ESIA) for the Construction of the Transmission and Distribution Lines Along the Laminkoto-Diabugu Corridor

Public Disclosure Authorized National Water and Electricity Company Government of The Gambia

THE GAMBIA ELECTRICITY RESTORATION AND MODERNIZATION PROJECT (GERMP)

Public Disclosure Authorized

Environmental and Social Impact Assessment (ESIA) for the Construction of the Transmission and Distribution Lines along the Laminkoto-Diabugu Corridor

Public Disclosure Authorized

March 2021

ABBREVIATIONS AND ACRONYMS ...... 6

LIST OF TABLES ...... 4 LIST OF FIGURES ...... 4 EXECUTIVE SUMMARY ...... 7 CHAPTER 1: INTRODUCTION AND BACKGROUND ...... 34 1.1 Project Background ...... 34 1.2 Project Development Objective ...... 34 1.3 Rationale for the ESIA ...... 34 1.4 Methodological Approach ...... 35 CHAPTER 2: OVERVIEW OF THE GERMP...... 36 2.1 Components of GERMP...... 36 2.2 Sub-Project Description and Location ...... 36 2.3 Technical Components of the Project...... 37 2.4 Project Activities ...... 38 2.5 Assessment of Project Alternatives ...... 38 CHAPTER 3: RELEVANT NATIONAL POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORKS ...... 40 3.1 Relevant National Policies ...... 40 3.2 Legal Framework Relevant to the Project ...... 42 3.3 Relevant International Conventions and Agreements ...... 44 3.4 Institutional Framework ...... 45 3.5 Relevant Bank Policies...... 46 3.6 Analysis of Gaps between Gambian legislation and Policies of the Banks ...... 48 CHAPTER 4: DESCRIPTION OF THE BASELINE ENVIRONMENTAL AND SOCIAL CONDITION OF THE PROJECT CORRIDOR ...... 49 THE PHYSICAL ENVIRONMENT ...... 49 Climate ...... 49 Rainfall ...... 49 Temperature ...... 50 Hydrology ...... 51 Physical Structures: Compounds, Buildings, Schools and Other Infrastructure ...... 52 THE BIOLOGICAL ENVIRONMENT ...... 59 Forest Cover of the Project area...... 59 Fruit trees and other Vegetation ...... 60 The Mammalian Fauna ...... 61 THE SOCIO-ECONOMIC ENVIRONMENT ...... 64 Demography and Population Along the Line Corridor ...... 64 Disadvantaged and Vulnerable Groups ...... 66 Gender and Gender-Based Violence (GBV)...... 66 Access of the Population to Education and Security Services...... 68

Access of the Population to Health ...... 68 Access of the Population to Electricity, Telephone Sevices ...... 68 Chance Finds and Cultural Heritage and Archaeology ...... 68 LOCATION-SPECIFIC BASELINE CONDITIONS ...... 74 CHAPTER 5: CONSULTAIONS AND AND PBLIC PARTICIPATION...... 84 5.1 Objectives of the Stakeholder Consultations ...... 84 5.2 List of Persons Consulted and Views Expressed ...... 86 CHAPTER 6: ANALYSES OF POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS...... 87 6.1 Principles Used in Evaluating Significance of Potential Impacts ...... 87 6.2 Potential Positive Impacts...... 92 6.3 Potential Negative Impacts and Mitigation Measures ...... 93 6.3.1The Physical Environment: Potential Negative Impacts and Mitigation measures ...... 93 6.3.2The Biological Environment: Potential Negative Impacts and Mitigation Measures ...... 99 6.3.3The Socio-economic Environment: Potential Negative Impacts and Mitigation Measures ...... 101 6.4 The Potential Cumulative Impacts ...... 108 CHAPTER 7: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN...... 110 7.1 Matrix on Mitigation of the Identified Potential Impacts ...... 110 CHAPTER 8: ESMP IMPLEMENTATION AND MONITORING ARRANGEMENTS ...... 132 8.1 Roles and Responsibilities for ESMP Implementation ...... 132 8.2 Specific Roles and Responsibilities ...... 134 8.3 Institutional Training and Sensitization ...... 135 8.4 Monitoring ...... 136 8.5 Reporting ...... 142 8.6 Environmental Auditing ...... 142 8.7 Budget for Implementation of ESMP ...... 142 CHAPTER 9: GRIEVANCE MECHANISM...... 144 9.1 Grievance and Conflict Resolution ...... 144 9.2 The Grievance Resolution Committee (GRC) ...... 144 9.3 Modalities for Conflict Prevention and Resolution to Address Grievances ...... 145 9.4 The Grievance Process...... 145 CHAPTER 10: CONCLUSIONS ...... 147 BIBLIOGRAPHY ...... 148 Annex1: List of Persons and Institutions Met...... 150 Annex 2: Summary of comments and views expressed during the consultations with stakeholders along the proposed line corridor ...... 152 Annex 3: Chance Find Procedures ...... 156 Annex 4: Modalities of the Proposed Grievance Mechanism ...... 157 Annex 5: Flow Chart of Grievance Process...... 158

Annex 6: Contract Clauses to be Included in Contractor’s Agreements...... 159 Annex 7: Codes of Conduct and Action Plan For Implementing ESHS and OHS Standards, and Preventing Gender Based Violence and Violence Against Children ...... 163

LIST OF TABLES

Table 3.1 Relevant National Polices Table 3.2 Legal Framework Relevant to the Project Table 3.3 Relevant Regional/International Signed/Ratified by The Gambia Table 3.4 Institutional Framework Table 3.5 World Bank Environmental and Social Safeguards relevant to the Project Table 3.6 EIB Environmental and Social Standards Relevant to the Project Table 3.7 Main gaps between Gambian legislation and Policies of the Banks Table 4.1 Annual and Monthly Mean Rainfall (mm) in Janjangbureh, 2008-2017 Table 4.2 Annual and Monthly Mean Rainfall (mm) in Basse 2008-2017 Table 4.3 Monthly Maximum Temperature (0C) in Janjangbureh - 2008-2017 Table 4.4 Monthly Maximum Temperature (0C) in Basse- 2008-2017 Table 4.5 Trees found along the corridor and their status nationally and within the IUCN Red List Table 4.6 Mammals found along the corridor and their Status nationally and within the IUCN Red List Table 4.7 Fish Species found within the Bolongs along the corridor, their Status nationally and within the IUCN Red List Table 4.8 The Avifauna Found along the corridor in the Park and their Status within the IUCN Red List Table 4.9 Villages and Communities Along the Transmission Line Corridor Table 4.10 Farming Calendar of Activities along the Transmission Line Corridor Table 4.11 Description of site-specific conditions along the Laminkoto-Diabugu Road Table 6.1 Some Factors used in Considering Significance of Impacts Table 6.2 Evaluation of Significance of Potential Environmental and Social Impacts Table 7.1 Potential Impacts and Corresponding Mitigation Measures Table 8.1 Summary of Roles and Responsibilities in ESMP Implementation Table 8.2 Capacity Enhancement Program for Effective ESMP Implementation Table 8.3 ESMP Monitoring Program Table 8.4 Estimated Budget to Implement the ESMP

LIST OF FIGURES

Figure 2.1 Location of Sub-Project Figure 4.1 Built-up area at junction of Karantaba Tabokoto/Wollof Figure 4.2 Karantaba Mosque close to the road Figure 4.3 Approach to the Sami Bridge at the Loumo site Figure 4.4 Sheds and stalls at the Loumo site at Sami Tenda Figure 4.5 Typical vegetation along the line corridor of Laminkoto-Diabugu Figure 4.6 Illustration of farm boundary away from the road Figure 4.7 Melon plantation (outside Project area) illustrating position of pole and farm clearance from the road and line corridor Figure 4.8 Market sheds and stalls at the weekly market in Sami Figure 4.9 Locally made insulated box for carrying ice blocks

Figure 4.10 Welding Workshop at Pachonki in Sami District, CRR Figure 5.1 Meeting with stakeholders along the Laminkoto- Diabugu Corridor Figure 5.2 Meeting with the TAC in Basse, URR

ABBREVIATIONS AND ACRONYMS

COVID-19 Coronavirus Disease 2019 CRR Central River Region DOF Department of Forestry DPPH Department of Physical Planning and Housing DPWM Department of Parks and Wildlife Management DWR Department of Water Resources EIA Environmental Impact Assessment EIB European Investment Bank ESHS Environmental Social Health and Safety ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan EU European Union GBV Gender-Based Violence GEAP Gambia Environment Action Plan GERMP Gambia Electricity Restoration and Modernization Project GM Grievance Mechanism GRC Grievance Resolution Committee IDA International Development Association IUCN International Union for the Conservation of Nature MOE Ministry of Energy MV/LV line Medium/Low Voltage Transmission and Distribution Line NAWEC National Water and Electricity Company NCAC National Council for Arts and Culture NEA National Environment Agency NEMA National Environment Management Act NRA National Roads Authority OHS Occupational Health and Safety OMVG Organisation pour la Mise en Valeur du fleuve Gambie (The Gambia River Basin Development Organization) PIU Project Implementation Unit PURA Public Utility Regulatory Authority SEA/SH Sexual Exploitation and Abuse/Sexual Harassment T&D Transmission and Distribution TAC Technical Advisory Committee URR Upper River Region VAC Violence Against Children WB World Bank

EXECUTIVE SUMMARY

Project Background This report is the Environmental and Social Impact Assessment (ESIA) of the proposed Medium Voltage (MV) Transmission and Distribution (T&D) line and other ancillary services along the Laminkoto- Diabugu Batapa road corridor and its branches to connect surrounding communities in the Central River and Upper River Regions.

This ESIA was prepared by Sustainable Development Focus (SD Focus) Ltd, a Gambian registered environment and natural resources consultancy firm, in consultation with the Environmental and Social team at NAWEC PIU. The ESIA study of the proposed line routing is based on the Consultant’s Contract Terms of Reference. The pre-feasibility studies have not yet been completed, and once the Contractor for the works has been selected, a Contractor’s ESMP (C-ESMP) be prepared based on the final technical design; the C- ESMP should be cleared by GERMP/PIU and the World Bank before the start of construction.

The proposed works are a sub-component of the Gambia Electricity Modernization and Restoration Project (GERMP). The GERMP is a $121 million multi-donor funded project involving the World Bank (WB), European Union (EU) and the European Investment Bank (EIB). Specifically, the WB and the EIB are financing this sub-component, and therefore, this ESIA is based on the World Bank Operational Policy/Bank Procedure (OP/BP 4.01) (Environmental assessment), EIB’s Environmental Social Standards (ESS 1) (Assessment and management of environmental and social impacts and risks), as well as the relevant national policies. Project Development Objective The development objective of GERMP is to improve the operational performance of the National Water and Electricity Company (NAWEC), by improving its power generation capacity and efficiency of its transmission network in order to increase access to electricity for socio-economic development.

Rationale for the ESIA Implementing the project activities are likely to generate negative impacts (physical, biological and/or social) including loss of vegetation and deforestation, soil erosion, wildlife and biodiversity, social conflicts, economic and physical displacement, as well as health and safety risks.

The rationale for preparing an ESIA along these corridors is to evaluate and mitigate the potential environmental and social risks and impacts that the construction activities will cause. The process will involve examining ways to prevent, minimize, mitigate, or offset/compensate for adverse impacts, and to enhance positive impacts throughout project implementation. This will enhance sustainability throughout the lifecycle of the project and beyond.

An Environmental and Social Management Plan (ESMP) which addresses and mitigates the risks and impacts is included in Chapter 7. The ESMP will identify specific mitigation measures, costs, and responsibilities for mitigation and monitoring. In addition, the National Environment Management Act (NEMA), 1994, requires that an ESIA, and an ESMP must be prepared to guide the implementation of the project activities. The general framework for the assessment and management of environmental and social safeguards of developments projects in The Gambia is provided in the NEMA, 1994, the EIA Guidelines and EIA Procedures of 1999, and the EIA Regulations, 2014.

Moreover, the EIB and WB require the development of an ESIA with an ESMP. Where policy conflicts occur between the national policies and the WB’s OP/BP 4.01 and EIB’s ESS1, the policies of the lenders will prevail.

OVERVIEW OF THE GERMP

Components of GERMP

The investments financed by the GERMP project are being implemented under 3 components with potential safeguards impacts; these are:

Component 1: On-grid solar PV This will finance a 20MW solar PV plant on a 31ha plot of land situated in the village of Jambur in West Coast Region (WCR).

Component 2: Transmission and Distribution (T&D) Upgrades This component will upgrade the existing T&D network to: • absorb the additional generation capacity • prepare for future capacity expansion including OMVG (the Gambia River Basin Development Organization) and other pipeline projects • reduce T&D losses • enable future grid extension

This component will also provide a new MV/LV line and substation between Laminkoto and Diabugu, which is the focus of this report.

Component 3: Off-grid solar PV. This would install solar PV with battery backup equipment in schools and health clinics in The Gambia.

Sub-Project Description and Location The proposed route of the transmission and distribution line is along the Laminkoto-Passamas road corridor in the northern bank of The Gambia, and it extends for 57km, terminating in Diabugu Batapa, (see Figure 4.1 below). The proposed line spans the Districts of Sami in Central River Region (CRR), and Sandu in the Upper River Region (URR).

The trajectory of the line will follow the road alignment, connecting the intermediate communities between Laminkoto and Diabugu. Additionally, T-offs (lines branching off from the main road) will be created where necessary, and lines will be constructed to connect communities located away from the main road alignment.

Some of the lines branching off from the main road will run through farmlands to supply the communities with both Medium Voltage (MV) and Low Voltage (LV) electricity. A total of 46 communities would be connected along these transmission corridors (see figure 2.1 below).

Figure 2.1: Location of Sub-Project

Source: Adapted from Google Earth

The CRR is the second most important region after the WCR in terms of electricity usage, with a population of 185,500 inhabitants. However, there is no electricity power supply between Laminkoto and Diabugu Batapa; creation of the new MV/LV lines and substation between these two communities will be a vital link, completing the network loop in CRR north, and connecting the Bansang and Basse networks. The substation in Bansang will serve Laminkoto, whilst the substation in Basse will supply Diabugu Batapa; this will promote the development of small businesses, reduce rural exodus, reduce illegal migration to Europe, and improve livelihoods in general.

Basse Local Government Area (LGA) in URR has a population of 240,000, and currently Basse supplies Diabugu Batapa in Sandu District, representing the largest electricity consumers in the north bank of Basse.

Technical Components of the Project covered under this ESIA

Characteristics of the proposed transmission network will include an operating voltage of 30kV covering 105Km of line connecting Laminkoto and Diabugu Batapa and surrounding communities via some branches, about 41 transformers (100kVA -160 kVA) mounted on steel poles. The transformers are used to transform electric power from MV (30kV) to the LV (415-volt (V) distribution system which is appropriate for use in private compounds and homes.

Movement of MV power will involve the use of transmission lines which consist of steel wires, cross bars, insulators, and conductors. The standard right of way (ROW) width for transmission lines is 6m (3m on each side of the centerline); the required setback from nearest structures is 2m horizontal. There is no approved vertical setback; therefore, the lines cannot be constructed over existing structures.

The standard and maximum span distances between transmission poles are 75m and 100m, respectively. The height of transmission poles will be a minimum of 10m, and the maximum height will depend on site-specific conditions and topography. Transmission poles will be erected on concrete foundations approximately 1 to 2m in diameter. Most of the foundation will be buried, with areas for bolting on the pole exposed above the ground. Following erection of the pole, the cross bar and insulators will be installed, and the conductors pulled from one pole to the next.

Project Activities

The following activities are expected to be carried out at various stages of project implementation: During the planning and construction phase

• Preparation of a detailed design for the project (including location of structures along the route) • Land clearing of vegetation, for base camp, to erect poles; felling/pruning of trees; digging foundation trenches etc. • Transportation of the various project components to the various work sites and locations • Stringing and connecting the lines to the poles

During the operations phase

• Management of the electricity production • Periodic clearing of vegetation and pruning of trees that have regrown

During the decommissioning phase

• Dismantling of base camp and installations • Transportation of equipment and materials away from base camp and pole sites • Management of disused elements and the pole sites

Assessment of Project Alternatives

Alternative Project Sites

Extension of electricity to the Districts of Sami and Sandu is in line with NAWEC’s policy goal of supplying electricity to all parts of the country in phases, especially in the face of resource constraints. Thus, it plans a gradual expansion of electricity coverage in the country, as resources become available, until it attains its ultimate objective of reaching universal access to electricity. It is on the basis of this plan that the two Districts have been selected for coverage under the GERMP, and with the availability of additional transmission capacity, NAWEC will consider other parts of the country for connection.

Thus, along this corridor, it is expected that developments in power supply can improve the foundation for job creation especially for youth and reduce economic migrants (backway syndrome) including for those who are vulnerable and disadvantaged such as women, and in the process contribute to the national goal of poverty reduction and boosting shared prosperity.

Along the road alignment is the ROW, (3 meters in width on either side of the road), which could potentially be the route of the lines. Any other alternative routing away from the ROW would potentially encroach into virgin land and/or forest and vegetated areas including some Community Forest Parks which are located further back away from the ROW. Creating another ROW to accommodate the lines will entail more vegetation and forest clearing, as well as impacting settlements through which the lines will pass. Thus, the project’s social and environmental footprints will be lesser along the existing ROW than an alternative routing.

Thus, the obvious choice to locate the lines will be preferable along either side of the road alignment using the existing ROW, but the left side (from Laminkoto to Diabugu) presents the least potential environment and social impact: • The left side has fewer trees likely to be impacted compared to the right side which has some indigenous protected species such as the baobab, and several Community Forests

• the right side has more communities likely to be impacted; several private properties are less than 5 meters from the edge of the road, whilst the communities on the left side of the road from Laminkoto can be by-passed

The “No Project” Alternative Under a “No Project” alternative scenario, the environmental and social impacts from the project will not occur. However, project benefits are expected to outweigh potential adverse impacts. The positive impacts of the project, as discussed in Chapter 6, will enhance the socio-economic development of the country, enhance access to electricity services to communities, and improve livelihoods and social development outcomes.

Specifically, without continuous electricity supply in the Sami and Sandu Districts, the youth would not be able to develop skills and trades such as welding, carpentry, or other small businesses that rely on electricity to enhance their livelihood. In addition, women would not be able to produce ice blocks and cold drinks made from locally available plants such as “wonjo” (hibiscus juice), which are few of the livelihood skills they wish to undertake.

Potential Positive Impacts

With the implementation of the project, the following benefits are expected:

2. Economic development and income generation from the supply of electricity will benefit specifically the population living along the line corridor, and generally the entire country. Specifically, women could be involved in the preparation and sale of food items (“wonjo” or

hibiscus juice, pancakes, roasted ground nuts, etc.) to the workers, as this is a common practice in construction sites.

3. With continuous electricity supply in the Sami and Sandu Districts, the youth could develop other skills and trade to enhance their livelihood; such skills and trade will include welding, carpentry, or other small businesses that rely on electricity. Women could also benefit by producing ice blocks and cold drinks made from locally available plants such as “wonjo”.

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

Potential Impacts and Corresponding Mitigation Measures Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility CONSTRUCTION WORKS (EXCAVATION FOR POLE CONSTRUCTION AND STRINGING OF LINES) Locating poles Involuntary resettlement Prepare and implement NAWEC/PIU Before TAC (to be For RAP within farmlands of PAPs; loss of crops and a RAP to consider all constructio coordinated by budget and markets earnings; loss of farmland lost; loss of n works the NEA) livelihoods livelihood sources, etc. start Works within market and Contractor During TAC - Loumo (weekly market works day) sites must not be carried during Loumo days Sexual Exploitation and Conduct community NAWEC/PIU All phases URR/CRR TAC 17,000 + Abuse (SEA) / Sexual sensitization meetings where 18,000 Harassment (SH) / about the need for NAWEC/PIU is co- =35,000 for Violence Against Children everybody to benefit opted as a Capacity (VAC); discrimination from project activities member Building and against women in irrespective of sex, and payment for employment and in ensure awareness of SEA/SH accessing project and SEA/SH, prohibited Prevention resettlement benefits, conduct, applicable and Response etc. sanctions, and the GRM Action Plan complaint procedures for SEA/SH and available services

Ensure codes of conduct outlining prohibited SEA/SH-related conduct and applicable sanctions, as well as relevant

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility provisions related to SEA/SH risk mitigation, are included in the contractor’s ESMP and bidding documents Monitor risks for NAWEC/PIU All phases Affected - escalating tensions communities Encourage women and NAWEC/PIU All phases URR/CRR TAC - other vulnerable groups where to raise their concerns NAWEC/PIU is co- on the resettlement opted as a process by organizing member independent consultations in safe and confidential environments, with groups and facilitators of the same sex Encourage women to Contractor All phases URR/CRR TAC/ Contractor’s apply for employment in NAWEC/PIU budget project activities without any impediments put in their way and ensure application of gender- equitable recruitment practices

Contractor to develop a hiring plan that would include hiring labor from within the community

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility giving equal opportunity to men and women

50/50 sharing for men and women of project benefits including benefits from compensation from resettlement

Enforce with signature and monitor codes of conduct for workers and all those involved in the project, ensuring that the codes outline prohibited SEA/SH conduct and applicable sanctions

Sensitize about the codes of conduct and SEA/SH for workers and community members, including prohibited conduct, applicable sanctions, and GM complaint procedures

Ensure survivor-centered approach to address

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility SEA/SH complaints by setting forth specific procedures under the GM, including a response protocol, to manage SEA/SH claims ethically and confidentially

Conduct periodic training of employees on the codes of conduct, prohibited behaviors, applicable sanctions, and GM complaint procedures for handling SEA/SH claims

Include the above NAWEC/PIU Before TAC (to be - measures in bidding works coordinated by documents for the NEA) contractors to enforce on their employees, including a SEA/SH Prevention and Response Action Plan for the contractor

Felling and Compensation of PAPs; Prepare and implement NAWEC/PIU Before TAC (to be For RAP pruning of loss of livelihoods, assets, a RAP to consider all lost constructio coordinated by budget economic trees and access to resources farmland, loss of n works the NEA) livelihood sources, etc. start

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility and impacts on Pruning of fruit trees livelihoods should be carried out only when tree branches grow towards the ROW

Risks of SEA/SH and VAC; Conduct community NAWEC/PIU All phases URR/CRR TAC See above discrimination against sensitization meetings where women in employment about the need for NAWEC/PIU is co- opportunities and in everybody to benefit opted as a accessing project and from project activities member resettlement benefits, irrespective of sex, and etc. ensure awareness of SEA/SH, prohibited conduct, applicable sanctions, and GM complaint procedures Monitor risks for NAWEC/PIU All phases Affected - escalating tensions communities Encourage women and NAWEC/PIU All phases URR/CRR TAC - other vulnerable groups where to raise their concerns NNAWEC/PIU is on the resettlement co-opted as a process by organizing member independent consultations in safe and confidential environments, with groups and facilitators of the same sex

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility 50/50 sharing of project NAWEC/PIU All phases URR/CRR TAC - and resettlement where benefits NAWEC/PIU is co- opted as a Enforce with signature member and monitor codes of conduct for personnel, ensuring that the codes outline prohibited SEA/SH conduct and applicable sanctions Ensure survivor-centered approach to address SEA/SH complaints by setting forth specific procedures under the GM, including a response protocol, to manage SEA/SH claims ethically and confidentially

Conduct periodic training of employees on the codes of conduct, prohibited behaviors, applicable sanctions, and GM complaint procedures for handling SEA/SH claims

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility Land clearance Loss of vegetation along Remove vegetation Contractor Before and URR/CRR TAC - and preparation line corridor around pole site only as during where necessary works NAWEC/PIU is co- opted as a member Cover pole’s concrete Contractor During and URR/CRR TAC Contractor’s and revegetate pole area after works where budget to maintain vegetation NAWEC/PIU is co- opted as a member Destruction of forest Ensure that only the Contractor Before and NAWEC/PIU/ TAC See above trees and effect on the right of way, if any, is during with DOF leading environment, landscape, cleared; avoid forests works process drainage and wildlife Seek approval from DOF before forest trees are felled Keep records of all ‘forest trees’ on to be felled Educate and warn workers to avoid burning activities Hunting by imported Contractor Before, NAWEC/PIU/TAC - workforce will be during and prohibited; after works

All employees, including volunteers and sub- contractors encouraged to report suspected or actual acts of

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility hunting/killing of wild animal by a fellow worker

Disciplinary measures Contractor During NAWEC/PIU/TAC Contractor’s must be applied works budget The Guinea Baboon Contractor/DP During NEA/PIU/TAC Contractor’s population must be WM works budget/PIU protected by:

Enforcing more vigorously the relevant laws and regulations that prohibit hunting

Conducting training and information meetings on its preservation and protection at community level at least once every quarter

Creating community wildlife reserves where threatened species such as the baboon could be protected Nesting grounds and Contractor Before, NAWEC/PIU/TAC - migratory paths, if any, during and are to be protected after works

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility Develop and implement NAWEC/PIU/DO Before, DOF For RAP tree replacement plan, F during and budget with 1:2 replacement after works ratio Soil compaction from Use only approved and Contractor During TAC/Communities - vehicles / machinery existing routes works destroying farmland and Do not establish new Contractor During TAC/Communities - causing erosion routes works

Grade existing routes to Contractor During TAC/Communities Contractor’s improve surface works budget drainage Destruction of cultural, Inform relevant parties NAWEC/PIU/ Before and NEA, NCAC - historical or of the Chance Find Contractor during archaeological sites Procedures and apply works where applicable Avoid the two mosques Contractor Before and TAC/Communities - in Laminkoto and during Karantaba respectively, works and the cemetery at Karantaba, or similar sites of religious or cultural importance Consult with community Contractor Before and TAC/Communities - to help identify any during other culturally or works spiritual sites of importance

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility Loss of livelihoods (e.g., Prepare RAP NAWEC/PIU Before TAC (to be For RAP rangeland, firewood, etc.) beginning coordinated by budget of works the NEA) During all land Noise and vibration Integrate ESMP into Contractor In contract TAC/Communities - preparation and nuisance, and air Contract Bidding before construction pollution from dust and Documents to ensure works and activities including hydrocarbon noncompliance by during establishment of combustion emissions Contractor works base camp(s) Works shall only be Contractor In contract TAC/Communities - carried out during before daytime works and during works Use dust suppression Contractor During TAC - measures such as works dampening Provide masks and Contractor During TAC Contractors’ necessary gear to works budget workers with the aim of preventing dust related health problems and other dust nuisances Use well-serviced Contractor During TAC Contractor’s equipment and works budget machinery; avoid overloading that strains the engines Wet road surfaces to Contractor During TAC Contractor’s depress dust works budget Trucks transporting sand Contractor During TAC Contractor’s and gravel must be works budget

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility covered to prevent dust and flying debris Ensure that vehicles’ Contractor During TAC Contractor’s engines need not idle for works budget prolonged periods unnecessarily Ensure the maintenance of machinery and vehicles periodically

Special care will be taken Contractor During TAC Contractor’s when working near works budget educational institutions and health centers such as:

Giving prior notice to the institution about the works

Cordoning off work sites to prevent access

Working during weekends when activities are less around these institutions Put in place security measures such as

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility suitable signage, awareness sessions and flag man to regulate traffic as needed Reduction in water Protect water sources Contractor, During TAC, DWR - quality of the Sandugu and report any communities works Bolong due to noticeable reduction in construction works quality Avoid storing dangerous products near bodies of water Ensure the establishment of retention to avoid pollution of the water table Improper management of Develop a waste Contractor Develop NEA Contractor’s wastes (solid and management plan plan before budget liquid/used oils, machine including types of waste, works, and parts, and domestic and expected quantities and implement sanitary waste, excess frequency, proposed during materials left on sites, storage and disposal works cement bags, etc. procedures and responsibilities, etc. Waste must be collected Contractor During NEA - and stored for disposal works or treatment at approved sites as per waste management plan

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility Clean waste such as Contractor During NEA - cleared vegetation, works packaging and rubble shall be given to workers or communities for reuse and recycling Manage wastewater in Contractor During NEA - accordance with works international standards such as IFC EHS Guidelines, and the national Environmental Discharge (Permitting) Regulations 1999, and the Environmental Quality Standards Regulations, 1999 Ensure waste NAWEC/PIU In contract NEA - management issues are before incorporated in works and Contractor’s Contract during works Unpleasing landscape and Remove excess and Contractor During NAWEC/NEA - impact on aesthetics unused materials and works equipment from work sites Replace lost vegetation NAWEC/PIU During and TAC RAP budget cover after works Risks to public health and Restrict and monitor Contractor/com During the NAWEC/PIU - safety at construction public access to the work munities works sites (pole sites, quarries, sites

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility camp sites, etc.) Construction works Contractor During NAWEC/NEA - imported diseases, dust, within the Loumo area works and noise etc.) on a market day must be avoided

Cover up the trucks, to Contractors In contract TAC Contractor’s prevent wind blowing before Community budget away sand and gravel to works and generate dust during works Initiate sensitization and NAWEC/PIU In contract NEA, From the education programs on Contractor before TAC, Labor capacity the dangers and works and Department building mitigation measures to during budget address STIs, including links with SEA/SH and prohibited behaviors under code of conduct

Encourage use of condoms to prevent STIs, ensuring simultaneous sensitization on links with SEA/SH and prohibited behaviors under code of conduct Contractor Before and TAC, Department Contractor’s Carry out active during of Health Services budget monitoring of workers works (screening, testing and analysis of such recorded

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility data, etc.) to take timely action through treatment and health education to prevent spread of diseases

Ensure surroundings are Contractor Before and TAC/Department Contractor’s safe and secure for all, during of Health Services budget including provision of works sex-segregated, well-lit, secure, and lockable sanitation facilities for personnel (implement health and safety plan, coordinate, inform, supervise and monitor) Risk of SEA/SH and VAC Enforce with signature Contractor Before and TAC, Department Contractor’s and monitor codes of during of Health Services budget conduct for workers and works all those involved in the project, ensuring that the codes outline prohibited SEA/SH conduct, including child labor, and applicable sanctions Sensitize about the Contractor Before and TAC, Department Contractor’s codes of conduct and during of Health Services budget SEA/SH for workers and works community members,

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility including prohibited conduct, applicable sanctions, and GM complaint procedures Conduct periodic Contractor Before and TAC, Department Contractor’s training of workers on during of Health Services budget the codes of conduct, works prohibited behaviors, applicable sanctions, and GM complaint procedures for handling SEA/SH claims Ensure survivor-centered Contractor Before and TAC, Department Contractor’s approach to address during of Health Services budget SEA/SH complaints by works setting forth specific procedures under the GM, including a response protocol, to manage SEA/SH claims ethically and confidentially Ensure that worksites Contractor Before and TAC, Department Contractor’s have sex-segregated during of Health Services budget sanitation facilities and works lodging that are well-lit, secure, and lockable Ensure that the above Contractor Before and TAC, Department Contractor’s mitigation measures are during of Labor budget included in contract and works bidding documents, including a SEA/SH

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility Prevention and Response Action Plan for the contractor Risks to health and safety Provide induction and Contractor/PIU Before and TAC/Labor Contractor’s of workers (work related training on the job, NAWEC during Department budget stress, heat stress, safety issues and other works electrocution, falls, relevant ESMP mechanical accidents, requirements human conflict, wildlife Sensitize and train Contractor Before and NAWEC/TAC Contractor’s attacks, poor handling workers on interpersonal during budget techniques, diseases relationships between works etc.). and among workers and community members, including prohibited behaviors related to SEA/SH; set and enforce codes of conduct that outline prohibited conduct and applicable sanctions Provide appropriate gear Contractor Before and NAWEC/TAC Contractor’s (helmets, masks, safety during budget goggles, hand gloves and works rubber boots, etc.) to workers Provide first aid kits and Contractor Before and NAWEC/TAC Contractor’s training on their use during budget works Ensure that worksites Contractor Before and NAWEC/TAC Contractor’s have sex-segregated during budget sanitation facilities and works

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility lodging that are well-lit, secure, and lockable Ensure GM for workers Contractor Before and NAWEC/TAC Contractor’s to report incidents, during budget including SEA/SH, in works order to address causes for preventing recurrence and ensuring accountability QUARRY SITES Quarrying for Quarrying impacts on Ensure approval is NAWEC/ In contract NEA/Geology - earth materials geology, landscape, obtained from the NEA, Contractor before Department (gravel/sand) ground water, wildlife GD for all proposed works and agriculture, etc. quarry sites During works Fully implement the Contractor During NEA/Geology - mine management plans operation Department of quarries All quarry pits created by Contractor After works NEA/Geology Contactor’s’ the project must be are budget rehabilitated after completed construction works

Indirect water Avoid mining to the Contractor During NEA/Geology - contamination by water table and near operation Department exposure of groundwater surface water bodies of quarries from over extraction Decommissioning/ Sites open to illegal Proper closure and NAWEC/ After NEA/Geology - closure of quarries exploitation after the timely restoration and Contractors mining, Department Project rehabilitation of borrow before end pits of works

Activity / Issue Potential Negative Proposed Mitigation Mitigation Mitigation Monitoring Budget (USD) Impacts Measures Responsibility Period Responsibility Monitor sites and report Communities After NEA/Geology - illegal activities mining or Department quarrying for gravel and sand by the Project Dismantling and During As per the construction Contractors During TAC/NAWEC Contractor’s transportation of decommissioning, all phase for mitigation of decommissi budget materials and potential impacts on public and worker health oning equipment from public and occupational and safety; the camp(s) health likely during construction, are also significant Poor aesthetic quality Implement Waste Contractors During TAC/TAC/NAWEC -Contractor’s from excess materials Management Plan decommissi budget and waste abandoned oning on camp sites Risk of fires and Remove all fuel storage Contractors During TAC/NAWEC - explosions from facilities decommissi abandoned fuel oning facilitates Total 35,000.00

ESMP IMPLEMENTATION AND MONITORING ARRANGEMENTS

Roles and Responsibilities for ESMP Implementation Implementation of this ESMP is the responsibility of the Contractor and PIU. Most of the mitigation measures as indicated in Chapter 7 are the responsibility of the Contractor who will be carrying out the works according to the C-ESMP that will be based on the project ESIA/ESMP.

