20832 Environmental and Social Safeguard Note D E c E M r Ea F I 1 9 1C.LJ 1D1 B E3 E I Implementing Environmental Management Plans: A Review of Selected Urban Environment Projects in China R apid economic growth is according to World Bank Opera- largely based on discussions and changing the face of tional Policy 4.01, "Environmental field visits to selected project sites China's cities. High rise Assessment" Detailed Environmen- in April and May 1999. The sample, office buildings and tal Assessments (EAs) usually albeit limited, has yielded valuable impressive highways intersect a precede these investments, and insights into environmental landscape of crowded living spaces, projects approved after July 1993 management and supervision of Air and water pollution remain must include comprehensive Bank projects in China, as well as serious and social services are environmental management plans general trends in environmental inadequate. To respond to these (EMPs).1 management. We are grateful to problems, the Bank is financing a the task managers, project man- number of environmental im- This note reviews the extent to agement offices, and counterparts provement projects, which are which EMPs have been imple- in local agencies for their coopera- some of the largest in the East Asia mented in the execution and daily tion and thoughtful inputs. and Pacific Region. Because of the operations of several large Bank- enormity of their potential impacts, funded urban environmental WHY ARE ENVIRONMENTAL many of them fall into Category "'A" investments in China. The note is MANAGEMENT PLANS IMPORTANT? f Environmental management plans ,.... ,_- have two critical functionis: To ....... ensure that project implementa- ~~~~~s # 4'R tion-planning, designing, con- .,>x e-. structing, commissioning-has as little negative impact on the ' f u _ t El environment as is possible; and =" g1i jt *- Jff eatI l "A project's envirotmirietntal tanagetint plan consists of tfle set of mitigation, monitoring, and institutional measures to be takeen during iniplenieutation and operationi to eliminlate k E X ¢F5 ZA t" t t iF&; LZk Q i m ~adverse enivirottteiita1 and sodal impacts, offset Ef; +X. Ttt@eR XItiz, rT'tt$-Lg@X>%'-tj\-: ~~~~~~~~~~~thelti, or reduce tliei totltcceptable lerels. The plain ~~~~ ~~~~~~ - ~~~~~~~also inicludes tlhe actionis nieed ed to imnplemnent vr - ~~~~~~~~~~~~~~these rueasures. 1tanagemneut planis are essenttial eletet ts of EA reports for Category I projects,for many Category B projects, the EA may result in a L - i l 1_ tno agenentlplati only:' Paragraph 1, Annex Public notice describing an investment project on the Xin He River. C, 01'4.01, World Bank, 1999. T H E W 0 R L D B A N K G R O U P World Bank supported and Box 1. NATIONAL ENVIRONMENTAL POLICIES AND encouraged EMP implementation. PROGRAMS IN CHINA' FRAMEWORK FOR ENVIRONMENTAL The main policies that have guided the development of China's PROTECTION AND MONITORING IN environmental regulation institutions are the f3llowing: whoever CHINA causes the pollution shall be responsible for its elimination, preven- tion first, and strengthened environmental management. The There are four levels of lawmaking polluter-pays principle is implemented througA a levy system in institutions in China, each of which polluters are assessed fines on discharges that are in excess which enacts environmental on emission standards. With the exception of Shanghai, this fine is legislation. The National People's usually based on pollutant concentration rather than total pollution Congress (NPC) is at the highest- load, although new SEPA policy recommends that total pollution level, with power to enact and loads be monitored. Two policy mechanisms are in place for pollu- amend fundamental statutes. The tion prevention: First, enterprises constructing -iew, expanded or NPC, along with the newly formed renovated facilities are required to submit EAs for approval by the Environmental Protection and EPB or SEPA, depending on the size of the investment. Second, the Natural Resources Conservation "Three-Synchronizations Program" requires that pollution control Committee, and the State Council, technologies be incorporated into the design, construction and has advisory as well as drafting operation of new projects. End-of-pipe treatment approaches and oversight roles with respect to continue, however, to dominate environmental investments. environmental legislation and The State has established the following eight environmental pro- regulations.2 In 1998, the National grams to control urban and industrial pollutioni: Environmental Protection Agency grams tocotoluba ndidutiaolwas elevated to ministrv-level 1. Environmental Impact Assessment status and renamed State Environ- 2. Three Svnchronizations (Environmental Man agement for Con- mental Protection Administration struction Projects). (SEPA). It is responsible for formu- lating national environmental 3. Pollution Levy Svstem (Pollution Charges) standards and other rules. Many 4. Pollution Control within set Deadlines other ministries have environmen- 5. Discharge Permit System tal protection departments. At the local level, the people's congresses 6. Centralized Control of Pollution of provinces, autononmous regions, 7 Environmental Responsibitity System with Targets and special municipalities (includ- 7. ging Beijing and Shanghai), formu- 8. Quantitative Annual Assessment of Urban Environmental Quality, late locally relevant regulations Prof. Zhang Kunming/Former Deputy Directoi; SEPA, Paper titled, based on national statutes. Local "China's Policies on Environment:' International Workshop on Environmental