Federal Government of Nigeria

E1964 FEDERAL GOVERNMENT OF NIGERIA

Federal Ministry of Health

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

FOR THE

Second Health Systems Development Project (HSDP II) – Additional Financing

- Final Report -

Submitted to:

Federal Ministry of Health Federal Secretariat Complex Central Business District F.C.T. Abuja, Nigeria

Maximizing Resources and Sustaining Development

August, 2008 Submitted by:

Joseph E. Akpokodje

Managing Consultant Earthguards Limited: Sustainable Development Consultants Suite 45, (3rd Floor), God’s Own Plaza, 4 Takum Close, Area 11, Garki, F.C.T. Abuja, Nigeria P.O. Box 12428, Garki, F.C.T. Abuja, Nigeria Website: www.earthguards.net Email: [email protected], [email protected]

i LIST OF ACRONYMS

CBO Community Based Organization CO Carbon Monoxide EA Environmental Assessment EDP Essential Drug Program EIA Environmental Impact Assessment ELSS Emergency Life-Saving Skills ESA Environmental Sensitive Area/ Environmental and Social Assessment ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan EMP Environmental Management Plan EOC Emergency Obstetric Care FCT Federal Capital Territory FEPA Federal Environmental Protection Agency FGN Federal Government of Nigeria FMEH Federal Ministry of Environment and Housing FMEH&UD Federal Ministry of Environment, Housing, and Urban Development FMEnv Federal Ministry of Environment FMAWR Federal Ministry of Agriculture and Water Resources HMIS Health Management Information System HSDP Health Systems Development Project HSDP II Second Health Systems Development Project HSE Health, Safety and Environment IDA International Development Association ISDS Integrated Safeguards Data Sheet M&E Monitoring and Evaluation NGO Non Governmental Organization NPCU National Project Coordinating Unit NPSC National Project Steering Committee LGA Local Government Area M & E Monitoring and Evaluation Officer OP/BP Operation Policy/Bank Policy PAD Project Appraisal Document PCN Project Concept Notes PCU Project Coordinating Unit PFMU Project Finance Management Unit PHCN Power Holding Company of Nigeria PIU Project Implementation Unit PMU Project Management Unit SEPA State Environmental Protection Agency SMOH State Ministry of Health SSA Sub Saharan Africa TDS Total Dissolved Solids TSP Total Suspended Particles TOR Terms of Reference WB World Bank

i ii TABLE OF CONTENTS LIST OF ACRONYMS...... I TABLE OF CONTENTS...... II TABLE OF FIGURES...... III LIST OF TABLES...... IV EXECUTIVE SUMMARY...... V CHAPTER ONE: INTRODUCTION...... 1

1.1 BACKGROUND...... 1 1.2 OBJECTIVES OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)...... 2 1.3 STUDY APPROACH & METHODOLOGY...... 2 CHAPTER TWO: DESCRIPTION OF PROPOSED PROJECT AND WORKS...... 4 .CHAPTER THREE: STUDY AREA...... 6

3.1 THE BIO- PHYSICAL ENVIRONMENTAL FEATURES...... 6 3.1.1 Physical Environment...... 7 3.1.2 Biological Environnent...... 9 3.2 SOCIAL -ECONOMICS...... 10 CHAPTER FOUR: POLICY, LEGAL AND REGULATORY FRAMEWORK...... 13

4.1 POLICY FRAMEWORK...... 13 4.2 LEGAL FRAMEWORK...... 13 4.2.1 Assessment of the Legal Framework...... 15 4.3 INTERNATIONAL ENVIRONMENTAL AGREEMENTS...... 16 4.4 WORLD BANK SAFEGUARD POLICIES...... 16 CHAPTER FIVE: POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS...... 18

5.0 POTENTIAL IMPACTS...... 18 5.1.1 Environmental Impacts...... 19 5.1.2 Social and Health Impacts...... 20 5.2 MITIGATION...... 22 5.2.1 Mitigation Measures...... 22 5.2.2 Mitigation Funding...... 25 CHAPTER SIX: INSTITUTIONAL ARRANGEMENTS FOR ENVIRONMENTAL MANAGEMENT...... 26 CHAPTER SEVEN: PUBLIC CONSULTATION PLAN...... 29

7.1 OBJECTIVES...... 29 7.2 IDENTIFYING STAKEHOLDERS...... 29 7.3 CONSULTATION STRATEGIES...... 29 ANNEX 1: LIST OF PERSONS MET...... 30 ANNEX 2: SUMMARY OF WORLD BANK ENVIRONMENTAL AND SOCIAL SAFEGUARD POLICIES...... 32 ANNEX 3: DRAFT EIA /ESIA TERMS OF REFERENCE...... 35 ANNEX 4: CONTRACT PROVISIONS: ENVIRONMENTAL AND SOCIAL IMPACTS...... 37

iii TABLE OF FIGURES

FIGURE 3.1: MAP OF NIGERIA SHOWING THE 36 STATES OF NIGERIA ...... 6

iv LIST OF TABLES

TABLE 3.1: NIGERIAN AMBIENT AIR QUALITY STANDARD...... 8

TABLE 3.2: AIR QUALITY CLASSIFICATION BASED ON TSP VALUES...... 8

TABLE 5.1: POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE HSDP II (ADDITIONAL FINANCING)

PROJECT...... 18

TABLE 5.3: SUMMARY OF ENVIRONMENTAL MITIGATION MEASURES...... 23

TABLE 6.1 INSTITUTIONAL CAPACITY STRENGTHENING PROGRAM...... 27

TABLE 7.1: STAKEHOLDER IDENTIFICATION MATRIX...... 29

v EXECUTIVE SUMMARY

The Second Health System Development Project (HSDP II) is currently operating in 36 states of the country. This project is jointly sponsored by the International Development Association (IDA) Credit from the World Bank with counterpart funding from the Federal Ministry of Health and the various State Governments in whose jurisdiction the project will take place.

As a result of the restructuring of the project in 2005 whereby resources were reallocated to cover overspending by 22 out of the 36 states, the Nigerian Authorities through the Federal and State Governments have requested for Additional Financing in order to carry out agreed work plans and complete ongoing activities.

The additional financing would retain the same objectives and implementation procedure of the original project and would be allocated as a supplementary credit to the Federal Government and the 22 states.

The HSDP II Components are as follows:

 Component 1: Rehabilitation and Refurbishment of Schools of Health Technology and Schools of Nursing and Midwifery.  Component 2: Support of Health Services.  Component 3: Strengthening Monitoring and Evaluation systems and processes at National and State Levels.

The World Bank’s Safeguard Policy, Environmental Assessment (OP 4.01) is triggered if a project is likely to present some risks and potential adverse environmental impacts in its area of influence. The activities of Components 1 will involve civil works and therefore triggers OP 4.01.

OP 4.01 requires that an Environmental and Social Management Framework (ESMF) be prepared which will establish a mechanism to determine and assess future potential environmental and social impacts of project investments and then to set out mitigation, monitoring and institutional measures to be taken during design, implementation and operation of the subprojects to minimize adverse environmental and social impacts to acceptable levels.

Objectives of the ESMF to the HSDP II are to:

 Assess the potential environmental and social impacts of sub-projects  Inform the project preparation team and the Nigerian Government of the potential impacts of different of different anticipated sub-projects and relevant mitigation measures and strategies  Establish clear directives and methodologies for the environmental and social screening of sub-projects to be financed

vi  Identify potential environmental policies, legal and institutional framework pertaining to the project.

Potential Environmental and Social Impacts:

There would be no significant cumulative adverse environmental and social impacts to the HSDP II project, but minimal site specific impacts to the environment and humans might occur which is consistent with category B projects. Since only a minimal part of HSDP II component 1 would involve civil works, there would be no need for a screening mechanism. Therefore appropriate mitigation measures have been identified that would reduce and/ or eliminate potential environmental impacts.

The potential site specific environmental and social impacts that might occur would be addressed through an Environmental and Social Impact Assessment (ESIA) report at the various state Project Implementation Units (PIUs) level with a specific Environmental Management Plan (EMP) developed.

Institutional Arrangement and Implementation of the ESMF:

In terms of implementation of the recommendations of the ESMF, it is recommended that each state PIU recruits the services of an environmental and social specialist or consultant on a part time basis to monitor and evaluate its implementation in each state.

Institutional Capacity Strengthening Program An institutional and capacity building strengthening on Environmental Management for HSDP II stakeholders should be incorporated at the various state PIUs.

The total estimated cost for capacity building / training of stakeholders for the 15 states is estimated at a lump sum of US $150,000.

vii Environmental and Social Management Framework of Health Systems Development Project II – Additional Financing

CHAPTER ONE: INTRODUCTION

1.1 Background The Second Health Systems Development Project (HSDP II) is a project operating in 36 states of the country with the exception of Kano State The development objective is to assist the Health authorities to redress the serious deterioration in the delivery of basic health care services and pave the way for a more sustained development of the Nigerian health care system by: (i) strengthening capacities for system management at the state level and encouraging an environment of broad-based consultation; (ii) supporting improvements in the delivery of primary health care services with a particular focus on maternal and child health and reproductive health services; and (iii) assisting the Federal Government to strengthen its policy formulation and further develop a system to monitor the health sector performance.