The GERMP/PIU will be responsible for overall follow-up, and to ensure that the ESIA/ESMP will be fully implemented with the support of the PIU environmental and social specialists. Specific mitigation measures to be implemented by the GERMP/PIU are inclusion of clauses in the Contractors’ agreements to ensure compliance, ensure development of the RAP, and coordination of the GM, among others.

However, communities will also have a responsibility of ensuring villagers avoid work sites and report, to NAWEC, issues of concern related to the Project, although PIU and contractor will engage the community regularly as an oversight measure in this regard, and conduct sensitization sessions to ensure communities are aware of reporting measures and understand project risks.

As the Secretariat of the EIA Working Group1, and supported by its members, NEA will be responsible for overall external monitoring of the ESMP implementation regarding the environmental aspects in collaboration with the PIU environmental and social safeguard specialists, monitoring compliance with the Banks’ policies as they relate to the environmental aspects of this project. In addition to the permanent members, in the EIA Working Group, other institutions on ad hoc basis will include those specialized in social aspects such as the Women’s Bureau, Department of Social Welfare, Department of Labor, and Department of Health Services amongst others.

Meanwhile, monitoring implementation of the social aspects of the project in line with the Banks’ safeguard instruments will be the responsibility of the PIU social safeguards specialist.

NEA will also provide technical support and participate in training and sensitization of stakeholders to enhance understanding of the national and the environmental and social safeguard instruments of the WB and EIB. Technical advice and/or regulatory information and support will also be provided by the Department of Forestry (DOF) for all forest related issues; the Department of Physical Planning and Housing (DPPH) and the Department of Lands and Surveys (DLS) will be responsible for addressing resettlement issues.

The Local Authorities and potential PAPs will be relevant during the preparatory stage of the works, as they can provide valuable information to assist in the planning of the works. Below is the breakdown of the institutional arrangement in ESMP implementation.

1 The EIA Working Group is one of nine multisector technical groups located at NEA. Nationally, NEA is the custodian of the ESIA process, and is supported by a multisector EIA Working Group which comprises the public sector, private sector and civil society, and at the Regional level, it is represented by the EIA/ANR (Agriculture and Natural Resources) Working Group sub committees of the Technical Advisory Committees (TAC). A major responsibility of the EIA Working Group (whether at central or regional level), is to provide support to the NEA in assuring the quality and integrity of the EIA process. Specifically, it:

• Provides expert advice on the EIA process and review impact statements and ESMPs upon receiving requests • Approves impact statements and ESMPs • Conducts periodical environmental audits • Ensures that public consultations as part of the EIA process are done

Budget for Implementation of ESMP

The proposed budget for implementation of the ESMP is USD 65,000 as indicated in the following Table. Estimated Budget to Implement the ESMP No. Activity Time Frame Budget Responsibility (USD) 1 Capacity Building Workshops and Once every 4 months 15,000 NEA/PIU/ESS/SSS meetings to strengthen during project the capacity of TACs in implementation managing ESIA and RAP Public sensitization to Month 3 of project 2,000 NEA/PIU/ESS/SSS raise awareness on the implementation Project issues (such as project risks and benefits, developments, progress, SEA/SH and GM etc.) through relevant radio programs and meetings GBV service-mapping 60 days x 300 18,000 PIU/ESS/SSS and other relevant measures under SEA/SH Prevention and Response Action Plan 2 ESMP Implementation, Monitoring, Evaluation and Reporting Regular monitoring of Project implementation 5,000 NEA/PIU Project sites and period activities ESMP implementation of Before and during 10,000 Contractor mitigation measures construction Operation of GM Site visits and Project implementation 10,000 GRC consultations/GRC period meetings ESMP implementation of During operations and 5,000 NEA/PIU mitigation measures maintenance annually 65,000 TOTAL

CHAPTER 1: INTRODUCTION AND BACKGROUND

1.1 Project Background This report is the Environmental and Social Impact Assessment (ESIA) of the proposed Medium Voltage (MV) Transmission and Distribution (T&D) line and other ancillary services along the Laminkoto- Diabugu Batapa road corridor in the Central River and Upper River Regions. It was prepared by Sustainable Development Focus (SD Focus) Ltd, a Gambian registered environment and natural resources consultancy firm. The ESIA study of the proposed line routing and branches is based on the Consultant’s Contract Terms of Reference. No pre-feasibility studies were provided and is therefore important that once the Contractor for the works has been selected, a Contractor’s ESMP (C-ESMP) be prepared based on this study findings; the C-ESMP should be cleared by GERMP/PIU and reviewed by the World Bank before the start of construction. The proposed works are a sub-component of the Gambia Electricity Modernization and Restoration Project (GERMP). The GERMP is a $121 million multi-donor funded project involving the World Bank (WB), European Union (EU) and the European Investment Bank (EIB). The WB and EIB are financing this sub-component, and therefore, this ESIA is based on the World Bank Operational Policy/Bank Procedure (OP/BP 4.01) (Environmental Assessment), EIB’s Environmental Social Standards (ESS 1) (Assessment and management of environmental and social impacts and risks), as well as the relevant national policies. 1.2 Project Development Objective The development objective of GERMP is to improve the operational performance of NAWEC, by improving its power generation capacity and efficiency of its transmission network in order to increase access to electricity for socio-economic development.

1.3 Rationale for the ESIA Implementing the project activities are likely to generate negative impacts (physical, biological and/or social) including loss of vegetation and deforestation, soil erosion, wildlife and biodiversity, social conflicts, health, and safety risks, and perhaps land use.

The rationale for preparing an ESIA along this corridor is to evaluate and mitigate the potential environmental and social risks and impacts that the construction activities will cause. The process will involve examining ways to prevent, minimize, mitigate, or offset/compensate for adverse impacts, and to enhance positive impacts throughout project implementation. This will enhance sustainability throughout the lifecycle of the project and beyond.

An Environmental and Social Management Plan (ESMP) which addresses and mitigates the risks and impacts is included in Chapter 7. The ESMP will specifically identify specific mitigation measures, costs, and responsibilities for mitigation and monitoring. Importantly, the National Environment Management Act (NEMA), 1994, requires that an ESIA and an ESMP must be prepared to guide the implementation of the project activities. The general framework for the assessment and management of environmental and social safeguards of developments projects in the Gambia is provided in the NEMA, 1994, the EIA Guidelines and EIA Procedures of 1999, and the EIA Regulations, 2014.

1.4 Methodological Approach The stakeholders of this Project were identified after undertaking literature review and preliminary consultations. Consultative meetings were held with stakeholders and institutions including residents of communities along the Project corridor. Annex 1 indicates the list of institutions and persons met, and Annex 2 shows the comments, views and concerns expressed during the consultations.

Specifically, the following approach was used to develop this report:

a) Literature Review This consisted of the review of relevant legislation and project documents, including the GERMP Environmental and Social Management Framework (ESMF) and socio-environmental assessments similar to this project. b) Field Visits and Community Consultations Field visits to the proposed transmission route and community consultations were undertaken using mainly unstructured methods; these included group discussions, and individual (one-to-one) meetings to:

• discuss the project with project beneficiaries and other stakeholders regarding its potential positive and negative impacts

• provide information about the project, and to acquire key social information, including schools, health, and other social facilities along the corridor

• facilitate inclusive participation of community members on the project so that they can voice their concerns and views about the design, project impacts, and to ask questions

• highlight potential roles and responsibilities of the various stakeholders, including community members; their expected roles and responsibilities during both the baseline survey period as well as in community-level monitoring of ESMP implementation, which is one way of enhancing their participation and promote sustainability in the project

• understand community dynamics, relations, and broader social and economic context of the communities viz-a-viz the possible impacts of this project c) Key Stakeholder Interviews and Consultations Consultations and interviews with relevant Government agencies, including NAWEC, NEA, Department of Forestry (DOF), Office of the Regional Governors of CRR and URR and other partner institutions, were undertaken to discuss their respective policy and legal mandates as they relate to the Project. This has enabled the definition of their potential roles and responsibilities in the implementation of the ESMP.

CHAPTER 2: OVERVIEW OF THE GERMP

2.1 Components of GERMP The investments financed by the GERMP are being implemented under 3 components which have potential safeguards impacts; these are:

Component 1: On-grid solar PV This will finance a 20MW solar PV plant on a 31ha plot of land situated in the village of Jambur in West Coast Region (WCR).

Component 2: Transmission and Distribution (T&D) Upgrades This sub-project essentially falls under this component, and thus, the focus of this ESIA. In addition, the component will upgrade the existing T&D network to:

• absorb the additional generation capacity • prepare for future capacity expansion including OMVG and other pipeline projects • reduce T&D losses • enable future grid extension

Component 3: Institutional Support: This will involve institutional strengthening, such as building capacity and providing project implementation support related to improved operational performance of NAWEC. This aspect includes:

i). twinning with the University of The Gambia ii). study tour to review environmental and social management systems in other power utilities iii). short-term course on environmental and social management.

2.2 Sub-Project Description and Location Covered by this ESIA The proposed route of the transmission and distribution line is along the Laminkoto-Passamas road corridor in the northern bank of The Gambia, and it extends for 57km, terminating in Diabugu Batapa, (see Figure 4.1 below). The proposed line spans the Districts of Sami in Central River Region (CRR), and Sandu in the Upper River Region (URR). The trajectory of the line will follow the road alignment, connecting the intermediate communities between Laminkoto and Diabugu. Additionally, T-offs (lines branching off from the main road) will be created where necessary, and lines will be constructed to connect communities located away from the main road alignment. Some of the lines branching off from the main road would run through farmlands to supply the communities with both Medium Voltage (MV) and Low Voltage (LV) electricity. A total of 46 communities would be connected along these transmission corridors. Figure 2.1: Location of Sub-Project

The CRR is the second most important region after the WCR in terms of electricity consumption, with a population of 185,500 inhabitants. However, there is no electricity power supply between Laminkoto and Diabugu Batapa; creation of the new MV/LV lines between these two communities will be a vital link, completing the network loop in CRR north, and connecting the Bansang and Basse networks. Whilst the substation in Basse is currently supplying Diabugu Batapa, the substation in Bansang will serve Laminkoto, and this will promote the development of small businesses and improve livelihood in general along this corridor. Basse Local Government Area (LGA) in URR has a population of 240,000, represents the largest electricity consumers in the north bank of Basse.

2.3 Technical Components of the Project Characteristics of the proposed transmission network will include an operating voltage of 30kV covering 105Km of line connecting Laminkoto and Diabugu Batapa and surrounding communities via some branches, about 41 transformers (100kVA -160 kVA) mounted on steel poles. The transformers are used to transform electric power from MV (30kV) to the LV (415-volt (V) distribution system which is appropriate for use in private compounds and homes.

Movement of MV power will involve the use of transmission lines which consist of steel wires, cross bars, insulators, and conductors. The standard right of way (ROW) width for transmission lines is 6m (3m on each side of the centerline)2; the required setback from nearest structures is 2m horizontal. There is no approved vertical setback; therefore, the lines cannot be constructed over existing structures.

2 A 3m right of way is the international standard for a 30kV line which is adequate from a safety perspective.

During the planning and construction phase

• Preparation of a detailed design for the project (including location of structures along the route and contractor base camp) • Land clearing of vegetation to install base camp, park equipment and machinery for the works and erect poles; felling/pruning of trees, digging foundation trenches, etc. • Transportation of the various project components to the various work sites and locations • Stringing and connecting the lines unto the poles

During the operations phase

• Management of the electricity production • Periodic clearing of vegetation and pruning of trees that have regrown

During the decommissioning phase

• Dismantling of base camp and installations • Transportation of equipment and materials away from pole and base camp sites • Management of disused elements and the pole sites • Reconditioning of quarries and affected sites

2.5 Assessment of Project Alternatives

Alternative Project Sites Extension of electricity to the Districts of Sami and Sandu is in line with NAWEC’s policy goal of supplying electricity to all parts of the country in phases, especially in the face of resource constraints. Thus, it plans a gradual expansion of electricity coverage in the country, as resources become available, until it attains its ultimate objective of reaching universal access to electricity. It is based on this plan that the two Districts have been selected for coverage under the GERMP, and with the availability of additional transmission capacity, NAWEC will consider other parts of the country for connection.

Thus, along this corridor, it is expected that developments in power supply can improve the foundation for job creation, including for those who are vulnerable and disadvantaged such as women, and in the process contribute to the national goal of poverty reduction and boosting shared prosperity.

The choice of the routing of the T&D lines could be on either side of the road alignment because the right of way (ROW) for the road alignment has already been established on both sides of the road by

the road contractor. Thus, either side of the road provides an established ROW for the T&D, which will reduce the environmental footprint of the project since the transmission lines will be located within the current ROW.

Any other alternative routing away from the ROW (on either side of the road alignment) would potentially encroach into virgin land and/or forest and vegetated areas including some Community Forest Parks which are located further back away from the ROW. Creating another ROW to accommodate the lines will entail more vegetation and forest clearing, as well as impacting settlements through which the lines will pass. Thus, the project’s social and environmental footprints will be lesser along the existing ROW than an alternative routing.

• The left side has fewer trees likely to be impacted as compared to the right side which has some indigenous protected species such as the baobab, and several Community Forests

• The right side has more communities likely to be impacted; several private properties are less than 5 meters from the edge of the road, whilst the communities on the left of the road from Laminkoto can be by-passed

The “No Project” Alternative Under a “No Project” alternative scenario, the environmental and social adverse impacts from the project will not occur. However, project benefits are expected to outweigh potential adverse impacts. The positive impacts of the project, as discussed in Chapter 6, will enhance the socio-economic development of the country, enhance access to electricity services to communities, and improve livelihoods and social development outcomes.

Specifically, without continuous electricity supply in the Sami and Sandu Districts, the youth would not be able to develop skills and trades such as welding, carpentry, or other small businesses that rely on electricity to enhance their livelihood. In addition, women would not be able to produce ice blocks and cold drinks made from locally available plants such as “wonjo”, which are few of the livelihood activities they wish to undertake.

CHAPTER 3: RELEVANT NATIONAL POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORKS

This section describes the various national policies, legal and institutional frameworks that will guide the development and implmentation of the report. The relationships and relevance of the policies and legal frameworks viz-a-viz the project are indicated in the following tables.

3.1 Relevant National Policies Table 3.1 shows the relevant national policies that will guide the development and implementation of this project.

Table 3.1: Relevant National Polices Policy Description Relevance to the Project Gambia Environment Integrated environment Provides guidance in general Action Plan, GEAP (2009- and natural resources environmental planning and natural 2018) management resources management National Energy Policy Policy aims to increase All national electricity projects are (2014 – 2018) electricity coverage implemented within the context of this nationally Policy National Strategic Aims to ensure Applies when developing policies, plans Environmental environmental or programs in all sectors, including Assessment Policy (2017- sustainability energy 2021) National Climate Change Policy provides the Promotes energy efficient options Policy (2016 – 2025) framework for managing climate risks, building institutions, capacities, and opportunities for climate- resilient development The National Health Protects public and Relevant to this Project since dust, noise Policy, 2012-2020 environmental health and other risks can be associated with including nuisance and the Project other risks associated with this Project Forestry Policy (2010-19) Promotes state and Three Community Forests close to the community forest Project study area development and management National Policy for the Policy provides a legitimate Relevant to this project since project Advancement of Gambian point of reference for will benefit both men and women Women and Girls (1999- addressing gender equitably 2009) inequalities at all levels of government and all stakeholders Gambia National Gender To mainstream gender in Women will be consulted widely and & Women Empowerment national and sectoral will be involved in the local monitoring Policy (2010–2020) planning and programming and evaluation process during project to ensure equity and implementation equality

National Development Policy proposes to increase Laminkoto-Diabugu corridor is Plan (2018-2021) the national coverage of prioritized electricity National Youth Policy Policy aims to mainstream Successful project implementation will (2009–2018) youth issues into the encourage youth engagement in skills advancement of all sectors to reduce youth underemployment National Transport Policy, Defines the priorities and The Laminkoto-Passamas and Kalem (2018-2027) objectives in the transport Jawbeh-Bush Town road corridors are sector, aimed to serve the the site of the project country’s development goals

3.2 Legal Framework Relevant to the Project Table 3.2 indicates the relevant legal framework that will guide the development and implementation of this Project.

Table 3.2: Legal Framework Relevant to the Project Legislation Description Relevance to the Project National Environment Principal legislation in This Project falls under Management Act, 1994 environmental management; Schedule A which requires an Part V of Act provides for ESIA certain projects listed under Schedule A to be considered for ESIA Environmental Impact The EIA Regulations elaborate The Regulations provide more Assessment Regulations, 2014 on the requirements for EIA details for the ESIA of this procedure, environmental Project and implementation of impact statements, approval, its ESMP environmental monitoring, etc. Local Government Act, 2002 Act makes provisions for Implementation of the Project decentralized administrative will require the participation of structures including devolution decentralized institutions of functions, powers and including the Offices of the duties to local authorities Governors of CRR and URR as well as their respective Technical Advisory Committees (TACs) The Forest Act, 2018 Provides framework for Three nearby Community implementation of Forestry Forests may potentially be Policy, and framework for the affected by the Project reservation and management of forests Physical Planning and Act ensures that developments The Project’s construction and Development Control Act, are in line with land use location of facilities should be 1991 planning and development in line with national planning Control Regulations rules Public Health Act, 1990 Protects public and Relevant to Project since dust, environmental health including noise and other risks can be abatement of nuisances and associated with the Project any condition that may be injurious to health Labor Act (2007) Provides the legal framework The project hiring and for administration of labor, management of its labor force recruitment and hiring of should adhere to this labor, and protection of wages framework

The Children’s Act 2005 Act sets out the rights and Rights of children impacted by responsibilities of children and the project need to be provides for their care, protected protection, and maintenance The Women’s Act 2010 Aims to advance women’s Relevant to this project in view rights to land and natural of potential impact on

resources in order to promote agricultural land farmed by their economic and social women; need for adherence to empowerment OP 4.12 Hazardous chemicals and Act provides framework for the Relevant in this Project in view pesticide control and manufacture, importation and of the potential for farmers to management Act 1994 use of hazardous chemicals use pesticides on their farms and pesticides

Environmental Impact The EIA Regulations elaborate The Regulations provide more Assessment Regulations, 2014 on the requirements for EIA details for the EIA of this procedure, environmental project and implementation of impact statements, approval, its ESMP environmental monitoring, etc. Electricity Act, 2005 Promotes the development of Electricity service providers the electricity sub-sector on such as NAWEC, are also the basis of the principles of a regulated by this Act competitive and market- oriented economy Anti-littering Regulations, 2007 Addresses waste management The project must ensure that and pollution issues in relation all waste produced during all to environmental health and phases is well managed hygiene Environmental Quality Regulations declare standards Project implementation has Standards Regulations 1999 set out in Schedule 1 in respect potential to generate dust, and of ambient air, saline waters, to pollute the Sandugu Bolong surface fresh waters and groundwater Environmental Discharge Regulations require that a Project implementation has (Permitting) Regulations 2001 permit be obtained for most potential to discharge discharges of potentially potentially polluting liquids polluting liquids in to or onto into the Sandugu Bolong the ground (i.e. to groundwater) or into surface waters (such as rivers or streams) Gambia Roads Technical Act created the National Roads The project will be Services Authority Act, 2003 Authority to be responsible for implemented along the the maintenance, construction, Laminkoto-Passamas and and safety of the national Kalem Jawbeh-Bush Town roads roads alignment Lands (Regions) Act, 1945 Regulates land tenure and All lands in both CRR and URR property rights as well as including project sites are held general land administration in and administered under this areas under Customary Land Act Tenure system. Act covers all Provinces land outside State lands Areas Land Acquisition & Provides for consultation, Project might cause Compensation Act, 1990 resettlement, and involuntary resettlement due compensation of land to certain project activities such as tree felling, destruction

of crops during line stringing

Physical Planning and Ensures developments in The The project construction Development Control Act, Gambia are in line with land activities shall be in line with 1991 use planning and construction national landuse and planning standards rules Development Control Regulations prescribe the All planning and construction Regulations, 1995 requirements for development phases of the project should control be considered The Gambia Public Utilities Act regulates the activities of NAWEC, the proponent of this Regulatory Authority Act, 2001 providers of certain public Project will be regulated by utilities in the various this Act economic sectors, including electricity, petroleum, and gas Act makes provision for pole construction during Mines and quarries Act, 2005 prospecting for minerals, for project implementation carrying out mining and involves use of sand and gravel quarrying operations including aggregates mined along the gravel, sand, and for road corridor connected matters National Centre for Arts and The NCAC Act was passed in It is relevant to the Project as Culture (NCAC) Act, 2003 1989 (amended 2003) to there are sites of cultural establish the NCAC with the significance, particularly responsibility “to preserve, mosques and a cemetery, promote and develop Gambian within the area of interest arts and culture”. It is responsible for both tangible and intangible cultural heritage and the conservation of historic monuments and cultural sites

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

Table 3.3: Relevant Regional/International Signed/Ratified by The Gambia Agreement/Convention Objective Relevance to Project ECOWAS Energy Protocol Promotes energy This Project prepares for future capacity A/P4/1/03 (2003) investment and trade in expansion to accommodate regional West Africa projects such as those of the OMVG United Nations Possible loss of Land clearing and potential burning in Convention on Biological trees/vegetation and preparation to install base camp, poles Diversity (CBD) 1993 dependent biodiversity and other infrastructure will impact current biodiversity along the corridor Convention to Combat Protection of forests to Land clearing and potential burning in Desertification (CCD) avoid desertification preparation to install power 1994 infrastructure

UN Framework Relates to all energy The loss of trees and vegetation will Convention on Climate projects with regards to mean loss of “green cover” and loss of Change (UNFCCC) 1994 sustainable sourcing carbon capture footprint

United Nations Convention ensures the full Project has potential for resettlement Convention on the development and as a result of project activities, Elimination of all Forms advancement of women, especially on farmlands cultivated by of Discrimination Against for the purpose of women; the Convention highlights the Women (CEDAW) 1979, guaranteeing them the right of women to own, manage, and the Optional Protocol exercise and enjoyment of enjoy and dispose of property is to the Convention on the human rights and central to their financial Elimination of All Forms fundamental freedoms on independence and may be critical to of Discrimination against a basis of equality with their ability to earn a livelihood and Women (OP-CEDAW) men to provide adequate housing and 2000 nutrition for themselves and for their children; women should have access to benefits of this project as men UN convention on the The rights in the treaty The project could potentially affect the rights of the child, (Unicef include the right to right to health of the child through the 1989) education, the right to generation of dust, and air pollution, play, the right to health poor waste management, and spread of and the right to respect for malaria due to stagnant water in quarry privacy and family life pits Convention on the rights The Convention intends to Persons with disabilities could of persons with protect the rights and potentially be impacted negatively by disabilities (CRPD) 2006 dignity of people with the project activities disabilities; to promote, protect, and ensure the full enjoyment of human rights by people with disabilities The Stockholm Convention aims to protect Relevance to the project in view of the Convention on Persistent human health and the presence of the industrial chemical Organic Pollutants (POPs) environment from (polychlorinated biphenyls (PCBs) in 2001 chemicals, known as POPs, transformers used by NAWEC which have harmful impacts on human health or on the environment. The Convention Convention aims to identify Project implementation could Concerning the and protect the world’s potentially impact natural or cultural Protection of the World's natural and cultural sites such as graves, mosques, or other Cultural and Natural heritage considered to be cultural relics Heritage (1972) of outstanding universal value

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

Table 3.4: Institutional Framework Institution Responsibilities Ministry of Petroleum and Energy The MOE is the overseeing institution of NAWEC and all (MOPE) energy related projects Ministry of Environment, Climate Oversees the NEA and implementation of environmental Change and Natural Resources laws and policies of The Gambia Ministry of Lands and Regional Oversees all the local government authorities and enforces Administration all legal regulations on land administration and land use. Its regional representatives are the TACs located in the offices of the Regional Governors. The TACs will support the implementation and monitoring processes of the Project at Regional level Ministry of Health and Social Responsible for overall formulation and direction of the Welfare national health agenda, planning and health infrastructural development. Oversees the potential beneficiary health facilities of this Project National Water and Electricity As the implementing arm of the MOE, NAWEC is the main Company (NAWEC) operator and manager of electricity production in The Gambia; it is the executer of this Project Public Utilities Regulatory PURA is a multi-sector regulator of utilities in The Gambia Authority (PURA) mandated to regulate electricity amongst others Department of Forestry (DOF) Responsible for the maintenance and development of forest resources in The Gambia. It recommends sites for forest reserves and parks, community forests and private forests, and monitors their management for sustainability Office of the Governor, CRR Oversees the Regional Technical Advisory Committee (TAC) for CRR Office of the Governor, URR Oversees the Regional Technical Advisory Committee (TAC) for URR National Environment Agency The NEA enforces the NEMA,1994 and EIA Regulations 2014 (NEA) Department of Physical Planning Responsible for the preparation and implementation of and Housing Physical Development and Land Use Plans as well as control and coordination of land development and land use at national, district and local levels

Department of Women Affairs In charge of the promotion and advance of women’s rights in order to promote their economic and social empowerment.

3.5 Relevant Bank Policies The following environmental and social safeguard policies of the funders outlined in Tables 3.5 and 3.6 below have been triggered by the Project.

Table 3.5: World Bank Environmental and Social Safeguards relevant to the Project World Bank Safeguards Triggered Remarks Operational Procedure (OP) OP 4.01 Environmental Yes Preliminary evaluation (literature reviews, etc.) has Assessment (including identified potential negative environmental and social public participation and impacts, thus, there is need for environmental stakeholder engagement) assessment to ensure appropriate mitigation measures are put in place during all stages of the Project OP 4.11 Physical Cultural No No sites of cultural or historical significance will be used Resources for or affected by the Project. Nonetheless, Chance Find Procedures are described in case of any discovery OP 4.12 Involuntary Yes There is likelihood of resettlement or loss of agricultural resettlement of land, temporary loss earnings, etc. as a result of the populations Project. A separate resettlement policy framework has not been prepared OP 4.36 Forests Yes There are Community Forests along the project corridor that are home to various invertebrates, mammalian, including avian fauna, that may be affected by the project

Table 3.6: EIB Environmental and Social Standards Relevant to the Project EIB Environmental and Social Applicable Remarks Principles and Standards to Project ESS 1 Assessment and management of Yes The need for environmental assessment environmental and social Impacts and confirmed due to initial potential risks negative impacts identified ESS 2 Pollution Prevention and Yes Potential pollution mainly from waste Abatement generation and limited, localized air pollution during pole construction works. Mitigation included in overall ESMP ESS 3 Standards on Biodiversity and Yes Community Forests fall within the study Ecosystems area and shall be considered in the ESIA ESS 4 Climate-related Standards Yes The loss of trees and vegetation will mean loss of “green cover” and loss of carbon capture footprint ESS 5 Cultural Heritage Yes Sites of cultural or historical significance will potentially be impacted (cemetery in Karantaba). Consequently, chance find procedures are described in case of any discovery of historical significance ESS 6 Involuntary Resettlement Yes There is likelihood of resettlement or loss of earnings resulting from project activities ESS 7 Rights and Interests of Vulnerable Yes The project shall consider specific interest Groups and vulnerable groups ESS 8 Labor Standards Yes Applies to all workers engaged by the project during all stages ESS 9 Occupational and Public Health, Yes There are potential health, safety, and Safety and Security security issues during all stages

ESS 10 Stakeholder Engagement Yes Important from design stages to promote project support and ownership, and for resettlement issues

3.6 Analysis of Gaps between Gambian legislation and Policies of the Banks

The main gaps between the Gambian legislation and policies / standards of the Banks relevant to this Project have been identified, including corresponding measures in addressing them as stated in Table 3.7.

Table 3.7: Main gaps between Gambian legislation and Policies of the Banks Safeguards / THE GAMBIA WB EIB Main Gaps Relevant to Addressing Gaps standards / this Project during this issues Project Pollution NEMA 1994 and OP 4.01 ESS2 The Banks encourage In addition to prevention Anti-littering waste management the local laws, and Regulations 2007 (Reference to hierarchy whilst the apply the Banks’ abatement the Pollution Gambian laws focus on policies and Prevention and general prohibition of standards for Abatement pollution. completeness as Handbook & Waste Bill drafted in 2007 outlined in the EHS not enacted yet to ESMP Guidelines,1.6 address specific waste on Waste management needs Management Stakeholder EIA Regulations OP 4.01 ESS10 The EIA Regulations Already applied Engagement 2014 (Part II, 16) highlight the need for during the ESIA public participation of process and shall interested and affected continue during persons during the ESIA project study, whist the Banks go implementation further to require stakeholder engagement throughout the project lifecycle. Involuntary Land Acquisition OP 4.12 ESS 6 As compared to the The Banks’ Resettlement and Compensation Banks’ policies, the policies and Act, 1991 national law does not: standards will be - provide for livelihood applied recovery - recognize those without legal title - legally require a RAP - prescribe for monitoring of the whole process

CHAPTER 4: DESCRIPTION OF THE BASELINE ENVIRONMENTAL AND SOCIAL CONDITION OF THE PROJECT CORRIDOR

The assessment of the project site was carried out in the dry season within a period of three days (22- 24 May 2019), a second round of consultation was held for 10 days to cover the areas added on the scope from 19 to 29 of September 2020. The methods used in the assessment of the baseline environment included the review of relevant literature and consultations with the Departments of Forestry and Parks and Wildlife Management.

Interaction with local community members also provided knowledge and information on the status of the project area, including the fauna and flora found within the corridor. Group meetings were held with community members in roadside “bantabas” or waiting sheds where the project and project benefits were explained to them particularly as stakeholders along the line corridor.

At the same time, the potential negative environmental, social, and economic impacts of the Project were highlighted, including possible loss of forest and vegetation cover; impacts of pole construction and line stringing on nearby farmlands, streams, and water bodies; persons losing their properties (parts of their farmlands, economic trees, etc.); and communities losing community structures, such as waiting sheds, located along the road alignment, etc.

During the discussions, they were encouraged to ask questions, or seek clarifications which they did, as reflected in Annex 2.

In addition, random physical walks were undertaken within the field along the proposed line corridor, and personal knowledge and experience provided more specific information in the assessment.

THE PHYSICAL ENVIRONMENT

Climate The Gambia has a Sudano-Sahelian climate with two distinct seasons: a hot rainy season from June to October, and a dry season from November to May with rare occurrence of rainfall. Rainfalls are typically heavy with July, August and September being the highest rainfall months usually accompanied by strong winds, heavy downpours and severe lightning flashes; October is the hottest month.

