Bosnia and Herzegovina

Sustainable Forest and Landscape Management Project

Environmental Management Framework

November 1, 2013

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GENERAL INFORMATION The overall Project Development Objective (PDO) and Global Environmental Objective (GEO) of the Sustainable Forest and Landscape Management Project is to build capacity and demonstrate approaches for sustainable forest and land management through integrated management of vulnerable forest, scrub and pasture landscapes. The description of components envisaged under this Project are given below: Component 1. Enhance the Planning and Monitoring for SFLM

This component focuses on selected activities through a targeted capacity building effort, building on existing

efforts introduced and identified under the FDCP. The component addresses current remaining needs for

broad-based institutional support that are aimed at both the productive and non-productive forest areas and

landscapes to improve management, production and sustainability.

Sub-component 1.1. Forest Block Management Plan Certification Support. This sub-component focuses on improving the sustainability of forest management, and benefit sharing with local peoples, through implementation of forest management to certifiable standards (e.g., FSC or Program for Endorsement of Forest Certification PEFC) in regions of the country that have not had the resources or capacity to move forward on this important forest certification effort. In FBiH this will largely consist of assisting with initial certification efforts while in RS this will focus on recertification. In both the FBiH and RS this sub-component will also cater for a review national and local legislation from the perspective of timber exports to analyze compliance with EU requirements.

Sub-component 1.2. Forest Road Strategic Plan. This sub-component will help identify the most urgent forest road rehabilitation projects (to improve both environmental and economic performance and help meet forest certification requirements) through the preparation of a model forest roads master plan and by instigating the adoption of best practice forest road rehabilitation guidelines to minimize environmental impacts, as part of the government’s expected efforts to rehabilitate the forest road network in both entities. The resultant best practice guidelines would also ensure environmental/social impact assessments of all road works and support the forest enterprises’ certification efforts.

Sub-component 1.3. Forest Management Information System (FMIS) Enhancements for Mainstreamed Decision-Making. Improving forest management operations through capacity building and localized development of the FMIS was already introduced under the FDCP. Existing centralized and decentralized IT capacity is already in place. This project will improve ability for the FMIS to be used in decision-making through introducing selected information relating to climate change: specifically this includes introduction of carbon stock accounting for mitigation efforts, and introduction of systems to monitor incidence of losses related to fires and pests. In addition, this sub-component will also support selected issues relating to governance improvement; these include social and financial accountability, flow of information, and potential artificial export barriers. Sub-component 1.4. Monitoring and Evaluation (M&E). Some additional M&E work will be supported throughout the project to assess effectiveness of existing and innovative systems. In general, this can include support for community-based monitoring, participatory processes, and supplementary monitoring being undertaken through existing extension services.

Component 2. Demonstration and Replication of SFLM Techniques in Vulnerable Areas

As the scrub forest is currently poorly stocked and areas of grassland are only slowly and unevenly converting

to forest, there is potential to substantially improve forest/habitat management, which would help BiH’s

climate change mitigation and adaptation program. The Project would be looking at landscape management in

terms of forest, degraded scrub, and unutilized pastures. The techniques to be demonstrated include already

developed sustainable forest practices through actually undertaking the activities as pilots.

Sub-component 2.1. Afforestation - Assisted Natural Regeneration and Stand Rehabilitation. These activities will be undertaken consistent with existing management plans in the public forest estate. Support will be given for sites on minimum areas of 50 ha, providing investment needs as well as operational support for up to 3 years for monitoring and management. It is expected that a minimum of 500-1000 ha will be directly targeted within each entity, for such activities as (i) afforestation with native species; (ii) afforestation with new species appropriate to drying conditions or increased fire hazard; (iii) stand management complementing natural regeneration through thinning, weeding; (iv) stand rehabilitation using enrichment planting, limbing, or thinning; and, (v) forest conversion from coppice forest to high forest.

Sub-component 2.2 Multi-purpose Forestry Demonstration Techniques. This generally will involve integrated management for vulnerable forest, scrub and unutilized pasture within the forested areas classified as state forests or on private or local community forest and non-forest lands. These will be demonstration activities on a minimum area of 2 ha per sub-project; in addition to capital investments the sub-project support will also provide about 6 months of operational support. The intent is to undertake innovative activities that improve SFLM while also addressing objectives in some other sector (e.g., energy, water management, agriculture, tourism). Examples of candidate activities include: (i) non-timber forest product (NTFP) harvesting and value added; (ii) medicinal products; (iii) hunting and wildlife management complementing forest management; (iv) bio-mass management for energy production; (v) bio-mass thinning for local use and fire management; and, (vii) forest-based tourism.

1. Sub-component 2.3 Fire Management Technique Demonstration and Implementation. This sub-component is intended to engage local communities in implementing appropriate small-scale fire management interventions. While there are no restrictions on land ownership, areas targeted will be those under fire hazard. Preference will be given to activities involving an element of local engagement and participation. Examples of eligible activities include: (i) fuel buildup management (clearing of deadwood before fire season); (ii) training in controlled burns; (iii) creation of defensible space; (iv) innovative water management systems in high risk areas; (v) emergency preparedness drills; (vi) appropriate small-scale equipment; (vii) glass removal; and, (ix) waste management interventions (dump removal). Areas can be of any size with no minimum or maximum.

2. Sub-component 2.4 Local Extension Services. This sub-component will provide operational support to existing extension services to engage in direct facilitation of local participation in the above activities (innovative demonstration projects and fire management).

Component 3. Project Management

Based on past experience and recent discussions with the Entities, the Project will be implemented through the two Entity Ministries responsible for Forestry, namely their mainstreamed implementation units (i.e., FBiH PIU and RS-APCU).

