Environmental and Social Impact Assessment (Esia) of the Transmission and Distribution Network of the Ecowas

Public Disclosure Authorized

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) OF THE TRANSMISSION AND DISTRIBUTION NETWORK OF THE ECOWAS-

REGIONAL ELECTRICITY ACCESS PROJECT (REAP) FROM THE PROPOSED BRIKAMA SUB-STATION

Public Disclosure Authorized

SEPTEMBER 2020

Public Disclosure Authorized

SUSTAINABLE DEVELOPMENT FOCUS (SD FOCUS) Ltd. Sahel WAIS Knowledge Campus, MDI Road, Kanifing

Contents LIST OF FIGURES ...... x EXECUTIVE SUMMARY ...... xi CHAPTER 1: INTRODUCTION ...... 1 1.1 Project Background ...... 1 1.2 The Project Development Objective (PDO) ...... 2 1.3 Project Beneficiaries ...... 2 1.4 Rationale of the Project ...... 2 1.5 Objectives of this ESIA Study ...... 2 1.6 Consultant Responsible for this Study ...... 2 1.7 Methodological Approach for the ESIA ...... 3 CHAPTER 2: PROJECT DESCRIPTION AND SCOPE ...... 6 2.1 – Presentation of the Project Proponent ...... 6 2.1.1 Objectives of the Commission ...... 6 2.1.2. Roles and Functions of the ECOWAS Commission ...... 6 2.1.3. Organizations of the Commission ...... 7 2.2 - Location of Project Sites ...... 7 2.2.1 Brief Description of OMVG Brikama Sub-station Site and Related Feeders ...... 7 2.3 Technical Consistency of the Works ...... 29 2.3.1 Construction of 33/30 kV Medium Voltage (MV) Lines ...... 29 2.3.2 Construction of distribution substations of 33/30 kV / 400 Volts (V) ...... 30 2.3.3 Construction of 400 V Low Voltage (LV) lines ...... 30 2.3.4 Supply and Installation of Last-mile Connection Equipment, including Service Drops, Prepaid Meters, and Ready Boards for LV customers ...... 30 CHAPTER 4: DESCRIPTION OF THE CURRENT STATE OF THE ENVIRONMENT OF THE PROJECT AREA ...... 32 4.1 Geographic and administrative location of the project area ...... 32 4.2 Delimitation of the Study Area ...... 33 4.3 Current State of the Environment of the Indirect Areas of Influence ...... 10 I. The Physical Environment ...... 10 i. Climatic Conditions ...... 10 ii. Hydrology ...... 11 iii. Geology and Soils ...... 12 iv. Topography and Land Use ...... 12 II. The Biological Environment ...... 13 i. The Vegetation and Forest Resources ...... 13

ii. Wetlands Along the Corridors ...... 15 iii. The Fauna ...... 16 2.4 Description of Activities by Project Phases ...... 17 2.4.1 Description of Construction Works of the 33/30 kV Medium Voltage (MV) lines ...... 17 2.4.2 Description of Construction Works of the Distribution Sub-Stations ...... 19 2.4.3 Description of Construction Works of the 400V Low Voltage Lines ...... 20 2.4.4 Description of the Supply and Installation Works of the Last-mile Connection Equipment, including Service Drops, Prepaid Meters, and Ready Boards for LV Customers ...... 22 2.5 Works Input ...... 22 2.5.1 Personnel ...... 22 2.5.2 Water ...... 23 2.5.3 Quarries ...... 23 2.5.4 Equipment ...... 23 2.6 Project Outputs ...... 23 2.7 Assessment of Project Alternatives ...... 23 CHAPTER 3: RELEVANT NATIONAL AND INTERNATIONAL POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK ...... 27 3.1 Relevant National Policies ...... 27 3.2 The National Legal Framework ...... 28 3.3 Relevant International Conventions and Agreements ...... 31 3.4 Institutional Analyses ...... 27 3.5 Institutional Framework ...... 27 3.6 Relevant Bank Policies ...... 33 3.7 Relevant ECOWAS Environmental and Social Safeguards triggered by the Project..... 34 III. Human and Socio-economic Environment ...... 35 i. Demography and Population ...... 35 ii. Physical Structures ...... 35 iii Schools and Other Infrastructure ...... 36 iv Chance Finds and Cultural Heritage and Archaeology ...... 36 v Disadvantaged and Vulnerable Groups ...... 36 vi Gender and Gender-Based Violence (GBV) ...... 37 vii Violence Against Children (VAC) ...... 38 viii Access of the Population to Education ...... 38 ix Access of the Population to Electricity, Telephone Services ...... 39 4.4 Modes of Subsistence and Daily Chores in the Project’s Area of Influence ...... 39 i. Agricultural Production ...... 39

ii. Market Gardening ...... 40 iii. Marketing and Petty Trading and Shop keeping ...... 41 iv. Tyre Repairing ...... 41 A tyre repair workshop is also located at the same area as Mr. Gaye’s business. His facility is made from corrugated iron sheets, and with his team of assistants, repairs tyres under the existing line as Mr. Gaye. He will also be impacted when the works start...... 41 v. Harvesting Non-wood Forest Products ...... 41 vi. Firewood Collection ...... 41 vii. Livestock Rearing ...... 41 viii. Fishing ...... 42 4.5 Description of Direct Influence Area and Location-Specific Baseline Conditions ...... 42 4.6Main Stakes and Risks of the Project ...... 42 CHAPTER 5: PUBLIC CONSULTATION ...... 45 5.1 Objectives of the consultation...... 45 5.2 Methodological Approach ...... 45 5.3 Targeted Groups ...... 46 5.4 Opinions, concerns and fears of populations and PAPs ...... 47 CHAPTER 6: ANALYSES OF POTENTIAL IMPACTS AND MITIGATION MEASURES...... 48 6.1 Methodological Approach ...... 48 6.1.1 Identification of the Main Sources of Potential Impacts of the Project on the Environment ...... 48 6.1.2. The Environment and Social Components Affected by the Project ...... 49 6.1.3 Identification of Potential Impacts ...... 49 6.2 Evaluating the Significance of Potential Impacts ...... 98 6.2.1 Nature of an Impact ...... 98 6.2.2 Types of Impacts...... 98 6.2.3 Evaluation of Impact Severity / Significance ...... 98 6.3 Potential Impacts of the Pre-construction Phase ...... 99 6.3.1 Potential Positive Impacts on the Biophysical Environment ...... 99 6.3.2 Potential Negative Impacts on the Biophysical Environment ...... 99 6.3.3 Potential Positive Impacts on the Human Environment ...... 103 6.3.4 Potential Negative Impacts on the Human Environment ...... 104 6.4 Potential Impacts of the Construction Phase ...... 106 6.4.1 Potential Positive Impacts on Biophysical Environment ...... 106 6.4.2 Negative Impacts on the Biophysical Environment ...... 106 6.4.3 Potential Positive Impacts on the Human Environment ...... 108

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6.4.4 Negative Impacts on Human Environment ...... 109 6.5 Potential Impacts of Operation and Maintenance ...... 111 6.5.1 Positive Impacts on Biophysical Environment ...... 111 6.5.2 Negative Impacts on the Biophysical Environment ...... 111 6.5.3 Potential Positive Impacts on Human Environment ...... 112 6.5.4 Potential Negative Impacts on Human Environment ...... 113 6.6 Impacts of Decommissioning and Dismantling ...... 114 6.6.1 Potential Positive Impacts on Biophysical Environment ...... 114 6.6.2 Negative Impacts on Biophysical Environment ...... 114 6.6.3 Potential Positive Impacts on Human Environment ...... 114 6.6.4 Negative Impacts on Human Environment ...... 114 6.8 Cummulative Impacts ...... 115 CHAPTER 7: MANAGEMENT MEASURES OF THE POTENTIAL NEGATIVE IMPACTS ON THE ENVIRONMENT ...... 117 7.1 Enhancement Measures for Potential Positive Impacts ...... 117 7.1.1 Enhancement Measures for Positive Impacts During Pre-construction Phase: Human Environment ...... 117 7.1.2 Enhancement Measures for Positive Impacts During Construction Phase: Human Environment ...... 118 7.1.3 Enhancement Measures for Positive Impacts During Operation Phase: Biophysical Environment ...... 118 7.1.4 Enhancement Measures for Positive Impacts During Operation Phase: Human Environment ...... 118 7.1.5 Enhancement Measures for Positive Impacts During Decommissioning Phase: Biophysical Environment ...... 119 7.2 Impact Management during Pre-construction Phase ...... 119 7.2.1 – Mitigation Measures of the Negative Impacts on the Biophysical Environment ..... 119 7.3 Impact Management during Pre-construction Phase ...... 124 7.3.1 Mitigation Measures of the Potential Negative Impacts on the Human Environment 124 7.4 Potential Impact management during the construction phase ...... 129 7.4.1 Mitigation Measures of the Potential Negative Impacts on the Biophysical Environment ...... 129 7.4.2 Mitigation Measures of the Negative Impacts on the Human Environment ...... 131 7.5 Impact Management during the Operation and Maintenance Phase ...... 136 7.5.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment ...... 136 7.5.2 Mitigation Measures of the Negative Impacts on the Human Environment ...... 136 7.6 Impact Management during the Decommissioning Phase ...... 138

7.6.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment ...... 138 7.6.2 Mitigation Measures of the Negative Impacts on the Human Environment ...... 139 7.7 Mitigation of Potential Cumulative Impacts ...... 142 CHAPTER 8: MANAGEMENT OF RISKS AND ACCIDENTS ...... 142 8.1 Methodological Approach for Hazards and Risks Identification ...... 143 8.1.1 Objectives of the Risk Assessment and Management ...... 143 8.1.2 Methodology ...... 143 8.1.3 Risk Identification...... 144 8.2 Risk Analysis ...... 101 8.3 Mitigation of Risks ...... 108 8.4 Training...... 108 8.5 Emergency Response in Case of Incidents ...... 108 8.6 Health and Safety Reporting and Recording ...... 109 8.7 Health and Safety Monitoring ...... 109 CHAPTER 9: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ...... 110 9.1 Objectives of The ESMP ...... 110 9.2 ESMP Implementation and Monitoring Arrangements ...... 110 9.2.1 Roles and Responsibilities for ESMP Implementation ...... 110 Specific Roles and Responsibilities of Project Personnel ...... 112 9.2.2 Institutional Training and Sensitization ...... 114 9.2.3 Monitoring ...... 116 9.2.4 Reporting ...... 123 9.2.5 Environmental Auditing ...... 123 9.2.6 Budget for Implementation of the ESMP ...... 123 9.3 Matrix on the Mitigation of the Identified Potential Negative Impacts ...... 124 CONCLUSION ...... 143 BIBLIOGRAPHY ...... 144 Appendix 1: Brikama Feeders 1 and 2 Corridors ...... 146

Appendix 1.1: Brikama Feeder 3 Corridors – Sheet 1

...... 147 Appendix 1.2: Brikama Feeder 3 Corridors – Sheet 2 ...... 148 Appendix 2: Communities Along the Brikama Feeders ...... 146 Appendix 3: List of Corridors under the Brikama Substation Feeders ...... 150 Appendix 4: Location-Specific Baseline Environmental Conditions along the Brikama Transmission Corridors ...... 151 Appendix 5: Chance Find Procedures ...... 160 Appendix 6: Summary of Comments and Views expressed at the Consultations ...... 161 Appendix 7: List of Persons Met ...... 165 Appendix 8: Codes of Conduct and Action Plan For Implementing ESHS and OHS Standards, and Preventing Gender Based Violence and Violence Against Children ...... 178 Appendix 9: The Existing Memoradum Between NAWEC and the Department of Forestry 201 Appendix 10: Technical Note: Public Consultations and Stakeholder Engagement in WB- Supported Operations when there are Constraints on Conducting Public Meetings ...... 208 Appendix 11 PROTOCOL FOR CONSULTATION AND CIVIL WORKS UNDER COVID 19 ECOWAS REGIONAL ELECTRICITY ACCESS PROJECT (ECOREAP) IN THE GAMBIA ...... 212 Appendix 12: Contract Clauses to be Included in Contractors’ Agreements ...... 218

Appendix 13: Modalities of the Proposed Grievance Redress Mechanism ...... 223 Appendix 14: Flow Chart of Grievance Redress Process ...... 225 225

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ABBREVIATIONS AND ACCRONYMS

AOI Area of Influence BF Brikama Feeder CBD Convention on Biological Diversity CCD Convention to Combat Desertification CEDAW Convention on the Elimination of All Forms of Discrimination Against Women CRR Central River Region CRR-N Central River Region-North CRR-S Central River Region-South DSA Deep Sandstone Aquifer DOF Department of Forestry DPWM Department of Parks and Wildlife Management DPPH Department of Physical Planning and Housing DWR Department of Water Resources ECOWAS Economic Community of West African States ECOWAS-REAP ECOWAS Regional Electricity Access Project ECREEE ECOWAS Centre for Renewable Energy and Energy Efficiency ERERA ECOWAS Regional Electricity Regulatory Authority ESHS Environmental Social Health and Safety EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental Safeguards Specialist GBOS Gambia Bureau of Statistics GBV Gender-Based Violence GD Geology Department GEAP Gambia Environment Action Plan GERMP Gambia Electricity Restoration and Modernization Project GIS Geographic Information System GoTG Government of The Gambia GPS Global Positioning System GRM Grievance Redress Mechanism HIV/AIDS Human Immune Deficiency Virus/Acquired Immune Deficiency Syndrome IDA International Development Association IUCN International Union for Conservation of Nature kV Kilovolts LHS Left Hand Side LRR Lower River Region Ltd. Limited LV Line Low Voltage MOE Ministry of Energy MOLRG Ministry of Lands and Regional Governments M&ES Monitoring and Evaluation Specialist MV Line Medium Voltage NEA National Environment Agency

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NRA National Roads Authority NAWEC National Water and Electricity Company NBR North Bank Region NCAC National Council for Arts and Culture NEMA National Environment Management Act NNP Niumi National Park OHS Occupational Health and Safety OMVG Organization pour la Mise en Valeur du Fleuve Gambie (French acronym for Gambia River Basin Development Organization) OMVS Organisation pour la Mise en Valeur du Fleuve Sénégal (French acronym for Senegal River Basin Development Organization) OP Operational Policy PC Project Coordinator PDO Project Development Objectives PE Power Engineer PIU Project Implementation Unit PSC Project Steering Committee PURA Public Utility Regulatory Authority RAP Resettlement Action Plan REAP Regional Electricity Access Project RHS Right Hand Side ROW Right of Way SD focus Sustainable Development Focus SEA Sexual Exploitation and Abuse SF Soma Feeder SH Sexual Harassment SOP Series of Projects SSA Shallow Sand Aquifer SSS Social Safeguards Specialist STD Sexually Transmitted Diseases STI Sexually Transmitted Infections STS Standard Transfer Specification T&D Transmission and Distribution TAC Technical Advisory Committee TWNP Tanbi Wetland National Park Tee-off A branch-off point of an MV Line ToR Terms of Reference UN United Nations UNESCO United Nations Educational, Scientific and Cultural Organisation UNFCCC United Nations Convention on Climate Change URR Upper River Region VAC Violence Against Children WAPP West African Power Pool WB World Bank WCR West Coast Region

LIST OF TABLES

Table 3.1: Relevant National Policies Table 3.2: The Legal Framework Relevant to the Project Table 3.3: Relevant Regional/International Signed/Ratified by The Gambia Table 3.4: Institutional Framework Table 3.5: World Bank Environmental and Social Safeguards Relevant to the Project Table 3.6: ECOWAS Safeguard Policies Triggered by the Project Table 4.1: Project Affected Districts Table 4.2: Recorded Annual Rainfall in Project Regions (mm) 2009-2018) Table 4.3: The Mangrove Vegetation Along some of Proposed Corridors Table 4.4: Vegetation Found in Wooded Savannah along the Project Corridors Table 4.5: Fruit Trees along the Corridors Table 4.6: Mammalian fauna found along the ECOWAS-REAP corridors Table 4.7: Avifauna Found Along the Corridors and in WCR Table 4.8: Reptiles Found in the Niumi National Park and Along the Corridors Table 4.9: Brikama Feeders 1- 3: Summary of Communities Along the Corridors Table 4.10: Farming Calendar of Activities along the Transmission Line Corridors Table 4.11: Main Stakes and Risks of the Project Table 7.1: Recommended Minimum Clearance Distances for Various Situations Table 6.1: Main Sources of Potential Impacts of the Project on the Environment Table 6.2: Environmental Components likely to be affected by the Project Table 6.2: Identification of impacts Table 8.1: Risk identification matrix Table 8.2: Risk evaluation / rating Table 8.3: ESMP Monitoring Program Table 9.1: Summary of Roles and Responsibilities in ESMP Implementation Table 9.2: Capacity Enhancement Program for Effective ESMP Implementation Table 9.3: ESMP Monitoring Program Table 9.4: Estimated Budget to Implement the ESMP

LIST OF FIGURES Figure 2.1: ECOWAS-REAP Substation and Line Corridors Figure 4.1: ECOWAS – REAP: Administrative Locations and Areas of Influence of Brikama Feeder Figure 4.2: Wetland along the proposed Kundunku line corridor Figure 4.3: Appropriate pole construction methods in wetlands Figure 4.4: Illustration of farm boundary away from the road Figure 4.5: Melon plantation (outside Project area) illustrating position of pole and farm clearance from the road and line corridor Figure 5.1: Meeting with the Community of Buram in Foni Bintang Karanai Figure 6.1: Example of stockpiles with green background (for a current road project) within this Project's AoI Figure 6.02: Combination of poles and cables around the Brusubi substation (outside this Project’s AoI) Figure 6.3: Combination of poles and cables (MV and LV poles; street light poles, Advertisement Boards) across the highway from Brusubi substation (outside this Project’s AoI)

EXECUTIVE SUMMARY

Background This report is the Environmental and Social Impact Assessment (ESIA) of the three Economic Community of West African States (ECOWAS)-Regional Electricity Access Project (REAP) feeders that emanate from the Brikama Sub-Station under the Gambia River Basin Development Organization (OMVG) Energy Project. The REAP Project is part of a Series of Projects (SOP) being implemented within the ECOWAS region, with a long-term view to achieving electricity distribution expansion within the Region.

Funded by the IDA/World Bank, the SOP aims to increase the number of people in West Africa with access to reliable and affordable electricity, as articulated in the ECOWAS White Paper of 2006 for Increasing Access to Energy Services to People of the Sub-region. The SOP consists of two Phases, which plan to provide 2.5 million people across six countries in West Africa, namely Guinea-Bissau, Niger, Mali, Senegal, Mauritania, and The Gambia with electricity. Phase I of the SOP is to provide access to 1.1 million people in Guinea-Bissau, Mali, and The Gambia. This Phase will finance the expansion of Medium Voltage (MV) and Low Voltage (LV) networks from the two high-voltage 225/33 kV substations (in Soma, Lower River Region–LRR, and in Brikama, in West Coast Region–WCR) being built under the OMVG Energy Project. It is expected that this will transform the power sectors of these countries and enable them to achieve their common objective of delivering more power to more consumers. The second Phase of the SOP will finance the reinforcement and extension of a similar distribution network (MV and LV) in Senegal, Niger, and Mauritania, and within the context of the ECOWAS White Paper of 2006, additional member countries will be included later (potentially through additional financing). The participating countries will benefit from attracting larger contractors to ensure timely implementation, and furthermore, the regional approach facilitated by ECOWAS will be used to disseminate lessons learned from the World Bank’s global access experiences, which will be shared with participating countries to implement the access agenda. Description of the Project

In The Gambia, the geographical extent of the Project covers a maximum of 100km radius from the OMVG Energy Project’s substation in Brikama, in the West Coast Region. Specifically, the scope of the works will include:

1. construction of 33/30 kV Medium Voltage (MV) lines; 2. construction of distribution substations of 33/30 kV / 400 Volts (V); 3. construction of 400 V Low Voltage (LV) lines; 4. supply and installation of last-mile connection equipment, including service drops, prepaid meter, and ready boards for LV customers.

Policy, legal and institutional framework

The National Policy Framework

The policies that will guide the implementation of the Project include the following:

i. National Development Plan (2018-2021) ; the principal national policy plan which proposes to increase the national coverage of electricity in the country;

ii. National Energy Policy (2014 – 2018) which aims Policy aims to increase electricity coverage nationally; iii. Gambia Environment Action Plan, GEAP (2009-2018): Provides guidance in general environmental planning and natural resources management;

iv. The National Elctricity Road Map 2017-2021 Road Map: plans to improve power generation and transmission capacity NAWEC. In addition, it aims to increase absorption capacity for the expected increase in generation capacity, and to reduce transmission and distribution losses;

v. Forestry Policy (2010-19) and the National Biodiversity Strategy and Action Plan (NBSAP), 2015 both of which promote State and community forest and biodiversity management;

The Legal Framework

This includes the following:

i. National Environment Management Act, 1999 - the principal legislation in environmental management; Part V of Act provides for certain projects listed under Schedule A to be considered for ESIA, and it includes this Project;

ii. Environmental Quality Standards Regulations 1999 sets the standards in Schedule 1 in respect of ambient air, saline waters, surface fresh waters and groundwater;

iii. Biodiversity and Wildlife Act, 2003: provides for the establishment of protected areas for protection of in-situ biodiversity; in addition to protect ex-situ biodiversity;

iv. National Council for Arts and Culture Act, 2003 this Act protects and preserves, restore any monument, relic, ethnographical article, or other article of archaeological ethnographical, or historical relevance. Project activities could unearth objects of historical relevance;

v. Land Acquisition & Compensation Act, 1990: Provides for consultation, resettlement, and compensation of land.

World Bank Safeguard Policies Triggered by the Project

These include:

i. OP 4.01 Environmental Assessment (including public participation and stakeholder engagement). The objective of this policy is to ensure that projects financed by the Bank are viable and environmentally feasible. It covers the impacts on the physical environment (air, water, and land, etc.); the living environment, health, and safety of populations; physical cultural resources; and environmental concerns at cross-border and global level;

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ii. OP 4.04 Natural Habitats: aims at protection, maintenance, rehabilitation of natural habitats and their functions. There are swamps, wetlands, and waterbodies along the Project corridor that are home to various invertebrates, mammalian, including avian fauna;

iii. OP 4.11 Physical Cultural Resources: Avoid or mitigate adverse impacts on physical cultural resources;

iv. OP 4.12 Involuntary resettlement of populations: Aims at avoiding resettlement where feasible or, at least minimizing it. Where it is not feasible to avoid resettlement, develop RAP, providing sufficient investment resources to enable the persons displaced by the project to share in project benefits, among other things;

v. OP 4.36 Forests: This Policy aims to harness the potential of forests to reduce poverty in a sustainable manner, integrate forests effectively into sustainable economic development, and protect the vital local and global environmental services and values of forests. The Project is challenged by this OP as there are Forest Parks, and Community Forests that may be affected by its implementation.

Institutional Framework The institutional framework relevant to the implementation of this Project includes the following:

i. National Environment Agency: The NEA enforces the NEMA, 1994 and EIA Regulations 2014, and reviews the ESIA report to grant Environmental Approval for the Project;

ii. National Water and Electricity Company (NAWEC): Project Proponent, and will lead implementation of ESMP;

iii. Women’s Bureau-Under the Ministry of Women, Children and Social Welfare, specifically promotes gender equity and women’s empowerment in The Gambia. It ensures the rights of women affected by the Project are protected; participates in sensitization on gender issues during pre-construction, construction, and operation phases;

iv. Department of Social Welfare: Protects and promotes the rights of vulnerable people such as children, women and the disabled; supports and guides the process during related grievances; participates in sensitization on GBV, SEA, SH, VAC etc.

v. Department of Labour: Enforces employment laws to protect employee rights, protect against child labour, and respond to complaints and reports such as accidents, abuse, and discrimination at work.

Description of the environment and major environmental and social issues

The Biophysical Environment

Climatic Conditions The climatic condition in The Gambia is of the Sudano-Sahelian type and is characterized by the occurrence of two distinct seasons: a hot rainy season from May/June to October, and a dry season from November to May with rare occurrence of rainfall in May. Rainfalls are typically heavy nationally,

xiii but the south-western part of the country records more rain than the eastern portion. July, August, and September are the highest rainfall months.

Hydrology

Surface Water The surface hydrology within the Project’s sphere of influence consists of the Tanbi Wetland National Park (TWNP) located at the mouth of the River Gambia, and occupying an area of approximately 6,000ha (of which mangroves make up 4,800ha). Whilst most of the Project area is out of the Park, settlements that border it to the south include the village of Mandinari, a potential ECOWAS-REAP site.

The community of Tunjina (a potential project site) is drained by the Mandinari “bolong” (Mandinka name for tributary) a tributary of the River Gambia whose banks are lined with mangrove vegetation. Another tributary that will influence the Project is the Kandong “bolong” in Foni Bintang Karanai (500m from the community of Kandunku. At high tide, the bolong submerges an entire portion of the road leading to the village.

Another surface hydrology within the Project’s sphere of influence is mainly the run-off and storm water during the rainy season which runs into tributaries and adjacent fields. Pole construction in swampy areas, or along pathways of storm water could potentially impact transmission poles.

Groundwater Resources Within the Project sites the ground water is tapped mostly from two main groundwater sources namely, the Shallow Sand Aquifer (SSA) and Deep Sandstone Aquifer (DSA), (the former is essentially where the local hand dug wells tap their supply along the route of the project).

The Vegetation and Forest Resources

The following vegetation types are found along the proposed line corridors: Riparian Vegetation

A riparian vegetation or riparian woodland is a forested or wooded area of land adjacent to a body of water such as a river, stream, lake, marshland, estuary, or reservoir. This vegetation type is found along corridors with swampy and marshy environment such as the wetlands of the Tunjina and Kondonk. Specifically, to access the community of Kondonk, the proposed line will have to cross the Kajara “bolong”. The vegetation within these areas includes white mangroves; it is likely that some parts of these habitats and vegetation will be affected by the line routing. Mangrove Vegetation

Mangrove forest dominates the fringes of the TWNP at Mandinari. The species found are the red mangrove (Rhizophora spp.), and the white mangrove (Avicennia sp.). There is also the salt tolerant species such as the bitter leaf (Vernonia colorata), the following woody species: i. The Wooded Savannah

Given that many parts of the earlier forests in WCR have given way to residential use and plantations and orchards, the typical wooded savannah (defined as having a canopy cover of more than 40 percent and reaching a height greater than 8m) has reduced along most of the proposed corridors. The dominant species found within the corridors are the African locust beans (Parkia biglobosa), and the rose wood (Pterocarpus erinaceus). Shrubby species found include the bush willows (Combretum

xiv nigricans), and the Chinese date (Ziziphus mauritiana), and the fruit locally called ditakh (Detarium senegalensis). Other forest trees along the corridors include the baobab (Adansonia digitata), which is planted for its shade as well as for food; its fruits are eaten and have certain uses as medicine; its leaves are used as vegetables, for sauces; its bark can be used as rope for tethering cattle. ii. Fruit trees Fruit trees are planted along the proposed line trajectories outside private compounds aligning the road corridors, or within compounds, or are planted as orchards and fenced and well protected from stray animals. Typically, mangos and cashew trees are the main fruit trees that will be potentially impacted by the lines because they are planted along many of the proposed corridors, including along the Shom-Omorto corridor.

These trees are important as a source of supplementary food for families, and in some instances, the fruits provide cash to the owners. Mangos also provide shade for family and individual relaxation. Thus, felling the trees by NAWEC’s contractors to make way for the lines could deprive these families of both food and income sources.

Wetlands Along the Corridors Wetlands in the Gambia are essentially three types; the marine and coastal types found mainly in shallow marine waters, estuarine waters, and intertidal mud flats; inland water type wetlands, which include permanent and seasonal rivers, riverine flood plains, freshwater marshes, seasonal freshwater lakes; artificial type wetlands which essentially are mainly irrigated land such as rice fields, etc. Parts of some of these water bodies serve as fishing areas for the local communities, cattle drinking and watering points, and the adjacent plains used for rice cultivation.

The Kandong “bolong” (tributary) in Foni Bintang Karanai, is about 52m wide at its crossing to the village of Kundunku and consists of three culverts. The proposed transmission line will cross the “bolong”, (wet and swampy ground). The construction of poles and lines within this area will have to use technologies that will protect the poles from collapsing over time due to saturation of the ground, and at the same time maintain the integrity of the ecosystem. The Fauna

The fauna along the various corridors are described below. Mammalian Fauna The mammalian fauna along the line corridors is generally influenced by the open forests, which are home to various invertebrates, reptiles and mammalian species, and includes primates such as the Patas monkey (Erythrocebus patas) and the Green vervet (Chlorocebus sabaceus), and the red colobus monkey, and the wart hog.

The Avifauna The list of bird species recorded within the various corridors, include Herons, Egrets, Ibises/spoonbills Vultures/Hawks/ Eagles, Sunbirds, Crows, Woodpeckers, Black billed wood-dove, Black-headed weaver, etc.

Socio-economic environment

Demography and Population The three Brikama feeders will supply 8 Districts consisting of 104 communities and 13,448 households. A total population of 120,430 persons (male population 60,295, and female population 60,135) will benefit from the Project. The women make up 49.9 percent of the beneficiary population.

Modes of Subsistence and Daily Chores in the Project’s Area of Influence The communities along the line corridors, to a large extent rely on agriculture and livestock for their subsistence. Like other parts of the country, agriculture is characterized by little diversification, and is mainly subsistence rain-fed, and semi-intensive cash crop production. Other economic activities carried out along the proposed corridor include, market gardening (mainly by women), petty trading and shop keeping, harvesting non-wood forest products; firewood collection; livestock rearing; and fishing

Potential environmental and social impacts and risks

 Potential impacts during pre-construction and construction phase

➢ Negative impacts on the biophysical environment During activities of the pre-construction phase, no potential positive impact is anticipated on the biophysical environment.

During the construction phase however, potential negative impacts on the biophysical environment will include: • impacts Relating to Geology and Soils; • air pollution; • noise and vibration nuisance; • unsightly landscape; • improper waste; • deforestation; • loss of Fruit Trees and other Vegetation; • negative impacts on fauna.

➢ Negative impacts on the human environment • involuntary resettlement and loss of livelihoods; • negligence of vulnerable groups and Gender-Based Violence (GBV); • risks to Public Health and Safety; • negative impacts from Violence Against Children (VAC); • risks to Occupational Health and Safety; • risks of Communicable Diseases; • community Instability and Reduced Cohesiveness (Including Impacts from Labor Influx); • impacts on sites of cultural and historical significance.

➢ Positive impacts on the biophysical environment There are no potential positive impacts of significance on the biophysical environment during the construction phase.

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➢ Positive impacts on the human environment • Creation of temporary jobs;

• Income generation;

• Improved community cohesiveness.

 Potential impacts during operation and maintenance phase

➢ Negative impacts on the biophysical environment • Effects of extreme weather affect applied loads and cause structural failure of various parts; • Impacts on landscape- waste from disused and worn-out materials such as poles, lines will create eyesores if not collected from the sites and managed properly; • Loss of Trees, especially fruit trees during pruning of trees; • Loss of fauna, especially monkeys on non-insulated cables amputating limbs;

• Large birds with wider wingspans (such as certain eagles, waterfowl, cranes, hawks, and vultures) may get electrocuted or killed in contact with lines during flight or resting on the lines.

➢ Negative impacts on the human environment • Risks to public health and safety where people come into contact with broken live lines during operation leading to electrocution or death;

• Occupational health and safety risks during all works, including operation and maintenance activities, workers are at risk of accidents from machinery, traffic, and illnesses. These include exposure of work crew to the risk of falling from heights during maintenance and repair of lines and accessing high trees during pruning;

• Negative impacts on public services particularly during connection to the main substation and pole-mounted transformers, when there will be temporary disruption of power services to existing customers.

➢ Positive impacts on the biophysical environment

• Impact on Climate Change is positive since source of power is renewable and thus no green hose gases produced. ➢ Positive impacts on the human environment • Employment generation;

• Enhanced economic development as a result of efficient energy supply;

• Improved livelihoods because of better services (education, health, communications, security and other social services that are largely dependent on electricity will be improved);

• Benefits to youth and vulnerable groups (with continuous electricity supply, youth could develop skills and trade to enhance their livelihood, e.g. welding, carpentry, or other small businesses that rely on electricity.

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 Potential impacts during decommissioning phase

➢ Negative impacts on the biophysical environment • Impacts of improper waste management may affect aesthetics, surface water, wildlife, livestock, and the public; • Air Pollution and local air quality deterioration due operation of heavy machinery, and vehicles releasing hydrocarbon and incomplete combustion gases to the air.

➢ Negative impacts on the human environment • Public health and safety risks; • Risks of communicable diseases due to influx of foreign workers; • Risks to occupational health and safety.

➢ Positive impacts on the biophysical environment • Improvement of landscape due to reclamation of quarries, camp sites, and removal of disused structures returning the landscape to original state or even better.

➢ Positive impacts on the human environment • Employment creation carrying out decommissioning activities; provide short-term employment for drivers, clearing workers, quarry restoration workers etc.

Management and impact mitigation measures

 Impact Management during the Pre-construction Phase

➢ Mitigation Measures of the Negative Impacts on the Biophysical Environment

• Mitigation of Impacts related to Geology and Soils: Any quarries for this Project must have clearance from the Geology Department (GD) and the NEA and will be based on a mining and reclamation plan;

• Mitigation of Air Pollution: Prohibit the public from work sites and avoid public places such as schools and markets. Provide personal protective gears for workers and use well maintained vehicles and machinery. Camps must also belocated at least 500m from the communitites;

• Mitigation of Noise and Vibration Nuisance: All preconstruction works must be carried out only during daytime and choose machines with less vibration effects;

• Mitigation of Unsightly Landscape: sites must be cleared of all preconstruction waste and stockpile of materials located in organized camps;

• Mitigation of Improper Waste Management: develop and implement a waste management plan;

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• Mitigation of Deforestation and the Loss of Fruit Trees: where trees must be fell or trimmed, develop and implement a RAP to assess the potential losses and required compensation for reforestation; relocate poles within the maximum span to avoid trees;

• Mitigation of Impacts on Fauna: Prohibit hunting by workers and educate on biodiversity conservation;

• Mitigation of Impacts on Wetlands: Integrate all mitigation measures into the design, including add-ons and evaluation of alternatives (routes, foundation types, pole designs, and cables).

➢ Mitigation Measures of the Potential Negative Impacts on the Human Environment

• Mitigation for Involuntary Resettlement and Loss of Livelihood: a RAP shall be developed and implemented for compensation of lost assets and livelihoods;

• Mitigation for the impacts on vulnerable groups: vulnerable groups will be included to ensure non-discriminatory benefit sharing;

• Mitigation for risks to public health and safety: use signage to prohibit access to worksite hazards and inform communities before works commence and throughout the implementation period;

• Mitigation of violence against children: employment of children prohibited, and implementation of the Codes of Conduct on Violence Against Children;

• Mitigation of Risks to Occupational Health and Safety: adopt and implement a health and safety program including accident and emergency response plans, training of workers, supervision, and provision of protection;

• Mitigation of Risks of Communicable Diseases: Limit worker importation and enforce Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children. Abide by national emergency regulations and the WB guidelines for protection against the Corona Virus;

• Mitigation for community instability: Initiate extensive consultations and sensitization with the communities;

• Mitigation of impacts on sites of cultural and historical significance: avoid all sites of cultural or historical significance including any buffer created for their protection;

 Potential Impact management during the construction phase

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➢ Mitigation Measures of the Potential Negative Impacts on the Biophysical Environment

• Mitigation of Surface Water Pollution: adjust pole spans to avoid water bodies and constant supervision to prevent waste dumping into water bodies;

• Mitigation of Impacts on Wetlands and Loss of Aquatic Ecosystems: promote regrowth of vegetation within wetlands by ensuring sites are returned to near original state;

• Mitigation of Noise and Vibration Nuisance: All construction activities must be carried out only during daytime and choose machines with less vibration effects;

• Mitigation of Unsightly Landscape: sites must be cleared of all construction waste and excess materials;

• Mitigation of Extreme Weather Impacts: Plan for pole erection during the dry season; train and supervise workers on response actions;

• Mitigation of Impacts related to the Importation of Workers: Limit importation of workers and use the Grievance Redress Mechanism (GRM) in case of complaints.

➢ Mitigation Measures of the Negative Impacts on the Human Environment

• Mitigation of Impacts related to Public Health and Safety: prohibit access of the public to work sites, materials, and equipment; use qualified workers, give prior notice to communities, avoid school and market days;

• Mitigation of Risks of Communicable Diseases: Limit worker importation and enforce Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence against Children. Abide by national emergency regulations and the WB guidelines for protection against the Corona Virus;

• Mitigation of Violence against Children: employment of children prohibited, and implementation of the Codes of Conduct on Violence against Children;

• Mitigation of Gender Based Violence: enforce the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC);

• Mitigation of Land Use Impacts and Loss of Livelihoods: no displacement causing loss of livelihoods should take place until PAPs have been fully compensated;

• Mitigation of Chance Finds Impacts: apply the Chance Find Procedures (avoid further disturbance and secure discovery, inform the relevant authorities);

• Mitigation of Risks from Force Majeure: abide by any national emergency regulations passed by the Government of The Gambia during such periods.

 Impact Management during the Operation and Maintenance Phase

➢ Mitigation Measures of the Negative Impacts on the Biophysical Environment

• Mitigation of effects of extreme weather conditions: routine inspection and maintenance shall reduce destruction of infrastructure during strong winds and heavy rainfall;

• Mitigation of Impacts on Landscape and Aesthetics: All waste must be collected and disposed according to law; consider alternatives to prevent unsightly wirescapes;

• Mitigation for Impacts on Trees: only trim branches within the Right of Way (ROW) and not during the fruiting season;

• Mitigation of Loss of Fauna: reproductive grounds, sanctuaries and migratory paths should be avoided, and alternative designs considered for the protection of the fauna.

➢ Mitigation Measures of the Negative Impacts on the Human Environment

• Mitigation of Risks to Public Health and Safety: public education on the safety of electricity infrastructure and prohibition from work sites during pruning;

• Mitigation of Impacts on Public Services: prior to connection of the new infrastructure, the public must be informed well in advance about disruptions to electricity services

 Impact Management during the Decommissioning Phase

➢ Mitigation Measures of the Negative Impacts on the Biophysical Environment

• Mitigation of Improper Waste Management: collect and dispose all waste according to law;

• Mitigation of Air Pollution: use protective gear and well serviced equipment and heavy vehicles. ➢ Mitigation Measures of the Negative Impacts on the Human Environment

• Mitigation for risks to public health and safety: use signage to prohibit access to worksite hazards and inform communities before decommissioning works;

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national emergency regulations and the WB guidelines for protection against the Corona Virus;

• Mitigation of violence against children: employment of children prohibited, and implementation of the Codes of Conduct on Violence against Children;

 Mitigation of Potential Cumulative Impacts

• Full implementation of the ESMP to include amongst others, working outside the farming season, avoiding forests and unrelated removal of vegetation, strategically locate poles, develop, and implement the C-ESMP, provide information and educate on health and safety. Future cumulative impacts may be mitigated by studies done and implemented at that time.

Strategic Environmental Assessment (SEA) of the Government’s and NAWEC’s wider plans and programs can contribute in coordinating similar projects or different projects in the same area with the aim of mitigating the cumulative impacts.

Stakeholder Consultations Stakeholders in all the Project areas were adequately sensitized on matters relating to the consultations with the communities, project background, processes, and procedures as well as the role of the communities and institutions during the implementation of the Project.

In general stakeholders, including potential PAPs, highly appreciated and welcomed the Project and highlighted the importance of electricity for the lives and livelihoods of the people, as well as the numerous benefits they will get from the availability of electricity. These benefits they maintained, would include their ability to preserve and store their different foodstuff, and enable them to engage in new revenue-earning businesses such as electricity-dependent professions like welding, that will raise their standard of living.

The opinions, concerns and fears of the populations and persons likely to be affected by the Project (PAPs) have been incorporated into the recommendations of this ESIA.

Risk and accident management

Based on the activities of the Project during all the phases, potential risks were identified, and their significance evaluated based on severity, probability, exposure levels and possibility of control. The following risks were identified with corresponding mitigation measures: • Sabotage; • Movement and circulation risks such as traffic accidents; • Noise nuisance; • Vibration risks; • Risks related to improper use and storage of equipment; • Fires and explosions; • Personal injuries such as cuts, struck by objects, stepping on objects, falls;

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• Risks related to ergometrics; poor manual handling etc.; • Respiratory risks; • Insecurity from burglary, threats, and personal attacks; • Contagious illnesses, ingestion of contaminated food or drink; • Risks related to unethical workers (Discriminating vulnerable PAPs, insensitivity to local norms, alcohol/drug abuse impacts etc.); • Wildlife attacks (reptiles, insects, and animals etc.); • Risks of work site conditions; • Work related stress.

Corresponding preventive and protective measures were then recommended for mitigation following the mitigation hierarchy from elimination, control, and reduction of the risks, to providing protection against the hazards. These include:

Developement and implementation of accident and emergecny response plans • Training; • Public information and awareness; • Constant supervision of workers; • Health and safety monitoring, reporting, and recording; • Limit exposure by reducing working hours; • Waste should never be burnt; follow waste management plan; • Use machines to assist in moving heavy and long loads; • Prohibit public access to work sites; • No work at night; • Provision of first aid kits; • Provision of protective gear.

Environmental and social management plan (ESMP)

The potential impacts and mitigation measures identified for all the various activities are further expanded in an ESMP matrix. For ease of reference during implementation, each mitigation activity is considered along: • responsibilities for its mitigation (contractor, Owner Engineer, NAWEC, PIU, communities etc.); • period of expected mitigation (before, during or after the specific Project activity); • responsibilities for monitoring (regional Technical Advisory Committees, NAWEC, NEA, PIU, Environmental Safeguards Specialist (ESS) and Social Safeguards Specialist, DoF, DPWM etc.); • required budget for mitigation to ensure resources are available in a timely manner:

Roles and responsibilities for ESMP implementation

Implementation of the ESMP is the responsibility of the Contractor and PIU. Most of the mitigation measures are the responsibility of the Contractor who will be carrying out the works according to the C-ESMP that will be based on the Project ESIA/ESMP.

The ECOWAS-REAP PIU will be responsible for overall follow-up, and to ensure that the ESIA/ESMP is fully implemented with the support of the PIU Environmental Safeguards Specialist (ESS) and Social Safeguards Specialists (SSS). Specifically, the ECOWAS-REAP PIU will include clauses in the Contractor’s agreements that will ensure compliance, and coordination with the GRM, among others.

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The supervising firm, Owner Engineer, will support the PIU in field supervision of all the contractors and their works. The Owner Engineer will also assist the PIU in bidding processes and verifies that contractors abide by clauses in the contracts.

The communities will also have the responsibility of ensuring that villagers avoid work sites, and report to NAWEC or relevant authorities, issues of concern related to the Project; the PIU and Contractor will engage the communities regularly as an oversight measure in this regard, and conduct sensitization sessions to ensure communities are aware of reporting measures and understand Project risks.

As the Secretariat of the EIA Working Group, and supported by its members, NEA will be responsible for the overall external monitoring of the ESMP implementation; in collaboration with the PIU ESS and SSS, they will monitor compliance with the Bank policies as they relate to the environmental aspects of this Project. In addition to the permanent members in the EIA Working Group, other institutions on ad hoc basis will include those specialized in social aspects such as the Women’s Bureau, Department of Social Welfare, Department of Labor, and Department of Health Services, amongst others.

Meanwhile, monitoring of the implementation of the social aspects of the Project in line with the Bank’s safeguards instruments will be the responsibility of the PIU SSS.

Overall estimated budget for the ESMP implementation is US $62,000, which includes capacity building; cost of implementation of the mitigation measures; regular environmental and social monitoring for compliance with the ESMP and with the relevant laws and policies.

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CHAPTER 1: INTRODUCTION This Chapter sets the background of the Project, its objectives, and beneficiaries. It further describes the rationale and objectives of the ESIA, in addition to the methodology used in carrying out the study. The various issues covered under the ESIA have also been outlined as presented in this report.

1.1 Project Background This report is the Environmental and Social Impact Assessment (ESIA) of the ECOWAS-Regional Electricity Access Project (REAP) three feeders that emanate from the Brikama Sub-Station under the OMVG Energy Project. The Project is part of a Series of Projects (SOP) being implemented within the ECOWAS region, with a long-term view to achieving electricity distribution expansion within the Region. Funded by the IDA/World Bank, the SOP aims to increase the number of people in West Africa with access to reliable and affordable electricity, as articulated in the ECOWAS White Paper of 2006 for Increasing Access to Energy Services to People of the Sub-region. The SOP consists of two Phases, which plan to provide 2.5 million people across six countries in West Africa, namely Guinea-Bissau, Niger, Mali, Senegal, Mauritanie and The Gambia with electricity. Phase I of the SOP is to provide access to 1.1 million people in Guinea-Bissau, Mali, and The Gambia. This Phase will finance the expansion of Medium Voltage (MV) and Low Voltage (LV) networks from the two high-voltage 225/33 kV substations (in Soma, Lower River Region–LRR, and in Brikama, in West Coast Region–WCR) being built under the OMVG1 Energy Project. It is expected that this will transform the power sectors of these countries and enable them to achieve their common objective of delivering more power to more consumers. The second Phase of the SOP will finance the reinforcement and extension of a similar distribution network (MV and LV) in Senegal, Niger, and Mauritanie, and within the context of the ECOWAS White Paper of 2006, additional member countries will be included later (potentially through additional financing). The participating countries will benefit from attracting larger contractors to ensure timely implementation, and furthermore, the regional approach facilitated by ECOWAS will be used to disseminate lessons learned from the World Bank’s global access experiences, which will be shared with participating countries to implement the access agenda. Specifically, the ESIA report consists of the following sections:

• Project description and scope; • Policies, legal and institutional framework; • Description of the current state of the environment of the project area; • Public consultations; • Analyses of potential impacts, enhancement and mitigation measures; • Management measures of the potential positive and negative impacts on the environment; • Management of risks and accidents; • Environmental and social management plan; • Conclusion; • Bibliography; • Appendices.

1 OMVG – “Organization pour la Mise en Valeur du Fleuve Gambie”, is the French acronym for Gambia River Basin Development Organization; OMVS – “Organisation pour la Mise en Valeur du Fleuve Sénégal is French acronym for Senegal River Basin Development Organization.

1.2 The Project Development Objective (PDO) The Project aims to increase grid electricity access in the six West African countries as indicated above, and specifically Phase I aims to substantially increase access to electricity to reach a rate of almost 65 percent, 25 percent, and 37 percent in Guinea Bissau, The Gambia and Mali respectively. The Project will reduce or eliminate the connection charges of these beneficiaries and will also deploy prepaid meters to enable beneficiaries to manage their own consumption without the risk of the physical disconnection process that can arise because of unpaid monthly bills. Thus, it is expected to have a transformative impact on the beneficiaries, both in the short-term and long-term. 1.3 Project Beneficiaries The Project’s beneficiaries will include households, small businesses, and public institutions (including local governments, schools, and health clinics), which will be connected to the electricity grid. The substation will connect communities that are up to 100km radius. Appendix 4.1 shows the communities to populations that will benefit from the Brikama feeders. 1.4 Rationale of the Project An ESIA should be performed because it is a requirement of the National Environment Management Act, (NEMA) of 1994, the EIA Guidelines and Procedures (1999), and the EIA Regulations (2014), which require impact assessment studies to be conducted prior to development activities that are likely to have adverse environmental and social impacts. The ECOWAS REAP, The Gambia, falls under Schedule A of the NEMA; “Projects to be considered for EIA, including electrical infrastructure such as “electrical transmission lines” and “electrical substations”.

To start the ESIA process in The Gambia, the Project proponent should complete and submit a screening form to the relevant authority, the National Environment Agency (NEA). Following the screening process, Terms of Reference (TOR) for the ESIA study is then developed by the NEA with support from the EIA Working Group. This Project was not screened by the NEA and the TOR was developed by the RCU through the ECOWAS-REAP PIU. Notwithstanding, the NEA was consulted during the course of the study. Since the IDA/World Bank is financing this Project, it becomes imperative that an ESIA is carried out; according to the Operational Policy (OP 4.01), the Bank requires environmental assessment of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable.

