Adentan Municipal Assembly

SFG3246 V4

Public Disclosure Authorized

MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT (MLGRD) GREATER ACCRA METROPOLITAN AREA (GAMA) SANITATION AND WATER PROJECT

Public Disclosure Authorized

ADENTAN MUNICIPAL ASSEMBLY

(AdMA)

Construction of Institutional Public Disclosure Authorized

Sanitation Facilities

ENVIRONMENTAL AND SOCIAL

MANAGEMENT PLAN (ESMP)

Public Disclosure Authorized FINAL ESMP

Prepared by: SAL Consult Limited, P. O. Box GP20200, Accra, Ghana April, 2017 SAL Consult Ltd GAMA - AdMA

ESMP PROJECT TEAM

Name Position Qualification Contribution to Report Seth A Larmie Chief Consultant MSc (Hydrology and Water Resources),  Quality Assurance VUB Brussels  Liaison with client  Review of draft report Emmanuel K Principal Consultant MSc (Environmental Policy and  Liaison with client Acquah Management) University of Hull, UK  Stakeholder Consultations  Socioeconomic and environmental baseline studies  Analysis of impacts  Review of draft report Nana Yaw Otu- Senior Consultant MPhil (Environmental Science), University  Stakeholder Consultations Ansah of Ghana, Legon  Socioeconomic and environmental baseline studies  Analysis of impacts Stephen Doso Jnr Consultant MSc (Sustainable Environmental  Stakeholder Consultations Management), University of Greenwich,  Socioeconomic and UK environmental baseline studies  Drafting of report Ewuresi Asmah Consultant MSc (Environmental Monitoring and  Stakeholder Consultations Management), University of Nottingham,  Socioeconomic and UK. environmental baseline studies Emmanuel Nii Consultant BSc (Forest Resources Technology), KNUST,  Stakeholder Consultations Adotey Addo Kumasi  Socioeconomic and environmental baseline studies

Email: [email protected]

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TABLE OF CONTENT

ESMP PROJECT TEAM ...... I

TABLE OF CONTENT ...... II

LIST OF FIGURES ...... IV

LIST OF TABLES ...... IV

LIST OF PLATES...... IV

ACRONYMS AND ABBREVIATIONS ...... VI

EXECUTIVE SUMMARY ...... VII

1.0 INTRODUCTION ...... 1

1.1 BACKGROUND ...... 1 1.2 OBJECTIVES/PURPOSE OF THE ESMP ...... 2 1.3 APPROACH AND METHODOLOGY ...... 2 1.3.1 Site Inspections ...... 2 1.3.2 Stakeholder Consultations ...... 4 1.3.3 Review of Available Literature/project documents ...... 5 1.3.4 Reporting ...... 5

2.0 DESCRIPTION OF THE PROPOSED PROJECT ...... 7

2.1 NEED FOR THE PROJECT ...... 7 2.2 BENEFICIARY INSTITUTIONS IN ADMA AND THEIR LOCATIONS ...... 7 2.3 DESCRIPTION/STATE OF EXISTING TOILET FACILITIES IN THE ASSESSED SCHOOLS ...... 10 2.4 PROPOSED SANITATION FACILITIES TO BE PROVIDED BY PROJECT ...... 13 2.5 DESCRIPTION OF KEY FEATURES OF PROPOSED SANITATION FACILITIES ...... 15 2.5.1 Toilet Facilities ...... 15 2.5.2 Water Supply ...... 16 2.5.3 Urinals ...... 16 2.6 LABOUR AND RELATED ISSUES ...... 17

3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS ...... 18

3.1 POLICY FRAMEWORK ...... 18 3.2 NATIONAL REGULATORY FRAMEWORK ...... 18 3.3 INSTITUTIONAL FRAMEWORK ...... 21 3.4 WORLD BANK SAFEGUARDS POLICIES ...... 23

4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS ...... 25

4.1 LOCATION AND SIZE ...... 25 4.2 PHYSICAL ENVIRONMENT ...... 28 4.2.1 Climatic Conditions ...... 28 4.2.2 Relief and Drainage ...... 28 4.2.3 Vegetation ...... 28 4.2.4 Geology and Soils ...... 29 4.3 SOCIO-ECONOMIC ENVIRONMENT ...... 30 4.3.1 Demographic Characteristics ...... 30

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4.3.2 Education and Literacy ...... 30 4.3.3 Employment and Industry ...... 31 4.3.4 Water Supply ...... 32 4.3.5 Sanitation and Hygiene ...... 32 4.3.6 Waste Management ...... 33

5.0 STAKEHOLDER CONSULTATIONS ...... 34

5.1 OBJECTIVES OF CONSULTATION ...... 34 5.2 STAKEHOLDER CONSULTATION STRATEGY AND PLAN ...... 34 5.3 STAKEHOLDERS CONSULTED ...... 38 5.4 OUTCOME OF STAKEHOLDER CONSULTATIONS CARRIED OUT DURING ESMP PREPARATION ...... 39 5.5 KEY ENVIRONMENTAL AND SOCIAL CONCERNS FROM STAKEHOLDER CONSULTATIONS ...... 46

6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS ...... 47

6.1 PROJECT AREA OF INFLUENCE ...... 47 6.1.1 Geographical Area of Influence ...... 47 6.1.2 Physical Environmental Media Influence ...... 47 6.1.3 Community Influence and Vulnerable Persons in the Institutions ...... 47 6.1.4 Institutional Influence ...... 48 6.2 PROJECT ACTIVITIES OF ENVIRONMENTAL AND SOCIAL CONCERN ...... 48 6.2.1 Preparatory Phase Activities ...... 48 6.2.2 Construction Phase Activities ...... 48 6.2.3 Operations and Maintenance Phase Activities ...... 49 6.2.4 Decommissioning Phase Activities ...... 49 6.3 CRITERIA OF IMPACT EVALUATION ...... 49 6.3.1 Duration of the Impact...... 49 6.3.2 Extent of the Impact ...... 49 6.3.3 Intensity of the Impact ...... 49 6.3.4 Impacts Severity ...... 50 6.4 EVALUATION OF POTENTIAL POSITIVE IMPACTS ...... 50 6.5 EVALUATION OF POTENTIAL ADVERSE IMPACTS ASSOCIATED WITH THE PROPOSED PROJECT ...... 52 6.6 EVALUATION OF RISKS TO SUSTAINABILITY OF PROJECT ...... 55

7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN ...... 57

7.1 MITIGATION/ACTION PLAN ...... 57 7.2 MITIGATION/ACTION PLAN FOR IDENTIFIED RISKS TO THE SUSTAINABILITY OF THE PROJECT ...... 62 7.3 ENVIRONMENTAL AND SOCIAL MONITORING PLAN AND REPORTING...... 65 7.3.1 Environmental and Social Monitoring Plan ...... 65 7.3.2 Environmental and Social Monitoring Reporting ...... 70 7.4 GRIEVANCE REDRESS PROCESS ...... 70 7.4.1 Background ...... 70 7.4.2 Objectives of the Grievance Redress Mechanism ...... 70 7.4.3 Grievance Redress Process ...... 71 7.5 CAPACITY BUILDING AND OTHER REQUIREMENTS FOR IMPLEMENTATION OF ESMP AND PERMIT CONDITIONS ...... 76 7.5.1 Objectives of the training ...... 76 7.5.2 Methodology for the training ...... 76 7.5.3 Output of the training ...... 77

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7.6 ESTIMATED BUDGET FOR ESMP IMPLEMENTATION...... 77

8.0 CONCLUSION ...... 79

9.0 BIBLIOGRAPHY ...... 80

ANNEXES ...... 81

ANNEX 1 STAKEHOLDER CONSULTATIONS ...... 82

ANNEX 2 CODE OF CONDUCT ...... 83

ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP ...... 84

ANNEX 4 GRIEVANCE FORM...... 85

LIST OF FIGURES

FIGURE 2-1: MAP OF ADMA SHOWING LOCATION OF ASSESSED SCHOOLS ...... 9 FIGURE 4-1: GREATER ACCRA REGIONAL MAP SHOWING LOCATION OF ADENTAN MUNICIPAL ...... 26 FIGURE 4-2: MAP OF ADENTAN MUNICIPALITY (SOURCE: GHANA STATISTICAL SERVICE, 2014)...... 27 FIGURE 4-3 TYPES OF WASTE MANAGEMENT IN THE SCHOOL FACILITIES (COLAN CONSULT, 2015A) ...... 33 FIGURE 7-1: GRIEVANCE REDRESS PROCESS FOR THE CONSTRUCTIONAL PHASE INSTITUTIONAL SANITATION FACILITIES PROJECT .... 73 FIGURE 7-2: GRIEVANCE REDRESS PROCESS FOR OPERATIONAL PHASE FOR THE INSTITUTIONAL SANITATION FACILITIES PROJECT .... 75

LIST OF TABLES

TABLE 2-1: DETAILS OF ASSESSED INSTITUTIONS IN ADMA ...... 7 TABLE 2-2: DETAILS OF EXISTING SANITATION FACILITIES IN THE ASSESSED INSTITUTIONS ...... 11 TABLE 2-3: DETAILS OF TOILET INTERVENTIONS TO BE PROVIDED IN THE BENEFICIARY SCHOOLS ...... 14 TABLE 3-1: SUMMARY OF WORLD BANK SAFEGUARD POLICIES ...... 23 TABLE 4-1: POPULATION OF PUPILS AND TEACHERS IN THE ASSESSED SCHOOLS (SOURCE: COLAN CONSULT, 2015A) ...... 31 TABLE 4-2 TYPE OF URINALS IN SCHOOLS (SOURCE: COLAN CONSULT, 2015A) ...... 33 TABLE 5-0-1: STAKEHOLDER ENGAGEMENT PROGRAMME ...... 35 TABLE 5-0-2: DETAILS OF STAKEHOLDER CONSULTATIONS ...... 40 TABLE 6-1: EVALUATION OF POTENTIAL POSITIVE IMPACTS...... 50 TABLE 6-2: EVALUATION OF POTENTIAL ADVERSE IMPACTS ...... 52 TABLE 6-3: EVALUATION OF RISKS TO THE SUSTAINABILITY OF THE PROJECT ...... 55 TABLE 7-1: MITIGATION MEASURES/ACTIONS FOR POTENTIAL SIGNIFICANT ADVERSE IMPACTS...... 57 TABLE 7-2: MITIGATION /ACTION PLAN FOR IDENTIFIED RISKS TO THE SUSTAINABILITY OF THE PROJECT ...... 62 TABLE 7-3: ENVIRONMENTAL AND SOCIAL MONITORING PLAN ...... 65 TABLE 7-4: CAPACITY BUILDING PLAN FOR IMPLEMENTATION OF ESMP AND PERMIT CONDITIONS ...... 76 TABLE 7-5: ESMP BUDGET...... 78

LIST OF PLATES

PLATE 1-1: SITE INSPECTION AT SOWA DIN MEMORIAL ADMA BASIC SCHOOL ...... 4 PLATE 4-1: VEGETATION AT ADJIRINGANOR ADMA BASIC SCHOOL ...... 29 PLATE 5-1: CONSULTATION WITH HEAD TEACHERS AND SHEP COORDINATORS OF AMRAHIA ADMA PRIMARY AND JHS ...... 45

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PLATE 5-2: CONSULTATION WITH HEAD TEACHERS, SHEP COORDINATORS, PREFECTS AND HEALTH CLUB MEMBERS OF CHRISTIAN FAITH MISSION SCHOOLS ...... 45 PLATE 5-3: CONSULTATIONS WITH SHEP COORDINATOR, PREFECTS AND HEALTH CLUB EXECUTIVES OF NII SOWA DIN MEMORIAL ADMA 2 PRIMARY AND JHS ...... 45

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ACRONYMS AND ABBREVIATIONS

AdMA Adentan Municipal Assembly BoQ Bill of Quantities EHSD Environmental Heath and Sanitation Department EPA Environmental Protection Agency ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan FMP Facilities Management Plan GAMA Greater Accra Metropolitan Area GES Ghana Education Service GHS Ghana Health Services GoG Government of Ghana GWCL Ghana Water Company Limited JHS Junior High School LI Legislative Instrument MA Municipal Authority MLGRD Ministry of Local Government and Rural Development MMA Metropolitan and Municipal Assembly MMDA Metropolitan, Municipal and District Assembly OP Operational Procedures PPE Personal Protective Equipment SHEP School Health Education Programme S&W Sanitation and Water ToR Terms of Reference WB World Bank WC Water Closet WD Works Department

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EXECUTIVE SUMMARY

The Government of Ghana (GoG) has received financing from the World Bank towards the cost of implementation of the Greater Accra Metropolitan Area (GAMA) Sanitation and Water Project (GAMA S&W Project). The objective of the Project is to increase access to improved sanitation and improved water supply in the GAMA, with emphasis on low income communities; and to strengthen management of environmental sanitation in the GAMA.

The GAMA Project, which has four components, supports eleven (11) Metropolitan and Municipal Assemblies (MMAs) spread across the Greater Accra Region. Part of the strategies under Component 1 of the Project is the provision of improved sanitation and water supply facilities in schools in each of the eleven (11) MMAs in GAMA, including hygiene education and campaigns for awareness raising and behavioural changes in low income communities.

Ghana’s Environmental Assessment Regulations, 1999 (LI1652) requires that for any start-up project which has potential to impact negatively on the environment and people, the undertaking should be assessed for its environmental and social impacts, and the appropriate mitigation measures identified prior to the undertaking for implementation. The Project has also triggered one of the World Bank Safeguards policies: the Environmental Assessment Policy OP4.01. These require that any potential environmental and social issues arising from the project implementation should be mitigated.

This ESMP is prepared to guide the construction and operation of the institutional sanitation facilities under the Adentan Municipal Assembly (AdMA) in accordance with the Environmental Assessment Regulations (EAR) 1999, LI 1652 and the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01).

Stakeholder consultations were carried out with key stakeholders to obtain their comments and concerns on the proposed project with respect to the potential environmental and socio-economic issues and impacts that have been addressed in the study. The stakeholders consulted comprise:

Project proponents:  Ministry of Local Government and Rural Development/ Project Coordinating Unit - Safeguards Specialist  Adentan Municipal Assembly - GAMA Project Coordinator

Engineering Consultant  Colan Consult - Resident Engineer (responsible for Safeguards); and - Clerk of Works

Contractors  Fekiop Construction Limited - Manager; and - Site Supervisor.  Macksams Limited - Manager

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Beneficiary Institutions  Ghana Education Service; Circuit Supervisor  WASH implementers (Head Teachers; SHEP Coordinators; representatives of School Management Committee and Parent Teacher Association; school children including school prefects and school health club executives) in the following institutions: - Adenta Community Kindergaten - Adenta Community Basic School - Amrahia AdMA Primary School - Amrahia AdMA JHS - Christian Faith Mission 1 Primary School - Christian Faith Mission 1 JHS - Christian Faith Mission 2 Primary School - Christian Faith Mission 2 JHS - Adjiringanor Kindergarten - Adjiringanor Primary - Adjiringanor Juniour High School (JHS) - Sowa Din Memorial AdMA 1 Primary - Sowa Din Memorial AdMA 1 JHS - Sowa Din Memorial AdMA 2 Primary - Sowa Din Memorial AdMA 2 JHS

Significant Environmental and Social Impacts

The significant adverse impacts identified from the analysis and evaluation of the potential impacts from the proposed project are stated below.

Preparatory Phase  Siting of Toilet Facility

Construction Phase  Soil impacts and sediment transport;  Air quality deterioration;  Vibration and noise nuisance;  Visual intrusion;  Destruction of property and obstruction of walkways;  Generation and disposal of solid waste;  Occupational health & safety;  Public safety & Traffic issues; and  Sanitation and public health.

Operational Phase  Nuisance from odour;  Waste generation;  Sanitation issues and public health impacts; and  Sustainability of the institutional facilities.

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Decommissioning Phase  Occupational/public safety and traffic impacts; and  Waste management.

Mitigation/Action Plan Mitigation and monitoring measures for the significant adverse impacts and identified risks to the sustainability of the project are stated below.

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Mitigation and monitoring actions for potential significant adverse impact No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) PREPARATORY PHASE 1. Siting of toilet facility  For all schools, Engineering Consultant to extensively consult school -Evidence of consultation with -Beneficiary -Prior to -Contractor/ authorities on the siting of toilet facilities in the school. The selection of authorities of beneficiary institutions construction Engineering sites should be agreed upon with the school authorities. institution on siting of facilities. - Daily Consultant  The selection of sites should take into consideration compatibility with -Complaints on siting of adjacent school facilities. The adjacent school facilities should not be at risk from the operation of the proposed toilets. facilities CONSTRUCTION PHASE 1. Soil impacts and  Vegetation (grasses and shrubs) should be cleared only when contractor -Observable change in turbidity -Construction Daily Contractor/ sediment transport is fully mobilised for construction. of water in drains site Engineering  Vegetation clearance (where necessary) and excavations should be -Nearby Consultant -Observable oil sheen in drains limited to the demarcated construction site. drains -Observation of rills/gullies  Backfill with excavated soil material where appropriate.  Re-vegetate areas around construction sites to restore the landscape.  Ensure that heaped sand delivered for construction works is covered with tarpaulin to prevent wind and water transport of soil particles.

2. Air quality deterioration  Deliver construction equipment and materials to the construction sites -Observation of air borne Construction Daily Contractor/ outside school sessions, such as in the evenings or on weekends. particulates (dust) and exhaust site Engineering  Speed limit for all vehicles and construction equipment should be less Consultant fumes -Immediate than 30km/h within the school environs and less than 50km/h within - Records of dust level environs communities. Provide speed limit signs to guide drivers/operators.  Dampen untarred routes of vehicles/trucks to the construction sites. measurements (dust  Haulage trucks carrying sand should be covered with tarpaulin. concentration should be below  Hydraulic concrete mixing machines should be used as much as possible 150µg/m3) and regularly service all construction equipment and machinery. -Records of dampening of construction sites and routes for vehicles/trucks 3. Vibration and noise  Demolition of old structures should be done outside school sessions, such -complaints on noise nuisance -Construction Daily Contractor/ nuisance as in the evenings or during weekends. site Engineering

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision)  Carpentry works, and other noise generating activities should as much as -Immediate Consultant possible be carried outside school sessions. environs  Hydraulic concrete mixing machines should be used as much as possible and regularly service all construction equipment and machinery. 4. Visual intrusion  The construction sites should be hoarded off from public view. -Hoarding in place -Construction Daily Contractor/  Ensure good housekeeping at the construction site. -Condition of areas around site Engineering  Ensure an acceptable post-construction site as per provisions in the construction site -Immediate Consultant contract. environs  Remove all construction equipment from the site after completion of work. 5. Destruction of property  Ensure construction equipment are not parked haphazardly to obstruct -Evidence of consultations with -Construction Daily Contractor/ and obstruction of walkways. affected property owners site Engineering walkways  As much as possible, do not dump construction materials in walkways. -Record of affected service -immediate Consultant  Provide safe alternative routes for pedestrians where walkways will be line/property and action taken environs obstructed. -Complains on affected  Consult affected property owners/users and seek their consent prior to property and obstruction of construction works. walkways  Realign all affected utility service lines.  Reinstate any damaged property such as pavements, etc. 6. Generation and  Apply the principles of Reduce, Reuse and Recover for waste -Availability and use of bins Construction Daily Contractor/ disposal of solid waste management. For example: -Records on frequency and site Engineering o Purchase the right quality and quantity of materials; location of waste disposal site Consultant o Ensure judicious use of construction materials such as pipes, of domestic and construction waste laterites, sand, etc.; o Reuse excavated soil material for backfilling and levelling if appropriate.  Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials.  Dispose all construction and domestic waste at AdMA approved dump sites.