During the months of December to April, the Hamattan (North-easterly winds blowing from the Sahara towards the western coast of Africa) results in the presence of dust particles in the air, and general cloudless skies and dry air. Rainfall It will be recalled that the Project spans the two Regions of CRR and URR; the rainfall data indicated in Tables 4.1 and 4.2 were obtained from the meteorological offices located in CRR and URR respectively, and they show the annual and monthly mean rainfall in the two Regions from 2008-2017. The rainfalls were heavy, with July, August, and September being the highest rainfall months.

For the CRR, annual mean rainfall ranged between a low of 81.6mm in 2014 to a high of 159mm in 2008.

Table 4.1: Annual and Monthly Mean Rainfall (mm) in Janjangbureh, 2008-2017

Year Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec 2008 0 0.6 0 0 0.0 204.4 193.4 253.9 242.8 59.8 0 0 2009 0 0 0 0 5.7 27.3 99.4 206.1 313.3 3.4 0 0 2010 0 0 0 0 0.0 114.5 228.1 268.5 228.8 27.3 0 0 2011 0 0 0 0 63.0 47.9 141.4 226.3 145.8 65.0 0 0 2012 0 0 0 0 69.6 79.4 213.8 306.2 253.4 0.0 0 0 2013 0 0 0 0 2.3 141.6 269.2 232.1 346.3 48.3 0 0 2014 0 0 0 0 0.9 15 39.5 199.5 158.3 76.2 0 0 2015 0 0 0 0 0 47.4 114.6 310.9 209.8 114.0 0 0 2016 0 0 0 0 16.6 30.7 260.4 311.9 237.1 3.7 0 0 2017 0 0 0 0 0.0 156.4 177.2 391.8 30.5 57.4 0 0 Source: DWR, 2018

Table 4.2: Annual and Monthly Mean Rainfall (mm) in Basse 2008-2017 Year Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Mean 2008 0 0 0 0 11 126.1 177.5 295.7 256.4 43.1 0 0 224.4 2009 0 0 0 0 9.7 60.9 150.4 307.2 377.6 35 0 0 226.9 2010 0 0 0 0 0 83.9 397.7 285.2 255.7 93.9 0 0 240.5 2011 0 0 0 0 4.9 73 95.7 337.7 330.2 48 0 0 223.1 2012 0 0 0 0 52.9 95.5 101 261.1 240.2 57.3 0 0 216.9 2013 Tr 0 0 0 16.1 85.9 169.5 352.8 243.9 65.5 10.1 0 246.4 2014 0 0 0 0 25.9 121.4 228.4 214.9 187.4 40.2 0 0 217.9 2015 0 0 0 0 0 35.8 307.9 274.4 297.6 76 TR 2.3 250.7 2016 0 0 0 0 TR 82.5 193.1 354.3 254.2 5.9 0 0 242.2 2017 0 0 0 0 0 124.8 289.3 436.1 35 12.6 0 0 224.2 Mean 0 0 0 0 13.4 89 211.1 311.9 247.8 47.8 1.1 0.23 Source: DWR, 2018

Tr- Trace

Basse, like Janjangbureh experiences heavy rainfall especially in the months of July-September; during this period, the annual mean rainfall ranged between a low 216.9mm in 2012 to a maximum of 250.7mm in 2015.

Temperature Tables 4.3 and 4.4 show the monthly maximum temperature readings in Janjangbureh and Basse respectively during the period 2008-2017. For Janjangbureh, annual maximum mean temperature essentially hovered around 390C and 400C all through the period, whilst the monthly means showed a bit more variation ranging between a low of 34.50C in the month of August to temperatures between 41-440C in the months of February to May. The month of May recorded the highest (440C), with the months of March and April coming close at 42.90C and 43.30C respectively.

Table 4.3: Monthly Maximum Temperature (0C) in Janjangbureh - 2008-2017 Year Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Mean 2008 37 41 43 43.5 46.2 41.7 34.5 33.5 35.3 36 39.3 39.5 39.2 2009 39 41.8 42 44.5 42.5 43 38.4 35 35 39 39 39 39.9 2010 39.9 42.6 44 43.6 41 37.3 36.4 35 36.5 39 37.4 39.3 2011 37.4 41.3 42.8 42.8 45.3 40 36.5 35.1 34.5 37.4 39.6 37.5 39.2 2012 38.7 40.8 41.8 42.1 43.4 40.5 34.6 32.8 34.5 36 38.6 38 38.5 2013 38 40.6 44 42.5 38.5 40.7 2014 38.9 35.2 35 38.6 39 38 37.5 2015 37.2 40.6 41.9 44 43.2 40.6 37.8 34 34 35.4 37 36.2 38.5 2016 38.1 41.6 42.8 43.6 44.6 41.4 37.1 34.8 35 38.7 39.3 40 39.8 2017 38.6 40.7 43.6 43.2 42.8 41.6 34.8 33.6 36.6 38 36.6 38 39.0 Mean 38.2 41.2 42.9 43.3 44.0 41.2 36.7 34.5 35.0 37.3 38.6 38.2 Source: DWR, 2018

For Basse in URR, a similar picture is evident as in CRR; annual mean temperature readings were around 390C and 400C, but with variations in monthly readings between a low of 34.90C in August to a high of 43.90C in the months of April and May.

Table 4.4: Monthly Maximum Temperature (0C) in Basse- 2008-2017 Year Jan. Feb. Mar. April May June July Aug. Sept. Oct. Nov. Dec. Mean 2008 37.8 42.8 43.2 43.6 45.5 42.6 36.2 34.4 34.6 36.2 39 39.5 39.6 2009 38.6 41.5 42.5 44.2 43.3 43.6 37.2 35.5 35.6 37.5 38.2 39.5 39.8 2010 40.5 44 44.2 44.5 44.8 41.2 36.9 33.8 35.3 37.2 38.2 40 40.1 2011 39.6 41.3 43.6 43.5 43.8 42.5 37.5 39.2 35.3 37.2 38.9 39.2 40.1 2012 38.6 41.5 42.2 43.5 43.6 41.5 35.5 34.2 35.8 38 39.6 38.5 39.4 2013 39 41.5 44.6 44.5 43 40.7 35.8 34.6 35.4 36.2 39.2 38.4 39.4 2014 40 40.1 42.5 43.8 43.9 39.4 39.5 34.7 34.4 37.1 38.7 38.2 39.4 2015 37.9 40.3 41.4 44.1 43.6 41.2 38.2 33.6 34.7 36.6 38 35.6 38.8 2016 38.3 41.1 42.2 44.2 44.6 43 36.4 35 34.9 39 38.5 40.4 39.8 2017 38 41 45 43.2 43 43 35.3 34 35 39.5 35 39.5 39.3 Mean 38.8 41.5 43.1 43.9 43.9 41.8 36.9 34.9 35.1 37.5 38.3 38.9 Source: DWR, 2018

Topography As in many parts of the country, the topography along the corridor is generally flat and low-lying, and in view of this, certain areas are prone to receiving heavy storm water a nd run-off during the rainy season, which leads to severe erosion; this could affect stability and durability of poles.

Hydrology

Surface Water The surface hydrology within the Project’s sphere of influence is mainly the River Gambia, which gets its source from the Fouta Djallon Highlands in Guinea, flowing westward towards the Atlantic Ocean, via communities such as Basse, Diabugu, Janjangbureh, and Laminkoto.

A mosaic of numerous tributaries has branched off from the main river system and has become major areas of economic activity for the riparian populations through which the tributaries and streams pass. Parts of some of these water bodies serve as fishing areas for the local communities, cattle drinking and watering points.

In addition to the River Gambia, the other surface water source is the run-off and storm water during the rainy season which runs into tributaries and adjacent fields. The Sandugu “bolong” (over which the Sami Bridge crosses) is the only permanent surface water encountered along the transmission route.

Physical Structures: Compounds, Buildings, Schools and Other Infrastructure

Usually, NAWEC transmission lines are constructed along the road alignments, for the most part occupying a defined right of way (ROW) for the various categories of the national road network. The different categories include: i. Primary roads where the ROW is 40m from the center of the road on either side. These are “all-weather” roads and include main trunk roads with bituminous finishing that connect large towns and communities. This is the type of road that links Laminkoto to Diabugu (via intermediate communities such as Changai Wollof, Karantaba Dutokoto, Sami Medina, Sami Pachonki, etc.).

The Kalen Jawbeh/Bush Town corridor, and the Karantaba Tabokoto/ Karantaba Tenda corridor are also within this category, and they both have bituminous finishing. Along these road corridors the poles will be constructed within the ROW and will not impact any farmland3. ii. Secondary roads have a ROW of 15m from the center of the road on either side, and they usually connect a particular region or locality to the primary network. They are of a lower standard than the primary road network. The Karantaba Tabokoto/Karantaba Tenda road alignment does not have any T-offs because there is no village located between these two communities; the lines between these two communities will impact no one.

However, along the Kaleng Jawbeh/Bush Town road, several T-offs will be created to connect the communities of Kunting, Dobo, and Tankong, Jalokoto, where the roads along the T-offs have laterite finishing. Along these types of roads, no farmland is affected since the poles will be located within the defined ROW. See Figure 4.1 for the different types of roads encountered along which the poles will be constructed.4 iii. Urban roads, (7.5m on either side of the centerline) which are usually located in urban centers and provide access to residential and commercial areas. These, usually, carry heavy traffic and are thus built to high standards. This type of road was not encountered within the communities.

3This road does not have any vendors, no farmland and no informal settlers. At least 10 meters on each side of the road have been left for servitude like water, electricity, telephone and internet. This right of way is gravel road, and nothing c an be farmed there. See figure 4.5. 4 However, all affected parties (owners, land users and informal settlers have been identified and accounted for in the Resettlement Action Plan (RAP).

iv. Feeder roads have a ROW of 15m on either side of the center line and are used for access between villages and the more remote areas of the country; they also provide access to farms, processing centers and rural markets.

Along these corridors, poles will be constructed within farmlands since the width of the roads are usually less than 15m, and thus the available service route is inevitably within adjacent farmlands. It is along such road corridors where the majority of the affected lands will be recorded. These include the corridors linking Demba Kali and Jamagen; Karantaba Tabokoto and Tandy Bara (via Karantaba Tukulor, Tandy Mandinka, Baya bah, etc.).

For these identified corridors, a Resettlement Action Plan need to be developed and implemented to mitigate negative social impact and compensate the affected farmlands owners.

Figure 4.1: Areas affected by the transmission lines corridors

Figure 4.2: Built-up area at junction of Karantaba Tabokoto/Wollof (Note the telecommunication tower on the right, and across the road on the left is the village cemetery)

Some physical structures built along the highway are very close to the line corridor, particularly within built-up settlements (e.g., Laminkoto, (Km 0-0.8), Changai (Km 11.6-11.8), Karantaba Tabokoto and Karantaba Wollof (Km 25)-telecommunication tower, butcher’s shop, mosque, waiting shed, and Km 38.5 – Road Project’s Camp, etc.). The junction of Karantaba Tabokoto and Karantaba Wollof (Km 25) is particularly busy, especially on Wednesdays being a “Loumo” or market day; people from all over the two Districts attend these occasions.

About 150m south of the “Loumo” site at Karantaba Wollof is the village cemetery, about 7m from the edge of the road. All efforts must be made to avoid any type of works within the cemetery, should the Contractor decide to site the poles on the left side of the road. Figures 4.1 and 4.2 indicate the proximity of some structures and facilities to the highway and therefore the potential of being affected by the lines.

Figure 4.3: Karantaba Mosque close to the road corridor

In addition, at Km 39.2, is the Sami bridge, connecting the two Districts of Sami and Sandu. By the bridge is the site of a major weekly market (or Loumo) covering approximately 10,000m2 sitting less than 2m from the edge of the road; the transmission lines will be very close to the physical structures, and possibly even directly above some of the structures, especially during pole construction and stringing. A situation like this will pose a threat to the safety of the occupants of such structures. Sheds and stalls from where people conduct business, displaying their wares and goods will be impacted resulting in involuntary resettlement, (temporary loss of earning and income, loss of access to assets, etc. with or without physical relocation).

Figure 4.4: Approach to the Sami Bridge at the Loumo site; note the sheds by the road

Figure 4.5: Sheds and stalls at the Loumo site at Sami Tenda

In addition, by their very nature, medium tension lines pose threats to human health and safety particularly in the event of an accident resulting in the snapping of the line and its contact with humans on the ground.

Similarly, social amenities such as schools will face similar challenges and concerns during project implementation. For example, whilst the distance between Kuraw Lower Basic School (Km 54.6) is within a reasonable 15m distance from the road, the Forestry Office in Karantaba Duto koto (Km 23.7), Changai Lower Basic School (Km 11.8), and Darsilami Mandinka Lower Basic School (Km 42.9) are only 5m, 7m, and 10m respectively from the road’s edge.

The fence of the Forestry Office is made of cement blocks, and just behind the fence is the building housing the officers. A concrete gutter is constructed right next to the fence to convey storm water into a nearby gully. Clearly, pole construction close to the Forestry compound will damage the fence and destroy the gutter, which could lead to flooding of the compound.

The Changai and Darsilami Lower Basic Schools’ fences are also made of cement block fence, but are a bit further removed from the road alignment, and any works near them will likely create some inconvenience and discomfort to these institutions. Impact will mainly be health and safety issues relative to the persons (including school children) going in and out of the schools; there will not be any impact on the physical structures such as the school fences, and no damage to properties is envisaged.

Figure 4.6: feeder roads connecting communities like Tandy Mandinka, Baya bah

Figure 4.7: feeder roads connecting communities like Demba Kali and Jamagen; Karantaba Tabokoto and Tandy Bara

For corridors like those linking Demba Kali and Jamagen; Karantaba Tabokoto and Tandy Bara (via Karantaba Tukulor, Tandy Mandinka, Baya bah, lines are passing through farmlands

In view of the above it is recommended that a RAP should be prepared to address the social issues that may result from project implementation.

Noise Levels A total of 16 communities along the main road Laminkoto-Passamas (See Table 4.9) were identified as possible receptors sensitive to increased noise levels during pole construction and line stringing because of their proximity to the road, which is the alignment if the transmission lines. These settlements include 3 Lower Basic Schools in Changai, Kuraw and Darsilami Mandinka, respectively. All these receptors will be sensitive to increased noise generated by the workforce during the construction of the lines. Villages and other facilities beyond the 100-m range are considered less sensitive to noise from the construction works because of the attenuation of noise intensity over distance. The other main corridors with traffic like Kalem Jawbeh to Bush Town are less sensitive because settlements are far from the highway, the road corridor is free of settlements, construction would not disturb surrounding communities.

Figure 4.8: Bush Town to Kalem Jawbeh Corridors

The study did not carry out a noise monitoring program to be able to detect level of noise as construction works progress. In any case noise levels within the immediate areas of the poles should not be above the minimum noise level standard of 90 dB (A) during the day, and 50-55 dB(A) during the night, according to the United States Department of Labor Occupational Safety and Health Administration – OSHA). As per the national Environmental Quality Standards Regulations (1999), the recommended noise level is between 45-55 dB (A). As much as possible, this should be the target, indicating a high-quality acoustic environment.

Air Quality Generally, along this road corridor the local air quality is only minimally affected by the relatively low traffic level caused mainly by motor bicycles, cars, passenger vans, light trucks, etc. that use the road.

With the proposed line construction activities, there is very little chance that the local air quality will be affected because construction of the lines would not require too much movement of heavy trucks, excavators, or other earth moving equipment, etc. Nonetheless, generation of dust and gaseous emissions should be mitigated.

In addition, local air quality may not decline significantly as a result of gaseous and particulate emissions from vehicle movements around the pole construction sites. Nonetheless, even where it happens, the project site is within rural surroundings that allows good ventilation and dispersion of any air pollutants.

Quarry and Borrow Areas At Km 7 (between Laminkoto and Fitu) there is a gravel quarry located 45m to the left side of the highway; presumably, this was used by the road contractor during the road works. It is clearly more than 500m from any habitation, which distance is recommended; the site for the supply of sand though, was not identified to the Consultant. It is assumed that some of the required gravel materials for construction of the bases for the poles in this project are going to be procured from here, and

perhaps other quarries along the road. Any site identified for mining of sand and gravel must be approved by the community, Geology Department and NEA.

THE BIOLOGICAL ENVIRONMENT Forest Cover of the Project area Forests in general have important functions, and in the project area these include the provision of domestic energy for cooking, building materials in the form of poles and timber, medicinal products, wild fruits, honey, etc.

Their environmental functions include soil erosion control, regulation of water quality and flow in watersheds, thereby moderating floods from heavy rain. They also have the unique potential to contribute to climate change mitigation by reducing emissions and enhancing carbon sinks. In addition, depending on the extent of deforestation, reduced tree cover could result in reduced cloud cover and rainfall.

Generally, within the two Regions of CRR and URR North, large tracts of savannah woodland are found in the Sami and Sandu Districts where elevation is between 20 and 30m above sea level. Moving away from near the river system upland, and on thinner soils (which is where the transmission lines will more likely be located) shrub savannah is the dominant vegetation. The major species here include the violet tree (Securidaca longipedunculata), the bush willows (Combretum spp.), Accacia albida (Kadd) Cassia spp. the “jambakatango”, Taminalia macroptela (“wolo”) and fig tree (Figus spp.)–soto). These are the dominant species, and they owe much of their pre-eminence to fire, and their drought resistant characteristics, as well as their being as food sources for the local inhabitants, and thus given high prominence in their conservation. Figure 4.5 shows the typical vegetation along the corridor.

Figure 4.5: Typical vegetation along the line corridor of Laminkoto-Diabugu

Community Forests There are at least three Community Forests (CFs) designated (about 15m from the edge of the road) located along the line corridor in close succession; they are Demba Kaleh Njaga (7ha), Demba Kaleh

Kassum (105ha) and Karantaba Dutokoto (115.6ha). They are located between Km 22 and Km 23 and given their close proximity to the road alignment and the potential trajectory of the transmission lines, it is recommended that workers exercise due diligence when erecting the poles within this area in order not to impact negatively on the forests; the road contractors degraded parts of the forests during the construction of the Laminkoto-Passamas road. It was reported that the forest boundaries toward the road were encroached upon and degraded by the road contractors. There is also an open access forest at Karantaba Dutokoto, which it was reported, is used by the community to graze their livestock, and to collect other non-wood products.

CFs have a vital role to play in the maintenance and management of the country’s forest cover. The need for their creation nationally was recognized after the drastic decrease of closed woodlands became evident as a result of the management system in place at the time, “state-controlled-top- down-forest management” approach adopted by the government. The Forestry Department developed the “participatory forest management” concept which promotes active local participation in forest management, where the community is given legally secured ownership and/or exclusive user right in order to gain its interest, giving it an investment and stake in protecting the nearby forests.

Thus, the overall goal of the CF concept is to increase the welfare of local communities and, at the same time, to contribute to protect and maintain an adequate national forest cover and/or slow down and eventually stop environmental degradation. In the process, indigenous tree species, (e.g., “dimba”, “jambakatang”, “bunkungo”, etc.) which are more climate resilient, that have been cut down, will be replaced. Communities will benefit from the practice as the trees would provide multiple additional amenity values including shade, fruit and other non-wood products, windbreaks, etc. and the communities are entitled to commercialize the forest products.

Given the above, should the contractors of the transmission lines degrade any part of the CFs, the affected trees must be replaced.

Fruit trees and other Vegetation Fruit trees along the line trajectory are planted outside private compounds aligning the road, or within compounds, or are planted as orchards and fenced and well protected from stray animals; some are planted on farmlands by farmers and left to grow unattended over the years. These trees include the mango, (Table 4.5) and it is important as a source of supplementary food for families. In some instances, the trees provide cash to the owners when the fruits are harvested and sold at the local “Loumo”. Mangos also provide shade for family and individual relaxation. Thus, felling the trees by NAWEC’s contractors to make way for the lines could deprive these families of both food and income sources.

Other forest trees along the corridor include the baobab (Adansonia digitata), which is planted for its shade as well as for food, its fruits are eaten and have certain uses as medicine; its leaves are used as vegetables, for sauces; its bark can be used as rope for tethering cattle. The “dimba” or “wula kono duto” (Cordyla pinnata), “nete/neto” or African locust bean (Parkia biglobosa), are also common within the farmlands and immediate village vicinities and are useful as food sources. The wild cola (Cola cordifolia) “tabo”/” taba” is often planted for its shade, and the fruit is edible and tasty, and it is a food source for animals.

Table 4.5: Trees found along the corridor and their status nationally and within the IUCN Red List Common Scientific Name National Status Source of identification and IUCN status English Name level on During Reported by Bibliographic status IUCN site visit Locals/DPWM research

Red List Mango Mangifera Lc LC x x X indica, Baobab Adansonia LC LC x x X digitata Cordyla Cordyla pinnata LC LC x x X African locust Parkia LC LC x x x bean biglobosa Wild cola Cola cordifolia LC LC x x x LC = Least Concern: Evaluated as not being a focus of species conservation

In the country, many trees along existing transmission line corridors (including those located within natural forests) are affected by NAWEC transmission lines. They are usually pruned by NAWEC (especially before the rains) when the branches grow too close to the lines, rather than felling the whole tree. This practice is repeated periodically as the trees regenerate new branches that threaten the lines. It is not uncommon also that whole trees are felled to make way for transmission lines, and this could include both private fruit trees and forests trees located along the trajectories of the lines. Contractors should ensure they fell only trees that need to be felled (e.g., if sited on a pylon location) and prune the rest.

Private trees should not be impacted (pruned or felled) without the consent of the owner, and indeed where they must be impacted, a Resettlement Action Plan (RAP) should be developed to address any potential social impacts. By the same token forest trees that need to be felled must be noted, and in consultation with the DOF a tree-replacement program developed; after all, the loss of “green cover” and loss of carbon capture footprint as a result of the felling needs to be managed. The Mammalian Fauna The mammalian fauna along the line corridor is generally influenced by the open forests, which are home to various invertebrates, reptiles and mammalian species. Among the primates is the patas monkey and the Guinea Baboon (Papio papio) which (Table 4.6). According to the IUCN the baboon is “near threatened”, and consequently needs to be protected. The baboon is generally regarded as a vermin species by famers, but to protect it DPWM allows only licensed hunters to kill it. The wart hog is also present in large numbers and is another pest especially for ground nut. Other mammal species include the sun squirrel, and some rodents. Among the reptiles are the agama lizard, red skink, rainbow and monitor lizards.

Table 4.6: Mammals found along the corridor, their Status nationally and within the IUCN Red List Common Scientific Name National Status on Source of identification and IUCN English level IUCN Red status Name Status List During Reported by Bibliographic site Locals/DPWM research visit Sun squirrel Marmotini spp. LC LC X x x Giant rat Cricetomys LC LC x x gambianus Guinea Papio papio LC Near x x Baboon threatened Common Phacochoerus LC LC X x Wart hog africanus

Patas Erythrocebus LC LC X x X monkey patas Red skink Plestiodon LC LC X x X fasciatus Agama lizard Agama africana LC LC X x X Rainbow Agama africana LC LC X x X lizard Monitor Veranus indicus LC LC X x X lizard LC = Least Concern: Evaluated as not being a focus of species conservation

Whilst the wart hogs are not usually food items for the local people due to religious reasons, other small mammals like the squirrel, rodents (such as the giant Gambian rat), and the monitor lizards are commonly hunted for food to supplement local protein supplies.

Aquatic species that occur within the main river system and the adjacent “bolongs” include such as the thick-lipped, sucking mouth carp locally called “fantango”, (Labeo spp.); tilapia or “furo”; named above, (see Table 4.7).

Table 4.7: Fish Species found within the Bolongs along the corridor, their status nationally and within the IUCN Red List

Common English Scientific Name Status on Source of identification and IUCN status Name IUCN Red During Reported by Bibliographic List site visit Locals/DPWM research African carp Labeo spp LC X X Tilapia fish Tilapia Spp. LC X X LC = Least Concern: Evaluated as not being a focus of species conservation

The Avifauna The avifauna along the line corridor essentially resides within the nearby open forests, and CFs, and they include pheasants, starlings, weavers, eagles, and hawks, etc. (Table 4.8). Some other recorded species include the black-necked weaver, black-billed wood-dove, and many other avian. No migratory routes have been found along the line corridor. Table 4.8: The Avifauna found along the corridor, their status nationally and within the IUCN Red List

Common Scientific Name National Status Source of identification and IUCN English Level on IUCN status Name Status Red List During Reported by Bibliographic site Locals/DPWM research visit Pheasants The white- (Peliperdix LC LC x x throated albogularis francolin The double- (Pternistis LC LC x x spurred bicalcaratus) francolin

Starlings Bronze- Lamprotornis LC LC x x x tailed chalcurus starling Chestnut Lamprotornis LC LC x x x bellied pulcher starling Weavers Black- Ploceus LC LC x x x headed melanocephalus weaver Black- Ploceus nigricollis LC LC x x x necked weaver Hawks, Vultures and Eagles African Polyboroides LC LC x harrier-hawk typus Doves The red- Streptopelia LC LC x x x eyed dove semitorquata Black-billed Turtur LC LC x x x wood abyssinicus LC = Least Concern: Evaluated as not being a focus of species conservation

Usually, birds do not get electrocuted by transmission lines whilst sitting on or hitting a single wire because they will not create a conduit of electricity as there is no voltage difference in a single wire; for electrons to move, there must be a difference in electrical potential. For example, electricity flows from areas of high voltage to areas of low voltage; thus, electricity flowing through a single power line will continue along the path of least resistance and bypass birds, because there is no difference in electrical potential. If, however, large birds with wide wingspans (such as certain eagles, hawks, and vultures) in flight or sitting on a single wire touch another electric wire with a different voltage, then they get shocked. This is because their bodies would become a place with a different voltage. However, there is no risk to humans on the ground when birds get electrocuted; the sound emitted with bird strikes is not related to the electric current but only to the impact of hitting. Thus, people near transmission lines need not be scared when they hear the sound.

On the other hand, the relatively small-sized, and short wing spanned species like starlings, weavers, etc. would normally not get electrocuted because they could fly between the conductors without touching any of them. Therefore, power lines tend to be high in the air with plenty of space between the wires to allow birds to pass between them without hitting both wires. In view of the above therefore, the avifauna is mainly at risk of collision with the transmission lines during flight between roosting/nesting and the feeding grounds.

THE SOCIO-ECONOMIC ENVIRONMENT

Demography and Population Along the Line Corridor This corridor has relatively few developed structures along the highway, and the population is principally subsistence farmers. A total of 16 communities and villages are along the line corridor, located mostly within 100 meters from the edge of the road. Table 4.9 below indicates the demography of the villages and communities located along the line corridor.

The project area is not very populated, consisting of only one community with more than 2,000 inhabitants (Sami Pachonki with 2,432 persons); the next three relatively large communities are Darsilami (in Sandu with 1,050 persons), and Sami Madina (913 persons). The total population of 8,993 persons comprises more than 51% women, and 49% men within in 640 households.

Table 4.9: Villages and Communities Along the Transmission Line Corridor

No: Village/Community District Population # of Households

Total M F 1.1 Dobo Sami 758 342 416 64

1.2 Changai Tukulor Sami 274 132 142 13

1.3 Changai Wollof Sami 463 227 236 40

1.4 Sinchu Baya Sami 376 203 173 20

1.5 Sami Pachonki Sami 2432 1105 1327 176

1.6 Sinchu Dura (Bayaba) Sami 35 23 12 2

1.7 Sami Tenda Sami 85 47 38 12

1.8 Kibiri Sami 681 320 361 51

1.9 Tankong Kunda Sami 465 228 237 38

1.10 Jalo Koto Sami 406 181 225 31

1.11 Keleng Sainey Sami 215 106 109 16

1.12 Kaleng Jawbeh Sami 191 99 92 12

1.13 Sami Suruwa Kunda Sami 848 384 464 51

1.14 Fitu Fula Sami 258 126 132 21

1.15 Fitu Wollof Sami 97 40 57 10

1.16 Jallubeh Sami 215 93 122 15

1.17 Tandy Mandinka Sami 538 281 257 20

1.18 Tandy Barra Sami 211 105 106 18

1.19 Tandy Wollof Sami 64 27 37 5

1.20 Sami Medina Sami 913 478 435 60

1.21 Sami Omar Jula Sami 132 65 67 9

1.22 Bantang Jel Sami 157 75 82 14

1.23 Demfaye Sami 37 13 24 5

1.24 Korra Sami 82 35 47 4

1.25 Yonna Sami 384 185 199 25

1.26 Banni Sami 549 266 283 56

1.27 Jamagen Sami 190 102 88 10

1.28 Timpa Sami 111 54 57 6

1.29 Demba Kali Njaga Sami 606 289 317 40

1.30 Damba Kali Sami 241 122 119 20

1.31 Karantaba Bantankoto Sami 83 39 44 2

1.32 Karantaba Tukulor Sami 466 211 255 35

1.33 Kunting Sami 1417 767 650 99

1.34 Bush Town Sami 343 147 196 45

1.35 Toniataba/Tassily Sami 147 70 77 10

1.36 Karantaba Tenda Sami 180 78 102 29

1.37 Karantaba Tabokoto Sami 269 133 136 21

1.38 Karantaba Dutokoto Sami 391 185 206 42

1.39 Karantaba Wollof Sami 292 142 150 35

1.40 Sare Jatta Sami 122 53 69 6

Sub-Total 15724 7578 8146 1188

1.41 Demba Wandu Sandu 161 84 77 15

1.42 Dasilame Seck Sandu 126 58 68 18

1.43 Nawdeh Sandu 477 249 228 56

1.44 Sinchu Musa Sandu 225 100 125 17

1.45 Kuraw Kemo Sandu 343 143 200 20

1.46 Kuraw Arafang Sandu 775 311 464 51

Sub-Total 2107 945 1162 177

Grand Total 17,831 8,523 9,308 1,365

Disadvantaged and Vulnerable Groups Table 4.9 presents the demography of the communities that line corridor will affect. Although women form more than 50% of the population of the communities, generally they are often marginalized in the decision-making process, especially as it relates to the allocation of agricultural land. The impact of this marginalization is compounded by cultural norms and customs which tend to privilege men and boys over women and girls. In The Gambia, land use and tenure rights tend to disfavor women as important decisions relating to land are made by the men, including inheritance, ownership, among others. In some of the settlements along the transmission line, women farmers engage in cash crop production, just as men, and in the process of this project’s implementation, their farms could very well be impacted in the same manner as the men. However, given the male-dominated environment within these localities, the adverse impacts would fall disproportionately on the women.

Given their social status, women would therefore, be considered a disadvantaged and vulnerable group in this project. In addition to women, this group includes the elderly and minors, and persons with disabilities, among others. These persons are more likely to be adversely affected by the Project impacts and/or more limited than others in their ability to take advantage of the project’s benefits. They are also more likely to be excluded from, or unable to participate fully in the mainstream consultative process and as such may require specific measures and/or assistance to do so.

Pole construction and line stringing within crops will result in impacts that will potentially affect women disproportionately to men, especially if works are carried out during the farming season. Similarly, persons with disabilities and the elderly can also be affected. For example, they may be unable to attend meetings for reasons due to their inability to reach the venues, and in this way will be excluded, and their voices and opinions may not therefore be considered.

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

Gender and Gender-Based Violence (GBV) The majority of the poor and extremely poor in the Gambia is made up of women, who represent 50% of the country’s population. In 2015, the Gambia was ranked 148th out of 159 countries with a score of 0.641, according to the UNDP Human Development Report’s Gender Inequality Index in 2013; female poverty is closely linked with very low literacy levels (40% for women and 64% for men) and education attainment rates for a variety of reasons, including cultural norms and physical access.

