Chapter 6 Environmental and Social Assessment of Draft Fisheries and Aquaculture Sector Development Plan (Fasdp)

LOI #: MOFA/GFSDP/PPA/CS/LOI/2010/01

Public Disclosure Authorized

ENVIRONMENTAL AND SOCIAL SAFEGUARD ASSESSMENT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK MARCH 2011

Public Disclosure Authorized

WEST AFRICA REGIONAL FISHERIES PROGRAM IN GHANA (WARFPG)

Submitted to: The Secretary to the Fisheries Commission and Director of Fisheries, The Ministry of Food and Agriculture, Accra Ghana Public Disclosure Authorized

By:

United Kingdom: Ghana Office: Church Barn House No. F872/1, Fifth Close, Ring way Church Lane Estates Accra-Ghana Tickenham Tel: 0302 912909 Fax: 0302 242425 Bristol, BS21 6SD

Public Disclosure Authorized Tel: +44 (0) 1275 811345 Fax: +44 (0) 1275 811333 E-mail: [email protected] www.theIDLgroup.com

PROJECT TEAM:

Terry Green - Project Director

Peter Jon Nelson – Team Leader - Environmental and Social Assessment Consultant,

Victoria Wiafe - Project Manager – IDF Group Ghana

Dr Andrew Baio – International Fisheries Consultant – Sierra Leone

Dr. Edward Kofi Abban National Fisheries Consultant – Ghana CSIR

Audrey Allotey Research Assistant

ACRONYMS

AF Affected Fisheries CMA Co-management Associations EIA Environmental Impact Assessment ESMF Environmental and Social Management Framework ESIA Environmental and Social Impact Assessment FC Fisheries Commission MCF Monitoring, Control and Surveillance MOFA Ministry of Food and Agriculture MPA Marine Protected Area NPF National Process Framework NGO Non-governmental organisation PAP Person affected by the project PC Participating Communities RAP Resettlement Action Plan RPF Resettlement Policy Framework TURF Territorial User Rights to Fisheries WARFP West Africa Regional Fisheries Programme WB World Bank ZMGFR Zoning Map of Ghana’s Fishery Resources

iii

TABLE OF CONTENTS

EXECUTIVE SUMMARY 1

PART A – ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT AND DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

1. INTRODUCTION 7

2. PLAN AND PROGRAMME DESCRIPTION 11 Part 1 The Draft Fisheries and Aquaculture Sector Development Plan 11 Part 2 The World Bank’ Contribution to the Ghana Fisheries Plan 11

3. BASELINE CONDITIONS 15 3.1 Profile of the Fisheries Industry 15 3.2 Environmental Conditions 20

4. POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL ISSUES 25 4.1 World Bank and Other Donors’ Safeguard Policies 25 4,2 Governance Framework in Ghana 28

5. WORLD BANK SAFEGUARD ISSUES 37

6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP) 45 6.1 Positive Environmental and Social Impacts 6.2 Adverse Environmental and Social Impacts

7 ASSESSMENT OF POLICY OPTIONS 53

8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 57

PART B NATIONAL PROCESS FRAMEWORK AND DRAFT NATIONAL RESETTLEMENT POLICY

9 DRAFT NATIONAL PROCESS FRAMEWORK 67

10 DRAFT RESETTLEMENT POLICY FRAMEWORK 71

BIBLIOGRAPHY

ANNEXES 1 Annex 1 to the Terms of Reference 2 Environmental and Social Evaluation Matrix

EXECUTIVE SUMMARY

This report draws together the contents of two separate documents which examine a number of interrelated issues concerned with environmental and social safeguards for the development of the fisheries sector in Ghana.

The first document (Part A) contains the Environmental and Social Assessment (ESA) of the Ghana Fisheries and Aquaculture Sector Development Plan (FASDP) together with a draft of the Environmental and Social Management Framework (ESMF) that will be adopted by the Government of Ghana. This document is reproduced in Chapters 1-8 of the Composite Report.

The second document (Part B) contains the outline structure of Ghana’s National Process Framework (NPF) for implementing the design and implementation of local fishery co-management,maintaining sustainability of local livelihoods and local monitoring of fisheries efforts together with an outline Resettlement Policy Framework (RPF). These elements are covered in Chapters 9-10 of the Composite Report.

This Composite Report and its individual components have been prepared on behalf of the Government of Ghana and the World Bank. Following review by both parties, it will be adopted as part of the framework leading to promotion of the Ghana Fisheries and Aquaculture Sector Development Plan.

Chapter 1 of the Report describes the need for environmental and social safeguards in the fisheries sector. It notes that the overall aim of FASDP is to improve fish stocks and increase the sustainability of fishing activity which will have long term environmental and social benefits for the Country.

Chapter 2 summarises the basic aims of the Ghana Fisheries and Aquaculture Sector Development Plan and proposals for financial and technical aid which are being developed by the World Bank. A decision on funding support will be taken by the World Bank in 2011. The World Bank is proposing to support FASDP under four key components. These are Good Governance and Sustainable management of the fisheries; reduction of illegal fishing; increasing the contribution of the marine fish resources to the local economies and assisting with coordination, monitoring, evaluation and programme management.

Chapter 3 provides a baseline description of the current nature and importance of Ghana’s marine and inland fisheries which provide 65% of the countries protein requirements, and sustain the livelihoods of almost 10% of the Ghana’s population. Unfortunately however, fishing is approaching a crisis. In recent years the annual volume of catch has fallen (from in excess of 500,000 to under 400,000 tonnes) but at the same time fishing effort has increased. If it were not for government subsidy the economic returns could no longer be justified since it costs more to catch and land fish than they are actually worth in the market place. Fishing activity (principally trawling) is causing substantial damage to the marine environment, while illegal methods in the canoe sector, including dynamiting and use of chemicals threaten fish stocks and human health

Chapter 4 examines the governance, legislative and policy framework under which reforms in the fisheries sector will take place. The chapter identifies five World Bank safeguard policies that are potentially triggered by FASDP. These are OP 4.01, Environmental Assessment; OP4.04 Natural Habitats; OP 4.09 Pest Management and OP 4.11 Physical and Cultural Resources and OP 4.12 Involuntary Resettlement. In most cases, the range of projects proposed under FASDP would have minimal impacts under these safeguards but there is nevertheless a need to ensure that adequate

1 protection and mitigation is provided through implementation of an Environmental and Social Management Plan

Chapter 5 considers the four funding components under which the World Bank is proposing to support the Ghana Fisheries and Aquaculture Sector Development Plan. These cover:

1. Good governance and sustainable management of the fisheries, 2. Reduction of illegal fishing, 3. Increasing the contribution of the marine fish resources to the local economy, and, 4. Coordination, Monitoring and Evaluation and Program Management. The potential for investment to give rise to adverse effects on the environment and/or social conditions is reviewed. It is concluded that that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments. The only possible exception relates to the effectiveness of measures that are put in place under Sub-Component 1.2 to support pilot stakeholder- based fishery initiatives. The outcome of the overall program will depend heavily on the success of these pilots. For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 1.3 and 1.4.

Chapter 6 provides an analysis of the environmental and social issues raised by the wider fisheries and aquaculture programme and as such it constitutes the Environmental and Social Assessment (ESA). A matrix is used to identify potential interactions between elements of marine and inland fishery capture operations and the natural environment together with possible socio-economic effects. A similar matrix is also used to examine the potential for aquaculture development. The overall effects of the planned interventions are positive in terms of both environmental and socio-economic gains, but there are potentially some adverse social and economic consequences for a limited number of individuals, whose livelihoods will be affected by restrictions on access to fishing or from changes in economic conditions affecting the purchase, processing and marketing of fish. Mitigation measures are considered subsequently in Chapter 8.

Chapter 7 briefly considers the possible consequences of taking no action to deal with the declining stocks and profitability of fishing (the do-nothing option A). This is a standard part of the methodology for conducting an Environmental and Social Assessment. The conclusions are compared with the alternatives of taking limited action (a ‘weak’ option B) or of implementing the full set of plans and proposals (the ‘optimum’ option C). The comparison includes the conclusion that the fisheries industry is often studied and dealt with in isolation from other parts of the economy. However, in order for the planned reforms to have maximum beneficial impact a new approach is required to integrated coastal development, in which a range of ministries and agencies should be involved.

Chapter 8 sets out a draft Environmental and Social Management Framework (ESMF). This picks up areas of risk identified in the ESA Report and proposes remedial action. The ESMF notes that the principal goals of government policy are to :

• Improve management of fisheries, the conservation of aquatic resources and protection of the natural environment, • Promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities, • Encourage sustainable development of aquaculture,

• Improve the services provided to the fisheries sector by the Fisheries Commission and supporting institutions.

The Draft ESMF sets out eight specific interlinked actions, namely: 1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters; 2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work; 3) Regular inspection by environmental protection officers of construction work at harbours and landing sites; 4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above; 5) Creation of community liaison groups to actively support community development, alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted; 6) Introduction of skills training centres and business advice for small and medium enterprise development; 7) Establishment of a coastal development approach drawing on the resources of the ministry of local government, agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans; 8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort. Chapter 9 provides a draft National Process Framework (NPF)) to implement the recommended process framework laid down by the West Africa Regional Fisheries Program (WARFP) which Ghana will become part of. This framework explains how eligibility criteria will be employed to determine which settlements qualify as participating communities and what the responsibilities of these communities will be in terms of setting up Co-management Committees (CMCs) and selecting classes of Project Affected People (PAPs) who will be eligible for assistance under national guidelines to be prepared by the Fisheries Commission. The ESMP also outlines proposals for income restoration measures in accordance with World Bank guidance as interpreted through the West Africa Regional Fisheries process framework that where open access to fishery resources is restricted for the common good, any adversely affected individuals should not be penalized but should receive assistance to restore their livelihoods at least to the extent that they are impacted by the project activities and preferably to an improved state.1 Measures are also outlined for conflicts or grievance resolution, administrative and legal procedures and monitoring arrangements.

1 Extract from Executive Summary, Process Framework; West African Region\l Fisheries Program (P106063) : Cape Verde, Liberia, Sierra Leone, Senegal. Commission sous Regionale des Peche, Dakar, Senegal . “Section V. Livelihood Restoration Measures. World Bank policy requires that livelihoods be restored at least to the extent that they are impacted directly by project activities and preferably inproved. This policy prescription is based on the principle that people who give up most for the public good – the PAPs- should not be penalised and impoverished as a result of their loss for the greater good. The aim, thereopfre is to improve the public good (in this instance , marine resources) while also ensuring that those who lose access to resources and income because of restrictions on marine resources are assisted effectively to restore that part of their income that is affected through alternative livelihood measures.” 3

Chapter 10 looks in more detail at specific safeguards relating to possible involuntary relocation of people as a result of the long term fisheries programme. It constitutes the Resettlement Policy Framework (RPF) which, while not a formal legal requirement of the World Bank’s lending policy, is nevertheless recommended as good practice.

PART A ENVIRONMENTAL AND SOCIAL SAFEGUARDS ASSESSMENT

The Environmental and Social Safeguard Assessment comprises: • Three background chapters (1-3); • Two chapters which deal with assessment of the potential effects of the World Bank’s financial and technical support for the Ghana Fisheries Programme over the initial five years (Chapter 4) and the longer term effects of the overall Fisheries Programme which is expected to run for 10- 15 years (Chapter 5); • Analysis of the consequences of taking no action (the do-nothing option) in Chapter 7, and, • A draft Environmental and Social Management Framework (Chapter 8)

CHAPTER 1 INTRODUCTION

1.1 INTRODUCTION The government of Ghana is embarking on a Fisheries and Aquaculture Sector Development Plan (FASDP) for restructuring its coastal and inland fisheries. The aim is to reverse the current trend whereby fish stocks are increasingly diminishing and the current rate of fishing is unsustainable, resulting in less productive fisheries, increased costs with declining profitability and the risk of exacerbating nutritional deficiencies and poverty within fishing communities. To date, the government has enacted legislation (Fisheries Act 2002), prepared policies (2008, updated in 2010) and published regulations (August 2010) but the Ministry of Food and Agriculture and the Fisheries Commission lack the capacity and financial resources to implement all of these initiatives. The World Bank is therefore considering a supporting programme of technical assistance and finance which will assist with governance reforms, the introduction of licensing for all vessels, a reduction in the size of the industrial and semi-industrial fishing fleets and the progressive transfer of fishing activity to the canoe sector.

International support for Ghana's fishing industry is being coordinated under the West Africa Regional Fisheries Programme (WARFP). This initiative began with four countries; Cape Verde, Liberia, Sierra Leone and Senegal. It is now being extended to the following countries; Ghana, Guinea, Guinea Bissau and Gambia. A process framework has been developed by the Commission sous Regionale des Peche (Based in Dakar, Senegal) to assist member countries of WARFP to prepare their own national process frameworks, together with accompanying environmental and social safeguards assessment, an environmental management plan and resettlement policy.

This report has been designed to provide the outline structure and contents for these documents on behalf of the Government of Ghana. Another important function of the report is to review the application of the World Bank's own Environmental and Social Safeguard policy to the planned investment. Both the government's development plan (FASDP) and preparation of the World Bank's financial assistance package are at an early stage. Consequently, this report covers (and can only cover) the broad principles and sets out initial conclusions. It will be necessary for further reviews to be undertaken when the Government of Ghana’s programme has been developed in more detail.

Objectives of the Environmental and Social Assessment (ESA) The overall aims of planned interventions in the fisheries industry of Ghana are to improve fish stocks and increase the sustainability of fishing activity which will have long-term environmental and social benefits for the country. However the process of introducing change is likely to have some short-term adverse effects on individuals and particularly those who are vulnerable or disadvantaged within poorer fishing communities unless appropriate mitigation measures are taken. The purpose of the environmental and social assessment set out in chapter 6 is to identify potential environmental and social impacts both individually and cumulatively and to assess their relative magnitude, duration, reversibility and importance. Based on these findings the draft management framework (see chapter 8) sets out proposals for avoiding or mitigating unacceptable change.

The process of reforming the fisheries sector will take a number of years and the existing FASDP covers only the first five years. With the exception of proposals to scale down the size of the industrial and semi-industrial fishing fleets it is unlikely that major changes will take effect in terms of fishing activity during this five-year period. Consequently, from the standpoint of the World Bank's investment there are likely to be relatively few issues in terms of potential conflict with safeguarding policies. Later,

7 however, significant change is within the fishing industry and particularly onshore processing and marketing of fish products. An important element in this report has therefore been the need to define the point at which the banks’ responsibilities are seen to terminate and all liabilities are transferred to other supporting donors and the government of Ghana.

In the short term, a reduction in the industrial fleet may lead to the loss of 1000 to 3000 jobs* for crew members although in practice most of this work is only part time and many of the vessels that are due to be withdrawn are no longer seaworthy. In the longer term it is intended to encourage more selective fishing by limiting open and unfettered access to fish stocks, eliminating illegal and damaging processes including dynamiting, uncontrolled light fishing, and the use of small size monofilament nets and introducing seasonal restrictions to protect breeding cycles. The intention is that these measures will be managed jointly by the government and communities through co-management systems. At the same time major efforts will be made to reduce the level of post-harvest losses and to increase the value of fish products.

