French COMOROS ENERGY SECTOR SUPPORT PROJECT

Home , African Development Bank, Domoni, Fomboni, Koimbani, Ouzioini

Language: English Original: French

AFRICAN DEVELOPMENT BANK GROUP

COMOROS ENERGY SECTOR SUPPORT PROJECT (PASEC) - SUPPLEMENTARY FINANCING

COUNTRY: UNION OF THE COMOROS

SUMMARY OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

MARCH 2019

Humphrey N. RICHARD Team Leader RDGE.1 8124

Moussa KONE, Power Engineer RDGE.1 8256 (Consultant) Mamadou DIOMANDE, Financial RDGE.4 8243 Management Specialist Souweye MAIGA, Procurement RDGE.4 8121 Specialist Gisele BELEM, Environmental and SNSC.0 4597 Social Safeguards Specialist Bambo DEMBELE, Disbursement Team Members FIFC.3 4617 Officer Ako Charlotte EYONG, Climate PECG.2 4548 Project Team Change and Green Growth Officer Gilberte DOGBEVI-FALY, Fragility RDTS.0 3127 Specialist Camille QUENARD, Gender and AHGC.1 4931 Energy Specialist Jin Jason Seung-Soo, Financial RDGE.1 8323 Analyst (Consultant) Humphrey N. RICHARD Sector Manager RDGE.1 8124

Sector Director Batchi BALDEH PESD 4036 Deputy Director- Nnenna NWABUFO RDGE 8343 General Director-General Gabriel NEGATU RDGE 8232

SUMMARY OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

Project Title: Comoros Energy Sector Support Project (PASEC) - Supplementary Financing SAP Code: P-KM-F00-002 Country : Union of the Comoros Category : 2 Department : RDGE Division : RDGE.1

INTRODUCTION

This document is a summary of the Environmental and Social Management Plan for the supplementary financing of the Comoros Energy Sector Support Project (PASEC 2) in its various target areas: (i) rehabilitation of the Voidjou and Itsamboni distribution networks and thermal power plants in Grande Comore; (ii) construction of the Domoni hydropower plant and associated energy evacuation line, as well as the rehabilitation of the Trénani thermal power plant in Anjouan; and (iii) rehabilitation of the Fomboni power plant in Mohéli.

This summary has been prepared in accordance with the Environmental and Social Requirements of the Union of the Comoros and the African Development Bank's (AfDB) Integrated Safeguard System (ISS) for Category 2 projects. The project description and rationale are first outlined, followed by the legal and institutional framework to guide project implementation. The description of the key baseline environmental conditions in the project area is then presented, as well as a summary of the public consultations and comparative options in terms of technical, economic, environmental and social feasibility.

The environmental and social impacts are summarised and the inevitable impacts identified during the preparation, construction and operation phases of the facilities (MV lines and thermal power plants as well as transformer substations to be rehabilitated). Measures are then recommended to enhance benefits and/or prevent/minimise the negative impacts. The monitoring and capacity-building programme is then presented, as well as the environmental and social management costs of project implementation.

1. PROJECT RATIONALE AND DESCRIPTION

1.1. Project Rationale

In 2013, the African Development Bank approved an African Development Fund (ADF) grant and a Transition Support Facility (TSF) grant of US$ 20 million to restore and improve the operation of the power network, the thermal power plants and the distribution grid as well as prepare for the development of renewable energy as part of the Comoros Energy Sector Support Project (PASEC). It was ascertained on completion of the supplementary technical studies that the resources available were not sufficient for all the works. According to the conclusions of these studies, the rehabilitation of the 20 kV distribution networks was estimated at EUR 8 130 000, whereas the available budget was approximately EUR 4 900 000. Similarly, the resource requirements for the rehabilitation of the thermal power plants were estimated at EUR 8 660 000, while the allocated budget was about EUR 2 763 000. The Government of the Union of the Comoros then approached the Bank for a supplementary funding of EUR 8.4 million under PASEC. The amount will mainly be used to further rehabilitate the 20 kV distribution networks and the thermal power plants, and to build the Domoni hydropower plant.

Although power supply had improved in 2017, the Union of the Comoros currently faces an energy deficit that unavoidably leads to load shedding. The cost of electricity in the country is among the highest in Africa (KMF

120/kWh) due to its production capacity that is largely dominated by diesel generators (electricity is produced mainly by high-speed diesel engines (1500 rpm) with limited capacity (1000 to 2000 kVA). Losses resulting from the outdated and inadequate energy infrastructure maintenance and the improper structuring of distribution networks, collection difficulties and fraud have contributed, among other things, to SONELEC's strenuous financial situation. The overall efficiency of the Comoros power sector has been relatively low in recent years, estimated in 2017 at 58% in Grande Comore and Mohéli, and 65% in Anjouan.

1.2. Project Description

The supplementary PASEC financing will facilitate the implementation of the three components described in the table below:

Components of the Supplementary Financing (in EUR)

No. Components Estimated Cost Description • Conduct of technical studies: (i) detailed technical studies of 5 hydropower plants in Anjouan and Mohéli, and preparation of bidding documents (BDs), (ii) study of the hydropower Support rehabilitation potential of at least 8 sites in Anjouan and A and technical 7 111 600 Mohéli implementation • Rehabilitation of 4 thermal power plants on the 3 islands • Rehabilitation of distribution networks • Construction of a hydropower plant • Construction of the SONELEC headquarters • Control and supervision of construction works • Implementation of the environmental and social B Institutional support 1 250 000 management plan • Implementation of climate change adaptation initiatives • Audit of project accounts C Project management 83 000 • Provision of accounting software services Total (UA million) 8 400 000

The construction and rehabilitation activities under Component A will have environmental and social impacts, including the activities detailed below:

(i) Rehabilitation of Medium Voltage (MV) Distribution Networks in Grande Comore: These concern the medium voltage feeders and lines connected to the switchyard and used to transmit the generated energy, and the medium/low voltage distribution stations. The following medium voltage (20 kV) distribution system sections have been selected for the supplementary financing:

Sections to be Rehabilitated in Grande Comore Sections Distance in Metres Nioumadzaha – Kanzile 16 756 Itsoundzou (military camp)-Koimbani-Mbéni 19 413 Ouzioini-Ouroveni 11 587 Length in metres 47 756

Rehabilitation of Diesel Thermal Power Plants

The thermal power stations to be rehabilitated are those of Voidjou and Itsambouni (Grande Comore), Fomboni in Mohéli and Trénani in Anjouan.

Works to be carried out at the power plants will mainly concern: - Supplying various equipment and overhauling generators - Installing remote monitoring and anti-intrusion systems - Strengthening the diesel fuel storage capacity (100 m3 Mohéli and 100 m3 Itsambouni) - Setting up a fuel and lubricating oil analysis laboratory and transformer insulation control - Purchasing batches of safety equipment (helmets, gloves, belts, shoes, coverall, etc.) and tools. Construction of the Domoni Hydropower Plant

This component concerns constructing a new 300 kW hydropower plant in Domoni on Anjouan Island. The feasibility study indicates that energy development will draw from the water supply infrastructure, which will involve a separate project being designed, according to the following parameters:

• Galani source sampling: 100 l/s • Water intake and transfer to the pressure chamber with a slope allowing a flow rate of more than 300 l/s • Pressure chamber of a dimension of 502 m • Gravitational supply of all sampling points (reservoirs), up to the last point: the network descends to about 100 m and then goes up to about 400 m • Diameter of the pipe from the pressure chamber to the first Domoni tanks: 350 mm • Pressure in the pipe at low point: approx. 40 bar. The main equipment planned for the plant include: • The shutoff valve • The turbine • The generator • A sufficiently large flywheel (operation in an isolated network) • Electrical equipment (power cabinets, transformers, circuit breakers, etc.) • Provision has been made to connect to the 20 kV line on the current network (50 m distance), which supplies Limbi from Domoni.