1.5 Objectives of this ESIA Study The overall objective of this ESIA study is to ensure that environmental considerations of The Gambia ECOWAS-REAP are considered during decision making for environmental sustainability. Specific objectives of the ESIA are to:

- identify, evaluate, and mitigate potential environmental and social risks and impacts of the proposed Project activities - examine ways to prevent, minimize, mitigate, or offset/compensate for adverse environmental and social impacts, and to enhance positive impacts describe the baseline conditions for future reference - provide platforms for public consultation and participation regarding the Project - maintain credibility of the Project developers and funders

1.6 Consultant Responsible for this Study This ESIA was carried out by Sustainable Developemnt Focus Ltd., a Gambian registered consultancy firm specialised in environment and natural resources management.

1.7 Methodological Approach for the ESIA The following approach was used to develop this report:

a) Literature Review This consisted of the review of relevant national polices and legislation, World Bank Operational Policies, ECOWAS Environmental Policy, 2008, the ECOWAS-REAP Project Appraisal Document (PAD), relevant international conventions and treaties to which The Gambia is a Party, among others.

The legislation and policies reviewed have guided the ESIA study to identify the legal scope of the process and ensure that issues highlighted are given due consideration during the study. For example, policies have described areas to protect such as historical sites, and gazetted forest. Therefore, special attention was given during the study to watch out for such sites and assess the necessary issues.

The reviewed legislation also highlighted areas to consider during the study, such as the need for community consultation; the need to ensure that women are included, and that compensation will be required for involuntary resettlement and loss of livelihood as a result of the Project.

The identified WB Policies that have been triggered by this Project also have assisted in identifying specific issues to consider during the study.

Although the Project’s Detailed Engineering Study report was not available to identify the exact Project sites, the ECOWAS-REAP Project Appraisal Document, the Study for the Project of Electricity Access from the Substations of Regional Project (OMVG and OMVS) in the Republic of Senegal, Guinea, Mali, Guinee Bissau and The Gambia, the ECOWAS-REAP Project Implementation Manual, the WAPP-REAP Environmental and Social Management Framework – Phase I, and the TOR for this study were reviewed. These Project documents provided the ESIA study with the information necessary to identify and evaluate the environmental impacts. These include the:

- physical scope of the Project in The Gambia and the list of proposed beneficiary villages as it is practically impossible to cover all villages within 100km of the Brikama Substation; - Project components, materials and activities that will cause the environmental change; - alternative sites, technology and design considered; - institutional arrangements for the Project implementation.

In addition to the above, an extensive review was carried out of data from a variety of sources, including a selection of features derived from appropriate secondary spatial datasets collected by different national sectoral institutions, maintained in a GIS database. See the full list of relevant documents reviewed in the Bibliography section.

b) Field Visits and Scoping Extensive field visits were carried out to potential Project communities within 100km radius of the two substations to validate the list of communities provided by the ToR. However, since the ToR did not provide a design of the proposed routings of the transmission lines, the Consultant’s consultation with the Project PIU and relevant staff of the National Water and Electricity Company (NAWEC) concluded that the ESIA will be used as the feasibility report to environmentally and socially design the best routes of the T&D lines. In this regard, the Consultant visited all the proposed Project corridors in the company of a senior engineer from NAWEC (with decision-making powers) and his team, to interact with the Consultant’s Engineer so that decisions for line routings will be confirmed on the spot, particularly given that the ESIA and ESMP is expected to be location-specific.

The visits provided the Consultant and the NAWEC team with the opportunity to analyze possible alternative transmission line routings, and possible construction methodologies in order to reduce the negative environmental and social impacts. The field visits also allowed the study to: - define, locate and precise the borders/limits of the Project areas of influence; - assess the current state of the environment; - identify the activities of residents likely to be affected by the Project; - assess the environmental sensitivity of the Project right-of-ways.

The ToR provided a list of communities proposed to benefit from the Project, but the list did not include a number of communities along some of the proposed corridors that are believed should have been obviously included, considering their respective locations along the proposed trajectories. For example, where a community located at the end of a proposed line corridor has been identified, some intermediary communities along the same trajectories were not included in the list supplied by the ToR.

Use of GIS to Support Corridor and Community Identification One of the aims of the field trips was to identify the communities that were left out, to address the above-mentioned shortcoming. In addition, GPS coordinates of routes and locations that were not evident on the maps provided by the OMVG studies were recorded wherever necessary, to update the list of proposed communities, and also to identify and digitize features such as roads that are missing in the spatial database.

The updated list of communities along the three Brikama feeders is provided in Appendix 4.1, and the maps showing the routes of the feeders are in Appendices2.1. This, effectively, defined the scope of the coverage of the Project in WCR.

Data Collection Data collection and analyses of supplementary primary data obtained from field surveys (using GPS technology) was carried out. In addition, existing secondary datasets (including topographic data, settlements data, forests, and protected areas, etc.) that are hosted by other national institutions were analyzed. These institutions included the Department of Lands and Surveys, Gambia Bureau of Statistics (GBOS), Department of Forestry (DOF), Department of Parks and Wildlife Management (DPWM), etc. Where a particular feature was encountered in the field, but does not exist in the appropriate sectoral database, the GPS coordinates of the feature were physically measured, digitized, and incorporated into a spatial database for the particular dataset.

Data Analyses The datasets were arranged into feature-based GIS layers that can be used as and when required for analyses, and/or presentation. For example, the settlements layer was used to extract and identify the Brikama substation, as well as all intervention villages. From this data, a spatial buffer of 100km radius was created around the substation’s location. This buffer was then “Intersected” and the resulting datasets “overlaid” with the settlements layer to analyze the location of all intervention villages as identified in the ToR.

Presentation The following datasets were used in both the analyses and/or the presentation of results:

i. Settlements

These included the proposed intervention villages, the Brikama substation, as well as other major towns/villages of significance to the Project. ii. Roads These comprised mainly the main roads (such as Brikama – Serekundanding-Kalaji, Mandinaba – Giboro Koto); feeder roads (Shom-Omorto), as well as earth roads/tracks/paths (such as Buram – Bulanjor, Buram – Katakor). This dataset is particularly significant because many of the MV lines in this Project will run along these roads. iii. International Boundaries This dataset identifies the scope and geographic limits of the analyses and hence the presentation of the results was based on this frame, i.e. the geographic limits of The Gambia. iv. National Parks The impact of the Project on National Parks was not evident in WCR; however, in other regions as in North Bank Region the impact of the project was studied by mapping out all possible influences the Project’s attributes and features have on forested areas. As stated earlier, this was achieved by analyses of data on National Parks, Settlements and Roads. v. Forests Like National Parks, the Project may also impact Forest Parks. As a result, data on Forests, Settlements and roads were analyzed. Based on the above, the GIS analyses presented in this report is a map of The Gambia (Figure 2.1) showing the following:

i. The substation in Brikama;

ii. All intervention villages/communities - maps of the line routes, and the communities that are located along the three Brikama feeders;

iii. Major water bodies that may be impacted by the Project;

iv. Other relevant physical features that may be impacted by the Project.

In addition to this map, other maps were created to highlight specific environmental and social issues and/analyses such as MV line corridors (see Appendices 2.1, maps of routes of the Brikama feeders.

c) Community Consultations During the field trips, consultations were undertaken using mainly unstructured methods; these included public meetings, focused group discussions, and individual (one-to-one) meetings. Refer to Chapter 5 for details.

d) Key Stakeholder Interviews and Consultations Consultations and interviews with relevant Government agencies were also conducted; these included NAWEC, the NEA, DPWM, DOF, National Roads Authority (NRA), and the National Council for Arts and Culture (NCAC). See Chapter 5 and Appendix 5.1 (Summary of Comments and Views from Consultations), and Appendix 5.2 (List of Persons and Institutions Met) for details.

CHAPTER 2: PROJECT DESCRIPTION AND SCOPE

This Chapter sets out to describe the ECOWAS-REAP, and to identify its potential sources of impacts; it aims to convey sufficient information and understanding of what the Project is about. The section focuses on the propsed location, technical description of the activities, the works input and output. Alternative sites and designs, and the ‘no project’ alternative are also analyzed to ensure the most environmentally friendly option is considered.

2.1 – Presentation of the Project Proponent The ECOWAS administrative structure was transformed from an Executive Secretariat to a Commission in 2007 in accordance with a decision taken in Niamey, Republic of Niger, in 2006. This change was necessitated by the need to enhance equity, transparency, and greater functionality in line with global best practice. This resulted in The Commission being in a better position to support ECOWAS member states to build their capacities for program implementation. Thus, establishment of the Commission together with the endorsement of institutional reforms covering all its structures, ECOWAS came to be in a better position to fulfil its mandates to meet and address emerging challenges. In this regard, the overall objectives of the Commission are geared towards improving the living conditions of its citizenry; ensure economic growth and creating an environment conducive to development and meaningful integration of member states.

The ECOWAS Commission, with its headquarters in Abuja Nigeria, coordinates all the activities of ECOWAS and comprises the following structures: Executive (headed by the Chairman of the Authority of Heads of State and Government); Legislative arm (comprising the Community Parliament headed by the Speaker) and the Judicial arm (comprising the Community Court headed by the President).

2.1.1 Objectives of the Commission The ECOWAS Bloc aims ‘to promote cooperation and integration leading to an economic union in West Africa with the sole intention of raising the standards of living of the its people, maintain and enhance the economic stability, foster relation among Members States and contribute to the progress and development of the African continent’; To achieve the above, the Community undertakes a number of measures including:

o ‘Harmonization and coordination of national policies and the promotion of integration of programs, projects, and activities particularly in agriculture, energy and natural resources, industry’; o Harmonization and coordination of policies for the protection of the environment; o The promotion and establishment of joint production enterprises; o Establishment of common markets ; o Establishment of an economic union through the adoption of common policies in the financial, economic, cultural and social sectors and the creation of a monetary union etc. (http://www.comm.ecowas.int/about-ecowas/objectives/);

2.1.2. Roles and Functions of the ECOWAS Commission The ECOWAS Commission performs the following tasks: designing, coordinating, and monitoring the regional integration process with professional competence, thereby helping the member states to improve their implementation of its policy decisions related to economics and trade, and peace and security.

2.1.3. Organizations of the Commission The Commission has 14 departments as listed below:

1. Agriculture, Environment and Water Resources; 2. Education, Science and Culture; 3. Energy and Mines; 4. Finance; 5. Financial Controller of ECOWAS Institutions; 6. General Administration and Conference; 7. Human Resources Management; 8. Industry and Private Sector Promotion; 9. Infrastructure; 10. Macro-Economic Policy and Economic Research; 11. Political Affairs Peace and Security; 12. Social Affairs and Gender; 13. Telecommunication and Information Technology; 14. Trade, Customs and Free Movement of Goods and Services.

The Department of Energy and Mines was created to ensure energy integration among ECOWAS member states over time and to harmonize exploitation of the community mineral resources. It was mandated to formulate and implement ECOWAS regional policies in the areas of energy and mines and in doing so, work closely with some agencies in selected member states, such as the West African Power Pool (WAPP), ECOWAS Centre for Renewable Energy and Energy Efficiency (ECREEE) and the ECOWAS Electricity Regulatory Authority (ERERA).

2.2 - Location of Project Sites

In addition to the WCR, the Project will be implemented in three other Regions in The Gambia as follows:

Part of the West Coast Region (WCR); The whole of the North Bank Region (NBR); The whole of the Lower River Region (LRR); The whole of the Central River Region (CRR North and South).

2.2.1 Brief Description of OMVG Brikama Sub-station Site and Related Feeders The OMVG Sub-station in Brikama is located at the Brikama power plant, which is on the industrial north-western side of Brikama, the administrative headquarters of the WCR; it is the biggest of the five Regional Administrative Regions in the country. The three (3) feeders will run across the entire length of the Region down to the south towards the border with Senegal, and to the east up to Kalaji, and to the north down to Mandinary in Kombo North; for example, Feeder 1 will connect the communities of Bafuloto, Mandinari, Kubuneh, etc.; Feeder 2 will connect communities including Kembujeh, Serekundaring, Tubakuta, etc.; Feeder 3 will connect localities along the main highway including villages such as Mandinaba, Kuloro (Tungina), Amdalai, Faraba Sutu, Sibanor, Bwiam, Kalaji, etc. The Project areas are shown in Figure 2.1.

Figure 2.1: ECOWAS-REAP Brikama Substation Feeder Line Corridors

Appendix 4.1 indicates the list of the communities along the three feeders, and Appendices 2.1 provide the maps indicating the routing of the three feeders. Specific corridors per feeder are listed in Appendix 4.3.

2.3 Technical Consistency of the Works

In The Gambia, the geographical extent of the Project covers a maximum of 100km radius from the OMVG Energy Project’s substation in Brikama. Specifically, the scope of the works will include:

• construction of 33/30 kV Medium Voltage (MV) lines; • construction of distribution substations of 33/30 kV / 400 Volts (V); • construction of 400 V Low Voltage (LV) lines; • supply and installation of last-mile connection equipment, including service drops, prepaid meter, and ready boards for LV customers.

2.3.1 Construction of 33/30 kV Medium Voltage (MV) Lines The MV lines will be designed to meet the required mechanical strength and resistivity on environmental impact such as salt, fog, and bushfires. The activities for this scope include, but not limited to the following:

i. Erecting MV (33 KV & 30kV) overhead lines support structures using hot dipped galvanized steel poles. The MV will be constructed using 12m high poles with an average span of 100m between support structures, and up to 150m span in wetland areas with pole structures of up to 15m in height

The MV lines will achieve a minimum sag clearance of 6m from the ground, and will be constructed within a corridor width of 6m

ii. The sheet-arch form of cross arm, Napoute type (NV2), will be used for the suspension lines. Dead-end cross arms will be used in dead-end angles. The H-type pole construction will be used at tee-offs with poles 1.5m to 2m apart; these H-type structures will be installed at least every 1.5km to 2km along the corridor to ensure line strength as per standards

iii. The MV pole foundations will be 1.5x1.5m and 2m deep standard gravel (washed stone) or basalt is appropriate for such. Foundations in wetland areas should be of marine grade type to ensure longevity of the pole foundations and structures

iv. Bare conductors of aluminium alloy studded conductors of up to 150mm2 and 70mm2 will be used for main lines and tee-offs, respectively. The stringing of conductors will be done using conventional methods; conductors will be pulled and tensioned on guyed structures, pulleys installed on the poles, and conductors in drums rolled through the pulleys and tensioned using special equipment such as ‘come-along tongues’

v. Insulators for the MV lines are of the composite type of string designed for both intermediate/suspension poles and for angles and dead poles. The insulators are up to 36kV insulation level and operated effectively with the service voltages of 33kV and 30kV. These insulators must always withstand harsh environmental conditions

2.3.2 Construction of distribution substations of 33/30 kV / 400 Volts (V) Transformer sub-station requires the installation of the following:

i. Installation of transformers (25kVAa, 50kVA or 100kVA, etc.). They will be positioned at load centers and function as substations to step down the voltage from 33kV or 30kV to 400V and 240V to supply electricity to consumers. The transformer is made of steel tank with copper coils immersed in mineral oil contained within the tank (the oils do not contain polychlorinated biphenyl, PCBs);

ii. H-pole transformer mounting frame structure and the necessary supports;

iii. MV fuse cut-out assembly will be installed above the transformer for both protection of the transformer, and safe operations at the transformer substation;

iv. Surge arrestors sets of up to 36kV insulation levels will be installed on the line at the substation for protection against lighting surges and other electrical network system disturbances. The arrestors are bridged on the lines accordingly and earthed to the ground together with the transformer body;

v. A low voltage distribution feeder pillar unit will be installed below the transformer. This comes with a busbar system controlled by a main breaker. The unit will contain several other breakers or fuse carriers for individual customer feeder lines/circuits.

2.3.3 Construction of 400 V Low Voltage (LV) lines The construction of LV lines will consist the following;

i. the overhead LV lines support structure will be constructed using 9m hot dip galvanized steel poles. The poles will have maximum span of 45m with a conductor sag clearance of at least 6m from the ground;

ii. the LV pole foundations will be 0.5x0.5m and buried one (1) meter deep, using gravel (washed stone) or basalt for the foundation works;

iii. the Aerial Bundle conductors (twisted cable) of the required standards will be used for the distribution. The main lines will be 3x70+54.6mm2+1x6mm2 and the tee-offs (branches) will be 3x50mm2+54.6mm2+1x16mm2 or 3x35mm2+54.6mm2+1x16mm2.

The stringing will be done using conventional methods and conductors will be pulled and tensioned on guyed structures using pulleys and ‘come- along tongues’, cranes, etc.

2.3.4 Supply and Installation of Last-mile Connection Equipment, including Service Drops, Prepaid Meters, and Ready Boards for LV customers

Key among the equipment and activities are:

i. Pre-paid type meters (cash power) that must be Standard Transfer Specification (STS) compliant, operating on both 3phase (400V) and single phase (240V). The majority of the meters will be single-phase meters and some 3-phase type;

30 ii. casing boxes (cabins) usually fireproof, or sometimes boarded or fitted on a plywood sheet; Protective fuses and load circuit breakers are also assembled at the same time; iii. 10mm copper cable conductors or aerial bundle conductors 1x16mm2 for single-phase and 4x16mm2 for 3-phase.

CHAPTER 4: DESCRIPTION OF THE CURRENT STATE OF THE ENVIRONMENT OF THE PROJECT AREA

This Chapter describes the geographic and administrative location of the Project area. It outlines the delimitation of the study area highlighting the direct and indirect areas of interest of the Project within WCR and the Districts where the Project sites are located. Within these areas, the general and specific baseline environmental and social conditions are discussed covering among other issues, the biophysical as well as the human and socio-economic environments of the study areas.

4.1 Geographic and administrative location of the project area The Project will be located within the Brikama administrative area in WCR, and the feeders will the communities listed in the Districts indicated and Table 4.1 below. Figure 4.1 below provide the Project’s area of influence in WCR.

Table 4.1: Project Affected Districts

Sub-Station Districts Covered Connected By Feeder No: Brikama Kombo North 1 Kombo Central/Kombo East 2 Kombo East; Foni Brefet; Foni Bintang 3 Karanai; Foni Kansala; Foni Bondali; Foni Jarol Source: SD Focus Ltd., 2020

4.2 Delimitation of the Study Area This section describes the direct and indirect areas of interest of the Project, and the general environmental baseline conditions of the study area. Indirect area of influence is the WCR and Districts where the Project sites are located. The direct areas of influence (the exact sites of the Project implementation) are the 23 corridors where the lines will run through, including the distribution substations.

The delimitation of these two areas of influence was derived by a GIS analysis of the available data. Specifically, the identified project villages (direct areas of influence) were delimited by overlaying the 100km buffer created around the proposed sub-station in Brikama. The result of this analysis is indicated in Figure 4.1 showing the administrative location of the Project sites, which also highlights the Project’s indirect areas of influence.

Regarding the baseline conditions of the study area, it will be noted that, in general the conditions will not be very different from one corridor to the other, especially given the small size of the country; issues such as climate, relief, landform, forest and vegetation cover are for the most part similar. In this regard the description will be general in nature, but where an issue of critical environmental, social, and cultural significance is encountered along any corridor, it will be reviewed specifically, and addressed accordingly.

Figure 4.1: ECOWAS – REAP: Administrative Locations and Areas of Influence of Brikama Feeder Lines - Source: SD Focus Ltd., 2020

4.3 Current State of the Environment of the Indirect Areas of Influence

4.3.1 Biophysical Environment

I. The Physical Environment

i. Climatic Conditions The climate in the Gambia is of the Sudano-Sahelian type and is characterized by the occurrence of two distinct seasons: a hot rainy season from May/June to October, and a dry season from November to May with rare occurrence of rainfall in May. Rainfalls are typically heavy nationally, but the south- western part of the country records more rain than the eastern portion, as indicated in Table 4.2 below. July, August, and September are the highest rainfall months.

During the rainy season, south-westerly monsoon winds combined with heat from the continent, and because of the northward movement of the wind, give rise to the formation of thundery activities. These are usually accompanied by strong winds and heavy downpours, causing localized flooding and erosion, especially of edges of streams, culverts, and bridges located along some of the main road corridors. This is of vital importance in those proposed Project sites prone to erosion and flooding. Transmission poles erected in these types of environments can be impacted by this phenomenon.

Table 4.2: Recorded Annual Rainfall in Project Regions (mm) 2009-2018) Year/Region WCR LRR CRR-N CRR-S NBR Annual Mean 2009 1,418.7 999.4 1002.1 655.2 1,297. 1,074.6 8 2010 1,203 1194.1 998.8 867.2 1,134. 1,080 5 2011 881 634.4 846.3 689.4 533.8 717 2012 1,374.1 1558.1 901.8 922.4 1,515. 1,254.3 2 2013 1022.4 900.7 896 1,039. 788.2 929.4 8 2014 613.6 607.4 668.1 489.4 615.9 598.9 2015 1,253.5 984.1 668.5 797 1,140. 968.7 5 2016 822.2 1156.3 952.4 860.4 827 923.7 2017 868.1 930.6 696.6 813.3 943.9 850.5 2018 889.8 745.8 567.7 854.5 645.5 740.7 Regional mean 1,034.6 971.1 819.8 798. 8 944.2 Source: Department of Water Resources, 2019

In the dry season (during the months of December to April) north-easterly winds (the Hamattan) blow from the Sahara towards the western coast of Africa resulting in the presence of dust particles in the air, and general cloudless skies and dry air. Much sunshine is received all year round throughout the country. Monthly mean temperatures in the rainy season vary between 29oC and 32oC, and from 15oC to 23oC in the cooler dry season.

ii. Hydrology Surface Water The surface hydrology within the Project’s sphere of influence consists of the Tanbi Wetland National Park (TWNP) located at the mouth of the River Gambia, and occupying an area of approximately 6,000ha (of which mangroves make up 4,800ha). Whilst most of the Project area is out of the Park, settlements that border it to the south include the village of Mandinari, a potential ECOWAS-REAP site.

a) The Shallow Sand Aquifer (SSA) System The Shallow Sand Aquifer (SSA), found throughout the Gambia and much of Senegal, is tapped throughout the Gambia for water supply. This aquifer system from the MioPliocene age occurs at depths between 15 and 120m below ground level.

Within the Gambia, the SSA is subdivided into two, the Upper Phreatic Aquifer and the Lower Semi- confined Aquifer. The two are separated by a clay-silt aquitard. The SSA is composed in average of medium to coarse sand.

The Upper Phreatic Aquifer: All hand-dug wells and some shallow boreholes along the proposed corridors feed from the Upper Phreatic Aquifer. This aquifer comprises mainly fine-to medium grained quartz sands with intercalations of silt and clay. The relatively thin aquifer (with a thickness of 1 to 20m) occurs at depths between 10 and 30m which is mostly the depths of local wells within the proposed Project sites.

The Lower Semi-confined Aquifer: The majority of boreholes (mostly provided by Government as portable water for the communities) in the various communities targeted by the Project tap this aquifer, which is constituted of mainly yellow-white fine- to medium-grained sands. The aquifer depth varies between 10 and 50m below ground level. The groundwater level is generally found at depth between 10 to 20m. Groundwater generally flows from South to North. The transmissivity values range from 100 m2/day to over 750 m2/day. The hydraulic conductivity ranges from 5 to 20 m/day.

b) The Deep Sandstone Aquifer (DSA) System The Deep Sandstone Aquifer (DSA), is constituted of Palaeocene and Maastrichtian sandstones; it underlies the whole of the Gambia and a large part of Senegal. It is confined by a 200m to 300m

11 thick sequence of mainly clays and marls. The groundwater in this aquifer moves from east to west; it is of fossil origin and 4,000 to 40,000 years old. This aquifer is tapped in most countries in the sub-region. However, it is not used for drinking water supply in the Gambia.

iii. Geology and Soils The geomorphology of the Gambia is dominated by the Gambia River, which divides the country into two strips of land no wider than 30 km. From the river outwards, there are three topographic regions: the valley bottom; dissected plateau with sand; a sandstone plateau.

The Valley Bottom

The valley bottom is the area immediately along the Gambia River and its tributaries and is characterized by poorly drained alluvial sediment formations. These areas are subjected to regular seasonal flooding. The combination of low-lying topography, poorly drained soils and abundant water provides unique and diverse habitats. The seasonally inundated swamps or Faro in Mandinka appear on either sides of the river for more than 2km away from the river.

The soils and vegetation in the valley bottom is primarily influenced by the hydrology; the soils are generally clay and alluvium and heavily impregnated with salt. This is because in the western part of the country, the river Gambia is mainly salty or brackish.

Dissected plateau with sandy hills

Upland, from the River, the country is dominated by dissected plateau with sand hills. This area is characterized by gentle rolling sand hills alternating with shallow valleys. In the coastal region, the soils are generally unconsolidated marine and aeoline sand with intermittent low-lying sand dunes. In central and eastern Gambia, the plateau is broken up by few flattop laterite sandy hills. The plateau is the center for groundnut (the country’s number one cash crop) and coarse-grains (millet and sorghum) production.

Sandstone Plateau

The eastern end of the country consists of low, rocky sandstone hills, which extend into Senegal. The hills (occupying about 4% of the total land area) are often unproductive rugged, uncultivated, and un- vegetated. The soils of this region are infertile but respond well to phosphate and nitrogen. Major crops in this area are groundnuts and millet.

iv. Topography and Land Use As in many parts of the Gambia, the topography in the Project’s area of influence is generally flat and low-lying with an approximate altitude range of between 12.2m to 51.2m GD.

Land use in most parts of the proposed project sites is a mixture of a few farmlands (cultivating mostly groundnut, and backyard plots for maize) and of mostly plantations and orchards (manly of mangos, oranges, and cashew). A number of well-established orchards of cashew and mango exist along, or close to some parts of the corridors. Vegetable gardening is common, usually practiced by mainly women. Gmelina plantations are common within the Region. Residential, commercial, and social amenities (such as schools) predominate the settlements through which the proposed transmission lines will run.

II. The Biological Environment

i. The Vegetation and Forest Resources The following vegetation types are found along the proposed line corridors: Riparian Vegetation A riparian vegetation or riparian woodland is a forested or wooded area of land adjacent to a body of water such as a river, stream, lake, marshland, estuary, or reservoir. This vegetation type is found along corridors with swampy and marshy environment such as the wetlands of the Tunjina and Kondonk. Specifically, to access the community of Kondonk, the proposed line will have to cross the Kajara “bolong”. The vegetation within these areas includes white mangroves; it is likely that some parts of these habitats and vegetation will be affected by the line routing. Mangrove Vegetation Mangrove forest dominates the fringes of the TWNP at Mandinari. The species found are the red mangrove (Rhizophora spp.), and the white mangrove (Avicennia sp.). There is also the salt tolerant species such as the bitter leaf (Vernonia colorata); the following woody species, as indicated in Table 4.3 are found within the mangrove belt. Table 4.3: The Mangrove Vegetation Along some of Proposed Corridors Scientific Name Common Name Source of identification During Reported by Bibliographic field visit Locals/DPWM Research Rhizophora harissionii Red mangrove X X Laguncularia racemose White mangrove X x Avicennia nitida Black mangrove X X Conocarpus erectus Button mangrove X X Vernonia colorata Bitter leaf X X x Source: DPWM, 2019 The Wooded Savannah Given that many parts of the earlier forests in WCR have given way to residential use and plantations and orchards, the typical wooded savannah (defined as having a canopy cover of more than 40 percent and reaching a height greater than 8m) has reduced along most of the proposed corridors. The dominant species found within the corridors are the African locust beans (Parkia biglobosa), and the rose wood (Pterocarpus erinaceus). Shrubby species found include the bush willows (Combretum nigricans), and the Chinese date (Ziziphus mauritiana), and the fruit locally called ditakh (Detarium senegalensis). See Table 4.4 below. Other forest trees along the corridors include the baobab (Adansonia digitata), which is planted for its shade as well as for food; its fruits are eaten and have certain uses as medicine; its leaves are used as vegetables, for sauces; its bark can be used as rope for tethering cattle.

Table 4.4: Vegetation Found in Wooded Savannah along the Project Corridors Scientific Name Common Name Source of identification During Reported by Bibliographic field visit Locals/DPWM Research Parkia biglobosa African locust beans X X Pterocarpus erinaceus Rose wood X X Ziziphus mauritiana Chinese date X X Adansonia digitate Baobab X X Detarium senegalensis ditax, ditakh, detar, tallow X Combretum nigricans Bush willows x Source: Adapted from NNP Management Plan, 2020

Fruit Trees Fruit trees are planted along the proposed line trajectories outside private compounds aligning the road corridors, or within compounds, or are planted as orchards and fenced and well protected from stray animals. Typically, mangos and cashew trees are the main fruit trees that will be potentially impacted by the lines because they are planted along many of the proposed corridors, including along the Shom-Omorto corridor.

These trees (see Table 4.5) are important as a source of supplementary food for families, and in some instances, the fruits provide cash to the owners. Mangos also provide shade for family and individual relaxation. Thus, felling the trees by NAWEC’s contractors to make way for the lines could deprive these families of both food and income sources.

Table 4.5: Fruit Trees along the Corridors Scientific Name Common English Name Source of identification During Reported by Bibliographic site visit Locals/DPWM Research Mangifera indica, Mango x X Adansonia digitate Baobab x X Anacardium Cashew x X occidentale Source: SD Focus Ltd., 2020 Others fruit trees include the baobab (Adansonia digitata), which is planted for its shade as well as for food, its fruits are eaten and have certain uses as medicine, and women make drinks from it for supplementary income; its leaves are used as vegetables, for sauces; its bark can be used as rope for tethering cattle. In the country, many trees along existing transmission line corridors (including those located within natural forests) are usually affected by NAWEC transmission lines. They are pruned by NAWEC (especially before the rains) when the branches grow too close to the lines, rather than felling the whole tree. This practice is repeated periodically as the trees regenerate new branches that threaten the lines. It is not uncommon also that whole trees are felled to make way for transmission lines, and this could include both private fruit trees and forest trees located along the trajectories of the lines. Contractors should ensure they fell only trees that need to be felled (e.g. if sited on a pylon location) and prune the rest. Private trees should not be impacted (pruned or felled) without the consent of the owners, and indeed where they must be impacted, a RAP should be developed to address any potential social impacts. By

14 the same token forest trees that need to be felled must be noted, and in consultation with the DOF a tree-replacement program developed; after all, the loss of “green cover” and loss of carbon capture footprint as a result of the felling needs to be managed. ii. Wetlands Along the Corridors Wetlands in the Gambia are essentially three types; the marine and coastal types found mainly in shallow marine waters, estuarine waters, and intertidal mud flats; inland water type wetlands, which include permanent and seasonal rivers, riverine flood plains, freshwater marshes, seasonal freshwater lakes; artificial type wetlands which essentially are mainly irrigated land such as rice fields, etc. Parts of some of these water bodies serve as fishing areas for the local communities, cattle drinking and watering points, and the adjacent plains used for rice cultivation.

The Kandong “bolong” (tributary) in Foni Bintang Karanai, is about 52m wide at its crossing to the village of Kundunku and consists of three culverts. The proposed transmission line will cross the “bolong”, (wet and swampy ground). (see Figure 4.2). The construction of poles and lines within this area will have to use technologies that will protect the poles from collapsing over time due to saturation of the ground, and at the same time maintain the integrity of the ecosystem.

Figure 4.2: Wetland along the proposed Kundunku line corridor - Source: SD Focus Ltd, 2020 For swampy or wetland areas within the Project area, poles higher than 12m with required standard characteristics are preferred to ensure enough clearance from ground, achieve lower pole spans say up to 150m thus reducing the number of poles to be erected within those wetlands. Sample of pole construction methods suited to these types of environments is indicated below in Figure 4.3.

Figure 4.3: Appropriate pole construction methods in wetlands - Source: SD Focus Ltd., April 2020 For more specification and mitigation measures in such circumstances, see Chapter 6 on the impacts on Wetlands. iii. The Fauna The fauna along the various corridors are described below. Mammalian Fauna The mammalian fauna along the numerous line corridors is generally influenced by the open forests, which are home to various invertebrates, reptiles and mammalian species. Table 4.6 lists the mammals found along the corridors. Among the primates is the Patas monkey (Erythrocebus patas) and the Green vervet (Chlorocebus sabaceus). The wart hog is also present in large numbers and is another pest especially for ground nut. Other mammalian fauna encountered include as listed in Table 4.6

Table 4.6: Mammalian fauna found along the ECOWAS-REAP corridors Scientific Name Common Name Source of identification During field Reported by Bibliographic visit Locals/DPWM Research Epomophrous gambianus Gambian fruit bat x x Cercopithecus aethiops Green vervet monkey X x Erythrocebus patas Patas monkey x x Colobus badius temmincki Red colobus monkey x x Heliosciurus gambianus Gambian sun squirrel X Euxerus erythropus Striped ground squirrel x Cricetomys gambianus Giant Gambian rat x Tragelaohus scriptus Warthog x x Source: SD Focus Ltd., April 2020

The Avifauna The list of bird species recorded within the various corridors, like the mammalian fauna, are influenced by the open forests. Table 4.7 below indicates the types that are found.

Table 4.7: Avifauna Found Along the Corridors and in WCR FAMILY Common Name Source of identification During Reported by Bibliographic Field Locals/DPWM Research Visit Ardeidae Herons/Egrets Tiger X X x heron Threskiornithidae Ibises/spoonbills X x Accipitridae: Eagles Vultures/Hawks/ X X Hawks/Vultures/ Eagles Nectatindae Sunbirds X Corvidae Crows X Picidae Woodpeckers X Columbidae Black billed wood-dove X Ploceidae Black-headed weaver X Ploceidae Black-necked weaver X SD Focus Ltd., April 2020

Reptiles Table 4.8 lists the reptiles recoded within the corridors. Table 4.8: Reptiles Found Along the Corridors Scientific Name Common Name Source of Identification During Reported by Bibliographic Field Locals/DPWM Research Visit Tarentola ephippiata Fig-tree gecko X Hemidactylus brokki angulatis House gecko X Agama agama Rainbow lizard X Chamaeleo senegalensis Senegal chameleon x Veranus niloticus Nile monitor X Matuya perotettii Red-flanked skink X Python sebae sebae Rock python X Python regius Royal python X Source: DPWM, 2019

2.4 Description of Activities by Project Phases

The work will be broken down into four (4) main phases: 2.4.1 Description of Construction Works of the 33/30 kV Medium Voltage (MV) lines

Phase 1: pre-construction phase Preliminary works: - work site installations or building of camps (office, water supply, toilets etc.);

- serving land/space for storage of materials and equipment;

- installation of road safety signs surface preparations;

- identification of the various existing networks in the corridors/right of ways (electricity, telecoms, water pipes sanitation etc.);

- identification of quarries for mining of gravel (wash stones);

- land clearing and preparation of corridors including access roads;

- transportation of equipment and tools to the sites;

- arrangements for residential/accommodations for professional staff;

- identification of water supply points for civil works and related activities;

- preliminary line surveys.

Phase 2: Construction and Installation of Equipment Preliminary activities: - final field survey detail engineering works for review and approval by client and consultant;

- pole spotting surveys;

- transportation of poles, cables cross arms, insulator, and other line hardware.

Physical works activities

- excavation of pole foundations;

- erection of poles fitted and dressed in the required cross arms and hardware fixtures;

- mounting of pulleys on the poles and related fixtures for stringing and conductor alignment;

- earthing cable connection to the poles (earth cable buried with the concrete)-

Testing and commissioning

- testing of the line with voltage through voltage injection or from the primary substation;

- switching of the line from source and observation of the performance of existing installation on the line;

- testing of the line continuity and insulation with meggering equipment and devices.

Phase 3: Equipment Operation and Maintenance

Operation and Maintenance: - Operational activities such as, switching arrangement planned and unplanned maintenances, installation of new equipment and demand-side management;

- trimming of trees, branches that have re-grown towards the conductors;

- periodic inspection and maintenance of fixture and hardware materials;

- periodic inspection and maintenance of civil works (pole foundations) in wetland areas;

- clearing sites of vegetation that have re-grown within the corridor.

Phase 4: Decommissioning It is anticipated that the distribution line facilities will be continuously maintained and repaired and will be operated for close to 30 years of design lifetime or more. Because of their long usable life, the circumstances under which they might ultimately be decommissioned are not foreseen at this stage. Thus, only general decommissioning approach will be considered. The process of decommissioning will involve the deconstruction of distribution lines (in reverse from construction) using similar equipment and techniques. Conductors will either be re-used or taken to steel/aluminium rolling mills for recycling; salvaged poles will either be re-used as fencing poles or taken to NEA approved disposal sites. Preliminary Decommissioning: - inspection of the lines to determine their status;

- preparation of temporal site for packing of dismantled materials before sending them to final disposal sites;

- identification of access roads within the corridors and to the temporal packing site;

- accommodation for professional staff and equipment operators during decommissioning activities.

Ground Activities: - dismantling of cables and rolling them in to bundles, or into used drums for easy transportation;

- removal of insulators and other hardware equipment and materials;

- dismantling of pole foundations and uprooting of poles;

- transportation of poles, cables, insulators, and hardware materials to temporal site;

- management of disused elements and the sites after dismantling of structures and facilities;

- re-vegetation of earlier deforested areas due to the Project;

- remediation of aesthetically unacceptable sites and removal of any stained soil;

- monitoring of contaminants, if any, or improper disposal or recycling of dismantled materials.

2.4.2 Description of Construction Works of the Distribution Sub-Stations

Phase 1: Pre-Construction Phase Preliminary: - Identification of load centers in the communities for placement or installation of distribution transformer stations. Such sites must be well drained, clear of overhead obstruction and not in hazardous areas.

Phase 2: Construction and Installation of Equipment

Physical works - installation of H-poles (2 poles) with transformer mounting H-frame between the poles;

- installation of cut-out MV fuses assembly, MV surge arrestors;

- mounting of transformers on the pole frames.

- monitoring of transformer contaminants to prevent leakage or improper disposal or recycling;

- installation of LV distribution boards below the transformer equipped with LV circuit breakers, busbars with LV breakers or fuse carriers for outgoing LV feeders/circuits;

- earthing of the entire sub-station with earthing material.

Testing and Commissioning Activities for the Substations

- Connection of transformer installation to the grid voltage;

- testing of input and output voltages of the transformer and LV distribution boards and feeders (50Hz) frequency;

- testing of earth resistance and possible improvement to the required levels;

- testing of the transformer insulation level with and without voltage.

Phase 3: Equipment Operations and Maintenance - Transformer routine inspection and maintenance such as oil leakages, cables, and fixtures;

- routine inspection and maintenance of other key substation fixtures such as surge arrestors, MV fuse cut-out, etc.;

- switching of LV board feeders for system operational activities such as load shedding, maintenance activities, tree trimming exercises and customer service connections if need be.

Phase 4: Decommissioning Even though decommissioning of such installation is not common in The Gambia, replacements after useful life of the transformer substation is possible, or were the transformer is overloaded and replaced with higher capacity as well as fixtures such as fuse cut-out current ratings. Thus, only general decommissioning approach has been considered. - Dismantling of sub-station fixtures on the MV lines such as surge arrestors and fuse cut-outs;

- dismantling of LV distribution boards and accessories;

- dismantling of transformer and support structures;

- transportation of materials to recycling facilities or to NEA approved waste sites.

2.4.3 Description of Construction Works of the 400V Low Voltage Lines

Phase 1: Pre-construction phase:

Preliminary - identification of LV line corridors within the communities;

- preliminary survey activities of the LV networks in the communities;

- details Surveys and engineering works by the Contractor for the LV lines for approval by the client and consultant.

Phase 2: Construction and Installation of Equipment - Pole spotting survey;

- pole excavations to the required depth;

- pole transportation and erection with the required concrete mixture;

- connection of LV line fixture such as clamps to the poles;

- connection of earth installations within the LV network as specified by the approved design;

- stringing with the use of cable stringing tools and equipment such as pulleys, ‘come-along tongues’, cranes, etc.;

- application of line anchors, line taps and other accessories where feasible;

- connection of LV lines to the LV distribution board feeder lines;

- numbering of poles according to feeder/circuit.

Testing and Commissioning Activities of the LV network

- Commissioning of LV lines with testing and measurement of voltage on several points of the LV lines (between phases and Neutral);

- verification of proper operation of other equipment such as streetlights. Testing of LV earthling systems and possible improvement;

Phase 3: Equipment Operation and Maintenance - periodic trimming of branches or trees that might dislocate the line from the pole;

- repairs of reported faults from customers;

- repairs and maintenance due to accidents by vehicles and damages from windstorms.

Phase 4: Decommissioning As mentioned in other sections, decommissioning of such installations are not common in The Gambia and are not foreseen. However, replacement of such installation during maintenance and upgrading works do occur. Thus, only general decommissioning approach has been considered, including: - Inspection of the LV line corridors and installation to establish the state of the installations and challenges such as access for equipment and material movement; - dismantling of LV cables and accessories packed in rolls or in used cable drums to be reused or sent to steel/aluminium rolling mills for recycling by scrap collecting companies; - disposal of salvaged poles, cables, and accessories at approved disposal facilities;

- remediation of aesthetically unacceptable portions of the site and removal of stained soil; - monitoring to prevent improper disposal or recycled salvaged material.

2.4.4 Description of the Supply and Installation Works of the Last-mile Connection Equipment, including Service Drops, Prepaid Meters, and Ready Boards for LV Customers

Phase 1: Pre-Construction Stage - Customer application and survey processes;

- payment of meter invoices, if required;

- allocation and commissioning of meters with customer details as well as relevant network data such as pole numbers next to the customer;

Phase 2: Construction and Installation of Equipment - installation of service poles or brackets by the customer at designated positions if required;

- boarding of meters in meter cabins or on plywood sheets;

- installation and testing input and output voltages of meters at customers’ premises;

- customer service points/offices for rendering services to the customers;

Phase 3: Equipment Operation and Maintenance - Repairs and maintenance of customer faults;

- inspection of installation to verify proper operation as well as electricity theft;

- monitoring and evaluation of customer commercial data to help enforce field inspections;

- recoveries for sub-charges and penalties of electricity theft.

Phase 4: Decommissioning of Equipment A general decommissioning approach has been considered to include: - Dismantling of service cables and fixtures;

- dismantling of meters from the premises;

- transportation to temporal recycling facilities or to approved waste disposal sites.

2.5 Works Input

2.5.1 Personnel Personnel is an important input for the efficient and timely implementation of all aspects of the project. Whilst unskilled workers may be hired directly from major settlements in the Project areas, skilled ones will unavoidably be imported from other parts of the country. The presence of these personnel will definitely generate impacts especially as they relate to the waste they will generate as well as health and social concerns they may bring along or engaged in.

2.5.2 Water For all the works in the Project, water will be required for activities such as mixing of aggregates. Water for such works will be sourced from pipe-borne water supply provided by NAWEC in many of the major settlements in the Project areas, stand-alone solar powered water supply systems, or hand pumps. All these sources of water can be used for construction works. In many instances, contractors use water tankers to transport water for use at construction sites and as well as store them in designated reservoirs. 2.5.3 Quarries Designated sand and gravel quarries are available in all the Regions of the Country. In some cases, these are located in relatively close proximity to the ECOWAS REAP sites. These will provide the gravel/stone for concrete and other works. However, for major foundation works such as in wetlands, it is common practice to use imported basalt, whose added advantage is strength and durability. However, the use of quarries needs to be well coordinated with the NEA, Department of Geology and Mines and the Regional and Land Administration Officials and the local communities due to increased awareness of customary rights of these resources and the attendant benefits that accrue from the exploitation. 2.5.4 Equipment - heavy equipment will be used during the works; these will include but not limited to: - bulldozer for land clearing; - excavator for digging foundation; - in some cases, contractor may need to create or improve an access road e.g. access road leading to a quarry and will need a compressor in that regard; - concrete mixers; - cranes for lifting, loading, and offloading of heavy equipment and project material; - trucks for transportation of materials and personnel. 2.6 Project Outputs Personnel will certainly generate both domestic and sanitary waste which will impact the environment. Imported personnel may potentially bring along deceases or transmit sexually transmitted infections such as Human Immune deficiency Virus/Acquired Immune Deficiency Syndrome (HIV/AIDS).

Water used in the Project will undoubtedly produce a certain amount of residual waste which can contaminate the topsoil especially when mixed with cement. In addition to this, such wastewater can impact water bodies close by, or the water table where it is not deep enough.

The operation of quarries equally has hugh impacts (gaping holes and ditches affecting tne aesthetics of the environment) and therefore their management and use need to be well coordinated with the NEA, the Department of Geology, and all other stakeholders.

The use of heavy equipment for land clearing and digging of foundations will affect trees and agricultural lands. Similarly, trucks for transportation of materials and personnel will affect access roads which may need to be created or improved for easy access to Project sites.

2.7 Assessment of Project Alternatives

According to the NAWEC Electricity Road Map, 2017-2021 national transmission capacity in power generation will be improved to eventually reach at least 80 percent of the country by 2021. However, in the face of resource constraints, it plans a gradual expansion of coverage, as resources become available, until it attains its ultimate objective of reaching universal access to electricity. It is in this regard that the ECOWAS-REAP has been launched to cover the selected 11 corridors in the 8 Districts

23 in WCR. The assessment of alternatives in project implementation in this report will look at the following:

1. Choice of Trajectory for Routing of Lines In view of the fact that the implementation of the Project will be along so many different corridors, and in as many different Districts, it will be impossible to detail out in this report the specific reason(s) as to why the routing of each transmission line should be located at a particular trajectory as opposed to another based on the degree of adverse environmental or social risks of proposed Project activities. Thus, the reason for the choice of routings or placement of transmission infrastructure along each corridor cannot be detailed here. Appendix 4.3, “Location-Specific Baseline Environmental Conditions”, indicates the routings for the different lines (whether to the right side of the road alignment or to the left). Thus, either side of the road provides a corridor for the lines and using this trajectory will reduce the environmental and social impacts of the Project.

However, where transmission infrastructure within the corridor is likely to encroach into virgin land and/or forest and vegetated areas, the selected routings will be behind these features. Along these trajectories, fewer trees are likely to be impacted, compared to what will be impacted along the corridor. In addition, where more communities are likely to be impacted along the corridors (many private properties are less than 5 meters from the edges of the various roads), the lines will be diverted behind the communities to reduce the social footprints of the Project.

2. Choice of design options for the transmission infrastructure The choice for the design of the transmission infrastructure in the Project is based, among other things, on the national experience and capacity of the staff of NAWEC, being more attuned to the existing types of transmission infrastructure. NAWEC technicians over time have become more knowledgeable on the technology and thus have developed dexterity in its use; the operational risks are fairly well understood. Given that the Project will be implemented in different types of environments, the following designs will be proposed for adoption at appropriate locations.

A. Preferred Type of Infrastructure Along the Feeders Along many of the corridors, numerous physical structures (including compound fences, dwelling houses, fruit trees, workshops, etc.) have been encountered, mostly built along the road alignment of the main transmission corridors. Particularly within built-up settlements, the approach that can be less damaging is double circuiting.

Typically, feeders 2 and 3 have been existing transmission corridors. Feeder 2 will run from the Brikama power plant down to Mandinaba, routed along the existing 33kV MV of Feeder 3. From here it branches to the right up to the border of town of Giboro koto.

Feeder 3 runs from the substation all the way to Kalagi. Since the MV line is in existence, the proposed ECOWAS-REAP will create mainly Tee-Offs: (MV line branch offs) (i) towards Giboro near the border; (ii) to Sohm; (iii) to Bintang; (iv) to Jifanga; and (v) Kanilai. Many communities within these MV lines have already been electrified. The recommended option along these corridors is to reconfigure and adjust the existing MV lines to allow double line construction for feeders 2 and 3. This configuration will start from Brikama power plant all the way to Mandinaba where the two (2) lines will separate; Feeder 2 branching to the right to be connected to the existing tee-off leading to the border town of Giboro.

The environmental advantages of double-circuiting on the existing line include the fact that:

• double circuiting leads to no new corridor. A new corridor from the Brikama plant to Mandinaba will be a big challenge leading to extensive social impact as the area is highly urbanized with lots of business activities. The land-use patterns have already adapted to the existing corridor; • magnetic fields may be reduced because new structure designs place line conductors closer together resulting in lower fields. Using corridor-sharing will minimize corridor requirements;

• no possible environmental impacts on human, fruit trees, forests etc.; • no resettlement of persons; it is cost effect, since no RAP for compensation; • cost saving since existing poles will be used, and existing conductors and insulators will be used for one of the circuits; • it has operational flexibility and opportunity to limit power outage to large areas during lengthy maintenance hours with the possibility of one circuit supplying the other; • it addresses the challenges of line routing from the plant due to many such feeder poles and lines within the Brikama plat/OMVG Sub-station; • recovered materials such as cross arms could be used for other electrification other works or system maintenance.

