03 Eepmas

You might also like

Download as pdf or txt
Download as pdf or txt
You are on page 1of 76

The World Bank

VOLUME I

INTRODUCTION AND
TECHNICAL GUIDELINES

Handbook for the Application of the


Enhanced Environmental Performance
Monitoring and Audit System of the
Philippine Environmental Impact
Assessment System

STRENGHTENING THE ENVIRONMENTAL PERFORMANCE MONITORING & EVALUATION


SYSTEM OF THE PHILIPPINE ENVIRONMENTAL IMPACT STATEMENT SYSTEM (SEPMES-PEISS)
VOLUME I

INTRODUCTION AND
TECHNICAL GUIDELINES

Handbook for the Application of the


Enhanced Environmental Performance
Monitoring and Audit System of the
Philippine Environmental Impact
Assessment System
HANDBOOK FOR THE APPLICATION OF THE ENHANCED ENVIRONMENTAL
PERFORMANCE MONITORING AND AUDIT SYSTEM OF THE PHILIPPINE
ENVIRONMENTAL IMPACT ASSESSMENT SYSTEM

VOLUME I:
INTRODUCTION AND TECHNICAL GUIDELINES

ISBN 971-8986-64-2

Published under the World Bank Institutional Development Facility (IDF) Grant
No. TF050534: Strengthening the Environmental Performance Monitoring and Evalu-
ation System of the Philippine Environmental Impact Statement System Project with
the cooperation of the Environmental Management Bureau-Department of Envi-
ronment and Natural Resources

Reproduction of this book in whole and in part in whatever manner is not allowed
except for citation in scholarly journals and other publications or review for print and
electronic mass media.

Maiden Issue January 2005

Printed in the Philippines

9876543210
ACKNOWLEDGEMENT

The preparation of this handbook is the result of the collaborative efforts of several individuals for
which we would like to extend our gratitude.

For his continued support and relentless encouragement, we would like to acknowledge former
DENR Undersecretary for Management and Technical Services Dr. Rolando L. Metin.

Similarly, we would like to acknowledge the Philippine Geothermal Incorporated and Na-
tional Power Corporation in Mak-Ban and Mirant Pagbilao and Mr. Jose Reynato M. Morente
of Mirant Philippines for their participation in pilot-testing of the proposed enhanced environmen-
tal monitoring and auditing scheme.

This is also to acknowledge the active participation of the pilot Multistakeholder Monitoring Teams
(MMTs): The Makban Geothermal Power Plant MMT especially Forester Luis L. Awitan of
Batangas PG-ENRO and Forester Edmund A. Guillen, Provincial Government Environ-
ment and Natural Resources Officer of Laguna and the Mirant Pagbilao Coal-fired Power
Plant MMT especially Quezon Provincial Administrator Evelyn S. Abeja and Ms. Ma. Elisa
O. Robles.

It is also with deepest sincerity that we extend our heartfelt appreciation to Dr. Maya G. Villaluz
of the World Bank for her invaluable support in the completion of this handbook.

And last but not the least, to the stakeholders of the Philippine EISS and M&A to whom this
undertaking is primarily dedicated.

JULIAN D. AMADOR
EMB Director
and SEPMES PEISS Project Director
The publication of this handbook evolved from a series of pilot-testing the environmental moni-
toring and audit scheme. The following have actively shared in carrying out this project:

MR. REYNALDO P. ALCANCES, Project Manager and Chief EIA Division


ENGR. PURA VITA G. PEDROSA, Deputy Project Manager
ENGR. ESPERANZA A. SAJUL, Chief Monitoring Section, EIA Division
ENGR. ELSIE CEZAR, Multi-Stakeholder Participation Coordinator
MS. CONSOLACION CRISOSTOMO, Foreign- Assisted Training Projects Coordinator
MS. JANUSETTE UY, Training Coordinator
MR. JONATHAN S. ABEJUELA, Financial Management and Disbursement Officer
MS SONIA C. ALCON, Logistics and Procurement Assistant

DR. MARLITO L. CARDENAS, Environmental Specialist and Volume 1 Author


DR. MARY ANN P. BOTENGAN, Participation Specialist and Volume 2 Author
MS MA. DULCE M. CACHA, Financial Specialist and Volume 2 Co-Author
MS JO ROWENA D. GARCIA, Institutional Specialist and Volume 3 Author
MS SOCORRO L. PATINDOL, Training Specialist

MR. MANUEL RAY M. ALMARIO, Technical Associate, Volume 1 Co-Author, Handbook


Layout and Graphics Artitst
MR. EDGAR A. DE JESUS, Technical Associate and Volume 1 Co-Author
MR. VANDERLEAF C. CAPALUNGAN, Institutional Associate and Volume 3 Co-Author
JULIUS E. REYES, Technical Research Associate
GERTIE M. APIGO, Technical Research Associate

Process Documentation Team Members:


ENGR. JESS L. ADDAWE
MR. RYAN FILIPERTO P. BOTENGAN
MS FILMA C. CALALO
MR. RONALD C. GARCIA
MR. ARMANDO C. RAMOS JR
MR. VICTOR N. MADLANGBAYAN

ENGR. MALOU AVENIDO, EIA Division Chief, EMB Region 3


MR. REDENTOR LAURETA, Chief Monitoring Section, EIA Division, EMB Region 3, PEMAPs

Pilot-test Participants:
MS. CHERRY SANTOS, EIA Division, EMB Region 3, PEMAPs Pilot-test Participant
FORESTER SALVACION P. VILLANUEVA, EIA Division Chief, EMB Region 4-A
FORESTER CORAZON C. GASAPOS, EMB Region 4-A Pilot-test Participant
ENGR. JENNIFER A. GAPPE, EMB Region 4-A Pilot-test Participant
DENR-PENRO DANILO MORALES, Batangas Province
MR. LEONEL F. BARTE, DENR-PENRO Batangas Province Office

ERIC M. LOPEZ, Handbook Technical Editor


RAY FRANCIS M. ALMARIO, Handbook Layout and Graphics Artist
Introduction and Technical Guidelines

TABLE OF CONTENTS
Volume 1: Introduction and Technical Guidelines
Acknowledgement
List of Tables .......................................................................................................... iv
List of Figures ........................................................................................................ v
List of Appendices .................................................................................................. vi
List of Acronyms/Terminologies ................................................................................ vii

PART 1: INTRODUCTION, OVERVIEW, BASES, ROLES, AND REQUIREMENTS

I.INTRODUCTION ................................................................................................... 1

A. BACKGROUNDER ..................................................................................... 1
1. The Philippine Environmental Impact Statement System .......................... 1
2. SEMPES-PEISS Project ....................................................................... 2
B. Highlights of the PEIS System Assessment .................................................. 3
1. Profile of the Regulated Community ........................................................ 4
2. Monitoring Performance based on ECC-issued Projects............................ 5
3. Organizational Structure, Capability and Financial Mechanisms ................ 6
a. Organizational Structure .................................................................. 6
b. Capability Assessment ................................................................... 7
c. PEISS M&E Financial Management and Administration ..................... 7
4. Multistakeholder Participation ................................................................ 10
C. Overview of the EIA M&A System Handbook ................................................. 11
1. Purpose, Legal Basis, and Target Users of the Handbook .......................... 11
2. Organization and Brief Description of the Handbook ................................. 12
a. Volume 1: Introduction and Technical Guidelines .................................... 12
b. Volume 2: Multistakeholder Participation ......................................... 12
c. Volume 3: Administrative Procedures ............................................... 12
3. Guidance on Use of the Handbook.......................................................... 13

II. Overview and Rationale of the Enhanced PEISS M&A System ........................ 14

A. Overview of the Enhanced PEISS M&A System ............................................. 14


B. Rationale for the Enhancements .................................................................. 15
C. The Generic EMA Process over the Project Lifecycle and EIA Stages.............. 15
D. Key Functions of the Project-level EIA M&A System ...................................... 22

III. PEISS M&A Stakeholders, Roles and Responsibilities,


and General Requirements ......................................................................... 23

A. Description of the EIA M&A System of the Three Lead EIA M&A
Stakeholders .............................................................................................. 23
1. Proponent-based EIA M&A System ........................................................ 23
2. Community-based EIA M&A System ...................................................... 24
3. EMB-based EIA M&A System ................................................................ 25

World Bank - DENR SEPMES PEISS i


B. Roles and Responsibilities of Stakeholders of the Enhanced
Project-level EIA M&A System ..................................................................... 26
C. Summary List of Technical Environmental
Documents/Reports to be prepared by the Key Actors ...................................... 26
1. Baseline Monitoring and Audit Plan and Manual (BEMAP/M) ....................... 30
2. Environmental Monitoring and Audit Plan and Manual (EMAP/M) ................. 31
3. Self-monitoring Report (EIA Module) .......................................................... 33
a. Baseline Environmental Monitoring and Audit Reports ........................... 33
b. Periodic Self-monitoring Reports ......................................................... 34
D. Selection and Prioritization of Projects for Monitoring ........................................ 35

PART 2: GUIDELINES IN IMPLEMENTING ENVIRONMENTAL MONITORING AND AUDIT


AND REPORTING SYSTEM

IV. GUIDELINES FOR PREPARATION OF BASELINE ENVIRONMENTAL


MONITORING AND AUDIT PLAN AND MANUAL (BEMAP/M) AND
ENVIRONMENTAL MONITORING AND AUDIT PLAN AND MANUAL
(EMAP/M) BY PROPONENT ......................................................................... 36

A. NATURE AND PURPOSE .............................................................................. 36


1. Baseline Environmental Monitoring and Audit Plan and Manual .................... 36
2. Environmental Monitoring and Audit Plan and Manual ................................. 39
B. CONTENTS OF THE BEMAP/M and the EMAP/M ........................................... 40
1. Executive Summary ................................................................................ 41
2. Environmental Policy and EM&A Objectives ............................................... 42
3. Baseline Monitoring ................................................................................ 42
4. Compliance Monitoring ............................................................................. 43
5. Impact Monitoring .................................................................................... 43
a. Identification of Significant Environmental Aspects and Impacts ............. 43
b. Selection of Monitoring Parameters .................................................... 45
c. Sampling and Measurement Plan ....................................................... 46
d. Setting Environmental Quality Performance Levels ............................... 49
6. Budget ................................................................................................... 50
7. Accountability ......................................................................................... 51
8. Stakeholder Participation .......................................................................... 51
9. Complaints Management, Communication and Reporting ............................ 51
10. Environmental Impact Event / Action Response Plan ................................... 52
11. Audit Plan or Program .............................................................................. 52
12. Schedule for Baseline Monitoring and Preparation of BEMAM/EMAM
for Design, Construction, Operation, and Decommissioning Phases .............. 52

V. GUIDELINES FOR PREPARATION OF THE BASELINE


ENVIRONMENTAL MONITORING AND AUDIT REPORT AND
SELF-MONITORING REPORT BY PROPONENT............................................... 53

A. PURPOSE OF THE GUIDELINES ................................................................... 53


1. Baseline Environmental Monitoring and Audit Report ................................... 53
2. Self-monitoring Reports ............................................................................. 53

ii World Bank - DENR SEPMES PEISS


B. CONTENTS OF THE BASELINE ENVIRONMENTAL MONITORING
AND AUDIT REPORT AND THE SELF-MONITORING REPORT
(EIA MODULE) .............................................................................................. 54
1. Executive Summary ................................................................................. 54
2. Introduction ............................................................................................. 54
3. Project Background ................................................................................. 54
4. Methodology ........................................................................................ 55
5. Results and Discussion ........................................................................ 55
a. Summary of Previous Monitoring ..................................................... 55
b. Reports of Complaints and Environmental
and Health-related Accidents ...................................................... 56
c. Current Monitoring Results and Findings ........................................... 57
6. Conclusions and Recommendations ....................................................... 57
a. Compliance Status ......................................................................... 57
b. Environmental Quality Status ........................................................... 58
c. Environmental Management Plan Status ........................................... 58
d. PEMAPS Score ............................................................................ 58
e. Work Plan for Next Monitoring Period ............................................... 58

References ............................................................................................................ 59
Appendices............................................................................................................. 61

World Bank - DENR SEPMES PEISS iii


List of Tables
Table Page

1-1 2002 Accomplishments of EMB CO and Region 3 Office 7


1-2 Summary of Technical and Institutional Aspects
of the System Assessment 8
2-1 List of Current Practices and Proposed Enhancements 16
3-1 Roles and Responsibilities of the Stakeholders of the
Enhanced Project-level EIA M&A System 27
3-2 List of Technical Environmental Reports to be Prepared by
the Key Actors under the Proposed Enhanced PEIS EMA System 29
3-3 Sample Risk-Based Environmental Monitoring and Audit
Strategy Selection Matrix 36
4-1 Environmental Monitoring and Audit Summary Matrix 41
4-2 Selection of Parameters for Monitoring of Critical Environmental
Aspects and Impacts (EA&I) 47
5-1 Summary Matrix for BEMAR & SMR 54
5-2 Dummy Table for Reporting Methodological Revisions 55
5-3 Summary Table for Reporting Monitoring Results 57

iv World Bank - DENR SEPMES PEISS


List of Figures
Figure Page

1-1 Certificates issued by DENR and EMB: 1980-2003 4


1-2 Profile of the Regulated Community by Major Project Type: 1980-2003 5
1-3 Current Status of PEISS Monitoring 6
2-1 PEISS M&A System Framework 14
2-2 Generic Simplified EMA Process over the Project
Life-cycle and EIA Stages 21
2-3 Enhanced Community-based Multipartite Monitoring and Audit System 22

World Bank - DENR SEPMES PEISS v


Introduction and Technical Guidelines

List of Appendices
Appendix

1 Project Environmental Monitoring and Audit Prioritization Scheme (PEMAPS)


2 Examples of Environmental Policy, Objectives and Targets
3 EMB Compliance Monitoring Form No. CM-3
4 Stressor-impact Matrices for Various Power Project Types
5 Environmental Stressor Rating Scheme (ESRS)
6 Sampling and Measurement Plan (SAMP) Matrix
7 Example of Environmental Quality Performance Levels (EQPLs)

vi World Bank - DENR SEPMES PEISS


List of Acronyms/ Terminologies
ADB Asian Development Bank
AI Additional Information
AO Administrative Order, a legal issuance of the Philippine President
AOAC Association of Official Analytical Chemists
APHA American Public Health Association
ASTM American Society for Testing Materials
AWFP Annual Work and Financial Plan
BEMAP Baseline Environmental Monitoring and Audit Plan
BEMAM Baseline Environmental Monitoring and Audit Manual
BOD Biochemical Oxygen Demand
CARP Comprehensive Agrarian Reform Program
CDO Cease and Desist Order
CENRO Community Environmental and Natural Resources Office(r)
CFCs Chlorofluorocarbons
CMVR Compliance Monitoring and Validation Report
CL Clearance Letter
CO Central Office; carbon monoxide
COC Chain of Custody
COD Chemical Oxygen Demand
COE Code of Ethics
DAO Department Administrative Order, this refers to a legal issuance
of the Department of Environment and Natural Resources
dbh Diameter at Breast Height of a tree
DBM Department of Budget and Management
DENR Department of Environment and Natural Resources
DO Dissolved Oxygen
DQI Data Quality Indicator
DQO Data Quality Objective
EA&I Environmental Aspects and Impacts, refers to a project’s environment-relevant
activities and elements (environmental aspects) and their singular or joint
effects on the environment (environmental impacts)
EBMR Environmental Baseline Monitoring Report
ECA Environmentally Critical Area
ECC Environmental Compliance Certificate
ECIMR Environmental Compliance and Impact Monitoring Report
ECP Environmentally Critical Project
EGF Environmental Guarantee Fund
EIA Environmental Impact Assessment
EIAD Environmental Impact Assessment Division
EIAMD Environmental Impact Assessment and Management Division
EIS Environmental Impact Statement
EM&A or Environmental Monitoring and Audit, refers to a process to followup EIA
EMA recommendations during implementation of a project granted an ECC
with the goal of improving the project’s environmental performance
EMAF Environmental Monitoring and Audit Fund

World Bank - DENR SEPMES PEISS vii


Introduction and Technical Guidelines

EMAM Environmental Monitoring and Audit Manual


EMAP Environmental Monitoring and Audit Plan
EMB Environmental Management Bureau, a line bureau of DENR mandated
to implement the Philippine EIS System
EMF Environmental Monitoring Fund
EMP Environmental Management Plan
EMoP Environmental Monitoring Plan
ENRO Environmental and Natural Resources Office(r)
EQPL Environmental Quality Performance Level(s)
ES Environmental Stressor
ESRS Environmental Stressor Rating Scheme
ExeCom Executive Committee
FCZ Foreshore Costal Zone
FGD Focus Group Discussion
GA Government Agency
GHG Greenhouse Gases
GO Government Office
GOP Government of the Philippines
IEC Information, Education, and Communication
IRR Implementing Rules and Regulations
KII Key Informant Interview
LCS Laboratory control samples
LGU Local Government Unit
M&A Monitoring and Audit
M&E Monitoring and Evaluation
MACOM Monitoring and Audit Committee
MFR Motion for Reconsideration
mg/cu m milligram per cubic meter
MMAS Multipartite Monitoring and Audit System
MMT Multipartite Monitoring Team
MOA Memorandum of Agreement
MOO Manual of Operations
MSP Multistakeholder Participation
NA Not Applicable
NECP or Non-Environmentally Critical Project
Non-ECP
NGA National Government Agency
NGO Nongovernment Organization
NOx Nitrogen Oxides
NOV Notice of Violation
NRIPS National/Regional Industry Prioritization Scheme
PCS Pollution Control System
PD Presidential Decree
PEIS or PEISS Philippine Environmental Impact Statement System
PEMAPS Project Environmental Monitoring and Audit Prioritization Scheme
PEPP Philippine Environmental Partnership Program
pH Measure of acidity or basicity of a liquid
PM10 Particulate Matter with less than 10 micron diameter
PM&E Participatory Monitoring and Evaluation
PO People’s Organization
QA/QC Quality Assurance/Quality Control

viii World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

RA Republic Act
RevCom EIA Review Committee
RO Regional Office
SAMP Sampling and Measurement Plan
SDP Social Development Program
SEAI Significant or Critical Environmental Stressors and Impacts
SEECCTA Strengthening Environmental Enforcement and Compliance Capacity
Technical Assistance Project
SMEs Small and Medium Enterprises
SMR Self-monitoring Report
SOx Sulfur Oxides
SRU Sectoral Regulatory Unit
SS Suspended Solids
TSP Total Suspended Particulates
URL Universal Resource Link
URTI Upper Respiratory Tract Infection
VOCs Volatile Organic Carbon
WB The World Bank

World Bank - DENR SEPMES PEISS ix


Introduction and Technical Guidelines

VOLUME 1

Introduction and Technical Guidelines

PART 1: INTRODUCTION, OVERVIEW, BASES, ROLES, AND REQUIREMENTS

I. INTRODUCTION
The Environmental Impact Assessment and Management Division formerly known as the Environ-
mental Impact Assessment Division (EIAD) of the Environmental Management Bureau (EMB),
Department of Environment and Natural Resources (DENR) publishes this three-volume Hand-
book as a set of guidelines to make the Philippine Environmental Impact Statement System (PEIS
System or PEISS) responsive to the policy goals of Presidential Decree 1586. In similar direction,
the Handbook provides a basis to establish a more efficient and effective platform in consolidating
multistakeholder collaboration in advocating environmentally sound project undertakings.