2. POLITICAL, LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1. Environmental Policy Framework of the Union of the Comoros

The National Environmental Policy of the Union of the Comoros was prepared and adopted in 1993 by Decree No. 93-214/PR, based on the document entitled "Diagnosis of the State of the Environment in the Comoros". The country’s 2001 Constitution, in its Preamble, proclaims "the right to a healthy environment and the duty of all to safeguard that environment". Adopted in 1994, its Environmental Code declares that environmental protection is in “the public interest" and recalls the right to a healthy environment and the obligation to safeguard it. Article 18 of the Environmental Code also stipulates that the State must ensure the protection of the soil and subsoil, water resources and the marine environment, the atmosphere and biological diversity.

Between 1993 and 2001, the Union of the Comoros adopted a policy framework that resulted in the preparation and adoption of a National Environmental Policy, an Environmental Action Plan and a National Strategy and Action Plan for the Conservation and Sustainable Management of Biodiversity. A legislative and regulatory framework was put in place with the adoption and promulgation of the framework law on the environment and some implementing regulations relating to the creation of the Mohéli Marine Park, species protection and an Environmental Impact Assessment (EIA) in October 1994 (Decree No. 94/100/PR). The framework law takes into account sustainable development, impact assessments, biological diversity, protection of the terrestrial and marine environment, and protected areas.

Three main international conventions directly concerned with the conservation of biological diversity have been ratified, namely the Convention on Biological Diversity (5 June 1992), the Convention on Climate Change (4 June 1992) and the Convention to Combat Desertification.

Legal and Regulatory Framework

Framework Law No. 94-018/AF of 22 June 1994: this law is the legal framework for environmental management in the Comoros. It stipulates that development and planning projects should be subject to environmental impact assessment. Some provisions of the law were amended by Act No. 95-007/AF of 19 June 1995 and Order No. 00-014 of 9 October 2000.

Decree of 19 April 2001: this decree is specific to ecological assessment, including the list of works, developments or structures that should be subject to an impact assessment. To date, however, no measures have been taken to enforce the decree.

Law N°88-006/PR: this law concerns the legal regime developed in 1988 for reforestation and forest management, requiring that forest management should aim at: (i) safeguarding the local environment; (ii) protecting agricultural plantations; (iii) combating erosion; and (iv) providing fuel or construction wood or improving living conditions.

Law N°95-013/A/F/F: this law concerns the Public Health Social Action Code for the people’s well-being. Article 58 thereof stipulates that health regulations shall be determined in accordance with the texts in force: (i) measures to be taken by administrative authorities to prevent or control communicable diseases; (ii) measures for protecting foodstuffs; (iii) measures for disinfecting or destroying objects that may serve as vehicles for transmission of diseases; (iv) requirements for home safety, outbuildings, private roads (closed or open), with irrigation or drainage channels at their ends, houses, hotels and restaurants and towns of any kind; (v) requirements for drinking water supply and monitoring of wells, washhouses, waste disposal and conditions that cesspits must meet; (vi) provisions for any other form of deterioration in the quality of people's living environment due to factors such as air or water pollution, industrial waste, noise, secondary effects of pesticides, water stagnation or poor storage conditions.

Other Decrees and Orders issued for the protection of biological diversity include: • Order No. 01/031 /MPE/CAB protecting wild fauna and flora of the Comoros • Decree No. 01/32/MPE/CAB of 14/05/2001 adopting the National Strategy and Action Plan for the Conservation of Biological Diversity • Decree N°01-053/CE of 19/04/2001 concerning the Mohéli Marine Park • Order No. 02/002/MPE/CAB of 01/02/2002 annexed to Decree No. 01-053/EC of 19 April 2001 on the Mohéli Marine Park and specifying the boundaries of the park area • Decree No. 01/33/MPE/CAB of 14/05/2001 adopting the Action Plan for the Conservation of Marine Turtles in the Comoros.

2.2. Institutional Framework

Project compliance with the Environmental Code and other planning documents requires the participation of various institutions at the strategic and operational level, including the Ministry of Energy, Environment and Agriculture, the Ministry of Urban Planning, Regional Planning and Decentralisation, the Ministry of Finance and Budget, the Ministry of Public Health, Social Protection and Gender Promotion, the Directorate General for Energy and the Directorate General for Environment and Forestry, SONELEC, the Project Coordination Unit, local authorities and non-governmental organisations. These institutions will participate in following-up the implementation of the ESMP through a monitoring committee coordinated by the Directorate General for Environment and Forestry (DGEF).

2.3. AfDB Safeguard Policies Applicable to the Project

The project is subject to ISS requirements, especially the following Operational Safeguards (OS): (i) OS 1 due to the nature of the project; (ii) OS 3 due to the potential impacts on flora and fauna; (iii) OS 4 due to the potential generation of waste during works and the use of SF6 gas, which may have effects on the ozone layer in the event of leakage; and (iv) OS 5 due to risks faced by workers, including working at height and risks related to routine thermal power plant operations. OS 2 will not be triggered, particularly because the transmission network to be rehabilitated is essentially located along road infrastructure. Some fruit trees may be affected during works, in which case compensation for losses will be paid before works are carried out. Other relevant policies and guidelines shall apply as soon as they are triggered under the ISS, principally the Poverty Reduction Policy (February 2004); the Gender Policy (2001); the Framework for Consolidated Engagement with Civil Society Organizations (2012); the Dissemination and Access to Information Policy (2013); the Handbook on Stakeholder Consultation and Participation in Bank Operations (2001) and Bank Population Policy and Implementation Strategy (2002).

3. DESCRIPTION OF THE TARGET ENVIRONMENT

The following is the description of project target area in terms of its physical, biological and socio-economic components:

Project Impact Area

The impact area includes all the natural and human elements that the project could affect directly or indirectly. This can be subdivided into two:

The limited study area or works right-of-way: for MV lines, the restricted study area or works right-of-way will be 1.5 m on either side of the lines. For diesel thermal power plants and the Domoni PCH, the restricted study area covers the power plant sites. The works impact these areas directly.

The extended impact area: the extended impact area will apply to all communities directly impacted by the project's socio-economic and environmental spinoffs. The indirect impact area will extend to all the localities bordering the MT line corridor, other project components and the three Comoros Islands: Grande Comore (N'gazidja), Anjouan (Ndzuani) and Mohéli (Mwali). This concerns the following prefectures and municipal councils:

Local Authorities Concerned by the Project ISLAND PREFECTURE MUNICIPAL COUNCILS Itsandra-Hamanvou Isahari Moroni Moroni-Bambao Bambao Ya Hari Tsinimoipangua Hambou Djoumoipangua GRANDE Ngouengoe Madjini-Ouest COMORE Nioumagama Itsahidi Madjini-Est Domba Dimbani Oichili-Dimani Oichili Yamboini Hamahamet-Mboinkou Nyuma Msiru Ouani Ouani ANJOUAN Domoni Domoni MOHELI Fouboni Foumboni

The maps below present the PASEC 2 extended study area and the location of the Domoni hydropower plant.

Extended Study Area

Domoni Hydropower Plant Study Area

3.1. Biophysical Environment

Relief: The three islands have a specific environmental profile due to their geographic location. They cover a total land area of 1,862 km2 and have a shoreline of 340 km. Mount Karthala, an active volcano in the south of Grande Comore, is the highest point at 2,361 m above sea level. Mount Ntringui in Anjouan stands at 1,595 m and the highest altitude in Mohéli is 790 m. These islands, which emerged at different geological periods, have never been in contact with each other, nor with Africa or Madagascar, and are isolated from one another by deep ocean trenches ranging from 300 to 4,000 m, which gives each of them distinct biophysical features. The intense erosion that has occurred between two phases of volcanic activity and at various stages of island formation has led to a great diversity of landscapes and geomorphological units. This is all the more significant as the islands are old and the recovery periods between two phases have been long.