Some of the disadvantages will include:

• power outages to existing customers on the existing line during the line re-configuration works to double circuits;

• possible impacts of equipment on nearby buildings and residences such as

(i) damages to building structures during civil and electromechanical works on pole adjustments;

(ii) impact on installation and business structures on the line corridor during pole works and line stringing.

• Challenges of maintenance, if the double circuiting is not well designed and implemented, leading to switching both circuits for maintenance works on either circuits/feeders.

The “No Project” Alternative Under a “No Project” alternative scenario, the adverse environmental and social impacts from the Project will not occur, but at the same time the potential Project’s benefits will not accrue to the communities. For example, without continuous electricity supply in the selected communities, the youth would not be able to develop skills and trades such as welding, carpentry, or other small businesses that rely on electricity to enhance their livelihood. In addition, women would not be able to produce ice blocks and cold drinks made from locally available plants such as baobab, “wonjo”, which are few of the livelihood activities they wish to undertake.

However, the Project benefits are expected to outweigh potential adverse impacts, as discussed in Sections 6.3 to 6.6; the benefits will enhance the socio-economic development of the country, enhance access to electricity services to communities, improve livelihoods and enhance social development nationally.

Without this Project, school, health infrastructures the Government offices in these areas will be without enough or sustainable electricity which would help them to meet their objective to properly

25 serve the communities. The potential for small businesses to grow would never be realized without stable and sustainable electricity.

In conclusion, given the potential impacts posed by the Poject within the proposed sites, the positive and negative risks will be assessed in the subsequent chapters afer which relevant recommendations will be made to address the impacts.

CHAPTER 3: RELEVANT NATIONAL AND INTERNATIONAL POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK

This Chapter describes the various national and international policies, legal and institutional frameworks, as well as the World Bank and ECOWAS safeguard policies that will guide the development and implmentation of this ESIA and its ESMP. The relationships and relevance of these instruments viz-a-viz the Project are discussed.

3.1 Relevant National Policies Table 3.1 below indicates the relevant national policies (listed in order of date adopted) that will guide the development and implementation of the Project.

Table 3.1: Relevant National Policies

Policy Description Relevance to the Project National Policy for the Policy provides a legitimate Relevant to this Project since it Advancement of Gambian point of reference for addressing will benefit both men and Women and Girls (1999-2009) gender inequalities at all levels women equitably of government and all stakeholders National Youth Policy Policy aims to mainstream youth Successful project (2009–2018) issues into the advancement of implementation will all sectors encourage youth engagement in skills to reduce youth underemployment Gambia Environment Action Integrated environment and Provides guidance in general Plan, GEAP (2009-2018) natural resources management environmental planning and natural resources management Forestry Policy (2010-19) Promotes state and community Sixty-six gazetted forest parks forest development and are located in various parts of management the country, some of which could be impacted by the project Gambia National Gender & To mainstream gender in Women will be consulted Women Empowerment Policy national and sectoral planning widely and will be involved in (2010–2020) and programming to ensure the local monitoring and equity and equality evaluation process during project implementation The National Health Policy, Protects public and Relevant to this Project since 2012-2020 environmental health including dust, noise and other risks can nuisance and other risks be associated with the project associated with this Project activities National Energy Policy (2014 – Policy aims to increase All national electricity projects 2018) electricity coverage nationally are implemented within the context of this Policy

The National Biodiversity The NBSAP recognizes the Seven gazetted national parks Strategy and Action Plan conservation and sustainable and wildlife reserves are in (NBSAP), 2015 use of biodiversity various parts of the country that could be impacted by the Project. In addition, other ex- situ biological diversity could be impacted as well National Climate Change Policy Policy provides the framework Promotes energy efficient (2016 – 2025) for managing climate risks, options building institutions, capacities, and opportunities for climate- resilient development The National Elctricity Road Road Map plans to improve ECOWAS-REAP aims to Map 2017-2021 power generation and increase access to electricity transmission capacity NAWEC. throughout the Region

In addition, aims to increase absorption capacity for the expected increase in generation capacity, and to reduce transmission and distribution losses National Strategic Aims to ensure environmental Applies when developing Environmental Assessment sustainability policies, plans or programs in Policy (2017- 2021) all sectors, including energy National Development Plan Policy proposes to increase the Project is an eclectricity access (2018-2021) national coverage of electricity project National Transport Policy, Defines the priorities and NAWEC’s electricty projects (2018-2027) objectives in the transport usually follow national road sector, aimed to serve the alignments under the National country’s development goals Transport Policy

Source: Sustainable Development (SD) Focus Ltd, 2020

3.2 The National Legal Framework The legal framework that will guide the Project’s implementation are indicated in Table 3.2 below, listed in order of date enacted.

Table 3.2: The Legal Framework Relevant to the Project

Title of Act or Regulations Description Relevance to the Project Regulates land tenure and Land in some of parts of WCR property rights as well as general (Kombo East and the Foni) fall land administration in areas under Lands (Regions) Act, 1945 under this Act. Potential Customary Land Tenure system. project sites are held and Act covers all Provinces land administered under this Act. outside State Lands Areas. All lands in the Kombo North, Regulates land tenure and State Lands Act, 1990 Kombo South, and Kombo property rights as well as general Central fall under this Act.

Title of Act or Regulations Description Relevance to the Project land administration in State Lands Potential project sites in these areas. areas are held and administered under this Act Protects public and environmental health including Relevant to Project since dust, Public Health Act, 1990 abatement of nuisances and any noise and other risks can be condition that may be injurious to associated with the Project. health. Project might cause involuntary resettlement due to certain project activities Provides for consultation, Land Acquisition & such as tree felling, destruction resettlement, and compensation Compensation Act, 1990 of crops during line of land. construction, etc. and the Act could be used in resettlement as compensations. Ensures developments in The The project construction Physical Planning and Gambia are in line with land use activities shall be in line with Development Control Act, planning and construction national land use and planning 1991 standards. rules. Principal legislation in environmental management; Part This Project falls under National Environment V of Act provides for certain Schedule A which requires an Management Act, 1994 projects listed under Schedule A ESIA. to be considered for ESIA. Project implementation has Regulations declare standards set potential to generate dust, and Environmental Quality out in Schedule 1 in respect of to pollute surface fresh waters Standards Regulations 1999 ambient air, saline waters, surface as are found along some of the fresh waters and groundwater. project corridors. Act regulates the activities of The Gambia Public Utilities providers of certain public utilities NAWEC, the proponent of this Regulatory Authority Act, in the various economic sectors, project will be regulated by this 2001 including electricity, petroleum, Act. and gas. Project implementation has Regulations require that a permit potential to discharge is obtained for most discharges of Environmental Discharge potentially polluting liquids potentially polluting liquids into or (Permitting) Regulations into the tributaries and other onto the ground (i.e. to 2001 surface water bodies as may be groundwater) or into surface found with the project’s Area of waters (such as rivers or streams). Influence (AoL) Implementation of the Project Act makes provisions for will require the participation of decentralized administrative decentralized institutions Local Government Act, 2002 structures including devolution of including the Office of the functions, powers, and duties to Governors of WCR as well as its local authorities Advisory Committees (TACs). Gambia Roads Technical Act created the National Roads The transmission lines will be Services Authority Act, 2003 Authority to be responsible for the constructed along the Road

Title of Act or Regulations Description Relevance to the Project maintenance, construction, and Reserves of the national roads safety of the national road network network, and Road Reserves. This Act prescribes the institutional framework and requirements for managing these road reserves Although no protected Park is within the Project area, Provides for the establishment of biodiversity, outside the legally Biodiversity and Wildlife Act, protected areas for protection of protected parks are in the 2003 in-situ biodiversity; in addition to Project’s direct area of protect ex-situ biodiversity influence, and may also be affected Act empowers the Council to assume control and preserve, restore any monument, relic, National Council for Arts and Project activities could unearth ethnographical article, or other Culture Act, 2003 objects of historical relevance article of archaeological ethnographical, or historical relevance. Promotes the development of the As the main proponent of the electricity sub-sector on the basis project NAWEC and other Electricity Act, 2005 of the principles of a competitive electricity service providers are and market-oriented economy. regulated by this Act. Act sets out the rights and Rights of children impacted by responsibilities of children and The Children’s Act 2005 the project need to be provides for their care, protection, protected. and maintenance Pole construction, including Act makes provision for pole mounted substations, prospecting for minerals, for during project implementation Mines and quarries Act, 2005 carrying out mining and quarrying involves use of sand and gravel operations including gravel, sand, aggregates mined along the and for connected matters road corridor. Provides the legal framework for The project hiring and administration of labor, management of its labor force Labor Act (2007) recruitment and hiring of labor, should adhere to this and protection of wages framework Addresses waste management The project must ensure that Anti-littering Regulations, and pollution issues in relation to all waste produced during all 2007 environmental health and hygiene phases is well managed. Relevant to this project in view of potential impact on Aims to advance women’s rights agricultural land farmed by to land and natural resources in The Women’s Act 2010 women; need for adherence to order to promote their economic OP 4.12; avoid gender-based and social empowerment violence (GVB) and sexual exploitation and abuse (SEA)

Title of Act or Regulations Description Relevance to the Project The EIA Regulations elaborate on The Regulations provide more Environmental Impact the requirements for EIA details for the EIA of this Assessment Regulations, procedure, environmental impact project and implementation of 2014 statements, approval, its ESMP. environmental monitoring, etc. Sixty-six gazetted forest parks are located in different parts of the country, including proposed Project sites; some of these may potentially be Provides framework for affected by the Project. This implementation of Forestry ESIA recommends that all The Forest Act, 2018 Policy, and framework for the forest parks, including reservation and management of community forests be avoided forests. and where impossible alternative options and mitigation measures such as tree replanting will be employed This Act is relevant to the Project due to the need for Updates the law and procedures protection of vulnerable Sexual Offences Act, 2013 regarding the trial of rape, sexual persons within the Project sites offences, and related matters against sexual offences, which is defined in the Act Source: SD Focus Ltd., 2020

3.3 Relevant International Conventions and Agreements The most important of these international conventions and agreements to which Gambia is a Party that are relevant in this Project are as indicated in Table 3.3 below.

Table 3.3: Relevant Regional and International Conventions Signed/Ratified by The Gambia Date of Agreement/Convention signature / Objective Relevance to the Project Activities ratification This Project prepares for future Promotes energy capacity expansion to ECOWAS Energy Signed investment and accommodate regional projects Protocol A/P4/1/03 2003 trade in West Africa such as those of the OMVG, West African Power Pool (WAPP). The project activities will lead to the The CBD promotes vegetation destruction and the not only the United Nations stripping of soil (use of quarry for protection of flora Convention on Ratified the construction of works), burning and fauna, but Biological Diversity 1994 in preparation to install base camp, linkage with humans (CBD) poles, etc.). The project is and dependence on challenged by this convention. This such biodiversity for ESMP of this study has defined

Date of Agreement/Convention signature / Objective Relevance to the Project Activities ratification food, medicine, measures to rehabilitate degraded shelter etc. sites by the works to prevent the loss of biodiversity. The project activities will lead to the vegetation destruction and the stripping of soil (use of quarry for the construction of works), burning in preparation to install base camp, Protection of forests Convention to Combat Ratified to avoid poles, etc.). The project is Desertification (CCD) 1996 desertification challenged by this convention. This ESMP of this study has defined measures to rehabilitate degraded sites by the works to contain desertification.

United Nations (UN) Relates to all energy The loss of trees and vegetation will Framework Convention Ratified projects with mean loss of “green cover” and loss on Climate Change 1996 regards to of carbon capture footprint. (UNFCCC) sustainable sourcing Project has potential for resettlement as a result of project United Nations Convention ensures activities, especially on farmlands Convention on the the full development cultivated by women; the Elimination of all Forms and advancement of Convention highlights the right of of Discrimination women, for the women to own, manage, enjoy Against Women purpose of and dispose of property is central (CEDAW) and the Ratified guaranteeing them to their financial independence Optional Protocol to the 1993 the exercise and and may be critical to their ability Convention on the enjoyment of human to earn a livelihood and to provide Elimination of All Forms rights and adequate housing and nutrition of Discrimination fundamental for themselves and for their against Women (OP- freedoms on a basis children; women should have CEDAW) of equality with men access to benefits of this project as men. The rights in the treaty include the The project could potentially affect right to education, the right to health of the child UN convention on the Ratified the right to play, the through the generation of dust, and rights of the child, 1990 right to health and air pollution, poor waste (UNICEF1989) the right to respect management, and spread of malaria for privacy and due to stagnant water in quarry pits. family life The Convention Convention on the intends to protect Persons with disabilities could rights of persons with Ratified the rights and potentially be impacted negatively disabilities (CRPD) 2006 2013 dignity of people by the project activities

with disabilities; to

Date of Agreement/Convention signature / Objective Relevance to the Project Activities ratification promote, protect, and ensure the full enjoyment of human rights by people with disabilities Convention aims to The Convention identify and protect Concerning the Project implementation could the world’s natural Protection of the Ratified potentially impact natural or and cultural heritage World's Cultural and 1987 cultural sites such as graves, considered to be of Natural Heritage (1972) mosques, or other cultural relics outstanding

universal value Convention on Project will be implemented along Wetlands of Convention is aimed certain corridors that have wetland International Ratified at the conservation environments and ecology e.g. the Importance especially 1998 and sustainable use wetland around the TWNP declared as Waterfowl Habitat of wetlands a RAMSAR Site in 1986 by The (RAMSAR Convention) Gambia Government Also known as the Bonn Convention, aims to conserve Convention on Project will be implemented in the Signed terrestrial, aquatic, Migratory Species (CMS within areas that are flyways of 2001 and avian migratory Convention) migratory birds species throughout their range

Source: SD Focus Ltd., 2020

3.4 Institutional Analyses

NEA, supported by a multi-sectoral Environmental Impact Assessment (EIA) Working Group, is the custodian of the EIA process in the Gambia. It is in this capacity that it serves as the secretariate of the EIA Working Group which is composed of different public and private sector Institutions. All these Institutions are relevant in the implementation of this Project and by virtue of their respective sectoral mandates have some fair level of capacity in environmental management.

However, other Institutions such as the National Council for Arts and Cultur (NCAC), the Women’s Bureau and ihe Department of Social Welfare are also relevant in the implementation of the Project but are not members of the EIA Working Group. By their individual sectoral mandates, these Institutions have limited capacity and experience in environmental management and therefore would require some form of capacity enhancement.

3.5 Institutional Framework The institutional framework relevant to the implementation of this Project is as indicated in Table 3.4.

Table 3.4: Institutional Framework relevant to implementation of the Project

Institutions Specific Responsibilities Interests and roles in this Project Level of intervention implementation

National Environment The NEA enforces the NEMA,1994 and EIA Evaluation of the ESIA report; All phases of the Project from Agency (NEA) Regulations 2014 grant Environmental Approval for the Project; planning and design to the monitoring the ESMP implementation construction and operation Ministry of Environment, Oversees the NEA and implementation of Policy guidance; oversees the Department of All phases of the Project from Climate Change and environmental laws and policies of The Forestry and Department of Parks and Wildlife planning and design to the Natural Resources Gambia Management that are key to this Project construction and operation Ministry of Lands and Oversees all the local government the Ministry will support in the coordination of Pre-construction, construction, and Regional Administration authorities. Its regional representatives are involuntary settlement as it enforces all legal operation phases the TACs located in the offices of the regulations on land administration and land Regional Governors. use Offices of the Governors, Oversee the Regional Technical Advisory the TACs will support the implementation and Pre-construction and construction CRR, LRR, NBR Committees (TACs) for CRR, LRR, NBR monitoring processes of the Project at Regional phases levels Ministry of Health Responsible for overall formulation and providing guidance on transmissible diseases Pre-construction, construction, and direction of the national health agenda, to consider during sensitization operation phases planning and health infrastructural promoting safe and healthy environments at development projects sites responding to accidents National Water and As the implementing arm of the MOE, NAWEC is the executer of this Project in The All phases of the Project Electricity Company NAWEC is the main operator and manager Gambia (NAWEC) of electricity production in The Gambia coordinates and monitors the Project ESMP implementation through its PIU

Institutions Specific Responsibilities Interests and roles in this Project Level of intervention implementation

Department of Forestry Responsible for the maintenance and advises on forest boundaries relative to the Pre-construction, construction, and (DOF) development of forest resources in The Project sites operation phases Gambia. It recommends sites for forest implements forest restoration / replanting reserves and parks, community forests and plans where available private forests, and monitors their monitors encroachment of forests by the management for sustainability Project Department of Parks and DPWM is responsible for the maintenance advises on national parks and reserves that fall Pre-construction, construction, and Wildlife Management and development of National Parks and within the Project area of influence operation phases (DPWM) Reserves it is responsible for NNP, one of the major environmentally sensitive features to be potentially impacted by the Project National Roads Authority NRA is responsible for overall planning, protects the road reserves along the main Pre-construction and construction construction, maintenance, and highways and feeder roads that will phases management of the country's roads. accommodate the transmission infrastructure of the ECOWAS-REAP advises on future plans, and procedures for road development that may require relocation of the T & D infrastructure National Council for Arts The Council is responsible for the control, confirms sites of historical importance with the Pre-construction and construction and Culture (NCAC) preservation and restoration of any Project area of influence phases monument, relic, ethnographical article of prescribes the buffer outside which T & D historical relevance structures may be erected monitors encroachment Women’s Bureau Under the Ministry of Women, Children and ensures the rights women affected by the Pre-construction, construction, and Social Welfare, the Women’s Bureau Project are protected operation phases specifically promotes gender equity and participates in sensitization on gender issues women’s empowerment in The Gambia. Department of Social This government department protects and supports and guides the process during related Pre-construction, construction, and Welfare promotes the rights of vulnerable people grievances and participates in sensitization on operation phases such as children, women and the disabled. GBV, SEA, VAC etc.

Institutions Specific Responsibilities Interests and roles in this Project Level of intervention implementation

Department of Labour Enforces employment laws and combats Protection of employee rights; Pre-construction, construction, and child labour Protection against child labour; operation phases Response to complaints and reports such as accidents, abuse and discrimination at work

3.6 Relevant Bank Policies The following environmental and social safeguard policies of the World Bank have been triggered by the ECOWAS-REAP.

Table 3.5: World Bank Environmental and Social Safeguards Relevant to the Project

Operational Policy Applicability and relevance to Objective (OP) triggered the Project The objective of this policy is to ensure that projects financed by the Bank are viable and environmentally feasible. It covers the impacts on the physical environment (air, water, and land, etc.); the living environment, health, and OP 4.01 The project is challenged by this safety of populations; physical cultural Environmental policy because the planned resources; and environmental concerns Assessment activities are going to generate at cross-border and global level. (including public risks and negative Diffusion: OP 4.01 also describes the participation and environmental and social consultation and dissemination stakeholder impacts. Hence the need to requirements. For Category A and B engagement) carry out this ESIA. projects and sub-projects. This policy is triggered if a project is likely to cause risks and potential (negative) environmental impacts in its area of influence.

OP 4.04 Natural To support the protection, maintenance, Habitats and rehabilitation of natural habitats and their functions in its economic and There are swamps, wetlands, sector work, project financing, and and waterbodies along the policy dialogue. The Bank supports and Project corridor that are home expects borrowers to apply, a to various invertebrates, precautionary approach to natural mammalian, including avian resource management to ensure fauna opportunities for environmentally sustainable development. OP 4.11 Physical To assist countries to avoid or mitigate Cultural Resources adverse impacts on physical cultural resources from development projects that are financed by the WB. The impacts Cultural resources such as on physical cultural resources resulting mosques and cemeteries could from project activities, including be impacted by the poles and mitigating measures, may not transmission lines. contravene either the borrower’s national legislation, or its obligations under relevant international environmental treaties and agreements. OP 4.12 Involuntary The overall objectives are: The project has constraints as resettlement of “(a) Involuntary resettlement should be there is likelihood of social populations avoided where feasible, or minimized, impacts which may lead to involuntary resettlement due to

exploring all viable alternative project loss of economic trees, designs. agricultural crops, temporary (b) Where it is not feasible to avoid loss of earnings and loss of other resettlement, resettlement activities livelihood as a result of the should be conceived and executed as Project. Thus, this OP is sustainable development programs, triggered. providing sufficient investment resources to enable the persons displaced by the project to share in project benefits. Displaced persons should be meaningfully consulted and should have opportunities to participate in planning and implementing resettlement programs. (c) Displaced persons should be assisted in their efforts to improve their livelihoods and standards of living or at least to restore them, in real terms, to pre-displacement levels or to levels prevailing prior to the beginning of project implementation, whichever is higher OP 4.36 Forests “The objective of this policy is to assist borrowers to harness the potential of The Project is challenged by this forests to reduce poverty in a OP as there are Forest Parks, sustainable manner, integrate forests and Community Forests that effectively into sustainable economic may be affected by the development, and protect the vital local implementation and global environmental services and values of forests”.

3.7 Relevant ECOWAS Environmental and Social Safeguards triggered by the Project

Table 3.6 below presents the ECOWAS Safeguard policies triggered by the Project.

Table 3.6: ECOWAS Safeguard Policies Triggered by the Project

ECOWAS Environmental Applicability and relevance Objective Safeguards to the Project “To promote long-term cooperation in the energy field, The ECOWAS Energy based on complementarities Protocol is relevant to this and mutual benefits, with a ESIA as it states that energy ECOWAS Energy Protocol view to achieving increased projects must be evaluated (Protocol A/P4/1/03) investment in the energy and implemented for sector, and increased energy environmental trade in the West Africa sustainability. region” ECOWAS White Paper for To ensure increased use of Although the ECOWAS-REAP Increasing Access to Energy renewable energy sources focuses on transmission and Services, 2006 such as solar, wind, small-scale distribution, rather than

hydro, and bioenergy for grid electricity production, it is electricity supply and for the relevant to this Project as it provision of access to energy increases access to energy. services in rural areas. The energy to be transmitted is from renewable sources, To also assist the ECOWAS dams. Member States to develop appropriate regulatory frameworks for the promotion of renewable energy technologies and services, thus reinforcing regional integration in the renewable energy sector ECOWAS Environmental Policy To promote, guide and 2008 facilitate common This Policy is relevant to the understanding and approach ECOWAS-REAP as it applies within the ECOWAS Region for to all member countries, the control of land including The Gambia. The degradation, erosion, and Policy also aims to protect desertification; loss of natural resources which are biodiversity; degradation of likely to be impacted by the river and lake water resources; Project. and degradation of coastal maritime ecosystems.

In conclusion, it will be noted that the policy and regulatory framework specified above will guide the development and implementation of the report; sucessful project impmentation is based on the Project’s adherence to these requirements.

III. Human and Socio-economic Environment

i. Demography and Population

Table 4.9 is the summary of the demography of the communities that will be connected to the three feeders from the proposed Brikama substation; the feeders will supply 8 Districts consisting of 126 communities and 13,939 households with a total population of 125,215 persons (male population 62,720, and female population 62,495). This is sourced from SD Focus Ltd, 2020 with data from GBOS, 2019. See Appendix 4.1 for detail.

ii. Physical Structures

There are numerous physical structures (including compound fences, dwelling houses, welding, and carpentry workshops,) built along the road alignment of the main transmission corridors, particularly within built-up settlements.

Examples of such corridors include the Brikama-Mandinaba-Serekundanding. In general, distances between compound fences and the highways range between 4m and 10m. Thus in some communities such as the Mandinaba/Giboro junction, where the distance between the structures and the edge of

35 the highway is 3m, the transmission lines will be so close to the physical structures that they pose a threat to the safety of the inhabitants of such structures. The lines will directly impact on these physical developments. See Appendix 4.3

iii Schools and Other Infrastructure

Similarly, in certain communities’ social amenities such as schools and health posts/centers are located very close to the road alignment. In Besse, Foni Berefet St. Andrews Nursery School is a mere 2m from the edge of the road; besides, the school is only partly fenced with cement blocks, the most part left open, and unfenced. This can present health and safety risks to the children and staff of the school especially during pole construction and line stringing.

Table 4.9: Brikama Feeders 1- 3: Summary of Communities Along the Corridors Feeder # of # of # of Population # Districts Communities Households Male Female Total 1 2 7 4,499 18,531 18,314 36,845 2 2 8 1,777 9,052 8,571 17,623 3 7 111 7,663 32,712 33,250 65,962 126 13,939 62,720 62,495 125,215 Source: GBOS, 2019

The Brikama feeders will pass through communities as indicated below: • Feeder 1: Communities: From Brikama- Mandinari-Bafuloto; • Feeder 2: Communities: From Brikama – Kembujeh–Giboro koto; • Feeder 3: Communities: From Brikama- Mandinaba–Besse-Kalaji.

Generally, these corridors have a relatively high number of private structures, such as dwelling houses, stores, and other commercial buildings, and mango or cashew plantations. Specifically, the Brikama- Mandinaba and the Shom to Omorto corridors are heavily populated, and several cashew and mango plantations are located within short distances from the edge of the roads. Generally, the lines will have to follow the road alignments within these areas, because behind them, there is hardly space for construction of poles and lines that will not result in heavy impacts on private structures and properties.

iv Chance Finds and Cultural Heritage and Archaeology There are sensitive sites of cultural and historical significance along some of the proposed line corridors; these include mosques, graveyards, and other historical relics. There is always a possibility of finding objects of cultural heritage by chance, particularly during land clearing and preparation for works along corridors. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

Should any finds be uncovered, use Appendix 4.4 to address the issue, and meanwhile inform the NCAC to address it in a more professional manner.

v Disadvantaged and Vulnerable Groups Table 4.9 above presents the demography of the communities that will benefit from the Project; the women make up 49.5 percent of the beneficiaries along the Brikama feeders. Despite their numerical strength the women are generally often marginalized in the decision-making process as it relates to

36 the allocation of land. This is particularly relevant where they are engaged in agricultural activities; the impact of this marginalization is compounded by cultural norms and customs which tend to privilege men and boys over women and girls. In this regard land use and tenure rights tend to disfavor women as important decisions relating to land are made by the men, including inheritance, ownership, among others. Where women engage in vegetable gardening and cultivation of other cash crops along the corridors, their farms could very well be impacted in the same way as the men who are engaged in groundnut farming. However, given the male-dominated environment within these localities the adverse impacts would fall disproportionately on the women.

Therefore, given their social status, women would be considered a disadvantaged and vulnerable group in this Project. Project activities (such as construction of poles and line stringing) that are carried out within farmlands will result in impacts that will potentially affect women disproportionately to men, especially if works are carried out during the farming season.

In addition to women, other groups regarded as vulnerable and disadvantaged include the elderly and minors, and persons with disabilities. Like the women, these groups are more likely to be adversely affected by the Project impacts and/or more limited than others in their ability to take advantage of the Project’s benefits. For example, they may be unable to attend meetings for reasons due to their inability to reach the venues, and in this way will be excluded, and their voices and opinions may not therefore be considered. Thus, they could be excluded from, or unable to participate fully in the mainstream consultative process, and as such may require specific measures and/or assistance to do so.

To ensure that these groups are not left out in the process, special efforts should be made to meet and discuss with them, especially bearing in mind that some of them (especially women) will potentially be impacted negatively when it concerns resettlement benefits relating to damaged crops. In this regard, all necessary assistance and support to these groups of persons will be ensured in the implementation of this Project.

vi Gender and Gender-Based Violence (GBV) The majority of the poor and extremely poor in the Gambia is made up of the women who make up to 50 percent of the national population. In 2019, The Gambia was ranked 174th out of 189 countries with a score of 0.466, according to the UNDP Human Development Report’s Index ranking. According to the Gender Inequality Index2 (GII), 2016 Gambia was ranked 143rd with a value of 0.622; poverty of the women is closely linked with very low literacy levels (40 percent for women and 64 percent for men) and education attainment rates for a variety of reasons including cultural norms and physical access.

Women’s access to land remains largely based on customary law where the land belongs to founding families, and the user rights of in-married women depend on the continuation of their marriage within the family. Furthermore, women often lack access to credit for income-generating activities and generally have a limited role in the decision-making that affects their lives. This disadvantaged position of women in the family is deeply rooted in gender inequality, and it contributes to gender-based intimate partner violence.

2 The Gender Inequality Index (GII) reflects women’s disadvantage in three dimensions—reproductive health, empowerment and the labour market—for as many countries as data of reasonable quality allow. The index shows the loss in human development due to inequality between female and male achievements in these dimensions. It ranges from 0, which indicates that women and men fare equally, to 1, which indicates that women fare as poorly as possible in all measured dimensions.

As it does happen often, GBV can cause economic and psycho-social harm to an individual through for example, property damage and restriction of access to resources; by impacting the person’s personal health and safety, leading to social exclusion; and by fostering dependency on their partners for all material needs which can often perpetuate the cycle of violence.

Given the traditional and customary set-up in communal land use as noted above, in the event of resettlement for lost crop or economic trees in this Project, women could be impacted the most in accessing financial resources paid as compensation.

In view of the above, particular attention will be paid to the needs of those impacted, including women and children, those below the poverty line, the elderly, etc.

vii Violence Against Children (VAC) Violence Against Children (VAC) is defined as physical, sexual, emotional and/or psychological harm, neglect or negligent treatment of minor children (i.e. under the age of 18), including exposure to such harm,3 that results in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power. This includes using children for profit, labor4, sexual gratification, or some other personal or financial advantage. This also includes other activities such as using computers, mobile phones, video, and digital cameras or any other medium to exploit or harass children or to access child pornography. During the implementation of the Project, the potential areas where this can be manifested may include:

i. employing children under the age of 18 years ii. using children for personal or financial advantage by both contractors and employees iii. any other way to harass children, including sexual exploitation and physical or sexual violence

In this regard, the Project Implementation Unit (PIU) and Contractors must ensure that no aspects of the Project works involve children under the minimum age of 16 for light work (as per The Children’s Act, 2005), and none under the age of 18 for hazardous work and work that impacts their schooling and social or moral development.

The Labour Act, 2007 prohibits children under 18 from engaging in agricultural, industrial, or non- industrial work for economic gains. In addition, to strengthen and protect children against possible violence and exploitation, the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV) and Violence Against Children (VAC) must be rigorously applied and monitored for compliance. These Codes will be included in the Contractors ESMP (Appendix 6.1 includes the Codes of Conduct for addressing GBV and VAC).

viii Access of the Population to Education The children in the communities along the various corridors have access to education; there are schools of different levels ranging from Lower Basic to Senior Secondary Schools, Colleges, and a University.

3 Exposure to GBV is also considered VAC. 4 The employment of children must comply with all relevant national legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. They must also be able to meet the Project’s Occupational Health and Safety competency standards.

ix Access of the Population to Electricity, Telephone Services Many parts of the corridors have access to electricity supply from the NAWEC grid; on the other hand, most of the Fonis, away from the main road do not have access to the NAWEC grid. They have expressed appreciation for this Project that will make it possible for them to have electric power. Regarding telephone services, mobile network services are operational within the Project area. The four local mobile telephone companies extend facilities to almost all the communities proposed to be served by the ECOWAS-REAP. 4.4 Modes of Subsistence and Daily Chores in the Project’s Area of Influence

i. Agricultural Production The communities along the line corridors, to a large extent rely on agriculture and livestock for their subsistence. Like other parts of the country, agriculture within the Project area is characterized by little diversification, and is mainly subsistence rain-fed, and semi-intensive cash crop production.

Figure 4.4: Illustration of farm boundary away from the road - Source: SD Focus, April 2017

Farmers generally practice mixed farming, producing food crops comprising cereals (early millet, late millet, maize, sorghum, rice and “findo”), although cash crops (including groundnuts, and horticulture produce), account for a greater portion of the production. The cultivation of horticultural crops (vegetables and fruits) is also practiced but mainly by women farmers growing tomatoes, okra, sorrel, etc.

Along the main highways, in many cases farms are located very close to the road (see Figures 4.4 and 4.5) on the trajectory of the transmission lines, and thus maybe impacted by the Project, depending on the timing of the works; they may be affected, especially when project activities are carried out during the rainy season, when crops are in the fields. The above figures, although outside Project area are some examples of farms’ locations in relation to the roads.

Figure 4.5: Melon plantation (outside Project area) illustrating position of pole and farm clearance from the road and line corridor - Source: SD Focus April 2017

Table 4.10 shows the general agricultural calendar of activities common within the Project’s area of influence; it can be used as guide in the timing of construction works on the lines.

Table 4.10: Farming Calendar of Activities along the Transmission Line Corridors Activities Carried Out Month Men Women May Clearing of farmland Prepare rice fields, groundnut fields June Clearing farmland Prepare rice fields, groundnut fields July Planting late millet, maize, groundnut, Planting rice, groundnut cassava Aug Weeding and guarding crops Weeding and guarding rice/groundnut crops Sept Weeding and guarding crops Weeding and guarding rice/groundnut crops Oct Harvesting millet, maize, and groundnut Guarding rice, harvesting groundnut Nov Harvesting millet Guarding rice, threshing groundnut Dec Threshing groundnut Harvesting rice, threshing groundnut Jan No works in the fields Harvesting rice Feb No Works in the fields Dry season gardening Mar No works in the fields Dry season gardening Apr No works in the fields Dry season gardening Source: SD Focus April 2017

Using the above Table as guide, Contractors can minimize damage to crops along the corridors; pole construction and line stringing should be carried out after the crops have been harvested and there is less activity in the fields; where construction cannot be halted during the farming season, extra care and diligence must be taken to avoid or minimize damage to crops. In this regard a RAP should be prepared. ii. Market Gardening The womenfolk in the various communities engage in dry season market gardening. Hand dug wells are used for watering of tomatoes, pepper, cabbage, onions, and bitter tomatoes. Much of the

40 produce is sold at the local level raising a small income for the women involved, and the balance of the produce are consumed in the household thereby improving nutrition intake. A major outlet for bigger producers is the main Brikama market. iii. Marketing and Petty Trading and Shop keeping Along many of the corridors, marketing and petty trading is a daily chore, and both man and women are engaged in it. The women engage in dry season gardening, but most of them claim that they do not have a market locally.

At the end of the Brikama-Mandinaba corridor, at the junction to Giboro koto, Mr. Abdourahman Gaye operates a shack of a canteen made from corrugated iron sheets (measuring 3x3m). He sells various items including cigarettes, soft drinks, meat, and boiled beef. His facility sits right under the existing transmission line, and it is expected that the Project will T-off from this junction to connect the Mandinaba-Giboro corridor. His business will potentially be impacted when the works start.

iv. Tyre Repairing A tyre repair workshop is also located at the same area as Mr. Gaye’s business. His facility is made from corrugated iron sheets, and with his team of assistants, repairs tyres under the existing line as Mr. Gaye. He will also be impacted when the works start.

v. Harvesting Non-wood Forest Products The community members along the transmission corridors collect medicinal plants, herbs bark of trees, and wild fruits for personal consumption from adjacent forests; the fruits include the baobab (Adansonia digitata), commonly used as beverage, or juice. Other types of fruits of commercial value are the Chinese date, locally called “solom solom”, etc. The fruits are sometimes sold within the communities to supplement the household income.

It is common that contractors and other workers employed in projects located close to natural resources such as forests, national parks, water bodies, etc. harvest produce from these resources for their own personal use, take home to their families or even for sale. In view of this, the workers in this Project should be prevented from competing with the community members for these products. This will be included in the contractors C-ESMP. Given the local use of these forest products, it will be recommended that the plants and trees that bear them are not felled unnecessarily in the course of project implementation, because loss of access to these products would adversely impact the communities’ livelihoods and income support, culture and social norms.

vi. Firewood Collection All the communities along the line corridors are dependent on the vegetation and forest resources for the provision of firewood as fuel. These are collected from the forest for domestic, and possibly livelihood use. Along the Brikama feeders in communities where there is generally less forest cover, Project beneficiaries procure their cooking fuel from supplies brought from the Fonis where fuel wood and charcoal are relatively more abundant.

vii. Livestock Rearing Cattle are reared by the community members, allowed to range over the bush, and on crop residues after the harvest. Small ruminants are seen generally grazing close to villages and are corralled within compounds overnight, cattle are corralled by tying to stakes in areas peripheral to the villages. Poultry are raised at the household level, and draft animals (donkeys, horses, and mules) are also kept mainly for cultivation in the fields.

viii. Fishing This is another important economic activity within some of the villages. It is practiced mainly by men, primarily at the subsistence level mainly within the peripheral communities of the TWNP, and Kandong “bolong” in Foni Bintang Karanai. They employ mainly gill nets and fish traps on part-time basis. The catches are generally home consumed or bartered at the village level for other goods or services or sold at the main Brikama market. Women too are engaged in the harvesting of oysters, in the Mandinari “bolong” and sold at the major markets in Serekunda and Brikama. These activities are also primarily at subsistence level. 4.5 Description of Direct Influence Area and Location-Specific Baseline Conditions This section describes the location-specific baseline conditions; environmental and social issues (deemed to be of significance) encountered along the various proposed transmission corridors are assessed, and where necessary, recommendations on how to address them are made.

With a total number of 23 corridors from the substation, the assessment of each route was started from the start of the corridor. For example, having selected the side of the road to construct the poles (side of road selected based on the least environmental and social impact) the car’s trip meter was taken to zero. Driving on the road/path along the proposed trajectory of the transmission line, any receptor (whether environmental or social) of relevance was recorded at distance indicated on the car’s odometer.

Parameters of the receptor were noted, and the necessary action to address the potential impact recommended. The receptor could be a compound fence, dwelling house, a tree (whether forest tree or private fruit trees of significance), water body, market or loumo site, swamps, etc.). See Appendix 4.3 for details.

4.6Main Stakes and Risks of the Project The development and implementation of the Project will not be without risks. However, most of the risks are expected to be moderate, with a few risks being high. The project will not be an isolated process, it will be implemented through existing structures and experienced partners that have already implemented transmission and distribution projects funded by multilateral donor agencies such as the World Bank, thus benefiting from a learning curve that will support the PIU and its contractors with risk mitigation measures. Some of the risks include the following, and summarized in Table 4.12:

i. Political and Governance Political and governance risks are high. The Gambia is already facing risks of political instability, in spite of previous parliamentary elections confirming wide support for the current administration in the last couple of years. Signs of political fragmentation, including parties running separately in the next election, could worsen and derail the reform momentum. There are concerns relating to the impending Presidential elections in 2021, which may impede key preparatory activities such as the delivery of prerequisite studies and/or changes in leadership could lead to revised client objectives.

ii. Macroeconomic Macroeconomic risks are also high. The Gambia lacks a stable financial sector; this risk is considerable. The country’s financial sector is small and narrow, and the majority of bank assets are focused on the public sector, impacting credit to the private sector. Inadequate risk management capacity and

42 incomplete credit information on customers hinder the capacity of financial institutions to support the private sector.

The government seeks to mitigate this risk by lowering the economic governance of the public sector, and by promoting the development of the private sector as an engine of growth.

iii. The COVID-19 Pandemic The risks posed by the COVID-19 pandemic is high. The national emergency public health emergency measures in place creates considerable constrain on the economy. Lockdown measures including the closure of international border entry points for both land and air means the free movement of goods and service across the region, which constitute major sources of economic activities and income for the country have almost ceased.

iv. Project Design Risks This risk is medium. The ECOWAS-REAP is appropriately aligned to the Gambia’s priorities and previous lessons of engagement for the national energy sector. However, environmental, and technical constraints of the Project include the following:

• technically, the lack of Project site designs to identify the specific locations of the poles and corridors causes delay and uncertainties in making decisions, particularly prior to the feasibility studies;

• harmonization of activities of similar projects in the same area. For example, connecting the ECOWAS-REAP T & D infrastructure to existing grid infrastructure with different characteristics; • the T & D corridors cannot be as straight as technically desired as the built-up environments should be avoided, or compensation paid; • accessibility for construction and maintenance may be difficult in vast open fields, remote areas, and floodplains; during the rainy season when the fields are planted, heavy machinery and equipment used in construction will compact the ground making it prone to erosion; • the need for more resources where longer routes will have to be chosen to avoid densely built communities, and where villages are very away far from each other yet the distances between them must be included.

Despite the above, the proposal builds upon previous experience with the GESP, GERMP, etc., learning from several experiences that were not successful in terms of project design and delivery.

v. Fiduciary Risks in managing the fiduciary aspect of the Project is low. The PIU has successfully implemented the Gambia Electricity Support Project (GESP) and through this have gained significant experience and expertise in related project implementation matters. These experiences have been crucial in the implementation of the ongoing Gambia Electricity and Modernization Project (GERMP).

To mitigate this risk, the PIU will take the lead in ensuring that the RAP is communicated to government for compensation to commence in earnest to avoid project delay.

vi. Insufficient Institutional Capacity Risks of insufficient institutional capacity to implement the project are medium. NAWEC does not have the required human, financial, and physical resources to implement the Project effectively. The institution suffers from insufficient performance incentives. Such constraints pose risks to the implementation of ECOWAS-REAP.

To mitigate the risks, the Government is working with development partners to build implementation capacity in critical areas. Building on the previous GESP, and the current GERMP, the Project will support several capacity development initiatives at NAWEC. viiThe Social Risks The social risks of the Project are medium. The Project will create involuntary resettlement and loss of livelihood as a result of areas that cannot be avoided. In addition, there may be low participation of women and other vulnerable groups that need special attention to ensure inclusiveness.

Where resettlement is necessary, compensation of lost property must be made according to existing resettlement policies. However, during the process of determining eligibility and assessment of entitlement, potential disagreement regarding ownership of affected assets especially land may be encountered which, if not properly managed, can lead to Potential Land disputes especially between neighboring communities. This may occur mainly to the lack of physical demarcation of land borders as traditional land ownership still dominant.

To mitigate the risks of involvement of regional and land administration officials, community and traditional leaders in the process is crucial to curb the occurrences of these incidences. The Grievance Redress Mechanism (GRM)5 put in place by NAWEC at the PIU must be understood project affected people for them to utilize it when necessary.

Table 4.12: Main Stakes and Risks of the Project Risks Mitigation Measure Political and Governance Enforce existing legal instruments Macroeconomic shocks; Lower economic governance of the public sector, and promote development of private sector, COVID-19 Pandemic COVID-19 needs assessment, central coordination of responses, develop business continuity plan to prevent avoidable project interruptions caused by the pandemic. Protocole is attached. Project Design Risks Build upon previous experience with the GESP, GERMP, etc., learn from several experiences Fiduciary PIU to communicate with government for compensation to commence to avoid project delay Insufficient Institutional Capacity Government work with development partners to build implementation capacity in critical areas

5 GRM: Grievance Redress Mechanism is a process whereby complaints and grievance’s relating to the Project and emanating from members of the communities will be channelled and addressed in a fair manner. Operational modalities are indicated in Appendix 9.1 and Appendix 9.2

Environment and Climate Risks Use existing institutional coordination mechanisms of sectoral initiatives; strengthen climate change adaptation and mitigation in project design Social Risks Involve regional community and traditional leaders; use existing Redress Mechanism (GRM) at the PIU

The above description of the current baseline conditions of the Projects’ area of influence focuses on the resources and receptors that may be impacted by the project. It is clear that the interaction of the proposed activities and the resources and receptors will result in both environmental and social risks that would need to be addressed.

CHAPTER 5: PUBLIC CONSULTATION This chapter presents the approach that was taken in order to conduct stakeholder consultations in the process of developing the ESIA. It describes the process through which the stakeholders, among other things, shared local and indigenous information with the Consultant, and who, in turn listened to their views, with a view to ultimately empower them to initiate, manage and control their own self- development.

5.1 Objectives of the consultation The consultations were held with community stakeholders and government institutions aimed at achieving the following objectives:

i. discuss the Project with potential beneficiaries, highlighting its components, its routings, and the potential positive and negative impacts;

ii. provide information about the ECOWAS-REAP, and to acquire key social information, including schools, health, and other social facilities

iii. facilitate transparency and inclusive participation of community members in the project so they can voice their concerns and views regarding the project design and its project impacts, and to ask questions;

iv. highlight the potential roles and responsibilities of community members, during both the project design and implementation; this is important especially in the context of community-level monitoring of ESMP implementation, which is one way to enhance their participation and promote sustainability in the project;

v. understand community dynamics, relations, and the broader social and economic context of the communities and the possible impacts of this Project.

5.2 Methodological Approach The approach adopted in the process was guided by the following principles: Free: Engagement was free of external manipulation or coercion and intimidation

Prior: Engagement was undertaken in a timely way and prior to decisions being made so that views expressed can be taken into account Informed: Relevant and understandable Project information was disclosed to help stakeholders to understand the risks, impacts and opportunities of the Project

Reactions and feedback from the local communities, regional and national regulatory stakeholders were used to inform the scope of the ESIA, identify and assess impacts and develop appropriate mitigation measures. Since stakeholder engagement is a continuous process, it is expected that ongoing engagement activities will be managed by the ECOWAS-REAP PIU and their Contractors as the Project moves into the implementation phase.

5.3 Targeted Groups Criteria used in the selection of stakeholders to be consulted were based on the level of the different stakeholders’ potential involvement in the Project, e.g. their potential to benefit from the Project, or where their properties and assets will potentially be impacted negatively. The other set of criteria used was based on the potential involvement of specific national institutions in the Project based on their respective institutional oversight of the Project.

Figure 5.1: Meeting with the Community of Buram in Foni Bintang Karanai - Source: SD Focus Ltd, 2020

For the latter category, this included consultative meetings with NAWEC, DPWM, NEA, NRA, DOF, and NCAC. Discussions with these institutions revolved around their respective sectoral policies and legal mandates as they relate to the implementation of the Project. The meetings enabled the definition of their strength and weaknesses in relation to their potential roles and responsibilities in the implementation of the ESMP.

Organization of the community consultations was mostly spontaneous, i.e. whilst the team of Consultants, NAWEC and Project staff were in a community, a request would be made of the Alkali (the village head) for a meeting of about one hour. The Alkali would oblige and call up the community

46 members (both men and women) to his compound, and after a good number of villagers turn up, the meeting would begin.

At other times notifications were made well ahead of time of arrival of the Consultant’s team, and on arrival the venues will be full of participants; the meetings would normally last at most, one hour. Certain stakeholders were consulted mainly based on the fact that the locations of their place of business was within the potential trajectory of a transmission line; should the works begin the potential for these businesses to shut down temporarily is very high. These included shops keeping, and tyre repair workshops located along the road corridor in Mandinaba.

The documentation of consultations enabled the Consultant to track stakeholders’ perceptions and concerns regarding the development of the Project. To record and track the process and comments from the stakeholder, the following forms were used:

▪ meeting notes were used to record, and document discussions held between the Consultant and individuals, groups, and communities

▪ guidance notes and focus group topic points, focusing on questions surrounding economic activities within the communities; the guidance notes included questions on community’s health, education, livelihoods, etc.

• A register of attendees, recording all individuals who attended the consultations was made

A summary regarding the stakeholder consultations undertaken is provided in Appendix 5.1 and the list of persons met is in Appendix 5.2.

5.4 Opinions, concerns and fears of populations and PAPs Stakeholders in all the Project areas were adequately sensitized on matters relating to the consultations with the communities, project background, processes, and procedures as well as the role of the communities and institutions during the implementation of the Project.

With the availability of electricity, they said they would also be able to acquire milling machines which will reduce the drudgery of threshing and milling of agriculture produce for home consumption and commercial purposes. They also stressed that studying with candles is very challenging for their children and will become a thing of the past as their children will enjoy studying under light bulbs as their compatriots in other schools.

From the consultaions, the opinions, concerns and fears of the populations and persons likely to be affected by the Project (PAPs) have been incorporated into the recommendations of this ESIA.

CHAPTER 6: ANALYSES OF POTENTIAL IMPACTS AND MITIGATION MEASURES

This Chapter identifies and analyses the potential impacts resulting from the Project’s activities, and describes the mitigation, management, and monitoring measures to be put in place to sustainably implement the Project. Beneficial impacts are also identified.

6.1 Methodological Approach

6.1.1 Identification of the Main Sources of Potential Impacts of the Project on the Environment Potential impacts, either positive or negative, are the likely changes to occur on the environmental and social components as a result of the Project implementation. Sources of these impacts include all project related activity, carried out during any of the different phases of implementation, which generate these changes. Table 6.1 identifies the main sources of impact for the ECOWAS REAP.

