ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State THE NIGERIA EROSION AND WATERSHED MANAGEMENT PROJECT (NEWMAP)

Public Disclosure Authorized Public Disclosure Authorized

FINAL REPORT

Public Disclosure Authorized

OF

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) FOR OZURI GULLY EROSION SITE,

ADAVI LGA, KOGI STATE, NIGERIA

Public Disclosure Authorized OCTOBER, 2018

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

TABLE OF CONTENTS Page Table of Contents 1 List of Tables 5 List of Figures 6 List of Plates 7 Executive Summary 8 List of Acronyms 20

CHAPTER ONE: INTRODUCTION 1.1 Background 21 1.2 Description of the Proposed Intervention 22 1.3 Purpose of the ESMP 23 1.4 Objectives of the ESMP 24 1.5 Scope of Work 25 1.6 Methodology and Technical Approach 26 1.6.1 Technical Approach 26 1.6.2 Scientific Approach 31

CHAPTER TWO: INSTITUTIONAL AND LEGAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT 2.1 Federal Policy, Legal, Regulatory and Administrative Frameworks 32 2.2 International Conventions and Guidelines 33 2.3 World Bank’s Environmental and Social Guidelines 34 2.4 Nigeria EA Guidelines and World Bank EA Guidelines 35 2.5 Comparing the Nigerian Environmental Laws and the World Bank Operational policies 36

CHAPTER THREE: BIOPHYSICAL ENVIRONMENT 3.0 Introduction 39 3.1 Location 39 3.2 Relief and Drainage 42 3.3 Climate and Meteorology 43 3.3.1 Rainfall and Precipitation 43 3.3.2 Temperature 44 3.3.3 Relative Humidity 45 3.3.4 Sunshine Hours 45 3.3.5 Wind Patterns and Speed 46

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

3.4 Geology and Hydrogeology 46 3.5 Environmental Quality Assessment 47 3.6 Flora Study 50 3.7 Fauna Study 51

CHAPTER FOUR: SOCIO-ECONOMIC CHARACTERISTICS AND STAKEHOLDERS CONSULTATION 4.1 Socio-Economic Assessment 53 4.1.1 The Affected community and persons of the Proposed Project Area 54 4.1.2 Attitude of the Community to the Project 56 4.1.3 Infrastructures and Facilities 56 4.1.4 Quality of life and available social Amenities 56 4.1.5 Socio-Demographic Characteristics of Sampled Households a Ozuri 59 4.1.6 Population Estimation and Projection 59 4.1.7 Age and Gender Profile of Respondents 59 4.1.8 Current Marital Status of Respondents 61 4.1.9 Literacy level of Respondents 61 4.1.10 Occupation of Respondents 62 4.1.11 Residential Status and Duration of Residence of Respondents 63 4.1.12 Standard of Living of Sampled Individuals and Households 65 4.1.13 Household Monthly Income 65 4.1.14 Changes in respondent’s Standard of Living 66 4.1.15 Sources of Water 66 4.1.16 Security /crime rate 67 4.1.17 Solid Waste Management 67 4.2 Public Consultation 69 4.2.1 Objectives of the Public Consultation 69 4.2.2 Concerns 70 4.3 Health Impact Study 70 4.3.1 Assessment of Health Status of Respondents 70 4.3.2 Health Management Records of Respondents 70 4.3.3 Satisfaction with Medical Services 71 4.3.4 Prevalent ailment 71

CHAPTER FIVE: ASSESSMENT OF POTENTIAL IMPACTS AND ANALYSIS OF ALTERNATIVES 5.1 Introduction 73 5.2 Impact Identification and Evaluation 73 5.2.1 Impact Identification 73 5.2.2 Impact Qualification 73 5.2.3 Impact Rating 74 2

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

5.3 Summary of Associated and Potential Impacts Determination 77 5.4 Mitigation Measures for Ozuri Gully Erosion 94 5.4.1 Selection of Mitigation Measures 95 5.5 Risk and Danger Assessment/Management 96 5.5.1 Assessing risks at the start of a project 96 5.5.2 Assessing risks at the start of each phase 98 5.5.3 Managing the risks 100 5.6 Project Alternatives and Options 102 5.6.1 No Project Alternative 102 5.6.2 Delayed Project Alternative 103 5.6.3 Do project alternative 103 5.6.4 Technologies/Designs Option 103

CHAPTER SIX: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 6.1 Overview 105 6.2 Institutional Arrangement for ESMP and Monitoring Plan 105 6.3 Environmental and Social Management Monitoring Plan 134 6.3.1 Waste Management Plan 134 6.3.2 Recommended Measures for Waste Management 134 6.4 Emergency Response and Incidence Management 136 6.5 Recommended Measures for Chance Find/Cultural Heritage Management 136 6.6 Reasons for Failure in Gully Rehabilitation 137 6.6.1 Management of Rehabilitated Erosion Site 138 6.7 Grievance Redress mechanism 139 6.8 Gender Based Violence 142 6.9 Workers influx and Child-Labour Management 146 6.10 Community Security, Health and Safety Management 148 6.11 Stakeholders Engagement Plan 149 6.12 Fundamentals of Stakeholder Engagement Approach 150 6.13 Social Investment Plan 152 6.14 Project Coordination and Implementation Arrangements 152 6.14.1 NEWMAP Institutional Arrangement 152 6.14.2 Roles and Responsibilities 153 6.15 ESMP and Monitoring Budget 154 6.16 ESMP Disclosures 155

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

CHAPTER SEVEN: SUMMARY, RECOMMENDATION AND CONCLUSSION 7.1 Summary 156 7.2 Conclusion 156 7.3 Recommendations 156

REFERENCES 157

ANNEX ONE: Term of Reference 158 TWO: General Environmental Management Conditions For Construction Contracts/Civil Work 163 THREE: Study Methodology 169 FOUR: Household Questionnaire for the ESMP 179 FIVE: Waste Management Plan 182 SIX: The World Bank’s Approach to Grievance Redress in Projects 184 SEVEN: NEWMAP: Labor Influx and Gender Based Violence (GBV) 190 EIGHT: Minutes of the Meeting With Ozuri Community 194 NINE: List of Attendance for Ozuri Community Consultation Meeting 195 TEN: Summary of Triggered World Bank Environmental and Social Safeguard Policies 196

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

LIST OF TABLES Table 2.1: Relevant Federal/State Policies, Legislation, Regulations and Guidelines 32 Table 2.2: International Conventions, Agreements and Protocols 33 Table 2.3: Triggered Safeguard Policies 34 Table 2.4: Comparison of the World Bank OP4.01and the Nigerian extant Laws 36 Table 3.1: Results of Air Quality and Noise Level along the Erosion Corridor in Ozuri Community 47 Table 3.2: Physico-Chemical Analysis of Ground Water Sample form Ozuri Community 47 Table 3.3: Physico-chemical analysis of the soil along the Erosion corridor 49 Table 3.4: Microbiological Analysis of the soil along Erosion corridor 50 Table 3.5: A summary of Plant Species found in the Study Area 50 Table 3.6: Wildlife species Identified around the Study Area 51 Table 4.1: Accessible Sources of Water 67 Table 4.2: Community meetings - dates, location and attendees 69 Table 4.3: Prominent Ailments/Diseases in the Project Area 72 Table 5.1: Probability of Occurrence 75 Table 5.2: Consequences of Impact 75 Table 5.3: Risk Assessment Matrix 75 Table 5.4: Frequency rating Criteria 76 Table 5.5: Importance Criteria 76 Table 5.6: Perception Criteria 77 Table 5.7: Impact Value and Rating Colour Code 77 Table 5.8: Summary of Beneficial and Adverse Impacts 78 Table 5.9: Identified Potential Impacts and Rating - Pre Construction Phase 89 Table 5.10: Identified Potential Impacts and Rating - Construction Phase 91 Table 5.11: Identified Potential Impacts and their Ratings - Operational Phase 93 Table 5.12: Criteria for Selection of Control Measures for a Continuous Gully 95 Table 5.13: Risk severity prioritization table 99 Table 5.14: Identified Risk, Ratings and Response to Risk 99 Table 6.1: ESMP - Pre-Construction Phase 106 Table 6.2: ESMP - Construction Phase 114 Table 6.3: ESMP - Operational Phase 129 Table 6.4: Guide for HSE Training 149

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Table 6.5: Summary of ESMP and Monitoring Budget 154

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

LIST OF FIGURES Figure 1.1: Design drawings for the rehabilitation of Ozuri gully erosion site. 23 Figure 3.1: Map of Nigeria Showing Kogi State 40 Figure 3.2: Map of Kogi State Showing Adavi LGA 41 Figure 3.3: Map of Adavi LGA showing project location, Ozuri 42 Figure 3.4: Characteristics of Monthly rainfall within the Project Area 44 Figure 3.5: Temperature Characteristics 44 Figure 3.6: Characteristics of Relative Humidity within the Project Area 45 Figure 3.7: Monthly Daily Sunshine Pattern in the Study Area 45 Figure 3.8: Wind rose for Ozuri town 46 Figure 4.1: Chart showing flow of authority in the host community and the state 55 Figure 4.2: Sex of Respondents 60 Figure 4.3: Age of Respondents 61 Figure 4.4: Marital Status of Respondents 62 Figure 4.5: Educational Status of Respondents 63 Figure 4.6: Occupation of Respondents 63 Figure 4.7: Residential Status of Respondents 64 Figure 4.8: Duration of Residence in the Area 64 Figure 4.9: Household Monthly Income 65 Figure 4.10: Change in Standard of Living over the Year 66 Figure 4.11: security/crime rate 67 Figure 4.12: Waste management 68 Figure 4.13: Health Management Approach of Respondents 71 Figure 4.14: Prevalent ailment 72 Figure 5.1: Risk Assessment Process 96 Figure 5.2: Risk matrix 97

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

LIST OF PLATES Plate 4.1: photograph showing electric cables, transformer and BTS masts 56 Plate 4.2: Showing Educational Institutions in the study area 57 Plate 4.3: Housing condition in the host community 57 Plate 4.4: Borehole available to the resident 58 Plate 4.5: Access road to the host community 58 Plate 4.6: showing roadside shops in the community 59

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

EXECUTIVE SUMMARY E.S1 Background Information The Government of Nigeria is implementing the multi-sectorial Nigeria Erosion and Watershed Management Project (NEWMAP), financed by the World Bank, Global Environment Facility, the Special Climate Change Fund, and the Government of Nigeria. Kogi State Government has received an advance on the proceeds of a credit through the World Bank Assisted Project on The Nigeria Erosion and Watershed Management Project (NEWMAP) to finance the age-long erosion malaise in the State through the intervention of prioritized gully erosion sites in Kogi State, of which Ozuri Gully Erosion site shall be a beneficiary. Consequently, there is the need to assess the Environmental and Social Impacts of the intervention project by the Kogi State NEWMAP prior to the rehabilitation of the gully erosion site. Considering the category of the proposed project and the population of the affected people, an Environmental and Social Management Plan (ESMP) is inevitable.

E.S2 Objectives of the Environmental and Social Management Plan The objective of the ESMP is to develop procedures and plans to ensure that the mitigation measures will be implemented throughout the phases for the Rehabilitation of Ozuri Gully Erosion Site. It has also been prepared to ensure the effective long-term protection of the area and other biotic and abiotic components of the environment. The specific objectives among others include: a) Description of the environment; b) Identification of the environmental and social issues/risks associated with the existing conditions; c) Select and measure appropriate baseline indicators (for example, m3/sec of runoff collected in the sub watershed during a heavy hour-long rainfall) d) Develop a plan for mitigating and monitoring environmental and social risks associated with construction and operation in the gully in consultation with the relevant public and government agencies; Identify feasible and cost-effective measures that may reduce potentially significant adverse environmental and social impacts to acceptable levels;

E.S3 Project Alternatives Various alternatives to the planned rehabilitation of the Ozuri Gully Erosion Site were evaluated. These include:

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

• Do nothing approach • Rocklined chute • Wood drop structure • Vegetated overall structure The preferred alternative would be to implement the current project proposal, however with a combination of suitable alternatives to enable the project to achieve its objectives.

E.S4 Policy, Legal and Administrative Framework The requirement for an Environmental Assessment and Social Management Plan is in compliance with the Federal Republic of Nigeria’s (FRN) laws and World Bank policies that are geared towards achieving sustainable development goals through proper and adequate care for the environment, health and safety, and social well-being of her citizens. Hence, this report was prepared in accordance with NEWMAP provision of Environmental and Social Management Framework (ESMF), Project Appraisal Document (PAD), Product Implementation Management (PIM) and Resettlement Policy Framework (RPF). National Regulatory Requirements • National Policy on the Environmental, 1989 Revised 1991 • National Environmental (Soil Erosion and Flood Control Regulations, 2001) by NESREA • National Erosion and Flood Control Policy, 2005 (Technical Guidelines on Soil Erosion, Flood and Coastal Zone Management of FMEnv) • National Effluent Limitation Regulation, S.1.8& S.1.9 of 1991 • Management of Solid and Hazardous Wastes Regulations, S.1.15 of 1991 • Environmental Impact Assessment Act No.86 of 1992 • The defunct FEPA (now Federal Ministry of Environment) Act, 1992 • The Oil in Water Act, 1986 • Kogi State Environmental Sanitation Law • Kogi State Environmental Pollution Law • Waste Management Authority Law • National Environmental Protection S.I.8 and S.1.9 (For Effluent Limitation and Pollution Abatement for Industries and Facilities Generating Wastes Regulations) FMEnv, 1991. • Land Use Act of 1978 modified 1990

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

• Forestry Act of 1958 • Urban and Regional Planning Decree No.88 of 1993 • National Agricultural Policy of 1988 • Inland Waterways Authority(NIWA) of1997 • Kogi State Environmental Protection Edicts 1991 Existing Safeguard Instruments and Rationale for the ESMP ESMF and RPF are the existing safeguard instruments that address the eight triggered safeguards policies of the World Bank, namely: Environmental Assessment (EA) (OP4.01), Natural Habitats (OP4.04), Pest Management (OP4.09), Forest (OP4.36), Physical Cultural Resources (OP4.11), Involuntary Resettlement (OP4.12), Safety of Dams (OP/BP4.37) and Projects on International Waterways (OP/BP 7.50). The ESMP was designed to guard the process of the proposed intervention projects with a view to enhancing project benefits and introduce standards of good environmental practice for sustainable development in the State. Institutional Framework NEWMAP involves many Federal and State Ministries, Departments and Agencies (MDAs), Local Governments, Communities, and the Civil society. Effective implementation of projects requires inter-ministerial and inter-state coordination, collaboration, and information sharing. Thus, each component, sub-component and activity of the project was to be implemented through relevant federal and state MDAs. To this end, the various MDAs include those responsible for planning, economy and finance, works, agriculture, water resources, forests, transport, power, emergency response, as well as those focused on climate and hydrological information or watershed/basin regulation. The investments for Ozuri Gully Erosion Site in Adavi, Kogi State is being made through the Kogi NEWMAP, as Kogi State has the primary responsibility for land management and land allocations of the project site. The Federal Ministry of Environment (FME) is the lead implementing agency for NEWMAP. The Federal Project Management Unit (FPMU) headed by a National Coordinator hosted by FMEnv. is responsible for the overall coordination of the project. The Kogi State Project Management Unit (Kogi-SPMU), headed by the State Coordinator and hosted by Kogi State Ministry of Environment and Natural Resources, is responsible for project coordination in Kogi State, thus is directly responsible for the coordinating activities of the Ozuri Gully Erosion Site intervention including the implementation of this ESMP. Both the federal and state levels coordinating units have

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

environmental officers responsible for the main streaming of environmental issues into NEWMAP projects. The Kogi State environmental officer is directly responsible for coordinating the implementation of this Ozuri Gully Erosion Site ESMP on behalf of the State Project Coordinator. At the community level, the Ozuri Gully Erosion Site Monitoring Committee will effectively participate in ensuring full compliance during project implementation including civil work activities.

E.S5 Project Activities The project activities are to be carried out through civil works and biophysical cumbio engineering rehabilitation, such as tree planting and refilling part of the gully in order; construction of collector drains along the main roads overlooking the intervention area in order to prevent further runoff concentration along secondary roads; provision of proper interceptor drains to safely discharge water through chutes and stilling basins or baffled aprons (the transverse chutes are positioned at appropriate points adjacent the interceptor drains to prevent the occurrence of erosion next to the lined concrete channel); provision of concrete channels in infrastructure areas and check dams at the lower end of the gully site, and at suitable intervals at gully bed of the main gully; construction of a new rectangular channel in place of the existing damaged trapezoid alone, and provision of vegetation measures following construction of the engineering measures.

E.S6 Project Location The Ozuri erosion has its origin from Okunchi Hill, which lies within Latitude 7034’48.31”N and Longitude 6012’46.04”E at an elevation of 303m to the eastern axis of the community and empties into Obuburu stream lies within Latitude 7035’9.78”N and Longitude 6013’0.41”E at an elevation of 255m. As a result of storm water, surface run off and rugged terrain of the hill, it flows with high velocity across Obangede – Ogaminana road (lies within Latitude 7034’58.16”N and Longitude 6012’52.68”E at an elevation of 271m). into the residential community characterized by deposit of sand being washed from the hill as well as exposing the base of Ogaminana road, residential houses and LGEA foundations as well as graves. Ozuri community takes its origin from Kwararafa kingdom who migrated to Idah then to Ajaokuta and finally to Okunchi (Hill top) where they reside and finally to the present Ozuri about 100 years ago for farming activities.

E.S7 Environmental Baseline and Information of the Project Area

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Biophysical Environment An assessment of the biophysical environment of the study area covers the general climate and meteorology, air quality and noise level, water and soil quality, geology and the ecosystem, as well as flora and fauna resources. Most parameters measured in this regard were in conformity with local and international standards and mitigation measures were provided where the environment will be affected.

E.S8 Socio-Economic The affected community of Ozuri has its origin from Kwararafa kingdom. The people migrated to the present Ozuri about 100 years ago for farming activities. The political and administrative setting is based on native authority institution, where the village head (Onoba) is the head of administrative and judicial hierarchy, followed by the council elders and youth leaders. The community enjoys some infrastructural and social amenities such as Borehole water, electricity, a clinic and government primary and secondary schools amongst others. Majority of the residents of Ozuri depend on boreholes and hand dug well, for water needs. Other sources of water include springs and storm water. There are two government primary/secondary schools and three private secondary schools. Forty percent (40.0%) of the respondents has Senior Secondary School Certificate, 29.0% attended Primary school only, and 15.0% gained tertiary education. Housing type and quality is semi-modern built with concrete blocks and zinc/aluminium roofs. Family size ranges from 2 to 4 people per room. Estimation population is less than 4000 people. The community had no well-defined market structures. What exist in the community are retail outlet, roadside sellers and street hawkers. Respondent’s sex distribution is 58.20% males and 42.80% females. Respondents age group ranges between 46 and 65 years (64%); 18 and 45 years (20.5%). Overall mean result shows that about 80% of the respondents are between 18 and 65 years. The respondents occupation include; Farming, trading and civil servants.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

E.S9 Health There is a government owned primary health centre in Ozuri, operated by a nurse and two auxiliary nurses; other privately owned medical centre also operate within the community. Health incidences recorded during the time of study are malaria/typhoid fever, diarrhea and communicable diseases which are reflected by 60%, 25% and 10% respectively. There were no reported cases of cardiac problem, sexually transmitted disease and maternal mortality; although, during the time of survey, other emergency cases reported were being attended to and treated at some of the healthcare centres visited.

E.S10 Public Consultation The Public Consultation was carried out on 12th November 2017 in the Chief’s Palace. The minutes of the meeting is annexed to the report. Concerns were raised at the meeting over compensation for those whose houses and lands will be affected by the proposed project. Another source of concern was whether the youth will be involved in the project implementation, viz-a-viz, material supply by qualified suppliers. The people’s expectations are varied. Some bother on when project will commence, and when those affected by the project will be resettled.

E.S11 Summary of Potential Impacts for the Ozuri Gully Site Beneficial Environmental and Socio-economic Impacts The beneficial environmental and socio-economic impacts associated with the rehabilitation works will include: • Rehabilitation of the erosion menace in the project community • Repair of the watershed gullies • Provision of proper and well-designed road drainage systems • Provision of employment opportunities for both skilled and unskilled workers. • Encourage community development programs. • Reintegration of community and diversification of sources of livelihood. • Reduction of mortality rate. • Promotion of afforestation programs (with all its benefits) • Minimization of flooding and control of coastal overflow. • Reduced fear perception of loss of property, inhabitation and ancestral origins of the

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

communities. • Control and Reduction of water body sedimentation rates due to erosion. • Initiation/ kick-off of rapid production systems and agricultural practices. • Increase in social interactions • Improved livelihood enhancing activities • Gender Issues: Construction activities will encourage economic activities, especially for women. Since there would be a large workforce, petty traders and food-spots owners will benefit immensely from the demand on site. • Promotion of goodwill and community appreciation of the NEWMAP intervention in Kogi State and Nigeria at large. Adverse Environmental and Socio-economic Impacts Some adverse impacts that may be associated with the rehabilitation of the gully as highlighted in this report may include the following: • Increase in fugitive dust emission during preconstruction and construction phases of the rehabilitation. • Waste generation especially construction wastes. • Possibility of seepage of fuel from machineries and effluent discharge into the watershed, thus impacting on the water quality. • Site clearing will lead to loss of species diversity and abundance, including soil organisms, fungi, invertebrates, and bacteria. • Noise and vibration from heavy-duty project vehicles and equipment resulting in nuisance. • The frequency and incidence of occupational hazards may rise during construction activities.

E.S12 Project Alternatives Various alternatives to the planned rehabilitation of the Ozuri Gully Erosion Site were evaluated. These include: • Do nothing approach • Rocklined chute • Wood drop structure • Vegetated overall structure

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

The preferred alternative would be to implement the current project proposal, however with a combination of suitable alternatives to enable the project achieves its objectives.

E.S13 Environmental and Social Management Plan The ESMP included the various impacts discussed according to the respective phases during project implementation. The impacts have been described, as they will impact on the different environmental and social sensitivities. The mitigation measures, mitigation costs and institutional responsibilities were also highlighted in the ESMP matrix table.

ES14 Grievance Redress Mechanism The World Bank’s approach to GRM will apply (Annex 5); alternative conflict resolution and problem solving mechanism abound at local levels, 4 levels of grievance resolution mechanism have been propounded; summary of which have been highlighted below: Step 1: Assessment of Risks and Potential Grievances and Disputes; Step 2: Capacity Assessment Step 3: Action Plan Step 4: Follow-up and review To operationalize the GRM effectively, grievances have to be classified according to their potential severity or complications. One of the most common ground for grievances is land compensation entitlement and disbursement. This is likely going to generate grievances more constantly than any other issues about the project. More complicated matters like RAP and implementation issues that may involve private sector entities and third party agencies are likely to require the attention of the PMU. For the GRM to be effective as an all-inclusive engagement instrument that effectively handle the grievances of women, there has to be a deliberate structuring to include Women in Grievance Redress Committee, who will easily be approached by women for the purpose of presenting their grievances.

ES15 Gender-Based Violence Nigeria has an obligation to take all appropriate measures to prevent rape, ensure that there are adequate sanctions for rape in law and in practice, and ensure access to reparation for the victims.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Furthermore, Nigeria has to take special measures to protect the rights of individuals who are vulnerable to sexual violence, namely women, children, and persons with disabilities. The following actions are recommended for immediate implementation to reduce and mitigate the risk of GBV/SEA in the project area: a. Hiring a dedicated GBV/SEA specialist or retraining SLOs for the project, b. Including in the focal NGO’s ToR services for managing social risks associated with GBV/SEA in the project, c. Building and improving FPMU/SPMUs, local communities and other relevant stakeholders’ capacities to address risks of GBV/SEA by developing and providing guidance, training, awareness, and dissemination of relevant GBV/SEA materials to communities, d. Developing a clear KSG-NEWMAP specific internal “Reporting and Response Protocol" to guide relevant stakeholders in case of GBV/SEA incidents, e. Strengthening operational processes of KSG-NEWMAP project area on GBV/SEA, f. Identifying development partners and cultivating pragmatic partnership on GBV/SEA prevention measures and referral services, g. Developing Codes of Conduct for civil works contractors with prohibitions against GBV/SEA, h. Strengthening consultations and operationalizing GBV/SEA specific grievance redress mechanisms, i. Providing financial support implementation of the GBV/SEA actions described herein, including training and awareness building for various stakeholders, j. Establishing inter-ministerial committee to advance GBV/SEA actions

ES17 Labour influx and Child Labour The project may face an influx of non-local labour and working conditions issues as skilled labourers might not be available in some of the project sites. The project is expected to take concrete measures to mitigate potential labour influx-related risks such as workers’ sexual relations with minors and resulting pregnancies, presence of sex workers in the community, the spread of HIV/AID, sexual harassment of female employees, child labour and abuse, increased dropout rates from school, inadequate resettlement practices, and fear of retaliation, failure to ensure community participation, poor labour practice, and lack of road safety. These risks will require careful consideration to improve social and environmental sustainability, resilience and social cohesion. Therefore, the project will include mitigation measures such as:

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

a. assessing living conditions of workers’ camps and ensuring appropriate living conditions; b. establishing and enforcing a mandatory Code of Conduct for the company, managers and workers, and an Action Plan for implementation; c. ensuring appropriate location for these camps; d. taking counter measures - indicated in the Social Management Plan - to reduce the impact of the labour influx on the public services; and e. devising and implementing a strategy for maximizing employment opportunities for local population, including women.

ES18 Waste Management Plan Detailed information on waste management including the amount and type of waste to be generated, the sources and proffered mitigation measures, among other measures were provided in the ESMP. Integrated approach including soft sensitization and hard practical approach including the provision of basic facilities for waste management were developed.

ES19 Capacity Building Plan The capacity building is targeted at all parties concerned with the implementation of the ESMP, which include the contractor, KSG-NEWMAP SPMU (Environment and safeguards specialist, Project engineer, Social safeguards specialist) and community members especially the Ozuri gully erosion monitoring committee members. This is to ensure an In-depth understanding of the mitigation measures proffered by the ESMP. Personnel require appreciation of World Bank’s, Federal/State environmental policies, as well as, an application of these policies in implementing the World Bank support for Ozuri gully erosion control. Training modules will include; Construction Safety, Fleet Safety, Hazard Communication, Job Hazard Analysis, Disaster management and Accident Investigation.

ES 20 ESMP Cost of Implementation The total cost for Implementing the Ozuri Gully Erosion Site Rehabilitation Works ESMP is estimated at N43,178,850.00 (Forty Three Million, One Hundred and Seventy Eight Thousand Eight Hundred and Fifty Naira) only, at N365 per USD; that correspond to One Hundred and Eighteen Thousand Two Hundred and Ninety Eight US. Dollars [USD118, 298.00].

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ES 21 ESMP Disclosures After review and clearance by the World Bank, the ESMP will be disclosed at the FMEnv, Edo State Ministry of Environment and Public Utility and host LGA offices. The purpose will be to inform stakeholders about the project activities; impacts anticipated and proposed environmental management actions as well as to obtained the certificate of conformity from the Federal Ministry of Environment.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

LIST OF ACRONYMS CBO Community Based Organization EA Environmental Assessment EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan FEPA Federal Environmental Protection Agency FMEnv Federal Ministry of Environment FPMU Federal Project Management Unit FRSC Federal Road Safety Corps GBV Gender Based Violence GHG Green House Gas GSM Global Systems for Mobil HAZCOM Hazard Communication Program HIV Human Immunodeficiency Virus IUCN International Union for the Conservation of Nature and Natural Resource JHA Job Hazard Analysis JONAD Joint Organization of National Association of Disable KSEPB Kogi State Environmental Protection Board LGA Local Government Area NESREA National Environmental Standards and Regulations Enforcement Agency NEWMAP Nigeria Erosion and Watershed Management Project NGO Non-Governmental Organization NIWA Nigeria Inland Waterways Authority Nos Number NSCDC Nigeria Security and Civil Defence Corps OHSMP Occupational Health and Safety Management Plan OHSRA Occupational Health and Safety Risk Assessment OP Operational Policies PAD Project Appraisal Document 20

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

PAPs Project Affected Persons PHA Process Hazard Analysis PIM Project Implementation Manual RAP Resettlement Action Plan RPF Resettlement Policy Framework SA Social Assessment SEA Sexual Exploitation and Abuse SLM Sustainable Land Management SME State Ministry of Environment SPMU State Project Management Unit STD Sexual Transmitted Diseases TOR Terms of Reference WB World Bank

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

CHAPTER ONE: INTRODUCTION

1.1 Background Some parts of Kogi State are currently under the threats of gully erosion. It has numerous causes; and these causes can be both naturally and artificially-induced, but the underlying geology and the severity of accompanying surface processes play a key role. Observations have shown clearly that gully erosion is more prevalent in sedimentary terrain than in the basement complex of Nigeria. This erosion activity at various scales has resulted in the loss of lives and properties almost on a yearly basis. Solutions that have been proffered include public awareness campaign, improved farming techniques, cultural method of gully control, enactment of laws against any activities that favour gully growth, and thorough implementation of suggested solutions. The World Bank, in collaboration with Kogi State Government launched the Kogi State Nigeria Erosion and Watershed Management Project (NEWMAP), to tackle gully erosion that has been ravaging most parts of the state. Ozuri gully sites in Adavi LGA are among the eight erosion sites that are included as part of the rationale for the first phase of NEWMAP’s intervention project in Kogi State. NEWMAP has played key role in the protection of environment, by preventing pollution and retaining natural systems, alleviating danger and discomfort of flooding by providing drainage and managing flood risks in Kogi State. The NEWMAP intervention programme is also making efforts to avoid damage caused by erosion in the state; by controlling run-off and discharges and supporting sustainable development and giving respect to heritage for prosperity. The Nigeria Erosion and Watershed Management Project (NEWMAP), is an eight-year government led intervention project to prevent and reverse land degradation, focusing on major gully erosion sites that threaten infrastructure, livelihoods, and environmental assets. The Project Development Objective (PDO) is to reduce vulnerability to soil erosion in targeted sub watersheds. The project is being financed through a World Bank $500million credit with blended grants of $3.96 million from the Global Environment Facility (GEF), $4.63 million from the Special Climate Change Fund (SCCF) and US$150 million from the Government of Nigeria. The project has three operational components: a) Gully restoration, catchment management, and livelihoods; b) Capacity building in key national and state institutions related to erosion and watershed management; and

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

c) Climate change and alternative energy in rural areas. d) Project implementation at National and State. The FMEnv is the lead implementing agency for NEWMAP with Federal and State Ministries, Departments and Agencies (MDAs), Local Governments, Communities, and Civil Society (CSOs).The institutional arrangements for the project implementation are the Project Steering Committee, Technical Committee and the Project Management Units (PMUs) at both Federal and State levels as well as Liaison Offices and Site Committees at the Local Government level. The general principle is that the Federal Steering Committee is responsible for overall project coordination, alignment of project content and approach, and oversight of activities taking place across participating States through the Federal Project Management Unit (FPMU). The State Project Management Unit (SPMU) is responsible for the practical implementation of project activities within the specific frameworks set by the Project. The Project implementation started with seven (7) Southern States at inception. However, Kogi State is among 12 additional States included in the implementation after the approval of the Federal Government; whereby, more States are also on the waiting list to join the project. There is no fixed amount of the loan/grant proceeds allocated to each state but every state level of withdrawal depends, among others, on the state performance, level of devastation and capacity to draw down. The loan component of the fund is repayable within forty years with 10 years moratorium at Maximum Commitment Charge Rate on the Unwithdrawn Financing Balance of one-

half of one percent (1/2 of 1% which is 0.5%) per annum and a Service Charge on the Withdrawn

Credit Balance of three-fourths of one percent (3/4 of 1% which is 0.75) per annum.

1.2 Description of the Proposed Intervention The proposed solution focuses on three major approaches and addresses the risk of these gullies reforming in the future. It comprises the gully rehabilitation, upgrade existing waterfall channel and rehabilitation of existing roads and drainage infrastructures. The rehabilitation works will involve; construction of a set of side drains at both verge of Ozuri, construction of a concrete culvert designed to convey the flow and links, filling and compaction of fill to reclaim part of the gully head and its finger gully, construction of step-wise drop structure to dissipate a large part of the energy of flow, use of Flat gabion mattresslying on geotextile material, use of reno/gabion mattresses where necessary to protect the base from scouring, and re-vegetation with local grass and trees

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

within the distance of the gully and its finger. Upgrading of existing waterfall channel will involves; the construction of a trapezoidal channel 3000 mm x 1500mm, 1:1 side slope 930 m long along the new channel line and construction of a lined rectangular concrete channel 3000 mm x 2000 mm of 930 m long along the new channel line. This is design to accommodate the peak flow of 45 m³/s emanating from watershed runoff from the hilly rocky catchment upstream. The work on existing roads and drainage infrastructures will involves; construction of road side drains, provision of new culverts and rehabilitation of existing culverts, construction of new channels to convey water to the natural water channel and the reinstatement of existing roads including earth roads. Figure 1.1 shows Design drawings for the rehabilitation of Ozuri gully erosion site.

Figure 1.1: Design drawings for the rehabilitation of Ozuri gully erosion site.

1.3 Purpose of the ESMP The Environmental and Social Management Plan (ESMP) is designed to guide the implementation and operation of a project to eliminate or offset adverse environmental and social impacts or to reduce them to acceptable levels; and the actions needed to implement these measures. The ESMP is an integral part of Category “A” Environmental Assessments (EAs) (irrespective of other instruments used). EAs for Category “B” projects may also result in an ESMP. However, the impacts of the Ozuri gully erosion rehabilitation project are considered to be mainly site specific. The project will concentrate mainly on the rehabilitation which will include the construction of a set

24

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

of side drains at both verges of the road, construction of a concrete culvert designed to convey the flow, filling and compaction of fill to reclaim part of the gully head and its finger gully, construction of step-wise drop structure to dissipate a large part of the energy of flow, use of flat gabion mattress lying on geotextile material, use of Reno/gabion mattresses where necessary to protect the base from scouring and re-vegetation of the gully site with local grass and trees within the distance of the gully and its finger. Some houses are very close to the gully, so the civil engineering works will be concentrated at the areas closest to the erosion site to avoid breaking houses at Ozuri, and to ensure negligible adverse impacts on livelihood. The adverse impacts will be largely reversible, indirect and short term. Considering the aforementioned, the project falls suitably into the World Bank’s category B; hence the most suitable safeguard instrument to address beneficial and adverse impacts is an Environmental and Social Management Plan (ESMP). The ESMP provides a set of procedures through which NEWMAP will develop and implement environmental, social, health, and safety management systems, programs, processes and procedures that will establish a foundation for sound mitigation of adverse impacts, enhancement of positive impacts, institutional responsibilities, indicative costs for mitigation and eventual monitoring of the ESMP. The ESMP outlines Kogi State NEWMAP Project Management Unit’s corporate commitment to managing the project in a responsible, safe and sustainable manner whereby the protection of the environment, safety of people and social concerns take priority above all other business concerns. The ESMP is also designed to ensure compliance with applicable environmental standards all through the lifespan of the project. If the recommendations and guidelines in this ESMP document are followed, it is envisaged that the anticipated potential negative environmental and social impacts associated with the project will be markedly minimized, and the positive impacts enhanced. The Bank will disclose the ESMP document publicly, in Nigeria and at the World Bank Info-shop before project appraisal.

1.4 Objectives of the ESMP The objective of the ESMP is to ensure that the environmental and social impacts likely to arise from the projects activities are addressed and appropriate mitigation measures integrated into project implementation and operation in order to protect human and environmental health. The objective is consistent with the Terms of Reference for the ESMP provided. 25

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

The specific objectives of this study include the following: a. Describe the existing status of the sub watershed; b. Identify the environmental and social issues/risks associated with the existing conditions; c. Select and measure appropriate baseline indicators (for example, m3/sec of runoff collected in the sub watershed during a heavy hour-long rainfall); d. Develop a plan for mitigating environmental and social risks associated with construction and operation in the gully in consultation with the relevant public and government agencies; Identify feasible and cost-effective measures that may reduce potentially significant adverse environmental and social impacts to acceptable levels; e. Develop a time-bound plan for mitigating environmental and social risks associated with the sub-watershed management in consultation with relevant public and government agencies; Identify feasible and cost-effective measures that may reduce potentially significant adverse environmental and social impacts to acceptable levels; f. Identify monitoring objectives and specify the type of monitoring, with linkages to the impacts assessed and the mitigation measures described above (as in a-e); g. Provide a specific description of institutional arrangements: the agencies responsible for carrying out the mitigation and monitoring measures (e.g. for operation, supervision, enforcement, monitoring of implementation, remedial action, financing reporting, and staff training) and the contractual arrangements for assuring the performance of each implementing agency; h. Define technical assistance programs that could strengthen environmental management capability in the agencies responsible for implementation; i. Provide an implementation schedule for measures that must be carried out as part of the project showing phasing and coordination with overall project implementation plans; and j. Provide the expected capital and recurrent cost estimates and sources of the funds for implementing the ESMP and inform accordingly the design consultants so that these costs are duly taken into consideration in the designs.

1.5 Scope of Work The scope of work in the preparation of this ESMP includes: - Compliance with NEWMAP’s safeguard policy - Review the concept of Environmental and Social Management Plan (ESMP) 26

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

- Review the existing Federal and State Environmental Laws/legal framework;

- Identify those construction and/or rehabilitation activities that may have detrimental impact on the environment and the society in each of the lots; - Determine the mitigation measures that will need to be taken into consideration, and the procedures for their implementation;

- Define the institutional arrangements for implementing activities to mitigate adverse environmental impacts, suppressing or reducing them to acceptable levels; - Develop an Environmental and Social Management Plan (ESMP) with indicative costs for implementation.

- The ESMP includes the screening checklist and a matrix summarizing the identified risks, recommended mitigation measures, timeline for implementation, responsible party and associated cost per road. - The final ESMP focuses on the assessment of the inclusiveness of the risks identified.