Climate: Comoros has a tropical maritime climate with local contrasts marked by microclimates due to the influence of the relief on the various climatic components, particularly rainfall. Depending on the season, the country is successively swept either by the southern and south-eastern trade winds from April to November, bringing relatively drier and cooler tropical air, and from May to October, or by the northern-to-northwest monsoon, which predominates from December to March, bringing warm and humid equatorial air from November to April. Monsoon ground winds can attain a speed of 110 km/s in Moroni, the capital. Ground wind speed recorded in Hahaya station can reach 75 km/s in gusts. These winds are sometimes cyclonic. The rainy season, from mid-November to mid-April, is characterised by humid heat, frequent storms and, especially in January-February, by some highly disruptive outbreaks caused by tropical depressions around the archipelago. The NW monsoon winds bring in warm, humid air and a lot of rain. The average temperature in the coastal area is around 27° C. The dry and cool season lasts from early June to the end of September. The annual rainfall in all the islands ranges from 1,000 mm to 5,000 mm, depending on the region.

Climate Change: Heavy rains, severe dry season and high temperatures cause soil stripping, clay soil slits and landslides, accelerating the degradation of 33,120 ha of soil (50%) in Grande Comore, 24,200 ha (65%) in Anjouan and 8,115 ha (52%) in Mohéli. A total 65,335 ha of agricultural land (57.5%) is affected out of an overall farming area of about 112,000 ha. Trees also flower early with changes in the geographical distribution areas of a number of plant and animal species in response to changing climatic conditions. These changes in climate zones threaten fauna and flora, leading to the depletion of certain species.

Pedology: The cartography of Comorian soils and their agricultural potential has highlighted three main types of soils according to the type of pedogenesis: (i) ferralitic soils with limited agricultural value due to their low fertility level; (ii) brown soils, rich but of limited thickness and quite stony, particularly in Anjouan and Mohéli; and (iii) andosols that develop mainly on volcanic mounds in the later phase. They are known for being up to 90% stony, high organic matter content and high permeability. These soils are predominant in Grande Comore and the other islands. Despite these constraints, most of the soils offer remarkable farming potential because they are very rich in organic matter, have high reserves of nutrients such as phosphorus, potassium, calcium and magnesium, and low acidity. They are suitable for a wide range of crops: food crops, market gardening, industrial shrubs and trees as well as grass.

Hydrographic Network: The permanent hydrographic network, non-existent in Grande Comore (no permanent surface runoff), is extensive in Anjouan and Mohéli. However, the flow of many rivers or streams/springs, has decreased significantly in all the islands over the past two decades, due to the lack of structure and material resources. Despite the human resources potential, there is no monitoring of water resources from all sources. The Anjouan and Mohéli network, although initially relatively dense, has been greatly reduced due to massive deforestation and an extension of annual crops. Many sources dry up in the dry season. The decrease in water resources in terms of quality and quantity reduces the food and agricultural supply, and increases hydropower operating costs.

Biodiversity: The Comoros Islands have a very high biodiversity rate, boosted by the altitudinal factor. They are classified as "hotspot areas" (high endemicity and significant threats) among the six major regions of the world (International Union for the Conservation of Nature - IUCN). Despite the small size of the territory, the heterogeneous ecological conditions in terms of altitude, climate and soil have resulted in a high diversity of terrestrial ecosystems that support several endemic, threatened and migratory species. However, this potential for biodiversity is still not adequately acknowledged, and consequently poorly managed and protected. Therefore, biodiversity is under strong anthropogenic pressures and its survival is threatened. It is also important to note the significant superiority of the number of invasive species over endemic or indigenous ones. Transmission lines are located in urbanised environments, mostly in modified wildlife and plant habitats. The sites of existing thermal power plants are already severely affected by current activities. Only the Domoni hydropower plant site (300 m2) could harm the flora.

Flora: There are about 2,000 estimated plant species on the three islands. The latest national inventory conducted revealed at least 350 species, 50 of which are endemic. Plant formations vary depending on microclimates and soil type: bare soils (recent lava flows) to primary rainforest formations, mangroves in the plains, anthropized vegetation (fruit trees, food crops, etc.). No plant species found on the layout is considered rare or threatened, and no sensitivity is recorded for any of these herbaceous species in respect of the project.

Fauna: The Comorian fauna is diverse in terms of wildlife, although it has few large mammals. The most significant mammals include the giant bat or Livingstone's fruit bat (Pteropus livingstonii), which is of internationally renowned value. The habitat is limited to the few remaining intact forest fragments in Anjouan and Mohéli, and under threat. The endemic rate for Megachiroptera (3 bat species) is close to 100%. There are also about 100 bird species, 60 of which are breeding and 39 migratory. Several cases of electrocution of Livingstone bats have been observed on bare-conductor MV lines, particularly during fruiting periods when bats skirt these lines to fetch their food on fruit trees.

Socio-economic Environment

Demography: According to estimates from the 2017 population census, the three (03) islands covered by the project (Grande Comore, Anjouan and Mohéli) will have a total population of approximately 873,724 inhabitants by 2019 and distributed as follows: 51% in Grande Comore, 42% in Anjouan and 7% in Mohéli. The average population density is about 341 inhabitants/km² and varies from one island to another: 763 inhabitants/km² (Anjouan), 175 inhabitants/km² (Mohéli), and 339 inhabitants/km² (Grande Comore). The annual population growth rate is about 2.1%. The urban population growth rate of 6.5% is high, and the urbanisation rate was 40% of the population in 2015 (Profile 2017).

Sociocultural Organisation: The Comorian population is the result of a mix of several cultures and civilisations from Africa, Arabia and South/East Asia. Its social organisation is deeply rooted in tradition and very hierarchical. The individual is part of the community and can only assert himself/herself through the mechanisms imposed by that community; the family is still the society's organisational and operational foundation. In terms of religion, almost the entire Comorian population is Muslim.

Land Tenure: Most of the farming land in the project areas is customary land. There are very few land use discussions, since the dominant mode of access to land is the traditional method. Most of these lands were acquired by inheritance from the descendants of the first occupants. These rights are legitimised through clearing of the land by its founders or the first village occupants. These customary rights, which are transmitted from generation to generation, are exercised over the whole territory. Access to farming land through city council allocation is still an exceptional method. The mayors estimate that less than 5% of land occupants have a title issued by the Municipal Council. The allocation only confers a right of use to the exclusion of any appropriation of land or transaction thereof.

Economic Activities: The project will be located in the urban areas (Grande Comore) as well as the rural agricultural production centres (partly in Anjouan, Mohéli and Grande Comore) because of the high hydraulic and pedological potentials. These centres have a significant role in the area's economic and social activities. About 70% of the population are farmers and 60% of the land is used for agriculture, which is the main activity carried out in rural areas and contributes significantly to wealth creation. The main agricultural products are subdivided into food crops, market gardening/fruit crops (bananas, cassava, coconuts, sweet potatoes, taro, etc.) and cash crops (vanilla, cloves and claws, ylang-ylang oil, lettuce, onions, citrus fruits, oranges, litchis, passion fruits, avocados, mangos, jack fruit, papaya, guava, etc.). Other activities include livestock farming and fishing.

Health: Significant progress has been made, in terms of maternal health and fight against malaria, which is being eradicated throughout the archipelago. In contrast, the quality of children's nutrition deteriorated between 1991 and 2012, with the proportion of under-5s suffering from wasting (emaciation) rising from 3.5 per cent to 11.1 per cent over the period. Currently, 95% of Comorians do not still have access to any kind of medical coverage.

