Environmental and Social Impact Assessment (Esia) of the Transmission And

Public Disclosure Authorized

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) OF THE TRANSMISSION AND

DISTRIBUTION NETWORK OF THE ECOWAS- REGIONAL ELECTRICITY ACCESS PROJECT (REAP)

FROM THE SOMA SUBSTATION

Public Disclosure Authorized

SEPTEMBER, 2020 Public Disclosure Authorized

SUSTAINABLE DEVELOPMENT FOCUS (SD FOCUS) Ltd. Sahel WAIS Knowledge Campus, MDI Road, Kanifing

CONTENTS

LIST OF TABLES ...... ix LIST OF FIGURES ...... ix EXECUTIVE SUMMARY ...... x CHAPTER 1: INTRODUCTION ...... 1 1.1 Project Background ...... 1 1.2 The Project Development Objective (PDO)...... 2 1.3 Project Beneficiaries ...... 2 1.4 Rationale of the ESIA ...... 2 1.5 Objectives of the ESIA study ...... 3 1.6 Consultant Responsible for this Study ...... 3 1.7 Methodological Approach for the ESIA ...... 3 CHAPTER 2: PROJECT DESCRIPTION AND SCOPE ...... 7 2.1 Presentation of the Project Proponent ...... 7 2.1.1 Objectives of the Commission ...... 7 2.1.2. Roles and Functions of the ECOWAS Commission ...... 7 2.1.3. Organizations of the Commission ...... 8 2.2 Location of Project Sites ...... 8 2.3 Technical consistency of the works ...... 11 2.4 Description of Activities by Project Phases ...... 13 2.4.1 Description of Construction Works of the 33/30 kV Medium Voltage (MV) lines ...... 13 2.4.2 Description of Construction Works of the Distribution Sub-Stations...... 15 2.4.3 Description of Construction Works of the 400 V Low Voltage Lines ...... 16 2.4.4 Description of the Supply and Installation Works of the Last-mile Connection Equipment, including Service Drops, Prepaid Meters, and Ready Boards for LV Customers ... 17 2.5 Works Input ...... 18 2.5.1 Personnel ...... 18 2.5.2 Water ...... 18 2.5.3 Quarries ...... 18 2.5.4 Equipment ...... 18 2.6 Works Output ...... 18 2.6.1 Output from imported personnel ...... 19 2.6.2 Waste Generation ...... 19 2.7 Assessment of Project Alternatives ...... 19

CHAPTER 3: RELEVANT NATIONAL AND INTERNATIONAL POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK ...... 25 3.1 Relevant National Policies ...... 25 3.2 The National Legal Framework ...... 28 3.3 Relevant International Conventions and Agreements ...... 31 3.4 Institutional Framework ...... 31 3.5 Institutional Analyses ...... 33 3.6 Relevant Bank Policies ...... 33 3.7 Relevant ECOWAS Environmental and Social Safeguards triggered by the Project . 34 CHAPTER 4: DESCRIPTION OF THE CURRENT STATE OF THE ENVIRONMENT OF THE PROJECT AREA ...... 36 4.1 Geographical and administrative location of the project area ...... 36 4.2 Delimitation of the Study Area ...... 36 4.3 Current State of the Environment of the Indirect Areas of Influence ...... 38 I. The Physical Environment ...... 38 Climatic Conditions ...... 38 Hydrology ...... 39 Topography and Land Use...... 40 II. The Biological Environment ...... 41 The Vegetation and Forest Resources...... 41 Wetlands Along the Corridors ...... 43 The Fauna ...... 45 Aquatic Vertebrate ...... 47 III. Human and Socio-economic Environment ...... 49 Demography and Population Along the Line Corridors ...... 49 Physical Structures ...... 50 Schools and Other Infrastructure ...... 50 Chance Finds and Cultural Heritage and Archaeology ...... 50 Disadvantaged and Vulnerable Groups ...... 52 Gender and Gender-Based Violence (GBV) ...... 53 Violence Against Children (VAC) ...... 54 Access of the Population to Education and Security Services ...... 55 Access of the Population to Health...... 55 Access of the Population to Electricity, Telephone Sevices ...... 55 Modes of Subsistence and Daily Chores in the Project’s Area of Influence ...... 55 Agricultural Production ...... 55

Market Gardening ...... 57 Marketing and Petty Trading and Shop keeping ...... 57 Welding and Carpentry and Youth Employment ...... 58 Harvesting Non-wood Forest Products ...... 59 Firewood Collection ...... 59 Livestock Rearing...... 59 Fishing ...... 60 4.4 Description of the Direct Influence Area and Location-Specific Baseline Conditions ..... 60 4.5 Main Stakes and Risks of the Project ...... 60 CHAPTER 5: PUBLIC CONSULTATION ...... 64 5.1 Objectives of the consultation ...... 64 5.2 Methodological Approach ...... 64 5.3 Targeted Groups ...... 65 5.4 Opinions, concerns and fears of populations and PAPs ...... 67 CHAPTER 6: ANALYSES OF POTENTIAL IMPACTS, ENHANCEMENT AND MITIGATION MEASURES.. 68 6.1 Methodological Approach ...... 68 6.1.1 Identification of the Main Sources of Potential Impacts of the Project on the Environment ...... 68 6.1.2. The Environment and Social Components Affected by the Project ...... 69 6.1.3 Identification of Potential Impacts ...... 69 6.2 Evaluating the Significance of Potential Impacts ...... 71 6.2.1 Nature of an Impact ...... 71 6.2.2 Types of Impacts ...... 71 6.2.3 Evaluation of Impact Severity / Significance ...... 71 6.3 Potential Impacts of the Pre-construction Phase ...... 72 6.3.1 Potential Positive Impacts on the Biophysical Environment ...... 72 6.3.2 Potential Negative Impacts on the Biophysical Environment ...... 72 6.3.3 Potential Positive Impacts on the Human Environment ...... 76 6.3.4 Potential Negative Impacts on the Human Environment ...... 76 6.4 Potential Impacts of the Construction Phase ...... 78 6.4.1 Potential Positive Impacts on Biophysical Environment ...... 78 6.4.2 Negative Impacts on the Biophysical Environment ...... 78 6.4.2.8 Impacts related to the Importation of Workers ...... 80 6.4.4 Negative Impacts on Human Environment ...... 81 6.5 Potential Impacts of Operation and Maintenance ...... 83 6.5.1 Positive Impacts on Biophysical Environment ...... 83

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6.5.2 Negative Impacts on the Biophysical Environment ...... 83 6.5.3 Potential Positive Impacts on Human Environment ...... 85 6.5.4 Potential Negative Impacts on Human Environment ...... 86 6.5.4.1 Risks to Public Health and Safety ...... 86 6.6 Impacts of Decommissioning and Dismantling ...... 86 6.6.1 Potential Positive Impacts on Biophysical Environment ...... 86 6.6.2 Negative Impacts on Biophysical Environment ...... 86 6.6.3 Potential Positive Impacts on Human Environment ...... 87 6.6.4 Negative Impacts on Human Environment ...... 87 6.7 Cummulative Impacts ...... 87 CHAPTER 7: MANAGEMENT MEASURES OF THE POTENTIAL POSITIVE AND NEGATIVE IMPACTS ON THE ENVIRONMENT ...... 89 7.1 Enhancement Measures for Potential Positive Impacts ...... 89 7.1.2 Enhancement Measures for Positive Impacts During Pre-construction Phase: Human Environment ...... 89 7.1.3 Enhancement Measures for Positive Impacts During Construction Phase: Human Environment ...... 90 7.1.4 Enhancement Measures for Positive Impacts During Operation Phase: Biophysical Environment ...... 90 7.1.5 Enhancement Measures for Positive Impacts During Operation Phase: Human Environment ...... 90 7.1.6 Enhancement Measures for Positive Impacts During Decommissioning Phase: Biophysical Environment ...... 91 7.2.1 – Mitigation Measures of the Negative Impacts on the Biophysical Environment ...... 92 7.2.2 Mitigation Measures of the Potential Negative Impacts on the Human Environment ... 96 7.3 Potential Impact management during the construction phase ...... 101 7.3.1 Mitigation Measures of the Potential Negative Impacts on the Biophysical Environment ...... 101 7.3.2 Mitigation Measures of the Negative Impacts on the Human Environment ...... 104 7.4 Impact Management during the Operation and Maintenance Phase ...... 108 7.4.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment ...... 108 7.4.2 Mitigation Measures of the Negative Impacts on the Human Environment ...... 109 7.5 Impact Management during the Decommissioning Phase ...... 110 7.5.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment ...... 110 7.5.2 Mitigation Measures of the Negative Impacts on the Human Environment ...... 112 7.6 Mitigation of Potential Cumulative Impacts ...... 115 CHAPTER 8: MANAGEMENT OF RISKS AND ACCIDENTS ...... 116

8.1 Methodological Approach for Hazards and Risks Identification ...... 116 8.1.1 Objectives of the Risk Assessment and Management ...... 116 8.1.2 Methodology ...... 116 8.1.3 Risk Identification ...... 117 8.2 Risk Analysis ...... Error! Bookmark not defined. 8.3 Mitigation of Risks ...... 145 8.4 Training ...... 145 8.5 Emergency Response in Case of Incidents ...... 145 8.6 Health and Safety Reporting and Recording ...... 146 8.7 Health and Safety Monitoring ...... 146 CHAPTER 9: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ...... 147 9.1 Objectives of The ESMP ...... 147 9.2 ESMP Implementation and Monitoring Arrangements ...... 147 9.2.1 Roles and Responsibilities for ESMP Implementation ...... 147 9.2.2 Specific Roles and Responsibilities of Project Personnel ...... 149 9.2.2 Institutional Training and Sensitization ...... 151 9.2.3 Monitoring ...... 154 9.2.4 Reporting ...... 159 9.2.5 Environmental Auditing ...... 159 9.2.6 Budget for Implementation of the ESMP ...... 159 9.3 Matrix on the Mitigation of the Identified Potential Negative Impacts ...... 160 CONCLUSION ...... 152 BIBLIOGRAPHY ...... 153 APPENDICES ...... 155 Appendix 2.1: Soma Feeder 1. Sheet 1 ...... 155 Appendix 2.1: Soma Feeder 1. Sheet 2 ...... 156 Appendix 2.1: Soma Feeder 2. Sheet 1 ...... 157 Appendix 2.1: Soma Feeder 3. Sheet 1 ...... 158 Appendix 2.1: Soma Feeder 3. Sheet 2 ...... 159 Appendix 2.1: Soma Feeder 4. Sheet 1 ...... 160 Appendix 2.1: Soma Feeder 4 Sheet 2 ...... 161 Appendix 4.1: Communities Along the Soma Feeders ...... 162 Appendix 4.2: List of Corridors under the Soma Substation Feeders ...... 169 Appendix 4.3: Location-Specific Baseline Environmental Conditions ...... 171 Appendix 4.3: Chance Find Procedures ...... 199 Appendix 5.1: Summary of Comments and Views expressed at the Consultations ...... 200

Appendix 5.2: List of Persons Met ...... 209 Appendix 6.1: Codes of Conduct and Action Plan For Implementing ESHS and OHS Standards, and Preventing Gender Based Violence and Violence Against Children ...... 223 Appendix 7.1: The Existing Memoradum Between NAWEC and the Department of Forestry ...... 246 Appendix 7.2: Technical Note: Public Consultations and Stakeholder Engagement in WB- Supported Operations when there are Constraints on Conducting Public Meetings ...... 253 Appendix 8.1: Contract Clauses to be Included in Contractors’ Agreements ...... 263 Appendix 9.1: Modalities of the Proposed Grievance Redress Mechanism ...... 268 Appendix 9.2: Flow Chart of Grievance Redress Process ...... 269

ABBREVIATIONS AND ACRONYMS

AOI Area of Influence BF Brikama Feeder CBD Convention on Biological Diversity CCD Convention to Combat Desertification CEDAW Convention on the Elimination of All Forms of Discrimination Against Women CRR Central River Region CRR-N Central River Region-North CRR-S Central River Region-South DSA Deep Sandstone Aquifer DOF Department of Forestry DPWM Department of Parks and Wildlife Management DPPH Department of Physical Planning and Housing DWR Department of Water Resources ECOWAS Economic Community of West African States ECOWAS-REAP ECOWAS Regional Electricity Access Project ECREEE ECOWAS Centre for Renewable Energy and Energy Efficiency ERERA ECOWAS Regional Electricity Regulatory Authority ESHS Environmental, Social, Health and Safety EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental Safeguards Specialist GBOS Gambia Bureau of Statistics GBV Gender-Based Violence GD Geology Department GEAP Gambia Environment Action Plan GERMP Electricity Restoration and Modernization Project GIS Geographic Information System GoTG Government of The Gambia GPS Global Positioning System GRM Grievance Redress Mechanism HIV/AIDS Human Immune deficiency Virus/Acquired Immune Deficiency Syndrome IDA International Development Association IUCN International Union for Conservation of Nature KV Kilovolts LHS Left Hand Side LRR Lower River Region Ltd. Limited LV Line Low Voltage MOE Ministry of Energy MOLRG Ministry of Lands and Regional Governments M&ES Monitoring and Evaluation Specialist MV Line Medium Voltage NEA National Environment Agency

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NRA National Roads Authority NAWEC National Water and Electricity Company NBR North Bank Region NCAC National Council for Arts and Culture NEA National Environment Agency NEMA National Environment Management Act NNP Niumi National Park OHS Occupational Health and Safety OMVG Organization pour la Mise en Valeur du Fleuve Gambie (French acronym for Gambia River Basin Development Organization) OMVS Organisation pour la Mise en Valeur du Fleuve Sénégal (French acronym for Senegal River Basin Development Organization) OP Operational Policy PC Project Coordinator PDO Project Development Objectives PE Power Engineer PIU Project Implementation Unit PSC Project Steering Committee PURA Public Utility Regulatory Authority RAP Resettlement Action Plan REAP Regional Electricity Access Project RHS Right Hand Side ROW Right of Way SD Focus Sustainable Development Focus SEA Sexual Exploitation and Abuse SF Soma Feeder SH Sexual Harassment SOP Series of Projects SSA Shallow Sand Aquifer SSS Social Safeguards Specialist STD Sexually Transmitted Diseases STI Sexually Transmitted Infections STS Standard Transfer Specification T&D Transmission and Distribution TAC Technical Advisory Committee Tee-off A branch-off point of an MV Line ToR Terms of Reference UN United Nations UNESCO United Nations Educational, Scientific and Cultural Organisation UNFCCC United Nations Convention on Climate Change URR Upper River Region VAC Violence Against Children WAPP West African Power Pool WB World Bank WCR West Coast Region

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LIST OF TABLES Table 3.1: Relevant National Policies Table 3.2: The Legal Framework Relevant to the Project Table 3.3: Relevant Regional and International Conventions Signed/Ratified by The Gambia Table 3.4: Institutional Framework Table 3.5: World Bank Environmental and Social Safeguards Relevant to the Project Table 3.6: ECOWAS Safeguard Policies Triggered by the Project Table 4.1: Project Affected Districts Table 4.2: Recorded Annual Rainfall in Project Regions (mm) 2009-2018) Table 4.3: The Mangrove Vegetation Along some of Proposed Corridors Table 4.4: Vegetation Found in Wooded Savannah along the Project Corridors Table 4.5: Fruit Trees along the Corridors Table 4.6: Mammalian Fauna Found Along the ECOWAS-REAP Corridors Table 4.7: Avifauna Found Along the Corridors and in Nuimi National Park Table 4.8: Families of Fish Occurring at Nuimi National Park Table 4.9: Reptiles Found in the Niumi National Park and Along the Corridors Table 4.10: Soma Feeders 1- 4: Communities Along the Transmission Corridors Table 4.11: Farming Calendar of Activities along the Transmission Line Corridors Table 4.12: Main Stakes and Risks of the Project Table 6.1: Main Sources of Potential Impacts of the Project on the Environment Table 6.2: Environment Components likely to be affected by the Project Table 6.3: Identification of impacts Table 7.1: Recommended Minimum Clearance Distances for Various Sites Table 8.1: Risk identification matrix Table 8.2: Risk evaluation / rating Table 9.1: Summary of Roles and Responsibilities in ESMP Implementation Table 9.2: Capacity Enhancement Program for Effective ESMP Implementation Table 9.3: ESMP Monitoring Program Table 9.4: Estimated Budget to Implement the ESMP Table 9.5: Potential Impacts and Corresponding Mitigation Measures

LIST OF FIGURES Figure 2.1: ECOWAS-REAP Substation and Line Corridors in LRR, NBR, and CRR Figure 4.1: ECOWAS – REAP: Administrative Locations and Areas of influence of Soma Feeder Lines Figure 4.2: Wetlands along the Njau Sawalo/Chamen Carols Wharf Corridor Figure 4.3: Appropriate pole construction methods in wetlands Figure 4.4: Map of the Niumi National Park: Land Use/Land Cover Figure 4.5: Stone Circles at Kerr Batch on the Chamen-Nyanga Bantang Corridor Figure 4.6: The Core Area of the Stone Circles at Kerr Batch, CRR-N Figure 4.7: Illustration of farm boundary away from the road Figure 4.8: Melon plantation (outside Project area) illustrating position of pole and farm clearance from the road and line corridor Figure 4.9: Market Sheds and Stalls at the Weekly Market in Nyanga Bantang in CRR-N Figure 4.10: Photo of the Wassu Workshops Figure 5.1: Meeting with the Community of Tambana in Jokadou, NBR Figure 6.1: Example of stockpiles with green background (for a current road project) within this Project's AoI Figure 6.02: Combination of poles and cables around the Brusubi substation (outside this Project’s AoI) Figure 6.2: Combination of poles and cables (MV and LV poles; street light poles, Advertisement Boards) across the highway from Brusubi substation (outside this Project’s AoI)

EXECUTIVE SUMMARY

Background This report is the Environmental and Social Impact Assessment (ESIA) of the four Economic Community of West African States Regional Electricity Access Project (ECOWAS-REAP) feeders that emanate from the Soma Sub-Station under the Gambia River Basin Development Organization, (OMVG) Energy Project. The REAP Project is part of a Series of Projects (SOP) being implemented within the ECOWAS region, with a long-term view to achieving electricity distribution expansion within the Region.

Funded by the IDA/World Bank, the SOP aims to increase the number of people in West Africa with access to reliable and affordable electricity, as articulated in the ECOWAS White Paper of 2006 for Increasing Access to Energy Services to People of the Sub-region. The SOP consists of two Phases, which plan to provide 2.5 million people across six countries in West Africa, namely Guinea-Bissau, Niger, Mali, Senegal, Mauritania, and The Gambia with electricity. Phase I of the SOP is to provide access to 1.1 million people in Guinea-Bissau, Mali, and The Gambia. This Phase will finance the expansion of Medium Voltage (MV) and Low Voltage (LV) networks from the two high-voltage 225/33 kV substations (in Soma, Lower River Region–LRR, and in Brikama, in West Coast Region–WCR) being built under the OMVG Energy Project in The Gambia. It is expected that this will transform the power sectors of these countries and enable them to achieve their common objective of delivering more power to more consumers. The second Phase of the SOP will finance the reinforcement and extension of a similar distribution network (MV and LV) in Senegal, Niger, and Mauritania, and within the context of the ECOWAS White Paper of 2006, additional member countries will be included later (potentially through additional financing). The participating countries will benefit from attracting larger contractors to ensure timely implementation, and furthermore, the regional approach facilitated by ECOWAS will be used to disseminate lessons learned from the World Bank’s global access experiences, which will be shared with participating countries to implement the access agenda. Description of the Project In The Gambia, the geographical extent of the Project covers a maximum of 100 km radius from the OMVG Energy Project’s substation in Soma in Lower River Region (LRR). With the construction phase estimated to be done in about 18 months, the scope of the works will include:

1. construction of 33/30 kV Medium Voltage (MV) lines;

2. construction distribution substations of 33/30 kV / 400 Volts (V);

3. construction of 400 V Low Voltage (LV) lines;

4. supply and installation of last-mile connection equipment, including service drops, prepaid meters, and ready boards for LV customers.

Policy, legal and institutional framework

The National Policy Framework

The policies that will guide the implementation of the Project include the following:

i. National Development Plan (2018-2021) ; the principal national policy plan which proposes to increase the national coverage of electricity in the country;

ii. National Energy Policy (2014 – 2018) which aims Policy aims to increase electricity coverage nationally;

iii. Gambia Environment Action Plan, GEAP (2009-2018): Provides guidance in general environmental planning and natural resources management;

iv. The National Electricity Road Map (2017-2021 Road Map): It plans to improve power generation and transmission capacity of the National Water and Electricity Company (NAWEC). In addition, it aims to increase absorption capacity for the expected increase in generation capacity, and to reduce transmission and distribution losses;

v. Forestry Policy (2010-19) and the National Biodiversity Strategy and Action Plan (NBSAP), 2015 both of which promote State and community forest and biodiversity management.

The Legal Framework

This includes the following:

i. National Environment Management Act, 1999 - the principal legislation in environmental management; Part V of Act provides for certain projects listed under Schedule A to be considered for ESIA, and it includes this Project;

ii. Environmental Quality Standards Regulations 1999 sets the standards in Schedule 1 in respect of ambient air, saline waters, surface fresh waters and groundwater;

iii. Biodiversity and Wildlife Act, 2003: provides for the establishment of protected areas for protection of in-situ biodiversity; in addition to protect ex-situ biodiversity;

iv. National Council for Arts and Culture Act, 2003 Act protects and preserve, restore any monument, relic, ethnographical article, or other article of archaeological ethnographical, or historical relevance. Project activities could unearth objects of historical relevance;

v. Land Acquisition & Compensation Act, 1990: Provides for consultation, resettlement, and compensation of land.

World Bank Safeguard Policies Triggered by the Project

These include:

i. OP 4.01 Environmental Assessment (including public participation and stakeholder engagement). The objective of this policy is to ensure that projects financed by the Bank are viable and environmentally feasible. It covers the impacts on the physical environment (air, water and land, etc.); the living environment, health and safety of populations; physical cultural resources; and environmental concerns at cross-border and global level;

ii. OP 4.04 Natural Habitats: Aims at protection, maintenance, rehabilitation of natural habitats and their functions. There are swamps, wetlands, and waterbodies along the Project corridor that are home to various invertebrates, mammalian, including avian fauna;

iii. OP 4.11 Physical Cultural Resources: Avoid or mitigate adverse impacts on physical cultural resources;

iv. OP 4.12 Involuntary resettlement of populations: Aims to avoid involuntary resettlement, where feasible, or at least minimize it. Where it is not feasible to avoid resettlement, a RAP should be developed providing sufficient investment resources to enable the persons displaced by the project to share in project benefits, among other things.

v. OP 4.36 Forests: This Policy aims to harness the potential of forests to reduce poverty in a sustainable manner, integrate forests effectively into sustainable economic development, and protect the vital local and global environmental services and values of forests. The Project is challenged by this OP as there are Forest Parks, and Community Forests that may be affected by its implementation.

Institutional Framework The institutional framework relevant to the implementation of this Project includes the following:

i. National Environment Agency: The NEA enforces the NEMA, 1994 and EIA Regulations 2014, and reviews the ESIA report to grant Environmental Approval for the Project;

ii. National Water and Electricity Company (NAWEC): Project Proponent, and will lead implementation of ESMP;

iii. Women’s Bureau-Under the Ministry of Women, Children and Social Welfare, specifically promotes gender equity and women’s empowerment in The Gambia. It ensures the rights of women affected by the Project are protected; participates in sensitization on gender issues during pre-construction, construction, and operation phases;

iv. Department of Social Welfare: Protects and promotes the rights of vulnerable people such as children, women and the disabled; supports and guides the process during related grievances; participates in sensitization on GBV, SEA, SH, VAC, etc.;

v. Department of Labor: Enforces employment laws to protect employee rights, protect against child labour, and respond to complaints and reports such as accidents, abuse, and discrimination at work.

Description of the baseline environmental and social issues

The Biophysical Environment

Climatic Conditions

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The climatic condition in The Gambia is of the Sudano-Sahelian type and is characterized by the occurrence of two distinct seasons: a hot rainy season from May/June to October, and a dry season from November to May with rare occurrence of rainfall in May. Rainfalls are typically heavy nationally, but the south-western part of the country records more rain than the eastern portion. July, August, and September are the highest rainfall months.

Hydrology

Surface Water The surface hydrology within the Project’s sphere of influence is mainly the River Gambia, which gets its source from the Fouta Djallon Highlands in Guinea, flowing westward towards the Atlantic Ocean, via communities in which the Project will be implemented. A mosaic of tributaries has branched off from the main river system and have become major areas of economic activity for the riparian populations through which the tributaries and streams pass.

Along some of the proposed line corridors of the Project, are permanent “bolongs” (“bolong” is Mandinka meaning tributary) and seasonal freshwater lakes. In Nianija District, in CRR-N these include the Nianija and Nianimaro “bolongs” which are permanent tributaries originating from the River Gambia.

Another surface water source is the run-off and storm water during the rainy season which runs into tributaries and adjacent fields. Pole construction in swampy areas, or along pathways of storm water could potentially impact transmission poles.

Groundwater Resources Within the Project sites the ground water is tapped mostly from two main groundwater sources namely, the Shallow Sand Aquifer (SSA) and Deep Sandstone Aquifer (DSA), (the former is essentially where the local hand dug wells tap their supply along the route of the project).

The Vegetation and Forest Resources

The following vegetation types are found along the proposed line corridors: Riparian Vegetation This vegetation type is found along corridors with swampy and marshy environment such as the wetlands of the Nianija “bolong” (at the Chamen bridge on the Njau/Carols Wharf corridor) in CRR-N), and the Nianimaro “bolong”, (specifically near the “loumo” site at Nyanga bantang, where the “bolong” crosses the road alignment. The vegetation within these areas includes reeds, shrubs, and herbaceous plants; it is likely that some parts of these habitats and vegetation will be affected by the line routing which will be close to the road alignments.

Mangrove Vegetation One of the main habitat types along some of the corridors is the mangrove habitat; it is found within the Nuimi National Park (NNP) in Lower Nuimi, NBR, and along the Nianija and Nianimaro “bolongs” in CRR. Mangrove forest dominates the “bolong” fringes within the NNP occupying a total area of approximately 800 ha. The species found are the red mangrove (Rhizophora spp.), and the white mangrove (Avicennia sp.). There is also the salt tolerant species such as the bitter leaf (Vernonia colorata).

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The Wooded Savannah The wooded savannah (with a canopy cover of more than 40 percent and reaching a height greater than 8 m) and is found along most of the proposed corridors. The dominant species found within these vegetation types are the African locust beans (Parkia biglobosa), and the rose wood (Pterocarpus erinaceus). Shrubby species found include the bush willows (Combretum nigricans), and the Chinese date (Ziziphus mauritiana).

On the sandier soils, the woodland has a higher incidence of Parinari macrophylla (commonly called gingerbread plum), Ficus spp (fig trees) and Tamarindus indica (the Tamarind). Other forest trees along the corridors include the baobab (Adansonia digitata), which is planted for its shade as well as for food; its fruits are eaten and have certain uses as medicine; its leaves are used as vegetables, for sauces; its bark can be used as rope for tethering cattle.

Fruit Trees Fruit trees are planted along the proposed line trajectories outside private compounds aligning the road corridors, or within compounds, or are planted as orchards and fenced and well protected from stray animals. Typically, mangos and cashew trees are the main fruit trees that will be potentially impacted by the lines because they are planted along many of the proposed corridors including the Sabach Sukoto-Mballow Omar Tega corridor in Upper Badibu, NBR.

These trees are important as a source of supplementary food for families, and in some instances, the fruits provide cash to the owners when harvested and sold at the local “loumo”. Mangos also provide shade for family and individual relaxation. Thus, felling the trees by NAWEC’s contractors to make way for the lines could deprive these families of both food and income sources.

In the country, many trees along existing transmission line corridors (including those located within natural forests) are usually affected by NAWEC transmission lines. They are pruned by NAWEC (especially before the rains) when the branches grow too close to the lines, rather than felling the whole tree. This practice is repeated periodically as the trees regenerate new branches that threaten the lines.

It is not uncommon also that whole trees are felled to make way for transmission lines, and this could include both private fruit trees and forest trees located along the trajectories of the lines. Private trees should not be impacted (pruned or felled) without the consent of the owners, and indeed where they must be impacted, a RAP should be developed to address any potential social impacts.

The Fauna The faunas along the various corridors are described below.

Mammalian Fauna The mammalian fauna along the numerous line corridors is generally influenced by the open forests, which are home to various invertebrates, reptiles and mammalian species. The mammalian fauna of NNP is relatively rich and is influenced heavily by the fairly undistributed habitats of parts of the park, such as southern Jinack.

Among the primates are the red colobus monkey, and the Guinea baboon, the former is in the International Union for Conservation of Nature (IUCN) Red List; the clawless otter and the West

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African manatee are also in the Red List. The baboon is generally regarded as a vermin species by famers, but to protect it, the Department of Parks and Wildlife Management DPWM allows only licensed hunters to kill it. The wart hog is also present in large numbers and is another pest especially for ground.

The Avifauna The list of bird species recorded within the various corridors, like the mammalian fauna, are influenced by the open forests. Specifically, approximately 300 bird species from 63 families, have been recorded within the NNP. Bird families include Palearctic migrants, resident species, and species with known African migratory populations occurring in The Gambia, which may include movements within Senegambia. It is possible that many of these birds will use the NNP to build up fat reserves after their migration, before dispersing further into the continent. This way, the NNP is apparently used as a corridor to the inland areas of the continent as well as providing extensive wintering grounds for many species.

In view of this, the avifauna within the NNP is of both national and international significance, and the risk of disturbing their migratory activities, and risk of collision with the transmission lines during flight between roosting/nesting and the feeding grounds should be avoided or minimized.

Human Environment

Demography and population along the Corridors

Overall, the four feeders from the Soma substation will supply 274 communities in 22 Districts in the three Regions. The households to be supplied will be about 31,807, with a total population of 255,635; the women make up more than half of the population (52.3 per cent – 133,585) and the male population is 122,050 (47.7 per cent). This is sourced from SD Focus Ltd, 2020 with data from GBOS, 2019. See Appendix 4.1 for details.

In the village of Kerr Batch in Nianija District, CRR, along the Chamen-Nyanga Bantang corridor is the ancient Stone Circles of Kerr Batch, one of the important national cultural sites; it is on coordinates 130 45’ N/150 42’W. In fact, it is now inscribed on the World Heritage List of UNESCO. The Stone Circles are thought to be over a thousand years old and are believed to be ancient burial areas for chiefs whose subjects belonged to a single unified culture. Because of this, local legend has it that there is a curse on anyone who disturbs those laid to rest there. The Circles in general, include various forms of burial mounds, isolated pillar stones, single circles and groups of stone circles that may represent cemeteries.

Given its cultural significance globally, Project activities must not be implemented anywhere within the buffer. Another important national site is at Wassu, (not affected by the Project).

Modes of Subsistence and Daily Chores in the Project’s Area of Influence The communities along the line corridors, to a large extent rely on agriculture and livestock for their subsistence. Like other parts of the country, agriculture is characterized by little diversification, and is mainly subsistence rain-fed, and semi-intensive cash crop production. Other economic activities carried out along the proposed corridor include market gardening (mainly by women), petty trading

xv and shop keeping, harvesting non-wood forest products, firewood collection, livestock rearing and fishing.

Potential environmental and social impacts and risks

 Potential impacts during pre-construction phase

➢ Negative impacts on the biophysical environment During activities of the pre-construction phase, no potential positive impact is anticipated on the biophysical environment.

During the construction phase however, potential negative impacts on the biophysical environment will include: • impacts relating to geology and soils; • air pollution; • noise and vibration nuisance; • unsightly landscape; • impacts of improper waste management; • deforestation; • loss of fruit trees and other vegetation; • negative impacts on fauna.

➢ Negative impacts on the human environment • Involuntary resettlement and loss of livelihoods; • Negligence of vulnerable groups and Gender-Based Violence (GBV); • Risks to Public Health and Safety; • Negative impacts from Violence Against Children (VAC); • Risks to Occupational Health and Safety; • Risks of Communicable Diseases; • Community Instability and Reduced Cohesiveness (Including Impacts from Labor Influx); • Impacts on sites of cultural and historical significance.

 Potential impacts during construction phase

➢ Positive impacts on the biophysical environment There are no potential positive impacts of significance on the biophysical environment during the construction phase.

➢ Positive impacts on the human environment • Creation of temporary jobs;

• Income generation;

• Improved community cohesiveness.

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 Potential impacts during operation and maintenance phase

➢ Negative impacts on the biophysical environment • Effects of extreme weather affect applied loads and cause structural failure of various parts • Impacts on landscape- waste from disused and worn-out materials such as poles, lines will create eyesores if not collected from the sites and managed properly.; • Loss of Trees, especially fruit trees during pruning of trees; • Loss of fauna, especially monkeys on non-insulated cables amputating limbs;

• Large birds with wider wingspans (such as certain eagles, waterfowl, cranes, hawks, and vultures) may get electrocuted or killed in contact with lines during flight or resting on the lines.

➢ Negative impacts on the human environment • Risks to public health and safety where people encounter broken live lines during operation leading to electrocution or death;

• Occupational health and safety risks during all works, including operation and maintenance activities, workers are at risk of accidents from machinery, traffic, and illnesses. These include exposure of work crew to the risk of falling from heights during maintenance and repair of lines and accessing high trees during pruning ;

Negative impacts on public services particularly during connection to the main substation and pole- mounted transformers, when there will be temporary disruption of power services to existing customers. ➢ Positive impacts on the biophysical environment

• Impact on Climate Change is positive since source of power is renewable and thus no greenhouse gases produced.

➢ Positive impacts on the human environment • Employment generation; approximately a total of 104 persons would be employed during both pre-construction and construction periods, including 25 skilled and specialist workers, and about 79 unskilled workers;

• Enhanced economic development as a result of efficient energy supply;

• Improved livelihoods as a result of better services (education, health, communications, security and other social services that are largely dependent on electricity will be improved);

• Benefits to youth and vulnerable groups (with continuous electricity supply, youth could develop skills and trade to enhance their livelihood, e.g. welding, carpentry, or other small businesses that rely on electricity).

 Potential impacts during decommissioning phase

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➢ Negative impacts on the biophysical environment • Impacts of improper waste management may affect aesthetics, surface water, wildlife, livestock, and the public; • Air Pollution and local air quality deterioration due operation of heavy machinery, and vehicles releasing hydrocarbon and incomplete combustion gases to the air.

➢ Negative impacts on the human environment • Public health and safety risks; • Risks of communicable diseases due to influx of foreign workers; • Risks to occupational health and safety.

➢ Positive impacts on the biophysical environment • Improvement of landscape due to reclamation of quarries, camp sites, and removal of disused structures returning the landscape to original state or even better.

➢ Positive impacts on the human environment • Employment creation carrying out decommissioning activities; provide short-term employment for drivers, clearing workers, quarry restoration workers etc.

Management and impact mitigation measures

 Enhancement Measures for Potential Positive Impacts

➢ Creation of Jobs: • employ local workers; • ensure equal employment opportunities; • provide training; • encourage technology transfer and development programs; • source materials and services locally.

➢ Improved Community Cohesiveness: • invest in community infrastructure or development projects; • encourage continuous community consultation and participation; • the GRM must also be active and made known; • communities to set up support committees/groups.

➢ Income Generation: • provide information to promote improved livelihoods.

➢ Impact on Climate Change: • upgrade infrastructure to ensure efficiency; • obtain optimal use of the renewable energy use.

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➢ Economic Development and Improved Livelihoods: • maintenance and periodic upgrade of the T&D infrastructure; • ensure optimal transmission and distribution through increased accessibility and affordability.

➢ Benefits to Youth and Vulnerable Groups • Promote equality in energy accessibility and distribution without discrimination.

➢ Increased Security • Ensure increased affordability of electricity to encourage communities light up.

➢ Improvement of Landscape • Landscape should be improved or at least returned to near original state.

 Negative Impact Management during the Pre-construction Phase

➢ Mitigation Measures of the Negative Impacts on the Biophysical Environment

• Mitigation of Impacts related to Geology and Soils: Any quarries for this Project must have clearance from the Geology Department (GD) and the NEA and will be based on a mining and reclamation plan.

• Mitigation of Air Pollution: Prohibit the public from work sites and avoid public places such as schools and markets. Provide personal protective gears for workers and use well maintained vehicles and machinery. Camps must also be located at at least 500 m from the communities.

• Mitigation of Noise and Vibration Nuisance: All preconstruction works must be carried out only during daytime and choose machines with less vibration effects.

• Mitigation of Unsightly Landscape: sites must be cleared of all preconstruction waste and stockpile of materials located in organized camps.

• Mitigation of Improper Waste Management: develop and implement a waste management plan.

• Mitigation of Deforestation and the Loss of Fruit Trees: where trees must be fell or trimmed, develop, and implement a RAP to assess the potential losses and required compensation for reforestation; relocate poles within the maximum span to avoid trees.

• Mitigation of Impacts on Fauna: Prohibit hunting by workers and educate on biodiversity conservation.

• Mitigation of Impacts on Wetlands: Integrate all mitigation measures into the design, including add-ons and evaluation of alternatives (routes, foundation types, pole designs, and cables). A RAP will address designated parks that may be affected.

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Consequent to the outcome of the field assessment for this ESIA study, the null alternative was chosen (the Jinak Island was excluded from the Project to avoid the highly sensitive NNP within which the Island falls).

➢ Mitigation Measures of the Potential Negative Impacts on the Human Environment

• Mitigation for Involuntary Resettlement and Loss of Livelihood: a RAP shall be developed and implemented for compensation of lost assets and livelihoods.

• Mitigation for the impacts on vulnerable groups: vulnerable groups will be included to ensure non-discriminatory benefit sharing.

• Mitigation for risks to public health and safety: use signage to prohibit access to worksite hazards and inform communities before works commence and throughout the implementation period.

• Mitigation of violence against children: employment of children prohibited, and implementation of the Codes of Conduct on Violence against Children.

• Mitigation of Risks to Occupational Health and Safety: adopt and implement a health and safety program including accident and emergency response plans, training of workers, supervision, and provision of protection.

• Mitigation of Risks of Communicable Diseases: Limit worker importation and enforce Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse, Sexual Harassment and Violence against Children. Abide by national emergency regulations and the WB guidelines for protection against the Corona Virus.

• Mitigation for community instability: Initiate extensive consultations and sensitization with the communities.

• Mitigation of impacts on sites of cultural and historical significance: avoid all sites of cultural or historical significance including any buffer created for their protection.

 Negative Impact Management during the Construction Phase

➢ Mitigation Measures of the Potential Negative Impacts on the Biophysical Environment

• Mitigation of Surface Water Pollution: adjust pole spans to avoid water bodies and constant supervision to prevent waste dumping into water bodies.

• Mitigation of Impacts on Wetlands and Loss of Aquatic Ecosystems: promote regrowth of vegetation within wetlands by ensuring sites are returned to near original state;

• Mitigation of Noise and Vibration Nuisance: All construction activities must be carried out only during daytime and choose machines with less vibration effects;

• Mitigation of Unsightly Landscape: sites must be cleared of all construction waste and excess materials.

• Mitigation of Extreme Weather Impacts: Plan for pole erection during the dry season; train and supervise workers on response actions;

• Mitigation of Impacts related to the Importation of Workers: Limit importation of workers and use the Grievance Redress Mechanism (GRM) in case of complaints.

➢ Mitigation Measures of the Negative Impacts on the Human Environment

• Mitigation of Impacts related to Public Health and Safety: prohibit access of the public to work sites, materials, and equipment; use qualified workers, give prior notice to communities, avoid school and market days;

• Mitigation of Risks of Communicable Diseases: Limit worker importation and enforce Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children. Abide by national emergency regulations and the WB guidelines for protection against the Corona Virus.

• Mitigation of Violence Against Children: employment of children prohibited, and implementation of the Codes of Conduct on Violence against Children.

• Mitigation of Gender Based Violence: enforce the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC);

• Mitigation of Land Use Impacts and Loss of Livelihoods: no displacement causing loss of livelihoods should take place until PAPs have been fully compensated:

• Mitigation of Chance Finds Impacts: apply the Chance Find Procedures (avoid further disturbance and secure discovery, inform the relevant authorities);

• Mitigation of Risks from Force Majeure: abide by any national emergency regulations passed by the Government of The Gambia during such periods.

 Negative Impact Management during the Operation and Maintenance Phase

➢ Mitigation Measures of the Negative Impacts on the Biophysical Environment

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• Mitigation of effects of extreme weather conditions: routine inspection and maintenance shall reduce destruction of infrastructure during strong winds and heavy rainfall.

• Mitigation of Impacts on Landscape and Aesthetics: All waste must be collected and disposed according to law; consider alternatives to prevent unsightly wires cape;

• Mitigation for Impacts on Trees: only trim branches within the Right of Way (ROW) and not during the fruiting season;

• Mitigation of Loss of Fauna: reproductive grounds, sanctuaries and migratory paths should be avoided, and alternative designs considered for the protection of the fauna.

➢ Mitigation Measures of the Negative Impacts on the Human Environment

• Mitigation of Risks to Public Health and Safety: public education on the safety of electricity infrastructure and prohibition from work sites during pruning;

• Mitigation of Impacts on Public Services: prior to connection of the new infrastructure, the public must be informed well in advance about disruptions to electricity services.

 Negative Impact Management during the Decommissioning Phase

➢ Mitigation Measures of the Negative Impacts on the Biophysical Environment

• Mitigation of Improper Waste Management: collect and dispose all waste according to law;

• Mitigation of Air Pollution: use protective gear and well serviced equipment and heavy vehicles.

➢ Mitigation Measures of the Negative Impacts on the Human Environment

• Mitigation for risks to public health and safety: use signage to prohibit access to worksite hazards and inform communities before decommissioning works.

• Mitigation of Risks of Communicable Diseases: Limit worker importation and enforce Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children. Abide by national emergency regulations and the WB guidelines for protection against the Corona Virus.

• Mitigation of violence against children: employment of children prohibited, and implementation of the Codes of Conduct on Violence Against Children.

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 Mitigation of Potential Cumulative Impacts

• Full implementation of the ESMP to include amongst others, working outside the farming season, avoiding forests and unrelated removal of vegetation, strategically locate poles, develop, and implement the C-ESMP, provide information and educate on health and safety. Future cumulative impacts may be mitigated by studies done and implemented at that time.

• Strategic Environmental Assessment (SEA) of the Government’s and NAWEC’s wider plans and programs can contribute in coordinating similar projects or different projects in the same area with the aim of mitigating the cumulative impacts.

Stakeholder Consultations Stakeholders in all the Project areas were adequately sensitized on matters relating to the consultations with the communities, project background, processes, and procedures as well as the role of the communities and institutions during the implementation of the Project.

In general stakeholders, including potential PAPs, highly appreciated and welcomed the Project and highlighted the importance of electricity for the lives and livelihoods of the people, as well as the numerous benefits they will get from the availability of electricity. These benefits they maintained, would include their ability to preserve and store their different foodstuff, and enable them to engage in new revenue-earning businesses such as electricity-dependent professions like welding, that will raise their standard of living.

The opinions, concerns and fears of the populations and persons likely to be affected by the Project (PAPs) have been incorporated into the recommendations of this ESIA.

Risk and accident management

Based on the activities of the Project during all the phases, potential risks were identified, and their significance evaluated based on severity, probability, exposure levels and possibility of control. The following risks were identified with corresponding mitigation measures: • sabotage; • movement and circulation risks such as traffic accidents; • noise nuisance; • vibration risks; • risks related to improper use and storage of equipment; • fires and explosions; • personal injuries such as cuts, struck by objects, stepping on objects, falls; • risks related to ergometrics; poor manual handling etc.; • respiratory risks;

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• insecurity from burglary, threats, and personal attacks ; • contagious illnesses, ingestion of contaminated food or drink; • Risks related to unethical workers (Discriminating vulnerable PAPs, insensitivity to local norms, alcohol/drug abuse impacts etc.); • wildlife attacks (reptiles, insects, and animals etc.); • risks of work site conditions; • work related stress.

Corresponding preventive and protective measures were then recommended for mitigation following the mitigation hierarchy from elimination, control, and reduction of the risks, to providing protection against the hazards. These include:

• developement and implementation of accidents and emergecny response plans; • training; • public information and awareness; • constant supervision of workers; • health and safety monitoring, reporting, and recording; • limit exposure by reducing working hours; • waste should never be burnt; follow waste management plan; • use machines to assist in moving heavy and long loads; • prohibit public access to work sites; • no work at night; • provision of first aid kits ; • provision of protective gear.

Environmental and Social Management Plan (ESMP)

The potential impacts and mitigation measures identified for all the various activities are further expanded in an ESMP matrix. For ease of reference during implementation, each mitigation activity is considered along: • responsibilities for its mitigation (contractor, Owner Engineer, NAWEC, Project Implementation Unit (PIU), communities etc.); • period of expected mitigation (before, during or after the specific Project activity); • responsibilities for monitoring (regional Technical Advisory Committees, NAWEC, NEA, PIU, Environmental Safeguards Specialist (ESS) and Social Safeguards Specialist (SSS), DoF, DPWM etc.); • required budget for mitigation to ensure resources are available in a timely manner.

Roles and responsibilities for ESMP implementation

Implementation of the ESMP is the responsibility of the Contractor and PIU. Most of the mitigation measures are the responsibility of the Contractor who will be carrying out the works according to the C-ESMP that will be based on the Project ESIA/ESMP.

The ECOWAS-REAP PIU will be responsible for overall follow-up, and to ensure that the ESIA/ESMP is fully implemented with the support of the PIU Environmental Safeguards Specialist (ESS) and Social Safeguards Specialists (SSS). Specifically, the ECOWAS-REAP PIU will include clauses in the Contractor’s agreements that will ensure compliance, and coordination with the GRM, among others.

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The supervising firm, Owner Engineer, will support the PIU in field supervision of all the contractors and their works. The Owner Engineer will also assist the PIU in bidding processes and verifies that contractors abide by clauses in the contracts.

The communities will also have the responsibility of ensuring that villagers avoid work sites, and report to NAWEC or relevant authorities, issues of concern related to the Project; the PIU and Contractor will engage the communities regularly as an oversight measure in this regard, and conduct sensitization sessions to ensure communities are aware of reporting measures and understand Project risks.

As the Secretariat of the EIA Working Group, and supported by its members, NEA will be responsible for the overall external monitoring of the ESMP implementation; in collaboration with the PIU ESS and SSS, they will monitor compliance with the Bank policies as they relate to the environmental aspects of this Project. In addition to the permanent members in the EIA Working Group, other institutions on ad hoc basis will include those specialized in social aspects such as the Women’s Bureau, Department of Social Welfare, Department of Labor, and Department of Health Services, amongst others.

Meanwhile, monitoring of the implementation of the social aspects of the Project in line with the Bank’s safeguards instruments will be the responsibility of the PIU SSS.

Overall estimated budget for the ESMP implementation is US $87,000, which includes capacity building; cost of implementation of the mitigation measures; regular environmental and social monitoring for compliance with the ESMP and with the relevant laws and policies.

The construction phase of the Project is planned to be completed in approximately 18months.

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CHAPTER 1: INTRODUCTION This Chapter sets the background of the Project, its objectives, and beneficiaries. It further describes the rationale and objectives of the ESIA, in addition to the methodology used in carrying out the study. The various issues covered under the ESIA have also been outlined as presented in this report.

1.1 Project Background This report is the Environmental and Social Impact Assessment (ESIA) of the ECOWAS-Regional Electricity Access Project (REAP), a part of a Series of Projects (SOP) being implemented within the ECOWAS region, with a long-term view to achieving electricity distribution expansion within the Region. Funded by the IDA/World Bank, the SOP aims to increase the number of people in West Africa with access to reliable and affordable electricity, as articulated in the ECOWAS White Paper of 2006 for Increasing Access to Energy Services to People of the Sub-region.

The SOP consists of two Phases, which plan to provide 2.5 million people across six countries in West Africa, namely Guinea-Bissau, Niger, Mali, Senegal, Mauritania, and The Gambia with electricity. Phase I of the SOP is to provide access to 1.1 million people in Guinea-Bissau, Mali, and The Gambia. In The Gambia, this Phase will finance the expansion of medium and low-voltage networks from the two high-voltage 225/33 kV substations (in Soma, Lower River Region–LRR, and in Brikama, in West Coast Region–WCR) being built under the OMVG1 Energy Project. It is expected that this will transform the power sectors of these countries and enable them to achieve their common objective of delivering more power to more consumers.

The second Phase of the SOP (Phase II) will finance the reinforcement and extension of the distribution network (MV and LV) in Senegal, Niger, and Mauritania, and within the context of the ECOWAS White Paper of 2006, additional member countries will be included later (potentially through additional financing).

These participating countries will benefit from attracting larger contractors to ensure timely implementation, and furthermore, the regional approach facilitated by ECOWAS will be used to disseminate lessons learned from the World Bank’s global access experiences, which will be shared with participating countries to implement the access agenda.

The ESIA report is based specially on the impacts of the four feeders emanating from the substation being built in Soma, Lower River Region (LRR) in The Gambia.

Specifically, the ESIA report consists of the following sections:

• Project description and scope;

• Policies, legal and institutional framework;

• Description of the current state of the environment of the project area;

• Public consultations;

• Analyses of potential impacts, enhancement and mitigation measures;

1 OMVG – “Organization pour la Mise en Valeur du Fleuve Gambie”, is the French acronym for Gambia River Basin Development Organization; OMVS – “Organization pour la Mise en Valeur du Fleuve Sénégal is French acronym for Senegal River Basin Development Organization.

• Management measures of the potential positive and negative impacts on the environment;

• Management of risks and accidents;

• Environmental and social management plan;

• Conclusion;

• Bibliography;

• Appendices.

1.2 The Project Development Objective (PDO) Specifically, the Project aims to increase grid electricity access in the Republics of Guinea-Bissau, Mali, and The Gambia. It is expected to substantially increase the access to electricity to reach an access rate of almost 65 percent and 25 percent, in The Gambia and Guinea Bissau respectively, while Mali will increase its electricity access rate to 37 percent.

1.3 Project Beneficiaries In The Gambia, the Project’s beneficiaries will include households, small businesses, and public institutions (including local governments, schools, and health clinics), which will be connected to the electricity grid. The Project will be implemented in three Regions, viz: LRR; North Bank Region (NBR); West Coast Region (WCR); and Central River Region (CRR-North and South).

The Soma feeders (which is the basis of the ESIA) will connect communities up to 100 km radius from the substation. See Appendix 4.1 for the details of project beneficiaries by community.

The Project will reduce or eliminate the connection charges of these beneficiaries and will also deploy prepaid meters to enable beneficiaries to manage their own consumption without the risk of the physical disconnection process that can arise because of unpaid monthly bills. Thus, the Project is expected to have a transformative impact on the beneficiaries, both in the the short-term and long term.

1.4 Rationale of the ESIA An ESIA should be performed because it is a requirement of the National Environment Management Act, (NEMA) of 1994, the EIA Guidelines and Procedures (1999), and the EIA Regulations (2014), which require impact assessment studies to be conducted prior to development activities that are likely to have adverse environmental and social impacts. The ECOWAS REAP, The Gambia, falls under Schedule A of the NEMA; “Projects to be considered for EIA, including electrical infrastructure such as “electrical transmission lines” and “electrical substations”.

To start the ESIA process in The Gambia, the Project proponent should complete and submit a screening form to the relevant authority, the National Environment Agency (NEA). Following the screening process, Terms of Reference (TOR) for the ESIA study is then developed by the NEA with support from the EIA Working Group. This Project was not screened by the NEA and the TOR was developed by the RCU through the ECOWAS-REAP PIU. Notwithstanding, the NEA was consulted in the course of the study. Since the IDA/World Bank is financing this Project, it becomes imperative that an ESIA is carried out; according to the Operational Policy (OP 4.01), the Bank requires environmental assessment of projects proposed for Bank financing to help ensure that they are environmentally and socially sound and sustainable.

1.5 Objectives of the ESIA study The overall objective of this ESIA study is to ensure that environmental considerations of The Gambia ECOWAS-REAP are considered during decision making for environmental sustainability. Specific objectives of the ESIA are to:

• identify, evaluate, and mitigate potential environmental and social risks and impacts of the proposed Project activities; • examine ways to prevent, minimize, mitigate, or offset/compensate for adverse environmental and social impacts, and to enhance positive impacts; • describe the baseline conditions for future reference ; • provide platforms for public consultation and participation regarding the Project; • maintain credibility of the Project developers and funders.

1.6 Consultant Responsible for this Study This ESIA was carried out by Sustainable Development Focus Ltd., a Gambian registered consultancy firm specialised in environment and natural resources management.

1.7 Methodological Approach for the ESIA The following approach was used to develop this report:

a) Literature Review This consisted of the review of relevant national polices and legislation, World Bank Operational Policies, ECOWAS Environmental Policy, 2008, the ECOWAS-REAP Project Appraisal Document (PAD), relevant international conventions and treaties to which The Gambia is a Party, among others.

The legislation and policies reviewed have guided the ESIA study to identify the legal scope of the process and ensure that issues highlighted are given due consideration during the study. For example, policies have described areas to protect such as historical sites, and gazetted forest. Therefore, special attention was given during the study to watch out for such sites and assess the necessary issues.

The reviewed legislation also highlighted areas to consider during the study, such as the need for community consultation; the need to ensure that women are included, and that compensation will be required for involuntary resettlement and loss of livelihood as a result of the Project.

The identified WB Policies that have been triggered by this Project also have assisted in identifying specific issues to consider during the study.

Although the Project’s Detailed Engineering Study report was not available to identify the exact Project sites, the ECOWAS-REAP Project Appraisal Document, the Study for the Project of Electricity Access from the Substations of Regional Project (OMVG and OMVS) in the Republic of Senegal, Guinea, Mali, Guinee Bissau and The Gambia, the ECOWAS-REAP Project Implementation Manual, the West African Power Pool (WAPP)-REAP Environmental and Social Management Framework – Phase I, and the Terms of Reference (ToR) for this study were reviewed. These Project documents provided the ESIA study with the information necessary to identify and evaluate the environmental impacts. These include the:

• physical scope of the Project in The Gambia and the list of proposed beneficiary villages as it is practically impossible to cover all villages within 100 km of the Soma substation; • Project components, materials and activities that will cause the environmental change;

• alternative sites, technology and design considered; • institutional arrangements for the Project implementation.

In addition to the above, an extensive review was carried out of data from a variety of sources, including a selection of features derived from appropriate secondary spatial datasets collected by different national sectoral institutions, maintained in a GIS database. See the full list of relevant documents reviewed in the Bibliography section.

b) Field Visits and Scoping Extensive field visits were carried out to potential Project communities within 100 km radius of the the Soma substation to validate the list of communities provided by the ToR. Each of the 274 communities and all 46 corridors were visited at least once, and where necessary, twice in some cases. However, since the ToR did not provide a design of the proposed routings of the transmission lines, the Consultant’s consultation with the Project PIU and relevant staff of the National Water and Electricity Company (NAWEC) concluded that the ESIA will be used as the feasibility report to environmentally and socially design the best routes of the T&D lines.

In this regard, the Consultant visited all the proposed Project corridors in the company of a senior engineer from NAWEC (with decision-making powers) and his team, to interact with the Consultant’s Engineer so that decisions for line routings will be confirmed on the spot, particularly given that the ESIA and ESMP is expected to be location-specific.

The visits provided the Consultant and the NAWEC team with the opportunity to analyze possible alternative transmission line routings, and possible construction methodologies in order to reduce the negative environmental and social impacts. The field visits also allowed the study to:

• define, locate and precise the borders/limits of the Project areas of influence; • assess the current state of the environment; • identify the activities of residents likely to be affected by the Project; • assess the environmental sensitivity of the Project right-of-ways.

The ToR provided a list of communities proposed to benefit from the Project, but the list did not include a number of communities along some of the proposed corridors that are believed should have been obviously included, considering their respective locations along the proposed trajectories. For example, where a community located at the end of a proposed line corridor has been identified, some intermediary communities along the same trajectories were not included in the list supplied by the ToR.

Use of GIS to Support Corridor and Community Identification One of the aims of the field trips was to identify the communities that were left out, to address the above-mentioned shortcoming. In addition, GPS coordinates of routes and locations that were not evident on the maps provided by the OMVG studies were recorded wherever necessary, to update the list of proposed communities, and also to identify and digitize features such as roads that are missing in the spatial database.

The updated list of communities along the four Soma feeders is provided in Appendix 4.1, and the maps showing the routes of the four Soma Feeders are illustrated in Appendices 2.1. This, effectively, defined the scope of the coverage of the Project.

Data Collection Data collection and analyses of supplementary primary data obtained from field surveys (using GPS technology) was carried out. In addition, existing secondary datasets (including topographic data, settlements data, forests, and protected areas, etc.) that are hosted by other national institutions were analyzed. These institutions included the Department of Lands and Surveys, Gambia Bureau of Statistics (GBOS), Department of Forestry (DOF), Department of Parks and Wildlife Management (DPWM), etc. Where a particular feature was encountered in the field, but does not exist in the appropriate sectoral database, the GPS coordinates of the feature were physically measured, digitized, and incorporated into a spatial database for the particular dataset.

Data Analyses The datasets were arranged into feature-based GIS layers that can be used as and when required for analyses, and/or presentation. For example, the settlements layer was used to extract and identify the substation located in Soma, as well as all intervention villages. From this data, a spatial buffer of 100 km radius was created around each of the substation locations. These buffers were then “Intersected” and the resulting datasets “overlaid” with the settlements layer to analyze the location of all intervention villages as identified in the ToR. Presentation For this study, the following datasets were used in both the analyses and/or the presentation of results:

Settlements These included the proposed intervention villages, Soma as well as other major towns/villages of significance to the Project.

Roads These comprised mainly the main roads (such as Barra-Farafenni, Farafenni-Laminkoto, Soma- Bansang, etc.); feeder roads (such as Jurunku-Kuntaya, Dankunku-Choya, Keneba-Sankandi, etc.), as well as earth roads/tracks/paths (such as Kanuma-Jinack Niji, Chamen-Nyanga bantang, Tamba Kunda- Sibanor, etc.). This dataset is particularly significant because most of the MV lines in this Project will run along these roads.

International Boundaries This dataset identifies the scope and geographic limits of the analyses and hence the presentation of the results was based on this frame, i.e the geographic limits of The Gambia.

National Parks The impact of the Project on National Parks was studied by mapping out all possible influences the Project’s attributes and features have on National Parks. As stated earlier, this was achieved by analyses of data on National Parks, Settlements and Roads which were then overlaid as shown in Appendix 2.1, which highlights the impacts on the Nuimi National Park (NNP). The Project has finally decided to completely avoid the Niumi National Park.

Forests

Like National Parks, the Project may also impact Forest Parks. As a result, data on Forests, Settlements and roads were analyzed. Based on the above, the GIS analyses presented in this report is a map of The Gambia (Figure 2.1) showing the following:

• the Soma substation;

• all intervention villages/communities - maps of the line routes, and the communities that are located along them, i.e. the four Soma feeders;

• Forest Parks, Protected Areas, major water bodies that may be impacted by the Project, where necessary;

• other relevant physical features that may be impacted by the Project.

In addition to this map, other maps were created to highlight specific environmental and social issues and/analyses such as MV line corridors (see Appendix 2.1, map of routes of the Soma feeders. c) Community Consultations During the field trips, consultations were undertaken using mainly unstructured methods; these included public meetings, focused group discussions, and individual (one-to-one) meetings. Refer to Chapter 5 for details. d) Key Stakeholder Interviews and Consultations Consultations and interviews with relevant Government agencies were also conducted; these included NAWEC, Office of the Regional Governor in Mansakonko, LRR, the National Environment Agency (NEA), DPWM, (DOF), National Roads Authority (NRA), and the National Council for Arts and Culture (NCAC). See Chapter 5 and Appendix 5.1 (Summary of Comments and Views from Consultations), and Appendix 5.2 (List of Persons and Institutions Met) for details.

