Reviewof EMPmonitoring

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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 Identificationof 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 Environment
Ambient Air (Protection) Rules,
Quality 1986
Standards

Environment Protection
 Ambient Noise Act (Central Pollution
Standards Control Board) No. 29
of 23-5-1986

Central Pollution
Control Board
Standards
 Classification
of Inland Surface IS 10500-1983
Water

IS 2490-1982

 Indian
Standards/
Specifications for
Drinking Water

 Indian Environment
Standards for (Protection) Rules,
Industrial and 1986, Schedule VI/
Sewage Standards Prescribed
Effluents by SPCBs
Discharge

 General
Standards for
discharge of
Environment
Pollutants
Where standards are not prescribed in

 Damage Dept. of Industrial


criteria for heat safety, The Netherlands
load and
pressure wave
 Risk Organisation for
acceptance Applied Science and
criteria Research (TNO), the
Netherlands
 Damage Risk Occupational Safety
Criteria for and Health
Hearing Loss 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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