Impact Assessment Framework
Impact Assessment Framework
World Bank
Minsheng Bank
July 14, 2009
Table of Contents
1. Introduction..................................................................................................................1
2. EA Procedures.............................................................................................................2
A. Sub-Project Preparation and Construction Phase.......................................................2
1) Sub-project Review and Categorization............................................................2
2) Environmental Assessment (EA) Documentation.............................................3
3) Applicable Environmental Standards................................................................5
4) Environmental Management System.................................................................5
5) Public Consultation and Disclosure..................................................................6
6) Grievance Mechanism.......................................................................................8
7) Review and Approval of EA.............................................................................8
8) Related Conditions and Responsibilities........................................................10
B. Implementation Phase...............................................................................................10
9) Monitoring and Reporting..............................................................................10
3. Institutional Arrangements........................................................................................11
B. Implementation Phase
9. Monitoring and Reporting
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2. EA Procedures
After the sub-borrower obtains all required Chinese environmental approvals, it will be
required to submit to Minsheng Bank an information package consisting of items outlined
in paragraph 1 below (Sub-project Review and Categorization) to demonstrate that the
Chinese EA procedures have been followed in strict accordance with Chinese EA
regulations. Minsheng Bank will review this material and if necessary, request additional
supplementary information from the sub-borrower to insure that the World Bank EA
procedures are also followed. Details of these requirements are presented below.
Minsheng Bank is responsible for project screening. After receiving official project
approvals from the Chinese environmental authorities, the sub-borrower will submit the
following Information Package to Minsheng Bank:
Minsheng Bank will then review materials and will exclude from financing any proposed
sub-project that includes, or is linked or connected to any production facility included in
the Exclusion List presented in Annex A.
If the project is not excluded based upon the Annex A Exclusion List, Minsheng Bank
will then make an independent evaluation based upon World Bank EA screening policies
and assign the sub-project to one of three Categories: Category A, B or C using the
World Bank screening criteria presented in Annex B.
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If one or more criteria are considered “High Impact” the sub-project should be tentatively
assigned Category A.
If one or more criteria are considered “Modest Impact” and no criteria are considered
“High Impact” the sub-project should be assigned Category B.
If all criteria are considered “Minor or No Impact” the sub-project should be considered
Category C.
The independent environmental risk evaluation based upon World Bank screening
procedures for environmental risk and the Chinese screening decision can result in the
possible outcomes as summarized in the Table below:
The most likely outcomes are highlighted in yellow. However, since the Chinese and
World Bank screening procedures are independent, it is possible under some
circumstances for Chinese screening procedures to yield different outcomes than the
World Bank screening approach (e.g. Chinese system may require an EIA Table whereas
the World Bank procedures would indicate a Category A EIA would be required etc.).
Clearly then there are six possible outcomes as follows:
For any sub-project that results in a Category A decision, Minsheng Bank will be
required to have the World Bank verify and confirm the Category A rating. Minsheng
Bank should provide the World Bank the Information Package described in paragraph 1
and the completed Environmental Risk Criteria Table (see Annex B). Any additional
information supporting the Category A decision (e.g. field trip reports etc.) which
Minsheng Bank may possess should also be included.
In all Cases presented below, the sub-borrower is responsible for preparing the required
EA documentation.
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Case I: Category A-Full Chinese EIA
The EIA Report will be prepared in accordance with the Chinese EIA requirements and
in accordance with World Bank policy (as detailed in OP 4.01 Annex B-Content of an
Environmental Assessment Report for a Category A or see Annex C of this Framework).
Minsheng Bank will review the approved Full Chinese EIA and in those cases where the
content of the approved Chinese EIA document differs from the content required for a
World Bank Category A project, Minsheng Bank will require the sub-borrower to prepare
a separate EIA Addendum with any supplemental information which may be required by
the World Bank EA policy. Normally, this includes an EA Executive Summary and an
Environmental Management Plan (EMP). However, there may be additional information
not included in the Full Chinese EIA that would be required in the World Bank EIA. The
World Bank Addendum (especially the Executive Summary) is to be prepared in both
English and Chinese.