Women’s access to land remains largely based on customary law where the land belongs to founding families, and the user rights of in-married women depend on the continuation of their marriage within the family. Furthermore, they often lack access to credit for income-generating activities and generally have a limited role in the decision-making processes that affect their lives. This disadvantaged position of women in the family is deeply rooted in gender inequality and a power imbalance between men and women which is likewise a root cause of gender-based violence (GBV). In The Gambia, women and girls experience violence at high levels. For example, women and girls marry very young in The Gambia, with nearly a quarter (24%) of females aged 15-19 already married; three out of four women aged 15-49 have likewise undergone female genital mutilation. In addition, one out of four (26%) ever-married women has experienced physical, sexual, or emotional abuse from an intimate partner.5 GBV can cause multiple forms of harm, such as physical, psychological, and

5 Demographic and Health Survey (2013).

socioeconomic harm. A survivor’s personal health and safety may be affected, which can lead to social exclusion and isolation, further hampering the survivor’s ability to earn an income or cover key personal expenses and thereby causing both physical and socioeconomic harm. In addition, economic harm to an individual may result from damage done to property owned by the survivor or restriction of a survivor’s access to resources, which can also foster a survivor’s financial dependency on her partner, creating additional risks for abuse.

Given the traditional and customary set-up in communal land use as noted above, in the event of resettlement of lost crop or economic trees in this Project, women could be impacted the most in accessing financial resources paid as compensation or being able to participate freely and meaningfully in the decision-making processes around resettlement and compensation. In addition, because of their vulnerable social and economic status, women, as well as children, are more at risk of experiencing SEA and SH in the context of the project, especially in relation to planned civil works activities where labor influx is occurring, whether as community members or as project workers.

In view of the above, therefore, particular attention will be paid to the needs of vulnerable groups, especially women and children, those below the poverty line, the elderly, etc. A SEA/SH Prevention and Response Action Plan, including an accountability and response framework, as well as a mapping of service providers for survivors of GBV, will be developed prior to construction. It has been costed in the budget.

Violence Against Children (VAC)

Defined as physical, sexual, emotional and/or psychological harm, neglect or negligent treatment of minor children (i.e., under the age of 18), including exposure to such harm,6 that results in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power. This includes using children for profit, labor7, sexual gratification, or some other personal or financial advantage. This also includes other activities, such as using computers, mobile phones, video, and digital cameras or any other medium to exploit or harass children or to access child pornography.

In The Gambia, there have been reports of children, mostly girls, subjected to domestic service and commercial forms of exploitation (i.e. tourism); female genital mutilation (FGM) is likewise still pervasive (76% prevalence rate), as are early marriage and other forms of exploitation.8

During project implementation, the potential areas where this can be manifested may include:

1. Employing children under the age of 18 years

2. Using children for personal or financial advantage by both contractors and employees

3. Any other way to harass children, including sexual exploitation and physical or sexual violence

In this regard, the PIU and Contractors must ensure that no aspects of the project works involve children under the minimum age of 16 for light work (as per The Children’s Act, 2005) and none under

6 Exposure to GBV is also considered VAC. 7 The employment of children must comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. They must also be able to meet the project’s Occupational Health and Safety competency standards. 8 The Gambia, Child Protection Plan of Action, 2016-2018 and UNICEF Gambia), https://www.unicef.org/gambia/activities_8342.html

the age of 18 for hazardous work and work that affects their schooling and social or moral development.

The Labor Act, 2007 prohibits children under 18 from engaging in agricultural, industrial, or non- industrial work for economic gains. In addition, to strengthen and protect children against possible violence and exploitation, the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender-Based Violence (GBV), Sexual Exploitation and Abuse (SEA), Sexual Harassment (SH), and Violence Against Children (VAC) must be rigorously applied, monitored for compliance and will be included in the Contractors ESMP (Annex 7 includes the Codes of Conduct for addressing GBV, including SEA and SH, and VAC).

Access of the Population to Education and Security Services The children in the villages and communities along the road have access to education, and the schools along the transmission line corridor are located in Laminkoto, Changai, Darsilami and Kuraw. A Lower Basic and an Upper Basic School are located at Karantaba Toro, and a Police station is located in Karantaba Wollof.

Access of the Population to Health The population has access to a Minor Health Center located in Karantaba Tenda, by the River Gambia (about 5km from the proposed project site); it is staffed with nurses, midwives, and public health officials. There is a Major Health Center in Yorobawol (15km away in Wuli), and a referral hospital in Basse, across the River (27km).

Access of the Population to Electricity, Telephone Sevices The population along the line corridor has no access to electricity supply from the NAWEC grid; only Diabugu Batapa has access to the grid, and it is supplied from Basse. Thus, the entire line corridor between Laminkoto and Kuraw Kemo is without electricity, and they have expressed appreciation for this project that will make it possible for them to have electric power.

However, mobile network services are operational within the project area. A transmission tower of one of the local mobile telephone companies is located at the junction of Karantaba Tabokoto and Karantaba Wollof (Km 25) next to the waiting shed and a mosque.

Chance Finds and Cultural Heritage and Archaeology There are sensitive sites of cultural significance along the road corridor; these include two mosques, (a small mosque at the Farafenni-Laminkoto road intersection and one other in Karantaba Wollof/Tabokoto), and the village cemetery in Karantaba Wollof/Tabokoto. The mosque in Laminkoto will potentially be more affected by the line. It is built with cement blocks with corrugated roof, and measures approximately 10x15 meters; without any protection or barrier towards the road, it is located within the compound of Mr. Samsudeen Mbye, a poultry farmer in Laminkoto, and is barely 5 meters from the edge of the road. The other mosque and cemetery in Karantaba will less likely be impacted by the project because they are a bit further removed from the road’s edge. Nonetheless, they are all of cultural relevance and must be preserved.

There is always a possibility of finding other types of cultural heritage by chance, particularly during land clearing and preparation for works. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

Modes of Subsistence and Daily Chores in the Project’s Sphere of Influence

(i) Agricultural Production The communities living along the transmission line corridor rely almost exclusively on agriculture and livestock for their subsistence. Like other parts of the country, agriculture within the project area is characterized by little diversification, and is mainly subsistence rain-fed, and semi-intensive cash crop production. Farmers generally practice mixed farming, producing food crops comprising cereals (early millet, late millet, maize, sorghum, rice and “findo”), although cash crops (including groundnuts, cotton, sesame and horticulture produce), account for a greater portion of the production. The cultivation of horticultural crops (vegetables and fruits) is also practiced but mainly by women farmers growing tomatoes, okra, sorrel, etc. In many instances the women do cultivate cash crops as well.

Figure 4.6: Illustration of farm boundary away from the road

Along the road, in many cases farms are located very close to the road corridor (see Figures 4.6 and 4.7) the trajectory of the transmission lines, and thus maybe impacted by the project, depending on the timing of the works; they may be affected, especially when the works are carried out during the rainy season, when crops are in the fields. Figure 4.7: Melon plantation (outside Project area) illustrating position of pole and farm clearance from the road and line corridor

Table 4.10 shows the general agricultural calendar of activities common within the study area, which could be used as guide in the construction of the lines. Figures 4.6 and 4.7 (outside Project area) are some examples of farms’ locations in relation to the roads.

Table 4.10: Farming Calendar of Activities along the Transmission Line Corridor ACTIVITIES CARRIED OUT Month MEN WOMEN May Clearing of farmland Prepare rice fields, groundnut fields June Clearing farmland Prepare rice fields, groundnut fields July Planting late millet, maize, groundnut, Planting rice, groundnut cassava Aug Weeding and guarding crops Weeding and guarding rice/groundnut crops Sept Weeding and guarding crops Weeding and guarding rice/groundnut crops Oct Harvesting millet, maize, and groundnut Guarding rice, harvesting groundnut Nov Harvesting millet Guarding rice, threshing groundnut Dec Threshing groundnut Harvesting rice, threshing groundnut Jan No works in the fields Harvesting rice Feb No works in the fields Dry season gardening Mar No works in the fields Dry season gardening Apr No works in the fields Dry season gardening

From the table above, it is clear that in order to minimize damage to crops within the corridor, line construction should be carried out after the crops have been harvested and there is less activity in the fields; where construction cannot be halted during the farming season, extra care and diligence must be taken to avoid or minimize damage to crops.

(ii) Marketing and Petty Trading The women from various surrounding villages engage in dry season gardening, but claim they do not have a market locally, and so most of their produce is sold at Diabugu, Basse and/or the “Loumo” at Sami Tenda. Figure 4.8 shows market stalls and sheds at the Loumo site in Sami Tenda. For example, women in Kuraw sell their produce in Diabugu (2km) and Sami Tenda about (15.7km) away; those in Karantaba travel 14.5km to Sami Tenda.

Figure 4.8: Market sheds and stalls at the weekly market in Sami

A hairdresser, recently trained in the Greater Banjul Area, plans to set up a hair dressing salon should the village have power supply as an example of project benefits to the community.

Weekly markets (“Loumo”) are held in various places, e.g., in Sami Tenda, near the Sami bridge, where people from various communities around the Districts of Sami and Sandu sell their goods on Thursdays. In Karantaba Wollof is another “Loumo”, held on Wednesdays where people from various areas sell and buy goods such as chicken, cattle, farming equipment. On “Loumo” days there is usually a brisk trade from as early as 8 a.m. to 5 p.m.

(iii) Sale of Ice Blocks Besides Diabugu (which is supplied with electricity from Basse), the entire corridor is without electricity. Typically, during the fasting month of Ramadan, ice blocks become a vital and fast selling commodity with vendors travelling all the way to Bansang, Basse, and Diabugu to procure ice blocks for retailing within the villages. In the village of Demba Kaleh a young woman was encountered with two sack loads of ice blocks she bought in Bansang to sell at her home community of Karantaba Dutokoto. Men using motorcycles commonly use locally made insulated boxes to carry ice blocks (Figure 4.9).

When available locally, the blocks are sold at D35 (USD0.70) per kg when supplied from Diabugu, and at D50 (USD1) per kg when they are supplied from Basse and Bansang. The villagers claim that with

this electricity project, the community will benefit greatly and be able to meet the demand by making their own ice blocks rather than travel to Basse and other places to get ice for sale.

Figure 4.9: Locally made insulated box for carrying ice blocks

(iv) Welding and Steel Fabrication and Youth Employment

In at least three communities along the corridor steel welding workshops were encountered, operated by young men using diesel powered Chinese-made generators. (See Figure 4.10 in the village of Sami Pachonki. Given the number of door and window frames fabricated in both workshops, it is possible that this trade could form an important line of business and activity for the youth of the communities in Sami and Sandu. This is particularly relevant given that the level of youth unemployment and underemployment is high nationally, even though they form an estimated 53.8% of the Gambian population. The challenges they face include limited job opportunities, inadequate employable skills, and limited access to productive assets. The high rate of unemployment causes frustration, dejection and dependency, and the situation has left youth in a vicious cycle of poverty that daily erodes their confidence and bright futures. This is leading to some of the youth taking the unsafe and risky journey to Europe in search of employment opportunities.

Figure 4.10: Welding Workshop at Pachonki in Sami District, CRR

The implementation of this MV line project and other NAWEC power projects could create the environment to address the economic root causes of youth frustration by supporting youth employment and entrepreneurship, particularly with the availability of electricity at their doorstep. More enterprises of different types could be developed by youth within this Project’s sphere of influence.

(v) Harvesting Wood and Non-wood Forest Products The communities along the transmission line corridor (men and women, children, youth) collect medicinal plants, herbs and the bark of trees, and wild fruits for personal consumption. Non-wood products include honey, the “neto”, “kaba”, “tomborong” “tabo” and “wulakono duto” etc. These products are sometimes sold within the village to supplement the household income.

Given the local use of these forest products, it will be recommended that the plants and trees that bear them are not felled unnecessarily in the course of project implementation, because loss of access to these products would adversely impact their livelihoods and income support, culture and social norms.

(vi) Firewood Collection Almost all the communities along the line corridor are dependent on the vegetation and forest resources for the provision of firewood as fuel. These are collected from the forest for domestic and possibly livelihood use. It was reported that some unscrupulous persons use fire to kill the trees and thus ensure continuous supply of wood; clearly this practice could result in deforestation.

(vii) Livestock Rearing Cattle are reared by the community members, allowed torange over the bush, and on crop residues after the harvest. Poultry are raised at the household level, and small ruminants (sheep and goats) graze close to the village and are corralled within the compounds at night. Cattle are corralled by tying to stakes in areas peripheral to the village. Draft animals (donkeys, horses and mules) are also kept mainly for cultivation in the fields.

(viii) Fishing This is another important economic activity within the villages, especially in Kuraw Kemo where some of the men fish for a living within the tributaries (“bolongs”). It is however unlikely that the project

activities will impede access to the “bolongs” since they are far removed from the potential line trajectory.

LOCATION-SPECIFIC BASELINE CONDITIONS

This section describes the location-specific baseline conditions encountered along the transmission line corridor; these refer to conditions as they relate to physical, biological and the socio-economic environment. Since the technical design has not yet been completed the Consultant decided to assess both the left and right sides of the road. Table 4.11 indicates the specific environments along the line corridor with recommendations on how to address issues identified during project implementation.

The trajectory of the transmission line follows the Laminkoto-Passamas, Kalem Jawbeh-Bush Town and Karantaba Tabokoto/ Karantaba Tenda roads alignment passing through the Districts of Sami in CRR and Sandu in URR; the corridor is sparsely populated with only a few relatively large communities such as Karantaba Dutokoto, Karantaba Tabokoto, Bush Town and Karantaba Wollof in Sami, and Darsilami in Sandu. Diabugu is a large community in Sandu, but Basse is already supplying its electricity needs.

Several depressions occur along the road for which culverts have been constructed as appropriate; it appears that these areas are prone to receiving heavy storm water a nd run-off during the rainy season, which may lead to severe erosion and inundation of surrounding areas thereby impacting on poles that may be erected on such areas.

Socio-economic activities along these corridors include farming (including horticultural activities) as well as small scale shops and other petty trading activities. Other activities include metal welding workshops mainly along the road.

Table 4.11: Description of site-specific conditions along the Laminkoto-Diabugu Road Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 0.0 Farafenni-Laminkoto High tension pole LHS 10m Transmission Pole to be The Laminkoto- Diabugu T&D Road Intersection relocated line starts here and will run with Laminkoto either on the Left- or Right- Passimas Road Hand Side of the Laminkoto- Passimas Road. 0.0 Farafenni-Laminkoto A small mosque RHS 5m Pole erection and line must Cultural impact to be avoided Road Intersection located within a avoid the mosque. Locate with Laminkoto compound pole at least 2 meters from Passimas Road structure 0.0 Laminkoto NAWEC waterpipe RHS 3m Partly within the Road Corridor; Intersection Manhole Health and safety concerns during construction of poles. 0.0 Laminkoto Private Compound RHS 9.3 Health and safety concerns Intersection (Mbye Kunda) during construction of poles. 0.32 Laminkoto Private Compound RHS 10 Health and safety concerns (Jallow Kunda) during construction of poles. 0.32 Laminkoto Tabo Tree RHS 5 Trim 0.4 Laminkoto Private Compound LHS 15 0.45 Laminkoto Mango Tree RHS 5 Trim 0.64 Laminkoto Village Water Tank RHS 20 Health and safety concerns during construction of poles. 0.68 Laminkoto Scrap metal Dump RHS 2 Clear before construction of poles 0.8 Laminkoto Group of 8 Baobab, RHS 20 Trim Neem, Jambakatang and Keno Trees.

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 1.61 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 2.09 Baobab trees LHS 7 Trim 2.11 Group of 5 baobab LHS 15 Trim trees 2.25 Jalo Tree LHS 15 Trim 2.25 Jalo Tree RHS 7 Trim 3.54 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 4.35 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 6.6 Gravel Quarry LHS 45 To be rehabilitated by refilling the quarry after completion of the Project 7.08 Jambakatang Tree RHS 7 Trim 8.55 Fitu Fula Group of 2 Acacia RHS 7 Trim and Dimba Trees 8.69 Fitu Fula Private Compound LHS 15 Health and safety concerns (Modou Salieu during road construction. Touray) 9.17 Fitu Fula Dimba Tree RHS 10 Trim 9.17 Fitu Fula Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 11.59 Changai Private Compound LHS 15 Health and safety concerns during construction of poles. 11.59 Changai Private Compound RHS 7 Health and safety concerns during construction of poles.

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 11.62 Changai Dimba Tree RHS 7 Trim 11.66 Changai Private Compound RHS 10 Health and safety concerns during construction of poles. 11.75 Changai Changai Lower Basic RHS 6 Health and safety concerns School during construction of poles. 12.07 Changai Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 13.04 Changai Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 13.36 Keleng Jawbe Bus Stop RHS Health and safety concerns during construction of poles. 15.45 Keleng Sainey Bus Stop RHS Health and safety concerns during construction of poles. 15.5 Keleng Sainey Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 15.61 Keleng Sainey Bus Stop LHS LHS Health and safety concerns during construction of poles. 16.25 Keleng Sainey Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 16.74 Group of 4 Baobab LHS 10 Trim Trees 17.2 Demba Kaleh Dimba Tree RHS 15 Trim 17.38 Demba Kaleh Private Compound RHS 10 Health and safety concerns during construction of poles. 17.38 Demba Kaleh Soto Tree RHS 4 Cut The soto is not within a Community Forest, and thus belongs to DOF

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 17.41 Demba Kaleh Private Compound LHS 5 Health and safety concerns during construction of poles. 17.43 Demba Kaleh Waiting Shed LHS 3 Avoid using Waiting Shed Health and safety concerns during construction of poles during construction of poles. 17.54 Demba Kaleh Bus Stop LHS Health and safety concerns during construction of poles. 19.15 Group of 3 RHS 8 Trim Jambakatang Trees 19.31 Dimba Tree RHS 12 Trim 19.63 Group of 2 Baobab LHS 5 Cut Trees 21.73 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 22.5 Demba Kaleh Njaga Community Forest RHS 7 Do not erect poles within the Established more than 10 years Forest ago. Communities collect firewood, timber, etc. grazing area for livestock 22.7 Demba Kaleh Kassum Community Forest RHS 7 Do not erect poles within the Established more than 10 years Forest ago. Communities collect firewood, timber, etc. grazing area for livestock 22.9 Karantaba Dutokoto Community Forest RHS 7 Do not erect poles within the Established more than 10 years Forest ago. Communities collect firewood, timber, etc. grazing area for livestock 23.17 Karantaba Dutokoto Culvert Across the Avoid putting poles on Road waterway

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 23.66 Karantaba Dutokoto Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 23.7 Karantaba Dutokoto Open Access Forest RHS Do not erect poles within the Communities collect firewood, Forest timber, etc. grazing area for livestock 23.7 Karantaba Dutokoto Forestry Office LHS 7 Avoid gutter, and do not site Gutter is too close to the fence pole line and any pole construction will destroy the concrete of the gutter; health and safety concerns during construction of poles 24.78 Karantaba Dutokoto Drainage Gutter RHS 5 Avoid putting poles close to Gutter 25.1 Karantaba Wollof Gully LHS 7 Avoid putting poles close to Gully 25.1 Karantaba Wollof Loumo Site on LHS 10 Be extra vigilant when “Loumo” attracts many people (Wednesdays) erecting poles, especially on “Loumo” days 25.1 Karantaba Wollof Community cemetery LHS 7 Avoid erecting any structures Cultural values and norms need to be respected 25.1 Karantaba Tabokoto Telecommunication RHS 2 Do not site pole to avoid Location too close to the road pole, butcher’s shed, resettlement and is too congested with and waiting shed, structures mosque LHS LHS 27.68 Sami Pachonki Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 27.84 Sami Pachonki Bus Stop LHS Health and safety concerns during construction of poles. 28.0 Sami Pachonki Bus Stop RHS Health and safety concerns during construction of poles. 28.49 Sami Pachonki Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 28.81 Sami Pachonki Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 29.13 Sami Madina Baobab Tree RHS 7 Trim 29.29 Sami Madina Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 30.26 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 32.19 Dimba Tree RHS 15 Trim 34.12 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 37.18 Neteh Tree RHS 8 Trim 38.46 Road Project Camp LHS 10 Health and safety concerns during road construction 38.62 Small mud house and RHS 8 Tanker 38.79 Group of Wolo and RHS 8 Trim Keno Trees 39.2 Sami Bridge Sami Bridge Across Line should run overhead The bolong is very wide (48m), Sandugu across the Bolong; Avoid but is less than the minimum Bolong putting poles on the slope of span between poles the banks

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 39.2 Sami Tenda Loumo Site On both sides 2 Avoid siting poles in people’s The area is usually busy with of road market sheds, etc. shoppers during Loumo days 42.02 Dasilami Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 42.39 Dasilami School RHS 10 Health and safety concerns during construction of poles. 42.62 Baobab Tree LHS 4 Trim 42.70 Dasilami Private Compound RHS 5 Health and safety concerns during construction of poles. 42.77 Bus Stop LHS Health and safety concerns during construction of poles. 43.2 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 44.33 Darsilami Bus Stop RHS Health and safety concerns during construction of poles. 44.97 Darsilami Bus Stop LHS Health and safety concerns during construction of poles. 45.93 Darsilami Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 46.74 Bus Stop RHS Health and safety concerns during construction of poles. 47.06 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 47.38 Nawdeh Bus Stop LHS Health and safety concerns during construction of poles. 47.38 Nawdeh Bus Stop RHS Health and safety concerns during construction of poles.

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 49.31 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 49.64 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 50.92 Bus Stop RHS Health and safety concerns during construction of poles. 51.08 Bus Stop LHS Health and safety concerns during construction of poles. 51.89 Culvert Across the Avoid putting poles in Low lying waterway liable to Road waterway flooding 53.02 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 53.5 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 53.82 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 54.63 Kuraw Kemo Kuraw Primary LHS 15 Health and safety concerns School during construction of poles. 54.95 Kuraw Kemo Group of 5 Mango RHS 6 Trim Trees 54.95 Kuraw Kemo Mango Tree LHS 5 Trim 55.27 Kuraw Kemo Private Compound LHS 5 Health and safety concerns during construction of poles. 55.27 Kuraw Kemo Tabo Tree RHS 5 Trim 55.3 Baobab Tree RHS 12 Trim 55.91 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding

Distance Location Features Position of App. Proposed Action Remarks from Feature along Ht/Dist. Laminkoto the Road from edge (Km) of road (m) 55.91 Baobab Tree RHS 5 Trim 56.72 Culvert Across the Avoid putting poles on Low lying waterway liable to Road waterway flooding 56.72 Drainage Gutter RHS 7 Avoid putting poles close to Gutter 56.88 Bus Stop RHS Health and safety concerns during construction of poles. 56.88 Baobab Tree RHS 5 Cut May impact the road corridor 57.04 Diabugu Batapa Bus Stop RHS Health and safety concerns during construction of poles. 57.2 Diabugu Batapa High Tension pole RHS 3 The Laminkoto- Diabugu T&D Line terminates here.

Two additional corridors, Kalem Jawbeh-Bush Town and Karantaba Tabokoto/ Karantaba Tenda, have been added to connect more communities. For these roads’ corridors, communities and their farmlands are far from the road right of way, construction will not impact people’s properties9 or assets. The branches or T-offs to connect the surrounding communities like Kunting, Dobo, Tankong, Jalokoto, Demba Kali and Jamagen; Karantaba Tabokoto and Tandy Bara (via Karantaba Tukulor, Tandy Mandinka, Baya bah will affect farmlands. There will be the need to develop a Resettlement Action Plan in order to address compensation for land acquisition and economic displacement under this project

9 There will be impact on agricultural land use which will not involve resettlement because of the very small land taken (4m square) and economic displacement which are accounted in the RAP already approved by the World Bank and EIB.

CHAPTER 5: CONSULTATION AND PUBLIC PARTICIPATION

5.1 Objectives of the Stakeholder Consultations It is important that communities affected by projects are given the opportunity to participate in the process of the project’s planning and implementation, particularly in the provision of information specific to the proposed project sites. Consequently, consultations were held with community stakeholders along the transmission line corridor.

The stakeholders in this project were identified after undertaking literature review and preliminary consultations; they were selected for consultation based on the level of their potential involvement in the project, as key stakeholders in relation to their institutional oversight of the project. In addition, their potential to be affected by the project (especially where their land, other assets and livelihoods will be impacted negatively) was another criterion in their selection for consultation.

Stakeholders included Government institutions such as NAWEC, NEA, National Roads Authority (NRA), the Technical Advisory Committees (TACs) of the Regional Governors’ Offices of CRR and URR, and other community members along the line corridor (including persons found under the sheds located along the road alignment). See Figures 5.1 and 5.2.

Figure 5.1: Meeting with stakeholders along the Laminkoto- Diabugu Corridor

The objective of the consultations was:

i. To provide information about the project and to tap stakeholder information on key environmental and social baseline information along the proposed line routing

ii. To provide opportunities to stakeholders to discuss their opinions and concerns

iii. To identify specific interests and to highlight potential roles and responsibilities of stakeholders and seek their approval and participation

iv. To inform the process of developing appropriate management measures as well as institutional arrangements for effective implementation of the ESMP

Figure 5.2: Meeting with the TAC in Basse, URR

In view of the above, different consultative sessions were held at different locations using different approaches, including one-on-one basis, as well as group discussions.

Key-stakeholder institutions (NAWEC, NRA, NEA, DOF, TACs, etc.) were visited to determine their respective potential roles and responsibilities in the implementation of the ESMP. The institutions were each visited at the level of the Headquarters, and also where applicable, at the Regional levels. For example, consultations were held with representatives of the DOF posted in the CRR/URR North for information on the existing forests and vegetation found within the region.

Given that the Regional TACs will be involved in monitoring of ESMP implementation, the two Regional TACs were also consulted at separate meetings held at the offices of the respective Regional Governors. At the meetings it became evident that the TACs capacities in ESIAs, and environmental management in general need to be developed to enhance their participation in the monitoring of the ESMP.

Even though Figure 5.2 shows only men at the URR TAC meeting, the Committee has women members as well. The current Chairperson of the URR TAC, the Governor is a woman, but was not in attendance during this meeting. At the CRR TAC meeting, Ms. Aunty Rohey Ceesay represented the DOF. Generally, in all the Regions (including the URR and CRR) female members of the TACs are far less than the male members. It will be noted that membership of the Regional TACs consist

exclusively of representatives of the different national institutions in the Regions. Their memberships, therefore, are based on whom the institutions decide to post in the Regions. Nonetheless, given that the female members are less than the male members, the Regional Governors should make all efforts for the female members to participate in TAC meetings to ensure as much gender inclusion as possible and/or encourage their attendance. The Project will also make sure that there are women representatives in the Grievance Redress Committee which will manage all complaints coming from Project Affected Persons in this area.

Consultations with community members and potential project beneficiaries were generally carried out using mainly group discussions. Typically, persons found sitting around along the road corridor under waiting sheds were interviewed as groups; where applicable, inhabitants of compounds located along the road were contacted, and interviewed on a one-to-one basis on their perceptions and views about the project. Overall, the communities are glad that NAWEC will provide them with electricity, and they hope that this will not take too long to materialize.

5.2 List of Persons Consulted and Views Expressed

Annex 1 indicates the list of institutions and persons met, and Annex 2 indicates the views and comments received during the consultations.

CHAPTER 6: ANALYSES OF POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS

6.1 Principles Used in Evaluating Significance of Potential Impacts The approach employed in evaluating the significance of the potential impacts took into consideration the characteristics of the impacts indicated in Table 6.1 and Table 6.2. Using qualitative and quantitative data from the literature review, consultations, visits along the proposed line corridor, and particularly subjective analyses using expert knowledge and experience, the following levels were employed:

(+2) High positive significance: Highly likely to promote sustainable development as beneficial to the receptors.

(+1) Low positive significance: There are some opportunities, possibilities, and alternatives for benefits to be gained as a result of the impact.

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

(-1) Low negative significance: Limited adverse impacts with main activities not focusing on the use of sensitive resources, and where prevention of negative effects is possible.

(-2) High negative significance: High vulnerability and sensitivity; irreversible impacts, etc.

Table 6.1: Some Factors used in Considering Significance of Impacts Impact Characteristics of the population such as distribution of women, youth, and the elderly; receptors economic activities including dependence on efficient electricity supply Habitats, distribution and protection status of animals and wildlife Types of vegetation, land cover and land use including wetlands, forest, and animal parks, historical or cultural sites Roads, underground water infrastructure, telecommunications, or other infrastructure that may be affected Receiving and response capacity of the receptors from similar projects or past incidents such as forest felling, social conflict, air, and soil pollution etc. Nature of Direct or induced impacts on the receptor; link with non-project activities or other projects impacts Timing: immediate or long-term effect; duration of the impact Magnitude in relation to the total affected area; number of trees, farmland, animals, or people; geographical extent, households, or towns/villages Probability of the impact occurring Cumulative impacts that only become an issue in combination with other impacts (construction of the road) Possibility of prevention or other mitigation measure; irreversibility of impact

Cumulative impacts were analyzed as the Project may exacerbate cumulative impacts as a result of a combination of issues from activities of the past, present or future, including natural phenomena. The distribution of such impacts may be local, regional, or global. These effects together, may cause significant impacts that would not have necessarily been relevant individually.

As discussed in Section 6.4, consideration of cumulative impacts may include combined effects of: • one activity on existing/previously affected parameter • many activities of the same project on various parameters/sites • many projects on the same • many projects on multiples parameters

Table 6.2: Evaluation of Significance of Potential Environmental and Social Impacts

SIGNIFICANCE OF POTENTIAL IMPACT DURING IMPACT ISSUE SOURCE OF POTENTIAL DIFFERENT PHASES IMPACT IMPACT Construction Operation Decommission (positive or negative)

PHYSICAL

Pollution of Surface Construction of line Turbidity of the -1 0 -1 Water across Sandugu Sandugu Bolong Bolong” (the only permanent surface water body along the line routing) Pollution of Ground Not Applicable Water demand 0 0 0 Water Air Quality Digging/excavation for Dust, exhaust -1 0 -1 Deterioration base camp construction smoke and other and pole gaseous erection/movement of emissions vehicles/use of quarry and construction material Geology / Soils Movement of heavy Erosion, soil -1 0 -1 vehicles and machinery compaction transporting materials and equipment to, and around pole construction areas during works

SIGNIFICANCE OF POTENTIAL IMPACT DURING IMPACT ISSUE SOURCE OF POTENTIAL DIFFERENT PHASES IMPACT IMPACT Construction Operation Decommission (positive or negative) Noise/Vibration Movement of heavy Noise nuisance -1 0 -1 vehicles and machinery around construction area during works Landscape/ Procurement of gravel Improper waste -1 0 -1 Aesthetics and sand material from management; quarries; use of Unsightly construction materials structures and supplies

BIOLOGICAL

Aquatic Ecosystem Construction of Turbidity of -1 0 -1 transmission line across Sandugu the Sandugu Bolong “bolong” leading (the only permanent to temporary surface water body loss of primary along the line routing) productivity that could potentially affect aquatic organisms Loss/disturbance of Land clearing/felling of Noise and -1 0 -1 terrestrial wildlife trees and vegetation habitat destruction/loss of species Loss of Agricultural Land clearing/felling of Loss of -1 0 0 land/ Livestock trees and crops/grazing grazing areas vegetation/excavation area from for erection of poles on change of land farmlands use/ loss of forest and vegetative cover Loss of Forest and Land clearing/felling of Felling and -2 -1 -2 Vegetation cover trees and clearing of forest vegetation/excavation trees /loss of for erection of poles grazing area, loss of forest trees During operation trees and vegetative are pruned periodically cover and to protect lines potential as Carbon sink

SOCIO-ECONOMIC

SIGNIFICANCE OF POTENTIAL IMPACT DURING IMPACT ISSUE SOURCE OF POTENTIAL DIFFERENT PHASES IMPACT IMPACT Construction Operation Decommission (positive or negative)

Public Health & pole erection and line Impact of -1 -1 -1 Safety stringing; working from accidents, waste, heights and traffic of dust, and noise, machinery and workers risk of SEA/SH for community and workers Occupational pole erection and line Impact of -1 -1 -1 Health & Safety stringing; working from accidents, falls, heights transport of dust, equipment and electrocution, workers handling large and heavy loads; risk of SH on work sites for female personnel Labor related Imported laborers Influx of labor/ -1 0 -1 issues spread of diseases such as sexually transmitted infections, risk of SEA/SH for community and workers Employment of Violence against -1 0 -1 children during project children, risk of implementation SEA for children Land Use / Involuntary Risk of SEA with -1 0 0 Ownership resettlement resettlement operations Siting of poles on Loss of land for -1 0 0 farmland agriculture Felling/pruning of Loss of asset -1 -1 0 private fruit trees Land clearing and Loss of -1 0 0 felling or pruning of customary use of forest trees within the forest and forested areas, such as other non-wood in Community Forests forest products Income Employment of local Generate 2 2 2 labor employment

SIGNIFICANCE OF POTENTIAL IMPACT DURING IMPACT ISSUE SOURCE OF POTENTIAL DIFFERENT PHASES IMPACT IMPACT Construction Operation Decommission (positive or negative) skills and trade/ improvement in household income; potential risk of household violence where women are employed as local labor and income generation for women shifts traditional gender norms Livelihoods Availability of Potential 2 2 0 electricity improvement of livelihoods/ leads to improved trades and skills Energy Availability of Electricity supply 2 2 0 electricity for economic development Vulnerable groups Availability of Benefits for 2 2 1 electricity women and children with household electricity, less time spent cooking and searching for firewood, which reduces risk and allows for greater opportunity for income generation; electrifying clinics and hospitals will improve the lives

SIGNIFICANCE OF POTENTIAL IMPACT DURING IMPACT ISSUE SOURCE OF POTENTIAL DIFFERENT PHASES IMPACT IMPACT Construction Operation Decommission (positive or negative) of the sick and elderly Cultural/Historical Siting poles within Cultural relics -1 0 0 the cemetery and and artifacts mosque

Matrix Key: 0 neutral - no discernible impact / insignificant impact 2 high positive significance -2 high negative significance 1 low positive significance -1 low negative significance

6.2 Potential Positive Impacts With the implementation of the project, the following benefits are expected:

1. Unskilled workers (mainly men) will be employed during the construction of the poles and stringing of lines, with the associated social benefits and improved living standards as a result of increased income. It is not usual in Gambia for women to be involved in such works, particularly within T&D construction; however, the project will ensure that both women and men can apply for employment opportunities without any impediments put in the way of women and applying gender-equitable recruitment practices. 2. Economic development and income generation from the supply of electricity will benefit specifically the population living along the line corridor, and generally the entire country. Specifically, women could be involved in the preparation and sale of food items (wonjo juice, pancakes, roasted ground nuts, etc.) to the workers, as is common in work construction sites.