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) 7. Occupational health  Engage experienced artisans for construction works. -Workers’ awareness of Construction Daily Contractor/ and safety (OHS) issues  All workers should be given proper induction/orientation on safety. Contractor’s health and safety site Engineering  The contractors should have a Health & Safety Policy to guide the Consultant policy construction activities. -Availability and proper use of  Regularly service all equipment and machinery.  Ensure first aid kits on site and a trained person to administer first aid. PPEs  Provide and enforce the use of appropriate personal protective -Availability and proper use of equipment (PPE) such as safety boots, reflective jackets, hard hats, hand warning signs gloves, earplugs, nose masks, etc. for the labour force. -Availability of first aid kit Comply with all site rules and regulations.  -Adherence to health and  Apply sanctions where safety procedures are not adhered to. safety procedures  Site meetings should create awareness on OHS. -Records on frequency, type and source of illness/accident/injury -Records on non-compliances -Absence of unauthorized persons at active construction sites 8. Public safety and traffic  Hoard off the construction sites to prevent access by unauthorised -Availability and proper use of Construction Daily Contractor/ issues persons. warning signs site Engineering  Use caution tapes and warning signs at the construction sites around Consultant -Hoarding of site trenches and excavations. -Use of caution tape around  Deliver construction equipment and materials to the construction sites outside school sessions such as in the evening or weekends. trenches/ excavations  Speed limit for all vehicles and construction equipment should be less -Records on frequency, type than 30km/h within the school environs and less than 50km/h within and source of communities. Provide speed limit signs to guide drivers/public. illness/accident/injury Do not park at unauthorised places to reduce the risk of accidents.  -Absence of unauthorized  Erect temporary road signs at junctions to the beneficiary institutions persons at active construction during the delivery of construction equipment and materials.

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision)  Ensure delivery trucks hired/contracted are in good condition to prevent sites breakdowns on roads.  Remove all construction equipment from the site after completion of work. 9. Sanitation issues and  Provide bins on site for temporary storage of domestic waste such as -Availability and use of bins Construction Daily Contractor/ public health impacts lubricant containers, drinking water sachets and carrier bags/packaging -Records on frequency and site Engineering materials. location of waste disposal site Consultant  Dispose all construction and domestic waste at AdMA approved dump of domestic and construction sites and in the approved manner. waste  Ensure all trenches or excavations made during the construction works do -Mobile toilet facilities in place not collect stagnant water which could breed mosquitoes. -Presence of stagnant water in  Provide separate temporary toilets (mobile toilets) for use by trenches construction workers. 10. Public Complaints/ - Implement Grievance Redress Mechanism, which will include such -Type and nature of complaints Project Weekly Grievance Grievances elements as: and concerns; community Redress o Lodging and registration of PAPs grievance by grievance redress -Complaint records (Record of Committee committee; grievance and number o Redress decision, feedback and implementation; resolved/unresolved) o Dissatisfaction and alternative action; and -Management and Stakeholder o Monitoring and evaluation. Meetings OPERATIONAL PHASE 1. Nuisance from odour  Comply with provisions in the Facilities Management Plan (FMP). -Smell of pungent odour -Beneficiary Daily Authorities of  Ensure good housekeeping at toilet facilities. institution beneficiary  Clean toilet facilities regularly with disinfectants. -Immediate institution/ SHEP  Empty bins in classrooms/offices/wards regularly. environs Coordinator  Liaise with AdMA to contract a registered waste management company to regularly collect and dispose refuse waste at AdMA approved dump site.  Dislodge septic tanks outside school sessions, such as on weekends. 2. Waste generation  Regularly empty waste bins at the various locations when full. -Waste disposal records Beneficiary -Daily Authorities of and disposal  Sensitize pupils/ staff on effective use of bins to avoid indiscriminate -Availability of bins institution beneficiary disposal of waste. institution/ SHEP -Litter around waste bin

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision)  Damaged waste bins should be replaced as appropriate. -Records of inspection and Coordinator  Liaise with AdMA to contract a registered waste management company to dislodging of septic tanks regularly collect and dispose waste at AdMA approved dump site.  Inspect septic tanks periodically and dislodge when full. 3. Sanitation issues and  Ensure pupils/staff wash their hands under running water and soap after -Cleaning roster -Toilet facility -Daily SHEP health impacts use of toilet facilities. -Clean environment -Waste -Week Coordinator/  Ensure good housekeeping at toilet facilities. Head of -Smell of pungent odour storage and  Clean toilet facilities regularly with disinfectants. Institution Availability of disinfectants collection  Ensure bins are properly covered at all times.  Avoid indiscriminate dumping of waste at waste storage and collection -Availability of cleaning PPEs sheds shed and always keep the place clean. and tools/materials  Provide disposable hand gloves for cleaning of sanitation facilities and -Availability of functional hand emptying of bins. wash facility  Create awareness on hygiene and sanitation issues, including proper use of sanitation facilities and proper handling and disposal of waste.  Comply with provisions in the FMP. 4. Complaints/ Grievances - Implement Grievance Redress Mechanism, which will include such -Type and nature of complaints Project -Weekly Grievance elements as: and concerns community Redress Committee o Lodging and registration of PAPs grievance by grievance redress -Complaint records (Record of committee; o Redress decision, feedback and implementation; grievance and number o Dissatisfaction and alternative action; and resolved/unresolved) o Monitoring and evaluation. SUSTAINABILITY OF INSTITUTIONAL FACILITIES 1. Flooding  As a precautionary measure against flooding, raise the foundation of all - Extent of flooding during Toilet facility During rains Authorities of toilet facilities to about 1 meter high. rains Institution/ PTA/  Provide adequate drainage around toilet facilities. Municipal - Drains clear of silt Monthly  Provide rain cover over all windows and doors of the toilet facilities. Assembly - Record of state of Rain  Beneficiary schools should ensure all broken louvre blades/or windows are replaced. covers - Record of state of louvre blades

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) 2. Security issues  Provide burglar proof at the doors and windows of toilet facilities. - Security measures (locks, Toilet facility Daily Authorities of burglar proof) functional Institution / PTA/  Connect electricity to all toilet facilities and provide adequate lighting in Municipal - Electricity availability and the toilets to ensure safe use. Assembly functioning light bulbs at  Maintain adequate security in the schools and at the sanitation facilities especially. Eg: through hiring a watchman. toilet facilities  MA should consider fencing of schools in future projects to improve - Watchman hired security.  Sensitize wider communities not to disturb school sanitation facilities 3. Unavailability of water  Confirm the source and reliability of the water supply prior to the - Confirmation of availability Toilet facility Prior to Authorities of commencement of construction. of water supply from GWCL commissioni Institution / PTA/  Ensure that storage tanks are installed for all the facilities to provide Municipal - Storage tanks installed and ng of continuous water supply even when GWCL lines are temporarily out of Assembly all connections and project/ order.  Ensure connection of water and installation of water storage tanks is plumbing functional Weekly completed and there is regular flow of water at the toilet facilities before - Leaks from plumbing commissioning/handing over of the facilities for use. 4. Funding  School authorities and PTA to incorporate discussions on funding for - Programme for PTA, SMCs, Beneficiary Monthly MLGRD-PCU/ water supply, electricity bills and maintenance of the facilities at the MMAs for fund raising for institution Municipal school management levels i.e. PTA Meetings and SMC meetings to ensure Assembly/ payment of water supply and availability of adequate long term fund for the O&M of the sanitation Consultant/ electricity bills, and facilities. Authorities of  Capacity building of School authorities /PTA for raising, mobilization and maintenance of the facilities Beneficiary stewardship of funding for O&M of the sanitation facilities to ensure - Receipts of payment of bills Institution/PTA availability of long term funding for the management of the sanitation - Audited accounts facilities.  ADMA Assembly stakeholder engagements to discuss innovations in funding for O&M from internally generated funds and from levies such as those on school (food, stationery) as well mainstreaming the O&M costs into PTA dues to ensure availability of adequate long term funding for O& M of the facilities.  The project should ensure that all outstanding electricity and water debts

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) of beneficiary institutions are paid and electricity and water connection restored to disconnected institutions.  The beneficiary institutions should ensure regular payment of electricity and water bills to ensure continuous supply of water and electricity to the facility. 5. Poor maintenance  The Engineering Consultant to include the relevant recommendations in - Record of training and -Beneficiary Monthly Authorities of culture the ESMP in the Facilities Management Plan (FMP). awareness creation on institution Institution /  For clusters of schools, where various units are to share the same toilet SHEP Facilities Management Plan facility, the SHEP Coordinators of the individual schools should coordinate Coordinators/ - Record of compliance with to ensure that roles and responsibilities are clearly assigned for the PTA/ Municipal cleaning and maintenance of the facilities. This should be done prior to Facilities Management Plan Assembly commissioning of the facilities. - Records on major  The assigned roles and responsibilities for the maintenance and breakdowns including management of the facilities should be incorporated into the FMP by the leakages Engineering Consultant. - Availability of school hygiene  Comply with provisions in the FMP such as: clubs o Replace damaged equipment/materials with durable ones during maintenance and repair works. o The beneficiary schools should hire cleaners for the sanitation facilities. o Develop and implement a maintenance regime for the facilities. o Report major breakdown of facilities to the Municipal GES Director. o Educate and create awareness on proper use of facilities. o Ensure all staff are trained in the effective use and management of the facilities, in collaboration with the Environmental Health and Sanitation Department. 6. Lack of awareness of  Stakeholders should be invited to attend monthly progress meetings to be - Monthly progress carried out -Beneficiary Monthly SMC/ PTA/ the project information constantly informed. - Information provided to institution Municipal SHEP  Before the project resumes, information on the project including its Committee teachers, students & PTA. benefits should be explained to teachers, students and the PTA.

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No. Environmental/ Social Monitoring Parameters Monitoring Frequency Responsibility Component Proposed Mitigation Measures Site (Implementation/ Supervision) DECOMMISSIONING PHASE 1. Occupational/ public  Personal protective gear are provided to workers involved with -Availability and proper use of -Project site -Daily Contractor/ safety and traffic decommissioning of facilities. PPEs Engineering -Adherence to health and impacts  Toilet facilities are available throughout the decommissioning period. Consultant safety procedures  Workers still have access to public toilet facilities in the communities or -Records on frequency, type can be conveyed to such facilities where needed, if mobile toilet facilities have been relocated. and source of  Final movement of vehicles and equipment comply with approved speed illness/accident/injury limits within the communities.  All community complaints are resolved before handing over sanitation project. 2. Waste management  Ensure that any remaining waste streams created during construction -Availability and use of bins -Project site -Daily Contractor/ activities and waste generated during decommissioning activities are -Records on frequency and Engineering collected from the project sites and properly disposed before handing location of waste disposal site Consultant over the project. of domestic and construction  Inspect the site to ensure that the contractor has properly cleaned up all waste construction sites before final payment is made to the contractor.

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Capacity Building and Other Requirements for Implementation of ESMP and Permit Conditions

Capacity building measures (refer to section 7.5 for a detailed capacity building Plan) and other requirements proposed to ensure effective implementation of the ESMP and environmental permit conditions are:  Training workshop and sensitization programmes for the Engineering Consultants, Contractors and their workers, school authorities, school children, AdMA and other key stakeholders on the ESMP and its implementation, EPA permit schedule and triggered World Bank Safeguards Policy; ESMP monitoring and reporting,  Induction on environmental, social occupational and public health and safety requirements of the workers; sensitization of workers on child sexual exploitation and HIV/AIDS, environmental management  Site Meetings; and  Reporting.

Conclusion

In keeping with these laws, this ESMP has identified and assessed key environmental and social impacts and concerns that may arise from the implementation of the proposed project. A monitoring programme to help detect changes arising from the predicted adverse impacts has also been presented in this ESMP. The recommendations outlined in the ESMP for the project will ensure a high level of health, safety and environmental management for the proposed project.

It is estimated that the implementation of the ESMP in the Adentan Municipality will cost about GH¢371,800.00. However, the proposed project has the potential to provide numerous benefits to the beneficiary schools and the national economy. These include improved sanitation, hygiene and waste management in the beneficiary institutions, improved access to sanitation facilities for vulnerable groups and employment opportunities.

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1.0 INTRODUCTION

1.1 Background

The objective of the GAMA S&W Project is to increase access to improved sanitation and improved water supply in the GAMA, with emphasis on low- income communities; and to strengthen management of environmental sanitation in the GAMA.

The GAMA Project supports eleven (11) Metropolitan and Municipal Assemblies (MMAs) spread across the Greater Accra Region. The project has four components: . Component 1 – Provision of water and environmental sanitation services to priority low income areas of GAMA; . Component 2 – Improvement and expansion of the water distribution network in the GAMA; . Component 3 – Improvement and expansion of waste water and faecal sludge collection, transportation and treatment in GAMA; and . Component 4 – Institutional Strengthening.

Provision of improved sanitation and water supply facilities in schools in each of the eleven (11) MMAs in GAMA, including hygiene education and campaigns for awareness raising and behavioural changes in low income communities, is part of the strategies under Component 1 of the Project.

Most schools in GAMA are faced with poor access to quality sanitation. This posed various degrees of risk to the pupils, teachers and other people within the area. The institutional sanitation component seeks therefore to scale-up sanitation, hygiene and waste management in the institutions.

Part of the Bank’s funds is to be used by the Metropolitan and Municipal Assemblies (MMAs) to undertake construction of improved sanitation and water supply facilities in schools within their jurisdiction where schools are faced with poor access to quality sanitation issues.

The Ministry of Local Government and Rural Development (MLGRD), is committed to undertake the construction activities in an environmentally and socially friendly manner, and in accordance with the World Bank’s Policy on Environmental Assessment (OP4.01) and GAMA Sanitation and Water Project Environmental and Social Management Framework (ESMF) guiding the Project as well as the Environmental laws of Ghana.

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MLGRD has therefore contracted Messrs SAL Consult Limited to prepare an Environmental and Social Management Plan (ESMP) for the implementation of the proposed institutional sanitation facilities in each of the eleven (11) MMAs. Adentan Municipal Assembly (AdMA) has registered the proposed project with the Environmental Protection Agency (EPA) in accordance with EAR 1999, LI 1652 and obtained environmental permit.

This ESMP is prepared to guide the construction and operation of the institutional sanitation facilities under AdMA in accordance with the Environmental Assessment Regulations (EAR) 1999, LI 1652 and the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01).

1.2 Objectives/Purpose of the ESMP

The objective/purpose of this ESMP is to guide the effective mitigation and management of potential environmental and social issues of the proposed construction and operation of institutional sanitation facilities in AdMA. The specific objectives of the ESMP include the following:  Identification of possible direct and indirect significant adverse impacts associated with the proposed interventions implementation in AdMA;  Assessment and evaluation of potential impacts of the proposed project on the biophysical and human environment;  Provision of practical, socially acceptable, technically and economically feasible and environmentally sustainable measures to address the potential adverse impacts; and  To comply with the World Bank’s Safeguards Policy on Environmental Assessment (OP 4.01).

1.3 Approach and Methodology

The approach and methodology adopted for the study include:  Site inspections;  Stakeholder Consultation;  Review of available literature; and  Reporting.

1.3.1 Site Inspections The Consultants visited some beneficiary institutions in AdMA between November 2016 and February 2017 to confirm the environmental and social issues and conditions to be affected or are likely to develop from the implementation of the proposed project.

Due to time constraints, all beneficiary institutions in AdMA could not be visited. The Consultants however selected a representative sample of institutions based on the environmental and social issues identified from the environmental screening and the extent of construction works. This was done in collaboration with the project proponents and the engineering consultant. Information on the remaining beneficiary schools which were not inspected was obtained from review of project documents (see section 1.3.3) prepared by the Engineering Consultant and AdMA on all the beneficiary schools. The Engineering Consultant and GAMA Project Coordinator for AdMA visited all the beneficiary schools during the project planning, feasibility studies, stakeholder engagements and screening activities.

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The inspections by SAL Consult covered the following:  the proposed construction sites and environs;  existing sanitation facilities in the beneficiary institutions (toilets, urinals and hand washing facilities);  existing waste collection and disposal facilities and water supply facilities; and  construction works that have been done for institutions where construction has started.

For beneficiary institutions where some construction works have been done, the inspection also ascertained the health and safety measures that had been put in place by the contractors, such as hoarding of the sites and use of cautionary tapes and warning signs around excavations and trenches.

The institutions visited are outlined below:  Adenta Community Kindergaten  Adenta Community Basic School  Amrahia AdMA Primary School  Amrahia AdMA JHS  Christian Faith Mission Schools (Cluster of Schools) - Christian Faith Mission 1 Primary School - Christian Faith Mission 1 JHS - Christian Faith Mission 2 Primary School - Christian Faith Mission 2 JHS  Adjiringanor ADMA Basic Schools (Cluster of Schools) - Adjiringanor Kindergarten - Adjiringanor Primary - Adjiringanor Juniour High School (JHS)  Sowa Din Memorial AdMA Basic Schools (Cluster of Schools) - Sowa Din 1 Primary - Sowa Din 1 JHS - Sowa Din 2 Primary - Sowa Din 2 JHS

Plate 1-1 shows one of the project sites at Sowa Din Memorial AdMA Basic Schools.

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Plate 1-1: Site inspection at Sowa Din Memorial AdMA Basic School

1.3.2 Stakeholder Consultations

Stakeholder consultations, involving one-to-one meetings, emails and phone calls, were carried out between November 2016 and February 2017 with some key stakeholders to obtain their comments and concerns on the proposed project with respect to the potential environmental and socioeconomic issues and impacts that have been addressed in the study. This includes the project proponents, some beneficiary institutions, engineering consultant and some contractors.

Details of the stakeholder consultations are presented in Chapter 5. Evidence of stakeholder consultations are provided in Annex 1.

Stakeholder consultations have been carried out with the following key stakeholders:

Project proponents:  Ministry of Local Government and Rural Development/ Project Coordinating Unit - Safeguards Specialist  Adentan Municipal Assembly - GAMA Project Coordinator

Engineering Consultant  Colan Consult - Resident Engineer (responsible for Safeguards); and - Clerk of Works

Contractors  Fekiop Construction Limited - Manager; and - Site Supervisor.  Macksams Limited - Manager

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Beneficiary Institutions  Ghana Education Service; Circuit Supervisor  WASH implementers (Head Teachers; SHEP Coordinators; representatives of School Management Committee and Parent Teacher Association; school children including prefects and health club executives) in the following institutions: - Adenta Community Kindergaten - Adenta Community Basic School - Amrahia AdMA Primary School - Amrahia AdMA JHS - Christian Faith Mission 1 Primary School - Christian Faith Mission 1 JHS - Christian Faith Mission 2 Primary School - Christian Faith Mission 2 JHS - Adjiringanor Kindergarten - Adjiringanor Primary - Adjiringanor Juniour High School (JHS) - Sowa Din Memorial AdMA 1 Primary - Sowa Din Memorial AdMA 1 JHS - Sowa Din Memorial AdMA 2 Primary - Sowa Din Memorial AdMA 2 JHS

1.3.3 Review of Available Literature/project documents

The following project documents prepared by the Engineering Consultant (Colan Consult) for AdMA were reviewed:  Baseline Study Report;  Draft Facilities Management Plan (FMP) and Hygiene Education Plan (HEP);  Preliminary Design of School WASH Facilities;  Assessment of Existing School WASH Facilities;  Knowledge, Attitudes and Practice (KAP) Study;  Environmental Screening Report;  Updated Environmental Management and Monitoring Plan; and  Environmental permit schedule.