1.6 Methodology and Technical Approach The study approach is in accordance with World Bank operational policy OP4.01 - Environmental Assessment which focuses on specific steps and procedures, policy and guidelines in preparing environmental management plan. Also, a number of national and international environmental guidelines are applicable to NEWMAP. In this context, analysis of the associated environmental variables was carried out in course of this study to assist in the scoping of baseline environmental characteristics of the project area, which are most representative of natural conditions and are most likely to be affected by the project development1.6.1 Technical Approach Study Approach Literature review and reconnaissance survey of the project area preceded field activity that included consultations, sampling and in-situ measurements. This was to enable the consultant carry out a successful field study execution. The field work activities started on the 7th of December 2017, running through 12th December 2017. This was presided by inception phase of between 23rd and 28th November 2017 of fieldwork. The post-inception phase fieldwork activities were carried out in the month of December 2017 in accordance with the FMEnv, World Bank (WB) and other international standards and guidelines.

Literature/Data Review

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Information and data on the project locations were demanded and obtained from Kogi NEWMAP which included engineering design, storm water master planning and conceptual design report, and other relevant information related to the gully erosion site at Ozuri. The following maps were obtained from Federal Surveys, Abuja; vegetation map, soil type map, geology and mineral deposit map. Also, for the purpose of gathering preliminary information, data were obtained from the following: - Nigerian Meteorological Agency for Climate and Meteorological Conditions from 1985 to 2015. - The Federal Department of Forestry for Vegetation and Soil Characteristics. - Nigerian Bureau of Statistics for Socio-Economic information and data. Relevant institutional, legal and regulatory guidelines and standards were obtained from the publications of FMEnv, World Bank and Kogi State Ministry of Environment of the project area.

Baseline Data Acquisition Methods Reconnaissance survey and delineation of the study area was carried out before data collection, with the objectives of setting boundaries of the study area. Visual observation within 2km radius of project sites were made to determine resources, population, land forms, feature, ecological characteristics, drainage, biological and human communities within and about the project area were surveyed. A professional team comprising experts in the various disciplines that cover the ESMP scope of work were assembled to execute the ESMP study. The ESMP Manager coordinated all field activities (baseline acquisition) and ensured quality in the work. Environmental safeguard policy of the World Bank was activated for a smooth implementation of the ESMP study. The sampling procedures adopted were designed to achieve scientific accuracy. The following methods were considered: • Phasing of samplings to identify the areas of interest. • Collection of soil samples: surface soil (depth of 0-15cm) and sub soil depth of (16-30cm and 31-60cm) to obtain data on the quality of soil. • Collection of ground water sampling from well and boreholes. • Quality of samples points identification/geo-referencing • Samples storage and preservation was ensured • Stratified random sampling

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Geographic co-ordinates of the sampling locations were obtained with the aid of a Garmin etrex GPS (Global Positioning System), with accuracy of about a meter. Control locations were selected and taken from pristine locations, 1.5km away from the project site and 5-8km from the communities. The geographic coordinates of the control location were taken. The baseline characteristics of the project areas were determined as follows: • Climate/Meteorology 35 years meteorological data of the project areas sourced from Nigerian Meteorological Agency (NIMET), Abuja. The data obtained covered the following parameters: temperature and evaporations, relative humidity, thunderstorm, rainfall, wind speed and direction. To complement the data, multi-data weather forecast application from the internet was used to determine a weekly forecast for all the study areas. • Air Quality The ambient air quality of the project area for dry season was determined by in-situ

measurement at different locations for the following parameters NO2, SO2, H2S, CO, NH3, and Suspended Particulate Matter (SPM). The SPM was measured using a digital Dust Indicator

Model P-SL2, while NO2, SO2, H2S, CO and NH3, were measured using NO2-meter,SO2- meter,

CO- meter and NH3 meter respectively. Samplings were done at 2-hour interval at each sample location for ten (10) hours. A maximum of 10 sample locations were carried out with mean value determined. • Sound Level The baseline sound level of the area was measured using Rion Sound pressure level (decibel) meter, NA model. Air quality measurement was carried out at ten (10) different locations spatially distributed across the watershed and its immediate environment. • Flora Separate sample quadrants (10m x 10m for trees, 2m x 2m for herbs and shrubs and 1m x 1m for grasses) were measured in different (five) sampling locations, which were randomly selected taking into account, plant species diversity or rarity density and dominance. Primary forest (if any) and homogeneous habitats were identified and sampled. Belt transects were laid as outlined by Sutherland (1977). In each quadrant, plant species were identified, woody species were enumerated and the vegetation structure observed. Unidentified plant species

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

and species whose identification were doubted were collected, given samples location coded number and pressed for identification and/or conformation of identification in an herbarium. Species identification and nomenclature followed the Flora of West Tropical African (Hutchinson and Dalzeil, 1952 – 1974), an outline in Nigeria vegetation (Keay, 1959) established for each vegetation type in the project areas using the data from the samples plots. Akobundu and Agyakwa (1989) was used extensively in the field. The leaves of plant species in each plot were examined for system of diseases and nutrient element deficiency. Where a particular disease was not diagnosed the diseased plant was taken to Labstaff Laboratory, Suite G05, Millipat Plaza, Airport Road, Abuja (Registered with FMEnv/NESREA) for proper identification of causative organisms. • Fauna The footprints, trails, nests, feaces and cells of birds and mammals were observed for evidence of wildlife presence. The approximate numbers of life in a location or between locations were estimated. The wildlife was also ascertained from interviews with local hunters, butchers and roaster shack operations, drawings and photograph of snakes, birds and mammals in Cansdale (1991), Nason (1992) and Booth (1991) respectively, for their confirmation of their presence in the project areas and their local names • Terrestrial Fauna Invertebrate Fauna: Quadrant sampling was used, at a sampling location, a 5m x 5m (25m2) quadrant was measured out (Maxwell, 1971: Slingby and Cook, 1989, Southwood, 1992) and the fauna within the quadrant were identified on sighting, enumerated and recorded directly into a previously prepared table. Insect and spiders were captured with an insect sweep net or by hand picking. The trials, feaces and burrows of animals and cast of earthworm were also used to indicate the presence and probable numbers of specific animals and species. Fauna: All the samples were collected by random sampling of a stretch of 0.5 km in the site as well interview with the locals. • Soil and Topography Soil samples were collected from the project area for dry season. A total of 10 soil samples were collected; that includes (0-15cm, 16-30cm, 31-60cm). Dutch auger of uniform cross section was used to ensure that uncontaminated and reproducible unit of soil samples were collected. Surface liters of undecomposed plant materials were removed to ensure that

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

uncontaminated soil samples were collected. Soil samples were collected in appropriately labeled and selected polythene bags in accordance with Standard Procedures of ASTM (Anon, 1994), FMEnv (1001) and APHS (1975), and kept away in a large “Ghana-must-go” bag in the field vehicle. Samples for physical analysis were dried in a dust free environment. • Land Use Pattern Physical observation and interviews were used to determine the land use pattern of the area. • Archeology Consultation and interviews with locals were used to identify and describe the social anthropology of the areas; shrines, burial sites and various aspects of the local culture, customs, religious beliefs, social taboos and sacred places. • Geology and Hydrogeology The regional and local geology and geomorphology of the areas were obtained from literature review and maps obtained from Nigerian Geological Survey headquarter, Abuja on the geology and landforms in Kogi State. Boreholes were used to study the geology and groundwater of the area. • Waste Management Waste inventory of the areas was carried out to identify the type and characteristics of waste generated in the areas and disposal route. • Community Health Interview with locals and community health clinic officials were used to determine the health status and disease inventory of the areas. Also, samples of community wells and stream were collected to check for suitability for drinking, domestic use or agricultural use. • Laboratory Analysis Laboratory activities were coordinated by Labstaff Nigeria Limited located at G03, G04, G05 Millipat Plaza by city gate, along Airport Road FCT, Abuja (registered with NESREA and Abuja Environmental Protection Board Laboratory) for the analysis of heavy metals and microorganism in soil and water samples. • Quality Control/Assurance For this project, a standard operating procedure was adopted in line with the principles of quality control and quality assurance. Sample containers, tools and points were key to the collection, handling, preservation, storage and laboratory analysis. It also forms the platform for

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

data analysis, result presentation and reporting. The holding time of the parameters were respected. Also, the equipment were calibrated to ensure consistency and accuracy. Both in- situ and ex-situ measurements were carried out depending on the holding analytical time for each parameter. Generally, the analytical procedures were consistent with both national and international standards. • Consultation with Stakeholders and Experts Experts in relevant fields, leaders of thought in environmental matters, and representatives of the host communities were consulted on issues relating to the potential ecological and socio- economic impacts of the proposed project. Also, the regulatory bodies were well consulted at both Federal and Kogi State levels by the consultants to ensure harmony and cooperation during the execution of the project. • Socio-Economics The questionnaire was structured to collect the baseline socio-economics of the area and it covered the following: General, Traditional and administrative structure, Culture, religion and archaeology, Population, etc.

1.6.2 Scientific Approach Air Quality and Noise Level Study Duration and Frequency The study covered a period of three weeks and measurements made between 0700 hours and (1830 hours throughout hours) throughout the study period. Materials Gaseous Emission Measurements The materials include; Model GP-204, Portable Combustible gas monitor for VOCs CO meter-ELE Toxic gas monitor NO meter-ELE Toxic gas monitor

NO2 meter-ELE Toxic gas monitor

SO2 meter-ELE Toxic gas monitor Total Suspended Particulate: Microdust 880nm Aerosol monitoring system Wind Speed Meter

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

CHAPTER TWO: INSTITUTIONAL AND LEGAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT 2.1 Federal Policy, Legal, Regulatory and Administrative Frameworks The requirements for an ESMP of this project derived from the following general national laws and enactments that stipulate and mandate project proponents to abide by the standard requirements for Sustainable Development, and in accordance with EIA laws of Nigeria. These are provided in Table 2.1 Table 2.1: Relevant Federal/State Policies, Legislation, Regulations and Guidelines S/N Policy Instrument Year Provision 1 National Policy on the 1989 This describes both the conceptual and theoretical frameworks Environment revised and strategies for archiving sustainable development in Nigeria 1991 2 National Erosion and Flood 2005 This addresses the need to combat erosion in the country Control Policy through the procedure outlined in the National Action Plan for Flood and Erosion and Technical Guidelines.

Legal/Regulatory Instrument Year Provision 1 Environmental Impact 1992 This provides guidelines for regulating the activities of Assessment Act No. 86, (FMEnv) development projects for which EIA is mandatory in Nigeria. The Act also stipulates the minimum content of an EIA as well as a schedule of projects that require mandatory EIAs 2 The National Guidelines and 1991 These represent the basic instrument for monitoring and Standards for Environmental controlling pollution in Nigeria Pollution Control in Nigeria 3 National Guidelines on (1999) This establishes the requirements for an Environmental Environmental Management Management System (EMS) in all organizations/facilities in Systems Nigeria 4 National Air Quality Standard 1991 This defines the levels of air pollutants that should not be Decree No. 59 of exceeded in order to protect public health. 5 The National Environmental 2007 This makes provision for solid waste management and its Standards and Regulations administration and prescribes sanctions for offences or acts, Enforcement Agency Act which run contrary to proper and adequate waste disposal (NESREA Act) procedures and practices 6 Land Use Act 1978 This is the primary legal means to acquire land in the country. Modified The Act vests all land in the territory of each state in the 1990 federation in the governor of the State and requires that such land be held in trust and administered for the use and common benefits of all Nigerians in accordance with the provisions of this Act 7 Endangered Species Act 1985 This provides for the conservation and management of wild life in Nigeria. It also provides and the protection of some of her endangered species from extinction. 8 FEPA/ FMEnv. EIA Procedural 1995 These indicate the steps to be followed in the EIA process guidelines through a project life cycle. 9 S115 National Environmental 1991 This regulates the collection, treatment, and disposal of solid Protection (The Management and hazardous waste for municipal and industrial sources and of Solid and Hazardous gives the comprehensive list of chemicals and chemical waste Wastes Regulations) by toxicity categories 10 S19 National Environmental 1991 These are imposed restrictions on the release of toxic Protection (The NEP (Pollution substances and requirements of Stipulated Monitoring of

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Abatement in Industries and pollution to ensure that permissible limits are not exceeded Facilities Generating Waste) during and after the project. Regulations) 11 S18 National Environmental 1991 This makes it mandatory for industrial facilities to install anti- Protection (National Effluents pollution equipment. It also makes provision for further effluent Limitations Regulation) treatment, prescribe maximum limit of effluent parameters allowed for discharge, and spells out penalties for contravention. 12 Public Health Law This deals with public health matters 13 Environmental Sanitation This deals with the general environmental health and Edits, Law and Enforcements sanitation. implementation and enforcement in the state. 14 Nigeria Inland Waterways 1997 Provide regulations for inland navigation and Authority(NIWA). ensurethedevelopmentofinfrastructuralfacilitiesforanationalinlan dwaterways network 14 Workmen Component Act 1987 This provides for occupational health and safety Revised 2010 Kogi State Policy & regulatory Instrument 1 Kogi State Ministry of This provide guidelines for flood and erosion control, forest Environment and Natural depletion and degradation and general environmental and Resources. Regulations on atmospheric pollution flood and erosion control and that of forest depletion 2 Kogi State Sanitation & Waste This provides for the compilation, transport, processing, Management Board recycling or disposal and monitoring of waste materials. 3 Kogi State Environmental Responsibility for general environmental matters in the State Protection Board

2.2 International Conventions and Guidelines Table 2.2: International Conventions, Agreements and Protocols to which Nigeria is Signatory and Applicable to the Kogi State NEWMAP in the Ozuri gully Site Table 2.2: International Conventions, Agreements and Protocols International conventions, Applicable Applicable Applicability to project How project address issues agreements and protocols to to Ozuri due to raised NEWMAP gully Site Yes No Yes No Both the Vienna convention [ x ] [ ] [ x ] [ ] Civil works may extend to ESMF has been prepared for the for the protection of the forest area. There will be NEWMAP and site-specific Ozone Layer and the reduction in tree taxonomy mitigation measures developed Montreal protocol for and biomass leading to in the ESMP. Provision of Control of Substances that reduction in carbon sink and vegetation measures following deplete the ozone layer. release of ODS gasses. construction of the engineering measures. Basel convention on the [ ] [x] [ ] [ x ] ESMF and ESMP do not NA prevention of trans- identify the use and or boundary movement of generation of hazardous hazardous wastes and their wastes in the project disposal. lifecycle. Convention on the [ x ] [ ] [ ] [ X ] No endangered species(s) NA prevention of the of any kind was identified in international trade in the project area.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

endangered species (CITES). Convention on Biodiversity. [ x ] [ ] [X ] [ ] Civil works may extend to ESMF prepared for NEWMAP areas covered by vegetation and site-specific mitigation but not reserve forest. This measures developed in the may disturb biodiversity in ESMP. Bioremediation measures the area. incorporated into the design of project. Convention on climate [ x ] [ ] [ x ] [ ] Proposed activities will ESMF prepared for NEWMAP change. results in both systemic and and site-specific mitigation cumulative environmental measures developed in the change thereby contributing ESMP. Bioremediation measures to sustained increase in incorporated into the design of temperature. project Convention on [x] [ ] [ x ] [ ] Proposed activities may Bioremediation measures Desertification. result in deforestation. incorporated into the design of project. Convention on Persistent [ ] [X] [ ] [X] No organic pollutant will be NA Organic Pollutants. used for activities design for the proposed project during it lifecycle. World Health Organization [x] [ ] [ x ] [ ] Proposed activities may be ESMF prepared for NEWMAP (WHO) Health and Safety injurious to man and the and site-specific mitigation Component of EIA, 1987. environment measures developed in the ESMP.

2.3 World Bank’s Environmental and Social Guidelines The main objective of the World Bank safeguard policies is to prevent and mitigate undue harms to people and their respective environment in the developmental processes. Table 2.3 provides the World Bank policies triggered by NEWMAP which are applicable to the specific project site in Kogi State. Table2.3: Triggered Safeguard Policies Safeguard Policies Triggered by Triggered by Applicability to How Project Address Policy NEWMAP? Site-specific Project due to Requirements Project? Yes No Yes No Environmental [x] [] [x] [] Civil works with Site- ESMF prepared for NEWMAP & Assessment specific impacts site specific mitigation measures (OP/BP4.01) developed in this ESMP

Natural Habitats [x] [] [] [x] NA* NA (OP/BP4.04) Pest Management [x] [] [] [x] NA NA (OP4.09) Physical Cultural [x] [] [x] [] Civil works with soil & there will be excavation works Resources (OP/BP4.11) ground movement involved in to address the gully erosion site rehabilitation

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Involuntary Resettlement [x] [] [x] [] Restriction of RPF prepared for NEWMAP & a (OP/BP4.12) access to sources of standalone RAP spells out site livelihoods. specific issues to be addressed & how. Indigenous Peoples [] [x] [] [x] NA NA (OP/BP4.10) Forests(OP/BP4.36) [x] [] [] [x] NA NA Safety of Dams [x] [] [] [x] NA NA (OP/BP4.37) Projects in Disputed [] [x] [] [x] NA NA * Areas (OP/BP7.60) Projects on International [x] [] [] [x] NA NA Waterways (OP/BP 7.50)

*NA = Not Applicable

2.4 Nigeria EA Guidelines and World Bank EA Guidelines The Environmental Impact Assessment Act No. 86 of 1992 requires that development projects be screened for their potential impact. Based on the screening, afull, partial, or no Environmental impact assessment may be required. Guidelines issued in 1995 direct the screening process. According to these guidelines, • Category I projects will require a full Environmental Impact Assessment (EIA). • Category II projects may require only a partial EIA, which will focus on mitigation and Environmental planning measures, unless the project is located near an environmentally sensitive area – in which case a full EIA is required. • Category III projects are considered to have “essentially beneficial impacts” on the environment, for which the Federal Ministry of the Environment will prepare an Environmental Impact Statement. With regard to environmental assessment, the Bank has also categorized projects based on the type of EA required, namely: • Category A - projects are those whose impacts are sensitive, diverse, unprecedented, felt beyond the immediate project environment and are potentially irreversible over the long term. Such projects require full EA. • Category B – projects involve site specific and immediate project environment interactions, do not significantly affect human populations, do not significantly alter natural systems and resources, do not consume much natural resources (e.g., groundwater) and have adverse

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

impacts that are not sensitive, diverse, unprecedented and are mostly reversible. Category B projects will require partial EA, and environmental and social action plans. • Category C - Projects are mostly benign and are likely to have minimal or no adverse environmental impacts. Beyond screening, no further EA action is required for a Category C project, although some may require environmental and social action plans. • Category FI – A proposed project is classified as Category FI if it involves investment of Bank funds through a financial intermediary, in road projects that may result in adverse environmental impacts. This World Bank categorization (A,B,&C) corresponds in principle with the Nigeria EIA requirements of Category I, II and III, which in actual practice is done with regard to the level of impacts associated with a given project. The relevant good practice guidelines/policies inline with the World Bank process shall be applied. This is more so since the proposed project is co- sponsored by the World Bank. However, it should be noted that in the event of divergence between the two (World Bank safeguard policy and Nigeria EA laws, guidelines and or standards) the more beneficial to the environment takes precedence between the two.

2.5 Comparing the Nigerian Environmental Laws and the World Bank Operational policies A comparison of the World Bank OP4.01and the Nigerian extant laws are presented in table 2.4 below. Table 2.4: Comparison of the World Bank OP4.01and the Nigerian extant Laws Aspects Extant EA Laws World Bank Ops Mandatory EA The law makes it mandatory for For all Bank supported project, consideration for proponents of all development projects EA, is required before approval of the proposed to undertake mandatory EA to project in order to ensure environmental and social ascertain the environmental sensitivity sustainability of the project. of the project whether EIA is required or not before proceeding with project implementation Projects for EIA All projects with significant adverse All projects with significant adverse effect whose effects on the environment impact can be mitigated through planning

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Exclusion from EIA 1. All projects that fall under category Projects that have been pre-determined to have no 3, implying that they have no adverse adverse environmental and social impacts, typical of environmental impacts category C projects. 2. Those in the list of projects which the President, Commander-in-Chief of the Armed Forces or the Council is of the opinion that the environmental effects of the project is likely to be minimal; 3. the project is to be carried out during national emergency for which temporary measures have been taken by the Government; Screening Required to be carried out at early Required to be carried out at early stage of project stage of project conception, planning & conception, planning & design to determine the design to determine the nature, scope, nature, scope, site, and environmental impacts. It site, and environmental impacts. It also also determines the category of the sub-project determines the category of the sub- project Category 2 categories-1, 2 and 3 3 Categories,-A,B, C and F1 1 and 2 required for further EA study A, B and F1 required for further EA study

Public engagement or Provides that opportunity be given to Public or community consultation is a continuous consultation government agencies, members of the process of public inclusion and participation in public, experts in any relevant discipline decision that affects any development project and interested groups to make comment on environmental impact assessment before final decision on the proposed development Pollution limit Guided & regulated by the national Guided & regulated by the Pollution Prevention and Control guideline & standard for environmental Abatement handbook, and also takes into account pollution control the borrower country’s legislation and local condition Social Sustainability The extant EIA laws anticipate and WB Ops is very rigid with social sustainability. It addresses social concerns but in a mainstreams vulnerability, involuntary resettlement rather non-stringent manner. In terms of and gender concerns in its EA concerns. project involving land acquisition, it In terms of project involving land acquisition, it compensates land for money subject to compensates land for land and compensation for right of ownership of land. Asset non-land asset is based on asset replacement compensation is based on the current amount at current market value irrespective of market value of the asset PAPs right to land being occupied. Disclosure Required to be carried out in accessible To be disclosed at two levels: in country and at public domain such as national daily, World Bank info shop FMEnv, SMEnv, LGAs and at the implementing institutions Concerns & Input of the public to be taken into Concerns & Input of the public to be account in further decision of the project taken into account in further decision of the project

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Management Plan Requires that mitigation measures be Requires that mitigation measures be offered to offered to adverse environmental adverse environmental & social impacts and an impacts and an EMP prepared to ESMP prepared to ensure management of the ensure management of the impacts to safeguards concerns. reduce adverse conditions

From the above, it is found that a lot of similarities exist between the World Bank operational policies and the Nigerian extant EA laws. However, where discrepancies exist, the more stringent one will take pre-eminence. Thus, for this ESMP, the Nigeria’s EIA requirements and World Bank operational procedures were harmonized as far as possible, hence it is made responsive to the objectives of good practice with regard to the followings: • Early consideration of environmental and social issues (starting at the screening stage); • Identification and early consultation with stakeholders; • Prevention of adverse impacts through the consideration of feasible alternatives; and • Incorporation of mitigation measures into planning and (engineering) design.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

CHAPTER THREE: BIOPHYSICAL ENVIRONMENT

3.0 Introduction The description of the existing biophysical environmental conditions of the project area draws on a number of primary and secondary data sources. Primary data source includes a one-season field sampling obtained through the environmental baseline survey conducted in December 2017. Laboratory analyses of the environmental media samples (soil and groundwater) were carried out at the Labstaff Nigeria Limited located at G03, G04, G05 Millipat Plaza by city gate, along Airport Road FCT, Abuja. The Lab is accredited by the FMEnv, NESREA, Abuja Environmental Protection Board Laboratory and other regulatory bodies. Secondary data sources (desktop studies/literature review) include research studies, maps, textbooks, and published literature relevant to the project area. The biophysical environment baseline information pertinent to the proposed intervention project area includes: a) Location; b) Relief and drainage; c) Soil and geology; d) Climate; e) Air Quality; f) Type of flora; and g) fauna and biodiversity

3.1 Location Adavi is a Local Government Area in Kogi State, Nigeria, is bounded to the North by Lokoja LGA, South by Edo State, West by Okehi LGA and East by Ajaokuta LGA. Okene LGA bounded it in the Southeast. It headquarter is the town of Ogaminana near the A123 highway in the southwest of the LGA at 7°36′05″N 6°12′01″E. It has an area of 718 km² and a population of 202,194 at the 2006 census. Figure 3.1, 3.2 and 3.3 show Kogi State in Nigeria, Adavi Local Government Area LGA in Kogi State and Adavi Local Government Area respectively.

Specifically, the Ozuri community takes its origin from Kwararafa kingdom who migrated to Idah then to Ajaokuta and finally to Okunchi (Hill top) where they reside and finally to the present Ozuri about 100 years ago for farming activities. Pa Odora was the first man to reside in Ozuri.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Ebira ethnic group form the indigenous population. However, because of its cosmopolitan status, there are bound of people from all parts of the State and Nigeria living in the community. Ebira is the main language spoken in the area as the area is predominantly dominated by Ebira people. Many non-indigenes live amongst them, such as Ibo’s, Igalas, Yorubas, Hausas, etc.

One of the major festivals of the area apart from the platitudinous Christian and Muslim festivals is Ekuchi. It is an annual festival held to mark the end of the lunar year. The unique occasion is characterised by the rendition of philosophical, thematic and dialectic songs by musicians and night masquerades. The other festivals which are celebrated are Echeane in June every year, Ebe in February and Echehana in September, to mark the beginning of eating of new yam. By virtue of its location within flood plain alongside hills, the people of Ozuri community embraced farming culture and thus, carried on successful trade and artistry.

N Kogi State

Figure 3.1: Nigeria Showing Kogi State

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Figure 3.2: Kogi State Showing Adavi LGA

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Figure 3.3: Map of Adavi LGA showing project location, Ozuri

3.2 Relief and Drainage The topographical landform of Adavi Local Government Area varies from undulating hills with valleys and plain lands. The plains and valley enhance settlement in the Eastern part while the remaining lowlands made settlement (human habitation) possible in other parts of the council. The physical uplands or mountains that characterised the area include Oborenyi hills, Okunchi Mountains, Anyioke hill, Anomi hills, Atami hills and Odumi hill while the lowlands are served with these uplands.Ozuri is drained by Obuburu stream; lies at southern axis of the community. It takes it source from Okene-Eba, flows through the foot of Okunchi to Ogaminana hill to Etegoza Stream forming Orro River during the peak of raining season. During dry season, the stream form ponds at deep depression which receive contaminated water from the community abattoir and as well as liquid waste from household located closed stream within the community. The stream channel has a width that ranged from 8m to 15m with the based characterised by rocks. Commonly observed along the stream are gallery of vegetation mostly with trees dominated by Azadirachtaindica, Jatropha coka, Elaeis guineensis, Chromolaenaodorata, and climbers. Due to the volume of waste

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

water being introduced into the pond of water along the stream channel especially from the community abattoir and cattle market and the high level of eutrophication of these ponds, sample of surface water from these ponds could not represent the actual quality of the stream while flowing. Hence, water samples from these ponds were not analysed.

3.3 Climate and Meteorology The climate in the study area is classified as ‘tropical savannah’ with two clearly marked seasons; wet (between April and October) and dry (between November and March). It is located within the humid tropical climatic region with rainfall being the single most important element for defining the climatic seasons.

3.3.1 Rainfall and Precipitation Rainfall regime is the pattern of rainfall distribution over the seasons and is determined by the two major air masses dominating the area: the moist tropical maritime (TM) with its associated westerlies and the dry tropical continental air mass (TC) with its associated easterlies. The movement of the ITCZ, a quasi-stationary boundary that separates the TC from the TM, further modifies the process. Average annual rainfall in the project area is about 1,140 mm, with the highest monthly rainfall occurring in July (on average, around 231.06 mm) and the lowest in December (on average, less than 0.2 mm). Figure 3.3 shows characteristics of monthly rainfall within the project area.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Figure 3.4 Characteristics of Monthly rainfall within the Project Area Source: NIMET, 2016 (25 years Average; 1991-2016)

3.3.2 Temperature Average temperatures remain fairly consistent throughout the year (fig 4.4), and these range from around 26oC in July to 32oC in March, with a pronounced dry season extending from November through to March. During this time, the climate is dominated by the dry north-eastern wind (‘Harmattan’).

Figure 3.5: Temperature Characteristics Source: NIMET, 2012 (24 years Average; 1992-2016)

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

3.3.3 Relative Humidity The relative humidity value is high and correlates with the rainfall. Overall, an average of 75.08% and 57.42% are recorded at 10:00hrs and 16:00hrs local time. Further assessment shows that the highest values are recorded in the early mornings. The lowest value of 68% in the region is recorded in February. During the dry season, values between 65% and 75% are common, while 90% humidity can be recorded in the raining season.

Figure 3.6: Characteristics of Relative Humidity within the Project Area Source: NIMET, 2012 (24 years Average; 1992-2014)

3.3.4 Sunshine Hours The intensity of the sunshine lasts longer in the dry season ranging between 7-9 hrs/day, while it is between 5-7 hrs/day in the wet season. The mean annual sunshine hour in the area is about 1,740 hours, with mean monthly values between 46 and 182 hours in July and January respectively (Fig 4.4).

Figure 3.7: Monthly Daily Sunshine Pattern in the Study Area

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

3.3.5 Wind Patterns and Speed The wind pattern in the area follows the migratory ITCZ. Thus, it is mainly southwesterly during the rainy season and northeasterly during the dry season. In general, the southwesterly swell is prevalent. The wind speed varies between 2 and 5 knots for most of the year with an average speed of about 5 knots. Incidences of severe storms are more frequent with some rare occasion coming as high as 55 – 60 knots. These are frequently associated with thunder and lightning during the rainy season more than any other time. The figure 3.8 below show the wind rose for ozuri town

Figure 3.8 Wind Rose for Ozuri town

3.4 Geology and Hydrogeology The geology of study area is made of the basement complex rocks of the Precambrian age extending slightly eastwards beyond the lower Niger Valley. The Precambrian rocks of Nigeria are grouped into three principal subdivisions. These are the ancient magmatite complex, the low grade schists and the plutonic series together with affiliated minor rocks which bear imprints of Liberian (in 2700 Ma), Eburnean (in 2000 Ma), and Pan African (in 650 Ma) tectonic events. The Precambrian rocks of the study area of the ancient magmatite complex.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

3.5 Environmental Quality Assessment Air Quality and Noise The results of measurement are presented in table 3.1. As presented in the table above, SPM, NO,

CO, and CO2 recorded values between 0.09mg/m3 and 0.12mg/m3, 0.01ppm and 0.03ppm, 0.00ppm, and 0.017ppm and 0.001% respectively; which are below FMEnv limit. Noise level as high as 69.6dBA and as low as 51.2dBA at an average was measure. The FMEnv limit for noise is 90dBA, which is greater than average result obtained along the gully corridor. Table 3.1: Results of Air Quality and Noise Level along the Erosion Corridor in Ozuri Community Sampling Latitude Longitude Time SPM NO CH4 CO CO2 VOC H2S S02 Noise Wind Code (N) (E) (am/pm) (mg/m3) (ppm) (%) (ppm) (%) (ppm) (ppm) (ppm) Level Speed dB(A) m/s A,N001 7034′ 58.34″ 6012′ 52.79″ 9:15am 0.09 0.03 0.00 5.6 0.017 0.00 0.00 0.00 69.6 0.9 A,N002 70 35′ 0.66″ 7012′ 56.12″ 9.32am 0.10 0.01 0.00 0.00 0.017 0.00 0.00 0.00 65.8 1.5 A,N003 70 35′ 2.79″ 70 12′ 57.74″ 9:48am 0.12 0.02 0.00 0.00 0.001 0.00 0.00 0.00 61.9 1.2 A,N004 70 35′ 6.48″ 70 12′ 56.06″ 10:20am 0.10 0.01 0.00 0.00 0.0 0.00 0.00 0.00 53.6 0.9 A,N005 70 35′ 9.34″ 70 13′ 0.73″ 10.43am 0.12 0.01 0.00 0.00 0.0 0.00 0.00 0.00 51.2 1.5 FMEnv 0.25 0.06 - 10 - - - - 90 - Source: Field Study, December, 2017 Physico-Chemical Analysis of the Water Samples Obuburu stream receive contaminated water from the community abattoir and as well as liquid waste from household located closed to the stream within the community. The stream is seasonal and was not flowing during the field study (dry season).There are, however, left over stagnant water along the stream channel. Due to the high volume of waste water being introduced into the stagnant water by the abattoir coupled with liquid and solid wastes from households along the stream channel which resulted to high level of eutrophication of the stagnant water, sample of water from the stream could not represent the actual quality of the stream while flowing. Hence, water sample from the stream was not analyzed. However, three (3) ground water samples (2 boreholes and one hand dug wells) from the community were analyzed and the results are presented in table 3.2 Table 3.2: Physico-Chemical Analysis of Ground Water Sample form Ozuri Community S/N Parameter WHO Limit FMEnv Limit BH001 BH002 HDW001 7035’7.55”N 7034’54.72”N 7034’48.54”N 6012’57.74”E 6012’57.36”E 6013’5.01”E 1 pH 6.5-8.5 6.5-8.5 7.05 7.02 7.23 2 EC(μS/cm) - - 51.09 68.13 81.56 3 Turbidity (NTU) 5 - 1.2 1.7 2.4 4 Temperature (0C) - - 20.1 22.8 21.3 5 Dissolved Oxygen(mg/L) - 7.5 2.9 3.2 2.6 6 Colourless Colourless Colourless Colourless Colourless Colourless 7 Odourless Unobjectionable Unobjectionable Unobjectionable Unobjectionable Unobjectionable

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

8 Total Dissolved Solid 200-600 500 32.7 43.6 52.2 9 Sodium (Na) (mg/L) - 200 3.9 2.5 3.9 10 Potassium (k+) (Mg/L) - 150 2.4 1.8 2.1 11 Calcium (Ca) (mg/L) 75-200 200 10 50 15.4 12 Oil/grease NIL NIL ND ND ND 13 Sulphate (SO42) (mg/L) 150-400 250 8.4 10.7 13.7 14 Nitrate(NO3-) (mg/L) 50 10 0.01 0.02 0.02 15 Lead (Pb) (mg/L) NIL Nil ND ND ND 16 Iron (Fe) (mg/L) 1.0 0.03 0.05 0.05 0.02 17 Mercury (Hg) (mg/L) NIL 0.002 ND ND ND 18 Chromium (Cr) (mg/L) NIL 0.10 ND ND ND 20 Copper (Cu) (mg/l) 0.01 0.01 ND ND ND 21 Manganese(Mn)(mg/L) 0.01 0.01 ND ND ND 22 BOD5@ 20 – 25oc - 50 2.0 1.3 2.2 23 Phosphate (mg/L) 50 50 0.7 0.5 0.8 24 Vanadium (mg/L) - 0.01 ND ND ND 25 Nickel (mg/L) - - ND ND ND 26 Zinc (mg/L) 5.00 0.01 0.01 0.03 27 Arsenic (mg/L) 0.1 ND ND ND 28 Cobalt (mg/L) Nil ND ND ND Total coliform Nill ND ND ND 29 Count(cfu/ml) Nill 30 Total Fungal Count(sml) Nil Nil ND ND ND 31 Total yeast count (cfu/ml) Nil Nil ND ND ND 32 Magnesium(mg/L) - 30 1.50 2.13 1.6 33 COD (mg/L) 90 5.1 4.4 8.1 Source: Field Study, December, 2017

Highest temperature of groundwater samples collected is 22.8oC. The pH value ranges between 7.02 and 7.23, which are within the WHO and FMEnv Limits of 6.5 -8.5, and slightly alkaline. The Total dissolved Solid (TDS) and electrical conductivity values ranges from 32.7 to 52.2 and 51.09 and 81.56 respectively. These values are far below the WHO (1991) limits of 1000mg/l and 1400µS/cm respectively. On the basis of these two parameters, the groundwater in this area is suitable for domestic purpose. The conductivity values of the ground water also indicate that it is suitable for irrigation. Overall, the chemistry of the ground waters represent the allomorphic phase of sediment modification (phase of ion exchange with clays, micas and feldspars) marked by mineral replacement such as quartz, chert, clay or feldspars by carbonates, feldspars by clays, aragonite and calcite, (Nwajide and Hoque, 1984.) Mg2+ and Ca2+, and K+ are most probably lithogenic.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Soil Physico-Chemistry The Soils of the study area is characterised by hydromorphic soil which contain a mixture of coarse alluvial and colluvial deposits. The alluvial soils along the valleys of the gully erosion route are sandy, while the adjoining laterite soils are deeply weathered and appeared grey to reddish in colour, sticky and permeable. The predominant soil types along the erosion are coarse textured, ranging from loamy to sandy loam in the surface horizons and from sandy loam to Coarse clay in the subsurface horizon. Table 3.3 present the Physico-chemical analysis of the soil along the erosion route while table 3.4 shows the results of microbiological analysis of the soil. The result of the soil analysis shows that the soil is made up of varying percentage compositions of sand, silt and clay. The pH values ranges between 6.35 and 7.10 during the time of study. This implies that the soil has slightly acidic to slightly alkaline characteristics. Slightly acidic and neutral soils are best for plant growth and micro-organism. The total hydrocarbon content was low.

