4 - ~~~~~~~~September 1999 4- :,,'-'..''..'.'.,.'''4.SSt''.',-' ' ' s n 0 ~~Reve of theS Effectivenes i s of P~~~~~~~~~raa R;v < -. , Eniom naiAssm nsi L L, _.t,, . ,, r F,| I f"'~~- i '"' -', E l e ~~ t _ -.,A4IF krl .~~~~~~~~~~~~~ .~z - ______________ INDI)1A Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects Fiscal 1990-97 Environment Sector Management Unit South Asia Region The World Bank © 1999 The International Bank for Reconstruction and Development / THE WORLD BANK 1818 H Street, N.W Washington, D.C. 20433, U.S.A. All rights reserved Manufactured in the United States of America First printing September 1999 This report has been prepared by the staff of the World Bank. The judgments expressed do not necessar- ily reflect the views of the Board of Executive Directors or of the governments they represent. The material in this publication is copyrighted. The World Bank encourages dissemination of its work and will normally grant permission promptly Permission to photocopy items for internal or personal use, for the internal or personal use of specific clients, or for educational classroom use, is granted by the World Bank, provided that the appropriate fee is paid directly to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, U.S.A., telephone 978-750-8400, fax 978-750-4470. Please contact the Copyright Clearance Center before photo- copying items. For permission to reprint individual articles or chapters, please fax your request with complete informa- tion to the Republication Department, Copyright Clearance Center, fax 978-750-4470. All other queries on rights and licenses should be addressed to the World Bank at the address above or faxed to 202-522-2422. Cover design by Elizabeth McNulty, Auras Design. Contents Acronyms and abbreviations v Acknowledgments vi Executive summary 1 1. Background to this review 5 Instituting environmental assessment 5 Scope and limitations of the review 6 Review methodology, structure and audience 6 2. Developing a review framework 8 3. Evaluating for quality 11 Review procedure to evaluate the quality of environmental assessment Overall observation of project-specific EAs 12 Identification of issues and scoping 12 Baseline conditions 13 Analysis of alternatives 13 Prediction and assessment of impacts 14 Mitigation measures 14 Public involvement and consultation 15 Monitoring plans/institutional aspects 17 Environmental covenants in legal documents 17 Environmental supervision 18 Summary of the review of sectoral EAs 19 4. Addressing special issues 20 Sectoral and regional environmental assessments 20 Project screening criteria 20 Guidelines for category-B projects 21 Review criteria 21 Integration of environmental assessment and social analysis 21 Mitigation measures and environmental assessment 21 Nontechnical summary for effective public consultation 23 Need for coherence between EA process and EIA systems 23 Financial intermediary lending 24 Iv India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 5. Conclusions and recommendations 25 How to improve the effectiveness of EA in project design ? 25 How to improve the effectiveness of EA in project implementation? 26 Next Steps 27 Annexes 1 Comparison of World Bank's OD 4.01 and Government of India's EIA notification 28 2 Categories of projects requiring environmental analysis 31 3 List of World Bank-financed projects by environmental assessment category 34 4 PasL studies on effectiveness of environmental assessments 36 5 Project information matrix 40 Bibliography 54 Boxes 3.1 Influence of public consultation on design of Second Madras Water Supply Project 15 3.2 Examples of specific and generic environmental and social legal covenants 17 Figure 1.1 Categorical distribution of projects supported by the World Bank in India, FY 90-97 6 Tables 2.1 Rules for assessing the EAs of category A- and B-projects 9 3.1 List of selected projects by sector 11 3.2 Summary of EA ratings for category A and B projects 12 3.3 Summary of attribute ratings assigned to all category A- and B-projects reviewed 13 3.4 Supervision ratings on compliance of environmental mitigation plans as reported in Form 590 during FY90-97 16 4.1 Checklist of review questions 22 Acronyms and abbreviations CAC Citizens Advisory Committee CIBA Central Institute of Brackish Water Aquaculture EA Environmental assessment EAP Environment action plan EIA Environment impact assessment EMP Environmental management plans Fl Financial intermediary GOI Government of India IDA International Development Association IPDP Indigenous people development plan IL&FS Infrastructure Leasing and Financial Services Limited IPCL Indian Petroleum Corporation Limited MCGM Municipal Corporation of Greater Mumbai MOEF Ministry of Environment and Forests, Government of India NEERI National Environmental Engineering Research Institute NGO Nongovernmental organizations NTPC National Thermal Power Corporation NTS Nontechnical summary OED Operations Evaluation Department, The World Bank ONGC Oil and Natural Gas Commission R&R Resettlement and rehabilitation SASEN South Asia Environment Unit of the World Bank TOR Terms of reference v Acknowledgments This review was prepared by L. Panneer Selvam, Michael Whitbread, Walter Vergara, J.R. Malhotra, N. Environment Officer, South Asia Environment Unit K. Bandyopadhyay, Geoffrey Spencer, Tawhid Nawaz (SASEN); Sonia Kapoor, Environmental Engineer, and Raj Kumar. In addition, the review team would SASEN; Prasad Modak, Director, Environment also like to thank P Illangovan and Robert Robelus for Management Centre, Mumbai; and Radha Gopalan, sharing their experiences and offering constructive Scientist, Environment Management Centre, Mumbai suggestions during the initial stages of this review; The review was initiated by the Department and to Carter Brandon and Richard Ackermann, Management Team and Richard Cambridge, Principal Sector Manager of SASEN, who provided invaluable Operations Officer, Environment, India Country strategic guidance to the issues discussed in this Department. The encouragement provided by David review and implemented by the environment unit. Marsden, Chief, Social Development Unit, and other Sheldon Lippman edited the final document. colleagues is acknowledged. The review team wishes to recognize the construc- This review has benefited from the cooperation of tive contribution by the entire staff of Environment numerous Bank staff in the New Delhi and Management Center, Mumbai, with a special mention Washington, DC and task managers and various oth- for Arvind Nema who contributed greatly towards the ers working in the environment assessment project analysis of the quality of Environmental Assessment. cycle. They have contributed by gathering data and We are very grateful to Sarah Brijnath and Padma offering constructive comments: Among these Gopalan, Social Development Unit, for their invaluable include Shyamal Sarkar, Tjaarda Storm Van Leeuwen, help and efforts in presenting this Report. vI Executive summary The World Bank's lending portfolio in India has grown The weakest areas identified for category-A projects recently and is expected to reach an annual level of were identification of issues and scoping, analysis of alter- about US$3 billion over the next few years. The World natives, prediction and assessment of impacts, and public Bank and the Government of India (GOI) are keen to involvement and consultation. For category-B projects, ensure that social development and environmental the analysis of alternatives and prediction and assessment concerns are fully reflected in this growth process. The of impacts were found to be weak. Finally, compliance main objectives of this document are to: with EAs during project implementation was found to * review the effectiveness of the environmental assess- be weak. ment (EA) in Bank-assisted projects in India between Sectoral EAs have been carried out in only three pro- fiscal years 1990 to 1997, jects in India. These are the Water Resources * identify areas requiring further attention, and Consolidation projects in the States of Haryana, Tamil * make recommendations to improve the EA effec- Nadu, and Orissa. A detailed review of these projects tiveness. could not be carried out because of the unavailability of This is a desk review of 14 projects from the India full EA reports of Haryana and Tamil Nadu. The weak portfolio based pnmarily on available EA, staff areas were found to be the same as in category-A pro- appraisal, supervision, and implementation completion jects. This could be because the sectoral EAs require a reports, and environmental data sheets. Discussions higher level of expertise as they have to focus more on were held with task managers, supervision staff, and rel- systemic alternatLives, policy analysis, linkages with evant Indian government officials and consultants. other sectors, and institutional arrangements None of these reports seem to have included process guidelines stating the sub-project eligibility or appraisal criteria, or Overall observations link between the sectoral, and project specific EAs. This is an important element of a sectoral EA as it lays down The quality of most reviewed EA reports was found to the framework to implement its recommendations. be 'satisfactory'. Two projects, Bombay Sewage Disposal and Vadodara-Halol Road Widening, top the list having benefited from intensive supervision and professional Effectiveness of EA in project preparation guidance from staff of the South Asia Environment Unit (SASEN). Overall EA quality has been steadily improv- Identification of issues and scoping was observed to be ing in India. Projects prepared in the years 1996 and one of the weak areas in EA preparation. This step is 1997 were much better than those prepared in the years important to focus the EA on priority environmental 1991 and 1992. This is an encouraging trend, which and cost-effectiveness issues. Often voluminous data could be due to gradual building of capacity in EA of direct relevance to the project are collected in an preparation among the project implementing agencies effort to comply with lengthy requirements of the GOI and local consultants as per World Bank guidelines and Ministry of Environment and Forests (MOEF). The close Bank supervision. MOEF requires elaborate questionnaires that give 2 India Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 more emphasis on collection of background data and peoples were integrated as part of the project design do not orient them to identify and prioritize the envi- to mitigate any adverse environmental impacts. ronmental issues arising from the project activities. However, it was also observed that the public consul- Description of baseline conditions was found to be the tations or involvement rarely continue beyond the strongest aspect in all but one of the projects reviewed, project preparation stage. This is because the EA consultants are most familiar Monitoring plans and institutional aspects were includ- with the MOEF requirements to collect exhaustive ed for most of the EAs covering all major mitigation ambient environmental quality and meteorological measures and an institutional framework to aid imple- data. However the question that still remains is, how mentation. For an 'excellent' rating, EAs would have to much of these data are useful (or actually used) and address all issues arising out of the environmental and cost effective for EA? social analysis and recommend an audit framework for Analysis of alternatives, despite the emphasis given in post-project monitoring. Rarely do EA reports cover all the Bank Operational Directive (OD) 4.01, was observed these aspects. to be one of the weakest elements of most of the EAs. Often only an analysis of 'with project' and 'without pro- ject' scenarios was carried out. One of the reasons for not Effectiveness of EA in project implementation exploring different altematives is the failure to initiate the EA at the earliest stage of project design, before the Environmental covenants in legal documents including crucial aspects (location, size, or technology) are decid- loan, credit and grant agreements, bidding documents, ed. As a result, EAs focus only on mitigation measures and related contracts provide much of the framework to defend the decisions already taken. to support and enforce supervision. It is therefore crit- Prediction and assessment of impacts using appropri- ical that such documents adequately reflect the project ate quantitative analytical tools, such as mathematical environmental requirements and specific mitigation water/air quality models or Geographical Information measures recommended by the EA process. Most of the Systems, have been carried out in only a few projects. projects reviewed have legal covenants which cover the Air quality modeling is one of the well-established development and/or implementation of Environmental tools for prediction and decision making. However in Management Plans (EMP). However the references are many cases these have not been used satisfactorily for usually generic in nature; and in more than 50 percent optimizing stack heights and air pollution control of the projects reviewed there was no clear relationship equipment. between the EMP/Rehabilitation Action Plans (RAP) Development of mitigation measures were found to be and the social/environmental legal covenants. 'above satisfactory' in all EAs except one. However none Environmental supervision was found to be inade- of the reports have recommended mitigation measures quate in several of the projects reviewed. This review for eliminating all major and mnor impacts. In most analyzed the data reported by the task managers in cases the identified mitigation measures have not been Form 5901 for information on the status of compliance costed and integrated with the project. Several of the EAs of environmental aspects and participation of environ- have failed to recognize the residual or induced impacts mental staff in supervision missions. In seven out of such as the treatment and secured disposal of chemical nine category-A projects, environmental specialists sludge from wastewater- and water-treatment plants. participated in less than 50 percent supervision mis- Public involvement/consultation under OD 4.01 sions. In case of category-B projects, environmental clearly states that EAs must be prepared ensuring max- specialists rarely (less than 20 percent of missions) par- imum participation of and consultations with the ticipated in supervision missions. In addition, Form affected peoples and nongovernmental organizations 590 does not necessarily reveal the ground realities or (NGO), especially after the EA category has been the actual status of EMP compliance. For example, assigned and when the draft EA has been prepared. eight consecutive supervision missions of the Shrimp There are few instances where the views of affected and Fish Culture project have been rating the project Executive summary 3 'satisfactory' for environment even when site-specific are differences in the requirements, approach and con- EMPs have not been designed until now. tent. Discussions during this review with MOEF offi- cials and the Bank staff confirm that there is a strong demand for a systematic program of educating and Special issues informing various interest groups of the requirements OD 4.01 and the EIA notification. Sectoral and regional environmental assessments, while limited in India, have considerable relevance to India where a large number of State-level projects are in the Conclusions and recommendations proposed fiscal 1998-2000 lending program. Conse- quently, opportunities to address environmental issues The quality of EA reports in India has been steadily at planning, programmatic, and policy level are not improving. But two major challenges are how to employed to achieve long-term sustainable solutions. improve the EA effectiveness in influencing the project Project screening criteria should not be based solely design, and how to improve EA compliance during on the project type, but primarily on field data. project implementation. Based on the findings of this Guidelines for category-B projects should be devel- review, the following key recommendations to address oped and followed during the project preparation and these challenges are proposed for the management's implementation stages. review and concurrence. Nontechnical summary (NTS) is an essential tool for How to improve the effectiveness of EA in project communicating EA findings and its absence reduces design? the opportunity for better communication with stake- * Introduce a sectoral and regional EA approach to holders. The recent amendment to the environmental improve the timing of the EA process. impact assessment (EIA) notification of the Govern- * Strengthen the early steps of issues identification ment of India (April 1997) also requires a public hear- and EA scoping to better focus EA activities. ing to be conducted. At present OD 4.01 does not * Reinforce environmental perspectives in the analy- require an NTS, but does require public consultations. sis of investment alternatives. It will be a good contribution therefore for the Bank to * Make the public consultation process inluential in formally require and provide specific guidance for a the project design and mitigation strategy NTS as result of the EA exercise. * Prepare review critena to ensure consistency and Financial intermediary (FI) lending by the Bank to pro- quality of EA reports. mote private sector development in India is increasing * Prepare follow-up training on key issues raised by According to OD 4.01, the Bank should appraise and EAs. strengthen, where necessary, the environmental capabili- How to improve the effectiveness of EA in project imple- ties of the Fl to ensure that they carry out appropriate envi- mentation? ronmental analysis of all sub-projects in a manner consis- * Ensure compliance of EMP through adequate envi- tent with Bank policy Among the projects reviewed, it is ronmental supervision by (a) including environmental evident that two different approaches are followed. One performance indicators in legal documents; (b) prepar- being the establishment and strengthening of social and ing a separate detailed supervision note on environ- environmental capacity within the Fl by preparing an mental components; and (c) strengthening the field environmental and social report that responds to both office capacity to assume more field-based environ- GOI and Bank requirements and regulations. The second mental supervision. approach being the reliance of the Bank on the existing * Strengthen EA capacity in the project implementing capacity of the Fl to provide the environmental and social agencies to reduce the communication gaps and to clearances for each sub-project to be financed. improve the quality of EA reports by (a) organizing sec- Capacity building. A comparison of the Bank's OD tor-specific meetings among the staff of the Bank, GOI, 4.01 and MOEF EIA system (Annex 2) shows that there and project implementing agencies, similar to those 4 India: Review of the Effectiveness of Environmental Assessments in World Bank-AssisLed Projects, Fiscal 1990-97 done in the highways sector, to discuss the environ- * develop a management information system to mon- mental and social issues, and (b) identifying and orga- itor the compliance of agreed environmental actions of nizing regular training programs and seminars in part- all category A- and B-projects. nership with other donors. * expand training of Indian officials and EA practi- tioners in best practice lessons learned around the world on such topics as: early scoping; analysis of alter- Next steps natives; increasing the decentralization of responsibil- ities to state and local levels; and strengthened public This review was a modest beginning to understand the consultation requirements. effectiveness of EA in Bank-assisted projects in India. The following actions are envisaged as next steps to N continue this task: * initiate a follow-up study including field visits and 1. Form 590 is the project supervision status reporting format. This report is completed by Bank task mangers following pro- post-implementation review to fully assess the effec- ject supervision missions. Environmental ratings are generally tiveness of the EA and integration of environmental assigned by comparing actual performance to the onginal and social assessments in Bank-assisted projects in objectives and parameters at appraisal, according to the scales India. described in OD 4.01. 