E661 October 2002

SIERRA LEONE NATIONAL COMMISSION FOR SOCIAL ACTION Public Disclosure Authorized

Environmental Assessment for the

Public Disclosure Authorized National Social Action Project (NSAP)

PreparedBy:

Dr. Raymond Geoffrey Johnson (Lead Consultant)

Public Disclosure Authorized E.A. Specialist

Dr. Reynold Godfrey Johnson Social Impact/NaturalResource ManagementSpecialist

Dr. Ernest Tom Ndomahina (Trainee Specialist)

Public Disclosure Authorized October 2002 TABLE OF CONTENTS Abbreviations and Acronyms Executive Summary 1.0 Introduction 6 2.0 Description of the Project 7 2.1 Background information on National Commission for Social Action (NaCSA.) 8 2.1.1 Funding 2.1.2 Country Project Focus 2.2 Review of NaCSA's Community Driven Initiatives 9 2.3 Achievements of the Commission 10 2.4 Lessons Learnt 10 2.5 Synergies Between Various Sub-projects 11 2.6 Purpose and Requirement of the Environmental Assessment 12 3.0 Description of the Area of Influence 13 3.1 The Biophysical Characteristics 13 3.1.1 3.1.2 District 3.1.3 3.1.4 3.1.5 3.1.6 3.2 The Social Structure of the Project Area 21 4.0 Description of the Legal, Regulatory and Administrative Frameworks 21 4.1 Organizational Structure of Environmental Management of the National level 21 4.2 Organizational Structure of Environmental Management at the Local Level. 25 4.3 International Conventions 26 4.4 The World Bank Social Safeguards and Policies 26 4.4.1 Operational Policies and Directives 26 4.5 Synergy between World Bank Safeguards and Policies and the Current E.A. Study 28 5.0 Methodology and Techniques used in Assessing and Analysing the Impacts 29 6.0 Consultations 31 6.1 Consultations with Affected People 32 6.1.1 Perceptions of the people about the environmental problems that are associated with the project. 6.2 Consultations with NaCSA Officials 7.0 Analysig'of Potential Xegative and Positive Environmental and Social Impacts of the Project 33 7.1 Impacts of Shelter and Housing Rehabilitation Program in "Newly Accessible Areas" 33 7.2 Potential Negative Environmental Impacts of Agricultural Inputs 37 7.3 Potential Negative Environmental Impacts of the Rehabilitation of Community infrastructure 39 7.4 Potential Negative Environmental Impacts of small-scale Irrigation Facilities 41 7.5 The Social Impacts of the Project 42 8.0 Managing the Negative Environmental and Social Impacts of the Project 44 8.1 Mitigating Measures for Shelter and Housing Rehabilitation 44 8.2 Mitigating Measures for Agricultural Inputs 47 8.3 Mitigating Measures for the Environmental Impacts of the Provision of Markets, Court Barries, Schools and Security Posts 49 8.4 Mitigating Measures for Social Impacts 52 8.5 Analysis of Alternatives 53 9.0 Description of the Institutional Arrangements for the Management of the Negative Environmental Impacts of Community Driven Initiatives 53 9.1 Institutional Arrangements 53 9.2 Specific Procedures 54 10.0 Proposed Institutional Framework for Environmental Management 55 10.1 Environmental Assessment Standing Committee 55 11.0 Proposed Mitigating Measures and Cost Estimates 56 11.1 Awareness Raising 57 11.2 Training Programme 57 12.0 Environmental and Social Monitoring Indicators 58 13.0 Environmental and Social Monitoring Plans 58 13.1 Environmental Monitoring Plan 58 13.2 Social Monitoring Plan 59 13.3 Persons and Institutions Contacted 59 General Recommendations 60 References 61 Annexes 62

2 8.2 Mitigating Measures for Agricultural Inputs 47 8.3 Mitigating Measures for the Environmental Impacts of the Provision of Markets, Court Barries, Schools and Security Posts 49 8.4 Mitigating Measures for Social Impacts 52 8.5 Analysis of Alternatives 53 9.0 Description of the Institutional Arrangements for the Management of the Negative Environmental Impacts of Community Driven Initiatives 53 9.1 Institutional Arrangements 53 9.2 Specific Procedures - 54 10.0 Proposed Institutional Framework for Environmental Management 55 10.1 Environmental Assessment Standing Committee 55 11.0 Proposed Mitigating Measures and Cost Estimates 56 11.1 Awareness Raising 57 11.2 Training Programme 57 12.0 Environmental and Social Monitoring Indicators 58 13.0 Environmental and Social Monitoring Plans 58 13.1 Environmental Monitoring Plan 58 13.2 Social Monitoring Plan 59 13.3 Persons and Institutions Contacted 59 General Recommendations 60 References 61 Annexes 62

2 Abbreviation and Acronyms MOHS Ministry of Health and Sanitation EPA Environmental Protection Act NGO Non Govemmental Organisation NaCSA National Commission for Social Action OCHA Organisation for the Coordination of Humanitarian Assistance WB World Bank EA Environmental Assessment EPD Environment Protection Department MLHCPE Ministry of Lands, Housing, Country Planning and the Environment CBO Community Based Organisation ADA Area Development Association FCC Freetown City Council WATSAN Water and Sanitation IFC International Finance Co-operation IDA International Development Agency IDPs Internally Displaced Persons SHARP HIV/AIDS Response Project WMP Waste Management Plan RPF Resettlement Policy Framework AIDS Acquired Immune Deficiency Syndrome BSAP Biodiversity Support Action Plan NEAP National Environmental Action Plan NEP National Environmental Policy MNRRR Ministry.of National Resettlement Reintegration and Reconstruction NCRRR National Commission for Resettlement Reintegration and Reconstruction ECOMOG ECOWAS Military Organisation

3 EXECUTIVE SUMMARY The EA identified a number of negative environmental impacts that may arise from project activities. However these impacts are all manageable. To achieve this, NaCSA will implement the proposed mitigating measures, which will be overseen by local authorities and area development communities.

The EA identified various impacts on land, water and air and proposed mitigating measures. The main findings are that the project will not have significant negative environmental impact at specific sites on the following:

* Human Health and human made environment * Land quality * Water quality * Air quality * Flora and Fauna * Protected wildlife and forest reserves * Monuments and sites of cultural and historic significance

Other findings include:

* The project is community driven and service oriented * The project was well conceived and environmental concerns have been taken on board implicitly * The environmental impacts of the project are manageable

A number of social impacts were identified. These impacts are all manageable as NaCSA and its partners will assume a more definitive and strategic role in responding to the needs of the local communities. The main findings include:

* There will be no involuntary displacement of people due to the project * There will be no loss of agricultural land since the project is community driven. * There will also not be a sudden upsurge of population in these areas * Other people have not taken up residence in areas original occupants will be returning * No squatters were found on sites visited * Water supply and sanitation conditions in the project areas need to be improved.

The EA has not considered alternative project sites, as the facilities to be rehabilitated are on sites they previously occupy.

The EA has described institutional arrangements for the management of the negative environmental inputs of the Community Driven Initiatives.

It has identified national and local frameworks as the overall structure and has shown how NaCSA can utilize this arrangement to ensure proper implementation of mitigation programs. The role of NGOs and CBOs in this framework is also mentioned.

4 Specific Procedures were identified and discussed which might be required by NaCSA projects in the form of management plans. Prominent amongst these is the Environmental Management Plan (EMP), which discusses the potential negative impacts of the NSAP and proposes mitigation measures and cost estimates. The main issues here relate to land rehabilitation, reforestation, clean-up programmers, proper project sitting and implementation of monitoring programs.

The Biodiversity Strategy Action Plan is being developed as part of the implementation strategy of the National Environmental Action Plan (NEAP).

The newly developed Waste Management Plan (WMP) of the Sierra Leone HIV/AIDS Response Project (SHARP) has also been highlighted as being required by NaCSA during the implementation of NSAP.

The EA also makes reference to the Resettlement Policy Framework that has been prepared and which presents a framework for the development of specific programs, in case the NaCSA projects result in involuntary displacement of people.

The EA proposed an Institutional Framework for Environmental Management of NaCSA's projects, which considers the establishment of a Standing Committee, comprising representatives from NaCSA, and other stakeholders, which will focus in the development of support mechanisms to implement environmental and social management programs. The formation of District Environmental Committees is also proposed.

Other important findings of the EA included:

* The need for awareness raising campaigns * Identification of training needs and development of training program * Identification of environmental and monitoring indicators

The EA also includes an EMP and suggests the concerns that should be addressed by a Social Monitoring Plan.

In the light of the above, the following are recommended:

* That the proponent and its development partners consider the mitigation measures suggested for each impact during the implementation of the project. * That efforts be made to carry out the mitigation and monitoring plans for expected impacts provided in the annexes. * That NaCSA and partners work with existing local institutions for direct and transparent communication with the local population to improve their social welfare. * That the capacity of local communities be built in order to enhance their participation in environmental management and protection.

5 Report Organisation The report presents the final results of the Environmental Assessment (EA) carried out in accordance with the World Bank safeguard policies for reconstruction and development of community infrastructure under Sierra Leone's Proposed National Social Action Program.

The E.A. was carried out in two phases. Phase one dealt with desktop research on the areas of project influence and phase two site visits.

The elements of this report are contained under thirteen (13) sections. The introduction (section 1) gives the coverage of the E.A. and its purpose and requirement. A description of the proposed project (Proposed Sierra Leone National Social Action Program) is given in section 2.

The third section describes the Proposed Project's areas of influence. Here, the general overview of selected districts is presented with particular reference to their biophysical characteristics.

The fourth section describes the legal, regulatory and administrative framework as pertains to environmental protection and management, as well as the World Bank Safeguards and Policies relevant to the project.

Section five (5) presents the methodology adopted for the study whilst section six (6) summarises the sentiments expressed by the beneficiaries of the proposed project during consultations with them. Section six deals with consultations with affected people.

Section seven provides a description of the possible negative and positive environmental and social impacts of the proposed project on the sites and on the socio-cultural environment at large.

Section eight examines the negative environmental impacts of the technical programmes of the project

Section nine describes the institutional arrangement for the management of the project and environmental awareoess-raising campaigns amongst stakeholders.

Section ten deals with mitigating measures. In this section mitigating measures are proposed for the impacts described in section six and other impacts that were deemed to be created by the proposed project.

Section eleven discusses a proposed institutional framework for environmental management of the project.

Section twelve deals with Environmental and Social Monitoring indicators.

Section thirteen discusses the proposed Environmental and Social Monitoring Plans.

6 1.0 INTRODUCTION

Sierra Leone has an area of 72,315 km2 extending between latitudes 65°55' and 10°00'N and between longitudes 10014' and 13°17'W. Its bio geographical affinities are Guinea-Congolian with Afromontane elements on higher ground and a Guinea- Congolian/Sudanian Transition Zone in extreme north. As for vegetation, lowland forests, although much cleared, cover important regions in the south and east, while the rest of the country is a patchwork of secondary forests. Mangrove swamps used to extend over all of the coast but much has been cleared for rice cultivation. Freshwater swamp forests back the mangroves in the lowlands and there is an extensive lagoon system along the southern coast.

Its hydrographic profile includes a series of rivers which run from the Guinean Dorsal Hills: the Kolente or Great Scarcies, the Little Scarcies, Rokel, Jong, Sewa, Moa and Mano rivers. Other streams in the lowlands include the Ribi, Kukuli, Gbangbaia and Waanje rivers. Basic data on Sierra Leone is given in the annex.

Sierra Leone with a small open economy has suffered prolonged deterioration and accompanying low standards of living despite vast resource endowment (minerals, marine, human and arable land). After recording a marginal positive growth rate of aboutl.8% in 1984, the economy was near collapse by the end of the 1980s. Since then, the country has yet to register marked increased in the growth rates of output to improve the standard of living of the majority of its 4.7 million population.

War related activities have caused extensive damage to an already inadequate- economic and social infrastructure leading to a further deterioration in the living standards of a hard-pressed population. Gross Domestic Product per capita, estimated at US$237 in 1990, declined by about 40% during the subsequent decade, to about US$142 in 2000. The conflict compounded the adverse legacies from long periods of economic decline and mismanagement including deteriorated capacity and weak institutions. The dismal performance of the economy has had an adverse effect on human and social development.

Available global indicators show that the health situation in Sierra Leone is the worst in the world. Life expectancy is 38 years compared to 45 years for Sub-saharan Africa (IJNDP, 2000). The low life expectancy is due to infant and child mortality rates, about the.highest in the world. The maternity mortality is also extremely high.

The dismal health situation is also attributable to inadequate health and sanitation facilities. Over 415 health units, including 15 hospitals and 150 primary health centers, have been destroyed and remain non-functional in many towns and villages. Health workers have abandoned workstations in most rural communities and relocated to safe towns. The 2000 Baseline Service Delivery Survey (BSDS) reported that about 65%, 60% and 80% of the population are without access to safe drinking water, health services and sanitation, respectively. The MICS2 reported sewage and refuse disposal facilities be grossly inadequate, and contribute to the spread of water-borne diseases and malaria. Also, environmental management practices are very poor.

7 As the country is now moving towards restoration of socio-economic community infrastructure, public order also needs to be fully restored therefore the rehabilitation of community infrastructure including security posts a,nd court barriers is crucial to the restoration of law and order and the sustainability of democracy in Sierra Leone.

The Government of Sierra Leone has 'requested the World Bank's assistance to fund a National Social Action Program. The development objective of the NSAP is to assist the Government of Sierra Leone through the National Committee for Social Action (NaCSA) to support selected rural population groups in financing a full spectrum of community-based initiatives that are identified, proposed, agreed upon, put in place and maintained by them as a means of ensuring sustainable community reintegration and development, support transition from war to peace in tandem with improved living conditions and/or increased incomes. The proposed program would support Sierra Leone's transition from post-conflict reconstruction to sustainable poverty reduction. In addition, IDA funds would be used to address longer term development challenges in Sierra Leone

2.0 DESCRIPTION OF THE PROJECT

The program has four (4) main components: Shelter and Housing Rehabilitation Program in "Newly Accessible Areas":

This component would provide matching grants for imported building materials. The target beneficiaries of this facility would be mainly internally displaced population groups, returning refugees, and female headed households;

Community-Based Demand Driven Initiatives: This component would provide funds to support productive investments such as agricultural inputs (excluding pesticides), rehabilitation of markets, small-scale irrigation facilities, etc. as well as non-productive investments (e.g. rehabilitation of schools, rural health clinics/posts,, vocational skill centres, provision of water and sanitation, community markets, and support to functional literacy programs);

Community-Based Capacity Building: This component would support capacity building of local level institutions such as district authoiities, village development committees, chiefdom development committees and other community groups (such as parent teacher association). Target intervention would include the acquisition of basic knowledge and skills in project management, procurement and accounting, participatory local planning, and maintenance of community-based infrastructure; and

Project Management: This component would provide support to the National Commission for social action to effectively and efficiently carry out its functions, mandates and responsibilities (e.g. coordination, planning, monitoring, and supervising humanitarian aid; reintegration, resettlement refugees and displaced people). The project would support capacity building of NaCSA staff with a focus on community participation, outreach

8 techniques, financial management and skills development for M&E and beneficiary impact assessments.

2.1 Background Information on the National Commpission for Social Action

In 1996 then Ministry of National Rehabilitation, Reconstruction and Resettlement (MNRRR) was created with the mandate of restoring the war torn country back on the path of rehabilitation and development. After the coup of 25'h May 1997, the government was forced to flee to neighbouring Republic of Guinea. It was during the stay in Guinea that the idea of a Commission to fast track national development was born. After the restoration of the then elected government back to power in March 1998 by the West African Intervention Force (ECOMOG), the NCRRR was established. The goal of NCRRR was to provide quick support to build Sierra Leone. In November 2001, an Act of Parliament transformed the then NCRRR to NaCSA. NaCSA is a social fund that supports development initiatives. The Commission is meant to accelerate the rehabilitation of the war torn country by 'leap-frogging' the bureaucratic red-tapes of line ministries whose mechanism were dislocated and incapacitated during the war.

NaCSA is continuing the work of NCRRR with an expanded mandate acting mainly as a service provider in a timely manner on behalf of government by working closely with sectoral line ministries, international and national non-governmental organisations and donors to ensure that the institution is both effective and efficient in service delivery to war-affected communities in Sierra Leone.

During the ten-year civil war, government authority was dislocated in most parts of the country. The District Councils are responsible for administering development initiatives in the twelve- (12) districts of Sierra Leone, which were made impotent as a result of the conflict. In this regard, NaCSA has provided an adhoc good substitution for them as it has provincial officers in all the provinces; at Makeni for the North, Bo for the South, Kenema for the East and Freetown for the West. There are also District Community structures supported by Development Officers that work with the communities at chiefdom levels.

NaCSA is also responsible for coordinating the National Recovery Plan/Program and its committees under the Office of the Vice President of Sierra Leone.

2.1.1 Funding

The main sources of funding of NaCSA are: Grant Fund from UNDP, UNHCR and DFID and loan Fund from the World Bank (WB), African Development Bank (AFDB) and the Islamic Development Bank (IDB). Under the Grant Fund, the UNHCR provides support for capacity building for the resettlement of refugees and displaced persons while DFID provides technical assistance in the design of programs.

The loan fund was provided by the WB, in supports of the Emergency Recovery Support Fund (ERSF) the AfDB supports the Social Action Poverty Alleviation Program SAPA and the IDB community development initiatives.

9 2.1.2 Country Proiect Focus

With the authority of the government being restored to newly acquired areas (areas fully brought under government's control) in the East and North of the Country, NaCSA will be focusing its rehabilitation activities on these parts of the country. The Commission will do less in the Southern Province and in the Western Area of the country, as these areas suffered relatively less in terms of infrastructural destruction. Moreover NGOs and some NaCSA activities were concentrated previously in these areas by virtue of their long period of security during the war.

2.2 Review of NaCSA's Community Driven Initiatives in Sierra Leone

The National Commission for Reconstruction, Resettlement and Rehabilitation (NCRRR) has recently been transformed by government into a social fund named, 'The National Commission for Social Action' (NaCSA). Starting as NCRRR, the Commission has operated along with four related donor funded project implementation units, namely:

1. The Emergency Recovery Support Fund (ERSF), funded by the World Bank (WB), the African Development Bank (AfDB) and the Government of Sierra Leone (GoSL). 2. The Social Action and Poverty Alleviation (SAPA) Project funded by the AfDB and GoSL. 3. The Integrated Rural Development Project (IRDP) funded by the Islamic Development Bank (IDB) and GoSL 4. Support to Resettlement and Reintegration Project (SRRP) funded by UNDP and GoSL.

2.3 Achievements of the Commission

1. Relief and Humanitarian Assistance: The Commission, with resources from Government and donors, provided relief to over 500,000 displaced persons and communities in camps and newly resettled communities, to returning refugees and non-camp IDPs. Various gifts received from abroad have been distributed to IDPs, the w ar-wounded and amputees. The Commission remains indebted to the UN Agencie and NGOs for the delivery of relief and humanitarian assistance provided so far toward repatriation and resettlement of IDPs, returning refugees, former combatants and towards their reintegration.

