Robert Crooks

1. Environmental and Social Assessments Robert Crooks ADFD/WB Project Preparation and Appraisal Workshop Abu Dhabi, April 2010

2. OBJECTIVES Introduction to Environmental Assessment (EA) and Social Assessment (SA) with the emphasis on EA Explain how the WB has incorporated these ideas into project preparation and management

3. Structure of presentation Two parts addressed separately: • Environmental Assessment – main motivation is to protect the institution and tends to be the most highly defined and regulated procedure • Social Assessment – more of an input to project design, much more flexible, procedures much less prescribed.

4. Environmental Assessment • What is Environmental Assessment? • Key elements or concepts of the US EIA system (the “grandfather” of all EIA systems) • How and why the WB developed its EIA system and later expanded it to a wider “environmental and social safeguards system” • How EA procedures are fitted into the WB’s project preparation and review procedures • The allocation of EA responsibilities between the WB and the project beneficiary

5. Development of the EIA Concept • Concept of EA developed in the US during the late 1960s in response to rising public pressure • EIA procedure was institutionalized as part of the National Environmental Policy Act (NEPA) of 1970 • EIA required for major federal actions having a significant potential effect on the environment • Basic objective of EIA was to “inform decision-makers” • NEPA also created a policy framework and institutional arrangements

6. Spread of the EIA Concept • Surprisingly rapid adoption of EIA concept within OECD countries (Canada, 1973, Australia, 1974, NZ 1974, etc.) WHY?? • Some countries were laggards (UK, 1988) • Most importantly, international agencies (e.g. WB) were quick to buy into the concept and this helped its spread into their client countries

7. World Bank and EIA • WB made an early start on environmental safeguards (1970) but approach limited to aspirational statements • First attempt at institutionalizing procedures was in 1984 (Operational Manual Statement (OMS) 2.36 Environmental Aspects of the Bank’s Work) • Other important donors (US, Canada, Finland, Germany) were ahead of the WB at this stage

8. World Bank and EIA (2) • Internal procedures were strengthened and made more explicit in 1989 (OD 4.00) • Controversial projects in the late 1980s and early 1990s (Brazil: Polonoreste and India: Sardar Sarova Water Resources) caused a storm of criticism • Further strengthening of EIA and other safeguards procedures in 1991 (OD 4.01 which is still largely in force today)

9. World Bank and EIA (3) • Late 1990s, WB amalgamates all its safeguards policies under the umbrella of OD 4.01 • Restructuring of OP system to distinguish between Policies, Procedures and Best Practices (OPs, BPs, and GP) • Development of the concept of a “suite of safeguards policies”

10. The 10 Safeguards Policies • OP 4.01, Environmental Assessment • OP 4.04 Natural Habitats • OP 4.09, Pest Management • OP 4.12, Involuntary Resettlement • OD 4.20 Indigenous People • OP 4.36 Forests • OP 4.37 Safety of Dams • OP 7.50 Projects on International Waterways • OP 7.60 Projects in Disputed Areas, • OPN 11.03 Cultural Property [Note there is no policy on Social Assessment]

11. Op 4.01 Environmental Assessment Objective “….to help ensure that (projects) are environmentally sound and sustainable, and thus to improve decision making”. Flexibility of process: ….the scope and form of an EA depends on the nature, scale, and potential environmental impact of the proposed project. Issues to be addressed:EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts.  

12. Op 4.01 Environmental Assessment • Responsibility for doing the EA:The borrower is responsible for carrying out the EA.   • WB’s responsibility:WB advises the borrower on the Bank's EA requirements, reviews the findings and determines whether they provide an adequate basis for processing the project for Bank financing. • Different types of EA for different situations. A range of instruments can be used to satisfy the Bank's EA requirement depending on the particulars of the project. • Environmental Screening process:The policy defines a screening process.

13. Op 4.01 Environmental Assessment Public consultation. The policy requires that, for all Category A and B projects (this used only to be required for Category A projects), the borrower consults project-affected groups and local nongovernmental organizations (NGOs) about the project's environmental aspects and takes their views into account. Disclosure. The borrower provides relevant material in a timely manner prior to consultation and in a form and language that are understandable and accessible to the groups being consulted. Implementation. During project implementation, the borrower reports on (a) compliance with measures agreed with the Bank on the basis of the findings and results of the EA, including implementation of any EMP, as set out in the project documents; (b) the status of mitigatory measures; and (c) the findings of monitoring programs.

14. WB Resources on EA

15. EIA & the Project Cycle • Considerable similarity between how these procedures are applied between both multilateral and bilateral assistance agencies (cf. the Bank procedures and those of the MCC). • For the process to have any value or meaning at all, it has to be incorporated into the project preparation (EA), implementation (Environmental Management) and completion process. • The process should be a shared responsibility between the donor agency and the beneficiary: • The donor agency is the one who has to determine whether the environmental impact is acceptable within the context of its own guidelines • The beneficiary has the responsibility for carrying out the environmental assessment • The utility of the process is greatly enhanced if the beneficiary’s EA procedures (if they exist) are followed to the extent possible.

