Initial Environmental Examination
Project Number: 46346-003 Date: August 2020
Republic of the Marshall Islands: Additional Financing of Ebeye Water Supply and Sanitation Project
Prepared by the Kwajalein Atoll Joint Utility Resources, Inc. (KAJUR) for the Asian Development Bank.
This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section of this website.
In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does intend to make any judgments as to the legal or other status of any territory or area.
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CONTENTS
ABBREVIATIONS AND ACRONYMS ...... v EXECUTIVE SUMMARY ...... vii I. INTRODUCTION ...... 12 II. POLICY, LEGAL AND ADMINISTRATION FRAMEWORK ...... 15 A. National and Local Legal Framework ...... 15 B. ADB Safeguard Policies ...... 17 III. DESCRIPTION OF THE PROJECT ...... 18 IV. DESCRIPTION OF ENVIRONMENT ...... 20 A. Physical Environment ...... 20 1. Climate ...... 20 2. Climate Change ...... Error! Bookmark not defined. 3. Geology and Geomorphology ...... 24 4. Soils ...... Error! Bookmark not defined. 5. Freshwater Resources ...... 25 6. Air Quality ...... 25 B. Ecological Environment ...... 26 1. Terrestrial Flora and Fauna ...... 26 2. Threatened, Rare, or Protected Species...... 26 C. Social Environment ...... 26 1. Socioeconomic Environment ...... 26 2. Population ...... 27 3. Ethnography ...... 28 4. Land Ownership and Use ...... 28 5. Education ...... 28 6. Poverty ...... 29 8. Noise ...... 29 9. Traffic ...... 30 10. Public Health ...... 30 V. ANALYSIS OF ALTERNATIVES ...... 33 A. No Project Alternative ...... 33 B. Discussion of Alternative Solutions ...... 33 VI. ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES .... 33
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A. Design and Pre-construction Impacts ...... 33 1. Impacts on Physical Resources ...... 33 2. Impacts on Ecological Resources ...... 34 3. Impacts on Socio-economic Resources...... 35 B. Construction Impacts ...... 36 1. Impacts on Physical Resources ...... 36 2. Impacts on Ecological Resources ...... 37 3. Impacts on Socio-economic Resources...... 37 C. Operation Impacts ...... 40 VII. INFORMATION DISCLOSURE AND PUBLIC CONSULTATIONS ...... 42 A. Legislative Framework for Public Consultation ...... 42 B. Public Consultation Activities ...... 42 VIII. GRIEVANCE REDRESS MECHANISM ...... 43 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 45 X. MONITORING AND REPORTING ...... 0 XI. CONCLUSION AND RECOMMENDATIONS ...... 0 BIBLOGRAPHY ...... 0
TABLES
Table 1: Project Steering Committee Recommendations ...... Error! Bookmark not defined. Table 2: Environmental agency consultations findings ...... 43 Table 3: Summary of environmental management responsibilities in the Project ...... 46 Table 4: Environmental Mitigation and Monitoring Plan of household fixtures program by reducing household water wastage from faulty plumbing fixtures ...... 0
FIGURES Figure 1- Ebeye Location Map ...... 12 Figure 2: Average Mean Temperature at Kwajalein ...... 20 Figure 3: Kwajalein Annual Rainfall ...... 21 Figure 4: ENSO Events and Impacts on Rainfall and Temperature ...... 23 Figure 5: Pacific North Equatorial Current (NEC) ...... 25 Figure 6: Key Natural and Human Induced Hazards ...... 27 Figure 7: Goals of the National Health Strategy 2012-2014...... 31 Figure 8: Ebeye Dumpsite Conditions ...... 32 Figure 9: Ebeye Dumpsite Location ...... 32
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ABBREVIATIONS
ADB - Asian Development Bank BNPL - Basic Needs Poverty Line CA - Conservation Area CEMP - Contractor Environmental Management Plan EA - Environmental Assessment EIA - Environmental Impact Assessment ENSO - El Niño Southern Oscillation EIS - Environmental Impact Statement EMP - Environmental Management Plan ESS - Environmental Safeguards Specialist GRM - Grievance Redress Mechanism IEE - Initial Environmental Examination JNAP - Joint National Action Plan for Climate Change Adaptation and Disaster Risk Management 2014-2018 KAJUR - Kwajalein Atoll Joint Utilities Resources Inc. KALGov - Kwajalein Atoll Local Government NEPA - National Environmental Protection Act 1984 NSS - National Safeguards Specialist OCS - Office of Chief Secretary PPE - Personal Protective Equipment PIA - Project Implementation Assistance PMU - Project Management Unit RP - Resettlement Plan RMIEPA - Republic of Marshall Islands Environmental Protection Authority SIDS - Small Island Developing States SPS - Safeguards Policy Statement, 2009 SSS - Social Safeguards/Resettlement Specialist STP - Sewage Treatment Plant SWRO - Saltwater Reverse Osmosis TFSDR - Toilet Facilities and Sewage Disposal Regulations WWTP - Wastewater Treatment Plant
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WEIGHTS AND MEASURES
dB – decibels gpcd – gallons per capita per day ha – hectare km – kilometer km2 – square kilometer lpcd – liters per capita per day m – meter 2 m – square meter 3 m – cubic meter m3/d – cubic meters per day m3/s – cubic meters per second mg/m3 – milligrams per cubic meter mm – millimeter
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EXECUTIVE SUMMARY
On 28 September 2015, ADB approved a project grant for the administration of the Ebeye Water Supply and Sanitation Project (EWSSP). The project impact will be reduced incidence of waterborne disease on Ebeye and the project outcome will be improved access to safe water and improved sanitation. The Project has five outputs: (i) secure and safe freshwater supplies; (ii) effective and efficient sewerage services; (iii) enhanced hygiene awareness and improved hygiene behaviors; (iv) secure electricity supply for water and sewerage operations; and (v) financial and technically sustainability of the Kwajalein Atoll Joint Utility Resources Inc. (KAJUR). The project was declared effective on 3 December 2015 and is scheduled to close on 30 June 2022. Substantial progress has been made towards delivering the project’s impact, outcome, and outputs. However, further assistance is required to ensure that the Project remains sustainable.
The additional financing will support the operation and maintenance to ensure the sustainability of the current project and improve water supply and hygiene behaviors essential to prevent the transmission of the coronavirus disease (COVID-19).
This initial environmental examination (IEE) has been prepared to assess the potential environmental impacts and appropriate mitigation measures for the replacement of existing, and installation of new, water, sewerage, and electrical power infrastructure in Ebeye, Republic of Marshall Islands (RMI). The IEE has been prepared in accordance with the requirements of the Asian Development Bank (ADB) Safeguard Policy Statement 2009 (SPS) and conforms to environmental assessment requirements defined in the RMI National Environmental Protection Act 1984 (NEPA). Chapter 1 NEPA contains a set of regulations for protection of surface and marine waters, air quality, and managing of potential impacts from earth works, sanitation systems, waste, and new infrastructure development. These regulations provide the framework for protection of resources and environmentally sustainable development in Ebeye and are directly applicable to this project.
Background. Ebeye, an islet in the Kwajalein Atoll has a significantly altered terrestrial environment, consisting almost entirely of built environment. The terrestrial and near-shore marine environments, and water quality, have been negatively impacted by inadequate sewerage collection and treatment, inadequate storm water management, and extensive sand and coral dredging on the near shore reef.
In 2015 to 2020, works were undertaken for water, wastewater, and electrical subprojects including: (i) Water Supply Improvements (a) installing a new 420,000 gallons/day (1.58MLD) treatment plant which will provide all residents with an average of 28 gpcd (105 Lpcd) of clean water; (b) constructing a new freshwater pumping station; (c) installing a new 25,000 gallons (100m3) capacity reinforced concrete or steel elevated freshwater tank; (d) constructing a brine outfall 164 ft (50m) in length to dispose of brine effluent from the treatment plant (if this option is decided by the project); (e) upgrading 1120 ft (330m) of water distribution pipeline from 6-inch (150mm) to 8-inch (200mm) diameter; (f) installing new water supply distribution pipelines to supply unserved residents; (g) installing bulk meters at appropriate locations; (h) installing up to 800 new service connections; and
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(i) replacing existing corroded fire hydrants with 62 standpipes and providing a fire truck. (ii) Wastewater System and Sanitation Improvements (a) constructing a new 12-inch (300mm) diameter HDPE outfall 1150 ft (350m) in length on the lagoon side of the island to terminate with a diffuser at a depth of 98 feet (30m) depth; (b) constructing four new submersible pumping stations; (c) installing 6mm fine screens at the junction manhole prior to discharging through the ocean outfall; (d) rehabilitating 1475 ft (450m) of existing sewer pipeline; (e) constructing 980 ft (300m) of 8-inch (200mm) sewer pipeline and 650 ft (200m) of 6-inch (150 mm) sewer pipeline to provide sewerage service to all residents; (f) repairing/replacing 1650 ft (500m) of saltwater flushing pipelines; (g) repairing/replacing 880 saltwater flushing house connections; (h) rehabilitating and/or replacing 120 manholes; and (i) constructing a new 12,500 gal (50 m3) reinforced concrete elevated reservoir for saltwater toilet flushing. (iii) Electrical System Improvements (a) replacing existing high voltage busbars and protection; (b) replacing existing high voltage switchgear; (c) installing a power plant data monitoring system; (d) replacing all existing wooden power poles; and (e) installing three-phase cash power meters.
Project Description. This additional financing will further strengthen KAJUR’s financial and technical capacity for sustainable delivery of water supply and sewerage services on Ebeye which are critical for improve hygiene behaviors and to eliminate the transmission of COVID-19 and other waterborne and contract transmissible diseases. The project’s target impacts will remain unchanged and outputs will be strengthened. The additional financing will support: (i) Output 1 – secure and safe freshwater supplies ensured. The sustainability of KAJUR’s water supply operations will be strengthened by: (a) extending the desalination plant design-build-operate contract for provision of remote monitoring and operation and maintenance support for 2 years to strengthen the operations and maintenance capacity of KAJUR desalination plant personnel; and (b) upgrading the desalination plant by providing anti-corrosion protection treatment to pipes and equipment, minor structural improvements, and provisions of 440 kVA backup generator. (ii) Output 2 – effective and efficient sewerage services provided. The scope of Output 2 will be expanded to review and recommend improvements to onsite sanitation treatment systems in the communities of Loi and Ebwaj (approximately 50 households or 320 people) which on the islets on causeway which links Ebeye and Guegeegue. Investments identified by the review will be implemented under future projects. (iii) Output 5 – financial and technical sustainability of KAJUR. Additional activities to be delivered under output 5 include: (a) further strengthening of KAJUR’s financial management capacity by extending the services of KAJUR’s financial management advisor through intermittent inputs (3 weeks every quarter) over 2 years. The services of the financial management advisor will be particularly important during the initial implementation of KAJUR’s new water and sewerage tariff framework;
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(b) strengthening the capacity of KAJUR water personnel to optimize freshwater and saltwater network operations and minimize system losses. Capacity will be strengthened by the provision of water distribution specialist to provide on-the- job training provided intermittently (12 weeks per year) over 2 years; (c) provision of a technical advisor on an intermittent basis (12 weeks per year) over 2 years to assist strengthen KAJUR’s capital works planning and to further strengthen KAJUR’s project management capacity; (d) extension of the EWSSP household fixtures program for 2 years to enhance demand management by reducing household water wastage from faulty plumbing fixtures and to ensure the poorest households on Ebeye can access to safe water and improved sanitation; and (e) to ensure the poorest households on Ebeye can access to safe water and improved sanitation.
The project will continue to build upon the previous upgrades for affordable water, sanitation, and power services for Ebeye. The project will continue to improve the health and safety of the resident population currently experiencing contamination from sewage, with the project improving water supply and supporting the ongoing development of the capacity of the Kwajalein Atoll Joint Utilities Resources (KAJUR) and Ebeye/Kwajalein Atoll Local Government (KALGov) to manage and monitor environmental performance of the water and sanitation systems.
Categorization. The project's anticipated environmental impacts are classified as Category B under the SPS. Such projects are judged to be site-specific, have some adverse environmental impacts, but to a lesser degree, or significance, than those for category A projects. The IEE, and accompanying environmental management plan (EMP), will be updated at the detailed design phase by the project management unit (PMU) responsible for implementing the project.
Assessment of Impacts. The proposed works are assessed as having minimal and site- specific impacts on the significantly altered terrestrial environment, which consists almost entirely of built environment. Project works will bring significant positive impacts to the Ebeye community with the improvements in the water and wastewater operations. These improvements are expected to have flow on social and ecological benefits in improved public health, and improved water quality.
Impacts are minor and will be related to the earthworks associated with works to reduce household water wastage from faulty plumbing fixtures to ensure the poorest households on Ebeye can access to safe water.
Overall, the environmental benefits of the project are significant. The project will continue on previous works to develop an efficient, effective, and affordable water and sanitation services for Ebeye.
Environmental management plan. The PMU within the KAJUR will be responsible for setting up the environmental management system, consisting of inspection, monitoring, reporting, and initiating corrective actions or measures. In the design stage, the PMU will pass the EMP to the design consultants for incorporating mitigation measures into the detailed designs. The EMP will be updated at the end of the detailed design, and finally be passed to the construction contractors. To ensure that contractors will comply with EMP provisions, the PMU will prepare and provide the following specification clauses for incorporation into the bidding procedures: (i) a list of environmental management requirements to be budgeted by the bidders in their proposals; (ii) environmental clauses for contractual terms and conditions, and (iii) the full IEE report for compliance. The PMU and contractors will each nominate dedicated, trained, and qualified
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Implementation arrangements. The Office of the Chief Secretary will be the executing agency and KAJUR will be the implementing agency for the project implementation. A project steering committee (PSC) has already been established to provide strategic direction and guidance for detailed design and implementation of the project and will meet at least once every quarter. A project management unit (PMU) also already established within KAJUR will be responsible for the overall design and implementation of the project. Consultants will be recruited to assist the PMU implement the project. Overall responsibility for implementing the EMP rests with the PMU- KAJUR, which during design and construction will be supported by the project implementation assistance consultants.
Information disclosure, consultation, and participation. Environmental information on the project was and will be disclosed. The IEE will be disclosed according to the provisions of the ADB Access to Information Policy, 2019, and by the requirements of the laws of the Republic of the Marshall Islands. The IEE will be made available for review by interested stakeholders at the RMIEPA upon submission. The stakeholder consultation process disseminated information to the general public, project affected communities, and key environmental stakeholders. Information was provided on the scale and scope of the project, and the expected impacts and proposed mitigation measures, through consultation with government departments, local authorities, and the general public in meetings. The process also gathered information on relevant concerns of the local community for the project, to address these concerns in the project design and implementation stages. No significant environmental concerns were raised during consultations, and the local community anticipates the substantial benefits from the project, in water and sewerage treatment improvements.
Grievance Redress Mechanism. In order to settle unforeseen issues effectively, an effective and transparent channel for lodging complaints and grievances has been established. Public participation, consultation and information disclosure undertaken as part of the IEE process have discussed and addressed major community concerns. Continued public participation and consultation has been emphasized as a key component of successful Project implementation. As a result of this public participation and safeguard assessment during the initial stages of the project, major issues of grievance are not expected. However, unforeseen issues may occur. In order to settle such issues effectively, an effective and transparent channel for lodging complaints and grievances has been established.
Conclusion and Recommendations. The project is expected to further strengthen KAJUR’s financial and technical capacity for sustainable delivery of water supply and sewerage services on Ebeye which are critical for improve hygiene behaviors and to eliminate the transmission of COVID-19 and other waterborne and contract transmissible diseases. Associated and cumulative benefits include, improved planning, management, and sustainability of future water and sanitation, improved development planning, and increased tourism potential. The potential environmental impacts arising from design, construction, operation and maintenance of the project will be minor, localized, and acceptable, provided that the corrective actions and mitigation measures, as set out in the EMP are implemented properly. Key findings are summarized below: (i) Adverse environmental impacts will mainly be construction impacts, which are expected to be minimal for land-based works. (ii) Climate change and vulnerability must be taken into consideration during final design and project implementation. Priority measures include 'climate proofing' for storm surge, intense rainfall, and long-term sea level rise.
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This IEE, and accompanying EMP, is considered sufficient to meet environmental safeguard requirements of ADB and the RMI, in respect to the improvement of water and sanitation in Ebeye.
I. INTRODUCTION
1. This initial environmental examination (IEE) presents the potential environmental impacts and appropriate mitigation and enhancement measures for the review and recommended improvements to onsite sanitation treatment systems in the communities of Loi and Ebwaj (approximately 50 households or 320 people) which are on the islets on causeway which links Ebeye and Guegeegue. in Ebeye, Republic of Marshall Islands (RMI) as shown in Figure 1. Ebeye Islet, sits at the southeastern end of Kwajalein Atoll in the Republic of the Marshall Islands, roughly midway between Australia and Hawaii in the western Pacific Ocean
Figure 1: Ebeye Location Map
Source: USACOE Ebeye Infrastructure Survey (2010).
2. The IEE has been prepared in accordance with the requirements of the Asian Development Bank (ADB) Safeguard Policy Statement 2009 (SPS) and conforms to environmental assessment requirements defined in the RMI National Environmental Protection Act 1984 (NEPA) and RMI Environmental Protection Authority (RMIEPA) regulations and related guidelines. The project’s 13
anticipated environmental impacts are classified as category B under the ADB SPS (2009).1
3. This IEE provides an assessment of potential environmental benefits, potential adverse environmental impacts, and risks associated with the proposed water improvements, and includes (i) a summary of the local, national, and international policies, standards, and guidelines; (ii) due diligence review of existing environmental impact assessments undertaken to meet local approval requirements; (iii) description of the project and anticipated environmental impacts and mitigations measures; (iv) information disclosure, consultation and participation, (v) a grievance redress mechanism, and (vi) and detailed environmental management plans (EMP) for water operations.
