waste: yellow bags and containers b. Sharps – Special puncture resistant containers/boxes

10

ACTIVITY BOX PARAMETER GOOD PRACTICES MITIGATION MEASURES CHECKLIST

c. Domestic waste (non-organic): black bags and containers � Appropriate storage facilities for medical waste are in place; and � If the activity includes facility-based treatment, appropriate disposal options are in place and

operational

I. Traffic and Pedes-trian Safety

Direct or indirect haz-ards to public traffic and pedestrians by construc-

tion activities

(a) In compliance with national regulations the contractor will insure that the construction site is properly secured and construction related traffic regulated. This includes but is not limited to � Signposting, warning signs, barriers and traffic diversions: site will be clearly visible and the

public warned of all potential hazards � Traffic management system and staff training, especially for site access and near-site heavy

traffic. Provision of safe passages and crossings for pedestrians where construction traffic in-terferes.

� Adjustment of working hours to local traffic patterns, e.g. avoiding major transport activities during rush hours or times of livestock movement

� Active traffic management by trained and visible staff at the site, if required for safe and convenient passage for the public.

� Ensuring safe and continuous access to office facilities, shops and residences during renova-tion activities, if the buildings stay open for the public.

J. Land and Water General land and water uses

(a) Internationally accepted good land use practices in place to minimize land degradation, and /or siltation in waterways

(b) Impoundments of water will not affect the upstream and downstream riparians (c) Minimize excessive groundwater extraction and put in place appropriate conservation of water

measures which can contribute to significant water savings

11

PART 3: MONITORING PLAN Section C: MONITORING PLAN

Phase What (Is the parameter

to be moni-tored?)

Where (Is the parameter

to be moni-tored?)

How (Is the parameter

to be moni-tored?)

When (Define the fre-quency / or con-

tinuous?)

Why (Is the parameter

being moni-tored?)

Cost (if not in-cluded in

project budg-et)

Who (Is responsible

for monitoring?)

During activity preparation

During activity

implementation

During activity

supervision

12