Introduction to

Environmental Mitigation &

Monitoring Plans (EMMPs)

Environmental Compliance/ESDM Training Workshops

Lake Naivasha, Kenya January & February 2010
Congratulations

9 We are all Mitigation

and Monitoring Experts!

Now, we must apply our knowledge

IEEs (and EAs) are useless unless the
conditions they establish are implemented!
USAIDs environmental procedures
therefore require implementation

Introduction to EMMPs. Visit www.encapafrica.org. 2

Review: Key LOP Env. Compliance Requirements

What does the ADS say?

Team Leaders and Activity
Managers or C/AOTRs must
actively manage and monitor
compliance with any IEE/EA
conditions, modifying or ending
activities not in compliance.
(ADS 202.3.6 , 204.3.4 and
303.2.f

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Implementation of IEE/EA conditions

Practically, implementation &

monitoring of M&M conditions
requires that:
1. USAID communicates applicable
IEE/EA conditions to the IP*
2. Complete Environmental
Mitigation and Monitoring Plan
(EMMP) exists
3. Workplans and budgets integrate EMMPs are
the EMMP critical.
4. Project reporting tracks What are they?
EMMP implementation

*Except Title II partners, who write their own IEEs.

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 Basic EMMP
EMMPs: Simple in concept template

An EMMP To determine if mitigation

is in place and
sets out: successful

(i.e., visual inspection for

ALL the leakage around pit For mitigation, and for
mitigation From IEE, include latrine; sedimentation at monitoring and
measures only activities with stream crossing, etc.) reporting.
conditions (May be different)
required by the
IEE/EA
Activity Adverse Mitigation Monitoring Monitoring Responsible
indicators or
Impacts Measure Indicators/ & Party(ies)
criteria for Criteria Reporting
monitoring their Schedule
implementation
& effectiveness
who is
responsible for
If well-specified,
mitigation & (e.g.., monitor weekly,
See EMMP template quote directly from report in quarterly
monitoring. in sourcebook IEE reports and more
If not well-specified in frequently under
IEE, define more specified conditions)
specifically

5
Introduction to EMMPs. Visit www.encapafrica.org.
Implementation of IEE/EA conditions

More sophisticated EMMP

formats can include:
1. Budgeting information---how
much will a mitigation or
monitoring measure cost? What We will use an EMMP
is the LOE involved format with these
2. A Monitoring Log section features
where mitigation implementation
information/the results of
monitoring
3. Etc.

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How are EMMPs being required?

Three mechanisms:
1. Technical direction from C/AOTR
2. Required by contract/agreement More about this
3. Required by MYAP guidance
(Title II only)

!
A key lesson learned from 40
years of world-wide EIA
experience:
implementation of env.
conditions requires EMMPs that
are incorporated in
workplans and budgets

Introduction to EMMPs. Visit www.encapafrica.org. 7

USAID is Required to Write IEE/EA
Conditions into Awards

ADS requires
incorporating. . .
mitigative measures
identified in IEEs [and] EAs
into implementation
instruments for programs,
projects, activities or
amendments.
(204.3.4.a.6; also 303.3.6.3e)

Introduction to EMMPs. Visit www.encapafrica.org. 8

Increasingly USAID is using best-practice environmental
compliance language beyond the ADS minimum

New awards and significant

modifications are requiring that:
To assure that projects do
1. The partner verifies current and planned not creep out of
activities annually against the scope of compliance as activities are
the RCE/IEE/EA. modified and added to over
their life.
2. The necessary mechanisms and
budget for partner implementation of Specifically:
IEE/EA conditions are in place 1. Complete EMMP
exists/is developed.
2. Workplans and budgets
integrate the EMMP
And new solicitations require that 3. Project reporting tracks
EMMP implementation
Proposals address qualifications
and proposed approaches to
compliance/ ESDM for
environmentally complex activities.

Introduction to EMMPs. Visit www.encapafrica.org. 9

 ( al
mo
Source of best-practice language new st)

Environmental Compliance:
Language for Use in
Solicitations and Awards (ECL)
9 An ADS
Additional Help
document
Easy step-by-step
guidance and
boilerplate language
9 For RFAs/ RFPs/
agreements/ grants/
Hardcopy in your
sourcebook. contracts
Also available from 9 Optional
www.usaid.gov/policy/
ads/200/204sac.pdf
but its use being strongly
encouraged

Introduction to EMMPs. Visit www.encapafrica.org. 10

In addition to improving LOP compliance and
better achieving ESDM. . .

