For the Liberia ACE Cable Landing Project

reve ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

Public Disclosure Authorized (Draft Report)

For

Public Disclosure Authorized The Liberia ACE Cable Landing Project

Public Disclosure Authorized

Prepared by:

Environmental Resources Managers Limited Plot 107A Imam Abibu Adetoro Street Off Ajose Adeogun Street Victoria Island

Public Disclosure Authorized Lagos, Nigeria

November, 2010

Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

TABLE OF CONTENTS

Table of Contents

List of Tables

List of Figures

Executive Summary xi

CHAPTER ONE: BACKGROUND AND INTRODUCTION 1

1.1 Introduction 1 1.2 Project Objective 2 1.3 Program Description 2 1.4 Structure of the Report 4

CHAPTER TWO: ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK; OBJECTIVES AND SCOPE OF WORK 5

2.1 ESMF Objectives 5 2.2 Scope of Work 6

CHAPTER THREE: METHODOLOGY 8

3.1 Data Gathering 8 3.2 Environmental and Social Screening Tool 8 3.3 Environmental Impact Analysis 9 3.4 Mitigation Measures 9 3.5 Environmental Management Plan 9 3.6 Capacity Building and Training 9

CHAPTER FOUR: POLICY AND REGULATORY FRAMEWORK 10

4.1 National Environmental Legislation 10 ii November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

4.1.1 The Liberian National Constitution (1986) 10 4.1.2 The National Environmental Policy 10

4.1.3 The Liberian Environmental Protection Agency (EPA) Act 12 4.1.3.1 The EPA EIA Process 12 4.1.4 The Land Use Act (1929) 13 4.1.5 The Liberian Labour Law 13 4.2 International Environmental Legislation 14 4.2.1 The IMO Convention for Prevention of Pollution from Ships 14 4.2.2 UN Convention on Law of the Sea 14 4.3 International Labour Laws 15 4.4 The Core Labour Standards 15 4.5 World Bank Policies 16 4.5.1 Triggered World Bank Policies 16 4.5.2 Other World Bank Policies 18 4.6 Adequacy of Environmental Legislation 19

CHAPTER FIVE: PROJECT DESCRIPTION 20

5.1 Project Overview 20 5.2 Project Justification 21 5.3 Benefits of the Project 22 5.3.1 Direct Benefits 22 5.3.2 Indirect Benefits 22 5.4 Cable Description 23 5.5 Cable Technology 25 5.6 Repeaters and Branching Units 26 5.7 Landing Sites 26 5.8 Project Alternatives 26 5.8.1 Technology Alternatives 26 5.8.2 Routing Alternatives 27 5.8.3 Landing Site Alternatives 27

5.9 Project Phases 31 5.9.1 Construction Phase 31 5.9.2 Operations Phase 33 5.9.3 Repair /Recovery Activities 34 5.9.4 Decommissioning Phase 34 5.10 Cable Laying Personnel 34 5.11 Project Schedule 35

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CHAPTER SIX: ENVIRONMENTAL CHARACTERISITCS OF THE PROJECT AREA 36

6.1 Geographical Location 36 6.2 Topography 38 6.3 Geology and Soils 38 6.4 Climate 38 6.5 Marine and Coastal Wildlife 39 6.5.1 Marine Species 40 6.6 Threats to Coastal and Marine Resources 41 6.7 Governance 41 6.8 Ethnic Groups 42 6.9 Culture 43 6.10 Religion 44 6.11 Macro Economy and Livelihood 45 6.12 Health Situation 46

CHAPTER SEVEN: STAKEHOLDER AND ENGAGEMENT AND PUBLIC DISCLOSURE 47

7.1 Stakeholder Identification 47 7.2 Stakeholder Engagement Phases 49 7.3 General Guidelines for Stakeholder Engagement 50 7.4 ESMF Disclosure 50

CHAPTER EIGHT: ENVIRONMENTAL IMPACT ASSESSMENT 51

8.1 Positive Impacts 51 8.2 Potential and Associated Adverse Impacts 51

CHAPTER NINE: IMPACT MITIGATION 55

9.1 Introduction 55 9.2 Project Mitigation Principles 56

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CHAPTER TEN: ENVIRONMENTAL AND SOCIAL MANAGEMENT IMPLEMENTATION PROCESS 60

10.1 Overview of ESMF Implementation Process 60 10.2 Project Screening and Categorization 61 10.2.1 Categorization for EIA 61 10.2.2 Applicable Standards, Limits and Permit Requirements 62 10.2.3 Screening Report 63

10.3 Preparation of EIA Reports 63 10.4 Environmental Management Plan 63 10.4.1 Policy 64 10.4.2 Environmental and Social (E &S) Management Department 64 10.4.3 Training 65 10.4.4 Communications 66 10.4.5 Monitoring and Reporting 67

10.5 Budget to Implement ESMF 67

APPENDICES

Appendix 1 Documents Consulted 70 Appendix 2 Illustrated EPA EIA Process 71 Appendix 3 Guidelines for Preparing Terms of Reference for an Environmental Impact Assessment (EIA) Study 72

Appendix 4 List of Participants at Stakeholder Workshops and Meetings 79

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LIST OF TABLES

Table 4-1: Summary of Other Key International Environmental Agreements, Treaty, Convention, Regulation Ratified By Liberia 14

Table 4-2: Labour Convention/Treaty Ratified by Liberia 15

Table 5-1: Submarine Telecommunication Cable Types 24

Table 6-1: Ethnic Groups and Tribes of Liberia 42

Table 7-1: ACE Cable Project in Liberia - Stakeholder Categories 48

Table 8-1: Types of Project -Related Occupational and Public Health Hazards 54

Table 9-1: Impact Mitigation Principles for Sub Project Activities 56

Table 10-1: Elements of Environmental and Social Management Process 60

Table 10-2: Project Categorization Checklist for EA 61

Table 10-3: Roles and Responsibility of Environmental and Social Management Officer 65

Table 10-4: Estimated Annual Budget to Implement ESMF 67

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LIST OF FIGURES

Figure 5-1: Cable Design Types 24

Figure 5-2: Modern Submarine Cable 25

Figure 5-3: Location of Landing Site Alternatives in Monrovia 29

Figure 5-4: Picture of Preferred Landing Site 29

Figure 5-5: Alternative Site Along 17th Street, Sinkor 30

Figure 5-6: Alternative Project Site around Fish Market 30

Figure 5-7: Alternative Project Site along Benard Beach, Congo Town 30

Figure 5-8: Typical Submarine Ploughs 33

Figure 6-1: Location of Liberia in Africa 36

Figure 6-2: Location of Liberia among Neighbouring Countries 37

Figure 6-3: Liberian Counties 37

Figure 6-4: Annual Climate Distribution of Liberia 39

Figure 6-5: Flow Chart of Local Administration 42

Figure 6-6: Distribution of Liberian Ethnic Groups Across the Country 43

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LIST OF ACCRONYMS

ACE - Africa Coasts to Europe

BTC - Barclay Training Centre

Bus - Branching Units

BPEO - Best Practice Environmental Options

C&MA - Construction and Maintenance Agreement

CBD - Convention on Biological Diversity

CBO - Community Based Organisations

CCL - Cable Consortium of Liberia

CEO - Chief Executive Officer

CLS - Core Labour Standards

CSO - Civil Society Groups

E&S - Environmental and Social

EA - Environmental Assessment

ECOWAS - Economic Community of West African States

EEZ - Exclusive Economic Zone

EIS - Environmental Impact Study

EPA - Environmental Protection Agency

ESIA - Environmental and Social Impact Assessment

ESMF - Environmental and Social Management Framework

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FONSI - Finding of No Significant Impact

GBPS - Gigabits per second

GEF - Global Environmental Facility

GHG - Green House Gas

GoL - The Government of Liberia

HIV/AIDS - Human Immuno deficiency Virus/ Acquired Immune Deficiency Syndrome ICT - Information and Communications Technology

IFC - International Finance Corporation

IMO - International Maritime Organisation

LCIP - Liberia Communications Infrastructure Program

LIBTELCO - Liberian Telecommunications Corporation

LMA - Liberian Maritime Authority

LTA - Liberia Telecommunications Authority

MDG - Millennium Development Goals

NGOs - Non Governmental Organisations

PIU - Project Implementation Unit

PPP - Polluter Pays Principle

ROV - Remotely Operated Vehicle

RPF - Resettlement Policy Framework

SAT-3 - South Atlantic-3

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SR - Screening Report

TOR - Term of Reference

UN - United Nations

UNCLOS - United Nations Convention on the Law of the Sea

UNDP - United Nations Development Programme

WARCIP - West Africa Regional Communications Infrastructure Program

WARCIPLP - West African Regional Communications Infrastructure Program Liberia Project

WDM - Wavelength Division Mulitplexing

WGB - World Bank Group

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EXECUTIVE SUMMARY

ES 1 - BACKGROUND AND INTRODUCTION The Government of Liberia in its plan to improve communication in the country and international connectivity with the rest of the world, is planning to link to the ACE submarine fibre optic cable, which is an approximately 17,000 km submarine cable system, connecting South Africa to Europe and potentially connecting up to 24 countries including a landing station in Liberia. Towards successful actualization of this goal, the government formed the Cable Consortium of Liberia (CCL) to own and operate the ACE landing station in Liberia. The benefit of the Liberia Communications Infrastructure Program (LCIP) will be significant, as a direct access to broadband will set the foundation for digital revolution. The Project is supported by the World Bank as part of the Bank‟s West Africa Regional Communications Infrastructure Program (WARCIP), which seeks to contribute to lowering the cost and improving quality of regional and international connectivity across the region.

The overall objective of the project is to improve communication in the country. In order to achieve this objective, the project will focus on improved connectivity through the connection of a submarine cable communications network in the country, address missing infrastructure link, and create an enabling environment and institutional strengthening to remove existing bottlenecks.

Although the details of the project implementation are yet unknown, it is timely to develop and design a structure to address possible adverse effects of anticipated project-environment interactions. To this end, the World Bank‟s environmental and social safeguards policies require that the recipient country prepare an Environmental and Social Management Framework (ESMF) (consistent with national laws, any applicable treaty concerning international waters, and OP 4.01) and a Resettlement Policy Framework (RPF) for the lateral cables and any associated equipment that will be laid from the junction with the main cable through territorial waters and onto the national shores.

ES2 – OBJECTIVES OF THE ESMF This Environmental and Social Management Framework seeks to provide a clear process including action plans to integrate environmental and social considerations into the implementation of the ACE project in Liberia.

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ES 3 - POLICY AND REGULATORY FRAMEWORK In Liberia, there are a few National laws, policies, regulations and standards, which seek to protect the natural environment and assure sustainable development in the country. These include the provisions of Liberian National Constitution (1986), the National Environmental Policy and the EPA Act of 2002.

The country is also a signatory to some international conventions, treaties and agreements that seek to protect the environment. Examples include the United Nations Convention of Law of the Sea, Convention on Biological Diversity, the Kyoto Protocol, Ramsar Convention on Wetlands and some Labour Agreements.

The World Bank policies that have been triggered by the Project are:

- Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment. - Operational Policy/Bank Procedure 4.04 - Natural Habitat - Operational Policy/Bank Procedure 4.36 - Forests. - Operational Policy /Bank Procedure 4.11 - Physical Cultural Resources - Operational Policy 4.12 - Involuntary Resettlement - ES4 - PROJECT DESCRIPTION Overview The Government of Liberia (GoL) in its plan to improve communication in the country and international connectivity with the rest of the world, is planning to link to the ACE submarine fibre optic cable. Towards successful actualization of this goal, the government formed the Cable Consortium of Liberia (CCL) to own and operate the ACE landing station in Liberia. CCL is a technology company that is partly owned by the Government of Liberia, LIBTELCO, Lonestar Communications and Cellcom.

The submarine cable will be deployed over 17,000 km and will provide access to more than 24 countries starting in 2012. It will include a new open-access fibre optic submarine cable, which will expand international telecommunications services to countries in the Atlantic Coast of Africa. It is envisaged that the system will facilitate data transmission, voice, internet and television signals, allowing for inter country transmission of information. With a planned capacity of about 1.92 Tbit/s, the ACE system will provide sufficient and redundancy capacity for the future country needs. Implementation of the ACE Cable Project in Liberia includes 3 distinct components; i. A deepsea cable laying in the international waters from France to Liberia; ii. a connecting cable from the submarine or deep sea cable to the shores of Liberia in Monrovia; and iii. A landing or cable station in Monrovia xii November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

Project Justification Currently the SAT-3 system is the only international fibre optic cable serving the West African coast since April 2002. Liberia could not be part of the SAT-3 system primarily because of the 14 year civil unrest, which ended in 2003. Further, the capacity on the SAT-3 system is severely constrained. The system currently has an overall capacity of 120 gigabits per second (Gbps).

The ACE project is also in consonance with Target 8.F of the UN Millennium Development Goals (MDG), which recognizes that:  Demand grows daily for information and communications technology;  Access to the World Wide Web is still closed to the majority of the world‟s people; and  A large gap separates those with high-speed Internet connections, mostly in developed nations, and dial-up users

Target 8.F therefore seeks to make available benefits of new technologies, especially information and communications in cooperation with the private sector

Project Benefits The direct benefits of the project include: i. Increase in available international transmission capacity and the lower cost for such access; ii. Faster and more reliable transmission for data and voice as a result of increased capacity and lower access cost; iii. Improved business performance while creating additional opportunities for business expansion; iv. Improved mobile telecommunications availability across the country; and v. Improved local content participation in the ICT industry, capacity building and technology transfer.

The indirect benefits are those derived from the direct benefits earlier listed and include: i. Better economic integration of, and cooperation among African State countries and linkage to global economy; ii. Catalyzed start-up of new businesses; iii. Support for gender-related advocacy and program activities; iv. Exchange of experience and technical expertise with international community and internally across various business sectors; i. Expansion of technology-based into Liberia; and

xiii November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report ii. Employment generation and better inclusion of low-income communities in ICT education.

Cable Description and Technology The proposed cable system will comprise an optical fibre submarine communications cable to carry telecommunications between France and Liberia. An optical fibre is a glass or plastic fibre that carries light along its length. Optical fibres are widely used in fibre-optic communication. They permit transmission over longer distances and at higher data rates than other forms of communications.

The ACE system will deploy wavelength division multiplexing (WDM) technology, which is currently the most advanced for submarine cables. With WDM, cable capacity can be increased without additional submarine work. With an overall potential capacity of 5.12 Tbit/s, the system will support the 40 Gbit/s technology at day 1.

Cable Landing Site A number of locations are being considered as options for the ACE Cable landing site in Monrovia including:

 Option 1: A 400-500m stretch of unencumbered land along Monrovia beach immediately south of the Ministry of Defense Headquarters. The stretch has no residents, squatters and fishing activities, but is only used by natives for soccer.  Option 2: A portion of the beach within a well built area of Monrovia – this is stretch of beach immediately southward of a slightly dense built up area also in the city. The buildings along this stretch are about 40 – 50m from the beach.  Option 3: A portion of the Monrovia beach near shanty towns. The very poor people live on both sides of a canal and derive their livelihood from the area.  Option 4: A portion of the beach used for landing fish by fisher folks.

Final selection of the landing site will however be done once necessary consultations have been completed and clearances have been obtained.

Project Alternatives Technology, Routing and Landing Site alternatives are being considered to determine which location, technology process or other aspect of the project are best in terms of cost-benefit, overall project objectives, environmental and social sustainability.

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Project Phases The project will be implemented in three main phases:

Construction The construction phase includes pre-installation activities which comprise cable route geotechnical and geophysical survey to investigate the most cost effective and safest possible environment for the cable and prepare for its installation followed by cable engineering design. Cable installation will then be carried out by ploughing in deeper marine sections while trenching options are likely to be used for shallower areas. The cable will be installed using a special built ship, which accurately places cables on or under the seabed along the route determined by the pre-installation survey.