5. With the potential for constant electricity supply and the possibility of more job creation prospects, this will encourage the youth to stay and work in their country, thus reducing the risky journeys to Europe.

6.3 Potential Negative Impacts and Mitigation Measures

The significant negative impacts identified are further analyzed, and mitigation measures recommended using the hierarchy from prevention, reduction, restoration, to compensation.

6.3.1 The Physical Environment: Potential Negative Impacts and Mitigation measures

Air Pollution In siting the poles and base camps, it is expected that existing trees and vegetation around the proposed sites for the poles and base camps will be cleared with the aid of either heavy machines such as bull dozers or excavators; the same machines could be used to dig the holes in which the poles will be placed in concrete. Alternatively, manual labor could equally be hired (presumably from within the communities) with the aid of machetes and cutlasses, shovels, and pickaxes to clear existing trees and vegetation, and to excavate to the required depth and width to hold the poles. However, given the expected size of the base of the poles (2x2m), the area required for each pole is quite small, and thus not much vegetation and trees will be expected to be cleared. The approximate area required for the base camps is not known at this moment, but during construction, dust pollution is expected from heavy vehicular movement, land clearing, excavations, and other related earthworks. The construction and decommissioning phases of camps also have the potential to affect local air quality and climate. Heavy machinery and vehicles will also release hydrocarbon incomplete combustion gases to the air, affecting air quality.

Nonetheless, whatever methods are employed in the above works will generate dust within the immediate area of the works but given that the planned route consists mostly of bushes and shrubs the dust and gaseous emissions, such as the oxides of carbon, etc. will only temporarily affect ambient air quality around the activity sites. Apart from the workers who will be immediately affected, this impact will be more significant in populated areas, where poles are to be erected close to compounds and other relaxation or resting areas such as waiting sheds, as compared to farms and open fields.

Mitigation Avoid unnecessary felling of trees and vegetation clearance as much as possible.

Provide information to the public to avoid pole construction and camp sites and put up adequate and appropriate signs at strategic locations to prevent public activities and access.

Camps must be located sufficiently away from human settlements (at least 500m)

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

Generation of dust • Wet road surfaces to suppress dust emissions

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

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

• Special care will be taken when working near educational institutions, football pitch or playground, mosque, clinics, and hospitals. This will include erection of barriers and posting of sign boards to warn against people intrusion into the work sites.

Gaseous Pollution • Equipment must be serviced frequently and run below the optimal as overloading strains the mechanisms that produce incomplete combustion. High quality oils must also be used to reduce dangerous air emissions

• Emission standards prescribed in the Discharge and Permitting Regulations must not be exceeded

• Ensure that vehicles’ engines need not idle for prolonged periods unnecessarily

Heavy Rainfall

Heavy rains will affect pole construction, especially half completed works, materials storage, etc.

The significance of the heavy rains has some bearing on the water level of the Sandugu Bolong (across which is the Sami Bridge at Km 39.2) especially in relation to the safety and wellbeing of the contractors during line construction. With a swell of the water in the Bolong, contractors working close to the banks could face some worker-safety issues such as falling into the Bolong, as well as from heights.

Locating poles on the banks of the bolong (the bolong is about 48m wide by the bridge and about five meters deep) could lead to poles collapsing due to erosion of the banks over time.

Numerous culverts have been constructed along the Laminkoto-Passimas highway (covering both regions) ostensibly to control storm water during the rains. Poles located close to the edges of culverts could collapse due to erosion of the culverts’ edges caused by storm water.

Mitigation

Plan and execute pole construction after the rainy season as this would prevent works from being interrupted due to the heavy rains; this could result to waste of materials especially cement aggregates which could be washed away when it rains heavily

The contractor should, avoid locating poles at the edges of culverts to prevent poles from collapsing as a result of erosion Workers should be trained and supervised in safe practices, such as daily inspection of equipment, and use of personal protective gear

Given that the minimum span between poles is 75 meters, (and the width of the bolong is 48 meters) contractors must not site poles less than at least 13.5 meters on each side of the bolong 10 to address possible erosion and collapsing of poles

Siting of poles near the culverts should be avoided to prevent poles collapsing when the edges of the culverts are eroded by storm water. Locate poles at least 5 meters from then edge of the culvert

Should construction works be carried out during the rains, ensure that materials (e.g., cement) and equipment are appropriately stored to avoid the rains.

Geology and soils Soils will be affected by the opening of quarries to extract construction materials for pole construction. Access roads to borrow pits may remain open after the project due to poor or incomplete site reclamation and restoration, encouraging illegal mining and waste dumping in the future.

Borrow pits that are not managed properly will pose risks to nearby communities; children and cattle in particular, are at risk of falling into them, and in the rainy season and could drown.

There is also possibility of soil compaction from the movement of heavy machinery and vehicles. This will open the bare areas to localized, temporary erosion risks and potential formation of new natural drainage routes during rainy seasons. Agricultural land may also be compacted, particularly with the creation of diversions within farmlands, affecting soil drainage and productivity.

Soils may also be polluted by hydrocarbon spills and improper disposal of solid and liquid wastes such as used oils, machine parts, inert wastes, packaging, cleaning water, etc.

Sand and gravel to be used for construction may be mined illegally from unapproved sites causing indirect, secondary negative impacts on landscape and vegetation.

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

• Copy of licenses should be displaced on site, or produced on request by the relevant national authorities

10 This is arrived at using the following: minimum pole span = 75 meters- 48 metres width of bolong/2 = 13.5 meters

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

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

• Only established transportation routes and diversions must be used to limit destruction and ensure reclamation is done at the end of the works

• Repair and reinforce access roads before start of works

• Improve surface drainage of existing routes by grading

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

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

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

In addition to construction rubble, poorly managed solid waste can result in creation of dumpsites which can have environmental health impacts. The effects from improper management may be long-term with localized negative impacts on aesthetics, health, and safety.

Laborers (especially imported laborers) will be housed in the camps and will generate such domestic wastes as food and sanitation wastes. Poor disposal of such wastes from the camps, has secondary potential impacts such as spread of disease, contamination of drinking water (including surface water), degradation of aquatic ecosystems and generation of greenhouse gases.

Mitigation Improved waste management measures shall be employed and enforced, and these will include the following, among others:

• Developing a waste management plan to include amongst others, the types of waste, expected quantities and frequency, proposed management procedures and responsibilities. The plan will indicate the following, among others:

i. Identification and classification (hazardous or not, solid, gaseous, or liquid) and estimate the likely type of waste generated such as cleared vegetation, packaging, excess aggregate, and disused equipment etc. If hazardous wastes are generated,

proper procedures must be taken regarding their storage, collection, transportation, and disposal as indicated in Hazardous material, 1994

ii. Minimizing the production of waste that must be treated or eliminated where waste generation cannot be avoided

iii. Using the cleared vegetation, as firewood within the communities

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

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

v. Recommending that the work contracts include waste management measures (as indicated in Annex 6) such as those described in World Bank’s Environmental, Health, and Safety (EHS) Guidelines (1.6 Waste Management) and EIB ESS2:

vi. Identifying and demarcation of approved disposal areas clearly indicating the specific materials that can be deposited in each.

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

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

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

Surface water quality The Sandugu “bolong” (over which the Sami bridge crosses) is the only permanent surface water encountered along the transmission route, and construction works close to it with heavy machinery could lead to soil compaction, and an increase in impermeable (or slowly permeable) surfaces could result in soil erosion and increase in sediment loads of the nearby “bolong”. This can lead to alteration of the flow regimes of the bolong, thereby affecting water velocity, depth, and channel morphology; accidental leaks/spills of oil/fuel from storage tanks or construction, will lead to pollution of the bolong.

High turbidity and change in the physical and chemical composition of the water will slow down flow and affect the local water biome and activities.

The chances of this happening are remote especially if pole construction activities are carried out away from the edge of the bolong.

Mitigation • Integrate all mitigation measures into the design to prevent or mitigate potential impacts. For example, siting of poles at a minimum safe distance from the bolong.

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

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

Landscape and aesthetics

For the duration of pole erection works, the aesthetically unpleasing landscape of the work sites will be visible (although with short-term impact) whilst any borrow pits created specifically for the project will be more long-term if not restored. There is also potential for unsightly areas where construction and other wastes are indiscriminately dumped.

Mitigation x. Equipment and materials not in use shall be removed from work sites, and public access prohibited

xi. Indiscriminate waste dumping will impact on the aesthetics of the vicinity

xii. A waste management plan (some of the elements are indicated above) must be implemented to avoid haphazard dumping and prevent associated health impacts

Noise and vibration Nuisance from noise and vibration is expected during construction of poles from operation of machines, and the large influx of workers. Potential victims or targets firstly to protect are the workers.

These localized impacts will disturb wildlife in the open fields and aquatic organisms in the short- term during the works. No sensitive sites of ecological importance or species have been identified.

Mitigation • All works must be carried out during daytime, between working hours, to reduce noise nuisance. In addition, the following must be observed:

o Use of well-serviced equipment shall also reduce nuisance, thus maintenance of vehicles, equipment and machinery shall be made o Provision of earplugs to workers exposed to high noise levels

6.3.2 The Biological Environment: Potential Negative Impacts and Mitigation Measures

Negative Impacts on Forest Vegetation and Wildlife

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

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

Mitigation In view of the above, deforestation shall be minimized by:

• Clearing only vegetation required • As the tress to be felled are forest trees, and thus belong to DOF, develop, and implement a tree replacement plan, with 1:4 replacement ratio to be implemented by DOF • Develop an MOU with DOF for the implementation of this mitigative measure • For loss of usufruct compensate PAPs on whose land these trees were felled

Fruit Trees ond Other Vegetation Loss of fruit trees along the line trajectory due to felling and/or pruning by NAWEC to protect the lines from tree branches will be of high magnitude impact to the farmer. Although felling of privately owned fruit trees is not envisaged in this project, the practice of tree pruning is an annual event, and each time it is carried out, the farmer will lose a part of his fruit tree; if, on the other hand and for whatever reason, a tree is felled the famer loses the tree permanently, and in the process his livelihood.

Pruning of fruit trees is carried out only when tree branches grow towards the ROW.

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

Mitigation • Although this project will not involve relocating people, but all persons affected by the project should be compensated as required by OP 4.12 and ESS6. In this regard, a resettlement action plan (RAP) shall be developed and implemented making sure that all persons affected by the project are compensated fully and fairly for lost assets

• Fruit tree pruning must be carried out only when tree branches grow towards the ROW

Fauna Terrestrial fauna, including reptiles and birds will be killed or disturbed by construction activities that create noise, create pollution, and destroy their sanctuaries.

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

According to the IUCN the Guinea Baboon is “near threatened” globally, although in the Gambia the population is of least concern, according to the Department of Parks and Wildlife Management (DPWM). Nonetheless, there are existing laws and regulations that accord general protection to certain species including the baboon, which must be enforced more rigorously.

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

Large birds with wide wingspans (such as certain eagles, hawks, and vultures) in flight and colliding with the lines or sitting on a single wire and touching another electric wire with a different voltage could get shocked and killed.

The project could create additional quarry pits. Flooded quarry pits usually create watering points for livestock and wildlife; however, their movement is hindered (especially if pits are too steep), and domestic animals may drown.

Mitigation • Supervision of works must be constant to ensure only necessary sites are cleared of vegetation

• Educate workers on guidelines relating to the hunting of wild animals

• Construction workers must protect natural resources and wild animals

• The Guinea Baboon population must be protected by: - Enforcing more vigorously the relevant laws and regulations that prohibit its killing - Conducting training and information meetings on its preservation and protection at community level - Creating community wildlife reserves where threatened species such as the baboon could be protected

• Hunting by the imported labor force will be prohibited, and offenders must be disciplined in any of the following ways:

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1. Informal warning 2. Formal warning 3. Loss of up to one week’s salary 4. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months 5. Termination of employment

• There should be a labor GM – to ensure that employees can report anonymously if needed to prevent risks of reprisals. The labor GM should be included in the C-ESMP and as part of the bidding documents

• Nesting grounds and migratory paths if any are to be protected

• To reduce risk of birds colliding with the lines, bird-flight diverters should be used; these are designed to make overhead lines and guyed structures visible to birds and provide an economical means of reducing the hazard to both lines and birds.

• Anti-nesting devices, or artificial nest platforms must be used to mitigate and reduce risks to the avifauna

• All quarry pits created by the project must be rehabilitated after construction works are finished

6.3.3 The Socio-economic Environment: Potential Negative Impacts and Mitigation Measures

Loss of vegetation and range Tree felling and clearance of vegetation could lead to loss of vegetation and range land for cattle and thus impact on livelihood of cattle owners.

Mitigation All loss of livelihood, including rangeland, firewood, and other forest produce collection will be addressed in a RAP. Any compensation schemes to address loss of livelihood or access to property or land must address potential exclusion of women or other vulnerable groups.

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

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Pole construction and stringing within congested areas such as the Loumo market site at Sami pose potential health and safety issues for owners of sheds and other structures located within the market. Some of the structures could be directly under the lines.

Vector-borne diseases are spread when stagnant water accumulates in active or abandoned quarries or borrow pits and breeds insect vectors, resulting in spread of communicable diseases including malaria.

Communicable diseases of most concern due to labor mobility are sexually transmitted diseases and infections (STDs/STIs), TB, such as gonorrhoea, and HIV/AIDS, due to influx of workers to the area, especially where imported laborers live within the communities. The influx of workers also increases risk of SEA for members of surrounding communities, including women who may be working or circulating as vendors at the work sites as well as children who may be living near the work sites. Female personnel, who may be employed by project contractors, are also at risk for workplace-related SH.

Mitigation • Warning and safety signs must be used before commencement and during the works to inform and warn the public of risks and means of avoidance, including signage addressing prohibition of SEA/SH and how to report incidents confidentially

• Sites must be cordoned off during construction works and proper lighting should be provided for night safety, including safe, well-lit, lockable, and sex-segregated sanitation facilities

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

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

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

• The “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), including Sexual Exploitation and Abuse (SEA), Sexual Harassment (SH), and Violence Against Children (VAC)” will also be included in contracts including explicit references for monitoring, enforcement and compliance (as per Annex 7, and its annexes included in this ESIA/ESMP report), and workers will be trained on SEA/SH, prohibited conduct, and applicable sanctions as outlined in the codes of conduct

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• The project, as well as any contractors, must develop specific complaint procedures, including a response protocol, as part of the grievance mechanism in order to receive and manage SEA/SH complaints ethically and confidentially

• Communities need to be informed beforehand about the start of works, and the need to keep children and youth away from the sites

• Awareness campaigns/orientation covering, but not limited to, HIV/AIDS/STDs transmission risks, as well as risks for SEA/SH, shall be carried out for workers and host communities, including information on prohibited conduct and how to report any incidents safely

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

• At the Sami and Karantaba weekly markets construction works must be carried out only on non-market days

• Alternatively, the routing of the line can be changed, and be located behind the markets, to avoid the congested areas

Occupational Health and Safety Accidents from equipment use, construction works, falling from heights, noise and dust may affect workers on the project; workplace-related SH is also a risk, especially for female personnel. Accidents and injuries could also arise from:

i. Exposure of community members and work crew to risk of falling during line stringing, and injuries from falling into excavation pits

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

iii. Operation of machinery endangers both operators and laborers

iv. Injury/accident due to lack of warning signs, site barricades and safeguards

However, the likelihood of accidents happening during these periods are low to moderate, given the small-scale nature and low-level technology expected to be employed in the course of project implementation. Nonetheless, the following measures are important to be taken: Mitigation

• must be prepared and implemented by the Contractor. At the minimum, it must consist of the following elements: i. Management Policy Statement ii. Authority and Accountability iii. Goals and Objectives

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iv. Employee Commitment and Responsibilities v. Employee Involvement vi. Disciplinary Policy vii. Record Keeping viii. Health care and monitoring of staff

ix. Safety and Health Surveys and Inspection/Program x. Safety or Other Related Meetings xi. Safety and Health Training xii. Safety Audit and Inspection xiii. Accident and Hazard Investigation xiv. Accident Reporting and Investigation xv. Simulation exercise and Revision of Components xvi. Risks associated with the contamination and spread of COVID-19 and preventive measures

xvii. Risk of SH within the work environment and associated risk mitigation measures (these can likewise be outlined in the contractor’s SEA/SH Prevention and Response Action Plan) xviii. Danger of accidents and injuries from utilities and other equipment and machinery during the construction phase shall be monitored vigorously; to prevent and protect the communities from harm, the contractor shall mount safety cordons and danger signs where necessary

xix. Provision of protective gear appropriate to the type of activities to be undertaken

xx. Workers should be trained in good practices and contingencies measures prior to start of works

xxi. Provision of first aid kits and training on their use is important. This is important for workers to use in minor accidents during construction

• Danger of accidents and injuries from utilities and other equipment and machinery during the construction phase shall be monitored vigorously; to prevent and protect the communities from harm, the contractor shall mount safety cordons and danger signs where necessary

• Provision of protective gear appropriate to the type of activities to be undertaken

• Workers should be trained in good practices and contingency measures prior to start of works, including on SEA/SH, prohibited conduct, applicable sanctions, and how to report such incidents safely

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• As noted above, workers will also need to sign codes of conduct prohibiting SEA/SH and outlining applicable sanctions • The project, as well as any contractors, will also need to develop specific complaint procedures, including a response protocol, as part of the grievance mechanism in order to receive and manage SEA/SH complaints ethically and confidentially

• Provision of first aid kits and training on their use is important. This is important for workers to use in minor accidents during construction

• There is also a need for reporting incidents to address causes for preventing recurrence. Workers must continue to be educated on health and safety including use of personal protective gear

The Contractor will strive to source the workforce locally to reduce the need for importation of workers, and adequate domestic and hygiene facilities provided to avoid workers requesting such from the communities • The contractors should provide or give workers access to adequate services including water, food, sanitation, rest time and waste disposal facilities

Land Ownership and Land Use

The land-take (especially agricultural land with crops during the rainy season) by the project will essentially be confined to the area required for the base of the pole, approximately 2x2m, and is thus of low impact. However, when the works are completed, and the base buried sufficiently the area could be used for cultivation again.

During line stringing the main activity will involve pulling and stretching of the lines between poles, and in the process, crops growing close to the line trajectory (especially when the works are done in the farming season) will be trampled upon by the workers and thus destroy them. Loss of one season’s harvest for a small portion of the land could result.

The size or area of impact will depend on the level of care and diligence exercised by the contractor, since the stringing operation will be from one pole to the next, and this could be a distance of a minimum of 50m to a maximum of 100m between two poles; thus, the severity of the impact could be moderate to high, with the farmer losing crops and part of his livelihood.

Sites of weekly markets (Karantaba and Sami) could be disturbed during pole construction and stringing and thus lead to potential loss of earnings especially if works are carried out on market days

Mitigation • To enable future use of the area occupied by the base of the pole, the Contactor must bury the base of the pole to below ground level to facilitate soil covering up the area and encourage crop cultivation

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• Contractor must ensure to use the maximum allowable distance between poles to reduce the number of poles that would potentially be located within a single farmer’s field

• Construction works should preferably be carried out outside the farming season to avoid destroying crops; if unavoidable, crops destroyed during the works must be compensated

• Construction works should preferably be carried out outside Loumo (market) days to avoid impacting shops and vendors’ income and revenues

• Communities, especially women and other vulnerable groups that might be affected more significantly and subject to exclusion, should be specifically consulted, in safe and confidential environments, to ensure that appropriate and responsive mitigation measures are applied, to avoid discrimination, and to ensure appropriate compensation

Community Stability and Cohesiveness including impacts from Labor Influx Overall, the communities are supportive of the project; however, grievances and conflicts may arise especially where negative project impacts (e.g., loss of land and/or crop due to pole construction and stringing, partial or total loss of economic trees, labor influx and impacts to community and intimate partner relationships, etc.) and community expectations are not clearly relayed in a timely manner.

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

Disadvantaged and vulnerable groups (including women farmers whose crops could be destroyed, female-headed households, the elderly, persons with disabilities, etc.) may be at risk of being left out during the process of stakeholder consultations due to their inability to get to consultation venues, and thus will be excluded.

There is also a risk of SEA/SH as well as VAC, particularly with the use of child labor, as a result of labor influx with workers from outside the community.

Furthermore, the arrival of workers from outside the region could disrupt existing community values and norms, as well as social cohesion, community stability, and interpersonal relationships within and among families.

Mitigation • Initiate extensive consultations and sensitization with the communities and project affected persons about eligibility and compensation requirements as well as SEA/SH- related risks, prohibited conduct, and how to report all types of complaints • Use the already established Grievance Mechanism (GM) at the GERMP PIU for prevention and resolution of conflicts arising from complaints and grievances relating to compensation and resolution of complaints, including inclusion of specific complaint procedures and a response protocol for the ethical and confidential management of SEA/SH-related complaints

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• A GM will involve a Grievance Redress Committee (GRC) to investigate all complaints and grievances from PAPs relating to, for example: eligibility for compensation; PAPs not listed; etc.; note that separate procedures for SEA/SH complaints will incorporate a separate verification structure to ensure safety and confidentiality • Particular attention should be paid to the needs of disadvantaged and vulnerable groups among those impacted by the project. The development of a Resettlement Action Plan (RAP) must identify and consult with them, in safe and confidential settings with groups and facilitators of the same sex, and address any potential risks that will deprive them from benefitting appropriately from resettlement benefits • Children must not be employed by the project, and the project must comply with all relevant local legislation, including labor laws in relation to child labor and minimum age for employment • Employing local workers enhances community cohesion as local workers know the community, culture, and norms which may also help decrease risks related to SEA/SH, spread of STDs and so on, as workers know the community and vice versa. As such, the Contractor will be required to have a hiring plan to incorporate local workers. • Contractor to develop a hiring plan to ensure that community labor is being used, and also to ensure that women are employed in the project and that gender-equitable recruitment practices are applied • Apply the Code of Conduct (see in Annex 7) in order to mitigate against risks of SEA/SH and VAC in project site; prior to the start of work, the staff will be well sensitized, and they will sign and be trained on the codes of conduct, including prohibited behavior and applicable sanctions. Ensure regular trainings and awareness-building on the Codes of Conducts, as well as the relevant complaint procedures under the GM and available support services for survivors of SEA/SH, among all key stakeholders (community, contractor, workers), which will also be included in contractor’s C-ESMP and in bidding documents.

Chance Finds and Cultural Heritage and Archaeology Besides the village cemetery in Karantaba Wollof/Tabokoto, there are two mosques in Laminkoto and Karantaba Tabokoto respectively; these are culturally sensitive sites.

There is also a possibility of finding other cultural heritage by chance, particularly during land clearing and preparation for works. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

Mitigation Contractor must avoid all three sites (the 2 mosques, and cemetery), and not locate any works within 2 meters from them.

In addition, should an unusual, uncommon or atypical finding be made, the Chance Find Procedures described in Annex 3 will be applied: avoid further disturbance and secure discovery, inform the supervisor for onward conveyance to NAWEC and the National Council for Arts and Culture (the legal institution responsible to manage cultural heritage).

Risk caused by Force Majeure

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All reasonable precaution will be taken to prevent danger to the workers and the public from fire, flood, drowning, or any calamity. All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

6.4 The Potential Cumulative Impacts • This Project may give rise to the following cumulative impacts on the biophysical and socioeconomic environment: As the T&D line follows the existing highway, poles will be erected along the edge of the road which may be boundaries of agricultural fields. Previous loss of agricultural land, or the composition and quality of the soil during the road construction would, in addition to potential disturbance of agricultural land during this project, potentially affect farmers once again. Moreover, larger farmlands too close to the road would be more affected where more than one pole is located along the farm. • As reported by Forestry Officers, community forests along this route were affected previously during the road construction; these same forests may be further affected by this project if control measures are not implemented. • In addition, collective loss of vegetation and consequential disturbance of forests and wildlife habitat, particularly for access during works and indirectly at quarrying sites, may cause fragmentation of biodiversity and potential change to the variety of species as wildlife tend to adapt or move in response to continuous changes in habitat. This could also adversely affect the livelihoods and food security and cultural practices of the community, including women who may depend on access to these resources for food production and livelihoods. • As earlier discussed in Chapter 4, there is an existing concrete drainage gutter right next to the fence of the Forestry Office in Karantaba Dutu Koto (about 5m from the road). Constructing a pole within this site would mean damage to the fence and gutter which could lead to flooding and erosion, particularly in combination to severe weather conditions such as continuous heavy rainfall. • Excavation activities, increased worker population and vehicle traffic in remote areas at the same time during construction will create a combination of nuisances and reduced tranquility as a result of noise, vibration and air pollution. • Cumulative impacts from similar projects in future, such as adding extra circuit lines to existing poles, will have minimal combined effect as compared to construction of another line along the same routes. • Potential visual disturbance is likely in the future where electricity transmission lines and lines of other services compete for space, for example, crisscrossing of telecom and electricity lines. In certain areas, poles may be situated near similar structures with adverts or road signs creating unaesthetically pleasing sights collectively. For example, at the Karantaba Tabokoto and Karantaba Wollof Junction, there are existing road signs plus a telecommunications tower; the T&D lines and poles to be constructed will add to the eyesore. • The cumulative impact from potential public health and occupational health and safety risks (falls, electrocution, effects of air and noise pollution, diseases, SEA/SHGBV, VAC etc.) associated with the project should be noted as various hazards will be present simultaneously during works, creating an environment for increased probability, frequency and number of incidents. The more the number of workers, the more the cumulative nature of the potential impacts and the need for more stringent supervision and

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monitoring to ensure safety, compliance, credibility, and social cohesiveness, including specific measures to address SEA/SH-related risks and ensure the safe and confidential management of such highly sensitive claims. Mitigation The cumulative impacts can be mitigated by ensuring that the measures, discussed in Section 6.3 and summarized in Chapter 7 on the identified impacts, are fully implemented. These include working outside the farming season, avoiding forests and unrelated removal of vegetation, strategically locating poles, developing and implementing the C-ESMP, as well as providing information and educating workers and communities on critical health and safety concerns in addition to ensuring that stakeholders know where to seek assistance and report violations. Future cumulative impacts may be mitigated by studies done and implemented at that time.

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CHAPTER 7: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

7.1 Matrix on Mitigation of the Identified Potential Impacts

Table 7.1 illustrates the proposed mitigation measures for the potential impacts identified during all project activitites; specific mitigation measures have also been highlighted for the various activities (pole construction and stringing, operation of the tarnsmission line, and quarries).

Responsibilities for specific mitigation measures, period of expected mitigation, and responsibility for monitoring have been identified.

A monitoring plan with frequency and indicators is further outlined in Table 8.2, and an estimate for the cost of mitigation has also been provided in Table 8.4.