Protection Bureaus China's Agenda 21, Beijing 1996. (EPBs), are delegated the authority to enact rules, methods, and standards set by SEPA. There are that project operation is environ- Timely and conscientious imple- EPBs at both provincial and mentallv sound. In essence, the mentation of EMPs, however rare, municipal levels. In addition to its EMP ensures-that the comprehen- does happen. In the Chinese role as an arm of SEPA, the EPB is sive work done on environmental projects surveyed, EMPs were also a part of the local government, assessments bears fruit in practice. implemented for a number of and reports to the mayor's office. reasons: they were found to be In 1989, the Environmental Protec- By outlining impacts, agencies useful by project management and tion law clarified that each level of responsible for monitoring these the borrower; elements of the local governmenit would be impacts and, in many cases, plans had to be implemented to responsible for environmental indicators to be monitored, the ensure that lhe general public and protection.' See Box 1. EMP sets up a simple benchmark the private sector supported the tablc. An environmentally sound project and d(id not suffer in the project not only follows the EMP course of project execution; the 2 Hongjun, Zhang and Richard J. Ferris in the initial stages but also, and plans were simple and easy to Jr. (1998) Shapinig an Environmential Protection more critically, internalizes "sound" follow; most of the critical mitigat- Regimefor the New Century: Environmiizential Law environmental management ing actions vvere already part of and Policy in tile People's Republic of China. principles throughout the life of Chinese pra(tice; and lastly, both Asian Journal of Environmental Manage- the project. the Chinese authorities and the ment, Vol. 6, No. 1., p. 56. T H E W O R L D B A N4 K s R O U P Box 2: ZHEJIANG MULTICITIES PROJECT BEST PRACTICE IN NINGBO CITY The Urban Infrastructure Upgrading office took the following eight steps to ensure that road rehabilitation and upgrading resulted in the fewest possible impacts on citizen safety, traffic flows and the environment: 1. joint option study with the police bureau on how to manage traffic flows 2. phased constructioil of main roads, to prevent major rerouting 3. formation of a construction-coordinating group with represen- tatives from police department, electricity, water supply compa- Worker safety posters at a project nies construction site. 4. project management office suggested that the municipal government institute a staggered work schedule to avoid delays in commuting 5. completion of construction was put on a fast-track; work done ENVIRONMENTAL MANAGEMENT in the .sit PLAN IMPLEMENTATION- EVIDENCE FROM CHINA 6. special care was taken to make commercial enterprises acces- sible Althoughthis reviewv encompasses 7. construction sites were kept clean, spoil disposal made a Although ects revie urban priority and the working areas enclosed only four projects in five urban centers in Eastern China, we 8. section of road near the construction site was cleaned everyday believe it provides insights into the 9. worker safety was made a priority strengths and weaknesses of the 10. a weekly assessment of the contractor's work was carried out, Chinese environmental manage- and warnings and penalties assessed when necessary. ment and protection systems. The following projects were selected for review: Local agencies have adopted many ENVIRONMENTAL MONITORING AND Beijing Environment Project'; EMP recommendations within ENFORCEMENT OF STANDARDS their standard operating proce- ShaghtProject; dures and incorporated several National environmental quality > Shanghai Environment Prolect; key mitigation measures into the standards, including ambient water coniditions and specifications of - Shanghai Second Sewerage contract documents. The Con- 5 Prof. Zhang Kunming/Former Deput' Project; struction Commissions and Director, SEPA, Paper titled, "China's Sewage and Sanitation Companies Policies on Environment;' International 2- Zhejiang Multicities Project take very seriously recommenda- Workshop on China's Agenda 21, Beijing (Hangzhou, Shaoxing and tions on control of noise pollution, 1996. Ningbo cities covered). removal of construction waste, 4 It is important to note that the Beijing replacement of topsoil, and traffic Environment Project which closed on There are currently eleven urban management during construction. June 30th, 1999 was classified a Cdtegory Worker safety is usuallv a top D project, and neither an EA nor an EMP environment/development projects priority and with the exception of were prepared for it. Ilowever, environ- in China (as of July 1999). The one glaring omission in which mental mandgement was an implied majority of these projects focus on very deep excavations were left objective of the project. A follow-up the delivery of services-water uncovered, construction sites were Beijing Environment Project 2 is under supply, sewerage, sanitation, and found to be well managed. In consideration. The review encompassed solid waste management. Projects some cases, such as in Ningbo water, air and solid wdste management in the sample are indicative of the City, the mitigation measures went investments under Beijing Environment well bevond EMP recommenda- Project, as well as general environmental Bank's investments In urban Chind.I tions (see Box 2). management in the Beijing area. T H E W O _ L. D B A N K G R O U P projects in China, and those more important to invest in general implementation experience from applicable to EMTPs in general. environmental awareness and