Operations Once in place and connected, the cable system requires no intervention. Power is provided to the system through electrical connection in the cable. This also provides power to the repeaters. The electrical current is fully shielded from the environment. During operations, cable repair or maintenance activities may be carried out as required.

Decommissioning As cables reach the end of their design life or become redundant due to technological advances, their removal from the seabed or decommissioning may be considered. In the case of a buried cable, its removal may result in some disturbance or impact.

ES5 – ENVIRONMENTAL AND SOCIAL CHARACTERISTICS OF THE PROJECT AREA

Project Location The ACE Submarine project will be implemented within deep and shallow marine waters of Liberia, and a shore location along the coast of metropolitan Monrovia.

Liberia is located on the west coast of Africa and is bordered on the north by Guinea, on the east by Côte d‟Ivoire, on the south and southwest by the Atlantic Ocean, and on the northwest by Sierra Leone.

Monrovia is the capital and the country‟s largest city. It is located in the Montserrado County. Monrovia has an estimated population of about 1.5 million inhabitants. Liberia is divided into 15 counties with an estimated country wide population of 3.5 million. The project landing site is located in the Montserrado county.

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Topography The proposed project will occur in the region of Liberia known as the flat Coastal Plain. It is the land region of the country just next to the Atlantic Ocean. Indeed, the selected landing site is less than 50 meters from the Atlantic Ocean.

Geology and Soils The project area is located in what is known as the Pan African Age Province. The rock type in this region is less than 500 million years. There is a zone of fluvial and deltaic deposit which extends from the Freeport of Monrovia. This zone comprises buff silt and sand deposits, which are characteristic of very low terrain along the coast. The preferred landing site is composed mainly of beach sand, nearly pure white quartz sand, less than 5 meters in thickness and above sea level.

Climate As is the case with the rest of Liberia the climate of the project area is tropical and humid, with little change in temperature throughout the year. The temperature rarely exceeds 36oC (97oF) or falls below 23oC (73.4oF), with a mean annual temperature of about 26oC (78.8oF). The climate is characterized by a monsoon (wet) season and a dry season. The monsoon season extends from late April through October, with the majority of the rainfall occurring between mid-April and mid- October. During this time frame the average humidity is about 82%. The dry season extends from mid-October to mid-April.

Marine and Coastal Wildlife Liberia animal life is exceptionally diverse, with a high population of species that are endangered outside the country. There are approximately 125 mammal species, 590 bird species, 165 native fish species, 74 unknown reptiles and amphibians and over 1000 described insects species in Liberia.

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(Lepidochelys Olvacea). The Green Turtles are classified as endangered and the Hawksbill. Turtles are classified as critically endangered (WCMC, 1996).

Governance Liberia has a Republican form of government, similar to that of the United States of America. There are three (3) branches of government: the Executive, the Legislative and the Judicial Branches. The Legislative Branch is responsible for making law and legislations; the Judiciary is responsible for interpreting laws and operates the court systems; and the Executive is responsible for the management and enforcement of laws of the country.

The Ministry of Internal Affairs through its Superintendents administers the fifteen (15) counties of Liberia, assisted by other local officials. The Superintendent is appointed by the President of Liberia, along with the Development Superintendent and Commissioners. The Paramount chiefs, Clan Chiefs and Town chiefs are elected by the people in keeping with the laws of Liberia

Ethnic Groups Liberia is comprised of approximately seventeen (17) major tribal groups divided into five categories namely; Mel, Kwa, Mande-fu, Mande-tan and English speaking. The majority of the tribal people of Liberia emigrated from ancient empires in West Africa, namely Ghana, Songhai and Mali Empires. As these empires failed and internal and regional conflicts ensued, the tribal people migrated toward the south and settled in what is today Liberia. The English-speaking people were however descendents of former slaves brought from the United States of America

Culture The culture of Liberia reflects this nation's diverse ethnicities and long history. Liberia was founded by freed slaves that returned from the United States of America and other areas. However, before the coming of the freed slaves, the land area of Liberia was inhabited by people from the ancient empires of West Africa.

The official language of Liberia is English. There are also more than 16 indigenous languages, a few of which have their own unique alphabets.

Religion Liberia was established by freed slaves returning from the United States of America. Most of those returning were Christians. Upon their interaction with natives, they evangelized them, thus raising the Christian population. Interaction with European sailors and missionaries also led to Christianization of Liberia.

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Liberia has always been recognized as a Christian country, but the Constitution of 1986 presents Liberia as a secular nation.

Macro Economy and Livelihood Liberia is one of the world's poorest countries, with a formal employment rate of only 15%. Historically, the Liberian economy depended heavily on iron ore and rubber exports, foreign direct investment, and exports of other natural resources, such as timber. Agricultural products include livestock (goats, pigs, cattle) and rice, the staple food. Fish are raised on inland farms and caught along the coast. Other foods are imported to support the population.

Health Situation Many years of civil crisis adversely affected Liberia in various respects, including the health sector. This sector experienced extensive destruction of its infrastructure, the displacement of health personnel, the massive looting and destruction of equipment, including drugs and medical supplies.

Malaria, diarrhea, acute respiratory infections, neonatal tetanus, measles and malnutrition are the major causes of morbidity. Malaria is the leading cause of death and accounts for over 40% of all cases dealt with in health facilities. Those with the highest risk to malaria are pregnant women, children and people with compromised immunity such as those living with HIV/AIDS.

ES 6 - STAKEHOLDER ENGAGEMENT AND PUBLIC DISCLOSURE The LTA recognizes that stakeholder involvement is an important element of the Ace Cable Project and the EA process and that stakeholder identification and analysis at an early stage of a project is critical in the assessment of interests, concerns, relationships, assumptions, their level of influence and the ways in which they affect project risks.

Through wide consultation therefore, the LTA sought to achieve public involvement for better and more acceptable decision-making especially with regard to the sustainability, scope, significance and mitigation of adverse project impacts. Consultation and stakeholder engagement have been pursued positively with the aim of utilizing outputs to assure the overall project sustainability and improve

xviii November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report environmental management planning. Additionally, it is anticipated that early consultation as embarked upon by the LTA will lay the foundation for ongoing positive relationships on the project among the variety of stakeholders. Stakeholder engagement involved planning and implementation stage activities.

This ESMF and copies of the environmental reports on the project will be made available to the public at selected locations for information and comments. Members of the public will be notified of report displays through electronic and print media. Such notification should provide:  Title and brief description of the Project;  List of venues where the ESMF report is on display and available for viewing;  Duration of the display period; and Contact details and procedure for comments

ES - 7 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT Positive Impacts If successfully implemented, the ACE Cable project is set to provide a number of direct and indirect benefits to Liberia. Although anticipated benefits will be in the area of economic growth and improved human development, some environmental benefits are expected.

Potential and Associated Adverse Impacts Adverse impact analysis of the ACE Cable Project in Liberia has been carried out using typical, known project activities and how they interact with the environment. Impact analysis has involved impact identification and qualitative assessment using indicators. Possible impacts of the project include those arising from the with the following biophysical and social components of the environment. - Air Quality - Landscape and Visual Receptors - Noise and Vibration Receptors - Transportation - Geology and Soils - Marine Biology and Fisheries - Vulnerable Groups - Cultural Heritage - Infrastructure - Economic Activities - Solid Wastes Generation and Handling - Population - Labour

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- Occupational and Public Health

ES 8 - MITIGATION MEASURES Mitigation measures, which are actions taken to enhance positive impacts and minimize negative ones have been recommended for the ACE Cable Project.

Impact mitigation measures proffered in this report are general guidelines for dealing with the project impacts. In recommending mitigation measures and as has been considered appropriate and practical, the following principles have been taken into consideration.  Design changes  Avoidance  Preservation  Minimization  Rehabilitation  Restoration  Replacement  Resource compensation  Improvement  Development  Diversification

It is noted that the application of each mitigation measure will be affected by specifics of the project implementation and environmental and social nuances that are documented from future studies.

ES - 9 - IMPLEMENTING THE ESMF This ESMF document incorporates a number of elements into an overall Environmental and Social Management process for the ACE Project. The process involves distinct steps and associated activities that are linked to deliver a robust and veritable management framework in line with the stated objectives of the ESMF

Project Screening and Categorization The Ace Cable Project will be required to go through Environmental and Social (E&S) Screening in accordance with World Bank and the Liberian EPA procedures. The screening process will involve an assessment of the project to determine the appropriate project categorization EA and applicable World Bank environmental and social safe guards. Although it has been Categorized as B by the World Bank the project should be screened to confirm category when project details become known.

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The Screening Report will among other things, establish the EA categorization, and environmental and social performance standards applicable to a particular sub- project. All EA studies will be required to comply with the EIA procedural guidelines of the Liberia EPA.

Environmental Management Plan The Environmental Management Plan (EMP) provides the procedures and processes that will be incorporated into the CCL activities to check and continuously monitor compliance effectiveness of commitments on mitigation and enhancement measures. In addition, the EMP focuses on policy, management personnel, competence building, communications with the public and monitoring and is used to ensure compliance with statutory requirements on safety and environmental issues.

Budget to Implement ESMF To achieve the stated goals of this ESMF, it is important to identify financial resource requirements even if indicative. This ensures upfront appreciation of the financial requirements and allows early planning and budgeting accordingly.

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CHAPTER ONE BACKGROUND AND INTRODUCTION

1.1 Introduction

The Government of the Republic of Liberia (GoL) has received a Project Preparation Advance (No Q-723) from the World Bank toward the cost of the West Africa Regional Communications Infrastructure Program – Liberia Project (WARCIPLP), and intends to apply part of the proceeds for consultant services. The services include advising the Liberia Telecommunications Authority (LTA) on the necessary regulatory instruments (e.g., license, interconnection agreements, capacity sale/lease agreements) to enable the Cable Consortium of Liberia (CCL) to effectively operate the landing station and to distribute capacity on “open access” terms, as required by the Africa Coast to Europe (ACE) Construction & Maintenance Agreement (C&MA) and distribute broadband services more widely within Liberia in accordance with Government‟s policy for ICT. As part of its effort to promote regional co-operation and integration, and to create a unified economic space, Economic Community of West African States (ECOWAS) member states are committed to the development of a sustainable regional West African telecommunications market to increase connectivity through the region. The West Africa Regional Communications Infrastructure Program seeks to contribute to lowering the cost and improving quality of regional and international connectivity by facilitating i) the connection of all countries in West Africa to global broadband fiber optics infrastructure, and ii) the creation of a coordinated regional and national transmission network which would ensure that all countries in West Africa are able to connect effectively within and between national borders. The Government of Liberia in its plan to improve communication in the country and international connectivity with the rest of the world, is planning to link to the ACE submarine fibre optic cable, which is an approximately 17,000 km submarine cable system, connecting South Africa to Europe and potentially connecting up to 24 countries including a landing station in Liberia. Towards successful actualization of this goal, the government formed the Cable Consortium of Liberia (CCL) to own and operate the ACE landing station in Liberia. The benefit of the Liberia Communications Infrastructure Program (LCIP) will be significant, as a direct access to broadband will set the foundation for digital revolution. The involvement of the World Bank follows on from extensive contributions made by the Bank to date in the country and the ECOWAS Connectivity Program fits well with World Bank Group‟s (WBG) strategy in the region. The WBG is well placed to support the region and Liberia in pushing for key reforms and strategies for

1 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report harmonizing policy and regulatory frameworks, mobilizing private investment, structuring PPPs, as well as leveraging existing infrastructure investment in Africa. The IFC has gained a good reputation for its expertise in structuring PPPs for telecom transactions at both the national and regional levels.

The LCIP will have a positive impact on the overall growth of the economy. At the microeconomic levels ICT investment will reduce transaction costs, increase market coverage and competitiveness and create significant opportunities for job creation and income generation. In addition, it will foster economic growth and development through affordable, reliable and seamless regional communication (voice and data services). 1.2 Project Objective The overall objective of the project is to improve communication in the country. In order to achieve this objective, the project will focus on improved connectivity through the connection of a submarine cable communications network in the country, address missing infrastructure link, and create an enabling environment and institutional strengthening to remove existing bottlenecks. 1.3 Program Description The West African Infrastructure Program has been designed around three preliminary components:

Component 1: Infrastructure Component: Supporting Connectivity International Connectivity: International connectivity component will focus on (i) support to provide access to those countries without established access to international submarine cable connectivity and (ii) supporting countries with limited/ indirect access to have alternative access to improve terms of access to capacity and lower cost.

Regional backhaul links: The main activity of the regional backhaul links component would include leveraging cross-border alternative infrastructure, including roads, railways and power transmission infrastructure, in order to create a seamless regional transmission network and interconnect countries in West Africa. Proposed activities would include (i) Financing investment required to equip existing fiber or lay fiber on existing transmission lines, (ii) Financing additional links to national infrastructure and landing points as per detailed feasibility studies, (iii) Purchase of capacity on fiber-based transmission networks for targeted users (eg. schools, universities, hospitals, and other priority groups) with discounted capacity prices and (iv) the establishment of national and regional Internet Exchange Points (IXPs).

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National connectivity: In order to ensure the viability of international and regional connectivity initiatives, it is important to ensure adequate traffic made possible by an acceleration of national infrastructure roll-out and application building. The individual countries may not be in a position to achieve low-cost broadband access and therefore may not be in a position to advance their growth agenda and overall global competitiveness without adequate national infrastructure. This component could also include financing the purchase of capacity for targeted users (eg. schools, universities, hospitals, and other priority groups).

Component 2: Designing PPP framework and Institutional strengthening This component will focus on the transaction design and operating model for ownership and management of submarine cable landing stations and infrastructure considered in Component 1. A PPP framework will be designed to address structural and ownership questions, access and management of network, rights and obligation of different players. The PPP framework would focus on principles of open and non-discriminatory access while maximizing the role of the private sector. Significant institutional strengthening support is needed to ensure that the PPP agreements and principles are implemented effectively.

Component 3: Creating an Enabling Environment for regional and national connectivity and applications This component will focus on creating an enabling environment to (i) address policy and regulatory bottlenecks at both regional and national levels to maximize the benefits of the proposed connectivity agenda, and (ii) to enable regional e- government applications.

Implementation of the ACE Cable Project in Liberia will include a number of activities that will lead to varied project-environment interactions across biophysical and social components within the project's area of influence. Potential and associated impacts of these interactions could range from small-scale and site-specific to less localized far reaching effects.

3 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report equipment that will be laid from the junction with the main cable through territorial waters and onto the national shores.

These safeguards documents will be prepared, disclosed and consulted before appraisal. Once the specific sites and project details are known, Environmental and Social Impact Assessments (ESIAs) and Resettlement Action Plans (RAP) considered appropriate to the project area of influence will be prepared as part of project implementation but before the cable is laid.

The Liberian Telecommunications Authority (LTA) has therefore commissioned this ESMF to comply with World Bank environmental and social safe guard requirements, and the Liberian Environmental Management laws.

1.4 Structure of the Report

Chapter One – Provides the project objective and background

Chapter Two - Gives the ESMF objectives and scope of work

Chapter Three - Highlights the methodology employed to prepare this ESMF

Chapter Four – Provides an overview of National and international laws, regulations and standards that are considered relevant to the ESMF.

Chapter Five – Is the Project Description including alternatives and implementation phases

Chapter Six – Provides a general discussion of the environmental and social characteristics of Liberia with emphasis on the coastal and marine environment.

Chapter Seven – Covers the stakeholder engagement and public disclosure requirements and procedure for the project.

Chapter Eight– Is a discussion of the positive and potential adverse effects of the project

Chapter Nine – Outlines a general approach to mitigate potential adverse affects

Chapter Ten – Discusses the process and steps to implement the ESMF including required budget.