Project performance has been rated satisfactory for the past three years. All 36 States have completed over 80% of their agreed annual workplans. The key indicators suggest that the project has met its appraisal targets and has had a positive impact on the delivery of primary health care services to populations that previously had no access. Strategies undertaken by the States to reduce the high maternal mortality and morbidity rates include the building and renovation of basic health facilities in hard to reach areas, the procurement of medical equipment and drugs for these facilities, strengthening health systems, and the training of health personnel in Emergency Obstetric Care (EOC) and Emergency Life-Saving Skills (ELSS). The project has also had a significant impact on revitalizing the health institutions responsible for training midwives, nurses and community health workers through a reactivation of their accreditation, which had previously been denied due to the lack of adequate infrastructure and equipment. With the success, government now wants a second phase prompting the request for an additional financing to the tune of N 50 million.

The proposed additional loan would support the Nigerian authorities in their efforts to redress the serious deterioration in the delivery of basic health care services and provide a more sustained development of the health care system by: (i) strengthening capacities for system management at the state level and encouraging an environment of broad-based consultation; (ii) supporting improvements in the delivery of primary health care services with a particular focus on maternal and child health and reproductive health services; and (iii) assisting the Federal Government to strengthen its policy formulation and further develop a system to monitor the health sector performance.

The additional financing will cover the gap in funding created after the project was restructured in 2005 and resources were reallocated to cover overspending by 15 out of the 36 states. Therefore, states that had previously been promised additional resources during the restructuring were unable to access funds and subsequently unable to complete agreed work plan activities. There are no major changes proposed, instead, the additional

1 Earthguards Limited Environmental and Social Management Framework of Health Systems Development Project II – Additional Financing financing will ensure the completion of ongoing activities to maximize the achievement of the development

The activities under the proposed project as identified in the project paper will involve civil works especially on rehabilitation and refurbishment of schools of health technology and schools of Nursing and Midwifery

The World Banks Operational Policy (OP) 4.01 requires that an ESMF be prepared which will establish a mechanism to determine and assess future potential environmental and social impacts of project investments and then to set out mitigation, monitoring and institutional measures to be taken during design, implementation and operation of the subprojects to minimize adverse environmental and social impacts to acceptable levels.

1.2 Objectives of the Environmental and Social Management Framework (ESMF) The primary goal of this ESMF is to improve decision making and to ensure that the design, construction, expansion, upgrading of health infrastructures and other activities being considered under the proposed project are environmentally sound and sustainable. The secondary objective is to ensure that in-country capacity, regulatory framework; principles and procedures are established to provide a basis for environmental assessments of all sub-projects to be carried out under this additional financing

More specifically, the purpose of the framework is to: i Assess the potential environmental and social impacts of the sub-projects (rehabilitation, extension, or new constructions), whether positive or negative and propose mitigation measures; ii Inform the project preparation team and the Nigerian Government of the potential impacts of different anticipated subprojects and relevant mitigation measures and strategies; iii Establish clear directives and methodologies for the environmental and social screening of sub-projects to be financed by the project; and iv Identify potential environmental policies, legal and institutional framework pertaining to the project.

1.3 Study Approach & Methodology The ESMF study was prepared in accordance with applicable World Bank safeguard policies and Nigerian environmental impact assessment guidelines. The distinct phases of the study include: . Data Gathering; . Literature review; . Reconnaissance Surveys and visits to potential sub-projects sites; . Characterization of the baseline conditions;

2 Earthguards Limited Environmental and Social Management Framework of Health Systems Development Project II – Additional Financing

. Identification of potential impacts; . Identification of impact mitigation measures; . Preparation of an Environmental and Social Management Plan; and . Preparation of sub-project guidelines

. Literature Review The approach was based on review of available literature and other strategic planning documents at the national and state level. Specifically, the following were reviewed: project concept notes (PCN), draft project appraisal document (PAD), concept-stage Integrated Safeguards Data Sheet (ISDS) of the parent project. In addition, the project paper on the proposed additional financing grant was consulted. Also consulted were the general environmental management conditions for construction contracts; federal and state environmental laws regulations, decrees, acts, policies and guidelines; World Bank safeguard policies and other relevant documents.

. Data Gathering The consultant assembled and evaluated relevant baseline data related to the physical, biological and socio-cultural environment of the country. The baseline data reviewed included: topography, soil, water resources, climate and meteorology; biological and socio-economics data. Field visits were made to Anambra, Enugu, FCT Abuja and Sokoto states. During the field study to the states, discussions were held with officials of relevant state ministries and agencies. (See Annex 1.0 for complete list). Using the specific circumstances of each state visited, the particular technical operations of each State ministries of health and environment, including related agencies such environmental protection agencies/authorities were studied, their capacity to implement the proposed environmental and social management process and mitigation measures was assessed, and discussions held to determine appropriate recommendations for improvement in service delivery, mitigation, monitoring, institutional requirements and their training and capacity building needs.

CHAPTER TWO: DESCRIPTION OF PROPOSED PROJECT AND WORKS

The additional financing proposed (US$50 million) would retain the same objectives and implementation procedures of the original project and would be allocated (on a notional basis) as a supplementary credit to the Federal Government and 15 States. Government has agreed, that, due to the limited resources available and in order to achieve economies of scale and ensure impact, not all of the states will participate in the additional financing. Given the political sensitivities, performance-based criteria have been agreed in order to select the States. Government convened a meeting with all project stakeholders to discuss the criteria which are based on project performance, financing gap, stability of the Project Implementation Units (PIUs) and PFMUs and the timely payment of government contributions.

The additional financing will only support those states that have performed well to date The 15 States selected meet this criteria and based on their current workplan projections indicate that roughly 50% of the funds will go to support civil works (completing construction and rehabilitation of health institutions and primary health centers), 30% for service delivery, including commodities and equipment, and 20% for systems development (e.g. M&E) and capacity building at the State and community level. It is envisaged that the additional funding will support the following sets of activities within the broader context of strengthening primary health care services:

 Rehabilitation and Refurbishment of Schools of Health Technology and Schools of Nursing and Midwifery The objective of this component is to support the health training institutions to secure relevant accreditation in order to improve the quality of pre-training of human resources for health. Renovation/upgrading of equipment and training facilities as well as the provision of basic pedagogic materials will especially improve the supply of skilled attendants at birth

 Support to Health Services The objective of this component is to support activities that would improve the delivery of primary health care services and increase utilization rates. The additional financing would support the refurbishment/re-equipment of primary health facilities and training of health service workers, as well as immunization activities, such as the procurement and repair of cold chain equipment and training of vaccinators. The local health facilities to be rehabilitated are designated in each State’s workplan.

 Strengthening Monitoring and Evaluation Systems and Processes at National and State Levels The objective of this component is to strengthen the processes and systems to ensure evidence-based decision making and confirmation of the impact of government interventions in improving the delivery of basic health services. The lack of baseline data and inconsistent efforts to track results has impeded the project from having the influence to inform policy decisions and build the capacity for managing a robust monitoring system. The challenges of

working across 36 states and the weak capacity at all levels for quality data collection should not be underestimated.

Therefore, the focus on only 15 states that are already well-performing combined with a revamped monitoring and evaluation framework is expected to support more meaningful use of project data. A rapid assessment of the current Health Management Information Systems (HMIS) will be conducted to ascertain the bottlenecks and remaining data gaps.

The Director of Health Planning and Research will continue to be responsible for Monitoring and Evaluation M&E). But, the additional financing will allocate supplemental funding to contract M&E firms to deliver quality project Monitoring and Evaluation.

.CHAPTER THREE: STUDY AREA

3.1 The Bio- Physical Environmental Features Nigeria is situated in West Africa lying between latitudes 400 N and 1400N and longitudes 2500 W and 1445 E, bordered to its south by the Gulf of Guinea for about 850km, by the Republic of Benin to the West for 773km, Republic of Niger to its North for 1497km, Chad at its North Eastern Boundary (water boundary) for 87km and Cameroon to its East for 1,690km (see Figure 3.1 below).

Figure 3.1: Map of Nigeria showing the 36 states of Nigeria

Nigeria is blessed with abundant water resources estimated at 226 billion m3 of surface water and about 40 billion m3 of ground water.

The main characteristics of the biological, physical and socio-economic environment of the project area are summarized below.

3.1.1 Physical Environment

Climate

Nigeria’s climate varies from arid in the north, tropical in the centre and equatorial in the south. The climate is largely controlled by prevailing winds and nearness to the Atlantic Ocean. The two dominant air masses are the dry wind from the Sahara and the wet wind from the Atlantic Ocean. Marginal alterations have being recorded due to landform characteristics, configuration of surrounding shoreline and the generally flat topography of the country.

Rainfall

Rainfall is the single most important element for defining the climatic seasons in the tropics. Hence, Nigeria has two dominant seasons; the wet and the dry seasons. Rainfall throughout Nigeria depends on the interaction of the tropical maritime air mass and the tropical continental mass which meet along the Inter-Tropical Convergence Zone (ITCZ). The annual average rainfall around the country is between 2000mm and 3000mm.

Temperature

Nigeria’s climate is characterized by relatively high temperatures throughout the year. The average annual maximum varies from 35oC in the north to 31oC in the south; the average annual minimum from 23oC in the south to 18oC in the north. On the Jos plateau and the eastern highlands altitude makes for relatively lower temperatures, with the maximum no more than 28oC and the minimum sometimes as low as 14oC.