DESCRIPTION OF WORKS AND ASSOCIATED ENVIRONMENTAL IMPACTS

The environmental impact of the project is expected to be largely positive and no major adverse environmental impacts are anticipated. The project supports investments in sustainable forest and land management, consistent with existing management plans and therefore legislation in place. The project is expected to increase the adoption of effective forest, land, and water management practices in the project sites and thus contribute to soil and water conservation, and building climate resilience. Majority of components envisaged under the actual Project involve planning and development of planning documentation for given actions, or include small-scale interventions in forested areas (afforestation, fire control, etc.) All of the works associated with the Project will be implemented fully in line with the legal provisions in force in the entities of Bosnia and Herzegovina, with the relevant World Bank Operational Policies, and with full respect of the forest management plans on each of the sites. The works that may have minor and easily mitigated environmental impacts will follow the guidelines set forth in this Environmental Management Framework, and the provisions of the specific Forest Management Plans. Activities such as afforestation, fire control measures and low-risk forest management activities may also have minor associated environmental impacts, which shall be incorporated in the Environmental Management Framework and the EMP here-in. This EMP can be applied at all project sites, and will include criteria and procedures to be applied at each individual site, in order to account for any unusual and site-specific conditions. Some general environmental impacts have been described further below. Having in mind that neither precise boundaries of possible extension of the existing protected areas nor the specific locations of individual activities are currently known, site or area specific impacts could not be described within the scope of this EMF. Therefore, a general approach was taken in the consideration of possible impacts. Wherever possible, guidelines for environmentally sound development of project financed infrastructure were provided within the separate sections on different categories of impacts. The intensity of individual impacts depends on both the magnitude and frequency of occurrence of their causes, as well as on the sensitivity and resilience of each subject of impacts. Aesthetic Impacts

Reconstructed, installed or constructed infrastructure, or interventions in natural settings, can by their visual characteristics affect the aesthetics of the landscape. This can be mitigated by careful selection of non-striking colors for the structures, as well as by planting locally available species of trees around the structures (natural fencing). Careful planning and site selection in the design phase is also recommended.

Impacts on soil

Although of minimal extent, the suggested project works especially with some excavation, can lead to erosion of soil or landslides. In order to prevent this, wherever possible, any construction of new structures should take place in sections that had already been altered. Wherever possible, the corrective soil leveling should be made by the soil already excavated during other works in the same area. In the event that clearing of land, removal of bushes, trees and other vegetation are necessary, the area’s original appearance should be restored upon completion of the works by re-planting of same types of vegetation, since this stabilizes the soil. If larger, locally concentrated interventions on soil are required, wherever possible, prior expert consideration of the geo-morphological characteristics of the soil should be made. Due to the use of vehicles, machines and equipment during the works of reconstruction or limited construction, as well as during the later regular use, maintenance and management of the forested areas, occasional spills and leaks of fuel, oils and other working fluids may occur. There also may be spills of paint,

varnish, bitumen or solvent during the works, but also due to improper storage or handling, which cause soil pollution. They can be prevented or minimized by storing all vehicles and machinery on nearest available paved parking lots and garages (concrete) with side channels for containment of accidentally leaked oils or fuels, as well as roofed warehouses for fuel, oils, paint, varnish, and other fluids, with a secondary containment of spills. Warehouses must be stable with regard to the maximum winds and earthquakes registered in the area. The use of stationary engines run on liquid mineral fuel, including power generators using liquid fuel, can also lead to fuel spills. Therefore, wherever possible, electric or solar energy should be used, or alternatively gaseous fuels. Inadequate disposal of waste, in particular hazardous waste by contractors during the reconstruction / construction phase, but also by a forested area's personnel, during regular work within the forested area, can cause significant negative impacts on the soil and water courses. It is therefore necessary to establish a waste management plan and strictly comply with it. This must include assignment of sites for the disposal of municipal and hazardous waste, and establishment of a system for waste collection and disposal on the nearest suitable waste disposal sites (sanitary landfills) or arrange hand over to operators authorized for hazardous waste disposal. It is also recommended for all removed vegetation and green wastes to be mulched. All open burning of vegetation or wastes is strictly prohibited. Considering that the personnel a protected area must have chainsaws for regular maintenance, it is necessary to pay attention to the lubricating oils applied. These types of oils are inevitably lost during chainsaw operation (through burning with the primary fuel in two-stroke engine of the chainsaw, as well as through leaks and dissipation into the environment) and therefore cause soil pollution. To mitigate this negative impact, biodegradable oils are recommended for such applications. This approach should also be taken when lubricating motor lawn mowers, where electric mowers are not available. Impacts on watercourses and hydrologic characteristics of the terrain

Ground pavement, construction or reconstruction of structures, access roads and trails, can change the regime of storm water flow in the given area (e.g. induced flow along roadsides, or accumulation of water in roadside pockets). Impacts of such changes should be carefully studied and, if necessary, corrective measures should be taken. Spills and leaks of fuel, oil, electric insulation (transformer) oils, paint, varnish, solvent or other fluids occurring during the use of vehicles, machines and equipment, but also during any works, as well as inadequate waste disposal, can lead to pollution of surface and groundwater. These impacts can be prevented or minimized as explained in the previous sections (Impacts on soil).