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CHAPTER TWO ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK OBJECTIVES AND SCOPE OF WORK

2.1 ESMF Objectives

This Environmental and Social Management Framework seeks to provide a clear process including action plans to integrate environmental and social considerations into the implementation of the ACE project in Liberia. The specific objectives of the ESMF are to:

 Ensure that the project is carried out in accordance with today‟s sustainable development tenets;

 Provide a structure/strategy for the integration of social and environmental consideration at all stages of the project planning, design, execution and operation;

 Ensure overall positive social and environmental impacts of the project and avoid/minimize, and manage any potential adverse impacts;

 Establish clear procedures and methodologies for incorporating environmental management requirements including stake holder engagement in the implementation of the project;

 Provide a framework for environmental and social screening, and assessment of cable construction and landing, as well as backbone and transmission telecommunications infrastructure development in Liberia;

 Provide guidelines for appropriate roles and responsibilities, and outline the necessary reporting procedures, for managing and monitoring environmental and social concerns of the project;  Determine the training, capacity building and technical assistance needed to successfully implement the provisions of the ESMF;

 Comply with regulatory and policy requirements (local and international) that are applicable to the project and individual activities;

 Provide as much information as possible about environmental and social impacts (including possible land acquisition and resettlement) at the project‟s current state of preparation;

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 Inform the project planning and design process by comparing the potential impacts of alternative locations, configurations, and construction techniques that are under consideration; and  Ensure stakeholder interaction during the project implementation to manage negative social effects . This ESMF will be used by the Liberian Telecommunications Authority (LTA) and the CCL, together with the separate report providing a Resettlement Policy Framework (RPF) for the project. The RPF provides a structure to address possible involuntary physical and economic displacement associated with the project.

2.2 Scope of Work

The Scope of Work (SOW) for the ESMF was designed to ensure attainment of the stated objectives throughout the ACE Cable project implementation. The key elements of the SOW are highlighted below.

Task 1-Project Description Will cover a brief description of the project, focusing on those aspects that could have positive or negative impacts on the natural and human environments.

Task 2 - Description of the Environment Relevant biophysical and socio economic characteristics of the project‟s area of influence will be described to provide a general overview of the project environment.

Task 3 - Legislative and Regulatory Considerations A compilation of relevant local and international legislation, including, those on environmental and social assessment, and land tenure.

Task 4 - Determination of the Potential Impacts of the Proposed Project This task covers the analysis of project-environment interactions to provide broad descriptions of the nature of potential positive and adverse effects of the proposed project. The task covers both biophysical and socio economic environments.

Task 5 - Analysis of Alternatives Typical project alternatives such as no project option, alternative technology, alternative landing site and cable routes will be discussed briefly mostly in the context of environmental and social safeguards.

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Task 5 - Identification of Mitigation and Monitoring Measures Broad recommendations will be made to mitigate to acceptable levels, identified potential adverse impacts of the project, and for enhancing positive ones.

Task 6 - Definition of Environmental and Social Impact Management Procedures, Guidelines and Responsibilities This includes scoping of the project‟s field of influence, and categorization for the purpose of Environmental and Social Impact Assessment (ESIA) using standard World Bank EIA categorization process. Additionally, the approach to environmental and social management including responsible parties, policy requirements, public consultation and disclosure, and interaction with project team will be covered.

Task 7 – Capacity Building and Training Needs Identify broad capacity building and training requirements for the implementing agency (CCL) and other relevant stakeholders to ensure adequate monitoring and enforcement of environmental standards.

Task 8- Public Consultation This activity will identify and carry out consultations with project stakeholders to ensure disclosure and elicit issues and related mitigants, as may be relevant to the ACE Cable Project Implementation. The ESMF will also provide a procedure for further consultation during the project construction and implementation phase.

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CHAPTER THREE METHODOLOGY

This ESMF has been prepared in accordance with standard procedures for environmental assessment including the applicable World Bank safeguard policies and Liberian environmental assessment guidelines. The study methodology generally followed the scope of services earlier outlined.

3.1 Data Gathering

Data gathering involved visits to various government offices, private libraries and internet searches to obtain information on: - The ACE Cable Project in general and the Liberian scope in particular; - Baseline environmental characteristics relevant to the proejct ; - Applicable local and international policies and regulations; - Lessons learned from other marine cable projects in other parts of Africa and globally; - Environmental and social impacts of marine cable laying projects and including land based interactions; and - Environmental and social management plans for marine cable laying projects.

3.2 Environmental and Social Screening Tool

To ensure the project is appropriately screened for environmental and social issues at the design stage, a check -list tool has been developed to screen each project in terms of: - Appropriate EIA category; - Applicable local and international regulations and standards (e.g., labour, pollution, occupational health and other standards); - Appropriate World Bank safe guards; - Level of stakeholder engagement (both sectoral and project level); - Existing environmental and other (e.g., pension or compensation) liabilities; and - Location sensitivities (e.g., sensitive environments and culture)

The screening tool provides necessary information to appropriately scope EIA studies.

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3.3 Environmental Impact Analysis

Since specific project details are not known at this stage, the environmental impact analysis has focused on mostly qualitative identification of a broad range of typical potential adverse impacts associated with marine based cable projects. As much as possible, the impact analysis has taken into consideration possible alternative scenarios for design, construction and operation of the project.

3.4 Mitigation Measures

Mitigation measures are often proffered to either eliminate or minimize adverse environmental and social impacts of specific actions, projects or programs while also enhancing positive effects. The approach to mitigation has been primarily preventive based on well known negative outcomes of project-environment interactions. As with the impact analysis, considerations have been given to the nuances in impacts as a result of project alternatives.

3.5 Environmental Management Plan

A critical outcome of the Environmental Assessment (EA) process is the Environmental Management Plan (EMP) document. This document describes the processes that the project implementing agency will follow to maximize its compliance and minimize harm to the environment. The EMP document also helps an organization map its progress towards achieving continual improvements. For the ACE Cable Project, an EMP framework has been provided to assure the environmental and social sustainability of the project.

3.6 Capacity Building and Training

Capacity building requirements have been dealt with at two levels. The first is the capacity building for the CCL/LTA, while the second is capacity building for other participating stakeholders. It is recognized that the nature of capacity building for each group in the second category may differ.

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CHAPTER FOUR POLICY AND REGULATORY FRAME WORK

There are a number of relevant national and international environmental policies and regulations that are applicable to the ACE Cable Project in Liberia. Some labour laws considered relevant to the project are also discussed.

4.1 National Environmental Legislation

In Liberia, there are a few National laws, regulations and standards, which seek to protect the natural environment and assure sustainable development in the country. These laws were developed relatively recently as is discussed below.

4.1.1 The Liberian National Constitution (1986)

Article 7 of Chapter II of the New Constitution of Liberia, which came into force and effect on January 6, 1986, provides for full public participation of all citizens in the protection and management of the environment and natural resources of Liberia. The constitution also encourages the government to pursue bilateral, regional and international cooperation in areas of mutual concerns. As a result, Liberia is party to some treaties and laws and a member of international and regional organizations for global protection of the environment and sustainable use of natural resources

4.1.2 The National Environmental Policy

The overall policy goal is to ensure long-term economic prosperity of Liberia through sustainable social and economic development which enhances environmental quality and resource productivity on a long-term basis that meets the requirements of the present generation without endangering the potential of future generations to meet their own needs.

Policy Statement

Environmental Protection in Liberia shall be guided by the following principles of sustainable development:

 The precautionary principle - This means that in certain cases action has to be taken without waiting for substantial proof.

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 The polluter pays principle - This means that the polluter or the person responsible for causing the environmental damage should bear the cost of repairs or protecting the environment.

 Individual responsibility - Is the responsibility of every to ensure that emission from individuals and households shall not amount to total to large volumes that will have subsequent impacts on the environment.

 Consideration for our neighbors - Each nation/individual should ensure that activities within its own boundaries do not cause harm to the environment in their neighbors/neighboring countries.

 Promoting sustainable development - Denote development that satisfies our contemporary needs without endangering the potential for future generations to satisfy theirs.

Particularly the Government will: a. Commit itself to the sound scientific and sustainable use of both renewable and non-renewable resources of the environment in the process of implementation of socio-economic national development; b. Create environment awareness among all sections of the community, including children, stressing the environment relationship to socio-economic development, and of the necessary for rational resource use; c. Develop procedures for the utilization of land resources in a manner that will ensure the maximum degree of economic value; d. Institute and implement an environmental quality control program by requiring prior environmental impact assessments for all investments that would be deemed to affect the quality of the environment; e. Institute the appropriate measures to control pollution and the importation and use of potentially toxic chemicals; f. Take appropriate measures to protect critical ecosystems against harmful effects, or destructive practices;

11 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report g. Develop and maintain a professional agency within the country to supervise, coordinate, implement and enforce procedures and legislation essential for safeguarding the environment and maintenance of sound ecological systems; h. Oblige all concerned to provide the relevant information needed for environmental protection and for the enforcement of relevant environmental regulations and legislation; i. Promote and support research programs for understanding of the different environmental zones and the factors affecting them, also for health-related environment problems, and development of appropriate technologies for sound management of the environment and use of local resources, including renewable energy resources; and j. Establish an adequate legislative and institutional framework for monitoring, coordinating and enforcing environmental programs and issues.

The fundamental goals and objectives of the National Environmental Policy shall be pursued and achieved through the harmonization and enforcement of the environment protection and management law and the implementation of national plan. The plan will attempt to provide a coherent framework for the various policy interventions necessary to safeguard the environment.

4.1.3 The Liberian Environmental Protection Agency (EPA) Act

The EPA Act of 2002 set up the agency to monitor, coordinate, supervise the sustainable management of the environment in partnership with regulated Ministries and organizations and in a close and responsive relationship with the people of Liberia. The agency is empowered to carry out a wide range of functions. Including in relation to environmental protection, advising the state, setting out policies, guidelines, regulations, monitoring, interfacing with international organisations, gathering data, developing capacity and others.

4.1.3.1 The EPA EIA Process

EPA has issued EIA procedural guidelines for Liberia. The process commences with the submission of an application to the Environmental Protection Agency (EPA) of Liberia. The application is followed by a Project Brief, providing a brief description of the project. After the screening of the document, the EPA may consider the 12 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report project as having little or no significant impact on the environment and issued a “Finding of No Significant Impact” (FONSI). However, should the EPA consider the project of having significant impacts to the environment, the agency will authorize the publication of a Notice of Intent and request for the conduct of a Scoping Study. The study will ensure early public participation in the project and narrows the issues to be addressed in an environmental impact study. A Term of Reference (TOR) to define the scope of the Environmental Impact Study (EIS) is formulated at the conclusion of the Scoping Study. The TOR is reviewed with the EPA and approval granted for the conduct of a full EIS.

The EIS will identify the nature of the project and address the nature and magnitude of the anticipated impacts of the project; predict the extent/scale/location of the impacts; Identify the timing, the stage at which the anticipated impact is likely to occur and the duration of the impact; and predict the reversibility/irreversibility of anticipated impacts. An Environmental Impact Assessment Report/Statement is submitted to the EPA for review. This document is circulated to line ministries and agencies for review. The document is subsequently reviewed through a public hearing. If the issues addressed in the document are considered inadequate, the project proponent is requested to review its study and revise the document. If the document is satisfactory, a permit is issued for the implementation of the project.

The generalized Environmental Impact Assessment of the EPA of Liberia is illustrated in Appendix 2.

4.1.4 The Land Use Act (1929)

The Act lays down the procedure for obtaining rights to any piece of land in Liberia through purchase. The Act distinguishes land in Liberia into two categories viz: the Hinterland, and the County area

4.1.5 The Liberian Labour Law

The government of Liberia, Labor Law (Title 18 and 18A), (1956 and 1989), provides guidelines, restrictions and penalties relating to recruitment, wages, hours of work and other general conditions of employment. Additionally, chapter 2d, section 74, sets the minimum age for work at 16 years. Children under 16 years are prohibited from working during the school day and may only work for wages if the employer can demonstrate that they are attending school regularly and have a basic education. Labor recruiters are permitted to hire children between 16 and 18 years for occupations approved by the Ministry of Labor.

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4.2 International Environmental Legislation

Liberia is signatory to a number of international treaties and conventions on the protection of the environment. These include those on climate, desertification, biodiversity conservation, coastlands and others. Some of the key ones are discussed while others are listed.

4.2.1 The IMO Convention for Prevention of Pollution from Ships

The IMO International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78) is the most important convention regulating and preventing marine pollution by ships. It covers accidental and operational oil pollution as well as pollution by chemicals, goods in packaged form, sewage, garbage and air pollution.

4.2.2 UN Convention on Law of the Sea

United Nations Convention on the Law of the Sea (UNCLOS), (Part XII: Articles 192 – 237) which addresses Protection and Preservation of the Marine Environment and gives basic obligations to prevent, reduce and control pollution from land-based sources; pollution from sea-bed activities subject to national jurisdiction; pollution from activities in the Area; pollution by dumping; pollution from vessels; and pollution from or through the atmosphere.

UNCLOS also introduces a number of provisions relating to limits, navigation, archipelagic status and transit regimes, exclusive economic zones (EEZs), continental shelf jurisdiction, deep seabed mining, the exploitation regime, scientific research, and settlement of disputes. The convention set the limit of various areas, measured from a carefully defined baseline.

Other conventions and their years of adoption are given in Table 4-1 below.

Table 4-1: Summary of Other Key International Environmental Agreements, Year Adopted Treaty, Convention, Regulation Ratified By Liberia Convention on Biological Diversity (CBD) The Cartagena Protocol on Biosafety to the Convention on Biological Diversity United Nations Convention to Combat Desertification The United Nations Framework Convention on Climate Change Kyoto Protocol Abidjan Convention And Protocol on Management And Protection Of Coastal and Marine Environment In the Sub-Region 14 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

Ramsar Convention On Wetlands

4.3 International Labour Laws

Liberia is party to a number of labour related conventions. The most relevant ones are highlighted in the Table 4-2.

Table 4-2 Labour Convention/Treaty Ratified by Liberia Year Adopted Seamen's Articles of Agreement Convention, 1926 (No. 22) 1977 Repatriation of Seamen Convention, 1926 (No. 23) 1977 Forced Labour Convention, 1930 (No. 29) 1931 Officers' Competency Certificates Convention, 1936 (No. 53) 1960 Shipowners' Liability (Sick and Injured Seamen) Convention, 1936 (No. 55) 1960 Minimum Age (Sea) Convention (Revised), 1936 (No. 58) 1960 Penal Sanctions (Indigenous Workers) Convention, 1939 (No. 65) 1962 Labour Inspection Convention, 1947 (No. 81) 2003 Freedom of Association and Protection of the Right to Organise Convention, 1948 1962 (No. 87) Accommodation of Crews Convention (Revised), 1949 (No. 92) 1977 Right to Organise and Collective Bargaining Convention, 1949 (No. 98) 1962 Abolition of Penal Sanctions (Indigenous Workers) Convention, 1955 (No. 104) 1962 Abolition of Forced Labour Convention, 1957 (No. 105) 1962 Seafarers' Identity Documents Convention, 1958 (No. 108) 1981 Discrimination (Employment and Occupation) Convention, 1958 (No. 111) 1959 Minimum Age (Fishermen) Convention, 1959 (No. 112) 1960 Medical Examination (Fishermen) Convention, 1959 (No. 113) 1960 Fishermen's Articles of Agreement Convention, 1959 (No. 114) 1960 Accommodation of Crews (Supplementary Provisions) Convention, 1970 (No. 133) 1978 Tripartite Consultation (International Labour Standards) Convention, 1976 (No. 144) 2003 Merchant Shipping (Minimum Standards) Convention, 1976 (No. 147) 1981 Labour Administration Convention, 1978 (No. 150) 2003

Worst Forms of Child Labour Convention, 1999 (No. 182) 2003

4.4 The Core Labour Standards

Although other labour standards exist, four labour standards are internationally accepted as the “core” labor standards (CLS).

i. Effective Abolition of Child Labor

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ii. Elimination of Discrimination in Employment and Occupation iii. Elimination of All F Forms of Forced or Compulsory Labor iv. Freedom of Association and the Effective Recognition of the Right to Collective Bargaining

The standards are a set of internationally recognized basic rights and principles at work. There is a global recognition that the CLS are generally applicable to all countries including Liberia. They do not establish a particular level of working conditions, wages, or health and safety standards to be applied internationally nor do they seek to change the comparative advantage of any country.