Two principal wind currents affect Nigeria. The south-westerlies dominate the rainy season of the year while north-easterlies dominate the dry season. Depending on the shifts in the pressure belts in the Gulf of Guinea, these winds are interspersed respectively by south-easterlies and north-westerlies in different parts of the year. The wetter winds prevail for more than 70% due to the strong influence of the breeze from the Atlantic Ocean. Mean annual wind speed varies between 2 to 6 m/s. Speeds in dry season (November - March) are lower. In the wet season (April–October), daily average speed could rise to 15 m/s. Values of up to 25 m/s are sometimes experienced due to inducement by convective rainfall activities and relative diffusion.

Ambient Air Quality

Generally, the air quality in the various states comply with regulatory standards. Although, slight variations are noticed in major industrial cities like Lagos, Ibadan, Aba, Kano, Port Harcourt and Kaduna.

The Federal Ministry of Environment, Housing and Urban Development (FME & UD) adopted the WHO standards (Table 3.1) as the national standards for gaseous emissions against which air quality parameters monitored are compared in order to ascertain its “cleanliness” (as seen in Table 3.2).

Table 3.1: Nigerian Ambient Air Quality Standard Air Pollutants Emission Limits Particulates 250 (µg/m3)

SO2 0.1 (ppm) Non-methane Hydrocarbon 160 (µg/m3) CO 11-4 (µg/m3) or 10 (ppm)

NOX 0.04-0.06 (ppm) Photochemical Oxidant 0.06 (ppm) Source: FME 1991

Table 3.2: Air Quality Classification Based on TSP Values Range of TSP Values (g/m3) Class of Air Quality 0 – 75 High Quality 76 – 230 Moderate Quality 231 – 600 Poor Quality Source: Jain, et. al (1976)

Geology

Nigeria lies on the southern portion of the West African Craton. The geological setting comprises broadly crystalline basement complex rocks and sedimentary formations. They occur in equal proportions around the country. The former are highly mineralized and give rise to soils of high nutrient status, although variable from place to place. The latter are found in the south-east, north-east and north-west of the country, and give rise to sandy and less variable soils that are deficient in plant nutrient.

Topography

Nigeria has varying landforms and much of the country is dominated by plains, generally less than 610m above sea level. The eastern border with the Republic of Cameroun is lined by an almost continuous range of mountains which rise to about 2,419m at Chappal Waddi, the highest known point in Nigeria.

In the North, the Jos Plateau rises abruptly from a general level of about 609.5m in the Hausa Plains to an average level of some 1,219m but reaches 1,781.6m in Shere Hills. The area west of the River Niger is dominated by the plain, which rises gently from the coast northwards 'to the area of crystalline rocks where inselbergs rise abruptly above the surrounding plains. The Idanre Hills, the highest point of these inselbergs, rise to about 981m above sea level.

In general, the land surface of the country could be classified into three broad physical units or major relief features namely: the plains; the highlands; the troughs and the river valleys.

Soils Characteristics

The broad pattern of soil distribution in the country reflects both the climatic conditions and the geological structure; heavily leached, reddish-brown, sandy soils are found in the south, and light or moderately leached, yellowish-brown, sandy soils in the north. The difference in color relates to the extent of leaching the soil has undergone.

Nigeria soils are highly weathered and are characterized by light texture, low pH, low organic matter, low potassium levels, variable phosphorous levels with clay contents ranging between 7%-43%.

Surface and Ground Water Hydrology

Nigeria has two major rivers, the Niger and the Benue, which traverse the northwest and northeast portion of the country, then merge at Lokoja before draining down to the Atlantic. There are several other rivers and quite a number of minor streams and rivulets that crisscross the entire Nigerian land mass. These include the Ogun, Oshun, Imo, Cross, Osse, Nun and the Anambra rivers in the south and the Kaduna, the Gongola, and the Hadeija rivers in the North.

Generally the water quality in the rivers of Nigeria is very good. The average electrical conductivity in the main rivers ranges between 48-65 Umhos/cm2 and the Total Dissolved Solids (TDS) concentration is about 100mg/l. The pH is less than 6.5, although higher values were reported in swamps and floodplains with levels of 100-150 Umhos/cm2. These rivers are also low in nutrients, with an average nitrogen content of 0.32mg/l and a total phosphorous content of 0.1 mg/l. The data indicate water of high quality according to FMEH & UD limits.

3.1.2 Biological Environnent

Animals found in both forest and savannas include leopards, golden cats, monkeys, gorillas, and wild pigs. Today these animals can be found only in protected places as the Yankari Park, Gashaka Gumti Park, and Cross River Park. Rodents such as the squirrel, porcupine, and cane rat constitute the largest family of mammals. The northern savannah

11 Earthguards Limited Environmental and Social Management Framework of Health Systems Development Project II – Additional Financing abounds in guinea fowl. Other common birds include quail, vultures, kites, bustards, and gray parrots. The rivers contain crocodiles, hippopotamuses, and a great variety of marine life.

In the rain forest, few large animals notably gorillas, chimpanzees, baboons and monkeys are present. Crocodiles, lizards, and snakes of many species are also present. Hippopotamuses, elephants, giraffes, leopards, and lions now remain only in scattered localities and in diminishing number. Wildcats, however, are more common and widely distributed. Wildlife in the savanna includes antelope, lions, leopards, gazelles, and desert hyenas. Nigeria also abounds in bird life with a great number of species being represented.

Vegetation varies dramatically in relation to climate, soil, elevation, and human impact on the environment. In the low-lying coastal region, mangroves line the brackish lagoons and creeks, while swamp forest grows where the water is fresh. Farther inland, this vegetation gives way to tropical forest, with its many species of tropical hardwoods, including mahogany, iroko, and obeche.

North of the forest is the Guinea Savannah, a region of tall grasses and trees. The southern margin of the Guinea Savannah has been so altered by humans that it is also called the derived savannah. Beyond the Guinea savannah lies the Sudan Savannah, a region of shorter grasses and more scattered, drought-resistant trees such as the baobab, tamarind, and acacia. In the northeastern corner of Nigeria, the very dry semi-desert Sahel Savannah persists.

3.2 Social -Economics

Demographics

According to the latest estimates, the population of Nigeria is approximately, 150million (Nigeria Population Census), which makes Nigeria the largest country by population, in Africa. The annual average growth rate between 1995-2001 was projected at 2.6% and the urban population represented 47% of the total population or 61.1 million people. The illiteracy rate, which is an estimate of the percentage the population over 15years old that have not completed a primary school education level, is 35%.

The real significance of Nigeria’s demographic situation is that it simultaneously has a large population and one of the highest rates of growth in the world, causing its projection to move up so rapidly in total population. Many unknown factors could alter the above estimate. AIDS is one factor that could have a dramatic impact on Nigeria’s future demographics. While AIDS is not the critical national health concern that it is in other sub-Saharan countries, it may grow to become a problem of great concern. Rural – Urban migration in Nigeria, like in most other countries is fuelled by the pursuit for increased economic/ livelihood opportunities.

Ethnic Groups and Religion

Nigeria, which is Africa’s most populous country, is composed of more than 250 ethnic groups, the larger of which are the Hausa and Fulani, who are predominantly from the North represent approximately 29% of the population, the Yoruba, predominantly from the South (South West) and represent approximately 21% of the population or and the Ibo, predominantly from the East represent about 18% of the population. The other large groups are the Ijaw with about 10%, the Kanuri with about 4%, the Ibibio with about 3.5%. The Middle Belt region of Nigeria shows the greatest degree of ethnic diversity, particularly in Adamawa, Taraba and Plateau States.

The religious groups include Muslims, which make up about half of the population at approximately 65 million people; Christians at about 40% or about 52million people and the rest are of indigenous beliefs (10%) or about 13 million people.

Land Use Pattern

The estimated land area of Nigeria is 924,000 km2. Land use varies based on location and the needs of the community. However, the different uses of land revolve around agriculture, industry and social needs such as the provision of infrastructure. Recent data shows that about 60% of the land area of Nigeria is under various forms of food (crop and animal) production and forest plantation.

Land Tenure

The Land Use Decree of 1978 vests all land in the state through the office of the governor. Land is to be held in trust and administered for the use and common benefit of all Nigerians according to the provisions of the Act. By this legal instrument, the state replaced the traditional institutions of obaship/emirship and chiefs in their roles as custodians of communal land.

Control and management of land in urban areas is the responsibility of the state governor, while all other land (rural, public, etc.) is the responsibility of the Local Government of the area. The governor is empowered to designate certain areas as urban land and to grant statutory rights of occupancy of fixed periods and rights of access to any person, subject to rental arrangements fixed by and payable to the state. The local government can grant a customary right of occupancy to land in the local government area (LGA) to any person or organization for agriculture, grazing, residential or other purposes.

Public Health Features

The increase in urban and peri-urban population over the years, coupled with the significant decline in the performance of the State Water Agencies to provide potable water (it is estimated that only 50% of the urban and 20% of the peri-urban have access to reliable water supply), and with poor or no acceptable sanitation or drainage infrastructure in many of these areas, the prevalence rate for diseases such as diarrhea, malaria, dysentery and other serious health conditions are high.

Poverty

According to the World Bank, Country at a Glance report, 2001, the gross national income (GNI) per capita of Nigeria is US$290, which is significantly lower than the average of US$470 for sub Saharan Africa (SSA). It is estimated that 60% of the total population of Nigeria live below the poverty line. The average percentage of the urban poor (i.e. % of population below national poverty line) is a staggering 45% compared with the SSA average of 32%.

Economics

The Nigerian economy rests on two pillars: oil/gas and agriculture. Both sectors contributes 65% - 70% of GDP, while the secondary sector (manufacturing contributes about 7% and the tertiary sector (transport, trade, housing etc) contributes about 25%.