Education: Access to education has improved considerably: 39 per cent of adults had attained secondary or higher education by 2014, compared to only 9 per cent in 2004. The net primary school enrolment rate increased from 67 per cent in 2004 to 76 per cent in 2014, and the literacy rate was 73.2 per cent. However, 40% of the population has no level of education.

Gender: Although the gender situation has improved in the Comoros, women still have limited political representation (only one woman is in government and just 6% of parliamentarians are women) and have very little access to higher education. However, women are relatively protected in terms of land ownership and in the event of divorce, thanks to the customary matrilineal and matrilocal system.

Sources of Energy: Fuelwood and petroleum products are the two main sources of the country's final energy consumption. Solar energy is gradually making inroads into the market, but remains negligible compared to

11 conventional energy sources. Looking at the various sectors, household energy consumption accounts for 63% of total final energy use; the rest comes from the transport (32%), industrial and commercial sectors (5%). Most of the biomass used is for households and restaurants (93%) and the distillation of ylang-ylang essential oil (7%), while other activities such as vanilla drying represent a negligible portion. The petroleum products consumed are all imported and used for transportation, power generation and domestic purposes.

4. VARIANT ANALYSIS

4.1. With and Without Project Analysis

The option to implement this project was compared with the no project option. If the project is not implemented, the negative environmental impacts of the various project components would be temporarily avoided. However, this option was rejected based on socio-economic arguments, including the expected positive impacts of the project. Failure to implement the project runs counter to PASEC and the country’s strategic objectives, which are intended to improve power sector infrastructure and better community access through reduced load shedding and lower energy costs, in the long term. Therefore, the project's short- and long-term benefits will far outweigh the negative and temporary environmental impacts associated with its implementation. Negative environmental impacts will be addressed and mitigated through the implementation of the Environmental and Social Management Plan.

4.2. Analysis of the Alternatives for the Domoni Power Plant

Three options were proposed in the Domoni PCH feasibility study, namely: (i) Case 1. Limbi Reservoir (230 m); (ii) Case 2. Limbi Roadside/Mahindini Crater (145 m); and (iii) Case 3. Domoni NR1-RB Reservoirs (120 m).

As regards the supply network, the location of the power plant is a sensitive factor, irrespective of any considerations related to land or access. The plan is to provide water supply by gravity for the entire network, induced by water pressure at the altitude of the source, with loading as soon as the water is abstracted at source. The choice of pipe diameter will limit the loss of pressure.

However, the power plant will use this pressure, particularly as it will be located at a low altitude. The resulting load at the power plant output is zero. Therefore, the usable waterfall is all the more favourable since the power plant is located lower. In contrast, there is a risk of a decrease in the usable flow because the flow is reduced by abstractions for the water supply system.

Case 2 (Limbi Reservoir) was selected following an analysis combining criteria on accessibility, distance from the network, water discharge possibilities and length of the supply pipe. Proposal for the installation was made to optimise access, connection and water discharge simultaneously. From these viewpoints, an installation along the road, at the beginning of the path that joins the crater rim, is deemed optimal: • No need to build an access road • 20 kV grid on site via 54 mm² (less than 50 m) • Minimal water discharge pipe (about 100 m)

5. PUBLIC CONSULTATION

An information and consultative approach was adopted to win public participation in the project environmental and social impact assessment process. Using methodological tools such as semi-structured interviews and an extended focus group, the aim was to maintain a dynamic and iterative exchange between the public and the consultant, a process that encouraged stakeholders and the public to express their concerns, fears and

12 preoccupations about the project and their suggestions and recommendations to better take on board those expectations. The consultations targeted the following stakeholders: technical services, local community representatives, local authorities and people in the project areas. Consultations were held on the 3 islands between 18 December 2018 and 16 January 2019. This section summarises the points discussed, the concerns and fears expressed by stakeholders, and the suggestions and recommendations arising from the consultations.

5.1. Institutional Meetings

Overall, all stakeholders consulted highly appreciated the project. However, participants also expressed fears, concerns and made proposals.

Issues Discussed Fears and Concerns Suggestions and Recommendations Project presentation (context and Have constant power Strengthen the environmental and social objectives) management capacity of departments involved Recruitment of local labour force; in the project Project environmental and social issues (positive and negative Involvement of the competent Provision of equipment to departments during impacts, ESMPs, environmental services (Environment, Land the project implementation phase (office and social monitoring) Registry, Urban Planning) in project equipment, IT, GPS, logistics, vehicles, implementation monitoring motorcycles, staff travel, fuel, etc.) Capacity and experience in project Conduct remedial reforestation monitoring and environmental Land conflict management surveillance Compensate people before works start Weak technical, material, logistical Capacity building in and other resources of departments Secure lines and power plants after works environmental and social (Environment, Urban Planning, management Cadastre, etc.) Involve the relevant technical departments in project implementation Mitigation and enhancement Compensation for people affected by measures the project (fruit trees...) Put in place adequate waste oil management, including traceability Conflict management Disastrous management of waste oils mechanisms. from thermal power plants Involve the Urban Planning Department in identifying (inspecting) the Domoni site Acts of sabotage that may occur at the power plants Avoid as much as possible the demolition of (valuable) buildings close to the MV line right- Unlawful and uncontrolled of-way occupation of the MV line rights-of- way by the people In the compensation process, take account of the real value of properties impacted (fruit Deforestation (uncontrolled logging) trees).

5.2. Meetings with the Authorities and Local Communities

The table below summarises the main issues discussed, the concerns and fears expressed and the suggestions and recommendations made by the local authorities and people in the project areas.

Issues Discussed Fears and Concerns Suggestions and Recommendations The Project and its objectives The people reiterated and confirmed Recruit local labour (unskilled labour: that they were not against the loss of track opening, labourers, etc.) taking Fears and concerns about the MV line income due to the pruning of fruit trees gender into account rehabilitation works and the Domoni along the line's corridors power plant construction Facilitate access to basic social The non-involvement of the various services (health, education, water, The dangers of dwelling under power project stakeholders, in particular the electricity, etc.) in targeted areas lines local communities concerned during project implementation Provide sustained assistance to The advantages of rehabilitating MV vulnerable people lines Laying insulated cables when passing through settlements Engage in community development Project mitigation and enhancement activities (e.g. support for measures The non-recruitment of unskilled local communities in waste management) labour Conflict management mechanisms Compensate all property losses caused by the project, particularly fruit trees

Possibility to move the power line overlooking residences

Inform the public of the next steps in project implementation

Inform and raise public awareness before works start

Give priority to the local people in recruiting unskilled labour

Comply with commitments made to the local workforce

Ensure that the conditions for democratic and transparent management of the workforce are in place

Involve authorities and communities in project implementation and monitoring

Overall, the project to rehabilitate MV lines and diesel thermal plants, and construct the Domoni hydropower plant is welcome as it is perceived as an asset for the entire community. Most of the people and authorities have requested that the project raise awareness on the risks of living close to power lines. Nonetheless, they are still willing to back the project and are soliciting support for community development actions. Most of the suggestions and recommendations made during the public consultations were incorporated into the project's mitigation and enhancement measures. Moreover, the ESIA and ESMP will be published by the DGEF in Grande Comore and by the Regional Environment Directorates in Anjouan and Mohéli. The ESMP summary will be published on the

Bank's website for 30 days before the project is presented to the Board of Directors. The full ESIA/ESMP document will also be published on the Bank's website in compliance with the Bank's information disclosure requirements.

5.3. Stakeholder Engagement Plan

A Stakeholder Engagement Plan (SEP) has been prepared for project implementation. SEP activities involve the project, project-impacted communities, local authorities, and decentralised and devolved institutional authorities. SEP includes measures for internal implementation by SONELEC and external implementation by all project stakeholders. This external engagement will include: (i) finalising stakeholder identification and mobilisation; (ii) formalising partnerships, conventions and working modalities with project stakeholders; (iii) coordinating activities among various stakeholders; (iv) capitalising and disseminating information to all stakeholders; (v) determining the role and limits of each stakeholder in the communication process; and (vi) supporting stakeholders in the process and in the overall monitoring of the ESMP.