To the greatest extent possible, the sub-borrower should utilize the information presented
in the approved Chinese EIA Table in the preparation of the World Bank Category A EIA
document. Minsheng Bank will review the two documents to ensure they are consistent in
terms of environmental issues, mitigating measures, monitoring requirements and
institutional responsibilities for mitigation and monitoring. However, given the nature of
the World Bank Category A EIA, it is anticipated that substantially more information
would be required, including, but not limited to an Executive Summary and an EMP.
Minsheng Bank should discuss with the World Bank the language requirements for the
Category A EIA document.
To the greatest extent possible, the sub-borrower should utilize the information presented
in the approved Full Chinese EIA in the preparation of the World Bank EMP document.
Minsheng Bank will review the two documents to ensure they are consistent in terms of
environmental issues, mitigating measures, monitoring requirements and institutional
responsibilities for mitigation and monitoring. The first two EMPs should be prepared in
both English and Chinese.
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To the greatest extent possible, the sub-borrower should utilize the information presented
in the approved Chinese EIA Table in the preparation of the World Bank EMP document.
Minsheng Bank will review the two documents to ensure they are consistent in terms of
environmental issues, mitigating measures, monitoring requirements and institutional
responsibilities for mitigation and monitoring. The first two EMPs should be prepared in
both English and Chinese. If agreement is reached with the World Bank, all subsequent
EMPs need only be prepared in Chinese.
All Category A and Category B sub-projects will require preparation of an EMP, which
will include mitigating actions to assure compliance with environmental standards of
performance. If both Chinese and World Bank standards are available for a particular
mitigating measure, the stricter of the two standards would apply. For example, if the
environmental issue of concern is “noise” and the World Bank noise standard is stricter
than the Chinese standard, it is expected that the mitigating measure selected would be
effective in meeting the stricter World Bank standard.
The Mitigation section of the EMP (see Annex D) should include a column to indicate
the applicable standard appropriate to the particular mitigating measure: either the
Chinese standard or the World Bank Standard. World Bank standards may be found in
the World Bank Group Environmental, Health, and Safety Guidelines (known as the
"EHS Guidelines") which are now in use.
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instituted by the sub-borrower to address any concerns the affected public or
communities may have during project implementation.
The evaluation should include a clear indication that sufficient personnel and funds are
available from the sub-borrower to perform these functions on an ongoing basis.
Public disclosure provides affected groups or individuals the opportunity to examine the
final approved EA document so that they can review the mitigating measures agreed
upon and the responsibilities for implementing them.
Since Chinese and World Bank consultation and disclosure requirements differ
somewhat, requirements for the five cases involving EA documentation are presented
below:
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Minsheng Bank should consult with the World Bank to establish EA documentation and
language requirements for disclosure.
Chinese language versions of the EA documentation and the record of the public
consultations should be placed at a public location near the project site and on the sub-
borrower website.
Minsheng Bank should consult with the World Bank to establish EA documentation and
language requirements for disclosure.
Chinese language versions of the EA documentation and the record of the public
consultations should be placed at a public location near the project site and on the sub-
borrower website.
Chinese language versions of the World Bank EMP, and the record of the public
consultation should be placed at a public location near the project site and on the sub-
borrower website.
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accordance with World Bank EA policy to discuss the issues to be addressed in the EMP
or to discuss the draft EMP itself. Therefore, for the sub-project, the sub-borrower will be
required to perform at least one public consultation to discuss the environmental issues
and the content of the EMP. Documentation for the consultation should follow the
requirements presented in Annex E and be submitted to Minsheng Bank as part of the
sub-project file.
Chinese language versions of the World Bank EMP, and the record of the public
consultation should be placed at a public location near the project site and on the sub-
borrower website.
Chinese language versions of the World Bank EMP, and the record of the public
consultation should be placed at a public location near the project site and on the sub-
borrower website.