Exchangeable anions detected in the analysis are SO42-, PO42-, Cl- and NO3-. The concentration of the Sulphate ion varies from 0.42mg/kg to 0.98mg/kg for SO42-, 0.10mg/kg to 0.20mg/kg for PO42-, and 0.34mg/kg to 0.78mg/kg for NO43-. The maximum concentration for Calcium is 7.30mg/kg while the minimum is 5.92mg/kg. The Cation Exchange Capacity of the soil was low. Cations detected in low concentrations were Magnesium, Potassium, and Sodium. The maximum concentration of the Magnesium was1.71 mg/kg. Table 3.3: Physico-chemical analysis of the soil along the Erosion corridor S/N Sample Code SS1 SS2 SS3 Parameter 70 35′ 2.17″ N 70 35′ 7.07″ N 70 35′ 9.43″ N (Units in mg /kg) 6012′ 58.23″ E 6012′ 56.94″ E 6013′ 0.73″ E Except stated 1. Depth (cm) 0-15 15-30 30-60 0-15 15-30 30-60 0-15 15-30 30-60 2. Moisture Content (%) 7.12 10.33 14.9 10.2 11.5 14.2 9.8 12.1 14.65 3. Sand (%) 51.20 35.50 42.00 52.60 37.50 44.00 55.00 34.50 44.50 4 Silt (%) 46.30 51.20 64.00 44.40 59.35 50.60 41.00 62.30 40.70 5 Clay (%) 2.50 3.30 4.00 3.00 3.15 5.40 2.00 3.20 4.80 6 pH 6.90 6.70 6.35 6.8 6.74 6.50 7.10 6.90 6.60 7 E.C (µScm-1) 167.8 156 143 282 175.2 169 262 244.2 231 8 Ca 6.68 6.21 5.96 6.84 6.78 5.92 7.30 6.90 6.45 9 Mg 1.71 1.52 1.26 1.32 0.81 0.68 1.67 1.29 1.02 10 K 7.61 6.68 6.02 8.65 5.76 5.03 8.90 6.48 6.13 11 SO42- 0.98 0.74 0.66 0.67 0.54 0.49 0.63 0.42 0.36 12 PO42- 0.11 0.10 0.10 0.12 0.10 0.10 0.20 0.12 0.10 13 NO3- 0.78 0.74 0.56 0.67 0.54 0.48 0.46 0.40 0.34 14 TOCmg/kg 0.32 0.23 0.09 0.18 0.12 0.11 0.28 0.16 0.10 Heavy metal 1 Fe 0.03 0.02 0.01 0.02 0.02 0.01 0.05 0.03 0.02 2 Cu 0.03 0.03 0.02 0.02 0.01 0.01 0.03 0.02 0.01

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

3 Pb ND ND ND ND ND ND ND ND ND 4 As ND ND ND ND ND ND ND ND ND 5 Mn 0.06 0.05 0.03 0.04 0.02 0.01 0.04 0.02 0.01 6 Cr (total) <0.011 <0.01 <0.001 ND ND ND <0.01 <0.01 <0.01 7 Ni ND ND ND ND ND ND ND ND ND 8 V ND ND ND ND ND ND ND ND ND 9 Zn 0.03 0.02 0.02 0.21 0.02 0.01 0.13 0.02 0.01 10 Hg ND ND ND ND ND ND ND ND ND Source: Field Study, December, 2017

Table 3.4: Microbiological Analysis of the soil along Erosion corridor Sample Code SS1 SS2 SS3 Coordinate 70 35′ 2.17″ N 70 35′ 7.07″ N 70 35′ 9.43″ N 6012′ 58.23″ E 6012′ 56.94″ E 6013′ 0.73″ E Parameter Depth (cm) 0-15 15-30 30-60 0-15 15-30 30-60 0-15 15-30 30-60 (cfu/g) (THB)X104 2.24 1.82 0.13 2.06 2.01 1.23 2.11 2.08 0.71 (HUB)X103 2.23 1.02 0.15 1.06 0.01 0.03 2.01 1.07 0.32

(THF)X103 1.21 1.02 0.12 0.01 1.01 1.26 2.08 1.06 0.24 (HUF)X102 0.22 1.82 0.14 0.06 2.01 1.13 0.11 1.05 0.11 Source: Field Study, December, 2017

3.6 Flora Study Vegetation commonly observed along the stream within the project area are gallery of vegetation mostly with trees dominated by Azadirachtaindica, Jatropha coka, Elaeis guineensis, Chromolaenaodorata, and climbers.Table 3.5 shows a summary of plant species found in the Study Area. Table 3.5: A summary of Plant Species found in the Study Area S/N FAMILY BOTANICAL NAME Abundance 1. Araceae Colocasia Esculenta + 2 Euphobiaceae Manihot Esculenta + 3 Euphobiaceae Recinus cuminis + 4 Euphobiaceae Phyllanthus amarus + 5 Euphobiaceae Jatropha Curcas - 6 Leguminosae Desmodium salicifolium - 7 Leguminosae Penthacletra macrophylla + 8 Leguminosae Parkia biglobosa + 9 Legumin-osae Calopogonium mucunodie + 10 Musaceae Musa sapientum +

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

11 Musaceae Musa spp. + 12 Nyetaginaceae Boerhavia diffusa - 13 Palmae Borasus aethoipicum - 14 Palmae Eleais guinearisis Iacq + 15 Papilionaceae Centrosema pubescens + 16 Papilionceae Crotalaria retusa + 17 Poaceae Panicum laxum + 18 Poaceae Pennisetum violaceum + 19 Poaceae Zea may + 20 Poaceae Secharum officinale + 21 Poaceae Imperata cylindrical + 22 Poaceae Pennisetum Purpureum + 23 Poaceae Pennisetum pedicellatum + 24 Lamiaceae Anthephora ampullace + 25 Cucurbitaceae Telfairia occidentalis + Key: + = Present; - = Not Present Source: Field study, 2017

3.7 Fauna Study Livestock production is common in the state, and common animals reared include goat and sheep. Poultry and fish farming are also practiced in the state. The wild life found in the state are dominated by birds (such as crows, black kites, ravens, crows, hornbills, doves and weaver birds), reptiles (including snakes and lizards) and mammals (including rats, rodents, squirrels, grass cutters, small deer, antelopes and monkeys. The Faunas in the study area are not IUCN threat status classified. Table 3.6 shows the fauna species Identified around the Study Area. Table 3.6: Fauna species Identified around the Study Area Class Species Common name Mode of detection Mammalian Aruicanthis niloticus + Mastomys roamys * Cristomys gambianus * Thryonomys swinderianus * Lepus zechi * Sylvicapra grimmia + * Gazelle sp. *

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Crocuta crocuta + Cercopithecus sp. * Pappio Anubis + Aves Stigmalopelia senegalensis * Streptopelia semitorquata + Peynonotus barbatus + Lagonostica senegala * Gentropus senegalensis * Turdoides plebeja + * Corvus albus * Ptilostomus afer * Francolin bicalcaratus * Tokus nasutus * Coracias abysassinica + Reptilian Naja nigricollis Agama agama + Kiniyxs erosa Crocodylus nilotis + * Python sebae + * Bitis ganica 11 Echis ocellatus Mollusca Archachatina marginata Limicolaria aurora Source: field work, 2017.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

CHAPTER FOUR: SOCIO-ECONOMIC CHARACTERISTICS AND STAKEHOLDERS

CONSULTATION

4.1 Socio-Economic Assessment The socio-demographic characteristics covered include amongst others; age, gender, education, income, occupation, residential and health status and standard of living rating. The survey is aimed at analyzing issues which include but not limited to the following; the effects of the project development on the receiving environment; the economic importance and benefits of the project to the public, the design to involve and carry along the host communities in a way of enhancing a people oriented and participatory project; the evaluation of the perception of the host community and their opinions without undermining their culture and health condition.

Methodology A mixture of investigative methods was used to acquire the socio-economic data. These include the following: • A review of secondary data relevant to the study; • Reconnaissance survey used to identify all persons in the community that will be directly or indirectly affected and to alert the community leaders and residents on the project; • Community consultation and Focus Group Discussions (FGDs) with stakeholder and project affected communities, especially adult men and women. The summary of it is provided as Annex 4. In-depth interviews with community leaders and some notable stakeholders and leaders in the affected community including chairman Ozuri Gully Intervention Site Monitoring, Committee, and state representative, Chief, Women Leader and Youth Leader were carried out. • Structured questionnaires (Appendix 3) were used to elicit baseline information from 100 randomly selected respondents and the perception of the Project Affected Persons (PAPs) on the gully erosion intervention across the affected community within the gully erosion area. The questionnaire contained five sections of structured questions covering the required information on household socio-demographic information, health status, standard of living, cultural property and gully erosion/proposed intervention impacts. Besides, the questionnaire addressed the different aspects of the gully erosion menace such as the trend, regularity, causes, impacts and 54

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

the management strategies employed by the affected individual and communities in the study area. • Simple random sampling was used for the administration of the questionnaire. Population estimation was based on the combinations of questionnaire survey and projection from 1991/2006 census figures by the National Population Commission (NPC). 100 questionnaires were administered and returned. • Field observations by the consultants and interviewers; the assessment also utilized personal observation methods and Focus Group Discussion. Finally, the analysis uses inferential statistics to draw conclusion on which the mitigation measures were based on.

4.1.1 The Affected community and persons of the Proposed Project Area The host community of the gully erosion project, Ozuri is located on latitude 7035’3.32”N and longitude 6012’58.67”E on an altitude of 247m above sea level in Adavi LGA of Kogi state. Ozuri community takes its origin from Kwararafa kingdom who migrated to Idah then to Ajaokuta and finally to Okunchi (Hill top) where they reside and finally to the present Ozuri about 100 years ago for farming activities. Pa Odora was the first man to reside in Ozuri. He was followed by Pa Isa’a Anamori, Opo and finally Edoh. Odora belongs to the Ezukaasema clan, Isa’aanamori is from Eziogu clan, Opo is Oziobaji clan.

People and Languages Spoken Ebira ethnic group form the indigenous population. However, because of its cosmopolitan status, there are bound of people from all parts of the State and Nigeria living in the community. Ebira is the main language spoken in the area as the area is predominantly dominated by Ebira people. Many non-indigenes live amongst them, such as Ibo’s, Igalas, Yorubas, Hausas, etc. Culture One of the major festivals of the area apart from the platitudinous Christian and Muslim festivals is Ekuchi. It is an annual festival held to mark the end of the lunar year. The unique occasion is characterised by the rendition of philosophical, thematic and dialectic songs by musicians and night masquerades. The other festivals which are celebrated are Echeane in June every year, Ebe in February and Echehana in September, to mark the beginning of eating of new yam. By virtue of its location within flood plain alongside hills, the people of Ozuri community embraced farming culture

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State and thus, carried on successful trade and artistry. Civil service is another famous occupation among them. The access road linking this community to the road is tarred while those within the community are footpaths and earth roads. However, the community enjoys some infrastructural and social amenities such as Borehole water, electricity, a clinic and government primary and secondary schools amongst others.

Traditional Governance The political and administrative setting is based on native authority institution, where the village head (Onoba) is the head of administrative and judicial hierarchy, followed by the council of elders and youth leaders. Decisions are made after due consultation with the village/ward head of Ozuri community and approval given by him. Below is the hierarchy of traditional administrative settings.

Atah (emir)

Ohinoyi

Chief/district head

Village/ward head

(onoba) Elders

Youth leaders

Figure 4.1: Chart showing flow of authority in the host community and the state

Settlement of dispute is done by the elders. Where the elders are unable to resolve it, they forward the case to the village/ward head (onoba) where the chief will call on all the other elders to settle the case. The highest punishment within the chief is lashing the offender with whip while other critical offenders are handed over to the police.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

4.1.2 Attitude of the Community to the Project Residents of Ozuri community showed positive attitude to the project as they are happy that the project will help reduce the gully erosion in the area. The chief and elders of this community on behalf of the community used the forum to appeal to the proponent to help with some of the basic social amenities.

4.1.3 Infrastructures and Facilities The infrastructures and facilities observed around the project area include Base Transmission Station (BTS) masts of different network providers, High tension Electric lines, feeders (earth) roads, boreholes, amongst others.

4.1.4 Quality of life and available social Amenities Electricity Supply - The host community has access to electricity through (National grid) with transformers being installed to power the community. However, some other residents depend solely on private generators as an alternative to electricity. Plate 4.1 shows electric cables, transformer and BTS masts in the study area

Plate 4.1: photograph showing electric cables, transformer and BTS masts

Educational institutions - Ozuri community is blessed with a host of educational institutions. Survey shows availability of two government primary/secondary schools and three private secondary schools which include; Success group of schools, Uka group of schools and Rodia group of schools. Both private and government schools were observed during the survey. Plate 4 .4 Shows educational institutions in the study area.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Plate 4.2: Showing Educational Institutions in the study area

Housing condition - The type and quality of houses within this project environment is semi- modern. Houses are built with concrete blocks and zinc/aluminium roofs. Some amongst the houses in the host community are of low grade built with mud blocks without proper foundation. This settlement has an estimated number of 1000 houses with a family of 2 to 4 people per room. By estimation the area is occupied by less than 4000 people as its total population. Plate 4.5 shows housing types in the host community.

Plate 4.3: Housing Types in the host community

Sources of water - Majority of the residents of Ozuri depend on boreholes and hand dug well, for water needs, that is, for cooking, washing and other domestic uses. In some cases, the people use water they directly source from Ademehe and Ahucheba springs which are about 1km from ozuri and storm water while water board is absent in the community. The boreholes are about 35m deep

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State and about 4 Bore holes and overhead storage tanks were observed as at the time of this study. Plate 4.6: shows borehole available to the resident of the study area

Plate 4.4: Borehole available to the resident

Transportation - The major access road to the community is the single lane of the Obangede- Obaminana road. Other roads that exist are earth roads linking the community with other communities. Private cars, taxis, commercial buses and bicycle are common means of transportation as observed in the community. Plate 4.7 shows access road to the host community

Plate 4.5: Access road to the host community

Markets - The community had no well-defined market structures. What exist in this part of the community are retail outlet, roadside sellers and street hawkers. Most of residence makes use of Ogaminana market which is about 2km from Ozuri. Plate 4.8 shows roadside shops in the community.

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Plate 4.6: showing roadside shops in the community

4.1.5 Socio-Demographic Characteristics of Sampled Households a Ozuri This section deals with socio-demographic features of sampled individuals and households through the administration of structured questionnaires within the proposed NEWMAP Gully Erosion Intervention project area. The socio-demographic assessment of the respondents included their age, gender, education, marital status and monthly income etc. In this regard, the distribution of responses with the above variables illustrates the attitudes towards several other desirable attributes related to the information rendered. The socio-demographic information measured gives an insight into the socio-demographic characteristics of the Project Affected People (PAP) in the area.

4.1.6 Population Estimation and Projection Ozuri community is in Adavi LGA. Its headquarters are in the town of Ogaminana. The LGA has an area of 718 km².Available information revealed that, the project affected community did not have a given population record. Thus, the population of the entire LGA in which they are sited were used. In other words, the population size was estimated using the population of Adavi Local Government Area in which the proposed project is situated and also results from the questionnaires distributed. The figures below depict population estimates by the National Bureau of Statistics (NBS) in the 2006 National population census. This gives an annual growth rate of 3.0 %. As presented in the Figures, the population estimates for Adavi LGA at the 2006 census, is approximately 202,194. Ozuri in particular has an estimated 8,000 inhabitants.

4.1.7 Age and Gender Profile of Respondents Gender characteristics give comparative proportion of males and females in the sample frame while age distribution provides a reflection of age structure of the respondents and households of

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State the project affected persons. The sex distribution of the respondents depicts that, 58.20% of sampled individuals who were available to respond to the survey are males while 42.80% are females (Figure 4.2). However, this survey can be related the sex distribution of Adavi local government area. With respect to age, the distribution of the respondents and households in accordance with encoded age groups is contained in Figure 4.3 below. As depicted in the Figure, the foremost respondents fall between 46 and 65 years (64%) and this was followed by those between 18 years and 45 years which account for 20.5% of the sampled frame. Overall mean result shows that about 80% of the respondents are between 18 and 65 years. The least responses (1.0%) are below 18 years but not less than 15 years. The responses above 65 years who are mainly retirees account for 14.5% (15 individuals). The overall pictures of gender and age though with returns for women shows a good quality representation necessary in a field survey.

Source: Field Survey, 2017 Figure 4.2: Sex of Respondents

Source: Field Survey, 2017 Figure 4.3: Age of Respondents

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4.1.8 Current Marital Status of Respondents Respondents were examined to understand if they had ever been married or lived with a man, and if yes, whether they were currently married, living with a man, widowed, divorced or separated. However, none of the respondents reported themselves as living with a man without formal marriage. For this rationale, the categories "married" and "living with a man" were pooled and indicated as "married" in the assessment. From the survey, 32.5% indicated that they had never been married, 58.0% were married, 5.5% are widowed and 4% were divorced or separated (Figure 4.4). The high volume of „couples‟ has inferences for which there is a potential population increase. This high proportion also determines the household type, the consumption power and the infrastructure needs of the project affected people.

Source: Field Survey, 2017 Figure 4.4: Marital Status of Respondents

4.1.9 Literacy level of Respondents The survey on the educational status of the respondents indicates that the highest proportion of 40.0% respondents has Senior Secondary School Certificate. This is followed by other educational qualifications of the respondents that had at-least attended primary school29.0%. The percentage of respondents who attended tertiary excluding university are 15.0%, university graduate 5%while those that had attended university post graduate amount to only 1%. Few percentage 10% of the respondents are either school dropout or had no educational background (Figure 4.5)..

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Source: Field Survey, 2017 Figure 4.5: Educational Status of Respondents

4.1.10 Occupation of Respondents The main occupations identified in the community are indicative of the semi- urban communities in Nigeria, consisting of farming, trading, civil service etc. Trading varies from a small shop in front of a house to large scale buying and selling in local markets. Other common occupations include artistry. Men are generally accountable for engaging in heavy work whereas women are more likely to be involved in other informal sector activities, such as small-scale trading. Main important crops include yam, cassava, maize, plantain, banana, while okra, peppers and other vegetables and crops are also grown in smaller quantities. Livestock nurture is also an important occupation, typically on a smaller scale, as large scale intensive livestock operations could not be identified in the area. The survey data on the employment status of the sampled population illustrate that about20% of the total respondents are farmers. This was behind civil servants whom constitute about 23% of the sampled respondents. Respondents who engaged in trading and shop keeping had an estimated proportion of 35.5%. Others include artisans and the self-employed who had estimated figures of 17.5% and 10.0% respectively (see Figure 4.6).

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Source: Field Survey, 2017 Figure 4.6: Occupation of Respondents

4.1.11 Residential Status and Duration of Residence of Respondents The distribution of the residential status and the duration of residence show most of the respondents85% are permanent residents in the proposed project area. The respondents identified as returnees (Back Home Residents) had an estimated figure of 10% of the sample frame. This is followed by the visitors‟ interviewed who are not permanent residents but who are relatives of the households; they account for 5% of the respondents (Figure 4.7). The residential status of the respondents has an implication on the other information provided as permanent residents with reasonable length of stay will have a sound knowledge of the gully history and appreciate the need for sound environmental mitigation measures during the phases of the gully intervention.

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Source: Field Survey, 2017 Figure 4.7: Residential Status of Respondents

The distribution of the respondent’s duration of residence in the study area is presented in Figure 3.9. As shown in the Figure, the highest proportion of the respondents and households with the highest percentage of 60% of the total sampled population has lived for more than twenty years in the proposed intervention project area. The respondents who have lived for an average of ten years (11-15 years) in the area had an estimated proportion of 25% of the sampled frame (Figure 4.8). This implies that about 90% of the total respondents have stayed long enough in the area to provide reliable information on the socio-economic condition of the PAP as well as information on how the proposed intervention will impact on the livelihood of the people.

Source: Field Survey, 2017 Figure 4.8: Duration of Residence in the Area

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4.1.12 Standard of Living of Sampled Individuals and Households Standard of living is defines as the intensity of material comfort in terms of goods and services accessible to the households and individuals in the project area. Generally, the lower the standard of living the easier it is to introduce an oppressive production system as well as violence in an area.

4.1.13 Household Monthly Income The distribution of the monthly income of the in-scope individuals and households is shown in Figure 4.9. This assessment concerns with all obtainable sources of livelihood to the sampled households in the Project Areas. As presented in the Figure 4.9 below, In Oziri community a high proportion of the respondents (27%) had monthly income in the range of N21,000.00 – N40,000.00. This was followed by the sampled individuals and households with monthly income in the range of N41,000.00 and N60,000.00 with an estimated figure of (20%) of the respondents. This is trailed by the households who income falls in the range of N61,000.00 – N80,000.00 with 20% of the total respondents and those who fall in the range of N81,000-100,000 are 15%. Respondents whose monthly income was above N100,000.00 had an estimated percentage of 10%. Respondents with main monthly income of less than N20,000.00 returned 17% of the total sampled households. However, from personal observation and possession of the PAP, it may be adjudged that the income of the people is slightly higher than what they claim they earn.

Source: Source: Field Survey, 2017 Figure 4.9: Household Monthly Income

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4.1.14 Changes in respondent’s Standard of Living The responses to the assessment of changes over the past years in standard of living of the respondents and households in the proposed project affected community are shown in Figure 3.14 below. About 15% of the sampled respondent feel their standard of living is better, 25% feel it is same while about 7%were not sure. It is obvious that the largest proportion (53%) of the respondents considered a worsening scenario in their standard of living and this was partly attributed to the expansion of the Ozuri gully. A detailed result is shown in Fig. 4.10 depicting the impact of the gully erosion. The continuous expansion of the gully has resulted in fear, threat and other vices that have deterred people from continuous investment in the area.

Source: Field Survey, 2017 Figure 4.10: Change in Standard of Living over the Year

4.1.15 Sources of Water This assessment covers the sources for drinking, cooking, and bathing & washing water available to the proposed project affected communities. As shown in the Table 4.1, the proposed project affected communities depend primarily on borehole as their source of domestic water supply for drinking (75%), cooking (75%), and bathing & washing (15%). Hand dug well was also identified as invaluable sources of water for drinking (20%), cooking (20%), and bathing & washing (80%). Some residents depend solely on nearby stream for washing of their cloths. Rain harvest can only be available in the rainy season between April and November annually.

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Table 4.1: Accessible Sources of Water Drinking Cooking Bathing & Washing Sources Frequency Percentage Frequency Percentage Frequency Percentage Rain 5 5.5 5 15.0 5 5 .0 River 0 0.0 0 3.5 20 20.0 Well 15 0.0 15 15.5 40 40.0 Bore hole 71 71.0 70 70.0 30 30.0 Spring 9 9.0 10 10.0 5 5.0 Total Response 100 100.0 100 100.0 100 100.0 Source: Field Survey, 2017

4.1.16 Security /crime rate There is no police station in the community, the people report criminal cases to the nearest police station about 3km away. However, the people of the area are peaceful and disputes are resolved within the community. From the survey, minor thievery constitutes the major security challenge of the people living at the study area as it had 74.5% of the total respondents (Figure 4.11). Other causes of insecurity such as land dispute, religious crisis are low in the area. The high rate of theft in the study area might be as a result of absence of police station in some community or lack of constant police patrol team and village vigilante group as. Apart from the recent kidnapping that is spreading all over the country, the assessment of crime rate in Ozuri is low as 89.9 % of the total respondents are of the opinion that crime rate is on the decrease.

Source: Source: Field Survey, 2017 Figure 4.11: security/crime rate

4.1.17 Solid Waste Management Effective waste management approach is pertinent for the protection of human health and the surroundings. As noted, the community in the project areas has no proper waste management methods. 68

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There are no solid waste collection points in the community. As a result of this, it is a common sight to find litters of waste around households in Ozuri community open dump and burning or re-use as manure. Liquid wastes are also not well re-directed. Cooking is done in open view. This leads to washings thrown around. Similarly, laundry is done in open view, with the liquid waste thrown around the place. Bathing is generally done in a poorly made shanty bathrooms behind household. Most people in the community use pit latrines, while some others do open defecation in bushes around the community. The result of the finding implies that, the sampled households mostly adopt informal approach to waste which puts a greater proportion of the people at risk in terms of epidemic that may result from improper disposal of human faeces. The waste management method adopted by the residents of the proposed project area was examined and the overall mean result is shown in Figure 4.12. The distribution of solid waste disposal methods in the project area as presented in Figure 4.12 depicts that, Bush dumping and open burning are the major methods of solid waste disposal at the study area. Whereas, bush dumping account for 45.2% of the respondents, open burning had 43.0%. Other methods such as landfilling, recycling and waste contractors are methods employed by fewer percentages of the people at the project area. The practice of open dumping and burning as it was observed in some community, is not environmentally friendly. As most of these wastes destroy the aesthetic quality of the environment and provide breeding grounds for disease causing organisms.

Source:labstaff Source: Field Survey, 2017 Figure 4.12: Waste management

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4.2 Public Consultation The public consultation for the Environmental and Social Management Plan (ESMP) for Ozuri community gully erosion site was conducted on the 12th of December 2017, following notification passed on to the Honourable youth chairman, Hon. Ahmed Nuhu of Ozuri community through NEWMAP Environmental Consultant. The consultation meeting was focused on sharing information and developing ideas and options. The meeting was about one hour long and led by NEWMAP Environmental Consultant. The dates, location and number of people who attended the meeting are outlined below in Table 4.2. Table 4.2: Community meetings - dates, location and attendees Date Location Number of attendees 12th December 2017 Ozuri community 22

The consultation meeting took place at His Royal Highness Palace. The consultation was conducted to ensure the effective participation and awareness to the people, and to document comments, suggestions and concerns raised with regards to the project. The following were taken into full account: a) The project will have foreseeable environmental and social impacts, especially on both the people and the adjoining roads and houses. b) The project aims at impacting more positively to the environment and social conditions, and the project managers will devise suitable, practicable mitigation measures through an ESMP to reduce or eliminate negative impacts. c) Positive impact of project activities will be enhanced, especially re-vegetation activities. d) Priority concerns raised by stakeholders will be put into account and incorporated in project planning and execution.

4.2.1 Objectives of the Public Consultation a) To create general public awareness and understanding of the project, and ensure its acceptance; b) To develop and maintain avenues of communication between the project proponent and stakeholders in order to ensure that their views and concerns are incorporated into project design and implementation with the objectives of reducing, mitigating or offsetting negative impacts and enhancing benefits from the project;

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c) To inform and discuss about the nature and scale of adverse impacts and to identify and prioritize the mitigation measures for the impacts in a more transparent and direct manner; d) To document the concerns raised by stakeholders so that their views and proposals are mainstreamed to formulate mitigation and benefit enhancement measures; and e) To sensitize the people of Ozuri community about the project and solicit their views and discuss their share of responsibility for the smooth functioning of the overall project operations.

4.2.2 Concerns Concerns were raised over compensation for those whose houses and lands will be affected by the proposed project. Another source of concern was whether the youth will be involved in the project implementation.

4.3 Health Impact Study There is one government primary health centre with a nurse and two auxiliary nurses. Their service to the community is more of first aid. The nurse prescribes drugs that are purchased from private dispensary. The prevalence disease is fever of various kinds and rheumatism among aged people. No cases of HIV or any cases of maternal mortality.

4.3.1 Assessment of Health Status of Respondents Analysis of health status of the PAP was carried out using information derived from respondents to structured questionnaire on health status, which was supported by hospital records acquired from Ozuri primary health care center.

4.3.2 Health Management Records of Respondents The responses to the health management approach used by the respondents are presented in Figure 4.13. As shown in the Figure, respondents’ responses to how they manage their health. As revealed by these findings, the health facilities recurrently used by the in-scope individuals and households for the treatment of ailments/diseases were mainly through patronizing local pharmaceutical shops and this returns 60% of the total sampled frame. Respondents who patronize clinic had 33.0% while the least was recorded for the respondents who use traditional remedial approach to treatment of diseases/ailments. The major ailments/diseases that frequently occur among the proposed project affected people and community across various age brackets are malaria and typhoid (see figure 4.13). 71

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Source: Field Survey, 2017 Figure 4.13: Health Management Approach of Respondents

4.3.3 Satisfaction with Medical Services More than four-fifth (81.0 per cent) of persons in households in the study area indicated their dissatisfaction with medical services received. The result of the study implies that a great proportion of the in-scope individuals and households in the project areas do not have access to modern healthcare facilities for their treatment of ailments/diseases, very few respondents are opportune to access modern facilities in the cities. It was also observed that, the most prominent ailments/diseases in the area across various age brackets are malaria and typhoid and this responsible for the high percentage of patronage to pharmaceutical shops for anti-malaria drugs. 4.3.4 Prevalent ailment The distribution of ailments/sickness affecting the households in Ozuri is presented in the figure below. The data shows that the health conditions of the residents in the proposed project area are affected by the high incidence of disease vectors such as mosquito. Table 4.3 presents the detailed findings of sickness/ailment mostly affecting the residents in the proposed intervention project area. Most commonly reported diseases according to the community sources in the study area are malaria/typhoid fever, diarrhea and communicable diseases which are reflected by 60%, 25% and 10% respectively (Figure 4.14). There were no reported cases of cardiac problem or sexually transmitted disease. The problem above occurs very commonly in all parts of Nigeria. There is no reported case of maternal mortality. This, however, was corroborated by hospital records that reveal over 90% of the reported sickness relating to malaria issues. Although there are

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State cases of emergencies, the bulk of what is being treated at Ozuri primary health care centre and other health institutions including private hospital in the area are malaria issues.

Source: Field survey 2017 Figure 4.14: Prevalent ailment

The result from the above assessment can be reflected in the records obtained from the health care centre in Ozuri community. Table 4.3: Prominent Ailments/Diseases in the Project Area Variables Always (%) Sparingly (%) Seldom (%) Never (%) G. Total Whooping Cough 0.0 1.4 27.1 71.4 100.0 Tuberculosis 0.0 0.6 49.7 49.7 100.0 Asthma 0.0 1.1 2.9 96.0 100.0 Dysentery 0.0 0.0 0.0 100.0 100.0 Diarrhea 0.0 0.0 0.0 100.0 100.0 Cholera 0.0 0.0 0.0 100.0 100.0 Pile 35.7 27.1 23.8 13.4 100.0 Hypertension 0.0 1.2 2.4 96.4 100.0 Congestive Health Problem 0.0 2.4 0.0 97.6 100.0 Pneumonia 3.0 0.3 0.0 96.7 100.0 Epilepsy 0.0 0.0 0.0 100.0 100.0 Rheumatism 17.1 6.9 22.9 53.1 100.0 Rashes 0.9 2.0 8.6 88.6 100.0 Eczema 0.0 0.0 0.0 100.0 100.0 Ringworm 0.0 0.6 2.9 96.5 100.0 Eye pains 4.9 2.3 9.8 83.1 100.0 Cataract 0.0 0.0 0.0 100.0 100.0 Glaucoma 0.0 0.0 0.0 100.0 100.0 Typhoid fever 17.4 18.9 6.6 57.1 100.0 Malaria 38.6 18.6 29.1 13.7 100.0 Sickle Cell Anemia 0.0 0.0 0.0 100.0 100.0 STDs 0.0 0.05 1.5 98.45 100.0 Source: Ozuri health care centre, 2017

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CHAPTER FIVE: ASSESSMENT OF POTENTIAL ADVERSE IMPACTS AND ANALYSIS OF ALTERNATIVES

5.1 Introduction The proposed Rehabilitation of Ozuri Gully Erosion Complex will lead to several changes in the environment and socio-economic aspect of the project area. A good number of these changes will be beneficial, especially the impacts of rehabilitating degraded land and reducing longer-term erosion vulnerability in the project community. There are a number of approaches for the prediction and evaluation of impacts. The ISO 14001 method is simple to apply and provides a high level of details and also relies on limited data, unlike the other methods that require the availability of large historical data. The ISO 14001 method, therefore, is selected for the identification and evaluation of impacts for the proposed gully rehabilitation project.

5.2 Impact Identification and Evaluation In line with general guidelines for an Environmental Impact Assessment (EIA) process, the following were the basic steps adopted for identification and evaluation of impacts: • Impact identification • Impact qualification • Impact rating • Impact description

5.2.1 Impact Identification The aim of impact identification is to account for the entire potential and associated bio-physical, social and health impacts making sure that both significant and insignificant impacts are accounted for. The anticipated impacts were determined based on the interaction between project activities and environmental sensitivities. The identified potential impacts during the different phases of the proposed project are listed in tables 5.10 to 5.11.

5.2.2 Impact Qualification The identified impacts of the project were qualified based on the following four criteria: • Positive or negative • Short-term or long-term

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• Reversible or irreversible • Direct or indirect Negative impacts are those that adversely affect the biophysical, health, and social environments, while positive impacts are those, which enhance the quality of the environment. For this study, short-term means a period of time less than three months while any period greater than three months is considered long-term. By reversible/irreversible, is meant whether the environment can either revert to previous conditions or remain permanent when the activity causing the impact is terminated.

5.2.3 Impact Rating This stage involves evaluation of the impact to determine whether or not it is significant. The quantification scale of 0, 3 and 5 was used. The system of rating employed was adapted from The International Organization for Standardization ISO 14001– Environmental Management System Approach. The criteria and weighting scale used in evaluating significance are as follows: • Legal/regulatory requirements (L) • Risk factor (R) • Frequency of occurrence of impact (F) • Importance of impact on an affected environmental components (I) • Public perception/interest (P) Legal /Regulatory Requirements (L) This seeks to address the question ‘if there is a legal/regulatory requirement or a permit required?’ The scoring is as follows: 0= There is no legal/regulatory requirement 3= There is legal/regulatory requirement 5= There is a legal/regulatory requirement and permit required The legal/regulatory requirements were identified based on national laws/guidelines/standards (FMEnv) relating to the project activity. Risk (R) This uses a matrix based on the interaction of the probability of occurrence of the impact (Table 5.1) against consequences of the impact (Table 5.2). The matrix (Table 5.3) is referred to as the Risk Assessment Matrix (RAM). Five probability categories are interacted against four groups of

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State consequences. The resultant outcomes are given scores with colour-coding. High-risk categories are red; intermediate risks, yellow and low risks, green as follows: 1=Low risk (green) 3=Intermediate risk (yellow) 5=High risk (red) Table 5.1: Probability of Occurrence Probability Category Definition A Possibility of Repeated Incidents B Possibility of Isolated Incidents C Possibility of Occurring Sometime D Not Likely to Occur E Practically Impossible

Table 5.2: Consequences of Impact Consequence Considerations Category Safety / Health Public Environmental Aspects Financial Disruption Implications I Fatalities / Serious Impact on Large Major/Extended High Public Community Duration/Full Scale Response II Serious Injury to Personnel / Small Serious / Significant Medium Limited Impact on Public Community Resource Commitment III Medical Treatment for Personnel / Minor Moderate / Limited Low No Impact on Public Response of Short Duration IV Minor Impact on Personnel Minimal to Minor / Little or No None None Response Needed

Table 5.3: Risk Assessment Matrix A B C D E I II III IV Key to Colours Low Medium High Positive

Frequency of Impact (F) Frequency of impact refers to the number of occurrence of impact. The frequency of impact was determined using historical records of occurrence of impacts, and consultation with experts and local communities. The criteria for rating the frequency of impacts are outlined in Table 5.4.

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Table 5.4: Frequency rating Criteria Frequency Rating Criteria Low 1 Rare, not likely to happen within project lifespan Medium 3 Likely to happen ≥ 5 years High 5 Very likely to happen throughout the project lifespan

Importance of Affected Environmental Component and Impact (I) The importance of the affected environmental components was determined through consultation and consensus of opinions. This was also further facilitated by information on experiences on the impacts of already existing facilities in the proposed project area. The rating of the importance of impacts is shown in Table 5.5. Table 5.5: Importance Criteria Importance Rating Criteria Low 1 - Imperceptible outcome - Insignificant alteration in value, function or service of impacted resource - Within compliance, no controls required Medium 3 - Negative outcome - Measurable reduction or disruption in value, function or service of impacted resource - Potential for non-compliance High 5 - Highly undesirable outcome (e.g., impairment of endangered species and protected habitat) - Detrimental, extended animal behavioural change (breeding, spawning, moulting) - Major reduction or disruption in value, function or service of impacted valued ecosystem resource - Impact during environmentally sensitive period - Continuous non-compliance with existing statutes

Public Perception (P) The consensus of opinions among the project stakeholders were used to determine the public perception on the potential impacts and the following criteria were applied (Table 5.6). The combination of the five impact rating weights forms the basis for judging the level of significance of each impact. A matrix displaying the combination based on the ISO 14001 tool is shown in Table 5.6. The final ratings of the identified impacts are presented in Table5.6.In this report, medium and high significant negative impacts were judged to require mitigation, and all positive impacts required enhancement.

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Table 5.6: Perception Criteria Public Rating Criteria Perception Low 1 - No risk to human health, acute and/or chronic - No possibility of life endangerment for residents, associated communities - Minor reduction in social, cultural, economic values - Unlikely adverse perception among population Medium 3 - Limited incremental risk to human health, acute and/or chronic - Unlikely life endangerment for residents, abutting communities - Some reduction in social, cultural, economic value - Possibility of adverse perception among population - Potential for non-compliance High 5 - Elevated incremental risk to human health, acute and/or chronic - Possibility of life endangerment for residents, abutting communities - Major reduction in social, cultural, economic value - Continuous non-compliance with statute - Any major public concern among population in study area

Table 5.7: Impact Value and Rating Colour Code Impact Value Cut off Values Impact Rating L+R+F+I+P <8 Low L+R+F+I+P ≥8 but <15 Medium L+R+F+I+P ≥15 F + I >6 High P = 5 Positive Positive

5.3 Summary of Associated and Potential Impacts Determination Tables 5.9, 5.10 and 5.11 show the identified potential impacts and rating for pre-construction, construction and operational phases respectively. The results of the evaluation of the interactions between the proposed activities and their impacts on environmental and social sensitivities are shown in subsequent pages of this chapter. The identified negative impacts were rated as minor, moderate and major. Beneficial impacts arising from the project were rated as positive. Hence, no further classifications were made on the beneficial impacts. The project is envisaged to have a range of positive environmental and social impacts. Some of these are a function of the objectives of the project, while others are a function of the way in which the project is designed to meet its objectives. Some adverse impacts that may be associated with the rehabilitation of the gully site are highlighted in this subsection (Table 5.8). Notwithstanding, the ESMP will be prepared to ensure that these impacts are reduced to the barest minimum. 78

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Table 5.8: Summary of Beneficial and Adverse Impacts S/N Positive Impacts Adverse Impacts 1. Community development programs. The frequency and incidence of occupational hazards may rise during construction activities. 2. Connection and restoration of access to houses and Possibility of seepage of fuel from machineries and villages already cut off by the erosion effluent discharge into the watershed, thus impacting on the water quality. 3. Control and Reduction of water body sedimentation Contaminated (with human waste) water run-off into rates due to erosion. surface water, etc. 4. Gender Issues: Construction activities will Soil destabilization due to vibrations from encourage economic activities, especially for construction equipment use. women. Since there would be a large workforce, petty traders and food-spots owners will benefit immensely from the demand on site. 5. Improved agricultural productivity within the Noise and vibration from heavy-duty project vehicles community and Kogi state at large. and equipment resulting in nuisance. 6. Improved livelihood enhancing activities. Disruptions to resident activities within the project area. 7. Increase in social interactions Delayed travel time due to movement of construction equipment or vehicles 8. Initiation/ kick-off of rapid production systems and Increase in sexual activities leading to possible agricultural practices. spread of STIs.