Nigeria’s major industries are located in Lagos, Sango Otta, Port Harcourt, Ibadan, Aba, Onitsha, Calabar, Kano, Jos and Kaduna.

Infrastructural Facilities

The main transportation means in Nigeria is the road. Water transportation is fairly developed in some coastal areas. Air transportation is considered fair with major airports in Lagos, Abuja, Port Harcourt, Kano and Kaduna. The railway sector has experienced a major decline in the last decades but efforts are being made to revive it.

Electricity is supplied through the national grid. The power supply is erratic; and government is promoting the development of independent power supply to augment the current inadequate supply.

With regard to educational facilities, Nigeria is reasonably served. There are over 50 universities consisting of federal, state and private owned. High schools in most states are insufficient and are in dilapidated state, except for states in the southern part of the country.

Presently the Federal Government is refurbishing all existing tertiary health institutions nationwide. There is at least 1 primary health care institution in each of the 744 local government areas

CHAPTER FOUR: POLICY, LEGAL AND REGULATORY FRAMEWORK Nigeria has developed a number of important initiatives in policies, laws and regulations applicable to the environment.

The major national policies and regulations that are considered relevant to the project are summarized in this section.

4.1 Policy Framework National Policy on the Environment The stated goal of the National Policy on the Environment is to achieve sustainable development in Nigeria, and in particular to:

. Secure a quality of environment adequate for good health and well being; . Conserve and use the environment and natural resources for the benefit of present and future generations; . Restore, maintain and enhance the ecosystems and ecological processes essential for the functioning of the biosphere to preserve biological diversity and the principle of optimum sustainable yield in the use of living natural resources and ecosystems; . Raise public awareness and promote understanding of the essential linkages between the environment, resources and development, and encourage individual and community participation in environmental improvement efforts; and . Co-operate in good faith with other countries, international organizations and agencies to achieve optimal use of trans-boundary natural resources and effective prevention or abatement of trans-boundary environmental degradation.

4.2 Legal Framework A number of national and international environmental guidelines are applicable to the sub-projects under the proposed project. In Nigeria, the power to enforce all activities that might impact the environment is vested in the Federal Ministry of Environment, Housing and Urban Development (FMEH & UD). Internationally, agencies such as the World Bank, DFID and other development agencies usually set environmental criteria for projects they are involved in.

 Federal

The Federal Ministry of Environment (FMEnv), now (since December 2006) Federal Ministry of Environment, Housing and Urban Development (FMEH & UD) was created in 1999 to take over the function of the Federal Environmental Protection Agency (FEPA). The ministry has a mandate to co-ordinate the environmental protection and conservation of natural resources for sustainable development in Nigeria.

The specific responsibilities of the ministry are to:

. monitor and enforce environmental protection measures; . enforce international laws, conventions, protocols and treaties on the environment; . prescribe standards and make regulations on air quality, water quality, pollution and effluent limitations, the atmosphere and ozone layer protection, control of toxic and hazardous substances; and . promote cooperation with similar bodies in other countries and international agencies connected with environmental protection.

As contained in FEPA Acts 58 of 1988 and 59 of 1992. FMEH & UD has put in place statutory documents to aid the monitoring, control and abatement of industrial waste. The statutory documents currently in place include: . National Policy on the Environment 1999 . National Environmental Protection (Effluent Limitations) Regulations(S.1.8) 1991; . National Environmental Protection (Pollution Abatement in Industries and Facilities Generating Wastes) (S.1.9) 2004; . National Environmental Protection (Management of Solid and Hazardous Wastes) Regulations (S.1.15) 1991; . Guidelines and Standards for Environmental Pollution Control in Nigeria 1991; . Sectoral Guidelines for EIA 1995 . Harmful Wastes (Criminal Provisions) Decree No. 42, 1988; . National Policy on the Environment, 1989; . Environmental Impact Assessment Procedural Guidelines 1995; . Environmental Impact Assessment (EIA) Act No. 86 of 1992; and . Environmental Impact Assessment (Amendments) Act 1999. . National Guidelines and Standards for Water Quality 1999 . National Guidelines on Environmental Management Systems (EMS) 1999 . National Guidelines on Environmental Audit in Nigeria 1999

These statutory documents clearly state the restrictions imposed on the release of toxic substances into the environment and the responsibilities of all industries whose operations are likely to pollute the environment. Such responsibilities include provision of anti-pollution equipment and adequate treatment of effluent before being discharged into the environment, etc. (S.1.8 & 9).

FMEH & UD also has put in place procedural and sectoral guidelines detailing the EIA process including a categorization of environmental projects into Categories I, II and III. These guidelines require that a complete EIA be performed for Category I projects. Category II projects may not require an EIA depending on the screening criteria, while Category III projects do not require an EIA.

In addition, the land use act is considered relevant to the project:

Land Use Act

The legal basis for land acquisition and resettlement in Nigeria is the Land Use Act of 1978 which was modified in 1990. The following are selected relevant sections:

Section 1: Subject to the provision of this Act, all land comprised in the territory of each state in the Federation is vested in the Governor of each state and such land shall be held in trust and administered for the use and common benefit of all Nigerians in accordance with the provisions of this Act.

Section 2: (a) All land in urban areas shall be under the control and management of the Governor of each State; and (b) all other land shall be under the control and management of the local government within the area of jurisdiction in which the land is situated.

Therefore, according to the Land Use Act, all land in Nigeria is vested in the Governor of each State, and shall be held in trust for the use and common benefit of all people. The administration of land area is divided into urban land which will be directly under the control and management of the Governor of each State; and non- urban land, which will be under the control and management of the Local Government. The Governor of each State will have the right to grant statutory rights of occupancy to any person or any purpose; and the Local Government will have the right to grant customary rights of occupancy to any person or organization for agricultural, residential and other purposes.

- State

By the provision of acts, edicts and laws the states have also set up State Environmental Protection Agencies or Authorities (SEPAs) as the regulatory bodies to protect and manage the environmental issues in the states.

The functions of the SEPAs include:

. Enforcement of all environmental legislations and policies; . coordination and supervision of environmental assessment studies; . Minimization of impacts of physical development on the ecosystem; . Preservation, conservation and restoration to pre-impact status of all ecological processes essential to the preservation of biological diversity; . Protection of air, water, land, forest and wildlife within the states; . Pollution control and environmental health in the states; and . Co-operation with FMEH & UD and other agencies to achieve effective prevention of abatement of trans-boundary movement of waste.

4.2.1 Assessment of the Legal Framework

The existing legal framework for environmental assessment in Nigeria is considered adequate. Detailed laws, regulations and guidelines have been developed and serve as the framework for conducting EIAs in both the public and private sectors. The implementation of these rules has been poor due to lack of adequate enforcement.

EIA Act

The Act does not encourage the participation of people whose lives are likely to be affected by a project; rather, it encourages the collection and documentation of technical information which is confusing and unintelligible to a majority of people. All too often, the provisions enshrined in the law are not enforced.

Environmental Policy

The policy and its laudable institutional arrangements have not yielded the desired results. This is principally due to weak enforcement; inadequate manpower in the area of integrated environment management; insufficient political will; inadequate and mismanaged funding; a low degree of public awareness about environmental issues; and a top–down approach to the planning and implementation of environmental programmes.

Land Use Act

The Land Use Act points out that the interests of individuals and communities have been reduced to mere rights of occupancy, which can be revoked by the appropriate authorities on certain conditions such as ‘over-riding public interest’ (right-of-way, mining activities etc). Moreover, the law is ambiguous in certain respects and makes interpretation difficult. The Act which grants excessive powers to the Federal and State Governments has a dramatic impact on land rights. It does not provide adequate security against forced evictions, harassment, and threats.

4.3 International Environmental Agreements Nigeria is a signatory to the following relevant international conventions:

. The African Convention on the Conservation of Nature and Natural Resources, The African Convention, 1968; . The Convention Concerning the Protection of the World Cultural and Natural Heritage, The World Heritage Convention, 1972; . The Convention on International Trade in Endangered Species of Wild Fauna and Flora, CITES, 1973; . The Convention on Conservation of Migratory Species of Wild Animals, Bonn, 1979. . The Basel Convention on the Control of Transboundary Movement of Hazardous Waste and Disposal, 1989; . The Framework Convention on Climate Change, Kyoto Protocol, 1995; . The Convention on Biological Diversity, 1992; . The Convention on the Prevention of Marine Pollution by Dumping of Waste, MARPOL, 1972.

Nigeria also has obligations to protect the environment through various commitments to the African Union (AU), the Economic Community of West African States (ECOWAS) and the Commonwealth. It is also committed through relations with the European Community under the Lome IV Convention.

4.4 World Bank Safeguard Policies The HSDP II – Additional Financing has been categorized as B implying that the expected environmental impacts are largely site-specific, that few if any of the impacts are irreversible, and that mitigation measures can be designed relatively readily.

The Environmental Assessment for a Category B project:  examines the project’s potential negative and positive environmental impacts,  recommends measures to prevent, minimize, mitigate, or compensate for adverse impacts, and  recommends measures to improve environmental performance

The World Bank has 10 Environmental and Social Safeguard Policies (see Annex 2) to reduce or eliminate the adverse effects of development projects, and improve decision making. These operational policies include:

. OP/BP 4.01: Environmental Assessment . OP/BP 4.04: Natural Habitats . OP 4.09: Pest Management . OP/BP 4.12: Involuntary Resettlement . OD 4.20: Indigenous Peoples . OPN 11.03: Cultural Property . OP 4.36: Forests . OP/BP 4.37: Safety of Dams . OP/BP 7.50: Projects on International Waters . OP/BP 7.60: Projects in Disputed Areas

The proposed additional financing project triggered the environmental assessment policy.

