Challenges of Merging International and Local Requirements in Russia

One of the challenges for Russian environmental specialists is combining the international and Russian requirements for environmental and social impact assessment. Although current Russian laws contain no strict requirement to develop an impact assessment, known as OVOS, it continues to be an integral part of the permitting process.

The OVOS process is roughly equivalent in its objectives to the internationally recognised Environmental and Social Impact Assessment (ESIA) procedure, however there are a number of areas where the expectations of an international ESIA differ from those of the OVOS process, namely:

• Audience: The international ESIA document is intended for regulatory review, public disclosure and is often submitted to financial institutions. The Russian OVOS is prepared for expert review as part of the permitting process, and requires complicated technical language
• Scope of assessment: Infrastructure such as access roads, power lines, and water supply associated with developments, are considered separate projects and are not evaluated within the OVOS whereas they are considered part of the ESIA process
• Technical scope: Issues, such as greenhouse gas emissions, noise, and sustainability are not usually addressed within the OVOS process. Although the OVOS process requires consideration of social issues and closure planning, there is no requirement to address health and safety or labour conditions
• Public consultation and disclosure: Although part of the OVOS process, in practice the quality and extent of public consultation is much less rigorous than would be expected as part of an international ESIA
• Mitigation measures and management systems: Under OVOS traditionally technical design decisions, not management measures, are considered as mitigation measures. Developing a Social and Environmental Management System is not required under OVOS
• Environmental standards: Direct comparison between Russian and international environmental quality standards is not always possible. Some Russian standards fall below the practical reporting limit and sometimes exceed the natural background concentrations. They are considered to be overly stringent even by the Russian authorities, yet compliance is still required

As a result of these differences, two separate documents need to be prepared – an internationally accepted ESIA and a Russian OVOS for permitting purposes. Both of these documents should be consistent in main statements and conclusions. This can be achieved by close cooperation between the ESIA and OVOS teams, as they carefully discuss the identified issues.

Ekaterina Vershinina:

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