1. Background to this review Instituting environmental assessment which require EIA with a minimum investment level of 50 crores (500 million Rupees or US$12.5 million). The World Bank adopted Operational Directive (OD) Such an approach excludes some types of invest- 4.00 (Annex 1) in 1989 to use environmental assess- ments with environmental impacts. Among those ment (EA) as a tool to improve the concept, design, excluded for example may be water supply and implementation, and monitoring of all investment pro- wastewater management projects including munici- jects from an environmental and social perspective. pal wastewater treatment and disposal, and common The OD 4.00 (Annex 1) was subsequently amended as effluent treatment plants which are often part of OD 4.01 in 1991 to expand its scope and provide more Bank-supported projects. The other differences are in clarity in the screening and implementation process 1 the analysis of alternatives and carrying out social The Government of India (GOI) notified the rules for assessments which are both strongly recommended Environmental Impact Assessment2 (EIA) of develop- by the Bank as part of the EA process but emphasized ment projects in 1994 under its Environment to a lesser degree by GOI. Protection Act of 1986. Between fiscal 1990 and 1997, 83 projects were The main objectives of the Bank's OD 4.01 and GOI financed by the Bank in India which were subject to EIA notification are to prevent, minimize, mitigate, or the EA process.3 A categorical distribution of these pro- compensate for the adverse environmental impacts of jects is shown in Figure 1.1. A list of these projects is development projects. A comparison of the two is given in Annex 3. given in Annex 1. All Bank-assisted projects are After seven years of experience in applying the EA screened at the identification stage for environmental process in India, the results of its practical application impacts and assigned to one of three categories: A, B, are mixed. In the National Thermal Power Corporation or C. GOI in its EIA notification lists 29 developmen- (NTPC) power generation project, a detailed environ- tal projects which require environmental clearance, mental and social assessment for the expansion of depending on the order of financial investments. A Rihand and Vindhyachal power stations was carned comparative description of categories of projects out. Still, however, a request for inspection has been requiring environmental analysis, as per the Bank's made by a local nongovernmental organization (NGO) OD 4.01 and the GOI EIA notification, is given in claiming violation of five operational directives and Annex 2. A summary of typical environmental issues policies, including OD 4.01 on environmental assess- of category A- and B-projects are also included in ment.4 The Shrimp and Fish Culture project, five years Annex 2. after effectiveness, remains to develop site-specific A comparison of Bank's OD 4.01 with GOI EIA Environmental Management Plans (EMP). On the other notification reveal the following key areas of differ- hand, there are some stand-outs, such as the State ence. The Bank's screening criteria include an illus- Health Systems Development project which is rated cat- trative list of projects which offers more flexibility in egory C. It is being supervised as a category-B project categorization and type of EA required. The GOI cri- because it deals with the management and disposal of teria are more rigid and specify 29 types of projects medical waste. During the course of initial supervision, 5 6 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 Figure 1.1 Categorical distribution of projects tion (R&R) issues which are to be the subject of a sep- supported by the World Bank in India, FY90-97 arate review over the coming months. A limited exam- ination of social issues as delineated in OD 4.01 was 16(19' / carried out. A iII Due to limited time and resources, this review did not include field visits.5 Detailed examination was lim- 34 (41%) ited to a selected sample of fourteen projects, carefully C drawn from the India portfolio to represent the various 28 (34%) types of Bank-assisted projects in India. It is recom- B mended that this review be followed by further work including field visits and post-implementation review to fully assess the effectiveness of the EA process. the controversy around installation of incinerators for disposing of medical waste was highlighted. Review methodology, structure and audience The review methodology consisted of the following Scope and limitations of the review four major steps: 1. review of previous studies on the effectiveness of EA This review was initiated in November 1996 to focus by the World Bank, national, and international agen- on the identification of the substantive environmental cies; issues addressed by category A- and B-projects, the 2. development of a conceptual framework for review- quality of EA (using full reports, when available, or ing the effectiveness of EA in representative Bank- summaries) and EMPs. It is expected that the lessons assisted projects; learned from this analysis of the EA process for projects 3. review of EA experiences of the selected projects; under implementation would be useful when applied and to the growing number of category A- and B-projects 4. drawing conclusions and making recommendations. which will enter the portfolio over the next few years. Chapter 1 of the report introduces the Bank's OD The main objectives of this review are to: 4.01 and GOI requirements for EIA of developmental * review the EA effectiveness in Bank-assisted projects projects, along with background discussions within in India (fiscal 1990 to 1997); the India Country Department, that led to the initia- * identify areas requiring further attention; and tion of this review Chapter 2 develops and analyzes the * make recommendations to improve the EA effec- quality review framework for effectiveness of EA. tiveness. Chapter 3 focuses on the quality of EA and analyzes the This is a desk review based primarily on staff influence of EA on project design and implementation appraisal, supervision, and implementation comple- of the selected projects. Chapter 4 highlights special tion reports where applicable, and environmental data issues arising from the lessons learned from the review sheets where available. Discussions with task man- that need further study Chapter 5 recommends agers, supervision staff, and relevant Indian govern- approaches for better management of environmental ment officials and consultants, were held. And the issues both by the Bank as well as the borrower. extent of compliance with the procedures laid down in This review is intended for Bank's regional and sec- the OD 4.01 could not be independently verified toral managers and staff. It is also aimed at GOI staff through interviews with the borrowers, consultants, as responsible for project design and implementation, well as project-affected groups. consultants, NGOs, and other staff involved in devel- This review was focused on OD 4.01 and no specif- oping and implementing public consultation and par- ic attention was given to resettlement and rehabilita- ticipation strategies. Background to this review 7 Notes 2. World Bank uses the term Environmental Assessment (EA); Gov- ernment of India uses Environmental Impact Assessment (EIA). 1. EA as defined by OD 4.01 is a flexible procedure which should 3 Out of 83, three projects belong to category D Category D vary in breadth, depth, and type of analysis depending on the pro- has been eliminated from the environmental screening in OD ject It maybe performed at one point in time or in discretestages 4 01. Two projects still show "category to be determined" and EA Is carned out during project preparation, before appraisal, and hence do not fall into categories A, B or C Thus the total of A, is closely linked to the feasibility study EA covers project specific B and C projects totals to 78 rather than 83 and other environmental impacts in the area of influence of a pro- 4. The other operational directives claimed to be violated were ject. The purpose of EA is to improve decision making and to on involuntary resettlement (OD 4.30), indigenous peoples ensure that the project options under consideration are environ- (OD 4.20), economic evaluation of investment operations (OP mentally sound and sustainable. All environmental consequences 10 04) and project supervision (OD 13.05). should be recognized early in the project cycle and taken into 5. This review was carried out in a period of seven months with account in project selection, siting, planning and design. a total budget of about US$25,000 2. Developing a review framework The term 'review' is used in a variety of different ways For sectoral EAs, two additional attributes were in EA literature. This review assesses the EA quality and included: coverage of policy, legal and administrative effectiveness of the 14 selected projects. In order to framework; and project description. ensure a comprehensive and fair review, a well-defined The second step in the review framework was to review framework was developed by analyzing the develop rules for assigning appropriate ratings to each review criteria used in some of the past studies on EA attribute: 'inadequate,' 'satisfactory,' or 'excellent'.1 effectiveness. The rules developed for the evaluation of each Evaluating the effectiveness of the EA process in attribute for project category A and B are given in decision making and ensuring sustainable develop- Table 2.1. While the same attributes have been used ment has been the focus of a number of studies and for category A- and B-projects, a different set of rules fora globally As part of this review, several studies car- were used for assigning the ratings. This is because in ried out by the Bank and other national and interna- the case of category-B projects, a full EA is not tional agencies were reviewed mainly for their key find- required and a partial environmental analysis, limited ings and criteria used in evaluating EA effectiveness. to the particular environmental issues of the project, Main findings emerging from the analysis are given in is sufficient.2 Annex 4 along with a list of the studies reviewed. In order to provide an overall quality rating for each The main focus of the Bank-initiated studies has EA report, a relative scoring or numerical value was been on the compliance with OD 4.01 on environ- assigned to each of the ratings. A sliding scale of scores mental assessment and OD 4.30 on involuntary reset- of 10, 6, and 3 was applied for ratings 'excellent,' 'sat- tlement; and on whether EMPs have been prepared and isfactory' and 'inadequate', respectively. For each pro- included in the project design. Analysis and findings ject these scores were aggregated to assess the overall emerging from these are also given in Annex 4. quality rating and could vary from 21 to 70 as a total The first step in developing the review framework of seven review attributes. was to identify a list of key attributes based on the expec- tations laid down in OD 4.01. Seven key attnbutes were used for reviewing the project-specific EAs: Notes 1. identification of issues and scoping, 1. Each attnbute is rated independently of one another. Thus, 2. baseline conditions, if an EA receives a rating of 'inadequate' for the attnbute 'iden- 3 analysis of alternatives, tification of issues', the attribute 'mitigation' can receive a 'sat- 4. prediction and assessment of impacts, isfactory' rating if, at least for the issues identified, appropnate '. mitigtion easurs,mitigations have been developed. 5. mitigation measures, 2. The OD 4.01 states that for category B projects "although a 6. public involvement and consultation, and full EA is not required, environmental analysis is required' and 7. monitoring plans and institutional aspects. "mitigations plans alone suffice 8 Developing a reviewframework 9 Table 2.1 Rules for assessing the EAs of category A- and B-projects Attoibute Category-A Rules Category-B Rules a) Identification of issues and scoping Inadequate: Even if one major issue is not Inadequate: Even if one major issue is Major issues are those which (a) have a high covered, although all minor issues have been not covered, although all minor issues order of severity (which capture the intensity covered Even if all major issues are covered, have been covered Even if all major of the project activity and the fragility of the but no scoping and pnontization has been done issues are covered, but no scoping and impacted environmental component), (b) Satisfactory: All major issues have been pnontization of issues has becn done have large spatial extent (area wide/regional covered. Scoping and pnontization of issues Satisfactory: All major issues have impact) and (c) last for long period & has been done been covered. Scoping and irreversible Rest of the issues are termed Excellent: All major and minor issues covered priontization of issues has been done as minor. and scoping and prioritization has been done Excellent: All major and minor issuCs covered and Scoping and priontization has been done. b) Baseline conditions Inadequate: Existing conditions are not Inadequate: ExIsLing conditions are not Baseline conditions cover existLing status of all adequately described (i e , baseline data is adequately described (I e , baseline data environmental components likely to be incomplete). Details not relevant to project is incomplete). Details not relevant lo impacted and environmental setting have been reported. project and environmental setting Satisfactory: ExIsting condLitons are adequately have been reported described Satisfactory: Fxistinig conditions Excellent: Existing conditions are adequately described adequately based on a described as above but in addition interlinkages reconnaissance survey between environmental and social settings have Excellent: Existing conditions are been identified which assist in the prediction adequately described as above but in and assessment of impacts addition some environmental monitoring activity has been done to define the baseline conditions in detail where an issue of significance has been identified. c) Analysis of alternatives Inadequate: No true alternatives examined Inadequate: No true alternatives Alternatives to be covered include those for Satisfactory: Alternatives have been examined examined proposed design, site, technology & but there is no influence on the project design Satisfactory Altcrnatives have been operational alternatives in terms of their Excellent: Alternatives have been examined examined but there is no influence potential env. impacts, capital and recurrent which lead to better project identification in on the project design costs, suitability under local conditions; and terms of cost-effectiveness, env compatibility Excellent: Alternatives have been institutional, training and monitonng and explore opportunities for environmental examined which lead to better project requirements. enhancements identification in terms of cost- effectiveness and environmental compatibility d) Prediction and assessment Inadequate: Predictions are done on an ad-hoc Inadequate: PredctLions are not done basis Predictions limit only to assessment of Satisfactory: PredictLions are ad-hoc present situation, but no actual predictions and limited only to an assessment of the have been performed Tools used (e.g. present situation, but no actual mathematical model, valuation techniques) for predictions have been performed assessment and prediction are inappropriate. Excellent: Predictions have been done Satisfactory: Predictions have been done on on quasi-quantitative basis with a stress quasi-quantLitatLive basis. Tools used for on quantitative tools as much as prediction and assessment are appropriate possible Excellent: Predictions have been done on a quasi-quantitative basis with a stress on quantitative tools as much as possible. Advanced presentation and interpretation techniques have been used (such as the Geographical Information Systems), to improve the level of assessment. Tools used for prediction and assessment are appropriate A sensitivity analysis has been done and certainty around the predictions has been stated. Model limitations are also well stated 10 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 Table 2.1 continued Attribute Category-A Rules Category-B Rules e) Mitigation measures Inadequate: Mitigation measures have Inadequate: Mitigation measures have Identification of feasible and cost effective not been proposed even for a single not been proposed even for a single measures that may reduce potentially major impact major issue. significant adverse environmental impacts Satisfactory: Mitigation measures have been Satisfactory: Mitigation measures have to acceptable levels, and estimation of the proposed for all major impact. Rationale for been proposed for all major issues potential environmental impacts; capital the mitigation measures is given. Techno- Rationale for the mitigation measures and recurrent costs; and institutional, economic feasibility including social acceptance is given. Techno-economic feasibility traintng and monitoring requirements of for the proposed mitigation measures has been including social acceptance for the those measures analyzed. proposed mitigation measures has been Excellent: Mitigation measures have been analyzed proposed to "nullify" or eliminate all major as Excellent: Mitigation measures have well as minor impacts An institutional plan has been proposed to "nullify" or eliminate been drawn allocating the responsibilities of all major as well as minor impacts. implementing the mitigation measures. Mitigation measures are integrated with project implementation plan. Side-effects or negative impacts of the mitigation measures themselves have been adequately recognized and understood. Mitigation measures include preparedness (e.g risks due to tank farms in a chemical factory) for uncertain impacts. More detailed studies are suggested for impacts not fully understood f) Public involvement/ consultation Inadequate: Totally missing or done after the Satisfactory: Done but has not been The section on Environmental Analysis in project design is frozen. carried out systematically The OD 4.01 does not make a specific request Satisfactory: Done but has not been carmed out outcomes of the consultation however for Public Consultation/Involvement for systematically The outcomes of the find some place m the project design category-B projects consultation however find some place in the and/or compensation strategy. project design and/or compensation strategy. Excellent: Done with ngor and the Excellent: Done with rigor and the nght spirit, right spint, right upfront, influencing upfront, influencing project concept, project concept, alternatives, assessment alternatives, assessment of impacts, mitigation of impacts, mitigation strategy etc. strategy etc , throughout the Project Cycle, leading to an acceptable project design. leading to an acceptable project design. g) Monitoring plan and institutional Inadequate: Monitoring plan is poorly Inadequate: Monitonng plan is poorly aspects formulated or is not suggested. Institutional formulated or is not suggested. General guidelines for long-term sector aspects are not looked into Institutional framework is not wide environmental monitoring to ensure Satisfactory: Monitonng plan is suggested developed. adequate implementation of investments. addressing all the major issues. Institutional Satisfactory: Monitoring plan is Should use findings of the baseline data aspects have been looked into. Costs have been suggested addressing all the major section as a basis to measure progress in estimated and accounted issues Institutional framework has been mid-term review and final evaluation. Excellent: Monitoring plan is suggested developed. addressing all the major issues, including those Excellent: Monitoring plan is suggested arising out of SA addresses monitoring needs for addressing all the major issues, post project monitoring / audit framework; including those arising out of SA Institutional framework shows public addresses monitoring needs for post involvement. Costs have been estimated and project monitonng. accounted. 3. Evaluating for quality For this EA review, a representative sample of 14 pro- social impacts, key EMP and legal covenants is given jects were selected for detailed analysis. The following in Annex 5. criteria were applied to select these 14 projects from a list of 83 projects (of which 16 are category-A and 28 are category-B projects) financed by the Bank between Review procedure to evaluate the quality of July 1990 and June 1997 in India: environmental assessment * a mix of category A- and B-projects with an empha- sis on category-A projects; The review framework outlined in Chapter 2 was * coverage of key sectors such as infrastructure, rural employed to evaluate the quality of EA reports. For development (water resources), energy, industry/pri- objectivity and consistency, EA reports were inde- vate sector development, and health; pendently reviewed by five professionals who are * projects that involve sectoral and project specific familiar with the requirements of OD 4.01. This was EA; and followed by a joint review to reconcile differences in * projects that use financial intermediaries. the judgments. This process also helped in refining The sectoral distribution of the 14 projects is shown the review criteria, especially the rules for evaluation. in Table 3.1. A brief project description along with its Each of the reviewers independently followed a objectives, major components, key environmental and sequential procedure: Table 3.1 List of selected projects by sector Projects Category Sector 1. Bombay Sewage Disposal Project A Infrastructure 2. Private Infrastructure & Finance (IL&FS) Project A 3. Second Madras Water Supply Project A 4 Haryana Water Resources Consolidation Projecta A Rural Development 5. Orissa Water Resources Consolidation Project A (Water Resources) 6. Tamil Nadu Water Resources Consolidation Projecta A 7. Assam Rural Infrastructure and Agricultural Services Project B 8. Bihar Plateau Development B 9. Shrimp and Fish Culture Project Project B 10. Gas Flaring Reduction Projecta A Energy 11. NTPC Power Generation Project (Rihand II and Vindhyachal 11) A 12 Industnal Pollution Prevention Project B Industry 13. Second Petrochemicals Development Project A 14. State Health Systems Development Project l1b C Health a.Due to unavailability of full EA reports, only the EA summary and SARs of these projects were reviewed Therefore, detailed review and comparative evaluation of these three projects could not be made b. In view of the adverse environmental impacts that may anse as a result of medical waste disposal, this project, although category C, is being super- vised as category B and future projects of similar nature will also be categorized as B 11 12 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 - The EA report together with other related documents It clearly emerges from Table 3.2 that the overall EA such as staff appraisal reports and supervision mission quality has been steadily improving in India during the reports were evaluated for each attribute and assigned a past six years. The projects that were prepared from rating of either 'inadequate', 'satisfactory', or 'excellent'. 