The expectation is that the number of industrial, semi-industrial vessels and canoes will be stabilised at a fixed, lower, level within five years. Once this point is reached and no further licences are granted, individual licences will acquire higher values especially as fish stocks recover and the size and value of fish catches starts to increase. Subsequently, licenses are likely to be sold and traded as less efficient owners drop out of the market and sell on to stronger individuals and companies. In terms of onshore activities, fish landing, processing and marketing will become more efficient and losses will be reduced through use of better smokers, freezing and drying equipment.

Previous studies in West Africa and elsewhere (Bennett et al, 2001) have shown that the transition away from open access to a more regulated system of access management can give rise to social risks. Specifically, older men are likely to be displaced when they are no longer fit enough to withstand the rigours of fishing while a rising number of young men may find it harder to enter a career in fishing. Women who currently manage or assist with all areas of buying, processing and marketing using traditional clay ovens may also experience competition as new companies and enterprises are established to take advantage of higher profitability in the fishing sector, perhaps using better equipment, newer technologies, and different logistics arrangements or their own transportation.

Methodology

This study has followed the methodology developed within the process framework for the West Africa regional fisheries programme (WARFP). Figure 1 sets out both sequence and timescale for the work.

* The range of jobs at risk is based on assumptions about the number of vessels and average crew size and cannot be determined with any degree of accuracy until the necessary surveys are undertaken.

The report is based on three major areas of activity: 1. documentary analysis and utilisation of the studies already carried out by the fisheries commission 2. meetings with institutional stakeholders principally affected by the project, and 3. Consultations and visits to some of the key fishing villages and communities.

The planned presentation of findings to Stakeholders has been postponed at the Client’s request due to other pressing commitments in the agriculture and fisheries sectors. This presentation will, however, need to be subsequently undertaken by the Ministry and the Fisheries Commission.

CHAPTER 2 PLAN AND PROGRAMME DESCRIPTION

INTRODUCTION

This chapter is divided into two parts: Part 1 sets out the progress which the government Ghana is making in giving effect to the legislation, policy and regulations. Part 2 describes the proposed programme of assistance being offered by the World Bank with the specific aims of strengthening governance and enforcement systems (Components 1 and 2) and in promoting value addition and reduction of post-harvest losses.

PART 1- THE DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)

This plan (FASDP) covers the period 2010-2015. It recognises the importance of Ghana’s fisheries which generate in the order of US$ 1 billion a year, contribute 4.5% to GDP and indirectly support the livelihoods of 2.2 million people. However, through over-fishing and lack of investment in management and value addition, the average income per canoe has dropped by up to 40% over the last ten years to the point where it costs as much to fish as the catch is worth. By comparison, well managed fisheries in other parts of the world are capable of generating economic returns of 30-60% on investment (equivalent to a potential income of US$ 300 million a year for Ghana’s fisheries).

The Draft FASDP acknowledges that the fishing sector is expected to make a substantial contribution towards doubling the size of the Ghanaian economy by 2015 (GPRS II) as part of the Republic of Ghana Fisheries and Aquaculture Policy. Seven targets are set in the draft FASDP: 1. Maintaining capture fisheries production at current levels, 2&3 Increasing revenue and profitability in capture fisheries by at least US$ 50 million a year after five years, 4. Increasing aquaculture production to 35,000 tonnes a year after five years, 5. Retaining Ghana as a landing and processing hub for the West Africa tuna industry, 6. Developing fisheries management to allow effective control of all commercial fishing effort in Ghanaian waters, and, 7. Ensuring fisheries management costs are sustainable and that the fisheries sector overall make a fiscal contribution to Government revenues.

There is an underlying presumption that the canoe sector will remain at the heart of Ghana’s fishing industry but the plan is not prescriptive and leaves open the ways of achieving the overall goals. At the same time there is an underlying assumption that the long term sustainability of Ghana’s fisheries will depend upon discouraging further entry by new operators.

PART 2 THE WORLD BANK’s CONTRIBUTION TO GHANA FISHERIESPLAN (FASDP)

The essential aim of the World Bank’s contribution to FASDP is to provide investment which will build the necessary policy and capacity for effective fisheries management designed to reduce fishing effort while maintaining approximately the same catch levels and to address the impacts of change for fishers

11 and the communities in which they live. Based on the currently available draft Project Appraisal Document (PAD) , each of the components is now described in turn

Component 1 - Good governance and sustainable management of the fisheries This component on good governance comprises four subcomponents which are broken down in turn into a number of separate activities

Sub-component 1.1 developing the capacity, rules, procedures and practices for good governance of the fisheries:

Activity 1.1.1 reviewing the Fisheries Act and developing regulations to support the Sector Policy and the Fisheries and Aquaculture Sector Development Plan. Activity 1.1.2 Developing an operational policy to enable implementation of the aquaculture and fisheries sector development plan. Activity 1.1 3 strengthening fisheries management systems and capability (fisheries management plan development, aquaculture implementation, technical support and training), Activity 1.1.4 strengthening fisheries Information Systems (catch recording and monitoring systems, statistical analysis, and training),

Sub-component 1.2 introducing fishing rights

Activity 1.2.1 developing pilot stakeholder-based fisheries management initiatives around defined fisheries units (i.e. local management initiatives tighter defining fisheries resources in up to 6 selected Fisher communities), Activity 1.2.2 introducing and administering a licensing regime,

Subcomponent 1.3 Adjusting fishing effort and capacity to more sustainable levels, marine resource conservation, and supporting alternative livelihood opportunities when needed:

Activity 1.3.1 vessel decommissioning, Activity 1.3.2 compensation packages for crew of decommissioned industrial/semi-industrial vessels, Activity 1.3.3 alternative livelihood development to incentivise voluntary capacity reduction in the canoe sector, Activity 1.3.4 marine resources management and conservation,

Subcomponent 1.4 social marketing, communication and transparency

Activity 1.4.1 communications, stakeholder consultations and awareness raising programmes to support fishery development,

Component 2 reduction of illegal fishing Under the West Africa regional fisheries programme subcomponent 2.1 allows for enabling environment for reduction of illegal fishing. These provisions already exist within Ghana and this subcomponent is therefore omitted.

Subcomponent 2.2 monitoring, control and surveillance (MCS) systems Activity 2.2.1 developing compliant systems and capability,

Component 3 increasing the contribution of the marine fish resources to the local economies Subcomponent 3.1 product diversification/value chain development (fresh/frozen product/trade facilitation)

Activity 3.1.1 landing site development Activity 3.1.2 Port development,

Subcomponent 3.2 fish product trade infrastructure, information and systems - regional minimum integrated trade expansion platform (MITEP)

Activity 3.2.1 export certification centre development, Activity 3.2.2 fish processing technology improvements, Activity 3.2.3 national fisheries advisory group,

Subcomponent 3.3 marine and inland aquaculture development Activity 3.3.1 space developing aquaculture policy and legal framework Activity 3.3.2 improving genetic policy of tilapia fingerlings and breedstock, Activity 3.3.3 catalysing aquaculture development

Component 4 Coordination, monitoring and evaluation and program management

Subcomponent 4.1 national implementation subcomponent 4.2 regional coordination.

Each of the components, sub-components and activities are described in more detail in Chapter 5 which assesses the nature of environmental and social safeguards issues in terms of the World Bank’s planned investment.

CHAPTER 3 BASELINE CONDITIONS

INTRODUCTION

This chapter discusses the existing fishery resources of Ghana and describes recent environmental and social trends. It identifies some of the pressures that led to the reduction in value of fishing activity and indicates the threats that could be posed if no action is taken, in accordance with the planned fisheries and aquaculture program, to deal with them.

FISHERY RESOURCES

The continental and coastal waters of Ghana are potentially very rich due to a combination of warm waters and nutrients carried in ocean currents which up-well seasonally on the continental shelf. The tonnage of fish caught in marine waters peaked in the mid-1990s around 500,000 tonnes and currently averages around 400,000 t.(See Figure 1)

Figure 1 Wild Capture Production in Ghana Table3.1 Top 10 Species Exported (by value) 1950-2005

1. Canned tuna ($72,000,000) 2. Fresh tuna ($7,200,000) 3. Tilapia (no figure available) 4. Miscellaneous dried fish ($1,000,000) 5. Salmonids, frozen ($900,000) 6. Marine fish, frozen ($600,000) 7. Cuttlefish and squid ($600,000) 8. Shrimps and prawns ($90,000) 9. Sardines ($80,000) 10. Crustaceans, frozen ($50,000)

Source: FAO Fishstat

The principal catch from deep waters is tuna. Industrial vessels registered in Ghana target these species in international waters but also illegally in coastal waters. Herring, sardine and anchovies are fished in coastal waters by semi-industrial vessels and canoes. Table 3.1 shows the top 10 species of fish exported from Ghana in 2005.

PROFILE OF THE FISHING INDUSTRY

Fishing is of vital importance in Ghana not only in terms of its contribution to gross domestic product (4.5% per annum) but because fish provides 65% of the country's protein. In recent years (between 2003-2008) and more specifically, in 2004, the country’s annual fish requirement has been estimated to be 882,000 tonnes of which the country produces just about half (Tetteh 2007). Of the total population of 22 million people it has been estimated that between 1.5 and 2.2 million people are employed or gain their livelihoods from fishing (8-10%). Of these there are 210,000 men who are directly employed as

2 This figure is the Fisheries Department’s estimate for 2008. 15 fishers. The total export of seafood was valued US$82.4 billion in 2005.

Ghana's fishing industry can be divided into three sections; marine capture, inland capture and aquaculture. It can be further analysed by scale of operations distinguishing between industrial, semi- industrial and artisanal sectors.

Marine fisheries

Industrial sector: Commercial fishing for tuna began in 1962. In the early 1980s, Ghana sought to develop an industrial fishing fleet and there are currently 90 industrial trawlers and other vessels which are located in Tema and Takoradi / Sekondi. The port of Tema was expanded from 1962 to create four main areas, the Inner Harbour, Outer Harbour, Canoe Basin and Commercial Area. In 1999 fish landing facilities were improved at the Albert Bosumtwi Sam Fishing Harbour built in Sekondi. This harbour is equipped with a cold store, an ice-making plant, offices, a berthing bay for inshore vessels, a jetty for canoes and a net drying area.

Under Ghanaian law more than 50% of the ownership of industrial vessels must be registered with a Ghanaian company or individuals. However in practice, many vessels are owned by foreign nationals with token Ghanaian ownership. Relatively few of these large vessels regularly put to sea and a number are in poor condition or obsolete. Nevertheless, the impact of trawling activities by Ghanaian registered and foreign owned vessels has been very considerable in coastal waters in recent years. Fish landed from industrial vessels is usually transferred directly to Canning factories in Tema and Takoradi. Ghana has the largest canning industry in West Africa. In the region of 30,000 tonnes of tuna are landed In addition to trawling some industrial vessels are engaged in shrimping, the use of tuna lines and polls, purse seining and demersal trawling.

Semi-industrial sector: in addition to deep sea trawlers there are around 230 large semi-industrial ships propelled by inboard motors which are used for trawling in shallow waters during the off-season and purse seining during upwelling seasons. There are currently reported to be 48 bottom trawlers, 14 pair trawlers, 2 shrimpers, 33 pole and line vessels and 10 tuna purse seiners operating from 2 of the 7 landing sites.

Canoe sector: Ghana's artisanal fishing sector is based on between 10,000 and 12,000 wooden canoes. Fifty seven per cent of the fleet is powered by outboard motors supported by paddle and occasionally sail. Each Canoe carries a crew of between three and 20 men depending on size and length. There are over 334 landing sites along the 550 km coast of Ghana and the majority of fish caught by canoe (180,000 tonnes) is returned to these sites accounting for 70% of Ghana’s fish production. The principal landing sites are at Teshie, Jamestown, Chorkor, Shama, Axim, Elmina, Winneba, Mumford, Akplabonya, Adina, Atiteti, Abutiakope and more. Fishing is undertaken by men but the majority of canoes are owned by women who pre-finance fishing trips (purchasing gear and premixed fuel) and purchase the catch. Women also predominate in processing and marketing fish and fish products. Only about 20% of fish sold fresh, a further 20% is salted and the majority (60%) is smoked. It is estimated that up to 30% of the catch is spoilt through lack of ice for storage or alternative processing facilities.

Inland fisheries

Water Resources : Ghana’s inland fishery resources consist of a natural lake( Lake Bosomtwe) and nine major river basins, which from east to west of the country are: • the Volta, • Densu, • Ayensu, • Ochi, • Kakum, • Pra, • Ankobra, and, • the Tano The River Tano forms the border between Ghana and Cote d’ Ivoire. The largest of the rivers is the Volta, which drains more than two-thirds of the country through several large tributaries in virtually all regions of the country. The Volta river system also incorporates the Volta reservoir, generally known as the Volta Lake which has a surface area of around 8,400 km2. The Volta lake discharges through the Akosombo dam before flowing through a delta into the Atlantic Ocean.

The eight other river systems are relatively smaller, simpler, and open more directly into the Atlantic. There are also several reservoirs created on the smaller river systems mainly for potable water production, irrigation and flood control. These reservoirs, irrespective of their primary purposes, enhance availability of more permanent aquatic habitable space for fish and therefore support some fisheries.

Finally, with all the river systems opening into the Atlantic there are a series of lagoons and estuaries which act as interfaces between the rivers and the sea. These water areas constitute another type of inland water resource for salt and brackish water fishes.

Inland Fish resources: Within the inland water resources of Ghana there are over 150 fish species more than 90 % of which are fished for food.

In commenting on inland fisheries in Ghana it must be noted that virtually all available information on inland fisheries is obtained from the Volta Lake. No national fish production records have been kept on the fisheries of the eight smaller river systems and the lagoons and estuaries. Thus, the usual statement that inland fish production constitutes about 20 % of what the country produces should refer to fish production from the Volta Lake. In practice the total inland fish contribution could more realistically be estimated at about 30-35% of national fish production. This is a very considerable but understated contribution to national food security and nutrition.

Fishing vessels: The dominant fishing vessel on the Volta Lake is the canoe, the majority of which are built from wooden planks. On some other river systems while plank canoes predominate, a small number are carved as dug-outs from single tree trunks. There is some variety in sizes of the canoes depending on how many planks are used to build the boat and the size of tree trunk used in building a canoe. The total number of canoes estimated on the Volta Lake during a survey in 2000 was 24,035. On the tributary rivers of the Volta Lake and other river systems in the country, the planked canoe is the main vessel used in fishing.

Fishing gear: There are about eleven main kinds of gear used for fishing on the Volta Lake. They are: Gill Nets, Cast Nets, Hook and Line, Basket and wire mesh traps, Winch net, Beach seine, Bamboo, Nifa- nifa, Wangara, Spears and Atidzas. On other rivers in the country, Gill nets, Cast nets, Hook and Line and traps are the fishing gear used. On both the lake and rivers, the Gill net is the main gear.

People Involved: In the 2000 frame survey of the Volta Lake conducted by the Fisheries Directorate of Ghana, the estimate of fishers on the Volta Lake was put at 71,861. Fishers on the lake work in collaboration with a host of fishmongers or handlers who also function as wholesalers for individual fishing groups. Assuming that the fisher population on the lake has increased by a modest 3% in the ten years from 1998 to 2010, a fisher population of about 93,500 could be considered to be on the Volta Lake now. If again it is estimated that number of fishers on rivers in the country were to be a tenth of those on the lake, this would put the fisher population on inland waters (apart from the Volta Lake) at about 9,350 fishers. A very conservative estimate therefore puts the total number of individuals who are directly engaged in inland fishing at over 100,000. This excludes all directly associated groups, such as fish handlers, processors and traders. An estimate of secondary fisheries operators, such as, boat builders, out-board motor operators and mechanics as well as bulk salt and fuel wood sellers and those engaged in buying, selling and distributing fish would have to be considered in developing estimates for both direct and indirect employment in inland fisheries but the number can be assumed to lie between 125,000 and 150,000 people.