2. The Support to Resettlement and Reintegration Project (SRRP); The programme is the former UNDP's Preventive Development Project, which ended in March 2001. Previous and current assistance have been very successful, concentrating resources on shelter rehabilitation, vocational training and trauma healing.

3. The SAPA Programme: This unit is the oldest within the Commission and dates back to 1992. It has provided assistance spread over various sectors including

10 agriculture, education, health, micro-credit, community development initiatives, skills training and employment creation. The SAPA Programme through its various delivery strategies and supervisory functions has been able to ensure that over 35,ooo poor people nation-wide have bepefited from micro-finance assistance. Over 80% of the beneficiaries are women.

4. The Integrated Rural Development Programme: The Integrated Rural Development Programme targets interventions in Agriculture, education, health and sanitation. This programme is another phase of the successful Emergency Assistance Programme funded by Islamic Development Bank.

5. The Emergency Recovery Support Fund: This Fund is the largest of the programme implementation units within the Commission and has provided funding for the implementation of over 250 projects covering the entire nation on community driven basis valued at over USD12 million by April this year. Sectors addressed include agriculture, education, WATSAN, community infrastructure, capacity building and information and sensitization.

For optimal performance at financial and fiscal management, the Commission, at its inception, contracted out its procurement and disbursement activities to an independent international accounting firm for efficiency, transparency and accountability.

As a social fund, NaCSA will from now on blend the above five (5) project implementation units into an integrated programme with three funding windows namely;

1. Community Demand Driven Programme: This is the largest of the three windows. It will fund community-based demand-driven sub-projects for the reconstruction, resettlement and rehabilitation in the education, health, agriculture, water and sanitation, environment and other key sectors of the economy.

2. Public Works Programme: This Window is based on the "AGETIP" model funded by the World Bank in several countries through a supply -driven approach. Currently the programme is being piloted to create ready jobs for youths and former combatants in urban and newly accessible areas of the country.

3. Micro-Fliiance Programme: The provision of micro-finance has been identified by the Government of Sierra Leone as a key strategy in its poverty alleviation efforts. The key institution for actualising this strategy, is SAPA.

With the creation of the above structure, NaCSA is able to effectively and efficiently manage grants and implement assistance programmes on behalf of donors with or without their presence in Sierra Leone.

2.4 Lessons Learnt

The current NaCSA support has helped to identify a number of positive features such as willingness of NaCSA to develop a transparent national program and to work with all sectors and partners. The project also demonstrates the increasing satisfactory

I I performance of NaCSA in decentralising its functions; namely, planning, financial management and procurement and its willingness to collaborate with NGOs.

Community driven initiatives constitute the bulk of,the development programs supported by NaCSA. They include sub-projects for reconstruction, rehabilitation and resettlement in the education, health, agriculture, water and sanitation, environment, housing, transport and other key sectors.

However experience in the past with these projects has shown that the local communities had not fully developed the capacity to handle monitoring and mitigation measures and as such, emphasis had to be on NGOs. Also, public appraisal mechanisms for the implementation of mitigation measures are not well developed. Experience has also shown that some of the environmental impacts of such projects are manageable and diminish over time. Major related project to be financed by the bank is given in the Annex.

2.5 Synergies Between Various Sub-projects

The project proposed by the National Commission for Social Action (NaCSA) can be seen as an overall development initiative aimed at fast-tracking rehabilitation, reconstruction and resettlement activities in Sierra Leone. Thus, this project encompasses sub-projects in the educational (rehabilitation of schools, vocational skill centres, functional literacy), health (rural health clinics/posts, provision of water and sanitation), community infrastructure (markets, etc).

Thus, NaCSA projects tends to be more "national" in character and sector specific in "ingredient".

Pros of NaCSA a) Operational wise; NaCSA has the capacity (financial and professional) to carry out these programs successfully. b) There are less "bureaucratic red tapes" compared to those of the government ministries to execute projects; hence, NaCSA's ability and capability to fast track rehabilitation projects. c) Efficiency in terms of financial transparency and probity is guaranteed.(as their funds are handled by an independent Finance and Procurement Unit (FMPU)). d) The secto-rehabilitated structures can always be handed back to the respective sectors. ' e) NaCSA is a fully decentralised body

Cons of NaCSA a) NaCSA is a Commission that will gradually phase out when government's permanent administrative structures are finally erected fully functional and decentralised (i.e. Ministries, Parastatals, Districts and Provincial Administrative Organs). b) NaCSA is seen as a threat by government structures in termns of "usurpation of their powers and mandates".

12 It is against the backdrop of these pros and cons that the following recommendations are formulated on how best to effectively harmonise and create synergies between various sector specific sub-projects.-

* That at present, NaCSA's role as a national fund be extended to cover government's institutions on the road to rehabilitation (i.e. government ministries be made to apply to NaCSA for instance for sectoral rehabilitation sub-projects) * That inter-sectoral panels involving NaCSA be set up to facilitate meaningful dialogue, to dispel suspicion and mistrust amongst development partners. * That regular consultative meetings be held between NaCSA, government ministries, donors/borrowers. * That the established National Environmental Protection Board acts as a standing environmental committee for NaCSA's projects.

2.6 Purpose And Requirement Of The Environmental Assessment (EA)

The purpose of the Environmental Assessment (EA) is to assess the potential environmental and social impacts of the proposed NSAP, particularly with regard to agricultural activities including small scale irrigation (excluding pesticide use), the rehabilitation of rural infrastructure (schools, rural health clinics/posts, vocational skill centres, provision of water and sanitation, community markets) and support to functional literacy programs.

The EA includes a full environmental, socio-economic and socio-cultural assessment of potential impacts of the above activities in the future and appropriate mitigation and monitoring plans. It is also intended to satisfy all requirements of the national and local authorities.

Appropriate consultation with stakeholders, potentially would-be affected groups, local communities, and non-governmental organisations (NGOs) has been undertaken during the preparation of the EA.

Objectives:

The objectives of the environmental analysis are to:

* Predict and assess any potential environmental and social impacts and benefits that could,remanate, from the financing of productive and non-productive investments, including capacity building activities under the proposed project; * Analyse alternative interventions an process tat may pose less environmental social damage than the one(s) proposed under the project; * Recommend practical and less costly but effective actions and processes to mitigate any potential adverse environmental and social impacts that could emanate during project implementation * Identify capacity building needs and recommend actions to strengthen NaCSA and its partners' capacity for ensuring sustained environmental and social compliance monitoring ; and * Prepare an environmental and social management plan.

13 3.0 DESCRIPTION OF THE AREA OF INFLUENCE

3.1 The Biophysical Characteristics

According to discussions with NaCSA, the project will focus mainly on areas of the Eastern and Northern provinces with less emphasis on the Southern province and even less focus on the Western Area. Generally, project activities will take place throughout the country. The exact location will depend on the type of activity identified by the various communities based on a participatory consultation process. The description of the biophysical characteristics therefore cover areas of project influence in the Eastern, Southern and Northern provinces. The description covers the following areas: -

Eastern Province 1. Kono District 2. Kailahun District Southern Province 3. Moyamba District Northern Province 4. Bombali District 5. Koinadugu District 6. Kambia District

3.1.1 Kono District

Kono District is located in the Eastern Province of Sierra Leone. The district is bordered on the north by Koinadugu district, on the east by the Republic of Guinea, the southeast by Kailahun and Kenema districts in the east and southeast and by Tonkolili and Moyamba districts in the west.

Relief

This area has a topography characterized by hills to the east and lowland covered with savannah grassland to the north. Inland valley swamps occupy a vast area of the district and are relatively fertile.

Climate

The climate of the area is typical of the eastern region of Sierra Leone. This area has a mean annual rainfall of over 250mm, 80% occurring between May and November. Mean monthly air temperature ranges between 20°C and 280C.

Drainage System There are various streams that flow throughout the district. Most of these streams experience heavy sediment load particularly from mining activities.

14 Vegetation and Soils In terms of biological diversity, the district is now covered in most parts by low grassland and most of the forest cover that has been lost was due to intense mining activities and the rebel war. Wildlife is poor, restricted to a limited species of birds and other wild animals e.g. monkeys.

Administration

Kono District comprises fourteen (14) chiefdoms. The headquarter town is Koindu which is also the administrative headquarter town.

Socio-Economic Activities

The population of Kono district (1985, census) was estimated to be around 7,000 with density of 69 persons per square kilometres. Presently, the population of the district has not been fully determined as it only now that government authority is gradually returning to the area.

Kono district is well known as the main economic activity there centres around mining of diamonds which is widely believed to be the dominant source of funding for the ten year old brutal civil war, the country experienced.

Agricultural activity is modest in the area, as the land for most part has been degraded by mining activities with little or no rehabilitation. Most of the soils are ferralitic shallow and of low fertility, except for the inland valley swamps which are relatively fertile. Presently, government control is returning to almost the entire district and there is little commercial or other related activities taking place in the district.

Educational and other Infrastructural Facilities

Being the scene of intense military activities throughout the ten years of civil conflict there is hardly any educational facility in the district, all schools were destroyed as well as hospitals and public services and infrastructure, water storage and delivery facilities have also been destroyed. Roads are, deplorable and sanitation is poor and infrastructural damage in the district was almost total.

3.1.2 MoyanTba District

Moyamba District is situated roughly between 7045' and 8025' North Latitude, and between 11045' and 130 West Longitude. It covers an estimated area of 86,902 square kilometres and has fourteen (14) chiefdoms.

Relief

The district has a varying topography with a general plateau surface, which has an elevation of 230ft to 300ft above sea level. Swamps are limited to a few hollows in the plateau as yet unaffected by the back cutting of the rejuvenated streams.

15 Hills are also found in the district, prominent amongst which is the Moyamba hill on which there is a forest reserve. It is also characterised by an extensive coastal plain. The up-standing hill masses diversify the coastal plain. One such mass is deeply cleft by through valleys into a series of sub-conical hills, the most elevated of which Yuvini reaches 1,439 feet.

Climate The mean annual rainfall of over 300mm, with about 85% in the months of May to November. Air temperatures-are in the range of 220C and 300C.

Drainage System There are various streams and rivers that incise the district, amongst which is the southward - flowing. Yambafui stream, which is constrained into passing around the eastern flank of the hills, where its waters mixing with those of the Gbangabia, a series of rapids are actively, cutting into skirts of the upland between Gondama and Bonjema.

Vegetation and Soils Under uniformly warm conditions, with abundant, though seasonal precipitation, the vegetation is characterised by high rain - forest and mangrove swamps along the coastal areas. There are also areas of derived grass on flatter areas. The soil is compared of infertile duricrust as a result of intense laterisation.

Socio-economic activities The main activities here are agriculture and mining. The traditional suites of crops are grown in this area, but in addition, ginger has been a local cash crop speciality.

Amongst the minerals mined commercially are bauxite and rutile. As a result of rutile mining, the traditional agricultural, forestry, hunting and fishing activities are giving way to mining and other associated activities.

3.1.3 Bombali District

This district lies 80 42 & 90 58 north, & between 110 48 & 120 26 west and shares its eastern boundary with Koinadugu District. It comprises 14 chiefdoms amongst which the Biriwa and Bombali-Sheboro chiefdoms are the largest having about 30% of the district's total population.

Relief

The district is also part of the interior hills and plateaux region of Sierra Leone with scarp zones separating the interior plateau and hills from the inland plains. Scarp erosion is eminent in this area as is evident in the granite residuals and inselberg concentration in the areas especially north of the headquarter town of Makeni. A typical example is the Gbenge hills consisting of a group of inselbergs. The geomorphology of the district also displays gently rolling plains, comprising, broad rounded interfluves with occasional isolated rocky hills, dissected by ill-defined, narrow valley swamps (FAO, 1979). There is the general presence of foot slopes and alluvium terraces. The inhabitants to provide basic foodstuffs cultivate the foot slopes and terraces.

16 Drainage

A few streams are present and are associated with narrow flood plains and terraces. The drainage comprise a trunk stream - Makpenta - which is a third order stream formed by the second order stream descending to Sendugu and Kagbouka hills. The flow is from a northeast to southwest direction revealing a denditic drainage pattern. In general the streams descending the watershed are swift, and punctuated by rapids in various places, stricted floors and potholes with steep - sided V-shaped valleys and gorges. Gullies and hills, which drain farm plots, are common features in the study area.

Geology

Most of the land is under pain by strongly folded igneous and metamorphic rocks belonging to various formations. Structurally known as the Kenema assemblage, which is part of the West African eraton. The igneous rocks of which biotile - granite is predominant vary in colour from light grey to brownish grey and from pink to dull salmon-red. The chief accessory minerals that make up these rocks include zireon, magnetite, epidote, apatite, rutile and pyrite.

Climate

Bombali district, like the rest of the country, experiences two seasons; dry and wet seasons. The dry season last from late November to early May and the wet season from late May to Mid-November. The Harmattan season (Mid-December to Mid - February) is sometimes severe in this region when compared with other regions in the country.

The wet season commences from April or May to Mid-November. The absence of meteorological data for this district is difficult to provide annual average air temperature or rainfall with the highest rainfall in July and August.

Soils and Vegetation

The soils in this area are formed from solid basement rocks of granite and gneisis under secondary bush and forest. Those on the hillslopes and footslopes are underlain by red gravel duricrust or mottled soils belonging to the group known as Oxosols. These soils are telatively infe4ile and support agriculture on a rotational bush fallow system.

The alluvial soils brought down the hills by fluvial and other weathering processes belong to the group known as Inceptisols and can support intense agricultural cultivation.

In terms of vegetation, there is little primary forest as most of the existing forest is secondary. Presently, deciduous woodland vegetation predominates. Savanna and herbaceous shrubs and grasses of the Andropogon spp. And Lacryma iobi are prevalent. The eroded hillslopes have to some extent been colonised by a mantle of aborescent sedge called catgria pilose.

17 The trees comprise mainly of the oil palm (Elaeis guineensis) Mango (Magnifera indica), Orange (citrus spp) and the Kola 'tree (cola nitida).

The swamps are dominated with herbaceous upright sedges such as scypus brizziformis.

Demography

The Bombali district has an average population density of 78 persons per square mile (Thomas 1983). According to the 1974 Census the total population of the district was 233,626

Socio- Economic Activity

The economic activities in the area include agriculture, animal husbandry, palm wine tapping, hunting and crafts. The prevalent farming system here is the rotational bush fallow system. Commercial activities are low in the district and there are no mining activities.

3.1.4 Koinadugu District

This district lies between latitude 9020' and 9042'N and longitude 11°16' and 11044'W. It comprises the chiefdoms of Wara-Wara Yagala and Sengbe and the total area involved is approximately 587 sq. miles; 120 and 467 sq. miles for Wara-Wara and Sengbe respectively.

Relief

The district is part of the interior hills and plateaux regions of Sierra Leone, which forms a broken plateau lying at an elevation ranging between 1000 - 2000' above sea level. A characteristic feature of the district is its numerous steeply sloping hills and narrow valleys covering the area. Prominent geomorphologic features the Wara-Wara Mountains and hills rising to about 3000 ft. above sea level. This rugged terrain is the precursor for the relative under development of the district especially with increasing distance from headquarter town of Kabala.

Climate

Mean annual rainfall values range between 70" and 90" of which 85-90% of the precipitation takes place between the months of May and November.

Mean monthly temperatures have a seasonal rhythm with minimum in July - August ranging, 25.6-28.9°C and 31.1-34.4°C for March - April. Minimum mean temperature is lowest in January and December of being 15.6 C or less.

Soils

The soils are lateritic or reddish brown soils derived from the basement complex of granite and gneisses.

18 Vegetation

The predominant vegetation in the area is open bush and grassland. Small patches of forest are also found scattered over the area together wit&. inland fresh water swamps. The latter are found mostly at the bottom of valleys along the courses of streams rising from the mountains

Population

In general the population is made up of a number of ethnic groups but numerically the Korankos and Limbas are the most important. Also found in significant numbers are the Madingoes and Fullahs. The latter are the main cattle rear and they derive their main source of income from the sale of cattle. The other groups are largely agriculturists. The population is largely rural. Over 85% of the population are estimated to be directly dependent on the land for that livelihood. The density of the population ranges from as low as 24.9 persons per square mile in Sengbe to as high as 144.2 in Wara-Wara. Also found in significant numbers are the Madingoes and Fullahs. The latter's income comes from the sale of cattle. The Madingoes are largely agriculturists.

Socio- Economic activity

The socio-economic activities in the area is similar to that of the Bombali District include agriculture, animal husbandry, palm wine tapping, hunting and crafts. The prevalent farming system here is the rotational bush fallow system. Commercial activities are low in the district and there are no mining activities.

Land Tenure

The indigenous system of land tenure and that, which still obtains in the district, is one of ursfructuary rights. Land belongs to the local community as a whole and every individual is considered to have a right to a piece of land for his use. The paramount chief is the custodian of the land and he is responsible for the primary allocation of land.

Farming Practices

The predominant farming practice here is one of subsistence shifting cultivation or progressive extension of cultiyation into new land with regular periods of cropping and resting.

The main crop grown is upland rice, which continue to be the primary charges of all the farm families of the district. However, the fertility status of the upland farming alone has not been able to provide subsistence to the farm family. As a result, swamplands in the valleys of the area have now received the attention of the farmers. Before the war started in 1991, the rotation of fields was speeded up, particularly in the Wara-Wara chiefdom because of the increase in population, but one year's rice followed by about 6-10 years bush fallow still fairly common: the more usual period is estimated as being 7-8 years. However, the system of arable upland farming depends on the maintenance of soil fertility.

19 3.1.5 Kailahun District Kailahun district is located in the eastern province of Sierra Leone. The Republic of Guinea borders the District on the north and on the southeast by the Republic of Liberia along the Mano river, it has a land of 1,490 Sq. miles.

Relief

The topography of the area is undulating, ranging from low-lying inland plains to more disserted upland areas with elevation between 600-700 meters altitude.

Climate

Most of the area has a mean annual rainfall of over 2,500 mm, with 80% of this mean falling during the period of June to November, mean annual temperatures vary between 25oC and 28oC with higher values occurring in March/April when solar radiation is most intense.

Vegetation and Soils

In terms of vegetation, the district is covered with dense farm bush dominated by fast growing, fire resistant species that thrive under the bush fallow system.

The district also has over 5,000 acres of forest reserves and protected forest areas (Gola rainforest). High trees traditionally surround many of the villages and are used as shade for cocoa and coffee. However, most of these forest reserves had been tampered by the war.

Administration

The administrative headquarter is in Kailahun town and the provincial headquarter office is located in Kenema Town, Kailhun is about 270 miles from Freetown. Administrative, Kailahun is divided into fourteen (14) chiefdoms

Socio-economic activities

Kailahun district had a population of about 200,000 with about 60% of this number living in the headquarter town of Kailhun. The district was predominantly inhabited by the mendes 'Although traditionally a Kissi dominated area. The minority tribes include the Krim, Vai and Gola inhabiting areas along the border with Liberia.