CHAPTER 2: PROJECT DESCRIPTION AND SCOPE

This Chapter describes the Project, from the objectives and roles of the Proponent to the specific project details such as location of sites, technical description of the activities, the works input and output. Alternative sites and designs, and the ‘no project’ alternative are also analyzed to ensure the most environmentally friendly option is considered.

2.1 Presentation of the Project Proponent The ECOWAS administrative structure was transformed from an Executive Secretariat to a Commission in 2007 in accordance with a decision taken in Niamey, Republic of Niger, in 2006. This change was necessitated by the need to enhance equity, transparency, and greater functionality in line with global best practice. This resulted in The Commission being in a better position to support ECOWAS member states to build their capacities for program implementation. Thus, establishment of the Commission together with the endorsement of institutional reforms covering all its structures, ECOWAS came to be in a better position to fulfil its mandates to meet and address emerging challenges. In this regard, the overall objectives of the Commission are geared towards improving the living conditions of its citizenry; ensure economic growth and creating an environment conducive to development and meaningful integration of member states.

The ECOWAS Commission, with its headquarters in Abuja Nigeria, coordinates all the activities of ECOWAS and comprises the following structures: Executive (headed by the Chairman of the Authority of Heads of State and Government); Legislative arm (comprising the Community Parliament headed by the Speaker) and the Judicial arm (comprising the Community Court headed by the President).

2.1.1 Objectives of the Commission The ECOWAS Bloc aims ‘to promote cooperation and integration in West Africa with the sole intention of raising the standards of living of the its people, maintain and enhance the economic stability, foster relation among Members States and contribute to the progress and development of the African continent’ (http://www.comm.ecowas.int/about-ecowas/objectives/).

To achieve the above, the Community undertakes a number of measures including:

harmonization and coordination of national policies and the promotion of integration of programs, projects, and activities particularly in agriculture, energy and natural resources, industry; harmonization and coordination of policies for the protection of the environment; the promotion and establishment of joint production enterprises; establishment of common markets; establishment of an economic union through the adoption of common policies in the financial, economic, cultural and social sectors and the creation of a monetary union etc.

2.1.2. Roles and Functions of the ECOWAS Commission The ECOWAS Commission performs the following tasks: designing, coordinating and monitoring the regional integration process with professional competence, thereby helping the member states to improve their implementation of its policy decisions related to economics and trade, and peace and security.

2.1.3. Organizations of the Commission The Commission has 14 departments as listed below:

• Agriculture, Environment and Water Resources; • Education, Science and Culture; • Energy and Mines; • Finance; • Financial Controller of ECOWAS Institutions; • General Administration and Conference; • Human Resources Management; • Industry and Private Sector Promotion; • Infrastructure; • Macro-Economic Policy and Economic Research; • Political Affairs Peace and Security; • Social Affairs and Gender; • Telecommunication and Information Technology; • Trade, Customs and Free Movement of Goods and Services.

The Department of Energy and Mines was created to ensure energy integration among ECOWAS member states over time and to harmonize exploitation of the community mineral resources. It was mandated to formulate and implement ECOWAS regional policies in the areas of energy and mines and in doing so, works closely with some agencies in selected member states, such as the West African Power Pool (WAPP), ECOWAS Centre for Renewable Energy and Energy Efficiency (ECREEE) and the ECOWAS Electricity Regulatory Authority (ERERA).

2.2 Location of Project Sites The Project will be implemented in three Regions in The Gambia as follows:

• the whole of the North Bank Region (NBR); • the whole of the Lower River Region (LRR); • the whole of the Central River Region (CRR ).

2.2.1 Brief description of OMVG Soma Sub-station site location and related feeders

The OMVG Soma Sub-station is located in Soma, LRR. The region is another administrative region among the five administrative regions in The Gambia and lies between WCR and CRR. Four (4) feeders from the OMVG site will run across two other regions namely NBR and CRR with administrative headquarters in Kerewan and Jamjambureh respectively. The proposed Project areas are shown in Figure 2.1.

Figure 2.1: ECOWAS-REAP Substation and Line Corridors in LRR, NBR, and CRR

Source: SD Focus Ltd, 2020

From Soma, the Project will connect the communities with the infrastructure mentioned below in Section 2.3; for example, from the substation, four-feeders (30kV) interconnection lines will be constructed to supply the proposed Project sites.

Feeder 1 will run between Farafenni, westward via Minteh Kunda, Kerewan, Kuntair, and up to Barra and Amdalai.

Feeder 2 will connect between Soma and the communities of Kemoto in Kiang West, on the south bank. The best part of this feeder is without power supply all the way to the village of Sakandi, and down to the right to Keneba, Karantaba and Kemoto. However, there is an ongoing electrification project funded by Exim Bank of India to electrify a significant section of this feeder. This ongoing electrification work covers Kwinella and extends all the way to Sankandi and to Keneba.

Feeder 3 will extend eastwards on the south bank via the communities of Jalanbereh, Mamutfana, Boiram, and up to Bansang in Central River Region-South; the existing MV line follows the highway trajectory from Karantaba to Jalanbereh where it ends. The Project line will link to the existing line at Jalanbereh and follow the road alignment until just before Dongoroba where it will be routed behind (to the left/north) Dongoroba, Bureng Crossma, and Wellingaraba.

These communities are very close to the highway, private houses, and other infrastructure; therefore, to avoid negative impacts on these structures, the line will be routed behind the communities.

Feeder 4 will cross the River Gambia into the NBR to connect Farafenni and continue eastward to extend to Laminkoto via the villages of Kaur, Njau, Panchang, etc. in CRR-N. It will terminate at Bush Town, just beyond the village of Dobo. Appendix 4.1 indicates the list of the communities along the four feeders from the Soma substation. Appendix 2.1 provides the routing map of the four feeders.

Overall, 46 medium voltage transmission line-corridors will be established along which Project activities will be carried out; the details of the activities are provided in Section 2.3 below.

2.3 Technical consistency of the works The geographical extent of the Project covers a maximum of 100 km radius from the OMVG Energy Project’s substation in Soma. Specifically, the scope of the works will include:

• construction of 33/30 kV Medium Voltage (MV) lines; • construction of distribution substations of 33/30 kV / 400 Volts (V); • construction of 400 V Low Voltage (LV) lines; • supply and installation of last-mile connection equipment, including service drops, prepaid meters, and ready boards for LV customers.

2.3.1 – Construction of 33/30 kV Medium Voltage (MV) lines

The MV lines will be designed to meet the required mechanical strength and resistivity on environmental impact such as salt, fog, and bushfires. The works activities for this scope include but not limited to the following:

(i). erecting MV (33kV & 30kV) over headlines support structures using hot dipped galvanize steel. The MV shall be constructed using 12 m high poles with an average span of 100 m between support structures and up to 150 m span in wetland areas with pole structures of up to 15 m height. The MV lines will achieve at least a minimum clearance of 6.0 m from the ground and will run over a maximum 6 m width;

(ii). the sheet-arch cross from arms, Napoute type (NV2) shall be used for the suspension lines dead end cross arms shall be used in dead end angles or H-type at tee-offs structures with poles 1.5 m to 2 m apart shall be installed at least every 1.5 km to 2 km within the line to ensure line strength as per standards;

(iii). MV pole foundations; The foundation of the poles are 1.5x1.5 m and 2 m deep standard gravel (washed stone) or basalt is appropriate for such. Foundations in wetland should be of marine grade type to ensure longtivity of the pole foundations and structures;

(iv). bare conductors of aluminum alloy studded conductors of up to 150 mm2 to 70 mm2 for tee-offs composite insulators of up to 36 kV insulation level shall be used and of the required standards to withstand wind loads as well as high frequency vibration due to wind. The stringing of conductors using conventional methods and conductors will be pulled and tension on guyed structures requires pulleys installed on the poles and the conductors in drums rolled through/ along the pulleys and tensioned using special equipment such as come along tongues;

(v). insulators for the MV lines are of the composite type of string design for both intermidaite/suspension poles and for angles and dead poles. The insulators are up to 36 kV insulation level and operated effectively with the service voltages of 33 kV and 30 kV. These insulators must always withstand harsh environmental conditions.

2.3.2 - Construction of distribution substations of 33/30 kV / 400 Volts (V)

Transformer sub-station requires the installation of the following:

(i). installation of transformer ratings ranges from (25 kVA, 50 kVA or 100 kVA, etc). They shall be positioned at load centers and function as substations to step down the voltage from 33 kV or 30 kV to supply electricity to consumers. The transformer is made of steel tank with copper coils immersed in mineral oil contained within the tank (no oils are used containing polychlorinated biphenyl PCB);

(ii). H - pole transformer mounting frame structure and supports;

(iii). MV fuse cut out assembly to be installed above the transformer for both protection of the transformer and safe operational activities with the transformer substation;

(iv). surge arrestors numbering 3 of up to 36 kV insulation level shall be installed on the line at the substation for protection against lighting surges and other electrical

network system disturbances. The arrestors shall be bridged on the lines accordingly and earthed to the ground together with the transformer body;

(v). a low voltage distribution feeder pillar unit shall be installed below the transformer. This comes with a busbar system controlled by a main breaker. The unit contains several other breakers or fuse carriers for individual customer feeder lines/circuits.

2.3.3 - Construction of 400 V Low Voltage (LV) lines

The construction of LV lines consist of the following;

(i). the overhead LV lines support structure will be constructed using 9 m hot dip galvanized steel poles. The poles shall have maximum spans of 45 m with a conductor clearance at least 6.0 m from ground;

(ii). the LV pole foundations shall be 0.5x0.5 m and one (1) meter deep using gravel (washed stone) or basalt for the foundation works;

(iii). the Aerial Bundle conductors (twisted cable) of the required standards shall be used for the distribution. The main lines shall be 3x70+54.6 mm2+1x6 mm2 and the tee-offs (branches) shall be 3x50 mm2+54.6 m2+1x16 mm2or 3x35 mm2+54.6 mm2+1x16 mm2. The stringing will be done using conventional methods and conductors will be pulled and tension on guyed structures using pulleys and come along tongues, etc.

2.3.4 - Supply and installation of last-mile connection equipment, including service drops, prepaid meters, and ready boards for LV customers

Key among the equipment and activities are:

(i). the meters shall be prepayment type (cash power) and must be Standard Transfer Specification (STS) compliant, operating on both 3phase (400V) and single phase (240V). Majority of the meters shall be single-phase meter and some 3-phase type;

(ii). the meters are usually fitted in a casing box usually fireproof or sometimes boarded or fitted on a plywood sheet;

(iii). the installation is done using 10 mm copper cables conductors or aerial bundle conductors 1x16 mm2 or for single-phase and 4x16 mm2 for 3-phase.

2.4 Description of Activities by Project Phases The work will be broken down into four (4) main phases:

2.4.1 Description of Construction Works of the 33/30 kV Medium Voltage (MV) lines

Phase 1: pre-construction phase Preliminary works: • work site installations or building of camps (office, water supply, toilets etc.);

• serving land/space for storage of materials and equipment; • installation of road safety signs surface preparations; • identification of the various existing networks in the corridors/right of ways (electricity, telecoms, water pipes sanitation etc.); • identification of quarries for mining of gravel (wash stones); • land clearing and preparation of corridors including access roads; • transportation of equipment and tools to the sites; • arrangements for residential/accommodations for professional staff; • identification of water supply points for civil works and related activities; • preliminary line surveys.

Phase 2: Construction and Installation of Equipment Preliminary activities:

• final field survey detail engineering works for review and approval by client and consultant; • pole spotting surveys; • transportation of poles, cables cross arms, insulator, and other line hardware.

Physical works activities:

• excavation of pole foundations; • erection of poles fitted and dressed in the required cross arms and hardware fixtures; • mounting of pulleys on the poles and related fixtures for stringing and conductor alignment; • earthing cable connection to the poles (earth cable buried with the concrete).

Testing and commissioning:

• testing of the line with voltage through voltage injection or from the primary substation; • switching of the line from source and observation of the performance of existing installation on the line; • testing of the line continuity and insulation with meggering equipment and devices.

Phase 3: Equipment Operation and Maintenance

Operation and Maintenance: • operational activities such as, switching arrangement planned and unplanned maintenances, installation of new equipment and demand-side management; • trimming of trees, branches that have re-grown towards the conductors; • periodic inspection and maintenance of fixture and hardware materials; • periodic inspection and maintenance of civil works (pole foundations) in wetland areas; • clearing sites of vegetation that have re-grown within the corridor.

Phase 4: Decommissioning It is anticipated that the distribution line facilities will be continuously maintained and repaired and will be operated for close to 30 years of design lifetime or more. Because of their long usable life, the

14 circumstances under which they might ultimately be decommissioned are not foreseen at this stage. Thus, only general decommissioning approach will be considered. The process of decommissioning will involve the deconstruction of distribution lines (in reverse from construction) using similar equipment and techniques. Conductors will either be re-used or taken to steel/aluminium rolling mills for recycling; salvaged poles will either be re-used as fencing poles or taken to NEA approved disposal sites. Preliminary Decommissioning: • inspection of the lines to determine their status; • preparation of temporal site for packing of dismantled materials before sending them to final disposal sites; • identification of access roads within the corridors and to the temporal packing site; • accommodation for professional staff and equipment operators during decommissioning activities.

Ground Activities: • dismantling of cables and rolling them into bundles, or into used drums for easy transportation; • removal of insulators and other hardware equipment and materials; • dismantling of pole foundations and uprooting of poles; • transportation of poles, cables, insulators, and hardware materials to temporal site; • management of disused elements and the sites after dismantling of structures and facilities; • re-vegetation of earlier deforested areas due to the Project; • remediation of aesthetically unacceptable sites and removal of any stained soil; • monitoring of contaminants, if any, or improper disposal or recycling of dismantled materials.

2.4.2 Description of Construction Works of the Distribution Sub-Stations

Phase 1: Pre-Construction Phase Preliminary:

• identification of load centers in the communities for placement or installation of distribution transformer stations. Such sites must be well drained, clear of overhead obstruction and not in hazardous areas.

Phase 2: Construction and Installation of Equipment Physical works:

• installation of H-poles (2 poles) with transformer mounting H-frame between the poles; • installation of cut-out MV fuses assembly, MV surge arrestors; • mounting of transformers on the pole frames; • monitoring of transformer contaminants to prevent leakage or improper disposal or recycling; • installation of LV distribution boards below the transformer equipped with LV circuit breakers, busbars with LV breakers or fuse carriers for outgoing LV feeders/circuits; • earthing of the entire sub-station with earthing material.

Testing and Commissioning Activities for the Substations

• Connection of transformer installation to the grid voltage; • Testing of input and output voltages of the transformer and LV distribution boards and feeders (50Hz) frequency; • Testing of earth resistance and possible improvement to the required levels; • Testing of the transformer insulation level with and without voltage.

Phase 3: Equipment Operations and Maintenance • Transformer routine inspection and maintenance such as oil leakages, cables, and fixtures; • Routine inspection and maintenance of other key substation fixtures such as surge arrestors, MV fuse cut-out, etc.; • Switching of LV board feeders for system operational activities such as load shedding, maintenance activities, tree trimming exercises and customer service connections if need be.

Phase 4: Decommissioning Even though decommissioning of such installation is not common in The Gambia, replacements after useful life of the transformer substation is possible, or were the transformer is overloaded and replaced with higher capacity as well as fixtures such as fuse cut-out current ratings. Thus, only general decommissioning approach has been considered.

• Dismantling of sub-station fixtures on the MV lines such as surge arrestors and fuse cut-outs; • Dismantling of LV distribution boards and accessories; • Dismantling of transformer and support structures; • Transportation of materials to recycling facilities or to NEA approved waste sites.

2.4.3 Description of Construction Works of the 400 V Low Voltage Lines

Phase 1: Pre-construction phase: Preliminary • Identification of LV line corridors within the communities; • Preliminary survey activities of the LV networks in the communities; • Details Surveys and engineering works by the Contractor for the LV lines for approval by the client and consultant.

Phase 2: Construction and Installation of Equipment • Pole spotting survey; • Pole excavations to the required depth; • Pole transportation and erection with the required concrete mixture; • Connection of LV line fixture such as clamps to the poles; • Connection of earth installations within the LV network as specified by the approved design; Stringing with the use of cable stringing tools and equipment such as pulleys, ‘come-along tongues’, cranes, etc.; • Application of line anchors, line taps and other accessories where feasible; • Connection of LV lines to the LV distribution board feeder lines; • Numbering of poles according to feeder/circuit.

Testing and Commissioning Activities of the LV network

• Commissioning of LV lines with testing and measurement of voltage on several points of the LV lines (between phases and Neutral); • Verification of proper operation of other equipment such as streetlights. Testing of LV earthling systems and possible improvement.

Phase 3: Equipment Operation and Maintenance • Periodic trimming of branches or trees that might dislocate the line from the pole; • Repairs of reported faults from customers; • Repairs and maintenance due to accidents by vehicles and damages from windstorms.

Phase 4: Decommissioning As mentioned in other sections, decommissioning of such installations are not common in The Gambia and are not foreseen. However, replacement of such installation during maintenance and upgrading works do occur. Thus, only general decommissioning approach has been considered, including:

• Inspection of the LV line corridors and installation to establish the state of the installations and challenges such as access for equipment and material movement; • Dismantling of LV cables and accessories packed in rolls or in used cable drums to be reused or sent to steel/aluminum rolling mills for recycling by scrap collecting companies; • Disposal of salvaged poles, cables, and accessories at approved disposal facilities; • Remediation of aesthetically unacceptable portions of the site and removal of stained soil; • Monitoring to prevent improper disposal or recycled salvaged material.

2.4.4 Description of the Supply and Installation Works of the Last-mile Connection Equipment, including Service Drops, Prepaid Meters, and Ready Boards for LV Customers

Phase 1: Pre-Construction Stage

• Customer application and survey processes; • Payment of meter invoices, if required; • Allocation and commissioning of meters with customer details as well as relevant network data such as pole numbers next to the customer.

Phase 2: Construction and Installation of Equipment • Installation of service poles or brackets by the customer at designated positions if required; • Boarding of meters in meter cabins or on plywood sheets; • Installation and testing input and output voltages of meters at customers’ premises; • Customer service points/offices for rendering services to the customers.

Phase 3: Equipment Operation and Maintenance • Repairs and maintenance of customer faults; • Inspection of installation to verify proper operation as well as electricity theft; • Monitoring and evaluation of customer commercial data to help enforce field inspections; • Recoveries for sub-charges and penalties of electricity theft.

Phase 4: Decommissioning of Equipment A general decommissioning approach has been considered to include: • Dismantling of service cables and fixtures;

• Dismantling of meters from the premises; • Transportation to temporal recycling facilities or to approved waste disposal sites.

2.5 Works Input

➢ 2.5.1 Personnel Personnel are an important input for the efficient and timely implementation of all aspects of the project. Whilst unskilled workers may be hired directly from major settlements in the Project areas, skilled ones will unavoidably be imported from other parts of the Country. The presence of these personnel will, definitely, generate impacts especially as it relates to the waste they will generate, as well as health and social concerns they may bring along or engage in.

2.5.2 Water For all the works in the Project, water will be required for activities such as mixing of aggregates. Water for such works will be sourced from pipe-borne water supply provided by NAWEC in many of the major settlements in the Project areas, stand-alone solar powered water supply systems, or hand pumps. All these sources of water can be used for construction works. In many instances, contractors use water tankers to transport water for use at construction sites and as well as store them in designated reservoirs.

2.5.3 Quarries Designated sand and gravel quarries are available in all the Regions of the Country. In some cases, these are located in relatively close proximity to the ECOWAS REAP sites. These will provide the gravel/stone for concrete and other works. However, for major foundation works such as in wetlands, it is common practice to use imported basalt, whose added advantage is strength and durability. However, the use of quarries needs to be well coordinated with the NEA, Department of Geology and Mines and the Regional and Land Administration Officials and the local communities due to increased awareness of customary rights of these resources and the attendant benefits that accrue from the exploitation.

2.5.4 Equipment Heavy equipment will be used during the works; these will include but not limited to:

• bulldozer for land clearing; • excavator for digging foundation; • in some cases, contractor may need to create or improve an access road e.g. access road leading to a quarry and will need a compressor in that regard; • concrete mixers; • cranes for lifting, loading, and offloading of heavy equipment and project material; • trucks for transportation of materials and personnel.

2.6 Works Output

2.6.1 Output from imported personnel Imported personnel may potentially bring along diseases or transmit sexually transmitted infections such as Human Immune Deficiency Virus/Acquired Immune Deficiency Syndrome (HIV/AIDS).

2.6.2 Waste Generation Waste will be produced during all phases of the Project with potential effects from improper management having short- to long-term localized negative impacts on aesthetics, health, and safety.

During all phases, laborers will generate domestic wastes such as food and sanitation wastes in camps and around work sites. Burnt oils and worn out parts from the use of machinery and heavy equipment is also expected.

Specific pre-construction waste will include topsoil wastes, cleared vegetation and waste from camp constructions.

Other wastes such as packaging materials, cement bags, metallic pieces, wooden planks, and leftover of aggregate material and debris will be produced during construction.

During operation, maintenance activities will give rise to waste from packaging materials, disused parts of the transmission infrastructure and vegetation from trimming of trees growing towards the lines.

Water used in the Project will undoubtedly produce a certain amount of residual waste which can contaminate the topsoil especially when mixed with cement. In addition to this, such wastewater can impact water bodies close by or the water table where it is not deep enough.

The use of heavy equipment for land clearing and digging of foundations will greatly affect trees and agricultural lands. Similarly, trucks for transportation of materials and personnel will affect access roads which may need to be created or improved for easy access to Project sites. The use of heavy vehicles and machinery will also produce combustion emissions.

The operation of quarries equally has high impacts to the environment and therefore their management and use need to be well coordinated with the NEA, the Department of Geology, and all other stakeholders.

2.7 Assessment of Project Alternatives According to the NAWEC Electricity Road Map, 2017-2021 national transmission capacity in power generation will be improved to eventually reach at least 80 percent of the country by 2021. However, in the face of resource constraints, it plans a gradual expansion of coverage, as resources become available, until it attains its ultimate objective of reaching universal access to electricity. It is in this regard that the ECOWAS-REAP has been launched to cover the selected 46 corridors in 22 Districts, in the three Regions. The assessment of alternatives in project implementation in this report will look at the following: Choice of Trajectory for Routing of Lines In view of the fact that the implementation of the Project will be along so many different corridors, and in as many different Districts, it will be impossible to detail out in this report the specific reason(s) as to why the routing of each transmission line should be located at a particular trajectory as opposed to another based on the degree of adverse environmental or social risks of proposed Project activities. Thus, the reason for the choice of routings or placement of transmission infrastructure along each

19 corridor cannot be detailed here. However, Appendix 4.3, “Location-Specific Baseline Environmental Conditions”, indicates the routings for the different lines (whether to the right side of the road alignment, or to the left). Thus, either side of the road provides a corridor for the lines and using this trajectory will reduce the environmental and social impacts of the Project.

However, where transmission infrastructure within a corridor is likely to encroach into virgin land and/or forest and vegetated areas, the selected routings will be behind these features. Along these trajectories, fewer trees are likely to be impacted, compared to what will be impacted along the corridor. In addition, where more communities are likely to be impacted along a corridor (many private properties are less than 5 meters from the edges of the various roads), the lines will be diverted behind the communities to reduce the social footprints of the Project.

Choice of design options for the transmission infrastructure The choice for the design of the transmission infrastructure in the Project is based, among other things, on the national experience and capacity of the staff of NAWEC, being more attuned to the existing types of transmission infrastructure. NAWEC technicians over time have become more knowledgeable on the technology and thus have developed dexterity in its use; the operational risks are fairly well understood. Given that the Project will be implemented in different types of environments, the following designs will be proposed for adoption at appropriate locations. Special consideration is given to sensitive environments such as the Nuimi National Park and Yellitenda- Bambatenda River Crossing.

A. Preferred Type of Infrastructure Within the Niumi National Park

There are three possible types of transmission infrastructure that can be used within the NNP to supply the two communities of Jinack. These are overhead lines and poles; underground and submarine cables; and standalone mini grid for the Jinack Islands. Below are the advantages and disadvantages of each of the three possible types:

Overhead lines and poles have the following advantages:

• electrification through overhead lines is less expensive compared to other alternatives; • line routing design and implementation could result in less trimming and less felling of trees; • overhead lines will occupy less land, since pole foundations are small, and farming can be done under the lines; • operation and maintenance costs are lower; challenges associated to fault tracing are less since the lines are visible. In general, maintaining overhead lines comes with less challenges compared to use of underground cables or sub-marine; • NAWEC has adequate manpower and capacity to maintain overhead lines, which makes up to 95 percent of transmission infrastructure in The Gambia. Experience, therefore in this area is enormous in the Company.

Some of the challenges related to this technology include:

• cutting down of trees and trimming for the erection and stringing of the power lines; • birds colliding with conductors during flight, and some possibly electrocuted; primates electrocuted when they climb on then poles and catch the conductor; • possible pollution of water bodies during construction works;

• need for periodic trimming of trees as the branches grow towards the conductors.

Electrification using underground and submarine cables • electrification of the two Jinack Islands through the NNP could be done through underground and submarine cables for the 7.4 km distance. The following advantages are possible with underground and submarine cables; • the habitat of the forest, especially birds will be safe from electrocution; • periodic trimming of the tree branches will be avoided.

However, the challenges with this approach will include:

• the use of submarine and underground cables could be too challenging and expensive to install for contractors; • operation and maintenance could pose challenges to NAWEC due to lack of the required human resource capacity; • operation and maintenance could be expensive as special tools are required for fault finding/ tracing as well as specials kits/hardware for maintained or repairs; • longer hours of power outages will occur as fault tracing and related repairs could take longer hours; • the underground cable trench, which could ideally be along the current feeder road in the Park can no longer be used as a feeder road by vehicles. This will mean a new feeder road or foot path has to be created within the Park and thus lead to the cutting of more trees for this purpose; • marine species could be affected by the presence of underground cable/sub-marine in rivers/ water bodies; • cable trenches could lead to formation of big gullies and ravines due to storm water and runoff in the rainy season; • trees within the cable trench will have to be uprooted completely, thus reducing the forest cover.

Use of Solar Mini Grid to Electrify the Jinack Islands Given that the end point of the Project is to supply the Islands, running transmission lines and cables through the NNP could be completely avoided by building a mini grid on the islands to serve the communities. This way the Park’s integrity will be preserved. The advantages of this system include the following: • since transmission lines will not be used within the Park, no felling of trees will be done; • digging of trenches to accommodate the cables will be avoided; • there will be no construction impact due to the use of heavy machinery and equipment; • no pollution of water bodies in the Park; • no electromagnetic effects within the Park; • no additional access route required to reach the Island because of the digging along the existing road to get to Jinack Islands; • there will be no need for maintenance of MV line, underground cable, or submarine cable;

• there will be no pollution of the environment due to CO2 emissions with use of fossil fuel in the operations of the machinery and equipment;

• No electrocution of habitat species.

The challenges involved in this approach will include:

• the high cost of the solar installation; • operations and maintenance for NAWEC due to challenges of the required/the availability technical capacity, (60 kW solar plant in Kaur is a case in point); • land acquisition for the solar park will lead to deforestation and possible RAP; • sustainability of the plant to the challenges of revenue returns as a result of inadequate the tariff; • challenges of river crossing with heavy equipment for civil and electromechanical works for the solar the plant.

Given the above, it will be recommended that the most appropriate system is the mini grid since this will avoid construction of any kind through the Park to teach the islands; this is followed by the overhead lines and poles, and the least preferred option being the use of underground and submarine cables through the Park.

B. Yellitenda/Bambatenda River Crossing Currently Soma and its environs are supplied from the power station in Farafenni through a submarine cable, a situation that has been in practice for over ten years now. During this period only a few times did the system break down, and indeed not as a result of equipment failure, but by the ferry which dislocated the cable at some point. Bringing back the power supply to Soma took over a month.

With the advent of the Project, Farafenni and the entire NBR and CRR-N will be supplied from the Soma substation, requiring a choice to be made between continuing to supply via a submarine cable; overhead transmission lines; or using ducts that have provided on the new Senegambia bridge, to carry the other national social service connections (NAWEC, Gamtel’s fiber optics, etc.) across the River Gambia. An assessment of the choices indicates the following:

Choice of Submarine Cables The advantages in the use of submarine cables include the following:

• no major civil works impact, such as pole foundation • no special equipment for stringing of lines across the river • no major impact on mangroves and habitat/species • no impact on bird species due to electrocution • no cutting or trimming of mangroves for the line corridor • water pollution could be avoided since there shall be no major civil works such as pole foundation.

The challenges will include the fact that:

• cables could be quite expensive; • challenges of installation and safely of personnel during works in the river; • challenges of fault tracing once a fault occurs leading to long hours of power outages; • potential challenges in operating and maintenance of fault tracing equipment due to inadequate capacity or knowledge;

• access to submarine cable is a challenge as it is normally on the riverbed; • expensive maintenance tools kits and special hardware and devices are required; • possible impact on marine life due to electrical cable in water/river.

Choice of overhead transmission lines The advantages of this system include the fact that:

• faults on the lines can be easily traced as the lines and associated hardware are visible • no special tools or devices are required for fault tracing • marine species within the river may be less affected • the navigation along the River is not affected as lines are normally built well above the required limit to accommodate vessels and other crafts that use river for tourism, commercial transport, fishing, etc. • periodic inspection of the poles and line hardware is less challenging.

Meanwhile the challenges include the fact that:

• the width of the river crossing is estimated around 1km, leading to challenges of overhead line crossing; • poles will be erected within the mangroves leading to significant tree cutting and trimming; • pollution of the water bodies due to civil and electromechanical works; • safety of bird species could be compromised due to electrocution of bird species; • cost of foundation for the poles /tower shall be enormous; • access channels for the heavy-duty equipment will lead to altering the landscape in the water bodies as well as additional mangrove cutting; • maintenance challenges will be numerous should a line be cut/damaged or other hardware material become faulty over the river. Access will be a challenge, and special equipment, tools, and manpower required to repair such incidences may not be available. iii. Choice of service duct on the bridge

With the advent of the new Senegambia bridge an underground cable suited for open/ exposed installation or in special ducts improvised in the bridge could be used for the river crossing. The advantages of this choice are:

• the cable to be use are less expensive compared to sub-marine cables; • with ducts already in place on the bridge meant for such utilities, installation challenges will be minimized; • impacts on the environment will be minimal as compared to overhead or sub-marine cable; • fault tracing and repair poses less challenges; • access to the cable is less challenging.

The constraints include:

• obstruction to traffic during installation of cable; • safety of personnel and equipment during installation as the bridge is high up; • possible damages to the ducts during installation of the cable;

• possible impact on the bridge structure as the cable carries significant weight; • current carrying capacity could be limited if the cable size does not correspond to the dimension and size of the ducts; • possible danger to motorists and pedestrians on the bridge due to current leakages.

In view of the above, it will be recommended that the use of the service ducts on the bridge be used to carry the power from Soma to Farafenni across the River.

The “No Project” Alternative Under a “No Project” alternative scenario, the adverse environmental and social impacts from the Project will not occur, but at the same time the potential Project’s benefits will not accrue to the communities. For example, without continuous electricity supply in the selected communities, the youth would not be able to develop skills and trades such as welding, carpentry, or other small businesses that rely on electricity to enhance their livelihood. In addition, women would not be able to produce ice blocks and cold drinks made from locally available plants such as baobab, “wonjo”, which are few of the livelihood activities they wish to undertake.

Without this Project, school, health infrastructures the Government offices in these areas will be without enough or sustainable electricity which would help them to meet their objective to properly serve the communities. The potential for small businesses to grow within these affected communities would never be realized without stable and sustainable electricity.

However, the Project benefits are expected to outweigh potential adverse impacts, as discussed in Sections 6.3 to 6.6; the benefits will enhance the socio-economic development of the country, enhance access to electricity services to communities, improve livelihoods and enhance social development nationally.

In conclusion, given the potential impacts posed by the Project within the proposed sites, the positive and negative risks will be assessed in the subsequent chapters afer which relevant recommendations will be made to address the impacts.

CHAPTER 3: RELEVANT NATIONAL AND INTERNATIONAL POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK

This Chapter describes the various national and international policies, legal and institutional frameworks, as well as the World Bank and ECOWAS safeguard policies that will guide the development and implementation of this ESIA and its ESMP. The relationships and relevance of these instruments viz-a-viz the Project are discussed.

3.1 Relevant National Policies Table 3.1 indicates the relevant national policies (listed in order of date adopted) that will guide the development and implementation of the Project.

Table 3.1: Relevant National Policies

Policy Description Relevance to the Project Policy provides a legitimate National Policy for the point of reference for Relevant to this Project since it Advancement of Gambian addressing gender inequalities will benefit both men and Women and Girls (1999-2009) at all levels of government and women equitably. all stakeholders Successful project Policy aims to mainstream implementation will National Youth Policy youth issues into the encourage youth engagement (2009–2018) advancement of all sectors in skills to reduce youth underemployment Provides guidance in general Gambia Environment Action Integrated environment and environmental planning and Plan, GEAP (2009-2018) natural resources management natural resources management. Sixty-six gazetted forest parks Promotes state and community are located in various parts of Forestry Policy (2010-19) forest development and the country, some of which management could be impacted by the project. Women will be consulted To mainstream gender in Gambia National Gender & widely and will be involved in national and sectoral planning Women Empowerment Policy the local monitoring and and programming to ensure (2010–2020) evaluation process during equity and equality project implementation. Protects public and Relevant to this Project since The National Health Policy, environmental health including dust, noise and other risks can 2012-2020 nuisance and other risks be associated with the project associated with this Project activities. All national electricity projects National Energy Policy (2014 – Policy aims to increase are implemented within the 2018) electricity coverage nationally context of this Policy Seven gazetted national parks and wildlife reserves are in The National Biodiversity The NBSAP recognizes the various parts of the country Strategy and Action Plan conservation and sustainable that could be impacted by the (NBSAP), 2015 use of biodiversity Project. In addition, other ex- situ biological diversity could be impacted as well Policy provides the framework Promotes energy efficient for managing climate risks, options by, for example, National Climate Change building institutions, capacities, encouraging energy Policy (2016 – 2025) and opportunities for climate- conservation and the use of resilient development renewable energy

Road Map plans to improve power generation and transmission capacity NAWEC.

ECOWAS-REAP aims to The National Electricity Road In addition, aims to increase increase access to electricity Map 2017-2021 absorption capacity for the throughout the Region. expected increase in generation capacity, and to reduce transmission and distribution losses National Strategic Applies when developing Aims to ensure environmental Environmental Assessment policies, plans or programs in sustainability Policy (2017- 2021) all sectors, including energy One of the five strategic priority outcomes for Energy and Infrastructure is the National Development Plan Policy proposes to increase the “improved access to electricity (2018-2021) national coverage of electricity and enhanced household energy security for sustainable economic development”. NAWEC’s electricity projects Defines the priorities and usually follow national road National Transport Policy, objectives in the transport alignments under, and these (2018-2027) sector, aimed to serve the roads and road reserves are country’s development goals. managed under this policy Source: SD Focus Ltd, 2020

3.2 The National Legal Framework The legal framework that will guide the Project’s implementation are indicated in Table 3.2 below, listed in order of date enacted.

Table 3.2: The Legal Framework Relevant to the Project

Title of Legislation or Description Relevance to the Project Regulations All lands in the NBR, CRR, Regulates land tenure and property LRR, and some of parts of rights as well as general land WCR (Kombo East and the administration in areas under Lands (Regions) Act, 1945 Foni) fall under this Act. Customary Land Tenure system. Act Potential project sites are covers all Provinces land outside held and administered under State Lands Areas. this Act. All lands in the Kombo North, Kombo South, and Kombo Regulates land tenure and property Central fall under this Act. State Lands Act, 1990 rights as well as general land Potential project sites in administration in State Lands areas. these areas are held and administered under this Act Public Health Act, 1990 Protects public and environmental Relevant to Project since

Title of Legislation or Description Relevance to the Project Regulations health including abatement of dust, noise and other risks nuisances and any condition that can be associated with the may be injurious to health. Project. Project might cause involuntary resettlement due to certain project activities Provides for consultation, such as tree felling, Land Acquisition & resettlement, and compensation of destruction of crops during Compensation Act, 1990 land. line construction, etc. and the Act could be used in resettlement as compensations. Ensures developments in The The project construction Physical Planning and Gambia are in line with land use activities shall be in line with Development Control Act, planning and construction national land use and 1991 standards. planning rules. Principal legislation in environmental management; Part V This Project falls under National Environment of Act provides for certain projects Schedule A which requires an Management Act, 1994 listed under Schedule A to be ESIA. considered for ESIA. Project implementation has Regulations declare standards set potential to generate dust, Environmental Quality out in Schedule 1 in respect of and to pollute surface fresh Standards Regulations 1999 ambient air, saline waters, surface waters as are found along fresh waters and groundwater. some of the project corridors. Act regulates the activities of The Gambia Public Utilities providers of certain public utilities in NAWEC, the proponent of Regulatory Authority Act, the various economic sectors, this project will be regulated 2001 including electricity, petroleum, and by this Act. gas. Project implementation has Regulations require that a permit is potential to discharge obtained for most discharges of Environmental Discharge potentially polluting liquids potentially polluting liquids into or (Permitting) Regulations into the tributaries and other onto the ground (i.e. to 2001 surface water bodies as may groundwater) or into surface waters be found with the project’s (such as rivers or streams). Area of Influence (AoL) Implementation of the Project will require the Act makes provisions for participation of decentralized decentralized administrative institutions including the Local Government Act, 2002 structures including devolution of Offices of the Governors of functions, powers, and duties to CRR, NBR, and LRR, as well as local authorities their respective Technical Advisory Committees (TACs). Act created the National Roads The transmission lines will be Gambia Roads Technical Authority to be responsible for the constructed along the Road Services Authority Act, 2003 maintenance, construction, and Reserves of the national

Title of Legislation or Description Relevance to the Project Regulations safety of the national road network, roads network and Road Reserves. The Act prescribes the institutional framework and requirements for managing these road reserves, and the Poles will be within the road reserves Specifically, NNP will be impacted by the transmission lines that will be constructed through the Park to the communities of Jinack Niji Provides for the protection of Biodiversity and Wildlife Act, and JinackKajata. biodiversity and the establishment 2003 All biodiversity, within and of protected areas outside the gazetted protected parks, that are in the Project’s direct area of influence may also be affected Act empowers the Council to assume control and preserve, restore any monument, relic, Transmission lines will National Council for Arts and ethnographical article, or other potentially impact the Stone Culture Act, 2003 article of archaeological Circles in Kerr Batch, in CRR-N ethnographical, or historical relevance. Promotes the development of the As the main proponent of the electricity sub-sector on the basis of project NAWEC and other Electricity Act, 2005 the principles of a competitive and electricity service providers market-oriented economy. are regulated by this Act. Act sets out the rights and Rights of children impacted responsibilities of children and The Children’s Act 2005 by the project need to be provides for their care, protection, protected. and maintenance Pole construction, including Act makes provision for prospecting pole mounted distribution for minerals, for carrying out mining substations, during project Mines and quarries Act, 2005 and quarrying operations including implementation involves use gravel, sand, and for connected of sand and gravel aggregates matters mined along the road corridor. Provides the legal framework for The project hiring and administration of labor, recruitment management of its labor Labor Act (2007) and hiring of labor, and protection force should adhere to this of wages framework Addresses waste management and The project must ensure that Anti-littering Regulations, pollution issues in relation to all waste produced during all 2007 environmental health and hygiene phases is well managed. The Women’s Act 2010 Aims to advance women’s rights to Relevant to this project in

Title of Legislation or Description Relevance to the Project Regulations land and natural resources in order view of potential impact on to promote their economic and agricultural land farmed by social empowerment women; need for adherence to OP 4.12; avoid gender- based violence (GVB) and sexual exploitation and abuse (SEA) The EIA Regulations elaborate on The Regulations provide Environmental Impact the requirements for EIA more details for the EIA of Assessment Regulations, procedure, environmental impact this project and 2014 statements, approval, implementation of its ESMP. environmental monitoring, etc. Sixty-six gazetted forest parks are located in different parts of the country, including Provides framework for proposed Project sites; some implementation of Forestry Policy, of these may potentially be The Forest Act, 2018 and framework for the reservation affected by the Project. This and management of forests. ESIA recommends that all forest parks, including community forests be avoided This Act is relevant to the Project due to the need for Updates the law and procedures protection of vulnerable Sexual Offences Act, 2013 regarding the trial of rape, sexual persons within the Project offences, and related matters sites against sexual offences, which is defined in the Act Source: SD Focus Lts., 2020

3.3 Relevant International Conventions and Agreements The most important of these international conventions and agreements to which Gambia is a Party that are relevant in this Project are as indicated in Table 3.3 below.

Table 3.3: Relevant Regional and International Conventions Signed/Ratified by The Gambia Date of Agreement/Convention signature / Objective Relevance to the Project Activities ratification This Project prepares for future Promotes energy capacity expansion to accommodate ECOWAS Energy Protocol Signed 2003 investment and regional projects such as those of the A/P4/1/03 trade in West Africa OMVG, West African Power Pool (WAPP). The CBD promotes The project activities will lead to the not only the vegetation destruction and the United Nations protection of flora stripping of soil (use of quarry for the Convention on Biological Ratified 1994 and fauna, but construction of works), burning in Diversity (CBD) linkage with humans preparation to install base camp, poles, and dependence on etc.). The project is challenged by this

Date of Agreement/Convention signature / Objective Relevance to the Project Activities ratification such biodiversity for convention. This ESMP of this study has food, medicine, defined measures to rehabilitate shelter etc. degraded sites by the works to prevent the loss of biodiversity The project activities will lead to the vegetation destruction and the stripping of soil (use of quarry for the construction of works), burning in Protection of forests preparation to install base camp, poles, Convention to Combat Ratified 1996 to avoid Desertification (CCD) etc.). The project is challenged by this desertification convention. This ESMP of this study has defined measures to rehabilitate degraded sites by the works to contain desertification.

United Nations Relates to all energy The loss of trees and vegetation will Framework Convention projects with regards Ratified 1996 mean loss of “green cover” and loss of on Climate Change to sustainable carbon capture footprint (UNFCCC) sourcing Project has potential for resettlement Convention ensures as a result of project activities, United Nations the full development especially on farmlands cultivated by Convention on the and advancement of women; the Convention highlights the Elimination of all Forms women, for the right of women to own, manage, of Discrimination Against purpose of enjoy and dispose of property is Women (CEDAW) and guaranteeing them Ratified 1993 central to their financial the Optional Protocol to the exercise and independence and may be critical to the Convention on the enjoyment of human their ability to earn a livelihood and Elimination of All Forms rights and to provide adequate housing and of Discrimination against fundamental nutrition for themselves and for their Women (OP-CEDAW) freedoms on a basis children; women should have access to of equality with men benefits of this project as men The rights in the treaty include the The project could potentially affect the United Nations right to education, right to health of the child through the Convention on the Rights the right to play, the generation of dust, and air pollution, Ratified 1990 of the Child, right to health and poor waste management, and spread (UNICEF1989) the right to respect of malaria due to stagnant water in for privacy and family quarry pits life The Convention intends to protect Convention on the rights the rights and dignity Persons with disabilities could of persons with Ratified 2013 of people with potentially be impacted negatively by disabilities (CRPD) 2006 disabilities; to the project activities

promote, protect, and ensure the full

Date of Agreement/Convention signature / Objective Relevance to the Project Activities ratification enjoyment of human rights by people with disabilities

Convention aims to The Convention identify and protect Concerning the Project implementation could the world’s natural Protection of the World's potentially impact natural or cultural Ratified 1987 and cultural heritage Cultural and Natural sites such as graves, mosques, or other considered to be of Heritage (1972) cultural relics outstanding

universal value Convention on Wetlands Convention is aimed of International Project will be implemented along at the conservation Importance especially as Ratified 1998 certain corridors that have wetland and sustainable use Waterfowl Habitat environments and ecology of wetlands (RAMSAR Convention) Also known as the Bonn Convention, aims to conserve Convention on Migratory Project will be implemented in the terrestrial, aquatic, Species (CMS Signed 2001 within areas that are flyways of and avian migratory Convention) migratory birds species throughout their range

Source: SD Focus Ltd., 2020

3.4 Institutional Framework The institutional framework relevant to the implementation of this Project is as indicated in Table 3.4.

Table 3.4: Institutional Framework

Institutions Specific Responsibilities Interests and roles in this Level of intervention Project implementation

National Environment The NEA enforces the Evaluation of the ESIA report; All phases of the Project from Agency (NEA) NEMA,1994 and EIA grant Environmental Approval planning and design to the Regulations 2014 for the Project; construction and operation monitoring the ESMP implementation Ministry of Oversees the NEA and Policy guidance; All phases of the Project from Environment, Climate implementation of oversees the Department of planning and design to the Change and Natural environmental laws and Forestry and Department of construction and operation Resources policies of The Gambia Parks and Wildlife Management that are key to this Project Ministry of Lands and Oversees all the local The Ministry will support in the Pre-construction, Regional Administration government authorities. coordination of involuntary construction, and operation Its regional settlement as it enforces all legal phases representatives are the regulations on land TACs located in the offices administration and land use of the Regional Governors. Governors Offices, CRR, Oversee the Regional The TACs will support the Pre-construction and LRR, NBR Technical Advisory implementation and monitoring construction phases Committees (TACs) for processes at Regional levels CRR, LRR, NBR Ministry of Health Responsible for overall Provides guidance on Pre-construction, formulation and direction transmissible diseases to construction, and operation of the national health consider during sensitization phases agenda, planning and promotes safe and healthy health infrastructural environments at projects sites development responding to accidents National Water and As the implementing arm NAWEC is the executer of this All phases of the Project Electricity Company of the MOE, NAWEC is the Project in The Gambia (NAWEC) main operator and coordinates and monitors the manager of electricity Project ESMP implementation production in The Gambia through its PIU Department of Forestry Responsible for the Advises on forest boundaries Pre-construction, (DOF) maintenance and relative to the Project sites; construction, and operation development of forest Implements forest restoration / phases resources in The Gambia. replanting plans where It recommends sites for available. forest reserves and parks, Monitors encroachment of community forests and forests by the Project private forests, and monitors their management for sustainability

Institutions Specific Responsibilities Interests and roles in this Level of intervention Project implementation

Department of Parks DPWM is responsible for Advises on national parks and Pre-construction, and Wildlife the maintenance and reserves that fall within the construction, and operation Management (DPWM) development of National Project area of influence; phases Parks and Reserves It is responsible for NNP, one of the major environmentally sensitive features to be potentially impacted by the Project National Roads NRA is responsible for Protects the road reserves along Pre-construction and Authority overall planning, the main highways and feeder construction phases construction, roads that will accommodate maintenance, and the transmission infrastructure management of the of the ECOWAS-REAP; country's roads. -Advises on future plans, and procedures for road development that may require relocation of the T & D infrastructure National Council for Arts The Council is responsible -Confirms sites of historical Pre-construction and and Culture (NCAC) for the control, importance with the Project construction phases preservation and area of influence; restoration of any -Prescribes the buffer outside monument, relic, which T & D structures may be ethnographical article of erected ; historical relevance -Monitors encroachment. Women’s Bureau Under the Ministry of -Ensures the rights women Pre-construction, Women, Children and affected by the Project are construction, and operation Social Welfare, the protected; phases Women’s Bureau -Participates in sensitization on specifically promotes gender issues. gender equity and women’s empowerment in The Gambia. Department of Social This department protects Supports and guides the process Pre-construction, Welfare and promotes the rights during related grievances and construction, and operation of vulnerable people such participates in sensitization on phases as children, women and GBV, SEA, VAC etc. the disabled. Department of Labor Enforces employment Protection of employee rights; Pre-construction, laws and combats child Protection against child labor; construction, and operation labor Response to complaints and phases reports such as accidents, abuse, and discrimination at work

3.5 Institutional Analyses NEA, supported by a multi-sectoral Environmental Impact Assessment (EIA) Working Group, is the custodian of the EIA process in the Gambia. It is in this capacity that it serves as the Secretariat of the EIA Working Group which is composed of different public and private sector Institutions. All these institutions are relevant in the implementation of this Project and by virtue of their respective sectoral mandates have some fair level of capacity in environmental management.

However, other Institutions such as the National Council for Arts and Culture (NCAC), the Women’s Bureau and the Department of Social Welfare are also relevant in the implementation of the Project but are not members of the EIA Working Group. By their individual sectoral mandates, these Institutions have limited capacity and experience in environmental management and therefore would require some form of capacity enhancement.

3.6 Relevant Bank Policies The following environmental and social safeguard policies of the World Bank have been triggered by the ECOWAS-REAP.

Table 3.5: World Bank Environmental and Social Safeguards Relevant to the Project Operational Policy Applicability and relevance to Objective (OP) triggered the Project The objective of this policy is to ensure that projects financed by the Bank are viable and environmentally feasible. It covers the impacts on the physical environment (air, water, and land, OP 4.01 The project is challenged by etc.); the living environment, health, and safety of Environmental this policy because the populations; physical cultural resources; and Assessment planned activities are going to environmental concerns at cross-border and (including public generate risks and negative global level. participation and environmental and social Diffusion: OP 4.01 also describes the consultation stakeholder impacts. Hence the need to and dissemination requirements. For Category A engagement) carry out this ESIA. and B projects and sub-projects. This policy is triggered if a project is likely to cause risks and potential (negative) environmental impacts in its area of influence. OP 4.04 Natural To support the protection, maintenance, and There are swamps, wetlands, Habitats rehabilitation of natural habitats and their and waterbodies along the functions in its economic and sector work, project Project corridor that are home financing, and policy dialogue. The Bank supports to various invertebrates, and expects borrowers to apply, a precautionary mammalian, including avian approach to natural resource management to fauna. The Nuimi National ensure opportunities for environmentally Park consists of different sustainable development. habitat types including wetland ecologies. OP 4.11 Physical To assist countries to avoid or mitigate adverse At the village of Kerr Batch in Cultural Resources impacts on physical cultural resources from Nianija are a set of stone circles development projects that are financed by the (indeed a UNESCO World WB. The impacts on physical cultural resources Heritage Site) that could be resulting from project activities, including impacted by the poles and

mitigating measures, may not contravene either transmission lines. Others the borrower’s national legislation, or its include mosques and obligations under relevant international cemeteries along the Project environmental treaties and agreements. trajectories. OP 4.12 Involuntary The overall objectives are: resettlement of “(a) Involuntary resettlement should be avoided populations where feasible, or minimized, exploring all viable alternative project designs. (b) Where it is not feasible to avoid resettlement, The project has constraints as resettlement activities should be conceived and there is likelihood of social executed as sustainable development programs, impacts which may lead to providing sufficient investment resources to involuntary resettlement due enable the persons displaced by the project to to loss of economic trees, share in project benefits. Displaced persons agricultural crops, temporary should be meaningfully consulted and should have loss of earnings and loss of opportunities to participate in planning and other livelihood as a result of implementing resettlement programs. the Project. Thus, this OP is (c) Displaced persons should be assisted in their triggered. efforts to improve their livelihoods and standards of living or at least to restore them, in real terms, to pre-displacement levels or to levels prevailing prior to the beginning of project implementation, whichever is higher OP 4.36 Forests “The objective of this policy is to assist borrowers to harness the potential of forests to reduce The Project is challenged by poverty in a sustainable manner, integrate forests this OP as there are Forest effectively into sustainable economic Parks, and Community Forests development, and protect the vital local and that may be affected by the global environmental services and values of implementation forests”.

3.7 Relevant ECOWAS Environmental and Social Safeguards triggered by the Project Table 3.6 below presents the ECOWAS Safeguard policies triggered by the Project.

Table 3.6: ECOWAS Safeguard Policies Triggered by the Project

ECOWAS Environmental Applicability and relevance to the Objective Safeguards Project “To promote long-term cooperation in the energy field, The ECOWAS Energy Protocol is based on complementarities and relevant to this ESIA as it states ECOWAS Energy Protocol mutual benefits, with a view to that energy projects must be (Protocol A/P4/1/03) achieving increased investment in evaluated and implemented for the energy sector, and increased environmental sustainability. energy trade in the West Africa region”. ECOWAS White Paper for To ensure increased use of Although the ECOWAS-REAP Increasing Access to Energy renewable energy sources such as focuses on transmission and Services, 2006 solar, wind, small-scale hydro, and distribution, rather than electricity bioenergy for grid electricity production, it is relevant to this

supply and for the provision of Project as it increases access to access to energy services in rural energy. The energy to be areas. transmitted is from renewable sources, dams. To also assist the ECOWAS Member States to develop appropriate regulatory frameworks for the promotion of renewable energy technologies and services, thus reinforcing regional integration in the renewable energy sector. ECOWAS Environmental To promote, guide and facilitate Policy 2008 common understanding and This Policy is relevant to the approach within the ECOWAS ECOWAS-REAP as it applies to all Region for the control of land member countries, including The degradation, erosion, and Gambia. The Policy also aims to desertification; loss of protect natural resources which are biodiversity; degradation of river likely to be impacted by the Project. and lake water resources; and

degradation of coastal maritime ecosystems.

In conclusion, it will be noted that the policy and regulatory framework specified above will guide the development and implementation of the report; successful project implementation is based on the Project’s adherence to these requirements.

CHAPTER 4: DESCRIPTION OF THE CURRENT STATE OF THE ENVIRONMENT OF THE PROJECT AREA

This Chapter describes the baseline conditions of the environment of the Project area. It delineates the Project area under geographical and administrative regions; describes the current physical, biological, human and socio-economic environments under direct and indirect areas of influence; and identifies the main stakes and risks of the Project that need consideration to ensure success.

4.1 Geographical and administrative location of the project area The Soma sub-station will connect the communities through four feeders running through 22 Districts in LRR, NBR, and CRR as indicated in Table 4.1 below. Table 4.1: Project Affected Districts

SUB-STATION DISTRICTS COVERED REGION Soma Kiang East; Kiang Central; Kiang West; Jarra East; Jarra Central; LRR Jarra West Jarra West; Jarra Central; Jarra East LRR Upper Badibou; Central Badibou; Jokadu; Lower Badibou; Upper NBR Niumi; Lower Niumi Lower Saloum; Upper Saloum; Niani; Sami; Nianija CRR Upper Fulladu West; Lower Fulladu West; Niamina East; Niamina CRR Dankunku; Niamina West Source: SD Focus Ltd., 2020

4.2 Delimitation of the Study Area This section describes the direct and indirect areas of interest of the Project, and also the general environmental baseline conditions of the study area. Indirect areas of influence are the three Regions, and 22 Districts where the Project sites are located. The direct areas of influence (the exact sites of the Project implementation) are the 46 corridors where the lines will run through, including the distribution substations.

The delimitation of these two areas of influence was derived by a GIS analysis of the available data. Specifically, the identified project villages (direct areas of influence) were delimited by overlaying the 100 km buffer created around the proposed Soma substation. The result of this analysis is indicated in Figure 4.1 showing the administrative location of the Project sites, which also highlights the Project’s indirect areas of influence.

Regarding the baseline conditions of the study area, it will be noted that, in general the conditions will not be very different from one corridor to the other, especially given the small size of the country; issues such as climate, relief, landform, forest and vegetation cover are for the most part similar. In this regard, the description will be general in nature, but where an issue of critical environmental, social, and cultural significance is encountered along any corridor, it will be reviewed specifically, and addressed accordingly.

Figure 4.1: ECOWAS – REAP: Administrative Locations and Areas of influence of Soma Feeder Lines Source: SD Focus Ltd.2020

4.3 Current State of the Environment of the Indirect Areas of Influence

The Biophysical Environment

I. The Physical Environment

➢ Climatic Conditions The climate in the Gambia is of the Sudano-Sahelian type and is characterized by the occurrence of two distinct seasons: a hot rainy season from May/June to October, and a dry season from November to May with rare occurrence of rainfall in May. Rainfalls are typically heavy nationally, but the south- western part of the country records more rain than the eastern portion, as indicated in Table 4.2 below. July, August, and September are the highest rainfall months.

During the rainy season, south-westerly monsoon winds combined with heat from the continent, and because of the northward movement of the wind, give rise to the formation of thundery activities. These are usually accompanied by strong winds and heavy downpours, causing localized flooding and erosion, especially of edges of streams, culverts, and bridges located along some of the main road corridors. This is of vital importance in those proposed Project sites prone to erosion and flooding. Transmission poles erected in these types of environments can be impacted by this phenomenon.

Table 4.2: Recorded Annual Rainfall in Project Regions (mm) (2009-2018) YEAR/REGION LRR CRR-N CRR-S NBR ANNUAL MEAN 2009 999.4 1002.1 655.2 1,297.8 1,074.6 2010 1194.1 998.8 867.2 1,134.5 1,080 2011 634.4 846.3 689.4 533.8 717 2012 1558.1 901.8 922.4 1,515.2 1,254.3 2013 900.7 896 1,039.8 788.2 929.4 2014 607.4 668.1 489.4 615.9 598.9 2015 984.1 668.5 797 1,140.5 968.7 2016 1156.3 952.4 860.4 827 923.7 2017 930.6 696.6 813.3 943.9 850.5 2018 745.8 567.7 854.5 645.5 740.7 REGIONAL MEAN 971.1 819.8 798. 8 944.2 Source: Department of Water Resources, 2019

In the dry season (during the months of December to April) north-easterly winds (the Hamattan) blow from the Sahara towards the western coast of Africa resulting in the presence of dust particles in the air, and general cloudless skies and dry air. Much sunshine is received all year round throughout the

38 country. Monthly mean temperatures in the rainy season vary between 29oC and 32oC, and from 15oC to 23oC in the cooler dry season.

➢ Hydrology Surface Water The surface hydrology within the Project’s sphere of influence is mainly the River Gambia, which gets its source from the Fouta Djallon Highlands in Guinea, flowing westward towards the Atlantic Ocean, via communities in which the Project will be implemented. A mosaic of tributaries has branched off from the main river system and have become major areas of economic activity for the riparian populations through which the tributaries and streams pass.

Along some of the proposed line corridors of the Project, permanent “bolongs” (“bolong” is Mandinka meaning tributary) and seasonal freshwater lakes were encountered. In Nianija District, in CRR-N these include the Nianija and Nianimaro “bolongs” which are permanent tributaries originating from the River Gambia.

The Shallow Sand Aquifer (SSA) System The Shallow Sand Aquifer (SSA), found throughout the Gambia and much of Senegal, is tapped throughout the Gambia for water supply. This aquifer system from the MioPliocene age occurs at depths between 15 and 120 m below ground level.

Within the Gambia, the SSA is subdivided into two, the Upper Phreatic Aquifer and the Lower Semi- confined Aquifer. The two are separated by a clay-silt aquitard. The SSA is composed in average of medium to coarse sand.

The Upper Phreatic Aquifer: All hand-dug wells and some shallow boreholes along the proposed corridors feed from the Upper Phreatic Aquifer. This aquifer comprises mainly fine-to medium grained quartz sands with intercalations of silt and clay. The relatively thin aquifer (with a thickness between 1 to 20 m) occurs at depths between 10 and 30m which is mostly the depths of local wells within the proposed Project sites.

The Lower Semi-confined Aquifer: The majority of boreholes (mostly provided by Government as portable water for the communities) in the various communities targeted by the Project tap this aquifer, which is constituted of mainly yellow-white fine- to medium-grained sands. The aquifer depth varies between 10 and 50 m below ground level. The groundwater level is generally found at depth between 10 to 20 m. Groundwater generally flows from South to North. The transmissivity

39 values range from 100 m2/day to over 750 m2/day. The hydraulic conductivity ranges from 5 to 20 m/day. The Deep Sandstone Aquifer (DSA) System The Deep Sandstone Aquifer (DSA), is constituted of Palaeocene and Maastrichtian sandstones; it underlies the whole of the Gambia and a large part of Senegal. It is confined by a 200 m to 300 m thick sequence of mainly clays and marls. The groundwater in this aquifer moves from east to west; it is of fossil origin and 4,000 to 40,000 years old. This aquifer is tapped in most countries in the sub- region. However, it is not used for drinking water supply in the Gambia.

Geology and Soils The geomorphology of the Gambia is dominated by the Gambia River, which divides the country into two strips of land no wider than 30 km. From the river outwards, there are three topographic regions: the valley bottom; dissected plateau with sand; a sandstone plateau.

