Public Disclosure Authorized

GOVERNMENT OF THE GAMBIA

MINISTRY OF FINANCE AND ECONOMIC AFFAIRS Public Disclosure Authorized MINISTRY OF INFORMATION AND COMMUNICATION INFRASTRUCTURE GAMBIA TELECOMMUNICATIONS COMPANY LIMIITED

West Africa Communications Infrastructure Programme (WARCIP) in The Gambia

ACE Submarine Cable Project Public Disclosure Authorized Environmental and Social Impact Assessment (ESIA)/ Environmental and Social Management Plan (ESMP)

Draft Report

Public Disclosure Authorized

SAL Consult Limited, P O Box GP20200, Accra May 2011

PROJECT TEAM

Name Position Qualification and Experience Contribution to Report Seth A Larmie Environmental M.Sc. (Applied Science) VUB Brussels Quality Assurance, Impact Management B.Sc. (Chemical Engineering) UST-Kumasi analysis Expert/Team Leader Richmond Environmental MPhil Environmental Science, University of Stakeholder consultations, Yeboah Management Expert Ghana Review of relevant socio- Amoako B.Sc (Hons) Chemistry, University of Cape economic and environmental Coast Baseline literature, Analysis of Dip Ed University of Cape Coast impacts and alternatives, drafting of report Francis K E Oceanographer and Ph.D. Fisheries Science, University of Ghana Coastal zone management and Nunoo (Dr) Coastal Zone M.Phil. Marine Sciences and Coastal marine ecology studies; Management Expert Management, University of Newcastle, Impact analysis on marine Newcastle upon Tyne resources; stakeholder MSc. Tropical Coastal Management, University consultations; review of relevant of Newcastle, Newcastle upon Tyne, UK. literature BSc. (Hons) Zoology with Botany. University of Ghana. Olivia Ahlijah Stakeholder consultations, Social (Mrs) Associate Consultant, M Phil (Social Anthropology), University of studies, Social Impact Sociologist Oslo, Norway Assessment and Resettlement Plan Akosua Stakeholder identification and Assistant Consultant, Agyeiwaa BSc (Water and Sanitation), University of Cape consultation; Field and baseline Socio-economic Opoku-Darko Coast data collection; Literature Environment (Ms) reviews

Email: [email protected]

SAL GOTG/ GAMTEL

Table of Contents LIST OF ACRONYMS AND ABBREVIATIONS ...... VII

EXECUTIVE SUMMARY ...... IX

1.0 INTRODUCTION ...... 1

1.1 PROJECT BACKGROUND ...... 1 1.2 PURPOSE AND OBJECTIVES OF THE ENVIRONMENTAL ASSESSMENT ...... 2 1.3 SCOPE OF SERVICES ...... 3 1.4 APPROACH AND METHODOLOGY ...... 3 1.5 LEGAL FRAMEWORK FOR PROJECT DEVELOPMENT ...... 4

2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 5

2.1 POLICY ON INFORMATION COMMUNICATIONS TECHNOLOGY ...... 5 2.2 RELEVANT LEGAL AND REGULATORY FRAMEWORK ...... 5 2.3 INSTITUTIONAL AND ADMINISTRATIVE FRAMEWORK...... 7 2.4 PROJECT APPROVAL REQUIREMENTS ...... 13 2.5 RELEVANT INTERNATIONAL INSTITUTION- WORLD BANK SAFEGUARD POLICIES ...... 13 2.5.1 OP/BP 4.01: Environmental Assessment ...... 14 2.5.2 OP/BP 4.12: Involuntary Resettlement ...... 14 2.6 INTERNATIONAL LAW AND AGREEMENTS ...... 14 2.6.1 International Maritime Organization...... 14 2.6.2 Legal Boundaries of the Ocean ...... 15 2.6.3 Marine Regulations on Submarine Cables ...... 17

3.0 PROJECT DESCRIPTION ...... 18

3.1 PROJECT BACKGROUND ...... 18 3.2 PROJECT JUSTIFICATION ...... 19 3.2.1 Connectivity challenges in The Gambia ...... 19 3.2.2 Existing Data Transmission Capacity in West Africa ...... 20 3.3 BENEFITS OF THE PROJECT ...... 20 3.3.1 Primary Benefits ...... 20 3.3.2 Indirect Benefits ...... 21 3.4 PROJECT COMPONENTS ...... 21 3.4.1 The submarine cable system ...... 22 3.4.2 Description of Marine Operations ...... 23 3.4.3 Proposed Infrastructure Installations ...... 28 3.5 PROJECT SCHEDULE ...... 31

4.0 ALTERNATIVE ANALYSIS ...... 32

4.1 TECHNOLOGY ALTERNATIVES ...... 32 4.2 ROUTING ALTERNATIVES ...... 33 4.3 CABLE LAYING OPTIONS- BURIAL AND NON-BURIAL ...... 33 4.4 CABLE TYPE OPTIONS ...... 33

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4.5 LANDING STATION SITE OPTIONS ...... 34 4.5.1 The Brusubi Phase III Institutional Area ...... 35 4.5.2 The BMH Site Behind Lemon Creek Hotel ...... 36 4.6 NO PROJECT SCENARIO ...... 36

5.0 ENVIRONMENTAL AND SOCIO-ECONOMIC BASELINE CONDITIONS ...... 37

5.1 LOCATION AND SIZE ...... 37 5.1.1 The Cable Location ...... 38 5.2 THE ATMOSPHERIC ENVIRONMENT ...... 39 5.2.1 Climate ...... 39 5.2.2 Noise Assessment...... 45 5.3 THE LAND ENVIRONMENT ...... 46 5.3.1 Relief/Topography ...... 46 The Valley Bottom ...... 46 Dissected plateau with sandy hills ...... 47 Sandstone Plateau ...... 47 5.3.2 Geology and Soils ...... 47 5.3.3 Biodiversity (flora and Fauna) ...... 47 5.4 OCEANOGRAPHY ...... 48 5.4.1 General Conditions ...... 48 5.4.2 Physical Oceanography ...... 48 5.4.3 Biological Oceanography ...... 52 5.4.4 Site Specific Oceanographic Information ...... 62 5.5 SOCIO-ECONOMIC ENVIRONMENT ...... 63 5.5.1 Population ...... 63 5.5.2 Educational Attainment ...... 64 5.5.3 Ethnicity ...... 65 5.5.4 Religious Affiliation ...... 65 5.5.5 Economic Activities ...... 65 5.5.6 Average Monthly Income ...... 66 5.5.7 Profile of Project Affected Persons (PAPs) ...... 67

6.0 STAKEHOLDER CONSULTATIONS, DISCLOSURE AND GRIEVANCE MANAGEMENT ...... 69

6.1 STAKEHOLDER CONSULTATIONS ...... 69 6.1.1 Objectives of Stakeholder Consultations ...... 69 6.2 STAKEHOLDER IDENTIFICATION AND DISCUSSIONS ...... 69 6.3 DISCLOSURE OF THE ESIA/ ESMP ...... 74 6.4 GRIEVANCE REDRESS MECHANISM ...... 74

7.0 POTENTIAL IMPACT ASSESSMENT ...... 76

7.1 DETERMINATION OF ENVIRONMENTAL/SOCIAL SIGNIFICANCE OF IMPACTS ...... 76 7.2 CATEGORIES OF IMPACT SIGNIFICANCE ...... 76 7.3 CONSTRUCTION PHASE ADVERSE IMPACTS/ ISSUES ...... 77

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7.3.1 Potential Adverse Environmental Impacts and Mitigation Measures ...... 77 7.3.2 Potential Adverse Social Impacts/ Issues ...... 80 7.4 OPERATION PHASE ADVERSE ENVIRONMENTAL/SOCIAL IMPACTS ...... 81 7.4.1 Landing Station ...... 81 7.4.2 Submarine Cable ...... 82

8.0 RECOMMENDED MITIGATION MEASURES FOR ADVERSE IMPACTS ...... 83

8.1 MITIGATION MEASURES FOR CONSTRUCTION PHASE IMPACTS ...... 84 8.1.1 Mitigating Potential Environmental Impacts /Concerns ...... 84 8.1.2 Mitigating Potential Social Impacts/ Concerns ...... 87 8.2 MITIGATION MEASURES FOR OPERATIONAL PHASE IMPACTS ...... 88 8.2.1 Minimizing Air Pollution and Noise Nuisance ...... 88 8.2.2 Minimizing Water Pollution and indiscriminate disposal of waste ...... 89 8.2.3 Security risk ...... 89 8.2.4 Managing Occupational Health and Safety Risks ...... 89 8.2.5 Emergencies ...... 89

9.0 ENVIRONMENTAL AND SOCIAL ACTION PLANS AND PROGRAMMES...... 90

9.1 ENVIRONMENTAL POLICY ...... 90 9.2 HEALTH AND SAFETY POLICY ...... 91 9.3 RESPONSIBILITIES ...... 91 9.3.1 Role of GAMTEL/PIU ...... 91 9.3.2 Appointment of an Environmental and Safety Coordinator (ESC) ...... 91 9.3.3 Contractor’s Role ...... 92 9.4 CONTRACTOR SPECIFIC ACTION PLANS ...... 92 9.5 AWARENESS CREATION AND TRAINING ...... 93 9.5.1 During construction phase ...... 93 9.5.2 During Operation Phase ...... 93 9.6 PUBLIC PARTICIPATION/INVOLVEMENT ...... 94 9.7 MONITORING PROGRAMME ...... 94 9.8 REPORTING ...... 94 9.9 EMERGENCY PREPAREDNESS AND RESPONSE PLAN ...... 95 9.9.1 Responsibilities...... 95 9.9.2 Notification ...... 95 9.9.3 Fire/emergency preparedness ...... 95 9.9.4 Fire Response Actions ...... 96 9.9.5 General Evacuation Procedures ...... 97 9.10 ENVIRONMENTAL AND SOCIAL ACTION PLANS ...... 97 9.11 UNCERTAINTY AND CHANGE MANAGEMENT...... 97

10.0 INSTITUTIONAL CAPACITY FOR ESMP IMPLEMENTATION...... 105

10.1 INSTRUCTIONAL COLLABORATION ...... 105 10.1.1 GAMTEL/PIU ...... 105

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10.1.2 NEA ...... 105 10.1.3 GPA ...... 105 10.2 CAPACITY BUILDING REQUIREMENT ...... 106

11.0 DECOMMISSIONING ...... 107

11.1 WORK CAMP FACILITIES ...... 107 11.2 CABLE LANDING STATION AND OTHER FACILITIES ...... 107 11.3 SUBMARINE CABLE ...... 107

12.0 CONCLUSION ...... 108

13.0 REFERENCES ...... 109

ANNEXES ...... 110

LIST OF TABLES TABLE 1: PROJECT APPROVAL REQUIREMENTS ...... 13 TABLE 2 COMPARING STUDY OF THE ADVANTAGES OF BURYING CABLES AND LAYING DIRECTLY ON SEABED ...... 33 TABLE 3 SUBMARINE TELECOMMUNICATION CABLE TYPES ...... 34 TABLE 4: STATISTICAL SUMMARY OF RAINFALL FOR THE PERIOD 1981 - 2010 ...... 41 TABLE 5: STATISTICAL SUMMARY OF TEMPERATURE DATA FOR THE PERIOD 1981 - 2010 ...... 42 TABLE 6STATISTICAL SUMMARY OF MEAN RELATIVE HUMIDITY DATA FOR THE PERIOD 1981 - 2010 ...... 43 TABLE 7: STATISTICAL SUMMARY OF WIND SPEED DATA FOR THE PERIOD 1981 - 2010 ...... 44 TABLE 8: STATISTICAL SUMMARY OF SUNSHINE DATAL FOR THE PERIOD 1981 - 2010 ...... 44 TABLE 9 RESULTS OF NOISE LEVEL ASSESSMENT ...... 46 TABLE 10: SEDIMENT TRANSPORT BY LOCAL STREAMS ...... 50 TABLE 11: UPDATED CETACEAN SPECIES CHECK LIST FOR THE GAMBIA (FROM WAFCET 2) ...... 54 TABLE 12: LIST OF SPECIES CAUGHT IN BEACH SEINE GEAR AT BIJILO BEACH ...... 58 TABLE 13: SUMMARY OF STAKEHOLDER CONSULTATIONS ...... 70 TABLE 14: GRIEVANCE REDRESS MANAGEMENT ...... 75 TABLE 15: POTENTIAL ADVERSE ENVIRONMENTAL IMPACTS/ ISSUES ...... 77 TABLE 16 POTENTIAL ADVERSE SOCIAL IMPACTS/ ISSUES ...... 80 TABLE 17: MITIGATION MEASURES FOR POTENTIAL ENVIRONMENTAL IMPACTS FOR THE CONSTRUCTION PHASE ...... 84 TABLE 18: MITIGATION MEASURES FOR POTENTIAL ENVIRONMENTAL IMPACTS FOR THE CONSTRUCTION PHASE ...... 87 TABLE 19 ENVIRONMENTAL ACTION PLAN ...... 98 TABLE 20 SOCIAL ACTION PLAN ...... 102

LIST OF FIGURES FIGURE 1 LEGAL BOUNDARIES OF THE OCEAN FROM TERRITORIAL SEA TO EXCLUSIVE ECONOMIC ZONE AND ONTO THE HIGH SEAS (FIGURES IN PARENTHESIS REFER TO TREATY ARTICLES) ...... 16 FIGURE 2: PROPOSED ACE SUBMARINE CABLE CONFIGURATION SHOWING THE LANDING POINTS ...... 18 FIGURE 3: ACE CABLE ROUTE FROM THE BMH TO THE CLS ...... 21 FIGURE 4: TYPICAL SUBMARINE CABLE SYSTEM ...... 22 FIGURE 5: ILLUSTRATION OF CABLE DESIGN AND TYPES ...... 23 FIGURE 6: EXAMPLES OF MARINE PLOUGHS ...... 26 FIGURE 7: PLAN OF THE SABLE STATION ...... 29 FIGURE 8: BLOCK PLAN OF THE CLS ...... 30 FIGURE 9: COMPARISON BETWEEN CABLES AND SATELLITES ...... 32

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FIGURE 10: THE LOCATION OF THE BMH AND CLS ...... 35 FIGURE 11: MAP OF THE GAMBIA ...... 37 FIGURE 12: ADMINISTRATIVE MAP OF THE GAMBIA ...... 38 FIGURE 13: THE TERRESTRIAL CABLE ROUTE ...... 39 FIGURE 14: GRAPHICAL PRESENTATION OF MEAN MONTHLY RAINFALL ...... 41 FIGURE 15: GRAPHICAL ILLUSTRATION OF DAYTIME TEMPERATURE ...... 42 FIGURE 16: GRAPHICAL PRESENTATION OF NIGHT-TIME TEMPERATURE...... 43 FIGURE 17: GRAPHICAL PRESENTATION OF MEAN RELATIVE HUMIDITY DATA ...... 44 FIGURE 18: GRAPHICAL PRESENTATION OF WIND SPEED ...... 44 FIGURE 19: GRAPHICAL PRESENTATION OF SUNSHINE DURATION DATA ...... 45

LIST OF PLATES PLATE 1 (A & B): THE CLS SITE AT BRUSUBI PHASE III INSTITUTIONAL AREA ...... 35 PLATE 2: THE LEMON CREEK HOTEL AT BIJILO BEACH WITH PROPOSED BMH SITE INDICATED WITH RED ARROW ...... 36 PLATE 3: UPPER SHORE OF BEACH WITH TYPICAL COASTAL SHRUBS AND GRASSES ...... 62 PLATE 4: GENTLY SLOPING BEACH WITH SHOREBIRDS AT THE EDGE OF THE SEA ...... 62 PLATE 5: SHORE BIRDS ENJOYING SMALL WASTEWATER LAGOON AT THE BEACH ...... 62

LIST OF ANNEXES ANNEX 1: COMMUNICATIONS WITH NEA ON PROPOSED ACE SUBMARINE CABLE PROJECT ANNEX 2: CLS SITE DOCUMENTATION PAPERS ANNEX 3: CLIMATIC DATA

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LIST OF ACRONYMS AND ABBREVIATIONS

ACE African Coast to Europe

ARAP Abbreviated Resettlement Action Plan

BMH Beach Manhole

BPEO Best Practicable Environmental Option

BU Branching Unit

CLS Cable Landing Station

EEZ Exclusive Economic Zone

EIA Environmental Impact Assessment

ESIA Environmental and Social Impact Assessment

EMSP Environmental and Social Management Plan

GAMTEL Gambia Telecommunications Company

GOTG Government of The Gambia

ICT Information and Communication Technology

IFC International Finance Corporation

IMO International Maritime Organisation

IUCN International Union for the Conservation of Natural Resources

LGA Local Government Area

MFEA Ministry of Finance and Economic Affairs

MOICI Ministry of Information and Communications Infrastructure

MOP Ministry of Petroleum

MARPOL International Convention for the Prevention of Pollution from Ships

NGOs Nongovernmental Organisations

nmi Nautical mile

NEA National Environment Agency

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NEMA National Environmental Management Act

NOAA National Oceanic and Atmospheric Administration

NRA National Roads Authority

ODS Ozone Depleting Substances

OP Operating Policy

PAPs Project Affected Persons

PCR Physical Cultural Resources

PIU Project Implementation Unit

RAP Resettlement Action Plan

RP Resettlement Plan

SOLAS International Convention for the Safety of life at Sea

UNCLOS United Nations Convention on the Law of the Sea

TANGO The Association of Non-Governmental Organisations

WARCIP West African Regional Communications Infrastructure Program

WB World Bank

WSIS World Summit on the Information Society

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EXECUTIVE SUMMARY

Project Benefits The Government of The Gambia is part of a new submarine cable system which forms part of the West Africa Regional Communications Infrastructure Program being funded by the World Bank. The Project will have direct benefits through increase in available international transmission capacity and lower cost for such access. For existing businesses, increased capacity and lower cost will allow for faster and more reliable transmission for data and voice. Lower entry costs will also facilitate expansion of existing businesses and start-up of new businesses. It could also facilitate increased business cooperation between the consortium countries.

Other indirect social and economic benefits would be associated with the proposed development and these include:  improved educational opportunities through increase in access to information and education resources;  development of a regional sense of community through greater equality of information sharing across geographical regions and across groups in society;  economic benefits from the enhanced opportunities for new and small enterprises that may have previously been excluded from technologies by high costs; and  macroeconomic benefits of the potential expansion of technology-reliant industries in West Africa, such as information technology services and software development businesses.

Purpose of the ESIA/ ESMP The purpose of the ESIA/ ESMP is to provide guidance to the submarine cable-laying and construction contractors, and to the operators of the facilities, on the measures and actions to be taken during implementation and operation of the facilities to eliminate, mitigate, or offset significant adverse environmental and social impacts, or to reduce them to acceptable levels.

Project Components and Locations The main components of the project will comprise of a deep sea cable in the international waters from France to The Gambia; a connecting cable from the submarine or deep sea cable to the shores of The Gambia at Bijilo near Banjul; and a BMH and CLS.

The proposed site for the CLS is in the Brusubi Phase III area about 3km from the Bijilo beach where the BMH will be constructed near the Lemon Creek Hotel. The approximate coordinate of the CLS site is N13o24.785’ and W16o43.126’ and currently fallow while the approximate coordinates of the BMH site is N13o25.205’ and W16o44.242’. There are no permanent structures on the cable route, however about 27no identified PAPs and their properties will be impacted by way of disturbance to their operations or access to their homes. The Kombo Coastal Highway will also be crossed.

Overview of project phase activities

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The major activities under Construction Phase include pre-installation and installation activities; while the major activities under Operation Phase include repair/recovery activities. Pre- installation activities will include a detailed cable route survey to investigate the safest possible environment for the cable and prepare for its installation as well as engineering design and fabrication of the subsea equipment. Installation involves laying of cables on or under seabed along the route determined by the pre-installation survey.

Cable repair and maintenance is required as a result of damage, failure, age /redundancy or clearance of congested routes. As cables reach the end of their design life or become redundant due to technological advances, their removal from the seabed or decommissioning may be considered.

