Guidelines For Environmental Impact Assessment For Waste Management in Rwanda
Guidelines For Environmental Impact Assessment For Waste Management in Rwanda
Final Report
Prepared by:
ECOTECH Consulting Environmental Management Firm Ltd
Wandegeya, Kampala.
March 2009
FOREWORD
The principal environment management law, the Organic Law No. 04/2005 provides the
modalities for protection, conservation and promotion of environment in Rwanda. The
requirement for all projects to be subjected to Environmental Impact assessment (EIA) is
stated by the Organic Law in article 67. General principles and specific responsibilities for
the management of the environment are clearly spelt. The Rwanda Environment
Management Authority therefore within its mandate has embarked on the preparation of
environmental management regulations and guidelines. These guidelines for EIA for waste
management are one such sectoral guideline prepared to provide for the EIA process specific
to waste management.
These guidelines serve as an administrative directive to guide EIA for waste management.
The guidelines should be used together with the General EIA Guidelines 2006 and any other
relevant EIA instruments developed by REMA.
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TABLE OF CONTENTS
FOREWORD ............................................................................................................................ i
TABLE OF CONTENTS.......................................................................................................... ii
LIST OF ACRONYMS ........................................................................................................... iii
Definitions................................................................................................................................. v
PART I: INTRODUCTION...................................................................................................... 1
1. INTRODUCTION ......................................................................................................................... 1
1.1 Background to the Environmental Impact Assessment guidelines .............................................. 1
1.2 Definition of Environmental Impact Assessment ........................................................................ 2
1.3 The Purpose of the Guidelines ..................................................................................................... 2
1.3.1 The Objectives of the Guidelines............................................................................. 2
1.3.2 The Scope................................................................................................................. 2
1.3.3 Quality assurance ..................................................................................................... 3
PART II: POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK.............................. 4
2. POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK FOR WASTE
MANAGEMENT EIA .............................................................................................................. 4
2.1 International Context of Environmental Assessment................................................................... 4
2.2 Rwandan Policies and Regulations Relating to EIA.................................................................... 4
2.3 Institutional Responsibility .......................................................................................................... 8
PART III: GUIDELINES FOR WASTE MANAGEMENT ENVIRONMENTAL IMPACT
ASSESSMENT ....................................................................................................................... 11
3. INTRODUCTION .............................................................................................................. 11
3.1 Project Brief ............................................................................................................................... 11
3.2 Screening.................................................................................................................................... 11
3.3 Scoping....................................................................................................................................... 14
3.4 Baseline Environmental Conditions of the proposed Project..................................................... 17
3.5 Prediction of Impacts ................................................................................................................. 19
3.6 Evaluation .................................................................................................................................. 19
3.7 Mitigation................................................................................................................................... 20
3.8 EIA Report ................................................................................................................................. 20
3.9 Review ....................................................................................................................................... 20
3.10 Monitoring and audits .............................................................................................................. 21
3.11 Decommissioning..................................................................................................................... 21
3.12 Cost of EIA .............................................................................................................................. 21
3.13 Professional expertise required for the waste management EIA.............................................. 21
Appendix I: Project Brief format ............................................................................................ 23
Appendix II: Format of questionnaire for public hearing....................................................... 24
Appendix III: Screening Process in EIA................................................................................. 26
Appendix IV: Guidelines for Waste Management.................................................................. 33
Appendix V: Projects requiring EIA....................................................................................... 36
Appendix VI: Checklists for impacts assessment of waste management projects ................. 38
Appendix VII: Preparing Environmental Management Plan.................................................. 42
Appendix VIII: Sample Terms of Reference (ToR) for waste management EIA studies ...... 45
Appendix IX: Summary of Institutional responsibilities in waste management .................... 48
Appendix X: Guidelines for Waste Management EIA Report ............................................... 49
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LIST OF ACRONYMS
ADB African Development Bank
CFCs Chlorofluorocarbons
CP Cleaner production
EA Environmental Audit
IRST Institute
EIA for Scientific and Technological Research
LG Local Governments
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MINITERE Ministry of Lands, Environment, Forestry, Water and Mines
(Now ministry of Natural Resources, MINIRENA)
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Definitions
Environment: Are the physical factors of the surroundings of the human beings including land,
water, atmosphere, climate, sound, odour, taste, the biological factors of animals and plants and
the social factor of aesthetics and includes both the natural and built environment.
An Impact: is the effect of any action that affects one or more elements of the natural, social or
economic environment, either adversely or beneficially.
Cumulative Impacts: Those impacts that result from the incremental impact of the proposed
action added to the impacts of other past, present, and foreseeable future actions.
Direct Impacts: Those impacts that are caused by the action and which generally occur at the
same time and place as the action.
Indirect Impacts: Those impacts that induce changes in the natural environment, population,
economic growth, and land use, as a result of actions not directly linked to the project in
question.
Environmental Impact Statement (EIS): The written report which presents the results of an
Environment Impact Study.
Environmental Impact Study: means the study conducted to determine the possible
environmental impacts of a proposed policy, project or activity, and measures to mitigate any
such impacts.
Environmental Monitoring: the continuous determination of the actual and potential effects of
any activity or phenomenon whether short-term or long term.
Lead Agency: any Ministry, Department, Parastatal agency, Local Government system or Public
Officer in which or in whom any laws vests functions of control or management of any segment
of the environment.
Mitigation measures: Actions which reduce, avoid or offset the potential adverse environmental
consequences of a project, and include engineering works, technological improvements,
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management measures and ways and means of ameliorating effects to the environment and losses
suffered by individuals and/or communities, including compensation and resettlement.
Participation: A process through which stakeholders’ influence and share control over
development initiatives and decisions or resources that affect them.
Pollution: any direct and indirect alteration of the physical, thermal, chemical, biological or
radioactive properties of any part of the environment by discharging, emitting or depositing
wastes so as to affect any beneficial use adversely, to cause a condition which is hazardous or
potentially hazardous to public health, safety or welfare, or to animals, plants or aquatic life, or to
cause a contravention of any condition, limitation or restriction to a healthy environment.
Project: a set of planned activities to achieve objectives within a given area and time frame.
Project brief: a summary statement designed to achieve specific objectives within a given area
and the likely environmental impacts and mitigation measures thereto.
Scoping: is the early transparent process of interaction that identifies concerns, evaluates them,
organises by eliminating insignificant impacts and focusing on significant impact for further
assessment so that attention and therefore resources, can be effectively and efficiently utilised.
Screening: Selection of actions or projects requiring EIA. Common methods for screening
include: project threshold, sensitive area criteria, positive and negative list, preliminary
assessment/ IEE.
Significant effect: substantial, or potentially substantial, adverse changes in any of the physical
factors of the surroundings of human beings including land, water, atmosphere, climate, sound,
odour, taste, the biological factors of animals and plants and the social factor of aesthetics and
includes both the natural and built environment.
Stakeholders: those affected by the outcome of a project or can affect the outcome of a proposed
either negatively or positively.
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PART I: INTRODUCTION
1. INTRODUCTION
The Republic of Rwanda has environmental challenges that have been faced by the
population for decades. These environmental challenges are evident in terms of land and
wetlands degradation, water pollution, soil erosion etc. Poverty, low level of awareness,
inadequate resources (technical, human, financial), low inter-sectoral coordination and socio-
economic activities exacerbate the environmental degradation impacts. Apart from the high
population pressure on natural resources that cause environmental degradation another area
of great concerns are large projects like industries, solid waste dumps or landfill (e.g. in
Kigali City) and agriculture.
Waste management is a big challenge in Rwanda especially within the urban areas. For
example in Kigali City only about 24% of the solid waste generated is disposed legally at
Nyanza landfill. Wastewater and sewage also cause management problems if the
management infrastructure is not adequate. Industrial effluent and diffuse release from
agricultural activities are other forms of pollution to the environment.