Furthermore, SEP provides for a complaint management system. Communities and individuals who feel aggrieved by the project may submit claims to the project authorities. Complaints or claims may be: (i) either written and sent to the mayors or prefectures in the project area; (ii) recorded in the complaints register, which will be established for that purpose and made available to the public at all times at the Town Councils in the following municipalities: Domoni, Mdé, Mitsoudjé, Ouzoini, Koimbani, and Mbéni. The Territorial Administrators will forward the complaints received to the Project Coordination (PASEC) through the Environmental and Social Safeguards Experts and ensure that they are promptly investigated to respond to concerns raised about the project.

6. ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES

This chapter summarises the main environmental and social impacts/risks during the rehabilitation/construction and operation phases of the project. They are generally of minor or medium importance.

6.1. Positive Impacts of the Project

The table below summarises the positive impacts of all project components: construction of the Domoni hydropower plant and rehabilitation of the distribution networks and diesel thermal power plants.

Positive Impacts of the Project Construction of the Domoni Hydropower Plant Rehabilitation of Distribution networks and of the Diesel Thermal Power Plants Works Phase Works Phase ☺ Recruitment of a large local workforce with ☺ Job creation the labour-based approach for constructing the ☺ Creation of income-generating activities and plant fight against poverty ☺ Creation of income-generating activities and ☺ Erosion control through anti-erosion works to fight against poverty be undertaken to secure the poles ☺ Strengthening local expertise through job ☺ Strengthening local expertise through job creation creation Operation Phase ☺ Improvement of access to power in the Union of the Comoros (for the hydropower plant: the localities bordering the Limbi plant, Domoni, etc.) ☺ Promotion of economic development in the Union of the Comoros (for the hydropower plant: the localities bordering the plant (Limbi, Domoni, etc.) ☺ Better conservation and enhancement of agri-food products ☺ Better preservation of pharmaceutical products

☺ Improvement of working conditions in hospitals ☺ Improvement of local government services ☺ Development of IGAs and local SMEs by securing power supply ☺ Extension of network coverage with the possibility of connecting neighbouring villages and increasing network density within cities ☺ Development of public lighting and improvement of security conditions ☺ Improvement of the people’s living conditions and comfort ☺ Reduction of gender inequalities (improving access to electricity in the Comoros will enable women to access equipment that will reduce the hardship of their chores and promote their active participation in developing their regions) ☺ Secure electricity distribution by stopping the operation of self-generators ☺ Reduction of oil leaks and spills at diesel power plants ☺ Improvement of fuel storage facilities at diesel power plants

6.2. Negative Project Impacts in the Preparation and Construction Phases

The following activities will have negative impacts during the preparation and construction phases: • Releasing the rights of way • Equipment haulage and site installation • Workers’ presence • Excavation and pole installation works • Use and/or movements of construction machinery • Laying pipes and electricity cables • Drilling boreholes and building transformer substations • Installing hardware and pulling cables • Connecting MV cables and necessary grounding.

6.2.1. Impacts on the Biophysical Environment

Flora: The vegetation will be impacted during the potential deforestation and pruning. However, the impacts would be quite limited. Erecting the poles will not require building access roads, as most lines are along the road. Once unloaded from the trucks, the poles will be transported to the site manually. Vegetation loss through clearing will occur locally on modest rights-of-way. Clearing and deforestation will be limited to herbaceous plants and a few large trees. Modest vegetation damage is expected on the Domoni hydropower plant site. There are no major negative impacts under the rehabilitation component of thermal power plants since the sites are already heavily affected by human activity and the work is carried out entirely within the plants. It should be noted that none of the components are located in or near protected areas.

Surface Water Pollution: Surface water pollution in the project areas could result from runoff drainage from excavated land (when trenches are opened) to nearby streams and wetlands, or from poor management of waste generated by project activities. The laying of pipes, electrical cables and drilling activities will produce a lot of waste such as cables, plastics, earth, cement etc. In the absence of adequate and effective management of this waste, it can end up in watercourses and contribute to their pollution. The absence of watercourses in the immediate project vicinity reduces the magnitude of this impact. Any such impact will be moderate.

Groundwater Pollution: There is concern that the works will have an impact on groundwater, leading to liquid waste infiltration. The risk of contamination is high due to the proximity of the water table and abundant rainfall.

The groundwater captured by existing traditional wells is the most exposed to this situation. The construction of a base camp and works in power plants could exacerbate the problem associated with managing wastewater and other waste oils from machine maintenance. The washing and maintenance of construction machines are operations that can lead to a deterioration in water quality. There is also the risk of accidental pollution due to leakage of petroleum, grease or hydraulic fluids from machines. However, this is a temporary phase and even if the location of the work sites could modify some hydrological properties locally, the change would not be irreversible. The impact will be of average import.

Air Pollution: Air quality could be affected by excavations and soil storage as well as by the release of exhaust gases (CO2 and other greenhouse gases such as NOx, SOx) into the air through the operation of motorised machines and equipment on the site. During such works, the raising of dust due to the movement of construction site vehicles and all other road users will contribute to air pollution, especially if the works take place in the dry season. Furthermore, dust (soil and rocks) and exhaust gases are a health hazard for exposed persons because they can cause respiratory or eye infections. Those most at risk are workers and people living near the project sites. The impact will be moderate.

Modification of Soil Structure: Excavation, soil storage and trench backfilling will cause a rupture of the soil structure at the works right-of-way. Clearing vegetation before excavation already exposes the soil to erosion. Land reclamation may increase the vulnerability of soils to erosion and leaching. Depending on the time between opening and backfilling of trenches, soil leaching could be considerable if work is carried out during the rainy season. Consequently, there might not be sufficient soil for full backfilling of the trenches. The loss of soil stability will be more sensitive on slopes, ravines and erosion zones. The potential site of the Domoni hydropower plant and some sections of the power grids to be rehabilitated may be exposed to water erosion that alters the soil structure. This water erosion could create significant gullying. Thus, infrastructure installations could become exposed to significant gullying, particularly on the edges of crest lines and on steep slopes. If adequate measures are not taken, the risk of erosion can significantly affect infrastructure sustainability. This impact will be of average import given the small size of the foundations required for the poles and the temporary nature of the works.

Soil Pollution: Soil pollution could result from poor management of waste from project activities such as used oils, greases, plastic waste and other unused sheaths and cables that are not biodegradable. The erection of new poles and buildings at the hydropower plant will require the use of hydraulic concrete, which can lead to localised changes in some of the physical and chemical properties of the soil. This impact will be moderate.

Impacts on the Landscape: Installing work sites and undertaking works will have a minor and temporary negative impact on the landscape. Initially, developing the sites will lead to the destruction of the natural vegetation, and a moderate change in the landscape. The same will also be observed at the hydropower plant site due to the presence of construction machines. The infrastructure construction (Domoni hydropower plant) and associated networks (pipelines, power grids, access roads, etc.) will also lead to a change in the landscape of the construction sites. Apart from the machines that will be removed at the end of the construction works, the other installations will now be part of the landscape as long as they are in operation. This impact will be moderate.

Noise Pollution: Noise and vibration during works will mainly come from construction machines (jackhammers, mechanical shovels, poles, rollers, etc.), and trucks used to transport construction materials. The vibrations generated by jackhammers could weaken houses built with fragile materials. Noise generated by construction machinery and transport vehicles will affect residents in all parts of the country. They will be temporary (site schedules) and intermittent because not all machines will operate at the same time; hence the impact will be moderate.

