1.

INTRODUCTION
The environmental issues likely to develop during project construction and operation
phases could be minimized by making necessary provision in the project design and
adopting Plan Environmental Management (EMP). The Environmental Management Plan
(EMP) covers the design, construction, operation and maintenance phases of each project
component. The EMP identifies the key environmental issues across the project and
provides strategies and plans for managing them effectively. It also defines the legal
requirements for the project and identifies the regulatory permits and licenses required for
construction activities. The Environment Management Plan (EMP) can be defined as a
site specific plan developed to ensure that the project is implemented in an environmental
sustainable manner where all contractors and subcontractors, including consultants,
understand the potential environmental risks arising from the project and take appropriate
actions to properly manage that risk. EMP also ensures that the project implementation is
carried out in accordance with the design by taking appropriate mitigation actions to
reduce adverse environmental impacts during its life cycle. The plan outlines existing and
potential problems that may adversely impact the environment and recommends
corrective measures where required. Also, the plan outlines roles and responsibility of the
key personnel and contractors who will be in-charge of the responsibilities to manage the
project site.
EMP Covers:
1. Documents methods & procedures to achieve environmental objectives and targets
of EIA.
2. Identifies environmental performance indicators to measure progress towards
achieving targets and objectives.
3. EMP is based on compiled information and data during environmental
screening/EIA.
4. Summarizes targets, objectives and regulations,
5. Nominates the individuals responsible and gives target dates.
Aspects covered by EMP include:
1. Water
2. Air

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 3. Soil
4. Noise
5. Damage to Flora and Fauna
6. Disruption to Users
7. Worker’s Accident Risks
8. Workers’ Health Risks including Hygiene
9. Enhancement of natural and man-made features
Contents of an EMP
1. Brief introduction of project design
2. Major Findings of EIA/screening
3. Environmental Impacts Overview
4. Regulatory/Statutory Requirements
5. Environmental Management Proposed
i. Pre-construction
ii. Construction
iii. Operation
6. Implementation Arrangements
7. Institutional Arrangements
8. Monitoring Mechanism
9. Reporting System
10. Environmental Training and Management Budget
EMP adds more value to:
1. Reduces unforeseen (not predicted) issues/ problems
2. Improves relations with local communities
3. Prevents delays and stoppages
4. Prevents legal disputes
5. Saves time and costs
6. Provides good publicity
7. Reduces financial costs

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1.1 Relation between Environmental Management Plan (EMP) and
Environmental Management Plan (EIA)
1. EIA is analysis of issues and recommendations
2. EIA is documented in an Environmental Assessment Report
3. EMP is an action plan
4. EMP is based on results of EIA

1.2 Scope of EMP

1. Management and mitigation measures - Managing its environmental performance
thereby allowing it to contribute to improved environmental quality by implementing
mitigation measures.
2. Implementation and supervision responsibilities - A process that confirms proper
operation through supervision and monitoring.
3. Monitoring and evaluation requirements - This includes monitoring, counteractive
actions and record keeping.
4. Implementation schedule - This comprises of resources available to the Society,
accountability of contractors, training of operational staff associated with
environmental control facilities and documentation of measures to be taken.
5. Training needs and Budget - The Construction Workers must receive basic training
in environmental awareness, including the storage and handling of hazardous
substances, minimization of disturbance to sensitive areas, management of waste, and
prevention of water pollution.
6. Includes measures to consider during project implementation and operation -
This includes identification of environmental impacts, legal requirements and setting
environmental objectives even during operational phase.
7. Provides actions to be taken to implement these measures - The management will
strive to provide and implement the Environmental Management Plan that
incorporates all issues related to air, water, land and noise.

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1.3 Goals and Aims of EMP
1. Develop procedures to implement project’s mitigation measures & monitoring
requirements.
2. Aims of an EMP are to:
i. Provide auditable commitments to practical and achievable strategies and design
standards.
ii. Develop an integrated plan for comprehensive.
iii. Monitoring and control of project impacts.
iv. Ensure the community that the environmental management of the project is
acceptable.