A. Background and Rationale
4. Ebeye is a small islet of roughly 32 hectares (80 acres) located on the Kwajalein Atoll in the North Pacific Ocean, with a maximum elevation of about 3 meters (10 feet) above mean sea level. As at the 2011 Census, the resident population is estimated at 11,408. Ebeye comprises 84% of the population of Kwajalein Atoll. Its economy consists mainly of employment at the US Reagan Missile Defense Base on Kwajalein Island, subsistence agriculture and fishing, and limited tourism. RMI relies heavily on financial assistance from the United States and international aid.
5. Ebeye has a significantly altered terrestrial environment, consisting mainly of built environment. Both terrestrial and near shore marine environments were negatively impacted by inadequate sewerage collection and treatment, as the existing waste-water treatment plant (WWTP) has been out of operation for at least 10 years. These shortcomings were addressed and upgraded during 2015-2020, to deliver affordable water, sanitation, and power services for Ebeye. This project will continue to improve the health and safety of the resident population currently experiencing contamination from sewage, with the project improving water supply and supporting the ongoing development of the capacity of the Kwajalein Atoll Joint Utilities Resources (KAJUR) and Ebeye/Kwajalein Atoll Local Government (KALGov) to manage and monitor environmental performance of the water and sanitation systems.
6. Ebeye’s limited natural resources and fragile ecosystems are under considerable pressure from rapid population growth. This growth also puts additional demand on failing water and wastewater infrastructure intended to protect the environment and public health. Hardships from inadequate water supply and lack of sanitation are still faced by the some of the Ebeye community. 7. An assessment of the current project implementation status and achievements demonstrate solid project progress. Over the past 4 years, the project has increased Ebeye’s capacity to produce freshwater from 249 cubic meters per day (m3/day) to 1,660 m3/day increasing the availability of water from 26 liters per person per day to 180 liters per person per day, expanded the island’s freshwater, saltwater, and sewerage networks by 8.5 kilometers (km), rehabilitated and expanded the existing sewerage system by 2.6 km, installed new sewage treatment facilities (1,400 m3/day) and a constructed a new 0.35 km long sewage marine outfall. A contract to upgrade Ebeye’s electrical distribution system (replacement of switchgear and power poles) is ongoing and is scheduled to be completed in August 2020 but may be delayed due to COVID-19 impacts including restrictions on the movement of contractor personnel and disruptions to equipment and materials supply chains.
1 As per the SPS a proposed project is classified as category B if its potential adverse environmental impacts are less adverse than those of category A projects. These impacts are site-specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. An initial environmental examination is required.
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8. There is also measurable progress towards delivering the project’s target impact and outcomes. The average monthly number of cases of diarrhea reported by the Ebeye Hospital has declined by almost 20% since following the implementation of the project’s hygiene awareness and education program and the commissioning of the new desalination plant (provided by the project through a design-build-operate contract). All 1,465 household on Ebeye now have access to freshwater, saltwater, and sewerage networks service. 9. However, further assistance is required to build the financial and technical capacity of KAJUR (the project implementing agency). KAJUR has developed a new water and sewerage tariff framework to apply to all water and sewerage services and targeting recovery of water and sewerage operations and maintenance costs. The tariff framework is scheduled to apply from 1 October 2020. While KAJUR has conducted consultations on the willingness to pay with the Ebeye community on universal water and sewer tariffs, the recovery of O&M costs may take a longer time than initially anticipated due to the shrinking of households’ income due to COVID19. Therefore, further investment is required before cost recovery of O&M is achieved. 10. Further assistance is also required to build KAJUR’s technical capacity to operate and maintain the new desalination plant and water supply system, which will also help to achieve financial sustainability. When the plant’s design-build-operate (DBO) contract finishes in July 2020, KAJUR would not be able to take it over due to the limited operations and maintenance capacity. The existing DBO contract needs to be extended to enhance skill transfer to KAJUR to operate and maintain the plant after the contact ends. Additional minor investments to protect the plant from corrosion and to strengthen the plant building structure, and the provision of a standby generator will also improve the sustainability of desalination plant.2 11. As part of the response to COVID19, the government requested ADB support to review and recommend approaches to improve the onsite sanitation systems in the small islet communities immediately north of Ebeye. Additional requirement of hygiene awareness and handwashing campaign to prevent the transmissible diseases including COVID19, will be delivered under the proposed ADB regional technical assistance.3 12. The project has been confirmed to meet the eligibility criteria for additional financing. The project has been effective but further work is required to ensure its sustainability. GORMI is complying with the grant covenants and assurance (although some have been complied late) and project’s environmental and involuntary resettlement safeguard requirements are being met. The additional financing modality is suitable because of (i) close linkages with the current project’s scope and will be efficiently implemented under the same implementation arrangements; (ii) the natural continuity of the current project; and (iii) the opportunity to sustain the benefits of the current project. Project preparatory activities include (i) environmental and social assessments are carried out under the current project; (ii) review of the ongoing DBO contract; and (ii) terms of reference of the capacity building consultants. 13. The project remains highly relevant in the COVID-19 context. The sustainable water supply and sanitation, and hygienic conditions are essential to stop the transmittable virus spreading and help to restore the economics in a safe environment.
2 The unreliable supply of electricity to desalination plant between February and August 2019 and in January 2020 resulted in substantial transient hydraulic loads which damaged some plant pipework and highlighted the need to strengthen several structural elements of the plant building. The standby generator, as well as improvements to Ebeye’s electricity generation systems, will reduce the risk of damage from transient hydraulic loads caused to power outages. 3 ADB. 2020. Draft Technical Assistance Report: Strengthening Water, Sanitation and Hygiene Practices and Hygiene Behavioral Change in the Pacific [Project Number: 54227-001]. Manila.
II. POLICY, LEGAL AND ADMINISTRATION FRAMEWORK
A. National and Local Legal Framework
1. National Environmental Framework
14. The RMIEPA is the governing body for environmental protection in the RMI. The NEPA is administered by the RMIEPA and contains a set of regulations for protection of surface and marine waters, and air quality, and managing of potential impacts from earth works, sanitation systems, waste, and new infrastructure development. These regulations provide the framework for protection of resources and environmentally sustainable development in Ebeye and are directly applicable to this project.
15. Environmental Impact Assessment Regulation. The environmental impact assessment (EIA) Regulation (Section 21, NEPA) is the central environmental planning legislation with the aim of ensuring that environmental concerns are given appropriate consideration in decision making for all new infrastructure projects. The EIA regulation applies a two-step assessment process to determine the level of assessment required, similar to the ADB environmental safeguard policy. Initially, a preliminary proposal is required for “each and every proposed development activity.” The preliminary proposal is an initial evaluation to determine whether an action may have a significant environmental effect. The preliminary proposal is evaluated by the RMIEPA General Manager to determine if the action has the potential to have a ‘significant effect on the environment’, if so, a second stage of assessment is required and an EIA must be completed.
16. If it is determined that an EIA shall be required for a proposed development activity, the RMIEPA shall immediately initiate a scoping process to identify the significant issues related to the proposal and to determine the scope of issues to be addressed. In preparing the EIA, the proponent shall follow the format and content, as detailed in Part IV of the regulation, unless otherwise directed by the Authority. The proponent shall remain subject to regulatory and permitting requirements pursuant to NEPA, Coast Conservation Act, and the Historic Preservation Act and Tourism Act 1991.
17. Earthmoving Regulations. These regulations stipulate that all earthmoving activities in the RMI require an earthmoving permit. Permitted persons engaging in earthmoving shall design, implement, and maintain erosion and sedimentation controls which prevent accelerated erosion and sedimentation. Earthmoving activities may also remain subject to permit requirements pursuant to NEPA, Coast Conservation Act, and the Historic Preservation Act and Tourism Act 1991. If the project involves earthmoving activity in a lagoon and reef area (trenching and filling for a 50m section of sewer outfall pipeline), the Authority may require the design plan to map and describe existing ecosystems, plants, animals, the coastal zone management boundary, coastal areas of special importance, as well as maximum/minimum turbidities. All sedimentation resulting from underwater earthmoving shall be contained and turbidities kept to a minimum. Sedimentation retention booms, containment areas (sedimentation curtains) shall be established around earth disturbing activities on reefs or in lagoons. The project is likely to require about 50m of sewer outfall pipeline to be trenched and buried and is therefore likely to trigger the Earthmoving Regulations and needs to address the requirements listed above.
18. The Director will provide a detailed list of what aspects of the environment must be considered in the EMP. This list may include, but is not limited to the following: (i) sedimentation in coastal waters; 16
(ii) erosion of shorelines; (iii) alterations to ecosystems including coral reef and/or other marine life; (iv) biodiversity or endangered species of the Republic; (v) human health; (vi) impact human uses of the land, including zoning laws, urban quality; (vii) historic or cultural resources; (viii) the extent to which the activity utilizes natural or exhaustible resources; (ix) any mitigation activities that may offset the costs of the development activity; and (x) projected generation of waste including quantities and characteristics and opportunities for recycling or reuse.
19. Permit conditions may require performance bonding, monitoring reports, and timelines for implementation of coast conservation measures, and other mitigation measures. The draft Sustainable Development Regulations have not been promulgated, as of the time of this document.
20. Toilet Facilities and Sewage Disposal Regulations. The Toilet Facilities and Sewage Disposal Regulations (TFSDR) establish standards for toilet and wastewater disposal systems. The regulations require that all public buildings and dwellings shall have toilet and sewage facilities in accordance with the regulations. Where a sewage system is available to the public, all buildings and dwellings shall be connected. The minimum standards govern the design, construction, installation and operation of toilet and wastewater disposal systems, for the purposes of minimizing environmental pollution, health hazards and public nuisance from such systems and facilities.
21. The TFSDR is focused on household sanitation systems, such as septic tanks, and connection requirements to the public sanitation system in areas where it is available. The regulation does not provide discharge standards or design specifications for the larger scale public sewerage infrastructure works under this project. However, as part of the permitting process, under the regulation, the RMIEPA will review and approve the standards and specifications submitted by the proponent (system operator).
22. Public Water Supply Regulations. The purpose of these regulations, technical provisions, and specifications is to establish certain minimum standards and requirements as determined by the Authority to be necessary for the public health and safety and to insure that public water supply systems and water supply sources are protected against contamination and pollution and do not constitute a health hazard. Before a proponent initiates construction of a new public water system or increases the capacity of, or modifies an existing public water system, the proponent shall notify the Authority, and submit with such notification a conceptual, descriptive plan with appropriate drawings detailing proposed location, water source capacity, budget estimates and other data as described in Regulation 6.
23. The proponent shall, to the extent practicable, avoid locating part or all of the new or expanded facility at a site which: (i) is subject to a significant risk from earthquakes, floods, fires, or other disasters which could cause a breakdown of the public water system or a portion thereof; or, (ii) except for intake structures, is within the floodplain of a 100-year flood or is lower than any recorded high tide where appropriate records exist; and (iii) in the case of a roof catchment, where reasonable consideration has not been given to effective typhoon resistance of buildings, roofs, guttering and other catchment appurtenances.
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24. The notification of intent to construct a new public water supply system or to increase the capacity of an existing public water supply system, as required in Regulation 5, shall include the following data and information: (i) number of persons to be supplied now, and the anticipated population of service area 10 years from now; (ii) proposed storage capacity of raw and treated water; and (iii) if the water source is to be a well or wells, estimated depth(s), measures to be taken to exclude surface water from well, kind of pump(s) to be used and capacity in gallons per minute, and adjacent land uses and pollution sources.
25. Procedures for applying for a public water system permit, and timelines for review and approval by the Authority, are contained in the regulations; as are requirements for operator certification, water quality testing and reporting.
26. International conventions and treaties. RMI is a signatory to the following conventions: (i) United Nations (UN) 64th General Assembly Resolution on the Human Right to Water and Sanitation; (ii) UN Framework Convention on Climate Change; (iii) UN Convention on Biological Diversity; (iv) UN Barbados Program of Action and Mauritius Strategy; (v) UN Convention to Combat Desertification; and (iv) The Micronesion Challenge.
B. ADB Safeguard Policies
27. All projects funded and/or administered by ADB must comply with the SPS. The purpose of the environmental safeguards is to ensure the environmentally soundness and sustainability of projects and to support the integration of environmental considerations into project decision- making. The policy is accompanied by the Environmental Safeguards Good Practice Sourcebook (2012). The policy promotes international good practice as reflected in recognized standards such as the World Bank Group’s Environmental, Health and Safety Guidelines.
28. The SPS requires several additional environmental considerations to that generally undertaken in accordance with the NEPA and related legislation. These include: (i) identification of project environmental risks and respective mitigation measures and project assurances; (ii) development of a project level grievance redress mechanism (GRM) including documentation in the EMP; (iii) definition of the project area of influence; (iv) undertaking a physical cultural resources damage prevention analysis; (v) identification of climate change mitigation and adaptation strategies; (vi) identification of biodiversity conservation and natural resources management requirements; and (vii) ensuring that the EMP includes an implementation schedule and (measurable) performance indicators.
29. ADB will not finance projects that do not comply with the SPS and the host country’s social and environmental laws and regulations, including those laws implementing host country obligations under international law. The SPS also contains a prohibited activities list identifying specific activities that ADB will not finance.
III. DESCRIPTION OF THE PROJECT
30. Project Description. This additional financing will support the operation and maintenance to ensure the sustainability of the current project and improve water supply and hygiene behaviors essential to prevent the transmission of COVID-19. The project sustainability will be improved which is in line with the lessons learned for the Pacific Department in the Independent Evaluation Department’s Annual Evaluation Report of 2019. The project design reflects lessons from the current project and previous relevant ADB and development partner sector operations in Pacific developing member countries. Key lessons include (i) ensuring adequate financial and technical capacity are essential to sustainable delivery of water supply and sewerage services, and (ii) urban service demand and willingness to pay must be ensured. 31. The impact and outcome statement will remain same as the current project. The overall project impact will be reduced incidence of waterborne disease on Ebeye and is aligned with RMI’s national development water and sanitation policy objectives of (i) improved sanitation for better health and well-being, and (ii) constant access to drinking water that meets World Health Organization standards, as articulated in RMI’s National Strategic Plan, 2020–2030. The outcome will be improved access to safe water and improved sanitation. The overall project outputs will be strengthened. The additional financing will support following key outputs:
(i) Output 1 - Secure and safe freshwater supplies. The sustainability of KAJUR’s water supply operations will be strengthened by: (a) extending the desalination plant design-build-operate contract for provision of remote monitoring and operation and maintenance support for 2 years to strengthen the operations and maintenance capacity of KAJUR desalination plant personnel. (b) upgrading the desalination plant by providing anti-corrosion protection treatment to pipes and equipment, minor structural improvements, and provisions of 440 kVA backup generator.
(ii) Output 2 – Enhanced water, sanitation and hygiene awareness and behaviour change. The scope of Output 2 will be expanded to review and recommend improvements to onsite sanitation treatment systems in the communities of Loi and Ebwaj (approximately 50 households or 320 people) which on the islets on causeway which links Ebeye and Guegeegue. Investments identified by the review will be implemented under future projects. The review will also recommend approaches to improve the sanitation, which plays important role to stop the transmissible disease such as COVID19. (iii) Output 4 – The electricity supply on Ebeye for water and sewerage operations has improved. Output 4 will be expanded to include the provision of additional high voltage electrical switchgear will ensure the security of the electricity supply to the desalination plant and to other KAJUR water supply and sewerage assets.
(iv) Output 5 – KAJUR is financially and technically sustainable. Additional activities to be delivered under output 5 include: (a) further strengthening of KAJUR’s financial management capacity by extending the services of KAJUR’s financial management advisor through intermittent inputs (3 weeks every quarter) over 2 years. The services of the financial management advisor will be particularly important during the initial implementation of KAJUR’s new water and sewerage tariff framework. 19
(b) strengthening the capacity of KAJUR water personnel to optimize freshwater and saltwater network operations and minimize system losses. Capacity will be strengthened by the provision of water distribution specialist to provide on-the- job training provided intermittently (12 weeks per year) over 2 years. (c) provision of a technical advisor on an intermittent basis (12 weeks per year) over 2 years to assist strengthen KAJUR’s capital works planning and to further strengthen KAJUR’s project management capacity. (d) extension of the EWSSP household fixtures program for 2 years to enhance demand management by reducing household water wastage from faulty plumbing fixtures and to ensure the poorest households on Ebeye can access to safe water and improved sanitation. (e) to ensure the poorest households on Ebeye can access to safe water and improved sanitation.
32. Project Location. The project, including the activities within the additional financing, is located on Ebeye Islet, which sits at the southeastern end of Kwajalein Atoll in the Republic of the Marshall Islands, roughly midway between Australia and Hawaii in the western Pacific Ocean (Error! Reference source not found.). Ebeye is a small, low-lying coral islet with a land area of about 40 hectares and a maximum elevation of about 3 meters above mean sea level. A short ferry ride to the southwest of Ebeye lies Kwajalein Island, which houses the main airfield and central base of the United States missile defense testing and space tracking facility known as the Ronald Reagan Ballistic Missile Defense Test Site. The scattered facilities of the base occupy and utilize most of the rest of the land and lagoon area of Kwajalein Atoll.