6.2.2. Socio-economic Impacts

Loss of Income: It is possible that the installation of substations and the opening of quarries (all activities for which sites have not yet been selected at this stage of the project) may require land acquisition, resulting in the loss of socio-economic assets. Furthermore, pruning for network rehabilitation work could affect fruit trees. In these cases, provision will be made for possible compensation in accordance with the provisions of the ESMP mitigation measures.

Disruptions in the Movement of People and Goods, and Risk of Accidents: The crossing of residential and commercial areas to erect poles and lay power cables will have consequences on the movement of people and goods. The digging of trenches will create difficulties in accessing homes and businesses, leading to frustration and the risk of accidents. The risk of road accidents arises mainly during the construction phase and is linked to excavations, traffic and parking of construction vehicles, and the presence of vehicles pulling electric cables. As a result, mobility is necessarily disrupted during the construction period. The impact will be of moderate importance.

Conflicts among Project Stakeholders: Potential conflicts may arise during implementation and may, depending on the causes, involve various project stakeholders. Social unrest could occur during the preparatory phase if the recruitment process (skilled workers and labourers) is not transparent. Such conflict could pit the local population against the contractors. Other conflicts might spark off if the promoter fails to comply with customs and traditions and/or the clauses contained in the specifications. These include those concerning working conditions, compliance with safety conditions on site, non-compliance with clauses on noise and olfactory pollution, and the safety of residents. This impact will be of considerable import.

Communicable Diseases: With regard to health, the presence of temporary workers in the project areas may pose the risk of STI/HIV/AIDS transmission. There are also risks of developing respiratory diseases with the inhaling of dust from exhaust emissions. Workers, the elderly and children will be particularly at risk. The non-compliance of workers with individual and collective hygiene rules may lead to the development of faecal hazards or the appearance of diarrhoeal diseases. This impact will be of considerable import.

Desecration of Cultural and Religious Sites: From a cultural standpoint, there is no archaeological site in the area that the works might impact. However, if any cultural heritage is discovered during the construction of the hydropower plant and the rehabilitation of the electricity networks, the contractor must immediately notify the relevant departments of the Ministry of Culture, and the work will be carried out in accordance with their instructions. Nevertheless, it should be noted that there are a few religious sites near power line corridors (places of worship, etc.) but outside the right-of-way. These should be avoided and well protected.

Health and Safety: The risks of work-related accidents are tied to certain project tasks and activities, such as trenching (risk of falling for workers and the public), the erection of poles and drawing of electric cables, and working at heights. The type and seriousness of occupational accident and disease risks vary by activity, ranging from physical injury to certain infections. An aggravating factor of these risks may be the failure to control or comply with safety measures and instructions, particularly for unskilled workers. During the construction, workers may carry out various electrical tests. Improper handling may cause electrocution, which could be fatal.

6.3. Negative Impacts during the Operation Phase

Birds and Bats: The installation of MV pylons will have a definite impact on bats, with the risk of collision and electrocution. This is particularly the case for Livingstone bats which, during the fruiting season visit fruit trees, as well as for large raptors seeking to nests a-top pylons. The risk of colliding with the cables is also real at high relief or high and dense vegetation cover where birds cannot see the obstacle until it is too late.

Flora: This impact will concern the regular pruning of trees located in the immediate vicinity of overhead lines. These slashes will prevent the formation of electrical arc that could cause fire outbreaks or damage to the installations.

Climate Impacts (Ozone and SF6): Given the extremely low quantities of ozone generated by the power line, the MV line cannot have an impact on the potential to exceed the health limit values of 110 μg/m3 over 8 hours or on the climate. Furthermore, circuit breakers will use sulphur hexafluoride (SF6). This gas, which limits over voltages during outage, is a greenhouse gas with a global warming potential 20,000 times higher than that of carbon dioxide, which potentially makes it the most powerful greenhouse gas. Moreover, although SF6 is nontoxic in pure state, it carries the risk of suffocation when inhaled because of its chemical characteristics (its density is higher than the density of air). It can have effects on the ozone layer if it escapes.

Water Resources: Over-abstraction of water from the Galani spring for the needs of the hydropower plant could cause the depletion of the spring water resources and induce other adverse impacts. This is likely to aggravate an already constrained situation brought on by the drying of Anjouan's watercourses. This impact is due to the deforestation of the island's rocky forests in recent years. The impact will, however, be limited as abundant rainfall fosters groundwater recharge. Nevertheless, given the intensive deforestation on Anjouan Island in recent years, the authorities have started reforestation operations in collaboration with NGOs.

Water Pollution: Water leakage may occur in the pipe during the plant's operating phase. This leakage could infiltrate and eventually pollute surface groundwater. However, such recharge and pollution of superficial aquifers will be modest.

Risk of the Domoni Hydropower Plant malfunctioning: Although the probability of the power plant failure is generally minimal, flooding caused by the failure of the plant's turbines is possible. Essentially, the impact of disastrous failure of a small hydropower plant is moderate.

7. IMPROVEMENT AND MITIGATION MEASURES

This section identifies and briefly describes the proposed improvement and mitigation measures to increase the benefits or prevent, reduce, mitigate or compensate for the environmental and social impacts associated with the project. The project will implement the Environmental and Social Management Plan (ESMP). Companies and their subcontractors will be required to prepare a construction ESMP to ensure compliance with AfDB standards and applicable national regulations before construction kicks off.

7.1. Improvement Measures

The improvement measures mainly concern activities to be undertaken in favour of women. Reducing inequalities and protecting women from potential violence will be addressed by involving women in compensation for property losses; employing about 40% of them on the site where possible; raising awareness among women and girls about the risk of pregnancy, the dangers of HIV/AIDS or other sexually transmitted diseases, and supporting the development of income-generating activities in the fisheries and agricultural sectors. Besides these activities, provision has been made for other improvement measures, including the recruitment of local workers and public lighting.

7.2. Mitigation Measures

7.2.1. Regulatory Measures

The aim is to ensure that the project is compliant with AfDB environmental regulations and safeguards measures. During both the construction and operating phases, project activities should comply with environmental standards

19 regarding noise, airborne particles and air pollutants from equipment. In the absence of limit values, World Bank Guidelines were used. Moreover, the firms entrusted with the works will operate closely with the environmental services to comply with the regulations governing installations. Such installations must obtain an operating permit.

Standard mitigation measures applicable to construction sites will be implemented during the construction period. Before work begins, the site impact management plan will be put in place during the contractor recruitment and pre-construction phases.

Choice of Contractors: Environmental and social clauses will be included in the bidding documents (BDs) to optimise environmental protection and the socio-economic milieu during project works. The contractor shall also ensure compliance with national laws and regulations on the environment, land legislation and AfDB requirements. The Control Office will ensure that the contractor obtains various permits and authorisations required to undertake the works.

Contractor's Commitment: Companies will be required to submit a Site Environmental and Social Management Plan (SESMP), which must be validated by the DGEF within 45 days of contract award. The SESMP will address potential site impacts, including deforestation and reforestation, air quality and noise, traffic, waste, soil and erosion management, work in wetlands, health and safety, and damage during construction. The contractor will also draw up a local recruitment plan and a Code of Conduct for employees. The SESMP is the single reference document in which the contractor defines in detail all the organisational and technical measures it will implement to meet the obligations under the clauses on the environment, health, safety and health.

Measures during the Preparation/Construction Phase

The following measures will be prepared with regard to impacts on the biophysical environment:

Air Quality: The measures will focus on regular maintenance of construction site vehicles, limiting their speed and the number of unnecessary trips, watering access roads regularly, covering the materials transported and banning the burning of construction site wastes.

Environmental Noise: A reasonable soundscape should be preserved by using good-quality vehicles that are regularly maintained, optimising truck traffic and limiting speed, enforcing noise limits and working hours in institutional and residential areas, and having workers use protective equipment if exposed to high noise levels.