1996 to 1997 were the best compared to the unsatis- * When the above review and evaluation sheets were factory ones prepared in 1991 to 1992. This is an complete, the reviewers met to compare findings. encouraging trend which could be due to two main When differences in the evaluation occurred, the reasons. One is the gradual building of capacity among reviewers jointly re-examined and reconciled their borrowers and local consultants in EA preparation as findings. per the Bank guidelines. And other reasons are improved skill of and closer supervision by Bank staff. A summary of attribute ratings assigned to all cate- Overall observation of project-specific EAs gory A- and B-projects reviewed is given in Table 3.3. This table highlights the strengths and weaknesses of An overall project score of the EA reports reviewed is the projects reviewed. Description of baseline condi- presented in Table 3.2. These overall scores are com- tions and development of mitigation measures puted as the sum of individual ratings and scores emerged as the strong areas of EAs reviewed. assigned to each attnbute by applying the rules The weakest areas identified for category-A projects explained in Chapter 2.' were identification of issues and scoping, analysis of The quality of most of the EA reports reviewed is alternatives, prediction and assessment of impacts, and found to be 'satisfactory' with an overall quality rating public involvement and consultation. Limited to the of 42 or above, calculated by multiplication of 7 (num- EA reports reviewed, the analysis of alternatives and ber of attributes) by 6 (score for rating as satisfactory). prediction and assessment of impacts were found to be Two projects, Bombay Sewage Disposal and Vadodara- weak in category-B projects. Halol Road Widening, a subproject of the Private Infrastructure Finance Project, top the list. These two projects had the benefit of intensive supervision and Identification of issues and scoping professional guidance from staff members of the Asia Technical Environment and Natural Resources Key observations on the Bank's experience in India Division (ASTEN), now reorganized as South Asia with respect to each attribute and a few other key Environment Sector Management Unit (SASEN). issues related to effective implementation of EAs Table 3.2 Summary of EA ratings for category A- and B-projects Project Overall score Year of preparation Category-A projects Pnvate Infrastructure Finance (IL&FS) Project 66 1997 Bombay Sewage Disposal Manne Outfalls 65 1996 Aerated Lagoons 63 Second Madras Water Supply 52 1996 NTPC Power Generation (Rihand & Vindhyachal) 51 1994 Second Petrochemicals Dev. Vadodara 34 1991 Nagothane 25 Category-B projects Assam Rural Infrastructure and Agncultural Services 45 1995 Bihar Plateau Development 43 1993 Shnmp and Fish Culture 30 1992 Evaluatingfor quality 13 Table 3.3 Summary of attribute ratings assigned to all category A- and B-projects reviewed No. of EAs with ratings Attributes less than satisfactory equal to/or above satisfactory Category-A projects 1, Identification of issues and scoping 3 4 2 Baseline conditions None 7 3. Analysis of alternatives 3 4 4 Prediction and assessment of impacts 3 4 5. Mitigation measures 1 6 6 Public involvement and consultation 2 5 7. Monitonng plans/institutional aspects 1 6 Category-B projects 1 Identification of issues and scoping 1 2 2. Baseline conditions 1 2 3. Analysis of alternatives 3 None 4 Prediction and assessment of impacts 2 1 5. Mitigation measures None 3 6 Public involvement and consultation None 3 7 Monitoring plans/institutional aspects 1 2 should be noted. Rarely are issues prioritized to lend understanding of issues and better implementation of a focus as well as cost-effectiveness to the EA study mitigation plans Often voluminous data collected are not directly rele- vant to the project. This may be because many EA con- sultants in India are familiar with complying with the Baseline conditions Ministry of Environment and Forests (MOEF) com- plex questionnaires. Baseline conditions were found to be the strongest These required questionnaires give more emphasis aspects in all but one of the category A- and B-pro- on collecting a wide array of background data. This jects reviewed. (The only exception was the EA report requirement is not oriented to identifying and prion- for Shrimp and Fish Culture Project which did not tizing the environmental issues arising from the project contain adequate baseline data on the proposed fish- activities. For example, the Second Petrochemical eries components in the States of Bihar and Uttar Development (Nagothane) Project simply followed the Pradesh.) This is not surprising: the consultants are formats laid down by MOEF, collected voluminous most familiar with the MOEF requirements to collect data but failed to recognize the likely impacts due to exhaustive ambient environmental quality and mete- laying of long-distance pipelines carrying hazardous orological data. Most EA reports had collected large chemicals. In another case the Second Madras Water amounts of data on existing environmental and social Supply Project failed to recognize the impacts due to settings. However the question that still remains is disposal of more than 3.0 million liters per day of how much data collected are useful for EA and is it chemical (alum) sludge from the proposed water treat- cost effective? ment plant. There were also some exceptions The Bombay Sewage Disposal Project is a good example where the Analysis of alternatives issues identified were pnoritized. Additional detailed field investigations such as (a) collection of oceano- The review has shown that analysis of alternatives is graphic data and calibration of mathematical models one of the weakest EA elements. Despite the emphasis covering expanded area of coastal waters; and (b) given to analysis of alternatives in OD 4.01, rarely did determination of the final configuration of the marine any EA identify and analyze systemic alternatives and outfall systems have been proposed to aid further a few had analyzed technical alternatives.2 These are 14 India Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 rarely explored and systematically analyzed for their Prediction and assessment of impacts environmental and social impacts. Most of the EAs reviewed simply carried out the analysis of two differ- Prediction and assessment of impacts has been rated ent scenarios either 'with project' and 'without project'. 'less than satisfactory' in 3 out of 7 category-A projects In a few cases, like the Second Petrochemicals Project reviewed. Only one category-B project was found to (Nagothane) where the site and technology options be 'less than satisfactory' because limited environ- were frozen because the project supported only expan- mental analysis or mitigation plans alone suffice. Most sion of existing facilities, it may be difficult to evaluate of them have not used the appropriate quantitative site or technology alternatives. But even in this case, analytical tools such as the mathematical water/air the EA could have explored alternative routes for lay- quality models or Geographical Information Systems. ing 72 kilometer-long pipes carrying propane gas. A good example of a comprehensive assessment of One reason for not exploring different alternatives is impacts is that of the Bombay Sewage Disposal Project: the failure to initiate the EA at the earliest stage of pro- The EA extensively used mathematical modeling for ject design. In a number of cases, EA are undertaken predicting water quality (shoreline bacterial concen- when most of the crucial aspects of the project design tration) impacts and for choosing the length of marine have already been decided In the case of Indian outfall. It also clearly stated the limitations of the Petroleum Corporation Limited (IPCL), Nagothane, model used and the unavailability of adequate field the project location, its size, and technology including data. the pipeline routes were fixed a priori. The EA was con- Air quality modeling is one of the well-established ducted primarily to identify measures to mitigate the tools for predictions and decision making. However, in potential risks and adverse impacts due to the project. many cases these have not been used satisfactorily For As a result, the EA focused on defending the decisions example, the Second Petrochemicals Project did not taken by developing appropriate mitigation measures. make quantitative predictions on sulfur oxides (SOX) On the other hand, evidence suggests that whenever and nitrogen oxides (NOX) and have not made use of EA are undertaken concurrent with the earliest stages the extensive meteorological data collected. Similarly of project design, there has been an improvement in the NTPC Project used the model only for predicting the quality of 'analysis of alternatives'. A good example ambient air quality and not for optimizing stack is the case of Vadodara-Halol Road Widening project, heights and air pollution control equipment. a sub-project under the Private Infrastructure Leasing and Financial Services (IL&FS) project. The original project design was to widen the existing road width Mitigation measures along the entire 33-kilometer stretch between Vadodara and Halol. The environmental and social Mitigation measures were found to be 'above satisfac- assessment noted that the project in its original form tory' in all EA projects reviewed except one case. None would lead to the resettlement and rehabilitation of of the reports received an'excellent'rating because mit- about 300 project-affected families, having residential igation measures for eliminating all major and minor and/or commercial structures within the proposed impacts have not been recommended. Also in most right of way A systematic analysis of various alterna- cases the identified mitigation measures have not been tives including social and environmental aspects was costed and integrated with the project. carried out, concurrent with the project design. The Several EAs have failed to recognize the residual project alignment was then changed by introducing or induced impacts and the side effects of the miti- bypasses at critical locations. The modified alignment gation measures themselves. For example, the treat- was found to be more acceptable to the people as well ment and secured disposal of chemical sludge from as cost effective. The extent of resettlement and reha- wastewater- and water-treatment plants seems to be bilitation was thereby reduced to only 10 project- an issue often neglected by many projects. The affected families. Second Petrochemicals, the Second Madras Water Evaluatingfor quality 1 5 Supply, and the Industrial Pollution Control are some~~~~ ~ ~ of th.rjcswihhv fie oadest Box 3.1 Influence of poublic consultation on design some of the projects which have failed to address this o eodMda ae upyPoet issue satisfactorily of Second Madras Water Supply Project. One of the main objectives of the Second Madras Water Supply Project was the treatment and transportation of Public involvement and consultation 190 million liters per day of water to the Madras city by a 235 kilometer-long transmission pipeline. (This com- ponent was dropped soon after the project became effec- Operational Directive 4.01 clearly states that EA must tive in 1996 by the Government of Tamil Nadu.) The be prepared ensuring maximum participation and con- source of the water is the ancient Veeranam irrigation sultations of the affected peoples and NGOs, especial- tank which is supplied by the Cauvery River system. ly after the EA category has been assigned and when There are about 11,500 farmers in the Veeranam com- the draft EA has been prepared. Despite this require- mand area. The entire local economy of the region, and hence the whole community is directly or indirectly ment, the detailed analysis of the project specific EA dendent on culr th is inethe Vranam , ~~~~~~~~~~~~~~dependent on agriculture. The villages in the Veeranam reports shows that only 50 percent of the projects were command area are widely distributed geographically rated 'satisfactory' or higher for 'public involvement and, although farmers do belong to associations, they are and consultation'. The outcomes of the consultations not generally well organized or represented. Dunng pro- which were undertaken did find some place in the pro- ject preparation an environmental assessment of the pro- jec deignandl/or mitigation strategy.3 ject was carnied out, which included a strategy to con- ject design an/rmtgto taey3sult the farmers and the community This review shows that there are a few examples Conulations ced farmeaia n r ~~~Consultations covered farmers associations ancd rep- where the views of affected peoples were integrated resentative groups, local governments and the most as part of the project design to mitigate any adverse necessary direct contact with the communities through environmental impacts. The Second Madras Water meetings in the villages. The requirement for formal Supply project (Box 3.1) is a good example where sys- operating rules governing supplies, as well as releases of tematic public consultation resulted in framing of water from the tank, for both irrigation and Madras city purposes was stressed by the farmers and others in these rules to protect the irrigation rights of the farmers in coslainThfrmsde ntaednauelcl consultations The farmers demonstrated an acute local drought periods. awareness of the need to incorporate new rules for This review also points out that public consulta- releases from the much larger Mettur Reservoir, some tions and involvement rarely continue beyond the 200 kilometers upstream on the Cauvery, which is one project preparation stage. Nonetheless there is a good of the sources which serve the Veeranam tank. example where such consultations were held regular- As a result of the consultations, formal rules were drafted which, with modifications, were accepted by ly during the implementation stage as well. In the the farmers and villagers. The most significant was that Bombay Sewage Disposal Project, a Citizens Advisory issued officially by the Government on October 26, Committee (CAC) was formed during the preparation 1994 as Govemment Order No. 1084, which estab- stage (April 1994) to assist and advise the Municipal lished operating rules for Veeranam tank that protect Corporation of Greater Mumbai (MCGM) in imple- the irrigation rights of farmers in drought years. A nec- menting the agreed environmental mitigation and essary adjunct to the rules were works to expand the capacity Of the veeranam tank. These works, later monitoring plan. It was comprised of two representa- caciyothVernmak.Tsewk,ltr included as part of the project, were required to ensure tives of a fisher-folk cooperative, two environmental- that at all times the irrigation supply would exceed the ists, two municipal councilors, and one representative supply that would otherwise have been provided, while each from residents associations. The CAC has been permitting continued off take for Madras. meeting regularly since 1996 at intervals of three to four months and the project management unit main- tains a record of the CAC discussions and of the fol- their likely impacts and MCGM efforts to mitigate low up actions taken. Bulletins in Marathi (local lan- these impacts. guage) and English were made accessible to the A clearly defined strategy for public consultation was public, informing them about the proposed works and completed in only 20 percent of the projects under 16 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 Table 3.4 Supervision ratings on compliance of environmental mitigation plans as reported in Form 590 during FY90-97 Form 590s Form 590s Form 590s No. of 'not rated" rated rated Project Form 590s for "satisfactory" 'unsatisfactory" Categorya reviewed environment (1, 2, S, HS)b (3, 4, U, HU)C Remarks Bombay Sewage Disposal 4 0 4 0 4 total missions (0 without env. specialist; Project / A 4 with env specialist) Gas Flanng Reduction / A 3 0 3 0 9 total missions (3 without env. specialist; 0 with env. specialist). Form 590s not available = 6 NTPC Power Generation / A 6 0 6 0 10 total missions (4 without env. specialist; 6 with env. specialist) 4Form 590s not available = 4 Private Infrastructure Finance Not Not Not Not 1 total mission (0 without env specialist; (IL&FS) / A available available available available 0 with env. specialist) Form 590s not available = 1 Second Madras Water Supply / A 4 2 2 0 4 total missions (2 without env. specialist: 2 with env. specialist) Second Petrochemicals 3 0 3 0 Total number missions not available (2 Development / A wIthout env. specialist; Iwith env specialist) Records of only 3 missions at NDO. Haryana Water Resources 7 7 0 0 7 total missions (7 without env specialist; Consolidation / A 0 with env. specialist) Form 590s not available = 0 Orissa Water Resources 4 0 4 0 4 total missions (3 without env. specialist, Consolidation / A 1 with env. specialist) Form 590s not available = 0 Tamil Nadu Water Resources 4 0 4 0 4 toLal missions (3 without env. specialist, Cons. / A 1 with env specialist) Industrial Pollution Prevention / B 4 0 4 0 5 total missions (0 without env. specialist; 5 with env specialist) Form 590s not available = 1 (Mid-term review has not yet taken place) Assam Rural Infrastructure 3 1 2 0 5 total missions (3 without env. specialist; and Agricultural Services / B 1 with env specialist) Form 590s not available = 2 (Mid-term review has not yet taken place) Bihar Plateau Development / B 8 1 7 0 9 total missions (7 without env specialist; 1 with env. specialist) Form 590s not available = 1 Shnmp and Fish Culture / B 10 1 8 1 10 total missions (9 without env. specialist, 1 with env. specialist) State Health Systems 1 Not Not Not 1 total mission (0 without env. specialist, Development 11 / C applicable applicable applicable 1 with env. specialist) (Mission included a medical waste management specialist/ bio-medical engineer) a Each project was reviewed from its respective date of effectiveness to June 1997 b. Rating format prior to FY97 (1) no significant problems; (2) moderate problems; (3) major problems, appropnate actions being taken to address them, and (4) major problems, not being addressed c Rating format from FY97 (HS) highly satisfactory, (S) satisfactory , (U) unsatisfactory; (HU) highly unsatisfactory, (NR) not rated Evaluatingfor quality 17 review. Only two projects, Vadodara-Halol Road monitoring plan addressing all social and environ- Widening and Assam Rural Infrastructure and mental issues, the Vadodara-Halol Road Widening Agricultural Services, were rated 'excellent' for public project has not addressed the audit/post-project mon- consultations. In the case of the Assam project, exten- itoring needs On the other hand, the CAC formed sive discussions on project design were held with local under the Bombay Sewage Disposal Project did assist NGOs and women's groups which also participated in and advise the MCGM in implementing the agreed site-specific project design, implementation, and mon- environmental mitigation and monitoring plan. Also, itoring. In the case of Vadodara-Halol Road Widening, the project has developed a comprehensive manage- the public involvement and consultation were carried ment information system to monitor the compliance out from the stage of site selection and analysis of alter- of agreed EMPs. natives for various proposed alignments of the highway Environmental covenants in legal documents Monitoring plans/institutional aspects Legal documents including loan, credit and grant Most EAs reviewed had prepared outline monitoring agreements, bidding documents and related contracts plans covering all major mitigation measures and an provide much of the framework to support and enforce institutional framework to aid implementation. For an supervision. It is therefore critical that such documents 'excellent' rating, EAs would have to address all issues adequately reflect the project environmental require- arising out of the environmental and social analysis ments and specific mitigation measures recommended and recommend an audit framework for post-project by the EA process (Environmental Assessment Source- monitoring. Rarely do the EA reports cover all these book Update on Environmental Performance Monitonng aspects For example, despite the preparation of a and Supervision, June 1996.) Box 3.2 Examples of specific and generic environmental and social legal covenants Specific legal covenants, examples where there is a direct facilities that will be constructed under the project and relation with the environmental or social component of safety audit for its entire offshore operations " the project. Generic legal covenants, examples where the covenant * Bombay Sewage Disposal project has dated covenant encompasses the environment mitigation plans in general which states "India to establish revised water quality stan- * National Thermal Power Corporation (NTPC) project's dards applicable to wastewater discharge to manne coastal legal document states that" NTPC to implement the envi- waters byjune 30, 1997." For implementing the slum san- ronmental action plan dated May 10, 1993, as agreed wiLth itation scheme component, it states "MCGM to apply the the Bank." policy guidelines for the slum sanitation schemes agreed * Fish and Shrimp Culture project's legal agreement with the Bank." mentions "each State shall carry out such mitigatory * In the case of Second Madras Water Supply, "Institute actions satisfactory to the AssociatLion as required for pre- dam safety inspection arrangements for Veeranam venting, reducing or eliminating the potential negative tank". effects of the project on the environment." * Gas Flaring Reduction Project specifies the environ- * Onssa