S/N Positive Impacts Adverse Impacts 9 Minimization of flooding and control of overflow. Grievance and resistance from communities 10 Promotion of afforestation programs (with all its Green House Gas (GHG) emissions from vehicular benefits) and construction equipment would be generated during the pre-construction, construction and subsequently, operational phases of the project 11 Promotion of goodwill and community appreciation Increased generation of solid and liquid wastes. of the NEWMAP intervention in Kogi State and Nigeria at large. 12 Provision of employment opportunities for both Site clearing will lead to loss of species diversity and skilled and unskilled workers. abundance, including soil organisms, fungi, invertebrates, and bacteria. 13 Reduced fear perception of loss of property, Injuries, falls, accidents, explosions, fires, leakages, inhabitation and ancestral origins of the accidents etc. communities. 14 Reduction in mortality/morbidity from landslides. Occurrence of social vices (e.g. theft, drug use, etc.). 15 Reduction of mortality rate. Increase in turbidity of river waters from storm water/ runoff during preconstruction and construction phase. 16 Rehabilitation of the erosion menace in the Increase in fugitive dust emission during community preconstruction and construction phases of the rehabilitation. 17 Reintegration of community and diversification of Loss of employment for labourers after the sources of livelihood. completion of the rehabilitation works, 18 Repair of the watershed gullies Waste generation especially construction wastes.

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Identified Potential Impacts (by Project Phases) Pre-Construction Phase A. Environmental Impacts Positive Prior to the commencement of rehabilitation works, a feasibility study and environmental assessment are required to describe the proposed project needs, aid project design, and ensure environmental and socio-economic sustainability of the project and the project community. - The project will undertake a stakeholders/public consultation exercise to sensitize the stakeholders in the project command area and beyond on the environmental safeguards components of the project. The public consultation process is seen to be a positive impact, as it will form a basis for project design and implementation of decision-making. Negative a. Air Quality - The pre-construction phase will give rise to fugitive dusts and frequent exhaust emissions into the atmosphere as equipment is delivered to the Site and along access roads where the proposed rehabilitation works will take place. b. Soil - Leakages may occur from stacked equipment containing oil such as engine oil. This could result in the seeping-through of oil into the soil, thereby leading to possible contamination of soil, surface water and ground water. - Soil compaction and soil structure changes may occur due to influx and stationary positioning of heavy duty equipment and vehicles Surface Water - Leakages may occur from stacked equipment containing oil such as engine oil. This could result in surface water contamination by run-off. c. Noise and Vibration - During the pre-construction activities the WHO/FMEnv permissible noise level (90dB) may be exceeded due to mobilization of heavy machinery to the rehabilitation site.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

B. Social Impacts Positive - The project will undertake a stakeholders/public consultation exercise to sensitize stakeholders in the project command area and beyond on the social safeguards to ensure project sustainability. The public consultation process is seen to be a positive impact, as it will form a basis for project concept decision-making and implementation. Negative a. Land Acquisition - Possible unresolved issues during land acquisition process from members of the community which may result in conflict between contractors and land owners. - Hostile and unfriendly community attitudes during land acquisition process. - Decrease in accruable income from land b. Noise - Noise from heavy-duty project vehicles and equipment may exceed the WHO/FMEnv acceptable noise level limits, resulting in nuisance. c. Others - Possible disruptions of movement of residents within the project area to places of work, and businesses, as a result of movement of equipment and materials along access roads, resulting in loss of man-hours and negative perception of the project amongst road users and residents. - Properties particularly farmlands may be accidentally damaged or destroyed during the movement of heavy duty vehicles and equipment. - Accidents involving vehicles or pedestrians may occur during vehicle and equipment movement to site. C. Occupational Health and Safety Positive - During the pre-construction phase, Occupational Health and Safety (OHS) awareness programs will be conducted. Awareness programs and interactive sessions will benefit primarily the contractors’ personnel, schools, residents and businesses. Guidelines on safe practices and safe behaviours will be made available to these groups in order to minimize the occurrence of occupational incidents or accidents in the course of implementing project activities

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Negative - During the pre-construction phase air pollution from exhaust fumes of vehicles and release of fugitive dust as a result of equipment moving to the work area may occur. This will pose an occupational health risk (respiratory infections and diseases), especially for people residing in and carrying out activities around the project rehabilitation area and also, contractor personnel, and personnel conveying equipment. - Exposure to noise pollution, injuries and accidents during movement of equipment to the work areas. Construction Phase A. Environmental Impacts Positive - Channelization of flood waters: Drainage channels will be constructed, to channel storm water to collector drains at the gully head. - Construction of suitable sized and aligned collector drains at the gully head to collect and lead the storm water/runoff from the roads into drop structures. - A chute will be constructed to channel water into the stilling basin. This will enable the controlled flow of water from the collector drain to the stilling basin. - The phase will allow for recovery works for land located within the gully, so as to safeguard residential properties at risk of erosion. - Re-vegetation activities will be carried out, to provide cover for the eased-out slopes, channels, chute and the stilling basin. The structured vegetation to be applied include sand bags, erosion resistance trees, plants and grasses in other to make the area environmental friendly and to improve the aesthetic of the project area. - Stabilization (even out/ uniformity) of the slopes, where feasible, to prevent further collapse of the slopes Negative a. Climate Change - Climate change impacts need to be assessed from two perspectives. Firstly, the impact of the project on climate change and secondly the impact of climatic change on the project scheme and its infrastructure.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

- Green House Gas (GHG) emissions from vehicular and construction equipment would be generated during the pre-construction, construction and subsequently, operational phases of the project. These emissions would be the primary impact of the project on climate change. GHG emissions are considered based on three “scopes” – Scope 1 (direct emissions), Scope 2 (indirect emissions) from the consumption of purchased energy [Purified Motor Spirit {PMS}, diesel] and Scope 3 (other indirect emissions) b. Air Quality - Emission of Green House Gases, Dust and Particulates: Emissions from exhaust fumes will originate from mobile sources including vehicles, trucks and heavy equipment during construction works. - Excavation and other civil works will lead to the increase in fugitive dust. - Civil works will cause changes in the air and atmospheric conditions of the project area and

surrounding environment. Fugitive dusts, machinery exhaust fumes [nitrogen oxides (NOX), carbon monoxide (CO), sulphur oxides (SOx), hydrocarbons and suspended particulates], and dusts from rehabilitation/construction activities will impact negatively on air quality. Air pollution from machineries will be short term, moderate and localized. c. Soil - Construction machinery stationed and moving around the area can create soil compaction, which may harm the soil’s future potential as farmland, impair drainage and increase the risk of flooding. - Excavation and compaction activities through construction works will alter the soil properties including loss of valuable top soils. - Accidental spillage of chemicals and fuels from the operation and maintenance of construction vehicles and equipment will pose negative impacts to surface and future groundwater quality. d. Water Quality and Hydrology - Increased pressure on water resources during construction works - During construction works, seepage of fuel from machineries and effluent discharge into the watershed may occur, thus impacting on the water quality - During the rehabilitation works, there may be potential for sediment/contaminant laden water runoff to impact on water quality. The contaminants in water runoff may have the potential to

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

enter existing drainage channels and into local watercourses, affecting downstream users and aquatic life. - Flood draining activities may introduce chemicals into water bodies leading to possible changes in water colour and pH levels, pollution and eutrophication in surface water. e. Noise and Vibration - The project area is a built-up area with residential houses, schools, market and a hotel. The civil works will generate noise and vibrations on site and surrounding environment. Most activities associated with road project starting from the pre-construction phase to the construction phase would generate relatively high levels of noise and would be mainly from heavy equipment. The noise levels generated by construction equipment would vary significantly, depending on such factors as type, model, size, and condition of the equipment, operation schedule, and condition of the area being worked. Accordingly, potential impacts of site monitoring and testing activities on ambient noise level would be expected to be temporary and intermittent in nature. - Vibrations resulting from construction equipment may cause further soil destabilization and consequent erosion. f. Waste - Construction activities will lead to the production of solid wastes - soil excavated debris, metal scraps, plastics, wood, waste concrete, papers and cartons, etc. - Increased generation of liquid waste – concrete washings, canal watering, etc. - Construction crews may generate solid and liquid wastes (sewages). Uncontrolled and untreated, these wastes are major sources of pollution, disrupting the ecosystem and contributing to local (and sometimes much broader) health problems. g. Flora and Fauna - Alteration/loss of habitat and biodiversity may occur, due to human activities and disturbance on the natural habitat. Site clearing will lead to loss of species diversity and abundance, including soil organisms, fungi, invertebrates, and bacteria. It will also lead to loss of food sources, fauna habitat, breeding grounds and nesting sites. - Reduction in the number of native wildlife - During mobilization of equipment, construction activities such as grading, dredging, filling, excavation etc., weed invasion/proliferation of opportunist species (weeds & pests) may occur.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State h. Topography - Scarification of natural landscape of the project site. B. Social Impacts Positive a. Employment - Employment of skilled and unskilled labour will be promoted. Artisans and professionals from the project area will be provided contractual employment during this phase. This will help promote community goodwill. b. Economic Benefits - This phase will encourage economic activities within and around work areas. Petty traders, food vendors and other small businesses will benefit from the demands at the work site. c. Waste Management - The construction phase will see the implementation of a viable waste management plan for project activities. d. Occupational, Health and Safety - Occupational health and safety efforts will be intensified during the construction phase as signage, warning and hazard signs will be put up to inform residents and others, about the on- going rehabilitation works in sensitive areas. - The phase will encourage the conduct of Occupational Health Risk Assessment (OHRA), Job Hazard Analysis (JHA), Hazard Communication Program (HAZCOM), OHS trainings and other proactive safety strategies (fulfilling the social and fiscal imperatives) which will help reduce the occurrence of on-site incidents/accidents and the resultant burden of direct or indirect compensation costs. Negative a. Impact on Livelihood/Community Activities/Social Stress - During the rehabilitation works there are bound to be restriction in movement, which will affect residents and business owners in the project area. - Gully rehabilitation activities may disrupt use of access roads by other users including travelers. There may be occurrences of traffic congestion on access roads as a result of intermittent movement of equipment and materials into and from the rehabilitation work area. There is high likelihood that when moving these equipment and personnel along these roads,

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

the transport activities of the community could be disrupted and this could have impact on the socio-economic activities of the community. - Flooding in other areas may occur during construction activities (construction of drainage), which can lead to destruction of lands, and properties. - Human Displacement: Civil, re-vegetative, and watershed management may require the relocation of surrounding residents and their sources of livelihood. - Social unrest as a result of non-participation/hiring of locals in the construction/ rehabilitation project. b. Social Vices - The project will attract a significant workforce. Associations between workers and local residents may lead to casual sexual relationships, thereby increasing the risks of sexually transmitted infections (STIs) and HIV - Vices such as theft, drug use, casual sex (with minors, prostitutes, etc.), small scale gambling, rape, etc., may arise due to the influx of project workforce into the area. c. Health and Safety - Incidences of respiratory conditions and respiratory diseases (silicosis, asthma, bronchitis, upper respiratory infections may occur due to air contamination by exhaust fumes and dust resulting from civil works. - Possible spread of water borne diseases (e.g. Cholera, Dysentery, Amoebiasis, Salmonellosis etc.) may occur. - Possible outbreak of HIV/AIDS and other STDs. - During construction activity through creation of pools of stagnant water there may be an increase in malaria cases - Exposure of workforce to attack by poisonous insects, reptiles and other dangerous wild animals. These attacks could result in injuries, poisoning or even death. - The frequency and incidence of occupational hazards may rise with during construction activities. - Accidents may occur during the construction phase as a result of increased vehicular movements d. Noise and Vibrations - This phase will cause noise and vibration nuisance

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State e. Waste - The construction phase will give rise to increased generation of waste from construction activities f. Archaeological and Cultural Loss - Construction works may impact on sensitive sites such as shrines, graves, etc. or unearth some cultural artifacts. g. Conflict - Conflict may arise between community members and contractor. This may hinder or slow down project implementation activities. h. Traffic - Existing travel patterns will be negatively impacted during the construction phase of the project. C. Occupational Health and Safety Negative - In the course of rehabilitation works, there would be a moderate to severe likelihood of the occurrence of workplace hazards. Activities using heavy and light equipment such as graders and bulldozers could predispose personnel to hazards. “Unsafe behaviours” and “unsafe conditions” will pose serious occupational health and safety risks. - Contact with natural hazards such as animals, insects, poisonous plants and reptiles. Operational Phase A. Environmental Impacts Positive - Repair of watershed gullies and rehabilitation of erosion menace. Proper erosion and watershed management as flood waters and run-off will be efficiently controlled. - Improved access road for between villages in the communities. This will immensely benefit community residents and other road users. - Stabilization of the gully erosion, this preventing further erosion from occurring. - Aesthetic modifications will promote good ambience within the gully erosion. - Availability of water (in the stilling basin) for agricultural use. - Control and reduction of water body sedimentation rates due to erosion. - Promotion of afforestation programs

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Negative a. Water Quality - Roadway runoff, wastes (municipal solid wastes, agricultural wastes, effluent, hazardous wastes etc.) may cause turbidity, changes in water colour and in pH levels. b. Odour - Release of foul smell from the collector drains, chute and stilling basin as a result of runoff/storm water containing decaying matter. c. Blocked Drains - There may be sediment laden run-off/storm water which may block the collector drains whereby affecting water flow. B. Social Impacts Positive a. Livelihood - Proper erosion and watershed management as flood waters and run-off will be controlled. - With the rehabilitation of the gully, the risk of land and properties being carried away will be significantly reduced. Reduced fear perception of loss of property, inhabitation and ancestral origins of the communities. - Increase in project area development and business opportunities - Improved access between villages and communities thus increasing social interactions. Reintegration of community and diversification of sources of livelihood. - Improved agricultural productivity within the community and Kogi state at large. - Initiation/ kick-off of rapid production systems and agricultural practices. - Reduction in mortality/morbidity from landslides. b. Education - The rehabilitation in the gully area will lead to educational and social tourism to the project (for example university students studying various fields of erosion and watershed management and engineering), and Industrial Training and those requiring hands-on experience. - Increase in community development programs c. Traffic - Increase in traffic within the roads and access roads of the project

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State d. Control - Control and monitoring of human activity e.g. farming, building etc. within the recovered areas and eased out side slopes Negative a. Loss of Employment - At the end of the project lifetime the project workforce will be demobilized. This will bring about loss of jobs for the project workers. This will translate to loss in income and business opportunities. Most of the small scale businesses that provided goods and services to the road crew members will either windup or experience significant reduction in the volume of business with the demobilization of the project and this too will translate to loss of income b. Air Quality - Increase vehicular emissions from road users c. Waste - Indiscriminate dumping of waste may lead to blocking of drainage channels and sanitation issues. d. Conflict - There may be land use conflict in managing the erosion site e.g. ecological, grazing and farming - e. Health and Safety - The stilling basin could become a breeding site for disease vectors e.g. flies and mosquitoes. Possible spread of water borne diseases (e.g. Cholera, Dysentery, Amoebiasis, Salmonellosis etc.) may occur. - Increase in respiratory problems amongst local residents as a result of increase in road users. - Increase in vehicular accidents along constructed/rehabilitated access roads. C. Occupational Health and Safety Positive - Implementation of site-specific occupational health and safety management plans (OHSMPs) - Monitoring for occupational health and safety risk assessment (OHSRA) report data. - Continuous job hazard analysis and process hazard analysis (JHA and PHA) - Implementation of a hazard communication program (HazCom) - Reduced direct and indirect costs as a result of pro-active safety strategies.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

- OHS Training - PPE availability Negative - There may be flood risk associated with the stilling basin. This is likely to occur when the impoundment level of the stilling basin exceeds the safety level. - Injury of workers and the public during the operation and maintenance activities Table 5.9: Identified Potential Impacts and Rating - Pre Construction Phase Project Component Sub- Potential Impact Description Likelihoo Consequenc Rating Phase componen d e t Pre- Environment Air Fugitive dust and Direct Medium Considerable Moderate construction exhaust fumes from Negative Phase vehicles Short-term/long-term Local/widespread Reversible Soil Soil compaction Direct Medium Considerable Moderate and soil structure Negative Low changes due to Short-term influx and stationary Local positioning of heavy Reversible duty equipment and vehicles Leakages from Direct Medium Considerable Moderate stacked equipment Negative and subsequent Short-term seeping through of Local contaminated oils Reversible and chemicals Noise Increase above Direct Medium Considerable Moderate permissible noise Negative level, (90dB) due to Short-term movement of Local/widespread vehicles, equipment Reversible and machines to the gully erosion site Vegetation De-vegetation – Direct Medium Little Minor Loss of flora and Negative fauna Short-term Local/widespread Reversible/Irreversibl e Project Component Sub- Potential Impact Description Likelihoo Consequenc Rating Phase componen d e t Pre- Social Land Conflict between Direct Medium Considerable Moderate construction Acquisition contractor and land Negative Phase owners, due to Short-term unresolved issues Local during land Reversible acquisition process Decrease in Direct Medium Considerable Moderate accruable income Negative due to sale of land Short-term/Long- term

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Local Reversible

Traffic Traffic Direct Medium Considerable Moderate congestion/travel Negative delay Short-term Local/widespread Reversible Noise Nuisance to Direct Medium Considerable Moderate surrounding Negative residents/ Short-term communities Local Reversible Others Accidental Direct Medium Little Minor destruction of Negative low property such as Short-term farmlands Local Reversible Accidents involving Direct/Indirect Low Little Minor vehicles or Negative pedestrians Short-term Local Reversible Grievances Direct/Indirect Medium Considerable Minor Negative Low Short-term Local Reversible Pre- Social Others Blocked access Direct/Indirect Medium Considerable Minor construction route to places of Negative Low Phase work, residence Short-term and business Local Reversible Pre- Occupational Air Exposure to Direct Medium Considerable Moderate Construction Health and respiratory disease Negative Safety risks from dusts, Short-term /long-term exhaust fumes of Local/wide spread equipment and Reversible vehicles Health and Exposure to injuries Direct Medium Great Major Safety and accidents Negative during movement of Short-term /long-term equipment Local/wide spread Reversible

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Table 5.10: Identified Potential Impacts and Rating - Construction Phase Project Phase Component Sub- Potential Impact Description Likelihood Consequence Rating component Construction Environment Climate GHG Emissions Direct /indirect Medium Considerable Minor Phase Change Negative low short-term/Long- term Local/widespread Irreversible Air Cement dust, Direct Moderate Considerable Moderate fugitive dust, Negative welding fumes, short-term/Long- exhaust fumes, term hazardous gases Local/widespread (NOx, CO, SOx, Irreversible PM 2.5, PM 10) Soil Destabilization of Direct Medium Considerable Moderate soil structure/ Negative Increase of short-term erosion site Local Reversible Compaction of Direct Medium- Considerable Moderate top soil due to Negative high movement of short-term heavy vehicles Local and equipment Reversible Contamination of Direct Medium- Considerable Minor soil by oil spills, Negative low fuel, etc. short-term Local Reversible Water Discharge of Direct/Indirect Medium Considerable Moderate quality/hydrolo sediment laden Negative gy run-off into water Short-term/Long- bodies term Local/Widespread Reversible Contamination Direct/indirect Medium Considerable Moderate from (oils, fuel, Negative chemical short-term/long-term substances etc.) Local/widespread Reversible Construction Environment Water Contamination Direct/indirect Medium Considerable Moderate Phase quality/hydrolo by human faecal Negative gy wastes short-term/long-term Local/widespread

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Reversible

Noise and Soil Direct Medium Considerable Minor Vibration destabilization Negative low due to vibrations short-term from construction Local equipment use Reversible

Waste Increased Direct Medium Considerable Moderate generation of Negative solid and liquid short-term wastes Local Reversible Biodiversity Loss of flora and Direct Medium Considerable Moderate fauna Negative High short-term /Long term Local Reversible/irreversib le

Project Phase Component Sub- Potential Impact Description Likelihood Consequence Rating component Construction Social Socio- Disruptions to Direct Medium Considerable Moderate Phase economic resident activities Negative activities within the project short-term area Local Reversible Blocked access Direct Medium Considerable Moderate route/Restricted Negative access short-term Local Reversible Construction Social Public Negative Direct Medium Little Minor Phase perception Negative among residents short-term and commercial Local establishments Reversible etc. about the project. Possible human Indirect Medium Great Moderate displacement Negative short-term Local Reversible Traffic Delay in travel Direct Medium Little Minor time Negative low short-term Local Reversible Education Noise Direct Medium Considerable Moderate disturbances to Negative the serene short-term learning Local environments. Reversible

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

(name of school)

Health and Increase in Indirect Medium Great Major Safety sexual activities Negative high leading to short-term possible spread Local/widespread of STIs Reversible Incidence of Direct Medium Considerable Moderate respiratory Negative diseases due to short-term air contamination Local by fugitive dusts Reversible and exhaust fumes Residents and Direct Medium Great Moderate workforce Negative exposed to short-term accidents and Local injuries Reversible Incidence of Direct Medium Considerable Moderate water borne Negative diseases (e.g., short-term dysentery, Local typhoid, cholera) Reversible Construction Social Behaviour Occurrence of Indirect Medium Considerable Moderate Phase social vices (e.g. Negative theft, drug use short-term etc.) Local Reversible Noise Nuisance due to Direct Medium Little Minor increase in noise Negative levels short-term Local Reversible Project Conflict between Direct Medium Considerable Moderate Performance community Negative members and short-term contractor Local Reversible Grievance and Direct/Indirect Medium Considerable Moderate resistance from Negative communities Short-term/long-term Local Reversible Construction Occupational Personnel Injuries, falls, Direct/Indirect Medium Considerable Moderate Phase Health and safety accidents, Negative high Safety explosions, fires, Short-term/Long- leakages, term accidents etc. Local/widespread Reversible

Table 5.11: Identified Potential Impacts and their Ratings - Operational Phase Project Phase Component Sub- Potential Description Likelihood Consequence Rating component Impact Operational Environment Air Exhaust fumes Indirect Medium Considerable Moderate Phase from road users Negative Short-term/long-term Local/widespread Irreversible

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Noise Nuisance due to Indirect Medium Considerable Moderate increase in Negative noise levels Short-term/long-term Local Reversible

Water quality Contaminated Indirect Medium Considerable Moderate and (with human Negative hydrology waste) water Short-term/long-term run-off into Local/widespread surface water Reversible etc. Water flow Blocked drains Indirect Medium Considerable Moderate (with sediment) Negative impeding water Short-term flow Local Reversible

Social Employment Loss of Indirect High Little Moderate employment Negative (engaged short-term contract staff on Local the project) Reversible

Health and Increase in Indirect Medium Considerable Moderate Safety water borne Negative diseases short-term (malaria, Local typhoid, Reversible cholera) Increase in Indirect Medium Considerable Moderate vehicular Negative related short-term accidents Local Reversible

Increase in Indirect Medium Considerable Moderate respiratory Negative problems short-term amongst local Local residents due to Reversible increase of road users Occupational Personnel Injury of Direct Low Considerable Minor Health and safety workers during Negative Safety operation and short-term/Long- maintenance term activities Local/widespread Reversible

5.4 Mitigation Measures for Ozuri Gully Erosion Gully control is one of the most important restoration methods used in watershed management, and timing is an essential element. The civil work in all structural and vegetative control measures selected should be completed during the dry and early rainy season. Otherwise, the incomplete structural work can easily be destroyed during the rainy season. In addition, vegetative measures such as the planting of tree seedlings and shrub and grass cuttings cannot begin until structural work is complete. Each continuous gully in the gully system should be regarded as a basic

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

treatment unit, and all the control measures in that unit should be finished before the rainy season. This is important because any continuous gully head that is left behind is capable of affecting the watershed again.

5.4.1 Selection of Mitigation Measures The duty of selection of Mitigation Measures is bound on the Client (SPMU/World Bank) as recommended by the ESMP Consultant. The main criteria for selecting structural control measures (See Table 5.12) should be based on: (a) The size of the gully catchment area, (b) The gradient and the length of the gully channel. The various portions of the main gully channel and finger gullies should be stabilized either by brush fills; earth plugs and brushwood, log, and loose-stone check dams. The lower parts are treated with loose-stone or boulder check dams. At a stable point in the lowest section of the main gully channel, for example, on a rock outcrop, a gabion check dam or cement masonry check dam should be constructed. If there is no stable point, a counter-dam (gabion or cement masonry) must be constructed in front of the first check dam. The points where the other check dams will be constructed are determined according to the compensation gradient of the gully channel and the effective height of the check dams. Table 5.12: Criteria for Selection of Control Measures for a Continuous Gully Length of main gully Gradient of main gully Catchment area of gully Required structural measures for channel portions (m) channel portions (%) portions (ha) each portion of main gully channel - - 2 or less Above gully heads: Diversion ditches or channels 100 or less (from gully Various 2 or less Maximum 100m from gully head: head) Brush fills, earth plugs, woven-wire, brushwood, log and loose stone check dams. These measures can also be constructed in branch gullies. 900 70 or less 2 - 20 Between 100m – 1000m: Boulder check dams, retaining walls between check dams if necessary, one gabion or cement-masonry check dam is usually constructed as a first check dam instead of a boulder one. Note: All structural measures must be accompanied with vegetative/bio-remediation measures (planting of tree seedlings, shrub and grass cuttings, and sowing of tree, shrub and grass seeds).

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

5.5 Risk and Danger Assessment/Management Development projects of this magnitude often have associated risks or dangers. These could be commonplace risks that are almost inevitable, such as the risk that a member of the team is sick for part of the project. There may be some unlikely but high impact risks such as the risk that the rehabilitation could cause the loss of source of livelihood. Therefore, there is the need to constantly assess the risks and take action as needed. Three possible outcomes can be envisaged for the risk; (a) Take action now to avoid the risk, to reduce its likelihood, or to reduce its impact, (b) Make contingency plans so that the team is ready to deal with the impact and mitigate the risk should it occur, (c) Agree that it is an acceptable risk to take no action and hope that the risk does not occur. Risks can then be managed as follows; (a) Identify all realistic risks (b) Analyse their probability and potential impact (c) Decide whether mitigating action should be taken now to avoid or reduce the risk and to reduce the impact if it does occur (d) Where appropriate, make plans now so that the proponent is prepared to deal with the risk should it occur (e) Constantly monitor the situation to watch for risks occurring, new risks emerging, or changes in the assessment of existing risks.

Figure 5.1: Risk Assessment Process

5.5.1 Assessing risks at the start of a project It is expected that during the Project conception, the headline risks should be considered as part of the overall benefit model. At this stage, one will not be dealing with a full catalogue of risks,

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State consequences and actions. You will focus on the main areas that affect either the justification of the project or the manner in which it will be carried out. Also, it will be necessary to instigate some specific activities to examine risk, for example additional interviews, workshops and brainstorming sessions. Where there is a specialist area involved, you should consult with an appropriate expert. A good technique for presenting these issues is to use a risk matrix showing the probability of different headline risks in comparison with their relative impact on the project's goals.

Figure 5.2: Risk matrix

This focuses attention on the areas where the project plan will need to address key issues and where specific actions and techniques may be required. Note how this example suggests that the biggest area of concern tends to be with the "people issues". The human element of a solution is often the most overlooked aspect.

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Sponsors and steering committee members are often very busy people and want the key risks spelt out into maybe the top ten they should consider. You can use these to raise the most vital points that need executive attention, but remember it is your job to make sure all significant risks are considered and dealt with. The other thing you should do early on is to decide upon the procedures and technology for managing risk. In most cases you will use some form of technology, preferably as part of a set of integrated Project Office tools. The procedures should make it easy for all participants to submit their thoughts and concerns. Always capture the thought. You may dismiss it later if appropriate, but you should always consider and assess the input.

5.5.2 Assessing risks at the start of each phase When you prepare in detail for each phase of work you should look at the risks in detail. Try to identify all realistic risks that should be considered. In most cases, it will be worth capturing the information electronically in a risk register. It should include: (a) A reference code for the risk (b) A description of the risk; (c) Who owns this risk (i.e. who is accountable for monitoring it and taking action); (d) The probability of the risk occurring; (e) A description and quantification of the potential impact of the risk; (f) The likely cost to the project if that risk occurs; (g) Optionally, the proximity of the risk (i.e. how soon could it strike); (h) The severity of the risk and/or priority for dealing with it; (i) What actions should be taken now to reduce the probability and/or impact and by whom; (j) Optionally, a re-assessment of the probability, impact and priority of the risk after those planned mitigation actions have been taken; (k) What contingency plans should be formulated now so that NEWMAP is ready to act if the risk occurs; (l) Optionally, tracking information for the actions proposed above (who, when, status, etc.); (m) When the risk should next be assessed (timing or trigger). In a quantitative risk assessment, considerable evidence is gathered to quantify the probability and impact of the risk. This is a specialised area and uses specialised tools, but the simple logic is impact x probability = expected cost. 99

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

The purpose of qualitative risk management is to focus leadership attention on risks that merit their attention. It is not helpful to present a high degree of precision since the risks have not been thoroughly quantified and the point is not to calculate their precise expected impact. Often the probability and impact are simplified to categories such as High, Medium and Low - or maybe 3, 2 and 1. Most people want to multiply qualitative probabilities with qualitative impacts to show severity. Mathematically, this is not logical as we are not dealing with quantified values. Some people prefer to add the scores or you could use a look-up table, but any way of focusing attention can be used if it conveys the key points to the leadership. The example below shows a risk severity prioritization table used to identify Risk Level from Probability and Impact. Table 5.13: Risk severity prioritization

The table below shows some specific risks identified for the rehabilitation project

Table 5.14: Identified Risk, Ratings and Response to Risk IDENTIFIED RISKS PROBABILITY IMPACT RESPONSE Team members leave or High Low Ensure the plan has contingency built into it to allow for become sick less than expected resource availability Key team member becomes Medium Medium Ensure project procedures include good knowledge available sharing and documentation so that the thought process, designs and decisions are not lost. Solution does not meet the Low High Ensure good participation and collaboration involving project needs representatives and resources from all stakeholders Insufficient participation from High Medium Ensure the Project Sponsor and supporting sponsors are stakeholders aware of the importance of promoting and rewarding participation. This message should be conveyed to the stakeholders.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Significant change in the Medium High Project needs may sometimes change, so plan the project project and its consequent so that it could adjust rapidly at relatively low cost, for needs (eg restructuring) example, a number of short incremental steps towards the goal could be easier and cheaper to re-direct than one enormously long delivery project. IDENTIFIED RISKS PROBABILITY IMPACT RESPONSE Technical solution has major Low High Invest in appropriate levels of testing. Consider a period of flaws parallel running. Have a fallback contingency plan to revert to a previous system if necessary Technical solution has High Low Put in place an "early care" programme to deal with operational flaws immediate snags. Ensure processes, resources and responsibilities for on-going maintenance are established well before live date System failures High Medium Invest now in fault tolerant components and adequate redundant contingency resources. Ensure the plan includes appropriate backup, recovery, and disaster recovery procedures (and tests them). PAPs fail to use the Medium Medium Plan for a detailed Training Needs Analysis and put in alternative livelihood options place an appropriate training programme. Consider how to effectively and efficiently coach and support users after live date PAPs resist the changes High High Use change management experts to assess the issues and create a change programme. Co-ordinate communications and sponsorship activities to convey the message. Confront big issues early in the project (not just before live operation). Dependency with other Low Medium Plan to accommodate other projects with minimal or no systems and projects negative impact on the proposed sub project. Degree of executive support High High Ensure that the executive is carried along from project required to succeed conception all through the life cycle of the project.

These risks and implications should be discussed with the relevant leaders and participants. Planned responses to those risks should be agreed by the World Bank and NEWMAP.

5.5.3 Managing the risks Risk management should be seen as a continuous process throughout the project. Once the initial risk register and procedures have been established the PMU, and all project participants should be alert for new, changing or occurring risks. Participants should be briefed on the importance of this and the specific procedures. Procedures for reporting risk should be as easy as possible. Feedback from all participants should be encouraged and rewarded. The PMU should review the risk register proactively on a regular basis. They should check the status of potential issues, for example, by calling the responsible party and checking if there has been any change in status. The Project Coordinator should also review the register on a regular basis and take action as required. Headline information on risks would be reported to the leadership along with the other project performance data. Where risks occur, they need to be managed therefore a contingency plan should be formulated and the Project Coordinator should be able to take immediate action to mitigate the impact. Some

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State of these methods stated below can be employed also in the management of risk for the rehabilitation project;

Transfer of risk Contractual clauses are intended to transfer risks. When laying-off risks, weigh up the frequency of occurrence against the level of premium paid for the transfer. It can be unwise to pass a risk that is difficult to assess to the contractor as they may either increase their prices, or disregard it when preparing their bid and then find they are in difficulty later. Acceptance of risk The client may carry highly unpredictable and poorly defined risks as the alternative might be to unacceptably inflate tenders. Avoidance of risk Redefine the project goes a long way in helping avoid risk. Clarification of responsibilities, remuneration, and expenditure at the beginning of the project will help avoid problems. Insuring against risk Most standard form contracts insist on certain types of insurance, such as; insurance against fire, professional indemnity insurance and so on. Doing nothing about risk Either none of the project team considers the risk, or they consider the risk and decided that they already lie with those who could best control them. Allocating risk through methods of payment One of these two ways can be used in allocating risk through payment method. (a) Fixed price: items paid for based on the contractor’s predetermined estimate (b) Cost reimbursement: items paid for based on what the contractor spends in executing the work. However, there will be a need to balance the envisaged risk. This can be achieved through one of the following contractual approach Design and build There is a single point of responsibility with the contractor for both the design of the project and operations on site. As such, most of the risk lies with the contractor, particularly where the contract is let on a lump sum basis. However, risk is increasingly transferred back to the employer as more preparatory design work is carried out before the contract is let. Traditional contract

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With traditional lump-sum contracts, the intention is that there should be a fair balance of risk between the parties. The employer is responsible for the design and the contractor for the operations on site (although this is complicated when nominated sub-contractors and suppliers are included). The balance can be adjusted as required, but the greater the risk assigned to the contractor, the higher the tender Plate is likely to be. The risk to the employer is lessened by the contract being let on a lump-sum basis, although in reality, no price is 'fixed'.

Management contracting In management contracting, the balance of risk lies with the employer. Separate works contracts are let, and the employer may continue to develop the design during construction, hence there may be little certainty about cost or time. However, the risk of delays and defects are associated with the responsibility for the works contract. In some cases the management contractor may absorb this risk and with a resulting increase in price, although this may compromise their 'impartiality'.

5.6 Project Alternatives and Options In the context of this ESMP, analysis of project alternatives refers to the performance of the natural and socio-economic resources with or without the project or with or without the implementation of the measures of this ESMP and/or other safeguard instrument considered appropriate. For intervention work of this nature, there are usually a number of viable options that can be considered. These alternatives include: the no project option; delayed project; alternative site/location and project execution options. For this project, analysis of the various alternatives is presented as follows: 5.6.1 No Project Alternative The No Project Alternative implies that the intervention work shall not be executed; hence there is no need to carry out this study. This implies the site will remain in its current state and perhaps widen due to natural forces without even any interference from man. Nevertheless, this situation will worsen and put the activities of man and the environment into further jeopardy since the area is already exposed to the forces of erosion. The intervention work is designed to stop these forces and mitigate any negative impacts that may arise. Therefore, choosing the no project option will mean a loss of efforts made by all parties to ensure the erosive forces do not continue to pose risk to lives and the environment and even loss of job opportunity to Nigerians. The ‘no project option’ is therefore not considered a viable option. 103

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5.6.2 Delayed Project Alternative This option implies that the planned intervention be delayed until a much later date. Such alternative is usually taken when conditions are unfavourable to project implementation such as in heavy rainfall, war situation, or where the host community is deeply resentful to it. Also, if the prevailing economic climate is not quite favourable, then delayed option may be feasible. None of these conditions is applicable at present. Further delay will mean the onset of heavy rainfall that is not favourable for the proposed treatment method. At present, both the economic and the political environment and natural environmental phenomena are most favourably disposed towards it. Therefore, the implication of delayed project alternative will mean that all the preliminary work and associated efforts/ costs incurred would have come to nothing. Also, because of inflationary trends, such a delay may result in unanticipated increase in project costs, which may affect the final target from the project. These, and other related problems make adopting the delayed option impracticable. 5.6.3 Do project alternative This alternative means going ahead to implement the intervention work. This also entails incorporating professional advice on the most practicable alternative such as are spelt out in this ESMP and other relevant safeguard instruments and/or best practices relating to the execution of the intervention. This will definitely reassure the public of their safety and the environment. It will also aid employment creation. The environmental threats from the gully erosion will be reduced drastically, if not totally solved in that area. The devastation by erosion that has rendered the existing road impassable will be addressed and solved. This alternative is therefore considered the most viable and recommended for implementation. However, in going ahead, appropriate measures for the gully treatment must be adopted and applied. 5.6.4 Technologies/Designs Option This will involve the use of Civil Works, Bioengineering and other Technological Options in solving the problems created by the gully. All the elements of the watershed including the environmental and social components were considered in the process of adopting the use of civil works, bioengineering and technological options analysis. This approach will ensure that relevant components of the natural and human environment under the threat and risk of destruction such as soil, public infrastructure, social and community infrastructures and facilities will be secured in the affected communities.

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The proposed intervention will involve intensive civil works across the broad spectrum of the affected and high-risk areas. Consequently, construction works, bioengineering and technological approaches will be adopted in restoring and enhancing affected areas as envisioned in the goals of the NEWMAP. Adverse impacts of these activities will be highly reduced to the extent that the benefits will outweigh the demerits as necessary. In conclusion, the merits of the Technologies/Designs Alternative outweigh the other alternatives, it is therefore, recommended.