1.3.4 Reporting

The major headings of this report include the following: a) Executive Summary; b) Introduction; c) Description of Proposed Project; d) Relevant Policies, Legal and Administrative Frameworks; e) Baseline Environmental and Social Conditions; f) Stakeholder Consultation; g) Description of Environmental and Social Impacts;

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h) Environmental and Social Impact Mitigation and Management Plan; i) Capacity Building Plan for Implementation of ESMP and Permit Conditions; j) Conclusions; k) Bibliography; l) Annexes.

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2.0 DESCRIPTION OF THE PROPOSED PROJECT

2.1 Need for the Project

Most schools in GAMA are faced with poor access to quality sanitation. This is as a result of inadequate toilet facilities to meet the schools’ population needs, poor condition of existing toilet facilities, waste management challenges, lack of water, etc. This poses various degrees of health risks to the pupils, teachers and other people within the area. There is therefore the urgent need to improve sanitation facilities within schools/institutions.

The institutional sanitation component of the GAMA Project therefore seeks to scale-up sanitation, hygiene and waste management in the institutions. The objective of the GAMA S&W Project is to increase access to improved sanitation and improved water supply in GAMA, with emphasis on low income communities and to strengthen management of environmental sanitation in GAMA. Part of the World Bank’s funds is to be used by the Metropolitan and Municipal Assemblies to undertake construction of improved sanitation and water supply facilities in schools/institutions within their jurisdiction where the schools/institutions are faced with poor access to quality sanitation issues.

2.2 Beneficiary Institutions in AdMA and their Locations

The beneficiary Municipal Assembly is the Adentan Municipal Assembly (AdMA). Twenty nine (29) schools in AdMA were assessed by the Engineering Consultant out of which twenty-seven (27) are to benefit from the proposed sanitation facilities under the project. The details of the assessed schools in AdMA (including the names of schools, GPS coordinates, location and land area) are provided in Table 2-1. Figure 2-1 shows a map of AdMA and the locations of the assessed institutions.

Table 2-1: Details of Assessed Institutions in AdMA

NO. NAME OF SCHOOL GPS COORDINATES LOCATION LAND AREA NORTHING WESTING

1 Abubakar Sadiq Islamic School 5°40'45.50"N 0° 8'43.90"W Botwe Newtown 31.2m2

2 Adenta Community KG School 5°42'33.02"N 0° 9'38.11"W Adenta Flats 24m2

3 Adenta Community Primary School 5°42'28.33"N 0° 9'33.43"W Adenta Flats 130m2

4 Adenta Community JHS School

5 Adjiriganor AdMA Primary School 5°38'50.27"N 0° 8'10.56"W Adjiriganor 110.50m2

6 Adjiriganor AdMA JHS School

7 Amrahia AdMA Primary School 5°45'21.72"N 0° 8'31.32"W Amrahia 70m2

8 Amrahia AdMA JHS School

9 Bethel Presby Primary School 5°39'13.91"N 0° 7'42.01"W Otano About

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NO. NAME OF SCHOOL GPS COORDINATES LOCATION LAND AREA NORTHING WESTING 50m2 10 Bethel Presby JHS School

11 Christ Faith Mission '1' Primary 5°44'3.76"N 0° 9'10.96"W Frafraha 370m2 School

12 Christ Faith Mission '1' JHS School

13 Christ Faith Mission '2' Primary School

14 Christ Faith Mission '2' JHS School

15 Holy Rosary R/C Primary School 5°41'55.90"N 0°10'2.30"W New Adenta 200m2

16 Holy Rosary R/C JHS School

17 Icodehs Islamic Primary School 5°41'39.01"N 0° 8'32.71"W New Adenta 150m2

18 Icodehs Islamic JHS School

19 Knowledge and Faith School 5°39'35.60"N 0° 8'23.00"W Dzen Ayor about 50m2

20 Mercy Islamic Primary School 5°42'1.62"N 0° 8'4.93"W Lakeside/Japan 80.58m2 Motors 21 Mercy Islamic JHS School

22 Nii Sowah Din Memorial '1' 5°40'33.31"N 0° 7'29.36"W Nmai Dzorn 381.5m2 Primary School

23 Nii Sowah Din Memorial '1' JHS School

24 Nii Sowah Din Memorial '2' Primary School

25 Nii Sowah Din Memorial '2' JHS School

26 Ogbojo Presby Primary School 5°40'2.08"N 0° 8'34.28"W Ogbojo 300m2

27 Ogbojo Presby JHS School

28 Sraha AdMA Primary School 5°40'36.24"N 0° 8'17.19"W Sraha 150m2

29 St. Francis Catholic Basic School 5°40'49.96"N 0° 8'16.60"W Ashale Botwe 200m2

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Figure 2-1: Map of AdMA showing location of assessed schools

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2.3 Description/State of Existing Toilet Facilities in the Assessed Schools

The current state/description of the existing toilet facilities in the assessed schools; including the types and size of facilities, population dependent on the facilities, current usage, and remarks from assessment made by the Engineering Consultant (Colan Consult) are presented in Table 2-2.

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Table 2-2: Details of Existing Sanitation Facilities in the Assessed Institutions NO. SCHOOL CAPACITY & TYPE PUPIL PER FUNCTIONALITY CONDITION CUBICLE STATUS 1 Abubakar Sadiq Islamic School 4 seater – VIP 168 In use Fairly sound structure, Broken main entrance doors (Exclusive) 2 Adenta Community KG School 5 seater – WC 60 In use Sound structure, Broken cisterns and minor leakages. Cubicles are clean (Exclusive) 3 Adenta Community Primary 21 seater – WC 49 Partial use Sound structure, Broken cistern and WC bowls, poor lighting and School (Exclusive) ventilation Cubicles are not clean 4 Adenta Community JHS School 17 seater – WC 31 Partial use Sound structure, Broken cistern and WC bowls, poor lighting and (Exclusive) ventilation Cubicles are not clean 5 Adjiriganor AdMA Primary 7 seater – WC 92 In use Fairy sound structure with minor cracks on walls and apron, poor School (Exclusive) ventilation and lighting, leaking septic tank with broken cover 6 Adjiriganor AdMA JHS School 4 seater - WC 71 In use Fairy sound structure with minor cracks on walls and apron, poor (Exclusive) ventilation and lighting, leaking septic tank with broken cover 7 Amrahia AdMA Primary School 9 seater – WC 85 In use Sound structure, defective door locks, broken cover of 1 no. biofil (Shared) digester 8 Amrahia AdMA JHS School 9 seater – WC 85 In use Sound structure, defective door locks, broken cover of 1 no. biofil (Shared) digester 4 seater - WC - Not in use Sound structure with broken windows and silted floors, being used as store for old furniture 6 seater - Biofill - Partial use Sound structure, only 3 function toilets, 1 no. broken digester cover (Exclusive) (teachers only) 9 Bethel Presby Primary School 6 seater – WC 106 In use Fairly sound structure with minor cracks, broken toilet bowl seat & (Exclusive) covers, poor ventilation and lighting, 10 Bethel Presby JHS School None N/A N/A Pupils use available public toilet at a fee, others resort to open defecation 11 Christ Faith Mission '1' Primary 8 seater – KVIP 145 Partial use Poor structure, several crack on wall and floor, immediate environs School heavily littered. Cubicles are not clean (Shared) 12 Christ Faith Mission '2' 8 seater – KVIP 86 Partial use Primary School (Shared) 15 Holy Rosary R/C Primary School 8 seater – KVIP 200 In use Weak structure, several cracks and breaks on wall and floor, broken (Shared) vent pipes and cubicle doors. Cubicles are not clean, poor maintenance 16 Holy Rosary R/C JHS School 8 seater – KVIP 75 Not in use regime (Shared)

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NO. SCHOOL CAPACITY & TYPE PUPIL PER FUNCTIONALITY CONDITION CUBICLE STATUS 17 Icodehs Islamic Primary School 6 seater – VIP 90 Not in use Weak/dilapidated structure with several cracks and breaks in walls and (Shared) floors 18 Icodehs Islamic JHS School 6 seater – VIP 90 Not in use (Shared) 19 Knowledge and Faith School 3 seater – VIP 119 In use Weak/dilapidated structure with few cracks in the walls, very poor (Exclusive) ventilation and lighting, poor maintenance regime 20 Mercy Islamic Primary School 10 seater – Squat 61 In use Sound structure, broken cisterns, poor ventilation, poor maintenance type WC regime (Exclusive) 21 Mercy Islamic JHS School 10 seater – WC 16 Partial use Weak structures, all WC’s are broken down/malfunction, pipe leakages (Exclusive) 22 Nii Sowah Din Memorial '1' 8 seater – Biofill 190 In use Very sound structure, poor maintenance regime observed Primary School (Shared) 23 Nii Sowah Din Memorial '2' 8 seater – Biofill 190 In use Primary School (Shared) 24 Nii Sowah Din Memorial '1' JHS 8 seater – WC 38 Partial use Sound structure, few broken cisterns, leakage in roof slab, poor School (Exclusive) maintenance regime 25 Nii Sowah Din Memorial '2' JHS 6 seater – WC 43 In use Sound structure, well maintained facility School (Exclusive) 26 Ogbojo Presby Primary School 7 seater – KVIP 156 In use Weak structure, severe cracks in cover slabs, walls and floor, poor (Shared) maintenance regime 27 Ogbojo Presby JHS School 7 seater – KVIP 156 In use (Shared) 28 Sraha AdMA Primary School 6 seater – WC 54 In use Fairly sound structure, minor cracks in the walls, poor ventilation and (Exclusive) lighting, facilities is obscured & susceptible to community encroachment 29 St. Francis Catholic Basic School 6 seater - VIP 105 Partial use Poor structure with cracks on walls and floor, poor ventilation and lighting, poor maintenance regime

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2.4 Proposed Sanitation Facilities to be provided by Project

The overview of sanitation facilities to be provided in the selected institutions in AdMA under the proposed project are as follows:  Rehabilitation and retrofitting of existing toilet facilities (water closet and septic tank);  Rehabilitation and expansion of existing septic tanks;  Demolition of existing defunct toilet facilities;  Construction of smart micro flush water closet (WC) with biofilm digester;  Construction of WC and septic tank;  Connection of water from GWCL supply lines;  Provision of water storage facilities.

Details of the specific toilet interventions to be provided under the project in each of the beneficiary schools is provided in Table 2-3. The choice of toilet facilities for each school was decided by the beneficiary schools after the design consultants, Colan Consult, had presented the available options as well as their respective advantages and disadvantages with respect to maintenance requirements, water requirements and cost of maintenance among others. The toilet facilities will be equipped with urinals and hand washing facilities, special cubicle for physically challenged pupils and changing room for girls.

Two schools – Bethel Presbyterian Primary & JHS and Knowledge and Faith School – will not benefit from the proposed project due to unavailability of land for the toilet facilities (as indicated in Table 2-3).

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Table 2-3: Details of toilet interventions to be provided in the beneficiary schools

NO. NAME OF SCHOOL PROPOSED INTERVENTION LOCATION

2-storey 12-seater WC toilet 1 Abubakar Sadiq Islamic School Botwe Newtown Water connection and provision of water storage tank Rehabilitation and retrofitting of the 2 Adenta Community KG School Adenta Flats existing 4-seater toilet with smart flush WC

Rehabilitation and expansion of the existing 2-seater toilet to 6-seater smart flush WC.

Water connection and provision of water storage tank Rehabilitation of existing toilet facilities 3 Adenta Community Primary School Adenta Flats Water connection and provision of water 4 Adenta Community JHS School storage tank 2 No. 10-seater WC toilets 5 Adjiriganor AdMA Primary School Adjiriganor Water connection and provision of water 6 Adjiriganor AdMA JHS School storage tank 6-seater WC toilet 7 Amrahia AdMA Primary School Amrahia Water connection and provision of water 8 Amrahia AdMA JHS School storage tank

9 Bethel Presby Primary School N/A (No space for toilet facilities) Otano

10 Bethel Presby JHS School

11 Christ Faith Mission '1' Primary 2 No. 12-seater WC toilets Frafraha School 2 No. 8-seater WC toilets 12 Christ Faith Mission '1' JHS School Water connection and provision of water 13 Christ Faith Mission '2' Primary storage tank School

14 Christ Faith Mission '2' JHS School Proposed 2 No. 8-seater micro flush toilet 15 Holy Rosary R/C Primary School New Adenta with a digester. 16 Holy Rosary R/C JHS School Proposed 2 No. 6-seater micro flush toilet with a digester

Water connection and provision of water storage tank 2 No. 8-seater WC toilets 17 Icodehs Islamic Primary School New Adenta

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NO. NAME OF SCHOOL PROPOSED INTERVENTION LOCATION Water connection and provision of water 18 Icodehs Islamic JHS School storage tank

19 Knowledge and Faith School N/A (No space available for toilet facilities) Dzen Ayor Proposed 2 No. 6-seater WC with septic 20 Mercy Islamic Primary School Lakeside/Japan tank Motors 21 Mercy Islamic JHS School Water connection and provision of water storage tank

22 Nii Sowah Din Memorial '1' Rehabilitation and retroffiting of existing 8- Nmai Dzorn Primary School seater WC toilets for JHS 1 & 2.

23 Nii Sowah Din Memorial '1' JHS Proposed 2 No. 6-seater smart flush WC School with biofil digester for Primary 1 & 2

24 Nii Sowah Din Memorial '2' Proposed 6-seater micro flush toilets with Primary School biofil digester next to the KG block.

25 Nii Sowah Din Memorial '2' JHS Water connection and provision of water School storage tank Proposed 2 No. 12-seater smart flush WC 26 Ogbojo Presby Primary School Ogbojo and septic tank 27 Ogbojo Presby JHS School Water connection and provision of water storage tank 2 No. 6 seater micro flush toilet with biofil 28 Sraha AdMA Primary School Sraha digester Water connection and provision of water storage tank Proposed 2 No. 10-seater micro flush toilet 29 St. Francis Catholic Basic School Ashale Botwe with biofil digester Water connection and provision of water storage tank

2.5 Description of Key Features of Proposed Sanitation Facilities

2.5.1 Toilet Facilities

Water-based technological options would be adopted in improving school sanitation because they are hygienic and are generally the most preferred choice. For each recommended technological option, the following key design considerations would be adhered to:  Separation of facilities for boys and girls;  Inclusion of changing rooms for menstrual hygiene. Changing rooms would be provided with appropriate WASH consumables such as water, soap, etc., and fittings like mirrors and hooks or hangers;  Facilities shall be provided to give access to pupils with disability and younger children;  Hand washing facilities would be provided either within or close to the toilets;

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 Preparation of FMPs to guide operation and maintenance.

Changing room for girls A changing room for girls shall be included in the design layout for use by adolescent girls during their menses. The room shall cover a minimum floor area of 3.5 m2, and shall be provided with a mirror, waste bin, storage and hand washing facility.

2.5.2 Water Supply

The following interventions would address water supply challenges in the schools:  Provision of connection to GWCL mains  Provision of storage tanks

The schools within AdMA have water mains within close proximity, as advised by Ghana Water Company Limited (GWCL). Water will be connected to the toilet facilities from the GWCL lines. The option of using borehole as a source of water was considered in the project design but was not preferred due to the high level of salinity of groundwater in the area.

The success of the proposed GAMA Project institutional sanitation facilities hinges heavily on readily available water at the beneficiary institutions and for use at the toilets. As such, the project design incorporates, in addition to connecting GWCL water supply lines into the sanitation facilities, provision of overhead poly tanks and surface pumps to store sufficient water to provide continuous water supply to the facilities even when GWCL supply is temporarily unavailable. These project features will be in place prior to the commissioning and handing over of the sanitation facilities. Elevated poly tanks will also be provided to store water and supply to the toilet facilities.

2.5.3 Urinals

The following are recommended to improve personal and school hygiene:  Provision of wall and gutter type urinals with adequate capacity;  Provision of infrastructure for adequate cleansing and effluent disposal; and  Preparation of Facilities Management Plans

Female Urinal Female urinals will be integrated in all toilet facility layout. The design will ensure comfort during use. The following are key in the provision of urinals for girls: . The female urinals will have an adequate elevated squatting area (up to 400mm). The space between the squatting area and back wall should be adequate (up to 500mm) for urinating. . Honey comb openings shall be provided above head height and about 1.8 m above outside ground level to allow for ventilation. . 60 cm of urinal length will be provided for every two (2) toilet cubicles.

Male Urinals Male urinals will also be integrated into the toilet facility layout. Male urinals may also be provided in the open when there are space constraints in locating the urinal within the toilet block. The following will be critical in providing urinals for boys:

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. Honey comb openings shall be provided above shoulder height and about 1.6 m above outside ground level to allow for ventilation. . 0.6m of urinal length will be provided for every unit.

2.6 Labour and Related Issues

The project construction activities will require less than ten (10.No) workers per site therefore labour influx from distant communities’ will not be required. Workers will be employed from among artisans in the local community and will return to their homes after completion of their daily assignments.

The conduct of workers on site will be guided by the model code of ethics provided in Annex 2 to be adopted by the contractor. The working hours will as much as possible be limited to non-school periods to minimize the interaction between students and construction workers and will therefore avoid exposure of students to any indecent behavior that may be exhibited by the workers. In addition, awareness meetings/ workshops will be conducted to sensitize workers on issues such as child sexual exploitation and HIV HIV/AIDS during project implementation.

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3.0 RELEVANT POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORKS

The relevant national and sector policies and plans, national legal and institutional frameworks and World Bank safeguards policies to guide the proposed construction of institutional sanitation facilities in Metropolitan and Municipal assemblies to ensure sustainable development and compliance with national and international regulations are briefly described below.

3.1 Policy Framework

The National Environment Policy (2013) The Ghana National Environmental Policy was formulated in 1995 and revised in 2013. The ultimate aim of the National Environmental Policy of Ghana is to improve the surroundings, living conditions and the quality of life of the entire citizenry, both present and future. It seeks to promote sustainable development through ensuring a balance between economic development and natural resource conservation. The policy thus makes a high quality environment a key element supporting the country’s economic and social development.

The National Environmental Sanitation Policy dated April 2010 The revised environmental sanitation policy seeks to refocus the priorities of the sector, so it is forward looking and effectively embraces the challenges of changing life-styles associated with modernization and improving wealth status. The policy lays the basis for developing a systematic approach and framework for identifying and harnessing resources for value-for-money (economy, effectiveness and efficiency) services to all.

The Community Water Supply and Sanitation Programme (1994) The Government has adopted a national water supply and sanitation programme to rationalize the water sector to promote and improve the delivery of water services in terms of economy, efficiency, effectiveness and satisfaction. The long term goals of the programme are generally directed at covering the entire country with potable water and adequate sewage disposal system by the year 2020 with emphasis on payment of adequate tariffs by consumers to ensure full cost recovery and to provide revenue for operations and maintenance and replacement of systems.

National Health Policy (2007) The National Health Policy document which aims at creating wealth through health, among other things places emphasis on improvements in personal hygiene, immunisation of mothers and children. The National Health Policy also argues that a healthy population could only be achieved if there were improvements in environmental hygiene and sanitation, proper housing and town planning, provision of safe water, safe food and nutrition and encouragement of regular physical exercise.

3.2 National Regulatory Framework

The Constitution of the Republic of Ghana (1992) The Constitution includes some provisions to protect the right of individuals to private property, and also sets principles under which citizens may be deprived of their property in the public interest (described in Articles 18 and 20). Article 18 provides that “…Every person has the right to own property either alone or in association with others.”