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Table 7.1: Potential Impacts and Corresponding Mitigation Measures Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) CONSTRUCTION WORKS (EXCAVATION FOR POLE CONSTRUCTION AND STRINGING OF LINES) Locating poles within Involuntary resettlement of Prepare and implement NAWEC/PIU Before TAC (to be For RAP budget farmlands and markets PAPs; loss of crops and a RAP to consider all construction coordinated earnings; loss of livelihoods farmland lost; loss of works start by the NEA) livelihood sources, etc. Works within market and Contractor During works TAC - Loumo (weekly market day) sites must not be carried during Loumo days Risks of SEA/SH and VAC; Conduct community NAWEC/PIU All phases URR/CRR TAC 17,000 +18,000 = discrimination against sensitization meetings where 35,000 for l capacity women in employment about the need for NAWEC/PIU is building and GBV everybody to benefit opportunities and in co-opted as a mapping and Action from project activities accessing project and member Plan irrespective of sex, and resettlement benefits, etc. ensure awareness of SEA/SH, prohibited conduct, applicable sanctions, and GM complaint procedures for SEA/SH and available services

Ensure codes of conduct outlining prohibited SEA/SH-related conduct

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) and applicable sanctions, as well as relevant provisions related to SEA/SH risk mitigation, are included in the contractor’s ESMP and bidding documents Monitor risks for NAWEC/PIU All phases Affected - escalating tensions communities Encourage women and NAWEC/PIU All phases URR/CRR TAC - other vulnerable groups where to raise their concerns NAWEC/PIU is on the resettlement co-opted as a process by organizing member independent consultations in safe and confidential environments, with groups and facilitators of the same sex Encourage women to Contractor All phases URR/CRR TAC/ Contractor’s budget apply for employment in NAWEC/PIU project activities without any impediments put in their way and ensure application of gender- equitable recruitment practices

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Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women

50/50 sharing of project and resettlement benefits between men and women

Enforce with signature and monitor codes of conduct for workers and all those involved in the project, ensuring that the codes outline prohibited SEA/SH conduct and applicable sanctions

Sensitize about the codes of conduct and SEA/SH for workers and community members,

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) including prohibited conduct, applicable sanctions, and GM complaint procedures Ensure survivor-centered approach to address SEA/SH complaints by setting forth specific procedures under the GM, including a response protocol, to manage SEA/SH claims ethically and confidentially

Conduct periodic training of employees on the codes of conduct, prohibited behaviors, applicable sanctions, and GM complaint procedures for handling SEA/SH claims

Include the above NAWEC/PIU Before works TAC (to be - measures in bidding coordinated documents for by the NEA) contractors to enforce on their employees,

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) including a SEA/SH Prevention and Response Action Plan for the contractor Felling and pruning of Compensation of PAPs; loss Prepare and implement NAWEC/PIU Before TAC (to be For RAP budget economic trees and of livelihoods and access to a RAP to consider all construction coordinated impacts on livelihoods resources farmland lost; loss of works start by the NEA) livelihood sources, property, etc. Pruning of fruit trees should be carried out only when tree branches grow towards the ROW

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) Encourage women and NAWEC/PIU All phases URR/CRR TAC - other vulnerable groups where to raise their concerns NNAWEC/PIU on the resettlement is co-opted as process by organizing a member independent consultations in safe and confidential environments, with groups and facilitators of the same sex 50/50 sharing of project NAWEC/PIU All phases URR/CRR TAC - and resettlement where benefits NAWEC/PIU is co-opted as a Enforce with signature member and monitor codes of conduct for personnel, ensuring that the codes outline prohibited SEA/SH conduct and applicable sanctions

Ensure survivor-centered approach to address SEA/SH complaints by setting forth specific procedures under the

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Conduct periodic training of project personnel on the codes of conduct, prohibited behaviors, applicable sanctions, and GM complaint procedures for handling SEA/SH claims

Land clearance and Loss of vegetation along line Remove vegetation Contractor Before and during URR/CRR TAC - preparation corridor around pole site only as works where necessary NAWEC/PIU is Conduct community co-opted as a sensitization meetings member about the need for everybody to benefit from project activities irrespective of sex, and ensure awareness of SEA/SH, prohibited conduct, applicable sanctions, and GM complaint procedures

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) Cover pole’s concrete Contractor During and after URR/CRR TAC Contractor’s budget and revegetate pole area works where to maintain vegetation NAWEC/PIU is co-opted as a member Destruction of forest trees Ensure that only the Contractor Before and during NAWEC/PIU/ See above and effect on the right of way, if any, is works TAC with DOF environment, landscape, cleared; avoid forests leading drainage, and wildlife Seek approval from DOF process before forest trees are felled Keep records of all ‘forest trees’ on to be felled Educate and warn workers to avoid burning activities Hunting by imported Contractor Before, during NAWEC/PIU/T - workforce will be and after works AC prohibited;

All employees, including volunteers and sub- contractors encouraged to report suspected or actual acts of hunting/killing of wild

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Disciplinary measures Contractor During works NAWEC/PIU/T Contractor’s budget must be applied AC The Guinea Baboon Contractor/D During works NEA/PIU/TAC Contractor’s population must be PWM budget/PIU protected by:

Enforcing more vigorously the relevant laws and regulations that prohibit its killing

Conducting training and information meetings on its preservation and protection at community level at least once every quarter

Creating community wildlife reserves where threatened species such as the baboon could be protected

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) Nesting grounds and Contractor Before, during NAWEC/PIU/T - migratory paths, if any, and after works AC are to be protected Develop and implement NAWEC/PIU/ Before, during DOF For RAP budget tree replacement plan, DOF and after works with 1:4 replacement ratio Soil compaction from Use only approved and Contractor During works TAC/Communi - vehicles / machinery existing routes ties destroying farmland and Do not establish new Contractor During works TAC/Communi - causing erosion routes ties

Grade existing routes to Contractor During works TAC/Communi Contractor’s budget improve surface ties drainage Destruction of cultural, Inform relevant parties NAWEC/PIU/ Before and during NEA, NCAC - historical, or archaeological of the Chance Find Contractor works sites Procedures and apply where applicable Avoid the two mosques Contractor Before and during TAC/Communi - in Laminkoto and works ties Karantaba respectively, and the cemetery at Karantaba, or similar sites of religious or cultural importance Consult with community Contractor Before and during TAC/Communi - to help identify any works ties

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Loss of livelihoods (e.g., Prepare RAP NAWEC/PIU Before beginning TAC (to be For RAP budget rangeland, firewood, etc.) of works coordinated by the NEA) During all land Noise and vibration Integrate ESMP into Contractor In contract before TAC/Communi - preparation and nuisance, and air pollution Contract Bidding works and during ties construction activities from dust and hydrocarbon Documents to ensure works including establishment non-combustion emissions compliance by of base camp(s) Contractor Works shall only be Contractor In contract before TAC/Communi - carried out during works and during ties daytime works Use dust suppression Contractor During works TAC - measures such as dampening Provide masks and Contractor During works TAC Contractors’ budget necessary gear to workers with the aim of preventing dust related health problems and other dust nuisances Use well-serviced Contractor During works TAC Contractor’s budget equipment and machinery; avoid

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) overloading that strains the engines Wet road surfaces to Contractor During works TAC Contractor’s budget depress dust Trucks transporting sand Contractor During works TAC Contractor’s budget and gravel must be covered to prevent dust and flying debris Ensure that vehicles’ Contractor During works TAC Contractor’s budget engines need not idle for prolonged periods unnecessarily

Special care will be taken Contractor During works TAC Contractor’s budget when working near educational institutions and health centers such as:

Giving prior notice to the institution about the works

Cordoning off work sites to prevent access

Working during weekends when

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Reduction in water quality Protect water sources Contractor, During works TAC, DWR - of the Sandugu Bolong due and report any communities to construction works noticeable reduction in quality Improper management of Develop a waste Contractor Develop plan NEA Contractor’s budget wastes (solid and management plan before works, and liquid/used oils, machine including types of waste, implement during parts, and domestic and expected quantities and works sanitary waste, excess frequency, proposed materials left on sites, storage and disposal cement bags, etc. procedures and responsibilities, etc. Waste must be collected Contractor During works NEA - and stored for disposal or treatment at approved sites as per waste management plan Clean waste such as Contractor During works NEA - cleared vegetation, packaging and rubble shall be given to workers or communities for reuse and recycling Manage wastewater in Contractor During works NEA - accordance with

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) international standards such as IFC EHS Guidelines, and the national Environmental Discharge (Permitting) Regulations 1999, and the Environmental Quality Standards Regulations, 1999 Ensure waste NAWEC/PIU In contract before NEA - management issues are works and during incorporated in works Contractor’s Contract Unpleasing landscape and Remove excess and Contractor During works NAWEC/NEA - impact on aesthetics unused materials and equipment from work sites Replace lost vegetation NAWEC/PIU During and after TAC RAP budget cover works Risks to public health and Restrict and monitor Contractor/c During the works NAWEC/PIU - safety at construction sites public access to the work ommunities (pole sites, quarries, camp sites sites, etc.) imported Construction works Contractor During works NAWEC/NEA - diseases, dust and noise within the Loumo area etc.) on a market day must be avoided

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) Cover up the trucks, to Contractors In contract before TAC Contractor’s budget prevent wind blowing works and during Community away sand and gravel to works generate dust Initiate sensitization and NAWEC/PIU In contract before NEA, For capacity building education programs on Contractor works and during TAC, Labor budget the dangers and Department mitigation measures to address STIs, including links with SEA/SH and prohibited behaviors under code of conductEncourage use of condoms to prevent STIs, ensuring simultaneous sensitization on links with SEA/SH and prohibited behaviors under code of conduct Contractor Before and during TAC, Contractor’s budget Carry out active works Department of monitoring of workers Health (screening, testing and Services analysis of such recorded data, etc.) to take timely action through treatment and health

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Ensure surroundings are Contractor Before and during TAC/Departme Contractor’s budget safe and secure for all, works nt of Health including provision of Services sex-segregated, well-lit, secure, and lockable sanitation facilities for personnel (implement health and safety plan, coordinate, inform, supervise and monitor) Risk of SEA/SH and VAC Enforce with signature Contractor Before and during TAC, Contractor’s budget and monitor codes of works Department of conduct for workers and Health all those involved in the Services project, ensuring that the codes outline prohibited SEA/SH conduct, including child labor, and applicable sanctions

Sensitize about the codes of conduct and

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) SEA/SH for workers and community members, including prohibited conduct, applicable sanctions, and GM complaint procedures

Ensure survivor-centered approach to address SEA/SH complaints by setting forth specific procedures under the GM, including a response protocol, to manage SEA/SH claims ethically and confidentially

Conduct periodic training of workers on the codes of conduct, prohibited behaviors, applicable sanctions, and GM complaint procedures for handling SEA/SH claims

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) Ensure that worksites have sex-segregated sanitation facilities and lodging that are well-lit, secure, and lockable

Ensure that the above mitigation measures are included in contract and bidding documents, including a SEA/SH Prevention and Response Action Plan for the contractor Do not employ or exploit Contractor Before and during TAC, Contractor’s budget children for project works Department of works. Ensure Labor enforcement and sensitization measures regarding SEA/SH and VAC, as noted above, are included in contract and bidding documents. Risks to health and safety of Provide induction and Contractor/P Before and during TAC/Labor Contractor’s budget workers (work related training on the job, IU works Department stress, heat stress, safety issues and other NAWEC

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) electrocution, falls, relevant ESMP mechanical accidents, requirements human conflict, wildlife Sensitize and train Contractor Before and during NAWEC/TAC Contractor’s budget attacks, poor handling workers on interpersonal works techniques, diseases etc.). relationships between and among workers and community members, including prohibited behaviors related to SEA/SH; set and enforce codes of conduct that outline prohibited conduct and applicable sanctions Provide appropriate gear Contractor Before and during NAWEC/TAC Contractor’s budget (helmets, masks, safety works goggles, hand gloves and rubber boots, etc.) to workers Provide first aid kits and Contractor Before and during NAWEC/TAC Contractor’s budget training on their use works Ensure that worksites Contractor Before and during NAWEC/TAC Contractor’s budget have sex-segregated works sanitation facilities and lodging that are well-lit, secure, and lockable Ensure GM for workers Contractor Before and during NAWEC/TAC Contractor’s budget to report incidents, works

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) including SEA/SH, in order to address causes for preventing recurrence and ensuring accountability QUARRY SITES Quarrying for earth Quarrying impacts on Ensure approval is NAWEC/ In contract before NEA/Geology - materials (gravel/sand) geology, landscape, ground obtained from the NEA, Contractor works Department water, wildlife, and GD for all proposed During works agriculture, etc. quarry sites Fully implement the Contractor During operation NEA/Geology - mine management plans of quarries Department All quarry pits created by Contractor After works are NEA/Geology Contactor’s’ budget the project must be completed rehabilitated after construction works

Indirect water Avoid extraction to the Contractor During operation NEA/Geology - contamination by exposure water table and near of quarries Department of groundwater from over surface water bodies extraction Decommissioning/closu Sites open to illegal Proper closure and NAWEC/ After mining, NEA/Geology - re of quarries exploitation after the timely restoration and Contractors before end of Department Project rehabilitation of borrow works pits Monitor sites and report Communities After mining or NEA/Geology - illegal activities quarrying for Department

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Activity / Issue Potential Negative Impacts Proposed Mitigation Mitigation Mitigation Period Monitoring Budget (USD) Measures Responsibility Responsibility (No value = included in PIU’s safeguards activities) gravel and sand by the Project Dismantling and During decommissioning, As per the construction Contractors During TAC/NAWEC Contractor’s budget transportation of all potential impacts on phase for mitigation of decommissioning materials and public and occupational public and worker health equipment from the health likely during and safety; camp(s) construction, are also significant Poor aesthetic quality from Implement Waste Contractors During TAC/TAC/NAW -Contractor’s budget excess materials and waste Management Plan decommissioning EC abandoned on camp sites Risk of fires and explosions Remove all fuel storage Contractors During TAC/NAWEC - from abandoned fuel facilities decommissioning facilitates Total 35,000.00

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CHAPTER 8: ESMP IMPLEMENTATION AND MONITORING ARRANGEMENTS

8.1 Roles and Responsibilities for ESMP Implementation a) PIU

Implementation of this ESMP is the responsibility of the Contractor and PIU. Most of the mitigation measures as indicated in Chapter 7 are the responsibility of the Contractor who will be carrying out the works according to the C-ESMP that will be based on the project ESIA/ESMP.

As the Secretariat of the EIA Working Group11, and supported by its members, NEA will be responsible for overall external monitoring of the ESMP implementation; in collaboration with the PIU environmental and social safeguard specialists, they will monitor compliance with the Banks’ policies as they relate to the environmental aspects of this project. In addition to the permanent members in the EIA Working Group, other institutions on ad hoc basis will include those specialized in social aspects such as the Women’s Bureau, Department of Social Welfare, Department of Labor, and Department of Health Services, amongst others.

Meanwhile, monitoring implementation of the social aspects of the project, including SEA/SH-related risks, in line with the Banks’ safeguard instruments will be the responsibility of the PIU social safeguards specialist.

NEA will also provide technical support and participate in training and sensitization of stakeholders to enhance understanding of the national and the WB and EIB environmental safeguards instruments. Technical advice and/or regulatory information and support will be provided by the Department of Forestry (DOF) for all forest related issues; the Department of Physical Planning and Housing (DPPH) and the Department of Lands and Surveys (DLS) will be responsible for addressing resettlement issues.

11 The EIA Working Group is one of nine multisector technical groups located at NEA. Nationally, NEA is the custodian of the ESIA process, and is supported by a multisector EIA Working Group which comprises the public sector, private sector and civil society, and at the Regional level, it is represented by the EIA/ANR (Agriculture and Natural Resources) Working Group sub committees of the Technical Advisory Committees (TAC). A major responsibility of the EIA Working Group (whether at central or regional level), is to provide support to the NEA in assuring the quality and integrity of the EIA process. Specifically, it:

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b) GERMP Project Steering Committee (PSC)

The GERMP Project Steering Committee (PSC), chaired by the Permanent Secretary, Ministry of Petroleum and Energy, will oversee all the activities of the GERMP, including the implementation of the ESMP and any other relevant safeguards document such as a possible RAP. The Permanent Secretary, MOLRG will be on the GERMP PSC due to the importance of the potential resettlement issues on land-take related to location of poles, and social issues relating to possible felling or pruning of private economic trees along the line corridor.

The PSC’s roles and responsibilities include: • Oversee and monitor overall implementation of the GERMP safeguard documents including the ESMP, and any possible RAP • Review and address all issues relating to resettlements and disputes • Review and monitor the progress reports • Visit the project sites to ensure progress of work and other activities

c) GERMP Project Implementation Unit (PIU)

The GERMP PIU will consist of the following, among others: • Project Coordinator • Environmental Safeguards Specialist (ESS) • Social Safeguards Specialist (SSS) • Technical Specialist (TS) • Monitoring and Evaluation Specialist (M&ES)

The PIU will oversee the implementation of this project, including this ESMP. Its other responsibilities will include:

• Ensure alignment of the environmental and social standards applied to the project • Work with the technical and procurement teams to ensure that contract documents contain environmental and social safeguard clauses that contractors must fully implement • Coordinate internal monitoring and evaluation of the ESMP based on monitoring plans • Coordinate project related to addressing grievances • Where applicable, facilitate project related activities of partner stakeholders

d) National Environment Agency

NEA will be responsible for overall monitoring of ESMP implementation, particularly the environmental side only. According to Section 31 of the EIA Regulations, 2014, NEA will monitor routinely to guide and audit the progress of the ESMP implementation to ensure compliance with both national laws and the policies of the Banks; NEA’s mandate is to monitor the national environment, and so in collaboration with the PIU safeguard specialists, can also monitor compliance with the Banks’ policies as they relate to this project. The monitoring visits should be at least once quarterly, to provide technical advice and support in project implementation.

e) Ministry of Lands and Regional Governments

In view of the possibilities for the project to impact patches of agricultural plots along the line corridor, and thus trigger resettlement, the MOLRG will play a crucial role in the development and implementation of any RAP that may arise because of the project.

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8.2 Specific Roles and Responsibilities

a) Project Coordinator (PC) The PC will oversee the implementation of the project, and consequently this ESMP and will have the responsibility for ensuring that implementation of this ESMP is carried out as required under the national law and the Banks’ Procedures.

b) Environmental Safeguards Specialist (ESS) The ESS will provide day-to-day management for all environmental issues and activities including implementation of this ESMP, in collaboration with NEA. The ESS will prepare progress reports for submission to the PIU for transmission to the PSC, NAWEC and the Banks.

c) Social Safeguards Specialist (SSS) The SSS will provide day-to-day management for all social issues, including SEA/SH risk, as they relate to implementation of any resettlement issues; prepare periodic reports on progress on social issues; prepare progress reports on the level of potential PAPs, and their participation in project activities on the issues of resettlement. These reports will be submitted to the PIU for transmission to the PSC, NAWEC and the Banks. The SSS shall directly oversee the implementation of the project’s SEA/SH Prevention and Response Action Plan, including application of the Codes of Conduct addressing SEA/SH and VAC as well as development of GM complaint procedures, and accompanying response protocol, addressing the ethical and confidential management of SEA/SH claims.

d) Technical Specialist (TS) The TS will integrate the construction phase mitigation measures and environmental and social clauses into the bidding documents; ensure that the Contactor obtains all the necessary approvals and integrates the relevant measures in the works breakdown structure or execution plan.

In collaboration with the ESS, SSS and other relevant members of the PIU (including the Procurement Specialist and Financial Management Specialist) the TS will ensure that contract documents contain environmental and social safeguard clauses spelling out the expectations of contractors with regards to their mitigation responsibilities; contractors must fully implement these clauses.

e) Monitoring and Evaluation Specialist (M&ES) Monitoring and evaluation are fundamental components of the ESMP, and they will be carried out on a continuous basis. Monitoring of the ESMP implementation is normally the responsibility of the PIU whereas evaluation is undertaken by an external entity. The M&E Specialist will coordinate internal monitoring and evaluation of ESMP implementation based on the monitoring plan. Table 8.1 summarizes the above write-up on the roles and responsibilities for the implementation of this ESMP.

Table 8.1: Summary of Roles and Responsibilities in ESMP Implementation No Steps/Activities Responsible Collaborating Service Provider Institutions Preparation of the works Contract documents, ESIA/RAP etc. in accordance with the national legislation/procedure (taking into account the Banks’ policy requirements) 1 Preparation and approval of ESS/SSS-GERMP; PC; NEA PIU the ToRs/Contracts TS

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Preparation of the ESIA ESS; SSS; NEA Consultant report ESS/SSS-GERMP; PC; TS Report validation and ESS/SSS; NEA Consultant; issuance of the permit World Bank (when required) ESS/SSS-GERMP Disclosure of the document NEA; NAWEC NAWEC and the Management PIU, also disclosed on the Bank’s external websites (i) Integrating the TS ESS/SSS; Contractor; NEA 2. construction phase NAWEC; PSC; mitigation measures and Engineer; E&S clauses in the bidding Contractor document prior to being advertised (Annex 6) (ii) ensuring that the contractor integrates relevant ESMP measures in the works breakdown structure or execution plan Implementation of the other ESS/SSS TS; M&ES; NEA Consultants; 3. safeguards’ measures, and EIA Working Other relevant including environmental Group; PSC; public institutions monitoring (when relevant) General public and sensitization activities Oversight of safeguards ESS/SSS/PC M&ES; PSC; NAWEC MD and implementation (internal) Management 4. Reporting on project PC M&ES; ESS, SSS; NAWEC MD and safeguards performance and PSC Management disclosure External oversight of the EIA Working PC; M&ES; ESS- NAWEC MD and project safeguards Group/NEA GERMP; SSS; Management compliance and PSC performance 5. Building stakeholders’ ESS PC; SSS; NEA Consultant capacity in safeguards Other qualified management public institutions

8.3 Institutional Training and Sensitization

It became evident during the study that the TACs of both regions need to be trained in the general area of enviromental and social management and ESIA and ESMP management. Thus, it will be necessary to strengthen the capacity of members of the TACs, some NAWEC staff (including the ESS, SSS, etc.) on the safeguards, procedures and resettlement programs, including questions and actions related to management of SEA/SH risk. This will require organizing training workshops. In addition, public sensitization on the project will be carried out to prevent complaints and conflicts, and to highlight community roles in promoting issues related to public health and safety. Capacity

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building of NAWEC and other collaborating institutions is estimated at USD15,000 (see Table 8.2) to be started before the works begin. Table 8.2: Capacity Enhancement Program for Effective ESMP Implementation

No Identified Activity Expected Output Beneficiary Budget (USD) Institutional Capacity – Technical Skills Development and Awareness Creation 1 Workshops and meetings • Project components and related NEA and TACs 15,000 to strengthen the human activities known of CRR/URR resource capacity of the TACs in managing EIA • Capacity enhanced in EIA Procedures

• ESMP requirements understood

• Roles and responsibilities of TAC members with regards to the ESMP understood

• Plan for enforcement of the ESMP developed 15,000

8.4 Monitoring

It is important to monitor if the recommended mitigation measures are being carried out effectively to ensure that the project is implemented in an environmentally and socially sound manner. In addition, monitoring may further identify new problems that were not anticipated at the time of this assessment, or due to changes in the design of project activities, or at the site that may require alternative means of mitigation. Efficiency and effectiveness of those responsible for the ESMP implementation and the proposed structures should also be reviewed, and the necessary changes made accordingly.

The main issues to be monitored include activities that have been earlier identified to have potential significant negative impacts on environment and socio-economic parameters, and their corresponding mitigation actions.

Whilst the ESS and SSS in the PIU will be responsible for monitoring internally, NEA and other institutions earlier identified will carry out routine monitoring to ensure compliance with government obligations under national law, but it is the responsibility of the PIU to ensure alignment of the Banks’ social and environmental policies.

For cost-effectiveness and ease of monitoring and evaluation, the ESMP implementation and monitoring should be mainstreamed in the main project management system at all levels.

To monitor the implementation of the ESMP, only a few selected and relevant TAC members (not more than 4, including the representatives of NEA and NAWEC) will conduct the monitoring visits to

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the Project sites. This requires relatively less resources and logistics than if the entire TAC, or the national EIA Working Group members from Headquarters monitor. Moreover, most of them will be redundant anyway because their sectoral expertise will not specifically useful to add value to the process, and the exercise will be unduly expensive and inefficient. With the NEA’s TAC representative providing the leadership and supported by the NAWEC staff to be included into the TAC, the Regional TACs have to take up this responsibility because they are closer to the project sites and are expected to be more familiar with the local terrain. Therefore, with only a selected relevant few, with specific expertise (including social expertise), the exercise would be more focused, and more cost effective. To develop the monitoring reports, the NEA’s TAC representative at Basse/Janjangbureh will coordinate with NEA Headquarters for onward transmission of the quarterly and eventually, annual reports to the PIU. The budget proposed for the monitoring exercises should be provided by the PIU to the offices of the Governors, (as and when due) who will coordinate the monitoring visits to the Project sites. Cost of monitoring is estimated at USD5,000 for the entire period of project implementation.

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Table 8.3: ESMP Monitoring Program Mitigation outputs Responsibility Monitoring Time to Monitoring indicator Monitoring frequency to be monitored for mitigation Responsibility monitor CONSTRUCTION WORKS (EXCAVATION FOR POLE CONSTRCUTION AND STRINGING OF LINES)

1 Involuntary Contractor ESS/SSS/NEA During and after • RAP report developed During RAP development resettlement of PAPs works • No. of PAPs to be resettled • Types of PAPs • Types of impacts 2 Loss of crops Contractor ESS/SSS/NEA During and after • Total area of crops During RAP development works • No. of PAPs • Type of crops 3 Loss of livelihood Contractor ESS/SSS/NEA During and after • No. of livelihood types During RAP development works affected • No. of PAPs 4 Loss of economic trees Contractor ESS/SSS/NEA During and after • No. of trees felled During RAP development works • No. of trees pruned • No. of PAPs 5 SEA/SH, VAC, and Contractor ESS/SSS/NEA During and after • No. of community During RAP development discrimination works consultations with women in safe and enabling environments with female facilitators • No. of women participating in community consultations • No. of women and minor children PAPs • No. of community sensitization meetings where SEA/SH issues,

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gender discrimination and VAC issues are discussed • No. of community sensitization meetings on GM • Reports on progress in enforcement of codes of conduct to address SEA/SH/VAC, etc., including % of workers and personnel who have signed codes of conduct • No. of worker trainings on SEA/SH, codes of conduct, and GM • No. of workers trained on SEA/SH, codes of conduct, and GM • No. of reports of child labor/abuse • Number and type of complaints through the GM, including on SEA/SH/VAC (without a target number for SEA/SH and VAC) • % of SEA/SH and VAC complaints referred for services • % of SEA/SH and VAC complaints resolved within the prescribed time delay under the GM

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• % of SEA/SH and VAC complaints resolved outside of the prescribed time delay under the GM • Average time delay for resolving SEA/SH and VAC complaints under the GM • Number and type of complaints relating to discrimination, exclusions from benefits and inequality (for example based on vulnerability such as sex, age, etc.) • Number of women hired in project, including in which functions and departments

6 Destruction of forest Contractor NEA/DOF During and after • No. of forest tress Quarterly trees and effect on the works felled/pruned environment, • No. of wildlife species landscape, drainage and impacted wildlife • No. of sensitization meetings on forest and biodiversity • No. of nesting grounds protected • Tree replacement plan No. of reports of illegal activities

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7 Soil compaction from Contractor ESS/SSS/NEA During works • No. existing routes used Quarterly vehicles / machinery and field • No. of Km/meters of road destroying farmland operation graded and improved and causing erosion Noise and vibration Contractor NAWEC/NEA/PIU During works • No. of dust suppression nuisance, and air equipment pollution from dust and • No. of masks and hydrocarbon non- necessary gear to prevent combustion emissions dust related health problems • No. of reports on measures to address dust and gaseous emissions 8 Improper management Contractor ESS/SSS/NEA Before works • Waste management plan Quarterly of wastes; liquid/used and during • Reports on waste oils, machine parts, and works management measures excess materials • Amount of waste re- used/recycled • Evidence that waste management measures incorporated in Contractor’s Contract 9 Impacts of quarrying on Contractor NEA/GD/NAWEC Before and • Mining approval from GD Quarterly geology, landscape, during works • Mine management Plan ground water, wildlife • Reports on process of and agriculture, etc. mining 10 Social cohesion and NAWEC/community NEA/PIU/PSC Before and • No. of locals employed Quarterly labor influx during works (disaggregated by gender and age) • No. of community conflicts

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8.5 Reporting

Reporting of the ESMP implementation and monitoring should be harmonized with the main project monitoring and evaluation reporting system, to ensure holistic and effective communication among the stakeholders.

Annually reporting of ESMP implementation and monitoring is recommended from the NEA to the PIU. NEA will work with the TACs of CRR and URR and report to other stakeholders, accordingly, evaluate the reports and coordinate immediate improvement, where necessary. An annual monitoring report is to be submitted to the PIU for consideration by the Banks.

8.6 Environmental Auditing

Part VI of the EIA Regulations, 2014, makes provisions for self-audit and audit by the NEA to ensure this ESMP is implemented as planned; the audit is supposed to identify potential impacts that have arisen due to any change in activity. The self-audit will be a continuous internal review of ESMP implementation activities, the results of which are used to do any necessary corrections. It will include a systemic review of the activities, the ESMP implementation, monitoring reports, any subsequent improvement measures, and communication between the affected stakeholders.

Whilst the internal audit is a routine activity of the PIU, an external environmental audit will be carried out after six months of ESMP implementation, preferably by an external auditor. The PIU will ensure the external audit is carried out.

8.7 Budget for Implementation of ESMP

The proposed budget for implementation of the ESMP is USD 65,000 as indicated in Table 8.4.

Table 8.4: Estimated Budget to Implement the ESMP No. Activity Time Frame Budget Responsibility (USD) 1 Capacity Building Workshops and Once every 4 months 15,000 NEA/PIU/ESS/SSS meetings to strengthen during project the capacity of TACs in implementation managing ESIA and RAP Public sensitization to Month 3 of project 2,000 NEA/PIU/ESS/SSS raise awareness on the implementation Project issues (such as project risks and benefits, developments, progress, SEA/SH risks and GM etc.) through relevant radio programs and meetings

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SEA/SH Prevention and 60 days x 300 18,000 PIU/ESS/SSS Response Action Plan 2 ESMP Implementation, Monitoring, Evaluation and Reporting Regular monitoring of Project implementation 5,000 NEA/PIU Project sites and period activities ESMP implementation Before and during 10,000 Contractor of mitigation measures construction 3 Operation of GM Site visits and Project implementation 10,000 GRC consultations period ESMP implementation During operations and 5,000 NEA/PIU of mitigation measures maintenance annually 65,000 TOTAL

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CHAPTER 9: GRIEVANCE MECHANISM

9.1 Grievance and Conflict Resolution

The project will be implemented along the road corridor, and will potentially negatively affect private structures and other assets including farm lands, private economic trees, community infrastructure such as waiting sheds located by the road side. In this regard, there will likely be grievances of some sort emanating from members of the communities through which the line will pass. The GERMP is already implementing a Grievance Mechanism (GM) approved by the World Bank. The project therefore needs to ensure that any kind of complaints, suggestions, feedback from stakeholders and project affected communities are acknowledged, documented and addressed within a standard business time. Thus, a process that involves a grievance mechanism (GM) has been instituted to ensure that community members or project beneficiaries are able to raise their concerns regarding project-related activities; this will help project management enhance operational efficiency in a variety of ways. For example, the process will create public awareness about the project and its objectives; deter corruption and fraud; provide project staff with practical suggestions/feedback that will allow them to be more accountable, transparent and responsive to beneficiaries; assess the effectiveness of internal organizational processes; and increase stakeholder involvement in the project. Specifically, the process will ensure that any person affetced by the project is given full, fair and timely compensation, rehabilitation and non-regression of rights in compliance with WB OP 4.12 and EIB ESS6. As part of the GM, the project will likewise develop specific and separate survivor-centered procedures to ensure the ethical and confidential management and resolution of SEA/SH and VAC complaints.

9.2 The Grievance Resolution Committee (GRC)

In view of the above, a Grievance Resolution Committee (GRC) has been set up within the PIU to inform and coordinate the relevant stakeholders and to provide resources for resolution activities. The Committee is chaired by the GERMP PC and will maintain all records from complaint to final decision for future reference. It will also ensure that public participation and consultation is always a part of the process to promote understanding and prevent unnecessary complaints and disputes.

The Committee will include permanent members, whilst others will be engaged as, and when necessary. The Committee consists of the following:

• The GERMP Project Coordinator (Chair) • The GERMP Social Safeguards Specialist (Secretary) • The GERMP Environmental Specialist • Representative of the MOLRG • Chiefs of the two Districts • Two community members (one of who should be a woman) to represent the PAPs

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Other members representing persons affected by the project (PAPs); a credible local NGO; and relevant local authority representatives will be named in due course for this project.

As noted above, the project will develop separate complaint procedures for the ethical and confidential management of SEA/SH and VAC claims, which will include a separate and specially trained verification structure.

9.3 Modalities for Conflict Prevention and Resolution to Resolve Grievances

When they occur, grievances will be referred to the GRC for resolution using traditional and administrative mechanisms, or the law courts at national, regional and community levels. It is important that this grievance mechanism is designed to be legitimate and trusted by all relevant partners including the PAPs in particular. The operating principles of the Committee are transparency, accountability, fairness, impartiality, independence and accessible.

Where a complaint is not admissible or relevant, (for example, not related to the project) the GRC will refer the aggrieved party(ies) to the relevant authority or other grievance process to address that complaint. This GRC grievance mechanism process will not impede access to independent judicial or administrative remedies outside the specific context of this project; on the contrary, it should complement and facilitate access to the courts.

The PIU is to be notified of any disputes, and the GRC will have to address grievances and conflicts immediately at the community level. The PIU should work closely with the communities and the community leaders to clarify and resolve any misunderstanding that could give rise to conflicts.

Where the dispute cannot be resolved at the community level, the affected persons or party will be advised to lodge a complaint to the GRC, and the PIU staff should advise the party on how and where to file the complaint. A standard grievance report form is already developed by the social safeguard specialist at the PIU, and it includes name, address and contact details of complainant, date, and nature of complaint, among other details.

Where traditional and administrative procedures fail to resolve disputes, the aggrieved party has the right to take the matter to the courts in accordance with the Constitution of The Gambia, other national laws, and the Banks’ policies.

As noted above, SEA/SH and VAC-related complaints will be managed and resolved under separate complaint procedures to ensure the safety and confidentiality of all involved parties.

9.4 The Grievance Process

The structure or steps of the grievance mechanism includes:

• Have multiple and accessible uptake stations to receive complaints (text number, website/address, post boxes, others) • Receive, register, and acknowledge complaint in logbook (SEA/SH complaints will be logged separately)

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• Screen and establish the foundation of the grievance • Implement and monitor decision/conclusion to address grievance • Notify the complainant of the result and obtain a response if the resolution is satisfactory. If not, inform the complainant of escalation process and document. • Advise for a judicial proceeding as last resort if necessary • Document the experience for future reference

A step-by-step process, with duration of each stage from the reception of the complaint to the notification of the resolution, with suggested timeframe and responsibilities is indicated in Annexes 4 and 5. Procedures for the ethical management and resolution of SEA/SH complaints will be developed separately within the GM process.

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CHAPTER 10: CONCLUSIONS The study has determined that implementation of the project will have various adverse impacts, including economic and social impacts resulting from pole construction and line stringing activities, and environmental impacts such as potential deforestation, soil erosion as a result of removal of natural land cover, excavation, extraction of construction materials.

However, most of the adverse environmental impacts are short-term, localized, and small scale, and can be mitigated through this ESMP. In the long-term, the construction of the transmission line and its attendant benefits to the communities along the corridor will outweigh the adverse impacts if the ESMP is properly implemented. In addition, despite the potential negative short- term impacts, overall, the people indicated that the Project will be for the good of the entire country’s development.