Impacts on air

Vehicles and machines used during works cause air emissions of dust and gaseous products fuel burning. Occurrence of excessive amounts of dust can be avoided by sprinkling water on the soil during the works. The negative impacts of exhaust gases from vehicles and machines can be mitigated by maximizing the use of machines running on electricity, and where this is not feasible, by using gaseous or liquid fuel of the best available quality (e.g. diesel fuel with minimum sulfur content). Impacts on nature, biodiversity, habitats

All necessary works in a forested area can lead to occasional vegetation damage, disruption of migration routes of animals, fragmentation of habitats, injuring or killing of animals by vehicles. Vegetation damage should be reduced to the extent possible, followed by re-planting of the original vegetation types upon the completion of works. Wherever possible, works related to the construction of new structures should be conducted in sections that had already been atrophied or altered previously. All works must be undertaken in accordance with the existing management plans for the given areas, in agreement with the Management of

each individual forested area. All the specifics (e.g. periods of the year in which flora and fauna are particularly sensitive, particularly sensitive locations, zones of different restrictions, migration routes of certain species, fish spawning locations, etc.) should thereby be taken into account. When constructing access roads, it is particularly important to consider the migration routes of animals and, where needed, place fences along the roads aimed at preventing the collision of vehicles with animals, as well as to construct underground passages or bridges for animals to cross from one to the other side of the road. The Management of the forested area should alert the contractors regarding the speed limits for vehicles driving through the area during the works, but also arrange placement of warning and speed limit traffic signs, and, where necessary, install speed ramps aimed at minimizing the possibility of damages to animals. Inadequate storage and use of fuel, lubricants, paints, varnishes, solvents and other harmful flammable liquids during reconstruction and construction works, but also during regular functioning and maintenance of the forested areas, can lead to fires with very harmful consequences for the biodiversity of the area. In order to prevent this, it is necessary to introduce adequate measures for management of these working fluids. Where storage premises are constructed for these materials, fire-extinguishers and equipment should be installed/made available in and around the warehouses, and a safety band with no trees or bushes should be formed around the structure. Noise generated by the works may cause disturbance of animals, and it should therefore be minimized and localized by use of sound barriers. Works should be performed during daylight hours. The impact of noise should also be considered with regards to regular traffic on roads passing through the forested area, or in its direct adjacency and, where needed in particularly sensitive sections, permanent sound barriers should be installed besides the roads. The Management of the forested area should consider that the improvement or construction of the access roads will primarily provide for a more efficient management of the forested areas and easier access, yet it also may facilitate unwanted occurrences, such as inadequate trafficking through the forested areas and illegal logging and hunting. Therefore, it is essential to establish an efficient system of monitoring and protection of the area, possibly combined with engagement of inspection teams. Pest and Disease Management

The Project, including the planning documents that will result from the Project, does not envisage any procurement or use of chemical pest management compounds. All of the forests will comply with FSC requirements, whether they have already been certified or if they are pending such certification. In line with the FSC certification guidelines, use of chemical pest management methods is forbidden, and is clearly outlined in all of the relevant Forest Management Plans. Furthermore, Bosnia and Herzegovina is signatory of the International Plant Protection Convention (IPPC) deposited with FAO, which is multilateral treaty for cooperation in plant protection. The purpose of IPPC is to secure common and effective action to prevent spread and introduction of pests of plants and plant products and to promote appropriate measures for their control.

Other Potential Environmental Impacts

The Project supported activities will in no shape or form finance involuntary resettlement and land acquisition. Furthermore, procurement, supply or increased use of pest management chemicals and compounds will also not be financed, while planning such use will be in line with FSC requirements. All critical habitats and sensitive ecological areas will be excluded from Project interventions, and identification of such areas is a pre-requisite to all planning and design documentation.

Environmental Management During Project Implementation This Environmental Management Framework (EMF) with a template Environmental Management Plan (EMP) is prepared prior to project Appraisal with disclosure in local language in country. The disclosure was carried out on-line, while hard copies were disclosed with the relevant institutions. Public consultations will be carried out in line with OP 4.01, with announcements made to all interested parties in the local papers, while individual invitations will be sent to key stakeholders. The list of the participants at public consultations, minutes of meeting and key points are included in this final EMF for disclosure. For each of the Project locations, a site-specific EMP will be prepared based on this template, and will be disclosed in the Project area, with public consultations organized prior to start of works. The Environmental Management Plan provided in this document will be reviewed for each of the proposed Project locations and adjusted based on the varying local conditions. Such an updated EMP will be disclosed in a public place prior to, and for the duration of start of works. The EMP will also be a part of the bidding and contractual documents, binding therefore the hired Contractor to implement all of the listed mitigation measures and for the hired Supervisor to ensure all of the measures have been implemented. Overall responsibility for the implementation of this EMP stays with the Project Implementation Units. Since most of the foreseen environmental impacts are linked to poor management or lack of management plans and coordination for activities, the first and foremost issue that would help enable proper environmental impact mitigation is establishment of proper management guidelines. Furthermore, Good Practices in Forestry and Afforestation will be drafted and included either in the Project Operational Manual, or as an Annex to each of the site-specific EMPs.

ANALYSIS OF LOCAL ENVIRONMENTAL AND PERMITTING REQUIREMENTS

Environmental Impact Assessment Regulations

The environmental permitting or Environmental Impact Assessment procedures are defined at the Entity level with respective Laws on Environmental Protection (2002 in RS with revised version from 2012 and 2003 in FBiH, with subsequent amendments). The overall responsibility of the environmental permitting lies with the Ministry of Physical Planning, Civil Works and Ecology in Republika Srpska and the Ministry of Environment and Tourism in Federation BiH. The activities for which an EIA and environmental permit is mandatory, or for which the need for a permit is at the discretion of the Ministries is defined through the supporting bylaws, under the framework Law on Environmental Protection. For activities for which the associated environmental impact is lower (according to prescribed threshold values) the environmental permits are issued at the municipal level in RS and the Cantonal level in FBiH. FBIH

According to the FBiH bylaw – Regulation on Activities which can be implemented or plants which can start operation if an environmental permit is obtained – activities on forest management mandate a Full EIA report and environmental permit for initial afforestation or clearing of areas larger than 30 hectares, with the intent to change the original land use category. A Partial EIA may be required for similar activities occupying areas larger than 15 hectares. There are no provisions related to small-scale forest interventions or forest road development, as these should be carefully managed through the forest management plan for each location.