Waste pollution is considered a serious threat and can broadly be defined as any pollution
associated with waste and waste management practices. Pollution or contamination by waste
can cause direct harm to humans, domestic animals, wildlife and the environment. It is
therefore very important to have in place an efficient waste management system to prevent
the harmful impacts of wastes. The Republic of Rwanda has initiated efforts to improve the
quality of the environment and enhance economic well-being. In recognition of the need to
protect the environment from adverse impact of developmental activities the government of
Rwanda requires the conduct of EIA of projects that are likely to have significant effect on
the environment before implementation. To streamline the conduct of EIA the General
Guidelines and Procedure for Environment Impact Assessment for Rwanda was published in
2006. The environment being complex and coupled with development in the different
sectors, it was found desirable to develop sectoral EIA guidelines. The sectoral EIA
guidelines are intended to guide the process of EIA in the different sectors. One such is the
EIA guidelines for waste management. The EIA guidelines for waste management are
developed to guide the process of EIA for waste management in Rwanda. The EIA
Guidelines will serve agencies and individuals involved in the EIA, waste managers and
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those involved in projects that generate waste with potential impacts on the environment. It is
part of the legislative tool being put in place for sustainable waste management in Rwanda
A key objective of the EIA guidelines is to provide clear and detailed advice on carrying out
effective EIA for waste management. This includes amongst others the purpose of EIA and
the guidelines, the role of EIA in decision-making, the policy, legal and institutional
framework, the environmental EIA procedure and the assessment process. The overall goal is
to employ an integrated approach to the management of waste that arise from various
activities (e.g. urban, domestic, industrial, agricultural, etc) and achieve ecologically
sustainable development.
The EIA guidelines for waste management set the minimum standards or controls for project
activities that may cause significant waste impacts on the environment. The specific
objectives of the waste management EIA guidelines are:
i) to provide direction and information for decision making by the REMA regarding
waste management EIA;
ii) to provide advice on waste management EIA processes;
iii) to enable proponents/developers and stakeholders to participate effectively in waste
management EIA process and related administrative actions; and
iv) to enable environmentally adequate management of waste in all institutions as well
as development projects.
The waste management EIA guidelines shall apply to all projects with associated waste
generation or waste management components which are listed under Article 2 of the
Ministerial Order establishing the list of works, activities and projects that have to undertake
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Environmental Impact Assessment and those listed in these guidelines (appendix V). The
Guidelines are intended to be used by:
These guidelines provide advice to encourage sound EIA outcomes across all phases of
planning for waste management proposals from project conception and design to approval.
When using these guidelines it should be recognised that each waste management proposal
has specific features (e.g. location, type of waste, etc) and proposal specific issues that should
be taken into account. The approach used to conduct the EIA should take account of the
particular unique circumstances of the individual projects.
Roles and responsibilities of key stakeholders in the waste management process are dynamic
and may change with time. It therefore may be necessary to review these guidelines
periodically. This is to ensure a continuous improvement approach to the provision of advice
and information by REMA. Reviews may be triggered by changes to policy or legislation;
changes or requests for reviews by stakeholders.
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PART II: POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK
The Environment Policy (2003) sets the overall goals for environmental management in
Rwanda. The policy emphasises improved management of the environment at both central
and local levels consistent with the policy on decentralisation and good governance. All
government policies take into account environmental protection as a priority (Environment
Indicators, REMA 2007). Environment is treated as a sector and a cross cutting issue in the
Economic Development and Poverty Reduction Strategy (EDPRS) document (2007). The
environment policy provides for the institutional and legal reforms. The implementation of
environmental management strategies employs the Sector Wide Approach (SWAP), which
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brings with it the advantage of synergies among different development actors. A key tool of
environmental management being applied in Rwanda is Environmental Impact Assessment
and the government Rwanda through REMA produced a General EIA Guidelines and now
has embarked on the developing of Sectoral Guidelines, one of which is for Waste
Management activities.
There are specific provisions within the Organic law (No 04/2005 of 08/04/2005) that deal
with EIA, the requirements for EIA and the contents of EIA. It also states clearly general and
specific responsibilities in the management of the environment and environmental
conservation. Relevant articles in the Organic law to Environmental Impact Assessment and
Waste Management are:
i) Article 3: Every person has the duty to protect, conserve and promote environment.
The State has a responsibility of protecting, conserving and promoting the
environment.
ii) Article 6: Every person in Rwanda has a fundamental right to live in a healthy and
balanced environment. He or she also has the obligation to contribute individually or
collectively to the conservation of natural heritage, historical and socio-cultural
activities.
iii) Article 7 (30). Adopts the Polluter pays principle. Every person who demonstrates
behaviour or activities that cause or may cause adverse effects on environment is
punished or is ordered to make restitution. He or she is also ordered to rehabilitate it
where possible.
iv) Article 8 : 10 to 60 lists projects and activities that ( may generate different
categories of wastes or cause risks) are subject to regulation by the national laws of
Rwanda
v) Article 18: Water from the sewage system as well as any liquid waste must be
collected in a treatment plant for purification before being released into a river, a
stream, a lake or a pond.
vi) Article 26: Any activities that may pollute the atmospheric pressure are governed by
an order of the Minister having environment in his or her attributions. Burning of
garbage, waste or any other object (tyres, plastics, polythene bags and others) shall
respect regulations of competent authorities.
vii) Article 27: The use of substances that pollute the atmospheric pressure that deplete
the Ozone Layer or that may cause climatic changes is governed by an order of the
Minister having environment in his or her attributions.
viii) Article 32: No one is permitted to dispose waste in an inappropriate place, except
where it is destroyed from or in a treatment plant and after being approved by
competent authorities.
ix) Article 33: Any waste, especially from hospitals, dispensaries and clinics, industries
and any other dangerous waste, shall be collected, treated and changed in a manner
that does not degrade the environment in order to prevent, eliminate or reduce their
adverse effects on human health, natural resources, flora and fauna and on the
nature of the environment.
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x) Article 34: Burying toxic waste is only done when there is an authorisation and in
accordance with special regulations determined by an order of the Minister having
environment in his or her attributions.
xi) Article 35: Removal of waste shall be done in accordance with existing rules and
where possible it shall be carried out with an aim of enhancing productivity.
xii) Article 40: Public administration, private institutions, international organisations,
associations and individuals are obliged to conserve the environment at all possible
levels.
xiii) Article 47: The treatment of liquid waste is the obligation of the State, the
population and all other parties that may perform activities that degrade the
environment. Concession regarding treatment of such liquid waste may be granted to
any other competent person.
xiv) Article 48: Central Government administration and decentralised entities are
obliged to prepare a plan of action and to draft emergency plans in all domains in
order to protect the environment.
xv) Article 56:The State establishes appropriate standards for treatment of waste in
order to produce more productivity (10 to 30, provides the means of achieving this)
xvi) Article 59: Competent authorities shall coordinate national activities and monitor
the implementation of international conventions and agreements relating to
environment.
xvii) Article 62:
Decentralised entities shall have the responsibility of designing plans of
collecting and treatment of domestic waste.
Decentralised entities are also responsible for collecting and piling domestic
waste. This is carried out in collaboration with institutions, Districts, Towns
and Municipalities or associations and authorised competent individuals.
Decentralised entities shall also put much emphasis on the removal of any
other waste in any possible way depending on its nature and quantity,
supervision and its treatment.