The major social-economic activities in the area are agriculture, mining and hunting, major cash crops like coffee , cacao used to fetch a sizeable proportion of Sierra Leone's foreign exchange earnings.

Presently, as a result of the rebel war, mass migration of the people to neighbouring countries of Guinea and Liberia had taken place as well as to other parts of the country (internally displaced). Currently, the district is gradually coming under the control of the government of Sierra Leone.

20 Population

Estimates of the population size at ptesents may between 10-20 thousand (not wholly reliable figures).

Community Infrastructural Facilities

Kailahun district and Kailahun town in particular used to have several primary and secondary schools, hospitals; medical centers, churches, mosques etc.

However, all these facilities have been destroyed during the ten years of civil war as reports from various organisations (both Governmental and Non - Governmental) suggests.

3.1.6 Kambia District

Kambia district is located in the, northern province of Sierra Leone. It is bordered on the north and northeast by the Republic of Guinea, Bombali and Port Loko districts, on the south and on the west by the Republic of Guinea and Atlantic Ocean. It covers a land area of about 1,100 sq. miles.

Relief

The topography of the district is mainly dominated by low-lying plains with heights between 50 and 250 feet.

Drainage System

The drainage system of the great and little scarcies rivers lie within the district.

Climate

The Kambia district has a mean annual rainfall of over 3000mm. The bulk of the rain falls during the rainy season as in most parts of the country. Mean annual temperatures lie between 25oC and 2OoC.

Vegetation and Soils

The district is covered mainly by low shrubs and grassland. In the proximity of the scarcies, mangrove swamps dominate but have been severely degraded to make way for rice cultivation.

Administration

The administrative headquarter is Kambia town. The provincial headquarters office of the Kambia district is located on Makeni, Kambia district is divided into seven (7) chiefdoms.

21 Socio-economic Activities

Kambia district is dominated by such activities as agriculture, fishing and hunting. Petty trading (commerce) is also an important economicactivity as the district lies on the border with the Republic of Guinea. The district is a major producer of swamp rice. Upland rice production is also important in the area.

This district was first attacked by the RUF and AFRC forces in 1995 and was subsequently occupied by-these forces in 1999. This resulted in widespread displacement of the civilian population, some of which fled to neighbouring Republic of Guinea. The district was under the RUF until May 2001 when a formal agreement was reached paving the way for RUF's withdrawal from the district.

Presently the district is gradually coming under government control with the return of a sizeable number of internally as well as externally displaced person. Commercially activity has resumed and the government is in the process of restoring essential services in the area.

Community Infrastructural Facilities With regards to educational facilities, school structures appear to be intact in the chiefdoms. In Kambia town itself, all schools were burnt down. Those remaining their structures need to be renovated as they have either cracked walls or damaged roofs. Other infrastructural facilities e.g. health, water and sanitation also need to be restored and rehabilitated.

3.2 The Social Structure Of The Project Area The Social structures of the districts are similar, except for the Western Area. In the districts, there are chiefdoms each of which are ruled locally by chiefs representing the various tribes in the chiefdom. The Paramount Chief is the overall local head of the chiefdom. The chiefdom councils are made up of Tribal Authorities (Chiefdom Councillors), which are set up to administer the chiefdoms, and to advice the paramount chief, who in turn, coordinates with the district councils. Headmen head the village while the Village Area Committees administer the villages. The smallest unit in the village is the household.

This social structure is important to take into account for the development of environmental.rnanagement strategies.

4.0 DESCRIPTION OF THE LEGAL, REGULATORY AND ADMINISTRATIVE FRAMEWORKS

4.1 Organisational Structure for Environmental Management at the National Level

There is an overall institutional and legal framework for the management and protection of our environment in the national context. The responsibility for the management and protection of the environment presently lies with the Department of the Environment of the Ministry of Lands, Country Planning Forestry and the

22 Environment (MLCPFE). The political head of the Department of the Environment at present is the Minister of Lands, Country Planning, Forestry and the Environment (MLCPFE).

The administrative head is the Permanent Secretary who is responsible for co- ordinating the functions of the departments within the Ministry viz. department of Land and Country Planning (DLCP), Department of Surveys and Lands (DSL) Department of Forestry (DOF) and the Department of the Environment, (DOE). He is also the Principal Adviser to the Minister and the Vote Controller of the Ministry's budget.

The Department of the Environment (DOE) has developed with World Bank Support, the National Environmental Action Plan (NEAP). It is presented into two volumes. Volume I analyses the environmental issues in Sierra Leone and the recommended interventions. Volume 2 contains the investment proposals. A National Environmental Policy (NEP) has been prepared. The goals, objectives and strategies of the (NEP) are outlined below:

Policy Goals:

The goal of the National Environmental Policy is to achieve sustainable development in Sierra Leone through sound environmental management.

Objectives:

* To secure for all Sierra Leoneans a quality of environment adequate for their health and well-being; * To conserve and use the environment and natural resources for benefit of present and future generations; * To restore, maintain and enhance the ecosystems and ecological processes essential for the functioning of the biosphere; to preserve biological diversity and the principle of optimum sustainable yield in the use of living natural resources and ecosystems; * To raise public awareness and promote understanding of the essential linkages between environment development and to encourage individual and community participation in environmental improvement efforts.

Strategies:

The strategies will be pursued in order to achieve the policy goals and objectives:

(a) To establish and/or strengthen environmental protection standards, monitor changes in, and publish relevant data on, environmental quality and resource use; (b) To make prior environmental impact assessment (EIA) of proposed activities which may significantly affect the environment or use of a natural resource and to provide relevant information, in a timely manner, to persons likely to be significantly affected by a planned activity and to grant them equal access and due process in administrative and judicial proceedings;

23 (c) To promote environmental management through the creation of administrative and infrastructural support with appropriate financial backing; (d) To co-operate in good faith with other countries and agencies to achieve optimal use of transboundry natural resource.rand effective prevention or abatement of transboundry environmental protection.

The legal basis for the implementation of the NEAP and for Environmental Management and Protection in Sierra Leone is the Environmental Protection Act, 2000.

The Environmental Protection Act (EPA) 2000 empowers the Environmental Protection Department to perform the following tasks amongst others:

* Screen projects for Environmental Impact Assessment (EIA)

* Issuance of Environmental Impact Assessment Licences

* Formulate or promote the formulation of, and monitor the implementation of environmental policies, programmes, projects, standards and regulations.

The EPA 2000 also provides for the establishment of an Environmental Protection Board with the following functions:

(a) Facilitating coordination, cooperation and collaboration among government ministries, local authorities and other agencies in areas of environmental protection; (b) review national and sectoral policies and make such recommendations or proposal it make think necessary to the Minister (c) review environmental impact assessments prepared pursuant to this Act and make appropriate recommendations to the Director (d) investigate or cause to be investigated, any activity, occurrence or transaction which it considers is likely to have or result in harmful consequences to the environment and advise on measures necessary to prevent or minimise such consequences; (e) advise the Minister on areas of environmental protection and control requiring special or additional measures indicating the priorities and specific goals to be achieved; .,, I (f) undertake or cause to be. undertaken specific studies and research aimed at developing strategies for the protection of the environment and make appropriate recommendations to the Minister; and (g) Consider any other matters which may be referred to it by the Minister and make appropriate recommendations or proposal thereon.

A number of government ministries also involve in environmental and management and protection activity by virtue of their responsibilities.

The activities of these ministries are regulated by their various acts and determined generally by their policies.

24 At present, the following Ministries are in one way or another associated with management issues pertaining to the environment of Sierra Leone.

* Ministry of Lands, Country Planning, Forestry and the Environment * Ministry of Transport, Communications * Ministry of Mineral Resources * Ministry of Agriculture and Food Security * Ministry of Marine Resources * Ministry of Tourism and Culture * Ministry of Works and Technical Maintenance * Ministry of Energy and Power * Ministry of Education, Science and Technology

At times, jurisdictional rights of these Ministries overlap. Thus, attempts should be made to harmonise laws to simplify enforcement.

Ministry of Lands, Country Planning, Forestry and the Environment

At present, the Ministry of Lands, Country Planning, Forestry and the Environment is charged with the responsibility of conserving and managing Sierra Leone's natural environment. It is also responsible for addressing land acquisition and transfer, land ownership and use, national development in a planning capacity and to provide advisory services to the public on land matters also responsible for physical planning and management of the forestry resources.

Ministry of Transport and Communication

This Ministry is mandated to deal with issues related to transport on land, air and sea as well as local and international communications.

Ministry of Mineral Resources (MMR)

This Ministry is charged with the responsibility to supervise mining operations in the country. It issues licences for all mining operations, enforces laws and provisions contained in the Mining Act and its amendments. It is responsible for enforcing provisions in the new mining act relating to the rehabilitation of mined out areas. The main institutional conflicts are; (I) the extent to which the Ministry has jurisdiction over marine areAs with respeQ to marine based mineral resources, offshore dredging and its impact on marine resources and (2) the overlap of water quality monitoring with the interest of the Ministry of Marine Resources.

Ministry of Agriculture and Food Security

This Ministry is mandated to develop agriculture and provide food security.

Ministry of Marine Resources

This Ministry is responsible for the exploitation and management of our marine resources.

25 Ministry of Tourism and Culture

The responsibility to promote and develop the country's tourist industry lies with this Ministry. It is also charged with the duty of protecting the country's heritage: monuments, cultural and historical sites.

Ministry of Works and Technical Maintenance

The duty of road construction and maintenance as well as public buildings lies with this Ministry. It enhances the improvement of road networks by securing bilateral and multi-lateral agreements with donors for funding.

Ministry of Energy and Power

The development of the energy sector and water supply are functions of the Ministry. It is expected to develop the energy resources and enhance current production to meet the needs of the community as well as provide adequate facilities and maintenance of existing ones.

Ministry of Education, Science and Technology

This Ministry is responsible for educational activities and the development of Science and Technology countrywide.

The activities of these ministries are regulated by their various acts and determined generally by their policies.

Non-Governmental Organisations (NGOs)

There are only a few non-governmental organisations (NGOs) in Sierra Leone with interests in environmental and resource management. Some of these are interested in the natural conservation and monitoring of the country's wildlife and natural habitats.

4.2 Organisational Structure for Environment Management at the Local Level

At the local level, the environmental functions are carried out by provincial officers of the DOE of the MLCPFE through its Assistant Environmental Officers in the Northern, Southern, Eastern Provinces, and an officer for the Western Area. It is envisaged that these officers will be part of the area town planning committees set within Town Councils.

At present the main tasks of the Assistant Environmental Officers operating at provincial levels basically include monitoring of environmental programmes and projects, evaluation of environmental degradation and compilation of reports. At present Town Councils, including the Freetown City Council (FCC) with statutory powers as a Local Authority (LA) does not participate in any arrangement affecting environmental management in accordance with the National Environmental

26 Protection Act, 2000. However, as the Act is implemented these Councils will start playing pivotal roles. The City and Town councils however have environmental units /committees which focus mainly onrhealth and sanitation issues.

4.3 International Conventions

Sierra Leone is a signatory to a number of international conventions, treaties and protocols. These conventions have 'components that border on pollution assessment and monitoring procedures and guidelines.

The Department of Environment itself is the focal point for the Global Environment Facility (GEF). The international protocols, treaties or conventions that have been ratified are given in the annex.

4.4 The World Bank Social Safeguards and Policies

Operational Policies and Directives

The World Bank safeguards policies (WBSPs) cover ten (10) areas: Environmental Assessment, Natural Habitats, Forestry, Safety of Dams, Pest Management, Disputed Areas, International Waterways, Indigenous Peoples, Involuntary Resettlement and Cultural Property.

OP 4.01 Environment Assessment

Operational Policy (OP) 4.01 requires an Environmental Assessment be prepared by applicants applying for World Bank financing to ensure that projects are environmentally and socially sound and sustainable. World Bank categorises potentially funded projects as A, B, C, or F. The NaCSA project is considered as Category B. Category B projects are those classified as likely to have some adverse effects on the environment, but that can be mitigated. An Environment Assessment is needed for such projects to examine potential negative and positive environmental and social impacts and recommend any measures needed to prevent, minimise, mitigate or compensate for adverse impacts and improve environmental and social performance.

Similar to the requirements of the Environmental Protection Act 2000, World Bank environmental assessments require the following information to address public and regulatory concerns regarding the project:

* Executive Summary; * Policy, legal, and administrative framework; * Project description; * Baseline data; * Environmental impacts; * Analysis of alternatives; and * Environmental Action Plan

27 The NaCSA EA Project, which includes the Executive Summary, EA and MP, has been developed to meet the above requirements and those of the Environmental Protection Act, 2000.

OP 4.04 Natural Habitats

OP 4.04 Natural Habitats establishes a guideline to promote and support projects that involve significant conversion or degradation of critical natural habitats. However, they do have the discretion to allow impacts to natural habitats if "there are no feasible alternatives for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project sustainability outweigh the environment costs". This EA has been prepared with due consideration of the Natural Habitats policy.

OP 4.10 Indigenous Peoples

Operational Directive (OD) 4.10 describes the policies and processing procedures for projects that affect indigenous peoples. The objective of this policy is to ensure that indigenous people benefit from development projects and avoid or mitigate potentially adverse effects on indigenous people caused by World Bank activities. In many cases, proper protection of the rights of indigenous people will require the implementation of special project components that may lie outside the primary project's objectives.

In this directive, the World Bank states, "When the bulk of the direct project beneficiaries are indigenous people, the Bank's concerns would be addressed by the project itself and the provisions of this OD would thus apply to the project in its entirety". There are no groups in the project area that are separated or disadvantaged due to ethnicity. The local residents in the project vicinity are addressed by the project itself in this EA.

OP 4.12 Involuntary Resettlement

OP 4.12 seeks to avoid displacing persons where feasible or minimising displacement by exploring all viable alternative designs. The World Bank requires that when resettlement is unavoidable, a Resettlement Action Plan (RAP) be developed to ensure that displaced persons are provided with sufficient resources. These resources include compensation for losses at full replacement cost prior to the actual move, support throughl the transitionperiod in the resettlement, and assistance in improving their former living standards, income earning capacity and production levels.

The World Bank requires the encouragement of community participation when planning and implementing resettlement. In addition, displaced persons should be integrated socially and economically into host communities so that adverse impacts on host communities are minimised. A Resettlement Policy Framework as an initial attempt to address this policy.

28 OP 4.36 Forestry

OP 4.36 policy aims to reduce deforestation, enhance the environmental contribution of forested areas, promote reforestation, reduce povei3y and encourage economic development. While there are limited forest resources beyond secondary re-growth in the project area, this EA has been developed with due consideration of this policy.

OP 4.37 Safety of Dams

OP 4.37 policy establishes requirements for new and existing dams. The owner takes full responsibility for the safety of the dams, dam safety measures, construction, operation and maintenance of the dam and associated works. For large dams over 15 meters in height or dams between 10 to 15 meters that present special design complexities, a review of the dam design and construction is required by independent experts along with the preparation of detailed plans, pre-qualification of bidders during procurement, and periodic safety inspections. For small dams, which is normally less than 15 meters generic dam safety measures designed by a qualified engineer are usually adequate.

OP 4.09 Pest Management OP 4.09 policy is designed to ensure the effective management of pests that affect either agriculture or public health through the promotion of strategies that makes use of biological and environmental control methods to reduce reliance on synthetic chemical pesticides. Where environmental methods alone are not effective, the Bank may finance the use of pesticides for control of disease vectors and when their use is justified under an IPM approach. With respect to the classification of pesticides and their specific formulations, the Bank refers to the World Health Organization's recommended guidelines that ensures negligible adverse human health effects, minimal effect on non-target species and the natural environment, whilst being effective against the target species and prevent the development of resistance in pests.

The Bank requires that the capacity of the country's regulatory framework and institutions to promote and support safe, effective and environmentally sound pest management is stalwart. In this directive, the policy states that "any pesticide the Bank finances must be manufactured, packaged, labelled, handled, stored, disposed of, and applied according to standards acceptable to the Bank. The Bank will not finance formulated products that fall in WHO classes IA and IB, or formulations of products in Clad 11, if (a) thecountry lacks restrictions on their distribution and use; or (b) they are likely to be used by, or be accessible to, lay personnel, farmers, or others without training, equipment, and facilities to handle, store, and apply these products properly."

OPN 11.03 Cultural Property

OPN 11.03 policy was developed for the protection of artifacts left by human inhabitants such as middens, shrines, battlegrounds, and unique environmental features. The World Bank generally assists in the preservation of these cultural properties and normally declines projects that will significantly damage non- replicable properties. The management of cultural property is the responsibility of the

29 government. The World Bank staff is required to determine what is known about the cultural property aspects of the project site. It there are any questions concerning cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist. The government, appropriate agencies, NGOs or university department should be consulted if questions arise about cultural property.

4.5 Synergy Between World Bank Safeguards and Policies and the Current EA Study

With regards to the current study, the relevant area of the WBSPs is the Environmental Assessment (OP 4.01). Under Annex B of the above document, which lists the content of an Environmental Assessment Report for a category A project, provision is also made for an Environmental Action Plan (EAP)Details of this EAP (annex C ) provides for mitigation and monitoring. The Environment Protection Act (EPA) 2000 also provides guidelines for carrying out Environmental Assessment (EA) which contain elements similar to those of the contents of the present EA and is therefore in accordance with the World Bank EA guidelines.

The National Environmental Action Plan (NEAP) also covers activities related to mitigation measures, monitoring and Institutional strengthening. The mitigation and monitoring plans for this current EA study is provided in the annexes.

The World Bank's safeguard Policies (WBSPs) particularly those on Environmental Assessment (OP 4.0) and Involuntary Resettlement (OP 4.12) provide for an activation of a Resettlement Action Plan (RAP) where a project would necessitate the displacement and subsequent relocation of people. However, the social structure of chiefdoms as described earlier, does not allow for the forceful removal of people, as land given for the proposed NaCSA project was done according to established procedures of community consultation, particularly with the Paramount Chiefs and other beneficiaries. Therefore, the beneficiaries of this project would be included in all stages of the planning and implementation process in order to ensure "ownership" and sustainability in the long term in accordance with the World Bank Group Policy. The proposed project apart from possible new construction mainly involves rehabilitation of community infrastructure. Therefore remediation of existing environmental problems may be more important than mitigation and monitoring of expected impacts. Thus the management plan focuses on cost effective measures to remedy and mainage these problems in the case of rehabilitation and upgrading.

The present project does not foresee relocation as an issue and thus the question of resettlement does not arise. However in any case, a resettlement policy framework has been prepared as a precaution for projects that might require relocation.

30 5.0 METHODOLOGY AND TECHNIQUES USED IN ASSESSING AND ANALYZING THE IMPACTS

Sampling

According to project documents, two stages were involved based on the following clusters: -

Stage 1 - Districts

The first stage of stratification - several districts under the project influence was purposefully and very specifically pre-selected by NaSCA and agreed upon with the World Bank.

