ENVIRONMENTAL RISK ASSESSMENT FOR INFRASTRUCTURE …
Environmental Risk Assessment for INFRASTRUCTURE SUBPROJECTS
Scope of Environmental Risk
There are no significant environmental issues and Bulgaria's environmental laws and requirements are compatible with the Bank's policies and those of the EU. It is expected that the execution of the infrastructure subcomponent will not cause any substantial environmental impact. For the purpose of controlling and preventing any particular situation, wastes resulting from health services, and wastewater of sewerage systems where buildings are constructed would be treated and/or disposed of in adequate manner. Infrastructure design and equipment would take into consideration elements to mitigate negative impact. Used materials, garbage and products of the construction phase would be disposed of in authorized and controlled places. All necessary precautions will be taken to ensure that potentially toxic substances such as asbestos or lead from paint will be handled in a safe and environmentally sound manner, based upon positive experiences already gained in undertaking environmental reviews and monitoring environmental aspects of subprojects under other Bank-funded project in Bulgaria. Furthermore, the construction plan will take steps to minimize waste, dust, and debris from construction and to safely dispose of construction wastes. Only licensed contractors will undertake such contracts. A guide for the formulation and evaluation of environmental aspects, with sections on diagnosis, interpretation and prevention of situations, forms a part of the Operations Manual.
Three factors ensure that the activities implemented under the SIP project will not be environmentally damaging interventions:
➢ Bulgaria has a strong policy for enforcing environmental regulations, and enforcement is improving especially after Bulgaria joined the EU on January 1, 2007;
➢ The SIP project will finance only small infrastructure construction and rehabilitation subprojects, with minor environmental impacts;
➢ The Bulgaria Social Investment and Employment Promotion (SIEP) project and the Bulgaria Child Welfare Project, will transfer their significant experience to SIP in the area of implementing sub-projects according to highest standards of environmental scrutiny.
Compliance with National Legislation
Bulgarian environmental laws and requirements are compatible with the Bank's policies and those of the EU. However, all necessary precautions will be taken to ensure that potentially toxic substances such as asbestos or lead from paint will be handled in a safe and environmentally sound manner. The construction plans will take steps to minimize waste, dust, and debris from construction and to safely dispose of construction wastes. Only licensed contractors will undertake such contracts.
The Bulgarian legislation relevant to environmental issues include the Environmental Protection Act and the Environmental Impact Assessment Regulations, as well as the Law for the Protected Territories, Reduction of the Harmful Impact of Waste upon the Environment Act, Water Act. The executive agencies responsible for their implementation are the Ministry of the Environment (MOE), the Regional Environment and Water Inspectorates and municipal administrations.
The legislation requires that for the investment proposals listed in Annex I and II of the Environmental Protection Act Environmental Impact Assessment procedure should be done. The completion of an Environmental Impact Assessment Report (EIAR) is required for the proposals subject of the mandatory EIA or with issued screening decision that EIA is necessary. The Environmental Impact Assessment Report is contracted by the developer and is prepared by independent experts. The condition and the procedure for registration of the experts, carrying out Environmental Impact Assessments could be found in the Ordinance 1 from 2003, issued by the Minister of Environment and Water.
Risk Assessment Methods and Techniques
Community Involvement in Assessing the Environmental Impact of Sub-Projects
Community involvement in the assessment of the environmental impacts of sub-projects will be ensured via:
(i) disclosure and dissemination of information about the envisaged project activities with potentially hazardous environmental impact. The SIP management in the MLSP is responsible to provide the relevant information to communities prior to consultations with the local stakeholders. The information should be provided in a timely manner and in a form that is meaningful for, and accessible to, the groups being consulted.
(ii) public consultation, soliciting people’s views on proposed actions and engaging them in a dialogue. Interaction with people and eliciting feedback will allow the affected population to influence the decision-making process by raising issues which should be considered in developing the scope of sub-projects, project design, monitoring of environmental impact, risk mitigation and analysis of alternatives where applicable. The process of consultation on environmental issues should be documented.
Environmental Inspection for Sub-Projects at SIP (MLSP) Level
Fully-fledged environmental assessments are not applicable in the case of sub-projects implemented under the SIP project. Projects entailing rehabilitation, maintenance and upgrading usually will have much more limited impacts, but may require attention to existing environmental problems at the site. Therefore, an environmental screening (inspection) may be more useful in fulfilling the environmental assessment needs for such projects.