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In Article 20, the Constitution describes the circumstances under which compulsory acquisition of immovable properties in the public interest can be done: “No property of any description, or interest in, or right over any property shall be compulsorily taken possession of or acquired by the State unless the following conditions are satisfied:  The taking of possession or acquisition is necessary in the interest of defence, public safety, public order, public morality, public health, town and country planning or the development or utilization of property in such a manner as to promote the public benefit; and  The necessity for the acquisition is clearly stated and is such as to provide reasonable justification for causing any hardship that may result to any person who has an interest in or right over the property.”

Article 20 of the Constitution provides further conditions under which compulsory acquisition may take place: no property “shall be compulsorily taken possession of or acquired by the State” unless it is, amongst other purposes, “to promote the public benefit (Clause 1).

Ghana Investment Promotion Centre Act 1994, Act 478 The Ghana Investment Promotion Centre Act 1994 (Act 478) requires that every investor wishing to invest in the country must in its appraisal of proposed investment projects or enterprises, “…have regard to any effect the enterprise is likely to have on the environment and measures proposed for the prevention and control of any harmful effects to the environment...”.

Environmental Protection Agency Act 1994, Act 490 The Environmental Protection Agency Act 1994 (Act 490) gave mandate to the Agency to ensure compliance of all investments and undertakings with laid down Environmental Assessment (EA) procedures in the planning and execution of development projects, including compliance in respect of existing ones.

Environmental Assessment Regulations 1999, LI 1652 The Environmental Assessment Regulations 1999 (LI 1652) enjoins any proponent or person to register an undertaking with the Agency and obtain an Environmental Permit prior to commencement of the project.

Fees and Charges (Amendment) Instrument 2015 (LI 2228) The Fees and Charges (Amendment) Instrument 2015 (L.I. 2228) replaces the Fees and Charges (Amendment) Instrument, 2014 (LI 2216), and gives regulation to the fees and charges (Miscellaneous Provision) Act 2009, Act 793. The law provides a comprehensive rates, fees and charges collectable by Ministries, Department and Agencies (MDAs) for goods and services delivered to the public.

Water Resources Commission Act 1996, Act 522 The Water Resources Commission Act 1996 (Act 522) establishes and mandates the Water Resources Commission as the sole agent responsible for the regulation and management and the utilisation of water resources and for the co-ordination of any policy in relation to them. Section 13 prohibits the use of water (divert, dam, store, abstract or use water resources or construct or maintain any works for the use of water resources) without authority. The Act states under Section 24 that any person

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who pollutes or fouls a water resource beyond the level that the EPA may pre-scribe, commits an offence and is liable on conviction to a fine or a term of imprisonment or both.

GWCL Act/Statutory Corporations (Conversion to Companies) Act 461 of 1993 (as amended by LI 1648) The Statutory Corporations (Conversion to Companies) Act 461 of 1993 as amended by LI 1648, on 1st July 1999, transformed Ghana Water and Sewage Corporation into a 100% state owned limited liability, Ghana Water Company Limited (GWCL), with the responsibility for urban water supply only. The mandate of GWCL is to provide, distribute and conserve the supply of water in Ghana for public, domestic and industrial purposes in urban communities. GWCL may, after giving notice to the owner or occupier of any land or premises, enter on that land or premises and dig trenches, lay pipes and do any other acts reasonably necessary for the carrying out its functions.

Local Government Act, 1993 Act 462 This Act establishes and regulates the local government system and gives authority to the Regional Coordinating Council (RCC) and the District Assembly to exercise political and administrative power in the Regions and District, provide guidance, give direction to, and supervise all other administrative authorities in the regions and district respectively. The Assembly is mandated to initiate programmes for the development of basic infrastructure and provide municipal works and services as well as being responsible for the development, improvement and management of human settlements and the environment in the district.

Lands (Statutory Wayleaves) Act, 1963 (Act 186) The Lands (Statutory Wayleaves) Act, 1963 (Act 186) details the process involved in the occupation of land for the purpose of the construction, installation and maintenance of works of public utility, and for the creation of rights of way for such works. Further to this act, the statutory wayleave registration 1964 provides procedural details and grievance redress mechanism.

The State Lands Act, 1963 (Act 125) The Act 125 vests the authority to acquire land for the public interest in the President of the Republic. It also gives responsibility for registering a claim on the affected person or group of persons, and provides details of the procedure to do this. The State Lands Act, 1962 provides some details to be taken into consideration when calculating compensation such as definitions for (1) cost of disturbance, (2) market value, (3) replacement value, and so on.

Lands Commission Act, 2008 (Act 767) This Act provides for the management of public lands and other lands and for related matters. The Commission manages public lands and any other lands vested in the President by the Constitution or by any other enactment or the lands vested in the Commission. The Act advises the Government, local authorities and traditional authorities on the policy framework for the development of particular areas to ensure that the development of individual pieces of land is coordinated with the relevant development plan for the area concerned.

The Minister may, with the approval of the President, give general directions in writing to the Commission on matters of policy in respect of the management of public lands. The Commission has the following divisions:

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 Survey and Mapping;  Land Registration;  Land Valuation; and  Public and Vested Lands Management.

The Labour Act, 2003 (Act 651) Section 118(1) of the Labour Act 2003 (Act 651) stipulates that it is the duty of an employer to ensure that every worker employed works under satisfactory, safe and healthy conditions. Act 651 contains a number of specific provisions relating to an employer’s duty to its workers. These include providing and maintaining “at the workplace, plant and system of work that are safe and without risk to health” and taking “steps to prevent contamination of the workplaces by, and protect the workers from, toxic gases, noxious substances, vapours, dust, fumes, mists and other substances or materials likely to cause risk to safety or health”. A worker is required to report situations that he believes may pose “an imminent and serious danger to his or her life, safety or health”.

Workmen’s Compensation Law, 1987, PNDCL 187 It is to provide for the payment of compensation to workmen for personal injuries caused by accidents arising out and in the course of their employment. The tenets of the law places a large share of the burden of supporting workers injured at the workplace on the shoulders of the employers.

3.3 Institutional Framework

Ministry of Local Government and Rural Development The Ministry of Local Government and Rural Development (MLGRD) exists to promote the establishment and development of a vibrant and well-resourced decentralized system of local government for the people of Ghana to ensure good governance and balanced rural based development. The Environmental Health and Sanitation Directorate (EHSD) of MLGRD has oversight responsibility for sanitation. The Ministry has developed and is currently implementing a National Environmental Sanitation Policy and an accompanying plan, the National Environmental Sanitation Strategy and Action Plan (NESSAP) and Strategic Environmental Sanitation Investment Plan (SESIP). The Ministry has a Project Coordinating Unit (PCU) which is coordinating the GAMA project.

Metropolitan, Municipal and District Assemblies Metropolitan, Municipal and District Assemblies (MMDAs) are responsible for the provision of water and sanitation services within their respective areas of jurisdiction, including the planning and implementation of projects where necessary. They serve as the planning authority responsible for the overall development of their areas of jurisdiction. The proposed construction of institutional sanitation facilities is being carried out by 11 MMDAs in the Greater Accra Metropolitan Area (GAMA).

Environmental Protection Agency The Environmental Protection Agency is the body responsible for regulating the environment and ensuring the implementation of government policies on the environment. The functions of the Agency include:

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 ensuring compliance with any laid down environmental impact assessment procedures in the planning and execution of development projects, including compliance in the respect of existing projects;  promoting effective planning in the management of the environment;  imposing and collecting environmental protection levies in accordance with the Environmental Protection Agency Act 1994, Act 490 or regulations made under the Act; and  acting in liaison and co-operation with government agencies, District Assemblies and other bodies and institutions to control pollution and generally protect the environment.

Ministry Of Education/ Ghana Education Service (GES) The Ministry of Education/Ghana Education Service provides oversight responsibility for basic, secondary and tertiary education in Ghana. The School Health Education Program (SHEP) Unit under the Ghana Education Service is responsible for health promotion in schools up-to pre-tertiary level. The SHEP Unit facilitates the effective mobilization and deployment of available human, material and financial resources to equip school children with basic life skills for healthy living through skills- based health education, promoting good health and preventing diseases among the school population. There are SHEP Coordinators at the Municipal levels and also at the school level. In the schools, the SHEP Coordinators are responsible for coordinating water, sanitation and hygiene (WASH) issues.

Ghana Health Service The Ghana Health Service (GHS) is the public service body responsible for implementation of national policies under the control of the Minister for Health through its governing Council - the Ghana Health Service Council. The mandate of GHS is to provide and prudently manage comprehensive and accessible health service with special emphasis on primary health care at regional, district and sub-district levels in accordance with approved national policies. The functions of GHS include to:  undertake management and administration of the overall health resources within the service;  Promote healthy mode of living and good health habits by people;  establish effective mechanism for disease surveillance, prevention and control; and  perform any other functions relevant to the promotion, protection and restoration of health.

The School Health Education Programme is a joint mandate of the Ministries of Health and Education.

Ghana Water Company Limited (GWCL) GWCL is the state utility company responsible for portable water supply to all urban communities in Ghana. The mandate of GWCL is to provide, distribute and conserve the supply of water in Ghana for public, domestic and industrial purposes in urban communities. The connection of water supply to the toilet facilities under the project will mainly be from GWCL supply lines.

Community Water and Sanitation Agency Community Water and Sanitation Agency (CWSA) facilitate water supply and sanitation delivery for rural communities and small towns. CWSA plays a facilitative role in providing technical assistance for the planning and implementation of water and sanitation facilities in the districts.

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3.4 World Bank Safeguards Policies

The World Bank (WB) has published policies/procedures to guide the safe development of projects it is funding. Among the ten (10) WB Safeguards Policies, one (1) – OP 4.01 – is triggered by the proposed project. The WB safeguards policies and a summary of their core requirements are provided in Table 3-1.

Table 3-1: Summary of World Bank Safeguard Policies

No World Bank Summary of core requirements Potential for Remarks or Safeguard Trigger under recommendation for Policy proposed project proposed project 1 OP 4.01 Requires environmental assessment (EA) of Triggered The entire GAMA Environmental projects proposed for Bank financing to help project being funded by Assessment ensure that they are environmentally sound and the WB, including the sustainable, and thus to improve decision Construction of making. The EA takes into account the natural Institutional Sanitation environment (air, water, and land); human Facilities in MAs and health and safety; social aspects (involuntary Construction of Road resettlement, indigenous peoples, and physical Culvert Drains falls cultural resources); and trans boundary and under category B, and global environmental aspects. It categorizes this ESMP is in line with proposed projects into categories A, B, C or FI the requirement of the based on the extent of adverse impacts policy. anticipated from the project.

For Category A and B projects, an ESMP is to be prepared to guide the Implementation of mitigation measures for all identified environmental impacts from the proposed project. 2 OP 4.04: Do not finance projects that degrade or convert Not triggered Project locations and Natural critical habitats. Support projects that affect design will not affect Habitats non- critical habitats only if no alternatives are any critical habitats. available and if acceptable mitigation measures are in place. The policy strictly limits the circumstances under which any Bank-supported project can damage natural habitats (land and water areas where most of the native plant and animal species are still present). 3 OP 4.09: Pest Support integrated approaches to pest Not triggered The project will not Management management, identify pesticides that may be involve the use of financed under the project and develop pesticides. appropriate pest management plan to address this. 4 OP 4.36: Aim is to reduce deforestation, enhance the Not triggered Project location and Forest environmental contribution of forested areas, design will not affect promote afforestation, reduce poverty, and any critical forests. encourage economic development.

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No World Bank Summary of core requirements Potential for Remarks or Safeguard Trigger under recommendation for Policy proposed project proposed project Support sustainable and conservation oriented forestry. Do not finance projects that involve significant conversion or degradation of critical forest areas. 5 OP 4.11: Investigate and inventorise cultural resources Not triggered No culturally sensitive Physical potentially affected. Include mitigation sites identified. Cultural measures when there are adverse impacts on Resources physical cultural resources or avoid if possible

6 OP 4.12: Assist displaced persons in their effort to Not triggered The study did not find Involuntary improve or at least restore their standards of any evidence of Resettlement living. Avoid resettlement where feasible or existence or occurrence minimise. Displaced persons should share in of Involuntary project profits. Resettlement. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects. 7 OP 4.10: Screen to determine presence of indigenous Not triggered No indigenous groups Indigenous peoples in project area. Policy triggered were identified. Peoples whether potential impacts are positive or negative. Design mitigation measures and benefits that reflect indigenous peoples’ cultural preferences. 8 OP 4.37: Requires that experienced and competent Not triggered The proposed project Safety of professionals design and supervise construction, does not involve the Dams and that the borrower adopts and implements construction of dams. dam safety measures through the project cycle. The policy distinguishes between small and large dams by defining small dams as those normally less than 15 meters in height. Large dams are 15 meters or more in height. 9 OP 7.50: Ascertain whether riparian agreements are in Not triggered The proposed project Projects on place, and ensure that riparian states are does not involve International informed of and do not object to project international waters. Waterways interventions. 10 OP 7.60: Ensure that claimants to disputed areas have no Not triggered No issues of land Projects in objection to proposed project. dispute were identified. Disputed Areas

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4.0 BASELINE ENVIRONMENTAL AND SOCIAL CONDITIONS

Baseline conditions give the existing status of the environment in the area before the commencement of the proposed project. The information serves the purpose of a base reference against which the changes due to the implementation of the project are measured. The ensuing therefore constitutes the baseline conditions of the proposed project area, which includes the existing physical and socioeconomic environment.

4.1 Location and Size

The proposed project district is the Adentan Municipal Assembly (AdMA), which is one of the sixteen (16) Metropolitan, Municipal and District Assemblies (MMDAs) in the Greater Accra Region of Ghana (as shown in Figure 4-1). AdMA lies 10 kilometres to the Northeast of Accra, which is specifically located on latitude 5′ 43′′N and longitude 0′ 09′′W. The Municipal has a land area of about 928.4 sq. km. It shares boundaries with Tema Metropolis and Kpong Katamanso Municipal to the east and north, La Nkwantanang Municipal to the west and Accra Metropolis and Ledzokuku Krowor Municipal to the south. (See Figure 4-2).

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Figure 4-1: Greater Accra Regional Map showing location of Adentan Municipal

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La Nkwantanang Madina Municipal

Kpone Katamanso Municipal

Accra Metropolis Tema Municipal

Ledzokuku Krowor Municipal

Figure 4-2: Map of Adentan Municipality (Source: Ghana Statistical Service, 2014)

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4.2 Physical Environment

4.2.1 Climatic Conditions

The Adentan Municipal experiences two types of rainy seasons: the first and the major season is from April to July while the second but minor season is from September to November. The bi-modal rainfall pattern provides a suitable environment for farming activities in most months (8 months) of the year.

Temperatures are generally high throughout the year. March to April is usually the hottest period with temperatures reaching 32°C during the day and 27°C at night. Cooler temperatures occur from May to September, with a high of 27-29°C during the day and 22-24°C in the night.

4.2.2 Relief and Drainage

The land area of the municipality generally consists of plains interspersed with undulating topography in the south and west. The Akwapim Range rises steeply above the northern part and lies generally at 375-420m south of Aburi and falls to 300m southwards. The main rivers and streams traversing the municipality include the Sisami and the Dakubi.

The topography at the various beneficiary institutions is generally flat. No river or stream flows at the project sites.

4.2.3 Vegetation

The municipality is covered by savannah grass with scattered neem trees to the southern part while the northern part has savannah semi-rain forest with deciduous trees but due to human activities, the general vegetation cover of some parts of the community have changed to grassland and in some places, bare land. The climatic condition and vegetation cover have contributed immensely to animal rearing and vegetable production in the area.

The vegetation found at the project sites in most schools are common grasses found in other areas of the beneficiary schools and in the municipality as a whole. Individual stands of common trees such as Azadirachta indica (neem tree), Khaya senegalensis (mahogany) and Albizia lebbeck (woman’s tongue) may be found in the compounds of some schools. Trees are generally not expected to be affected from the project construction. Plates 4-1 shows the vegetation at the project site of Adjiringanor AdMA Basic School, which is typical of the vegetation at the various project sites.

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Plate 4-1: Vegetation at Adjiringanor AdMA Basic School

4.2.4 Geology and Soils

The municipality is underlain by Precambrian rocks of the dahomeyan formation. Sedimentary rocks are deposited at the southern, western and eastern parts of the municipality. Metamorphic rock deposits are found at the northern parts that consist of granite and gneiss therefore making this part rocky and stony in appearance. The rock formation in the area has promoted stone quarry and sand winning, providing a kind of informal employment.

Yields of boreholes in the Precambrian formation are low due to low transmissivities and low storativities (HAP, 2006), and range from 1 to 3 m3/h as shown in Figure 5. Groundwater from the dahomeyan formation are characterized by high salinity.

Figure 4-3: Groundwater potential zones in Southern Ghana (WRRI, 1996b)

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Transmissivity values range 0.3 m2/d to 42 m2/d in the Dahomeyan formation (Agyekum, 2004). Information on aquifer storativity is lacking. Borehole success rate (defined as boreholes with a minimum yield of 0.78 m3/h) in the Precambrian rocks is poorest in the Dahomeyan formation with an average value of 36%). Depth of boreholes varies between 45 m and 70 m with an average depth of 55 m.

4.3 Socio-Economic Environment

The socioeconomic characteristics of AdMA are presented below.

4.3.1 Demographic Characteristics

The population of Adentan Municipal, according to the 2010 Population and Housing Census, is 78,215 which constitute 50.3% males and 49.7% females. About 62.5% of the population resides in urban and 37.5% in rural areas.

The municipality has a sex ratio of 101.3. The population of the district depicts a broad base population pyramid which tapers off with a small number of elderly persons. The age dependency ratio for the municipality is 51.1, the age dependency ratio for males is lower (49.5) than that of females (52.8). However, the average household size in the municipality is 3.7 persons per household with children constituting the largest proportion of the household members which accounts to 35.1% (Ghana Statistical Service, 2014).

4.3.2 Education and Literacy elsewhere

Education serves as the backbone of development in every geographical area. In the municipal, 91.9% of the population 11 years and older are literate in one language or another. However, of the literate population, more than half (54.8%) are literate in English and Ghanaian language.

Nearly 60% (57.9%) of the population have attended school in the past, while 34.3% are attending now. However, more females (10.5%) than males (5.2%) have never attended. About 71.4% of the population 3 years and older are attending basic education comprising kindergarten (13.8%) primary (40.7%), and JSS/JHS (16.9%). Also, 9.3% of the populations are attending higher education beyond the secondary school level with tertiary level ranking 8%. Table 4-1 shows the population of pupils (boys and girls) as well as the population of male and female teachers in the assessed schools in AdMA.

There are forty-two (42) Public/Government Owned Schools (KG, primary, JHS, SHS, and tertiary) that constitute 12%, and two hundred and ninety-eight (298) Private Schools that constitute 88% of all the educational institutions in the Adentan Municipality. Currently, enrolment in schools (Public and Private) up to Junior High level is 36,782 of which 17,931 (49%) are boys and 18,851 (51%) are girls.

Also, there are no Public/Government Owned Second Cycle Institutions in the municipality and therefore students travel to other Metropolitan/Municipal/District (MMDAs) to access such institutions. Those who can afford the fees patronize the few privately owned Second Cycle

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Institutions in the municipality. There are three private tertiary level institutions in the municipality, namely, Islamic University, Radford University and Christian University College (Ghana Statistical Service, 2014).

