Understanding the Implementation of

Environmental and Social Management

Framework (ESMF) of P3TB

Mitzi Pollisco
Environmental Safeguard Specialist
 Environmental and Social Management Framework (ESMF)

• Different methods and tools can be used to identify and assess the
environmental and social risks and impacts of a project (EIA, SEA, CIA, etc)

• The use of these tools can vary depending on the baseline data available and
the nature and significance of the environmental and social risks and impacts

• The ESMF is an appropriate instrument to examine the risks and impacts of a

project that consists of a program and/or series of subprojects, and the risks and
impacts cannot be determined until the program or subproject details have been
identified,

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 Environmental and Social Management Framework (ESMF)

• Establishes a unified process for addressing all E & S safeguards issues on subprojects
from preparation, thorough review and approval, to implementation

• The ESMF serves as a guide to implementing agencies to adequately screen and

assess environmental and social impacts of proposed activities and to propose the
required safeguard instruments

• The E & S instruments are to be used only after the Detailed Engineering Design (DED) for
the subprojects have been prepared, and locations (direct impact areas) of the potential
activities under the subprojects are already final

• Ensures that the project interventions will be undertaken in a manner that avoids
and/or minimizes E & S risks and impacts as much as possible.

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 Procedure for the Implementation of ESMF

• Eligibility screening of subprojects

Step 1

• Technical screening of E & S impacts

Step 2

• Development of E & S instruments

Step 3

• Approval of E & S instruments

Step 4

• Implementation, supervision, monitoring and reporting

Step 5

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 Step-1: Eligibility of Screening Using the OP  
 Ascertain whether the sub-project can be funded under the project and whether
the sub-project fulfils all the environmental and social requirements of World
Bank Operational Policies.

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 Step-1: Eligibility of Screening (2) 

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 After having categorized the subprojects, the Indonesian Ministry of Environment Regulation
No. 5 Year 2012 is followed; it states the requirements for activities to be required to have
AMDAL (full environmental and social impact assessment).

Below the threshold, the less intensive “environmental management effort” (UKL) and
“environmental monitoring effort” (UPL) must be prepared, except in cases of negligible
impact.

UKL-UPL is comparable to the ESMP that is often used for Category B projects being
implemented under Bank safeguards.

When impacts are negligible, in projects that are under Category C of the Bank safeguards, the
Indonesian system provides for a third instrument, a Statement of Environmental Management
and Monitoring Undertaking (SPPL) to be executed by the proponent.

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 World Bank OP 4.01 (Environmental Assessment)

 Considered to be an “umbrella policy;”

 Requires environmental and social issues to be considered in an “integrated manner”

 There are some cross-references among the various Bank OPs

 The Bank’s safeguard system exhibits a relatively horizontal architecture as the various WB OPs
can operate independently of one another

 Requires the EA to take into account impacts on watersheds and estuaries and promotes the
protection of natural habitat and ecological functions of the area

 Requires all Environmental and Social concerns to be taken into account for the design and siting
of all projects

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 WORLD BANK SAFEGUARD SYSTEM

Terrestrial, freshwater or marine

Mangrove, Beach, Dipterocarps, Mossy, Pine, etc.

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 Step 2 Technical Screening
How the ESMF applies varies by type of Project activity.

1. The ITMP Term of Reference specifies the use of IFC Guidance Note No 6 (version 2019) d in the
determination of critical natural habitat to ensure that these would not be degraded or converted to other
uses

Natural Habitats - Areas composed of viable assemblages of plant and/or animal species of largely native origin,
and/or where human activity has not essentially modified an area’s primary ecological functions and species
composition.

Any conversion or degradation is mitigated according to the mitigation hierarchy (IFC 2019)

Mitigation Hierarchy as an option for mitigation has not been mentioned in the WB OP/BP

The identification of “no-go zones” based on sensitivity of natural or cultural features, in early consultations with
all stakeholders, including IPs and vulnerable groups, etc. was recommended by the WB OP

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 2. In the case of sectoral plans, also financed under Component 1, the ESMF requires that
outputs include a preliminary assessment of environmental and social impacts, based on the
World Bank safeguards policies and Indonesian laws and regulations and guides the
preparation of the necessary safeguards instruments for the sectoral investment that will be
implemented.