The Handbook was prepared with the financial support of the World Bank (WB) under its Institu-
tional Development Facility Grant No. TF050354 through a project entitled “Strengthening the
Environmental Performance Monitoring and Evaluation System of the Philippine Environmental
Impact Statement System” (SEPMES-PEISS). The Handbook shall be known as the “Environ-
mental Performance Monitoring and Audit System Handbook” or “EPMA System Handbook” or
PEISS M&A System Handbook.

A. BACKGROUNDER

1. The Philippine Environmental Impact Statement System

Presidential Decree (PD) No. 1151, entitled the “Philippine Environmental Policy” man-
dated the creation of the Environmental Impact Statement (EIS) System in the Philip-
pines. Issued in 1977, PD 1511 (section 4) explicitly requires “all agencies and instru-
mentalities of the national government, including government-owned and controlled
corporations, as well as private corporations, firms and entities to prepare an environ-
mental impact statement (EIS) for every action, project or undertaking which signifi-
cantly affects the quality of the environment.”

The Philippine EIS System was formally created in 1978 by PD No. 1586. Pursuant to
the policy statement of PD 1151, it declared environmentally critical projects (ECPs)
and projects located within environmentally critical areas (ECAs) as projects which
require the submission of an EIS. Section 4 of PD 1586 states that “no person, partner-
ship or corporation shall undertake or operate any or in part such declared ECP or
project within an ECA without first securing an Environmental Compliance Certificate
(ECC).” PD 1586 also identified the lead agency for the implementation of the EIS
System and provided sanctions for its violation.

The major categories of ECPs and ECAs were mandated through Presidential Procla-
mation No. 2146, series of 1981. The categories were given technical definitions by
EMB’s predecessor agency, the National Environmental Protection Council (NEPC),
through NEPC Office Circular No. 3, series of 1983.

World Bank - DENR SEPMES PEISS 1


Introduction and Technical Guidelines

PD 1586 was implemented through the issuance of a number of administrative regula-


tions and guidelines. The first of such administrative issuance is the implementing
rules and regulations (IRR) released by NEPC in 1979, and amended in 1984.

Over the years, the PEISS was subjected to several refinements to make it a more
effective planning, management, and regulatory tool in addressing environmental prob-
lems in the country. Innovative features and requirements were adopted in response to
changing political, economic, and social realities, the growing environmental conscious-
ness of the Filipinos and the worsening environmental deterioration.

Upon assuming the NEPC’s mandate, DENR subsequently amended NEPC-issued


rules through its issuance of Department Administrative Order (DAO) No. 21 in 1992.

Chiefly, the need to sustain the environment’s carrying capacity and its productive
balance stood as riveting backdrop of the expanding and diversifying activities of the
industry sector in the succeeding years. Across this period, new issues over PEISS
underpinned for a more rational basis to qualify and expand its scope and to further
attune the sector’s activities with sustainable development.

On 2 Dec. 1996, the DENR issued DAO No. 96-37 to further strengthen the PEISS. On
2 Nov. 2002, the Office of the President issued Administrative Order No. 42 (A.O. 42)
which intends to rationalize the implementation of the PEISS to make it a more effective
planning as well as management tool for sustainable development.

The IRR of A.O. 42 was issued as DAO No. 03 series of 2003 or DAO 2003-30.
The procedural manual was released in December 2004.

A key requirement under DAO 03-30 is the establishment of an EIA Monitoring and
Evaluation (M&E) System as a tool for strengthening EIA Follow-up and Implementa-
tion. This three-volume Handbook presents the key features and implementation re-
quirements of the Enhanced Monitoring and Audit (M&A) System of the PEISS.

2. SEPMES-PEISS Project
The “Strengthening the Environmental Performance Monitoring and Evaluation System
of the Philippine Environmental Impact System (SEPMES-PEISS)” Project is managed
by EMB-EIAMD and funded by the World Bank under its Institutional Development
Facility Grant No. TF050534. The Grant Agreement was signed on 29 Jan. 2002 and
was concurred by the Government of the Philippines (GOP) through the Department of
Finance on 1 Feb. 2002.

The objectives of SEPMES-PEISS are to:


1. strengthen the monitoring and evaluation aspect of the EIS System by implement-
ing an EIS M&E model based on a comprehensive analysis of the System taking
into consideration the various constraints (e.g., financial, institutional, regulatory)
as well as focusing on the most critical environmental concerns of development
projects, minimizing duplication of functions among different government agencies
and encouraging cooperation among various stakeholders;

2 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

2. strengthen the capability of the environmental regulatory agency tasked to imple-


ment the EIS System, encourage LGUs and communities in the monitoring, evalu-
ation, and reporting of compliance to environmental rules and regulations (including
the implementation of the Environmental Management plans by Project Propo-
nents), especially the World Bank supported projects; and

3. improve the capacity of GOP to develop and adopt innovative financial and institu-
tional mechanisms including participatory approaches that will ensure continued
implementation of EMPs and compliance to environmental covenants.

The SEPMES-PEISS Project has three components to accomplish each of the follow-
ing main tasks:

1. carry out a comprehensive assessment of the policy, legal, and regulatory and
institutional frameworks governing the EIS Monitoring and Evaluation and develop
an enhanced EIS Monitoring and Evaluation Model;

2. determine the effectiveness of the EIS M&E Model through pilot-testing and en-
hancing the capability of the regulatory agency in the implementation of the EIS
M&E Model; and

3. develop and implement mechanism to encourage public disclosure of environmen-


tal performance and multistakeholder participation in EIS Monitoring and Evalua-
tion.

The project ended in January 2005. The PEISS M&A System and this Application
Handbook are the main deliverables of the SEPMES-PEISS Project. These outputs
resulted from a comprehensive PEIS System Assessment as well as design, pilot-
testing, consultations on, and finalization of the PEISS M&A System. The highlights of
the PEIS System Assessment are presented in the following section.

B. HIGHLIGHTS OF THE PEIS SYSTEM ASSESSMENT

The PEIS System Assessment was aimed at:


• assessing policy and practice of the PEISS M&E System, and
• recommending improvements to the PEISS M&E System.
The System Assessment focused on the following tasks:
• Understanding the origin, characteristics and structure of the current PEISS M&E Sys-
tem
• Estimating the size of the regulated community to be monitored and analyzing the
major PEISS M&E requirements
• Assessment of the environmental aspects of the project-based M&E functions
• Assessment of the institutional aspects of EMB as the lead PEIS M&E unit
• Assessment of the multistakeholder participation in PEISS M&E
• Assessment of the institutional linkages of DENR on PEISS M&E
• Assessment of the legal framework for the management of environmental performance/
other legal issues

World Bank - DENR SEPMES PEISS 3


Introduction and Technical Guidelines

The results of the System Assessment were used as a major basis for designing the EIA
M&A System. The major findings are briefly presented in the following.

1. Profile of the Regulated Community


The regulated community encompasses those projects that are covered by PEISS,
either as ECPs or ECAs. These projects may be captured in the System through the
application for and issuance of ECCs to covered projects. Those covered projects
operating without ECC are in violation of PD 1586 and subject to cease-and-desist
proceedings. Projects which applied for and are issued either a Certificate of Non-
Coverage (CNC) or an Environmental Compliance Certificate (ECC) are followed up
through Post-ECC monitoring and evaluation.

From 1980 to 2003, DENR and EMB issued more than 23,000 certificates (see Figure
1-1). Most of these issued certificates (around 83%) are ECCs based on the PD/IEE,
a simpler form of EIA documentation. A total of 1,993 ECCs were issued based on the
EIS, the more comprehensive EIA documentation. About the same number (1,993 or
9%) of projects were issued CNC and thus, do not normally require monitoring and
evaluation. All in all, more than 21,000 ECCs were issued over this period of study.

Figure 1-1 Certificates Issued by DENR and EMB: 1980-2003.

A breakdown of projects issued ECCs by major project type by DENR and EMB CO is
shown in Figure 1-2. The Resource Extractive Industries account for 48%, followed by
Infrastructure at 30%, then Heavy Industries at 17%, SMEs 3.4%, Golf Courses 1.4%,
and lastly, Biodiversity and Reforestation 0.15%.

4 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Figure 1-2 Profile of the Regulated Community by


Major Project Type: 1980-2003.

2. Monitoring Performance based on ECC-issued Projects


The current status of PEISS monitoring as of 2002 is given in Figure 1-3.

Out of the more than 21,000 projects issued ECCs, around 3,000 were monitored.
These consisted of 17.60% of IEE monitored by EMB RO, 0.20% of EIS monitored by
CO, 0.20% of EIS monitored by MMTs, and 0.01% of IEE monitored by MMTs. What
is alarming in these figures is the proportion of unmonitored projects which accounts for
around 82% of projects issued ECCs. By any standard, this monitoring performance is
not tenable if the PEISS goal of environmental protection is to be significantly achieved.
Thus, improvements in the PEISS M&E System must be identified and implemented on
a continuous basis. Such improvements or enhancements must consider current ca-
pacity constraints of the DENR-EMB to be effective and sustainable. This Handbook
presents various enhancements which will increase the productivity of each major actor
even with current levels of budget and logistics.
One key area for enhancement is the preparation, approval, and implementation of the
Environmental Monitoring Plan (EMoP). The System Assessment indicated that the
EMoPs are generally of poor quality and oriented mostly to compliance monitoring and
to lesser extent to impact monitoring. The parameters monitored cover all impacts
identified during the EIA study instead of being selective to the more critical ones.
However, the socioeconomic and ecosystem impacts are less considered. Also, there
is little evaluation or audit EMoPs. Proponents with certified EMS such as ISO 14000
series, however, undergo third-party audit.

World Bank - DENR SEPMES PEISS 5


Introduction and Technical Guidelines

Figure 1-3. Current Status of PEISS Monitoring

3. Organizational Structure, Capability, and Financial Mechanisms

a. Organizational Structure
The EIA Division has been an ad hoc division of then NEPC and present EMB since
PEISS was established. As such, there is no plantilla organization and all the staff
members are either seconded from other divisions or contractual (the greater ma-
jority). This is an overwhelming constraint, but, as accomplishments have shown,
not insurmountable.

Table 1-1 shows the 2002 Accomplishments of CO and Region 3 Office. Based on
the reported accomplishments, it was estimated that CO must have a staffing
complement of 18 technical staff but actually has only 12 and all are contractual.
On the other hand, Region 3 Office has a staffing complement of 2 permanent and
4 contractual technical staff but required an additional 22 people for its level of
accomplishments. The lack of personnel suggests that the quality of service ren-
dered and other tasks such as monitoring and evaluation must have also suffered
inspite of the remarkable efforts from the current staff members. The overall poor
monitoring performance of 18% of ECC-issued projects (see Figure 1-3) validates
this finding.

The recently issued AO 42 by the President recognizes this organizational weak-


ness which subsequently created a regular EIAM division. However, the Depart-
ment of Budget and Management (DBM) has yet to favorably act on the request for
plantilla positions and operating budget. Moreover, in view of the of the the govern-

6 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

ment budgetary shortfall, all contractual positions are to be abolished in 2005. This
will leave EIAMD with no personnel except for a few seconded EMB staff and
shared personnel from field units of DENR.

Aside from the lack of EMB personnel for M&E functions, there are other concerns
identified during the System Assessment. A tabular summary of the main technical
and institutional findings is shown in Table 1-2.

The institutional and technical concerns have been addressed by this three-volume
Handbook.
b. Capability Assessment

The main findings of the Capability Assessment is that the MMTs and EMB/DENR
field personnel are, with few exceptions in some EMB ROs, not technically quali-
fied and experienced to conduct appropriate and scientifically credible monitoring
and evaluation studies. In particular, the surveyed persons have difficulty in techni-
cal sampling and data processing and almost nil skills in laboratory analyses.
However, they are good in preparing reports. This situation indicates that there is
much to be improved in terms of training. The lack of skills is exacerbated by the
poor logistics support, such as vehicles, field sampling equipment and measure-
ment kits, and minimal operational budget for per diems and miscellaneous and
incidental expenses.

c. PEISS-M&E Financial Management and Administration


Three of the four current EIA financial mechanisms, namely, ERF, Review Support
Fund, and EMF were created to fund activities related to the implementation of the
EIS system. EGF, on the other hand, is a mechanism to ensure that the Proponent
will be held responsible or will pay for the prevention, rehabilitation or restoration of,
and actual damages to life, health, property, and environment that may be brought

World Bank - DENR SEPMES PEISS 7


Introduction and Technical Guidelines

Table 1-2.
Summary of Technical and Institutional Aspects of the System Assessment

Strength / Good Practice Gap / Weakness


TECHNICAL
1. Lack of documented systematic guidelines on
M&E
a. Defining the objectives, coverage & methods for
EMA (only compliance M&E: No baseline M&E,
1. EIAMD CO initially developed the PEISS limited Impact M&E, no environmental audit)
database/ MIS for EIS review, M&E, & adjudi- b. Criteria for selection and prioritization of projects
cation functions for M&E (driven by public pressure)
c. Content & organization of EMoP (no EMoP/poor
EMoP design)
d. Technical Guidelines for MSP in EMA (M&E
Mechanics only in MOA, no Manual)
e. Review Criteria of Proponent’s performance (lack
of M&E technical review criteria)
2. EMB has developed standardized review 2. PEISS database largely contains project metadata
and monitoring forms; and an operational and no interoffice/interagency networking
document tracking system
3. EMB CO has documented its existing
review and M&E Operational Control Proce-
dures for the PEISS
4. Most EIAMD RO practice integrated
compliance monitoring with EQD
INSTITUTIONAL
1. EIAMD is systems-oriented, i.e., ISO 1. Lack of integrated M&E goal
14001-certified
2. EIAMD/EMB has developed partnerships 2. Too centralized functions, inadequate structure
and linkages since 1992 (18 MOAs on and manpower (CO:12 current technical staff vs 21
PEISS + several LGU MOAs) required; R3: 6 technical current vs. 37 required)

3. EIAMD CO/RO practice a more defined/ 3. Lack of definite timelines, authorities, liabilities in
detailed system in handling violations than resolving complaints/ violation information, and legal
what is provided in the Procedural Manual protection to EMB personnel
4. EIAMD CO/ROs despite limited manpower
4. Weak M&E linkaging within and outside DENR
and financial resources were able to attain
significant accomplishments (e.g., processed
>20,000 ECCs since 1980)
5. No review on the effectiveness of the existing 18
interagency MOAs on PEISS implementation

8 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

about by its project or undertaking.

The proponents or the industry can view these financial mechanisms in the follow-
ing manner:
• Paying penalties (source of the ERF) can be avoided if it complies with the
:
laws (particularly PD No. 984 and 1586), and its rules and regulations;
• Paying a certain amount of fee to hasten the processing of an application for
clearance will eventually result in savings and lower total business costs if
such will result in shorter processing time;
• The MMT activities (funded by EMF), within reasonable limits, will not only
improve relation with the community but will also serve as a confirmation of the
internal or self-monitoring mechanism, which will lessen overall risks in poten-
tial damages due to its operations/undertaking; hence lessen the actual charges
that may be made against EGF or other forms of insurance or financial instru-
ments;
• Reasonable expenditures on the education of the community (charged against
EGF) will eventually prevent further damages due to accidents or increase the
pool of capable workers, while expenditures on livelihood will enhance or uplift
economic circumstances that will lessen undesirable/criminal incidences and
improve economic activities within the area.