Aquaculture

Under Ghana’s legal framework aquaculture is defined as “any activity designed to cultivate or farm fish and other aquatic living resources”. Currently only fin fishes are involved in aquaculture in Ghana.

Current culture media and environment: Currently fish culture takes place almost exclusively in fresh water in Ghana, either in cages, brush parks or dugouts. Dug-outs are excavations made in floodplains in the savannah parts of the country were water scarcity has been a major hindrance to development in general and food security in particular. Dug-outs get filled with flood waters and whatever the water carries during major wet periods of a year in the savannah areas. Waters that fill Dug-outs invariably contain fish which are trapped in the Dug-out after the wet period. These water bodies are managed until the end of the dry period and the fish are harvested before the next flood period.

Since the 1960’s various strategies to augment fish production from Dug-outs have been developed and tested. These involve adding fingerlings of selected fish species to those which are ‘naturally stocked’ in Dug-outs by floods. Dug-outs are the major fish culture production approach in the savannah parts of the country, which accounts for a little more than half the area of the country.

The Environment of fish culture: Currently, fish culture is taking place mainly in freshwater environments. Brackish water fish culture and mari-culture activities which will bring lagoons, estuaries and the sea into fish culture production have long term potential for development.

Fishes in culture : Fishes being cultivated in Ghana In order of importance are: Nile tilapia, Oreochromis niloticus, the African catfish, Clarias gariepinus, species of the catfish, Heterobranchus, and the Bony tongue, Heterotis niloticus

Scale of Culture: Based on level of production, fish culture operations can be categorized as follows: • Large scale commercial, where an enterprise produces up to 10,000 tonnes per year;

• Medium scale commercial, where a single enterprise produces between 50 and 500 tonnes; • Small scale commercial, where an enterprise produces between one and 20 tonnes, and, • Very small scale commercial, with productions below 20 tonnes.

Fish culture production: Cultured fish contribution to national production was officially stated as 9,000 tonnes for the year 2009. However, informed opinion amongst fish farmers indicates that a figure of between 16,000 and 20,000 tonnes in 2010 would be closer to reality. This statement is based on the facts that most producers’ published figures are underestimates; several small to medium scale producers are not recorded in official lists and the recording of newly established fish farms has lagged actual establishment especially since 2009. Although cultured production up till 2009 may not have been significant considering a shortfall of about 460,000 mt (as recorded in 2004) between captured fish production and national demand, this reflected the fact that there were only two large scale commercial producers in the country each of which had had less than ten years of operation. Anticipated growth in fish culture production within the next five years is expected to be dramatic as some of the critical challenges of the industry are resolved.

CHALLENGES AND PROSPECTS

Marine Fisheries: The fishing sector is vital for food security and job creation to help alleviate rural poverty in Ghana. However the levels of fisheries harvests are generally considered to be close to, or to have exceeded, the maximum sustained yield. Future sustainability in the industry will depend upon the restriction of open access to fisheries and the introduction of management systems which allow fish stocks to recover and the establishment of consistent yields in both marine and inland waters.

Inland Fisheries: Environmental conditions on the Volta Lake constitute the major environmental and social challenges for fisheries, its sustainability and profitability. In terms of future prospects, success will depend heavily on implementation of the ‘Ghana Fisheries and Aquaculture Sector Development Plan’ and the capacity of the system in Ghana to enforce the Fisheries Regulations passed by parliament in August 2010. Aspects of the Development plan that offers great prospects for the lakes fisheries include the provisions for eventually licensing boats (although the scale of this task should not be underestimated) and measures to involve communities in management of fisheries resources of the Lake.

Aquaculture: The main challenges facing aquaculture development in Ghana relate to: • The high cost of fish feed (significantly due to its importation from other countries) • None availability of commercial fish hatcheries as enterprises • Lack of a nation-wide distribution network for fish seed and cultured fish producers. Most sources of fingerlings are concentrated in one part of the country and, since farms all over Ghana obtain their fingerlings individually, transportation costs add significantly to overall production costs. • Now emerging certification and monitoring to check the health and safety of aquaculture processes and products. • The absence of adequate regulations regarding establishment of an aquaculture enterprise until August, 2010. (In the absence of regulations only the large and medium scale commercial farms worked towards conforming to international performance. Standards and operational regulations for certification of farms and their products still remain in a draft state) • Low national support for research to support expansion and systematic development of aquaculture.

The prospects for development of aquaculture as an industry in Ghana are good since a number of practical, policy and legal frameworks have been put in place to resolve the basic challenges to the industry listed above. These include:

• Construction of the first local fish feed plant by an international fish feed company with the expectation of having initial products on the Ghanaian market during 2011. • A ‘Large scale commercial fish farm’ with great capacity for fingerling production is shifting emphasis to fish seed production. And several localized fish seed producers are expanding operations. • Distribution strategies by cultured fish producers have started to emerge on a limited scale and are expected to evolve with increasing production as existing commercial farms expand and new ones join in.

Now that regulations regarding establishment of aquaculture enterprises have been gazetted there is likely to be a positive response amongst fish farmers of all size categories .New operational standards are being prepared which will introduce minimum standards for local certification. This should set the stage for preparation of fish culture products and the broadening of choice for consumers while also qualifying Ghanaian producers to enter external markets.

ENVIRONMENTAL CONDITIONS

The coastal and marine environment: a critical zone of influence for this study, comprises a 550 km coastline, a coastal belt ranging from 1 to 20 km in width, and coastal waters extending to 200 nautical mile limit which was established in 1977(under the territorial waters and continental shelf act, 1973 as amended by the territorial waters and continental shelf amendment decree 1977).

The Coastal Belt

The coastal belt accounts for only 6.5% of the land mass of Ghana but it is one of the most densely settled areas accounting for 25% of the population and80% of the industrial establishments in Ghana. Historically the coastal zone was cultivated for coconut (copra) but this industry is in decline. Vegetables and other agricultural produce are grown on better soils but the principal economic activities are fishing, transportation, salt production and sand and stone winning. Tourism also offers great potential. There is considerable expectation that the discovery of offshore oil and gas deposits will bring new wealth to parts of the coastal corridor. However, present plans to transfer crude products to tankers at sea and then export them directly will limit industrial activity to a support role. A high percentage of industrial and municipal wastes is dumped at landfill sites within the coastal zone which creates pollution risks.

The coastal belt is generally a low-lying area less than 200 m above sea level. Vegetation types reflect the rainfall gradient and consist of coastal shrub and Savannah to Winneba, southern marginal forest to the east of Sekondi, dry semi-deciduous and moist semi-deciduous forest to the east of Cape Three Points estuary and wet evergreen forest in the extreme south. Soils are variable within this area ranging from fertile pockets river valleys to Sandy poorer quality soils close to the sea.

The Coast The coast line divides into three sections (Ly 1980): • West of Cape Three Points; this area has a wide and flat beaches, backed by coastal lagoons and

wave heights are generally low: • Between Cape three points and Tema; the coast consists of a series of rock headlands enclosing shallow bays together with sandbars or spits enclosing coastal lagoons. The surf zone is a medium to high energy environment with wave heights often exceeding 1 m. South-westerly prevailing winds give rise to longshore drift in an easterly direction. • Between Tema and Aflao; most of the shore is sandy although there are rocky outlets

The coastal zone is important internationally in providing feeding, roosting and nesting sites for thousands of migratory birds.

Environmental degradation is significant in Ghana and is recognized in the country’s environmental action plan. It contributes to rising poverty levels coupled with poor human health and inadequately planned urbanization which fuel a vicious cycle inhibiting human development. The core issues include: • Domestic sanitation • Increased urbanization without appropriate infrastructure • Wetlands and mangrove degradation • Coastal erosion and • General biodiversity loss.

Briefly, each of the above could directly or indirectly adversely influence fisheries and aquaculture separately or together. For example, in a recently completed study of water quality scenarios of the Volta Lake in relation to fish production, as a component of a comprehensive study (The Challenge Program Project of Water & Food), it was concluded , among others that, poor sanitation in highly populated fisheries communities adversely influenced water quality to the detriment of fish life and thus fish production. With reference to aquaculture, the same unsanitary conditions in highly populated shore communities adversely influenced water quality, especially in terms of oxygen depletion when lake waters extend to the shore in high water periods. This is a situation which has caused fish kills in cages because caged fish cannot escape ‘polluted’ waters. Degradation of wetlands and mangroves leads directly to a reduction in their capacities as spawning and nursery zones for both marine and inland water fishes which reduce fish production in both environments.

The situation outlined above is often contributed to by anthropogenic and industrial pollution due to urbanization without appropriate infrastructure. Another issue linking human activity to a deteriorating environment is demonstrated by the encroachment of aquatic weeds on inland waters such as the Volta Lake. Weed growth is accelerated by , farming reservoir catchments which increases nutrient levels and the building of dams which reduce or cut off intrusion of sea water into rivers. Currently as climatic change observable impacts such as floods, seem to escape predictions. The project could possibly contribute to mitigating against direct and indirect effects of climate change on fishing and aquaculture through investment into climate change orientation and education of fishers and fish farmers to mainly influence reasonable precautions they take.

Marine waters

The continental shelf is relatively narrow projecting out to 25-35 km except in the area of Cape Coast to Salt Pond where it extends to almost 80 kms. Sandy and rocky substrates which previously supported coral and seaweeds have been severely affected by former trawling activity which indiscriminately

21 dredges material from the seabed. Coastal waters are enriched by freshwater discharges from the relatively small number of rivers and by two seasonal up-wellings which occur between late June and early October (the main upwelling) and January and March (the minor upwelling). The origin and driving mechanisms of these up-wellings are not fully understood and both their location and strength varies from year to year.

Lake Volta and other inland water

Major environmental issues on the Volta Lake which might also be considered as challenges to sustainable fisheries on the major inland fisheries resource can be summarised as follows:

• The Volta Lake is known to be low in nutrients. It therefore has low standing crops of phytoplankton and zoo plankton to support high fish production • The northern segment of the lake together with tributary rivers constitute the spawning and feeding grounds for majority of fish species in the lake during the wet season however, these segments are intensely fished during the same period. • The Volta Lake is divided into eight unequal strata with different distribution of boats per Km2. At the last estimation of carrying capacity in 2000, stratum V and II had the highest (5.27) and lowest(1.57) number of boats/Km2 respectively. • The rate of siltation in the lake is considered to be increasing due to erosion associated with high rates of deforestation. • A major challenge exists in getting fishers, fishing communities and fishing entrepreneurs to understand and comply with fishing regulations aimed at conserving fish and fisheries resources. • There is a lack of resources, studies and research to support fisheries management of the Lake. • High illiteracy exists amongst lake shore communities. • Open access to the fish resources of the Lake has been in operation since its formation. • Declining fish yields are occurring in the lake (46.8 Kg/ha in 1976 to 32.0 Kg/ha in 2003-MOFA) brought about by the constraints listed above. • The commonly assumed estimate of potential fish production from the lake of around 75,500 mt/yr) is considered to be a serious underestimate since Stratum VII alone was estimated to produce 33,800mt/yr in 1996. • The policy environment for aquaculture is currently strongly supportive of the industry and related enterprises. • There is good quality and more than sufficient water to allow some kind of aquaculture to be developed in every region of the country with the Volta lake (about 8,400 Km2) as the single most important water unit for fish culture. Currently it appears that the free access to the fish resources of the lake has to some extent been applied to establishment of small scale caged fish culture enterprises, a situation constituting environmental risk to investments of large scale commercial fish culture establishments in the lake. • The Volta Lake is low in nutrients (Obeng 1964) resulting in a situation where higher fish yields could be sustained if greater quantities of fish feed were available.

• In Ghana the Nile tilapia, O. niloticus, occurred naturally only in the Volta system. Due to positive culture characteristics of the fish it has been moved into virtually all other river basins in the country. The situation provides opportunities for hybridization of the Nile tilapia with other tilapia species native to the river basin into which the Nile tilapia has been moved.

CHAPTER 4 POLICY AND LEGAL FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES

4.1 INTRODUCTION

Development and implementation of the Ghana Fisheries and Aquaculture Sector Development Plan and the World Bank’s supporting program need to be developed with full regard to existing international conventions, national legislation, policies and regulations. This chapter highlights the main legislative and policy considerations for the protection of the environment, natural resources, fisheries and social and economic development. It begins with reference to the World Bank’s safeguard framework and those of other donors. This is followed by a section on the governance framework in Ghana.

4.2 WORLD BANK AND OTHER DONORS’ SAFEGUARDS POLICIES

The World Bank’s safeguard policies exist to ensure that all projects which it finances are developed and implemented on environmentally and socially sound principles. A range of different policies exist and these have been carefully considered to ensure that the Ghana Fisheries and Aquaculture Development Sector Development Plan complies with these safeguards. All policies have been screened and those that have no bearing on the fisheries programme have been excluded from Table 4.1 below. Table 4.1 lists policies which could have some applicability to the FASDP even if this interaction might be very slight. It is important to stress that the comments in the third column of Table 4.1 relate to the entirety of the Fisheries and Aquaculture Sector Development Plan whose effects will continue to be experienced long after the World Bank’s financial support has been expended. Most of the activities in the FASDP will have no effect in relation to safeguard objectives, and where there are implications these are likely to occur at precise locations (for example at fish landing sites) rather than throughout the industry. Where potential interactions have been noted the necessary mitigating measures are incorporated in the Draft Process Framework.

Table 4.1 World Bank Safeguard Policies in Context

Safeguard Safeguard Policy Objective Brief Description and relevance to FASDP Policy

OP 4.01 This policy aims to ensure that Bank- The majority of actions planned under Environmental financed projects are environmentally FASDP will be beneficial to the marine Assessment sound and sustainable, and that the environment and to inland waters.

decision-making process is improved However, new construction activities through appropriate analysis of actions could have impacts and depending on the and mitigation of their likely project and the nature of impacts, a environmental impacts. This policy is range of instruments can be used to triggered if a project is likely to carry ameliorate and mitigate adverse effects potentially adverse environmental risks while enhancing beneficial effects. These and impacts on its area of influence. OP include EIA, environmental audit, risk 4.01 covers impacts on the natural assessment, and environmental environment (air, water, and land), management plans (EMP). The need for

EIA and EMP is considered in this report

OP 4.04 This policy recognizes that This policy is triggered by any Natural conservation of natural habitats is project (including any sub-project Habitats essential to safeguard their unique under a sector investment or

biodiversity and to maintain financial intermediary) with the environmental services and goods potential to cause significant for human society and for long-term conversion (loss) or degradation of sustainable development. The Bank natural habitats, whether directly therefore supports the protection, (through construction) or indirectly management, and restoration of (through human activities induced natural habitats in its project by the project). financing as well as policy dialogue and economic and sectoral work. This policy is applicable to the Natural habitats comprise many Ghana Fisheries Programme types of terrestrial, freshwater, because the project focuses on the coastal, and marine ecosystems. integrated management of natural They include areas lightly modified habitats. However, by screening all by human activities but retaining proposals under the ESMF any sub- their ecological functions and most projects that might impact these native species. habitats will not be funded,

OP 4.09 The objective of this project is to: (i) The policy is triggered if: (i) procurement Pest promote the use of biological or of pesticides or pesticide application Management environmental control and reduce equipment is envisaged either directly reliance on synthetic chemical pesticides; through the project or indirectly through and (ii) strengthen the capacity of the on-lending, co-financing, or government country’s regulatory framework and counterpart funding; (ii) the project institutions to promote and support safe, supports an activity requiring the use of effective, and environmentally sound pesticides that may have negative effects pest management. on the environment. The only instance in which this policy might be triggered by the Ghana Fisheries Programme is if aquatic herbicides or antibiotics were to be used in connection with aquaculture. This is most unlikely but can be monitored through the implementation programme

OP 4.11 The policy objective is to assist countries in Under the Ghana Fisheries Programme, Physical avoiding or mitigating adverse impacts of construction and rehabilitation activities Cultural development projects on physical cultural that could have negative impacts on Resources resources. For the purposes of this policy, cultural property will be avoided. In the “physical cultural resources” are defined as case of discovery of remains, national movable or immovable objects, sites, procedures will be applied. structures, groups of structures, natural features, and landscapes that have

archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance.