1.4 Purpose of EMP

1. Minimize negative impacts.
2. Enhance positive impacts.
3. Ensuring environmentally sustainable planning, construction and operations
management.
4. Reduce problems & delays during project implementation.
5. Improve overall project quality.
6. Add value to the project.

1.5 Role of Environmental Management Plan (EMP)

1. Summarize environmental impacts identified in the EA report
2. Identify impacts that must be mitigated
3. Describe mitigation measures
4. Describe monitoring and reporting arrangements
5. Describe assignment of responsibilities and schedules
6. Provide costs estimates for mitigation and monitoring measures

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2. EMP Format
There is no established format for EMP some commonly used formats include:
1. Tabular
2. Verbiage/Text : The format include the following content
i. Summary of impacts
ii. Description of mitigation measures
iii. Description of monitoring program
iv. Institutional arrangements, including training
v. Implementation schedule and reporting procedures
vi. Cost estimates and sources of funds
3. Combination of text and tabular (most common)
4. Self-standing (separate) document vs part of EA report
5. Sometimes can be incorporated in Operational Manual (no separate EMP)
-

Figure 1: EMP Format Example - Combination of text and tabular

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2.1 EMP Requirements for Pre-Construction Phase
The requirements that need to be fulfilled during the pre-construction phase of the
project are as follows:
1. There should be continuous liaison between the Proponent, the EPC contractor and
Landowners along the wayleave to ensure all parties are appropriately informed of
construction phase activities at all times.
2. The Landowners should be informed of the starting date of construction as well as the
phases in which the construction will take place.
3. The EPC contractor must adhere to all conditions of contract including the
Environmental Management Plan.
4. The EPC contractor should plan the construction program taking cognizance of
climatic conditions along the way leave especially wet seasons and disruptions that
can be caused by heavy rains.
5. Where existing private roads are in a bad state of repair, such roads’ condition shall
be documented before they are used for construction purposes. This will allow for
easy assessment of any damage to the roads which may result from the construction
process. If necessary some repairs should be done to prevent damage to equipment.
6. The construction site office must keep a proper record of all complaints received and
actions taken to resolve the complaints.
7. A Project HSE Officer should be appointed by the Proponent and Contractor HSE
officer should be appointed by the EPC contractor to implement this EMP as well as
deal with Landowner related matters.
8. Internal and external environmental inspections and audits should be undertaken
during and upon completion of construction. The frequency of these audits should be
quarterly.
9. The Project HSE Officer should conduct regular inspections along the wayleave in
order to maintain good control over the construction process during the construction
phase.
10. A formal communications protocol should be set up during this phase. The aim of the
protocol should be to ensure that effective communication on key issues that may
arise during construction be maintained between key parties such as the Project HSE

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 Officer, project manager and EPC contractor. The protocol should ensure that
concerns/issues raised by stakeholders are formally recorded and considered and
where necessary acted upon. If necessary, a forum for communicating with key
stakeholders on a regular basis may need to be set up. This could be done through the
EPC contractor’s site office that would meet on a regular basis. The communications
protocol should be maintained throughout the construction phase.

2.2 EMP Requirements for Construction Phase

1. Site preparation: Site clearing along the wayleave will be limited to the width of the
proposed wayleave which is about 60m. Site clearing must take place in a phased
manner, as and when required. Areas which are not to be constructed on within say one
month of time must not be cleared to reduce erosion risks. The area to be cleared must
be clearly demarcated and this footprint strictly maintained. Topsoil from the must be
neatly stockpiled at the edge of the wayleave ready for backfill when required.
2. Establishment of Construction Camps and Materials yards: The proposed 100MW
wind farm and 220kV transmission line project will utilize approximately two
construction camps and laydown areas. The construction camp locations have been
identified based on the ease of access to the wind farm area as well as the transmission
line. Site establishment shall take place in an orderly manner and all required amenities
shall be installed at Camp sites before the main workforce move onto site. The
Construction camp shall have the necessary ablution facilities with chemical toilets at
commencement of construction. The EPC Contractor shall inform all site staff to make
use of supplied ablution facilities and under no circumstances shall indiscriminate
sanitary activities be allowed other than in supplied facilities. The Contractor shall
supply waste collection bins where such is not available and all solid waste collected
shall be disposed of using NEMA approved waste handlers. A Waste Tracking Sheet
required by Legal Notice 121: Waste Management Regulations, 2006 will be obtained
by the EPC contractor and kept on file. The disposal of waste shall be in accordance
with the Waste Management Regulations, 2006. Under no circumstances may any form
of waste be burnt on site.