Relevant Legal and Regulatory Framework The relevant regulatory frameworks include:  Constitution of the Republic of the Gambia, 1997;  National Environment Management Act (NEMA), 1994;  Environmental Quality Standards Regulations, 1999;  Wildlife Conservation Act, 1977;  Fisheries Act 2007; and  Public Utilities Regulatory Authority Act, 2001;  International Maritime Organization conventions; and  World Bank safeguards policies.

Stakeholder consultations, disclosure and grievance management Extensive consultations were held with relevant stakeholder as part of the preparation of the ESIA/ ESMP. Key stakeholders contacted include Ministry of Finance and Economic Affairs, Ministry of Information and Communication Infrastructure, GAMTEL), Ministry of Petroleum/ Gambia National Petroleum Corporation, National Environmental Agency, Gambia Ports Authority, Gambia Bureau of Statistics, National Roads Authority, Department of Lands and Surveys, Department of Physical Planning and Housing, Geological Department and The Association of Non-Governmental Organisations among others.

As part of its procedures, NEA was furnished with a completed EIA Form by GAMTEL, and the NEA has formally given the environmental approval for the project based on their assessment. The NEA will also assist in the review and implementation of this ESIA/ ESMP document.

Potential Impacts and Recommended Mitigation Measures The identified potential impacts and the recommended mitigation measures are provided in the tables below for both construction and operation phases of project development. Most of the concerns and impacts will occur during the construction phase, and adequate environmental and safety care is required during this period. During the operational phase there will be no routine maintenance of the cable and will not have much significant adverse impact on the bio-physical and social environment except during cable repairs and recovery.

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Mitigating Potential Environmental Impacts /Concerns during the Construction Phase

Impact issues Description of mitigation measures Construction of Landing Station Facilities Waste disposal Solid waste  Adequate waste reception facilities should be provided at the project sites/camp sites  Final disposal should be at dump sites approved by the LGA Waste oil /fuel . Spent or waste oil from vehicles and equipment should be collected and temporarily stored in drums or containers at site . Waste oil should be disposed off by oil marketing companies or agents approved or recognized and have the capacity to undertake oil disposal

Human waste/liquid waste  Toilet facilities should be provided at or near the site for use by construction workers  It should be a policy that free-range defecation is prohibited and offenders could be suspended  Vehicles, trucks and construction equipment should not be washed on site or at the beach Air pollution  The Project should require that construction contractors operate only well maintained engines, vehicles, trucks and equipment. A routine maintenance program for all equipment, vehicles, trucks and power generating engines should be in place.  The project should ensure the use of good quality fuel and lubricants only  If dust generation at the project/construction site becomes a problem, limited wetting of batching plant site and or unloading and reloading points should be done to reduce dust raising  Construction traffic speed control measures should be enforced on unpaved roads (speed limits through communities should be ≤50km/hr on unpaved or untarred roads and near or at project site should be ≤30 km/hr).  Engines of vehicles/trucks and earth-moving equipment should be switched off when not in use. Noise and vibration  The Project should require contractors to use equipment and vehicles that are in good working order, well maintained, and that have some noise suppression equipment (e.g. mufflers, noise baffles) intact and in working order. This will be achieved by making it a component of contractual agreements with the construction contractors.  Contractors will be required to implement best driving practices when approaching and leaving the site (speed limit of ≤30 km/hr) to minimize noise generation created through activities such as unnecessary acceleration and breaking squeal.  Engines of vehicles/trucks and earth-moving equipment should be switched off when not in use. Impacts on Landscape  The CLS should be boarded off from public view during construction and Visual Receptors  Good house-keeping at construction sites should be ensured Impact on traffic  Only road worthy vehicles and trucks should be used to avoid frequent breakdowns on the roads  Only experienced drivers should be employed Water pollution  No garbage/refuse, oily wastes, fuels/waste oils should be discharged into drains or shores/beach or onto site grounds  Fuel storage tanks/sites should be properly secured to contain any spillage

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 Maintenance and cleaning of vehicles, trucks and equipment should take place offsite in view of the proximity of the landing sites to the marine environment.  Toilet facilities should be provided for construction workers to avoid indiscriminate defecation in nearby bush or shores Impact on fauna and . Security lighting should be aimed at the project site and not extended to the beach area to habitat avoid impacts on sensitive fauna. Spillage of illumination outside the direct work area should be avoided. Submarine Cable Activities Air/ Noise pollution The Project should require that marine vessels/ equipment are well maintained and have a routine maintenance program in place. Impact on seabed The cable route design should avoid areas of potential geological sensitivity such as ocean geology trenches, bedrock outcrops etc. Detailed pre-installation surveys should be carried out and should identify potential geological sensitive areas and subsequently avoided by the detailed cable route design. Impacts on Marine  The Project should require that marine vessels implement a hazardous materials Fauna/habitat management plan that includes specification for proper storage and handling of fuels, oil, wastes, and other potentially hazardous materials as well as a plan for containment and cleanup of accidental spills into marine environment.  During pre-installation and installation, spotting of marine mammals and turtles should form part of the project work while at sea. Should these species be observed in the vicinity of the work area, the vessels should execute measures to avoid destruction or disturbance. Vessel operators should maintain a distance of at least 100m and should travel at 10 knots or less if safety permits until animals are more than 500 m away. Abrupt changes in direction should be avoided.  Vessel crews must report sightings of any injured or dead marine mammals and sea turtles immediately, regardless of whether the injury or death is caused by a Project vessel. The report should include the date and location of the animal/strike, and the species identification or a description of the animal. The report should be made to GAMTEL to be forwarded to NEA and other interested organisations.  The Project workforce and local communities should be educated to ensure that the importance of environmental protection and nature conservation are effectively communicated and that wider appreciation of environmental issues and construction best practice are fostered. Impacts on marine  Cable routes should avoid major ports, fish landing sites and shipping routes traffic  The Project should notify the Maritime Administration (GPA) of the submarine activities, so that vessels in the area would be warned in advance of the ongoing operations through a ‘Notice to Mariners’ report transmitted daily as well as potential dangers posed by and to other vessels when working in areas of higher traffic. Impact on marine  The Project should require that marine vessels implement a hazardous materials water quality /coastal management plan that includes specification for proper storage and handling of fuels, oil, processes wastes, and other potentially hazardous materials as well as a plan for containment and cleanup of accidental spills into the marine environment.  Marine vessels will be required to adhere to International Maritime Organization (IMO) regulations on bilge and ballast water discharge.  Areas of nearshore environment that are disturbed during installation activities (such as trench digging) should be rehabilitated as soon as possible after the cable has been installed.  All rehabilitated areas should be surveyed on weekly basis for the first month after rehabilitation, and a monthly basis for the subsequent five months, to monitor levels of

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coastal erosion in the vicinity of the development. If observations indicate that significant erosion and sediment transport is taking place (i.e. that rehabilitation has been unsuccessful) additional mitigation should be employed to reduce erosion.  Marine vessel anchors will not be dragged along the seabed and they will be retrieved vertically to avoid unnecessary sediment disturbance.  The maximum speed of the cable laying should not exceed 6 knots per hour so that the amount of seabed sediment disturbed and dispersed during the cable laying process can be kept to a minimum.  No waste oils, solid wastes, oily wastes as well as garbage will be discharged into sea. Marine vessels in consultation with the GPA will comply fully with the requirements of the MARPOL Protocol.

Mitigating Potential Social Impacts/ Concerns during the Construction Phase

Type of impact Description of mitigation measures Construction of lCLS and BMH Facilities Physical displacement No PAP will be displaced. Mostly, they will be disturbed and a Resettlement Plan has been and loss of livelihood prepared as part of this study to cater for any loss livelihoods

Local employment Contractors should use local labour as much as possible and where available. As much as possible, all unskilled labour should be contracted or obtained from the local community. GAMWORKS, a local unit that recruits contractors for projects in The Gambia is involved in the project to ensure local participation. Deprivation of use of No issues to be encountered land

Loss of structures/ No issues to be encountered properties

Impacts on recreation Appropriate notices and warning signs will be erected around working areas of beach or shore areas to warn prospective trespassers of any danger or risk Impacts on Human  There will be restricted access to the construction site. Security check point will be Health/ Safety and mounted at the entrance and exit to the site. sanitation  The construction site will be boarded off to prevent intruders and easy access by the public especially from the beach end. The retaining wall is short and can easily be climbed over.  All construction workers will be provided with ID cards  Trucks carrying construction materials such as sand, quarry dust, laterite etc will have the buckets covered with tarpaulin or appropriate polythene material from or to project site  Only road worthy vehicles/trucks will be used  Only experienced drivers/operators will be engaged  Except for areas secured by fencing, all active construction areas will be marked with high-visibility tape to reduce the risk of accidents.  All open trenches onshore and excavated areas will be backfilled after works have been completed.  Adequate sanitary facilities will be available for workers and open range defecation will

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not be countenanced.  Construction workers will be provided with and educated to wear suitable Personal Protective Equipment (PPE) including hard hats, overalls, high-visibility vests, safety boots, earplugs, gloves etc.  Every construction worker engaged will have an induction briefing on adherence to basic rules on occupational health and safety, environmental protection, public safety and work ethics, including most importantly hygiene and disease (HIV) prevention. Submarine cable activities Impacts on artisanal  GAMTEL/PIU will notify local fishermen /local communities early of the marine fishing activities or programme for the area.  Artisanal fishing activities will not be stopped because of the project but the fishermen will be advised or educated to move away from the proposed cable route corridor. Impacts on cultural  Should the pre-installation/marine surveys identify wrecks or marine cultural heritage heritage/archaeological resource or marine infrastructure such as pipelines or cable routes, the cable route interest /existing marine design will avoid and by-pass these resources. infrastructure and  The project will adopt and implement a chance find procedure and reporting system to services enable contractors report on any cultural heritage feature or marine infrastructure encountered. Impacts on Human  The Project will require all contractors to implement an Environmental, Health and Health and Safety Safety (EHS) plan which will outline procedures for avoiding health and safety incidents and for emergency medical treatment. This will be achieved by making it a component of contractual agreement.  All workers on board a cable vessel will be required to wear suitable Personal Protective Equipment (PPE) including hard hats, high-visibility vests, safety boots and gloves and life vests as appropriate.  All construction and cable repair workers will be sufficiently trained in the safe methods of working with fiber optic cables to avoid injury associated with laser lights and fibers.  Vessels will increase watch when navigating in areas that are known to be used by fishermen and other vessels. If other vessels are observed within the near vicinity, the Project vessel will stop moving, make contact with the other vessel if possible, and wait until it has been confirmed that the course of both vessels will not result in collision or damage to equipment.  While a vessel is laying cable its manoeuvrability is restricted, as such it will display the day signals and lights of a hampered vessel to avoid collision with other vessels at sea.

Mitigation Measures for Operational Phase Impacts

Standby generators will be kept in proper housing or cage in order to localise noise generated from these equipment. Routine maintenance regime of engines, generators and equipment will be instituted to reduce incidence of smoke/fume and noise generation.

A permanent fence wall will be constructed around the CLS facility with a 24-hour security at the premises. The premises will have CCT surveillance monitoring system for effective security monitoring.

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The facility will be installed with smoke detectors, and fire alarms. Fire extinguishers will be positioned at all strategic areas and fire hydrants will be provided. An emergency assembly point will be created. Directions for exit within the facility will be provided and well labelled.

Workers will be provided with adequate and appropriate personal protective equipment. Workers will not be exposed to the direct fibre optic laser light which can affect their vision or eye sight. GAMTEL/PIU will enter into a standby agreement with the submarine cable contractors to undertake cable repairs as and when required. An emergency preparedness and response plan will be developed and implemented.

ESIA/ ESMP Implementation It is the policy of GAMTEL/PIU to establish and maintain high standards of occupational health, safety and environmental protection at work, so as to prevent personal injury or illness, property damage, fires, security losses and environmental pollution. The contractors will appoint an Environmental and Safety Supervisor, while the Project will have an Environmental and Safety Coordinator to oversee the implementation of the ESIA/ ESMP. Appropriate programmes to ensue the implementation of the ESIA/ ESMP have been developed and these cover:  Awareness creation and training;  Public participation/Involvement;  Contractor specific action plans;  Monitoring;  Uncertainty and change management;  Reporting; and  Emergency preparedness and response plan.

Capacity Building The capacity building requirements will be in the form of a training workshop on the ESMP, MARPOL Conventions, the World Bank safeguard policies of OP 4.12 and OP 4.01 for the following key stakeholders: GAMTEL/PIU; NEA; GPA and Project consultants/contractors.

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1.0 INTRODUCTION

1.1 Project Background

Africa is set to receive a significant broadband boost with France Telecom (FT) signing a construction agreement with Alcatel-Lucent for the new Africa Coast to Europe (ACE) submarine communications cable. The ACE submarine communications cable is a planned cable system along the west coast of Africa between France and South Africa. This will be about 17,000km fibre-optic link connecting the countries along the western coast of Africa especially the West African countries to the global broadband network. The ACE consortium is a newly formed group comprising of about 20 telecom operators.

The Republic of The Gambia has recently signed the consortium agreement to be part of the ACE Submarine Cable to be financed by the World Bank. This support forms part of the West Africa Regional Communications Infrastructure Program (WARCIP) being executed by the World Bank. The WARCIP aims to contribute to lowering the cost and improving quality of regional and international connectivity by facilitating:  the connection of all countries in West Africa to global broadband fiber optics infrastructure; and  the creation of a coordinated regional and national transmission network which would ensure that all countries in West Africa are able to connect effectively within and between national borders.

The World Bank’s environmental and social safeguards policies require that the recipient country prepare an Environmental and Social Impact Assessment (ESIA) Report/ Environmental and Social Management Plan (ESMP), which is consistent with national laws, any applicable treaty concerning international waters, and OP 4.01 and a Resettlement Action Plan (RAP) for the lateral cables and any associated equipment that will be laid from the Branching Unit (BU) at the junction with the main cable through territorial waters and onto the national shores and on land.

The ACE submarine cable is going to be deployed over 17,000 km and will provide access to more than 20 countries starting in 2012. With a planned capacity of about 5.12 Tbit/s, the ACE submarine cable system will provide sufficient and redundancy capacity for the future country needs.

This ACE Connectivity Project entails laying a lateral submarine cable to connect with the ACE submarine cable which will be laid off the coast of France to the coast of The Gambia and construction of a Beach Manhole (BMH) at Bijilo beach, and Cable Landing Station (CLS) at Brusubi area. The installation of the lateral connecting cable requires laying the submarine cable on the sea bed of The Gambia’s EEZ and territorial waters, then burying the cable in the

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nearshore zone and across the beach before arriving at the CLS, which will be constructed as part of the project.

In compliance with the National Environment Management Act, 1994, the proposed project has been registered with the National Environment Agency (NEA) to obtain an environmental permit for implementing the project. The communications with the NEA on the proposed project are presented in Annex 1.

SAL Consult Limited, a Ghanaian registered multidisciplinary water and environmental consultancy firm based in Accra, Ghana was contracted to prepare the ESIA/ ESMP and the RAP for the Project by the Government of The Gambia (GOTG) acting through the Project Implementation Unit (PIU) of the Ministry of Finance and Economic Affairs (MOFEA) on behalf of the Ministry of Information and Communications Infrastructure (MOICI) and the implementing agency, Gambia Telecommunications Corporation (GAMTEL). The RAP component of the ESIA/ ESMP has been prepared as a separate stand-alone document to provide guidance in the event that land needs to be acquired and people need to be resettled or compensated in accordance with OP 4.12.

1.2 Purpose and Objectives of the Environmental Assessment

The purpose of the ESMP is to provide guidance to cable-laying and construction contractors, and to the operators of the facilities, on the measures and actions to be taken during implementation and operation of the facilities to eliminate, mitigate, or offset significant adverse environmental and social impacts, or to reduce them to acceptable levels.

The objective of the environmental assessment (EA) is to assist the PIU of GOTG to obtain the necessary Environmental Approvals for the development of the Project at the proposed sites at Bijilo and Brusubi which are within the jurisdiction of the Western Region and in the Kombo North District, the Local Government Authority (LGA).

This ESMP aims to bring the Project into compliance with the World Bank safeguard policies as well as The Republic of Gambia’s Environmental Assessment Procedures to improve decision making in order to ensure environmental and social sustainability in line with the Bank’s policies and guidelines. The ESIA/ ESMP also seek to obtain the necessary environmental permit from the NEA for the execution of the project in compliance with statutory provisions under the NEMA 1994.

The specific objectives of the EA study are to:  Identify significant adverse environmental and social impacts, conflicts and concerns likely to arise as a result of the implementation of the project;  outline mitigating/enhancing, monitoring, consultative and institutional measures for managing adverse environmental and social impacts or to enhance the programme beneficial impacts; and

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 address capacity building requirements needed to strengthen key institutional stakeholders as well as affected local groups or communities’ environmental and social capacities; and  document all findings and recommendations in an ESIA/ ESMP Report to guide project execution.

1.3 Scope of Services

The scope of work includes:  Description of the existing bio-physical and socio-economic and cultural environment with emphasis on the project area of influence and /or marine protected areas;  Legislative and regulatory considerations including national, international and World Bank requirements;  Identification of the potential direct, induced and cumulative impacts;  Analysis of alternatives;  Provision of mitigation and management measures for negative impacts identified;  Institutional capacities to address adverse impacts; and  Development of an environmental and social management plan.

1.4 Approach and Methodology

The approach and methodology adopted for the study included:  Desk studies;  Site visits;  Consultations;  Data analysis; and  Report preparation.

Desk Studies Documents relevant to the proposed project were reviewed to help predict, identify and evaluate the potential impacts of the project. These documents include;  project documents including information obtained on the internet; and  Environmental Assessment Reports on similar projects.

Site Visits The project site was visited to confirm baseline environmental and socio-economic conditions that would be affected or likely to develop from the implementation of the proposed project.

Consultations Stakeholder participation during project planning, design and implementation has now become widely recognised as an integral part of environmental and social impact assessment. In this regard, various stakeholders were consulted for their views, concerns or interests in the proposed project and these include:  Ministry of Finance and Economic Affairs (MOFEA);

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 Ministry of Information and Communication Infrastructure (MOICI)  Gambian Telecommunications Company Limited (GAMTEL);  National Environmental Agency (NEA);  Gambia Ports Authority (GPA);  Gambia Bureau of Statistics (GBoS);  Gambia National Petroleum Corporation (GNPC;  National Roads Authority (NRA);  National Water and Electricity Company (NAWEC);  Department of Lands and Surveys;  Department of Physical Planning and Housing;  Geological Department;  The Association of Non-Governmental Organisations (TANGO); and  Gambia Tourism Authority.

Information obtained from the consultation process was used to confirm or otherwise the information obtained from the desk study or observations made from the field inspections.

Data Analysis and Reporting Data obtained from both field and desk studies was analysed and a report prepared accordingly. Major headings making the report comprise: a) Introduction; b) Policy, Legal and Institutional Framework; c) Description of the Proposed Development; d) Alternative Analysis; e) Baseline Environmental Conditions; f) Assessment of Potential Environmental Impacts; g) Mitigating and Enhancement Measures; h) Environmental Monitoring Plan; i) Provisional Environmental Management Plan; j) Conclusion; k) Bibliography; l) Annexes.

1.5 Legal Framework for Project Development

The relevant regulatory framework that will guide the proponent throughout the construction and operation and or decommissioning of the project include the following:  Constitution of the Republic of the Gambia, 1997;  National Environment Management Act (NEMA), 1994;  Environmental Quality Standards Regulations, 1999;  Wildlife Conservation Act, 1977;  Fisheries Act 2007; and  Public Utilities Regulatory Authority Act, 2001.

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2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1 Policy on Information Communications Technology

In 2002 the MOICI was created to coordinate the prolific growth in the Information Communications Technology (ICT) Industry and was charged to:  develop policies and the regulatory framework to facilitate orderly growth in the communications industry;  manage telecommunication resources including the radio spectrum; and  to coordinate and support the numerous sectoral information and communication technology initiatives at the public sector level.

As part of efforts by GOTG to implement some aspects of the World Summit of Information Society (WSIS) principles and the Africa Information Society Initiatives (AISI) for an informed society, the MOICI has concretised on-going and future ICT initiatives into a coherent and robust national ICT-led policy and plan, the National Information and Communications Initiative (NICI) for socioeconomic development including:  infrastructure development initiatives; and  institutional mechanisms/ structures implementation.

