Environmental Management Plan

Environmental Management Plan (EMP) is aimed at mitigating the possible adverse impacts of a project and ensuring that the environmental quality is maintained. In fact the management plan covers all aspects of environmental mitigatory ac­tion plan including human resources management of the entire project operation starting from con­struction and operation of the project.

EMP—Review and Monitoring Guideline:

(a) General:

Environment Management Plan should include:

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

2. Delineation of unmitigated impacts

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

4. 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

(b) 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.

1. Ambient Environment Quality Standards/ Acts

2. Policies of government or statutory bodies

3. Compliance with the International obligations

4. Assimilative capacity of the region

Ambient Environmental Quality Standards/ Acts:

Where standards are not prescribed in India, the following may be referred:

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

Government Policies (Illustrative List):

1. National Water Policy, 1987 (Prioritization of Water Uses)

2. National Land use Policy, 1988 (Protection of land under cultivation and suitable for agri­culture)

3. National Forest Policy, 1988 (Protection) and Conservation of Forest

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

5. Industrial Policy 1991

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

7. National Rehabilitation and Resettlement Policy (Draft)

8. National Mineral Policy 1993

(c) Mitigation Plans and Relief and Rehabilitation:

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

(i) 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:

1. Pollution prevention

2. Waste/minimisation

3. End-of-the-pipe treatment technology

4. Attenuation in the source-receptor pathway

5. Protection of the sensitive receptors

6. Mitigation Measures (onsite and offsite) to minimise 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 organisation 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.

(ii) 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

1. The listing of divides 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).

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

3. 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.

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

1. the skills required for effective implementa­tion of mitigation plans are identified

2. the organisational chart for implementation of mitigation measures with roles and respon­sibility is provided

3. 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 organised 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:

1. The cost of mitigation measures and flow of investments based on schedule of implemen­tation of mitigation measures are delineated

2. The costs of maintenance and operation throughout its life time are specified

3. Documentation of evidence of inclusion of such costs in the project planning is demon­strated

4. Adequacy of financial resource allocation is demonstrated through a cash-flow chart.

(d) Stipulating the Conditions:

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

(e) What should be Monitored?

1. Stipulated conditions

2. Implementation of EMP

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

4. Issues raised in the Public Hearing

(f) 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.

(g) Who should Monitor?

The Project Proponent Impact Assessment Agency and Pollution Control Board should moni­tor the implementation of conditions stipulated while according to 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.

Management Action Plan:

It is essential to implement the management plan right from the conception of the project and should continue all through.

The Environment Management Plan (EMP) thus can be divided into two phases:

(a) During construction phase and

(b) During operational phases

Environmental Issues Considering during Project Planning:

(a) Site Selection:

This is prime action required for any project proposal. As the proposed project is planned in coastal areas, coastal regu­lations viz., CRZ notification of 1991, should also be considered duly for site selection at each of the proposed locations. These are other consideration also viz., security problem, disaster project, communicability, transports fa­cilities, overall environmental consideration around the project sites should also be con­sidered.

This is an organge categories of project, so some precautionary measures to be observed during setting up of the project into action and also to observe the MoEF project site clearance guideline several aspects like avoidance of forest, wildlife sanctuaries, erosion-prone zone, populated areas, and other sensitive locations should also be considered.

(b) Construction Design:

Landscaping of the area, construction of permanent and tempo­rary two storied hotel, tent age, cottage, etc. should be done in such a manner so that aesthetic aspect of the area should not be nor­mally disturbed. As the region is very much corrosion prone due to salt incrustation of iron materials. So ad­equate protection against corrosion should be taken up either changing the use of non-corrosive structural materials or by regular painting by corrosion protection materials.

(c) Transportation and Communication:

In the initial site planning greater emphasis should be given in transportation on land and river routes which must be safe and shortest irrespective of tidal condition. Transport car­riers or vessels must be properly maintained and fastest in movement with liter noise dur­ing operation.

There should be planning for on broad telecommunication link from different places.

(d) Safety and Security:

Safety and security as­pect of the project at each site should get proper priority at the initial stage of planning. Each and every project site should be prop­erly guarded by security personnel’s.

(e) Environmental Protection and Aesthetic Improvement of the Site:

Though the present land use pattern showed the area to be developed for the project, it is either swamp, crop field or non-cultivable wasteland. But at the initial planning phase environment pro­tection from standpoint of emission regula­tion, wastewater treatment, solid waste dis­posal and overall improvement landscape of the area should get priority.