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CHAPTER SIX: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

6.1 Overview The range of environmental, social and occupational health and safety issues associated with the rehabilitation works for the Ozuri Gully Erosion Complex have been described in a matrix table format for the environmental and social management plan (ESMP). The table (6.1 to 6.3) also include columns for Monitoring Indicators, monitoring parameters, monitoring instruments, monitoring locations, Monitoring Frequencies, monitoring responsibilities and costs. It outlines the corresponding mitigation measures for potential environmental and social impacts; and occupational health and safety risks that are envisaged to occur during activities. Since the project consists of civil rehabilitation works basically, the majority of the environmental and social impacts and occupational hazards will be expected to arise during the construction phase of the project. The ESMP also covers potential impacts as perceived during the pre-construction and operation phases.

6.2 Institutional Arrangement for ESMP and Monitoring Plan It is envisaged that the environmental and social impacts and their designed enhancement and mitigation measures shall be monitored during implementation of the construction/rehabilitation works and operation phases. The roles and responsibilities for monitoring the environmental and social impacts and the implementation of the ESMP are as follows. Overall sub-project coordination will be housed in Project Management Unit (PMU), of Kogi State NEWMAP Office. They will oversee the day-to-day project management and ensure that environmental and socio-economic concerns and management as elucidated in the ESMP are integrated into all aspects of project implementation. The Kogi State Ministry of Environment; herein referred to as State Ministry of Environment (SMEnv); National Environmental Standards Regulatory Enforcement Agency (NESREA), and Kogi State Environmental Protection Board (KSEPB) will monitor, evaluate and audit the implementation of the ESMP to ensure that the rehabilitation works and project operations meet “best environmental practices”. Awareness creation exercises on HIV/AIDS, environmental protection and personal hygiene and sanitation shall also be undertaken for contactors personnel and all stakeholders involved in project implementation.

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Table 6.1: ESMP - Pre-Construction Phase Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibili Responsibility (USD) ty (Monitoring) (Mitigation) Environment Air Mobilization Increase in Sprinkling of Air quality 2-3km Air quality Twice Mitigation: Monitoring: 800 of workers, amounts of water via parameters Radius of test monthly Contractor SMENV, PMU, equipment fugitive dusts spraying are within project area ESO and other and exhaust devices to limit permissible Contractor materials into fumes from dusts. Limits Ozuri Gully movement of Ensure that . 2-3km Air quality Every two Contractor ESO 1000 Erosion Site heavy-duty vehicles are 1. 1. Number Radius of test months vehicles and serviced; of time project area equipment undergo vehicle water is into work emission testing sprinkle on areas. (VET) and vehicle exhaust daily bases screening (VES) during as laid down in construction the NESREA guidelines. • 2. Level of airborne particulate matter during construction

• 3. Number of tme routine maintenance was done on equipment and machinery

Soil Mobilization Loss of top Limit zone of• Number of Project Visual Weekly Mitigation: ESO 1200 of workers, soil and soil vehicle and trees camp sites observation, PMU and equipment compaction equipment planted. and Soil Contractors and other due to weight impacts• 2. Area of equipment Compaction materials into movement of (designate an vegetated packing test Ozuri Gully vehicles to area for parking lawns zones Erosion Site site and and stacking created stacking of equipment) 2.

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heavy-duty equipment

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Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibilit Responsibility (USD) y (Mitigation) (Monitoring)

Leakages Ensure . Project camp Soil quality Weekly Contractor Monitoring: 1200 from stacked fastening of sites and test ESO, SMENV, equipment loose parts equipment KSEPB, PMU and (bolts, nuts); packing subsequent Install zones intrusion of impermeable oil and surface at the chemical limit zone to substances contain into soil. potential leakages Environment Noise Mobilization Increase The effective 2-3Km Noise level Weekly Mitigation: Monitoring: 700 of workers, above control of • Noise level Radius of measurement PMU, ESO,SMEnv, equipment permissible noise from in dB. project site in dB Contractor KSEPB and other noise level, vehicles and materials into (90dB) during equipment 3. Number Ozuri Gully movement of during this of time vehicles, phase may heavy equipment be achieved duties were and by maintained machines considering (site-specific the following and techniques:

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Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibilit Responsibility (USD) y (Mitigation) (Monitoring) Erosion Site Widespread). Data sheet Access Site visits During/materi Mitigation: Monitoring: 600 A Logarithmic Alternative route and al movement ESO and ESO,KGS- scale in design options; within inspection Contractor MEnv, KSEPB decibels (ie Mitigation at the project Decibel Sound source; Pressure Mitigation along Level) was the path; and used. Mitigation at the receiver

For minimal disturbance it will be advised that equipment is transported when it will cause least disturbance Vegetation Vegetation Displacement Contractors Vegetation Project For a and Monthly Mitigation: Monitoring: 750 clearing of soil fauna should limit clearing is Community fauna Contractors ESO, NRO, and damage to vegetation limited to especially studies in PMU flora. clearing to precise access selected minimum areas areas routes to areas required gully as particularly areas well as with indigenous gully vegetation

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Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Corridors

Predisposing Cleared areas Re- Community Ground Monthly Mitigation: ESO 1000 of soils to should be re- vegetation especially trotting PMU, erosion vegetated with is ongoing access Contractor beneficial local where routes to species known appropriate. gully to mitigate against erosion

Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Social Traffic Mobilization Traffic Apply lane 1.Lane Project Site visits Daily Mitigation: Monitoring: 1200 of workers, congestion/tr configuration configuration routes within and Contractors, ESO, FRSC; equipment avel delay changes to changes are community observation FRSC (Federal and other along some affected Road Safety being made materials into major roads roads and Corps) Ozuri Gully streets. where Erosion Site applicable. 2. Number of traffic warders available

3.Number of awareness campaign conducted on safety and driving

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issues

Noise Mobilization Nuisance to Retrofit with 1.Retrofitting Project Inspect Daily Mitigation: Monitoring: 1750 of workers, nearby suitable cost with vehicle community Contractors Contractors ESO, SMENV, equipment residential effective sound proof equipment KSEPB and other areas vehicle sound materials is materials into proofing being Ozuri Gully materials/ performed Erosion Site technologies. Social Air Mobilization Exposure to and provision Provision of Project area Site visits Weekly Mitigation: Monitoring: 1000 of workers, health risks of face mask face masks and SMENV, PMU, ESO, KSEPB equipment from fugitive to project and inspections Public Health and other dusts and personnel. appropriate depts. Adavi materials into exhausts Sprinkle PPEs are LGA Ozuri fumes. water daily being provided

Regular assessment of airborne particulate matter

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Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Ozuri Gully Restrict • 1. Restriction Project site Site visits Weekly Mitigation: KGS Monitoring: Erosion Site access of barrier are and MEnv, PMU, ESO, KSEPB non-project being inspection Public Health depts. Adavi personnel to installed. LGA work areas• 2. Number where dusts of and communit emissions y exist/persist complaints from project received. works.

Land Land Conflict The PMU will Documented Project Examine Monthly for Mitigation: PMU Monitoring: RAP Acquisition owing to carry out an evidence of community grievance 6months PMU, SLO, unresolved extensive enlightenmen redress before and FoNGO, land enlightenmen t carried out reports during Independent acquisition t program to showing construction/r Consultant, and inform method, ehabilitation Contractors involuntary farmers and coverage and phase displacement communities dates of during the on the aim, programs construction scope and nature of the work

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Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Construction Transportatio Public Safety Transportatio Evidence of Project Site visits Weekly Mitigation: Monitoring: 1500 camping n and and Traffic n of heavy warning communities and during pre- Contractor PMU most movement of congestion equipment signal and transport inspections construction PMU importantly, heavy will be carried Log record of routes phase ESO), equipment out during off time of lorry pick hours arrival/discha when it will rge of not disturb equipment public movement Where movement cannot be avoided during work hour, the contractor must attach a warning signal Others Mobilization Disruption of Adequate Adequate Project Site visits Monthly Mitigation: Monitoring: 2000 of workers, vehicle and and timely and timely communities and Contractor, PMU(most equipment pedestrian sensitization sensitization and transport inspections PMU importantly, and other access to of identified program is routes ESO) materials into where Respondents being Ozuri Gully rehabilitation ; Lane conducted Erosion Site works will be configuration Lane conducted configuration change have been made Grievances Adequate Sensitization Project Examine Monthly Mitigation: Monitoring: 1000 and negative and timely exercise are communities Awareness Contractor, PMU most community sensitization conducted and transport reports, site PMU importantly, perception of identified routes visits and ESO,SLO, about the Respondents consultations FoNGO project.

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Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Occupational Air Mobilization Respiratory Institute 1. Number Contractors Examine Weekly Mitigation: Monitoring: 500 Health and of workers, disease risks workers of workers project contractors Independent ESO, KSEPB, Safety equipment from respiratory camp/office WRPP Consultant, PMU and other exposure to protection with PPEs Contractors materials into exhaust program gully erosion fumes of (WRPP) 1. 2...Number site equipment of safety and vehicles talk and awareness conducted . Institution of WRPP Mobilization Noise Institute • Institution of Contractors Examine Weekly Mitigation: Monitoring: 400 Noise of workers, pollution noise control noise control project Contractors Independent ESO, KSEPB, equipment plan plan . camp/office Noise control Consultant, PMU and other plan Contractor materials into gully erosion site Accidents Mobilization Accidents Education 2. 1.Education Contractors Examine One-off PMU, PMU 750 of workers, involving and training and training project Contractors Contractor, equipment pedestrians of has been camp/office Accident Independent and other Respondents conducted prevention Consultant materials into about the 42.Number plan gully erosion project and of safety site accident talk and occurrence awareness conducted Contractor(s) Training has Contractors Examine One-off PMU PMU 1000 education been project Contractors and training conducted camp/office Accident on pedestrian safety

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Table 6.1: ESMP - Pre-Construction Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators Monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Install safety Safety Project site Site visits Weekly PMU, PMU(ESO, 1000 signage signage have and Contractor etc.) been installed inspection Collapse of Conduct Training has Contractors Inspection One-off Contractor PMU most 800 heavy haulage been project and importantly, equipment safety conducted camp/office consultation ESO) etc. being training with workers conveyed to rehabilitation work area Enhanced Contractor(s) Contractors Site visits Weekly Contractor PMU most 500 fastening of Compliance project and importantly, equipment to camp/office inspection ESO) carriage section of vehicles. Personnel Attack from Conduct Records of Contractors Inspection One-off Contractor PMU most 500 Safety dangerous safety and Training project and importantly, animals first aid conducted camp/office consultation ESO) during de- training with workers vegetation activities

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Table 6.2: ESMP - Construction Phase Component Sub- Activities Potential Mitigation Measures Monitoring where to How to Monitoring Institutional Institutional Costs component Impact Indicators monitor monitor Frequency Responsibilit Responsibility (USD) y (Mitigation) (Monitoring) Environment Climate Operation of GHG Fuel switching- Fuel Compliance 2-3km Radius Air quality test Weekly Mitigation: Monitoring: 1750 Change equipment Emissions switching from high- to to proffered of project area Site visits and PMU, KSEPB, used during low-carbon content mitigation Project site inspection Contractors PMU.CCO the fuels (where available) measures. construction can be a relatively phase cost effective means to mitigate GHG emissions during this phase. Transition to renewable energy sources i.e. solar energy (where applicable) Energy efficiency- Machines e.g. generator plants could be turned off when not in use, in order to reduce carbon emissions. Multiple trips reduction: In order to reduce vehicular movement and subsequent

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring where to How to monitor Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Increased carbon emissions. Hire vehicles, plants and equipment that are in good condition (current models) generally less than 3 yrs. old. Air Operation of Fugitive and Routine . Contractors 2-3km Air quality test Daily Mitigation: Monitoring: 1200 equipment cement dusts watering of Compliance Radius of Contractors KSEPB, PMU used during the project area (most the rehabilitation importantly, construction site ESO) phase Rehabilitation Daily Mitigation: Monitoring: 1000 works – Contractors KSEPB, including PMU(most filling and importantly, compaction ESO) activities, construction of side drains, culverts and other hydraulic structures

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Environment Air Heavy Exhaust Wet Right-of-Way to QC and QA Project site Site Visit and Monthly Mitigation: Monitoring: 1400 equipment fumes, reduce dust are in inspection PMU, PMU most operations hazardous production practice . Contractors importantly, during gases (NOx, ESO), construction CO, SOx, Contractors • SPM,),

Oxides from

welding activities. Test Procedures – Contractors Monthly Monitoring: 950 Routine measuring Compliance PMU (most of HC and CO importantly, concentrations ESO), KGS- during rehabilitation MEnv works should be employed for PMS powered vehicles. Diesel (AGO) vehicles should be tested for exhaust opacity during unloaded engine free acceleration periods.

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Quality Control – Contractors Project Site visits, Monthly Mitigation: Monitoring: 900 Routine Compliance site inspection Contractors PMU (most equipment and importantly, efficiency audits consultation ESO), KGS- Quality Assurance with workers MEnv –Continuous training of contractor(s) personnel on air quality management Water All Contaminati Attempts to • Contractors Surface Water weekly Mitigation: Monitoring: 950 quality/Hydrol rehabilitation on of dispose of Compliance 1 water Quality Contractors PMU (most ogy works surface sediment-laden • within importantly, water run-off into project (pH, TDS, ESO), SMEnv (discharge surface water area TSS, of sediment should be laden run- discouraged and BOD, COD, off into prevented. drainages, Implement site- waterways specific waste Turbidity, etc) management THC, plans heavy metals) measuremen t

Defecation Generation Liaise with the Number of Surface Water quality Monthly Mitigation: Monitoring: 1300 near gully of sewage municipal sewage mobile toilet water test, Contractor PMU (most erosion site overtime collection provided within consulatation importantly, (from use of authorities for project with ESO, WRO, temporary collection and area monitoring KGS-MENV, mobile treatment of waste agency KSEPB toilets by with KSEPB personnel involved in civil works)

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Environment Soil/geology Movement of Surface soil Creation of limit PMU, and Project site Site visits Monthly PMU, Monitoring: 800 heavy compaction zones Contractor’s and routes and Contractors KGS-MENV, vehicles/Stati Minimize Compliance inspection, PMU (most onary compaction soil testing importantly, vehicles and during ESO,NRO equipment stockpiling by working the soil in the dry state. Rip compacted areas to reduce runoff and re- vegetate where necessary All topsoil and other soil profiles must be managed strictly

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Contaminatio Pollution of All oil and Contractor Project site Site visits Periodically Mitigation: Monitoring: 1800 n by oil spills, soil and lubricants Compliance and routes and Contractor SMENV, PMU lubricants and groundwater should be sited inspection, (most other on an soil and importantly, chemicals impervious base groundwate ESO) and should r testing have drip pans The storage area should be far from water course All containers should be clearly labelled Filling and Loss of top Ensure Contractor Project site Site visits Monthly Contractor Monitoring: 1500 Compaction soil ; possible excavation is Compliance and routes and PMU (most activities for minor to limited to inspection importantly, gully head moderate soil desired areas ESO) and finger instability Filling and gullies compaction in reclamation layers must range between 150-200mm thicknesses as recommended. Erosion Erosion The contractor • Contractor Project site Site visits Weekly Contractor Monitoring: 1800 management management must implement Compliance and routes and KGS-MENV, appropriate inspection PMU (most erosion control importantly, measures to ESO) Project avoid further Engr erosion in this watershed.

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Measures Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Construct soil • conservation measures at appropriate locations Execution of major works that would impact on soil structure should be carried out during the dry season. If done during the wet season, temporal drain should precede the permanent drain so that run-off from rain can be managed properly.

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Measures Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Environment Noise Construction Extensive Mitigation at source • Contractors Project site Site visits Weekly Mitigation: Monitoring: 2000 of all hydraulic noise site- (for all activities) Compliance and routes and PMU, ESO, SMENV, structures specific A noise barrier or . inspection, Contractors pollution as acoustic shield will ts of

2. Regular maintenance of machinery

3. Limit work hours to daytime.

Rehabilitation a result of reduce noise by Equipment Monitoring: and on-going interrupting the ESO, SMENV, stabilization of construction propagation of sound gully works. waves. Waste All Increase in Implement site- Contractors Project site Site visits, Weekly Mitigation: Monitoring: 800 rehabilitation/c waste specific waste Compliance inspection, Contractor ESO, KGS- onstruction generated management plan and MENV, KSEPB, works Liaise with KSEPB for consultation effective waste with management monitoring agencies Sanitary Increased Increased Provision of on-site Contractors Project Site visits One-off Mitigation: Monitoring: 1200 Concerns human faecal human sanitary facilities Compliance community and Contractor ESO,KGS- waste faecal waste inspection MENV, KSEPB, Design All Interference The design shall in no Contractors Project site Site visit and During Monitoring: PMU No Rehabilitation with the way propose to Compliance inspection Design Contractor additional Works physical implement costs to setting developments that will BOQ hinder drainage, change the topography or introduce physical changes that are not in harmony with

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Measures Monitoring Where How to Monitoring Institutional Institutional Costs component Impact Indicators to monitor Frequency Responsibility Responsibility (USD) monitor (Mitigation) (Monitoring) the physical setting of the Project area. The structures to be developed should be aesthetically acceptable to blend in with the surrounding. These structures should not form or end up being used by the resident population as access or bridges. No residential facilities shall be erected on site and the proponent shall as much as possible complete the works in such a way that natural aesthetics shall be retained at the locations. Restoration shall be undertaken to ensure that the original setting is as much as possible retained.

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Social Livelihood Rehabilitatio Disruptions to Conduct survey 1. Project Examine One-off Mitigation: PMU, Monitoring: PMU 1100 Impacts n/ residents to identify best Independent community Community Independent (most Construction activities – alternatives to Consultants Livelihood Consultant importantly, of drainage (e.g. blocked prevent Compliance enhancement SLO) network access to disruptions to 2Number plan residents) livelihood within of on & off-site work Complaints areas before made by commencement the project of rehabilitation affected works. community members Traffic Mobilization Loss of travel Lane Contractors Project Site visits and Weekly Mitigation: Monitoring: PMU 1000 of time due to configuration Compliance area inspection FRSC (most equipment heavy changes importantly, and other concentration 3.. Number ESO), materials of of construction/pr oject vehicles sensitizatio on and off the n and project site awareness campaign conducted

3. Number of Complaints made by the project affected community members Grievances Involve PMU Project Site visit and Monthly Mitigation: PMU, Mitigation: PMU, 1000 and negative Respondents at Compliance community consultation Contractors (most perception certain levels of with importantly, among decision making community ESO) residents and and commercial implementation establishments of activities about the

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project

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Impact Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Education Extensive Noise Mitigation at 1.Complianc Academic Visits Monthly Mitigation: Monitoring: 1800 civil disturbances to source e institutions ,inspection PMU, ESO, Adavi work/rehabilit the serene Inform residents within and Contractors LGA ation environments for prior to project consultation activities the residence commencement of area with works institutions Social Health Continuous Increase in sexual Awareness Conduct of Project Consultation Quarterly Mitigation: Monitoring: 700 civil work activities leading campaign on awareness community, s, MWR, Public ESO, SMH activities and to possible spread sexual diseases, campaigns contractors Health dept. of steady influx of STIs and distribution of camp the Adavi LGA. of workforce male and female condoms.

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Social Health Continuous Incidence of Regular Project Site visits Monthly Mitigation: PMU, Monitoring: 1700 civil work respiratory sprinkling of community and Contractors ESO, SMH, activities and diseases due water in during inspection Public Health steady influx to air construction dept. of the of workforce contaminatio works. Adavi LGA n by fugitive dusts and exhaust fumes Blocked Possible Creation of Compliance Project Site visits Mitigation: Monitoring: 1800 drainage spread of temporary community and Contractors ESO, SMENV, channel water borne channels to inspection SMH diseases collect flood water

Environment Waste Increase in Ensure that all• Contractors Project Site visits Weekly Contractors Monitoring: 900 al hygiene management waste construction Compliance community and ESO, KGS- and generated wastes are inspection MENV, KSEPB aesthetics from gathered on- construction site and works disposed off according through the available waste disposal operation in

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) the project area. Behaviour Implementa Occurrence of Enforce and Compliance Project Site visits Monthly Contractors PMU 700 tion of civil on-site/off-site ensure proper community and works and social vices orientation on inspection Rest (Fights, rape, acceptable and periods harassments, behaviours for consultations theft, construction vandalism, personnel drug use etc. on/off-site. Project Implementa Conflicts Good work Compliance Project Site visit and Monthly Contractors PMU 1000 performance tion of all between enforcement community consultations construction contractors, program phase communities activities etc. may Conflict disrupt resolution completion of tasks. Regular stakeholders meetings

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Social Noise Massive use of Hearing Operators of Evidence of Project Site visits and Daily Contractor Monitoring: 1200 heavy impairment heavy duty procurement community inspection and KGS-MENV, machinery for for machines of ear muffs consultation PMU land clearing, machinery must wear Evidence of levelling and operators ear muffs use of the excavation of They must PPE soil not exceed 8 Record of working signing out hours per time day Noise Mitigation at 1.Complianc Project Site visits and Monthly Mitigation: PMU, Monitoring: 400 nuisance for source e 2.Number community inspection, Contractors PMU Residents. Inform of consultation residents complaints prior to received commencem from the ent of works community members Loss of Land Disincentive The Minutes of Project consultation monthly Mitigation: Monitoring: - occupation Acquisition to land pastoralist meetings community Contractor PMU owners must be with land carried along owners all through

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Impact Mitigation Measures Monitoring Where to How to monitor Monitoring Institutional Institutional Costs compone Indicators monitor Frequency Responsibilit Responsibility (USD) nt y (Mitigation) (Monitoring) Occupational Personnel All Fugitive dust and Develop and Independent Project Inspection and Monthly Independent Monitoring: 1600 Health and safety construction fumes from implement on-site Consultants/ communit consultation with Consultant, PMU, ESO Safety activities grinding, welding, occupational health Contractors y contractor, Contractors cutting, or brazing and safety Compliance examining surfaces coated management plan; contractors with lead-based Routine OHS training health and paint; Silica dust and education; Safety from cutting Conduct routine management concrete; solvent JHA/PHA; Use of plan and vapours from PPE; Establish consultants adhesives, paints, electrical safety report strippers, cleaning program; Establish fall solvents, and protection program; spray coatings; Establish fleet safety and isocyanate management program; vapours from Establish and spray foam implement HazCom; insulation and Conduct hazard certain identification, control and analysis; Establish fire prevention program; Use material safety data sheets (MSDS); Employ hierarchy of controls procedure; Conduct OHSRA, Cost Benefit Analysis(CBA), Return on Investment(ROI)/pay- back period analysis

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Table 6.2: ESMP - Construction Phase cont’d Component Sub- Activities Potential Mitigation Measures Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) spray paints Contractors should Monthly Contractors Monitoring: or coatings. prepare and implement PMU a Community Affairs, Safety, Health, Environment and Security (CASHES) manual, to coordinate OHS issues during the construction phase.

Table 6.3: ESMP - Operational Phase Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Environment Air Increased Increase of Air sampling Compliance Project Air quality Monthly Monitoring: Monitoring: ESO, 800 Vehicle road users on and community testing SMENV KGS-MENV, movement Access Road monitoring (state), KSEPB Soil Change of Change in Training on Trainings are Project Soil quality Monthly Mitigation: PMU, Monitoring: ESO, 600 topography soil profile Sustainable conducted community testing SMENV KGS-MENV, Land KSEPB Management (SLM) practices Increase in Monitoring: ESO, soil salinity SMENV, KSEPB Change in Monitoring: ESO, land use SMENV, (state), KSEPB Noise Increase of Noise Noise Project Noise level One-off Mitigation: PMU, Monitoring: ESO, 700 road users on nuisance to sampling and community testing SMENV SMENV, (state), Access Road local monitoring KSEPB residents Water Quality Roadway Potential Water Compliance Project Water quality Bi-Annual Mitigation: PMU, Monitoring: ESO, 800

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runoff surface water sampling and community, testing SMENV SMENV, (state), pollution monitoring surface water KSEPB

Table 6.3: ESMP - Operational Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Waste Waste Social and Dispose waste Proper Project Visits and Monthly Mitigation: PMU, Monitoring: 800 generation health concerns streams waste community Inspections SMENV ESO, SMENV, arising due to through the management (state), KSEPB poor waste municipal management waste practices management system in the project area. Blocked Flooding on Monitoring: 600 drainage due to roads ESO, SMENV, poor waste (state), KSEPB disposal Environment Others Negligence of Negligence of Regular PMU Project Visits and Monthly PMU Monitoring: 1500 rehabilitated rehabilitated maintenance Compliance community Inspections Weekly ESO, SMENV Ozuri gully Ozuri gully and dredging of Monthly erosion site erosion site sediments in drainage channels and chute

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Table 6.3: ESMP - Operational Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Social Employment Closure of Loss of Inform personnel Proper Project Consultatio One-off Contractors Monitoring: 1000 civil works employment that employment engagement of community ns PMU is short-term prior service to their documentation engagement. Health Operation of Blocked Regular Compliance Project Visits and Independent Monitoring: - 1500 rehabilitated drainage maintenance of community Inspections consultant, ESO, gully site structure drainage and PMU , SMH Breeding site structures consultatio for disease n with vectors health Possible institutions increase of and malaria cases community due to members stagnant water in drainage structures Increase in Increase in Regular sampling Regular Project Visits and Monitoring: 700 number of respiratory and monitoring monitoring community Inspections ESO, vehicles problems and tests SMH using roads amongst local residents

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Table 6.3: ESMP - Operational Phase Cont’d Component Sub- Activities Potential Mitigation Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Measures Indicators monitor monitor Frequency Responsibility Responsibility (USD) (Mitigation) (Monitoring) Land use Land use Land use Control land Inspections Project Visits and Contractors Monitoring: 600 conflicts conflicts conflict use conflicts are conducted community Inspections PMU through Land and use planning consultations that should be participatory to designate areas for ecological, grazing and farming Safety Increase in Increase in Use of road Compliance Project Visits and One-off Monitoring: 900 number of vehicular safety signage community Inspections ESO, FRSC road users accidents Operation of Seepage or Re-vegetation Compliance Project site Visits and One-off Monitoring: 1200 rehabilitated flow back activities using Inspections PMU gully site action approved Collapse of plant/tree rehabilitated species to gully head or establish finger gullies green belt along the gully as a stabilization measure

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Table 6.3: ESMP - Operational Phase Cont’d Component Sub- Activities Potential Mitigation Measures Monitoring Where to How to Monitoring Institutional Institutional Costs component Impact Indicators monitor monitor Frequency Responsibilit Responsibilit (USD) y (Mitigation) y (Monitoring) Occupational Personnel Tasks Injuries, Implement on-site Independent Project Site Monthly SMEnv PMU 1200 Health and safety implementati accidents, occupational health Consultants, community Inspections Safety on deaths and safety Contractors management plan; Compliance. Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Establish electrical safety program; Implement fall protection program; fleet safety management program; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Conduct OHSRA, Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis

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6.3 Environmental and Social Management Monitoring Plan Some specific Management plans have been described in the sections below.

6.3.1 Waste Management Plan The ESMP had provided detailed information on waste management including the amount and type of waste to be generated, the sources and proffered mitigation measures, among other measures to be considered include: - Sensitization amongst the labourers on the need for effective waste management throughout the sub-project activity. - Sensitization and mobilization on the adverse consequences of poor waste management. It is important that the Kogi State Ministry of Environment and KSEPB ensure that appropriate waste management control is employed.

6.3.2 Recommended Measures for Waste Management The ESMP details how wastes that will be generated at the project sites will be managed in an environmentally sustainable and socially acceptable manner. To be practical and effective in handling of wastes, (Solid and liquid) the ESMP follows the fundamental principles of waste management: - Identify and classify the type of waste generated. Proper procedures must be taken regarding their storage, collection, transportation and disposal - Identify and demarcate disposal areas clearly indicating the specific materials that can be deposited in each. - Dispose all wastes in authorized areas, metals, used oils, etc. - Identify and demarcate equipment maintenance areas (>15m from rivers, streams, lakes or wetlands). - Identify, demarcate and enforce the use of within-site access routes to limit impact to farm. - Erect erosion control barriers around perimeter of cuts, disposal pits, and roadways. - Spray water on dirt roads and stockpiled soil to reduce wind-induced erosion and particulates dispersal, as needed. - Establish and enforce daily site clean-up procedures, including maintenance of adequate disposal facilities for construction debris.

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The management of other kinds of waste that will be generated from the rehabilitation works is highlighted below: a. General Waste - There should be adequate number of garbage bins and containers made available at strategic areas of the site. The use of plastic bin liners should be encouraged. - All organic and inorganic materials will be placed and/or disposed of so as not to directly or indirectly impact any watercourse or groundwater. The placement and disposal of all such products and materials will be done in an environmentally acceptable manner. - Solids, sludge and other pollutants generated as a result of construction or those removed during the course of treatment or control of wastewaters will be disposed of in a manner that prevents their direct or indirect re-entry into any watercourse or ground waters. - Any waste material that is inadvertently disposed of in or adjacent to watercourses will be removed immediately in a manner that minimizes adverse impacts, and the original drainage pattern should be restored. - Waste materials should be placed and stored in suitable containers. Storage areas and containers will be maintained in a sanitary condition and shall be covered to prevent spreading of wastes by water, wind or animals. - All food wastes should be collected and stored in containers at appropriate locations and should be emptied at regular intervals and the collected waste should be transported to Government designated waste management facilities. d. Oil waste - Ensure that all equipment maintenance activities, including oil changes, are conducted within demarcated maintenance areas designated for such. - Ensure that oil or other lubricants are never dumped on the ground, but only in designated areas. c. Vegetative waste - The land clearing of the vegetation will be performed in accordance with stipulated standards in order to mitigate negative impact that maybe associated with the activity to the environments.

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6.4 Emergency Response and Incidence Management In the context of this sub-project, the purpose of Emergency Response and Incident Management (ERIM) is to ensure that well developed and rehearsed emergency procedures assist Kogi State NEWMAP and inhabitants of the project community to: - Effectively respond to emergencies and critical incidents in the project area - Reduce the risk of severe injuries. - Limit potential harm to the environment & surrounding infrastructure. - Minimise disruption to the community and surrounding businesses through the effective implementation of this ERIM procedures As much as possible ERIM procedures should address: - Community security and public safety actions to be taken in the case of an emergency - Effective spill containment and management - Effective fire-fighting - Effective response to emergencies and critical incidents Incident Prevention Incident preparedness procedures for potential incidents and emergencies include: - Ongoing training for project personnel; - Periodic Desktop and field exercises to uncover work place risks and hazards; - Regular auditing of construction activities; - Ongoing liaison with Emergency Services - Identifying key roles and responsibilities and effective methods of communication; - Monitoring of activities and documentation and ongoing compliance checks with statutory OHS and Environmental requirements.

6.5 Recommended Measures for Chance Find/Cultural Heritage Management In the event of chance finds of items of cultural significance, all forms of excavation in and around the site will be stopped. Subsequently, experienced archaeologist and anthropologist would be recruited to carry out an investigation and proposed plans for the preservation of such cultural artifacts. During the project site induction meeting, all contractors will be made aware of the presence of an on-site archaeologist who will monitor earthmoving and excavation activities.

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The following procedure is to be executed in the event that archaeological material is discovered: - All construction activity in the vicinity of the find/feature/site will cease immediately. - Delineate the discovered find/ feature/ site will be delineated. - Record the find location, and all remains are to be left in place. - Secure the area to prevent any damage or loss of removable objects. - The on-site archaeologist will assess, record and photograph the find/feature/ site. - The on-site archaeologist will undertake the inspection process in accordance with all project health and safety protocols under direction of the Health and Safety Officer. In consultation with the statutory authorities the on-site and Project Archaeologist will determine the appropriate course of action to take.

6.6 Reasons for Failure in Gully Rehabilitation Gully control can be tedious where executed measures do not seem to work. Failure in control brings losses of material, time, money and sometimes makes the gully erosion even worse. Actually, failure can be avoided if appropriate measures are taken and proper techniques are applied. From experience, the following problems can be taken as the major reasons for the failure of most of the gully rehabilitation schemes and they must be avoided in this project. - Poor consideration for upper catchment treatment - Poor installation of check-dams that is related to lack of keying the check-dam to the floor and sidewalls of the gully - Lack of apron. If there is no apron, water falling from the check-dam spillway erodes the area below and undermines the structure. If the apron is not keyed or secured into the gully, it will be washed away. - Lack of spillway. The check-dam tends to impede the flow of water. This leads to the water exerting pressure on the dam that can weaken it. A spillway will discharge the runoff thus protecting the check-dam. - Poor maintenance. The life and effectiveness of control measures are extended by regular maintenance. Any shortcomings in the control structures should be corrected before they develop into serious problems. Any grass, shrub/bush and tree planted which dies should be replaced.

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- Improper spacing of check-dams. Proper spacing is crucial if the check-dams are to serve their purpose. Inappropriate and irregular spacing of the check-dams may lead to their being washed away. - Failure to complete the work. In some instances, the gully rehabilitation schemes may not be completed because of various reasons. Half measures do not offer the required protection and are a waste of time and resources. - Structures are sometimes made too high and the water that ponds causes instability of the soil and piping underneath or around the structure. - Poor integration between physical and biological measures.

6.6.1 Management of Rehabilitated Erosion Site Management of gully control structures is a very important point worth to be emphasized. Treated gullies should be checked regularly and the healing process monitored closely. Structures built in the gully for stabilization purpose should be observed for damage especially during rainy seasons and after heavy storms. Damaged check-dams should be repaired immediately to avoid further damage and the eventual collapse. The use of gully will depend on whether it has been established for a protected waterway or the water has been diverted and the gully stabilized for other uses. Under the condition when the water is discharged through the gully after the necessary stabilization activities have been undertaken, the side of the gully can be used for growing of grass or fodder. But, in conditions when the gully is not used as a waterway, it can be used for growing horticultural crops or plants such as banana or other fruit trees. Wide gullies can have tree planted on the side slopes provided they are not too steep. The other important issue for sustainable gully rehabilitation scheme is the identification of users and development of a use concept or management plan. In most cases, gullies are crossing different land uses owned by many land users. Therefore, before treatment of gullies, the users should be identified and the boundaries should be clearly demarcated, the gully rehabilitation process should be objective oriented and responsibilities of owners in managing, maintaining and utilizing the gully and its produces should be elaborated and agreed upon. Experiences have shown that most of the gully rehabilitation efforts are made accidentally without having clear purposes. As a result, it is common to see gullies with a huge biomass, mostly of one species (Sesbania sesban or Elephant grass) but not harvested and after all owners are not 145

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

known. This has forced the community members into conflict and hence destruction of the whole endeavour. In view of this fact, the identification of land owners along gully areas and demarcation of their boundary, development of a management plan and formulating user’s agreement (on maintenance and proper utilization of the gully) should come before any treatment effort. It is always crucial to remember that before deciding to undertake gully control measures one has to plan first for what purpose the gully is intended to be used after treatment and then try to take measures relevant to the future strategy.

6.7 Grievance Redress mechanisms The World Bank’s approach to GRM will apply (Annex 5); alternative conflict resolution and problem solving mechanism abound at local levels. 4 levels of grievance resolution mechanism have been propounded; summary of which have been highlighted below: Step 1: Assessment of Risks and Potential Grievances and Disputes; Step 2: Capacity Assessment Step 3: Action Plan Step 4: Follow-up and review To operationalize the GRM effectively, grievances have to be classified according to their potential severity or complications. One of the most common ground for grievances is land compensation entitlement and disbursement. This is likely going to generate grievances more constantly than any other issues about the project. More complicated matters like RAP and implementation issues that may involve private sector entities and third-party agencies are likely to require the attention of the PMU. For the GRM to be effective as an all-inclusive engagement instrument that effectively handle the grievances of women, there has to be a deliberate structuring to include Women in Grievance Redress Committee, who will easily be approached by women for the purpose of presenting their grievances. Grievance Procedures Registration It may be less depending on the severity of the matter under consideration. The first step is the presentation of a grievance at the uptake point at any level. The social contact person will receive grievance from the complainant clarify primary information, register and acknowledge receipt of it 146

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State to the grievant within two days. The registration will capture the following data: Name of the complainant, Date of the grievance, Category of the grievance, Persons involved, Impact on complainant’s life, Proofs and witnesses. A registration form will have all these bits of information. Verification The verification will determine among other things whether the matter has any relationship with the Project and whether the level at which it is presented can handle it. This will mean a quick referral of the case either to the next level or the traditional rulers or to law enforcement. Part of investigation will also be assessing the cost of loss or risk involved in the grievance. Processing The processing step is when options for the approach to resolving the case are weighed and determined. Parties involved in the case are brought together for a first attempt at resolution with suggestion from the parties by the social contact personnel. The social personnel at a certain level then decide where the case should go to for hearing and resolution if complainant decides to pursue the matter further. This should happen within five days from investigation. Implementation and case closing The social contact personnel then refer the case to the responding authority within the level for GRM implementation. This authority may be the chairman of the GRC or the officers with direct responsibility over the nature of the case within the PMU. Putting this in writing makes the appeal process faster in case of dissatisfaction on the part of the complainant. And in the case of satisfaction, it is an instrument to compel execution of decision. The outcome of the Grievance Redress process is therefore communicated to the complainant and other concerned party. The result of the process can vary. The request of the complainant may be turned down, compensation may be recommended, or Management may simply apologize to the grievant. Feedback All responses to the complainant in a grievance redress process that moves beyond the unit level must be communicated in writing and/or by verbal presentation to the complainant. This will include a follow up on the corresponding authority where cases are referred to ascertain the status of reported cases. Feedback on outcome of each case should get to the complainant through the social contact person at all levels. Guiding Principles

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Having a grievance redress measure connotes readiness for plain fairness. This GRM has to be based on the following universal principles that guide fairness in these matters: i. Accessibility and social inclusion: The process has to be accessible to everybody that feels aggrieved and affected by the project components in anyway regardless of their age, gender or economic status within the communities. Vulnerable groups including women, children and the physically challenged should have opportunities to present their complaints without complications. ii. Simplicity: the filing of complaints and grievances will be kept simple and the process of redress will be easy to understand by stakeholders. Suggestions complaints and queries may be presented through different accessible channels. iii. Transparency: The system will encourage feedback of any kind (negative or positive) as long as it has bearing on the project. These feedbacks will be made available to all stakeholders to put them abreast of issues that may stall or enhance the sustenance of the project. It is important that representatives of the community be involved in the redress of grievances and everybody kept informed on any progress made on them. iv. Due process and impartiality: Every grievant will have the right to be present and be heard before a duly constituted body saddled with the responsibility of hearing and managing their complaints or grievances. The system will view and analyse all issues with transparent objectivity. This will enhance responsiveness of all parties concerned and build trust. The mechanism will be independent so that it will be perceived as fair by all. v. Quick action: Response to grievance and feedbacks will be prompt and direct to the grievant or the feedback provider. Grievances will be acknowledged at the point of uptake and the ensuing decisions will be communicated within 48 hours of reaching them. vi. People: It is important that all stakeholders, including project personnel be involved in the process of grievance redress. Grievant lodgers or feedback providers will assume full responsibility for their filings. Personnel that would be involved in grievance redress on the supply side have to have basic communications skills. Key persons on the redress team will need to acquire skills for mediation, conciliation and negotiation. Grievance redress policy will be sustained by the commitment of persons involved both on the demand and supply side. There is need for personnel who will be providing grievance redress services to have knowledge of the already disclosed policies guiding resettlement for NEWMAP.