33. Ebeye is a densely populated urban community that serves as the commercial and government center of the Ralik Chain of the Marshall Islands. The 2011 Census recorded 1,103 households with 9,614 people on Ebeye with an average household size of 8.7 persons. One of the reasons for the dense population on Ebeye is its access to jobs at the US base, known locally as “Kwaj,” where roughly 1,000 Marshallese work at any one time. The great majority of these Marshallese workers live on Ebeye and commute daily by ferry to the base, but some live semi- permanently on the base and visit their family and friends on Ebeye during free time. Ebeye population fairly stable with an average increase of just 0.4% per annum.
IV. DESCRIPTION OF ENVIRONMENT
A. Physical Environment
1. Climate
34. Located at latitude: 8⁰ 47' 33" north and longitude: 167⁰ 44' 56" east, Ebeye island is at the southern end of Kwajalein atoll, the world’s largest atoll. The atoll has a total land area of 16 square kilometers, with about 90 islands surrounding a 1,700 square kilometer lagoon. Ebeye is a small low-lying coral islet comprised of a land area of 32 hectares (80 acres), with a maximum elevation of about 3 meters (10 feet) above mean sea level. The climate is maritime tropical with slight seasonal and daily variations, with temperatures averaging about 270C. Figure 2 in light blue, dark blue and grey bars denote El Niño, La Niña and neutral years respectively..
35. The rainfall of the RMI varies greatly from north to south. The atolls at >10⁰ north receive less than 1250 mm (50 inches) of rain annually and are very dry in the dry season. Atolls < 7⁰ north (closer to the equator) receive more than 2500 mm (100 inches) of rain annually. Both Majuro and Kwajalein have a dry season from around December to April and a wet season from May to November (Figure 3). The difference between the seasons is greater at Kwajalein where the driest months (January–March) receive about 4 inches (100 mm) on average and the wettest months (September–October) receive on average around 12 inches (300 mm).4 Seasonal wind direction dictates the wet and dry periods, with northeast “trade winds” bringing dryer weather, and the monsoonal southwest winds increasing precipitation. Droughts and storm surge are the main extreme events that impact the Marshall Islands. Droughts generally occur in the first 4 to 6 months of the year following an El Niño. During severe El Niño events, rainfall can be suppressed by as much as 80%. The dry season begins earlier and ends much later than normal. Tropical cyclones (typhoons) usually form between September and November but are often weak when they pass through the RMI.
Figure 2: Average Mean Temperature at Kwajalein
Source: Pacific-Australia Climate Change Science and Adaptation Planning Program Technical Report, 2014.
4 Pacific-Australia Climate Change Science Program. Technical Report – Chapter 7 Marshall Islands Report (2014). 21
2. Climate Change
36. The International Panel on Climate Change (IPCC) recognizes that developing countries particularly small island developing states such as the RMI are particularly vulnerable to climate change.5 Projected sea level increases to the year 2100 are 0.35m to 0.70m, this rise, in combination with extreme sea level events, such as swell waves, storm surges, and El Niño- southern oscillation (ENSO) events, present severe sea inundation and erosion risks for low lying atoll islands. Locations currently experiencing adverse impacts such as coastal erosion and inundation will continue to be affected due to increasing sea levels. The contribution of mean sea level rise to increased coastal highwater levels, coupled with the likely increase in tropical cyclone maximum wind speed, is a specific issue for tropical small island states.6 Based on the recent Technical Report,7 for the period to 2100, the latest global climate model projections and climate science findings indicate: (i) El Niño and La Niña events will continue to occur in the future (very high confidence), but there is little consensus on whether these events will change in intensity or frequency; (ii) annual mean temperatures and extremely high daily temperatures will continue to rise (very high confidence); (iii) average rainfall is projected to increase (high confidence), along with more extreme rain events (high confidence); (iv) droughts are projected to decline in frequency (medium confidence); (v) ocean acidification is expected to continue (very high confidence); (vi) the risk of coral bleaching will increase in the future (very high confidence); (vii) sea level will continue to rise (very high confidence); and (viii) wave height is projected to decrease in the dry season (low confidence) and wave direction may become more variable in the wet season (low confidence).
Figure 3: Kwajalein Annual Rainfall
Source: Pacific-Australia Climate Change Science and Adaptation Planning Program Technical Report, 2014
5 IPCC. Assessment Report 5 (2014). 6 IPCC. Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation (SREX): Summary for Policy Makers (November 2011). 7 Pacific-Australia Climate Change Science Program, op cit.
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37. Temperature. While relatively warm and cool years and decades will still occur due to natural variability, there is projected to be more warm years and decades on average in a warmer climate.
38. Rainfall. There will still be wet and dry years and decades due to natural variability, but most models show that the long-term average is expected to be wetter. The effect of climate change on average rainfall may not be obvious in the short or medium term due to natural variability. These projections are similar to those in Australian Bureau of Meteorology and CSIRO (2011).
39. Drought. For both the northern and southern RMI the overall proportion of time spent in drought is expected to decrease under all global climate model scenarios.
40. Tropical cyclone (typhoon). There is a growing level of agreement among models that on a global basis the frequency of tropical cyclones is likely to decrease by the end of the 21st century. These projections are consistent with those of Australian Bureau of Meteorology and CSIRO (2011).
41. Sea level rise. Mean sea level is projected to continue to rise over the course of the 21st century. There is very high confidence in the direction of change. Several global climate models (CMIP5, RCPs) simulate a rise of between approximately 3 to 7.5 inches (7–19 cm) by 2030. Inter-annual variability of sea level will lead to periods of lower and higher regional sea levels. In the past, this year to year variability has been about 8 inches (20 cm), and it is likely that a similar range will continue through the 21st century. The sea level rise near the Marshall Islands measured by satellite altimeters since 1993 is about 0.3 inches (7 mm) per year.8
42. Sea level is also generally higher around the Marshall Islands during La Niña events, with three of the top 10 water levels recorded at Kwajalein occurring during La Niña and none during El Niño (Australian Bureau of Meteorology and CSIRO, 2011). Tide gauge data show the strong annual variability in tide heights and indicate that ENSO events are a significant component of high-water levels. The Weather Service Office has recorded that roads in both Majuro and Ebeye are affected by significant inundation on almost every equinox tide during La Niña conditions. During December 2008, a State of Emergency was declared following weeks of high seas which resulted from storm surges coinciding with high tides and two tropical depressions (UNOCHA, 2009). The populated areas of Majuro and Ebeye suffered damage to roads, houses, and other infrastructure on the low-lying atolls. A similar event occurred in June-July 2013, mainly affecting Majuro.
43. Tropical cyclones (typhoons) usually form between September and November but are often weak when they pass through the Marshall Islands’ region. Nevertheless, RMI was affected by devastating cyclones several times in the last few decades. For example, typhoon Paka in 1997 caused severe damage to crops, and damaged 70% of houses on Ailinglalap Atoll, with total damage estimated at US$80 million for the entire nation. Typhoons Zelda, Axel and Gay each caused significant damage and losses with the space of 1 year (1991-1992).9 Tropical Storm Roy impacted Kwajalein in 1988.
44. ENSO events also modulate temperature and rainfall in the western equatorial Pacific
8 Pacific Climate Change Science Program. op cit. 9 Pacific Catastrophe Risk Assessment and Financing Initiative. Country Risk Profile: Marshall Islands, September 2011.
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Ocean. Droughts generally occur in the first 4 to 6 months of the year following an El Niño. During severe El Niño events, rainfall can be suppressed by as much as 80%. The dry season begins earlier and ends much later than normal. Variability in temperature and rainfall, during ENSO events is shown in Figure 4.
Figure 4: ENSO Events and Impacts on Rainfall and Temperature
Observed time series of annual average values of mean air temperature (red dots and line) and total rainfall (bars) at Kwajalein. Light blue, dark blue and grey bars denote El Niño, La Niña and neutral years respectively. Solid black trend lines indicate a least square fit. Source: Pacific-Australia Climate Change Science and Adaptation Planning Program Technical Report, 2014.
45. Planning for the future climate change scenario will help mitigate potential impacts to the project, vulnerable ecosystems, and quality of life indicators for Ebeye residents. Of additional concern, is if disasters occur more frequently and/or with greater magnitude. Subsequently, some local areas will become increasingly marginal as places to live and subsist, especially for locations such as atolls. In such cases, migration and displacement could become permanent and exacerbate pressures in areas of relocation, such as Ebeye. Potential threats to water, wastewater, and power infrastructure will likely include: (i) increased sea water inundation; (ii) increased erosion and subsidence of coastal areas; (iii) increased frequency of intense rainfall events, and subsequent flooding; (iv) increase in tropical cyclone intensity, though reduced frequency; and (v) increase in drought intensity, though reduced frequency.
46. Planning for the potential impacts of climate variability will help to mitigate against potential impacts which may include (i) sea water inundation resulting in failure of near shore sanitation infrastructure, and (ii) increased risk of contamination of near shore marine waters. Planning considerations should include: (i) planning new infrastructure at a suitable elevation above the current high tide level (utilizing accurate topographic survey), (ii) provision for protective flood berms around existing above ground infrastructure at low elevations above the current hide tide
24 level, (iii) ensuring new infrastructure is designed to withstand extreme weather events.
47. Although stormwater management improvements are not part of the project’s scope of works, a non-functioning storm water drainage system, as described in the 2010 USACOE Ebeye Infrastructure Survey, may have serious impacts on water and sewer infrastructure, especially considering predicted climate change variability, such as increased sea level rise and rainfall intensity. Rehabilitation of the drainage system is a prime example of a climate change adaptation measure that would qualify as a cost effective, "no regrets", investment.
48. Increasing sea level rise, with more frequent episodes of inundation and coastal erosion, will severely impact the existing Ebeye dumpsite, which cannot be considered a sanitary landfill. The dumpsite was constructed on the northern end of the island and extends out over the nearshore lagoon reef. Though a berm and concrete block seawall extend around the perimeter, it is breached in several locations. The tidal water table is exposed in several areas inside the site. Serious consideration needs to be given to any proposed disposal of sewage screenings or sludge, without providing adequate containment, to avoid further contamination of nearshore waters and direct exposure to residents entering the dumpsite.
49. The vulnerability of fragile ecosystems such as coral reefs and coastal zones, as well as rare or endangered species is further increased by climate variability, droughts, water pollution, soil erosion, poor land management and land degradation, and unsustainable development.
50. Matrices assessing climate change vulnerability and mitigation measures for the project were presented in the project Inception report, and have been further refined, as subproject options have been detailed, and are included in Appendix D.
1. Geology and Geomorphology
51. The atolls of the Marshall Islands are made up of calcareous remains of coral growth that have accumulated over millions of years on the peaks of submerged mid-oceanic volcanic islands. The atoll and islands lie in two parallel chains: Ratak (meaning sunrise) to the east, and Raliik (sunset) to the west. The two atoll chains are approximately 130 miles (209km) apart and are aligned diagonally northwest to southeast between 1600 east-1730 east and 040 -150 north.
52. Most atolls of the Marshall Islands consist of an irregular shaped reef-rim with numerous islets encircling a lagoon with water depths that can reach 200 feet (60 m). The islets are more prevalent on the windward side. The atolls vary in size from Kwajalein, the largest Pacific atoll with 6.3 square miles (16.4 km2) of dry land and a lagoon of 840 square miles (2,174 km2). Ebeye Island is located at the lower, southeastern area of Kwajalein atoll.10
53. Ebeye lies at the southern edge of the Pacific North Equatorial Current (Latitude: 8° 47' 33" N, Longitude: 167° 44' 56" E); as such, ocean prevailing currents flow westerly, and towards the eastern shore of the island. Consideration of the site location of any new sewerage effluent discharge point must take this into account (see Figure 5).
1. Soils
54. According to the US Department of Agriculture- Natural Resources Conservation Service, survey of soils in Majuro and several other islands in the Ratak chain, the main soil component in
10 State of Coral Reef Ecosystems of the Marshall Islands, NOAA 2008.
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the atoll islands is classified as the Majuro series. With the climate, parent material, topography, vegetation, and age of soils being fairly uniform throughout the atoll islands, we can extrapolate that soils on Ebeye Island are similar.11 The Majuro series consists of very deep, somewhat excessively drained soils that formed in water deposited coral rubble and sand. Slope is 0-2%. These soils are sandy-skeletal, carbonate in composition.
Figure 5: Pacific North Equatorial Current (NEC)
55. Soil properties are an important consideration for evaluating the suitability of individual, or collective, septic systems as a sanitation option. Excessively drained soils, such as those soils in Ebeye, are not well suited to densely sited septic systems. The water table (saltwater) is also typically encountered at 1 to 1.8 meters depth. These conditions emphasize the need for a well- functioning sewage collection and treatment system; especially given the density of households in Ebeye.
2. Freshwater Resources
56. Groundwater exists as a basal aquifer, often called a freshwater lens—the Ghyben- Herzberg lens--on many atoll islands. Water quality varies from somewhat fresh to brackish. The lens is recharged by rainfall that percolates through the highly permeable coral soil. The groundwater level and salinity fluctuate with the sea tidal level. There are a few private wells in use in Ebeye, the water being brackish to mildly brackish, the well water is typically bailed by bucket. High groundwater salinity was found during the hydrology investigation in March 2014, despite high rainfall during the previous month. This indicates there is low potential for fresh groundwater use, and given the minimal lens formed under the narrow island, the width of which averages 250 meters across.
57. There are no surface water resources existing in Ebeye.
3. Air Quality
58. Only minor ambient air quality impacts tend to occur from sources such as sewage pump
11 USDA/NRCS. Soil Survey of Airik, Arno, Majuro, Mili and Taroa (July 1989).
26 stations, the power plant, and from motor vehicles. The practice of burning trash at the dumpsite at the north end of the island could contribute significant pollutants in nearby areas, including some residences south of the dumpsite. Otherwise, consistent trade winds from the northeast predominate and one would expect the air quality on Ebeye, to be almost pristine. The RMI has not promulgated air quality regulatory standards.
B. Ecological Environment
1. Terrestrial Flora and Fauna
59. Well over 90% of the Ebeye community area is built environment. Vegetation primarily consists of plantings among residences and yards, such as: coconut, Terminalia catapp, tropical almond ('kotel'), Morinda citrafolia, noni, ('nin'), and ornamentals. Casuarina litorea, ironwood pines, are also common, planted as windbreaks, and along property boundaries. Scaevola taccada 'beach cabbage' or 'naupaka' dominates the shoreline north of the community, on the causeway to Gugeegue village. Observed fauna consisted mainly of introduced species such as dogs, cats, and rats. Resident and migratory shorebirds are common along the fringing reef.
2. Threatened, Rare, or Protected Species
60. No threatened, rare, or protected species (terrestrial or marine) were identified by the project. The RMI Endangered Species Act 1975 has not developed a list of species to be specified as endangered under the Act. Additional identification and description of marine species and habitat is found in Appendix B: Sewer Outfall Benthic Habitat Survey.
61. No conservation or protected areas have been established for Ebeye Island.12
C. Social Environment
1. Socioeconomic Environment
62. Public sector spending and contributions from the United States, via the Compact of Free Association, largely drives the RMI’s relatively small national economy. The government sector accounts for 41% of formal employment and 40% of GDP (including state owned enterprises). The US Test Site on Kwajalein also accounts for one-third of economic activity. The fragile nature of energy and food security was evident when a State of Economic Emergency was declared in 2008 following rising inflation which peaked at 30.1%. High food and fuel prices resulted, highlighting the vulnerability of the RMI to external market variations.13
63. Some 94% of the employed Marshallese population worked in paid employment (11,932), with the private sector employing 41% of paid employees, ahead of the government sector at 35%. In all forms of employment males are more prevalent than females, at 65% male to 35% female. From 1999 to 2011, formal employment, in both the private and public sectors, increased by 1,848, with public sector growth (1,074) ahead of private sector job creation (772).14
64. The 2011 Census reports that 15.2% of all Kwajalein households reported no income and another 7.8% reported less than $3,000 annual income. In total, 23% of all households thus
12 Odrikawa Jatios, EPA Deputy General Manager, Ebeye Office, pers. Comm. 13 RMI. Joint National Action Plan for Climate Change Adaptation and Disaster Risk Management 2014-2018 (2014). 14 RMI. Census of Population and Housing Summary Report (2011).
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reported incomes of less than $3,000 per year or less than $8.22 per day. With an Ebeye census average of 8.7 people per household (likely higher for poorer households), that means 23% of the Ebeye population is living on less than $0.94 per day with little or no subsistence income.
65. Vulnerabilities are linked to both physical and social characteristics of its islands and people, in addition to ongoing unsustainable development practices. Key drivers of the RMI’s vulnerability include: (i) rapid population growth and over-population in urban centers; (ii) low elevation and small atoll islands; (iii) unsustainable development; (iv) localized pollution (including contamination of water supply), poor waste management, sanitation, and environmental degradationl (v) climate change impacts including accelerated sea level rise, which may increase vulnerability and exposure to shocks and stresses, as well as increase intensity of extreme events; (vi) limited resources (particularly food, water and fuel) (vii) limited economic potential due to small size and remoteness (viii) high exposure to external market shocks (demonstrated by the State of Economic Emergency declared in 2008 following unprecedented increases in costs of imported food and fuel;); and (ix) sparse and scattered nature of islands and atolls, making communication and transportation to outer islands more difficult, with infrequent and unreliable transport links.
66. The key natural and human-induced hazards were listed in the RMI Joint National Action Plan below. All are specific concerns for Ebeye residents (Figure 6).