The Valley Bottom

The valley bottom is the area immediately along the Gambia River and its tributaries and is characterized by poorly drained alluvial sediment formations. These areas are subjected to regular seasonal flooding. The combination of low-lying topography, poorly drained soils and abundant water provides unique and diverse habitats. The seasonally inundated swamps or Faro in Mandinka appear on either side of the river for more than 2km away from the river.

The soils and vegetation in the valley bottom are primarily influenced by the hydrology, in the western third of the Gambia, the river water is salty or brackish and as a result the clayey and alluvium soils are heavily impregnated with salt.

Dissected plateau with sandy hills

Upland, from the River, the country is dominated by dissected plateau with sand hills. This area is characterized by gentle rolling sand hills alternating with shallow valleys. In the coastal region, the soils are generally unconsolidated marine and aeoline sand with intermittent low-lying sand dunes. In central and eastern Gambia, the plateau is broken up by few flattop laterite sandy hills. The plateau is the center for groundnut (the country’s number one cash crop) and coarse-grains (millet and sorghum) production.

Sandstone Plateau

The eastern end of the country consists of low, rocky sandstone hills, which extend into Senegal. The hills (occupying about 4% of the total land area) are often unproductive rugged, uncultivated, and un- vegetated. The soils of this region are infertile but respond well to phosphate and nitrogen. Major crops in this area are groundnuts and millet.

➢ Topography and Land Use As in many parts of The Gambia, the topography in the Project’s area of influence is generally flat and low-lying with an approximate altitude range of between 12.2 m to 51.2 m GD. Areas of high ground

40 occur mainly in the CRR. These include sloppy hills located in Kaur (CRR-N) (approximately 37 km from Farafenni, the Jahally hills (CRR-S) located 40km from Bansang.

Much of the proposed line corridors in the respective Regions run through predominantly agricultural land.

II. The Biological Environment

➢ The Vegetation and Forest Resources The following vegetation types are found along the proposed line corridors:

Riparian Vegetation A riparian vegetation or riparian woodland is a forested or wooded area of land adjacent to a body of water such as a river, stream, lake, marshland, estuary, or reservoir. This vegetation type is found along corridors with swampy and marshy environment such as the wetlands of the Nianija “bolong” (at the Chamen bridge on the Njau/Carols Wharf corridor) in CRR-N), and the Nianimaro “bolong”, (specifically near the “loumo” site at Nyanga bantang, where the “bolong” crosses the road alignment. The vegetation within these areas includes reeds, shrubs, and herbaceous plants; it is likely that some parts of these habitats and vegetation will be affected by the line routing which will be close to the road alignments.

Mangrove Vegetation One of the main habitat types along some of the corridors is the mangrove habitat; it is found within the NNP in Lower Nuimi, NBR, and along the Nianija and Nianimaro “bolongs” in CRR. Mangrove forest dominates the “bolong” fringes within the NNP occupying a total area of approximately 800 ha. The species found are the red mangrove (Rhizophora spp.), and the white mangrove (Avicennia sp.). There is also the salt tolerant species such as the bitter leaf (Vernonia colorata); the following woody species, as indicated in Table 4.3 are found within the mangrove belt.

Table 4.3: The Mangrove Vegetation Along some of Proposed Corridors

Scientific Name Common Name Source of identification During Reported by Bibliographic field visit Locals/DPWM Research Rhizophora harissionii Red mangrove X X Laguncularia racemose White mangrove X X Avicennia nitida Black mangrove X X Conocarpus erectus button mangrove X X Rhizophora mangle Red mangrove X Vernonia colorata Bitter leaf X X X Source: DPWM, 2019

The Wooded Savannah The wooded savannah is defined as having a canopy cover of more than 40 percent and reaching a height greater than 8 m and is found along most of the proposed corridors. The dominant species found within these vegetation types are the African locust beans (Parkia biglobosa), and the rose wood (Pterocarpus erinaceus). Shrubby species found include the bush willows (Combretum nigricans), and the Chinese date (Ziziphus mauritiana).

Table 4.4: Vegetation Found in Wooded Savannah along the Project Corridors

Scientific Name Common Name Source of identification During Reported by Bibliographic field Locals/DPWM Research visit Parkia biglobosa African locust beans X X Pterocarpus erinaceus Rose wood X X Combretum nigricans Bush willows X X Ziziphus mauritiana Chinese date X X Parinari macrophylla Gingerbread plum X X Ficus spp Fig trees X X X Tamarindus indica Tamarind/ Dakharr X Adansonia digitate Baobab X X Cordyla pinnata Bush mango X Andropogon gayanus Gamba grass X Asystasia gangetica Chinese violet X Commelina benghalensis) Tropical spiderwort X Synedrella nodiflora Cinderella weed X Echinochloa colona Jungle rice X Detarium senegalense ditax, ditakh, tallow X Source: Source: SD Focus Ltd., adapted from NNP Management Plan, 2020

The perennial Gamba grass (Andropogon gayanus), which reaches heights of over 2 m, is common, and is considered one of the best grazing grasses; makes valuable hay and green fodder grass, and young shoots are preferred, but cattle will eat it up to time of flowering.

There is a wide range of weeds including weeds associated with arable or disturbed ground, including the Chinese violet (Asystasia gangetica), tropical spiderwort (Commelina benghalensis), and the Cinderella weed (Synedrella nodiflora). Other grasses which occur include Echinochloa colona, (commonly known as jungle rice) and Chloris spp. or windmill grass or finger grass.

The above species are more dominant in locations where there has been clearance for agriculture in the past, or a high incidence of fire damage to the vegetation giving rise to bushland or thicket. They are found along the various proposed corridors including the corridors of Kanuma-Jinack; Njau-Carols Wharf; Mbolletba-Mbamkam; Suwareh Kunda – Njawara, among others.

Sabach Sukoto-Mballow Omar Tega corridor in Upper Badibu, NBR. In the communities of Tambakoto and Basik, at least 17 cashew and 10 mango trees have been identified as potentially vulnerable to the transmission lines. These trees (see Table 4.5) are important as a source of supplementary food for families, and in some instances, the fruits provide cash to the owners when harvested and sold at the local “loumo”. Mangos also provide shade for family and individual relaxation. Thus, felling the trees by NAWEC’s contractors to make way for the lines could deprive these families of both food and income sources.

Table 4.5: Fruit Trees along the Corridors Scientific Name Common English Name Source of identification During Reported by Bibliographic site visit Locals/DPWM research Mangifera indica, Mango x X Adansonia digitate Baobab x X Anacardium occidentale Cashew x X Source: SD Focus Ltd., adapted from DPWM, 2019

Others fruit trees include the baobab (Adansonia digitata), which is planted for its shade as well as for food, its fruits are eaten and have certain uses as medicine, and women make drinks from it for supplementary income; its leaves are used as vegetables, for sauces; its bark can be used as rope for tethering cattle.

It is not uncommon also that whole trees are felled to make way for transmission lines, and this could include both private fruit trees and forest trees located along the trajectories of the lines. Contractors should ensure they fell only trees that need to be felled (e.g. if sited on a pylon location) and prune the rest. Private trees should not be impacted (pruned or felled) without the consent of the owners, and indeed where they must be impacted, a RAP should be developed to address any potential social impacts. By the same token forest trees that need to be felled must be noted, and in consultation with the DOF a tree-replacement program developed; after all, the loss of “green cover” and loss of carbon capture footprint as a result of the felling needs to be managed. In addition, private forest trees (Eucalyptus trees owned by Kolior Lower Basic School, under Feeder 2) will be included in the RAP for compensatory reforestation.

➢ Wetlands Along the Corridors Wetlands in the Gambia are essentially three types; the marine and coastal types found mainly in shallow marine waters, estuarine waters, and intertidal mud flats; inland water type wetlands, which include permanent and seasonal rivers, riverine flood plains, freshwater marshes, seasonal freshwater lakes; artificial type wetlands which essentially are mainly irrigated land such as rice fields, etc. Parts of some of these water bodies serve as fishing areas for the local communities, cattle drinking and watering points, and the adjacent plains used for rice cultivation.

The Nianija “bolong” (tributary) in CRR-N is 190 m at its widest point and passes through the flood plains of the communities of Gui Jahanka, Bati Ndar, Chamen, Sita koto, and Carols Wharf. A concrete- steel bridge (about 75 m wide) crosses the “bolong” at its narrowest point near the village of Chamen, connecting the two banks along the Njau Sawalo/Carrols Wharf corridor. It is at this point that the proposed transmission line will cross the “bolong”, and this is within an expanse of more than 500m of wet and swampy ground and densely vegetated with reeds (see Figure 4.2, part of the wetlands near the Chamen Bridge). The construction of poles (at least 5 poles will be needed here) and lines within this area will have to use technologies that will protect the poles from collapsing over time due to saturation of the ground, and at the same time maintain the integrity of the ecosystem.

Figure 4.2: Wetlands along the Njau Sawalo/Chamen Carols Wharf Corridor

SD Focus Ltd., April 2020

For swampy or wetland areas within the Project area, poles higher than 12 m with required standard characteristics are preferred to ensure enough clearance from ground, achieve lower pole spans say up to 150 m thus reducing the number of poles to be erected within those wetlands. Sample of pole construction methods suited to these types of environments is indicated below in Figure 4.3.

Figure 4.3: Appropriate pole construction methods in wetlands

Source: SD Focus Ltd., April 2020

The Nianimaro “bolong” (also a permanent bolong) crosses the main highway along the Njau/Nyanga Bantang road corridor, close to the “loumo” (weekly market) site in the village of Nyanga Bantang. The “bolong” crosses the main highway from the south to the north via a culvert of about 5 m wide. At this point along the highway the width of the stream is about 75 m, and the ground is waterlogged and marshy with the embankments vegetated by reeds and thorny bushes. A similar situation is found here as in construction methodology will be applied here as in Chamen.

Along the Jarreng/Choya transmission corridor in Niamina West District CRR-S are two water bodies located in Jarreng and Kumbaniye respectively. These swamps are watered by the Pasul “bolong” which originates from the River Gambia and drains into the swamps of these communities. The expanse of the two water bodies at their narrowest points (along the road alignment) is more than 100m; the water crosses from one side of the highway to the other via culverts. The wide expanse of marshy and muddy ground will possibly accommodate at least two poles. In this case the design of the pole location will have to be similar to the Chamen type.

Along the Kolior Nyamala and Jomar corridor in Kiang East (LRR), a swampy area measuring about 100 m wide between these communities was encountered; the water has generally dried up at this time of year, and only scattered vegetation can be observed. However, at the height of the rains the entire area could be waterlogged and locating transmission lines across this swamp will have to use appropriate engineering designs to protect the poles, and at the same time maintain the integrity of the ecosystem.

➢ The Fauna The fauna along the various corridors are described below.

Among the primates is the Patas monkey, and the Guinea Baboon (Papio papio). The baboon is generally regarded as a vermin species by famers, but to protect it DPWM allows only licensed hunters to kill it. The wart hog is also present in large numbers and is another pest especially for ground nut.

Table 4.6: Mammalian Fauna Found Along the ECOWAS-REAP Corridors

Scientific Name Common Name Source of identification During Reported by Bibliographic field visit Locals/DPWM Research Epomophrous gambianus Gambian fruit bat x X Galago senegalensis Lesser bush baby x X Papio papio Guinea baboon X x X Cercopithecus aethiops Green vervet monkey X x Erythrocebus patas Patas monkey x X Colobus badius temmincki Red colobus monkey x X Heliosciurus gambianus Gambian sun squirrel X Cricetomys gambianus Giant Gambian rat x Tursiops truncatus Bottled-nosed dolphin x Sousa teuszii Humpback dolphins x X Trichechus senegalensis W. African manatee x X Aonyx capensis Clawless otter X Orycterpus afer Spotted hyena x X Tragelaohus scriptus Warthog x X Adapted from NNP Management Plan, 2020

The Avifauna The list of bird species recorded within the various corridors, like the mammalian fauna, are influenced by the open forests. Table 4.7 below indicates the types of bird species that are found, including those that occur within the NNP. Specifically, within the NNP approximately 300 bird species from 63 families, have been recorded. This diversity of birds results from the range of habitat present within the Park, i.e. marine, estuary, freshwater swamp, etc. The bird families include Palearctic migrants, resident species, and species with known African migratory populations occurring in The Gambia, which may include movements within Senegambia.

In the early autumn (October – December) the Palearctic migration gets underway and a large diversity and abundance of species accumulate in the Park. It is possible that many of these birds will use the Park to build up fat reserves after their migration, before dispersing further into the continent. This way, the Park is apparently used as a corridor to the inland areas of the continent as well as providing extensive wintering grounds for many species. In view of the above, the avifauna within the NNP is of both national and international significance, and the risk of disturbing their migratory activities, and risk of collision with the transmission lines during flight between roosting/nesting and the feeding grounds should be avoided or minimized.

Other bird species recorded in other parts of the corridors include for example, the starlings, and the black-billed wood-dove.

Table 4.7: Avifauna Found Along the Corridors and in Nuimi National Park

FAMILY Common Name PM RES IAF Source of identification During Reported by Bibliographic Field Locals/DPWM Research Visit Phalacrocoracidae Cormorants X x x x x Pelecanidae Pelicans X x x x Ardeidae Herons/Egrets X x x x x x Threskiornithidae Ibises/spoonbills X x x x Anatidae Ducks, Gees X x x x x x Ciconidae Storks X x Accipitridae Vultures/Hawks/ X x x x x Eagles Falconidae Falcons X x x x Sturnidae Starlings x Phasiandae Pheasants X x x x Nectatindae Sunbirds x x Corvidae Crows x x Bucerotidae Hornbills X x Estrilldidae Waxbills x x Indicatoridae Honeyguides X x x x Picidae Woodpeckers X x Columbidae Black billed X x wood-dove Ploceidae Black-headed X x weaver Ploceidae Black-necked X x weaver Source: Adapted from NNP Management Plan, 2020

Abbreviations used in the table above are : PM – Palearctic Migrant; Res = species with records in every month in The Gambia; IAF = species with known African migratory populations occurring in The Gambia and these may include movements within Senegambia.

Aquatic Invertebrate Fauna The aquatic invertebrate fauna is composed predominantly of crustaceans and mollusks in the NNP; it includes the West African Fiddler Crab Ucatangeri, African Ghost Crab, Ocypode africana and mangrove oyster Crassostrea tulipa.

Aquatic Vertebrate Fauna In the tributaries along the corridors fish species that occur include the African carp (Labeo spp.), Tilapia spp., freshwater catfish, (Clarias lazera). Within the NNP fishes belonging to at least 13 families, have been recorded, and the most abundant species are the Tilapia spp., followed closely by Mullets (Mugil spp).

The fry and juveniles of the Giant African Threadfin (Polydactylus quardrfilis), Ethmalosa fimbriata (shads/bonga), the African red snapper, Sompat grunt, are also present in large numbers. Table 4.8 presents the families present along the corridor.

Table 4.8: Families of Fish Occurring at Nuimi National Park

Families Common Mang Lagoo Seasonall Coasta Source of Identification Name rove ns y Flooded l Strip During Reporte Biblio Areas Field d by graphic Visit Locals/ Researc DPWM h Cichlidae Tilapia x X x x x x Clupeidae Shad/Bonga x X x x x Carangidae Jack x x x mackerel Elopidae Skipjacks x X x x Gerreidae Mojarras x X x x x Lutjanidae Snapper x x x x Mugilidae Mullet x X x x x x Polynemidae Thread fins x x x Pomadasida Grunt/ x X x x e Sompat Sciaenidae Drums/ x X x x Croaker Sparidae Bream x x x x Tetraondonti Puffer fish x x x x dae Cyprinidae African carp x x Claridae Fresh water x x catfish Source: Adapted from the NNP Management Plan, 2020

Amphibians The amphibian fauna is largely the Common African Toad (Bufore gularis), the Savanna Toad (B. xeros), Rocket Frogs (Ptychadena spp.) and the Puddle Frogs (Phyrnobatrachus spp.) that have been identified.

Reptiles Given the diverse habitat types within the NNP the listed species in Table 4.9 have been recorded. In addition to these, others found along other parts of the corridors are indicated in the Table below.

Table 4.9: Reptiles Found in the Niumi National Park and Along the Corridors Scientific Name Common Name Source of Identification During Reported by Bibliographic Field Locals/DPWM Research Visit Chelonia mydas Green turtle X Lepidochelys olivacea Olive Ridley turtle X Caretta caretta Loggerhead turtle X X Knixys belliana nougeyi Bells hinged turtle X X Pelidus subniger W. African mud X turtle Crocodylus niloticus Nile crocodile X

Tarentola ephippiata Fig-tree gecko X Hemidactylus brokki angulatis House gecko X Agama agama Rainbow lizard X Chamaeleo senegalensis Senegal chameleon X Veranus niloticus Nile monitor X Veranus exabthematicus Bosc’s X Matuya perotettii Red-flanked skink X Python sebae sebae Rock python X Python regius Royal python X Psammon elegans African beauty X X snake N. nigricallis Spitting cobra X Dendroaspis viridis Green mamba X Source: Adapted from NNP Management Plan, 2020

III. Human and Socio-economic Environment

➢ Demography and Population Along the Line Corridors Overall, the four feeders from the Soma substation will supply 274 communities in 22 Districts in the three Regions (See Appendix 4.1). Table 4.10 gives a summary of Appendix 4.1, showing the demography of the communities along the various line corridors of the four Soma feeders. The households to be supplied will be about 31,807, with a total population of 255,635; the women make up more than half of the population (52.3 per cent – 133,585) and the male population is 122,050 (47.7 per cent). This is sourced from SD Focus Ltd, 2020 with data from GBOS, 2019.

The corridors in these communities have relatively few developed structures along the road alignments, and the populations are principally subsistence farmers. Where the communities are well removed from the main highways, (e.g. in CRR-N, the Njau Sawalo-Carrols Wharf corridor; the Chamen-Kerr Batch-Nyanga Bantang corridor, among others), the proposed lines will pass, for the most part, through farm lands, behind the communities, rather than through them. This will avoid impacting houses and other private structures located along the usually narrow village pathways, to minimize the potential social impacts.

Table 4.10: Soma Feeders 1- 4: Communities Along the Transmission Corridors Feeder # # of # of # of Population Districts Communities Households Male Female Total 1 6 90 18,669 68,914 73,794 142,708 2 4 38 2,812 9,945 11,461 21,406 3 8 71 6,870 26,449 28,938 55,387 4 6 75 3,456 16,742 19,392 36,134 274 31,807 122,050 133,585 255,635 Source: SD Focus Ltd. (2020) with data from GBOS, 2019

The four feeders from Soma will pass through the communities listed below:

Feeder 1: Communities: From Soma-Farafenni-Jurunku/Barra – Fass Njaga Choi Feeder 2: Communities: From Soma-Sankandi-Kemoto/Tankular Feeder 3: Communities: From Soma-Dankunku/Brikamaba- Bansang Feeder 4: Communities: From Soma-Kerr Ali- Lamin koto- Bush Town

➢ Physical Structures There are numerous physical structures (including compound fences, dwelling houses, welding, and carpentry workshops,) built along the road alignment of the main transmission corridors, particularly within built-up settlements.

Examples of such corridors include the Kuntaya-Memmeh, in NBR; Nyanga bantang-Wassu in CRR-N; and in Mali Kunda-Dankunku, in CRR-S. At the Wassu “loumo”, a line of private workshops of some young men is located along the trajectory that is likely going to be used for the transmission line from Nyanga bantang to connect to the existing line from Bansang.

In general, distances between compound fences and the highways range between 4 m and 10 m. Thus in some communities such as in Wassu in CRR-N, where the distance between the structures and the edge of the highway is 3 m, the transmission line will be so close to the physical structures that they pose a threat to the safety of the inhabitants of such structures. The lines will directly impact on these physical developments. See Appendix 4.3

➢ Schools and Other Infrastructure Similarly, in certain communities’ social amenities such as schools and health posts/centers are located very close to the road alignment, and thus the potential trajectory of the transmission lines will impact them. This can present health and safety risks to the children and staff of the school especially during pole construction and line stringing. Along the Fass Njaga Choi-Jamagen corridor in NBR, two primary schools are located in Kerr Sanyang and Jamagen respectively, and both of them are less than 8m from the edge of the road.

Health facilities are located along some of the corridors, and some are very close to the edge of the road; these include the communities of Kolior Nyamala in Kiang West, in LRR and Kerr Sanyang, in Lower Nuimi District, NBR. In both cases the health facilities are about 12m from the edge of the road, and the facilities are adequately fenced; nonetheless during project implementation surrounding areas must be cordoned-off to protect the visitors from harm.

➢ Chance Finds and Cultural Heritage and Archaeology There are sensitive sites of cultural and historical significance along some of the proposed line corridors; these include mosques, graveyards, and other historical relics. A small mosque is located at the Farafenni-Laminkoto road intersection within the compound of Mr. Samsudeen Mbye, a poultry farmer in Laminkoto, and is barely 5m from the edge of the road. It is built with cement blocks with corrugated roof, and measures approximately 10m x 15m, and without any protection or barrier towards the road alignment. Because it is very close to the road and potentially within the route of the transmission line, the mosque could potentially be impacted by the Project. As a cultural relevance it must not be affected by the Project.

In the village of Kerr Batch in Nianija District, CRR, along the Chamen-Nyanga Bantang corridor is the ancient Stone Circles of Kerr Batch (Figure 4.5), one of the important national cultural sites; it is on coordinates 130 45’ N/150 42’W. In fact, it is now inscribed on the World Heritage List of UNESCO.

Figure 4.5: Stone Circles at Kerr Batch on the Chamen-Nyanga Bantang Corridor Source: SD Focus April 2020

The core area of the site at Kerr Batch (Figure 4.6) is 0.79ha, and is under the purview of the National Council for Arts and Culture (NCAC); the site is located on the outskirt of the village, on the way to Nyanga Bantang. It is fenced with chain-link steel wires, part of which material unfortunately is broken in some places, allowing intrusion by stray cattle and other livestock from the village. A mud house is located at one end of the fenced area; supposed to have housed some of the artefacts, but due to its state of disrepair, the artefacts were transferred to another stone circle location in Wassu.

Figure 4.6: The Core Area of the Stone Circles at Kerr Batch, CRR Source: SD Focus, April 2020

The Stone Circles are thought to be over a thousand years old and are believed to be ancient burial areas for chiefs whose subjects belonged to a single unified culture. Because of this, local legend has it that there is a curse on anyone who disturbs those laid to rest there. The Circles in general, include various forms of burial mounds, isolated pillar stones, single circles and groups of stone circles that may represent cemeteries.

Surrounded by farmlands, a 200 m buffer (extending from the immediate limits of the fence all sides) has been created to protect it from encroachment by the community. Within this buffer farming is allowed, but construction is forbidden. The trajectory of the proposed line from Chamen is expected to pass behind the village of Kerr Batch, and in the process, will potentially run through the 200 m buffer, to impact the site. Given its cultural significance globally, Project activities must not be implemented anywhere within the buffer. Another important national site is at Wassu, (not affected by the Project.

Besides the Stone Circles, there is always a possibility of finding other types of cultural heritage by chance, particularly during land clearing and preparation for works along other corridors. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

➢ Disadvantaged and Vulnerable Groups Table 4.1 above presents the demography of the communities that will benefit from the Soma feeders; 52 per cent of the population is composed of women. Despite their numerical strength, the women are generally often marginalized in the decision-making process, especially in the rural areas, as it relates to the allocation of agricultural land. This is particularly relevant, where women are engaged more in agricultural activities than in other economic activities. The impact of this marginalization is compounded by cultural norms and customs which tend to privilege men and boys over women and

52 girls. In The Gambia, land use and tenure rights tend to disfavor women as important decisions relating to land are made by the men, including inheritance, ownership, among others.

In all the communities along the Soma feeders, women farmers engage in cash crop production, just as men, and in the process of this Project’s implementation, their farms could very well be impacted in the same manner as the men. However, given the male-dominated environment within these localities the adverse impacts would fall disproportionately on the women. Given their social status therefore, women would be considered a disadvantaged and vulnerable group in this Project. Construction of poles and line stringing within farmlands will result in impacts that will potentially affect women disproportionately to men, especially if works are carried out during the farming season.

In addition to the women, other groups regarded as vulnerable and disadvantaged include the elderly and minors, and persons with disabilities. Like the women, these groups are more likely to be adversely affected by the Project impacts and/or more limited than others in their ability to take advantage of the Project’s benefits. For example, they may be unable to attend meetings for reasons due to their inability to reach the venues, and in this way will be excluded, and their voices and opinions may not therefore be considered. Thus, they could be excluded from, or unable to participate fully in the mainstream consultative process, and as such may require specific measures and/or assistance to do so.

To ensure that these groups are not left out in the process, special efforts should be made to meet and discuss with them, especially bearing in mind that some of them (especially women) will potentially be impacted negatively when it concerns resettlement benefits relating to damaged crops. In this regard, all necessary assistance and support to these groups of persons will be ensured in the implementation of this Project.

➢ Gender and Gender-Based Violence (GBV) The majority of the poor and extremely poor in the Gambia is made up of the women who make up to 50 percent of the national population. In 2019, The Gambia was ranked 174th out of 189 countries with a score of 0.466, according to the UNDP Human Development Report’s Index ranking. According to the Gender Inequality Index2 (GII), 2016 Gambia was ranked 143rd with a value of 0.622; poverty of the women is closely linked with very low literacy levels (40 percent for women and 64 percent for men) and education attainment rates for a variety of reasons including cultural norms and physical access.

Women’s access to land remains largely based on customary law where the land belongs to founding families, and the user rights of in-married women depend on the continuation of their marriage within the family. Furthermore, women often lack access to credit for income-generating activities and generally have a limited role in the decision-making that affects their lives. This disadvantaged position

2 The Gender Inequality Index (GII) reflects women’s disadvantage in three dimensions—reproductive health, empowerment and the labour market—for as many countries as data of reasonable quality allow. The index shows the loss in human development due to inequality between female and male achievements in these dimensions. It ranges from 0, which indicates that women and men fare equally, to 1, which indicates that women fare as poorly as possible in all measured dimensions.

53 of women in the family is deeply rooted in gender inequality, and it contributes to gender-based intimate partner violence.

As it does happen often, Gender-Based Violence (GBV) can cause economic harm an individual through for example, property damage and restriction of access to resources; by impacting the person’s personal health and safety, leading to social exclusion; and by fostering dependency on their partners for all material needs which can often perpetuate the cycle of violence.

Given the traditional and customary set-up in communal land use as noted above, in the event of resettlement of lost crop or economic trees in this Project, women could be impacted the most in accessing financial resources paid as compensation.

In view of the above, therefore, particular attention will be paid to the needs of those impacted, including women and children, those below the poverty line, the elderly, etc.

➢ Violence Against Children (VAC) Violence Against Children (VAC) is defined as physical, sexual, emotional and/or psychological harm, neglect or negligent treatment of minor children (i.e. under the age of 18), including exposure to such harm,3 that results in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power. This includes using children for profit, labor4, sexual gratification, or some other personal or financial advantage. This also includes other activities such as using computers, mobile phones, video, and digital cameras or any other medium to exploit or harass children or to access child pornography.

In The Gambia, there have been reports of children, mostly girls, subjected to domestic service and commercial forms of exploitation (i.e. tourism); female genital mutilation (FGM) is still pervasive (76% prevalence rate), early marriage and other forms of exploitation.5

During the implementation of this Project, the potential areas where this can be manifested may include:

i. employing children under the age of 18 years; ii. using children for personal or financial advantage by both contractors and employees; iii. any other way to harass children, including sexual exploitation and physical or sexual violence.

In this regard, the Project Implementation Unit (PIU) and Contractors must ensure that no aspects of the Project works involve children under the minimum age of 16 for light work (as per The Children’s

3 Exposure to GBV is also considered VAC. 4 The employment of children must comply with all relevant national legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. They must also be able to meet the Project’s Occupational Health and Safety competency standards. 5 The Gambia, Child Protection Plan of Action, 2016-2018 and UNICEF Gambia, https://www.unicef.org/gambia/activities_8342.html

Act, 2005), and none under the age of 18 for hazardous work and work that impacts their schooling and social or moral development.

The Labor Act, 2007 prohibits children under 18 from engaging in agricultural, industrial, or non- industrial work for economic gains. In addition, to strengthen and protect children against possible violence and exploitation, the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV) and Violence Against Children (VAC) must be rigorously applied, monitored for compliance. These Codes will be included in the Contractors ESMP (Appendix 6.1 includes the Codes of Conduct for addressing GBV and VAC).

➢ Access of the Population to Education and Security Services The children in the villages and communities along the various corridors have access to education; there are schools in many of the communities (e.g. Kerr Sanyang and Farafenni in NBR, Kwinella, and Geniere in LRR, Mamutfana and Bureng in CRR-S, Chamen and Njau Sawalo in CRR-N). Police stations are located in many of the communities including Njau Sawalo, Brikamaba.

➢ Access of the Population to Health The populations have access to a hospital, (Farafenni General Hospital in NBR), major health centers, minor health centers, and health posts located in different communities along the various corridors (e.g. Health Centers in Dankunku, Soma and Kuntaya; a health post in Kerr Sanyang).

➢ Access of the Population to Electricity, Telephone Sevices The populations along the line corridors have no access to electricity supply from the NAWEC grid; thus, the entire line corridors are without electricity, and they have expressed appreciation for this Project that will make it possible for them to have electric power.

However, mobile network services are operational within the Project area. The four local mobile telephone companies extend facilities to most of the communities proposed to be served by the ECOWAS-REAP.

Modes of Subsistence and Daily Chores in the Project’s Area of Influence

➢ Agricultural Production The communities along the line corridors rely almost exclusively on agriculture and livestock for their subsistence. Like other parts of the country, agriculture within the Project area is characterized by little diversification, and is mainly subsistence rain-fed, and semi-intensive cash crop production.

Farmers generally practice mixed farming, producing food crops comprising cereals (early millet, late millet, maize, sorghum, rice and “findo”), although cash crops (including groundnuts, and horticulture produce), account for a greater portion of the production. The cultivation of horticultural crops (vegetables and fruits) is also practiced but mainly by women farmers growing tomatoes, okra, sorrel, etc. In many instances the women do cultivate cash crops as well.

Along the main highways, in many cases farms are located very close to the road (illustrated in Figures 4.7 and 4.8) on the trajectory of the transmission lines, and thus maybe impacted by the Project, depending on the timing of the works; they may be affected, especially when project activities are carried out during the rainy season, when crops are in the fields.

Figure 4.7: Illustration of farm boundary away from the road

Source: SD Focus April 2020

Figure 4.8: Melon plantation (outside Project area) illustrating position of pole and farm clearance from the road and line corridor

Source: SD Focus April 2020

Table 4.11 shows the general agricultural calendar of activities common within the Project’s area of influence; it can be used as guide in the timing of construction works on the lines.

Table 4.11: Farming Calendar of Activities along the Transmission Line Corridors Activities Carried Out Month Men Women May Clearing of farmland Prepare rice fields, groundnut fields June Clearing farmland Prepare rice fields, groundnut fields July Planting late millet, maize, groundnut, Planting rice, groundnut cassava

Aug Weeding and guarding crops Weeding and guarding rice/groundnut crops Sept Weeding and guarding crops Weeding and guarding rice/groundnut crops Oct Harvesting millet, maize, and groundnut Guarding rice, harvesting groundnut Nov Harvesting millet Guarding rice, threshing groundnut Dec Threshing groundnut Harvesting rice, threshing groundnut Jan No works in the fields Harvesting rice Feb No Works in the fields Dry season gardening Mar No works in the fields Dry season gardening Apr No works in the fields Dry season gardening Source: SD Focus April 2020

Using the above Table as guide, Contractors minimize damage to crops along the corridors; pole construction and line stringing should be carried out after the crops have been harvested and there is less activity in the fields; where construction cannot be halted during the farming season, extra care and diligence must be taken to avoid or minimize damage to crops. In this regard a RAP should be prepared.

➢ Market Gardening The womenfolk in the various communities engage in dry season market gardening, utilizing the same areas used for rice cultivation during the rainy season, to avail themselves of the organic soils and the high-water table. Hand dug wells are used for watering of tomatoes, peppers, cabbage, onions, hibiscus (“wonjo”), and bitter tomatoes. Much of the produce is sold at the local level raising a small income for the women involved, and the balance of the produce are consumed in the household thereby improving nutrition intake.

➢ Marketing and Petty Trading and Shop keeping Along many of the corridors, marketing and petty trading is a daily chore, and both man and women are engaged in it. The women engage in dry season gardening, but most of them claim that they do not have a market locally, and so most of their produce is sold at the weekly markets in Fass Njaga Choi in NBR, Nyanga Bantang and Panchang in CRR-N, Wellingaraba in LRR, or in major markets such as Farafenni, Bansang, etc.

Weekly markets are held on different days in various places, along the corridors, e.g. in Nyanga Bantang, Farafenni, Wassu (all along the Farafenni-Lamin koto corridor), Brikamaba and Wellingaraba (on the Soma-Bansang corridor). On “loumo” days there is usually a brisk trade from as early as 8 a.m. to 5 p.m.; people from various communities around the Districts sell and buy goods such as chicken, cattle, farming equipment, etc. Figure 4.9 shows market stalls and sheds at the “loumo” site in Nyanga Bantang, in CRR-N.

Figure 4.9: Market Sheds and Stalls at the Weekly Market in Nyanga Bantang in CRR Source: SD Focus April 2020

➢ Welding and Carpentry and Youth Employment In at least two communities along the corridors welding and carpentry workshops were encountered, operated by young men; one using diesel powered Chinese-made generator in Changai (on the Lamin koto-Bush Town corridor), and the others using power from the NAWEC grid at the “loumo” site in Wassu (on the Nyanga Bantang-Wassu corridor. (See Figure 4.10).

Figure 4.10: Photo of the Wassu Workshops

Source: SD Focus April 2020 A carpentry workshop is also located close by the welding workshops in Wassu, and they are all located at a spot that will likely be impacted by the proposed line coming from Nyanga Bantang, to connect with the existing line from Bansang. The workshops are located across the road, opposite the terminating pole that is currently being supplied from Bansang. However, since the ECOWAS-REAP is supplying Wassu from the opposite direction (i.e. where these workshops are located), Project activities will impact the operation of these businesses.

Given the number of door and window frames fabricated in these workshops, it is possible that this trade could form an important line of business and activity for the youth of the proposed communities. This is particularly relevant given that the level of youth unemployment and underemployment is high nationally, inspite of the fact they form an estimated 53.8 pe rcent of The Gambian population.

➢ Harvesting Non-wood Forest Products The community members along the transmission corridors collect medicinal plants, herbs bark of trees, and wild fruits for personal consumption from adjacent forests; the fruits include the Tamarindus indica, or tamarind (locally called “dakharr”), and the baobab (Adansonia digitata), commonly used as beverage, or juice. Other types of fruits of commercial value are the Chinese date, locally called “solom solom”, etc. The fruits are sometimes sold within the communities and at “loumos” to supplement the household income.

It is common that contractors and other workers employed in projects located close to natural resources such as forests, national parks, water bodies, etc. harvest produce from these resources for their own personal use, take home to their families or even for sale. In view of this, the workers in this Project should be prevented from competing with the community members for these products. This will be included in the contractors ESMP.

Given the local use of these forest products, it will be recommended that the plants and trees that bear them are not felled unnecessarily in the course of project implementation, because loss of access to these products would adversely impact the communities’ livelihoods and income support, culture and social norms.

➢ Firewood Collection All the communities along the line corridors of the Soma feeders are dependent on the vegetation and forest resources for the provision of firewood as fuel. These are collected from the forest for domestic, and possibly livelihood use.

➢ Livestock Rearing Cattle are reared by the community members, allowed to range over the bush, and on crop residues after the harvest. Within the NNP, cattle utilize the area for grazing. Small ruminants (sheep, and goats) are seen generally grazing close to villages and are corralled within compounds overnight, cattle are corralled by tying to stakes in areas peripheral to the villages.

Poultry are raised at the household level, and draft animals (donkeys, horses, and mules) are also kept mainly for cultivation in the fields.

➢ Fishing This is another important economic activity within some of the villages. It is practiced mainly by men, primarily at the subsistence level mainly within the peripheral communities of the NNP, and the communities adjacent to tributaries that branch off from the River Gambia. They employ mainly gill nets and fish traps on part-time basis. The catches are generally home consumed or bartered at the village level for other goods or services or sold at “loumos”.

In the villages of Kemoto (on the Keneba-Kemoto corridor) and Tankular (on the Manduar Tankular corridor) in Kiang West, LRR, the fishermen are more commercially oriented in their fishing activity, and their catches reach markets of larger towns as far away as Banjul, Brikama, and Serekunda.

Women too are engaged in the harvesting of oysters, clams, and whelks in the NNP; the oysters are harvested from the roots of mangroves, and clams are collected from the mud flat during spring tides. These activities are also primarily at subsistence level.

4.4 Description of the Direct Influence Area and Location-Specific Baseline Conditions This section describes the location-specific baseline conditions; environmental and social issues (deemed to be of significance) encountered along the various proposed transmission corridors are assessed, and where necessary, recommendations on how to address them are made.

With a total number of 46 corridors from the substation, the assessment of each route was started from the start of the corridor. For example, having selected the side of the road to construct the poles (side of road selected based on the least environmental and social impact) the car’s trip meter was taken to zero. Driving on the road/path along the proposed trajectory of the transmission line, any receptor (whether environmental or social) of relevance was recorded at distance indicated on the car’s odometer.

Parameters of the receptor were noted, and the necessary action to address the potential impact recommended. The receptor could be a compound fence, dwelling house, a tree (whether forest tree or private fruit trees of significance), water body, market or loumo site, swamps, etc.). See Appendix 4.2 for details.

4.5 Main Stakes and Risks of the Project The development and implementation of the Project will not be without risks. However, most of the risks are expected to be moderate, with a few risks being high. The project will not be an isolated process, it will be implemented through existing structures and experienced partners that have already implemented transmission and distribution projects funded by multilateral donor agencies such as the World Bank, thus benefiting from a learning curve that will support the PIU and its contractors with risk mitigation measures. Some of the risks include the following and summarized in Table 4.12.

Table 4.12: Main Stakes and Risks of the Project

Risks Mitigation Measure Political and Governance Enforce existing legal instruments Macroeconomic shocks; Lower economic governance of the public sector, and promote development of private sector’ COVID-19 Pandemic COVID-19 needs assessment, central coordination of responses, develop business continuity plan to prevent avoidable project interruptions caused by the pandemic. A protocol elaborated by the PIU is included in Appendix 7.1 Project Design Risks Build upon previous experience with the GESP, GERMP, etc., learn from several experiences Fiduciary PIU to communicate with government for compensation to commence to avoid project delay Insufficient Institutional Capacity Government work with development partners to build implementation capacity in critical areas Environment and Climate Risks Use existing institutional coordination mechanisms of sectoral initiatives; strengthen climate change adaptation and mitigation in project design Social Risks Involve regional community and traditional leaders; use existing Redress Mechanism (GRM) at the PIU

Political and Governance Political and governance risks are high. The Gambia is already facing risks of political instability, despite previous parliamentary elections confirming wide support for the current administration in the last couple of years. Signs of political fragmentation, including parties running separately in the next election, could worsen and derail the reform momentum. There are concerns relating to the impending Presidential elections in 2021, which may impede key preparatory activities such as the delivery of prerequisite studies and/or changes in leadership could lead to revised client objectives.

Macroeconomic Macroeconomic risks are also high. The Gambia lacks a stable financial sector; this risk is considerable. The country’s financial sector is small and narrow, and the majority of bank assets are focused on the public sector, impacting credit to the private sector. Inadequate risk management capacity and incomplete credit information on customers hinder the capacity of financial institutions to support the private sector.

The government seeks to mitigate this risk by lowering the economic governance of the public sector, and by promoting the development of the private sector as an engine of growth.

The COVID-19 Pandemic The risks posed by the COVID-19 pandemic is high. The national emergency public health emergency measures in place creates considerable constrain on the economy. Lockdown measures including the closure of international border entry points for both land and air means the free movement of goods

61 and service across the region, which constitute major sources of economic activities and income for the country have almost ceased.

Project Design Risks This risk is medium. The ECOWAS-REAP is appropriately aligned to the Gambia’s priorities and previous lessons of engagement for the national energy sector. However, environmental, and technical constraints of the Project include the following:

• technically, the lack of Project site designs to identify the specific locations of the poles and corridors causes delay and uncertainties in making decisions, particularly prior to the feasibility studies • harmonization of activities of similar projects in the same area. For example, connecting the ECOWAS-REAP T & D infrastructure to existing grid infrastructure with different characteristics • the T & D corridors cannot be as straight as technically desired since the built-up areas will have to be avoided to minimize impact • accessibility for construction and maintenance may be difficult in vast open fields, remote areas, and floodplains; during the rainy season when the fields are planted, heavy machinery and equipment used in construction will compact the ground making it prone to erosion • the need for more resources where longer routes will have to be chosen to avoid densely built communities, and where villages are very away far from each other yet the distances between them must be included

Despite the above, the proposal builds upon previous experience with the GESP, GERMP, etc., learning from several experiences that were not successful in terms of project design and delivery.

Fiduciary Risks in managing the fiduciary aspect of the Project is low. The PIU has successfully implemented the Gambia Electricity Support Project (GESP) and through this have gained significant experience and expertise in related project implementation matters. These experiences have been crucial in the implementation of the ongoing Gambia Electricity and Modernization Project (GERMP).

To mitigate this risk, the PIU will take the lead in ensuring that the RAP is communicated to government for compensation to commence in earliest to avoid project delay.

Insufficient Institutional Capacity Risks of insufficient institutional capacity to implement the project are medium. NAWEC does not have the required human, financial, and physical resources to implement the Project effectively. The institution suffers from insufficient performance incentives. Such constraints pose risks to the implementation of ECOWAS-REAP.

To mitigate the risks, the Government is working with development partners to build implementation capacity in critical areas. Building on the previous GESP, and the current GERMP, the Project will support several capacity development initiatives at NAWEC. The Social Risks

The social risks of the Project are medium. The Project will create loss of livelihood as a result of areas that cannot be avoided. In addition, there may be low participation of women and other vulnerable groups that need special attention to ensure inclusiveness.

Where resettlement is necessary, compensation of lost property must be made according to existing resettlement policies. However, during the process of determining eligibility and assessment of entitlement, potential disagreement regarding ownership of affected assets especially land may be encountered which, if not properly managed, can lead to Potential Land disputes especially between neighboring communities. This may occur mainly to the lack of physical demarcation of land borders as traditional land ownership still dominant.

To mitigate the risks of involvement of regional and land administration officials, community and traditional leaders in the process is crucial to curb the occurrences of these incidences. The Grievance Redress Mechanism (GRM)6 put in place by NAWEC at the PIU must be understood by project affected people for them to utilize it when necessary. The above description of the current baseline conditions of the Projects’ area of influence focuses on the resources and receptors that may be impacted by the project. It is clear that the interaction of the proposed activities and the resources and receptors will result in both environmental and social risks that would need to be addressed.

6 GRM: Grievance Redress Mechanism is a process whereby complaints and grievance’s relating to the Project, and emanating from members of the communities will be channelled and addressed in a fair manner. Operational modalities are indicated in Appendix 9.1 and Appendix 9.2

CHAPTER 5: PUBLIC CONSULTATION This Chapter presents the approach that was taken in order to conduct stakeholder consultations in the process of developing the ESIA. It describes the process through which the stakeholders, among other things, shared local and indigenous information with the Consultant, and who, in turn listened to their views, with a view to ultimately empower them to initiate, manage and control their own self- development.

5.1 Objectives of the consultation The consultations were held with community stakeholders and government institutions aimed at achieving the following objectives:

- discuss the Project with potential beneficiaries, highlighting its components, its routings, and the potential positive and negative impacts;

- provide information about the ECOWAS-REAP, and to acquire key social information, including schools, health, and other social facilities;

- facilitate transparency and inclusive participation of community members in the project so they can voice their concerns and views regarding the project design and its project impacts, and to ask questions;

- highlight the potential roles and responsibilities of community members, during both the project design and implementation; this is important especially in the context of community- level monitoring of ESMP implementation, which is one way to enhance their participation and promote sustainability in the project;

- understand community dynamics, relations, and the broader social and economic context of the communities and the possible impacts of this Project.

5.2 Methodological Approach The approach adopted in the process was guided by the following good practice principles: − Free: Engagement was free of external manipulation or coercion and intimidation; − Prior: Engagement was undertaken in a timely way and prior to decisions being made so that views expressed can be taken into account; − Informed: Relevant and understandable Project information was disclosed to help stakeholders to understand the risks, impacts and opportunities of the Project.

Reactions and feedback from the local communities, regional and national regulatory stakeholders were used to inform the scope of the ESIA, identify and assess impacts and develop appropriate enhancement and mitigation measures. Since stakeholder engagement is a continuous process, it is expected that ongoing engagement activities will be managed by the ECOWAS-REAP PIU and their Contractors as the Project moves into the implementation phase.

5.3 Targeted Groups Criteria used in the selection of stakeholders to be consulted were based on the level of the different stakeholders’ potential involvement in the Project, e.g. their potential to benefit from the Project, or where their properties and assets will potentially be impacted negatively. The other set of criteria used was based on the potential involvement of specific national institutions in the Project based on their respective institutional oversight of the Project.

For the latter category, this included consultative meetings with NAWEC, DPWM, NEA, NRA, DOF, NCAC, and the Governor of LRR. Discussions with these institutions revolved around their respective sectoral policies and legal mandates as they relate to the implementation of the Project. The meetings enabled the definition of their strength and weaknesses in relation to their potential roles and responsibilities in the implementation of the ESMP.

Organization of the community consultations was mostly spontaneous, i.e. whilst the team of Consultants, NAWEC and Project staff were in a community, a request would be made of the Alkali (the village head) for a meeting of about one hour. The Alkali would oblige and call up the community members (both men and women) to his compound, and after a good number of villagers turn up, the meeting would begin. Figure 5.1 and Figure 5.2 show meetings held in Tambana and Sabakh Njien respectively.

Figure 5.1: Meeting with the Community of Tambana in Jokadou, NBR Source: SD Focus Ltd. 2020

Figure 5.2: Community members from Sabakh Njien in Sabakh Sanjal Source: SD Focus Ltd, 2020

At other times notifications were made well ahead of time of arrival of the Consultant’s team, and on arrival the venues will be full of participants; the meetings would normally last at most, one hour. Certain stakeholders were consulted mainly based on the fact that the locations of their place of business was within the potential trajectory of a transmission line; should the works begin the potential for these businesses to shut down temporarily is very high. These included welding and carpentry workshops located along the road corridors (e.g. in Wassu, CRR).

The transparent documentation of consultations enabled the Consultant to track stakeholders’ perceptions and concerns regarding the development of the Project. To record and track the process and comments from the stakeholder, the following forms were used:

• meeting notes were used to record, and document discussions held between the Consultant and individuals, groups, and communities

• guidance notes and focus group topic points, focusing on questions surrounding economic activities within the communities; the guidance notes included questions on community’s health, education, livelihoods, etc.

• a register of attendees, recording all individuals who attended the consultations was made.

A summary of the comments and views or concerns expressed during the consultations is provided in Appendix 5.1 and the list of persons met is in Appendix 5.2.

5.4 Opinions, concerns and fears of populations and PAPs Stakeholders in all the Project areas were adequately sensitized on matters relating to the consultations with the communities, project background, processes, and procedures as well as the role of the communities and institutions during the implementation of the Project.

With the availability of electricity, they said they would also be able to acquire milling machines which will reduce the drudgery of threshing and milling of agriculture produce for home consumption and commercial purposes. They also stressed that studying with candles is very challenging for their children and will become a thing of the past as their children will enjoy studying under light bulbs as their compatriots in other schools.

From the consultations, the opinions, concerns and fears of the populations and persons likely to be affected by the Project (PAPs) have been incorporated into the recommendations of this ESIA.

CHAPTER 6: ANALYSES OF POTENTIAL IMPACTS, ENHANCEMENT AND MITIGATION MEASURES

This Chapter identifies the potential impacts resulting from the Project’s activities, and describes the mitigation, management and monitoring measures put in place to sustainably implement the Project. Enhancement measures are also identified for the beneficial impacts.

The results of this process will assist the ECOWAS-REAP PIU, NEA and other government agencies in making informed decisions about the environmental and social assessment that has been conducted on the Project. It will be noted that the Policy and Regulatory framework specified in Chapter 3, has been taken into consideration in the development of this report, and the impact assessment is based on the Project’s adherence to these requirements.

6.1 Methodological Approach

6.1.1 Identification of the Main Sources of Potential Impacts of the Project on the Environment Potential impacts, either positive or negative, are the likely changes to occur on the environmental and social components as a result of the Project implementation. Sources of these impacts include all project related activity, carried out during any of the different phases of implementation, which generate these changes. Table 6.1 identifies the main sources of impact for the ECOWAS REAP.

Table 6.1: Main Sources of Potential Impacts of the Project on the Environment and the Social aspect

No PROJECT PHASES TYPES OF WORK IMPACT GENERATING ACTIVITIES 1 Pre-construction Planning -Consultation and provision of project information to stakeholders - Physical survey of proposed project sites Land acquisition for poles Siting of poles in land owned or used by villagers Land preparation for -Clearing of vegetation for access and construction poles -Felling and trimming of economic trees within the ROW Sourcing of earth materials -Clearing of quarrying site -Excavation during quarrying -Stockpiling Establishment of base -Clearing of camp sites camps 2 Construction Mobilization of logistics -Transportation of workers, equipment, and materials to Project sites -Importation of workers -Repair of heavy vehicles and equipment -Storage of heavy vehicles and equipment during works Construction of poles -Digging of trenches -Building of foundations -Erection of poles Stringing of lines -Installation of cables and accessories Clearance of sites after -Removal of excess materials works -Removal of waste materials

3 Operation and Electrification of new lines -Connection to substations and existing Maintenance grid -Connection to users Routine clearing of ROW -Pruning of trees Maintenance of -Repair and replacement of T&D parts infrastructure

4 Decommissioning Closure of quarries Reclamation and restoration of quarries Closure of base camps Dismantling of equipment and structures Transportation of materials and equipment from camps Cleaning of camp sites upon closure

6.1.2. The Environment and Social Components Affected by the Project The Project implementation may affect the different environmental components as listed in Table 6.2

Table 6.2: Environment and Social Components likely to be affected by the Project COMPONENTS AFFECTED Human Physical Biological

Surface water Aquatic ecosystem Public health and safety Ground water Terrestrial wildlife Occupational health and safety Air quality and climate Forests and vegetation Labor related issues Geology and soils Agriculture and livestock Land use and land ownership Noise and vibration Income Landscape and aesthetics Energy Vulnerable groups Community stability Cultural and historical sites

6.1.3 Identification of Potential Impacts Having identified the environment components and the Project’s sources of impacts, their correlation was considered using the Leopold’s Matrix. Each activity (source of impact) was listed and the potential for creating an impact considered against each environment component. Where there is likelihood of an impact, the interaction box is highlighted with a cross as indicated in Table 6.3.

Table 6.3: Identification of impacts ENVIRONMENT COMPONENT AFFECTED PHYSICAL BIOLOGIC HUMAN / SOCIAL AL

PROJECT ACTIVITIES / SOURCES OF PHASES IMPACTS

1 Pre- Consultation and provision X X construction of project information Physical survey of proposed X project sites Siting of poles X X X X X Clearing of vegetation for X X X X X X X X X access and poles Felling and trimming of X X X X X X X X X X X economic trees within the ROW Clearing of quarrying site X X X X X X X X Excavation during quarrying X X X X X X X Stockpiling X X X X Clearing for camp sites X X X X X X

2 Construction Transportation of workers, X X equipment, and materials Importation of workers X X X X X X Repair of heavy vehicles and X X X X equipment Storage of heavy vehicles X X and equipment during works Digging of trenches X X X X X X X X X Building of foundations X X X X Erection of poles X X X X X X X Installation of cables and X X X X X X accessories Removal of excess materials X X X X X Removal of waste materials X X X X X

3 Operation and Connection to substations X X X X Maintenance and existing grid Connection to users X X X X X X Pruning of trees X X Repair and replacement of X X X T&D parts

4 Decommission Reclamation and restoration X X X X ing of quarries Dismantling of equipment X X X X X X and structures Transportation of materials X X and equipment from camps Cleaning of camp sites upon X X X X closure

6.2 Evaluating the Significance of Potential Impacts

In order to ensure that the limited resources are used optimally to mitigate (prevent, reduce, repair, or compensate) the potential impacts, it is important to identify which impacts are more significant for adequate consideration. The parameters used to assess the significance of an impact include intensity, extent, and duration.

6.2.1 Nature of an Impact

Negative impacts create adverse changes that destroy or degrade the receiving environmental component. Negative impacts are undesirable as project development is expected to improve biophysical or socioeconomic environments.

Positive impacts as result of the project activities are changes that are beneficial and improve quality of the related environmental components.

6.2.2 Types of Impacts

Direct or primary impacts are those impacts that are created as a result of change to the immediate environmental component by the Project activities. There is clear causative link between the activity and the component. For example, losses of forest cover due to land clearing.

Indirect impacts are usually secondary in the sense that the correlation between the activity and the environmental component is not readily noticeable and may not necessarily be on the same site.

Cumulative impacts are those that are only significant when in combination. The potential cumulative impacts of this Project were also analyzed as the Project may exacerbate effects as a result of a combination of issues from activities of the past, present or future, including natural phenomena. The distribution of such impacts may be local, regional, or global. These effects together may cause significant impacts that would not have necessarily been relevant individually. Consideration of cumulative impacts may include combined effects of:

• one activity on existing/previously affected parameter; • many activities of the same project on various parameters/sites; • many projects impacting the same parameter; • many projects impacting multiple parameters.

6.2.3 Evaluation of Impact Severity / Significance

The Leopold’s impact identification matrix is further explored to evaluate the extent or scale of correlation between the activity and environmental component. The impacts were weighed based on considerations such as duration of the impact, the magnitude in relation to the total affected area, geographical scope, and population amongst others.

The relevance and importance of the impact to the component is also given consideration. Sensitivity and vulnerability of the component, such as protected habitats or women respectively, are analyses in addition to assessing the probability of the impact occurring and possibility of prevention, reversibility, or other mitigation measure.

6.2.4 Definition of severity levels

The following defines the levels of significance employed for this assessment stated in Tables 6.4 to 6.7:

(+2) Major positive significance: Impacts that are highly likely to promote sustainable development by creating changes that will improve the environment.

(+1) Low positive significance: Implies that there are some opportunities, possibilities, and alternatives for benefits to be gained as a result of the change caused by the impact.

(0) Insignificant positive or negative impact: No discernible impact or interference with the identified environmental parameters. The Project activity is not likely to create any beneficial or problematic change.

(-1) Minor negative significance: Limited adverse impacts caused by the Project activities, and not using sensitive resources. The prevention of such negative effects is also easily possible.

(-2) Major negative significance: High vulnerability and sensitivity; irreversible impact, and outcome of the impact affecting a wider area or population, etc.

6.3 Potential Impacts of the Pre-construction Phase

6.3.1 Potential Positive Impacts on the Biophysical Environment During activities of the pre-construction phase, no potential positive impact is anticipated on the biophysical environment.

6.3.2 Potential Negative Impacts on the Biophysical Environment

6.3.2.1 Impacts Relating to Geology and Soils Where quarries are used for sourcing sand and gravel for the Project compared to purchasing from registered mining companies, excavation carried out at the water table level, have the potential to contaminate ground water.

Sand and gravel to be used for construction may be mined illegally from unapproved sites causing indirect, secondary negative impacts on soil stability, landscape, and vegetation. Access roads to borrow pits may remain open after the project due to poor or incomplete site reclamation and restoration, encouraging illegal mining and waste dumping in the future.

There is also the possibility of soil compaction from the movement of heavy machinery and vehicles. This will open the bare areas to localized, temporary erosion risks and potential formation of new natural drainage routes during rainy seasons.

Agricultural land may also be compacted, particularly with the creation of diversions within farmlands, affecting soil drainage and productivity.

Soils may also be polluted by hydrocarbon spills and improper disposal of solid and liquid wastes such as used oils, machine parts, inert wastes, and packaging, etc.

6.3.2.2 Air pollution

In getting access, siting the poles and base camps, it is expected that existing trees and vegetation around the proposed sites for the poles and base camps will be cleared with the aid of heavy machines such as bull dozers or excavators. Dust and vehicular emissions will be released.

Alternatively, manual labor could equally be hired (preferably from within the communities) using machetes, cutlasses, shovels, and pickaxes to clear existing shrubs and vegetation.

The approximate area required for any proposed base camp is not known at this moment; however, during camp construction, dust pollution is expected from heavy vehicular movement, land clearing, excavations, and other related pre-construction earthworks. Dust emissions will also be produced during truck off-loading of earth materials in stockpiles for storage or heaping nearer the work sites.

Nonetheless, whatever methods are employed in the above works will generate dust within the immediate area of the works, but given most of the planned transmission corridors consist mostly of bushes and shrubs, the dust and gaseous emissions, such as the oxides of carbon, etc. will only temporarily affect ambient air quality around the activity sites. In addition to the high dispersion rates around the sites within open areas, the impact is considered low due to the localized and temporary nature during the works phases.

Apart from the workers who will be immediately disturbed, this impact will be more significant in populated areas, where poles are to be erected close to compounds and other relaxation or resting areas such as waiting sheds, as compared to farms and open fields.

6.3.2.3 Noise and vibration nuisance Temporarily during pre-construction works, noise and vibration is inevitable from the use of machinery and increased traffic to move workers and materials. Workers are generally the main victims, except where sites, particularly for distribution infrastructure, are in closely developed communities.

The use of heavy machinery such as electric saws to cut or trim trees is also another source of noise and vibration.

These localized impacts will scare wildlife in the open fields and aquatic organisms in the short-term during land preparation works. This is particularly relevant within areas which consist of sensitive sites of ecological importance for certain bird and mammalian species.

6.3.2.4 Unsightly landscape The aesthetically unpleasing landscape of the work sites will be visible (although with short-term impact) whilst any borrow pits created specifically for the Project will be more long-term, if not restored.

There is also potential for unsightly areas where construction and other wastes are indiscriminately dumped such as cleared vegetation and materials that have been damaged in the process.

Cleared camp sites and sites for stockpiles of earth materials within vegetated areas also reduce the green scenery as a result of vegetation clearing as illustrated in Figure 6.1

Figure 6.0-1: Example of stockpiles with green background (for a current road project) within this Project's AoI

Source: SD Focus Ltd., 2020

6.3.2.5 impacts of Improper waste management During land clearing and use of other aggregates to include building base camps, related wastes such as cleared vegetation, solid waste such as cement bags, iron, and other pieces of materials, could cause secondary pollution if not cleared in time.

Indiscriminate waste dumping will affect vegetation and water flow while also impacting the aesthetics of the immediate vicinity. In addition to construction rubble, poorly managed solid waste can result in creation of dumpsites which can have environmental health impacts.

Laborers (especially imported laborers) will generate domestic wastes such as food and sanitation wastes in camps or around work sites. Poor disposal of such waste may have secondary impacts with the potential of spreading of diseases, contamination of water bodies, degradation of aquatic ecosystems, and generation of greenhouse gases if the waste is burnt.

As waste will be produced during all phases of the Project, effects from improper management may be long-term with localized negative impacts on aesthetics, health, and safety.

6.3.2.6 Deforestation This Project involves mostly construction of poles and stringing of lines, and given the area required for the base of the pole, vegetation is not expected to be extensively cleared. Therefore, the chances of change in macro and microclimate are very low.

Nonetheless, tree felling, and clearance of vegetation may add to climate change factors on the microclimate temperature increment. It is expected that this impact could be brought to the absolute minimum or fully mitigated given the relatively small area required for the base of the pole.

There is however risk of felling mature trees and unnecessary invasion of forests due to ease of access from routes developed by workers, and poor monitoring. Workers clearing the sites may take the opportunity to fell nearby trees that are not even along the identified trajectories, merely for personal benefits. As workers are in the habit of lighting small fires for brewing local tea whilst at work, fires may go out of control. There is high risk of potential negative impact where uncontrolled fires spread to cover large vegetated areas, destroying both mature and young trees that provide sanctuary and food for wildlife species, and forest products of various uses for the communities.