They are basic rights that have been repeatedly articulated in international human rights instruments and declarations, such as the Universal Declaration of Human Rights in 1948 and the Convention on the Rights of the Child, 1989.

4.5 World Bank Policies

The World Bank is committed to a number of operational and safeguard policies which aim to prevent and mitigate undue harm to people and their environment in any development initiative involving the bank. These policies provide guidelines for bank and borrower staff in the identification, preparation, and implementation of programs and projects. There are ten World Bank Environmental/Safeguard Policies. As discussed below not all these policies are triggered by the ACE Cable Landing Project in Liberia.

4.5.1 Triggered World Bank Policies

The World Bank policies that have been triggered by the proposed ACE Cable Project are:

- Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment.

This is the umbrella policy for the Bank's environmental 'safeguard policies' which among others include: Natural Habitats (OP 4.04), Forests (OP 4.36), Pest Management (OP 4.09), Physical Cultural Resources (OP 4.11), and Safety of Dams (OP 4.37)

The Bank requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus improve decision making.

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Such EA are carried out by the borrower to evaluate a project's potential environmental risks and impacts in its area of influence. The EA process analyzes project alternatives; identifies ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. The Bank favors preventive measures over mitigatory or compensatory measures, whenever feasible.

EA looks at the interaction of the project with the natural environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples, and physical cultural resources); and where applicable, transboundary and global environmental aspects.

The Bank has categorized projects based on the type of EA required.

 Category A - projects are those whose impacts are sensitive, diverse, unprecedented, felt beyond the immediate project environment and are potentially irreversible over the long term. Such projects require full EA.

 Category B - projects involve site specific and immediate project environment interactions, do not significantly affect human populations, do not significantly alter natural systems and resources, do not consume much natural resources (e.g., ground water) and have adverse impacts that are not sensitive, diverse, unprecedented and are mostly reversible. Category B projects will require partial EA, and environmental and social action plans.

 Category C - Projects are mostly benign and are likely to have minimal or no adverse environmental impacts. Beyond screening, no further EA action is required for a Category C project, although some may require environmental and social action plans.

 Category FI - A proposed project is classified as Category FI if it involves investment of Bank funds through a financial intermediary, in subprojects that may result in adverse environmental impacts.

The World Bank Pollution Prevention and Abatement Handbook describes pollution prevention and abatement measures and emission levels that are normally acceptable to the Bank. However, taking into account borrower country legislation 17 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report and local conditions, the Bank works with alternative emission levels and approaches to pollution prevention and abatement for projects. The EA report must provide full and detailed justification for the levels and approaches chosen for the particular project or site.

- Operational Policy/Bank Procedure 4.04 - Natural Habitat - seeks to ensure that World Bank-supported infrastructure and other development projects take into account the conservation of biodiversity, as well as the numerous environmental services and products which natural habitats provide to human society

- Operational Policy/Bank Procedure 4.36 - Forests. This policy aims to reduce deforestation, enhance the environmental contribution of forested areas, promote afforestation, reduce poverty, and encourage economic development.

- Operational Policy /Bank Procedure 4.11 - Physical Cultural Resources seeks to avoid, or mitigate, adverse impacts on cultural resources from development projects that the World Bank finances.

- Operational Policy 4.12: Involuntary Resettlement is concerned with situations involving involuntary taking of land and involuntary restrictions of access to legally designated parks and protected areas. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts.

It promotes participation of displaced people in resettlement planning and implementation, and its key economic objective is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement.

4.5.2 Other World Bank Policies

Other Bank policies that are not considered relevant to the ACE Cable Project are:

- Operational Policy (OP)/Bank Procedure (BP) 4.10 - Indigenous Peoples. - Operational Policy 4.09 - Pest Management. - Operational Policy (OP) 4.37 - Safety on Dams - Operational Policy (OP)/Bank Procedure (BP) 7.50 - Projects on International Waterways

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- Operational Policy (OP)/Bank Procedure (BP) 7.60 - Projects in Disputed Areas - World Bank Interim Guidelines for Addressing Legacy Issues

4.6 Adequacy Of Environmental Legislation

Sections 4.1 to 4.5 have provided an overview of existing laws, regulations and standards available in Liberia. International laws that are relevant to the ACE Cable Project were also highlighted. As is evident, there are legislative instruments to assure sustainable development in Liberia. As most of these laws are relatively recent, their adequacy and implementation performance will be evaluated over time. For now, they are considered adequate for protection of the Liberian environment and sustainability of the ACE Cable Project.

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CHAPTER FIVE PROJECT DESCRIPTION

5.1 Project Overview

The Government of Liberia (GoL) in its plan to improve communication in the country and international connectivity with the rest of the world, is planning to link to the ACE submarine fibre optic cable. Towards successful actualization of this goal, the government formed the Cable Consortium of Liberia (CCL) to own and operate the ACE landing station in Liberia. CCL is a technology company that is partly owned by the Government of Liberia, LIBTELCO, Lonestar Communications and Cellcom.

The ACE cable system will be the first international submarine cable to land in a number of African countries including the Democratic Republic of Congo, Equatorial Guinea, The Gambia, Guinea, Liberia, Mauritania, Namibia, Sao Tome and Principe and Sierra Leone. Other countries benefiting from the ACE project are Angola, Benin, Cameroon, Côte d‟Ivoire, France, Gabon, Ghana, Mali, Niger, Nigeria, Portugal, Senegal, South Africa and Spain (Tenerife).

The ACE submarine cable system is configured into 4 segments as follows:  Segment 1: Between the Penmarch (France) and the Dakar (Senegal) Terminal Stations  Segment 2: Between the Dakar (Senegal) and the Abidjan (Cote D‟Ivoire) Terminal Stations  Segment 3: Between the Abidjan (Cote D‟Ivoire) and the Santana (Sao Tome) Terminal Stations, and  Segment 4: Between the Santana (Sao Tome) and the Cape Town (South Africa) Terminal Stations (however the contract for this segment is not effective yet).

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Liberia and Sierra Leone are expected to be included in Segment 2. Liberia opted for the less costly option to have branching units which allows the cable to split while in deep sea to serve multiple countries.

Liberia‟s participation in the project is supported by the World Bank through the Bank‟s West Africa Regional Communications Infrastructure Program (WARCIP). The program aims to contribute to lowering the cost and improving quality of regional and international connectivity by facilitating: i) the connection of all countries in West Africa to global broadband fiber optics infrastructure, and ii) the creation of a coordinated regional and national transmission network which would ensure that all countries in West Africa are able to connect effectively within and between national borders. The first phase of the program will be implemented in Liberia, and Sierra Leone where there is least access to submarine cables.

Implementation of the ACE Cable Project in Liberia includes 3 distinct components; iv. A deepsea cable laying in the international waters from France to Liberia; v. a connecting cable from the submarine or deep sea cable to the shores of Liberia in Monrovia; and vi. A landing or cable station in Monrovia

5.2 Project Justification

The South Atlantic 3 (SAT-3) Cable is an existing submarine communications cable linking Portugal and Spain to South Africa, with connections to several West African countries along the route. It forms part of the SAT-3/WASC/SAFE cable system, where the SAFE cable links South Africa to Asia. Currently the SAT-3 system is the only international fibre optic cable serving the West African coast since April 2002. The landing towns and beneficiary countries include Melkbosstrand-South Africa, Luanda-Angola, Libreville-Gabon, Douala-Cameroon, Lagos-Nigeria, Cotonou- Benin, Accra-Ghana, Abidjan-Ivory Coast, Dakar-Senegal, Alta Vista-Gran Canary Island, Chipiona-Spain, Sesimbra-Portugal. Liberia could not be part of the SAT-3 system primarily because of the 14 year civil unrest, which ended in 2003.

Additionally, capacity on the SAT-3 system is severely constrained. The system currently has an overall capacity of 120 gigabits per second (Gbps). Access to the SAT-3 system is by contractual agreement and this has limited the number of telecommunication companies and other commercial businesses who wish to access the system. One effect of the SAT-3 pricing structure and the high demand for access is a relatively high price for usage.

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The project is also in consonance with Target 8.F of the UN Millennium Development Goals (MDG), which recognizes that:  Demand grows daily for information and communications technology;  Access to the World Wide Web is still closed to the majority of the world‟s people; and  A large gap separates those with high-speed Internet connections, mostly in developed nations, and dial-up users

Target 8.F therefore seeks to make available benefits of new technologies, especially information and communications in cooperation with the private sector.

5.3 Benefits of the Project

The Project will have both direct and indirect benefits as discussed below.

5.3.1 Direct Benefits

The direct benefits are those directly associated with telecommunication services and include: vi. Increase in available international transmission capacity and the lower cost for such access; vii. Faster and more reliable transmission for data and voice as a result of increased capacity and lower access cost; viii. Improved business performance while creating additional opportunities for business expansion; ix. Improved mobile telecommunications availability across the country; and x. Improved local content participation in the ICT industry, capacity building and technology transfer.

5.3.2 Indirect benefits

The indirect benefits are those derived from the direct benefits earlier listed and include: v. Better economic integration of, and cooperation among African State countries and linkage to global economy; vi. Catalyzed start-up of new businesses; vii. Support for gender-related advocacy and program activities; viii. Exchange of experience and technical expertise with international community and internally across various business sectors; iii. Expansion of technology-based into Liberia; and 22 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report iv. Employment generation and better inclusion of low-income communities in ICT education.

5.4 Cable Description

The proposed cable system will comprise an optical fibre submarine communications cable to carry telecommunications between France and Liberia. An optical fibre is a glass or plastic fibre that carries light along its length. Optical fibres are widely used in fibre-optic communication. They permit transmission over longer distances and at higher data rates than other forms of communications.

Sub-sea systems are designed to have very high resilience against failure. The most common reason for failure is through physical cable damage from shipping, particularly in shallow seas.

The construction of subsea cables varies with manufacturer and seabed conditions. Cable engineering specifications for the proposed Project will be based on cable industry standards. The diameter of subsea cables varies between 17 and 20 mm for sections without protective armor; armored cables may be as large as 50 mm in diameter. The cable consists of an inner optical fibre, surrounded by a polyethylene or fibre-glass core for strength and fibre separation. The core is normally surrounded by two polyethylene jackets and copper conductor layer and the outer layers comprise a steel wire protective armour layer and an outer protection and wire containment (polypropylene yarn). The physical cable system will comprise two fiber pairs that provide two separate bi-directional paths (i.e., one fiber in each pair carries signals in the outbound direction and the other fiber in the return or inbound direction). The cable system is likely to have a submerged or „wet plant‟ part, and a „dry plant‟ part which interfaces at proposed Landing Stations.

The ACE C&MA states that countries own their terminal landing station (segment T) as well as the „R‟ section of the respective „wet segment‟. The „wet segment‟ consists of two components: R section; and M section. R sections are sections that fall in territorial water. M sections are sections of the branch that fall in international water. Countries do not own the M section.

A summary of cable types that may be used for the ACE submarine cable route, including the stub segments, is provided in Table 5-1 below. Illustrations of typical cable designs are also shown in Figure 5-1 and 5-2.

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Table 5-1: Submarine Telecommunication Cable Types Cable type Approximate length Application Feature Double armour buried 90 km -Rocky terrain Two armour wire layers -High risk of trawler applied to core cable damage -Moderate abrasion risk -Depth to 600 m Single armour 10 km -Very rocky terrain Heavy armour wire Single armour buried 30 km -High risk of trawler layer applied to core damage cable -Depth to 1,200 m Light weight armour 10 km -Rocky terrain Light armour wire layer -Moderate risk of applied to core cable trawler damage -Depth to 1,500 m -Normally used for burial Light weight 7,150 km -Benign, sandy bottom Core cable, light -Depth to 8,000 m protection

Figure 5-1: Cable Design Types

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Figure 5-2: Modern Submarine Cable

5.5 Cable Technology

In fiber-optic communications, wavelength-division multiplexing (WDM) is a technology which multiplexes a number of optical carrier signals onto a single optical fiber by using different wavelengths (colours) of laser light. This technique enables bidirectional communications over one strand of fiber, as well as multiplication of capacity.

The term wavelength-division multiplexing is commonly applied to an optical carrier (which is typically described by its wavelength), whereas frequency-division multiplexing typically applies to a radio carrier (which is more often described by frequency). Since wavelength and frequency are tied together through a simple relationship, the two terms actually describe the same concept.

WDM systems are popular with telecommunications companies because they allow them to expand the capacity of the network without laying more fiber. By using WDM and optical amplifiers, they can accommodate several generations of technology development in their optical infrastructure without having to overhaul the backbone network. Capacity of a given link can be expanded by simply upgrading the multiplexers and demultiplexers at each end. 25 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

5.6 Repeaters and Branching Units

Repeaters are installed along the cable to boost the signal because the signal loses strength en route. Branching Units (BUs) are pieces of equipment used in submarine telecommunications cable systems to allow the cable to split to serve more than one destination.

5.7 Landing Sites

The landing site/station is where the underwater cable makes landfall. The landing or termination station can also be the point at which the submarine cable connects into the land-based telecommunication infrastructure or network.

Four options are being considered as landing site locations for the Project (Section 5- 8). One of the options - a 400m-500m stretch of land along the beach immediately south of the Ministry of Defense Headquarters in Monrovia appears to be more suitable and appealing to GoL because it is Government owned, secured (close to the Ministry of Defense) and does not require relocation and resettlement of people. Further, its use will not lead to any form of economic displacement. The final selection of a landing site will however be done once necessary consultations have been completed and clearances have been obtained.

5.8 Project Alternatives

Project alternatives are often considered to determine which location, technology process or other aspect of a project are considered best in terms of cost-benefit, overall project objectives, environmental and social sustainability. A summary of alternatives considered are discussed below.

5.8.1 Technology Alternatives

Technology alternatives considered are fibre optic versus satellite technology. Fibre optic networks have greater advantages over satellite, microwave and radio transmissions. Radio has largely been phased out due to restricted bandwidth and poor data transmission. Modern fibre optic networks transmit high volumes of voice and data traffic with higher security and reliability and at a lower cost than satellite systems. Cable also has a more dependable installation and repair record.

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Bandwidth demand, particularly as a result of internet activity far exceeds satellite capacity at the present time (Hogan and Hartson, 1999).

5.8.2 Routing Alternatives

Land-based fibre optic cables are an alternative to the proposed submarine system. In this alternative, the cable would be routed on land, generally along the coastal areas where telecommunications use is concentrated. The cable would need to be installed below ground and given the lack of existing infrastructure, this would require extensive trenching to bury the cable. The cable would also have to be installed across surface water bodies (e.g. rivers, streams, and wetlands). In practice it has been found that installation costs are higher for terrestrial systems due to the increased complexity. Further, trenching and cable laying across built up areas will result in more physical and economic displacement concerns. In addition, permitting can be more complex and time consuming and cable faults are known to be more frequent. There are other practical and security issues as well as greater potential for environmental and social impacts associated with terrestrial cable burial for a system of several thousands of kilometers. A submarine system therefore currently offers the better option.