The NICI as an e-Strategy Plan is a mechanism to implement the vision of AISI at the national level. As AISI focuses its vision on ICT Development in Africa, the NICI contains a guiding framework for ICT program planning, project development and implementation which are consistent with its vision and mission statements. It has a series of sector applications defined according to Africa 's priorities.

The NICI Plan and Policies development process in The Gambia is geared towards recognizing the areas where ICT would contribute to the attainment of the overall objective of the Vision 2020 and the four strategic issues identified in the PRSP:  Enhancing the productive capacity of the poor;  Enhancing access to and the performance of social services;  Local level capacity building; and  Promoting participatory communications process.

2.2 Relevant Legal and Regulatory Framework

The relevant national regulatory framework to guide the project implementation include the following:  Constitution of the Republic of the Gambia, 1997;  The Vision 2020;  National Environment Management Act (NEMA), 1994;  Environmental Quality Standards Regulations, 1999;

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 Wildlife Conservation Act, 1977;  Fisheries Act 2007; and  Public Utilities Regulatory Authority Act, 2001.

The Constitution of The Gambia, 1997 The Constitution includes some provisions to protect the right of individuals to private property or protection from deprivation of property. It also sets principles under which citizens may be deprived of their property compulsorily in the public interest as described in Section 22 of the Constitution. It also makes provision for the prompt payment of adequate compensation and access to the court or other impartial and independent authority for the determination of the land owner’s interest or right, and the amount of any compensation to which he is entitled and for the purpose of obtaining prompt payment of that compensation.

The Vision 2020 The GOTG has recently introduced the multi-year Vision 2020 development programme in which it commits itself to conserve and promote the rational use of the country’s natural resources and environment for the benefit of present and future generations in a manner that is consistent with the overall goal of sustainable development. At the core of Vision 2020 is the recognition that accelerated economic growth will require increased investment and exploitation of the country’s natural resources. However, sustained growth will also require successful incorporation of new technologies that are environmentally sound to increase productivity, particularly among resource based establishments.

National Environment Management Act (NEMA), 1994 The NEMA, 1994 is the framework law that established the National Environment Agency (NEA) as a frontline agency to manage the implementation of the Gambia Environmental Action Plan (GEAP) in 1994. This was made possible following the Banjul Declaration of 1977 as the first policy instrument to focus on the need for environmental conservation in The Gambia and subsequently, the creation of the Environment Unit in 1981 under the Ministry of Natural Resources to advise it on matters related to the environment and culminating in the formulation of GEAP in 1992.

The ultimate goal of the NEA is to achieve the essential policy objectives of the Gambia Environmental Action Plan as indicated below.  To make sure that the economic and social development of The Gambia is done in an environmentally sustainable manner.  To develop and maintain a National Environmental Planning Framework for the Gambia.  To have a Legal recognition of the fundamental right to a sound environment, ensuring the health and well-being of all those living in the Gambia.  To educate about the environment, increasing environmental awareness and empowering communities to take action to identify and solve environmental problems.  To provide reliable and relevant information for sound environmental management.  To conserve and promote the sound and rational use of natural resources.

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The NEA is governed by the National Environmental Management Council (NEMC), which is the main policy making body for environmental Management in The Gambia and chaired by the President of the republic.

Environmental Quality Standards Regulations, 1999 The Environmental Quality Standards Regulations (EQSR), 1999 establishes the Environmental Quality Board (EQB) with the following functions:  to propose environmental quality standards to the NEMC and to review same eriodically; and  to carry out any other functions that may be delegated to it by the NEMC.

In line with the objectives set out in the NEMA, environmental quality standards have been enacted as part of the EQSR in respect of ambient air, saline waters, surface fresh waters and groundwater.

Wildlife Conservation Act, 1977 The Wildlife Conservation Act (WCA), 1997 is an Act to provide for the conservation and rational management of wildlife in the Gambia and for matters connected therewith and incidental thereto. The Act provides for the establishment of National Parks, Nature Reserves and Local Sanctuaries among others.

Fisheries Act, 2007 The Fisheries Act (FA), 2007 provides for the conservation, management and sustainable utilisation and development of fisheries and aquaculture in the fisheries waters and in the territory of the Gambia and matters connected therewith.

Public Utilities Regulatory Authority Act, 2001 The Gambia Public Utilities Regulatory Authority Act, 2001 provides for the establishment of PURA, a multi-sector regulatory authority, to regulate the activities of providers of certain public utilities amongst them energy services (electricity, petroleum and gas), communications services (telecommunications, broadcasting and postal services), water and sewerage services and transport services (on land, water and in the air).

2.3 Institutional and Administrative Framework

The relevant institutions with direct bearing on the project include:  Ministry of Finance and Economic Affairs (MOFEA);  Ministry of Information and Communication Infrastructure (MOICI)  Gambian Telecommunications Company Limited (GAMTEL);  Ministry of Petroleum (MOP)/ Gambia National Petroleum Corporation (GNPC);  National Environmental Agency (NEA);  Gambia Ports Authority (GPA);

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 Gambia Bureau of Statistics (GBoS);  National Roads Authority (NRA);  National Water and Electricity Company (NAWEC);  Department of Lands and Surveys;  Department of Physical Planning and Housing;  Geological Department;  The Association of Non-Governmental Organisations (TANGO); and  Gambia Tourism Authority.

Ministry of Finance and Economic Affairs (MOFEA) The MFEA derives its mandate from the constitution of The Gambia and is in charge of setting the government’s overall economic policy objectives and formulating legal and institutional frameworks for achieving the objectives. The specific responsibility of the ministry is as follows:  Development of the Government’s macro fiscal policy and the medium-term expenditure framework for budget preparation;  Management of the national budget preparation process;  Coordination and management of external grants and loans;  Carrying out budget execution and internal auditing, cash management and in-year financial planning, management of government banking arrangements, management of government accounting and reporting, and management of public debt;  Promotion of fiscal transparency and effective management in respect of revenues, expenditures, and assets and liabilities of the Government;  Responsibility for all tax and non tax revenue policy related issues, including all policy issues related to direct and indirect taxes, foreign trade taxes, excise duties and fees and licenses.  Exercising control over the implementation of the Government Budget, including any in-year adjustments to the budget;  Publishing, by appropriate means, the progress of budget execution;  Inspection of the financial operations and property management of budget agencies; and  Preparation and submission of annual statements of Government accounts to the Auditor- General, and have them published for the interest of the general public.

It is the ministry’s function of coordination and management of external grants and loans that explains MOFEA’s relationship with the ACE project. The MFEA is currently hosting the Project Preparation Activities (PPA) within the (IFMIS) Project Implementation Unit (PIU). It is planned that a separate PIU will be created for the WARCIP – The Gambia Project. The Aide Memoire for the project has identified the needed capacity requirements for the PIU and has put steps in motion to develop the necessary capacities for the proper management of the process. The MFEA is expected to participate in the dialogue between GAMTEL and private operators to discuss and agree on issues regarding the creation of a Special Purpose Vehicle (SPV) for the landing station. The Ministry will also help to finalize the choice and determine the degree of private sector participation and the schedule for the contribution of the private sector.

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Ministry of Information and Communication Infrastructure (MOICI) The vision and mission of MoICI is to lead and advocate in the mainstreaming of ICT in all sectors of The Gambian society. The MOICI was created in 2002 to harmonize the rapid growth in the communications, information and technology (notably information technology) industries. The MOICI is to formulate policies and regulatory frameworks to aid systematic growth in the communications industry and to manage telecommunication resources including the radio spectrum. At the level of the public sector (inter-sector collaboration), the MOICI is to coordinate and support the various sectoral information and communication technology (ICT) initiatives. In an effort to build an information-rich and knowledge-based society consistent with the Declaration of Principles of the World Summit on the Information Society (WSIS), the MOICI will organize on-going and future ICT initiatives into a consistent and vigorous national ICT-led policy and plan for socioeconomic development.

MoICI is the principal actor in the WARCIP – ACE – The Gambia Project. An official from the Ministry is the focal Point for the project which MoICI is implementing through its technical unit – GAMTEL. The Aide Memoire for the project assessed and recommended capacity-building in the areas of: 1. Development of policy and institutional framework for top level domain name; and 2. Providing support to the MoICI in the area of ICT development.

In addition training, study tours will be organized and advisors hired for capacity building support for the Ministry.

Gambia Telecommunications Company (GAMTEL) The Gambia Telecommunications Company is the principal telecommunications company of The Gambia. It is a state-owned company, charged with the task of supervising the provision of telecommunications and internet service in the country. In association with GAMTEL's internet company, GAMNET, it has successfully built Gambia's internet infrastructure. The company was established in 1990 by an act of parliament as the single licensed telecommunications services provider in the country; 99 percent of its stock is owned by the government of the Gambia and the remaining 1 percent owned by the Gambia National Insurance Company. In 1993 it commenced the task of creating the Gambia Radio and Television Service, a company that operates the nation's radio and television industry. GAMTEL Currently employs over 1,000 people and its main offices are at GAMTEL House in Banjul.

The Company has steadily created a modern efficient network infrastructure, using state-of-the -art technology in order to respond to the increasing demand of a dynamic market. GAMTEL has grown swiftly into one of Gambia's leading enterprises recording an annual turnover of D417.8 million for the year ending 2001 and expecting an estimated figure of D419million for the year ending 2002. During the eighteen years of operations GAMTEL has achieved and hit countless number of targets. Among its latest ventures was the introduction of integrated service digital network (ISDN), virtual private network (VPN), Internet Service Provider (ISP), electronic banking (E-BANKING) and still in the pipeline is electronic education (E-LEARNING) and electronic

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commerce (E-COMMERCE). The single aim of GAMTEL is to provide a complete range of communication services, based on market demand, at the lowest possible cost to the customers and using the most modern and effective technology. It is this quest that makes the ACE project so crucial to GAMTEL.

Ministry Of Petroleum (MOP) The Ministry of Petroleum (MOP) has the responsibility for Petroleum exploration, development and production. This includes:  Administration and implementation of the Petroleum Laws and regulations;  Petroleum policies;  Licensing;  Petroleum data management;  Human resources development; and  Petroleum resources management.

The MOP aims to explore development, produce and manage petroleum resources of The Gambia for sustainable economic development of the country and to support poverty reduction. It does this through the Gambia National Petroleum Company (GNPC).

The role of the MOP/ GNPC in the ACE project is to co-ordinate its core activities and the location of the submarine section of the fibre optic cable. The sea bed has been divided into the blocks for the purposes of oil exploration. Each block is about 1,400km2 and the cable is expected to pass through the oil blocks. Current technical studies for the project advocated a 500m buffer zone around for the cable but discussions with MOP/ GNPC revealed that this size of buffer will adversely affect oil exploration activities. Further interaction between MOP/ GNPC and GAMTEL is therefore required to fine tune and determine the barest minimum size of buffer zone for the cable. Continued collaboration and co-operation between Gamtel and MoP is required so that oil exploration activities and the ACE project are not in conflict with each other. Currently the MOP/ GNPC has adequate resources to fulfil its functions with regards to the ACE project.

National Environment Agency (NEA) The NEA was established in 1993 by a cabinet decision and became fully functional in 1995. Some of the duties of the NEA are to regulate the licensing of imported pesticides/hazardous chemicals that are used in the country and to implement strategies and build capacity to phase out Ozone Depleting Substances (ODS). NEA also has responsibility for coastal zone management through harmonizing all policies and co-ordinating development activities inside the coastal zone. On the ACE project NEA’s technical service directorate is responsible for corroborating and approving the ESIA/ ESMP document and the issuing of environmental approval for the project.

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Gambia Ports Authority (GPA) Gambia Ports Authority (GPA) was established by the Ports Act of 1972 to take over the assets and operations of the erstwhile Marine Department. GPA, which is a monopoly in the marine sector, is responsible for the management, operation and development of marine and cargo handling services at the Port of Banjul. It is a strategic entity which facilitates international trade. In 2001, the ferries department was detached from the Gambia Public Transport Corporation and transferred to GPA. Apart from the provision of ferry crossing services in Banjul, the Ferries Department also operate ferry crossing at eight other crossing points throughout the country. These are at Yellintenda/Bambatenda, Basse, Jarreng, Janjangbureh, Barajally, Sankully Kunda, Bansang and Fatoto. GPA, which is wholly owned by the Government, has a share capital of D16.3 million. The GPA's main port is located in Banjul. It is mainly used for discharging and loading shipment for Container Carriers, Tankers, Ro-Ro and General Cargo Vessels. It also provides a Navy base for the Gambia Navy and provides a ferry-crossing Terminal for Banjul/Barra crossing. Another small port is located in Kaur but not operational.

GPA’s role in the ACE project will be to collaborate with the Gambian Navy to mark the route of the cable both in the sea and on maps so that any conflicts between the cable and shipping activities can be avoided. When the cable is laid, vessels of draft of 3-4m can still access the area.

National Road Authority (NRA) Established in 2003 by an Act of Parliament the NRA has responsibility for the construction, maintenance, administration and control of all roads in The Gambia. NRA may with the consent of the Minister, delegate its duties to a local authority or competent body or person for part of any road. It has an independent board which is in charge of its general direction and practice. The Ministry of Works, Construction & Infrastructure (MOWCI) has the oversight responsibility for the NRA.

NRA has a very important role to play in the ACE project because the cable land route is located in the utility corridor along three different types of road – a highway and access roads. Moreover, the cable will cross the Kombo Beach Highway and this will entail the digging across the road, the diversion of traffic away from the road for the duration of the conduit construction and re-instatement of the road surface. Apart from ensuring that road surface confirms to the standards of NRA, continued monitoring of the road corridor to secure the cable and to avoid any conflict between any future road development and the cable route will also be the responsibility of the NRA. The NRA is confident of being adequately equipped to discharge its responsibilities towards the ACE project.

The NRA confirmed having a Memorandum of Understanding (MoU) with the utility providers i.e., GAMTEL, and the National Water and Electricity Company (NAWEC) concerning road crossings. Under the ACE project, NRA will carry out the road reinstatement while GAMTEL pays for it.

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Ministry of Fisheries and Water Resources Within this ministry, it is the fisheries section that has any role to play in the cable project. The vision and mission of the ministry includes ensuring the sustained development of the fisheries. The ministry is in charge of fisheries which include marine fishing. It is therefore expected to play a role is safeguarding fishing interests as well as the fibre optic cable. The ministry is expected to help ensure that fishing activities do not endanger the cable through the use of nets or anchors.

It is expected that the Ministry will organize sensitization for fishermen before cable laying occurs in June-July 2011 which is also the peak fishing season. It is envisaged that, the responsibility of the Ministry of Fisheries would be to create awareness of the project among fishermen and assist GAMTEL and other relevant authorities to leave a corridor for the cable, if necessary, to ensure the success of the project. In terms of qualified personnel the Ministry is adequately resourced; however, it needs to be resourced with vehicles, printed materials and air time on radio and TV to do effective work.

Gambia Tourism Authority (GTA) GTA was set up by an Act of National Assembly in July 2001 as a statutory body to develop, regulate and promote the tourism industry in The Gambia in conjunction with the National Vision 2020. The GTA seeks to transform The Gambia into a World Class tourist haven and business hub. It is the implementing outfit of the Departments of State for Tourism and Culture and is in charge of licensing and regulation of tourism project and provides advice to prospective investors.

The primary responsibility of GTA is the marketing and promotion of The Gambia as a preferred choice for tourists. GTA is involved in the ACE project as the custodian of Bijilo Beach since the whole coastline of the Country has been leased to GTA and has been declared a tourism zone. The BMH is situated on Bijilo beach which means that during the constructional and operational and maintenance phases of the project, GAMTEL has to continue to work in close collaboration with GTA to ensure that whatever future development that GTA plans to implement would not adversely affect the cable. Currently, the GTA’s normal staff would be able to handle their role in the ACE project.

The Association of Non-Governmental Organizations (TANGO) TANGO is a non-partisan, voluntary, non-profit, non-religious and non-sectarian organization. The organization’s principal commitment is to support and develop NGO activities by means of capacity building. TANGO also acts as a representative and advocate for NGOs working in The Gambia. In addition, the Association helps NGOs to deliver better service to Gambian communities to equip such NGOs to participate in national and international activities and administrative practices that impact on the lives of their members and beneficiaries. The vision of TANGO is “To become a dynamic, pro-active innovative and inclusive NGO consortium, playing a key and constructive role in building a strong, vibrant and independent civil society in a democratic, peaceful and equitable Gambia” and its mission is “To contribute to national

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poverty reduction effort by expanding membership and improving services to members in a cost effective and financially sustainable manner.”

The role of TANGO in the ACE will be one of monitoring to ensure that the social safeguards are incorporated into project implementation activities, especially in the execution of civil works. Although the magnitude of social impacts are low and the duration relatively short, the role of TANGO will ensure that whatever mitigation measures have been designed would be applied to avoid inconveniencing people who live or work along the cable land route.

Department of Lands and Surveys and Department of Physical Planning and Housing The Ministry of Local Government and Lands (MOLGL) is the main agency for local government planning and land development in the Gambia and has oversight responsibility for the Departments of Lands and Surveys (DOLS) and Physical Planning and Housing (DOPPH). These two departments have collaborated well with GAMTEL to ensure release of land for the ACE project in the Gambia (see Annex 2).

2.4 Project Approval Requirements

The key project approvals required at the national level are presented in Table 1.

Table 1: Project Approval Requirements No. Institution Type of approval Status 1 NEA Environmental Licence Project registered with the NEA and Screening carried out. NEA has in principle given it’s environmental Approval for commencement of the project (see Annex 1). 2 Department of Lands and Land Acquisition Application for Land for the CLS concluded and Surveys site secured (Annex 2).

2.5 Relevant International Institution- World Bank Safeguard Policies

The World Bank has published ten policies/ procedures to guide the safe development of projects it provides funding for and these include OP/BP 4.01-Environmental Assessment, OP/BP 4.04-Natural Habitats, OP/BP 4.09-Pest Management, OP/BP 4.11-Physical Cultural Resources, OP/BP 4.12-Involuntary Resettlement, OP/BP 4.36-Forests, OP/BP 4.37-Safety of Dams, OP/BP 7.50-Projects on International Waters, OP/BP 7.60-Projects in Disputed Areas, OD 4.20- Indigenous Peoples

The relevant World Bank safeguard policies triggered by the implementation of this project include:  OP/BP 4.01 – Environmental Assessment; and  OP/BP 4.12 – Involuntary Resettlement.

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2.5.1 OP/BP 4.01: Environmental Assessment

The objective of the OP. 4.01 is to ensure that the projects financed by the Bank are environmentally and socially sustainable, and that the decision making process is improved through an appropriate analysis of the actions including their potential environmental impacts. The purpose of Environmental Assessment is to improve decision making and to ensure that the project options under consideration are environmentally sound and sustainable, and that potentially affected people have been properly consulted. Environmental Assessments identify ways of improving projects environmentally, by preventing, minimizing, mitigating, or compensating for adverse impacts.

2.5.2 OP/BP 4.12: Involuntary Resettlement

The World Bank’s safeguard policy on involuntary resettlement, OP/BP 4.12, is triggered in situations involving involuntary taking of land and involuntary restrictions of access to legally designated parks and protected areas. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts.

It promotes participation of displaced people in resettlement planning and implementation, and its key economic objective is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects.

The proposed site selected for the BMH and the CLS will not require the preparation of RAP or ARAP due to the number of Project Affected Persons (PAPs) involved, about twenty seven (27no) PAPs. However, a Resettlement Plan (RP) to cater for the 27no PAPs will be prepared as a standalone document with this ESIA/ ESMP document.

2.6 International Law and Agreements

The GOTG is signatory to a number of international conventions and agreements relating to industry, development and environmental management and they include the following among others:

2.6.1 International Maritime Organization

The Gambia is signatory to the following International Maritime Organization (IMO) Conventions:  International Convention for the Prevention of Marine Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78);

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 International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers (STCW), 1978;  International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Casualties (Intervention Convention), 1969;  Convention on Limitation of Liability for Maritime Claims (LLMC), 1976;  Convention on the International Regulations for Preventing Collisions at Sea (COLREGs), 1972; and  International Convention for the Safety of Life at Sea (SOLAS), 1974.

