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Republic of Belarus Proposed Energy Efficiency Project Environmental Assessment

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    1. Project Description

Project Objectives

The development objective of the project is to improve energy security, increase energy efficiency in the energy sector in Belarus and reduce negative environmental impacts.

Project Components and Activities

The project is planned to have two investment components and two implementing agencies, Belenergo and the Energy Efficiency Department (EED). This EMP concerns the Borisov and Mogilev sites. The EED component is covered by a separate EMP prepared in the framework of this environmental assessment.

The Borisov and Mogilev interventions are conversion of large heat-only-boilers (HOBs) operated by Belenergo to combined heat and power (CHP) plants in the cities of Borisov and Mogilev (Appendix 2A shows the location of the cities on a map of Belarus). These CHPs will be located at the existing boiler plant sites and will partly utilize existing buildings and other infrastructure. The existing preliminary feasibility studies have considered several alternatives for the proposed investments, including (i) continuation of heat generation without power generation, and (ii) different configurations for power generation.
Borisov. In Borisov the plan is to convert the existing boiler house # 3, which is owned and operated by Minskenergo, to a combined cycle CHP plant based on natural gas, with diesel fuel as a back-up fuel. The power capacity will be about 65 MW. The considered boiler house is situated in the town’s industrial zone in close proximity to a railway and occupies 4.8 ha of land (Appendix 2B shows the location of the boiler house in Borisov). The main fuel currently used is gas; and a reserve fuel, used in case of gas supply disruption, is fuel oil. Gas is supplied by an underground pipeline. Fuel oil is shipped via a nearby railway and stored on the boiler house’s site in three storage tanks with the storage capacity of 3,000 m3 each. The nearest residential building is situated 700 m from the boiler house.
According to the preliminary plan, the proposed intervention in Borisov involves decommissioning of two steam and two water boilers and installation of cogeneration equipment in a newly constructed building next to the existing main building of the boiler house. Additionally, construction of two diesel fuel storage (2x700m3) and turbine and transformer oil storage (8x20m3) is envisaged.
Mogilev. In Mogilev a HOB, operated by Mogilevenergo, would be converted to a CHP plant based on gas combined cycle technology with the power capacity of 15.5 MW. Fuel oil will be a back-up fuel. The reconstruction of the boiler house will include installation of cogeneration equipment on the existing territory of the boiler house.
The boiler house in Mogivel is situated in the northern part of Mogilev on the territory of the “Mogilevselmash” factory and occupies 4 ha of land (see Appendix 2C); and is surrounded by industrial plants and railways. The boiler house supplies with heat and hot water the “Mogilevselmash” factory and the residential sector of the Northern and Eastern districts on Mogilev. The current installed heat producing capacity of the boiler house is 210 Gcal/h. The main fuel is natural gas; and a reserve fuel is fuel oil. The nearest residential building is situated 300 m from the boiler house.

    1. Institutional Framework

2.1.1.Brief Review of the Pertaining Organizational Framework

Energy Sector. The Ministry of Energy of Belarus is the state administration body responsible for the energy policy formulation and implementation. The Ministry established a state owned power utility called Belenergo, which is currently responsible for power generation, transmission and distribution through its subsidiaries. In each of the Belarusian regions (oblasts) Belenergo has its regional offices - Oblenergo. Oblenergo manage some large-scale boiler houses in big and mid-size Belarusian cities.

Environmental Protection. The Belarusian Ministry of Natural Resources and Environmental Protection (MoEnv) is responsible for environmental protection in the country, and has a similar vertical structure. The MoEnv has its regional and local offices in all the Belarusian regions and districts. The environmental authorities are responsible, among other activities related to environmental protection, for conducting State Environmental Review (SER), issuing environmental licenses and permits, and for conducting regular and ad-hoc environmental monitoring.

2.1.1.Brief Review of the Relevant Belarusian Legislation and Procedures

The Belarusian environmental legal and regulatory framework pertinent to the project is rather extensive and covers air and water protection, waste management and environmental assessment, along with the relevant international treaties ratified by Belarus. The Law on Environmental Protection (1992, amended in 2002) is the Belarusian framework law, which establishes the basis for environmental protection and the use of natural resources in Belarus
Air. The Law on Atmospheric Air Protection (1997, amended in 2007) is the main law regulating air protection activities in Belarus. The law contains general provisions aiming at protection and improving the quality of the atmospheric air, as well as at prevention and alleviation of adverse impact on the air from human economic activities. The law also lays down obligation of enterprises in terms of air protection, including emission control and monitoring.
According to the Law, enterprises are obliged to obtain emission permits, containing emission limits and other environmental conditions for conducting industrial activities which involve emission of pollutants. Enterprises have to renew their emission permits in the case of a change in the amount or composition of pollutants emitted, according to the Regulation on the Procedure for Issue, Prolongation and Termination of Permits for Pollutants Emission to the Atmospheric Air (2005). Emission permits can be terminated in case of enterprise’s failure to comply with the requirements of the permits.
The Hygienic Norms (2005) establish Maximum Allowable Concentrations (MACs) of air pollutants in settlements. According to the Norms, the MACs (daily average) for the criteria pollutants in settlements are:


200 µg/m3


240 µg/m3


100 µg/m3


3000 µg/m3


5 ng/m3

The Technical Standards 1626.1-2006 Boilers. Installations Burning Gas, Liquid and Hard Fuels (2006) establish limit values for pollutants emission from boiler houses using gas, liquid and hard fuels (excluding biomass), while the Technical Standards 1626.2-2006 Boilers. Biomass Burning Installations (2006) provides limits for pollution emission from biomass burning installations.