This document i.e. the ESMF is the appropriate instrument prepared to address the triggered environmental assessment policy

OP 4.01 Environmental Assessment The objective of OP 4.01 is to ensure that projects financed by the Bank are environmentally and socially sustainable, and that the decision making process is improved through an appropriate analysis of the actions including their potential environmental impacts. Environmental Assessment (EA) is a process whose breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. EA takes into account the natural environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples, and cultural property); and trans-boundary and global environmental aspects.

OP 4.01 is triggered if a project is likely to present some risks and potential adverse environmental impacts in its area of influence. Thus, in the case of the HSDP II additional financing sub-projects, potential negative environmental and social impacts will be due to construction and rehabilitation activities linked to schools of nursing and mid-wifery.

CHAPTER FIVE: POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS

5.0 Potential Impacts The implementation of the proposed additional financing project will enhance the health and socio-economic development of the country through the facilitation of improved health care services and access to all.

The rehabilitation and refurbishment of schools of health technology and schools of Nursing and Midwifery, however, may cause negative environmental impacts. Poorly planned schools and bad practices in construction, maintenance and rehabilitation could have negative effects. Table 5.1; gives an overview of the major environmental impacts resulting from the construction and operation of health infrastructures (Schools of health technology, Nursing and Midwifery).

Table 5.1: Potential Environmental and Social Impacts of the HSDP II (Additional Financing) Project Environmental Parameters Impacts . Soil erosion and modification of surface relief . Sedimentation of roadside water bodies and drains Soil . Loss of productive topsoil in burrow areas . Contamination from waste materials e.g. cement, paints, lubricants, fuels and detergents . Modification in flow of surface water /increased runoff . Drainage clogging and creation of stagnant water pools Water . Contamination from hazardous wastes e.g. paints, lubricants, fuels . Sedimentation of surface water bodies . Damage, fragmentation or loss of habitat and biodiversity . Destruction of vegetation Ecosystem . Contamination of biota . Transmission of diseases . Destruction/disruption of wildlife . Threats to rare and endangered species Air . Air pollutants emission from construction machinery . Change in natural drainage pattern Landscape . Destruction of vegetation and trees . Deforestation and desertification . Transmission of diseases . Contamination of local water supplies Human health and safety . Air pollution . Noise & vibration disturbance . Obstructions owing to presence of road side barriers

5.1.1 Environmental Impacts

Construction Phase i Flora and Fauna

The rehabilitation/construction of new health inclined schools and/or the expansion and upgrading of existing schools could result in clearing and depletion of vegetation that will result in: loss of plant cover, disturbance and loss of fauna habitats, weakening and degradation of soils, disturbance of the natural landscape and disfiguring of the natural morphology. ii Soil and Land Degradation

Earth-moving equipment such as excavators will be used in cutting and excavation. This earth moving equipment will expose the soil to erosion and also compact it and break down the soil structure which will potentially decrease the drainage of the areas.

Furthermore, the risk of accidental discharge of hazardous products, leakage of hydrocarbons, oils or grease from construction machinery also constitute potential sources of soils and water pollution. Moreover, the high pressure on water resources can cause potential conflicts, particularly during the dry seasons in certain localities of high water scarcity in Kano and Kaduna States. iii Vehicular Traffic

Construction works will result in a high traffic volume around the schools and within the communities. Wastes generated from project activities such as cement bags, paint drums and debris will result in pollution and constitute obstructions to vehicular traffic.The transport of raw materials will introduce a number of heavy trucks on the access road and this could increase the risk of motor accidents and result in vehicular- pedestrian conflicts. iv Waste Management

Activities at construction sites will produce construction wastes such as excavated soils and debris. Excavated wastes could obstruct the general public, the movement of the workers and vehicles as well as affect the aesthetics of the environment. v Slope, Erosion and Drainage

If the topography of the project area is hilly, erosion problems during construction are likely to be more severe, as compared to a flat area. However, if the area is flat, water will not drain away easily, and stagnant pools of water will be created. These pools, if not drained regularly will provide favourable breeding grounds for mosquito and other disease vectors.

vi Air Quality

Air Quality will be impacted by emissions from vehicles, earthmoving equipment and released particulate matters. At the peak of construction; various equipment rated between 200-600 horsepower and burning diesel fuel will be operated.

vii Water Quality

Water quality will be impacted by wastewater discharges from construction activities. These will include discharges from onsite sewage system and rainwater run-off from the developed areas such as workshops etc. The discharge of this wastewater into surface waters will impact water quality by causing changes to its physical, chemical and biological properties.

Given the high anticipated volume of waste/spoil that will be generated, it is likely that the waste will be stockpiled on road sides. If it is not properly contained, rains could carry it along with runoff into other surface waters, leading to increased turbidity and siltation. This could affect aquatic resources such as fisheries and aquatic invertebrates.

Operation Phase i. Visual Intrusion

Health schools rehabilitation and construction will change the characters of the area (marred landscapes). The clearing of vegetation required for the expansion of existing school will impact the visual amenity of nearby houses and surrounding communities.

5.1.2 Social and Health Impacts

Construction Phase

i Loss of Livelihood

Land acquisition for construction of new schools could cause changes in land use pattern and result in displacement, especially in the urban areas. This will cause significant disruption to the communities as it could affect small businesses such as cafeterias, mechanic shops etc.

ii Disruption of Utilities Service

The excavation and cutting during construction may cause temporary disruptions of utility services such as electricity and water. Such disruptions may incur the anger of the communities in the project area.

iii Contractors’ (Workers) Camp

The civil work contractor will have to establish and operate a camp which will house offices, workshops etc. The selection of the camp location should be based on approval of the PPT project engineer.

Problems that may be encountered include disposal of liquid and solid wastes. Other social impacts associated with the contractors’ camp are theft, alcoholism and sexually transmitted diseases (especially HIV/AIDS).

iv Occupational Safety and Health

The safety of the local population may be at risk during construction activities. The movement of trucks to and from the site, the operation of various equipment and machinery and the actual construction activities will expose the workers to work- related accidents and injuries. Pollutants such as dust and noise could also have negative implications for the health of workers and near-by communities.

v Noise

Noise and vibration caused by machines, site vehicles, pneumatic drills etc will be commonplace during construction activities. These impacts can affect the quietness of the communities and provoke irritation and anger.

vi Traffic

Communities around the construction sites (where schools are being upgraded or constructed) will experience heavier human and vehicular traffic. Construction related activities will be a nuisance to road users e.g. storage of construction stones by the road side.

Operation Phase

i Improved access to education

The project implementation will improve access to quality basic education, especially for disadvantaged groups (e.g. girls, poor families). ii National Development

The impacts of the project on national development are largely positive. The implementation of the HSDP II will enhance the opportunities available for the general public in the participating states especially the rural areas. iii Road Accidents

The improvement of access and quality of the schools will translate into a higher pedestrian traffic (teachers, and students). This could increase the likelihood of road accidents.

iv Community Development

Positive impacts on community development would include enhancement of educational standards, diversification of knowledge notably in the scientific and technical fields, and improved access to formal education previously unavailable to a large number of rural communities.

Provision of socio-cultural infrastructures such as playgrounds and sports facilities will have beneficial impacts on the communities as well as contributing towards the reduction of delinquency.

5.2 Mitigation Environmental mitigation consists of measures that can reduce the negative environmental impacts associated with implementation (construction, expansion, rehabilitation etc) of the project.

5.2.1 Mitigation Measures

Mitigation measures have been identified that would reduce both existing and potential impacts associated with existing facilities and rehabilitation/upgrading/new construction on the proposed project. Potential impacts and related measures are identified in Table 5.2.

The table indicates the areas to which the potential impact and its associated measures apply. In addition, mitigation measures are identified as either social or physical measures. Social mitigation includes the measures used to mitigate effects such as noise, land use, and other effects to the human environment. Physical mitigation includes measures that address impacts to the physical environment, such as biological communities, vegetation, air quality, and others.

Table 5.2: Summary of Environmental Mitigation Measures Potential Impacts Recommended Mitigation Measures Physical Resources Land Use . Visual impact following the disposal of construction and demolition waste . Regular collection and evacuation of work site refuse towards authorized onto roadsides dumps . Involvement of the Local Government Authorities and Communities in the selection of discharge sites . Noise . Employees and communities exposed to high noise level . Installation of sound insulation. . Disturbance of school and education activities during construction works . Schedule work periods to avoid school hours

Air Quality . Emission of pollutants from mobile (vehicles) and stationary (mixers, . Introduction of dust reduction measures in construction sites generators etc) sources. . Safety measures put in place . Air pollution from burning of demolition wastes e.g. wood, paper etc

Soil . Point source contamination from diesel, lubricants etc around workshop . Appropriate containment measures for all operational areas and proper areas. disposal of used lubricants. . Increased soil erosion due to vegetation clearing , soil trampling and . Soil erosion control measures (e.g. reforestation, reseeding of grasses, compaction land preparation, terracing etc) . Increased rapid runoff due to vegetation clearing and soil compaction diminishing infiltration capacity . Deterioration of soil characteristics due to increased erosion

Water Quality . Potential pollution of surface and ground water though runoff of . Appropriate containment measures for all operational areas and proper pollutants e.g. lubricating oil, diesel fuel etc from workshop areas etc disposal of used lubrication oil. . Water pollution due to seepage from tanks (diesel, sanitary wastes etc) . Work sites Installed far from waterways . Lack of water for sanitation or toilet facilities . Regular collection of work sites wastes for proper disposal . Heavy water usage resulting in reduction of surface and groundwater . Liquid waste discharged at designated outfalls after effluent treatment to sources protect water resources . Regular emptying of on-site latrines and toilets

Potential Impacts Recommended Mitigation Measures Biological Resources Vegetation . Vegetation clearing resulting in loss of valuable habitat, species diversity . No siting and excavations in sensitive habitat and population levels. . Careful planning and selection of sites . Impacts on protected areas; critical habitats for rare species or of ecologic . Forests and cultural heritage sites protection enforced. or domestic importance. Wildlife . Wildlife impacted through direct loss, loss of movement corridors, and . Pre-construction focused surveys, dust and noise abatement measures, indirectly through introduction of noise and pollutants. and minimization of construction generated pollutants.