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2.2.1 Environmental Measure during Construction Phase

2.2.1.1 PROVISION OF COMMUNITY KITCHEN

 A community kitchen could be provided where workers will have their meals. The fuel
used in these community kitchens would be LPG. This will also help avoid pressure for
fuel wood on the adjoining forests.
 The water for drinking purpose would be collected either from the river or from
streams flowing upstream of the labor camps. The water would be stored in tanks and
supplied for use. The water quality in general is good and does not require any
elaborate treatment, apart from disinfection.

2.2.1.2 FACILITIES IN LABOR CAMPS

 Encamping of large number of workers (about 1000) in the project area during the
construction phase is likely to put considerable stress on the ecosystem of the area, if
adequate measures to develop infrastructure in the labor camp are not undertaken. It
would be made mandatory for the contractor to provide adequate facilities at the labor
camps.
 The contractor would also be made to provide a block of large rooms in which about
30-40 workers could stay. Community toilets for each block would be constructed close
by. During winter months, heating facilities in the form of electric heaters or fuel based
heating stoves would be provided to avoid workers engaging in cutting of trees for
heating requirements like heating the room and also the water required for various uses.

2.2.1.3 SEWAGE TREATMENT

 All the workers and staff are proposed to be housed near their work sites.
 During project operation phase, about 25 families will be residing in the area and
about 0.02 MLD of sewage is likely will be generated. Two sewage treatment plants
are proposed to be developed in the project area, for treatment of sewage generated
during project operation phase.

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 It is proposed to provide sewage treatment plants comprising of Aerated lagoon and
Secondary settling tank. The dimensions of the treatment unit are: Aerated Lagoon

Figure 2: Aerated Lagoon

2.2.1.4 SOLID WASTE MANAGEMENT

 The labor colonies will generate substantial amount of municipal wastes.
 A total of about 1.08 tonnes of solid waste/day will be generated from the labor camp.
Adequate facilities for collection conveyance of municipal wastes generated to the
disposal site would be developed.

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 One small covered truck, to collect the solid waste from the common point and
transfer it to the disposal site, would to be put to service.
 A suitable landfill site can be identified and designated to contain the municipal waste
from all the project townships, labour colonies, etc.

2.2.1.5 ENVIRONMENTAL MANAGEMENT IN ROAD

CONSTRUCTION
 Approach roads will have to be constructed to access various construction sites.
 Steeply sloping banks are liable to landslides, which can largely be controlled by
provision of suitable drainage. The basic principle remains to intercept and divert as
much water as possible, before it arrives at a point, where it could trigger landslides.
 The surface hazard of the banks can be best controlled by vegetative measures, but the
difficulty lies in growing vegetation on steeply sloping banks. Several methods
engineering or bio-technical measures or a combination of these can be employed to
stabilize landslides.

2.2.1.6 MUCK DISPOSAL

 The total quantity of muck to be generated during construction phase of the proposed
project is planned to be utilized in a number of activities of the Project such as
inverted filter, earth back fill and for aggregate etc.
 The muck disposal sites cause increased sedimentation in the rivers (though
insignificant compared to natural sedimentation) and totally spoil the visual aesthetics
of the area.

2.2.1.7 MAINTENANCE OF WATER QUALITY

 During project construction phase, sufficient measures have been proposed to avoid
effects of pollution from various other sources
 It is proposed to treat the sewage generated from various labor camps in septic tanks.
The septic tanks shall be located so as not to pollute the drinking water sources.

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 A community toilet would be provided per 20 persons. The sewage from community
toilets would be treated in septic tanks. For each 500 persons, one septic tank would be
provided.
 The effluent from these septic tanks would be disposed off through absorption
trenches.
 A septic tank is a key component of the septic system, a small-scale sewage treatment
system common in areas with no connection to main sewage pipes provided by local
governments or private corporations.
 The septic container has five functions:
i. It receives the wastewater from the house
ii. Separates the solids from the liquids
iii. Stores the solids
iv. Decomposes the solids
v. Sends the effluent wastewater out to the drain field.