Table 6.1: Main Sources of Potential Impacts of the Project on the Environment and the Social aspect

No PROJECT PHASES TYPES OF WORK IMPACT GENERATING ACTIVITIES 1 Pre-construction Planning -Consultation and provision of project information to stakeholders - Physical survey of proposed project sites Land acquisition for poles Siting of poles in land owned or used by villagers Land preparation for -Clearing of vegetation for access and construction poles -Felling and trimming of economic trees within the ROW Sourcing of earth materials -Clearing of quarrying site -Excavation during quarrying -Stockpiling Establishment of base -Clearing of camp sites camps 2 Construction Mobilization of logistics -Transportation of workers, equipment, and materials to Project sites -Importation of workers -Repair of heavy vehicles and equipment -Storage of heavy vehicles and equipment during works Construction of poles -Digging of trenches -Building of foundations -Erection of poles Stringing of lines -Installation of cables and accessories Clearance of sites after -Removal of excess materials works -Removal of waste materials 3 Operation and Electrification of new lines -Connection to substations and existing Maintenance grid -Connection to users Routine clearing of ROW -Pruning of trees Maintenance of -Repair and replacement of T&D parts infrastructure

4 Decommissioning Closure of quarries Reclamation and restoration of quarries Closure of base camps Dismantling of equipment and structures Transportation of materials and equipment from camps Cleaning of camp sites upon closure

6.1.2. The Environment and Social Components Affected by the Project

The Project implementation may affect the different environmental components as listed in Table 6.2

Table 6.2: Environment and Social Components likely to be affected by the Project COMPONENTS AFFECTED Human Physical Biological

Surface water Aquatic ecosystem Public health and safety Ground water Terrestrial wildlife Occupational health and safety Air quality and climate Forests and vegetation Labor related issues Geology and soils Agriculture and livestock Land use and land ownership Noise and vibration Income Landscape and aesthetics Energy Vulnerable groups Community stability Cultural and historical sites

6.1.3 Identification of Potential Impacts Having identified the environment components and the Project’s sources of impacts, their correlation was considered using the Leopold’s Matrix. Each activity (source of impact) was listed and the potential for creating an impact considered against each environment component. Where there is likelihood of an impact, the interaction box is highlighted with a cross as indicated in Table 6.3.

Table 6.3: Identification of impacts ENVIRONMENT COMPONENT AFFECTED PHYSICAL BIOLOGIC HUMAN / SOCIAL AL

PROJECT PHASES ACTIVITIES / SOURCES OF IMPACTS

1 Pre-construction Consultation and X X provision of project information Physical survey of X proposed project sites Siting of poles X X X X X Clearing of vegetation for X X X X X X X X X access and poles Felling and trimming of X X X X X X X X X X X economic trees within the ROW Clearing of quarrying site X X X X X X X X Excavation during X X X X X X X quarrying Stockpiling X X X X Clearing for camp sites X X X X X X

2 Construction Transportation of X X workers, equipment, and materials Importation of workers X X X X X X Repair of heavy vehicles X X X X and equipment Storage of heavy vehicles X X and equipment during works Digging of trenches X X X X X X X X X Building of foundations X X X X Erection of poles X X X X X X X Installation of cables and X X X X X X accessories Removal of excess X X X X X materials Removal of waste X X X X X materials

3 Operation and Connection to substations X X X X Maintenance and existing grid Connection to users X X X X X X Pruning of trees X X Repair and replacement X X X of T&D parts

4 Decommissioning Reclamation and X X X X restoration of quarries Dismantling of equipment X X X X X X and structures Transportation of X X materials and equipment from camps Cleaning of camp sites X X X X upon closure

6.2 Evaluating the Significance of Potential Impacts

In order to ensure that the limited resources are used optimally to mitigate (prevent, reduce, repair, or compensate) the potential impacts, it is important to identify which impacts are more significant for adequate consideration. The parameters used to assess the significance of an impact include intensity, extent, and duration.

6.2.1 Nature of an Impact

- Negative impacts create adverse changes that destroy or degrade the receiving environmental component. Negative impacts are undesirable as project development is expected to improve biophysical or socioeconomic environments.

- Positive impacts as result of the project activities are changes that are beneficial and improve quality of the related environmental components.

6.2.2 Types of Impacts

- Direct or primary impacts are those impacts that are created as a result of change to the immediate environmental component by the Project activities. There is clear causative link between the activity and the component. For example, losses of forest cover due to land clearing.

- Indirect impacts are usually secondary in the sense that the correlation between the activity and the environmental component is not readily noticeable and may not necessarily be on the same site.

- Cumulative impacts are those that are only significant when in combination. The potential cumulative impacts of this Project were also analyzed as the Project may exacerbate effects as a result of a combination of issues from activities of the past, present or future, including natural phenomena. The distribution of such impacts may be local, regional, or global. These effects together may cause significant impacts that would not have necessarily been relevant individually. Consideration of cumulative impacts may include combined effects of:

• one activity on existing/previously affected parameter; • many activities of the same project on various parameters/sites; • many projects impacting the same parameter; • many projects impacting multiple parameters.

6.2.3 Evaluation of Impact Severity / Significance

The Leopold’s impact identification matrix is further explored to evaluate the extent or scale of correlation between the activity and environmental component. The impacts were weighed based on considerations such as duration of the impact, the magnitude in relation to the total affected area, geographical scope, and population amongst others.

The relevance and importance of the impact to the component is also given consideration. Sensitivity and vulnerability of the component, such as protected habitats or women respectively, are analyses in addition to assessing the probability of the impact occurring and possibility of prevention, reversibility, or other mitigation measure.

6.6.4 Definition of severity leves

The following defines the levels of significance employed for this assessment stated in Tables 6.4 to 6.7:

(+2) Major positive significance: Impacts that are highly likely to promote sustainable development by creating changes that will improve the environment.

(+1) Low positive significance: Implies that there are some opportunities, possibilities, and alternatives for benefits to be gained as a result of the change caused by the impact.

(0) Insignificant positive or negative impact: No discernible impact or interference with the identified environmental parameters. The Project activity is not likely to create any beneficial or problematic change.

(-1) Minor negative significance: Limited adverse impacts caused by the Project activities, and not using sensitive resources. The prevention of such negative effects is also easily possible.

(-2) Major negative significance: High vulnerability and sensitivity; irreversible impact, and outcome of the impact affecting a wider area or population, etc.

6.3 Potential Impacts of the Pre-construction Phase

6.3.1 Potential Positive Impacts on the Biophysical Environment During activities of the pre-construction phase, no potential positive impact is anticipated on the biophysical environment.

6.3.2 Potential Negative Impacts on the Biophysical Environment

6.3.2.1 Impacts Relating to Geology and Soils Where quarries are used for sourcing sand and gravel for the Project compared to purchasing from registered mining companies, excavation carried out at the water table level, have the potential to contaminate ground water.

Sand and gravel to be used for construction may be mined illegally from unapproved sites causing indirect, secondary negative impacts on soil stability, landscape, and vegetation. Access roads to borrow pits may remain open after the project due to poor or incomplete site reclamation and restoration, encouraging illegal mining and waste dumping in the future.

There is also the possibility of soil compaction from the movement of heavy machinery and vehicles. This will open the bare areas to localized, temporary erosion risks and potential formation of new natural drainage routes during rainy seasons.

Agricultural land may also be compacted, particularly with the creation of diversions within farmlands, affecting soil drainage and productivity. Soils may also be polluted by hydrocarbon spills and improper disposal of solid and liquid wastes such as used oils, machine parts, inert wastes, and packaging, etc.

6.3.2.2 Air pollution In getting access, siting the poles and base camps, it is expected that existing trees and vegetation around the proposed sites for the poles and base camps will be cleared with the aid of heavy machines such as bull dozers or excavators. Dust and vehicular emissions will be released.

Alternatively, manual labor could equally be hired (preferably from within the communities) using machetes, cutlasses, shovels, and pickaxes to clear existing shrubs and vegetation.

The approximate area required for any proposed base camp is not known at this moment; however, during camp construction, dust pollution is expected from heavy vehicular movement, land clearing, excavations, and other related pre-construction earthworks. Dust emissions will also be produced during truck off-loading of earth materials in stockpiles for storage or heaping nearer the work sites.

Nonetheless, whatever methods are employed in the above works will generate dust within the immediate area of the works, but given most of the planned transmission corridors consist mostly of bushes and shrubs, the dust and gaseous emissions, such as the oxides of carbon, etc. will only temporarily affect ambient air quality around the activity sites. In addition to the high dispersion rates around the sites within open areas, the impact is considered low due to the localized and temporary nature during the works phases.

Apart from the workers who will be immediately disturbed, this impact will be more significant in populated areas, where poles are to be erected close to compounds and other relaxation or resting areas such as waiting sheds, as compared to farms and open fields.

6.3.2.3 Noise and vibration nuisance Temporarily during pre-construction works, noise and vibration is inevitable from the use of machinery and increased traffic to move workers and materials. Workers are generally the main victims, except where sites, particularly for distribution infrastructure, are in closely developed communities.

The use of heavy machinery such as electric saws to cut or trim trees is also another source of noise and vibration.

These localized impacts will scare wildlife in the open fields and aquatic organisms in the short-term during land preparation works. This is particularly relevant within areas which consist of sensitive sites of ecological importance for certain bird and mammalian species.

6.3.2.4 Unsightly landscape The aesthetically unpleasing landscape of the work sites will be visible (although with short-term impact) whilst any borrow pits created specifically for the Project will be more long-term, if not restored.

There is also potential for unsightly areas where construction and other wastes are indiscriminately dumped such as cleared vegetation and materials that have been damaged in the process.

Cleared camp sites and sites for stockpiles of earth materials within vegetated areas also reduce the green scenery as a result of vegetation clearing.

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6.1: Example of stockpiles with green background (for a current road project) within this Project's Aol Source: SD Focus Ltd., 2020

6.3.2.5 Impacts due to Improper waste management During land clearing and use of other aggregates to include building base camps, related wastes such as cleared vegetation, solid waste such as cement bags, iron, and other pieces of materials, could cause secondary pollution if not cleared in time.

Indiscriminate waste dumping will affect vegetation and water flow while also impacting the aesthetics of the immediate vicinity. In addition to construction rubble, poorly managed solid waste can result in creation of dumpsites which can have environmental health impacts.

Laborers (especially imported laborers) will generate domestic wastes such as food and sanitation wastes in camps or around work sites. Poor disposal of such waste may have secondary impacts with the potential of spreading of diseases, contamination of water bodies, degradation of aquatic ecosystems, and generation of greenhouse gases if the waste is burnt.

As waste will be produced during all phases of the Project, effects from improper management may be long-term with localized negative impacts on aesthetics, health, and safety.

6.3.2.6 Deforestation This Project involves mostly construction of poles and stringing of lines, and given the area required for the base of the pole, vegetation is not expected to be extensively cleared. Therefore, the chances of change in macro and microclimate are very low.

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Nonetheless, tree felling, and clearance of vegetation may add to climate change factors on the microclimate temperature increment. It is expected that this impact could be brought to the absolute minimum or fully mitigated given the relatively small area required for the base of the pole.

There is however risk of felling mature trees and unnecessary invasion of forests due to ease of access from routes developed by workers, and poor monitoring. Workers clearing the sites may take the opportunity to fell nearby trees that are not even along the identified trajectories, merely for personal benefits. As workers are in the habit of lighting small fires for brewing local tea whilst at work, fires may go out of control. There is high risk of potential negative impact where uncontrolled fires spread to cover large vegetated areas, destroying both mature and young trees that provide sanctuary and food for wildlife species, and forest products of various uses for the communities.

6.3.2.7 Loss of Fruit Trees and other Vegetation Total or part loss of fruit trees, such as mangoes and cashews, along the line trajectories due to felling or trimming by the Project to construct and protect the lines will be of high magnitude impact to the owners and users of the trees. Minimal felling of privately owned fruit trees is envisaged during site preparation for this Project.

6.3.2.8 Negative impacts on fauna Terrestrial fauna, including invertebrates, reptiles, and mammalian species, (including the primates) will be impacted by construction activities that create noise and pollution that destroy their sanctuaries.

Clearing of terrestrial vegetation will expose dependent wildlife, causing them to move to other areas for food and shelter, with the probability of creating competition and potential nuisance if they move to agricultural fields.

According to the International Union for Conservation of Nature (IUCN) Red List the Red Colobus monkey (Colobus badius temmincki) present in the open forests, is threatened, and the Guinea Baboon (Papio papio) is “near threatened”. However, in The Gambia the Guinea baboon population is of least concern, according to the DPWM. Nonetheless, the Biodiversity and Wildlife Act, 2003 accords general protection to certain species including the colobus monkey and the baboon which must be enforced more rigorously.

Workers (especially those imported) may hunt wildlife species for food, or income generation and thus compete with the local population, and this could impact the general population of the species and cause conflicts with the community. It could equally impact on the local population’s food source.

The Project could create additional or expand quarry pits during the pole construction period, and during the rains, the quarry pits may get flooded, creating watering points for livestock and wildlife; however, their movement is hindered (especially if pits are too steep) and domestic animals may drown.

6.3.2.9 Negative Impacts on Wetlands Wetlands occur in several places along the proposed transmission corridors, in different forms and serve vital functions; these include storing runoff, regenerating groundwater, filtering sediments and pollutants, and providing habitat for aquatic species and wildlife. Locating T & D infrastructure in wetlands can have impacts on these functions.

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Any of these and other activities can impair or limit wetland functions. Organic soils consist of layers of decomposed plant material that formed very slowly. Disturbed wetland soils are not easily repaired, and severe soil disturbances may permanently alter wetland hydrology.

6.3.3 Potential Positive Impacts on the Human Environment

6.3.3.1 Creation of Temporary Jobs Pre-construction activities including surveying, removal of vegetation and site preparation works will create approximately 16 temporarily employment possibilities for both skilled workers (5 persons) such as planners and engineers, and less skilled workers (11 persons) employed to remove vegetation on camp sites and corridor ROW. This is enhanced with the use of local labor, particularly unskilled workers.

Priority will be given to the community local workforce during labor selection to further enhance positive impact on the local community.

6.3.3.2 Improved Community Cohesiveness At the project inception, planning and design stages, the proposed beneficiaries are consulted to encourage participation and ownership whilst also learning from local knowledge on the environmental components.

Overall, the communities are delighted with the Project, and discussions around expectations further bring them together for the common goal. The momentum and enthusiasm generated by the impending lighting of the communities could be used as a spring board to form local committees to organize and coordinate community efforts, for example to negotiate with NAWEC on behalf of the communities to reduce the cost of connection. The commitees could equally act as forums where community greivances related to the Project could be lodged for onward transmission to the Project GRC.

To further enhance community cohesiveness the following could be possibilities:

• the Project may invest in related community infrastructure such as road upgrades and community reforestation as compensation for losses or as part of the activities; • consultation and participation of beneficiary communities should be a continuous process during the preconstruction phase; • the SSS could ensure all the necessary consultation and disclosure is done prior to the commencement of construction; • the GRM must also be active and made known for timely address of grievances; • communities can be encouraged to set up committees/groups that can be useful in supporting each other with regards to the benefiting and participating in the Project; this will create an internal support system

6.3.3.3 Income Generation Despite potential loss of economic trees, immediate income can be derived from the sale of the logs, or fuel wood produced therein.

Savings made from the Project related activities will provide opportunities for more income generation through investment into more lucrative businesses, therefore, compensation for involuntary resettlement should be accompanied by advice and information to promote improved livelihoods.

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Employment of local labor, could create capital for local community members to maximize the benefits of the electricty within the communities; they could be encouraged to invest in such trades as welding, carpentry, etc. and this could increase economic activity within local communities. Increased numbers of people in these trades could have spin offs into other trades with increased financial income within the communities.

6.3.4 Potential Negative Impacts on the Human Environment

6.3.4.1 Involuntary Resettlement and Loss of Livelihoods Preconstruction activities will create loss of land for poles and camps, and loss of economic trees for the ROW. Minima loss of agricultural land and range will occur.

It is common that open fields within the Project sites are used for farming during the rainy season. Tree felling and clearance of vegetation for the works will be carried out with negligible reduction in range land for cattle.

Considering that farming can still take place around the poles with insignificant impact from the loss of minimal space, and cattle have vast surrounding areas to graze on there will be low negative impact during pre-construction.

Other potential risks will be associated with people who would lose access to non-wood forest produce, (wild fruits such as baobab, “ditakh”, medicinal plants, etc.) and in the process result in the loss of their livelihood and cultural norms. However, given the large expanse of forested areas left untouched by the Project, the communities will continue to have access to non-wood forest products.

6.3.4.2 Negligence of Vulnerable Groups and Gender Based Violence (GBV) During the preconstruction phase, information on the proposed project is provided to the affected and interested stakeholders. Disadvantaged and vulnerable groups may be at risk of being left out during the process of stakeholder consultations due to their inability to get to consultation venues, and thus will be excluded. Project affected women, people living with disabilities and children, for example, may be sidelined and not considered by the male-headed community leaders during consultations.

In this Project there is also risk of some of the PAPs not benefitting adequately from the resettlement benefits and financial compensation. This will potentially include disadvantaged and vulnerable groups (including children, women and female-headed households, the elderly, persons with disabilities, etc.) within some PAPs’ households

6.3.4.3 Risks to Public Health and Safety During preconstruction activities, the communities are at risk of increased traffic accidents, and other incidents related to the project activities. Borrow pits that are not managed properly will pose risks to nearby communities; children in particular, are at risk of falling into them, and in the rainy season may cause drowning. Children are also in the habit of playing around work sites and climbing stockpiles, which increased their risk of involving in an accident.

For settlements close to sites of land clearing and preparation, dust and noise nuisance will be created.

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Due to influx of workers, especially where imported workers live within the communities and not in camps, communicable diseases of most concern include tuberculosis and sexually transmitted diseases and infections (STDs/STIs) such as gonorrhea, and HIV/AIDS.

6.3.4.4 Negative impacts from Violence Against Children (VAC) There is risk of using children as workers in the course of project implementation, particularly during preconstruction for site clearance. Children playing in camps and around work sites may be abused verbally, physically, or sexually, in addition to the risk of worksite accidents occurring.

6.3.4.5 Risks to Occupational Health and Safety During all phases of the Project, there are long-term hazards which could be pertinent to worker health and safety and of high significance because peoples’ lives are directly at risk. These include risks and hazards (noise, soil erosion, high traffic, air quality deterioration, named earlier under physical environment), that may occur during works in the field. During the preconstruction phase, particularly site clearing, workers are at risk of being attacked by bees, snakes, dogs or other wildlife. Work related stress including long hours of work and under extreme heat, will affect workers if they are not provided adequate services including water, food, sanitation, rest area and waste disposal facilities.

Accidents from equipment use, noise and dust may affect workers on the Project. Accidents and injuries could also arise from:

i. danger from quarry operations and safety risks from abandoned quarries or borrow pits, as well as when quarries continue to be used by unauthorized persons;

ii. operation of machinery, endangering both operators and laborers;

iii. injury/accident due to lack of warning signs, site barricades and safeguards.

6.3.4.6 Risks of Communicable Diseases Communicable diseases of most concern are sexually transmitted diseases (STDs), and HIV/AIDS due to influx of workers to the Project site or living within the communities.

The novel Corona Virus pandemic that started in 2019 affects The Gambia and is highly contagious.

6.3.4.7 Community Instability and Reduced Cohesiveness (Including Impacts from Labor Influx) Community instability, conflict or grievances of high significance may arise where information on the Project, land ownership, land use, and community expectations are not clearly relayed to them in a timely manner. Grievances and conflicts may arise especially where negative project impacts (e.g. loss of land or crop due to pole siting, partial or total loss of economic trees, labor influx and impacts to community and intimate partner relationships etc.), mitigation measures and community expectations are not well understood.

Clearing activities, particularly during the pre-construction phase, results to the production of vegetation waste (branches, logs, shrubs, whole trees etc.). Conflict may arise where ownership and distribution is unclear.

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Complaints are also likely, especially where compensations are not provided to PAPs due to disputes regarding eligibility for compensation, or disagreements in the amount of compensation received, or some PAPs not enumerated at all.

Other community stability risks that may result from labor influx include Gender-Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC) particularly with the use of child labor, sexual and other harassment by workers.

There are also risks of breaking community cohesion and reducing community participation on the Project where locally available human resources are not employed. Furthermore, construction crew that comes from outside the communities could introduce alcohol or other social vices to negatively affect existing socio-cultural values, norms, cohesion and the stability of the communities and interpersonal relationships within and among families.

6.3.4.8 Impacts on sites of cultural and historical significance As earlier discussed, there are sensitive sites of cultural and historical significance along some of the proposed line corridors; these include mosques and graveyards, There is always a possibility of finding objects of cultural heritage by chance, particularly during land clearing and preparation for works along corridors. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

6.4 Potential Impacts of the Construction Phase

6.4.1 Potential Positive Impacts on Biophysical Environment There are no potential positive impacts of significance on the biophysical environment during the construction phase.

6.4.2 Negative Impacts on the Biophysical Environment

6.4.2.1 Pollution of Surface Water There are a number of seasonal and permanent surface water bodies within the Project’s area of influence (such as the Bulanjor tributary in Foni Bintang Karanai) and construction works within them with heavy machinery could lead to soil compaction; a decrease in the permeability of the surface could result in soil erosion and increase in sediment loads of the nearby tributary. This can lead to alteration of the flow regimes of the tributary, thereby affecting water velocity, depth, and channel morphology.

High turbidity and change in the physical and chemical composition of the water will also slow down flow and affect the local water biome and activities. The probability of this happening will be increased where materials are also left on site, blocking water flow.

Accidental leaks or spills of oil/fuel from storage tanks or construction into these water bodies will lead to pollution.

6.4.2.2 Loss of Aquatic Ecosystems

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Within the study area are several surface waterbodies that may be impacted and indirectly affecting the flora and fauna they contain. Construction of transmission lines across these resources may have both short-term and long-term effects.

Water quality can be impacted not only by work within these streams, but also by nearby vegetation clearing and pole construction activities. The removal of adjacent vegetation can cause water temperatures to rise and negatively affect the aquatic habitats. Vegetation clearing can also increase erosion of adjacent soils causing sediment to be deposited into the streams, especially during rain events.

Woodlands and shrub vegetation along the streams are a valuable buffer between adjacent land uses such as farmlands and corridors of natural habitats. The vegetation protects water quality, maintains soil moisture levels in stream banks, helps stabilize the banks, filters nutrient-laden sediments and other runoff, maintains cooler water temperatures, and encourages a diversity of vegetation and wildlife habitats.

Overhead transmission lines across the streams or lakes may pose a potential collision hazard for waterfowl and other large birds, especially when located in a migratory corridor.

6.4.2.3 Impacts on Wetlands Pole construction and stringing of the lines can have impacts on the functions provided by wetlands in the following several ways:

- heavy machinery can crush wetland vegetation; - wetland soils, especially very peaty soils can be easily compacted, increasing runoff, blocking flows, and reducing the soil’s water holding capacity; - the construction of access roads to reach pole sites can change the quantity or direction of water flow, causing permanent damage to wetland soils and vegetation; - construction and maintenance equipment (cranes, trucks, and other heavy machinery) that will be used can stir up sediments and endanger fish and other aquatic life; - water flow during the rainy seasons, low and high tides, should not be impeded as a result of the civil and electromechanical works; - engineering of the poles, construction/installation methods and processes are of the required standards.

6.4.2.4 Noise and Vibration Nuisance During the construction phase, noise and vibration is inevitable from the use of machinery and increased traffic to move workers, equipment, and materials. Both noise and vibration nuisances are of higher significance where compressor drill machines are used during excavation of hard soil. Workers are generally the main victims, except where sites, particularly for distribution infrastructure, are in closely developed communities.

These localized noise impacts will also scare away wildlife in the open fields and aquatic organisms in the short-term during works on the foundation and presence of workers. Within non-seasonal wetlands where the ground is less hard, noise and vibration impacts from digging trenches for the pole foundation is low.

Where deadlines for construction are tight, contractors tend to work longer hours into the night when noise effects are more pronounced with less background sounds.

6.4.2.5 Impacts of Unsightly Landscape

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For the duration of pole construction works and stringing of the lines, the aesthetically unpleasing landscape of the work sites will be visible, and from far afield where heavy vehicles and equipment are parked. Although usually short-term only during the works, there is also likelihood of long-term impacts such as pole foundations that have already been dug and abandoned for any reason.

There is also potential for unsightly areas where excess construction materials (cement and earth materials) are left on site long after the works; other wastes that may indiscriminately be dumped during construction include packaging waste, empty cable drums, engine oils, worn out parts such as drill bits etc.

6.4.2.6 Air pollution Earthworks during construction such as excavations and handling of materials (sand, gravel, basalt, and cement) will produce localized dust emissions. Increased vehicular movement from transportation of equipment, workers, and materials (particularly in remote areas with very limited traffic) will also create an increase in air pollution during the works.

The emissions are temporary and significant only to the immediate area of the works. As such, workers around the sites will be disturbed by the nuisance and likely respiratory effects. In populated areas, more so during construction of the LV lines within communities, dust and gaseous emissions may affect the residents.

6.4.2.7 Effects of Extreme Weather Effects of extreme weather conditions can affect materials and construction during works. Heavy rains and storms will affect the erection of poles during construction, especially half completed works and material storage; this could result in wastage of materials, especially cement aggregates which could be washed away or diluted under rain.

The significance of heavy rains has some bearing on the water level of the surface water bodies and wetlands, especially in relation to the safety and wellbeing of the workers during construction. With unusual swell of the water in such sites, workers may drown or lose equipment in the water.

Locating poles on the banks of water bodies and close to road culverts could lead to poles collapsing due to potential erosion of the banks by heavy storm water runoff.

6.4.2.8 Impacts related to the Importation of Workers

Importing workers (that are not known by the communities) to Project sites may open the environment such as forests and wildlife or wetlands to illegal exploitation and pollution, respectively. Bearing in mind that the construction period is relatively short and that they may never return to the communities to be held accountable, imported workers may engage in illegal activities, such as logging, with potential long-term consequences.

6.4.3 Potential Positive Impacts on the Human Environment

6.4.3.1 Employment and income Employment resulting from the Project construction will create social benefits and improved standards of living.

During construction, approximately 57 workers, skilled (12) and unskilled (45) workers are required for the various activities. Skilled workers shall include various managers, engineers, planners,

108 environmental and social experts, heavy vehicle drivers, etc. The less skilled workers will include construction handymen, security, housekeeping personnel, etc.

It is uncommon for women to be involved in similar construction works, however, this Project will ensure that men and women are given the same employment opportunities without any impediments put in the way of women.

Temporary economic improvement of women in the immediate vicinity of the Project sites will be attained through commercial activities targeting project workers, as is common in most construction sites in Gambia. Employing youth will improve their skills that may encourage interest in the field for further personal development.

6.4.4 Negative Impacts on Human Environment

6.4.4.1 Risks to Public Health and Safety During construction, where the public risk access to hazards such as open pits, long and heavy materials, increased traffic and heavy equipment, there is potential significant negative impact that may lead to disabilities or loss of lives.

During pole construction and line stringing, dust and noise generation may cause nuisance to the communities, especially those settlements close to LV pole construction sites. However, given the required area for the base of the pole, noise and generation of dust will be localized, small scale, and temporary, confined to the period of pole erection when heavy vehicular movement may generate dust; as soon as work is completed, the situation is reversed to pre-Project state.

6.4.4.2 Risks of Communicable Diseases The risk of spreading communicable diseases is always present irrespective of the duration of the Project activity and increases with the importation of workers to communities. Communicable diseases of most concern especially during the construction phase are sexually transmitted diseases (STDs), and highly contagious disease outbreaks such as the novel Corona Virus pandemic.

The communities and workers are equally at risk of contracting diseases during the construction phase.

6.4.4.3 Risks to Occupational Health and Safety Construction activities include working in remote areas with risk of pest invasion (insects and wild animals), water bodies and paddy soils in wetlands, working at heights, and working with specialized machinery and equipment. Improper operation of machinery may endanger the lives of both operators and other workers within the sites. There is specific exposure of work crew to risk of falling during line stringing, and injuries from falling into excavation pits or falling on same level. Road traffic accidents will also be considered, particularly where most corridors are along existing roads, and some along busy highways.

Other issues which could be pertinent to worker health and safety during the construction phase include risks and hazards associated with noise and vibration, long and heavy parts, air quality and personal attacks.

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Work related stress including long hours of work and under extreme heat, will affect workers if they are not provided adequate services including water, food, sanitation, rest area and waste disposal facilities.

The likelihood of accidents happening during construction is moderate given the nature of the technology expected to be employed in the course of implementation of the Project. However, considering the scope of the Project in at least 104 the cumulative impacts of more than one incident will cause severe grievances and loss of credibility.

6.4.4.4 Negative Impacts from Gender Based Violence and Violence Against Children (VAC) Women and children are vulnerable to exploitation and abuse during the construction phase. Children are generally inquisitive and usually found around Project construction work sites. Children may also be employed during the works or casually asked to carry out errands.

Both women and children are at risk of being abused verbally, physically, or sexually, in addition to the risk of worksite accidents.

6.4.4.5 Negative Impacts on Land Use (Loss of Livelihood) During construction of the poles, the work site surrounding should be clear of day-to day activities for health and safety reasons, and to avoid interruption with the works. The main activities involved in line stringing are pulling and stretching of the lines between poles.

In the process of such works, activities around the works sites will be affected temporarily. During construction, not much agricultural vegetation will be expected to be affected for the required depth (1.5 m) and width (1.5 m) of excavations to hold the poles. However, agricultural land may be crossed for access. Crops growing close to the line trajectory (especially when the works are done in the farming season) will be trampled upon by the workers and destroyed. Loss of one season’s harvest for a small portion of the land could result if works are carried out during the farming season.

The size or area of impact will depend on the level of care and diligence exercised by the Contractor, since the stringing operation will be from one pole to the next, and this could be a distance of a minimum of 100m between two poles; thus the severity of the impact could be moderate to high, with the farmer losing crops and part of his livelihood.

Sites of weekly markets could also be disturbed during pole construction and stringing and thus lead to potential loss of earnings especially if works are carried out on market days as they will be temporarily displaced to prevent accidents.

6.4.4.6 Loss of Chance Finds During digging for the pole foundations, there is possibility of finding cultural heritage by chance. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

6.4.4.7 Risks Caused By Force Majeure Despite various management plans and proper implementation, there may be risks and calamities beyond the control of the Project or Contractors such as wildfires, flooding, storms, or disease outbreaks such as the 2019 Corona Virus pandemic.

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6.5 Potential Impacts of Operation and Maintenance

6.5.1 Positive Impacts on Biophysical Environment

6.5.1.1 Impact on Climate Change Globally, renewable energy is becoming one of the best replacements of conventional energy to fight climate change. Human activities, especially over the past few centuries, have impacted negatively the global environment; burning fossil fuels to produce energy, expulsion of chlorofluorocarbons that clog the atmosphere, and depletion of forest covers are only some of the activities which have led to the serious threat of global warming and irreversible climate change. The use of renewable energy, in this case, hydroelectric power generation has potential to mitigate climate change by directly reducing emission of Greenhouse Gases (GHG), which are the main culprits of global warming.

6.5.2 Negative Impacts on the Biophysical Environment

6.5.2.1 Effects of Extreme Weather Efficiency of overhead electricity lines can be reduced through extreme weather conditions such as strong winds and excessive rains that may affect applied loads and cause structural failure of various parts of the transmission and distribution infrastructure that are unable to withhold strong winds.

6.5.2.2 Impacts on Landscape Waste from disused and worn-out materials such as poles, lines, transformers, bolts, and knots etc. will be created during operation, maintenance, and repair works. These will create eyesores when not collected from the sites and managed properly.

At the substation sites, along highways, and in developing LV networks within densely built communities, the impact from wirescape is common. There may be criss-crossing or increased numbers of transmission lines, distribution lines, telecommunication lines and other structures in the same areas causing visual disturbances as illustrated in Figures 6.2 and 6.3.

Figure 6.2: Combination of poles and cables around the Brusubi substation (outside Project’s AoI) - Source: SD Focus Ltd. 2020

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Figure 6.3: Combination of poles and cables (MV and LV poles; streetlight poles, Advertisement Boards) across the highway from Brusubi substation (outside this Project’s AoI) - Source: SD Focus Ltd., 2020

6.5.2.3 Loss of Trees During maintenance, pruning of trees will have minimal significance as only affected branches should be trimmed.

6.5.2.4 Loss of Fauna Consultation with the DPWM highlighted an example of significant impact of non-insulated cables amputating monkeys within the Abuko Nature Reserve in Abuko (outside this Project area); similarly, in the open forests, one could expect such impacts on the populations.

Large birds with wider wingspans (such as certain eagles, waterfowl, cranes, hawks, and vultures) may get electrocuted or killed in contact with lines during flight or resting on the lines.

6.5.3 Potential Positive Impacts on Human Environment

6.5.3.1 Employment During operation, approximately 13 workers (9 skilled and 4 unskilled) will be employed at various times to include the more skilled project managers and specialists, operators of T&D systems, maintenance workers, and workers to clear the ROW routinely.

6.5.3.2 Economic Development as a Result of Efficient Energy Supply Enhanced economic development and associated income generation from activities reliant on supply of electricity will specifically improve livelihood and benefit communities within the identified line corridors, and generally the entire country.

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Improvement of tourism facilities was highlighted, including the importance of energy in the maintenance of museums and offices in remote areas of cultural significance such as the Stone Circles in Kerr Batch.

6.5.3.3 Improved Livelihoods as a Result of Better Services Education, health, communications, security and other social services that are largely dependent on electricity will be improved; with availability of electricity both locally and nationally, students will be able to stay up longer to read, and other social services such as health centers, clinics and national communication infrastructure will be more efficient.

Operation of the Project will also result to efficient electricity supply that will improve agricultural productivity such as cool storage and value adding processes.

6.5.3.4 Benefits to Youth and Vulnerable Groups With continuous electricity supply, youth could develop skills and trade to enhance their livelihood; these may include welding, carpentry, or other small businesses that rely on electricity. Consequently, more job creation prospects will encourage youth to stay and work in The Gambia, rather than venture the risky illegal migration journeys to more developed countries.

In the long-term, women could benefit by producing and selling, ice blocks and cold drinks made from local ingredients such as “kaba”, baobab and “wonjo” (hibiscus).

As outlined in a number of consultations, women look forward to having the opportunity to refrigerate or freeze food rather than cooking every day or having to get rid of excess food. The physical energy and time saved could be used to spend more time in other activities such as agriculture.

In remote areas where fishmongers come only periodically, women hope to purchase fish, where possible, in bulk when there is electricity for cold storage; this will help in promoting varied and balance diets.

6.5.3.5 Increased Security Operation of the Project will enhance security within the beneficiary communities, specifically at night, as lighting will be available.

6.5.4 Potential Negative Impacts on Human Environment

6.5.4.1 Risks to Public Health and Safety

Operation of T & D networks may cause harm to the public particularly where people encounter broken live lines during operation leading to electrocution or death. The significance is considered high as a single life lost to the Project is irreversible.

During pruning of trees, the public may also encounter dangerous equipment such as sawing machines or falling branches where these are collected for domestic use. 6.6.4.2 Occupational Health and Safety Risks During all works, including operation and maintenance activities, workers are at risk of accidents from machinery, traffic, and illnesses. These include exposure of work crew to the risk of falling from heights during maintenance and repair of lines and accessing high trees during pruning.

Electrocution and fire outbreaks during maintenance are also potential impacts of high significance.

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6.5.4.3 Negative Impacts on Public Services During operation on the grids (particularly during connection to the main substations and pole- mounted transformers) there will be temporary disruption of power services to existing customers (within and outside the Project’s area of influence) supplied by the transmission lines and substations involved in the works.

6.6 Impacts of Decommissioning and Dismantling

6.6.1 Potential Positive Impacts on Biophysical Environment

6.6.1.1 Improvement of Landscape Reclamation of quarries, camp sites, and removal of disused structures will return the landscape to original state or even better.

6.6.2 Negative Impacts on Biophysical Environment

6.6.2.1 Impacts of Improper Waste Management Decommissioning activities involve removal and movement of installations that have been used for the Project. These activities will produce waste of various types from earth materials to broken and disused parts, structures and used oils. Such waste may affect aesthetics, surface water, wildlife, livestock, and the public.

6.6.2.2 Air Pollution The decommissioning phases of camps have the potential to temporarily affect local air quality. Heavy machinery and vehicles will also release hydrocarbon incomplete combustion gases to the air, affecting local air quality.

6.6.3 Potential Positive Impacts on Human Environment

6.6.3.1 Employment All activities will have to be carried out by people who are paid. Decommissioning activities will provide short-term employment for drivers, clearing workers, quarry restoration workers etc.

6.6.4 Negative Impacts on Human Environment

6.6.4.1 Public Health and Safety Risks As with all work activities, the decommissioning phase will also create health and safety risks to the public.

6.6.4.2 Risks of Communicable Diseases The risk of spreading communicable diseases is always present irrespective of the duration of the Project activity. Communicable diseases of most concern especially during the construction phase are sexually transmitted diseases (STDs), and highly contagious disease outbreaks such as the novel Corona Virus pandemic.

The communities and workers are equally at risk of contracting diseases during the decommissioning phase. 6.7.4.3. Risks to Occupational Health and Safety Decommissioning will involve use of machinery and equipment that may endanger the lives of both operators and other workers within the sites.

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Other issues which could be pertinent to worker health and safety during the construction phase include risks and hazards associated with noise and vibration, air quality and personal attacks. Work related stress including long hours of work and under extreme heat may also affect workers.

6.4.4.4 Negative Impacts from Gender Based Violence and Violence against Children (VAC) Women and children are vulnerable to exploitation and abuse during all phases including the decommissioning phase.

Children may be found at the Project sites or illegally employed during the works. Both women and children are at risk of being abused verbally, physically, or sexually, in addition to the risk of worksite accidents. 6.8 Cummulative Impacts This Project may give rise to the following cumulative impacts on the biophysical and socioeconomic environment:

• As the T&D lines usually follow existing highways and roads, poles will be erected along the edge of the road which may be boundaries of agricultural fields. Previous loss of agricultural land, or the composition and quality of the soil during the road construction would, in addition to potential disturbance of agricultural land during this project, potentially affect farmers once again. Moreover, larger farmlands too close to the road would be more affected where more than one pole is located along the farm.

• As reported by Forestry Officers, some Community Forests in the Gambia (particularly those without noticeable boundaries) have been affected previously during road construction and similar T&D projects; more Community Forests may be further affected by this Project if control measures are not fully implemented.

For example, during field visits for this study, there was evidence of cleared vegetation (as a bye-pass for the road construction) and trees felled along the whole trajectory of the current road construction from Keleng Jawbeh, Sami District (CRR-N)6 to the settlement of Bush Town, across the River from Bansang. Along this bye-pass is a camp, stockpiles of earth materials and clearance for the road alignment. Therefore, no matter how minimal the vegetation clearance is for the Project, in combination with the current loss of vegetation, the impacts will be more pronounced.

• In addition, collective loss of vegetation and consequential disturbance of forests and wildlife habitat, particularly for access during works and indirectly at quarrying sites, may cause fragmentation of biodiversity and potential change to the variety of species as wildlife tend to adapt or move in response to continuous changes in habitat. This could also adversely impact the livelihoods, food security and cultural practices of the community, including women who may depend on access to these resources for food production and livelihoods.

• Excavation activities, increased worker population and vehicle traffic in remote areas at the same time during construction will create a combination of nuisances and reduced tranquility as a result of noise, vibration and air pollution (especially in most rural areas where similar activities and machinery are extremely rarely seen or used).

6 Although not within the WCR and thus outside the scope of this repot, but similar situations have been noted in many other places; this can contribute to increased cumulative impacts of different projects on the same receptor

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• Cumulative impacts from similar projects in future, such as adding extra circuit lines to existing poles, will have minimal combined effect as compared to construction of another line along the same routes.

• Potential visual disturbance is likely in the future where electricity transmission lines and lines of other services compete for space, for example, crisscrossing of telecom and electricity lines. In certain areas, poles may be situated near similar structures with adverts or road signs creating unaesthetically pleasing sights collectively.

Specific concern is at the main substations where many poles and lines will have to be connected to serve the various feeders creating unsightly wirescapes

• The cumulative impact from potential public health and occupational health and safety risks (falls, electrocution, effects of air and noise pollution, diseases, GBV, SEA, VAC etc.) associated with the project should be noted as various hazards will be present simultaneously during works, creating an environment for increased probability, frequency and number of incidents. The more the number of workers, the more the cumulative nature of the potential impacts and the need for more stringent supervision and monitoring to ensure safety, compliance, credibility, and social cohesiveness.

• Considering the wide scope of the Project with more than 330 villages, low impacts of the Project in these villages in combination may lead to impacts of high significance. For example, where minor grievances are reported from several villages, the Project and GRC will have to work effectively to maintain credibility (especially with the fast spread of news on social media). Moreover, the total land-take of the Project, combining the negligible land-take from each PAP, will become significant.

The results of the anaylsis will assist the ECOWAS-REAP PIU, NEA and other government agencies in making informed decisions about the environmental and social assessment that has been conducted on the Project. It will be noted that the Policy and Regulatory framework specified in Chapter 3, has been taken into consideration in the development of this report, and the impact assessment is based on the Project’s adherence to these requirements.

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CHAPTER 7: MANAGEMENT MEASURES OF THE POTENTIAL NEGATIVE IMPACTS ON THE ENVIRONMENT

This Section prescribes the necessary measures to manage both the negative impacts of the project activites as well as the positive impacts. Whilst the negative impacts are mitigated, positive impacts should be enhanced or encouraged.

7.1 Enhancement Measures for Potential Positive Impacts

7.1.1 Enhancement Measures for Positive Impacts During Pre-construction Phase: Human Environment

7.1.1.1 Creation of Temporary Jobs Temporary employment can be created for more people by providing opportunities to local workers in the various Regions, particularly unskilled labor.

Contractors should be encouraged and monitored to ensure equal employment opportunities to men, women, and youth.

7.1.1.2 Improved Community Cohesiveness

Overall, the communities are delighted with the Project, and discussions around expectations further bring them together for the common goal. The momentum and enthusiasm generated by the impending lighting of the communities could be used as a spring board to form local committees to organize and coordinate community efforts, to negotiate with NAWEC on behalf of the communities to reduce the cost of connection, among other initiatives. The committees could equally act as forums where community grievances related to the Project could be lodged for onward transmission to the Project GRC. To further enhance community cohesiveness the following could be possibilities:

7.1.1.3 Income Generation Cleared vegetation should be made available to the communities without discrimination, for sale or domestic use. Savings made from the Project related activities will provide opportunities for more income generation through investment into more lucrative businesses, therefore, compensation for involuntary resettlement should be accompanied by advice and information to promote improved livelihoods.

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Increased numbers of people in these trades could have spin offs into other trades with increased financial income within the communities.

7.1.2 Enhancement Measures for Positive Impacts During Construction Phase: Human Environment

7.1.2.1 Employment and income • During construction, employment can be created for more people by providing opportunities to local workers in the various Regions, particularly unskilled labor.

• Hiring practices and training should encourage technology transfer and development programs to promote the use of local suppliers of goods, services, and personnel.

• Where possible, the required materials should be produced in The Gambia, to create further employment as compared to the importation of materials; local suppliers should be encouraged through provision of adequate technical and commercial information for fulfilment of requirements.

• Contractors should be encouraged and monitored to ensure equal employment opportunities to men, women, and youth.

7.1.3 Enhancement Measures for Positive Impacts During Operation Phase: Biophysical Environment

7.1.3.1 Impact on Climate Change NAWEC shall ensure optimal use of the electricity produced from the renewable energy source to reduce the use of fossil fuels in energy production; transmission and distribution infrastructure should be periodically upgraded to improve efficiency.

7.1.4 Enhancement Measures for Positive Impacts During Operation Phase: Human Environment

7.1.4.1 Employment During operation, the employment needs are minimal for inspection, repair, and maintenance of infrastructure. Periodic pruning of vegetation along the ROW shall also create employment. To enhance employment during operation, the limited number of employees can be given refresher training to ensure they can handle new technology and designs. This shall improve employment opportunities.

Indirect employment can also be created as agents are required in most of the communities for the sale of electricity tokens.

7.1.4.2 Economic Development as a result of Efficient Energy Supply

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National development is highly dependent on electricity, therefore, NAWEC most ensure during operation that the necessary maintenance and periodic upgrade of the T&D infrastructure is carried out to ensure constant supply; this will prevent unnecessary electricity shortage as a result of breakdown in the T&D system.

NAWEC shall also expand to ensure optimal transmission and distribution of the available energy.

7.1.4.3 Improved Livelihoods as a Result of Better Services Availability of electricity improves livelihoods, therefore, NAWEC most ensure during operation that the necessary maintenance and periodic upgrade of the T&D infrastructure is carried out to ensure constant supply. Reliable energy supply will promote the development and maintenance of businesses and improve domestic livelihood activities with the use of electrical equipment.

NAWEC shall also ensure optimal transmission and distribution of the available energy through increased accessibility and affordability.

7.1.4.4 Benefits to Youth and Vulnerable Groups To enhance benefits of the Project to potentially vulnerable groups, NAWEC shall promote equality in energy accessibility and distribution without discrimination. 7.1.4.5 Increased Security NAWEC shall ensure increased affordability of electricity to the wider population; this will encourage communities to light up.

7.1.5 Enhancement Measures for Positive Impacts During Decommissioning Phase: Biophysical Environment

7.1.5.1 Improvement of Landscape The ESS and the NEA must ensure the landscape is improved or at least returned to near original state.

7.1.6 Enhancement Measures for Positive Impacts During Decommissioning Phase: Human Environment

7.1.6.1 Employment During decommissioning, local workers should be employed to carry out the removal and clearing activities.

7.2 Impact Management during Pre-construction Phase

7.2.1 – Mitigation Measures of the Negative Impacts on the Biophysical Environment

7.2.1.1 Mitigation of Geology and Soils related Impacts

• For operating new quarries, the materials shall be obtained from quarries only after the consent of relevant authorities, including such as the affected communities, the Geology Department (GD) and the NEA. Extraction sites will need to be assessed before commencement of mining, and after approval of mining and reclamation plans;

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• quarries approved for this Project, must be officially closed after the works, and communities given the responsibility of reporting to the authorities (NEA, GD) of any illegal mining activities:

• for quarries approved for this Project, copy of licenses should be displayed on site, or produced on request by the relevant national authorities;

• access to the quarries must always be prohibited and communities educated on controlling children to avoid such sites due to the associated risks, including drowning during the rainy season;

• only established transportation routes and diversions must be used to limit destruction and ensure reclamation is done at the end of the works by reinforcing and repair access roads;

• contractor must be cautioned through relevant clauses in the works agreements to use only certified sand and gravel suppliers that have been approved by the NEA and GD;

• vegetation removal must be carefully carried out to avoid major soil disturbance, and only existing transportation routes used to avoid destruction of virgin land.

7.2.1.2 Mitigation of Air Pollution

• access to pre-construction sites by the public must be prohibited by placing appropriate signs and barriers in combination with community sensitization on health and safety during works;

• camps must be located sufficiently away from human settlements (at least 500m);

• reduce speed to 10-20 km/h when entering settlements;

• erecting speed bumps when settlements are regularly crossed.

In addition, other mitigation measures for generation of dust and other gaseous pollutants are as follows:

Generation of dust

• Wet road surfaces to suppress dust emissions and prevent nuisance;

• workers must be provided with personal protection gear with the aim of preventing dust- related health problems and other dust nuisances;

• trucks transporting sand and gravel must be covered to prevent dust and flying debris;

• special care will be taken when working near educational institutions, recreational grounds, mosques, health facilities, and other areas where the public may gather such as markets. This will include erection of barriers and posting of sign boards to warn against intrusion of people into the work sites.

Gaseous Pollution

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• contractors must also be warned in their agreement clauses to reduce air pollution through use of well-maintained equipment. Equipment must be serviced frequently and run below the optimal, as overloading strains the mechanisms that produce incomplete combustion. High quality oils must also be used to reduce dangerous air emissions;

• emission standards prescribed in the Environmental Quality, Permitting and Discharge Regulations must not be exceeded;

• ensure that engines of vehicles and machines are not left operating idle;

7.2.1.3 Mitigation of Noise and Vibration Nuisance All works must be carried out during daytime, between working hours, to reduce noise nuisance. In addition, the following must be observed:

• use of well-serviced equipment to reduce nuisance, thus maintenance of vehicles, equipment and machinery should be emphasized ;

• provision of earplugs to workers exposed to high noise levels;

• raise awareness of this risk for the population and the measures put in place.

7.2.1.4 Mitigation of Unsightly Landscape • work sites must be cleared after all Project activities; • borrow pits should be reclaimed and restored to enhance landscape; • all waste produced during the pre-construction phase should be well managed; • stockpiles should be located at base camps and not numerous locations for ease of access; • make an environmental and social reception which goes before the technical reception of the works.