According to the Technical Standards1626.1-2006, the boiler houses in Borisov and Mogilev after the reconstruction have to meet the following pollutants emission standards (at 6% oxygen by volume):
Boiler house in Borisov.


Liquid Fuel


200 mg/m3


250 mg/m3


150 mg/m3


300 mg/m3


850 mg/m3

Boiler house in Mogilev.


Liquid Fuel


100 mg/m3


150 mg/m3


120 mg/m3


250 mg/m3


4,750 mg/m3

Enterprises are obliged to conduct monitoring of their emission in accordance with the Procedure for Performing Local Environmental Monitoring by Enterprises, Operating Sources of Adverse Environmental Impact (2007).


The Water Code (1998, amended in 2007) is the main legal act regulating water management in the country. The Code establishes a legal framework for water sustainable use and protection, along with protection of natural water ecosystems. To abstract water from or discharge wastewater to underground or surface water bodies, an enterprise has to obtain permit for special water use from respective environmental authorities in accordance with the Regulation on Issuing of Permits for Special Water Use (2003). The water pollution limit values established for water quality for fisheries are presented in tabular form below.


Limit value

Dissolved oxygen

4.0 – 6.0 mg/litre


3 mg/l O2

Nitrite as N

0.002 mg/l

Nitrate as N

9.1 mg/l


0.39 mg/l


300 mg/l


100 mg/l


0.01 µg/l




5 µg/l (Cr+3) 1 µg/l (Cr+6)


1 µg/l (Cu+2)


10 µg/l (Zn+2)

Source: Second Environmental Performance Review. Belarus. 2005.

The Law On Waste Management, adopted in 2007, is the main legal act regulating waste management in Belarus. The Law sets priority of waste reusing to disposing in landfills. The Law contains also provisions regulating construction waste management. Industrial waste storage and/or disposal are allowed only in designated places in accordance with special permit acquired by an enterprise. Enterprises are obliged to keep records on the wastes generated by them, and to prevent any adverse environmental impact from these wastes.

The Regulation on the Procedure for Identification of Waste Hazard Degree and Setting Hazard Class for Waste (2001) categorizes waste to 1st, 2nd, 3rd and 4th classes, assigning 1st class to the most dangerous wastes. Below are some examples of pollutants and corresponding hazard class.






Asbestos dust

Hazard class






Noise. Sanitary Norms and Rules 2.2.4/ Noise on Working Places, in Residential, Public Buildings and on Residential Territories (2002) set the following maximum allowable noise levels at night:

Mean frequency, Hz









Noise level limit values in residential buildings, dB









Environmental Assessment. The Belarusian legal basis for environmental assessment comprises four enactments. These are the Law on Environmental Protection, the Law on State Environmental Review (1993, amended in 2000), the Regulation on Implementation Procedure of State Environmental Review in Belarus (SER Regulation), adopted in 2001, and the Regulation on Implementation Procedure of Environmental Impact Assessment of Economic and Other Activities (EIA Regulation), adopted in 2005.
Environmental assessment in Belarus consists of two interrelated but separate procedures: Environmental Impact Assessment (EIA) and State Environmental Review (SER). SER is a formal procedure aiming to verify that a proposed development is in line with the Belarusian environmental legislation. SER is organized and carried out exclusively by the MoEnv and its regional and local offices according to the SER Regulation and is funded from the state budget. Thermal power generating stations and district boiler houses are subject to mandatory SER. Based on the outcomes of the SER, a final decision is made, which has to be adhered to during implementation by the proponent. The Law on State Environmental Review prohibits implementation of any activity requiring an SER without a positive SER statement (Article 14).
EIA is organized and funded by the proponent of the proposed development and is carried out by a design or scientific institute (EIA Regulation). According to the EIA Regulation, thermal power generation installations with the heat capacity of 25 MW and more are subject to mandatory EIA. For the developments not included in the list, but which can still result in adverse environmental consequences, a decision on whether or not EIA is required is left to the MoEnv and its regional and local offices.
The outcome of EIA is an environmental impact report, which becomes an integral part of the project design documentation and is submitted to national, regional or local environmental authorities for SER. EIA procedural framework is presented in Appendix 3. In cases where EIA is not required, a proponent or a design institute (on their behalf) is obliged to prepare a separate section devoted to environmental protection. This section is also submitted as an integral part of design documentation for SER.
Public Consultations. The Belarusian environmental legislation grants the general public the right to participate in the EIA process. A proponent has an obligation to provide to the public concerned all the necessary information on the proposed development and organize and finance public hearings (Law on Environmental Protection and Law on State Environmental Review). Section 6 of the EIA Regulation contains prescribes a procedure for public hearings on EIA findings (see also Appendix 3 for EIA procedural framework).
The Belarusian citizens and NGOs have the right to organize and conduct an independent public environmental review (PER). A report on findings of a public environmental review has an advisory status and can be handed over to the environmental authorities for consideration. Financing of a PER is responsibility of the party initiating the PER, that means NGOs and/or citizens (Article 61, Law on Environmental Protection).

Belarus ratified in 2000 the Aarhus Convention, which requires public consultations and environmental information disclosure by the environmental authorities. An Aarhus Centre has been established in Belarus, which provides Belarusian citizens with environmental information upon their requests.

International Treaties. Belarus ratified a number of international environmental treaties, which became a part of the national legal framework. Among these treaties are the UN Framework Convention on Climate Change and the Kyoto Protocol ratified by Belarus respectively in 2000 and 2005. Belarus has also ratified the Vienna Convention on the Protection of the Ozone Layer and the Montreal Protocol, the UN Convention on Biological Diversity, the Stockholm Convention on Persistent Organic Pollutants, the Convention on Long-Range Transboundary Air Pollution and the UNECE Convention on Environmental Impact Assessment in a Transboundary Context.

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