UNIT III - ENVIRONMENTAL MANAGEMENT PLAN

Plan for mitigation of adverse impact on water, air and land, water, energy, flora and
fauna – Environmental Monitoring Plan – EIA Report Preparation – Review of EIA
Reports – Environmental Clearance – Environmental Audit
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The Environment Management Plan (EMP) consist of all mitigation measures for
each component of the environment due to the activities increased during the operational
phase of the project and these are discussed in later subsections.

The EMP is generally

 Prepared in accordance with the rules and requirements of the MoEF & CC and
CPCB/ PPCB.
 To ensure that the component of facilities is operated in accordance with the design.
 A process that confirms proper operation through supervision and monitoring.
 A system that addresses public complaints during operation of the facilities and
 A plan that ensures remedial measures is implemented immediately.

The key benefits of the EMP are that it offers means of managing its environmental
performance thereby allowing it to contribute to improved environmental quality. The other
benefit includes cost control and improved relations with the stakeholders.

EMP includes four major elements:

 Commitment & Policy: The management strives to provide and implemented the
Environmental Management Plan that incorporates all issues related to air, water, land
and noise.
 Planning: This includes identification of environmental impacts, legal requirements
and setting environmental objectives.
 Implementation: This comprises of resources available to the developers,
accountability of contractors, training of operational staff associated with
environmental control facilities and documentation of measures to be taken.
 Measurement & Evaluation: This includes monitoring, counteractive actions and
record keeping.

As part of the EMP, a monitoring committee would be formed comprising of the site
incharge/coordinator, environmental group representative and project implementation team
representative. The committee’s role would be to ensure proper operation and management of
the EMP including the regulatory compliance.
Plan for mitigation of adverse impact:
Mitigation refers to minimizing or avoiding the described impacts. Overall,
mitigation measures are a response to the findings of impact assessment; they need to
cover all the areas identified.

The key focus of mitigation actions should be on:

 Preventive measures that avoid the occurrence of impacts and thus avoid harm or
even produce positive outcomes.
 Measures that focus on limiting the severity and the duration of the impacts.
 Compensation mechanisms for those impacts that are unavoidable and cannot be
reduced further.

Impacts and related mitigation actions are evaluated and identified according to the
key environmental, social and cultural characteristics of the area where the project will be
implemented.

Various mitigation measures may be suggested to solve a potential problem and it is

important to assess the likely effectiveness of each measure in terms of the extent to
which the problem will be reduced, as well as to indicate the costs of implementation.
Whatever mitigation measures are proposed; it is important to ensure that they do not
create problems of their own. Mitigation feeds back into design, so mitigation measures
proposed to minimise adverse impacts of the project can be incorporated as alternatives in
the project description.

Mitigation of adverse impact on air:

1. If the pollution impact from an industrial stack is predicted to approach or exceed air
quality standards, this impact can be reduced by encouraging greater atmospheric
dispersion and dilution of emissions by (a) raising the stack height, (b) reheating the
flue gases to higher temperatures, and (c) emitting them at greater velocity.
2. If a planned development is likely to exceed, say, maximum hourly pollution
standards only during periods of poor atmospheric dispersion, then one possible
mitigation measure would be to keep a cleaner standby fuel for use during those
forecasted occasions or to reduce emissions by reducing production output in the case
of an industrial process.
3. Improved fuel combustion designs can reduce pollutant emissions, such as by using
low nitrogen oxides burners in furnaces. In many cases the type and amount of
pollutants emitted are a function of the fuel being burned, so alternative fuels can be
proposed, such as fuel oil with a very low sulphur content or natural gas.
4. Traffic-generated pollutants decrease rapidly away from roads, and this process can
be enhanced by roadway trenching, embankments, walls and trees, to reduce the
pollution concentrations in nearby residential areas.
5. The construction stage of most projects has the potential to cause localised windblown
dust problems, either when excavation is taking place or when materials are being
transported and stored in stockpiles. Careful design of construction operations,
 including the selection of haulage routes into the site and the location of stockpiles,
can help to minimise dust problems in nearby residential areas. Mitigation measures
can include (a) frequent spraying of stockpiles and haulage roads with water, (b)
regular sweeping of access roads, (c) covering of lorries carrying materials, (d)
enclosing conveyor-belt delivery systems, and (e) early planting of peripheral tree
screens where they are part of the planned development.
6. Limitations on the practice of open burning of agricultural crop residues; such
limitations
might include a permitting program, delineation of specified times for burning to
occur,
and the establishment of distance requirements between residences and open-burning
areas.