Upon the advice of the committees responsible for the protection of
environment referred to in article 66 of this organic law, consultative
committees of Districts, Towns and Municipalities, shall determine a hygiene
and sanitation service fee.
xviii) Article 67: Every project shall be subjected to environmental impact assessment,
before obtaining authorisation for its implementation. This applies to programmes
and policies that may affect the environment. An order of the Minister having
environment in his or her attributions shall determine the list of projects mentioned
in this organic law.
xix) Article 69: The environmental impact assessment shall be examined and approved by
the Rwanda Environmental Management Authority or any other person given a
written authorisation by the Authority. The promoter pays a levy reduced from the
operating cost of his or her project excluding the working capital. This tax is
determined by the law establishing the National Fund for the Environment. The
environment impact assessment shall be carried out at the expense of the promoter.
xx) Article 70: An order of the Minister having environment in his or her attributions
establishes and revises the list of planned works, activities and projects, and of which
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the public administration shall not warrant the certificate, approve or authorise
without an environmental impact assessment of the project. The environmental
impact assessment shall describe direct and indirect consequences on the
environment.
xxi) Article 75: provides for Control, Monitoring and Inspection.
xxii) Article 79: Enterprises or operations that excessively pollute environment are
subject to inspection by competent experts. The owner of the enterprise or operations
meets expenses of such an inspection. The procedure through which such an
inspection is conducted is specified by the order of the Minister having environment
in his or her attributions. Findings of such an inspection are transmitted to the
competent authorities.
xxiii) Articles 80 – 94: lists the prohibited activities (e.g. waste creation and poor waste
management) waste that impact negatively on the environment.
xxiv) Articles 95 -115: elaborates punitive sanctions against activities that adversely
impact on the environment e.g. waste creation and poor waste management)
These provisions of the Organic Law (No 04/2005) are relevant in guiding the Environmental
Impact Assessment for Waste Management Projects and waste generating activities in
Rwanda to ensure safety, health and environmental conservation.
Apart from the Organic law there are other legislative instruments and various socio-
economic development strategy documents whose relevance to Waste Management varies
depending on each particular project activities or location. These include:
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Others relevant national policy documents that provide for the protection of the environment
from pollution include:
i) The Rwanda Investment And Exports Strategic Action Plan, 2005-2007” and “Vision
2020” call for a well regulated environment management system that takes into
account principles of sustainable development while at the same time contributing to
poverty reduction.
ii) Agricultural policy (July 2004) recognises the need for the protection against land,
water and soil degradation of pollution.
iii) Strategic Plan for Agriculture in Rwanda (October 2004) in section 8.2 (345 -347)
recognises the need for the protection of environment, water and land.
The key stakeholders in the waste management EIA are listed in table A10 in Appendix IX.
Apart from MINIRENA and REMA there are other government agencies and institutions that
are public and private are involved in waste management or waste generating activities.
However municipalities, industries and the agricultural sector will have a big role because of
the volumes and characteristics of the wastes that they generate and manage. The key
environmental management institutions have the following responsibilities:
REMA: Mandated by law, REMA has a responsibility to organise the EIA procedure by
undertaking screening, guiding developers on assessment procedures, conducting public
hearings, reviewing EIA reports based on the terms of reference (ToR) and taking decisions
on approval or disapproval of proposed projects. The Authority is also responsible for
monitoring implementation of environmental protection measures recommended by EIA
studies. REMA advises the Government on legislative and other measures for the
management of the environment or the implementation of relevant international conventions,
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treaties and agreements in the field of environment. The roles of REMA in the EIA processes
is summarised in the General Guidelines and Procedure for EIA Part 3, section 4.
MINAGRI: It is in charge of agriculture. It is also the lead agency for the implementation of
Agricultural policy (July 2004) that recognises the need for the protection against land, water
and soil degradation or pollution. Since agriculture has associated waste generation which in
some cases can be hazardous, MINAGRI has the responsibility to guard against
environmental degradation from agricultural activities that generate wastes.
Districts: The districts with advice from committees responsible for the protection of the
environment implement decentralised environmental protection and management activities.
Waste management is a key decentralised activity which the districts have to plan and
implement its management.
Developers: The developer has direct responsibility for the project and should provide
necessary information about the project at all stages of the EIA process. Developers hire
experts to undertake EIA studies on their behalf and answer questions about potential
impacts and proposed mitigation recommendations at public hearings. Developers have the
responsibility to implement the environmental management plan including mitigation
measures as proposed in the EIA report and carry out subsequent environmental monitoring
and auditing.
EIA Experts: EIA experts are professionals registered with REMA to undertake impact
studies. They help the developer to carry out EIA, design mitigation measures, prepare EIA
report, and design environmental management and monitoring plans.
Lead Agencies: Lead agencies such as government ministries or departments have the
responsibility for management and protection of environmental resources, public health and
socio-economic development. Lead agencies are responsible for the EIA of projects under
their sectors. They provide valuable technical information to EIA experts during EIA studies
and are involved in the review process. Key lead agencies in waste management are
government agencies such as MINIRENA, MINAGRI, MINALOC, MINISANTE, urban
authorities (e.g. KCC) and MINIFRA.
The Public: Communities have a right to take part in the EIA process. Public participation
allows important social and environmental problems to be identified and gain consensus on
the nature and adequacy of proposed mitigation measures and recommendations. The role of
the public in the EIA process includes contributing information and advice to EIA studies
during scoping and public hearing process. The public also advises project developers and
REMA on approaches to avoid, minimize or compensate for adverse environmental impacts.
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Academic Institutions: Members of academic institutions are commonly co-opted on EIA
Technical Committees. They also institutionalise environmental education in their curricula.
In this case integrated waste management should be included in the curricula. Developing
training modules for both EIA and waste management and implementing training
programmes could be done by academic institutions liaising with REMA.
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PART III: GUIDELINES FOR WASTE MANAGEMENT ENVIRONMENTAL
IMPACT ASSESSMENT
3. INTRODUCTION
EIA is a systematic step by step process that is initiated by the proponent/developer and it
involves many stakeholders whose contributions are vital to cause informed decision on a
proposed project. The steps of carrying out EIA are outlined here below and summarized by
Figure 2.1.
A developer is required to prepare a project brief which is a description of the project. This is
background information on the project for consideration by REMA. The EIA process
normally begins once the developer has submitted the project brief to REMA for screening.
Project brief format is presented in Appendix I (also see general Guidelines for EIA, REMA
2006 section 2.1).
3.2 Screening
This is the task of deciding whether or not an EIA is required for a particular project. Basic
details of the proposed development will be needed for the project to be screened. Screening
results in the categorization of the proposals in three categories:
Appendix III presents key steps in screening projects. For waste management factors like the
category of waste (e.g. hazardous, toxic, etc), characteristics (organic, inorganic,
biodegradable, etc), waste generation rate, the size of the population to be served by the
project or impacted by the project and project location are the critical information required to
determine whether an EIA is necessary. The general Guidelines for EIA in Rwanda (REMA
2006) in Appendix 2 provide the general criteria for screening. The Ministerial Order
establishes the list of works, activities and projects in Rwanda that have to undertake
Environmental Impact Assessment. However every project will have unique associations to
require screening. A summary of information on screening is provided in the Table 2.1.
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Figure 2.1: Steps in carrying out EIA displayed as a Flow Chart
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Table 2.1: Summary information on screening
Screening Typical proposal that Screening methods Screening information Typical project list
require full-scale EIA required by decision- categories
makers
It is a process for Natural resources IEE Information on the Full-scale EIA
determining whether or exploitation that proposal and its required
not a proposal requires release wastes (e.g. Project lists -inclusive potential impacts
Some further
full-scale EIA and the mining and quarry) Exclusive list Level of confidence environmental
level at which the
assessment should occur Oil exploration and Decision-makers’ of predictions- analysis required
mining discretion impacts
No EIA required
Infrastructure Characteristics of the
development environment and its
resilience
Agriculture and agro-
industry Planning,
environmental
Industrial activities management and
Extractive industries decision-making
framework
Waste management
and disposal ( Degree of public
landfill, transfer interest
stations, wastewater
treatment, large
incinerators,
hazardous waste)
Storage of wastes
Waste transportation
Trade in waste
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If a decision is made at screening stage to exempt a project, or to approve its
environmental aspects on the basis of identified mitigation measures, such a decision
shall be taken by the Authority (REMA).
If, however, after screening, it is determined that the project requires a detailed
Environmental Impact Study, a certificate shall only be issued after approval of the
Environmental Impact Assessment. See also section 2.1.2 of the General EIA Guidelines
for Rwanda that lists the project categories (IL1, IL2 and IL3).
