Table 2. Gap Analysis of Environmental and Social Assessment Requirements E&S Principle Scope/Topic WB Policy GOI Regulation Gap Identified Addressed in the ESMF OP 4.01 Reference to legal and OP 4.01 paragraph 3 Ministry of Environment Lack of reference to legal and The ESMF follows OP Environmental administrative Regulation No. 16/2012 section G.5 administrative framework such 4.01. The subproject OP 4.01 (Annex B) Assessment framework such as and B.4.a, stipulated that other data as international environmental environmental international and information required in treaties, agreement, international document will also EA takes into account environmental treaties, reporting environmental document standard policies etc. The cover this gap and obligations of the country, agreement, international shall be incorporated including current regulation only refers to follow OP 4.01. pertaining to project activities standard policies, etc reference to other requirements. data and “other information”. under relevant international treaties or agreement. Project area of OP 4.01 paragraph 2 Ministry of Environment Lack of analysis about project The subproject influences Regulation No. 16/2012 section area of influence, ancillary environmental OP 4.01 (Annex B) B.4.c, requested project proponent facilities, induced impacts and document will cover the to provide information in detail on site selection analysis for project area of influence EA evaluates a project’s this aspect with of activities require environmental as per OP 4.01. “map, scale potential environmental risks operation and activities monitoring & management. component” and impacts in its area of that could be used to determine the influence, identifies ways of project area of influence, improving project selection availability of ancillary facilities and sitting etc. and associated facilities during UKL UPL preparation as good practice. However it does not state about the area of influence project’s outside the footprints. project’s Environmental Impact OP 4.01 paragraph 8 Ministry of Environment Environmental screening based The subproject Screening Regulation No. 16/2012 section 4.C on technical thresholds only will environmental OP 4.01 (Annex C) regulates the requirement to result in inappropriate extent document will include evaluate all possible impacts from and type of EA. the environmental Environmental screening of the project and prepare mitigation impact screening as each proposed project to measures to tackle those issues. stipulated at Section determine the appropriate 2.2.of the ESMF. extent and type of EA. Minister of Public Works Regulation no.10/PRT/M/2008 on
Table 2. Gap Analysis of Environmental and Social Assessment Requirements E&S Principle Scope/Topic WB Policy GOI Regulation Gap Identified Addressed in the ESMF OP 4.01 Environmental Assessment Reference to legal and administrative framework such as international environmental treaties, agreement, international standard policies, etc OP 4.01 paragraph 3 OP 4.01 (Annex B) EA takes into account obligations of the country, pertaining to project activities under relevant international treaties or agreement. Ministry of Environment Regulation No. 16/2012 section G.5 and B.4.a, stipulated that other data and information required in reporting environmental document shall be incorporated including reference to other requirements. Lack of reference to legal and administrative framework such as international environmental treaties, agreement, international standard policies etc. The current regulation only refers to “other data and information”. The ESMF follows OP 4.01. The subproject environmental document will also cover this gap and follow OP 4.01. Project area of influences OP 4.01 paragraph 2 OP 4.01 (Annex B) EA evaluates a project’s potential environmental risks and impacts in its area of influence, identifies ways of improving project selection and sitting etc. Ministry of Environment Regulation No. 16/2012 section B.4.c, requested project proponent to provide information in detail on this aspect with “map, scale of operation and activities component” that could be used to determine the project area of influence, availability of ancillary facilities and associated facilities during UKL UPL preparation as good practice. However it does not state about the project’s area of influence outside the project’s footprints. Lack of analysis about project area of influence, ancillary facilities, induced impacts and site selection analysis for activities require environmental monitoring & management. The subproject environmental document will cover the project area of influence as per OP 4.01. Environmental Impact Screening OP 4.01 paragraph 8 OP 4.01 (Annex C) Environmental screening of each proposed project to determine the appropriate extent and type of EA. Ministry of Environment Regulation No. 16/2012 section 4.C regulates the requirement to evaluate all possible impacts from the project and prepare mitigation measures to tackle those issues. Minister of Public Works Regulation no.10/PRT/M/2008 on Environmental screening based on technical thresholds only will result in inappropriate extent and type of EA. The subproject environmental document will include the environmental impact screening as stipulated at Section 2.2.of the ESMF.
ESMF-revised.docx