5.8.3 Landing Site Alternatives

Landing site alternatives were evaluated for their capability to attain the project goals and objectives with very little environmental and resettlement problems, security concerns for the facility, as well as nearness to supporting facilities. Four landing site options were considered as shown in Figure 5-3.

 Option 1 – Near Ministry of Defense: This 400-500m beach stretch (see Figure 5-4) has no residents, squatters and fishing activities, but is only used by natives for soccer. It is located on the beach along the Redemption Drive, behind the Barclay Training Center (BTC), presently housing the Ministry of National Defense. Further, the area is Government-owned land and provides other facilities and space for the construction of further facilities to enhance the project. The location also has the advantage of security because of its proximity to the Ministry of National Defense and the Executive Mansion, official residence of the Present of the country. The land is owned by the GoL and clearance for its use would be sought from the Ministry of Interior.

 Option 2 - 17th Street-Sinkor Site - A portion of the beach within a well built area of Monrovia along the southern end of 17th Street, in the Sinkor area. It is approximately 30 m in width and similarly composed of sand of different 27 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

grain sizes. The site is about 300 m from an existing facility of the LTA, which formerly housed the Liberia Telecommunication Authority. The buildings along this stretch are about 40m–50m from the beach. However, the site is privately owned and situated amidst private residential structures. Further, its use may require resettlement costs, demolition of structures and the time for the exercise may prolong the project-implementation schedule. A picture of the area is shown in Figure 5-5.

 Option 3 - Fish Market Area, Sinkor - This alternative is situated along the beach in the area known as Fish Market, located in the Sinkor area. It is approximately 25m in width and similarly composed of sand of different grain sizes. Though the location seems favorable as a landing site, there are shanty structures nearby, inhabited by locals engaged in fishing activities. Their relocation and resettlement will be avoidable additional project costs while also delaying project implementation. The area is shown in Figure 5-6.

 Option 4 - Bernard Beach Area, Congo Town: This alternative (Figure 5-7) is situated in the area known as Bernard Beach, located in Congo Town, Monrovia. It is approximately 35 m in width, similarly composed of sand of different grain sizes and provides adequate space for the project objective. Though the location seems favorable as a landing site, there are swamp and marshland near, which serve as nesting grounds for marine fishes, birds and other organisms. Disturbance of this area may adversely affect the ecosystem.

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Figure 5-3: Location of Landing Site Alternatives in Monrovia

Figure 5-4: Picture of Preferred Landing Site

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Figure 5-5: Alternative Site Along 17th Street, Sinkor

Figure 5-6: Alternative Project Site around Fish Market

Figure 5-7: Alternative Project Site along Benard Beach, Congo Town

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5.9 Project Phases

The ACE Cable Project in Liberia will be implemented in the following Phases:

5.9.1 Construction Phase

This phase includes pre-installation and cable laying activities.

Pre-Installation

Pre-installation activities will include a detailed cable route survey to investigate the most cost effective and safest possible environment for the cable and prepare for its installation as well as engineering design and fabrication of the subsea equipment.

Cable Route Survey A marine geophysical and geotechnical survey will be performed to investigate the safest route for the cable system. The surveys indicate the characteristics of the sediments and presence of rocks or rock beds below the seabed that may hinder the cable burial work. The geophysical survey will be complemented by diver surveys in the area of the shore approach to the landing sites. A detailed topographic survey will be performed to assess the conditions and feasibility of the landing. A limited seabed-sampling program will also be conducted to supplement the side-scan sonar and sub-bottom profiler data in the areas where the cable will be buried.

The marine survey equipment will be capable of collecting quality bathymetry and side-scan intensity data. The survey will investigate the conditions of the seafloor and shallow subsurface layers, including sediment characteristics along the corridor and taking into consideration the seabed profile or water depth variations. The diver work will include probing of the seabed and visual recording in order to assess the feasibility of cable burial. After the detailed cable route surveys a pre- installation grapple run will be undertaken along the exact route of the cable to ensure that no debris, fishing materials or other pipelines far within the route of the cable.

Engineering and Cable Design The engineering approach and design of the cable to the deployed on the project will be designed ahead of installation using input from the from the cable route survey. Design considerations include protection options that best suit the project environment.

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Cable Installation (Trenching and Burial)

The cable will be installed using a special built ship, which accurately places cables on or under the seabed along the route determined by the pre-installation survey. Cables are typically buried under the seabed to protect the cable from fishing and other marine activities particularly in shallower waters. Backfilling and or cementing as appropriate for cable trench should be done to ensure proper burial.

Actual final depth of cable trench is confirmed after the seabed survey or geological and general condition is established. It is often recommended that the cable should be buried wherever possible to a target depth of between 0.5 m and 1 m below the seabed.

Deepwater Sections In deeper offshore sections, cables will be buried in a narrow (≤1 m wide) trench that is cut by a water jet or plough while the cable is being laid. A cable plough works by lifting a wedge of sediments just enough to insert a cable below the seabed. Examples of such ploughs are shown in Figure 5-8. The cable will be laid most probably with the aid of remotely operated vehicles (ROV).

A remotely operated vehicle (ROV) is a guided underwater robot commonly used in deepwater industries such as offshore hydrocarbon extraction. ROVs are unoccupied, highly manoeuvrable and operated by a person aboard a vessel. They are linked to the ship by a tether (sometimes referred to as an umbilical cable), a group of cables that carry electrical power, video and data signals back and forth between the operator and the vehicle. High power applications will often use hydraulics in addition to electrical cabling.

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Figure 5-8: Typical Submarine Ploughs

Shallow Waters Sections Cable installation in shallower sections will typically require trenching using a single grab dredger or similar equipment, and through the placing of the cable within the trench by divers. After the cable has been laid inside the trench, it would be covered with concrete mats and backfill materials. It is expected that this method of cable installation will only be necessary for shallow water depths where the cable burial machine or plough cannot be used.

It is noted that the best protection against external risks, such as cable damage from fishing or shipping activities, is achieved by burial. However, some seabed areas are not suitable for burial such as rocky and highly mobile sand areas. The pre- installation survey will confirm the potential threats existing in the nearshore and offshore marine environment with regard to cable burial.

5.9.2 Operations Phase

Once in place and connected, the cable system requires no intervention. Power is provided to the system through electrical connection in the cable. This also provides power to the repeaters. The electrical current is fully shielded from the environment.

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5.9.3 Repair /Recovery Activities

Cable repair and maintenance may be required as a result of damage, failure, age, redundancy or clearance of congested routes. To effect repairs on deep cables, the damaged cable is cut at the seabed and each end separately brought to the surface, whereupon a new section is spliced in. The repaired cable is longer than the original, so the excess is deliberately laid in a „U‟ shape on the seabed.

5.9.4 Decommissioning Phase

As cables reach the end of their design life or become redundant due to technological advances, their removal from the seabed or decommissioning may be considered. In the case of a buried cable, its removal may result in some disturbance or impact.

To ensure that due consideration is given to all the relevant issues it is recommended that a detailed evaluation of facility decommissioning options (options to include leaving the submarine cable in-sit) is carried out. The evaluation should consider environmental issues in conjunction with technical, safety and cost implications to establish the best practicable environmental options (BPEO) for the decommissioning of the cable.

The International Maritime Organisation (IMO) guidelines adopt the following recommendations when determining decommissioning procedures for offshore installations;  A general presumption in favour of full removal with recovered infrastructure reused, recycled or incinerated with energy recovery or disposal at a licensed site,  Exceptions to this general presumption will apply, where individual circumstances may not allow for full recovery resulting in all or part of the device remaining in situ  Installations can remain in situ where a second use had been identified and confirmed, or the process of removal presents an unacceptable level of risk to the marine environment and/or personnel involved, or made unfeasible by the occurrence of technical obstacles.

5.10 Cable Laying Personnel

The submarine cable will be laid from a purpose built ship with crew working 24 hours a day. Most of the crew onboard are required to operate at 2 or 3 shifts during the cable laying operation. The number of persons on board for staffing the

34 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report day and night shifts can range between 40 and 65, although this number varies depending on the duration of the operation and the capacity of the ship. All personnel work on board for the period from the start to the end of the work, which may sometimes be for as long as three to four months.

5.11 Project Schedule The ACE submarine cable is expected to be landed in Liberia between the last quarter of 2011 and the second quarter of 2012.

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CHAPTER SIX ENVIRONMENTAL CHARACTERISTICS OF THE PROJECT AREA

6.1 Geographical Location The ACE Submarine project will be implemented within the deep and shallow marine waters of Liberia, and a shore location along the coast of metropolitan Monrovia.

Figure 6-1: Location of Liberia in Africa

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Figure 6-2: Location of Liberia among Neighbouring Countries

Figure 6-3: Liberian Counties

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6.2 Topography

Liberia can be divided into three distinct topographical areas. Moving landward from the coast, first is a flat coastal plain which extends up to 80 km inland, with creeks, lagoons, and mangrove swamps; second, an area of broken, forested hills with altitudes from 180–370 m, which covers most of the country; and third, an area of mountains in the northern highlands, with elevations reaching 1,384 m.

The proposed project will occur in the region of Liberia known as the flat Coastal Plain. It is the land region of the country just next to the Atlantic Ocean. Indeed, the selected landing site is less than 50 meters from the Atlantic Ocean.

6.3 Geology and Soils

The project area is located in what is known as the Pan African Age Province. The rock type in this region is less than 500 million years. There is a zone of fluvial and deltaic deposit which extends from the Freeport of Monrovia. This zone comprises buff silt and sand deposits, which are characteristic of very low terrain along the coast.

The preferred landing site is composed mainly of beach sand, nearly pure white quartz sand, less than 5 meters in thickness and above sea level. The soil profile in the project area is uniform. There is mostly one unit of soil, the sandy soil

The main types of soils found in Liberia include: latosols, which are of low to medium fertility, sandy soils or regosols, which are infertile; shallow, coarse lithosols found in hilly and rugged terrain; highly fertile alluvial soils which are suitable for agriculture; and humus-rich swamp soils. In general, the soils are characterized by a shallow layer of humus content and high acidity as a result of deficiency in magnesium and calcium

6.4 Climate

As is the case with the rest of Liberia the climate of the project area is tropical and humid, with little change in temperature throughout the year. The temperature rarely exceeds 36oC (97oF) or falls below 23oC (73.4oF), with a mean annual temperature of about 26oC (78.8oF). Figure 6-4 shows a graph of the annual climate distribution of Liberia.

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(Source: Climatetemp.info) Figure 6-4: Annual Climate Distribution of Liberia

The climate of the project area is characterized by a monsoon (wet) season and a dry season. The monsoon season extends from late April through October, with the majority of the rainfall occurring between mid-April and mid-October. During this time frame the average humidity is about 82%. The dry season extends from mid- October to mid-April.

During the dry season, the average humidity is 78%; however, it may drop to 50% or lower between December and March when the dust-laden Harmattan winds blow from the Sahara. Wind velocity is greatest in the rainy season and lowest in the dry season.

6.5 Marine and Coastal Wildlife

Liberia animal life is exceptionally diverse, with a high population of species that are endangered outside the country. There are approximately 125 mammal species, 590 bird species, 165 native fish species, 74 unknown reptiles and amphibians and over 1000 described insects species in Liberia.

In December 1999, the Global Environmental Facility (GEF) funded West African Conservation priority-setting exercise for the Upper Guinea Ecosystem. The project identified Liberia as a top priority country in West Africa for conservation purposes since 41 percent of its area is designated as being of exceptionally high biological importance.

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The rich wildlife population of the coastal area is currently threatened by two major factors: first, loss and fragmentation of habitat caused by deforestation resulting from uncontrolled logging, construction of logging road network, and slash-and burn agriculture. Secondly, marine wildlife remains a critical source of protein for rural Liberians, as well as a cash income earner. Animals of all sizes and species are indiscriminately hunted and killed, caught in snares (traps) and eaten locally. Raw and smoked meats are also sent to urban centers or across the border for sale in the markets although hunting is governed by a permit system managed by the Wildlife and National Parks Division of the Forestry Development Authority (FDA). Logistical reasons and a lack of implementation and enforcement of legislation have been problematic. On the other hand, marine resources are not protected by any conservation practices or legislation. The emphasis is on fishing licensing for the sole purpose of revenue generation for the government.

6.5.1 Marine Species

Liberia is rich in marine species including mollusks and crustaceans, small mammals such as statungas, other, atilax paludinosus, dasymys incomtus, and large mammals such as cephalophus ep. Mollusks found in this habitat include crassostrea gasar clams), arca senilis (volutes), cymbium pepo, cones, cowries and conches.

These mollusks form all-important basis for fish and bird food chains as well as being a major food source for humans. Mangroves also habor some species of crocodiles and the endangered West African manatee, tichechus senegalese.

Four of the seven remaining species of marine turtles in the world can be found in Liberia where they lay eggs at selected places along the shores. The four species are the Atlantic Green Turtle Chelonian Mydas), the leather back (Dermochelys Coriacea), the Hawksbill (Eretmochelys Imbricate) and the Olive Ridley (Lepidochelys Olvacea). The Green Turtles are classified as endangered and the Hawksbill. Turtles are classified as critically endangered (WCMC, 1996). Despite international initiatives to protect these endangered species, marine turtles are still secretly hunted for food throughout Liberia. Their eggs are also collected by humans and destroyed by dogs and pigs on the beaches.

There has not yet been any fish stock assessment undertaken for the country to standardize fisheries resources.

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6.6 Threats to Coastal and Marine Resources

The coastline of Liberia is 560 kilometers long and about 58% of its population lives along the coasts. With a continental shelve area of 14,894km2 and territorial sea produces annually 7,616 metric tons of fish and 126 metric tons of mollusks and crustaceans. The coastal area consists of swamp-related vegetation, which includes mangroves forests and savannah related vegetation that extends 25 miles inland.

The coastal area and marine environments are subjected to a variety of pressures such as erosion due to sand mining, oil pollution, waste dumps, human settlement and the discharge of municipal wastes due to lack of proper water and environmental sanitation facilities.

Except for few places in southeastern Liberia, primary mangrove has been replaced by secondary ones. Much of the mangroves destruction appears to concentrate along the edges of creeks, river, and estuaries and particularly more wide spread around the large towns and cities such as Monrovia, Robertsport, Greenville, Harper and Rivercess.

The coastal ecosystem is under severe threat as a result of habitat loss and fragmentation caused by the deforestation, excessive hunting and poaching of wild animals for protein sources. Excessive hunting and poaching have eliminated most animal species especially in areas that are accessible. The deforestation has been estimated at an annual rate of 3% as a result of uncontrolled logging, shifting cultivation and establishment of plantation.

Invasive species identified in the country are the water hyacinth (Eichornia Crossipes), Nile Salad, Lececenea Leucocephalus and Chromoleana Odorata. The most offensive of these are the water hyacinth and often covers the entire surface of water bodies near towns and villages.

6.7 Governance

Liberia has a Republican form of government, similar to that of the United States of America. There are three (3) branches of government: the Executive, the Legislative and the Judicial Branches. The Legislative Branch is responsible for making law and legislations; the Judiciary is responsible for interpreting laws and operates the court systems; and the Executive is responsible for the management and enforcement of laws of the country.

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The Executive Branch is headed by the President and comprises of ministries and agencies. One of such ministries is the Ministry of Internal affairs, whose minister is appointed by the President.

Superintendent

Development Superintendent

District Commissioner

Township Commissioner Clan Chief

Paramount Chief

General Town chief

Town Chief

Figure 6-5: Flow Chart of Local Administration

6.8 Ethnic Groups

Liberia is comprised of approximately seventeen (17) major tribal groups divided into categories shown in Table 6-1. Figure 6-6 shows their distribution across the country.