Table 4-1: Population of pupils and teachers in the assessed schools (Source: Colan Consult, 2015a)

No. NAME OF SCH. PUPIL ENROLLMENT TEACHERS BOYS GIRLS TOTAL MALE FEMALE TOTAL 1 Abubakar Sadiq Islamic School 131 185 316 3 16 19 2 Adenta Community Primary School 136 164 300 0 4 4 3 Adenta Community KG School 495 537 1032 3 21 24 4 Adenta Community JHS School 232 295 527 4 14 18 5 Adjiriganor AdMA Primary School 302 345 647 4 14 18 6 Adjiriganor AdMA JHS School 100 121 221 4 7 11 7 Amrahia AdMA Primary School 274 254 528 0 15 15 8 Amrahia AdMA JHS School 112 128 240 4 7 11 9 Bethel Presby Primary School 311 324 635 4 2 6 10 Bethel Presby JHS School 90 96 186 3 7 10 11 Christ Faith Mission '1' Primary School 271 307 578 2 12 14 12 Christ Faith Mission '1' JHS School 151 200 351 5 11 16 13 Christ Faith Mission '2' Primary School 180 165 345 2 8 10 14 Christ Faith Mission '2' JHS School 87 91 178 5 11 16 15 Holy Rosary R/C Primary School 345 455 800 1 15 16 16 Holy Rosary R/C JHS School 130 170 300 5 8 13 17 Icodehs Islamic Primary School 202 215 417 2 8 10 18 Icodehs Islamic JHS School 57 64 121 5 5 10 19 Knowledge and Faith School 124 113 237 5 13 18 20 Mercy Islamic Primary School 237 244 481 6 13 19 21 Mercy Islamic JHS School 136 117 253 5 9 14 22 Nii Sowah Din Memorial '1' Primary School 362 410 772 21 1 22 23 Nii Sowah Din Memorial '1' JHS School 0 0 0 4 10 14 24 Nii Sowah Din Memorial '2' Primary School 384 366 750 1 19 20 25 Nii Sowah Din Memorial '2' JHS School 120 140 260 5 9 14 26 Ogbojo Presby Primary School 143 276 419 1 8 9 27 Ogbojo Presby JHS School 322 352 674 4 15 19 28 Sraha AdMA Primary School 155 171 326 1 9 10 29 St. Francis Catholic Basic School 260 370 630 5 14 19

4.3.3 Employment and Industry

On the average, about 3 out of every 4 persons (74.1%) aged 15 years and older are economically active (of which 67.6% are employed and 6.5% are unemployed) while about one-quarter (25.9%) are economically not active in the municipality. The proportion of employed males (92.5%) is higher than that of the females (89.7%). The proportions of the employed population increase with increase in age from 17.2% for the 15-19 year age group to 89.0% for the 40-44 year age group.

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Females are more likely than males to be engaged in service and sales work (51.5%) whereas males are more likely than females to be engaged as craft and related trade workers (34.8%). These two leading occupational categories do not require highly skilled expertise and high educational training. The proportions of the occupations which require high skills and long years of training such as professionals, managers and technicians account for 23.3% of the labour force.

Based on industry, wholesale and retail, repair of motor vehicles and motorcycles, constitute the largest industry which employs about one-quarter (24.8%) of the workforce aged 15 years and older. Other major industries include manufacturing (13.3%), construction (12.8%) and accommodation and food service activities (7.5%) (Ghana Statistical Service, 2014).

4.3.4 Water Supply

A higher proportion of rural households (36.9%) than urban households (21.2%) use pipe-borne water while more urban households (16.3%) than rural households (8.3%) use tanker supply in the municipality. Sachet water is the main source of drinking water for more than half (53.6%) of the households in the municipal, followed by pipe-borne outside dwelling (15.4%) and tanker supply/vendor provided (13.4%) (Ghana Statistical Service, 2014).

The source of water supply in schools vary. All the schools have access to potable water supply, either through connection to GWCL mains (though it appears to be irregular), boreholes or water tanker services. However, about a third of the schools obtain water by direct supply from GWCL, another third obtain their supply from boreholes, and about a fifth from tanker services (Colan Consult, 2015a).

Majority of the students (about 71%) buy sachet water from vendors and also consider this source as the safest to drink, suggesting suspicion of the quality of water from the existing sources. However, about 90% of the students use their own cups for drinking while 10% of the students drink from shared cups, or drink directly from the tap using their hands or mouths, which could be a pathway for disease transmission (Colan Consult, 2015a).

4.3.5 Sanitation and Hygiene

About one-third (32.2%) of households in the municipality use WC and 16.4% use public toilets. Nearly one-quarter (23.5%) of households do not have toilet facilities. The most common method of disposal of solid waste is collection (45.5%) (Ghana Statistical Service, 2014).

The types of toilet facilities in the schools are mainly WC, KVIP and Biofil. A large majority of the schools (a little less than two thirds) have the ventilated improved (KVIP 44%, VIP 19%) pit latrine. About a third of them have water closet toilets. Only one school (Bethel Presby JHS) has no toilet facility. The pupils in the school use a nearby public toilet facility at a fee (Colan Consult, 2015a). Most of the existing urinals are available for use by boys and have rather limited capacity. Facilities for effluent disposal are woefully inadequate and require improvement. Table 4-2 below shows the types of urinal facilities in the beneficiary schools

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Table 4-2 Type of Urinals in Schools (Source: Colan Consult, 2015a)

Description With Urinals Without Urinals Type Wall Gutter Floor Drain / Soak Pit No. of Schools 3 18 4 4

4.3.6 Waste Management

The most common method of solid waste disposal is collection (45.8%). More than one-quarter (27.1%) of households burn their solid waste. It is also observed that 11.3 % of households dump their solid waste in containers while 10.0% of the households dump in open spaces. Dumping of solid waste indiscriminately is practiced by 4.0% of the households. The proportion of households dumping waste indiscriminately is higher in rural areas (5.2%) than in urban areas (3.2%) (Ghana Statistical Service, 2014).

Solid waste management is generally poor in the schools and therefore requires immediate attention for improvement. Although several schools have engaged the services of private waste management companies for collection and disposal of their waste, some operate refuse dumps and some burn their refuse (as shown in Figure 4-3).

Figure 4-4 Types of Waste Management in the school facilities (Colan Consult, 2015a)

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5.0 STAKEHOLDER CONSULTATIONS

Stakeholder participation during project planning, design and implementation is widely recognized as an integral part of environmental and social management for projects. It is a two-way flow of information and dialogue between project proponents and stakeholders, which is specifically aimed at developing ideas that can help shape project design, resolve conflicts at an early stage, assist in implementing solutions and monitor ongoing activities.

Key project stakeholders were identified for consultations and these included AdMA, the beneficiary institutions, local communities, and their representatives and local government institutions.

5.1 Objectives of Consultation

The main objective of the consultations with stakeholders is to discuss the proposed project’s environmental and social implications and to identify alternatives for consideration. Specifically, the consultations seek to achieve the following objectives:  To provide some information about the proposed project;  To provide opportunities for stakeholders to discuss their concerns and offer recommendations;  To gain insight on the role of each stakeholder in the implementation of the environmental and social safeguards as well as structures in place for the management of the proposed facilities;  To provide and discuss with stakeholders the alternatives considered to reduce anticipated impacts;  To identify and verify significance of environmental, social and health impacts; and  To inform the process of developing appropriate mitigation and management options.

5.2 Stakeholder Consultation Strategy and Plan

Stakeholder consultation is a process and would continue through the ESMP study stages through to its implementation. Table 5-1 summarizes the proposed approach for stakeholder engagement.

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Table 5-1: Stakeholder Engagement Programme

No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator Frequency 1. Preparation of  Ministry of Local Government and  Challenges with WASH implementation Throughout the  One on one Interviews SAL Consult in schools, ESMP/ Project design Rural Development/ Project ESMP study  Field visitation Limited Coordinating Unit,  Potential environmental and social issues  Sharing and review of relevant  Colan Consult, of concern from the proposed project’s period reports  GWCL implementation  Email and phone calls  AdMA (SHEP Coordinator/SHEP  Compliance with World Bank and EPA Committee), requirements for GAMA S&W Project  Head Teachers, student  Strategies for mitigating the potential representatives, School impacts and successful maintenance of Management Committee, non- the proposed facility during their teaching staff in schools operation  Public and occupational health and safety at construction sites  Scope of interventions of proposed works for institutional facilities construction and adequacy of sanitation facilities 2. Site preparation prior  School authorities  Information on schedule of preparation Two weeks prior  General stakeholder meeting Colan Consult/ and construction to construction  Students to construction for school authorities, AdMA Works  Community/ Assembly member  Awareness creation on the potential Consultant, and contractor  Colan Consult/ Contractor impacts and remedial measures to  Announcement at School Department/ students and community Assembly Head teacher/  Integration of the ESMP into planning for  Utilisation of WASH Notice School based construction (impacts and mitigation “Talk” boards for students/staff measures) and notice board at site Health  Grievance redress procedures including safety signs Coordinator  Capacity building for stakeholders for the  Community notifications. implementation of the ESMP 3. Start of construction  School authorities  Information on Schedule of construction Throughout the  General stakeholder meeting Colan Consult / works, activities and progress of  Students construction for school authorities, AdMA Works  Community/ Assembly member construction Consultant, and contractor  Colan Consult/ Contractor  Awareness creation on the potential period  Announcement at School Department/ impacts and remedial measures to Assembly Head teacher/ students and community  Utilisation of WASH Notice  Training School based

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No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator Frequency o ESMP Implementation (impacts and “Talk” boards for students/staff Health mitigation measures) and notice board at site o Code of Conduct including safety signs Coordinator  Grievance redress mechanism  Community notification. 4. End of construction /  School authorities  Information on Schedule of Decommissioning  General stakeholder meeting Colan Consult / decommissioning works, activities and Decommissioning of  Students phase for school authorities, AdMA Works  Community/ Assembly member progress of decommissioning Consultant, and contractor construction  Colan Consult/ Contractor  Awareness creation on the potential  Announcement at School Department/ equipment and impacts and remedial measures to Assembly Head teacher/ students and community  machinery Utilisation of WASH Notice School based  Training “Talk” boards for students/staff o ESMP Implementation (impacts and and notice board at site Health mitigation measures) including safety signs Coordinator o Code of Conduct  Community notification.  Grievance redress mechanism 5. Commissioning and  School Management Committee  Operation and Maintenance (O&M) Prior to operation  General stakeholder meeting Colan Consult/ requirements of the toilets handing over of (SMC) of the facility for school authorities, Municipal SHEP  Parents Teacher Association (PTA)  Roles and responsibilities in the O&M Consultant, and contractor Institutional  School based Health Coordinator  Training on the Facilities Management  Announcement at School Committee and sanitation facility (SBHC) Plan Assembly and Coordinator/  School Health Club (SHC)  Utilisation of WASH Notice Head teacher/ “Talk” boards for students/staff School based Health Coordinator 6. Operation and  School Management Committee/  Hygiene education During operation  General stakeholder meeting Colan Consult/  Operation and Maintenance (O&M) maintenance of Parents Teacher Association and maintenance  Training workshops Municipal SHEP  School based Health Coordinator requirements of the toilets facility  Teachers/staff  Roles and responsibilities in the O&M period Committee  School Health Club  Training on the Facilities Management and Coordinator / Plan  Students Municipal SHEP  Review of grievance Coordinator  Students  Interactive activity teaching and testing 3 times a week  Classroom activity Class Teacher knowledge

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No. Activity Identified Stakeholders Focus of Consultation/ Engagement Timelines/ Forms of communication Facilitator Frequency  Demonstration activity for building habits  Entire School  Teaching knowledge and motivating Fortnightly  Main school lesson during School health pupils for change of habits worship time club and SBHC.  Reinforcing/repeating key messages from 3 times a week  Morning Assembly School health Worship Time Sessions club and SBHC.  Reinforcing/repeating key messages from 3 times a week  WASH Notice “Talk” boards School health Worship Time Sessions club and SBHC.  All classes and all schools in  Activities focusing on testing knowledge Once a term  Competitions and SBHCs/ Municipal Metropolis dissemination to the entire school and demonstrative activities indirectly parents and communities SHEP Coordinator  Parents and Teachers  Support to activities/actions as well as Once a term  WASH Session during PTA  PTA reports on progress meeting for schools  Funding for the O&M of facilities

 School Management Committee  Support to activities/actions as well as Once a term  WASH Session during SMC SMC (SMC) reports on progress. Meeting  support to School Health Club activities as well as individual support as club patrons  Support to SBHC

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5.3 Stakeholders Consulted

Key stakeholders to the proposed Institutional Sanitation Facilities in the Adenta Municipality have been identified and sampled for consultation. The Consultation of the stakeholders was carried out from November 2016 to February 2017 to gather information, comments and concerns on the proposed project with respect to the potential environmental and social issues and impacts.

The approach adopted for the stakeholder consultations involved one-on-one interviews and focus group discussions. The stakeholders consulted during the ESMP study are listed below.

Project proponents:  Ministry of Local Government and Rural Development/ Project Coordinating Unit - Safeguards Specialist  Adentan Municipal Assembly - GAMA Project Coordinator

Engineering Consultant  Colan Consult - Resident Engineer (responsible for Safeguards); and - Clerk of Works

Contractors  Fekiop Construction Limited - Manager; and - Site Supervisor.  Macksams Limited - Manager

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- Sowa Din Memorial AdMA 2 Primary - Sowa Din Memorial AdMA 2 JHS

5.4 Outcome of Stakeholder Consultations carried out during ESMP Preparation

A summary of the outcome of the stakeholder consultations is provided in Table 5-2. Further evidence of stakeholder consultations with the various stakeholders/institutions have been provided as Annex 1.

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Table 5-2: Details of Stakeholder Consultations

Stakeholder Contact Person Role Contact Date Concerns raised / information Received number PROJECT PROPONENTS/CONSULTANT/CONTRACTOR

Ministry of Local George Awudi Safeguard Specialist 0506152780 Ongoing  Provided relevant information and documents on project implementation and Government and environmental and social concerns  Provided input on requirements for compliance with World Bank safeguards Rural  The ESMP must ensure it incorporates the provision of constant water supply to the Development/ sanitation facilities Project Coordinating Adenta Municipal Michael Akumfi- GAMA Project Coordinator 0573539380 Nov. – Dec.  Provided relevant information and documents on project implementation and Assembly Ameyaw (AdMA) 2016 environmental and social concerns including project description, screening reports, Facilities Management Plan, Baseline studies and other relevant reports of studies carried out.  Also served as liaison between the Environmental Consultant and the beneficiary institutions, as well as the Engineering Consultants. Engineering Atsu Tettey Works Manager 0504432177 Nov.- Dec.  Provided a description of the proposed project scope and schedule for construction Consultant Tettevia 2016  Provided information on environmental and safety measures to be put in place during (Colan Consult) Jeffery Clerk of Works 0244127337 construction works. Bernard Clerk of Works 0244712640 Contractors -Fekiop Francis Fenuku Contractor 0243148256 23/11/2016  Provided details of project and information on safety measures to be put in place at Construction Ltd Justice Amankwah Site Supervisor 0242608414 ‘’ project sites.

-Macksams Ltd Malik Mohammed Contractor 0208125250 15/12/2016 HEADS OF INSTITUTIONS/SHEP COORDINATORS

Amrahia AdMA John G. Acquah 0241749884 13/02/2017  There are no urinal facilities in the school at present. -Head Teacher – JHS Primary and JHS  Pump for existing borehole is non-functional, hence the school buys water for use.

School spends Gh₵60 on 500 litres of water.

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Stakeholder Contact Person Role Contact Date Concerns raised / information Received number Diana Dery Head Teacher – Primary & KG 0244485948  Bins are provided for segregation of waste, which is emptied weekly by AdMA.  School population has increased, which has increased utility bills. Currently, the school Mabel Acquah SHEP Coordinator 0244993701 owes electricity and water bills.  Funding is supplemented by collection of levies from parents, which is sometimes difficult. Vida E. Gblortsyo SHEP Coordinator 0206485162  Recommends the Municipal Assembly supports schools with payment of utility bills.

N.T. Narh SHEP Coordinator 0266336636 (See Plate 5-1) Christian Faith Esther B. Kubol Head Teacher (CFM 2 Primary) 0208304732 13/02/2017  The school has no connection to GWCL supply lines. It depends on a mechanized Mission (CFM) borehole for water supply. The operation of the borehole increases the cost of School Millicent Ofori Head Teacher (CFM 1 Primary) 0244638936 electricity, hence PTA assists in payment of electricity bills. The borehole has broken down recently.  Waste are collected into bins, which are emptied by AdMA. Fidelia Krakani Head Teacher (CFM JHS) 0277411216  Security is a challenge in the school. Portions of school wall is broken and school has no

security personnel. Members of public come to use school’s toilet facilities, especially outside school hours and weekends.  Based on current inflow of funds, it is envisaged that managing the new facilities will be a challenge.  School has challenges in raising funds to employ janitors for toilet facilities, hence pupils clean the toilets.

Nii Sowa Din Agartha M. Bansah SHEP Coordinator 0541261986 13/02/2017  Only two cubicles of existing toilet facilities is functional due to choked sewage lines.  Odor from existing toilet facilities affects school. Memorial AdMA  There is water connection from GWCL to toilet facilities, however the flow is 1 JHS Yaa Boahemaa SHEP Coordinator 0262693336 irregular. Ampewuah  Existing toilet facilities have no changing rooms.

 Existing toilets have burglar proof, which secures them from intruders (public).

 New dustbins provided to school by Municipal Assembly are sometimes used for storing water. Municipal Assembly empties bins in schools.  School does not have adequate hand washing facilities.

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Stakeholder Contact Person Role Contact Date Concerns raised / information Received number  Toiletries are provided by pupils.

Nii Sowa Din Rita Adjei School Based Health 027647340 13/02/2017  School is not walled which poses security challenges. Members of the public may Memorial AdMA Coordinator come to use the toilet facilities, especially when school is not in session. 2 Primary and JHS  The school lacks hand washing facilities.  Infrequent emptying of refuse bins causes over flow of rubbish. Adenta Eva Gagakuma 0516589013 23/11/2017  School has not encountered any problems with the Contractor. Deputy Head Community KG  Handles of newly installed WCs at a toilet being rehabilitated are faulty. Contractors

have been informed about the situation but are yet to take action. (NB: -SAL Consult

followed up with the Engineering Consultant who indicated they have already

noted the situation and the faulty WCs will be replaced). PARENT TEACHER ASSOCIATION/ SCHOOL MANAGEMENT COMMITTEE/ GES CIRCUIT SUPERVISOR

Ghana Education Gamadeku Edgar 0243645375 23/11/2016  Security is a challenge in many schools. Community members sometimes break doors Service Circuit Supervisor of toilets to use facilities when school is not in session.  Conveying materials to site by vehicles could potentially generate dust and noise.  Excavated materials were wrongly dumped at a site in one of the schools, however the contractor immediately collected the excavated materials when his attention was drawn to the situation. Amrahia AdMA Elder Asare Nyadu P.T.A Chairman (JHS) 0246355036 23/02/2017  They are happy with the projects as it will help improve health, sanitation and Primary and JHS hygiene in the schools. Ebenezer Vice Chairman (JHS) 0276103251  They expressed concerns on the halting on the projects and hoped that construction Fergusson works will resume soon.  The P.T.A will have to discuss and come into agreement as to how they will help - SMC Chairman (Primary & JHS) 0244632254 maintain the new facilities for the schools. Nii Sowa Din Ali Mohammed SMC Chairman 0244815677 23/02/2017  Sometimes levies agreed upon are not paid by some parents. Memorial AdMA 1 JHS Rev. Adjei PTA Chairman 0276692661 Mr Dankwa PTA Vice Chairman 0267441155

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Stakeholder Contact Person Role Contact Date Concerns raised / information Received number STUDENT LEADERSHIP/HEALTH CLUB EXECUTIVES

Christian Faith See Plate 5-2. - 13/02/2017  Health Club sensitizes other students on health, sanitation and hygiene issues, such as Mission Schools how to wash hands properly and how females can take care of themselves during menses. Prefects and Health Club  Students clean existing toilet facilities. Members  Female pupils have one changing room, with a sink. Changing room does not have shelves.  There were a few instances of noise from the construction site.  Lack of water flow to the existing toilet facilities makes it difficult to manage. Amrahia AdMA See Annex 1 for -Prefects - 13/02/2017  Existing facilities do not offer girls privacy to change themselves, especially during Primary & JHS picture menstruation. -Health Club Executives  Facilities are inspected regularly by head teacher.