6.3.2.7 Loss of Fruit Trees and other Vegetation Total or part loss of fruit trees, such as mangoes and cashews, along the line trajectories due to felling or trimming by the Project to construct and protect the lines will be of high magnitude impact to the owners and users of the trees. Minimal felling of privately owned fruit trees is envisaged during site preparation for this Project.

6.3.2.8 Negative impacts on fauna Terrestrial fauna, including invertebrates, reptiles, and mammalian species, (including the primates) will be impacted by construction activities that create noise and pollution that destroy their sanctuaries.

Clearing of terrestrial vegetation will expose dependent wildlife, causing them to move to other areas for food and shelter, with the probability of creating competition and potential nuisance if they move to agricultural fields.

According to the IUCN Red List, the Red Colobus monkey (Colobus badius temmincki) present in the open forests, is threatened, and the Guinea Baboon (Papio papio) is “near threatened”. However, in The Gambia the Guinea baboon population is of least concern, according to the DPWM. Nonetheless, the Biodiversity and Wildlife Act, 2003 accords general protection to certain species including the colobus monkey and the baboon which must be enforced more rigorously.

Workers (especially those imported) may hunt wildlife species for food, or income generation and thus compete with the local population, and this could impact the general population of the species and cause conflicts with the community. It could equally impact on the local population’s food source.

The Project could create additional or expand quarry pits during the pole construction period, and during the rains, the quarry pits may get flooded, creating watering points for livestock and wildlife; however, their movement is hindered (especially if pits are too steep) and domestic animals may drown.

6.3.2.9 Negative Impacts on Wetlands Wetlands occur in several places along the proposed transmission corridors, in different forms and serve vital functions; these include storing runoff, regenerating groundwater, filtering sediments and pollutants, and providing habitat for aquatic species and wildlife. Locating T & D infrastructure in wetlands can have impacts on these functions.

Any of these and other activities can impair or limit wetland functions. Organic soils consist of layers of decomposed plant material that formed very slowly. Disturbed wetland soils are not easily repaired, and severe soil disturbances may permanently alter wetland hydrology.

6.3.3 Potential Positive Impacts on the Human Environment

6.3.3.1 Creation of Temporary Jobs Pre-construction activities including surveying, removal of vegetation and site preparation works, estimated for a period of four months, will create approximately 24 temporarily employment possibilities for both skilled workers (10 persons) such as planners and engineers, and less skilled workers (14 persons) employed to remove vegetation on camp sites and corridor ROW. This is enhanced with the use of local labor, particularly unskilled workers.

6.3.3.2 Improved Community Cohesiveness At the project inception, planning and design stages, the proposed beneficiaries are consulted to encourage participation and ownership whilst also learning from local knowledge on the environmental components. Overall, the communities are delighted with the Project, and discussions around expectations further bring them together for the common goal.

6.3.3.3 Income Generation Despite potential loss of economic trees, immediate income can be derived from the sale of the logs, or fuel wood produced therein.

6.3.4 Potential Negative Impacts on the Human Environment

6.3.4.1 Involuntary Resettlement and Loss of Livelihoods Preconstruction activities will create loss of land for poles and camps, and loss of economic trees for the ROW. Minima loss of agricultural land and range will occur.

It is common that open fields within the Project sites are used for farming during the rainy season. Tree felling and clearance of vegetation for the works will be carried out with negligible reduction in range land for cattle.

Considering that farming can still take place around the poles with insignificant impact from the loss of minimal space, and cattle have vast surrounding areas to graze on there will be low negative impact during pre-construction.

Other potential risks will be associated with people who would lose access to non-wood forest produce, (wild fruits such as baobab, “ditakh”, medicinal plants, etc.) and in the process result in the loss of their livelihood and cultural norms. However, given the large expanse of forested areas left untouched by the Project, the communities will continue to have access to non-wood forest products.

6.3.4.2 Negligence of Vulnerable Groups and Gender Based Violence (GBV) During the preconstruction phase, information on the proposed project is provided to the affected and interested stakeholders. Disadvantaged and vulnerable groups may be at risk of being left out during the process of stakeholder consultations due to their inability to get to consultation venues, and thus will be excluded. Project affected women, people living with disabilities and children, for example, may be sidelined and not considered by the male-headed community leaders during consultations.

In this Project there is also risk of some of the PAPs not benefitting adequately from the resettlement benefits and financial compensation. This will potentially include disadvantaged and vulnerable groups (including children, women and female-headed households, the elderly, persons with disabilities, etc.) within some PAPs’ households.

6.3.4.3 Risks to Public Health and Safety During preconstruction activities, the communities are at risk of increased traffic accidents, and other incidents related to the project activities. Borrow pits that are not managed properly will pose risks to nearby communities; children in particular, are at risk of falling into them, and in the rainy season may cause drowning. Children are also in the habit of playing around work sites and climbing stockpiles, which increased their risk of involving in an accident.

For settlements close to sites of land clearing and preparation, dust and noise nuisance will be created.

Due to influx of workers, especially where imported workers live within the communities and not in camps, communicable diseases of most concern include tuberculosis and sexually transmitted diseases and infections (STDs/STIs) such as gonorrhea, and HIV/AIDS.

6.3.4.4 Negative impacts from Violence Against Children (VAC) There is risk of using children as workers in the course of project implementation, particularly during preconstruction for site clearance. Children playing in camps and around work sites may be abused verbally, physically, or sexually, in addition to the risk of worksite accidents occurring.

6.3.4.5 Risks to Occupational Health and Safety During all phases of the Project, there are long-term hazards which could be pertinent to worker health and safety and of high significance because peoples’ lives are directly at risk. These include risks and hazards (noise, soil erosion, high traffic, air quality deterioration, named earlier under physical environment), that may occur during works in the field. During the preconstruction phase, particularly site clearing, workers are at risk of being attacked by bees, snakes, dogs, or other wildlife. Work related stress including long hours of work and under extreme heat, will affect workers if they are not provided adequate services including water, food, sanitation, rest area and waste disposal facilities. Accidents from equipment use, noise and dust may affect workers on the Project. Accidents and injuries could also arise from:

• danger from quarry operations and safety risks from abandoned quarries or borrow pits, as well as when quarries continue to be used by unauthorized persons; • operation of machinery, endangering both operators and laborers; • injury/accident due to lack of warning signs, site barricades and safeguards.

6.3.4.6 Risks of Communicable Diseases Communicable diseases of most concern during the pre-construction phase are sexually transmitted diseases (STDs), and HIV/AIDS due to influx of workers to the Project site or living within the communities. The novel Corona Virus pandemic that started in 2019 affects The Gambia and is highly contagious.

6.3.4.7 Community Instability and Reduced Cohesiveness (Including Impacts from Labor Influx) Community instability, conflict or grievances of high significance may arise where information on the Project, land ownership, land use, and community expectations are not clearly relayed to them in a timely manner. Grievances and conflicts may arise especially where negative project impacts (e.g. loss of land or crop due to pole siting, partial or total loss of economic trees, labor influx and impacts to community and intimate partner relationships etc.), mitigation measures and community expectations are not well understood.

Clearing activities, particularly during the pre-construction phase, results to the production of vegetation waste (branches, logs, shrubs, whole trees etc.). Conflict may arise where ownership and distribution is unclear.

Complaints are also likely, especially where compensations are not provided to PAPs due to disputes regarding eligibility for compensation, or disagreements in the amount of compensation received, or some PAPs not enumerated at all.

Other community stability risks that may result from labor influx include Gender-Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC) particularly with the use of child labor, sexual and other harassment by workers.

There are also risks of breaking community cohesion and reducing community participation on the Project where locally available human resources are not employed. Furthermore, construction crew that comes from outside the communities could introduce alcohol or other social vices to negatively affect existing socio-cultural values, norms, cohesion and the stability of the communities and interpersonal relationships within and among families.

6.3.4.8 Impacts on sites of cultural and historical significance As earlier discussed, there are culturally sensitive sites such as mosques, cemeteries, and historical relics (Stone Circles) within the Project’s area of influence.

Typically, the Stone Circles at Kerr Batch are an archaeological and historical resource that is currently protected by the NCAC Act, 2003. Transmission line construction and maintenance can damage the site by digging, crushing artefacts with heavy equipment, uprooting trees, exposing site to erosion or the elements, or by making the site more accessible to vandals. Impacts can occur wherever soils will be disturbed, at pole locations, or where heavy equipment is used.

6.4 Potential Impacts of the Construction Phase

6.4.1 Potential Positive Impacts on Biophysical Environment There are no potential positive impacts of significance on the biophysical environment during the construction phase.

6.4.2 Negative Impacts on the Biophysical Environment

6.4.2.1 Pollution of Surface Water There are a number of seasonal and permanent surface water bodies within the Project’s area of influence (such as the Kundunku bolong) and construction works within it with heavy machinery could

78 lead to soil compaction; a decrease in the permeability of the surface could result in soil erosion and increase in sediment loads of the nearby tributary. This can lead to alteration of the flow regimes of the tributary, thereby affecting water velocity, depth, and channel morphology.

High turbidity and change in the physical and chemical composition of the water will also slow down flow and affect the local water biome and activities. The probability of this happening will be increased where materials are also left on site, blocking water flow.

Accidental leaks or spills of oil/fuel from storage tanks or construction into these water bodies will lead to pollution.

6.4.2.2 Loss of Aquatic Ecosystems Within the study area are several surface waterbodies that may be impacted and indirectly affecting the flora and fauna they contain. Construction of transmission lines across these resources may have both short-term and long-term effects.

Water quality can be impacted not only by work within these streams, but also by nearby vegetation clearing and pole construction activities. The removal of adjacent vegetation can cause water temperatures to rise and negatively affect the aquatic habitats. Vegetation clearing can also increase erosion of adjacent soils causing sediment to be deposited into the streams, especially during rain events.

Woodlands and shrub vegetation along the streams are a valuable buffer between adjacent land uses such as farmlands and corridors of natural habitats. The vegetation protects water quality, maintains soil moisture levels in stream banks, helps stabilize the banks, filters nutrient-laden sediments and other runoff, maintains cooler water temperatures, and encourages a diversity of vegetation and wildlife habitats.

Overhead transmission lines across the streams or lakes may pose a potential collision hazard for waterfowl and other large birds, especially when located in a migratory corridor.

6.4.2.3 Impacts on Wetlands Pole construction and stringing of the lines can have impacts on the functions provided by wetlands in the following several ways:

• heavy machinery can crush wetland vegetation; • wetland soils, especially very peaty soils can be easily compacted, increasing runoff, blocking flows, and reducing the soil’s water holding capacity; • the construction of access roads to reach pole sites can change the quantity or direction of water flow, causing permanent damage to wetland soils and vegetation; • construction and maintenance equipment (cranes, trucks, and other heavy machinery) that will be used can stir up sediments and endanger fish and other aquatic life; • water flow during the rainy seasons, low and high tides, should not be impeded as a result of the civil and electromechanical works; • engineering of the poles, construction/installation methods and processes are of the required standards.

6.4.2.4 Noise and Vibration Nuisances During the construction phase, noise and vibration is inevitable from the use of machinery and increased traffic to move workers, equipment, and materials. Both noise and vibration nuisances are of higher significance where compressor drill machines are used during excavation of hard soil.

Workers are generally the main victims, except where sites, particularly for distribution infrastructure, are in closely developed communities.

These localized noise impacts will also scare away wildlife in the open fields and aquatic organisms in the short-term during works on the foundation and presence of workers. Within non-seasonal wetlands where the ground is less hard, noise and vibration impacts from digging trenches for the pole foundation is low.

Where deadlines for construction are tight, contractors tend to work longer hours into the night when noise effects are more pronounced with less background sounds.

6.4.2.5 Impacts of Unsightly Landscape For the duration of pole construction works and stringing of the lines, the aesthetically unpleasing landscape of the work sites will be visible, and from far afield where heavy vehicles and equipment are parked. Although usually short-term only during the works, there is also likelihood of long-term impacts such as pole foundations that have already been dug and abandoned for any reason.

There is also potential for unsightly areas where excess construction materials (cement and earth materials) are left on site long after the works; other wastes that may indiscriminately be dumped during construction include packaging waste, empty cable drums, engine oils, worn out parts such as drill bits etc.

6.4.2.6 Air pollution Earthworks during construction such as excavations and handling of materials (sand, gravel, basalt, and cement) will produce localized dust emissions. Increased vehicular movement from transportation of equipment, workers, and materials (particularly in remote areas with very limited traffic) will also create an increase in air pollution during the works.

The emissions are temporary and significant only to the immediate area of the works. As such, workers around the sites will be disturbed by the nuisance and likely respiratory effects. In populated areas, more so during construction of the LV lines within communities, dust and gaseous emissions may affect the residents.

6.4.2.7 Effects of Extreme Weather Effects of extreme weather conditions can affect materials and construction during works. Heavy rains and storms will affect the erection of poles during construction, especially half completed works and material storage; this could result in wastage of materials, especially cement aggregates which could be washed away or diluted under rain.

The significance of heavy rains has some bearing on the water level of the surface water bodies and wetlands, especially in relation to the safety and wellbeing of the workers during construction. With unusual swell of the water in such sites, workers may drown or lose equipment in the water.

Locating poles on the banks of water bodies and close to road culverts could lead to poles collapsing due to potential erosion of the banks by heavy storm water runoff.

6.4.2.8 Impacts related to the Importation of Workers Importing workers (that are not known by the communities) to Project sites may open the environment such as forests and wildlife or wetlands to illegal exploitation and pollution, respectively. Bearing in mind that the construction period is relatively short and that they may never return to the

80 communities to be held accountable, imported workers may engage in illegal activities, such as logging, with potential long-term consequences.

6.4.3 Potential Positive Impacts on the Human Environment

6.4.3.1 Employment and income Employment resulting from the Project construction will create social benefits and improved standards of living.

During construction, estimated to last for 18 months, 80 workers would be employed at various times to include the 15 skilled (to include various managers, engineers, planners, environmental and social experts, heavy vehicle drivers, etc.) and about 65 unskilled workers (construction handymen, security, housekeeping personnel, laborers to clear the ROW routinely, and similar menial jobs).

It is uncommon for women to be involved in similar construction works, however, this Project will ensure that men and women are given the same employment opportunities without any impediments put in the way of women.

During construction, temporary economic improvement of women in the immediate vicinity of the Project sites will be attained through commercial activities targeting project workers, as is common in most construction sites in Gambia.

Employing youth will improve their skills that may encourage interest in the field for further personal development.

6.4.4 Negative Impacts on Human Environment

6.4.4.1 Risks to Public Health and Safety During construction, where the public risk access to hazards such as open pits, long and heavy materials, increased traffic and heavy equipment, there is potential significant negative impact that may lead to disabilities or loss of lives.

During pole construction and line stringing, dust and noise generation may cause nuisance to the communities, especially those settlements close to LV pole construction sites. However, given the required area for the base of the pole, noise and generation of dust will be localized, small scale, and temporary, confined to the period of pole erection when heavy vehicular movement may generate dust; as soon as work is completed, the situation is reversed to pre-Project state.

6.4.4.2 Risks of Communicable Diseases The risk of spreading communicable diseases is always present irrespective of the duration of the Project activity and increases with the importation of workers to communities. Communicable diseases of most concern especially during the construction phase are sexually transmitted diseases (STDs), and highly contagious disease outbreaks such as the novel Corona Virus pandemic.

The communities and workers are equally at risk of contracting diseases during the construction phase.

6.4.4.3 Risks to Occupational Health and Safety

Construction activities include working in remote areas with risk of pest invasion (insects and wild animals), water bodies and paddy soils in wetlands, working at heights, and working with specialized machinery and equipment. Improper operation of machinery may endanger the lives of both operators and other workers within the sites. There is specific exposure of work crew to risk of falling during line stringing, and injuries from falling into excavation pits or falling on same level. Road traffic accidents will also be considered, particularly where most corridors are along existing roads, and some along busy highways. Other issues which could be pertinent to worker health and safety during the construction phase include risks and hazards associated with noise and vibration, long and heavy parts, air quality and personal attacks. Work related stress including long hours of work and under extreme heat, will affect workers if they are not provided adequate services including water, food, sanitation, rest area and waste disposal facilities. The likelihood of accidents happening during construction is moderate given the nature of the technology expected to be employed in the course of implementation of the Project. However, considering the scope of the Project in at least 258 communities on the Soma feeders, the cumulative impacts of more than one incident will cause severe grievances and loss of credibility.

6.4.4.4 Negative Impacts from Gender Based Violence and Violence Against Children (VAC) Women and children are vulnerable to exploitation and abuse during the construction phase. Children are generally inquisitive and usually found around Project construction work sites. Children may also be employed during the works or casually asked to carry out errands. Both women and children are at risk of being abused verbally, physically, or sexually, in addition to the risk of worksite accidents. 6.4.4.5 Negative Impacts on Land Use (Loss of Livelihood) During construction of the poles, the work site surrounding should be clear of day-to day activities for health and safety reasons, and to avoid interruption with the works. The main activities involved in line stringing are pulling and stretching of the lines between poles.

In the process of such works, activities around the works sites will be affected temporarily. During construction, not much agricultural vegetation will be expected to be affected for the required depth (1.5 m) and width (1.5 m) of excavations to hold the poles. However, agricultural land may be crossed for access. Crops growing close to the line trajectory (especially when the works are done in the farming season will be trampled upon by the workers and destroyed. Loss of one season’s harvest for a small portion of the land could result if works are carried out during the farming season.

The size or area of impact will depend on the level of care and diligence exercised by the Contractor, since the stringing operation will be from one pole to the next, and this could be a distance of a minimum of 100 m to a maximum of 150 m between two poles; thus the severity of the impact could be moderate to high, with the farmer losing crops and part of his livelihood.

Sites of weekly markets could also be disturbed during pole construction and stringing and thus lead to potential loss of earnings especially if works are carried out on market days as they will be temporarily displaced to prevent accidents.

6.4.4.6 Loss of Chance Finds

During digging for the pole foundations, there is possibility of finding cultural heritage by chance. These may be disturbed or lost due to lack of knowledge in managing cultural heritage discovered by chance.

6.4.4.7 Risks Caused By Force Majeure Despite various management plans and proper implementation, there may be risks and calamities beyond the control of the Project or Contractors such as wildfires, flooding, storms, or disease outbreaks such as the 2019 Corona Virus pandemic.

6.5 Potential Impacts of Operation and Maintenance

6.5.1 Positive Impacts on Biophysical Environment

6.5.1.1 Impact on Climate Change Globally, renewable energy is becoming one of the best replacements of conventional energy to fight climate change. Human activities, especially over the past few centuries, have impacted negatively the global environment; burning fossil fuels to produce energy, expulsion of chlorofluorocarbons that clog the atmosphere, and depletion of forest covers are only some of the activities which have led to the serious threat of global warming and irreversible climate change. The use of renewable energy, in this case, hydroelectric power generation has potential to mitigate climate change by directly reducing emission of Greenhouse Gases (GHG), which are the main culprits of global warming. 6.5.2 Negative Impacts on the Biophysical Environment

6.5.2.1 Effects of Extreme Weather Efficiency of overhead electricity lines can be reduced through extreme weather conditions such as strong winds and excessive rains that may affect applied loads and cause structural failure of various parts of the transmission and distribution infrastructure that are unable to withhold strong winds.

6.5.2.2 Impacts on Landscape Waste from disused and worn-out materials such as poles, lines, transformers, bolts and knots etc. will be created during operation, maintenance and repair works. These will create eyesores when not collected from the sites and managed properly.

At the substation sites, along highways, and in developing LV networks within densely built communities, the impact from wires cape is common. There may be crisscrossing or increased numbers of transmission lines, distribution lines, telecommunication lines and other structures in the same areas causing visual disturbances as illustrated in Figures 6.2 and 6.3.

Figure 6.00-2: Combination of poles and cables around the Brusubi substation (outside this Project’s AoI)

Source: SD Focus Ltd. 2020

Figure 6.3: Combination of poles and cables (MV and LV poles; street light poles, Advertisement Boards) across the highway from Brusubi substation (outside this Project’s AoI) Source: SD Focus Ltd. 2020

6.5.2.3 Loss of Trees

During maintenance, pruning of trees will have minimal significance as only affected branches should be trimmed.

Loss of Fauna Consultation with the DPWM highlighted an example of significant impact of non-insulated cables amputating monkeys within the Abuko Nature Reserve in Abuko (outside this Project area); similarly, in the open forests, one could expect such impacts on the populations.

Large birds with wider wingspans (such as certain eagles, waterfowl, cranes, hawks, and vultures) may get electrocuted or killed in contact with lines during flight or resting on the lines.

6.5.3 Potential Positive Impacts on Human Environment

6.5.3.1 Employment During operation, it is estimated that 20 persons will be employed (16 skilled and 4 unskilled) to include specialists’ operators of T&D systems, maintenance workers.

6.5.3.2 Economic Development as a Result of Efficient Energy Supply Enhanced economic development and associated income generation from activities reliant on supply of electricity will specifically improve livelihood and benefit communities within the identified line corridors, and generally the entire country. Improvement of tourism facilities was highlighted, including the importance of energy in the maintenance of museums and offices in remote areas of cultural significance such as the Stone Circles in Kerr Batch.

6.5.3.3 Improved Livelihoods as a Result of Better Services Education, health, communications, security and other social services that are largely dependent on electricity will be improved; with availability of electricity both locally and nationally, students will be able to stay up longer to read, and other social services such as health centers, clinics and national communication infrastructure will be more efficient.

Operation of the Project will also result to efficient electricity supply that will improve agricultural productivity such as cool storage and value adding processes.

6.5.3.4 Benefits to Youth and Vulnerable Groups With continuous electricity supply, youth could develop skills and trade to enhance their livelihood; these may include welding, carpentry, or other small businesses that rely on electricity. Consequently, more job creation prospects will encourage youth to stay and work in The Gambia, rather than venture the risky illegal migration journeys to more developed countries. In the long-term, women could benefit by producing and selling ice blocks and cold drinks made from local ingredients such as “kaba”, baobab and “wonjo” (hibiscus).

As outlined in a number of consultations, women look forward to having the opportunity to refrigerate or freeze food rather than cooking every day or having to get rid of excess food. The physical energy and time saved could be used to spend more time in other activities such as agriculture.

In remote areas where fishmongers come only periodically, women hope to purchase fish, where possible, in bulk when there is electricity for cold storage; this will help in promoting varied and balance diets.

6.5.3.5 Increased Security Operation of the Project will enhance security within the beneficiary communities, specifically at night, as lighting will be available.

6.5.4 Potential Negative Impacts on Human Environment

6.5.4.1 Risks to Public Health and Safety Operation of T & D networks may cause harm to the public particularly where people come into contact with broken live lines during operation leading to electrocution or death. The significance is considered high as a single life lost to the Project is irreversible.

During pruning of trees, the public may also encounter dangerous equipment such as sawing machines or falling branches where these are collected for domestic use.

Occupational Health and Safety Risks During all works, including operation and maintenance activities, workers are at risk of accidents from machinery, traffic, and illnesses. These include exposure of work crew to the risk of falling from heights during maintenance and repair of lines and accessing high trees during pruning. Electrocution and fire outbreaks during maintenance are also potential impacts of high significance.

6.5.4.3 Negative Impacts on Public Services During operation on the grids (particularly during connection to the main substations and pole- mounted transformers) there will be temporary disruption of power services to existing customers (within and outside the Project’s area of influence) supplied by the transmission lines and substations involved in the works.

6.6 Impacts of Decommissioning and Dismantling

6.6.1 Potential Positive Impacts on Biophysical Environment

6.6.1.1 Improvement of Landscape Reclamation of quarries, camp sites, and removal of disused structures will return the landscape to original state or even better.

6.6.2 Negative Impacts on Biophysical Environment

6.6.2.1 Impacts of Improper Waste Management Decommissioning activities involve removal and movement of installations that have been used for the Project. These activities will produce waste of various types from earth materials to broken and disused parts, structures and used oils. Such waste may affect aesthetics, surface water, wildlife, livestock, and the public.

6.6.2.2 Air Pollution

The decommissioning phases of camps have the potential to temporarily affect local air quality. Heavy machinery and vehicles will also release hydrocarbon incomplete combustion gases to the air, affecting local air quality.

6.6.3 Potential Positive Impacts on Human Environment

6.6.3.1 Employment All activities will have to be carried out by people who are paid. Decommissioning activities will provide short-term employment for drivers, clearing workers, quarry restoration workers etc.

6.6.4 Negative Impacts on Human Environment

6.6.4.1 Public Health and Safety Risks As with all work activities, the decommissioning phase will also create health and safety risks to the public.

6.6.4.2 Risks of Communicable Diseases The risk of spreading communicable diseases is always present irrespective of the duration of the Project activity. Communicable diseases of most concern especially during the construction phase are sexually transmitted diseases (STDs), and highly contagious disease outbreaks such as the novel Corona Virus pandemic. The communities and workers are equally at risk of contracting diseases during the decommissioning phase.

Risks to Occupational Health and Safety Decommissioning will involve use of machinery and equipment that may endanger the lives of both operators and other workers within the sites. Other issues which could be pertinent to worker health and safety during the construction phase include risks and hazards associated with noise and vibration, air quality and personal attacks. Work related stress including long hours of work and under extreme heat may also affect workers.

6.4.4.4 Negative Impacts from Gender Based Violence and Violence Against Children (VAC) Women and children are vulnerable to exploitation and abuse during all phases including the decommissioning phase. Children may be found at the Project sites or illegally employed during the works. Both women and children are at risk of being abused verbally, physically, or sexually, in addition to the risk of worksite accidents.

6.7 Cummulative Impacts This Project may give rise to the following cumulative impacts on the biophysical and socioeconomic environment:

• As the T&D lines usually follow existing highways and roads, poles will be erected along the edge of the road which may be boundaries of agricultural fields. Previous loss of agricultural land, or the composition and quality of the soil during the road construction would, in addition to potential disturbance of agricultural land during this project, potentially affect farmers once

again. Moreover, larger farmlands too close to the road would be more affected where more than one pole is located along the farm.

• As reported by Forestry Officers, some Community Forests in the Gambia (particularly those without noticeable boundaries) have been affected previously during road construction and similar T&D projects; more Community Forests may be further affected by this Project if control measures are not fully implemented.

For example, during field visits for this study, there was evidence of cleared vegetation (as a bye-pass for the road construction) and trees felled along the whole trajectory of the current road construction from Keleng Jawbeh, Sami District (CRR-N)7 to the settlement of Bush Town, across the River from Bansang. Along this bye-pass is a camp, stockpiles of earth materials and clearance for the road alignment. Therefore, no matter how minimal the vegetation clearance is for the Project, in combination with the current loss of vegetation, the impacts will be more pronounced. • In addition, collective loss of vegetation and consequential disturbance of forests and wildlife habitat, particularly for access during works and indirectly at quarrying sites, may cause fragmentation of biodiversity and potential change to the variety of species as wildlife tend to adapt or move in response to continuous changes in habitat. This could also adversely impact the livelihoods, food security and cultural practices of the community, including women who may depend on access to these resources for food production and livelihoods.

• Excavation activities, increased worker population and vehicle traffic in remote areas at the same time during construction will create a combination of nuisances and reduced tranquility as a result of noise, vibration and air pollution (especially in most rural areas where similar activities and machinery are extremely rarely seen or used).

• Cumulative impacts from similar projects in future, such as adding extra circuit lines to existing poles, will have minimal combined effect as compared to construction of another line along the same routes.

• Potential visual disturbance is likely in the future where electricity transmission lines and lines of other services compete for space, for example, crisscrossing of telecom and electricity lines. In certain areas, poles may be situated near similar structures with adverts or road signs creating unaesthetically pleasing sights collectively.

• Specific concern is at the main substations where many poles and lines will have to be connected to serve the various feeders creating unsightly wires capes.

• The cumulative impact from potential public health and occupational health and safety risks (falls, electrocution, effects of air and noise pollution, diseases, GBV, SEA, VAC etc.) associated with the project should be noted as various hazards will be present simultaneously during works, creating an environment for increased probability, frequency and number of incidents. The more the number of workers, the more the cumulative nature of the potential impacts and the need for more stringent supervision and monitoring to ensure safety, compliance, credibility, and social cohesiveness. • Considering the wide scope of the Project with more than 274 villages, low impacts of the Project in these villages in combination may lead to impacts of high significance. For example,

7 Although not within the Soma Feeders, and thus outside the scope of this report, but similar situations have been noted in many other places; this can contribute to increased cumulative impacts of different projects on the same receptor.

where minor grievances are reported from a number of villages, the Project and GRC will have to work effectively to maintain credibility (especially with the fast spread of news on social media). Moreover, the total land-take of the Project, combining the negligible land-take from each PAP, will become significant.

The results of the analysis will assist the ECOWAS-REAP PIU, NEA and other government agencies in making informed decisions about the environmental and social assessment that has been conducted on the Project. It will be noted that the Policy and Regulatory framework specified in Chapter 3, has been taken into consideration in the development of this report, and the impact assessment is based on the Project’s adherence to these requirements.

CHAPTER 7: MANAGEMENT MEASURES OF THE POTENTIAL POSITIVE AND NEGATIVE IMPACTS ON THE ENVIRONMENT

This Chapter describes the recommendations made in managing the impacts earlier identified in Sections 6.3 to 6.7. Enhancement measures for the positive impacts earlier identified and mitigation measures for the negative impacts for each of the Project phases are described.

7.1 Enhancement Measures for Potential Positive Impacts

➢ 7.1.2 Enhancement Measures for Positive Impacts During Pre-construction Phase: Human Environment

7.1.2.1 Creation of Temporary Jobs Temporary employment can be created for more people by providing opportunities to local workers in the various Regions, particularly unskilled labor. Contractors should be encouraged and monitored to ensure equal employment opportunities to men, women, and youth.

7.1.2.2 Improved Community Cohesiveness

Overall, the communities are delighted with the Project, and discussions around expectations further bring them together for the common goal. The momentum and enthusiasm generated by the impending lighting of the communities could be used as a spring board to form local committees to organize and coordinate community efforts, to negotiate with NAWEC on behalf of the communities to reduce the cost of connection, among other initiatives. The committees could equally act as forums where community grievances related to the Project could be lodged for onward transmission to the Project GRC. To further enhance community cohesiveness the following could be possibilities:

• the Project may invest in related community infrastructure such as road upgrades and community reforestation as compensation for losses or as part of the activities; • consultation and participation of beneficiary communities should be a continuous process during the preconstruction phase; • the SSS could ensure all the necessary consultation and disclosure is done prior to the commencement of construction; • the GRM must also be active and made known for timely address of grievances; • communities can be encouraged to set up committees/groups that can be useful in supporting each other with regards to the benefiting and participating in the Project; this will create an internal support system.

7.1.2.3 Income Generation

Cleared vegetation should be made available to the communities without discrimination, for sale or domestic use. Savings made from the Project related activities will provide opportunities for more income generation through investment into more lucrative businesses, therefore, compensation for involuntary resettlement should be accompanied by advice and information to promote improved livelihoods.

Employment of local labor, could create capital for local community members to maximize the benefits of the electricity within the communities; they could be encouraged to invest in such trades as welding, carpentry, etc. and this could increase economic activity within local communities. Increased numbers of people in these trades could have spin offs into other trades with increased financial income within the communities.

➢ 7.1.3 Enhancement Measures for Positive Impacts During Construction Phase: Human Environment

7.1.3.1 Employment and income • During construction, employment can be created for more people by providing opportunities to local workers in the various Regions, particularly unskilled labor.

• Hiring practices and training should encourage technology transfer and development programs to promote the use of local suppliers of goods, services, and personnel. • Where possible, the required materials should be produced in The Gambia, to create further employment as compared to the importation of materials; local suppliers should be encouraged through provision of adequate technical and commercial information for fulfilment of requirements.

• Contractors should be encouraged and monitored to ensure equal employment opportunities to men, women, and youth.

➢ 7.1.4 Enhancement Measures for Positive Impacts During Operation Phase: Biophysical Environment

7.1.4.1 Impact on Climate Change NAWEC shall ensure optimal use of the electricity produced from the renewable energy source to reduce the use of fossil fuels in energy production; transmission and distribution infrastructure should be periodically upgraded to improve efficiency.

➢ 7.1.5 Enhancement Measures for Positive Impacts During Operation Phase: Human Environment

7.1.5.1 Employment During operation, the employment needs are minimal for inspection, repair and maintenance of infrastructure. Periodic pruning of vegetation along the ROW shall also create employment. To enhance employment during operation, the limited number of employees can be given refresher

90 training to ensure they can handle new technology and designs. This shall improve employment opportunities.

Indirect employment can also be created as agents are required in most of the communities for the sale of electricity tokens.

7.1.5.2 Economic Development because of Efficient Energy Supply National development is highly dependent on electricity, therefore, NAWEC most ensure during operation that the necessary maintenance and periodic upgrade of the T&D infrastructure is carried out to ensure constant supply; this will prevent unnecessary electricity shortage as a result of breakdown in the T&D system.

NAWEC shall also expand to ensure optimal transmission and distribution of the available energy.

7.1.5.3 Improved Livelihoods as a Result of Better Services Availability of electricity improves livelihoods, therefore, NAWEC most ensure during operation that the necessary maintenance and periodic upgrade of the T&D infrastructure is carried out to ensure constant supply. Reliable energy supply will promote the development and maintenance of businesses and improve domestic livelihood activities with the use of electrical equipment.

NAWEC shall also ensure optimal transmission and distribution of the available energy through increased accessibility and affordability.

7.1.5.4 Benefits to Youth and Vulnerable Groups To enhance benefits of the Project to potentially vulnerable groups, NAWEC shall promote equality in energy accessibility and distribution without discrimination.

7.1.5.5 Increased Security NAWEC shall ensure increased affordability of electricity to the wider population; this will encourage communities to light up.

➢ 7.1.6 Enhancement Measures for Positive Impacts During Decommissioning Phase: Biophysical Environment

7.1.6.1 Improvement of Landscape The ESS and the NEA must ensure the landscape is improved or at least returned to near original state.

7.1.7 Enhancement Measures for Positive Impacts During Decommissioning Phase: Human Environment

7.1.7.1 Employment During decommissioning, local workers should be employed to carry out the removal and clearing activities.

7.2 Impact Management during Pre-construction Phase

7.2.1 – Mitigation Measures of the Negative Impacts on the Biophysical Environment

7.2.1.1 Mitigation of Geology and Soils related Impacts

• For operating new quarries, the materials shall be obtained from quarries only after the consent of relevant authorities, including such as the affected communities, the Geology Department (GD) and the NEA. Extraction sites will need to be assessed before commencement of mining, and after approval of mining and reclamation plans ;

• For quarries approved for this Project, copy of licenses should be displayed on site, or produced on request by the relevant national authorities;

• Quarries approved for this Project, must be officially closed after the works, and communities given the responsibility of reporting to the authorities (NEA, GD) of any illegal mining activities;

• Access to the quarries must be prohibited at all times and communities educated on controlling children to avoid such sites due to the associated risks, including drowning during the rainy season;

• Only established transportation routes and diversions must be used to limit destruction and ensure reclamation is done at the end of the works by reinforcing and repair access roads;

• Contractor must be cautioned through relevant clauses in the works agreements to use only certified sand and gravel suppliers that have been approved by the NEA and GD;

• Vegetation removal must be carefully carried out to avoid major soil disturbance, and only existing transportation routes used to avoid destruction of virgin land.

7.2.1.2 Mitigation of Air Pollution

• Access to pre-construction sites by the public must be prohibited by placing appropriate signs and barriers in combination with community sensitization on health and safety during works.

• Camps must be located sufficiently away from human settlements (at least 500 m).

In addition, other mitigation measures for generation of dust and other gaseous pollutants are as follows:

Generation of dust

Wet road surfaces to suppress dust emissions and prevent nuisance: • Workers must be provided with personal protection gear with the aim of preventing dust- related health problems and other dust nuisances;

• Trucks transporting sand and gravel must be covered to prevent dust and flying debris ;

• Special care will be taken when working near educational institutions, recreational grounds, mosques, health facilities, and other areas where the public may gather such as markets. This

will include erection of barriers and posting of sign boards to warn against intrusion of people into the work sites;

• Reduce speed to 10-20 km/h when crossing settlements or erecting speed bumps near;

• Training for drivers to adopt the best practices in driving.

Gaseous Pollution

• Contractors must also be warned in their agreement clauses to reduce air pollution through use of well-maintained equipment. Equipment must be serviced frequently and run below the optimal, as overloading strains the mechanisms that produce incomplete combustion. High quality oils must also be used to reduce dangerous air emissions;

• Emission standards prescribed in the Environmental Quality, Permitting and Discharge Regulations must not be exceeded;

• Ensure that engines of vehicles and machines are not left operating idle.

7.2.1.3 Mitigation of Noise and Vibration Nuisance All works must be carried out during daytime, between working hours, to reduce noise nuisance. In addition, the following must be observed:

• use of well-serviced equipment to reduce nuisance, thus maintenance of vehicles, equipment and machinery should be emphasized;

• provision of earplugs to workers exposed to high noise levels;

• raise awareness of this risk for the population and the measures put in place.

7.2.1.4 Mitigation of Unsightly Landscape • work sites must be cleared after all Project activities; • borrow pits should be reclaimed and restored to enhance landscape; • all waste produced during the pre-construction phase should be well managed; • stockpiles should be located at base camps and not numerous locations for ease of access ; • make an environmental and social reception which goes before the technical reception of the works.

7.2.1.5 Mitigation of the Impacts of Improper Waste Management Improved waste management measures shall be employed and enforced, and these will include developing a waste management plan to include amongst others, the types of waste, expected quantities and frequency, proposed management procedures and responsibilities. The plan will indicate the following:

• minimizing the production of waste that must be treated or eliminated where waste generation cannot be avoided;

• identification and classification (hazardous or not, solid, gaseous, or liquid) and estimate the likely type of waste to be generated such as cleared vegetation, packaging, excess aggregate, and disused equipment etc. in the C-ESMP;

• if hazardous wastes are generated, proper procedures must be taken regarding their storage, collection, transportation, and disposal as indicated in the Hazardous Chemicals and Pesticides Control and Management Act, 1994;

• using the cleared vegetation, as firewood within the communities;

• reusing the solid waste (such as topsoil wastes) generated from the excavation works as backfill while the rest will be disposed of in designated areas;

• other solid wastes (such as cement bags, metallic pieces, wooden planks, and leftover of aggregate material and debris) will be disposed of according to the National Environment Management Act, 1994 and Antilittering Regulations, 2007;

• recommending that the work contracts include waste management measures (as indicated in Appendix 6.1) such as those described in World Bank’s Environmental, Health, and Safety (EHS) Guidelines (1.6 Waste Management);

• identifying and demarcation of approved disposal areas, clearly indicating the specific materials that can be deposited in each; waste must not be discarded within, or close to Community Forests;

• all waste management options must be in a sound manner that does not affect human health and the environment;

• the Contractor developing a well-organized internal supervision and monitoring system to ensure waste reduction and proper management through full implementation of the waste management plan;

• external monitoring to be carried out by the TACs to remind the Contractors that they are being watched; also, to ensure discontinuation and mitigation where waste has been dumped illegally.

7.2.1.6 Mitigation of Deforestation Deforestation shall be minimized by the following:

• although vegetation will have to be cleared for the camp, poles, and access to certain areas, this should only be limited to the required area;

• divert routings to avoid trees where feasible;

• NAWEC shall develop a RAP to assess the potential losses and required compensation; where trees to be felled are forest trees (even outside protected forests), and thus belong to the DOF the DoF shall develop and implement a tree replacement plan, with 1:4 replacement ratio.. This will be done through the already developed and signed MOU with the DOF for its implementation (Appendix 7.1). The specific Reforestation and Restoration Plans, to be developed under the MOU, should include the situation of cut trees such as species and quantities.

Accordingly, other PAPs will also be considered, including loss of usufruct. In addition, timber trees (6 Eucalyptus trees) privately owned by Kolior Lower Basic School, under Feeder 2, Corridor 2 will be included in the RAP for compensatory reforestation.

• workers must be educated and warned by the Contractor to avoid forested areas, extracting wood, hunting, and burning activities, which will degrade the forests (particularly Community Forests certain corridors) and other vegetation.

7.2.1.7 Mitigation for the Loss of Fruit Trees • Only remove trees that are absolutely necessary for the works by diverting lines where possible; • Locate poles within the maximum range to avoid trees; • Encourage replanting programs rather than mere cash compensations.

7.2.1.8 Mitigation of Impacts on Fauna • All quarry pits created by the Project must be fully rehabilitated after mining;

• There must be constant supervision of works to ensure only necessary sites are cleared of vegetation;

• Construction workers must protect natural resources and wildlife; thus, they should be educated on guidelines relating to the hunting of wild animals;

• The Guinea baboon and Red colobus monkey populations, must be protected by:

o enforcing more vigorously the relevant national laws and regulations that prohibit their killing; o conducting training and information meetings on their preservation and protection at community level; o creating community wildlife reserves where threatened species such as the baboon could be protected;

o hunting and eating of bush meat by all workers, particularly imported workers, will be prohibited and alternatives such as fish and domestically reared animals encouraged; offenders must be disciplined in any of the following ways:

✓ informal warning; ✓ formal warning; ✓ loss of up to one week’s salary; ✓ suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months; ✓ termination of employment.

There should be a labor Grievance Redress Mechanism (GRM) to ensure that employees can report anonymously if needed to prevent risks of reprisals. The labor GRM should be included in the Contractors ESMP (C-ESMP) and as part of the bidding documents.

7.2.1.9 Mitigation of Impacts on Wetlands Avoid placing transmission lines through wetlands, if possible. If inevitable to avoid wetlands, there should be constant supervision of the works, environmental monitoring, and the

Contractor must ensure construction works and mitigation measures are according to the C- ESMP.

• Contractors shall minimize impacts wherever possible by integrating all mitigation measures into the design, including evaluation of alternative routes and designs to prevent or mitigate potential impacts. These include:

i. Routing of lines One method to mitigate impacts during Project design is replacing or double circuiting an existing line rather than building a new line. The same principle could apply in other areas besides wetlands. The environmental advantages of double-circuiting on an existing line are:

• little or no additional corridor clearing, if the new line can be placed in the center of an existing corridor; • land use patterns may have already adapted to the existing corridor; • magnetic fields may be reduced because new structure designs place line conductors closer together resulting in lower fields. Using corridor-sharing to minimize corridor requirements.

ii. Transmission Line Infrastructure Choosing a different transmission pole with different construction requirements and aesthetic appeal is another method to mitigate impacts during Project design. These will include:

• using H-frame structures, which have longer span widths, and thus make it easier to cross rivers, wetlands, or other resources with fewer impacts ;

• using the darker color of oxidized steel structures, which blend in better with forested backgrounds.

Pole foundation design factors to be considered especially in wetlands will involve: • highest flood and /or tidal level shall be established before pole construction; • soil analysis report especially in wetlands; • marine grade design concrete mix is used and vibrated accordingly.

iii. Add-ons By adding flight diverters to conductors, bird collisions with the wires can be minimized. These markers on the top (shield) wire make the lines more visible to birds if the collision potential is high.

7.2.2 Mitigation Measures of the Potential Negative Impacts on the Human Environment

7.2.2.1 Mitigation for Involuntary Resettlement and Loss of Livelihoods • Avoid agricultural lands by choosing alternative routes wherever possible;

• Where alternative routes are not possible, all loss of livelihood, including agricultural and rangeland, firewood and other forest produce collection will be addressed in a RAP;

Although this Project will not involve physical relocation of people, all PAPs should be compensated as required by the Bank’s OP 4.12. In this regard, a RAP shall be developed and implemented making sure that all persons affected by the Project are fully and fairly compensated for lost assets and livelihoods;

• Construction activities should be carried out in the dry season when agricultural fields are not in use (although for NAWEC, this is common practice for ease of access to line corridors without damaging crops in farmlands).

7.2.2.2 Mitigation for the impacts on vulnerable groups World Bank policies (such as OP 4.12) require that particular attention is paid to the needs of vulnerable groups, including women. Therefore, the development of any RAP must clearly identify and consult with them and address any potential risks that will prevent them from benefitting appropriately from resettlement benefits and financial compensations 7.2.2.3 Mitigation for risks to public health and safety • Warning and safety signs must be used before commencement and during the works to inform and warn the public of risks and means of avoidance;

• Gravel and sand borrow pits specifically approved for these works must be reclaimed to return the sites to as close as possible to the natural state;

• Danger of accidents and injuries from utilities and other equipment and machinery during the pre-construction phase shall be monitored vigorously; to prevent and protect the communities from harm, the contractor shall mount safety cordons and danger signs at strategic locations.

• Communities must be informed to stay away from work sites to avoid dust inhalation prior to works;

• Sourcing of workers, especially unskilled labor shall be from local communities to avoid imported labor, as much as possible;

• Recommended that skilled labor be rotated in on and off duty cycles to make them available to meet with their family members (back home) to minimize the chances of their mixing with the village women to minimize the chances of spreading STDs/STIs and HIV/AIDs (and increasing incidents of conflicts with the community, disruption to social cohesion and interpersonal relationships, including intimate partner relationships);

• The “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), and Violence Against Children (VAC)” will also be included in contracts including explicit references for monitoring, enforcement and compliance (as per Appendix 6.1);

• Awareness campaigns/orientation covering but not limited to HIV/AIDS/STDs transmission risks shall be carried out for workers and host communities;

• Regular check-up for workers to determine whether there are new cases of infections, and to what extend are these infections increasing or decreasing.

7.2.2.4 Mitigation of Violence Against Children • Children must not be employed by the Project, and the Project must comply with all relevant local legislation, including labor laws in relation to child labor and the Bank’s safeguard policies on child labor and minimum age.

• Communities need to be informed about the start of all works at least 5 days before, and the need for them to keep children away from the sites • Specifically, the project should ensure that the “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC)” are included in the Project’s bidding documents. The Codes of Conduct are meant to:

o create awareness of the ESHS and OHS expectations on the Project; o create common awareness about GBV, SEA and VAC; o ensure a shared understanding that GBV, SEA and VAC have no place in the Project; o create a clear system for identifying, responding to, and sanctioning GBV and VAC o incidents.

7.2.2.5 Mitigation of Risks to Occupational Health and Safety The following measures are important to be carried out to prevent and manage negative impacts to worker health and safety during the preconstruction phase:

• training and safety information should generally be provided to management, supervisors, workers, and occasional visitors to areas of risks and hazards. Specifically, there must be on- the-job training, and knowledge on procedures to reduce risks, including coordination and supervision;

• workers should be trained in good practices and contingency measures prior to the start of works. Integrate staff training, especially drivers on defensive driving, given the real road traffic risk;

• all workers employed by a Contractor for the Project must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments;

• although the main risks are analyzed in Chapter 8 for appropriate action, biological risks (wildlife attacks) can specifically be addressed by: - discussing with the communities risks of potential wildlife attacks in the area; - providing information to the staff on preparedness; - training on response; - provision of first aid kits; - provision of knowledge on the closest health facilities for additional expert help.

• the Contractor must provide proper working conditions for labor, including adequate toilets, drinking water, areas for rest and having meals, lighting (for camps) and waste disposal facilities. Consideration must also be given to these facilities at peak sites and times when the demand is higher.

The Contractor should adopt and implement a health and safety program which entails:

o effectively identifying and correcting unsafe conditions routinely; o protection of the workers and the public from dangers arising from operational activities of the facility;

o prevention of events resulting in potential injury to workers, the public, or the environment; o fire extinguishers, personal protective equipment and first aid kits should be provided, and training given on how to use them; o reporting of incidents is also essential for the review and improvement of safety procedures; o a tailor-made Accident Prevention Plan (APP) must be prepared and implemented by the Contractor. At the minimum, the Plan must consist of the following elements: ✓ management Policy Statement; ✓ authority and Accountability; ✓ goals and Objectives; ✓ employee Commitment and Responsibilities; ✓ employee Involvement; ✓ disciplinary Policy; ✓ record Keeping; ✓ safety and Health Surveys and Inspection/Program; ✓ safety or Other Related Meetings; ✓ safety and Health Training; ✓ safety Audit and Inspection; ✓ accident hazard and risk assessment; ✓ accident and Hazard Investigation; ✓ accident Reporting and Investigation; ✓ review and Revision of Components.

• Despite the accident prevention plan, incidents may occur, and an Emergency measures plan in case of accidents will be implemented to address: o general measures; o internal Operation Plan (POI); o circulation and movements on the sites; o individual and collective protection equipment; o special instructions for the use and movement of vehicles; o works inspection and maintenance program; o fire protection measures; o training and exercise procedures.

7.2.2.6 Mitigation of Risks of Communicable Diseases • The workforce shall be sourced locally to reduce the need for importation of workers. Employing local workers enhances community cohesion as the local workers know the community, culture, and norms which may also help decrease risks to GBV, SEA, spread of STDs and so on

• Nonetheless, to prevent STDs, it is essential that Contractors are required through the contracts to educate their workers on the risks and prevention methods before, and constantly during works. In addition to implementing measures on sensitization and education on the dangers and mitigation measures to address STIs, there will also be strict monitoring to ensure adherence to the relevant codes of conduct.

• Other methods include: Encouraging use of condoms.

NAWEC and Contractors providing surveillance and active screening and treatment of workers

• Ensuring the Contractor routinely reviews the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children with Project workers, including mandatory reviews with new workers to a Project site to ensure all workers understand behavior expectations and GBV/SEA risks, including sexual harassment. The Social Safeguards Specialist of the Project will attend sensitization meetings to ensure they are taking place. The Codes of Conduct are meant to:

o create awareness of the ESHS and OHS expectations on the project; o create common awareness about GBV, SEA and VAC; o ensure a shared understanding that GBV, SEA and VAC have no place in the project; o create a clear system for identifying, responding to, and sanctioning GBV, SEA and VAC incidents.

• Regarding the global Corona Virus pandemic, the PIU and contractors shall rely on national, WHO and WB guidance (Appendix 7.2) for safety of workers and community beneficiaries.

7.2.2.7 Mitigation for community instability • Initiate extensive consultations and sensitization with the communities and project affected persons about eligibility and compensation requirements through awareness-building meetings

• With regards to the management of deforestation products, privately owned trees are left with the owners and forest trees with the DOF, whilst products from other vegetation in the open can be collected by villagers on a first-come, first-served basis as traditionally practiced.

• Use the Grievance Redress Mechanism (GRM) at the ECOWAS-REAP PIU for prevention and resolution of conflicts arising from complaints and grievances relating to compensations, other Project related benefits and redress. Appendices 9.1 and 9.2 describes the GRM process.

• The GRM will involve Grievance Redress Committees in each Region (GRC) to investigate all complaints and grievances from PAPs relating to, for example: eligibility for compensation; PAPs not listed; etc.

• Employing local workers enhances community cohesion as local workers know the community, cultures, and norms which may also help decrease risks to GBV, SEA, spread of STDs and so on, as workers know the community and vice versa. As such, the Contractor will be required to write a hiring plan to incorporate local workers

Contractor to develop a hiring plan to ensure that community labor is being used, and also to ensure that women are employed in the Project;

• Apply the Codes of Conduct in order to mitigate against VAC, SEA and GBV in Project sites; prior to the start of work, the staff will be well sensitized, and they will sign the Codes of Conduct. Ensure regular trainings and awareness-building on the Codes of Conducts among all key stakeholders (community, contractor, workers) which will also be included in contractor’s C-ESMP and in bidding documents.

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7.2.2.8 Mitigation of impacts on sites of cultural and historical significance • The Contractors must avoid all sites of cultural or historical significance including any buffer created for their protection. These may include complete diversion of the lines or ensuring poles are not locating next to such sites. For example, small mosques along the routes can be avoided by adjusting the line span to ensure the poles are far away from the structures.

• Pole location must not be within the 200 m buffer around the Stone Circle site at Kerr Batch.

7.3 Potential Impact management during the construction phase

7.3.1 Mitigation Measures of the Potential Negative Impacts on the Biophysical Environment

7.3.1.1 Mitigation of Surface Water Pollution • Adjust the span between the poles to avoid waterbodies;

• For larger water bodies and wetlands, integrate all the identified mitigation measures, from design to implementation, in order to prevent or mitigate potential changes of water quality. For example, designs and plans should ensure siting of poles at a minimum safe distance from the water bodies;

• Constant supervision of the works and environmental monitoring will ensure construction works are not carried out close to the banks in order to avoid soil compaction leading to soil erosion and increase in sediment load of the tributaries;

• Workers shall be careful to prevent spills and improper management of waste and excess materials. Contractors will also ensure prescribed procedures are followed to protect water quality as required by the Environmental Quality Standards Regulations, 1999, and the Environmental Discharge (Permitting) Regulations, 2001.

7.3.1.2 Mitigation of Loss of Aquatic Ecosystems Existing vegetative buffers should be left undisturbed whenever possible.

For areas where construction impacts cannot be avoided, low-growing native tree and shrub buffers along these streams should be allowed to regrow so as to maintain the pre-construction water quality in the streams. To allow regrowth, the Contractor must ensure that the sites are returned to near original state (clear all excess materials and wastes that may affect regeneration; level soil around worksites similar to the surroundings to allow water movement).

Place markers on the top (shield) wire to make the lines more visible to birds if the collision potential is high.

Mitigation of Impacts on Wetlands Avoid placing transmission lines through wetlands, if possible. If inevitable to avoid wetlands, there should be constant supervision of the works, environmental monitoring, and the Contractor must ensure construction works and mitigation measures are according to the C-ESMP.

Adjust pole placements to span wetlands, or limit equipment access in wetlands, wherever possible. By making minor adjustments in pole locations (especially given the allowable span between poles), impact on archaeological sites and agricultural operations can be minimized.

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Line clearance safety is important to take into consideration during the routing of the MV lines. Use Table 7.1 below as guide.

Table 7.1: Recommended Minimum Clearance Distances for Various Sites

Nature of Area Minimum Clearance (meters) Over Open Country 5.20 Over the Road 6.10 Along the Road 5.80 Over telecom Lines 2.44 Over Rivers 6.10 Over MV or LV Lines 2.44 Under HV Lines 2.44 Near Buildings Vertical 3.70 Horizontal 2.00 Source: OMVG, 2018

7.3.1.4 Mitigation of Noise and Vibration Nuisance All construction works must be carried out during daytime, between 8am and 6pm, to reduce noise and vibration nuisance. In addition, the following must be observed:

- use of well-serviced equipment to reduce nuisance, thus maintenance of vehicles, equipment and machinery should be emphasized;

- provision of earplugs to workers exposed to high noise levels;

- enforce strict work rules to limit only necessary workers at the sites.

7.3.1.5 Mitigation of Unsightly Landscape During the works, Contractors must encourage good housekeeping to ensure sites are organized. All excavations and piles of earth materials that have been made during the works and not used must be levelled to return the sites similar to its surroundings.

All equipment and heavy vehicles must be parked securely at special sites (base camp or identified sites for this purpose) at the end of each workday.

All excess and waste materials will be removed from the work sites for appropriate management as earlier discussed.

7.3.1.6 Mitigation of Air Pollution Mitigation measures for air pollution through generation of dust and other gaseous pollutants during construction include:

• wetting work sites to suppress dust emissions and prevent nuisance;

• workers must be provided with personal protection gear with the aim of preventing dust nuisances and other dust-related health problems;

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• trucks transporting sand and gravel to the work sites must be covered to prevent dust and flying debris;

• special measures will be taken when working near complex areas such as educational institutions, recreational grounds, mosques, markets, and health facilities. This will include erection of barriers and posting of sign boards to warn against intrusion of people into the work sites;

• the workdays will also be altered to make use of opportunities when these sites are free or less busy. For example, avoiding school or weekly market days;

• contractors must also be warned in their agreement clauses to reduce air pollution through use of well-maintained equipment. Equipment must be serviced frequently and run below the optimal, as overloading strains the mechanisms that produce incomplete combustion. High quality fuels and oils must also be used to reduce dangerous air emissions;

• emission standards prescribed in the Environmental Quality, Permitting and Discharge Regulations must not be exceeded;

• reduce speed to 10-20 km/h when entering settlements;

• ensure that engines of vehicles and machines are not left operating idle;

• erecting speed bumps when settlements are regularly crossed.

7.3.1.7 Mitigation of Extreme Weather Impacts Plan and execute pole erection after the rainy season as this would prevent works from being interrupted due to potential heavy rains.

Workers should be trained and supervised in safe practices, such as daily inspection of equipment, and use of personal protective gear.

The planners and contractors should avoid locating poles at the edges of culverts and water bodies to prevent poles from collapsing as a result of erosion. Given that the minimum span between poles is 100 m, contractors must not site poles less than 15 m on each side of surface water bodies to prevent possible erosion and collapsing of poles. Poles should be located at least 5 m from the edge of the culvert, and not within the route of water flow.

Within wetlands, specially engineered foundation types should be employed for durability.

7.3.1.8 Mitigation of Impacts related to the Importation of Workers Employing construction workers in the various Project intervention villages will be impractical considering the short-term nature of the construction activities with little time for scouting and training. Therefore, contractors should at least aim to employ workers from the various administrative Regions of The Gambia where the Project falls.

Communities should also be aware of the GRM in case of complaints and reports relating to the Project, including activities of its workers.

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Internal supervision and monitoring by the Contractor’s team will ensure workers are controlled within the Project sites and identified construction activities.

7.3.2 Mitigation Measures of the Negative Impacts on the Human Environment

7.3.2.1 Mitigation of Impacts related to Public Health and Safety

• At sites of weekly markets or schools, construction works must be carried out only on non- market or school days. Where some traders remain permanently at the sites, a RAP will be developed to include any loss of livelihood for displacement to a safe location during the construction phase.

• Alternatively, the routing of the lines can be changed where possible, and be located behind the markets, to avoid the congested areas.

• Strict restrictions must be put in place to prohibit access of the public to work sites, materials, and equipment

• Communities must be given prior notice before commencement of the works to inform and warn the public of risks and means of avoidance. Communities must be informed to stay away from work sites.

• To prevent road traffic accidents, work supervisors must ensure speed limits are controlled and operators of vehicles and heavy equipment well trained other measures to mitigate the potential health risks in traffic and vehicular movement, include:

o the Contractors must emphasize safety aspects among drivers;

o drivers’ skills should be tested and improved through training, including training on defensive driving, given the real road traffic risks;

o Contractors should adopt limits for trip duration and preparing driver rosters to avoid overtiredness;

o drivers must avoid dangerous routes and busy times of day to reduce the risk of accidents, particularly with long parts;

o Contractors should maintain regular maintenance of vehicles and use of manufacturer approved parts to minimize potentially serious accidents caused by equipment malfunction or premature failure;

o institute fines and penalties for non-compliance, including deduction of wages, suspension, or even dismissal for habitual errant Project drivers;

o there should be effective site management, including signage, lighting, and warning signs, including restriction of access by unauthorized personnel.

7.3.2.2 Mitigation of Risks of Communicable Diseases • During disease outbreaks, the PIU and Contractors must ensure that the Project related activities and workers are in line with the Emergency Regulations set by the Government of

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The Gambia. Specifically, these include distancing, crowd control, improved sanitation, and movement restrictions.

• The workforce shall be sourced locally to reduce the need for importation of workers. Employing local workers will make them take more responsibility for their actions and will reduce promiscuousness. Knowing the community, culture, and norms will also help decrease risks to GBV, SEA, and spread of STDs.

• Other methods include:

o encouraging use of condoms;

o NAWEC and Contractors providing surveillance and active screening and treatment of workers;

o ensuring the Contractor routinely reviews the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children with Project workers, including mandatory reviews with new workers to a Project site to ensure all workers understand behavior expectations and GBV/SEA risks, including sexual harassment. The Social Safeguards Specialist of the Project will attend sensitization meetings to ensure they are taking place. The Codes of Conduct are meant to:

✓ create awareness of the ESHS and OHS expectations on the project; ✓ create common awareness about GBV, SEA and VAC; ✓ ensure a shared understanding that GBV, SEA and VAC have no place in the project; ✓ create a clear system for identifying, responding to, and sanctioning GBV, SEA and VAC incidents.