These are: * Moyamba district * Kono District * Kailahun District * Bombali District * Koinadugu District * Kambia District

The districts of the Eastern Province (Kono, Kailahun) according to various reports, were the most affected in terms of damage to infrastructure and the environment. Kambia, in the North, also suffered significantly, as well as Moyamba in the South. Bombali and Koinadugu in the North were also damaged but to a lesser extent..

Stage 2 - Chiefdoms

This stage involved the villages/settlements (three in each of the above districts) in areas of project influence.

Both primary and secondary data were collected.

The secondary data was collected from various Governmental and Non-Governmental agencies and other organisations. The primary data collection was undertaken primarily to provide field data to enable the consultantsito fulfil ihe objective of the project. Secondly, it was used to cross check some of the information gathered from secondary sources.

The information collected was used to assess the potential environmental and social impacts of the components of rehabilitation activities.

Environmental Analysis

The environmental analysis covered the issues as provided in the Draft-Terms of Reference (DTOF).

31 Data collection

Both primary and secondary'data were collected.

Primary data

Site visits

Visits to a sample of sites were conducted. Structured questionnaires were administered. The information was related to the following issues:- Another purpose of the visits was to assess the suitability of the land in terms of topography for infrastructure (building) construction, proximity to forest reserves, protected wildlife as well as to monuments and sites of cultural and historic significance. The visits were also made to ascertain whether or not the sites were occupied by squatters or whether the previous landuse patterns have changed.

* Assessment of potential environmental and social impacts of rehabilitation activities in the rural areas, including the potential impacts due to the establishment of community infrastructure. * Assessment of the environmental and social impacts of increased provisions of water supply and sanitation facilities. * Assessment of the need for liquid and solid waste collection, disposal and management. * Assessment of potential environmental and social impacts of agricultural inputs * Assessment of the existing capacity to implement and manage plans under the proposed project.

Interviews:

Interviews at various levels were conducted with the help of the structured questionnaires. The information sought were related to the following issues:

* Assessment of potential and actual environmental impacts of shelter and Housing Rehabilitation Program in "Newly Accessible Areas". * Assessment of the pptential and actual social impacts of Community Demand Driven Initiatives (agriculture, rehabilitation of markets, small-scale irrigation facilities, rehabilitation orfschools, rural health clinics/posts; vocational skill centres, provision of water and sanitation) and support to functional literacy programs. * Assessment of the existing capacity of NaCSA to implement a resettlement plan under the proposed project. * Identification of alternatives that may pose less environmental and social damage that the one(s) proposed under the project * Identification of capacity building needs in order to recommend actions to strengthen NaCSA and its partners for sustained environmental and social compliance monitoring. * Preparation of appropriate environmental and social management plans.

32 Secondary Data

Desktop research and visits

Information on previous related assessments was collected from various sources/institutions to complement the present assessment.

The information sought were related to the following:-

* Biophysical characteristics of the environment in the rural area covered by the project * Review of the social legislation with regard to resettlement * Review the national environmental policies, legislation, regulatory and administrative frameworks in conjunction with the WB's safeguard policies. * Review of community driven initiatives in Sierra Leone(donor and government funded) * Review of the authority and capability of institutions at local or provincial / regional and national levels to implement, manage and monitor plans in the environmental and social assessments.

6.0 CONSULTATIONS

The steps undertaken for an environmental assessment of the proposed project are in accordance with those proposed in the Terms of Reference (TOR) for Environmental Assessment in Schedule 2 of the Environment Protection Act 2000 as well as in the Terms of Reference (TOR) for the present Environmental Assessment (EA). In preparing the Environmental Management Plan consultations with stakeholders was an important activity. The team visited the following districts: Moyamba, Bombali and Kenema. The principal aim of the visit was to assess the possible potential negative impacts of the

Project in these districts. The team held meetings with the Paramount Chiefs and cross sections of the various communities. The team also visited the proposed sites for the project.

The purpose of the meetings were:

1. To acquaint the people with details of the project 2. To educate them about environmental concerns of the project 3. To seek information on potential negative environmental and social impacts of the projects on the communities 4. To assess the environmental challenges facing the various communities. 5. To assess the possible occurrence and resurgence of pests and diseases in the agricultural activities under the project. 6. To assess the capacity at the local and regional levels to implement environmental mitigation and management plans. 7. To seek information on the possibility of involuntary displacement of people due to the project, with a view to preparing a Resettlement Policy Framework (RPF).

33 6.1 Consultations With Affected People

The following groups were consulted: community- leaders and government authorities, population centres (villages, towns), special interest groups (NGOs, CBOs, ADAs), etc. The mechanisms of consultation included: public meetings, personal discussions, and administration of questionnaires.

The NaCSA regional officers facilitated consultations with communities in their various regions. Minutes of the consultative workshops/meetings are annexed.

6.1.1 Perceptions Of The People About The Environmental Problems That Are Associated With The Proiect.

Community Infrastructure which include health facilities, schools, water supply systems, roads, market places, security posts, court barries and other administrative structures have been in Moyamba, Kono, Koinadugu Kambia and Bombali Districts since the period after independence. The sites where these facilities were located were initially acquired by various Ministries of government. However destruction of these facilities were widespread during the ten-year civil war. During the meetings with various communities in the districts visited the people expressed the desire to see an early start to the project. They stressed the importance of community infrastructure and agricultural development as major ingredients for the improvement of their livelihoods. Analysis of responses shows that the people were enthusiastic about the project and were anxious for it to start. The people met, expressed their determination to see their environment improve in terms of the restoration of water and sanitation facilities.

On the issue of possible occurrence or resurgence of pests and diseases due to inputs into agriculture, the people were of the view that any such occurrence or resurgence can be handled as they have some experience in dealing with such issues. In any case, the desire for food production appears to be the overriding issue according to many of those interviewed.

Analysis of responses to the administered questionnaires showed that an appreciable number of those intervietved in the various districts expressed the desire to see the strengthening of their local capacities to handle environment mitigation plans and activities.

The perception on environmental impacts of the project amongst those interviewed varied slightly. The majority view seems to be that the project poses little or no threat to the environment. There were those who agreed that some degree of environmental degradation is associated with the project. However, they were of the view that these impacts are manageable as no new land will be acquired.

On the issue of environmental management it is the view of the people, that such mitigation activities as tree planting be community based.

34 They expressed the desire to see socio-economic development go hand in hand with environmental management.

6.2.1 Consultations With NaCSA Officials

The consultants also held discussions with key NaCSA officials both at the National and Regional levels in order to obtain information pertaining to project sites, management structure, implementation, monitoring and evaluation and training needs.

The discussions revealed that the projects were to be community driven and therefore project sites have been chosen in such a way, as to avoid any involuntary displacement of people, social resource and land use conflicts and to ensure compliance with traditional and cultural criteria and regulations. NaCSA being a commission has a well-established management structure, which oversees the implementation of these projects with adequate mechanisms for monitoring and evaluation.

7.0 ANALYSIS OF POTENTIAL NEGATIVE AND POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS OF THE PROJECT

A number of districts and sample sites selected for the rehabilitation of community infrastructures were visited. to assess the potential negative environmental impacts of the project on human health, land resources, water and air quality, protected wildlife and forest reserves, monuments and sites of cultural and historic significance.

Below is a discussion on the potential negative environmental impacts of the project.

7.1 Impacts Of Shelter And Housing Rehabilitation Program In "Newlv Accessible Areas".

This component would provide marching grants for imported building materials to be used for individual shelter construction and rehabilitation by mainly internally displaced groups, returning, refugees and female headed households. This project will mainly cover areas in which NaCSA has not intervened including areas in the north of Sierra Leone, which have been brought under control of the GOSL followirqg the May 14, 2002 General Elections and parts of the east and south of the country and "pockets" tn the Western Area.

The shelter and housing rehabilitation activities will be confined to villages and towns that were destroyed during the ten- (10) years of civil war. It is envisaged that road networks will also be rehabilitated for the resumption of transportation to those areas and communities that will be rehabilitated.

Landuse requirements for this project will include land that was formerly available to the original sites where the communities/villages where located and probably "new areas" for vulnerable groups (amputees, disabled, etc) as envisaged by the project.

35 The EA has identified a number of negative and positive environmental impacts of this component of the project on human health and the biophysical environment in the different districts.

7.1.1 Impacts on Human Health and Human Made Environment

Rehabilitation of shelter poses some threats to human health and safety as a result of it's potential negative environmental impacts on land, air and water resources. These threats are associated with disposal of construction waste, litter and pools of water in burrow pits. If not properly and quickly disposed of, construction wastes and litter can attract flies, cockroaches etc. which may carry and eventually transmit diseases. Burrow pits can serve as receptacle for water and litter and provide breeding grounds for mosquitoes and other disease vectors and can cause injuries to people. The impact on public health (e.g. respiratory, ailments, water contamination, noise pollution) is expected to be minimal, temporary and localised..

The social impacts on the development of nearby communities are mainly related to cultural and socio-economic activities. The returnees and internally displaced are expected to restore family units, restore cultural ties and fabrics, and will not generate conflicts (e.g. compulsory acquisition of property and or displacement of nearby communities). The site visits revealed that the communities to be rehabilitated are being rehabilitated with their social administrative structures.

7.1.2 Impact On Land

Shelter rehabilitation like rehabilitation of other community structures can generate wastes and create burrow pits that can impair the aesthetic quality of the land if not quickly cleared or burrow pits are not covered. Shelter rehabilitation/construction is also likely to be accompanied by land clearing (where rehabilitation/construction takes place on vegetated land), loss of biodiversity, pollution, loss of agricultural land and topographic modification.

Community infrastructure rehabilitation will be done on sites previously occupied in both the previously and newly accessible areas. The type of land to be affected by the project has been carefully selected in conformity with the national and district development plans and does not belong to the category of land considered unsuitable for community, infrastructure development. The project is expected to have minimal impact on deforestation, loss of biodiversity and agricultural land topography as well as on pollution of the land.

Deforestation:

This is one of the most common environmental problems associated with building and construction. Deforestation is associated with loss of biodiversity and soil fertility. It enhances erosion and affects evapo-transpiration processes and watershed hydrological regimes. Deforestation can also affect or alter the microclimate regime.

36 Loss of biodiversity:

The possible impact of the project 6n biodiversity is mainly related to deforestation and physical landscaping and may be restricted- to only the areas of rehabilitation/construction.

Pollution:

The project is likely to cause-pollution of the environment in terms of noise associated with rehabilitation/construction works. Pollution can also be caused as a result of the abandoning and poor disposal of paint materials. Dust associated with earth preparation for foundation of building can impair the quality of air around construction sites.

Loss of agricultural land:

Agriculture is the dominant economic activity in the rural areas covered by the E.A. The agricultural activities are mostly food and cash crop production. Livestock rearing was at a very low ebb at the time of the assessment. The main food crop grown in the EA areas are rice (upland and swamp), groundnuts, sweet potatoes, cassava and other assorted vegetables. The project will however not cause loss of agricultural land, as new land will not be taken.

Creation of open pits:

Open pits are often associated with rehabilitation/construction sites. These pits are created during landscaping for laying of building foundation, construction of toilets and water delivery and storage facilities. If not well protected, these pits can pose threats to lives, can cause injuries, serve as rubbish dumps as well as mosquito breeding sites if left to collect water.

Impact on topography (Land stripping): The rehabilitation of community infrastructure would require the clearing of land cover and land stripping. The establishment of foundation for the buildings would require earth removal and soil modification. The topography of the selected areas is relatively flat a,nd landstaping activities will not significantly interfere with the aesthetic quality of the land. The environmental issues relating to land stripping are related to land cover change, dust pollution and noise amongst others.

7.1.3 Impact On Water Resources

Rehabilitation activities would require water for mortar mixing, bathing, laundering, drinking etc. The clearing and preparation of the land will increase river and stream sediment loading through soil erosion and transported sediments (dusts). Noise will also become an issue at the construction sites. The release of sediments into streams and rivers will have an impact on ecosystems such as mangroves. In any case, this project component is not expected to have any significant effect on surrounding water resources as the wastes to be generated will not include toxic materials. Construction

37 wastes are mainly solid in nature (pieces of wood, bricks, nails, corrugated iron sheets etc.) which are normally disposed off at designated disposal sites.

7.1.4 Impact On Air

The above-mentioned impacts of rehabilitation/building and construction on land have implications for air quality.

When the land cover is removed i.e. forests or vegetation is cleared for building purposes, the soil is exposed to the direct effects of wind. Thus, dust particles can be easily raised and carried about in the air causing short-term respiratory problems for both plants and animals. Land stripping produces a similar effect on air quality of the surrounding by causing dusty conditions particularly during the dry season.

Land preparation is a major activity in all aspects of rehabilitation/construction projects. It is often accompanied by emissions of dust particles and fumes (mainly from rock breaking activities) into the atmosphere. The impacts of these pollutants on air quality are usually low and gradually reduce as construction activity progresses.

7.1.5 Impact On Flora And Fauna

According to the site surveys, the selected sites are covered by low shrubs and grass with little or no medicinal value. There are no critical habitats at the identified/- selected sites as well as forest reserves. The fauna include small insects and rodents and the project is not likely to have any appreciable impact on them, Significant deforestation and therefore wide spread disruption of ecosystem is not envisaged.

7.1.6 Impact On Protected Wildlife Areas And Forest Reserves

The selected sites for housing and shelter construction do not lie on or close to protected wildlife areas and forest reserves and therefore the project is not expected to have any negative impact on these assets.

7.1.7 Impact On Monuments And Sites Of Cultural And Historic Significance

The project sites have been selected in consultation with the local (chiefdom, village) authorities arid.), accord'ance with the national and district development plans. The sites plans reveal that the project will not infringe on monuments and sites of cultural and historic significance.

7.2 Potential Negative Environmental Impacts Of Agricultural Inputs

Agricultural Inputs:

It is expected that the project will support productive investments in terms of agricultural inputs for these target beneficiaries in the form of crop seedlings to farmers, tree nurseries, fruit trees, and peripherals such as water hoses, watering cans, garden lines, hoes, cutlasses and so on. The project is clear on the fact that pesticides will not be provided as agricultural input.

38 Most of the target beneficiaries are internally displaced people, refugees from neighbouring countries, (mostly w6men and children). Most of these people are traditionally farmers who practised the shifting cultivation and rotational bush fallow system. The common practice in both systems is a period of cropping, during which the nutrient reserves of the soils are exploited, followed by a period of fallow during which the nutrient reserves are again mobilised .

The crops grown by these people include, sorguhn, corn, cassava, yam, and groundnuts. Fruit trees include banana, plantains, citrus fruits (orages, grapes, and lime), Palm trees, coconuts trees, piassava, ginger etc. The instruments used are crude forms of tools such as cutlasses, hoes, and rakes, to clear the land, turn the soil and remove the grass.

Preparations of the land for agriculture involves land clearing therefore the environmental impacts are quite varied. These can include the following a) Impact on public health and safety b) Impact on flora and fauna c) Impact on land d) Impact on water resources e) Impact on Air Quality f) other direct and secondary Impacts.

7.2.1 Impact On Health And Safety

Agricultural activities can negatively affect human health and safety as a result of ingestion of poison due to improper treatment and handling of chemicals. Stagnant water pools often associated with small-scale gardening can create breeding grounds for disease vectors. The use of pesticides for crop protection can also pose a threat to human health if accumulated in soil and drinking water.

The development of agriculture as a result of inputs by the project may likely cause an occurrence and resurgence of pests and diseases in areas of project coverage.

The Malaria Control Programme of the Ministry of Health and Sanitation provides basic sanitation tools to various communities and malathion (insecticide) is used to spray breeding sites of mosquitoes. There is also an ongoing Onchocerciasis programme aimed at eradicating this disease countrywide.

However, if there are any signs or indications of an occurrence or resurgence of pests and diseases relating to irttensification of agricultural activities, a brief reconnaissance survey should be undertaken in.the field by a specialist. Also, the Pest Control Unit of the Ministry of Agriculture and Food Security should be consulted to tackle any issue on pest control. With regards to diseases control, the Ministry of Health and Sanitation should be brought on board.

7.2.3 Impact On Land

Agricultural activities affect basically the area and type of land. If the terrain is hilly as in the case of upland rice cultivation, then the environmental concerns relate to soil erosion and downslope siltation and increase in the sediment load of streams if present in such areas.

39 The potential negative impact on the upland can be different from that of the impact on a coastal strip of land. For instance, swamp rice farming can create the threat of development of acid-sulphate soils as well as increasing the risk of salt water intrusion inland.

7.2.4 Impact On Water Resource

Agricultural practices often require water for irrigation. The potential negative impacts on water resourcerelate to reduction of stream/river runoff associated with the construction of irrigation facilities. Use of pesticides in crop protection can lead to their accumulation in water bodies thus reducing the quality of water nearby streams and rivers.

7.2.5 Impact on Air Quality

Soil preparation is an important aspect in agriculture. The usual practice of slash and bum can inject dust and other particulates into the atmosphere. Aerial spraying of chemical although not envisaged can impair air quality with ultimate human consequences for human health.

7.2.2 Impact on Flora and Fauna

Agricultural activities often involve land clearing and therefore encroachment into areas supporting critical habitats or significant biodiversity. They may even cause damage to terrestrial wildlife habitats biological resources or ecosystems as well as interfering with migratory routes. Other potential negative impacts may involve the fragmentation or isolation of habitats and plant and animal species.

7.2.3 Impact on Protected Wildlife Areas and Forest Reserves

The selected sites for agricultural activities do not lie on or close to protected wildlife areas and forest reserves and therefore the project is not expected to have any negative impact on these assets.

7.2.4 Impact on Monuments and Sites of Cultural and Historic Significance

The project sites have been selected in accordance with the national and district development 'pl4ns. Con'sultations reveal that agricultural aspects of the project will not infringe on monuments and sites of cultural and historic significance.

7.3 The Potential Negative Environmental Impacts of the Rehabilitation of Community Infrastructure (Provision of Markets, Court Barries, Schools, Rural Clinics and Security Posts).

The potential negative environmental impacts of the rehabilitation of community infrastructure (markets, court barries, schools, rural clinics and security posts etc.) are varied and site specific. Below is a discussion of these impacts on human health, land , water and air quality as well as on flora and fauna, potential wildlife areas and forest reserves and on monuments and sites of cultural and historic significance.

40 7.3.1 Impacts on Human Health and Human Made Environment

The impact on public health (e.g. respiratory, ailments, water contamination, noise pollution) are associated with land preparation and include landuse required for disposing of wastes.

It is expected that the NSAP of NaCSA will support the rehabilitation of health posts and clinics. Hospital/clinical wastes are also expected to be generated from these rural clinics. A waste management plan has been developed by MOHS and NaCSA will relate to MOHS with regards to the management of such wastes.

