Environmental and Social Management Framework (esmf)
Potential Cumulative Impacts
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Considering the small size of most sub-projects, it would be easy to dismiss the negative effects that each project might have on the environment. For instance, it is anticipated that small farmers will request modest grants for the purchase of basic farm inputs of seed, fertilizers, pesticides and fuel, and for livestock. Such a grant to a single farmer would present little environmental concern and a large number of such small loans spread throughout the country would have a relatively negligible effect. However, if by chance a large number of requests for loans originated from the same area, and more importantly from the same watershed, the cumulative effect of all of the small (negligible) effects could be significant. Cumulative effect is important in spatial terms, as indicated above, and also over time. For instance, a grant for seed purchase in itself has no negative impact, and in fact, has much the opposite with an increased production and return to the farmer. However, the same grant provided for more than two years in a row could promote poor crop and land management and disrupt a relatively current good agricultural management system characterized by long rotations. By avoiding a crop rotation program the farmer can deplete the fertility and organic content of his soil and further promote soil erosion. Over time there would be a cumulative effect. Farmers should not be denied credits on the basis of their location, but if monitoring of patterns indicates concentrations of grants (e.g. fertilizers) in one watershed, the PIU environmental specialist should alert the SES, and local environmental authorities and the PIU office for special monitoring of the situation. If the cumulative effects have the potential to become severe, lending for the activity should be suspended. Another example applied to small and medium enterprises is the application of grants for rehabilitation or for the start-up of new businesses. With agro-processing and other agribusinesses, small-scale processing, manufacturing and service works the environmental concerns usually focus on air emissions and effluent discharge. In the case of air emissions, there are usually standards in place that guide the concentration of various emissions at the stack. Although each industrial activity may have emission controls well within established national standards, cumulatively, all of the enterprises in one region (e.g. in a small closed valley with poor air circulation) could significantly contribute to the deterioration of overall air quality, resulting in an impact on human health. Similarly, for water quality, a number of enterprises releasing effluents into a water body could cumulatively affect the quality of the water in a significant manner even though each enterprise may be releasing very small amounts of effluent that meet set standards. The other aspect of cumulative effects of the overall project is the accumulation of a large number of very small impacts over the full range of grant-funded activities. That is, the cumulative impact of all of the small impacts as a result of a number of grants for fertilizer purchase, added to the cumulative impact of all of the small impacts from the manufacturing sub-projects, added to the cumulative impact of all of the small impacts from the non-farm enterprises. The overall cumulative impact could be significant. Since many of these activities can have an effect on water quality, the overall effect on water quality could be significant. In a comprehensive examination of cumulative effects, analysis would be made of all of the other activities taking place that have impacts. For instance, other programs that could be providing agricultural lines of grant program, forestry programs that could be contributing to soil erosion, and in the same vein, road construction activities and other general construction that could add to the soil erosion problem. In order to prevent the risk of adverse cumulative environmental effects, a brief environmental analysis will be made of the portfolio every year by the PIU environmental specialist and reported to the relevant authorities in the MLSPP, MENR and the World Bank. On the social side, systematic deficiencies in beneficiary engagement, inclusive outreach, quality of information provided and of consultations, or of the grievance redress mechanisms can accumulate to produce wider lack of trust in the program. Lack of transparent information can also produce misperceptions on the integrity of the program. The grievance and redress mechanism should be accessible not only to persons directly involved in the program but also other citizens that may be directly or indirectly influenced by program activities, for example, neighbors, community members, local leaders, etc. These stakeholders are likely to be clients and consumers of products produced by project beneficiaries and have a stake in these products being produced in a safe, environmentally and socially conscious manner. Failure to engage with diverse stakeholders and to diversify the types of activities within one region can also inadvertently discourage potential applicants. For example, if the majority of grants and training provided in a region are concentrated in agriculture, qualified applicants with skills in other sectors may be less proactive to apply to the program. Similarly, if the majority of beneficiaries represent one vulnerable group, a misperception can be created on who the program is targeted to. Frequent engagement with beneficiates is also key in order to identify and attempt to reduce systematic obstacles and barriers to potential beneficiaries. Collecting such feedback and sharing in a continuous way with project implementation authorities can support continuous improvement of the program and maintain high trust in its results. In order to prevent and mitigate the above risks, the PIU social specialist will conduct regular monitoring of activities on site, including meetings with selected and potential beneficiaries, and other community members, ensure that social screening reports are prepared in a thorough manner, and stakeholder engagement activities are implemented with high quality, and that the grievance redress mechanism is known and accessible to project beneficiaries. All social-related issues will be described in regular project monitoring reports. Systematic issues identified in any social aspect will be flagged by the social specialist to PIU management and corrective or remedial actions will be discussed and pursued. The following measures are proposed to enhance the positive impacts and to mitigate the adverse ones: Training the farmers on proper application of fertilizers; Training the farmers and agro-dealers on best practices for pesticide storage, handling, application and disposal; Equipping the farmers with skills in improved water catchment management; Increasing and intensifying extension services for imparting knowledge to farmers; Training the farmers in good soil and water conservation and land management techniques; Minimize stripping of vegetation so that surface soil is less susceptible to erosion; Control flow of water to reduce erosion and siltation through engineering solutions; Rehabilitate all quarry sites and burrow pits after civil works; Haul roads should be regularly maintained; Conduct road safety awareness campaign meetings with local communities; Dispose all waste in designated and approved dump sites; Training beneficiaries on basic labor health and safety provisions relevant to their area of occupation Training responsible local-level stakeholders involved in service delivery (case workers, local government, local leaders) in conducting inclusive our each and participatory meetings when selecting types of activities and training as per demand Training of the above actors on specific measures and accommodations that should be taken into considerations when working with specific vulnerable groups (for example, women, persons with disability, IDPs) to ensure their participation (for example, setting timing of meeting when women can attend, providing transportation support for persons with disability etc. can help to ensure their participation) Training of all persons involved in the functioning of the GRM on their role and responsibilities Maintenance of functioning GRM and grievance log Regular monitoring and reporting on the above measures The proposed measures can be used for ESMP development for individual sub-projects. An indicative list types/sectors of subprojects for which the project will support in-kind transfer of assets is presented in Annex 1. All subprojects shall be assessed in terms of their potential impacts and necessary mitigation measures in compliance WB EHSG and GIIP.43 A summary of potential environmental and social risks and impacts during the implementation of sub-projects for which the project can provide in-kind transfer of assets and, generic mitigation measures, are presented in Annex 2. As only those sub-projects that do not require land acquisition or involuntary physical relocation will be included in the financing within the framework of this project, all sub-project activities will be carried out in the territory of existing facilities, that minimizes the impact on flora and fauna during the construction stage. Herewith, for the construction of some facilities, there may be an option when it is necessary to dismantle part or all existing building or structure, which will significantly increase the volume of waste, dust and noise. For sub-projects related to the modernization of existing production, namely, the purchase of new equipment or the expansion of production by increasing capacity, the main impact on the environment is expected during the operation phase, in the form of increased waste generation and wastewater. In these cases, no construction / rehabilitation work is foreseen. However, in the case of modernization by replacing existing old equipment, it is most probably that emission reductions and waste generation will occur due to the use of modern equipment. Yüklə 13,37 Mb. Dostları ilə paylaş:
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