Soil Quality and Erosion: Working methods and various types of measures will be put in place, such as avoiding sensitive environments, working during the dry season, minimising topsoil clearance, protecting rubble against runoff, using excavated materials to regenerate degraded land along the line, and replanting grasses and shrubs at pylon sites on steeper slopes. The erosion management plan to be prepared by the companies will complement these measures.

Soil and Water Contamination: The contractor will plan emergency measures to respond to all spills, together with garbage, wastewater and oil collection/disposal.

Flora: During surveying, protected tree species will be identified and the areas to be cleared minimised, using GPS technology and manual work, to avoid additional deforestation resulting from the use of heavy equipment. Shrubs less than 3.5 m high in the right-of-way, as well as low vegetation around watercourses and on steep slopes, should be preserved. Existing access roads and quarries should also be used. The width of the right-of-way should be respected to the minimum required for installing conductors when the transmission line crosses plantations. Compensatory reforestation shall be practised at a 2:1 ratio. The contractor shall also ensure that no invasive non-native species are introduced and that workers are not allowed to collect non-timber forest products.

Fauna: To limit the disruption of wildlife habitats, biological corridors will be protected by preserving as much vegetation as possible by restricting clearing along the corridor to a certain height to enable small animals to pass through it. To protect animal habitat, streams, marshes and trenches will be kept free of vegetation and other debris. Poaching will also be prohibited. The consultant recommends that the contractor and the contracting authority work closely with the forestry services to see in what manner a flora restoration and protection programme would be implemented.

In socio-economic terms, the key measures recommended are as follows:

Flora: Prior to works and particularly before pruning and deforestation, those identified as land or fruit tree owners must be properly compensated for losses suffered.

Social Cohesion: Social cohesion risks stemming from the site's location will be limited by the strict implementation of compensation measures for assets lying outside the agreed right-of-way but affected by construction activities, as well as by establishing a fair and transparent local recruitment procedure.

Quality of Life: Measures will be taken to reduce noise, dust and heavy traffic generated by the works. Furthermore, an awareness plan on sexually transmitted diseases targeting the public and workers will be put in place, including voluntary and free counselling, free testing and condom distribution services.

Cultural Heritage: in the event of accidental discovery, the pylons will be relocated to avoid potential sacred, cultural or archaeological sites. Moreover, in the event of discovery, work will be interrupted and the competent authorities informed.

Operating Phase Measures

Provisions for the project phase concern measures to be taken to secure and maintain completed structures.

Securing Structures: The project manager will ensure that the rights-of-way of the installations are not occupied. In this regard, the involvement of regional and local authorities is strongly recommended to raise public awareness against such occupancy.

Measures to protect Sites Vulnerable to Erosion and Landslides: Some project areas are prone to water erosion and very significant landslides. Therefore, companies will have to stabilise the soil through revegetation or riprapping to avoid the risk of the poles falling.

Availability of Network Tracking Plans: At the end of the works, the project manager shall put the location plans of the rehabilitated network at the disposal of structures in charge of managing the power grid and public property, namely MAM'WE and EDA, the municipal councils, and the Cadastre Directorate. This information should be shared with other developers in the area.

Soil Protection against Pollution: Soil pollution caused by broken pipes and prolonged stagnant waters can be eliminated by quickly repairing the broken pipes and regularly monitoring them. These actions will be reinforced through periodic training or retraining sessions for technical officers in charge of environmental monitoring and facility maintenance. The public will be involved through awareness sessions on safe driving.

Measures to Control the Quality of Discharged water: To ensure the quality of water discharged during the hydropower plant operating phase, physical and chemical parameters will be monitored and instructions followed before and after equipment maintenance. After every plant equipment maintenance, it is recommended to check the water quality before discharging the overflow. It is also desirable to regularly monitor the physical and

21 chemical quality of the water at the inlet and outlet of the purification system. The specifications for managing the PCH shall include managing the hygiene of the spaces around the works.

Mitigation Measure against Impacts on Wildlife: The risk of electrocution, particularly for birds tempted to perch on MV lines or power tower transformers, can be avoided by applying the following measures: marking the guard cables that protect the conductive cables so that passing birds can see and move away from them; setting up visual scare systems (silhouettes of artificial birds of prey, called "frighteners", fixed on a support so that "prey" birds can fly over them and avoid the cables); using hanging insulators on pylons to protect the bird of prey that perch on them.

Mitigation Measures against Electromagnetic Risks: The impact of HV line electromagnetic fields on community health is higher for those directly under the line but decreases sharply as one moves away from it. Health protection areas will be established to shield people against the health impacts of electromagnetic fields generated by the transmission line. Fencing wires and hives can be earthbound by installing metal stakes. PASEC, MAM'WE and EDA will ensure that no dwelling house is directly under the line.

Measures against Accidental Oil or Fuel Leakage at Thermal Power Stations: This will involve the installation of a waterproof tank at each power plant connected to a remote waterproof pit to collect oil and fuel in case of leakage. This device prevents contamination when oil or fuel leaks. These tanks and pits must be proportionate to the quantity of waste oils at the power plants. The capacity of the pit must take account of oil and spray liquids in the event of fire in the power plants.

Measures against SF6 Emissions: This will involve implementing appropriate design, installation and maintenance techniques to limit leakage risk. When servicing an equipment containing SF6, the gas should be recovered using suitable tools, then reprocessed and reused if it meets the technical requirements of the equipment. Otherwise, the SF6 must be returned to a service provider for destruction or regeneration. It is necessary to monitor SF6 emissions and establish strict personnel intervention procedures (airing of premises, recovery of SF6 and its decomposition products, and personal protection) to protect against possible leakage and ensure the safety of people around electrical installations. Substation operations staff must also be trained on managing SF6 in the substation (recovery, filling, etc.). To that end, the substation must be equipped with a portable SF6 detector that can easily detect minor leaks. Ensure that the SF6 is recovered at the end of the equipment's lifespan.

Implementing an Emergency Plan against Fire Risks and Accidental Pollution: SONELEC (during the operating phase) and the contractors (in the construction phase) will prepare a Risk and Contingency Management Plan presenting the general safety measures applicable to such works in order to reduce, limit or even eliminate risks and the consequences of an accident. These standard measures do not exclude the implementation of additional actions appropriate for the site environment.

8. ENVIRONMENTAL MONITORING AND FOLLOW-UP PROGRAM

The purpose of the monitoring and follow-up programme is to ensure that mitigation and enhancement measures implemented produce the expected results and that they are modified, interrupted or replaced if deemed inadequate. Furthermore, it assists in assessing compliance with national environmental and social policies and standards, as well as the African Development Bank's (AfDB) safeguards policies.

8.1. Environmental Monitoring

Environmental monitoring aims to ensure that contractors meet their environmental commitments and obligations throughout the project cycle. Its purpose is to ensure that the improvement and mitigation measures proposed are effectively implemented during the implementation phase. Therefore, the purpose of monitoring is to reduce

22 inconveniences to the resident communities and the impacts of various project activities on the environment. The contracting authority will carry out environmental monitoring of each project activity, and may delegate part of its prerogatives to an approved control office. Environmental monitoring will cover both the construction and commissioning phases. It will be carried out by the Control Office during the works phase and by SONELEC both during the works and operational phases.

8.2. Environmental Follow-up

These activities consist of assessing and evaluating the project's impacts on certain environmental and social components of concern, and applying corrective measures as required. Moreover, it can also facilitate prompt reaction to any failing mitigation or compensation measures, or any new environmental problems by putting appropriate measures in place. Finally, environmental follow-up helps to better address impacts on subsequent projects and possibly to review environmental protection standards and guidelines.