Whilst the socio-economic impacts, such as loss of small patches of agricultural plots, pruning of fruit trees may be short-term, felling of economic trees may be long-term, and thus it is expected that an acceptable RAP, in consultation with the affected persons, would meaningfully address these concerns.

Overall, the severity of the resettlement impact, especially on crops, will depend on the timing of the works (i.e. whether during the farming season or outside the farming season). Should the works be carried out during the rains, and the crops around pole sites are destroyed, the resettlement will be relatively more severe than when the works are carried out outside the rainy season.

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BIBLIOGRAPHY

Anti-littering Regulations (2007) DWR (2017) Climate data of The Gambia ECOWAS Energy Protocol (2003) A/P4/1/03 EIB (2013) European Investment Bank Environmental and Social Handbook GoTG (2003) Gambia Roads Technical Services Authority Act GoTG (1990) Public Health Act GoTG (1991) Land Acquisition and Compensation Act GoTG (1991) Physical Planning and Development Control Act GoTG (1945) Lands (Regions) Act GoTG (1994) National Environment Management Act GoTG (1995) Development Control Regulations GoTG (1999) Environmental Discharge (Permitting) Regulations GoTG (1999) Environmental Quality Standards Regulations GoTG (1994) Hazardous Chemicals and Pesticides Control and Management Act GoTG (2002) Local Government Act GoTG (1945) Lands (Regions) Act GoTG (2006) Forestry Policy (2006-2016) GOTG (2007) Labor Act GOTG (2009) The National Youth Policy (2009-2018) GoTG (2010) The Women’s Act GoTG (2014) EIA Regulations GOTG (2001) Gambia Public Utilities Regulatory Act GoTG (2017) National Development Plan 2018-2021 GoTG (1990) Land Acquisition and Compensation Act GoTG (2005) Mines and Quarries Act GOTG (2005) The Children’s Act GoTG (1994) Hazardous chemicals and pesticide control and management Act http://hdr.undp.org/en/content/gender-inequality-index https://www.lavanguardia.com/natural/actualidad/20191021/471036333031/aguila- pesacadora-migres-red-electrica-plataforma-nido.html https://www.lavanguardia.com/natural/actualidad/20191021/471036333031/aguila- pesacadora-migres-red-electrica-plataforma-nido.html National Women’s Bureau (2009) The Gambia National Gender and Women Empowerment Policy 2010-2020 NAWEC (2015) Gambia Electricity Support Project - ESMP NEA (1999) Environmental Impact Assessment (EIA) Guidelines NEA (2009) Gambia Environmental Action Plan, Phase II (2009-2018) UN The Stockholm Convention on Persistent Organic Pollutants (POPs) UN (2001) Convention to Combat Desertification (CCD) (1994) UN Convention on the Rights of the Child, (UNICEF) (1989)

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UN Convention on the Rights of Persons with Disabilities (CRPD) (2006) UN Framework Convention on Climate Change (UNFCCC) (1994) UN Convention on Biological Diversity (CBD) (1992) UN Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW) (1979) WB (1999) Operational Manual Operational Policies OP 4.01 Environmental Assessment WB IFC (2007) EHS General Guidelines

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ANNEXES

Annex 1: List of Persons and Institutions Consulted

No Name Designation Institution/Community National Institutions and NGOs

Ebrima Bah Project Transmission Manager NAWEC Ousman Njie Project Transmission Manager NAWEC Malick Bah Senior Program Officer, EIA NEA Alieu Jawo Assistant Director Geology Department George Jatta Engineer NRA Vincent Atanga Resident Engineer for Laminkoto- NRA Passamas road Technical Advisory Committees – CRR and URR Samba Bah Deputy Governor URR Hudul E. N. Kolley NDMA Coordinator URR TAC Yaya Ceesay Physical Planning URR TAC Ebrima Fofana Regional Livestock Officer URR TAC Dandang Sanneh NEA Inspector URR TAC Lamin Sima Youth Coordinator URR TAC Edrisa Keita TOSTAN URR TAC Bubacarr Sankareh Seyfo’s Badge Messenger Fulladu East Muhammed Krubally Seyfo Fulladu East Mustapha S. Kolley Women’s Bureau URR TAC Momodou Billo Jallow Regional Population Officer URR TAC Foday Danjo Chairman Basse Area Council Kebba Jobarteh DPPH CRR TAC Yaya Jobe DWR CRR TAC Aunty Rohey Ceesay DOF (CRR North) CRR TAC Alieu Mbowe DCD CRR TAC Stakeholder Community Members Samsudeen Mbye Poultry Farmer Laminkoto Alhaji Cham Welder Changai Wollof Amadou Cham Welder Changai Wollof Opah Bah Farmer Demba Kalleh Ebrima Jallow Farmer Demba Kalleh Boye Wali Farmer Demba Kalleh Momodou Fofana Farmer Demba Kalleh Ms. Musu Sonko Ice block Vendor Karantaba Wollof Lamin Jobarteh Forest Ranger Karantaba Dutokoto Ablie ??? Forest Ranger Karantaba Dutokoto

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Alhaji Kan Sainey Ceesay Farmer Karantaba Dutokoto Ousman Sisawo Farmer Karantaba Tabokoto Sainey Ceesay Farmer Karantaba Dutokoto Amadou Camara Farmer Karantaba Dutokoto Sainey Sallah Farmer (Alkalo) Karantaba Wollof Amadou Jallow Farmer Jalubeh Maburaima Ceesay Farmer Karantaba Dutokoto Bunja Touray Farmer (Alkalo) Karantaba Tabokoto Alhaji Ousubi Danso Farmer Kuraw Kemo Ms. Hawa Jatta Farmer Kuraw Kemo Ms. Mariama Touray Farmer Kuraw Kemo Demba Danso Farmer Kuraw Kemo Ms. Fanta Ceesay Farmer Kuraw Kemo Ms. Sira Giana Farmer Kuraw Kemo Ms. Aja Tida Janko Farmer Kuraw Kemo Ms. Hawa Bayo Farmer Kuraw Kemo

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Annex 2: Summary of comments and views expressed during the consultations with stakeholders along the proposed line corridor Dates: 24-28th May At each of the locations visited, the Consultant gave an introduction on what the project 2019 is about; that it is a World Bank, EIB, EU, and Gambia Government-funded Project involving the construction of electricity transmission and distribution lines from Laminkoto to Diabugu along the existing Laminkoto-Passamas road alignment.

Reminded the meetings of the benefits of the Project to the entire country, and specifically to the stakeholders along the line corridor such as the economic and social benefits, including the supply of electricity to their homes, to economic centers and to other social services which, currently is nonexistent within the two Districts of Sami and Sandu.

At the same time, the potential negative environmental, social and economic impacts of the Project were highlighted. These would include loss of forest and vegetation cover; impacts of pole construction and line stringing on nearby farmlands, streams and water bodies; persons losing their properties (parts of their farm lands, economic trees, etc.); and communities losing community structures such as waiting sheds, located along the road Venues In Banjul, KMC, and along the proposed alignment, etc. Laminkoto-Diabugu line corridor including the Offices of the Regional Governors

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Consultant’s Opening Remarks The other reasons for the consultations with them, as explained by the Consultant included the following:

To prepare an ESIA report that would evaluate the potential negative environmental and social risks and impacts that the Project may have, and to propose ways of mitigating them, and at the same to identify the positive impacts and propose ways to further enhance them

To provide information about the Project to the communities, and to receive stakeholder information on key environmental and social baseline information in the project area

To provide opportunities to stakeholders to discuss their opinions and concerns about the Project

To inform the process of developing appropriate management measures as well as institutional arrangements for effective implementation of the Project

Remarks and Comments from Stakeholders and Interviewees Name Designation Location/Origin Comments/views/ Government Institutions NAWEC NAWEC NAWEC

Alieu Jawo Assistant Director Geology Department I have no knowledge of the number of gravels borrows for this Project, although we visited certain sites along the corridor on the invitation of NRA. However, whatever the numbers are right now, the need for an initial assessment of the proposed borrow sites is obvious. This assessment will include consultations with landowners and, possibly some form of compensation to either the landowner, or the community in the form of a community infrastructural project such as borehole, etc. on reaching an agreement for use.

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NEA carries out the assessment and recommends approval, or otherwise, after which Geology issues the mining permits with conditions including restoration plans. It did not happen like this in this project. We have not issued any permits regarding the gravel borrows, and neither for the sand quarries in Kumbaniye in CRR. (Recommendations Needed here) Malick Bah Senior Program NEA ESIA is mandatory for development projects listed under SCHEDULE A of NEMA, 1994. If Officer, EIA the line is close to existing structures, the Project needs to consider rerouting the line behind villages to avoid structures Samba Bah Deputy Governor URR The Project needs to consult with and adequately sensitize stakeholders, including the relevant communities Hudul E. N. Kolley NDMA Coordinator URR TAC This Project is very important because it will bring development to the region Kebba Jobarteh DPPH CRR TAC If compounds are very close to the road, then high-tension poles cannot be 10 meters from the compounds. poles must not be placed too close to compounds Aunty Rohey Ceesay DOF (CRR North) CRR TAC Sensitization and monitoring should be rigorously undertaken. Community Forests exist close to the proposed T&D line; these include those in Fitu and Laminkoto Yaya Jobe DWR CRR TAC The ANR subcommittee of the TAC also exists and can also be used for the monitoring. The Project should avoid putting poles inside people’s compounds Alieu Mbowe DCD CRR TAC Mitigation measures need to be identified and properly monitored Edrisa Keita TOSTAN URR TAC Electricity is always welcomed, but stakeholders impacted by the Project should be properly sensitized Sisawo Sabally Regional Forestry URR TAC Trees felled by the project remain the property of the Department of Forestry and should Officer therefore be disposed by the Department. Communities along the road corridor Samsudeen Mbye Poultry Farmer Laminkoto The proposed transmission line will be very welcome because all villages along the Laminkoto-Passimas road will enjoy electricity. Currently, Laminkoto has electricity, supplied from Janjangbureh, but it’s not 24 hours supply. We hope this will change when this Project is implemented Alhaji Cham Welder Changai Wollof If we have electricity, it will be very good for my business. We need constant electricity for our work but without electricity we use a generator for welding which consumes 5 liters of gasoil every day Opah Bah Farmer Demba Kalleh The Electricity Project is welcome. It will definitely change our lives

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Boye Wali Farmer Demba Kalleh • NAWEC is welcomed here, because right now it is Ramadan, and people need cold drinks; right now, ice blocks are procured from Bansang. With NAWEC ice could be produced in the village • A lot of then young mean could be engaged in economic activities such as welding tailoring, etc. • Cooling of fish brought from Tanji, in the Kombo will help us in our diet • Use of educational material and equipment will be possible with the availability of NAWEC Alhaji Ousubi Danso Farmer Kuraw Kemo We are happy with the Project as it will bring us electricity Ms. Hawa Jatta Farmer Kuraw Kemo Now we are in Ramadan, but we can only get ice to break our fast if only we go to Basse. Electricity is therefore important to us. Ousman Baldeh Farmer Demba Kalleh There has never been electricity in this area. We want electricity now so that the area can develop. Ms. Musu Sonko Ice block vendor Demba Kalleh I am staying with my husband (a Police Officer) in Karantaba Wollof, but I sell ice blocks purchased in Bansang to sell in Karantaba. With NAWEC ice/cold drinks will be available in the villages around here, and there will not be any need to travel to Bansang, more than 30 km to buy ice blocks Momodou Fofana Farmer Demba Kalleh NAWEC is welcomed into the community

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Annex 3: Chance Find Procedures

This Chance Find Procedure shall be applied in case previously unknown culturally valuable materials are unexpectedly discovered during the GERMP implementation: • In the case of chance find of any material with possible archaeological, historical, paleontological, religious, or other cultural value, all work at and around the find, feature or site must immediately stop.

• The discovery will be clearly demarcated and secured from unauthorized access, and all found remains will be left where they were found. If necessary, artefacts will be protected and measures to stabilize the area will be implemented.

• Notify the Project Manager/PIU of the findings who in turn will immediately notify the National Council for Arts and Culture for the necessary, assessment, recording and determine the next course of action.

• Restart construction and public works only upon authorization of the relevant authorities (the National Council for Arts and Culture under the Ministry of Tourism and Culture).

• Relevant findings will be recorded in the Banks’ supervision reports.

• These procedures must be referred to as standard provisions in construction contracts.

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Annex 4: Modalities of the Proposed Grievance Mechanism

Step Process Description / Time-frame Responsible Agency / Person Required Action 1 Receipt of complaint Document date of 1 day GRC/PIU (specifically social receipt, name of safeguards specialist) complainant, nature of complaint 2 Acknowledge receipt By letter, email, phone 1-5 days Social safeguards specialist at the of grievance and PIU Communicate Response 3 Screen and establish Visit the site; listen to 7-14 days GRC members including the the foundation or the complainant / project safeguard specialist, merit of the community; assess the complainant and his/her grievance merit representative 4 If the complaint has If yes, inform 21-30 days or Project Coordinator, SSS/ESS to merit, the GRC to complainant of possible at a time coordinate the implementation of proceed with resolution. If no, inform specified in resolution action resolution. complainant, record writing to the his/her response and complainant inform him/her of escalation measures if he/she would like to proceed further (see 5) 4A Is resolution If yes, GRC move to 2-5 days Project Coordinator/SSS/ESS acceptable to the implement and monitor complainant? measure.

Notify complainant when implementation is complete and ask complainant if he/she is satisfied and record response. If not, move to 5. 5 Extra intervention for If response is 2-4 weeks of Project Coordinator GERMP and a dissatisfied uncceptable to receiving GRC to review and react scenario including complanant, review the status report resolution not resolution steps and acceptable to conclusions, provide comlainant/not intervention solution implemented properly/fully 6 Judicial adjudication Take complaint to court No fixed time Complainant of law

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7 Funding of grievance GRC logistics (costs of No fixed time GERMP process litigation,training), compensation, court process

For cases regarding SEA/SH and VAC, specific procedures will be put into place under the project and contractor GM to manage SEA/SH and VAC complaints ethically and confidentially, including the establishment of a separate review structure to handle these complaints, and will include a response protocol to ensure timely referral for survivors to appropriate support services.

Annex 5: Flow Chart of Grievance Process

Maximum Timeframe for implementation of Grievance Action is 85 days from receipt of complaint

(1) PIU Receives (1) PIU Receives PAP Complaint Complaint PAP (1Day) (1Day)

(3) Screen and Establish Merit (7-14 Days) (3) Screen and Establish Merit (7-14 Days) (2) PIU Acknowledges Complaint/Communicat es Response (1-5 Day) NO (4) Is Complaint Acceptable TO GRC? (21 – 30 Days)

(1-5 Day)

YES

(4A) If Complaint is acceptable, then inform complainant; Is resolution acceptable to the complainant? If NO inform Complainant of possible resolution beyond GRC (2 – 5 Days) 158

(5) Extra Intervention for a Dissatisfactory Scenario (2 – 4 Weeks)

(6) Judicial Adjudication (No Fixed Time)

(7) Funding of grievance Process (No Fixed Time)

Annex 6: Contract Clauses to be Included in Contractor’s Agreements

The rules, including specific prohibitions and construction management measures, should be incorporated into all relevant bidding documents, contracts, and work orders.

Prohibitions: The following activities should be prohibited on or near the project site: ▪ Cutting of trees for any reason outside the approved construction area ▪ Hunting, fishing, wildlife capture, or plant collection ▪ Use of unapproved toxic materials ▪ Disturbance to anything with architectural or historical value ▪ Setting of fires ▪ Use of firearms (except authorized security guards) ▪ Use of alcohol or drugs (except prescribed medicines) by workers ▪ Any acts of SEA/SH or VAC, including employment of children in accordance with international law and the Children’s Act.

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Construction Management Measures: Waste Management: ▪ Minimize the production of waste that must be treated or eliminated. ▪ Identify and classify the type of waste generated. If hazardous wastes are generated, proper procedures must be taken regarding their storage, collection, transportation and disposal. ▪ Identify and demarcate disposal areas clearly indicating the specific materials that can be deposited in each. ▪ Control placement of all construction waste (including earth cuts) to approved disposal sites. Dispose in authorized areas all of garbage, metals, used oils, and excess material generated during construction, incorporating recycling systems and the separation of materials. ▪ Establish and enforce daily site clean-up procedures, including maintenance of adequate disposal facilities for construction debris.

Maintenance: ▪ Ensure that all equipment maintenance activities, including oil changes, are conducted within demarcated maintenance areas; never dispose spent oils on the ground, in water courses, drainage canals or in sewer systems. ▪ Identify, demarcate and enforce the use of within-site access routes to limit impact to site vegetation. Labour health and safety: ▪ Place signs and lighting at strategic locations informing community before works starts. ▪ Conduct safety training for construction workers prior to beginning work. ▪ Provide personal protective equipment and clothing (goggles, gloves, respirators, dust masks, hard hats, steel-toed boots etc.,) for construction workers and enforce their use. ▪ During heavy rains or emergencies of any kind, suspend all work. ▪ Safely store hazardous items away from the public. ▪ Educate on risks and prevention of STD/STIs, including links with SEA/SH risks ▪ Educate and train workers on SEA/SH risks, including in workplace, prohibited conduct, applicable sanctions, and GM complaint procedures ▪ Ensure that work sites have appropriate sex-segregated, well-lit, secure, and lockable sanitation facilities for personnel

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▪ Erect Speed bumps and speed limits. ▪ Cover up trucks transporting sand and gravel

Community Safety during Construction: The Contractor’s responsibilities include the protection of every person (workers and the public) and nearby property from construction accidents. The Contractor shall be responsible for complying with all national and local safety requirements and any other measures necessary to avoid accidents, including the following: ▪ Carefully and clearly mark pedestrian-safe access routes. ▪ If school children are in the vicinity, include traffic safety personnel to direct traffic. ▪ Keep the public away from construction sites ▪ Ensure worker and community sensitization on SEA/SH risks, prohibited conduct, applicable sanctions for workers, GM complaint procedures, and available survivor support services

Nuisance and dust control should include: ▪ Maintain all construction-related traffic at minimum ▪ Maintain equipment and machinery to reduce noise ▪ In sensitive areas (including residential neighbourhoods, health centres, schools) more strict measures may need to be implemented to prevent undesirable noise levels, including controlled working times ▪ Minimize production of dust and particulate materials at all times, to avoid impacts on surrounding families and businesses ▪ Spray water as needed on dirt roads, cut areas and soil stockpiles or fill material. ▪ Apply proper measures to minimize disruptions from vibration or noise coming from construction activities.

Community Relations: To maintain amicable community relations, the Contractor should: ▪ Inform the population about construction and work schedules, interruption of services, traffic detour routes as appropriate. ▪ Avoid construction activities at night or early in the morning. ▪ Hire to the extent possible workers from the project affected communities.

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▪ Ensure appropriate community sensitization on SEA/SH risks, prohibited conduct, and how to access GM complaint procedures as well as available survivor support services

Chance Find Procedures for Culturally Significant Artefacts: In case culturally valuable materials are uncovered during excavation: ▪ Stop work immediately following the discovery of any materials with possible archaeological, historical, paleontological, or other cultural value, announce findings to project manager and notify the PIU who in turn notifies the National Council for Arts and Culture ▪ Protect artefacts as well as possible, using plastic covers, and implement measures to stabilize the area, if necessary ▪ Prevent unauthorized access to the artefacts ▪ Restart construction works only upon the authorization of the relevant authorities.

Environmental and Social Supervision during Construction The bidding documents should indicate how compliance with environmental rules and design specifications would be supervised, along with the penalties for noncompliance by contractors or workers. Construction supervision requires oversight of compliance with the ESMP by the contractor or his designated environmental supervisor. If necessary competencies to are needed to adquately monitor the social aspects of this ESMP, the contractor should hire such capacity. The “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), including Sexual Exploitation and Abuse (SEA), Sexual Harassment (SH), and Violence Against Children (VAC)” will also be included in contracts including explicit references for monitoring, enforcement and compliance (as per Annex 7, and its annexes included in this ESIA/ESMP report).

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Annex 7: Codes of Conduct for Implementing ESHS and OHS Standards, and Preventing Sexual Exploitation and Abuse, Sexual Harassment, and Violence Against Children

Background

The purpose of these Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Sexual Exploitation and Abuse (SEA), Sexual Harassment (SH), and Violence Against Children (VAC) is to introduce a set of key definitions, core Codes of Conduct, and guidelines that:

i. clearly define obligations on all project staff (including sub-contractors and day workers) with regard to implementing the project’s environmental, social, health and safety (ESHS) and occupational health and safety (OHS) requirements, and; ii. help prevent, report and address SEA/SH and VAC within the work site and in its immediate surrounding communities.

The application of these Codes of Conduct will help ensure the project meets its ESHS and OHS objectives, as well as preventing and/or mitigating the risks of SEA/SH and VAC on the project and in the local communities.

These Codes of Conduct are to be adopted by those working on the project and are meant to:

i. create awareness of the ESHS and OHS expectations on the project; ii. create common awareness about SEA/SH and VAC and: (a) ensure a shared understanding that they have no place in the project; and, (b) create a clear system for identifying, responding to, and sanctioning SEA/SH and VAC incidents.

Ensuring that all project staff understand the values of the project, understand expectations for all employees, and acknowledge the consequences for violations of these values, will help to create smoother, more respectful and productive project implementation thereby helping ensure that the project’s objectives will be achieved.

Definitions

The following definitions apply:

Environmental, Social, Health and Safety (ESHS): an umbrella term covering issues related to the impact of the project on the environment, communities and workers.

Occupational Health and Safety (OHS): Occupational health and safety is concerned with protecting the safety, health and welfare of people engaged in work or employment. The enjoyment of these standards at the highest levels is a basic human right that should be accessible by each worker.

Gender-Based Violence (GBV): is an umbrella term for any harmful act that is perpetrated against a person’s will and that is based on socially ascribed (i.e. gender) differences between males and

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females. It includes acts that inflict physical, sexual or mental harm or suffering, threats of such acts, coercion, and other deprivations of liberty. These acts can occur in public or in private. The term GBV is used to underscore systemic inequality between males and females (which exists in every society in the world) and acts as a unifying and foundational characteristic of most forms of violence perpetrated against women and girls. The 1993 United Nations Declaration on the Elimination of Violence against Women defines violence against women as “any act of gender- based violence that results in, or is likely to result in, physical, sexual or psychological harm or suffering to women.”12 The six core types of GBV are: • Rape: non-consensual penetration (however slight) of the vagina, anus or mouth with a penis, other body part, or an object. • Sexual Assault: any form of non-consensual sexual contact that does not result in or include penetration. Examples include: attempted rape, as well as unwanted kissing, fondling, or touching of genitalia and buttocks.

o Sexual Exploitation: any actual or attempted abuse of position of vulnerability, differential power or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.

o Sexual Abuse: the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. o Sexual Harassment: any unwelcome sexual advance, request for sexual favor, verbal or physical conduct or gesture of a sexual nature, or any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment. Sexual conduct is unwelcome whenever the person subjected to it considers it unwelcome (e.g. looking somebody up and down; kissing, howling or smacking sounds; hanging around somebody; whistling and catcalls; in some instances, giving personal gifts). o Sexual Favors: form of sexual harassment and includes making promises of favorable treatment (e.g. promotion) or threats of unfavorable treatment (e.g. loss of job) dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior.

• Physical Assault: an act of physical violence that is not sexual in nature. Examples include: hitting, slapping, choking, cutting, shoving, burning, shooting or use of any weapons, acid attacks or any other act that results in pain, discomfort or injury.

• Forced Marriage: the marriage of an individual against her or his will.

• Denial of Resources, Opportunities or Services: denial of rightful access to economic resources/assets or livelihood opportunities, education, health or other social services (e.g. a widow prevented from receiving an inheritance, earnings forcibly taken by an

12 It is important to note that women and girls disproportionately experience violence; overall 35 percent of women worldwide have faced physical or sexual violence (WHO, Global and regional estimates of violence against women: prevalence and health effect s of intimate partner violence and non-partner sexual violence, 2013). Some men and boys also face violence based on their gender and unequal power relationships.

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intimate partner or family member, a woman prevented from using contraceptives, a girl prevented from attending school, etc.).

• Psychological / Emotional Abuse: infliction of mental or emotional pain or injury. Examples include: threats of physical or sexual violence, intimidation, humiliation, forced isolation, stalking, harassment, unwanted attention, remarks, gestures or written words of a sexual and/or menacing nature, destruction of cherished things, etc.

Violence Against Children (VAC): physical, sexual, emotional and/or psychological harm, neglect or negligent treatment of minor children (i.e. under the age of 18), including exposure to such harm,13 that results in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power. This includes using children for profit, labor14, sexual gratification, or some other personal or financial advantage. This also includes other activities such as using computers, mobile phones, video and digital cameras or any other medium to exploit or harass children or to access child pornography.

Grooming: behaviors that make it easier for a perpetrator to procure a child for sexual activity. For example, an offender might build a relationship of trust with the child, and then seek to sexualize that relationship (for example by encouraging romantic feelings or exposing the child to sexual concepts through pornography).

Online Grooming: the act of sending an electronic message with indecent content to a recipient whom the sender believes to be a minor, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender. 15

Accountability Measures: the measures put in place to ensure the confidentiality of survivors and to hold contractors, consultants and the client responsible for instituting a fair, safe, and credible system of addressing cases of SEA/SH and VAC.

Contractors Environmental and Social Management Plan (CESMP): the plan prepared by the contractor outlining how they will implement the works activities in accordance with the project’s environmental and social management plan (ESMP).

Child: a term used interchangeably with the term ‘minor’ and refers to a person under the age of 18. This is in accordance with Article 1 of the United Nations Convention on the Rights of the Child.

Child Protection (CP): an activity or initiative designed to protect children from any form of harm, particularly arising from VAC.

Consent: the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if

13 Exposure to GBV is also considered VAC. 14 The employment of children must comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. They must also be able to meet the project’s Occupational Health and Safety competency standards. 15 For example, the Vanuatu Criminal Code Act 1995, Division 474 (telecommunications offences, subdivision C).

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national legislation of the country into which the Code of Conduct is introduced has a lower age. 16 Mistaken belief regarding the age of the child and consent from the child is not a defense.

Consultant: any firm, company, organization or other institution that has been awarded a contract to provide consulting services to the project, and has hired managers and/or employees to conduct this work.

Contractor: any firm, company, organization or other institution that has been awarded a contract to conduct infrastructure development works for the project and has hired managers and/or employees to conduct this work. This also includes sub-contractors hired to undertake activities on behalf of the contractor.

Employee: any individual offering labor to the contractor or consultant within country on or off the work site, under a formal or informal employment contract or arrangement, typically, but not necessarily (e.g. including unpaid interns and volunteers), in exchange for a salary, with no responsibility to manage or supervise other employees.

SEA/SH and VAC Allegation Procedure: the prescribed procedure to be followed when reporting incidents of SEA/SH or VAC.

SEA/SH and VAC Codes of Conduct: The Codes of Conduct adopted for the project covering the commitment of the company, and the responsibilities of managers and individuals with regards to SEA/SH and VAC.

Grievance Mechanism (GM): the process established by a project to receive and address complaints.

Manager: any individual offering labor to the contractor or consultant, on or off the work site, under a formal or informal employment contract and in exchange for a salary, with responsibility to control or direct the activities of a contractor’s or consultant’s team, unit, division or similar, and to supervise and manage a pre-defined number of employees.

Perpetrator: the person(s) who commit(s) or threaten(s) to commit an act or acts of SEA/SH or VAC.

Response Protocol: is the mechanisms set in place to respond to cases of SEA/Sh and VAC (see Section 4.7 Response Protocol).

Survivor/Survivors: the person(s) adversely affected by SEA/SH or VAC. Women, men and children can be survivors of SEA/SH; children can be survivors of VAC.

Work Site: is the area in which infrastructure development works are being conducted, as part of the project. Consulting assignments are considered to have the areas in which they are active as their work sites.

16 For example, under Article 97 Criminal consolidation act for age of legal consent in Vanuatu, sexual activity with any child under the age of 15 years for heterosexual conduct and 18 years for same sex conduct is prohibited (http://tinyurl.com/vu-consent). However, the World Bank follows the United Nations for the age of consent (18 years) so this applies on World Bank financed projects.

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Work Site Surroundings: is the ‘Project Area of Influence’ which are any area, urban or rural, directly affected by the project, including all human settlements found on it.

Codes of Conduct

This chapter presents three Codes of Conduct for use: i. Company Code of Conduct: Commits the company to addressing SEA/SH and VAC issues; ii. Manager’s Code of Conduct: Commits managers to implementing the Company Code of Conduct, as well as those signed by individuals; and, iii. Individual Code of Conduct: Code of Conduct for everyone working on the project, including managers.

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Company Code of Conduct

Implementing ESHS and OHS Standards

Preventing Sexual Exploitation and Abuse, Sexual Harassment, and Violence Against Children

The company is committed to ensuring that the project is implemented in such a way which minimizes any negative impacts on the local environment, communities, and its workers. This will be done by respecting the environmental, social, health and safety (ESHS) standards, and ensuring appropriate occupational health and safety (OHS) standards are met. The company is also committed to creating and maintaining an environment in which gender-based violence (GBV), including sexual exploitation and abuse (SEA), sexual harassment (SH), and violence against children (VAC), have no place, and where they will not be tolerated by any employee, sub- contractors, supplier, associate, or representative of the company.

Therefore, to ensure that all those engaged in the project are aware of this commitment, the company commits to the following core principles and minimum standards of behavior that will apply to all company employees, associates, and representatives, including sub-contractors and suppliers, without exception:

General

1. The company—and therefore all employees, associates, representatives, sub-contractors and suppliers—commits to complying with all relevant national laws, rules and regulations. 2. The company commits to full implementing its ‘Contractors Environmental and Social Management Plan’ (C-ESMP). 3. The company commits to treating women, children (persons under the age of 18), and men with respect regardless of sex, race, color, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or nationality, sexual orientation, gender identity, or other status. Acts of SEA/SH and VAC are in violation of this commitment. 4. The company shall ensure that interactions with local community members are done with respect and non-discrimination. 5. Demeaning, threatening, harassing, abusive, culturally inappropriate, or provocative language and behavior, including of a sexual nature, are prohibited among all company employees, associates, and its representatives, including sub-contractors and suppliers. 6. The company will follow all reasonable work instructions (including regarding environmental and social norms). 7. The company will protect and ensure proper use of property (for example, to prohibit theft, carelessness or waste).

Health and Safety

8. The company will ensure that the project’s occupational health and safety (OHS) Management Plan is effectively implemented by company staff, as well as sub-contractors and suppliers. 9. The company will ensure that all persons on-site wear prescribed and appropriate personal protective equipment, preventing avoidable accidents and reporting conditions or practices that pose a safety hazard or threaten the environment.

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10. The company will: i. prohibit the use of alcohol during work activities. ii. prohibit the use of narcotics or other substances which can impair faculties at all times.

11. The company will ensure that adequate sanitation facilities, which are sex-segregated, safe, lockable, and well-lit, are available on site and at any worker accommodations provided to those working on the project.

Sexual Exploitation and Abuse (SEA), Sexual Harassment (SH), and Violence Against Children

12. Acts of SEA, SH, or VAC constitute gross misconduct and are therefore grounds for sanctions, which may include penalties and/or termination of employment, and if appropriate, and with survivor consent, referral to the Police for further action.

1. 1. All forms of SEA, SH, and VAC, including grooming, are unacceptable, regardless of whether they take place on the work site, the work site surroundings, at worker’s camps, or within the local community.

2. i. Sexual exploitation is defined as any actual or attempted abuse of position of vulnerability, differential power or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. 3. ii. Sexual abuse is defined as the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. i. Sexual harassment is defined as any unwelcome sexual advance, request for sexual favor, verbal or physical conduct or gesture of a sexual nature, or any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment.

13. Sexual contact or activity with children under 18—including through digital media—is prohibited. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse. All forms of child labor not in compliance with Gambian law are prohibited. Sexual activities and sexual interactions between the company’s employees (at any level) and members of the communities surrounding the workplace are prohibited. This includes relationships involving the withholding/promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex—such sexual activity is considered “non-consensual” within the scope of this Code.