OP 4.12 Involuntary The objective of this policy is to: (i) avoid or The policy covers not only physical Resettlement minimize involuntary resettlement where relocation but any loss of land or other feasible, while exploring all viable assets resulting in: (i) relocation or loss of alternative project designs; (ii) to assist shelter; (ii) loss of assets or access to displaced persons in raising their former assets; (iii) loss of income sources or living standards, income-earning capacity, means of livelihood, whether or not the and production levels, or at least in affected people must move to another restoring them; (iii) encourage community location. participation in planning and implementing The activities of the Ghana Fisheries resettlement; and (iv) provide assistance to Programme are likely to result in loss of affected people regardless of the legality of assets or access to assets, and loss of land tenure. income sources or means of livelihood for some groups and individuals. The potential for such losses will be carefully scrutinised and compensated for through the National Process Framework and Resettlement Policy Framework described in this report, and appropriate procedures will be followed where necessary.

Other donors and aid agencies, including International and National NGOs play an active role within the fisheries sector in Ghana and their safeguards standards will be observed through operation of the Environmental and Social Safeguards Management Plan.

4.3 THE GOVERNANCE FRAMEWORK IN GHANA

The Ministry of Food and Agriculture (MOFA): Preparation of Fisheries laws and policies fall under the responsibilities of the Minister of Food and Agriculture who in turn delegates functions, including implementation to a semi-autonomous body; the Fisheries Commission.

The Fisheries Commission (FC) was established under the Fisheries Commission Act (625, 2002). It oversees management, regulation and utilisation of the fisheries resources of Ghana drawing on powers set out in the Fisheries Law (PNDC 256, 1991). Fisheries Act 625 provided for the establishment of a more robust Fisheries Commission (FC) which is an amalgamation of the erstwhile FC and Department of Fisheries.

Ten individuals constitute the Board which is led by a chairman (appointed by the President of Ghana in consultation with the Council of State) supported by three members drawn from the ministries of transport, defence and environment. There are three representatives from the following parastatal organizations - the Ghana Marine Fishing Officers Association, Water Research Institute and Ghana Irrigation Development Authority- and two representatives (one from the artisanal and one from the industrial sections )of the National Fisheries Association of Ghana. Finally, the tenth member is a person with requisite knowledge of the fishing industry or natural resources renewal management

The day to day work of the Fisheries Commission is undertaken by the Department of Fisheries (DOF) which serves as the implementation secretariat of the Fisheries Commission, as stipulated by the Fisheries Act 625 of 2002. Specific tasks that are undertaken by the Department of Fisheries include:

• preparing fishery resource management plans; • developing regulations for the fishing industry; • organizing monitoring, surveillance and enforcement for the national fishery resources and ensuring compliance with national fisheries law; and institutionalizing co-management concepts

The MCS Division of the DoF (established under the Fisheries Sub sector Capacity Building project), works in conjunction with the Ghana Navy and undertakes sea patrols to exclude industrial fishing vessels from the 30-metre depth IEZ, reserved for artisanal fisheries. The MCS also conducts inspection of industrial vessels at the fishing ports of Tema and Takoradi for: • valid fishing licences, • legality of fishing gear • skipper’s certificate, • log book and crew composition

The MCS undertakes similar functions for inland fisheries on Lake Volta

The Ministry of Local Government and Rural Development (MLGRD) is responsible for managing fishers, fish processors and fishery resources at district and sub-district levels which it undertakes through the District Assemblies. In 2002, the District Assemblies in collaboration with DoF, were mandated to facilitate fishery resource management by:

• helping to form and sustain Community Based Fisheries Management Committees (CBFMCs); • cooperating with the DoF MCS units; • providing legal and financial support to the CBFMCs; and, • approving levies proposed by the CBFMCs

Community-Based Fisheries Management Committees: are charged with the responsibility of enforcing national fisheries laws at community level, as well as initiating and enforcing their own by-laws.

4.4 THE LEGAL FRAMEWORK

4.4.1 International Conventions

Ghana has ratified a number of international conventions and treaties which have an important bearing on the state of its marine and inland waters and the condition of the fisheries. These are listed in Box 1 below.

Box 1 International Conventions, treaties and agreements to which Ghana is a signatory. 1. International Convention for the Prevention of Pollution of the sea by Oil: 21 October 1962 2. Convention on the Africa Migratory Locust: 25 May 1962 3. Treaty Banning Nuclear Weapon Tests in the Atmosphere, in Outer Space and Under Water: 5th August 1963 4. International Convention for the Conservation of Atlantic Tunas: 4 May 1966 5. Africa Convention on the Conservation of Nature and Natural Resources: 15 September 1968 6. International Convention on Civil Liability for Oil Pollution Damage: 29 November 1969 7. International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Causalities 8. Convention on Wetlands of International Importance, Especially as Waterfowl Habitats: 2 February 1971 9. Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof: 11 January 1971 10. International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage: 18th December, 1971 11. Convention Concerning the Protection of World Cultural and Natural Heritage: 16 November 1972 12. Convention on International Trade on Endangered Species of Wild Fauna and For a: 3 March 1973 13. Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques: 10 December 1976 14. Convention on the Conservation of Migratory Species of Wild Animals: 23 June 1979 15. Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region,1981(Abidjan Convention) 16. United Nation Convention on the Law of the Sea: 10 December 1982 17. Montreal Protocol on Substances that Deplete the Ozone Layer: 24 July 1989 18. Convention to Combat Drought and Desertification 19. Framework Convention on Climate Change: June 1992 20. Convention on Biological Diversity,1992

4.4.2 Environmental-Related Conventions Environmentally related conventions ratified by Ghana include: • International Convention for the Prevention of Pollution of the sea by Oil: 21 October 1962 • Convention on the Africa Migratory Locust: 25 May 1962 Treaty Banning Nuclear Weapon Tests in the Atmosphere, in Outer Space and Under Water: 5th August 1963 • International Convention for the Conservation of Atlantic Tunas: 4 May 1966 • Africa Convention on the Conservation of Nature and Natural Resources: 15 September 1968 • ␀International Convention on Civil Liability for Oil Pollution Damage: 29 November 1969 • International Convention Relating to Intervention on the High Seas in Cases of Oil

Pollution Causalities • Convention on Wetlands of International Importance, Especially as Waterfowl Habitats: 2 February 1971 • Treaty and Prohibition of the Emplacement of Nuclear Weapons of Mass Destruction on the Seabed and the Ocean Floor and in the Subsoil Thereof: 11 January 1971 • International Convention on the Establishment of an International Fund for Compensation of Oil Pollution Damage: 18th December, 1971 • Convention Concerning the Protection of World Cultural and Natural Heritage: 16 November 1972 • Convention on International Trade on Endangered Species of Wild Fauna and For a: 3 March 1973 • Convention on the Military or Any other Hostile Use of the Environmental Modification Techniques: 10 December 1976 • Convention on the Conservation of Migratory Species of Wild Animals: 23 June 1979 • Convention for the Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region,1981(Abidjan Convention) • United Nation Convention on the Law of the Sea: 10 December 1982 • Montreal Protocol on Substances that Deplete the Ozone Layer: 24 July 1989 • Convention to Combat Drought and Desertification • Framework Convention on Climate Change: June 1992 • Convention on Biological Diversity,1992

4.4.3 National Legislation The principal national legislation that affects fisheries in Ghana is listed below: 1. Fisheries Regulation 1984 LI 1294; 2. Fisheries (Amendment) Regulation 1977 3. Maritime Zones (Delimitation) Law, 1986; 4. PNDC Law 256 of 1991; 5. Fisheries Commission Act of 1993; and 6. Fisheries Act 625 of 2002. 7. Fisheries Regulations passed in 2010, LI 1968

Other laws that have relevance to the fisheries sector include:

1. Wild Animals Preservation Act, 1961 (Act 43); 2. Volta River Development Act, 1961 (Act 46); 3. Ghana Water and Sewerage Corporation Act, 1965 (Act 310); 4. Oil in Navigable Waters Act, 1964 (Act 235); 5. Irrigation Development Authority Decree, 1977 (SMCD 85); 6. Minerals and Mining Law 1986 (PNDCL 153); 7. Environmental Protection Agency Act, 1994 (Act 490); 8. Ghana Highway Authority Act, 1997 (Act 540); 9. Timber Resources Management Act, 1998 (Act 547); and 10. Minerals and Mining Act, 2006 (Act 703

4.3.4 Policies

A number of Environmental related Policies exist in Ghana however there is no specific policy on the coastal zone. These include: • The National Environment Policy • National Wetlands Policy • Agricultural Policy • Tourism Development Policy • Land Management Policy • National Health Policy • Energy Policy • Minerals Policy • Wildlife Conservation Policy

The main thrust and orientation of national policies on the protection, management and development of the marine and coastal environment focuses on the following three major areas: • Integrated coastal zone management and sustainable development • Marine environmental protection, both from land-based activities and from sea-based activities; and • Sustainable use and conservation of marine living resources (both of the high seas and under national jurisdiction).

Specific plans have been developed to ensure the realization of prudent management of the marine and coastal environment. These include: • Coastal Zone Management Indicative Plan, 1990 • National Environmental Action Plan, 1994 • Draft Integrated Coastal Zone Plan, 1998 • Coastal Zone Profile of Ghana 1998 • National Oil Spill Contingency Plan with specific reference to the marine environment, 2002 • Environmental sensitivity map of the coastal areas of Ghana, 1999 and 2004.

Despite the existence of these plans active integration and coordination has been lacking in practice at local level.

4.3.4 Regulations Though several legislations exist on coastal protection and sustainable development, there is no omnibus legislation on the environment. Legislation relating to the area include the following: • Beaches Obstruction Ordinance, 1897 (Cap 240) • The Mineral and Mining Law, 1986 (PNDC 153) • Rivers Ordinance, 1903 (Cap 226) • Land Planning and Soil Conservation Ordinance No 32 of 1953 as Amended by the • Land Planning and Soil Conservation (Amendment) Act, 1957 (No. 35 of 1957) • Maritime Zones (Delimitation) Law 1986 (PNDCL 159) urban planning and

• development • Town and Country Planning Ordinance (Cap 84) • Wild Animals Preservation Act, Act 235 1964 • The Towns Ordinance (Cap 86) • National Building Regulations 1996 (LI 1630) • Volta River Development Act, 1961 • Fisheries Act 2002, Act 625 • Fisheries Law, 1991 (PNDC 256) • Fisheries (Amended) Regulations, 1977 and 1984 The sustainable use and conservation of marine resources is encouraged through legislation, regulations, education and awareness creation programmes as well as the enforcement of existing regulations and legislation The legal framework for coastal zones issues and management in the country are contained in the following documents • The 1992 constitution • EPA Act, 1994 (Act 490) • Environmental Assessment Regulations, 1999 (LI 1652) • Local Government Act, 1993 (Act 462) • Environmental Standards and Guidelines. • In addition, there are other specific legal frameworks, which include: a) The legal framework for Ecosystem Protection, which are: • Wild Animals Preservation Act 1961 (Act 43) • Wildlife Conservation Regulations 1971 (LI685) • Wild Reserves Regulations 1971 (LI 740) • The Wetland Management (Ramsar sites) Regulation, 1999 • Oil in Navigable Waters Act, 1964 (Act 235) b) The legal framework for Fisheries Resources, which are: • Fisheries Law 1971 (PNDCL 256) • Fisheries Act 2000 c) The legal framework for Oil and Gas Industry • Petroleum (Exploration and production) Law 1984 (PNDCL 84) • Mineral (Offshore) Regulations 1963 (LI 257) • Mineral (Oil and Gas) Regulations 1963 (LI 256) • Oil and Mining Regulations, 1957 (LI 221) d) The legal framework for Tourism Promotion (including coastal tourism) • Ghana investment Promotion Centre Act 1994 (Act 478) • Companies Code 1963 (Act 179) • Free Zone Act 1995 (Act 504) • Ghana Tourism Board • Ghana Commission on Culture

4.4 ACTIVITIES RELATING TO FISHERIES INTERESTS

Over the years, several activities have been undertaken which are of relevance to protection of the marine environment and fisheries. These include: • Ghana Environmental Resource Management Project in Coastal Wetlands Management Component • Gulf of Guinea Large Marine Ecosystem Project • Fisheries Sub-sector Capacity Building Project • Establishment of a Protected Wetland Ecosystem on the coast • Development and Implementation of Oil Spill Contingency Plan • Monitoring of fish stock levels and associated oceanographic parameters • Institution of a programme of Monitoring, Compliance and Surveillance of the marine environment • Development of industrial pollution standards • Development of University course on Coastal Zone Management • Increased public education on sound coastal and marine environmental practices

4.5 RELEVANT INSTITUTIONS With regards to protection, management and development of the marine and coastal environment, a number of ministries and agencies have been identified as potential stakeholders. Those shown with an asterisk are likely to have a particularly active role: • Ministry of Environment and Science* • The Environmental Protection Agency* • Ministry of Tourism* • Ministry of Local Government and Rural Development* • Ministry of Ports*. • District Assemblies * • Ghana Ports and Harbours Authority* • Hydrological Services Department • Ministry of Food and Agriculture • Ghana Tourist Board • Ghana Investment Promotion Centre • Fisheries Commission Ministry of trade, Industries and PSI* • Ministry of Lands, and Natural Resources Forestry and Mines • Ministry of Energy • Ministry of Health • Ministry of Education, Youth and Sports • Ministry of Defence • Ghana Navy* • Ministry of Works and Housing • Ministry of Women and Children’s Affairs* • Ministry of Roads and Transport • National Development Planning Commission • Council for Scientific and Industrial Research • Universities and Research Institutions • Ghana Meteorological Agency • Town and Country Planning Department • Water Resources Commission

• Ghana National Petroleum Corporation* • Volta River Authority* • Geological Survey Department • Forestry Commission (Forestry and Wildlife Division) • Traditional Rulers and their analogous ministry and laws

Non-Governmental Organisations including Resource Development & Environmental Oriented Development Organisation • Friends of the Earth • Green Earth • Wildlife Society • Recerca e Cooperazione • Centre for African Wetlands • And many others

4.6 PARTNERSHIPS Few formal partnerships exist. However, support for coastal conservation activities has been received from the private sector as well as from Government. Regional and sub-regional collaboration efforts occur at various levels although the level of practical intervention is sometimes limited. The science and technology unit of ECOWAS is engaged on issues relating to the management of the Gulf of Guinea. In addition, a bilateral arrangement exists between Ghana and Cote d’Ivoire for the management of and datasharing on Sardinella stocks which migrate between the two countries. The NEPAD framework among the coastal states of Africa is also developing an interest in marine and coastal management.