Table 6-1: Ethnic Groups and Tribes of Liberia Regional Groups Tribes Mel Speaking Gola and Kissi Kwa (Kru) Speaking Bassa, Belle, Dei, Grebo, Krahn and Kru Mande-fu Speaking Gbandi, Gio, Kpelle, Lorma, Mano and Mande Mande-tan Speaking Mandingo and Vai English Speaking Descendants of the settlers

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The majority of the tribal people of Liberia emigrated from ancient empires in West Africa, namely Ghana, Songhai and Mali Empires. As these empires failed and internal and regional conflicts ensued, the tribal people migrated toward the south and settled in what is today Liberia. The English-speaking people were however descendents of former slaves brought from the United States of America

Figure 6-6: Distribution of Liberian Ethnic Groups Across the Country

While the rest of the tribal groups are spread across the country, the English- speaking people settled mainly in Monrovia and surrounding settlements and major towns along the coast.

The largest tribal group in Liberia is the Kpelle, followed by the Bassa, Grebo, Gio, Mano, Kru and Lorma. Of the approximately 3.5 million people, Montserrado and Grand Kru counties are the most populated and under populated counties with a total population of 1,118,241 and 57,913 respectively in the final census results of 2008.

Because of intermarriage and an aggressive national unification program, tribal divisions are rapidly becoming less distinct, especially around the capital. Nevertheless, there is a strong tendency among the indigenous people to preserve their tribal identities.

6.9 Culture

The culture of Liberia reflects this nation's diverse ethnicities and long history. Liberia was founded by freed slaves that returned from the United States of America and other areas. However, before the coming of the freed slaves, the land area of Liberia was inhabited by people from the ancient empires of West Africa.

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The official language of Liberia is English. There are also more than 16 indigenous languages, a few of which have their own unique alphabets. Among the most widely studied Liberian languages in schools and universities are Bassa and Vai languages and to a lesser extent, Kpelle. Loma and Mende also have their own unique alphabets but are studied less. Both languages are noted for their unique alphabets and phonetics.

The different tribal groups of Liberia have their own distinct culture. However, some cultural practices are common to many groups.

Rice is by far the most important staple of Liberians. However, as a primarily agrarian culture Liberia does produce and eat cassava, bananas, citrus fruit, plantains and coconut. Sweet potatoes and fish are are also an important part of Liberian meal.

Liberia is renowned for its detailed decorative and ornate masks, large and miniature wood carvings of realistic human faces, people, scenes of everyday life and accessories particularly combs, spoons and forks which are often enlarged sculptures. Sculptures are produced in both the countryside and cities. Due to its strong relationship with the United States, Liberia‟s culture, particularly along the coastal areas, has been influenced by American culture.

Liberia has its own ancient music and instruments. While Liberian music is part of wider West African music heritage, it is also distinct from its neighbors. Christian music is heavily influenced by its counterpart in United States regardless of region.

6.10 Religion

Liberia was established by freed slaves returning from the United States of America. Most of those returning were Christians. Upon their interaction with natives, they evangelized them, thus raising the Christian population. Interaction with European sailors and missionaries also led to Christianization of Liberia.

Liberia has always been recognized as a Christian country, but the Constitution of 1986 presents Liberia as a secular nation. Christianity of various denominations is the largest religious group in Liberia. The recent population censor of 2008 shows that of the approximately 3.5 million people, 2,975,675 or 85.6% are Christians. There are 424,685 or 12.2% Muslims, according to the report. The remaining 2% of Liberians subscribe to traditional beliefs, other religions or no religion.

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6.11 Macro Economy and Livelihood

Liberia is one of the world's poorest countries, with a formal employment rate of only 15%. Historically, the Liberian economy depended heavily on iron ore and rubber exports, foreign direct investment, and exports of other natural resources, such as timber. Agricultural products include livestock (goats, pigs, cattle) and rice, the staple food. Fish are raised on inland farms and caught along the coast. Other foods are imported to support the population.

While official export figures for commodities declined during the 1990s‟ civil war as many investors fled, Liberia's wartime economy featured the exploitation of the region's diamond wealth.

Other commodity exports continued during the war, in part due to illicit agreements between Liberia's warlords and foreign concessionaires. Looting and war profiteering destroyed nearly the entire infrastructure of the country, such that the Monrovian capital was without running water and electricity (except for fuel- powered generators) by the time the first elected post-war government began to institute development and reforms in 2006.

Once the hostilities ended, some official exporting and legitimate business activity resumed. For instance, Liberia signed a new deal with steel giant ArcelorMittal for the export of iron ore in summer 2005. But, as of mid-2006 Liberia was still dependent on foreign aid, and had a debt of $3.5 billion, which has recently been written off by international and bilateral partners.

The Liberia dollar currently trades against the US dollar at a ratio of 71:1. Liberia used the US dollar as its currency from 1943 until 1982. Liberia is trying to revive its economy post civil war. Various sanctions imposed by UN on diamond and timber exports were removed by 2007. The country has the second-largest maritime registry in the world, with some 3500 vessels registered under its flag (over 110 million gross tons).

Liberia continues to suffer with poor economic performance due to a fragile security situation, the devastation wrought by its long war, its lack of infrastructure, and necessary human capital to help the country recover from the scourges of conflict and corruption. However, since the election of the Ellen Johnson-Sirleaf government in 2005, the country has signed several multi-billion dollar concession agreements with numerous multinational corporations, including BHP Billiton, ArcelorMittal, Chevron and APM Terminals. 45 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

6.12 Health Situation

Many years of civil crisis adversely affected Liberia in various respects, including the health sector. This sector experienced extensive destruction of its infrastructure, the displacement of health personnel, the massive looting and destruction of equipment, including drugs and medical supplies.

Pervasive poverty, coupled with the effects of the war and the low level of funding of the health sector by the national government has grossly affected the level and quality of health services. This has accounted for the major causes of the country‟s high morbidity and mortality rates. The situation is worse in the rural areas, where health services have greatly deteriorated or non-existence.

The gross insufficiency of midwifery and inadequacy of medical staff, and the limited functional health facility have limited access to quality maternal and child health care services. Currently, HIV/AIDS is estimated at 8.2% of the population. Prior to 1990, the government provided about 60% of health care services with the remaining 40% being provided by religious missions and non-governmental organizations. Church-sponsored facilities were the forerunners.

Currently, non-governmental organizations (NGOs) are contributing immensely to the health sector, as the capacities of the government and religious-missions have eroded significantly due to the years of war. However, the government has begun tremendous effort to revamp the health sector with the construction of medical facilities across the country and provision of equipment and drugs.

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CHAPTER SEVEN STAKEHOLDER ENGAGEMENT AND PUBLIC DISCLOSURE

7.1 Stakeholder Identification

Stakeholder engagement has been increasingly identified as a key to business success both within private and government sectors. The IFC (2007) defines "stakeholder engagement” as a means of describing a broader, more inclusive, and continuous process between a company and those potentially impacted, that encompasses a range of activities and approaches, and spans the entire life of a project.

The LTA recognizes that stakeholder involvement is an important element of the overall Environmental Assessment process for the ACE Cable Project in Liberia, and that stakeholder identification and analysis at an early stage of a project is critical in the assessment of interests, concerns, relationships, assumptions, their level of influence and the ways in which they affect project risks.

For the ACE Project, a contemporary definition of stakeholders is used thus: those individuals or organisations, who can influence the project and who the project can impact either positively or negatively.

Through wide consultation therefore, the LTA seeks to achieve public involvement for better and more acceptable decision making especially with regard to the sustainability, scope, significance and mitigation of adverse project-impacts. Consultation and stakeholder engagement have been pursued positively with the aim of utilizing outputs to assure the overall sustainability of the project and improve environmental management planning. Additionally, it is anticipated that early consultation as embarked upon by the LTA will lay the foundation for ongoing positive relationships regarding the project, among the variety of stakeholders.

Stakeholder identification and engagement commenced early, from project conceptualization and will be continuous throughout its implementation.

A number of key stakeholders have so far been identified. They fall into various categories as shown in Table 7-1.

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Table 7-1: ACE Cable Project in Liberia - Stakeholder Categories Stakeholder Category Description Functions/Role i Federal Government Liberian Telecommunications Regulates the telecommunications industry in Agencies Authority (LTA) Liberia, issues licenses to operators, monitors their activities and advises the Minister on policy for telecommunications. Liberia Telecommunications LIBTELCO is Liberia’s National Operator and Corporation (LIBTELCO) sole licensed fixed line telephone provider in the country. LIBTELCO is the incumbent fixed lines and associated communications services provider. Corporation is part of the CCL to implement the ACE Project in Liberia Ministry of Postal Affairs Has authority over all telecommunication activities in the country. Is also the national partner, liaising with international organizations for the connection ACE Project. Supervises activities of the Liberia Telecommunication Authority (LTA), which is implementing the connection ii Ministry of Defense The ministry is responsible for the national defense and protection of the country. Any communication installation of this nature has significant effect on national security. Further, the landing site is expected to be near the ministry’s location. iv Ministry of Internal Affairs Formulates and implements policies relating to defense, security, law and order. Is also responsible for immigration. The Ministry approved the preferred landing site for the ACE Cable Project in Monrovia. Environmental Protection The principal authority in Liberia responsible Agency (EPA) for management of the environment. To coordinate, monitor, supervise and consult with relevant stakeholders on all activities in the protection of the environment and sustainable use of natural resources.

Liberian Maritime Authority Formerly Bureau of Maritime, has the (LMA) statutory mandate to Control Marine Safety & Environment. Under this mandate, the LMA has control over all coastal state obligations. Some of these activities include Marine Pollution Prevention and Maritime Security. v Financial Institutions World Bank, Liberian Banks, Provide funding and advisory services for 48 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

Financial Intermediaries aspects of the project implementation in Liberia vi Private Sector Members of the Cable Participate in the planning, decision making Consortium of Liberia and funding in relation to technical and administrative aspects of the project vii Civil Society Groups All non-market and non-state May be involved in information dissemination, (CSO) organizations and structures in organizing focus groups, monitoring project which people organize to implementation with regard to its social pursue shared objectives and interactions and benefits. ideals e.g., farmers, fishers, professional associations, Community based organizations (CBOs), religious groups, research institutions, legal practitioners and others viii The General Public Any interested or potentially Express concerns on project impacts and also affected individual or group provide suggestions on sustainable options

7.2 Stakeholder Engagement Phases

Stakeholder engagement for the project will be carried out at various levels as the project progresses. Stakeholder engagements include consultations government agencies, key individuals in the metropolis, and focus group discussions.

Planning Phase Engagement - This stakeholder engagement commenced at the project conceptualization and involved discussions among the relevant stakeholders (e.g., LTA, LIBTELCO, World Bank, EPA and CCL members) on the general technical and administrative aspects of the project, and environmental and social safeguard requirements were also covered. Meetings were also held with key officials to appreciate concerns over project implementation and issues for special focus.

Implementation Stage Consultations – This will include workshop type meetings or one-on-one interviews with key individuals to discuss overall project implementation plans including possible environmental and social interactions while also eliciting opinions and options for sustainable project implementation from meeting attendees. Consultations at this stage will cover the general public, NGOs, CSOs, opinion leaders, the EPA and others.

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7.3 General Guidelines for Stakeholder Engagement

The general approach to stakeholder consultation and engagement should be participatory and embrace the following key elements of successful public involvement in EIA.  Proper identification of stakeholders using definition provided earlier  Profiling of stakeholders including their description, and identification of key contact persons and details  Selection of suitable venue and timing for stakeholder meetings to allow and encourage participation of maximum attendance and free exchange of ideas by all stakeholders.  Provision of sufficient relevant information in an easy to understand (non technical) format.  Allowing sufficient time for stakeholders to read, discuss and provide input on the information provided.  Providing response (where available) on issues raised during stakeholder interactions and as may be necessary, committing to provide responses to un answered issues within a given time.  Obtaining feedback from stakeholders on agreed action items from earlier stakeholder engagement meetings.

7.4 ESMF Disclosure

Environmental Assessment procedures of the Liberia EPA and the World Bank require public disclosure of project details, impacts and measures to mitigate them. To this end, environmental reports for ACE Project will be made available to project affected groups, local NGOs, and the public at large. Starting with this ESMF, copies of the environmental reports on the project will be made available to the public at selected locations for information and comments. Members of the public will be notified of report displays through electronic and print media. Such notification should provide:  Title and brief description of the Project;  List of venues where the ESMF report is on display and available for viewing;  Duration of the display period; and  Contact details and procedure for comments.

The substantive project EIA will be similarly disclosed upon completion of a satisfactory report in accordance with EPA and World Bank requirements.

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CHAPTER EIGHT ENVIRONMENTAL IMPACT ASSESSMENT

This Chapter discusses the possible environmental and social impacts of the Ace Cable Project in Liberia on the biophysical and social (including health) environment. The discussion covers both positive and adverse impacts.

8.1 Positive Impacts

If successfully implemented, the ACE Cable project is set to provide a number of direct and indirect benefits to Liberia. Although anticipated benefits will be in the area of economic growth and improved human development, some environmental benefits are expected. Benefits have been discussed in Chapter 5.

8.2 Potential and Associated Adverse Impacts

Adverse impact analysis of the ACE Cable Project in Liberia has been carried out using typical, known project activities and how they interact with the environment. Impact analysis has involved impact identification and qualitative assessment using indicators. For this ESMF, quantitative impact analysis is not possible and has not been carried out.

Air Quality - Impacts to air quality may occur during cable laying as a result of combustion engines such as diesel-powered generators used for the cable laying ship and from dust if the cable is landed on shore during the dry season.

Landscape and Visual Receptors - Cable laying activities will lead to minimal increased light both in deepwaters and shallower areas.

Noise and Vibration Receptors - There may be some increased noise in the marine environment and shore landing area during construction activities. Impacts to sensitive local receptors such as nearby residences may also minimally occur due to

Protected Areas – Protected areas are locations which receive protection because of their environmental, cultural or similar value. A large number of kinds of protected areas exist, which vary by level of protection and by the enabling laws of each country or rules of international organization. Examples include parks, reserves and wildlife sanctuaries. There are no known marine or terrestrial protected areas within the project‟s area of influence

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Geology and Soils –Trenching and ploughing for cable installation will cause some minor physical impact on sea bed geology. Onshore, there will be some soil excavation over a small area around the landing site.

Marine Biology and Fisheries - Some minor disturbance to marine sediments and benthos will occur during surveys and cable installation activities as a result of coring, trenching or ploughing and when the cable is installed on the sea bed. Thes activities could lead to temporary water quality impairment which in turn affects fish and other marine biota.

Vulnerable Groups – According to the World Bank (2005), a vulnerable group is a population that has some specific characteristics that make it at higher risk of falling into poverty than others living in areas targeted by a project. Vulnerable groups include the elderly, the mentally and physically disabled, at-risk children and youth, ex-combatants, internally displaced people and returning refugees, HIV/AIDS- affected individuals and households, religious and ethnic minorities and, in some societies, women.

Cultural Heritage - There are no known sites of significant cultural heritage or archaeological interest within the project‟s area of influence both onshore and in the marine environment. Some cultural heritage could be buried and encountered during excavation on land or by trench ploughing at sea (e.g., coastal wrecks).

Infrastructure – Existing marine infrastructure (if any) such as other submarine cables and pipelines could be damaged during surveys and cable-laying if their routes are not identified a priori and avoided.

Transportation - Cable surveys and installation could lead to temporary disruption to the flow of shipping traffic and other users in the nearshore environment. Similarly, road traffic disruptions may occur during onshore based construction

Economic Activities – Marine based activities such as those to be carried out as part of the ACE Cable Project could affect fishing and other socio-economic activities if within the project‟s area of influence.