RS

According to the RS bylaw – Regulation on Activities which can be implemented or plants which can start operation if an environmental permit is obtained – activities on forest management are managed in a similar manner to those in the FBiH legislation, with threshold values being 30 and 15 hectares respectively. Primary afforestation or clearing of forests with the intent to change the land use category (article 3 of Regulation – Official Gazzettte RS 124/12). In addition, the Ministry may seek an EIA to be conducted even if a project does not meet the threshold values but could have a substantial environmental impact as related to sensitive natural areas, specific protection regimes of a given area, or inter-entity and transboundary impacts.

Relevant Legislation in Federation BiH

As of 27 November 2009 the Law on Forests (Official Gazette of FBiH, No. 20/02) has been declared as lacking

provisions for local governance and was put out of force. As a temporary provision a Decree on Forests was

delivered to bridge the gap until a new Law on Forests is adopted. The new Law on Forests is available in a

preliminary draft form and is pending adoption. Almost all of the relevant bylaws will remain in force, and

these help define forest management issues in FBIH at present, and will continue to do so once the new Law is

also formally adopted.

The Decree on Forests (Official Gazette FBIH no. 83/09) defines what forests, including plantations are, and

what forested areas are. The Decree establishes the time-frame and content of the forest management plans,

including precise definitions and limitations on the volumes and types of forest to be cut. Furthermore, the

Decree defines that only authorized personnel can carry out works in forests, and limits use of biotic and non-

biotic agents in forest management. The sale of lumber and other non-wooden forest products is also defined,

as well as traffic management inside forested areas. The Decree defines management at the level of FBiH and

Cantons, while establishing monitoring procedures and fines for non-compliance. This Decree will remain in

force as a temporary solution until the new Law on Forests is adopted.

Rulebook on Elements used to Develop Forest Management Bases (Federal Minsitry of Agriculture, Water

Management and Forestry, 2003)

The most important bylaw for the development of planning documentation meant to define the work

methodology, structure and content of the Forest Management Basis (FMB). The Rulebook defines that FMBs

should as a minimum contain: (i) scope and type of afforestation and nursing activities for protection

purposes, (ii) investments in forest road development and (iii) measures for maintenance and improvement of

biodiversity and other ecological and social functions of the forest.

The Rulebook also defines that, within the scope of development of FMBs and Guidelines for implementing

FMBs the following need to be taken into account: (i) harmonization of FMBs with physical plans, water

management basis, and documentation which is kept at the Institute for the protection of cultural-historical

and natural heritage, as well as the Federal program for management of mineral materials, (ii) management of

protected forest areas and areas of special purposes, (iii) ban on cutting and collecting endemic and

endangered plant species, (iv) protection of the forest hydro-potential and protection of land during

construction works in forest, (v) ban on clear cutting on large areas of the forests, (vi) implementing plans of

nurturing and protection of forests while preferring original tree species in afforestation, all with the intent

and purpose to ensure adequate forest management and improvement of biodiversity and ecological and

social functions of the forests.

Law on Hunting (Official Gazette of FBiH, No. 4/06, with two Amendment Laws from 2010 and one in draft)

This Law regulates the organization of hunting and hunting ground, breeding, production, usage of wild

animals, cadastre of hunting grounds, hunting guard service, administrative and inspectoral supervision of

implementation of the Law, and other issues important for hunting on the FBiH territory.

Law on Seeds and Seedlings of Forest and Horticulture Varieties of Trees and Shrubs (Amended by Law in

Official Gazette of FBiH 8/10)

This law regulates registration and control over seeds and seedlings of forest and horticulture varieties, while

establishing control over import of reproductive materials in order to ensure high-quality forests and

horticulture varieties and higher economic production while safeguarding environmental, biological and

consumer protection. This law specifically lists the forest varieties and species.

Law on Nature Protection (Official Gazette of FBiH 33/03 with a new law in procedure as of 2013)

This law regulates the management, protection and sustainable development of protected areas including

landscapes, natural areas, plants, animals and their habitats, minerals and fossils and other nature

components in FBIH. This Law contains provisions on establishing protected areas and measures to ensure

protection of these areas.

Law on Protection of Cultural, Historical and Natural Heritage (Off. Gaz. of SRBiH, No. 20/85)

Based on this law, the Agency for Protection of Cultural, Historical and Natural Heritage of BiH has been

established, whose successor is the Agency of Protection of Monuments of FBiH. Upon the signing of the

Dayton Peace Accord in 1995, the cantons have established their own Agencies for Protection of Cultural,

Historical and Natural Heritage, whereas no such institution exists on the Federation level. These agencies are

consulted during permitting processes. Their judgments in this context are based on available data, as well as

direct insights on the spot. If a project is not expected to impact cultural or historical heritage and in the event

that sudden discoveries of valuable items, or natural values emerge later on (during project activities), the

investor is obliged to immediately notify the responsible agency and the municipal authorities in charge and

arrange temporary protective measures. The provisions of this law related to nature have been superseded

with the enactment of the Law on Nature Protection.

Other relevant cantonal legislation

Besides the described federal legislation, each particular Canton may have their own lower tier legislation as

related to protection of nature, environmental impact assessment and forest management which need to be

complied with.