Furthermore, the monitoring programme defines as clearly as possible the indicators to be used for monitoring mitigation and improvement measures that should be assessed during project implementation and/or operationalisation. It also provides technical details on monitoring activities such as methods to follow, sampling locations, frequency of measurements, detection limits, and definition of thresholds for reporting the need for corrective measures. The Directorate General of Environment and Forestry (DGEF) is responsible for environmental follow-up, which may be supplemented by the relevant administrative entities, depending on the type of monitoring indicator.

9. INSTITUTIONAL ARRANGEMENTS AND CAPACITY BUILDING NEEDS

9.1. Institutional Arrangements

The following institutional arrangements are proposed for implementing the ESMP:

The companies will be in charge of implementing the ESMP, especially the work site ESMPs that they will prepare.

The works Control Bureau (consulting engineer) will ensure the effectiveness and efficiency of environmental measures contained in the works contracts.

PASEC will oversee the works and facilitate the mission of the monitoring committees. PASEC will take into account environmental and social criteria when finalising and validating the layouts, and will participate in the environmental and social monitoring of the works. It will coordinate the implementation and internal monitoring of the environmental and social aspects of activities, and act as an interface between the project, local authorities and other stakeholders involved in the project.

DGEF: The Directorate General of Environment and Forestry (DGEF) shall approve the ESMP. Under the Project Assistance Protocol, the DGEF and its regional departments will carry out the external monitoring of the ESMP at national level, with a view to implementing the project's environmental and social measures.

The Regional Directorates of Environment and Forests: The Regional Directorates will supervise deforestation activities on the islands, as well as pruning and reforestation. They will participate in monitoring the ESMP implementation.

The Ministry of Health will participate in monitoring hygiene and public health issues (monitoring waterborne diseases; STI/HIV/AIDS, respiratory diseases, etc.).

The Directorate General for Labour shall ensure compliance with working conditions during works execution (schedule, salary, protection, hygiene and safety of the premises, etc.).

Local Authorities (prefecture and municipal council) will participate in sensitising the people and in social mobilisation activities. At the local level, the technical departments will closely monitor the implementation of ESMP recommendations. They will participate in social mobilisation, the adoption and dissemination of information contained in the ESMP, and will manage and maintain the infrastructure built.

NGOs will participate in reforestation and awareness-raising activities (inform, educate and raise awareness) of energy sector stakeholders and communities in the beneficiary areas on the environmental and social aspects of the project.

SONELEC will participate in its area of competence in the technical monitoring of works and the management of installations during commissioning. It will also provide monitoring and follow-up during the operational phase.

The ESMP implementation will be monitored by a committee comprising representatives of the various ministries, under the coordination of the Directorate General for Environment and Forestry. A memorandum of understanding will be signed with the DGEF in this regard.

9.2. Capacity Building

Interviews with the various stakeholders involved in implementing the ESMP revealed that for them to properly carry out their mission, it will be essential to set up a capacity building, information and awareness-raising programme for them.

Recruitment of an environmental and social safeguards specialist: To implement the project, PASEC shall recruit two local environmental and social safeguards specialists experienced in resettlement, to monitor environmental and social management activities. These experts will be based in Anjouan and Mohéli and shall be provided all the logistical facilities (vehicles, computers, measuring equipment, etc.) to enable them attain their objectives. The international environmental, health and safety specialist to be recruited under the initial project will coordinate the project's environmental and social aspects, in addition to covering the project components.

Training of stakeholders involved in project implementation: Training activities will aim at building the capacity of managers of the Monitoring Committee, PASEC and local technical departments, particularly in planning, management and monitoring/evaluation of the environmental and social aspects. The topics would focus on: (i) land, environmental and social aspects of the works; (ii) health and safety; (iii) appropriate environmental regulations; and (iii) environmental assessment regulations, good environmental and social practices, environmental site control and monitoring.

It will be recalled that SONELEC does not have a unit or department dedicated to project environmental and social monitoring. To address this issue, a Health, Safety and Environment (HSE) department shall be set up within SONELEC. The department would be responsible for the current project’s environmental and social monitoring/follow-up. It would also be AfDB's interlocutor for the proper implementation of the environmental and social component. The two local specialists to be recruited under the project will be attached to SONELEC and should be the first staff of the department, which will be strengthened during project implementation.

Stakeholder information, communication and awareness raising: In the opinion of all the stakeholders consulted, the successful implementation of the project will depend essentially on communication, i.e. the ability of managers to capitalise, pool and disseminate information while ensuring that it has been effectively understood within the desired timeframe. The table below summarises the planned information and capacity-building activities.

Capacity building, Information and Awareness-raising Activities

Beneficiary Responsibility for Activities Stakeholders Implementation Information/awareness raising on the project Information on the layout and works right-of-way Information on works duration Safety training on line right-of-way safety Firm Regional Raising awareness of the risks related to the presence of a SONELEC community power line and the behaviour to adopt PASEC Local population Awareness-raising on HIV The modes of STI and HIV infection High-risk behaviours Demonstration of condom use Occupational health and safety training Training and awareness raising on health and safety-related risks for certain tasks and first aid Fire-fighting and emergency response procedures Firm STI and HIV modes of transmission SONELEC SONELEC staff High-risk behaviours PASEC

Demonstration of condom use ESMP training Application of ESMP measures and other good practices during works (waste management, limitation of nuisances, etc.) DGEF PASEC Training on environmental and social monitoring PASEC Monitoring ESMP implementation monitoring SONELEC Committee Monitoring of health and safety standards

10. ESMP COSTS AND SCHEDULE

The project's environmental and social management measures will cost EUR 370,000. These are only indicative and may increase or decrease during project implementation. All other mitigation measures included in the ESMP but omitted from these costs will be duly incorporated into the bidding documents for the recruitment of construction companies. The ESMP will be implemented during the 33-month construction period and subsequently during operation.

Cost of Environmental and Social Management Measures Environmental and Social Measures Costs in EUR All Components Measures concerning the human environment Use of insulated cable at urban crossings PM Compensatory measures for loss of income sources (pruning of fruit trees) 90 000 Health measures and awareness campaign against STIs and HIV/AIDS 10 000 Improving women's living conditions (IGA) 80 000 IEC and training in environmental education for communities and management 35 000 committees Measures concerning the biophysical environment Air quality (usual measurements during construction) PM Soil and water degradation (management of used oils and diesel fuel) PM Draining of the existing Voidjou oil collection sump and conduct of PM maintenance work Installation of bird and bat diverters (expert intervention) 10 000 Reforestation campaigns 30 000 Monitoring and follow-up MdC’s control and monitoring of works PM Salary, international specialist in environmental and social protection PM Salaries of 2 local health, safety and environment specialists for Mohéli and 60 000 Anjouan Memorandum of Understanding with DGEF and technical departments for 20 000 implementing the ESMP Capacity building 35 000 Total 370 000

11. CONCLUSION

The ESIA and ESMP covering all project components on the three (3) Islands showed that the project will not generate significant or irreversible environmental impacts both in its direct and extended impact areas. The identified impacts will be addressed through appropriate mitigation or compensation measures, as described in the ESMP. Very few residual impacts will persist. However, the project is expected to have a significant positive impact on each of the islands at the national level. Under these circumstances, the project is deemed environmentally and socially acceptable.

12. REFERENCES AND CONTACTS

Habib DIEDHIOU, 2019. Environmental and Social Impact Assessment (ESIA) – Comoros Energy Sector Support Project (PASEC) Habib DIEDHIOU, 2019. Environmental and Social Management Plan (ESMP) – Comoros Energy Sector Support Project (PASEC) For further information, please contact:

For PASEC: Msaidie ZABABI, Project Coordinator: [email protected] Youssouf Mohamed NASSURDINE, Regional Project Coordinator: [email protected]

For AfDB: Humphrey N. RICHARD, Manager: [email protected] Moussa KONE, Power Engineer (Consultant): [email protected] Gisèle BELEM, Environmental and Social Safeguards Officer: [email protected]