3. The types of investments to be supported under Component 2 (road quality and basic services) are
known, but locations, sizes, and timing are not. The framework approach is appropriate in this situation.
The ESMF provides for: screening proposed investments, guiding the identification of impacts,
facilitating the preparation of safeguards instruments, reviewing and approving the instruments, and
monitoring their implementation.

4. The ESMF calls for inclusion of environmental awareness training in Component 3 (promoting local
participation) programs, including relevant aspects of EHS Guidelines, and including the industry sector
guidelines for tourism and hospitality development.

5. For Component 4, the ESMF calls for awareness raising of relevant aspects of EHS Guidelines,
including the industry sector guidelines for tourism and hospitality development, amongst business
license applicants/investors.

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 Step 3: Development of E & S instruments 
• Appropriate E & S risk management instruments and mitigation measures should be
identified according to the nature and extent of the potential negative impacts.

• This step focuses on the preparation of appropriate E & S instruments such as ESIA or
ESMP in accordance with the screening result. 

• ESIA: For activities which may involve substantial risks including community health and
safety, sub-project proponents will be required to conduct an environmental and social
impact assessment (ESIA)

• Environmental and Social Management Plans (ESMP): will briefly include the sub-project
description; E & S background of the sub-project areas, includes maps showing locations of
the sub-project and site specific activities and/or process as appropriate; the potential
impacts and proposed mitigation measures; and the implementation and monitoring
arrangement and budget. Public consultation is to be carried out as part of the ESMP
preparation. 

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 How the ESMF applies varies by type of Project activity.

1. The ITMP Terms of Reference specifies the use of IFC Guidance Note No 6 (version 2019) d in the
determination of critical natural habitat to ensure that these would not be degraded or converted to other
uses

Natural Habitats - Areas composed of viable assemblages of plant and/or animal species of largely native origin,
and/or where human activity has not essentially modified an area’s primary ecological functions and species
composition.

Any conversion or degradation is mitigated according to the mitigation hierarchy (IFC 2019)

Mitigation Hierarchy as an option for mitigation has not been mentioned in the WB OP/BP

The identification of “no-go zones” based on sensitivity of natural or cultural features, in early consultations with
all stakeholders, including IPs and vulnerable groups, etc. was recommended by the WB OP

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 The Mitigation Hierarchy

https://www.forest-trends.org/bbop/bbop-key-concepts/mitigation-hierarchy/

Set asides are areas over which Borrower has management control. Excluded for development, targeted for
conservation; equivalent to Avoidance (Av) mitigation measures,

Offsets (Ofs) are intended to compensate for significant residual impacts and must demonstrate no net loss
 Ecosystem Services

Ecosystem services are the benefits that people, including businesses, derive from ecosystems.

Ecosystem services are organized into four types:

i) provisioning services - products people obtain from ecosystems

e.g., food, freshwater, timber, fibers, medicinal plants

(ii) regulating services - benefits people obtain from the regulation of ecosystem processes
e.g., surface water purification, carbon storage and sequestration, climate regulation,
protection from natural hazards

(iii) cultural services - nonmaterial benefits people obtain from ecosystems

e.g., may include natural areas that are sacred sites and areas of importance for
recreation and aesthetic enjoyment

(iv) supporting services - natural processes that maintain the other services
e.g., soil formation, pollination, nutrient cycling, habitats for species

(Source: Millennium Ecosystem Assessment Homepage, “Millennium Ecosystem Assessment”, 2006, http://www.millenniumassessment.org.)

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 Step 3: Development of ES instruments 
To support activities of the subprojects, mitigation measures per OP triggered such as SOP/ECOP, LMP,
Resettlement Planning Framework, Indigenous Peoples Planning Framework, Guidance on Terms of
Reference (TOR) for EIA and ESMP will be accomplished as needed. Also, the management of
environmental impacts for Category C subprojects (SPPL).

Will be site-specific, and in proportion/appropriate to the hazards and risks associated with the particular
activities that will be implemented by the Contractor/s; should address site-specific environmental and
OHS issues.
 
