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:
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
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.
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.
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:
(ii) Tent ages,
(iii) Tourist lodge (2 stories)
(v) Service centre,
(vi) Meditation centre,
(vii) Medical facility centre,
(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.