Environment Management during Construction Phase:

(a) Land Restoration:

Proper care should be taken up for land improvement/development of the area to start construction of various types of structures and network of transport roads on land based sites. A good number of well-designed structures needs to be con­structed in each project sites.

These are as fol­lows:

(i) Cottages,

(ii) Tent ages,

(iii) Tourist lodge (2 stories)

(iv) Restaurants,

(v) Service centre,

(vi) Meditation centre,

(vii) Medical facility cen­tre,

(viii) Eco-park,

(ix) Amusement cum sports complex,

(x) Administrative office com­plex

(xi) Staff quarters,

(xii) Helipad and

(xiii) Jelly (fixed or pantoon type depending on site).

In every site more than 1 /4 of the total lease­hold was planned for kept as open space in­cluding open air bathing facilities, Eco park, amusement park, sports centre, roads, waste­water treatment plant, drinking water treat­ment plant and waste disposal sites etc.

During construction, proper protection should be made for noise reduction, dust sup­pression on site etc. A well designed green belt planning should also be attempted along with construction of all the planned structures.

(b) Bank Protection:

As the area lies in the coast, proper protection of embankment encircling the entire complex in each site should also be taken into consideration. The banks of the major water crossing will be suitably protected. For the said purpose on top of the backfilled, compacted and graded bank gravel, bolder filled embankment matters of galvanized iron wire will be laid.

(c) Drainage and Sanitation:

During construc­tion plan, appropriate drainage and sanitation plan of the project site should be properly as­sessed, so that there should not be any water­logging area inside the site during monsoon or flash flood period. Wastewater treatment plant and Drinking water treatment plant should be placed on elevation, which never get any chance for inundation.

Environmental Management—Operational Phase:

During operation of the project, several aspects may lead to management of negative environment impact needs to be addressed and monitoring for future guideline.

1. Solid waste disposal,

2. Wastewater disposal,

3. Ground water withdrawal,

4. Coastal zone (beach) protection,

5. Erosion control

6. Socio-economic impact of the entire project assessment

As mentioned earlier in this report, the over­all impact of the project on environment is ex­pected to be improved if proper Environmental Management Plan can be implemented.

(a) Water Balance:

Water requirement of the project in each is fairly high. This is required primarily for domestic supply. As the area fall in the sweet scarcity’ zone, rain water harvest­ing and subsequent treatment facilities needs to be developed. Of course some amount of water may be withdrawn from the ground by deep tube well.

Attempt will also be made to prevent any wastage of water to avoid misuse of natural resources. Major volume of waste­water which will be generated from domestic sector will be treated in septic tanks and soak pits. However, run off water and community wastewater should be collected through waste­water channel and then treated by low cost option.

(b) Environmental Monitoring:

Periodic moni­toring of environmental quality like meteo­rology, air, water, soil and noise etc. should be done by monitoring cell or by a competent consultant. Such a monitoring is essential for long-term impact assessment of the project. Environment management cell must have monitoring equipment’s and skilled personnel’s.

(c) Afforestation and Green Belt Development:

For climatic amelioration and aesthetic im­provement of the area an well designed green belt in the form of Avenue plantation about a meter wide on either side of road), block plan­tation in various design as conservatory (after reaction block), eco-park with or mental species, recreational-amusement park with perennial shed trees etc. can be planned for future development in other areas. The green belt will also assert the soil erosion and divert spread. It will also attract birds and several other wildlife to like inside.

The suitable species for greenbelt, develop­ment may be listed in following Table 24.6:

(D) Other Issues:

(i) Statutory requirements:

Management needs to meet a number of statutory requirements under water (Prevention and Control of Pol­lution) Act, 1974; Air (Prevention and Con­trol of Pollution) Act, 1981; Environment (Protection) Act, 1986; Coastal Zone Regula­tion, 1991. etc. Timely submission of envi­ronment report to State Pollution Control Board periodically is the prime responsibility of environment management group.

(ii) Awareness Campaign:

Overall improvement of the environmental quality is dependent on the environmental awareness amongst all sec­tion of employees in the corporate. Thus among the workers of the corporate is very essential for improvement of the quality of environment in the concerned project. Publi­cation of new-letters, observation of environ­ment week/day, arrangement of seminars/ workshops on Environmental issues involv­ing the workers will enscine better awareness.

(iii) Social interaction:

The corporate should also encourage environment awareness among the people around the project site. This will make a good public relation and will help in assum­ing better environment management programme. Thus, a good corporate should have a environment policy of their own.