Figure 6: Key Natural and Human Induced Hazards
Source: RMI Joint National Action Plan for Climate Change Adaptation and Disaster Risk Management 2014-2018.
2. Population
67. The 2011 Census Report highlighted several population statistics, for RMI in general, and specific to Ebeye, which are causal for the human induced hazards and vulnerabilities noted above: (i) The 2011 Census recorded a total population of 53,158 persons (27,243 males and 25,915 females) currently residing in the RMI. (ii) The last Census, or the 1999 Census, revealed 50,840 people so there are 2,318 more persons in the RMI or 0.4% population growth rate during the inter-censual period. (iii) Prior to the Census, there were projections that the RMI population would have 55,000 to over 60,000 people, but due to massive outmigration in recent years, it is estimated that around 11,000 Marshallese have left the country.Majuro and Ebeye continue to contain the largest population share (i.e., 74% or 39,337 people) and the populations
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have increased indicating people moving from the outer islands. (iv) All outer islands’ populations, except Jaluit, Lae, and Lib, have decreased since 1999. (v) Ebeye is the most densely populated/crowded area in the RMI with 9,614 people per square mile.22 (vi) Small and young children, ages 0-14, continue to constitute the largest portion of 40%, or 21,263 of the population indicating RMI has very high fertility rates although this has come down from 43% and 51% revealed by the 1999 and 1988 censuses, respectively. (vii) Of total occupied houses more than three-quarters (79%) use rainwater collected from roofs of their houses and stored in water-catchment as their main source of drinking water, indicating that serious policy attention towards water quality is needed.
68. The highest population density in the RMI is on Ebeye island in Kwajalein Atoll where 11,408 people live on 0.12 square miles (0.31 km2), resulting in population densities 80,117/sq. mile or 31,013/km2. Population densities of this magnitude, when associated with overcrowding, often entail health and other social challenges of varying severity.
3. Ethnography
69. The safeguards assessment for indigenous people, prepared for the project, found that “Ebeye people” do not constitute a distinct cultural group, “Ebeye people” are not dominated by another Marshallese cultural group or groups, and “Ebeye people” do not speak a language that is distinct from the Marshallese language spoken by other Marshallese. Thus, “Ebeye people” are not defined as Indigenous Peoples under the SPS.
4. Land Ownership and Use
70. Most land in the urban area of Ebeye is occupied with permission from the traditional chiefs (Iroji/Alap): 71% with permission from Iroji/Alap, 21% by family rights or closely related to title holder, 4% hold land title.
71. The Public Lands Act 1966 declares that all marine areas below the high watermark belong to the national government. The owner of land abutting the ocean or lagoon shall have the right to fill in, erect, construct and maintain piers, buildings, or other construction on or over the water or reef abutting his land and shall have the ownership and control of such construction; provided, that said owner first obtains written permission of the Chief Secretary before beginning such construction.
5. Education
72. The 2011 Census shows 17% of the population 6 years and older have completed either high school (Grade 12) or GED, while another 12% have completed some college or higher. Almost one-fourth (24%) have completed grade 9–11, while those who have completed grade 8 comprise 14%. Over a quarter of the population (28%) 6 years and older have completed elementary grades 1–7, and 3% have competed pre-school. Only 2% were reported to have never been to school. More males than females were reported to have completed a higher level of education. While 13.1% of males have at least some college education as compared to 9.9% of females, there is very little difference in the percentage of those who have completed high school or GED by sex. However, more females than males were reported to have completed grade 8-11.
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73. The proportion of the Kwajalein population having completed at least a secondary level of education is 27.5%.
6. Poverty
74. As in most Pacific countries, cash or material poverty is a sensitive and often controversial topic. This stems from strong cultural beliefs and practices of ‘caring and sharing’ for those vulnerable and where no one gets hungry. Acknowledging the presence of poverty challenges the traditional foundation of the society and strength of its culture.
75. In a recent RMI national report, in preparation for the 2014 Small Island Developing States (SIDS) conference in Samoa, the issue of 'economic inclusiveness' was addressed, stating "Inclusive economic development is predicated upon eradicating income poverty and hunger, reducing inequalities, and ensuring decent work and productive employment.” In 2009, the RMI’s progress on Millennium Development Goal 1, Eradicate Extreme Poverty and Hunger, was mixed. While the RMI did not yet have abject or extreme poverty, the RMI was not on track to meeting the three targets under Millennium Development Goal 1. More recently, the 2010 Majuro and Kwajalein Household Water Survey concluded that poverty was a real and serious problem in urban areas of the RMI, with households facing problems such a no water, no electricity, high unemployment, stagnant wages, rising prices, a need for improved government services, and access to information.15
76. The 2011 census reported that 15.2% of all Kwajalein households reported no income and another 7.8% reported less than $3,000 annual income. In total, 23% of all households thus reported incomes of less than $3,000 per year or less than $8.22 per day. With an Ebeye census average of 8.7 people per household (likely higher for poorer households), that means 23% of the Ebeye population is living on less than $0.94 per day with little or no subsistence income.
7. Cultural and Traditional Features
77. Initial response from Historic Preservation Office (HPO) indicated that the presence of cultural or traditional features of significance were highly unlikely in the project area, especially as the project works will lie wholly within the footprint of the existing infrastructure. HPO will issue a letter of guidance to the project advising that if any features are encountered during Project works, that works will stop immediately and the HPO be notified as soon as possible. The project's national community participation and development specialist, and long-time Ebeye resident, affirms that no resources of cultural significance have been identified.16
8. Noise
78. Vehicle traffic consists of private and commercial cars and trucks; and taxis (typically pickup trucks). It is observed that most residents do not own private vehicles and the main mode of transportation is by bicycle or walking. Given this situation it can be reasonably assumed that traffic levels do not exceed 100 vehicles per hour, or an average of 15 miles per hour (24 kph), which are thresholds, above which traffic generated noise dominates ambient noise levels. Below these thresholds, ambient noise levels would be controlled by non-traffic noise sources such as voices, animals (dogs, chickens), wind, foliage, etc. Noise levels are generally low from
15 RMI-Ministry of Foreign Affairs. National Report to 2014 SIDS Conference (2013). 16 Stevens R. Titml, Historian, Ministry of Internal Affairs, Historic Preservation Office and Yumi Crisostomo, pers. comm.
30 commercial activities in the area, such as markets, auto repair shops, and port activities (the port area being offset form the residential areas by about 130m).
79. The US State of Hawaii Department of Health regulations set a maximum permissible sound level in general residential areas at 60 dB (decibels).17 Construction works in the congested Ebeye community area will likely exceed this level and raise noise impacts to the “nuisance” level, defined as 15dB (decibels) above ambient noise levels.18 Mitigation for noise impacts to residents will be required, as detailed in section VI, B, Noise Impacts.
80. No sound measurements were taken during preparation of this IEE. The IEE should be updated after detailed design is prepared, to evaluate the construction duration, noise generation level of equipment to be used, and an assessment of impacts to specific, sensitive, noise receptors, proximate to construction works.
9. Traffic
81. Motor vehicle traffic levels are typically light, though minor traffic congestion is encountered along the main streets at the end of the workday, mostly due to taxi vehicles. One-way traffic is routed in a clockwise direction around the island's perimeter road.
82. As stated above, in Noise Quality, it is observed that most residents do not own private vehicles and the main mode of transportation is by bicycle or walking. It can be reasonably assumed the traffic levels do not exceed 100 vehicles per hour, or an average of 15 miles per hour (24 kph).
10. Public Health
83. In the RMI, the health care system is comprised of two hospitals, one in Majuro and one in Ebeye, and 58 health care centers in the outer atolls and islands. Both hospitals provide primary and secondary care but limited tertiary care. Patients who need tertiary care are referred to Honolulu or the Philippines (off-island referrals consume much of the health resources). Over the last decade, the people of the Marshall Islands have seen improvements in health indicators with decreases in maternal and child mortality. That said, a sedentary lifestyle and processed foods have brought about a sharp rise in the levels of adult obesity and non-communicable diseases (NCDs). Diabetes-related diseases and cancer are now the leading causes of death. High population growth and crowded conditions in urban areas have also contributed to the re- emergence and/or rise of certain communicable diseases, such as tuberculosis and leprosy. Other areas of concern include malnutrition in children, immunization coverage, a high teen pregnancy rate, and alarming rates of STIs.1927
84. The Ministry of Health recently developed a revised National Health Strategy 2012-2014. This strategy acknowledges the national goals and objectives stated in the Vision 2018 while providing insight on current priorities in the health sector (
17 Title 11, Administrative Rules, Chapter 46, Community Noise Control, Hawaii State Department of Health, 1996. 18 US Army Corps of Engineers Safety Manual EM 385-1-1, 2003. 19 RMI-Ministry of Foreign Affairs. National Report to 2014 SIDS Conference (2013).
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85. Figure 7: Goals of the National Health Strategy 2012-2014).
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Figure 7: Goals of the National Health Strategy 2012-2014
Source: RMI-Ministry of Foreign Affairs Third International Conference on Small Islands Developing States (2013).
86. Ministry of Health has partnered with the World Health Organization (WHO) to incorporate climate change impacts into its plans and policies, focusing particularly on improved drinking water safety planning and rainwater harvesting, as well as household and community-based water quality monitoring.
87. Solid waste management on Ebeye poses health concerns because they do not have a hygienic, sustainable means of disposing trash. Trash is collected and deposited into an unsecure open dumpsite, prior to being burned for volume reduction. The burning is often inadequate leaving a source for bacterial growth and promotion of disease vectors. There is a risk of toxic material contamination to adjacent and underground waters. Additionally, there are health risks to residents bordering the dumpsite (USCOE 2010).
88. The solid waste program on Ebeye is managed by the KALGov Department of Public Works (DPW). They are responsible for the collection and disposal of all the solid waste generated on the island, and also manage and operate the dumpsite. Currently, the program is fully subsidized by the government and no fees are charged to the residents for the service. Most of the trash generated on the island can be categorized as municipal solid waste and comes from the residential areas which include several schools, grocery/clothing stores, and restaurants. In addition, there is also a hospital that generates medical waste ( Figure 8).
89. The dumpsite (Figure 9) is located at the northern end of the island and occupies an area of approximately 5.3 acres (2 ha). The site is adjacent to, or partially encroaching, on the reef flat. Open leachate filled pits within the site are seen to be tidally influenced, showing a significant hydraulic connection between the site and open sea to the west. (Leachate is the formation of highly contaminated water that forms after rainwater passes through the waste). The mixed waste is dumped in random piles and eventually burned. There are no burial cells or trenches at the site, and no compaction or covering of trash with fill material.
90. A solid waste management plan has recently been developed by the ADB (2020) as Proposed Grant for Additional Financing as the Ebeye Solid Waste Management Project.
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Figure 8: Ebeye Dumpsite Conditions
Figure 9: Ebeye Dumpsite Location
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V. ANALYSIS OF ALTERNATIVES
A. No Project Alternative
91. Compared to the with-project scenario, the without-project scenario would see continued inefficient and ineffective water and sanitation management. There would be continued incidence of intestinal disease outbreaks from contaminated household and public water sources, and from public exposure to sewage.
B. Discussion of Alternative Solutions
92. Water System Improvements. No practicable alternatives to the proposed rehabilitation of the existing reverse osmosis water plant were evident, as no significant alternative water sources exist.
93. Wastewater System Improvements. Originally, those households not provided with connections, will be serviced by public toilet facilities. The outcomes of the review for improvements to onsite sanitation treatment systems in the communities of Loi and Ebwaj (approximately 50 households or 320 people) on the islets on causeway which links Ebeye and Guegeegue will met be with future budgetary planning for upgrades to be implemented under future projects.
VI. ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES
94. The potential environmental and social impacts of the proposed subprojects have been assessed in line with ADB's Safeguard Policy Statement, including assessment of the possible benefits and impacts with regards to (i) sustainable natural resource management; (ii) pollution prevention and abatement; (iii) health and safety; and (iv) climate change. Similar to previous ADB initiatives that improved water and sanitation services in Ebeye the project will generate significant environmental and related benefits, with minor adverse environmental impacts incurred during Project implementation and operations.
95. The subprojects will improve existing water and sanitation accessibility to the population of Ebeye in a highly modified built environment, and densely populated community.
A. Design and Pre-construction Impacts
1. Impacts on Physical Resources
96. These impacts relate to topography, geology, and soils impacts, and consideration of climate change, for the subproject at the design and pre-construction stage. Also considered, at this stage, is the appropriate implementation of mitigation measures, to monitor and ensure compliance with environmental regulations and provide environmental and social protection.
97. Proper implementation will ensure continuously improving environmental protection activities during design, construction, and operation in order to prevent, reduce, or mitigate adverse impacts. Inclusion of mitigation measures in contract documents for all subprojects, and assurance that the PMU (KAJUR), has adequate capacity to implement the EMP, including training of contractor personnel in the requirements of the EMP, will eliminate or minimize
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anticipated impacts. The EMP will require updating following the detailed design phase.
98. Mitigation measures include: (i) All land acquisition and resettlement issues are resolved. (ii) Under the Public Water Supply Regulations, where the proponent initiates construction of a new public water system or increases the capacity of, or modifies an existing public water system, the proponent shall notify the Authority, and submit with such notification a conceptual, descriptive plan with appropriate drawings detailing proposed location, water source capacity, budget estimates and other data as described in Regulation 6. (iii) Appropriate environmental mitigation and monitoring measures are included in the environmental management plan (EMP). The proposed environmental mitigation measures will form part of the design documents for the project and will be adequately budgeted and included in the contracts for procurement of goods and services. All contractors and subcontractors will be required to comply with the EMP. (iv) Contract tender documents will direct the contractor to provide qualified staff for environmental, safety and health, management, and monitoring, as specified in the construction EMP (CEMP). (v) Submission of a construction environmental management plan will be required by the contractor, through the PMU. The plan will address erosion and sedimentation control (for land-based works), waste and materials management, control plans for traffic, noise, and dust.
99. Climate Change/Natural Hazard considerations. Planning for the potential impacts of climate variability, and natural hazards, will help to mitigate against potential impacts which may include: (i) sea water inundation resulting in failure of water, wastewater, and electrical systems infrastructure; (ii) increased risk of contamination for the community and near shore marine waters from sewage overflows.
100. Mitigation measures include (i) planning new infrastructure at a suitable elevation above the current high tide level (utilizing accurate topographic survey), and (ii) ensuring new infrastructure is designed to withstand extreme weather events, such as sea water inundation.
101. Topography, geology, and soils. For all subprojects, land-based earthworks will not have significant impacts on the existing topography, geology, and soils; the majority of site works will be located in the same footprint as the existing water, wastewater, and electrical infrastructure. Ebeye, being an atoll island is very flat, with elevation differences of about six meters. Soils are uniform, extremely well drained, coral rubble and carbonate sand.
102. Construction permits. Permits will be obtained from RMIEPA for Earthmoving activities.
2. Impacts on Ecological Resources
103. There will be limited land-based earthworks, and these will not have significant impacts on the existing topography, geology, and soils, or significant terrestrial habitat. The terrestrial ecology has been extensively modified by the built environment, and introduced species, in all areas. There are no protected sites in the project area. No mitigation for terrestrial ecological impacts is necessary.
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104. Mitigation measures include avoiding and/or minimizing the requirement for disturbance of surface soils in the design phase wherever possible.
3. Impacts on Socioeconomic Resources
105. Land acquisition and resettlement. All three infrastructure subprojects do not involve land acquisition and resettlement. Instead it would involve legalization of, and potential compensation for the formal acquisition of private lands that have long been occupied by the public utility infrastructure and currently operates under de facto control. In the 1980s the Kwajalein Atoll Development Authority (KADA) was established as a result of the first U.S.-RMI Compact of Free Association. KADA signed a comprehensive land lease agreement with the landowners of Ebeye that dedicated existing and planned road and utility corridors to public use “in perpetuity” and “for no additional compensation” while also securing annual lease payments for the remainder of the leased area, specifically including the land underlying all existing and planned government facilities on Ebeye. 106. When KADA was dissolved in the 2000s, KAJUR nor any other entity did not take over the lease, as U.S.-RMI Compact funds were being used to subsidize KAJUR’s operating losses rather than paying the land lease. As a consequence, the lease was broken repeatedly by non-payment. A new Master Lease was negotiated in 2016. The Master Lease became effective on 21 October 2016 and will terminate on 20 October 2066. It covers all waste water facilities, water facilities, powerplant and associated areas, sea-water reverse osmosis plant and associated tanks; and north and south fresh water head reservoirs, docks, public schools, hospitals, shelters, government office buildings, public recreational facilities, and other existing facilities for public use. This is on the condition that (i) the user continues to pay rent at the existing annual rate, and (ii) the facilities continue to be used for public purposes.
107. In summary, a due diligence report (DDR) for the additional financing has been prepared and confirms that it will not have any involuntary resettlement impacts as follows: Upgrading of the desalination plant. The upgrade will involve anti-corrosion protection treatment to pipes and equipment, minor structural improvements, and the addition of a back-up generator. The upgrading activities will be located within the existing KAJUR facility where the desalination plant is located. The KAJUR facility is under the master lease agreement. There will be no physical or economic displacement impacts. Installation of high voltage electrical switchgear. The high-voltage electrical switchgear will be located within the existing KAJUR power station. This KAJUR facility is under the master lease agreement. There will be no physical or economic displacement impacts. Installation of household fixtures. The additional financing will extend the household fixtures program. The program funds and installs household fixtures to support access to the water supply and sanitation services for poor households. The household fixtures program will not have adverse impacts on structures or assets. If there are unanticipated impacts during installations (such as accidental damage to personal property/assets) KAJUR will replace or fix the asset or provide compensation at replacement value.