3.3 Scoping
i) Identify the characteristics of the proposed development that are likely to give
rise to impacts.
ii) Identify what type of impacts that may arise that need to be addressed in the
EIA study.
iii) Determine which environmental resources and people in the vicinity of the
proposed site are likely to be particularly sensitive to the above impacts, and
what categories of impacts are likely to be a problem in this respect.
iv) Suggest delineation of the appropriate boundaries to be considered in the EIA
Study.
v) Provide questions about the proposed project which should be answered
through the EIA Study.
vi) Give alternatives to the proposed action.
vii) Indicate the full range of stakeholders to be consulted and suggestions for full
public involvement in the process.
viii) Identify the full range of stakeholders who may be affected or are interested in
the proposed project.
ix) Provide other technical aspects related to the proposed action.
x) Identify other past, or foreseeable future projects in the area that may be
impacted upon by, or will impact on the proposed project; and
xi) State how the proposed project conforms to existing laws, policies and
regulations.
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In case the project characteristics or the boundaries of the proposed site changes, then the
potential impacts may also change, and the scope of the EIA will need to be reviewed.
There are generally benefits from focusing attention on the key issues of concern. Not all
issues identified will have the same degree of relevance for all proposals. The
identification and prioritization process should therefore result in:
The EIA should address the key issues as fully as practicable. However the level of
analysis should reflect the level of significance of the impacts and their importance for
the proposal. Lesser attention should be given to those issues which have lesser
significance. For significant issues, there should be sufficient analysis to develop a
sustainable mitigation strategy for any potential adverse impacts. The consideration of
alternatives, particularly alternative sites or schemes, during the scoping stage is
important. The scoping report should indicate why the preferred alternative was chosen
on environmental grounds. The main part of the EIA can then concentrate on the
preferred option. Terms of Reference (ToR) for the EIA study, is produced at this stage
of the EIA process. Appendix VIII of these guidelines provides the format for ToR.
Guidelines for preparation of ToR are in appendix 4 of the General Guidelines for EIA
for Rwanda.
The scoping exercise shall conclude with the identification of the relevant inter-
disciplinary expertise necessary to address the identified significant impacts. The names
and qualifications of the experts identified to undertake the Environmental Impact Study
shall be approved by REMA. Summary of information on scoping is provided in the
Table 2.
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Table 2: Summary information on scoping
Scoping Purpose of scoping Steps in scoping process Who is involved in Outline of ToR
scoping
A process of Consider project Prepare outline of the The Proponent Background to the
interaction alternatives EIA scope proposal
The Authority
Identifies Inform affected Develop the scope Context of the
public through informal Lead Agencies issues
i. Boundaries of
EIA study Identifies impacts
discussion Environmental Alternatives
Make the draft scope Practitioners,
ii. Important issues Understand local widely available Experts, Institutions and
iii. Information for values consultants public involvement
Identify issues of
decision-making Evaluated concern Those affected Required
iv. What to be concerns by the project information
Evaluate concerns
considered Define EIA The wider Analysis of impacts
during EIA boundary Incorporate concerns community
Mitigation and
Identifies concerns, Determine Develop strategy for monitoring
evaluates, organizes, methodology and addressing concerns
presents to assist consultation Conclusions and
decision-making procedures Provide feedback recommendations
Suggested format for TOR for Waste Management EIA is in appendix VIII.
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3.4 Baseline Environmental Conditions of the proposed Project
Based on the information from the scoping exercise as contained in the Terms of
Reference, an Environmental Impact Study shall be conducted and an Environmental
Impact Statement (EIS) will be prepared. The ToR produced during scoping should be
adhered to strictly from this stage of EIA till submission of the EIS.
Data already existing should be obtained as the first step in collection of baseline
information. It can then be reviewed for its relevance to the proposed project and used as
a basis for determining what survey work may be needed. Original data is required on air
quality, odours and noise; socio-economic situation; water quality, soil quality and
aquatic biology; terrestrial ecology; landscape. Original surveys should be conducted
initially at a general level to identify whether more detailed survey will be required. The
waste management EIA will consider specific issues during the assessment and reporting
(Table 3).
Data collection must focus on the key issues needing to be examined for the EIA
(identified during the Scoping process), and should be collected at the appropriate time(s)
of year taking into consideration seasonal climatic variables. Consider the likely
monitoring requirements during survey planning, so that the data collected is suitable for
use as a baseline to monitor impacts and mitigation measures in the future.
Assess the need for long-term sampling as early as possible. Carry out data collection is a
sufficiently wide area to ensure adequate coverage for monitoring. For example,
watercourses (e.g. rivers) should be assessed as far up and downstream as necessary to
assess to enable good future monitoring of beneficial or deleterious changes in water
quality or aquatic biota. The distances involved will depend on the characteristics of any
existing waste dumping, landfills or discharge close to the watercourse(s) in question, and
on the location and characteristics of other discharges affecting the watercourse(s).
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Table 32: Issues to be considered in doing Environmental Impact Assessment (source
Uganda EIA Regulations 1998 with modifications)
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3.5 Prediction of Impacts
Impact prediction must encompass the whole waste management cycle from waste
generation, temporary storage, transportation, landfill (construction and operation) for
solid wastes and for wastewaters sewerage network, construction and operation of the
wastewater works. Impacts should be quantified wherever possible, or fully described if
not quantifiable. The following regarding impacts should be considered:
Impacts on the following specific aspects of the physical, socio-cultural and biological
environment must be assessed:
Impacts of the scheme as proposed should be clearly identified, so that if for any reason
mitigation is not implemented, the consequences will be clearly identified in the EIA.
The impacts and the assigned mitigation measures must be presented clearly for easy
understanding and adoption of the mitigation measures.
3.6 Evaluation
Criteria for evaluation of impacts must be stated. Where possible, legislative standards or
international standards should be followed (e.g. discharge standards, waste management
regulations, etc). If no suitable standards exist, descriptive criteria may be used, but must
be fully explained. Evaluation of significance of impacts should take account of the
magnitude, duration and extent of impact, and whether the impact is temporary or
permanent. The consultant should identify and, where possible, quantify the level of
19
uncertainty associated with these predictions. Some indication of probability of
occurrence of impacts should also be included.
3.7 Mitigation
Reporting of mitigation should include such specific features which have been
incorporated during the planning and design of the proposed development. Where
mitigation has not already been incorporated into the design or siting of the proposed
project during the EIA process, or specific commitment to mitigation measures from the
developer has not been obtained, mitigation measures should be included as
recommendations, and should be clearly stated as such.
Details of EIA report reparation is provided in appendix X of these guidelines for waste
management EIA, where all the sections of the report are discussed to help on the report
preparation.
3.9 Review
Review of the EIA Report /Environmental Impact Statement (EIS) is usually done by the
authority (REMA), a government lead agency or an independent panel of reviewers. In
this review, the level of address of the Terms of Reference set out for the study shall be
considered. After reaching a decision on the proposed action, if it is approved, the
developer will be licensed or permitted to implement the project in accordance with the
mitigation measures stipulated in the Environmental Impact Statement and any other
terms and conditions attached to the approval. If it is denied, the developer may, if such
denial is based on environmental considerations that can further be improved, be urged to
revise the proposed action to eliminate adverse impacts. The developer may appeal
against the decision in line with the provisions of the Organic Law.
20
3.10 Monitoring and audits
3.11 Decommissioning
For various reasons a project may be decommissioned. The decommissioning may have
impacts on the environment that have to be understood in order to put in place adequate
mitigation measures. The impact may be caused by items such as written off equipment,
chemicals, physical structures, etc of the project if they are just abandoned on site without
proper management. An environmental assessment of the decommissioning process will
provide adequate mitigation measures.
Article 69 of the Organic Law (No. 04/2005 of 08/04/2005) indicates that environment
impact assessment shall be carried out at the expense of the developer. Upon project
approval, a developer is required to pay an administrative fee to the environmental fund
(FONERWA) to be determined as a percentage of the estimated cost of the investment.