Mitigation of adverse impact on water:

If a project is likely to cause a significant increase in flood risk or water pollution, there
should be a strong presumption in favour of the relocate or no action alternatives. Some of
the mitigation and enhancement measures commonly adopted in relation to various water-
impact issues are:

1. Damage to riparian features and/or change in channel morphology caused by

river works, etc.

Use project management and restoration techniques to minimise and repair damage. Create
new features such as pools and riffles. Use dredging’s positively, e.g. for landscaping or
habitat creation.

2. Increased sediment loads and turbidity caused by river channel works

Select appropriate equipment and timing, e.g. construct new channels in the dry and allow
vegetation to establish before water is diverted back in

3. Impacts of development on floodplains

If development is permitted:

(a) steer away from wetlands and high-flood-risk areas;

(b) ensure that new flood defences do not increase flood risk elsewhere;

(c) take compensatory measures, e.g. floodways and flood storage areas/reservoirs to provide
flood storage and flow capacity;

(d) allow for failure/overtopping of defences, e.g. by creating flood routes to assist flood
water discharge;

(e) take opportunities for enhancement in redevelopment, especially where (as in many urban
sites) existing conditions are poor, e.g. use river corridor works to restore floodplain (by
removing inappropriate existing structures), enhance amenity and wildlife value, and create
new floodplain wetlands.

4. Impacts of mineral workings, especially on floodplains

Operational phase– Carefully manage the use and storage of materials/spoil, and runoff from
spoil heaps/earthworks. Use siltation lagoons. Route dewatering water into (a) lagoons, wells
or ditches to recharge groundwater, (b) watercourses to augment streamflows.

Restoration phase– Careful backfill and aftercare management. Enhancement, e.g. of

amenity/wildlife value.

5. Impacts of new roads and bridges, or road improvement schemes

Use: careful routing; designs to minimise impacts on river corridors (not just channels); and
measures to control runoff, e.g. routed to detention basins or sewage works, and not into
high-quality still waters. If construction imposes river realignment, create new meandering
channel with vegetated banks.

6. Impacts of dams and reservoirs

Adjust size or location (avoid sensitive areas). Minimise height and slope of embankments,
and plant with trees.

7. Water depletion by abstraction

Promote infiltration and hence groundwater recharge in urban areas. Minimise water use, e.g.
by metering and the installation of water-efficient equipment/appliances.

8. Increased runoff from urban and industrial developments

Use sustainable urban drainage schemes with (a) efficient piped drainage and sewer systems
and (b) runoff source control measures, i.e. at or near the point of rainfall, e.g.: porous
surfaces (car parks, pavements, etc.), soakaways (gravel trenches, vegetated areas); flow
detention measures (grass swales, vegetated channels, stepped spillways, detention/balancing
ponds/basins/storm reservoirs, and project layout/landscaping to increase runoff route).

9. Increased runoff and pollution (including sediments) from construction sites

Minimise soil compaction and erosion. Ensure careful storage and use of chemicals, fuel, etc.
Install adequate sanitation. Guard against accidental spillage, vandalism and unauthorised
use.

10. Chemical pollution from built environments, e.g. roads, urban/industrial areas

Control runoff (as above). Use: oil traps; siltation traps/ponds/lagoons; vegetated buffer zones
and wetlands, e.g. constructed reed beds.
 11. Increased sewage and/or sewage-pollutant content

Increase capacity and/or sewage treatment level, e.g. from primary to secondary or secondary
to tertiary.