Water Resources Consolidation Project - "carry mental covenant with respect to its environmental com- out R&R in accordance with the R&R plan and in a man- ponent requirement, "Oil and Natural Gas Commission ner and timeframe acceptable to IDA." (ONGC) to obtain environmental clearance for all com- * Bihar Plateau Development Project "make arrange- ponents of the proposed project," and "ONGC to carry out ments satisfactory to Association for resettlement and a safety engineenng study of existing platforms linked to rehabilitation of displaced persons." Source Drawn from form 590 sections on compliance of legal covenants 18 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 A summary of key project activities, their environ- quality EA reports, the project supervision often does mental and social impacts, key EMPs, and relevant not give adequate focus on environmental issues and legal covenants along with their compliance status as supervision reports do not include enough details on of June 1997 is given in Annex 5. Several main obser- progress in implementing EA recommendations. The vations emerge: Environmental Assessment Sourcebook Update on * Most of the projects have legal covenants which Environmental Performance Monitoring and cover the development and/or implementation of Supervision (June 1996) states that category-A pro- EMPs. However the majority of covenants do not jects require annual participation of an environmen- necessarily contain specific environmental or social tal and/or social sciences specialist (depending on actions to be met on a timely basis. The references the importance of environmental or social issues) in are usually general in nature. Box 3.2 gives examples project supervision. Category-B projects require par- of general environmental language used in a legal ticipation in mid-term reviews as a minimum document. requirement. * In less than 50 percent of the projects, a clear rela- This section of the review analyzes the information tionship exists between the EMP/ Rehabilitation Action on environmental supervision, as reported by the task Plans (RAPs) and the social/environmental legal managers in Form 590.3 The available information/data covenants. was analyzed for participation of environmental staff * All three water resources consolidation projects, during supervision missions, and the level of compli- which are classified as category A do not have specific ance of environmental aspects as suggested by the spec- environmental covenants although some aspects of ified environmental rating criteria. Table 3.4 summa- EMPs are covered under covenants related to the "man- rizes the information collected from Form 590 of agement aspects of the project". On the contrary, social various supervision missions. Some key observations impact mitigation measures are well reflected in the emerge from the review: legal covenants. * Inadequate environmental supervision to monitor * There are no specific environmental or social progress in agreed-upon EMP implementation has covenants for the Assam Rural Infrastructure and been one of the weakest aspects. Recent studies by the Agricultural Services project, but aspects of the EMP are Environment Department and the Operations covered under the covenant related to'implementation'. Evaluation Department (OED) also reached similar In some projects the legal document simply makes conclusions. In the category-B Shrimp and Fish a reference to environmental mitigation and manage- Culture project, despite good environmental analysis ment plans described in the staff appraisal report. with adequate mitigation strategies in the initial stages, Some examples are given in Box 3.2. While such a step lack of local ownership of the EA process and weak helps in covering all identified mitigation measures, supervision by the Bank resulted in unsatisfactory the effectiveness of this approach depends on the qual- environmental outcome. Only one of the 10 missions ity and clarity of the measures described in the staff included an environmental specialist. appraisal report and the commitment of the borrow- * In seven out of nine category-A projects, environ- ers, especially since the staff appraisal report lacks legal mental specialists participated in less than 50 percent status. supervision missions. Therefore ratings seldom get assigned. Sometimes, the minimum requirement of annual participation by an environmental specialist in Environmental supervision project supervision was not followed. In the Haryana Water Resources Consolidation project, there was no Supervising the environmental aspects of a project participation of an environmental specialist during any includes monitoring the compliance of environmen- supervision mission. tal commitments and the implementation status of * Participation of environmental specialists in super- mitigatory measures. Despite the preparation of good vision missions is rare in category-B projects (less than Evaluatingfor quality 19 20 percent), except the Industrial Pollution Prevention appraisal criteria, link between the sectoral and pro- project wherein environmental specialists were present ject-specific EAs. Such details were found in the sec- for regular project supervision as well. In the Bihar toral EA under preparation for the proposed Plateau Development project even the minimum Hazardous Waste Management project. This important requirement of participation in the mid-term review element lays down the framework to implement sec- (Feb. 5-10, 1996) was not carried out. toral EA recommendations. Form 590s do not reveal the ground realities or the * The environmental supervision of these projects actual status of EMP compliance. Eight consecutive appears to be weak. These projects require closer supervision missions of the Shrimp and Fish Culture supervision from which to learn how to improve the project have been rating the project 'satisfactory' for effectiveness of sectoral EAs. environment even when site specific EMPs had not been designed till later (June 1997). Notes 1. As explained in note a of Table 3 1, not all projects in the sample were reviewed in a sufficiently detailed manner as to Summary of the review of sectoral EAs allow comparisons. 2. As per OD 4.01, assessment of investment alternatives from Sectoral EAs were carried out in only three projects in an environmental perspective should form an essential part of India and all were selected for this review. These are the the EA process. This includes the systematic companson of the water resources consolidation projects in the states of proposed investment design, site, technology and other opera- tional alternatives in terms of their potential environmental Haryana, Tamil Nadu, and Orissa. A detailed review of impacts, capital and recurrent costs, and institutional, training, these projects could not be carried out because of the and monitonng requirements Para 2 of Annex B in OD 4 01 unavailability of full EA reports for Haryana and Tamil states that the basis for selection of the alternative proposed for Nadu. However based on the staff appraisal reports of the project design should also be stated these two projects and a detailed review of the EA report 3. The views of affected groups and local NGOs should be fully for Onssa,the following generic conclusions are drawn: taken into account in project design and implementation, and in for Onssa, the following generic conclusions are drawn: particular in the preparation of EAs. This process is important in * The weak areas in category-A projects were found to terms of both the nature and extent of any social or environmental be analysis of alternatives, prediction and assessment impact and the acceptability of proposed mitigatory measures, of impacts, and public involvement and consultation. particularly to affected groups. Consultations do not reduce the This is not surprising because the sectoral EAs require decision authonty of the borrower, but are a valuable way to a higher level of expertise to focus more on systematic improve decision making, to obtain feedback on the EA process and to increase community cooperation in implementing the EA alternatives, policy analysis, linkages with other sec- recommendations Such consultations should occur at least at the tors, and institutional arrangements. following two stages: (a) shortly after the EA category has been * Other attributes like project description, baseline assigned and, (b) once a draft EA has been prepared. conditions, mitigation plans, development of environ- 4. Form 590 is the project supervision status reporting format. mental management and training plans have been This report is completed by Bank task mangers following pro- addressed at a satisfactory level. ject supervision missions. Environmental ratings are generally addressed at a assigned by comparing actual performance to the original * No reviewed reports seem to have included process objectives and parameters at appraisal, according to the scales guidelines stating the sub-project eligibility or descnbed in OD 4.01 4. Addressing special issues This review has so far highlighted several important toral master plans and five-year budget exercises can issues pertaining to the analysis of project-specific and be powerful sites to introduce sectoral EAs. sectoral EAs. This chapter discusses some of the spe- For the first time in India a series of Water Resources cial issues that need to be addressed for improving the Consolidation Projects (WRCP) currently under effectiveness of the EA process in India. implementation in Haryana, Tamil Nadu, and Orissa are using the sectoral EA approach. These projects are programmatic in nature with the main environmental Sectoral and regional environmental assessments issues concerning monitoring and management of existing operations across the sector as a whole, rather Sectoral and regional EAs have considerable relevance than impacts from new construction. to India where a large number of State-level projects The first phase focuses heavily on the institutional such as State health systems, municipal services, and and legal framework for the entire water sector in each road and highway projects are in the proposed fiscal state. The second phase, based on the recommendations 1998-2000 lending program. For example, the pro- of the first phase, would include activities like long-term posed Hazardous Waste Management project is already BA training and preparation of case studies and moni- using the sectoral EA approach. While the EA system in toring plans for the irrigation sector. It will be extreme- India is currently maturing with respect to project-spe- ly useful to monitor the effectiveness of this approach cific EAs, the experience is limited m recognizing and compared to the project-specific EA approach. coordinating regional and sectoral EA. Consequently, The regional EA approach has not been used in any of opportunities to address environmental issues at plan- the projects in India. The advantage of using regional BA ning, programmatic, and policy level are not used to as a tool to develop investment strategies, programs, and strike long-term sustainable solutions. Therefore projects that are environmentally sustainable for a region strengthening this approach would benefit implemen- as a whole has not been fully understood or exploited. tation of projects with sectoral/regional impacts. The Assam Rural Infrastructure and Agricultural Services The World Bank has much experience in carrying project and the Shrimp and Fish Culture project (both out project-specific EA. This has resulted in the devel- category-B projects covering most parts of the State) are opment of the Environmental Assessment Sourcebooks good examples where the regional EAs could have influ- (Volumes I, II and III) which provide valuable guidance enced the respective State governments in makig envi- on project-specific EAs. However, although OD 4.01 ronmentally sustainable investment decisions, much refers to regional and sectoral EAs, experience in car- beyond the scope of the Bank-assisted project. rying out these types of assessments have been com- paratively limited. 1 This slow uptake of sectoral EA can be expedited in relevant projects by linking analysis of Project screening criteria alternatives with tried-and-true economic least-cost sequencing while integrating social and environmental The Bank's classification of projects by categories A, B criteria to conventional economic criteria. State sec- and C depends on the significance of the environmen- 20 Addressing special issues 21 tal issues and the subsequent level of analysis needed. 4.01 among consultants and borrowers. This could The project screening criteria plays an important role become an attachment to the consultant's terms of ref- in assigning the right type of category The review sug- erence (TOR) on EA. gests that deciding the level of EA to be undertaken based solely on the project type may not be the best way of screening. Several other important variables Integration of environmental assessment and should be considered including 'project size,''location' social analysis and 'project type'. Category-B projects may have to be elevated to category A because of the sensitivity of loca- Several projects reviewed have carried out satisfactory, tion. The Shrimp and Fish Culture project is a good independent environmental and social assessments but example where an analysis of adverse environmental failed to adequately integrate or link them. The type and impacts due to large-scale shrimp farming in coastal level of social analysis which must be undertaken varies areas might have changed from category B to category with each project In most cases it is not expected to be A. Therefore it is important that the project catego- a complete sociological study nor a social cost-benefit rization is based primarily on field data, and less on analysis of the project. Of the many social impacts that project type. Similar findings were reported in the sec- might occur, the EA is concerned primarily with those ond review by the Environment Department of the relating to environmental resources and the informed World Bank. participation of affected groups For the purpose of EA, social analysis focus on how various groups of people affected by a project allocate, regulate, and defend Guidelines for category-B projects access to the environmental resources upon which they depend for their livelihood.2 Such an integration seems Operational Directive 4.01 outlines a suggested table to have been well achieved in case of the Second Madras of contents for the detailed EA report for category-A Water Supply project and Bihar Plateau Development projects. However, no such guidance is provided for project EA reports. category-B projects and the EAs are limited to adequate environmental analysis and development of the miti- gation plans. Consequently, there are varying levels of Mitigation measures and environmental details in the EA reports prepared for category-B pro- assessment jects and review of these reports is rather difficult. In order to ensure the quality and improve the effective- During the EA, mitigation measures emerge from the ness of EA in category-B projects, it will be useful to recommendations delineated in the EMP It is also pos- develop detailed guidelines to be followed during the sible that the mitigation measures get identified as project preparation and implementation stages. stand-alone projects. Examples are the Bombay Sewage Disposal Project at a local scale and the Industrial Pollution Control Project at the national scale. Review criteria Generally, mitigation measures are expected to reduce or eliminate the critical negative impacts likely The review team used a set of questions given in Table to be caused by the various activities as under the 4.1 as a basis to develop the review framework development project. However there could be situa- described in Chapter 2. These questions reflect the tions when mitigation projects themselves have a requirements of OD 4.01 and identifies the key tasks potential to lead to other significant environmental and and their expected outcome at each milestone of the social impacts. Examples are the problem of treatment project cycle. Further improvement of these questions and disposal of sludge arising from an effluent treat- and the review framework developed in Chapter 2 will ment plant or the intrusion to the aviation airspace be useful in disseminating the requirements of OD caused by a tall industrial stack or the interference 22 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 Table 4.1 Checklist of review questions Task Related Questions Outcome Related Questions Milestone: IDENTIFICATION Is screening done? Are screening critena adequate and clear? Are the outcomes of screening commensurate with the national guidelines? Is scoping done? Are all critical environmental issues identified? Is consultation with affected groups done? Has the outcome of the scoping been used in defining further studies? Milestone: PREPARATION AND DESIGN Have baseline studies been conducted? Do the baseline studies cover information on the impacted environmental components? Have alternatives been examined? Are the concerns of the affected groups reflected in the identification of the alternatives? Have all significant issues been assessed? Is the methodology used for assessment acceptable? Are all relevant national guidelines/rules satisfied? Have mitigation measures been identified for mitigation of Are the mitigation measures proposed adequate? significant issues? Are the residual impacts acceptable? Have the Resirual nsks been identified? Is a nsk management plan prepared as a part of the EMP? Has an EA report been prepared as per the guidelines? Is the quality of the EA report produced acceptable? Has the public involvement/ consultation been done during the Is there a linkage between environmental and social assessment? preparation of the EA report? Have the concerns of affected groups been addressed in the Does the EA address the monitonng requirements during proposed mitigation measures? implementation? Does the EA address the post-project monitoring requirements? Is the post-project monitoring plan comprehensive and supported by an adequate institutional framework? Are the mitigation measures integrated with the project elements, Is the integration of the mitigation measures with the project plannng and budgets? elements, planning and budgets satisfactory? Is the project selected, out of the alternatives identified, based on an economic analysis covering environmental costs and benefits? Milestone: APPRAISAL Has the review of the EA procedures and findings been done? Is the review of the EA procedures and findings satisfactory? Has the review of the institutional arrangements been done? Is the review of the institutional arrangements satisfactory? Have the Environmental performance indicators been developed? Are the indicators measurable and meaningful? Milestone: NEGOTIATIONS AND LOAN APPROVAL Have environmental covenants been included in the agreements? Is the formulation of the environmental covenants satisfactory? Milestone: IMPLEMENTATION AND SUPERVISION Has there been consultation / stakeholder involvement? Does the implementation plan integrate concerns ansing from public consultation into the proposed time frame? Has assessment of existing human resources been done? Does the implementation plan identify training areas? Have provisions been made for additional staffing and staff training? Have the environmental performance indicators been used for Have corrective actions been taken if result of environmental supervision and assessment? performance indicators is unsatisfactory? Milestone: COMPLETION Has the project completion report been prepared? Has the post project monitoring been done adequately? Has post project monitoring been done? Has the methodology used for the auditing of the project EA been satisfactory? Has a project EA audit been done? Have the results of the project EA audit been used to improve the EA process? Addressing special issues 23 caused to the local fishermen by a marine outfall. It is EA in this case could have insisted that CETPs be necessary therefore that the mitigation measures are accompanied by comprehensive sludge management also examined as projects and an EA is performed. The schemes. Eligibility criteria for individual industry EA should ensure that the impacts arising from the mit- loans could have stressed waste minimization at igation projects are identified, predicted and assessed source as well as a need to address multimedia man- to find out the most acceptable design. ifestation of pollutants. The Bombay Sewage Disposal Project is an excellent Thus EA has a considerable role to play in structur- example in favor of this concept where EA led to ing even mitigation projects so as to ensure that they are redesign of the mitigation measures by an exhaustive environmentally sound as well as cost effective. analysis of alternatives. After establishing that the pro- posed mitigation project (aerated lagoons at Malad and Versoa) was ineffective in delivering the desired envi- Nontechnical summary for effective public ronmental improvement on receiving ecosystem, the consultation EA undertook a systematic step-by-step analysis of alternatives so that the project meets the minimum A nontechnical summary (NTS) is an essential tool for environmental objectives. A series of alternatives were communicating the EA findings to the project stake- examined, all of which were technically feasible; tech- holders. Generally prepared in English, Hindi, as well nology was proven, land was available, and discharge as the local language, NTS provides a basis for public standards were expected to be met. understanding of the project-related environmental Finally, the alternative which ensured a minimum and social issues, and the proposed EMP