6) Grievance Mechanism
As indicated above the sub-borrower will submit the Chinese EIA documentation to
appropriate Chinese environmental authorities for review and approval. Only after
receiving official approval from the Chinese environmental authorities, will the sub-
project be eligible for consideration of a loan from Minsheng Bank under the Project.
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reduce energy use. Generally speaking these types of sub-project have either minor or no
adverse environmental impacts and provide environmental benefits (reductions in local
pollution such as dust and sulfur dioxide emissions or reductions in emissions of
greenhouse gases such as carbon dioxide).
The sub-borrower must also validate that the existing production facility which will be
defined as the “connected project” has a valid, approved EA1 if required by the Chinese
environmental authorities and a verification that the existing production facility(ies) is
(are) operating with all appropriate environmental approvals, permits, licenses, etc.
required by Chinese environmental regulations. This is only required if the existing
production facility was constructed after Chinese EA regulations were officially adopted
or Chinese environmental authorities had a retroactive EA requirement for the facility.
For any World Bank Category A or Category B sub-project, Minsheng Bank must review
the EA documentation and ascertain that the content of the of the World Bank EA
documentation (EIA, EIA Supplement or EMP) is consistent with the content of the
Chinese EA documentation (Full Chinese EIA or Chinese EIA Table).
In addition to the English language versions of the EA documentation agreed upon with
the World Bank as discussed above in Section 5, Minsheng Bank will also submit the
information tabulated below to the World Bank as part of the package for World Bank
review and approval (or “No Objection”).
Minsheng Bank will not approve any loan under the Project until it receives approval or
“No Objection” from the World Bank.
1
The World Bank environmental safeguard policies require an evaluation of any activities which although
not directly involved with the World Bank investment may be “linked” to that investment and whose
operational performance is dependent upon the World Bank investment. For example, if the World Bank
was financing a transmission line extending from an existing power station, the policy would require a
verification that the power station was operating with all appropriate environmental approvals, permits,
licenses, etc. required by the sub-borrowers’ country.
9
For the first two Category B sub-projects, Minsheng Bank will submit English language
versions of the World Bank EMP, the record of the public consultation, to the World
Bank for review and approval (or “No Objection”). In addition, Minsheng Bank should
discuss with the World Bank, if there is any additional English language information
documentation requirements. For example, English language versions for any or all of the
following information may be of interest to the World Bank:
Minsheng Bank will not approve the first two loans under the Project until it receives
approval or “No Objection” from the World Bank. If after the first two loans, the World
Bank is satisfied that Minsheng Bank is performing EA review procedures as outlined in
this Framework in a satisfactory manner, no further World Bank prior approvals will be
required for Category B sub-projects. Subsequently, only Minsheng Bank approvals of
Chinese language EMPs would be required.
Minsheng Bank will ensure that an appropriate clause is included in sub-borrower loan
agreement obligating the sub-borrower to exercise due diligence in implementing the
mitigation, monitoring, and reporting measures specified in the EMP and strictly follow
the procedures according to related Chinese laws and regulations in the event of chance
finds of culturally significant artifacts or sites
B. Implementation Phase
The sub-borrower is responsible for insuring that all the requirements of the World Bank
EMP are properly implemented.
Minsheng Bank
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During the normal sub-project supervision activities, Minsheng Bank will check with
local environmental authorities to determine if the sub-project implementation is meeting
all specified EMP requirements. Minsheng Bank should make supervision visits to sub-
project sites confirming that the EMPs are being faithfully implemented. A supervision
report covering environmental management should be included in the overall site visit
report.
Minsheng Bank should require each sub-borrower to include, as part of their normal
reporting, a section on environmental performance with respect to the sub-project
investment, including any critical mitigating actions taken and any significant
environmental incidents. However, if during a site visit, Minsheng Bank determines that
environmental management procedures are not being followed adequately, Minsheng
Bank should request more frequent reporting (semi-annually or quarterly) until the sub-
borrower demonstrates the situation has been corrected.
