Improving Internet Connectivity for the South Pacific Project

Environmental Monitoring Report

Annual Report September 2020

Cook Islands: Improving Internet Connectivity for the South Pacific Project

Prepared by Avaroa Cables Limited for the Ministry of Finance and Economic Management and the Asian Development Bank.

CURRENCY EQUIVALENTS (as of 20 October 2020)

Currency unit – New Zealand dollar (NZ$) NZ$1.00 = $0.66060 $1.00 = NZ$1.513775

ABBREVIATIONS

ACL Avaroa Cable Limited ADB Asian Development Bank BMH Beach Manhole CLS Cable Landing Station CLC Cable Laying Contractor EA Environment Assessment EEZ Exclusive Economic Zone EIA Environmental Impact Assessment EMP Environmental Management Plan ESMP Environment and Social Management Plan ESMiT Environment and Social Mitigation Table ESMoT Environment and Social Monitoring Table Gbps Gigabits per second GRM Grievance Redress Mechanism H&S Health and Safety HHs "Pulling Manholes" HSP Health & Safety Plan ICT Information and Communications Technology IEE Initial Environmental Examination Mbps megabits per second MC Manatua Consortium MCP Manatua Cable Project NEC National Environmental Council NES National Environmental Service NT Telecom Niue OPT Office des Postes et telecommunication PMU Project Management Unit PPE Personal Protective Equipment ROW Right of Way SCS Submarine Cable System SPS Safeguard Policy Statement SSCC Samoa Submarine Cable Company

NOTES

(i) The fiscal year (FY) of the Government of the Cook Islands and its agencies ends on 30 June. “FY” before a calendar year denotes the year in which the fiscal year ends, e.g., FY2016 ends on 30 June 2016.

(ii) In this report, “$” refers to United States dollars, unless otherwise stated.

This environmental monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

I. EXECUTIVE SUMMARY

The Government of the Cook Islands, through an approved ADB Loan and grant funding from the New Zealand Ministry of Foreign Affairs and Trade, is undertaking the installation of a new submarine fibre optic cable to Rarotonga and Aitutaki.

The Project: Improving Internet Connectivity for the South Pacific, is being managed in the Cook Islands by the Ministry of Finance and Economic Management division and executed by Avaroa Cable Limited, a limited liability company wholly owned by the Government of the Cook Islands.

The Manatua Cable, a new, state of the art submarine fibre optic cable, has been installed between the four Pacific nations linking Samoa and Tahiti with spurs to Niue, Rarotonga, Aitutaki and Bora Bora.

In summary, specific infrastructure components and installation works for the Cook Islands comprise of:

(i) Fibre optic cable, consisting of 0.125mm thick glass fibres (excluding protective cladding) along which a signal is transmitted, to be laid directly on the sea floor by a cable laying vessel from a branch unit on the main trunk cable to shore at Rarotonga and Aitutaki; (ii) When the cable is close to shore it is floated ashore and installed with the assistance of divers. From this point to the Beach Man Hole (BMH), the cable is protected using articulated piping and either buried in the soft substrate or bolted to the harder substrate, avoiding sensitive ecological features. In the upper intertidal beach areas, the cable will be buried using a tractor with a backhoe up to 1.5m deep and under foreshore land to the BMH; (iii) Installation of a BMH structure on the seaward side of the road on private (Rarotonga) and Government-owned (Aitutaki) land; (iv) Installation of terrestrial fibre cable in ducting buried in the road reserve adjacent to the road pavement in between the BMH and the Cable Landing Station (CLS); (v) Installation of smaller ‘pulling manholes’ (HHs) between the BMH and the CLS to assist with installing the cable; (vi) A self-contained CLS located within a prefabricated 20-foot container.

Analysis and thorough considerations were considered when evaluating the impacts, the specific infrastructure components and installation works would have on the environment resulting in the following:

(i) A comprehensive Environment Impact Assessment published by Environment specialists, Argo Consulting on proposed project works. (ii) Works permitted by National Environment Services, the government body managing the monitoring and preservation of sea and land environment within the Cook Islands. (iii) Works permitted by the National Environment Council, the government body managing the monitoring and preservation of sea activities within the Cook Islands Exclusive Economic Zone (EEZ). (iv) A comprehensive safeguard monitoring plan to mitigate and monitor all works undertaken.

The outcome of all actions taken has resulted in minimal impact to the environment and natural habitats.

II. TABLE OF CONTENTS Table of Contents I. EXECUTIVE SUMMARY 4 II. TABLE OF CONTENTS 5 III. ABBREVIATIONS 5 IV. INTRODUCTION 6 A. Background 6 B. Project Objectives 7 V. POLICY AND LEGAL FRAMEWORK 7 C. Introduction 7 D. Legal Framework 8 E. Environment laws and regulation. 8 F. Cultural preservation. 8 G. ADB Safeguard Policy 9 H. Health & Safety 9 I. Industry Sector policies / Codes of Practice 9 VI. PROJECT CONSTRUCTION & INSTALLATION WORKS 9 J. Analysing the cable route 9 K. Cable Installation works 13 VII. ENVIRONMENTAL MANAGEMENT 14 L. Existing Environment 14 M. Ecological Environment 14 N. Construction Environment Impacts 15 O. Environment Summary and Conclusions 15 VIII. GRIEVANCE REDRESS MECHANISM 16 P. Acting in Good Faith 16 IX. ENVIRONMENT AND SOCIAL MANAGEMENT PLAN (ESMP) 18 X. ENVIRONMENT MITIGATION PLAN (ESMIT) REPORTING 27 XI. ENVIRONMENT MONITORING PLAN (ESMOT) REPORTING 32 XII. SUMMARY AND CONCLUSION 37 APPENDIX 1: 38 APPENDIX 2: 39

III. ABBREVIATIONS

Table 3.1: Key abbreviations used in this Report

IV. INTRODUCTION

Background

1. In 2018, the Governments of the Cook Islands, Niue, Samoa and French Polynesia signed an International Treaty to work together on the Manatua Cable Project (MCP) to link the four countries through a new fibre optic submarine cable system (see Figure 4.1). It is the first collaboration of its kind in the Pacific. Each country would engage in the Manatua Consortium (MC) through its own operator company, in the case of the Cook Islands, this is Avaroa Cable Limited (ACL).

2. ACL is part owner of the Manatua cable in a consortium with publicly held operators in: (i) French Polynesia – Office des Postes et telecommunication (ii) Niue – Telecom Niue (iii) Samoa – Samoa Submarine Cable Company

3. ACL has been established to transform connectivity to the Cook Islands through the design, manufacture, installation and operation of the Manatua cable. The Manatua cable is a 3,634 km, two fibre pairs system connecting Samoa, Niue, Rarotonga and Aitutaki in the Cook Islands and Tahiti and Bora Bora in French Polynesia. Each fibre is capable of operating at up to 10 tera bits per second (10,000,000 megabits per second) using state-of-the-art fibre optic technology.

4. The cable provides cheaper, faster and more reliable wholesale connectivity which will be consumed by retailers (e.g. Vodafone Cook Islands) to provide better products and services to the people and businesses of the Cook Islands.

5. In 2020, The Manatua Cable was successfully installed across the four pacific nations and declared ready for service (RFS) in July. This news coincided with the announcement of the first customers to use the Manatua Cable, the Vodafone Cook Islands consumers located on the small atoll of Aitutaki in the Cook Islands.

6. ACL is head-quartered in the Ingram House Building, Avarua, Rarotonga, Cook Islands.

Figure 4.1: MCP cable alignment

7. The Cook Islands consists of a group of 15 islands located about 3000 km northeast of Auckland, New Zealand, with the capital at latitude 21°14′S 159°46′W. The Islands are generally split into the southern and northern group with the southern considered subtropical

and the northern group fully tropical islands. The Cook Islands' exclusive economic zone (EEZ) covers 1,970,000 km2 of ocean (see Figure 4.2.).