108. Livelihood impacts are also not foreseen, although in regard to subsistence fishing, construction of the sewer outfall pipeline under the current project will prevent fishers from utilizing this specific area of reef, until the end of works. Once complete, the pipeline and concrete anchors will add additional physical structure to the reef, which will eventually be colonized by invertebrate biota, and fishes will be attracted and naturally orient to the structure, as observed along the
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existing outfall pipeline.
B. Construction Impacts
109. The project construction phase has the potential to result in adverse environmental impacts. The construction phase, which will occur over a 1 to 2-year period will involve construction of the infrastructure described in Section III. The proposed construction works have the potential to cause adverse environmental impacts to soil, water, air, and marine flora, and fauna.
1. Impacts on Physical Resources
110. Climate Change/Air Quality. Construction vehicles, equipment, and generators will emit greenhouse gases during the period of construction but will not be a significant contributor to overall greenhouse gases.
111. The RMI does not have air emissions standards, though solid waste regulations speak to the prevention of air pollution from the collection and disposal of solid waste. Construction vehicles, equipment, and generators will be serviced regularly to reduce emissions.
112. Water Quality. Earthworks associated with the project have the potential to result in increased sediment runoff entering the coastal marine environment. Minor earthworks will be associated with the household fixtures program by reducing household water wastage from faulty plumbing fixtures.
113. Water quality impacts from earthworks can be mitigated as follows: (i) Use of sediment retention fencing, berms, and sandbags around excavations to restrict the release of sediment from the construction site; (ii) Immediately re-vegetate and/or stabilize exposed surfaces and stockpiles of excavated materials; and
114. Disposal of spoil. Spoil amounts should be negligible as the construction footprint is very small.
115. Generation of solid wastes and disposal. Construction works will result in general waste and construction solid waste. Management of waste should include minimization, reuse, recycling through the use of multi-compartment collection bins, composting of solid waste where appropriate, regular collection, and disposal to the north dumpsite. However, it is noted that the amounts of general waste for recycling and composting generated by the project will not be significant.
116. Solid waste disposal impacts can be mitigated as follows: (i) Contactor will prepare a Waste Management Plan (WMP) as part of the CEMP to cover waste disposal procedures, and to include a spill cleanup plan; (ii) Multi-compartment collection bins will be provided by the Contractor for waste segregation and subsequent reuse and recycling; (iii) Burning of construction waste will be prohibited; and (iv) Solid waste will be collected from the work sites on a regular basis and disposed at the north dumpsite, under the direction of KALGov.
117. Hazardous materials. The use and storage of hazardous materials during construction can impact on physical soil and water resources if they accidentally spill or leak into the environment
38 and if hazardous materials are not properly disposed of. Mitigation measures include: (i) Hazardous materials that will be stored as part of the construction of the subprojects will be machinery fuels and oil. Hazardous waste in the form of used batteries, fuel drums and oily wastes may require disposal as part of the construction works. To mitigate the impacts of hazardous materials, use the contractor will be required to implement the following: (a) Hydrocarbons and toxic material will be stored in adequately protected sites consistent with international best practices to prevent soil and water contamination. (b) All areas intended for storage of hazardous materials will be quarantined and provided with adequate facilities to combat emergency situations. (c) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with international best practice (d) Ensure all storage containers are in good condition with proper labeling. (e) Regularly check containers for leakage and undertake necessary repair or replacement. (f) Store hazardous materials above possible flood level (g) Discharge of oil contaminated water shall be prohibited. (h) Used oil and other toxic and hazardous materials shall be disposed of off-site at a facility authorized by permit, or safely transported off island to an authorized facility. (i) Ensure availability of spill clean-up materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored.
118. Terrestrial ecology. Well over 90% of the Ebeye community area is built environment, which has displaced any former natural habitat. Observed fauna consists mainly of introduced species such as dogs, cats, and rats. Resident and migratory shorebirds are common along the fringing reef, though typically found away from the residential areas. No surface water resources, or associated flora and fauna, exist on Ebeye. Construction noise and dust will not have impact on any terrestrial habitat of value, and no mitigation is necessary. Clearing planting sites may cause permanent or temporal disturbances to vegetation. While no known protected flora species have been identified on the project sites, disturbance of vegetation should be minimized.
119. The project will not introduce any alien species that are not yet established in the region of the project or promote species that are known to be invasive in the given environments. All vessels carrying equipment and materials to the project will be subject to inspection by agriculture quarantine inspectors and may be refused entry into the RMI if they are known or suspected of being infected or infested with disease or pests.
2. Impacts on Ecological Resources
120. Mitigation measures include: (i) Prohibition of burning vegetation and residual bushes and grasses when clearing planting sites; (ii) Only cutting flora which are a direct obstacle to project infrastructure works; (iii) All vessels carrying equipment and materials for the project will be subject to inspection by agriculture quarantine inspectors.
3. Impacts on Socioeconomic Resources
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121. Construction camp, offices, and laydown areas. It is doubtful that a construction camp will need to be built, as the workforce will be small, but public accommodations are also very limited. There is one hotel in Ebeye and limited apartment rentals available. Given the density of development in the Ebeye residential area, any construction camp would need to be located at either the extreme north or south ends of the island, to avoid disturbance to residents. The KAJUR utility has sufficient laydown area at the power plant site to accommodate storage of materials and equipment. There is also another, smaller, storage facility, next to the existing sewerage treatment plant site, which could also accommodate the contractor. Temporary housing and offices, with laborers from off island, could create disturbances and conflicts. Impacts can be mitigated by the following: (i) laydown areas are established within KAJUR facilities; (ii) workforce accommodations and office facilities utilize the hotel or rental properties; (iii) any camps established are through the approval of KALGov, traditional leadership, and landowners; (iv) camps are provided with sufficient potable water, shower and toilet facilities (designated male and female); (v) all sites utilized for contractor facilities are restored to the landowner’s satisfaction at end of project. Site cleanup will be inspected and approved by KAJUR’s environmental manager; and (vi) the use of local labor to the greatest extent possible.
122. Worker health and safety. Worker health and safety requirements must comply with the Public Health and Sanitation Act, 1966, and the project will also comply with the World Bank Environmental Health and Safety Guidelines. The contractor will prepare a health and safety plan (HSP), including an activity hazard analysis (AHA); these will be subject to approval by KAJUR’s environmental manager and the DSC, prior to the start of any works. The contractor will appoint a competent person as safety manager, who will conduct initial training for workers, prior to the startup of works and hold weekly safety meetings through the project duration. Training topics will include review of the HSP and AHA, first aid.
123. Due to the novel coronavirus (COVID-19) pandemic, the HSP will also need to be updated to include preparedness and response procedures. This will include internationally recognized guidance and advice on matters such as World Health Organization. 2020. Considerations for public health and social measures in the workplace in the context of COVID-1920. Personal protective equipment (PPE) will be provided by the contractor and will include at minimum, safety boots, hardhats, high visibility vests, eye and ear protection, gloves and other protective clothing as necessary.
124. Potential impacts to worker health and safety include (i) unsanitary living and working conditions; (ii) contaminated food and water; (iii) communicable disease; (iv) air and noise pollution; (v) work site accidents. These potential impacts and prevention measures will be addressed in the HSP.
125. Mitigation measures proposed to ensure worker health and safety include: (i) contractor prepared Health and Safety Plan, including an Activity Hazard Analysis, approved by KAJUR environmental manager and the DSC; (ii) contractor appoints a competent person as safety manager, supervising all health and safety matters;
20 https://www.who.int/publications-detail/considerations-for-public-health-and-social-measures-in-the- workplace-in-the-context-of-covid-19
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(iii) contractor safety manager conducts initial worker training and review of AHA. Weekly safety meetings are conducted through the duration of project; and (iv) all workers provided with appropriate PPE, as issued by the safety manager. The safety manager trains all workers in the proper use of PPE.
126. Community safety. Impacts of concern to the crowded residential community of Ebeye will focus on contractor vehicle and equipment traffic safety, and work site safety. Residential streets are typically crowded, especially with the large child population on the island. As most residents do not own private vehicles and the main mode of transportation is by bicycle or walking, impacts on residential vehicle access will be minor. The road system is circular around the island, so if vehicle traffic is restricted in one area, locations can be accessed by traveling in the opposite direction. The contractor safety manager must prepare a comprehensive traffic safety plan, to be included in the HSP, with review and approval by KAJUR and KALGov. The safety manager will appoint full time traffic control personnel with stop and go signs, to direct local and construction traffic around all work sites. Work site access will be restricted by fences or other barriers to prevent residents, especially children, from entering unsafe areas. Mitigation for impacts includes: (i) contractor traffic safety plan, included in the HSP, and approved by KAJUR and KALGov; (ii) full-time traffic control personnel at all work sites; and (iii) restricted and controlled work site access.
127. Noise. Construction vehicle and heavy machinery operation has the potential to result in significant noise impacts. Noise volume of construction machinery is generally between 80 ~ 110 dB, while heavy vehicle noise intensity is generally about 90 dB, and general traffic about 60 dB. As most of the construction works will be within the urban parts of Ebeye or close to residential dwellings it will be important to reduce noise impacts where possible. Typical daytime residential noise level is 55 dB, noise from construction should be mitigated so that it does not exceed a maximum of 3 dB above this background level at the nearest receptor location off site.
128. Project equipment and machinery must comply with commonly accepted standards (such as Part 204 of US Federal Regulations-Noise Emission Standards for Construction Equipment (40 CFR 204)), and select low-noise technology and equipment, use of vibration dampers for equipment components with large vibration, and maintaining equipment in good repair. The use of construction noise barriers (typically temporary plywood wall structures) may be warranted for specific sites, such as pump station and treatment plant works, to provide abatement from noise impacts to nearby residents. The contractor safety manager will monitor noise levels at all work sites and document any complaints from residents, then take remedial action. Mitigation for noise impacts will include: (i) Construction vehicles and equipment comply with international standards for noise emissions; (ii) Vehicles and equipment are maintained in good working order; (iii) Construction works should be restricted outside the hours 07:00 and 18:00, or as agreed based on consultation with the community, KALGov, and RMIEPA; and (iv) The contractor safety manager will monitor noise levels at all work sites and document any complaints from residents, then take remedial action.
129. Dust. Coral dust and sand build up on the paved residential roads in Ebeye, as there is typically no road sweeping conducted by Public Works, and the lack of functioning storm water drainage exacerbates the problem. Mitigation for dust generation by construction works will require the contractor to keep roads in the vicinity of work sites cleaned of dust and sand to avoid impacts from fugitive dust, created by vehicles and equipment traffic.
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130. Sites of significance. Initial response from the Ministry of Interior, Historic Preservation Office (HPO) indicated that the presence of cultural or traditional features of significance are highly unlikely in the project area, especially as the project works will lie wholly within the footprint of the existing infrastructure. HPO will issue a letter of guidance to the project, once design is finalized and plans are submitted for review. (Stevens R. Titml, Historian, Ministry of Internal Affairs, Historic Preservation Office, pers. comm.). The project's National Community Participation and Development Specialist, and long-time Ebeye resident, affirms that no resources of cultural significance have been identified (Yumi Crisostomo, pers. comm.)
131. In case such resources are found, all construction work will be put to a halt and consultations will be held with the local authorities (KALGov), project staff, and HPO on how to proceed. Such events and the subsequent decisions and actions will be reported in the environmental progress reports. In any case, to mitigate impacts to cultural or traditional features found, the project will not remove any physical cultural resources unless explicit approval is granted from HPO and KALGov.
C. Operation Impacts
1. Impacts on Physical Resources
132. Greenhouse gases emissions. The provision of 440 kVA backup generator will produce greenhouse gases, however these will be minor.
2. Impacts on Ecological Resources
133. There will be only minor impacts on ecological resources during extension of the EWSSP household fixtures program repairing from faulty plumbing fixtures.
3. Impacts on Socioeconomic Resources
134. The water system improvements subproject will result in the consistent delivery of properly treated water to respective connected households. The improvements will reduce the incidence of contamination within the public system and reduce the reliance upon household water catchments, which are frequently contaminated, leading to reduced incidents of gastrointestinal infections (GI) infections.
135. Water system improvements, assuring consistent potable water from the tap, will alleviate hardships currently experienced in sourcing drinking water, and transporting the water to households. Many residents now carry water containers filled at the Kwajalein military base across on the ferry to the homes in Ebeye. The amount of purchased bottled water for drinking, and the subsequent plastic waste, will be reduced once the public is assured the supply is potable, and expanded water reticulation services more households. 136. The back-up power supply will maintain continuity of supply from the RO plant when the main power is not functioning so the previously mentioned public health benefits will be maintained consistently within the Ebeye population.
137. The ongoing external management support for the RO plant and capacity building program will contain to sustain the operation for the RO plant and provide the public health benefits.
138. The project's Hygiene Promotion Plan will further hygiene awareness and education, to
42 correct ineffective hygiene behaviors, especially among children. Fundamental both to reducing vulnerability to disease, as well as changing attitudes to practices that spread disease, is an understanding of the principles of personal hygiene. The Plan will encourage the use of safe KAJUR water by households. These efforts are aimed at a further reduction in the incidence of infections.
139. Poverty analysis. The project will assist the public utility company, KAJUR, to implement institutional reforms to enhance the financial and technical sustainability of the water supply and sewerage services together with the electricity services on which they depend.
140. The result will be a healthier and more productive population with fewer private and public funds spent on medical services and fewer work and school days lost to illness. Reduction of income poverty will thus be indirect through greater lifetime productivity and earnings together with lower medical expenses.
141. Ebeye is a very densely populated urban community where more than one quarter of all households are not connected to the public fresh water supply, more than one third are not connected to the public sewerage system, and less than half are connected to both systems. The unconnected households are almost entirely those that also suffer income poverty under which a quarter of all residents live on less than $1.00 per day with no significant subsistence income.
142. The project will reduce poverty of opportunity by improving and extending potable water and sewerage services to all residents. The project will also help institute lifeline rates for potable water, for sewerage, and for electricity so that all households can afford at least the necessary minimum of these essential urban services.
143. The project includes several pro-poor design features including. (i) The project will extend potable water to those community members that currently lack that infrastructure, which generally means to the poorest areas. (ii) The project will make connections to residences that currently lack water and will provide and install the necessary equipment so residents can use the services. Without such project support, the poorest people could not afford to connect to the services and thus would not receive the direct benefits of the project.
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VII. INFORMATION DISCLOSURE AND PUBLIC CONSULTATIONS
A. Legislative Framework for Public Consultation
144. Public participation and consultation in the evaluation of project design, planning and implementation is an important part of environmental impact assessment; it can directly reflect the public’s perceptions on environmental quality in the project’s area of influence. Relevant provisions in the local RMIEPA EIA regulation require public consultation through public disclosure, provision for submission of written comments, design review and RMIEPA approval.
145. ADB’s environmental guidelines also have detailed and strict requirements on public participation and consultation. The public consultation processes for this project therefore follow both the RMI requirements and the ADB requirements under the Access to Information Policy 2019.
B. Public Consultation Activities
146. During preparation of the additional financing, consultations were carried out with key project stakeholders on Ebeye to ensure that the final project design has stakeholder ownership and sustainably addresses the needs of project beneficiaries including the Government of RMI, the Kwajalein Leadership, the Kwajalein Atoll Local Government (KALGOV), KAJUR and more importantly, the wider Ebeye community. The affected people from with the project area were mainly concerned about the funding and implementation of the project, capacity of the implementing agency to operate and maintain the new systems; decision making processes for the future planning relating to water and sanitation; a strong expectation for reliable delivery of safe water, and a reduction in the occurrence of sewage overflows to mitigate public health risk and potential impacts to the marine environment. 147. The primary anticipated negative impacts included: (i) poor operation and maintenance of the facility resulting in poor performance and ongoing environmental impacts, and (ii) potential impacts to the marine environment. The stakeholder consultations also reinforced the current issues associated with the existing system, which included common concerns such as (i) disruption of water service and rationing, (ii) chronic overflowing of raw sewage to streets, houses, and yards, (iii) weak planning, monitoring and reporting, and enforcement to address overflows, (iv) weak communication on sanitation problems by responsible agencies and measures being undertaken to address them, (v) funding, (vi) perceived inaction and lack of information by government agencies to address sanitation problems (Table 1). 148. Results from these consultations were shared with the project feasibility team and incorporated into design. A summary of consultations held are included in Annex 1. During project implementation, KAJUR will also undertake the following: • consultations with nearby residents before the upgrading activities at the desalination plant; • quarterly meetings with the Project Steering Committee; • community-wide communications campaign about the household fixtures program; and • consultations with the communities of Loi and Ebwaj regarding their needs and feedback on onsite sanitation treatment system options.
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Table 1: Environmental Agency Consultations Findings
Stakeholder Identified Benefits Issues Forward Proposed Actions
1. National Government 1.1 Mr. Lowell Alik, General Improved water Need for enforcement of The project will provide Manager, Environmental and sewer permitting requirements the Environmental Protection Authority (EPA), systems will and enforcement of Management Plan (EMP), Majuro Office achieve permit conditions with necessary Mr. Julian Alik, Deputy compliance with Capacity building in information for permitting General Manager, RMIEPA KAJUR and KALGov requirements, and EPA regulations. for Operations and reporting capacity. The Concerns for Maintenance (O&M). project will provide maintenance of assistance to systems and possible KAJUR/KALGov in environmental developing O&M plans, impacts. including environmental protection and compliance.