16. EA During Project Preparation Three parts to the process during preparation of the project: • Part 1: Environmental Screening – preliminary determination of how environmentally significant a proposed project is likely to be and what level of environmental assessment should be undertaken • Part 2: Environmental Assessment – preparing the environmental analysis at a level dictated by the screening decision • Part 3: Environmental Analysis – evaluating whether the project is likely to be acceptable in terms of environmental and social impacts, whether the proposed environmental and social safeguards are likely to be adequate to avoid or mitigate likely impacts and articulating the results of that analysis in a form understandable to “decision-makers”.

17. Part 1: Environmental Screening • Most donors use a simple categorization process which is modeled on the WB process (indeed, many countries, notably China, have modeled their own EA procedures on the same scheme): • Category A: - project is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented.  These impacts may affect an area broader than the sites or facilities subject to physical works.   • Category B:- potential impacts are less adverse than those of Category A projects.  Impacts are site-specific; few if any of them are irreversible; and in most cases mitigatory measures can be designed more readily than for Category A projects.  The scopeof EA for a Category B project is narrower than that of Category A EA.   • Category C:- impacts will be minimal or non-existent. No further EA action is required for a Category C project. • Category FI: a special category for projects where WB pass through a financial intermediary before being invested in activities that have environmental impact potential.

18. How is Screening Done? • Timing: Screening decision is made as soon as possible in the project processing process which is at or about the time that the project identification document (PID) is prepared by the task manager • Process: The classification is usually done through an interactive process (i.e. a round table meeting +/- one-on-one meetings with the person making the screening decision) involving the task team and the safeguards unit • Not much participation by beneficiary: Process is internal to the WB. Beneficiary of the loan gets little say in the screening decision. • New OP (OP 4.00 Piloting the Use of Borrower Systems to Address Environmental and Social Safeguard Issues in Bank-Supported Projects) provides the promise of a less “imperialistic” approach to EA.

19. Category A Projects: the WB “Indicative List” • Large scale aquaculture and mariculture (aquaculture in the sea) • Dams and reservoirs • Forestry production projects • Hazardous waste management and disposal • Industrial plants (large-scale) and industrial estates • Irrigation, drainage, and flood control (large-scale) • Land clearance and leveling • Manufacture, transportation, and use of pesticides or other hazardous and/or toxic materials • Mineral development (including oil and gas) • New construction or major upgrading of highways or rural roads • Port and harbor development • Reclamation and new land development • Resettlement • River basin development, thermal power and hydropower development or expansion • Water supply and wastewater collection, treatment and disposal projects (large-scale) [NOTE: not all these would be subject to EIA in most developed countries]

20. Category B projects: the WB “Indicative List” Agro-industries (small-scale) Electrical transmission Energy efficiency and energy conservation Irrigation and drainage (small-scale) Protected areas and biodiversity conservation Rehabilitation or maintenance of highways or rural roads Rehabilitation or modification of existing industrial facilities (small-scale) Renewable energy (other than hydroelectric dams) Rural electrification Rural water supply and sanitation Tourism Watershed projects (management or rehabilitation)[NOTE: some of these would rank as Category A in some countries]

21. Contents of EIA for a Category A Project • Executive summary. • Policy, legal, and administrative framework.   • Project description.  Includes both the project (including necessary off-site investments required) and its environmental and social context and relevant maps/plans, as required. • Baseline data.  Describes relevant physical, biological, and socioeconomic conditions.  Also takes into account current and proposed development activities within the project area but not directly connected to the project.  • Environmental impacts.  Predicts and assesses the project's likely positive and negative impacts.  Identifies mitigation measures and any residual negative impacts that cannot be mitigated.  • Analysis of alternatives.   Systematically compares feasible alternatives to the proposed project site, technology, design, and operation--including the "without project" situation--in terms of their potential environmental impacts. • Environmental management plan (EMP).  Covers mitigation measures, monitoring, and institutional strengthening, etc. • Appendixes

22. Contents of EA for a Category B Project Almost anything – it all depends on the particular characteristics of the project and the environmental issues that it raises For a specific project investment, it might be an abbreviated EA which provides a brief project description, provides some general background on the local environment, identifies one or two key issues that need to be addressed and then uses the bulk of the document to define the environmental management and monitoring plan In the case of programmatic projects the report might focus mainly on specifying limits on what sorts of activities may or may not be included in the project (for environmental reasons) and defining the administrative and technical procedures to be adopted to environmentally evaluate sub-project proposals as they arise.