14. In addition to company sanctions, legal prosecution of those who commit acts of SEA, SH, or VAC will be pursued if appropriate and only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent.

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15. All employees, including volunteers and sub-contractors, are highly encouraged to report suspected or actual acts of SEA, SH, and/or VAC by a fellow worker, whether in the same company or not. Reports must be made in accordance with project’s SEA/SH and VAC Allegation Procedures. 16. Managers are required to report and act to address suspected or actual acts of SEA, SH, and/or VAC as they have a responsibility to uphold company commitments and hold their direct reports responsible. Reports of SEA/SH and VAC claims may be made only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent.

Implementation

To ensure that the above principles are implemented effectively the company commits to ensuring that:

17. All managers sign the project’s ‘Manager’s Code of Conduct’ detailing their responsibilities for implementing the company’s commitments and enforcing the responsibilities in the ‘Individual Code of Conduct’. 18. All employees sign the project’s ‘Individual Code of Conduct’ confirming their agreement to comply with ESHS and OHS standards, and not to engage in activities resulting in SEA, SH, or VAC. 19. Displaying the Company and Individual Codes of Conduct prominently and in clear view at workers’ camps, offices, and in in public areas of the workspace. Examples of areas include waiting, rest and lobby areas of sites, canteen areas and health clinics. 20. Ensure that posted and distributed copies of the Company and Individual Codes of Conduct are translated into the appropriate language of use in the work site areas as well as for any international staff in their native language. 21. An appropriate person is nominated as the company’s ‘Focal Point’ for addressing SEA/SH and VAC issues, including supporting implementation of the SEA/SH Prevention and Response Action Plan, including any SEA/SH-specific grievance resolution procedures or response protocols for the appropriate referral of survivors to available services. 22. Ensuring that an effective SEA/SH Prevention and Response Action Plan is developed, which includes at a minimum:

i. Allegation Procedures to report SEA/SH and VAC issues through the project Grievance Mechanism (Section 4.3 Action Plan); ii. Accountability Measures to protect confidentiality of all involved (Section 4.4 Action Plan); and, iii. Response Protocol to ensure appropriate, safe, and timely referral of survivors to locally available services (Section 4.7 Action Plan).

23. That the company effectively implements the agreed final SEA/SH Prevention and Response Action Plan, providing feedback to the relevant SEA/SH focal points or personnel for improvements and updates as appropriate.

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24. All employees attend an induction training course prior to commencing work on site to ensure they are familiar with the company’s commitments to ESHS and OHS standards, and the project’s Codes of Conduct prohibiting all forms of SEA, SH, and VAC. 25. All employees attend a mandatory training course once a month for the duration of the contract starting from the first induction training prior to commencement of work to reinforce the understanding of the project’s ESHS and OHS standards and the project’s Codes of Conduct prohibiting all forms of SEA, SH, and VAC. 26.

I do hereby acknowledge that I have read the foregoing Company Code of Conduct, and on behalf of the company agree to comply with the standards contained therein. I understand my role and responsibilities to support the project’s OHS and ESHS standards, and to prevent and respond to SEA, SH, and VAC. I understand that any action inconsistent with this Company Code of Conduct or failure to act mandated by this Company Code of Conduct may result in disciplinary action.

Company name: ______

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Manager’s Code of Conduct

Implementing ESHS and OHS Standards

Preventing Sexual Exploitation and Abuse, Sexual Harassment, and Violence Against Children

Managers at all levels have a responsibility to uphold the company’s commitment to implementing the ESHS and OHS standards, and preventing and addressing SEA/SH and VAC. This means that managers have an acute responsibility to create and maintain an environment that respects these standards and prevents SEA/SH and VAC. Managers need to support and promote the implementation of the Company Code of Conduct. To that end, managers must adhere to this Manager’s Code of Conduct and sign the Individual Code of Conduct. This commits them to supporting the implementation of the CESMP and the OHS Management Plan and developing systems that facilitate the implementation of the SEA/SH Prevention and Response Action Plan. They need to maintain a safe workplace, as well as an environment at the workplace and in the local community that is free from all forms of abuse and violence, including SEA/SH and VAC. These responsibilities include, but are not limited to:

Implementation

1. To ensure maximum effectiveness of the Company and Individual Codes of Conduct: i. Prominently displaying the Company and Individual Codes of Conduct in clear view at workers’ camps, offices, and in public areas of the workspace. Examples of areas include waiting, rest and lobby areas of sites, canteen areas and health clinics. ii. Ensuring all posted and distributed copies of the Company and Individual Codes of Conduct are translated into the appropriate language of use in the work site areas as well as for any international staff in their native language. 2. Verbally and in writing explain the Company and Individual Codes of Conduct to all staff. 3. Ensure that: i. All direct reports sign the ‘Individual Code of Conduct’, including acknowledgment that they have read and agree with the Code of Conduct. ii. Staff lists and signed copies of the Individual Code of Conduct are provided to the OHS Manager and the client. iii. Participate in required trainings and ensure that staff also participate as outlined below. iv. Put in place a mechanism for staff to: (a) report concerns on ESHS or OHS compliance; and, (b) confidentially report SEA/SH or VAC incidents through the specific procedures set out under the Grievance Mechanism (GM) to manage SEA/SH and VAC complaints ethically and confidentially. v. Staff are encouraged to report suspected or actual ESHS, OHS, SEA/SH or VAC issues, emphasizing the staff’s responsibility to the Company and the country hosting their employment, and emphasizing the respect for confidentiality. 4. In compliance with applicable laws and to the best of your abilities, prevent perpetrators of SEA and SH from being hired, re-hired or deployed. Use background and criminal reference checks for all employees. 5. Ensure that when engaging in partnership, sub-contractor, supplier or similar agreements, these agreements: i. Incorporate the ESHS, OHS, SEA/SH and VAC Codes of Conduct as an attachment.

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ii. Include the appropriate language requiring such contracting entities and individuals, and their employees and volunteers, to comply with the Individual Codes of Conduct. iii. Expressly state that the failure of those entities or individuals, as appropriate, to ensure compliance with the ESHS and OHS standards, take preventive measures against SEA/SH and VAC, to investigate allegations thereof, or to take corrective actions when SEA/SH or VAC incidents have occurred, shall not only constitute grounds for sanctions and penalties in accordance with the Individual Codes of Conduct but also termination of agreements to work on or supply the project. 6. Provide support and resources to the relevant personnel or focal points implementing the SEA/SH Prevention and Response Action Plan to create and disseminate internal sensitization initiatives through the awareness-raising strategy under the plan. 7. Ensure that any SEA/SH or VAC issue warranting Police action is reported to the Police, the client and the World Bank immediately, but only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent. 8. Report and act according to the response protocol (Section 4.7 Response Protocol) any suspected or actual acts of SEA/SH and/or VAC as managers have a responsibility to uphold company commitments and hold their direct reports responsible. Reports of SEA/SH and VAC claims may be made only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent. 9. Ensure that any major ESHS or OHS incidents are reported to the client and the supervision engineer immediately.

Training

10. The managers are responsible to: i. Ensure that the OHS Management Plan is implemented, with suitable training required for all staff, including sub-contractors and suppliers; and, ii. Ensure that staff have a suitable understanding of the CESMP and are trained as appropriate to implement the CESMP requirements. 11. All managers are required to attend an induction manager training course prior to commencing work on site to ensure that they are familiar with their roles and responsibilities in upholding elements of these Codes of Conduct related to mitigation of SEA/SH and VAC risk. This training will be separate from the induction training course required of all employees and will provide managers with the necessary understanding and technical support needed to begin to develop the SEA/SH Prevention and Response Action Plan for addressing SEA/SH and VAC risk mitigation. 12. Managers are required to attend and assist with the project facilitated monthly training courses for all employees. Managers will be required to introduce the trainings and announce the self-evaluations, including collecting satisfaction surveys to evaluate training experiences and provide advice on improving the effectiveness of training. 13. Ensure that time is provided during work hours and that staff prior to commencing work on site attend the mandatory project facilitated induction training on: i. OHS and ESHS; and, ii. SEA/SH and VAC required of all employees. 14. During civil works, ensure that staff attend ongoing OHS and ESHS training, as well as the monthly mandatory refresher training course required of all employees to combat increased risk of SEA/SH and VAC.

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Response

15. Managers will be required to take appropriate actions to address any ESHS or OHS incidents. 16. With regard to SEA/SH and VAC: i. Provide input to the SEA/SH and VAC Allegation Procedures (Section 4.2 Action Plan) and Response Protocol (Section 4.7 Action Plan) as part of the procedures for the ethical and confidential management of SEA/SH claims under the project GM and incorporated under the SEA/SH Prevention and Response Action Plan. ii. Once adopted by the Company, managers will uphold the Accountability Measures (Section 4.4 Action Plan) set forth in the SEA/SH Prevention and Response Action Plan to maintain the confidentiality of all employees who report or (allegedly) perpetrate incidents of SEA/SH and VAC (unless a breach of confidentiality is required to protect persons or property from serious harm or where required by law). iii. If a manager develops concerns or suspicions regarding any form of SEA/SH or VAC by one of his/her direct reports, or by an employee working for another contractor on the same work site, s/he is required to report the case using the GM, but only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent. iv. Once a sanction has been determined, the relevant manager(s) is/are expected to be personally responsible for ensuring that the measure is effectively enforced, within a maximum timeframe of 14 days from the date on which the decision to sanction was made. v. If a Manager has a conflict of interest due to personal or familial relationships with the survivor and/or perpetrator, he/she must notify the respective company and the relevant SEA/SH focal points or personnel with the company. The Company will be required to appoint another manager without a conflict of interest to respond to complaints. vi. Ensure that any SEA/SH or VAC issue warranting Police action is reported to the Police, the client and the World Bank immediately, but only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent.

17. Managers failing to address ESHS or OHS incidents or failing to report or comply with the SEA/SH and VAC provisions may be subject to disciplinary measures, to be determined and enacted by the company’s CEO, Managing Director or equivalent highest-ranking manager. Those measures may include: i. Informal warning. ii. Formal warning. iii. Additional Training. iv. Loss of up to one week's salary. v. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. vi. Termination of employment.

18. Ultimately, failure to effectively respond to ESHS, OHS, SEA/SH and VAC cases on the work site by the company’s managers or CEO may provide grounds for legal actions by authorities.

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I do hereby acknowledge that I have read the foregoing Manager’s Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, SEA/SH and VAC requirements. I understand that any action inconsistent with this Manager’s Code of Conduct or failure to act mandated by this Manager’s Code of Conduct may result in disciplinary action.

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Individual Code of Conduct

Implementing ESHS and OHS Standards

Preventing Sexual Exploitation and Abuse, Sexual Harassment, and Violence Against Children

I, acknowledge that adhering to environmental, social health and safety (ESHS) standards, following the project’s occupational health and safety (OHS) requirements, and preventing sexual exploitation and abuse (SEA), sexual harassment (SH), and violence against children (VAC) is important.

The company considers that failure to follow ESHS and OHS standards, or to commit acts of SEA/SH or VAC —be it on the work site, the work site surroundings, at workers’ camps, or the surrounding communities—constitute acts of gross misconduct and are therefore grounds for sanctions, penalties or potential termination of employment. Prosecution by the Police of those who commit SEA/SH or VAC may be pursued if appropriate, but only upon informed survivor consent, or in the case of a minor, with appropriate caregiver consent.

I agree that while working on the project I will:

1. Attend and actively partake in training courses related to ESHS, OHS, HIV/AIDS, SEA/SH and VAC as requested by my employer. 2. Will wear my personal protective equipment (PPE) at all times when at the work site or engaged in project related activities. 3. Take all practical steps to implement the contractor’s environmental and social management plan (CESMP). 4. Implement the OHS Management Plan. 5. Adhere to a zero-alcohol policy during work activities, and refrain from the use of narcotics or other substances which can always impair faculties. 6. Consent to Police background check. 7. Treat women, children (persons under the age of 18), and men with respect regardless of sex, race, color, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or nationality, sexual orientation, gender identity, or other status. 8. Not use language or behavior towards women, children or men that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate. 9. Not engage in sexual exploitation, which is defined as any actual or attempted abuse of position of vulnerability, differential power or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. 10. Not engage in sexual abuse, which is defined as the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. 11. Not engage in sexual harassment, which is defined as any unwelcome sexual advance, request for sexual favor, verbal or physical conduct or gesture of a sexual nature, or any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment.

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12. Not engage in sexual favors, which is a form of sexual harassment—for instance, making promises or favorable treatment dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior. 13. Not participate in sexual contact or activity with children—including grooming or contact through digital media. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse. 14. No have sexual interactions with members of the surrounding communities. This includes relationships involving the withholding or promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex—such sexual activity is considered “non-consensual” within the scope of this Code. 15. Consider reporting through the GM or to my manager any suspected or actual SEA/SH or VAC by a fellow worker, whether employed by my company or not, or any breaches of this Code of Conduct.

With regard to children under the age of 18:

16. Wherever possible, ensure that another adult is present when working in the proximity of children. 17. Not invite unaccompanied children unrelated to my family into my home unless they are at immediate risk of injury or in physical danger. 18. Not use any computers, mobile phones, video, and digital cameras or any other medium to exploit or harass children or to access child pornography (see also “Use of children's images for work related purposes” below). 19. Refrain from physical punishment or discipline of children. 20. Refrain from hiring children for domestic or other labor below the minimum age of 14 unless national law specifies a higher age, or which places them at significant risk of injury. 21. Comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. 22. Take appropriate caution when photographing or filming children (See Annex 2 for details).

Use of children's images for work related purposes

When photographing or filming a child for work related purposes, I must:

23. Before photographing or filming a child, assess and endeavor to comply with local traditions or restrictions for reproducing personal images. 24. Before photographing or filming a child, obtain informed consent from the child and a parent or guardian of the child. As part of this I must explain how the photograph or film will be used. 25. Ensure photographs, films, videos, and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be sexually suggestive. 26. Ensure images are honest representations of the context and the facts. 27. Ensure file labels do not reveal identifying information about a child when sending images electronically.

Sanctions

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I understand that if I breach this Individual Code of Conduct, my employer will take disciplinary action which could include:

6. Informal warning. 7. Formal warning. 8. Additional Training. 9. Loss of up to one week’s salary. 10. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. 11. Termination of employment. 12. Report to the Police if warranted.

I understand that it is my responsibility to ensure that the environmental, social, health and safety standards are met. That I will adhere to the occupational health and safety management plan. That I will avoid actions or behaviors that could be construed as SEA/SH or VAC. Any such actions will be a breach this Individual Code of Conduct. I do hereby acknowledge that I have read the foregoing Individual Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, SEA/SH and VAC issues. I understand that any action inconsistent with this Individual Code of Conduct or failure to act mandated by this Individual Code of Conduct may result in disciplinary action and may affect my ongoing employment.

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Annex 8: PROTOCOL FOR CONSULTATION AND WORKS CONSTRUCTION UNDER COVID-19 GERMP

Introduction The novel coronavirus disease (COVID-19) has been spreading rapidly across the world since December 2019, following the initial cases in Wuhan, Hubei Province, China. Whilst the pandemic imposed tremendous strain on the health systems as they try to cope with the increase demand for services, it has also resulted in tremendous economic and social hardship as governments institute measures such as ‘social distancing’ to limit the spread of the disease. One of the consequences of these measures was the closure of schools, limit of works, trade, closure of borders, and other economic activities. Immediate action is required to ensure continuity and restarting of economic activities and projects implementation once the pandemic effects reduce or subsides. This is particularly critical in the Bank’s least developed client countries like The Gambia. A key source of guidance on communications, civil works, and stakeholder engagement that the Project will draw on is the Ministry of Health guidelines which are on line with WHO’s “COVID-19 Strategic Preparedness and Response Plan OPERATIONAL PLANNING GUIDELINES TO SUPPORT COUNTRY PREPAREDNESS AND RESPONSE” (2020). These guidelines outline the following approach in their Risk Communication and Community Engagement - Pillar 2. It will lay the basis for the Project’s stakeholder engagement and civil works implementation approach. The project will also draw on other recently-available resources for carrying out the implementation of the civil works in the context of COVID-19, including the World Bank’s “Technical Note: Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on conducting public meetings” (March 20, 2020). These guidelines will be taken into consideration for the civil works to protect workers, the affected communities and Project staff. In The Gambia, the first cases of COVID-19 were reported in March 2020, and following a presidential address on March 17, 2020, The Gambia closed all schools and education institutions as a measure to protect children and communities to control the spread of the virus. The Gambia has declared a state of Emergency, which is still maintained by the Authorities. Given the social distancing recommended to stop or reduce the COVID 19 transmission, the GERMP PIU has decided to elaborate this Protocol in order to implement the upcoming stakeholder sensitization and civil works implementation in a very safe manner.

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1- Methodology In order to meet best practice approaches, the Project will apply the following principles for stakeholder engagement and civil works implementation:

• Openness and life-cycle approach: public consultations for the Project will be arranged during the whole lifecycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation • Informed participation and feedback: information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholders’ feedback, for analyzing and addressing comments and concerns

• Inclusiveness and sensitivity: stakeholder identification is undertaken to support better communications and build effective relationships. The participation process for the projects is inclusive. All stakeholders, always, are encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention should be given to vulnerable groups, in particular women, youth, disabled, elderly and the cultural sensitivities of diverse ethnic groups

• Flexibility: if social distancing inhibits traditional forms of engagement, the methodology should adapt to other forms of engagement, including various forms of internet, radio, or TV communication. • Workers: to avoid or reduce the risk of contagion or spreading the COVID-19, all workers will wear their mask, goggle, and social distancing will closely be followed by all workers at the site. Same measures will be followed during interactions with local communities.

• Affected Parties – persons, groups and other entities within the Project Area of Influence (PAI) that are directly influenced (actually or potentially) by the Project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures; • Vulnerable Groups – persons who may be disproportionately impacted or further disadvantaged by the Project as compared with any other groups due to their vulnerable status17, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the project.

17 Vulnerable status may stem from an individual’s or group’s race, national, ethnic or social origin, color, gender, language, religion, political or other opinion, property, age, culture, literacy, sickness, physical or mental disability, poverty or economic disadvantage, and dependence on unique natural resources.

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Disadvantaged / vulnerable individuals or groups It is particularly important to understand whether project impacts may disproportionately fall on disadvantaged or vulnerable individuals or groups, who often do not have a voice to express their concerns or understand the impacts of a project and to ensure that awareness raising and stakeholder engagement with disadvantaged or vulnerable individuals or groups on infectious diseases and medical treatments in particular, be adapted to take into account such groups or individuals particular sensitivities, concerns and cultural sensitivities and to ensure a full understanding of project activities and benefits. The vulnerability may stem from person’s origin, gender, age, health condition, economic deficiency and financial insecurity, disadvantaged status in the community (e.g. minorities or fringe groups), dependence on other individuals or natural resources, etc. Engagement with the vulnerable groups and individuals often requires the application of specific measures and assistance aimed at the facilitation of their participation in the project-related decision making so that their awareness of and input to the overall process are commensurate to those of the other stakeholders.

Within the Project, the vulnerable or disadvantaged groups may include and are not limited to the following: women headed households, elders, youth, people renting the land, especially women…etc. Vulnerable groups within the communities affected by the Project will be consulted through dedicated means, as appropriate. Description of the methods of engagement that will be undertaken by the project is provided in the following sections.

2- Strategy The PIU in collaboration with the stakeholders, and especially with the Contractor, will identify and examine all the activities planned within the framework of the project requiring the engagement of stakeholders, public consultations, and civil works implementation.

Then it will be a question of evaluating according to the targets, the location, and the size of the proposed activities by focusing on a strategy of limitation of contacts and gatherings as much as possible.

Continue the strategy by assessing the level of risk of spread with these commitments and how to align with restrictions in effect at the national level. Identify the critical activities for which the consultations cannot be postponed without significant impact on the project deadlines. At the end of this exercise, consider viable means to obtain the contributions and commitment of stakeholders. Identify how planned civil work activities may imply gathering and how to impose social distancing and the strict respect of the PPE to prevent from contagion like mask, goggle, hand sanitizers…etc. Before effective consultation and civil works will start, the Project will recommend the Contractor to start by a first field visit to identify the affected communities.

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The objective of this mission will be to:

• Identification of limits of the corridors, sites, and the affected communities • The Contractor and the PIU will also assess the media coverage to see which media channels are more suitable for spreading of preventive measures • According the affected areas, Contractor will review the best telecommunication coverage to decide which one they will use to communicate with communities • Traditional communication channels will also be assessed to verify how they can be effective in conveying relevant information to stakeholders from mosques, churches, griots According the outcomes of this first field visit mission, Contractor with the PIU will be able to start site preparation and sensitization of affected communities on the ESMP, GRM and COVID-19 measures recommended by the WHO and the Ministry of Health. For this second phase, the Project will implement specific measures to mitigate the risk of the COVID-19 transmission.

A precautionary approach will be taken for the consultation process and civil works implementation to prevent infection and/or contagion, given the highly infectious nature of COVID-19. The following are some considerations for selecting channels of communication and behavior for the safe implementation of the civil works, considering the current COVID-19 situation:

• Avoid public gatherings (considering national restrictions or advisories), including public hearings, workshops, community meetings, and in working sites

• As smaller meetings are permitted (Five people with distance of 1.5m distance between participants), consultations will be conducted in small-group sessions, such as focus group meetings. Efforts will be made to conduct meetings through telephone or, if possible, online, channels to reduce risk of contagion or contamination

• Employ channels of communications (TV, newspaper, radio, dedicated phone-lines, and mail) when stakeholders do not have access to online channels or do not use them frequently. Communication channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions

• Where direct engagement with project affected people or beneficiaries is necessary, identify channels for direct communication with each affected household via a context specific combination of email messages, online platforms, dedicated phone lines with knowledgeable operators

• Each of the proposed channels of engagement will clearly specify to PAP how feedback and suggestions can be provided by stakeholders

• For the civil works implementation, Contractor will delimit the site and provide posters showing measures to be strictly followed by all who are on site

• All workers will always wear their PPE and masks, goggles, and hand sanitizers will be available in all strategic areas of the site

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• Equipment to take temperatures for all entering in the work sites should be available. In each site, the contractor will have two thermometers • The contact of the Ministry of Health local COVID-19 committee will be communicated to all workers, the contact number will be posted on site. The Project will closely work with this committee to implement the Project in a safely manner In line with the above precautionary approach, different engagement methods are proposed and cover different needs of the stakeholders as below:

• Consultation meetings • Focus group meetings • One on one interview • Public notices • Electronic publications and press releases on the NAWEC website, NAWEC hour on West Coast • Telephone/Mobile Interview via • Text messages • Social media • Wearing of masks • Wearing of goggles • Availability of hands sanitizers • Thermometers in each working sites • Posters • Social distancing of 1,5 meter between workers

Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions It should also be noted that in the event that none of the above means of communication is considered adequate for the required consultations with stakeholders, the Contractor should discuss with the PIU to find out if the activity in question can be postponed at a later date, when significant stakeholder engagement is possible. When it is not possible to postpone the activity or when the postponement is likely to last more than a few weeks, the PIU should consult the Bank team for advice and guidance.

3- Management of COVID-19 during civil works A special COVID-19 induction will be performed for each employee before they are able to start work. Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID- 19 mitigation measures on women is properly considered. This induction will be entirely dedicated to COVID-19:

• How it spreads

• How to protect oneself (including washing protocols)

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• How to properly use PPE (mask and gloves) and requirements of wearing PPE

• Understanding symptoms and what to do if one is exhibiting them

• Understanding the impact of COVID-19 on vulnerable groups (who is vulnerable) This induction will be renewed for all workers every month. Every day before the start of activities, a specific briefing will be carried out by the Site Manager who is the team leader. The Site Manager will address the following points:

• Reminder of the context and the need to respect the rules • Reminder of barrier gestures: how to cough, hand hygiene (basins and soap will be always available on site), social distancing and wearing a mask

• Taking of temperature every morning before works start

• Reminder of the exceptional measures applicable to the activities concerned

• Reminder of the main symptoms of COVID-19

• Reminder of the COVID-19 Hotline 1052 4- Monitoring of symptoms and other hygiene and mitigation protocols • Symptoms associated with COVID-19 will be monitored in workers. Each worker should monitor the onset of symptoms for themselves and colleagues and inform their manager immediately if they feel unwell or suspect a colleague is not feeling well. If symptoms appear during the night, the employee notify their superior and not come to the construction site. The procedure applied will then be the same as for employees who will be present in the morning with fever.

• The Contractor will ensure the transportation to health centers by liaising with the COVID- 19 Hotline 1052 in case ambulances of the health centers are not available.

• PPE must be clean and for individual use only (they must not be shared, exchanged, or loaned between employees). Barrier/social distancing against COVID-19 must be applied during break times and meals. Drinking water materials for personnel such as a cup or water bottle must be available for all workers and must not be shared for use among workers. Anyone who is not an employee of the contractor, or its service providers is a visitor. Any visitor wanting access to the site must submit himself to the same COVID-19 mitigation controls as employees.

• Cleanliness, including sanitization, of personnel reception facilities must be maintained regularly throughout the day. Any waste likely to be infected must be managed to avoid any risk of contamination.

• The contractor will delimit the site and provide posters showing measures to be strictly followed by all who are on site.

• Workers must always wear masks, goggles, and maintain regular hand cleanliness. Hand sanitizers will be available in all strategic areas of the site.

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• Equipment to take temperatures for all entering in the work sites should be available. In each site, the contractor will have two thermometers, regularly cleaned to avoid contamination in each site. Taking of temperature and management of the thermometers should be the responsibility of the ESHS officer.

• The contact information of the local COVID-19 committee (set up by the Ministry of Health under the Governor with all the relevant stakeholders in each region) COVID-19 1025 Hotline will be communicated to all workers. The contact number will be posted on site. The Project will closely work with this committee to implement the Project in a safely manner.

Conclusion During all this process, recommended WHO hygienic practices will be respected and monitored by the PIU environmental and social safeguard team to ensure that mitigation measures would be properly followed and duly respected. As protocols and recommendations by the WHO changes in response to this pandemic, these protocols will be updated accordingly.

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Annex 9: MOU between NAWEC and the Department of Forestry

MOU NAWEC - Department of Forests MEMORANDUM OF UNDERSTANDING

BETWEEN

National Water and Electricity Company (NAWEC) & Department of Forestry (DOF)

Background

The Republic of The Gambia together with the International Development Association (IDA), European Investment Bank (EIB), and European Union (EU), collectively the “Lenders”), are preparing a new energy project to improve the power generation and transmission capacity in the country. The Gambia Electricity Restoration and Modernization Project (GERMP) and the Ecowas Regional Electricity Access Project (ECOWAS Reap) will increase the generation capacity through renewable sources, reinforce the transmission capacity in the Great Banjul Area, and expand access to electricity to rural Gambia, schools and health centers across the Gambia.

For the implementation of all these projects, the construction of substations and transmission and distribution lines by NAWEC shall impact part of the forest areas through the line’s routes. Activities including the releasing of rights-of-way, construction of access roads, and erection of pylons and poles may thus have a negative impact on the protective and ecological role of forests and on floral diversity.

The Forest also plays an important role in the supply of Non-Timber Forest Products (NTFPs) and lands which represent a substantial source of income for rural populations and, in particular, the most vulnerable groups (women and youths).

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Analysis of the negative impacts that the electricity networks will have on forests reveals the vital need to address the conflict between the requirement to cut down or trim trees for public interest and the ever-increasing demand of the population for timber and non-timber forest products so as to actively safeguard the protective and ecological role of forests.

An inclusive development of forests emerges as inevitable alternative, NAWEC, The World Bank, European Investment Bank, European Union and the ECOWAS have decided to solicit the services of the Department of Forestry- MECCNAR, which has the mandate in The Gambia to protect and manage the forest areas. The main objective of this collaboration is to elaborate a strategy for the Mitigation of the Negative Impacts of the Construction of Substation and Transmission and Distribution lines of the projects on forest covers through Reforestation and Restoration in the Classified Forests. See annexes

THEREFORE, THE FOLLOWING MEMORANDUM OF UNDERSTANDING HAVE BEEN AGREED UPON

BETWEEN:

The National Water and Electricity Company Ltd, Ministry of Petroleum and Energy (MoPE), located at Mamady Maniyang Highway, Kanifing-PO Box 609, Banjul The Gambia Tel (+220) 4375990 – Fax: (+220) 4375990 E-mail [email protected] On the one hand,

AND

The Department of Forestry at the Ministry of Environment, Climate Change and Natural Resources (MECCNAR), located at 5 Marina Parade, P.O. Box 504 – Banjul The Gambia Tel: (+220) 4201203, represented by its Director, Muhammed JAITEH, duly authorized for this purpose (hereinafter referred to as ''DoF ").

On the other hand,

The DoF and NAWEC are hereinafter collectively referred to as the "Parties" or individually as the ''Party".

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HEREINAFTER REFERRED TO AS THE UNDERSIGNED PARTIES ENTERED INTO BY AND BETWEEN THE UNDERSIGNED PARTIES: -

WHEREAS NAWEC and DoF entered into an MOU for the implementation of the Gambian Electricity Restoration and Modernization Project and the ECOWAS Regional Electricity Access Project (ECOWAS Reap) of the NAWEC World Bank/European Investment Bank and European Union funded Electricity Project.

WHEREAS The MOU will specify the general and specific arrangements regarding the Reforestation and Restoration of the impacted forests in the implementation of the Projects

WHEREAS In particular, The MOU will frame the guidance for the mitigation of the impacted forests areas by the DoF and NAWEC (which is the implementing agency for the Projects). The MOU will formalize the expressed willingness and capacity of both parties to co-operate.

WHEREAS The objectives of the MOU are:

(1) To define the roles of the two parties for the implementation of the mitigation strategies of the Projects on forests resources under NAWEC

(2) To ensure that the restoration and reforestation program is elaborated and implemented for the effective implementation of the Projects

NAWEC and DoF agree to cooperate and collaborate on the terms and conditions for the release of rights of-way and the restoration and/or compensation for the loss of forest areas;

NOW THEREFORE, the under-mentioned parties record the following terms and conditions:

TERMS and RESPONSIBILITIES

NAWEC shall

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❖ Bear the costs for the reforestation and restoration plan to be implemented by DoF ❖ Timely disburse required funds to the DoF for the smooth implementation of the mitigation program on impacted forests area. ❖ NAWEC will contact the DoF services before starting of works to present to them the route and the schedule of works; ❖ Provide the DoF-MECCNAR with all the necessary logistics to facilitate travel for implementation and monitoring restoration operations; ❖ Support field implementation and monitoring missions of DoF officers within the context of implementing of these projects; and ❖ Conduct evaluation missions in the field in collaboration with Dof to ensure the implementation of activities within the required time frame; ❖

DOF shall ❖ Review route plan and Environmental and Social Impact Assessment prepared by NAWEC PMU to ensure minimum damage to forest and tree cover ❖ Provide NAWEC PMU with clearance permits to fell or trim trees covering the entire project zone, as agreed in the above documents; ❖ Ensure that alien species are not introduced deliberately or by accident in the intervention zones; ❖ Develop, and submit to NAWEC for approval, a detailed Reforestation and Restoration plan and budget and timetable for implementation, including maintenance and survival plan to serve as the reforestation and restoration plan to mitigate losses due to the works being carried out; ❖ Implement the Reforestation and Restoration plan, including maintenance for survival ❖ Prepare and submit to the NAWEC PMU quarterly and annual technical and financial reports on activities undertaken to implement the Reforestation and Restoration Plan Conduct monitoring missions in the field together with NAWEC to ensure optimal implementation of the Memorandum of Understanding;

BINDING EFFECT

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This Memorandum of Understanding shall be binding upon both parties subject to the approval of the Reforestation and Restoration Program by funders (World Bank, European Investment Bank and European Union)

PERIOD of VALIDITY

The undersigned parties’ further record that this Memorandum of Understanding is valid and binding and will remain in force until the parties enter into a comprehensive Memorandum of Agreement at the project completion on such terms and conditions as the respective institutions may determine. The Memorandum of Understanding will be subject to the approval by both institutions. The MOU shall be terminated upon mutual agreement in writing.

ENVIRONMENTAL OBLIGATIONS

The two (2) Parties undertake to strengthen the capacities of affected local authorities and communities to ensure preservation of restored areas as well as the implementation of environmental enhancement actions.

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