Public dis- desired level of dissolved oxygen in the receiving cussions on the NTS can provide clues for developing waters was identified. This consisted of a diversion of alternatives as well as assist in determining acceptance bulk of the wastewater away from Malad Creek with of the project and the proposed EMP This exercise is only limited discharge of secondary treated sewage into very crucial while addressing category-A projects, for the creek via a marine outfall. This alternative was rad- developing regional projects or while preparing sec- ically different from the original mitigation project with toral EAs. The absence of NTS reduces the opportuni- a potential for substantial environmental improve- ty for better communication with stakeholders and ment As a result, the Malad aerated lagoons were thereby reduce the effectiveness of the EA process. scrapped. Versoa lagoons were scaled down and Currently, OD 4.01 does not require a NTS, but it does retained as technology demonstration schemes. require public consultations. Also, the amendments to During the environmental screening process, the the EIA notification of the GOI (April 1997) requires a Bombay Sewage Disposal Project was marked catego- public hearing to be conducted. Guidelines for conduct- ry A, whereas the Industrial Pollution Control project ing a Public Hearing are being developed to this effect. was given category C and did not undergo a similar This review shows that NTS is not produced as a part of EA process. Consequently, the designs of Common EA reports. It is essential therefore for the Bank to for- Effluent Treatment Plants (CETP, a component in the mally require a NTS as a result of the EA exercise and pro- Industrial Pollution Control Project) were not com- vide specific guidance in producing the same. prehensive enough to address the management of sludges arising from the treatment plants. Similarly, the eligibility criteria for granting the loans for indi- Need for coherence between EA process and EIA vidual industries did not put enough stress on the systems preventative and multiple media aspects of waste management. It is therefore clear that even projects A comparison of the Bank's OD 4.01 and the GOI formulated as a package of mitigation measures (such MOEF EIA system (Annex 1) shows that there are dif- as Industrial Pollution Control Project) should be ferences in the requirements, approach, and content. subjected to an EA to derive maximum benefits. An The EA for the Second Petrochemicals project was writ- 24 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 ten in the style of MOEF requirements but failed to meet social clearances for each sub-project to be financed. This the requirements of OD 4.01. Discussions dunng this approach does not include a separate or specific institu- review between MOEF officials and Bank staff confirm tional capacity building component as in the IL&FS pro- that there is a strong demand for a systematic program ject. This is the case with the on-going Industrial of educating and informing various interest groups of Pollution Control and Industrial Pollution Prevention the requirements of OD 4.01 and the EIA notification. Projects. The financial intermediaries are the Industrial Such an exposure when conducted would lead to: Development Bank of India and Industrial Credit and * a clearer understanding of the requirements which Investment Corporation of India. In the absence of strict would in turn reduce delays as well as improve the EA guidelines and limited capacity within these financial quality of analysis; and intermediaries to analyze the environmental issues and * minimize overlaps and/or identify needed expan- carry out environmental supervision, some of the sub- sions and strengthening for striking a coherence. projects approved to date have potential adverse impacts. In particular some of the common industrial effluent treatment plants and individual on-site industrial-efflu- Financial intermediary lending ent, hazardous-waste treatment facilities supported under these projects deserve more detailed environmen- Bank lending through financial intermediary (Fl) to tal assessments/appraisal than the current practice. promote private sector development in India is increas- ing. Under OD 4.01 the Bank should appraise and Notes strengthen where necessary the environmental capa- 1. Stated in the Environment Assessment Sourcebook Update, bilities of financial intermediary lending to ensure that Dec. 1996, the purpose of regional EA is to improve investment they carry out appropriate environmental analysis of all decisions by bringing environmental opportunities and con- sub-projects in a manner consistent with Bank policy straints into development planning at the regional level. It assess- Among the projects reviewed it is evident that two dif- es environmental issues and impacts in a distinctly spatial setting. ferent courses of action or approaches have been taken. Sectoral EAs avoid the inherent limitations of project specific EAs in addressing issues related to policy and planning and the legal and instutional framework It offers better opportunities not environmental screening and review capacity within only for analyzing existing policies, institutions and development the financial intermediary appears to be one approach plans in terms of environmental issues, but also for supporting that was well achieved in the IL&FS project via the fol- environmentally sound sector wide investment strategies lowing key steps: 2. In projects with major social components, which require con- * development and adoption of an in-house policy on sultations pursuant to other Bank Operational Directives i.e., social .devrnetlas t OD 4 30, Involuntary Resettlement and OD 4.20 Indigenous social and environmental assessment giving IL&FS an Peoples, the consultations on social issues and on Environ- Environmental and Social Report which spells out the mental Assessment should be linked. (OD 4 01, October 1991 policies and guidelines governing the environmental and Environmental Assessment Sourcebook, Volume 1, 1991) and social clearance for sub-loans;3 and 3. The Environment and Social Report responds to both GOI * creation of an Environmental and Social Develop- and Bank's requirements and regulations. Organized in 3 vol- ment Unit managed by a team of professionals. umes, the Report (a) outlines the company's environmental and social goals; (b) provides the contextual setting for the envi- The above aproach seems to be working well asthe ronmental and social assessment process; (c) identifies the quality of EA report for a sub-project financed by major issues in the prionty sectors; (d) details the environmen- IL&FS (Vadodara-Halol Road Widening project) has tal and social assessments process that IL&FS will follow when emerged as one of the best EA reports covered in this appraising sub-projects; (e) outlines methods to moderate risks review, and liabilities due to environmental and social factors; (0 spec- A second approach followed by the Bank is to rely on ifies the organizational arrangements in IL&FS to manage the the existing Fl capacity to provide the environmental and envlronmental and social assessment process; and (g) spells out the staff development plan. 5. Conclusions and recommendations This chapter offers recommendations based on the importantly the stress on quick project preparation. lessons emerging from the detailed review of 14 pro- These hurdles could be overcome to a large extent by jects to improve the effectiveness of the EA in the Bank- carrying out broader sectoral and regional EAs very early assisted projects in India and identifies areas requiring in the project cycle. To quote from the OED study (1996) further attention. on effectiveness of EA: "More frequent recourse to sec- The quality of EA reports m India has been steadily toral and regional EAs would lead to improvement in improving. However the World Bank's experience with timeliness, better screening, more careful consideration regard to the effectiveness of the EA process in influenc- of alternatives and would eliminate the need for repeat- ing the project design and implementation is not fully sat- ed gathering of same data for project specific environ- isfactory This is an area of concern particularly in view of mental assessments." This will also help in improving the fact that the Bank's lending portfolio in India is expect- the scoping and prnoritization of environmental issues ed to grow at a faster pace and reach a level of US$3-4 bil- while carrying out project-specific EAs, as these were not lion over the next few years. Both the Bank and GOI are satisfactory in a majonty of EAs reviewed. keen to ensure that social development and environmen- Recommendation. Looking at these benefits and con- tal concerns are fully reflected in the growth process. sidering India's proposed lending program for fiscal 1998-2000, the sectoral and regional approach should be used for the projects in the sectors such as State and How to improve the effectiveness of EA in project National highways, municipal services, and State design? health systems. In order to make the EA process proactive and ensure b) Improve the analysis of investment alternatives quality assessments, it is recommended that priority from an environmental perspective actions be taken to improve: (a) the timing of the EA Advantages of a senous economic analysis of environ- process, (b) the analysis of alternatives, (c) the public mental costs and benefits of various investment alterna- consultation process, and (d) the EA review cnteria. tives presented during the project preparation stage are These observations also reflect the conclusions of other well known. Despite the emphasis given in OD 4.01 and Bank-wide studies carried out by OED and the in Indian regulations, analysis of alternatives was ob- Environment Department. served to be one of the weakest aspects of the EA process. Recommendation. In order to identify and analyze var- a) Improve the timing of the EA process by introducing ious investment alternatives from an environmental per- sectoral and regional EA approach spective, the EA process should be initiated at an early EA process is known to have greatly influenced the pro- stage of the project preparation, a separate section on ject design when it is carried out early in the project analysis of alternatives should be introduced in the TOR cycle. But this is not always easy because of various rea- for the EA assignment, and the sectoral and regional EA sons such as the emphasis on comprehensiveness, the approaches should be applied wherever possible. Also, need for collecting field data for at least a twelve-month there is a need for the MOEF to prepare separate appli- period to capture the seasonal variations, and more cation forms for various categories of projects. 25 26 India Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 c) Improve the public consultation process to influence aspects observed in this review The main reasons the project design and mitigation strategy include rare participation of environmental specialists in supervision missions, inadequate reflection of spe- Operational Directive 4.01 clearly states that EA must cific mitigation measures in the legal documents, and be prepared ensuring maximum participation and con- lack of seriousness as in some cases when EA is only sultations of the affected peoples and NGOs, especially considered only a project preparation activity In some after the EA category has been assigned and when the extreme cases, EAs were not available in the project draft EA has been prepared. Only 50 percent of the pro- files. The real challenge is to create proper incentives jects reviewed had carried out 'satisfactory' public and disincentives (for the staff to comply with the pro- involvement/consultation process. Common shortcom- visions of ODs) for enhancing the effectiveness of EA ings were found to be poor documentation of the con- process. sultative process and its outcome, limited influence on project design and development of mitigation strate- a) Improve compliance of EMPs through adequate gies, and consultation during and after implementation. environmental supervision Recommendation. To improve this situation, prepare Often, the supervision reports lack details on environ- specific guidelines on public consultation during various mental issues and Form 590s do not reveal the ground stages of project preparation and implementation, realities or the actual status of compliance of the envi- including on NTS preparation; and prepare a generic ronmental management or mitigation plans. TOR on public participation and consultation to be part Recommendation. In order to enhance the adequacy of the main EA TOR. A fairly comprehensive, generic of environmental supervision, include environmental TOR prepared for the proposed Hazardous Waste performance indicators, prepare a separate detailed Management project is a good beginning in this direction. environmental supervision note as prepared for other components of the project, and strengthen the capaci- d) Prepare a review criteria to ensure consistency and ty in the Field Office to have more field-based envi- quality EA reports. ronmental supervision. A quality control and review mechanism and some mandatory environmental mitigation plans with a b) Strengthen EA capacity in the project implementing focus on integration of environment and social assess- agencies ment would greatly benefit both the Bank and the bor- A comparison between the Bank's OD 4.01 and the rowers. Some donor agencies like Asian Development GOI EIA notification shows that there are differences Bank and Finnish International Development Agency in the requirements, approach, and contents. A strong have developed a quality review criteria along with need exists to understand these differences and build standardization across sectors to promote consistency, capacity in specific areas identified as the weak areas in accuracy and better quality EAs. this review. Such an initiative would not only improve Recommendation. Fine tune the criteria used in this the quality but also reduce the delay in EA preparation. review and develop a standard review criteria which These areas include scoping, analysis of alternatives, could be shared with the project implementing agen- public consultation, integration of environmental and cies and EA consultants. social concerns and preparation of sectoral and region- al EAs. Recommendation. In this context, organize sector- How to improve the effectiveness of EA in project specific meetings among staff of the Bank, GOI, and implementation? project implementing agencies, similarly planned for the highways sector, to discuss the environmental and Inadequate environmental supervision to monitor the social issues; identify and organize regular training compliance of agreed environmental manage- programs and seminars in partnership with other ment/mitigation plans has been one of the weakest donors;' get environmental units from sectoral imple- Conclusions and recommendations 27 menting ministries together annually to share common post-implementation review to fully assess the effec- problems as a form of capacity strengthening. tiveness of the EA in the Bank-assisted projects in India; and - develop a management information system to mon- Next Steps itor the compliance of agreed environmental actions of all category A- and B-projects. This review was a modest beginning to understand the effectiveness of EA in the Bank-assisted projects in Note India. The following actions are envisaged as the next 1 Asian Development Bank, through a Technical Assistance steps to continue this task: Project, is assisting the GOI in improving its capacity in the EIA * initiate a follow-up study including field visits and area. Annex 1 Comparison of World Bank's OD 4.01 and Government of India's EIA notification Critena World Bank (OD 4.01) MOEF (Handbook of Environmental Procedures and Guidelines) Year of 1991 UntilJanuary 1994, environmental clearance was an administrative requirement. After January implementation 1994 EIA has been made statutory for 29 specific project categories through enactment of EIA notification in May 1994. Target * Staff of the Bank * Borrowers (=> consultants) - MOEF, Pollution Control Boards, State Department of Environment * Project Proponent (=> consultants) Purpose * To improve decision making. * To ensure optimal utilLzation of finite natural resources, through * To ensure the project options under use of better technology and management packages. consideration are environmentally * To incorporate suitable remedial measures in the project sound and sustainable (guidance of formulation sustainability is provided as OD 4.00 environmental policies). Types of EA * Project specific Project specific * Regional Need for Regional EAs being recognized by MOEF For example * Sectoral area development projects are now subjected to EIA. Screening criteria * Categonzation is based on the * Rapid EIA or full EIA depending upon the decision of Impact judgment of task manager with the Assessment Agency (IAA). The project proponent may submit concurrence of Regional Environment the rapid EIA report, followed by detailed if asked for by IAA. Division. * EIA clearance from MOEF required if the project falls under * Category A (full EA required) the list of 29 projects listed in schedule I of EIA notification * Category B (preparation of mitigation 1994. The following categories also require environmental clearance: plan) * All mdustrial activities with investments of Rs 50 crores and above * Category C (EA not required) * More polluting industnes such as pesticides, distillenes, pharmaceuticals, raw skin and hides, dyes, foundries and electroplating, if the investments are more than 1 crore. * Thermal Power Plants with investments of Rs 50 crores and above. * Mining projects involving more than 5 hectare of land. * Aquaculture projects involving more than 40 hectare of farm area * All tourism projects between 200 to 500 meters of high tide line within elevation of 1,000 meters and mvolving an investment of more than 5 crores * All projects should comply with CRZ notification of Feb 1991. Identification of Issues to be addressed in the EA are Separate guidelines are available for the following projects which potential issues provided in Bank's policies and indicate specific issues to be addressed in the EA: guidelines for the following areas * nver valley * agrochemical * thermal power plants * biological diversity * mining 28 Annex 1 29 Criteria World Bank (OD 4.01) MOEF (Handbook of Environmental Procedures and Guidelines) coastal and marine resources * rail, roads and highways management - ports and harbors * cultural properties * new townships * dams and reservoirs * hazardous waste storage, treatment and disposal facilities * hazardous and toxic materials * indigenous peoples * induced development and other socio-cultural aspects * industrial hazards * international treaties and agreements on environment and natural resources * international waterways * involuntary resettlement * land settlement * natural hazards * occupational health and safety * ports and harbors * tropical forests * watersheds * wetlands * wild lands EA report TOR and table of contents- TOR and table of contents-not defined well defined. Whereas, a questionnaire is specified which is mandatory vith No requirement of the questionnaire. the EA report Analysis of alternatives Strongly recommended Consideration of altematives is mandated Also, for industrial pro- jects, analysis of alternative technological processes is required Geographical scope No generalized definition. * 20 kilometers radius for the industrial projects of the EA study Case specific scoping is done by the * 10 kilometers radius for other projects environmental specialist (Regional Environment Division). Social assessment Social assessment is mandatory Land acquisition act is applicable where relevant including rehabilitation action plan A comprehensive rehabilitation plan is required if more than (RAP) and indigenous people 1,000 people are likely to be displaced development plan (IPDP). Public and NGO Public participation and involvement of Public hearing is a must for any of the 29 project listed in the involvement NGO is a strong element, which may schedule I of the EIA notification. Guidelines have been recently even lead to change m the project design. developed for public hearing. It is not a participatory process mfluencmg the project design. Real benefits of EA are not thus accrued Public participation and involvement of NGO is not mandatory in deciding on the project elements Risk management Mandatory under mitigation plan On-site and off-site nsk management plan is an essential part of EIA report EMP and monitoring plan Detailed guidelines are available for No detailed guidelines provided. * institutional arrangements However, EMP and monitoring plan is essential. * implementation schedule * monitonng and reporting procedure * integration of environmental and social cost Review process for EA Process is described but cnteria are not Process is descnbed but criteria are not defined defined (Table continues on next page) 30 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 Cnteria World Bank (OD 4.01) MOEF (Handbook of Environmental Procedures and Guidelines) Post project monitoring Project is monitored only until project Half yearly compliance report is mandatory completion Duration of EA report 6 to 18 months Rapid assessment - 3 months (minimum) preparation and review Detailed assessment - 12 months (minimum) process Review of the report - 3 months Annex 2 Categories of projects requiring environmental analysis The World Bank OD 4.01 (1991) * irrigation, drainage and flood control (large scale), * land clearance and leveling, All Bank-assisted projects are screened at the identifi- * mineral development (including oil and gas), cation stage for environmental impacts and assigned to * port and harbor development, one of three categories: A, B, or C. Bank and interna- * reclamation and new land development, tional experience shows that projects in certain sectors * resettlement and all projects with potentially major or of certain types are normally best classified as illus- impacts on people, trated below and they are by no means exhaustive: * river basin development, * thermal and hydropower development, and * manufacture, transportation, and use of pesticides Category-A classification or other hazardous and /or toxic materials. A project is classified as category A if it is likely to have significant adverse impacts that may be sensitive, irre- Category-B classification versible, diverse, comprehensive, broad or precedent setting and require full EA. These impacts generally A project is classified as category B if its potential envi- result from a major component of the project and affect ronmental impacts are site specific in nature and do not the area as a whole or an entire sector. An illustrative significantly affect human populations or alter environ- list of category-A projects includes: mentally important areas, such as mangroves, wetlands, * dams and reservoirs, and other major natural habitats. Few if any of the impacts * forestry production projects, are irreversible and mitigatory measures can easily be * industrial plants (large scale) and industrial estates, designed. A partial environmental analysis is required, Typical environmental issues of category-A projects * Water impoundment, flooding, and alterations of heavy construction i.e., dams, thermal and hydropower water flows. plants or highways and roads * Change in surface and groundwater quality * Increase in air emissions and solid residues from * Groundwater overpumping, water logging, saliniza- industrial units and occupational health hazards due to tion, reduction of downstream flows. fugitive emissions * Disruption in nverine fisheries from stream flow * Sea-bed disturbances due to laying of oil and gas alterations pipelines and disturbances of cultural resources, benthic * Leaching of soil nutrients, soil erosion. communities, coral reefs, wetlands etc. * Forest clearing, loss of wild lands and wild life * Hazards from gas pipeline leakage or rupture and con- habitats. tamination of groundwater aquifers. * Dislocation of people in affected zones * Chemical contamination from wastes and accidental * Air and water pollution and increase in noise due to oil spills. 