Small irrigation facilities could result in unforeseen health impacts from agricultural runoff into canals and streams, growth of aquatic weeds, expansion of snail populations and outbreaks of schistosomiasis (snails being a vector of this disease)

The impacts on the development of nearby communities may include increase in commercial and cultural activities. The returnees and internally displaced are expected to restore family units, restore cultural ties and fabrics. These activities will not generate conflicts (e.g. compulsory acquisition of property and or displacement of nearby communities). The site visits revealed that the communities to be rehabilitated are being rehabilitated with their social administrative structures.

7.3.2 Impact on Land

Community infrastructure rehabilitation as well as the provision of water and sanitation will be done on sites previously occupied such structures in both the previously and newly accessible areas. The type of land to be affected by the project has been carefully selected in conformity with the national and district development plans and does not belong to the category of land considered unsuitable for community infrastructure development.The project is expected to have minimal impact on deforestation,loss of biodiversity and agricultural land topography as well as on pollution of the land.

Deforestation

This is one of the most common environmental problems associated with building and construction. Deforestation is associated with loss of biodiversity and soil fertility. It enhances er6sQn and' affects evapo-transpiration processes and watershed hydrological regimes. Deforestation can also affect or alter the microclimate regime. Bush sticks may be required for scaffolding and support during rehabilitation of shelter and other community infrastructure. Loss of biodiversity

The possible impact of the project on biodiversity is mainly related to deforestation and physical landscaping and may be restricted to only the areas of construction

Pollution

The project is not likely to cause pollution of the environment in terms of noise associated with construction works. Pollution may also be caused as a result of the

41 abandoning and poor disposal of litter. Dust associated with earth preparation for foundation of building can impair the quality of air around construction sites.

Loss of agricultural land

Agriculture is the dominant economic activity in the rural areas covered by the E.A. The agricultural activities are mostly food and cash crop production. Livestock rearing was at very low ebb at the time of the assessment. The main food crop grown in the EA areas are rice (upland swamp), groundnuts, sweet potatoes, cassava and other assorted vegetables. Even though disarmament in the region has just been concluded. The project will however not cause loss of agricultural land, as new land will not be taken.

Creation of open pits

Open pits are often associated with rehabilitation/construction sites. These pits are created during landscaping for laying of building foundation, construction of toilets and water delivering and storage facilities.

If not well protected, these pits can pose threats to lives, can cause injuries and can also inadvertently serve as rubbish dumps as well as mosquito breeding sites if left to collect water.

Impact on topography (Lands tripping)

The rehabilitation of community infrastructure would require the clearing of land cover and land stripping. The establishment of foundation for the buildings would require earth removal and soil modification. The topography of the selected areas is relatively flat and land scapping activities will not significantly interfere with the aesthetic quality of the land. The environmental issues relating to land stripping are related to land cover change, dust pollution and noise amongst others.

7.3.3 Impact on Water Resources

Rehabilitation activities would require water for mortar mixing, bathing, laundering, drinking etc. The clearing and preparation of the land will increase river and stream sediment loadings through soil erosion and transported sediments (dusts). Noise will also become an.issue at the construction sites. The release of sediments into streams and rivers will have an impast on ecosystems such as mangroves.In any case, this project component is not expected to have any significant effect on surrounding water resources as the wastes to be generated will not include toxic materials. Construction wastes are mainly solid in nature (pieces of wood, bricks, nails, corrugated iron sheets etc.) which are normally disposed off in accordance with national waste management procedures.

7.3.4 Impact on Air

The above-mentioned impacts of rehabilitation/building and construction on land have implications for air quality.

42 When the land cover is removed i.e. forests or vegetation is cleared for building purposes, the soil is exposed to the direct effects of wind. Thus, dust particles can be easily raised and carried about in tlie air causing short-term respiratory problems for both plants and animals. Land stripping produces a similar effect on air quality of the surrounding by causing dusty conditions.

Land preparation is a major activity in all aspects of rehabilitation/construction projects. It is often accompanied by emissions of dust particles and fumes (mainly from rock breaking activities ) into the atmosphere. The impacts of these pollutants on air quality are usually low and gradually reduce as construction activities progresses.

7.3.5 Impact on Flora and Fauna

According to the site surveys, the selected sites are covered by low shrubs and grass with little or no medicinal value.There are no critical habitats at the identified/ selected sites as well as forest reserves.The fauna include small insects and rodents and the project is not likely to have any appreciable impact on them, Significant deforestation and therefore wide spread disruption of ecosystem is not envisaged.

7.3.6 Impact on Protected Wildlife Areas and Forest Reserves

The selected sites for housing and shelter construction do not lie on or close to protected wildlife areas and forest reserves and therefore the project is not expected to have any negative impact on these assets.

7.3.7 Impact on Monuments and Sites of Cultural and Historic Significance

The project sites have been selected in accordance with the national and district development plans. The sites plans reveal that the project will not infringe on monuments and sites of cultural and historic significance.

7.4 Potential Negative Environmental Impacts of Small-Scale Irrigation Facilities

At present there are no major irrigation schemes in the country due to high costs of development and lack of government policy to encourage the system. There were however few minor scheme that does not store any appreciable amount of water. The war however'd,troyed these schemes. Recently in the Koinadugu district as well as in the Western Area, simple gtavity-fed systems have been developed.

It is expected that the project will not fund major irrigation schemes, which are associated with large-scale river diversion, flooding etc. The environmental impacts of small simple schemes are manageable. Such impacts are discussed below.

The Project Appraisal Document (PAD) makes provision for small-scale irrigation facilities to rural communities. The negative potential environmental impacts of irrigation facilities depend on the size of the facility, its technical details and the scale of irrigation activities involved.

43 For small irrigation facilities, the potential negative environmental impact is associated with the creation of a small pool of water in the reservoir from where the water is pumped. This pool of water can act as a breeding ground for mosquitoes if not properly managed. Another impact relates to- stream damming. Partial transmission pipes or hoses to the reservoir, which is often small. Such dams have very little effect on stream flow during the rainy season. However, during the dry season when the volume of stream flow is low, sediments can accumulate in the dams and therefore may interfere with the stream sediment transport dynamics

7.5 The Social Impacts Of The Project (Community Driven Initiatives) Project components I and 2 would involve support for social infrastructures such as shelter and housing, rural clinics, schools and vocational training centres, markets, inputs into agriculture and small-scale irrigation facilities. A discussion of the social impacts of this support is given below.

The rehabilitation of community infrastructure including shelter facilities as well as inputs into agriculture will generally improve the livelihood of the target beneficiaries, quality of their lives, health, education, security, increase socio- economic activity, and reduce trauma, Poverty, the spread of HIV/AIDS and teenage pregnancy amongst others.

Inputs into agriculture would likely be to raise agricultural production and productivity; increase and ensure food security, and provide means of income and livelihood, particularly for IDPs, returnees and refugees.

It may also cause agricultural land expansion (increased land take) and intensification (increased yields/ha, use of high yielding varieties, increased pesticide and agrochemical u se, misuse and abuse.

7.5.1 Impact on Involuntary Resettlement

A selected number of site visits, which discussions with stakeholders were important activities in the assessment of the social impacts of the project. The main issues raised related to involuntary settlement associated with returnees, possible acquisition of new land for shelter construction and squatters. Other issues related to the improvement of the quality of life associated with the provision of social facilities viz.: schools, health cliniCs, markets, agricultural inputs etc.

Discussion and interviews with the NaCSA project committee and other stakeholders revealed, that resettlement of the people will be voluntary as they will be returning to their original villages, in accordance with government's national resettlement strategy.

Sites visits to a number of the villages to where the people will be returning revealed, that other people have not taken up residence in these villages after the original occupants had left. In places were such illegal occupation has occurred, (for instance, in the Kailahun district), resettlement issues are handled under the provision of the World Bank's resettlement policy as described in OP 4.12.

44 Where acquisition of new land is inevitable, e.g. for disadvantaged, vulnerable groups (amputees, disabled etc.) a resettlement Policy Framework has been annexed as part of this EA. It was found out, that with the return of law and order, government and local authority, the returning population is returning to their original homes. Also no squatters were found on the sites visited and this situation appears to be common to all the other villages according to reports from various other agencies.

From discussions with the relevant authorities, the returning population may need to rehabilitate their destroyed homes, which obviously will entail rehabilitation. However, the rehabilitation of homes will not entail the acquisition of new land. In case where new land will be required for the construction of new homes, this will not involve any involuntary resettlement of people and that no serious environmental impact resulting from construction activities is envisaged.

However, some activities of the project may result in some form of physical displacements and involuntary taking of land. In such cases the procedure for land take from communities at chiefdom and village levels where communal land ownership is the dominant form of tenure, will be followed. Under such circumstances, compensation, payment and provisions of the Resettlement Policy Framework (RPF) for involuntary resettlement will apply.

7.5.2 Impact on Potential Agricultural Land Traditional agricultural practices are associated with shifting cultivation and bush fallow systems. The rehabilitation of community infrastructure is likely to affect potential agricultural land as much of the farming is at the subsistence level and any decrease in crop Production per capita (i.e. due to decreased fallow periods and smaller farm plots) will have a direct impact on the local economy.

7.5.3 Impact on local economy The majority of the people we spoke to were eager to see the implementation of the project as they are of the view that the project was well conceived and will immensely contribute to the improvement of the quality of their lives and alleviate poverty in their area.

In the short term, the influx of job seekers may bring some problems to the local sites, as there will bettompetition fQr limited jobs. The areas to which these workers will move are those villages or location close to the construction sites, which suffered destruction during the rebel war. This will put pressure on the already limited food supply and social services. NaCSA will work with local authorities to address these problems and identify possible solutions. To support the overall development of the project areas NaCSA will establish working relationships with relevant ministries and development partners to attract development support.

7.5.4 Impact on Health and Sanitation

Very poor sanitary conditions exists in the chiefdoms covered by the EA in the various districts These result from unhealthy living conditions as well as inadequate

45 refuse and sewage disposal facilities and methods. The chiefdoms visited lack safe sources of drinking water as well as such basic sanitation facilities as pit latrines as over 50% of these latrines were conpletely destroyed during the civil conflict. Inhabitants occasionally use village streams and the near.by bush as toilet and for sewage disposal. .

An important social impact of the project will be increased provision of water supply and sanitation facilities which would help in the reduction of diseases like malaria, diarrhoea, dysentery, bilharzias, lassa fever, measles, polio, etc

8.0 MANAGING THE NEGATIVE ENVIRONMENTAL AND SOCIAL IMPACTS OF COMMUNITY-BASED DEMAND DRIVEN INITIATIVES.

8.1 Mitigating Measures For Shelter And Housing Rehabilitation

The various activities associated with community based demand driven initiatives such as rehabilitation of community infrastructure, are likely to degrade the environment and to produce wastes that should be managed in such a manner so as not to impair the quality of the environment. Issues of environmental concern relate to the disposal of wastes and protection and management of the environment. It is expected that the wastes generated by these activities should be disposed of in such a manner, that they would pose little or no threat to the environment. The potential negative environmental impacts of these activities include pollution of the land, water resources and the air.

8.1.1 Mitigating Measures for the Impacts on Human Health and Human Made Environment

The potential negative impacts on human health and human made environment have been discussed earlier. They include amongst others, the possible increase in respiratory disorders, ailments, and water-bome diseases. However, these impacts can be mitigated by properly disposing of wastes for example, by implementing the SHARP and its Waste Management Plan (WMP), land degradation control programs, water pollution control programs, air pollution control programs (see annex),and through public education.

8.1.2 Mitigating Measures for the Impacts on Land The mitigating measures identified to reduce the negative environmental impacts of the project on land are discussed below although the project is expected to have minimal impact on deforestation, loss of biodiversity and agricultural land topography. As well as on pollution of the land.

Mitigating Measures for Deforestation

This is one of the most common environmental problems associated with building and construction. Deforestation is associated with loss of biodiversity and soil fertility. It

46 enhances erosion and affects evapo-transpiration processes and watershed hydrological regimes. Deforestation can also affect or alter the microclimate regime.

Reforestation drives through community tree-planting aotivities will help restore and mitigate the negative environmental impacts of the project on land.

Mitigating Measures for the Loss of biodiversity

The possible impact of the project on biodiversity is mainly related to deforestation and physical landscaping and may be restricted to only the areas of construction. On- site biodiversity loss can be minimised or mitigated by proper siting of infrastructure.

Mitigating Measures for Pollution

In Sierra Leone, solid unseparated wastes are either disposed of indiscriminately or at designated open-dumpsites. Pollution may be caused as a result of the abandoning and poor disposal of litter. In order to mitigate environmental pollution, disposal practices will be employed so as to reduce the transmission of infectious diseases, as well as the threat of injury to people and animals from various materials.

The project not is also likely to cause pollution of the environment in terms of noise associated with construction works. Dust associated with earth preparation for foundation of building can be mitigated by keeping fill areas damp, covering trucks carrying dust and monitoring of air quality

Mitigating Measures for the Loss of agricultural land

Agriculture is the dominant economic activity in the rural areas covered by the E.A. The agricultural activities are mostly food and cash crop production. Livestock rearing was at very low ebb at the time of the assessment. However, compensation payment to those likely to loose land will be done in case of any unexpected land take and loss of assets, Community infrastructure rehabilitation will however not cause loss of agricultural land, as new land will not be taken.

Mitigating Measures for the Creation of open pits

Open pits are bqdn associated with rehabilitation/construction sites. These pits are created during landscaping forH4aying of building foundation, construction of toilets and water delivering and storage facilities.

If not well protected, these pits can pose threats to lives, can cause injuries and can also inadvertently serve as rubbish dumps as well as mosquito breeding sites if left to collect water. These locations of such pits should be marked and pits covered as soon as no longer in use. Rehabilitation of such areas at the end of the project can mitigate the above impact.

47 Mitigating Measures for the Impact on topography (Lands tripping)

Community infrastructure rehabilitation will be done on sites previously occupied such structures in both the previously and newly accessible areas. The type of land to be affected by the project has been carefully selected in`conforrnity with the national and district development plans and does not belong to the category of land considered unsuitable for community infrastructure development The topography of the selected areas is relatively flat and landscaping activities will not significantly interfere with the aesthetic quality of the land. 8.1.3 Mitigating Measures for the Impact on Water Resources

Mitigating the negative impacts such as land clearing (CDIS) on water resources would require proper control of land use, reforestation and /or soil conservation activities in watersheds.

Also strict adherence to waste management control procedures will also reduce the risk of pollution of either surface or ground water. Mitigation measures, such as water quality monitoring as well as community sensitization programmes will have to be put in place. Implementation of the (SHARP) program can help mitigate the impact of the project on water resources.

8.1.4 Mitigating Measures for the Impact on Air

The above-mentioned impacts of rehabilitation/building and construction on land have implications for air quality.

Land preparation is a major activity in all aspects of rehabilitation/construction projects. It is often accompanied by emissions of dust particles and fumes (mainly from rock breaking activities ) into the atmosphere. The impacts of these pollutants on air quality are usually low and gradually reduce as construction activities programmes.

However, air pollution should be considered in planning and layout of projects, which are likely to pollute the air as a mitigation measure. Also a programme for air sampling and measurement should be considered as a mitigation measure. Dusty areas should be kept damp and trucks carrying fill materials covered.

8.1.5 Mitigatmg Measures for the Impact on Flora and Fauna

Project sites will be selected in accordance with community laws and practices so as to avoid or minimise projects' impacts on flora, fauna, critical habitats and forest reserves. According to the site surveys, low shrubs and grass with little or no medicinal value cover the selected sites.

48 8.1.6 Mitigating Measures for the Impact on Protected Wildlife Areas and Forest Reserves

The selected sites for housing and shelter construction will be chosen so that, they do not lie on or close to protected wildlife areas and forest reserves and therefore the project is not expected to have any negative impact on these assets.

8.1.7 Mitigating Measures for the Impact on Monuments and sites of cultural and historic significance-

The project sites will be selected in accordance with the national and district development plans so that the project will not infringe on monuments and sites of cultural and historic significance.

8.1.8 Mitigating Measures for Miscellaneous Impacts

There are a few issues such as noise, dust, visual impact which may require remediation rather than mitigation, none are considered significant, but will be covered within the framework of the National Environmental Action Plan which will ensure appropriate controls and monitoring where necessary.

The EA has also identified a number of impacts due to the planned activities of the project. All the impacts are manageable. Other impacts are culturally related in that the rehabilitation/ construction process of community infrastructure would be a source of temporary employment for the people particularly the youths, as well as providing them with an informal building training experience.

8.2 Mitigating Measures For Agricultural Inputs

8.2.1 Mitigating Measures for Potential/Actual Negative Impacts on Public Health

To avoid ingestion of poison by individuals or the public at large due to improper treatment and handling of chemicals, it is necessary to educate target groups on safety regulations and measures to be taken to prevent accidents and poisoning.

Farmers and gardeners will be educated on the need to reduce the creation of pools of stagnant water by improving the construction of channels and canals.

Mitigating the p'ossible effect, of pesticide accumulation in soil and drinking water can be done through the implementation of national and international regulations on pesticide use. The use of organic fertilizers and herbicides will be promoted through training workshops and demonstrations.

8.2.2 Mitigation Measures for Potential/Actual Negative Impacts on Flora and Fauna

In identifying land for agricultural activities, efforts should be made to avoid encroachment into areas supporting critical habitats or significant biodiversity, rear and/or protected species and destruction of wildlife habitats and ecosystems. This can be achieved by applying and local planning regulations as well as through public

49 (community based) sensitization programmes. At the local level, specific restrictions on deforestation in certain areas (critical habitats, shrines, nature reserves etc.)exist. These regulations will be used to tnitigate the above potential negative impacts of agriculture on flora and fauna.

Sierra Leone is a party to the convention on Biological Diversity and therefore has obligations to protect the country's biodiversity. Also the planting drives will also be undertaken to restore the aethetic values of deforested areas.

8.2.3 Mitigation Measures for Potential/Actual Negative Impacts of Agricultural Inputs on Land

National and local planning regulations will be applied to prevent or minimise the impact of the project on soil salinity, erosion and desertification. Extension services to equip farmers with new technologies and improved farming methods compatible with soil conservation and sound environmental management expected to be provided by government will also serve as mitigating measures.

National and local planning and environmental regulations will be enforced to reduce the potential negative impacts on land topography and on water bodies caused by erosion and siltation as well as on the aethetic quality of surrounding areas. Tree planting exercises will be regularly carried out as an operational mitigating measure.

8.2.4 Mitigating Measures for Potential/Actual Negative Impacts of Agricultural Inputs on Water Resource

Where water extraction is from small inland streams partially dammed to provide an irrigation facility (reservoir) for small scale gardening, the environmental impacts such as reduced flow and increased sedimentation can be regulated by local guidance and education. Limits on how much water can be drawn at any given time can be established so as to minimise the negative environmental impacts. The project is not expected to finance large-scale irrigation schemes. Therefore the application of national and local planning and environmental guidelines and regulations will help mitigate the above-mentioned negative environmental impacts. It will however be necessary to strengthen monitoring programmes which will help in the management of any negatiye environmental threats.