Figure 3: Septic Tank

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2.2.1.8 PROPOSED HEALTH FACILITIES AT CONSTRUCTION
SITES AND LABOR CAMP
 First aid facility is to be provided at each of the major construction sites, so that
workers are immediately attended to in case of an injury or accident. This first-aid post
will have the following
 Facilities:
i.First aid box with essential medicines including ORS packets
ii.First aid appliances –splints and dressing materials
iii.Stretcher etc.

Figure 4: First Aid Kit

2.2.1.9 CONTROL OF NOISE POLLUTION

 The likely sources of noise pollution are operation of machinery and equipment's.
 To reduce the noise from machinery, it is suggested that mufflers provided with the
exhaust be kept in good condition during operation.
 A muffler (silencer in British English) is a device for reducing the noise emitted by
the exhaustaof an internal combustion engine

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 Similarly the contractors would be required to provide earplugs to the labor engaged in
all the underground works.

Figure 5: Ear Plugs

2.3 EMP Requirements for Operation Phase

The overall goal for the Operational Environmental Management Program (OEMP) is to
ensure that the operation of the facility does not have unforeseen negative impacts on the
environment and to ensure that all impacts are monitored and the necessary corrective
action is taken timorously. In order to achieve this goal, it is necessary to operate in a
way that:
1. Ensures that operational activities are properly managed in respect of environmental
aspects and impacts.
2. Enables the operational activities to be undertaken without significant disruption to
other land uses in the area, in particular with regards to noise impacts, farming
practices, traffic and road use, and effects on local residents

3. Minimizes impacts on birds and other fauna found onsite.

4. Monitors and evaluates the impacts of the WEF on birds and bats in order to mitigate
appropriately.

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2.4 Follow-Up and Supervision Of EMP Implementation
 EMPs should be periodically reviewed, especially when: Environmental impacts are
associated with the operational rather than construction phase (Example: power plant
or mining operations);
 Revisions to EMP may be necessary when: Final EIA produced after project appraisal
renders the original EMP obsolete or irrelevant;
 Site-specific EMPs produced after project appraisal need to be checked during project
supervision

2.5 Supervision of EMP

 Implementation (enforcement) of EMPs has often been problematic
 Assignment of a dedicated Environment Specialists to PIU(project implementation
unit) is good practice
 Monitoring/Reporting Program needs to cover environmental indicators
 Legal Coverage/Bidding and Contracting Documents
 Active supervision is needed, including reshaping mitigation measures, institutional
assignments, etc.

2.6 Mitigation Plan

 Defines the key environmental (and social) issues which should be managed.
 Describes specific mitigating measures to manage each possible impact, including
specific actions to be achieved.
 Identifies the authorities responsible for mitigation implementation.
 Includes associated estimated costs.

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 Pre-

Phase
Phase
Phase

Operational
Construction
Construction
Project Activity

Potential Environmental
Impacts

Proposed Mitigation
Measures(s)
(incl. Legislation & regulations)

Institutional Responsibilities

Figure 6: Example of table for Mitigation

(incl. Enforcement and
coordination)

Cost Estimates

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 and
Pre-
Proposed Mitigation

Phase
Phase
Phase
Measure

all Phases
Operation

Maintenance
Construction
Construction

Total Cost for

Parameters
to be Monitored

Location

Measurements
(incl. Methods &
equipments)

Frequency of
Measurement

Responsibilities
(incl. review and
reporting)

Figure 7: Example of table for Mitigation in Environmental Monitoring Plan

Cost (equipment

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& individuals)
 Example: Environmental Management Plan
For a Power Plant Construction Project in X-land
Mitigation: Construction Phase

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 Example: Environmental Management Plan
For a Power Plant Construction Project in X-land
Mitigation: Operation Phase

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 Example: Environmental Management Plan
For a Power Plant Construction Project in X-land
Monitoring: Construction Phase

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 Example: Environmental Management Plan
For a Power Plant Construction Project in X-land
Monitoring: Operation Phase

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