12. Groundwater pollution

Avoid contamination from leaking storage tanks, etc. by appropriate bunding of tanks and
improved site management. Use buffer zones.

Mitigation of adverse impact on land and soil:

1. Use of techniques to decrease soil erosion during either the construction or
operational phase of a project. Examples of such techniques include minimization of
the exposed time during the construction phase by planting rapidly growing
vegetation and the use of sediment catchment basins. Additionally, as various types of
grasses and vegetation have relatively greater or less potential for minimizing soil
erosion, the selection of pertinent vegetation for usage should take this characteristic
into account.
2. Rotation of land-use practices in the project area can be used to permit natural
recovery without the continuing stress related to any one land-use practice. Examples
include the rotation of military training areas, agricultural crops in given geographic
areas, and grazing patterns in areas permitted by pertinent governmental agencies.
3. The project can be designed to exhibit greater earthquake resistance if this is a
potential concern for the project area. Examples include structural designs for
withstanding shocks associated with the occurrence of earthquakes.
4. For projects involving usage of the groundwater resource, groundwater usage could
be decreased.
5. If the potential impact of concern is land subsidence, management techniques to
minimize groundwater usage in the area where subsidence is expected to occur could
be implemented. These could encompass water conservation measures so as to reduce
groundwater extraction requirements.
6. For projects that may be of concern because of leachate generation, measures could be
taken to immobilize the constituents and prevent their occurrence in leachate through
the use of waste solidification techniques.
7. Liners could be used to provide a physical barrier to limit the movement of
contaminant materials from waste-disposal sites into and through the subsurface
environment. Liners can be composed of either natural or man-made materials.
Leachate collection systems could also be used, along with surface-water run-
on/runoff control systems.
8. Avoid runoff of pollutants in liquid form over the land.
9. In general, deforestation must be avoided to protect soil erosion on mesoscale basis. 9.
Crop rotation and leaving the agricultural land uncultivated for some time between the
successive crops are effective ways to restore natural recovery of soil fertility.
 10. Excessive withdrawal of groundwater and other resources like coal should be avoided
in order to protect land areas from subsidence.
11. Excessive use of chemical fertilizers and pesticides in agricultural practices must be
avoided in order to avoid land degradation due to irrigation itself.

Plan for mitigation of adverse impact on biological environment:

Greenbelt is often recommended as a part of the environment management plan (EMP).
Depending on the size and magnitude of impacts, a minimum of 30% of total core area of at
least 10–15 m wide thick greenbelt of 1500–2000 plants per hectare is recommended as per
the guidelines of the Central Pollution Control Board. The main objectives of a greenbelt are:

 Greenbelts are mainly meant to isolate and protect the surroundings and neighbouring
areas of industries from air, dust, and noise pollution.
 To provide shade, shelter, food, and nesting space for wildlife.
 To give green and pleasant look and a relaxing place for workers.
 To prevent neighbouring towns from merging into one another in case of city and
town planning.
 To provide tangible economic benefits of fruit, fodder, firewood, and other minor
produce to the workers and nearby communities and others.

The general criteria for selection of plants for greenbelt are the following:

 It is preferable to go for tall and evergreen plants that are locally adapted. Exotic
species except those that got naturalized should not be introduced.
 Trees with multiple uses are more desirable than the useless fast growing species.
They should be able to provide at least non timber products such as minor fruit,
flower, and fodder.
 The plants chosen for greenbelt should be structurally and functionally similar to the
local trees
 Plants with thick canopy and high leaf area index are more preferable than others.
 They should be capable of growing under the given set of environmental conditions.
 Trees with known allergens should be avoided in human environment.
 Resistance to wind, cyclones, dust, heat, water logging or drought, etc. are among the
other considerations.
 Even if it is the most suitable species, it is desirable to avoid monocultures (single
species). Polyculture or mixed culture of different species is always better than a
single species.