The ECL benefits both Mission Staff & partners:

USAID Mission Staff Implementing Partners
Assures that environmental monitoring Provides clarity regarding environmental
and reporting is integrated into routine compliance responsibilities
activity monitoring and reporting
Prevents unfunded mandates-
reduces the cost and effort of
requirements to implement M&M after
verification/oversight.
implementation has started & without
Avoids the effort, costs and loss of good additional budget.
will that come from imposing
corrective compliance measures after
implementation has started.

Missions and centrally funded programs are

! increasingly using the ECL. Partners should
expect that future solicitations and awards will
incorporate ECL-based environmental
compliance language

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 11

How are EMMPs approved?

EMMPs must be approved by

the C/AOTR
Usually submitted &
approved with the workplan or
PMP
(For Title II, sometimes
submitted as part of the IEE,
with the MYAP.)
Sometimes additional review
by the MEO or REA.

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EMMP example: Diversion works at
the head of the system
Irrigation Rehabilitation
PROJECT BRIEFING:
System reconstructed early
1980s
Abstracts water from high-
level river source and irrigates
140 Ha (2 parcels; valley &
hillside lands)

One dam is made of brush,

straw, soil, and stone
The other is made of stone
and soil
Water source low in salts; soil
salinization potential is
minimal.

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 13

EMMP example:
Irrigation Rehabilitation
Doing laundry in the canal
PROJECT BRIEFING:
Canals used for many
purposes: irrigation, bathing,
drinking water, laundry. . .

At the end of the dry season,

not enough water for all plots
During heavy rains, canals fill
with sediment from hillside
erosionresult: not enough
water for all plots.
No adjacent wetland nor
critical wild life habitat.

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 14

EMMP example:
Irrigation Rehabilitation
PROJECT BRIEFING:
The canals are hand made
and carry open water from
upstream

Roads: In poor condition

difficult to get crops out.
System maintenance
committee not functional
Surrounding hillside is
completely deforested Water distribution: Land
registration to receive

!
irrigation water was done in
There are many baseline issues
early 1980s. No new plots
that are not impacts of the can be registered (but theft
rehabilitation, but should be from the system is possible.)
addressed in the EMMP

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 15

 Impacts/Baseline
EMMP example: Issues & Mitigations
Irrigation Rehabilitation (Excerptsummary language)

#
Sub-activity or Description of Mitigation Measures
component Impact/Baseline Issue
Dam & primary Flooding of irrigated areas/damage to Design so that excess of water wont damage systems (excess 1
canals re- system during high-flow events flow diversion, removable dam etc.)
construction Soil erosion from hillsides and Install & properly operate flow regulation structures for 2
/replacement & secondary/tertiary canals secondary canals
subsequent Protect upper slope with fruit trees (mangoes, citrus, 3
operation avocado) and native forest trees
Water losses (from evaporation and Line primary canals with concrete 4
leaching but also from canal blockage
Train water committee on heavy rain after-maintenance 5
from dirt, debris etc.)
Health issue (drinking irrigation water Community education on water quality/use/management 6
because it appears cleaner) Water committee to enforce use restrictions
Water contamination from animals, Provide separate water points for construction washing 7
construction stations and animal watering
Social impact of inequality of water use -Existing water committee reinforcement 8
increasing # of people using the water -Land Registration
Road Increased Deforestation Work with local officials to control deforestation 9
rehabilitation: (due to increased ease of access)
bridges & drainage Increased sedimentation Sedimentation control (silt screen and hay bails- local weeds) 1
works from enhanced road drainage 0

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 16

 And finally. . .the EMMP itself

(Uses a Title II format that includes a

monitoring results log. )

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 17

EMMP example: EMMP & Monitoring Log
Irrigation Rehabilitation (Excerpt)

Mitigation Responsible Monitoring Scheme Est. Monitoring Log

Measure Party Cost
Indicators Data source/ How Often Date Result Follow-up
Method

3. Install & Project # of doors and other flow- Reports Quarterly

properly agricultural control structures installed Field visit
operate canal- technician % of Ha. under flow control
level flow
% of secondary & tertiary
regulation
canals showing significant
structures
erosion damage after each
growing season
4. Protect Project # of trees planted and survived Reports Quarterly
upper slope agricultural % of at-risk upper slope land Field visit /Annual
with fruit technician protected Comparison
(mangoes,
total m3 of sediment with baseline
citrus, avocado)
removed from canals over each information
and forest trees
rainy season.

5. Line primary Engineering % of primary canals lined with Reports Quarterly

canals with Contractor concrete. Field visit
concrete # of additional hectares Comparison
irrigated with baseline
information

Implementing IEE/EA Conditions. Visit www.usaid.gov/our_work/environment/compliance/ane/index.htm & www.encapafrica.org 18