The European Bank for Reconstruction and Development (EBRD) holds six one-day public consultations in Europe, Central Asia, Russia, and Caucasus. The discussion topics are the Environmental and Social Policy as well as the Public Information Policy.

Representatives of non-governmental organizations, partners of the Bank, and all stakeholders have been invited by the Bank to work out commentaries on the strategic documents: the Environmental and Social Policy and the Public Information Policy.

In Russia, the EBRD public consultations were organized by Russian Regional Environmental Center and were held on March 28, 2008 in Moscow.

SHANECO specialists had examined the EBRD project materials published for discussions (the Summary Feedback had been submitted to Russian Regional Environmental Center).

SHANECO Group considers participation of the international credit institutions in regulation and follow-up actions on environmental requirements in Russia to be of an utmost importance.  The developing practice of applying the policies and requirements of international credit institutions in Russia is an effective mechanism of providing environmentally sound operations. The declared and implemented policies and requirements of the EBRD and the IFC promote fulfillment of the national legislation and provide for the basis of its future development. The  discussion of the EBRD Environmental Policy draft documents is seen by us as an important event helping to spread general environmental knowledge; this allowed Russian specialists to understand the internationally accepted regulations.

Photo by: ebrd.com

SHANECO Summary Feedback

Opinions of the SHANECO Group specialists on project materials for the EBRD Environmental and Social Policy:

Dmitry Shanaurin, Director General, SHANECO Group CJSC:

1. The policy will work if its recipients and requirements to its performance are clearly defined. If the initiators of the investment process are guided solely by the Russian environmental regulatory framework, successful application of the Policy in Russia would be complicated, because:

• Russia does not have a corresponding nation-wide document with similar requirements;
• change is necessary in Russian procedures of the investment project decision making;
• requirements for projects from the supervisory bodies and the Policy performance requirements differ initially;
• project lending procedures implemented within the Russian banking system do not correspond to the Policy;
• the Policy contains requirements not defined or vaguely defined in the Russian legislation (resettlement, protection of indigenous peoples' rights, lending policy, affected population rights);
• the Policy is at variance with the Russian practice: one expertise—the EBRD Board of Directors—vs. the team of experts scattered in different agencies who are characterized by narrow departmental approach. Sustainability principle cannot work without an agency advocating the integral approach to investment project assessment and considering the diverse requirements of authorized bodies;
• the Policy does not provide the design organizations with guidance documents whose application is mandatory in the Russian Federation.

Environmental and social impact assessment is a business that grows rapidly in Russia but unfortunately, does not follow "the book" or law based scenarios, instead, it develops empirically.

Concerning the compliance of the EBRD proposals with the principles and requirements of Russian national policy, it has to be noted that the principles and requirements submitted for discussion do not fully comply with the Russian ones, therefore, their use is determined solely by the level of environmental consciousness of the designer and the investor. The application is also complicated because such time and financial expenses are not laid down by Russian legislation; there are no economic incentives or legal pressure to impel the Investor to finance these expenses.

2. In general, my educated opinion as that of an environmental engineer is positive, even though the document in question has some uncertainties caused by subjectivity of external experts (the requirements to contents of the environmental and social impact assessment are not detailed).

The New Policy, in some of its points, proposes provision of requirements, not their compliance or consideration with due sequence and interconnection. E.g. the documents have no references to particular requirements for composition of the project documentation which meets the accepted policy (western designers are aware about these requirements, Russian designers are not).

3. As far as the mechanisms of the Policy and requirements application are concerned—the corresponding documents are not available in Russia, therefore, no application mechanisms are available either. Besides, such document must be approved by the appropriate federal authorities.  So the EBRD's efforts must first of all be aimed at acceptance of international or interbank agreements for shaping environmental policies of the Russian banking community.

Alexey Emmanuilov, senior specialist in ambient air protection:

1. Structure of the Policy and Performance Requirements of the projects financed by the EBRD is close to the corresponding ones of the IFC which is positive for us practitioners. However, in order to implement this Policy and Performance Requirements, it is appropriate to develop (similar to IFC) the Recommendations on Application of PRs and the Environmental, Health, and Safety Guidelines (EHS Guidelines). It is also appropriate to use a unified terminology, in addition to similarity of the EBRD and IFC documents structure. Or at least to have the accepted documents include Terms and Definitions sections to avoid misunderstanding.

2. One of the characteristics of the Russian production sphere is that investors pay for the environmental impact mitigation with strong reluctance. Thus it would be beneficial to provide for an economic mechanism making greener production more financially attractive. E.g. benefits, installments, etc. for the expenses provided by the ESAP.