Mitigation strategies for wetland impacts can be divided into four categories:

(1) Avoidance or minimization,

(2) Restoration,

(3) Enhancement, and

(4) Creation

Environmental Monitoring Plan:

Monitoring provides data on the environmental and social impacts of the project for
the whole project lifecycle. As part of their operations, most development projects
involve regular monitoring of indicators (including such things as quantity of ores
extracted, materials processed, energy used and sewage released, etc.). More specifically,
the information collected during monitoring activities helps to ensure that the priorities
listed in the Environmental Management Plan (EMP), mitigation measures, and
contingency plans are properly implemented, and that these plans and measures are
effective in addressing the project’s impacts.

Why Conducting Monitoring?

Monitoring is critical to ensuring the fulfillment of all the commitments made in the
approved EIA. It is one of the ongoing outcomes of EIA for a given project. Monitoring is
also important for keeping track of any changes that happen in the environment and in
communities because of the project and other local and/or global events, such as changes
in livelihoods due to economic crisis or migration, or differences in water availability due
to drought. After the project is implemented, basic monitoring efforts will continue during
project remediation.

How is Monitoring Conducted?

Monitoring is usually carried out by the project proponent, under the supervision of
independent agencies and/or government agencies. The key steps in creating a
monitoring plan are:

 Identify the focus areas to be considered for the plan (based on the impacts, mitigation
measures and other issues from the contingency plans).
 Select of a long list of indicators for the focus areas, such as those on population,
health, and natural elements used by the population (soil, drinking water, etc.).
 Prioritize a core set of indicators based upon agreed criteria.
 Identify data collection protocols.
 Develop data interpretation methods and create a reporting template.
 Schedule activities, evaluate program and personnel costs, define personnel
responsibilities.

EIA Report Preparation:

The EIA report is a primary document for decision-making and for informing
stakeholders about likely environmental impacts of a proposal and the measures for
mitigating them. EIA reports must be written to an appropriate technical standard, in
compliance with the terms of reference and in an easy-to-understand style. They also must be
carefully edited, designed, and produced.
 The EIA Report is a compilation of several important project components, including
the project description, the assessment of its environmental and social impacts, mitigation
measures, and related management and monitoring plans. During this step, all the information
gathered during the previous steps is compiled into a comprehensive report that analyzes and
synthesizes the data, structuring it as stipulated in the terms of reference.

A quality EIA Report has the following characteristics:

 It is well-structured and uses non-technical language supported by data and well-

executed analyses.
 It provides information that is helpful and relevant to decision making.
 It results in the satisfactory prediction of the adverse effects of the proposed actions
and their mitigation using conventional and customized techniques.

Structure of EIA report:

S. No EIA Structure Contents

1. Introduction  Purpose of the report
 Identification of projects and project proponent
 Brief description of nature, size, location of the project, and
its importance to the country, region
 Scope of the study—details of regulatory scoping carried out
(as per terms of reference)

2. Project  Type of project

description  Need for the project
 Location (maps showing general location, specific location,
project boundary, and project site layout)
 Size or magnitude of operation (incl. associated activities
required by/or for the project)
 Proposed schedule for approval and implementation
 Technology and process description
 Project description including drawings showing project layout,
components of project, schematic representations of
feasibility drawings that give information important for EIA
 Description of mitigation measures incorporated into the
project to meet environmental standards, environmental
operating conditions, or other EIA requirements (as required
by the scope)
 Assessment of new and untested technology for the risk of
technological failure

3. Description of  Study area, period, components, and methodology

the  Establishment of baseline for VECs, as identified in the scope
environment  Base maps of all environmental components

4. Anticipated  Details of investigated environmental impacts due to project

environmental location, possible accidents, project design, project
impacts and construction, regular operations, final decommissioning, or
mitigation rehabilitation of a completed project
 measures  Measures for minimizing and/or offsetting adverse impacts
identified
 Irreversible and irretrievable commitments of environmental
components
 Assessment of significance of impacts (criteria for determining
significance, assigning significance)
 Mitigation measure