149. Environmental information on the project was and will be disclosed. This IEE will be made available for review by interested stakeholders at the RMIEPA upon submission. In accordance with the requirements under the SPS, ADB shall post on its website the following documents submitted by RMI/KAJUR: (i) the final IEE, upon receipt by ADB; (ii) a new or updated EIA or IEE, and a corrective action plan, if any, prepared during project implementation, upon receipt by ADB.
VIII. GRIEVANCE REDRESS MECHANISM
150. To settle unforeseen issues effectively, an effective and transparent channel for lodging complaints and grievances has been established. Public participation, consultation and information disclosure undertaken as part of the IEE process have discussed and addressed major community concerns. Continued public participation and consultation has been emphasized as a key component of successful project implementation. As a result of this public participation and safeguard assessment during the initial stages of the project, major issues of grievance are not expected. However, unforeseen issues may occur. In order to settle such issues effectively, an effective and transparent channel for lodging complaints and grievances has been established (Annex 2).
151. In the event of a grievance, the basic stages established for redress are: (i) Stage 1. If a concern arises during construction, the affected person tries to resolve the issue of concern directly with the contractor and the project manager. If successful, no further follow-up is required. (ii) Stage 2. If the affected person is not satisfied with the reply in Stage 1, he/she can appeal to the local government after receiving the reply in Stage 1 and the local government must give a clear reply within 2 weeks. (iii) Stage 3. If the affected person is still not satisfied with the reply of local government, he can appeal to KAJUR. KAJUR, through the PMU, must report to the ADB project officer as soon as the complaint is recorded, by submitting relevant documents. KAJUR, the IA, must prepare a clear reply in consultation with the EPA (if applicable), and give it to the affected person within 30 days. (iv) Stage 4. If the affected person is still not satisfied with the reply of KAJUR, he/she can appeal to the Office of the First Secretary (EA), after receiving the reply of Stage
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3. The EA must report to ADB as soon as the complaint is recorded by submitting relevant documents and prepare a clear reply in consultation with ADB. The EA must give the reply to the affected person within 30 days. ADB project team will assess the situation, contact the affected people and government project counterparts and design, and implement the course of actions. Stages 1-4 will be further refined during the detailed design stage.
152. The GRM has been developed in accordance with the KAJUR policies and procedures, as well as ADB Safeguards Policy Statement. The GRM is designed to work within existing legal and cultural frameworks, providing an opportunity to resolve grievances at the project level. Specifically, the project GRM has been designed to: • be understandable, culturally appropriate, and accessible to project-affected persons, with its availability communicated to residents of the island; • address a wide range of grievances and concerns – both those based in factual data and those arising from perceptions or misperceptions; • be transparent and allow persons to submit a grievance at no cost and without retribution to the party that expressed the issue or concern; • protect the identity of the persons raising the grievance; • resolve concerns in a timely manner, via consultation with stakeholders, or forward any unresolved cases to the relevant authority; • report back to the community (through the Steering Committee) periodically on the types of cases and how they were resolved; and • be evaluated periodically to ensure that it is working effectively.
153. In addition to the established project specific channel above, ADB's overall accountability mechanism (2003) applies. The mechanism provides opportunities for people adversely affected by ADB-financed projects to express their grievances; seek solutions; and report alleged violations of ADB’s operational policies and procedures, including safeguard policies. ADB’s accountability mechanism comprises two separate, but related, functions: (i) consultation, led by ADB’s special project facilitator, to assist people adversely affected by ADB-assisted projects in finding solutions to their problems; and (ii) providing a process through which those affected by projects can file requests for compliance review by ADB’s Compliance Review Panel.
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IX. ENVIRONMENTAL MANAGEMENT PLAN
A. Introduction
154. Environmental assessment has determined that the Project will have less than significant impacts on the local environment. Subprojects can be implemented in an environmentally acceptable manner with appropriate mitigation measures to avoid or minimize the environmental impacts.
155. The EMP includes: (i) implementation arrangement, mitigating measures to be implemented, and (iii) required monitoring associated with the mitigating measures. It also describes institutional roles and responsibilities during pre-construction, construction, and operation phases.
B. Institutional Arrangements
156. The Office of the Chief Secretary is the Project executing agency and KAJUR is the implementing agency, operating through a PMU which will include various specialists. A project steering committee (PSC) provides strategic direction and guidance for the project, and the PSC will continue throughout the implementation of the Additional Financing. The PSC meets at least once every quarter. A project management unit (PMU) has been established within KAJUR and is responsible for the overall implementation of the project and additional financing, including ensuring that all land lease issues are resolved by the Government of RMI. Consultants have been recruited by the Government of RMI to assist the PMU to implement the project and to build capacity within KAJUR.
C. Project Management Unit
157. KAJUR has established a PMU to implement the Project. The PMU ensures compliance with assurances, including safeguards, and prepares and submits semi-annual safeguards monitoring reports. As the upgrading works at the desalination plant and power station, as well as the installation of the household fixtures will continue to be implemented by the original contractor, the PMU has already approved the Contractors’ Construction Environmental Management Plan (CEMP), Stakeholder Communication Plan, and Occupational Health & Safety (H&S) Plan. The PMU will include a Safeguards and Community Liaison Officer (SCLO). The SCLO will ensure that all subprojects are implemented in accordance with the Project’s environmental assessments and development consents are obtained, and compliance with each subproject EMP and development consent conditions is monitored and reported.
D. Construction Contractors
158. The contractors undertaking the works will be responsible for ensuring that their activities comply with the environmental safeguard requirements of the contract including the technical specifications. The contractor will revise the CEMP for review and approval by the PMU. The CEMP will be activity, site and subproject-specific and detail how the contractor intends to meet the environmental management requirements identified in the EMP of the IEE. It will be designed to ensure that appropriate environmental management practices are applied throughout the construction period. The CEMP will include all of the site-specific and sub- plans necessary to meet the standards and targets set out in the EMP. The contractor will be required to employ a full-time environmental health and safety officer (EHSO) to ensure compliance with all requirements concerning environmental, health and safety, and labor regulations during
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construction.
E. MIREPA
159. The EPA will review the development consent applications and issue, either with or without conditions. The EPA will be invited to participate in joint inspections and audits during construction activities.
A summary of the environmental management responsibilities for the Project is presented in Table 2 160. Table 2.
Table 2: Summary of Environmental Management Responsibilities in the Project
Project Implementation Management Roles and Responsibilities Organization Asian Development • Review and approve IEEs/EMPs Bank • Review bidding documents • Review executing agency and implementing agency’s submissions for procurement of goods, equipment, works and services • Conducts project review missions, midterm review mission and project completion review mission to assess project implementation progress of all outputs, compliance of project to covenants including safeguards requirements • Review semi-annual and annual EMR
Office of the Chief • Guide and monitor overall project execution Secretary • Financial oversight (executing agency) • Ensure flow of funds to the implementing agency and the timely availability of counterpart funding
Project Steering • Responsible for oversight and providing guidance and strategic direction Committee (PSC) to XXXXX with respect to project implementation • Ensure that the PMU is provided with the necessary resources to effectively carry out its duties and responsibilities.
KAJUR • Responsible for overall project implementation and monitoring at the (implementing implementing agency level agency) • Ensure adequate funding available for the PMU • Submit semi-annual and annual monitoring reports to ADB • Assist in resolving complaints brought through the GRM that have not been resolved at lower levels KAJUR Project • Responsible for overall project management, implementation and Management Unit monitoring • Review and coordinate evaluation of bids for works, goods, and consultant services • Responsible for xxxxx’s application for a Development Consent • Prepare the IEEs and EMPs based on the detailed design and submit to ADB for clearance • Ensure environmental safeguard concerns are incorporated in the detailed engineering design • Disclose safeguard documents, as appropriate • Conduct awareness and consultations as per the CCP • Monitor on site construction progress and quality • Engage as appropriate specialist consultants in order to complete specific
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Project Implementation Management Roles and Responsibilities Organization engineering inspections as required • Receive and a response to all contractor related requests for information, extensions of time and variations. • Arrange and attend regular progress meeting on site • Recommend changes to the drawings, specifications and program for the employer’s approval. • Submit monthly, quarterly, semi-annual, and annual monitoring report to XXXX Management • Review and clear the CEMP of contractors • Review contractor’s monthly reports • Implement the GRM and maintain records of complaints/ grievances • Ensure the contractor observes the GRM requirements • Ensure contractor compliance with required resources for mitigation measures as reflected in the CEMP PMU Safeguards • Ensure IEEs/EMPs are updated based on changes in site conditions, if and Community required, and ensure their disclosure in locations and form accessible to the Liaison Officer public; (SCLO). • Coordinate with the preparer of bid documents for the inclusion of IEEs/EMPs and CEMP frameworks in the bidding documents and civil works contracts; • Ensure required government permits and clearances acquired by XXX prior to actual construction activities; • Establish system for monitoring environmental safeguards of the Project as described in the IEEs/EMPs; • Review, monitor, and evaluate the effectiveness of implemented mitigation measures and recommend corrective actions whenever necessary; • Prepare monthly environmental monitoring reports for consolidation to the semi-annual monitoring reports for XXX and ADB; • Ensure grievance redress mechanism is activated prior to the start of construction; • During construction, conduct site visits and coordinate with the project engineers to ensure that required environmental mitigation measures are implemented at the construction sites, and • Coordinate with the contractors’ environment and safety officers to ensure that environmental awareness trainings for workers are done. Contractor • Prepares and submit prior to construction the CEMP for review by PMU’s Environment Specialist for approval by PMU • Understand the EMP requirements and allocate necessary resources for implementation • Activates an Environmental Health and Safety Officer (EHSO) to ensure that the contractor complies with all requirements concerning environmental, health and safety, and labor regulations during construction • Implement construction activities with the required mitigation measures • Conduct environmental monitoring as required by EMP • Act promptly on complaints and grievances concerning the construction activities in accordance with the project’s GRM • Submit monthly progress reports on CEMP/EMP implementation to PMU EPA • Responsible for processing of XXX’s application for a Development Consent • Monitors construction progress for compliance with the terms of the issued Development Consent • Monitors implementation of the mitigation measures and the EMP in general
F. Environmental Mitigations and Monitoring Matrices
161. The EMP (including monitoring requirements) is presented in Table 3.
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Table 3: Environmental Mitigation and Monitoring Plan of Household Fixtures Program by Reducing Household Water Wastage from Faulty Plumbing Fixtures
Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored PRE-CONSTRUCTION
Climate change Climate change adaptation Part of Contractor PMU Engineering Verify PMU Cost vulnerability of all measures are: (i) results of detailed drawings and engineering household fixtures engineering assessment on design cost specifications drawings and projects potential site erosion of the considered specifications routes involved with climate upgrades. change adaptation features
Implementation of Tender documents and Part of Contractor PMU CEMP CEMP submittal To be all of the construction contract of the contractors' prepared by by contractors to undertaken as household fixtures household fixtures bid cost contractors PMU/ prior to per contractor’s projects into the projects will include commencement contract project’s EMP provisions that will: (i) of site works require the contractors to prepare their respective Contractor's Environmental Management Plan (CEMP) prior to the start of the construction activities with details of staff, resources, implementation schedules, as well as monitoring and reporting procedures; (ii) issue a CEMP framework as guidance for the contractor in preparing a CEMP as part of his bid proposal; and (iii) require the PMU to review and approve the CEMP prior to site mobilization.
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored
Complaints due PMU and the contractors Part of Contractor PMU Consultation Verify meetings PMU Cost to project- will: (i) establish the contractors' and PMU meetings; documentation; related impacts approved project’s bid cost specific Verify tender grievance redress provisions in documents; verify mechanism (GRM); (ii) tender the in-placed publicize the existence of documents CACs/ after the project’s GRM through on completion of public awareness nuisance & meetings, once campaigns, website, problems to after tender billboards, public public; documents notifications, etc.; (iii) prepared ensure that the names and contact numbers of representatives of the contractors and the PMU are placed on notice boards at agreed locations and/or website.
Disruption of KAJUR and the contractors Part of Contractor PMU Contractor’s verify PMU Cost utilities and will: (i) coordinate with the contractors' bid and PMU coordination contractor’s services other utilities companies cost with the other coordination regarding the potential utility meetings and disruptions; (ii) make companies; notifications/ provisions to preserve the notification of after completion operation of current affected of meetings and facilities, and households notifications (iii) affected households and and establishments will be establishments notified well in advance of such disruptions.
Disposal of The PMU will: (i) require the Part of Contractor PMU Contractor’s PMU disposal PMU Cost excavation contractors to submit a plan contractor’s disposal sites’ spoils for the disposal of excess bid cost plan for inspection/ after excavation spoils, and (ii) excess contractor’s undertake inspection and excavation submittal approval of the contractors’ spoils suggested disposal sites prior to actual construction
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored
Potential damage to Tender documents and Part of Contractor PMU Specific verify tender PMU Cost unknown construction contact will contractor’s bid provision in documents/ archaeological and include a provision that will: cost tender once after cultural assets (i) require construction documents tender activities to be stopped on documents immediately upon discovery archeological prepared of any unknown / cultural archaeological and cultural relics assets; and (ii) the contractor will promptly inform the local authorities and the Chuuk State National Museum CONSTRUCTION
Soil erosion and The contractor will divert Part of Contractor PMU Disturbed Visual inspection PMU Cost sediment loss from surface runoffs away from contractors' sites; use of of sites; plans construction sites the exposed areas and bid cost appropriate verification/daily prevent sediments from sediment during rainy moving offsite. Measures controls periods may include, as appropriate for site conditions: (i) small interceptor dikes, (ii) pipe slope drains, (iii) grass bale barriers, (iv) silt fence, (v) sediment traps, and (vi) temporary sediment basins; total exposed area will be minimized as the conditions allow.
Oil and other To prevent accidental Part of Contractor PMU Measures Visual inspection PMU cost hazardous releases, where required, contractors' required to of sites; records materials the contractors will bid cost prevent verification/ daily releases. implement the following: (i) accidental provide, if required, releases; maintenance shops, fuel measures for and oil depot with clean-up and impermeable flooring with handling of sump where wash water contaminated
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored and sludge can be collected materials; for proper disposal; (ii) training refueling and servicing of records of equipment should only be personnel for carried out in specified hazardous areas adequately equipped materials; to avoid leaks and spills that records of could contaminate soil and accidental water resources; (iii) releases chemicals, hazardous substances and fuel will be stored on-site within an enclosed and covered secure area that has an impervious floor and impervious bund around it, (iv) storage area will be located away from water- courses, flood-prone areas and danger areas, (v) equipment maintenance areas and fuel storage areas will be provided with drainage leading to an oil- water separator that will be regularly skimmed of oil and maintained to ensure efficiency; (vi) regularly check containers for leakage and undertake necessary repair or replacement; (vii) store hazardous materials above flood level; (viii) ensure all storage containers are in good condition with proper labeling; and (ix) store waste oil, used lubricant and other hazardous wastes in tightly sealed containers to avoid contamination of soil and
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored water resources; Measures for clean-up and handling of contaminated materials include: (i) undertake immediate clean-up of spills, (ii) oil stained wastes and used oil should be collected and disposed of through recyclers/ authorized waste handlers and disposal in authorized waste facilities; (iii) ensure availability of spill cleanup materials such as absorbent pads, (iv) restoration of temporary work sites will include removal, treatment, and proper disposal of oil contaminated soils, (v) discharge of oil contaminated water into the environment will be prohibited; and (vi) construction personnel designated to handle of fuels/hazardous substances will be trained particularly in spill control procedures.
Onsite dust The contractor will be Part of Contractor PMU Dust Visual inspection PMU cost due to required to do the following: contractors' generation, of sites/ daily construction (i) regular water spraying of bid cost water spraying, activities roads, work areas and other cover of construction-related stockpiles, facilities to minimize dust smoke emitting generation; (ii) construction equipment, materials stockpiles and open burning of spoils with potential for materials significant dust generation to be covered or sprayed with water, as appropriate, to prevent fine materials
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored from being blown; (iii) prohibit use of equipment and vehicles that emit dark sooty emissions; (iv) hauling trucks transporting loose construction materials such as sand, gravel, and spoils to be provided with tight tarpaulin cover or other suitable materials to avoid spills and dust emission; and (v) prohibit burning of all types of wastes generated at the construction sites, as well as other project-related facilities and activities.
Solid waste The contractor will be Part of Contractor PMU Construction Visual inspection As per management required to: (i) provide contractors' wastes: of sites/ daily contractor’s garbage bins and facilities bid cost waste contract within the project site for separation, temporary storage of temporary on- construction waste and site waste domestic solid waste; (ii) storage, separate solid waste into regular hazardous, non-hazardous disposal and reusable waste streams records, and store temporarily on- surplus site in secure facilities with materials not weatherproof flooring and removed roofing; (iii) ensure that upon wastes are not haphazardly completion dumped within the project site and adjacent areas; (iv) regular disposal of wastes to the local Landfill; (v) prohibit burning of all types of wastes; (vi) remove the construction wastes from the sites after work completion, and (vii)
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored implement the required restoration of disturbed sites.
The CEMP shall contain a waste management plan and describing all waste types, amounts, disposal method, transport documentation requirements, and details of licensed waste treatment/recycling facilities for each waste stream.