• It is recommended that skilled labor be rotated in on and off duty cycles to make them available to meet with their family members (back home) to minimize the chances of their mixing with the village women to minimize the chances of spreading STDs/STIs and HIV/AIDs (and increasing incidents of conflicts with the community, disruption to social cohesion and interpersonal relationships, including intimate partner relationships)

• Awareness campaigns/orientation covering but not limited to HIV/AIDS/STDs transmission risks shall be carried out for workers and host communities

• Regular check-up for workers to determine whether there are new cases of infections, and to what extend are these infections increasing or decreasing.

7.3.2.3 Mitigation of Occupational Health and Safety Risks

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The following measures will be implemented to mitigate worker health and safety risks during construction. In addition, Chapter 8 covers the accident risk assessment and management plan which will be employed for specific risks and accidents.

• Specifically, biological risks (wildlife attacks) can be addressed by: - discussing with the communities, risks of potential wildlife attacks in the area; - providing information to the staff on preparedness; - training on response; - provision of first aid kits; - provision of knowledge on the closest health facilities for additional expert help.

• Training and safety information should generally be provided to management, supervisors, workers, and occasional visitors to areas of risks and hazards. Specifically, there must be on- the-job training, and knowledge on procedures to reduce risks, including coordination and supervision.

• Workers should be trained in good practices and contingency measures prior to the start of works

• All workers employed by the Contractor for the Project must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments.

• The Contractor must provide proper working conditions for labor, including adequate toilets, drinking water, areas for rest and having meals, lighting (especially for camps) and waste disposal facilities. Consideration must also be given to these facilities at peak sites and times when the demand is higher.

• The Contractor should support in providing medical care to workers, particularly for health conditions occurring during work. This may include health insurance, transportation costs to health facilities and medical fees.

• The Contractor should adopt and implement a health and safety program which entails:

o effectively identifying and correcting unsafe conditions routinely; o protection of the workers and the public from dangers arising from construction activities; o prevention of events resulting in potential injury to workers, the public, or the environment; o fire extinguishers, personal protective equipment and first aid kits should be provided, and training given on how to use them; o reporting of incidents is also essential for the review and improvement of safety procedures; o a tailor-made Accident Prevention Plan (APP) must be prepared and implemented by the Contractor. At the minimum, the Plan must consist of the following elements:

✓ management Policy Statement; ✓ authority and Accountability;

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✓ goals and Objectives; ✓ employee Commitment and Responsibilities; ✓ employee Involvement; ✓ disciplinary Policy; ✓ record Keeping; ✓ safety and Health Surveys and Inspection/Program; ✓ safety and other Related Meetings; ✓ safety and Health Training; ✓ safety Audit and Inspection; ✓ accident hazard and risk assessment; ✓ accident and Hazard Investigation; ✓ accident Reporting and Investigation; ✓ review and Revision of Components.

• Despite the accident prevention plan and due diligence, incidents may occur, and an Emergency Measures Plan in case of accidents will be implemented to address:

o general measures; o internal Operation Plan (POI); o circulation and movements on the sites; o individual and collective protection equipment; o special instructions for the use and movement of vehicles; o works inspection and maintenance program; o fire protection measures; o training and exercise procedures.

7.3.2.4 Mitigation of Gender Based Violence and Violence Against Children • Children must not be employed by the Project (paid or unpaid), and the Project must comply with all relevant local legislation, including labor laws in relation to child labor and the World Bank’s safeguard policies on child labor and minimum age.

• Communities need to be informed about the start of all works, at least 5 days before, and the need for them to keep children away from the sites.

• Specifically, the project should ensure that the “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse (SEA) and Violence Against Children (VAC)” are included in the Project’s bidding documents. The Codes of Conduct are meant to:

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7.3.2.5 Mitigation of Land Use Impacts and Loss of Livelihoods

• Avoid agricultural lands by choosing alternative routes wherever possible

• Where alternative routes are not possible, this Project will not involve permanent, physical relocation of people; all PAPs will be compensated as required by the national laws and the World Bank’s OP 4.12. In this regard, a RAP shall be developed and implemented making sure that all persons affected by the Project are fully and fairly compensated for any loss of assets and livelihoods.

• Contractors must ensure to use the maximum allowable distance between poles to reduce the number of poles that would potentially be located within a single farmer’s field

• Construction works will be carried out outside loumo (market) days to avoid impacting shops and vendors’ income and revenues

7.3.2.6 Mitigation of Chance Finds Impacts • Should an unusual, uncommon or atypical finding be made along any of the feeder corridors, the Chance Find Procedures described in Appendix 4.3 will be applied: avoid further disturbance and secure discovery, inform the supervisor for onward conveyance to NAWEC and the National Council for Arts and Culture (the legal institution responsible to manage cultural heritage) for proper management.

7.3.2.7 Mitigation of Risks from Force Majeure • All reasonable precaution will be taken by the Project during construction to prevent danger to the workers and the public. This will include provision of timely information, and in certain instances (such as disease pandemics) postponement of works until the risk subsides.

• The PIU and Contractors will abide by any national emergency regulations passed by the Government of The Gambia during such periods.

7.4 Impact Management during the Operation and Maintenance Phase

7.4.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment

7.4.1.1 Mitigation of effects of extreme weather conditions • During operation, routine inspection and maintenance shall reduce destruction of infrastructure during strong winds and heavy rainfall.

7.4.1.2 Mitigation of Impacts on Landscape and Aesthetics • All waste must be collected and disposed according to the C-ESMP.

• T & D technical designs and plans will consider reducing the number of feeder lines emanating from the same points of a particular substation (different directions or underground). NAWEC

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planners and surveyors will also be trained in improving the scenery during installation of distribution networks.

7.4.1.3 Mitigation for Impacts on Trees • Fruit tree pruning must be carried out only when tree branches grow towards the conductors.

• Pruning should also be planned when fruit trees are not in their fruiting season to reduce losses.

7.4.1.4 Mitigation of Loss of Fauna • Although overhead MV lines are usually of bare cables, this Project must give special design consideration to corridors within protected areas in order to avoid impact on avifauna and climbing animals. The Project design should include a more protective line design.

• Add-ons may be installed, such as flight diverters to conductors, to minimize bird collisions with the wires. These markers on the top (shield) wire make the lines more visible to birds if the collision potential is high.

• Nesting grounds and migratory paths should be protected; to reduce risk of birds colliding with the lines, bird-flight diverters will be used. These are designed to make overhead lines and guyed structures visible to birds and provide an economical means of reducing the hazard to both lines and birds.

• Anti-nesting devices, or artificial nest platforms must be used to mitigate and reduce risks to the avifauna

7.4.2 Mitigation Measures of the Negative Impacts on the Human Environment

7.4.2.1 Mitigation of Risks to Public Health and Safety • General education on the safety of electricity infrastructure will be included in public awareness programs.

• Maintenance teams routinely clearing the ROW for the T & D corridors will ensure community members are prohibited from work sites during pruning.

7.4.2.2 Mitigation of Occupational Health and Safety Risks The following measures will be implemented to mitigate worker health and safety risks during operation and maintenance:

• training and safety information should generally be provided to management, supervisors, and workers on the risks and hazards. Specifically, there must be on-the-job training, and knowledge on procedures to reduce risks, including coordination and supervision;

• workers should be trained in good practices and contingency measures prior to the start of works;

• All workers employed the Project activities must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments;

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• The Contractor / NAWEC staff carrying out maintenance works should adopt and implement a health and safety program which entails:

o effectively and routinely identify and correct unsafe conditions routinely; o Protection of the workers and the public from dangers arising from construction activities; o prevention of events resulting in potential injury to workers, the public, or the environment; o fire extinguishers, personal protective equipment and first aid kits should be provided, and training given on how to use them; o reporting of incidents is also essential for the review and improvement of safety procedures; o a tailor-made Accident Prevention Plan (APP) must be prepared and implemented by the Contractor. At the minimum, the Plan must consist of the following elements: ✓ Management Policy Statement; ✓ Authority and Accountability; ✓ Goals and Objectives; ✓ Employee Commitment and Responsibilities; ✓ Employee Involvement; ✓ Disciplinary Policy; ✓ Record Keeping; ✓ Safety and Health Surveys and Inspection/Program; ✓ Safety and other Related Meetings; ✓ Safety and Health Training; ✓ Safety Audit and Inspection; ✓ Accident hazard and risk assessment; ✓ Accident and Hazard Investigation; ✓ Accident Reporting and Investigation; ✓ Review and Revision of Components.

• Despite the accident prevention plan and due diligence, incidents may occur, and an Emergency Measures Plan in case of accidents will be implemented to address:

o general measures; o internal Operation Plan (POI; o circulation and movements on the sites; o individual and collective protection equipment; o special instructions for the use and movement of vehicles; o works inspection and maintenance program; o fire protection measures; o training and exercise procedures.

7.4.2.3 Mitigation of Impacts on Public Services • Prior to connection of the new infrastructure to the substations, the public must be informed well in advance about disruptions to electricity services. This will allow them to plan and prepare accordingly.

7.5 Impact Management during the Decommissioning Phase

7.5.1 Mitigation Measures of the Negative Impacts on the Biophysical Environment

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7.5.1.1 Mitigation of Improper Waste Management Improved waste management measures shall be employed and enforced, and these will include developing a waste management plan to include amongst others, the types of waste, expected quantities and frequency, proposed management procedures and responsibilities. The plan will indicate the following:

• minimizing the production of waste that must be treated or eliminated where waste generation cannot be avoided;

• identification and classification (hazardous or not, solid, gaseous, or liquid) and estimate the likely type of waste to be generated such as cleared vegetation and disused equipment etc.;

• other wastes will be disposed of according to the National Environment Management Act, 1994 and Antilittering Regulations, 2007;

• identifying and demarcation of approved disposal areas, clearly indicating the specific materials that can be deposited in each; waste must not be discarded within, or close to Community Forests;

• the Contractor developing a well-organized internal supervision and monitoring system to ensure waste reduction and proper management through full implementation of the waste management plan;

• external monitoring to be carried out by the TACs to remind the Contractors that they are being watched; also, to ensure discontinuation and mitigation where waste has been dumped illegally.

7.5.1.2 Mitigation of Air Pollution In addition, other mitigation measures for generation of dust and other gaseous pollutants are as follows: • wet road surfaces to suppress dust emissions and prevent nuisance;

• workers must be provided with personal protection gear with the aim of preventing dust- related health problems and other dust nuisances;

• contractors must also be warned in their agreement clauses to reduce air pollution through use of well-maintained equipment. Equipment must be serviced frequently and run below the optimal, as overloading strains the mechanisms that produce incomplete combustion. High quality oils must also be used to reduce dangerous air emissions;

• reduce speed to 10-20 km/h when entering settlements;

• erecting speed bumps when settlements are regularly crossed.

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7.5.2 Mitigation Measures of the Negative Impacts on the Human Environment

7.5.2.1 Mitigation of Impacts related to Public Health and Safety • Gravel and sand borrow pits specifically approved for these works must be reclaimed to return the sites to as close as possible to the natural state to prevent water looging and drowning of children and animals.

• Strict restrictions must be put in place to prohibit access of the public to work sites, materials, and equipment.

• Communities must be given prior notice before commencement of the works to inform and warn the public of risks and means of avoidance. Communities must be informed to stay away from decommissioning work sites.

o the Contractors must emphasize safety aspects among drivers; o drivers’ skills should be tested and improved through training on defensive driving, given the real road traffic risks; o contractors should adopt limits for trip duration and preparing driver rosters to avoid overtiredness; o drivers must avoid dangerous routes and busy times of day to reduce the risk of accidents, particularly with long parts; o contractors should maintain regular maintenance of vehicles and use of manufacturer approved parts to minimize potentially serious accidents caused by equipment malfunction or premature failure; o institute fines and penalties for non-compliance, including deduction of wages, suspension, or even dismissal for habitual errant Project drivers; o there should be effective site management, including signage, lighting, and warning signs, including restriction of access by unauthorized personnel.

7.5.2.2 Mitigation of Risks of Communicable Diseases • During disease outbreaks, the PIU and Contractors must ensure that the Project related activities and workers are in line with the Emergency Regulations set by the Government of The Gambia. Specifically, these include distancing, crowd control, improved sanitation, and movement restrictions.

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on the dangers and mitigation measures to address STIs, there will also be strict monitoring to ensure adherence to the relevant codes of conduct.

• Other methods include: o encouraging use of condoms; o NAWEC and Contractors providing surveillance and active screening and treatment of workers; o ensuring the Contractor routinely reviews the Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV), Sexual Exploitation and Abuse and Violence Against Children with Project workers, including mandatory reviews with new workers to a Project site to ensure all workers understand behavior expectations and GBV/SEA risks, including sexual harassment. The Social Safeguards Specialist of the Project will attend sensitization meetings to ensure they are taking place. The Codes of Conduct are meant to:

• Awareness campaigns/orientation covering but not limited to HIV/AIDS/STDs transmission risks shall be carried out for workers and host communities.

7.5.2.3 Mitigation of Occupational Health and Safety Risks The following measures will be implemented to mitigate worker health and safety risks during decommissioning:

• training and safety information should generally be provided to management, supervisors, workers, and occasional visitors to areas of risks and hazards. Specifically, there must be training on-the-job, and knowledge on procedures to reduce risks, including coordination and supervision;

workers should be trained in good practices and contingency measures prior to the start of works;

• the Contractor should support in providing medical care to workers, particularly for health conditions occurring during work. This may include health insurance, transportation costs to health facilities and medical fees;

• all workers employed by the Contractor for the Project must be informed of the associated hazards and risks. A basic occupational training program and specialty courses should be provided as needed to ensure that workers are aware to the specific hazards of individual work assignments;

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• the Contractor should adopt and implement a health and safety program which entails:

✓ Management Policy Statement; ✓ Authority and Accountability; ✓ Goals and Objectives; ✓ Employee Commitment and Responsibilities; ✓ Employee Involvement; ✓ Disciplinary Policy; ✓ Record Keeping; ✓ Safety and Health Surveys and Inspection/Program; ✓ Safety and other Related Meetings; ✓ Safety and Health Training; ✓ Safety Audit and Inspection; ✓ Accident hazard and risk assessment; ✓ Accident and Hazard Investigation; ✓ Accident Reporting and Investigation; ✓ Review and Revision of Components.

• Despite the accident prevention plan and due diligence, incidents may occur, and an Emergency Measures Plan in case of accidents will be implemented to address:

7.5.2.4 Mitigation of Gender Based Violence and Violence Against Children • Children must not be employed by the Project (paid or unpaid), and the Project must comply with all relevant local legislation, including labor laws in relation to child labor and the World Bank’s safeguard policies on child labor and minimum age.

• Communities need to be informed about the start of all works, at least 5 days before, and the need for them to keep children away from the sites.

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7.6 Mitigation of Potential Cumulative Impacts

• The cumulative impacts can be mitigated by ensuring that all the mitigation measures in the ESMP are fully implemented. These include amongst others, working outside the farming season, avoid forests and unrelated removal of vegetation, strategically locate poles, develop and implement the C-ESMP, provide information and educate on health and safety. Future cumulative impacts may be mitigated by studies done and implemented at that time.

Given the above, it is evident that there will be both positive and negative impacts created by the Project. For the most part negative impacts will be short-term, localized and small scale, and can be mitigiated through this ESMP. With full implementation of the ESMP in timely manner, and enhancement of the positive impacts, the beneficiaries and affected communities will be better-off with the Project than the null alternative.

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CHAPTER 8: MANAGEMENT OF RISKS AND ACCIDENTS

This Chapter identifies and analyses the potential risks and accidents that may occur during the various phases of the Project. It further outlines the main issues to be addressed by the Contractor including mitigation and prevention, training needs, contingeny and emergency response planning, recording, reporting and monitoring.

8.1 Methodological Approach for Hazards and Risks Identification

8.1.1 Objectives of the Risk Assessment and Management

The main purpose of the risk assessment is to: • identify potential risks of the Project activities (factors / hazards that have the potential to expose the workers, communities, and property to harm); • evaluate which risks require priority actions ; • recommend corresponding measures to prevent or reduce the risks, and at last resort, protection against the risks.

8.1.2 Methodology In this risk identification, the Project activities (sources of hazards and risks) earlier stated were correlated with a list of possible risks. Where there is likelihood of a risk causing harm to the public or workers, the interaction box is highlighted with a cross as indicated in Table 8.1.

Further analysis of the risks (severity, probability, exposure levels and possibility of control) will consider their importance and magnitude of mitigation measure needed for prevention or effective management.

Adopted from Moja et al. (2016), the procedure below was modified for this risk assessment:

i. Rate the risks: Scores (1-5) were allocated to the various risks on severity, probability, exposure, and control according to the ratings described in Table 8.2.

ii. Calculate the actual risk: actual risk = severity + probability + exposure iii. Calculate significance of the risk = actual risk - possibility of control iv. Rate the final scores according to the following levels of significance as in Table 8.3:

0 means no significance of risk 1 - 5 means low significance of risk 6 - 9 means medium significance of risk 10 - 15 means high level of concern

Following the risk analyses, corresponding preventive and protective measures are then recommended for mitigation. These should follow the mitigation hierarchy from elimination, control, and reduction of the risks to providing protection against the hazards. An example of the risk analysis matrix for the pre-construction phase is given for replication by the contractor. The contractor should tailor-make the analyses based on his tasks and program.

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8.1.3 Risk Identification Table 8.1 identifies the risks likely to cause harm during the different phases of the Project implementation. It further identifies whether the communities or workers are exposed to such risks.

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PROJECT PHASES ACTIVITIES / SOURCES OF RISKS RISKS TO THE PROJECT WORKERS RISKS TO THE

PUBLIC

llness

sks

ance

l injuries linjuries

al workers al

ite conditions conditions ite

age age

Noise nuis Noise risks Vibration ri Chemical shocks Electrical explosions and Fires injuries Personal Ergometrics risks Respiratory Unethic attacks Wildlife s Work stress related Work nuisance Noise shocks Electrical explosions and Fires risks Respiratory workers Unethical

Movement circulation Equipment use and and storage Sabot Insecurity illness Contagious Movement circulation Equipment use and and storage Persona i Contagious

Explosions Explosions Pre-construction Consultation and provision of Project X X information Physical survey of proposed project sites X X X X X X X X Siting of poles in land owned or used by X X X villagers Clearing of vegetation for access and X X X X X X X X X X X X X X X X X X poles Felling and trimming of economic trees X X X X X X X X X X X X X X X within the ROW Clearing of quarrying site X X X X X X X X X X Excavation during quarrying X X X X X X X X X Stockpiling of earth and other materials X X X X X X X Clearing for camp sites X X X X X X X X Construction Transportation of workers, equipment X X X and materials Importation of workers X X X X X X Repair of heavy vehicles and equipment X X X X X X X Storage of heavy vehicles and equipment X X X during works Digging of trenches for pole foundations X X X X X X X X X X X X X X Building of foundations X X X X X X X X Erection of poles X X X X X X Installation of cables and accessories X X Removal of excess and waste materials X X X X Operation and Connection to substations and existing X X X Maintenance grid

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Connection to users X X X X X X X X Pruning of trees X X X X X X Repair and replacement of T & D parts X X X X X X Decommissioning Reclamation and restoration of quarries X X X X X X X Dismantling of equipment and structures X X Transportation of materials and X X X X equipment from camps

Cleaning of camp sites upon closure X X X

Table 8.1: Risk identification matrix

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Description Score Definition

PROBABILITY Insignificant 1 Risk consequences will occur only in exceptional circumstances (The Likelihood that a risk Minor 2 Risk consequences unlikely to occur in a year consequence will Moderate 3 Risk consequences likely to occur in a year occur) Major 4 Risk consequences could likely occur within a month Catastrophic 5 Risk consequences almost certain to occur a few times in a month

EXPOSURE Rare 1 Exposure to this risk is limited to only 1 person (employee/public) who may be affected (which parties and how many people Unlikely 2 Exposure to this risk may affect more than 1 person are exposed) Possible 3 Exposure to this risk may affect 50% of (workers or beneficiary community) Likely 4 Exposure to this risk may affect more the 50% of employees / beneficiary community Almost certain 5 Exposure may affect 100 % of workforce / beneficiary community

SEVERITY Minimal 1 Insignificant or no likely injury or treatment will be required (minimum time of exposure) (what will be the seriousness of the Restricted 2 Minor injury or need for medical attention. No lost time expected Local 3 Likely disabling condition consequence) Widespread 4 Several disabilities may occur Extensive 5 Fatality; Imminent risk of long-term disability

CONTROL 1 Measures that protect the individual worker e.g. provision of masks, safety shoes, helmets, fencing etc. (possible mitigation measures that can prevent or reduce risks) 2 Measures that in addition to the above, involve changes in procedure to safety to involve instructions, training, awareness, and screening 3 Measures that address hazards by design of infrastructure or equipment e.g. insulation or infiltration 4 Measures that replace the hazard with a safer option 5 Measures that eliminate the risk completely Table 8.2: Risk evaluation / rating

Source: S D Focus Ltd. (2020), Adopted from Moja et al. (2016)

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Table 8.3 is an example of risk analysis using the described procedure. The Contractors shall develop similar matrices for the construction, operation and maintenance and decommissioning phases. The Contractors shall tailor-make the analyses based on the specific tasks, resources, personnel, procedures etc. they plan to employ.

Table 8.3: Preconstruction Phase Risk Analysis Matrix

Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance 1 Sabotage Poor Consultation All Project 2 1 1 4 4 0 Consultations consultations, activities workers to start well in non-cohesive (Consultants advance communities / NAWEC during the staff / project Contractors) development phase to enhance acceptability 2 Movement Increased Physical Workers 2 3 3 2 8 6 Workers must and circulation movement of surveying employ good risks such as vehicles and driving and traffic number of parking skills; accidents people avoid parking in middle of

roads; use

reflector

vests; use hazard lights

Train all drivers on

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance defensive driving

Clearing for Workers 3 3 4 2 10 8 Constant access and and the supervision of sites of public workers; poles employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only Clearing for Workers 2 3 2 2 7 5 Constant quarrying and the supervision of public workers; employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Excavation Workers 2 2 2 2 6 4 Constant during and the supervision of quarrying public workers; employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only Stockpiling Workers 3 4 3 2 10 8 Constant of materials and the supervision of public workers; employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only; secure stockpiles

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing of Workers 2 2 2 2 6 4 Constant base / camp and the supervision of sites public workers; employ qualified workers; train workers; restriction warning signs; inform community to avoid sites; work during daylight only 3 Noise nuisance Heavy Clearing for Workers 4 1 2 2 7 5 Use machinery access and and the appropriate, and sites of public well-serviced equipment; poles equipment; workers provide protective gear for workers; restriction warning signs; inform community to avoid sites; only work during the day

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Felling and Workers 2 2 2 2 6 4 Use trimming of and the appropriate, trees within public well-serviced ROW equipment; provide protective gear for workers; restriction warning signs; inform community to avoid sites; only work during the day Clearing for Workers 2 1 1 3 4 1 Use quarrying appropriate, well-serviced equipment; provide protective gear for workers; inform community to avoid sites; only work during the day

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing of Workers 2 1 1 3 4 1 Use base / camp appropriate, sites well-serviced equipment; provide protective gear for workers; restriction warning signs; inform community to avoid sites; work during the day 4 Vibration risks Heavy Clearing for Workers 2 3 3 4 8 4 Use of machinery access and appropriate and hand-held sites of machinery and tools poles equipment based on the type of terrain Felling and Workers 2 3 3 3 8 5 Limit exposure trimming of by reducing trees within working hours ROW on handheld equipment such as chain saws

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance 5 Risks related Heavy Clearing for Workers 4 4 4 2 12 10 Employ to improper machinery, access and and the workers with use and sharp and hot sites of public requisite skills; storage of objects poles keep equipment equipment in secure base camps; restrict access to sites Clearing for Workers 3 2 4 2 9 7 Constant quarrying supervision of workers; employ qualified workers; train workers; set procedures for safe operation Felling and Workers 2 3 3 2 8 6 Constant trimming of and the supervision of trees within public workers; ROW employ qualified workers; train workers; set procedures for safe operation; prohibit the public from the sites during works

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Excavation Workers 2 3 2 2 7 5 Constant during supervision of quarrying workers; employ qualified workers; train workers; set procedures for safe operation Clearing of Workers 3 4 4 2 11 9 Constant base / camp supervision of sites workers; employ qualified workers; train workers; set procedures for safe operation 6 Fires and Vegetation Clearing for Workers 3 3 3 2 9 7 Waste should explosions and other access and and the never be waste from sites of public burnt; follow clearing poles waste management plan Clearing for Workers 2 3 3 2 8 6 Waste should quarrying and the never be public burnt; follow waste management plan

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing of Workers 2 3 3 2 8 6 Waste should base / camp never be sites burnt; follow waste management plan 7 Personal Hanging trees Physical Workers 3 2 3 3 8 5 Use trained injuries such branches, survey of personnel that as cuts, struck stones, proposed incorporate by objects, equipment project sites health and stepping on etc. safety issues objects, falls in the work programmes; use personal protective gear Clearing for Workers 4 3 5 1 12 11 Use trained access and and the personnel that sites of public incorporate poles health and safety issues in the work programmes; provide personal protective gear; prohibit public access to sites

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Felling and Workers 2 2 5 2 9 7 Use trained trimming of and the personnel that trees within public incorporate ROW health and safety issues in the work programmes; provide personal protective gear Excavation Workers 2 4 2 2 8 6 Use trained during and the personnel that quarrying public incorporate health and safety issues in the work programmes; provide personal protective gear; prohibit public access to sites Stockpiling Workers 3 4 4 3 11 8 Prohibit public of materials and the access to public stockpiles; use security personnel

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing of Workers 2 2 4 2 8 6 Use trained base / camp personnel that sites incorporate health and safety issues in the work programmes; provide personal protective gear Clearing for Workers 2 3 3 2 8 6 Provide quarrying and the personal public protective gear; prohibit public access to quarries; supervise constantly 8 Risks related Long Excavation Workers 4 3 5 2 12 10 Use to materials, during excavation ergometrics; heavy quarrying machinery poor manual materials, rather than handling etc. tasks manual involving labour; allow bowing for adequate long breaks during work Stockpiling Workers 4 4 4 1 12 11 Use machines of materials to assist moving heavy

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance and long loads; supervise constantly 9 Respiratory Dust, gaseous Clearing for Workers 4 2 5 3 11 8 Provide masks risks vehicular access and and the for workers; emissions sites of public prohibit public poles access to work sites; give prior notification particularly for LV lines within populated areas Felling and Workers 2 2 4 3 8 5 Provide masks trimming of for workers; trees within prohibit public ROW access to work sites Clearing for Workers 3 3 5 2 11 9 Provide masks quarrying for workers Excavation Workers 5 3 5 2 13 11 Provide masks during for workers quarrying Stockpiling Workers 2 2 3 2 7 5 Provide masks of materials for workers; prohibit public access to work sites

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing of Workers 2 3 5 2 10 8 Provide masks base / camp for workers sites 10 Insecurity Aggressive Siting of Workers 4 4 2 3 10 7 Early from burglary, PAPs, poles in land consultation; threats, and stockpiles left owned or involvement personal in the open used by of village attacks villagers heads; use well trained personnel; work in teams; use base camps and provide security Stockpiling Workers 2 2 5 4 9 5 pack materials of materials only at designated bases / camps; employ security personnel 11 Contagious Microbes Physical Workers, 2 4 5 2 11 9 Education and illnesses, (e.g. STIs, E- surveying villagers awareness on ingestion of coli, Covid 19) prevention contaminated and relevant food or drink codes of conduct; provision and use of masks, condoms

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing for Workers, 4 4 5 2 13 11 Educate access and villagers workers and sites of communities poles of risks and prevention of contagious illnesses; provide protection; provide sanitation means for workers; reduce importation of workers Felling and Workers, 2 4 3 2 9 7 Educate trimming of villagers workers and trees within communities ROW of risks and prevention of contagious illnesses; provide protection; provide sanitation means for workers

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing for Workers 2 4 2 2 8 6 Educate quarrying workers and communities of risks and prevention of contagious illnesses; provide protection; provide sanitation means for workers Clearing of Workers 2 4 3 2 9 7 Educate base / camp workers and sites communities of risks and prevention of contagious illnesses; provide protection; provide sanitation means for workers

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance 12 Risks related unethical / Siting of Villagers 3 3 4 2 10 8 Educate PAPs to unethical untrained poles in land (especially on the RAP workers workers owned or women, and GRM. (Discriminating used by children, Educate vulnerable villagers disabled) workers on PAPs, Physical Workers, 2 3 4 2 9 7 involuntary insensitivity to surveying of villagers resettlement local norms, proposed and loss of alcohol/drug sites livelihoods abuse impacts) safeguards; Induction and monitoring of workers; include prohibition of substance abuse during work in the work rules; Replace workers with known record of discrimination; train workers on inclusiveness. 13 Wildlife Wildlife (e.g. Physical Workers 5 5 2 1 12 11 First aid kits attacks snakes, bees, survey of made (reptiles, dogs etc.) proposed available; project sites discuss with

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance insects, and the animals etc.) community about wildlife risks; include awareness on response and recovery Clearing for Workers 5 5 3 1 13 12 First aid kits access and made sites of available; poles discuss with the community about wildlife risks; include awareness on response and recovery Felling and Workers 5 5 4 1 14 13 First aid kits trimming of made trees within available; ROW discuss with the community about wildlife risks; include awareness on response and recovery

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance Clearing for Workers 5 5 3 1 13 12 First aid kits quarrying made available; discuss with the community about wildlife risks; include awareness on response and recovery 14 Risks of work Uneven Clearing for Workers 4 3 3 2 10 8 Use protective site conditions terrain, loose access and gear such as soil, wetland, sites of hard boots; remote and poles work during densely low tides in vegetated wetlands; areas etc. supervisors to assess site conditions and educate workers prior to work activities Clearing for Workers 3 3 5 2 11 9 Use protective quarrying gear such as hard boots; work during low tides in wetlands; supervisors to

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance assess site conditions and educate workers prior to work activities Felling and Workers 2 3 3 2 8 6 Use protective trimming of gear such as trees within hard boots; ROW work during low tides in wetlands; supervisors to assess site conditions and educate workers prior to work activities Excavation Workers 3 3 3 2 9 7 Use protective during gear such as quarrying hard boots; work during low tides in wetlands; supervisors to assess site conditions and educate workers prior to work

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Risk Hazard Source of Who is at Exposure Severity Probability Control Actual Significance Level of Mitigation Risk Risk level Risk Significance activities; Avoid mining into caves

15 Work related Overexertion, Clearing for Workers 5 3 5 2 13 11 Control work stress hot work access and hours to environments, sites of include long work poles enough rest hours, time; do not untrained for work at night; the task provide adequate training and employ qualified workers; Excavation Workers 4 3 5 2 12 10 Control work during hours to quarrying include enough rest time; do not work at night; provide adequate training and employ qualified workers;

Source: S D Focus Ltd (2020)

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Risk significance Key: 0 means no significance of risk 1 - 5 means low significance of risk 6 - 9 means medium significance of risk 10 - 15 means high level of concern

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8.3 Mitigation of Risks The identified risks that have been analyzed will be treated accordingly by implementing proposed mitigation measures, giving more attention to risks of medium to high significance. Mitigation measures range from training, change in design, alternative equipment, warning, and prohibition signage etc.

8.4 Training The contractor will develop an Internal Operation Plan to guide all workers, and will include works inspection and supervision, instructions and standard operating procedures for special activities such as working at heights, maneuvering of vehicles carrying long materials (poles), storage of equipment and machinery outside established camps and the use of individual and collective protective equipment. Training will also be a continuous process to ensure awareness and improve skills including:

• Training of new staff on-the-job and on occupational health and safety including: - knowledge of materials and equipment; - hazards and risks with coressponding managemnt options; - risk exposure prevention; - hygiene requiments; - use of PPE; - expected response ; - incident reporting procedures.

• Periodic refresher training of existing workers as people tend to short-cut procedures with experience over time.

• Visitor orientation and restrcitions to work sites and camps

8.5 Emergency Response in Case of Incidents

Despite the risk assessment and implementation of mitigation measures, accidents may occur due to human error or machine failure etc. Therefore, the Contractor shall develop a contingency plan to guide emergency response in case of accidents. It should be relevant and realistic with regards to the activities, human capacity, and resource requirements.

The response plan will include actions to be taken when an incident (the risks with medium to high significance) occurs, and may include: • response actions for various accidents; • alerting workers, community members and visitors of the emergency situation; • identify roles and responsibilities, including coordination; • identify the relevant partners; • accounting for people; • evacuation to a safe location or for treatment; • procedures for notifying management, relatives, and the authorities.

Workers must however be trained on this plan and drills carried out to test it.

All accident sites must be cordoned-off to prevent bystanders and other workers from accessing the site. This will reduce impacts of potential secondary incidents such as unstable objects from an

145 accident falling on people, and electrocution of rescuers getting into contact with electrocuted victims. Moreover, restricting access will allow the rescuers to freely carry out activities without hindrance.

During and after all incidents, provision of facts is very important to prevent the spread of rumors. In some instances, requesting for expert support (firefighters, police officers, health personnel etc.) in a timely manner is necessary in efficiently responding to accidents.

8.6 Health and Safety Reporting and Recording The contractor should develop standard recording and reporting formats to ensure consistency and ease of comparison. These will ensure workers have means of immediately reporting to the supervisors, situations believed to have imminent risk of causing accidents and incidents that have already occurred. All work-related injuries, near misses, and suspected cases of diseases, particularly contagious diseases, should also be reported and investigated to ascertain what happened, the specific causes and means of preventing recurrences.

All the procedures and plans, reports, training programs and monitoring reports should be recorded and stored for evaluation and litigation purposes.

8.7 Health and Safety Monitoring OHS monitoing programs should be routinely carried during all phases of the Project to evaluate the effectiveness of the accident mitigation measures or response procedures. Monitoring will include: - safety inspection and testing of work equipment and processes - surveillance of the work environment - surveillance of the workers health and wellbeing - evaluation of trainings carried out includeing drills to out the knowledge to test.

Since the aim of this Chapter is to ensure that no one is injured or hurt by a hazard, following the above prescribed process should minimize the expected risks assocaited with health and safety hazards in the implementation of the Project. It furhter identifies action to take in case of incidents beyond the control of the parties.

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CHAPTER 9: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

This Chapter presents the ESMP, and sets out the action plan (both social and environemtnal) of the measures to be implemented to acchieve the avoidance, prevention, minimization, including compensation, of adverse imapcts. It is also to ensure compliance with the Bank’s OP 4.01.

9.1 Objectives of The ESMP

The Objectives of this ESMP are to:

• ensure environmental sustainability of the ECOWAS REAP in The Gambia; • provide a project specific environmental management guide to support the PIU during implementation; • identify responsibilities for the various environmental management actions; • provide an estimated budget for mitigation measures to ensure environmental issues and financial requirements are incorporated at the planning stage; • provide direction and guidance to the contractors whose focus is usually getting technical works done; • ensure the project is implemented according to environmental laws of The Gambia and policies of the WB.

9.2 ESMP Implementation and Monitoring Arrangements

9.2.1 Roles and Responsibilities for ESMP Implementation Implementation of this ESMP is the responsibility of the Contractor and PIU. Most of the mitigation measures are the responsibility of the Contractor who will be carrying out the works according to the C-ESMP that will be based on the Project ESIA/ESMP.

The supervising firm, Owner Engineer, will support the PIU in field supervision of all the contractors and their works. The Owner Engineer will also assist the PIU in the bidding processes and verifies that contractors abide by clauses in the contracts.

Communities will also have the responsibility of ensuring that villagers avoid work sites and report to NAWEC or relevant authorities, issues of concern related to the Project; the PIU and Contractor will engage the community regularly as an oversight measure in this regard, and conduct sensitization sessions to ensure communities are aware of reporting measures and understand Project risks.

As the Secretariat of the EIA Working Group8, and supported by its members, NEA will be responsible for the overall external monitoring of the ESMP implementation; in collaboration with the PIU ESS and

8 The EIA Working Group is one of nine multisector technical groups located at NEA. Nationally, NEA is the custodian of the ESIA process, and is supported by a multisector EIA Working Group which comprises the public sector, private sector and civil society, and at the Regional level, it is represented by the EIA/ANR (Agriculture and Natural Resources) Working Group sub committees of the Technical Advisory Committees (TAC). A major responsibility of the EIA Working Group (whether at central or regional level), is to provide support to the NEA in assuring the quality and integrity of the EIA process. Specifically, it:

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SSS, they will monitor compliance with the Bank policies as they relate to the environmental aspects of this Project. In addition to the permanent members in the EIA Working Group, other institutions on ad hoc basis will include those specialized in social aspects such as the Women’s Bureau, Department of Social Welfare, Department of Labor, and Department of Health Services, amongst others.

Meanwhile, monitoring of the implementation of the social aspects of the Project in line with the Bank’s safeguards instruments will be the responsibility of the PIU SSS.

The NEA will also provide technical support and participate in training and sensitization of stakeholders to enhance the understanding of the national and the Bank’s environmental safeguards instruments. Technical advice and/or regulatory information and support will be provided by the DOF for all forest related issues, the Department of Physical Planning and Housing (DPPH) and the Department of Lands and Surveys (DLS) will be responsible for addressing resettlement issues.

The Local Authorities and beneficiary community members will be relevant during the preparatory stage of the works, as they can provide valuable information to assist in the planning of the works.

The breakdown of the institutional arrangement for the ESMP implementation is as follows: a) ECOWAS REAP Project Steering Committee in The Gambia (PSC) The ECOWAS-REAP Project Steering Committee (PSC), chaired by the Permanent Secretary, Ministry of Petroleum and Energy, will oversee all the activities of the Project, including the implementation of the ESMP, and any other relevant safeguards document. The Permanent Secretary, MOLRG will be on the PSC due to the importance of the potential resettlement issues, and social risks relating to possible felling or pruning of private economic trees along the line corridors.

The PSC’s roles and responsibilities include: • oversee and monitor overall implementation of the ECOWAS-REAP safeguards documents including the ESMP, and RAP; • review and address all issues relating to resettlements and disputes; • review and monitor the progress reports; • visit the Project sites to ensure progress of work and other activities. b) ECOWAS-REAP Implementation Unit (PIU)

The PIU will consist of the following, among others: - Project Coordinator; - Environmental Safeguards Specialist (ESS); - Social Safeguards Specialist (SSS); - Power Engineer (PE); - Procurement Specialist; - Monitoring and Evaluation Specialist (M&ES).

The PIU will oversee the implementation of this Project, including the ESMP. Its other responsibilities will include:

• Provides expert advice on the EIA process and review impact statements and ESMPs upon receiving requests • Approves impact statements and ESMPs • Conducts periodical environmental audits • Ensures that public consultations as part of the EIA process are done

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- ensuring alignment of the environmental and social safeguards standards applied to the Project; - working with the technical and procurement teams to ensure that contract documents contain Environmental and social safeguard clauses that Contractors must fully implement; - coordinating internal monitoring and evaluation of the ESMP based on monitoring plans - coordinating Project related grievance redress activities; - where applicable, facilitating Project related activities of partner stakeholders.

National Environment Agency The NEA will be responsible for overall monitoring of the implementation of the ESMP, particularly the environmental component. According to Section 31 of the EIA Regulations 2014, NEA will monitor routinely to guide and audit the progress of the ESMP implementation to ensure compliance with both national laws and the policies of the Bank; NEA’s mandate is to monitor the national environment, and so in collaboration with the PIU safeguards specialists, can also monitor compliance with the Bank’s policies as they relate to this Project. The monitoring visits should be at least once quarterly, to provide technical advice and support in project implementation. d) Ministry of Lands and Regional Governments In view of the high possibilities for the Project to trigger involuntary resettlement, the MOLRG will play a crucial role in the development and implementation of the RAP that may arise because of the Project. 9.2.2 Specific Roles and Responsibilities of Project Personnel

a) Project Coordinator (PC) The PC will oversee the implementation of the Project, and consequently the ESMP and will have the responsibility for ensuring that implementation of the ESMP is carried out as required under the national law and the World Bank’s Procedures.

b) Environmental Safeguards Specialist (ESS) The ESS is responsible for validating the ESIA and obtaining the environmental compliance certificate and publishing the ESIA. The ESS will make sure that all environmental measures outlined in the ESMP are integrated in the bidding documents and in the companies’ contracts. S/He will also assure the approving of the contractors’ site-ESMP.

The ESS will provide day-to-day management for all environmental issues and activities including implementation of the ESMP, in collaboration with NEA. He will prepare progress reports for submission to the PIU for transmission to the PSC, NAWEC, RCU (Regional Coordination Unit) and the World Bank. S/He will also directly oversee the implementation of the capacity building of stakeholders on environmental and social safeguards.

c) Social Safeguards Specialist (SSS) The ESS will make sure that all social measures outlined in the ESMP are integrated in the bidding documents and in the companies’ contracts. S/He will also make sure that all social measures outlined in the ESMP are integrated in the bidding documents and in the companies’ contract. S/He will provide day-to-day management for all social issues as they relate to implementation of any resettlement issues; prepare periodic reports on progress on social issues; prepare progress reports on the level of potential PAPs, and their participation in project activities on the issues of resettlement.

These reports will be submitted to the PIU for transmission to the PSC, NAWEC, RCU (Regional Coordination Unit) and the World Bank. The SSS will directly oversee the implementation of the capacity building of stakeholders on the GRM and the Code of Conduct for addressing GBV, SEA and

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VAC.

d) Power Engineer (PE) The PE will integrate the construction phase mitigation measures and environmental and social clauses into the bidding documents; ensure that the Contactors obtain all the necessary approvals and integrate the relevant measures in the works breakdown structure or execution plan.

In collaboration with the ESS, SSS and other relevant members of the PIU (including the Procurement Specialist and Financial Management Specialist) the PE will ensure that contract documents contain environmental and social safeguard clauses spelling out the expectations of Contractors with regards to their mitigation responsibilities; Contractors must fully implement these clauses.

e) Monitoring and Evaluation Specialist (M&ES) Monitoring and evaluation activities are fundamental components of the ESMP to be carried out throughout the Project cycle. Monitoring of the ESMP implementation is normally the responsibility of the PIU whereas evaluation is undertaken by an external entity. The M&E Specialist will coordinate internal monitoring and evaluation of ESMP implementation based on the monitoring plan. Table 9.1 summarizes the above write-up on the roles and responsibilities for the implementation of this ESMP.

Table 9.1: Summary of Roles and Responsibilities in ESMP Implementation No. Steps/Activities Responsible Collaborating Service Provider Partners Preparation of the works Contract documents, ESIA/RAP etc. in accordance with the national legislation/procedure (taking into account the World Bank’s policy requirements) 1 Preparation and approval of ESS/SSS; PC; PE NEA PIU the ToRs/Contracts Report validation and ESS/SSS; PC; PE ESS/SSS; NEA Consultant; World issuance of the permit (when Bank required) Disclosure of the document ESS/SSS NEA; NAWEC NAWEC and the Management PIU; PC also disclosed on the World Bank’s external website (i) Integrating the mitigation PE ESS/SSS; Contractor; NEA 2. measures of the construction NAWEC; PSC; phase and E&S clauses in the Engineer; bidding document prior to Contractor being advertised (see Appendix 8.1)

(ii) ensuring that the contractor integrates relevant ESMP measures in the works breakdown structure or execution plan / C-ESMP

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Implementation of the other ESS/SSS PE; M&ES; NEA Consultants; 3. safeguards’ measures, and EIA Working Other relevant including environmental Group; PSC; public institutions monitoring (when relevant) General public and sensitization activities Oversight of safeguards ESS/SSS/PC M&ES; PSC; NAWEC MD and implementation (internal) Management 4. Reporting on project PC M&ES; ESS, SSS; NAWEC MD and safeguards performance and PSC Management disclosure External oversight of the EIA Working PC; M&ES; ESS- NAWEC MD and project safeguards Group/NEA ECOWAS REAP; Management compliance and performance SSS; PSC 5. Building stakeholders’ ESS PC; SSS; NEA Consultant capacity in safeguards Other qualified management public institutions

9.2.2 Institutional Training and Sensitization During the consultations, it became evident that there is need for the members of the Regional Technical Advisory Committees (TACs) and other institutions of the affected Regions to be trained in the general area of environmental and social administration, ESIA, GRM and ESMP management. They will also be trained on preventing and managing related GBV, SEA and VAC. Thus, it will be necessary to strengthen the capacity of members of the TACs, some NAWEC staff (including the ESS, SSS, etc.) on the safeguards, procedures, and resettlement programs. This will require organizing training workshops. Capacity building of NAWEC and other collaborating institutions is estimated at US$ 30,000 (see Table 9.2) to be started before the works begin.

In addition, public sensitization on the Project will be carried out to prevent complaints and conflicts, and to highlight community roles in promoting issues related to public health and safety at an estimated budget of $US 2,000 NBR and LRR each, and US$ 4,000 for CRR-N and S (Total, $US 8,000).

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Table 9.2: Capacity Enhancement Program for Effective ESMP Implementation

Identified Expected Output Target Implementer Budget Activity Beneficiary (US $) Institutional Capacity – Technical skills development and awareness creation 1 Workshops - Project components NEA and NEA and 5,000 x 4 = 20,000 and meetings and related activities TACs of LRR, consultant to strengthen known. NBR, CRR Gender ($5,000 for training of NEA including the the human - Capacity enhanced Specialist EIA Working Group) resource in EIA Procedures. capacity of the - ESMP requirements ($5,000 for each of the 3 TAC training Regional TACs understood. workshop) and other - Roles and institutions in responsibilities of managing ESIA TAC members with regards to the ESMP understood. - Plan for enforcement of the ESMP developed. - Skills of the TAC members in GBV, SEA and VAC prevention and handling developed. 2 Capacity - Environmental and NAWEC NEA and PIU 10,000 building of social safeguard Senior ($2,000 for Management Training) relevant issues understood. Management Team and NAWEC staff - Roles and ($8,000 for the 2 Training of Technical technical responsibilities of officers (such Officers NAWEC staff as planning, towards T&D and implementing the generation). ESMP understood. Public Sensitization - Education, communication, and information provision 3 Public - Increased awareness General NAWEC, 2,000 x 4 = 8,000 sensitization on the Project public, NEA, on the Project information. specifically consultant ($2,000 for the National awareness (such as - Increased communities Gender program) project risks, community where the Specialist ($2,000 for each of the 3 Regional benefits, participation on Project will programs) progress, GBV, environmental and be SEA, VAC and social affairs related implemented GRM etc.) to the Project. through

152 radio/TV programs and meetings as appropriate. TOTAL 38,000

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9.2.3 Monitoring Once the Project commences, including implementation of accompanying mitigation measures, monitoring must be carried out by the different stakeholders to ensure effectiveness in maintaining environmental and social sustainability. Monitoring will act as an oversight mechanism to remind and push the one responsible for mitigation that they are under guard and enforcement action may be executed upon them for any breaches.

Issues to be monitored (as listed in Table 9.3) include activities that have been identified earlier to have potential significant negative impacts on the environment and socio-economic parameters, and their corresponding mitigation actions. Routine monitoring may also identify new issues that have arisen due to changes (at the sites, or in Project design or activities) that will need alternative mitigation measures. Thus, appropriate mitigation will be developed accordingly.

Internal monitoring will be the responsibility of the Environmental Safeguards Specialist and Social Safeguards Specialist within the PIU, in addition to ensuring compliance with the World Bank’s social and environmental policies.

The recommended arrangements and roles for implementing the ESMP will also be evaluated for completeness, and improvements suggested where necessary.

The NEA and other relevant institutions identified in the ESMP will monitor for compliance with requirements under Gambian law. Selected relevant TAC members (including the representatives of NEA and NAWEC who will provide leadership and technical support respectively) will conduct monitoring visits to the Project sites. TAC members whose sectoral expertise will not be useful, nor add value to the process, will not be included in the TAC monitoring team. This arrangement will ease coordination and lower expense on resources. Furthermore, it will be more cost-effective and focused to use the regional TACs than displace members of the national EIA Working Group (in the Greater Banjul Area) to monitor Project activities in the respective Regions where the Project will be implemented. The regional TACs are also supposed to be more familiar with the local terrain and communities.

NEA’s representative in the TACs will forward the monitoring reports to the NEA Headquarters for eventual transmission to the PIU. To support the TACs in monitoring, an estimated budget of US$ 20,000 is recommended for the entire implementation of the Project. Disbursements should be made when due to the Offices of the Governors with NEA at TAC providing oversight, coordinating the monitoring visits to the Project sites. A monitoring plan with frequency and indicators is further outlined in Table 9.3, and an estimate for the cost of mitigation has also been provided in Table 9.4.

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Table 9.3: ESMP Monitoring Program

Mitigation Responsibil Monitoring Time to monitor Monitoring Monitoring outputs to be ity Responsibility frequency indicators monitored for mitigation 1 Involuntary NAWEC ESS/SSS/NEA/M Before initial Monthly during No. of sensitization resettlement of OLRG works and any RAP sessions considering PAPs addressed development development land use and and ownership issues implementation RAP report developed RAP fully implemented Loss of land, NAWEC ESS/SSS/NEA/M Before initial Monthly during No. of consultative crops, economic OLRG works and any RAP sessions trees, assets, development development No. of related livelihood, and and complaints inheritance implementation RAP developed addressed RAP implemented No. of PAPs compensated as compared to the total no. of PAPs 2 Protection of Contractor NEA/DOF During and after Monthly during No. of forest tress forest trees and / works RAP felled effect on the NAWEC development No. of forest trees environment, and pruned landscape, implementation No. of wildlife drainage, and species impacted wildlife No. of sensitization meetings on forest and biodiversity No. of nesting grounds protected Tree replacement plan implemented No. of reports of illegal activities 3 Protection Community SSS with support Before and Quarterly No. of sensitization against Gender NAWEC from the during project meetings on GBV Based Violence Women’s Bureau implementation codes of conduct and Sexual and Department No. of women Exploitation and of Social Welfare participating in Abuse consultations % of women PAPs addressed No. of community sensitization meetings where GBV/SEA and

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Mitigation Responsibil Monitoring Time to monitor Monitoring Monitoring outputs to be ity Responsibility frequency indicators monitored for mitigation discrimination are discussed No. of meetings on GRM Reports on progress in enforcement of Codes of conduct to address GBV/ SEA etc. Number and type of complaints through the GRM including SEA/GBV Number and type of complaints relating to discrimination exclusions from benefits and inequality (for example based on vulnerability such as sex, age, etc.) Number of women hired in the Project Tenure security NAWEC / NEA/MOLRG Before works Monthly during No. of consultative for women community RAP sessions considering development women’s land tenure and No. of related implementation complaints No. of women receiving equitable benefits and access to land rights 4 Women and Contractor/ PIU SSS Before and Annually No. of women youth considered NAWEC during works participating in consultations No. of youth participating in consultations (male and female) No. of youth employed by the Project (male and female) 5 Protection from Contractor PIU SSS Before and Quarterly No. of reports of Violence Against / NAWEC during project child labor / abuse Children

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Mitigation Responsibil Monitoring Time to monitor Monitoring Monitoring outputs to be ity Responsibility frequency indicators monitored for mitigation No. of women participating in consultations % of children PAPs addressed No. of Community sensitization meetings where VAC issues are discussed No. of meetings on GRM Reports on progress in enforcement of Codes of conduct to address VAC. No. of reports of children involved in Project related accidents 6 Public and worker Contractor ESS/SSS/NEA During land Quarterly No. of accidents health and safety Beneficiaries preparation, related to the Project construction, activities and operation No. of health education / sensitization sessions No. of reports on works during nighttime No. of heavy vehicle/machinery left broken down No. of complaints /reports on lack of measures to address air polluting emissions No. of dust suppression equipment No. of protective gear provided to workers 7 Proper waste Contractor ESS/SSS/NEA During works Quarterly No. of waste dumps management and operation on and around sites No. of sensitization meetings on waste management

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Mitigation Responsibil Monitoring Time to monitor Monitoring Monitoring outputs to be ity Responsibility frequency indicators monitored for mitigation No. of contracts that included waste management clauses Waste management plans developed No. of reports/complaints on waste management issues 8 Employ local labor Contractor/ ESS/SSS/NEA/Lab Before works Annually No. of people NAWEC or Department and during employed from the works local communities No. of contracts that specify use of local labor 9 Consultation and Contractor/ NEA/ESS/SSS Before and Biannually No. of consultative participation of NAWEC during works meetings with beneficiaries beneficiaries No. of complaints on lack of consultation No. of minutes /reports of consultations No. of persons in attendance 1 Social cohesion NAWEC / NEA/PIU Before and Quarterly No. of locals 0 community during works employed No. of community conflicts 1 Prevention of Contractor NEA/GD/PIU Before and Quarterly Mine management 1 impacts from during works Plans developed quarrying on Reports on process of geology, mining landscape, No. of mining wildlife, approvals from GD agriculture etc. 1 Soil compaction Contractor ESS/SSS/ During works Quarterly No. existing new 2 from vehicles / NEA and operation routes established machinery Lengths of access controlled roads graded and improved

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9.2.4 Reporting As monitoring of the ESMP implementation falls under the general monitoring and evaluation system of the Project, its reporting should be synchronized. This will ensure efficient reporting and communication of the ESMP related issues to all relevant stakeholders for holistic management, particularly where changes for improvement are recommended.

It is recommended that the NEA submits annual reports to NAWEC (through the ECOWAS REAP PIU) on its monitoring of the ESMP implementation. NEA will work with its Regional Environment Officers to ensure issues reported by the TACs are incorporated and follow-up actions by the various affected institutions and stakeholders coordinated accordingly.

Where incidents or accidents occur that require immediate action, NEA shall report to NAWEC immediately, and NAWEC should in turn notify the World Bank as soon as possible.

The PIU, according to its work plan, shall submit all reports to the World Bank for consideration.

9.2.5 Environmental Auditing According to Part VI of the EIA Regulations, 2014, environmental audits should be carried out by the Project and the NEA. A systematic environmental audit shall evaluate predictions made during the ESIA study and assess the status of implementation of the proposed enhancement and mitigation measures. The audit may also identify potential impacts that have arisen due to any modification in planned design or activities or changes to environmental and social parameters.

The Project may carry out self-audit to include review of its activities, the Project ESMP implementation, monitoring reports and any subsequent improvement measure, capacity, and communication between the affected stakeholders amongst others.

Whilst the self-audit is a routine activity of the PIU, an independent environmental audit will be carried out midway during implementation of the ESMP and upon project completion, preferably by an external auditor to avoid conflict of interest.

Environmental Inspectors of the NEA are also empowered to carry out audits in their own time, with the aim of confirming that all mitigation measures are complied with, and any breach pursued for appropriate redress.

9.2.6 Budget for Implementation of the ESMP The proposed budget for implementation of the ESMP is US$ 87,000 as indicated in Table 9.4.

Table 9.4: Estimated Budget to Implement the ESMP

No. Activity Time Frame Budget Responsibility to (US$) coordinate 1 Capacity Building Workshops and meetings to First quarter of the 20,000 NEA/PIU/ESS/SSS strengthen the capacity of the Project Regional TACs in managing ESIA implementation and RAP Capacity building of relevant Annually during 10,000 NAWEC NAWEC staff on environmental project Management / PIU and social safeguards and their implementation roles

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Public sensitization to raise First and second 8,000 NEA/PIU/ESS/SSS awareness on the Project issues quarter of the through relevant radio / TV project programs and meetings implementation

2 ESMP Implementation, Monitoring, Evaluation and Reporting Implementation of the mitigation Annually during all 10,000 PIU measures phases (construction, operations, and maintenance) Regular environmental and social Project 20,000 NEA/PIU monitoring of the implementation implementation of mitigation period measures and the activities. Audit of environmental and social During and after 10,000 PIU/NEA/Consultant measures construction

3 Operation of the GRM Field investigations Project 10,000 GRC implementation period Implementation of GRM related Annually during all 9,000 NEA/PIU to activities and mitigation phases (pa) measures (construction, operations, and maintenance TOTAL 87,000

9.3 Matrix on the Mitigation of the Identified Potential Negative Impacts Table 9.5 illustrates the proposed mitigation measures for the potential impacts identified during all Project activities; specific mitigation measures have also been highlighted for the various activities (pole construction and stringing, operation of the transmission and distribution lines, and any quarries).

Responsibilities for specific mitigation measures, period of expected mitigation, and responsibility for monitoring have been identified.

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Table 9.5: Potential Impacts and Corresponding Mitigation Measures

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility

CONSTRUCTION WORKS (LAND PREPARATION, EXCAVATION FOR POLE CONSTRUCTION AND STRINGING OF LINES) Land acquisition Involuntary resettlement of Prepare and implement a RAP to NAWEC/PIU Before works Regional TACs with In RAP budget for pole PAPs; loss of crops and evaluate all potential losses NEA to coordinate, location earnings; loss of livelihoods MOLRG Works within Loumo (weekly market day) Contractor During works Regional TACs - sites must not be carried during such days Gender-based Violence; Conduct community sensitization NAWEC/PIU Before works Regional TACs where Under total Sexual Exploitation and meetings on the need for everybody to NAWEC is co-opted as capacity building Abuse; Violence Against benefit from project activities Project Affected a member budget ($US Children; discrimination of irrespective of gender (inclusive access to Community 38,000) women in employment benefits); Leaders opportunities; in tenure and disproportionate 50/50 sharing of project and compensation resettlement benefits between men and women Ensure awareness of the GRM NAWEC/PIU Before and during PIU Social Safeguards - operation Specialist Monitor risks for escalating tensions Affected All phases PIU Social Safeguards - communities Specialist Encourage women and other vulnerable NAWEC/PIU All phases PIU Social Safeguards - groups to raise their concerns safely and Specialist

9 (No value = included in PIU’s safeguards activities) Mitigation measures that are to be done by the PIU have no budget attached as costs are included in the PIU’s safeguards activities; other measures without values have no mitigation costs such as community leaders encouraging women to participate in decision making, and reporting of illegal activities such as illegal felling of forest trees

161

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility anonymously, if they so choose, on the Project Affected resettlement process and other issues Communities Encourage women to enlist for Contractor All phases NAWEC/PIU Contractor’s employment in project activities without Social Safeguards budget any impediments put in their way; Specialist

Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women;

Enforce and monitor Codes of Conduct for workers and all those involved in the project

Sensitize about the Codes of Conduct for workers and community;

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

162

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Felling and Compensation of PAPs; loss Prepare and implement a RAP to consider NAWEC/PIU Before Regional TACs (to be For RAP budget trimming of of livelihoods and access to any loss of farmland, fruit and timber construction coordinated by the economic trees resources trees, livelihood sources, property, and works start NEA) usufructs etc. Trimming of fruit trees should be carried Contractors During works PIU Social and - out only when tree branches are on the Environmental ROW of lines Safeguards Specialists Gender-based Violence; Conduct community sensitization NAWEC/PIU Before works Regional TACs where Capacity building Sexual Exploitation and meetings on the need for everybody to NAWEC is co-opted as budget Abuse; Violence Against benefit from project activities Project Affected a member Children; discrimination of irrespective of gender (inclusive access to Community women in employment benefits); Leaders opportunities; in tenure and disproportionate 50/50 sharing of project and compensation resettlement benefits between men and women Ensure awareness of the GRM NAWEC/PIU Before and during PIU Social Safeguards - operation Specialist

Monitor risks for escalating tensions Affected All phases PIU Social Safeguards - communities Specialist

Encourage women and other vulnerable NAWEC/PIU All phases PIU Social Safeguards - groups to raise their concerns safely and Specialist anonymously, if they so choose, on the Project Affected resettlement process and other issues Communities Encourage women to enlist for Contractor All phases NAWEC/PIU Contractor’s employment in project activities without Social Safeguards budget any impediments put in their way; Specialist

163

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women;

Enforce and monitor Codes of Conduct for workers and all those involved in the project

Sensitize about the Codes of Conduct for workers and community;

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

Conduct periodic training of employees on the codes of conduct and related procedures Include the above measures in bidding NAWEC/PIU Before works PIU Social Safeguards - documents including, codes of conduct Specialist for GBV, SEA and VAC, for contractors to enforce on their employees Land clearance Loss of vegetation along line Remove vegetation around pole site only Contractor Before and during Regional TACs (NAWEC - and preparation corridor as necessary works co-opted as member) Cover area around the pole foundations Contractor During and after NAWEC/PIU Contractor’s to facilitate revegetation works budget Loss of livelihoods (e.g. Prepare and implement RAP NAWEC/PIU Before beginning TAC (to be coordinated For RAP budget rangeland, firewood, other of works by the NEA) usufructs etc.)