23. Environmental Analysis The findings and recommendations of the EA report and other relevant factors are put together into an evaluation of environmental risk that should be understandable to the ultimate decision-makers (in the case of the WB, that is firstly, the senior management and ultimately, the Board) This part of the process tends to be ignored in most guidelines and procedures Preferably, the evaluation of the environmental reports should be done by an operational unit that is separate from and essentially has no vested interest in whether or not the project proceeds

24. Environmental Management & Monitoring The EMP/EMMP consists of the set of mitigation, monitoring, and institutional measures to be taken during project implementation to avoid or minimize adverse environmental impacts, offset them, or reduce them to acceptable levels and specifies the management arrangements and other actions that will be taken to implement the plan and monitor its effectiveness. The form, length and complexity of the EMP/EMMP is extremely variable and is primarily influenced by the scale and significance of the expected impacts. In the WB scheme of policies and procedures, some elements of what might otherwise be include in an EMP, most notably the procedures to be followed to resettle and/or compensate adversely affected people is covered in a separate stream of documentation (the Resettlement Action Plan or RAP); For the lending institution, an important but frequently ignored corollary of the EMP/EMMP, is that some procedure needs to be adopted by the lender to periodically evaluate reports arising out of the EMMP. This is generally not done systematically and, if it is done, it is often sub-contracted to outside consultants – which is a polite way for the institution to say that it does not actually believe in the procedures that are being followed.

25. Social Assessment Two ways to look at social assessment: • as a component of Environmental Impact Assessment in which case it is more correctly referred to as Social Impact Assessment (SIA). Like EA, this is an essentially backward-looking process – the project is a given and the SIA purports to predict what the social impacts will be. • as a component of project conceptualization and design—essentially a forward-looking process. It seeks to identify the social context and either uses that as a basis for developing the project concept or, at the very least, proceeds in parallel with development of the project concept and significantly influences the design.

26. Social Issues Often Key to Project Success As development institutions move more towards small and medium scale developments and away from very large scale infrastructure developments, the importance of understanding the social context increases There are some suggestions from reviews by the WB and others that projects based on explicit attempts to understand the social context in which the project is to be developed, through techniques such as social assessment, tend to perform better in terms of outcomes A recent (2005) independent review of WB projects suggested that community-based (CBB) and community-driven (CBD) projects, which are usually strongly based on social assessments of some kind, perform better in terms of development outcomes, than non-CBB/CBD projects There are certainly plenty of examples of project failures due to a complete failure to understand the social context (e.g. Kalimantan Irrigation)

27. What does a Social Assessment Look Like Unlike EA, the scope, content and format of a social assessment for the purposes of project design is not prescribed in WB policies and procedures The scope and form of a social assessment for the purposes of project conceptualization and design depends o a wide variety of factors not least being the nature of the community involved, the types of interventions being considered, etc.;

28. Social Assessment Most SAs would include some or all of the following: • Consultations with potential project beneficiaries about the main development issues they are facing, their attitudes to development, the factors they feel are constraining their ability to improve their circumstances • Collection of relevant baseline information (both from relevant government statistics and site surveys) on the demographic, social, cultural, and political characteristics of the affected peoples, the land and territories that they have traditionally owned or customarily used or occupied, and the natural resources on which they depend. • A stakeholder assessment to identify who are the main potential stakeholders and what are the main power relations influencing their interactions with each other and identification of particularly vulnerable groups who may tend to miss out on the benefits of projects unless specific measures are included to encourage their participation • Identification of the main cultural factors governing the way in which the community functions as these may relate to the implementation of development activities • These factors are then fed into the project design to ensure that the project is relevant to local needs and likely to beneficially affect the local community

29. Some wins for Social Assessment • Social assessments done for rural development projects in China discovered a large disconnect between the views of county officials and farmers on what would be the best investments to promote local development • Kabupaten (County) Development Program in Indonesia provides a much more central role for project beneficiaries in selecting which development investments should be made, how they are designed and how they are implemented. Greater local ownership has generally improved sustainability of investments • Effectiveness of programs to reduce use of pesticides and herbicides and promote Integrated Pest Management (IPM) in Indonesia, Thailand and China was greatly improved by training farmers to train other farmers and also by taking account of social factors in designing training and dissemination plans • The effectiveness of a food crop development program in Eastern Indonesia was greatly improved after social assessment showed that it was women who were primarily responsible for food crop production. Extension program was reoriented to focus on training women rather than men.

30. Lesson Learned (1) • EA is something that was largely imposed on governments and development agencies • Initially some reluctance but the procedure has been incorporated into the project preparation process with an acceptable level of efficiency • Under some circumstances, EA can provide a development opportunity but it is often still viewed as an imposition

31. Lesson Learned (2) • Ideally EA should be more than a meaningless report-writing exercise. • Best approach is to rely on local procedures as much as possible. • Social Assessment (SA) has great potential to increase the relevance and effectiveness of project designs • SA is particularly important on Community Based and Community Driven Development projects.