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vii. Process: This GRM will have a predictable process that will operate in all the intervention sites and in all the components of the project. There will be specified grievance uptake points where grievances/complaints will be lodged. The time frame for a response will be known to the grievant. Investigation and deliberations on the complaint will be open and communicated promptly. viii. Analysis: In grievance redress it is important for handlers to be clear on all the issues. A first step is an honest appraisal of whether the feedback is proactive or reactive. Facts have to be established against the interest and goal of grievant. Fact-finding is essential for meaningful and sustainable grievance/conflict redress. Grievances spring from differences in expectations, interests, knowledge or lack of it, needs and fears. Questions arise in the process that must be taken into account. Are the complainants digging in or unforgiving or are they unwilling to accept the outcomes? The handlers of grievance redress also need to appraise the complaints against relevance to the project and the project policies. This will need to be done with reference to the already prepared RPF, ESMF and the RAP. This requires a thorough knowledge of various policies and guidelines of NEWMAP. Grievance handlers also need to know the category of grievance involved and treat accordingly. Grievances need to be characterized both for the sake of proper redress and for evaluation purpose.

6.8 Gender Based Violence Nigeria has acceded to the core international human rights treaties and is a party to the major regional human rights instrument which obliged States to respect, protect and fulfill human rights of all persons within the territory and subject to the jurisdiction of the State, without discrimination. Rape may violate several human rights obligations enshrined in the instruments ratified by Nigeria and is also a form of gender-based violence and a brutal manifestation of violence against women. As a State party to the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) and the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa (the “Maputo Protocol”), Nigeria has made legally binding commitments to exercise due diligence to combat gender-based violence and discrimination. Accordingly, Nigeria has an obligation to take all appropriate measures to prevent rape, ensure that there are adequate sanctions for rape in law and in practice, and ensure access to reparation for 149

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State the victims. Furthermore, several human rights instruments require Nigeria to take special measures to protect the rights of individuals who are vulnerable to sexual violence, namely women, children, and persons with disabilities. The United Nations Special Rapporteur on violence against women has provided guidance on States’ due diligence obligations in combating sexual violence, noting that it must be implemented at both individual and systemic levels. Individual due diligence focuses on the needs of individual survivors and “places an obligation on the State to assist victims in rebuilding their lives and moving forward,” for instance through the provision of psychosocial services. Individual due diligence “requires States to punish not just the perpetrators, but also those who fail in their duty to respond to the violation.” As for systemic due diligence, it includes ensuring “a holistic and sustained model of prevention, protection, punishment and reparations for acts of violence against women. 1. International Treaties • The International Covenant on Civil and Political Rights (ICCPR) (2004) • The International Covenant on Economic, Social and Cultural Rights (ICESCR) (2004) • The Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT) (1993) • The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) (1984) • The Convention on the Rights of the Child (CRC) (1990), and the Convention on the Rights of Persons with Disabilities (CRPD) (2012) • International Convention on the Elimination of All Forms of Racial Discrimination (1976) 2. Regional Treaties • The African Charter on Human and Peoples’ Rights (ACHPR) (1982) • The African Charter on the Rights and Welfare of the Child (ACRWC) (2007) • The Protocol to the ACHPR on the Rights of Women in Africa (the “Maputo Protocol”) (2007) 3. National polices • The National Action Plan for the Implementation of United Nations Security Council Resolution 1325 (2009); • The National Gender Policy (2010)

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Nigeria is among the 10 percent of countries worldwide that exhibit the highest levels of gender discrimination according to the OECD’s Social Institutions and Gender Index (see the figure below), with an assessment of “high” or “very high” in all of the evaluated categories (discriminatory family code, restricted physical integrity, son bias, restricted resources and assets, restricted civil liberties). It also falls into the group of countries with highest gender inequality in human development outcomes (UNDP 2016). Gender-Based Violence (GBV) remains pervasive and underreported in the country, largely constraining women’s autonomy and life chances. The 2013 Demographic Health Survey (DHS) indicates that nationally 38 percent of women between the ages of 15-49 have experienced some form of physical or sexual violence from the age of 15, and 11 percent experienced physical violence within the 12 months prior to the survey. 45 percent of women who experienced violence never sought help or never told anyone about the violence. Besides interpersonal and sexual violence, child marriage and Female Genital Mutilation are the other culturally harmful practices prevalent across Nigeria. Conflict in the North East has further contributed to a steep rise in targeted violence against women and children by Boko Haram increasingly for abduction and violence. Women are increasingly being used as instruments of war, making them vulnerable to stigmatization and rejection from their families and communities. Figure 1 below illustrates pervasiveness of GBV Nigeria on regional:

Nigeria Degree of Gender Inequality according to the Social Institutions and Gender Index

South Nigeria Niger Mali Namibia Vietnam Brazil Thailand Africa Overall Discriminatory family code Restricted physical integrity Son bias Restricted resourcs and assets Restricted civil liberties

Legend: very low medium very high low high

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GBV Risk Management Mechanisms NEWMAP has adopted Specific measures to reduce and mitigate the risk of GBV/SEA in the project. Such measures include: i GBV/SEA assessment of project; ii mandatory contractors’ code of conduct on sexual harassment; iii appointment of NGO to monitor GBV/SEA in NEWMAP-AF; iv community and workers’ sensitization on GBV/SEA; v provision of referral units for survivors of GBV/SEA; vi provisions in contracts for dedicated payments to contractors for GBV/SEA prevention activities against evidence of completion; vii Contractor and SPMU requirement to ensure a minimum target of female employment with incremental rewards of the obtainment of this target. The following actions are recommended for immediate implementation: • Hiring a dedicated GBV/SEA specialist or retraining SLOs for the project, • Including in the focal NGO’s ToR services for managing social risks associated with GBV/SEA in the project, • Building and improving FPMU/SPMUs, local communities and other relevant stakeholders’ capacities to address risks of GBV/SEA by developing and providing guidance, training, awareness, and dissemination of relevant GBV/SEA materials to communities, • Developing a clear NEWMAP specific internal “Reporting and Response Protocol" to guide relevant stakeholders in case of GBV/SEA incidents, • Strengthening operational processes of NEWMAP states project area on GBV/SEA, • Identifying development partners and cultivating pragmatic partnership on GBV/SEA prevention measures and referral services, • Developing Codes of Conduct for civil works contractors with prohibitions against GBV/SEA, • Strengthening consultations and operationalizing GBV/SEA specific grievance redress mechanisms, • Providing financial support implementation of the GBV/SEA actions described herein, including training and awareness building for various stakeholders, • Establishing inter-ministerial committee to advance GBV/SEA actions described above.

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Overall, GBV risks in the project target areas might include Intimate Partner Violence (IPV), public harassment including harassment, verbal insults, physical abuse, rape, harmful widowhood practices and women and child trafficking. Targeted support to women under the program could likely exacerbate these risks. Development and implementation of specific GBV risk prevention and mitigation strategies, tailored to local contexts, will be critical. Guidelines for situation analysis of GBV and safe reporting guidelines in line with international best practices will be implemented. Further, all risks related to labor influx will have to be mitigated by participation of project beneficiaries/communities, and involvement of project contractors and contractors’ workers and consultant employees, in identifying mitigation and implementing measures, including developing mitigation instruments such as “Labor Influx Management Plan” and “Workers Camp Site Management Plan”.

6.9 Workers Influx and Child-Labour Management The project may face an influx of non-local labour and working conditions issues as skilled labourers might not be available in some of the project sites. The project is expected to take concrete measures to mitigate potential labour influx-related risks such as workers’ sexual relations with minors and resulting pregnancies, presence of sex workers in the community, the spread of HIV/AID, sexual harassment of female employees, child labour and abuse, increased dropout rates from school, inadequate resettlement practices, and fear of retaliation, failure to ensure community participation, poor labour practice, and lack of road safety. These risks will require careful consideration to improve social and environmental sustainability, resilience and social cohesion. Therefore, the project will include mitigation measures such as:

a assessing living conditions of workers’ camps and ensuring appropriate living conditions;

b establishing and enforcing a mandatory Code of Conduct for the company, managers and workers, and an Action Plan for implementation;

c ensuring appropriate location for these camps;

d taking counter measures - indicated in the Social Management Plan - to reduce the impact of the labour influx on the public services; and,

e devising and implementing a strategy for maximizing employment opportunities for local population, including women.

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The following guidelines lays out the principles that are key to properly assessing and managing the risks of adverse impacts on project area communities that may result from temporary NEWMAP induced labour influx. a The SPMU will have to hire, to the maximum extent, skilled and unskilled workers from affected communities in the project area. The SPMU will adopt or implement all possible measures to avoid if not minimize labour influx into the project area. b The SPMU will assess and manage labour influx risk, based on appropriate instruments such as those based on risks identified in the ESIA and the Bank’s sector-specific experience in the country. c Depending on the risk factors and their level, appropriate mitigation instruments need to be developed such as Site-specific Labour Influx Management Plan and/or a Workers’ Camp Management Plan, d Risk factors to the SPMU that should be considered, include: • weak institutional capacity of the implementing agency; • predominant presence of contractors without strong worker management and health and safety policies; • anticipated high volumes of labour influx; • pre-existing social conflicts or tensions; • weak local law enforcement; • prevalence of gender-based violence and social norms towards it in the community (acceptance of gender based violence); • prevalence of transactional sex; • local prevalence of child and forced labour; • existing conflict situation between communities; • absorption capacity of workers to the community e The SPMU will be required to incorporate social and environmental mitigation measures into the civil works contract and responsibilities for managing these adverse impacts. This will be a binding contractual obligation on the SPMU, with appropriate mechanisms for addressing non- compliance The Supervision Consultant shall be responsible for monitoring the contractor performance and adherence to the labour influx guideline and that of its Sexual Exploitation and Abuse (SEA)

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obligations, with a protocol in place for immediate, timely, mandatory and confidential reporting in case of incidents to project community. This allows the SPMU to enforce the implementation of such mitigation measures, which are required to ensure the consultant’s own compliance with Bank policy requirements. While the Bank reviews and clears project-level safeguard instruments such as the ESIA/ESMP, it is the SPMU’s responsibility to:

i ensure the safeguard instruments are reflected in the contractor’s ESMP (CESMP), and

ii ensure the project is implemented in accordance with the CESMP, safeguard instruments and other relevant contractual provisions.

6.10 Community Security, Health and Safety Management Sub-project activities, equipment, and infrastructure can increase community exposure to risks and impacts. While acknowledging the role of public authorities’ in promoting the health, safety, and security of the public, Kogi NEWMAP through the Contractor(s) will be directly responsible for avoiding or minimizing the risks and impacts of community health, safety, and security that may arise from project related-activities, with particular attention to vulnerable groups. Major Objectives of Community Security, Health and Safety Management include: - To anticipate and avoid adverse impacts on the health and safety of the Affected Community during the project life from both routine and non-routine circumstances. - To ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities. Community Security, Health and Safety Management should be established during the environmental and social risks and impacts identification process. The implementation of the actions necessary to meet the community security, health and safety should be managed by Kogi NEWMAP’s Environmental and Social safeguards officers. It is necessary that trainings be delivered for the Community, Contractors and the SPMU with regards to Health and Safety. The SPMU should procure a consultant that will carry out these trainings before the contractors are mobilized to sight. This will help prepare the SPMU and Communities in handling HSE issues that may arise during project implementation. Below is a guide to some of the trainings and timeline for delivery;

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Table 6.4: Guide for HSE Training S/N Module Topics Duration Participants 1 Construction Safety Fall Protection 2days Contractor, SPMU, Community, Equipment safety and Handling 1day Contractor, SPMU, Community, Excavation Waste management 3days Contractor, SPMU, Community, Permit to work 1day Contractor, SPMU, 2 Fleet Safety Vehicle Parking and Operations 2days Contractor, SPMU, Community, Sight specific and Perimeter Safety Signage 2days Contractor, SPMU, communication for communities Community, Emissions Management 1day Contractor, SPMU, Community 3 Hazard Effective hazard Communication for contractor 1day Contractor, SPMU Communication Personnel / Workers Effective hazard Communication for Communities 1day Community, 4 Job Hazard Job Hazard Analysis 1 day Contractor, SPMU, Analysis Community, 5 Disaster Hazard Preparedness and Response 1day Contractor, SPMU, management Community, Emergency Planning and Communication 1day Contractor, SPMU, Community, 6. Accident Accident Investigation 1day Contractor, SPMU Investigation Accident Analysis and Report Writing 1 day Contractor, SPMU

6.11 Stakeholders Engagement Plan Stakeholders’ engagement is essential in achieving the major objectives of any project implementation and sustainable development. Participatory approaches in project planning and implementation enhance project policy, ownership and sustainability and also empower targeted beneficiaries. The objectives for stakeholders’ engagement and sensitization includes but not limited to the following; i. To create general public awareness and understanding of the project, and ensure its acceptance; ii. To develop and maintain avenues of communication between the project proponent, stakeholders and PAPs in order to ensure that their views and concerns are incorporated into the project design and implementation with the objectives of reducing, mitigating or offsetting negative impacts and enhancing benefits from the project;

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iii. To inform and discuss about the nature and scale of possible adverse impacts of the rehabilitation work and to identify and prioritize the mitigation measures for the impacts in a more transparent and direct manner; iv. To document the concerns raised by stakeholders and PAPs so that their views and proposals are mainstreamed to formulate mitigation and benefit enhancement measures; v. To sensitize other MDAs, local authorities, Non-governmental Organizations (NGOs) and Community Based Organizations (CBOs) about the project and solicit their views and discuss their share of responsibility for the smooth functioning of the overall project operations; and vi. Reducing conflict between stakeholders, project proponents PAPs. a) In summary, it goes to spell out the role of stakeholders in the project planning, implementation and monitoring. Envisaged Benefits The envisaged benefits of the Stakeholders engagement and sensitization exercises include; - Provision of opportunities to foresee and/or resolve potential obstacles, constraints and conflicts; - Means to identify and address potential negative social and environmental impacts as envisaged by stakeholders; - Opportunities to generate social learning and innovations based on local field experiences; - Means of ensuring that project benefits are distributed equitably, and; - Strengthened working relations between stakeholders; Federal and State Governments, etc., and the World Bank.

6.12 Fundamentals of Stakeholder Engagement Approach Consultations Meaningful consultations can contribute to improved design, implementation, and sustainability of development interventions. The objectives of consultations include receiving input for improved decision-making about the design and implementation arrangements of a development program or project, to contribute to improved results and sustainability. In this context, consultations can potentially give voice to the needs of different population groups, including vulnerable and marginalized groups; improve risk management by identifying opportunities and risks from and to a project; and increase transparency, public understanding, and stakeholder involvement in development decision-making. 157

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Consultations with key stakeholders, including project-affected people and civil society, are mandatory in development projects so as to satisfy “best practices”. Consultation methods include public hearings or meetings, focus group discussions, household surveys and interviews, electronic consultations, and advisory/expert groups. In addition, consultations can include informal structures at the local level, such as village councils and women’s groups. Good practice approaches to consultation, including closing the feedback loop, need to be applied more systematically. Collaboration Collaboration with stakeholders in decision-making processes and events can make decisions more responsive to stakeholder needs and improve the sustainability of program and project outcomes through increased ownership by stakeholders. Mechanisms for collaboration include stakeholder/user membership in decision-making bodies, integrity pacts, participatory planning and budgeting, and stakeholders’ juries. Collecting, Recording, and Reporting on Inputs from Stakeholders Stakeholder feedback can be collected periodically on various dimensions of public services provided, such as effectiveness, inclusiveness, quality, delivery time, transaction costs, and targeting, as well as on resource utilization or engagement processes. Tools include satisfaction surveys, focus group discussions, hotlines, community scorecards, stakeholder report cards, or SMS/online feedback Stakeholders-led Monitoring Involving stakeholders in monitoring service delivery, revenues, budget execution, procurement, contract awards, and reform policies can increase transparency, improve efficiency of service delivery or budget execution, and reduce opportunities for corruption. Some mechanisms for stakeholders-led monitoring include public expenditure tracking surveys, social audits, or stakeholder report cards. Additional entry points for stakeholder’s engagement in monitoring include collaboration with local CBOs/NGOs, communities, local academia, or think-tanks in gathering results data and conducting joint evaluations of project results after project completion (including in the preparation of project Implementation Completion Reports). Capacity Building for Stakeholder Engagement Capacity building for stakeholders, CBOs, communities, government officials, and national accountability institutions to engage and participate in service delivery, natural resource

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management, public financial management, or CDD projects can also contribute to improved project outcomes. Capacity-building components are therefore included in a number of World Bank-supported operations. Capacity building for all relevant stakeholders is particularly necessary and needs to be systematically integrated into WBG supported operations where SE approaches are introduced for the first time at scale at the national, sectoral, program, or project level. A focus on building government capacity is also important to ensure the sustainability of engagement processes beyond the life of a project intervention.

6.13 Social Investment Plan Social investment refers to philanthropy, charitable giving, corporate social responsibility, community programs and social contributions to contribute to society that is not primarily motivated by generating a direct financial return. NEWMAP should employ a three phased approach strategy which includes community investment, social investment and philanthropy. The potential benefit of NEWMAP social investments in the community will create significant opportunities for businesses, including enabling them to meet regulatory requirements, secure a social license to operate, improve reputation, attract talented employees, increase workforce engagement and develop new products and markets. The areas for social investment include education, health, disaster relief, environment, community welfare, housing, infrastructure & energy, sports & recreation, food and agriculture. NEWMAP should work in conjunction with existing community NGOs/CBO in achieving the investment plan. This social investment plan is further delineated in the RAP/ARAP developed in the framework of this subproject.

6.14 Project Coordination and Implementation Arrangements It is necessary to highlight and define the roles, responsibilities and institutional arrangements for the implementation of the ESMP, as they are fundamental to the effective implementation of the environmental safeguard measures outlined in this ESMP. Accordingly, details of institutional arrangements and the roles and responsibilities of the various institutions in the implementation of the ESMP are highlighted below.

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6.14.1 NEWMAP Institutional Arrangement Generally, the NEWMAP project is expected to run at two levels, namely the Federal and State. At the Federal level, the Federal Project Management Unit (FPMU) supervised by the Federal Ministry of Finance will manage the Coordination and Program Support. The FPMU will establish coordination and support relationship with the State counterpart Agencies. Thus at the State level, the governments of the 14 States have set up by State Law, agencies that would work in collaboration with the FPMU, though operating independently. Albeit, the Ministry of Finance, Budget and / Economic Planning, as the case may be in the various State is at present taking the lead in the coordination of the NEWMAP preparatory programmes. The law or legal agreement used in establishing the agencies will insulate the agencies and specifically the management unit from undue political or administrative interference. In addition, to implement the NEWMAP program according to the agreed terms and conditions, a formal agreement is needed between the State Governments, the Implementing Agencies (PMU) and other MDAs outlining the tasks, responsibilities, schedules, procedures, deliverables etc., required for preparation and implementation of the approved sub-projects. Furthermore, the State Agency/Project Management Unit (PMU) will have an advisory board or a technical steering committee and a management unit. The board will include representatives from civil society and the government. The State Project Management Unit S(PMU) headed by a Project Coordinator who will supervise activities of staff within three (3) major departments of the Agency, namely: Operations, Finance and Administration, and Monitoring and Evaluation (all three departments will cater for the environmental and social components/issues as concerns the NEWMAP). To capture the inflow and use of credit proceeds in a transparent manner through the Office of the Accountant General [Project Financial Management Unit (PFMU) set up for financial management of donor assisted projects at the state level], the PMU shall establish a relationship with PFMU. This relationship would entail: -A copy of the annual budget and work plan will be made available to the FPMU by the SPMU; -FPMU internal auditors will be responsible for regular internal audit in the PMU and submit quarterly reports to the government (copied to IDA). -A copy of monthly progress reports, quarterly reviews and interim Financial Reports (IFRs) shall be sent regularly to the PFMU; 160

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-

6.14.2 Roles and Responsibilities The successful implementation of the ESMP depends on the commitment of the sector and related institutions, and the capacity within the institutions to apply or use the ESMP effectively, and the appropriate and functional institutional arrangements, among others. Thus, details of institutional arrangements, the roles and responsibilities of the institutions that would be involved in the implementation of the ESMP are highlighted below. For the purpose of this ESMP, the institutions identified include; -Federal Level Institutions: Federal Ministry of Environment and other relevant Ministries, Departments and Agencies (MDAs). -State Level Institutions: SPMUs and other relevant Ministries, Departments and Agencies (MDAs). - Local Government Level Institutions: Local Government Review Committee -(LGRC); Local Government Desk Office (LGDO) - Community Level and other Institutions -Direct and Other Stakeholder/Groups: Community Project Management Committee (CPMC); CDA; CBO/NGOs - Consultants, Contractors and Site Engineers -World Bank

6.15 ESMP and Monitoring Budget Table 6.5: Summary of ESMP and Monitoring Budget S/N Items Responsibilities Cost Estimate in Cost Estimate in Nigerian Naira (N) Us Dollars (USD) 1 Mitigation Contractor To be included in To be included in contract sum contract sum 2 Monitoring KSG-NEWMAP,KSG MDAs, 24,053,500 65,900 FMEnv. Federal MDAs KSG- MEnvr, KSEPB 3 Capacity Building KSG-NEWMAP, Communities 15,200,000 41,643.84 4 Sub-Total 39,523,500 107,544 5 10% Contingency 3,925,350 10754.4 6 Grand Total 43,178,850 118,298

The total cost for Implementing the Ozuri Gully Erosion Site Rehabilitation Works ESMP is estimated at N43,178,850.00 (Forty Three Million, One Hundred and Seventy Eight Thousand

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Eight Hundred and Fifty Naira) only, at N365 per USD; that correspond to One Hundred and Eighteen Thousand Two Hundred and Ninety Eight US. Dollars [USD118, 298.00].

6.16 ESMP Disclosures After a review and clearance by the World Bank, the ESMP will be disclosed at the FMEnv, SME and host LGA offices as well as at the World Bank website. The purpose will be to inform stakeholders about the project activities, impacts, anticipate and proposed environmental management actions. The purpose is also to obtain the certificate of conformity from the Federal Ministry of Environment.

The ESMP will be subjected to mandatory Technical Review as scheduled by Federal Ministry of Environment followed by the Impact Mitigation Monitoring (IMM) exercise for the purpose of EIA Certification

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CHAPTER SEVEN: SUMMARY, CONCLUSION AND RECOMMENDATION 7.1 Summary This Environmental and Social Management Plan (ESMP) has provided operational guide, including action plans, to incorporate environmental and social considerations into the proposed gully rehabilitation project at the Ozuri gully erosion site located at Adavi Local Government Areas (LGAs), Kogi State, Nigeria. The biophysical, social and environmental baseline information of the proposed intervention site were assessed. The ESMP identified environmental parameters which may be positively and or negatively impacted upon at the different identified phases of the project development, and presented the necessary mitigation measures for such identified impacts. 7.2 Conclusion The approach developed in this ESMP will restore gully induced damage and reduce longer-term gully vulnerability in Ozuri community of Adavi LGA in Kogi State. It is expected that if the gully is rehabilitated, both the tangible and intangible human and environmental values within the community will be enhanced. 7.3 Recommendations The following recommendations are for the consideration of the Kogi State NEWMAP PMU towards ensuring the improvement of decisions and filling of gaps identified by the ESMP study. Improvement of capacity of the Project site committee members is important to ensure that they deliver their duties as expected. Also there should be adequate awareness creation in the area of water harvesting as this will reduce surface run-off especially during the rainy season thereby preventing flooding and subsequent erosion. Residents should be enlightened on the anthropogenic causes of erosion and ways to prevent them especially in alternative ways of doing things. There is a need to enlighten the residents of the community on SLM practices that will maintain or improve a balanced soil organic material-nutrient cycle as well as reduce vulnerability to erosion There is also a need to create more awareness on the anthropogenic causes of soil erosion and flooding with a bid to prevent future occurrence after the rehabilitation works.

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Waste management is also a serious issue in the area as residents tend to dump refuse either in the gully or drainages. These should be discouraged and programmes designed to enlighten them of best practice for refuse disposal.

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REFERENCE Allen, A. and Bem, D.J., (1974). On Predicting some of the People some of the Time: Search for Cross- Situational Consistencies in Behavior. Psychological Review, 81. 506-520

American Public Health Association (APHA), 1998: Standard Methods for the Examination of Water and Wastewater, 20th edn. Washington, DC.

Black et al. (1965), Methods of Soil Analysis, Part 2. Am. Soc. Agron.,Madison, Wise., pp. 1467—1472.

Bouyoucos, G. H. 1951: A Recalibration of the Hydrometer Method for Making Mechanical Analysis of Soils. – Agronomy J. 43: 434-438.

Golterman, H.L., Clyno, R.S. & Ohnstad, M.A.M. 1978. Methods for physical and chemical analysis of freshwaters. 2 ed. Blackwell, Oxford. 315p.

International Institute of Tropical Agriculture, IITA (1979). Selected methods for soil and plant analysis, manual series No 1, 3 Edition, IITA, Ibadan, Nigeria, p. 34.

Jackson, P.W., and Getzels, J.W., (1962): Creativity and Intelligence. New York: Wiley

Jones, P. D., Briffa, K. R., Barnett, T. P. and Tett, S. F. B., 1998. High-resolution palaeoclimatic records for the last millennium; interpretation, integration and comparison with general circulation model control-run temperatures, The Holocene, 8, 455-471.

Murphy, J., and J.P. Riley (1962): A Modified Single Solution Method for the Determination of Phosphate in Natural Waters. Anal. Chim. Acta, 27: 31-38

Tabatabai MA (1974) A rapid method for determination of sulfate in water samples. Environ Lett 7:237–243

Walkley, A. and I. A. Black. 1934. An examination of Degtjareff method for determining soil organic matter and a proposed modification of the chromic acid titration method. Soil Sci. 37: 29-37.

(keay et al. 1964, Akobundu and Agyakwa 1987, Hawthorne 1990)

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ANNEX ONE KOGI STATE NEWMAP: TERMS OF REFERENCE FOR THE PREPARATION OF ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) FOR OZURI GULLY SITE UNDER THE NIGERIA EROSION AND WATERSHED MANAGEMENT PROJECT (NEWMAP)

Background The Government of Nigeria is implementing the multi-sectoral Nigeria Erosion and Watershed Management Project (NEWMAP), which is financed by the World Bank, Global Environment Facility, the Special Climate Change Fund, and the Government of Nigeria. NEWMAP finances activities implemented by States and activities implemented by the Federal government. The project initially targeted 7 states, namely Anambra, Abia, Cross River, Edo, Enugu, Ebonyi, and Imo. However six additional states including Plateau, Kogi, Kano, Delta, Oyo and Gombe have recently joined the programme.

The lead agency at the Federal level is the Federal Ministry of Environment (FME), Department of Erosion, Flood and Coastal Zone Management. State and local governments, local communities and CSOs are or will be involved in the project, given that the project is a multi-sector operation involving MDAs concerned with water resources management, public works, agriculture, regional and town planning, earth and natural resources information, and disaster risk management.

The development objective of NEWMAP is: to rehabilitate degraded lands and reduce longer-term erosion vulnerability in targeted areas. At State level, NEWMAP activities involve medium-sized civil works such as construction of infrastructure and/or stabilization or rehabilitation in and around the gullies themselves, as well as small works in the small watershed where gullies form and expand. These works trigger the World Bank’s Safeguard Policies including Environmental Assessment OP 4.01; Natural Habitats OP 4.04; Cultural Property OP 11.03; Involuntary Resettlement OP 4.12 Safety of Dams OP 4.37; Pest Management Safeguard Policy OP 4.09; and Projects on International Waterways OP 7.50.

The environmental and social safeguards concerns are being addressed through two national instruments already prepared under the project: an Environmental and Social Management Framework (ESMF) and a Resettlement Policy Framework (RPF). These framework instruments need to be translated into specific costed, measurable, and monitorable actions for specific intervention sites through the preparation of site- specific management and action plans.

ESMF.In general, the ESMF specifies the procedures to be used for preparing, approving and implementing (i) environmental/social assessments (ESAs, or alternately both an SA or an EA) and/or (2) environmental/social management plans (ESMPs, or alternately both an EMP and SMP) for individual civil works packages developed for each project. ESMPs are essential elements for Category B projects.

RPF .The RPF applies when land acquisition leads to the temporary or permanent physical displacement of persons, and/or loss of shelter, and /or loss of livelihoods and/or loss, denial or restriction of access to economic resources due to project activities. It sets out the resettlement and compensation principles, organizational arrangements and design criteria to be applied to meet the needs of project-affected people, and specifies the contents of a Resettlement Action Plan (RAP) for each package of investments. Objective and Scope of the Consultancy The objective of the consulting services is to prepare an environmental and social management plan (ESMP) for the Ozuri gully erosion sub-project in Kogi State intervention site(s). Each ESMP is site-specific and consists of a well-documented set of mitigation, monitoring, and institutional actions to be taken before and during implementation to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. Each ESMP also includes the measures needed to implement these actions, 166

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addressing the adequacy of the monitoring and institutional arrangements for the upper and lower watersheds in the intervention site. The consultant will work in close collaboration with the engineering design consultants and NEWMAP State Project Management Unit’s (SPMU) safeguard team, and with other actors as directed by the SPMU. In that respect the sequencing of the technical/feasibility studies and the ESMP will be critical. The consultant will have to receive the draft technical/feasibility studies in order to take into account the technical variants of the proposed activities and also in return inform the technical design consultants of any major constraint that may arise due to the social and environmental situation on the ground. In each intervention site, the consultant will visit the full sub-watershed as delimited in the given gully stabilization design. These sub-watersheds are an average of four square kilometres in southern Nigeria. The consultant will take into account the proposed civil engineering designs, vegetative land management measures and other activities aimed at reducing or managing runoff that would be carried out within the sub- watershed. The consultant will assess natural resources and infrastructure potentially affected during project implementation and operation and select the management strategies needed to ensure that environmental risks are appropriately mitigated. Tasks of the consultant include the following: a) Describe biophysical and social environment including the existing status of the sub-watershed (Upper/Lower) and gullies; b) Identify the potential environmental and social issues/risks associated with the intervention; c)Drawing on the feasibility and engineering report and site design, appropriate baseline indicators (for example, m3/sec of runoff collected in the sub-watershed during a heavy hour-long rainfall). d) Develop a plan for mitigating environmental and social risks associated with construction and operation in the gully intervention in consultation with the relevant public and government agencies; e) Identify feasible and cost-effective measures that may reduce potentially significant adverse environmental and social impacts to acceptable levels; f) Develop a time-bound plan for mitigating environmental and social risks associated with the specific intervention in the designated sub-watershed management in consultation with the relevant public and government agencies; g) Identify feasible and cost-effective measures that may reduce potentially significant adverse environmental and social impacts to acceptable levels; h) Identify monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed and the mitigation measures described above(in a-e); i) Provide a specific description of institutional arrangements: the agencies responsible for carrying out the mitigation and monitoring measures (e.g., for operation, supervision, enforcement, monitoring of implementation, remedial action, financing, reporting, and staff training) and the contractual arrangements for assuring the performance of each implementing agency; j) Define technical assistance programs that could strengthen environmental management capability in the agencies responsible for implementation; k)Provide an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans; and l) Provide the expected capital and recurrent cost estimates and sources of funds for implementing the ESMP and inform accordingly the design consultants so that these costs are duly taken into consideration in the designs. m) Other tasks: n) The consultant shall assist the SPMU to: (i) Register the ESMP with the environmental assessment (EA) departments at Federal and State levels; and (ii) Disclose the finalized ESMP at National, State, LGA and Community levels. DESCRIPTION OF THE SITE The Ozuri gully site is located in Ozuri community in Adavi L.G.A. of Kogi State. The area is typically low laying and within them flood plain and surrounding hills which empty its water in Oro river.

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The gully is 550m in length with width varying from 20m to 25m and depth of 10m to 20m. The gully has existed in the community for about 20 years and is caused by uncontrolled/unchecked water falls from the surrounding hills resulting to poor drainage control. Many residential buildings have been destroyed and many are under serious treat. The access road in the community has been destroyed and the gully has developed fingers. Urgent action is required at the site to salvage the environment, protect and preserve lives and properties. The affected site enjoys ample rainfall. The annual mean rainfall ranges from 1000mm to 1300mm per annum. The vegetation is mostly Guinea savannah. The geology of the area is basement complex comprising of granite, gneiss and biotite. Most of the inhabitants of the area are generally Ebiras with few populations of non indigenes. Majority of the people are farmers, weavers and traders, the crop grown are mainly yam, cassava, maize and benissed.

OZURI GULLY SITE Qualifications The consultant(s) must have expertise and advanced degrees earned in relevant fields including but not limited to: civil/environmental engineering, environmental sciences, or the social sciences. Minimum experience should be eight (8) years with a minimum specific experience of four (4) years on planning related to infrastructure development or disaster response. The consultant(s) must have experience in design and preparation of an Environmental and Social Management Plan (ESMP) for infrastructure projects. The consultant(s) must have competency and documented experience in social and environmental scientific analysis and development of operational action plans.

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The consultant(s) must have a working knowledge of World Bank operational safeguards policies gained through hands-on experience in the preparation and implementation of environmental and social management plans in an urban area.

Deliverables and timing

• Inception Report: One week after contract signing. • Week 4: A draft ESMP will be submitted for comments in Four weeks from the date of signing the contract. • Week 6: The draft final ESMP Report will take into account all comments, and will be submitted to the SPMU. • Week 8: The Final ESMP acceptable to Kogi State and to the World Bank. A comprehensive database of relevant information collected in Excel format.

Project-specific background documents

• Environmental and Social Management Framework(ESMF) • Resettlement Policy Framework (RPF) • NEWMAP Project Appraisal Document (PAD) • NEWMAP Project Implementation Manual (PIM) • World Bank safeguards policies • Intervention design

Payment Schedule 20% of Contract sum on successful conclusion of inception deliverable 30 % of Contract sum on submission of Draft Report 30% of Contract sum on submission of Draft Final Report 20% of Contract sum of submission and Acceptance of Final Report

Annex 1: Outline and Substance of the ESMP report The ESMP Report shall be presented in a concise format containing all studies, processes, analyses, tests and recommendations for the proposed intervention. The report shall focus on the findings, conclusions and any recommended actions, supported by summaries of the data collected and citations for any references used. The ESMP report will include the following topics, organized in a suggested outline that can be adjusted for local needs:

Cover page Table of contents List of acronyms and their definitions Executive Summary

Chapter 1: Introduction • Description of the proposed intervention • Rationale for ESMP • Map

Chapter 2: Institutional and Legal Framework for Environmental Management • Discussion of the World Bank safeguard policies triggered by NEWMAP and the proposed activity • Summary of relevant local and federal policy, legal, regulatory, and administrative frameworks

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Chapter 3: Biophysical Environment • Description of the area of influence and environmental baseline conditions

Chapter 4: Socio-Economic Characteristics and Consultation with Stakeholders • Analysis of existing livelihoods opportunities, income, gender characteristics, age profile, health, transport access, existing community structures – at watershed, community, household, and individual levels • Analysis of existing formal and informal grievance redress mechanisms in and around the intervention area • Presentation of consultations with relevant stakeholders and affected persons • Other topics as relevant

Chapter 5: Assessment of Potential Adverse Impacts and Analysis of Alternatives • Methods and techniques used in assessing and analyzing the environmental and social impacts of the proposed project • Discussion of alternatives to the current project and reasons for their rejection, including short description of likely future scenario without intervention; • Discussion of the potentially significant adverse environmental and social impacts of the proposed project

Chapter 6: Environmental and Social Management Plan (ESMP), including: • Discussion of the proposed mitigation measures • Institutional responsibilities and accountabilities • Capacity building plan • Public consultation plan • Description of grievance redress mechanism(in alignment with the ESMF, RPF, RAP, and Project Implementation Manual) to address situations of conflicts or disagreements about some of the project activities • Monitoring and evaluation plan, including suitable indicators for the proposed project • Costs of implementing the ESMP

Chapter 7: Summary, Recommendations and Conclusion

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ANNEX TWO: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS/CIVIL WORK General 1. In addition to these general conditions, the Contractor shall comply with any specific Environmental Management Plan (EMP) in the Ozuri gully SiteEnvironmental and Social Management Plan (ESMP). The Contractor shall inform himself about such an EMP, and prepare his work strategy and plan to fully take into account relevant provisions of that EMP. If the Contractor fails to implement the approved EMP after written instruction by the Supervising Environmental Officer (EO) to fulfil his obligation within the requested time, the Owner reserves the right to arrange through the EO for execution of the missing action by a third party on account of the Contractor. 2. Notwithstanding the Contractor’s obligation under the above clause, the Contractor shall implement all measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore work sites to acceptable standards, and abide by any environmental performance requirements specified in an EMP. In general, these measures shall include but not be limited to: (a) Minimize the effect of dust on the surrounding environment resulting from earth mixing sites, asphalt mixing sites, dispersing coal ashes, vibrating equipment, temporary access infrastructure such as roads, etc. to ensure safety, health and the protection of workers and communities living in the vicinity dust producing activities. (b) Ensure that noise levels emanating from machinery, vehicles and noisy construction activities (e.g. excavation, blasting) are kept at a minimum for the safety, health and protection of workers within the vicinity of high noise levels and nearby communities. (c) Ensure that existing water flow regimes in rivers, streams and other natural or irrigation channels is maintained and/or re- established where they are disrupted due to works being carried out. (d) Prevent bitumen, oils, lubricants and waste water used or produced during the execution of works from entering into rivers, streams, irrigation channels and other natural water bodies/reservoirs, and also ensure that stagnant water in uncovered burrow pits is treated in the best way to avoid creating possible breeding grounds for mosquitoes. (e) Prevent and minimize the impacts of quarrying, earth burrowing, piling and building of temporary construction camps and access infrastructure such as roads on the biophysical environment including protected areas and arable lands; local communities and their settlements. In as much as possible restore/rehabilitate all sites to acceptable standards. (f) Upon discovery of ancient heritage, relics or anything that might or believed to be of archaeological or historical importance during the execution of works, immediately report such findings to the SE so that the appropriate authorities may be expeditiously contacted for fulfilment of the measures aimed at protecting such historical or archaeological resources. (g) Discourage construction workers from engaging in the exploitation of natural resources such as hunting, fishing, collection of forest products or any other activity that might have a negative impact on the social and economic welfare of the local communities. (h) Implement soil erosion control measures in order to avoid surface run off and prevents siltation, etc. (i) Ensure that garbage, sanitation and drinking water facilities are provided in construction workers camps. (j) Ensure that, in as much as possible, local materials are used to avoid importation of foreign material and long distance transportation. (k) Ensure public safety, and meet traffic safety requirements for the operation of work to avoid accidents. 3. The Contractor shall indicate the period within which he/she shall maintain status on site after completion of civil works to ensure that significant adverse impacts arising from such works have been appropriately addressed. 4. The Contractor shall adhere to the proposed activity implementation schedule and the monitoring plan / strategy to ensure effective feedback of monitoring information to project management so that impact management can be implemented properly, and if necessary, adapt to changing and unforeseen conditions. 5. Besides the regular inspection of the sites by the Edo State NEWMAP and other supervising agencies for adherence to the contract conditions and specifications, the Owner may appoint an Inspector to oversee the compliance with these environmental conditions and any proposed mitigation measures. State environmental authorities may carry out similar inspection duties. In all cases, as directed by the EO, the Contractor shall comply with directives from such inspectors to implement measures required to ensure the adequacy rehabilitation measures carried out on the bio-physical environment and compensation for socio-economic disruption resulting from implementation of any works.