8.2.5 Mitigating Measures for Potential/Actual Negative Impacts on Air Quality

Since the popular method of farming in Sierra Leone involves slash and burning, farmers should be encouraged to avoid large scale burning at any one time. This will reduce the amount of non-dust particles emitted into the atmosphere in a given area. Dust pollution of air in the project areas is expected to below as the soil preparation technology employs mainly hand-held hoes.

Air pollution due to pesticide use outside project funding may need to be monitored and regulated through already existing programmes international, national and local regulatory mechanisms.

50 8.3 Mitigating Measures For The Environmental Impacts Of The Provision Of Markets, Court Barries, Schools And Security Posts.

The provision of markets, court barries, schools and security posts involve that may impair the quality of the environment. Such activities of concern relate to the disposal of waste and degradation of the environment. The potential negative environmental impacts of these activities include pollution of land, water resources and the air. It is expected that the wastes generated by these activities would be disposed of in such a manner and that environmental degradation will be minimised so that little or no threat will be posed to the environment.

8.3.1 Impacts on Human Health and Human made environment

The impact on public health (e.g. respiratory, ailments, water contamination, noise pollution) is expected to be minimal and temporary. These impacts are associated with land preparation and include landuse required for disposing of wastes.

The impacts on the development of nearby communities are multiple. The returnees and internally displaced are expected to restore family units, restore cultural ties and fabrics, and will not generate conflicts (e.g. compulsory acquisition of property and or displacement of nearby communities). The site visits revealed that the communities to be rehabilitated are being rehabilitated with their social administrative structures.

8.3.2 Mitigating Measures for the Impacts on Land The mitigating measures identified to reduce the negative environmental impacts of the project on land are discussed below although the project is expected to have minimal impact on deforestation, loss of biodiversity and agricultural land topography as well as on pollution of the land.

Mitigating Measures for Deforestation

This is one of the most common environmental problems associated with building and construction. Deforestation is associated with loss of biodiversity and soil fertility. It enhances erosion and affects evapo-transpiration processes and watershed hydrological regimes. Deforestation can also affect or alter the microclimate regime.

Reforestation .4tives throqgh community tree-planting activities will help restore and mitigate the negative environmental impacts of the project on land.

Mitigating Measures for the Loss of biodiversity

The possible impact of the project on biodiversity is mainly related to deforestation and physical landscaping and may be restricted to only the areas of construction. On- site biodiversity loss can be minimised or mitigated by proper siting of infrastructure.

Mitigating Measures for Pollution

In Sierra Leone, solid unseperated wastes are either disposed of indiscriminately or at designated open-dumpsites. Pollution may be caused as a result of the abandoning and

51 poor disposal of litter. In order to mitigate environmental pollution, disposal practices will be employed so as to reduce the transmission of infectious diseases, as well as the threat of injury to people and animats from various materials.

The project not is also likely to cause pollution of the environment in terms of noise associated with construction works. Dust associated with earth preparation for foundation of building can be mitigated by keeping fill areas damp, covering trucks carrying dust and monitoring of air quality

Mitigating Measures for the Loss of agricultural land

Agriculture is the dominant economic activity in the rural areas covered by the E.A. The agricultural activities are mostly food and cash crop production. Livestock rearing was at very low ebb at the time of the assessment. Community infrastructure rehabilitation will however not cause loss of agricultural land, as new land will not be taken.

Mitigating Measures for the Creation of open pits

Open pits are often associated with rehabilitation/construction sites. These pits are created during landscaping for laying of building foundation, construction of toilets and water delivering and storage facilities.

If not well protected, these pits can pose threats to lives, can cause injuries and can also inadvertently serve as rubbish dumps as well as mosquito breeding sites if left to collect water. These locations of such pits should be marked and pits covered as soon as no longer in use. Rehabilitation of such areas at the end of the project can mitigate the above impact.

Mitigating Measures for the Impact on topography (Lands tripping)

Community infrastructure rehabilitation will be done on sites previously occupied such structures in both the previously and newly accessible areas. The type of land to be affected by the project has been carefully selected in conformnity with the national and district development plans and does not belong to the category of land considered unsuitable for community infrastructure development The topography of the selected areas is relatively flat and landscaping activities will not significantly interfere with the aesthetic quality of the land.

8.3.3 Mitigating Measures for the Impact on Water Resources

Mitigating the negative impacts such as land clearing (CDIS) on water resources would require proper control of land use, reforestation and /or soil conservation activities in watersheds.

Also strict adherence to waste management control procedures will also reduce the risk of pollution of either surface or ground water. Mitigation measures, such as water quality monitoring as well as community sensitization programmes will have to be put in place. Implementation of the (SHARP) program can help mitigate the impact of the project on water resources.

52 8.3.4 Mitigating Measures for the Impact on Air

The above-mentioned impacts of rehabilitation/building and construction on land have implications for air quality.

Land preparation is a major activity in all aspects of rehabilitation/construction projects. It is often accompanied by emissions of dust particles and fumes (mainly from rock breaking activities ) into the atmosphere. The impacts of these pollutants on air quality are usually low and gradually reduce as construction activities programmes.

However, air pollution should be considered in planning and layout of projects, which are likely to pollute the air as a mitigation measure. Also a programme for air sampling and measurement should be considered as a mitigation measure. Dusty areas should be kept damp and trucks carrying fill materials covered.

8.3.5 Mitigating Measures for the Impact on Flora and Fauna

Community projects sites such as wells, will be selected in accordance with community laws and practices so as to avoid or minimise projects' impacts on flora, fauna, critical habitats and forest reserves. According to the site surveys, low shrubs and grass with little or no medicinal value cover the selected sites.

8.3.6 Mitigating Measures for the Impact on Protected Wildlife Areas and Forest Reserves

The rehabilitation of housing will not be close to protected wildlife areas and forest reserves and therefore the project is not expected to have any negative impact on these assets.

8.3.7 Mitigating Measures for the Impact on Monuments and sites of Cultural and Historic Significance

The project sites will be selected in accordance with the national and district development plans so that the project will not infringe on monuments and sites of cultural and historic significance.

8.4 Mitigating Measures For The Social Impacts

Specific mitigating measures are associated with various constructional activities that impact on the local populations. These include the following:

8.4.1 Relocation and Resettlement

In the construction process the aspect of relocation and settlement was not an issue, thus there was no social impact associated with this issue. Since the construction of community infrastructure is a demand driven exercise the land was leased to NaSCA gratis. To address any other issues, NaSCA will consult with a representative group of stakeholder, chiefdom authorities and other authorities as appropriate on the

53 rehabilitation of any disturbed land and on any outstanding issues in order to address them effectively. A Resettlement Policy Framework has also been prepared to take into account any relocation or resettlement.

8.4.2 Loss of Potential Agricultural Lands

Where loss of agricultural land is inevitable NaSCA will work with the local chiefdom authorities in finding land or alternatives for those affected. This will require surveys on pre-construction land use plans. However, the land acquisition procedures by NaSCA has not given any indication that the population will loose land and that relocation would be necessary.

8.4.3 Local Economy

Where influx of job seekers may put pressure on already limited food supply and social services, NaCSA is expected to work with the local authorities to address these problems and identify possible solutions. NaCSA will also support overall development of project areas and establish working relationships with relevant ministries and development partners to attract development support.

8.4.4 Health and Sanitation

The returning population is likely to create pressure on the modes of health and sanitation facilities in the project areas of coverage. Therefore NaCSA will work with other government and Non-governmental agencies and organisations to improve on the health and sanitation facilities as well as implement monitoring programmes.

8.4.5 Mitigating Miscellaneous Impacts

There are a few issues such as noise, dust, visual impact which may require remediation rather than mitigation, none are considered significant, but will be covered within the framework of the National Environmental Action Plan which will ensure appropriate controls and monitoring where necessary.

The EA has also identified a number of impacts due to the planned activities of the project. All the impacts are manageable. Other impacts are culturally related in that the rehabilitatio4/ construetion process of community infrastructure would be a source of temporary ernmployment for the people particularly the youths, as well as providing them with an informal building training experience.

8.5 Analysis Of Alternatives

Alternative sites were not considered as the designated sites are the same as those occupied by the infrastructures that are going to be rehabilitated under the project in short the project is skewed towards rehabilitation rather that new construction. The "newly accessible areas" were areas that had been negotiated with the community landowners thus, the question of accepting or rejecting the "given sites" does no arise.

54 9.0 DESCRIPTION OF THE INSTITUTIONAL ARRANGEMENTS FOR THE MANAGEMENT OF THE NEGATIVE ENVIRONMENTAL IMPACTS OF COMMUNITY DRIVEN INITIATIVES.

9.1 Institutional Arrangements

The effective management of the Environmental and Social Assessment Plans (ESAP) depends on NaCSA's commitment on the one hand to ensure, that the programs are adequately implemented and financed and on the other hand on the capability of the other stakeholders to carry out the mitigation programs. This sub-section discusses the institution and instruments available to and those developed so far by NaCSA and the institutional arrangements to be made to ensure that these programs are implemented in a timely and effective manner.

The national and local institutional framework for environmental management and protection is the overall structure, which is designed to protect, conserve and restore our environment.

The social structure in each district described earlier is important for the development of environmental management strategy at the local level therefore; any proposed framework should take cognisance of this structure.

Environmental and social management at the local level is for now carried out by Community Based Organisations (CBOs) and Non-Governmental Organisations (NGOs), which operate through local groups, mainly youths. Environmental Management activities are often associated with reforestation programmes, sensitisation and regulation enforcement. These CBOs and NGOs are co-ordinated by the Department of Environment that has posted environmental officers to Northern, Southern and Easter regions of the country.

At the chiefdom levels the community groups are often empowered to arrest people who degrade the environment and pose threat to the health and wealth of the community.

The National Environment Board of the helm of the environmental management in the country facilitates co-ordination, co-operation and collaboration amongst government ministries, local authorities, international and local NGOs and other agencies. The National FocatlPoint (NFP) which is the Department of Environment (DOE) acts as secretariat to the board. The Department of Environment is expected to establish Provincial, District and Chiefdom Environmental Committees to implement policies at the local level.

The proposed framework therefore envisages a bottom - up approach wherein the local communities will be assisted to develop and execute projects related to mitigation measures identified in the EA.

55 9.2 Specific Procedures The NaCSA projects activities might require preparation or the application of existing plans where appropriate, individual plans will be used if they exist or be prepared by appropriate agencies.

These plans will define the specific procedures, actions and monitoring needed to carry out certain tasks required by the project. These plans and framework will require the participation of NaCSA and Sectoral Govemment Ministries and commissions, and the implementation of the activities contained within these plans, and the fleshing out of a plan from the RPF

9.2.1 Environmental Management Plan

An Environmental Management Plan (EMP) has been developed to complement this EA study and is part of this report. This plan discusses the potential negative environmental impact of the NSAP and proposes mitigation measures and cost estimates. (See Annex III). There is also a National Environmental Action Plan (NEAP) which envisages the development of various environmental management plans e.g. Biodiversity Strategy Action Plan, Coastal Zone Management Plan and Land Use Plan amongst others.

9.2.2 Biodiversity Strategy Action Plan

Currently a Biodiversity Strategy and Action Plan (BSAP) is the in the process of being developed as part of an implementation strategy of the National Environment Action Plan (NEAP), within the Ministry of Agriculture and Food Security.

9.2.3 Waste Management Plan

The newly developed Waste Management Plan (WMP) developed by the Ministry of Health which addresses the management of wastes including hazardous and medical would be used by NaCSA in instances were a proposed project may require such issues. The Waste Management Plan of the SHARP project (AMP SHARP) details the handling and disposing of wastes that are generated countrywide by various sectoral projects ad more specifically for medical health wastes. The WMP SHARP also addresses the management of waste designated for special handling including hazardous, medical, emergency response wastes and sewage as well as waste minimisation th4ough composting and recycling programs. The WMP SHARP may require updating as the NSAP progresses to reflect specific site conditions or may be adapted to those conditions. The Ministry of Health (MOH) in partnership with the Project Management and Evaluation (PME) unit of NaCSA and other line ministries will be responsible for updating and carrying out the actions specified in the WMP SHARP

9.2.4 Resettlement Policy Framework

Apart from the above plans the preparation of a Resettlement Policy Framework (RPF) has also been suggested as part of this EA study as a precautionary measure in case the WB OD 430 on Involuntary Resettlement is triggered by the NSAP

56 The resettlement policy framework has been prepared in compliance with the World Ban requirements as stated in the WB's policy on involuntary resettlement (OP 4,12). The RPF is also designed to meet the legal requirements.of the government. The RPF presents a framework for the development of specific programs for relocating individuals who may be displaced by NSAP development. The RPF outlines the various components around which issues associated with the local governing structure in Sierra Leone, possible payment/compensation procedures, grievance reporting, and monitoring can be carried out. NaCSA and partners will be responsible for implementing, monitoring the RPF and its specific RAP where applicable.

10.0 PROPOSED INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT

10.1 Environmental Assessment Standing Committee

Environmental and Social Management of NaCSA's project will be administered through an Environmental Assessment Standing Committee which will be established by and will work in close collaboration with the National Environmental Protection Board (NEPB) and may include representatives of NaCSA's management staff, implementing partners, local community and representatives of the National Environmental Protection Board.

This Standing Committee will focus on developing the capabilities and support mechanisms necessary to administer environmental and social management programs of NaCSA's project. At local level, environmental committees should be established within the respective Area Development Committees. The committees should work with the respective programme representatives/consultants on the implementation of management and monitoring programs.

These District Environmental Committees should report to the regional/district environmental officers via, their respective district councils. The regional environmental .officers will then report to the Department of the Environment and the National Envirqpment B6ard.

NaCSA will register Community Based Organisations in the various districts.

A monitoring and evaluation team should be set up in collaboration with NaCSA and Area Development Committees to ascertain the success of implementation of programs during routine field checks.

57 11.0 PROPOSED MITIGATING MEASURES AND COSTS ESTIMATES

The proposed mitigating measures for the potential negative environmental impacts of the NaCSA project and cost estimates are given in the annex.

This table contains the potential environmental impacts of activities of the proposed NaCSA project discussed earlier and for which the present EA is being done, and cost estimates. Some of the mitigating measures are ongoing whilst others will last for the duration of the project.

Basically, the project activities such as shelter and community infrastructure development will impact on or contribute to land degradation, water pollution and air pollution.

With regards to land degradation, the following mitigation measures are being proposed: Where open or burrow pits have been created, these areas should be rehabilitated at the end of the specific project activity. Nearby materials, (earth) can be used for this purpose.

In the case of deforestation; tree planting activities and awareness raising campaigns should be embarked upon. In order to minimise the accumulation of litter/garbage, local and national regulations on health should be enforced as well as the provision of adequate number of litter container.

Water pollution may occur as a result of the project's activities. This may result from ineffective methods of waste disposal, small-scale irrigation schemes as well as from agricultural run-off. Implementation of the solid /liquid waste management programme under the SHARP project and a water quality monitoring programme are measures proposed to mitigate possible water pollution.

Dust and other emissions can result in air pollution. This is more relevant at the construction stage of the project and is expected to be minimized once the community infrastructure is fully rehabilitated. Post construction/building materials should be cleared and properly disposed of inorder to prevent water pollution. During the active phase of the project, efforts should be made to minimise the volume of dust and other emissions reaching the atmosphere by keeping all areas of fill damp, cover truck carrying fill materials with canvas and implement an air quality monitoring programme Dust pollution can be reduced after post construction era, through paving of alleys and covering of feeder roads with tar, and planting of carpet grass on open fields. Cost estimates of mitigating measures are provided in the annex.

Restoration of the construction sites should be carried through tree planting as an erosion control measure and water control measure. A tree nursery site should be maintained and replanting schemes put in place in deforested areas. Local NGOs will be involved together with the local communities in tree planting exercises. The

58 planted trees will assist in water management by reducing land surface evaporation rates and by regulating infiltration rate during the rainy season by reducing surface runoff through interception.

A clean up programme will have to be put in place. This should involve the clearing of dangerous materials like nails, pieces of timber, broken blocks, scattered sand and gravel, pieces of iron, mortar mixing waste water, saw dust etc. where recycling or reuse is possible, this should be done e.g. sawdust can be used as manure in the experimental health-facility gardens.

Efforts shall be made to preserve natural habitats, monuments and sites of historic value in the vicinity of the proposed project sites.

Identification of applicable and effective measures to prevent accidents involving hazardous substance should be carried out as well as sensitization activities on safety techniques.

At the construction phase of the project(s) protective head and body gear will be worn to protect workers from contact with hazardous materials or substances in accordance to building safety regulations. Information and training of workers will also complement this issue.

11.1 Awareness Raising

A number of programmes will be developed to create and/or improve on environmental knowledge, attitudes and practices within the community. Sensitisation of community leaders including the Area Development Committees (ADC) should be undertaken. The awareness raising campaigns should take the form of workshops, radio talks, meetings, posters, skits, songs, etc.

11.2 Training Programme

During the consultative meetings, training needs of NaCSA and the local communities were identified. These include training on the following: * Identification of negative environmental impacts * Identification of Mitigating Measures for negative environmental impacts * Management of the negative environmental impacts of NaCSA's projects * Natiohal.jegislativ'e and Institutional framework for environmental protection * Monitoring plan develbpment and implementation * Basic knowledge and skills in project management * Procurement and accounting * Participatory local planning * Maintenance of community-based infrastructure * Community participation in project management * Outreach techniques * Financial management and skills development * Beneficiary impact assessments

The Proposed Training Programme is given in the Annex.

59 12.0 ENVIRONMENTAL AND SOCIAL MONITORING INDICATORS

There are a number of environmental and social monitoring indicators. The environmental indicators include but not restricted to:

* Water quality * Land quality * Air quality * Rate of deforestation * Rate of biodiversity loss

On the social front the indicators can include: * Number of labourers employed * Employment rates * Level of remuneration for employees * Amount and type of sanitation facilities provided * Number of local people trained in various skills of construction during the project * Types of water contaminated disease * Number of persons with access to basic services * Number of persons exposed to economic governance An analysis of the above indicators show that, water quality, land quality and air quality will not be significantly impaired; rates of deforestation will be moderate and biodiversity loss will not be significant due to the project activity at the specific sites. The social impact of the project will be mostly favourable according to the analysis of the above indicators as well as from public consultations.

13.0 ENVIRONMENTAL AND SOCIAL MONITORING PLANS 13.1 Environmental Monitoring Plan

Sierra Leone is in the process of rehabilitation after the war. Various ministries of government are involved in various sector projects relating to rehabilitation. As required by thejNEAP, Z000, an EA of these projects are being carried out. Most of these projects (education and health) related are WB funded and are also subjected to EAs in compliance with WB funding policies. The present EA, has also developed a monitoring plan (See Annex) to assist NaCSA in the management of the environmental negative impacts, that are likely to result from the implementation of its projects. Environmental monitoring will take place on a quarterly basis. Environmental indicators will be integrated into NaCSA's monitoring and evaluation system at the central, regional, and district levels.