8. In summary, the Cook Islands MCP (the Project) includes:

(i) Placement of the cable from the deep ocean spur to a landing on the shore; and (ii) Installation of cable on land via a Beach Manhole (BMH) and trenched along the road reserve to a cable station (CLS).

Figure 4.2: Cook Islands geographical location

Project Objectives

9. The objective of the Project is to reduce the cost and increase the availability of Information & Communications Technology (ICT) services to support social and economic development.

10. The Project is expected to contribute to improved public service delivery (including online government services, health and education and financial services); increased private sector development opportunities, and reduced transaction costs for businesses and individuals; and national and regional integration objectives of improved service delivery, trade and communications between the Cook Islands and other Pacific island economies.

11. The key safeguards objective is to undertake the MCP in a way that no significant environmental or social impacts arise following implementation of mitigation measures.

V. POLICY AND LEGAL FRAMEWORK

Introduction

12. A range of environmental approvals were obtained from various Cook Island Government Ministries for MCP installation and operation. These are outlined in Table 5.1. 7

TABLE 5.1: APPROVALS REQUIRED Approvals Required Government Ministry / Date Obtained Attachment Department Environmental Building National Environment 12 September 2019 Permit - Rarotonga Service Permit_Rarotonga.p df

Environmental Building National Environment 12 September 2019 Permit - Aitutaki Service Permit_Aitutaki.pdf

Environmental Building National Environmental 12 September Permit – Economic Council of the Cook 2019 Exclusive Zone (EEZ) Islands Permit_CI_EEZ.pdf

Legal Framework

13. The Constitution Act was enacted by the Parliament in 1964. It is the supreme law of the land that sets out the power and responsibilities of the government and its three main branches: executive, legislative and judiciary.

Environment laws and regulation.

14. A detailed review of the Cook Islands’ environmental legislation was undertaken in 1995-6 (Boer, 1996). Since the review, two relevant acts and a regulation were either revised (Marine Resources Act) or drafted (the Environment Act 2003 & the Environment Regulations 2011).

15. The Environment Act 2003 is the Cook Islands’ key environmental legislation. The Environment (Permits and Consents) Regulations 2011 set out the requirements for undertaking a project that impacts the natural environment as well as that of the National Environment Service (NES). When NES is satisfied that all concerns (if any) have been addressed, it may then issue any one of three decisions: (i) permit to proceed with no conditions; (ii) permit to proceed with specific conditions; or (iii) refuse to issue a permit to proceed.

16. The NEC (National Environment Council), as stipulated in the Environment Act 2003, has a role in the permitting process especially in regard to Projects that extend 12 nautical miles out from the Cook Islands into the Exclusive Economic Zone (EEZ). When NEC is satisfied that all concerns (if any) have been addressed, it may then issue any one of three decisions: (i) permit to proceed with no conditions; (ii) permit to proceed with specific conditions; or (iii) refuse to issue a permit to proceed.

Cultural preservation.

17. The Cook Islands Cultural Development Act 1990 aims to preserve, perpetuate and enhance the country’s cultural heritage to uphold traditions and develop an appreciation for the Cook Islands’ culture. The act also enables growth and expansion of productive economic, social and educational activities that may enhance cultural forms and protect the unique national cultural identity of the people of Cook Islands. The Act also created the Ministry of Cultural Development and the Advisory Technical Committees to advise the Minister on the functions of the Ministry.

ADB Safeguard Policy

18. The ADB’s 2009 Safeguard Policy Statement (SPS) consists of three safeguard requirements (SR): SR1: environment; SR2: involuntary resettlement; and SR3: Indigenous Peoples.

19. The objectives of ADB’s safeguards are to: (i) avoid adverse impacts of projects on the environment and affected people, where possible; (ii) minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is not possible; and (iii) help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks. Through its SPS ADB establishes policy objectives, scope and triggers, and principles for three key safeguard areas of environment, involuntary resettlement, and Indigenous People. The SPS sets out the process to be applied from screening, through due diligence and assessment to monitoring and reporting.

20. The objective of SR1 is to ensure the environment soundness and sustainability of projects and to support the integration of environmental considerations into the project decision-making process. To help achieve the desired outcomes, ADB adopts a set of specific safeguard requirements that need to be achieved during the processing and implementation of projects financed by ADB.

21. In accordance with ADB’s SPS, the project has been classed as Category B for environment. The overarching objective of ADB’s SPS is to provide a process which the borrower must use to define, prevent and secondarily mitigate any significant negative effects on the physical, ecological and social environment within a projects’ impact area.

Health & Safety

22. The SPS requires compliance with the World Bank Group’s Environmental Health and Safety Guidelines (World Bank 2007). Each project is required to provide workers with a safe and healthy working environment, considering inherent risks, any hazards in the work areas, including physical, chemical, biological, and radiological hazards. The SPS also requires that the government, through the implementing agency, will take steps to prevent accidents, injury, and disease arising from, associated with, or occurring during the course of work.

Industry Sector policies / Codes of Practice

23. There are no specific Code of Environmental Practice available for submarine internet cable installations.

VI. PROJECT CONSTRUCTION & INSTALLATION WORKS

Analyzing the cable route

24. Analysis of the most optimal offshore cable route determined that the cable originate in Samoa, then follow a south-westerly track passing Niue and then between Rarotonga and Aitutaki of the Cook Islands, then north to French Polynesia. Various other alignments have been considered but the current offshore route is considered to be the most cost-effective. It was also agreed that the cable would have at last three spurs, one to Niue, one to Rarotonga, and one to Aitutaki in the Cook Islands. In this document, a spur is the term given to a cable that branches off from the main Manatua Cable “trunk” and ends at its designated destination. A number of alignment options have been considered in Rarotonga and Aitutaki previously, with 3 and 4 key options respectively analyzed. The preferred option was selected on the basis of analysis of the following criteria: 9

(i) Least amount of encroachment on private or customary land; (ii) Least amount of interference with marine protected areas; (iii) Least effect on sensitive coastal and nearshore marine features; (iv) Lowest risk of impacts on Beach Manhole (BMH) site due to coastal erosion; (v) Least effect on tourism/fishing/boating/shipping activities; and (vi) Proximity of the BMH site to the proposed Cable Landing Station (CLS).

25. The outcome of this analysis concluded that on Rarotonga the preferred option brings the cable through Rutaki Passage to a BMH located on private land, and then along a route adjacent to the road corridor to a CLS located adjacent to the Vodafone Cook Islands facility at Aroa (see Figure 6.1A).

26. In Aitukai the preferred option brings the cable through Ava Motu Passage to a BMH located at the end of the old airport runway on Government-owned land, and then along a route adjacent to the road corridor to the CLS to be located adjacent to the hospital at Arutanga (see Figure 6.1B).

27. In conclusion, the Cable alignment follows the route where impacts on marine ecology are minimized.

a. b.

c. d.

e.g. f.

Figure 6.1A: Rarotonga - Images showing cable alignment through subtidal & intertidal environment (a., b. & c.), foreshore land (d.), beach manhole and typical road corridor (e. & f.)

a. b.

e. f.

Figure 6.1B: Aitutaki - Images show cable alignment through the intertidal environment (a.), foreshore land (b.), beach manhole location at the end of the old runway (c.), and typical road corridor (d. & e.) and CLS location (f.)

Cable Installation works

28. On Rarotonga, the Cable from the BMH has been buried within the existing road ROW leading to the Aroa CLS approximately 1.3 km (see Figure 6.2A). Similarly, on Aitutaki, the cable has been buried from the BMH along the main road to the CLS within the hospital compound approximately 6.3 km (see Figure 6.2B).

c. b.

Figure 6.2A: These images show the cable route and works undertaken in Rarotonga (a) Cable route from the BMH to CLS (b) Trenching works occurring in ROW (c) Turning Man Hole (d) BMH (e) CLS site a. b.