Minsheng Bank will include an environmental section in any report prepared for the
World Bank. As appropriate, the Section will discuss details of any environmental issues
that occurred during the reporting period and the actions taken by Minsheng Bank and/or
any of their sub-borrowers to resolve them.
Sub-borrower
The sub-borrower should carefully document monitoring results in accordance with the
Monitoring Plan included in the EMP and identify any necessary corrective or preventive
actions taken during the monitoring period, as well as the results/outcome of similar
actions that may have been taken in the previous reporting period.
3. Institutional Arrangements
The Project will be administered by the Trade and Finance Department of Minsheng
Bank. Within this Department, the Credit Assessment Unit is responsible for risk
management and will be assigned the responsibility for properly implementing this
Framework. Minsheng Bank will designate staff to manage environmental risk and assure
that procedures specified in the Framework Document are properly followed during
implementation. In addition, qualified Chinese environmental consultants will be
contracted to support the risk management staff for any technical reviews or any other
activities that are their responsibility. World Bank safeguard specialists will provide
training to perform the tasks required under this Framework in the identification and
management of environmental risk in project evaluation and implementation.
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Annex A: Exclusion List
Production or trade in any product or activity deemed illegal under host
country laws or regulations or international conventions and agreements,
or subject to international bans, such as pharmaceuticals,
pesticides/herbicides, ozone depleting substances, polychlorinated
biphenyls (PCBs), wildlife or products regulated under CITES
Production or trade in weapons or munitions
Gambling, casinos, and equivalent enterprises
Production or trade in radioactive materials (this does not apply to the
purchase of medical equipment, quality control (measurement) equipment
and any equipment where the World Bank considers the radioactive source
to be trivial and/or adequately shielded).
Production or trade in unbounded asbestos fibers. This does not apply to
purchase and use of bonded asbestos cement sheeting where the asbestos
content is less than 20%.
Drift net fishing in the marine environment using nets in excess of 2.5 km
in length
Production or activities involving harmful or exploitive forms of forced
labor/harmful child labor
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Annex B: Environmental Risk Criteria
CRITERIA Minor Modest High Comment
or Impact Impact
No
Impact
1 Does the existing enterprise have a valid
operating permit, licenses, approvals etc.?
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alter downstream river basin
characteristics?
6 Will the sub-project generate air
emissions that:
violate Chinese air emission
standards
result in a long term violation of
Chinese air quality standards
release pollutants that affect
downwind sensitive receptors
(hospitals, schools, population
centers, sensitive crops etc.)
harm sensitive ecosystems (e.g.
forests)
impact a natural habitat or protected
area
are difficult, expensive, or hard to
control
are inconsistent with EHS Guidelines
or recommendations
7 Will the sub-project generate noise levels
that:
violate Chinese noise standards
impact particularly sensitive
receptors (natural habitats, hospitals,
schools, local population centers)
are inconsistent with EHS Guidelines
or recommendations
8 Will the subproject consume, store,
produce or utilize hazardous materials
that:
require special permits or licenses
require licensed or trained personnel
are outlawed or banned in EU or
Western countries
are difficult, expensive, or hard to
manage
are inconsistent with EHS Guidelines
or recommendations
9 Will the sub-project be located within or
close to officially protected areas or areas
under consideration by the Government
for official protection status?
10 Will the sub-project potentially impact
areas of known local, regional or national
cultural heritage significance? (During
the public consultation, the local
population should be asked to provide
information about any sites or structures
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which are not on any official list, but
which they consider to be of significance
and which they think should be protected)
11 Has the local population or any NGOs
expressed concern about or opposition to
the sub-projects’ environmental aspects
12 Will the sub-project involve any
construction outside the existing plants
which might require land acquisition or
resettlement
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Annex C: Content of an Environmental Assessment
Report for a Category A Project
1. An environmental assessment (EA) report for a Category A project focuses on the significant
environmental issues of a project. The report's scope and level of detail should be commensurate
with the project's potential impacts. The report submitted to the Bank is prepared in English,
French, or Spanish, and the executive summary in English.