The aim of environmental inspection at SIP level is twofold: (i) to ensure that sub-projects with negative environmental impact are not financed, and (ii) to ensure that approved sub-projects are implemented in an environmentally acceptable manner.
The environmental inspection will be initiated by the SIP administration at MLSP. Normally, potential environmental impacts are identified early during the review of the proposal for a sub-project. For projects under implementation the environmental inspection will complement the check for compliance with national environmental legislation. The process will include a detailed review of the technical proposal (specification) for small works with respect to defining the type and scale of the potential environmental impact and risk.
A sample questionnaire for the review could address the following issues:
Do the technical project and the implemented works comply with the existing national norms regarding the environmental protection? Yes No
Does the project’s implementation produce environmental damage that cannot be mitigated? Yes No
If yes, describe.
…………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………
Does the project’s implementation produce any environmental damage?
Yes No
If yes, describe.
…………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………
Is the project’s implementation associated with the presence of dangerous materials?
Yes No
If yes, describe.
……………………………………………………………………………………………………………………………………………………………………………………………………
Is the project’s implementation associated with dangerous conditions at the project site?
Yes No
If yes, describe.
…………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………
Is the agency proposing the project demonstrating awareness of the social aspects of the potential environmental damage?
Yes No
Are measures included in the proposal to avoid or minimize this damage?
Yes No
Are these measures sufficient and/or relevant? Yes No
If no, motivate.
…………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………
Were the communities affected by the sub-project involved in the identification of environmental impacts and risks?
Yes No
What forms of community participation in environmental impact and risk assessment have been used? Explain.
………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………….
Based on the results of the screening, the SIP administration prepares plans for environmental impact monitoring through appraisal and supervision, and develops customized checklists to be used for this purpose, depending on the type of the sub-project and the magnitude of risk.
The SIP administration can recommend to or oblige contractors to follow appropriate environmental, health and safety standards, to reduce associated risks during construction, rehabilitation and refurbishment. For example, construction specifications might include clauses relating to:
➢ preservation of the natural landscape to the extent possible;
➢ restoration of natural landscape in the event of unavoidable damages;
➢ prevention of accidental spillage of hazardous materials, noise and dust;
➢ ensuring proper disposal of rubbish and waste construction materials;
➢ timely removal of temporary construction facilities from the site, etc.
As the above illus
trates, potential problems can be solved through relatively simple measures related to the subproject design and technical advice. Each subproject including small works must be submitted, at the application stage, with a full application package, comprising a feasibility study cleared by the regional or municipal authorities for environmental protection. The key to ensuring that sub-projects will be environmentally sound and that positive environmental management actions are taken, is building the implementing capacity of the implementing staff and of the community representatives.
Possible Cumulative Effects from Concentration of Subprojects in one Type of Investment
The nature of the SIP construction involves rehabilitation of buildings or parts of buildings, or construction of a limited number of new buildings. The new construction will consists of normally no more than one building per participating municipality, with an expected total of sites not to exceed 20. The buildings themselves are expected to have a foundation area of less than 400 sq meters, and to rise to up to 4 floors maximum.
The design of the SIP project will not allow the concentration of project resources in a single type of investment. Moreover, the total amount of SIP financing of infrastructure would not be more than US$ 25 million, which is a relatively small amount of infrastructure investment for Bulgaria.
However, to ensure that cumulative effects of a single type of investment be avoided, the SIF will include in its quarterly reports, based on data from the MIS, summary tables and analysis of the approved subprojects during the past period by type. The tables and analysis will also include regional break-down and analysis.
Cultural Property
Before proceeding with a subproject which prima facie entails the risk of damaging cultural property (e.g., any project that includes large scale excavations, movement of earth, surface environmental changes or demolition), the SIP technical staff or consultants will determine what is known about the cultural property aspects of the proposed project site and will record the findings in the appraisal report. If there is any question of cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist and if it is determined that the subproject in any way negatively influences cultural property, the project will be declared ineligible for financing.
Natural Habitats
The treatment of natural habitats will be according to the national legislation, which is very strict and is implemented at the stage of micro-project appraisal, through a mandatory Environmental Impact Assessment. Subprojects will be sited only on lands already converted and subproject involving conversion of natural habitats will not be eligible for financing. The status of the site will be determined during the Environmental Impact Assessment. The availability of this determination will be ensured by the SIP administration during the appraisal stage.
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