Conducting EIA on waste management projects requires a team that should include, but
not necessarily be limited to the following:
i) Environmental specialist.
ii) Waste management or pollution assessment expert (expertise in the waste
category being assessed e.g. solid waste, sewage treatment, medical waste,
etc).
iii) Environmental Lawyer.
iv) Health (public health, occupational health) specialist.
v) Environmental engineer.
vi) Aquatic biologist, microbiologist or biochemist.
vii) Socio-economics specialist.
viii) Terrestrial ecologist.
ix) Process engineer in wastewater treatment.
x) Hydrologist/hydrogeologist.
xi) Development planner or landscape architect.
xii) Air quality (odour, dust and noise) specialist.
xiii) Transport/roads specialist (e.g. for effective and efficient routing of waste
transport system).
xiv) Antiquities specialist.
21
The composition of the EIA team will vary depending on the project type and complexity
of the waste management. Some team members may fulfil several of the above roles if
suitably qualified and experienced. Each member of the team, for their specialist
subject(s), will follow the basic processes identified above namely: screening, scoping,
consultation, baseline data collection, prediction and evaluation of impacts, and
identification of mitigation measures. The Basic minimum academic requirement is a
University degree or its equivalent from recognised higher institutions of learning.
22
Appendix I: Project Brief format
23
Appendix II: Format of questionnaire for public hearing
The public has a right to express their opinion in the EIA processes. There is no standard
format of questionnaire for public consultation however the following may be used to
guide the process.
After the overview presentation the public may be guided to assess the following sections
(2 to 6) and express their opinion.
2. Project impacts:
3. Mitigation measures:
24
4. EIA Procedure:
5. Project alternatives:
6. Project Implementation:
25
Appendix III: Screening Process in EIA
Screening is that part of the EIA process which determines whether an EIA is required
for a particular project. A number of steps are involved in deciding whether EIA is
required for a proposed project. Explanation of each step (1-5) during screening is given
below. The process should be followed through until a decision is made on whether or
not EIA is required.
Step 1 - Is the Project listed under Article 2 of the Ministerial Order establishing the
list of works, activities and projects that have to undertake Environmental Impact
Assessment?
The first step in the screening exercise is to determine whether the project (components)
is listed under either in the above Article, Appendix V of the guidelines for EIA of waste
management or in The World Bank Category A or B projects.
In summary, if a project is not of a type listed in the Ministerial Order, these EIA
guidelines or The World Bank Category A and B projects, EIA is not required, unless a
special reason exists for further environmental examination of the project.
The second task is to determine whether there is a mandatory requirement for EIA. An
EIA will be required if the project is listed under mandatory list for EIA (Appendix V of
the Waste Management EIA Guidelines or if it is in the World Bank Category A and B
list of projects). In summary, if a project is on a mandatory list then EIA will be required.
This step is used to check whether there is any legal exemption for the project. Some
projects may be classified by the state as emergency activities that require quick response
and delay may cause disaster. These are set out in exclusion or negative lists of projects.
If a project is on an exclusion list EIA will not be required.
A country’s legislation may provide for exceptions to exclusion lists if the project is in a
specified sensitive location. Such an exception would apply if the project were likely to
have significant effects on a sensitive environment (e.g. homes, schools, rivers, wetlands,
lakes, groundwater, lake shores, river banks, etc). State legislation must also be checked
to determine any other locations defined as sensitive in which an exclusion list would not
apply.
26
Step 4 - Case-by-Case Consideration: Is the Project Likely to have Significant
Effects on the Environment?
Mandatory and exclusion lists are designed to simplify the process by identifying
thresholds and criteria defining projects, which are always or are never considered likely
to have significant effects on the environment. If a project is not on a mandatory or
exclusion list a screening decision must be made on a case-by-case basis.
Also considered in the screening analysis are the project size, type and location relative to
the sensitive ecosystems and the environment. In addition such guidance may refer to
indicative thresholds and criteria. This is used to check project activities/components that
do not appear on the mandatory and exclusion lists.
In summary, where it is decided that a project is likely to have significant effects on the
the environment through a case-by-case examination, then EIA will be required.
After the screening process, the authority will make a final decision and the developer
will be informed in writing. Screening decision is made based on findings of steps 1
through to 4 above. In the screening process the Authority may consult the lead agencies
to discuss the proposed project.
Professional judgment
Based on the professional experience the authority and the screening team can make
judgement to predict the magnitudes of the impact of the project on the environment and
decide the levels of EIA required for the project. The following should be considered
during screening:
27
iii) Identification of past, present and likely future waste management projects
that could result in cumulative environmental effects in combination with
the project.
iv) Identification of project-environment interactions and likely
environmental effects.
v) Assessment of the significance of residual environmental effects. and
vi) Determination of the need for further environmental study (EIA) or no
EIA.
i) Atmospheric Environment.
ii) Aquatic (water) Environment (surface water and groundwater).
iii) Sensitive environment (e.g. Homes, leisure facility, schools, nature
conservation areas, wetlands, hills, slopes, lakeshores, river banks, forest,
etc).
iv) Terrestrial Environment.
v) Public and Worker Health and Safety.
vi) Socio-economic conditions.
The screening process follows logical series of steps as described above in steps 1-5.
These screening steps are summarised below in Figure AI.
28
Figure AI: Diagrammatic flow of decision making steps in screening
Step 1
Is the project in a Is the project likely No EIA not required
Category listed to have a
under Article 2 of No significant effect
the Ministerial on sensitive/fragile
Order? Yes EIA required
ecosystems?
• A combination of both
quantitative and qualitative
Step 4 Yes EIA required characteristics e.g. the project
Case-by-Case will be within a specified
Is the project distance of a particular type
likely to have of area, it will generate more
significant effects No EIA not required
than a specified level of
on the environment? pollutant etc.
Step 5
Recording the Screening Decision
Formal screening decision is made, whether to require or not to require EIA. A record of
the decision is forwarded to the authority (REMA) for final decision and records.
29
Screening results
The result of the screening should clearly describe the path followed in Figure AI to
arrive at the screening decisions. Checklist such as the one displayed by Table A.I and
appendix VI can be used to explain the screening results. An example of checklist that
can be used during screening is in table A1.
30
Brief Project Description:
31
Brief Project Description:
When using these screening guidelines also refer to project screening criteria found in
Appendix 2 of the General Guidelines for EIA for Rwanda (REMA, 2006).
32
Appendix IV: Guidelines for Waste Management
1. General
1.1 The Appendix describes the commonly adopted approaches and methodologies for
assessment of waste management arising from projects. The methodologies may vary
from case to case, depending upon the nature of wastes and the latest development in
methods and techniques.
2.1 The projects that need special requirements for waste disposal are but not be limited
to, the following:
b. Livestock Rearing:
Cattle, pigs, chickens, ducks, geese, turkeys, pigeons other fowls generating wastes.
i) Abattoirs
ii) Hospitals/clinics and other health care premises
iii) Markets
iv) Recreation venues such as stadium, tourism facilities, beach facilities etc
v) Other community facilities which use ozone depleting substances or include
incinerators may need special attention in the EIA processes.
d. Wastewater works:
33
The planning and siting of sanitary facilities especially conventional sewerage in urban
areas should be done together with the urban plan or settlement plans requiring full EIA.
e. Landfills:
The planning and siting of landfill facilities in urban areas should be done together with
the urban plan or settlement plans requiring full EIA. Major issues include:
3. Waste Management
Prior to considering the disposal options for various types of wastes, opportunities for
reducing waste generation should be fully evaluated taking into account the following
factors:
Having taken into account the factors above in previous paragraph, the types and
quantities of the wastes generated as a consequence should be estimated and the disposal
options for each type of waste described in detail. The disposal method recommended for
each type of wastes should be based on the result of the assessment in section 3.3 below.