A number of the provisions and guidance outlined in the MARPOL Convention are relevant to marine activities, including general requirements over the control of waste oil/engine oil discharges and grey and black waste water discharges. In addition, a number of the Annexes of the Convention relevant such as Annex V (Prevention of Pollution by Garbage from Ships) and Annex VI (Prevention of Air Pollution from Ships).

2.6.2 Legal Boundaries of the Ocean

The submarine cable route will be in both territorial waters of The Gambia and international waters as illustrated in Figure 1. The United Nations Third Conference on the Law of the Sea (UNCLOS) introduces a number of provisions. The most significant issues covered were setting limits, navigation, archipelagic status and transit regimes, exclusive economic zones (EEZs), continental shelf jurisdiction, deep seabed mining, the exploitation regime, protection of the marine environment, scientific research, and settlement of disputes. The convention set the limit of various areas, measured from a carefully defined baseline. The areas are as follows:

Internal waters It covers all water and waterways on the landward side of the baseline. The coastal state is free to set laws, regulate use, and use any resource. Foreign vessels have no right of passage within internal waters.

Territorial waters Out to 12 nautical miles from the baseline, the coastal state is free to set laws, regulate use, and use any resource. Vessels were given the right of innocent passage through any territorial waters, with strategic straits allowing the passage of military craft as transit passage, in that naval vessels are allowed to maintain postures that would be illegal in territorial waters. "Innocent passage" is defined by the convention as passing through waters in an expeditious and continuous manner, which is not “prejudicial to the peace, good order or the security” of the coastal state.

Contiguous zone Beyond the 12 nautical mile limit there was a further 12 nautical miles or 24 nautical miles from the territorial sea baselines limit, the contiguous zone, in which a state could continue to enforce laws in four specific areas: pollution, taxation, customs, and immigration.

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Exclusive economic zones (EEZs) This zone extends from the edge of the territorial sea out to 200 nautical miles from the baseline. Within this area, the coastal nation has sole exploitation rights over all natural resources. In casual use, the term may include the territorial sea and even the continental shelf. Foreign nations have the freedom of navigation and over flight, subject to the regulation of the coastal states. Foreign states may also lay submarine pipes and cables.

Continental shelf The continental shelf is defined as the natural prolongation of the land territory to the continental margin’s outer edge, or 200 nautical miles from the coastal state’s baseline, whichever is greater. Coastal states have the right to harvest mineral and non-living material in the subsoil of its continental shelf, to the exclusion of others. Coastal states also have exclusive control over living resources "attached" to the continental shelf, but not to creatures living in the water column beyond the exclusive economic zone.

Source: D. Burnett

Figure 1 Legal Boundaries of the Ocean from Territorial Sea to Exclusive Economic Zone and onto the High Seas (figures in parenthesis refer to treaty articles)

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2.6.3 Marine Regulations on Submarine Cables

Local Jurisdiction The GOTG is signatory to the United Nations Convention on the Laws of the Sea (UNCLOS). Under this The Gambia claims rights within a 12 nautical mile (nmi) territorial water and a 200 nmi Exclusive Economic Zone (EEZ). EEZ and territorial waters are defined by UNCLOS and within which specific rules apply. Article 79 of UNCLOS, in particular, concerns the installation of “submarine cables and pipelines on the continental shelf” and specifies the following: All States are entitled to lay submarine cables and pipelines on the continental shelf, in accordance with the provisions of this article.  Subject to its right to take reasonable measures for the exploration of the continental shelf, the exploitation of its natural resources and the prevention, reduction and control of pollution from pipelines, the coastal State may not impede the laying or maintenance of such cables or pipelines.  The delineation of the course for the laying of such pipelines on the continental shelf is subject to the consent of the coastal State.

 Nothing in this Part affects the right of the coastal State to establish conditions for cables or pipelines entering its territory or territorial sea, or its jurisdiction over cables and pipelines constructed or used in connection with the exploration of its continental shelf or exploitation of its resources or the operations of artificial islands, installations and structures under its jurisdiction.  When laying submarine cables or pipelines, States shall have due regard to cables or pipelines already in position. In particular, possibilities of repairing existing cables or pipelines shall not be prejudiced.

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3.0 PROJECT DESCRIPTION

3.1 Project Background

The ACE submarine cable system comprises a submarine communications cable that will run along the west coast of Africa to provide telecommunications capacity for international and internet connectivity to countries beginning from France to South Africa (as shown Figure 2). The cable system will span over 17,000 km along the entire route.

Figure 2: Proposed ACE Submarine Cable Configuration Showing the Landing Points

The ACE submarine cable system will link Africa to Europe with Terminal Stations in South Africa, Namibia, Angola, Democratic Republic of Congo, São Tomé and Principe, Gabon, Equatorial Guinea, Cameroon, Nigeria, Ghana, Côte d’Ivoire, Liberia, Sierra Leone, Guinea, The Gambia, Senegal, Mauritania, Canary Islands (Spain), Portugal and France.

The ACE cable relies on Wavelength Division Multiplexing (WDM), which allows cable capacity to be increased without additional submarine work. The ACE system will deploy the WDM technology, which is currently the most advanced for submarine cables ensuring that cable

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capacity is increased without additional submarine work to an overall potential capacity of 5.12 Tbit/s such that the system will support the 40 Gbit/s technology from its launch.

The ACE submarine cable system shall consist of four (4) Segments:  Segment 1 trunk running from Penmarch, France to Dakar, Senegal with four branching units providing links to Portugal, Morocco, Tenerife and Nouakchott;  Segment 2 trunk running from Dakar, Senegal to Abidjan, Côte d’Ivoire with four branching units providing links to The Gambia, Guinea, Sierra Leone and Liberia;  Segment 3 trunk running from Abidjan, Côte d’Ivoire to Santana, São Tomé and Príncipe with six branching units providing links to Ghana, Benin, Nigeria, Cameroon, Equatorial Guinea and Gabon; and  Segment 4 trunk running from Santana, São Tomé and Príncipe to Cape Town, South Africa with three branching units providing links to the Democratic Republic of the Congo, Angola and Namibia.

The Gambia falls under Segment 2 (S2) as indicated above and in Figure 2.

3.2 Project Justification

The Project is intended to increase the capacity for international telecommunication services to Sierra Leone, Liberia, Gambia, Senegal, Guinea, Cote d’ Ivoire, Ghana, Benin, Nigeria and to other counties along the west coast of Africa. Although the region has experienced explosive growth in phone use in recent years, it remains severely constrained with respect to access to cable capacity for international transmission and global connectivity.

The Project will provide open access to regional telecommunication operators and internet services. The system will ease the difficulties and reduce the costs of switching telecommunications traffic between African countries without the need to go through Europe, as well as provide broadband capacity to expand internet access in the sub-Saharan region.

The network ACE Submarine Cable System will facilitate transmission of data of various bandwidths, voice, internet and television signals allowing for inter country transmission of data thereby reducing the cost of data transfer and bridging the information gap between Africa, West Africa and the rest of the world.

3.2.1 Connectivity challenges in The Gambia

High-speed internet access has remained elusive to The Gambia in spite of the progress made in recent years as far as mobile connectivity is concerned. Indeed, internet connectivity in The Gambia is very slow to the effect that people spend so much time idly staring at pages loading at snail's pace or at lost network connections.

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Most of the country and the region rely on satellite networks, which, by the time signals are beamed to earth and dispersed, are very slow and discouraging. Purchasing extra capacity on satellites is costly and often does little to increase speeds. An hour of computer time can cost over $1.25, but little can be accomplished because of the network traffic crawl.

Africa has the lowest household broadband penetration rate in the world at 2.3 percent as of September 2009, according to research firm Informa Telecoms & Media. The penetration rate in the Middle East, the next lowest, is 9.4 percent.

A way out for The Gambia to get its share of broadband subscribers is to bring fiber optic cables that can carry across the Atlantic Ocean vast amounts of web, voice, data and video traffic at high-speeds and improve internet access as well as bringing connection costs down for providers and consumers.

3.2.2 Existing Data Transmission Capacity in West Africa

Currently the SAT-3 system is the only international fibre optic cable serving the West African coast. It has been in service since 18 April 2002. The landing towns and beneficiary countries include Melkbosstrand-South Africa, Luanda-Angola, Libreville-Gabon, Douala-Cameroon, Lagos- Nigeria, Cotonou-Benin, Accra-Ghana, Abidjan-Ivory Coast, Dakar-Senegal, Alta Vista-Gran Canary Island, Chipiona-Spain, Sesimbra-Portugal. The Gambia is not a beneficiary of the SAT-3 system.

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

3.3 Benefits of the Project

3.3.1 Primary Benefits

Increased Capacity The Project will have direct benefits through increase in available international transmission capacity and lower cost for such access. For existing businesses, increased capacity and lower cost will allow for faster and more reliable transmission for data and voice. This can result in an improvement of business performance as well as create opportunities for expansion. Lower entry costs will also facilitate the start-up of new businesses. The Project will also improve the connectivity between African countries on the system. This will also allow for improved voice transmission quality. It could also facilitate increased business cooperation between the countries on the system.

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3.3.2 Indirect Benefits

In addition to the direct macroeconomic benefits of increased telecommunications access and reliability in West Africa, many other indirect social and economic benefits would be associated with the proposed development. These include:  improved educational opportunities through increase in access to information and education resources;  development of a regional sense of community through greater equality of information sharing across geographical regions and across groups in society;  economic benefits from the enhanced opportunities for new and small enterprises that may have previously been excluded from technologies by high costs; and  macroeconomic benefits of the potential expansion of technology-reliant industries in West Africa, such as information technology services and software development businesses.

3.4 Project Components

The main components of the project will comprise:  A submarine cable system comprising a deep sea cable in the international waters from France to The Gambia, and a connecting cable from the deep sea cable to the BMH at the shores of Bijilo near Banjul; and  A CLS at Brusubi Phase III Institutional Area.

Figure 3 is a map showing the ACE cable route from the BMH to the CLS.

Figure 3: ACE Cable Route from the BMH to the CLS

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3.4.1 The submarine cable system

The proposed system will comprise an optical fibre submarine communications cable to carry telecommunications between The Gambia, France, Europe and rest of the world. An optical fibre is a glass or plastic fibre that carries light along its length. Submarine cable systems usually consist of subsea cables, repeaters and branching units.

Subsea Cables The construction of subsea cables varies with manufacturer and seabed conditions. Cable engineering specifications for the proposed Project will be based on cable industry standards. The diameter of subsea cables varies between 17mm and 20mm for sections without protective armour; armoured cables may be as large as 50mm in diameter. The cable consists of an inner optical fibre, surrounded by a polyethylene or fibre-glass core for strength and fibre separation. The core is normally surrounded by two polyethylene jackets and copper conductor layer and the outer layers comprise a steel wire protective armour layer and an outer protection and wire containment (polypropylene yarn). Figure 4 shows a typical submarine cable system. Illustration of typical cable design is provided in Figure 5.

Figure 4: Typical Submarine Cable System

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Figure 5: Illustration of Cable Design and Types

Cable Types The ACE cable system will comprise of wholly new equipment manufactured by Alcatel-Lucent Submarine Networks (ASN) based on the specific design requirements resulting from the Cable Route Studies (CRS) and cable route survey. The cable will be of repeated type and will have the following cable armouring options:  Light Weight (LW)  Light Weight Protected (LWP)  Single Armour Light(SAL)  Medium Double Armour (MDA)

Cable type selection and the depth at which transitions are located (up to maximum qualified depth) will be based on the results of the marine survey and ASN route engineering guidelines.

3.4.2 Description of Marine Operations

Marine operations required to install submarine systems include:  Cable Route Survey;  Route Clearance;  Pre-Lay Grapnel Run;  Cable Surface Lay;  Cable Burial;

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 Post Lay Inspection and Burial; and  Shore End Landing.

All cable ships and other vessels used in the installation of submarine systems by Alcatel-Lucent are MARPOL compliant and fully certified and accredited.

Cable Route Survey The marine cable route survey, in conjunction with desk top studies and local consultations, not only identifies the optimal route for a submarine cable in terms of cable security and protection, but also highlights the existence of sensitive habitats such as coral reefs and other important littoral ecological complexes including seagrass, mangrove and dune formations. The desk top study component of the survey also identifies protected areas, nesting sites, migratory routes and the presence of threatened and endangered species. Overall, properly executed surveys result in routes that to the greatest extent possible avoid sensitive habitats.

The survey determines cable length and type (including the appropriate level of cable armouring), which are essential inputs to the system design and cable manufacturing processes, and also establishes the methods to be followed for cable deployment. The survey also generates a reference record that supports subsequent maintenance and repair of the cable.

In water of depths less than 1000m, swath bathymetry, side scan sonar, seismic profiling and a geotechnical survey are performed. In water of depths greater than 1000m, multibeam bathymetry only is required. The nominal corridor to be surveyed is 500m wide, which allows adjustment of the cable location if unfavourable conditions are found. The final installed cable will lie within the survey corridor.

At water depths between about 15m and 1000m, it is common practice to bury the cable to a depth of about 1m in the sea bed, to protect it from hazards such as deep sea fishing trawls. This is only done where conditions allow, generally in sandy and muddy sediments. Cable route survey therefore incorporates burial assessment, which is achieved by testing the mechanical properties of the seabed along sections of the proposed route. The sediments are investigated by geophysical means (side scan sonar and subbottom profiler), and by intermittent physical samples (grab samples and/or penetrometer tests).

Additionally, an inshore cable route survey (generally between 0 and 15m water depth) is conducted using small boats and divers to perform visual checks of the seabed and map an optimized route for the cable as it approaches the shore. The inshore survey is normally conducted along a corridor about 200m wide, providing flexibility to adjust the cable route to avoid hazards and minimise threats to marine habitats.

If necessary the survey may incorporate video footage or mapping of important ecological zones, habitats and features, to ensure that they will not be damaged, or to support planning of mitigation and compensation measures where impact is unavoidable.

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Where survey operations take place in and around sensitive sites, habitats are protected by careful anchoring of survey and support vessels, and by instructions to divers to avoid contact with corals and other sessile organisms.

Route Clearance The purpose of route clearance (RC) is to clear the cable path of all linear obstacles such as out of service (OOS) cables identified during the cable route survey, since these can be hazardous both to the vessel’s burial equipment and to the cable itself. RC is only carried out in areas where burial is deemed necessary.  The vessel positions itself perpendicular to, and in close proximity to, the OOS cable indentified during the survey.  The Grapnel (either a Deep Trenching Grapnel or DTG for buried OOS cables, or a normal grapnel for surface-laid OOS cables) is lowered off the stern of the vessel using the A-frame.  The vessel then moves towards the OOS cable, allowing the fluke of the DTG to penetrate the seabed and unbury the cable.  The vessel continues to move until the cable is broken, leaving the two ends on the seabed.  The vessel performs grapnel runs to retrieve each end individually.  Once on the deck, a portion of the cable is cut and clump weights are attached to the ends.  The vessel then returns the ends to the seabed, leaving between them a space of approximately 1km through which the new cable will be installed  The cut cable lengths are kept onboard and disposed of onshore at authorized waste disposal facilities.

Pre Lay Grapnel Run A Pre-Lay Grapnel Run (PLGR) is carried out only along sections of the route where burial is intended. Undertaken just before ploughing commences, PLGR is intended to clear the route of obstacles and debris that could damage or obstruct the plough (rocks, fishing equipment etc). PLGR is achieved as follows using a series of linked chain grapnels:  At the Plough Down position, the linked grapnels are lowered off the bow of the vessel.  Once the Grapnels have landed on the seabed, with slack to ensure maximum coverage, the vessel will then move forward along the planned route  The forward motion and design of the Grapnels creates a clear path by penetrating the seabed and hooking any linear obstacle  The grapnels are retrieved to the vessel’s deck at least every 20km, or when a large tension is registered by the vessel, as this will indicate that an unidentified obstacle has been hooked  All retrieved debris is kept on board for safe disposal onshore at authorized waste disposal facilities.

The grapnel will penetrate the seabed to a depth of 40-80cm. Potential impacts of the operation are minimized by avoidance of sensitive areas such as coral reefs, which are in any case often unsuitable substrates for cable installation.

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Installation of the Submarine Cable The marine cable installation proceeds along the selected route, which will have been optimized on the basis of the survey data to balance considerations of system cost, cable security/protection, and environmental and regulatory interests and constraints.

In water depths typically exceeding 1000m the cable is laid on the surface of the sea-bed.

Where geology and environmental considerations allow, the cable is buried in the sea bed to a burial depth of approximately 1m in water depths of less than 1000m.

An industry-standard cable plough weighs approximately 24 tonnes in water. It is deployed from the stern of the installation vessel and towed behind the ship, burying the cable into the seabed as it progresses along the route. Burial is achieved using a share blade: as the plough is towed through the seabed, it lifts a triangular wedge of soil and depresses the cable into the cut trench; as the plough progresses forwards, this sediment is dropped back into the trench to cover the cable The process of lifting and replacing the wedge of sediment is continuous and results in very little disturbance to the soil inside the wedge. Figure 6 shows examples of a typical marine plough.

Figure 6: Examples of Marine Ploughs

Continuous video monitoring of the plough operation from the vessel allows the plough to avoid hazards or features of interest, whether these are pre-identified or unexpected. An instruction to “plough with caution” may be issued if the risk of encountering such hazards or features is considered high.

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Cable Burial

According to the provisional cable route study report, there is a significant risk to the ACE cable systems surface laid cables in water depths less than 1000m. This risk is as a result of fishing, offshore petroleum extractions, anchoring and other offshore activities and is present along all segments in water depths of less than 1000m. In order to mitigate the threat to the ACE cable system cable burial is planned in water depths less than 1000m.

Cable burial is proposed to be by trenching/ploughing or ROV Post Lay Burial (PLB). According to the provisional CRS report, burial is feasible over the continental shelves of France, Portugal and West Africa, which also covers The Gambia. However, a comprehensive marine cable route survey and burial assessment studies are recommended to ascertain the geotechnical properties of the seabed and shallow subsurface materials and to design the optimum cable route.

Post Lay Inspection and Burial - Remedial Burial Operations Post-lay burial is undertaken to bury sections of cable where plough burial has not been possible, but where burial is nevertheless needed to protect the cable.

Water-jetting ROVs (remotely operated vehicles) are used typically between 15-1500m water depth. They may be either tracked or free-swimming vehicles. Free-swimming ROVs are neutrally buoyant and have very little contact with the seabed. Tracked vehicles leave minor depressions in the seabed, due to the action of their caterpillar-tracks.

Post-lay burial in shallower water (0-15m) is undertaken by divers using jetting machines. Diver- assisted jetting uses a hand-held device in which the pressure is low, so the physical effect on the seabed is limited.

Shore-end Landing Shore-ends are generally landed from the main-lay cable ship. The cable is buried across the beach, both for system security and for environmental and public safety reasons. The cable trench is dug using hydraulic digging machinery and the beach is returned to its pre-installation state after cable burial.

Shore-end operations are usually completed within one day, although some preparations may be made on the previous day:  The cable ship is dynamically positioned at a water depth between 12m and 14m (depending on sea conditions). This is typically between 500m and 1500m from the coast.  The vessel sends a floating line to the beach.  The shore end crew will attach this line to a pulling device (an excavator, winch, or similar).  The line is then attached to the cable (kept afloat by buoys) and pulled up the beach into the beach manhole (BMH).  The cable is jointed in the BMH and the offshore cable floats cut away by divers, allowing

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the cable to fall to the seabed and to be positioned along the optimized route.  Diver jetting and/or articulated piping may be used to immobilise the cable, protecting it and the seabed from risk of abrasion or “cable strumming”. The buoys are returned to the vessel.  An inspection of the inshore as-laid cable route is carried out by divers and recorded on video.

Post lay Inspection At water depths inaccessible to divers, an ROV inspection of the cable is usually carried out to ensure that the burial operation has been successful. This operation is coincident with the post- lay burial, utilising the same vehicle. During inspection, the ROV in free-swimming mode merely tracks along the route, recording on video the position of the cable with respect to the seabed.

Cable Protection Considerations/Articulated Pipe

Cable protection considerations will be confirmed after the marine cable route survey has been carried out. In the near shore zone to the landing site, external protective measures such as articulated split piping will be considered to guard against cable damage due to surf zone wave action, local currents, and in high risk areas over rock and coral outcrops in water depths less than 20m.