Wetlands . Expansion and new construction encroaching on the wetland and directly . Preservation, restoration, and enhancement of existing wetland. impact wetland plant communities. . Sensitive and critical habitats avoided

Farmlands and Grazing Areas . Land take for new school construction could lead to loss of farmland and . Farmland and grazing areas should be relocated to other areas. grazing areas. . If possible avoid farmlands and grazing areas.

Solid/Hazardous Waste Management . Solid waste generated from demolition and construction activities . Quick sorting, collection and disposal of waste removed from the sites in containing potentially hazardous materials (e.g. asbestos). accordance with applicable regulations. . Waste generation during building works piling on the roadside Social Health and Safety . Risks of road accidents during work . Conduct an awareness raising campaign for the work sites staff and the . Contamination risk by HIV from the labour force. users of school infrastructures (pupils, students, teachers, etc.) . Conduct awareness raising campaigns on HIV/AIDS Land Use . Involuntary displacement of populations or economic activities . Acquisition and relocation should occur in accordance with appropriate . Changes of existing uses within affected communities. regulations including World Bank OP/BP 4.12 Involuntary Resettlement. . Avoid facilities in areas that will need resettlement, the displacement; or the encroachment on historic, cultural or traditional use areas

5.2.2 Mitigation Funding

Cost of Design Measures

The quantities, specifications and estimated costs of design measures to avoid or mitigate negative impacts will be assessed by the civil design contractor and incorporated into the bidding documents. The contractor will execute all required works and will be reimbursed through pay items in the bill of quantities, which will be financed by the project.

HIV/AIDS Awareness Program

The quantities, specifications and estimated costs of the HIV/AIDS Awareness Program and condom distribution will be assessed by the design consultant and incorporated into the works bidding documents. The contractor will execute the program through a subcontractor and will be reimbursed through pay items in the bill of quantities, which will be financed by the project.

CHAPTER SIX: INSTITUTIONAL ARRANGEMENTS FOR ENVIRONMENTAL MANAGEMENT

The Institutional arrangements under the additional financing would be the same as for the original project, as they are generally working well. The one area where some changes will be made is with respect to monitoring and evaluation. State Ministries of Health (SMOH) would continue to be responsible for project management through the established state Project Implementation Units (PIUs).

LGAs are responsible for delivering basic health services in upgraded facilities supported under the project. The chief medical officer in the LGA is responsible for ensuring that each facility is operated according to standard procedures and guidelines. The Director of Health Planning and Research in the Federal Ministry of Health has the overall responsibility for the project, operating through the National Project Coordinating Unit (NPCU).

The NPCU monitors implementation of the federal component and provides assistance to states, as needed, to implement their respective work programs. It also consolidates annual work programs, reports and accounts. In order to improve the quality of the monitoring and evaluation functions, the NPCU will hire private firms to support the collection, analysis and reporting activities for the project. These firms would also provide guidance and technical assistance to the NPCU on how to effectively establish a functioning monitoring and evaluation system. The NPCU will organize semi-annual meetings of state health commissioners to review progress in project implementation. The National Project Steering Committee (NPSC) plays a critical role in enhancing management, monitoring progress, providing overall policy direction and coordination among various agencies. The World Bank will also explore methods for conducting supplemental supervision to the 15 States to better monitor implementation, evaluate impact and provide quality assurance.

With respect to the implementation of this Environmental and Social Management Framework (ESMF), it is recommended that each state PIU recruits an environmental and social specialist on a consultant on part time basis that will be responsible for following up the recommendations of the ESMF and site specific EIAs. Since there is just one sub- project i.e. rehabilitation of schools (Health technology, Nursing and Midwifery), there is no need for a screening mechanism, as the mitigations measures contained in the report suffices.

The chances of preparing a full EIA under this project is very remote due to the small and site specific nature of the impacts. However, site specific EIA might occur and therefore the state PIU would be responsible for preparing the EIAs before implementation.

Details of the capacity of the SEPAs would be addressed in the EIAs. A typical TOR for an EIA/ESIA is shown on Annex 3. It is also important that all bidding documents and final contracts contain the general environmental and social management clause (see

Annex 4). This is to tie the contractor to respect environmental and social concerns during civil works.

Capacity building in environmental management is also essential during project implementation. The objectives of the training/capacity building efforts under proposed additional financing project will be to:  Support the PIUs to mainstream environmental and social issues in their sub- projects; and  Strengthen the capacity of local NGOs and other services providers to provide technical support to communities in environmental and social aspects of the sub-projects. The target audience for training, sensitization and capacity building, will inter-alia include the following:  Project Coordinators  Project Teams  LGAs Staff involved in environmental and social concerns  Environment consultant (s) at the PIU  NGO’s/CBOs in the health sector  State Environmental Protection Agencies/Authorities

The training will follow the program in table 6.1 below:

Table 6.1 Institutional Capacity Strengthening Program

Target Audience Description Application Duration Project General environmental awareness Personnel require appreciation of Three days coordinators/teams seminar that will include WB’s, Federal/State environmental seminar ecological and social science policies, as well as, an appreciation principles, legal responsibilities, for the need to support consequences of non-sustainable environmentally sustainable development, costs of poor development. environmental decisions, and introduction to the EIA process and the use of the environment and social screening mechanism.

Environmental An in-depth comprehensive course The target audience will be Five days specialist/consultant, on environmental management responsible for EA review at the workshop officials of SEPAs including legal requirements, EIA State level and for preparing TORs and LGA methodology, for EIA consultants as well as environmental and monitoring consultants’ work and social specialists Impact determination (methods) final approval of EIAs. Target and mitigation analysis, public audience will also be responsible involvement methods, ESMP for conducting environmental preparation, monitoring audits on selected sub-projects and techniques, preparation of EIAs, for periodic monitoring of sub- TORs, and other. Course will project implementation to ensure include field visits and classroom compliance. exercises.

CBOs/NGOs in the General environmental awareness NGOs/CBOs require an One day health sector seminar that will include appreciation for the WB’s and ecological and social science Nigerian environmental

principles and introduction to the requirements/procedures. EIA process.

The cost estimates are based on the assumption that resource persons are likely to come from other parts of the country and therefore require travel allowances; participants will come from local communities and attend during the day only but will receive a per diem. These estimates include an allowance for travel expenses.

The total cost is estimated at a lump sum US $ 150,000

CHAPTER SEVEN: PUBLIC CONSULTATION PLAN

The different PIUs have responsibilities to effectively engage stakeholders in achieving the project objectives for the benefit of all. The implementation of the HSDP II depends on the meaningful participation of all stakeholders for success.

7.1 Objectives This plan provides a framework for achieving effective stakeholder involvement and promoting greater awareness and understanding of issues so that the project is carried out effectively within budget and on-time to the satisfaction of all concerned. To ensure effective implementation of this plan, the PIU shall be committed to the following principles:

 promoting openness and communication;  ensuring effective stakeholder involvement in the development of the project;  increasing public knowledge and understanding of the project implementation process;  using all strategies and techniques which provide appropriate, timely and adequate opportunities for all stakeholders to participate; and  evaluating the effectiveness of the engagement plan in accordance with the expected outcomes.

7.2 Identifying Stakeholders Stakeholders for the purpose of this project shall be defined as all those people and institutions that have an interest in the successful planning and execution of the project. This includes those likely to be positively and negatively affected by the project. Table 7.1 identifies the key stakeholders.

Table 7.1: Stakeholder Identification Matrix Affected Parties How to identify them People living in the vicinity of the proposed  Identify the local government area(s) that falls within works. (students, teachers, parents etc) 500m radius of the proposed schools.  Review available data to determine the profile of the whole stakeholder or relevant group.  Use identified groups and individuals to tap into stakeholder networks to identify others. Special interest groups  Identify key individuals or groups through organized groups, local clubs, community halls and religious places.  Be aware of similar local groups or individuals.