31 32 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 curtailed to the particular environmental issues of the pro- obtain environmental clearance from MOEP Besides ject. A typical list of category-B projects includes: this, site specific projects such as mining, pit-head * agro-industries (small scale) thermal power stations, hydro-power, major irrigation * electrical transmission projects, ports and harbors will also have to obtain sep- * aquaculture and mariculture arate site clearance from the GOI or the State govern- * irrigation and drainage (small scale) ments as the case may be. * renewable energy The 29 projects covered by this 1994 notification * rural electrification follow: * tourism 1. Nuclear power and related projects such as heavy * rural water supply and sanitation water plants, nuclear fuel complex, rare earths; * watershed projects (management of resettlement) 2. River valley projects including hydel power, major irri- * resettlement maintenance, and upgrading projects gation and their combination including flood control; (small scale). 3. Ports, harbors, airports (except minor ports and harbors); 4. Petroleum refineries including crude and product Category-C classification pipelines; 5. Chemical fertilizers (nitrogenous and phosphatic A project is categorized as category C if it is unlikely to other than single superphosphate); have adverse environmental impacts, or its impacts are 6. Pesticides (technical); likely to be negligible, insignificant, or minimal and EA 7. Petrochemical complexes (both olefinic and aro- is not required. Typically these projects fall under: matic) and petro-chemical intermediates such as * education department management team, Caprolactam, LAB etc. * family planning and production of basic plastics such as LDPE, HDPE, * health PP, PVC; * nutrition 8. Bulk drugs and pharmaceuticals; * institutional development 9. Exploration for oil and gas and their production, * technical assistance transportation and storage; * most human resource projects. 10. Synthetic rubber; 11. Asbestos and asbestos products; 12. Hydrocyanic acid and its denvatives; GOI notification on environmental impact assess- 13. Primary metallurgical industries (such as produc- ment of development projects tion of Iron and Steel, Aluminium, Copper, Zinc, Lead and Ferro Alloys) and (b) Electric arc furnaces (Mini Any new project or the expansion or modernization of Steel Plants); any industry or project listed below are required to 14. Chlor-alkali industry; Summary of typical environmental issues of category-B projects * Agro-industnes lead to air pollution, solid waste prob- and siltation in dams due to small scale irrigation and lems, water pollution due to discharge of liquid effluents. mini-hydel schemes. * Eutrophication of lagoons and lakes and endanger- * Marginal loss of farm land; water !ogging due to inap- ment of mangroves in the vicinity of fisheries and aqua- propriate road design. culture projects. * Loss of land use and population relocation due to * Loss of forest cover placement of towers and sub-stations in electrical trans- * Submergence of farm land, soil erosion in watershed mission projects Annex 2 33 15. Integrated paint complex including manufacture of to improvement work including widening and resins and basic raw materials required in the manu- strengthening of roads with marginal land acquisi- facture of paints; tion along the existing alignments provided it does 16. Viscose staple fiber and filament yarn; not pass through ecologically sensitive areas such as 17. Storage batteries integrated with manufacture of national parks, sanctuaries, tiger reserves, reserve oxides of lead and lead antimony alloy; forests; 18. All tourism projects between 200 meters to 500 22. Tarred roads in Himalayas and/or forest areas; meters of high tide line or at locations with an eleva- 23. Distilleries; tion of more than 1,000 meters with investment of 24. Raw skins and hides; more than Rs.5 crores; 25. Pulp, paper and newsprint; 19. Thermal power plants; 26. Dyes; 20. Mining projects (major minerals) with leases more 27. Cement; than 5 hectares, 28. Foundries (individual); and 21. Highway projects except those projects relating 29. Electroplating Annex 3 List of World Bank-financed projects by environmental assessment category Number Project Category Sector Fiscal Year 1. Infrastructure Finance (IL&FS) A Infrastructure 96 2 Onssa Water Resources Consolidation A Rural Dev 96 (Water Resources) 3. Bombay Sewage Disposal A Infrastructure 96 4. Tamil Nadu Water Resources Consolidation A Rural Dev. 96 (Water Resources) 5. Madras Water Supply 11 A Infrastructure 96 6 Haryana Water Resources Consolidation A Rural Development 94 (Water Resources) 7 NTPC Power Generation I A Energy 94 8. Pnvate Power Development A Energy 94 9. Renewable Resources A Energy 93 10. Rajasthan Agncultural Development A Rural Development 93 11. Maharashtra Power 11 A Energy 93 12 Gas Flanng Reduction A Energy 92 13. Pnvate Power Utilities A Energy 92 14. Second Petrochemicals A Industry 91 15 Private Power Utilities (11) A Energy 91 16 Cement Industry Restructuring A Industry 90 17. Industrial Pollution Prevention B Industry 97 18 Andhra Pradesh lmgation Ill B Rural Development 97 19. Andhra Pradesh Emergency Cyclone B Infrastructure 97 20. Ecodevelopment B Rural Development 97 21. Uttar Pradesh Rural Water B Rural Development 97 22. Onssa Power Sector B Energy 96 23. Assam Rural Infrastructure B Rural Development 95 24 Madhya Pradesh Forestry B Rural Development 95 25. Financial Sector Development B Finance 95 26. Container Transport B Infrastructure 95 27. Andhra Pradesh Forestry B Rural Development 94 28. Uttar Pradesh Sodic Land Reclamation B Rural Development 94 29 Karnataka Water Supply & Environmental Sanitation B Infrastructure 93 30. PGC Power system B Energy 93 31. Jharia Mine fire Control B Energy 93 32 Bihar Plateau Development B Rural Development 93 33. Rubber B Rural Development 93 34. National Highways 11 B Infrastructure 92 35. West Bengal Forestry B Rural Development 92 36. Power Utilities Efficiency Improvement B Energy 92 37 Maharashtra Forestry B Rural Development 92 38. Shnmp and Fish Culture B Rural Development 92 39 Oil and Gas Sector Development B Energy 92 40 Dam Safety B Rural Development 91 41. Maharashtra Rural Water Supply B Infrastructure 91 34 Annex 3 35 Number Project Category Sector Fiscal Year 42. Agriculture Development I (TN) B Rural Development 91 43 Northern Region Transmission B Energy 91 44 Maharashtra Power B Energy 90 45 Reproductive Health I C Health 97 46 Rural Women's Development C Rural Development 97 47 Tuberculosis Control C Health 97 48. Environmental Capacity Building TA C Environment 97 49 State Road Infrastructure Technical Assistance C Infrastructure 97 50 District Pnmary Education 11 C Education 97 51. Coal Sector Environmental & Social C Energy 96 Mitigation 52. State Health Systems 11 C Health 96 53 Hydrology Project C Rural Development 96 54 Agricultural Human Resources Development C Rural Development 95 55 Andhra Pradesh First Referral Health System C Health 95 56. Distnct Primary Education C Education 95 57. Population IX C Health 95 58 Blindness Control C Health 94 59. Maharashtra Earthquake C Infrastructure 94 60 Forestry Research Education C Rural Development 94 61. National Leprosy Elimination C Health 94 62. External Sector Adjustment C Finance 94 63. Uttar Pradesh Basic Education C Education 94 64 Integrated Child Development Services 11 C Health 93 (Bihar & Madhya Pradesh) 65 Social Safety Net C Health 93 66. Population VIII C Health 93 67 AIDS Prevention and Control C Health 92 68. Structural Adjustment Loan I C Finance 92 69. Health I (MCH) C Health 92 70 Technician Education 11 C Education 91 71. Andhra Pradesh Emergency Cyclone C Infrastructure 91 72. Integrated Child Development Services I C Health 91 (Orissa & Andhra Pradesh) 73. Second Tamil Nadu Nutrition C Health 91 74. Population Training (VII) C Health 90 75. Technician Education I C Education 90 76 Technology Development C Industry 90 77 Family Welfare Training C Health 90 78. Electronics C Industry 90 79 Industrial Pollution Control D Industry 91 80 Watershed Plains D Rural Development 90 81. Watershed Hills D Rural Development 90 82. Hyderabad Water Supply TBD Infrastructure 90 83. Punjab Imgation & Drainage TBD Water Resources 90 Annex 4 Past studies on effectiveness of environmental assessments Considerable experience has been gathered worldwide tional studies reviewed can be found in the References in the application of the EA process both at the project at the end of this document. and policy planning levels. The EA process is consid- ered effective if it has a positive influence on the deci- sion-making process. These positive effects may be in Key findings the form of (a) the project being conducted in a more environmentally sustainable manner than originally The key findings of these studies have been summarized proposed; (b) timely recognition of unacceptable into 'general' and 'specific' to milestones in the project adverse environmental and social impacts leading to cycle. The general findings include the following: modification of the project (e.g., alterations in design, (a) All of the studies cited above recommend the site, route, alignment, choice of raw materials, tech- need for early timing of EA in the project cycle to make nology etc.); or (c) in an extreme situation, cancella- the process more effective. In addition, the need for well tion or postponement of an activity ln addition, a defined review criteria and improvement of the report number of indirect effects such as improvement in leg- quality are the other two major recommendations. islation, streamlining procedures, increase in environ- (b) A questionnaire based study made by Canadian mental awareness, also emerge as benefits of EA. Some Environmental Assessment Agency and International experiences in the form of review studies on effective- Agency for Impact Assessment reported that in 40 per- ness of EA from various sources are briefly described cent of the responses reviewed (out of 324), EA con- below tributed to better decision making. In 38 percent of the cases, it was reported that the EA prevented environ- mental damage and social losses beyond what would Past studies be achieved without assessment. (c) According to both the European Commission stud- Evaluation of the effectiveness of the EA process in ies, public participation and consultation influenced decision making and ensuring sustainable develop- modifications at the pre and post submission phase of the ment has been the focus of several studies and fora EA process. Study on Resettlement and Rehabilitation in globally As part of this review, several studies carried India (World Bank, 1994) noted an improvement in out by the Bank and other national and international quality of project performance since 1990 (after OD 4.3) agencies were reviewed mainly for their (i) key find- due to better interaction between Bank and Borrower. ings; and (ii) criteria used in assessing the effectiveness (d) Despite the above, there are increased concerns of EA. about the cost-effectiveness of the EA process includ- The main focus of the Bank initiated studies has ing the financial, time and administrative burdens. For been on the compliance of the EA with OD 4.01 and example, the World Bank's experience in Indonesia has 4.30; and whether EMPs have been prepared and the shown a lack of coordination between the Bank and the mitigation measures included in the project design. A national EIA implementing agency, BAPEDAL. (World list of World Bank studies and national and intema- Bank, 1995) 36 Annex 4 37 (e) The Canberra, 1994 and the East and South Asia (d) Implementation and supervision EA, World Bank, 1995 studies found that there is a lack * The OED study (June 1996) notes that mitigatLion of an effective public consultation strategy during the plans are not integrated with the Project resulting in entire project cycle, including, public hearing and dis- weak implementation and supervision. closure. G. J. Alearts (World Bank, 1994) stresses a * The Second Environment Assessment Review need for technical guidance in the form of checklists (World Bank, July 1992-1995) found that there is an for task managers for screening, scoping and supervi- ambiguity in definition and allocation of responsibili- sion, based on the observations on the limited projects ties and resources of Environmental Units during in water and wastewater sectors. supervision. * Level of involvement of local technical experts and Key findings "specific to milestones in the project NGOs is found to be inadequate during supervision cycle" include the following: * Careful monitoring needed of the environmental (a) Identification capacity in the Bank to supervise projects subject to EA. * Screening is based more on desk review than on Institutionally, options for carrying out cost-effective lessons learnt from field experiences (Alearts, 1994). environmental supervision are inadequately considered * Scoping has been generally found to be deficient * According to European Commission's Review, there (Delphi, 1994; IAIA, 1994; European Commission's is in general an insufficient use of EAs, and the con- Review). sultations based upon them, in authorizing new pro- * Institutional deficiencies have been noticed in jects. Thus, the lessons learnt from EA are rarely put understanding differences between the Sectoral into policies and strategies. (European Commission's Environmental Assessment and Project Environmental Review, 1993) Assessment methods (Delphi, 1994) (b) Preparation and design * In general, the EA methodologies employed are not Analyzing the EA review criteria used comprehensive and/or appropriate. The steps of pre- diction and assessment of impacts don not use quanti- There is no one set of universally accepted EA review tative framework. (Delphi, 1994, United Nations criteria and each set uses a different framework. A brief Development Programme-MOEF, 1995). summary of some of the reported EA review criteria * Lack of data or lack of access to data has been report- (see References) is discussed below. ed as one of the reasons for poor quality of EA. (Delphi, The World Bank's Second Environment Assessment 1994, European Commission's Review, United Nations Review (1996) makes an overall and direct assessment Development Programme- MOEF, 1995). of the EA report and uses different framework for * There is an absence of integration of social issues in category A- and B-projects. The review uses five attrib- the Environmental Assessment process, including utes i.e., impact assessment; alternatives; public con- indigenous people's involvement etc. (Canberra, 1994). sultation; mitigation plan; monitoring plan; and man- (c) Appraisal, negotiations and loan approval agement plan, and four ratings for category-A projects. The second Environmental Assessment Review of the For category-B projects, five gross ratings are applied Bank notes that: to the entire report. These ratings are described below. * The mitigation and monitoring plans of EAs do not Elkin and Smith study (1988) uses 37 criteria, in the include key environmental performance and impact form of a checklist. These critena are grouped under indicators. nine categories i.e., Administration, Effective Com- * Relevant documents such as staff appraisal reports munication, Identifying Key Concerns, Looking at and legal documents do not reflect sufficiently the EA Alternatives, Collecting Information, Describing Base- findings. line Conditions, Predicting Impacts, Managing and * Loan covenants are general in nature and do not Mitigating Impacts, and Follow up Surveillance and address project specific issues. Monitoring. No aggregation is done over the criteria to 38 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 Category-A ratings for EA work Category-B ratings for EA work Excellent: Work exceeds that required by OD 4 01 and is Full: Analysis close to the level of category-A report. comparable to the best international work, even in the Moderate: Moderate level of environmental analysis, e.g., most advanced countries; mitigation plan or management plan, often in the form an Good: Work fully meets the EA requirements of OD 4.01; annex to the staff appraisal report. Adequate Work barely meets the EA requirements of OD Reference: Refers to studies associated with other projects 4.01 or to existing or planned guidelines, standards, proce- Inadequate: Work does not meet the minimum EA require- dures, regulations, manuals etc.; ments of the OD 4.01 Mininimum: Minimum mention of environment; Zero: Nothing on environment rate the EA report as a whole. This review system was the EA, the methodology of which is however subjec- adapted in the First Environment Assessment Review of tive This review framework was used by the European the World Bank' by developing nine questions based on Commission to evaluate performance of the EA process the categories described above. Fifty-three projects from within eight member states of the EU by reviewing a eight countries were reviewed based on this criteria. total of 112 EA reports. N. Lee and Colley study (1992) uses 52 attributes and Key observations emerging from the analysis of the 7 types of ratings, for communicating quality of the EA review framework used in the above studies are: with non-specialists. These attributes are organized * The review criteria developed by Elkin and Smith over sixteen sub-categories which are in turn grouped (1988) does not have a system of ratings. Hence, it is under four categories as described below. Aggregation subjective in judging effectiveness and in making spe- is done over all the criteria to report overall quality of cific recommendations; Categories and sub-categories Ratings (applied to all fifty-three attributes) 1. The description of the development, the local envi- A. Generally well performed, no important tasks left ronment and the baseline conditions incomplete * Descnption of the development, Site description B. Generallysatisfactoryandcomplete,onlyminoromis- * Wastes sions and inadequacies * Environment Description * Baseline conditions C. Can be considered just satisfactory despite omissions and or/inadequacies 2. Identification and evaluation of key impacts * Definition of impacts D. Parts are well attempted but must as a whole be con- * Identification of Impacts sidered just unsatisfactory because of omissions and/or * Scoping inadequacies * Prediction of Impact Magnitude E. Not satisfactory, significant omissions or inadequacies . Assessment of Impact Significance E Very unsatisfactory, important tasks poorly done or not 3 Alternatives and mitigation of impacts attempted * Alternatives * Scope of effectiveness of mitigation measures NA. The review topic is not applicable or relevant in the * Commitment to mitigation context of EA 4. Communication of results * Layout m Presentation * Emphasis * Non-technical summary Annex 4 39 * The review criteria developed by Lee and Colley (1992) Note does not follow the milestones of the project cycle; and 1. Reference: Effectiveness of Environmental Assessments * The review criteria used by the World Bank (1996) and National Environmental Action Plans. A Process Study, is 'generalized' and lacks structure and objectivity OED, The World Bank 1996 Annex 5 Project