Articulated piping serves to increase cable protection against chafing caused by wave action and will be of particular importance where the cable cannot avoid routing over rock or coral in areas of shallow water wave action.

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

3.4.3 Proposed Infrastructure Installations

Major facilities/Infrastructure The major facilities/infrastructure to be installed at the beach and the Brusubi sites include the CLS (building), Zero manhole, BMH, connections conduits and ducts, generators, fuel tanks, transformer, switch board and cable drums.

Cable Landing Station (CLS) Building A generic sketch plan of the cable station is provided in Figure 7. The cable station is expected to take about 45m x 25m land space. The cable station building will have the following:  An equipment room for the submarine cable equipments;  A control room (supervision, monitoring);  An energy room (batteries, rectifiers, UPS, transfer switch board;

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 Two separate cable entrances;  A storage space;  An office and work facilities; and  A training/meeting /crisis room.

Figure 7: Plan of the Sable Station

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Figure 8 shows the block plan of the CLS.

Figure 8: Block Plan of the CLS

The following will be provided outside the building:  A diesel generator;  Fuel tank;  A transformer and the main switch board; and  A spare land cable drum.

Manholes: BMH, Zero Manhole, Intermediate Jointing and Intermediate Pulling Manholes The BMH will be constructed to international standard and will have the following dimensions: Length = 4m; Width = 2m; and Height = 2m. The manhole structure will be built with reinforced concrete with a lockable cover. From the BMH toward the sea, two pipes of 150mm/ 200mm diameter will be installed and from the BMH toward the zero manhole of the landing station, a conduit of three pipes of 45mm/ 50mm diameter will be installed.

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The zero manhole is the land cable entry in the building. The manhole will be a reinforced concrete structure with a lockable cover. It will have the following minimum inside dimensions: Length = 3m; Width = 2m; and Height = 2m.

Two other manhole types will be provided including the (i) intermediate Jointing Manhole (IJM) and (ii) intermediate Pulling Manhole (IPM). The IJM will be about 2km apart with the following dimensions: Length = 3m; Width = 2m; and Height = 2m. The IPM will be of a maximum interval of 0.5km with dimensions: Length = 1.5m; Width = 0.75m; and Height = 1.2m.

3.5 Project Schedule

The Construction and Maintenance Agreement (C&MA) of ACE submarine cable project was signed on Saturday June 5, 2010.

In its planned configuration, the 17,000km-long fiber optic cable stretching from France to South Africa will be operational in the first half of 2012. It will connect 23 countries, either directly for coastal countries or indirectly through terrestrial links for landlocked countries, like Mali and Niger.

3.6 Maintenance and Repair

If, during its operational life of up to 25 years, the submarine cable is damaged or broken, for example by fishing gear of ships’ anchors, it may be necessary to retrieve and remove damaged sections and replace them with new cable which is spliced into the system. Cable recovery involves grapnel operations similar to those used in route clearance.

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4.0 ALTERNATIVE ANALYSIS

Besides the proposed ACE submarine cable, some other individual cable systems off the west coast of Africa include:  ATLANTIS-2;  GLO-1;  Main One;  SAT-2;  SAT-3/WASC; and  WACS.

4.1 Technology Alternatives

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

Bandwidth demand, particularly as a result of internet activity far exceeds satellite capacity at the present time (Hogan and Hartson, 1999). A comparison between cables and satellites is provided in Figure 3:1 below.

Source: www.iscpc.org Figure 9: Comparison Between Cables and Satellites

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4.2 Routing Alternatives

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

It is however noted that a small portion of the cable, about 3km span will be land based.

4.3 Cable Laying Options- Burial and Non-burial

The advantages of cable burial and advantages of laying cables directly on seabed are discussed in Table 2.

Table 2 Comparing Study of the Advantages of Burying Cables and Laying Directly on Seabed Advantages of Burying Cables under Seabed Advantages of Laying Cables on Seabed Cables are protected from shipping, fishing and Cost of installation is cheaper other activities near-shore Protection from trawl fisheries in deep waters Installation is faster Cables not exposed to shark bites Cables are easy to access or recovered for repairs, maintenance and replacement Safety and security of cables are assured Little or no disruption of seabed during cable laying Limited or no restriction of sea use around cable Cables can form artificial reefs which attract a range of routes by other marine or sea users marine organisms from algae to fish

Project choice The project will adopt both burial and non-burial options depending on the water depth and seabed conditions. Under this project, cable burial will be carried out in water depth less than 1000m.

4.4 Cable Type Options

The cable type options available for this project are provided in Table 3.

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Table 3 Submarine Telecommunication Cable Types Cable type Approximate length Application Feature Double armour buried 90 km -Rocky terrain Two armour wire layers -High risk of trawler damage applied to core cable -Moderate abrasion risk -Depth to 600 m Single armour 10 km -Very rocky terrain Heavy armour wire layer Single armour buried 30 km -High risk of trawler damage applied to core cable -Depth to 1,200 m Light weight armour 10 km -Rocky terrain Light armour wire layer -Moderate risk of trawler damage applied to core cable -Depth to 1,500 m -Normally used for burial Light weight 7,150 km -Benign, sandy bottom Core cable, light -Depth to 8,000 m protection

Project choice The cable type selection for the project will be based on the results of the marine survey to be carried out and ALSN route engineering guidelines.

4.5 Landing Station Site Options

A cable landing station (CLS) is the location where a submarine or other underwater cable makes landfall. The landing or termination station can also be the point at which the submarine cable connects into the land-based infrastructure or network.

Two proposed sites for the landing station were considered under the project and these include:  The site at Brusubi Phase III Institutional Area; and  The BMH site behind Lemon Creek Hotel at Bijilo.

Figure 10 shows the location of the sites.

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Figure 10: The Location of the BMH and CLS

4.5.1 The Brusubi Phase III Institutional Area

This site is acquired for development of institutional infrastructure and currently lies fallow. It is approximately 3km from the BMH at the beach. The land currently has no permanent structures and borders the Brufut-Sukuta Coastal road. The site is about 2,800m2 (40m x 70m) and has the following coordinates N13o24.785’ and W16o43.126’. Plates 1a&b shows some photos of the site, which is suitable for the CLS.

Plate 1 (a & b): The CLS Site at Brusubi Phase III Institutional Area

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4.5.2 The BMH Site Behind Lemon Creek Hotel

This site is principally administered by The Gambia Tourism Authority (GTA) and leased to investors for development of tourism facilities. It is in the same vicinity as the BMH site at the beach. The land is at the beachfront and has the following coordinates N13o25.205’ and W16o44.242’. Use of this site as a CLS may not be suitable. Plates 2 (a & b) shows some photos of the site.

Plate 2: The Lemon Creek Hotel at Bijilo Beach with Proposed BMH Site Indicated with Red Arrow

4.6 No Project Scenario

Under this option, the proposed Project would not be executed. In this scenario, the development of the country will continue to be constrained by lack of telecommunications capacity, especially in the area of international data transfer. The demand for capacity will continue to grow along with the overall economic growth. The cost of data transfer will increase as private investors may exploit the situation.

The environmental and social impacts associated with the proposed project will not arise but a different and greater negative impact on the national economy will arise. New and international business entities may not bring in the needed investment into in a very poor telecommunication service environment. Existing businesses will not grow as expected. Unemployment will continue to increase and the cost of doing business will remain high.

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5.0 ENVIRONMENTAL AND SOCIO-ECONOMIC BASELINE CONDITIONS

The existing physical and socioeconomic environment of the project area is presented in this chapter.

5.1 Location and Size

The proposed project is to be located in the Bijilo area of the The Gambia, a West Africa country and bordering the North Atlantic Ocean and Senegal. It’s geographical coordinates is 13°28′N 16°34′W The total area is 11,300km² with a land area of 10,000km² with water occupying 1,300km². It’s coastline spans about 80km and the land stretch is about 740km while the major river, Gambia river spans the whole country and empties into the Atlantic Ocean near Banjul, the Capital.

The grassy flood plain of the Gambia river contains Guinean mangroves near the coast, with West Sudanian savanna upriver inland. The terrain is dominated by the flood plain of the Gambia river flanked by some low hills, the lowest point being the Atlantic Ocean (0m) while the highest point is the Red Rock at (53m). Figure 11 is a map of the Gambia showing the only neighbouring nation, Senegal while Figure 12 shows the Administrative setting in The Gambia, which indicates that the proposed project will occur within the Kombo North District of the Western Region of The Gambia.

Figure 11: Map of The Gambia

Fish, groundnuts (peanuts), titanium, tin, zircon, silica sand, clay, petroleum are some of the natural resources of The Gambia.

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Figure 12: Administrative Map of The Gambia

5.1.1 The Cable Location

The submarine cable on reaching the shores of The Gambia will be connected to the BMH at Bijilo beach, and terminated at the Cable Landing Station (CLS) at Brusubi Phase III Institutional Area. Figure 13 shows the cable route.

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Figure 13: The Terrestrial Cable Route

5.2 The Atmospheric Environment

5.2.1 Climate

General Climatic Conditions

The proposed submarine cable termination infrastructure in The Gambia including the BMH and CLS fall within the subtropical climatic region with distinct cool and hot seasons. The dry season generally starts in October and ends around mid-June each year.

Fanned by the north-east trade winds the average daytime temperature along the Atlantic beach is around 24oC in contrast to the about 32°C for the whole country. In the evenings the temperature drops to around 16°C. Along the western part of the country, known as the Kombos, temperatures are moderated by the Atlantic Ocean with less seasonal and daily variability in daytime temperatures. There are about 9 hours of sunshine everyday with virtually clear skies during the dry spell.

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Between January to May the humidity level is at about 50-60%. This period is characterised by several phases. The first half of this period is generally cool and dry and the early stages can sometimes be marked by cloudy days but no rain and there is considerable cooling off in the evening. The second half is marked by very cool, dry winds in the evenings and warm sunny days on the coast and at the capital.

Up-country, between February and May, the climate is characterised by the so called Harmattan is characterised by very dry, dusty winds which adds a haze to the atmosphere making visibility difficult and at about 50m and characterised by a blanket of fine dust particles (from the Sahara and Sahel) over the land.

The other distinct climatic season is the rainy season, known locally as "Nawet", which is caused by the summer heat causing the air in the Sahara to rise thus creating an area of low pressure which encourages monsoons as it meets with the north east trade winds coming of the Atlantic Ocean in an inter-tropical front. Fog can occur off the coast when the relatively warm Guinea stream meets the cooler Canary current. This rainy period starts around the middle of June and ends around the middle of October with August being the wettest month of the year. Relative humidity levels can rise to 95% and temperatures can reach a skin tingling 43oC.

The average annual rainfall ranges from 920mm in the interior to 1,450mm along the coast. The storms are very often short and spectacular as huge volumes of rain descend on the land transforming from brown parched patches to a rich green landscape of foliage. Normally the cloudbursts occur during the night time and when they occur during the day they are short-lived leaving clear blue skies.

The climatic data for the area obtained from the Department of Water Resources (DWR) has been assessed using information from the Yundum meteorological station close to the International Airport. The details are presented in the annex as Annex 3.

Rainfall The rainfall events in the area are often intense, torrential and stormy. The resultant runoffs are very intense and short lived and accompanied by massive sheet erosion of loose soil material, especially where the vegetative cover is removed. Rainfall distribution has one peak i.e., in August while the main season is from mid June to mid October.

Annual Rainfall: The statistical summary of the annual rainfall for the area ranged from 423.6mm – 1,443.4mm with a mean value of 895.0mm for the 30 year period.

Monthly Rainfall: The Statistical Summary of the mean monthly rainfall for the meteorological stations are presented in Table 4 and illustrated further Figure 14.

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Table 4: Statistical Summary of Rainfall for the Period 1981 - 2010 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Mean 0.4 0.6 0.0 0.0 2.0 64.1 227.2 306.0 237.6 56.2 0.4 0.4 Max 12.6 10.6 1.3 0.0 45.4 361.6 654.2 547.3 681.3 169.8 5.2 5.1 Min 0.0 0.0 0.0 0.0 0.0 0.0 46.7 185.4 71.4 0.0 0.0 0.0

Mean Rainfall (mm) 700.0

600.0

500.0

400.0 Mean 300.0 Max Min 200.0

100.0

0.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 14: Graphical Presentation of Mean Monthly Rainfall

Temperature The daytime temperature for the area ranged from 29.7oC in January to 42.8oC in February, while the mean daytime temperature varied from 31.1oC in August to 34.7oC in March for the 30 year period.

Similarly, the nigh-time temperature for the area ranged from 15.2oC in December to 25.4oC in June, while the mean night-time temperature varied from 26.5oC in January to 36.8oC in August/ September for the 30 year period.

The statistical summary of the daytime and night-time temperature data are provided in Table 5 and further illustrated as Figures 15 and 16.

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Table 5: Statistical Summary of Temperature Data for the Period 1981 - 2010 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Daytime Mean 32.5 34.3 34.7 33.4 32.8 32.8 31.5 31.1 31.6 32.7 33.7 33.1 Max 34.9 42.8 36.7 34.8 35.1 33.9 33.0 32.0 32.7 34.1 35.3 39.8 Min 29.7 31.0 30.9 31.6 30.3 31.4 30.7 30.1 30.5 31.9 32.0 30.1 Night-time Mean 26.5 28.4 29.3 31.2 33.0 34.9 35.5 36.8 36.8 36.3 32.8 29.9 Max 18.8 20.1 20.3 21.2 23.7 25.4 24.6 24.4 23.9 24.4 21.5 20.3 Min 15.4 16.6 17.8 18.3 18.3 21.1 22.6 22.3 21.1 19.9 17.2 15.2

Daytime Temperature (oC) 44.0

42.0

40.0

38.0

Mean 36.0 Max 34.0 Min

32.0

30.0

28.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 15: Graphical Illustration of Daytime Temperature

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Night-time Temperature (oC) 40.0

35.0

30.0

Mean 25.0 Max

20.0 Min

15.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 16: Graphical Presentation of Night-time Temperature

Mean Relative Humidity Mean Relative humidity is generally low between the months of November to May and high during the rest of the year. The mean Relative Humidity data for the 30 year period ranged from 31.0% to 98.0% as shown in Table 6 and further illustrated in Figure 17.

Table 6Statistical Summary of Mean Relative Humidity Data for the Period 1981 - 2010 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Mean 47.3 51.1 55.1 63.7 70.5 76.0 81.6 87.1 86.9 82.1 69.6 56.6 Max 66.0 64.0 64.1 71.5 74.0 84.6 86.9 98.0 97.0 86.0 79.0 71.1 Min 31.0 38.0 44.0 46.0 67.0 73.0 75.0 82.6 83.6 68.5 56.0 47.0

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Mean Relative Humidity (%) 100.0

90.0

80.0

70.0 Mean 60.0 Max Min 50.0

40.0

30.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 17: Graphical Presentation of Mean Relative Humidity Data

Wind Speed The wind speed data for the area suggest that the mean daily wind speed for the 30 year period ranged from 2.0knots to 10knots as shown in Table 7 and further illustrated in Figure 18.

Table 7: Statistical Summary of Wind Speed Data for the Period 1981 - 2010 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Mean 7.0 7.3 7.9 8.2 7.9 7.1 5.7 4.7 4.2 3.7 4.1 5.7 Max 8.3 9.1 9.6 10.0 9.6 8.7 8.0 6.2 6.8 7.8 9.3 8.9 Min 3.6 5.2 5.0 5.9 5.1 4.6 3.0 2.8 2.5 2.0 2.5 3.6

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 18: Graphical Presentation of Wind Speed

Sunshine The mean sunshine for the project area ranged from 4.4hrs to 10.9hrs and averaging 7.5 hours over the entire period as shown in Table 8 and further illustrated as Figure 19.

Table 8: Statistical Summary of Sunshine Datal for the Period 1981 - 2010 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Mean 7.9 8.3 8.5 8.7 8.1 6.9 6.1 6.1 6.4 7.8 8.0 7.5 Max 9.7 10.3 10.1 10.4 10.1 10.9 6.9 7.9 7.9 8.9 9.7 8.9 Min 5.8 4.9 5.8 6.5 5.1 4.6 5.0 4.7 4.4 6.6 5.2 5.8

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Sunshine Duration (hours)

11.0

10.0

9.0

8.0 Mean

7.0 Max Min 6.0

5.0

4.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 19: Graphical Presentation of Sunshine Duration Data

5.2.2 Noise Assessment

Noise levels assessment was carried out simultaneously with dust levels at the Lemon Creek Beach, BMH and CLS sites using castle 1900 type A Precision Sound Level Meter. The instrument was positioned at a height of 1.2 meters above ground.

The meter was calibrated prior to monitoring and the data logged at 3 seconds interval. The results of the noise level assessment are summarized in the Table 8.

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Table 9 Results of Noise Level Assessment

Sample ID Sampling Site Leq Lmax Lmin L10 L50 L90 A1 Lemon Creek Beach at Edge of the Sea 76.8 62.3 91.4 86.4 76.9 68.3

A2 BMH Site at Middle of the Road 65.3 55.6 73.6 71.7 65.4 58.8

A3 CLS Site at Edge of the Side Road 62.6 47.7 84.2 76.4 59.0 52.1

IFC Noise Level Guideline for Commercial Areas 70.0 - - - - -

Legend Leq - Integrated noise level during the measurement period Lmax - Maximum noised level Lmin - Minimum noise level L50 - Average noise level L10 - Nuisance noise level L90 - Background noise level

The integrated noise level during the measurement period was 65.3dB(A) for the BMH site and 62.6dB(A) for the CLS site and thus within the IFC permissible noise limit of 70dB(A) for predominantly commercial areas. The beach front had a noise level of 76.8dB(A) indicating effect of the wave action on the noise levels at the beach, which is usually in the form of a humming sound.

5.3 The Land Environment

5.3.1 Relief/Topography

The geomorphology of the Gambia is dominated by the Gambia River. The Gambia River divides the country into two strips of land no wider than 30km. The country is generally low-lying with high areas not exceeding 60m. Thus, only four percent of the country’s land area is above 50m. Over 48% of the total land area of the Gambia is below 20m high with nearly one-third of the country, at or below 10m above sea level. From the river outwards, one can identify three topographic regions: (i) The valley bottom, (ii) dissected plateau with sandy hills, and (iii) a sandstone plateau.

The Valley Bottom The valley bottom is the area immediately along the Gambia River and its tributaries. The area is characterized by poorly drained alluvial sediment formations. These areas are subjected to regular seasonal flooding. The combination of low-lying topography, poorly drained soils and abundant water provides unique and diverse habitats. The valley makes up nearly 4,048km2 or 39% of the land area. From MacCarthy Island, westward, the valley broadens and seasonally inundated swamps, appear on either sides of the river. These swamps extend for more than 2km away from the river.

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The soils and vegetation in the valley bottom is primarily influenced by the hydrology. In western third of the Gambia, where the river water is salty or brackish, the soils are clay and alluvium and heavily impregnated with salt. The only vegetation that thrives in such condition is mangrove forest. The freshwater areas, the soils are often light alluvium and are more fertile and are for centuries the center for rice production in the Gambia. The natural vegetation in this area is dominated by swamps grass and marshes.

Dissected plateau with sandy hills Upland Gambia is dominated by dissected plateau with sand hills. This area is characterized by gentle rolling sand hills alternating with shallow valleys. In the coastal region, the soils are generally unconsolidated marine and aeoline sand with intermittent low-lying sand dunes. Underlying these unconsolidated soils are the ferruginous sandstones, which form cliffs about no more than 20m high of Cape St. Mary. In central and eastern Gambia the plateau is broken up by few flattop laterite sandy hills.

Natural vegetation in the plateau is along a precipitation gradient, ranging from trees and shrub savannah in the northeast to multi-story tropical forest in the southwest. All but a few pockets of the original vegetation of the plateau areas are modified or converted for cropland expansion, settlement and wood collection. The plateau is the center for groundnut (the country’s number one cash crop) and coarse-grains (millet and sorghum) production.

Sandstone Plateau The eastern end of the country is enclosed by low, rocky sandstone hills, which extend into Senegal. Occupying about 4% of the total land area, these hills are often unproductive rugged, uncultivated, un-vegetated. Major crops cultivated in this area are groundnuts and millet.