With these obviously rational behaviors that can be expected of the industry/propo-
nents on the various financial mechanisms, the following must be considered in
reviewing and assessing the various mechanism: 1) receipts from penalties will
eventually become less as the industry or business being monitored becomes
aware of the law and sees it more beneficial to comply with the law; 2) as the
economy improves, there will be more businesses that will apply for clearance; 3)
businesses or businessmen are willing to pay reasonable fees as long as they get
what they need on time or promptly; 4) awareness of the environment and public
participation can only increase over time and it is good business sense to be
transparent and open to public participation; 5) it is the responsibility of the local
government units to monitor industries within their area of jurisdiction; 6) while
corporate social responsibility is a sound business policy, not all companies are up
to facing their responsibilities especially when confronted with potential additional
cost.

The various innovative funding mechanisms were devised to support the proper
implementation of the EIS system which has been allocated with limited resources
from the general fund or regular appropriations. It was also a creative way of avoid-
ing the legal requirement of depositing all collection with the National Treasury or
General Fund and which will not be available for its operations. While the mecha-
nisms provided flexibility and enabled the undertaking of the critical pro-
cesses in EIS system, it remains remedial in nature. There is still the real need
to further strengthen and institutionalize the implementation of the EIS system,
funding sources included.

Over the years, the requirements of the EIS system have multiplied. The organiza-
tion mandated to implement the system has gone through a number of modifica-

World Bank - DENR SEPMES PEISS 9


Introduction and Technical Guidelines

tions, being transferred from one department to another, merged with other organi-
zation, converted from a council to a staff bureau and then line agency. The orga-
nizational unit in charge of its implementation started as an ad hoc unit and re-
mained such through all these transformations of its mother organization. Admin-
istrative Order No. 42, Rationalizing the Implementation of the Philippine EIA
System...was issued on 2 Nov. 2002 by President Arroyo. This AO, aiming to
remedy the negative impact of an inefficient implementation of the EIS system on
the country’s economic development, mandated, among others, the conversion of
the ad hoc EIA unit at the Central and Regional Offices into full pledged division.
Given such mandate, it has to be done within the existing budgetary resources and
within the government system. Hence, even if funds are available through the
various EIA financial mechanisms, the conversion of the ad hoc unit into “full pledged
division” will have to be done without using such funds or funding sources.
Thus, it becomes apparent that while “extra-budgetary” financial mechanisms
can provide necessary support and flexibility for operation, they cannot
provide institutional/ organizational requirements, particularly the itemized
positions and regular budget for operations. Hence, tedious the processes may
be, sustainable funding sources will have to be worked out within the na-
tional budgetary and accounting systems.
4. Multistakeholder Participation
The major findings of the assessment of MMT, currently the main mechanism of
multistakeholder participation in PEISS, are as follows:
• Skewed participation of two stakeholder groups (EMB and Proponent to the detri-
ment of the third group (the local stakeholders);
• Stakeholder identification limited to project impact area boundaries;
• Confused and inconsistent organizing of MMT ;
• Vague expectations as regards MMT functions;
• Irregularity of EMB-DENR attendance to MMT activities and as Chair;
• Disparate MMT organization and structure across areas;
• Lacking substantive provisions in the Pro-forma Memorandum of Agreement;
• Dearth of MMT Manual of Operations; and
• Unclear public disclosure, complaints, reporting, and IEC guidelines.

10 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

C. OVERVIEW OF THE EIA M&A SYSTEM HANDBOOK

1. Purpose, Legal Basis, and Target Users of the Handbook


This Handbook describes the administrative and technical procedures for the applica-
tion of the enhanced model for the Environmental Impact Assessment (EIA) Monitoring
and Audit (M&A) System in the Philippines for all phases of a project. It provides
detailed instructions to the EMB regulatory staff, project proponents, and stakeholders
who will be the major players in the implementation of the proposed enhanced model.

The enhanced system is part of the EIA Follow-up or Post-ECC Requirements needed
to ensure that the projects covered by the EIA system cause no or minimal undesirable
or unacceptable impacts on the environment and attain and maintain optimum environ-
mental performance. There are however enhancements introduced during the Pre-ECC
Phase that set the staging point for an effective Environmental Performance Monitoring
and Audit System

The specific purposes of this Handbook are to:


• describe the Enhanced EIA M&A Model as an EIA policy instrument for attaining
and maintaining optimum project environmental performance;
• provide administrative and technical guidelines on applying the model for the regu-
lated projects under the PEISS;
• illustrate procedures for operationalizing multistakeholder participation; and
• elucidate capability building measures to effectively apply the Model.

The Handbook is anchored on several environmental laws and policy pronouncements,


namely:
• PD 1152 (Environmental Code) and PD 1586 (basic EIA law)
• DAO 96-37 (IRR)
• Memorandum Circular on Revised 2nd Edition of the DAO 96-37 Procedural Manual
• DAO 2000-05 (Programmatic Compliance EIA)
• DAO 2003-14 (PEPP)
• AO 42 (2003) and DAO 2003-30 (EIA IRR)
• DAO 2003-26 (Ecowatch)
• DAO 2003-27 (Self-monitoring Reports) and Procedural and Reference Manual
• DAO 2003-30 Procedural Manual

The complete text of these legal issuances may be downloaded from the DENR
(www.denr.gov.ph) and the EMB (www.emb.gov.ph) websites.
The primary target end-users are the key stakeholders of the enhanced Model, namely
the EMB officials and staff as the regulatory agency or first party, the proponent or
regulated community as the second party, and the local stakeholders (including LGUs)
as the host community or third party, and other third-party entities such as the indepen-
dent environmental auditor, media, civil society, other concerned sectors and technical
resources engaged in the EIA M&A activities.

World Bank - DENR SEPMES PEISS 11


Introduction and Technical Guidelines

2. Organization and Brief Description of the Handbook


The Handbook is divided into three volumes, as follows:
• Volume 1: Introduction, PEISS M&E System and Technical Guidelines
• Volume 2: Multistakeholder Participation
• Volume 3: Administrative Procedures

a. Volume 1: Introduction and Technical Guidelines


The major topics of Volume 1 are as follows:
• Introduction
o Backgrounder
o Highlights of System Assessment
o Overview of the Handbook
• The Proposed Enhanced PEISS M&A System
o Overview of the Enhanced PEISS M&A System
o Rationale of the Enhancements
The Generic EM&A Process over the Project Life Cycle and EIA Stages
o Key Functions of the Project-level PEISS M&A System
• Technical Guidelines for the Preparation of:
o Environmental Monitoring and Audit Plan and Manual, including Baseline
EMAP/M
o Self-Monitoring Report, including Baseline EMA Report and PEMAPS

b. Volume 2: Multistakeholder Participation


The major topics of Volume 2 are as follows:
• Nature and Concept of Participation
• Stakeholder Identification and Analysis
• Formation of the Multipartite Monitoring Team (MMT)
• Operationalizing the MMT Monitoring
• Environmental Monitoring and Audit Fund Mechanism
• Monitoring and Validation Activities
• Public Disclosure and IEC
• MMT Performance Audit

c. Volume 3: Multistakeholder Participation


The major topics of Volume 3 are as follows:
• Administrative Procedures for the Review and Validation of following documents:
o Environmental Monitoring and Audit Plan (EMAP) and Manual (EMAM) of
Proponents
o Selfmonitoring Report (SMR) and Baseline Environmental Monitoring and
Audit Report (BEMAR) of Proponents
o Manual of Operations (MOO) with Code of Ethics of the Multipartite Moni-
toring Teams (MMTs)
o Compliance Monitoring and Validation Report (CMVR) of the MMTs
o Annual Work and Financial Plan (AWFP) for EIA Monitoring and Audit of
EMB ROs and MMTs

12 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

o Project Environmental Monitoring and Audit Prioritization Scheme


(PEMAPS) Reports of EMB Regional Offices and Proponents
• Administrative Investigation and Enforcement Procedures
• EMA System and Performance Audit Protocols

Volume 3 has the objective of providing systematic guidance primarily to DENR-


EMB and MMTs on the implementation of the functions of the EMA System.

This Handbook is also applicable to the Proponent as well as to other PEISS


stakeholders who may want to undertake an internal review and self-audit of their
EMA plans, reports, and over-all performance against the PEISS standards as
provided for in the legislation, its Implementing Rules and Regulations, and sup-
porting Procedural Manuals.

This Handbook provides step-by-step procedures, timelines, delineated responsi-


bilities and authorities as well as support forms and criteria to ensure effective and
efficient implementation of the EMA functions and proper documentation of the
EMA performance. It supports the EMB thrust towards a substantive and progres-
sive analysis of the EMA data for the EMA planning, policy enhancements, deci-
sion-making and last but not least, for public information towards well-informed and
more meaningful participation in EMA of projects and their environs. The Handbook
is, thus, a very practical tool, for the continual improvement of the EMA System.

3. Guidance on Use of the Handbook


The three-volume System Handbook will play a key role in the institutionalization of the
enhanced PEISS M&A System. The Institutionalization Action Plan (IAP), a separate
report and one of the major outputs of the SEPMES-PEISS Project, details the pro-
posed implementation schedule, the initial phases of which is the timely issuance of
policy statements and guidelines and capacity building program especially in the use of
this handbook.

PEMAPS is one enhancement that may be effected immediately after the initial strate-
gic planning and training of concerned personnel without any new policy issuance.
EMB regional offices may prepare their annual EMA plans using the results of PEMAPS.
Likewise, proponents may begin incorporating PEMAPS and other enhancements in
their SMRs on a voluntary basis while awaiting the new policy issuance.

Another enhancement not requiring policy issuance but EMB approval is the formation
and operation of the local MMTs and existing MMTs under the new guidelines initially
on a voluntary basis initially until the new policy is issued.

World Bank - DENR SEPMES PEISS 13


Introduction and Technical Guidelines

Figure 2-1. PEISS M&A System Framework

PROCESS OUTPUT OUTCOME


(Planning,
INPUT Improved
Implementation
& Evaluation) Proponent /
EMA Plans/ DENR /
1) Core Functions Manuals; Community /
1. Management (project-based) Other
Directions EMA institutional Stakeholders’
a) Preparation of
instruments Performance
Post-ECC EMA
requirements (e.g., MOA) ——————
2. Project Profile b) EMA Proper Improved
(Baseline, EMA Reports; Project
3. Project Compliance & Design &
Requirements Impact EMA Decision Operations
Monitoring & Documents; —————
4. Process, Validation)
Procedures Improved
c) Surveillance of
Projects Audit Reports; Stakeholder
5. Tools without ECC Participation
d) Administrative Proposed & Partnership
6. Stakeholders Investigation System ——————
of Issues Improvements Improved
7. Resources
Environmental
2) System
Status
Management
Functions ——————
Sustained
Development

II. OVERVIEW AND RATIONALE OF THE ENHANCED PEISS M&A SYSTEM

A. OVERVIEW OF THE ENHANCED PEISS M&A SYSTEM FRAMEWORK


In using the Handbook, it is essential that the reader has full understanding and apprecia-
tion of the PEISS M&A System Framework (Figure 2-1) for the following reasons:
1. The System Framework can be used as a common reference for all the stakeholders on
how to view the system from their points of interest and participation.
2. The Framework depicts the M&A System as manageable components or elements
where specifications depend on the desired level of achievements of the system.
3. The Framework serves as an aid in the analysis of the system’s effectiveness, effi-
ciency, and sustainability in achieving its objectives;
4. The Framework situates the proposed areas for enhancements in the system.
The understanding of the PEISS M&A System Framework (Figure 2-1) starts from its core
(project-based) functions which include the planning, implementation, and evaluation activi-
ties for the selection of the appropriate EMA strategy for the project, processing or prepara-
tion of M&A requirements prior to a project’s implementation, the EMA proper at the project-
level, the evaluation and subsequent investigation or recognition of the results of EMA. The
system management function is necessary to ensure that the entire EMA system is de-
signed, constructed, operated, and continually improved to support the core functions. The

14 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

system has input, output, and outcome elements, as described briefly below. Feedbacks to
each of the elements trigger the continual improvement in the EMA system.

The input element provides the enabling mechanisms to operationalize the functions of the
EMA System. These input elements are comprised of management directions (EMA goals
or target outcomes, policies, legislations, rules and regulations), the consolidated profile of
the regulated community or projects covered by the PEISS, the EMA project requirements
(e.g., monitoring plans, MMT MOA, EGF), the EMA processes and procedures (e.g., for the
regular validation, issue investigation, performance audits), tools (manuals, checklists, forms,
dataBase systems), stakeholders (e.g., the lead EMA units: the proponent, EMB, and the
local community, LGUs, other relevant goverment agencies, and the third party auditors),
and resources (e.g., manpower, budget, equipment).

The output element manifests the performance against the project-based and system man-
agement functions; these are the monitoring plans and manuals prepared, the monitoring
reports produced from the monitoring and audit activities and the decisions made based on
the evaluation of the EMA reports.
The outcome element is a measure of the effectiveness and efficiency of the outputs against
the EMA goals and policies. The actual outcome is the resultant or net compliance and
performance of the projects and the EMA stakeholders after M&E efforts. The outcomes are
targeted to achieve the following goals in an enhanced and sustained manner: a) project
environmental compliance and performance; b) project improvement in design and opera-
tions; c) social equity/enhancements; d) meaningful public participation and performance in
EMA; and e) harmonious partnership among proponent, the public and& the government
regulatory units.

B. RATIONALE FOR THE ENHANCEMENTS


The specific areas of enhancements and key features of the enhanced Project-level EIA
M&A System are presented in Table 2-1. The enhancements derive from the assessment
of the current PEISS M&E practices, the results of which are also presented in Table 2-1.

Other inputs into designing the enhancements included survey of good M&E practices
locally and globally, recent DENR policy issuances, mainly the promotion of Self-Monitoring
and Regulation as well as Environmental Partnership and Community Participation and the
adherence to the sustainable development framework.

C. THE GENERIC EMA PROCESS OVER THE PROJECT LIFECYCLE AND EIA STAGES
Figure 2-2 presents the generic EMA process showing the enhancements over the project
life-cycle from prefeasibility to final design/preconstruction, construction, operation, and
abandonment phase and cutting across all stages of the EIA process from scoping to EIS
preparation and submission, EIS review, ECC issuance, and post-ECC follow-up phase.
Figure 2-3 focuses on the enhanced post-ECC EIA M&A System which shows the relation-
ship of the three (3) lead monitoring units - the Proponent, LGU, Community and DENR/
EMB, through their EMA plans, manuals, and reports.

What is most significant in the enhanced system is the integration of the EMA concerns
and requirements at the prefeasibility project phase and the EIA Scoping Stage. Thus, the
quality, extent, depth, frequency, and stakeholders involved in the post-ECC follow-up activi-

World Bank - DENR SEPMES PEISS 15


Introduction and Technical Guidelines

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements.