34
The impact caused by handling (including labelling, packaging & storage), collection,
and disposal of wastes shall be addressed in detail. This assessment should cover but not
limited to the following areas:
i) Potential hazard;
ii) Air & odour emission;
iii) Noise;
iv) Public health
v) Wastewater discharge;
vi) Leachate; and
vii) Inconvenience to public transport.
When large quantities of wastes are identified, the impact on the capacity of waste
collection, transfer and disposal facilities, especially the existing or strategic waste
disposal facilities have to be assessed.
In addition to the waste management practices recommended for the project, the
handling, collection/transportation and disposal of wastes, shall have to comply with the
national regulations on wastes and sanitation and waste disposal laws (e.g. Ordinance,
effluent standards, etc ) if in place . Typical waste management documents that should be
complied with include but not limited to:
In case there are no national regulations then international regulations such as WHO, US-
EPA, etc should be used and explicitly stated in the EIS.
35
Appendix V: Projects requiring EIA
1. Introduction
All projects listed under Article 2 of the Ministerial Order establishing the list of works,
activities and projects that have to undertake Environmental Impact Assessment
(infrastructure, agriculture and animal husbandry, works in parks and its buffer zones and
works of extraction mines) and those generating wastes with potential significant adverse
impacts on the environment and or waste management projects.
Factors that must be considered when categorising projects for mandatory EIA or
exemption are:
i) Waste composition.
ii) Waste characteristics with respect to human impacts (e.g. toxicity,
carcinogenicity, irritant, pathogenic, etc).
iii) Waste persistence and stability in the environment (soil and water) and
the food chain.
iv) Nature of waste (e.g. flammability, corrosiveness, reactivity, explosive,
radioactive, etc).
v) Leachability of the waste and characteristics of the leachate
vi) Degree of attenuation of the leachate within the soil-water system
36
3. Waste related activities for which EIA is not mandatory
37
Appendix VI: Checklists for impacts assessment of waste management projects
Is the area --
Densely populated?
iii.River banks
iv.Protected area
38
SCREENING QUESTIONS YES NO REMARKS
Social services?
2. Sewage Treatment
Is the area:
Densely populated?
39
SCREENING QUESTIONS YES NO REMARKS
i. Wetlands
Social services?
Aesthetics problems?
40
SCREENING QUESTIONS YES NO REMARKS
areas and local community workers?
Public hazards due to overflow flooding, burst
systems and pollution of ground water by
sewerage system?
Water pollution from inadequately disposed
sludge or direct discharge of sewage?
Health and safety hazards to workers from toxic
materials which may be contained in the
sewage flow and pathogens in sewage or
sludge?
41
Appendix VII: Preparing Environmental Management Plan
Contents of EMP
i) Summary of potential impacts
ii) Description of planned mitigation measures
iii) Description of planed environmental monitoring
iv) Description of planned public consultation process
v) Description of responsibilities for the implementation
vi) Description of responsibilities for reporting and review
vii) Work Plan: staff chart, schedules, activities and inputs of all including
lead agencies
viii) Procurement Plan that is environmentally responsible
ix) Detailed cost estimates
x) Mechanism of feedback and adjustment
42
assessment and project environmental management; (ii) conduct of the survey
and sampling program; (iii) analysis of samples and data/information collected,
and interpretation of data and information; and (iv) preparation of reports to
support environmental management. Environmental monitoring is normally
carried out before and during planning to establish baseline data needed for
environmental assessment and evaluating environmental impacts during project
implementation. It continues through project operation to detect changes in the
key environmental quality parameters, which can be attributed to the project.
The results of the monitoring program are used to evaluate the following: (i)
extent and severity of the environmental impacts against the predicted impacts;
(ii) performance of the environmental protection measures or compliance with
pertinent rules and regulations; (iii) trends in impacts; and (iv) overall
effectiveness of the project EMP.
d) Environmental monitoring should have clear objectives, and the survey and
sampling program designed to focus on data required to meet the objectives. In
addition, the design of the monitoring program has to take into account its
practicability considering the technical, financial, and management capability of
the institutions that will carry out the program and period of monitoring that will
be needed to achieve the objectives (see Table A7.2). The monitoring program
should include action or emergency plans so that appropriate action can be
taken in the event of adverse monitoring results or trends. It should also be
constantly reviewed to make sure that it is effective, and determine when it can
be stopped.
Table A7.2: Features of an Effective Environmental Monitoring Plan
43
Both the environmental management and monitoring plans need to include who will
implement them, when, and where. The capacity of the executing agency, LG, and
community organization should be reviewed to identify feasible approach for
implementing the plans. The project lifecycle should be taken into account in setting the
timing of implementation. For example, the EMP should identify environmental
mitigation measures that should be implemented in the engineering design for the
contract documents, and materials to be avoided in procurement, among others. On the
other hand, the location for monitoring should be selected based on where the impacts
would occur and the areas to be affected. To ensure that the environmental management
and monitoring plans will be implemented, it is necessary to identify the key management
issues to be included.
44
Appendix VIII: Sample Terms of Reference (ToR) for waste management EIA
studies
1. Introduction
The following guide to develop ToRs for waste management EIAs was adopted with
modifications from appendix 4 of the General Guidelines and Procedure for
Environmental Impact Assessment 2006.
i) provide the Developer with advice on how project design can avoid or mitigate
negative impacts and to enhance anticipated environmental benefits, and
ii) prepare for review by REMA, an EIA report and Environmental Management
Plan (EMP) according to national EIA Guidelines and Regulations, 2006.
The Guidelines for EIA for Waste Management should be followed during the EIA
process. The following are specific issues to address in the EIA study;
2. Project Description
The EIA Expert should provide a description of proposed project and any alternatives
being considered in sufficient detail to benefit stakeholders and decision-makers.
Policies, legislation, regulations directly relevant to the proposed waste management
project and the environment should be discussed in the EIA report. Relevant documents
on waste management and conservation should also be reviewed.
The EIA study should address key ecological (biophysical), socioeconomic and landuse
issues. In particular the impacts of wastes on ecosystems, the environment and services
should be addressed. Refer to section 3.4 of the EIA Guidelines for waste management
where key issues are presented.
While the impact study is to be focused on the above issues, the EIA Experts may, in the
course of the impact study, identify further waste management concerns which should be
investigated. Any such other issues should be brought to the attention of REMA and the
Developer.
4. Environmental Management
45
The expert should pay particular attention to identifying and recommending measures or
practices for avoiding, mitigating or managing negative impacts of the waste
management project on the environment and for enhancing potential environmental and
socio-economic benefits. Any potential measures or practices identified by the EIA
Expert should be brought to the attention of the Developer for possible inclusion in
project design and planning.
In particular, the expert should prepare an Environmental Management Plan (EMP) for
construction, operation and decommissioning of the waste management project. The EIA
Expert should estimate the costs of implementing this plan, including all capital,
operating and training costs.
To maximize opportunity for good environmental planning and design of the project, EIA
Experts should work closely with the Developer to offer feasible options to enhance the
project’s environmental performance.
6. Public Consultation
The Developer is obliged to ensure that all concerned public and private stakeholders in
the project have adequate input during the EIA study. The EIA Expert should therefore
undertake comprehensive consultation with the local community, relevant lead agencies
such as REMA, MINAGRI, MINIRENA, MINALOC, MININFRA, MIGEPROFE in
addition to any relevant waste management stakeholders identified when conducting the
impact study.
At minimum, the EIA report produced by EIA Experts should contain information
outlined in the Appendix X of Guidelines for Environmental Impact Assessment for
Waste Management.
8. Reporting Requirements
The expert should submit a final EIA report including Environmental Management Plan
(EMP) to the Developer. The Developer after reviewing and appending an EIA Report
Addendum to it, if necessary, will submit 10 copies of the final draft report to REMA.
The EIA Expert and developer should be available for discussions about the EIA report
with REMA and participate in any public hearings organised by the Authority.
46
9. EIA Team Members
EIA experts to undertake the EIA study must be recognised and authorised by REMA.