4.6.1 Technical and financial support Ghana receives technical support in the form of training, research and project implementation from national, bilateral and multi-lateral sources. Financing of activities in the sector is primarily supported from the national budget. However, donor support from both bilateral and multilateral sources has also been obtained for specific programmes, such as the World Bank sponsored Fisheries Sub-sector Capacity Building Project; UNOPS sponsored Environmental Sensitivity Map for Coastal Areas, The Ghana Coastal Wetland Project of the World Bank, UNEP’s WACAF Programmes, and The Darwin Marine Biodiversity of West Africa Project by DFID implemented by the University of Ghana.

4.7 ACTIVITIES Activities undertaken in the country with importance to the marine and coastal area are outlined in the following sections. 4.7.1 Environment-related activities • Ecological Baseline studies of Korle Lagoon (1990-2000). This was carried out to satisfy EIA requirement and as a result pollution status of the lagoon was established. • Lower Volta Mangrove Project (1996-1998). The objective is to ensure sustainable management of mangrove stands and as such baseline information was documented. • Save the Seashore Birds Project (1985-1995). This was to protect the seashore birds and as a result conservation awareness of seashore birds was achieved. • Ghana coastal wetlands management project (1996-1999). In this, management of the five coastal wetlands designated as Ramsar Site was put in place • Darwin Marine Biodiversity of West Africa Project. It is a training project in marine biodiversity assessment.

4.7.2 Social-related activities • A considerable amount of attention is currently being given to the potential impact of oil-related development in coastal regions following the publication of Environmental and Social Impact Assessments and Management Plans relating to the Jubilee Oil Field discoveries.

4.7.3 Coastal area management • Climate and vulnerability and adaptation assessment on water resources, agriculture and the coastal zone Projects. (1997-1999). The projects assessed the vulnerability of the coastal zone to climate change. • Coastal area management plan for Princess Town (1998-2000), which aimed at providing a plan for the management of Princess Town. • Keta Sea Defence Project Work (2000-2004). The project aimed at protecting the Keta and its environs from the episodes of erosion faced in the area and also to ensure improvement in environmental and socio-economic conditions at Keta and its immediate surroundings.

4.7.4 Regional Programmes • Gulf of Guinea Large Marine Ecosystems Project (1996-1999). The project developed an effective approach to prevent and control pollution in the Gulf of Guinea and conserve its biodiversity. As a result, regional institutional capacities were strengthened and also a coastal zone management profile and plans produced. • UNEP WACAF Projects 1 & 2. This aims at institutionalising and coordination of national contingency plans, monitoring of pollution in the marine environment and control of coastal erosion. 4.7.5 Other major programmes Other recent programmes and activities in the marine and coastal environments have included: • Ghana Environmental Resources Management Project in Coastal Wetlands • Fisheries sub-sector Capacity Building Project • Establishment of a Protected Wetland Ecosystem on the coast • Development and Implementation of Oil Spill Contingency Plan • 4.8 ONGOING PROJECTS Ghana is currently implementing several projects in the marine and coastal area. Some of these projects are linked to developmental projects for which impact assessments are required under the Environmental Assessment Regulations of 1999. Some of the projects are large scale in nature with extensive baseline and monitoring studies like the Keta Sea Defence Project and the West Africa Gas Pipeline project. Others are projects being implemented under the auspices of the United Nations agencies and non-governmental organisations include: • Combating Living Resource Depletion and Coastal Area Degradation in the Guinea Current LME through Ecosystem-based Regional Actions. • Amansuri Conservation and Integrated Development Project (ACID) • Danida Water and Sanitation Sector Programme II: Support to Integrated Water Resources Management (IWRM) Component (2004-2008):The Densu Basin aspect of the IWRM component. • Reduction of Environmental Impact from coastal tourism. • Bui Hydro Power Project. • Sea Defence Project at Atorkor. • Sea Defence Projects in selected towns in the Western Region of Ghana. 35

4.9 CONCLUDING REMARKS

This chapter has highlighted the wide range of conventions, laws, policies, regulations and activities affecting the inland and coastal regions and inland freshwater and marine environment of Ghana. It will be important to keep all of these processes and procedures under review as the Fisheries and Aquaculture Sector Development Plan is taken forward to the implementation stage. The main responsibility for ensuring delivery of the Fisheries and Aquaculture Sector Development Programme will rest with the Fisheries Department of the Ministry of Food and Agriculture and the Fisheries Commission, supported by the MCS Division and Ghana Navy. However, a key part of the programme is the development of local co-management arrangements, and the Ministry of Local Government and Rural Development and individual District Assemblies will play a key role in helping to form and sustain Community Based Fisheries Management Committees. Over time, a significant number of fishermen and individual fish processors are likely to leave the sector as harvesting, landing and processing of the catch becomes more efficient. Management of these changes, especially where disadvantaged and vulnerable sections of the community are affected, will need substantial support and investment and a high degree of coordination amongst government ministries and agencies, NGOs and international partners to ensure that development assistance is effectively targeted.

CHAPTER 5 WORLD BANK SAFEGUARD ISSUES

5.1 INTRODUCTION

The World Bank’s proposed funding support to the Government of Ghana covers an initial five years’ period which could potentially be extended at a later date. As the Government of the Republic of Ghana notes in the draft FASDP “improving the management of the country’s fisheries and ensuring that the impacts on individuals and communities are properly addressed ...will take 20 or more years to effect”. It has therefore been judged important in this report to distinguish between changes that might occur as a direct result of the World Bank’s financial assistance, thereby triggering the Bank’s environmental and social safeguards, and changes that could result from longer term adjustments to fisheries and other sectors of Ghana’s economy as a result of wider influences by Government, other donors and world- wide factors (for example, international progress in world trade agreements).

The aim in this chapter is to identify changes which are likely to fall within the purview of the World Banks reputational risks and responsibilities under the first five years of the Fisheries and Aquaculture Sector Development Plan (FASDP). It should be clearly understood that the views expressed are those of the consultancy team and it will be for the World Bank’s internal advisors to decide what formal recommendations are made to the World Bank Board.

Trends that may emerge in later stages of the implementation of FASDP – subsequent to the initial five year period - are discussed in chapter 6.

5.2 THE CURRENT SITUATION

The general status of Ghana’s fisheries has been described in Chapters 3, while the legal and policy context has been set out in Chapter 4. The World Bank’s investment is being planned specifically to support government policy with the aim of providing a more efficient and better regulated fisheries sector. Currently, open access is leading to progressive deterioration in fish stocks and lower economic returns. Based on many international examples of successful intervention, the current proposals (see Chapter 2) are to provide support to introduce formal licensing of all vessels and proper monitoring and control over the seasonal timing and location of fishing activity, use of gear and approved nets and self regulation through co-management structures under which the Government and fishing communities will work together to achieve recovery of fish stocks, higher income levels for fishers and better returns on catches by reducing post harvest losses and improving processing and marketing operations.

5.3 ANTICIPATED OUTCOMES

It is expected that the proposed reforms and changes will eventually lead to significant improvement in the marine environment, restoration of fisheries and enhanced incomes. In this respect the provision of grants and loans from the World Bank will bring about major benefits to the economy, livelihoods and the environment in the longer term. The question that has to be addressed, however, is - are there likely to be any short term adverse environmental or social consequences from the Bank’s own investment strategy? Answers are considered in relation to each of the planned components, subcomponents and activities which are summarised in Table 5.1. A colour coding and numbering system has been adopted to distinguish those activities that are seen as particularly relevant from the standpoint of the environmental and social assessment. Elements highlighted in green are those likely to have positive and beneficial effects on the environment and social conditions; those highlighted in orange / red have potentially negative or adverse consequences if not handled properly.

Component 1 Good Governance and Sustainable Management of the Fisheries

Sub-Component 1.1 seeks to develop the capacity, rules, procedures and practices that will lead to better governance. As such these procedural interventions will have no direct effect on the environment or social conditions of fishing communities. However, it will be important to ensure that the drafting agencies (government departments and consultants) give due attention to environmental and social objectives during this phase of work. Three specific areas are highlighted including undertaking a socio-economic impact assessment with mitigation measures as part of the plan for fishing capacity reduction; reviewing the economic and social implications of subsidies and fish import tariffs in the fisheries sector and developing the policy for the development and operation of community-based management networks built around defined fisheries management units.

In developing regulations and guidelines it will be important to consider how less able individuals and vulnerable sectors are going to adapt to new systems. For example the new regulations on licensing canoes, including completion of registration forms, the display of registration numbers on vessels and demonstration of basic competence in health and safety standards may prove taxing demands for owners and crew lacking any formal education. Similarly legal instruments that are used to remove fuel subsidies or other benefits will need to be carefully explained. A socio-economic impact assessment is proposed in the draft PAD to be accompanied by appropriate mitigation measures. This assessment should consider, amongst other things; • whether support should be offered, and if so under what conditions, to any company, community or individual who fails to secure a license for a particular class of vessel, • how the transfer or sale of licenses will be regulated in the wider public interest to ensure transparent processes and avoid the creation of monopolistic and oligopolistic elites, • who wins and who loses from any planned changes to subsidies and fish import tariff adjustments, • how the performance of community-based management networks will be judged , • what action will be taken to mitigate the loss of any traditional fishing grounds that become the subject of marine protected area development, or are subject to exclusion zones to protect oil drilling and production platforms.

Sub-Component 1.2 introduces the concept of fishing rights. This is to be initiated through a series of four pilot stakeholder-based fishery initiatives, and the rolling out of licensing procedures. Discussions with stakeholders have made it very clear that the credibility of the entire fisheries policy and programme could be challenged if these pilots do not show positive and constructive ways of moving forward with fisheries reform. There is a great deal of distrust for new procedures amongst the fishing communities based on the knowledge that many previous initiatives have failed. It is therefore essential that the pilots are led by a strong implementation team, are adequately financed and include a credible, transparent and inclusive process for debate, discussion and consultation. Co-operation from the selected communities will be more likely to be achieved if they can see early results in terms of income generating activities.

Sub-Component 1.3 is targeted at adjusting fishing effort and capacity to more sustainable levels, and supporting alternative livelihood opportunities. These activities are critical in giving effect to the policy decisions that have already been taken to reduce the size of the industrial and semi-industrial fishing fleet and to strengthen the role of the canoe sector. Specific measures are proposed for compensating crew members who lose their jobs and for providing training to young men who are willing to transfer

38 out of the fishing sector. The scale of this task should not be under-estimated, however, since there are currently few alternative employment opportunities in the coastal belt for manual workers with low education and skill levels which typify the status of many young fishermen. The concept of creating some additional employment with conservation of the coastal, littoral and marine ecosystems is strongly supported since this can be linked with development of tourism.

Sub-Component 1.4 is another element that is strongly focused on delivering improved livelihoods with its emphasis on social marketing, communication and transparency. The focus on stakeholder participation is particularly welcome and should lead to positive response providing it is backed with direct financial support to participating communities.

Component 2 - Reduction of Illegal Fishing

There is no Sub-Component 2.1 within the Ghana Fisheries Programme.

Sub-Component 2.2 aims to develop monitoring, control and surveillance (MCS) systems. These measures are largely procedural and, apart from the relatively small team that will be recruited to operationalise the systems it will have minimal effects on either the environment or social conditions. One element that is highlighted in Table 5.1 relates to provision of facilities and training for participatory coastal surveillance of small-scale fisheries. This should have direct and strongly positive benefits for participants and the communities who are enrolled in the training programmes.

Component 3. increasing the contribution of the marine fish resources to the local economies

Sub-Component 3.1 will support the development of basic infrastructure at nine marine fish landing sites and two inland sites. The scale of physical construction will be restricted to repair and minor extension of roads and jetties / wharves and construction of net mending screens and storage sheds. These activities are unlikely to have any significant adverse environmental impacts and should lead to positive social effects.

Sub-Component 3.2 will underpin efforts to improve fish product trade infrastructure, information and systems. Introduction of new technology for smoking and curing fish and the extension of existing ice preparation plants will start to have positive beneficial effects within the selected communities.

Sub-Component 3.3 provides a modest level of support to marine and inland aquaculture development. Aquaculture development should include finalization, establishment and enforcement of current draft operational standards to cater for environmental friendliness of fish culture industry for its own survival. The main focus will be on developing policy and legal frameworks, together with support for stock improvement. These measures will have some impact on affected communities in the short term but are clearly aimed at longer term benefits.

Component 4. Coordination, Monitoring and Evaluation and Program Management

Sub-Components 4.1 and 4.2 are directed specifically at strengthening the capacity of the Government’s institutions for national implementation and regional co-ordination. As such they will have no direct environmental or social impacts.

5.4 SUMMARY AND CONCLUSIONS

This review of potential environmental and social safeguard issues under the World Bank’s targeted programme concludes that there are unlikely to be any significant adverse environmental or social effects as a result of the planned investments.

The only possible exception relates to the effectiveness of measures that are put in place under Sub- Component 1.2 to support pilot stakeholder-based fishery initiatives. It is of paramount importance that these pilots are successful and win the confidence of all participants since failure to achieve positive results could set back the entire fisheries programme. For this reason it is essential that planning of the pilot initiatives is linked closely with measures for supporting alternative livelihoods and strengthening processing and marketing initiatives under Sub-Components 1.3 and 1.4

A number of the planned interventions may have longer term consequences as policies, regulations and bye-laws are put into effect but these will be addressed in subsequent work by the Government of Ghana (see Chapter 6).

Table 5.1 Elements of the World Bank Programme and assessment of potential environmental and social risks

Description of Component, Sub-Component and Measure of Likely Effects Activities Beneficial Adverse Large (3) 3 3 Moderate (2) 2 2 Small (1) 1 1 None   Component 1. Good Governance & Sustainable Management of the Fisheries

Sub-Component 1.1 Developing the Capacity, Rules, Procedures & Practices for Good Governance of the Fisheries

Reviewing developing programmes and projects designed to support the Fisheries and   Aquaculture Development Sector Plan (FASDEP)

Developing an operational Plan for fishing capacity reduction (including socio- policy to enable economic impact assessment and mitigation) 3 2 implementation of the Aquaculture and Fisheries Commercial vessel and fishing activity licensing plan   including allocation criteria, rules for transfer of licenses,

Sector Development Plan and timetable and schedule of license fees

Compliance strategy and plan  

Regulations for the management of fisheries including the identification and specification of fisheries management   units (i.e., stocks, species, areas)

Recommendations for environmental and social safeguards arising from the review of the economic and social 3  implications of subsidies and fish import tariffs in the fisheries sector

Policy for the development and operation of community- based management networks built around defined fisheries 3  management units

Policy on adaptation strategies for climate change and 2 2 marine protected area development

Review of the Ghana Tuna Industry to identify policy or   infrastructure needs that threaten Ghana’s hub status.