AREA OF PRESENT PROPOSED RATIONALE


ENHANCEMENT

A. Environmental Lacks screening and 1) For the collective set 1) Indicates outright the
Monitoring prioritization criteria of projects issued need for monitoring
Planning: for M&E: projects ECCs: Application of and corresponding
Selection and selected for M&E are screening using priority ranking for
Prioritization of usually based on PEMAPS (Project planning purposes;
projects for convenience or public Environmental
monitoring pressure Monitoring and Audit 2) Rationalizes alloca-
Prioritization tion of scarce M&E
Scheme), a risk- resources to projects
based evaluation and that matter to environ-
categorization of mental quality con-
projects into high-, cerns
medium- and low-risk
clusters, with 3) Reduces regulatory
corresponding pressures on firms
appropriate monitor- complying and with
ing strategies good environmental
performance track
2) For the project- record and those that
specific monitoring do pose only low en-
requirement: use of vironmental risks.
PEMAPS together
with the EMB policy
on ECP/NECP
monitoring, as basis
to determine if the
project will be subject
to EMA and what is
the appropriate
monitoring strategy
for the project
B. Baseline 1) Baseline data gathering 1) During Scoping 1) Improves scientific
Monitoring matrix in Scoping Report : Phase: reliability of
Preparation and submis- benchmark
2) Actual baseline data
sion by the proponent of a information used in
gathering during the
comprehensive Baseline setting perfor-
conduct of the EIA;
EMA Plan/Manual mance criteria for
3)PEISS IRR with no (BEMAP/M) to establish evaluating impacts;
subsequent explicit good baseline data, with
requirement to the propo- due consideration to and 2) Allows identification
nent to continue baseline integration of, the other of relevant
data gathering (“baseline agencies’ requirements for monitoring stations
monitoring” ) during M&E 3) Accurate baseline pre-
preconstruction stage;
vents baseless accu-
2) During EIA Preparation: sation of firms for an
4)On a case-to-case basis, Recognition that the
some proponents conduct environmental event if
baseline data gathering is proven to be due to
baseline monitoring, and the initial baseline
continue such during natural or external
monitoring for the project; causative factors
operations by monitoring
“control stations”

16 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements
(continuation).
AREA OF PRESENT PROPOSED RATIONALE
ENHANCEMENT
3) Project
Preconstruction
(Post-ECC Phase):

Continuation of Baseline
Monitoring to be continued
through the pre-construction
stage.
C. Environmental 1) Environmental 1) Replacement of EMoP 1) EMAP/M incorporates
Monitoring Monitoring Plan with a more comprehen- self-monitoring and
and Audit Plan / (EMoP) incorporated in sive EMA Plan and Manual self-regulation;
Manual EMP but mainly (EMAP/M) cutting across 2) Reduces technical
compliance and less of the project life-cycle, to pre- monitoring tasks of
impact monitoring; identify most significant EMB and MMT to
environmental aspects and validation (Focuses
2) Uses mainly impacts (SEAI); 2) prioritize work of MMT to
shotgun approach the aspects and impacts doable tasks)
and lacks focus and through the Environmental 3) EMB and MMT can
relevance Stressor Rating System opt to confirm
(ESRS) and monitor at proponent’s data
various levels (early through another
warning or red alert level, sampling and
action level, limit /standard measurement of
level) through the questionable
Environmental Quality parameters and
Performance Levels sampling stations
(EQPLs). 4) The normally single
sampling by the propo-
nent and mere valida
tion by MMT and EMB
reduces safeguards
costs of proponent

D. Environmental EMoP and EMP Systematic link of EMP/ 1) Ensures EMP,


Management approved during ECC EMAP/M to environmen- through updates on
Planning application remain tal management with the EMAP/M, as a
mostly unchanged EMB annual review & living document
irrespective of monitor- approval of updated 2) Provides dynamism
ing results – changes EMAP/M and EMP based and relevance to
within the scope of the on EMA results environmental
existing ECC are management
officially presented and throughout the project
discussed only during lifespan
MMT meetings but not
submitted by the 3) Ensures better
proponent to the DENR/ environmental
EMB. It is assumed that performance and
the DENR-EMB member lesser financial risks
of MMT reflects such from environmental
changes in its assess- liability of proponents
ment of the project
performance over time.

World Bank - DENR SEPMES PEISS 17


Introduction and Technical Guidelines

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements
(continuation).
AREA OF PRESENT PROPOSED RATIONALE
ENHANCEMENT
E. Reporting and 1) Limited guidelines for 1) Technical and 1) Provides optimum
Disclosure quarterly reporting by administrative public transparency
the proponent and guidelines for the and disclosure of
proponent’s semi-
MMT; annual Self-monitoring EMA information
Report (SMR) for the leading to good
2) Monitoring limited to PD 1586 module community relations
compliance monitor- with proponent and
ing 2) Technical, operational EMB.
& administrative
3) Poor disclosure of guidelines through the 2) Nurtures proponents’
Manual of Operations
environmental (MOO) for the MMT’s positive corporate
performance or IEC SMR-based Compli- image and good-
program both by the ance Monitoring & neighborly relations
proponents and by Validation Report
(CMVR), IEC and 3) Conforms with inter-
MMT
disclosure programs nationally accepted
and complaints environmental report-
management by MMT ing by exporting pro-
ponents
3) Relevant and transpar-
ent review and
validation of SMR and
CMVR through
standardized and
comprehensive
administrative
guidelines and
procedures

F. MMT Role and 1) There is not enough 1) Preliminary identifica- 1) Avoids potential
Composition guidelines for tion of stakeholders conflict of interest for
selection of members and analysis of EMB and proponent;
to the MMT and for participation issues 2) Provides better
the MMT’s administra- during the Scoping conditions for
tive management of Phase, through a expressing local
its operations meaningful process of knowledge,
Social Preparation by observations,
2) EMB, Proponent, and the Proponent perceptions, and
local stakeholders are recommendations
members of the MMT. 2) Delineation of the 3) MMT COE screens
Studied MMTs show MMT member roles & local community
high potential for functions and members with
conflict of interest and revision of validation sincere interests in
subliminal intimidation process to ensure providing voluntary
of local stakeholders local stakeholders’ service for vigilant
due to dominance on voice is heard and M&E of projects
technical expertise documented. 4) MMT MOO provides
and administrative guidelines for proper
management of EMB 3) Transformation of administrative man-
and proponent. MMT to Multipartite agement of MMT and
Proponent’s financial Monitoring and Audit documents the delin-
clout prone to abuse System (MMAS): a eation of roles and
and to influence MMT Proponent and DENR- functions of the mem-
compliance monitor- -EMB each comprising bers of the reconsti-
ing reports separate parties, and only tuted MMT as

18 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements
(continuation).
AREA OF PRESENT PROPOSED RATIONALE
ENHANCEMENT
Current roles are: local stakeholders, civil as well as the relation-
1) DENR/EMB provides society and NGAs ship of the members
direction on policy, acts as concerned comprising with DENR/EMB and the
Chairman and Secretariat,
leads sectoral sampling, the community-based, proponent
provides technical advice, reconstituted MMT.
leads in discussions and EMB continues to
sometimes drafts the MMT serve its regulatory,
reports. (However, these technical, policy
functions and roles are
advisory roles – with
consistent with the role of the
DENR/EMB, as described in added coaching/
the PEISS IRR). nurturing role, while
the proponent continu-
2) Proponent provides ing its technical role –
monitoring funds, equipment, with the special
logistics, shares technical
expertise in the conduct of
recognition that the
sampling for MMT’s impact proponent is the driver
monitoring, assists the EMB of the Project-based
in leading the discussions EMA System through
and assists the secretariat its EMAP/M and SMR
draft the MMT reports.
submissions, and the
(However, these functions
and roles are not necessarily sustainer of the
inconsistent with the role of financial feasibility of
the proponent as described in the MMT through
the PEISS IRR). provision of the EMF.
3) Local stakeholders in the
4) Formulation of the
MMT are supposed to
serve as the voice, eyes Code of Ethics and
and ears of the commu- EMAP-based MOO for
nity in monitoring the
the reconstituted MMT;
environmental perfor-
mance of the proponent
against the ECC and EMP. 5) Capacity- building
However, the process of program for reconsti-
sampling / monitoring, tuted MMT, proponent
discussions / delibera-
tions, drafting the report,
and DENR/EMB for
disclosure, and IEC do not their tasks under the
show or document the enhanced Multipartite
independent observations EMA System
and independent process
of deliberations of the
community.

G. Financial 1) Sampling and 1) Sampling and 1) Reduce unneces-


Management and measurement tasks measurements to be sary tasks and
Sustainability constitute the most regularly done only by wastage of financial
expensive part of proponent; MMT and resources of
the MMT monitoring EMB to normally do proponents;
but merely only validation, and on 2) Timely and efficient
duplicates the special cases, release of funds to
proponent’s self- confirmatory sampling MMT work
monitoring to be undertaken for 3) Train local commu-
unnecessarily questionable data and/ nity to be responsible
2) Proponent, or or validate complaints. and learn to be
Execom, of which 2) Revised guidelines on accountable for
Proponent is a setting up, disburse- entrusted funds
member, manages ment and overall 4) Avoids unneces-
EMF/EGF: PEISS management of EMF sary proponent
M&E System costs demanded by

World Bank - DENR SEPMES PEISS 19


Introduction and Technical Guidelines

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements
(continuation).
AREA OF PRESENT PROPOSED RATIONALE
ENHANCEMENT

Assessment 3) Fund administration MMT if not in the ap-


shows slow and by professional (one proved AWFP
inadequate release of the qualifying
of funds by the member organizations
proponent or of the local stake-
Execom holder members of
the proposed
reconstituted MMT);

4) Disbursement based
on approved AWFP;
5) MMT allowed fund-
raising activities

ties have been predetermined, costed, and allocated with the proper institutional support by
the proponent during the EIS Review process. The Proponent serves as the driver of the
EMA process— through the Proponent’s preparation or submission of EMAP/M and SMR
for the review and validation of EMB and the community MMT for projects with MMT require-
ments. (Note: For other projects with no MMT, the current (DAO 03-30) requirement of a
third party auditors’ report will be adequate as the basis of the EMB for evaluation of the
proponent’s environmental performance.).

As the principal stakeholder of the enhanced EMA System, proponent’s self-monitoring


should be comprehensive, relevant, and scientifically credible. Thus, selfmonitoring will be
guided by an EMAP and EMAM to be prepared by the proponent according to the guide-
lines in this Handbook and reviewed and approved by EMB. The implementation of EMAP/
M will result in the periodic preparation and submission of SMR by the proponent to EMB.

EMB may use additional information provided by MMT through the latter’s semiannual Com-
pliance Monitoring and Validation Report (CMVR) as well as periodic audit reports, if deemed
necessary. Under normal conditions, only the proponent’s self-monitoring will involve highly
technical and costly work such as sampling and measurement of environmental media and
receptors. Validation by EMB and MMT may involve confirmatory sampling and measure-
ment under certain circumstances, but in general, the enhanced Model relies mostly on the
veracity and adequacy of the self-monitoring data to properly evaluate the project’s environ-
mental performance. It is therefore expected that the self-monitoring focus of the enhanced
model will avoid unnecessary duplication of expensive sampling and measurement efforts
and prove to be more cost-effective than the current practices.

20 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Figure 2-2. Generic Simplified EMA Process over the


Project Life-cycle and EIA Stages.

DENR/
Project Proponen t EMB / RevCom / EMB
Stage in MACOM
DOCUMENT PREPARATIONAND
the PEISS
SUBMISSION
Ø Project Description with BEMAP/M, M&E Re-
Project Pre-FS; quirements Checklist for reference in screen-
EIA Screening & ing and scoping, preliminary PEMAPS rating
Scoping by Proponent
Ø Scoping Report with BEMAP/M and M&E Re-
quirements Checklist, List of Stakeholders &
Participation Issues

Project Pre-FS/FS;
EIS Preparation,
Ø EIS with EMAP/M with SEAI, ESRS & EQPL
within the EMP for all project phases (i.e, Pre-
Review and
Construction, Construction, Operation and, Aban-
ECC Issuance donment); EIS w/ confirmed PEMAPS rating, fi-
nal sectoral stakeholder list & issues

Project Ø Formation & Operationalization of the Commu-


Implementation nity MMT; Generic & Detailed MOA signing
and Community MMT
Ø Pre-construction Baseline Environmental
Environmental Monitoring Report
Performance • Reviews EMAP/
Ø Updated EMAP/M for Construction/ Opera- M for comments
M&E & to prepare
tion (CEMAP/M /OEMAP/M), for significant
change in design/operation within ECC cov- MMT MOO: sub-
erage mits MOO to EMB

• Validates SMR,
prepares and
Project submits CMVR
Abandonment; to EMB Prepares
EIA Monitoring &
Closure Ø Abandonment EMAP/M, if project is termi-
nated

World Bank - DENR SEPMES PEISS 21


Introduction and Technical Guidelines

Figure 2-3. Enhanced Multipartite Monitoring and Audit System

D. KEY FUNCTIONS OF THE PROJECT-LEVEL EIA M&A SYSTEM


In summary, the Enhanced EIA M&A System consists of four data gathering functions on
the environmental performance of development projects, namely:
• Baseline Monitoring – undertaken for the purpose of establishing a solid environmen-
tal profile of the baseline or similar control environment as reference for comparison of
changes due to the project or natural causes. This is done by the proponent during the
EIA, and continued after ECC issuance up to preconstruction phase. In the case of
controlled stations, monitoring may be done throughout the project lifespan and even
after abandonement as in the case of landfill sites and other “brownfield” sites.

• Compliance Monitoring and Validation– undertaken for the purpose of establishing


compliance with the ECC conditionalities and EMP commitments, which include the
EMAP/M. This is done by the proponent at all phases of the project from preconstruction,
construction to operation and abandonment. This is also regularly done by MMT thus
its witnessing, authentication or confirmatory sampling. MMT validates the proponent’s
SMR, with at least twice a year reporting of its findings through its CMVR.

• Impact Monitoring – undertaken for the purpose of determining actual impacts caused
by the project on the receiving environment. This is also done to monitor residual and
cumulative impacts due to the project. This monitoring is conducted by the proponent

22 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

during construction, operation, and abandonment phases. This can also be periodically
done by MMT and EMB, although the skill required to interpret the data is more appro-
priate for experts. Thus, this implies the need for MMT to access the services of ex-
perts, preferably from the local community, if available, and for EMB to first access the
sectoral regulatory units within DENR who have expertise and mandate over the areas
of concern, or to avail of the pool of auditors accredited by or registered with DENR,
Board of Investments or any internationally recognized registration body.

• Project Environmental Performance Audit – undertaken by accredited environmen-


tal auditors or registered EMS auditors. The auditors may be direct-hired by the propo-
nent or through MMT.

III. PEISS M&A STAKEHOLDERS, ROLES AND RESPONSIBILITIES, AND GENERAL


REQUIREMENTS

A. DESCRIPTION OF THE EIA M&A SYSTEM OF THE THREE LEAD EIA M&A
STAKEHOLDERS
The overall manager of the PEISS M&A System is EMB as the mandated regulatory agency.
However, the proponent plays a major role as the source of potential environmental stres-
sors, impacts, and interventions that are subject to regulation and other forms of manage-
ment actions. The host local community, on the other hand, by virtue of its approval of the
project’s operation in its jurisdiction, stands to directly or indirectly benefit from the project,
but in the process, it also will be the receptor of the potential impacts likely to arise from the
project’s construction and operation. Descriptions of their unique EIA M&A Systems are as
follow:
1. Proponent-Based EIA M&A System
The enhanced EIA M&A System is predominantly proponent-driven, primarily triggered
by the proponent’s self-monitoring function as manifested by the preparation of EMAP/
M and SMR submissions to DENR/EMB. The project proponent is expected to make
investments in M&E as a tool for assuring that its committed environmental manage-
ment plan will be implemented effectively and periodically calibrated according to the
results of the M&E to improve environmental performance. Investments in M&E are
deemed internal costs or overhead of the project and not of society and government.

The proponent-based EIA M&A System includes its internal policies, objectives and
targets for M&E, its internal processes and procedures which may be embodied in an
Environmental Management System (EMS), for implementation by its environmental
and social institutional unit (i.e., environmental staff or internal auditors) which can
access M&E experts/consultants and third party auditors to heighten the quality and
practice transparency in its M&E. The proponent who is proactive in its M&E program
normally would also have as part of its system, the necessary tools and resources for
an effective and efficient management information system, reporting, and communica-
tions and disclosure system and other management functions which ensure continual

World Bank - DENR SEPMES PEISS 23


Introduction and Technical Guidelines

The rural landscape of the community hosting the Mak-ban-PGI geothermal power plant in Bay,
Laguna.
improvement without necessarily incurring excessive cost. Part of the proponent-based
EIA M&A System is its linkaging with other stakeholders. The ideal proponent-based
EIA M&A System would normally value continuing guidance and support to a commu-
nity-based multi-stakeholder M&E team towards capacitation to carry out various EMA
functions, self-sustenance, mutual trust, and buildup of harmonious partnership across
the project life.

The tools to be used by the proponent in the conduct of its self-monitoring are dis-
cussed in detail in this volume– Introduction and Technical Guidelines. For the propo-
nent to be knowledgeable of its EMA role with respect to the community stakeholders,
the guidelines are provided in Volume 2 of the Handbook. With respect to the prepara-
tion of the proponent for the review and validation of its outputs by the regulatory agency,
Volume 3 provides the proponents with the guidance on the review of its EMAP/M,
SMR, PEMAPS-rating, investigation of issues raised against the proponent and proto-
cols for system audit which are applicable to any of the project stakeholders.
2. Community-Based EIA M&A System
The multistakeholder participation in the enhanced EIA M&A System limits the involve-
ment to the local community representatives. The proponent and DENR/EMB, by virtue

24 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

of the redefined roles of the latter two sectors as the entity subject to regulation (propo-
nent), and the regulatory entity evaluating the performance of both the proponent and
MMT are exclued.

The community-based EIA M&A System has the primary function of serving as the
people’s eyes, noses, and ears on events and issues likely to affect the community. It
shall be the public voice through which advisories and other project environmental infor-
mation can be released and disseminated to the public-at-large. It shall be the people’s
conscience in following through and investigating any complaint lodged before it by
anyone and referring its initial findings and recommendations to the proponent and
EMB for appropriate action.

Its LGU member, through its independent mandate as enforcer of environmental laws,
can immediately enforce temporary mitigating and contingency measures to protect
public and environmental safety while EMB validates and investigates adverse situation
for more permanent and long-term resolution of the case at hand. The reconstituted
MMT serves as the early-warning mechanism of impending environmental pollution and
threat to public safety due to project operations.