In case of existing facilities, measures to rectify the prevailing risks and adverse impacts identified in the
environmental and social audits or due diligence reports will also be included. A suite of other mitigation
measures required under other applicable ESSs form part of the ESMPs.

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Scope of Impacts to be Assessed Based on OP 4.01

EA takes into account the natural environment (land, air, water), human H & S; Social aspects (IR, IPs, and
PCR); and transboundary and global environmental aspects. EA considers natural and social aspects in an
integrated way

EA evaluates a projects potential environmental risks and impacts in its area of influence… including all its
ancillary aspects such as power transmission corridors, pipelines, canals, tunnels, relocation and access roads,
borrow and disposal areas, and construction camps, as well as unplanned developments induced by the project
(e.g. spontaneous settlement, logging, or shifting agriculture along access roads).

The Project area of influence is the area likely to be affected by Component 2

investments and activities recommended in the ITMPs for the tourism
destinations and elaborated in downstream plans as well as by unplanned
developments induced by those activities (e.g., spontaneous settlements and
informal businesses) and cumulative impacts.
 Environment, Health and Safety (EHS) Guidelines

The EHS Guidelines are technical reference

documents with general and industry-specific
examples of Good International Industry Practice
(GIIP)

These Guidelines are applied as required, after

the conduct of the Environmental and Social
assessment

Designed to be used together with the relevant

Industry Sector Guidelines which can be found
at:
https://www.ifc.org/wps/wcm/connect/
topics_ext_content/ifc_external_corporate_site/
sustainability-at-ifc/policies-standards/ehs-guidelines/
ehsguidelines

Should be considered in Contractor’s CEMP

https://www.ifc.org/wps/wcm/connect/29f5137d-6e17-4660-b1f9-02bf561935e5/Final%2B-%2BGeneral
%2BEHS%2BGuidelines.pdf?MOD=AJPERES&CVID=nPtguVM
 Most of the risks can be mitigated by inclusion of good construction practices and basic EHS
management measures in environmental management plans (RKL and UKL)
Construction contracts incorporating ESHS performance standards and by supervision and
enforcement of their implementation by supervision ESHS personnel, including attention to provision
and use of PPE and use of signage and barricades at locations of hazards.

(Source: Draft ESSA ITDP PforR P157599)

Exception: visual intrusion - this needs to be taken into account in siting and design of
infrastructure in the Integrated Tourism Master Plans

Even in no regret projects especially inside WH Sites

The specific use of the WH Operational Guidelines (2011), Safeguard Instruments such
as the IUCN EA Checklist for ESA and the HIA developed by ICOMOS was suggested

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 Step 4: Stakeholder Engagement and Disclosure
 
Before commencement of implementation of a sub-project, the prepared ES instruments
together with the screening checklists and due diligence will be submitted to the World Bank
for disclosure on the Bank’s websites and WB ES clearance. Public disclosure of the ES
instruments in the country and the project areas will also be required.

Monitoring of environmental and social performance will be in accordance with the legal
agreement (including the ESCP).

The project’s ESMP (a stand-alone document or as captured in the ESCP) sets out the
monitoring objectives and types of monitoring for the project’s environmental and social
impacts and mitigation measures. Indicators selected for monitoring are based on the
project’s baseline data. 

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 Step 5: Implementation, Supervision, Monitoring and
Reporting  
Monitoring will normally include information to track performance, and establishing relevant
operational controls to verify and compare compliance and progress. This information will
serve as inputs to regular reports as set out in the ESCP for submission to the Bank.

Such reports will serve as accurate and objective record of project implementation, including
compliance with the ESCP and the requirements of the ESSs. The reports will include
information on stakeholder engagement conducted during project implementation in
accordance with ESS 10.

The Borrower (RIDA?) will ensure that adequate institutional arrangements, systems,
resources and personnel are in place to carry out monitoring. They will also engage
stakeholders and third parties to complement or verify its own monitoring activities.

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 Step 5: Implementation, Supervision, Monitoring and
Reporting  
Monitoring of environmental and social performance will be in accordance with the legal
agreement (including the ESCP).

The project’s ESMP (a stand-alone document or as captured in the ESCP) sets out the
monitoring objectives and types of monitoring for the project’s environmental and social
impacts and mitigation measures. Indicators selected for monitoring are based on the
project’s baseline data. 