Figure 6.2B: (a) The Aitutaki Cable route from the BMH to CLS trenching works (b) CLS being constructed in Aitutaki

VII. ENVIRONMENTAL MANAGEMENT

Existing Environment

29. Offshore in Cook Islands territorial waters, the benthic habitat consists of mud sands of the deep ocean which has ecological resources of little or no significance. Nearshore, the Cable alignment in Rarotonga and Aitutaki brings the cable through Rutaki Passage and Ava Motu Passages directly to shore. The subtidal habitat in these locations consists primarily of coral rubble, sands and hard rock pavement with occasional sensitive ecological features such as corals. The intertidal area consists primarily of sandy beach with little or no ecological significance.

30. The terrestrial ecological resources of the BMH, cable corridor alongside the road to the CLS and the CLS sites themselves are limited as a result of previous clearance activities. There is a small amount of vegetation on private land between the upper intertidal and the BMH at the Rarotonga site, but this is also considered to be of limited ecological significance.

Ecological Environment

Overview of Rarotonga:

31. Volcanic Rarotonga has the only cloud forest in the Cook Islands, as well as upland forests along mountain slopes, fern meadows created after primary forest removal, partially drained wetlands and remnants of coastal and strand forests. The cloud and upland forests provide critical habitat for many native species including 24 endemic species. Native marine habitats are limited to fringing coral reef, shallow lagoon systems never exceeding a depth of 4m. There is one shrinking saltwater marsh located in Avana, Ngatangiia. In addition to providing spawning and nursing grounds from many fish species, the marshland also provides for two species of native fiddler crab, the Koiti and Raukura (Uca crassipes and U. tetragonon). 9 As of 2011 Rarotonga had ten environmental protection/conservation areas, of which six are protected via Ra’ui, three are national reserves and one is a water catchment reserve. The location of the BMH, the cable corridor alongside the road to the CLS and the CLS sites themselves are not located in the area of any identified critical habitats for Rarotonga.

Overview of Aitutaki:

32. Aitutaki is halfway between being a volcanic island and an atoll and, as shown has a triangular ring of islets encircling a large lagoon. It has a land area of 18 km2 of land and a well-established coastal coconut and broadleaf tropical forest cover. There are wetlands, providing habitat for freshwater eels and taro cultivation. The surrounding islets are the nesting grounds for many seabirds including the nationally endangered red-tailed tropicbird (Phaethon rubricauda). Saltwater marshes, bordering the coral reef, and the expansive lagoon are fringed by the coastal hardwood shrub ngangie (Pemphis acidulus) growth. These marshes are key nursery and spawning grounds for many lagoon fish. Aitutaki has a marine hatchery that is successfully breeding the giant clam (Tridacna maxima) for restocking around Aitutaki and other Cook Island locations. The location of the BMH, the cable corridor alongside the road to the CLS and the CLS sites themselves are not located in the area of any identified critical habitats for Aitutaki.

Construction Environment Impacts

Key Biodiversity & Habitat Impacts

(i) Direct loss of small area of marine habitat in cable footprint (ii) Physical effect of sedimentation as a result of suspension of fine materials and off-site deposition affecting fish & coral. (iii) Direct loss of terrestrial biodiversity or habitat in BMH/CLS locations or along roadside. Overall, impacts were not significant due to the very small area of marine habitat directly impacted, there was no critical habitat present, and works were of short duration.

Key Social Impacts

(i) Temporary Restrictions on access to channel / reef areas. (ii) Involuntary Resettlement, Land Acquisition and Asset Loss. There was no displacement of tenants nor land use. (iii) Pedestrian & Vehicular Traffic. Small construction crew along road corridor during BMH installation and cable front haul activities. Traffic Management Plan (TMP), public notices advising of timing of works, restrict public access, maintenance of property access all resulted in minimal to no impact experience. (iv) Worker & Community Health & Safety. Health & Safety Plan (HSP), Health & Safety training, personal protective equipment (PPE), signage, access restrictions, public notices all resulted in minimal to no impact experienced. Environment Summary and Conclusions

(i) The cable alignment route has minimal impact on marine ecology. (ii) Key ecological impact is the very minor loss of reef habitat in cable footprint and short-term disturbance during cable installation. (iii) Key socio-economic impacts include temporary restrictions to access reef. No involuntary resettlement, land acquisition or asset Loss. (iv) A range of potential environmental and social impacts that could arise were identified in advance and mitigating measures outlined in the detailed ESMP. (v) Therefore, the MCP Project, during the construction and installation stages, has had no more than a minor overall impact on the environment. 15

VIII. GRIEVANCE REDRESS MECHANISM

33. A grievance redress mechanism (GRM) was instated. A grievance could, in theory, arise as a result of fishing gear becoming entangled on the cable presumed to be due to due to faulty cable placement, or an issue arises as a result of the failure of the contractor to restore the front haul trench following completion of cable installation.

34. The GRM is scaled to the risks and adverse impacts of the Project. If promptly addressed and using an understandable and transparent process that is gender responsive, culturally appropriate, and at no costs and without retribution, the concerns and complaints of potentially affected people will usually be resolved.

35. The GRM mechanism does not impede access to regular judicial process, but simply provides a simpler access to complaint resolution. The PMU will inform the Village chief of the GRM before commencement of any civil works. This will be done as part of an initial consultation session (see Table 9.2 ESMoT Item 1.2).

36. The following six-step mechanism (Table 8.1) is proposed for grievance redress of social and environmental matters.

Table 8.1: Grievance Redress Process Step Process Duration 1 Affected Person (AP) / village elected or traditional chief takes Any time grievance to Project Manager or Contractor 2 Project Manager or contractor reviews issue, and in 2 weeks consultation with Village chief and contractor (if appropriate), agrees to a solution and records the results. 3 Project Manager reports back to Village chief and AP and gets 1 week clearance the complaint has been resolved. If unresolved 4 AP take grievance to relevant government agency for Decision within 2 weeks resolution Director of Cook Islands National Environment Services 5. AP refers matter to relevant government agency 2 weeks 6 Relevant government agency refers to an internal committee 4 weeks 7 Internal committee reports back to relevant government 1 week agency/AP If unresolved or if at any stage and AP is not satisfied with progress AP can take the matter to appropriate state or national court. As per judicial system

37. During implementation, the Project Manager will be responsible for interacting with the GRM. The Project Manager will be the grievance focal point, and receive and address project related concerns, via the designated staff member. Concerns will be resolved first by the Project Manager and contractor. The community and stakeholders will be made fully aware of their rights regarding land ownership and environmental degradation.

38. Throughout this process, the Government will always be available to hear public complaints and provide advice if the complainant feels that Project Manager responses are not satisfactory.

Acting in Good Faith

39. The Project Management Unit has worked alongside the members of the community and landowners alike to ensure all actions undertaken were done with care and in consultation with those interested. As a result, the Grievance Redress Mechanism has not been required, to date.

40. Feedback received and actions undertaken with regards to project works are captured in following table: Table 8.2 Public Requests

Table 8.2: Public Requests # Request Requeste Location Action Owner Outcome d by 1 When trenching Landowner Rutaki, Best endeavors. Project Completed. alongside Rarotonga Trenching required Manager Successfully residential hedge, very close to hedge preserved please take care to root system so may hedge. ensure the hedge is damage or not damaged. collapse into Property adjacent trench. Will place to BMH site. temporary retainer to protect hedge whilst exposed 2 When clearing the Landowner Rutaki, Will discuss with Project Completed beach area please s Rarotonga National Manager tidy up the rocks Environment leading down to the Support as is beach coastal area. If no negative impact, then will arrange whilst works are being undertaken on site 3 Please level the Landowner Rutaki, Agreed to Project Completed land next to the s Rarotonga undertake this Manager BMH site and activity at the time remove all debris works are being so it looks tidy carried out. Remove existing debris including concrete block foundation of old home. 4 If you have any Elderly Aroa, Agreed. Any Project Completed. leftover gravel, can Residential Rarotonga surplus to needs Manager you place on my homeowne once works driveway? r (lives completed will be along cable placed on route) driveway. 5 When trenching the Local Arutanga, Agreed. Project Completed road can you make community Aitutaki Reinstatement of Manager sure to reinstate it? member roads included in contracts and closely monitored. 6 Trim the trees and Local BMH Agreed. Local Project Completed. surrounding areas community location, Island council Manager on the coastal area member Aitutaki undertook this work so the cable ship in working can be viewed from partnership with a safe distance ACL. away from those working on the beach.

