4.0 Environmental Management Plan

Environment Management Plan should include:

· Delineation of mitigation and compensation measures for all the identified significant impacts

· Delineation of unmitigated impacts

· Physical planning including work programme, time schedule and locations for putting mitigation and compensation systems in place

· Delineation of financial plan for implementing the mitigation measures in the form of budgetary estimates and demonstration of its inclusion in the project budget estimates.

4.1 Identification of Significant or
Unacceptable Impacts Requiring
Mitigation

The impact is significant or unacceptable if, emission/discharge load and characteristics or the resultant environmental quality are in violation or exceed.

· Ambient Environment Quality Standards / Acts (Box 4.1)

· Policies of government or statutory bodies (Box 4.2)

· Compliance with the International obligations

· Assimilative capacity of the region

Box 4.1

Ambient Environmental Quality Standards/Acts

· National Ambient Air Quality Standards · Ambient Noise Standards · Classification of Inland Surface Water · Indian Standards/ Specifications for Drinking Water · Indian Standards for Industrial and Sewage Effluents Discharge · General Standards for discharge of Environment Pollutants	Environment (Protection) Rules, 1986 Environment Protection Act (Central Pollution Control Board) No. 29 of 23-5-1986 Central Pollution Control Board Standards IS 10500-1983 IS 2490-1982 Environment (Protection) Rules, 1986, Schedule VI/ Standards Prescribed by SPCBs
Where standards are not prescribed in India, the following may be referred
· Damage criteria for heat load and pressure wave	Dept. of Industrial safety, The Netherlands
¨ Risk acceptance criteria	Organisation for Applied Science and Research (TNO), the Netherlands
¨ Damage Risk Criteria for Hearing Loss	Occupational Safety and Health Administration (OSHA) of USA

In addition, reviewer should use his/her judgement to decide whether the deviation from prescribed environmental standards if any, is marginal or significant keeping in view the implicit goals and targets articulated in various policies documents.

In case the magnitude or intensity, or extent or duration of the impact is uncertain or nonspecific, the necessary mitigation measure for such an impact need to be provided, otherwise the impact may be classified as unmitigated impact.

The comprehensive list of identified significant impacts should be verified with community's perception during public hearing process.

Box 4.2 Government Policies

(Illustrative List)

· National Water Policy, 1987 (Prioritization of Water Uses)

· National Landuse Policy, 1988 (Protection of land under cultivation and suitable for agriculture)

· National Forest Policy, 1988 (Protection) and Conservation of Forests)

· Policy Statement for abatement of Pollution, 1991
(Environment Management Strategy)

· Industrial Policy 1991

· National Conservation Strategy and Policy Statement on Environment and Development (1992)
(Sustainable Development

· National Rehabilitation and Resettlement Policy (Draft)

· National Mineral Policy 1993

4.2 Mitigation Plans and Relief &
Rehabilitation

The mitigation plans for control of adverse impacts arising out of developmental activity should address the following:

Technological Measures

Technological measures are to be specified to mitigate the impacts in each phase of the project. The mitigation measures need to be stated separately alongwith emission and waste reduction for each phase and under the following strategy categories:

· Pollution prevention

· Waste/minimization

· End-of-the-pipe treatment technology

· Attenuation in the source-receptor pathway

· Protection of the sensitive receptors

· Mitigation Measures (onsite & offsite) to minimize risk

The reviewer, in this step would assess the effectiveness of mitigation measures suggested. Guidance to the reviewer to verify the efficiency and effectivity of mitigation measures is in Annex XI.

The EIA should contain a 'commitment list' summarizing all mitigation proposals with explicit mention of organizations responsible for implementation and regulation. The list should provide details on what mitigation are intended to achieve; why it is assessed to succeed and the consequence of failure, if any.

Physical Planning

Physical plans address formulation, implementation and monitoring of environmental protection measures during and after commissioning of the project.

It is important to verify the inclusion of the following points in the EMP for checking the completeness and adequacy of the Physical Plan

· The listing of devices for pollution control, prevention and attenuation; and receptor protection to be put in place; their specifications, efficiency and cost. (it is recommended that such a listing be provided for each stage of the project and significant impacts separately. The physical facilities specified in Disaster Management Plan also need to be covered).

· The Schedule of project implementation dovetailed with proposed environmental management measures.

· The proposed layout plan of facilities dovetailed with requirements for Environmental Management and Disaster Management Plans.

Human Resources

The Human Resources Plan for implementation of Environmental Management should include staffing, training, awareness, preparedness and institutional strengthening requirements. For demonstration of due diligence it is important to present the Human Resources Plan as in the Box 4.3.

The salient issues that need verification by the reviewer are whether:

· the skills required for effective implementation of mitigation plans are identified

· the organizational chart for implementation of mitigation measures with roles and responsibility is provided

· the provision for financial resource allocation for supporting the human resources is made the responsibilities of operation and maintenance and provision for preventive maintenance are specified.

Financial Planning

The Financial Plan should necessarily include the annual expenditures for the next five to ten years for implementation of Environmental Management Plan clearly indicating the assumptions regarding cost escalation, operation and maintenance costs of devices and the life-time of devices. The Financial Plan may be organized as per MoEF Questionnaire.

The Expenditure forecast provided in the Financial Plan of EMP may be verified for its inclusion in the Detailed Feasibility/Project Report of the Project.

The salient issues that need verification by the reviewer are whether:

· the cost of mitigation measures and flow of investments based on schedule of implementation of mitigation measures are delineated

· the costs of maintenance and operation throughout its life time are specified

· documentation of evidence of inclusion of such costs in the project planning is demonstrated

· adequacy of financial resource allocation is demonstrated through a cash-flow chart.

4.3 Stipulating the Conditions

After reviewing the ‘commitments list’ which is not explicit in the present EIA practice, the Impact Assessment Agency draws as approved list of ‘conditions’ which include mitigation and compensation measures as also monitoring requirements for the proponent.

4.4 What should be monitored?

· Stipulated conditions

· Implementation of EMP

· Priority should be given to specific condition(s) related to the project

· Issues raised in the Public Hearing

4.5 Monitoring Methods

The monitoring methods for environmental parameters are already outlined. However, it is of relevance to take note of the fact that the monitoring of clearance conditions is targeted towards validating the assumptions in impact identification and prediction; and demonstrating effectiveness of mitigation measures. Hence, the monitoring data (including the relevant data from other sources) have to be aggregated in the form of indicators along with the production data.

4.6 Who should monitor?

The Project Proponent, Impact Assessment Agency and Pollution Control Boards should monitor the implementation of conditions stipulated while according environment clearance. The Commitments of the individual can be incorporated in the environmental clearance conditions. Project proponent is required to file once in six months a report demonstrating the compliance to IAA. The IAA should examine these reports and take further action.

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