7.2.1.5 Mitigation of Improper Waste Management Improved waste management measures shall be employed and enforced, and these will include developing a waste management plan to include amongst others, the types of waste, expected quantities and frequency, proposed management procedures and responsibilities. The plan will indicate the following:

i. minimizing the production of waste that must be treated or eliminated where waste generation cannot be avoided;

ii. identification and classification (hazardous or not, solid, gaseous, or liquid) and estimate the likely type of waste to be generated such as cleared vegetation, packaging, excess aggregate, and disused equipment etc.;

If hazardous wastes are generated, proper procedures must be taken regarding their storage, collection, transportation, and disposal as indicated in the Hazardous Chemicals and Pesticides Control and Management Act, 1994:

iii. using the cleared vegetation, as firewood within the communities;

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iv. reusing the solid waste (such as topsoil wastes) generated from the excavation works as backfill while the rest will be disposed of in designated areas;

Other solid wastes (such as cement bags, metallic pieces, wooden planks, and leftover of aggregate material and debris) will be disposed of according to the National Environment Management Act, 1994 and Antilittering Regulations, 2007;

v. recommending that the work contracts include waste management measures (as indicated in Appendix 6.1) such as those described in World Bank’s Environmental, Health, and Safety (EHS) Guidelines (1.6 Waste Management);

vi. iIdentifying and demarcation of approved disposal areas, clearly indicating the specific materials that can be deposited in each; waste must not be discarded within, or close to Community Forests;

vii. all waste management options must be in a sound manner that does not affect human health and the environment;

viii. the Contractor developing a well-organized internal supervision and monitoring system to ensure waste reduction and proper management through full implementation of the waste management plan;

ix. external monitoring to be carried out by the TACs to remind the Contractors that they are being watched; also, to ensure discontinuation and mitigation where waste has been dumped illegally.

7.2.1.6 Mitigation of Deforestation Deforestation shall be minimized by the following:

• although vegetation will have to be cleared for the camp, poles, and access to certain areas, this should only be limited to the required area;

• divert routings to avoid trees where feasible;

• develop a RAP to assess the potential losses of forest trees and required compensatory reforestation. Where trees to be felled are forest trees (even outside protected forests), and thus belong to the DOF, the RAP consultant should develop a costed tree replacement plan with 1:4 replacement ratio to be implemented by DOF

• workers must be educated and warned by the Contractor to avoid forested areas, extracting wood, hunting, and burning activities, which will degrade the forests (particularly Community Forests certain corridors) and other vegetation.

7.2.1.7 Mitigation for the Loss of Fruit Trees • only remove trees that are absolutely necessary for the works by diverting lines where possible; • locate poles within the maximum range to avoid trees; • encourage replanting programs rather than mere cash compensations;

7.2.1.8 Mitigation of Impacts on Fauna • all quarry pits created by the Project must be fully rehabilitated after mining;

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• there must be constant supervision of works to ensure only necessary sites are cleared of vegetation;

• construction workers must protect natural resources and wildlife; thus, they should be educated on guidelines relating to the hunting of wild animals;

• The Guinea baboon, and Red colobus monkey populations, must be protected by: o enforcing more vigorously the relevant national laws and regulations that prohibit their killing; o conducting training and information meetings on their preservation and protection at community level; o creating community wildlife reserves where threatened species such as the baboon could be protected;

• Hunting and eating of bush meat by all workers, particularly imported workers, will be prohibited and alternatives such as fish, and domestic animals encouraged; offenders must be disciplined in any of the following ways:

i. informal warning; ii. formal warning; iii. loss of up to one week’s salary; iv. suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months; v. termination of employment;

• there should be a labor Grievance Redress Mechanism (GRM) to ensure that employees can report anonymously if needed to prevent risks of reprisals. The labor GRM should be included in the Contractors ESMP (C-ESMP) and as part of the bidding documents.

7.2.1.9 Mitigation of Impacts on Wetlands • avoid placing transmission lines through wetlands, if possible. If inevitable to avoid wetlands, there should be constant supervision of the works, environmental monitoring, and the Contractor must ensure construction works and mitigation measures are according to the C- ESMP;

• contractors shall minimize impacts wherever possible by integrating all mitigation measures into the design, including evaluation of alternative routes and designs to prevent or mitigate potential impacts. These include:

i. Routing of lines One method to mitigate impacts during Project design is replacing or double circuiting an existing line rather than building a new line. The same principle could apply in other areas besides wetlands. The environmental advantages of double-circuiting on an existing line are:

- Little or no additional corridor clearing, if the new line can be placed in the center of an existing corridor - Land use patterns may have already adapted to the existing corridor - Magnetic fields may be reduced because new structure designs place line conductors closer together resulting in lower fields. Using corridor-sharing to minimize corridor requirements

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ii. Transmission Line Infrastructure Choosing a different transmission pole with different construction requirements and aesthetic appeal is another method to mitigate impacts during Project design. These will include:

- Using H-frame structures, which have longer span widths, and thus make it easier to cross rivers, wetlands, or other resources with fewer impacts

- Using the darker color of oxidized steel structures, which blend in better with forested backgrounds

Pole foundation design factors to be considered especially in wetlands will involve: - Highest flood and /or tidal level shall be established before pole construction - Soil analysis report especially in wetlands - Marine grade design concrete mix is used and vibrated accordingly

iii. Add-ons By adding flight diverters to conductors, bird collisions with the wires can be minimized. These markers on the top (shield) wire make the lines more visible to birds if the collision potential is high

7.3 Impact Management during Pre-construction Phase

7.3.1 Mitigation Measures of the Potential Negative Impacts on the Human Environment

7.3.1.1 Mitigation for Involuntary Resettlement and Loss of Livelihoods • avoid agricultural lands by choosing alternative routes wherever possible;

• where alternative routes are not possible, all loss of livelihood, including agricultural and rangeland, firewood and other forest produce collection will be addressed in a RAP;

Although this Project will not involve physical relocation of people, all PAPs should be compensated as required by the Bank’s OP 4.12. In this regard, a RAP shall be developed and implemented making sure that all persons affected by the Project are fully and fairly compensated for lost assets and livelihoods;

• construction activities should be carried out in the dry season when agricultural fields are not in use (although for NAWEC, this is common practice for ease of access to line corridors without damaging crops in farmlands).

7.3.1.2 Mitigation for the impacts on vulnerable groups World Bank policies (such as OP 4.12) require that particular attention is paid to the needs of vulnerable groups, including women. Therefore, the development of any RAP must clearly identify and consult with them and address any potential risks that will prevent them from benefitting appropriately from resettlement benefits and financial compensations 7.3.1.3 Mitigation for risks to public health and safety • workers should be trained in good practices and contingency measures prior to the start of works. Integrate staff training, especially drivers on defensive driving, given the real road traffic risk;

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• they must also be sensitized on how accidents or incidents can affect Project implementation, the measures they have to follow and fines in case of non-compliance; • warning and safety signs must be used before commencement and during the works to inform and warn the public of risks and means of avoidance;

• gravel and sand borrow pits specifically approved for these works must be reclaimed to return the sites to as close as possible to the natural state;

• danger of accidents and injuries from utilities and other equipment and machinery during the pre-construction phase shall be monitored vigorously; to prevent and protect the communities from harm, the contractor shall mount safety cordons and danger signs at strategic locations;

• communities must be informed to stay away from work sites to avoid dust inhalation prior to works;

• sourcing of workers, especially unskilled labor shall be from local communities to avoid imported labor, as much as possible;

• recommended that skilled labor be rotated in on and off duty cycles to make them available to meet with their family members (back home) to minimize the chances of their mixing with the village women to minimize the chances of spreading STDs/STIs and HIV/AIDs (and increasing incidents of conflicts with the community, disruption to social cohesion and interpersonal relationships, including intimate partner relationships);

• the “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), and Violence Against Children (VAC)” will also be included in contracts including explicit references for monitoring, enforcement and compliance (as per Appendix 6.1);

• awareness campaigns/orientation covering but not limited to HIV/AIDS/STDs transmission risks shall be carried out for workers and host communities;

• regular check-up for workers to determine whether there are new cases of infections, and to what extend are these infections increasing or decreasing.

7.3.1.4 Mitigation of violence against children • Children must not be employed by the Project, and the Project must comply with all relevant local legislation, including labor laws in relation to child labor and the Bank’s safeguard policies on child labor and minimum age.

• Communities need to be informed about the start of all works at least 5 days before, and the need for them to keep children away from the sites

• Specifically, the project should ensure that the “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC)” are included in the Project’s bidding documents. The Codes of Conduct are meant to:

i. Create awareness of the ESHS and OHS expectations on the Project ii. Create common awareness about GBV, SEA and VAC

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iii. Ensure a shared understanding that GBV, SEA and VAC have no place in the Project iv. Create a clear system for identifying, responding to, and sanctioning GBV and VAC incidents

7.3.1.5 Mitigation of Risks to Occupational Health and Safety The following measures are important to be carried out to prevent and manage negative impacts to worker health and safety during the preconstruction phase:

• Training and safety information should generally be provided to management, supervisors, workers, and occasional visitors to areas of risks and hazards. Specifically, there must be on- the-job training, and knowledge on procedures to reduce risks, including coordination and supervision.

• Workers should be trained in good practices and contingency measures prior to the start of works. Integrate staff training, especially drivers on defensive driving, given the real road traffic risk.

• All workers employed by a Contractor for the Project must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments. • Although the main risks are analysed in Chapter 8 for appropriate action, biological risks (wildlife attacks) can specifically be addressed by: - Discussing with the commintities risks of potential wildlife attacks in the area - Providing information to the staff on preparedness - Training on response - Provision of first aid kits - Provision of knowledge on the closest health facilities for additional expert help

• The Contractor should adopt and implement a health and safety program which entails:

- Effectively identifying and correcting unsafe conditions routinely - Protection of the workers and the public from dangers arising from operational activities of the facility - Prevention of events resulting in potential injury to workers, the public, or the environment - Fire extinguishers, personal protective equipment and first aid kits should be provided, and training given on how to use them - Reporting of incidents is also essential for the review and improvement of safety procedures - A tailor-made Accident Prevention Plan (APP) must be prepared and implemented by the Contractor. At the minimum, the Plan must consist of the following elements:

i. Management Policy Statement

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ii. Authority and Accountability iii. Goals and Objectives iv. Employee Commitment and Responsibilities v. Employee Involvement vi. Disciplinary Policy vii. Record Keeping viii. Safety and Health Surveys and Inspection/Program ix. Safety or Other Related Meetings x. Safety and Health Training xi. Safety Audit and Inspection xii. Accident hazard and risk assessment xiii. Accident and Hazard Investigation xiv. Accident Reporting and Investigation xv. Review and Revision of Components

• Despite the accident prevention plan, incidents may occur, and an Emergency measures plan in case of accidents will be implemented to address: i. General measures ii. Internal Operation Plan (POI) iii. Circulation and movements on the sites iv. Individual and collective protection equipment v. Special instructions for the use and movement of vehicles vi. Works inspection and maintenance program vii. Fire protection measures viii. Training and exercise procedures

7.3.1.6 Mitigation of Risks of Communicable Diseases • The workforce shall be sourced locally to reduce the need for importation of workers. Employing local workers enhances community cohesion as the local workers know the community, culture, and norms which may also help decrease risks to GBV, SEA, spread of STDs and so on

• Nonetheless, to prevent STDs, it is essential that Contractors are required through the contracts to educate their workers on the risks and prevention methods before, and constantly during works. In addition to implementing measures on sensitization and education on the dangers and mitigation measures to address STIs, there will also be strict monitoring to ensure adherence to the relevant codes of conduct.

• Other methods include: • Encouraging use of condoms

• NAWEC and Contractors providing surveillance and active screening and treatment of workers • Ensuring the Contractor routinely reviews the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children with Project workers, including mandatory reviews with new workers to a Project site to ensure all workers understand behavior expectations and GBV/SEA risks, including sexual harassment. The Social Safeguards Specialist of the Project will attend sensitization meetings to ensure they are taking place. The Codes of Conduct are meant to:

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- Create awareness of the ESHS and OHS expectations on the project - Create common awareness about GBV, SEA and VAC - Ensure a shared understanding that GBV, SEA and VAC have no place in the project - Create a clear system for identifying, responding to, and sanctioning GBV, SEA and VAC incidents

• Regarding the global Corona Virus Pandemic, the PIU and contractors shall rely on national, WHO and WB guidance for safety of workers and community beneficiaries (the WB Guidelines are stated in Appendix 7.2).

7.3.1.7 Mitigation for community instability

• Initiate extensive consultations and sensitization with the communities and project affected persons about eligibility and compensation requirements through awareness-building meetings

• With regards to the management of deforestation products, privately owned trees are left with the owners and forest trees with the DOF, whilst products from other vegetation in the open can be collected by villagers on a first-come, first-served basis as traditionally practised.

• Use the Grievance Redress Mechanism (GRM) at the ECOWAS-REAP PIU for prevention and resolution of conflicts arising from complaints and grievances relating to compensations and redress. Appendices 9.1 to 9.2 explains the GRM process.

• The GRM will involve a Grievance Redress Committee (GRC) to investigate all complaints and grievances from PAPs relating to, for example: eligibility for compensation; PAPs not listed; etc.

• Employing local workers enhances community cohesion as local workers know the community, cultures, and norms which may also help decrease risks to GBV, SEA, spread of STDs and so on, as workers know the community and vice versa. As such, the Contractor will be required to write a hiring plan to incorporate local workers

• Contractor to develop a hiring plan to ensure that community labor is being used, and also to ensure that women are employed in the Project

• Apply the Codes of Conduct in order to mitigate against VAC, SEA and GBV in Project sites; prior to the start of work, the staff will be well sensitized, and they will sign the Codes of Conduct. Ensure regular trainings and awareness-building on the Codes of Conducts among all key stakeholders (community, contractor, workers) which will also be included in contractor’s C-ESMP and in bidding documents

7.3.1.8 Mitigation of impacts on sites of cultural and historical significance • The Contractors must avoid all sites of cultural or historical significance including any buffer created for their protection. These may include complete diversion of the lines or ensuring poles are not locating next to such sites. For example, small mosques along the routes can be avoided by adjusting the line span to ensure the poles are far away from the structures

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7.4 Potential Impact management during the construction phase

7.4.1 Mitigation Measures of the Potential Negative Impacts on the Biophysical Environment

7.4.1.1 Mitigation of Surface Water Pollution • Adjust the span between the poles to avoid waterbodies. • For larger water bodies and wetlands, integrate all the identified mitigation measures, from design to implementation, in order to prevent or mitigate potential changes of water quality. For example, designs and plans should ensure siting of poles at a minimum safe distance from the water bodies.

• Constant supervision of the works and environmental monitoring will ensure construction works are not carried out close to the banks in order to avoid soil compaction leading to soil erosion and increase in sediment load of the tributaries

• Workers shall be careful to prevent spills and improper management of waste and excess materials. Contractors will also ensure prescribed procedures are followed to protect water quality as required by the Environmental Quality Standards Regulations, 1999, and the Environmental Discharge (Permitting) Regulations, 2001

7.4.1.2 Mitigation of Loss of Aquatic Ecosystems • Existing vegetative buffers should be left undisturbed whenever possible.

• For areas where construction impacts cannot be avoided, low-growing native tree and shrub buffers along these streams should be allowed to regrow so as to maintain the pre- construction water quality in the streams. To allow regrowth, the Contractor must ensure that the sites are returned to near original state (clear all excess materials and wastes that may affect regeneration; level soil around worksites similar to the surroundings to allow water movement).

• Place markers on the top (shield) wire to make the lines more visible to birds if the collision potential is high.

7.4.1.3 Mitigation of Impacts on Wetlands • Avoid placing transmission lines through wetlands, if possible. If inevitable to avoid wetlands, there should be constant supervision of the works, environmental monitoring, and the Contractor must ensure construction works and mitigation measures are according to the C- ESMP.

• Adjust pole placements to span wetlands, or limit equipment access in wetlands, wherever possible. By making minor adjustments in pole locations (especially given the allowable span between poles), impact on archaeological sites and agricultural operations can be minimized.

Line clearance safety is important to take into consideration during the routing of the MV lines. Use Table 7.1 below as guide.

Table 7.1; Recommended Minimum Clearance Distances for Various Situations

Nature of Area Minimum Clearance (meters) Over Open Country 5.20

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Over the Road 6.10 Alone the Road 5.80 Over telecom Lines 2.44 Over Rivers 6.10 Over MV or LV Lines 2.44 Under HV Lines 2.44 Near Buildings Vertical 3.70 Horizontal 2.00 Source: OMVG, 2018

7.4.1.4 Mitigation of Noise and Vibration Nuisance All construction works must be carried out during daytime, between 8am and 6pm, to reduce noise and vibration nuisance. In addition, the following must be observed:

• Use of well-serviced equipment to reduce nuisance, thus maintenance of vehicles, equipment and machinery should be emphasized

• Provision of earplugs to workers exposed to high noise levels

• Enforce strict work rules to limit only necessary workers at the sites

7.4.1.5 Mitigation of Unsightly Landscape • During the works, Contractors must encourage good housekeeping to ensure sites are organized. All excavations and piles of earth materials that have been made during the works and not used must be levelled to return the sites similar to its surroundings.

• All equipment and heavy vehicles must be parked securely at special sites (base camp or identified sites for this purpose) at the end of each workday.

• All excess and waste materials will be removed from the work sites for appropriate management as earlier discussed.

7.4.1.6 Mitigation of Air Pollution Mitigation measures for air pollution through generation of dust and other gaseous pollutants during construction include:

• Wetting work sites to suppress dust emissions and prevent nuisance

• Workers must be provided with personal protection gear with the aim of preventing dust nuisances and other dust-related health problems

• Trucks transporting sand and gravel to the work sites must be covered to prevent dust and flying debris

• Special measures will be taken when working near complex areas such as educational institutions, recreational grounds, mosques, markets, and health facilities. This will include erection of barriers and posting of sign boards to warn against intrusion of people into the work sites.

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• The workdays will also be altered to make use of opportunities when these sites are free or less busy. For example, avoiding school or weekly market days.

• Contractors must also be warned in their agreement clauses to reduce air pollution through use of well-maintained equipment. Equipment must be serviced frequently and run below the optimal, as overloading strains the mechanisms that produce incomplete combustion. High quality fuels and oils must also be used to reduce dangerous air emissions.

• Emission standards prescribed in the Environmental Quality, Permitting and Discharge Regulations must not be exceeded.

• Ensure that engines of vehicles and machines are not left operating idle.

• Reduce speed to 10-20 km/h when entering settlements.

• Erecting speed bumps when settlements are regularly crossed.

7.4.1.7 Mitigation of Extreme Weather Impacts • Plan and execute pole erection after the rainy season as this would prevent works from being interrupted due to potential heavy rains.

• Workers should be trained and supervised in safe practices, such as daily inspection of equipment, and use of personal protective gear.

• The planners and contractors should avoid locating poles at the edges of culverts and water bodies to prevent poles from collapsing as a result of erosion. Given that the minimum span between poles is 100m, contractors must not site poles less than 15m on each side of surface water bodies to prevent possible erosion and collapsing of poles. Poles should be located at least 5m from the edge of the culvert, and not within the route of water flow.

• Within wetlands, specially engineered foundation types should be employed for durability.

7.4.1.8 Mitigation of Impacts related to the Importation of Workers • Employing construction workers in the various Project intervention villages will be impractical considering the short-term nature of the construction activities with little time for scouting and training. Therefore, contractors should at least aim to employ workers from the various administrative Regions of The Gambia where the Project falls.

• Communities should also be aware of the GRM in case of complaints and reports relating to the Project, including activities of its workers.

• Internal supervision and monitoring by the Contractor’s team will ensure workers are controlled within the Project sites and identified construction activities.

7.4.2 Mitigation Measures of the Negative Impacts on the Human Environment

7.4.2.1 Mitigation of Impacts related to Public Health and Safety • At sites of weekly markets or schools, construction works must be carried out only on non- market or school days. Where some traders remain permanently at the sites, a RAP will be

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developed to include any loss of livelihood for displacement to a safe location during the construction phase.

• Alternatively, the routing of the lines can be changed where possible, and be located behind the markets, to avoid the congested areas. • Strict restrictions must be put in place to prohibit access of the public to work sites, materials, and equipment

• Communities must be given prior notice before commencement of the works to inform and warn the public of risks and means of avoidance. Communities must be informed to stay away from work sites.

• To prevent road traffic accidents, work supervisors must ensure speed limits are controlled and operators of vehicles and heavy equipment well trained other measures to mitigate the potential health risks in traffic and vehicular movement, include:

- The Contractors must emphasize safety aspects among drivers - Drivers’ skills should be tested and improved through training, including training on defensive driving - Contractors should adopt limits for trip duration and preparing driver rosters to avoid overtiredness - Drivers must avoid dangerous routes and busy times of day to reduce the risk of accidents, particularly with long parts - Contractors should maintain regular maintenance of vehicles and use of manufacturer approved parts to minimize potentially serious accidents caused by equipment malfunction or premature failure - Institute fines and penalties for non-compliance, including deduction of wages, suspension, or even dismissal for habitual errant Project drivers - There should be effective site management, including signage, lighting, and warning signs, including restriction of access by unauthorized personnel.

7.4.2.2 Mitigation of Risks of Communicable Diseases • During disease outbreaks, the PIU and Contractors must ensure that the Project related activities and workers are in line with the Emergency Regulations set by the Government of The Gambia. Specifically, these include distancing, crowd control, improved sanitation, and movement restrictions.

• The workforce shall be sourced locally to reduce the need for importation of workers. Employing local workers will make them take more responsibility for their actions and will reduce promiscuousness. Knowing the community, culture, and norms will also help decrease risks to GBV, SEA, and spread of STDs.

• Other methods include: • Encouraging use of condoms

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• It is recommended that skilled labor be rotated in on and off duty cycles to make them available to meet with their family members (back home) to minimize the chances of their mixing with the village women to minimize the chances of spreading STDs/STIs and HIV/AIDs (and increasing incidents of conflicts with the community, disruption to social cohesion and interpersonal relationships, including intimate partner relationships)

• Awareness campaigns/orientation covering but not limited to HIV/AIDS/STDs transmission risks shall be carried out for workers and host communities

• Regular check-up for workers to determine whether there are new cases of infections, and to what extend are these infections increasing or decreasing.

7.4.2.3 Mitigation of Occupational Health and Safety Risks The following measures will be implemented to mitigate worker health and safety risks during construction. In addition, Chapter 8 covers the accident risk assessment and management plan which will be employed for specific risks and accidents.

• Specifically, biological risks (wildlife attacks) can be addressed by: - Discussing with the commintities risks of potential wildlife attacks in the area - Providing information to the staff on preparedness - Training on response - Provision of first aid kits - Provision of knowledge on the closest health facilities for additional expert care • Training and safety information should generally be provided to management, supervisors, workers, and occasional visitors to areas of risks and hazards. Specifically, there must be on- the-job training, and knowledge on procedures to reduce risks, including coordination and supervision.

• Workers should be trained in good practices and contingency measures prior to the start of works

• All workers employed by the Contractor for the Project must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be

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provided as needed to ensure that workers are aware to the specific hazards of individual work assignments.

• The Contractor must provide proper working conditions for labor, including adequate toilets, drinking water, areas for rest and having meals, lighting (especially for camps) and waste disposal facilities.Consideration must also be given to these facilities at peak sites and times when the demand is higher.

• The Contractor should support in providing medical care to workers, particularly for health conditions occurring during work. This may include health insurance, transportation costs to health facilities and medical fees.

• The Contractor should adopt and implement a health and safety program which entails:

- Effectively identifying and correcting unsafe conditions routinely - Protection of the workers and the public from dangers arising from construction activities - Prevention of events resulting in potential injury to workers, the public, or the environment - Fire extinguishers, personal protective equipment and first aid kits should be provided, and training given on how to use them - Reporting of incidents is also essential for the review and improvement of safety procedures - A tailor-made Accident Prevention Plan (APP) must be prepared and implemented by the Contractor. At the minimum, the Plan must consist of the following elements:

i. Management Policy Statement ii. Authority and Accountability iii. Goals and Objectives iv. Employee Commitment and Responsibilities v. Employee Involvement vi. Disciplinary Policy vii. Record Keeping viii. Safety and Health Surveys and Inspection/Program ix. Safety and other Related Meetings x. Safety and Health Training xi. Safety Audit and Inspection xii. Accident hazard and risk assessment xiii. Accident and Hazard Investigation xiv. Accident Reporting and Investigation xv. Review and Revision of Components

• Despite the accident prevention plan and due diligence, incidents may occur, and an Emergency Measures Plan in case of accidents will be implemented to address:

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vi. Works inspection and maintenance program vii. Fire protection measures viii. Training and exercise procedures

7.4.2.4 Mitigation of Gender Based Violence and Violence against Children • Children must not be employed by the Project (paid or unpaid), and the Project must comply with all relevant local legislation, including labor laws in relation to child labor and the World Bank’s safeguard policies on child labor and minimum age.

• Communities need to be informed about the start of all works, at least 5 days before, and the need for them to keep children away from the sites.

i. Create awareness of the ESHS and OHS expectations on the Project ii. Create common awareness about GBV, SEA and VAC iii. Ensure a shared understanding that GBV, SEA and VAC have no place in the Project iv. Create a clear system for identifying, responding to, and sanctioning GBV and VAC incidents

7.4.2.5 Mitigation of Land Use Impacts and Loss of Livelihoods • Avoid agricultural lands by choosing alternative routes wherever possible

• Where alternative routes are not possible, this Project will not involve permanent, physical relocation of people; all PAPs will be compensated as required by the national laws and the World Bank’s OP 4.12. In this regard, a RAP shall be developed and implemented making sure that all persons affected by the Project are fully and fairly compensated for any loss of assets and livelihoods.

• Construction activities should be carried out in the dry season when agricultural fields are not in use (although for NAWEC, this is common practice for ease of access to line corridors without damaging crops in farmlands).

• Contractors must ensure to use the maximum allowable distance between poles to reduce the number of poles that would potentially be located within a single farmer’s field

• Construction works will be carried out outside loumo (market) days to avoid impacting shops and vendors’ income and revenues

7.4.2.6 Mitigation of Chance Finds Impacts • Should an unusual, uncommon or atypical finding be made along any of the feeder corridors, the Chance Find Procedures described in Appendix 4.4 will be applied: avoid further disturbance and secure discovery, inform the supervisor for onward conveyance to NAWEC and the National Council for Arts and Culture (the legal institution responsible to manage cultural heritage) for proper management.

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7.4.2.7 Mitigation of Risks from Force Majeure • All reasonable precaution will be taken by the Project during construction to prevent danger to the workers and the public. This will include provision of timely information, and in certain instances (such as disease pandemics) postponement of works until the risk subsides.

• The PIU and Contractors will abide by any national emergency regulations passed by the Government of The Gambia during such periods.

7.5 Impact Management during the Operation and Maintenance Phase

7.5.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment

7.5.1.1 Mitigation of effects of extreme weather conditions • During operation, routine inspection and maintenance shall reduce destruction of infrastructure during strong winds and heavy rainfall.

7.5.1.2 Mitigation of Impacts on Landscape and Aesthetics • All waste must be collected and disposed according to the C-ESMP.

• T & D technical designs and plans will consider reducing the number of feeder lines emanating from the same points of a particular substation (different directions or underground). NAWEC planners and surveyors will also be trained in improving the scenery during installation of distribution networks.

7.5.1.3 Mitigation for Impacts on Trees • Fruit tree pruning must be carried out only when tree branches grow towards the conductors

• Pruning should also be planned when fruit trees are not in their fruiting season to reduce losses

7.5.1.4 Mitigation of Loss of Fauna • Although overhead MV lines are usually of bare cables, this Project must give special design consideration to corridors within protected areas in order to avoid impact on avifauna and climbing animals. The Project design should include a more protective line design.

• Add-ons may be installed, such as flight diverters to conductors, to minimize bird collisions with the wires. These markers on the top (shield) wire make the lines more visible to birds if the collision potential is high.

• Nesting grounds and migratory paths should be protected; to reduce risk of birds colliding with the lines, bird-flight diverters will be used. These are designed to make overhead lines and guyed structures visible to birds and provide an economical means of reducing the hazard to both lines and birds.

• Anti-nesting devices, or artificial nest platforms must be used to mitigate and reduce risks to the avifauna

7.5.2 Mitigation Measures of the Negative Impacts on the Human Environment

7.5.2.1 Mitigation of Risks to Public Health and Safety

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• General education on the safety of electricity infrastructure will be included in public awareness programs.

• Maintenance teams routinely clearing the ROW for the T & D corridors will ensure community members are prohibited from work sites during pruning.

7.5.2.2 Mitigation of Occupational Health and Safety Risks The following measures will be implemented to mitigate worker health and safety risks during operation and maintenance.

• Training and safety information should generally be provided to management, supervisors, and workers on the risks and hazards. Specifically, there must be on-the-job training, and knowledge on procedures to reduce risks, including coordination and supervision.

• Workers should be trained in good practices and contingency measures prior to the start of works

• All workers employed the Project activities must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments.

• The Contractor / NAWEC staff carrying out maintenance works should adopt and implement a health and safety program which entails:

- Effectively and routinely identify and correct unsafe conditions routinely - Protection of the workers and the public from dangers arising from construction activities - Prevention of events resulting in potential injury to workers, the public, or the environment - Fire extinguishers, personal protective equipment and first aid kits should be provided, and training given on how to use them - Reporting of incidents is also essential for the review and improvement of safety procedures - A tailor-made Accident Prevention Plan (APP) must be prepared and implemented by the Contractor. At the minimum, the Plan must consist of the following elements:

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xiii. Accident and Hazard Investigation xiv. Accident Reporting and Investigation xv. Review and Revision of Components

• Despite the accident prevention plan and due diligence, incidents may occur, and an Emergency Measures Plan in case of accidents will be implemented to address:

i. General measures ii. Internal Operation Plan (POI) iii. Circulation and movements on the sites iv. Individual and collective protection equipment v. Special instructions for the use and movement of vehicles vi. Works inspection and maintenance program vii. Fire protection measures viii. Training and exercise procedures

7.5.2.3 Mitigation of Impacts on Public Services • Prior to connection of the new infrastructure to the substations, the public must be informed well in advance about disruptions to electricity services. This will allow them to plan and prepare accordingly. 7.6 Impact Management during the Decommissioning Phase

7.6.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment

7.6.1.1 Mitigation of Improper Waste Management Improved waste management measures shall be employed and enforced, and these will include developing a waste management plan to include amongst others, the types of waste, expected quantities and frequency, proposed management procedures and responsibilities. The plan will indicate the following:

i. Minimizing the production of waste that must be treated or eliminated where waste generation cannot be avoided

ii. Identification and classification (hazardous or not, solid, gaseous, or liquid) and estimate the likely type of waste to be generated such as cleared vegetation and disused equipment etc.

Other wastes will be disposed of according to the National Environment Management Act, 1994 and Antilittering Regulations, 2007

iii. Recommending that the work contracts include waste management measures (as indicated in Appendix 6.1) such as those described in World Bank’s Environmental, Health, and Safety (EHS) Guidelines (1.6 Waste Management)

iv. Identifying and demarcation of approved disposal areas, clearly indicating the specific materials that can be deposited in each; waste must not be discarded within, or close to Community Forests

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v. The Contractor developing a well-organized internal supervision and monitoring system to ensure waste reduction and proper management through full implementation of the waste management plan

vi. External monitoring to be carried out by the TACs to remind the Contractors that they are being watched; also, to ensure discontinuation and mitigation where waste has been dumped illegally. 7.6.1.2 Mitigation of Air Pollution In addition, other mitigation measures for generation of dust and other gaseous pollutants are as follows: • Wet road surfaces to suppress dust emissions and prevent nuisance.

• Workers must be provided with personal protection gear with the aim of preventing dust- related health problems and other dust nuisances

• Contractors must also be warned in their agreement clauses to reduce air pollution through use of well-maintained equipment. Equipment must be serviced frequently and run below the optimal, as overloading strains the mechanisms that produce incomplete combustion. High quality oils must also be used to reduce dangerous air emissions. • Reduce speed to 10-20 km/h when entering settlements.

• Erecting speed bumps when settlements are regularly crossed.

7.6.2 Mitigation Measures of the Negative Impacts on the Human Environment

7.6.2.1 Mitigation of Impacts related to Public Health and Safety

• Gravel and sand borrow pits specifically approved for these works must be reclaimed to return the sites to as close as possible to the natural state to prevent water looging and drowning of children and animals

• Strict restrictions must be put in place to prohibit access of the public to work sites, materials, and equipment

• Communities must be given prior notice before commencement of the works to inform and warn the public of risks and means of avoidance. Communities must be informed to stay away from decommissioning work sites.

- The Contractors must emphasize safety aspects among drivers - Drivers’ skills should be tested and improved, including training on defensive driving given the real road traffic risks. - Contractors should adopt limits for trip duration and preparing driver rosters to avoid overtiredness - Drivers must avoid dangerous routes and busy times of day to reduce the risk of accidents, particularly with long parts

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- Contractors should maintain regular maintenance of vehicles and use of manufacturer approved parts to minimize potentially serious accidents caused by equipment malfunction or premature failure - Institute fines and penalties for non-compliance, including deduction of wages, suspension, or even dismissal for habitual errant Project drivers - There should be effective site management, including signage, lighting, and warning signs, including restriction of access by unauthorized personnel.

7.6.2.2 Mitigation of Risks of Communicable Diseases • During disease outbreaks, the PIU and Contractors must ensure that the Project related activities and workers are in line with the Emergency Regulations set by the Government of The Gambia. Specifically, these include distancing, crowd control, improved sanitation, and movement restrictions.

• Other methods include: • Encouraging use of condoms • NAWEC and Contractors providing surveillance and active screening and treatment of workers • Ensuring the Contractor routinely reviews the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children with Project workers, including mandatory reviews with new workers to a Project site to ensure all workers understand behavior expectations and GBV/SEA risks, including sexual harassment. The Social Safeguards Specialist of the Project will attend sensitization meetings to ensure they are taking place. The Codes of Conduct are meant to:

• Awareness campaigns/orientation covering but not limited to HIV/AIDS/STDs transmission risks shall be carried out for workers and host communities

7.6.2.3 Mitigation of Occupational Health and Safety Risks The following measures will be implemented to mitigate worker health and safety risks during decommissioning:

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• Training and safety information should generally be provided to management, supervisors, workers, and occasional visitors to areas of risks and hazards. Specifically, there must be training on-the-job, and knowledge on procedures to reduce risks, including coordination and supervision.

• Workers should be trained in good practices and contingency measures prior to the start of works.

• The Contractor must provide proper working conditions for labor, including adequate toilets, drinking water, areas for rest and having meals, lighting (for camps) and waste disposal facilities. Consideration must also be given to these facilities at peak sites and times when the demand is higher. • The Contractor should support in providing medical care to workers, particularly for health conditions occurring during work. This may include health insurance, transportation costs to health facilities and medical fees.

• All workers employed by the Contractor for the Project must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments.

• The Contractor should adopt and implement a health and safety program which entails:

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• Despite the accident prevention plan and due diligence, incidents may occur, and an Emergency Measures Plan in case of accidents will be implemented to address:

7.6.2.4 Mitigation of Gender Based Violence and Violence against Children • Children must not be employed by the Project (paid or unpaid), and the Project must comply with all relevant local legislation, including labor laws in relation to child labor and the World Bank’s safeguard policies on child labor and minimum age.

• Communities need to be informed about the start of all works, at least 5 days before, and the need for them to keep children away from the sites.

7.7 Mitigation of Potential Cumulative Impacts

The cumulative impacts can be mitigated by ensuring that all the mitigation measures in the ESMP are fully implemented. These include amongst others, working outside the farming season, avoid forests and unrelated removal of vegetation, strategically locate poles, develop, and implement the C-ESMP, provide information and educate on health and safety. Future cumulative impacts may be mitigated by studies done and implemented at that time.

Given the above, it is evident that there will be negative impacts created by the Project, although for the most part they will be short-term, localized and small scale, and can be mitigated through this ESMP; with full implementation of the ESMP in a timely manner, the beneficiaries / affected communities will be better-off with the Project than the null alternative.

CHAPTER 8: MANAGEMENT OF RISKS AND ACCIDENTS

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This Chapter identifies and analyses the potential risks and accidents that may occur during the various phases of the Project. It further outlines the main issues to be addressed by the Contractor including mitigation and prevention, training needs, contingeny and emergency response planning, recording, reporting and monitoring.

8.1 Methodological Approach for Hazards and Risks Identification

8.1.1 Objectives of the Risk Assessment and Management

The main purpose of the risk assessment is to: • identify potential risks of the Project activities (factors / hazards that have the potential to expose the workers, communities, and property to harm); • evaluate which risks require priority actions; • recommend corresponding measures to prevent or reduce the risks, and at last resort, protection against the risks;

8.1.2 Methodology In this risk identification, the Project activities (sources of hazards and risks) earlier stated were correlated with a list of possible risks. Where there is likelihood of a risk causing harm to the public or workers, the interaction box is highlighted with a cross as indicated in Table 8.1.

Further analysis of the risks (severity, probability, exposure levels and possibility of control) will consider their importance and magnitude of mitigation measure needed for prevention or effective management.

Adopted from Moja et al. (2016), the procedure below was modified for this risk assessment:

i. Rate the risks: Scores (1-5) were allocated to the various risks on severity, probability, exposure, and control according to the ratings described in Table 8.2.

ii. Calculate the actual risk: actual risk = severity + probability + exposure iii. Calculate significance of the risk = actual risk - possibility of control iv. Rate the final scores according to the following levels of significance as in Table 8.3:

0 means no significance of risk 1 - 5 means low significance of risk 6 - 9 means medium significance of risk 10 - 15 means high level of concern

Following the risk analyses, corresponding preventive and protective measures are then recommended for mitigation. These should follow the mitigation hierarchy from elimination, control, and reduction of the risks to providing protection against the hazards. An example of the risk analysis matrix for the pre-construction phase is given for replication by the contractor. The contractor should tailor-make the analyses based on his tasks and program.

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8.1.3 Risk Identification Table 8.1 identifies the risks likely to cause harm during the different phases of the Project implementation. It further identifies whether the communities or workers are exposed to such risks.

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Table 8.1: Risk identification matrix

PROJECT PHASES ACTIVITIES / SOURCES OF RISKS RISKS TO THE PROJECT WORKERS RISKS TO THE PUBLIC

ires and explosions and ires

Noise nuisance Noise risks Vibration risks Chemical shocks Electrical explosions and Fires injuries Personal Ergometrics risks Respiratory workers Unethical attacks Wildlife conditions site Work stress related Work nuisance Noise shocks Electrical F risks Respiratory workers Unethical

Movement circulation Equipment use and and storage Sabotage Insecurity illness Contagious Movement circulation Equipment use and and storage injuries Personal illness Contagious

Explosions Explosions Pre-construction Consultation and provision of Project X X information Physical survey of proposed project sites X X X X X X X X Siting of poles in land owned or used by X X X villagers Clearing of vegetation for access and X X X X X X X X X X X X X X X X X X poles Felling and trimming of economic trees X X X X X X X X X X X X X X X within the ROW Clearing of quarrying site X X X X X X X X X X Excavation during quarrying X X X X X X X X X Stockpiling of earth and other materials X X X X X X X Clearing for camp sites X X X X X X X X Construction Transportation of workers, equipment, X X X and materials Importation of workers X X X X X X Repair of heavy vehicles and equipment X X X X X X X Storage of heavy vehicles and equipment X X X during works Digging of trenches for pole foundations X X X X X X X X X X X X X X

Building of foundations X X X X X X X X Erection of poles X X X X X X Installation of cables and accessories X X Removal of excess and waste materials X X X X Operation and Connection to substations and existing X X X Maintenance grid Connection to users X X X X X X X X Pruning of trees X X X X X X Repair and replacement of T & D parts X X X X X X Decommissioning Reclamation and restoration of quarries X X X X X X X Dismantling of equipment and structures X X Transportation of materials and X X X X equipment from camps Cleaning of camp sites upon closure X X X

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Table 8.2: Risk evaluation / rating

Source: S D Focus Ltd. (2020), Adapted from Moja et al. (2016)

Description Score Definition

PROBABILITY Insignificant 1 Risk consequences will occur only in exceptional circumstances (The Likelihood that a risk Minor 2 Risk consequences unlikely to occur in a year consequence will Moderate 3 Risk consequences likely to occur in a year occur) Major 4 Risk consequences could likely occur within a month Catastrophic 5 Risk consequences almost certain to occur a few times in a month

EXPOSURE Rare 1 Exposure to this risk is limited to only 1 person (employee/public) who may be affected (which parties and how many people Unlikely 2 Exposure to this risk may affect more than 1 person are exposed) Possible 3 Exposure to this risk may affect 50% of (workers or beneficiary community) Likely 4 Exposure to this risk may affect more the 50% of employees / beneficiary community Almost certain 5 Exposure may affect 100 % of workforce / beneficiary community

SEVERITY Minimal 1 Insignificant or no likely injury or treatment will be required (minimum time of exposure) (what will be the seriousness of the Restricted 2 Minor injury or need for medical attention. No lost time expected Local 3 Likely disabling condition consequence) Widespread 4 Several disabilities may occur Extensive 5 Fatality; Imminent risk of long-term disability

CONTROL 1 Measures that protect the individual worker e.g. provision of masks, safety shoes, helmets, fencing etc. (possible mitigation measures that can prevent or reduce risks) 2 Measures that in addition to the above, involve changes in procedure to safety to involve instructions, training, awareness, and screening 3 Measures that address hazards by design of infrastructure or equipment e.g. insulation or infiltration 4 Measures that replace the hazard with a safer option 5 Measures that eliminate the risk completely

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8.2 Risk Analysis

Table 8.3 is an example of risk analysis using the described procedure. The Contractors shall develop similar matrices for the construction, operation and maintenance and decommissioning phases. The Contractors shall tailor-make the analyses based on the specific tasks, resources, personnel, procedures etc. they plan to employ.

Table 8.3: Preconstruction Phase Risk Analysis Matrix

Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

1 Sabotage Poor Consultation All Project 2 1 1 4 4 0 Consultations to consultations, activities workers start well in non-cohesive (Consultants advance during communities / NAWEC the project staff / development Contractors) phase to enhance acceptability

2 Movement Increased Physical Workers 2 3 3 2 8 6 Workers must and circulation movement of surveying employ good risks such as vehicles and driving and traffic number of parking skills; accidents people avoid parking in middle of roads;

use reflector vests; use hazard lights

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Train all drivers on defensive

driving

Clearing for Workers 3 3 4 2 10 8 Constant access and and the supervision of sites of public workers; poles employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only

Clearing for Workers 2 3 2 2 7 5 Constant quarrying and the supervision of public workers; employ qualified workers; train workers; restriction warning signs; inform

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

community to avoid sites; work during daylight only

Excavation Workers 2 2 2 2 6 4 Constant during and the supervision of quarrying public workers; employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only

Stockpiling Workers 3 4 3 2 10 8 Constant of materials and the supervision of public workers; employ qualified workers; train workers; restriction warning signs;

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

inform community to avoid sites; work during daylight only; secure stockpiles

Clearing of Workers 2 2 2 2 6 4 Constant base / camp and the supervision of sites public workers; employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only

3 Noise nuisance Heavy Clearing for Workers 4 1 2 2 7 5 Use machinery access and and the appropriate, and sites of public well-serviced equipment; poles equipment; workers provide protective gear

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

for workers; restriction warning signs; inform community to avoid sites; only work during the day

Felling and Workers 2 2 2 2 6 4 Use trimming of and the appropriate, trees within public well-serviced ROW equipment; provide protective gear for workers; restriction warning signs; inform community to avoid sites; only work during the day

Clearing for Workers 2 1 1 3 4 1 Use quarrying appropriate, well-serviced equipment; provide

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

protective gear for workers; inform community to avoid sites; only work during the day

Clearing of Workers 2 1 1 3 4 1 Use base / camp appropriate, sites well-serviced equipment; provide protective gear for workers; restriction warning signs; inform community to avoid sites; work during the day

4 Vibration risks Heavy Clearing for Workers 2 3 3 4 8 4 Use of machinery access and appropriate

and hand-held sites of machinery and tools poles equipment

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

based on the type of terrain

Felling and Workers 2 3 3 3 8 5 Limit exposure trimming of by reducing trees within working hours ROW on handheld equipment such as chain saws

5 Risks related to Heavy Clearing for Workers 4 4 4 2 12 10 Employ workers improper use machinery, access and and the with requisite and storage of sharp and hot sites of public skills; keep equipment objects poles equipment in secure base

camps; restrict access to sites

Clearing for Workers 3 2 4 2 9 7 Constant quarrying supervision of

workers; employ qualified workers; train workers; set procedures for safe operation

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Felling and Workers 2 3 3 2 8 6 Constant trimming of and the supervision of trees within public workers; ROW employ qualified workers; train workers; set procedures for safe operation; prohibit the public from the sites during works

Excavation Workers 2 3 2 2 7 5 Constant during supervision of quarrying workers; employ qualified workers; train workers; set procedures for safe operation

Clearing of Workers 3 4 4 2 11 9 Constant base / camp supervision of sites workers; employ qualified

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

workers; train workers; set procedures for safe operation

6 Fires and Vegetation Clearing for Workers 3 3 3 2 9 7 Waste should explosions and other access and and the never be burnt; waste from sites of public follow waste clearing poles management plan

Clearing for Workers 2 3 3 2 8 6 Waste should quarrying and the never be burnt; public follow waste management plan

Clearing of Workers 2 3 3 2 8 6 Waste should base / camp never be burnt; sites follow waste management plan

7 Personal Hanging trees Physical Workers 3 2 3 3 8 5 Use trained injuries such as branches, survey of personnel that cuts, struck by stones, proposed incorporate objects, equipment project sites health and stepping on etc. safety issues in objects, falls the work programmes;

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

use personal protective gear

Clearing for Workers 4 3 5 1 12 11 Use trained

access and and the personnel that sites of public incorporate poles health and safety issues in the work programmes; provide personal protective gear; prohibit public access to sites

Felling and Workers 2 2 5 2 9 7 Use trained trimming of and the personnel that trees within public incorporate ROW health and safety issues in the work programmes; provide personal protective gear

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Excavation Workers 2 4 2 2 8 6 Use trained during and the personnel that quarrying public incorporate health and safety issues in the work programmes; provide personal protective gear; prohibit public access to sites

Stockpiling Workers 3 4 4 3 11 8 Prohibit public of materials and the access to public stockpiles; use security personnel

Clearing of Workers 2 2 4 2 8 6 Use trained base / camp personnel that sites incorporate health and safety issues in the work programmes; provide

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

personal protective gear

Clearing for Workers 2 3 3 2 8 6 Provide quarrying and the personal public protective gear; prohibit public access to quarries; supervise constantly

8 Risks related to Long Excavation Workers 4 3 5 2 12 10 Use excavation ergometrics; materials, during machinery poor manual heavy quarrying rather than handling etc. materials, manual labour; tasks involving allow adequate

bowing for breaks during long work

Stockpiling Workers 4 4 4 1 12 11 Use machines to of materials assist moving heavy and long loads; supervise constantly

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

9 Respiratory Dust, gaseous Clearing for Workers 4 2 5 3 11 8 Provide masks risks vehicular access and and the for workers; emissions sites of public prohibit public

poles access to work

sites; give prior notification particularly for

LV lines within populated areas

Felling and Workers 2 2 4 3 8 5 Provide masks trimming of for workers; trees within prohibit public ROW access to work sites

Clearing for Workers 3 3 5 2 11 9 Provide masks quarrying for workers

Excavation Workers 5 3 5 2 13 11 Provide masks during for workers quarrying

Stockpiling Workers 2 2 3 2 7 5 Provide masks of materials for workers; prohibit public access to work sites

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Clearing of Workers 2 3 5 2 10 8 Provide masks base / camp for workers sites

10 Insecurity from Aggressive Siting of Workers 4 4 2 3 10 7 Early burglary, PAPs, poles in land consultation; threats and stockpiles left owned or involvement of personal in the open used by village heads; attacks villagers use well trained

personnel; work

in teams; use base camps and provide security

Stockpiling Workers 2 2 5 4 9 5 pack materials of materials only at designated bases / camps; employ security personnel

11 Contagious Microbes Physical Workers, 2 4 5 2 11 9 Education and illnesses, (e.g. STIs, E- surveying villagers awareness on ingestion of coli, Covid 19) prevention and contaminated relevant codes

food or drink of conduct; provision and

use of masks, condoms

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Clearing for Workers, 4 4 5 2 13 11 Educate access and villagers workers and

sites of communities of poles risks and prevention of contagious illnesses; provide protection; provide sanitation means for workers; reduce importation of workers

Felling and Workers, 2 4 3 2 9 7 Educate trimming of villagers workers and trees within communities of ROW risks and prevention of contagious illnesses; provide protection; provide sanitation

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

means for workers

Clearing for Workers 2 4 2 2 8 6 Educate quarrying workers and communities of risks and prevention of contagious illnesses; provide protection; provide sanitation means for workers

Clearing of Workers 2 4 3 2 9 7 Educate base / camp workers and sites communities of risks and prevention of contagious illnesses; provide protection; provide sanitation

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

means for workers

12 Risks related to unethical / Siting of Villagers 3 3 4 2 10 8 Educate PAPs on unethical untrained poles in land (especially the RAP and workers workers owned or women, GRM. Educate (Discriminating used by children, workers on vulnerable villagers disabled) involuntary PAPs, resettlement Physical Workers, 2 3 4 2 9 7 insensitivity to and loss of surveying of villagers local norms, livelihoods proposed alcohol/drug safeguards; sites abuse impacts) Induction and monitoring of workers; include prohibition of substance abuse during work in the work rules; Replace workers with known record of discrimination; train workers on inclusiveness.