Relevant Legislation in Republika Srpska Law on Forests (75/08, 60/13) This Law shall govern the policy and planning, administration and management of forests and forest land, forest protection, financing and value of forests, cadastre of forests and forest land including forest information system, property issues as well as all other issues pertinent to forests and forest land aiming at the improvement and sustainable use of forests and forest land and forestry development. This Law shall apply to all forests regardless of ownership. Law on Hunting (60/09, 50/13) This Law shall govern hunting resources, management of hunting sites, ownership of game, systematic classification and protection of game, hunting sites, hunting sector planning and cadastre of hunting sites, hunting and exploitation of game, prevention of damages caused by game and compensation for damages by and to game, hunting sector development funds and human resources. Law on Protection of Forest Reproductive Material (60/09) This Law shall govern the main features of basic and reproductive material of forest trees, conditions, manner of evaluation and recognition of basic material, production, control and handling reproductive material of forest trees as well as the quality, trade and use thereof, including the register of forest plant species and other registers. Law on Nature Protection (113/08) This Law shall govern rehabilitation, protection, conservation and sustainable development of landscapes, natural areas, plants, animals and their habitats, land, minerals, fossils and other components of nature that constitute part of the environment as well as the institutional framework for their protection. Law on Cultural Property (11/95,103/08) This Law shall govern the system of protection and use of cultural property and shall lay down the conditions for performing the activity of protection of such property. Cultural property shall mean objects and products of tangible or intangible culture of interest to the Republic of Srpska that are subject to special protection according to this Law. Law on Environmental Protection (71/12) This Law shall govern protection of the environment with the aim to ensure preservation thereof, mitigation of risks to human livelihoods and health as well as improvement of livelihoods, protection of all elements of the environment, raising awareness and access to information on the environment, environmental planning and protection, strategic and environmental impact assessment, procedure of issuing ecological permits and prevention of large-scale disasters, the system of eco-labelling and management of environmental protection, funds for the environment-related activities, responsibility for damages caused to the environment, as well as rights and obligations of natural and legal entities that perform the activities laid down by this Law. Other permitting procedures as related to forestry management It remains the responsibility of the Client (relevant PIUs) to ensure that all of the procedures and legal obligations in BiH, including both entities, relevant cantons or municipalities are met before start of activities.

PUBLIC DISCLOSURE

The Environmental Management Framework has been disclosed in public, with public consultations held in

both entities – in Sarajevo and Banja luka. The minutes of meeting from both consultations, with list of

attendees are included in the Annex 1 of this final version of the EMF.

The EMF together with an invitation to the public consultations has been publically disclosed at the website of

the Ministry of Agriculture, Forestry and Water Management of Republika Srpska on 24.10.2013 and at the

website of the Forestry PIU of the Ministry of Agriculture, Water Management and Forestry of FBiH

(http://portal.piusum.ba/Projekti/GEFProjekatodrživoupravljšumamaikrajolicima/tabid/80/language/en-

US/Default.aspx).

A public notification of the consultations meetings was carried out through the daily papers (Nezavisne novine

in RS and Dnevni Avaz in FBIH, both on 26.10.2013) while the targetted invitations have been sent to the

identified stakeholders from a number of institutions and subjects dealing with forestry and/or environmental

protection.

The public consultations were held on 30.10.2013 in the building of the Federal Ministry of Agriculture, Water

Management and Forestry in Sarajevo (Marka Marulića 2). Public consultations were also held on 31.10.2013.

in the Ministry in Banja luka, starting at 12 o' clock.

The public consultations in Banja luka were attended by representatives from the Ministry of Agriculture,

Forestry and Water Management of Republika Srpska, the Head Forestry Inspector, representatives of PUF

“Forests” RS, Forestry Faculty in Banja luka, and a representative of the NGO sector (Eko zona Šipovo). Written

comments were received from the colleagues from the Ministry of Physical Planning, Construction works and

Ecology. The consultations meeting in Sarajevo was attended by representatives of federal ministry, cantonal

ministries and forest management bodies, and Faculty of Forestry.

Based on the discussions at the consultations meeting, there are no substantial changes that need to be done

to the EMF. Most of the discussion was related to the significance of the project itself, and the need to

develop communication in the high-risk areas for the purpose of multiple functions of the forests (protection,

social function, rural development, nursery, tourism). The discussion placed an emphasis that this project can

be the beginning of a much wider forestry activity plan. According to the conclusions of the public

consultations in FBIH, good forestry practices need to be added to each of the site specific EMPs, and that the

Decree on Forests needs to be included in the legislative review.

The list of attendees and detailed minutes of meeting are attached in Annex 1.

ENVIRONMENTAL MANAGEMENT PLAN Design Phase

Issue Mitigation Measure Costs Institutional

Responsibility

Monitoring Parameters

Planning documentation needs

to be harmonized with the

environmental mitigation

measures

Planning documentation needs

to avoid works in sensitive

habitats, on private or otherwise

occupied land

Harmonization with measures proposed in

EMP (accessibility, development planning,

vegetation removal, construction practices,

environmentally friendly construction

materials, etc.)

Part as a project

activities, included in

operating cost

Project Implementation

Unit (PIU) with relevant

forest management

teams

Review of planning

documentation as per

environmental requirements

Improper site selection may

damage natural vegetation in

ecologically fragile areas, may

also cause water and soil erosion

if the slope is greater than 35o

Sites need to be distributed

properly to ensure smaller

cumulative environmental

impact

Harmonization with measures proposed in

EMP (accessibility, development planning,

vegetation removal, construction practices,

environmentally friendly construction

materials, etc.)

Observe sloping of sites and project locations

prior to start of planning activities.

Part as a project

activities, included in

operating cost

Project Implementation

Unit (PIU) with relevant

forest management

teams

Review of planning

documentation and selected

sites as per environmental

requirements

Improper selection of tree

species may cause decrease of

ecological adaptability and

stability of forest plantations

Large scale of pure forest may

also increase chances of disease

and related impacts

Good native tree species should be selected as

the main afforestation species in the project.