5.3.2 Geology and Soils

Geology of the Gambia is of relatively recent origin, Tertiary and Quaternary period. The country is part of the Tertiary Continental Terminal Plateau covering 53% of the land area with alluvial deposits of Quaternary period along the river. Occasional marine intrusion and deposits on the terrestrial sand and sandstone characterize the geological periods. Alternation of wet and dry periods resulted in the formation of iron pan during the Pleistocene period.

Generally, the soils are dominated by hard clays and sandy soils in the project area.

5.3.3 Biodiversity (flora and Fauna)

The vegetation cover of The Gambia is savanna on the uplands, various kinds of inland swamp in the low-lying areas, and mangrove swamp along the brackish lower Gambia River. Few wild animals are native to the region, and those that survive are under pressure from the human and domestic animal populations. In the middle and upper river areas there are warthogs, monkeys,

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baboons, antelope, pygmy hippopotamuses, and crocodiles. In addition, more than 500 species of birds live throughout the country. Birds and wildlife can be found in Bijilo Forest Park, along the Atlantic coast, the , just upriver from Banjul, , farther inland, and River Gambia National Park (also known as Baboon Island National Park), near Kuntaur.

The land use classes are closed forest, open forest, savannah, cultivated area and high mangroves.

5.4 Oceanography

5.4.1 General Conditions

The largest population density in The Gambia is along the coast where the employment possibilities are greater by far than in the rest of the country, mainly because of the tourism sites and government institutions. The Gambian coast has naturally been divided by the Gambia river in two parts or regions, Northern and Southern. The River Gambia discharges into the Atlantic Ocean. The Gambia is located in an area affected by trade winds, canary current and upwelling system. These natural conditions support aquatic fauna and flora.

5.4.2 Physical Oceanography

The Gambian coastline is characterised by a series of embayments, with long sandy beaches and rocky headlands that protrude seawards. The headlands are low and composed of nodular or pisolitic laterite and sandstone rocks, large blocks of which are commonly found broken off and scattered over the foreshore area.

Coastal Dynamics Tides in The Gambia are of the semi-diurnal type with two daily high and two daily low waters in each lunar day. Spring tides occur at full moon and new moon; neap tides occur at first quarter and last quarter of each year. Generally, the ebb stream continues to run after time of low water for approximately one hour at spring tides and for one and half hours at neap tides (GPA, 2011). Tidal ranges are low; at Banjul, for example, the tides of highest magnitude or spring tides are of 1.6 m, whilst the neap or lowest tide is 0.7 m. Though tidal regimes are small, large areas of the low lying coastal plain could be submerged during high tides and storms. Tidal currents, especially those generated during ebb tides, are capable of removing the fine sands out to sea. The only exception is the Gambia River estuary where the tidal currents exceed 1 m/s. The strength of the coastal current however, ranges between 2 to 3.5 knots depending on energy of spring or neap tides (GPA, pers. comm.).

The coastal area experiences the following winds: (i) marine trade winds which account for 43% of the average readings at Banjul, (ii) the NE or Hamattan 17%, and (III) the rain-bearing NW

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18%, the rest being calms (Delft Hydraulics, 1992). The strength of the wind is 5 to 6 force on the Beaufort scale (GPA, pers. comm.).

The Gambian coast is affected by northerly to north-westerly swell wave regimes which are more dominant during the dry season. The NW swell is thus the main factor controlling the regional coastal morphology. It induces a major south-going sedimentary transit owing to the general coast orientation. However, the west-east oriented coast between the Cape St Mary and Banjul, experiences an east-going littoral drift which is strengthened by the flood dominated tidal flows running close to the shore. These two mechanisms thus promote a littoral drift directed from the Buniada Point in the north and the Cape St. Mary in the west towards the estuary mouth which acts as sediment sink. With regard to wave action from the Atlantic Ocean, the prevailing wave direction is the NW swell (98%) which is the most important factor in explaining the littoral regime. Because of the general north-south orientation of the coast this swell induces a major south-going sediment movement, particularly south of the Bald Cape to the Allahein River.

Between the Bald Cape and the Cape Saint Mary (oriented SW-NE) however, the littoral drift goes in the opposite direction, northwards. Between the Cape Point and Banjul the coast is oriented W-E and east-going littoral drift is being experienced. In the north between the Barra Point and the Buniadu Point, the drift is southerly along the North-South oriented coast. The littoral drift along the coast south of the Bald Cape has been estimated at 100,000 m³/yr to 250,000m³/yr. based on the Sangamar spit development at the mouth of the River Saloum (Delft Hydraulics, 1992). East of the Cape Saint Mary, the littoral drift is between 30,000 m³/yr and 100,000m³/yr.

It is estimated that the combined effects of waves and tides result in the littoral drift estimated at 200,000m³ to 300,000m³ annually along the Gambian coast. Much of the sediment in the littoral drift is derived from the beaches between the Banjul Point and the Saniang Point. This results in an average erosion rate of 1km/year to 1.5km/year, or 2.5 to 3.0 hectares of land annually.

The Delft Hydraulics report of 1992 concluded that the coastal watersheds, including the River Gambia and its estuary, contributed insignificantly to the sediment budget of the coast. In the River Gambia estuary an inward sediment transport is experienced due to the gravity circulation induced by the density gradient which in turn is caused by salt water intrusion. This estuary serves as a sediment sink rather than a source of sediment for the coast. Material is transported westwards towards the river mouth from upstream, while the coastal current moves the material eastwards into the estuary. Local streams and rivers debauching at the coast have too limited catchments to contribute any significant amount of sediment to the coast (see Table 10).

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Table 10: Sediment Transport by Local Streams Stream Catchment (km2) Transport m3/ year Near Barra 27 1,800 – 5,500 Oyster Creek 20 - Cape Creek 3 - Kotu Stream 65 4,500 – 9,000 Tanji River 145 10,000 – 30,000 Tujering River 26 1,800 – 5,000 Kakima River 100 7,000 – 20,000 (Source: Delft Hydraulics, 1992)

The Allahein River, on the other hand, has a larger catchment area of 500km² and flows more directly into the sea without a wide estuary. A sediment discharge at the mouth of the river is estimated at 30,000-100,000m³/yr. Sediments delivered here are transported southwards onto the Cassamance coast.

Coastal Geomorphology The coastline of The Gambia is about 80 km long, from the mouth of the Allahein River in the south (130º4' N) to the Buniadu point in the north (130º31'56” N). From the Allahein River to the Cape Saint Mary facing the Atlantic ocean, the coastline is about 56km long; from the Cape Saint Mary to the Banjul point 13km, and from the Barra point to the Buniadu point 11km. Seawards the coast is separated from the continental slope or deep sea by the continental shelf 80km wide, which is marked by the 200 bathymetric line. Landwards the coast consists of the catchments of the Gambia, Saloum and Allahein rivers at the northern and southern borders with Senegal respectively, and several small local rivers such as the Kotu Stream, Tanji River, Tujering River and River Kakima.

The embayed sandy parts have been prograding since the end of the Nouakchottian transgression i.e. about 5,500 years BP (Whyte, Stewart, Pijl 1981). The amount of progradation varies at different locations but is generally of the order of 200m-400m in the Batu Kunku area, and 500m-800m in the Sanyang and Kartong areas. These predominantly sand deposits, in both the surf zone (present beach) and the raised or ancient beach (usually covered with vegetation) have been grouped together as the Holocene Coastal Beach Complex. The raised beaches consist of yellowish medium to fine sands with distinctive black colouring as a result of heavy mineral presence. These sands have been originally reworked by waves and exceptionally high waters into series of broad, low ridges, parallel to the present shoreline, and later modified by aeolian processes (Whyte, Stewart, Pijl, 1981).

Landwards, behind the beach complex, the geology of the coastal area is made predominantly of the continental terminal series which forms the protruding rocky headlands. The continental terminal rises from 10m-15m at the coast to 100m at 400km inland. Pleistocene and Holocene formations exist in the wetland (the River Gambia and its estuary plus other coastal rivers).

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These include the Pleistocene alluvium of undivided sand, silt and clay, and the Holocene marine fluvial (typically of the River Gambia estuary) of undivided sand silt, clay salt and organic deposits.

In the coastal waters up to about 1,000m from shore, the maximum depth is 25.5m and the sediment ranges from fine sand, through medium sand to sandy shingles (Chart 608). The very shallow bottom allows only vessels of smaller draught (GRT 1,000 to 1,500 tonnes) to enter the Banjul port. There are no unchartered wrecks offshore; and there is no bunkering or unchartered existing pipelines offshore. All bunkering is done at Banjul port. The monthly average maritime traffic of 35 to 40 vessels for the Banjul port, which is relatively low compared to other ports in West Africa.

The Gambian coastal zone consists of unconsolidated marine and aeolian sands. The very fine nature of the sediment makes them easily thrown in suspension and transported away. For example, a result of that is the muddy colour of the water off the shore of the St. Mary's Island (Banjul and vicinity), extending from the municipal area towards the Oyster creek.

The 80km long Gambian coast is composed of embayments and headlands. This coastline configuration results in the development of several cells with respective dynamic patterns. The embayments are composed of flat eaolian sands underlain in most places by tertiary ferruginous sandstone of the “continental terminal”, which is occasionally exposed along the coast as cliffs or rocky platforms and headlands. These unconsolidated sands are very susceptible to erosion caused by wave action.

To the south-west of the Cape St. Mary, there are active cliffs which border the shoreline. The soft layers of lateritic soils and perched sand dunes above the consolidated basement are subject to erosion. There is considerable cliff erosion at this point due to direct wave action which results in slope failures and landslides. Many tourist hotels, like the Tropic Garden Hotel, the African Village Hotel, and the Medical Research Council (MRC) park are now threatened by this cliff erosion.

Coastal Erosion Coastline erosion has been documented as the most serious environmental hazard of the Gambian coast. The rate of erosion of the Gambian coast has been estimated at 1 to 2 metres per year at average, amounting to a land loss averaging 2.5ha to 3ha of land per year, or 200m³/year - 300,000m³/year (Delft Hydraulics, 1992). Though erosion is a major environmental problem, erosion rates of the relatively harder rocks at the headlands are lower, averaging about 0.5m/yr. This was confirmed by comparison of earlier aerial photographs showing the position of the coastline from 1964 to 1982. In some places where there are cliffs, recession was measured at 1 metre per year. The cliff recession is caused by the effect of run- off on the cliff slope and the impact of wave action at the bottom of the cliff. The situation had been worsened by the uncontrolled sand mining at Kololi, and later at Bijilo, where we estimated an annual removal of 150,000m³ to 200,000m³ of sand for the construction industry.

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Sea level Rise Though there are no records of regional sea level rise along the Gambian coast, it is to be expected that eustatic sea level rises will aggravate the already bad erosive state along the coast. This will be more pronounced along the low lying coastal areas. At the present rate of sea level rise, the apparent loss of sediments along the Gambian coast is preliminary estimated at some 75,000m³/year.

5.4.3 Biological Oceanography

The Gambia’s coastal area consists of not only those areas that border the Atlantic Ocean but also those with brackish water environments that border the River Gambia, extending 200 km inland. It is an area rich in natural resources and with particularly high biodiversity of national, regional and global environmental significance, housing important nursery grounds for regional coastal and marine fisheries and breeding, nesting, feeding and refuge habitats for endangered and threatened species. The characteristics of the marine environment combined with the relatively favourable conservation status of the coastal ecosystems, have produced a high degree of biological diversity: from the extremely rare West African manatee, monk seal; and a variety of cetaceans, major breeding colonies of sea turtles, water bird colonies and the concentrations of wintering Waders arriving from European breeding grounds. The Gambia coastal ecosystem could be classified into estuarine, intertidal and oceanic ecosystems.

Estuarine Ecosystem The Estuarine ecosystem includes Coastal Terrestrial, Mangrove Forest, Coastal Wetlands, Seagrassbeds, Sediments and Soft Bottom habitats. In this habitat, diverse flora and fauna with mostly littoral species are common. Meiofauna includes high amount of microorganisms like bacteria and protista; nematodes, annelids, larvae of oligochaetes, dense patches of copepods, coelenterates and different species of shellfish. These habitats are also important feeding grounds to a wide variety of birds particularly within river mouths. Estuarine flora includes rich phytoplankton particularly along salt marshes and mudflats. Angiosperms particularly white mangroves (Avicennia africana, A. nitida or A. germinans) red mangroves (Rhizophora harisonii, R. mangle or R. racemosa), Laguncularia racemosa, and Concarpus erectus. Seaweed and sea grass are also common along estuarine coasts. Estuarine Ecosystems are exporting nutrients and organic materials to outside waters through tidal circulation. Esturine ecosystems provide habitat for a number of commercially or recreationally valuable fish species. Likewise serving the needs of migratory near shore and oceanic species which require shallow, protected habitats for breeding and or sanctuary for their young ones. Wetland bird species include Dendrocygna viduata, sacred ibis (Threskiornis aethiopicus), Palm- nut Vulture (Gypohierax angolensis), crakes, Greater Painted Snipe (Rostratula benghalensis) and African jacana (Actophilornis africanus).

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Coastal Terrestrial Habitats The coastal terrestrial habitat that was once abundant along the Atlantic coastline now remains small forest patches especially the northern areas of the southern bank Tanji to Bakau. Only the Bijilo Forest Park which is protected remains slightly undisturbed. Coastal terrestrial habitats in The Gambia include some relic patches of woodland especially towards Abuko to Mandinari, woodland, Kachumeh and Kartong forests. These habitats also comprise of a Rhun palm zone from Dua Dula to Kartong. Although under intensive pressure mainly due to anthropogenic activities however, there still exist patches of coastal terrestrial habitats along River Gambia. These habitats comprise biologically diverse populations of trees, woody plant species, forest animals, birds, invertebrates, fungi and micro organisms all interacting in a complex system.

Mangrove Ecosystem The Gambia has 80km of open Ocean Coast and about 200km of sheltered coast along the Gambia River. The sheltered coast is dominated by extensive mangrove systems (66,900ha (15,000ha of tall mangroves Rhizophora and 51,900ha short mangroves Avicennia and Laguncularia). Mangroves are riverine vegetation that can thrive in varying degrees of salinity depending on the species. In The Gambia the four main species that occur are Avicennia africana, Laguncularia racemosa, Rhizophora racemosa and Rhiizophora mangle. A fifth species believed to be a hybrid of the two latter species is Rhizophora harrisonii. Of the five species mentioned, the Avicennia spp is the most salt tolerant. Consequently this species could be found in and around the Banjul and Kombo St. Mary area, as well as in the lagoon areas close to the sea. The Rhizophora species which occur further up river require brackish water although at certain times of the year they are exposed to highly salty water, and sometimes fresh water. Unless physically disturbed, the mangrove ecosystem is extremely versatile, especially with regard to its adaptability to changes in the water regime.

The mangrove ecosystem of The Gambia has remained relatively stable over the decades. Except for localised areas of death, the total mangrove area remained unchanged since 1968. Recently, perhaps as a result of the disturbance of the ecosystem caused by the reconstruction of the Brumen bridge, a large area of mangroves along the Bintang Bolong perished. Prior to this occurrence however, there was a high death rate in the mangrove population as a result of a combination of edaphic and climatic factors.

Although the mangrove system could be said to be in a state of equilibrium, threats to disturbing this equilibrium still exist. Construction works close to the mangrove areas, particularly in the Greater Banjul Area, pose a threat to the stability of the local ecosystems. In the rural areas, especially in the Lower River Division, clearing of swamps for rice cultivation invariably results in clearing of mangrove areas. Disturbances resulting from these clearings may have repercussions for the stability of the adjacent mangrove ecosystems.

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Coastal Wetlands Wetlands are areas of marsh, fern, whether peat land or water, natural or artificial, permanent or temporal, with water that is static or flowing fresh, brackish or salt, including areas of marine water, the depth of which at low tide does not exceed 6m (The Gambia Biodiversity Country Study, 1999). In the Gambia, coastal wetlands include River Gambia and its estuary plus other coastal rivers. The wetlands of the Gambia range from hypersaline lagoons brackish waters to mangrove swamps, barren (or salt) reed swamp, raphia swamps and seasonally flooded grasslands.

Marine Mammals such as large and small cetaceans (e.g. dolphins), sirenians, pinnipeds, rare sea otters and clawless otters are commonly destined in the coastal zones and wetlands. Also reported are whales, seals, and manatees. The West African manatee is the least known Sirenian species biologically and has never been studied before across its entire range. The West African manatee (Trichechus senegalensis) which belongs to the order of sirenian is an aquatic mammal endemic to Western and Central West Africa. Due to its threatened nature which results from excessive subsistence hunting coupled with destruction of habitats, this aquatic mammal a keystone species in The Gambia if not protected is likely to go extinct in the near future. The West African manatee listed as vulnerable in the IUCN red list of threatened animals appears on Appendix II of CITIES. In The Gambia manatees occur in both fresh and salt water areas and are said to be abundant in the estuaries where access to freshwater is facilitated. The Monk seal is a vagrant visitor in Gambian waters. This endangered pinniped has repeatedly been sighted around Bijol Island.

A total of 19 species of cetaceans have been reported by Dupuy (1980), and it is highly probable that some additional species also utilize Gambian waters based on the numbers of species known to occur in Senegal. The Gambia has a resident population of Atlantic Humpback dolphins (Sousa teuszii), which occur both in the river estuary and in coastal waters. There is some indication of movements in this species between River Gambia and the Delta du Saloum in Senegal which is separated by 15km of coastline. The bottle nose dolphin (Tursiops truncatus), is also resident within the mouth of the river and in the coastal water, and the interaction between these two species merits further investigations. Table 11 provides an updated cetacean list for the country.

Table 11: Updated Cetacean Species Check List for the Gambia (from WAFCET 2) ENGLISH NAME

STATUS Atlantic Humpback Dolphin Appendix II (CMS) Common Bottlenose Dolphin

West African population not listed (CMS) Clymene Dolphin

Unlisted (CMS) Long snouted common Dolphin

West African population unlisted (CMS) Short-finned pilot whale

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The large mammal fauna of the Gambia has been severely depleted over the last century, leaving only an impoverished and threatened remnant. Protection of Gambian wildlife has been afforded as early as 1901 under section 111 of the Wild Animal, Bird and Fish preservation order, the Wildlife Conservation Act (1977) repealed the 1916 Act while maintaining some of the subsidiary legislation of the earlier Act. The National Environment Management Act of 1994 and the Biodiversity/Wildlife Policy Act also provides for the conservation of biodiversity and the establishment of biodiversity areas.

Intertidal Ecosystem The intertidal ecosystem are mainly salt mash habitats and includes shorelines, inter-tidal zones and mangrove swamps. There is considerable fluctuations in seasonal incidence of tidal inundation. Such areas usually experience steady salinity variations. These are mostly influenced by rainfall patterns, ground and surface water inputs. These habitats are frequently waterlogged, turbid and anaerobic. Vegetation in these areas is predominantly mangrove trees, ferns, and fringing palms on mudflats. The vegetation acts as a buffer allowing terrestrial sediments from rivers to settle. It promotes accretion and further habitat development. It also habours complex community of animals especially invertebrates, numerous species of birds, insects and lizards. Roots of the trees provide a secure substrate for shrimps, bivalves and amphibians. It has muddy bottom suitable for a large number of burrowers (crabs, mulluscs and worms). Fish and other filter feeder find shelter in the crannies between roots of vegetation in the inter-tidal/salt marsh ecosystems.

The long stretches of sandy beaches are important nesting areas for sea turtles. 75% of The Gambia’s coastline is considered suitable for nesting of large numbers of turtles. Notable sea turtle breeding area is the Bijilo island area and Brufut heights which are of close proximity to the beach where the cable arrives on land from sea.

The biology and status of Marine turtle populations in the Gambia are poorly documented. The lack of information is partly due to the absence of local turtle specialists coupled with the lack of research resources and infrastructure. The first comprehensive survey of marine turtles of the Gambia coastline indicates the occurrence of 4 species namely: Green, Hawksbill, Leatherback, Olive ridlely and possibly also Loggerhead turtles. Anecdotal information regarding nesting, seasonality, and backed up to a certain extent by observations from the preliminary study made, suggest that the main breeding season extends from August through to October with some nesting taking place earlier (in June) and later (in November). The Green Turtle appears to be the commonest species in The Gambia as the majority of sightings, nests, recovered carapices and strandings are from this species. Globally Green, Loggerhead and Olive ridley turtles are categorized endangered on the IUCN Red list and Hawksbill and Leatherback turtles as critically endangered (IUCN 2000).