other Category A projects would be education. This could be accom- another valuable tool for team - Local level conflicts that arise plished by better supervision of leaders in the Bank. because governments own and sub-components aimed at operate industries and manufac- strengthening environmental > EMPs themselves could be more turing or utilities while simulta- education, training and institution- manageable. Mitigation measures neouslv regulating them must be building. Supervision reports could be ranked in order of resolved. This is a critical obstacle should be required to comment on importance or arranged in priori- to improving environmental these activ:ties. With increased tized clusters. By naming every management. More effective ways environmental awareness, public potential environmental problem, of building and strengthening local disclosure -equirements will need EMPs can become launidry lists of capacity for implementing projects to be strengthened. troubles, and overwhelmed project and conducting environmental entities pay little attention to their supervision should be found. It is > In the face of shrinking budgets implementation. Because they important not just to identify at the Bank, it is unlikelv that more generally folloxv standard formats, which agency will be responsible resources will be allocated to EMP EMPs often appear to fulfill for implementing specific mitigat- supervision. However, existing bureaucratic requirements rather ing actions but how much time reports shculd have a specific than serving as useful environ- will be required and how resources requirement to comment on EMP mental safeguard documents.7 will be found to do so. It is clear implementition. In addition, some tllat a strong and better-endowed objective criteria should be sug- EP13 can spend more human and gested to rate performance, and 7 The REDEEM (Refining the Design of financial resources on supervision. flag and remnedy problems. MIaking Environmental Managemenlt Plans) supervision more cost-effective by Project, headed by J-R. Nlercier in the T o ensure sustainabilitv of using local expertise wherever Africa Environment Department, is work- environmental improvements, it is possible is one option. A record of ing on resolving exactly this problem. December 1999 For more information, please contact: Heinz iUnger, E-mail: hunger@worldbank.org Tanvi Nagpal, E-mail: tnagpal@worldbank.org T H E W 0 R L D B A N K G R 0 U P scale pig farms) are particularly weak. MITIGATING AND COMPENSATORY ACTIONS There are variations in the degree to which local authorities follow mitigation plans outlined in the EMP. In best-practice cases such as Shanghai, the Shanghai Fnviron- ment Project Office reported spending a quarter of staff time on monitoring EMP implementation. Moreover, they saw this time as being well-spent. In Shanghai and Hangzhou, local authorities planned carefully to prevent loss of income or Idlnd during project implementation. Pipelines were laid in the agricultural off-season and diverted to prevent encroach- ment on private land. This not only ensured that there were no crop losses but also minimized the need for compensatory actions. Topsoil cover was returned to the fields dS planned. Even in instances where ENIP procedures are not followed to the word, it appears that project- = implementing agencies do follow nationally-mandated procedures Shanghai Second Sewerage Project Construction Site. a and plans. These plans ldrgelv and air quality, wastewater dis- moving upstream. Efforts to overlap the procedures laid out in charge or effluent standards, and institute river-basin-management the EMPs prepared for projects air emissions standards are part of approaches are relatively new in financed entirely with doomestic regular EPB monitoring responsi- China. For example, one of the new resources and those prepared with bilities. Water quality is monitored intakes in Hangzhou is potentially Bank or other international assis- three times per year, including at threatened by polluting enterprises tance: project sites. The main parameters that discharge close to the intake in include pH, suspended solids, BOD, a tidal river. Pre-treatment or REASONS FOR NON- COD, toxic chemicals and Various primary treatment by some of the IMPLEMENTATION OF EMP bacteria. Despite thlis, failure to in(dustries is likely to be insufficient RECOMMENDATIONS AND OTHER effectively protect water resources to ensure "good quality" water at MEASURES is a critical problem in many parts the intake. Municipal sewage of China. There are three mdin treatment of this industrial sewage Responsibility for monitoring and reasons for this failure. First, is planned but wvill not become enforcing standards often lies with pollutant discharge fees are operational for at least three more intended to serve as a penalty as years, thereby putting in question 5 Internal research clone bv Bank staff well as an incentive to reduce the advisability of investing in the shows that EA and ENIP implementation pollutant discharge, but they are new intake. Third, differences in may not be as rigorous in rural areas as it not high enough to achieve this the relative autonomy of local is in oirban ones. Even so, the inherent goal. Second, although intakes are agencies impact the degree to conflicts between the EPB's roles as part moved upstream of existing which they can enforce standards. of the local government responsible for pollution sources, with rapid In addition, the mechanisms to raising local revenues on the one hand economic development, polluting monitor non-point polluters and as environmental regulator on the