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4. ENVIRONMENTAL MANAGEMENT GUIDELINES

4.1 General

This EMP includes specific management activities that will be followed for ensuring that any Category B type project (e.g. an agro-processing enterprise) that results from on-lending by a PFI receives an appropriate environmental assessment. The responsibility for recognizing the environmental category of loan applications rests with the loan officers of the various lending institutions.

4.2 Management

The PMU within the SAAC of the Ministry of Agriculture will be responsible for overall Project implementation. The Project in general will be regularly supervised by the World Bank task team. At the beginning of the project the PMU will hire a full time Environmental Specialist to ensure implementation of the Project in compliance with the EMP. The individual must be able to recognize an activity for which a loan is being sought that may fall into Category A, B or C of the World Bank and ensure that the EMP guidelines are followed. The same consultant will maintain a working relationship with the relevant officers in the DoSEE of MENR and the relevant environmental inspectorates. As well, this individual will have a working relationship with the PFIs and provide assistance in cases where determining the category of a particular activity that has been proposed for financing may be in question.

4.3 Mitigation

Mitigation of any environmental effects will be the responsibility of the activity proponent. However, it will also be the responsibility of the SEE, VCDS, PFIs and the PMU to ensure that mitigation is carried out successfully for sub-projects of Category B and some sub-projects of Category C as it might be required. This responsibility will be reflected in an effectively established monitoring system. Tables A-3.1 and A-3.2 (Annex 3) provide suggestions for agricultural good practices and non-agricultural rural activity good practices which, if followed, will prevent many of the potential impacts from occurring.

Most mitigation for the various activities that have been suggested as likely candidates for financial support can be conducted through the application of best practices. Often it is a choice of how an activity is conducted – between the right way and wrong way with little, if any, additional cost to the activity’s proponent. However, often the proponent will not be aware of an approach that will minimize the environmental effects. The advisory services sub-component of the Project will have an important role to play in directing farmers and agribusinesses towards best practices in order to eliminate or reduce environmental impacts as these are related to the various farm inputs that would be sought through the grant and credit program. For example, if a borrower has purchased a tractor, cultivating with the contour as opposed to against the contour will significantly reduce erosion.

Mitigation Plans for each of the 10 potential subprojects are presented in Tables 7A-1 to 7A-10 in Annex 7. A format for a mitigation plan is attached at Annex 2 (Table A-2.3)

4.3.1. Recommended Preventive Actions or Mitigation Measures for Laboratory

Good international practice emphasizes preventive actions in order to avoid these potential risks by employing good housekeeping, general cleanliness and diligent laboratory and medical waste handling and disposal procedures based on international best practice guidelines (see Annex 8). Currently the laboratory is not in full compliance with good practice. The revised procedures, once they are put in place and implemented, should help ensure (i) the health and safety of laboratory personnel and (ii) the protection of the general public.

A training program will be designed with the help of experienced local and/or international Consultants to demonstrate how in employing these procedures the proper handling of potentially hazardous, noxious or toxic materials and waste will be ensured. To the extent feasible, laboratory staff at the appropriate level should also be included in this training program, so that they understand the human health and environmental implications of laboratory waste management.

Chemicals and laboratory equipment which are disbanded, dismantled or disposed off during rehabilitation works will be strictly separated and disposed appropriately in coordination with the MoA.. Directions for laboratory waste management according to international good practice are listed in Annex 8.

Environmental management during laboratory operation: For the operational of laboratories a number of international best practice guidelines exist, such as

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  The environmental management guidelines for small laboratories (US-EPA, May 2000); http://www.epa.gov/sbo/pdfs/smalllabguide_500.pdf, or
  
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  Safety and Environmental Management Requirements for Operating Laboratory Facilities at the University of Maryland; http://www.des.umd.edu/ls/pi_requirements.html
  

These guidelines cover air emissions, aqueous discharges, hazardous and non-hazardous wastes, biologically active substances and wastes (which may contain pathogenic organisms), emergency planning and community information, toxic and hazardous materials storage, handling and management, drinking water management and sustainable practices in some detail.

4.4 Monitoring

Monitoring of all activities within the Project will be the responsibility of the PMU. The PMU Environmental Specialist will be undertaking regular monitoring of the project activities, identify any environmental issues, suggest solutions and timing and ensure follow up. As to the sub-projects, with the potential of hundreds of small farm loans it will not be feasible to monitor all of them on regular basis. The Environmental Specialist will need to select sampling individual activities within categories of activities for regular monitoring purposes. A number of activities will be environmentally benign and as such will not require monitoring on a regular basis. Nevertheless, they should be examined on occasion to ensure that this EA did not overlook any potential impacts. Rural enterprise activities should be monitored regularly on a random sample basis. A checklist for random sampling monitoring is attached in Annex 5. Preliminary Selection of Monitoring Indicators for each of the 10 potential subprojects are presented in Table 4.1