The size of single plantations should be strictly

controlled, including introduction of varieties.

Part as a project

activities, included in

operating cost

Project Implementation

Unit (PIU) with relevant

forest management

teams

Careful selection and review

of selected tree species.

All selections and purchases

need to be evidenced.

Construction Phase

Issue Mitigation Measure Costs Institutional

Responsibility

Monitoring Parameters

Construction activities may affect overall traffic safety and endanger safety of wild animals

Clearly display informative and warning signs around construction area and limit access.

Limit works to daytime intervals. Allocate alternative traffic routes, introduce speed limit.

1000 Euro for signage Project

Implementation

Unit (PIU) with

relevant forest

management teams

Signs in place

Compliance with working

hours

Improper site preparation may affect soil erosion, water drainage and soil loss. Unnecessary clearing of vegetation may occur

Vegetation removal should be limited to the basic minimum necessary to implement project activities. The site selection process should also take into consideration the type of vegetation to be removed.

Careful control of excavated materials, stockpiling on the uphill side of the trench.

No open burning of removed vegetation should occur on site, rather wastes should be mulched.

Planned for in works Project

Implementation

Unit (PIU) with

relevant forest

management teams

Visual inspection of

parameters.

Included in the log from

the working sites.

Forest path or road construction may cause partial excavation, compaction and clearing of vegetation

Minimize vegetation clearing. No open burning of vegetation or other wastes.

During excavation minimize chances for landslides and avoid storage of material on sites that may aesthetically or hydrologically disturb the area.

Planned for in works Project

Implementation

Unit (PIU) with

relevant forest

management teams

Visual inspection of

parameters.

Included in the log from

the working sites.

Worker camp or machinery and equipment storage may impact the soil, groundwater and sensitive forest ecosystems

Ensure setting up of worker camp or facilities have minimal impact on the surroundings.

Ensure no machinery is stored in areas where leakage can pollute the soil or groundwater.

Planned for in works

Storage of vehicles may

incur additional costs

based on locations

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Visual inspection of

parameters.

Included in the log from

the working sites.

Construction Phase

Issue Mitigation Measure Costs Institutional

Responsibility

Monitoring Parameters

Waste management All waste streams will be separated, reused or recycled when possible.

No open burning of wastes or vegetation on site. All green wastes should be mulched.

All wastes generated during construction activities, including hazardous wastes, need to be disposed of at approved landfills or handed over to authorized agencies for management of special wastes.

Disposal at landfill site

(including assessment of

transport to nearest

sanitary landfill): 100-200

Euro per ton

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Log kept of all wastes

handed over for

management

Visual inspection of open

burning and traces of it

on site

Chance finds If encountering archaeological findings during rehabilitation works, contractor should stop operations and notify competent authorities

Also applies to unexploded ordinance and other significant chance finds in area.

May incur costs through

works delay

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Log of working sites.

Maintenance of all

written correspondence.

Photos of chance finds.

Noise Working hours limited to daily shifts

Ensure minimal disruption

Use of attested machinery

No idling of machinery or transport vehicles on site Use noise barriers or noise suppressors on equipment if necessary.

Cost of noise barriers:

200-300 Euro

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Log of working sites.

Inspection on site.

Dust Watering or coverage of dusty materials; adjusting the speed of vehicles in transport

Cover all material or waste loads during transport

When possible use protective cloth or other covers in areas where works are ongoing and dust is being generated.

Cost of 1 m3 of water:

max 50 Eur

Cloth covers: 200-300 Eur

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Log of working sites.

Inspection on site.

Construction Phase

Issue Mitigation Measure Costs Institutional

Responsibility

Monitoring Parameters

New infrastructure can affect the aesthetic appearance and landscapes, as well as migration routes of animals

Use non-striking colors, place natural fences around buildings or structures. Install tunnels or bridges for undisturbed transfer of animals.

Additional costs for the

tunnels or bridges for

animals should be

included in the design

phase.

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Log of working sites.

Visual inspection on site.

Site organization and restoration

Plans to minimize disturbances to the neighborhood made (including plans to avoid traffic jams based on heavy duty equipment and/or transport of materials)

Fencing off the construction site and/or safety signs and warnings clearly posted as applicable

The site will be cleaned from all debris and waste materials and restored to the state planned in the designed upon completion of works; all machinery will be removed

N/A

Project

Implementation

Unit (PIU) with

relevant forest

management teams

Log of working sites.

Visual inspection on site.

Operation Phase

Issue Mitigation Measure Costs Institutional

Responsibility

Monitoring Parameters

Increased number of visitors/workers or activity in a given area can upset wildlife, lead to damage of biodiversity, and scattering of wastes

Efficient Forest Management Plan in place.

Establish control mechanisms in the forest management plan or separately

Control access to the forests

Inspections

relevant forest

management teams

relevant forest

management teams

Use of vehicles or machinery, equipment and materials during operation and maintenance of infrastructure or forestry activities can cause air, soil, and watercourse pollution and upset or damage flora and fauna

Efficient Forest Management Plan in place.

Ensure use of well-maintained vehicles. Restrict use and activities within the forested areas.

relevant forest

management teams

relevant forest

management teams

Opening area for illegal activities including waste disposal, lumber cutting or poaching

Efficient Forest Management Plan in place.

Establish control mechanisms in the forest management plan or separately

Control access to the forests

Inspections

relevant forest

management teams

relevant forest

management teams

ANNEX 1 : MINUTES OF MEETING FROM PUBLIC CONSULTATIONS AND LIST OF ATTENDEES

Minutes of Meeting from the Consultations held in Banja Luka

List of participants:

1. Mr Marković Boris, forestry engineer, MAFWM RS, Head of Department 2. Milan Kecman, forestry engineer, MAFWM RS, senior expert 3. Prof. dr Zoran Stanivuković, forestry engineer, Forestry Faculty, Vice-dean for lecturing 4. Goran Ljubojević, forestry engineer, Head Forestry Inspector of RS 5. Srđan Kašić, forestry engineer, Manager of the Resarch and Development Center – PUF “Forests” RS 6. Nenad Bužanin, Eko zona Šipovo, president of organization

After introductory statements related to the project, as presented by the Ministry officials, the public

consultations were declared as open.