3. As part of a more justified application of this Policy and requirements, certain technical documents are necessary that translate declarative principles into measurable criteria, i.e. the ones that can be assessed quantitatively. Besides, a document is highly necessary to regulate composition, contents, and requirements for the ESIA materials.

In any case it is necessary to possibly reduce subjectivity of the decisions taken by the EBRD (on classification of objects, project borders, determination of applicable requirements and admissibility of impacts, etc.)

4. In the matters of ambient air protection, the declared principles generally meet the requirements of Russian legislation. However, the problem here lies in the fact that the ambient air protection legislation in Russia is observed on a pro forma basis or minimally. Preemptive policy is not used at all; the best technologies, according to investors, are the ones that produce higher profits. Development of technical standards and regulations is at an embryonic stage. Perhaps the EBRD, IFC, and Equator requirements will assist in compliance with environmental standards and rules for economic activities, and in some instances assist more effectively than  the bureaucratized Russian regulatory bodies.

5. On editorial corrections: Probably, a better definition should be coined for "an already degraded area" (p. 27). Also, a term should be found to replace the vague "non chemical substances" (p. 28).

Inna Ovchinnikova, lead specialist:

The proposed documents on the Environmental Policy are a well-developed material; however, to apply it in a particular country, further development is necessary with account of national, political, legal, social, and environmental particularities.

As part of discussion of the Environmental Policy Discussion Paper, it is important that the following issues be further elaborated:

• with regard to the national specifics, a differentiation needs to be made in the list of environmental project requirements between the state sector and the private capital, with more stringent requirements for the latter;
• under part III, p. 3 Project Boundaries, in the first paragraph, a statement should be made that the whole company and not only the Project performed by it, and the project part that is financed by the EBRD, must comply with the requirements of the Environmental Policy;
• under part III, p. 3 Project Boundaries, in the second paragraph, consumers should be added;
• under part III, p. 4 Project Classification, in the second paragraph, the classification should become even more elaborated, with account of the new or reconstructed facility, which is of primary importance for the social sphere;
• under part III, p. 5 Project Requirements, under d) subpoint Cultural Heritage, detailed guidelines should be worked out to define the cultural heritage and state the necessity of guidance from the coordinating authorized bodies. With regard to the national specifics, the necessity of developing the appropriate standard acts needs to be stated if such acts are absent.
• under part III, p. 5 Project Requirements, under d) Indigenous Peoples, the third paragraph should have a point on verification of compliance with the requirement of fair and equitable sharing;
• under part III, p. 6, in the social sphere, not only health and occupation issues matter for the population, but also changes in real estate prices due to implementation of A and B category projects;
• under part III, p. 8, Monitoring and Reporting, paragraph 2 needs to be included in the B category projects as well.

For greater clarity, the Policy needs to be elaborated in the following aspects:

• weak standing of NGOs in Russia has to be taken into account; their strengthening must be assisted by their involvement in public consultations of projects;
• the question of the third parties' role in meeting the project requirements has to be thoroughly elaborated;
• on p. 28, specific provisions should be made clarifying the difference between the cases of impact abatement and mitigation and the cases of compensations;
• concerning p. 38, under Evaluation section, the prerogative of task controls on each project at the point of funds allocation should have documentary confirmation of fulfillment of these tasks; 
• concerning p. 42: overwhelmingly, the population is not aware of the EBRD project financing and therefore will not address the Independent Recourse Mechanism.
• the contents of p. 46 must become one of the primary tasks.

Besides, under the section dedicated to public discussions of projects, the question of public groups should become more specific—whether these are representatives of NGOs, initiative groups from among the local population, or local municipalities.  In general, the term "the public" must be explained in more detail.

Because environmental issues are not among the national priorities of the Russian Federation, the declared expansion of the EBRD activities of project financing should have an appropriate section on promotion of environmental consciousness of the society and, accordingly, business entities, by drawing their attention to environmental issues in the country.

Svetlana Krestnikova, lead specialist in urban planning:

Some questions and comments probably come up because of translation problems. In my opinion, the Russian version of the documents needs more editing.

Optional title of the Policy submitted for discussion—Environmental and Social Policy of the EBRD, as the unique term reflecting the EBRD goals and objectives in the fullest extent. The proposed change of the Policy name needs explanation of the definitions used: "protection of nature", "environmental protection", and "ecology" ("environmental damage" under EBRD Performance Requirement 5, p. 4, literally "damage to ecology" in the Russian translation).