7.3 Consultation Strategies The consultation process shall ensure that all those identified as stakeholders are conferred with. Subject to PIU coordinator’s approval, the Environmental/Social consultant will share information about the project with the public to enable meaningful contributions and thus enhance the success of the project

Public consultation will take place through workshops, seminars, meetings, radio programs, request for written proposals/comments, questionnaire administration, public reading and explanation of project ideas and requirements

ANNEX 1: LIST OF PERSONS MET

1. Dr Jamilu Yankwashi Project Manager, HSDP II Abuja 2. Mr Shaibu Asuku Project Accountant, HSDP II Abuja 3. Mr Ihijaru Mohammed EDP Manager, HSDP II Abuja 4. Mrs Abdullai Awawo Project Accountant, HSDP II Abuja 5. Mrs Suliat Abdullai Procurement Officer, HSDP II Abuja

6. Dr R.O. Ngrigu Project Manager, HSDP II Anambra. 7 Pharmacist Ogukwe EDP Manager, HSDP II Anambra 8 Mr F.C. Onuchukwu Project Accountant, HSDP II Anambra 9. Mr Sylvester Ezeanhue Procurement Officer, HSDP II Anambra 10. Mrs Amaka Okoye Training Officer, HSDP II Anambra 11. Mr I.C. Chukwuchibem Assistant Project Accountant, HSDP II Anambra

12. Mrs E. Nnaji Project Manager HSDP II Enugu 13. Mr E.E. Edoga EDP Manager, HSDP II Enugu. 14. Mr Martin Ozor Training/Admin Officer HSDP II , Enugu. 15. Mr F.O. Obodo Project Accountant HSDP II Enugu 16 Mr Emma Njoku Procurement Officer HSDP II Enugu. 17. Mr F.C. Okeh Internal Audit HSDP II Enugu. 18 Mr Laz Nwosu HMIS Officer, HSDP II Enugu

19 Alhaji Ibrahim Hussaini Project Manager HSDP II Sokoto 20. Mr. Mohammed Aliyu Project Accountant, HSDP II Sokoto 21. Mr. Shehu Garba Procurement Officer, HSDP II Sokoto 22. Mr. Usman Mohammed Auyalo Project Quantity Surveyor, HSDP II, Sokoto 23. Mr Murtalla Bello EDP Manager, HSDP II Sokoto 24. Mr Aminu Sokoto Internal Auditor, HSDP II Sokoto 25. Mr Faruk Abubakar Wuhor Training Officer, HSDP II Sokoto

26. Mr Ibrahim Madawaki Project Cashier, HSDP II Sokoto 27. Mr Bello Mohammed Wammako Project Store Officer, HSDP II, Sokoto 28. Mallam Umar Mohammed Deputy Project Accountant 29. Mallam Umar M. Wali Managing Director, Sokoto State Environmental Protection Agency (SEPA)

ANNEX 2: SUMMARY OF WORLD BANK ENVIRONMENTAL AND SOCIAL SAFEGUARD POLICIES.

 Environmental Assessment (OP 4.01). Outlines Bank policy and procedure for the environmental assessment of Bank lending operations. The Bank undertakes environmental screening of each proposed project to determine the appropriate extent and type of EA process. This environmental process will apply to all sub-projects to be funded by the proposed project.

 Natural Habitats (OP 4.04). The conservation of natural habitats, like other measures that protect and enhance the environment, is essential for long-term sustainable development. The Bank does not support projects involving the significant conversion of natural habitats unless there are no feasible alternatives for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs. If the environmental assessment indicates that a project would significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to the Bank. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g. strategic habitat retention and post-development restoration) and establishing and maintaining an ecologically similar protected area. The Bank accepts other forms of mitigation measures only when they are technically justified. Should the sub-project-specific EMPs indicate that natural habitats might be affected negatively by the proposed sub- project activities with suitable mitigation measures, such sub-projects will not be funded under this project

 Pest Management (OP 4.09). The policy supports safe, affective, and environmentally sound pest management. It promotes the use of biological and environmental control methods. An assessment is made of the capacity of the country’s regulatory framework and institutions to promote and support safe, effective, and environmentally sound pest management. This policy was not triggered by the proposed project.

 Involuntary Resettlement (OP 4.12). This policy covers direct economic and social impacts that both result from Bank-assisted investment projects, and are caused by (a) the involuntary taking of land resulting in (i) relocation or loss of shelter; (ii) loss of assets or access to assets, or (iii) loss of income sources or means of livelihood, whether or not the affected persons must move to another location; or (b) the involuntary restriction of access to legally designated parks and protected areas resulting in adverse impacts on the livelihoods of the displaced persons. The project did not trigger this policy.

 Indigenous Peoples (OD 4.20). This directive provides guidance to ensure that indigenous peoples benefit from development projects, and to avoid or mitigate adverse effects of Bank-financed development projects on indigenous peoples.

Measures to address issues pertaining to indigenous peoples must be based on the informed participation of the indigenous people themselves. Sub-projects that would have negative impacts on indigenous people will not be funded under the proposed project.

 Forests (OP 4.36). This policy applies to the following types of Bank-financed investment projects: (a) projects that have or may have impacts on the health and quality of forests; (b) projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests; and (c) projects that aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned. The Bank does not finance projects that, in its opinion, would involve significant conversion or degradation of critical forest areas or related critical habitats. If a project involves the significant conversion or degradation of natural forests or related natural habitats that the Bank determines are not critical, and the Bank determines that there are no feasible alternatives to the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs, the Bank may finance the project provided that it incorporates appropriate mitigation measures. Sub-projects with likelihood of having negative impacts on forests will not be funded under the project.

 Cultural Property (OPN 11.03). The term “cultural property” includes sites having archaeological (prehistoric), paleontological, historical, religious, and unique natural values. The Bank’s general policy regarding cultural property is to assist in their preservation, and to seek to avoid their elimination. Specifically, the Bank (i) normally declines to finance projects that will significantly damage non-replicable cultural property, and will assist only those projects that are sited or designed so as to prevent such damage; and (ii) will assist in the protection and enhancement of cultural properties encountered in Bank-financed projects, rather than leaving that protection to chance. The management of cultural property of a country is the responsibility of the government. The government’s attention should be drawn specifically to what is known about the cultural property aspects of the proposed project site and appropriate agencies, NGOs, or university departments should be consulted; if there are any questions concerning cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist. The proposed project will not fund sub-projects that will have negative impacts on cultural property.

 Safety of Dams (OP 4.37). For the life of any dam, the owner is responsible for ensuring that appropriate measures are taken and sufficient resources provided for the safety to the dam, irrespective of its funding sources or construction status. The Bank distinguishes between small and large dams. Small dams are normally less than 15 m in height; this category includes, for example, farm ponds, local silt retention dams, and low embankment tanks. For small dams, generic dam safety measures designed by qualified engineers are usually adequate. This policy does not apply to the proposed project.

 Projects on International Waterways (O 7.50). The Bank recognizes that the cooperation and good will of riparians is essential for the efficient utilization and protection of international waterways and attaches great importance to riparians making appropriate agreements or arrangement for the entire waterway or any part thereof. Projects that trigger this policy include hydroelectric, irrigation, flood control, navigation, drainage, water and sewerage, industrial, and similar projects that involve the use or potential pollution of international waterways. The proposed project did not triggered this policy

 Disputed Areas (OP/BP/GP 7.60). Project in disputed areas may occur in the Bank and its member countries as well as between the borrower and one or more neighbouring countries. Any dispute over an area in which a proposed project is located requires formal procedures at the earliest possible stage. The Bank attempts to acquire assurance that it may proceed with a project in a disputed area if the governments concerned agree that, pending the settlement of the dispute, the project proposed can go forward without prejudice to the claims of the country having a dispute. This policy is not expected to be triggered by sub-projects. This policy is unlikely to be triggered by sub-projects to be funded by this project.

ANNEX 3: DRAFT EIA /ESIA TERMS OF REFERENCE

Introduction and context This part will be completed in time and will include necessary information related to the context and methodology to carry out the study.

Objectives of study This section will indicate (i) the objectives and the project activities; (ii) the activities that may cause environmental and social negative impacts and needing adequate mitigation measures.

Tasks The consultant should realize the following:  Describe the biophysical characteristics of the environment where the project activities will be undertaken; and underline the main constraints that need to be taken into account at the field preparation, during the implementation and exploitation/maintenance of equipments.  Assess the potential environmental and social impacts related to project activities and recommend adequate mitigation measures, including costs estimation..  Review political, legal and institutional framework, at national and international level, related to environmental, identify the constraints and suggest recommendations for reinforcement  Identify responsibilities and actors for the implementation of proposed mitigation measures  Assess the capacity available to implement the proposed mitigation measures, and suggest recommendation in terms of training and capacity building, and estimate their costs.  Develop a Environmental Management Plan (EMP) for the project. The EMP should underline (i) the potential environmental and social impacts resulting from project activities (ii) the proposed mitigation measures; (iii) the institutional responsibilities for implementation; (iv) the monitoring indicators; (v) the institutional responsibilities for monitoring and implementation of mitigation measures; (vi) the costs of activities; and (vii) the calendar of implementation.  Public consultations. The EIA/ESIA results and the proposed mitigation measures will be discussed with population, NGOs, local administration and other organisations mainly involved by the project activities. Recommendations from this public consultation will be include in the final EIA or ESIA report.

Plan of the EIA report - Cover page - Table of contents - List of acronyms - Executive summary - Introduction

- Description of project activities - Description of environment in the project area - Description of political, legal and institutional framework - Description of methodology and techniques used in assessment and analyse of project impacts. - Description of environmental and social impacts for project activities - Environmental Management Plan (EMP) for the project including the proposed mitigation measures; the institutional responsibilities for implementation; the monitoring indicators; the institutional responsibilities for monitoring and implementation of mitigation; Summarized table for EMP - Recommendations - List of persons / institutions meet

Duration of study The duration of study will be determined according to the type of activity

Production of final report The consultant will produce the final report one (1) week after receiving comments from the World Bank, SEPAs/FMEH & UD (Impact Monitoring Unit) and the PIU. The report will include all the comments from all.