Solid Wastes Generation and Handling - Waste management is perhaps one of the most challenging environmental problems facing Liberia. In many areas, wastes are comingled and dumped indiscriminately on the road side, in open unlined dump sites, in inland and coastal waters and in constructed drainage lines. Thankfully, only minimal wastes will be generated from the ACE Cable landing project. Wastes 52 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report from marine based activities will handled in accordance with statutory shipping and maritime laws, while land based waste will require appropriate waste handling plans.

Use of Natural Resources – The ACE Cable Project will not lead to unsustainable use of any natural resources.

Population Influx - The construction phase of many projects requires a relatively large number of construction workers. Much more than urban areas, rural and peri urban areas typically feel the effects of the resulting influx of people, whose population comprises project workers and job seekers. Others are itinerant traders. Thus while there is often increased commerce around project areas, some types of infrastructure (e.g., housing, transport, health care and others) become stretched as these social services are often inadequate for the pre-project population and become even more stretched as a result of project-associated influx. Additionally, social pathologies such as crime, prostitution, erosion of traditional authority are well known risks associated with influx and so are health risks from increased communicable and non-communicable diseases and HIV/AIDS. Infractions on cultural norms and beliefs, and changes in the micro-economic structure leading to increased prices of general goods and services in affected areas have also been recorded.

Labour Relations – The ACE Cable Project will involve hiring and disengagement of workers at various stages of the project implementation. Conflicts between the project owner or contractor and locals are known to occur during project implementation. UNDP, 2006 suggests that conflicts associated with labour relations can be caused by:  Dissatisfaction among local populations on the quantum and sharing of employment; and  Disengagement of workers hired over relatively short periods (less than 0- 3years) leading to boom-bust situations Further, child labour has been observed at some construction sites while in other areas, there is discrimination against women or other ethnic groups. These practices contravene Liberian World Bank statutory requirements on labour.

Occupational and Public Health - Infrastructure projects present several occupational health hazards. The public including communities are also exposed to some of these hazards. Health hazards may be either, physical, chemical or biological. Common examples are shown in Table 8-1.

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Table 8-1: Types of Project -Related Occupational and Public Health Hazards Physical Hazards Chemical Hazards Biological Hazards Increased vehicle and boat Accidental chemical, fuel and other Release of biological accidents spills agents Increased noise - Fire and Explosions Rotating and moving equipment Environment temperature Poor ergonomics Welding/hot work Working in water bodies

Accidents cause direct impacts through physical harm to affected persons or indirectly, impairment of livelihood base as in the case of chemicals or oil spilled in farmlands and water bodies. Dependants of affected persons will also suffer if accidents result in significant time away from work. In addition, hazards leading to permanent disability or death can threaten the success or timely delivery of infrastructure projects. Adverse occupational and community health incidents can therefore lead to more costly projects with severe implications for the project owner.

Biodiversity Loss, Endangered and Exotic Species - The loss of the world's biological diversity is causing major concern worldwide (Pearce and Moran, 1994). They also suggest that the global rate of biodiversity loss is directly related to the expanding human niche. Liberia‟s rich biodiversity is currently being threatened by various factors. Exotic non-native species such as water hyacinth are also threats. Moreover, four of the globally listed endangered turtle species nest on Liberian coasts. The ACE Cable Project can further contribute to the biodiversity challenge through impacts on turtles during construction and the inadvertent introduction of non native species.

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CHAPTER NINE IMPACT MITIGATION

9.1 Introduction

Mitigation measures are actions taken to enhance positive impacts and minimize negative ones. They aim to improve the environmental and social sustainability of a project. Depending on the nature of the impact they seek to address, they can already be applied during the design, strategic planning or implementation stage of the project. To assure environmental sustainability, mitigation measures are implemented on a continuous basis through the project‟s life-cycle.

The approach to mitigating adverse impacts of the ACE Cable Landing Project in Liberia is to proactively design strategic measures which can be applied at the overall project stage and the individual project activities.

Impact mitigation measures proffered in this report are general guidelines for dealing project impacts. As has been considered appropriate and practical, the following principles have been taken into consideration.

 Design changes  Avoidance  Preservation  Minimization  Rehabilitation  Restoration  Replacement  Resource compensation  Improvement  Development  Diversification

It is noted that the application of each mitigation measure will be affected by differences in project types, and environmental and social nuances. Moreover, some measures may be too costly or completely impractical to implement under certain conditions. In pursuing any of the proffered mitigation measures, therefore, it is important for the project further assess the following:

 Feasibility;  Ease of implementation;  Local suitability; 55 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

 Institutional requirements;  Training requirements;  Monitoring requirements;  Cost (capital and operating); and  Cost-effectiveness.

9.2 Project Mitigation Principles

Chapter 8 identified a number of typical project-environment interactions associated with the ACE Project. Details of the project construction activities are not known and so the magnitude, frequency, duration and other characteristics of the interactions cannot be discussed at this stage. However, the general approach to mitigating adverse impacts will generally be similar regardless of which construction options are finally selected. Table 9-1 provides generic impact mitigation principles/measures for possible project impacts.

Table 9-1: Impact Mitigation Principles for Sub Project Activities Possible Cause of Type of Impact Impact Mitigation Principles Impact Increased Traffic Hardship to other road/waterway - As much as possible plan work for least busy users and lost productive time hours - Work with appropriate authorities to Implement traffic procedures that help reduce jams and bottle necks - Train drivers and enforce their compliance with traffic rules - Where possible, work with relevant authorities to establish effective alternative routes especially in urban areas - In rural areas, provide support to rural dwellers to reduce the burden of increased traffic - Notify other road/water way users on plans

Economic displacement - As much as possible plan work for least busy hours - Notify other road/waterway users and other affected persons of possible effects - Avoid active fishing areas - If traffic will cause sustained impacts on livelihood, compensate affected persons in accordance with the Program's Resettlement Framework Air Emissions Air Pollution - Ensure combustion engines used on the project are serviced and running efficiently - Select technologies that meet applicable air emissions standards (Liberia and World Bank)

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Table 9-1: Impact Mitigation Principles for Sub Project Activities Possible Cause of Type of Impact Impact Mitigation Principles Impact - If working during dry season, implement dust reduction procedures - If working in arid environments, implement dust reduction measures - If working with batching plants, implement suspended particle reduction procedures - Model GHG balance for carbon intensive projects - Model air quality for projects that interact significantly with air (e.g., power, oil and gas, waste management) Noise Noise Pollution/Hearing - Use combustion engines fitted with noise Impairment mufflers - As much as possible, avoid nighttime work - Erect noise barriers for projects with extensive noise - Model noise levels for project operations - Comply with applicable noise standards Solid Wastes Soil and water pollution and - Identify expected solid waste streams and odour characterize - Develop waste management plan for all solid wastes - Maintain a cradle to grave approach for solid waste - Use only approved waste management contractors - Dispose wastes only in accordance with regulatory requirements - Monitor waste handling by waste contractors Use of Natural Changes to natural resources - Consider using designs that limit use of Resources availability and supported natural resources functions - Model use of natural resources such as surface and ground water to determine safe threshold Chemical Handling Chemical pollution and health - Identify and characterize all chemicals to be hazards used during all project phases - Prohibit the use of banned chemicals e.g., - Develop and implement chemical handling and disposal plans for all chemicals - Ensure proper storage and labeling of chemicals on project sites and when being transported Labour Relations Poor wage structure, conflicts - Develop hiring and disengagement plans and boom-bust scenario for all project work in accordance with core labour standards and other applicable labour regulations - Consider local area and cultural sensitivities when hiring labour - Implement a disengagement strategy to

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Table 9-1: Impact Mitigation Principles for Sub Project Activities Possible Cause of Type of Impact Impact Mitigation Principles Impact address the boom-bust situation - Implement a grievance mechanism for labour issues Population Influx Inflation in local area, pressure - As much as possible use workers from the in infrastructure, increase in local area around the project disease burden including HIV - If project will result in significant influx, /AIDS, desecration of cultural implement influx management plan which sites, conflicts, erosion of addresses: inflation, pressure on traditional authority structure infrastructure, increase in social pathologies (e.g., crime, prostitution, increased disease burden - Provide HIV/AIDS awareness program and materials to workers and public - Give non-local area workers orientation on cultural norms - Respect traditional beliefs and festival days Occupational and Occupational and Public Health - Develop and enforce occupational Public Health Hazards health/safety policy and plans for all project activities. As may be applicable, plan should address: use of personal protection equipment (e.g., for hearing, gloves, coveralls, hard hats, safety shoes, goggles) - Monitor compliance with safety plans - Maintain applicable standards on exposure to all types of radiation - Maintain minimum life saving equipment on facility as required by appropriate law - Maintain workers health care program including clinic on or around work site - Maintain retainership for workers with well equipped hospital - Maintain signage around work areas including traffic routes for public - Regularly provide early warning to the public on movement of heavy equipment and vehicles - Maintain applicable minimum standards on distances from dwelling and work areas, for installation of various facilities - Work with minimum safety standards for fire and prevention - Maintain minimum fire fighting facilities commensurate to type of fire hazard exposure - Maintain and implement emergency contingency plan including chemical and oil spill contingency plan where applicable - Store combustible and other hazardous materials in accordance with approved procedures

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Table 9-1: Impact Mitigation Principles for Sub Project Activities Possible Cause of Type of Impact Impact Mitigation Principles Impact Biodiversity, Biodiversity loss, threat to - As much as possible, avoid critical habitats Endangered and endangered species, invasion of - If high biodiversity areas are affected, Exotic Species non-native species compensate by supporting conservation initiatives in association with locals - Develop and implement biodiversity action plan - If working around beaches, identify nesting areas and implement turtle conservation plans - Ensure visiting ships discharge ballast waters outside coastal areas Vulnerable Groups Susceptibility to increased - Identify and profile vulnerable groups in the poverty and deprivation project area - Develop plans to support vulnerable groups during project implementation Cultural Resources Desecration of cultural sites, - Identify cultural resources around project loss of cultural resources areas - Implement chance find procedure - Design and implement appropriate grievance mechanism in consultation with affected persons - Develop and implement relocation procedures in consultation with affected persons

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CHAPTER TEN ENVIRONMENTAL AND SOCIAL MANAGEMENT IMPLEMENTATION PROCESS

10.1 Overview of ESMF Implementation Process

This ESMF document incorporates a number of elements into an overall Environmental and Social Management process for the ACE Cable Project in Liberia. The process involves distinct steps and associated activities that are linked to deliver a robust and veritable management framework in line with the stated objectives of the ESMF. Table 10-1 below gives an overview of the processes, linkages and responsible parties for each element of the process.

Table 10-1: Elements of Environmental and Social Management Process

Element Chapter in Project Phase Responsible Party ESMF Report

Environmental Chapter 10 At the conceptual stage of the LTA in consultation with World Bank Screening project and Liberia EPA

Environmental Impact Chapter 10 Upon completion of negotiation CCL in accordance with minimum Assessment and tendering and after contract scope of work for EIA as agreed with and financial close-out but prior EPA and World Bank to commencement of activities.

Environmental Chapter 10 At tendering and negotiating Contractors and CCL Management Plan stage

As part of EIA for the Project

Training and Capacity Chapter 10 At the conceptual and planning LTA, EPA, CCL Building stage - Introduction to EA, Screening, Scoping and Budgeting for EIA,

Implementation stage - Monitoring and Evaluation

Monitoring and Chapter 10 Post EIA and after project LTA, EPA, CCL Evaluation commences during Project Governance

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10.2 Project Screening and Categorization

10.2.1 Categorization for EIA

The ACE Cable Project will be required to go through Environmental and Social (E&S) Screening in accordance with World Bank and the Liberian EPA procedures. The screening can be carried out by a designated officer of the LTA. The screening process will involve an assessment of the project to determine the appropriate project categorization EA and applicable World Bank environmental and social safe guards. Although it has been Categorized as B by the World Bank the project should be screened to confirm category when project details become known.

The checklist to be used for this screening is shown below. In general, if the response to two or more of the questions in the check list is yes, then the sub-project is Categorized as A and will require a full Environmental Impact Assessment. The Remarks column is used to provide additional information on the basis for the categorization.

Table 10-2: Project Categorization Checklist for EA Check Items Y N Remarks 1 Is the project situated in a sensitive environment e.g., wetlands wild lands or close to coral reefs? 2 Is the project situated in a conflict zone? 3 Will the project lead to direct pollutant discharges to air, water or land that could affect the carrying capacity of the environment (e.g., extensive air emissions, large volume of effluents, large volume of solid wastes). 4 Is the project currently or will expansion/enhancement make the project carbon-intensive? 5 Will the project result in large scale land clearing, loss/conversion of forest resources? 6 Does the project require large scale and extensive extraction of natural resources currently or in future e.g., ground water? 7 Will the project lead to involuntary physical or economic displacement? 8 Will the project affect natural biophysical processes such as hydrology and coastal dynamics? 9 Does the project generate hazardous wastes that cannot be handled locally? 10 Does the project portend significant security risks to employees or to the public?

If a sub project has been classified as A, then the LTA or sponsoring agency will be required to: i. Retain independent EA experts not affiliated with the project to carry out the EA in accordance with Liberian regulatory and World Bank EA process;

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ii. Engage an advisory panel of independent, internationally recognized environmental specialists to advise on all aspects of the project relevant to the EA if the project is highly risky or contentious or involves serious and multidimensional environmental concerns; iii. Convene an EA scoping meeting, which attendance will include EA practitioners, regulatory authorities (Federal and State), potentially affected stakeholders and selected NGOs; iv. Ensure extensive stakeholder engagement for the project. The EA process will include a stakeholder identification and engagement process; v. Ensure that all EA Reports for Category A projects are not only duly authorized by the Liberian environmental regulators but also the World Bank. vi. Ensure the EA Report includes a stand-alone Environmental Management Plan that can be implemented.

Projects that do not meet two or more of the checklist criteria in Table 10-2 will be either Category B or C Projects.

Category B Projects will result in adverse environmental impacts on human populations or environmentally important areas--including wetlands, forests, grasslands, and other natural habitats, that are less adverse than those of Category A projects. In general, such impacts are localized, do not affect sensitive area/resources, and reversible. All category B projects will also require EA. However, the scope will be reduced but the PIU will also be required to: i. Retain independent EA experts not affiliated with the project to carry out the EIA in accordance with Liberian regulatory EIA process; ii. Ensure appropriate stakeholder engagement for the project.

Category C - Projects are generally benign and typically do not require EA. However, all such progress should be screened to determine if specific environmental management plans (e.g., waste management plan) are required.

10.2.2 Applicable Standards, Limits and Permit Requirements

The project will also be screened to determine applicable occupational health, environmental and other standards. The permitting requirements to implement the project including estimated processing time will also be identified at this stage.

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10.2.3 Screening Report

At the end of the screening and scoping exercise, a Screening Report (SR) will be prepared. The report will provide the following information that will be used for decision making: - Brief description of project - Project Category for EA including rationale - Applicable World Bank Safeguards - Overview of anticipated wastes - Indicative list of stakeholders to be engaged and guidelines for engagement - Applicable environmental standards e.g., for emissions, effluents and others - Permit requirements and typical timelines for obtaining each permit - Discussion of existing liabilities including recommendations on responsibility sharing - Key environmental and social risks

The SR will be submitted to the LTA, CCL and EPA

10.3 Preparation of EIA Reports

The SR will among other things, establish the EA categorization, and environmental and social performance standards applicable to a particular sub-project. All EA studies will be required to comply with the EIA procedural guidelines of the Liberia EPA (Appendix 1).

10.4 Environmental Management Plan

This EMP provides the procedures and processes that will be incorporated into the CCL activities to check and continuously monitor compliance effectiveness of commitments on mitigation and enhancement measures. In addition, the EMP focuses on policy, management personnel, competence building, communications with the public and monitoring and is used to ensure compliance with statutory requirements on safety and environmental issues.