The PMU Environmental Specialist will develop a monitoring procedure and schedule. It will be important that for each category of activity that indicators upon which to base monitoring are identified. However, in reality it will be impossible to collect base line information, particularly since the Project is not site specific and investment applications can come from anywhere in the country. Indicators may be quantifiably measurable or they may be measured subjectively. Some indicators will require precise measurement, for instance in the case of the water quality indicator to measure the effects of effluent discharge from an agro-processing facility. In the case of fertilizer application on individual small holdings, and the effects on downstream aquatic systems, monitoring will be extremely difficult if not impossible. The real concern might be the cumulative effect on important downstream systems and in catchments where a significant number of loans have been made for fertilizer purchase, monitoring of system health may have to be done on a qualitative basis. For this case, observation of the presence of superfluous downstream aquatic plant growth may be the only indicator available, otherwise monitoring will be almost impossible and certainly determining the extent of impact attributed to farmers receiving loans vs. other external causes of the impact will be impossible.

Overuse of fertilizers may lead to accumulation of some nutrients downstream in rivers. Fertilizer use can be monitored, and to mitigate this, based on soil type, fertilizer is applied on the basis of soil fertility coupled with crop requirement. This kind of nutrient leakage is the “Non-Point” sources of pollution.

From an environmental viewpoint, those groups of projects which have the potential for creating the most serious environmental problems should be given highest priority for sampling The findings of the monitoring visits should be summarized in monitoring reports which will also provide for specific recommendations on the actions to be taken, if necessary, to address environmental concerns identified by the monitoring.

Table 4.1: Preliminary Selection of Monitoring Indicators

Sub- project	Indicator	Baseline
Laboratory Testing	Quality of waste water Amounts of disposed wastes Safety and health of record of employees	Current level of chemical inputs Current waste generation data
Veterinary services	Amounts of chemical inputs	Current level of chemical inputs
Seed testing	Water consumption per production unit	Current level of water consumption per unit
Fertilizer	Water quality Soil quality	Current surface water quality Current soil quality
Pest management/ Pesticides	Water quality	Current surface water quality Current level of pesticides application
Plant production technologies	Soil productivity Water quality	Current soil productivity Current surface and groundwater quality
Livestock production technologies	Water quality Pasture productivity	Current surface water quality Current pasture productivity
Slaughter houses	Quality of waste water	Existing standards
Primary Processing	Energy rate	Current energy rate
Storage facilities	Use of fumigants	Current level of chemical inputs

4.4.1 Monitoring plan

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  The PMU Environmental Specialist will review the quarterly activity reports submitted by the VCDS and PFIs, and will conduct random sampling review of 10% of grants and small and medium credit applications every 6 months to verify compliance with the EMP, including pesticide use. Review of the sub-projects selected for the random sampling will be based on (i) in the case of the credit line on the environmental screening sheet provided by the PFIs on each loan; and (ii) in the case of grants on the environmental screening sheet provided by the VCDS on each grant. The review should include a visit to the activity site, an interview with the applicant, and a consultation with the regional environmental authorities. In sub-projects selected for environmental monitoring, a typical environmental monitoring plan would be prepared as shown in Annex 5.
  

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  The PMU Environmental Specialist will be responsible for monitoring of the use of authorized pesticides by borrowers and grant beneficiaries as part of the regular monitoring for compliance with the EMP.
  

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  Based on the sub-project activity reports, site visits, data on pesticide sales, and information from local environmental authorities, the PMU environmental specialist will analyze pesticide use by rayon to determine whether purchases under ADCP-3 investments has increased, potentially creating cumulative impact. If this occurs, ADCP-3 may suspend lending that include pesticide purchases of products falling in Class Ia, Class Ib, and in some cases, even WHO Class II.
  

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  The PMU Environmental Specialist will review plans for training and advisory services to ensure that IPM, pesticide safety, storage and handling and other sustainable agricultural practices for farmers and agro-business personnel are included, and that environmental due diligence for VCDS and PFI staff is addressed.
  

The PMU Environmental Specialist will work in cooperation with the project M&E specialist to integrate monitoring of EMP implementation into the overall project M&E design.

4.4.2 Environmental monitoring of long term issues

The Ministry of Environment and Natural Resources and its local agents will decide on measures to monitor the long-term effects of activities that could have negative environmental impacts. This may include monitoring by its staff, or by specialists contracted to undertake specific monitoring duties. Typically this may include:

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  Monitoring effluents from production units and factories, and monitoring the water body into which effluents discharge, to ensure no negative impacts
  

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  Monitoring air quality in and around mills to ensure compliance with air quality standards
  
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  Monitoring soil/water conditions in and around chemical and fuel storage depots and chemical mixing plants to ensure no negative impacts
  
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  Monitoring forestry and large scale farming operations to ensure the ecology is being maintained (run-off and erosion)
  
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  Monitoring wet-lands or areas of scientific, natural or historic interest where they may be affected by the project
  

Special environmental studies may also be called for in the event of sudden environmental change near to a sub-project activity. The frequency of monitoring and type of samples analyzed would be dependent on the nature of the pollutant.

Bank supervision missions will include an environmental specialist to audit monitoring procedures and results. The specialist should assess one or two loan activities where impacts are likely to occur in order to ensure compliance.