For appropriate use of the principles and requirements set out in the EBRD Policy, their differentiation by design stages is necessary. In this connection, differentiation of the EBRD requirements for projects against design stages should be made.

Difference of approaches within the environmental and social assessment may complicate adaptation of the international requirements in Russia.  The international principles emphasize initial prevention of possible impacts and preemptive multi-component forecast of the possibility of negative consequences. The environmental policy in the Russian Federation has a distinct pro forma attitude. in Russia, traditionally, the main emphasis of environmental measures lies in reducing the adverse impacts, not their prevention; that is why so little attention is paid to adoption of state-of-the-art technologies.

Yuri Chernov, lead specialist in ambient air protection:

The environmental policy development lines set forth in the Discussion Paper are mostly of declarative nature. Apparently, it is important that within the scope of the declared EBRD operations expansion into Eastern Europe and former USSR republics, the need to take into account national particularities and specificity of environment protection legislation in these countries was not properly addressed.

The attempt made to develop the current EBRD environmental policy along multiple dimensions is rather successful; on the other hand, it should be noted that it has a number of significant drawbacks, considerably affecting its implementation, such as:

• Mechanisms and principles of economic regulation related to environment protection, e.g. environmental insurance issues, have not been properly highlighted;
• references to EU standards and regulatory documents have not been provided in full;
• project category classification has no distinct criteria established;
• no clear requirements for conducting public hearings by project phases;
• loose definitions do not allow explicit identification of the need to conduct public consultations for B and C category projects;
• the requirements that relate to project scope are not clearly defined—not the general requirements, rather the individual approach that enables environmental and social impact assessment for a separate part of the project;
• the "individual" approach to clients who request financing on advanced project stages (after the project roll-out) in case the project complies with the environmental and social policy (Derogations and Exemptions section) seems subjective and insufficiently determined.

Russia has its own long-established methodological base and procedure for assessment (expert appraisal) of projects, which differs from its European analog significantly. In this regard, it is necessary to conduct studies in order to enable unification of hygienic, environmental, and technological criteria, monitoring principles, as well as methodological approaches to population health risk assessment, etc.

The EBRD Policy application in the Russian Federation is possible provided staged harmonization of Russian environmental legislation and international norms and regulations. Potential need to align administrative, financial, and juridical regulatory measures should not be excluded either.

Andrey Kalinin, lead specialist in surface and ground water protection:

At large, the discussion topics structure and content correspond to the declared goals on the EBRD environmental policy revision, however, some environmental aspects are not considered. For example, it appears that environmental pollution prevention requirements pertaining to such important aspect as effluents discharge were not sufficiently elaborated, as compared to the atmospheric air exposure regulations.

Environmental impact assessment procedure during development of pre-project drafts and project documentation pertaining to assessment of environmental impacts on water resources can only be employed provided due accounting of current national water quality standards and techniques enabling detection of water quality deterioration from pollutant discharge. EBRD policy fails to tackle both existing fundamental disaccord and the option for concurrent compliance with Russian and EBRD requirements, in some occasions.

Also, I would advise to restate p. 11 PR3 Pollution Prevention and Abatement as follows: "Client shall preclude emission / discharge of pollutants…", remainder of text unchanged.

Moreover, the EBRD proposals do not require separation of the dedicated environment protection authorities into a special category, as one of the concerned parties, structured and proper interaction with which would be an important factor for successful project implementation in Russia.

Stepan Kovalsky, lead geobotanist:

The Discussion Paper is structured quite logically, however, some topics, such as biodiversity, have not been elaborated sufficiently to enable their discussion, since they just touch upon the issue, pronouncing potentially stricter approach to the financed projects regarding the biodiversity conservation commitments. Although biodiversity protection issues have been regarded by the Policy, however, with view of significance of these issues, it is advisable to elaborate the methodological basis with greater detail, and to refine the items pertaining to critical habitats and environmentally protected/sensitive territories.

Overall, the EBRD Policy requirements for biodiversity preservation do not contradict the current Russian legislation and can be applicable. On the other hand, the degree of elaboration of these issues in the national legislation is much lower, which might cause conflicts with the client in certain situations. For example, the suggested project life cycle stage system does not match the practice adopted in Russia.

The positive aspect of the Policy, generally speaking, is its intent to encourage clients to use progressive European regulatory and legal framework on biodiversity preservation (2001/42/EC; 2004/35/EC; 92/43/EEC, etc.) and guidance documents (e.g., Biodiversity in Impact Assessment, IAIA publication).