Oceanic Ecosystem The Gambia oceanic ecosystems are habitats that range from continental shelf to deep sea areas. It includes rocky shores/hard bottom habitats, pelagic habitats, seagrassbeds and

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upwelling areas. Rocky shores in the Gambia can be characterized into well defined cells along The Gambian coastline. The coastline along the Atlantic Coast of the Gambia comprises of rocky shores from Bakau Cape Point, Sun Wing Hotel to Fajara (NAWEC water tanks) and from the seashore of Tranquil to Brufut Sheraton Hotel. These rocky coasts were once deposited by the action of high energy flow of water from the hinterland towards the open ocean where it discharges detritus and gravel. Boulders of varying rock sizes can be seen as depositional layers forming a continuous belt of rock and gravel sequences from boulder deposited during the highest energy flow of the river to pebbles of various sizes deposited during the lowest energy flow. These areas usually consist of bivalves, gastropods, echinoids, crabs, sea bivalves, seaweed and micro-organisms.

Seagrass Beds Seagrass beds occur in both the estuarine and oceanic ecosystems. Seagrass beds occur in areas receiving significant freshwater input and also in areas characterised by oceanic salinity levels. In the former they are viewed as estuarine and shallow habitats (GESAMP Reports and Studies No 55). Sea grass families (Potamogetonacea and Hydrocharitacea) are often submerged and found in shallow coastal areas particularly in estuaries and lagoons. Although seagrass has little commercial use, they play an important ecological role in providing detritus matter as nutrients and as a habitat for a large number of marine organisms, seagrass helps to stabilize the seabed by holding down sand at times of rough seas and ocean turbulence (Mikkola & Khan, 2002). Algal and sea grass beds are found in the Atlantic Ocean and are very important food for the Green Turtle and others which are threatened species in The Gambia.

Reserves and Protected Areas Within the southern coastal strip of The Gambia, there are two gazetted reserves; the Bijilo Forest under the Department of Forestry, and the Tanji Bird Reserve under the Department of Parks and Wildlife Management. Bijilo is a fenced reserve of 51.3ha gazetted in 1952. The Park is composed primarily of a closed canopy coastal forest dominated by rhun palms, and with a small strip of herbaceous dune vegetation. The reserve has resident troops of colobus and vervet monkeys, and though unrecorded, invariably holds a range of small mammals such as mongoose, gennet and various rodents. Both the avifauna and reptiles are diverse though also little studied.

The Tanji Bird Reserve, gazetted in 1993, covers an area of 616ha, including the offshore Bijol Islands. The mainland area includes a wide diversity of habitat types: coastal lagoons, saltmarsh, mangrove, saltpan, dunes, grassland, scrub and woodland. The Bijol Islands are sparsely vegetated with herbaceous vegetation, and are important roosting grounds for waders, gulls and terns. Bald cape in Tanji Bird Reserve serves as roosting ground for a large variety of gulls, terns and warder riverine outlets; associated fauna includes Colobus monkeys, Dwarf Crocodile, Grimms Duiker, Sun Squirrel and Green Turaco. The islands also form an important breeding ground for green turtles. The rare Mediterranean monk seal (Monachus monachus) has been sighted in the sound between the islands and the Bald Cape.

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Gore (1990) indicated that there are 525 species of birds recorded from the Gambia, but this list has been recently enlarged to 552 species by Barlow et al (1997). This impressive list is represented by 75 families of Birds and gives the Gambia one of the highest density of avian species per kilometer square in Africa over 220 species are known to breed within the country, it is possible that a further 27 species also breed intermittently while 150 species migrate from the paleartic during the Northern winter. There are many inter-African Migrants also and the River Gambia appears to act as a flyway of considerable international importance. The greater part of the shoreline is dominated by long shelving sandy beaches Western Reef Heron Stalk the surf. Pied Kingfisher hovers above, whilst Sanderlings and Ruddy Turnstones are very numerous for much of the dry-season. The beaches are punctuated by occasional fishing villages where gulls take full advantage of fish processing operations on the beach. At sand spits formed opposite bend in the Coastline semi-permanent roosts of gulls, terns and warders find rest when not feeding at high tide. Rarities might include Audouins Gull and Kelp Gull. Opposite the few freshwater outlets along the beaches, white fronted plover and Giant Kingfisher are also encountered.

Fisheries Fish provides the cheapest form of protein and supplies about 40% of the total animal protein consumed in the country. Its current per capita consumption is estimated at 28kg (compared to 20kg in 1995). The total fish production is estimated at approximately 30,000 tonnes per year, with 25,000 tonnes from artisanal fisheries and dwindling catches from industrial fishing undertaken mainly by foreign vessels. The fishing industry contributes 3% percent of GDP and employs 3% of the population. The coastal population involved in fisheries can be divided into seven professional sub-groups: a) Boat owners; b) Boat builders; c) Fishermen; d) Fish dryers; e) Fish smokers; f) Fish suppliers (‘banabanas’); and g) Others, such as women fish carriers.

The fisheries sub-sector is divided into two categories: artisanal and industrial fisheries, the former producing the bulk of resources. Industrial production remains largely underdeveloped. The sub-sector’s (both artisanal and industrial) performance is marred by several constraints: lack of accessibility and affordability of concessionary credit, limited technical capacity, foreign dominance, high cost of pre-mix fuel and low use of suitable fishing technologies; absence of a fisheries port and lack of sufficient industrial on-shore facilities (fish factories) to encourage landing of high value fish catches from national waters; inadequate fish handling and storage facilities; poor distribution and marketing systems and structures. Despite these challenges, the fisheries sub-sector has great potential for contributing to national socio-economic development, providing sources of income, employment – including for youth and women,

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animal protein, foreign exchange earnings and has been identified by GOTG as key sector for increased investment. The fisheries policy objectives include promoting: the increase of fish supplies by at least 30 percent of present levels to meet food fish security needs of the country particularly the vulnerable populations; linking artisanal fisheries to markets to realize increased income and employment and take advantage of investment opportunities; providing artisanal fisheries with appropriate advice; data and information provided on a continuous basis to improve policy, planning and investment in productivity in the sector; and appropriate legislation, guidelines and practices with adequate monitoring.

The beach seine gear is the most dominant gear used by fishermen close to the project area. There are no available records on beach seine catches because it is proscribed by law. A short term independent study at Bijilo (Asberr, 2009) indicated beach seining attracts large crowds (including tourists) and is an important income generating activity for the Bijilo fishing community. The fishery impacts on the resources and the environment as evident in the landings of young fish and seaweeds. It also had and still has the potential to cause conflict between users of the beach with regard the amount of litter it generates and the crowds it draws to the beach. Table 12 provides the list of fish species caught in beach seine gear at Bijilo Beach.

Table 12: List of Species Caught in Beach Seine Gear at Bijilo Beach Scientific name English name

Polydactylus quadrifilis Giant African Threadfin

Scomberomorus tritor West African Spanish Mackerel

Alectis alexandrinus Alexandria pompano

Drepane africana African sicklefish

Pseudotholitus sp Croakers

Ethmalosa fimbriata Bonga shad

Caranx hippos Crevalle jack

It is generally observed that catches peak in the rainy season (May to September). It is closely followed in numbers by the set gill net and other surround gears. Artisanal fishermen do not drop anchor in the coastal waters and do not therefore pose any threat to the underground cable. Trawling is limited to waters of depth beyond 9m. The provisions of the Fisheries Act and associated regulations are enforced by the Fisheries Department in close collaboration with The Gambia Navy.

Fish Resource Potential The Gambia's continental shelf covers an area of 3,855km² and is believed to be one of the richest fishing grounds in the West African sub-region. In addition to its marine resources the

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River Gambia and its tributaries contain significant fresh water fish resources. Knowledge of the potential resource is constrained by inadequate financial and technical resources to conduct comprehensive and in-depth resource assessment studies.

Demersals The demersal fauna is extremely varied. Near the river estuary the most numerous species are the croakers (Sciaenidae), grunts (Pomadasyidae), threadfins (Polynemidae) and mullets (Mugilidae).

Pelagics The most common fish in the region are the small pelagics, Sardinella aurita, Sardinella eba and Sardinella maderensis, offshore, and closer inshore, the bonga Ethmalosa fimbriata. The latter are found in great abundance in shallow waters, particularly within the river estuary, and constitute the largest portion of the catch of artisanal fishermen. The Sardinella are highly migratory and are found near areas of cooler upwelling or at depths of 70m to 90m when surface waters are warm. Much less numerous among the pelagic species but of greater individual commercial value are the mackerels (Scomber japonicus), jacks (Carangid spp) and barracudas. The maximum sustainable yield of pelagics is estimated at 60,000 tons per year.

Estimated Maximum Sustainable Yield Whereas demersal resources are believed to be fully or even over-exploited, there appears to be still potential for additional harvests of small pelagic species. High value shrimp and lobster resources are also believed to be fully or over-exploited. The current estimate for potential sustainable yield is 1,000 tonnes. The high value demersal fish stocks are subject to intensive exploitation from industrial fisheries, but there is little data available, and no analyses have been done in this field.

At present, there is no hard evidence of a decline in the stocks of bonga and other small pelagics available to the artisanal canoe fishery. However, there is a noticeable trend of new entrants into this and other fisheries, and average catches per canoe are likely to decrease gradually. Many of the new entrants are from neighbouring Senegal.

There is a small fishery for lobsters and this high value resource is believed to be heavily exploited. Local fisheries officials are empowered to prevent the capture of small immature lobsters, as well as of adult egg-bearing females. Clearly, the pelagic stock is under exploited considering its potential yield and its estimated yearly production. This, to a large extent is due to the fact that it is not the target species of the industrial sector. The potential annual yield of the demersal species is, on the average, 16,000 metric tonnes. According to the estimated production (1990) there is the likelihood of overfishing, and this becomes even more likely since it is the preferred target of the industrial sector. This precarious state of the demersal stocks underscores the need for appropriate regulatory measures to ease pressure on these species, particularly the shrimp resources. The absence of sufficient biological data on the shrimp stocks

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(oceanic and estuarine) makes this need even more urgent. High percentages of juveniles are now being landed by the artisanal sector.

Shell fish Within the artisanal sub-sector there is also the oyster fishery, based on extensive natural populations of the West African mangrove oyster, Crassostrea tulipa. The oysters are found attached to mangrove roots and branches that line the Gambia River estuary. In most of the estuarine villages oyster harvesting is an important source of income, and in some areas oysters are an essential protein supplement for the family. Harvesters use machetes, axes, knives, cutlasses, to hack the oysters from the roots and branches, and in some cases the whole root or branch is chopped off in the process.

At certain sites continuous harvesting and extensive destruction of overhanging roots and branches pose a threat not only to oyster stocks around these sites but also to the livelihood of the harvesters themselves. Chopping the roots and branches reduces the total available setting space for the oysters which can lead to decrease in population, and eventually jeopardise the availability of oysters in general. While there are no empirical data on the quantities harvested, the average size of the harvests has become smaller indicating intense exploitation.

Oysters are a highly priced commodity, and given the high demand the current method of harvesting is putting a strain on the stocks at some sites. Oyster harvesting is dominated by women whose primary aim is to collect the meat. A survey conducted in 1990 counted 114 harvesters, 110 of whom (96.5%) were women. This total includes both Gambians and foreigners – 76.3% Gambians, 14% Senegalese, and 9.6% from the neighbouring Guinea Bissau. Of the 76.3% Gambian harvesters, 44.8% harvest at their local oyster grounds whilst the remainder are migratory. Oyster production levels vary from site to site, sometimes by as much as 3 times. Within the creeks and estuaries around Banjul, the daily production per harvester is 15-25 kg of shelled oysters, whilst at most inland sites the production is 40-60 kg per harvester. At average, local (non migratory) oyster harvesters earn approximately D 340.00 per month during the harvest season. This is variable depending upon the size of the group (whether two or more women are in the group) and the location of the harvesting site. The data suggest that migrant harvesters generate more income than the non-migrant ones, earning an average of D 464.00 per month.

Another important component of the oyster industry is the production of lime used for block making, wall plastering, painting and vegetable gardening. This aspect involves only the men using basically low-input techniques that require only oyster shells and fuelwood for burning the shells. Since both these resources are available at harvesting sites the only required element is labour. A lime maker would buy a heap of oyster shells, about 700kg -1000kg from a harvester, for about D 40.00 to produce 20 bags (50kg each) of powdered lime. A bag of lime costs D 15.00 amounting to at least D 300.00.

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Besides oysters the only other shellfish harvested for sale to local consumers are clams. The harvesting of these shellfish is also an activity dominated by women. Like oysters they are found in the intertidal areas of the estuary of the river. However, unlike oyster, clams are found buried in the mud and the women harvesters use their hands to collect them. Clams are of lower value than oysters and therefore attract lower prices than oysters. Exploitation of clams is not as intensive as that of oysters, and it also seems to have no harmful environmental effects.

Aquaculture Aquaculture production has made little or no contribution to the local market or consumption balance sheet, either in terms of improved nutrition or supplementary income for the local population. It is generally assumed that there is potential for development of aquaculture in The Gambia. But so far efforts made to introduce and develop it have not yielded the expected results. The Fisheries Department is presently conducting a pilot aquaculture project in the Central River Division. It is a research initiative in fish culture using river fish in two ½ hectare ponds.

Institutions Main institutions and actors involved in the fisheries sector include: foremost among Government institutions, the Department of Fisheries with overall responsibility of the sector. The Gambia Navy protects the country’s territorial waters; Ministry of Health and Social Welfare manages issuance of export health certificates; Gambia Ports Authority manages fish landing issues; and Ministry of Justice reviews and updates the fisheries Act and Regulations. For instance the Ministry of Justice was able to pass the Fisheries Amendment No. 4 regulations, 2009 of the Fisheries Act 2007. This amendment allows the use of beach seine gear, originally banned for the entire coast, in the Kololi and Bijilo areas due to their peculiar socio-economic conditions. It is noteworthy that the Bijilo area is where the BMH is sited.

In addition to Government, private fishing companies (e.g. Barra Fishing Company and Pelican Fishing Company) and community fisheries centres (semi-autonomous) are involved in the sector, the latter in particular managing fisheries centres to facilitate transportation and marketing.

Another important stakeholder institution is the Gambia Port Authority (GPA). The Gambia has two ports, the main one in Banjul, and a small one, Kaur port, as described below. The ports of The Gambia are managed and run by the GPA which is an autonomous public agency. The ports are very important to the Gambia economy as revenue generating institutions, and the points of entry/arrival of most of the essential goods (such as rice and sugar) consumed in the country. This is because The Gambia imports over 50% of its food and 100% of its fuel. The ports are also used for exporting Gambian products dominated by groundnuts.

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5.4.4 Site Specific Oceanographic Information

The beach where the cable arrives from sea to land at Bijilo is an almost flat at the lower shore but has a gentle slope at the upper shore (see Plates 3 & 4). The beach width at low water ranges between 50m to 65m depending on tidal level. Dominant at the lower beach are bivalves and range of worms that provide food for gulls and terns roosting at the beach in large numbers. An estimate of about 250 mixed flock of gulls and terns was made on a visit. There were strandings of fish and other invertebrate at the beach. The African sickle fish, Drepane africana; the puffer fish Epipphion spp. and an eel were found dead at the beach. Also noted at the lower shore was two specimens of the jellyfish, Aurelia spp. On the upper shore were typical coastal savannah vegetation made of grasses and shrubs (Plate 4). A small wastewater lagoon was at the upper shore and was a popular site for flocking gulls and terns (Plate 5). Some distance away from where the birds roosted were a fish landing site where beach seine fishers landed their catch. The upper shore was bordered by tourist facilities. A few revellers and traders were at the beach to enjoy nature and the country.

Plate 4: Gently Sloping Beach with Shorebirds Plate 3: Upper Shore of Beach with Typical Coastal at the edge of the Sea Shrubs and Grasses

Plate 5: Shore Birds Enjoying Small Wastewater Lagoon at the Beach

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5.5 Socio-Economic Environment

Primary data was gathered through consultations with officials from the following departments: 1. Ministry of Finance and Economic Affairs; 2. Ministry of Information and Communications and Infrastructure; 3. National Environment Agency,; 4. Gambia Ports Authority; 5. Ministry of Petroleum; 6. National Roads Authority; 7. Ministry of Fisheries and Water Resources; 8. Geology Department; 9. Gambia Bureau of Statistics; and 10. The Association of Non-Governmental Organizations.

In addition, data was gathered from the people involved in various activities along the cable route: in all, the team interviewed sixteen (16) project affected persons out of an estimated twenty-seven activities on-going in the project area.

The cable route passes through Bijilo community and ends up at Brusubi Institutional Area. The resident district is known as Kombo North district which is situated in Brikama Local Government Area in the West Coast Region of The Gambia. The Brikama LGA has the highest population in the country with 29 percent of the total nationwide population of 1,360,681.

5.5.1 Population

Brikama Local Government Area (LGA) is within the Western Division which is one of the five Divisions in The Gambia. The division had a total population of 307,014 made of 153,119 males and 153,895 females. Within Brikama, Kombo North has the fastest growing population with an intercensal growth rate of 106%. This may be explained by the increase in settlements along the Kombo Coastal highway and the creation of the Brusubi Housing Estate. The Gambia population and Housing Census, 2003, Economic Characteristics Volume 7 captured the population of people aged 7 years and in 5 years age group intervals. A further classification shows that 186,553 (60.8%) resided in the urban areas of Brikama LGA whilst the remaining 120,461(39.2%) were located in the rural areas.

Children between 7 and 14 years formed 84,143 of which males were 42,289 and females were 41,854. The age group of 50 years and above constituted 33,995 whilst the youth (20 – 49 years) formed the majority 188,876 (61.5%). The economically active population of the Brikama was 127,126 of which 116,396 were employed and 10,730 were unemployed. A LGA analysis of

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the economically active population carried out in the Census showed that the age group 7-9 years and 10-14 years accounted for the lowest proportion in Brikama unlike the other LGAs. This could be attributed to the fact that these ages, children are mostly sent to school in the urban areas whilst in the rural area some are engaged in farming or other forms of economic activity.

5.5.2 Educational Attainment

Education is a human right and a key factor to reducing poverty and child labour, promoting democracy, peace, tolerance and development (World Fit for children – p. 33). Data from the 2003 Population and Housing census, Education Characteristics, Volume 8 revealed that 132,270 children were reported to be attending school. Comparison of data on proportions of the population who never attended school between the 1993 and 2003 censuses revealed a widespread reduction in the Brikama LGA in both urban/rural residence and sex over the 1993- 2003 inter-censal period.

A similar change in gender differentials was observed between the two censuses at the urban/rural residential and LGA levels. The regional disparity continues to be explained by the unequal access to educational facilities despite the significant reduction in regional disparity. Differentials in the proportion of persons who never went to school in 2003, are also attributable to factors that were inherent during the 1993 census. Factors such as negative perception of Western-type educational system, which were in part influenced by religious, traditional or cultural orientation and variations in access to educational facilities among regions, impacted on the level and scale of educational attainment.

The educational attainment was assessed from pre-school to tertiary for the population aged 3 years and over. The pre-primary/Nursery represents mainly the age group between 3– 9 years. The total number of people who had attained pre-primary/Nursery level was 18,006 of which males formed 8,978 and females were 9,028. The Primary/Lower Basic level is from stages 1 to 6. Those with Primary/Lower Basic level education had the highest population in Brikama with 77,854. Majority (44,969) lived in urban areas whilst the remaining 32,885 lived in the rural areas. Again, there were slightly more males (39,177) than females (38,677) at the Primary/Lower Basic level.

