Environmental Management Plan Checklist and Format for Low-Risk Topologies

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized 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 Environmental 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, inclusive 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 template for a monitoring plan for activities during project construction and implementation (Section 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 highlighted (e.g. by hatching the field or copy pasting the relevant text passages into the special provisions 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 sustainability 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. 1

2 ANNEX 1: Format for Environmental Management Plan PART I: Activity Description Environmental Management Plan (EMP) Energy Small and Medium Enterprise Project Kenya (28 th November 2013) 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 Kenya 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 environmental laws and the World Bank s Safeguards Policy, this Environmental and Social Management 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 Assistance 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 delivery and utilization. 2

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 available 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 battery 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, conserve 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 Environment 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 business 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. Although 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 negative impacts and therefore the World Bank Operational Policy 4.01 on Environmental Assessment was triggered and the project was classified as EA category B. Sub-projects that could potentially trigger policies on Safety of Dams, Natural Habitats, Forestry, Pest Management, Cultural 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 instrument 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 3

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 establish 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 batteries. - Provide incentives for users to return used batteries to distributor 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 consolidated and reported through the GVEP Manager to the Bank on a regular basis. 4

5 Part II : EMP Checklist for Activities Section A: (a) INSTITUTIONAL & ADMINISTRATIVE Country Project title Scope of project and activity Institutional arrangements (Name and contacts) WB (Project Team Leader) Project Management Local Counterpart and/or Recipient Implementation arrangements (Name and contacts) Safeguard Supervision Local Counterpart Supervision Local Inspectorate Supervision OGL Distributor (b) SITE DESCRIPTION Name of site Describe site location Attachment 1: Site Map [ ]Y [ ] N Who owns the land? Geographic description (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 process took place (f) INSTITUTIONAL CAPACITY BUILDING Will there be any [ ] N or [ ]Y if Yes, Attachment 2 includes the capacity building program capacity building? 5

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 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 3. Individual wastewater treatment system Effluent and / or discharges into receiving waters 4. Historic building(s) and districts Risk of damage to known/unknown historical or archaeological sites 5. Acquisition of land 1 Encroachment on private property Relocation of project affected persons Involuntary resettlement Impacts on livelihood incomes 6. Hazardous or toxic materials 2 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 II 3 [ ] YES [ ] NO Activity Box A& B below [ ] YES [ ] NO Activity Box A& B below [ ] YES [ ] NO Activity Box A& C below [ ] YES [ ] NO Activity Box A& D below [ ] YES [ ] NO Activity Box A& E below [ ] 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 people 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, ) 6

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 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 9. Traffic and Pedestrian Safety Site specific vehicular traffic Site is in a populated area 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& G below [ ] YES [ ] NO Activity Box A& H below [ ] YES [ ] NO Activity Box A& I below [ ] YES [ ] NO Activity Box A& J below ACTIVITY BOX PARAMETER GOOD PRACTICES MITIGATION MEASURES CHECKLIST A. General Conditions Notification & Worker Safety (a) Consult with the Task Team Lead and World Bank Safeguard Coordinators 4 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 (always hardhats, as needed masks and safety glasses, harnesses and safety boots) B. General Rehabilitation and /or Construction Activities Air Quality (g) Appropriate signposting of the sites will inform workers of key rules and regulations to follow. (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 7

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 mechanical equipment should be closed, and equipment placed as far away from residential areas as possible 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 expected 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 D. Historic building(s) E. Acquisition of land Water Quality Cultural Heritage Land Acquisition Plan/Framework (a) The approach to handling sanitary wastes and wastewater from building sites (installation or reconstruction) 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 effluent quality and wastewater treatment (c) Monitoring of new wastewater systems (before/after) will be carried out (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 encountered in excavation or construction are noted, officials contacted, and works activities delayed or modified to account for such finds. (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 8

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 Pesticides (a) Waste (i.e., used batteries) are transported by specially licensed carriers and disposed in a licensed 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 (a) Follow recommend and minimum standards as described in the United Nations Food and Agriculture Organization (FAO) International Code of Conduct on the Distribution and Use of Pesticides (Rome, 2003) (b) Promote use of ecologically based biological or environmental pest management practices (integrated pest management IPM) G. Affects forests and/or protected areas H. Disposal of medical waste Protection Infrastructure for medical waste management (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. (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 9

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 Pedestrian Safety Direct or indirect hazards to public traffic and pedestrians by construction 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 interferes. 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 renovation 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 10

11 PART Section 3: C: MONITORING PLAN PLAN Phase What (Is the parameter to be monitored?) During activity preparation Where (Is the parameter to be monitored?) How (Is the parameter to be monitored?) When (Define the frequency / or continuous?) Why (Is the parameter being monitored?) Cost (if not included in project budget) Who (Is responsible for monitoring?) During activity implementation During activity supervision 11

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