Construction The contractor will control Part of Contractor PMU Noise levels Use of sound As per noise and noise generation from their contractors' not to exceed levels meter; contractor’s vibration activities near residential bid cost 55 dB(A) near visual inspection contract areas. The contractor will: residential of sites/ daily (i) provide prior notification areas during to the community on daytime and schedule of construction 45 dB(A) for activities; (ii) provide noisy nighttime; equipment with noise noisy reduction covers whenever equipment applicable; (iii) position not to be stationary equipment that operated produce elevated noise between levels, such as diesel 19:00 generators and air – 06:00hrs; compressors, as far as regular noise practicable from houses level monitoring and other receptors; (iv) by contractor prohibit operation of noisy equipment and construction works in populated areas and where sensitive receptors are found during nighttime (19:00 – 06:00); (v) make prior notification and consultation with the affected people and local
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored officials for necessary nighttime operation; (vi) locate concrete batching plant, and rock crushing plant at a reasonable distance away from inhabited areas and sensitive receptors; and (vii) conduct regular noise level monitoring to determine compliance with WHO guidelines for noise which should not to exceed 55 dB(A) near residential areas during daytime and 45 dB(A) for nighttime
Vehicular The contractor will: (i) Part of Contractor PMU Contractor’s Traffic plans PMU traffic prepare a traffic plan and contractors' traffic plan verification; visual congestion and provide traffic management bid cost and traffic inspection of hindrance to personnel to direct the flow management sites/ daily public access of traffic in the vicinity of the personnel; construction sites and traffic signs in construction-related vicinity of facilities; (ii) closely construction coordinate with local sites; authorities for any closure contractor’s of roads or rerouting of work vehicular traffic; (iii) provide schedule traffic signs in the vicinity of related to the construction sites to festivities, direct motorists and processions, pedestrians; and (iv) parades, etc. minimize disruption to local activities by timing the construction activities with consideration to the schedules of festivities, processions, parades, etc. The contractor will: (i) use Community barriers and install signage Part of Contractor PMU/ Work sites Work sites safety As per health and to keep the public away contractors' Contract safety plan; plan verification; contractor’s
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored safety from constructions sites and bid cost or warning visual inspection contract/ PMU excavation sites; (ii) provide signs, of sites/ Cost security personnel in barricades, daily/weekly hazardous areas to restrict and night All aspects of the public access; (iii) operate lamps for labor influx construction night light at open management the vicinity of construction excavations, plan. visual sites; and (iv) whenever lighting inspection of necessary, provide system for sites/ daily/weekly adequate safe nighttime passageways for the public operations; crossing the construction adequate sites whose access to safe properties, establishments, passageways etc. has been disrupted or for the public blocked by the ongoing crossing the construction activities. construction A labor influx plan will be sites. All required from the contractor aspects of the to address amongst others: labor influx (i) Measures to minimize management contact with local residents plan. to prevent the risk of spread of communicable diseases including STI’s and HIV as well as potential COVID 19. (ii) induction of all workers on Project requirements regarding safeguards (including child protection), GRM and CCP requirements; (iii) agreement to and implementation of protocols (including code of conduct) concerning the workers contact with the local communities; (iv) ensuring that sufficient water supply and temporary sanitation facilities are provided for workers at work sites in
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored order that community infrastructure is not over- burdened; (v) security at contractor’s yard to control unauthorized access and prevent entry of the public (especially children).
Occupational The contractor will Part of Contractor PMU Health and Health and As per health and implement good practices of contractors safety plan; safety, plan contractor’s safety at work occupational health and bid cost first aid verification; visual contract sites safety at the construction station; PPE, inspection of sites by: (i) implementing a sanitation, sites/ daily/weekly construction site health and facilities; safety management plan firefighting (CSHSMP), (ii) ensuring equipment that an equipped first aid and fire station is available at all extinguishers times, (iii) providing the workers with potable water and adequate sanitation facilities, (iv) providing the workers with personal protective equipment (PPE) to minimize exposure to a variety of hazards, and (v) providing firefighting equipment and fire extinguishers in workshops, fuel storage facilities, and any sites where fire hazard and risk are present.
Monitoring and During the pre-construction Part of Contractor PMU Specific Verify that these As per Reporting phase any gaps in the specs provisions on aspects are contractor’s baseline will be filled. It is in preparation environmental incorporated in contract the pre-construction phase cost monitoring in the said where requirements for the: (i) project documents environmental monitoring in specifications, during the construction phase can (ii) bidding submission of the be legally required by documents, draft documents placing specific provisions and (iii) and later during
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Environmental Aspects/ Proposed Mitigation Means of Issues/ Potential Mitigation Supervision/ Parameters Monitoring Measure or Enhancement Implementation Monitoring/ Environmental Cost Monitoring to be Cost Measure Frequency Impact monitored on environmental construction submission of the monitoring in the: (i) project contracts. draft final specifications, (ii) bidding documents. documents, and (iii) construction contracts. Relevant aspects of each subproject’s EMP shall be incorporated in these documents. The PMU shall verify if these aspects are incorporated in the said documents first during submission of the draft documents and later during submission of the draft final documents. OPERATIONS
Public health Mitigations include: (i) Part of KAJUR’s KAJUR’s Schedule of Verify regular Visual risk due to identification of potential KAJUR’s operations Operatio inspection inspection and inspection unplanned causes of unplanned operational personnel ns Dept. and maintenance outages and outages and emergencies cost Mgt. maintenance emergencies shall be conducted during of water of the water operation of the water supply supply system supply system and updated systems as necessary;
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X. MONITORING AND REPORTING
162. Environmental monitoring is required across all phases of subproject implementation. The monitoring meets two objectives to ensure: (i) that mitigation measures are effective in reducing/managing impacts, and identify corrective actions as required; and (ii) that safeguard requirements are being complied with by the contractor and the implementing agency (on behalf of government).
163. Pre-construction monitoring. During the pre-construction phase any gaps in the baseline will be filled. It is in the pre-construction phase where requirements for environmental monitoring in the construction phase can be legally required by placing specific provisions on environmental monitoring in the: (i) project specifications, (ii) bidding documents, and (iii) construction contracts. Relevant aspects of each subproject’s EMP shall be incorporated in these documents. The PMU shall verify if these aspects are incorporated in the said documents first during submission of the draft documents and later during submission of the draft final documents.
164. Construction monitoring. Contractors are expected to implement the relevant aspects of each project’s EMP as per their approved CEMP during execution of the construction activities as stipulated in their contracts. The contractors’ CEMP will detail the monitoring plan (based on the subproject EMP) with details on staff, resources, implementation schedules, and monitoring procedures (parameters, frequency etc.).
165. Compliance with the approved CEMP will be the basis for inspections and audits by PMU and the ADB. The BCD will include provisions requiring the contractor to submit their CEMP which will include a section on monitoring which should be linked to allocation of budget and staff for implementation.
166. Reporting. Overall, the Project will establish a system of reporting. The contractor will prepare monthly reports which will include a section on compliance with the approved CEMP, corrective actions, training and the like. This will also record any grievances lodged and project communications undertaken by the contractor. The PMU will review and consolidate information from the monthly reports of all subprojects. The quarterly progress report (QPR) prepared by the PMU will include a section on safeguards implementation summarizing the monthly reports (including training and capacity development activities).
167. A semi-annual safeguard monitoring report will be submitted to ADB. This report will be based on the QPR and will include the environmental performance of each subproject/component.
168. Institutional arrangements. The Office of the Chief Secretary is the executing agency, while KAJUR is the implementing agency for the Project. The project steering committee (PSC), is responsible for oversight and providing guidance and strategic direction to CUPC with respect to project implementation. KAJUR has established a project management unit (PMU) to implement the project. The PMU is responsible for overall project management, project delivery, safeguards implementation, and monitoring.
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XI. CONCLUSION AND RECOMMENDATIONS
169. The project covered in this assessment offer benefits to Ebeye by ensuring an upgraded supply of potable water.
170. The environmental screening process has identified and addressed the minor nature of the environmental issues of the proposed projects. All projects are located in urban/peri-urban locations which are highly modified.
171. Based on the potential environmental impacts and risks of the proposed projects, there are no significant negative environmental impacts or risks that cannot be mitigated or managed. The EMP prepared will be used as the basis for preparation of the CEMP to be prepared by the contractor. Monitoring and reporting of the approved CEMP will ensure that each project can be implemented in an environmentally acceptable manner.
172. A detailed Resettlement Plan is not required but a due diligence report has been prepared and a consultation program has been undertaken with the community and the relevant authorities. This program is ongoing.
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BIBLOGRAPHY
Auckland City - Overview of the Effects of Residual Flocculants on Aquatic Receiving Environments – TP 226 - www.aucklandcity.govt.nz › documents › technical publications ›
Asian Development Bank. 2017. Guidelines for climate proofing investment in the water sector: Water supply and sanitation. Manila.
Asian Development Bank. 2004. Omnibus Infrastructure Development Project. Manila. The CPUC reforms commenced in 2010.
Asian Development Bank 2019. Project Readiness Financing Report. Federated States of Micronesia: Preparing the Chuuk Water Supply and Sanitation Project. Manila.
Asian Development Bank 1996. Water Supply and Sanitation Project. Manila
Asian Development Bank 2008. Weno Water Supply Well Remediation Project. Manila
Asian Development Bank 2019. Country Operations Business Plan: 11 Small Pacific Island Countries, 2020–2022. Manila.
Asian Development Bank 2018. Draft Marine Ecological Assessment – Honiara Port Development Project. Trade & Transport Facilitation in the Pacific: Regional Transport Sector Study (TA 8674- REG).
Dilley, M and others. 2005. Natural Disaster Hotspots - A Global Risk Analysis. The International Bank for Reconstruction and Development / The and Columbia University. Washington, DC.
International Finance Corporation. 2017. General EHS Guidelines: Environmental, Air Emissions, and Ambient Air Quality. Washington, DC.
Government of the Federated States of Micronesia. 2011. Summary Analysis of Key Indicators from the FSM 2010 Census of Population and Housing. Palikir. More recent data is unavailable.
World Health Organization. 2017. Guidelines for Drinking-Water Quality. 4th Edition. Geneva.
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APPENDIX 1 – Consultation Summary Introduction The Asian Development Bank (ADB) is presently working on a Project Readiness Financing (PRF) undertaking in Ebeye to assist the Kwajalein Atoll Local Government in preparing the Ebeye Solid Waste Management Project (ESWMP) and assist KAJUR with the Ebeye Water Supply and Sanitation Project (EWSSP) – Extra Financing. Outputs from the PRF are intended to ensure a smooth transition from preparation to design and implementation of the projects, and to minimize contracting delays and guarantee rapid projects start-up. A Project Preparation Facilitator was engaged on 06 May with an estimated completion date of 14 August 2020. This report covers project preparation activities for the months of May and June 2020.
In general, the role of the Project Preparation Facilitator is to facilitate surveys, discussions and agreement with key project stakeholders on Ebeye to ensure that the final project design has stakeholder “ownership” and sustainably addresses the needs of project beneficiaries including the Government of RMI, the Kwajalein Leadership, the Kwajalein Atoll Local Government (KALGOV), KAJUR and more importantly, the wider Ebeye community. However, it was recognized at the onset that the narrow window of opportunity to secure project financing and the inability of international project experts to travel to Ebeye were huge challenges facing this project engagement. It was therefore a huge relief for national consultants in Ebeye to receive support from two local experts from the ADB office in Majuro who traveled to Ebeye for two weeks during this period to provide technical support to national consultants in Ebeye.
Community Consultations Prior to engaging the community in survey and data collection activities, coordination meetings were held with KALGov and the Kwajalein senior Alap (Jesse Riketa) to schedule consultations with Iroijlaplap Mike Kabua, the mayor and local council, and the senior land owners (Alaps) of Kwajalein Atoll. The list below outlines consultations that were completed during this period: 1. Asst Secretaty Glorine Jeadrik (MoHHS) …… May 12, 2020 (Romeo) Iroijlaplap Mike Kabua ……………………………… May 14, 2020 (Romeo, Yumi & Alap Jesse) Kwajalein Atoll Local Council & Alap ………… May 25, 2020 (Romeo, Yumi & Scott) Business Community ……………………………….. May 28, 2020 (Romeo & Yumi) Refuse Collection Crew ……………………………. May 31, 2020 (Romeo & Yumi) Mayor Hirata Kabua …………………………………. June 11, 2020 (Romeo, Yumi, Ellen, Denise, Scott) GM Joe Pedro (KAJUR) ……………………………… June 11, 2020 (Romeo, Ellen & Denise) The primary focus of these initial consultations was to ensure that key government and traditional leaders are aware of the two projects being proposed for Ebeye. Additionally, in a small and closely-knit community such as Ebeye, it is culturally and politically appropriate, even necessary, that leaders are aware of these planned survey and community-wide consultations before these activities take place. Consequently, after project awareness and support was secured with the community leadership, national consultants and survey teams were able to seamlessly implement survey activities throughout the island community.
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Other planned consultations which have already been planned for the month of July after the ADB virtual mission include the following: 1. Kwajalein Education Association (KEA) ..….. Pending 2. Kwajalein Atoll Development Authority …… Pending 3. Gugeegue Community ……………………………. Pending 4. Ebwaj Community …………………………………… Pending 5. Looj Community ……………………………………… Pending 6. North Camp Community …………………………. Pending 7. Rest of Ebeye (Community Gym)……………… Pending The Project Preparation Facilitator had also proposed a Project Working Team with cross-representation from key organizations such as KALGov, KAJUR, PSS, MOHHS, Youth, Kwajalein NGO’s, and Kwajalein Alaps. The proposed Project Working Team’s listing is with KALGov awaiting membership confirmation. As conceptualized, this Project Working Team can later continue to serve as the Project Steering Committee during the project design and project implementation phases if KALgov and KAJUR accept this arrangement. Presentation Before the Local Council on the Ebeye Solid Waste Management Project (ESWMP) (1:00 PM, 25 May 2020)
The following is a brief synopsis of a presentation done by ESWMP National Consultant Team Romeo Alfred and Yumi Crisostomo before the Kwajalein Atoll Local Council on 25 May 2020 at the Local Government Conference Room in Ebeye, Marshall Islands. The Kwajalein Atoll City Manager, Scott Paul presented the request for this presentation to the Mayor. After receiving a positive response from Mayor Hirata Kabua, and with the understanding that there were other presenters at this council meeting including the Kwajalein Military Base Commander, The Minister of Health and Human Services, and the Kwajalein Atoll Development Authority, the ESWMP Team limited its presentation to only 15 minutes and reserved another five minutes to answer questions.
There were just three questions/comments raised by Iroijlaplap Iroij Mike Kabua, Councilman Telmong Kabua, and Alap Jesse Riketa. All three question/comments centered on sanitation services for communities along the causeway up to Gugeegue; primarily, whether sanitation services to these communities could somehow be included in the ESWMP. Iroij Mike Kabua’s comments were more pointed when he insisted that KADA and the Kwajalein Atoll Local Government seek budgetary allocations to provide for a larger sewage vacuum21 unit with greater capacity to service the needs of communities by the causeway as soon as practical. The full line-up of council members and alap (senior landowners) who were present at this meeting include the following:
Mayor Hirata Kabua 8. Council Member Conny Livai Iroijlaplap Michael Kabua 9. City Manager Scott Paul Council Member Telmong Kabua 10. City Clerk Capelle Antibas Council Member Morson James Jr. 11. Alap Jesse Riketa Council Member Tony Maika 12. Alap Nelson Bolkeim Council Member Michael Luther 13. Alap Rep. Juren Jatios Council Member George Luther 14. Alap Rep. Jerry Jacklick
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Council members listen to Iroijlaplap Mike Kabua explain the needs of communities by the causeway
Consultation with Ebeye’s Business Community on the Ebeye Solid Waste Management Project (ESWMP) (12:00 noon, 25 May 2020)
The following is a summation of a consultation between project team members in Ebeye and representatives from major business operations in Ebeye. The project team generated a list of ten questions to help promote lively discussion among the group. The list of questions is provided in attachment (A). Two major business operators (H2 Imports and Lucky Star) were not represented at this meeting as managers from these two business establishments were not available during the period this consultation was conducted. Businesses that were represented at this consultation included Triple J, DIY, Ebeye Fish Market, Best Choice, Bing’s Store, MIR (Ebeye Hotel), Bank of Marshalls, and Ralik Store.
General Description on the Existing Garbage Collection Service by the Business Community
Under the existing schedule, garbage in Ebeye is collected on Mondays, Wednesdays, Fridays, and Saturdays. On Tuesdays and Thursdays, garbage collection is done for communities along the causeway. Most businesses felt that the existing service is good, as long as equipment are functioning. Some businesses like Ebeye Hotel felt that their business generates waste much quicker than the frequency of collection service established under the existing collection schedule. Consequently, the hotel does its own garbage delivery daily and does not rely on the garbage collection service provided by KalGov. Similarly, Bank of Marshalls who also operates a retail and food establishment, does its own garbage delivery on a daily to basis. By their estimation, both Ebeye Hotel and Bank of Marshalls generate an average of three full bins daily. Other than Ebeye Hotel and Bank of Marshalls, all businesses rely 90% of the time on the garbage collection service provided by KALGov. The other 10% is for periods shortly after the arrival of the supply barge every two to three weeks when the stores generate more waste from new merchandise
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Business operators present include from left: Bruce Bevin (Triple J), Tom Butler (Ralik), Jesse (Best Choice), Samantha Inok (Ebeye Hotel) Romeo Alfred (Consultant), Patrick Bing (Meko Store), Loen Pam (DIY), Lise Sheet (Fish Market), and Yumi Chrisistomo (Consultant). causing huge garbage pile-up in their collection areas. During these periods, business operators supplement the collection and disposal efforts using their own vehicles.