Professional experts to undertake this study are listed in section 3.13 of Guidelines for
Environmental Impact Assessment for Waste Management.
47
Appendix IX: Summary of Institutional responsibilities in waste management
Institutions Responsibilities
REMA Coordination and supervision of environmental
protection activities undertaken by environmental
promotion agencies (e.g. waste management and
sanitation)
MINAGRI Is in charge of the development of agriculture
production and animal husbandry. Implementation
of Agricultural policy (July 2004) that recognises
the need for the protection against land, water and
soil degradation of pollution (e.g. of agricultural
wastes against pollution and all other agricultural or
agro-industry activities that generate wastes).
MINALOC Is in charge of mobilising the population to
participate in the management and protection of the
environment (e.g. best practices in waste
management).
MINICOM Is in charge of the promotion of industries, trade and
agro-livestock production cooperatives and
management of protected tourist areas. To ensure
and promote environmental conservation.
MININFRA In charge of the organisation of human settlement,
town planning, public infrastructure and transport;
and waste management systems associated with
these.
MINECOFIN In charge of the mobilisation of funds, coordination
of donors and allocation of budgets to different
Ministries. Coordination of the financing of waste
management projects
MINIJUST In charge of giving support in the resolution of
conflicts by formulating appropriate laws
MIGEPROFE In charge of mobilisation of men and women in the
activities of natural resource protection and
management.
MINISANTE In charge of the promotion of hygiene and
sanitation among the population
MINEDUC In charge of training human resources in the
management and protection of natural resources
Higher Institutions of learning In charge of capacity building and research in waste
management and environmental management
NGOs/CBOs In charge of support and working with communities
in environment and waste management projects,
capacity building and financing community projects
Development partners Support sector budgets
Local Governments and Town/City Councils Implement decentralized services (e.g. sanitation
and waste management provision)
Private sector Work under contract to implement environment
management projects (e.g. design and construction
of waste management facilities)
Community Demand and contribute positively to waste
management and sanitation to ensure environmental
conservation. Establish recycling, reuse waste
businesses
48
Appendix X: Guidelines for Waste Management EIA Report
For a good EIS, it must be technically robust, but at the same time it must be clear,
intelligible and unambiguous. The report should be kept short and simple and avoid the
use of technical terms unless absolutely necessary. Technical appendices may be included
as appropriate.
Below is the proposed contents list for the waste management EIA report:
1. Executive summary.
2. Introduction.
3. Legislative framework.
4. Description of the proposed development.
5. Potential impacts, alternatives and consultation.
6. Description of the existing environmental conditions within and surrounding
the site.
7. Prediction and evaluation of significant environmental impacts.
8. Mitigating measures and alternative processes.
9. Residual impacts.
10. Monitoring plan.
11. Conclusions.
12. Bibliography/ list of references.
13. Appendices (include e.g. Technical data, EMP and maps).
1. Executive Summary
The content and structure of the summary should broadly follow the heading (sections)
structure of the EIA report.
49
2. Introduction
The introduction should present the background to the project, the purpose of the EIA,
responsibility for the EIA, the content of the EIA report, responsible party for preparing
the EIA report and the EIA methodology used.
3. Legislative Framework
This section deals with the laws and their administrative regulations considered during
the planning of the project, e.g. the Organic law on the environment, Environmental
Policy, Decentralization policy, as they relate to waste management and the environment
and other sectoral laws, guidelines, regulations and standards, ordinances or by-laws
relevant to waste management. It should also deal with issues of licences, permits and
certifications required by law for waste management if any. The statutory documents
reviewed in this section will differ depending on the nature of the project being assessed
and the category of project ( e.g. industry, agriculture, landfill) and the characteristics of
the environment (e.g. wetlands, surface water, groundwater, human settlements, land use,
etc) anticipated to be impacted.
This section of the report should be brief, and may refer to a feasibility study carried out
by the Developer or their agent. Such a feasibility report should be summarized within
the main EIA report, and could be incorporated as a technical appendix. The following
should be covered briefly.
b) The Location
50
water; Local land use plans and other community activities in the area; any
historical sites or environmental protection areas.
a) Maximum area (e.g. land, water, wetland, forest, etc) affected by the proposal.
b) On-site plans, layout, photomontages or similar, and cross sections identifying the
existing and proposed facilities (e.g. landfill drawings, transfer point
plans/drawings , incinerator technical drawings, composting facility drawings,
recycling plant drawings, wastewater treatment works and any off site associated
pipe work or sewage collection systems).
51
i) Power supply requirements and proposed energy conservation measures
ii) Details of access arrangements and whether these are completely new,
upgraded or already in existence.
iii) Identification of drainage lines and on site surface water management
systems.
iv) Employment during the project phases.
v) Arrangements for effluent treatment or storage during maintenance and/or
breakdown of plant.
i) The capacity and type of any nearby wastewater treatment facility or solid
waste management facility; or waste storage facilities or and other type of
waste treatment.
ii) The relationship of the proposed development to previous or existing
operations in the proposed project area.
iii) Past environmental performance of similar nearby projects, including impacts
on the environment and the effectiveness of any impact mitigation.
52
The section summarizes the outcome of the process of identification and prioritization of
potential impacts, it should include:
a) Potential Impacts
During operation of any wastewater treatment works positive impacts may occur on the
quality of a watercourse to which a works already discharges, and on health and living
standards of local residents. Negative impacts on water quality of receiving water may
also occur, if it is not currently used for effluent disposal. Negative impacts are likely
regarding loss of useful land to the project, odours, noise, traffic and landscape. Disposal
of sewage sludge generated may be either a positive impact (if of suitable quality,
adequately treated and used in agriculture), or a negative impact (if of unsuitable quality
for use in agriculture, insufficiently treated, or disposed to landfill or other waste disposal
site). Other impacts, both positive and negative, will occur, but will depend on the
particular site, proposal and circumstances. Solid wastes that can be recycled or reused
can be a source of income to the community and entrepreneurs with a positive impact.
Organic vegetable matter can be composted and compost sold, plastics and metals can be
recycled or reused.
Landfill site pose negative impacts in the form of land losses, odour, noise, traffic,
landscape, insects, rodents, scavengers, birds and aesthetics. Leachates may also pollute
land and water courses if not contained and treated. Positive impacts associated with
landfill is the reduction of waste nuisance in urban area, provision of employment
opportunities to waste workers, livelihood opportunities to waste pickers and
improvement in public health and living standards. Other opportunities in the solid waste
sector are composting, recycling and reuse of wastes which can provide business
opportunities to the community and entrepreneurs.
53
The procedures or methodology used to identify and priorities issues should be outlined.
This should include:
b) Alternatives
i) Alternative location(s).
ii) Alternative schemes and layouts of the development and services (these may
be further developed under mitigation section).
iii) Alternative management or operational practices (these may be further
developed under mitigation section).
The scoping exercise can explicitly report on what grounds the preferred alternative was
chosen. The main part of the EIA can then concentrate on the preferred option.
c) Consultation
The EIA report should include details of consultation undertaken as part of the EIA
process. Those consulted should include relevant stakeholders. A brief description of the
reason for and the outcome of consultation should be included. For wastes regulatory
powers or responsibilities concerning planning control, waste disposal, and discharge
limits to fresh waters, emissions to air and application of sludge to land must be
consulted. Other agencies or departments might include those responsible for
conservation of natural resources (water, wetlands, forests, National Parks, etc), as
appropriate.
54
ii) Water quality and aquatic ecology.
iii) Socio-economic and cultural environment.
iv) Transport system and access.
v) Air quality.
vi) Flora and fauna.
vii) Hydrology and groundwater.
viii) Visual environment and landscape - Aesthetics.
ix) Proposed project site in relation to other landuse(s) in the area
x) Risk and hazards.
xi) Meteorological data.
xii) Landscape and topography.
Data must be specific to the proposed site, rather than general information on a particular
area, and the EIA should only deal with issues relevant to the proposal being assessed.