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 THE AIDE MEMOIRE
Performance of each policy in the implementation until December 2021
Operational Policy Performance Remarks
OP 4.01 Moderately The project prepares the environmental documents … and meets the requirements of the
Environmental Satisfactory ESMF
Assessment (MS)
 The environmental documents were integrated in the bidding documents during
procurement
 The counterpart-funded subprojects under APBN and APBD for the 3 destinations of batch 1
were reviewed; did not provide all required information on time. The requirements were
explained again and the subprojects directed to fully comply with the ES<F form batch 2021
and onwards
OP 4.04 Natural S No civil works of the subprojects funded have started until this MTR
Habitats
Preparation of subprojects located in sensitive natural habitats included the potential impacts
and adequate mitigation plans to prevent negative impacts
OP 4.10 Indigenous S Subprojects have been screened to identify IPs presence and social analysis carried out to
People determine whether IPs would be affected. No IPs were to be affected by the subprojects
OP 4.11 Physical S Consideration of PCRs and the potential have been considered in preparation of sub-
Cultural Resources projects. Special attention has been given to UNESCO WH sites
OP 4.12 Involuntary S Projects have been screened to ID the need for land acquisition and/or relocation and/or to
Resettlement confirm the land status. Potential social impacts due to land acquisition were also assessed.
Update on instruments will be done should there be an adjustment of subproject design. Civil
works start only when land is physically and legally clean and clear.
OP 4.36 Forests S Subprojects in or adjacent to forest areas were equipped with the proper environmental
management documents

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 FROM THE AIDE MEMOIRE as a result of the 2021 WB Mission:

By end of January 2022

A) Develop an Environmental Safeguards Master Checking Table that will consist of:

1) Name of subprojects
2) Name of destination
3) Type/form of environmental documents
4) Status (under procurement; under preparation, under approval process, or
completed)
5) C-EMP status
6) Implementation reports

B) Social Safeguards Master Checking Table

The table will be used to check and balance which destinations may need more
attention/assistance and support in safeguards issues, as well as to see the
champions in this subject for cross learning purposes

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 THE AIDE MEMOIRE as a result of the 2021 WB Mission:

Changes coming from recommendations in the Aide Memoire need to be incorporated in the ESMF

OP4.11 Physical Cultural Resources

The key risks to UNESCO WHC’s concern re infrastructure development at Borobudur and Komodo WH
Sites were considered critical

The WB Mission recommended to consider as one of the strategic key actions at MTR:
- to explore the development of a communication strategy to articulate the positive environmental
and social impacts of project activities, both to civil society and to local communities.
deadline was set as February 2022.

The other agreed action that the MTR Mission indicated in their Aide Memoire specific for PMS to do:
- Amend the safeguards screening process, to identify subprojects that may need the Heritage
Impact Assessment (HIA) or EIA procedure and review by UNESCO

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 FROM THE AIDE MEMOIRE as a result of the 2021 WB Mission:

The environmental and social instruments should be prepared based on the final
DEDs and be ready prior to bidding of subprojects.

Development of a screening process for sub-projects that may impact UNESCO World
Heritage sites.
 
(i) For any sub-projects that may impact the OUV of the World Heritage sites, the
procedures outlined in the Operational Guidelines (2019) for the UNESCO World
Heritage Convention must be followed.
 
(ii) For cultural World Heritage sites this may involve conducting Heritage Impact
Assessments (HIAs, using the UNESCO/ICOMOS process) and formal notification of
the World Heritage Centre of the planned work (including submission of the HIA and
draft designs).
 
(iii) For natural World Heritage sites Environmental Impact Assessments (EIAs, using the
UNESCO/IUCN process). The safeguards screening process needs to be amended to
identify sub-projects in and around the WHS that may need the HIA or EIA process. For
these projects, sufficient time should be allocated in the project cycle to allow a review of
the EIA/HIA by UNESCO.
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 Expect an upcoming field mission

Upcoming field mission proposing a technical field visit in early July 2022 to focus
on safeguards and progress implementation of sub-projects in a specific location

Thank You all

Terima kasih

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