164

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Destruction of forest trees Compensatory reforestation will be NAWEC/PIU Before beginning DOF For RAP budget and effect on the developped and implanted in of works environment, landscape, collaboration with the Forestry drainage, and wildlife Department Ensure that only the right of way is Contractor Before and during NAWEC/PIU/ and TAC - cleared; avoid forests works with DOF leading the Seek approval from DOF before forest process trees are felled Keep records (types and quantities) of all ‘forest trees’ to be fell Educate and warn workers to avoid burning activities Hunting by imported workforce will be Contractor Before, during and NAWEC/PIU/TAC - prohibited; after works

All employees, including volunteers and sub-contractors encouraged to anonymously report suspected or actual acts of hunting/killing of wild animal by a fellow worker

Disciplinary measures must be applied Contractor During works NAWEC/PIU/TAC Contractor’s budget The endangered and threatened and Contractor/ Before and during DPWM/NEA/PIU Contractor’s endangered species must be protected DPWM works Environmental budget by: Safeguards Specialist

Enforcing more vigorously the relevant laws and regulations that prohibit its killing

165

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Conducting training and information meetings on its preservation and protection at community level at least once every quarter

Creating community wildlife reserves where threatened species such as the baboon could be protected Avifauna nesting grounds and migratory Contractor Before and during DPWM / PIU - paths are to be protected works Environmental Safeguards Specialist Soil compaction from Use only approved and existing routes Contractor During works Regional TACs / - vehicles / machinery Communities destroying farmland and Do not establish new routes Contractor During works Regional TACs / - causing erosion Communities Grade existing routes to improve surface Contractor During works Regional TACs / Contractor’s drainage Communities budget Destruction and loss of Inform relevant parties of the Chance NAWEC PIU/ Before and during NCAC, PIU Social - cultural, historical, or Find Procedures and apply where Contractor works Safeguards Specialist archaeological sites applicable Avoid mosques, cemeteries, World Contractor Before and during NCAC/ - Heritage Sites, and similar sites of works Regional TACs / cultural significance Communities Consult with community to help identify Contractor Before and during NCAC/ - any other cultural or spiritual sites of works Regional TACs / importance Communities All Construction Nuisance from noise, Integrate ESMP into Contract Bidding NAWEC PIU In contract before PIU Social Safeguards - Activities vibration, and air pollution Documents and ensure compliance by works, and during Specialist / from dust or hydrocarbon Contractor Contractor works Regional TACs / non-combustion emissions Communities

166

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility (During all land Works shall only be carried out during Contractor During works Regional TACs / - preparation and daytime Communities construction Use dust suppression measures such as Contractor During works Regional TACs - activities dampening including Provide masks and necessary protective Contractor During works Regional TACs Contractors’ establishment gear to workers with the aim of budget of base camps) preventing dust related health problems and other dust nuisances Use well-serviced equipment and Contractor During works Regional TACs Contractor’s machinery; avoid overloading that strains budget the engines Trucks transporting sand and gravel must Contractor During works Regional TACs Contractor’s be covered to prevent dust and flying budget debris Ensure that engines of vehicles and Contractor During works Regional TACs Contractor’s machinery are not idle for prolonged budget periods unnecessarily Special care will be taken when working Contractor During works Regional TACs / PIU Contractor’s near educational institutions and health Social Safeguards budget facilities such as: Specialist

Giving prior notice to the institution about the works

Cordoning off work sites to prevent access

Working during weekends when activities are less around these institutions

167

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Reduction in water quality Protect water sources and report any Contractor / During works Regional TACs / - of tributaries along the noticeable reduction in quality Communities Department of Water corridors due to Resources construction activities Effects of improper Develop a waste management plan Contractor Develop plan NEA / PIU management of wastes including types of waste, expected before works, and Environmental (solid and liquid/used oils, quantities and frequency, proposed implement during Safeguards Specialist machine parts, and storage and disposal procedures and works domestic and sanitary responsibilities, etc. waste, excess materials left Do not burn any type of waste Contractor All phases Regional TACs / - on sites, cement bags, etc.) Communities on land, water, fauna, and Set an internal supervision and Contractor Before, and NEA / PIU Contractor’s public health monitoring system to ensure waste implement during Environmental budget reduction and management works Safeguards Specialist Waste must be collected and stored for Contractor During works NEA / PIU - disposal or treatment at approved sites Environmental as per waste management plan Safeguards Specialist Clean waste such as cleared vegetation, Contractor During works NEA / PIU - packaging and rubble shall be given to Environmental workers or communities for reuse and Safeguards Specialist recycling Ensure waste management issues are NAWEC PIU Before works PIU Environmental - incorporated in Agreements with the Safeguards Specialist Contractors Unpleasing landscape and Remove excess and unused materials and Contractor During works NEA / PIU - impact on aesthetics equipment from work sites Environmental Safeguards Specialist Replace lost vegetation cover NAWEC PIU During and after Regional TACs For RAP budget works Risks to public health and Restrict and monitor public access to the Contractor/ During the works NAWEC PIU - safety during construction work sites communities

168

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility (at pole sites, quarries, camp Integrate staff training especially drivers Contractor Before and during NAWEC PIU - sites, within beneficiary on defensive driving works communities etc.), from Construction works within the Loumo Contractor During works NAWEC PIU / Regional - imported diseases, VAC, area on a market day must be avoided TACs including NEA SEA, GBV, and work site Cover up the trucks, to prevent wind Contractors In contract before Regional TACs Contractor’s hazards etc. blowing away sand and gravel to works and during budget generate dust works Initiate sensitization and education NAWEC PIU In contract before PIU Social Safeguards For capacity programs for communities and workers works and during Specialist building budget on the dangers and mitigation measures works to address STIs; Contractor Encourage use of condoms to prevent STIs Carry out active monitoring of workers Contractor Before and during Regional TACs with Contractor’s (screening, testing, and analysis of such works Department of Health budget recorded data, etc.) to take timely action Services leading through treatment and health education to prevent spread of diseases Ensure surroundings are safe and secure Contractor Before and during Regional TACs with Contractor’s for all (implement health and safety plan, works Department of Health budget coordinate, inform, supervise and Services leading monitor) Employ local unskilled workers to Contractor Before and during NAWEC PIU - enhance community cohesion as local works workers will know the community better, its culture, norms, and values, which may also help in reducing the risks of GBV, VAC and STIs.

169

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Risk of violence against Ensure enforcement and adherence to Contractor Before and during Regional TACs, Contractor’s children and women Codes of Conduct for addressing VAC, works Communities / budget GBV, and SEA, including regular Department of Labor monitoring and awareness building of the Codes of Conduct Do not employ or exploit children for Contractor Before and during Regional TACs, - project works works Communities / Department of Labor Conduct community sensitization NAWEC/PIU Before works Regional TACs where Capacity building meetings on the need for everybody to NAWEC is co-opted as budget benefit from project activities Project Affected a member irrespective of gender (inclusive access to Community benefits) Leaders Ensure awareness of the GRM NAWEC/PIU Before and during PIU Social Safeguards - operation Specialist Monitor risks for escalating tensions Affected All phases PIU Social Safeguards - communities Specialist Encourage women and other vulnerable NAWEC/PIU All phases PIU Social Safeguards - groups to raise their concerns safely and Specialist anonymously, if they so choose, on the Project Affected resettlement process and other issues Communities Encourage women to enlist for Contractor All phases NAWEC/PIU Contractor’s employment in project activities without Social Safeguards budget any impediments put in their way; Specialist

Contractor to develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women;

170

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Enforce and monitor Codes of Conduct for workers and all those involved in the project

Sensitize about the Codes of Conduct for workers and community;

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

Conduct periodic training of employees on the codes of conduct and related procedures Include the above measures in bidding NAWEC/PIU Before works PIU Social Safeguards - documents including, codes of conduct Specialist for GBV, SEA and VAC, for contractors to enforce on their employees Risks to health and safety of Make the hiring medical examination for Contractor Before and during NAWEC PIU Contractor’s workers (work related all workers works budget stress, heat stress, Provide induction and training on the job, electrocution, falls, safety issues and other relevant ESMP mechanical accidents, requirements human conflict, wildlife Sensitize on interpersonal relationship Contractor Before and during NAWEC PIU Contractor’s attacks, poor handling management between and among works budget techniques, diseases etc.). workers and community members; set codes of conduct Provide appropriate protective gear Contractor Before and during PIU Social Safeguards Contractor’s (helmets, masks, safety goggles, hand works Specialist / Regional budget gloves and rubber boots, etc.) to workers TACs

171

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Provide fire extinguishers and first aid Contractor Before and during PIU Environmental and Contractor’s kits including training on their use works Social Safeguards budget Specialists / Regional TACs Provide constant supervision and record Contractor During works PIU Environmental and Contractor’s and report incidents to address causes Social Safeguards budget for preventing recurrence and promoting Specialists / Regional improvement TACs

QUARRY SITES Quarrying earth Quarrying impacts on Where sand and gravel dealers are used, Contractor Before works NEA/Geology - materials geology, landscape, ground ensure only suppliers certified by the NEA Department (gravel / sand) water, wildlife, and and GD are used for construction agriculture, etc. Ensure approval is obtained from the Contractor Before works NEA/Geology - works NEA and GD for any proposed quarry site Department

Fully implement the mine management Contractor During mining NEA/Geology - plans Department All quarry pits created by the project Contractor After mining is NEA/Geology Contactor’s’ must be rehabilitated after construction completed budget works Ensure the above measures are included NAWEC/PIU Before works PIU ESS - in bidding documents for contractors Indirect water Avoid extraction to the water table and Contractor During operation NEA/Geology - contamination by exposure near surface water bodies of quarries Department of groundwater from over extraction

OPERATION OF THE TRANSMISSION AND DISTRIBUTION NETWORKS (INCLUDING MAINTENANCE) Effects from improper waste Develop a waste management plan NAWEC as the Develop plan NEA / NAWEC To be funded by management of items such including types of waste, expected operator of the before, and NAWEC as part of

172

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility All activities as trimmed vegetation, quantities and frequency, proposed T & D networks implement during its operational during broken cables, broken poles, storage and disposal procedures and will be operation mandate operation of the old and worn out parts such responsibilities etc. responsible for T & D networks as bolts and knots Waste must be collected and stored for all mitigation During operation NEA / NAWEC disposal or treatment at approved sites during (including as per waste management plan operation; routine clearing Do not burn any type of waste where During operation NEA / Communities of ROW, Clean waste such as cleared vegetation contractors are During operation NAWEC’s ESS and SSS connection to and packaging shall be given to workers used for specific users, repair, or communities for reuse and recycling activities rather maintenance Set an internal supervision and than NAWEC During operation NAWEC’s ESS and monitoring system to ensure waste staff, all replacement of reduction and management including mitigation T & D training of relevant NAWEC staff measures infrastructure Ensure waste management issues are corresponding Before specific NAWEC’s ESS - parts) incorporated in Agreements with the to the activities works Contractors carrying out maintenance should be works such as tree pruning and electricity included in connection to users contracts Risk of violence against Ensure enforcement and adherence to Before and during NAWEC’s ESS and- SSS children and women Codes of Conduct for addressing VAC, works GBV, and SEA, including regular monitoring and awareness building of the Codes of Conduct Do not employ or exploit children for Before and during - project works works Ensure awareness of the GRM Before and during - operation Monitor risks for escalating tensions All phases - Encourage women and other vulnerable All phases - groups to raise their concerns safely and

173

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility anonymously, if they so choose, on the resettlement process and other issues Encourage women to enlist for All phases - employment in project activities without any impediments put in their way;

Enforce and monitor Codes of Conduct for workers and all those involved in the project

Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct)

Conduct periodic training of employees on the codes of conduct and related procedures Risks to health and safety of Provide induction and training on the job, Before and during NAWEC ESS and SSS - workers, operators etc.) safety issues and other relevant ESMP works requirements (E.g. fires, electrocution, Provide appropriate protective gear Before and during NAWEC ESS and SSS - explosions, pest and wildlife (helmets, masks, safety goggles, hand works attacks in remote areas, falls gloves and rubber boots, etc.) to workers etc.) Sensitize on interpersonal relationship Before and during NAWEC ESS and SSS - management between and among works workers and community members; set codes of conduct Provide first aid kits including training on Before and during NAWEC Environmental - their use works and Social Safeguards Specialists

174

Activity / Issue Potential Negative Impacts Proposed Mitigation Measures Mitigation Mitigation Period Monitoring Budget ($US)9 Responsibility / Timeline Responsibility Provide supervision; record and report During works NAWEC ESS and SSS - incidents to address causes for preventing recurrence and promoting improvement DECOMMISSIONING Closure of Sites open to illegal Proper closure and timely restoration Contractors After mining and NAWEC PIU / NEA / - quarries exploitation after the and rehabilitation of borrow pits before Project Geology Department Project ends Monitor sites and report illegal activities Communities After restoration NEA/Geology - Department Dismantling and During decommissioning, all As per the construction phase for Contractors During TAC/NAWEC Contractor’s transportation potential impacts on public mitigation of public and worker health decommissioning budget of materials and and occupational health and safety; equipment likely during construction, All mitigation measures are also from the are also significant applicable during decommissioning camp(s)

Poor aesthetic quality from Implement measures prescribed in the Contractors During Regional TACs / PIU ESS Contractor’s excess materials and waste Waste Management Plan for decommissioning budget abandoned on camp sites decommissioning activities Ensure waste management issues are NAWEC Before works NAWEC’s ESS - incorporated in Agreements with the Contractors carrying out decommissioning works Risk of leakages, fires and Remove all fuel storage facilities Contractors During Regional TACs / PIU ESS - explosions from abandoned including burnt/used oils decommissioning fuel facilitates Total 38,000

175

176

Considering the evaluation of the potential impacts of the Project, and the recommended mitigation measures, it is concluded most of the adverse environmental impacts are short-term, localized, and small scale, and can be mitigated through this ESMP. With full implementation of the ESMP in a timely manner, the beneficiaries/affected communities will be better-off with the Project than without it.

CONCLUSION

The ECOWAS-REAP in The Gambia is expected to generate temporary and long-term employment, economic development from improved services dependent on reliable electricity and consequently improved livelihoods.

In The Gambia, indirect benefits to the biophysical environment expected from the Project include protection of natural resources from overexploitation as the increased access to electricity will create alternative means of livelihood. For example, welding and carpentry as compared to fuelwood burning; cooling of seafood rather than smoking for preservation; and cold storage of perishable foods during increased agricultural productivity (more efficiency in production means less land and agrochemicals required).

Despite the potential benefits, the ECOWAS-REAP is likely to create socio-economic negative impacts such as involuntary resettlement and loss of livelihood as a result of land-use and land-take; public and occupational health and safety risks such as traffic accidents, falls from heights and imported contagious diseases; violence against vulnerable groups such as disproportionate compensation for women, sexual exploitation and child employment; destruction of cultural/historical sites of importance; and instability in the affected communities.

Negative environmental impacts include air and surface water pollution, vegetation clearing and destruction of forest trees with its indirect impact on dependent wildlife, land degradation causing erosion and invasion of environmentally sensitive protected areas that destroy biodiversity. Consequent to the outcome of the field assessment for this ESIA study, the Jinak Island was excluded from the Project to avoid the highly sensitive NNP within which the Island falls.

This ESIA recommends a resettlement action plan to address land and livelihood loss due to the Project implementation. Stakeholder consultation and participation during all phases will encourage ownership and prevent grievances. Training and sensitization of all relevant stakeholders in implementing their specific roles in the ESMP including the affected public, TACs, relevant NAWEC staff and workers to be employed by the Contractors.

It is recommended that the contractor develops the Contractors ESMP to specify and guide all mitigation measures related to the construction. This will include proper management of waste, avoidance of forests and other protected parks, avoidance of hunting, legal sourcing of earth materials and use of well serviced equipment and machinery that produces less emission. To mitigate the identified negative impacts, the PIU will ensure that the contractors’ agreements stipulate the ESMP requirements and that efficient monitoring takes place.

The total estimated cost for the ESMP implementation is US $87,000 (eighty-seven thousand dollars). Considering the evaluation of the potential impacts of the Project and the recommended mitigation measures, it is concluded that with full implementation of the ESMP in a timely manner, the beneficiaries / affected communities will be better-off with the Project than the null alternative.

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BIBLIOGRAPHY DWR (2019) Climate data of The Gambia ECOWAS Energy Protocol (2003) A/P4/1/03 ECOWAS White Paper for Increasing Access to Energy Services, 2006 GoTG (1945) Lands (Regions) Act GoTG (1990) Public Health Act GoTG (1991) Physical Planning and Development Control Act, 1991 GoTG (1994) Hazardous chemicals and pesticide control and management Act GoTG (1994) Hazardous Chemicals and Pesticides Control and Management Act GoTG (1994) National Environment Management Act GoTG (1999) Environmental Discharge (Permitting) Regulations GoTG (1999) Environmental Quality Standards Regulations GoTG (2001) The Gambia Public Utilities Regulatory Act (2001) GoTG (2002) Local Government Act GoTG (2003) Gambia Roads Technical Services Authority Act GoTG (2003) National Council for Arts and Culture Act, 2003 GoTG (2005) Mines and Quarries Act GoTG (2005) The Children’s Act (2005) GoTG (2006) Forestry Policy (2006-2016) GoTG (2018) Forestry Act, 2018 GoTG (2007) Anti-littering Regulations GOTG (2007) Labor Act GoTG (2009) National Women’s Bureau (2009) The Gambia National Gender and Women Empowerment GoTG (2019) GBOS Date GoTG (2017) The Stone Circles of Senegambia Management Plan -2017-2021 GOTG (2009) The National Youth Policy (2009-2018) GoTG (2010) The Women’s Act GoTG (2014) EIA Regulations GoTG (2017) National Development Plan 2018-2021 Moja SJ, Van Zuydam CS, Mphephu (2016) Hazard and Risk Assessment in Electricity Sector: A Case of Swaziland Electricity Company. Journal of Geography and Natural Disasters S6: 006. doi: 10.4172/2167-0587.S6-006 NEA (1999) Environmental Impact Assessment (EIA) Guidelines NEA (2009) Gambia Environmental Action Plan, Phase II (2009-2018) Nuimi National Park Management Plan- 2020 OMVG (2018) Study For The Project Of Electricity Access From The Substations Of Regional Project (Omvg And Omvs) In The Republic Of Senegal, Guinea, Guinee Bissau And The Gambia; Deliverable N° 4 : Detailed Studies; Final Report (Revised); The Gambia UN Convention on Biological Diversity (CBD) (1992) UN Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW) (1979) UN Convention on the Rights of Persons with Disabilities (CRPD) (2006) UN Convention on the Rights of the Child, (UNICEF) (1989) UN Framework Convention on Climate Change (UNFCCC) (1994) United Nations (2001) Convention to Combat Desertification (CCD) (1994) World Bank (March, 2020) Technical Note: Public Consultations and Stakeholder Engagement in WB-

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Supported Operations when there are Constraints on Conducting Public Meetings WB (1999) Operational Manual Operational Policies OP 4.01 Environmental Assessment WB IFC (2007) EHS General Guidelines http://hdr.undp.org/en/content/gender-inequality-index https://www.lavanguardia.com/natural/actualidad/20191021/471036333031/aguila-pesacadora- migres-red-electrica-plataforma-nido.html https://www.lavanguardia.com/natural/actualidad/20191021/471036333031/aguila-pesacadora- migres-red-electrica-plataforma-nido.html “The Gambia, Guinea Bissau, Mali and Economic Community of West African States (ECOWAS) - ECOWAS-Regional Electricity Access Project” (IDA/R2018-0379/1) dated November 26, 2018, with a closing date of December 13, 2018. Ramsar Wetland Study The Gambia, 1997). hdr.undp.org/en/countries/profiles/gmb chartsbin.com/view/4319 www.ecowrex.org/.../2008_ecowas_environmental_policy_-_ecowa… · PDF file

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APPENDICES Appendix 2.1: Map of Routes of the Soma Feeder

Appendix 2.1: Soma Feeder 1. Sheet 1

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Appendix 2.1: Soma Feeder 1. Sheet 2

156

Appendix 2.1: Soma Feeder 2. Sheet 1

157

Appendix 2.1: Soma Feeder 3. Sheet 1

158

Appendix 2.1: Soma Feeder 3. Sheet 2

159

Appendix 2.1: Soma Feeder 4. Sheet 1

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Appendix 2.1: Soma Feeder 4 Sheet 2

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Appendix 4.1: Communities Along the Soma Feeders

No: Village/Community District Population # of Households Total M F SOMA SUB-STATION FEEDER 1 1.1 Soma Jarra West 12672 6101 6571 2252 1.2 Sankwia Jarra West 1571 701 870 219 1.3 Kani Kunda Jarra West 965 420 545 153 1.4 Jenoi Jarra West 1070 501 569 164 1.5 Pakalinding Jarra West 2114 962 1152 302 1.6 Farafenni Illiasa/Upper 27396 13445 13951 4215 Badibu 1.7 Makka Farafenni Illiasa 1201 545 656 85 1.8 Chamen Illiasa 306 134 172 26 1.9 Daaru Yalla Illiasa 282 135 147 23 1.10 Conteh Kunda Illiasa 653 278 375 84 1.11 Conteh Kunda Niiji Illiasa 744 339 405 82 1.12 Darusalam Lower Badibu 368 201 167 22 1.13 Dobo Central Badibu 811 395 416 56 1.14 Amdallai Lower Niumi 1626 811 815 202 1.15 Fass Njaga Choi Lower Niumi 3284 1610 1674 408 1.16 Kerr Sanyang Lower Niumi 319 157 162 33 1.17 Missiranding Lower Niumi 592 275 317 33 1.18 Jinack Kajata Lower Niumi 741 346 395 112 1.19 Jinack Niji Lower Niumi 584 299 285 80 1.20 Kerr Jatta Lower Niumi 788 395 393 70 1.21 Medina Sotokoi Lower Niumi 286 136 150 31 1.22 Wellingara Lewna Lower Niumi 309 162 147 51 1.23 Lewna Lower Niumi 337 171 166 37 1.24 Njongon Lower Niumi 785 371 414 81 1.25 Mbollet Lower Niumi 1527 729 798 160 1.26 Kanuma Lower Niumi 1784 830 954 195 1.27 Barra Lower Niumi 5016 2650 2366 954 1.28 Essau Lower Niumi 9796 4830 4966 1564 1.29 Buniadu Lower Niumi 1080 516 564 118 1.30 Berending Lower Niumi 1871 882 989 212 1.31 Kerr Wali Lower Niumi 482 237 245 39 1.32 Ndofan Lower Niumi 724 345 379 55 1.33 Madina Serigne Mass Lower Niumi 1799 857 942 155 1.34 Chamen Lower Niumi 829 400 429 84 1.35 Kerr Samba Kalla Lower Niumi 1227 604 623 89 1.36 Ndungu Kebbeh Lower Niumi 3709 1764 1945 378 1.37 Njoufain Lower Niumi 310 140 170 21 1.38 Jamagen Lower Niumi 566 280 286 45 1.39 Jamagen Lower Niumi 566 280 286 4 1.40 Kerr Bugumayaa Lower Niumi 308 162 146 26 1.41 Kolly Kunda Lower Niumi 108 61 47 9 1.42 Mendy Kunda Lower Niumi 123 46 77 7

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No: Village/Community District Population # of Households Total M F 1.43 Kerr Gallo Lower Niumi 398 240 158 43 1.44 Kerr Ngojan Jokadu 403 197 206 25 1.45 Kuntair Jokadu 1326 627 699 170 1.46 Kerr Jarga Jobe Jokadu 1349 594 755 92 1.47 Munyagen Jokadu 1774 811 963 140 1.48 Dasilameh Jokadu 1149 580 569 132 1.49 Tambana Jokadu 939 432 507 93 1.50 Kerr selle Jokadu 178 82 96 16 1.51 Kerr Ngonyane Jokadu 403 197 206 25 1.52 Daaru Foday Baa Jokadu 388 185 203 44 1.53 Jurunku Upper Niumi 335 141 194 85 1.54 Kerwan Lower Badibu 4570 2174 2396 676 1.55 Saba Lower Badibu 1990 903 1087 249 1.56 Gunjur Lower Badibu 1310 562 748 158 1.57 Banni Lower Badibu 1477 704 773 130 1.58 Njawara Lower Badibu 944 460 484 123 1.59 Kinteh Kunda Central Badibu 670 307 363 42 1.60 Jammeh Kunda Central Badibu 382 287 95 178 1.61 Salikenni Central Badibu 3403 1584 1819 487 1.62 Mandory Central Badibu 967 482 485 79 1.63 Marong Kunda Central Badibu 461 194 267 68 1.64 Daru Riliwan Central Badibu 2163 1177 986 113 1.65 Njaba Knuda Central Badibu 2865 1283 1582 342 1.66 Kerr Pateh Koreh Central Badibu 1801 889 912 174 1.67 Minteh Kunda Central Badibu 639 263 376 90 1.68 Burang Ya Upper Badibu 303 142 161 24 1.69 No Kunda/No Kunda Upper Badibu 1833 786 1047 245 Fula 1.70 Illiassa Upper Badibu 1305 584 721 148 1.71 Jajary Upper Badibu 730 328 402 83 1.72 Jumasarr Ba Upper Badibu 877 388 489 63 1.73 Jumasarr Koto Upper Badibu 91 49 42 9 1.74 Alkali Kunda Upper Badibu 922 435 487 102 1.75 Katchang Upper Badibu 1788 835 953 242 1.76 Kerr Cherno Upper Niumi 1003 641 362 75 1.77 Mamuda Upper Niumi 268 118 150 20 1.78 Sika Upper Niumi 907 492 415 95 1.79 Kerr Demba Holeh Upper Niumi 1.80 Samba Kala Lower Niumi 1227 604 623 89 1.81 Pakau Saloum Upper Niumi 579 272 307 45 1.82 Pakau Njogu Upper Niumi 1608 767 841 136 1.83 Bakalarr Upper Niumi 656 390 266 58 1.84 Aljamdou Upper Niumi 1066 499 567 135 1.85 Sitanunku Upper Niumi 1173 536 637 116 1.86 Toubab Kolong Upper Niumi 1077 516 561 140 1.87 Bantang Killing Upper Niumi 749 351 398 80 1.88 Memeh Upper Niumi 586 299 287 47

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No: Village/Community District Population # of Households Total M F 1.89 Ndangka Ndangka Upper Badibu 47 24 23 7 Sub-Total 142,708 68,914 73,794 18,669 SOMA SUB-STATION FEEDER 2 2.1 Missira Jarra West 806 370 436 74 2.2 Sare Musa Jarra West 700 317 383 72 2.3 Subundu Jarra West 322 130 192 26 2.4 Jiffin Jarra West 452 210 242 73 2.5 Si- Kunda Jarra West 1047 472 575 116 2.6 Toniataba Jarra West 1057 502 555 166 2.7 Sare Biran Jarra West 86 36 50 24 2.8 Kaiaf Kiang East 1773 807 966 257 2.9 Geniere Kiang East 584 263 321 90 2.10 Massembeh Kiang East 636 292 344 85 2.11 Kolior Sula Kiang East 73 32 41 13 2.12 Kolior Nyamala Kiang East 348 153 195 20 2.13 Nema Kuta, Kiang Central 241 111 130 51 2.14 Mandina Kiang Central 284 132 152 28 2.15 Jirroff Kiang Central 485 207 278 71 2.16 Kundong Numu Kunda Kiang Central 215 102 113 20 2.17 Kundang Fula Kunda Kiang Central 133 61 72 21 2.18 Kundang Maria Kiang Central 16 8 8 4 2.19 Nema Kiang Central 1024 479 545 118 2.20 Bambako Kiang Central 253 111 142 38 2.21 Bumari Kiang Central 256 132 124 31 2.22 Kwinella Kiang Central 1290 632 658 179 2.23 Tendaba Kiang Central 388 179 209 54 2.24 Nioro Jataba Kiang West 1321 589 732 142 2.25 Sankandi Kiang West 590 296 294 81 2.26 Jataba Kiang West 766 362 404 120 2.27 Jomar Kiang East 200 85 115 28 2.28 Jasobo Kiang East 271 127 144 33 2.29 Wurokang Kiang Central 598 292 306 71 2.30 Bateling Kiang West 232 115 117 40 2.31 Jali Kiang West 1055 469 586 140 2.32 Kantong Kunda Kiang West 526 244 282 64 2.33 Manduar Kiang West 566 268 298 94 2.34 Karantaba Kiang West 900 472 428 109 2.35 Janneh Kunda Kiang West 703 335 368 74 2.36 Kemoto Kiang West 284 144 140 50 2.37 Butung/Jula Kunda Kiang West 244 109 135 40 2.38 Tankular Kiang West 681 300 381 95 Sub-Total 21,406 9,945 11,461 2,812

SOMA SUB-STATION FEEDER 3 – SOMA-BANSANG 3.1 Karantaba Jarra West 1189 530 659 165 3.2 Buiba Mandinka Jarra Central 463 225 238 46 3.3 Buiba Jallow Kunda Jarra Central 140 58 82 15

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No: Village/Community District Population # of Households Total M F 3.4 Buiba Musa Njado Jarra Central 210 134 76 12 3.5 Jappineh Tembeto Jarra Central 675 319 356 60 3.6 Jappineh Marikoto Jarra Central 1488 694 794 178 3.7 Jobe Kunda Jarra Central 117 47 70 12 3.8 Nema Kuta Jarra Central 90 46 44 10 3.9 Sita Huma Jarra Central 288 151 137 44 3.10 Jalamberehcrossma Jarra Central 2018 988 1030 224 3.11 Forololo Jarra Central 235 103 132 19 3.12 Badumeh Kuta Jarra Central 193 100 93 23 3.13 Dongoroba Jarra East 1416 664 752 125 3.14 Wellingara Ba- Jarra East 2520 1228 1292 467 Korosima 3.15 Bureng Jarra East 1313 587 726 180 3.16 Dasilami Jarra East 534 270 264 98 3.17 Sutukung Jarra East 2331 1344 987 125 3.18 Barrow Kunda Jarra East 2542 1320 1222 295 3.19 Jassong Jarra East 591 300 291 76 3.20 Boraba Upper Fulladu 367 162 205 39 West 3.21 Yoro Beri Kunda Upper Fulladu 469 267 202 32 Mandinka West 3.22 Boiram Lower Fulladu 1847 911 936 132 West 3.23 Njoben Lower Fulladu 2012 864 1148 117 West 3.24 Tabanding Lower Fulladu 481 221 260 24 West 3.25 Brikamaba Lower Fulladu 4238 2007 2231 749 West 3.26 Munyagen Lower Fulladu West 3.27 Darusalam (Sinchu Niamina East 810 355 455 58 Alagi) 3.28 Pateh Sam Niamina East 2123 1034 1089 120 3.29 Mamud Fana Niamina East 1466 618 848 127 3.30 Mbayen Niamina East 694 291 403 53 3.31 Mbayen Kakka Lower Fulladu West 3.32 Njai Kunda Niamina East 660 268 392 58 3.33 Mai Kunda Lower Fulladu West 3.34 Dankunku Niamina Dankuku 954 444 510 160 3.35 Bansang Upper Fuladu West 7938 3813 4125 1583 3.36 Sololo Upper Fulladu 1193 552 641 146 West 3.37 Fulabantang Lower Fulladu 802 387 415 120 West

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No: Village/Community District Population # of Households Total M F 3.38 Faraba Lower Fulladu 401 181 220 46 West 3.39 Pacharr Lower Fulladu 1329 630 699 74 West 3.40 Kerewan Samba Sira Lower Fulladu 970 445 525 116 West 3.41 Bamba kolong Niamina East 177 73 104 21 3.42 Pakaliba Jarra East 1050 483 567 177 3.43 Dablly Jarra East 38 19 19 3 3.44 Wellingara Jarra East 106 50 56 8 3.45 Jula Kunda Jarra East 106 50 56 8 3.46 Missira Jarra East 51 23 28 4 3.47 Sukuta Jarra East 440 213 227 69 3.48 Madina Jarra East 556 257 299 33 3.49 Felleng koto Jarra East 171 86 85 19 3.50 Sankuleh Kunda Lower Fulladu 615 313 302 98 West 3.51 Sarre Laobeh Niamina Dankunku 3.52 Sarre Ifra Niamina Dankunku 3.53 Sare Lefa Niamina Dankunku 37 19 18 2 3.54 Pinai Niamina West 305 137 168 45 3.55 Katamina Niamina West 512 237 275 75 3.56 Mali Kunda Niamina West 392 195 197 37 3.57 Jamwelly Niamina West 139 78 61 21 3.58 Sambang Fula Niamina West 453 245 208 54 3.59 Sambang Mandinka Niamina West 230 115 115 36 3.60 Buniadu Niamina Dankunku 56 27 29 7 3.61 Touba Mourid Niamina Dankunku 234 99 135 23 3.62 Sey Kunda Niamina Dankunku 180 79 101 16 3.63 Kerr Lien Lower Saloum 117 49 68 7 3.64 Jassedi Niamina Dankunku 480 202 278 57 3.65 Jassedi Wharf Town Niamina Dankunku 3.66 Missira Niamina Dankunku 223 111 112 24 3.67 Barrow Kunda Niamina Dankunku 620 263 357 40 3.68 Jawulaba Kunda Niamina West 297 123 174 9 3.69 Papa Niamina West 304 144 160 22 3.70 Weillingara Momodou Niamina West 284 140 144 22 3.71 Koli Kunda Niamina West 107 61 46 5 Sub-Total 55,387 26,449 28,938 6,870 SOMA SUB-STATION FEEDER 4- 4.1 Kerr Ali Illiasa/Upper 598 323 275 53 Badibou 4.2 Kunjo Sabach Sanjal 491 231 260 41 4.3 Numu Kunda Sabach Sanjal 364 166 198 27 4.4 Kerr Bamba Sabach Sanjal 520 195 325 39 4.5 Njieyen Sabach Sanjal 569 265 304 32 4.6 Ndowen Sabach Sanjal 222 105 117 15

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No: Village/Community District Population # of Households Total M F 4.7 Loumen Sabach Sanjal 401 165 236 43 4.8 Mballow Omar Tega Sabach Sanjal 966 446 520 84 4.9 Sabach Sukoto Sabach Sanjal 116 55 61 18 4.10 Chalal Upper Badibu 541 254 287 44 4.11 Mbapa Marige Upper Badibu 301 107 194 24 4.12 Mbapa Bah Upper Badibu 255 107 148 23 4.13 Sinchu Njabo Upper Badibu 88 31 57 11 4.14 Kani Kunda Upper Badibu 393 171 222 52 4.15 Sukoto Fula Upper Badibu 85 40 45 5 4.16 Sabach Njieyen Sabach Sanjal 1575 899 676 70 4.17 Taiba Sabach Sanjal 106 48 58 9 4.18 Kataba Sabach Sanjal 155 68 87 11 4.19 Kataba Mandinka Sabach Sanjal 300 138 162 16 4.20 Tambaa Koto Sabach Sanjal 301 136 165 30 4.21 Bassik Sabach Sanjal 453 217 236 36 4.22 Nyang Kunda Sabach Sanjal 191 81 110 12 4.23 Dibba Kunda Sabach Sanjal 1276 603 673 110 4.24 Ngeyen Sabach Sabach Sanjal 302 134 168 26 4.25 Ngayen Sanjal Sabach Sanjal 2951 1308 1643 249 4.26 Sara Kunda Sabach Sanjal 1346 645 701 153 4.27 Pallen Fula Sabach Sanjal 639 296 343 41 4.28 Ballangharr Benteng Ke Lower Saloum 361 160 201 22 4.29 Ballangharr Ker Janga Lower Saloum 225 94 131 16 4.30 Auldi Upper Saloum 471 200 271 39 4.31 Kerr Sulay Upper Saloum 407 171 236 34 4.32 Pakala Upper Saloum 101 52 49 10 4.33 Bambara Lower Saloum 4.34 Kerr Isap Upper Saloum 254 98 156 22 4.35 Kerr Alhagie Demba Upper Saloum 115 52 63 9 4.36 Jaring Mandinka Lower Saloum 4.37 Jaring Mboyen Lower Saloum 4.38 Kerr Kossa Lower Saloum 142 58 84 10 4.39 Ballangharr Chamen Lower Saloum 102 43 59 7 4.40 Ballangharr Kerr Nderry Lower Saloum 174 79 95 110 4.41 Arafat Lower Saloum 4.42 Kaur Lower Saloum 4739 2098 2641 714 4.43 Njau Sawalo Upper Saloum 623 257 366 66 4.44 Panchang Upper Saloum 736 316 420 96 4.45 Tuba Koto Niani 181 73 108 16 4.46 Barajali Niani 761 385 376 63 4.47 Barajali Tenda Niani 141 76 65 10 4.48 Kunting Sami 1417 767 650 99 4.49 Dobo Sami 758 342 416 64 4.50 Lamin Koto Sami 519 252 267 42 4.51 Yonna Sami 384 185 199 25 4.52 Buduck Nianija 429 225 204 37 4.53 Maka Nianija 18 9 9 2

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No: Village/Community District Population # of Households Total M F 4.54 Chamen Nianija 1427 670 757 124 4.55 Conteh Nianija 781 350 431 74 4.56 Leba Amat Jallow Upper Saloum 119 55 64 10 4.57 Leba Malick Mbye Upper Saloum 353 176 177 34 4.58 Leba Pegal Upper Saloum 44 17 27 4 4.59 Leba Samba Jobe Upper Saloum 269 116 153 20 4.60 Leba Seedy Njie Upper Saloum 39 18 21 2 4.61 Bati Khai Upper Saloum 396 167 229 31 4.62 Kayai Nianija 86 44 42 14 4.63 Palelai Nianija 412 187 225 42 4. 64 Kerr Batch Nianija 100 45 55 13 4. 65 Tento Upper Saloum 410 190 220 31 4.66 Fass Upper Saloum 927 457 470 54 4.67 Mbaien Lower Saloum 109 56 53 10 4.68 Kerr Samba Sira Lower Saloum 190 90 100 25 4.69 Kerr Samba Njabe Lower Saloum 4.70 Nyanga Bantang Niani 779 376 403 86 4.71 Kutcha Niani 162 67 95 15 4.72 Njoben Wollof Niani 180 75 105 19 4.73 Kass Fula Niani 233 118 115 13 4.74 Dingirai Niani 401 186 215 37 4.75 Ndarameh Nianija 154 56 98 11 Sub-Total 36,134 16,742 19,392 3,456 Total Population/Household 255,635 122,050 133,585 31,807 SD Focus Ltd. (2020) with data from GBOS, 2019

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Appendix 4.2: List of Corridors under the Soma Substation Feeders

Soma Feeder 1 (SF-1) Transmission Line Corridors

Corridor 2: Fass Njaga Choi – Jamagen – Along Farmlands Corridor 3: Kerr Sanyang – Sotokoi - Along Farmlands Corridor 4: Mbolletba – Mbankam – Along Farmlands Corridor 5 Kuntaya – Jurunku - Along Road Corridor Corridor 6 Njongon – Bangally - Along Farmlands Corridor 7: Albreda – Sika - Along Road Corridor Corridor 8: Albreda – Demba Holleh - Along Road Corridor Corridor 9: Sukumya – Chillah - Along Farmlands Corridor 10: Kerr Jarga Junction – Kerr Jarga Jobe Along Road Corridor Corridor 11: Munyagen – Karantaba - Along Farmlands Corridor 12: Njawara – Minteh Kunda - Along Road Corridor Corridor 13: Illiasa – Katchang - Along Road Corridor/Along Farmlands??

Number of Corridors = 12

Soma Feeder 2 (SF-2) Transmission Line Corridors

Corridor 1: Toniataba – Kolior - Along Road Corridor Corridor 2: Kolior – Jasobo - Along Farmlands Corridor 3: Kolior – Kwinella - Along Road Corridor Corridor 4: Wurokang – Bateling - Along Road Corridor Corridor 5: Sankandi – Jali Junction - Along Road Corridor Corridor 6: Jali Junction – Jali Village - Along Road Corridor Corridor 7: Jali Junction – Keneba - Along Road Corridor Corridor 8: Keneba – Kemoto - Along Road Corridor Corridor 9: Karantaba – Burong - Along Farmlands Corridor 10: Manduar – Tankular - Along Road Corridor

Number of Corridors = 10

Soma Feeder 3 (SF-3) Transmission Line Corridors

Corridor 1: Brikamaba – Tabanding Along Road Corridor Corridor 2: Mamutfana Junction – Mamutfana Village - Along Road Corridor Corridor 3: Jareng – Choya - Along Road Corridor Corridor 4: Choya – Mali Kunda - Along Road Corridor Corridor 5: Mali Kunda – Dankunku - Along Farmlands Corridor 6: Dankunku – Koli Kunda - Along Farmlands Corridor 7: Borehole – Jesadi Tenda - Along Road Corridor Corridor 8: Pakaliba – Jalanbereh - Along Road Corridor Corridor 8A Pakaliba – Sukuta - Along Road Corridor Corridor 9: Darsilami – Sutukung - Along Road Corridor Corridor 10: Wellingaraba – Bureng - Along Road Corridor

Number of Corridors = 10

169

Soma Feeder 4 (SF-4) Transmission Line Corridors

Corridor 1: Kunjo – Numu Kunda - Along Road Corridor Corridor 2: Sabach Sukoto – Mballow Omar Tega - Along Farmlands Corridor 3: Arafat Junction – Arafat Village - Along Road Corridor Corridor 4: Kaur – Kerr Maila village - Along Farmlands Corridor 5: Kaur – Njau Sawalo - Along Road Corridor Corridor 6: Njau Sawalo – Carrols Wharf - Along Road Corridor Corridor 7: Chamen – Nyanga bantang - Along Farmlands Corridor 8: Nyanga bantang – Njau Sawalo - Along Road Corridor/Area impacted by loss of earnings Corridor 9: Nyanga bantang – Wassu - Along Road Corridor/Area impacted by loss of earnings Corridor 10: Palang – Kataba - Along Farmlands Corridor 11: Kuntaur Fula Kunda – Barajally Tenda - Along Road Corridor Corridor 12: Kaleng Jawbeh – Bush Town - Along Road Corridor

Number of Corridors = 12

Total Number of Corridors for Soma Feeders = 46

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Appendix 4.3: Location-Specific Baseline Environmental Conditions Soma Feeder 1 (SF-1) Transmission Line Corridors

Corridor 1: Fass Njaga Choi – Jamagen

Distance Location Features Position Approx. Action Remarks from Fass of Height/ Proposed by Njaga Choi Feature Area the Project (km) (m) 0.0 Barra- Transmission LHS 5m Locate pole The Amdalai line pole to here proposed Road (at be located Fass Njaga Fass Njaga here Choi- Choi) Jamagen line starts here and will run either on the Left- or Right- hand side of the Fass- Jamagen Road 0.1 Fass Njaga Transmission RHS 3m Line to run Choi line pole to along the be located RHS of the here road 0.15 Fass Njaga Transmission LHS 2m Line to run Choi line pole to along the be located LHS of the here road 0.6 Fass Njaga Gully LHS 6 Avoid Choi putting poles close to Gully 1.8 Fass Njaga Line of RHS 5 Trim RAP Choi Cashew trees 3.5 Kerr Women’s LHS 4 Avoid Health and Sanyang vegetable putting safety Garden poles inside concerns the Garden during construction of poles 3.7 Kerr Kerr RHS 7 Health and Sanyang Sanyang safety Primary concerns School during construction of poles

171

Distance Location Features Position Approx. Action Remarks from Fass of Height/ Proposed by Njaga Choi Feature Area the Project (km) (m) 3.75 Kerr Hansis RHS 3 Health and Sanyang Health Clinic safety concerns during construction of poles. 3.9 Kerr Cemetery RHS 2 Avoid 100x100 Sanyang putting fenced with poles inside wooden the poles. Cemetery 5.0 Kerr Wetland RHS and Across the Avoid Low lying Sanyang Area LHS Road putting waterway poles in liable to wetland flooding area 6.4 Jamagen Football field LHS 2 Avoid Unfenced putting 150mx150m poles in football field 6.4 Jamagen Jamagen RHS 5 100mx100m Primary fenced with School cement blocks. Health and safety concerns during construction of poles. 6.6 Jamagen Transmission LHS For health The line pole to and safety Proposed be located reasons, Fass Njaga here with transformers Choi- pole- must not be Jamagen mounted accessible to terminates transformer public here with a pole - mounted transformer.

Corridor 2: Kerr Sanyang – Sotokoi

172

Distance Location Features Position Approx. Action Remarks from Fass of Height/ Proposed by Njaga Choi Feature Area the Project (km) (m) Distance Location Features Position Approx. Action Remarks from Kerr of Height/Area Proposed by Sanyang Feature (m) the Project (km) 0 Kerr Transmission RHS 7 Locate pole The Sanyang line pole to here Proposed be located Kerr here Sanyang- Sotokoi line starts here and will run on the LHS of the Kerr Sanyang- Sotokoi Road. 1.1 Missiranding Women’s LHS 10 Avoid Health and Garden putting poles safety inside the concerns Garden during construction of poles. 1.5 Sotokoi Private LHS 8 Avoid 100mx100m Garden putting poles fenced with inside the grass. Garden Health and safety concerns during construction of poles. 1.55 Sotokoi Private RHS 10 Avoid 100mx100m Garden putting poles fenced with inside the grass. Garden Health and safety concerns during construction of poles. 2.6 Sotokoi Proposed LHS For health The transmission and safety Proposed line pole reasons, Kerr with transformers Sanyang – transformer must not be Sotokoi Line accessible to terminates public here with a

173

Distance Location Features Position Approx. Action Remarks from Fass of Height/ Proposed by Njaga Choi Feature Area the Project (km) (m) pole - mounted transformer.

174

Corridor 3: Kanuma – Jinack Islands

Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Kanuma Feature (m) by the (km) Project 0.0 Barra- Transmission LHS 5m Locate pole The Proposed Amdalai line pole to Kanuma - Jinack Road (at be located Niji line starts Kanuma) here here and will run on LHS of the Kanuma – Jinack Niji Road. 0.1 Kanuma Transmission LHS Line to run along line pole to the LHS of the be located road here 0.11 Kanuma Women’s LHS 5 Avoid 200mx100m Garden putting fenced with poles inside sticks. Health the Garden and safety concerns during construction of poles. 0.11 Kanuma Group of LHS 3 Trim RAP Cashew Trees 0.4 Kanuma Private LHS 5 Avoid Fenced with Garden putting wooden posts poles inside and barbed the Garden wire. Health and safety concerns during construction of poles. 0.45 Kanuma Orchard LHS 4 Avoid Belongs to one putting Mr Njie. Health poles inside and safety the orchard concerns during construction of poles. 0.6 Kanuma Kanuma RHS 1 Avoid Lodge putting poles inside Lodge 1.3 Kanuma Transmission RHS Line turns right line pole to towards Jinack be located Islands and runs here on RHS of road 1.4 Kanuma The NNP RHS Construct Extreme caution boundary pole and must be

175

Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Kanuma Feature (m) by the (km) Project begins minimize exercised during here/Office damage project of DPWM and implementation, destruction as this is a highly to the fauna ecologically and flora sensitive area of global significance.

A RAP will be developed to mitigate the potential negative impact of the Project 1.8 Kanuma Swampy Swamp Avoid Low lying area Area extends putting liable to across poles in the flooding the swamps road 8.8 Jinack Niji Transmission RHS For health Line will cross line pole to and safety the bolong to be located reasons, Jink Niji and here with transformer Jinack Kajata by pole- must not overhead mounted be towers or sub transformer accessible marine cables to public

Corridor 4: Mbolletba – Mbankam

Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Mboletba Feature (m) by the (km) Project 0.0 Barra- Transmission LHS 5m Locate pole The Amdalai Road line pole to Proposed (at be located Mbolletba - Mbolletba) here Mbankam line starts

176

Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Mboletba Feature (m) by the (km) Project here and will run on LHS or RHS of the Mbolletba - Mbankam Road. 0.1 Mbolletba Mango Tree LHS 3 Avoid 0.1 Mbolletba Public Well RHS 3 Avoid well Health and safety concerns during construction of poles. 0.2 Mbolletba Mbolletba RHS 10 Avoid 100mx100m School school fenced with cement blocks. Health and safety concerns during construction of poles. 0.3 Mbolletba Public RHS 8 Avoid Health and standpipe putting safety pole close concerns to during standpipe construction of poles. 0.4 Mbolletba Mango Tree LHS 5 Avoid 0.5 Mbolletba Row of 1 LHS 5 Trim Mango and 3 Cashew Trees 1.0 Mbolletba Row of 3 LHS 3 Trim RAP Mango Trees 1.6 Mbolletba Cashew Tree LHS 4 Trim 1.6 Mbolletba Cashew Tree RHS 3 Trim 1.8 Mbolletba Cashew LHS 2 Trim 1.8 Mbolletba Row of RHS 4 Trim Cashew Tree 1.9 Mbankam Cashew RHS 4 Trim 2.3 Mbankam Group of 5 LHS 2 Trim Cashew Trees 3.1 Mbankam Mango Tree RHS 3 Trim

177

Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Mboletba Feature (m) by the (km) Project 3.3 Mbankam Transmission RHS For health The proposed line pole and safety Mbolletba – with reasons, Mbankam transformer transformer line to be must not be terminates located here accessible here with a to public pole - mounted transformer.

178

Corridor 5: Kuntaya – Jurunku

Distance Location Features Position Approx. Action Remarks from of Height/Area Proposed Kuntaya Feature (m) by the (km) Project 0.0 Kuntaya Transmission LHS 5m Locate pole The Proposed line pole to pole Kuntaya - Jurunku be located line starts here here and will run on LHS of the Kuntaya - Jurunku Road. 1.3 Memmeh Private LHS 4 Avoid compound putting poles inside the compound 1.4 Memmeh Football field LHS 1.5 Avoid Unfenced putting 130mx130m poles on football field 2.3 Memmeh Culvert and Across Avoid Low lying swampy mangroves the putting area vulnerable to road poles in flooding. Width of Swamp is less than 100m. One pole span can be used across the swampy area. 6.3 Chamen Cashew LHS 5 Trim RAP Sosseh orchard Cashew Trees along frontage 14.6 Chillah Row of LHS 4 Trim RAP forest trees 15.0 Jurunku Transmission RHS For health The Proposed line pole and safety Kuntaya – Jurunku with reasons, Line terminates transformer transformer here with a pole - to be must not mounted located here be transformer. accessible to public

179

Corridor 6: Njongon – Bangally

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Njongon Feature Area by the (km) (m) Project 0.0 Barra- Transmission line pole LHS 5m Locate pole The Proposed Njongon- Amdalai to be located here Bangally line starts here Road (at and will run on the LHS of Njongon) the Njongon -Bangally Road. 1.3 Sam New transmission line LHS 3m Line turns right to run Mbollet pole to be located along the RHS of the road (Mbolletn here ding 4.8 Ndofan New transmission line RHS Line turns right to run pole to be located behind the village to avoid here to run through obstructions within the farmlands village. 6.6 Kerr Proposed RHS Line turns right to run Wally transmission line ole behind the village to avoid pole obstructions within the village. 8.2 Bangally Proposed RHS For health The Proposed Njongon – transmission line pole and safety Bangally Line terminates with transformer reasons, here with a pole -mounted transformer transformer. must not be accessible to public

Corridor 7: Albreda – Sika

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Albreda Feature Area by the (km) (m) Project 0.0 Albreda New transmission LHS 5m Locate pole The Proposed Albreda- Sika line line pole to be starts here and will run on the located here LHS of the Albreda -Sika Road. 0.2 Albreda Nursery School LHS 5m Do not 75mx50m fenced with cement construct blocks. pole at least 10 meters from fence

180

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed Albreda Feature Area by the (km) (m) Project 5.6 Sika New transmission LHS For health The proposed Albreda – Sika line pole to be and safety line terminates here with a located here reasons, pole -mounted transformer. transforme r must not be accessible to public

Corridor 8: Albreda – Demba Holleh

Distance Location Features Position Approx Action Remarks from of Height/ Proposed by Albreda Feature Area the Project (km) (m) 0.0 Albreda New transmission line RHS Locate new The proposed Albreda - pole to be located pole here Demba Holleh line starts here here and will run on the RHS of the Albreda – Demba Holleh Road. 3.4 Pakau Cashew Plantation RHS 5 Trim 100mx100m unfenced. Health Saloum and safety concerns during construction of poles. 4.7 Pakau Pakau Saloum LHS 7 Health and School is unfenced. Saloum Primary School safety concerns during construction of poles 4.0 Pakau New transmission to RHS For health and The proposed Albreda - Saloum be located here with safety Demba Holleh Line terminates transformer concerns here with a pole -mounted transformer transformer. must not be accessible to public.

181

Corridor 9: Sukumya – Chillah

Distance Location Features Position Approx Action Remarks from of Height/ Proposed by Sukumya Feature Area the Project (km) (m) 0.0 Sukumy New transmission line RHS Locate new The Proposed Sukumya - a/ pole to be located pole here Chillah line starts here and Mamud here will run on the RHS of the a Sukumya - Chillah Road. Junction (along Albreda – Demba Holleh Road) 0.3 Sukumy No features impacted No features impacted a because transmission line will run outside the village 1.8 Mamud No features impacted No features impacted da because transmission line will run outside the village 6.4 Medina No features impacted No features impacted Serign because transmission line Mass will run outside the village 10.6 Fass No features impacted Chaho 16.9 Kerr No features impacted Cherno Baba 19.2 Bafuloto No features impacted 20.8 Kerr No features impacted Mamut Jow 24.3 Chillah New transmission RHS For health The Proposed Sukumya – pole to be located and safety Chillah line terminates here here with concerns with a pole -mounted transformer transformer transformer. must not be accessible to public.

182

162

Corridor 10: Kerr Jarga Junction – Kerr Jarga Jobe

Distance Location Features Position Approx. Action Remarks from Junction of Height/ Proposed by (km) Feature Area the Project (m) 0.0 Barra –Farafenni New transmission line pole to RHS Locate new The Proposed Kerr Jarga Junction - Kerr Highway (at Kerr be located here pole here Jarga Jobe line starts here and will run on Jarga Junction) the RHS of the Road to Kerr Jarga. 0.2 Kerr Jarga Private property fenced with RHS 10 Avoid putting sticks and wire pole inside the compound 0.2 Kerr Jarga Kerr Jarga Jobe Lower Basic LHS 5 Health and School is unfenced and is children could School safety be impacted especially during pole concerns construction. during construction of poles 0.3 Kerr Jarga New transmission pole to be RHS For health The Proposed Kerr Jarga Junction – Kerr located here with transformer and safety Jarga Line terminates here with a pole- concerns mounted transformer. transformer must not be accessible to public

162

Corridor 11: Munyagen – Karantaba

Distance from Location Features Position of Approx. Action Proposed by the Remarks Munyagen Feature Height/Area Project (km) (m) 0.0 Barra –Farafenni New transmission LHS LV poles already exist The Proposed Munyagen - Highway (at line pole to be but not electrified Karantaba line starts here Munyagen) located here and will run on the LHS of the Road to Karantaba. 0.1 Munyagen Private compound LHS 0.5 Compound is 60mx50m, with 1 LV pole fenced sticks and belongs to erected inside Ousman Ceesay 0.2 Munyagen Private compound h LHS 0.4 Compound is 70mx50m, 1 LV pole erected unfenced. Has 1 mud block inside house and belongs to Wally Sowe 0.3 Munyagen Private compound LHS 0.6 Compound is 50mx50m, with 1 LV pole fenced with sticks and erected inside belongs to Kebba Jahateh 1.4 Tambana No features Vegetation/land use: impacted Farmland sparsely located trees 2.6 Karantaba New transmission RHS For health and safety The Proposed Munyagen – pole to be located concerns transformer Karantaba Line terminates here with must not be accessible here with a pole -mounted transformer to public transformer.

163

Corridor 12: Suwareh Kunda – Njawara

Distance Location Features Position Approx. Action Remarks from of Feature Height/Area Proposed by Suwareh (m) the Project Kunda (km) 0.0 Suwareh New transmission line pole to RHS LV poles The Proposed Suwareh Kunda - Njawara line Kunda be located here already exist starts here and will run on the RHS of the Road but not to Njawara. electrified 0.1 Suwareh Group of 5 Mango Trees RHS 4 Trim RAP Kunda 1.9 Darusalam No features impacted Vegetation/Land use: Farmland sparsely located trees 5,6 Toro Bah No features impacted Vegetation/Land use: Farmland sparsely located trees

6.6 Njawara New transmission line pole to RHS For health The Proposed Suwareh Kunda – Njawara Line be located here with and safety terminates here with a pole -mounted transformer concerns transformer. transformer must not be accessible to public

164

Corridor 13: Njawara – Minteh Kunda

Distance Location Features Position Approx. Action Proposed by Remarks from of Feature Height/Area the Project Njawara (m) (km) 0.0 Njawara New transmission line pole to RHS LV poles already exist The Proposed Njawara - Minteh be located here but not electrified Kunda line starts here and will run on the RHS of the Road to Minteh Kunda. 3.2 Kerr Ardo Farmlands Locate new poles 6.5 Cheken Farmlands Locate new poles Missira 7.6 Wellingara Farmlands Locate new poles Vegetation/Land use: Farmland sparsely located trees 8.5 Mamri Farmlands Locate new poles Kunda 9.3 Talen Wollof Farmlands Locate new poles 11.4 Kerr Pateh Farmlands Locate new poles 14.0 Road Road Junction to Njonen Tee-off to Njonen; Junction locate new poles 15.8 Road Road Junction to Nawleru Tee-off to Nawleru; Junction locate new poles 10.1 Kerr Jawbeh Farmlands Locate new poles 11.2 Wellingara Farmlands Locate new poles 20.1 Kerr Samba Farmlands Locate new poles Njado 21.2 Kerr Katim Farmlands Locate new poles 22.7 Maida Farmlands Locate new poles 23.8 Minteh New transmission line to be RHS For health and safety The Proposed Njawara – Minteh Kunda located here with transformer concerns transformer Kunda Line terminates here with a must not be accessible pole -mounted transformer. to public

165

Corridor 14: Illiasa – Katchang

Distance Location Features Position Approx. Action Proposed by the Remarks from of Feature Height/Area Project Illiasa (m) (km) 0.0 Illiasa New transmission line pole to RHS To avoid impacts within The Proposed Illiasa - Katchang be located here Illiasa, line will start from line starts here. and will run on the Illiasa to Farafenni road the LHS of the Illiasa – Katchang (approx. 1km east of Illiasa) road. and run through the bush and farmlands for about 2km to Jumansariba. 2.3 Jumansariba Tee-off into Jumansariba 2.9 Jumansariba Transmission connects to the Jumansariba – Katchang road 3.5 Katchang Farmlands Construct poles 3.7 Katchang New transmission line pole to RHS For health and safety The Proposed Illiassa – Katchang be located here with concerns transformer must Line terminates here with a pole transformer not be accessible to public -mounted transformer.

166

Soma Feeder 2 (SF-2) Transmission Line Corridors

Corridor 1: Toniataba – Kolior

Distance from Location Features Position Approx. Action Remarks Toniataba (Km) Of Height/Area Proposed By Feature (M) The Project 0.0 Toniataba Junction New transmission line pole to RHS Locate pole The Proposed Toniataba - Kolior be located here line starts here and will run on the RHS of road from Toniataba - Kolior. 3.5 Jiffin Culvert RHS Across the Avoid Low lying waterway liable to road putting flooding poles in waterway 3.9 Jiffin 3 Mango Trees RHS 5 Trim Possible RAP 4.2 Jiffin Culvert RHS Across the Avoid Low lying waterway liable to road putting flooding poles in waterway 4.3 Kaiaf Group of 2 Mango Trees RHS 5 Trim Possible RAP 4.7 Geniere Mahogany RHS 2 Trim Possible RAP 6.1 Geniere Rice Fields RHS 10 Avoid Low lying waterway liable to putting flooding poles in rice fields 7.1 Geniere Culvert RHS Across the Avoid Low lying waterway liable to road putting flooding poles in waterway 9.7 Yorro Jula Group of 2 Mango Tree Tree 5 Trim Possible RAP 9.9 Kolior New transmission line pole to RHS For health The Proposed Toniataba – Kolior be located here with and safety Line terminates here with a pole - transformer concerns mounted transformer.