Large businesses operations such as Triple J and DIY were issued the larger size garbage bins. However, based on information shared by these two retail/wholesale operators, they returned the bins that KALGov issued them and fabricate their own out of woods. Reason being that the bins issued to them were torn from improper use of forklift to lift the bin during garbage collection periods. The Ebeye Hospital ran into similar problem with its government issued garbage bin, and like Triple J, had to get rid of its plastic bin. The hospital now uses a fabricated wooden base garbage bin to contain its general wastes.
Overflowing garbage bins was also noted as a common occurrence among business operators. Some alluded this as another reason why they opted to build their own (larger) trash containers as oppose to using the large plastic container provided by KALGov which all feel inadequate for their needs.
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A huge tear at bottom of large plastic bin issued to Triple J (left). The wooden garbage RMI collection bin fabricated out wooden pallets (right) is what Triple J is using now.
Legislation banning plastic bags and foam products
All businesses who spoke on the existing legislations on plastics and foams products confirmed that these legislations are being enforced to some extent in Ebeye. Special consideration is given to produce (plastic) bags whereby plastic bags are allowed in the produce section area and used to carry fruits and vegetables. The Ebeye fish market is appreciative of the existing loose enforcement of the ban on plastic bags as it still uses plastic bags to sell its fish and ice. At present, all businesses understand and support the ban on plastic bags given the flexible nature of its enforcement. On the other hand, all businesses present find it unfair that the Container Disposal Legislation (CDL) tax on beer and soda has been enforced in Ebeye for a year now with no mechanism for recycling in place. As the imposed tax is passed down to consumers and no recycling program nor any recycling machines are available on island, the intended benefits to the community is simply not there. A grace period in implementing this CDL tax would have been a more fair and equitable approach for the Ebeye community.
Segregation of waste is NOT a common practice among business operators although Triple J does segregate its cooking oil. The main issue now is that they (Triple J) has no place to properly dispose of their used cooking oil.
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Open dumping is practiced by all the rest of the businesses when it comes to disposal of cooking oil. Oil from vehicles and equipment are being transported to the dumpsite for disposal.
On the subject of “Willingness to Pay”, the general feeling among business operators is that everyone should pay for that service. Based on their personal observation, all business felt that is much easier to collect payment for services from businesses than from individual members of the community. And that “everyone should pay a reasonable price” for the service. Unfortunately, some businesses observed that it is just as difficult to collect from the “needy” as it is from the “well off” members of the community.
Commenting on pests and rodents, most businesses do not associate the existing problems with flies and rats in Ebeye with businesses’ garbage management practices. It is obvious there is currently an infestation of flies. It used to be seasonal, but it’s been bad for over a year now. Yet, none of the businesses thinks it is linked to their garbage management practices.
Consultation with Refuse Collection Crew (KALGov)
The following information was taken from a consultation done between ESWMP national consultation project team and employees who are tasked with collecting solid waste throughout Ebeye and the communities along the causeway between Ebeye and Gugeegue. The crew consists of six employees. Only five employees are required to perform this daily operation, permitting normal operations to continue with one person out sick or on scheduled Paid Time Leave. Similar to the format used in the business community consultation, a set of eighteen basic questions were developed to generate discussions among the group. The set of questions are provided in attachment (B). This consultation was done on a Sunday, the only day that garbage collection is not performed.
Composition and Work Schedule
The six-man crew that makes up the Solid Waste Management team comprises of the following team members:
1. Hanner Nuka ………………………………………. Truck Driver & Team Leader 2. Romeak Leon ……………………………………… Truck Bin Operator 3. Kanel Benjamin ………………………………….. Truck Bin Operator 4. Ioseph Rowa ………………………………………. Refuse Collector 5. Takaio Hanchor ………………………………….. Refuse Collector 6. Tony Amlej …………………………………………. Refuse Collector The crew’s work schedule starts at 8 AM and ends at 5PM Monday through Saturday. Overtime is allowed when the team falls behind schedule and needed additional time to complete their scheduled collection. Their pick-up schedule is broken down into two primary areas of Ebeye Proper and communities along the causeway. The image below shows the tip of Ebeye (farthest right) and the rest of the islands connected by the causeway.
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In any given week, garbage is collected in Ebeye on Monday, Wednesday, Friday, and Saturday. Tuesday and Saturday are set aside for communities along the causeway. There are no specified pick-up points for the garbage truck. During scheduled days for pick-up, families just drag their wheeled garbage bins close to the roadside for easy pick up. Roughly 30 – 40% of bins in Ebeye and communities along the causeway have lost their wheels. In this case it requires two persons to carry these bins with no wheels over to the roadside for collection.
Tools and Equipment When asked about the adequacy of tools and equipment which are readily available for the Refuse Collection Team to use, the consensus among team members is that one garbage truck is adequate to do the job. However, one truck does not allow much time for the team to properly perform clean up and proper daily maintenance on the garbage truck. By the time they are done collecting, they are tired already and often delay cleaning the garbage truck to the next day or the following day. It is not uncommon for truck cleaning tasks to be delayed for three days. It is almost impossible to do maintenance on the truck because it is constantly used Mondays to Saturdays. The crew is forced to request repairs on the garbage truck only when they run into mechanical issues. In the event of mechanical break-down, the Refuse Crew uses a Front Loader and a regular Dump Truck (pictured below) to resume their island-wide garbage collection efforts.
On the topic of Personal Protective Equipment (PPE) the crew explained that they are providing for themselves. They do not have any protective coverall and had to provide for their own gloves, masks, and safety shoes. They understand that KALGov is under much financial stress and so they have to do with what they can provide on their own in order to protect themselves on the job. In addition to Personal Protective Equipment, the crew also expressed needs with pressure washer, raincoats, coverall, cleaning tools and of course higher pay. They pointed out that the lowest paid person is being paid $3.15/hr while the highest paid refuse collector gets $3.95/hr. With the going price of rice on Ebeye at around $10.00, a waste collector will have to work 2-3 hours just to earn a bag of rice.
Some Challenging Aspects in the Job of the Refuse Collection Team Improper handling of food waste products and especially adult and baby diapers that are tainted with human feces appears to be the number one undesirable aspect of their job. Some families just place these items in the garbage bins as they are, without using plastic or paper bags even to properly secure these wastes. Occasionally, these types of wastes would splatter on them if they are not careful. It was also noted that a common practice among families in Ebeye is dumping food wastes in the lagoon or ocean. Children are normally instructed by their older siblings to dump food waste products in this manner. We observed one such incident and took the photos below. In the incident we observed below, kids have somehow discovered an empty cooler a few yards from the ocean shoreline and uses it to dump their food wastes to avoid having to go all the way down to the shorelines. Flies and maggots were clearly visible, an indication that the cooler has been sitting there for several days.
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Two kids were observed dumping their family food waste in a cooler they discovered among Some a pile of concrete rubbles close to the ocean. Lagoon/ocean food waste dumping is common. families gather food wastes to feed pigs mostly in communities along the causeway as raising livestock is not permitted in Ebeye. One practice expressed by the team involves the common practice of just throwing their wastes on the ground expecting the refuse crew to gather and load their garbage manually onto the garbage truck. The crew believes that one reason behind this practice is that some families have either lost their garbage bins or their bins are no longer usable due to wear and tear. In either case, the local government is not able to replace old or lost receptacles because there are none available at the moment. The quantity of electric meters that were hooked up to various households throughout Ebeye and communities by the causeway was used to determine the quantity of bins to order. As such, 1,500 small bins and around 10 large size bins were distributed to businesses, schools, and government organizations. Commenting on the conditions of existing bins, the team observed that most are in pretty bad shape and needs to be replaced. If this is to be part of the plan moving forward, the team suggested that the ESWMP team may want to consider a slight modification on bin specifications to allow the next batch of garbage bins to last in Ebeye’s harsh and corrosive environment.
Pulling the 6-man refuse collection crew on their only day off to discuss garbage collection in Ebeye.
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Photo above provides some idea on how garbage bins are pulled from their usual locations immediately outside living quarters to roadside for collection during scheduled days for collection in Ebeye or communities by the causeway.
Appendix 2 – Grievance Redress Mechanism
1. Introduction
This Grievance Redress Mechanism (GRM) serves to address complaints or concerns by persons that may be impacted by the Ebeye Water Supply and Sanitation Project (herein referred to as ‘the project’). A grievance is an issue, concern, problem or claim (perceived or actual) that an individual or group wants Kwajalein Atoll Joint Utilities Resources Inc.(KAJUR), the project management unit (PMU) or one of its contractors to address and resolve. The GRM outlines the procedures in which grievances concerning the performance or behaviour of KAJUR, PMU, its contractors or employees will be accepted, assessed and resolved. The GRM aims to reduce impacts and risks of the project and promote mutually constructive and trust-based relationships with the residents of Ebeye.
2. Background
The purpose of this GRM is uphold the project’s social and environmental safeguards performance. It must be noted, however, that existing grievance mechanisms already exist for residents of Ebeye, which should be integrated with processes relating to project-specific grievance claims.
Island Level The community on Ebeye is an established society with existing traditional and cultural grievance redress mechanisms. Community leaders play an active role in resolving everyday community or social disputes on the island.
These mechanisms involve the traditional landowners, which under Republic of the Marshall Islands (RMI) law includes the Iroij, Alaps and Senior Dri Jerbal. It is customary for land-related grievances and/or issues pertaining to structures on land, or relocation or resettlement of persons, to be resolved by traditional landowners. This may also extend to involve local legal systems (such as the Ebeye Police) and/or community level committees, such as as the Party of Five and church groups.
There may be issues caused by the project that are raised and resolved through these existing community level grievance redress mechanisms. In such cases, the PMU will coordinate with the relevant traditional leaders and authorities to provide assistance, as required, and will record the complaint/outcomes of any dispute. A grievance committee will be established by KAJUR General Manager, if required due to the nature and number of grievances. This grievance committee will be established with permission from the traditional landowners to aid in their ability to hear and resolve community level complaints about the project.
Nonetheless, residents will be encouraged to raise project grievances firstly through project representatives as detailed in this GRM. Project representatives are from Ebeye and are familiar with traditional island-level grievance processes. When the project representative feels the grievance needs to involve traditional landowners and/or local legal systems/committees, they will consult KAJUR General Manager first, before inviting traditional land-owners, local legal systems or committees to provide support in resolving grievances.
Judiciary level 2
The project level process detailed below will not impede affected persons access to the RMI legal system. At any time, the complainant may take the matter to the appropriate legal or judicial authority as per the laws of RMI.
3. Objective
The objective of the project GRM is to establish guidelines for accepting, assessing, resolving, monitoring and evaluating grievances concerning the project.
4. Scope
This mechanism covers policies and procedures related to the management of grievances. It is intended for KAJUR/PMU/contractor employees who will process grievance claims, as well as persons wishing to file grievances.
5. Principles
The GRM has been developed in accordance with the KAJUR policies and procedures, as well as ADB Safeguards Policy Statement. The GRM is designed to work within existing legal and cultural frameworks, providing an opportunity to resolve grievances at the project level. Specifically, the project GRM has been designed to: • Be understandable, culturally appropriate and accessible to project-affected persons, with its availability communicated to residents of the island; • Address a wide range of grievances and concerns – both those based in factual data and those arising from perceptions or misperceptions; • Be transparent, and allow persons to submit a grievance at no cost and without retribution to the party that expressed the issue or concern; • Protect the identity of the persons raising the grievance; • Resolve concerns in a timely manner, via consultation with stakeholders, or forward any unresolved cases to the relevant authority; • Report back to the community (through the Project Steering Committee) periodically on the types of cases and how they were resolved; • Be revised if it is not working effectively.
6. Confidentiality
All KAJUR and PMU employees, contractor and subcontractor personnel involved in the resolution of grievances are required to keep confidential the nature of the claim, the claimants and the outcomes of the resolution process. KAJUR will periodically report back to stakeholders (through the Project Steering Committee) on the types of issues raised and how they were resolved, but this reporting will not feature the names of the aggrieved person/s or claimants, nor provide specific details of the issue/s.
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Types of grievances In the context of the project, grievances could encompass:
7. Procedures
Implementing the GRM involves five steps, which are described below in further detail and outlined in Figure 1. A project representative has been nominated to act as the grievance officer to receive, review and address project related concerns. This person is:
Ms Yumiko Crisostomo Deputy Team Leader KAJUR / Ebeye Water Supply and Sanitation Project (+692) 329-3799 or [email protected]
Yumi is from Ebeye and is a trusted member of the community. She is knowledgeable about the project, as well as local and legal forms of grievance redress mechanisms on Ebeye. She has met with traditional landowners to explain the project and will explain the project GRM at the next scheduled Steering Committee Meeting (May 2017). When Yumiko Crisostomo is not available, the grievance officer will be:
Mr Edward Bobo Project Manager KAJUR / Ebeye Water Supply and Sanitation Project (+692) 329-3799 or [email protected]
Step 1: Receive grievance claims
Grievances, complaints and concerns are to be submitted to Ms. Yumiko Crisostomo or Mr. Edward Bobo. This can be via KAJUR’s contractor or the sub-contractors. Contractor’s and subcontractors will be informed of the GRM, as well as who to notify in PMU/KAJUR when a grievance claim has been made. In addition, grievances and concerns can be made: • In person at the KAJUR office • Verbally via telephone to (+692) 329-3799 • In writing by email to [email protected] and [email protected] • In writing by letter sent or delivered to
Ms Yumiko Crisostomo KAJUR / Ebeye Water Supply and Sanitation Project 5819 Mon kubok weto Ebeye, MH 96970 Marshall Islands
Ms Yumiko Crisostomo KAJUR / Ebeye Water Supply and Sanitation Project PO Box 5806 Ebeye, MH 96970 Marshall Islands
Step 2: Record and acknowledge grievance claims
Any person (other than the two grievance officers) receiving the grievance claim will notify Yumiko/Edward who will log it on the Grievance Claim Log Sheet (Appendix A) and assign a reference number or identifier, and complete a Grievance Claim Reporting Form (Appendix B). The grievance officer will provide the claimant with information about the process, their assigned reference number and the timeframe in which a response can be expected. The following details will be recorded when receiving grievance claims: 1. Date 2. Manner in which the grievance claim was received (phone, email, letter, in-person etc.) 3. Name of the person who received the grievance claim 4. Summary of the grievance claim 5. Name and contact details of the claimant/s
All incoming claims to the grievance officer will be acknowledged within three working days, by the quickest method available. If the claim is received by the grievance officer in person or verbally over the telephone, it will be acknowledged on the spot. If the claim is in writing, then an email, telephone call or text message will be returned acknowledging that the grievance claim has been received, with details of the process and timeframe in which a response can be expected.
Step 3: Screen and assess grievance claims
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Received grievance claims are then screened, assessed and investigated (if required) by the grievance officer to verify validity. This includes establishing the nature of the grievance to determine the measures needed for review and investigation.
The grievance officer will either: 1. Assign personnel (including themselves) to complete actions to resolve the grievance OR 2. Elevate the claim directly to the KAJUR General Manager to resolve or facilitate the resolution of the grievance. The KAJUR General Manager will meet with the claimant and then assign personnel to complete actions or establish a grievance committee to aid in the resolution of the grievance. 3. If required, the KAJUR General Manager will convene a meeting with the EWSSP Grievance Committee to assist in resolving grievances. The EWSSP Grievance Committee will include one landowner, and representative of the EPA, representative of the Chief Secretary and representative of the Mayor of Kwajalein.
Grievances which do not apply to the project will be referred to the appropriate entity, and the claimant notified that this has occurred.
The Grievance Claim Reporting Form will be kept up-to-date regarding the status of the grievance claim and the actions required and completed.
Step 4: Decide on a response or resolution and monitor issues
The grievance officer (and the relevant GRM committee when needed) will decide on the response or resolution of the grievance claim and notify the claimant within 20 working days. The response may be in the form of a written letter/email or verbally through a meeting with the claimant/s or a telephone call. The Grievance Claim Reporting Form will be amended to reflect the closure of the grievance claim and future dates for monitoring. All documentation will be filed according to the reference number assigned and remain confidential.
Where an agreement on the resolution cannot be reached or if the claimant is not satisfied with the resolution, the grievance officer will provide the claimant with the details of RMI Office of the Chief Secretary (Executing Agency).
Step 5: Evaluate the GRM and report periodically
On a periodic basis, the grievance officer is to publish an evaluation report on the types of grievance claims and cases that were received and how they were resolved. The evaluation will include a report on the: • number and types of grievance claims received • number of claims that have been resolved/reached agreement • number of claims that have gone to mediation • number of claims unresolved
The report should also include an assessment of the effectiveness of the GRM and KAJUR/PMU in responding to the grievance claims. This report will be shared with the Project Steering Committee.
Figure 1: Grievance mechanism framework
8. Communication of the GRM
It is the responsibility of the PMU to ensure the Ebeye community is informed of the GRM. The PMU has translated the GRM into Marshallese and will provide details/training about the GRM to new contractors and the Project Steering Committee (scheduled for month year). Information about the GRM will be publicized at the following locations or events: • At KAJUR office • At construction sites or at the contractor’s management office (if one is set up) • Notice boards on the island • At meetings held with stakeholders
A poster has been developed in Marshallese and English (Appendix B). The PMU will use these posters and develop additional materials (as needed) to explain the GRM process in Marshallese and English.
9. Resources
Financial resources to cover the operational costs of the GRM are part of the project budget. Costs for resolving grievance claims will come out of contingency funds set-aside for unanticipated social and environmental impacts during design and construction. Costs for grievances made during the operation phase will be shouldered by KAJUR.
Appendix A – EWSSP Grievance Claim Log Sheet
Appendix B – EWSSP Grievance Reporting Form
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Appendix C – EWSSP Poster