MMT through the guidance provided by the Environmental Quality Performance Levels
(EQPLs) in the Proponent’s EMAP/M, will provide the local community with a laymanized
picture of the project environmental condition before the situation becomes worse or
violative of environmental standards. This is made possible with the MMT’s use of pseudo-
indicators of pollution such as perceptible odor, color, dust, noise, fish kills, and crop
loss which can be correlated with specific range of EQPLs.
The elements of the community-based EIA M&A System are generally the same as the
proponent’s, with differences only in the specifications of the community M&E targets,
its procedures, its institutional and administrative arrangements which are all embod-
ied in the proposed Manual of Operations (MOO) described in Volume 2 of the Hand-
book. The community is guided by Volume 1 on the technical basis, scope and
limitations of its EMA tasks while Volume 3 provides the community-based EIA M&A
System with guidance on the administrative procedures for its review and validation of
the proponent’s EMA documents and reports.

The community-based EIA M&A System is linked with that of the proponent through
the M&E superordinate goal of promoting project and stakeholder performance, and
improving environmental status while ensuring sustained project operations and devel-
opment in a manner that promotes public participation and partnership with the propo-
nent.

3. EMB-based EIA M&A System


The EMB-based EIA M&A System is comprised of the functions of a) review and
validation of the EMA documents and reports of both the proponent and the community-
based MMT, b) administrative investigation of the issues and complaints, and c) con-
duct of system and performance audits of any stakeholder or partner of DENR/EMB in
EMA. All the necessary tools (e.g., review forms, field validation forms, complaints
investigation report form, system audit forms and checklists) have been provided in
Volume 3 of the Handbooks. The criteria for the review of the EMA documents are

World Bank - DENR SEPMES PEISS 25


Introduction and Technical Guidelines

contained in the Volume 1 and Volume 2 of the Handbook.

EMB is mandated to implement and manage the PEIS System law and is therefore
primarily responsible for ensuring that all projects covered by the PEISS do not signifi-
cantly impact the environment and are continually improving in environmental perfor-
mance. In carrying out this mandate, EMB shall equip itself with monitoring information
gathered on its own, the proponent’s self-monitoring reports, third-party validation such
as that of the MMTs and independent auditor, and general inputs from the public such
as investigation results due to complaints.

Being proponent-driven, EMB is not obliged to conduct regular sampling and


measurement activities except when there is a need to validate the proponent’s
monitoring reports or third-party audits or validation reports, or when reliable
data are required for complaint validation, for noncompliance issue resolution,
litigation, and adjudication, and for scientific research and educational pur-
poses.

B. ROLES AND RESPONSIBILITIES OF STAKEHOLDERS OF THE ENHANCED PROJECT-


LEVEL EIA M&A SYSTEM

The three lead EMA units – proponent, community MMT, and DENR/EMB – are supported
by other key actors in the enhanced EIA M&A System such as the pool of experts who
assists EMB in the review of EMA requirements during the EIS review (the RevCom) and
optionally, during the post-ECC review of EMA documents, the Monitoring & Audit Commit-
tee (MACOM). DENR/EMB is also assisted in its EMA functions by the sectoral regulatory
units (SRUs) who have direct mandates over the project (e.g., EQD on RA 6969, 8749; FMB
on forestry, DAR on “carpable” areas (e.g., under CARP), LGUs on social development and
employment programs). The public-at-large is also considered a key actor since feedback
to the regulatory agency on the performance of the proponents and of other sources outside
the PEISS M&A System are received by the lead M&E units through them.

The respective roles and responsibilities of the key actors are presented in Table 3-1.

C. SUMMARY LIST OF TECHNICAL ENVIRONMENTAL DOCUMENTS / REPORTS TO BE


PREPARED BY THE KEY ACTORS

Table 3-2 presents the list of EMA documents that are expected to be produced or used by
the key actors in carrying out their specific roles and functions. These documents can be
classified into three types namely: (1) regulatory requirement, (2) procedural tools, and (3)
output documents. Regulatory documents are those that are required from the Proponent or
MMT as a prerequisite of a certain EMA policy. Procedural tools on the other hand, are
those that are used by EMB to facilitate the EMA processes and procedures such as forms.
Output documents are those resulting from the conduct of a certain EMA activity such as
review and validation (refer to Volume 3 for details).

Pursuant to the enhanced EIA M&A System, the proponent is required to prepare (in-house
or outsourced) and submit for EMB approval the following documentation:
• Baseline Monitoring Plan, Manual and Report(s)
• EMAP/M

26 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Table 3-1. Roles and Responsibilities of the Stakeholders of the Enhanced


Project-Level EIA M&A System.
Key Actor General Role and Responsibility in EMA

1) EMB Central Office • the regulatory agency tasked to manage the entire EMA
process from pre-ECC/project feasibility phase to post-
ECC/project operational to abandonment phase;

• specifically, EMB CO supervises the implementation of M&E


requirements during the pre-ECC phase

• preliminary assessment of issues for referral to EMB ROs


and management of the appeal process
• PEIS system management at the national level on effective-
ness, efficiency, and sustainability of the system: undertakes
system and performance audits of EMB RO, and its M&E
partners such as MMTs, LGUs, among others.

• the regulatory agency tasked to supervise the implementa-


2) EMB Regional Office tion of the EMA process and performance of the various
stakeholders from post-ECC phase to project operations/
abandonment for ECPs whose ECC’s were issued by the
DENR Central Office; handles all M&E requirements at all
phases of the EIA process for downloaded ECPs (i.e., for
infrastructure), and NECPs

• detailed assessment and investigation of issues referred


to it by MMT, EMB CO, LGUs, other sources of complaints

• PEIS system management at the regional level on effective-


ness, efficiency, and sustainability: undertakes system and
performance audits of the EMB ROs, and its M&E partners
e.g., MMTs and LGUs, within the region
• To MMT: technical and policy resource person, coach and nurturer,
trainor and supervisor

3) Proponent • the regulated entity to submit all required the EMA docu-
ments i.e., EMAP/M, SMR, response to NOV, compliance
report on Case Decisions, among others.

• fund provider to MMT


• trainor to the community MMT on technical aspects of
the EIA M&A System

4) EIS Review • body of internal and/or external experts designated by


DENR to review EIS, including the enhanced M&E require-
ments

5) Monitoring and Audit • reviews revised EMAP/M and EMA Reports,when deemed
Committee necessary by the EMB
(MACOM)

World Bank - DENR SEPMES PEISS 27


Introduction and Technical Guidelines

Table 3-1. Roles and Responsibilities of the Stakeholders of the


Enhanced Project-Level EIA M&A System
(continuation).
Key Actor General Role and Responsibility in EMA

6) Multipartite • Autonomous body to review and validate compliance by


Monitoring Team proponent, and a mechanism for public participation
(MMT) serving as a focal body for meaningful public participation
and for public disclosure of the proponent’s performance,
including investigation of issues on likely nonconfor-
mance on ECC/EMP commitments
7) Third-party Auditor • Independent Environmental Checker, for optional third-party
validation of M&E Reports and for conduct of third party
Performance Audits

8) Other agencies/ • conduct actual monitoring on parameters within their M&E


entities /sectoral mandates;
regulatory units • provide proof of proponent’s compliance to EMB on the
(SRUs) SRU’s respective permits/requirements pursuant to their
environmental-related mandate;
• provide EMB with list of M&E requirements for use in
screening and scoping of all project for M&E requirements

9) The wider public • review/comment on EIS, including the enhanced M&E


and the host requirements;
local communities • lobby for societal and community welfare and rightful
share in the fruits of development; inform EMB of any
violation on PEISS rules and regulations including the
ECC;
• assist the regulatory agency in ensuring project’s compli
ance to cease orders and other resolutions.

28 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Table 3-2. List of Technical Environmental Reports to be Prepared by the Key


Actors under the Proposed Enhanced PEIS EMA System.

TECHNICAL ENVIRONMENTAL RECIPIENT OF


KEY ACTOR
DOCUMENT PREPARED DOCUMENT
1) EMB Central • EIS Review and Approval Report EMB RO, Proponent
Office
• PEIS System Audit Report EMB CO, EMB ROs
• Initial Assessment Report on Violation EMB ROs, Propo-
Information received nent, Complainant
• Decision on Appeals EMB RO, Proponent

2) EMB Regional • EIS/IEE Review and Approval Report EMB RO, Proponent
Office
• MMT Performance Audit Report EMB CO, cc: MMT and
Proponent
• SMR Field Validation Report EMB RO
• Complaint Field Validation Report EMB RO, cc: Proponent
and Complainant
• Technical Hearing Report EMB RO

• Case Decision Document, i.e., CL or Proponent, cc:


NOV Complainant
• Decision on MFRn Report Proponent

• Case Documentation Report EMB RO

• Case Proceedings Report (Feedback) Complainant/ Public

3) Proponent • Scoping Report with BEMAP/M EMB CO/RO

• EMAP/M for all project phases EMB CO/RO and MMT


• SMR EMB CO/RO and MMT

• Response to Notice of Inquiry EMB RO

• Compliance Report on Case EMB RO, MMT, other


Decision Document parties concerned

4) MMT • MOO
EMB RO, cc: to Proponent
• CMVR EMB RO, cc: to Proponent

• Complaint Validation Report EMB RO, cc: to Proponent

• Public Disclosure EMA Report Public

World Bank - DENR SEPMES PEISS 29


Introduction and Technical Guidelines

Table 3-2. List of Technical Environmental Reports to be Prepared by the Key


Actors under the Proposed Enhanced PEIS EMA System (continuation).

TECHNICAL ENVIRONMENTAL RECIPIENT OF


KEY ACTORS
DOCUMENT PREPARED DOCUMENT
5) EIS Review • EIS Review Report, i.e., EMP EMB CO/RO
Committee w/ EMAP/M

6) MACOM • EMAP/M Review Report EMB CO/RO

7) Auditor • 3rd Party Audit Reports EMB CO/RO


8) SRUs • Sectoral M&E Reports EMB CO/RO

• PEISS Violation Information EMB CO/RO


9) Public
• Compliance Monitoring Report EMB CO/RO

* Forms are provided in Volume 3 for the various technical environmental document

1. Baseline Monitoring and Audit Plan and Manual (BEMAP/M)


The Baseline Environmental Monitoring and Audit Plan (BEMAP) and Manual (BEMAM)
are the initial documents prepared and submitted under the enhanced M&E Model.
These documents are ideally prepared during the Scoping Phase of the EIA Study and
submitted with the Scoping Report. BEMAP forms part and is subject to the same
approval process as the Scoping Report. BEMAP shall cover the monitoring period
required by the EIA study and shall continue as long as possible until the proposed
project activities are expected to physically change the environment such as earthmoving
during the construction stage.

BEMAP selects the potential critical environmental issues to monitor from a


longlist of issues identified during various stages of the Scoping Process. BEMAP
will define the monitoring needs, objectives and targets, location, and respon-
sibility center, among others. BEMAM, on the other hand, will elucidate the
detailed actions for implementing BEMAP.

Baseline monitoring is needed because it will provide the basic information about the
original, natural or preproject or no-project environmental characteristics, processes,
and trends. The baseline monitoring results will provide an estimation of the vulnerabil-
ity of the various environmental components to environment-relevant project aspects.
Such baseline data are essential inputs to the EIA study, particularly for impact identi-
fication, prediction, and evaluation as well as generating environmental management
options.

Baseline monitoring will identify other potential natural or man-made environmental stres-
sors in the vicinity. The baseline data will also serve as the benchmark or reference

30 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Joint proponent and MMT ground water sampling station survey at MIRANT- Pagbilao in Quezon
Province.

point for detecting future changes and for comparing such changes in the environmental
conditions as influenced by project activities under the “with-project” scenario. In this
manner, baseline monitoring will allow attribution of significant environmental change
either to natural fluctuation or to the project or to other causes.

More importantly, the baseline data will form the basis for determining the EQPLs for
the project which will be used as decision criteria during the environmental audit as well
as forward environmental management planning of the project. The environmental qual-
ity performance levels will initially be approved during the ECC review stage and may be
modified as new information accumulates and necessitates review by EMB.
2. Environmental Monitoring and Audit Plan and Manual (EMAP/M)
EMAP is submitted with the EIA document upon application of the proponent for issu-
ance of an ECC. EMAP shall describe the proponent’s commitments, objectives,
strategies, and measures to track environmental aspects and impacts of the project.
Thus, in conjunction with appropriate environmental management measures in EMP,
the proponent ensures that negative residual impacts are avoided, if not, minimized to
predetermined acceptable levels. On the other hand, positive impacts of the project are
expected to be enhanced though EMP and EMAP.

World Bank - DENR SEPMES PEISS 31


Introduction and Technical Guidelines

Opening of a secured borehole by a MIRANT-Pagbilao technical staff for the joint proponent and MMT
ground water monitoring.

EMAP shall present the justification for selection of critical environmental aspects and
impacts (EA&I) and other issues and concerns to be monitored. EMAP shall also
contain indicative Work and Financial Plans for the EM&A activities and commitments,
such as the establishment of an Environmental Monitoring and Audit Fund (EMAF) and
MMT as well as building in-house capacity for environmental management including
monitoring and audit.

It is ideal for EMAP to already contain the action plan for the Detailed Design Phase
beforehand. This can take into account any later changes in the final design, whether
these are modifications, additions or deletions in materials, processes, products, loca-
tion, and construction scheduling, that may affect the project’s EA&I and consequently
its EMP and ECC.

EMAP is reviewed with the other EIA documents during the ECC processing stage.
The reviewers from EMB, RevCom or MMT may comment and provide inputs toward
making EMAP a better tool for achieving optimum environmental performance by the
project. EMAP is approved during the ECC processing stage and made an integral part

32 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

of the ECC conditionalities, if the project is issued an ECC.

Should there be significant changes in project design but still within the gen-
eral approved terms and conditions of the ECC, the attendant EMAP must be
modified and submitted to EMB for approval before construction can be initi-
ated.

EMAM details the aspects, arrangements, requirements, and actions to be un-


dertaken by the proponent to effectively implement and attain the objectives of
EMAP. It will serve as the guide for the proponent in carrying out its commitment under
ECC to comply with its EMP and ECC.

EMAP and EMAM may be amended during the course of project operations should
monitoring results indicate the need thereof.

The technical guidelines for preparing EMAP and EMAM are in Chapter IV.

3. Self-monitoring Report (EIA Module)

a. Baseline Environmental Monitoring and Audit Reports


BEMAR present benchmark information gathered on the preexisting environ-
mental conditions, that is, collected on a continuing basis commencing during the
EIA baseline studies and lasting until the physical start of project construction and
other activities causing environmental changes. As described earlier, the baseline
environmental conditions once properly established serve as a scientifically valid
bases for determining the significance or insignificance of environmental changes
by setting environmental performance thresholds for red-flagging, action and limit
levels.
BEMAR may also provide information gathered on “controlled environmental
components”, if the project’s BEMAP and BEMAM have directed so. The con-
trolled environmental components or systems are selected portions of the environ-
ment which are similar to or representative of the components or systems likely
affected by the project and shall serve as the undisturbed or natural conditions of
the environment but not impinged upon by the project’s EA&Is. Controlled environ-
mental components are therefore selected to allow tracking of natural fluctuations
and trends in the environment and provide reference point for evaluating project-
affected environmental changes.

BEMAR may also describe reference environmental sites which similar to the “con-
trolled environmental components” are selected to reflect the “with project” and
“without project” conditions. An example of a reference environmental point or
station is the segment of a river located before an end-of-pipe outfall. The reference
station will be compared with the selected environmental characteristics at the
outfall and downstream of the outfall. Statistically significant differences in the
monitoring results of these stations (upstream, at and downstream of outfall) will
allow the determination of any project impact, if any.

World Bank - DENR SEPMES PEISS 33


Introduction, PEISS M&A System & Technical Guidelines

b. Periodic Self-monitoring Reports


The results of the compliance and impact monitoring will be compiled by the propo-
nent on a weekly or monthly basis, depending on management preference, and
consolidated in a quarterly SMR to EMB.

SMRs are quarterly reports submitted by the proponent under DAO 2003-27. DAO
2003-30 requires a semiannual submission of self-monitoring reports with respect
to the proponent’s compliance to PD 1586 which is an integral part of the SMR as
the EIA Module. The EIA module of the SMR can serve as a summary for the other
modules as EIA by its nature cuts across various regulations. It shall ideally review
the results, findings, recommendations, and actions of the various SMR modules in
the past quarters. The SMR’s fourth quarter data shall be compared with the previ-
ous three quarters and on this basis, the EIA module of the fourth quarter SMR
shall conclude key issues in EM&A with the planned objectives, strategies, and
actions for subsequent monitoring, if EM&A activities are still further warranted.
Noncompliances and exceedances in the project’s environmental performance should
be addressed with appropriate revisions in the EMP. The EIA module of the fourth
quarter SMR shall also contain the EM&A Work and Financial Plans for the follow-
ing year. Any revision in EMAP/M and EMP should be highlighted. The annual
report will be reviewed by EMB and, as needed, its EIA Monitoring and Audit Com-
mittee (MACOM).

Inspection of the air quality monitoring station by MIRANT-Pagbilao together with its MMT.

34 World Bank - DENR SEPMES PEISS


Introduction, PEISS M&A System & Technical Guidelines

D. SELECTION AND PRIORITIZATION OF PROJECTS FOR MONITORING


Given the limited resources, it is not possible to monitor all the projects covered by the
PEIS and granted ECCs which account to more than 20,000 nationwide. Moreover, the
current ad hoc practice of monitoring mainly in reaction to public pressure or controversy
does not guarantee an efficient use of the limited resources in attaining optimum environ-
mental performance. It is therefore useful to develop an objective and rational system of
prioritizing progress to monitor.