Strengthening capture Development of fisheries and aquaculture management fisheries management systems and processes and training.   systems and capability

Strengthening fisheries Installation and operation of fisheries ‘dashboard’ database   information systems and information collection

Sub-Component 1.2 Introducing Fishing Rights ($1.5 M GEF)

Developing 4 pilot Stakeholder-Based Fisheries Management initiatives around defined fisheries units (i.e. local management initiatives tied to defined fisheries resources, 3 2 including demand-side governance initiatives)

Introducing and administering a licensing regime (registry establishment, training, stakeholder education) 2 2

Sub-Component 1.3 Adjusting Fishing Effort and Capacity to more Sustainable Levels, and Supporting Alternative Livelihood Opportunities where Needed

Vessel decommissioning Decommissioning of 60 to 80 industrial trawlers in an  2 environmentally friendly manner 

Developing alternative Skills training and small business development training and livelihoods for crew of support for young (18-30 yrs) industrial/semi-industrial 3  decommissioned crew members willing to transition out of the sector industrial/semi-industrial

41 vessels

Alternative livelihood Alternative livelihoods fund and CDD support to targeted development to fishing communities incentivize voluntary 3 2 capacity reduction in canoe sector

Marine Resource Would include confirming conservation priorities and Conservation management regimes, and possible provision of support for alternative livelihood options (funded under 1.3.3) associated with conservation of coastal, littoral and marine 3  ecosystems, as well as de facto protected areas associated with the development of oil and gas extraction.

Sub-Component 1.4 Social Marketing, Communication and Transparency)

Communications, stakeholder consultations and awareness raising programs to support 3  fisheries development

Component 2. Reduction of Illegal Fishing

Sub-Component 2.1 does not apply to Ghana

Sub-Component 2.2 Monitoring, Control and Surveillance (MCS) Systems

Developing compliance Development of judicial and policy capacity (training)   systems and capability Compliance risk assessment/strategy, systems and process   development Enforcement Unit establishment (dedicated facility)  

Coastal surveillance stations  2

Facilities and training for participatory coastal surveillance of 3  small-scale fisheries

Training for surveillance officers  

Operation of aerial and water patrols (vessel leases, aerial patrols, operational costs, patrol vehicles)  

Observer program  

Compliance education (stakeholder training, signage) 1 

Upgrade/maintenance of the Vessel Monitoring System (VMS)  

Component 3. Increasing the Contribution of the Marine Fish Resources to the Local Economies

Sub-Component 3.1 Fish Landing Site Clusters

Product 9 marine landing sites (basic infrastructure) diversification/value chain at Axim, Dixcove, Fete, Jamestown, Moree, Mumford, Senya- 3 1 development Beraku, Teshi, and Winneba

2 inland fish landing sites (improved access and berthing 3 infrastructure) at Abotoase and Dzemeni 1

2 ports developed (technical studies for 1 new port at Axim 3 and additional berthing space in existing port of Elmina) 2

Sub-Component 3.2 Fish Product Trade Infrastructure, Information and Systems

Export certification center development  

Fish processing technology improvements 1 1

Technical assistance, training and goods to support the National Fisheries Advisory Group  

Sub-Component 3.3 Marine and Inland Aquaculture Development

Developing aquaculture policy and legal framework  

Improving genetic quality of Tilapia fingerlings and breedstock  

Catalyzing aquaculture development  2

Component 4. Coordination, Monitoring and Evaluation and Program Management

Sub-Component 4.1 National Implementation

Technical assistance for Secretariat to the Fisheries Commission to implement the Project  

Sub-Component 4.2 Regional Coordination

Technical assistance for Regional Coordination Unit at the CSRP, support to Fisheries   Information Systems (‘Dashboard’)

CHAPTER 6 ENVIRONMENTAL AND SOCIAL ASSESSMENT OF DRAFT FISHERIES AND AQUACULTURE SECTOR DEVELOPMENT PLAN (FASDP)

6.1 INTRODUCTION This chapter examines environmental and social issues which need to be considered as part of the overall structural and economic adjustments in Ghana’s fisheries sector in the longer term (i.e. 1-15 years). The assessment deliberately focuses on the longer term because it will take a number of years before current plans start to have their full effect. However, the same temporal considerations apply to measures that are designed to avoid or mitigate potentially harmful effects so it will be important to start planning remedial actions as part of the joint Government of Ghana and World Bank fisheries programme

6.1.1 Key sectors and activities The fishing industry is divided first into marine capture and inland capture fisheries and then aquaculture. For each of these three sectors, activities are then broken down as follows:

Marine Capture Fisheries CATEGORY ACTIVITY Stock Management Research /Surveillance/ reef building Harvesting Vessels / Gear / Skills / capacity Marketing Sellers / Buyers Processing Fresh fish /Sun dried / Smoking / Freezing Consumers By market sector Support Sectors Boat / Canoe Building / fuel supply / net making/ kiln construction /refrigeration / transport / cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour / wharf / processing plant construction

Inland Capture Fisheries CATEGORY ACTIVITY Stock Management Research /Surveillance Harvesting Vessels / Gear / Skills / capacity Marketing Sellers / Buyers Processing Fresh fish /Sun dried / Smoking / Freezing Support Sectors Boat / Canoe Building / fuel supply / net making/ kiln construction /refrigeration / transport / cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour / wharf / processing plant construction

Aquaculture and Mariculture CATEGORY ACTIVITY Stock Management Research /Surveillance Rearing Roe / fingerling production / cage -pond rearing Harvesting Vessels / Gear / Skills / capacity Marketing Sellers / Buyers Processing Fresh fish /Sun dried / Smoking / Freezing Support Sectors Boat / Canoe Building / fuel supply / cage construction/ kiln construction /refrigeration / transport / cold store management Legal Enforcement Financing Investment in all elements Infrastructure Harbour / wharf / processing plant construction

6.1.2 Evaluation Criteria The environmental and social assessment has been undertaken using a matrix (See Annex 11.4) which analyses the key sectors and activities of the fishing industry and the changes that are envisaged against a set of evaluation criteria. Evaluation Criteria are broken down into environmental and social issues, distinguishing between beneficial and adverse effects. Table 6.1 below shows the relationship between the groups of criteria.

Table 6.1 List of Evaluation Criteria Environment Social

Positive Adverse Positive Adverse

• Sea bed rejuvenated • Sea bed degraded • Increased harvest • Reduced harvest (catch • Fish stocks recovered • Fish stocks reduced (catch volume) volume) • Biodiversity enhanced • Biodiversity reduced • Increased catch value • Reduced catch value • Reduced costs of • Increased costs of inputs inputs • Increased profit • Reduced profit • Enhanced livelihoods • Reduced livelihoods • Increased job • Reduced job opportunities opportunities • Increased local • Reduced local economic multiplier economic multiplier

The assessment process has involved systematically considering each sector/activity against the evaluation criteria and recording either positive or negative results by drawing on the judgement of the consultancy specialists. The findings are discussed in the paragraphs that follow and are reflected in Table 8.1 forming part of the Draft Environmental and Social Management Plan.

6.2 DETAILED ASSESSMENT OF THE MARINE AND AQUACULTURE SECTORS

Tuna/Industrial fleet streamlined and catch per vessel improved: At present, industrial trawlers have to travel increasing distances to fishing grounds and while the level of catch is remaining broadly static costs are increasing against available economic returns. A major shortcoming is lack of investment in re- equipping the aging fishing fleet. Many of the 90 vessels that make up this sector are increasingly unseaworthy and need to be replaced with modern trawlers and gear. The plan is to buy out owners of substandard vessels by offering compensation at market value, based on a full commercial survey. Vessels remaining in the fleet will be required to meet exacting standards. By reducing the number of old and inefficient boats this will allow each of the remaining vessels to catch a higher proportion of fish. The aim is to ensure that Ghana is equipped with the latest vessels and technology in order to preserve the country’s position as the hub of the West African tuna fishing and processing industry (see also the section on canneries below). The effect of these measures on the environment will remain broadly neutral since the same number of fish will be caught. Providing other policies and increased surveillance are successful in preventing trawling in inland waters the smaller fleet will have to fish in deep oceanic waters. This could potentially transfer some environmental effects on fish populations to other parts of the migratory cycle. However, this would become part of the international effort through fishing quotas to regulate overall catches.

Reduction in the size of the industrial fleet will mean that fewer men are needed to crew and service the vessels. However, in practice many men who work in this sector have only part time work and since a significant percentage of boats no longer put to sea, the number of crewmen who will be displaced could be in the range of 1000-30003. It will be important to set up support services for those losing their jobs, including retraining and welfare assistance where necessary.

Decommissioning will necessitate the sale of seaworthy vessels and their removal from Ghanaian waters. Other boats will need to be broken up and scrapped. This process requires heavy duty specialized equipment and can release significant quantities of waste oil, other toxic chemicals including refrigerants and asbestos used in pipe and engine room cladding. Measures will need to be taken to ensure that proper environmental and health safety precautions are taken, that decommissioning takes place in properly equipped boatyards and that all waste products are disposed of without environmental risk.

Cannery sector optimized: The Fisheries and Aquaculture Sector Development Plan seeks to maintain the port of Tema as the centre of the Tuna canning industry in Ghana. At present a proportion of Ghana’s tuna catch is diverted to neighbouring countries due to constraints on processing capacity. These limitations include poor port infrastructure, ageing equipment, and delays in handling catch for some operators due to preferential treatment of vessels that are part-owned by the existing canneries. Options for improvement include encouraging upgrading of the capacity of one or more existing canneries or promoting more competition in the processing sector and improving the infrastructure. Providing modern building designs and construction techniques are employed and a full environmental assessment is undertaken in accordance with Ghana’s EIA regulations there should be no significant environmental or social risks associated with these development possibilities. The potential economic benefit resulting from encouraging investment in this sector is very high.

Industrial fishing excluded from inshore waters A major longer-term intention under the new fisheries plan (FASDP) is to ensure that existing regulations that restrict industrial and semi-industrial vessels from trawling in inshore waters are properly enforced. This requires provision of surveillance

3 Based on an average crew of 20 47 equipment, fast patrol vessels, capacity building and training and increased staffing within Government agencies together with a full programme of awareness raising, training and financial support to local bodies providing self-governance under new co-management services. Restriction of industrial trawling in coastal waters will greatly ease pressures on fish stocks and reduce environmental damage to the sea bed. In time this should lead to healthier fish population with more fish to be caught by the canoe industry as a result. However, the task of policing and enforcing regulations will not be easy and will take a number of years to bring into full effect.

Reduction in fishing activity by inshore trawlers will displace a number of crew members and have a short-term impact on dependent families until these individuals are either absorbed into the canoe fleet or find alternative employment. There will therefore be a need to assist genuinely deserving cases where crew members (and their families / dependents) need to transfer to other sectors of the economy. These measures will only be required in the short term since the anticipated improvement in fish stocks will lead to improved economic performance in the canoe sector within which the bulk of employment exists.

Expansion of deep water fisheries: The fisheries plan notes that there may be a potential for exploitation or increased exploitation of some deep sea fish resources. However, the status and population dynamics of some affected species is not well known so any such activities should be scientifically monitored through research and enforced by MCS. .

Tema /Secondi Port infrastructure improvements (equipment/buildings): Under present conditions the transfer of fish from commercial and industrial vessels to canneries is often delayed by the time taken to offload crates and manouvre within the port area where there are conflicting activities. There are also difficulties that arise when vessels owned by the canneries are given priority for landing leaving other boats waiting for many hours which can result in quality deterioration. At this stage no details are available about the precise improvements that could be introduced and this will need to be investigated as the fisheries plan is advanced. Any environmental effects from infrastructure improvements would be contained within the existing port areas and should be largely positive in reducing fuel (energy) costs and increasing overall efficiency. It will, however, be important to carry out an environmental review of specific development proposals at the design stage; especially if these involve plans for any dredging, or for altering facilities for discharging waste and disposing of bilge water. Both of these activities can have damaging effects on the sea bed. (The first through dispersal of silt and sediment and the second through release of potential contaminants). Socio-economic effects from the infrastructure improvements should also be beneficial by removing delays, increasing efficiency and reducing waste. However, there could be some slight reduction in manpower requirements leading to the need for skills retraining.

Regulating the catch (e.g. Fishing for selected species/ reducing juvenile catch/ to improve value of catch in inshore waters): The fundamental aim of the fisheries plan is to reduce the harmful effects on fish stocks and low economic returns from fish catches by phasing out open access for all and introducing regulation of fishing activity. This is to be achieved through close cooperation between the Fisheries Commission Monitoring and Surveillance Unit as well as marine fisheries management division and individual fishing communities working together under a co-management framework. The practical details will need to be worked out through each individual co-management group and, initially, the World Bank is offering to assist in the establishment of four pilots. These bodies will test exactly what is required to increase fishers’ awareness, to build capacity in self regulation and agree on appropriate measures.

From discussion with stakeholders it is clear that while the broad principles are accepted, the majority of the fishing community simply do not believe that the new regulations will be enforced because they have witnessed the failure of so many previous efforts to introduce firm management. A major issue for the planned programme is therefore how to change this critical mindset, without which very little progress is likely to be made in practice. It will be necessary to demonstrate through the pilots that by regulating fishing activity, direct benefits will accrue to those participating fishing communities. Unfortunately, efforts to eliminate harmful practices are unlikely to result in an immediate gain in fish stocks. Instead catches are likely to fall in the short term. It will therefore be essential to introduce other forms of incentive to cushion short term losses Such measures might include the purchase of new nets and gear for sale at subsidized price to local cooperatives, the introduction of cash incentives for canoes demonstrating best practice in the use of gear and nets, preservation of the catch using ice and landing and marketing fish of the required size and quality.

As restriction of open access starts to take effect there should be positive environmental gains in terms of improving fish stocks and less damage of the sea bed. On the other hand both fishers and fish processors will feel the adverse temporary effect of reduced catches. These social and local economic impacts will need to be monitored closely and assistance provided to help foster alternative livelihoods.

Cephalopus (Octopus) harvesting encouraged in inshore waters: Although most fish species are currently exploited to unacceptably high levels within coastal waters there is a specific opportunity to increase the number of octopus caught by pot fishing. This fishery could be developed by both the semi-industrial and canoe sectors. Taking octopus in pots would have no adverse physical impacts on the sea bed and could allow very slight expansion in fish species that are preyed on by octopus. At the same time it is important to note that there is only limited information on species composition and functioning of selected marine habitats; including those of the octopus and more research should be undertaken on this and other species that could be selected for expanded fishing activity. There would be clear socio-economic benefits arising from the creation of this new fishery

Focusing fish landing at specific landing sites: (to improve opportunities for subsequent marketing / processing): Plans are already being developed for the enhancement of landing and processing facilities at a number of existing locations along the coast. These locations include the construction of harbours at Jamestown and Elmina and development of landing sites at Teshie, Ada, Axim, Dixcove, Winneba, Mumford, SenyaBeraku, Gomoa, Fetteh, Moree, Keta, Dzemeni and Tapa Abotoase.

Two sets of issues need to be considered in relation to these improvements, all of which affect existing fish landing and processing sites. The first is the nature of the physical works and infrastructure and it s potential effect on the marine and terrestrial environment. The second is the socio-economic impact.

Both Elmina and Jamestown are long established fishing ports where the catch is landed either directly onto the beach or shallow wharves. It is understood that the primary aim of the improvements will be to increase the area of permanent wharves to make it easier for fish to be offloaded to reduce the time taken in transferring stock to processing plants and to introduce modern technology. In the case of other smaller landing sites, the scale of improvements will be quite modest, involving improvement to existing short stretches of access road, the erection of stores for nets and other gear and provision of covered areas to provide shade for net-mending.