IX. ENVIRONMENT AND SOCIAL MANAGEMENT PLAN (ESMP)

41. This section outlines the Environmental and Social Management Plan (ESMP). The ESMP is organized into two cross-referenced tables; namely the Environmental Mitigation table (ESMiT) and monitoring table (ESMoT) provided in Tables 9.1 & 9.2 below. These two tables list in detail the mitigation measures and monitoring actions that the Executing Agency (ACL) has implemented, from the planning through the operating period of the project.

Table 9.1: Environmental and Social Impact Mitigation Table (ESMiT) TIMING/ PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION IMPLEMENTATION SUPERVISION DURATION 1.0 PRE-CONSTRUCTION PERIOD (Planning and design actions to prevent future impacts) 1.1 Ecological Environment Ecological Disturbance of marine, Prepare routing report based on detailed design Subtidal, Prior to start Cable Laying Project Environment terrestrial & freshwater demonstrating avoidance of significant habitat Intertidal & of Contractor (CLC) & Manager organisms and habitats areas terrestrial Construction TIM cable route Reef Communities Damage to coral In contract specifications instruct cable survey Subtidal & Construction CLC, TIM, contract Project assemblages team to survey cable alignment for coral Intertidal contract specialist & Project Manager outcrops, and design alignment to avoid. cable route documents Manager Species potentially Disturbance of marine Contract specifications to include best practice Subtidal & Construction CLC, TIM, contract TIM at risk (whales, cetaceans and turtles for operating vessels in proximity to marine Intertidal contract specialist dolphins, turtles) mammals as included in the Code of cable route documents Environmental Practice (COEP) document. 1.2 Socio-Economic Environment Community Misconceptions raising Specify in contract docs that at least one Cook Islands Before civil Project Manager & CLC Information people’s fears regarding community consultation prior to commencement work begins TIM project footprint and of civil works and during construction to reduce and during at potential damages to concerns about construction impacts. regular marine food supply. intervals Community Minor concerns/issues Establishment of grievance redress mechanism Cook Islands Before civil Project Manager Project Grievances developing community (GRM) prior to commencement of civil works and works begin Manager resentment due to making this known to villages during follow up unaddressed project meetings before the work begins. related concerns Access during Failure of contractors to Contract specs to include instruction re full Residents Before civil Project Manager Project landside trenching do front haul trenching rehabilitation immediately after trenching with access works begin Manager work with minimal completed. Develop protocol to provide notice of affected by damage, impact on access restrictions, comprising the following: trenching existing services and • Notification of roadside residents by letter access restrictions to providing project details, potential access property restrictions and likely timing of activities; • On-site meetings with affected residents (if requested). Develop a specific procedure, in consultation with hospital management, to ensure emergency access is maintained to local Hospital. 19

TIMING/ PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION IMPLEMENTATION SUPERVISION DURATION 2.0 CONSTRUCTION PERIOD (Impacts associated with the work) 2.1 Ecological Environment Reef Communities Disturbance of coral reef Contractor(s) to adhere to avoidance rule and lay Off & Inshore When work CLC, TIM, contract Project communities cable along surveyed route, as per cable-laying coastal areas is being specialist & Project Manager specification, thus avoiding coral outcrops. undertaken Manager Cable placement in to be diver-assisted to avoid significant ecological features such as corals. Species of special Entanglement in cable Control cable tension so that laid cable conforms Oceanic When work CLC, TIM, contract TIM Interest – risk for deep diving to undulations of seabed as per cable laying deep-sea is being specialist Cetaceans cetaceans specification and-or provide anchors if needed. areas. undertaken 2.2 Socio-Economic Environment Coastal Resource Damage to local As per the contract specifications, contractor is Offshore & When work CLC Project Users – nearshore fishing to confine cable installation activities to a narrow nearshore is being Manager subsistence and grounds or introduce corridor, restore beach area when finished and Coastal undertaken artisanal fisheries greater chances of gear confine activities to short a period as possible. areas. entanglement Request Fisheries authorities to advise local fishers of cable laying activities, dates, and avoidance measures. Consider placing markers along cable line in shallow (<10 m) waters. Fishing vessel Potential impact on Residents/Fishers to be notified in advance – Offshore & When work CLC Project activity in nearshore existing recreational and adopt notification protocol based around advice nearshore is Manager coastal commercial vessel to Government Coastal undertaken. environment activity areas. Coastal shipping – Damage to ships Ensure shipping notice is issued, warning of Offshore and When work CLC & TIM Project commercial through cable cable-laying, dates, and safe clearance for other inshore is Manager shipping and ports entanglement. activities. areas undertaken. Disruption to shipping Request Port Authority to advise local shipping during cable laying. of laying activities and avoidance measures. Contractors to provide written statement to TIM that marine navigation lights and other national maritime measures are closely followed by contractors’ vessels at all times. Land Use Detour from agreed Consult Government on progress of work and Various When work CLC Project cable alignment cable alignment with the objective of informing is Manager all interested people on the work and general undertaken. alignment location and methods to be used.

TIMING/ PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION IMPLEMENTATION SUPERVISION DURATION Access to fishing Temporary loss of local Consult with Government During cable When work CLC Project grounds communities’ access to laying is Manager fishing grounds during undertaken. cable laying Earthworks Loss of or disturbance to Chance findings of heritage resources trigger During cable When work CLC Project activities potential recreational & “Chance Finds Procedure”. laying is Manager heritage resources undertaken. Inadequate TIM and CLC fail to TIM and CLC, prior to start of work, present draft Various At start of CLC & TIM Project information include Government in plan to Government and seek input and construction Manager disclosure final alignment planning agreement on final alignment plan, TIM. and decision making 3.0 OPERATING PERIOD 3.1 Physical & Ecological Environment Perceived pollution Fear of potential In-house procedures for receiving and Various At start of ACL ACL from cable. damages to marine life addressing complaints developed operation 3.2 Socio-Economic Environment Vessel activity in Entanglement of anchor Due to burial and cable attachment to reef there Various At start of ACL ACL nearshore coastal on cable is low risk of this occurring. operating environment period Potential impacts As well as fishing in An awareness-raising programme is considered Various At start of ACL ACL on fishing - risk of shallow water, fish in the best approach to avoiding such losses. If operating entanglement deep water. Gear could fishers are aware of locations, they will be able period be caught on cable. to reduce likelihood of gear loss to unlikely Impact associated Failure to adopt Make population aware of internet site blocking Various At all times Service provider and ACL with improved measures and continue features available to every subscriber; possibly an appointed NGO Internet - easier mitigation actions via a village advisory group. or women’s group access to harmful sites Use of internet Many lifestyle and health Provide community support and training in Various At all times Service provider and ACL adversely issues derive from lack of relation to internet use. One option here could be an appointed NGO impacting on exercise. Increased an integrated community education programme exercise by access to the internet addressing all potential social impacts identified members of local might make these in this table. communities. problems worse

TIMING/ PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION IMPLEMENTATION SUPERVISION DURATION Access to Potential for significant Provide community support and training in Various At all times Service provider and ACL inappropriate impacts in small relation to internet use. One option here could be an appointed NGO material, communities arising from an integrated community education programme particularly access to internet and addressing all potential social impacts identified children; use of social media in this table. cyberbullying. among young people.