167

Distance from Location Features Position Approx. Action Remarks Toniataba (Km) Of Height/Area Proposed By Feature (M) The Project transformer must not be accessible to public

Corridor 2: Kolior – Jasobo

Distance Location Features Position of Approx. Action Proposed by Remarks from Feature Height/ the Project Kolior Area (km) (m) 0.0 Kolior Nyamala New transmission line pole to LHS Along the Brikama – The proposed Kolior - Jasobo line be located here Soma road. starts here and will run on the LHS of transmission line road from Kolior - Jasobo. should run north wards outside the Running behind the villages through villages of Kolior farmlands, the line will Tee-off to Nyamala, Kolior Sula, Kolior Nyamala and Kolior Sula to Jomarr and Jasobo. avoid Kolior Health Center and narrow road into the 2 communities.

After Kolior Sula, the line runs along the road to Jomar and Jasobo 0.2 Kolior Nyamala Kolior Health Centre RHS 12 Avoid putting poles 100mx100m; fenced with cement inside the Health blocks. Centre

168

Distance Location Features Position of Approx. Action Proposed by Remarks from Feature Height/ the Project Kolior Area (km) (m) 0.35 Kolior Kolior Lower Basic School RHS 10 Avoid putting poles Fenced with live Eucalyptus trees, Nyamala inside the school and six of which will be impacted by the avoid felling the line and as such will be trimmed timber trees 0.5 Kolior Nyamala Rice Fields RHS & LHS Across the Avoid putting Pole Low lying waterway liable to flooding road Poles on rice fields 0.8 Kolior Sula Cashew Orchard LHS 2 Trim Cashews along Low lying waterway liable to flooding frontage 0.9 Kolior Sula Group of 2 Mango Trees LHS 3 Trim 2.5 Jomarr Farmlands Construct line on the Line will run outside Jomarr (to the farmlands East of the village) to avoid severe impacts inside the village. Line will thus run through farmlands Jasobo New transmission line to be RHS For health and safety The Proposed Kolior – Jasobo Line located here with transformer concerns transformer terminates here with a pole-mounted must not be transformer. accessible to public

Corridor 3: Kolior – Kwinella

Distance from Location Features Position Approx. Action Proposed by Remarks Kolior of Height/Area the Project (km) Feature (m) 0.0 Kolior New transmission line pole RHS Locate pole The Proposed Kolior -Kwinella pole to be located here line starts here and will run on the RHS of road from Kolior - Kwinella.

169

Distance from Location Features Position Approx. Action Proposed by Remarks Kolior of Height/Area the Project (km) Feature (m) 0.6 Kolior Swamp land RHS 2 Avoid putting poles Low lying swamps liable to in swamps and flooding waterways 2.1 Kolior Group of 5 Mango Trees RHS 4 Trim RAP 2.6 Nema kuta Group of 2 Mango Trees RHS 5 Trim RAP 2.9 Nema kuta Mosque RHS 8 Avoid running line Health and safety concerns across mosque during construction of pole poles and stringing. 3.9 Medina No features impacted RHS 2 5.0 Jiroff Rice fields RHS 10 Avoid putting Pole Low lying waterway liable to Poles on rice fields flooding

7.2 Kundong Cashew RHS 3 Trim RAP 8.4 Nema No features impacted 10.6 Bambako Group of 5 Mango Trees RHS 5 Trim RAP 13.4 Kwinella Mahogany RHS 10 Trim RAP 14.3 Kwinella New transmission line to be RHS For health and The Proposed Kolior – Kwinella located here with safety concerns Line terminates here with a transformer transformer must Pole Pole -mounted not be accessible to transformer. public

170

Corridor 4: Wurokang – Bateling

Distance from Location Features Position Approx. Action Proposed by Remarks Wurokang of Height/ the Project (km) Feature Area (m) 0.0 Wurokang New transmission line pole RHS Locate pole here The Proposed Wurokang - to be located here Bateling line starts here and will run on the RHS of road from Wurokang - Bateling 0.6 Wurokang No features RHS Construct poles Usual Bush/farmland impacted/farmlands within the farmlands 4.5 Bateling New transmission line to be RHS For health and safety The Proposed Wurokang – located here with concerns Bateling Line terminates here transformer transformer must with a pole -mounted not be accessible to transformer. public

Corridor 5: Sankandi – Jali Junction

Distance from Location Features Position of Approx. Height/ Action Proposed by the Remarks Sankandi (km) Feature Area Project (m) 0.0 Sankandi Farmlands RHS Coordinate with Indian MV poles are currently Project/NAWEC being constructed on the RHS along the Sankandi – Jali Junction road by the Indian Project.

171

Distance from Location Features Position of Approx. Height/ Action Proposed by the Remarks Sankandi (km) Feature Area Project (m) It is not clear whether ECOWAS-REAP will connect T&D lines on the pole polesbeing constructed. 3.7 Jifarong No features RHS Usual Bush/farmland impacted/farmlands 5.2 Bajana No features RHS Usual Bush/farmland impacted 11.0 Kulikunda No features RHS Usual Bush/farmland impacted 15.5 Jali Junction Road junction to Jali RHS Tee-off to Jali 15.5 Jali Junction Road junction to LHS Tee-off to Kantong Kunda Kantong Kunda 15.5 Jali Junction Indian Project MV RHS The Proposed Sankandi pole located here – Jali Junction Line terminates here with a pole -mounted transformer.

172

Corridor 6: Jali Junction – Jali Village

Distance Location Features Position Approx. Action Remarks from Jali of Height/ Proposed Junction (km) Feature Area by the (m) Project 0.0 Jali Indian Project RHS Coordinat MV poles are currently Junction MV pole e with being constructed on currently Indian the RHS along the constructed Project/ Sankandi – Jali Junction here NAWEC road by the Indian Project.

It is not clear whether ECOWAS-REAP will connect T&D lines on the poles being constructed. 0.2 Jali Gravel Quarry. Poles Approx. width is must not 75mx75m, be depth over 3m erected within the gulley 0.9 Jali Indian Project RHS For The new proposed Jali MV pole health Junction – Jali line currently and terminates here with a constructed safety pole pole-mounted here concerns transformer. transform er must not be

199

Distance Location Features Position Approx. Action Remarks from Jali of Height/ Proposed Junction (km) Feature Area by the (m) Project accessible to public

Corridor 7: Jali Junction – Keneba

Distance Location Features Position Approx. Action Remarks from Jali of Height/Area Proposed by Junction Feature (m) the Project (km) 0.0 Jali Junction New RHS Locate pole The Proposed Jali transmission here Junction - Keneba line pole to be line starts here and located here will run on the RHS of road from Jali Junction - Keneba. 5.1 Keneba Medical LHS Though not on the Research same trajectory as Council the new MV line, health and safety concerns need to be addressed during construction of poles and stringing. 5.8 Keneba Keneba Upper RHS 7 Chain link fence Basic School 200mx100m; Health and safety concerns

200

Distance Location Features Position Approx. Action Remarks from Jali of Height/Area Proposed by Junction Feature (m) the Project (km) during construction of poles. 6.0 Keneba Indian Project RHS 5 Indian transmission MV pole line terminates here located here 6.0 Keneba Indian Project RHS Coordinate The Indian MV line with Indian transmission Line terminates here Project/ from Sankandi – NAWEC on Keneba Line way forward terminates here with a pole mounted transformer.

Corridor 8: Keneba – Kemoto

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Keneba Feature Area the Project (km) (m) 0.0 Keneba New RHS The Indian The Proposed Keneba - Kemoto line transmission Project MV from starts here and will run on the RHS of line pole to Sankandi – road from Keneba - Kemoto. be located Keneba. here Coordinate with Indian Project/NAWEC

201

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Keneba Feature Area the Project (km) (m) 5.3 Keneba New LHS Tee-off to the transmission Karantaba - line pole to Burong road be located here

6.4 Keneba New RHS Line turns right The line will run through farmlands transmission and runs on the line pole to eastern side and be located behind all the here villages to connect to the Karantaba- Kemoto road 5.8 Manduar Forestry RHS 5 Health and Office. Chain safety concerns link fence during 200mx100m construction of Pole Poles. 6.3 Manduar Group of 5 RHS 3 Trim RAP Mango Trees 10.4 Kunyang Kunyang RHS 6 Construct pole Safety concerns during construction Lower Basic at least 5m from of poles. School. nearest class Unfenced room 15.5 Karantaba No features Usual Bush/farmland impacted 18.8 Bush No features Usual Bush/farmland Town impacted

202

Distance Location Features Position Approx. Action Remarks from of Height/ Proposed by Keneba Feature Area the Project (km) (m) 19.4 Janneh No features Usual Bush/farmland Kunda impacted 25.5 Kemoto Indian RHS Coordinate with The Proposed Keneba – Kemoto Line Project MV Indian terminates here with a pole - pole pole Project/NAWEC mounted transformer. evident

203

Corridor 9: Karantaba – Burong

Distance from Location Features Position Approx. Action Proposed Remarks Karantaba (km) of Height/Area by the Project Feature (m) 0.0 Karantaba New transmission line pole to RHS The Proposed Karantaba - be located here Burong line starts here and will run on the RHS of road from Karantaba – Burong 0.4 Karantaba New transmission line pole to LHS Line turns left to join Line along be located here Manduar to Karantaba Road 3.2 Jula Kunda No features impacted Usual Bush/farmland 3.6 Burong New transmission line to be RHS For health and The Proposed Jali Junction – Jali located here with pole - safety concerns Line terminates here with a pole mounted transformer transformer must -mounted transformer. not be accessible to public

Corridor 10: Manduar – Tankular

Distance from Location Features Position Approx. Action Proposed Remarks Manduar (km) of Height/Area by the Project Feature (m) 0.0 Manduar New transmission line pole to RHS The Proposed Manduar - be located here Tankular line starts here and will run on the RHS of road from Manduar – Tankular 2.5 Manduar Tributary Across the road Avoid putting poles Low lying waterway liable to close to the flooding tributary

204

Distance from Location Features Position Approx. Action Proposed Remarks Manduar (km) of Height/Area by the Project Feature (m) 7.2 Tankular New transmission line to be RHS For health and The Proposed Manduar – located here with pole - safety concerns Tankular Line terminates here mounted transformer transformer must with a pole -mounted not be accessible to transformer. public

205

Soma Feeder 3 (SF-3) Transmission Line Corridors

Corridor 1: Brikamaba – Tabanding

Distance from Location Features Position Approx. Action Proposed by Remarks Brikamaba (km) of Height/ the Project Feature Area (m) 0.0 Brikamaba New transmission line pole LHS The Proposed Brikamaba - to be located here Tabanding line starts here and will run on the LHS of the Brikamaba - Tabanding Road. 0.2 Brikamaba Group of Mangoes LHS 2 Trim 0.3 Brikamaba Row of 5 private compounds LHS 2 Avoid putting poles Each of the compounds measures inside the approx. 50x35m fenced with compounds cement blocks. RAP?? Brikamaba 2 Mango Trees LHS 2 Trim 3.5 Boiram Private compound LHS 2 Avoid putting poles Measures 50mx50m; fenced with inside the cement blocks. Usual compound Bush/farmland 4.0 Boiram Road junction to Fass Abdou LHS Run a Tee-off to Fass Abdou 4.0 Boiram Road junction to Njoben RHS Run a Tee-off to Njoben 5.5 Tabanding Cashew Plantation LHS 3 Trim Cashews on frontage 6.3 Tabanding New transmission line to be LHS For health and The Proposed Brikamaba – located here with pole safety concerns Tabanding Line terminates here mounted transformer transformer must with a pole -mounted not be accessible to transformer. public

206

Corridor 2: Mamutfana Junction – Mamutfana Village

Distance from Location Features Position Approx. Action Proposed by Remarks Mamutfana (km) of Height/ the Project Feature Area (m) 0.0 Mamutfana New transmission line pole LHS The Proposed Mamutfana Junction Junction (along to be located here - Mamutfana line starts here and Soma – Basse will run on the LHS of the Road) Mamutfana Junction - Mamutfana Road. 1-3 Mamutfana Private compound LHS 5 Avoid putting poles 43mx30m and fenced with cement inside the blocks. compound 1.5 Mamutfana New transmission line to be LHS Erect transformer The Proposed Mamutfana junction located here with pole here; Distribution – Mamutfana Line terminates here mounted transformer lines already exist with a pole -mounted transformer. within the village.

For health and safety concerns transformer must not be accessible to public

207

Corridor 3: Jareng – Choya

Distance from Location Features Position Approx. Action Proposed by Remarks Jareng (km) of Height/ the Project Feature Area (m) 0.0 Jareng New transmission line pole RHS The Proposed Jareng - Choya line to be located here starts here and will run on the RHS of the Basse – Soma Road. 0.1 Jareng Bus Stop RHS Health and safety concerns during construction of poles and stringing. 0.11 Jareng Mango Tree RHS 5 Trim RAP? Jareng Group of 6 Mangoes RHS 7 Trim 0.18 Jareng Jareng Lower Basic School RHS 10 70mx70m; Fenced with cement blocks. Health and safety concerns during construction of poles. 0.6 Jareng Wetland Area Across the corridor Avoid putting Pole Low lying waterway liable to Poles on wetland Area flooding 0.6 Jareng Culvert RHS Across Avoid putting Pole Low lying waterway liable to the road Poles on waterway flooding RAP??? Kumbanye Group of 4 Mangoes RHS 3 Trim 2.9 Kumbanye Group of 6 Mangoes RHS 7 Trim 3.4 Kumbanye Wetland Area Across Avoid putting Pole Low lying waterway liable to the Poles on wetland Area flooding road 3.4 Kumbanye Culvert Avoid putting Pole Low lying waterway liable to Across the road Poles on waterway flooding 3.9 Kumbanye Neem Tree RHS 2 Trim 4.0 Dalaba Group of 3 Mangoes RHS 4 Trim

208

Distance from Location Features Position Approx. Action Proposed by Remarks Jareng (km) of Height/ the Project Feature Area (m) 9.7 Choya New transmission line to RHS For health and safety The Proposed Jareng – Choya be located here with pole concerns transformer Line terminates here with a pole mounted transformer must not be accessible -mounted transformer. to public

Corridor 4: Choya – Mali Kunda

Distance Location Features Position of Approx. Action Proposed by the Remarks from Choya Feature Height/Area Project (km) (m) 0.0 Choya New transmission line pole to RHS The Proposed Choya- Mali be located here Kunda line starts here and will run on the RHS of the Choya – Mali Kunda road 0.0 Choya Group of 2 Mangoes RHS 7 Trim 1.4 Choya Cashew Tree RHS 5 Trim 3.5 Pinai No features impacted Usual Bush/farmland 4.7 Katamina No features impacted Usual Bush/farmland 6.0 Mali Eucalyptus RHS 2 Avoid Kunda 6.3 Mali New transmission line to be RHS For health and safety The Proposed Choya – Mali Kunda located here with pole concerns transformer Kunda Line terminates here with mounted transformer must not be accessible a pole -mounted transformer. to public

209

Corridor 5: Mali Kunda – Dankunku

Distance Location Features Position of Approx Action Proposed by the Remarks from Mali Feature Height/ Project Kunda Area (km) (m) 0.0 Mali Kunda New transmission line pole RHS The Proposed Mali Kunda - to be located here Dankunku line starts here and will run on the RHS of the Mali Kunda - Dankunku Road via Sambang Wollof. 0.02 Mali Kunda Private compound RHS 1 Avoid putting Pole Poles 30mx25m and fenced with inside compound cement blocks. 0.2 Mali Kunda Mud block house RHS 2 Avoid stringing the line 6mx5m of mud block walls over the house 1.3 Demba Kunda No features impacted RHS Usual Bush/farmland 1.5 Jamwelly No features impacted RHS Usual Bush/farmland 2.7 Sambang Fula No features impacted RHS Usual Bush/farmland 3.3 Sambang No features impacted RHS Usual Bush/farmland Wollof 4.2 Buniadu Cashew Plantation RHS Usual Bush/farmland 4.8 Sare Leffa Group of Mangoes RHS Usual Bush/farmland 6.9 Dankunku New transmission line to be RHS For health and safety The Proposed Mali Kunda– located here with pole concerns transformer Dankunku Line terminates here mounted transformer must not be accessible to with a pole -mounted public transformer.

Corridor 6: Dankunku – Koli Kunda

210

Distance Location Features Position of Approx. Action Proposed by the Remarks from Feature Height/ Project Dankunku Area (km) (m) 0.0 Dankunku New transmission line pole RHS Run line behind (west) of The Proposed Dankunku - Koli to be located here the communities along Kunda line starts here the farmlands to Koli Kunda 0.8 Nyani Kunda No features impacted Vegetation/Land use mainly Shrubs/farmlands 1.6 Touba No features impacted Vegetation/Land use mainly Shrubs/farmlands 2.7 Borehole No features impacted Vegetation/Land use mainly Shrubs/farmlands 5.0 Babou Jobe No features impacted Vegetation/Land use mainly Shrubs/farmlands 7.1 Sare Lien No features impacted Vegetation/Land use mainly Shrubs/farmlands 8.6 Kabangbang No features impacted Vegetation/Land use mainly Shrubs/farmlands 10.5 Jawula No features impacted Vegetation/Land use mainly Shrubs/farmlands 11.6 Sare Saidou No features impacted Vegetation/Land use mainly Shrubs/farmlands 11.9 Pappa No features impacted Vegetation/Land use mainly Shrubs/farmlands 16.3 Koli Kunda New transmission line to RHS For health and safety The Proposed Dankunku – Koli be located here with pole concerns transformer Kunda Line terminates here mounted transformer must not be accessible to with a pole -mounted public transformer.

211

212

Corridor 7: Borehole – Jesadi Tenda

Distance Location Features Position of Approx. Action Proposed by the Remarks from Feature Height/ Project Borehole Area (km) (m) 0.0 Borehole New transmission line RHS Construct poles The Proposed Borehole - Jesadi pole to be located here following the road Tenda line starts here. alignment to Jesadi Tenda on RHS of the gravel road. 1.9 Sey Kunda No features impacted Vegetation/Land use mainly Shrubs/farmlands 5.2 Jesadi No features impacted Vegetation/Land use mainly Shrubs/farmlands 6.1 Ifra No features impacted Vegetation/Land use mainly Shrubs/farmlands 7.4 Jesadi Tenda Wetland Area Avoid putting Poles in Low lying waterway liable to Across the Road wetland Area flooding 8.9 Jesadi Tenda New transmission line to RHS For health and safety The Proposed Borehole – Jesadi be located here with pole concerns transformer Tenda Line terminates here with mounted transformer must not be accessible a pole -mounted transformer. to public

Corridor 8: Pakaliba – Jalanbereh

Distance from Location Features Position Approx. Action Proposed by Remarks Pakaliba (km) of Height/ the Project Feature Area (m) 0.0 Pakaliba New transmission line pole RHS Locate pole here The Proposed Pakaliba - to be located here Jalanbereh line starts here and

213

Distance from Location Features Position Approx. Action Proposed by Remarks Pakaliba (km) of Height/ the Project Feature Area (m) will run on the RHS of the Basse to Soma. 0.3 Pakaliba Mango Tree RHS 7 Trim 0.32 Pakaliba Bus Stop RHS Health and safety concerns during construction of poles and stringing. 0.4 Pakaliba Group of 3 Eucalyptus Trees RHS 5 Avoid 0.5 Pakaliba Neem Tree RHS 5 Avoid 0.51 Pakaliba Pakaliba Basic Cycle School RHS 8 Exercise caution due 100mx100m; Fenced with to health and safety cement blocks. concerns during construction of poles. 0.6 Pakaliba Football field RHS 9 Avoid putting poles Unfenced 100mx100m on football field 1.8 Pakaliba Pakaliba Rossi Clinic RHS 12 Avoid putting poles 100mx100m; fenced with inside the clinic cement blocks. 3.1 Pakaliba Private compound RHS 6 Avoid putting poles 50mx35m and fenced with inside compound cement blocks. 3.2 Pakaliba Bus Stop RHS Health and safety concerns during construction of poles and stringing. 3.2 Pakaliba Row of 3 Mango Trees RHS 5 Avoid 15.3 Wellingaraba No features impacted. A RHS Avoid loumo site. Run From the loumo site in busy loumo site line north, behind the Wellingaraba towards loumo site beginning Dongoroba, there is wide at km 15.3; Pass line expanse of water body to be behind Dongoroba avoided and continue to km 29 in Jalanbereh

214

Distance from Location Features Position Approx. Action Proposed by Remarks Pakaliba (km) of Height/ the Project Feature Area (m) 24.2 Dongoroba No features impacted RHS Line will run outside Dongoroba (North East of the village) to avoid severe impacts inside the village 29.6 Jalangbereh New transmission line to be RHS For health and safety The Proposed Pakaliba – located here with pole concerns transformer Jalangbereh Line terminates mounted transformer must not be here with a pole -mounted accessible to public transformer.

Corridor 9: Darsilami – Sutukung

Distance from Location Features Position Approx. Action Proposed by Remarks Darsilami of Height/ the Project (km) Feature Area (m) 0.0 Darsilami New transmission line pole LHS The proposed Darsilami - to be located here Sutukung line starts here and will run on LHS of the Darsilami – Sutukung road. 2.0 Darsilami Row of 5 mango Trees RHS 3 Trim Big spread would reach the proposed Line even though it’s on the RHS. 2.3 Darsilami Mango Tree RHS 3 Trim Big spread would reach the proposed Line even though it’s on the RHS. 3.5 Barrow Kunda Mango Tree LHS 3 Avoid

215

Distance from Location Features Position Approx. Action Proposed by Remarks Darsilami of Height/ the Project (km) Feature Area (m) 4.6 Sutukung New transmission line to be RHS For health and safety The proposed Darsilami – located here with pole concerns transformer Sutukung line terminates here mounted transformer must not be accessible with a pole -mounted to public transformer.

Corridor 10: Wellingaraba – Bureng

Distance from Location Features Position Approx. Action Proposed by Remarks Wellingaraba of Height/ the Project (km) Feature Area (m) 0.0 Wellingaraba To avoid loumo site, run the line north, behind the loumo site beginning at km 15.3 from Pakaliba 0.3 Wellingaraba New transmission line pole RHS The Wellingaraba line to be located here to Bureng starts at approx. 300m from the junction and runs on RHS of the road. 1.9 Bureng Proposed transmission line LHS Line turns left and runs on LHS pole of the road 2.6 Bureng New transmission line to be RHS For health and safety The Proposed Wellingaraba – located here with pole concerns transformer Bureng Line terminates here mounted transformer must not be accessible with a pole -mounted to public transformer.

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Soma Feeder 4 (SF-4) Transmission Line Corridors

Corridor 1: Kunjo – Numu Kunda

Distance from Location Features Position Approx. Action Proposed by Remarks Kunjo (km) of Height/ the Project Feature Area (m) 0.0 Kunjo (along New transmission line pole RHS The Proposed Kunjo - Numu Farafenni – to be located here Kunda line starts here and will Laminkoto Road) run on the RHS of the road corridor between Kunjo and Numu Kunda. 1.3 Numu Kunda New transmission line to be RHS For health and safety The Proposed Kunjo – Numu located here with pole concerns transformer Kunda Line terminates here with mounted transformer must not be a pole -mounted transformer. accessible to public

Corridor 2: Sabach Sukoto – Mballow Omar Tega

Distance from Location Features Position Approx. Action Proposed by Remarks Sabach Sukoto of Height/Area the Project (km) Feature (m) 0.0 Sabach Sukoto New transmission line pole LHS The Proposed Sabach Sukoto - to be located here Mallow Omar Tega line starts here and will run on the LHS of the Sabach Sukoto - Mballow Omar Tega Road corridor. 0.2 Sabach Sukoto Unfenced Football field LHS 2 Avoid putting poles Unfenced 150mx150m on football field 0.3 Sabach Poll No features impacted Usual Bush/farmland

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Distance from Location Features Position Approx. Action Proposed by Remarks Sabach Sukoto of Height/Area the Project (km) Feature (m) 0.6 Sabach Njieyen No features impacted Usual Bush/farmland 1.3 Taiba No features impacted Usual Bush/farmland 3.1 Kataba Group of Mangoes LHS 3 Trim Mangoes belong to Sulay Sabally Mandinka 3.4 Kataba Group of Mangoes LHS 2 Trim Mangoes belong to Jereh Sabally Mandinka Sabally 4.0 Kataba Cashew Plantation LHS 2 Trim Cashew Plantation belong to Mandinka Jerreh Sabally 4.2 Tambakoto Group of Mangoes LHS 2 Trim Mangoes belong to Pap Faal 4.8 Tambakoto Group of Cashew Trees LHS 5 Trim Owner unknown 5.5 Tambakoto Group of Cashew Trees LHS 5 Trim Owner unknown 6.4 Tambakoto Group of Cashew Trees LHS 7 Trim Owner unknown 9.7 Basik Group of Mangoes LHS 10 Trim Mangoes belong to Samba Topp 10.1 Dibba Kunda Poll Gully RHS 8 Avoid putting poles close to Gully 10.3 Dibba Kunda Poll Gully LHS 1.1 Avoid putting poles close to Gully 14.0 Dibba Kunda Poll Bridge across Water body Across Bridg= Avoid putting poles the 12.8m wide close to the water Water body Gully body 18.9 Kerr Bamba No features impacted Usual Bush/farmland 19.3 Njaien No features impacted Usual Bush/farmland 19.5 Ndowen No features impacted Usual Bush/farmland 21.2 Lowen No features impacted Usual Bush/farmland 23.0 Mballow Omar New transmission line to LHS For health and safety The Proposed Sabach Sukoto - Tega be located here with pole concerns Mallow Omar Tega Line mounted transformer transformer must not terminates here with a pole - mounted transformer.

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Distance from Location Features Position Approx. Action Proposed by Remarks Sabach Sukoto of Height/Area the Project (km) Feature (m) be accessible to public

Corridor 3: Arafat Junction – Arafat Village

Distance from Location Features Position of Approx. Action Proposed by Remarks Arafat Junction Feature Height/ the Project (km) Area (m) 0.0 Arafat Junction New transmission line LHS Tee-off to Arafat The Proposed Arafat Junction - (along Farafenni pole to be located here Arafat line starts here and will run – Laminkoto on the LHS of the Arafat Junction Road) - Arafat Road. 0.2 Arafat New transmission line to LHS For health and The Proposed Arafat Junction - be located here with pole safety concerns Arafat Line terminates here with mounted transformer transformer must a pole -mounted transformer. not be accessible to public

Corridor 4: Kaur – Kerr Maila village

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Distance from Location Features Position of Approx. Action Proposed by Remarks Kerr Kaur (km) Feature Height/ the Project Area (m) 0.0 Kaur New transmission line LHS Tee-off to Kerr The Proposed Kaur - Kerr Maila pole to be located here Maila line starts here and will run on the LHS of the Kaur - Kerr Maila road. 3.3 Kerr Maila/Kerr Road Junction to Nema LHS Tee-off to Nema Samba Sira Birom Bah Birom Bah 3.4 Kerr Maila/Kerr New transmission line to LHS For health and The Proposed Kaur - Kerr Maila Samba Sira be located here with pole safety concerns Line terminates here with a mounted transformer transformer must pole -mounted transformer. not be accessible to public

Corridor 5: Kaur – Njau Sawalo

Distance from Location Features Position Approx. Action Proposed by Remarks Kaur (km) of Feature Height/Area the Project (m) 0.0 Kaur New transmission line pole LHS Run line along the The Proposed Kaur - Njau Sawalo to be located here road alignment line starts here and will run on the LHS of the Kaur - Njau Sawalo Road. 0.6 Kaur Road junction to Kerr LHS Run a Tee-off to Kerr Samba Sira Samba Sira 1.6 Kerr Kossa No features impacted Run line along the Usual Bush/farmland road alignment 6.3 Taiba No features impacted Run line along the Usual Bush/farmland road alignment 10.8 Njoben No features impacted Run line along the Usual Bush/farmland road alignment

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Distance from Location Features Position Approx. Action Proposed by Remarks Kaur (km) of Feature Height/Area the Project (m) 11.6 Kerr Mod Hali No features impacted Run line along the Usual Bush/farmland road alignment Njau Sawalo New transmission line to be LHS Run a Tee-off to Njau The Proposed Kaur - Njau Sawalo located here with pole Sawalo Line terminates here with a pole - mounted transformer mounted transformer. For health and safety concerns transformer must not be accessible to public

Corridor 6: Njau Sawalo – Carrols Wharf

Distance from Location Features Position Approx. Action Proposed by Remarks Njau of Feature Height/Area the Project Sawalo(km) (m) 0.0 Njau Sawalo New transmission line pole LHS Tee-off to Carrols The Proposed Njau Sawalo - to be located here Wharf; Carrols Wharf line starts here and Run line along the will run on the LHS of the Njau road alignment Sawalo - Carrols Wharf Road. 0.3 Stream Culvert and stream Across the road Avoid putting poles Low lying area liable to flooding close to the stream 2.2 Gui Jahanka Road junction to Bati Yonga LHS Run a Tee-off to Bati Yonga 7.2 Bati Ndar Culvert Across the road Avoid putting poles Low lying area liable to flooding close to the Lowland area

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Distance from Location Features Position Approx. Action Proposed by Remarks Njau of Feature Height/Area the Project Sawalo(km) (m) 7.4 Bati Ndar Culvert/swamps Across the road Avoid putting Pole Low lying area liable to flooding Poles close to the swamps 7.7 Bati Ndar Road junction to Conteh LHS Run a Tee-off to Conteh 9.8 Chamen New transmission line to LHS For health and safety Line turns left to run west of be located here with pole concerns Sitakoto mounted transformer transformer must not be accessible to public

Run line along the road alignment to Sitakoto 10.6 Sitakoto Wetland area Across the road Avoid putting poles Low lying area liable to flooding close to the wetland area 11.5 Carol Wharf New transmission line to be LHS For health and safety The Proposed - Njau Sawalo – located here with pole concerns Carrol Wharf Line terminates mounted transformer transformer must not here with a pole -mounted be accessible to transformer. public

Corridor 7: Chamen – Nyanga bantang

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Distance from Location Features Position Approx. Action Proposed by Remarks Chamen of Feature Height/Area the Project (km) (m) 0.0 Chamen New transmission line to LHS From Chamen, run The Proposed Chamen - Nyanga be located here with pole the poles behind bantang line starts here and will mounted transformer (north) the run to Nyanga bantang. communities through farmlands to Nyanga bantang 0.2 Sare Alfa No features impacted Usual Bush/farmland 5.8 Paleleh No features impacted Usual Bush/farmland Sinchu Alfa No features impacted Usual Bush/farmland Sare Sidi No features impacted Usual Bush/farmland Sare Janko No features impacted Usual Bush/farmland Buduk No features impacted Usual Bush/farmland Ngeden No features impacted Usual Bush/farmland Kerr Batch No features impacted Avoid the stone Usual Bush/farmland circles- stay away from the fence for at least 200m Mbayen No features impacted Usual Bush/farmland Buram Sinch Ngedi No features impacted Usual Bush/farmland Kerr Jabel No features impacted Usual Bush/farmland Sinch Badu No features impacted Usual Bush/farmland Sinchu Alasan No features impacted Usual Bush/farmland Kucha No features impacted Usual Bush/farmland 20.6 Nyanga New transmission line to LHS For health and safety The Proposed Chamen - Nyanga bantang be located here with pole concerns bantang Line terminates here mounted transformer transformer must not with a pole -mounted be accessible to transformer. public

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Corridor 8: Nyanga Bantang – Njau Sawalo

Distance from Location Features Position Approx. Action Proposed by Remarks Nyanga Bantang of Feature Height/Area the Project (km) (m) 0.0 Nyanga loumo Site RHS 4 New line starts Health and safety concerns during bantang exactly at the loumo construction of poles Stalls and site and will run on market structures located by the the RHS of the road roadside will be impacted. corridor to Njau Sawalo 0.1 Nyanga Market/loumo site. RHS 10 Health and safety bantang 100mx100m unfenced. concerns during construction of poles. 0.2 Nyanga PIU Station. 100mx100m RHS 8 Health and safety bantang unfenced concerns during construction of poles. 0.3 Nyanga Culvert and swampy area Across the road Avoid putting poles Low lying area liable to flooding bantang on Swamps. 0.4 Nyanga Culvert and water body Across the road bantang Use poles/distances to avoid stream and swampy area 13.8 Panchang Culvert and water body Across the road Avoid putting poles Low lying area liable to flooding on Swamps.

Use poles/distances to avoid stream and swampy area

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Distance from Location Features Position Approx. Action Proposed by Remarks Nyanga Bantang of Feature Height/Area the Project (km) (m) 15.1 Panchang Market/loumo site. RHS 4 Health and safety To avoid market/loumo site line 100mx100m unfenced. concerns during runs behind the market to the construction of north. poles. 15.4 Panchang Proposed transmission line RHS Line turns left to run pole along the road corridor after the market/loumo site 23.5 Njau Sawalo Proposed transmission line RHS Line turns left to run pole on the north outside Njau Sawalo Primary School 11.5 Njau Sawalo New transmission line to RHS For health and safety The Proposed Nyanga bantang – be located here with pole concerns Njau Sawalo Line terminates here mounted transformer transformer must with a pole -mounted not be accessible to transformer. public

Corridor 9: Nyanga bantang – Wassu

Distance from Location Features Position Approx. Action Proposed by Remarks Nyanga of Feature Height/Area the Project Bantang (m) (km) 0.0 Nyanga bantang Proposed Transmission LHS New line starts Health and safety concerns during Line Pole Pole exactly at the loumo construction of poles. Stalls and site and will run on market structures located by the the LHS of the road roadside will be impacted corridor to Wassu

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Distance from Location Features Position Approx. Action Proposed by Remarks Nyanga of Feature Height/Area the Project Bantang (m) (km)

0.1 Nyanga bantang Soto Tree LHS 5 Avoid 0.2 Nyanga bantang Neem Tree LHS 8 Avoid 1.3 Nyanga bantang Baobab LHS 10 Avoid 2.7 Nyangen Neem Tree LHS 3 Avoid 4.3 Njoben Row of 2 shops LHS 3 Avoid running Line Belong to Arona Jallow and Yaya over the Shops Jobe 4.4 Njoben Kungel Garage/Taxi Park. LHS 4 Health and safety Health and safety concerns during Unfenced concerns during construction of Pole Poles. construction of Pole Poles. 8.9 Firdawsy No features impacted Usual Bush/farmland 15.4 Ndokeh No features impacted Usual Bush/farmland 17.3 Sinchu Jenung Private house LHS 6 Avoid running Line over the House 18.5 Madina Proposed transmission LHS Line turns to the right and runs line pole RHS 18.8 Wassu Welding Workshop RHS 3 Avoid running Line Belongs to Ebrima Babu; Length = 20m over the workshop Workshops will be impacted during line construction. Health and safety concerns during construction of poles. Wassu Welding Workshop RHS 3 Avoid running Line Belongs to Momodou Cham; Length = 20m over the workshop Workshops will be impacted during line construction. Health and safety concerns during construction of poles. Wassu Carpentry Workshop RHS 3 Avoid running Line Belongs to Sheikh Ndure; Length = 20m over the workshop Workshops will be impacted

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Distance from Location Features Position Approx. Action Proposed by Remarks Nyanga of Feature Height/Area the Project Bantang (m) (km) during line construction. Health and safety concerns during construction of poles. Wassu Carpentry Workshop RHS 3 Avoid running Line Belongs to Omar Touray; Length = 20m over the workshop Workshops will be impacted during line construction. Health and safety concerns during construction of poles. Wassu Welding Workshop RHS 3 Avoid running Line Belongs to Juldeh Jallow; Length = 20m over the workshop Workshops will be impacted during line construction. Health and safety concerns during construction of Poles. 19.0 Wassu Proposed transmission RHS Line turns left to connect to line pole existing MV line from Basse/Bansang Wassu New transmission line RHS For health and The Proposed Nyanga bantang – pole to be located here safety concerns Wassu Line terminates here with a with pole mounted transformer must pole -mounted transformer. transformer not be accessible to public

Corridor 10: Palang – Kataba

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Distance from Location Features Position Approx. Action Proposed by the Remarks Palang of Height/Area Project (km) Feature (m) 0.0 Palang Proposed Transmission LHS The Proposed Palang - Line Pole Pole Kataba line starts here (approx. 100m. north of the road) and will run on the LHS of the Palang - Kataba Road through mainly farmland Palang Toro No features impacted Usual Bush/farmland Kuyarang No features impacted Usual Bush/farmland 11.5 Kataba New transmission line to LHS For health and safety The Proposed Palang – Kataba be located here with pole concerns transformer Line terminates here with a pole mounted transformer must not be accessible -mounted transformer. to public

Corridor 11: Kuntaur Fula Kunda – Barajally Tenda

Distance from Location Features Position of Approx. Action Proposed by the Remarks KTR Fula Kunda Feature Height/Area Project (km) (m) 0.0 Kuntaur Fula Proposed transmission LHS The proposed Kuntaur Usual Bush/farmland Kunda line pole Fula Kunda - Barajally 4.3 Touba Kuta Tenda line starts here and will run on LHS along the existing MV Line up to Sukuta (approx. 100m. north of the road). 7.5 Sukuta No features impacted Existing MV Line from Kuntaur Fula Kunda ends

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Distance from Location Features Position of Approx. Action Proposed by the Remarks KTR Fula Kunda Feature Height/Area Project (km) (m) here and proposed new Line to Barajally Tenda starts here. 8.7 Barajally Suba Proposed transmission Run line behind the Usual Bush/farmland line pole along the same trajectory (through farmlands) as the existing line from KTR Fula Kunda 9.2 Barajally Tenda New transmission line to LHS For health and safety The Proposed Kuntaur Fula be located here with pole concerns transformer Kunda – Barajally Tenda mounted transformer must not be accessible to Line terminates here with a public pole -mounted transformer.

Corridor 12: Kaleng Jawbeh – Bush Town

Distance from Location Features Position Approx. Action Proposed by the Remarks Kaleng Jawbeh of Feature Height/Area Project (km) (m) 0.0 Kaleng Jawbeh Proposed transmission ine RHS The proposed Kaleng A bye-pass has already pole Jawbeh - Bush Town line been created on the RHS starts here and will run on by the road construction RHS of the Kaleng Jawbeh team. It runs through - Bush Town road (under farmlands up to the river construction). side in Bush Town. Thus, the line will run along the bye-pass 1.4 Jalokoto Road junction to Yona RHS Run a Tee-off to Yona 2.4 Kunting No features impacted Vegetation/Land use mainly Shrubs/farmlands

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Distance from Location Features Position Approx. Action Proposed by the Remarks Kaleng Jawbeh of Feature Height/Area Project (km) (m) 10.1 Road junction to Tankong RHS Run a Tee-off to Tankong Kunda Kunda 15.6 Dobo No features impacted Vegetation/Land use mainly Shrubs/farmlands 15.6 Bush Town Temporary Project Camp LHS 25 Parking and maintenance (ARESKI Roads Construction site for trucks; land area Company) and a gravel cleared for trucks’ Quarry for roads parking –about 100m, construction and thus potential cumulative impact 16.3 Bush Town New transmission line to RHS For health and safety The Proposed Kaleng be located here with pole concerns transformer Jawbeh – Bush Town Line mounted transformer must not be accessible to terminates here with a public pole -mounted transformer.

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Appendix 4.3: Chance Find Procedures

This Chance Find Procedure shall be applied in case previously unknown culturally valuable materials are unexpectedly discovered during the implementation of the Project: • In the case of chance find of any material with possible archaeological, historical, paleontological, religious, or other cultural value, all work at and around the find, feature or site must immediately stop.

• The discovery will be clearly demarcated and secured from unauthorized access, and all found remains will be left where they were found. If necessary, artefacts will be protected and measures to stabilize the area will be implemented.

• Notify the Project Manager/PCU of the findings who in turn will immediately notify the National Council for Arts and Culture for the necessary, assessment, recording and determine the next course of action.

• Restart construction and public works only upon authorization of the relevant authorities (the National Council for Arts and Culture under the Ministry of Tourism and Culture).

• Relevant findings will be recorded in the Banks’ supervision reports.

• These procedures must be referred to as standard provisions in construction contracts.

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Appendix 5.1: Summary of Comments and Views expressed at the Consultations

Communities/Venues Dates Introduction and objectives of ECOWAS-REAP Demba Holle - NBR 31/01/20 The lead Consultant introduced the team, including Tambakoto - NBR 01/02/20 the NAWEC team of experts who were also part of Sinchu Alhaji – CRR -S 03/02/20 the field exercises. Mbankam - NBR 29/02/20 Jurunku - NBR 29/02/20 The Consultant took time to share valuation Tambana - NBR 01/03/20 information on matters surrounding the field trips, Katchang - NBR 01/03/20 consultations with the communities, project Chamen – CRR-N 02/03/20 background, processes and procedures as well as the Bush Town – CRR-N 03/03/20 role of the communities and institutions during the Dankunku – CRR -S 04/03/20 implementation of the Project. Kolior ??? National Regulatory Institutions He gave a brief background of the ECOWAS-REAP; National Water and Electricity ??? that it is an IDA/World Bank funded regional project Company meant to enhance electricity access to ECOWAS Governor’s Office, LRR 05/03/20 member countries. He informed the meetings that Department of Parks and 10/03/20 the OMVG Energy Project is currently building an Wildlife Management electricity substation in Soma, LRR; that ECOWAS- National Roads Authority 10/03/20 REAP will connect from these two sub stations to Department of Forestry 11/03/20 provide electricity to rural and peri-urban National Environment Agency 11/03/20 communities 100km radius of the substations via MV National Council for Arts and 11/03/20 (30kV) and LV (400V) infrastructure. Culture This means therefore, that the lines will pass through Consultant’s Opening Remarks communities, feeder roads, farmlands, bushes/shrubs, protected areas such as forests, parks and cultural heritage sites. He informed the gathering that as part of the assessment, the routing of the lines is being done collectively with the NAWEC team, and the objective is to avoid or minimize environmental

and social impacts as much as possible. Where

impacts are inevitable, the assessment shall be carried out to ensure that the appropriate mitigation measures are recommended and implemented. If compensation is required, the affected families shall be consulted adequately before the compensation is done.

He concluded by saying that once implemented, the Project will contribute to improving the livelihoods of the people in many ways.

Rationale of the Public Consultations

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The Consultant informed the meetings that the rationale for the public consultations is for information sharing with Project beneficiaries; to seek their opinion, learn from their experiences of past projects, hear their concerns and fears to help in better planning of the ECOWAS-REAP activities.

From the consultations an ESIA report will be developed with an ESMP to address the potential negative environmental and social impacts that may be caused by the Project.

Remarks, Comments by Project beneficiaries Location Comments/Views Demba Holleh - NBR Stakeholders highly appreciate and welcome the Project and highlighted: • The importance of electricity for the lives and livelihood of the people

• The numerous benefits they will get from the availability of electricity Tamba Koto - NBR The Project is highly appreciated because: • It will help them preserve and store their foodstuff

• It will enable them to engage in new revenue-earning businesses that will raise their standards of living Mbankam - NBR • Villagers expressed appreciation for this public consultation and welcomed the advent of the project.

• They further lamented that the community of Mbamkam continues to experience various challenges in their livelihoods due to the lack of power supply

• It was noted that lack of power supply is responsible for the problems relating to the operation of the village borehole, and recognized that once the village gets power this problem will be resolved

• Lack of power supply in the village was described as deplorable as fishermen are not able to preserve their catch, and therefore, experience a lot of revenue losses as the excess of the catch perishes

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Jurunku - NBR • Community expressed its delight with the Project and opined that the availability of power supply will lead to increased economic activities as petty businesses will thrive and the people will experience improvements in their livelihoods.

• They further hailed the advent of the Project as the availability of power supply will help the community to preserve cooked food, fish, meat etc. It was confirmed that the community discards a lot of food, fish, and meat especially during Muslim festivals like Tobaski as the excess meat/mutton cannot be preserved. During the Month of Ramadan, the community buys ice blocks at D50 and this drains their income.

• There is a health post in the village; but due to the lack of power supply, challenges related to the storage of supplies continue to be faced and put a strain on overall operation. Equipment that are operated by electricity in the health facility are lying idle.

• On experiences with previous project consultations, it was reported that several consultations were held in the village, but no intervention took place. They therefore hoped that this Project will be different. Tambana - NBR • The community of Tambana raised concern on the fact that the MV lines shall pass through their farmland and asked what will happen to their crops.

In response, NAWEC assured that construction of the lines shall be done outside the rainy season to avoid damage to crops and to impede farm activities. After the completion of the line, crop, vegetables and fruit trees can be grown under the lines, but trees that grow to the height of the line will be trimmed with the consent of the owners.

• The idea of conducting this consultation was highly welcomed. The daily ordeal women undergo in the village as a result

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of the lack of power supply was highlighted; If the village has power supply then milling machines can be used and the borehole can supply water

• The community complained that whilst the project will enhance the commencement of new and the growth of existing petty businesses such as the sale of baobab and “Wonjo” juices

• The operations of the school are currently seriously handicapped as they have to travel to Farafenni to print examination papers and other documents

• It was revealed that the school received a donation of printing equipment as well as laptops and computers in the past, but could not utilize them due to lack of power Katchang - NBR • The community of Katchang lamented that the absence of power supply makes the community face challenges of adding value to their farm produce; in particular, the process of transforming groundnut to groundnut butter and groundnut cake is a major challenge

• The villagers expressed that the community is part of the Gambia and therefore deserve social services that will improve their livelihoods. They said as farmers, they endure post-harvest losses of their horticultural produce due to lack of cold storage facilities created by the lack of power supply

• Fishermen and fish mongers cannot store fish caught at home even if it is abundantly available. They face these problems due to lack of storage and preservation and therefore suffer loss of income

• The people decried the lack of electricity services in the village which makes it impossible for skill workers like welders, tailors, panel beaters to operate in the village

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Chamen - CRR • The people of Chamen said they do not foresee many damages to their properties or farmlands. They however listed some of the challenges they face as a result of the lack of electricity in the community:

• The lack of electricity is retarding the development of the community. This is the biggest village in the Nianija District and electricity will help to generate employment with skills such as welding, tailoring, hairdressing, barbing saloons etc.

• The village has a health center which faces numerous operational challenges due to the absence of electricity services; drugs, laboratory reagents cannot be stored under ideal conditions

• Petty businesses like the sale of baobab juice, “Wonjo”, etc. can bring extra income and will be enhanced if electricity is available by ensuring that the financial burden of buying ice blocks at expensive prices will be a thing of the past

• Operating a generator is very expensive and as famers we cannot store our garden/farm produce Bush Town – CRR-N • This is always a busy crossing point with a ferry and canoes crossing the river. The car park is always busy; with availability of electricity services, vehicle repair and maintenance services will create employment for skilled people

• This community and people cannot progress without electricity;

• People have built good houses but cannot use them due to lack of electricity.

• With electricity, we can save money spent on many products and services that are dependent on power supply Sinchu Alhaji- CRR-S The Project is highly welcomed, but the villagers decried: • Lack of confidence as a number of neighboring villages were promised electricity which is still not forthcoming

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• Women are particularly disadvantaged as they spend a lot of time and resources on ice cubes for their businesses

• The youth of the village are constantly migrating to Kombo because they cannot practice electricity dependent professions such as welding

• Electricity will therefore greatly help in preserving foodstuff at the household level as well as make the youth stay at home • Community express appreciation for the meeting, and acknowledge that this is the first consultation meeting of its kind in the community

• The lack of electricity supply has negatively constrained their potential involvement in economic activities such as to selling cold water, ice block, food preservation of such as fish and horticulture produce

• Due to lack of power supply, the community cannot have a milling machine that will reduce the drudgery of threshing and milling of agriculture produce for home consumption and commercial purposes

• “We cannot enjoy studying under light bulbs as our compatriots at Armitage Senior Secondary and Bansang Senior Secondary Schools. Studying with candles is very challenging and for me, I have developed some eye problems due it”

• “We have so many youths with skills in carpentry, metal works, tailoring but they have migrated out of this community to communities with electricity in order to practice their trade Dankunku – CRR-S • Alkali and stakeholders in Dankunku welcome the Project and expressed readiness to support its activities to ensure smooth implementation

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• However, concerns were raised about the lack of financial capacity of some families to pay for the cost of cash power meters and hope that the Project considers subsidizing this for the rural poor

• Electricity will help the health delivery system, including the storage of essential basic supplies and drugs; the solar power at the health facility is not adequate

• Electricity supply can ensure cooked food, meat, and fish we can be stored thereby improving the lives of the people

• Women can get into petty businesses such as sale of local juices like “Wonjo”, baobab juice, etc. Kolior - LRR • Our living conditions have not improved due to the lack of electricity We cannot preserve food and other produce

• In the month of Ramadan, we buy ice block at a high price

• The availability of electricity will enhance our economic and livelihood activities like selling of juices, e.g. baobab, “Wonjo” etc.

• This situation does not improve our status. We cannot have cold water to drink under this hot weather, our children still use candles to study and during Ramadan, we buy ice block for thirty dalasi”

• On the time frame for the village to have power supply, the community complained that the two- and half-year duration given by the Consulting team as an estimate is very long. “We need power supply within the next six months” Government Institutions Governor’s Office, LRR Governor, LRR welcomes the team of consultants and noted:

• The importance of public consultations especially at regional level as very important

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• That the Project is implemented in the regions, and thus the participation of TACs is crucial for its successful implementation

• The need to develop the capacities of TAC members to enable them to participate in the monitoring of ESMP and RAPs Department of Parks and Wildlife • Concerned that some parts of the Niumi Management National Park may be impacted, and the Park hosts endangered and threatened species that need to be protected

• However, should coated wires be used, chances of animals being electrocuted will be minimal

• Anything inside the National Park, including forest trees belong to DPWM but any tree felled and is to be taken out of the Park, approval of DOF must be sought and obtained

• Any destruction must be repaired National Roads Authority • Poles should not be erected within road corridors which are less than 15m from the center of roads

• In the case of expansion of roads, relocation of poles can be costly; thus, erect poles as far away from roads as possible

• The possibility of running lines behind communities should be considered to avoid busy roads within communities Department of Forestry • As far as this Project is concerned, DOF’s interests relates to impacts on flora whilst DPWM is concerned with fauna

• However, there is always a positive consultation between the two Departments especially as it relates to consultations in respect of forest products

• In the case of any impacts on National Parks resulting in a RAP, DOF can always support DPWM with seedlings production in case of reforestation National Environment Agency • Challenges are foreseen in the Niumi National Park including issues pertaining to RAP and water facility

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• Possibility of underground cable to avoid impacts on habitat, flora and fauna etc. should be explored

• The need to build capacity especially at the regional level will help in the monitoring of project works

• Monitoring from HQ is not going to be effective, so there is need to utilize the TACs; TACs at regional level must always be engaged and their capacities should be built too NCAC • The Project will be very close to the stone circles in Kerr Batch, which are the most protected in the country

• Funds have been secured to refurbish the Kerr Batch site and presence of electricity in the future shall make the place more attractive and viable for tourism and its related benefits for the community

• Due to its cultural heritage, the Kerr Batch Stone Circles has immense significance and needs to be preserved; lines should be designed not to pass close to the site.

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Appendix 5.2: List of Persons Met

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Appendix 6.1: Codes of Conduct and Action Plan For Implementing ESHS and OHS Standards, and Preventing Gender Based Violence and Violence Against Children

Background

The purpose of these Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV) and Violence Against Children (VAC) is to introduce a set of key definitions, core Codes of Conduct, and guidelines that:

i. clearly define obligations on all project staff (including sub-contractors and day workers) with regard to implementing the project’s environmental, social, health and safety (ESHS) and occupational health and safety (OHS) requirements, and;

ii. help prevent, report and address GBV and VAC within the work site and in its immediate surrounding communities.

The application of these Codes of Conduct will help ensure the project meets its ESHS and OHS objectives, as well as preventing and/or mitigating the risks of GBV and VAC on the project and in the local communities.

These Codes of Conduct are to be adopted by those working on the project and are meant to:

i. create awareness of the ESHS and OHS expectations on the project;

ii. create common awareness about GBV and VAC and: (a) ensure a shared understanding that they have no place in the project; and, (b) create a clear system for identifying, responding to, and sanctioning GBV and VAC incidents.

Ensuring that all project staff understand the values of the project, understand expectations for all employees, and acknowledge the consequences for violations of these values, will help to create smoother, more respectful and productive project implementation thereby helping ensure that the project’s objectives will be achieved.

Definitions

The following definitions apply:

Environmental, Social, Health and Safety (ESHS): an umbrella term covering issues related to the impact of the project on the environment, communities and workers.

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Occupational Health and Safety (OHS): Occupational health and safety is concerned with protecting the safety, health and welfare of people engaged in work or employment. The enjoyment of these standards at the highest levels is a basic human right that should be accessible by each worker.

Gender-Based Violence (GBV): is an umbrella term for any harmful act that is perpetrated against a person’s will and that is based on socially ascribed (i.e. gender) differences between males and females. It includes acts that inflict physical, sexual or mental harm or suffering, threats of such acts, coercion, and other deprivations of liberty. These acts can occur in public or in private. The term GBV is used to underscore systemic inequality between males and females (which exists in every society in the world) and acts as a unifying and foundational characteristic of most forms of violence perpetrated against women and girls. The 1993 United Nations Declaration on the Elimination of Violence against Women defines violence against women as “any act of gender-based violence that results in, or is likely to result in, physical, sexual or psychological harm or suffering to women.”10 The six core types of GBV are: • Rape: non-consensual penetration (however slight) of the vagina, anus or mouth with a penis, other body part, or an object. • Sexual Assault: any form of non-consensual sexual contact that does not result in or include penetration. Examples include: attempted rape, as well as unwanted kissing, fondling, or touching of genitalia and buttocks.

o Sexual Harassment: is unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature. Sexual harassment is not always explicit or obvious, it can include implicit and subtle acts but always involves a power and gender dynamic in which a person in power uses their position to harass another based on their gender. Sexual conduct is unwelcome whenever the person subjected to it considers it unwelcome (e.g. looking somebody up and down; kissing, howling or smacking sounds; hanging around somebody; whistling and catcalls; in some instances, giving personal gifts). o Sexual Favors: is a form of sexual harassment and includes making promises of favorable treatment (e.g. promotion) or threats of unfavorable treatment (e.g. loss of job) dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior.

• Physical Assault: an act of physical violence that is not sexual in nature. Examples include: hitting, slapping, choking, cutting, shoving, burning, shooting or use of any weapons, acid attacks or any other act that results in pain, discomfort or injury.

• Forced Marriage: the marriage of an individual against her or his will.

• Denial of Resources, Opportunities or Services: denial of rightful access to economic resources/assets or livelihood opportunities, education, health or other social services (e.g. a

10 It is important to note that women and girls disproportionately experience violence; overall 35 percent of women worldwide have faced physical or sexual violence (WHO, Global and regional estimates of violence against women: prevalence and health effects of intimate partner violence and non-partner sexual violence, 2013). Some men and boys also face violence based on their gender and unequal power relationships.

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widow prevented from receiving an inheritance, earnings forcibly taken by an intimate partner or family member, a woman prevented from using contraceptives, a girl prevented from attending school, etc.).

• Psychological / Emotional Abuse: infliction of mental or emotional pain or injury. Examples include: threats of physical or sexual violence, intimidation, humiliation, forced isolation, stalking, harassment, unwanted attention, remarks, gestures or written words of a sexual and/or menacing nature, destruction of cherished things, etc.

Violence Against Children (VAC): is defined as physical, sexual, emotional and/or psychological harm, neglect or negligent treatment of minor children (i.e. under the age of 18), including exposure to such harm,11 that results in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power. This includes using children for profit, labor12, sexual gratification, or some other personal or financial advantage. This also includes other activities such as using computers, mobile phones, video and digital cameras or any other medium to exploit or harass children or to access child pornography.

Grooming: are behaviors that make it easier for a perpetrator to procure a child for sexual activity. For example, an offender might build a relationship of trust with the child, and then seek to sexualize that relationship (for example by encouraging romantic feelings or exposing the child to sexual concepts through pornography).

Online Grooming: is the act of sending an electronic message with indecent content to a recipient who the sender believes to be a minor, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender.13

Accountability Measures: are the measures put in place to ensure the confidentiality of survivors and to hold contractors, consultants and the client responsible for instituting a fair system of addressing cases of GBV and VAC.

Contractors Environmental and Social Management Plan (CESMP): the plan prepared by the contractor outlining how they will implement the works activities in accordance with the project’s environmental and social management plan (ESMP).

Child: is used interchangeably with the term ‘minor’ and refers to a person under the age of 18. This is in accordance with Article 1 of the United Nations Convention on the Rights of the Child.

Child Protection (CP): is an activity or initiative designed to protect children from any form of harm, particularly arising from VAC.

Consent: is the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is

11 Exposure to GBV is also considered VAC. 12 The employment of children must comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. They must also be able to meet the project’s Occupational Health and Safety competency standards. 13 For example, the Vanuatu Criminal Code Act 1995, Division 474 (telecommunications offences, subdivision C).

225 obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if national legislation of the country into which the Code of Conduct is introduced has a lower age.14 Mistaken belief regarding the age of the child and consent from the child is not a defense.

Consultant: is as any firm, company, organization or other institution that has been awarded a contract to provide consulting services to the project, and has hired managers and/or employees to conduct this work.

Contractor: is any firm, company, organization or other institution that has been awarded a contract to conduct infrastructure development works for the project and has hired managers and/or employees to conduct this work. This also includes sub-contractors hired to undertake activities on behalf of the contractor.

Employee: is any individual offering labor to the contractor or consultant within country on or off the work site, under a formal or informal employment contract or arrangement, typically, but not necessarily (e.g. including unpaid interns and volunteers), in exchange for a salary, with no responsibility to manage or supervise other employees.

GBV and VAC Allegation Procedure: is the prescribed procedure to be followed when reporting incidents of GBV or VAC.

GBV and VAC Codes of Conduct: The Codes of Conduct adopted for the project covering the commitment of the company, and the responsibilities of managers and individuals with regards to GBV and VAC.

Grievance Redress Mechanism (GRM): is the process established by a project to receive and address complaints.

Manager: is any individual offering labor to the contractor or consultant, on or off the work site, under a formal or informal employment contract and in exchange for a salary, with responsibility to control or direct the activities of a contractor’s or consultant’s team, unit, division or similar, and to supervise and manage a pre-defined number of employees.

Perpetrator: the person(s) who commit(s) or threaten(s) to commit an act or acts of GBV or VAC.

Response Protocol: is the mechanisms set in place to respond to cases of GBV and VAC (see Section 4.7 Response Protocol).

Survivor/Survivors: the person(s) adversely affected by GBV or VAC. Women, men and children can be survivors of GBV; children can be survivors of VAC.

14 For example, under Article 97 Criminal consolidation act for age of legal consent in Vanuatu, sexual activity with any child under the age of 15 years for heterosexual conduct and 18 years for same sex conduct is prohibited (http://tinyurl.com/vu-consent). However, the World Bank follows the United Nations for the age of consent (18 years) so this applies on World Bank financed projects.

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Work Site: is the area in which infrastructure development works are being conducted, as part of the project. Consulting assignments are considered to have the areas in which they are active as their work sites.

Work Site Surroundings: is the ‘Project Area of Influence’ which are any area, urban or rural, directly affected by the project, including all human settlements found on it.

Codes of Conduct

This chapter presents three Codes of Conduct for use: i. Company Code of Conduct: Commits the company to addressing GBV and VAC issues; ii. Manager’s Code of Conduct: Commits managers to implementing the Company Code of Conduct, as well as those signed by individuals; and, iii. Individual Code of Conduct: Code of Conduct for everyone working on the project, including managers.