 Health Club holds educational programmes on health, sanitation and hygiene. For

example on the need to and how to wash hands properly. Nii Sowa Din See Annex 1 for Health Club Executives - 13/02/2017  Most of existing toilet facilities are non-functional. Memorial AdMA picture  There are no changing rooms for girls, sometimes used menstrual pads are left lying 1 JHS about in the toilets due to lack of waste collection bins.  Students do not manage facilities properly due to irregular flow of water. Students have to go fetch water to flush the toilet after use.

 Health club educates other pupils on sanitation and hygiene issues.

Nii Sowa Din See Plate 5-3 for -Prefects - 13/02/2017  School lacks adequate urinal facilities. Memorial AdMA picture  Students sometimes do not flush the toilets after use due to lack of water. 2 Primary & JHS -Health Club Executives  Health Club holds educational programmes for students, example on how to wash hands properly and its importance. Oyarifa Presby – -Asante Ivy School Health Club facilitator - 23/02/2017  The existing toilet facility is not adequate for the current population of students KG, Primary 1&2  There is currently no dump site in the school. & J.H.S -and prefects  Water flow from the stand pipe is irregular.  There are currently no changing rooms for the girls.

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Stakeholder Contact Person Role Contact Date Concerns raised / information Received number  Funding provided for the maintenance of the existing toilet may be inadequate to maintain the new facility.  There is electricity connection at the J.H.S block but not at the primary block.  The health club will organize programmes that will educate students on personal hygiene.

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Plate 5-1: Consultation with head Teachers and SHEP Coordinators of Amrahia AdMA Primary and JHS

Plate 5-2: Consultation with Head Teachers, SHEP Coordinators, Prefects and Health Club Members of Christian Faith Mission Schools

Plate 5-3: Consultations with SHEP Coordinator, Prefects and Health Club Executives of Nii Sowa Din Memorial AdMA 2 Primary and JHS

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5.5 Key Environmental and Social Concerns from Stakeholder Consultations

The main environmental and social concerns raised during the stakeholder consultations are as follows: i. Security Consultation with the Ghana Education Service (GES) Circuit Supervisor revealed that security is a major challenge facing all schools in the municipality. The schools mostly do not have a fence/wall and security personnel. Members of the neighbouring communities therefore use the schools’ toilet facilities, especially outside school sessions. This is more prominent in communities that do not have public toilet facilities. Locks installed by school authorities at the toilet facilities to keep out the public are usually destroyed. Security needs to be improved at the schools in general, and the toilet facilities especially to ensure the sustainability of the facilities. ii. Noise and dust According to the GES Circuit Supervisor, the movement of trucks in schools may generate noise and dust. This had occurred in some schools. Measures must be put in place to address this. iii. Lack of awareness of the project among school pupils Majority of the pupils in the various schools had seen the construction work ongoing and were aware there was a new toilet facility project. However the pupils were not aware of the projects key components.

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6.0 DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS

Field inspections and observations, concerns arising from stakeholder consultations and project description and designs formed the basis for the identified potential environmental issues and impacts likely to be associated with the proposed construction of institutional sanitation facilities in AdMA.

6.1 Project Area of Influence

6.1.1 Geographical Area of Influence

The immediate geographical area of influence for each sanitation facility is the land area covered by the beneficiary school, as indicated in Table 2-1. The larger geographical area of influence covers the Adentan Municipal of the Greater Accra Region of Ghana.

6.1.2 Physical Environmental Media Influence

The physical environmental media to be potentially influenced by the activities of the proposed project are land (landscape), air quality, groundwater and any adjacent drain to any of the project sites. The landscape features include soil, flora and fauna at the proposed project site which will be impacted by the project activities. Any adjacent drain to any of the project sites will be the recipient of runoff water from the project site. Any percolation of fuels during construction works and leachates from poorly constructed or improperly sited septic tanks through the soil may impact on groundwater resources. The air quality may also be impacted by dust and gaseous emissions from construction activities.

6.1.3 Community Influence and Vulnerable Persons in the Institutions

The implementation of the proposed project could have an impact on the economic and socio- cultural conditions of the various project communities (as indicated in Table 2-1) and other neighbouring localities in AdMA.

Vulnerable Groups Vulnerable groups are those at risk of becoming disadvantaged and require special provisions in the project design. Vulnerable people include, but not limited to:  Physically challenged (disabled) pupils/teachers;  Pre-school children; and  Female pupils/teachers.

The project will not result in the displacement of any person. The construction sites are within and belong to the beneficiary institutions, and are not inhabited by any persons. The toilet facilities to be provided are disability friendly, with a special cubicle provided in each toilet for disabled persons and ramp provided to aid access to the toilet. Adequate segregation and protection have been provided between toilet facilities for boys and girls to keep girls from aggressive boys (or any other potential attackers). Special facilities have also been included in the designs for toddlers.

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6.1.4 Institutional Influence

The major institutions to be influenced or involved in the proposed project include:  Ministry of Local Government and Rural Development;  Ministry of Education;  Ghana Education Service;  Ministry of Health;  Ghana Health Services;  Environmental Protection Agency;  Adentan Municipal Assembly;  Colan Consult;  The various Contractors;  The various beneficiary schools; and  Ghana Water Company Limited.

6.2 Project Activities of Environmental and Social Concern

Activities of potential environmental and social impacts identified with the proposed project are outlined under four (4no.) main phases of the project activities; namely preparatory; construction; operations and maintenance; and decommissioning phases.

6.2.1 Preparatory Phase Activities

Preparatory phase activities include among others:  Assessment of existing sanitation facilities, selection of beneficiary schools, field studies and environmental screening;  Preparation of environmental and social screening reports;  Statutory permitting activities from EPA.

The preparatory phase activities had been completed prior to commencement of the preparation of the ESMP.

6.2.2 Construction Phase Activities

Construction activities include among others:  Demolition of existing defunct toilet facilities (where applicable);  Site clearing and excavation works;  Identification of storage area for construction material;  Transportation and handling of materials and equipment;  Rehabilitation and retrofitting of existing toilet facilities (WC and septic tank) (where applicable);  Rehabilitation and expansion of existing septic tanks (where applicable);  Construction of smart micro flush WC with biofil digester (where applicable;  Construction of WC and septic tank (where applicable);  Water connection from GWCL supply line (where applicable); and  Installation of water storage tanks and connection to toilet facilities.

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6.2.3 Operations and Maintenance Phase Activities

Operations and maintenance phase activities include:  Housekeeping;  Waste management (collection and disposal);  Maintenance and repair works; and  Materials management and storage (including disinfectants, cleaning tools, personal protective equipment, etc.).

6.2.4 Decommissioning Phase Activities

Decommissioning activities after construction works will involve the following:  Disposal of construction spoil and waste in general;  Restoration of landscape around construction site; and  Removal of construction equipment.

The sanitation facilities to be provided by the project will be utilized by the beneficiary schools as long as they are well maintained. Decommissioning during the operational phase is therefore unlikely.

6.3 Criteria of Impact Evaluation

6.3.1 Duration of the Impact

 A temporary impact can last days, weeks or months, but must be associated to the notion of reversibility.  A permanent impact is often irreversible. It is observed permanently or may last for a very long term.

6.3.2 Extent of the Impact

 The extent is regional if an impact on a component is felt over a vast territory or affects a large portion of its population.  The extent is local if the impact is felt on a limited portion of the zone of study or by a small group of its population.  The extent is site-specific if the impact is felt in a small and well defined space or by only some individuals.

6.3.3 Intensity of the Impact

 The intensity of an impact is qualified as strong when it is linked to very significant modifications of a component.  An impact is considered of average intensity when it generates perceptible disturbance in the use of a component or of its characteristics, but not in a way to reduce them completely and irreversible.

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 A weak intensity is associated with an impact generating only weak modifications to the component considered, without putting at risk some its utilization or its characteristics.

6.3.4 Impacts Severity

 Major Impact: An impact of major significance is one where an accepted limit or standard may be exceeded, or large magnitude impacts occur to highly valued/sensitive resource/receptors. Repercussions on the environment are very strong and cannot easily be reduced.  Moderate Impact: An impact of moderate significance is within accepted limits and standards. Moderate impacts may cover a broad range, from a threshold below which the impact is minor, up to a level that might be just short of breaching an established (legal) limit. Repercussions on the environment are substantial but can be reduced through specific mitigation measures.  Minor Impact: An impact of minor significance is one where an effect will be experienced, but the impact magnitude is sufficiently small and well within accepted standards, and/or the receptor is of low sensitivity/value. Repercussions on the environment are significant but subdued and may or may not require the application of mitigation measures.

6.4 Evaluation of Potential Positive Impacts

The potential positive impacts of the proposed construction of institutional sanitation facilities in AdMA are stated and evaluated in Table 6-1.

Table 6-1: Evaluation of potential positive impacts. No. Impact Key receptor(s) Evaluation Significance 1. Improved Students/staff/ The current sanitation infrastructure (toilets, urinals) in the Major beneficiary schools are inadequate and in a poor state. hygiene and visitors of Changing rooms for girls are not available. sanitation in beneficiary beneficiary schools The proposed project, through the construction and schools rehabilitation of toilet facilities, including urinals and hand washing facilities will improve hygiene and sanitation infrastructure as well as access in the beneficiary schools. The provision of changing rooms for girls will improve privacy for girls especially during their menstrual period and menstrual hygiene. The proposed project will therefore lead to a major improvement in hygiene and sanitation in the beneficiary schools in AdMA. 2. Improved Disabled people The existing sanitation facilities in the beneficiary schools Major are not disability-friendly, which makes access to the access to in the disabled a challenge. The sanitation facilities to be provided hygiene and beneficiary by the project will have toilets specially made and reserved sanitation schools for disabled people. Ramps will also be made to ease access facilities by to the toilet facilities by disabled people on wheel chairs. disabled people The impact will be major. 3. Improved waste Students/staff/ Waste management is a challenge in many schools due to Major inadequate bins and lack of proper storage areas of bins management in visitors of prior to collection. Some schools resort to dumping of beneficiary beneficiary refuse in open areas and burning as a means of waste schools schools management due to inadequate or lack waste collection

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No. Impact Key receptor(s) Evaluation Significance bins and storage areas. The proposed project will improve waste collection and disposal through the provision of bins for use in classrooms and outside classrooms, and construction of waste storage and collection sheds. The impact on waste management in the beneficiary institutions is major. 4. Improved water Beneficiary Water supply for use and cleaning of existing sanitation Major facilities in the beneficiary institutions is unavailable or supply in institutions where available, is unreliable. This leads to poor hygiene beneficiary and cleaning in the toilets and urinals which poses health institutions risks to the users. The proposed project will improve water supply for use in the sanitation facilities through connection of water from GWCL pipelines, repair of existing pipelines, mechanisation of existing boreholes and provision of overhead and ground level water storage tanks. The impact will be major. 5. Employment Community The proposed project will create employment opportunities Major for skilled and unskilled labour during the construction and generation members, operational phases. These include direct employment people from opportunities such as masons, carpenters and labours to be other engaged by the contractor during construction works, and communities indirect employment opportunities such as food vendors, petty traders and suppliers of raw materials for construction. During the operational phase, job opportunities will be created for maintenance workers and suppliers of disinfectants, waste management companies, etc. The project will therefore have a major positive impact on the socioeconomic conditions of the various project communities, and AdMA as a whole through the creation of permanent (e.g. cleaners and security persons) and temporary direct jobs as well as indirect jobs. 6. Improvement in Neighbouring The creation of direct and indirect job opportunities during Major the construction and operational phases of the project will local and communities, boost the local and national economy. Improved hygiene national AdMA and and access to sanitation facilities, as well as improved waste economy national management in the beneficiary institutions will reduce economy sanitation and hygiene related diseases and associated cost. The impact will be major and last throughout the duration of the project.

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6.5 Evaluation of Potential Adverse Impacts Associated with the Proposed Project

The adverse environmental and social issues which could potentially arise from the proposed project activities are stated and evaluated in Table 6-2.

Table 6-2: Evaluation of potential adverse impacts No. Impact Key Evaluation Significance receptor(s) Preparatory Phase 1. Siting of toilet Beneficiary It is important that siting of the proposed sanitation facilities is Major compatible with activities in its close proximity. For instance, facility schools where the proposed construction sites are close to canteens, this may influence the hygienic conditions of food sold at the canteen. Construction Phase 1. Loss of Flora, fauna, The construction of the various project facilities may require Minor limited vegetation clearance (where necessary) at some selected vegetation and soil sites. The vegetation to be lost are mainly grasses or shrubs. impacts on Individual stands of trees occur at very few schools, example fauna Adjiriganor AdMA Primary School. A tree will be removed only where it is unavoidable after review by an Environmental Specialist. The vegetation clearance will therefore not result in the loss of any species of conservation value. Insects which may inhabit these vegetation may be disturbed and will escape to adjoining vegetation. Impact on vegetation is site-specific. The impact on fauna (insects) is negligible as the project sites are already disturbed due to ongoing human activities. 2. Soil impacts and Soil, drains Excavation works, vegetation clearance, levelling and other Moderate ground works will expose and loosen the soil making it sediment susceptible to erosion. Transported soil from erosion may end up transport in nearby drains. Improper handling and storage of fuel at the construction site could lead to oil/fuel spills which could contaminate the soil.

The impact is temporary lasting during the construction works. But can be managed through good construction practices. 3. Air quality Ambient air Loosed and exposed soils from land preparation, dumping of Moderate sand/laterite for construction works and movement of vehicles deterioration environment, delivering construction materials to the sites may release dust in construction the immediate vicinity of the project. This may temporarily affect workers, air quality in the schools. Exhaust fumes from vehicles and pupils and concrete mixing machines may also impact on air quality. teachers The impact is local and temporary, lasting during the land preparation and construction phase. 4. Vibration and Air, fauna, The operation of concrete mixing machines, movement of Major delivery trucks, tooting of horns of delivery trucks and carpentry noise nuisance workers, works will generate noise. This will create a nuisance for the pupils and beneficiary institutions, especially when school is in session. The teachers, demolition of old sanitation facilities may also lead to minor vibrations. The impact is temporary and of local extent. 5. Visual intrusion Landscape, Construction of new sanitation facilities will result in alteration in Moderate the landscape character and features. Poor housekeeping pupils and practices at the site may also reduce the aesthetic value of the teachers area. The presence of the workers at site and their activities may

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No. Impact Key Evaluation Significance receptor(s) attract the attention of the pupils. This impact will be local and temporary. 6. Destruction of Public, The movement of delivery trucks through the compound of Moderate beneficiary schools to the construction sites may result in property and property destruction of pavements and concreted areas. The dumping of obstruction of construction materials and waste in pathways may also obstruct walkways movement of people. Excavations for laying of pipelines for water connection may also obstruct movement where it crosses walkways or destroy pavements and concreted areas along the route. The affected pavements or concreted areas may belong to individuals where the water connection point is outside the school’s compound. The impact, though temporary and lasting during the construction phase, will create inconvenience for the pupils/teachers and may result in public complaints. 7. Generation and Soil, water Vegetative material, excavated soil and construction spoils will Major form the bulk of construction waste generated at the project disposal of solid bodies, sites. Construction spoils will mainly consist of demolished waste school/clinic structures, used nails, wood chippings, plastics and pieces of iron premises rods, etc. Construction workers may also generate human and domestic wastes such as used polythene bags, food wastes, used water sachets and bottles, etc. The impact is of local extent and temporary, lasting during the construction phase. 8. Occupational Workers Occupational health and safety issues associated with the Major proposed project construction include: health & safety  Exposure of workers to excessive noise, vibrations and dust;  Accidents in the use and handling of equipment and machinery;  Injury to the body during the use and handling of equipment and machinery; and  Illness caused by exposure to wastes and odour. The extent of impact could be temporary or permanent. 9. Public safety & Public, The transportation of construction materials to site and the Major movement of equipment to and from the project site may pose Traffic issues school safety risk to school children especially during break periods community when school children are playing. The movement of delivery trucks to the construction sites may also potentially disrupt traffic especially at junctions leading to the schools.

Unsecured construction sites and excavations may pose safety risks to school children in particular who may go playing at the construction sites. The non-removal/abandoning of construction equipment from sites after completion of construction works may pose safety risks to pupils/teachers/public. The impact could be temporary or permanent and could have major safety consequences. 10. Sanitation and Land, water Key potential sanitation and public health issues that may arise Major from the proposed project include: public health bodies,  unsightly conditions of poorly managed construction site and workers, indiscriminate disposal of waste; public  indiscriminate disposal of human waste could also lead to spread of diseases; and  open trenches and containers could collect water and breed mosquitoes.

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No. Impact Key Evaluation Significance receptor(s)

The duration of the impact is temporary. 11. Presence of Workers, Construction activities usually bring workers and attract traders Minor to project areas. The workers may not conform to the norms and workers and public rules of the beneficiary schools. The pupils may be exposed to impacts on indecent behaviour of the workers such as smoking. pupils behaviour The local community may provide unskilled labour and artisans for the construction activities. There will be no work camps at the beneficiary schools. The maximum number of workers expected at a project site at a particular time is 10.

Any impacts will therefore be minimal and temporary, lasting during the construction period. Operational Phase 1. Nuisance from Public, pupils Odour may emanate from the toilets and urinals if they are not Moderate properly and frequently cleaned. Dislodging of septic tanks when odour and teachers full will also generate odour which will be a nuisance to nearby residents and members of the beneficiary school. Odour may also emanate from the waste storage and collection sheds if the bins are not regularly emptied. The odour may be intense within the vicinity of the facilities. 2. Ground water Ground Poorly constructed septic tanks may result in leakages which Minor could potentially contaminate ground water, especially if there contamination water, public are areas where the water table is high. This could have serious health implications for people who depend on ground water as the leakage may occur for long periods without being detected. This impact can be prevented/minimized through proper designing and construction.

No areas have been identified through the field visits and also by the Engineering Consultant to have high water table. The probability of the impact is therefore minimal. 3. Waste Land, public, The main solid waste to be generated on a daily basis at the Major toilet facilities are faecal matter, used tissue paper, toilet roll and generation school sanitary pads. These have to be regularly and properly disposed or could lead to odour, attract flies and have health implications. Bins have to be regularly emptied to prevent overflows which will be a nuisance and have health implications. Septic tanks may also overflow if they are not emptied when full. Waste generation will be permanent, lasting throughout the life span of the project. 4. Sanitation Public, Rodents, flies, cockroaches and other insects may transmit Major diseases to humans from contact with exposed faecal matter. issues and school The impact could occur through the life span of the project. public health impacts

Decommissioning Phase 1. Occupational/ Workers, The relocation of all construction facilities and remaining Moderate public safety pupils, materials including concrete mixer, trucks, water tanks to new and traffic teachers, sites or contractor’s office could result in accident and injury to workers. The removal and transport of such equipment and impacts public

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No. Impact Key Evaluation Significance receptor(s) materials could also pose traffic risks and public safety concerns within the schools and along the routes. The duration of the impact is temporary and could be local or of regional extent. 2. Waste Workers, The dismantling and removal of equipment and materials at the Moderate site, as well as landscape restoration works could generate waste management pupils, such as scraps metal, wood, concrete debris, vegetative material, teachers, and garbage (pieces of plastic bags, food wrappers, etc.). public The duration of the impact is temporary, the extent local and the severity minor.