Cost to end-users Concern about cost of New internet availability would be of little benefit Various At all times Service provider ACL internet for users and if people cannot access it for a reasonable price. their ability to afford related equipment. if people cannot afford the internet, the cable will not benefit the population.

Table 9.2: Environmental and Social Impact Monitoring Table (ESMoT) WHEN/ PARAMETERS POTENTIAL IMPACT MONITORING FREQUENCY/ OUTPUT IMPLEMENTATION SUPERVISION DURATION 1.0 PRE-CONSTRUCTION PERIOD (Planning and design actions to prevent future impacts) 1.1 Ecological Environment Ecological Disturbance of marine & Prepare routing report based on detailed design Prior to Routing CLC & TIM Project Environment terrestrial organisms and demonstrating avoidance of significant habitat construction report Manager habitats areas Reef Communities Destruction of coral In contract specifications instruct cable survey Prior to Record to CLC, TIM, contract Project assemblages team to survey cable alignment for coral construction file specialist & PMU Manager outcrops, and design alignment to avoid.

Species potentially Disturbance of marine Contract specifications to include best practice Prior to Record to CLC, TIM, contract Project at risk (whales, cetaceans and turtles for operating vessels in proximity to marine construction file specialist, PMU Manager dolphins, turtles) mammals

1.2 Socio-Economic Environment Community Misconceptions raising Specify in contract docs that at least one Prior to Record to Project Manager& CLC Information people’s fears regarding consultation with Community leaders prior to construction file TIM project footprint and commencement of civil works and during potential damages to construction to reduce concerns about marine food supply. construction impacts is required.

WHEN/ PARAMETERS POTENTIAL IMPACT MONITORING FREQUENCY/ OUTPUT IMPLEMENTATION SUPERVISION DURATION Community Minor concerns/issues Establish of GRM prior to commencement of civil Prior to Record to Project Manager Project Grievances developing community works and making this known to villages during construction file Manager resentment due to follow up meetings before the work begins. unaddressed project related concerns Access during Failure of contractors to Contract specs to include instruction concerning Prior to Record to Project Manager Project landside trenching do trenching work with full rehabilitation immediately after trenching construction file Manager minimal damage and completed in one area. access restrictions to Develop notification protocol to provide notice of property access restrictions, comprising the following steps: • Notification of the roadside residents by letter providing details of the project, potential access restrictions and likely timing of activities; and • On-site meetings with affected residents (if requested). Develop a specific procedure, in consultation with hospital management, to ensure emergency access is maintained to local Hospital. Front haul cable Disruption to existing Design to avoid interference with existing Prior to Routing Telecom &TIM Project install affecting services services construction report Manager existing services

2.0 CONSTRUCTION PERIOD (Impacts associated with the work) 2.1 Ecological Environment Reef Communities Disturbance of coral reef Contractor(s) to adhere to avoidance rule and lay During cable Site notes CLC, TIM, contract Project communities cable along surveyed route, as per cable-laying installation taken, to specialist Manager specification, thus avoiding coral reefs and file outcrops. Cable placement in to be diver-assisted to avoid coral heads.

Species of special Entanglement in cable Control cable tension so that laid cable conforms During cable Site notes CLC, TIM, contract PMU & TIM Interest – risk for deep diving to undulations of seabed as per cable laying installation taken, to specialist Cetaceans cetaceans specification and-or provide anchors if needed. file

WHEN/ PARAMETERS POTENTIAL IMPACT MONITORING FREQUENCY/ OUTPUT IMPLEMENTATION SUPERVISION DURATION 2.2 Socio-Economic Environment Coastal Resource Damage to local As per the contract specifications, contractor is During cable Site notes CLC Project Users – nearshore fishing to confine trenching activities to as narrow a installation taken, to Manager subsistence and grounds or introduce corridor as possible and restore site when file artisanal fisheries greater chances of gear finished and confine trenching/laying activities to entanglement as short a period as possible Request Fisheries authorities to advise local fishers of cable laying activities, dates, and avoidance measures. Consider placing warning markers along cable line in shallow (<10 m) waters. Fishing vessel Potential impact on Residents to be notified in advance – adopt During cable Site notes CLC Project activity in nearshore existing recreational and notification protocol based around providing installation taken, to Manager coastal commercial vessel advice. Written notification to residents and on- file environment activity. site meetings if requested. Coastal shipping – Damage to ships Ensure shipping notice is issued, warning of During cable Site notes CLC & TIM Project commercial through cable cable-laying, dates, and safe clearance for other installation taken, to Manager shipping and ports entanglement. activities. file Disruption to shipping Request Port Authorities to advise local shipping during cable laying. of laying activities and avoidance measures. Contractors to provide written statement to TIM that marine navigation lights and other national maritime measures are closely followed by contractors’ vessels at all times. Land Use Detour from agreed Conduct a series of consultations on progress of During cable Site notes CLC Project cable alignment work and cable alignment with the objective of installation taken, to Manager informing all interested people on the work and file general alignment location and methods to be used. Access Temporary loss of local Consult with Government agencies During cable Site notes CLC Project communities’ access to installation taken, to Manager fishing grounds during file cable laying Earthworks Loss of or disturbance to Chance findings of heritage resources trigger During cable Site notes CLC Project activities potential recreational & “Chance Finds Procedure”. installation taken, to Manager heritage resources file

WHEN/ PARAMETERS POTENTIAL IMPACT MONITORING FREQUENCY/ OUTPUT IMPLEMENTATION SUPERVISION DURATION Disturbance of grave Monitoring to ensure no physical disturbance of During cable Site notes CLC Project located on Te Au Road grave installation taken, to Manager (Rarotonga) file TIM and CLC fail to TIM and CLC, prior to start of work, present draft During cable Site notes CLC & TIM Project Inadequate include Government in plan and seek input and agreement on final installation taken, to Manager information final alignment planning alignment plan, etc. file disclosure and decision making 3.0 OPERATING PERIOD 3.1 Physical & Ecological Environment Perceived marine Fear of potential In-house procedures for receiving and As required Periodically ACL Project pollution from damages to marine life addressing complaints developed Manager installed cable 3.2 Socio-Economic Environment Impact associated Failure to adopt Make population aware of internet site blocking As required Periodically Service provider and Regulator with improved measures and continue features available to every subscriber; possibly an appointed NGO Internet - better mitigation actions via a village advisory group. or women’s group access to harmful defined in the sites Construction Period Environmental Completion report. Use of internet Many lifestyle and health Provide community support and training in As required Periodically Service provider and MoH adversely issues derive from lack of relation to internet use. One option here could be an appointed NGO impacting on exercise. Increased an integrated community education programme exercise by access to the internet addressing all potential social impacts identified members of local might make these in this table. communities. problems worse if people become addicted. Access to Potential for significant Provide community support and training in As required Periodically Service provider and MoH inappropriate societal impacts in small relation to internet use. One option here could be an appointed NGO material, relatively isolated an integrated community education programme particularly communities arising from addressing all potential social impacts identified children; access to internet and in this table. cyberbullying. use of social media among young people.

WHEN/ PARAMETERS POTENTIAL IMPACT MONITORING FREQUENCY/ OUTPUT IMPLEMENTATION SUPERVISION DURATION Cost to end-users Concern about cost of New internet availability would be of little benefit As required Periodically Service provider Regulator internet for users and if people cannot access it for a reasonable price. their ability to afford related equipment. if people cannot afford the internet, the cable will not benefit the population.

