Guidance gives details on project alternatives, environmental and social point including the no-project option. of view or carry out any significant modifications to project location or design at this stage. It has been observed that this analysis is mostly done in retrospect to justify the site already selected without actual consideration of the environmental and social aspects. 1.2c Explicit assessment of Determination of cumulative environmental Data on ambient conditions Provisions of cumulative impacts of air potential induced, impacts is not covered by the of the EIA such as status of air, noise, and water pollution should be made part of cumulative, and regulation. However, induced and cumulative water, soil, waste pollution and the EIA scope. transboundary impacts (but not transboundary) impact analysis pollution levels of receiving More strengthening to the induced, requirements are mentioned in the MoEnv bodies are collected under the cumulative, and transboundary Guidance. specific regulations and requirements should be made in the Specific regulations/instructions were issued by instructions, and impacts are specific regulations and instructions, as virtue of the Environmental Protection Law that determined for immediate well as in the EIA Guidance. aim to provide allowable limits of pollutants/ surroundings (only for precautions for air, water, soil, pollutants, noise comprehensive EIA studies). level, and hazardous materials. However, occurrence of cumulative impacts under air and water pollution dispersion modeling are not done. 1.2d Identification of The EIA Regulation the adequacy of Procedures for the assessment More technical expertise should be measures to mitigate adverse mitigation measures as a condition to approve of environment and social included in the EIA evaluation technical environmental or social EIA and thus the Project from and an impacts are in for the committee. impacts that cannot be environmental perspective (Article 11). The EIA development projects; however, More emphasis in the EIA Regulation otherwise avoided or report is considered incomplete if it’s missing a its actual implementation is not should be made on requirements and minimized full set of mitigation measures. done. output of mitigations preparation. It is also detailed in the EIA Guidance key Mostly the mitigation measures elements of mitigation measures to be considered are provided in the when preparing the EIA. environmental assessment report but mostly they are not project-specific and their implementation is limited to the projects financed by international agencies.
Guidance gives details on project alternatives, including the no-project option. environmental and social point of view or carry out any significant modifications to project location or design at this stage. It has been observed that this analysis is mostly done in retrospect to justify the site already selected without actual consideration of the environmental and social aspects. 1.2c Explicit assessment of potential induced, cumulative, and transboundary impacts Determination of cumulative environmental impacts is not covered by the of the EIA regulation. However, induced and cumulative (but not transboundary) impact analysis requirements are mentioned in the MoEnv Guidance. Specific regulations/instructions were issued by virtue of the Environmental Protection Law that aim to provide allowable limits of pollutants/ precautions for air, water, soil, pollutants, noise level, and hazardous materials. Data on ambient conditions such as status of air, noise, water, soil, waste pollution and pollution levels of receiving bodies are collected under the specific regulations and instructions, and impacts are determined for immediate surroundings (only for comprehensive EIA studies). However, occurrence of cumulative impacts under air and water pollution dispersion modeling are not done. Provisions of cumulative impacts of air and water pollution should be made part of the EIA scope. More strengthening to the induced, cumulative, and transboundary requirements should be made in the specific regulations and instructions, as well as in the EIA Guidance. 1.2d Identification of measures to mitigate adverse environmental or social impacts that cannot be otherwise avoided or minimized The EIA Regulation the adequacy of mitigation measures as a condition to approve EIA and thus the Project from and an environmental perspective (Article 11). The EIA report is considered incomplete if it’s missing a full set of mitigation measures. It is also detailed in the EIA Guidance key elements of mitigation measures to be considered when preparing the EIA. Procedures for the assessment of environment and social impacts are in for the development projects; however, its actual implementation is not done. Mostly the mitigation measures are provided in the environmental assessment report but mostly they are not project-specific and their implementation is limited to the projects financed by international agencies. More technical expertise should be included in the EIA evaluation technical committee. More emphasis in the EIA Regulation should be made on requirements and output of mitigations preparation.