This Handbook presents an enhanced prioritization and selection scheme to obtain more
meaningful monitoring information. This information serves as a gauge in accomplishing and
basis for corrective actions in executing monitoring plans improving monitoring system. The
risk-based scoring system called the Project Environmental Monitoring and Audit Prioritization
Scheme (PEMAPS) can be situated as an input in the planning function of the M&E cycle.
The M&E cycle can be simply viewed to involve planning, implementation, monitoring, and
evaluation. As shown in Figure 2-1, the planning tasks may start with the formulation of the
EMB M&E policy or mandate from which M&E goals and targets can be set, in consider-
ation of M&E goals from other DENR offices, and the super-ordinate goals of DENR itself.
Thereafter, the projects can be selected and prioritized, preferably synchronized with the
project list of other monitoring units within and outside the DENR. From the shortlisted
projects, annual work and financial plans and monitoring strategies can then be formulated
based on the available resource mix. The planning inputs are the Major Final Outputs (MFO’s),
the most critical regional environmental issues, and the project profiles to where the PEMAPS
can be specifically applied.

For this purpose, PEMAPS may be used. PEMAPS was taken up from a risk-based
methodology called National/Regional Industry Prioritization Scheme (NRIPS) developed at
EMB but remained unused. The scheme may be employed to rank all the projects covered
within PEIS according to the potential risks on environment and human health and welfare.
The ranking will be the basis for categorizing the projects into three groups:
• High environmental risks
• Medium environmental risks
• Low environmental risks.

Each category will correspond to a specific mix of EM&A strategies and varying levels of
intensity as illustrated in Table 3-3.

To facilitate the conduct of environmental evaluation and monitoring, the particiapation of the
T Proponent in data gathering is critical. Because the Proponent is abreast with project ope-
rations he can provide some information as asked in PEMAPS (Appendices 1a-b) with
which EMB will be using as part and parcel of the scoresheets for the conduct of environ-
mental evaluation and monitoring prioritization.

World Bank - DENR SEPMES PEISS 35


Introduction and Technical Guidelines

Table 3-3
Sample Risk-Based Environmental Monitoring and
Audit Strategy Selection Matrix.
Potential Environmental Monitoring and Audit Strategy
Risk
Surveillance
and Compliance Monitoring Impact Performance
(Based on Inspection Monitoring Audit
PEMAPS
score) EMB EMB 3rd EMB EMB 3rd
EMB
EMB MMT Desk Field MMT Party Desk Field Party

High
(70-100 X X X X X X X X X X
points)

Medium
(40-69 X X X X X X X X X
points)

Low
(1-39 X X
points)

The PEMAPS criteria used for project prioritization and the mechanics and worksheet for applying
PEMAPS for EIA M&A are in Appendix 1.

36 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

PART 2: GUIDELINES IN IMPLEMENTING ENVIRONMENTAL MONITORING AND


AUDIT AND REPORTING SYSTEM

IV. GUIDELINES FOR PREPARATION OF BASELINE ENVIRONMENTAL MONITORING AND


AUDIT PLAN AND MANUAL (BEMAP/M) AND ENVIRONMENTAL MONITORING AND
AUDIT PLAN AND MANUAL (EMAP/M) BY PROPONENT

A. NATURE AND PURPOSE

1. Baseline Environmental Monitoring and Audit Plan and Manual


Baseline environmental monitoring and audit refers to sampling, measurement,
and evaluation of activities to determine with sufficient credibility and reliability the am-
bient environmental conditions of the influence area of a given project. The
data collection is initiated at the outset of the project cycle. The longer the measure-
ment period, the more credible and reliable are the time-series data to set the bench-
mark or reference conditions.

Baseline environmental monitoring and audit by its nature will identify all significant
potential natural or man-made environmental stressors in the vicinity. Aside from
being able to compare environmental changes caused by project activities, baseline moni-
toring will also allow for such changes either to natural fluctuation or to other causes,
man-made or natural. This is essential to the development of EMAP/M as a comparative
basis between conditions obtaining in “with” and “without” project scenarios.

The baseline monitoring data is critical in determining the environmental im-


pacts of a project. Baseline monitoring will provide an estimation of the vulnerability of
the various environmental components. This is essential in impact identification, predic-
tion, and evaluation as well as generating environmental management options.

Without a properly conducted and scientifically defensible baseline monitoring regime,


the basis for all succeeding monitoring endeavors will be prone to errors with the analy-
sis resulting as a subject of doubtful validity and short of properly approximating empiri-
cal environmental condition.

This monitoring can either be time- or geography-bounded. Time-bounded sampling


technique takes into account environmental conditions before project construction
and operation. Once a project is established and operating, all monitoring activities will
already show the effects of the project and will no longer show the “natural” environment
or the “without project” scenario.

Geography-bounded sampling technique accounts samples from an area that is


not affected or is not within the impact zone of the project. For example, ambient air
monitoring baseline data can be taken upwind from a project such as a cement plant or
in the case of water, upstream of the river where a wastewater treatment plant dis-
charges its effluent. However, in all cases the monitoring stations selected must be

World Bank - DENR SEPMES PEISS 37


Introduction and Technical Guidelines

comparable to the natural state (without project) of the area where the project was
constructed, and thus can be called as a control station for future monitoring activities.

The Baseline Environmental Monitoring and Audit Plan and Manual (BEMAP/M) are
intrinsically linked to the scoping process and should be prepared at this process and
submitted as part of the scoping report. It is during the scoping process that significant
impacts and environmental risks are identified. The range of issues, actions, alterna-
tives, and impacts including the direct impact area and any secondary impact areas
that need to be included in EIS are defined, identified, and agreed upon during this
stage. The scoping process determines the coverage, focus, depth, and the extent of
EIA and the basis for its review. As such, this subprocess is the basis for identifying the
parameters and the stations for collecting baseline information and for all future moni-
toring activities.

Moreover, BEMAP, particularly its built-in tool of Environmental Stressor Rating Sys-
tem (ESRS), can be particularly useful in evaluating the identified scoping issues,
thereby filtering out insignificant ones. Once the critical environmental issues are
identified, the monitoring objectives are easily determined. But more importantly, the
identified critical environmental issues and concerns will guide the scope and focus of
the EIA study proper and consequently be addressed in the crafting of the Environmen-
tal Management Plan (EMP) of the EIA document.

BEMAP/M also provide additional inputs to the EIA report itself, since baseline informa-
tion also needs to be presented in this report. The EIA report will focus on the identified
critical impacts from the scoping report, the scientifically selected monitoring stations
in BEMAP/M, and the presentation of baseline information in BEMAR.

BEMAM is derived from BEMAP. BEMAM provides more details on the baseline
monitoring activities and discussions of the selection of monitoring locations
and the methodology (including specific sampling and measurement procedures and
equipment, QA/QC procedures, reporting formats, among others.) that will be used
during the monitoring exercise. BEMAP will also define the monitoring needs,
objectives, targets, location, and responsibility center, among others. The Manual,
on the other hand, will elucidate the detailed actions for implementing BEMAP.

BEMAP shall cover the monitoring period agreed upon in the scoping process and shall
continue as long as possible until the proposed project activities are expected to physi-
cally change the environment such as earthmoving.

BEMAP and the BEMAM may be submitted together as part of the scoping report. It
will also form part of the EIA report as an attachment, together with the Baseline EMA
Reports prepared during the EIA study proper. It will be reviewed as part of the scoping
report and as part of the EIA report (scoping report is attached to the EIA report) to
determine if it is sufficient to meet the needs of the baseline monitoring for that particu-
lar project. Reviewers of the scoping report and BEMAP/M should ensure that the
information presented is technically adequate for the specific project and follows the
scoping process appropriate for the project.

38 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Securing water samples obtained by MIRANT-Pagbilao during their joint proponent-MMT marine water
quality survey.

Reviewers of the scoping report and BEMAP/M should ensure that the information
presented is technically adequate for the specific project and follows the scoping pro-
cess appropriate for the project.
2. Environmental Monitoring and Audit Plan and Manual
The Environmental Monitoring and Audit Plan and Manual (EMAP/M) are key documents
in the proposed Enhanced EIA M&E System. These documents are prepared and sub-
mitted by the proponent to EMB and become the main basis for EMB, stakeholders, and
other third-party validators to assess the environmental performance of projects and other
undertakings covered by PEISS.

EMAP is submitted initially with the EIA documents as part of the Environmental Manage-
ment Plan (EMP) upon the application ECC. EMAP is a broad outline of commitments
and measures that the proponent will undertake to monitor and audit the project’s
implementation of its EMP as well as compliance to the ECC terms and other post
ECC follow-up activities.

EMAM is derived from and expounds on the EMAP. EMAM contains the detailed ac-
tivities of the proponent to track the implementation of its EMP, to institute re-

World Bank - DENR SEPMES PEISS 39


Introduction and Technical Guidelines

sponse mechanisms to noncompliance or exceedances or complaints, to provide


for resources and enabling mechanisms to implement EMAP, and to undertake
whatever is reasonably needed to attain optimum environmental performance.

EMAM may be submitted together with EMAP during the EIA review, or after the ECC has
been granted as long as the approval is given by EMB before any construction activity. In the
latter case, changes in project design or construction or operation should be considered in the
drafting of EMAM.

The EMB EIA staff and the EIA RevCom shall ascertain that the proponent submits its EMAP
and EMAM that is sufficient in form and substance. During the procedural review of EIA
documentary submissions at the Pre-ECC stage, EMB shall ensure that EMAP/M contain
the complete topics required. EMB endorses the complete EMAP/M with other documentary
requirements to the EIA RevCom for a substantive review.

The EIA RevCom members (during Pre-ECC Stage) and MACOM (during Post-ECC stage)
should be experts in the necessary scientific discipline to credibly review the submitted EMAP/
M. Basically, the EIA RevCom and MACOM members should ensure that the approach,
methods, and technical analysis are adequate, feasible, relevant, and accurate for the specific
project and that there are no fallacious or dubious analyses. They should ensure that the logic
of the discussion is rational and that the information presented is credible. This will include
reviewing the identified impacts and the mitigating measures, monitoring parameters, the
sampling locations, schedule and frequency, sampling methodology (including transport of
samples to laboratories), set standards, and the recommended EQPL, among others.

Reviewers should ensure that the information presented and its rationale is technically ad-
equate for the specific project. However, reviews should be limited to what is really needed in
the project and not toward the reviewer’s bias for his/her own specific field of interest or toward
his own person. They should also ensure that the EIA report did not miss anything essential
in the protection of the environment such as additional parameters, better treatment options
compared to the ones presented, sensitive receptors not included as sampling locations.
Reviewers should also ensure that the proponent has the ability to implement its EMAP/M.
The use by the proponent of an accredited consulting firm to implement the EMAP/M is
acceptable.

B. CONTENTS OF BEMAP/M AND EMAP/M


EMAP/M shall contain the following topics:
• Executive Summary
• Environmental Policy and Monitoring and Audit Objectives
• Baseline Monitoring (for BEMAP/M only)
• Compliance Monitoring
• Impact Monitoring
o Identification of Significant Impacts to Monitor
o Selection of Monitoring Parameters
o Setting of Environmental Quality Limits
o Sampling and Measurement Plan, including Quality Assurance
• Budget
• Accountability

40 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

• Stakeholder Participation
• Complaints Management, Communication and Reporting
• Environmental Impact Event / Action Response Plan
• Audit Program
• Schedule for Baseline Monitoring and Preparation of EMA Manual for Design, Construc-
tion, Operation, and Abandonment Phases
• Appendices

1. Executive Summary
The Executive Summary serves as an overview of BEMAP or EMAP. It shall contain a
Summary Matrix (Table 4-1) that lists the environmental and audit (EM&A) objective,
significant environmental aspects and impacts (EA&I) selected for monitoring and specify
the monitoring elements, such as the parameters selected for the monitored aspect or
impact, the sampling and measurement methodology for each parameter, the account-
ability for each monitoring task and logistics required. The following format may be
used as guide. The contents of the environmental aspects and impacts may vary
depending on whether it is a BEMAP or an EMAP.
Table 4-1.
Environmental Monitoring and Audit Summary Matrix.

Environmental Sampling and


Monitoring and Environmental Aspect & Impact Parameter Measurement Budget Accountability
Audit Objective Specifications

ECC Conditionalities
To comply with Compliance
ECC and EMP Monitoring
requirements
EMP Commitments

To detect any Impact


residual impact Monitoring

To track any Compliance


noncompliance Issues and
and compliance Complaints

The Executive Summary will also provide a brief narrative on the monitoring and audit
design. The narration will specify the parameters or characteristics of the EA&I to be
measured, what, where, when, how to sample and measure the parameters, the envi-
ronmental performance evaluation criteria, the environmental management response to
monitored changes, especially noncompliance and complaints, communication and
reporting protocol, accountability and logistics. An audit scheme must be included,
which may be done in-house and third party, such as the MMT and an independent
environmental checker (auditor).

Any significant change in project design that may affect BEMAP, or EMP and EMAP
should also be summarized and the corresponding EM&A objective change noted.

World Bank - DENR SEPMES PEISS 41


Introduction and Technical Guidelines

Reviewers should ensure that all the abovementioned information is presented and that
the section is technically accurate.
2. Environmental Policy and EM&A Objectives
An Environmental Policy Statement must be made by the proponent’s top manage-
ment. The Policy Statement shall address the proponent’s commitments and prin-
ciples governing the project’s environmental performance and shall provide the frame-
work for setting of environmental monitoring and audit objectives, targets, and strate-
gies for implementation. A typical Policy Statement will elaborate the proponent’s
commitment to comply with the ECC conditionalities and EMP requirements and rel-
evant environmental laws and standards, and to pursue continual improvement of envi-
ronmental performance through an established environmental management system.
Examples of environmental policy, EM&A objectives and targets are given in Appendix
2.

Reviewers should ensure that the policy and objectives are achievable and aligned with
the goals of the EM&A activities.
3. Baseline Monitoring
Baseline environmental monitoring involves the sampling and measurement of environ-
mental parameters during a representative preimplementation period to:
• Determine the nature and ranges of natural variations. Baseline environmental data
will show the condition of the natural environment and upper and lower fluctuations
before the project is established and identify other possible sources of environmen-
tal impacts
• Establish EQPLs. By conducting a baseline monitoring, the proponent can set
levels that will serve as a warning of environmental deterioration because of project
activities. For example, a water body that will be directly affected by a proposed
tuna canning facility has been identified during the baseline monitoring to have a
biochemical oxygen demand (BOD) of 20 mg/L. The proponent can then set the
EQPL for that water body. If future environmental monitoring shows that the water
quality in terms of BOD is deteriorating (i.e., higher BOD values), it will serve as a
warning that the project may have an impact and that additional mitigation measure
may be needed to address the deterioration.
• Show the suitability of impact, control, and reference monitoring stations. It is
during the baseline monitoring, specifically during the preparation of BEMAP/M
that monitoring stations are identified. To properly identify the monitoring stations,
the basic design and blueprints of the project must already be available to deter-
mine potential impact points of the project. These will then be contextualized
within the landscape of the proposed location of the project. For example, sam-
pling stations will be established for the source of impacts such as the ash pond for
a power plant, stack emissions, and effluent outfall. Sampling stations will also be
established for sensitive receptors such as the nearest community downwind of the
project, a national park serving as the habitat of certain endangered species, the
water source of the community, and agricultural lands affected by the project. Sam-

42 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

pling stations will also be established at areas that are not affected by the project to
act as control and reference stations. These areas will include a community up-
wind of the project site, a groundwater source upgradient of the water table or a
bathing area upstream of the effluent outfall.

4. Compliance Monitoring
Compliance monitoring is focused on the status of proponent’s delivery of commit-
ments made in its EMP and meeting the ECC terms and conditions. Appendix 3
presents the form currently used by EMB which will further be retained under the En-
hanced System. This form will be integrated into EMAP/M.

In case ECC contains specific conditionality related to compliance with environmental


laws, rules and regulations other than PD 1586 and its IRR, the compliance status of
the specific conditionality shall be merely noted in the EIA Module of the SMR and the
compliance issue resolution referred to other more appropriate SMR modules (i.e., PD
984 or RA 6969 or RA 8749 or RA 9003 modules) pursuant to DAO 2003-27.
5. Impact Monitoring
Impact monitoring addresses actual changes in the environment that project features
and activities to have triggered or directly caused. The occurrence or nonoccurrence of
an impact is the best concrete indicator of a project’s environmental performance. How-
ever, it is best to detect a potential problem ahead of the actual impact rather than later
to minimize any damage that may be caused by the project.

The Philippine EIA System views the environment to be composed of physicochemical,


biological, and socioeconomic components. Thus, impact monitoring will cover all
kinds or environmental aspects of a project as well as broad categories of impacts from
both the natural and man-made environments.

In view of the wide range of environmental aspects and impacts potentially attributable
to a project, it is practical and much more useful for environmental decision-making to
focus on significant and critical ones in the light of limited resources. There are several
tools that can be employed for the identification of significant environmental aspects
and impacts as well as the selection of critical parameters that must be monitored.
a. Identification of Significant Environmental Aspects and Impacts
The first step in preparing the project-specific BEMAP or EMAP is to select the
project’s critical environmental aspects and impacts (EA&Is) that will be moni-
tored. EA&Is are derived from the long list of significant EA&Is identified in longlist
scoping process, EIA study and articulated in EMP, which may also be incorpo-
rated in ECC.