X. ENVIRONMENT MITIGATION PLAN (ESMIT) REPORTING

42. The Environmental and Social Management Plan (ESMP), is organized into two cross- referenced tables; namely the Environmental Mitigation table (ESMiT) and monitoring table (ESMoT) provided in Tables 9.1 & 9.2. These two tables list in detail the mitigation measures and monitoring actions that the Executing Agency (ACL) has implemented across the following periods of the Project:

(i) Pre-construction period (ii) Construction period (iii) Operational period

43. This section reports on the ESMiT against activities undertaken during the Pre- construction and Construction stages for the Project. The status of compliance against the mitigating actions, and evidence of, is provided in Table 10.1 below.

Table 10.1: Environmental and Social Impact Mitigation Table (ESMiT) – Status of Compliance TIMING/ IMPLEMENTA SUPERVISI PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION STATUS DETAILS DURATION TION ON 1.0 PRE-CONSTRUCTION PERIOD 1.1 Ecological Environment Ecological Disturbance of Prepare routing report based on Subtidal, Prior to start Cable Laying Project Compliant Pre-Survey route Environment marine, terrestrial & detailed design demonstrating Intertidal & of Contractor Manager completed by CLC. freshwater organisms avoidance of significant habitat terrestrial Construction (CLC) & TIM and habitats areas cable route Reef Damage to coral In contract specifications instruct Subtidal & Construction CLC, TIM, Project Compliant Pre-survey route Communities assemblages cable survey team to survey cable Intertidal contract contract Manager completed by CLC. alignment for coral outcrops, and cable route documents specialist & design alignment to avoid. Project Manager

Species Disturbance of Contract specifications to include Subtidal & Construction CLC, TIM, TIM Compliant Clause 11.1.22 in CLC potentially at marine cetaceans best practice for operating Intertidal contract contract contract. risk (whales, and turtles vessels in proximity to marine cable route documents specialist dolphins, mammals as included in the Code turtles) of Environmental Practice (COEP) document. 1.2 Socio-Economic Environment Community Misconceptions Specify in contract docs that at Cook Islands Before civil Project CLC Compliant Monitored by Project Information raising people’s fears least one community consultation work begins Manager & Manager during weekly regarding project prior to commencement of civil and during at TIM meetings. Extract of footprint and potential works and during construction to regular minutes: Appendix 1 damages to marine reduce concerns about intervals food supply. construction impacts. Community briefings conducted. Records of attendance: Appendix 2

Community Minor Establishment of grievance Cook Islands Before civil Project Project Compliant GRM published in EIA Grievances concerns/issues redress mechanism (GRM) prior works begin Manager Manager document/environment developing to commencement of civil works management plan. community and making this known to villages Compliance with this is resentment due to during follow up meetings before stipulated in CLC unaddressed project the work begins. contract with SubCom related concerns LLC Clause 16.3.7

TIMING/ IMPLEMENTA SUPERVISI PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION STATUS DETAILS DURATION TION ON Access during Failure of contractors Contract specs to include Residents Before civil Project Project Compliant Compliance with this is landside to do front haul instruction re full rehabilitation with access works begin Manager Manager stipulated in CLC trenching trenching work with immediately after trenching affected by contract with SubCom minimal damage, completed. Develop protocol to trenching LLC Clause 16.3.7 impact on existing provide notice of access services and access restrictions, comprising the restrictions to following: property • Notification of roadside residents by letter providing project details, potential access restrictions and likely timing of activities; • On-site meetings with affected residents (if requested). Develop a specific procedure, in consultation with hospital management, to ensure emergency access is maintained to local Hospital. 2.0 CONSTRUCTION PERIOD 2.1 Ecological Environment Reef Disturbance of coral Contractor(s) to adhere to Off & Inshore When work CLC, TIM, Project Compliant Installed as per Communities reef communities avoidance rule and lay cable coastal areas is being contract Manager specifications. Verified along surveyed route, as per undertaken specialist & by post installation cable-laying specification, thus Project diver survey. avoiding coral outcrops. Manager Cable placement in to be diver- assisted to avoid significant ecological features such as corals. Species of Entanglement in Control cable tension so that laid Oceanic When work CLC, TIM, TIM Compliant Installed as per survey special Interest cable risk for deep cable conforms to undulations of deep-sea is being contract route specifications. – Cetaceans diving cetaceans seabed as per cable laying areas. undertaken specialist specification and-or provide anchors if needed. 2.2 Socio-Economic Environment

TIMING/ IMPLEMENTA SUPERVISI PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION STATUS DETAILS DURATION TION ON Coastal Damage to local As per the contract specifications, Offshore & When work CLC Project Compliant No entanglement of Resource nearshore fishing contractor is to confine cable nearshore is being Manager fishing gear, Users – grounds or introduce installation activities to a narrow Coastal undertaken installation works subsistence greater chances of corridor, restore beach area when areas. completed in short and artisanal gear entanglement finished and confine activities to period of time (1 day), fisheries short a period as possible. beach area restored. Request Fisheries authorities to advise local fishers of cable laying activities, dates, and avoidance measures. Consider placing markers along cable line in shallow (<10 m) waters. Fishing vessel Potential impact on Residents/Fishers to be notified in Offshore & When work CLC Project Compliant Public notice issued activity in existing recreational advance – adopt notification nearshore is Manager nearshore and commercial protocol based around advice to Coastal undertaken. coastal vessel activity Government areas. environment Coastal Damage to ships Ensure shipping notice is issued, Offshore and When work CLC & TIM Project Compliant Shipping notice shipping – through cable warning of cable-laying, dates, inshore areas is Manager issued. No damage to commercial entanglement. and safe clearance for other undertaken. ships through cable shipping and Disruption to shipping activities. entanglement. ports during cable laying. Request Port Authority to advise local shipping of laying activities and avoidance measures. Contractors to provide written statement to TIM that marine navigation lights and other national maritime measures are closely followed by contractors’ vessels at all times. Land Use Detour from agreed Consult Government on progress Various When work CLC Project Compliant Non-applicable. cable alignment of work and cable alignment with is Manager Agreed cable the objective of informing all undertaken. alignment adhered to. interested people on the work and general alignment location and methods to be used. Access to Temporary loss of Consult with Government During cable When work CLC Project Compliant Public notice issued; fishing grounds local communities’ laying is Manager installation works access to fishing undertaken. completed in short period of time (1 day).

TIMING/ IMPLEMENTA SUPERVISI PARAMETERS POTENTIAL IMPACT MITIGATION MEASURES LOCATION STATUS DETAILS DURATION TION ON grounds during cable laying Earthworks Loss of or Chance findings of heritage During cable When work CLC Project Compliant No recreational & activities disturbance to resources trigger “Chance Finds laying is Manager heritage resources potential recreational Procedure”. undertaken. identified during & heritage resources planning stages. No reported Chance Finds during works. Inadequate TIM and CLC fail to TIM and CLC, prior to start of Various At start of CLC & TIM Project Compliant No instances of non- information include Government work, present draft plan to construction Manager compliance. disclosure in final alignment Government and seek input and planning and agreement on final alignment decision making plan, TIM.

XI. ENVIRONMENT MONITORING PLAN (ESMOT) REPORTING

44. The Environmental and Social Management Plan (ESMP), organized into two cross- referenced tables; namely the Environmental Mitigation table (ESMiT) and monitoring table (ESMoT) provided in Tables 7.1 & 7.2. These two tables list in detail the mitigation measures and monitoring actions that the Executing Agency (ACL) has implemented, across the following periods of the Project:

(i) Pre-construction period (ii) Construction period (iii) Operational period

45. This section reports on the ESMoT against activities undertaken during the Pre- construction and Construction stages for the Project. The status of compliance against the mitigating actions, and evidence of, is provided in Table 10.1 below.