Srđan Kašić, as a representative of the Public Utility for Forestry – Šume RS has expressed his gratitude for this

project initiative, as well as the defined components of the project. He stated that PUF Forestry RS have FSC

Certificate which binds them to ensure environmentally friendly practices and behavior in all phases of work.

He also discussed the issues of obtaining environmental permits at the local instances.

Goran Ljubojević stated that the environmental impacts can be both positive and negative, and that the

project components itself have a clear positive impact on the environmental aspects. He also stressed that the

real needs of the forestry sector are substantially greater than those defined in the project itself and that each

of the activities of this type needs to be welcomed, and that the ministry needs to define the strategic

priorities for financing.

Zoran Stanivuković, as head of the department for forest protection at the Faculty of Forestry explained that

the scope of the project is such, that every item demands a separate public discussion. He noted the issue of

openness, as well as the need to address forest protection notably with respect to forest fires, as well as the

aspect of rural development, and use of forests for multiple purposes, that have not been conducted as of

yet. He stressed the need of raising public awareness and education of the population of all ages in order to

preventively act on forest fires, as well as the urgent need of the IDP agency to become operational. He also

noted that the FSC standard defines the ban on using harmful chemicals in forest management of RS. With

regards to afforestation he noted the need to carefully select the species and to plan to fire-fighting access.

During the discussion the example of the catastrophic forest fire in Jablanica was discussed.

The public discussion was closed with a remark that the document is acceptable with its scope and content.

Minutes of Meeting of the Public Consultations held in Sarajevo

Sustainable Forest and Landscape Management Project

Public Debate on the Draft Environment Management Plan

Sarajevo, October 30, 2013

Location: Federal Ministry of Agriculture, Water Management and Forestry Marka Marulića 2, Sarajevo Beginning at: 11 o’ clock.

Agenda:

1. Information on activities on Project preparation 2. Information of the current status of evaluation of Project proposals 3. Presentation of the “Draft Environmental Management Plan” 4. Discussion of the document under No. 3

Attendees: List attached

1. Introductory and welcoming remarks Omer Pašalić (Director of the Federal Forestry Administration):

2. Alojz Dunđer (PIU Director): Represented activities performed thus far and the plan for forthcoming

activities

- The Project Appraisal Mission shall visit BiH in the period from November 4 to November 8, 2013. It shall be necessary to finalize the Environmental Management Plan by then.

- Negotiations for the Sustainable Forest and Landscape Management Project shall be organized in the period from November 26 to November 27, 2013, and they shall be attended by the

representatives of the following, inter alia: entity ministries - FMAWMF, RSMAFWM, FMF, MFRS,

BiHMFT, and the World Bank.

- The World Bank Board shall be in session on January 14, 2014, and then the decision of approving the Sustainable Forest and Landscape Management Project shall be made.

- After the Project is approved by the World Bank Board, the ratification process shall follow, and in BiH that process lasts for 8-12 months, in average. That process involves entity and state level

parliaments (both houses), the Council of Ministers of BiH, presidents of the entities and members

of the BiH Presidency.

- The period of ratification may be used for continuing the activities on Project preparation (development of detailed projects, terms of reference, and preparation of tender documentation).

- Omer Pašalić and Danica Cigelj (Assistant Minister for the Forestry and Hunting Sector) informed the attendees on the operations of the commission for evaluation of preliminary project

applications. The selection criteria were defined on the basis of the GEF guidelines (Chapter No. 5

of the GEF) and instructions prepared by the FMAWMF.

- Information on the Project had been sent to the Federal Ministry of Finance, and they should forward the information to the FBIH Government for its consideration.

- Investments into fire protection infrastructure should be harmonized with the provisions of the Forestry Management Bases and annual management plans. The Forestry Management Bases and

annual management plans shall have to envisage investments in fire protection infrastructure;

equally so, mechanisms shall have to be ensured for the utilization of that infrastructure for its

earmarked purposes (and not for the purposes of exploiting forests).

3. Alojz Dunđer presented the key provisions of the “Environmental Management Plan”

4. Omer Pašalić opened the public debate and invited the attendees to take the floor. Danica Cigelj moderated the public debate.

Alojz Dunđer emphasized the lack of certain rulebooks relating to the Law on Forests, which define the

activities in forestry that are of relevance for this Project (for example, the Rulebook on Forest Order, etc).

Sead Vojniković, PhD, professor at the Forestry School of the University of Sarajevo, pointed out, inter alia,

that neither had the Law on Water been analyzed, nor the latest "Law on Nature Protection" dating from

2013. He also observed that there was a certain terminological confusion. (For example, whether "a new

species" concerned a "new species" in taxonomic terms or whether the term referred to native species). For

the purposes of the project, it would be good to retain the width of the meaning, in order to allow

beneficiaries to include more activities.

Omer Pašalić pointed out that the Environmental Impact Plan needed to be improved with recognized / good

practices in forestry, applied during afforestation, conversion of forests, environmental protection, heritage

protection, etc. It is necessary to focus on the subject of activities, to define the reduction of environmental

impacts, which are the native species, protection of the water – in which way, etc. and the protection of air? ...

The environmental impact plan should define our usual practices, and exclude the aforementioned activities

that do not occur here (i.e. the issue of the production of dust is not that present).