By definition, the project’s environmental aspects are those environmentally rel-


evant project elements and activities, including processes, procedures, mitigation
and enhancement measures, and the likes, excluding monitoring and audit. The
elements that pose potential burden to the environment are also called environmen-
tal stressors. The environmental impacts are physical, chemical, biological or
socioeconomic changes in the environment that may either be positive or negative

World Bank - DENR SEPMES PEISS 43


Introduction and Technical Guidelines

caused by the project’s environmental aspects. The emphasis in BEMAP and


EMAP is on the negative environmental impacts.

The critical EA&I selection criteria include the following:


• Probability to cause adverse environmental damage to environmental systems
(flora, fauna, habitats, ecosystems) and human health and welfare if improperly
managed. Examples are the specific activities of highly pollutive or high-risk
ECPs and projects in ECAs generating toxic and hazardous wastes
• Vulnerability and high conservation value of potential environmental receptors,
such water supply, fishing grounds, and protected areas
• Long gestation period for mitigation or remediation or enhancement, such as
reforestation, transplantation of corals, and sanctuary establishment
• Uncertainties due to unproven or unfamiliar technology used or mitigation mea-
sure employed or unfamiliar operating environment
• Other criteria that EMB or RevCom may impose.
The selection process can employ a weighting-scaling formula, which may be de-
rived from Delphi or other consensus-building techniques, similar to the ones used
in the EIA Impact Assessment phase. Alternatively, an environmental risk assess-
ment technique may be used, such as the NRIPS developed by the Industrial
Environmental Management Project. An highly recommended adaptation of the
NRIPS for selecting and prioritizing EIS-issued projects called PEMAPS is shown
in Appendix 1.

Another method which is more sophisticated and thus more difficult to use is the
ADB’s environmental evaluation technique or the extended benefit-cost analysis
framework. Environmental checklists for various project categories are available in
the literature and may be used in selecting the EA&I and the corresponding param-
eters for monitoring and audit (Appendix 4).

The scoping report will identify the impact zones of the proposed project. Impact
zones are areas that will most likely be directly or indirectly affected by the project.
Impact zones are primarily identified based on the type of project and knowledge of
the biophysical and social environments of the proposed location. These areas
should be delineated on a map.

The EIA system identifies two types of impact areas:


• The primary impact area(s) are areas where the project will construct facilities
or infrastructures such as a waste treatment plant, buildings, access roads,
mining area, among others. These areas could cause critical environment or
social change such as population displacement, potential flooding, deforesta-
tion, disturbance of habitats, and other possible adverse changes.
• Secondary impact area(s) refer to the influence area of the project that could
be indirectly affected. These may include areas in the vicinity of the direct
impact zone, and may include communities outside of the direct impact area
that may benefit from employment from the proposed project, subtributaries of
the river system which can be indirectly affected by pollution, or water sources
outside of the direct impact zone which could be affected by drawdown from
the project.

44 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

In any case, the end point of the EA&I selection is a prioritized list that can be
expanded or trimmed off depending on the available manpower and logistics as well
as overall attainability of the environmental monitoring and audit tasks and objec-
tives.
b. Selection of Monitoring Parameters
Each critical or significant EA&I selected for monitoring will be included in BEMAP/
M and EMAP/M for the specific project. The monitoring design will specify the
parameters or characteristics of EA&I to be measured, among others. The selec-
tion of the parameter(s) to use for each of EA&I is a very important step in estab-
lishing the credibility and validity of the entire monitoring and audit program.

The following criteria may guide the selection of parameters for EA&I:
• Relevance – The parameter must provide the type and amount of information
needed to meet a specific monitoring objective. For example, if the objective
is to track the effectiveness and compliance of a mitigation measure such as a
wastewater treatment plant for an organic pollution, then the parameter to be
used is the biochemical oxygen demand (BOD) of the end-of-pipe effluent.
Another example, if the monitoring objective is to protect a downwind commu-
nity from air emissions of a cement factory, then the parameter of choice must
be the total suspended particulates of the stack emission as well as the ambi-
ent air quality at the community or, better, several sampling points before the
emission reaches the community. Another example, if the objective is to pro-
tect an adjacent community from contaminated water supply of a coal-fired
power plant, then the parameter is the content of heavy metals, such as mer-
cury and cadmium, in the ash pond and the affected groundwater, including the
point of abstraction of drinking water by the community.
• Representativeness – The parameter must indicate directly or reflect indi-
rectly the unique characteristic(s) of EA&I relevant to environmental values and
decision-making. For example, the organic pollution of a water body may be
represented as the organic carbon content or by BOD or by other parameters.
• Measurability - The parameter must be able to measure, perceive or appreci-
ate quantitatively or qualitatively in a replicable and standardized manner. The
measured data must be able to be processed and tested for statistical validity
and presented in graphs or tables or other data processing and presentation
format.
• Cost-Effectiveness – The sampling and measurement costs must be afford-
able and commensurate to the environmental value of the parameter and its
EA&I.
• Simplicity - The parameter must be simple to understand and appreciate in
terms of environmental decision-making.
The parameter-rating called Environmental Stressor Rating Scheme (ESRS)
may be used to facilitate selection of parameters to monitor, as adopted from the
ADB Economic Valuation Handbook (1996), is shown in Appendix 5. It is worth-
while to review the selected critical parameters in terms of inclusion of stakeholder
concerns and other public interest issues.

A summary table (Table 4-2) showing the selected critical monitoring parameters

World Bank - DENR SEPMES PEISS 45


Introduction and Technical Guidelines

integrating relevant information for designing a Sampling and Measurement Plan


should be included. The information required are: the EM&A objective being ad-
dressed, the significant EAI identified, the monitoring parameters, recommended
action or mitigation measure in case of noncompliance or exceedances as well as
the project phase when the monitoring should be done. This information is com-
bined with the source of the environmental stressor, the environmental pathway and
the location of vulnerable receptors (see Appendix 5) as well as with the selected
sampling and measurement methodology for each parameter to almost complete
the design of a Sampling and Measurement Plan discussed in the next section.

c. Sampling and Measurement Plan


Another foremost concern of the proponent is the scientific credibility of the data
sets. Any misinterpretation, miscalculation or error arising from the sampling and
measurement activities can be very costly to the proponent. As they say, “Garbage
In, Garbage Out”. Thus, the proponent has his best interest in mind by preparing a
scientifically sound and socially acceptable EMAP. A good EMAP is charac-
terized by a carefully designed sampling and measurement plan (SAMP) for
each of the parameters selected.

Scientific credibility is best attained by adhering to the official and standard meth-
ods developed and adopted by the different professional associations and imple-
menting a QA/QC program. In the environmental chemistry field, for example,
physico-chemical analysis of air, water, and soils are managed by the Association
of Official Analytical Chemists (AOAC) and the American Public Health Association
(APHA), among others. Standard methods for a wide variety of materials are handled
by the American Society for Testing Materials (ASTM). There are European, Japa-
nese, and other country-specific standard methods as well. In the Philippines,
EMB has released official methodologies for both air and water studies, but these,
while still valid, are in dire need of major updating efforts.

The sampling and measurement plan should also contain the following features:
• Parameters Selected - The type and number of measurements selected for
each parameter must yield relevant data sets that can be subjected to statisti-
cal processing and interpretation as well as presentation in graphs or tables.
This means that there should be enough replication for each control and treat-
ment (if any) sampling point to allow computation of mean and standard devia-
tion values for comparing both and enough repetition or replication over loca-
tion, time and season to allow analysis of variance.
• Sampling Protocols - The sampling points or locations, frequency, duration,
method of sampling and sample handling and preservation and other standard
requirements for the parameters to be measured must be specified in relation
to the objective of the monitoring.
• Methodology - The specific sampling and measurement design for each pa-
rameter should adopt official and standard methods set for that parameter by
relevant professional groups or scientific associations. If there are no official or
standard methods, the procedure commonly accepted and performed by the
relevant professional or scientific body should be employed. It is therefore
important that EMB or its MACOM should include an expert or a specialist for
the relevant discipline as a resource person.

46 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

Table 4-2. Selection of Parameters for Monitoring of Critical


Environmental Aspects and Impacts (EA&I).
Environmental Action for Non- Project Stage
Monitoring compliance /
Objective Aspect or Parameter Mitigation Measure Des Con Ope Aba
Impact
1)To protect Stack emission Total Suspended Increase stack X
valuable Particulates; height; install addi-
receptors heavy metals in tional air pollution
against fly ash control device, e.g.,
environmen- wet scrubber, elec-
tal stressors trostatic precipitator
from a coal-
Downwind Ambient air Increase stack X X
fired power
community quality: Total height; install
plant
Suspended additional air
Particulates; pollution control
heavy metals; device; provide
URTI morbidity personal air filter
and mortality mask in case of
excursions
Downstream Heavy Metals in Seal leakages X X
communal water ash pond and from ash pond;
supply gradient of intensify monitor-
adjacent ground- ing; provide
water body, alternative drinking
including abstrac- water source
tion point
Downwind Ambient air X X
Protected Forest quality: SOX,
TSS; precipita-
tion: acidity/pH;
flora and fauna
biodiversity
Index; tree
growth rate (dbh)
of protected
species
Coral reef near Water temperature
cooling water in mixing zone and
outfall adjacent ambient
waters; live coral
cover and
composition; fish
catch
2) To protect the Small farms of
ecosystem neighboring
from land farming
development community
(housing
subdivision)

Legend: Des: design, Con: construction, Ope: operations, Aba: abandonment

World Bank - DENR SEPMES PEISS 47


Introduction and Technical Guidelines

• Quality Assurance - The sample analysis must be performed by EMB-ac-


credited laboratories and signed by registered chemists. Quality assurance
procedures of these laboratories must be specified including interlaboratory
comparisons and statistical techniques. Data quality objectives (DQO) and
data quality indicators (DQI) should be included. The number of QA/QC samples
to take, such as duplicates, blanks, and trips must be specified for each pa-
rameter. A Chain of Custody (COC) procedure must also be built into SAMP.
Lastly, the decontamination procedure to be used if needed during the actual
sampling activity must be defined. The COC will document each sample from
the time of its collection until its receipt by the analytical laboratory. Internal
laboratory records then documents the custody of the sample through its final
disposition.
• Sample Labeling - Each sample should labeled with a unique project identi-
fication number recorded on a sample data sheet along with other information
such as sampling date, location of the sample, size of the sample (volume or
area), sampling flow rate, sampling start/stop time, and conditions (environ-
mental and operational) of sampling.
• QA/QC samples include the following;
o Field Blank Samples - nonexposed sample of the medium being used for
testing (e.g., mixed cellulose ester membrane filter).
o Laboratory Control Samples – Example, matrix spiked with known con-
centration of lead analyzed for each sample matrix e.g., paint chip, wood
chip, brick substrate, and mixed cellulose ester filter. Laboratory control
samples (LCS) consists of each matrix spiked with a certified reference
material such as in the case of the example mentioned: paint chips - NIST
Standard Reference Material 2589, air sampling filters - Fisher Scientific
Lot # 973670-24, TCLP extracts -High Purity Standards Lot # 726120, and
soil - Environmental Resource Associates Inorganic Trace Metals Lot #
235. Laboratory control samples are analyzed with each sample set
processed to verify that the accuracy and bias of the analytical process
are within control limits.
o Replicate Sample Analysis - determines the precision of the analytical
method on each matrix.
o Method Blanks - documents any contamination resulting from the analyti-
cal process.
• Each sampling and analysis plan should include a schedule that clearly
specifies the time when each element of the monitoring and evalua-
tion report will be completed. Elements to be scheduled include:
o Field mobilization
o Field sampling
o Field demobilization
o Shipment of samples to laboratories
o Initiation and completion of physicochemical and biological analyses
o Initiation and completion of data validation
o Submission of draft and final reports
• Maximum holding times for each type of sample should be explicitly speci-
fied. Along with the schedule, a brief discussion should be provided describing

48 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

the rationale for the frequency, timing, and phasing (if any) of the sampling and
analyses.
• The records of all sampling and measurement activities and results should be
kept for at least two years in case there is a need for audit later on.
• SAMP is subject to review both by MMT and EMB. EMB shall approve the final
SAMP as the core of the EM&A program for the specific project.
An example of a SAMP is given in Appendix 6.
d. Setting Environmental Quality Performance Levels
EQPLs are environmental performance criteria set for each selected parameter. At
least two EQPLs are required, namely action and limit levels. A third optional
criterion is the early warning level which is actually a red-flagging alert level.

The limit level may indicate the regulated threshold of a pollutant or environmental
characteristic, which may be expressed in terms of standards that must not be
exceeded (as in the case of pollutants) or optimum range to maintain (as in tem-
perature and pH or acidity of a water body). In quantitative terms, reaching and
exceeding the limit level is the worst case of environmental performance. If the limit
level is exceeded, the appropriate environmental management action can
take the form of the following:
• Issuing a cease-and-desist order (CDO) to stop any imminent threat or actual
damage to the environment, property, and limbs and lives,
• Instituting emergency response to contain the damage or threat or protect
potential receptors and launch rescue operations, where needed,
• Implementing rehabilitation and remediation measures, when called for.
Where there are no legal standards, scientific criteria or internationally ac-
cepted thresholds may be employed to set the limit level. Alternatively, for param-
eters that are not regulated nor have a scientific or international criteria or basis,
consensus- building among the key stakeholders may be resorted to. Stake-
holder consensus can also be used in setting environmental quality criteria for
hard-to-quantify parameters such as some socioeconomic indicators related to
quality of life or poverty indices.

The action level on the other hand, is usually that point where the environmental
change is significant enough but has not yet reached the limit level. The action
level indicates that management measures must be employed such that further
deterioration to the limit level is not reached and, preferably, reverse the deteriora-
tion to pre-impact or optimum environmental quality.

Management measures can take the form of intensifying the monitoring and audit
program, scaling up or upgrading the mitigation measures or introducing innovative
and effective control measures or improving or changing the project technology
(such as clean production, clean technology). Either expert judgment or similar
experience elsewhere or statistical techniques may be employed to set the action
level.

If an early warning is desirable, a third optional level called the red-flag level may be
set. This usually signals that the environment is starting to change toward a nega-

World Bank - DENR SEPMES PEISS 49


Introduction and Technical Guidelines

tive direction (deterioration of environmental quality) indicating that the project is


causing residual impacts. However, this change may be due to a natural fluctua-
tion or another environmental stressor apart from the project, or a sampling and
measurement error or another factor external to the project.

The red-flag level is best set using statistical techniques. For example, the red-flag
level of mercury, a highly toxic metal, in a stream classified as Class C waters may
be set at 2 to 3 times the standard deviation of the baseline average mercury
content, provided that this value is still below the action and limit levels. The main
idea is to be able to detect the start of a significant environmental change and call
the attention of the proponent to study the matter more closely.

Pertinent responses in case the red-flag level is reached are, for instance: 1) re-
peating or confirming the analytical results, preferably using an accredited refer-
ence laboratory, 2) reviewing the potential stressors and the mitigating measures,
3) investigating other possible stressors outside the project, or 4) establishing ad-
ditional, more reliable control points through additional baseline measurements
that can better detect natural fluctuations of the parameter.

An example of the setting of EQPL is given in Appendix 7.


6. Budget
A realistic and sufficient budget for conducting the environmental monitoring and audit
activities is the clearest indication that the proponent will effectively implement its ap-
proved BEMAP or EMAP. The following cost items are expected to be identified in
BEMAP and EMAP:
• Personal services (regular and contractual staff as well as external auditors and
consultants)
• Maintenance and Other Operating Expenses
o Travel
o Supplies and Materials
o Equipment Rental
o Laboratory Fees
• Capital Outlay
o Equipment (Field and Laboratory)
o Laboratory and other related Facilities
o Vehicles
o Software and Hardware
• Miscellaneous Expenses
The proponent should particularly include in the detailed budget the full cost of the
sampling and measurement program. In case of outsourced services, the de-
ployed equipment must be identified and where these will be sourced. Moreover,
the proponent must give information on the cost of procuring or renting the equip-
ment, the cost of the containers and preservatives to be used, and the cost of
transporting the samples. The budget should also specify the cost per parameter
for laboratory analyses.

DAO 2004-30 further requires the proponent to establish an Environmental Guaran-

50 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

tee Fund (EGF) and an Environmental Monitoring Fund (EMF). EMF is used to
support the activities of MMT organized for the specific project or cluster of projects,
as the case may be. Respective guidelines for EMF and MMT are found in Chapter
VII of this Handbook.
7. Accountability
BEMAP/M and EMAP/M shall specify the requirements for qualified personnel charged
with the routine EM&A of the project activities, detailing the education, training, knowl-
edge, and experience of the environmental team. The Plan/Manual may identify the
need for independent auditing of the environmental performance at all stages of project
implementation.