Worksite/Campsite Waste Management 6. All vessels (drums, containers, bags, etc.) containing oil/fuel/surfacing materials and other hazardous chemicals shall be bunded in order to contain spillage. All waste containers, litter and any other waste generated during the construction shall be collected and disposed off at designated disposal sites in line with applicable government waste management regulations. 7. All drainage and effluent from storage areas, workshops and camp sites shall be captured and treated before being discharged into the drainage system in line with applicable government water pollution control regulations. 172

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX TWO: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS/CIVIL WORK 8. Used oil from maintenance shall be collected and disposed off appropriately at designated sites or be re-used or sold for re-use locally. 9. Entry of runoff to the site shall be restricted by constructing diversion channels or holding structures such as banks, drains, dams, etc. to reduce the potential of soil erosion and water pollution. 10. Construction waste shall not be left in stockpiles along the infrastructure such as road, but removed and reused or disposed of on a daily basis. 11. If disposal sites for clean spoil are necessary, they shall be located in areas, approved by the SE, of low land use value and where they will not result in material being easily washed into drainage channels. Whenever possible, spoil materials should be placed in low-lying areas and should be compacted and planted with species indigenous to the locality.

Material Excavation and Deposit 12. The Contractor shall obtain appropriate licenses/permits from relevant authorities to operate quarries or burrow areas. 13. The location of quarries and burrow areas shall be subject to approval by relevant local and national authorities, including traditional authorities if the land on which the quarry or burrow areas fall in traditional land. 14. New extraction sites: a) Shall not be located in the vicinity of settlement areas, cultural sites, wetlands or any other valued ecosystem component, or on on high or steep ground or in areas of high scenic value, and shall not be located less than 1km from such areas. b) Shall not be located adjacent to stream channels wherever possible to avoid siltation of river channels. Where they are located near water sources, burrow pits and perimeter drains shall surround quarry sites. c) Shall not be located in archaeological areas. Excavations in the vicinity of such areas shall proceed with great care and shall be done in the presence of government authorities having a mandate for their protection. d) Shall not be located in forest reserves. However, where there are no other alternatives, permission shall be obtained from the appropriate authorities and an environmental impact study shall be conducted. e) Shall be easily rehabilitated. Areas with minimal vegetation cover such as flat and bare ground, or areas covered with grass only or covered with shrubs less than 1.5m in height, are preferred. f) Shall have clearly demarcated and marked boundaries to minimize vegetation clearing. 15. Vegetation clearing shall be restricted to the area required for safe operation of construction work. Vegetation clearing shall not be done more than two months in advance of operations. 16. Stockpile areas shall be located in areas where trees can act as buffers to prevent dust pollution. Perimeter drains shall be built around stockpile areas. Sediment and other pollutant traps shall be located at drainage exits from workings. 17. The Contractor shall deposit any excess material in accordance with the principles of the general conditions, and any applicable EMP, in areas approved by local authorities and/or the SE. 18. Areas for depositing hazardous materials such as contaminated liquid and solid materials shall be approved by the SE and appropriate local and/or national authorities before the commencement of work. Use of existing, approved sites shall be preferred over the establishment of new sites.

Rehabilitation and Soil Erosion Prevention 19. To the extent practicable, the Contractor shall rehabilitate the site progressively so that the rate of rehabilitation is similar to the rate of construction. 20. Always remove and retain topsoil for subsequent rehabilitation. Soils shall not be stripped when they are wet as this can lead to soil compaction and loss of structure. 21. Topsoil shall not be stored in large heaps. Low mounds of no more than 1 to 2m high are recommended. 22. Re-vegetate stockpiles to protect the soil from erosion, discourage weeds and maintain an active population of beneficial soil microbes. 23. Locate stockpiles where they will not be disturbed by future construction activities. 24. To the extent practicable, reinstate natural drainage patterns where they have been altered or impaired. 25. Remove toxic materials and dispose of them in designated sites. Backfill excavated areas with soils or overburden that is free of foreign material that could pollute groundwater and soil. 26. Identify potentially toxic overburden and screen with suitable material to prevent mobilization of toxins. 27. Ensure reshaped land is formed so as to be inherently stable, adequately drained and suitable for the desired long-term land use, and allow natural regeneration of vegetation. 28. Minimize the long-term visual impact by creating landforms that are compatible with the adjacent landscape. 29. Minimize erosion by wind and water both during and after the process of reinstatement. 173

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX TWO: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS/CIVIL WORK 30. Compacted surfaces shall be deep ripped to relieve compaction unless subsurface conditions dictate otherwise. 31. Revegetate with plant species that will control erosion, provide vegetative diversity and, through succession, contribute to a resilient ecosystem. The choice of plant species for rehabilitation shall be done in consultation with local research institutions, forest department and the local people.

Water Resources Management 32. The Contractor shall at all costs avoid conflicting with water demands of local communities. 33. Abstraction of both surface and underground water shall only be done with the consultation of the local community and after obtaining a permit from the relevant Water Authority. 34. Abstraction of water from wetlands shall be avoided. Where necessary, authority has to be obtained from relevant authorities. 35. Temporary damming of streams and rivers shall be done in such a way avoids disrupting water supplies to communities downstream, and maintains the ecological balance of the river system. 36. No construction water containing spoils or site effluent, especially cement and oil, shall be allowed to flow into natural water drainage courses. 37. Wash water from washing out of equipment shall not be discharged into water courses or infrastructure such as road drains. 38. Site spoils and temporary stockpiles shall be located away from the drainage system, and surface run off shall be directed away from stockpiles to prevent erosion. Traffic Management 39. Location of access infrastructure such as roads/detours shall be done in consultation with the local community especially in important or sensitive environments. Access infrastructure such as roads shall not traverse wetland areas. 40. Upon the completion of civil works, all access infrastructure such as roads shall be ripped and rehabilitated. 41. Access infrastructure such as roads shall be sprinkled with water at least five times a day in settled areas, and three times in unsettled areas, to suppress dust emissions. Blasting 42. Blasting activities shall not take place less than 2km from settlement areas, cultural sites, or wetlands without the permission of the SE. 43. Blasting activities shall be done during working hours, and local communities shall be consulted on the proposed blasting times. 44. Noise levels reaching the communities from blasting activities shall not exceed 90 decibels.

Disposal of Unusable Elements 45. Unusable materials and construction elements such as electro-mechanical equipment, pipes, accessories and demolished structures will be disposed of in a manner approved by the SE. The Contractor has to agree with the SE which elements are to be surrendered to the Client’s premises, which will be recycled or reused, and which will be disposed of at approved landfill sites. 46. As far as possible, abandoned pipelines shall remain in place. Where for any reason no alternative alignment for the new pipeline is possible, the old pipes shall be safely removed and stored at a safe place to be agreed upon with the SE and the local authorities concerned. 47. AC-pipes as well as broken parts thereof have to be treated as hazardous material and disposed of as specified above. 48. Unsuitable and demolished elements shall be dismantled to a size fitting on ordinary trucks for transport.

Health and Safety 49. In advance of the construction work, the Contractor shall mount an awareness and hygiene campaign. Workers and local residents shall be sensitized on health risks particularly of AIDS. 50. Adequate infrastructure such as road signs to warn pedestrians and motorists of construction activities, diversions, etc. shall be provided at appropriate points. 51. Construction vehicles shall not exceed maximum speed limit of 40km per hour.

Prohibition of Forced or Compulsory Labour

The Contractor shall not employ forced labour, which consists of any work or service, not voluntarily performed, that is exacted from an individual under threat of force or penalty, and includes any kind of involuntary or compulsory labour, such as indentured 174

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX TWO: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS/CIVIL WORK labour, bonded labour or similar labour-contracting arrangements

Prohibition of Harmful Child Labour

The Contractor shall not employ children in a manner that is economically exploitative, or is likely to be hazardous, or to interfere with, the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social development. Where the relevant labour laws of the Country have provisions for employment of minors, the Contractor shall follow those laws applicable to the Contractor. Children below the age of 18 years shall not be employed in dangerous work

Repair of Private Property 52. Should the Contractor, deliberately or accidentally, damage private property, he shall repair the property to the owner’s satisfaction and at his own cost. For each repair, the Contractor shall obtain from the owner a certificate that the damage has been made good satisfactorily in order to indemnify the Client from subsequent claims. 53. In cases where compensation for inconveniences, damage of crops etc. are claimed by the owner, the Client has to be informed by the Contractor through the SE. This compensation is in general settled under the responsibility of the Client before signing the Contract. In unforeseeable cases, the respective administrative entities of the Client will take care of compensation.

Contractor’s Environment, Health and Safety Management Plan (EHS-MP) 54. Within 6 weeks of signing the Contract, the Contractor shall prepare an EHS-MP to ensure the adequate management of the health, safety, environmental and social aspects of the works, including implementation of the requirements of these general conditions and any specific requirements of an EMP for the works. The Contractor’s EHS-MP will serve two main purposes: • For the Contractor, for internal purposes, to ensure that all measures are in place for adequate EHS management, and as an operational manual for his staff. • For the Client, supported where necessary by a SE, to ensure that the Contractor is fully prepared for the adequate management of the EHS aspects of the project, and as a basis for monitoring of the Contractor’s EHS performance.

The Contractor shall at all times take all reasonable precautions to maintain the environment and social component of the community. In collaboration with local environment authorities, the Contractor shall ensure that mitigation measures proffered in the ESMP is complied with The Contractor shall appoint an environment officer at the Site, responsible for implementing and reporting on the environmental and social management plan. This person shall be qualified for this responsibility, and shall have the authority to issue instructions and take action as required in the ESMP throughout the execution of the Works, the Contractor shall provide whatever is required by this person to exercise this responsibility and authority. The Contractor shall send, to the Environment Officer of the Supervising Engineer, details of environment and social breaches as soon as practicable after its occurrence. The Contractor shall maintain records and make reports concerning the ESMP mitigation implementation on site during the construction phase. It is required that the contractor keeps and maintains the following records and made them available for inspection audits by SPMU Environment Officer: A register of environmental complaints defining the nature of complaint, date of complaint, corrective action taken and date it was recorded, A registered of incidents such as spillages and leakages including the date, nature of the incident and corrective action taken; Date on types and quantities of waste removed from the site, Records of formal consultation or communication activities, Site inspection checklist as the Engineer may reasonably require.

55. The Contractor’s EHS-MP shall provide at least: • a description of procedures and methods for complying with these general environmental management conditions, and any specific conditions specified in an EMP; • a description of specific mitigation measures that will be implemented in order to minimize adverse impacts; • a description of all planned monitoring activities (e.g. sediment discharges from burrow areas) and the reporting thereof; and • the internal organizational, management and reporting mechanisms put in place for such. 56. The Contractor’s EHS-MP will be reviewed and approved by the Client before start of the works. This review should demonstrate if the Contractor’s EHS-MP covers all of the identified impacts, and has defined appropriate measures to counteract

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX TWO: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS/CIVIL WORK any potential impacts. EHS Reporting 57. The Contractor shall prepare bi-weekly progress reports to the SE on compliance with these general conditions, the project EMP if any, and his own EHS-MP. An example format for a Contractor EHS report is portrayed in Annex 6. It is expected that the Contractor’s reports will include information on: • EHS management actions/measures taken, including approvals sought from local or national authorities; • Problems encountered in relation to EHS aspects (incidents, including delays, cost consequences, etc. as a result thereof); • Lack of compliance with contract requirements on the part of the Contractor; • Changes of assumptions, conditions, measures, designs and actual works in relation to EHS aspects; and • Observations, concerns raised and/or decisions taken with regard to EHS management during site meetings. 58. It is advisable that reporting of significant EHS incidents be done “as soon as practicable”. Such incident reporting shall therefore be done individually. Also, it is advisable that the Contractor keep his own records on health, safety and welfare of persons, and damage to property. It is advisable to include such records, as well as copies of incident reports, as Annexes to the bi-weekly reports. A sample format for an incident notification is shown below. Details of EHS performance will be reported to the Client through the SE’s reports to the Client.

Training of Contractor’s Personnel 59. The Contractor shall provide sufficient training to his own personnel to ensure that they are all aware of the relevant aspects of these general conditions, any project EMP, and his own EHS-MP, and are able to fulfil their expected roles and functions. Specific training should be provided to those employees that have particular responsibilities associated with the implementation of the EHS-MP. General topics should be: • EHS in general (working procedures); • emergency procedures; and • social and cultural aspects (awareness raising on social issues).

Cost of Compliance 60. It is expected that compliance with these conditions is already part of standard good workmanship and state of art as generally required under this Contract. The item “Compliance with Environmental Management Conditions” in the Bill of Quantities covers this cost. No other payments will be made to the Contractor for compliance with any request to avoid and/or mitigate an avoidable EHS impact.

3. Example Format: EHS Report

Contract: Period of reporting: EHS Management Actions/Measures: Summarize EHS management actions/measures taken during period of reporting, including planning and management activities (e.g. risk and impact assessments), EHS training, specific design and work measures taken, etc. EHS incidents: Report on any problems encountered in relation to EHS aspects, including its consequences (delays, costs) and corrective measures taken. Include relevant incident reports. EHS compliance: Report on compliance with Contract EHS conditions, including any cases of non-compliance. Changes: Report on any changes of assumptions, conditions, measures, designs and actual works in relation to EHS aspects. Concerns and observations: Report on any observations, concerns raised and/or decisions taken with regard to EHS management during site meetings and visits.

Signature (Name, Title Date): Contractor Representative

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ANNEX TWO: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS/CIVIL WORK EHS Incident Notification

Provide within 24 hrs to the Supervising Engineer

Originators Reference No:......

Date of Incident:...... Time:......

Location of incident:......

Name of Person(s) involved:......

Employing Company:......

Type of Incident:......

Description of Incident: Where, when, what, how, who, operation in progress at the time (only factual)

Immediate Action: Immediate remedial action and actions taken to prevent reoccurrence or escalation

Signature (Name, Title, Date):...... Contractor Representative

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX THREE STUDY METHODOLOGY ENVIRONMENTAL SOCIAL AND HEALTH IMPACT ASSESSMENT METHODOLOGY

IMPACT ASSESSMENT METHODOLOGY The assessment of the environmental impacts of the sites was done using the ISO 14000 as well as the modified Effect Management Process (HEMP) methods. The methods were used alongside key sources of references: these are 1. Federal Ministry of Environment EIA Procedural Guideline 2. Federal Ministry of Environment EIA Sectoral Guideline for infrastructural development (1995). 3. World Bank Environmental assessment source book (1991) 4. ISO 14000 Environmental Management Systems Standard (2004) 7. Baseline data and information 8. Checklist of environmental and social impacts

Identification of Impacts Screening was conducted to identify the impacts. The activities that could occur during the phases of development of the project were screened against various environmental aspects and components. The purpose of the screening is to evaluate if interactions between the project activity and environmental components are likely to result in an impact. The screening was done using a checklist matrix adopted from the Leopold Matrix method (Leopold et. al., 1971). The project activities screened are as follows;-

Site Acquisition and Construction Phase - Site Acquisition - Site cleaning - Excavation and trenching - Construction and civil works - Operation - Maintenance

Environmental Indicators/Sensitivities - Waste and sanitation effects - Exposure to hazardous waste - Risk of fire outbreak - Quality of habitat - Vegetation quality - Surface water quality - Groundwater quality - Household water quality - Biodiversity/Genetic resource - Air quality - Level of noise and sound

Social and Economic Indicators/Sensitivities - Sense of place/well being /socio-economically - Opportunities for contracting and procurement - Opportunities for local employment - Exposure to nuisance (dust, noise etc.) - Third party agitation (land owners, communities, NGO, CBO, etc.)

Health Indicators/Sensitivities - Fire hazard from fuel storage - Accident from civil work Prediction and Evaluation of Impacts The interactions in Table 1 with a “YES” are identified as impacts. The Impact prediction and evaluation is the formal

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

stage at which the identified impact is quantified and a test of significance is made. Step one involves evaluating the significance of ‘as predicted’ impacts to define the requirements for mitigation and other remedial actions. Step two involves evaluating the significance of the ‘residual’ impacts i.e after mitigation measures are taken into account. This test is the critical measure of whether or not a proposal is likely to cause significant impacts. It is determined by the joint consideration of its characteristics (magnitude, extent, duration etc.) and the importance (or value) that is attached to the resource losses, environmental deterioration or alternative uses which are foregone. These will assist decision making process in prioritizing mitigation measures. The quantification and evaluation of significance done based on the criteria defined in Table 1.

Table 1: Criteria Used for Evaluation of Significance of Impact CRITERIA CONSIDERATION RANKING Legal or regulatory requirement (L) There is no legal or regulatory requirement 0 There is a legal or regulatory requirement 3 Permit required 5 Impact frequency (F) Low frequency 1 Medium or intermediate frequency 3 High frequency 5 Importance (I) Low Importance 1 Medium or intermediate Importance 3 High Importance 5 Public perception (P) Low perception and interest 1 Medium or intermediate perception and interest 3 High perception and interest 5 Risk (R) Low risk 1 Medium or intermediate risk 3 High risk 5 Adverse/Beneficial (A/B) Adverse impacts or negative impacts - Beneficial impacts or positive impacts + Duration of Impacts (D) Short term impacts (<6months) ST Long term impacts (>6months) LT

Applying the test of significance, the significance of potential impact are determined as follows: High significance: when, (L+F+I+P+R) = 15 or (F+I) > 6, or P =5. Medium significance: when (L+F+I+P+R) = 8 but <15 Low significance: when (L+F+I+P+R) < 8 The definition and elaboration of these criteria are in Table 3 below.

Table 2: Importance Criterion Importance Rating Attribute – Environmental Attribute - Socio-economic Low 1 Imperceptible outcome No risk to human health, acute and/or chronic Insignificant alteration in value, function or No possibility of the endangerment of residents service of impacted resource for abutting communities Within regulatory compliance, no controls Minor reduction in social, cultural, economic required value Unlikely adverse perception among population Medium 3 Negative outcome Limited incremental risk to human health, acute Measureable reduction of disruption in value, and/or chronic function or service of impacted resource Unlikely life endangerment for residents of Potential for non-compliance with statute or abutting communities regulation Some reduction in social, cultural, economic value Possibility of adverse perception among

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

population Potential for non-compliance with statute or regulation. High 5 Highly undesirable outcome (e.g., impairment of endangered species or habitat) Elevated incremental risk to human health, Detrimental, extended animal behavioural acute and/or chronic change (breeding, spawning , moulting) Possibility of life endangerment for residents of Major reduction or disruption in value, function abutting communities or service of impacted resource Major reduction in social, cultural, economic Impact during environmentally sensitive period value Continuous non-compliance with statute or Continuous non-compliance with statute or regulation regulation A major public concern among population in study area

Table 3: Risk Criterion Risk Category Rating Attribute - Socio-economic High 5 If the likelihood of adverse Impacts occurring, which will require avoidance or major control/mitigation is almost certain to occur. Medium 3 Moderate chance of the adverse impacts occurring that can be mitigated with additional controls and modifications. Low 1 If the impact is either not likely to occur or the chances is very slim or the impact may not require mitigation.

The significance of the impacts of the project evaluated and the computed ranking are shown in Tables below.

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Table 4: Significance and Ranking of Impacts (Construction Phase) IMPACTS RANKING LEVEL OF IMPACTS A/B D L F I P R F+I L+F+I+P+R SIGNIFICANCE

AIR QUALITY AND NOISE IMPACTS Dust generation from construction equipment - ST 3 1 3 3 3 4 13 High Gaseous emissions by construction equipment - ST 3 1 3 3 3 4 13 High Public nuisance from noise generation - ST 3 1 3 5 3 4 15 High ECOLOGICAL IMPACTS Alteration of hydrological pattern leading to soil erosion - LT 0 1 3 3 1 4 8 Medium Alteration of land use pattern and changes to landscape - LT 0 1 3 5 3 4 12 High Decrease in ecological species diversity - ST 0 1 3 1 3 4 8 Medium Quality of surface water and aquatic habitat - ST 3 1 3 3 3 4 13 High Loss of vegetation and wildlife habitat - LT 3 1 3 1 3 4 9 Medium Ground water quality - ST 3 1 3 3 1 4 11 Medium Household water quality - ST 0 1 3 1 1 4 6 Low Encroachment on archaeological and cultural sites - ST 0 1 3 1 1 4 6 Low INTERACTION WITH ADJACENT DEVELOPMENTS Damage to underground public utility pipe and cables during excavation. - ST 0 1 3 1 1 4 6 Low IMPACTS FROM WASTES Littering of site with used cement bags/packaging materials - ST 3 3 1 3 3 4 13 High SOCIAL AND ECONOMIC IMPACTS Conflict among communal landowners - ST 0 1 3 3 1 4 8 Medium Conflicts from entry into archaeological sites/places of worship - ST 3 1 3 5 3 4 15 High Improved accessibility to closed areas especially rural areas + LT 0 1 3 1 1 4 6 Low

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IMPACTS RANKING LEVEL OF SIGNIFICANCE IMPACTS A/B D L F I P R F+I L+F+I+P+R Increased access to restricted areas(forest reserves) leading to poaching and - LT 5 5 3 1 1 8 15 High ecosystem fragmentation Income through the payment of compensation to affected landowners + ST 0 1 3 5 5 4 14 High Employment of local labour (semi-skill and non skilled) + ST 0 1 3 5 3 4 12 High Revenue to LGAs and othe Government Agencies + ST 3 1 3 1 3 4 11 Medium Temporary obstruction of traffic during construction - ST 3 1 3 5 3 4 15 High Exposure to communities to nuisance (dust, noise etc.) - ST 3 1 3 5 1 4 13 High HEALTH RISKS Accident risk from working – civil works - LT 0 1 3 3 1 4 8 Medium Health effects of dust and NOx, SOx, COx, gases - LT 3 1 3 3 1 4 11 Medium Injuries to on-site workers from fall or dislodgement of earth, rock or other - LT 3 1 3 3 1 4 11 Medium materials Respiratory disorder from inhalation of cement dust - LT 0 1 3 3 1 4 8 Medium Death/injury of personnel from poisonous snake bite - LT 0 1 3 1 3 4 8 Medium

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Table 5: Significance and Ranking of Impacts (Operation Phase) IMPACTS IMPACTS RATING LEVEL OF A/B D L F I P R F+I L+F+I+P+R SIGNIFICANCE AIR QUALITY AND NOISE IMPACTS Gaseous emissions vehicles on road - LT 3 3 3 3 3 6 15 High Public nuisance from noise generation - LT 3 3 3 5 3 6 17 High ECOLOGICAL IMPACTS Boost in economic and business activities/transactions within the country through + LT 0 5 5 5 5 10 20 High enhanced transportation network. Alteration of land use pattern and changes to landscape - LT 0 3 1 1 3 4 8 Medium Decrease in ecological species diversity - ST 0 3 1 1 3 4 8 Medium Soil/groundwater contamination resulting from disposal of cement liquor - LT 3 3 3 1 3 6 13 High Soil/groundwater contamination due to fuel leaks/spills at project site - LT 3 1 3 1 1 4 9 Medium Soil/groundwater contamination from disposal of toxic substances such as generator - LT 3 3 3 1 3 6 13 High batteries, used engine oil Quality of surface water and aquatic habitat - ST 3 1 3 1 1 4 9 Medium Loss of vegetation and wildlife habitat - ST 3 3 3 1 3 6 13 High contamination of household water quality from oil spills into wells - LT 0 1 1 1 1 2 4 Low IMPACTS FROM WASTES Littering and contamination of soil, water and air (when burnt) from disposal of packaging - LT 0 1 3 1 3 4 8 Medium materials SOCIAL AND ECONOMIC IMPACTS Access to farms + LT 3 5 3 5 5 8 21 High Increased conspiracy and criminal activities due to improved transportation. - LT 3 3 3 5 3 6 17 High Creation of jobs and job opportunities (distribution and marketing of farm produces + LT 0 5 3 3 3 8 14 High

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IMPACTS IMPACTS RATING LEVEL OF A/B D L F I P R F+I L+F+I+P+R SIGNIFICANCE Facilitating of crime abatement through improved transportation + LT 3 4 3 5 3 7 18 High Improved accessibility to closed areas especially rural areas + LT 0 3 1 3 1 4 8 Medium Improved ease of escape from danger, thus promoting prompt emergency response + LT 0 3 3 3 3 6 12 Medium Increased access to restricted areas(forest reserves) leading to poaching and ecosystem - LT 3 3 1 1 1 4 9 Medium fragmentation Social responsibilities intervention projects and contributions to quality of life + LT 0 3 1 5 3 4 12 High Exposure of communities to nuisance gaseous emissions and noise) - LT 3 3 3 5 3 6 17 High Revenue generation for government agencies from agriculture sales + LT 3 3 5 1 3 8 15 High HEALTH RISKS Possible fire and explosion from ignition of petroleum products at storage facilities. - ST 0 1 3 3 3 4 10 Medium Health effects of dust and NOx, SOx, COx, gases - LT 3 3 5 5 3 8 19 High Increase in accident rates due to speed at driving - LT 3 3 5 5 5 8 21 High

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LEVEL OF IMPACTS A/B D L F I P R F+I L+F+I+P+R SIGNIFICANCE AIR QUALITY AND NOISE IMPACTS Dust generation from scrapping of road - ST 3 1 3 3 3 4 13 Medium Gaseous emissions - ST 3 1 3 3 3 4 13 Medium Public nuisance from noise generation - ST 3 1 3 5 3 4 15 High ECOLOGICAL IMPACTS Alteration of hydrological pattern leading to soil erosion - LT 0 1 3 3 1 4 8 Medium Alteration of land use pattern and changes to landscape - LT 0 1 3 5 3 4 12 Medium Decrease in ecological species diversity - ST 0 1 3 1 3 4 8 Medium loss of nesting sites (mast)to birds especially within urban areas - ST 0 1 1 1 3 2 6 Low Availability of land for alternative use + LT 0 1 3 3 3 4 10 Medium Availability of concrete debris as fill materials for land reclamation + ST 3 1 3 3 3 4 13 High Loss vegetation and Wildlife - ST 0 1 3 1 1 4 6 Low Quality of surface water and aquatic habitat - ST 3 1 3 1 1 4 9 Medium Household water quality - ST 0 1 3 1 1 4 6 Low INTERACTION WITH ADJACENT DEVELOPMENTS Damage to underground public utility pipe and cables during excavation activities. - ST 0 1 1 1 3 2 6 Low IMPACTS FROM WASTES Littering of site with unwanted materials - ST 3 3 1 3 3 4 13 Medium SOCIAL AND ECONOMIC IMPACTS Conflict among communal landowners - ST 0 1 3 3 1 4 8 Medium Employment of local labour (semi-skill and non skilled) + ST 0 1 3 5 3 4 12 High Temporary obstruction of traffic during decommission - ST 3 1 3 5 3 4 15 High Exposure to neighbouring communities to nuisance (dust, noise etc.) - ST 3 1 3 5 1 4 13 High HEALTH RISKS Accident risk from working civil work - LT 0 1 3 3 1 4 8 Medium Injuries to on-site workers from fall or dislodgement of earth, rock or other materials - LT 0 1 3 1 1 4 6 Low Death/injury of personnel from poisonous snake bite

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Analytical methods used for water analysis S/N Parameter Method Equipment 1 pH pH Meter pH Tester, Hanna (H198128) Conductivity Conductivity meter, 2 EC(μS/cm) Hanna(H196301) 3 Turbidity (NTU) (mg/L) turbidimetry (Nephelometric) Secchi disc 4 Temperature (0C) Thermometry Jenco UC Meter 6100 5 Dissolved Oxygen (mg/L) Titrimetric electrochemical DO Meter, Wrinkler 6 Colour Colorimetric Lovibond Colorimeter 7 Odour Subjective (inhalation/smell) - 8 Total Dissolved Solid Gravimetric (weigh to constant) Analytical balance (FEJ-600g) 9 TSS(mg/L) Gravimetric (weigh to constant) Analytical balance (FEJ-600g) 10 Salinity (Nacl)(% or mg/L)* Electrical Conductivity Salinometer Taylor water tester, UV/VIS 11 Sodium (Na) (mg/L) Colorimetric Spectrometer (T80) Taylor water tester, UV/VIS 12 Potassium (k+) (Mg/L) Colorimetric Spectrometer (T80) 13 Calcium (Ca) (mg/L) Complexometeric UV/VIS Spectrometer (T80) N-Hexane extraction/UV 14 Oil/grease Chromatographic/Spectrophotometric Spectrometer 280 Lamotte smart 2 colorimeter, 15 Sulphate (SO42) (mg/L) Colorimetric Taylor water tester Phenoldisulphionic acid/Lamotte 16 Nitrate(NO3-) (mg/L) Colorimetric smart 2 colorimeter Digestion, Lamotte smart 2 17 Lead (Pb) (mg/L) Absorption Spectroscopy colorimeter 18 Iron (Fe) (mg/L) Colorimetric Lamotte smart 2 colorimeter 19 Mercury (Hg) (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 20 Chromium (Cr) (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 21 THC Atomic Absorption Spectrophotometry Digestion, Unicam 939 22 Copper (Cu) (mg/l) Atomic Absorption Spectrophotometry Digestion, Unicam 939 23 Manganese(Mn)(mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 24 BOD5@ 20 – 25oc Iodometric Hach BOD Track 25 COD (mg/L) Redox Hach COD Tester 26 Magnesium(mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 Lamotte smart 2 colorimeter, 27 Phosphate (mg/L) Colorimetric Taylor water tester 28 Vanadium (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 29 Nickel (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 30 Zinc (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 31 Arsenic (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 32 Cobalt (mg/L) Atomic Absorption Spectrophotometry Digestion, Unicam 939 Total coliform Count Standard plate counttechnique using spread Petri dish, Nutrient, autoclave, 33 (cfu/ml) plate method microscope Heterotrophic Bacteria Standard plate count technique using Petri dish, Nutrient, autoclave, 34 count (cfu/ml) spread plate method microscope Total Fungal Count Standard plate count technique using Petri dish, Potato Dextrose Agar 35 (spore/ml) spread plate method (PDA), autoclave, microscope Standard plate count technique using Petri dish, Sabour and Dextrose spread plate method Agar (SDA), autoclave, 36 Total yeast count (cfu/ml) microscope Source: Labstaff Laboratory, 2017 *Salinity: unit of measurement is % or mg/L. the equipment was set to read in % which can be converted. Table 6 pg 29 of National Guidelines and Standards for water quality in Nigeria (undated) by Federal Ministry of Environment

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

Analytical methods used for soil analysis S/N Parameter Method Equipment 1. Moisture Content (%) Gravimetric/drying to constant weight Analytical balance (FEJ-600g) 2. Sand (%) Sieve Graded standard sieves 3. Silt (%) Sieve Graded standard sieves 4 Clay (%) Sieve Gradedstandard sieves 5 pH pH Meter pH Tester, Hanna (H198128) 6 E.C (µScm-1) Conductivity Conductivity meter, Hanna(H196301) 7 Ca Colorimetric Lamotte smart 2 colorimeter 8 Mg Colorimetric Lamotte smart 2 colorimeter 9 K Colorimetric Lamotte smart 2 colorimeter 10 SO42- Colorimetric Lamotte smart 2 colorimeter 11 PO42- Colorimetric Lamotte smart 2 colorimeter 12 NO3- Colorimetric Lamotte smart 2 colorimeter Diachromate wetoxidation UV/VIS Spectrometer, T80 13 TOC (420mmwavelenght) 14 Fe Atomic Absorption Spectrophotometry Digestion, Unicam 939 15 Cu Atomic Absorption Spectrophotometry Digestion, Unicam 939 16 Pb Atomic Absorption Spectrophotometry Digestion, Unicam 939 17 As Atomic Absorption Spectrophotometry Digestion, Unicam 939 18 Mn Atomic Absorption Spectrophotometry Digestion, Unicam 939 19 Cr (total) Atomic Absorption Spectrophotometry Digestion, Unicam 939 20 Ni Atomic Absorption Spectrophotometry Digestion, Unicam 939 21 V Atomic Absorption Spectrophotometry Digestion, Unicam 939 22 Zn Atomic Absorption Spectrophotometry Digestion, Unicam 939 23 Hg Atomic Absorption Spectrophotometry Digestion, Unicam 939 Standard plate count technique using 24 (THB)X104 Petri dish, Nutrient, autoclave, microscope spread plate method Standard plate count technique using 25 (HUB)X103 Petri dish, Nutrient, autoclave, microscope spread plate method (THF)X103 Standard plate count technique using Petri dish, Potato Dextrose Agar (PDA), 26 spread plate method autoclave, microscope (HUF)X102 Standard plate count technique using Petri dish, Potato Dextrose Agar (PDA), 27 spread plate method autoclave, microscope Source: Labstaff Laboratory, March, 2017

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX FOUR: HOUSEHOLD QUESTIONNAIRE SOCIO – ECONOMIC QUESTIONNAIRE ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN FOR OZURI GULLY EROSION SITE, ADAVI LGA, KOGI STATE Your kind assistance in answering the following questions as correctly as possible is hereby solicited. You are expected to tick {√} against the option that best represent your situation. Your response will be accorded necessary confidentiality. Name of community/settlement/neighbourhood:…………………………...... Local Government Area:………………………………………………………………………………………………….. State:……………………………………………………………………………… Date:…………………………

RESPONDENT PERSONAL INFORMATION 1. Sex: Male [ ] Female [ ] 2. Marital Status: a. Single [ ] b. Married [ ] c. Divorced [ ] d. Widow/widower [ ] 3. Age bracket (in years): a. 1 – 18 [ ] b. 19 – 36 [ ] c. 37 – 54 [ ] d. 55 – 73 [ ] e. 74 & above [ ] 4. Level of education: a. None [ ] b. Primary [ ] c. Secondary [ ] d. Tertiary [ ] 5. How would you describe yourself in this community? a. Indigene [ ] b. Settler [ ] c. Visitor [ ] d. Tenant [ ] 6. How long have you lived in this community a. less than 5years [ ] b. 6-10years [ ] c. 11-15years [ ] d. 16-20years [ ] e. above 20yrs [ ] 7. Position hold in this community: a. Traditional ruler [ ] b. Religious leader [ ] c. Family head [ ] d. Youth leader [ ]

DEMOGRAPHIC CHARACTERISTICS 8. Family size: a. 1-3 [ ] b. 4-6 [ ] c. 7-10 [ ] d. 11-15 [ ] e. above 15 [ ] 9. Number in the family:……………………………………………. 10. How many births in the last 12months? a. 0 [ ] b. 1 [ ] c. 2 [ ] d. 3 [ ] d. 4 [ ] 11. How many deaths in the last 12months? a. 0 [ ] b. 1 [ ] c. 2 [ ] d. 3 [ ] d. 4 [ ] 12. How many vulnerable persons in the family? a. 0 [ ] b. 1 [ ] c. 2 [ ] d. 3 [ ] d. 4 [ ] 13. Age distribution in the family: a. 1-5 [ ] b. 6-10 [ ] c. 11-15 [ ] d. 16-20 [ ] e. 21-25 [ ] f. 26-30 [ ] g. 31-35 [ ] h. 36-40 [ ] i. 41-45 [ ] j. 46 and above [ ]

ECONOMIC ENVIRONMENT 14. What is your occupation? a. Trading [ ] b. Farming [ ] c. Civil servant [ ] d. Banker [ ] e. Hunting [ ] g. Teacher/lecturer [ ] h. Industrial worker [ ] i. others (specify):……………………………. 15. How long have you been in the occupation? a. Less than 5yrs [ ] b. 6-10yrs [ ] c. 11-20yrs [ ] d. 21-30yrs [ ] e. above 30yrs [ ] 16. If farming, what crops do you grow? a. Maize [ ] b. Guinea corn [ ] c. Millet [ ] d. Yam [ ] e. Cassava [ ] f. Soya beans [ ] g. Others (Specify):………………………………………………………….. 17. Where do you sell your farm produces? a. Community Market [ ] b. Markets within the state [ ] c. Markets outside the state [ ] d. International Market [ ] 18. Do you have market/s in this community? A. Yes [ ] B. No [ ] If yes, state its/their name/s……………………………………………………………………………………… 19. What is your means of transportation? A. Bicycle [ ] B. Car [ ] C. Motorcycle [ ] D. Foot [ ] E. Animal [ ] F. All of the above [ ] 20. How much do you realise annually from the job you do? a. Less than 20,000 [ ] b. 21,000-40,000 [ ] c. 41,000-60,000 [ ] d. 61,000-80,000 [ ]

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

e. 81,000-100,000 [ ] f. 101,000 and above [ ] 21. Please state in order of importance your monthly household expenditure item: a. Food items [ ] b. Education [ ] c. Transportation [ ] d. Health care [ ] e. Shelter/accommodation [ ] f. Household maintenance [ ] g. Others (Specify):…………… 22. Do you own any land in the community? If yes, what is the size in hectares? a. 0-1 [ ] b. 2-3 [ ] c. 4-5 [ ] d. 6-7 [ ] e. Above 7 [ ] 23 What is your monthly expenditure? a. Less than 20,000 [ ] b. 21,000-40,000 [ ] c. 41,000-60,000 [ ] d. 61,000-80,000 [ ] e. 81,000-100,000 [ ] f. 101,000 and above [ ] 23. What is the nature of land ownership? a. Personal [ ] b. Family [ ] c. Communal [ ] e. Leasehold [ ] f. Others (Specify):……………………………………………………………………..