information matrix 1. BOMBAY SEWAGE DISPOSAL PROJECT Background Category A, Project Specific Environmental Assessment; IDA credit: US$25 0 million; IBRD loan: US$167 0 million Effective: Mar. 22, 1996. Closing. Dec 31, 2002; Sector: Infrastructure Components A. Physical works: (i) construction of two, 3 km submarine tunnel outfall sewers of 3.5m diameter each to convey partially treat- ed sewage effluent to the Arabian Sea; (ii) construction of a pumping station; (iii) construction of two aerated sewage treatment lagoons; (iv) construction of an influent tunnel; (v) rehabilitation of the existing tunnel; (vi) structural improvements of five exist- ing sewage pumping stations, (vii) conveyance systems improvements; (viii) provision of slum sanitation B Technical assistance for project support and studies on water quality management. C. Studies and detailed engineering for the second stage of the project Environniental impacts/issues as a result of major project activities: * Construction of outfalls: Vibrations due to blasting, nse in ambient noise levels, impairment of air quality near the sites, and locally impaired water quality due to the trenching at the diffuser section. * Construction of lagoons: Major impact is the loss of about 40 hectares of mangrove cover amounting to 5% of total area of mangrove forest. * Operation of outfalls: improvement in coastal water quality by moving waste water discharge points 3 km offshore and eliminating Dissolved Oxygen (DO) depletion along with reduction in nutrient loading. * Operation of the Lagoons: single cell lagoons as planned will arrest further deterioration in creek water quality. An EA was undertaken by National Environmental Engineering Research Institute (NEERI) beginning in September 1991. Social issues. * No R&R requirements for the sewerage works. * Municipal Corporation of Greater Mumbal's (MCGM) response to public concern intiated a program to improve sanitary conditions. * MCGM proposed to do so in those 164 slums which presently occupy municipally-owned lands in order to avoid awaiting resolution of the legal issues arising from public investments on pnvately owned lands, or the costs and delays to be expected from efforts towards their municipal acquisition. Key EMPs Construction/operation of outfalls Construction/operation of lagoons * Construction sites and access roads to be watered twice daily * Mangrove replantation of equivalent area * Noise monitonng * Weekly monitoring of lagoon effluent for BOD, SS etc. * Regular supervision of blasting and dnlling operations * Monthly monitoring of lagoon effluent for metal * Monitonng air quality twice a week. concentrations. * Monitonng at beaches for bacterial and chemical parameters * Seasonal creek monitoring. twice / week. Environmental covenants and compliance as ofJune 1997: * "India to establish revised water quality standards applicable to wastewater discharge to marine coastal waters." Compliance is "not yet due", studies completed. GOI consultations are scheduled forJuly 3/4. Revision expected by 30-Sep-97 * "MCGM to implement the agreed Environmental Impact Mitigation and Monitoring Plan" In "compliance", (Oct. 1996, Supervision. mission) Social"8 covenants and compliance as of June 1997: * "MCGM to apply the policy guidelines for the slum sanitation schemes agreed with the Bank." In "compliance," (Oct. 1996, Supervision mission) * "MCGM to certify to the Bank that the Slum Sanitation policy guidelines have been complied with in all respects for each such scheme." In "compliance", (Oct 1996, Supervision. mission) Note: Social covenants include "Involuntary Resettlement", and "Indigenous People." 40 Annex 5 41 2. PRIVATE INFRASTRUCTURE FINANCE (INFRASTRUCTURE LEASING & FINANCIAL SERVICES (IL&FS)) PROJECT Background: Category A; Project Specific Environmental Assessment; IDA credit: US$5million equiv; IBRD loan US$200 million; Sub-project: Rs.1,500 million; Effective Nov 22, 1996; Sector Infrastructure Components: Assist IL&FS to finance sub-projects such as major bridges, urban bypasses, port facilities, water supply/effluent treatment schemes and integrated area development on a Build-Operate-Transfer basis. A. Investment in the form of line of credit to IL&FS to provide long term finance for construction / operation of commercial infra- structure projects in IL&FS pipeline B Sub-project preparation component for specialized consultancy purposes. C Technical assistance for (i) IL&FS staff development; (ii) specific studies by IL&FS to facilItate the evaluation & implementa- tLion of commercial infrastructure projects This Review focuses on the Gujarat Roads Project, which comprises of widening and strengthening of existing two lane state high- way, will be effective from fourth quarter 1997-98. The Project assists IL&FS in financing infrastructure sub-projects. IL&FS adopted a policyframeworkfor integrating environmental and social issues (the Environment and Social Report approach) Hence, the reportingformat is different and not analyzed in this manner This Review hasfocused on one sub-project i.e. Gujarat Roads, Widening and Strengthening of Vadodara-Halol Road 42 India. Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 3. SECOND MADRAS WATER SUPPLY PROJECT Background: Category A; Project Specific Environmental Assessment; IBRD loan US$275.8 million, Effective Feb 14, 1996; Closing: June 30, 2002, Sector: Infrastructure Components: A. Physical works: (i) source works at the existing Veeranam irrigation tank to the south of Madras; (ii) 235 km, transmission pipeline from Veeranam to Madras, with associated treatment and pumping facilities supplying 180 million liters of water per day; (iii) continuation of distnbution improvements from the First Madras Water Supply project; (iv) water conservation program i.e., leak detection, repairs and tariff increases to encourage efficiency of water use B. Technical assistance in the form of project preparation and implementation support. C. Resettlement and rehabilitation of displaced persons along Veeranam pipeline right of way Environmental impacts/ issues as a result of major project activities: * Source improvement works: impact on ecology of Veeranam lake and surroundings * Improved Veeranamfeeder system: impact on surface water quality * Laying of transmission main, construction of water treatment plant and pumping stations: impact on terrestrial flora and fauna, air quality / noise levels. * The EA was undertaken by NEERI, completed in October, 1994, and submitted to the Bank in February 1995. Social issues: * The number of project-affected persons is 168, including encroachers a total of 1,429, of which 521 will require only reset- tlement, 864 only rehab. and 44 will require both * Most displacement will be along the pipeline right-of-way, already in Tamil Nadu Water Supply and Drainage Board (TWAD) ownership. Key EMPs: Pre-construction phase. * The pipeline ROW selected from three alternatives to minimize land acquisition, R&R, etc. Construction phase: * Minimum damage to existing structures flora, fauna / other infrastructure. * Replantation on areas/periphery of construction. * Ensure unobstructed natural drainage. * Minimize social disruption. * Air quality and noise monitoring Operational phase: * Regular source and treated water quality monitoring once a month. Environment covenants and compliance as of June 1997: * "Carry out provisions of Environmental Mitigation and Monitoring Plan". * "Institute dam safety inspection arrangements for Veeranam tank". Social covenants and compliance as of June 1997: * "TWAD to undertake R&R, implement the RAP and provide prompt compensation and assistance to displaced persons / families". * The latter two covenants will be made redundant by decision to drop the Veeranam pipeline by GOTN. (Oct. 1996, supervi- sion. mission ) Annex 5 43 4. HARYANA WATER RESOURCES CONSOLIDATION PROJECT Background: Category A; Sectoral Environmental Assessment; IDA credit. US$258.0 million, Effective: June 24, 1994, Closing: Dec. 31, 2000; Sector: Water Resources Components' A. Physical Works (i) rehabilitation and modernization of the existing canal, drainage systems, and watercourses, replacement of the Hathnikund Barrage, and construction /extension of minor canals; (iii) upgradation of operation and maintenance of the water distribution and drainage system; B Institutional strengthening to support administration, data collection, planning, design, research, training, beneficiary participa- tion and formation of Water User Associations. (These investments are financed under the areas of the Bhakra Canal and Western Yamuna Canal System of the State) Environmental impacts / issues as a result of major project activities: * Rehabilitation of irrigationfacilities: conservation and increased water use efficiency * Canal/Water course lining: water conservation, better distribution, public health benefit due to better supply * Drainage Programme: flood control benefits, reduction of water logging and soil salinity * Research/training, benefit water resource management, data collection etc. * Hathnikund Barrage economic benefits, minimal disruption of aquatic resources * A Category A-Sectoral EA completed for the project in August 1993 (before appraisal) Social issues: * There are no R&R issues involving movement of families or communities Land acquisition would be limited to narrow strips for realigned canals * Benefits to people provided through increased and assured water supplies for irrigation, agnculture, domestic and livestock related uses Key EMPs. * Notification of works to users/public relations Programme on water conservation * Replanting as appropriate. * Monitoring of water quality impacts * Notification at command area level. * Notification to downstream user groups Environment covenants and compliance as of June 1997. * No environmental covenants Covenant class "management aspects of the project" * "Carry out a socio economic baseline survey related to water resources use, management and service and furnish findings to IDA" (Partially completed) * Select tubewells for rehabilitation as per agreed criteria. (Not yet due) * Select water courses for rehabilitation only after formation of Water Users Association (WUA) of the beneficiaries". (Not yet due) Social covenants and compliance as ofJune 1997. * "Implement a satisfactory land acquisition program" This has been complied with. (Mar 1997, supervision. mission) 44 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 5. ORISSA WATER RESOURCES CONSOLIDATION PROJECT Background. Category A; Sectoral Environmental Assessment; IDA credit: US$290.9 million; IBRD loan: Effective: Jan. 30, 1996; Closing. Sept. 30, 2002, Sector Water Resources Components: A Physical works. (i) scheme completions, for ongoing projects for increased availability / reliability of water; (ii) systems improve- ment and farmer turnover, to improve productivity through rehabilitation / modernization of selected existing irrigation schemes, linked with increased farmer participation; B. Institutional Strengthening. (i) capacity building to introduce multi-sectoral water planning, allocation and incorporation of envi- ronmental management in all aspects of water use; (ii) strengthening Orissa's Department of Water Resources in technical and managerial areas; C Technical assistance: (i) research and agricultural intensification to foster research and technology transfer in the water sector and improved agricultural practices; D. Resettlement and rehabilitation for project affected persons and Indigenous peoples development plan Environmental impacts/issues as a result of major project activities: * SIFT Projects i.e. rehabilitation, of irrigation systems, better O&M: relieve 240,000 hectares of irrigated command area, increase in crop yields * Improved watermanagement: reduce water logging, soil salinity, malaria and water borne diseases. * Scheme completions i.e. Naraj Barrage, Rengali and Mahanadi-Chitrotpala irrigation: ensure flood control, silt reduction, stabilize irrigation systems, marginal loss of forest land * River basin multi-sectoral planning optimum use of water resources, integrate flood control and drought management. * A Sectoral EA prepared in October 1993 initially by Snowy Mountains Engineering Corporation, (SMEC). The report was revised after a review of the issues related to the implementation of the OWRCP Program, in June 1994. Social issues * Resettlement and rehabilitation is required on seven scheme completion sites. * About 1,799 hectares of private lands, 1,680 hectares of government lands (pnmarily unused wastelands) and about 1,636 hectares of forest lands need to be acquired. * About 76% of the land acquired would be due to canal! drainage construction and 24% due to submergence / reservoirs. * About 2,596 persons would be displaced and about 31,207 persons would be affected. * "Orissa State resettlement and rehabilitation Policy" was issued in 1994. * An IPDP has been prepared for six project sites. The total tribal population to benefit from the IPDP Component is close to 57,000 persons. Key EMPs Environment Action Plan Prioritizes: (There is no detailed EMP) * Formation of EA cells, training of EA Staff in DOWR. * State Water Policy emphasizes the implementation of an Environmental Management Plan. This incorporates rehabilitation measures, afforestation, impacts on estuarine/coastal fisheries, salt intrusion, mitigate waterlogging effects. * Institutional strengthening i.e creation of the Water Resources Board to decide about water allocation among water users * Measurement/monitoring-all aspects of surface water hydrology/water quality * Catchment management-watershed mgmt to form part of environment management. To control sediment inflow into reservoirs. Environment covenants and compliance as ofJune 1997. * No environmental covenants. SocialI covenants and compliance as ofJune 1997: * "Carry out resettlement and rehabdlitation in accordance with the resettlement and rehabilitation plan and in a manner and time frame acceptable to IDA". * "Carry out IPDP activities in a manner and time frame acceptable to the Association". * For both the above covenants, comphance status shows "work in progress and to be continued" (Oct. 1996, supervision, mission) Annex 5 45 6. TAMIL NADU WATER RESOURCES CONSOLIDATION PROJECT Background: Category A; Sectoral Environmental Assessment; IDA credit: US$282.9 million; Effective: Dec.14, 1995; Closing: Mar 31, 2002; Sector: Water Resources Components A Physical Works: (i) rehabilitation and modernization of the existing irrigation systems linked with farmers' participa- tion; (ii) scheme completion to complete viable investment on existing schemes for increased availabifily and reliabili- ty of water. B. Institutional strengthening: (i) capacity building to incorporate environmental management in water planning, invest- ment and management; (ii) strengthen Tamil Nadu's Water Resources Organization. C. Technical Assistance to enhance research in the water sector. D. Land acquisition and economic rehabilitation for project affected persons. Environmental impacts/ issues as a result of major project activities: * Rehabilitation, modernization and scheme completion: mitigate against waterlogging, salinization, depletion of ground- water levels and disease risks caused by sources of stagnant water. * Category A Sectoral EA was conducted by Public Works Department/WRO and HR Wallingford consultants (before appraisal). Social issues: * Acquisition of 570 hectares of farmed land involving about 1,460 project-affected persons, i.e., no village residential sites are being relocated. * Needs for project-affected persons catered for, based on socio-economic surveys and Land Acquisition and Economic RAP, undertaken by consultants and WRO with project-affected person participation for each of the scheme completion sites where LAER is involved. Key EMPs: Environment Action Plan Prioritizes: (There is no detailed EMP). * Set up Environment cells for state water planning, allocation and EA. * Unit to regulate groundwater usage. * Consolidation of water data collection. * Establish code of practice incorporating environmental safeguards. * Studies in groundwater use, soil conservation, catchment interlinkages, pesticide impacts, sedimentation, waste water reuse, pollution and health hazards. Environment covenants and compliance as of June 1997: * No environmental covenants. Social covenants and compliance as ofJune 1997: * "Carry out the land acquisition and economic rehabilitation of the project as given under Sch 2, Part E of Development Credit Agreement (DCA) in accordance with a plan agreed with IDA" This is being complied with. (October 1996, supervision. mission) 46 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 7. ASSAM RURAL INFRASTRUCTURE AND AGRICULTURAL SERVICES PROJECT Background Category B; Project Specific Environmental Assessment, IDA credit: US$126 0 million; Effective Aug. 31, 1995; Closing: Dec 31, 2003; Sector Rural Development Components: A. Income generation: (i) fisheries development including fish production, support services and monitoring and evaluation, (ii) horticulture development including strengthening 23 progeny orchards, training and demonstrations; (iii) livestock development. B. Institutional development: (i) technology generation; (ii) education and training; (iii) extension services to include women farm- ers etc; (iv) seed multiplication, (v) land administration. C. Infrastructure development: (i) small scale irrigation, (ii) rural roads improvements; D. Technical assistance to include a number of studies necessary for improving the use of natural resources and the marketing of penshable horticulture products. Environmental impacts / issues as a result of major project activities: * Rice-basedfarming systems. No new land will be cultivated. Consumption of artificial fertilizers is not expected to increase. * Horticulture- directed towards domestic cultivation of pineapple, banana, etc. promotion of integrated pest mgmt and natur- al fertilizers. * Livestock: possible conversion of small areas of waste land / other land to fodder production. Pressure from grazing will be reduced as more animals will be stall fed. Fishenes: loss of existing habitat (less than 2% of total water area), possible loss in biodiversity and change in water quality through overloading with organic matter Rehabilitation of existing fishing places rather than the creation of new ones is proposed * Minor irrigation. withdrawal of more water for irrigation would not deplete groundwater as recharge exceeds the rate of withdrawal. * Rural roads( rehabilitation of existing roads). no significant loss of agricultural land. * The EA camed out is part of the Pre-appraisal Working Paper of July 1994 and the Public Information Report Social issues: * The social focus is on benefits to women as in Assam they play a key role in agnculture. * Improvements in the infrastructure (rural roads), and the production of livestock, fish fruits and vegetables would contribute to women welfare. * Women would also benefit from increascd incomes from milk and fish production * In general, women laborers would benefit from significantly enhanced employment opportunities Key EMPs: * Livestock. research to determine the extent of the problem, find solutions involving the community in their own health man- agement, housing small livestock ie poultry, ducks away from human habitations and recycle the manure they produce; in tea growing areas grass for animals should not be cut from areas sprayed with pesticides. * Fisheries: ensure that breeding areas for wild fish are not lost; leave some vegetation untouched in the water body; env. issues for each rehab. site to be discussed with community members; provide analysis kits for water and soil to farmers to enable them to monitor / control the water quality of their ponds, Pollution Control Board to assist the Dept. of Fisheries in monitoring. * Rural roads. existing, instead of new quarnes to be used to avoid additional dust, noise etc; boulders needed to be extracted from river beds should be done so from shallow depths only, to avoid erosion of the river bed Environment/social covenants and compliance as of June 1997. * No environmental or social covenants, but certain issues covered by "Implementation" covenants. * "Prepare a road maintenance policy, financing arrangements and an implementation plan satisfactory to the Association as a condition of disbursement of credit proceeds for rural road repair and maintenance". Status-Committee is being established and consultant to be recruited, (Mar. 1997, supervision. mission) * "Carry out land acquisition and resettlement and rehabilitation of any people affected under the project in accordance with arrangements and procedures agreed with the Association". No land acquisition is needed to date (Mar. 1997, supervision. mission). Annex 5 47 8. BIHAR PLATEAU DEVELOPMENT PROJECT Background Category B; Project Specific EA (Environmental Reconnaissance); IDA credit. US$117.0 million; Effective: Mar 16, 1993; Closing -June 30, 1998, Sector Rural Development Components: A. Institutional development: (i) agricultural research and technology transfer to aid agricultural development; (i0) support on- farm tnals / demonstrations and training; (iii) strengthen the Minor Irrigation Department (MID). B. Infrastructure development: (i) irrigation facilities development and rehabilitation including better operation and maintenance schemes; (n) rural roads upgradation; (iii) drinking water schemes development and upgradation C Technical assistance to support MID in preparation / supervision work and staff training Environmental impacts / issues as a result of major project activities. * Small scale imgation and mini-hydel schemes. submergence of farm land (less than 20 hectares), soil erosion in watershed and siltation in dams, waterlogging, Socio-env. impacts - health