Supervision of study The consultancy will be supervised by the Environmental consultant attached to the PIU.

ANNEX 4: CONTRACT PROVISIONS: ENVIRONMENTAL AND SOCIAL IMPACTS

1. General Provisions and Precautions

The contractor shall all necessary measure and precautions and otherwise ensures that the execution of the works and all associated operations on the work sites or off site are carried out in conformity with statutory and regulatory environmental requirement of Nigeria. The contractor shall take all measures and precautions to avoid any nuisance or disturbance arising from the execution of the work. This shall, wherever possible, be achieved by suppression of the nuisance at source rather than abatement of the nuisance once generated. In the event of any soil or debris or silt from the work sites being deposited on any adjacent land, the contractor shall immediately remove all such spoil debris or silt and restore the affected area to its original state to the satisfaction of the responsible authorities.

2. Water Quality

The following conditions shall apply to avoid adverse impacts to water quality:

 The contractor shall prevent any interference with supply to, or abstraction from, water resources and the pollution of water resources (including underground percolating water) as a result of the execution of the works.  The contractor shall not discharge or deposit any matter arising from the execution of the work into any waters except with the permission of the contractor and regulatory authorities concerned.  The contractor shall at all times ensure that all existing stream courses and drains within and adjacent to the site are kept safe and free from any debris and any material arising from the works.  The contractor shall protect all water courses, waterways, ditches, canals, drains, lakes and the like from pollution, silting, flooding or erosion as a result of the execution of the works.

3. Air Quality

The following conditions shall apply to avoid adverse impacts to air quality:

 Open burning will be prohibited.  Blasting (If any) will be carried out using small charges, and dust – generating items will be conveyed under cover.

 In periods of high wind, dust- generating operations shall not be permitted within 200 meters of residential areas having regard to the prevailing direction of the wind.  Asphalts and hot- mix plants sites shall not be established prior to the approval of the contractor and shall be located at least 500 meters away from the nearest sensitive receptor(e.g. ,schools and hospitals ).Operators will be required to install emission controls.  Water sprays shall be used during the delivery and handling of materials when dust is likely to be created and to dampen stored materials during dry and windy weather.  Stockpiles of materials shall be sited in sheltered areas or within hoarding, away from sensitive areas. Stockpiles of friable material shall be covered with tarpaulins. With application of sprayed water during dry and windy weather. Stockpiles of material or debris shall be dampened prior to their movement whenever warranted.  Vehicle with an open load – carrying area used for transporting potentially dust- producing material shall have proper fitting side and tailboards. Materials having the potential to produce dust shall not be loaded to a level higher than the side and tail boards, and shall be covered with a clean tarpaulin in good condition. The tarpaulin shall be properly secured and extend over the edges of the side and tailboards.  In periods of adverse weather adverse impacts to adjacent residents or site employees during construction will be mitigated by either discontinuing until favourable conditions are restored, or, if warranted, sites may be watered to prevent dust generation, particularly at crushing plants.  Machinery and equipment will be fitted with pollution control devices, which will be checked at regular intervals to ensure that they are in working order. Best available pollution control technologies will be used

4. Protection of soils

Borrow pits. The following conditions shall apply to borrow pits:

 Borrow areas will be located outside the ROWs.  Pit restoration will follow the completion of works in full compliance all applicable standards and specification.  The excavation and restoration o f the borrow areas and their surroundings, in an environmentally sound manner to the satisfaction of the contractor is required before final acceptance and payment under the terms of contracts.  Borrow pit areas will be graded to ensure drainage and visual uniformity, or to create permanent tanks\dams.  Topsoil from borrow pit areas will be saved and reused in re-vegetating the pits to the satisfaction of the contractor.

 Additional borrow pits will not be opened without the restoration of those areas no longer in use.

Quarries. To ensure adequate mitigation of potential adverse impacts, only licensed quarrying operations are to be used for material sources. If licensed quarries are not available the contractors may be made responsible for setting up their dedicated crusher plants at approved quarry sites.

Erosion. To avoid potential adverse impacts due to erosion, the contractor shall:

 Line spillage ways with riprap to prevent undercutting.  Provide mitigation plantings and fencing where necessary to stabilize the soil and reduce erosion.  Upgrade and adequately size, line and contour storm drainage to minimize erosion potential.  To avoid erosion and gullying of road formations, the contractor should reduce his earthworks during the peak of rainy seasons, use gabions and miter drains and avoid angle termination at the intersections of cuts and fills.  As noted in elsewhere in these specifications, ditches shall be designed for the toe of slopes in cut sections with gutters or drainage chutes being employed to carry water down slopes to prevent erosion. Interceptor ditches shall be designed and constructed near the top of the back of slopes or on benches in the cut slopes as well as when there is a slope on adjacent ground toward the fill. When the roadway has a steep longitudinal slope, a drain is to be designed and constructed at the down – slope end of the cut to intercept longitudinal flow and carry it safely away from the fill slopes.

5. Avoidance of Social Impacts

To avoid adverse social impacts, the Contractor shall:

 Coordinate all construction activities with neighboring land uses and respect the rights of local landowner. If located outside the ROW, written agreements with local landowners for temporary use of the property will be required and sites must be restored to a level acceptable to the owner within a predetermined time period.  Maintain and cleanup campsites.  Attend to health and safety of their worker by providing basic emergency health facilities for workers and incorporate programs aimed at the prevention of sexually transmitted diseases as a part of all construction employee orientation programs.  Obtain approval of all diversions and accommodation of traffic. A stipulated by section- which states that “the Contractor shall provide the contractor with a written traffic control plan which is to include when and where flagmen shall be employed and when and where traffic cones or

other devices such as barricades and \or lights will be used. Where ….traffic diversions area planned for ….additional areas (will) be determined and the diversions clearly defined for travel.”

 Construct and maintain by – passes around bridges to be reconstructed until such time as the bridge is open for traffic. By- passes will be removed and the affected areas re-graded so as to blend in with the existing contour when the bridge is opened.

6. Noise

To avoid adverse impacts due to noise, the contractor shall:

 Consider noise as an environmental constraint in his planning and execution of the works.  Use equipment conforming to international standards and directives on noise and vibration emissions.  Take all necessary measures to ensure that the operation of all mechanical equipment and construction processes on and off the site shall not cause any unnecessary or excessive noise, taking into account applicable environmental requirements.  Maintain exhaust systems in good working order; properly design engine enclosures, use intake silencers where appropriate and regularly regular maintain noise –generating equipment.  Use all necessary measures and shall maintain plant and silencing equipment in good condition so as to minimize the noise emission during construction works.  Schedule operations to coincide with periods when people would least likely be affected and by the contractor having due regard for possible noise disturbance to the local residents or other activities. Construction activities will be strictly prohibited between 10PM and 6PM.  Incorporate noise considerations in public notification of construction operations and specify methods to handle complaints. Disposal sites and routes will be coordinated with local officials to avoid adverse traffic noise.

7. Protection of Historic and Cultural resources

To avoid potential adverse impacts to historic and cultural resources, the contractor shall; in the event of unanticipated discoveries of cultural or historic artifacts (movable or Immovable) in the course of the work, the sub-contractor shall take all necessary measures to protect the findings and shall notify the contractor and provincial- level representatives of the Archaeological committee under the ministry of Information and culture. If continuation of the work would endanger the finding, project work shall be suspended until a solution for preservation of the artifacts is agreed upon.

8. Protection of Utilities

To avoid potential adverse impacts to utilities, the Contractor shall:

 Ascertain and take into account in his method of working the presence of utility services on and in the vicinity of the site.  Take into account in his programme the periods required to locate, access, protect, support and divert such services, including any periods of notice required to effect such work in consultation with authorities operating such services.  Assume all responsibility to locate or to confirm the details and location of all utility services on or in the vicinity of the site.  Exercise the greatest care at all times to avoid damage to or interference with services.  Assume responsibility for any damage and \or interference caused by him or his agents, directly or indirectly, arising from actions taken or a failure to take action, and for full restoration of the damage.

9. Waste Disposal and Hazardous materials

Water and waste products shall be collected, removed via suitable and properly designed temporary drainage systems and disposed of at a location and in a manner that will cause neither pollution nor nuisance. Insofar as possible, all temporary construction facilities will be located at least 50 metres away from a water course, stream or canal.

The contractor shall not dispose of used pavement material on the road or highway side, nor in water courses or wetlands. Such material shall be utilized or disposed of in places approved by the CSC.

Whenever large amounts of asphaltic concrete are to be removed from a highway, the material should be reused or disposed of by burial to a minimum of one meter depth. The contractor shall not dispose of any surplus material on private land unless authorized by in writing by the owner(s), authenticated before a notary public, and with previous authorization of the CSC.

10. Environmental monitoring

Monitoring or direct impact will be carried out by the CSC and will include, but not restricted to, the following concerns:  Erosion along highway segments and borrow sites during and after construction;  Silting and increased sediment loads to streams crossed by the highway.  Prevention of damage to undiscovered significant archeological or historical findings;  Verification that proper waste disposal at construction sites and road camps is done;

50 Earthguards Limited Environmental and Social Management Framework of Health System Development Project II – Additional Financing

 Assurance that construction sites and road camps are cleaned after construction and  Inspection of vegetation covers (removal and re- growth) on the basis of field examinations.

51 Earthguards Limited