Table 10.1: Environmental and Social Impact Monitoring Table (ESMoT) – Status of Compliance WHEN/ POTENTIAL IMPLEMENTAT SUPERVISIO PARAMETERS MONITORING FREQUENCY/ IMPACT ION N STATUS DETAILS DURATION 1.0 PRE-CONSTRUCTION PERIOD 1.1 Ecological Environment Ecological Environment Disturbance of Prepare routing report based on Prior to CLC & TIM Project Compliant Pre-Survey route marine & terrestrial detailed design demonstrating construction Manager completed by CLC. organisms and avoidance of significant habitat areas habitats Reef Communities Destruction of coral In contract specifications instruct cable Prior to CLC, TIM, Project Compliant Pre-Survey route assemblages survey team to survey cable alignment construction contract Manager completed by CLC. for coral outcrops, and design specialist & alignment to avoid. PMU Species potentially at Disturbance of Contract specifications to include best Prior to CLC, TIM, Project Compliant Clause 11.1.22 in CLC risk (whales, dolphins, marine cetaceans practice for operating vessels in construction contract Manager (SubCom LLC) contract. turtles) and turtles proximity to marine mammals specialist, PMU 1.2 Socio-Economic Environment Community Information Misconceptions Specify in contract docs that at least Prior to Project CLC Compliant Community briefings raising people’s one consultation with Community construction Manager& TIM conducted. fears regarding leaders prior to commencement of civil project footprint works and during construction to and potential reduce concerns about construction damages to marine impacts is required. food supply. Community Grievances Minor Establish of GRM prior to Prior to Project Project Compliant GRM published in EIA concerns/issues commencement of civil works and construction Manager Manager document/environment developing making this known to villages during management plan. community follow up meetings before the work Compliance with this is resentment due to begins. stipulated in CLC unaddressed contract with SubCom project related LLC Clause 16.3.7. No concerns instances of GRM requiring Project Manager intervention raised.

WHEN/ POTENTIAL IMPLEMENTAT SUPERVISIO PARAMETERS MONITORING FREQUENCY/ IMPACT ION N STATUS DETAILS DURATION Access during landside Failure of Contract specs to include instruction Prior to Project Project Compliant Minimal damage & trenching contractors to do concerning full rehabilitation construction Manager Manager restrictions to property trenching work with immediately after trenching completed access experienced. minimal damage in one area. Rehabilitation and access Develop notification protocol to immediately actioned restrictions to provide notice of access restrictions, after trenching property comprising the following steps: completed. • Notification of the roadside residents by letter providing details of the project, potential access restrictions and likely timing of activities; and • On-site meetings with affected residents (if requested). Develop a specific procedure, in consultation with hospital management, to ensure emergency access is maintained to local Hospital. Front haul cable install Disruption to Design to avoid interference with Prior to Telecom &TIM Project Compliant Instance of interference affecting existing existing services existing services construction Manager with water supply services reported & restored immediately on empty lot. No consumer/community impacting interference with services. 2.0 CONSTRUCTION PERIOD (Impacts associated with the work) 2.1 Ecological Environment Reef Communities Disturbance of Contractor(s) to adhere to avoidance During cable CLC, TIM, Project Compliant Diver assisted cable coral reef rule and lay cable along surveyed installation contract Manager placement executed. communities route, as per cable-laying specialist specification, thus avoiding coral reefs and outcrops. Cable placement in to be diver- assisted to avoid coral heads.

WHEN/ POTENTIAL IMPLEMENTAT SUPERVISIO PARAMETERS MONITORING FREQUENCY/ IMPACT ION N STATUS DETAILS DURATION Species of special Entanglement in Control cable tension so that laid cable During cable CLC, TIM, PMU & TIM Compliant Cable tension control Interest – Cetaceans cable risk for deep conforms to undulations of seabed as installation contract effective. diving cetaceans per cable laying specification and-or specialist provide anchors if needed. 2.2 Socio-Economic Environment Coastal Resource Users Damage to local As per the contract specifications, During cable CLC Project Compliant Coastal area cordoned – subsistence and nearshore fishing contractor is to confine trenching installation Manager off during site works. Site artisanal fisheries grounds or activities to as narrow a corridor as restored same day and introduce greater possible and restore site when finished no open trench left chances of gear and confine trenching/laying activities unattended entanglement to as short a period as possible Request Fisheries authorities to advise local fishers of cable laying activities, dates, and avoidance measures. Consider placing warning markers along cable line in shallow (<10 m) waters. Fishing vessel activity in Potential impact on Residents to be notified in advance – During cable CLC Project Compliant Public notice issued. nearshore coastal existing adopt notification protocol based installation Manager environment recreational and around providing advice. Written commercial vessel notification to residents and on-site activity. meetings if requested. Coastal shipping – Damage to ships Ensure shipping notice is issued, During cable CLC & TIM Project Compliant Shipping notice issued commercial shipping and through cable warning of cable-laying, dates, and installation Manager by CLC ports entanglement. safe clearance for other activities. Disruption to Request Port Authorities to advise local shipping during shipping of laying activities and cable laying. avoidance measures. Land Use Detour from agreed Conduct a series of consultations on During cable CLC Project Compliant No unplanned detour cable alignment progress of work and cable alignment installation Manager from agreed cable with the objective of informing all alignment. interested people on the work and general alignment location and methods to be used. Access Temporary loss of Consult with Government agencies During cable CLC Project Compliant Traffic Management Plan local communities’ installation Manager executed. No incidents access to fishing reported.

WHEN/ POTENTIAL IMPLEMENTAT SUPERVISIO PARAMETERS MONITORING FREQUENCY/ IMPACT ION N STATUS DETAILS DURATION grounds during cable laying Earthworks activities Loss of or Chance findings of heritage resources During cable CLC Project Compliant Compliant. No identified disturbance to trigger “Chance Finds Procedure”. installation Manager recreational & heritage potential resources. Chance Finds recreational & procedure not activated. heritage resources Disturbance of Monitoring to ensure no physical During cable CLC Project Compliant Trenching work did not grave located on disturbance of grave installation Manager disturb identified grave. Te Au Road (Rarotonga) TIM and CLC fail to TIM and CLC, prior to start of work, During cable CLC & TIM Project Compliant No instances of non- include present draft plan and seek input and installation Manager compliance reported. Inadequate information Government in final agreement on final alignment plan, etc. disclosure alignment planning and decision making

XII. SUMMARY AND CONCLUSION

46. The works undertaken to analyze the potential cable alignment, BMH location, front haul corridor and CLS has resulted in an approach that assisted in minimizing the environmental and social impacts.

47. The installation and construction areas were located where the terrestrial ecology has little or no conservation interest, there has been no displacement of tenants or other land uses, and no assets or livelihoods have been affected.

48. The comprehensive Environment and Social Management Plan (ESMP) identifies potential social and community issues, each of which is addressed by way of mitigation and monitoring in both the ESMiT table and ESMoT table.

49. Effective management and monitoring against the identified areas of the ESMP has resulted in the Project construction and installation works being conducted with minimal impact on the environment.