6.6 Evaluation of Risks to Sustainability of Project

The potential risks to the sustainability of the proposed project, as identified by the stakeholder consultations, review of project documents and field inspections, are evaluated in Table 6-3.

Table 6-3: Evaluation of risks to the Sustainability of the Project No. Risk Key receptor(s) Evaluation Significance 1. Flooding Groundwater, Heavy rains may result in flooding of areas around the toilet Major facilities which may end up flooding the toilets if adequate beneficiary preventive measures are not incorporated into the design. institution Flooding at toilet facilities may also result from rain water getting into toilets which do not have proper windows and adequate drains around the facility. Flood waters may carry feacal matter which may end up contaminating surface and ground water bodies and the soil. 2. Security issues Beneficiary Poor security in the institutions could lead to community Major institution members entering the institutions’ compounds to use the toilet facilities or break into the toilets to use them. This could lead to damage to equipment parts such as door handles or damage to the water closet. Security is currently a challenge in many schools and the risk is high. 3. Unavailability of Students/staff/ The success of the proposed facilities hinges heavily on the Major water regular availability of water at the toilets and beneficiary visitors institutions. Damage to water supply lines and unavailability of water/irregular flow of water for flushing and cleaning may pose serious health risks. Water supply to the beneficiary institutions is currently unavailable or where available, is unreliable. The health risk is high. 4. Poor Sanitation The installation of less durable equipment such as water Major maintenance closets, hand wash basins and their fittings may lead to facilities, culture frequent breakdowns or early damage of the equipment. beneficiary Improper use of the sanitation facilities and poor institutions maintenance culture by the beneficiary institutions will also result in frequent damage to parts of the facilities, which may result in the facilities not functioning properly. This may also result in high cost of repairs. Maintenance of the existing toilet facilities is currently a challenge in many schools. 5. Inadequate Sanitation Funds are required for facility cleaning, provision of Major supplies, desludging services, maintenance and repairs and funds facilities,

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No. Risk Key receptor(s) Evaluation Significance beneficiary other related activities. The GES-SHEP Facilities Management Guide indicates the Capitation Grant as the institutions main source of funds for implementing the school’s facilities management plan (FMP). This allocation is however inadequate and must be supplemented to meet the maintenance needs of the proposed facilities. Payment of water and electricity bills in most schools is a challenge. Some schools have accumulated debts which must be paid to avoid any potential disconnection of electricity and water to the schools in future. 6. Lack of Beneficiary In order to obtain the full support of the beneficiary Minor institutions, it is important to ensure they are fully aware of awareness of institutions the scope and schedule of the facilities to be provided for the project each beneficiary institution. information Consultations indicate that the level of awareness of the project is mainly limited to the head teachers and SHEP Coordinators, other staff and students have minimum knowledge and this may affect the extent to which they take ownership of the project.

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7.0 ENVIRONMENTAL AND SOCIAL MITIGATION AND MANAGEMENT PLAN

7.1 Mitigation/Action Plan

Mitigation and management measures for the significant adverse impacts (rated as moderate or major) identified from the analysis and evaluation of the potential impacts from the proposed project activities are provided in Table 7-1.

Table 7-1: Mitigation measures/actions for potential significant adverse impacts

No. Potential Environmental Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per and Social Impacts project site (Gh₵)

PREPARATORY PHASE 1. Siting of Toilet Facility  Siting of toilet facilities  For all schools, Engineering Consultant to extensively consult school authorities on the Engineering Already captured in siting of toilet facilities in the school. The selection of sites should be agreed upon with Consultant Bill of Quantities the school authorities. (BoQ)  The selection of sites should take into consideration compatibility with adjacent school facilities. The adjacent school facilities should not be at risk from the operation of the proposed toilets.

CONSTRUCTION PHASE 1. Soil impacts and  Site clearing and excavation works  Vegetation (grasses) should be cleared only when contractor is fully mobilised for Contractor/ Already captured in sediment transport  Water connection from GWCL construction. Engineering Bill of Quantities supply line.  Vegetation clearance (where necessary) and excavations should be limited to the Consultant (BoQ) demarcated construction site.  Backfill with excavated soil material where appropriate.  Re-vegetate areas around construction sites to restore the landscape.  Ensure that heaped sand delivered for construction works is covered with tarpaulin to prevent wind and water transport of soil particles. 2. Air quality deterioration  Site clearing and excavation works;  Deliver construction equipment and materials to the construction sites outside school Contractor/ Already captured in  Transportation of materials and sessions, such as in the evenings or on weekends. Engineering BoQ equipment;  Speed limit for all vehicles and construction equipment should be less than 30km/h Consultant

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No. Potential Environmental Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per and Social Impacts project site (Gh₵)  Construction of facilities within the school environs and less than 50km/h within communities. Provide speed  Disposal of construction spoil and limit signs to guide drivers/operators. waste in general.  Dampen untarred routes of vehicles/trucks to the construction sites.  Haulage trucks carrying sand should be covered with tarpaulin.  Hydraulic concrete mixing machines should be used as much as possible and regularly service all construction equipment and machinery. 3. Vibration and noise  Demolition of existing facilities  Demolition of old structures should be done outside school sessions, such as in the Contractor/ Already captured in nuisance (where applicable); evenings or during weekends. Engineering BoQ  Site clearing and excavation works;  Carpentry works, and other noise generating activities should as much as possible be Consultant  Transportation of materials and carried outside school sessions. equipment;  Hydraulic concrete mixing machines should be used as much as possible and regularly  Construction of facilities service all construction equipment and machinery. 4. Visual intrusion  All construction phase activities  The construction sites should be hoarded off from public view. Contractor/ Already captured in  Ensure good housekeeping at the construction site. Engineering BoQ  Ensure an acceptable post-construction site as per provisions in the contract. Consultant  Remove all construction equipment from the site after completion of work. 5. Destruction of property  Demolition of existing sanitation  Ensure construction equipment are not parked haphazardly to obstruct walkways. Contractor/ Already captured in and obstruction of facilities (where applicable);  As much as possible, do not dump construction materials in walkways. Engineering BoQ walkways  Site clearing and excavation works;  Provide safe alternative routes for pedestrians where walkways will be obstructed. Consultant  Transportation of materials and  Consult affected property owners/users and seek their consent prior to construction equipment; works.  Excavation works;  Realign all affected utility service lines.  Disposal of construction spoil and  Reinstate any damaged property such as pavements, etc. waste in general. 6. Generation and disposal  All construction activities  Apply the principles of Reduce, Reuse and Recover for waste management. For Contractor/ Already captured in of solid waste example: Engineering BoQ - Purchase the right quality and quantity of materials; Consultant

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No. Potential Environmental Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per and Social Impacts project site (Gh₵) - Ensure judicious use of construction materials such as pipes, laterites, sand, etc.; - Reuse excavated soil material for backfilling and levelling if appropriate.  Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials.  Dispose all construction and domestic waste at AdMA approved dump sites. 7. Occupational health and  All construction activities  Engage experienced artisans for construction works. Contractor Already captured in safety (OHS) issues  All workers should be given proper induction/orientation on safety. BoQ  The contractors should have a Health & Safety Policy to guide the construction activities.  Regularly service all equipment and machinery.  Ensure first aid kits on site and a trained person to administer first aid.  Provide and enforce the use of appropriate personal protective equipment (PPE) such as safety boots, reflective jackets, hard hats, hand gloves, earplugs, nose masks, etc. for the labour force.  Comply with all site rules and regulations. Engineering  Apply sanctions where safety procedures are not adhered to. Consultant  Site meetings should create awareness on OHS. 8. Public safety and traffic  Construction activities  Hoard off the construction sites to prevent access by unauthorised persons. Contractor/ Already captured in issues  Transport of equipment and  Use caution tapes and warning signs at the construction sites around trenches and Engineering BoQ materials to and from site excavations. Consultant  Deliver construction equipment and materials to the construction sites outside school sessions such as in the evening or weekends.  Speed limit for all vehicles and construction equipment should be less than 30km/h within the school environs and less than 50km/h within communities.  Do not park at unauthorised places to reduce the risk of accidents.  Erect temporary road signs at junctions to the beneficiary schools during the delivery of construction equipment and materials.

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No. Potential Environmental Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per and Social Impacts project site (Gh₵)  Ensure delivery trucks hired/contracted are in good condition to prevent breakdowns on roads.  Remove all construction equipment from the site after completion of work. 9. Sanitation issues and  All construction phase activities  Provide bins on site for temporary storage of domestic waste such as lubricant Contractor/ Already captured in public health impacts containers, drinking water sachets and carrier bags/packaging materials. Engineering BoQ  Dispose all construction and domestic waste at AdMA approved dump sites. Consultant  Ensure all trenches or excavations made during the construction works do not collect stagnant water which could breed mosquitoes.  Provide separate temporary toilets (mobile toilets) for use by construction workers. OPERATIONS PHASE

1. Nuisance from odour  Operation of sanitation facilities  Comply with provisions in the Facilities Management Plan (FMP). School 4,000 (per school  Ensure good housekeeping at toilet facilities. Authorities / per year)  Clean toilet facilities regularly with disinfectants. SHEP  Liaise with AdMA to contract a waste management company to regularly collect and Coordinator dispose waste at AdMA approved dump site.  Dislodge septic tanks outside school sessions, such as on weekends. 2. Waste generation and  Use of sanitation facilities  Regularly empty waste bins at the toilets when full. School 4,000 (per school disposal  Waste management  Sensitize pupils/staff on effective use of bins to avoid indiscriminate disposal of waste. Authorities / per year)  Maintenance and repair works.  Damaged waste bins should be replaced as appropriate. SHEP  Liaise with AdMA to contract a waste management company to regularly collect and Coordinator dispose waste at AdMA approved dump site.  Inspect septic tanks periodically and dislodge when full. 3. Sanitation issues and  Use of sanitation facilities  Ensure pupils/staff wash their hands under running water and soap after use of toilet SHEP 1,000 (per school health impacts  Waste management (collection and facilities. Coordinator/ per year) disposal)  Ensure good housekeeping at toilet facilities. School  Maintenance and repair works; and  Clean toilet facilities regularly with disinfectants. Authorities  Materials management and storage  Ensure bins are properly covered at all times.

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No. Potential Environmental Project Activities Proposed Mitigation Measures/Actions Responsibility Cost Estimates per and Social Impacts project site (Gh₵) (including disinfectants, cleaning  Provide appropriate PPE for cleaning of sanitation facilities and emptying of bins. tools, personal protective  Create awareness on hygiene and sanitation issues, including proper use of sanitation equipment, etc.). facilities and proper handling and disposal of waste.  Comply with provisions in the FMP.

DECOMMISSIONING PHASE 1. Occupational/public All decommissioning activities The contractor will be required to ensure that: Contractor/ No additional cost safety and traffic  personal protective gear are provided to workers involved with decommissioning of Engineering required aside BoQ facilities. impacts Consultant  toilet facilities are available throughout the decommissioning period.  workers still have access to public toilet facilities in the communities or can be conveyed to such facilities where needed, if mobile toilet facilities have been relocated.  final movement of vehicles and equipment comply with approved speed limits within the communities.  all community complaints are resolved before handing over sanitation project. 2. Waste management All decommissioning activities  Ensure that any remaining waste streams created during construction activities and Contractor/ No additional cost waste generated during decommissioning activities are collected from the project sites Engineering required aside BoQ properly disposed before handing over the project. Consultant  Inspect the site to ensure that the contractor has properly cleaned up all construction sites before final payment is made to the contractor. Sub-Total: 9,000 (per school per year) Grand Total: 243,000 per year for AdMA

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7.2 Mitigation/Action Plan for Identified Risks to the Sustainability of the Project

Table 7-2: Mitigation /Action Plan for Identified Risks to the Sustainability of the Project

No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per project site (Gh₵) 1. Flooding  As a precautionary measure against flooding, raise the foundation of all  Construction Contractor/ Engineering -Already captured in toilet facilities to about 1 meter high. Consultant BoQ / If not revise  Provide adequate drainage around toilet facilities.  Construction BoQ accordingly  Provide rain cover over all windows and doors of the toilet facilities.  Construction  Beneficiary schools should ensure all broken louvre blades/or windows are  Operation -500.00 per school replaced. per year 2. Security issues  Provide burglar proof at the doors and windows of toilet facilities.  Construction Contractor/ Engineering -Already captured in Consultant/ Municipal BoQ/ If not revise Assembly/ Authorities of BoQ accordingly  Connect electricity to all toilet facilities and provide adequate lighting in the  Construction Beneficiary Institution -Already captured in toilets to ensure safe use. BoQ  Maintain adequate security in the schools and at the sanitation facilities  Operation -2,400.00 per especially. Eg: through hiring a watchman. institution per year

 MA should consider fencing of schools in future projects to improve - security.  Sensitize wider communities not to disturb school sanitation facilities  Operation - 3. Unavailability of  Confirm the source and reliability of the water supply prior to the  Construction Contractor/ Engineering -Already captured in water commencement of construction. Consultant BoQ/ If not revise  Ensure that storage tanks are installed for all the facilities to provide  Construction BoQ accordingly continuous water supply even when GWCL lines are temporarily out of

order.  Ensure connection of water and installation of water storage tanks is  Construction - completed and there is regular flow of water at the toilet facilities before commissioning/handing over of the facilities for use. 4. Poor  The Engineering Consultant to include the relevant recommendations in the  Construction Contractor/ Engineering -Already captured in

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No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per project site (Gh₵) maintenance ESMP in the Facilities Management Plan (FMP). Consultant/SHEP BoQ / If not revise culture  For clusters of schools, where various units are to share the same toilet  Construction Coordinators/Heads of BoQ accordingly facility, the SHEP Coordinators of the individual schools should coordinate Institutions -Refer to FMP to ensure that roles and responsibilities are clearly assigned for the cleaning Budget and maintenance of the facilities. This should be done prior to commissioning of the facilities.  The assigned roles and responsibilities for the maintenance and  Construction management of the facilities should be incorporated into the FMP by the Engineering Consultant.  Comply with provisions in the FMP such as: o Replace damaged equipment/materials with durable ones during  Operational maintenance and repair works. o Always replace dead light bulbs at the toilet facilities to ensure  Operational adequate lighting for safe use. o The beneficiary schools should hire cleaners for the sanitation facilities.  Operational o Develop and implement a maintenance regime for the facilities.  Operational o Report major breakdown of facilities to the Municipal GES Director.  Operational o Educate and create awareness on proper use of facilities.  Operational o Ensure all staff are trained in the effective use and management of the  Operational facilities, in collaboration with the Environmental Health and Sanitation Department. 5. Inadequate  School authorities and PTA to incorporate discussions on funding for water  Operational MLGRD-PCU/ Municipal - funds supply, electricity bills and maintenance of the facilities at PTA Meetings Assembly/ Consultant/ and SMC meetings. Authorities of Beneficiary -Refer to Capacity  Capacity building of School authorities /PTA for raising, mobilization and  Operational Institution Building Budget stewardship of fund. -  MA level stakeholder engagements to discuss innovations in funding for  Operational O&M such as levies from school vendors (food, stationary, etc.) as well as -

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No. Risk Proposed Mitigation Measures/Actions Implementation Phase Responsibility Cost Estimates per project site (Gh₵) mainstreaming the O&M costs into PTA dues.  The project should ensure that all outstanding electricity and water debts of  Operational beneficiary institutions are paid and electricity and water connection -

restored to disconnected institutions.  The beneficiary institutions should ensure regular payment of electricity  Operational and water bills to ensure continuous supply of water and electricity to the facility. 6. Lack of  Stakeholders should be invited to attend monthly progress meetings to be  Operational Consultant - awareness of the constantly informed. project  Before the project resumes, information of the proposed project including  Operational information its benefits should be explained to teachers, students and the PTA. Sub-Total 2,900 (per institution per year) TOTAL COST 78,300 (per year for AdMA)

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7.3 Environmental And Social Monitoring Plan and Reporting

7.3.1 Environmental and Social Monitoring Plan

The environmental and social monitoring plan proposed for the Institutional Sanitation Project in AdMA is presented in Table 7-3.