On the other hand, with a view to changes in nature of the EBRD's activities set out in the Discussion Paper – tendency to devote increased attention to projects in the East and in the South – it is reasonable to develop guidelines in their own status based on European documents for non-EU countries. That would help understand the work scope and methodology for the clients located beyond the EU constitutional area. It is important for all the PR aspects.

As to biodiversity preservation, it is appropriate to prepare, for the further improvement of PR6, the draft documents entitled Biodiversity Impact Assessment Principles and Methodology, and Biodiversity Protection as Part of Environmental and Social Action Plan.

Public presentation of the ESAP Summary (instead of the ESAP itself) does not appear sufficiently comprehensive. Given the significant number of В-category facilities, such downward bias of requirements seems unjust and not fully complying with Aarhus Convention On Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters.

Given the difference in legal regulations of the EBRD documentation and national legislations, it would be expedient for non-EU clients to outline the interference proceedings. Optionally, it is suggested to establish the stricter regulation predominance principle.

To resolve the issue on admissibility of recession from the Policy during project implementation (p. 12 of the Discussion Paper) it appears appropriate to work out a set of strict and unbreakable clauses, upon violation of which no project financing should be granted (besides the Environmental Exclusion List).

The suggested Policy may only be adopted for application in Russia upon its thorough analysis and public discussion of its compliance with the national legislation, and followed by release of relevant recommendations and guidelines.

Alexandra Panyutina, lead zoologist:

The biodiversity concept mentioned in Environmental Policy section of the EBRD Policy Discussion Paper mingles natural and artificial biodiversity. These two notions should be clearly segregated and defined explicitly. Action plans and measures to protect natural biodiversity and to maintain biodiversity of e.g. cultivated plants have virtually nothing in common.

The paragraph Protected and Designated Areas needs deeper elaboration. This is a highly important paragraph, and it is advisable to identify those types of the protected area impacts that are considered impermissible.

Under the Critical Habitat section there should be a precise definition provided as to which evolutionary processes should be considered the crucial ones.

Paragraph 14 of Natural Habitats section of PR6 should clarify the circumstances of possible impacts causing degradation of natural habitats.

Explanation is needed on what is implied by "unavailability of technologically and economically feasible options" criterion—should all of the criteria contained in this Section be implemented, or just one of them should be deemed sufficient?

Would the project associated with natural habitats degradation be considered in case of e.g. unavailability of technologically and economically feasible options, but when there is no vital necessity to implement the project?

It is desirable that a clause be incorporated into the document on preservation of unique communities of species being far more valuable than preservation of the species area. This has not been elaborated separately although it has particular importance.

In general, the EBRD Policy Discussion Paper elaborates biodiversity preservation requirements with greater detail, in comparison with Russian national environmental requirements, thus facilitating the activities to be conducted within the scope of research in this field.

Victor Vlasov, senior project engineer:

The document proposed for discussion is actually about introduction of additional policy guidelines rather than about policy revision. We would propose the title On Further Elaboration and Changes in the EBRD Environmental Policy instead of Environmental Policy.

The document does not properly address requirements for using environmentally clean manufacturing processes, technologies and equipment (stricter environmental requirements for technology and equipment), and stricter national and international environmental requirements for projects under development, as well as new developing technologies and equipment.

The current EBRD policy and project requirements are based on national and international requirements, e.g. they incorporate requirements to conduct OVOS (Russian EIA) procedures and community health risks assessment, etc., and are mostly aligned with the requirements of Russian environmental legislation.

Some editorial changes are suggested, as follows:

• Page 4, paragraph 3 from the bottom should be revised as follows: "Ensure that the EBRD environmental and social requirements are updated to match the EBRD's mandate and reflect the modern state-of-the-art practice."
• Page 5, Section III p.1 (second line from the top): "Policy Scope Expansion."
• Page 6, 3rd line from the top should read as follows: "Such changes shall be discussed and approved by the Board of Directors."
• Page 15—the question has been raised on how should be participatory approach (literally in the Russian translation, "wide participation of community concerned") assessed in each particular case? The answer can be given by the "affected community" official representatives only (provided a legitimate procedure for discussing the proposed projects is in place in the country).

Marina Kumskaya, lead specialist in social economic assessment:

The Discussion Paper does not address the issues related to extent of social economic aspects elaboration for the EBRD-financed projects with the impacts beyond the issues of involuntary resettlement, cultural heritage, indigenous peoples, etc. outlined in the Policy. Therefore, this puts forth the need to consider not only social, but economic implications in the Project areas as well.