Mladinko Perković, a representative of the Forestry Company of Central Bosnia Canton, Donji Vakuf, pointed

out that in all the activities in the forest there was an impact on the environment, to a lesser or greater extent,

for example, the disturbance of the game, and therefore the activities needed to be adapted to the highest

possible extent. One of the proposals was to mark the works visually, which should be easy to notice for

humans, but would not be noticeable at all for the game.

Refik Hodžić, a representative of the Forestry Company of Tuzla Canton, asked whether the document had

been sent to other institutions that might have an impact on the environment, particularly local communities,

and institutions of local communities. He stressed that all the restrictions listed in the presentation were also

regulated in the process of certification, for example the issue of ownership, demarcation between private

and public property, laws and regulations that govern the management of forests and are taken into account

in the preparation of the Forestry Management Bases. According to FSC certification (as well as any other), the

certified area in provisions of the Forestry Management Bases must define the environmental impact of all the

planned activities. He stressed that it made sense to regulate the FMIS at the entity level, rather than at the

cantonal level.

Danica Cigelj replied that the invitation had been sent to the representatives of all institutions and

organizations (including NGOs) for which it had been estimated that they could have had an interest in the

activities of the GEF project, as well as that the information on this document was, inter alia, published in daily

newspapers last Saturday (Daily avaz).

Alojz Dunđer pointed out in that the description of the project components included one very important

sentence, "for each project area, each project shall have to, inter alia, develop the environmental management

plan." If that would be insisted on, it would dramatically increase the workload for the beneficiaries. One of

the more cost-effective solutions would be that all the redundant mitigation measures were excluded from

this plan; and that they would then be supplemented for the project activities with more relevant additional

mitigation measures, including the measures defined in the FSC certificate.

Ševal Konjalić, a representative of the Forestry Company of Central Bosnia Canton, Donji Vakuf, also confirmed

that all the activities in the forest had an impact on the environment. The Environmental Impact Plan needed

to address the impact, the method of mitigation, and to establish the guidelines through the project

management plan. We are under obligation to do that pursuant to other relevant regulations. The Forestry

Company of Central Bosnia Canton currently neither has the certificate nor the capacity for the development

of those documents, but those activities shall have to be performed regardless of whether they are related to

a certain project or not. He added that the public required that any project was announced and that its impact

on the environment was explained. He addressed the legislation which should be taken into account, the

provisions of the forest management bases, the FSC or any other certificate, and the provisions of detailed

project designs. He also stressed that in all the forestry companies, the process of planning and project design

had be raised to a higher level, to stop and overcome the long-standing routine / formulaic approach to

planning.

Refik Hodžić asked what the final deadline was for submitting comments with the objective of improving the

Environmental Impact Plan (the environment protection plan, concerning the constraints under the GEF

Sustainable Forest and Landscape Management Project), and the answer was given that potential additional

objectives / suggestions could be submitted, in writing, by Monday, November 4, 2013, by 4 in the afternoon.

Bajro Makić, the general manager of the Forestry Company of Central Bosnia Canton, Donji Vakuf, stressed

that one should also address auxiliary forest products, in which, in addition to herbs and medicinal plants, he

would also include mushrooms and other non-timber forest products (NTP).

Danica Cigelj noted that it would be possible but that no preliminary applications for a project relating to NTP

had been delivered from any of the forest management companies.

Sead Vojniković: The sub-component A2 should include game and the NTP, mushrooms, herbs, in short it

should analyze international standards for sutainable management, use and protection (ISSC-MAP). It would

also be necessary to consult with the provisions of the Bern Convention. In general, that could be planned

separately, in case of certain extreme activities (for example, total cutting), but, in principle, a single common

impact plan could be developed.

Alojz Dunđer stressed that we should be precise in defining the measures relating to the establishment of the

forest order, i.e. the waste that will arise as a consequence of project activities. It shall be necessary to

elaborate in detail the process of project implementation. All that shall be subject to activities of audits and

controls.

The attendees discussed the term of biomass and whether it referred to the legislation or to the

recommendations in existing publications that deal with that topic. It was emphasized that the contractual

obligations that any of the companies had or could have had in terms of delivery should also be taken into

account.

Nevzeta Elezović, the director of the Cantonal Forestry Administration of Zenica-Doboj Canton, recommended

that it would be advisable to refer to the Rulebook on Forest Order.

Omer Pašalić said that there could be minor potential changes to these regulations in accordance with the

certification.

Refik Hodžić concluded that the documents, which currently did not have the status of legislation, could be

regarded as "good practice".

Danica Cigelj concluded that by Monday (November 4, 2013.) at 4 in the afternoon, all potential additional

comments and suggestions could / should be submitted, and that they would be incorporated in the

Environmental Impact Plan.

6. Summary: Alojz Dunđer

- Review all laws and bylaws that process the issue of environmental impact relating to project

activities in their contents

- When it comes to proposed mitigation measures, actions that are not relevant for forestry and this

GEF project should be eliminated from the Environmental Impact Plan

- Add the principles of good practice based on the experience of forestry management in BiH, as well

as the literature pertaining to this topic

- Recognize the comments and integrate them in the revised document.

Refik Hožić, a representative of the Forestry Company of Tuzla Canton and a member of the Commission for

Evaluation of Preliminary Project Applications, stressed that it was necessary to develop detailed project terms

of reference, i.e. high-quality project proposals. The preliminary applications included some good ideas, which

were, at the same time, very briefly described.

Danica Cigelj pointed out that the instructions on the structure and content of the projects would be delivered

to all interested parties.

Omer Pašalić thanked all participants in the discussion and expressed his hope that we would use the time

available to develop project terms of reference and that we would acquire approved projects.

The public debate ended at 1 in the afternoon.