The plan identifies a number of environmental concerns, which include; water quality, air quality, land quality and deforestation.

60

The issues to be addressed in relation to the afore-mentioned concerns are; pollution/contamination of water and air, soil erosion, nutrient loss and biodiversity loss.

The parameters to be measured include; PH, BOD, COD and water nutrients, odour, visibility, rates of erosion, soil nutrients, amounts of generated solid waste and types/families and genera of plant species. The following methods will be used in the monitoring process; laboratory analysis, visual observation, surveys and numerical methods.

Sampling sites will be selected in accordance with standard scientific criteria and frequency of measurements and observations will depend on the intensity of the projects activity with a minimum frequency of at least once weekly.

NaCSA will utilise these plans in ensuring that its supported projects are properly monitored using the indicators mentioned herein and developing more where necessary and will develop appropriate reporting procedures and monitoring mechanisms.

13.2 Social Monitoring Plan

The Social Monitoring Plan identifies the following concerns:

* Involuntary displacement of people. * Possible loss of agricultural land. * Sudden upsurge of population in project areas. * Deterioration of water and sanitation conditions.

It is expected that NaCSA will collaborate with line Ministries and its development partners in addressing the above concerns using existing monitoring sectoral programs.

Persons and Institution Contacted

The consultative meetings saw participants from various regions of the country, institutions and organisations. The various institutions represented included, various government riigiJstries, local government authorities and ministries private agencies. Also contacted were variouswNon-Governmental Organisations, Community Based organisations, Area Development Associations and Local Traditional authorities (Chiefs).

61 GENERAL RECOMMENDATIONS

I. The E.A. showed that the environmental impacts are manageable, therefore it is recommended that the project as proposed be cXried out with the mitigation measures as proposed by this summary report.

2. That this report be made available to all stake holders involved in the project.

62 REFERENCES:

Government of Sierra Leone: 1994; Sierra Leone National Environmental Action Plan

Government of Sierra Leone: 1994; The National Environmental Policy; Revised Edition

Government of Sierra Leone: 1992; The Fisheries Management and Development (Amendment) Act.

Government of Sierra Leone: 1988; The New Forestry Act

Government of Sierra Leone: 1989; The Wildlife Conservation Act

Government of Sierra Leone: 1992; The Mines and Mineral Act

Government of Sierra Leone 2000; National Environmental Protection Act, 2000

Government of Sierra Leone 1997; Guidelines for the implementation of school construction projects,

Republic of Sierra Leone, 2001; Interim Poverty Reduction Strategy Paper, Freetown

World Bank, 1991; Environmental Assessment Sourcebook, Vol. lI; Sectoral Guidelines; Environment Department; ISBN 0-8213 - 1844 - 6 (V. 2)

World Bank Safeguard Policies; 1998 Environmental Assessment (OP 4.01 October 1998).

63 ANNEXES

64 Annex 1 Basic Data on Sierra Leone

Land Area: 72,325Km2 Population Estimate (mid-1991) 4.3 million Population Density (No/km2 59 Natural Population Increase (annual % 3.7 Per Capita Gross National Product (1989) US$ 220 Total Debt (1989: US$ 1,057 million Real GDP Growth (86-90) (annual % 0.44 change): Food Production per Capita 86-89) (1979-81 90 = 100): Access of Safe Water (%) (85-88): 42 Major Sources of Foreign Exchange: Agriculture, wood production, fisheries, minerals.

Source: Various

65 Annex 2: Major related Projects to be financed by the Bank and/or other development agencies (completed, ongoing and planned).

Funding Agency Project Sector Issue Supervision Ratings (Implementation Progress IP) Bank Financed 1. Rehabilitation and Food Agriculture Security 2. Livestock Rehabilitation Bank Financed 1. Rehabilitation/Reconstr Health uction of health posts & clinics 2. Water and Sanitation Bank Financed 1. Rehabilitation/ of public Labour Intensive infrastructures Bank financed Rehabilitation/Reconstructi Education on of Schools Bank financed Community Market Community Structures infrastructure Bank Financed socio-economic Capacity Building Empowerment of severely war affected communities

66 Annex 3. Register of international treaties and other agreements in the field of the environment

No Sierra Leone Signature Ratification Accession (AC) Succession (S) Adherence (AD) I Convention on Fishing and Conservation of the Living 13-3-1962(S) Resources of the High Seas. 2 Convention on the High Seas - 13-3-1962 3 Treaty Banning Nuclear Weapon Test in the Atmosphere, in 4-9-1963 21-2-1964 outer space and under water 4 Convention on the continental shelf - 25-11- 1966(AC) 5 Treaty on Principles Covering the Activities 27-1-1967 - Of state in the Exploration and the use of outer space including the moon and other celestial bodies 6 Treaty on the Prohibition of the Emplacement of Nuclear 11-2-1972 - Weapons and other Weapons of Mass destruction on the Sea Bed and Ocean Floor and in the Sub-Soil thereof. 7 Convention on the Prohibition of the development Production 24-11-1972 29-6-1972 and stock piling of Bacteriological (Biological) and toxic Weapons and on their destruction 8 Convention on the Prohibition of Military or and other hostile 12-4-1978 - use of Environmental Modification Techniques. 9 International Plant Protection Convention - 23-6-1981(AD) 10 United Nation Convention on the Law of the Sea 10-12-1982 12-12-1994 (R) II Agreement Relating to the Implementation of part XI of the - 12-12-1994 (P) United Nations Convention on the law of the Sea of 10 Dec. 1982

67 Annex 4 Mitigating Measures and Cost Estimates

Activity IMPACT MITIGATION RESPONSIBLE COST MEASURES ORGANISATION ESTIMATE (USD) Rehabilitation of Shelter Land Degradation and other Community a) Open Pits * Rehabilitation of such NaCSA and 10,000 Infrastructure areas at the end of Development project Partners

b) Deforestation * Reforestation/tree 20,000 planting activities -do- * Awareness campaign

* Implement a waste c) Pollution management plan 20,000 -do-. * Enforce regulations on health and sanitation * Provide litter containers d) Modification of * Implement local topography building regulations and planning procedures * Proper selection of sites

Water Pollution a) Ineffective methods of * Implementation of NaCSA and 20,000 waste disposal solid/liquid waste Development management Partners programme under the SHARP project

* Implement a water b) Agricultural run-off quality monitoring programme 20,000 -do- Air Pollution

a) Dust and other * Ensure minimum -do- 20,000 emissions volume of dust in the air * Keeping all areas of fill damp * Cover with canvas material trucks carrying fill material * Implement an air quality monitoring programme

Impact on flora and fauna -do- 20,000 a) Habitat destruction * Selection of project sites in accordance with community laws and regulations

68 Impact on wildlife areas and forest reserves a) Habitat destruction -do-

Possible accumulati6h of . Education and training pesticide in soil and water on the use of organic fertilizers and herbicides * Implementation of national and international regulations on pesticides use * Train farmers in new and improved farming techniques

Agricultural inputs related to land -do- 20,000 Small Scale irrigation * Implement water schemes and related quality monitoring pollution impacts programme * Improve technical details of schemes

Damage to natural habitats * Limit scale of -do- 20,000 irrigation * Consider com pensatory measures

69 Annex 5 - Monitoring Plan

Environ- Issue to be Parameters Methods'to be Sampling Freg. Of Detection Definition mental addressed to be used Locations Measurements/ Limits of Concern Measured .Observations Thresholds

Water Pollution/ PH,BOD, Laboratory Along Monthly quality Contamination COD & Water analysis Water Nutrients course

Air -do- Odour Visual Construction Monthly Quality ,Visibility observation Sites Land Soil erosion, Erosion rate, Erosion Project Monthly Quality nutrient loss, nutrients, Assessment affected areas pollution amount of Surveys, solid wastes Laboratory generated. analysis for soil quality, Pollution assessments Deforestatio Forest cover Rates of Surveys Project Monthly n loss deforest-ation affected areas Biodiversity Biodiversity Number and Surveys Project Monthly loss types of affected areas species lost

70 Annex 6 Proposed Training Programme

Training Programme Time frame Responsible Funding Expected person/organisation source outcome 1 Identification of negative July, 2003 NaCSA NaCSA & NaCSA staff environmental impacts Partner trained 2 Identification of mitigating measures for negative August, environmental impacts 2003 -do- -do- -do- 3 Management of the negative environmental impacts of NaCSA Projects Sept., 2003 -do- -do- -do- 4 National Legislative and NaCSA staff Institutional framework for trained environmental protection Oct., 2003 -do- -do- Community staff trained 5 Monitoring plan development and NaCSA staff implementation Nov., 2003 -do- -do- trained 6 Basic knowledge and skills Community in project management Dec. 03/Jan. -do- -do- capacity built 04 7 Procurement and accounting Jan. 2004 -do- -do- -do- 8 Participatory local planning Feb. 2004 -do- -do- -do- 9 Maintenance of community March 2004 based infrastructure -do- -do- -do- 10 Community participation in April 2004 NaCSA staff project management -do- -do- trained May 2004 11 Outreach techniques -do- -do- -do- 12 Financial management and June 2004 skills development -do- -do- -do- 13 Beneficiary impact July 2004 assessments assessments J -do- -do- -do-

Total Estimated Cost of theTraining Programme: $200,000*

* This figure will be further refined duringproject implementation.

71 ANNEX 7: FIRST SCHEDULE OF EPA PROJECTS REQUIRING ENVIRONMENTAL IMPACT ASSESSMENT LICENCES

A licence is required for the projects whose activities involve or include the following:-

a) Substantial changes in renewable resource use (e.g. conversion of land to agricultural production, forestry or to pasture land, rural development, timber production);

b) Substantial changes in farming and fisheries practices (e.g. introduction of new crops, large scale mechanization or use of chemicals in agriculture);

c) Exploitation of hydraulic resources (e.g. dams, drainage and irrigation projects, water basin development, water supply);

d) Infrastructure (e.g. roads, bridges, airports, harbours, transmission lines, pipelines, railway);

e) Industrial activities (e.g. metallurgical plants, wood processing plants, chemical plants, power plants, cement plants, refinery and petrochemical plants, agro-industries);

f) Extractive industries (e.g. mining, quarrying, extraction of sand, gravel, salt, peat, oil and gas);

g) Waste management and disposal (e.g. sewerage systems and treatment plants, landfills, treatment plants for household and haizrdous waste);

h) Housing construction and development schemes;

i) Establishment of places of entertainment, motor repair garages and welding shops;

j) Importation of second hand vehicles. ANNEX 8 SECOND SCHEDULE OF EPA

Factors for determining whether a project requires an environmental impact assessment:- a) The environmental impact on the community; b) The location of the project; c) Whether the project transforms the locality; d) Whether the project has or is likely to have substantial impact on the ecosystem of the locality; e) Whether the project results in the diminution pf the aesthetic, recreational, scientific, historic, culture or other environmental quality of the locality; f) Whether the project will endanger any species of flora or fauna or the habitat of the flora fauna; g) The scale of the project; h) The extent of the degradation of the quality of the environment; i) Whether the project will result in an increase in demand for natural resources in the locality; j) The cumulative impact of the project together with other actiVities or projects, on the environment; ANNEX 9 THIRD SCHEDULE

CONTENTS OF ENVIRONMENTAL IMPACTS ASSESSMENT (EIA)

An EIA shall contain a true statement and description of:-

a) The location of the project and its surroundings;

b) The principle, concept and purpose of the project;

c) The direct or indirect effects that the project is likely to have on the environment;

d) The social, economic and cultural effects that the project is likely to have on people and society;

e) The communities, interested parties and Government Ministries consulted;

f) Any actions or measures which may avoid, prevent, change, mitigate or remedy the likely effect on people and society;

g) Any alternatives to the proposed project;

h) Such other information as may by necessary for a proper review of the potential environmental impact of the project. ANNEX 10 CHECKLIST OF POTENTIAL ISSUES FOR AN ENVIRONMENTAL AND SOCIAL ASSESSMENT

1. Will land settlement be reviewed as a result of the project?

Yes ------No ------Insufficient information ------

2. Will forests and woodlands be affected by the project?

Yes ------No ------Insufficient information ------

3. Will adequate measures be taken to ensure the protection of threatened areas?

Yes ------No ------Insufficient information ------

4. Will the project consider planning and management issues of mineral resources?

Yes ------No ------Insufficient information ------

5. Are any wetlands (e.g. estuaries, lakes, mangroves, marshes and swamps) likely to be affected by the project?

Yes ------No ------Insufficient information ------

6. With the project consider planning and management issues of coastal marine resources?

Yes ------No ------Insufficient information ------

7. Will the project likely stimulate the secondary growth of settlements and infrastructure?

Yes ------No ------Insufficient information ------

8. Will watcrsheds within the refugee and IDP reintegration areas effectively protected and managed?

Yes ------No ------Insufficient information------

9. Will wildlands (natural habitants) be affected by the project?

Yes ------No ------Insufficient information------

10. Will adequate measures be taken to ensure the protection of wildiands?

Yes ------No ------Insufficient information --- 11. Will the project involve the use of pesticides?

Yes ------No ------Insufficient infornation ------

12. Will the project potentially expose people to water - related or water-borne diseases?

Yes ------No ------Insufficient information ------

13. Will the project involve rural works?

Yes ------No ------Insufficient information ------

14. Will monuments and sites of cultural and historic significance be affected by the project?

Yes ------No ------Insufficient information ------

15. Are there people who have taken up residence in these villages after the original occupants had fled?

Yes ------No ------Insufficient information ------

16. Is the returning population returning to their original homes?

Yes ------No ------Insufficient information ------

17. Are these homes vacant?

Yes ------No ------Insufficient information ------

18. Are there squatters on the land?

Yes ------No ------Insufficient information -----

19. Will the retirning population need to construct new homes?

Yes ------No ------Insufficient information ------

20: Will the project involve acquisition of new land?

Yes ------No ------Insufficient information ------

21. Will the project involve any involuntary resettlement of people?

Yes ------No ------Insufficient information------ANNEX 11: MINUTES OF CONSULTATIVE WORKSHOP HELD IN KENEMA TOWN AT THE HOLY ROSERY SECONDARY SCHOOL FOR GIRLS, CHAPEL 23RD - 24TH OCTOBER, 2002.

Dignitaries Present:

Mr. Joseph Sam-Sesay - Asst. Director Planning Monitoring & Evaluation Unit NaCSA Mr. John Paul Gegbe - Regional NaCSA Officer -East Mrs. Theresa Sesay - Principal - Holy Rosery Secondary School for Girls Mr. Willie Momoh - Regional Director, Ministry of Lands, Country Planning, Forestry and the Environment (MLCPFE) Mr. Edwin Baimba-Environment Officer, (East) Department of the Environment, MLCPFE Mr. P. Daboh - Administrative Officer, NaCSA

Consultants:

Dr. Raymond G. Johnson Dr. Reynold G. Johnson Dr. Ernest T. Ndomahina

The opening ceremony for the consultative workshop started at 9:50 a.m. with Muslim and Christian Prayers.

The language adopted was Krio (Lingua Franca).

Opening Remarks

Dr. Ndomahina gave a brief-overview of the purpose of the consultative meeting. Highlights of his over view include:

- The need for EIA studies as part of the World Bank procedure for the NSAP

- To consider the implications of the NSAP for involuntary resettlement

- Introduction of the consultants and dignitaries invited to the Consultative workshop.

The Chairman of the occasion was Mr. John Paul Ngebeh, Regional Co-ordinator of NaCSA Eastern Province. In his remarks the following were highlighted: Expressed gratitude to the participants from Kono, Kailahun, and the host district Kenema for coming. He described the focus of the workshop which he said was consultative on one hand and experience sharing on the other for the successful implementation of the NSAP which now requires more emphasis on environmental considerations He stressed the importance of planning with environmental concerns He informed that NCRRR has been transformed into NaCSA NaCSA is now moving from relief (humanitarian) to recovery and development. NaCSA has been funding over three hundred projects twenty five percent of which is in the Eastern Region. NaCSA acknowledges the fact that minimum attention had been paid to environmental issues in the past due to ignorance The EIA is good and useful to NaCSA as they move from ERSF to NSAP Environmental issues will now be put into the design right unto implementation stage He admonished implementing partners to be very conscious about the new demands for environmental concerns to be taken firmly onboard in implementing the NSAP according to the recommendations for mitigation that will be provided in the EA study.

Statement by Principal Holy Rosery Secondary School, Kenema The purpose of the consultative meeting is important Environmental issues are also important to women who are crucial users of the environment.

- She stressed community participation as important.

- She expressed the view that mitigation measures to be proposed in the EIA study must be implemented by implementers of the NSAP and that the local community should be as 'watchdogs' for a good environment.

- She wished to consultative meeting well. Statement by the Regional Director of Ministry of Lands Country Planning Forestry and the Environment Highlights of his speech include:

- Consultative workshop is timely and expressed his gratitude to the World Bank and NaCSA - Catalogued the process of formal Environmental Management in Sierra Leone.

- Description of Institutional Framework for environmental management and government's position on environmental matters

- Intemational conventions, protocols and treaties that the government has signed and acceding to, such as UNCLOS, UNFCC, BSAP, Montreal, protocol Stockholm (POP's),Desertification convention etc.

- He wished to consultative meeting well.

Statement by Lead Consultant on the EA study Dr. Raymond Johnson

Highlights of the lead consultant's presentation:

Overview and update of the environmental impact assessment study and Resettlement Policy Framework being developed for NaCSA The impact of the expected National Social Action Project ( NSAP) on the physical, biological and social environment were analysed After the predicted cumulative site specific impact of the NSAP successor program of the ERSF has been established mitigation measures will be identified that are designed to limit the impact on the physical biological, and social environment Detailed National and sector plans are existing to support the proposed mitigation measures. These national plans include amongst others the National Environment Action Plan (NEAP) ,National Biodiversity Action Plan (BSAP), National Forestry Plan, Sierra Leone HIV/AIDS project (SHARP), various sector plans and programs aimed at reducing environmental impact. Most of these plans, programs and projects are aimed at building capacities of institutional Frameworks, management of programs for managing the environment and monitoring programs. Several major issues emerged out of the study conducted by Dr. Raymond Johnson and his team. Their report will highlight the following The speedy rehabilitation of community infrastructures will be very important to reducing the social problems faced by communities in post-war Sierra Leone. Involuntary resettlement has to be catered for even though land given or acquired for rehabilitation of community infrastructure was done in accordance with existing procedures. It is important for communities to take environmental management into their own hands to ensure sustainability of the NSAP. In the evaluation process, community development issues are crucial for project management and sustenance The EA document and the RPF will be completed soon and will be available for public review after being cleared by the World Bank. Copies will then be displayed to the public, at the at NaCSA regional offices, the Head quarter office in Freetown, MLCPFE, the University and SLANGO.