enterprises themselves have been (agricultural enterprises, small- other, come into pldy. T H E W O R L D B A N K G Rl O U P [PBs. Hlowever, because they do cal Office aPpears to be uninvolved in original project dlesigin and in at not generate revenue, their deci- in examination of air quality data, least a few cities, non-Bank sion-making power can be limited. especially for modeling and projects also are prepared and A large portion of [PB budgets forecasting of air quality indicators implemented with greater rigor. comes from local government that requirc meteorological data. budgets. As a result, EPBs must Nevertheless, there is scope for c]elicately balance their allegiance Increasing numbers of Bank further improvement in environ- to SEPA and their regulatory documents now include the mental planning and managemenit. responsibilities with their status ds implementation of the E[MP in Local agencies should have more a local government agency. Finan- the legal agreements of the project, latitude to set their owIn priorities, Cidl issues affect not only general thereby placing "environmental and to set and adhere to stricter environimentdl monitoring but also management" at a level previously standards, in addition to SEPA the EPB's ability to ensure compli- reserved for finanicial management. requiremenits. The "sanitary citv" ance with EMP procedures. EPBs Howvever, a puick sLurvey of project competition demonstrates howv may be responsible for monitoring and loan agreements shows that current institutional arrangements but lack sufficienit resources. In few if any of the recommendations negatively impact environmental flangzhou, the local EPB spent less in the EMP are actually included in mndiagemetil.t Becoming a "sanitary than two percent of its total budget the legal agreements. Thus, there city" brings recognition to the city Oll a(tual monitoring in 1997, are no remedies for not imple- bureaucracy and accolades to the whereas the well-funded provincial menting parts or all of the E.IP mayor. According to SEPA guide- El'B in Shanghai spcnt 20 percent. lines, a sdanitary city must provide Another weak link is the absence secondary treatment for at least 50 The "Environmenital Responsibility of regular "enviroinmental" super- percent of city sewage. However, S'vstem" aims to make the provin- vision in Bank projects. Although this may occur in the absence of cidal governior, mayor, or magistrate project impL-mCntationl plans have anv treatment for the other 50 responsible for environmental begun to include some elements of percent. Secondary and even qcuality in his or her jurisdiction. In environmental supervision, these tertiary treatment is promoted practice, implementation is vari- are not directlv linked to the EMP. without reference to the assimila- able. Administrations mayd still As a result, the EMP continues to tive capacity of the water body conlsi(der economic development be regarded as a bureaucratic into whichl the sewage flows. In goals to be far more urgent and hurdle, and not as a tool that addition, the 50 percent of sewage important than environmental cnsures environmental perfor- which is not being treated at all protection goals, especially when mance. Inadlequate supervision of may not be interceptecl and could there is a perceived trade-off the E[IP could result from a be flowing into drains, rivers and between growth and conservation. combination of budgetary con- lakes throughout the urban area. straints and ihe lack of sufficienitly Finally, the fact that both E['Bs and Thie new emphasis on "centralized trained personnel. Goodland aind local polluters, often city-ows/ne(d pollution control;" which would Mercier in their recent evaluation enterprises, report to th-ie mayor appear to go hand-in-hand with of EMPs note that the lack of results in a conflict of interest. the cnvironmental responsibility implemenItat,on of EMPs, which Local polluters are either not fined system, requires cooperation oftcn contain capacity-building or fiiie( insufficiently to provide among many institutions, which is measures, is itself one of the incentives for changing behavior not a common occurrence. As a reasons why environmental or making needed investmenits. result, investment planning is management continues to suffer.' almost completely under the RECOMMENDATIONS FOR juris(dictioni of city government GENERAL TRENDS IN STRENGTHENING EMP construction bureaus, even though ENVIRONMENTAL MANAGEMENT IMPLEMENTATION [As are submitted to and approved bv the EPB. Groundwater quality Despite these shortcomings, there Recommendations for strengthen- monitoring is ulldler the jurisdic- is an undeniable trend towNard ing EMP implementation and tion of the Geology and Mines improved urban environimenital general enviironmenital manlage- Bureau, which is mandated to management in Chind. The profu- ment of projects, includc those share information with the EPB sion of environmental legislation applicable to borrowers locally an(i only once every fivc years to in the 1990s is indicative of the nationally, those specific to Bank produce an environment report. importance accorded to envirorn- Public health statistics are seldom melntal managemene1t by Chinese 6 Goodiand, Robert and( lean-Roger used by EPBs to make the case for lawmakers. Ruiles for EA in China Xlercicr (1999) Thie Lvolutioin oJ ltiiviroiinifiiial increased environmental expenidi- reflect closely those of the Bank. ,lssessiinrlI iii lie lVorld Bank: Froin "Approval to tures. In additioni, the Meteorologi- The EA process has led to changes Results', Washington DC: The World Bank. T H E W O R L D B A NJ K G3 R 0 U P