2. The EA report should include the following items (not necessarily in the order shown):
(a) Executive summary. Concisely discusses significant findings and recommended
actions.
(b) Policy, legal, and administrative framework. Discusses the policy, legal, and
administrative framework within which the EA is carried out. Explains the environmental
requirements of any cofinanciers. Identifies relevant international environmental
agreements to which the country is a party.
(c) Project description. Concisely describes the proposed project and its geographic,
ecological, social, and temporal context, including any offsite investments that may be
required (e.g., dedicated pipelines, access roads, power plants, water supply, housing, and
raw material and product storage facilities). Indicates the need for any resettlement plan
or indigenous peoples development plan). Normally includes a map showing the project
site and the project's area of influence.
(d) Baseline data. Assesses the dimensions of the study area and describes relevant
physical, biological, and socioeconomic conditions, including any changes anticipated
before the project commences. Also takes into account current and proposed development
activities within the project area but not directly connected to the project. Data should be
relevant to decisions about project location, design, operation, or mitigatory measures.
The section indicates the accuracy, reliability, and sources of the data.
(e) Environmental impacts. Predicts and assesses the project's likely positive and negative
impacts, in quantitative terms to the extent possible. Identifies mitigation measures and
any residual negative impacts that cannot be mitigated. Explores opportunities for
environmental enhancement. Identifies and estimates the extent and quality of available
data, key data gaps, and uncertainties associated with predictions, and specifies topics
that do not require further attention.
(f) Analysis of alternatives. Systematically compares feasible alternatives to the proposed
project site, technology, design, and operation--including the "without project" situation--
in terms of their potential environmental impacts; the feasibility of mitigating these
impacts; their capital and recurrent costs; their suitability under local conditions; and their
institutional, training, and monitoring requirements. For each of the alternatives,
quantifies the environmental impacts to the extent possible, and attaches economic values
where feasible. States the basis for selecting the particular project design proposed and
justifies recommended emission levels and approaches to pollution prevention and
abatement.
(g) Environmental management plan (EMP). Covers mitigation measures, monitoring,
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and institutional strengthening; see outline in OP 4.01, Annex C, or Annex D.
(h) Appendixes
(i) List of EA report preparers--individuals and organizations.
(ii) References--written materials both published and unpublished, used in study
preparation.
(iii) Record of interagency and consultation meetings, including consultations for
obtaining the informed views of the affected people and local nongovernmental
organizations (NGOs). The record specifies any means other than consultations
(e.g., surveys) that were used to obtain the views of affected groups and local
NGOs.
(iv) Tables presenting the relevant data referred to or summarized in the main
text.
(v) List of associated reports (e.g., resettlement plan).
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Annex D: Environmental Management Plan Format
Sub-Project Description
Present a brief description of the Sub-project. Include the nature of the investment, the location, and any characteristics of the area that
are of particular interest, e.g. near a protected area, area of cultural, historical, religious interest etc. Also, very briefly describe the
general land use characteristics (farming, small industry etc.), and the location(s) of the nearest population centers. Provide a brief
summary of the major Sub-project related environmental issues, how will they be managed, who will manage them and what, if any,
are the environmental risks.
MITIGATION PLAN
Applicable Standard Cost of Start End
Phase Issue Mitigating Chinese World Mitigation Responsibility* Date Date
Measure Bank/IFC (If
Substantial)
Construction
Operation
* Items indicated to be the responsibility of the contractor should be specified in the bid documents
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MONITORING PLAN
Operate
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INSTITUTIONAL ARRANGEMENTS
A brief narrative discussion should be prepared to indicate how monitoring data is going
to be used to maintain sound environmental performance—who collects the data, who
analyzes it, who prepares reports, whom the reports are sent to and how often, what
he/she does with the information.
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Annex E: Consultation with Local NGOs and Project-
affected Groups
Provide documentation of the following:
Who attended
Meeting Program/Schedule
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