APPENDIX 1:

Extract from Project meeting minutes capturing the meeting with landowners:

APPENDIX 2:

Community consultation records:

Photos of community meetings at Betela Meeting House (Top Left), Sinai Hall (Top Right), Muri Meeting House (Middle Left), Arutanga Meeting House (Middle Right) and Vaipae Community Sports Centre (Bottom)

# Location Raised by Question/feedback Response Date 1 Betela Hall ? Where is cable to be located? Explanation of route provided 10-06-19 2 ? Is cable harmful? Completely inert, No EMFs, able to be colonized over time 10-06-19 ? EIA review NES has reviewed draft. Available for public comment once draft 3 report lodged. 10-06-19 ? Land compensation CLS on government land, easement for cable across private land being negotiated, Land to MHWS is crown and road ROW. no displacement of tenants nor land use as both easement pass across 4 unused land 10-06-19 5 ? Can competitors use cable? Yes, that is the idea for multiple retailers 10-06-19 6 ? Will competitors dig up road to lay more cable? It is the intention that existing infrastructure is used 10-06-19 7 ? Is Cook Islands big enough for competition? Yes, based on experience with other island nations 10-06-19 ? Have other alignment options been looked at? Yes, no fishing in channel, fishers on reef between channel north to 8 Ra'ui 10-06-19 ? What about other islands? Tough challenge, not as part of this Project. Continued connectivity 9 via satellite 10-06-19 10 ? Will cable be a monopoly? It will likely outcompete satellite 10-06-19 11 ? What is design life? 25 years 10-06-19 12 ? CLS site has 20 yrs. left on lease No response given 10-06-19 13 ? Government needs to act for people No response given 10-06-19 ? Total costs of Project? Each project partner is responsible for some elements of project, so we do not have a figure for the whole project cost. We do know ACL's costs, which are a maximum of US$15m from ADB and 14 NZ$15m from MFAT 10-06-19 ? Have costs between satellite and cable been compared? Yes, this has been done. Modelling on commercials are positive 15 10-06-19 16 ? Other retailers yet? What’s plan B? No other retailers yet. 10-06-19 17 ? Aitutaki water project. Can same trench be used? ACL to explore 10-06-19 18 ? Other technologies for outer island connectivity Additional tech needs to be explored. 10-06-19 1 Sinai Hall Maria Henderson origin of Manatua name? Unknown 11-06-19 2 Moana will the cable be buried? where it can be it will 11-06-19 being engineered to be as structurally sound as possible, putting all mitigating factors in where able and reasonable, also plans to repair if it does include involves potential subscribing to south pacific 3 Tui Tonga cable cut, will it happen here? scheme 11-06-19 4 Phillip Strickland Has there been a study of the beach profile? yes 11-06-19 5 Phillip Strickland How deep will the cable go at the BMH? 1.5m, sink in the sand 11-06-19 6 Phillip Strickland Have you spoken to the arona mana? yes 11-06-19 7 William costing's, the spurs, how much will CI be paying? explained funding and how it is being spent 11-06-19 8 William what is the capacity of the cable? 11-06-19 9 Phillip Maintenance costs 11-06-19 10 William cost per mb explained wholesaler 11-06-19 11 Papa William what is the shareholding 100% government owned 11-06-19 12 Papa William will taxpayers get dividends no 11-06-19 13 Papa William will bluesky no 11-06-19 14 Papa William shipping investments no response required or given 11-06-19 15 Papa William why isn't the government funding other things no response required or given 11-06-19 16 William Telecom owns the cable lines around not ACL referenced the Telecommunications act 11-06-19 what will be put in place to insure what happens in Tonga does explained actions we would take re: subscribing to scheme and 17 Papa William not happen here engineering it so the likelihood of it happening is low 11-06-19 Can you include the pictures you have on your slides in your Pictures in presentation are extracted from 2016 survey report which 18 Phillip EIA is attached to EIA 11-06-19 19 Papa William what is the cost of the cable? explained funding and how it is being spent 11-06-19 20 Papa William what are the costs for the Raro components explained funding and how it is being spent 11-06-19 21 Papa William cost for Northern group? n/a - not connecting to Northern group 11-06-19 22 Papa William projections for the next 5 years? do not have 11-06-19 23 Papa William are all other countries government or private? No 11-06-19 24 Papa William were we asked whether we wanted this cable? it is a necessity for the island 11-06-19 25 Francis Tamangaro grateful for the cable finally coming through no response required or given 11-06-19 26 Francis Tamangaro request for ACL to meet with Airport authorities agreed to arrange 11-06-19 27 Muri Meeting House Imogen Ingram Hacking over cable satellite cyber security Cost to update virus protection should be cheaper 11-06-19 28 Imogen Ingram Timing - if its late do we pay? No - subcom contract 11-06-19 What we have read of the government act, liberating the market, goal 29 Imogen Ingram Regulator - how will it achieve with only one retailer? is to create competition 11-06-19

have seen it impact other towns with similar population positively - 30 Imogen Ingram size of country too small? Ranulf spoke about the improvements seen in Cornwall 11-06-19 31 Noeline can it withstand a cyclone? yes 11-06-19 32 Noeline cut the road, can you do before the new road is done? referenced ICI act 11-06-19 33 Imogen Ingram Our regulator, how will they comply? Telecommunications Act 11-06-19 34 Imogen Ingram What do they do in the EU? explained 11-06-19

in our opinion, having faster cheaper internet will allow users here to 35 Imogen Ingram The hackers will be faster better protect themselves from viruses and malware content 11-06-19 What is our backup strategy? Why aren't we doing a second 36 Matt cable at the same time? costs for second cable not in scope 11-06-19 concerns of physical damage to the cable, will it rub and 37 Noeline move? no 11-06-19 38 Noeline what about the idiots here who vandalize? will engineer to mitigate, references the iron clad sleeve 11-06-19 39 Will ACL be the wholesaler? Yes, we need to be cheaper than O3B 11-06-19

40 Noeline Will it be not for profit? No. We need to build a fund for cable cut and loan repayments 11-06-19 41 Matt But Bluesky own the cables anyway referenced telecommunications act liberalizing the market 11-06-19 42 Eric Short Is the 30million just for our part or the whole cable? explained funding and Cook Islands costs 11-06-19 the cable is the key enabler. All the other pieces of the puzzle are 43 Michael Tavioni Is it going to be faster, cheaper, free internet? required 11-06-19 Satellite biosecurity, economic concern, where does the cable 44 Arutanga Hall Richard Thomas originate from? explained connectivity 12-06-19 45 Richard Thomas security issues virus protection 12-06-19 End of old airport runway and along road up to hospital - referenced 46 Mark Trench, where is it going to be dug? Aitutaki map slide 12-06-19 47 Mark where will it run? along Amuri 12-06-19 48 Nick Henry Where will it run in terms of location through CI? explained branching 12-06-19 49 Nick Henry Which company will own the land base cable? ACL 12-06-19 Business Plan for ACL is there enough and to replace the 50 Nick Henry cable? 12-06-19 Damage of the road? Fiber at same time, cooper, electrical 51 Nick Henry cable 12-06-19 52 Mark CLS battery power? 12-06-19 53 Mark Will it run slower once it hits copper? 12-06-19 Will there be compensation for the land you are using? I No, that is not correct. We are working with the landowners to do heard the landowners in Rarotonga are receiving what we can to jointly protect the land our cable comes in in 54 Teina Bishop compensation Rarotonga from erosion 12-06-19

Social impact. We paid for the pipes ourselves. Privately

owned service lines. May impact people who have their power 55 Helen Tepaki cut off. Having services connected on the same day? 12-06-19 What are you providing to address it? So this cable can go in We are still in negotiations with potential contractors. We will have 56 Helen Tepaki and we do not suffer for it? one ACL person on site to supervise 12-06-19 Talk of intention for the 25 years. What happens if the 57 Helen Tepaki government tries to sell in future The idea is to provide cheapest internet possible 12-06-19 58 Helen Tepaki Share? Who owns? Government owns all the shares 12-06-19

# Location Raised by Question/feedback Response Date explained actions we would take including engineering the cable to 59 Helen Tepaki What happens if the cable is damaged mitigate all potential threats to the best of our ability 12-06-19 Vandalism? How safe is it from people? How are we 60 Vaipae Des Clarke protecting it from deliberate damage Engineering to make it safe from others 13-06-19 Not professional to speak in English, should speak Maori. The route your explaining is different from what we agreed to 2 61 ? years ago 13-06-19 62 Enua How do we know you have a plan 13-06-19 63 Tiraa Arere This is a good thing no response required or given 13-06-19 64 ? This is a good thing no response required or given 13-06-19 65 ? Are you going to fix the road? any damage will be fixed 13-06-19 What happens from the Hospital (CLS) to households? Who 66 ? owns the connection from there? 13-06-19 67 Po'o Bishop Can we fish? Yes 13-06-19