Separating the projects associated with involuntary resettlement into a distinct category, and developing special requirements for public consultations, disclosure of information, and assessment of social implications for such projects are the matters of great importance. Within the Policy's approach on obtaining project approval by indigenous peoples, the precise definition of "indigenous peoples consent" is required, and relevant estimation techniques in this area need to be developed as well.

Environmental and social impact assessment requirements, as well as the requirement to take public opinion into consideration, are stipulated by current Russian legislation. These stipulations are prescribed in the fullest extent in the document titled Regulations on Assessment of Environmental Impacts from Planned Economic Operations and Other Activities in the Russian Federation. The EBRD policy requirements do not disagree with this document and thus can be applied. Range of social economic studies has been made substantially wider in the EBRD Policy, as compared with domestic requirements, according to which a review of social economic issues directly related to environmental consequences of project activities is sufficient.

The issues of community outreach within the framework of OVOS procedure, the requirements, criteria, and management methods related to this process are not sufficiently elaborated in Russia. In this regard, the EBRD guidelines on information disclosure and dialog with concerned parties can be adapted for Russian practice.

Changes and amendments in the EBRD procedure within the scope of Public Information Principles Discussion Paper have not covered the operating procedures of Independent Recourse Mechanism (IRM). Currently, IRM only reviews complaints from the persons who have or may be exposed as a result of the Project implementation. As for other concerned parties (e.g., NGOs), it is stipulated that under specific circumstances a group of persons may submit a complaint for violation. Such organizational layout implies crucial limitation, since local residents are not always capable to formulate their claims and protect their interests by themselves. The new edition of the document as well as the current one provide no guarantees for due complaint processing.

Alexander Ryabenko, Director General, SHANECO Research Center LLC:

New revision of the EBRD Policy is a sound multi-aspect document; however, the first revision requires certain refinement. Some suggestions to refine the Policy are as follows:

• Explore the possibility of unifying project classification in view of the current IFC requirement;
• Identify feasibility of the mechanism for independent experts involvement in projects assessment, since conventionally the organizations a client engages to conduct environmental and social impact assessment are financially dependent on him (directly or indirectly);
• Define more clearly the goals and objectives of preliminary environmental and social impact assessment for project category identification; 
• Within each Performance Requirement (PR) of the projects, clearly define key directions of best practice, since the EBRD financed projects require compliance with best international practice of sustainable development;
• Specific measures and requirements, defined individually (p. 32 Section А), require disclosure of their content, since client's capability to achieve high social and/or environmental project performance, which is dependent on third-party activities, with Russian real-life practices taken into account, cannot be considered as unconditional ones;
• Definition of the "Project's area of influence" (p. 6 PR 1) has no environmentally justified explanation; it is rather aimed at infrastructural and social economic imposition criteria. It is advisable to disclose how specifically "EBRD and client will agree on the area of influence for each project." (ibid.)

Also, the following issue require elaboration in the Policy revision suggested for discussion:

• Which project phase should the studies of technologically and financially feasible options of planned activities be conducted at for Category A projects, and what should be the extent of these studies (p. 9, PR 1)? What is the difference between options and alternatives (ibid.)?
• What should be the coverage of project location options study (p. 15, PR 3)?
• It may be assumed with high probability, based on large projects implementation, that contractor's compliance with environmental requirements is one of the most complicated problems in implementing large projects. As for Russia, it should be recognized that the actual possibility to ensure contractor's compliance with the stated stringent requirements, including EU EHS requirements, is very small;
• Paragraph 5 PR 3 specifies that projects must be developed in compliance with EU environmental requirements. At the same time, p. 6. PR 3 specifies that for non-EU countries, neither EU membership applicants nor EU potential membership applicants, the timeline for compliance with EU environmental requirements "should be consistent with any bilateral agreements or action plans agreed between the EU and the relevant country." Would project assessment in compliance with EU environmental requirements be reasonable  for such countries?

Gennady Popov, senior technologist, SHANECO Group CJSC:

The Policy sets general directions of the EBRD practical activities for achieving the stated goal to promote environmental and social stability. There are no doubts about these lofty goals whatsoever. But the "bias of focus" toward the social component is evident.