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

13 Wildlife Wildlife (e.g. Physical Workers 5 5 2 1 12 11 First aid kits attacks snakes, bees, survey of made available; (reptiles, dogs etc.) proposed discuss with the insects and project sites community

animals etc.) about wildlife risks; include

awareness on

response and recovery

Clearing for Workers 5 5 3 1 13 12 First aid kits access and made available; sites of discuss with the poles community about wildlife risks; include awareness on response and recovery

Felling and Workers 5 5 4 1 14 13 First aid kits trimming of made available; trees within discuss with the ROW community about wildlife risks; include awareness on

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

response and recovery

Clearing for Workers 5 5 3 1 13 12 First aid kits quarrying made available; discuss with the community about wildlife risks; include awareness on response and recovery

14 Risks of work Uneven Clearing for Workers 4 3 3 2 10 8 Use protective site conditions terrain, loose access and gear such as soil, wetland, sites of hard boots;

remote and poles work during low densely tides in vegetated wetlands; areas etc. supervisors to assess site

conditions and educate workers prior to work activities

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Clearing for Workers 3 3 5 2 11 9 Use protective quarrying gear such as hard boots; work during low tides in wetlands; supervisors to assess site conditions and educate workers prior to work activities

Felling and Workers 2 3 3 2 8 6 Use protective trimming of gear such as trees within hard boots; ROW work during low tides in wetlands; supervisors to assess site conditions and educate workers prior to work activities

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Excavation Workers 3 3 3 2 9 7 Use protective during gear such as quarrying hard boots; work during low tides in wetlands; supervisors to assess site conditions and educate workers prior to work activities; Avoid mining into caves

15 Work related Overexertion, Clearing for Workers 5 3 5 2 13 11 Control work stress hot work access and hours to include environments, sites of enough rest

long work poles time; do not hours, work at night; untrained for provide the task adequate training and

employ qualified workers;

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance

Excavation Workers 4 3 5 2 12 10 Control work during hours to include quarrying enough rest time; do not work at night; provide adequate training and employ qualified workers;

Source: S D Focus Ltd (2020) Risk significance Key: 0 means no significance of risk 1 - 5 means low significance of risk 6 - 9 means medium significance of risk 10 - 15 means high level of concern

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8.3 Mitigation of Risks The identified risks that have been analysed will be treated accordingly by implementing proposed mitigation measures, giving more attention to risks of medium to high significance. Mitigation measures range from training, change in design, alternative equipment, warning, and prohibition signage etc.

8.4 Training The contractor will develop an Internal Operation Plan to guide all workers, and will include works inspection and supervision, instructions and standard operating procedures for special activities such as working at heights, manoeuvring of vehicles carrying long materials (poles), storage of equipment and machinery outside established camps and the use of individual and collective protective equipment. Training will also be a continuous process to ensure awareness and improve skills including:

• Training of new staff on-the-job and on occupational health and safety including: - knowledge of materials and equipment - hazards and risks with coressponding managemnt options - risk exposure prevention - hygiene requiments - use of PPE - expected response - incident reporting procedures

• Periodic refresher training of existing workers as people tend to short-cut procedures with experience over time.

• Visitor orientation and restrcitions to work sites and camps

8.5 Emergency Response in Case of Incidents

Despite the risk assessment and implementation of mitigation measures, accidents may occur due to human error or machine failure etc. Therefore, the Contractor shall develop a contingency plan to guide emergency response in case of accidents. It should be relevant and realistic with regards to the activities, human capacity, and resource requirements.

The response plan will include actions to be taken when an incident (the risks with medium to high significance) occurs, and may include: • response actions for various accidents; • alerting workers, community members and visitors of the emergency situation; • identify roles and responsibilities, including coordination; • identify the relevant partners; • accounting for people; • evacuation to a safe location or for treatment; • procedures for notifying management, relatives, and the authorities.

Workers must however be trained on this plan and drills carried out to test it.

All accident sites must be cordoned-off to prevent bystanders and other workers from accessing the site. This will reduce impacts of potential secondary incidents such as unstable objects from an accident falling on people, and electrocution of rescuers getting into contact with electrocuted

108 victims. Moreover, restricting access will allow the rescuers to freely carry out activities without hindrance.

During and after all incidents, provision of facts is very important to prevent the spread of rumours. In some instances, requesting for expert support (firefighters, police officers, health personnel etc.) in a timely manner is necessary in efficiently responding to accidents.

8.6 Health and Safety Reporting and Recording The contractor should develop standard recording and reporting formats to ensure consistency and ease of comparison. These will ensure workers have means of immediately reporting to the supervisors, situations believed to have imminent risk of causing accidents and incidents that have already occurred. All work-related injuries, near misses, and suspected cases of diseases, particularly contagious diseases, should also be reported and investigated to ascertain what happened, the specific causes and means of preventing recurrences.

All the procedures and plans, reports, training programs and monitoring reports should be recorded and stored for evaluation and litigation purposes.

8.7 Health and Safety Monitoring OHS monitoing programs should be routinely carried during all phases of the Project to evaluate the effectiveness of the accident mitigation measures or response procedures. Monitoring will include: - safety inspection and testing of work equipment and processes - surveillance of the work environment - surveillance of the workers health and wellbeing - evaluation of trainings carried out includeing drills to out the knowledge to test.

Since the aim of this Chapter is to ensure that no one is injured or hurt by a hazard, following the above prescribed process should minimize the expected risks associated with health and safety in the implementation of the Projec

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CHAPTER 9: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

The Section presents the Environmental and Social Management Plan (ESMP), essentially an action plan which defines the basic management and monitoring measures that are needed to identify whether: a) impacts remain in conformance with predictions and applicable standards; and b) mitigation measures are effectively addressing impacts, and compensatory measures and offsets are reducing effects to the extent predicted. It is also to ensure compliance with the Bank’s OP 4.01.

9.1 Objectives of The ESMP

The Objectives of this ESMP are to:

- ensure environmental sustainability of the ECOWAS REAP in The Gambia; - provide a project specific environmental management guide to support the PIU during implementation; - identify responsibilities for the various environmental management actions; - provide an estimated budget for mitigation measures to ensure environmental issues and financial requirements are incorporated at the planning stage; - provide direction and guidance to the contractors whose focus is usually getting technical works done; - ensure the project is implemented according to environmental laws of The Gambia and policies of the WB. 9.2 ESMP Implementation and Monitoring Arrangements

9.2.1 Roles and Responsibilities for ESMP Implementation Implementation of this ESMP is the responsibility of the Contractor and PIU. Most of the mitigation measures are the responsibility of the Contractor who will be carrying out the works according to the C-ESMP that will be based on the Project ESIA/ESMP.

The supervising firm, Owner Engineer, will support the PIU in field supervision of all the contractors and their works. The Owner Engineer will also assist the PIU in the bidding processes and verifies that contractors abide by clauses in the contracts.

Communities will also have the responsibility of ensuring that villagers avoid work sites and report to NAWEC or relevant authorities, issues of concern related to the Project; the PIU and Contractor will engage the community regularly as an oversight measure in this regard, and conduct sensitization sessions to ensure communities are aware of reporting measures and understand Project risks.

As the Secretariat of the EIA Working Group7, and supported by its members, NEA will be responsible for the overall external monitoring of the ESMP implementation; in collaboration with the PIU ESS and

7 The EIA Working Group is one of nine multisector technical groups located at NEA. Nationally, NEA is the custodian of the ESIA process, and is supported by a multisector EIA Working Group which comprises the public sector, private sector and civil society, and at the Regional level, it is represented by the EIA/ANR (Agriculture and Natural Resources) Working Group sub committees of the Technical Advisory

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SSS, they will monitor compliance with the Bank policies as they relate to the environmental aspects of this Project. In addition to the permanent members in the EIA Working Group, other institutions on ad hoc basis will include those specialized in social aspects such as the Women’s Bureau, Department of Social Welfare, Department of Labor, and Department of Health Services, amongst others.

Meanwhile, monitoring of the implementation of the social aspects of the Project in line with the Bank’s safeguards instruments will be the responsibility of the PIU SSS.

The NEA will also provide technical support and participate in training and sensitization of stakeholders to enhance the understanding of the national and the Bank’s environmental safeguards instruments. Technical advice and/or regulatory information and support will be provided by the DOF for all forest related issues, the Department of Physical Planning and Housing (DPPH) and the Department of Lands and Surveys (DLS) will be responsible for addressing resettlement issues.

The Local Authorities and beneficiary community members will be relevant during the preparatory stage of the works, as they can provide valuable information to assist in the planning of the works.

The breakdown of the institutional arrangement for the ESMP implementation is as follows:

a) ECOWAS REAP Project Steering Committee in The Gambia (PSC) The ECOWAS-REAP Project Steering Committee (PSC), chaired by the Permanent Secretary, Ministry of Petroleum and Energy, will oversee all the activities of the Project, including the implementation of the ESMP, and any other relevant safeguards document. The Permanent Secretary, Ministry of Lands and Regional Governments (MOLRG) will be on the PSC due to the importance of the potential resettlement issues, and social risks relating to possible felling or pruning of private economic trees along the line corridors.

The PSC’s roles and responsibilities include: • oversee and monitor overall implementation of the ECOWAS-REAP safeguards documents including the ESMP, and RAP; • review and address all issues relating to resettlements and disputes; • review and monitor the progress reports; • Visit the Project sites to ensure progress of work and other activities.

b) ECOWAS-REAP Implementation Unit (PIU)

The PIU will consist of the following, among others: • project Coordinator; • Environmental Safeguards Specialist (ESS); • Social Safeguards Specialist (SSS); • power Engineer (PE); • procurement Specialist; • monitoring and Evaluation Specialist (M&ES).

Committees (TAC). A major responsibility of the EIA Working Group (whether at central or regional level), is to provide support to the NEA in assuring the quality and integrity of the EIA process. Specifically, it:

• Provides expert advice on the EIA process and review impact statements and ESMPs upon receiving requests • Approves impact statements and ESMPs • Conducts periodical environmental audits • Ensures that public consultations as part of the EIA process are done

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The PIU will oversee the implementation of this Project, including the ESMP. Its other responsibilities will include:

• ensuring alignment of the environmental and social safeguards standards applied to the Project; • working with the technical and procurement teams to ensure that contract documents contain Environmental and social safeguard clauses that Contractors must fully implement; • coordinating internal monitoring and evaluation of the ESMP based on monitoring plans; • coordinating Project related grievance redress activities. • Where applicable, facilitating Project related activities of partner stakeholders

c) National Environment Agency The NEA will be responsible for overall monitoring of the implementation of the ESMP, particularly the environmental component. According to Section 31 of the EIA Regulations 2014, NEA will monitor routinely to guide and audit the progress of the ESMP implementation to ensure compliance with both national laws and the policies of the Bank; NEA’s mandate is to monitor the national environment, and so in collaboration with the PIU safeguards specialists, can also monitor compliance with the Bank’s policies as they relate to this Project. The monitoring visits should be at least once quarterly, to provide technical advice and support in project implementation.

d) Ministry of Lands and Regional Governments In view of the high possibilities for the Project to trigger involuntary resettlement, the MOLRG will play a crucial role in the development and implementation of the RAP that may arise because of the Project.

Specific Roles and Responsibilities of Project Personnel

a) Project Coordinator (PC) The PC will oversee the implementation of the Project, and consequently the ESMP and will have the responsibility for ensuring that implementation of the ESMP is carried out as required under the national law and the World Bank’s Procedures.

b) Environmental Safeguards Specialist (ESS) The ESS is responsible for validating the ESIA and obtaining the environmental compliance certificate and publishing the ESIA. The ESS will make sure that all environmental measures outlined in the ESMP are integrated in the bidding documents and in the companies’ contracts. S/He will also assure the approving of the contractors’ site-ESMP.

The ESS will provide day-to-day management for all environmental issues and activities including implementation of the ESMP, in collaboration with NEA. He will prepare progress reports for submission to the PIU for transmission to the PSC, NAWEC, RCU (Regional Coordination Unit) and the World Bank. S/He will also directly oversee the implementation of the capacity building of stakeholders on environmental and social safeguards.

c) Social Safeguards Specialist (SSS) The ESS will make sure that all social measures outlined in the ESMP are integrated in the bidding documents and in the companies’ contracts. S/He will also make sure that all social measures outlined in the ESMP are integrated in the bidding documents and in the companies’ contract. S/He will provide day-to-day management for all social issues as they relate to implementation of any resettlement

112 issues; prepare periodic reports on progress on social issues; prepare progress reports on the level of potential PAPs, and their participation in project activities on the issues of resettlement.

These reports will be submitted to the PIU for transmission to the PSC, NAWEC, RCU (Regional Coordination Unit) and the World Bank. The SSS will directly oversee the implementation of the capacity building of stakeholders on the GRM and the Code of Conduct for addressing GBV, SEA and VAC.

d)Power Engineer (PE) The PE will integrate the construction phase mitigation measures and environmental and social clauses into the bidding documents; ensure that the Contactors obtain all the necessary approvals and integrate the relevant measures in the works breakdown structure or execution plan.

In collaboration with the ESS, SSS and other relevant members of the PIU (including the Procurement Specialist and Financial Management Specialist) the PE will ensure that contract documents contain environmental and social safeguard clauses spelling out the expectations of Contractors with regards to their mitigation responsibilities; Contractors must fully implement these clauses.

e) Monitoring and Evaluation Specialist (M&ES) Monitoring and evaluation activities are fundamental components of the ESMP to be carried out throughout the Project cycle. Monitoring of the ESMP implementation is normally the responsibility of the PIU whereas evaluation is undertaken by an external entity. The M&E Specialist will coordinate internal monitoring and evaluation of ESMP implementation based on the monitoring plan. Table 9.1 summarizes the above write-up on the roles and responsibilities for the implementation of this ESMP.

Table 9.1: Summary of Roles and Responsibilities in ESMP Implementation

No. Steps/Activities Responsible Collaborating Service Provider Partners Preparation of the works Contract documents, ESIA/RAP etc. in accordance with the national legislation/procedure (taking into account the World Bank’s policy requirements) 1 Preparation and approval of ESS/SSS; PC; PE NEA PIU the ToRs/Contracts Internal monitoring of ESMP ESS/SSS; PC; PE ESS; SSS Consultant implementation Report validation and ESS/SSS; NEA Consultant; World issuance of the permit (when ESS/SSS Bank required) Disclosure of the document PC NEA; NAWEC NAWEC and the Management PIU; also disclosed on the World Bank’s external website

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(i) Integrating the mitigation PE ESS/SSS; Contractor; NEA 2. measures of the construction NAWEC; PSC; phase and E&S clauses in the Engineer; bidding document prior to Contractor being advertised (see Appendix 8.1)

(ii) ensuring that the contractor integrates relevant ESMP measures in the works breakdown structure or execution plan / C-ESMP Implementation of the other ESS/SSS PE; M&ES; NEA Consultants; 3. safeguards’ measures, and EIA Working Other relevant including environmental Group; PSC; public institutions monitoring (when relevant) General public and sensitization activities Oversight of safeguards ESS/SSS/PC M&ES; PSC; NAWEC MD and implementation (internal) Management 4. Reporting on project PC M&ES; ESS, SSS; NAWEC MD and safeguards performance and PSC Management disclosure External oversight of the EIA Working PC; M&ES; ESS- NAWEC MD and project safeguards Group/NEA ECOWAS REAP; Management compliance and performance SSS; PSC 5. Building stakeholders’ ESS PC; SSS; NEA Consultant capacity in safeguards Other qualified management public institutions

9.2.2 Institutional Training and Sensitization During the consultations, it became evident that there is need for the members of the Regional Technical Advisory Committees (TACs) of the affected Regions to be trained in the general area of environmental and social administration, ESIA, GRM and ESMP management. They will also be trained on preventing and managing related GBV, SEA and VAC. Thus, it will be necessary to strengthen the capacity of members of the TACs, some NAWEC staff (including the ESS, SSS, etc.) on the safeguards, procedures, and resettlement programs. This will require organizing training workshops. Capacity building of NAWEC and other collaborating institutions is estimated at US$ 30,000 (see Table 9.2) to be started before the works begin.

In addition, public sensitization on the Project will be carried out to prevent complaints and conflicts, and to highlight community roles in promoting issues related to public health and safety at an estimated budget of $US 2,000 per Region (Total, $US 8,000).

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Table 9.2: Capacity Enhancement Program for Effective ESMP Implementation

No Identified Activity Expected Output Target Budget Beneficiary (US $) Institutional Capacity – Technical skills development and awareness creation 1 Workshops and meetings • Project components and NEA and TAC (5,000 x 4) to strengthen the human related activities known of WCR = 20,000 resource capacity of the • Capacity enhanced in EIA Regional TACs in managing Procedures ESIA • ESMP requirements understood • Roles and responsibilities of TAC members with regards to the ESMP understood • Plan for enforcement of the ESMP developed • Skills of the TAC members in GBV, SEA and VAC prevention and handling developed 2 Capacity building of • Environmental and social NAWEC Senior 10,000 relevant NAWEC staff safeguard issues understood Management Team and • Roles and responsibilities of other relevant NAWEC staff towards technical implementing the ESMP officers (E.g. understood from the planning, T&D and generation departments). Public Sensitization - Education, communication and information provision 3 Public sensitization to Increased community General (2,000 x 4) raise awareness on the participation on environmental public, = 8,000 Project issues (such as and social affairs related to the specifically project risks and benefits, Project communities developments, progress, where the GBV, SEA, VAC and GRM Project will be etc.) through relevant implemented radio/TV programs and meetings as appropriate TOTAL 38,000

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9.2.3 Monitoring Once the Project commences, including implementation of accompanying mitigation measures, monitoring must be carried out by the different stakeholders to ensure effectiveness in maintaining environmental and social sustainability. Monitoring will act as an oversight mechanism to remind and push the one responsible for mitigation that they are under guard and enforcement action may be executed upon them for any breaches.

Issues to be monitored include activities that have been identified earlier to have potential significant negative impacts on the environment and socio-economic parameters, and their corresponding mitigation actions. Routine monitoring may also identify new issues that have arisen due to changes (at the sites, or in Project design or activities) that will need alternative mitigation measures. Thus, appropriate mitigation will be developed accordingly.

Internal monitoring will be the responsibility of the Environmental Safeguards Specialist and Social Safeguards Specialist within the PIU, in addition to ensuring compliance with the World Bank’s social and environmental policies.

The recommended arrangements and roles for implementing the ESMP will also be evaluated for completeness, and improvements suggested where necessary.

The NEA and other relevant institutions identified in the ESMP will monitor for compliance with requirements under Gambian law. Selected relevant TAC members (including the representatives of NEA and NAWEC who will provide leadership and technical support respectively) will conduct monitoring visits to the Project sites. TAC members whose sectoral expertise will not be useful, nor add value to the process, will not be included in the TAC monitoring team. This arrangement will ease coordination and lower expense on resources. Furthermore, it will be more cost-effective and focused to use the regional TACs than displace members of the national EIA Working Group (in the Greater Banjul Area) to monitor Project activities in the respective Regions where the Project will be implemented. The regional TACs are also supposed to be more familiar with the local terrain and communities.

NEA’s representative in the TACs will forward the monitoring reports to the NEA Headquarters for eventual transmission to the PIU. To support the TACs in monitoring, an estimated budget of US$ 20,000 is recommended for the entire implementation of the Project. Disbursements should be made when due to the Offices of the Governors with NEA at TAC providing oversight, coordinating the monitoring visits to the Project sites. A monitoring plan with frequency and indicators is further outlined in Table 9.3, and an estimate for the cost of mitigation has also been provided in Table 9.4.

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Table 9.3: ESMP Monitoring Program

Mitigation Responsibil Monitoring Time to Monitoring Monitoring outputs to be ity Responsibility monitor frequency indicators monitored for mitigation 1 Involuntary NAWEC ESS/SSS/NEA/ Before initial Monthly during • No. of sensitization resettlement MOLRG works and any RAP sessions considering of PAPs development development land use and addressed and ownership issues implementation • RAP report developed • RAP fully implemented Loss of land, NAWEC ESS/SSS/NEA/ Before initial Monthly during • No. of consultative crops, MOLRG works and any RAP sessions economic development development • No. of related trees, assets, and complaints livelihood, and implementation • RAP developed inheritance • RAP implemented addressed • No. of PAPs compensated as compared to the total no. of PAPs 2 Protection of Contractor NEA/DOF During and Monthly during • No. of forest tress forest trees / after works RAP felled and effect on NAWEC development • No. of forest trees the and pruned environment, implementation • No. of wildlife landscape, species impacted drainage and • No. of sensitization wildlife meetings on forest and biodiversity • No. of nesting grounds protected • Tree replacement plan implemented • No. of reports of illegal activities 3 Protection Community SSS with Before and Quarterly • No. of sensitization against Gender NAWEC support from during project meetings on GBV Based Violence the Women’s implementatio codes of conduct and Sexual Bureau and n • No. of women Exploitation Department of participating in and Abuse Social Welfare consultations • % of women PAPs addressed • No. of community sensitization meetings where

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Mitigation Responsibil Monitoring Time to Monitoring Monitoring outputs to be ity Responsibility monitor frequency indicators monitored for mitigation GBV/SEA and discrimination are discussed • No. of meetings on GRM • Reports on progress in enforcement of Codes of conduct to address GBV/ SEA etc. • Number and type of complaints through the GRM including SEA/GBV • Number and type of complaints relating to discrimination exclusions from benefits and inequality (for example based on vulnerability such as sex, age, etc.) • Number of women hired in the Project Tenure NAWEC / NEA/MOLRG Before works Monthly during • No. of consultative security for community RAP sessions considering women development women’s land and tenure implementation • No. of related complaints • No. of women receiving equitable benefits and access to land rights 4 Women and Contractor/ PIU SSS Before and Annually • No. of women youth NAWEC during works participating in considered consultations • No. of youth participating in consultations (male and female) • No. of youth employed by the Project (male and female)

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Mitigation Responsibil Monitoring Time to Monitoring Monitoring outputs to be ity Responsibility monitor frequency indicators monitored for mitigation 5 Protection Contractor PIU SSS Before and Quarterly • No. of reports of from Violence / NAWEC during project child labor / abuse Against • No. of women Children participating in consultations • % of children PAPs addressed • No. of Community sensitization meetings where VAC issues are discussed • No. of meetings on GRM • Reports on progress in enforcement of Codes of conduct to address VAC. • No. of reports of children involved in Project related accidents 6 Public and Contractor ESS/SSS/NEA During land Quarterly • No. of accidents worker health Beneficiaries preparation, related to the and safety construction, Project activities and operation • No. of health education / sensitization sessions • No. of reports on works during nighttime • No. of heavy vehicle/machinery left broken down • No. of complaints /reports on lack of measures to address air polluting emissions • No. of dust suppression equipment • No. of protective gear provided to workers 7 Proper waste Contractor ESS/SSS/NEA During works Quarterly • No. of waste dumps management and operation on and around sites

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Mitigation Responsibil Monitoring Time to Monitoring Monitoring outputs to be ity Responsibility monitor frequency indicators monitored for mitigation • No. of sensitization meetings on waste management • No. of contracts that included waste management clauses • Waste management plans developed • No. of reports/complaints on waste management issues 8 Employ local Contractor/ ESS/SSS/NEA/L Before works Annually • No. of people labor NAWEC abor and during employed from the Department works local communities • No. of contracts that specify use of local labor 9 Consultation Contractor/ NEA/ESS/SSS Before and Biannually • No. of consultative and NAWEC during works meetings with participation beneficiaries of • No. of complaints on beneficiaries lack of consultation • No. of minutes /reports of consultations • No. of persons in attendance 1 Social NAWEC / NEA/PIU Before and Quarterly • No. of locals 0 cohesion community during works employed • No. of community conflicts 1 Prevention of Contractor NEA/GD/PIU Before and Quarterly • Mine management 1 impacts from during works Plans developed quarrying on • Reports on process geology, of mining landscape, • No. of mining wildlife, approvals from GD agriculture etc. 1 Soil Contractor ESS/SSS/ During works Quarterly • No. existing new 2 compaction NEA and operation routes established from vehicles / • Lengths of access machinery roads graded and controlled improved

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9.2.4 Reporting As monitoring of the ESMP implementation falls under the general monitoring and evaluation system of the Project, its reporting should be synchronized. This will ensure efficient reporting and communication of the ESMP related issues to all relevant stakeholders for holistic management, particularly where changes for improvement are recommended.

It is recommended that the NEA submits annual reports to NAWEC (through the ECOWAS REAP PIU) on its monitoring of the ESMP implementation. NEA will work with its Regional Environment Officers to ensure issues reported by the TACs are incorporated and follow-up actions by the various affected institutions and stakeholders coordinated accordingly.

Where incidents or accidents occur that require immediate action, NEA shall report to NAWEC immediately, and NAWEC should in turn notify the World Bank as soon as possible.

The PIU, according to its work plan, shall submit all reports to the World Bank for consideration.

9.2.5 Environmental Auditing According to Part VI of the EIA Regulations, 2014, environmental audits should be carried out by the Project and the NEA. A systematic environmental audit shall evaluate predictions made during the ESIA study and determine the level of implementation of proposed mitigation measures. The audit may also identify potential impacts that have arisen due to any modification in planned design or activities; or changes to environmental and social parameters.

The Project may carry out self-audit to include review of its activities, the Project ESMP implementation, monitoring reports and any subsequent improvement measure, capacity, and communication between the affected stakeholders amongst others.

Whilst the self-audit is a routine activity of the PIU, an independent environmental audit will be carried out midway during implementation of the ESMP and upon project completion, preferably by an external auditor to avoid conflict of interest.

Environmental Inspectors of the NEA are also empowered to carry out audits in their own time, with the aim of confirming that all mitigation measures are complied with, and any breach pursued for appropriate redress.

9.2.6 Budget for Implementation of the ESMP The proposed budget for implementation of the ESMP is US$ 62,000 as indicated in Table 9.4.

Table 9.4: Estimated Budget to Implement the ESMP

No. Activity Time Frame Budget (US$) Responsibility Responsibility to implement coordinate measure 1 Capacity Building Workshops and meetings to First quarter of 5,000 PIU/ESS/SSS NEA strengthen the capacity of the Project the Regional TACs in implementation managing ESIA and RAP Capacity building of relevant Annually during 10,000 PIU/ESS/SSS PIU/NAWEC NAWEC staff on project Management / implementation

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environmental and social safeguards and their roles Public sensitization to raise First and second 8,000 PIU/ESS/SSS NEA awareness on the Project quarter of the issues through relevant radio project / TV programs and meetings implementation ESMP Implementation, Monitoring, Evaluation and Reporting 2 Implementation of the Annually during 10,000 PIU PIU mitigation measures all phases (construction, operations, and maintenance) Regular environmental and Project 5,000 NEA PIU social monitoring of the implementation implementation of mitigation period measures and the activities. Audit of environmental and During and after 10,000 Independent PIU/NEA social measures construction Consultant Operation of the GRM 3 Field investigations Project 5,000 GRC SSS/PIU implementation period Implementation of GRM Annually during 9,000 (pa) PIU NEA related to activities and all phases mitigation measures (construction, operations, and maintenance 62,000 TOTAL

9.3 Matrix on the Mitigation of the Identified Potential Negative Impacts Table 9.5 illustrates the proposed mitigation measures for the potential impacts identified during all Project activities; specific mitigation measures have also been highlighted for the various activities (pole construction and stringing, operation of the transmission and distribution lines, and any quarries).

Responsibilities for specific mitigation measures, period of expected mitigation, and responsibility for monitoring have been identified.

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Table 9.5: Potential Impacts and Corresponding Mitigation Measures

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline

CONSTRUCTION WORKS (LAND PREPARATION, EXCAVATION FOR POLE CONSTRUCTION AND STRINGING OF LINES) Land acquisition Involuntary resettlement of Prepare and implement a RAP to NAWEC/PIU Before works Regional TACs with In RAP for pole location PAPs; loss of crops and evaluate all potential losses NEA to coordinate, budget earnings; loss of livelihoods MOLRG Works within Loumo (weekly market Contractor During works Regional TACs - day) sites must not be carried during such days Gender-based Violence; Conduct community sensitization NAWEC/PIU Before works Regional TACs where Under total Sexual Exploitation and meetings on the need for everybody to NAWEC is co-opted as capacity Abuse; Violence Against benefit from project activities Project a member building Children; discrimination of irrespective of gender (inclusive access Affected budget ($US women in employment to benefits); Community 38,000) opportunities; in tenure and Leaders disproportionate 50/50 sharing of project and compensation resettlement benefits between men and women Ensure awareness of the GRM NAWEC/PIU Before and PIU Social Safeguards - during operation Specialist Monitor risks for escalating tensions Affected All phases PIU Social Safeguards - communities Specialist

8 (No value = included in PIU’s safeguards activities) Mitigation measures that are to be done by the PIU have no budget attached as costs are included in the PIU’s safeguards activities; other measures without values have no mitigation costs such as community leaders encouraging women to participate in decision making, and reporting of illegal activities such as illegal felling of forest trees

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Encourage women and other vulnerable NAWEC/PIU All phases PIU Social Safeguards - groups to raise their concerns safely and Specialist anonymously, if they so choose, on the Project resettlement process and other issues Affected Communities Encourage women to enlist for Contractor All phases NAWEC/PIU Contractor’s employment in project activities without Social Safeguards budget any impediments put in their way; Specialist

Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women;

Enforce and monitor Codes of Conduct for workers and all those involved in the project

Sensitize about the Codes of Conduct for workers and community;

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

Conduct periodic training of employees on the codes of conduct and related procedures

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Include the above measures in bidding NAWEC/PIU Before works PIU Social Safeguards - documents including, codes of conduct Specialist for GBV, SEA and VAC, for contractors to enforce on their employees Felling and Compensation of PAPs; loss Prepare and implement a RAP to NAWEC/PIU Before Regional TACs (to be For RAP trimming of of livelihoods and access to consider any loss of farmland, fruit and construction coordinated by the budget economic trees resources timber trees, livelihood sources, works start NEA) property, and usufructs etc. Trimming of fruit trees should be carried Contractors During works PIU Social and - out only when tree branches are on the Environmental ROW of lines Safeguards Specialists Gender-based Violence; Conduct community sensitization NAWEC/PIU Before works Regional TACs where Capacity Sexual Exploitation and meetings on the need for everybody to NAWEC is co-opted as building Abuse; Violence Against benefit from project activities Project a member budget Children; discrimination of irrespective of gender (inclusive access Affected women in employment to benefits); Community opportunities; in tenure and Leaders disproportionate 50/50 sharing of project and compensation resettlement benefits between men and women Ensure awareness of the GRM NAWEC/PIU Before and PIU Social Safeguards - during operation Specialist

Monitor risks for escalating tensions Affected All phases PIU Social Safeguards - communities Specialist

Encourage women and other vulnerable NAWEC/PIU All phases PIU Social Safeguards - groups to raise their concerns safely and Specialist anonymously, if they so choose, on the resettlement process and other issues

144

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Project Affected Communities Encourage women to enlist for Contractor All phases NAWEC/PIU Contractor’s employment in project activities without Social Safeguards budget any impediments put in their way; Specialist

Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women;

Enforce and monitor Codes of Conduct for workers and all those involved in the project

Sensitize about the Codes of Conduct for workers and community;

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

Conduct periodic training of employees on the codes of conduct and related procedures Include the above measures in bidding NAWEC/PIU Before works PIU Social Safeguards - documents including, codes of conduct Specialist for GBV, SEA and VAC, for contractors to enforce on their employees

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Land clearance Loss of vegetation along line Remove vegetation around pole site only Contractor Before and Regional TACs (NAWEC - and preparation corridor as necessary during works co-opted as member) Cover area around the pole foundations Contractor During and after NAWEC/PIU Contractor’s to facilitate revegetation works budget Loss of livelihoods (e.g. Prepare and implement RAP NAWEC/PIU Before beginning TAC (to be coordinated For RAP rangeland, firewood, other of works by the NEA) budget usufructs etc.) Destruction of forest trees Compensatory reforestation will be NAWEC/PIU Before beginning DOF For RAP and effect on the developped and implemented in of works budget environment, landscape, collaboration with the forestery drainage and wildlife department. Ensure that only the right of way is Contractor Before and NAWEC/PIU/ and TAC - cleared; avoid forests during works with DOF leading the Seek approval from DOF before forest process trees are felled Keep records (types and quantities) of all ‘forest trees’ to be fell Educate and warn workers to avoid burning activities Hunting by imported workforce will be Contractor Before, during NAWEC/PIU/TAC - prohibited; and after works

All employees, including volunteers and sub-contractors encouraged to anonymously report suspected or actual acts of hunting/killing of wild animal by a fellow worker

Disciplinary measures must be applied Contractor During works NAWEC/PIU/TAC Contractor’s budget

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline The endangered and threatened and Contractor/ Before and DPWM/NEA/PIU Contractor’s endangered species must be protected DPWM during works Environmental budget by: Safeguards Specialist

Enforcing more vigorously the relevant laws and regulations that prohibit its killing

Conducting training and information meetings on its preservation and protection at community level at least once every quarter

Creating community wildlife reserves where threatened species such as the baboon could be protected Avifauna nesting grounds and migratory Contractor Before and DPWM / PIU - paths are to be protected during works Environmental Safeguards Specialist Soil compaction from Use only approved and existing routes Contractor During works Regional TACs / - vehicles / machinery Communities destroying farmland and Do not establish new routes Contractor During works Regional TACs / - causing erosion Communities Grade existing routes to improve surface Contractor During works Regional TACs / Contractor’s drainage Communities budget Destruction and loss of Inform relevant parties of the Chance NAWEC PIU/ Before and NCAC, PIU Social - cultural, historical or Find Procedures and apply where Contractor during works Safeguards Specialist archaeological sites applicable

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Avoid mosques, cemeteries, World Contractor Before and NCAC/ - Heritage Sites and similar sites of cultural during works Regional TACs / significance Communities Consult with community to help identify Contractor Before and NCAC/ - any other cultural or spiritual sites of during works Regional TACs / importance Communities All Construction Nuisance from noise, Integrate ESMP into Contract Bidding NAWEC PIU In contract PIU Social Safeguards - Activities vibration, and air pollution Documents and ensure compliance by before works, Specialist / from dust or hydrocarbon Contractor Contractor and during works Regional TACs / (During all land non-combustion emissions Communities preparation and Works shall only be carried out during Contractor During works Regional TACs / - construction daytime Communities activities including Use dust suppression measures such as Contractor During works Regional TACs - establishment of dampening base camps) Provide masks and necessary protective Contractor During works Regional TACs Contractors’ gear to workers with the aim of budget preventing dust related health problems and other dust nuisances Use well-serviced equipment and Contractor During works Regional TACs Contractor’s machinery; avoid overloading that budget strains the engines Trucks transporting sand and gravel must Contractor During works Regional TACs Contractor’s be covered to prevent dust and flying budget debris Ensure that engines of vehicles and Contractor During works Regional TACs Contractor’s machinery are not idle for prolonged budget periods unnecessarily Special care will be taken when working Contractor During works Regional TACs / PIU Contractor’s near educational institutions and health Social Safeguards budget facilities such as: Specialist

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline

Giving prior notice to the institution about the works

Cordoning off work sites to prevent access

Working during weekends when activities are less around these institutions

Reduction in water quality Protect water sources and report any Contractor / During works Regional TACs / - of tributaries along the noticeable reduction in quality Communities Department of Water corridors due to Resources construction activities Effects of improper Develop a waste management plan Contractor Develop plan NEA / PIU management of wastes including types of waste, expected before works, Environmental (solid and liquid/used oils, quantities and frequency, proposed and implement Safeguards Specialist machine parts, and storage and disposal procedures and during works domestic and sanitary responsibilities, etc. waste, excess materials left Do not burn any type of waste Contractor All phases Regional TACs / - on sites, cement bags, etc.) Communities on land, water, fauna, and Set an internal supervision and Contractor Before, and NEA / PIU Contractor’s public health monitoring system to ensure waste implement Environmental budget reduction and management during works Safeguards Specialist Waste must be collected and stored for Contractor During works NEA / PIU - disposal or treatment at approved sites Environmental as per waste management plan Safeguards Specialist

149

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Clean waste such as cleared vegetation, Contractor During works NEA / PIU - packaging and rubble shall be given to Environmental workers or communities for reuse and Safeguards Specialist recycling Ensure waste management issues are NAWEC PIU Before works PIU Environmental - incorporated in Agreements with the Safeguards Specialist Contractors Unpleasing landscape and Remove excess and unused materials Contractor During works NEA / PIU - impact on aesthetics and equipment from work sites Environmental Safeguards Specialist Replace lost vegetation cover NAWEC PIU During and after Regional TACs For RAP works budget Risks to public health and Restrict and monitor public access to the Contractor/ During the works NAWEC PIU - safety during construction work sites communities (at pole sites, quarries, Integrate staff training especially drivers Contractor Before and NAWEC PIU - camp sites, within on defensive driving during works beneficiary communities Construction works within the Loumo Contractor During works NAWEC PIU / Regional - etc.), from imported area on a market day must be avoided TACs including NEA diseases, VAC, SEA, GBV, Cover up the trucks, to prevent wind Contractors In contract Regional TACs Contractor’s and work site hazards etc. blowing away sand and gravel to before works budget generate dust and during works Initiate sensitization and education NAWEC PIU In contract PIU Social Safeguards For capacity programs for communities and workers before works Specialist building on the dangers and mitigation measures and during works budget to address STIs; Contractor Encourage use of condoms to prevent STIs

150

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Carry out active monitoring of workers Contractor Before and Regional TACs with Contractor’s (screening, testing and analysis of such during works Department of Health budget recorded data, etc.) to take timely action Services leading through treatment and health education to prevent spread of diseases Ensure surroundings are safe and secure Contractor Before and Regional TACs with Contractor’s for all (implement health and safety plan, during works Department of Health budget coordinate, inform, supervise and Services leading monitor) Employ local unskilled workers to Contractor Before and NAWEC PIU - enhance community cohesion as local during works workers will know the community better, its culture, norms, and values, which may also help in reducing the risks of GBV, VAC and STIs. Risk of violence against Ensure enforcement and adherence to Contractor Before and Regional TACs, Contractor’s children and women Codes of Conduct for addressing VAC, during works Communities / budget GBV, and SEA, including regular Department of Labor monitoring and awareness building of the Codes of Conduct Do not employ or exploit children for Contractor Before and Regional TACs, - project works during works Communities / Department of Labor Conduct community sensitization NAWEC/PIU Before works Regional TACs where Capacity meetings on the need for everybody to NAWEC is co-opted as building benefit from project activities Project a member budget irrespective of gender (inclusive access Affected to benefits) Community Leaders

151

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Ensure awareness of the GRM NAWEC/PIU Before and PIU Social Safeguards - during operation Specialist Monitor risks for escalating tensions Affected All phases PIU Social Safeguards - communities Specialist Encourage women and other vulnerable NAWEC/PIU All phases PIU Social Safeguards - groups to raise their concerns safely and Specialist anonymously, if they so choose, on the Project resettlement process and other issues Affected Communities Encourage women to enlist for Contractor All phases NAWEC/PIU Contractor’s employment in project activities without Social Safeguards budget any impediments put in their way; Specialist

Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women;

Enforce and monitor Codes of Conduct for workers and all those involved in the project

Sensitize about the Codes of Conduct for workers and community;

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

152

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Conduct periodic training of employees on the codes of conduct and related procedures Include the above measures in bidding NAWEC/PIU Before works PIU Social Safeguards - documents including, codes of conduct Specialist for GBV, SEA and VAC, for contractors to enforce on their employees Risks to health and safety of Provide induction and training on the job, Contractor Before and NAWEC PIU Contractor’s workers (work related safety issues and other relevant ESMP during works budget stress, heat stress, requirements electrocution, falls, Make the hiring medical examination for Contractor Before and NAWEC PIU Contractor’s mechanical accidents, all workers compulsory during works budget human conflict, wildlife attacks, poor handling Sensitize on interpersonal relationship Contractor Before and NAWEC PIU Contractor’s techniques, diseases etc.). management between and among during works budget workers and community members; set codes of conduct Provide appropriate protective gear Contractor Before and PIU Social Safeguards Contractor’s (helmets, masks, safety goggles, hand during works Specialist / Regional budget gloves and rubber boots, etc.) to workers TACs Provide fire extinguishers and first aid Contractor Before and PIU Environmental and Contractor’s kits including training on their use during works Social Safeguards budget Specialists / Regional TACs Provide constant supervision and record Contractor During works PIU Environmental and Contractor’s and report incidents to address causes Social Safeguards budget for preventing recurrence and promoting Specialists / Regional improvement TACs

QUARRY SITES

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline Quarrying earth Quarrying impacts on Where sand and gravel dealers are used, Contractor Before works NEA/Geology - materials (gravel / geology, landscape, ground ensure only suppliers certified by the Department sand) for water, wildlife, and NEA and GD are used construction agriculture, etc. Ensure approval is obtained from the Contractor Before works NEA/Geology - works NEA and GD for any proposed quarry site Department

Fully implement the mine management Contractor During mining NEA/Geology - plans Department All quarry pits created by the project Contractor After mining is NEA/Geology Contactor’s’ must be rehabilitated after construction completed budget works Ensure the above measures are included NAWEC/PIU Before works PIU ESS - in bidding documents for contractors Indirect water Avoid extraction to the water table and Contractor During operation NEA/Geology - contamination by exposure near surface water bodies of quarries Department of groundwater from over extraction

OPERATION OF THE TRANSMISSION AND DISTRIBUTION NETWORKS (INCLUDING MAINTENANCE) All activities Effects from improper waste Develop a waste management plan NAWEC as the Develop plan NEA / NAWEC To be funded during operation management of items such including types of waste, expected operator of the before, and by NAWEC as of the as trimmed vegetation, quantities and frequency, proposed T & D networks implement part of T & D networks broken cables, broken storage and disposal procedures and will be during operation its poles, old and worn out responsibilities etc. responsible for operational (including routine parts such as bolts and knots Waste must be collected and stored for all mitigation During operation NEA / NAWEC mandate clearing of ROW, disposal or treatment at approved sites during connection to as per waste management plan operation; users, repair, Do not burn any type of waste where During operation NEA / Communities

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Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline maintenance and Clean waste such as cleared vegetation contractors are During operation NAWEC’s ESS and SSS replacement of T and packaging shall be given to workers used for & D infrastructure or communities for reuse and recycling specific parts) Set an internal supervision and activities rather During operation NAWEC’s ESS monitoring system to ensure waste than NAWEC reduction and management including staff, all training of relevant NAWEC staff mitigation Ensure waste management issues are measures Before specific NAWEC’s ESS - incorporated in Agreements with the corresponding works Contractors carrying out maintenance to the activities works such as tree pruning and electricity should be connection to users included in Risk of violence against Ensure enforcement and adherence to contracts Before and NAWEC’s ESS and- SSS children and women Codes of Conduct for addressing VAC, during works GBV, and SEA, including regular monitoring and awareness building of the Codes of Conduct Do not employ or exploit children for Before and - project works during works Ensure awareness of the GRM Before and - during operation Monitor risks for escalating tensions All phases - Encourage women and other vulnerable All phases - groups to raise their concerns safely and anonymously, if they so choose, on the resettlement process and other issues Encourage women to enlist for All phases - employment in project activities without any impediments put in their way;

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Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

Conduct periodic training of employees on the codes of conduct and related procedures Risks to health and safety of Provide induction and training on the job, Before and NAWEC ESS and SSS - workers, operators etc.) safety issues and other relevant ESMP during works requirements (E.g. fires, electrocution, Ensure medical exams are compulsory Before and NAWEC ESS and SSS - explosions, pest and wildlife prior to employment during works attacks in remote areas, falls Provide appropriate protective gear Before and NAWEC ESS and SSS - etc.) (helmets, masks, safety goggles, hand during works gloves and rubber boots, etc.) to workers Sensitize on interpersonal relationship Before and NAWEC ESS and SSS - management between and among during works workers and community members; set codes of conduct Provide first aid kits including training on Before and NAWEC Environmental - their use during works and Social Safeguards Specialists Provide supervision; record and report During works NAWEC ESS and SSS - incidents to address causes for preventing recurrence and promoting improvement

156

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Monitoring Budget Responsibility Period / Responsibility ($US)8 Timeline DECOMMISSIONING Closure of Sites open to illegal Proper closure and timely restoration Contractors After mining and NAWEC PIU / NEA / - quarries exploitation after the and rehabilitation of borrow pits before Project Geology Department Project ends Monitor sites and report illegal activities Communities After restoration NEA/Geology - Department Dismantling and During decommissioning, all As per the construction phase for Contractors During TAC/NAWEC Contractor’s transportation of potential impacts on public mitigation of public and worker health decommissioning budget materials and and occupational health and safety; equipment from likely during construction, All mitigation measures are also the camp(s) are also significant applicable during decommissioning

Poor aesthetic quality from Implement measures prescribed in the Contractors During Regional TACs / PIU ESS Contractor’s excess materials and waste Waste Management Plan for decommissioning budget abandoned on camp sites decommissioning activities Ensure waste management issues are NAWEC Before works NAWEC’s ESS - incorporated in Agreements with the Contractors carrying out decommissioning works Risk of leakages, fires and Remove all fuel storage facilities Contractors During Regional TACs / PIU ESS - explosions from abandoned including burnt/used oils decommissioning fuel facilitates Total 38,000

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Considering the evaluation of the potential impacts of the Project, and the recommended mitigation measures, it is concluded most of the adverse environmental impacts are short-term, localized, and small scale, and can be mitigated through this ESMP. With full implementation of the ESMP in a timely manner, the beneficiaries/affected communities will be better-off with the Project than without it.

CONCLUSION

The ECOWAS-REAP in The Gambia is expected to generate temporary and long-term employment, economic development from improved services dependent on reliable electricity and consequently improved livelihoods.

In The Gambia, indirect benefits to the biophysical environment expected from the Project include protection of natural resources from overexploitation as the increased access to electricity will create alternative means of livelihood. For example, welding and carpentry as compared to fuelwood burning; cooling of seafood rather than smoking for preservation; and cold storage of perishable foods during increased agricultural productivity (more efficiency in production means less land and agrochemicals required).

Despite the potential benefits, the ECOWAS-REAP is likely to create socio-economic negative impacts such as involuntary resettlement and loss of livelihood as a result of land-use and land-take; public and occupational health and safety risks such as traffic accidents, falls from heights and imported contagious diseases; violence against vulnerable groups such as disproportionate compensation for women, sexual exploitation and child employment; destruction of cultural/historical sites of importance; and instability in the affected communities.

Negative environmental impacts include air and surface water pollution, vegetation clearing and destruction of forest trees with its indirect impact on dependent wildlife, land degradation causing erosion and invasion of environmentally sensitive protected areas that destroy biodiversity.

This ESIA recommends a resettlement action plan to address land and livelihood loss due to the Project implementation. Stakeholder consultation and participation during all phases will encourage ownership and prevent grievances. Training and sensitization of all relevant stakeholders in implementing their specific roles in the ESMP including the affected public, TACs, relevant NAWEC staff and workers to be employed by the Contractors.

It is recommended that the contractor develops the Contractors ESMP to specify and guide all mitigation measures related to the construction. This will include proper management of waste, avoidance of forests and other protected parks, avoidance of hunting, legal sourcing of earth materials and use of well serviced equipment and machinery that produces less emission. To mitigate the identified negative impacts, the PIU will ensure that the contractors’ agreements stipulate the ESMP requirements and that efficient monitoring takes place.

The total estimated cost for the ESMP implementation is US $62,000 (sixty-two thousand dollars).