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Company Code of Conduct

Implementing ESHS and OHS Standards

Preventing Gender Based Violence and Violence Against Children

The company is committed to ensuring that the project is implemented in such a way which minimizes any negative impacts on the local environment, communities, and its workers. This will be done by respecting the environmental, social, health and safety (ESHS) standards, and ensuring appropriate occupational health and safety (OHS) standards are met. The company is also committed to creating and maintaining an environment in which gender based violence (GBV) and violence against children (VAC) have no place, and where they will not be tolerated by any employee, sub-contractors, supplier, associate, or representative of the company.

Therefore, to ensure that all those engaged in the project are aware of this commitment, the company commits to the following core principles and minimum standards of behavior that will apply to all company employees, associates, and representatives, including sub-contractors and suppliers, without exception:

General

1. The company—and therefore all employees, associates, representatives, sub-contractors and suppliers—commits to complying with all relevant national laws, rules and regulations. 2. The company commits to full implementing its ‘Contractors Environmental and Social Management Plan’ (CESMP). 3. The company commits to treating women, children (persons under the age of 18), and men with respect regardless of race, color, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status. Acts of GBV and VAC are in violation of this commitment. 4. The company shall ensure that interactions with local community members are done with respect and non-discrimination. 5. Demeaning, threatening, harassing, abusive, culturally inappropriate, or sexually provocative language and behavior are prohibited among all company employees, associates, and its representatives, including sub-contractors and suppliers. 6. The company will follow all reasonable work instructions (including regarding environmental and social norms). 7. The company will protect and ensure proper use of property (for example, to prohibit theft, carelessness or waste).

Health and Safety

8. The company will ensure that the project’s occupational health and safety (OHS) Management Plan is effectively implemented by company staff, as well as sub-contractors and suppliers. 9. The company will ensure that all persons on-site wear prescribed and appropriate personal protective equipment, preventing avoidable accidents and reporting conditions or practices that pose a safety hazard or threaten the environment.

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10. The company will: i. prohibit the use of alcohol during work activities. ii. prohibit the use of narcotics or other substances which can impair faculties at all times.

11. The company will ensure that adequate sanitation facilities are available on site and at any worker accommodations provided to those working on the project.

Gender Based Violence and Violence Against Children

12. Acts of GBV or VAC constitute gross misconduct and are therefore grounds for sanctions, which may include penalties and/or termination of employment, and if appropriate referral to the Police for further action. 13. All forms of GBV and VAC, including grooming are unacceptable, regardless of whether they take place on the work site, the work site surroundings, at worker’s camps or within the local community. i. Sexual Harassment—for instance, making unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct, of a sexual nature, including subtle acts of such behavior, is prohibited. ii. Sexual favors —for instance, making promises or favorable treatment dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior are prohibited. 14. Sexual contact or activity with children under 18—including through digital media—is 7prohibited. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse. 15. Unless there is full consent15 by all parties involved in the sexual act, sexual interactions between the company’s employees (at any level) and members of the communities surrounding the work place are prohibited. This includes relationships involving the withholding/promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex— such sexual activity is considered “non-consensual” within the scope of this Code. 16. In addition to company sanctions, legal prosecution of those who commit acts of GBV or VAC will be pursued if appropriate. 17. All employees, including volunteers and sub-contractors are highly encouraged to report suspected or actual acts of GBV and/or VAC by a fellow worker, whether in the same company or not. Reports must be made in accordance with project’s GBV and VAC Allegation Procedures. 18. Managers are required to report and act to address suspected or actual acts of GBV and/or VAC as they have a responsibility to uphold company commitments and hold their direct reports responsible.

15 Consent is defined as the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if national legislation of the country into which the Code of Conduct is introduced has a lower age. Mistaken belief regarding the age of the child and consent from the child is not a defense.

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Implementation

To ensure that the above principles are implemented effectively the company commits to ensuring that:

19. All managers sign the project’s ‘Manager’s Code of Conduct’ detailing their responsibilities for implementing the company’s commitments and enforcing the responsibilities in the ‘Individual Code of Conduct’. 20. All employees sign the project’s ‘Individual Code of Conduct’ confirming their agreement to comply with ESHS and OHS standards, and not to engage in activities resulting in GBV or VAC. 21. Displaying the Company and Individual Codes of Conduct prominently and in clear view at workers’ camps, offices, and in in public areas of the work space. Examples of areas include waiting, rest and lobby areas of sites, canteen areas and health clinics. 22. Ensure that posted and distributed copies of the Company and Individual Codes of Conduct are translated into the appropriate language of use in the work site areas as well as for any international staff in their native language. 23. An appropriate person is nominated as the company’s ‘Focal Point’ for addressing GBV and VAC issues, including representing the company on the GBV and VAC Compliance Team (GCCT) which is comprised of representatives from the client, contractor(s), the supervision consultant, and local service provider(s). 24. Ensuring that an effective GBV and VAC Action Plan is developed in consultation with the GCCT which includes as a minimum:

i. GBV and VAC Allegation Procedure to report GBV and VAC issues through the project Grievance Redress Mechanism (Section 4.3 Action Plan); ii. Accountability Measures to protect confidentiality of all involved (Section 4.4 Action Plan); and, iii. Response Protocol applicable to GBV and VAC survivors and perpetrators (Section 4.7 Action Plan).

25. That the company effectively implements the agreed final GBV and VAC Action Plan, providing feedback to the GCCT for improvements and updates as appropriate. 26. All employees attend an induction training course prior to commencing work on site to ensure they are familiar with the company’s commitments to ESHS and OHS standards, and the project’s GBV and VAC Codes of Conduct. 27. All employees attend a mandatory training course once a month for the duration of the contract starting from the first induction training prior to commencement of work to reinforce the understanding of the project’s ESHS and OHS standards and the GBV and VAC Code of Conduct.

I do hereby acknowledge that I have read the foregoing Company Code of Conduct, and on behalf of the company agree to comply with the standards contained therein. I understand my role and responsibilities to support the project’s OHS and ESHS standards, and to prevent and respond to GBV and VAC. I understand that any action inconsistent with this Company Code of Conduct or failure to act mandated by this Company Code of Conduct may result in disciplinary action.

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Company name: ______

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Manager’s Code of Conduct

Implementing ESHS and OHS Standards

Preventing Gender Based Violence and Violence Against Children

Managers at all levels have a responsibility to uphold the company’s commitment to implementing the ESHS and OHS standards, and preventing and addressing GBV and VAC. This means that managers have an acute responsibility to create and maintain an environment that respects these standards, and prevents GBV and VAC. Managers need to support and promote the implementation of the Company Code of Conduct. To that end, managers must adhere to this Manager’s Code of Conduct and sign the Individual Code of Conduct. This commits them to supporting the implementation of the CESMP and the OHS Management Plan, and developing systems that facilitate the implementation of the GBV and VAC Action Plan. They need to maintain a safe workplace, as well as a GBV-free and VAC- free environment at the workplace and in the local community. These responsibilities include but are not limited to:

Implementation

1. To ensure maximum effectiveness of the Company and Individual Codes of Conduct: i. Prominently displaying the Company and Individual Codes of Conduct in clear view at workers’ camps, offices, and in public areas of the work space. Examples of areas include waiting, rest and lobby areas of sites, canteen areas and health clinics. ii. Ensuring all posted and distributed copies of the Company and Individual Codes of Conduct are translated into the appropriate language of use in the work site areas as well as for any international staff in their native language. 2. Verbally and in writing explain the Company and Individual Codes of Conduct to all staff. 3. Ensure that: i. All direct reports sign the ‘Individual Code of Conduct’, including acknowledgment that they have read and agree with the Code of Conduct. ii. Staff lists and signed copies of the Individual Code of Conduct are provided to the OHS Manager, the GCCT, and the client. iii. Participate in training and ensure that staff also participate as outlined below. iv. Put in place a mechanism for staff to: (a) report concerns on ESHS or OHS compliance; and, (b) confidentially report GBV or VAC incidents through the Grievance Redress Mechanism (GRM) v. Staff are encouraged to report suspected or actual ESHS, OHS, GBV or VAC issues, emphasizing the staff’s responsibility to the Company and the country hosting their employment, and emphasizing the respect for confidentiality. 4. In compliance with applicable laws and to the best of your abilities, prevent perpetrators of sexual exploitation and abuse from being hired, re-hired or deployed. Use background and criminal reference checks for all employees. 5. Ensure that when engaging in partnership, sub-contractor, supplier or similar agreements, these agreements: i. Incorporate the ESHS, OHS, GBV and VAC Codes of Conduct as an attachment.

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ii. Include the appropriate language requiring such contracting entities and individuals, and their employees and volunteers, to comply with the Individual Codes of Conduct. iii. Expressly state that the failure of those entities or individuals, as appropriate, to ensure compliance with the ESHS and OHS standards, take preventive measures against GBV and VAC, to investigate allegations thereof, or to take corrective actions when GBV or VAC has occurred, shall not only constitute grounds for sanctions and penalties in accordance with the Individual Codes of Conduct but also termination of agreements to work on or supply the project. 6. Provide support and resources to the GCCT to create and disseminate internal sensitization initiatives through the awareness-raising strategy under the GBV and VAC Action Plan. 7. Ensure that any GBV or VAC issue warranting Police action is reported to the Police, the client and the World Bank immediately. 8. Report and act according to the response protocol (Section 4.7 Response Protocol) any suspected or actual acts of GBV and/or VAC as managers have a responsibility to uphold company commitments and hold their direct reports responsible. 9. Ensure that any major ESHS or OHS incidents are reported to the client and the supervision engineer immediately.

Training

10. The managers are responsible to: i. Ensure that the OHS Management Plan is implemented, with suitable training required for all staff, including sub-contractors and suppliers; and, ii. Ensure that staff have a suitable understanding of the CESMP and are trained as appropriate to implement the CESMP requirements. 11. All managers are required to attend an induction manager training course prior to commencing work on site to ensure that they are familiar with their roles and responsibilities in upholding the GBV and VAC elements of these Codes of Conduct. This training will be separate from the induction training course required of all employees and will provide managers with the necessary understanding and technical support needed to begin to develop the GBV and VAC Action Plan for addressing GBV and VAC issues. 12. Managers are required to attend and assist with the project facilitated monthly training courses for all employees. Managers will be required to introduce the trainings and announce the self- evaluations, including collecting satisfaction surveys to evaluate training experiences and provide advice on improving the effectiveness of training. 13. Ensure that time is provided during work hours and that staff prior to commencing work on site attend the mandatory project facilitated induction training on: i. OHS and ESHS; and, ii. GBV and VAC required of all employees. 14. During civil works, ensure that staff attend ongoing OHS and ESHS training, as well as the monthly mandatory refresher training course required of all employees to combat increased risk of GBV and VAC.

Response

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15. Managers will be required to take appropriate actions to address any ESHS or OHS incidents. 16. With regard to GBV and VAC: i. Provide input to the GBV and VAC Allegation Procedures (Section 4.2 Action Plan) and Response Protocol (Section 4.7 Action Plan) developed by the GCCT as part of the final cleared GBV and VAC Action Plan. ii. Once adopted by the Company, managers will uphold the Accountability Measures (Section 4.4 Action Plan) set forth in the GBV and VAC Action Plan to maintain the confidentiality of all employees who report or (allegedly) perpetrate incidences of GBV and VAC (unless a breach of confidentiality is required to protect persons or property from serious harm or where required by law). iii. If a manager develops concerns or suspicions regarding any form of GBV or VAC by one of his/her direct reports, or by an employee working for another contractor on the same work site, s/he is required to report the case using the GRM. iv. Once a sanction has been determined, the relevant manager(s) is/are expected to be personally responsible for ensuring that the measure is effectively enforced, within a maximum timeframe of 14 days from the date on which the decision to sanction was made v. If a Manager has a conflict of interest due to personal or familial relationships with the survivor and/or perpetrator, he/she must notify the respective company and the GCCT. The Company will be required to appoint another manager without a conflict of interest to respond to complaints. vi. Ensure that any GBV or VAC issue warranting Police action is reported to the Police, the client and the World Bank immediately

17. Managers failing to address ESHS or OHS incidents, or failing to report or comply with the GBV and VAC provisions may be subject to disciplinary measures, to be determined and enacted by the company’s CEO, Managing Director or equivalent highest-ranking manager. Those measures may include: i. Informal warning. ii. Formal warning. iii. Additional Training. iv. Loss of up to one week's salary. v. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. vi. Termination of employment.

18. Ultimately, failure to effectively respond to ESHS, OHS, GBV and VAC cases on the work site by the company’s managers or CEO may provide grounds for legal actions by authorities.

I do hereby acknowledge that I have read the foregoing Manager’s Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, GBV and VAC requirements. I understand that any action inconsistent with this Manager’s Code of Conduct or failure to act mandated by this Manager’s Code of Conduct may result in disciplinary action.

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Signature: ______

Printed Name: ______

Title: ______

Date: ______

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Individual Code of Conduct

Implementing ESHS and OHS Standards

Preventing Gender Based Violence and Violence Against Children

I, ______, acknowledge that adhering to environmental, social health and safety (ESHS) standards, following the project’s occupational health and safety (OHS) requirements, and preventing gender based violence (GBV) and violence against children (VAC) is important.

The company considers that failure to follow ESHS and OHS standards, or to partake in GBV or VAC activities—be it on the work site, the work site surroundings, at workers’ camps, or the surrounding communities—constitute acts of gross misconduct and are therefore grounds for sanctions, penalties or potential termination of employment. Prosecution by the Police of those who commit GBV or VAC may be pursued if appropriate.

I agree that while working on the project I will:

1. Attend and actively partake in training courses related to ESHS, OHS, HIV/AIDS, GBV and VAC as requested by my employer. 2. Will wear my personal protective equipment (PPE) at all times when at the work site or engaged in project related activities. 3. Take all practical steps to implement the contractor’s environmental and social management plan (CESMP). 4. Implement the OHS Management Plan. 5. Adhere to a zero-alcohol policy during work activities, and refrain from the use of narcotics or other substances which can impair faculties at all times. 6. Consent to Police background check. 7. Treat women, children (persons under the age of 18), and men with respect regardless of race, color, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status. 8. Not use language or behavior towards women, children or men that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate. 9. Not engage in sexual harassment—for instance, making unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct, of a sexual nature, including subtle acts of such behavior (e.g. looking somebody up and down; kissing, howling or smacking sounds; hanging around somebody; whistling and catcalls; giving personal gifts; making comments about somebody’s sex life; etc.). 10. Not engage in sexual favors—for instance, making promises or favorable treatment dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior. 11. Not participate in sexual contact or activity with children—including grooming, or contact through digital media. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse.

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12. Unless there is the full consent16 by all parties involved, I will not have sexual interactions with members of the surrounding communities. This includes relationships involving the withholding or promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex—such sexual activity is considered “non-consensual” within the scope of this Code. 13. Consider reporting through the GRM or to my manager any suspected or actual GBV or VAC by a fellow worker, whether employed by my company or not, or any breaches of this Code of Conduct.

With regard to children under the age of 18:

14. Wherever possible, ensure that another adult is present when working in the proximity of children. 15. Not invite unaccompanied children unrelated to my family into my home, unless they are at immediate risk of injury or in physical danger. 16. Not use any computers, mobile phones, video and digital cameras or any other medium to exploit or harass children or to access child pornography (see also “Use of children's images for work related purposes” below). 17. Refrain from physical punishment or discipline of children. 18. Refrain from hiring children for domestic or other labor below the minimum age of 14 unless national law specifies a higher age, or which places them at significant risk of injury. 19. Comply with all relevant local legislation, including labor laws in relation to child labor and World Bank’s safeguard policies on child labor and minimum age. 20. Take appropriate caution when photographing or filming children (See Annex 2 for details).

Use of children's images for work related purposes

When photographing or filming a child for work related purposes, I must:

21. Before photographing or filming a child, assess and endeavor to comply with local traditions or restrictions for reproducing personal images. 22. Before photographing or filming a child, obtain informed consent from the child and a parent or guardian of the child. As part of this I must explain how the photograph or film will be used. 23. Ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive. 24. Ensure images are honest representations of the context and the facts. 25. Ensure file labels do not reveal identifying information about a child when sending images electronically.

Sanctions

16 Consent is defined as the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do something. No consent can be found when such acceptance or agreement is obtained using threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be given by children under the age of 18, even if national legislation of the country into which the Code of Conduct is introduced has a lower age. Mistaken belief regarding the age of the child and consent from the child is not a defense.

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I understand that if I breach this Individual Code of Conduct, my employer will take disciplinary action which could include:

1. Informal warning. 2. Formal warning. 3. Additional Training. 4. Loss of up to one week’s salary. 5. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. 6. Termination of employment. 7. Report to the Police if warranted.

I understand that it is my responsibility to ensure that the environmental, social, health and safety standards are met. That I will adhere to the occupational health and safety management plan. That I will avoid actions or behaviors that could be construed as GBV or VAC. Any such actions will be a breach this Individual Code of Conduct. I do hereby acknowledge that I have read the foregoing Individual Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, GBV and VAC issues. I understand that any action inconsistent with this Individual Code of Conduct or failure to act mandated by this Individual Code of Conduct may result in disciplinary action and may affect my ongoing employment.

Signature: ______

Printed Name: ______

Title: ______

Date: ______

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GBV and VAC Action Plan

4.1 The GBV and VAC Compliance Team

The project shall establish a ‘GBV and VAC Compliance Team’ (GCCT). The GCCT will include, as appropriate to the project, at least four representatives (‘Focal Points’) as follows:

i. A safeguards specialist from the client; ii. The occupational health and safety manager from the contractor17, or someone else tasked with the responsibility for addressing GBV and VAC with the time and seniority to devote to the position; iii. The supervision consultant; and, iv. A representative from a local service provider with experience in GBV and VAC (the ‘Service Provider’).

It will be the duty of the GCCT with support from the management of the contractor to inform workers about the activities and responsibilities of the GCCT. To effectively serve on the GCCT, members must undergo training by the local service provider prior to the commencement of their assignment to ensure that they are sensitized on GBV and Child Protection.

The GCCT will be required to:

i. Approve any changes to the GBV and VAC Codes of Conduct contained in this document, with clearances from the World Bank for any such changes. ii. Prepare the GBV and VAC Action Plan reflecting the Codes of Conduct which includes: (a) GBV and VAC Allegation Procedures (See 4.2) (b) Accountability Measures (See 4.4) (c) An Awareness raising Strategy (See 4.6) (d) A Response Protocol (See 4.7) iii. Obtain approval of the GBV and VAC Action Plan by the contractor’s management; iv. Obtain client and World Bank clearances for the GBV and VAC Action Plan prior to full mobilization; v. Receive and monitor resolutions and sanctions regarding complaints received related to GBV and VAC associated with the project; and, vi. Ensure that GBV and VAC statistics in the GRM are up to date and included in the regular project reports.

The GCCT shall hold quarterly update meetings to discuss ways to strengthen resources and GBV and VAC support for employees and community members.

4.2 Making Complaints: GBV and VAC Allegation Procedures

17 Where there are multiple contractors working on the project, each shall nominate a representative as appropriate.

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All staff, volunteers, consultants and sub-contractors are encouraged to report suspected or actual GBV or VAC cases. Managers are required to report suspected or actual GBV and/or VAC cases as they have responsibilities to uphold company commitments and they hold their direct reports accountable for complying with the Individual Code of Conduct.

The project will provide information to employees and the community on how to report cases of GBV and VAC Code of Conduct breaches through the Grievance Redress Mechanism (GRM). The GCCT will follow up on cases of GBV, VAC and Code of Conduct breaches reported through the GRM.

4.3 Addressing Complaints about GBV or VAC

The figure below shows the process for addressing complaints based on the example of the Vanuatu Aviation Investment Project (VAIP).

Note: VPMU is the Vanuatu Project Management Unit (VPMU) responsible for the implementation of VAIP.

GRM

The project operates a grievance redress mechanism (GRM) which is managed by a designated GRM operator with the project implementation unit. Reports of GBV or VAC, other complaints, or other concerns may be submitted online, via telephone or mail, or in person.

All complaints regarding GBV and VAC must immediately be reported to the World Bank task team by the GRM operator.

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The GRM operator will refer complaints related to GBV or VAC to the GCCT to resolve them. In accordance with the GBV and VAC Action Plan, the GCCT through the Service Provider and Focal Point(s) will investigate the complaint and ultimately provide the GRM operator with a resolution to the complaint, or the Police if necessary. The victim’s confidentiality should also be kept in mind when reporting any incidences to the Police.

The GRM operator will, upon resolution, advise the complainant of the outcome, unless it was made anonymously. Complaints made to managers or the Service Provider will be referred by them to the GRM for processing.

If the complaint to the GRM is made by a survivor or on behalf of a survivor, the complainant will be directly referred to the service provider to receive support services while the GCCT investigates the complaint in parallel.

Service Provider

The Service Provider is a local organization which has the experience and ability to support survivors of GBV or VAC. The client, the contractor(s) and consultant must establish a working relationship with the Service Provider, so that GBV and VAC cases can safely be referred to them. The Service Provider will also provide support and guidance to the GBV and VAC Focal Points as necessary. The Service Provider will have a representative on the GCCT and be involved in resolving complaints related to GBV or VAC.

GCCT GBV and VAC Focal Points

The GCCT shall confirm that all complaints related to GBV or VAC have been referred to the World Bank by the GRM operator.

The GCCT shall consider all GBV and VAC complaints and agree on a plan for resolution. The appropriate Focal Point will be tasked with implementing the plan (i.e. issues with contractor’s staff will be for the contractor to resolve; consultant’s staff the consultant; and client staff the client). The Focal Point will advise the GCCT on resolution, including referral to the Police if necessary. They will be assisted by the Service Provider as appropriate.

All the Focal Points on the GCCT must be trained and empowered to resolve GBV and VAC issues. It is essential that all staff of the GRM and GCCT understand the guiding principles and ethical requirement of dealing with survivors of GBV and VAC. All reports should be kept confidential and referred immediately to the Service Provider represented on the GCCT18. In GBV and VAC cases warranting Police action, the Focal Points must appropriately refer the complaint to: (i) the authorities; (ii) the Service Provider; and, (iii) management for further action. The client and the World Bank are to be immediately notified.

18 Survivors of GBV and VAC may need access to Police, justice, health, psychosocial, safe shelter and livelihood services to begin on a path of healing from their experience of violence.

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4.4 Accountability Measures

All reports of GBV or VAC shall be handled in a confidential manner to protect the rights of all involved. The client, contractor and consultant must maintain the confidentiality of employees who notify any acts or threats of violence, and of any employees accused of engaging in any acts or threats of violence (unless a breach of confidentiality is required to protect persons or property from serious harm or where required by law). The contractor and consultant must prohibit discrimination or adverse action against an employee because of survivor’s disclosure, experience or perceived experience of GBV or VAC (see Annex 1 for examples of actions to maintain accountability).

To ensure that survivors feel confident to disclose their experience of GBV or VAC, they can report cases of GBV or VAC through multiple channels: (i) online, (ii) phone, (iii) in-person, (iv) the local service provider, (v) the manager(s), (vi) village councils; or, (vii) the Police. To ensure confidentiality, only the service provider will be privy to information regarding the survivor. The GCCT will be the primary point of contact for information and follow up regarding the perpetrator.

4.5 Monitoring and Evaluation

The GCCT must monitor the follow up of cases that have been reported and maintain all reported cases in a confidential and secure location. Monitoring must collect the number of cases that have been reported and the share of them that are being managed by Police, NGOs etc.

These statistics shall be reported to the GRM and the Supervision Engineer for inclusion in their reporting.

For any GBV and VAC cases warranting Police action, the client and the World Bank are to be immediately notified.

4.6 Awareness-raising Strategy

It is important to create an Awareness-raising Strategy with activities aimed to sensitize employees on GBV and VAC on the work site and its related risks, provisions of the GBV and VAC Codes of Conduct, GBV and VAC Allegation Procedures, Accountability Measures and Response Protocol. The strategy will be accompanied by a timeline, indicating the various sensitization activities through which the strategy will be implemented and the related (expected) delivery dates. Awareness-raising activities should be linked with trainings provided by the Service Provider.

4.7 Response Protocol

The GCCT will be responsible for developing a written response19 protocol to meet the project requirements, in accordance to national laws and protocols. The response protocol must include mechanisms to notify and respond to perpetrators in the workplace (See 4.9 for Perpetrator Policy and Response). The response protocol will include the GRM process to ensure competent and

19 Develop appropriate protocol for written recording of GBV issues and VAC raised in case the notes are subpoenaed. Develop processes for record keeping including activities undertaken by the GRC

242 confidential response to disclosures of GBV and VAC. An employee who discloses a case of GBV or VAC in the workplace shall be referred to the GRM for reporting.

4.8 Survivor Support Measures

It is essential to appropriately respond to the survivor’s complaint by respecting the survivor’s choices to minimize the potential for re-traumatization and further violence against the survivor. Refer the survivor to the Service Provider to obtain appropriate support services in the community—including medical and psychosocial support, emergency accommodation, security including Police protection and livelihood support—by facilitating contact and coordination with these services. The client, contractor or consultant may, where feasible, provide financial and other supports to survivors of GBV or VAC for these services (see Annex 1 for examples of financial support).

If the survivor is an employee, to ensure the safety of the survivor, and the workplace in general, the client, contractor or consultant, in consultation with the survivor, will assess the risk of ongoing abuse to the survivor and in the workplace. Reasonable adjustments will be made to the survivor’s work schedule and work environment as deemed necessary (see Annex 1 for examples of safety measures). The employer will provide adequate leave to survivors seeking services after experiencing violence (see Annex 1 for details).

4.9 Perpetrator Policy and Response

Encourage and accept notification through the GRM from employees and community members about perpetrators in the workplace. Through the GCCT and/or the Service Provider, oversee the investigation of these grievances, ensuring procedural fairness for the accused, and within the local laws. If an employee has breached the Code of Conduct, the employer will act which could include:

i. Undertake disciplinary action up in accordance with sanctions in the GBV and VAC Codes of Conduct; ii. Report the perpetrator to the Police as per local legal paradigms; and/or iii. If feasible, provide or facilitate counselling for the perpetrator.

5.0 Sanctions

In accordance with the Code of Conduct, any employee confirmed as a GBV or VAC perpetrator shall be considered for disciplinary measures in line with sanctions and practices as agreed in the Individual Code of Conduct (see Annex 1 for examples of sanctions). It is important to note that, for each case, disciplinary sanctions are intended to be part of a process that is entirely internal to the employer, is placed under the full control and responsibility of its managers, and is conducted in accordance with the applicable national labor legislation.

Such process is expected to be fully independent from any official investigation that competent authorities (e.g. Police) may decide to conduct in relationship to the same case, and in accordance with the applicable national law. Similarly, internal disciplinary measures that the employer’s managers may decide to enact are meant to be separate from any charges or sanctions that the official investigation may result into (e.g. monetary fines, detention etc.).

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Codes of Conduct Annex 1 - Potential Procedures for Addressing GBV and VAC

Accountability Measures to maintain confidentiality can be achieved through the following actions:

1. Inform all employees that confidentiality of GBV/VAC survivors’ personal information is of utmost importance. 2. Provide the GCCT with training on empathetic and non-judgmental listening. 3. Take disciplinary action, including and up to dismissal, against those who breach survivor’s confidentiality (this is unless a breach of confidentiality is necessary to protect the survivor or another person from serious harm, or where required by law).

GBV and VAC Allegation Procedures should specify:

1. Who survivors can seek information and assistance from. 2. The process for community members and employees to lodge a complaint through the GRM should there be alleged GBV or VAC. 3. The mechanism for how community members and employees can escalate a request for support or notification of violence if the process for reporting is ineffective due to unavailability or non- responsiveness, or if the employee’s concern in not resolved.

Financial and Other Supports to survivors can include:

1. No/low interest loans. 2. Salary advances. 3. Direct payment of medical costs. 4. Coverage of all medical costs related specifically to the incident. 5. Upfront payments for medical costs to later be recouped from the employee’s health insurance. 6. Providing or facilitating access to childcare. 7. Providing security upgrades to the employee’s home. 8. Providing safe transportation to access support services or to and from accommodation.

Based on the rights, needs and wishes of the survivor, survivor support measures to ensure the safety of the survivor who is an employee can include20:

1. Changing the perpetrator or survivor’s span of hours or pattern of hours and/or shift patterns. 2. Redesigning or changing the perpetrator or survivor’s duties. 3. Changing the survivor’s telephone number or email address to avoid harassing contact. 4. Relocating the survivor or perpetrator to another work site/ alternative premises. 5. Providing safe transportation to and from work for a specified period. 6. Supporting the survivor to apply for an Interim Protection Order or referring them to appropriate support. 7. Taking any other appropriate measures including those available under existing provisions for family friendly and flexible work arrangements.

20 It is critical that a survivor centered approach be adopted. The survivor should be fully involved in the decision making. Except for exceptional circumstances the perpetrator should be required to take appropriate actions to accommodate the survivor (e.g. move, change hours, etc.), rather than the survivor changing.

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Leave options for survivors that are employees can include:

1. An employee experiencing GBV should be able to request paid special leave to attend medical or psychosocial appointments, legal proceedings, relocation to safe accommodation and other activities related to GBV. 2. An employee who supports a person experiencing GBV or VAC may take care givers leave, including but not limited to accompanying them to court or hospital, or to take care of children. 3. Employees who are employed in a casual capacity may request unpaid special leave or unpaid care givers leave to undertake the activities described above. 4. The amount of leave provided will be determine by the individual’s situation through consultations with the employee, the management and the GCCT where appropriate.

Potential Sanctions to employees who are perpetrators of GBV and VAC include:

1. Informal warning 2. Formal warning 3. Additional Training 4. Loss of up to one week’s salary. 5. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. 6. Termination of employment.

Referral to the Police or other authorities as warranted.

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Appendix 7.1: The Existing Memoradum Between NAWEC and the Department of Forestry

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Appendix 7.2: Technical Note: Public Consultations and Stakeholder Engagement in WB-Supported Operations when there are Constraints on Conducting Public Meetings

With the outbreak and spread of COVID-19, people have been advised, or may be mandated by national or local law, to exercise social distancing, and specifically to avoid public gatherings to prevent and reduce the risk of the virus transmission. Countries have taken various restrictive measures, some imposing strict restrictions on public gatherings, meetings and people’s movement, and others advising against public group events. At the same time, the general public has become increasingly aware and concerned about the risks of transmission, particularly through social interactions at large gatherings.

These restrictions have implications for World Bank-supported operations. In particular, they will affect Bank requirements for public consultation and stakeholder engagement in projects, both under implementation and preparation. WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. All these documents are available on the WHO website through the following link: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance.

This Note offers suggestions to World Bank task teams for advising counterpart agencies on managing public consultation and stakeholder engagement in their projects, with the recognition that the situation is developing rapidly and careful regard needs to be given to national requirements and any updated guidance issued by WHO. It is important that the alternative ways of managing consultation and stakeholder engagement discussed with clients are in accordance with the local applicable laws and policies, especially those related to media and communication. The suggestions set out below are subject to confirmation that they are in accordance with existing laws and regulations applying to the project.

Investment projects under implementation. All projects under implementation are likely to have public consultation and stakeholder engagement activities planned and committed as part of project design. These activities may be described in different project documents and will involve a variety of stakeholders. Commonly planned avenues of such engagement are public hearings, community meetings, focus group discussions, field surveys and individual interviews. With growing concern about the risk of virus spread, there is an urgent need to adjust the approach and methodology for continuing stakeholder consultation and engagement. Taking into account the importance of confirming compliance with national law requirements, below are some suggestions for task teams’ consideration while advising their clients:

Task teams will need to review their project, jointly with the PMUs, and should:

Identify and review planned activities under the project requiring stakeholder engagement and public consultations.

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• Assess the level of proposed direct engagement with stakeholders, including location and size of proposed gatherings, frequency of engagement, categories of stakeholders (international, national, local) etc.

• Assess the level of risks of the virus transmission for these engagements, and how restrictions that are in effect in the country / project area would affect these engagements.

• Identify project activities for which consultation/engagement is critical and cannot be postponed without having significant impact on project timelines. For example, selection of resettlement options by affected people during project implementation. Reflecting the specific activity, consider viable means of achieving the necessary input from stakeholders (see further below).

• Assess the level of ICT penetration among key stakeholder groups, to identify the type of communication channels that can be effectively used in the project context.

Based on the above, task teams should discuss and agree with PMUs the specific channels of communication that should be used while conducting stakeholder consultation and engagement activities. The following are some considerations while selecting channels of communication, in light of the current COVID-19 situation:

• Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings;

• If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings. If not permitted, make all reasonable efforts to conduct meetings through online channels, including webex, zoom and skype;

• Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders;

• Employ traditional channels of communications (TV, newspaper, radio, dedicated phone-lines, and mail) when stakeholders to do not have access to online channels or do not use them frequently. Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions;

• Where direct engagement with project affected people or beneficiaries is necessary, such as would be the case for Resettlement Action Plans or Indigenous Peoples Plans preparation and implementation, identify channels for direct communication with each affected household via a context specific combination of email messages, mail, online platforms, dedicated phone lines with knowledgeable operators;

• Each of the proposed channels of engagement should clearly specify how feedback and suggestions can be provided by stakeholders;

• An appropriate approach to conducting stakeholder engagement can be developed in most contexts and situations. However, in situations where none of the above means of communication are considered adequate for required consultations with stakeholders, the team should discuss with the PMU whether the project activity can be rescheduled to a later time, when meaningful stakeholder engagement is possible. Where it is not possible to postpone the activity (such as in the case of

254 ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance.

Investment projects under preparation. Where projects are under preparation and stakeholder engagement is about to commence or is ongoing, such as in the project E&S planning process, stakeholder consultation and engagement activities should not be deferred, but rather designed to be fit for purpose to ensure effective and meaningful consultations to meet project and stakeholder needs. Some suggestions for advising clients on stakeholder engagement in such situations are given below. These suggestions are subject to the coronavirus situation in country, and restrictions put in place by governments. The task team and the PMU should:

• Review the country COVID-19 spread situation in the project area, and the restrictions put in place by the government to contain virus spread;

• Review the draft Stakeholder Engagement Plan (SEP, if it exists) or other agreed stakeholder engagement arrangements, particularly the approach, methods and forms of engagement proposed, and assess the associated potential risks of virus transmission in conducting various engagement activities;

• Be sure that all task team and PIU members articulate and express their understandings on social behavior and good hygiene practices, and that any stakeholder engagement events be preceded with the procedure of articulating such hygienic practices.

• Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings, and minimize direct interaction between project agencies and beneficiaries / affected people;

Employ traditional channels of communications (TV, newspaper, radio, dedicated phone-lines, public announcements, and mail) when stakeholders do not have access to online channels or do not use them frequently. Such channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions;

• Employ online communication tools to design virtual workshops in situations where large meetings and workshops are essential, given the preparatory stage of the project. Webex, Skype, and in low ICT capacity situations, audio meetings, can be effective tools to design virtual workshops. The format of such workshops could include the following steps:

- Virtual registration of participants: Participants can register online through a dedicated platform. - Distribution of workshop materials to participants, including agenda, project documents, presentations, questionnaires and discussion topics: These can be distributed online to participants. - Review of distributed information materials: Participants are given a scheduled duration for this, prior to scheduling a discussion on the information provided.

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- Discussion, feedback collection and sharing: ✓ Participants can be organized and assigned to different topic groups, teams or virtual “tables” provided they agree to this. ✓ Group, team, and table discussions can be organized through social media means, such as webex, skype or zoom, or through written feedback in the form of an electronic questionnaire or feedback forms that can be emailed back. - Conclusion and summary: The chair of the workshop will summarize the virtual workshop discussion, formulate conclusions, and share electronically with all participants.

• In situations where online interaction is challenging, information can be disseminated through digital platform (where available) like Facebook, Twitter, WhatsApp groups, Project weblinks/ websites, and traditional means of communications (TV, newspaper, radio, phone calls and mails with clear description of mechanisms for providing feedback via mail and / or dedicated telephone lines. All channels of communication need to clearly specify how stakeholders can provide their feedback and suggestions.

• Engagement with direct stakeholders for household surveys: There may be planning activities that require direct stakeholder engagement, particularly in the field. One example is resettlement planning where surveys need to be conducted to ascertain socioeconomic status of affected people, take inventory of their affected assets, and facilitate discussions related to relocation and livelihood planning. Such survey activities require active participation of local stakeholders, particularly the potentially adversely affected communities. However, there may be situations involving indigenous communities, or other communities that may not have access to the digital platforms or means of communication, teams should develop specially tailored stakeholder engagement approaches that will be appropriate in the specific setting. The teams should reach out to the regional PMs for ENB and Social Development or to the ESSA for the respective region, in case they need additional support to develop such tailored approaches.

• In situations where it is determined that meaningful consultations that are critical to the conduct of a specific project activity cannot be conducted in spite of all reasonable efforts on the part of the client supported by the Bank, the task team should discuss with the client whether the proposed project activities can be postponed by a few weeks in view of the virus spread risks. This would depend on the COVID-19 situation in the country, and the government policy requirements to contain the virus spread. Where it is not possible to postpone the activity (such as in the case of ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance.

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1. Appendix 7.3: PROTOCOL FOR CONSULTATION AND CIVIL WORKS UNDER COVID 19 ECOWAS REGIONAL ELECTRICITY ACCESS PROJECT (ECOREAP) IN THE GAMBIA

1.1 Introduction

The novel coronavirus disease (COVID-19) has been spreading rapidly across the world since December 2019, following the initial cases in Wuhan, Hubei Province, China. Whilst the pandemic imposed enormous strain on the health systems as they try to cope with the increase demand for services, it has also resulted in tremendous economic and social hardship as governments institute measures such as ‘social distancing’ to limit the spread of the disease. One of the consequences of these measures was the closure of schools, stoppage of civil works, trade and travel, closure of borders, and other economic activities.

A key source of guidance on communications, civil works, and stakeholder engagement that the Project will draw on is the Ministry of Health guidelines which are in line with the World Health Organization’s (WHO) “COVID-19 Strategic Preparedness and Response Plan: Operational Planning Guidelines to Support Country Preparedness And Response” (2020). These guidelines outline the following approach in their Risk Communication and Community Engagement - Pillar 2.

It will lay the basis for the Project’s stakeholder engagement and civil works implementation approach. The project will also draw on other recently-available resources for carrying out the implementation of the civil works in the context of COVID-19, including the World Bank’s “Technical Note: Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on conducting public meetings” (March 20, 2020). These guidelines will be taken into consideration for the civil works in order to protect workers, the affected communities and Project staff.

The Gambia has declared a state of Emergency, which is still maintained by the Authorities. Given the raising of the number of cases and the social distancing recommended in order to stop or reduce the COVID 19 transmission, the Project has decided to elaborate this Protocol in order to implement the upcoming stakeholder engagement and civil works implementation.

1.2 Methodology

To meet best practice approaches, the Project will apply the following principles for stakeholder engagement and civil works implementation:

• Openness and life-cycle approach: public consultations for the Project will be arranged during the whole lifecycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation

• Informed participation and feedback: information will be provided to and widely distributed among all stakeholders in an appropriate and accessible format and language; opportunities are provided for communicating stakeholders’ feedback, for analyzing and addressing comments and concerns

• Inclusiveness and sensitivity: stakeholder identification will be undertaken to support better communication about project activities and development, transparency, accountability and build effective community relationships. The participation process for the project will be inclusive and will consider vulnerable and disadvantaged groups to ensure they can attend

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and fully participate in discussions. All stakeholders are encouraged to be involved in the consultation process, and this includes ensuring that the time of day of meetings is suitable for women who may have different work schedules and commitments and that persons with disabilities are able to attend and participate. Every community member will have access to information. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods and the time and location of meetings. Special attention should be given to vulnerable groups, in particular women, youth, disabled, elderly and the cultural sensitivities of diverse ethnic groups. Consultations should be conducted with women in sex- segregated groups and in safe and enabling settings, which means that confidentiality can be assured and that these consultations will be facilitated by other women.

• Flexibility: if social distancing inhibits traditional forms of engagement, the methodology should adapt to other forms of engagement, including various forms of internet, radio, or TV communication, and communication via mail.

• A precautionary approach will guide consultation process and civil works implementation to prevent infection and/or contagion, given the highly infectious nature of COVID-19.Worker and Community Health and Safety: to avoid or reduce the risk of contagion or spreading the COVID-19, all workers will wear their mask, goggles and other personal protective equipment (PPE) and respect social distancing protocols at the site. Same measures will be followed in interactions with local communities.

• Affected Parties – persons, groups and other entities within the Project Area of Influence (PAI) that are directly influenced (actually or potentially) by the Project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures;

• Vulnerable Groups – persons who may be disproportionately impacted or further disadvantaged by the Project as compared with any other groups due to their vulnerable status21, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the project. Consultations should be conducted with women in sex-segregated groups and in safe and enabling settings, which means that confidentiality can be assured and that these consultations will be facilitated by other women.

1.3 Consideration of impacts on disadvantaged/vulnerable individuals or groups

It is particularly important to understand how project impacts may disproportionately fall on disadvantaged or vulnerable individuals or groups who often do not have a voice to express their concerns or may not be considered fully when addressing the impacts of a project. It is equally important that awareness raising and stakeholder engagement with disadvantaged or vulnerable individuals or groups be undertaken with respect to infectious diseases and medical treatments. Such consultations must be adapted to consider such groups and/or individuals concerns and cultural or other sensitivities and to ensure a full understanding of project activities and benefits. Consultations should be conducted with women in sex-segregated groups and in safe and enabling settings, which

21 Vulnerable status may stem from an individual’s or group’s race, national, ethnic or social origin, color, gender, language, religion, political or other opinion, property, age, culture, literacy, health status, physical or mental disability, poverty or economic disadvantage, and dependence on unique natural resources, among others.

258 means that confidentiality can be assured and that these consultations will be facilitated by other women. The vulnerability may stem from person’s origin, gender, age, health condition, economic status, disability, livelihood, among others. Engagement with vulnerable groups and individuals often requires the application of specific measures and assistance aimed at the facilitation of their participation in the project-related decision making so that their awareness of and input to the overall process are commensurate to those of the other stakeholders.

Within the Project, the vulnerable or disadvantaged groups may include and are not limited to the following: women-headed households, elders, youth, people renting land (especially women renters), youth, elders, and persons with disabilities. Vulnerable groups within the communities affected by the Project will be consulted through dedicated means, as appropriate. Description of the methods of engagement that will be undertaken by the project is provided in the following sections.

Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered.

1.4 Strategy

The PIU in collaboration with the stakeholders will identify and examine all the activities planned within the framework of the project requiring the engagement of stakeholders, public consultations, and civil works implementation.

The PIU and its consultants and future contractors will evaluate the targets, the location, and the size of the proposed activities. Personal contact and large social gatherings or meetings will be limited and all protocols from the Government regarding social distancing will be respected. The PIU and its consultants and future contractors will assess the level of risk of spread to the community and how best to align with restrictions in effect at the national level.

In addition, The PIU and its consultants and future contractors will identify the critical activities for which the consultations cannot be postponed without significant impact on the project deadlines. At the end of this exercise, the PIU will consider viable means to obtain the contributions and commitment of stakeholders.

Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered.

Where planned civil work activities require community meetings, PIU and contractors will assess how to put in place proper social distancing and make available PPE such as masks, eye shields, hand sanitizers, etc. for workers and community members.

Before consultation and civil works can start, the Project will require Contractors to identify and visit the affected communities.

The objective of this mission will be to:

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• The PIU and its consultants and future contractors will also assess the media coverage to see which media channels are more suitable for spreading information about COVID-19 preventive measures, who to contact if people are exhibiting symptoms, and how to contact the Grievance Mechanism (GM) should community members have additional questions or concerns.

• According to the affected areas, The PIU and its consultants and future contractors will review the best telecommunication coverage to decide which ones they will use to communicate with communities, considering the commitment to inclusive and accessible participation and communication.

• Traditional communication channels will also be assessed to verify how they can be effective in conveying relevant information to stakeholders.

According to the outcomes of field visits, The PIU and its consultants and future contractors will be able to start site preparation and sensitization of affected communities about the ESMP, GM, RAP, information about SEA/SH risks, especially around civil works, access to services, and how to lodge complaints through the GM, and COVID-19 mitigation measures that are recommended by the WHO and the Ministry of Health.

Following the field visit, the Project will implement specific measures to mitigate the risk of the COVID- 19 transmission.

A precautionary approach will guide the consultation process and the implementation of civil works to prevent transmission and infection, given the highly infectious nature of COVID-19.

The following are some considerations for selecting channels of communication and encouraging behavior for the safe implementation of the civil works, considering the current COVID-19 pandemic. Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered:

• Avoid public gatherings (considering national restrictions or advisories), including public hearings, workshops, community meetings, and in working sites

• As smaller meetings are permitted (Five people with distance of 1.5m distance between participants), consultations will be conducted in small-group sessions, such as focus group meetings. Efforts will be made to conduct meetings through telephone or, if possible, online, channels to reduce risk of contagion or contamination

• Employ channels of communications (TV, newspaper, radio, dedicated phone-lines, and mail) when stakeholders do not have access to online channels or do not use them frequently. Communication channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions

• Where direct engagement with project affected people or beneficiaries is necessary, identify channels for direct communication with each affected household via a context specific combination of email messages, online platforms, dedicated phone lines with knowledgeable operators

• communication channels during COVID-19 will also help women receive accurate information about SEA/SH risk, access to services, and the project GM

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• Each of the proposed channels of engagement will clearly specify to community members how feedback and suggestions can be provided by stakeholders via the project’s GM.

1.5 Management of COVID-19 during civil works

A special COVID-19 induction will be performed for each employee before they are able to start work. Female employees should also be independently consulted by a female facilitator in safe and enabling environments to ensure the impact of COVID-19 mitigation measures on women is properly considered. This induction will be entirely dedicated to COVID-19:

• How it spreads

• How to protect oneself (including washing protocols)

• How to properly use PPE (mask and gloves) and requirements of wearing PPE

• Understanding symptoms and what to do if one is exhibiting them

• Understanding the impact of COVID-19 on vulnerable groups (who is vulnerable)

This induction will be renewed for all workers every month and every day before the start of activities, a specific briefing will be carried out by the Site Manager who is the team leader.

The Site Manager will address the following points:

• Reminder of the context and the need to respect the rules

• Reminder of barrier gestures: how to cough, hand hygiene (basins and soap will be always available on site), social distancing and wearing a mask

• Taking of temperature every morning before works start

• Reminder of the exceptional measures applicable to the activities concerned

• Reminder of the main symptoms of COVID-19

• Reminder of the COVID-19 Hotline 1052

Monitoring of symptoms and other hygiene and mitigation protocols:

• Symptoms associated with COVID-19 will be monitored in workers. Each worker should monitor the onset of symptoms for themselves and colleagues and inform their manager immediately if they feel unwell or suspect a colleague is not feeling well. If symptoms appear during the night, the employee notify their superior and not come to the construction site. The procedure applied will then be the same as for employees who will be present in the morning with fever.

• The PIU and its consultants and future contractors will ensure the transportation to health centers by liaising with the COVID-19 Hotline 1052 in case ambulances of the health centers are not available.

• PPE must be clean and for individual use only (they must not be shared, exchanged, or loaned between employees). Barrier/social distancing against COVID-19 must be applied during break times and meals. Drinking water materials for personnel such as a cup or water bottle must be available for all workers and must not be shared for use among workers. Anyone who is not an employee of The PIU, and its consultants and future contractors will not have access

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to the site. Any visitor wanting access to the site must submit to the same COVID-19 mitigation controls as employees.

• Cleanliness, including sanitization, of personnel reception facilities must be maintained regularly throughout the day. Any waste likely to be infected must be managed to avoid any risk of contamination.

• The PIU and its consultants and future contractors will delimit the site and provide posters showing measures to be strictly followed by all who are on site.

• It is planned that about 10 people will be each work site. Workers must always wear masks, goggles, and maintain regular hand cleanliness. Hand sanitizers will be available in all strategic areas of the site.

• Equipment to take temperatures for all entering in the work sites should be available. In each site, Contractors will have two thermometers, regularly cleaned to avoid contamination in each site. Taking of temperature and management of the thermometers should be the responsibility of the ESHS officer.

• The contact information of the local COVID-19 committee (set up by the Ministry of Health under the Governor with all the relevant stakeholders in each region) COVID-19 1025 Hotline will be communicated to all workers. The contact number will be posted on site. The Project will closely work with this committee to implement the Project in a safely manner.

In line with the above precautionary approach, different engagement methods are proposed and cover different needs of the stakeholders as below:

• All in person meetings (such as consultation meetings, focus group meetings, one on one interviews (respecting social distancing requirements, wearing masks and eye shields)

• Public notices

• Electronic publications and press releases on the NAWEC website and social media, NAWEC Talk show radio and community radios in the Provinces

• Telephone Interviews

• Text messages communication

• Social media notices

• Posters erected in communities

At all times, the following COVID-19 mitigation measures will be followed in engaging with the public:

• Availability of hand sanitizers

• Thermometers in each working site

• Social distancing of 1,5 meters between workers

Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions, such as committees of elders, women, youth, but also communication of religious leaders like imams and the griot (traditional communicators.

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In the event none of the above means of communication is considered adequate for the required consultations with stakeholders, Contractors and service providers should discuss with the PIU to find out if the activity in question can be postponed at a later date, when significant stakeholder engagement is possible. When it is not possible to postpone the activity or when the postponement is likely to last more than a few weeks, the PIU should consult the World Bank team for advice and guidance.

1.6 Conclusion

During all this process, recommended WHO hygienic practices will be respected and monitored by the PIU safeguards team to ensure that mitigation measures would be properly followed and duly respected. As protocols and recommendations by the WHO changes in response to this pandemic, these protocols will be updated accordingly.

Appendix 8.1: Contract Clauses to be Included in Contractors’ Agreements

The rules, including specific prohibitions and construction management measures, should be incorporated into all relevant bidding documents, contracts, and work orders.

General Prohibitions: The following activities should be prohibited on or near the project site: ▪ Cutting of trees for any reason outside the approved construction area ▪ Hunting, fishing, wildlife capture, or plant collection; All employees, including volunteers and sub-contractors should be encouraged to anonymously report suspected or actual acts of hunting/killing of wild animal by a fellow worker ▪ Use of unapproved toxic materials ▪ Disturbance to anything with architectural or historical value ▪ Setting of fires ▪ Use of firearms (except authorized security guards) ▪ Use of alcohol by workers ▪ Employment of children in accordance with international law and the Children’s Act.

Protection of Trees and Vegetation:

▪ Remove vegetation around pole site only as necessary ▪ Ensure that only the right of way is cleared; avoid forests ▪ Cover area around the pole foundations to facilitate revegetation ▪ Seek approval from DOF before forest trees are felled ▪ Keep records (types and quantities) of all ‘forest trees’ to be fell

Waste Management: ▪ Develop a waste management plan including types of waste, expected quantities and frequency, proposed storage and disposal procedures and responsibilities, etc. Minimize the production

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of waste that must be treated or eliminated. If hazardous wastes are generated, proper procedures must be taken regarding their storage, collection, transportation and disposal. ▪ Do not burn any type of waste ▪ Waste must be collected and stored for disposal or treatment at approved sites as per waste management plan. Identify and demarcate disposal areas clearly indicating the specific materials that can be deposited in each. ▪ Clean waste such as cleared vegetation, packaging and rubble shall be given to workers or communities for reuse and recycling ▪ Set an internal supervision and monitoring system to ensure waste reduction and management. ▪ Control placement of all construction waste (including earth cuts) to approved disposal sites. Dispose in authorized areas all of garbage, metals, used oils, and excess material generated during construction, incorporating recycling systems and the separation of materials. ▪ Establish and enforce daily site clean-up procedures, including maintenance of adequate disposal facilities for construction debris.

Construction related measures:

▪ Ensure that all equipment maintenance activities, including oil changes, are conducted within demarcated maintenance areas; never dispose spent oils on the ground, in water courses, drainage canals or in sewer systems. ▪ To avoid soil compaction, use only approved and existing routes, do not establish new routes ▪ Grade existing routes to improve surface drainage. ▪ Avoid water sources and report any noticeable reduction in quality ▪ Remove excess and unused materials and equipment from work sites to improve the landscape ▪ Decommission all camps and bases including clearing of all waste

Quarrying realted measures: ▪ Where sand and gravel dealers are used, ensure only suppliers certified by the NEA and GD are used. ▪ Ensure approval is obtained from the NEA and GD for any proposed quarry site ▪ Fully implement the mine management plans ▪ All quarry pits created by the project must be rehabilitated after construction works ▪ Avoid extraction to the water table and near surface water bodies

Labour health and safety: ▪ Place signs and lighting at strategic locations informing community before works starts. ▪ Conduct safety training for construction workers prior to beginning work; provide induction and training on the job, safety issues and other relevant ESMP requirements. Drivers must also be trained on defensive driving.

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▪ Provide personal protective equipment and clothing (goggles, gloves, respirators, dust masks, hard hats, steel-toed boots etc.,) for construction workers and enforce their use. ▪ During heavy rains or emergencies of any kind, suspend all work. ▪ Safely store hazardous machinery and items away from the public. ▪ Educate on risks and prevention of STD/STIs ▪ Erect Speed bumps and speed limits. ▪ Make the hiring medical examination for all workers compulsory ▪ Sensitize on interpersonal relationship management between and among workers and community members; set codes of conduct ▪ Provide fire extinguishers and first aid kits including training on their use ▪ Provide constant supervision and record and report incidents to address causes for preventing recurrence and promoting improvement

Prevention of Violence against Children and Women:

▪ Ensure enforcement and adherence to Codes of Conduct for addressing VAC, GBV, and SEA, including regular monitoring and awareness building of the Codes of Conduct ▪ Do not employ or exploit children for project works ▪ Encourage women to enlist for employment in project activities without any impediments put in their way ▪ Develop a hiring plan that would include hiring labor from within the community giving equal opportunity to men and women ▪ Enforce and monitor Codes of Conduct for workers and all those involved in the project ▪ Sensitize about the Codes of Conduct for workers and community; ▪ Ensure survivor-centered approach to address GRM as per the procedures in the GRM (and Codes of Conduct) ▪ Conduct periodic training of employees on the codes of conduct and related procedures

Community Safety during Construction: The Contractor’s responsibilities include the protection of every person (workers and the public) and nearby property from construction accidents. The Contractor shall be responsible for complying with all national and local safety requirements and any other measures necessary to avoid accidents, including the following:

▪ Carefully and clearly mark pedestrian-safe access routes. ▪ If school children are in the vicinity, include traffic safety personnel to direct traffic. ▪ Restrict and monitor public access to the work sites ▪ Construction works within the Loumo area on a market day must be avoided ▪ Cover up the trucks, to prevent wind blowing away sand and gravel to generate dust ▪ Initiate sensitization and education programs for communities and workers on the dangers and mitigation measures to address STIs; Encourage use of condoms to prevent STIs

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▪ Carry out active monitoring of workers (screening, testing and analysis of such recorded data, etc.) to take timely action through treatment and health education to prevent spread of diseases ▪ Ensure surroundings are safe and secure for all (implement health and safety plan, coordinate, inform, supervise and monitor)

Nuisance and dust control should include: ▪ Maintain all construction-related traffic at minimum ▪ Cordoning off work sites to prevent access ▪ Use and maintain well-serviced equipment and machinery; avoid overloading that strain the engines to reduce noise ▪ In sensitive areas (including residential neighbourhoods, health centres, schools) more strict measures may need to be implemented to prevent undesirable noise levels, including controlled working times; works shall only be carried out during daytime ▪ Give prior notice to institutions amnd communitites about the works and work during weekends when activities are less around these institutions ▪ Minimize production of dust and particulate materials at all times, to avoid impacts on surrounding families and businesses ▪ Use dust suppression measures such as dampening on dirt roads, cut areas and soil stockpiles or fill material. ▪ Trucks transporting sand and gravel must be covered to prevent dust and flying debris ▪ Ensure that engines of vehicles and machinery are not idle for prolonged periods unnecessarily ▪ Apply proper measures to minimize disruptions from vibration or noise coming from construction activities.

Community Relations: To enhance adequate community relations, the Contractor should: ▪ Employ local unskilled workers to enhance community cohesion as local workers will know the community better, its culture, norms, and values, which may also help in reducing the risks of GBV, VAC and STIs. ▪ Inform the population about construction and work schedules, interruption of services, traffic detour routes as appropriate. ▪ Avoid construction activities at night.

Chance Find Procedures for Culturally Significant Artefacts: ▪ Avoid mosques, cemeteries, World Heritage Sites and similar sites of cultural significance ▪ Consult with the communities to help identify any other cultural or spiritual sites of importance

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In case culturally valuable materials are uncovered during excavation: ▪ Stop work immediately following the discovery of any materials with possible archaeological, historical, paleontological, or other cultural value, announce findings to project manager and notify the PCU who in turn notifies the National Council for Arts and Culture ▪ Protect artefacts as well as possible, using plastic covers, and implement measures to stabilize the area, if necessary ▪ Prevent unauthorized access to the artefacts ▪ Restart construction works only upon the authorization of the relevant authorities.

ENVIRONMENTAL AND SOCIAL SUPERVISION DURING CONSTRUCTION The “Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards, and Preventing Gender Based Violence (GBV) and Violence Against Children (VAC)” should also be considered in contracts. All bidding documents should indicate how compliance with environmental rules and design specifications would be supervised, along with the penalties for noncompliance by contractors or workers. Construction supervision requires oversight of compliance with the ESMP by the contractor or his designated environmental supervisor. Depending on the type and severity of breach, penalties may include: ▪ cancellation of contract ▪ suspension of works, and payment withheld until remediation has taken place without entitlement to claims ▪ existing penalties listed by various laws for specific breaches ▪ litigation for breaches of specific laws (by NAWEC, the relevant enforment institutions or affected parties). ▪ barring the contractor from future assignments of the World Bank and NAWEC

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Appendix 9.1: Modalities of the Proposed Grievance Redress Mechanism

Step Process Description / Timeframe Responsible Agency / Person Required Action 1 Receipt of Document date of receipt, 1 day GRC/PIU (specifically social safeguards complaint name of complainant, nature of specialist) complaint 2 Acknowledge By letter, email, phone 1-5 days Social safeguards specialist at the PIU receipt of grievance and Communicate Response 3 Screen and Visit the site; listen to the 7-14 days GRC members including the project establish the complainant / community; safeguard specialist, complainant, and foundation or assess the merit his/her representative merit of the grievance 4 If the complaint If yes, inform complainant of 21-30 days or Project Coordinator, SSS/ESS to has merit, the possible resolution. If no, at a time coordinate the implementation of GRC to proceed inform complainant, record specified in redress action with resolution. his/her response, and inform writing to the him/her of escalation measures complainant if he/she would like to proceed further (see 5) 4A Is resolution If yes, GRC move to implement 2-5 days Project Coordinator/SSS/ESS acceptable to and monitor measure. the complainant? Notify complainant when implementation is complete and ask complainant if he/she is satisfied and record response. If not, move to 5.

5 Extra If response is unacceptable to 2-4 weeks of Project Coordinator GERMP and GRC intervention for complainant, review the redress receiving to review and react a dissatisfied steps and conclusions, provide status report scenario intervention solution including resolution not acceptable to complainant/no t implemented properly/fully 6 Judicial Take complaint to court of law No fixed time Complainant adjudication 7 Funding of GRC logistics (costs of litigation, No fixed time GERMP grievance training), redress process compensation, court process

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Appendix 9.2: Flow Chart of Grievance Redress Process

Maximum Timeframe for implementation of Grievance Redress Action is 85 days from receipt of complaint

(1) PCU Receives Complaint PAP (1Day)

(3) Screen and Establish Merit (7-14 Days)

(2) PCU Acknowledges Complaint/Co (3A) Is Complaint mmunicate Acceptable? Response (1-5 Day) (1-5 Day)

(5) If Complaint is acceptable, then Implement and Monitor Redress action (21 – 30 Days)

(6) Extra Intervention for a Dissatisfactory Scenario (2 – 4 Weeks)

(7) Judicial Adjudication (No Fixed Time)

(8) Funding of grievance Process (No Fixed Time)

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