Statement by the Environment Officer ,Eastern Region of MLCPFE

Mr Edwin Baimba stated that govemment attaches great importance to environmental issues. This is why the National Environmental Policy, the National Environmental Action Plan, the National Environmental Protection Act 2000 and the National Environmental Protection Board have all been established.

Statement by NaCSA (Head Office, Freetown)

Dr. J. Sam-Sesay, NaCSA's Programme Manager for Planning, Monitoring and Evaluation, stated that NaCSA wants the NSAP which is a community driven project to commence. The thrust of this project will lie in its harmony with the physical, biological and social environments so as to bring benefits to communities.

Representative of NGO Community Highlights:

- The period of relief is over and now it is development

- It is expected that this meeting will provide the NGOs with a road map for environmental management

- The impacts of their activities on the environment are beginning to show and that they hope to take into account the knowledge the workshop will generate. Expression of Community Concerns.

Highlights

Disappointment of the delay of NSAP. Pleaded with NaCSA to expedite the project commencement Desire to see socio-economic development go hand in hand with environmental management . That NSAP is concerned mainly with pQst war rehabilitation and reconstruction it will therefore pose little or no environmental problems to communities. The restoration of. agricultural activities will provide livelihood for traumatised populations and negative environmental impacts will be managed through existing government safeguards (i.e legislations and sector mandates) Land take from people will be avoided as far as possible and where necessary the issue of involuntary resettlement will be dealt with in accordance with existing land acquisition procedures NGO activities should encourage local community participation and development of community based organisations Expressed desire for proper environmental management, particularly in mining areas to ensure their rehabilitation. Education of communities and NGOs on the National Environmental Protection Act - 2000 governing environmental matters countrywide. Consulted people were happy to learn that Sierra Leone has also adopted guidelines and procedures for Environmental Impact Assessments similar to those of the World Bank.

Closing Courtesies

NaCSA staff and the consultants thanked their audience for the indulgence during the consultative workshop, for their co-operation and inputs. ANNEX 12 MINUTES OF CONSULTATIVE WORKSHOP HELD IN MAKENI TOWN AT THE PASTORAL CENTRE, MAKENI, 9TH _ 10TH OCTOBER, 2002.

Dignitaries Present:

Mr. Joseph Sam-Sesay, Programme Manager, Planning, Monitoring and Evaluation Mr. Peter Buridu - Regional NaCSA Officer - North Mr. George Banya - Provincial Secretary - North

Consultants:

Dr. Raymond G. Johnson Dr. Reynold G. Johnson Dr. Ernest T. Ndomahina

The opening ceremony for the consultative workshop started at 9:50 a.m. with Muslim and Christian Prayers.

The language adopted was Krio (Lingua Franca).

Opening Remarks

The chairman was Mr. Peter Bundu, Regional NaCSA Co-ordinator Northern Province highlighted the following:

The objectives of the consultative workshop were to acquaint stakeholders and development partners of NaCSA, traditional leaders and community development organisations on the purpose and objectives of the EA study that is preceding the NSAP of NaCSA.

- Generate input into the environmental and social aspects of the EA study. - Inform about environmental concerns of the NSAP which are to be incorporated into the EA report. - Identify'training Rkeeds on environmental issues for NaCSA staff. - Purpose of the workshop - Background to the ERSF and NSAP programs of NaCSA - The importance of the sustainability of the NSAP by taking on board environmental concerns. - Expressed gratitude to the participants from Koinadugu, Kambia,Port Loko, Tonkolili and the host district Bombali for coming. He described the focus of the workshop which he said was consultative on one hand and experience sharing on the other for the successful implementation of the NSAP which now requires more emphasis orLenvironmental consideration He stressed the importance of planning with environmental concerns. He explained how NCRRR has been transformed into NaCSA NaCSA is now moving from relief (humanitarian) to recovery and development NaCSA has been funding over three hundred projects. The Northern Region is expected to benefit greatly from the NSAP. NaCSA acknowledges the fact that minimum attention had been paid to environmental issues in the past due to ignorance The EIA is good and useful to NaCSA as they move from ERSF to NSAP Environmental issues will now be put into the design right unto implementation stage He admonished implementing partners to be very conscious about the new demands for environmental to be taken firmly onboard in implementing the NSAP according to the recommendations for mitigation that will be provided in the EA study.

Statement by the Provincial Secretary -Northern Province

He welcomed all on behalf of the Resident Minister, Northern Province and expressed his delight for the meeting and to deliver a statement from the Minister who was unavoidably absent. The Minister's statement highlighted the following:

- The EA was particularly important considering the devastation of physical and biological resources after the war, dislocation of community organisations and social structure as a result of the war .. - He expressed his gratitude to the country's President for bringing peace to the country at large and provision for sustainable development in the country

- He admonished the meeting to be attentive and participate in this consultation and to eventually take steps the minimise environmental degradation

- He wished the meeting well.

Statement by Lead Consultant on the EA Study Dr. Raymond Johnson

Highlights of the lead consultant's presentation. Overview and update of the Environmental Assessment and Resettlement Policy Framework studies The impact of the expected National Social Action Project ( NSAP) on the physical, biological and social environment were analysed. After the predicted cumulative sight specific impact of the NSAP successor program of the ERSF has been established mitigation measures will be identified that are designed to limit the impact on the physical biological, and social environment Detailed National and Sectoral plans are existing to support the proposed mitigation measures. These national plans include amongst others the National Environment Action Plan (NEAP) ,National Biodiversity Action Plan (BSAP), National Forestry Plan, Sierra Leone HIV project (SHARP), various sectoral plans and programs aimed at reducing environmental impact. Most of these plans, programs and projects are aimed at building capacities of institutional Frameworks, management of programs for managing the environment and monitoring programs.

Several major issues emerged out of the study conducted by Dr. Raymond Johnson and his team. Their report will highlight the following.

The speedy rehabilitation of community infrastructures will be very important to reducing the social problems faced by communities in post-war Sierra Leone.

Involuntary resettlement is not a serious problem as land given or acquired for rehabilitation for rehabilitation of community infrastructure was done in accordance with existing procedures. It is important for communities to take environmental management into their own hands to ensure sustainability of the NSAP. In the evaluation process, community development issues are crucial for project management and sustenance.

The EA document will be complemented soon and will be available for public revieW a,fter being cleared by the World Bank. Copies will then be displayed to the public, at the at NaCSA regional offices, the Head quarter office in Freetown, NLCPFE, the University and SLANGO.

NGO Representative

He thanked God for the workshop and acknowledge that the World Bank is changing its focus to involve grass-root people in the development phase of the project. He instructed that before environmental concerns were not taken onboard, but now this has come to the forefront. He pledged NGOs' commitment not only to carry the message of the consultative meeting to a wider community, but to implement any measure designed to minimise environmental degradation. Expression of Community Concerns Highlights

The sentiments expressed by the participants from the NQrthern Province were similar to those expressed by their colleagues for the Eastern Province.

- They expressed the desire to see NSAP commence quickly - They were of the view that NSAP was a good initiative to which they felt a sense of ownership - It was the general opinion, that environmental problems associated with NSAP are manageable. - They were pleased with the fact that agricultural inputs will be made but were disappointed, that 'pesticides' will not be funded by the bank. - On the issue of 'land take' the team was assured that existing land acquisition procedures would be used so as to deal with any issue on involuntary resettlement. - The need for greater collaboration between NGOs and CBOs in an area of implementing mitigation plans for environmental and social impacts of NASP was highlighted. - The people expressed their appreciation for the knowledge gained and for the opportunity to contribute to the development of the E.A.

Closing Courtesies

NaCSA staff and the consultants thanked their audience for the indulgence during the consultative workshop, for their co-operation and inputs. ANNEX 13 MINUTES OF CONSULTATIVE WORKSHOP HELD IN MOYAMBA TOWN AT THE HARFORD SECONDARY SCHOOL

FOR GIRLS, CHAPEL, MOYAMBA 16 TH - 1 8 TH SEPTEMBER, 2002.

Dignitaries Present:

Mr. Syl Fannah - Director, Programming and Coordination Mr. Moses Gbouma - Regional Coordinator, South Mrs. Lulu Sheriff - Principal - Harford Secondary School for Girls, Moyamba Deputy for Paramount Chief Momodu Sillah -

Consultants:

Dr. Raymond G. Johnson Dr. Reynold G. Johnson Dr. Ernest T. Ndomahina

The opening ceremony for the consultative workshop started at 9:50 a.m. with Muslim and Christian Prayers.

The language adopted was Krio (Lingua Franca).

Opening Remarks

Dr. Ernest Ndomahina (Consultant) welcomed the dignitaries and participants present at the opening ceremony. He stated that the purpose of the consultative workshop was to acquaint participants with the National Social Action Programme of NaCSA and the role of the communities and implementing partners of NaCSA in mitigating the environmental effects as identified in the EA study. He noted that the consultation was designed to crystallize training programmes for NaCSA staff, local communities, implementing partners and other stake holders for environmental management of the upcoming NSAP. He then called on Mr. S. M. Jonjo (Chairman of the Farmers Association, Moyamba district) to introduce the Chairperson for the opening ceremony.

Chairman's O. ening Remarks

The Chairperson of the occasion Mrs. Lulu Sheriff (Principal Harford School, Moyamba) in her opening remarks, dwelt on the widespread degradation of the environment country and in Moyamba Town in particular. She landed the efforts of the World Bank (WB) and it's in country partner (NaCSA) for putting environmental issues on the top of their projects agenda.

She then called on the following people to make their statements. Statements by the Deputy Chief of Kaiyamba Chiefdom

He expressed his sentiments for the consultative workshop being in his chiefdom. He dilated on the environmental concerns of the chiefdom, which amongst others included, safe drinking water, protection of forests and wildlife and good social infrastructure.

Statement by Mr. Moses Gbouma, Regional Coordinator 8 Southern Province

In his statement he lauded the consultants for conducting this consultative training workshop to address the concerns of the World Bank in environmental issues.

- Expressed gratitude to the participants from Pujehun, Bo, Bonthe, Mattru-Jong and the host district Moyamba for coming.

- He described the focus of the workshop which he said was consultative on one hand and experience sharing on the other for the successful implementation of the NSAP which now requires more emphasis on environmental consideration.

- He stressed the importance of planning with environmental concerns.

- He explained how NCRRR has been transformed into NaCSA.

- NaCSA is now moving from relief (humanitarian) to recovery and development.

- NaCSA has been funding over three hundred projects. The Northern Region is expected to benefit greatly from the NSAP.

- NaCSA acknowledges the fact that minimum attention had been paid to environmental issues in the past due to ignorance.

- The EIA is good and useful to NaCSA as they move from ERSF to NSAP.

Statement by the Director, Programming and Coordination, NaCSA

Mr. Syl Fannah recognised the presence of all dignitaries and observed all protocols. He welcomed all present at the meeting on NaCSA's behalf. He expressed kind sentiments for the consultative meeting and for the opportunity to update stakeholders on the purpose of the meeting and progress in the implementation of NaCSA's mandate.

The following 'te highlights from Mr. Fannah's address:

The NSAP is a successor program to the ERSF which was an emergency fund. The NSAP is a program designed to take Sierra Leone from emergency and relief to sustainable development after the war. The World Bank which is the main funding partner is concerned about environmental deteriQration that might accompany the NSAP. It is for this reason that this consultative mLeeting is held to explain environmental; issues and seek clarification for mitigating the negative effects of this successor program. To update the public on the EA study and the RPF for NaCSA. The World Bank is very much interested in the NSAP being implemented on a firm footing and therefore community structures which are the driving force and administrative framework for the success of the program is crucial.

Overview of Community Setting and Resettlement Issues.

Dr. Ernest Ndomahina gave an overview of this study and findings. He said the study was based on sample of communities from the Northern, Southern and Eastern Provinces. He said as this study was more or less a "Pilot Study" the overview was concerned with perceptions regarding the NSAP in post war Sierra Leone.

Statement by the Lead Consultant Dr. Raymond G. Johnson

He set the stage for the workshop by explaining the workshop objectives which he repeated was to (a) identify training needs for both NaCSA staff and the local communities (b) to relate NaCSA's project to the World Bank's requirement for an EIA study to ensure sustainability of the project, and to acquaint them with elements of environmental management. An update on the EA and RPF were also given.

Highlights of the Lead Consultant's Presentation

Overview and update of the environmental impact assessment study and RPF The impact of the expected National Social Action Project ( NSAP) on the physical, biological and social environment were analysed After the predicted cumulative sight specific impact of the NSAP successor program of the ERSF has been established mitigation measures will be identified that are designed to limit the impact on the physical biological, and social environment Detailed National and Sectoral plans are existing to support the proposed mitigation measures. These national plans include amongst others the National Environment Action Plan (NEAP) ,National Biodiversity Action Plan (BSAP), National Forestry Plan, Sierra Leone HIV project (SHARP), various sectoral plans and programs aimed at reducing environmental impact. Most of these plans, programs and. projects are aimed at building capacities of institutional Frameworks, management of ptograms for managing the environment and monitoring programs. Several major issues emerged out of the study conducted by Dr. Raymond Johnson and his team. Their report will highlight the following The speedy rehabilitation of community infrastructures will be very important to reducing the social problems faced by communities in post-war Sierra Leone Involuntary resettlement is not a serious problem as land given or acquired for rehabilitation for rehabilitation of community infrastructure was done in accordance with existing procedures. It is important for communities to take environmental management into their own hands to ensure sustainability of the NSAP. In the evaluation process, community development issues are crucial for project management and sustenance The EA document will be complemented soon and will be available for public review after being cleared by the World Bank. Copies will then be displayed to the public, at the at NaCSA regional offices, the Head quarter office in Freetown, NLCPFE, the University and SLANGO.

General Overview of Environmental Concerns

Dr. Reynold G. Johnson dwelt on the principles and sustainability of community development initiatives. He showed the synergy between community driven initiatives and sustainability and environmental soundness of such projects. He then explained the environmental considerations of NACSA rehabilitation programs.

NGO Representative

The NGO representative expressed his appreciation that the NGOs have been given the opportunity to participate in this meeting. He explained the important role they play in community development and welcomed the idea of grass-root participation in project identification and development. He expressed the desire that NGOs will work with the communities in the implementation of plans to reduce the potential negative environmental and social impacts of NSAP. Expression of Community Concerns

Highlights

- The majority of the participants from the Southern Region (Province) who gathered in Moyamba expressed the desire to see rehabilitation commence.

- They expressed the need for such an environmental assessment and were happy that the Government of Sierra Leone has also made efforts to protect the environment. - They highlighted the need to strengthen local institutions and build their capacity to implement environmental and social mitigation plans. - They acknowledge the 'newness' of environmental management and hoped that the NGOs , CBOs and the local communities will work in concert to ensure sustainability of NSAP. - It was the general view, that involuntary resettlement be avoided as far as possible and drew the team's attention to their local procedures for land acquisition - They were eager to see NSAP commence

Closing Courtesies

NaCSA staff and the consultants thanked their audience for the indulgence during the consultative workshop, for their co-operation and inputs. ANNEX 14 LIST OF INDIVIDUALS CONTACTED DURING THE REGIONAL CONSULTATIVE MEETINGS

SOUTHERN AND EASTERN PROVINCE

NAME DISTRICT 1. G.T Johnson Bonthe 2. M.K. Jaish Bonthe 3. Joseph Koroma Fillie Bonthe 4. Richard Salanicole Mattru 5. Harolla Tagbo Bonthe 6. Braima Baimba Mattru 7. Janet Massaguoi Mattru 8. Mustapha Cindeh Bompe Bonthe 9. M.A Jengo Mattru 10. M.L Morovia Mattru 11. Rosaline .M .Alie Moyamba 12. Ansu .O.Kallon Moyamba 13. Teddy Kpanabom Moyamba 14. D.M.Nicol Moyamba 15. Christiana .A.Vandy Moyamba 16. Katis Bangura Moyamba 17. Mustapha Kormoh Moyamba 18. Michael Bockarie Moyamba 19. Philip.M.Conteh Moyamba 20. Emmanuel.S.George Moyamba 21. Momodu Kemokai Pujehun 22. Chief Sidi Braima sowa Pujehun 23. Anthony O.S.Amara Pujehun 24. Lucy. M .F. Katter Pujehun 25. Mattia Koroma Pujehun 26. Eric .M .A Moosa Bo 27. Mohamed . S .Kamanda Bo 28. Samuel Torkpoh Bo 29. F . Mugbe Bassie Bo 30. Edward Sesay Bo 31 Willie Momoh Kenema 32 Edwin Baimba Kenema 33. Sylvester B.Aruna Kenema 34 Madam. Mariama Jalloh Kenema 35 Christian Musa Kenema 36 Patrick .S A,bu Kenema 37 James .N. Kendebo Kenema 38 Edmond .N. saidu Kenema 39 Holima.A.Sawai Kenema 40. Rev. Patrick.A.M.Kamara Kenema 41 Sahr.S. Mani Kono 42 Tamba.E.Boyah Kono 43 Tamba. E . M'bayo Kono 44 Yusuf Kamara Kono 45 Sahr Fillie Kono 46 Bobson .N.Banya Kailahun 47. Dauda.D.Lansana Kailahun 48. Joseph Nyuma Kailahun 49. Faiya Kormoh Kailahun 50. Alfred Lansana Kailahun NORTHERN PROVINCE. NAME DISTRICT 1. James.A.Kamara Tonkolili 2. Komba.S. Kamara Port Loko 3. Unisa .M .Conteh Port Loko 4. Brima.0. Kanu Port Loko 5. Sulaima.M. Kalokoh Port Loko 6. Umarr Sankoh Tonkolili 7. Sorie Tholley Tonkolili 8. Ibrahim.S.Turay Kambia 9. Mr. A. R. Sesay Kambia 10. Paul .K.Kanu Kambia 11. Momorie .F. Koroma Kabala 12. M .O. Barrie Kabala 13. M. J. Gassama Kabala 14. L. S . H . Marah Kabala 15. Sulaima.M. Samura Kabala 16. Aminata.N. Sheriff Kambia 17. Mohamed .S. Conteh Tonkolili 18. Martina.F. Sankoh Kambia 19. Alims Kabia Bombali 20. Ibrahim Daramy Bombali 21. Abu .B. Koroma Bombali 22. Aloysious Kamara Bombali 23. Isatu .M. Koroma Bombali 24. Fatu.S.Kamara Bombali 25. Hamid Bureh Bombali 26: Dennis .A . Conteh Bombali 27. Victor .A. Turay Bombali 28. Mohamed . I. Bangura Bombali 29. J. Bunting Williams Bombali 30. M .N .S .Kargbo Bombali 31. Moses. J. Mansaray Bombali 32. David Charles Bombali 33. Rev. Lawrence E. M . Kalloh Bombali 34. Rev. Mark M'Barma Bombali 35. Michael Keister Bombali 36. Bob Conteh Bombali 37. Rugiatu Kanu Bombali 38. Ar Wurie Bombali 39. Sam Massaquoi Bombali 40. I . B .Charlie Bombali 41. Samuel Bangura Bombali