Environmental (Social) Management Framework

(ESMF):
preparation and implementation aspects

Training Workshop for Financial Intermediaries

and Implementing Agencies
May 2011

Ruxandra Floroiu
Senior Environmental Engineer,
ECA Region, World Bank
ESMF Purpose

OP 4.01 – allows use of ESMF as EA safeguard instrument when:

“a project consists of a program and/or series of sub-projects, and the impacts
can not be determined until the program or sub-project details have been
identified” = before project appraisal

 EA Category FI – subprojects (most identified after project appraisal) are

financed through a Financial Intermediary (“FI”) – requirements and
procedures set-out in an ESMF

 manage potential adverse impacts through a guide consisting of a set of

methodologies, procedures and measures to facilitate adequate environmental
management (risk management and impacts) related to the works financed
under the project and whose specific location is unknown or may change
during project implementation

 social aspects are briefly addressed (not as in RPF) - ESMF

ESMF Purpose
 Provides guidance to sub-borrowers (sub-project sponsors) and FIs to ensure the EA
process is carried out in compliance with national legislation and OP 4.01
 Provides an environmental and social screening process to allow for identification,
assessment and mitigation of potential impacts by proposed works at the time the detailed
aspects are known
 Used as a reference document for assessing the potential environmental and social impacts
of investment alternatives
 Serves as guidelines for the development of sub-project/site-specific Environmental
Management Plans (EMPs), Environmental Assessments (EAs), due diligence reports,
environmental audits, etc
 Is an integral part of the project Operational Manual and applicable to all FIs investments,
regardless of its funding source or implementing agency

MAIN OBJECTIVES:
 Establish procedures for screening all proposed sub-projects for their potential adverse

environmental and social impacts

 Specify measures for managing, mitigating and monitoring environmental impacts during

project operation
 Outline training and capacity-building arrangements needed to implement the EMF

provisions
EMF Procedures Cover

1. Brief description of project components including description of

type of activities eligible for financing
2. Operating requirements (diagnosis of legal and institutional
framework, applicable safeguards)
3. Environmental/social baseline at national/state level

4. EMF screening procedures (criteria, process, environmental

due diligence process, EA/EMP documentation)
5. Implementation arrangements

6. Public consultation and disclosure process/procedures

7. Environmental mitigation measures

8. Monitoring and reporting arrangements

9. Training and capacity building recommendations

10. Various annexes

 EMF (project level)
Prepared by primary Borrower (FI)
Sets out requirements & responsibilities
for sub-project-specific EA
Acceptable to WB
PROJECT
Disclosure and one National level
(FI)
consultation on EMF Sub-project
Preparation, consultation and disclosure (Meski water supply, cat. B)
prior to Project Appraisal
Sub-project
Sub-project
(KaYseri landfill, cat. A)
(Akfirat sewage system, cat. B )

Sub-project-specific EA or EMP (sub-project level)

Prepared by sub-borrower/grant recipient (sub-project implementer), during project
implementation
EA/EMP disclosure and local level consultation prior to finalizing document
FI responsible for quality/clearance and for monitoring implementation
WB prior review of some Category B
EMF Sub-project Screening, Review, Approval
Process
 Screening form to be filled out by sub-project proponent
Sub-project name, location (map), type of activity, physical data,
environmental information, likely environmental impacts,
environmental screening category (A, B or C), mitigation of pollution,
environmental studies required (EIA/EMP), public
consultation/disclosure required.
 Screening Criteria – site-specific environmental risks and impacts;
land zoning requirements, environmental license/permit; “negative”
list of investments not allowed for financing under the project
 Reviewer decides the level of impact to be assessed through EIA
(category A or B) or EMP/EMP Checklist (category B)
 Subproject approved on the basis of environmental and social
review findings (or denied/approved with some changes)
 Disclosure/public meeting – function of subproject EA category
EMF Sub-project Screening, Review, Approval Process
 Identification of sub-project
 Application preparation and its
submission to FI
 EA/EMP financing and
preparation
 Collection of necessary
permits/licenses
 Obtain clearances from
local/regional environmental
authorities
 Implement the sub-project in line
with EMP
 Reports to FI on any EMP non-
compliance
Sub-project proponent
 EA screening for World Bank
requirements
 Review of sub-project
application
 Appraisal of sub-project
 Monitor environmental
compliance based on EMP
 Training of sub-project staff
 Reports to the Bank on any
EMF non-compliance
 Maintains records of safeguard
documents for all sub-projects
Financial Intermediary
 Key Safeguard Actors in EMF