With all proposals for physical infrastructure development there will be a need to consider possible

49 environmental implications. Due to the existing nature of these sites there are no major industrial or other commercial processes in the vicinity which could give rise to cumulative impacts including contamination of fish products. The scale of plant needed for ice-making and storage, and commercial smokeries is commensurate with the artisanal nature of the fishing activity itself and would not give rise to any significant environmental effects on air or water quality. Harbour works could potentially involve some small scale dredging, (for example the removal of accumulated silt). Where dredging is required it will be important to identify disposal areas (either at sea or on land) where silt can be deposited without damage to sensitive habitats.

In terms of economic and social impacts it is not clear at this stage who are likely to be the major investors from the private sector although it may be assumed that existing operators who have access to finance will be the main beneficiaries. Over time as landing marketing and processing become more efficient it is possible that individuals in the traditional fish smoking sector will lose a significant proportion of their trade as the product switches to fresh or frozen fish sales for transfer to the major urban markets and the beach price for fish rises. The draft Ghana fisheries and aquaculture sector development Plan notes in annex 2 that "proposed facilities associated with the ports and landing sites may not have support from fish mammies, or at least formidable commercial advocates able to resist any opposition from that quarter".

Inspection of major fish landing areas like Elmina and Sekondi indicates that the existing social and commercial structure of support activities to fish harvesting is very complex and involves almost every member of the community including children and the elderly. Such activities include net mending boatbuilding, metalworking (for cooking pots, stoves, and grills, supplies (ropes, weights, tar, paint, wood), fuel supplies, ice crates, transport etc. Leaders of the fishing community confirmed that in principle the improvements of facilities is welcomed provided that safeguards are in place for those who may lose part or all of their current trading activity through rationalisation.

Stabilise fleet capacity at a sustainable level: Fishery experts consider that there would be significant benefits in reducing the number of canoes from the present 10,000-12,000 to around 8000-9000 which correlates with the number operating in the mid 1990’s when catches were at optimum levels. At the same time, the Fisheries and Aquaculture Plan stresses that the canoe sector will remain at the heart of the Ghana fishing industry and this has strong political enforcement. Consequently there is unlikely to be any enforced reduction in the number of canoes holding licenses and owners of all existing canoes will be able to register their vessels. The ability of canoe owners to pay annual licence fees should rise as the overall measures to increase efficiency and improve catches take effect. However, many people anticipate that over time, as the annual cost of holding licenses rises, less efficient fishers will sell their licenses (and hence their rights to fish). There may therefore be a de facto reduction in the size of the canoe fleet. Even if numbers do not decrease, the fleet could be stabilized at its present size by taking a decision not to grant new licences. The draft plan discusses the fact that under existing law (section 53) there is a requirement for licenses to be issued on demand (presumably to ensure that Ghanaians are not barred from subsistence fishing). It is argued in the plan that this is a misconception since canoe fishing is largely a commercial activity and it is concluded that ‘it is therefore essential that the number of canoe licenses can be controlled in future and the legal basis for these controls must be reviewed as a matter of priority’.

Decisions of this nature will require the full support of local co-management groups if they are to be effective, but committees could easily come under pressure to make exceptions as the coastal population continues to rise and families without alternative livelihoods start lobbying for assistance.

Accusations of preferential treatment of certain individuals by committees (or committee officials) -, possibly linked with suggestions of bribery and corruption -could cause a lot of social tension and start to undermine community trust in the need to work together to improve fisheries management. It is therefore most important that the detailed proposals for co-management address this risk and include proposals for mitigating individual hardship of the less advantaged – for example by offering voluntary retirement with some form of incentive.

Influencing marketing to maximise value and reduce post harvest losses (marketing cooperatives, strong market structures etc): FAO has estimated that physical post harvest losses in Ghana amount to between 3 and 17% of smoked fish production and 16-20% of gillnet landings. The plan notes that introduction of ‘new generation’ small scale fish smokers should be introduced to replace the traditional Chorkor model. This would improve fish product quality by eliminating charring of fish over open flames and also protecting operators’ eyes from the damaging effect of smoke and particles. The other major improvement in post harvest value and profits would arise from greater use of ice throughout the supply chain.

Developing Aquaculture : A distinction needs to be made between aquaculture development in ponds and dugouts which are self-contained and fish rearing in cages within open water. In the case of farm ponds, the commercial rearing of fish is little different to other forms of intensive livestock rearing. Providing there is no direct connection to rivers and streams there is little likelihood of interaction between farmed and wild stocks which could spread fish infections and parasites.

In the case of fish farms in open water (rivers and lakes) there are well known risks of the spread of disease which can arise if overstocking occurs. Intensive feeding of large numbers of fish in a confined area can lead to significant deterioration in water quality through the build up of nutrients from wood and waste. It is also possible for antibiotics and growth hormones to be dispersed beyond the area of farm cages. Genetic modification of farmed fish can also affect the local fish population through escapes. All of these issues are capable of being managed and mitigated through good initial planning and design and subsequent maintenance and supervision. It will therefore be necessary to develop additional regulations and guidelines specifically for the aquaculture sector.

6.3 SUMMARY OF ENVIRONMENTAL RISKS AND OPPORTUNITIES Review of the full range of governance and development activities suggests that there are no high levels of risk to the marine or littoral environment. Successful implementation of the Policy, and plan should, in fact result in very significant environmental gains. Over a timespan of 5-20 years, five activities in particular should result in significant improvements in the condition of the sea bed in coastal waters (to a depth of 30 metres), reestablishment of benthic flora and niche habitats, increased fish stock and enriched biodiversity. These interlinked activities are: • The exclusion of industrial vessels and trawling within coastal waters, • Regulation of fish catches through zonation, seasonal control of fishing and standards for vessels / gear, • Stabilisation of the fishing fleet within sustainable harvesting yields, • The adoption of management plans, formulated and agreed with full cooperation of local communities, • The introduction of fishing rights through co-management agreements, and • Well planned consultation and information dissemination throughout the fisheries sector.

Three components of the development plan have been identified where minor to moderate risk to the physical and biological environment could arise if proper design and implementation standards are not adhered to. These relate to: • A potential risk of over-exploitation of new catch species in deep water off the continental shelf if such development is not accompanied by through research to establish the sustainable yield of target species, • Strictly localized effects on the physical environment from construction of landing wharves or jetties and other harbour facilities, and • Infrastructure development at the existing ports of Tema and Takoradi.

All of these risks are capable of being fully managed by improved governance in the fishing sector and EIA procedures that are well-established in Ghana.

6.4 SUMMARY OF SOCIO-ECONOMIC RISKS AND OPPORTUNITIES Implementation of the Plan / Project will bring about substantial change in the fisheries sector and, over time, increased revenue, reduction of post[harvest losses and added value to fish products will bring major economic returns. At the same time there will be some individuals who do not participate in direct gains and whose livelihoods could be adversely affected if appropriate safeguarding measures are not put in place. The level and extent of these socio-economic risks will be determined by: 1. the level of commitment that is entered into by Government and its development partners to deliver incentives to vulnerable and disadvantaged groups and, 2. the speed with which the sector is transformed. Rapid change could cause significant displacement of less-efficient operators, especially within the semi-industrial and canoe sector which would have serious ramifications for dependent communities. However, these effects can be marginalized if the development programme is carefully phased to ensure that alternative livelihood and employment incentives are available.

The main risks to local livelihoods relate to the potential for: • loss of employment for crews of unseaworthy / obsolete vessels ( from all sectors including industrial / semi-industrial and canoes) that are withdrawn from the fishing fleet because they no longer comply with license regulations, • the inability of vulnerable and disadvantaged groups, including artisanal fishers, vendors and individual fish processors in small fishing villages to adjust to new market conditions at selected landing sites.

CHAPTER 7 ASSESSMENT OF POLICY OPTIONS

7.1 INTRODUCTION

In order to place the significance of the environmental and social safeguards assessment in context, this chapter examines the possible consequences of different policy responses to the existing challenges that face the fisheries sector in Ghana. These different policy responses range from a continuation of the status –quo, effectively a “do-nothing” option (A) to full-scale commitment by all stakeholders to achieving a sustainable fisheries future, the “Optimum Solution” option (C). Various less sustainable outcomes lie in between these two ends of a continuum of policy choices and these are represented by the “Weak Solution” option (B).

7.2 OPTION A – DO NOTHING Background research and discussion with stakeholders indicates that practical capacity to deliver on clearly stated national goals for sustainable fisheries, livelihoods and the reduction of poverty is weak. This situation exists despite the fact that Ghana has a strong legal framework for management of its fisheries, including the Law, Policies and Regulations. There is inertia and strong resistance on the part of the majority of players to accept that it is largely their own actions which are responsible for present conditions. This, in turn, leads to the attitude that it is only the ‘Government’ that must act by providing increased subsidies and cushioning the industry against further deterioration in catches.

Unfortunately, there is overwhelming evidence from around the world that where fish stocks are exploited beyond their natural capacity to regenerate this can lead to sudden and near-total collapse. Ghana has historically been one of the strongest fisheries in West Africa but the signs are ominous that current levels of exploitation are leading to progressive decreases in annual catches for most species in both marine and inland waters. As fishing effort intensifies with an increasing number of all types of vessel using illegal methods and inappropriate gear the distinction between the traditional ‘peak season and lean season (linked to migration patterns, breeding cycles and upwelling) is becoming blurred. This is clearly illustrated by a statement from one of Elmina’s fish mammies; “we use to smoke the herring in the peak but now the fishers bring them all the year”. Use of monofilament nets, light, dynamite and chemicals to obtain fish in the lean season is aggravating a situation where too many boats are chasing too few fish. Many fishers blame the reduction of catch on global warming for increasing water temperature, the emergent oil and gas industry for restricting access to traditional fishing grounds and industry and urban development for increasing pollution leading to deterioration in water quality. Each of these assertions warrants careful consideration but the industry is generally in denial when it comes to the primary fact – too many fish including juveniles are caught to allow regeneration of the stock. In addition, weak governance and lack of resources to ensure implementation of policy result in a situation where the law can be ignored with impunity.

If collective failure to recognize the seriousness of the current position and lack of commitment to taking hard decisions continues the omens for the future are not good. Within a period of 10-15 years fish catches could fall by 50% or more from their present level. Impacts on each species would vary and catches of some fish with regional or global migration patterns could remain viable (although this depends on the international conservation effort). On the other hand stocks of fish that provide the mainstay of local food resources herring and sardine could be decimated.

Complete collapse of all fish species is unlikely but it is possible to envisage a situation where catches might fall below 300,000 tonnes a year by 2025 (a reduction of more than 25% from present levels). The most serious consequences would be felt as a result of the social and local economic impact on fishing communities. Perhaps 30,000 men representing the crews of 3000 canoes and semi industrial boats and 15000 women engaged in marketing and processing would lose their present livelihoods. Population migration away from the coast could follow and severe social pressures and local economic hardship . This is clearly a “worst case” scenario and if conditions were to worsen gradually it might be possible to intervene but the fact has to be accepted that fish stocks are dynamic and subject to rapid decline (as in the case of the North Sea Herring and Atlantic Cod).

7.3 OPTION B THE ‘WEAK’ SOLUTION

The bleak future painted in Option A is unlikely to arise if the present policy and draft fisheries development plan is followed since these are specifically directed to addressing the major challenges. However, realization of the aims is dependent upon delivery across a wide range of initiatives by multiple stakeholders. The following paragraphs illustrate some of the ways in which delivery of policy objectives might be thwarted: These may be summarized as: • Commitment to good governance and institutional reform • Political resolve to implement unpopular measures • Availability of adequate technical and financial resources • Inertia to necessary changes in fishing practice

Good Governance and Institutional Reform Fundamental reforms are required to fully equip the national fisheries management effort at government level. This includes introduction of change management, clarification of responsibilities for senior staff, rationalization of financial management systems, provision of equipment, expansion of staff numbers, additional training and capacity building. As an illustration of the extent of the effort required reference can be made to just one topic area, the issue of monitoring, control and surveillance. At present the Fisheries Commission’s MCS Unit has only 10 employees to oversee implementation of the fisheries regulations throughout Ghana. This number will be increased as other institutions are engaged in joint monitoring initiatives but it is obvious that staff numbers and capacity will need to be expanded if regulations on fishing activities are to be affected. Enforcement is only one part of the equation however. Much greater emphasis will need to be placed on voluntary controls and self-policing at community level through Co-management schemes.

Failure to press ahead with governance and institutional reform could delay the process of introducing and registering licenses which represents a crucial first step in moving from open access to managed access in the fisheries sector. Given the urgency for action, the five years allowed in the current plan for completing the registration process seems very generous.

Political resolve to implement unpopular measures Stakeholder meetings have confirmed the significance of party political influence as a constraint on achieving progress in the reform of the fisheries sector. The offer of incentives like subsidies or the promise of new facilities and equipment are regularly employed by individual politicians to garner votes, whether or not these form part of party manifestos. Examples have been quoted to the consultants where enabling regulations that might restrict fishing access and prove unpopular amongst the fishing community are quietly ignored and officers may be discouraged from pursuing breaches of the law where the offender has political influence. These issues arise with governments of all political

54 persuasions and can apply at all levels from District Assemblies, through to regional and national committees.

A serious issue with fisheries sector reform is that once actions have been taken to conserve fish stocks it may be years before the full benefits are felt and the results are evident in terms of increased catches. This makes it harder for governments to institute unpopular reforms – even though these are in the best interests of the nation, fishing communities and individuals. Fishermen and their families are used to seeing an instant ‘same day return’ on their catch and are less willing or able than stakeholders in other economic sectors to wait for gradual improvements.

There is an urgent need to establish cross-party support for the fisheries sector in Ghana and to seek agreements between the main political parties to support established policy and regulations where these are in the interests of delivering sustainable fish stocks.

Availability of Technical and Financial Resources The process of moving from complete open access to restricted use rights for both marine and inland capture fisheries will take many years to complete. Progress will be heavily influenced by the level of political will, availability of technical assistance and financial support. Existing subsidies (pre-mix fuel and import tariffs) are seen as a deterrent to the encouragement of more efficient business practices. However, in order to reduce dependencies on these forms of government aid there is also a need to underwrite new forms of economic enterprise by giving help to start-up businesses, developing training centres and promoting alternative livelihoods for those individuals who are either displaced or voluntarily give up work in the fisheries sector.

Inertia to Change Traditional fishing practices are quite literally a way of life for many Ghanaians and have been handed down from generation to generation. These traditions are closely interlinked with cultural practices and power and influence resides in specific families with hereditary authority. In order to change attitudes and gain acceptance of new approaches to fishing there is a need for a major awareness building and communications strategy targeting, in particular the traditional leaders of the fishing industry. Without such a plan it will be difficult to break down the internal resistance and inertia towards change.

The constraints that have been outlined above in relation to the ‘weak’ option are very real and in combination they present a serious barrier to progress. It will require real political commitment on the part of Government and strong financial support from international partners to break down these barriers.

7.4 OPTION C THE ‘OPTIMUM’ SOLUTION

The new Draft Fisheries and Aquaculture Plan, together with the Act and Policies provide a solid foundation for revitalising the fisheries sector in Ghana. However, for the reasons discussed in relation to options A and B above, there are a number of impediments that need to be overcome. In addition to the measures in Option B, an “Optimum” solution would also include::

A coherent mix of Incentives (carrots) and Regulation (sticks): A top priority in developing existing strategies and plans will be to ensure that measures are in place to offer encouragement and practical assistance to fishers to convert to more sustainable practices while at the same time introducing effective enforcement. There are some real challenges with both of these goals.