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United Nations (2001) Convention to Combat Desertification (CCD) (1994) World Bank (March, 2020) Technical Note: Public Consultations and Stakeholder Engagement in WB- Supported Operations when there are Constraints on Conducting Public Meetings WB (1999) Operational Manual Operational Policies OP 4.01 Environmental Assessment WB IFC (2007) EHS General Guidelines http://hdr.undp.org/en/content/gender-inequality-index https://www.lavanguardia.com/natural/actualidad/20191021/471036333031/aguila-pesacadora- migres-red-electrica-plataforma-nido.html https://www.lavanguardia.com/natural/actualidad/20191021/471036333031/aguila-pesacadora- migres-red-electrica-plataforma-nido.html “The Gambia, Guinea Bissau, Mali and Economic Community of West African States (ECOWAS) - ECOWAS-Regional Electricity Access Project” (IDA/R2018-0379/1) dated November 26, 2018, with a closing date of December 13, 2018. Ramsar Wetland Study The Gambia, 1997). hdr.undp.org/en/countries/profiles/gmb chartsbin.com/view/4319 www.ecowrex.org/.../2008_ecowas_environmental_policy_-_ecowa… · PDF file

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Appendix 1: Brikama Feeders 1 and 2 Corridors

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Appendix 1.1: Brikama Feeder 3 Corridors – Sheet 1

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Appendix 1.2: Brikama Feeder 3 Corridors – Sheet 2

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Appendix 2: Communities Along the Brikama Feeders No: Village/Community District Population # of Household Total M F s BRIKAMA SUB-STATION FEEDER 1 1.1 Bafuloto Kombo Central 1389 697 692 189 1.2 Makumbaya Kombo North 2691 1333 1358 307 1.3 Kubaruko Kombo North 809 445 364 76 1.4 Galoya Kombo Central 686 337 349 85 1.5 Kubuneh Kombo Central 1455 725 730 151 1.6 Kunkujang Kombo North 21256 10721 10535 2861 1.7 Madinaring Kombo North 8559 4273 4286 830 Sub-Total 36845 18531 18314 4499 BRIKAMA SUB-STATION FEEDER 2 2.1 Kembujeh, Kombo Central 7633 3874 3759 733 2.2 Serekundanding Kombo Central 615 319 296 63 2.3 Tabakuta Kombo East 2026 1155 871 165 2.4 Bassore Kombo East 3352 1681 1671 246 2.5 Madina Talokoto Kombo East 700 350 350 97 2.6 Gidda Sukuta Kombo East 425 222 203 12 2.7 Giboro Kuta Kombo East 1624 831 793 248 2.8 Giboro Koto Kombo East 1248 620 628 213 Sub-Total 17623 9052 8571 1777 BRIKAMA SUB-STATION FEEDER 3 3.1 Mandinaba Kombo East 2390 1203 1187 277 3.2 Kuloro (Tunjina) Kombo East 716 361 355 71 3.3 Pirang Kombo East 2506 1227 1279 311 3.4 Berending Kombo East 3456 1695 1761 43 3.5 Faraba Banta Kombo East 3041 1451 1590 309 3.6 Sotokoi Kombo East 1449 706 743 146 3.7 Amdalie Kombo East 292 150 142 43 3.8 Faraba Sutu Kombo East 718 355 363 89 3.9 Sohm Kombo East 1116 579 537 144 3.10 Kafuta Kombo East 4415 2141 2274 470 3.11 Sanyangha Kombo East 452 239 213 56 3.12 Bullock Foni Brefet 4073 2054 2019 463 3.13 Buram Foni Bintang Karanai 171 90 81 18 3.14 Badjana Foni Brefet 1197 566 631 87 3.15 Sutusinjang, Foni Brefet 1615 809 806 189 3.16 Jagil Foni Berefet 333 158 175 38 3.17 Katakor Foni Bintang karanai 570 278 292 52 3.18 Besse Foni Brefet 895 402 493 93 3.19 Ndemban Foni Brefet 2372 1188 1184 298 3.20 Somita, Foni Brefet 2723 1322 1401 292 3.21 Jalokoto Foni Brefet 530 272 258 64 3.22 Tempoto Foni Bintang Karanai 429 224 205 46 3.23 Komosorr Foni Bintang Karanai 54 22 32 5 3.24 Sangajor Foni Kansala 870 427 443 108 3.25 Jomo Kunda Foni Kansala 213 104 109 28

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No: Village/Community District Population # of Household Total M F s 3.26 Jonyer Foni Kansala 124 64 60 15 3.27 Bajiran Foni Bondali 82 36 46 8 3.28 Bantajang Foni Bondali 75 39 36 8 3.29 Kallang Foni Bondali 41 23 18 4 3.30 Mayork Foni Bondali 579 296 283 48 3.31 Kafenkeng Bambarang Foni Bondali 972 502 470 116 3.32 Buramba Foni Bondali 151 76 75 11 3.33 Kanwally Foni Bondali 330 174 156 29 3.34 Jending Ba Foni Bondali 90 50 40 6 3.35 Kalimou Foni Bondali 108 51 57 9 3.36 Jendi Foni Bondali 31 20 11 3 3.37 Kanjibat Foni Bondali 74 32 42 11 3.38 Bondali Tenda Foni Bondali 143 74 69 15 3.39 Kankurang Foni Bondali 443 213 230 31 3.40 Bulengart Foni Bondali 199 103 96 18 3.41 Jorem Drammeh Kunda Foni Jarrol 72 39 33 11 3.42 Sibanor Foni Bintang Karanai 3118 1512 1606 436 3.43 Batabute Kantora Foni Bintang Karanai 810 392 418 80 3.44 Arragelen Foni Bintang Karanai 706 368 338 84 3.45 Janack – t-off from Kabacor Foni Bintang Karanai 400 208 192 49 3.46 Tampoto Koto Foni Bintang Karanai 133 72 61 12 3.47 Kanuma – t-off from Foni Bintang Karanai 344 182 162 35 Tampoto 3.48 Bajakarr Foni Bintang Karanai 729 350 379 74 3.49 Kanpart Foni Kansala 228 99 129 26 3.50 Kambong Foni Kansala 165 85 80 19 3.51 Genia, Foni Kansala 151 68 83 15 3.52 Bwiam Foni Kansala 3013 1496 1517 494 3.53 Darsilameh Foni Kansala 407 173 234 31 3.54 Nyadinding, Sangajor,– (t- Foni Kansala 38 15 23 4 off from Sangajor) 3.55 Burock Foni Kansala 309 168 141 34 3.56 Dumbuto – (t-off from Foni Kansala 184 99 85 17 Kanfenda) 3.57 Kappa – t-off from Foni Kansala 225 111 114 25 Kampant 3.58 Kalagi Foni Jarol 291 166 125 51 3.59 Sintet Foni Jarol 1171 559 612 135 3.60 Kanmamudu Foni Jarol 248 131 117 22 3.61 Kampassa Foni Jarol 735 444 291 71 3.62 Jonkel Foni Jarol 219 120 99 23 3.63 Chabai Foni Bondali 337 176 161 27 3.64 Wasswdu Foni Jarol 831 465 366 97 3.65 Arangkoli Kunda Foni Jarol 181 102 79 17 3.66 Jorem Drammeh Kunda Foni Jarrol 72 39 33 11 3.67 Jorem Bunda kunda Foni Jarrol 88 39 49 9

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No: Village/Community District Population # of Household Total M F s 3.68 Kambale ba Foni Jarrol 44 24 20 4 3.69 Nigie Kombo East 305 153 152 40 3.70 Omorto Kombo East 698 345 353 98 3.71 Brefet Foni Berefet 452 215 237 46 3.72 Kandunku Foni Bintang Karanai 543 265 278 54 3.73 Somita Foni Berefet 2723 1322 1401 292 3.74 Batendeng Kajara Foni Bintang karanai 341 160 181 34 3.75 Bulanjor Foni Bintang Karanai 388 186 202 35 3.76 Kaimo Foni Bintang Karanai 54 22 32 5 3.77 Kusamai Foni Bintang Karanai 449 234 215 52 3.78 Siwol/Kayanga Foni Bintang Karanai 446 254 192 44 3.79 Gilanfari Foni Bintang Karanai 210 98 112 19 3.80 Sitanunku Foni Bintang Karanai 44 22 22 5 3.81 Bajagarr Foni Bintang Karanai 729 350 379 74 3.82 Tampoto Foni Bintang Karanai 296 152 144 34 3.83 Tampoto koto Foni Bintang Karanai 133 72 61 12 3.84 Kanuma Foni Bintang Karanai 344 182 162 35 3.85 Kabokor Foni Bintang Karanai 349 172 177 40 3.86 Janack Foni Bintang Karanai 400 208 192 49 3.87 Kampant Foni Kansala 228 99 129 26 3.88 Kappa Foni Kansala 225 111 114 25 3.89 Kanfenda Foni Kansala 674 335 339 81 3.90 Burok Foni Kansala 309 168 141 34 3.91 Dumbuto Foni Kansala 184 99 85 17 3.92 Sangajor Foni Kansala 870 427 443 108 3.93 Sangajor Jiramba Foni Kansala 179 81 98 17 3.94 Nyadingding Foni Kansala 38 15 23 4 3.95 Darsilame Sheriff Kunda Foni Kansala 407 173 234 31 3.96 Arankolikunda Foni Jarrol 181 102 79 17 3.97 Kambaleba Foni Jarrol 44 24 20 4 3.98 Jorem Drammeh Kunda Foni Jarrol 72 39 33 11 3.99 Jorem Bunda Kunda Foni Jarrol 88 39 49 9 3.100 Bondali Foni Bondali 520 250 270 71 3.101 Bondali Tenda Foni Bondali 143 74 69 15 3.102 Kamwally Foni Bondali 330 174 156 29 3.103 Kanjibati Foni Bondali 74 32 42 11 3.104 Kalimu Foni Bondali 108 51 57 9 3.105 Jending Foni Bondali 31 20 11 3 3.106 Jending Ba Foni Bondali 90 50 40 6 3.107 Burambang Foni Bondali 151 76 75 11 3.108 Bulengat Foni Bondali 199 103 96 18 3.109 Kankurang Foni Bondali 443 213 230 31 3.110 Kafenkene Foni Bondali 68 29 39 6 3.111 Bambara Foni Bondali 972 502 470 116 Sub-Total 70,819 35,176 35,643 7,663

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No: Village/Community District Population # of Household Total M F s Total Population/Household 125,215 62,720 62,495 13, 939

Source: SD Focus Ltd, (2020) with data from GBOS, 2019

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Appendix 3: List of Corridors under the Brikama Substation Feeders

Brikama Feeder 1 (BF 1) Transmission Line Corridors

Corridor 1: Mandinary – Brikama - Along Road Corridor

Number of Corridors = 1

Brikama Feeder 2 (BF-2) Transmission Line Corridor

Corridor 1: Brikama – Serekundanding - Along Road Corridor Corridor 2: Mandinaba – Giboro Koto - Along Road Corridor

Number of Corridors = 2

Brikama Feeder 3 (BF-3) Transmission Line Corridor

Corridor 1: Faraba Sutu - Sohm – Omorto - Along Road Corridor Corridor 2: Buram – Bulanjor - Along Farmlands Corridor 3: Buram – Katakor - Along Farmlands Corridor 4: Besse – Berefet - Along Road Corridor Corridor 5: Somita – Batendeng Kajara - Along Road Corridor Corridor 6: Komosor – Sibanor - Along Farmlands Corridor 7: Sangajor – Mayork - Along Road Corridor Corridor 8: Sintet – Arankoli Kunda - Along Road Corridor Corridor 9: Sibanor – Bajagar – Along Road Corridor Corridor 10: Tampoto – Kanuma - Along Road Corridor Corridor 11: Kabacorr – Janak – Along Farmland Corridor 12: Kampant – Kappa - Along Road Corridor Corridor 13: Kamfenda – Kanfenda Badji Kunda – Along Farmland Corridor 14: Kanfenda – Dumbutu – Along Farmland Corridor 15: Sangajor – Dasilami - Along Road Corridor Corridor 16: Kanwally – Jending Jilahar - Along Road Corridor Corridor 17: Kanwally – Kalimu - Along Road Corridor Corridor 18: Buramba – Bambarang - Along Road Corridor Corridor 19: Jorem Drammeh Kunda – Jorem Bunda Kunda - Along Road Corridor Corridor 20: Arankoli Kunda – Kambaleba - Along Road Corridor

Number of Corridors = 20

Total Number of Corridors for Brikama Feeders = 23

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Appendix 4: Location-Specific Baseline Environmental Conditions along the Brikama Transmission Corridors

Corridor 1: Mandinary – Brikama

Distance Location Features Positio Approx Action Remarks from n of . Proposed Mandinar Feature Height/ by the y Area Project (km) (m) 0.0 Mandinary Proposed LHS 5m No action The Mandinary- Transmissio needed Brikama n Line Pole from corridor has an Pole ECOOWAS- existing line REAP 1.1 Mandinary Road LHS Run a Tee- junction to off to Kunkujang Kunkujang Jattaya Jattaya 2.9 Makumbaya Private LHS 10 Avoid Sony Enterprise property putting fenced with Pole Poles cement blocks. inside property 4.7 Makumbaya Road LHS Run a Tee- junction to off to Galoya and Galoya and Kubuneh Kubuneh 4.8 Makumbaya Road RHS Run a Tee- junction to off to Kubariko Kubariko 6.4 Bafuloto No features Both MV and LV impacted exist 9.2 Brikama Brikama Sub LHS Brikama Station Feeders originate from here 9.5 Serekundandin New LHS For health The Proposed g transmission and safety Brikama - line to be concerns Serekundandin located here transforme g Line with pole r must not terminates here mounted be with a pole - transformer accessible mounted to public transformer.

Brikama Feeder 2 (BF-2) Transmission Line Corridor

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Corridor 1: Brikama – Serekundanding

Distance Location Features Position of Approx. Action Remarks from Brikama Feature Height/Area Proposed by (km) (m) the Project 0.0 Brikama Sub Proposed LHS 5m The existing The proposed Station transmissio MV line shall Brikama – n line pole be Serekundandin reconfigured g line already and adjusted exist and runs to allow on the Right- double line hand side of the construction Brikama - for feeders 2 Serekundandin and 3. This g Road. configuration shall start from Brikama Power Plant all the way to Mandinaba where the two lines separate; feeder two branching to the right and be linked/ connected to the existing tee-off leading to the border town of Giboro

1.2 Brikama Proposed LHS 1 Line turns left to transmissio run on LHS of n line pole road 1.4 Brikama 1 Mango RHS 1 Trim and 1 orange trees 1.7 Brikama Proposed LHS 10 Line turns left transmissio and runs on LHS n line pole of Brikama – Soma highway 1.8 Brikama Carpentry/ LHS 5 Avoid putting Health and Mechanical Pole Poles safety concerns workshops above during workshops construction of poles.

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Distance Location Features Position of Approx. Action Remarks from Brikama Feature Height/Area Proposed by (km) (m) the Project 1.9 Brikama Mechanical/ LHS 6 Avoid putting Health and Tyre repair Pole Poles safety concerns workshop above during workshops construction of poles 4.5 Kembujeh No features Both MV and LV impacted Lines exist 6.3 Serekundandi Proposed LHS For health and The Proposed ng transmissio safety Brikama - n line pole concerns Serekundandin with transformer g Line transformer must not be terminates here accessible to with a pole - public mounted transformer.

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Corridor 2: Mandinaba – Giboro Koto

Distance Location Features Positio Approx Action Remarks from n of . Proposed by Mandinab Feature Height/ the Project a Area (km) (m) 0.0 Mandinab The Proposed MV LHS The existing There is a a line already exists MV line shall potential from Brikama to be RAP to Mandinaba – reconfigured address the Giboro Koto and adjusted loss of to allow earnings At the Junction of double line Mandinaba/Gibro construction , there are a few for feeders 2 structures and and 3. This businesses that configuratio will potentially be n shall start impacted during from line construction; Brikama a shop Power Plant keeper/Afra man, all the way to and a tyre repair Mandinaba man. where the two lines separate; feeder two branching to the right and be linked/ connected to the existing tee-off leading to the border town of Giboro

2.1 Tabakuta No features Both MV impacted and LV exist 4.7 Basori No features Both MV impacted and LV exist 7.9 Madina No features Both MV Talokoto impacted and LV exist 9.0 Gida No features Both MV Bajonki impacted and LV exist 10.1 Giboro No features Both MV Kuta impacted and LV exist 11.4 Giboro Proposed LHS The koto transmission Line Proposed

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Distance Location Features Positio Approx Action Remarks from n of . Proposed by Mandinab Feature Height/ the Project a Area (km) (m) pole with Mandinaba - transformer Giboro koto Line terminates here with a pole mounted transformer .

Brikama Feeder 3 (BF-3) Transmission Line Corridor

Corridor 1: Faraba Sutu - Sohm – Omorto

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Sohm Feature Area the Project (km) (m) 0.0 Faraba Proposed RHS Proposed Faraba Sutu - Sutu Transmission transmission Sohm has an Line Tee-off to line Tee-off to existing MV/LV Sohm-Omorto Sohm-Omorto lines running on the RHS of the Faraba Sutu-Sohm road corridor 0.02 Sohm Mango Tree RHS 2 Avoid 0.1 Sohm Proposed LHS 3 Line turns right Transmission and runs along Line Pole the road to Omorto 0.2 Sohm Mango Tree RHS 5 Avoid 0.2 Sohm Police Station RHS 8 Avoid putting Health and poles inside safety Police Station concerns premises during construction of poles. 0.3 Sohm Proposed LHS 5 Line crosses transmission the road and line pole runs on LHS on the opposite side, to Omorto 0.6 Sohm Mango Tree LHS 2 Avoid

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Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Sohm Feature Area the Project (km) (m) 1.3 Sohm Mahogany LHS 5 Trim 2.4 Niji Group of Mango LHS 2 Avoid Trees 2.9 Niji Cashew LHS 6 Trim cashews Potential RAP Plantation along the frontage 3.7 Omorto Group of 6 LHS 3 Avoid Mango Trees 4.0 Omorto Mango Tree LHS 5 Avoid 4.2 Omorto New RHS For health and The Proposed transmission safety Sohm - Omorto line to be concerns Line terminates located here transformer here with a with pole must not be pole -mounted mounted accessible to transformer. transformer public

Corridor 2: Buram – Bulanjor

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Buram Feature Area the Project (km) (m) 0.0 Buram Proposed RHS Construct transmission proposed line pole Buram – Bulanjor line on the RHS of the Buram - Bulanjor Road 2.7 Bulanjor Tributary Across the road Avoid putting Low lying pole s close to waterway the tributary liable to flooding 3.1 Bulanjor New LHS For health and The Proposed transmission safety Buram - line to be concerns Bulanjor Line located here transformer terminates with pole must not be here with a mounted accessible to pole -mounted transformer public transformer.

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Corridor 3: Buram – Katakor

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Buram Feature Area the Project (km) (m) 0.0 Buram Proposed RHS Construct the transmission proposed line pole Buram – Katakor line on the RHS of the Buram - Katakor Road. 0.3 Buram Football field; RHS 8 Avoid putting Stringing should Unfenced. poles on be done when football field match is not in progress 1.4 Buram Cashew tree RHS 3 Avoid 1.9 Katakor Football field; RHS 10 Avoid putting Stringing should Unfenced. poles on be done when football field play is not in progress 2.1 Katakor Proposed LHS For health and The Proposed transmission safety Buram - Katakor line pole with concerns line terminates transformer transformer here with a pole must not be -mounted accessible to transformer. public

Corridor 4: Besse – Berefet

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Besse Feature Area the Project (km) (m) 0.0 Besse Proposed LHS The transmission line pole Proposed Besse – Berefet Line runs on LHS of the Besse - Berefet Road. 0.2 Besse St. Andrews Nursery LHS 2 Health and School; partly fenced safety with cement blocks concerns during construction of poles

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Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Besse Feature Area the Project (km) (m) 0.2 Besse Besse Community LHS 3 Fenced with Association cement blocks. Health and safety concerns during construction of poles 2.4 Besse Kassila Community Both sides of road Avoid Forest (CF) erecting poles inside CF 5.1 Berefet Proposed LHS Line turns transmission line pole right and runs on RHS 5.5 Berefet Proposed LHS For health The Proposed transmission line pole and safety Besse - with transformer concerns Berefet Line transformer terminates must not be here with a accessible to pole - public mounted transformer.

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Corridor 5: Somita – Batendeng Kajara

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Basse Feature Area by the (km) (m) Project 0.0 Somita Proposed RHS The transmission line pole Proposed Somita – Batendeng Kajara Line runs on RHS Somita – Batendeng Kajara Road. 3.4 Kandunku Cashew Plantation RHS 5 Avoid 4.0 Kandunku Women’s Vegetable RHS 7 Avoid Health and Garden putting safety poles inside concerns the Garden during construction of poles 4.3 Kandunku Mosque RHS 5 Avoid Health and running the safety line above concerns the Mosque during construction of poles 5.6 Batendeng Proposed RHS For health The Kajara transmission line pole and safety Proposed with transformer concerns Somita – transformer Batendeng must not be Kajarabu Line accessible terminates to public here with a pole - mounted transformer.

Corridor 6: Komosor – Sibanor

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Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Komosor Feature (m) by the (km) Project 0.0 Sibanor Proposed RHS The Proposed transmission Komosor – line pole Sibanor runs on RHS Komosor - Sibanor Road. 3.3 Batendeng No features Usual impacted Bush/farmland 5.1 Komosor Proposed LHS For health The Proposed transmission and safety Komosor - line pole with concerns Sibanor Line transformer transformer terminates must not be here with a accessible pole -mounted to public transformer.

Corridor 7: Sangajor – Mayork

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Sangajor Feature Area by the (km) (m) Project 0.0 Sangajor Proposed LHS 5m Construct transmission line poles to run pole on RHS of the Sangajor - Mayork road corridor 0.3 Sangajor Gully RHS 2 Avoid putting poles close to gully 3.7 Jomo Group of Mangoes RHS 3 Avoid Kunda 3.9 Jomo Silk cotton Tree RHS 6 Avoid Kunda 6.4 Jomo Jomo Kunda/Jonyerr RHS 7 Avoid Kunda Community Forest putting poles inside forest 6.7 Jomo Mango Tree RHS 4 Trim Kunda 8.5 Jonyerr Mango Tree RHS 5 Trim

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Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Sangajor Feature Area by the (km) (m) Project 8.7 Jonyerr Mosque RHS 6 Avoid Health and running the safety line over concerns the mosque during construction of poles 8.8 Jonyerr Mango Tree RHS 8 Avoid 10.0 Bajiran No features Usual impacted Bush/farmland 10.1 Bantajang No features Usual impacted Bush/farmland 11.9 Bantajang Mango Tree RHS 5 Trim 15.0 Kallang Group of 2 Mangoes RHS 3 Avoid 17.7 Mayork Proposed RHS For health The Proposed transmission line and safety Sangajor - pole with concerns Mayork Line transformer transformer terminates must not be here with a accessible pole -mounted to public transformer.

Corridor 8: Sintet – Arankoli Kunda

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Sintet Feature Area by the (km) (m) Project 0.0 Sintet No features Usual impacted Bush/farmland 6.8 Kanmamudu No features Usual impacted Bush/farmland 7.8 Kampassa No features Usual impacted Bush/farmland 9.7 Jonkel No features Usual impacted Bush/farmland 14.0 Chabai No features Usual impacted Bush/farmland 16.1 Wassadu Quranic School of RHS 8 Health and cement block safety structure concerns during construction of poles 18.0 Arankoli Proposed RHS For health The Proposed Kunda transmission line and safety Sintet - pole with concerns Arankoli Kunda transformer transformer Line

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Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Sintet Feature Area by the (km) (m) Project must not be terminates accessible here with a to public pole -mounted transformer.

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Appendix 5: Chance Find Procedures

This Chance Find Procedure shall be applied in case previously unknown culturally valuable materials are unexpectedly discovered during the implementation of the Project: • In the case of chance find of any material with possible archaeological, historical, paleontological, religious, or other cultural value, all work at and around the find, feature or site must immediately stop.

• The discovery will be clearly demarcated and secured from unauthorized access, and all found remains will be left where they were found. If necessary, artefacts will be protected and measures to stabilize the area will be implemented.

• Notify the Project Manager/PCU of the findings who in turn will immediately notify the National Council for Arts and Culture for the necessary, assessment, recording and determination of the the next course of action.

• Restart construction and public works only upon authorization of the relevant authorities (the National Council for Arts and Culture under the Ministry of Tourism and Culture).

• Relevant findings will be recorded in the Banks’ supervision reports.

• These procedures must be referred to as standard provisions in construction contracts.

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Appendix 6: Summary of Comments and Views expressed at the Consultations

Communities/Venues Dates Introduction and objectives of ECOWAS-REAP Buram - WCR 15/02/20 The lead Consultant introduced the team, including Komossor - WCR 15/02/20 the NAWEC team of experts who were also part of National Regulatory Institutions the field exercises. National Water and Electricity ??? Company The Consultant took time to share valuation Department of Parks and 10/03/20 information on matters surrounding the field trips, Wildlife Management consultations with the communities, project National Roads Authority 10/03/20 background, processes, and procedures as well as the Department of Forestry 11/03/20 role of the communities and institutions during the National Environment Agency 11/03/20 implementation of the Project. National Council for Arts and 11/03/20 Culture He gave a brief background of the ECOWAS-REAP; that it is an IDA/World Bank funded regional project Consultant’s Opening Remarks meant to enhance electricity access to ECOWAS member countries. He informed the meetings that the OMVG Energy Project is currently building an electricity substation in Brikama; that ECOWAS-REAP will connect from the substation to provide electricity to rural and peri-urban communities 100km radius of

the substation via MV (30kV) and LV (400V)

infrastructure.

This means therefore, that the lines will pass through communities, feeder roads, farmlands, bushes/shrubs, protected areas such as forests, parks and cultural heritage sites. He informed the gathering that as part of the assessment, the routing of the lines is being done collectively with the NAWEC team, and the objective is to avoid or minimize environmental and social impacts. Where impacts are inevitable, the assessment shall be carried out to ensure that the appropriate mitigation measures are recommended and implemented. If compensation is required, the affected families shall be consulted adequately before the compensation is done.

He concluded by saying that once implemented, the Project will contribute to improving the livelihoods of the people in many ways.

Rationale of the Public Consultations

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The Consultant informed the meetings that the rationale for the public consultations is for information sharing with Project beneficiaries; to seek their opinion, learn from their experiences of past projects, hear their concerns and fears to help in better planning of the ECOWAS-REAP activities.

From the consultations an ESIA report will be developed with an ESMP to address the potential negative environmental and social impacts that may be caused by the Project. Remarks, Comments by Project beneficiaries Location Comments/Views Mandinaba The Project is highly welcomed, but the villagers decried: • Lack of confidence as several neighboring villages were promised electricity which is still not forthcoming • Women are particularly disadvantaged as they spend a lot of time and resources on ice cubes for their businesses • Electricity will greatly help in preserving foodstuff at the household level as well as make the youth stay at home Buram • This Project has more positive impacts than negative ones. In addition, it will make the neighborhood a lot brighter and therefore increase security in the village Komosor • Making electricity accessible is very good and welcomed but how much will it cost the poor farmers in the village?

• With electricity we can engage in businesses that are dependent on electricity and enhance our livelihood even further Government Institutions Department of Parks and Wildlife • Coated wires should be used, to reduce Management risks of animals being electrocuted

• Anything inside any National Park, including forest trees belong to DPWM but any tree felled and needs to be taken out of the Park, approval of DOF must be sought

• Any destruction must be repaired

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National Roads Authority • Poles should not be erected within road corridors which are less than 15m from the center of roads

• In the case of expansion of roads, relocation of poles can be costly; thus, erect poles as far away from roads as possible

• The possibility of running lines behind communities should be considered to avoid busy roads within communities Department of Forestry • As far as this Project is concerned, DOF’s interests relates to impacts on flora whilst DPWM is concerned with fauna

• However, there is always a positive consultation between the two Departments especially as it relates to consultations in respect of forest products

• In case of any impacts on National Parks resulting in a RAP, DOF can always support DPWM with seedlings production in case of reforestation National Environment Agency • Challenges are foreseen in some National Parks including issues pertaining to RAP and water facility

• Possibility of underground cable to avoid impacts on habitat, flora and fauna etc. should be explored

• The need to build capacity especially at the regional level will help in the monitoring of Project works

• Monitoring from HQ is not going to be effective, so there is need to utilize the TACs; TACs at regional level must always be engaged and their capacities should be built too NCAC • The Project will be very close to the stone circles in Kerr Batch, which is protected in the country

• Funds have been secured to refurbish the Kerr Batch site and presence of electricity in the future will make the place more

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attractive and viable for tourism and its related benefits for the community

• Due to its cultural heritage, the Kerr Batch Stone Circles has immense significance and needs to be preserved; lines should be designed not to pass close to the site.

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Appendix 7: List of Persons Met

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Appendix 8: Codes of Conduct and Action Plan For Implementing ESHS and OHS Standards, and Preventing Gender Based Violence and Violence Against Children

Background

The purpose of these Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV) and Violence Against Children (VAC) is to introduce a set of key definitions, core Codes of Conduct, and guidelines that:

i. clearly define obligations on all project staff (including sub-contractors and day workers) with regard to implementing the project’s environmental, social, health and safety (ESHS) and occupational health and safety (OHS) requirements, and;

ii. help prevent, report and address GBV and VAC within the work site and in its immediate surrounding communities.

The application of these Codes of Conduct will help ensure the project meets its ESHS and OHS objectives, as well as preventing and/or mitigating the risks of GBV and VAC on the project and in the local communities.

These Codes of Conduct are to be adopted by those working on the project and are meant to:

i. create awareness of the ESHS and OHS expectations on the project;

ii. create common awareness about GBV and VAC and: (a) ensure a shared understanding that they have no place in the project; and, (b) create a clear system for identifying, responding to, and sanctioning GBV and VAC incidents.

Ensuring that all project staff understand the values of the project, understand expectations for all employees, and acknowledge the consequences for violations of these values, will help to create smoother, more respectful and productive project implementation thereby helping ensure that the project’s objectives will be achieved.

Definitions

The following definitions apply:

Environmental, Social, Health and Safety (ESHS): an umbrella term covering issues related to the impact of the project on the environment, communities, and workers.

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Occupational Health and Safety (OHS): Occupational health and safety is concerned with protecting the safety, health and welfare of people engaged in work or employment. The enjoyment of these standards at the highest levels is a basic human right that should be accessible by each worker.

Gender-Based Violence (GBV): is an umbrella term for any harmful act that is perpetrated against a person’s will and that is based on socially ascribed (i.e. gender) differences between males and females. It includes acts that inflict physical, sexual, or mental harm or suffering, threats of such acts, coercion, and other deprivations of liberty. These acts can occur in public or in private. The term GBV is used to underscore systemic inequality between males and females (which exists in every society in the world) and acts as a unifying and foundational characteristic of most forms of violence perpetrated against women and girls. The 1993 United Nations Declaration on the Elimination of Violence against Women defines violence against women as “any act of gender-based violence that results in, or is likely to result in, physical, sexual or psychological harm or suffering to women.”9 The six core types of GBV are: • Rape: non-consensual penetration (however slight) of the vagina, anus or mouth with a penis, other body part, or an object. • Sexual Assault: any form of non-consensual sexual contact that does not result in or include penetration. Examples include: attempted rape, as well as unwanted kissing, fondling, or touching of genitalia and buttocks.

o Sexual Harassment: is unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature. Sexual harassment is not always explicit or obvious, it can include implicit and subtle acts but always invoLVes a power and gender dynamic in which a person in power uses their position to harass another based on their gender. Sexual conduct is unwelcome whenever the person subjected to it considers it unwelcome (e.g. looking somebody up and down; kissing, howling or smacking sounds; hanging around somebody; whistling and catcalls; in some instances, giving personal gifts). o Sexual Favors: is a form of sexual harassment and includes making promises of favorable treatment (e.g. promotion) or threats of unfavorable treatment (e.g. loss of job) dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior.

• Physical Assault: an act of physical violence that is not sexual in nature. Examples include: hitting, slapping, choking, cutting, shoving, burning, shooting or use of any weapons, acid attacks or any other act that results in pain, discomfort or injury.

• Forced Marriage: the marriage of an individual against her or his will.

• Denial of Resources, Opportunities or Services: denial of rightful access to economic resources/assets or livelihood opportunities, education, health or other social services (e.g. a

9 It is important to note that women and girls disproportionately experience violence; overall 35 percent of women worldwide have faced physical or sexual violence (WHO, Global and regional estimates of violence against women: prevalence and health effects of intimate partner violence and non-partner sexual violence, 2013). Some men and boys also face violence based on their gender and unequal power relationships.

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widow prevented from receiving an inheritance, earnings forcibly taken by an intimate partner or family member, a woman prevented from using contraceptives, a girl prevented from attending school, etc.).

• Psychological / Emotional Abuse: infliction of mental or emotional pain or injury. Examples include: threats of physical or sexual violence, intimidation, humiliation, forced isolation, stalking, harassment, unwanted attention, remarks, gestures or written words of a sexual and/or menacing nature, destruction of cherished things, etc.

Violence Against Children (VAC): is defined as physical, sexual, emotional and/or psychological harm, neglect or negligent treatment of minor children (i.e. under the age of 18), including exposure to such harm,10 that results in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power. This includes using children for profit, labor11, sexual gratification, or some other personal or financial advantage. This also includes other activities such as using computers, mobile phones, video, and digital cameras or any other medium to exploit or harass children or to access child pornography.

Grooming: are behaviors that make it easier for a perpetrator to procure a child for sexual activity. For example, an offender might build a relationship of trust with the child, and then seek to sexualize that relationship (for example by encouraging romantic feelings or exposing the child to sexual concepts through pornography).

Online Grooming: is the act of sending an electronic message with indecent content to a recipient who the sender believes to be a minor, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender.12

Accountability Measures: are the measures put in place to ensure the confidentiality of survivors and to hold contractors, consultants, and the client responsible for instituting a fair system of addressing cases of GBV and VAC.

Contractors Environmental and Social Management Plan (CESMP): the plan prepared by the contractor outlining how they will implement the works activities in accordance with the project’s environmental and social management plan (ESMP).

Child: is used interchangeably with the term ‘minor’ and refers to a person under the age of 18. This is in accordance with Article 1 of the United Nations Convention on the Rights of the Child.

Child Protection (CP): is an activity or initiative designed to protect children from any form of harm, particularly arising from VAC.

Consent: is the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is

10 Exposure to GBV is also considered VAC. 11 The employment of children must comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. They must also be able to meet the project’s Occupational Health and Safety competency standards. 12 For example, the Vanuatu Criminal Code Act 1995, Division 474 (telecommunications offences, subdivision C).

180 obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if national legislation of the country into which the Code of Conduct is introduced has a lower age.13 Mistaken belief regarding the age of the child and consent from the child is not a defense.

Consultant: is as any firm, company, organization or other institution that has been awarded a contract to provide consulting services to the project, and has hired managers and/or employees to conduct this work.

Contractor: is any firm, company, organization, or other institution that has been awarded a contract to conduct infrastructure development works for the project and has hired managers and/or employees to conduct this work. This also includes sub-contractors hired to undertake activities on behalf of the contractor.

Employee: is any individual offering labor to the contractor or consultant within country on or off the work site, under a formal or informal employment contract or arrangement, typically, but not necessarily (e.g. including unpaid interns and volunteers), in exchange for a salary, with no responsibility to manage or supervise other employees.

GBV and VAC Allegation Procedure: is the prescribed procedure to be followed when reporting incidents of GBV or VAC.

GBV and VAC Codes of Conduct: The Codes of Conduct adopted for the project covering the commitment of the company, and the responsibilities of managers and individuals with regards to GBV and VAC.

GBV and VAC Compliance Team (GCCT): a team established by the project to address GBV and VAC issues.

Grievance Redress Mechanism (GRM): is the process established by a project to receive and address complaints.

Manager: is any individual offering labor to the contractor or consultant, on or off the work site, under a formal or informal employment contract and in exchange for a salary, with responsibility to control or direct the activities of a contractor’s or consultant’s team, unit, division or similar, and to supervise and manage a pre-defined number of employees.

Perpetrator: the person(s) who commit(s) or threaten(s) to commit an act or acts of GBV or VAC.

Response Protocol: is the mechanisms set in place to respond to cases of GBV and VAC (see Section 4.7 Response Protocol).

13 For example, under Article 97 Criminal consolidation act for age of legal consent in Vanuatu, sexual activity with any child under the age of 15 years for heterosexual conduct and 18 years for same sex conduct is prohibited (http://tinyurl.com/vu-consent). However, the World Bank follows the United Nations for the age of consent (18 years) so this applies on World Bank financed projects.

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Survivor/Survivors: the person(s) adversely affected by GBV or VAC. Women, men and children can be survivors of GBV; children can be survivors of VAC.

Work Site: is the area in which infrastructure development works are being conducted, as part of the project. Consulting assignments are considered to have the areas in which they are active as their work sites.

Work Site Surroundings: is the ‘Project Area of Influence’ which are any area, urban or rural, directly affected by the project, including all human settlements found on it.

Codes of Conduct

This chapter presents three Codes of Conduct for use: i. Company Code of Conduct: Commits the company to addressing GBV and VAC issues; ii. Manager’s Code of Conduct: Commits managers to implementing the Company Code of Conduct, as well as those signed by individuals; and, iii. Individual Code of Conduct: Code of Conduct for everyone working on the project, including managers.

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Company Code of Conduct

Implementing ESHS and OHS Standards

Preventing Gender Based Violence and Violence Against Children

The company is committed to ensuring that the project is implemented in such a way which minimizes any negative impacts on the local environment, communities, and its workers. This will be done by respecting the environmental, social, health and safety (ESHS) standards, and ensuring appropriate occupational health and safety (OHS) standards are met. The company is also committed to creating and maintaining an environment in which gender based violence (GBV) and violence against children (VAC) have no place, and where they will not be tolerated by any employee, sub-contractors, supplier, associate, or representative of the company.

Therefore, to ensure that all those engaged in the project are aware of this commitment, the company commits to the following core principles and minimum standards of behavior that will apply to all company employees, associates, and representatives, including sub-contractors and suppliers, without exception:

General

1. The company—and therefore all employees, associates, representatives, sub-contractors and suppliers—commits to complying with all relevant national laws, rules and regulations. 2. The company commits to full implementing its ‘Contractors Environmental and Social Management Plan’ (CESMP). 3. The company commits to treating women, children (persons under the age of 18), and men with respect regardless of race, color, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status. Acts of GBV and VAC are in violation of this commitment. 4. The company shall ensure that interactions with local community members are done with respect and non-discrimination. 5. Demeaning, threatening, harassing, abusive, culturally inappropriate, or sexually provocative language and behavior are prohibited among all company employees, associates, and its representatives, including sub-contractors and suppliers. 6. The company will follow all reasonable work instructions (including regarding environmental and social norms). 7. The company will protect and ensure proper use of property (for example, to prohibit theft, carelessness, or waste).

Health and Safety

8. The company will ensure that the project’s occupational health and safety (OHS) Management Plan is effectively implemented by company staff, as well as sub-contractors and suppliers. 9. The company will ensure that all persons on-site wear prescribed and appropriate personal protective equipment, preventing avoidable accidents and reporting conditions or practices that pose a safety hazard or threaten the environment.

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10. The company will: i. prohibit the use of alcohol during work activities. ii. prohibit the use of narcotics or other substances which can always impair faculties.

11. The company will ensure that adequate sanitation facilities are available on site and at any worker accommodations provided to those working on the project.

Gender Based Violence and Violence Against Children

12. Acts of GBV or VAC constitute gross misconduct and are therefore grounds for sanctions, which may include penalties and/or termination of employment, and if appropriate referral to the Police for further action. 13. All forms of GBV and VAC, including grooming are unacceptable, regardless of whether they take place on the work site, the work site surroundings, at worker’s camps or within the local community. i. Sexual Harassment—for instance, making unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct, of a sexual nature, including subtle acts of such behavior, is prohibited. ii. Sexual favors —for instance, making promises or favorable treatment dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior are prohibited. 14. Sexual contact or activity with children under 18—including through digital media—is 7prohibited. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse. 15. Unless there is full consent14 by all parties invoLVed in the sexual act, sexual interactions between the company’s employees (at any level) and members of the communities surrounding the work lace are prohibited. This includes relationships invoLVing the withholding/promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex— such sexual activity is considered “non-consensual” within the scope of this Code. 16. In addition to company sanctions, legal prosecution of those who commit acts of GBV or VAC will be pursued if appropriate. 17. All employees, including volunteers and sub-contractors are highly encouraged to report suspected or actual acts of GBV and/or VAC by a fellow worker, whether in the same company or not. Reports must be made in accordance with project’s GBV and VAC Allegation Procedures. 18. Managers are required to report and act to address suspected or actual acts of GBV and/or VAC as they have a responsibility to uphold company commitments and hold their direct reports responsible.

14 Consent is defined as the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if national legislation of the country into which the Code of Conduct is introduced has a lower age. Mistaken belief regarding the age of the child and consent from the child is not a defense.

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Implementation

To ensure that the above principles are implemented effectively the company commits to ensuring that:

19. All managers sign the project’s ‘Manager’s Code of Conduct’ detailing their responsibilities for implementing the company’s commitments and enforcing the responsibilities in the ‘Individual Code of Conduct’. 20. All employees sign the project’s ‘Individual Code of Conduct’ confirming their agreement to comply with ESHS and OHS standards, and not to engage in activities resulting in GBV or VAC. 21. Displaying the Company and Individual Codes of Conduct prominently and in clear view at workers’ camps, offices, and in in public areas of the workspace. Examples of areas include waiting, rest and lobby areas of sites, canteen areas and health clinics. 22. Ensure that posted and distributed copies of the Company and Individual Codes of Conduct are translated into the appropriate language of use in the work site areas as well as for any international staff in their native language. 23. An appropriate person is nominated as the company’s ‘Focal Point’ for addressing GBV and VAC issues, including representing the company on the GBV and VAC Compliance Team (GCCT) which is comprised of representatives from the client, contractor(s), the supervision consultant, and local service provider(s). 24. Ensuring that an effective GBV and VAC Action Plan is developed in consultation with the GCCT which includes as a minimum:

i. GBV and VAC Allegation Procedure to report GBV and VAC issues through the project Grievance Redress Mechanism (Section 4.3 Action Plan); ii. Accountability Measures to protect confidentiality of all invoLVed (Section 4.4 Action Plan); and, iii. Response Protocol applicable to GBV and VAC survivors and perpetrators (Section 4.7 Action Plan).

25. That the company effectively implements the agreed final GBV and VAC Action Plan, providing feedback to the GCCT for improvements and updates as appropriate. 26. All employees attend an induction training course prior to commencing work on site to ensure they are familiar with the company’s commitments to ESHS and OHS standards, and the project’s GBV and VAC Codes of Conduct. 27. All employees attend a mandatory training course once a month for the duration of the contract starting from the first induction training prior to commencement of work to reinforce the understanding of the project’s ESHS and OHS standards and the GBV and VAC Code of Conduct.

I do hereby acknowledge that I have read the foregoing Company Code of Conduct, and on behalf of the company agree to comply with the standards contained therein. I understand my role and responsibilities to support the project’s OHS and ESHS standards, and to prevent and respond to GBV and VAC. I understand that any action inconsistent with this Company Code of Conduct or failure to act mandated by this Company Code of Conduct may result in disciplinary action.

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Company name: ______

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Manager’s Code of Conduct

Implementing ESHS and OHS Standards

Preventing Gender Based Violence and Violence Against Children

Managers at all levels have a responsibility to uphold the company’s commitment to implementing the ESHS and OHS standards, and preventing and addressing GBV and VAC. This means that managers have an acute responsibility to create and maintain an environment that respects these standards and prevents GBV and VAC. Managers need to support and promote the implementation of the Company Code of Conduct. To that end, managers must adhere to this Manager’s Code of Conduct and sign the Individual Code of Conduct. This commits them to supporting the implementation of the CESMP and the OHS Management Plan and developing systems that facilitate the implementation of the GBV and VAC Action Plan. They need to maintain a safe workplace, as well as a GBV-free and VAC-free environment at the workplace and in the local community. These responsibilities include but are not limited to:

Implementation

1. To ensure maximum effectiveness of the Company and Individual Codes of Conduct: i. Prominently displaying the Company and Individual Codes of Conduct in clear view at workers’ camps, offices, and in public areas of the workspace. Examples of areas include waiting, rest and lobby areas of sites, canteen areas and health clinics. ii. Ensuring all posted and distributed copies of the Company and Individual Codes of Conduct are translated into the appropriate language of use in the work site areas as well as for any international staff in their native language. 2. Verbally and in writing explain the Company and Individual Codes of Conduct to all staff. 3. Ensure that: i. All direct reports sign the ‘Individual Code of Conduct’, including acknowledgment that they have read and agree with the Code of Conduct. ii. Staff lists and signed copies of the Individual Code of Conduct are provided to the OHS Manager, the GCCT, and the client. iii. Participate in training and ensure that staff also participate as outlined below. iv. Put in place a mechanism for staff to: (a) report concerns on ESHS or OHS compliance; and, (b) confidentially report GBV or VAC incidents through the Grievance Redress Mechanism (GRM) v. Staff are encouraged to report suspected or actual ESHS, OHS, GBV or VAC issues, emphasizing the staff’s responsibility to the Company and the country hosting their employment, and emphasizing the respect for confidentiality. 4. In compliance with applicable laws and to the best of your abilities, prevent perpetrators of sexual exploitation and abuse from being hired, re-hired, or deployed. Use background and criminal reference checks for all employees. 5. Ensure that when engaging in partnership, sub-contractor, supplier or similar agreements, these agreements: i. Incorporate the ESHS, OHS, GBV and VAC Codes of Conduct as an attachment.

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ii. Include the appropriate language requiring such contracting entities and individuals, and their employees and volunteers, to comply with the Individual Codes of Conduct. iii. Expressly state that the failure of those entities or individuals, as appropriate, to ensure compliance with the ESHS and OHS standards, take preventive measures against GBV and VAC, to investigate allegations thereof, or to take corrective actions when GBV or VAC has occurred, shall not only constitute grounds for sanctions and penalties in accordance with the Individual Codes of Conduct but also termination of agreements to work on or supply the project. 6. Provide support and resources to the GCCT to create and disseminate internal sensitization initiatives through the awareness-raising strategy under the GBV and VAC Action Plan. 7. Ensure that any GBV or VAC issue warranting Police action is reported to the Police, the client and the World Bank immediately. 8. Report and act according to the response protocol (Section 4.7 Response Protocol) any suspected or actual acts of GBV and/or VAC as managers have a responsibility to uphold company commitments and hold their direct reports responsible. 9. Ensure that any major ESHS or OHS incidents are reported to the client and the supervision engineer immediately.

Training

10. The managers are responsible to: i. Ensure that the OHS Management Plan is implemented, with suitable training required for all staff, including sub-contractors and suppliers; and, ii. Ensure that staff have a suitable understanding of the CESMP and are trained as appropriate to implement the CESMP requirements. 11. All managers are required to attend an induction manager training course prior to commencing work on site to ensure that they are familiar with their roles and responsibilities in upholding the GBV and VAC elements of these Codes of Conduct. This training will be separate from the induction training course required of all employees and will provide managers with the necessary understanding and technical support needed to begin to develop the GBV and VAC Action Plan for addressing GBV and VAC issues. 12. Managers are required to attend and assist with the project facilitated monthly training courses for all employees. Managers will be required to introduce the trainings and announce the self- evaluations, including collecting satisfaction surveys to evaluate training experiences and provide advice on improving the effectiveness of training. 13. Ensure that time is provided during work hours and that staff prior to commencing work on site attend the mandatory project facilitated induction training on: i. OHS and ESHS; and, ii. GBV and VAC required of all employees. 14. During civil works, ensure that staff attend ongoing OHS and ESHS training, as well as the monthly mandatory refresher training course required of all employees to combat increased risk of GBV and VAC.