World Bank
Project • Conduct supervision
Team and • Provide safeguard assistance
Safeguard and training
Specialists

World Bank •Ensure policies are followed

Safeguard •Conduct reviews
Compliance

Republic of Turkey •Review and clear sub-projects

Ministry of according to national and
Environment and local regulatory requirements
Forestry • Issue environmental permits
•E-permit (since 2010) for new facilities

8
 Integrating Flow Charts to Guide PFIs
Example of EIA Review Flow Chart for SME Credit Line Projects in Turkey

Annex I Annex II No Annex

EIA
PC Necessary
already PIF(Project Info File)
done EIA Positive No Environmental
Documentation
EIA NOT
Necessary
(**)
Installation of new
WB – A WB – B WB – B Yes
buildings and extension
Category or in Category Category of existing buildings
other ineligibility
list No

Eligible Eligible WB – C
Category
Ineligible
EA with EMP, or EMP / Checklist
EMP alone EMP
WB requires Eligible
EA/EMP and PC
Public Public No Environment
Consultation Consultation Documentation
Role of WB in EMF preparation and implementation

 WB Appraisal evaluates:
◦ adequacy of relevant national EA requirements; EMF
gap-filling
◦ adequacy of proposed EA procedures for sub-projects
◦ capacity of FI and others responsible
◦ measures in project to strengthen EA FI
arrangements/capacity as needed assessment

 WB Supervision:
◦ Prior review/NOB of Category A (sometimes also
Category B) sub-project EIAs (unless FI assessment
indicates this is unnecessary)
◦ Spot-checking of EPF implementation, including site
visits
Subproject Implementation based on EMF

FI has main responsibility for preparing and monitoring the

application and use of EMF. During sub-project
supervision the FI:

 Responsible for assessing the capacity of sub-borrowers to comply with

EMP and more generally to do proper environmental and social
management
 Performs sub-project site supervision visits to confirm EMP
implementation
 Consults local environmental authorities for EMP requirements including
current permits
 Verifies with sub-borrower the overall environmental performance of the
investment including any critical mitigation measure taken and
significant environmental incident
 Prepares quarterly/annually reports on results of EMP actions
 Incorporating EMF into Sub-Project Cycle
Submission of priority proposals
Evaluation/selection of proposals
Eligibility Screening
FEASIBILITY/DESIGN
(Assisted) preparation
of applications EIA/EMP Preparation
Pre-FS Form Sub-Project approval

PRE-FEASIBILITY Environmental Permit

Construction Permit

IDENTIFICATION sub-project cycle Agreement on work

plan, contract signing

SUPERVISION

Start of works
OPERATION
Monitoring of works
EMP implementation
Progress reports
 review of eligibility of
proposal, excluding any
Eligibility Screening
with high environmental
of
riskproposals EA screening, evaluation of
env. issues and proposed
Evaluation/selection of
5 mitigations; scope of EA/EMP,
Submission of proposals eligible
if requiredproposals
4 6
(Assisted)
identify preparation
potential environmental issues Sub-Project approval
and proposed mitigation measures
of applications 3
6 Environmental mitigation
AdviceTraining
to prospective applicants on eligible/ineligible Agreement
measures included inon work
Sub-project
Workshops for 2 2 issues e; potential
activities, potential environmental plan,
contract; contract
includes signing
specific
impacts and mitigation measures for different types of provisions for environmentally
Applicants
sub-projects 7
sound procurement, contracting

Program
1 sub-project cycle
Advertisement
Procurement: include First tranche
environmental
provisions in bidding
8 disbursement
documents,
specifications, contracts (including
penalties for non-compliance)
Final reportISR
Final reports, & report
accounting
on
EMP compliance and
env./social impacts 11
Progress
Sub-borrower report,
monitors according to
Env. Monitoring Plan, reports to PIU;
9 Accounting,
PIU verifies, reports toverification
Borrower & WB
10
environmental measures
maySecond tranche
be triggers for disbursement
disbursement
Challenges of EMF Preparation and
Implementation
 EMF not recognized in
national legislation (no
national mechanism to
approve it)
 Enhancing the capacity of FIs
 Good quality EA/EMPs
World Bank
 Differences between national
and WB EA screening criteria,
environmental standards
 Meaningful public consultation
and timely public disclosure
 Improving environmental
screening
 Intensifying monitoring
 Incorporating estimated costs
of EMP mitigation measures in
sub-project cost/budget
 Timely Progress Reporting on
EMP implementation aspects
Financial Intermediary