Table 7-3: Environmental and Social Monitoring Plan

No. Environmental/ Social Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Component (Implementation/ (GH) Supervision) PREPARATORY PHASE 1. Siting of toilet facility -Evidence of consultation with authorities of -Beneficiary institutions -Prior to -Contractor/ Engineering No additional cost beneficiary institution on siting of facilities. construction Consultant required aside BoQ -Complaints on siting of facilities - Daily CONSTRUCTION PHASE 1. Soil impacts and -Observable change in turbidity of water in drains -Construction site Daily Contractor/ Engineering No additional cost sediment transport -Observable oil sheen in drains -Nearby drains Consultant required aside BoQ -Observation of rills/gullies 2. Air quality/ Noise - Observation of air borne particulates (dust) and -Construction site Daily Contractor/ Engineering No additional cost exhaust fumes -Immediate environs Consultant required aside BoQ -Records of dust level measurements (dust concentration should be below 150µg/m3) -Records of dampening of construction sites and routes for vehicles/trucks 3. Vibration and noise -Complaints on noise nuisance Construction site Daily Contractor/ Engineering No additional cost nuisance -Immediate environs Consultant required aside BoQ 4. Visual Intrusion -Hoarding in place Construction site Daily Contractor /Engineering No additional cost -Condition of areas around construction site -Immediate environs consultant required aside BoQ 5. Destruction of property -Evidence of consultations with affected property -Construction site Daily Contractor /Engineering No additional cost

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No. Environmental/ Social Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Component (Implementation/ (GH) Supervision) and obstruction of owners -immediate environs consultant6 required aside BoQ walkways -Record of affected service line/property and action taken -Complains on affected property and obstruction of walkways Reinstatement of damaged property and landscape 6. Waste Management -Availability and use of bins Construction site Monthly Contractor/ Engineering No additional cost -Records on frequency and location of waste disposal Consultant required aside BoQ site of domestic and construction waste 7. Occupational Health & -Workers’ awareness of Contractor’s health and safety Construction site Daily Contractor/ Engineering No additional cost Safety policy Consultant required aside BoQ -Availability and proper use of PPEs -Availability and proper use of warning signs -Availability of first aid kit -Adherence to health and safety procedures -Records on frequency, type and source of illness/accident/injury -Records on non-compliances -Absence of unauthorized persons at active construction sites 8. Public safety and traffic Availability and proper use of warning signs Construction Site Daily Contractor/Engineering No additional cost issues -Hoarding of site consultant required aside BoQ -Use of caution tape around trenches/ excavations -Records on frequency, type and source of illness/accident/injury -Absence of unauthorized persons at active construction sites 9. Sanitation issues, health -Availability and use of bins Construction site Daily Contractor/ Engineering No additional cost

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No. Environmental/ Social Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Component (Implementation/ (GH) Supervision) and safety impacts -Records on frequency and location of waste disposal Consultant required aside BoQ site of domestic and construction waste -Mobile toilet facilities in place -Presence of stagnant water in trenches 10. Public Complaints/ -Type and nature of complaints and concerns; Project community Weekly Grievance Redress 500.00 Grievances Redress -Complaint records (Record of grievance and number Committee resolved/unresolved) -Management and Stakeholder Meetings OPERATIONAL PHASE 1. Nuisance from odour  Smell of pungent odour Beneficiary school Daily School Authorities/SHEP 1500.00 -Immediate environs Coordinator 2. Waste Management -Waste disposal records Beneficiary Institution -Daily SHEP Coordinator/ School 800.00 -Availability of bins Heads -Litter around waste bin -Records of inspection and dislodging of septic tanks 3. Sanitation, hygiene, -Cleaning roster -Toilet facility -Daily SHEP Coordinator/ School 500.00 health and safety -Clean environment -Waste storage and -Week Heads -Smell of pungent odour collection sheds -Availability of disinfectants -Availability of cleaning PPEs and tools/materials -Availability of functional hand wash facility -Payment of utility bills -Records on accidents/injury 4. Complaints/ Grievances -Type and nature of complaints and concerns; Beneficiary institution -Weekly Grievance Redress 500.00 -Complaint records (Record of grievance and number Committee resolved/unresolved)

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No. Environmental/ Social Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Component (Implementation/ (GH) Supervision) Sustainability of the institutional facilities 1. Flooding - Extent of flooding during rains Toilet facility During rains School Authorities / PTA/ 800.00 - Drains clear of silt Municipal Assembly - Record of state of Rain covers Monthly - Record of state of louvre blades 2. Security issues - Security measures (locks, burglar proof) functional Toilet facility Daily School Authorities/ PTA/ 1500.00 - Electricity availability and functioning light bulbs at Municipal Assembly toilet facilities - Watchman hired 3. Unavailability of water - Confirmation of availability of water supply from Toilet facility Prior to School Authorities/ PTA/ 1000.00 GWCL commissioning of Municipal Assembly - Storage tanks installed and all connections and project/ plumbing functional Weekly - Leaks from plumbing 4. Funding - Programme for PTA, SMCs, MMAs for fund raising Beneficiary institution Monthly MLGRD-PCU/ Municipal 1500.00 for payment of water supply and electricity bills, and Assembly/ Consultant/ School Authorities /PTA maintenance of the facilities - Receipts of payment of bills - Audited accounts 5. Poor maintenance - Record of training and awareness creation on -Beneficiary institution Monthly School Authorities / SHEP 1200.00 culture Facilities Management Plan Coordinators/ PTA/ Municipal Assembly - Record of compliance with Facilities Management Plan - Records on major breakdowns including leakages - Availability of school hygiene clubs 6. Lack of awareness of - Monthly progress carried out -Beneficiary institution Monthly SMC/ PTA/ Municipal SHEP 700.00 the project information - Information provided to teachers, students and the Committee

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No. Environmental/ Social Monitoring Parameters Monitoring Site Frequency Responsibility Cost Estimate/ Year Component (Implementation/ (GH) Supervision) PTA. DECOMMISSIONING 1. Occupational/public - Availability and proper use of PPEs -Beneficiary institution -Daily Contractor/ Colan Consult/ No additional cost safety and traffic - Adherence to health and safety procedures AdMA required aside BoQ - Records on frequency, type and source of illness/accident/injury 2. Waste disposal - Availability and use of bins -Beneficiary institution Daily Contractor/ Colan Consult/ No additional cost - Records on frequency and location of waste disposal AdMA required aside BoQ site of domestic and construction waste TOTAL: 10,500.00

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7.3.2 Environmental and Social Monitoring Reporting Environmental monitoring is an essential component to ensure the successful implementation of the ESMP. A report on the monitoring programme will provide the contractor and AdMA with relevant data and information to better understand the extent of implementation of the ESMP. All monthly and progress reports should capture health, safety and environment issues arising from the implementation of the ESMP. A template for reporting on the implementation of the ESMP is provided in Annex 3.

The format requires the implementing body to specify evidence of completion for each mitigation measure (e.g. a document that proves the completion of the measure or a short description of the expected achievement or pictures). If implementation is ongoing, the status of implementation should be described. The monitoring report concludes by summarising the main findings and by indicating the overall status of ESMP implementation using a three-point ranking scale: on track (green), slightly delayed (yellow) or delayed (red). Opportunity is provided for indicating any additional environmental or social risks that may have emerged since the project start and the appropriate mitigation measures taken or planned for any significant new risk.

7.4 Grievance Redress Process

7.4.1 Background

A grievance is any query, call for clarification, problems and concerns raised by individuals or groups related to activities undertaken or processes applied by the project. Grievances can be an indication of growing stakeholder concerns and can escalate if not identified and resolved. A Grievance Redress Mechanism (GRM) is a system by which queries or clarifications about a project are responded to, problems that arise out of implementation are resolved and grievances are addressed efficiently and effectively. An effective and efficient GRM should have multiple avenues or channels for lodging complaints, transparency, promptness and timeliness of responses and clear procedures.

During the planning of the planning stages of the projects in each school, the school authorities, PTA and the SHEP Coordinators were consulted by the AdMA Management, AdMA GAMA Project Team and the Engineering Consultant for AdMA (Colan Consult). The consultation helped to identify the plot boundaries of the institutions, the appropriate toilet types for the institutions and the location of toilets.

Since the entire project implementation programme was carried out with consultation and participation of the beneficiary institutions and AdMA, many grievances are not anticipated to arise from the project implementation and any unforeseen grievances may be resolved amicably and easily. Nevertheless, appropriate channels have been provided for expression and resolution of grievances during the implementation and operation of the project.

7.4.2 Objectives of the Grievance Redress Mechanism

The objectives of the grievance redress mechanism are as follows: 1. To provide affected people and institutions with channels to lodge complaints or resolve any disputes that may crop up during project implementation;

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2. Provide a mechanism for stakeholder concerns to be addressed in a mutually acceptable and timely manner, and by the most appropriate officers; 3. Identify and monitor stakeholder concerns to support effective stakeholder and risk management; 4. Enhance the reputation of the project implementers as transparent and environmentally and socially responsible; and, 5. Meet requirements of international best practice.

7.4.3 Grievance Redress Process

The grievance redress process has been discussed below under the construction and operational phases of the proposed project. Any grievance received from affected stakeholders shall be treated confidentially and resolved in a transparent and fair manner.

Construction Phase Grievance Redress Grievance registration The School based Health Coordinator/SHEP Coordinator of each beneficiary school will be officially responsible for receiving grievances which may be channeled to them directly through face-to-face communication, phone calls, letters, e-mail, text messages, etc. Complaints received shall be forwarded to the grievance redress committee. The members of the committee shall be the Head Teacher, the School Management Committee and the SHEP Coordinator, who will be secretary to the grievance redress committee.

All grievances, presented in writing or verbally, will be logged by the Head Teacher by filling a grievance redress form. The SHEP Coordinator will ensure that each complaint has an individual reference number, and is appropriately tracked and recorded actions are completed. A sample of a Grievance mechanism Form is included in Annex 4. Grievances may also be channeled to the GAMA Project Coordinator at AdMA.

The log book should take into account the following: date the complaint was reported; date on which the grievance form was submitted to the grievance committee, date information on proposed corrective action sent to complainant (if appropriate); the date the complaint was closed out and date response was sent to complainant.

Redress decision, feedback and implementation The redress committee will make a decision on all matters received, in consultation with the complainant, if necessary, in not more than two working days. The agreed redress action should be implemented within an agreed timeframe of not more than five days, depending on the nature of the complaint.

If field verification is required, the redress committee, in company with the complainant, will visit the complaint area to verify satisfactory redress action is carried out. When the complainant is

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satisfied with the redress action, the complaint will be closed and logged in the grievance log book and endorsed by the complainant.

Dissatisfaction and alternative action 1. If no understanding or amicable solution is reached, or the affected person does not receive a response from the redress committee within 5 working days, the affected person can appeal to the GAMA Project Coordinator, who shall seek to resolve the issue in collaboration with the Project’s Engineering Consultant and the AdMA Works Engineer. It is expected that the complaint/grievance will be resolved within 5 working days of its filing. 2. If the grievance remains unresolved, the affected person can appeal to the Safeguards Specialist at the PCU, who in consultation with the GAMA Project Director at the MLGRD, GAMA Project Coordinator at the PCU and the Chief Director will mediate on the issue within five working days. 3. If a resolution is not reached from the first three steps, the complainant may seek legal action for redress. However, noting that court cases can be cumbersome and time consuming, it is of high opinion that Court cases should be the last ‘resort’ and all effort must be made to reach amicable settlement at the very early stages of complaints by affected persons.

Monitoring and Evaluation Monitoring and evaluation activities will be conducted by the PCU to ensure complaint and grievances lodged by the affected persons are followed-up and amicably resolved.

The grievance redress process for the construction phase is illustrated in Figure 7-1.

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TIER 1

Grievance received and screened by SHEP Coordinator

Redress Committee of meet and take decision

TIER 2 2 wkn days Complainant not Feedback to satisfied (Grievance complainant unresolved

Complainant satisfied Grievance sent to GAMA with decision Project Coordinator, Project’s (Grievance resolved) Engineering Consultant and AdMA Works Engineer

5 wkn days TIER 3 Decision taken through discussion Complainant not with beneficiary satisfied (Grievance

institution and unresolved Complainant

Complainant Grievance sent to Safeguard satisfied (Grievance Specialist PCU, the GAMA resolved) Project Director at the MLGRD, GAMA Project Coordinator at the PCU and the Chief Director

TIER 4 5 wkn days Decision taken Complainant not through discussion satisfied (Grievance with all parties unresolved

Complainant Complainant takes satisfied (Grievance legal action resolved)

Law Court Rules

Figure 7-1: Grievance Redress Process for the Constructional Phase Institutional Sanitation Facilities Project

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Operational Phase Grievance Redress The School based Health Coordinator/SHEP Coordinator of each beneficiary school will be officially responsible for receiving grievances which may be channeled to them directly through face-to-face communication, phone calls, letters, e-mail, text messages, etc. Complaints received shall be forwarded to the School Management Committee (SMC) for redress.

All grievances, presented in writing or verbally, will be logged by the SHEP Coordinator by filling a grievance redress form. The SHEP Coordinator will ensure that each complaint has an individual reference number, and is appropriately tracked and recorded actions are completed. A sample of a grievance mechanism form is included in Annex 4.

The SHEP Coordinator shall have a log book for keeping records of all grievances received and copies of the records kept with all the relevant authorities. A review of grievances will be conducted at least every three months during implementation in order to detect and correct systemic problems. The log book should take into account the following: date the complaint was reported; date on which the grievance form was submitted to the grievance committee, date information on proposed corrective action sent to complainant (if appropriate); the date the complaint was closed out and date response was sent to complainant. Redress decision, feedback and implementation The SMC will make a decision on all matters received, in consultation with the complainant, if necessary, in not more than two working days. The agreed redress action should be implemented within an agreed timeframe of not more than five days, depending on the nature of the complaint.

If field verification is required, the redress committee, in company with the complainant, will visit the complaint area to verify satisfactory redress action is carried out. When the complainant is satisfied with the redress action, the complaint will be closed and logged in the grievance log book and endorsed by the complainant. Dissatisfaction and alternative action 1. If no understanding or amicable solution is reached, or the affected person does not receive a response from the redress committee within 5 working days, the affected person may appeal to the Municipal SHEP Committee, through the Municipal SHEP Coordinator, who should act on the complaint/grievance within 5 working days of its filing. Grievances from the school stakeholders, where necessary, will be resolved in collaboration with the beneficiary institution and the complainant. Grievances involving the community members will be resolved in consultation with the community leadership and complainant, as necessary. 2. If the grievance remains unresolved, the affected person can appeal to the Regional SHEP Coordinator at the Ministry of Education who, in consultation with the Municipal SHEP Committee will mediate on the issue. 3. If a resolution is not reached from the first three steps, the complainant may seek legal action for redress. However, noting that court cases can be cumbersome and time consuming, it is of high opinion that Court cases should be the last ‘resort’ and all effort must be made to reach amicable settlement at the very early stages of complaints by affected persons Monitoring and Evaluation Monitoring and evaluation activities will be conducted by the PCU to ensure complaint and grievances lodged by the affected persons are followed-up and amicably resolved. The grievance redress process for the operational phase is illustrated in Figure 7-2.

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TIER 1

Grievance received and screened by SHEP Coordinator

School Management Committee meet and take decision TIER 2 2 wkn days Complainant not Feedback to satisfied (Grievance complainant unresolved

Complainant satisfied Grievance sent to Municipal with decision Assembly/GES (Municipal (Grievance resolved) Committee/ Municipal SHEP Coordinator to receive)

5 wkn days TIER 3 Decision taken through discussion with Complainant not beneficiary institution/ satisfied (Grievance community leadership unresolved and Complainant

Complainant Grievance sent to satisfied (Grievance Regional SHEP resolved) Coordinator at GES

- TIER 4

Decision taken Complainant not through discussion satisfied (Grievance with all parties unresolved

Complainant Complainant takes satisfied (Grievance legal action resolved)

Law Court Rules

Figure 7-2: Grievance Redress Process for Operational Phase for the Institutional Sanitation Facilities Project

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7.5 Capacity Building and other Requirements for Implementation of ESMP and Permit Conditions

Training Workshop will be organized to guide the implementation of the ESMP, Permit Schedule, Triggered World Bank Safeguards Policy and environmental management. The training on the ESMP implementations will include the Code of Conduct for contractor and his/her labour force, public and occupational health and safety issues, Grievance Redress Mechanism for the project, ESMP monitoring and reporting, sensitization of workers on child sexual exploitation.

7.5.1 Objectives of the training The main objective of the capacity building and training activities is to create, enhance and develop the necessary skills and abilities for successful implementation of the proposed project.

7.5.2 Methodology for the training The methodology to implement the training will include:  Workshops and site meetings;  Sensitization for students during School Assembly, Morning Devotion or in the classrooms;  Sensitization at PTA meetings.

It is recommended that the site meetings discuss the ESMP issues and any health and safety issues identified in the course of the month. Non-compliances identified during monitoring should reviewed and corrective actions taken. A capacity building measure proposed to achieve this is provided in Table 7-4.

Table 7-4: Capacity building plan for implementation of ESMP and Permit Conditions

No. Activity Target Group/Participants Timeline/Duration Proposed Estimated Facilitator Cost/(Gh₵) 1. Training Workshop on ESMP, MMA Prior to Municipal 15,000 Permit Schedule, Triggered -MMA Project Coordinator resumption/ Assembly/ World Bank Safeguards Policy -Municipal Works Engineer commencement of Safeguards and and environmental -Municipal SHEP Officer construction works Specialist/ management -Procurement Officer Consultant Engineering Consultant -Works Engineer -Clerk of Works, safeguards personnel

Contractor -Manager -Site Supervisor -Engineers,

-Foreman

AdMA -Project Coordinator, Works Engineer, Planning Officer, Finance Officer

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No. Activity Target Group/Participants Timeline/Duration Proposed Estimated Facilitator Cost/(Gh₵) 2. Induction on occupational and All construction workers Prior to Lead 10,000 public health and safety commencement of Contractor/ requirements of the works and construction works Engineering environmental management, Consultant child sexual abuse and HIV/AIDS education 3. Training for use and -SHEP Coordinators Prior to -Engineering 10,000 management of facilities -Teachers commissioning and Consultant -SMC handing over of -GAMA -School Health Club facilities to schools Coordinator -Municipal SHEP Committee & Coordinator 4. Sensitization and awareness -Students Throughout -SHEP As part of creation on use and operation of Coordinators duties of SHEP management of facilities facilities -School Coordinators, (interactive activity, teaching, Health Club School and demonstrative activity for School Health building habits & knowledge Club. testing during classes, worship time and assembly)

TOTAL COST 35,000.00

7.5.3 Output of the training

Capacity building on the health, safety, environmental and social management measures provided in this chapter is required to ensure the effective implementation of the ESMP and the permit conditions. All monthly and progress reports should capture health, safety and environment capacity building activities carried out.

7.6 Estimated Budget for ESMP Implementation.

The environmental and social management actions described above require detailed cost analysis after project development to determine the budget needed for implementation. It is estimated that an amount of Three Hundred and Seventy One Thousand, Eight Hundred Ghana Cedis (GH¢371,800.00) will be required to implement the provisions of the ESMP for all the beneficiary institutions in AdMA as shown in Table 7-5. This figure is subject to review following confirmation from cost studies to be carried out after project development phase.

The budget for the monitoring activities by the MLGRD-PCU are not captured in the monitoring costs presented in the Environmental and Social Monitoring Plan and reporting. This is because, the monitoring roles of the PCU is already included in the GAMA Project cost.

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Table 7-5: ESMP Budget. No. Programme Cost/year (GH) 1. Mitigation Action for Identified Impacts (Table 7-1) {GH¢ 9000 per institution} 243,000.00 2. Mitigation Action for Identified Risks To The Sustainability of the Project (Table 7-2) 78,300.00 3. Environmental And Social Monitoring Plan (Table 7-3) 10,500.00 4. Grievance Redress 5,000.00 5. Capacity Building (Table 7-4) 35,000.00 Total 371,800.00

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8.0 CONCLUSION

AdMA and the Project Coordinating Unit of MLGRD are committed to ensuring sustainable environmental management and safeguarding the health and safety of the construction workers, pupils/teachers/staff at the beneficiary schools and the general public during the implementation of the proposed project. AdMA is also aware of the provisions in the Environmental Assessment Regulations 1999, LI 1652 and the World Bank Operational Policies. In keeping with these laws, this ESMP has identified and assessed key environmental and social impacts and concerns that may arise from the implementation of the proposed project.

Consultations with stakeholders, review of relevant literature, field inspections and studies underpinned the identification of the project adverse environmental and social impacts. A monitoring programme to help detect changes arising from the predicted adverse impacts has also been presented in this ESMP. The recommendations outlined in the ESMP for the project will ensure a high level of health, safety and environmental management for the proposed project.

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9.0 BIBLIOGRAPHY

Colan Consult (2015a) Baseline Study. Draft WASH Report, Volume 2 – Part A. Adentan Municipal Assembly.

Colan Consult (2015) Assessment of Existing School WASH Facilities. Draft WASH Report, Volume 2 – Part B. Adentan Municipal Assembly.

Colan Consult (2015) Draft FMP and Hygiene Education Plans (HEP). Draft WASH Report, Volume 4. Adentan Municipal Assembly.

Colan Consult, 2016. Final WASH Assessment Report. Volume 1: Facilities Assessment. Adentan Municipal Assembly.

Colan Consult (2016) Environmental Screening Report. Adentan Municipal Assembly.

Colan Consult (2015) Knowledge, Attitude and Practice (KAP) Study. Draft WASH Report, Volume 1. Adentan Municipal Assembly.

Colan Consult (2015) Preliminary Design of School WASH Facilities. Draft WASH Report, Volume 3. Adentan Municipal Assembly.

Ghana Statistical Service (2014) 2010 National Population & Housing Census. District Analytical Report. Adentan Municipality.

WRRI, 1996. Borehole yield map of Ghana, WRRI publication, Accra, Ghana.

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ANNEXES

Annex 1 Stakeholder Consultations Annex 2 Code of Conduct Annex 3 Template for reporting on the implementation of the ESMP Annex 4 Grievance Form

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ANNEX 1 STAKEHOLDER CONSULTATIONS

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ANNEX 2 CODE OF CONDUCT

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ANNEX 3 TEMPLATE FOR REPORTING ON THE IMPLEMENTATION OF THE ESMP

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ANNEX 4 GRIEVANCE FORM

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