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Response

15. Managers will be required to take appropriate actions to address any ESHS or OHS incidents. 16. With regard to GBV and VAC: i. Provide input to the GBV and VAC Allegation Procedures (Section 4.2 Action Plan) and Response Protocol (Section 4.7 Action Plan) developed by the GCCT as part of the final cleared GBV and VAC Action Plan. ii. Once adopted by the Company, managers will uphold the Accountability Measures (Section 4.4 Action Plan) set forth in the GBV and VAC Action Plan to maintain the confidentiality of all employees who report or (allegedly) perpetrate incidences of GBV and VAC (unless a breach of confidentiality is required to protect persons or property from serious harm or where required by law). iii. If a manager develops concerns or suspicions regarding any form of GBV or VAC by one of his/her direct reports, or by an employee working for another contractor on the same work site, s/he is required to report the case using the GRM. iv. Once a sanction has been determined, the relevant manager(s) is/are expected to be personally responsible for ensuring that the measure is effectively enforced, within a maximum timeframe of 14 days from the date on which the decision to sanction was made v. If a Manager has a conflict of interest due to personal or familial relationships with the survivor and/or perpetrator, he/she must notify the respective company and the GCCT. The Company will be required to appoint another manager without a conflict of interest to respond to complaints. vi. Ensure that any GBV or VAC issue warranting Police action is reported to the Police, the client and the World Bank immediately

17. Managers failing to address ESHS or OHS incidents or failing to report or comply with the GBV and VAC provisions may be subject to disciplinary measures, to be determined and enacted by the company’s CEO, Managing Director, or equivalent highest-ranking manager. Those measures may include: i. Informal warning. ii. Formal warning. iii. Additional Training. iv. Loss of up to one week's salary. v. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. vi. Termination of employment.

18. Ultimately, failure to effectively respond to ESHS, OHS, GBV and VAC cases on the work site by the company’s managers or CEO may provide grounds for legal actions by authorities.

I do hereby acknowledge that I have read the foregoing Manager’s Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, GBV and VAC requirements. I understand that any action inconsistent with

189 this Manager’s Code of Conduct or failure to act mandated by this Manager’s Code of Conduct may result in disciplinary action.

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Individual Code of Conduct

Implementing ESHS and OHS Standards

Preventing Gender Based Violence and Violence Against Children

I, ______, acknowledge that adhering to environmental, social health and safety (ESHS) standards, following the project’s occupational health and safety (OHS) requirements, and preventing gender based violence (GBV) and violence against children (VAC) is important.

The company considers that failure to follow ESHS and OHS standards, or to partake in GBV or VAC activities—be it on the work site, the work site surroundings, at workers’ camps, or the surrounding communities—constitute acts of gross misconduct and are therefore grounds for sanctions, penalties or potential termination of employment. Prosecution by the Police of those who commit GBV or VAC may be pursued if appropriate.

I agree that while working on the project I will:

1. Attend and actively partake in training courses related to ESHS, OHS, HIV/AIDS, GBV and VAC as requested by my employer. 2. Will wear my personal protective equipment (PPE) at all times when at the work site or engaged in project related activities. 3. Take all practical steps to implement the contractor’s environmental and social management plan (CESMP). 4. Implement the OHS Management Plan. 5. Adhere to a zero-alcohol policy during work activities, and refrain from the use of narcotics or other substances which can impair faculties at all times. 6. Consent to Police background check. 7. Treat women, children (persons under the age of 18), and men with respect regardless of race, color, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status. 8. Not use language or behavior towards women, children or men that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate. 9. Not engage in sexual harassment—for instance, making unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct, of a sexual nature, including subtle acts of such behavior (e.g. looking somebody up and down; kissing, howling or smacking sounds; hanging around somebody; whistling and catcalls; giving personal gifts; making comments about somebody’s sex life; etc.). 10. Not engage in sexual favors—for instance, making promises or favorable treatment dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior. 11. Not participate in sexual contact or activity with children—including grooming, or contact through digital media. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse.

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12. Unless there is the full consent15 by all parties involved, I will not have sexual interactions with members of the surrounding communities. This includes relationships involving the withholding or promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex—such sexual activity is considered “non-consensual” within the scope of this Code. 13. Consider reporting through the GRM or to my manager any suspected or actual GBV or VAC by a fellow worker, whether employed by my company or not, or any breaches of this Code of Conduct.

Regarding children under the age of 18:

14. Wherever possible, ensure that another adult is present when working in the proximity of children. 15. Not invite unaccompanied children unrelated to my family into my home unless they are at immediate risk of injury or in physical danger. 16. Not use any computers, mobile phones, video, and digital cameras or any other medium to exploit or harass children or to access child pornography (see also “Use of children's images for work related purposes” below). 17. Refrain from physical punishment or discipline of children. 18. Refrain from hiring children for domestic or other labor below the minimum age of 14 unless national law specifies a higher age, or which places them at significant risk of injury. 19. Comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. 20. Take appropriate caution when photographing or filming children (See Annex 2 for details).

Use of children's images for work related purposes

When photographing or filming a child for work related purposes, I must:

21. Before photographing or filming a child, assess and endeavor to comply with local traditions or restrictions for reproducing personal images. 22. Before photographing or filming a child, obtain informed consent from the child and a parent or guardian of the child. As part of this I must explain how the photograph or film will be used. 23. Ensure photographs, films, videos, and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive. 24. Ensure images are honest representations of the context and the facts. 25. Ensure file labels do not reveal identifying information about a child when sending images electronically.

Sanctions

15 Consent is defined as the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if national legislation of the country into which the Code of Conduct is introduced has a lower age. Mistaken belief regarding the age of the child and consent from the child is not a defense.

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I understand that if I breach this Individual Code of Conduct, my employer will take disciplinary action which could include:

1. Informal warning. 2. Formal warning. 3. Additional Training. 4. Loss of up to one week’s salary. 5. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. 6. Termination of employment. 7. Report to the Police if warranted.

I understand that it is my responsibility to ensure that the environmental, social, health and safety standards are met. That I will adhere to the occupational health and safety management plan. That I will avoid actions or behaviors that could be construed as GBV or VAC. Any such actions will be a breach this Individual Code of Conduct. I do hereby acknowledge that I have read the foregoing Individual Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, GBV and VAC issues. I understand that any action inconsistent with this Individual Code of Conduct or failure to act mandated by this Individual Code of Conduct may result in disciplinary action and may affect my ongoing employment.

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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GBV and VAC Action Plan

4.1 The GBV and VAC Compliance Team

The project shall establish a ‘GBV and VAC Compliance Team’ (GCCT). The GCCT will include, as appropriate to the project, at least four representatives (‘Focal Points’) as follows:

i. A safeguards specialist from the client; ii. The occupational health and safety manager from the contractor16, or someone else tasked with the responsibility for addressing GBV and VAC with the time and seniority to devote to the position; iii. The supervision consultant; and, iv. A representative from a local service provider with experience in GBV and VAC (the ‘Service Provider’).

It will be the duty of the GCCT with support from the management of the contractor to inform workers about the activities and responsibilities of the GCCT. To effectively serve on the GCCT, members must undergo training by the local service provider prior to the commencement of their assignment to ensure that they are sensitized on GBV and Child Protection.

The GCCT will be required to:

i. Approve any changes to the GBV and VAC Codes of Conduct contained in this document, with clearances from the World Bank for any such changes. ii. Prepare the GBV and VAC Action Plan reflecting the Codes of Conduct which includes: (a) GBV and VAC Allegation Procedures (See 4.2) (b) Accountability Measures (See 4.4) (c) An Awareness raising Strategy (See 4.6) (d) A Response Protocol (See 4.7) iii. Obtain approval of the GBV and VAC Action Plan by the contractor’s management; iv. Obtain client and World Bank clearances for the GBV and VAC Action Plan prior to full mobilization; v. Receive and monitor resolutions and sanctions regarding complaints received related to GBV and VAC associated with the project; and, vi. Ensure that GBV and VAC statistics in the GRM are up to date and included in the regular project reports.

The GCCT shall hold quarterly update meetings to discuss ways to strengthen resources and GBV and VAC support for employees and community members.

4.2 Making Complaints: GBV and VAC Allegation Procedures

All staff, volunteers, consultants and sub-contractors are encouraged to report suspected or actual GBV or VAC cases. Managers are required to report suspected or actual GBV and/or VAC cases as they

16 Where there are multiple contractors working on the project, each shall nominate a representative as appropriate.

194 have responsibilities to uphold company commitments and they hold their direct reports accountable for complying with the Individual Code of Conduct.

The project will provide information to employees and the community on how to report cases of GBV and VAC Code of Conduct breaches through the Grievance Redress Mechanism (GRM). The GCCT will follow up on cases of GBV, VAC and Code of Conduct breaches reported through the GRM.

4.3 Addressing Complaints about GBV or VAC

The figure below shows the process for addressing complaints based on the example of the Vanuatu Aviation Investment Project (VAIP).

Note: VPMU is the Vanuatu Project Management Unit (VPMU) responsible for the implementation of VAIP.

GRM

The project operates a grievance redress mechanism (GRM) which is managed by a designated GRM operator with the project implementation unit. Reports of GBV or VAC, other complaints, or other concerns may be submitted online, via telephone or mail, or in person.

All complaints regarding GBV and VAC must immediately be reported to the World Bank task team by the GRM operator.

The GRM operator will refer complaints related to GBV or VAC to the GCCT to resoLVe them. In accordance with the GBV and VAC Action Plan, the GCCT through the Service Provider and Focal Point(s) will investigate the complaint and ultimately provide the GRM operator with a resolution to

195 the complaint, or the Police if necessary. The victim’s confidentiality should also be kept in mind when reporting any incidences to the Police.

The GRM operator will, upon resolution, advise the complainant of the outcome, unless it was made anonymously. Complaints made to managers or the Service Provider will be referred by them to the GRM for processing.

If the complaint to the GRM is made by a survivor or on behalf of a survivor, the complainant will be directly referred to the service provider to receive support services while the GCCT investigates the complaint in parallel.

Service Provider

The Service Provider is a local organization which has the experience and ability to support survivors of GBV or VAC. The client, the contractor(s) and consultant must establish a working relationship with the Service Provider, so that GBV and VAC cases can safely be referred to them. The Service Provider will also provide support and guidance to the GBV and VAC Focal Points as necessary. The Service Provider will have a representative on the GCCT and be involved in resolving complaints related to GBV or VAC.

GCCT GBV and VAC Focal Points

The GCCT shall confirm that all complaints related to GBV or VAC have been referred to the World Bank by the GRM operator.

The GCCT shall consider all GBV and VAC complaints and agree on a plan for resolution. The appropriate Focal Point will be tasked with implementing the plan (i.e. issues with contractor’s staff will be for the contractor to resolve; consultant’s staff the consultant; and client staff the client). The Focal Point will advise the GCCT on resolution, including referral to the Police if necessary. They will be assisted by the Service Provider as appropriate.

All the Focal Points on the GCCT must be trained and empowered to resolve GBV and VAC issues. It is essential that all staff of the GRM and GCCT understand the guiding principles and ethical requirement of dealing with survivors of GBV and VAC. All reports should be kept confidential and referred immediately to the Service Provider represented on the GCCT17. In GBV and VAC cases warranting Police action, the Focal Points must appropriately refer the complaint to: (i) the authorities; (ii) the Service Provider; and, (iii) management for further action. The client and the World Bank are to be immediately notified.

4.4 Accountability Measures

All reports of GBV or VAC shall be handled in a confidential manner to protect the rights of all involved. The client, contractor and consultant must maintain the confidentiality of employees who notify any

17 Survivors of GBV and VAC may need access to Police, justice, health, psychosocial, safe shelter and livelihood services to begin on a path of healing from their experience of violence.

196 acts or threats of violence, and of any employees accused of engaging in any acts or threats of violence (unless a breach of confidentiality is required to protect persons or property from serious harm or where required by law). The contractor and consultant must prohibit discrimination or adverse action against an employee because of survivor’s disclosure, experience or perceived experience of GBV or VAC (see Annex 1 for examples of actions to maintain accountability).

To ensure that survivors feel confident to disclose their experience of GBV or VAC, they can report cases of GBV or VAC through multiple channels: (i) online, (ii) phone, (iii) in-person, (iv) the local service provider, (v) the manager(s), (vi) village councils; or, (vii) the Police. To ensure confidentiality, only the service provider will be privy to information regarding the survivor. The GCCT will be the primary point of contact for information and follow up regarding the perpetrator.

4.5 Monitoring and Evaluation

The GCCT must monitor the follow up of cases that have been reported and maintain all reported cases in a confidential and secure location. Monitoring must collect the number of cases that have been reported and the share of them that are being managed by Police, NGOs etc.

These statistics shall be reported to the GRM and the Supervision Engineer for inclusion in their reporting.

For any GBV and VAC cases warranting Police action, the client and the World Bank are to be immediately notified.

4.6 Awareness-raising Strategy

It is important to create an Awareness-raising Strategy with activities aimed to sensitize employees on GBV and VAC on the work site and its related risks, provisions of the GBV and VAC Codes of Conduct, GBV and VAC Allegation Procedures, Accountability Measures and Response Protocol. The strategy will be accompanied by a timeline, indicating the various sensitization activities through which the strategy will be implemented and the related (expected) delivery dates. Awareness-raising activities should be linked with trainings provided by the Service Provider.

4.7 Response Protocol

The GCCT will be responsible for developing a written response18 protocol to meet the project requirements, in accordance to national laws and protocols. The response protocol must include mechanisms to notify and respond to perpetrators in the workplace (See 4.9 for Perpetrator Policy and Response). The response protocol will include the GRM process to ensure competent and confidential response to disclosures of GBV and VAC. An employee who discloses a case of GBV or VAC in the workplace shall be referred to the GRM for reporting.

4.8 Survivor Support Measures

18 Develop appropriate protocol for written recording of GBV issues and VAC raised in case the notes are subpoenaed. Develop processes for record keeping including activities undertaken by the GCCT.

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It is essential to appropriately respond to the survivor’s complaint by respecting the survivor’s choices to minimize the potential for re-traumatization and further violence against the survivor. Refer the survivor to the Service Provider to obtain appropriate support services in the community—including medical and psychosocial support, emergency accommodation, security including Police protection and livelihood support—by facilitating contact and coordination with these services. The client, contractor or consultant may, where feasible, provide financial and other supports to survivors of GBV or VAC for these services (see Annex 1 for examples of financial support).

If the survivor is an employee, to ensure the safety of the survivor, and the workplace in general, the client, contractor or consultant, in consultation with the survivor, will assess the risk of ongoing abuse to the survivor and in the workplace. Reasonable adjustments will be made to the survivor’s work schedule and work environment as deemed necessary (see Annex 1 for examples of safety measures). The employer will provide adequate leave to survivors seeking services after experiencing violence (see Annex 1 for details).

4.9 Perpetrator Policy and Response

Encourage and accept notification through the GRM from employees and community members about perpetrators in the workplace. Through the GCCT and/or the Service Provider, oversee the investigation of these grievances, ensuring procedural fairness for the accused, and within the local laws. If an employee has breached the Code of Conduct, the employer will act which could include:

i. Undertake disciplinary action up in accordance with sanctions in the GBV and VAC Codes of Conduct; ii. Report the perpetrator to the Police as per local legal paradigms; and/or iii. If feasible, provide or facilitate counselling for the perpetrator.

5.0 Sanctions

In accordance with the Code of Conduct, any employee confirmed as a GBV or VAC perpetrator shall be considered for disciplinary measures in line with sanctions and practices as agreed in the Individual Code of Conduct (see Annex 1 for examples of sanctions). It is important to note that, for each case, disciplinary sanctions are intended to be part of a process that is entirely internal to the employer, is placed under the full control and responsibility of its managers, and is conducted in accordance with the applicable national labor legislation.

Such process is expected to be fully independent from any official investigation that competent authorities (e.g. Police) may decide to conduct in relationship to the same case, and in accordance with the applicable national law. Similarly, internal disciplinary measures that the employer’s managers may decide to enact are meant to be separate from any charges or sanctions that the official investigation may result into (e.g. monetary fines, detention etc.).

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Codes of Conduct Annex 1 - Potential Procedures for Addressing GBV and VAC

Accountability Measures to maintain confidentiality can be achieved through the following actions:

1. Inform all employees that confidentiality of GBV/VAC survivors’ personal information is of utmost importance. 2. Provide the GCCT with training on empathetic and non-judgmental listening. 3. Take disciplinary action, including and up to dismissal, against those who breach survivor’s confidentiality (this is unless a breach of confidentiality is necessary to protect the survivor or another person from serious harm, or where required by law).

GBV and VAC Allegation Procedures should specify:

1. Who survivors can seek information and assistance from. 2. The process for community members and employees to lodge a complaint through the GRM should there be alleged GBV or VAC. 3. The mechanism for how community members and employees can escalate a request for support or notification of violence if the process for reporting is ineffective due to unavailability or non- responsiveness, or if the employee’s concern in not resolved.

Financial and Other Supports to survivors can include:

1. No/low interest loans. 2. Salary advances. 3. Direct payment of medical costs. 4. Coverage of all medical costs related specifically to the incident. 5. Upfront payments for medical costs to later be recouped from the employee’s health insurance. 6. Providing or facilitating access to childcare. 7. Providing security upgrades to the employee’s home. 8. Providing safe transportation to access support services or to and from accommodation.

Based on the rights, needs, and wishes of the survivor, survivor support measures to ensure the safety of the survivor who is an employee can include19:

1. Changing the perpetrator or survivor’s span of hours or pattern of hours and/or shift patterns. 2. Redesigning or changing the perpetrator or survivor’s duties. 3. Changing the survivor’s telephone number or email address to avoid harassing contact. 4. Relocating the survivor or perpetrator to another work site/ alternative premises. 5. Providing safe transportation to and from work for a specified period. 6. Supporting the survivor to apply for an Interim Protection Order or referring them to appropriate support. 7. Taking any other appropriate measures including those available under existing provisions for family friendly and flexible work arrangements.

19 It is critical that a survivor centered approach be adopted. The survivor should be fully involved in the decision making. Except for exceptional circumstances the perpetrator should be required to take appropriate actions to accommodate the survivor (e.g. move, change hours, etc.), rather than the survivor changing.

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Leave options for survivors that are employees can include:

1. An employee experiencing GBV should be able to request paid special leave to attend medical or psychosocial appointments, legal proceedings, relocation to safe accommodation and other activities related to GBV. 2. An employee who supports a person experiencing GBV or VAC may take care givers leave, including but not limited to accompanying them to court or hospital, or to take care of children. 3. Employees who are employed in a casual capacity may request unpaid special leave or unpaid care givers leave to undertake the activities described above. 4. The amount of leave provided will be determine by the individual’s situation through consultations with the employee, the management and the GCCT where appropriate.

Potential Sanctions to employees who are perpetrators of GBV, and VAC include:

1. Informal warning 2. Formal warning 3. Additional Training 4. Loss of up to one week’s salary. 5. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. 6. Termination of employment.

Referral to the Police or other authorities as warranted.

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Appendix 9: The Existing Memoradum Between NAWEC and the Department of Forestry

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Appendix 10: Technical Note: Public Consultations and Stakeholder Engagement in WB-Supported Operations when there are Constraints on Conducting Public Meetings

With the outbreak and spread of COVID-19, people have been advised, or may be mandated by national or local law, to exercise social distancing, and specifically to avoid public gatherings to prevent and reduce the risk of the virus transmission. Countries have taken various restrictive measures, some imposing strict restrictions on public gatherings, meetings and people’s movement, and others advising against public group events. At the same time, the general public has become increasingly aware and concerned about the risks of transmission, particularly through social interactions at large gatherings.

These restrictions have implications for World Bank-supported operations. In particular, they will affect Bank requirements for public consultation and stakeholder engagement in projects, both under implementation and preparation. WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. All these documents are available on the WHO website through the following link: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance.

This Note offers suggestions to World Bank task teams for advising counterpart agencies on managing public consultation and stakeholder engagement in their projects, with the recognition that the situation is developing rapidly and careful regard needs to be given to national requirements and any updated guidance issued by WHO. It is important that the alternative ways of managing consultation and stakeholder engagement discussed with clients are in accordance with the local applicable laws and policies, especially those related to media and communication. The suggestions set out below are subject to confirmation that they are in accordance with existing laws and regulations applying to the project.

Investment projects under implementation. All projects under implementation are likely to have public consultation and stakeholder engagement activities planned and committed as part of project design. These activities may be described in different project documents and will involve a variety of stakeholders. Commonly planned avenues of such engagement are public hearings, community meetings, focus group discussions, field surveys and individual interviews. With growing concern about the risk of virus spread, there is an urgent need to adjust the approach and methodology for continuing stakeholder consultation and engagement. Taking into account theimportance of confirming compliance with national law requirements, below are some suggestions for task teams’ consideration while advising their clients:

Task teams will need to review their project, jointly with the PMUs, and should:

Identify and review planned activities under the project requiring stakeholder engagement and public consultations.

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• Assess the level of proposed direct engagement with stakeholders, including location and size of proposed gatherings, frequency of engagement, categories of stakeholders (international, national, local) etc.

• Assess the level of risks of the virus transmission for these engagements, and how restrictions that are in effect in the country / project area would affect these engagements.

• Identify project activities for which consultation/engagement is critical and cannot be postponed without having significant impact on project timelines. For example, selection of resettlement options by affected people during project implementation. Reflecting the specific activity, consider viable means of achieving the necessary input from stakeholders (see further below).

• Assess the level of ICT penetration among key stakeholder groups, to identify the type of communication channels that can be effectively used in the project context.

Based on the above, task teams should discuss and agree with PMUs the specific channels of communication that should be used while conducting stakeholder consultation and engagement activities. The following are some considerations while selecting channels of communication, in light of the current COVID-19 situation:

• Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings;

• If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings If not permitted, make all reasonable efforts to conduct meetings through online channels, including webex, zoom and skype;

• Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders;

• Employ traditional channels of communications (TV, newspaper, radio, dedicated phone-lines, and mail) when stakeholders to do not have access to online channels or do not use them frequently. Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions;

• Where direct engagement with project affected people or beneficiaries is necessary, such as would be the case for Resettlement Action Plans or Indigenous Peoples Plans preparation and implementation, identify channels for direct communication with each affected household via a context specific combination of email messages, mail, online platforms, dedicated phone lines with knowledgeable operators;

• Each of the proposed channels of engagement should clearly specify how feedback and suggestions can be provided by stakeholders;

• An appropriate approach to conducting stakeholder engagement can be developed in most contexts and situations. However, in situations where none of the above means of communication are considered adequate for required consultations with stakeholders, the team should discuss with the PMU whether the project activity can be rescheduled to a later time, when meaningful stakeholder engagement is possible. Where it is not possible to postpone the activity (such as in the case of

209 ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance.

Investment projects under preparation. Where projects are under preparation and stakeholder engagement is about to commence or is ongoing, such as in the project E&S planning process, stakeholder consultation and engagement activities should not be deferred, but rather designed to be fit for purpose to ensure effective and meaningful consultations to meet project and stakeholder needs. Some suggestions for advising clients on stakeholder engagement in such situations are given below. These suggestions are subject to the coronavirus situation in country, and restrictions put in place by governments. The task team and the PMU should:

• Review the country COVID-19 spread situation in the project area, and the restrictions put in place by the government to contain virus spread;

• Review the draft Stakeholder Engagement Plan (SEP, if it exists) or other agreed stakeholder engagement arrangements, particularly the approach, methods and forms of engagement proposed, and assess the associated potential risks of virus transmission in conducting various engagement activities;

• Be sure that all task team and PIU members articulate and express their understandings on social behavior and good hygiene practices, and that any stakeholder engagement events be preceded with the procedure of articulating such hygienic practices.

• Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings, and minimize direct interaction between project agencies and beneficiaries / affected people;

• If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings. If not permitted, make all reasonable efforts to conduct meetings through online channels, including webex, zoom and skype meetings;

Employ traditional channels of communications (TV, newspaper, radio, dedicated phone-lines, public announcements and mail) when stakeholders do not have access to online channels or do not use them frequently. Such channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions;

• Employ online communication tools to design virtual workshops in situations where large meetings and workshops are essential, given the preparatory stage of the project. Webex, Skype, and in low ICT capacity situations, audio meetings, can be effective tools to design virtual workshops. The format of such workshops could include the following steps:

- Virtual registration of participants: Participants can register online through a dedicated platform. - Distribution of workshop materials to participants, including agenda, project documents, presentations, questionnaires and discussion topics: These can be distributed online to participants. - Review of distributed information materials: Participants are given a scheduled duration for this, prior to scheduling a discussion on the information provided.

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- Discussion, feedback collection and sharing: ✓ Participants can be organized and assigned to different topic groups, teams or virtual “tables” provided they agree to this. ✓ Group, team and table discussions can be organized through social media means, such as webex, skype or zoom, or through written feedback in the form of an electronic questionnaire or feedback forms that can be emailed back. - Conclusion and summary: The chair of the workshop will summarize the virtual workshop discussion, formulate conclusions and share electronically with all participants.

• In situations where online interaction is challenging, information can be disseminated through digital platform (where available) like Facebook, Twitter, WhatsApp groups, Project weblinks/ websites, and traditional means of communications (TV, newspaper, radio, phone calls and mails with clear description of mechanisms for providing feedback via mail and / or dedicated telephone lines. All channels of communication need to clearly specify how stakeholders can provide their feedback and suggestions.

• Engagement with direct stakeholders for household surveys: There may be planning activities that require direct stakeholder engagement, particularly in the field. One example is resettlement planning where surveys need to be conducted to ascertain socioeconomic status of affected people, take inventory of their affected assets, and facilitate discussions related to relocation and livelihood planning. Such survey activities require active participation of local stakeholders, particularly the potentially adversely affected communities. However, there may be situations involving indigenous communities, or other communities that may not have access to the digital platforms or means of communication, teams should develop specially tailored stakeholder engagement approaches that will be appropriate in the specific setting. The teams should reach out to the regional PMs for ENB and Social Development or to the ESSA for the respective region, in case they need additional support to develop such tailored approaches.

• In situations where it is determined that meaningful consultations that are critical to the conduct of a specific project activity cannot be conducted in spite of all reasonable efforts on the part of the client supported by the Bank, the task team should discuss with the client whether the proposed project activities can be postponed by a few weeks in view of the virus spread risks. This would depend on the COVID-19 situation in the country, and the government policy requirements to contain the virus spread. Where it is not possible to postpone the activity (such as in the case of ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance.

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Appendix 11 PROTOCOL FOR CONSULTATION AND CIVIL WORKS UNDER COVID 19 ECOWAS REGIONAL ELECTRICITY ACCESS PROJECT (ECOREAP) IN THE GAMBIA

1.1 Introduction

The novel coronavirus disease (COVID-19) has been spreading rapidly across the world since December 2019, following the initial cases in Wuhan, Hubei Province, China. Whilst the pandemic imposed enormous strain on the health systems as they try to cope with the increase demand for services, it has also resulted in tremendous economic and social hardship as governments institute measures such as ‘social distancing’ to limit the spread of the disease. One of the consequences of these measures was the closure of schools, stoppage of civil works, trade and travel, closure of borders, and other economic activities.

A key source of guidance on communications, civil works, and stakeholder engagement that the Project will draw on is the Ministry of Health guidelines which are in line with the World Health Organization’s (WHO) “COVID-19 Strategic Preparedness and Response Plan: Operational Planning Guidelines to Support Country Preparedness And Response” (2020). These guidelines outline the following approach in their Risk Communication and Community Engagement - Pillar 2.

It will lay the basis for the Project’s stakeholder engagement and civil works implementation approach. The project will also draw on other recently-available resources for carrying out the implementation of the civil works in the context of COVID-19, including the World Bank’s “Technical Note: Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on conducting public meetings” (March 20, 2020). These guidelines will be taken into consideration for the civil works in order to protect workers, the affected communities and Project staff.

The Gambia has declared a state of Emergency, which is still maintained by the Authorities. Given the raising of the number of cases and the social distancing recommended in order to stop or reduce the COVID 19 transmission, the Project has decided to elaborate this Protocol in order to implement the upcoming stakeholder engagement and civil works implementation.

1.2 Methodology

To meet best practice approaches, the Project will apply the following principles for stakeholder engagement and civil works implementation:

• Openness and life-cycle approach: public consultations for the Project will be arranged during the whole lifecycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation

• Informed participation and feedback: information will be provided to and widely distributed among all stakeholders in an appropriate and accessible format and language; opportunities are provided for communicating stakeholders’ feedback, for analyzing and addressing comments and concerns

• Inclusiveness and sensitivity: stakeholder identification will be undertaken to support better communication about project activities and development, transparency, accountability and build effective community relationships. The participation process for the project will be inclusive and will consider vulnerable and disadvantaged groups to ensure they can attend and fully participate in discussions. All stakeholders are encouraged to be involved in the

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consultation process, and this includes ensuring that the time of day of meetings is suitable for women who may have different work schedules and commitments and that persons with disabilities are able to attend and participate. Every community member will have access to information. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods and the time and location of meetings. Special attention should be given to vulnerable groups, in particular women, youth, disabled, elderly and the cultural sensitivities of diverse ethnic groups. Consultations should be conducted with women in sex- segregated groups and in safe and enabling settings, which means that confidentiality can be assured and that these consultations will be facilitated by other women.

• Flexibility: if social distancing inhibits traditional forms of engagement, the methodology should adapt to other forms of engagement, including various forms of internet, radio, or TV communication, and communication via mail.

• A precautionary approach will guide consultation process and civil works implementation to prevent infection and/or contagion, given the highly infectious nature of COVID-19.Worker and Community Health and Safety: to avoid or reduce the risk of contagion or spreading the COVID-19, all workers will wear their mask, goggles and other personal protective equipment (PPE) and respect social distancing protocols at the site. Same measures will be followed in interactions with local communities.

• Affected Parties – persons, groups and other entities within the Project Area of Influence (PAI) that are directly influenced (actually or potentially) by the Project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures;

• Vulnerable Groups – persons who may be disproportionately impacted or further disadvantaged by the Project as compared with any other groups due to their vulnerable status20, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the project. Consultations should be conducted with women in sex-segregated groups and in safe and enabling settings, which means that confidentiality can be assured and that these consultations will be facilitated by other women.

1.3 Consideration of impacts on disadvantaged/vulnerable individuals or groups

It is particularly important to understand how project impacts may disproportionately fall on disadvantaged or vulnerable individuals or groups who often do not have a voice to express their concerns or may not be considered fully when addressing the impacts of a project. It is equally important that awareness raising and stakeholder engagement with disadvantaged or vulnerable individuals or groups be undertaken with respect to infectious diseases and medical treatments. Such consultations must be adapted to consider such groups and/or individuals concerns and cultural or other sensitivities and to ensure a full understanding of project activities and benefits. Consultations should be conducted with women in sex-segregated groups and in safe and enabling settings, which means that confidentiality can be assured and that these consultations will be facilitated by other

20 Vulnerable status may stem from an individual’s or group’s race, national, ethnic or social origin, color, gender, language, religion, political or other opinion, property, age, culture, literacy, health status, physical or mental disability, poverty or economic disadvantage, and dependence on unique natural resources, among others.

213 women. The vulnerability may stem from person’s origin, gender, age, health condition, economic status, disability, livelihood, among others. Engagement with vulnerable groups and individuals often requires the application of specific measures and assistance aimed at the facilitation of their participation in the project-related decision making so that their awareness of and input to the overall process are commensurate to those of the other stakeholders.

Within the Project, the vulnerable or disadvantaged groups may include and are not limited to the following: women-headed households, elders, youth, people renting land (especially women renters), youth, elders, and persons with disabilities. Vulnerable groups within the communities affected by the Project will be consulted through dedicated means, as appropriate. Description of the methods of engagement that will be undertaken by the project is provided in the following sections.

Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered.

1.4 Strategy

The PIU in collaboration with the stakeholders will identify and examine all the activities planned within the framework of the project requiring the engagement of stakeholders, public consultations, and civil works implementation.

The PIU and its consultants and future contractors will evaluate the targets, the location, and the size of the proposed activities. Personal contact and large social gatherings or meetings will be limited and all protocols from the Government regarding social distancing will be respected. The PIU and its consultants and future contractors will assess the level of risk of spread to the community and how best to align with restrictions in effect at the national level.

In addition, The PIU and its consultants and future contractors will identify the critical activities for which the consultations cannot be postponed without significant impact on the project deadlines. At the end of this exercise, the PIU will consider viable means to obtain the contributions and commitment of stakeholders.

Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered.

Where planned civil work activities require community meetings, PIU and contractors will assess how to put in place proper social distancing and make available PPE such as masks, eye shields, hand sanitizers, etc. for workers and community members.

Before consultation and civil works can start, the Project will require Contractors to identify and visit the affected communities.

The objective of this mission will be to:

• The PIU and its consultants and future contractors will also assess the media coverage to see which media channels are more suitable for spreading information about COVID-19 preventive measures, who to contact if people are exhibiting symptoms, and how to contact the Grievance Mechanism (GM) should community members have additional questions or concerns.

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• According to the affected areas, The PIU and its consultants and future contractors will review the best telecommunication coverage to decide which ones they will use to communicate with communities, considering the commitment to inclusive and accessible participation and communication.

• Traditional communication channels will also be assessed to verify how they can be effective in conveying relevant information to stakeholders.

According to the outcomes of field visits, The PIU and its consultants and future contractors will be able to start site preparation and sensitization of affected communities about the ESMP, GM, RAP, information about SEA/SH risks, especially around civil works, access to services, and how to lodge complaints through the GM, and COVID-19 mitigation measures that are recommended by the WHO and the Ministry of Health.

Following the field visit, the Project will implement specific measures to mitigate the risk of the COVID- 19 transmission.

A precautionary approach will guide the consultation process and the implementation of civil works to prevent transmission and infection, given the highly infectious nature of COVID-19.

The following are some considerations for selecting channels of communication and encouraging behavior for the safe implementation of the civil works, considering the current COVID-19 pandemic. Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered:

• Avoid public gatherings (considering national restrictions or advisories), including public hearings, workshops, community meetings, and in working sites

• As smaller meetings are permitted (Five people with distance of 1.5m distance between participants), consultations will be conducted in small-group sessions, such as focus group meetings. Efforts will be made to conduct meetings through telephone or, if possible, online, channels to reduce risk of contagion or contamination

• Employ channels of communications (TV, newspaper, radio, dedicated phone-lines, and mail) when stakeholders do not have access to online channels or do not use them frequently. Communication channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions

• Where direct engagement with project affected people or beneficiaries is necessary, identify channels for direct communication with each affected household via a context specific combination of email messages, online platforms, dedicated phone lines with knowledgeable operators

• communication channels during COVID-19 will also help women receive accurate information about SEA/SH risk, access to services, and the project GM

• Each of the proposed channels of engagement will clearly specify to community members how feedback and suggestions can be provided by stakeholders via the project’s GM.

1.5 Management of COVID-19 during civil works

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A special COVID-19 induction will be performed for each employee before they are able to start work. Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered. This induction will be entirely dedicated to COVID-19:

• How it spreads

• How to protect oneself (including washing protocols)

• How to properly use PPE (mask and gloves) and requirements of wearing PPE

• Understanding symptoms and what to do if one is exhibiting them

• Understanding the impact of COVID-19 on vulnerable groups (who is vulnerable)

This induction will be renewed for all workers every month and every day before the start of activities, a specific briefing will be carried out by the Site Manager who is the team leader.

The Site Manager will address the following points:

• Reminder of the context and the need to respect the rules

• Reminder of barrier gestures: how to cough, hand hygiene (basins and soap will be always available on site), social distancing and wearing a mask

• Taking of temperature every morning before works start

• Reminder of the exceptional measures applicable to the activities concerned

• Reminder of the main symptoms of COVID-19

• Reminder of the COVID-19 Hotline 1052

Monitoring of symptoms and other hygiene and mitigation protocols:

• Symptoms associated with COVID-19 will be monitored in workers. Each worker should monitor the onset of symptoms for themselves and colleagues and inform their manager immediately if they feel unwell or suspect a colleague is not feeling well. If symptoms appear during the night, the employee notify their superior and not come to the construction site. The procedure applied will then be the same as for employees who will be present in the morning with fever.

• The PIU and its consultants and future contractors will ensure the transportation to health centers by liaising with the COVID-19 Hotline 1052 in case ambulances of the health centers are not available.

• PPE must be clean and for individual use only (they must not be shared, exchanged, or loaned between employees). Barrier/social distancing against COVID-19 must be applied during break times and meals. Drinking water materials for personnel such as a cup or water bottle must be available for all workers and must not be shared for use among workers. Anyone who is not an employee of The PIU, and its consultants and future contractors will not have access to the site. Any visitor wanting access to the site must submit to the same COVID-19 mitigation controls as employees.

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• Cleanliness, including sanitization, of personnel reception facilities must be maintained regularly throughout the day. Any waste likely to be infected must be managed to avoid any risk of contamination.

• The PIU and its consultants and future contractors will delimit the site and provide posters showing measures to be strictly followed by all who are on site.

• It is planned that about 10 people will be each work site. Workers must always wear masks, goggles, and maintain regular hand cleanliness. Hand sanitizers will be available in all strategic areas of the site.

• Equipment to take temperatures for all entering in the work sites should be available. In each site, Contractors will have two thermometers, regularly cleaned to avoid contamination in each site. Taking of temperature and management of the thermometers should be the responsibility of the ESHS officer.

• The contact information of the local COVID-19 committee (set up by the Ministry of Health under the Governor with all the relevant stakeholders in each region) COVID-19 1025 Hotline will be communicated to all workers. The contact number will be posted on site. The Project will closely work with this committee to implement the Project in a safely manner.

In line with the above precautionary approach, different engagement methods are proposed and cover different needs of the stakeholders as below:

• All in person meetings (such as consultation meetings, focus group meetings, one on one interviews (respecting social distancing requirements, wearing masks and eye shields)

• Public notices

• Electronic publications and press releases on the NAWEC website and social media, NAWEC Talk show radio and community radios in the Provinces

• Telephone Interviews

• Text messages communication

• Social media notices

• Posters erected in communities

At all times, the following COVID-19 mitigation measures will be followed in engaging with the public:

• Availability of hand sanitizers

• Thermometers in each working site

• Social distancing of 1,5 meters between workers

Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions, such as committees of elders, women, youth, but also communication of religious leaders like imams and the griot (traditional communicators.

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In the event none of the above means of communication is considered adequate for the required consultations with stakeholders, Contractors and service providers should discuss with the PIU to find out if the activity in question can be postponed at a later date, when significant stakeholder engagement is possible. When it is not possible to postpone the activity or when the postponement is likely to last more than a few weeks, the PIU should consult the World Bank team for advice and guidance.

1.6 Conclusion

During all this process, recommended WHO hygienic practices will be respected and monitored by the PIU safeguards team to ensure that mitigation measures would be properly followed and duly respected. As protocols and recommendations by the WHO changes in response to this pandemic, these protocols will be updated accordingly.

Appendix 12: Contract Clauses to be Included in Contractors’ Agreements

The rules, including specific prohibitions and construction management measures, should be incorporated into all relevant bidding documents, contracts, and work orders.

General Prohibitions: The following activities should be prohibited on or near the project site: ▪ Cutting of trees for any reason outside the approved construction area ▪ Hunting, fishing, wildlife capture, or plant collection; All employees, including volunteers and sub-contractors should be encouraged to anonymously report suspected or actual acts of hunting/killing of wild animal by a fellow worker ▪ Use of unapproved toxic materials ▪ Disturbance to anything with architectural or historical value ▪ Setting of fires ▪ Use of firearms (except authorized security guards) ▪ Use of alcohol by workers ▪ Employment of children in accordance with international law and the Children’s Act.

Protection of Trees and Vegetation:

▪ Remove vegetation around pole site only as necessary ▪ Ensure that only the right of way is cleared; avoid forests ▪ Cover area around the pole foundations to facilitate revegetation ▪ Seek approval from DOF before forest trees are felled ▪ Keep records (types and quantities) of all ‘forest trees’ to be fell

Waste Management:

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▪ Develop a waste management plan including types of waste, expected quantities and frequency, proposed storage and disposal procedures and responsibilities, etc. Minimize the production of waste that must be treated or eliminated. If hazardous wastes are generated, proper procedures must be taken regarding their storage, collection, transportation and disposal. ▪ Do not burn any type of waste ▪ Waste must be collected and stored for disposal or treatment at approved sites as per waste management plan. Identify and demarcate disposal areas clearly indicating the specific materials that can be deposited in each. ▪ Clean waste such as cleared vegetation, packaging and rubble shall be given to workers or communities for reuse and recycling ▪ Set an internal supervision and monitoring system to ensure waste reduction and management. ▪ Control placement of all construction waste (including earth cuts) to approved disposal sites. Dispose in authorized areas all of garbage, metals, used oils, and excess material generated during construction, incorporating recycling systems and the separation of materials. ▪ Establish and enforce daily site clean-up procedures, including maintenance of adequate disposal facilities for construction debris.

Construction related measures:

▪ Ensure that all equipment maintenance activities, including oil changes, are conducted within demarcated maintenance areas; never dispose spent oils on the ground, in water courses, drainage canals or in sewer systems. ▪ To avoid soil compaction, use only approved and existing routes, do not establish new routes ▪ Grade existing routes to improve surface drainage. ▪ Avoid water sources and report any noticeable reduction in quality ▪ Remove excess and unused materials and equipment from work sites to improve the landscape ▪ Decommission all camps and bases including clearing of all waste

Quarrying realted measures: ▪ Where sand and gravel dealers are used, ensure only suppliers certified by the NEA and GD are used. ▪ Ensure approval is obtained from the NEA and GD for any proposed quarry site ▪ Fully implement the mine management plans ▪ All quarry pits created by the project must be rehabilitated after construction works ▪ Avoid extraction to the water table and near surface water bodies

Labour health and safety: ▪ Place signs and lighting at strategic locations informing community before works starts.

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▪ Conduct safety training for construction workers prior to beginning work; provide induction and training on the job, safety issues and other relevant ESMP requirements. Drivers must also be trained on defensive driving. ▪ Provide personal protective equipment and clothing (goggles, gloves, respirators, dust masks, hard hats, steel-toed boots etc.,) for construction workers and enforce their use. ▪ During heavy rains or emergencies of any kind, suspend all work. ▪ Safely store hazardous machinery and items away from the public. ▪ Educate on risks and prevention of STD/STIs ▪ Erect Speed bumps and speed limits. ▪ Make the hiring medical examination for all workers compulsory ▪ Sensitize on interpersonal relationship management between and among workers and community members; set codes of conduct ▪ Provide fire extinguishers and first aid kits including training on their use ▪ Provide constant supervision and record and report incidents to address causes for preventing recurrence and promoting improvement

Prevention of Violence against Children and Women:

▪ Ensure enforcement and adherence to Codes of Conduct for addressing VAC, GBV, and SEA, including regular monitoring and awareness building of the Codes of Conduct ▪ Do not employ or exploit children for project works ▪ Encourage women to enlist for employment in project activities without any impediments put in their way ▪ Develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women ▪ Enforce and monitor Codes of Conduct for workers and all those involved in the project ▪ Sensitize about the Codes of Conduct for workers and community; ▪ Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct) ▪ Conduct periodic training of employees on the codes of conduct and related procedures

Community Safety during Construction: The Contractor’s responsibilities include the protection of every person (workers and the public) and nearby property from construction accidents. The Contractor shall be responsible for complying with all national and local safety requirements and any other measures necessary to avoid accidents, including the following:

▪ Carefully and clearly mark pedestrian-safe access routes. ▪ If school children are in the vicinity, include traffic safety personnel to direct traffic. ▪ Restrict and monitor public access to the work sites ▪ Construction works within the Loumo area on a market day must be avoided ▪ Cover up the trucks, to prevent wind blowing away sand and gravel to generate dust

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▪ Initiate sensitization and education programs for communities and workers on the dangers and mitigation measures to address STIs; Encourage use of condoms to prevent STIs ▪ Carry out active monitoring of workers (screening, testing and analysis of such recorded data, etc.) to take timely action through treatment and health education to prevent spread of diseases ▪ Ensure surroundings are safe and secure for all (implement health and safety plan, coordinate, inform, supervise and monitor)

Nuisance and dust control should include: ▪ Maintain all construction-related traffic at minimum ▪ Cordoning off work sites to prevent access ▪ Use and maintain well-serviced equipment and machinery; avoid overloading that strain the engines to reduce noise ▪ In sensitive areas (including residential neighbourhoods, health centres, schools) more strict measures may need to be implemented to prevent undesirable noise levels, including controlled working times; works shall only be carried out during daytime ▪ Give prior notice to institutions amnd communitites about the works and work during weekends when activities are less around these institutions ▪ Minimize production of dust and particulate materials at all times, to avoid impacts on surrounding families and businesses ▪ Use dust suppression measures such as dampening on dirt roads, cut areas and soil stockpiles or fill material. ▪ Trucks transporting sand and gravel must be covered to prevent dust and flying debris ▪ Ensure that engines of vehicles and machinery are not idle for prolonged periods unnecessarily ▪ Apply proper measures to minimize disruptions from vibration or noise coming from construction activities.

Community Relations: To enhance adequate community relations, the Contractor should: ▪ Employ local unskilled workers to enhance community cohesion as local workers will know the community better, its culture, norms, and values, which may also help in reducing the risks of GBV, VAC and STIs. ▪ Inform the population about construction and work schedules, interruption of services, traffic detour routes as appropriate. ▪ Avoid construction activities at night.

Chance Find Procedures for Culturally Significant Artefacts: ▪ Avoid mosques, cemeteries, World Heritage Sites and similar sites of cultural significance ▪ Consult with the communities to help identify any other cultural or spiritual sites of importance

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In case culturally valuable materials are uncovered during excavation: ▪ Stop work immediately following the discovery of any materials with possible archaeological, historical, paleontological, or other cultural value, announce findings to project manager and notify the PCU who in turn notifies the National Council for Arts and Culture ▪ Protect artefacts as well as possible, using plastic covers, and implement measures to stabilize the area, if necessary ▪ Prevent unauthorized access to the artefacts ▪ Restart construction works only upon the authorization of the relevant authorities.

ENVIRONMENTAL AND SOCIAL SUPERVISION DURING CONSTRUCTION The “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV) and Violence Against Children (VAC)” should also be considered in contracts. All bidding documents should indicate how compliance with environmental rules and design specifications would be supervised, along with the penalties for noncompliance by contractors or workers. Construction supervision requires oversight of compliance with the ESMP by the contractor or his designated environmental supervisor. Depending on the type and severity of breach, penalties may include: ▪ cancellation of contract ▪ suspension of works, and payment withheld until remediation has taken place without entitlement to claims ▪ existing penalities listed by various laws for specific breaches ▪ litigation for breaches of specific laws (by NAWEC, the relevant enforment institutions or affected parties). ▪ barring the contractor from future assignments of the World Bank and NAWEC

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Appendix 13: Modalities of the Proposed Grievance Redress Mechanism

Ste Process Description / Time-frame Responsible Agency / Person p Required Action 1 Receipt of Document date of 1 day GRC/PIU (specifically social complaint receipt, name of safeguards specialist) complainant, nature of complaint 2 Acknowledge By letter, email, phone 1-5 days Social safeguards specialist at receipt of the PIU grievance and Communicate Response 3 Screen and Visit the site; listen to 7-14 days GRC members including the establish the the complainant / project safeguard specialist, foundation or community; assess complainant and his/her merit of the the merit representative grievance 4 If the complaint If yes, inform 21-30 days or Project Coordinator, SSS/ESS has merit, the GRC complainant of at a time to coordinate the to proceed with possible resolution. If specified in implementation of redress resolution. no, inform writing to action complainant, record the his/her response and complainant inform him/her of escalation measures if he/she would like to proceed further (see 5) 4A Is resolution If yes, GRC move to 2-5 days Project Coordinator/SSS/ESS acceptable to the implement and complainant? monitor measure.

Notify complainant when implementation is complete and ask complainant if he/she is satisfied and record response. If not, move to 5. 5 Extra intervention If response is 2-4 weeks of Project Coordinator GERMP for a dissatisfied unacceptable to receiving and GRC to review and react scenario including complainant, review status report resolution not the redress steps and acceptable to conclusions, provide complainant/not intervention solution implemented properly/fully 6 Judicial Take complaint to No fixed time Complainant adjudication court of law

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7 Funding of GRC logistics (costs of No fixed time GERMP grievance process litigation, training), redress compensation, court process

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Appendix 14: Flow Chart of Grievance Redress Process

Maximum Timeframe for implementation of Grievance Redress Action is 85 days from receipt of complaint

(1) PCU Receives Complaint PAP (1Day)

(3) Screen and Establish Merit (7-14 Days)

(2) PCU Acknowledges Complaint/Co (3A) Is Complaint mmunicate Acceptable? Response (1-5 Day) (1-5 Day)

(5) If Complaint is acceptable, then Implement and Monitor Redress action (21 – 30 Days)

(6) Extra Intervention for a Dissatisfactory Scenario (2 – 4 Weeks)

(7) Judicial Adjudication (No Fixed Time)

(8) Funding of grievance Process (No Fixed Time)

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