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10.4.1 Policy

The CCL should developed an Environmental and Social (E&S) Policy and a Sustainability Commitment which together state the their commitment to conducting business in a socially responsible and ethical manner, and to protecting health, safety and the environment. In its E and S Policy, the LTA/CCL should commit to:

i. Integrate health, safety and environmental matters into every aspect of its activities and set objectives to drive continual improvement; ii. Comply with all relevant health, safety and environmental laws and regulations; iii. Initiate and maintain effective arrangements for communication within the organisation, other agencies, public or its agents and other stakeholders regarding health, safety and environmental matters; iv. Require relevant standards, good engineering practices and principles of risk management to protect health, safety and the environment and to ensure the integrity, reliability and efficiency of all sub projects; v. Exhibit socially responsible leadership, demonstrate exemplary health, safety and environmental performance and publicly report performance; vi. Support loss prevention for assets and natural resources, and minimize the impact of sub-project activities on the environment, by ensuring EA are conducted on projects and ensuring responsible management of emissions, discharges and waste streams. This includes efficient use of energy. vii. Identify present or future potential health, safety and environmental hazards resulting from project activities, conduct risk assessments and select and implement appropriate measures to manage the risks; viii. Effectively communicate the health, safety and environmental requirements to all contractors, and require them to manage E&S in accordance with the LTA/CCL Policy; ix. Ensure conformity with this policy by a comprehensive compliance program including audits; and x. Adequately resource health, safety and environment functions in the LTA/CCL.

10.4.2 Environmental and Social (E &S) Management Department

The CCL will be required to establish an E and S Management Department that defines roles, responsibilities and authority to put into practice the PIU's policies,

64 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report including undertaking any training necessary to do so. The specific roles of the key positions in the unit are given in Table 10-3.

Table 10-3: Roles And Responsibility of Environmental and Social Management Officer Designation Functions Officer, E & S Management Department - Oversee and coordinate all activities pertaining to the Environmental and Social Management of the project; - Ultimately responsible for mainstreaming environmental and social management into all project activities in accordance with this ESMF. - Will report directly to the CEO of the CCL - Primary liaison person with other government agencies, the public and other stakeholders on environmental and social issues. - Prepare technical papers and other documentation to progress his/her functions - Identify and coordinate training programs for employees and other stakeholders - Develop effective monitoring procedure for E&S considerations Assistant Officer, E &S Management - He will support the Officer in carrying out his functions. Department - Act on behalf of the Officer in his absence - Conduct necessary research to mainstream E&S considerations into overall program activities

10.4.3 Training

The CCL shall identify, plan, monitor, and record training needs for personnel whose functions may have a direct or indirect impact on the environment or social management policy. The CCL will also ensure that all its employees have basic understanding of its environmental, social, and health policy; potential impacts of the program, their activities; roles and responsibilities in achieving conformance with the policy and procedures. This will be achieved through a formal training process. Employee training will include awareness of and competency with respect to: - Environmental Assessments - Regulatory requirements on environmental issues - Environmental due diligence

The E&S Officer is responsible for coordinating the training, maintaining employee- training records, and ensuring that these are monitored and reviewed on a regular basis. The Officer will also periodically verify that staff are performing competently through discussion and observation. 65 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

Given the nature of the environmental and social management requirements and provisions outlined in this ESMF, competencies and capacity building will be required in the following areas: - Environmental Impact Assessment Process - Basic concepts, screening, scoping, impact analysis, mitigation measure and monitoring, reviewing EIA Reports - Environmental Due Diligence - Types of due diligence, screening projects for liabilities, scoping due diligence investigations and reviewing due diligence reports - Monitoring and Evaluation - Understanding the importance of M&E in project implementation, M&E requirements for environmental and social sustainability of projects Training and capacity building may also be required for other project stakeholders.

To build the required capacity, it is critical that the CCL allocate sufficient resources to training and capacity building especially at the early stage of the project. The CCL's budget should therefore include adequate provision for training and capacity building on an ongoing basis. Budgeting should cover: - Trainer's fees - Logistics (as may be applicable) - training location, accommodation, transportation for participants and or trainers - Useful resources - Participation at seminars workshops

10.4.4 Communications

The E&S department is responsible for communications with the public and with public stakeholder organizations on environmental and social issues.

With regard to E&S issues, the department facilitates dissemination of information necessary to mitigate impacts through coordinating public notifications (e.g., meetings, media announcements, written postings) and through stakeholder interaction.

The E&S Officer is responsible for communication on all E&S issues to and from regulatory authorities. The CCL CEO is kept informed of such communications.

The E&S Officer will maintain a written register of stakeholder interactions to effectively track communications and so that commitments made to follow up actions can be tracked and implemented. This includes grievances that are also tracked through the formal grievance procedure and communications that come through other stakeholders. 66 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

10.4.5 Monitoring and Reporting

Monitoring will be conducted to assure the project‟s compliance with mitigation measures, and the effectiveness of operational controls and other measures intended to mitigate potential adverse impacts.

Periodic Monitoring Reports shall be issued by the E&S Department on compliance with mitigation measures.

10.5 Budget To Implement ESMF

To achieve the stated goals of this ESMF, it is important to identify financial resource requirements even if indicative. This ensures upfront appreciation of the financial requirements and allows early planning and budgeting accordingly.

An indicative budget (Table 10-4) has been prepared for the implementation of the ESMF bearing in mind the elements that make up the implementation process Assumptions to provide clarity on the basis of the budget have also been given. The budget covers: - Routine E & S duties of the CCL; - Capacity Building for the CCL and other stakeholders; - Engagement of Environmental and Social Specialists - Environmental Impact Assessment (EIA) Studies - Monitoring and Evaluation

Table 10-4: Estimated Annual Budget to Implement ESMF ACE Project ESMF Requirements Budget Basis and Assumptions Total Cost per Stage Annum (US$) Project Capacity Building for CCL Two Training Programs held in- 70,000 Management at Personnel country CCL

Meetings, Workshops and Four large meetings and some one 35000 Stakeholder Engagement –on-one interactions Project Planning Environmental Screening of Screening and scoping in 15000 Stage transactions accordance with EPA requirements EIA Studies Assume Category B EIA 65000 Project Monitoring Compliance with Assume monitoring at start, midway 45000 Implementation EMP and months after project Phase implementations TOTAL Estimated Budget US$230,000

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APPENDICES

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APPENDIX 1 DOCUMENTS CONSULTED

Environmental Protection Agency of Liberia (2007) - National Report on the Marine and Coastal Environment in Liberia

Ministry of Foreign Affairs Liberia (2003)- An Act Creating the Environment Protection Agency of the Republic of Liberia

United Nations Environment Program (2000) - Municipal Solid Waste Management in Liberia, Regional Overviews and Information Sources.

United States Agency for International Development (2002) -Annual Report.

UNDP (2000) - Human Development Report

UNEP (2004) - Desk Study on the Environment in Liberia

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APPENDIX 2: THE ILLUSTRATED EPA EIA PROCESS

PROPOSAL IDENTIFICATION

SCREENING

EIA REQUIRED INITIAL NO EIA ENVIRONMENTAL EXAMINATION SCOPING *PUBLIC INVOLVEMENT

IMPACT *PUBLIC INVOLVEMENT TYPICALLY ANALYSIS OCCURS AT THESE POINTS. IT MAY ALSO OCCUR AT ANY OTHER STAGE MITIGATION & IMPACT OF THE EIA PROCESS MANAGEMENT

*PUBLIC INVOLVEMENT EIA REPORT RESUBMIT INFORMATION FROM THIS PROC REVIEW ESS CONTRIBUTES TO EFFECTIVE FUTURE EIA REDESIGN

DECISION MAKING

NOT APPROVE APPROVED D

IMPLEMENTATION & FOLLOW UP

Figure A1: Illustrated Liberia EPA Process

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APPENDIX 3 GUIDELINES FOR PREPARING TERMS OF REFERENCE FOR AN ENVIRONMENTAL IMPACT ASSESSMENT (EIA) STUDY

1.0 INTRODUCTION

A Terms of Reference (TOR) is essentially a document that describes the purpose and structure of a project, committee, meeting, negotiation, study or contract. Standard EIA Process requires that project proponents prepare Terms of Reference (TOR) for projects that require Environmental Impact Assessment (EIA). The TOR should be submitted to the authorizing agency (Federal Ministry of Environment) for review and approval.

1.1 Objectives of the Terms of Reference

The TOR provides the necessary guidance for undertaking an EIA for a proposed project in accordance with the project's categorization for EIA. The basic objectives of the TOR are to:

 Define what types of information are to be presented in the Environmental Impact Assessment (EIA) Report;  Delineate the relevant issues to be discussed;  Define what studies will be performed;  Explain who will conduct the studies;  Ensure issues identified in scoping have been properly addressed in the EIA;  State when the studies will be conducted; and  Outline the basic structure of the EIA.

The contents of the TOR should include the critical environmental issues identified from the Scoping process. The format for the TOR is given in....

Scoping identifies the issues to be addressed, whereas the TOR provides a complete guidance on how to address these issues in the process of the EIA.

1.2. Appropriate Time for Developing Terms of Reference

Following the completion of Scoping, a TOR should be developed based entirely on the results of Scoping. The most appropriate time for preparation of TOR is at the feasibility and design stage of the project cycle.

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1.3. Responsibility for Developing TOR

The TOR evolves from the Scoping process in EIA. The critical issues identified during the Scoping exercise, to be carried out in EIA study, should be included in the TOR. The project proponent should prepare a TOR that both delineates the scope of the EIA and provides complete guidance for undertaking the EIA study. After approval from the authorizing agencies the TOR becomes an official document. In the EIA report review process the TOR serves as a standard document against which the subject matter covered by the EIA report will be evaluated.

2.0 CONTENT OF TERMS OF REFERENCE

The recommended content of a TOR document is as discussed in the following sections.

2.1. Name and Address of the Person/Institution Preparing the Report

This section of the TOR should provide a concise description (corporate overview) of the organization that will be responsible for carrying out the EIA. The information given will be used by the concerned agencies to evaluate the institutional capabilities for carrying out the EIA. The information should at least include:

 The name of organization, address and contact numbers (telephone, fax, e-mail, web site);  The year the organization was established; and,  The approximate number of full-time professional staff.

A similar format should be used to list any other organizations to be subcontracted by the lead organization.

2.2. General Information on the Project

This section must clearly state the objectives of the EIA, and the relationship of its results to project planning, design and implementation. It should highlight critical points in the decision making process linking environmental and social assessment and project execution.

The section will also provide brief descriptions of the various project-stages including site preparation, construction and operations. This description should include the project's:

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 Location and accessibility;  Design and layout;  Size and capacity;  Land requirements;  Raw materials;  Construction activities;  Energy and power source for construction;  Schedule;  Staffing plan;  Support facility services;  Labor requirements;  Operation and maintenance activities; and  A map showing the key project facilities around and environmental features for appreciation of the project's area of influence at a glance.

2.3 Data Required for Preparation of EIA Report and Methodology of Data Collection

The evaluation of the effects of a given infrastructure project on biophysical, social and health characteristics of the environment requires adequate knowledge of the ecosystems, including the human communities, which exist within and around project's area of influence.

Based on the outcome of the scoping exercise the TOR should therefore provide a summary of information required for the EIA and comments on data sources and how they will be used. It is important to keep the data collection well focused. The study goals should also be highlighted.

The methodologies to be used for data collection should be briefly described, together with an explanation of how precise the information needs to be for decision-making. Predictive, quantitative models and standards should be proposed wherever possible to avoid vague and subjective predictions. In addition, public involvement to focus the analysis on locally important concerns and issues, and to ensure peoples' participation, should be employed.

2.4. Policies, Laws, Rules and Directives

The purpose of this section is to establish that the organization responsible for carrying out the EIA is familiar with all of the various laws and regulations applicable to the EIA of the specific project. A summary should be made of the guidelines, procedural aspects, acts, rules, regulations and policies e.g., national and sectoral guidelines including international laws, conventions and treaties. 73 November, 2010 Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report

2.5. EIA Report Preparation Requirements

The TOR should provide the following information on the EIA Report

Timelines

Using appropriate bar graph and simple critical path chart, the proposed plan for carrying out the EIA study should be indicated so that the project will be completed within a realistic time period. The graph or chart should indicate which studies are seasonally dependent, and the time frame must match the activities to be carried out.

Estimated Budget

The total estimated cost of the proposed EIA study should be given, together with estimates of the probable costs for preparing Resettlement Action Plan (if applicable), Mitigation Plans, Monitoring Plan, Auditing Plan, and Environmental Management Plan. Roughly, the total cost for environmental integration in the project implementation can be expected to be in the range of 0.5% to 5% of the total cost of project construction which should be borne by the project proponent.

Also to be included in the budget are the costs required for various stakeholder engagement during the EIA, public hearings where applicable, notices in newspapers, and electronic media and logistic support required for conducting all stakeholder engagement and public hearings.

Specialist/Experts

Starting with the team leader, a list of the key EIA project staff should be given, together with their key qualifications and affiliations.

A description of proposed the roles of each team staff should be presented including qualification summaries. A single individual should be designated as the EIA Team Leader, to be assigned full time for the duration of the project. It is most important that the expertise of the project staff is shown to cover all of the major issues identified from the scoping exercise.

2.6 Approved Scope for the Preparation of the Report

In this section, all impacts/issues determined and approved during the Scoping exercise shall be incorporated. The section should also provide a summary of impacts identified from the scoping exercise.

The impacts should be grouped into two basic categories as follows:

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a) Biophysical b) Socio-Economic, Cultural and Health

2.7 Mitigation Measures

Based on the issues identified from the scoping exercise, the areas of focus for mitigation should be summarized, and their budgetary requirements should be estimated.

2.8 Environmental Management Plan

Following the format of an EIA report (Section 3.0) the outline of an Environmental Management Plan (EMP) considered appropriate to deal with the issues identified from the scoping exercise hould be described.

3.0 THE EIA REPORT FORMAT

A standard EIA Report format is given below.

EIA REPORT WRITING FORMAT 1. Table of contents a. Chapters and their titles b. List of maps, illustrations and figures. c. List of tables d. List of acronyms e. E.I.A preparers. 2. Executive Summary 3. Acknowledgements 4. Introduction- Background information, Administrative and legal framework, Terms of Reference. 5. Project Justification - need for the project - value of the project - envisaged sustainability 6. Project and/or Process Description - type (e.g., food processing or infrastructure) - input and output of raw materials and products - location - technological layout - production process - project construction, operation and maintenance

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- project schedule 7. Description of the Environment including data acquisition. - study approach - baseline data acquisition methods - geographical location - field data - climatic conditions - air quality assessments - noise level assessment - vegetation cover characteristics. - potential land use and landscape patterns - ecologically sensitive areas. - terrestrial fauna and wildlife - soil studies - aquatic studies, including hydrobiology and fisheries - groundwater resources - socio-economic studies - infrastructural services.

8. Associated and Potential Environmental Impacts - impact prediction methodology - significant positive impacts - significant negative impact - site preparation and construction impacts - transportation impacts - raw materials impacts - process impacts - project specific incremental environmental changes (if any) - project specific cumulative effects - project specific long/short term effects - project specific reversible/irreversible effects - project specific adverse/beneficial effects - Project specific risk and hazard assessments.

9. Mitigation Measure/Alternatives - best available control technology/best practicable technology - liability compensation/resettlement - site alternative, location/routes - no project option

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- insert a table listing impact with corresponding mitigation measures. - Compliance with health & safety hazard requirements.

10. Environmental Management Plan - scope monitoring - parameters to be monitored - methodology - monitoring schedule

11. Remediation plans after decommissioning/closure 12. Conclusions and recommendations 13. Bibliography 14. Appendices

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APPENDIX 4 LIST OF PARTICIPANTS AT STAKEHOLDER WORKSHOPS AND MEETINGS

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