SOCIO CULTURAL ENVIRONMENT 24. What is your religion? a. Christianity [ ] b. Islam [ ] c. Traditional [ ] d. Others (Specify)…………………… 25. Which of the following do you have in the community? a. Shrines [ ] b. Sacred ground/forest [ ] c. Historical/archaeological site [ ] e. Religious houses [ ] 26. Which of these social problems do you have in your community? a. Youth delinquency/unrest [ ] b. Land dispute [ ] c. Chieftancy problem [ ] d. Communal crisis [ ] e. Herdsmen attack [ ] f. Religious crisis [ ] g. Others (Specify):…………………………………………………… 27. Nature of community security: a. secured b. Insecure c. No idea If secured, what is the nearest security post:…………………………………………………………………… AVAILABILITY OF INFRASTRUCTURE 28. What is your source of water supply? a. Streams [ ] b. Pipe-borne water [ ] c. Hand dug well [ ] d. Borehole [ ] e. Others (Specify):…………………………………………………… 29. What is your source of energy? a. Wood [ ] b. Kerosene [ ] c. Gas [ ] d. Petrol [ ] e. Coal [ ] f. Electricity [ ] 30. What are your fears about this proposed project? a. Loss of land [ ] b. Damage of agricultural land [ ] c. Cultural interferences [ ] d. Noise nuisance from working equipment [ ] e. Pollution of fishing ground [ ] 31. What benefits do you expect in the course of the execution of this project? Please rank them in order of importance by placing 1 against the most important, 2 against next important and so on a. Employment of indigenes [ ] b. Ease of trade [ ] c. Ease of transportation [ ] d. Primary school [ ] e. Water project [ ] f. Health centers [ ] g. Others:……………. 32. What type of road networks exist in this community? a. Foot path [ ] b. Un-tarred road [ ] c. Feeder [ ] d. Arterial (State) [ ] e. National [ ] 33. What communication mode exists in this community? a. Tele mast [ ] b. Radio [ ] c. Television [ ] d. Town crier [ ]

EDUCATION 34. How many primary schools do you have in this community? a. 1-2 [ ] b. 3-5 [ ] c. 6-8 [ ] d. 9 and above [ ] 35. How many secondary schools do you have in this community? a. Less than 2 [ ] b. 3-5 [ ] c. 6-8 [ ] d. 9 and above [ ] 36. Name the tertiary institutions nearest to this community? ………………………………………………………………………………………………………………… 37. How many members of your family are out of school? a. None [ ] b. 1 [ ] b. 2 [ ] c. 3 [ ] d. 4 [ ] 38. You are literate in how many languages a. English [ ] b. Hausa [ ] c. Arabic [ ] d. Nupe [ ] e. Gbagi [ ] SECURITY 39. What are the prevalent security issues in the community? a. Communal crisis [ ] b. Armed robbery [ ] c. Herdsmen attack [ ] d. Religious crisis [ ]

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40. What means exist to combat security challenges? a. Army [ ] b. Police [ ] c. Civil Defense [ ] d. Vigilante [ ]

POVERTY ALLEVIATION 41. What poverty alleviation mechanism is available in this community? a. Npower [ ] b. Cooperative [ ] c. Youwin [ ] d. Soft loan from financial institution/s [ ]

HEALTH STUDY 42. Do you have hospitals in this community? A. Yes [ ] B. No [ ] 43. How many private hospitals? ……………………………………………….. 44. How many government hospitals? …………………………………………. 45. How often do you visit the hospital for treatment? a. Weekly [ ] b. Once in a month [ ] c. Once in a year [ ] d. Once in a year [ ] e. Always [ ] 46. What are the major causes of death in the last three in this community? a. Ill health [ ] b. Old age [ ] c. Child birth [ ] d. Accident [ ] e. Food poison [ ] f. Communal crisis [ ] g. Others (specify):……………………………………………………... 47. Are you satisfied with the medical services received? a. Yes [ ] b. No [ ] 48. What are the common illnesses in this community? a. Malaria [ ] b. Yellow fever [ ] c. Dysentery/diarrhea [ ] d. Measles [ ] e. Cough [ ] f. Skin disease [ ] g. Others(Specify):…………………………………… 49. What are the common environmental problems in this community? a. Flooding [ ] b. Bush fire [ ] c. Erosion [ ] d. Landslide [ ] e. Others:………………………

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX FIVE WASTE MANAGEMENT PLAN S/N Potential Source Waste Type Waste Streams Management A PRECONSTRUCTION 1 Movement of vehicles on Emission COx, SOx, VOCs, NOx, SPM, Use water suppression to prevent dust emission unpaved surface and CH4, Dust Maintain vehicles and machineries to reduce emission engine exhaust Maintain low speed to reduce dust and gaseous emission Allow aerial dispersal over a large area. 2 Site Clearing and Non- • Vegetal Waste Vegetal waste shall be supplied to farmers for use as Installation of temporary Hazardous compost. workers camp and offices Woody vegetal shall be supplied to host communities and workshops for domestic uses including as fuel wood for cooking.

• Industrial Waste: Metal Segregated and stored on site to be collected at least scraps, packaging waste once a week for reuse or recycle through licensed third party facilities. 3 Project yard Domestic and • Food remnant, kitchen To be transferred to locals for use as compost and Sanitary wastes. Food packaging etc animal feed. Plastic and other packaging to be recycled through licensed recycling third parties. • Domestic Sewage Temporary stored and transferred to licensed carrier for disposal B CONSTRUCTION 1 Movement of vehicles on Emission COx, SOx, VOCs, NOx, SPM, See A1 unpaved surface and CH4, Dust engine exhaust 2 Civil works Non- • Spoils Reuse spoils as fill materials as much as possible Hazardous • Waste Packaging and Segregated and kept securely in closed containers on /Industrial Dunnage such as scrap site. To be transferred to approved recycling third wood, scrap metal, steel, parties for reuse/recycling. glass, plastic, paper and Non-recyclables to be removed by approved waste cardboard, empty metal contractor for onward disposal at approved sites. containers, excess concrete, broken equipment, or Workers’ camp/offices components To be transferred to locals for use as compost and • Domestic-type waste: animal feed. wastepaper and food Plastic and other packaging to be recycled through scraps, metal cans licensed recycling third parties. 3 Civil Works Hazardous Solid Wastes: used batteries, Store on site in closed containers with secondary Waste chemical containers, concrete containment and transferred to a registered waste etc contractor with off-site permitted hazardous waste Liquid Waste: spent treatment, storage, or disposal facilities lubricating oils, hydraulic fluids, brake fluids, battery electrolyte, and dielectric fluids, chemical cleaning agents, paints, primers, thinners, and corrosion control coatings; sealants and adhesives etc Civil works Waste Water Waste water from equipment Discharged to the ground as only very small quantity is washing and concrete envisaged at this stage. production

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

4 Workers’ camp Domestic and • Food remnant, kitchen See A3 Sanitary wastes. Food packaging etc • Domestic Sewage C OPERATION 1 Movement of vehicles Emission COx, SOx, NOx, CO, Dust See A1

2 Maintenance of bridge Non- • Packaging waste, scrap Segregated and kept securely in closed containers on and other infrastructures Hazardous metals, plastic, paper and site. To be transferred to approved recycling third /Industrial cardboard, empty metal parties for reuse/recycling. containers, broken Non-recyclables to be removed by approved waste equipment, or components contractor for onward disposal at approved sites. Workers’ camp/offices • Domestic-type waste: To be transferred to locals for use as compost and wastepaper and food animal feed. scraps, metal cans Plastic and other packaging to be recycled through licensed recycling third parties. 3 Maintenance of bridge Hazardous Same as B3 but smaller See B3 and other infrastructures quantity may be expected.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

ANNEX SIX THE WORLD BANK’S APPROACH TO GRIEVANCE REDRESS IN PROJECTS Background and Purpose The World Bank is committed to enhancing opportunities for grievance redress, collaborative problem solving, and alternative dispute resolution on the projects it supports. Effectively addressing grievances from people impacted by World Bank projects is a core component of managing operational risk. Grievance redress mechanisms (GRMs) can be an effective tool for early identification, assessment, and resolution of complaints on projects. Understanding when and how a GRM may improve project outcomes can help both project teams and beneficiaries improve results. The business case for such an approach is strong—many major infrastructure projects around the world are stalled due to disputes over land, water, or labor issues. The costs of ignoring such disputes—or responding too late—are high. A core characteristic of an effective grievance mechanism is the ability to identify minor community incidents before they escalate into unmanageable disputes. This is especially important for development projects, where support from impacted communities is critical to success. The World Bank Executive Board and senior management are supporting more effective approaches to problem solving to help strengthen the Bank’s performance and development outcomes. OPCS has taken the lead in coordinating this strengthened corporate approach1 focusing on a preventive approach to identify, track and resolve grievances early; and offering lower-cost, rapid citizen redress at the project and country level through mediation, facilitation or other problem solving processes where it is most needed. The Bank is not alone in this: across public and private sectors, in developed and emerging economies, organizations have increasingly institutionalized complaints handling and dispute resolution processes to better manage feedback and operational risks. This note presents the World Bank’s recommended approach to strengthening grievance capacity in Bank- supported projects. Approach to Grievance Redress The approach proposes three interlinked steps: (i) a risk-based assessment of potential grievances, disputes or conflicts that may arise during project preparation and implementation; (ii) identification of the client’s existing capacity for grievance redress; and (iii) an action plan that identifies priority areas for strengthening grievance capacity, or if necessary, establishing new mechanisms at the project level. Where applicable, dedicated resources should be allocated for realisation of the action plan. Step 1: Assessment of Risks and Potential Grievances and Disputes The project team works with the client to conduct a rapid review of contentious issues, stakeholders, and institutional capacity, strongly relying on existing information from the client, civil society and other non-state institutions. The ESIA, ORAF, and/or RAP or IPP should provide the basis for much of this work. The work will start by understanding the issues that are—or are likely to be—at the heart of disputes related to the project, such as clarity over land rights, benefit distribution, existing ethnic tension, or labor issues. The review will map who the key stakeholders to these issues are and what the nature of the debate is (informed, polarised, etc). Attention will be paid to the local dispute resolution culture and, particularly, to the capacity and track- record of stakeholders to settle disputes through mediation or constructive negotiation. Step 2: Capacity Assessment The review will also cover the availability, credibility and capabilities of local and national institutions to address the issues related to the project or program. For each of the institutions that are expected to deal with these issues, there will be a credibility assessment, based on the following criteria:

• Legitimacy: is its governance structure widely perceived as sufficiently independent from the parties to a particular grievance? • Accessibility: does it provide sufficient assistance to those who face barriers such as language, literacy, awareness, cost, or fear of reprisal?

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

• Predictability: does it offer a clear procedure with time frames for each stage and clarity on the types of results it can (and cannot) deliver? • Fairness: are its procedures widely perceived as fair, especially in terms of access to information and opportunities for meaningful participation in the final decision? • Rights compatibility: are its outcomes consistent with applicable national and international standards? Does it restrict access to other redress mechanisms? • Transparency: are its procedures and outcomes transparent enough to meet the public interest concerns at stake? • Capability: does it have the necessary technical, human and financial resources to deal with the issues at stake?

Categorising both risks of disputes and institutional capacity to address those disputes is central to this approach. Where capacity of national institutions are low and the stakes are high, the risk of grievances going unaddressed will be significant. The risk analysis table is a helpful guide:

Issues and stakeholder reviews will be mostly desk-based and will initially and primarily rely on the information contained in the ESIA and other project documents. Review of institutional capacity will likely require both desk-work and in-country interviews with key stakeholders. A two-page “GRM Evaluation” that can be used to guide a discussion on the effectiveness of existing grievance capacity in a country is also available. The focus should remain on whether existing systems are credible to the users, i.e. beneficiaries and local citizens. Step 3:Action Plan Action plans will necessarily be project specific, but should focus on tangible steps that can be taken during preparation and implementation to strengthen grievance capacity more widely. A key emphasis is to explore opportunities and synergies for supporting improved sectoral or national capacity for addressing disputes that might arise from project-specific impacts.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

In practical terms, there are a small number of components for an effective institutional approach to grievance management: Additional detail on each component is provided below. Access Point / Complaint Uptake Have Access Points as Close to the Users as Possible

An easily accessible and well publicised focal point or user-facing ‘help desk’ is the first step. This can be within the relevant agency or government department, but must be in a location that is seen as credible and accessible. Uptake channels should include some or all of the following: phone hotline, email, mail, SMS, webpage, or face-to-face. The uptake channels should be publicized and advertised via local media, the implementing agency and—where relevant— contractors. Staff members who receive complaints verbally should put them in writing for them to be considered. Recognising that many complaints may be resolved ‘on the spot’ and informally by project staff, there are opportunities to encourage these informal resolutions to be logged here to (i) encourage responsiveness; and (ii) ensure that repeated or low-level grievances are being noted in the system. The GRM should have the ability to handle anonymous complaints. Typically, the user should be provided with a receipt and ‘roadmap’ telling him/her how the complaint process works and when to expect further information. Grievance Log It is important that all complaints are logged in writing and maintained in a database—either a simple Excel file or a publicly accessible web site (with appropriate steps taken to preserve anonymity). Complaints received should be assigned a number that will help the complainant track progress via the online system or database. Complainants should be handed a receipt and a flyer that describes the GRM procedures and timeline (staff should be trained to read this orally for illiterate complainants). Where possible, the grievance log should capture complaints being made via informal or traditional systems, such as village councils or elders. This will often require training local people and putting in place a formal link between the traditional systems and a Bank-designed GRM (this could take the form of a verbal agreement or a written MoU). DRP and SDV staff can provide examples of GRM databases and off-the-shelf technology to build a database

At a minimum, the database should track and report publicly on the following metrics: • # complaints received • # complaints resolved • # complaints that have gone to mediation GRM data should be included in the Bank’s own supervision systems, including via ISRs and ICRs. The project team should discuss with the client the need to fully share the data with the Bank to allow the Bank to provide support where needed and help the client respond quickly and effectively.

The database should also show the issues raised and location of complaints circle around.

Assessment, Acknowledgment, and Response Eligibility should be a procedural step to ensure that the issue being raised is relevant to the project. It is often better to ensure a relatively low barrier to entry with quick turnaround rather than to prevent users having their issues considered.

Complaints that cannot be resolved on the spot should be directed to the grievance focal point who will have a set number of days to assess the issue and provide a written response to the complainant, acknowledging receipt and detailing the next steps it will take (one week or less is recommended). The determination of whether the issue can be resolved on the spot or needs to be referred elsewhere requires some judgment on the part of the client—and, in some instances, the TTL. Grievances should be categorised according to the type of issue raised and the effect on the environment/claimant if the impacts raised in the complaint were to occur. Based on this categorisation, the complaint can be prioritised based on risk and assigned for appropriate follow up. For example, claims relating to land may be referred to an existing land claims court if this has been identified as a credible institution for resolving these disputes. The process of assigning cases is generally more successful when it is done with the agreement of the user. On the spot resolution is encouraged but make sure all incidents are recorded in a central database.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

The assessment of next steps should consider: • Who is responsible for responding to this grievance? Is it the client, the World Bank, or someone else? It is anticipated that the majority of issues raised will be informational in nature or feedback that requires small course corrections; these should generally be handled by the client. Issues having to do with governance issues— at the client or by World Bank staff—should be addressed at a higher level, either an appeals or supervisory body within the client or senior management within the Bank. The ‘tip of the iceberg’ complaints will likely be those reflecting outright opposition to a project or open conflict between stakeholders. These issues are unlikely to be resolved via a GRM and should be handled at the highest appropriate level within either the client country or the Bank. Higher risk issues will require greater independence to handle, whereas lower-level feedback can and should be handled “in-house,” i.e. by the client. • What is the risk-level of this complaint? Is it low risk, medium risk, or high risk? Ideally, the person or office handling the complaints will have been involved with (or aware of) the risk assessment process that may have been completed prior to putting in place the GRM (i.e. Steps 1&2 above). Some training will be required to ensure staff implementing the GRM are aware of what would constitute a higher-risk issue for the project and which entity should handle such a complaint. • Is the complaint already being addressed elsewhere? If an issue is already being handled, for example by a local court or mediation body, or within the World Bank (for example by INT or the Inspection Panel), then the issue should most likely be excluded from the grievance redress process in order to avoid duplication and confusion on the part of the complainant. The client should have the primary role in resolving complaints. If possible, this responsibility should be written into appropriate project management manuals and procedures.

Once the above issues have been considered, the complainant should be offered option(s) for resolution of their issue. The option offered is likely to fall into one of the following three categories: • The complaint falls under the mandate of (contractor/ client) and resolution can be offered immediately according to the request made by the complainant. The response will describe how and when resolution will be provided by (contractor/client) and the name and contact information of the staff member responsible for it. • The complaint falls under the mandate of (contractor/ client) but various options for resolution can be considered and/or extraordinary resources are required. The response will invite the complainant to a meeting to discuss these options.

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State

• The complaint does not fall or partially falls under the mandate of (contractor/client). The response will indicate that the complaint has been referred to the appropriate body (eg. Complaints related to resettlement will be forwarded to the Resettlement Committee), which will continue communications with the complainant. Appeals Where an agreement has not been reached, the complainant should be offered an appeals process. One approach is to refer appeals to the national courts or other suitable process. In some countries, the courts may not be seen as effective, in which case the Bank and client should discuss offices/individuals within the implementing agency that have a degree of independence from the project and are viewed as credible spaces to resolve higher-level disputes. In some instances, it is helpful to convene a senior and independent panel of individuals to seek appropriate resolution of the case, with representation from both government and civil society. This panel may also play the role of providing strategic oversight and assurance of the mechanism through reviewing monitoring and tracking data.

At this stage it may be helpful to offer third party fact-finding, facilitation or mediation. OPCS3 maintains a roster of independent professionals located in the regions who are experienced with World Bank projects and can provide independent support on a contract basis. Costs will be paid by the project. • If the complainant accepts the options, and an agreement is reached, implementation will be monitored by the mediation service and a minute will be signed signaling the complaint has been resolved. • If the complainant does not accept these options or if he/she does but an agreement is not reached, the case will be closed. The complainant may seek redress through courts or other mechanisms available at the country level.

Resolve and Follow-Up Where there is an agreement between the complainant and the client or contractor on how the complaint will be resolved, a minute will be drafted and signed by both parties. After due implementation of it, a new minute will be signed stating that the complaint has been resolved.

All supporting documents of meetings needed to achieve resolution should be part of the file related to the complaint. This should include meetings that have been escalated to an appeals level or are handled by a third party.

The client should provide regular (monthly or quarterly) reports to the public that track the # complaints received, resolved, not resolved, and referred to a third party. The World Bank project team should receive either the raw 197

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State grievance data or the monthly reports, in order to support the client in early identification of developing risks. The GRM data should feed into ISRs and ICRs to demonstrate responsiveness and early resolution of issues (and help teams identify outstanding complaints in need of attention).

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ANNEX SEVEN NEWMAP: LABOR INFLUX AND GENDER BASED VIOLENCE (GBV) Labor Influx The project may face an influx of non-local labor and working conditions issues as skilled laborers might not be available in some of the project sites. The project will take concrete measures to mitigate potential labor influx-related risks such as workers’ sexual relations with minors and resulting pregnancies, presence of sex workers in the community, the spread of HIV/AID, sexual harassment of female employees, child labor and abuse, increased dropout rates from school, inadequate resettlement practices, and fear of retaliation, failure to ensure community participation, poor labor practice, and lack of road safety. These risks require careful consideration to improve social and environmental sustainability, resilience and social cohesion. Therefore, the project will include mitigation measures such as: (a) assessing living conditions of workers’ camps and ensuring appropriate living conditions; (b) establishing and enforcing a mandatory Code of Conduct for the company, managers and workers, and an Action Plan for implementation; (c) ensuring appropriate location for these camps; (d) taking countermeasures - indicated in the Social Management Plan - to reduce the impact of the labor influx on the public services; and, (e) devising and implementing a strategy for maximizing employment opportunities for local population, including women. The following guidelines lays out the principles that are key to properly assessing and managing the risks of adverse impacts on project area communities that may result from temporary NEWMAP induced labor influx. • The SPMU will have to hire, to the maximum extent, skilled and unskilled workers from affected communities in the project area. The SPMU will adopt or implement all possible measures to avoid if not minimize labor influx into the project area. • The SPMU will assess and manage labor influx risk based on appropriate instruments such as those based on risks identified in the ESIA and the Bank’s sector-specific experience in the country. • Depending on the risk factors and their level, appropriate mitigation instruments need to be developed including the ESMP, Site-specific Labor Influx Management Plan and/or a Workers’ Camp Management Plan1, • Risk factors to the SPMU that should be considered, include, o weak institutional capacity of the implementing agency; o predominant presence of contractors without strong worker management and health and safety policies; o anticipated high volumes of labor influx; o pre-existing social conflicts or tensions; o weak local law enforcement; o prevalence of gender-based violence and social norms towards it in the community (acceptance of gender based violence); o prevalence of transactional sex; o local prevalence of child and forced labor; o existing conflict situation between communities; o absorption capacity of workers to the community (See http://pubdocs.worldbank.org/en/497851495202591233/Managing-Risk-of-Adverse-impact-from- project-labor-influx.pdf) • The SPMU will be required to incorporate social and environmental mitigation measures into the civil works contract and responsibilities for managing these adverse impacts. This will be a binding contractual obligation on the SPMU, with appropriate mechanisms for addressing non-compliance The Supervision Consultant shall be responsible for monitoring the contractor performance and adherence to the labor influx guideline and that of its Sexual Exploitation and Abuse (SEA) obligations, with a protocol in place for immediate, timely, mandatory and confidential reporting in case of incidents to project community. This allows the SPMU to enforce the implementation of such mitigation measures, which are required to ensure the consultant’s own compliance with Bank policy requirements. While the Bank reviews and clears project-level safeguard

1 A Labor Influx Management Plan addresses specific activities that will be undertaken to minimize the impact on the local community, including elements such as worker codes of conduct, training programs on HIV/AIDS, etc. A Workers’ Camp Management Plan addresses specific aspects of the establishment and operation of workers’ camps.

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instruments such as the ESIA/ESMP, it is the SPMU’s responsibility to: (i) ensure the safeguard instruments are reflected in the contractor’s ESMP (CESMP), and (ii) ensure the project is implemented in accordance with the CESMP, safeguard instruments and other relevant contractual provisions. Gender Based Violence Nigeria has ratified or acceded to the core international human rights treaties and is a party to the major regional human rights instrument which obliged States to respect, protect and fulfill human rights of all persons within the territory and subject to the jurisdiction of the State, without discrimination. Rape may violate several human rights obligations enshrined in the instruments ratified by Nigeria and is also a form of gender-based violence and a brutal manifestation of violence against women. As a State party to the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) and the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa (the “Maputo Protocol”), Nigeria has made legally binding commitments to exercise due diligence to combat gender-based violence and discrimination. Accordingly, Nigeria has an obligation to take all appropriate measures to prevent rape, ensure that there are adequate sanctions for rape in law and in practice, and ensure access to reparation for the victims.2 Furthermore, several human rights instruments3 require Nigeria to take special measures to protect the rights of individuals who are vulnerable to sexual violence, namely women, children, and persons with disabilities. The United Nations Special Rapporteur on violence against women has provided guidance on States’ due diligence obligations in combating sexual violence, noting that it must be implemented at both individual and systemic levels. Individual due diligence focuses on the needs of individual survivors and “places an obligation on the State to assist victims in rebuilding their lives and moving forward,” for instance through the provision of psychosocial services. Individual due diligence “requires States to punish not just the perpetrators, but also those who fail in their duty to respond to the violation.”4 As for systemic due diligence, it includes ensuring “a holistic and sustained model of prevention, protection, punishment and reparations for acts of violence against women. International Treaties • The International Covenant on Civil and Political Rights (ICCPR) (2004) • The International Covenant on Economic, Social and Cultural Rights (ICESCR) (2004) • The Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT) (1993) • The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) (1984) • The Convention on the Rights of the Child (CRC) (1990), and the Convention on the Rights of Persons with Disabilities (CRPD) (2012) • International Convention on the Elimination of All Forms of Racial Discrimination (1976) Regional Treaties • The African Charter on Human and Peoples’ Rights (ACHPR) (1982) • The African Charter on the Rights and Welfare of the Child (ACRWC) (2007) • The Protocol to the ACHPR on the Rights of Women in Africa (the “Maputo Protocol”) (2007) National polices • The National Action Plan for the Implementation of United Nations Security Council Resolution 1325 (2009); • The National Gender Policy (2010) Nigeria is among the 10 percent of countries worldwide that exhibit the highest levels of gender discrimination according to the OECD’s Social Institutions and Gender Index (see the figure below), with an assessment of “high” or “very high” in all of the evaluated categories (discriminatory family code, restricted physical integrity, son bias, restricted resources and assets, restricted civil liberties). It also falls into the group of countries with highest gender inequality in human development outcomes (UNDP 2016). Gender-Based Violence (GBV) remains pervasive and underreported in the country, largely constraining women’s autonomy and life chances.The 2013 Demographic Health Survey (DHS) indicates that nationally 38 percent of women between the ages of 15-49 have experienced some form of physical or sexual violence from the age of 15, and 11 percent experienced physical violence within the 12 months prior to the survey. 45 percent of women who experienced

2 CEDAW art. 2(c), for example, provides that States must “establish legal protection of the rights of women on an equal basis with men and ensure through competent national tribunals and other public institutions the effective protection of women against any act of discrimination.” The Maputo Protocol, art. 4, paras. 2(a) and (e), explicitly provides that laws prohibiting violence against women must be enforced and perpetrators held accountable; See also CEDAW general recommendation N.19 (n). 3 CRC, CEDAW, CRPD, ACRWC, and the Maputo Protocol. 4 Report of the Special Rapporteur on violence against women, its causes and consequences, para. 70, UN Doc. A/HRC/23/49 (14 May 2013). 200

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violence never sought help or never told anyone about the violence. Besides interpersonal and sexual violence, child marriage and Female Genital Mutilation are the other culturally harmful practices prevalent across Nigeria. Conflict in the North East has further contributed to a steep rise in targeted violence against women and children by Boko Haram increasingly for abduction and violence. Women are increasingly being used as instruments of war, making them vulnerable to stigmatization and rejection from their families and communities. Figure 1 below illustrates pervasiveness of GBV Nigeria on regional: Figure 6.0 Nigeria Degree of Gender Inequality according to the Social Institutions and Gender Index

South Nigeria Niger Mali Namibia Vietnam Brazil Thailand Africa Overall Discriminatory family code Restricted physical integrity Son bias Restricted resourcs and assets Restricted civil liberties

Legend: very low medium very high low high

GBV Risk Management Mechanisms A GBV workshop was conducted to sensitize the SPMU staff on the key principle and specific requirements to address GBV/SEA have been included in the bidding documents (‘pre-qualification’ and ‘employers’ requirements’). As such specific measures to reduce and mitigate the risk of GBV/SEA in the project. Such measures will include: i) GBV/SEA assessment of project; ii) mandatory contractors’ code of conduct on sexual harassment; iii) appointment of NGO to monitor GBV/SEA in NEWMAP-AF; iv) community and workers’ sensitization on GBV/SEA; v) provision of referral units for survivors of GBV/SEA; vi) provisions in contracts for dedicated payments to contractors for GBV/SEA prevention activities against evidence of completion; vii) contractor and SPMU requirement to ensure a minimum target of female employment with incremental rewards of the obtainment of this target. The followingactions are recommended for immediate implementation: • Hiring a dedicated GBV/SEA specialist or retraining SLOs for the project, • Including in the focal NGO’s ToR services for managing social risks associated with GBV/SEA in the project, • Building and improving FPMU/SPMUs, local communities and other relevant stakeholders’ capacities to address risks of GBV/SEA by developing and providing guidance, training, awareness, and dissemination of relevant GBV/SEA materials to communities, • Developing a clear NEWMAP specific internal “Reporting and Response Protocol" to guide relevant stakeholders in case of GBV/SEA incidents, • Strengthening operational processes of NEWMAP states project area on GBV/SEA, • Identifying development partners and cultivating pragmatic partnership on GBV/SEA prevention measures and referral services, • Developing Codes of Conduct for civil works contractors with prohibitions against GBV/SEA, • Strengthening consultations and operationalizing GBV/SEA specific grievance redress mechanisms, • Providing financial support implementation of the GBV/SEA actions described herein, including training and awareness building for various stakeholders, • Establishing inter-ministerial committee to advance GBV/SEA actions described above. Overall, GBV risks in the project target areas might include Intimate Partner Violence (IPV), public harassment including harassment, verbal insults, physical abuse, rape, harmful widowhood practices and women and child trafficking. Targeted support to women under the program could likely exacerbate these risks. Development and implementation of specific GBV risk prevention and mitigation strategies, tailored to local contexts, will be critical. Guidelines for situation analysis of GBV and safe reporting guidelines in line with international best practices will be 201

ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State implemented. Further, all risks related to labor influx will have to be mitigated by participation of project beneficiaries/communities, and involvement of project contractors and contractors’ workers and consultant employees, in identifying mitigation and implementing measures, including developing mitigation instruments such as “Labor Influx Management Plan” and “Workers Camp Site Management Plan”.

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ANNEX EIGHT MINUTES OF THE MEETING WITH OZURI COMMUNITY FOR THE REHABILITATION OF GULLY EROISON SITE ON 12TH NOVEMBER, 2017 The meeting started at 3.15pm. The Honourable, Hon. Ahmed Nuhu introduced the Environmental consultant to the people of Ozuri community while His Royal Highness briefed the people on the issues that necessitated the meeting. High Royal Highness welcomed the Environmental Consultant and his team for being part of the efforts to bring lasting solution to the erosion menace in Ozuri community for the past 5-8 years. He called on the people to aid profitable ideas and comments that will in turn bring lasting solution to the problem. He also assured NEWMAP on the community’s willingness to make their stay in the community during project implementation conducive.

The Environmental Consultant, NEMWAP addressed the people on the NEWMAP intervention in Ozuri community. He stressed that today’s meeting is vital because of need for information gathering from the community, which will aid the Consultant in preparing the Environmental and Social Management Plan (ESMP) and the need to foster relationship between the community and NEWMAP.

The Consultant introduced himself and the rest of his team, stressing that he has been engaged to carry out the Environmental and Social Management Plan (ESMP). He described the ESMP as a tool used to ascertain the positive and negative impacts that the proposed project will trigger to the environment and people. He said if the ESMP is successfully carried out, it will provide a sustainable platform to recommend mitigation measures against the adverse impacts of the project.

The Consultant emphasized that NEWMAP will ensure that any person or persons affected by this project would be properly compensated upon the agreement reached by the two parties. He restored the people’s confidence on the World Bank commitment in providing sustainable plans during and after the project.

The consultant also explained the envisaged benefits accruable to the community during rehabilitation. Expected benefits include: youth Empowerment, job creation, business opportunity and infrastructure development.

Response, Inputs and concerns The Honourable, Hon. Ahmed Nuhu appeal to NEWMAP for those affected people who have left their houses due to the gully erosion years back before the inception of NEWMAP should be consider for the compensation process. He expresses his fear that the NEWMAP Resettlement Action Plan committee is focusing on only those that are currently affected.

How the comments were addressed a) The Consultant explained that the World Bank has earmarked certain money for the erosion and watershed intervention which will be used in the rehabilitation exercises. However for the need of compensation for the affected persons, the Consultant stressed that NEWMAP team on RAP will look into the matter and see how the compensation process extend to those affected either in the past or presently. The compensation format will be made known to the affected persons by the Consultants responsible for the preparation of Resettlement Action Plan.

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ANNEX NINE LIST OF ATTENDANCE FOR OZURI CONSULTATION MEETING

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ANNEX TEN Summary of Triggered World Bank Environmental and Social Safeguard Policies • Environmental Assessment (OP 4.01). Outlines Bank policy and procedure for the environmental assessment of Bank lending operations. The Bank undertakes environmental screening of each proposed project to determine the appropriate extent and type of EA process. • Natural Habitats (OP 4.04). The conservation of natural habitats, like other measures that protect and enhance the environment, is essential for long-term sustainable development. The Bank does not support projects involving the significant conversion of natural habitats unless there are no feasible alternatives for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs. If the environmental assessment indicates that a project would significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to the Bank. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g. strategic habitat retention and post-development restoration) and establishing and maintaining an ecologically similar protected area. The Bank accepts other forms of mitigation measures only when they are technically justified. Should the sub-project-specific EMPs indicate that natural habitats might be affected negatively by the proposed sub-project activities with suitable mitigation measures • Indigenous Peoples (OP 4.10). This directive provides guidance to ensure that indigenous peoples benefit from development projects, and to avoid or mitigate adverse effects of Bank-financed development projects on indigenous peoples. Measures to address issues pertaining to indigenous peoples must be based on the informed participation of the indigenous people themselves. • Forests (OP 4.36). This policy applies to the following types of Bank-financed investment projects: (a) projects that have or may have impacts on the health and quality of forests; (b) projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests; and (c) projects that aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned. The Bank does not finance projects that, in its opinion, would involve significant conversion or degradation of critical forest areas or related critical habitats. If a project involves the significant conversion or degradation of natural forests or related natural habitats that the Bank determines are not critical, and the Bank determines that there are no feasible alternatives to the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs, the Bank may finance the project provided that it incorporates appropriate mitigation measures. • Cultural Property (OPN 11.03). The term “cultural property” includes sites having archeological (prehistoric), paleontological, historical, religious, and unique natural values. The Bank’s general policy regarding cultural property is to assist in their preservation, and to seek to avoid their elimination. Specifically, the Bank (i) normally declines to finance projects that will significantly damage non-replicable cultural property, and will assist only those projects that are sited or designed so as to prevent such damage; and (ii) will assist in the protection and enhancement of cultural properties encountered in Bank-financed projects, rather than leaving that protection to chance. The management of cultural property of a country is the responsibility of the government. The government’s attention should be drawn specifically to what is known about the cultural property aspects of the proposed project site and appropriate agencies, NGOs, or university departments should be consulted; if there are any questions concerning cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist. • Physical Cultural Resources (OP. 4.11).This policy addresses physical cultural resources,1 which are defined as movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance. Physical cultural resources may be located in urban or rural settings, and may be above or below ground, or under water. Their cultural interest may be at the local, provincial or national level, or within the international community. Physical cultural resources are important as sources of valuable scientific and historical information, as assets for economic and social development, and as integral parts of a people’s cultural identity and practices. • Involuntary Resettlement (OP 4.12). This policy covers direct economic and social impacts that both result from Bank-assisted investment projects, and are caused by (a) the involuntary taking of land resulting in (i) relocation or loss of shelter; (ii) loss of assets or access to assets, or (iii) loss of income sources or means of livelihood, whether or not the affected persons must move to another location; or (b) the involuntary restriction of access to legally designated parks and protected areas resulting in adverse impacts on the livelihoods of the displaced persons. This policy will

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ESMP for Ozuri Gully Erosion Site in Adavi LGA of Kogi State most likely not apply to SESP as this project will not entail taking of land or restriction of access to sources of livelihood.

Plate 3.1: Main feeder from Okunchi Hill to the east of Ozuri community

Plate 3.2: Exposed base of Obangede - Ogaminana Plate 3.3: Feeder running along Ogaminana Road road due to heavy runoff from Okunchi hill

Plate 3.4: Erosion route with large deposit of sand

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Plate 3.5: Pictorial presentation of the gully

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Hon. Ahmed introducing the consultant

His Royal Highness briefing the people on the issues that necessitated the meeting

Opening remark by Mr. Simon Odaudu, NEWMAP Environmental Consultant

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Mr. Salawu Sumaila (chairman) Ozuri NEWMAP site committee briefing the consultant

Mr. Momoh Yusuf raised issues concerning compensation Mrs. Shaibu Rabi expresses her gratitude to NEWMAP

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