hazards, conflicts on water nghts. Downstream impacts- change in water supply and quality * Dinking water supply (approx 5,000 hand pumps) lack of adequate drainage in the vicinity of wells * Agricultural development: no serious impact except soil erosion and land alienation * Rural Roads marginal loss of farm land; waterlogging due to inappropnate road design * Environmental Reconnaissance Report (prepared by Mariom Ward & Abdul Salam, Ranchi, Bihar, 1991) Social Issues * Benefit about 3.7 million people by increasing their annual average net income from farming alone by 70%. * With imgation and watershed treatment, the cropping intensity would improve by about 30% * Infrastructural improvements would benefit women. * No new activities introduced in the tnbal project area, except ensured representation of tribals in all resource management committees. Key EMPs * Small scale irrigation schemes: conservation practices to avoid soil erosion, people participation in site choice and final design; integrated water resource use strategy to avoid social conflicts; mechanisms for appropnate distribution of benefits among water- shed users; environmental Training. * Drinking water supply: improved design with proper drainage into soak pit to be used to grow trees etc * Agricultural development: continue to emphasize cereal and pulse production to improve nutrition level of people, irngation development to be tailored to agncultural technology; soil erosion and moisture retention control by adopting the watershed development approach; NGO help in solving land alienation problems. * Rural Roads: prioritization based on new road access to minimize land acquisition, appropriate design standards to avoid water- logging etc. Environment covenants and compliance as ofJune 1997: * No environmental covenants. Social covenants and compliance as ofjune 1997: * "Make arrangements satisfactory to Association for resettlement and rehabilitation of displaced persons". (Compliance is "not yet due", April/ May 1997, supervision. mission) Other covenants of relevance: Management aspects of the project or of its executing agency: * "Transfer O&M responsibilities of drinking water facilities to village Panchayats" (Not complied with, out of 6,800 tubewells, not one has been transferred to user groups, due to lack of maintenance capability at field level. ApriU May 1997, supervision. mission) * "Transfer ownership and responsibility of O&M of irrigation schemes to Panchayat and WUC". (Not complied with, April May 1997, supervision, mission) * "Implement criteria satisfactory to Association for selection of roads". (Complied with partially, some roads do not meet Bank specified cnteria ) 48 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 9. SHRIMP AND FISH CULTURE (B) Background: Category B; Project Specific Environmental Assessment; IDA credit- US$85.0 million, Effective- May 28, 1992; Clostng. June 30, 1999; Sector: Rural Development Components A Institutional and infrastructure development: (i) Brackish water shrimp component located in the states of West Bengal, Orissa, and Andhra Pradesh, representing about 80% of the project cost. Its benefits would be significant both in terms of foreign exchange earmings and income to the beneficianes; (ii) Inland fisheries component located in West Bengal, Orissa, Andhra Pradesh, Bihar and Uttar Pradesh representing about 8% of project cost, requires very little infrastructural cost, with the majority of investments associated with the stocking of water bod- ies and the provision of support equipment and services, B Technical Assistance : project management including environmental management and training representing about 12% of pro- ject cost, with a greater emphasis on the shrimp component. Environmental impacts/issues as a result of major project activities: * Meendwip Island site. in W Bengal endangers the mangrove vegetation in the vicinity. * Pond and infrastructure development: loss of forest cover. The location of the site is near the Indian Oil Company refinery dis- charging hydrocarbon restdues into the estuary, dredging would disturb sediments on the river bottoms which may contain pol- lutants. * Interu site in Andhra Pradesh (300 hectares site to be developed into a prawnfarm), would lead to the eutrophtcation of the lagoon, eventually resulting in poor pond water quality. * Inlandfishenes component is not expected to have a significant environmental impact. The main area of possible negative impact relates to the eutrophication of ox-bow lakes * Environmental Assessment Report was prepared by Tropical Research & Development, Inc., USA and a team of local experts in 1991. Social issues: * Provision for joint ownership of husband and wife, under the shrimp component, enabling sharing of moneys earned. * Training programs to include women from the earliest stage. * While the physical division of labor would continue, with women forming at least 30% of cooperative membership, they would be economically better off. Women would also be eligible to participate as small entrepreneurs to receive credit to set up rearing ponds and manage pens and cages owned by the cooperatives Key EMPs Meendwip island site. * Afforestation/regeneration of equivalent area of mangrove * Assay for heavy metals in shrimp tissue semi-annually Biderpur site: * Construction of sluice gates to allow drainage of agncultural water through the shrimp farm dikes. Internu site * Study by Central Institute for Coastal Engineering and Fishenes of the lagoon hydrology at Interu. Awareness programs. * Environmental monitoring programs of the three states in shrimp component Training in conservation techniques for prawn seed collectors to reduce mortality of the catch Environment covenants and compliance as ofJune 1997: Environmental: * "Each state shall carry out such mitigatory actions satisfactory to the Association as required for preventing, reducing or elim- inating the potential negative effects of the project on the environment". Not complied, no environmental monitoring plan in oper- ation due to delays in contracting for this work. (Dec. 1996, supervision. mission). Social covenants and compliance as ofJune 1997: * No social covenants. Annex 5 49 10. GAS FLARING REDUCTION (A) Background Category A, Project Specific Environmental Assessment; IDA credit US$350 million; Effective July 12, 1991; Closing: June 30, 1997, Sector: Energy Components A. Physical works (i) Erection of two process platforms; (ii) construction of three submarine pipelines; (iii) expansion of the exist- ing gas terminal at Hazira to process additional gas supplies, nearly doubling the current capacity of the terminal B. Technical assistance: (i) provide support for a reservoir study of the Bombay High Oilfield aiming to optimize oil and gas pro- duction and reduce the chances for the recurrence of excessive gas flaring; (n) implementation of a package of measures to reduce environmental risks and enhance the safety of offshore operations Environmental impacts / issues as a result of major project activities. * Overall positive environmental impact. Improve the facilities that currently exist, such as worker safety and emissions from flared gas. * Construction ofprocess platforms: very limited disturbances of the sea floor during location sampling and platform siting Possible env nsks from generated liquid effluents like sewage and deck drainage during operations * Construction of gas pipelines very limited disturbances of the sea floor. Localized occupational health issue due to exhausts from the large power drivers and combustion of gas flaring. * An Environmental Assessment (EA) was prepared in 1990 by the NEERI in Nagpur, India, and sponsored by the Borrower, the ONGC Social issues: * Beneficial socio-economic impacts. the utilization (instead of waste) of an important energy source and the increase in employ- ment * Setting up a new oil processing terminal at Usar vis-a'-vis designing a pipeline system to the existing terminal at Hazira, the former was rejected since it had environmental as well as land acquisition / social implications which would result in delays in the project implementation. Key EMPs Mitigation measures are incorporated in the Env. Component of the project * Safety engineenng study for the existing platfonms to be linked to the facilities to be constructed. * Staff training in safety and environmental engineenng, * Strengthening current arrangements for rescue of persons at sea. * Expansion of ONGC current capacity to combat oil spills * Enhance ONGC capability to monitor the environment impact of its operations especially on manne ecosystems Implement the environmental monitoring program of all ONGC operations * Strengthen ONGC to deal with risk fires through the design of flares and nsk assessment studies. Environmental covenants and compliance as of June 1997: Environmental * "ONGC to obtain environmental clearance for all components of the proposed project". Complied, (Feb. 1997, supervision mission) * Relevant covenant under class -"Monitonng, review and reporting" "ONGC to carry out a safety engineenng study of existing platfonns linked to facilities that will be constructed under the project and safety audit for its entire offshore operations". Complied, safety engineering study completed in October 1991; safety audit completed in Dec. 1993; recommendations reviewed by the Bank and is being implemented by ONGC. (Feb. 1997, supervision mission) Social covenants and compliance as of June 1997: * No social covenant 50 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 11. NTPC POWER GENERATION (A) Background: Category A, Project Specific Environmental Assessment; IBRD loan- US$400 million, Effective-Jun. 6, 1994; Closing - Sept 30, 1997; Sector Energy Components A. Physical works: (i) generation capacity additions for Stage 11 expansions of the Rihand and Vindhyachal thermal power plants. B. Institutional strengthening: (i) support NTPC to undertake joint venture operations; (ii) strengthen its environmental and reset- tlement and rehabilitation management capability C. Technical assistance (i) environmental strengthening and resettlement and rehabilitation component which includes upgrad- ing environmental performance of NTPC power stations; (ii) implementation of an Environment Action Plan which includes envi- ronmental upgrading of projects, training and technical assistance Environmental impacts / tssues as a result of major project activities: Rihand 11 & Vindhyachal ll * Construction phase: increase in suspended solids in water, dust and NOx concentration in air; soil erosion. * Operation phase. coliform in open wells, toxic metal contamination in groundwater, suspended solids from plant effluent; hot water discharge into lake; acidic/alkalne effluent; nitrogen oxides (NOx), sulfur dioxide (S02), particulate matter in ambient air. * Full EAs were carried out for Rihand 11 and Vindhyachal 11, by NTPC in April 1993. Social issues: * Resettlement and rehabilitation of persons displaced by the construction of new power stations. Remedial programs which mitigate the effects of deficiencies in R&R from earlier NTPC projects. Rihand 11: * Total land acquired is 720 acres, out of which 223 acres is forest land,2 villages have been affected with a total of 121 Homestead oustees, of which 18 still remain to be settled. Out of a total of 191 project-affected persons, 38 still remain to be rehabilitated. Vindhyachal I. * Total land acquired is 1,165 acres. No forest land was acquired. 4 villages have been affected with a total of 384 Homestead oustees, of which 207 still remain to be settled. Out of a total of 824 project-affected persons, 247 still remain to be rehabilitated. Key EMPs: Construction phase- * Neutralization pit to be provided. * Temporary sedimentation tank. * Effluents treated in sedimentation tank * Sprinkling of water in construction * EMPs to limit emissions of suspended particulate matter * Revegetation after construction to 100mg/m3 (Bank standard) Operation phase: * Water blanket over entire ash pond. * Promotion of hand pumps in resettlement colonies. * Tall stacks (275 meters high) for wider dispersal of SO2 * Cooling towers to cool the effluent. and NO,. Environmental strengthening / resettlement and rehabilitation component of the project would fulfill the key objectives and imple- mentation of an EAP which includes environmental and implementation of an EAP which includes environmental upgradmg, training and technical assistance for strengthening NTPC's environmental and R&R management capability and the implementa- tion of the EAP Environmental covenants and compliance as ofjune 1997: * "NTPC to implement the Environment Action Plan dated May 10, 1993, as agreed with the Bank". Complied partially (March 1997, supervision. mission). Social covenants and compliance as ofjune 1997: * NTPC to implement the Rehabilitation Action Plan in respect of each of the projects to be financed as agreed with the Bank". Complied partially (March 1997, supervision. mission). * "NTPC shall (i) carry out socio-economic survey not later than Dec. 31, 1994 to ascertain the present socio-economic status of persons affected by the on-going projects of NTPC, (ii) based upon such surveys, draw up wherever necessary remedial action programs in consultation with the Bank, (iii) implement such action programs". Complied by Dec. 31, 1994 (March 1997, super- vision. mission). Annex 5 51 12. INDUSTRIAL POLLUTION PREVENTION PROJECT Background Category B, No Environmental Assessment, IDA credit. US$330 million, Effective: Mar. 1, 1995, Closing Mar. 31, 2001, Sector Industry Components A. Institutional strengthening of the State Pollution Control Boards in Rajasthan, Madhya Pradesh, Karnataka and Andhra Pradesh. B. Technical Assistance (i) establishment of a "clean technology institutional network" to promote transfer of technologies with environmental benefits for industry; (ii) services for identification of waste minimization and abatement methods for small scale industry; (iii) pre-investment studies for Common Effluent Treatment Plants, Industrial Waste Water Recycling Plants and other waste min- imization facilities; (iv) finance for other training and consulting services planned by the Ministry of Environment and Forest, including trainingfor the preparation of environmental statements by industries. Environmental impacts/lssues as a result of major project activities. * Overall beneficial environmental impacts. * Amelioration and prevention of environmental issues in the industrial sector. * Involves the introduction of cleaner technologies, which are associated with : (i) waste minimization; (u) higher productivi- ties and yields that in turn reflect in reduced volumes of by-products; and (ii) improved energy efficiencies that are expected to lead to a reduction in the emissions of pollutants. Social issues' * For installation of most individual waste water treatment units, no land acquisition will be involved * The appraisal mission will confinm that the procedures to be followed in case of any land acquisition are consistent with Bank requirements, including the provision for public hearings pnor to sanctioning of credits which may raise legitimate public con- cern. * There are no other social issues anticipated. Key EMPs: No EMP, as the project finances sub-projects through financial intermediaries Environment/social covenants and compliance as ofjune 1997 * No environmental or social covenants. * Relevant covenant under class - "Implementation" * "Institutional strengthening plan for State Pollution Control Board." Covenant complied with (Feb 1997, supervision mission) 52 India: Review of the Effectiveness of Environmental Assessments in World Bank-Assisted Projects, Fiscal 1990-97 13. SECOND PETROCHEMICALS DEVELOPMENT PROJECT Background Category A; Project Specific EAs for Nagothane and Vadodara; IBRD loan US$245 million; Effective. Dec.18, 1990 Closing: Sept 30, 1997, Sector Industry Components: A. Physical works: (i) expansion of the Maharashtra Gas Cracker Complex from 300,000 to 400,000 tons per year; (ii) setting up the second phase, 12,500 tpy wire / cable polyethylene compounding unit in Nagothane; (iii) establishment of a new 7,500 tons per year engineering polymers processing facility; (iv) setting up of a new 60,000 tons per year polyproylene plant; (v) revamp- ing and expansion of IPCls butadiene extraction and poly-butadienne rubber manufacturing complex in Vadodara to 50,000 tons per year; (vi) implementation of modernization schemes at the Nagothane and Vadodara complexes, B. Technical Assistance (i) training and analytical equipment for Central Institute of Plastic Engineering and Technology, (ii) mar- ket development for planning preproduction imports of polymers. Environmental impacts/issues as a result of major project activities. * Vadodara. expansion of the three units and the implementation of the engineenng polymers plant will result in an increase in the level of wastewater discharges, emission of airborne pollutants and generation of solid residues. * Nagothane. increase in production & cracking capacity will lead to increased emissions of airborne pollutants and waste water discharge, increase in transportation and the addition of the third line in the HDPE/LLDPE plants leads to marginal increases of fugitive emissions and volatile organic chemicals. Social issues. * Vadodara: no land acquisition as the three expansion projects will be located within the existing complex. * Nagothane: about 3 villages affected major occupation being semi -agncultural activities. Total population is 2,153. These peo- ple have been rehabilitated on the South side of the complex as per the guidelines laid by the government. Key EMPs: Vadodara * Hazardous emissions warming system * Laboratory testing for effluent characteristics. Nagothane: * Measures to prevent leakage, minimize waste production, recirculation of waste and separation of pollutant streams. * Monitonng of air and water quality * Tree plantation Environment/social covenants and compliance as ofJune 1997: "IPCL carry out safety audit of Nagothane and Baroda complexes". (Covenant type-Maintenance & operation, Compliance sta- tus is OK, as per mid term review supervision mission.) Annex 5 53 14. STATE HEALTH SYSTEMS DEVELOPMENT 11 PROJECT Background Category C, No Environmental Assessment required; IDA credit. US$350.0 million, Effective: June 27, 1996, Closing Mar. 31, 2002; Sector Health Components: Implementatlon of project is in Karnataka, Punjab and West Bengal A. Institutional strengthening (i) develop a surveillance capacity for major communicable diseases, (ii) improve service quality access and effectiveness at the first referral level i.e., upgrade community / subdivisional and district hospitals, upgrade clinical and support services; (in) improve access to primary health care in remote and underdeveloped areas i.e , upgrade primary health centers in the Sunderban area of West Bengal and increase access to pnmary care services among the scheduled caste / scheduled tribe population in Karnataka Environmental impacts/issues as a result of major project activities * Medical waste disposal and management has been addressed, by improving which nsk of affecting human health or the envi- ronment would be minimized. * Inappropriate management could cause transmission of HIV/AIDS, Hepatitis B/C virus, through injuries caused by syringe nee- dles or sharp instruments infected by contaminated human blood. * Hospital water sewage could also transmit some diseases such as cholera to the surrounding neighborhoods Social issues * Risks to scavengers and handlers of medical waste. * Benefits in the form of improved hospital services in Karnataka, West Bengal and Punjab and the scheduled tribe population of West Bengal. Key EMPs: EA / EMP not required for Category-C projects. However medical waste management has been addressed in * First phase (Short term): reduction in hazards by segregating clinical waste, on-site storage to remove scavenging * Second phase (medium term ): fuller segregation and on-site treatment like needle crushers * Third phase (ong term): development of management systems from cradle to grave, implementation of clinical waste manage- ment plans and training. * The proposal to procure incinerators has been put on hold until all options are clear as per phase Ill of the plan. Environment/social covenants and compliance as of June 1997: No environmental or social covenants or any other that address the management and disposal of medical waste Bibliography Alearts G. J. 1994. "Water Supply, Wastewater and Sanitation Lee, N. and Colley. 1992. Reviewing the Quality of Projects. A Review of Environmental Assessment in Asia Environmental Statements. 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Environmental Assessment Source Book Vol. 2. and Training Manual Vols. I and II." Training workshop on Washington, D C.: World Bank. Environmental Impact Assessment and Evaluation. . 1991. Environmental Assessment Source Book Vol. 3. GOI/ADB/ESCAP New Delhi, India. Washington, D.C.. World Bank. Gonzalez, M. 1995. "East and South Asia Environmental . 1994. "Resettlement and Rehabilitation in India: A Assessment Consultation Review." World Bank. Washington, Status Update of Projects Involving Involuntary Resettle- D C ment." World Bank, Washington, D.C. Kjorven, Olav 1996. The Impact of Environmental Assessment: the . 1996 "Effectiveness of Environmental Assessments World Bank's Expenence: Second Environmental Assessment and National Environmental Action Plans A Process Study" Review. Washington, D C. . Land, Water, and Natural Habitats Operations Evaluation Department, World Bank, Division, Environment Dept., World Bank. Washington, D C. 54 The World Bank 1818 H Street, N.W. Washington, D.C. 20433 USA 202/477-1234 - 202/477-6391 MCI 64145 WORLDBANK MCI 248423 WORLDBANiK www.worldbank.org books@worldbank.org * ... ......I