Each issue and the level of detail should match the level of importance of the issue in
decision-making. To make the EIA report easier to read, it may be sensible to include the
specialist detail for each of the following sections as a technical appendix to the report,
with a summary of each section in the main EIA report.
The status of the water resources nationally and internationally (e.g. tranboudary) must be
discussed.
55
11. Social, Economic and Cultural Issues
i) Existing health of the local population (in quantitative terms where possible)
which may be affected by provision or change to waste treatment or collection
(e.g. local incidence of water borne diseases).
ii) Existing potable water usage of the community, which may be affected after
provision of waste collection and treatment system.
iii) Existing charging structure and cost of waste management.
iv) Wastewater disposal and solid waste disposal, which may be affected by
provision of different waste collection and treatment systems.
v) Impacts of existing waste disposal systems which may be affected by
provision of different systems.
vi) Existing and projected water treatment facilities for potable supply, which
may be affected by provision of different waste management systems.
vii) Local employment conditions which may be affected during construction and
operation.
viii) Existing economic situation which may be affected by provision of different
waste treatment, especially concerning: other developments, land values,
agriculture, tourist facilities.
ix) Identification of items or sites of cultural or historical significance likely to be
affected by the proposal, and an assessment of their cultural and/or financial
importance.
i) Likely opportunities for re-use of sewage sludge and solid wastes and/or
effluent(e.g. availability of agricultural land, attitudes towards use of sewage
sludge and wastes in agriculture, ease of distribution of sludge to end users,
legislative requirements for such re-use, manure and briquette production
from solid wastes, solid waste reuse and recycling, wastewater use in
agriculture).
ii) Potentials sites and routes for disposal of wastes.
iii) Potential disposal sites and routes for excess material from the site during
construction of the management site.
Alternative ways of solid waste management that reduce pressure on the conventional
methods (landfill, incineration) are often overlooked in EIA. EIA of solid waste
management should include data and environmental management systems (EMS) with
explicit waste management activities such as:
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i) Waste segregation or sorting.
ii) Waste recycling options.
iii) Wastes reuse options.
iv) Composting.
v) Potential contribution from waste pickers (scavenging) towards waste
reduction.
vi) Itinerant waste buyers.
vii) Wholesalers.
viii) Recycling enterprises.
ix) End-users.
Here the community can be encouraged to get involved in waste management through
awareness programmes, capacity building and financial facilitation to form micro-or
small waste businesses. There is already an NGO making manure and briquettes in Kigali
and this should be supported and duplicated in other areas as informal measure to reduce
the pressure of waste management.
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15. Flora and Fauna
Terrestrial and/or aquatic flora and fauna or their habitats which are likely to be disturbed
or obliterated by the project must be identified and their importance evaluated. As a
general rule, distribution data should be presented as habitat or species location maps,
shown in relation to position of the proposed works. Data collection and surveys should
include:
Information to allow assessment of potential transport and access impacts should include:
i. Existing drainage patterns, including the location of wells and boreholes and
identification of areas prone to floods, the range of water heights/depths in the
area;
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ii. Groundwater regime and quality, e.g. depth to groundwater level, whether
groundwater is used for water supply and its quality, whether control of the use of
groundwater is done in the proposed project area;
iii. Presence and importance of structures likely to be affected by changes in
groundwater levels.
The nature of the existing visual environment and landscape should be assessed for their
sensitivity to impacts such as changed, obstructed views and unsightly activities.
Particularly sensitive receptors likely to be affected in the vicinity should be identified,
such as tourist establishments, prestigious developments, schools, recreation facilities,
etc.
Risks and hazards posed by the proposed project should be identified and if possible
quantified. Information should include:
EIA report should include a discussion of impacts during each of the phases of the
proposed waste management project. Impacts of different aspects of the proposed project
on the above sectors of the environment should be considered separately. Criteria for
evaluation of the significance of impacts should distinguish between impacts which are:
Criteria should be based on local legislative standards wherever possible. Where these are
not available, acceptable international standards should be used (e.g. WHO, US EPA
guidelines, etc.). In all cases the choice of the appropriate standard must be robust and
defensible. If no suitable standard is available, then the criteria developed and used must
be clearly explained in the EIA. Use of matrices can be very helpful in co-coordinating
and summarizing information for this section of the EIA report. Examples of potentially
significant impacts of waste management developments include (but are not restricted
to):
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i) Positive impacts on water quality, health of local population, aquatic flora and
fauna currently affected by untreated or inadequately treated wastes.
ii) Negative impacts on flora and fauna or local inhabitants by occupation of site
or direct removal of habitats of nature conservation, agricultural or
aquaculture importance.
iii) Positive impacts by provision of sewage sludge for use in agriculture, or this
impact could be negative if the sludge is not adequately treated.
iv) Positive effect on community livelihood by providing business opportunities
(e.g. composting, recycling, waste picking and sales, etc).
v) Negative indirect effects, e.g. dust generated during construction affecting
crop growth, damage to crops by spillages or leakage onto adjacent land or
into irrigation waters.
vi) Positive effects on local economy allowing rapid development, by provision
of waste treatment.
vii) Negative impacts on the community (infections, injury, smell, vermin,
contamination, etc).
viii) Negative impact caused by pollution of water (e.g. eutrophication, fish kills,
disease organisms, poisoning, etc).
ix) Negative impacts of pollution of land and groundwater causing loss of use of
these resources.
x) Negative odour and aesthetic problems.
This section considers mitigation measures and strategies to reduce negative impacts on
different sectors of the environment. Mitigation must be sustainable, integrated and
feasible. Some mitigation measures should be implemented at a very early stage of design
of the works easily, but are difficult or expensive to implement once early design has
been completed. Therefore it is vital that any mitigation should be discussed and
developed in consultation with the developer and regulatory authorities throughout the
EIA process. This section of the EIA report should therefore be a summary of any
mitigation already implemented in the ongoing design of the facility, and also include any
recommended mitigation strategy to be implemented during the other project phases.
This section may also include any enhancement measures for which there is a
commitment from the developer, which will enhance any positive impacts of the
development. This may include measures such as planned public education programmes
in waste management, re-use and recycling, composting, entrepreneurship, etc. Suitable
mitigation for waste treatment facilities will depend on the design and layout of the
facility, as well as the local environment, and location.
This section should give a summary of those impacts which will remain assuming
mitigation has been implemented. It will therefore include those impacts for which there
are no suitable or only low levels of mitigation, and positive impacts.
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23. Monitoring Plan
The EIA should outline the need for, and use of any proposed monitoring plan, its
duration and reporting procedures, define suitable criteria for monitoring, and actions to
be taken in the event of non-compliance with these criteria.
b) Monitoring.
This section presents a monitoring plan. This is to ensure commitments in the EIA,
subsequent assessment reports, and approval or licence conditions. This should
demonstrate that sound environmental practices that will be followed during the
construction and operation of the development project. It should cover the following:
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The Environmental Management Plan should describe the following monitoring details:
i) The key information that will be monitored, its criteria and the reasons
for monitoring (e.g. limits of parameters such as BOD, faecal coliform
bacteria, suspended solids, ammonia and nutrients, drug residues, to be
achieved in the effluent and also heavy metals from solid waste
leachates).
ii) The monitoring locations, intervals and duration of monitoring.
iii) Auctions to be undertaken if the monitoring indicates a non-compliance
with the defined criteria or an abnormality.
iv) Internal reporting procedures and links to management practices and
action plans.
v) Reporting procedures to relevant authorities and, if appropriate, to the
consent authority (REMA) or the community.
Guidelines for waste management (Appendix IV) are also important as reference during
EIA.
24. Conclusions
This should be a summary of the prediction of the impacts and evaluation of the impacts,
the mitigation measures assigned to the impacts and the alternatives and also the
identified residual impacts to emphasize:
The developer shall submit the EIS to REMA that will in-turn forward copies to the Lead
Agency and to the stakeholders and interested parties for comment and review, before
approval is considered. Any comments received shall be taken into account in making a
decision on the EIS.
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