The following aspects are not addressed either among the current EBRD requirements, or in the Discussion Paper:

• indigenous population's health, safety and protection. This aspect was not addressed in the Policy adopted in 2003 and requires greater consideration in this revision;
• requirement for project sponsors to identify the concerned parties with regard to implementation of category В or С projects; 
• explicit description of information disclosure requirements.

Suggested changes in the EBRD Policy and requirements are focused on improvements along four strategic lines of activity:

• integrating environmental considerations into the project cycle;
• promoting environmentally oriented investments across all sectors;
• mainstreaming environmental considerations through the EBRD's sectoral and country strategies and technical cooperation activities;
• building partnerships to address regional and global environmental issues.

Unfortunately, requirements implementation mechanisms have not been suggested. Therefore, the document is not likely to be functional in its current form.

The Policy stipulations are reflected and specified under the Project Performance Requirements (PRs), which are envisaged to be published as annexes to the Policy. The application mechanism is apparently straightforward: it provides for analysis of project compliance with the EBRD requirements and making a decision on its basis on granting or non-granting of credit.

The EBRD proposals generally do not conflict with principles and requirements of Russian national policy on environmental and social issues. They can be applied during OVOS procedures performed at pre-project and project phases by serving as an auxiliary guideline. National guidelines and regulatory documents are in place [in Russia] that govern the projects on development of standards of permissible limits with regard to environmental impact. The EBRD proposals are not applicable for developing the projects of impact standards.

Andrey Parshin, lead specialist in ambient air protection:

To enable this Policy application in Russia, harmonization of national and international legislation is needed. In many cases, international standards do not match the national ones, while the requirement to comply with national standards of the country of project implementation complicates its assessment. As part of the requirements harmonization, it is advisable to compare the EBRD projects classification with the current classification of Russian facilities by class of hazard.

The EBRD Policy, in considering air pollution issues, attaches growing value to carbon dioxide (GHG) emission reduction, and carbon quota market development. Carbon quota trading market does not exist in Russia at the present time. Russia does not put much stress on СО2 emission reduction, since in our country the assessment of air quality compliance to valid sanitary and public health standards serves as the basis for air pollution regulation.

Olga Klimenkova, senior specialist in physical impact factors assessment:

The document does not pay proper attention to noise emission issues, despite the fact that in modern life it has a growing impact on the human environment. In this respect, it is suggested to develop requirements as part of the EBRD Policy for conducting surveys and assessments of physical environmental impacts.

It would be interesting to get familiarized with the Environmental Exclusion List and the Reference List of Prohibited Activities available from the EBRD publications (reference on page 18 of the Discussion Paper), which documents need to be translated into Russian.

Olga Goretskaya, environmental engineer in physical impact factors assessment:

The PR3 Section of EBRD Policy should address the issues of equipment and machinery employment, which represents a significant source of impact on the physical environmental factors (noise, vibration, radiation, electromagnetic radiation), thus negatively affecting occupational and community health. It is also suggested to supplement Paragraph 9 PR3—prevention of pollution and physical environmental impacts (non-ionizing and ionizing radiation).

Nadezhda Melnikova, environmental engineer in industrial waste management:

Certain waste management aspects (e.g., minimizing wastes generation, greater extent of waste usage in products manufacturing and waste recycling, safe waste destruction, or waste release to specialized organizations for their safe disposal, transportation, and monitoring) are only loosely outlined in the EBRD Policy Discussion Paper. These issues have not been addressed with due depth and elaboration, which are required for their practical application.

Including the following items into the Policy is also advisable:

• procedure of handling production and consumption wastes at the plant;
• necessity of reporting;
• necessity of environmental payments;
• arrangements for production and consumption waste interim storage and accumulation at the enterprise, and/or waste disposal facilities;
• necessity of licensing the hazardous waste handling activities as well as production and consumption waste burial and recycling activities.

Vladislav Zagitov, Director General, SHANECO Analitica LLC:

On the overall structure and content of the topics discussed:

The EBRD's intention is to cover environmental and social aspects of sustainable development, and assume life quality as a basis. In this respect, the social component (preserving sustainability of social and cultural systems, cultural heritage and diversity) has been worked out in greater depth, as compared against economical and environmental components of the Policy. Such aspects as water, soil resources, and noise impacts have not been thoroughly elaborated.

It has to be clarified, which type of "sustainable development" is planned within the Policy framework: natural and industrial capital not diminished with time, or, with natural capital not diminished, a portion of revenues from sales of non-renewable natural resources will be allocated for increasing the value of natural capital.

Obviously, practical implementation in Russia is going to encounter a lot of obstacles, due to both legislative and social differences.