Management structures, procedures, and protocols shall be presented in EMAM. An


organizational chart shall be presented showing the reporting flow and coordination
links of the environmental team to the project management and the project engineer
during design and construction stages of the plant or operations manager during the
operation and abandonment phases. The roles and functions of every personnel in-
volved must be listed. The contact person(s) for EMB and other external transactions
shall be named.

An environmental training and awareness program shall be presented. The program


shall show how a necessary and sufficient level of understanding of the environmental
issues appropriate to the targets of regulatory requirements and EMAP can be effected
not only among the environmental staff but also the management and employees at all
levels of the project facility, site, and management operations.
8. Stakeholder Participation
Stakeholders, particularly community MMT (if formed already at the time of the monitor-
ing/sampling activities) should be encouraged by the proponent to participate in the
conduct of baseline monitoring activities. Baseline monitoring with stakeholder partici-
pation and community involvement may form an important part of the scoping process.

BEMAP/M or the EMAP/M should detail the procedure for stakeholder participation.
The participation can be in the form, for example, of: 1) a structured MMT, 2) a less
structured one through a complaints or public relations desk, or 3) organized commu-
nity or stakeholder consultations. It is important to undertake proper stakeholder
identification. Refer to Volume 2 of this Handbook for specific guidelines on stake-
holder participation and MMT.
9. Complaints Management, Communication, and Reporting
Protocols for managing complaints must be outlined in BEMAP or EMAP as appropri-
ate and detailed in BEMAM and EMAM. These should address the complaint receiving
setup, case investigation, implementation of corrective measures, communication with
the complainant/public, and complaint documentation.

Communication and reporting procedures should also be detailed in BEMAM and EMAM.
These should include:
• Methods of communication (e.g., correspondences, phone call, facsimile, and
electronic mail)

World Bank - DENR SEPMES PEISS 51


Introduction and Technical Guidelines

• Liaison with EMB and other regulatory bodies, media, local community, and spe-
cial interest groups and other stakeholders
• Early Warning System for imminent hazards and Emergency Response to ensure
public safety
• Circulation of project’s environmental statement
• Triggers for sending communications and reports
• Type and Frequency of reporting
• Persons responsible for making the report
• Feedback mechanisms for complaints
10. Environmental Impact Event / Action Response Plan

Appropriate and effective environmental impact remedial actions or mitigation mea-


sures must be specified in this section in case:

• Monitoring and audit data indicate noncompliance with any of the prescribed envi-
ronmental performance criteria and exceedances over any applicable environmen-
tal standards or self-defined EQPL
• Vulnerable environmental media and human receptors indicate unacceptable dete-
rioration or degradation or adverse health and welfare impacts, respectively.
In the event that the proponent faces a compliance issue, such as issuance of a Notice
of Violation or worse a CDO, the proponent should have an environmental management
plan that specifically addresses this issue. This may involve implementing remedial
action such as cleanup, storage, and disposal of wastes, restoration and remediation,
and compensation or substitution. The plan should identify the persons responsible for
each segment of the response plan, the procedures necessary to implement the re-
sponse plan, identify possible restraining forces that may inhibit the response plan, and
identify resources, government agencies, or plans that may make the response plan
more effective.

The proponent should also document actual measures taken and report to EMB and
other responsible government agencies as well as the affected communities.
11. Audit Plan or Program
In this section, the proponent shall describe any auditing activity that is planned for
each facility. The Audit Program must indicate the audit activity, purpose, audit objec-
tives and criteria, audit frequency and schedule, auditor, at the very least.This audit
may be in compliance with a certified Environmental Management Systems, such as
the ISO 14000 series. The proponent may hire the services of another third-party
auditor accredited by EMB or other concerned government agencies, such as the Bu-
reau of Product Standards.
12. Schedule for Baseline Monitoring and Preparation of BEMAM/EMAM for
Design, Construction, Operation, and Abandonment Phases
BEMAP/M and EMAP/M should also include a work plan for the continued collection of
baseline monitoring data which should have started during the EIA study proper. The
schedule should show at what time baseline monitoring of each parameter will end i.e.,
start date for construction or operations depending on parameter. Continuing baseline
monitoring until there is project-induced change in the environment and human condi-

52 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

tion is important in fine-tuning the setting of the EQPL.

The proponent should also present the schedule in preparing and submitting the manu-
als for the design, construction, operation, and abandonment phases. The manual can
be submitted individually or can be integrated as a compendium depending on the
schedule of the proponents and how complicated the process for each phase is.

V. GUIDELINES FOR PREPARATION OF THE BASELINE ENVIRONMENTAL MONITORING


AND AUDIT REPORT AND SELF-MONITORING REPORT BY PROPONENT

A. PURPOSE OF THE GUIDELINES


1. Baseline Environmental Monitoring and Audit Report

These Guidelines for the Preparation of the BEMAR specify the contents and the infor-
mation that the proponent/preparer is expected to submit to EMB as part of the EIA
process.

BEMAR is based on BEMAP/M that is initially submitted by the proponent during the
Scoping Phase when the important environmental aspects and impacts of the project
are identified on a preliminary basis to guide the conduct of the EIA Study. BEMAR will
become part of the EIS document subject to review for ECC processing. Henceforth,
BEMAR will be submitted regularly (quarterly) until the construction phase begins or
until significant changes due to project construction and operations are made. As
BEMAP is completed, there is a continuity of monitoring through the regular EMAP.
EMB may extend the length of the baseline information period because of the need to
collect additional data to show a trend of the natural environment or in cases when
ECA, such as protected areas, national parks, protected seascapes, and the likes may
be affected by the project. In case proper control monitoring stations can be estab-
lished, baseline monitoring may be pursued even throughout the project life. This is
useful in adjusting EQPL whenever the natural environment has changed on its own or
through other nonproject man-made interventions.

BEMAR contains scientific discussions and the methodologies used in determining the
state of the natural environment which will be affected by the project prior to its con-
struction as well as control stations that need to be established for comparing the data
collected during the regular monitoring period. This will determine if the actual impacts
are within the limits of those that were predicted under EIA and to ensure that changes
to the natural environment do not go beyond the Limit Level set in the ECC.
2. Self-Monitoring Reports
The Guidelines in preparing SMRs by the proponents are intended to specify the type
and extent of information that the proponent is expected to disclose to EMB, MMT, and
other stakeholders as a result of implementing EMAP/M. Pursuant to DAO 2003-27
EMB requires the proponent to quarterly submit SMRs. On the other hand, in compli-
ance to the EIA Module as stipulated in DAO 2003-30, proponent is also asked to
submit semiannual monitoring report on compliance to PD 1586.

The EIA module of SMR contains the status of EA&I of the projects to determine if the
proponent complies with the EMP and ECC, conditionalities. It can serve as a sum-

World Bank - DENR SEPMES PEISS 53


Introduction and Technical Guidelines

mary for the other modules as the EIA by its nature cuts across various regulations.
This module will therefore act as a management tool for regulators as it covers/summa-
rizes the other modules in SMR. Further, it shall contain scientific discusion and the
methodology used in determining the compliance of the proponent to the critical EA&I
identified in the EMAP. Following is a discussion of the major topics in the EIA module
of the SMR (initial version is the BEMAR).

B. CONTENTS OF THE BASELINE ENVIRONMENTAL MONITORING AND AUDIT REPORT


AND THE SELF-MONITORING REPORT (EIA MODULE)

The annotated outline BEMAR and SMR is as follows.


1. Executive Summary
This section contains a summary of the whole report. It should include the scope and
purpose of the study. It should include which specific parameters were monitored, where
the monitoring stations are located and the monitoring period.

It should also include a summary of the major findings for the monitoring period. For
example, a statement that there were no major activities that influenced the monitoring
parameters during the monitoring period can be made if there were really no activities
by the proponent that affected the monitored parameters.

BEMAR and SMR should contain a table matrix similar to the following format:

Table 5-1 Summary Matrix for BEMAR and SMR.

Impact/Conditionality/Commitment Status Action Taken Recommendation

2. Introduction
This should be a generic section that can be used for several projects’ BEMARs and
SMRs. The only information in this section expected to change are:
• Name of project proponent
• Name of project
• Name of monitoring team/individual consultants/consulting firm
• Dates
• Locations

54 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

3. Project Background
This section should provide a brief background about the type of project, significant
milestones achieved i.e., date of scoping, submission of scoping report, date ECC was
approved, and date EMAP was approved.

The section may be generic for all BEMARs or SMRs for a specific project. However,
changes in BEMAP/M or EMAP/M and additional milestones may occur which will
necessitate changing/adding this section.

As part of background documentation, the following information in pictorial or map for-


mat must be appended:
• Location Plan and Facility Process Flow Chart or equivalent Project Operations
Document
• Location of Sensitive Receptors
• Drawings (to scale) showing locations of the Monitoring Locations with proper la-
bels
• Implementation Schedule

4. Methodology
This section should describe the steps/scientific process used in the monitoring event.
It should frequently refer to BEMAP/M or EMAP/M; specifically, the Sampling and
Measurement Plan (SAMP). In the event that SAMP was not followed, the reasons
should be given in this section. Deviations should be presented in a table as follows:

Table 5-2 Dummy Table for Reporting Methodological Revisions.


Planned Activity Actual Activity Reason for Deviation

5. Results and Discussion

a. Summary of Previous Monitoring


The key findings, recommendations, and action plan from the previous monitoring
and outstanding issues from earlier monitoring periods (if applicable) should be
highlighted in this section. The status of the recommendations and measures
included in the action plan should be described and any unmet commitment must
be rationalized and alternative, if needed, presented.

A suggested format is to give a brief description of the environmental setting of the


previous monitoring. It should also contain the summary table in the executive
summary of the previous monitoring with an added column to check if the previous
recommendations were implemented. In the event that previous recommendations
were not implemented, the reason behind it should be specified.

World Bank - DENR SEPMES PEISS 55


Introduction and Technical Guidelines

(i) Compliance Monitoring


The status of compliance to the ECC conditionalities and the attainment of EMP
commitments should be elaborated in this section. The appropriate EMB form
for this purpose (Appendix 3) should be presented as a running total of compli-
ances and met commitments. Reasons for noncompliance or unmet commit-
ment should be explained and solutions and measures to attain full compliance
of ECC terms and conditions as well as satisfactory attainment of EMP commit-
ments should be discussed as renewed efforts for the next monitoring period.
(ii) Impact Monitoring
It should be noted that EIS where the decision to grant or deny ECC was based
mainly with predicted environmental impacts of a project. In this section, valida-
tion of the predicted impacts through the monitoring of actual project impacts is
reported to provide a basis for effective planning and management of environmen-
tal measures. Graphical presentation of quantitative and semiquantitative impact
monitoring results over the whole monitoring period is an excellent way of pre-
senting past monitoring results. The latest monitoring findings and conclusion
should be discussed in text form. The information added by the current monitor-
ing period may also be plotted on the same graphical formats.

Qualitative impact monitoring results may be presented in text form or in terms of


pictorial coverage, if applicable. Examples of qualitative impacts are those relat-
ing to quality of life, degree of happiness, and sense of environmental cleanli-
ness.
b. Reports of Complaints and Environmental and Health-related Accidents
The protocols for managing complaints must be outlined in EMAP and detailed in
EMAM. These should address the complaint receiving setup, case investigation,
implementation of corrective measures, communication with the complainant/pub-
lic, and complaint documentation. If there is an MMT established for the project,
proper coordination mechanisms with MMT must be put in place.

A complaints investigation protocol may consist of the following steps:


• Log complaint and date of receipt into complaint database and inform EMB
(and MMT) immediately
• Investigate complaint to determine its validity and to assess whether the prob-
lem is due to project activities
• If a complaint is valid and due to project activities, identify mitigation measures
in consultation with EMB (and MMT)
• If mitigation measures are required, request decision-maker for resources and
implementation requirements
• Review implementation and current situation
• Report to EMB (and MMT) on status of complaint investigation and follow-up
action
• Undertake M&A to verify complaint, if needed, and identify preventive measures
• Inform complainant about investigation results and subsequent actions
• Log a record of complaint, investigation and follow-up actions, and results in
the monthly EM&A Reports and SMR
Communication and reporting procedures should also be detailed in EMAM. These
should include:

56 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

• Methods of communication e.g., correspondences, phone call, facsimile,


and electronic mail
• Liaison with EMB and other regulatory bodies, media, local community, and
special interest groups and other stakeholders
• Early Warning System for imminent hazards and Emergency Response to
ensure public safety
• Circulation of project’s environmental statement
• Triggers for sending communications and reports
• Type and Frequency of reporting
• Persons responsible for making the report
• Feedback mechanisms for complaints

c. Current Monitoring Results and Findings


The data collected from the various sampling and measurement events done
under SAMP are presented in tabular form and discussed under this section.
One table must be prepared for each sampling point or location. Only processed
and summarized data must be presented here. The raw data should be included
in the appendices section of the report.

The results must be related to the historical trend for the parameter. Any devia-
tion from this trend must be explained. More, importantly, the discussion must
focus on point-by-point comparison of the gathered values with the set EQPLs
developed during the scoping and explained in detail in BEMAP/M. The monitor-
ing results could also be used to determine the action and limit levels for the
specific project. These should all be presented here in detail and summarized in
the conclusions and recommendations section.

Compliances, noncompliances, and exceedances must all be thoroughly ex-


plained. In cases of compliances, success factors must be cited. For
noncompliances and exceedances, the proponent’s response should be explained.
Moreover, causative factors must be identified and additional solutions and miti-
gation measures proposed, if needed.

It should also include the major activities carried out on the site during the moni-
toring period. It should also cite the weather conditions and other factors which
may affect the results of the sampling activities.

A summary table may be included with the following format:

Table 5-3. Summary Table for Reporting Monitoring Results.

Parameter Frequency Date/Time Location Analytical Result EQPL


Sampled Red- Action Limit
Flag

World Bank - DENR SEPMES PEISS 57


Introduction and Technical Guidelines

6. Conclusions and Recommendations


This section should present the conclusions and recommendations of the current
BEMAR or SMR based on the results and discussion of the previous sections. It
should also explain if the previous monitoring recommendations should continue (if
implemented). On the other hand, if warranted, the recommendation may be the
cessation of specific or all monitoring activities.

The conclusions and recommendations should preferably be in a bulleted format and


as much as possible grouped according to coherent themes, such as the following
headings.

For a BEMAR, a summary on identifying the alert, action, and limit levels for a spe-
cific parameter and how they were set needs to be presented in this section.
a. Compliance Status
Only the key conclusions about the status of compliance to ECC and EMP are
included in this section. The status of noncompliances should be particularly
tracked throughout all SMRs even if compliance has been already attained. Rec-
ommended additional measures or amendments to BEMAP/M or EMAP/M should
be presented here.
b. Environmental Quality Status
Only the key conclusions on meeting the set EQPLs are included in this section.
c. Environmental Management Plan Status
Only the key conclusions about the status of EMP implementation and recom-
mended additional measures or amendments should be presented here.
d. PEMAPS Score
The proponent should fill up or update the project’s environmental risk score
using the PEMAPS earlier discussed in this Handbook.
e. Work Plan for Next Monitoring Period
The specific actions for the next monitoring period, including carry-overs from
previous monitoring periods, should be detailed in this section.
7. Appendices
BEMAR or SMR shall typically append the following information:
• Location of Sensitive Receivers and Monitoring Stations
• Location Plan of Plant and Facility Process Flow Chart
• Implementation Schedule and Status
• Environmental Monitoring Technical Summary
• Process Audit Proforma
• Regulatory Compliance Proforma
• Complaint Log
• Calibration Certificate
• Data Presentation

58 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

REFERENCES:

Asian Development Bank (ADB). 1996. Economic Evaluation of Environmental Impacts -


A Workbook Part 1. Manila: ADB, Philippines.

Guerrero, Sylvia H. et al, 1993. Public Participation in EIA. A Manual on Communication.


Environmental Management Bureau and the Asian Development Bank.

DENR Administrative Order No. 21-92. Amending the Revised Rules and Regulations
Implementing P.D. 1586 (Environmental Impact Statement System).

DENR Administrative Order No. 96-37. Revising DENR Administrative Order No. 21, Series of
1992, To Further Strengthen the Implementation of the Environmental Impact Statement
(EIS) System.

DENR Administrative Order No. 2003-30. Implementing Rules and Regulations on the
Rationalization of the Philippine Environmental Statement (EIS) System Implementation.

Environmental Assessment and Noise Division, Environmental Protection Department,


Hongkong. 1998.

Environmental Management Division-Environmental Management Bureau-DENR. Philippines.

Lohani, Bindu N. et al. 1997. Environmental Impact Assessment for Developing Countries in
Asia Volume 1 and 2. Asian Development Bank.

Presidential Decree 1586. Establishing an Environmental Impact Statement System Including


Other Environmental Management Related Measures and for Other Purposes.

World Bank - DENR SEPMES PEISS 59


Introduction and Technical Guidelines

60 World Bank - DENR SEPMES PEISS


Introduction and Technical Guidelines

APPENDICES

1 PEMAPS Scoring Guidelines


2 Examples of Environmental Policy and Objectives
3 EMB’s Compliance Monitoring Form No. CM-3
4 Stressor-Impact for Various Power Project Types
5 ESRS
6 Examples of Sampling and Monitoring Plans
7 Examples of EQPLs

World Bank - DENR SEPMES PEISS 61

You might also like