New forms of incentive need to be developed to convince boat owners and their crews that it is worth their while to drop illegal methods (dynamiting / use of monofilament nets etc), and to reduce the level of fishing effort (through close seasons/ introduction of restricted zones etc). Without these incentives it is highly unlikely that there will be significant take-up of the fisheries stock management and conservation message.

Special attention needs to be given to the role of chief fishermen and local community councils in developing effective local policing since it is impractical to rely on a national MCS team to regulate canoe activity in either the marine or inland capture fisheries. The national MCS team will have its own responsibilities for policing local and international waters in relation to industrial and semi-industrial sized vessels.

Integrated Coastal Development: The long term success of the fisheries strategy depends upon reducing fishing effort to a level at which catches become both sustainable and profitable for those who remain in the business. This, in turn, requires that those displaced from the industry are able to find gainful employment and livelihoods in other sectors of the economy. The fisheries industry is often seen as a separate economic sector which attracts its own funding and support but in order for the necessary reforms to take place these attitudes will need to change. A new approach is required to ‘integrated coastal development’ following the lessons from integrated rural development.

Many fishing inland and marine fishing communities are almost wholly dependent on fishing with less than 10% of the local economy being devoted to other industries. Reform of the fishing sector therefore requires that as much – if not more – effort is devoted by government and its international partners to building up complementary economic activities in construction, transportation, manufacturing, food processing, environmental conservation and tourism. There is a need to explore new state / industry partnerships, to establish appropriate economic development agencies and to coordinate activities between relevant state institutions, ministries and departments under the current decentralisation initiatives with district assemblies taking a prominent role.

If initiatives of this sort are taken forward, it will make the task much easier in persuading conservatively –minded fishing communities that they need to simultaneously develop their own entrepreneurial flair and impose their own discipline.

Chapter 8 DRAFT ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

8.1 INTRODUCTION

Previous chapters of this report have described the principal environmental and social impacts that are likely to arise from reform in the fisheries sector. This chapter sets out the Framework (ESMF) for an Environmental and Social Management Plan (ESMP).The first step has been to outline specific objectives to be achieved through implementation of the ESMF. These objectives relate specifically to the issues described in earlier chapters. Subsequent sections of the chapter detail the measures which are required to respond to specific areas of environmental and social impact through mitigation and amelioration works. They also describe the types and level of environmental monitoring required together with the institutional aspects which need to be improved in order to support the fisheries sector.

8.2 STRATEGY AND OBJECTIVES

The basic aim of the environmental and social management plan is to set out guidelines for participatory programs under which members of local fishing communities and civil society in general can become involved in the design and implementation of local fishery co-management, maintaining sustainable local livelihoods and achieving local monitoring of fishery efforts. The basic principle for future fisheries management is that both marine and inland waters will be demarcated as territories for use rights to fisheries (TURFs).

The principal goal of government policy in the fisheries sector is to ensure that the fisheries industry plays an increasingly important role in supporting the growth of the economy as outlined in the Ghana poverty reduction strategy (GPRS II) and the Republic of Ghana fisheries and aquaculture policy. This goal will be supported by implementation of the fisheries and aquaculture sector development plan over the next five years. In this timescale the aim will be to: • improve management of fisheries, the conservation of aquatic resources and protection of the natural environment • promote value addition in the fisheries sector and the improvement of livelihoods in fisheries communities • encourage sustainable development of aquaculture • improve the services provided to the fisheries sector by the fisheries commission and supporting institutions.

The overall consequences of this strategy and the investments that are being made by the government and its aid partners will be stabilisation of fish stocks and sustainable catch levels, a strengthening of the national economy and creation of a more robust fisheries industry with consequent benefits for fishing communities. Impact assessment confirms that the result will be significant benefits for the marine environment and local economy. However, depending on the rate of transition from an open access to a fully regulated market a number of adverse effects could arise unless appropriate mitigation measures are put in place. Specific issues which require attention in this plan are listed below: • potential risks of environmental degradation through development of new fishing targets in deep water;

• localised environmental impacts at construction sites; • loss of resources for individual operators due to restricted or controlled access to fishing grounds; • displacement of labour from crews of vessels that are withdrawn from the industrial and semi- industrial fleet; • Decommissioning of obsolete industrial vessels may not necessarily lead to recovery of fish stocks. Catch Per Unit Effort (CPUE) may increase. This could lead to loss of livelihoods to crew members and the owners of the decommissioned vessels; it could increase catch for the few vessels remaining in the system. • increase production costs due to idling time in closed seasons for fishing; • exclusion of some groups and individuals seeking entrance to the industry following completion of licensing; • concentration of processing and marketing at selected landing sites leaving Fish Mammies and their dependents in other smaller fishing communities at an economic disadvantage; • displacement of traditional canoe building and other ancillary support industries by more efficient and modern methods of construction and the inability of some workers in these trades to train and re-skill in the use of modern materials; • lack of employment opportunities in alternative sectors.

The ESMF will set out specific actions to address these concerns through a coordinated set of interlinked proposals as follows: 1) Preparation of local management plans and close surveillance of all new fishing enterprises in deep waters; 2) Preparation of environmental protection clauses to be included in all contracts and agreements for physical development work; 3) Regular inspection by environmental protection officers of construction work at harbours and landing sites; 4) Establishment of community management plans to provide support to those groups and individuals who are adversely affected by any of the measures listed above; 5) Creation of community liaison groups to actively support community development, alternative livelihoods and conversion to new areas of economic activity for those Fisher families or individual fishers who are adversely impacted; 6) Introduction of skills training centres and business advice for small and medium enterprise development; 7) Establishment of a coastal development agency drawing on the resources of the ministry of local government, agriculture and tourism (others to be added) to coordinate integrated projects and initiatives for economic development linked with the existing coastal zone management plans; 8) Creation of a liaison group between the government of Ghana and its international development partners to ensure that investment in the fisheries sector is targeted in the most effective way to deliver plan objectives and avoid duplication of effort.

8.3 COMPONENTS OF THE ESMF The following paragraphs provide a summary of the draft ESMF:

8.3.1 Local Management Plans: these plans will be prepared for discrete zones of influence around specified fishing settlements. Each plan will contain the same standard list of relevant activities that are to be monitored.

8.3.2 Environmental Protection: In relation to construction activity a checklist will be prepared identifying precisely what level of environmental scrutiny is required for specific types of development. This checklist will be prepared by the Fisheries Commission with the support and advice of the Environmental Protection Agency.

8.3.3 Small-Scale Project Development and Livelihood Restoration:: a list of potential micro-projects will be prepared by the Fisheries Commission which are regarded as suitable for support funding. Demand for these micro-projects will be determined at the local level (i.e. in villages and fishing communities). Applications for funding of micro-projects will be submitted to the community liaison group for vetting and recommendation based on pre-established eligibility criteria. Recommended projects will be referred for formal approval at national level (or through the Coastal Development Agency).

8.4 POTENTIAL PROJECT IMPACTS ON ASSETS AND LIVELIHOODS The project will have some adverse impacts on assets and livelihoods Therefore, provisions will be made under the ESMF to minimize all such impacts including those of socio- economic significance and on any environmentally sensitive sites. Provisions are also made in the RPF to accommodate all potential situations; including cases that may entail actual displacement and livelihood restoration assistance in accordance with the Government’s policy and World Bank Policy on Involuntary Resettlement, OP4.12 (see Chapters 9 and 10). The potential social and environmental impacts associated with the project (see Chapters 5 and 6) are summarised in Table 8.1 and the approach to related mitigation measures is defined in section 8.5 and Table 8.2 below

Table 8.1 Potential Environmental impacts and Social issues Type of Activity Description Environmental Social Significance Significance Decommissioning Scrapping of vessels may Contamination of Related health of obsolete release toxic waste landfill dumps hazards industrial vessels (contaminated oils / asbestos pipe wrapping and insulation etc) Laying off of work force Recovery of fish Decommissioning of stocks in areas excess/overcapacity currently over-fished would result in loss of by trawling livelihoods for crew members

Plan for fishing introduction of licensing system Reduced catch from Short term reduction capacity for canoes and enforcement of the decline in the use in fishing effort and reduction licensing system for semi of prohibited fishing increased regulation industrial vessels methods (activities) may prejudice as stipulated in the vulnerable sectors Fisheries Regulation (illiterate / elderly 2010 (LI1968) e.g. use fishers) of light, dynamite etc Capping on new entrants may remove Reduction in fishing the safety net capacity should lead opportunity offered to significant by fisheries to would- recovery of fish be fishers who may stocks with long term be without benefits for all alternative livelihoods Harbour Construction of access road Removal of shelters / Possible non- development and improvements. Erection of fish homes. voluntary landing site processing and ice making Displacement of boat resettlement improvements plant. repair and trading including vulnerable The Project could give rise to a sites for local groups (women, small level of physical community children and the displacement for some sectors elderly) of individual communities Adaptation Introduction over time of Measures to combat Both beneficial and Strategies to regulations relating to fishing /tackle rising adverse effects may climate change activity in rivers/ lakes/ temperature and result from changes estuaries / lagoons and ‘areas of other climate induced in climate (e.g. faster upwelling affected by climate changes should growth rates from change ameliorate higher water environmental temperature / spread impacts of invasive species) Establishment of Restrictions on fishing in oil Positive – recovery of Temporary loss of exclusion zones – production areas and marine fish stocks but also livelihood for those oil production protection areas potential risks of fishers displaced from and marine pollution from oil ‘traditional’ fishing protection areas leaks and human grounds waste Development of Creation of 4 pilot Stakeholder – Demonstration of Greater social Co-Management based Fisheries Management practical benefits for cohesion and sense System Initiatives the marine of purpose environment established. resulting from elimination of damaging practices

Type of Activity Description Environmental Social Significance Significance Support for PAPs. Development of criteria for Major benefits for Establishment of defining Project Affected PAPs – but scope for enterprise Persons (PAP) , misinterpretation training Development of skills training /mismanagement of programmes schemes / enterprise programme at local allowances/ alternative level. livelihoods fund Jobs created under social significance should be familiar to the fishers; i.e. things they will be willing to do.

Developing Establishment of enforcement This component will A number of new jobs Compliance unit and development of greatly improve should be created Systems facilities and training for controls over under this participatory coastal environmentally programme surveillance of small-scale unfriendly damaging fisheries activities Improvements in Development of more efficient This measure should Potential fish processing fish processing plant reduce significantly displacement of technology the proportion of fish vulnerable groups lost or degraded post (women, children and harvest . Improved the elderly)who fish processing currently participate technology will also in fish drying /curing reduce wood used using basic from the forest as equipment firewood for fish smoking. Construction of Expanding areas of dug-outs Small scale impacts Displacement of fish ponds and other farm ponds on vegetation / existing land users stream flow Catalysing Encouragement of larger fish Localised Potential competition aquaculture farming enterprises deterioration in with free capture development Installation of fish cage water quality / fisheries displacing aquaculture increased nutrients vulnerable groups in leading to existing fishing eutrophication / villages potential spread of fish parasites/ disease

8.5 PROPOSED MITIGATION MEASURES AND COST ESTIMATES

Mitigation measures The potential environmental and social impacts to be addressed within the context of preparing this Environmental and Social Management Framework are generalized as shown in Table 8.2 below. It is not possible at this time to prepare specific mitigation measures. It is expected though that environmental and social assessment studies will be carried out within specific localities, as and when required.

The framework for compensation/resettlement (See Chapters 9 and 10) will then be applied incorporating: (1) specific institutional arrangements, (2) resettlement/compensation eligibility criteria, (3) implementation procedures, (4) financial responsibilities, and, (5) monitoring and evaluation plan.

Livelihood restoration measures Furthermore, the livelihood restoration measures will consider issues such as: (1) income levels of affected persons, (2) other non-monetary sources of livelihood, (3) constraints and opportunities for income generation, (4) number of persons not able to revert to previous occupation, and, (5) existing skills of affected persons.

Table 8.2 Proposed mitigation measures for some potential impacts Type of Impact Description of mitigation measures

1. Decommissioning of obsolete a) A register will be prepared of all industrial vessels that are due to industrial vessels be decommissioned, recording the owner and location of each vessel. b) A system will be introduced for tracking progress on decommissioning , including the means of disposal and measures taken to dispose of all potentially toxic or hazardous materials c) Persons who lose their job or livelihood as a result of a decision to decommission any particular vessel will be entitled to benefit from the skills training schemes / enterprise allowances/ alternative livelihoods fund being developed. 2. Plan for fishing capacity a) A full Social and Environmental Impact Assessment will be carried reduction out on the Plan for fishing capacity reduction and appropriate measures for ameliorating and mitigating adverse effects on affected sectors of the community and PAPs will be incorporated in a revised edition of this Fisheries Environmental and Social Management Framework

3. Harbour development and a) All harbour development proposals will be subject to landing site improvements Environmental and Social Impact Assessment (ESSA) in accordance with EPA Regulations. b) Proposals for improvement of individual landing sites will be assessed in accordance with the checklist (8.3.2) and submitted to EPA for a ruling on the level of environmental assessment that is required which will depend on the nature of the intended works 4. Adaptation Strategies to a) An adaptation Strategy shall include proposals for mitigating any climate change impacts on the environment or social welfare of local communities. b) Any strategy for responding to potential effects of climate change on the fisheries sector will be submitted to EPA for review to determine whether an SEA or EIA is required. 5. Establishment of exclusion a) Proposals for restricting access of fishing vessels to oil production zones – oil production and areas and marine production areas shall be subject to an marine protection areas Environmental and Social Assessment which shall be submitted for approval to EPA. b) In the event that restrictions are likely to adversely affect fishers’ livelihoods the provisions set out in 7 below will apply. 6. Development of Co- a) Development of co-management systems will require full Management System cooperation and engagement of all stakeholders. In the unlikely event that the provisions of any scheme are challenged by local communities there shall be a right of appeal to the Minister of Food and Agriculture and the Fisheries Commission acting jointly. 7. Support for PAPs. a) Identification of vulnerable people, including women, children and Establishment of enterprise the elderly and identification of the cause and impacts of their training programmes vulnerability shall be established through direct interviews and procedures to be developed as part of 6 above. b) A high priority within the Fisheries and Aquaculture Sector Development Plans’ first five year programme will be the development of specific proposals for the establishment of skills training programmes and the establishment of enterprise allowances and an alternative livelihoods fund. c) The measures outlined in 7b) above will be targeted specifically at PAPs and vulnerable sectors of the community.

8. Developing Compliance a) All proposals for securing compliance with fisheries regulations Systems shall be subject to review by a fisheries stakeholder committee to be established by the Fisheries Commission with the remit of ensuring that the measures themselves and penalties for failure to comply, are commensurate with the ability of offenders to make restitution and do not unfairly penalize vulnerable sectors of the community. 9. Improvements in fish a) All plans and proposals for the introduction of new fish processing processing technology technology shall be published and shall include a statement on the likely impact of the project on existing processors within the local community.

b) Any members of the public who consider they are unfairly disadvantaged by proposals for the introduction of new technology may apply to the local co-management committee to determine whether or not they fall within the category of PAP (see 6 and 7 above) 10. Construction of fish ponds Proposals for the construction of new fish ponds shall be assessed in accordance with the checklist (see section 8.3.2). 11. Catalysing aquaculture a) All proposals for aquaculture development shall be in accordance development with the provisions laid down in Local Management Plans applying to specific TURFs