5. Analysis of  In case, the scoping exercise results in need for alternatives:

alternatives  Description of each alternative
(technology and  Summary of adverse impacts of each alternative
site)  Mitigation measures proposed for each alternative and
selection of alternative

6. Environmental  Technical aspects of monitoring the effectiveness of

monitoring mitigation measures (incl. measurement methodologies,
program frequency, location, data analysis reporting schedules,
emergency procedures, detailed budget, and procurement
schedules)

7. Additional  Public consultation

studies  Risk assessment
 Social impact assessment, R&R action plans

8. Projects  Improvements in physical infrastructure

benefits  Improvements in social infrastructure
 Employment potential—skilled, semiskilled, and unskilled
 Other tangible benefit

9. Environmental  If recommended at the scoping stage

cost-benefit
analysis
10. EMP  Description of administrative aspects that ensure proper
implementation of the mitigative measures and their
effectiveness monitored, after approval of the EIA

11. Summary and  Overall justification for implementation of the project

conclusion (this  Explanation of how adverse effects have been mitigated
will constitute
the summary of
the EIA report)
12. Disclosure of  Names of the consultants engaged with their brief resume
consultants and nature of consultancy rendered
engaged

Review of EIA Reports:

Review and Licensing is the final check on the quality of the EIA report submitted to obtain a
project license. Once the EIA report is submitted, designated authorities will usually go
through it thoroughly, weighing the methods used, data, interpretations, measures and
conclusions to assess the impacts of the planned development. Their review will determine
whether or not the project adequately addresses major environmental and social impacts and
other risks, and whether or not to grant a licence to the project proponents, or to request
project changes. This means that a good quality EIA might still lead to the planned
development not being permitted to go ahead based on the identified impacts. Often, the
review process leads to a requirement for additional information on potential impacts,
mitigation measures or other aspects.

Environmental Clearance:

Environmental Clearance is the procedure to get clearance from the government for the
installation and modification (amendment) of certain projects. The environmental clearance
process is required for 39 types of projects and covers aspects like screening, scoping and
evaluation of the upcoming project. It is mandatory for projects which can cause high
environmental Pollution. Indian Constitution made a list of those projects under EIA
Notification 2006, which includes mining, thermal power plant, infrastructure, etc.

The Central Pollution Control Board (CPCB) has also introduced a colour codification for
industries depending on their impact of environment. Industries are classified on a pollution
potential index as red, orange, green and white industries to differentiate environmental
clearance process across categories.

Red Orange Green White

Pollution Index Score Pollution Index Pollution Index Pollution Index
60 and Above Score 41 to 59 Score 21 to 40 Score up to 20

Ex: Ex: Ex: Ex:

 Hazardous  Bakery and  Ayurvedic  Blending
chemicals confectioner and and packing
manufacturin y units Homeopathic of Tea
g  Food and medicines  Cotton &
 Lead and food without Woolen
battery processing boiler hosiers
manufacturin including  Carpentry & making
g fruits and Wooden  Organic
 Cement vegetables furniture manure
industry processing  Mineralized mixing
 Nuclear  Automobile water  Diesel pump
power plants servicing,  Ready mix repairing &
repairing and concrete Servicing
painting
 Building &
Infrastructure
projects

Purpose of Environmental Clearance:

The main purpose behind Environmental Clearance is to assess the impact of the proposed
project on environment and people, and to try to abate or minimize the impact of proposed
project on environment and people.

Procedure for Environmental Clearance

To get Environmental Clearance for a proposed project following steps are required to be
followed.

1. Identification of location

A location for the proposed project should be selected which will comply with existing
guidelines. If project site does not comply with existing guidelines the proponent has to
identify other alternative site for the proposed project.

2. Screening

The project proponent then will assess in which category the proposed project falls in and if it
requires environmental clearance and environment impact assessment study.

