Regardless of the category and type of investment financed and the extent of the environmental and social assessment of the project carried out, many international finance institutions (including the European Bank for Reconstruction and Development (EBRD), the International Finance Corporation (IFC), the European Investment Bank (EIB)) include in their guidelines a requirement to prepare an Environmental and Social Management Plan (ESMP).
The development of an effective ESMP is one of the key Environmental and Social requirements for the entire lifetime of the project. The document is prepared in order to develop action plans to minimise the negative impacts of identified environmental and social risks, outline management structures, required resources, and draw up a schedule of activities. The ESMP may be an umbrella document consisting of a set of management plans, procedures and practices, and setting out the guidelines for the development of a complete set of documentation necessary for the implementation of the project.
In accordance with the guidelines of financial institutions, in addition to specifying measures and actions, the ESMP should also include additional information to answer questions such as:
- how compliance of the actions with the prepared Plan will be verified?
- whether monitoring will be carried out to verify the effectiveness of the measures applied?
- what process will be implemented when corrective actions are required?
A properly developed ESMP provides the basis for an investment to be carried out in accordance not only with the Lenders’ requirements, but also with Polish and European legislation and good international industry practice. The Plan also addresses all the requirements and obligations of the environmental permits (in Poland – in the Environmental Decision) and the Environmental and Social Action Plan (ESAP), including the need to prepare additional documentation such as a Biodiversity Management Plan (an article on this document can be found on our Blog https://ambiens.pl/blog/biodiversity-management-plan-one-of-the-key-documents-within-the-esms/ ), Stakeholder Engagement Plan (https://ambiens.pl/blog/stakeholder-engagement-plan-a-tool-for-building-and-maintaining-public-acceptance-for-renewable-energy-projects/ ) or Chance Find Procedure.
It is essential that the ESMP is developed as early in the project implementation as possible, as many of the measures and activities identified in the document are generally implemented by contractors, and it may therefore be necessary to incorporate the requirements of the ESMP into the terms and conditions of contracts as soon as possible. It is a „living document” that requires regular monitoring, and where new potential risks are identified, significant design changes are made to the project, or the project phase changes (e.g. from construction to operation), it may need to be updated to address the effects of these factors. The ESMP should not be formulated in general terms, as it is necessary to describe the individual activities and the related information in specific and detailed manner.