There are two categories – A category and B category.

o Projects falling under A category go to MoEFCC for clearance.

o Projects falling under B category go to State government for clearance which further
gets categorized into B1 and B2 projects. B2 projects do not require preparation of
EIA report. But depending upon the project and its location the Appraisal Committee
can ask project proponent to carry out EIA study.
3. Public hearing
The Public hearing is a mandatory step in the process of environmental clearance for certain
developmental projects. It is a part of EIA study. This provides public of an area to come
forward and express their concerns and views regarding the proposed project to the project
proponent and the Government.

4. Application

The project proponent then has to submit an application for environmental clearance. The
Application process is Online.

o The projects falling under A category will apply on MoEFCC website.

o The projects falling under B category will apply on State website.

Registration

Filling of Consolidated
Statement
Submission of Consolidated Statement with Form-I and Form IA

Attached forms will include all NOCs like – Tree NOC, Debris NOC, CFO NOC, etc.

Submission of other documents like EIA Report, Reports of particular studies

carried out for proposed project

Environmental Clearance Application Process

5. Environmental Appraisal

The documents submitted by project proponent will be first scrutinized by a disciplinary

committee. They might also conduct a site visit if required.

If the conditions said in the Environment Clearance are not followed then the Appraisal
Committee has the right to cancel EC granted for that project.

Once all the requisite documents and data from the project authorities are received and public
hearings (where required) have been held, assessment and evaluation of the project from the
environment angle is completed within 90 days and the decision of the ministry shall be
conveyed within 30 days thereafter. The clearance granted shall be valid for a period of five
years for commencements of the construction or operation of the project. If EC is expired, the
project proponent can go for renewal of EC by following the same procedure.
Environmental Audit:

Environmental audit is essentially an environmental management tool for measuring the

effects of certain activities on the environment against set criteria or standards. Depending on
the types of standards and the focus of the audit, there are different types of environmental
audit.

Objectives of Environmental Audit:

The audit may focus on some or all of the several aspects e.g. material utilization, waste
minimization, energy conservation, equipment or staff. The objectives of various aspects are
as follows:
1. Material utilization:
 To determine the mass balance of raw materials
 To determine the water balance and wastewater output
 To determine the energy balance e.g. fuel consumption, total energy
consumption.
2. Waste minimization:
 To ensure minimization, through recovery and recycling of waste components.
 To determine qualitatively and quantitatively the nature of all emissions e.g.
solid liquid wastes and hazardous wastes.
3. Energy conservation
4. Equipment operation/maintenance:
 To monitor the performance of process and pollution control equipment.
 To monitor the performance of waste handling equipment.
5. Staff recruitment/training:
 To improve technical competency and environmental awareness of the staff.
 To develop the right attitude and concern for the environment in staff and
employees.
6. Rules and Regulations:
 To ensure compliance with the rules and regulations as per law.

Benefits of Environmental Audit:

• Enables the management to run the unit efficiently, minimizing wastes and
maximizing the output.
• Provides an up-to-date record of the performance of the equipment. Maintenance is
greatly improved.
• Supplies to the management with the environmental database of the units. This will
ensure compliance with the legal requirements and avoid the risk of future litigation
or hidden liabilities.
• Timely actions can be taken to avert any risk, or disaster in the future by providing
independent verification.
• It enables the staff and employs to improve their technical capability and
environmental awareness.
• It safeguards the environment, and improves goodwill and public image of the
company.
Steps in Environmental audit:

1. Pre audit:

 Collection of background information

 Questionnaire based survey of unit
 Identification of main areas of concern
 Preparation of audit team and assigning specific task

2. At site activities:

 Interviews with staff

 Tour of various facilities
 Computing material balance
 Computing water balance
 Analysis of waste flow quantity and quality
 Conducting monitoring, sampling
 Preparing and discussing draft report

3. Post audit:

 Evaluation of technical capability and awareness of staff to environmental concerns.

 Evaluation of waste generation, treatment facilities and disposal practices
 Identification and assessment of energy consumption, waste reduction and recycling
measures.
 Preparation of final report including recommendations and action plan.
 Follow up of action plan