The Middle School/Upper Basic continues from stages 7 to 9. The age group 15-19 is the standard school going age for the Middle School level. 34,758 of the population had attained the Middle School level. Those with Secondary Technical level education formed 18,755, Senior Secondary were 13,677 while High school graduates were 6,018; most lived in urban areas. Secondary Technical graduate males were 12,193 with females being 6,562. Males who had completed Senior secondary were 8,872 whilst females numbered 4,805. High school male graduates were 4,512 and females were 1,506. The tertiary level comprise the under

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graduate/studying for Diploma, Graduate/Diploma level and Post Graduate totaling 2,244; 1,701 were males with 543 being females.1

5.5.3 Ethnicity

The main ethnic groups among the population of Brikama LGA were Mandinka Jahanka, Fula Tuku/Lorobo, Wollof, Jola Karoninka Serre-Huli, Serere, Creole Aku/Marabou, Manjago and Bambara. The 2003 census further showed that Brikama was mostly dominated by Mandinka Jahanka (134,245). This was followed by Jola Karoninka with 77,105 people. The others were Fula Tuku/Lorobo (53,404), Wollof (27,835), Serre-Huli (4,835), Serere (8,066), Manjago (11,683) and Bambara (1,977). Creole Aku/Marabou were the least with 879.2

5.5.4 Religious Affiliation

Gambia is an Islamic nation which is believed to have been influenced by Berber traders even before the 10th century. Although Muslims dominate among the population, Christian religion is also practiced in the country with minimal followers. All these religious groups peacefully co- exist with no apparent social division. Islam, particularly Sunni is the major religion in the country with about 90% of the entire population as adherents. There is no Shi’ite following in the country but there is a small Ahmadiyya community. Christianity is one of the minor religions in Brikama and the nation as a whole representing 9% of the population. The Christian faith was initially introduced by the Portuguese in the 15th century. Gambian Christianity though, crystallized only in the 19th century. In particular, most Christian believers are Roman Catholics comprising 2% of the overall population. Other Christian believers include Anglicans, Baptists, Methodists, Protestants, Seventh Day Adventists and Jehovah’s Witnesses.3

5.5.5 Economic Activities

According to the Economic Characteristics (Vol. 7) of the 2003 Census, a person is considered employed if he or she was working or had a job but was not at work or reported to have worked for pay or profit in the month preceding census enumeration. There is male dominance in employment with 60 percent of the employed being males. The census revealed that the urban dwellers were largely engaged in the service sector, craft and related trade and in primary occupations. Rural dwellers on the other hand were mainly into crop production and skilled agricultural work. A differential in the occupation between urban and rural areas largely depicts differences in educational attainment. In all, majority (59.78%) of the active workforce in Brikama are self-employed.

1 Pp. 55-59 of The Gambia Population and Housing Census 2003: Educational Characteristics, Vol. 8 2 Sections on population, education, ethnicity and religious affiliation are based on statistics from GBOS. Ethnicity is on pp. 253. 3 From www.spainexchange.com/guide/gm-religion

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Agriculture and Animal Husbandry Agriculture and animal husbandry means the following activities: growing of crops; horticulture; rearing of animals; mixed farming; hunting and trapping of game; forest logging and other related activities. The 2003 Census showed that agriculture and animal husbandry was the most predominant in Brikama and in Gambia as a whole. 39,797 people were engaged in agriculture and animal husbandry in Brikama; rural dwellers dominated with 29,409 as compared to 10,388 in urban areas. However, there has been a decline in this industry as compared to what obtained in the 1993 census.

Wholesale and Retail Trade The wholesale and retail trade industry is the second highest economic activity which employs about 22,565 (19%) of the economically active population. The industry includes maintenance and repair of motor vehicles, fuel sales, and wholesale of agricultural raw materials, beverages; household goods; machinery and equipment; hardware and construction materials. It also includes retail sale of food and other goods in specialized stores.

Community, Social and Personal Service Community, social and personal services employs about 17,145 (13.5%) people. It is the third largest and the industry covers services in general in addition to public administration, health and education. Nearly two times the number of Males (11,375) more than females (5,770) are employed within this sector and the services are mostly centered in urban areas. Fisheries involves fishing and fish related activities and employs 3,322 (2.6%) people , whilst financial and business services which deals with the provision of services by monetary, financial and insurance institutions employed 2,085 (1.6%) people. Other industries in which the economically active population were engaged are manufacturing (7,821 or 6.2%) transport, storage and communication (8815 or 7%) electricity, gas and water (3902 or 3.1%) hotel and restaurant services (2571 or 2%).

5.5.6 Average Monthly Income

Average annual income according to National Household Poverty Survey in 1998 was D5,926; it varied both between socioeconomic groups and administrative divisions. Apart from Banjul and KMA which have the higher average income than the overall average for the country, Western where Brikama is located, follows with an average annual income of D4,675. Amongst socioeconomic groups within Western, the average income per year for households of a private worker was the highest at D16134, followed by income for public workers and informal workers, D9,031 and D6,325 respectively. In all, farming had the lowest average annual income of about D2,739.4 The average annual income for western was D4,675.

4 From table 4.2.1.1 pp 33 of The Gambia 1998 National Household Poverty Survey Report

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5.5.7 Profile of Project Affected Persons (PAPs)

A total of 14 PAPs were interviewed within the project area and this was done in Bijilo as all of the affected activities are located in Bijilo.

Age and sex Majority of the PAPs identified were male (78.6%) whilst the remaining 21.4% were female. The age distribution showed that 50% fall within the age bracket of 21 to 30 years. Males form about 28.6% of this group. PAPs between 31 and 40 years formed about 21.4 percent. A further 28.6% of PAPs who were all males were also between ages 41 and 50 years.

Educational background The educational level of the affected persons was not high. About 14.3% of the respondents had up to Upper Basic School level with about 35.7% not exposed to any form of education at all. This is made up of 28.6% male and 7.1% female. Significantly, there were 35.6% of PAPs who had been educated beyond the Upper Basic School. This was made up of HS/SS (21.4%), Teacher Training (7.1%) and University (7.1%). However, 14.3% who were males had passed through the Arabic School.

Ethnicity Most PAPs (85.7%) were nationals of the Gambia. They comprised 64.3% male and 21.4% female. Two persons (7.1% each) were from Senegal and Sierra Leone. The Gambians were from six main ethnic groups. Of these, Wolof formed half (50%) of the affected persons and were male. The Bambara, Fula and Jula who were all male made up 8.3% each while Serere, Mandinka and Jola also constituted 8.3% each and were females. Furthermore, all the affected persons identified professed their faith as the Islamic Religion.

Marital status Majority of the affected persons are married (64.3%). Among the married male PAPs only one had two wives. The rest had only one wife each.

Household sizes The average household size was 6.6 persons per household. This is a little lower than the National average household size of 8.5 persons. About 57.2% had an average household size of 1 to 6 members. This category had only one female (7.1%). The largest household size ranged from 15 to 18 people and belonged to one female.

Occupation The respondents were engaged in diverse occupations such as trading, artisan, business, beverage (coca cola) retailing etc. Artisanship (28.6%), business– supplier of IT equipment (7.1%), coca cola retailer (7.1%), labourer (7.1%) and waiter (7.1%) were done by male respondents. The artisans were into auto mechanics, carpentry, welding and pavement blocks making. Trading, which forms one of the major activities within the community is composed of

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food vending, trading in electrical gadgets, bikes and tires. Trading employs 35.8% of the affected persons comprising 21.5% male and 14.3% female. Only one female was unemployed. Only one male had a minor occupation as a watchman.

Average monthly incomes from major Occupations The average monthly income generated from the major occupations varied widely from below 1,000 to above 10,000 Dalasi. Only one female earned below 1,000 Dalasi from her major occupation. About 14.3% earned between 2,000 and 3,000 Dalasi and another 14.3% earned 5,000 and 6,000 Dalasi. Respondents who earned above 9,000 Dalasi a month constituted 28.6%. About 14.3% could not disclose their average monthly income and others claimed they had no income at the end of the month.

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6.0 STAKEHOLDER CONSULTATIONS, DISCLOSURE AND GRIEVANCE MANAGEMENT

6.1 Stakeholder Consultations

6.1.1 Objectives of Stakeholder Consultations

Consultation with stakeholders was carried out as part of the ESIA/ ESMP processes to specifically achieve the following objectives:  To provide information about the project and its potential impacts to those interested in or to be affected by the project, and solicit their opinion in this regard;  To provide opportunities to stakeholders to discuss their opinions and concerns;  To manage expectations and misconceptions regarding the project;  To verify the significance of environmental and social impacts identified; and  To inform the process of developing appropriate mitigation, monitoring and emergency preparedness measures.

6.2 Stakeholder Identification and Discussions

Key project stakeholders were identified for consultations and these included Government Ministries, State Agencies/Organisations/Departments, Project Implementation Unit/offices, University/Research Institutions, Non-governmental organization and local community/fisher- folks.

Meetings were held with key officials and opinion leaders to gauge level of awareness and involvement with the project, concerns of project implementation/impacts, and to obtain relevant documents or information on the project area and the coastal profile of The Gambia. The consultations also served to gather information on the mandates and permitting requirements of key regulatory institutions to inform the development of the Project.

Table 13 provides a summary of stakeholder concerns and discussions.

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Table 13: Summary of Stakeholder Consultations Stakeholder/ institution/ Contact Person Role Contact No. Date Concerns Raised/ Information Received Location Project Implementers Ministry Of Finance And Mr. Saffie Dambelleh, (220)9913743 18/04/11  Project at the preparatory stage. Economic Affairs Project Director  Project funded by the World Bank  Cable route determined and land for landing station acquired Fatou Njie-Faal (220)9966870  Marked cable route goes through oil concession blocks some of which belong to Senegal  Site for beach manhole is in Bijilo and that for the landing station is in Brusubi Ministry of Mr. Larmine Camarah (220)9974077 18/04/11  The Ministry is acting as the facilitator for the project Communication WARCIP Focal Point (220)7472299  Responsible for the development of the communication infrastructure  The project will improve tourism in the country through the introduction of broadband in Hotels  The ministry foresee cyber-crime and are in the process of finding mitigations GAMTEL Pamoudou Gassama , (220)9961900 18/04/11  The Site for landing station has been acquired with all its backing Director of Planning documents. and Development  Land area for landing station is 40m by 70m  Neighboring lands are private owned and currently being used for Sulleyman Gaye, Senior (220)9968854 farming manager Planning and  The Cable distance is about 2.8m from beach manhole to landing station Development  The cable laying is done by local contractors under the supervision of a foreign contractor Ministry Of Petroleum 19/04/11  Marked Cable route goes through some oil concession blocks for The Gambia and Senegal  The need to know the exact route for the cable offshore  The 500m buffer for the cable is too wide and will cover some area for the oil blocks.

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Stakeholder/ institution/ Contact Person Role Contact No. Date Concerns Raised/ Information Received Location  The need to study other places to know measures taken to make cable coexist efficiently with other offshore operations  To avoid damages, there should be good planning, proper communication and collaboration.  The WARCIP project will be very useful for the offshore operations in The Gambia  All parties involved in offshore activities should be made to understand the operations of the submarine cable so they can coexist  Location of the cable route backed with GPS coordinates will aid anchorage of oil vessels National Road Mr. Momodou Sey, 19/04/11  The Authority has a Memorandum Of Understanding with Gamtell on Authority(NRA) Operations and Safety road cutting and road crossing Engineer  When a road is cut, NRA charges the organization responsible for reinstatement of the road  The utility corridor is 20m from the center of the road  There is the need for Gamtell to provide NRA with information on the exact location of the cable  There is a road reservation committee which see to use of road reservation  Once the cable is laid 2m below the road surface and the location is known, it will not be affected by any road construction works  In laying the cable across the road, there should be warning nets 1m above it to tell excavators of the presence of a delicate material which is not to be tempered with National Environmental Mr. Aliu Nyang 19/04/11  Site verification for the project has been done and the go ahead given Agency (NEA) Department of Physical Mr. Essa Camara, (220)9952198 19/04/11  Lands applications from the ministry of Local Government goes to the Planning Principal Physical (220)7952198 Land Survey department before it goes to physical planning

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Stakeholder/ institution/ Contact Person Role Contact No. Date Concerns Raised/ Information Received Location Planning Officer development.  The land servey department is in charge of allocation of land and Land And Survey Hamidou Jallow, (220)7794766 preparation of Lease. Department Principal Lands and  Physical planning development is responsible for issue of permits Valuation Officer  Project site for beach manhole is managed by Tourism Development Authority(TDA)  The land allocated for the landing station was acquired from the Ministry of Local Government  The site for beach manhole and landing station are under the Kombo North district of the Western Region Water Resources  The project is welcome as the cost for internet is expensive presently  The water resources department is in charge of surface water and groundwater  The catchment in Bijilo is the Koto stream, a seasonal tributary to the Gambia River Fisheries Department 20/04/11  The site for the beach manhole is allowed for fishing  Fishing is done during the rainy season that is from May to September  Trawling is done within 9 nautical miles from the shore all year round.  The fisheries department is ready to help in awareness creation and sensitization on the project Gambia Ports Authority Momodou A.B.S (220)9960416 20/04/11  The wave current within Bijilo is between 2and 3.5 knots Mboob, Ag. Director of  When the cable is laid vessels of draft of 3-4m can still access the area Marine and Habours  The Gambian waters does not experience heavy waves

Mam Pateh Dampha, (220)9962824 Marine Pilot TANGO Ousman Yabo, (220)9921974 21/04/11  The organization was Founded in 1983 Executive Director (220)3921974  It has a membership of sixty five national and international Non

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Stakeholder/ institution/ Contact Person Role Contact No. Date Concerns Raised/ Information Received Location Governmental Organisations(NGOs) out of 120 NGOs registered with the Hadrammeh Sidibel, (220)9959411 Government Accountant  The need for sensitization program to inform people on the project  Road cutting should be done in the evening to avoid any inconvenience Kebbark Barrow, (220)9918528 to road users Programmes officer  TANGO should be made the link between the Government, stakeholders of the project and the affected community  There should be an NGO representative on the implementation committee to ensure that communities to be affected by the project are well represented Geological Survey Jerreh Barrow, (220)4374357 21/04/11  The country is planning for Sand dredging activities offshore in the near Department Assistant Director (220)7453313 future  The Mid Atlantic Ocean has some ongoing activities. Gambia Bureau Of Wally Hadre Ndow, (220)7127962 21/04/11  The last population census was conducted in 2003 Statistics (GBOS) Statistician  The Kombo North and South districts constitute the larger parts of the Western Region Baba Suwarea (220)9969982

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6.3 Disclosure of the ESIA/ ESMP

The World Bank policies require that environmental reports for projects are made available to project affected groups, local NGOs, and the public at large. Public disclosure of ESIA documents or environmental reports is also a requirement of the NEA procedures. However, there is no limitation as to the extent and scope of disclosure.

GAMTEL/ PIU in collaboration with the MOICI will disclose the ESIA/ ESMP to the general public through publication of dates for disclosure in one of the national newspapers and in local radio station(s). The ESIA/ ESMP reports will be placed or sent to specific public places (which will be indicated in the publication) to enable interested groups, affected persons and other stakeholders access the documents and make comments on the impact studies and submit to the NEA for decision making. The PIU will select display venues upon consultation with NEA but would be expected that one of the venues or places will be near the proposed landing site or local community.

The report will also be gazette and circulated to professional organizations for comments.

6.4 Grievance Redress Mechanism

Grievance redress mechanisms provide a formal avenue for affected groups or stakeholders to engage with the project implementers or owners on issues of concern or unaddressed impacts. Grievances may take the form of specific complaints for damages/injury, concerns about routine project activities, or perceived incidents or impacts. Identifying and responding to grievances supports the development of positive relationships between projects and affected groups/communities, and other stakeholders.

The World Bank/IFC expects the concerns to be addressed promptly using an understandable and transparent process that is culturally appropriate and readily acceptable to all segments of stakeholders at no cost and without retribution.

While this Project may have only limited potential adverse impacts to people and the environment in general, identifying grievances and ensuring timely resolution is still very necessary. As such the ESIA/ ESMP has developed a grievance management process to serve as a guide during project implementation. The grievance management guide is provided in Table 14.

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Table 14: Grievance Redress Management Step Process Description Time frame Other information 1 Identification of Face to face; phone; letter, e-mail; 1 Day email address; hotline grievance recorded during public/community number interaction; others 2 Grievance assessed Significance assessed and grievance 4-7 Days Significance criteria and logged recorded or logged (i.e. in a log book) Level 1 –one off event; Level 2 – complaint is widespread or repeated; Level 3- any complaint (one off or repeated) that indicates breach of law or policy or the ESIA/ ESMP 3 Grievance is Acknowledgement of grievance through 7-14 Days email address, public media acknowledged appropriate medium 4 Development of -Grievance assigned to appropriate party 4-7 Days PIU response for resolution -Response development with input from 10-14 Days management/ relevant stakeholders 5 Response signed off Redress action approved at appropriate 4-7 Days Senior management staff of levels GAMTEL/ PIU should sign off 6 Implementation and Redress action implemented and update of 10-14 Days GAMTEL/ PIU communication of progress on resolution communicated to response complainant 7 Complaints Response Redress action recorded in grievance log 4-7 Days GAMTEL/ PIU book Confirm with complainant that grievance can be closed or determine what follow up is necessary 8 Close grievance Record final sign off of grievance. 4-7 Days Final sign off on by If grievance cannot be closed, return to Managing Director GAMTEL/ step 2 or refer to sector Minister or Project Coordinator-PIU recommend third-party arbitration or resort to court of law

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7.0 POTENTIAL IMPACT ASSESSMENT

The nature of the project, field inspections and observations, concerns from stakeholder consultations and issues from relevant literature search formed the basis for the identified potential adverse environmental and social impacts.

7.1 Determination of Environmental/Social Significance of Impacts

The actual impact significance rating depends on a lot of factors, including:  the magnitude of the impact;  the sensitivity and value of the resource or receptor affected;  compliance with relevant laws, regulations and standards;  views and concerns of stakeholders;  overall worker/public comfort; and  likelihood of occurrence.

7.2 Categories of Impact Significance

A ‘negligible or nil impact’ or an impact of negligible significance is where a resource or receptor will not be affected in any way by a particular activity, or the predicted effect is deemed to be imperceptible or is indistinguishable from natural background levels.

A ‘minor impact’ or an impact of minor significance is one where an effect will be experienced, but the impact magnitude is sufficiently small and well within accepted standards, and/or the receptor is of low sensitivity/value. In such instances, standard construction/ operational practices can address such impacts.

A ‘moderate impact’ or an impact of moderate significance is where an effect will be within accepted limits and standards. Moderate impacts may cover a broad range, from a threshold below which the impact is minor, up to a level that might be just short of breaching an established (legal) limit. In such cases, standard construction practices can take care of these impacts but mitigation measures may also be required.

A ‘major impact’ or an impact of major significance is one where an accepted limit or standard may be exceeded, or large magnitude impacts occur to highly valued/sensitive resource/receptors. In such cases, alternatives are required to address such impacts otherwise mitigation measures should be adopted with strict monitoring protocols.

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7.3 Construction Phase Adverse Impacts/ Issues

7.3.1 Potential Adverse Environmental Impacts and Mitigation Measures

These are discussed in the Table 15.

Table 15: Potential Adverse Environmental Impacts/ Issues Impact issues Description of Potential Impact/ Issue Environmental Significance BMH and CLS Activities Waste generation Solid waste and Site preparatory activities including vegetation removal at the site will Moderate environmental generate biomass waste which will have to be disposed of. Excavated sanitation materials of mostly loose sandy soil will be generated. Construction spoil problems such as metal/plastic/wood pieces, concrete debris, and other solid wastes from packaged raw materials such as cement bags, wooden crates, plastic containers among others will be generated. These wastes would have to be disposed of appropriately.

Waste oil/fuel Waste oil will be generated from the use of fuel powered equipment and Moderate machinery- vehicles, trucks, engines/generators.

Human waste/liquid waste Indiscriminate disposal of human waste (faeces and urine) by construction Moderate workers especially at the beach will create environmental health risk to the beach users and water pollution concerns. Washing or cleaning of vehicles/equipment at the site will generate wastewater which will have to be managed properly Air pollution Exhausts/fumes and gaseous emissions from engines of vehicles, trucks, Moderate construction equipment/machinery and generators. Dust will be generated during construction and excavation; at the batching plant and during handling of cement and sand.

Dust generation will occur during transportation of materials to and from Minor site along unpaved dry roads Noise and (a) Use of construction equipment and machinery such as dump trucks, Moderate vibration vibrators, excavators, dozers will generate noise and vibration. The main receptors are workers, nearby residents, and nearby beach users. (b) Transport of materials to and from site, and abuse of vehicle horns by drivers will generate noise in local communities. Minor Impacts on Small amounts of light pollution will occur during construction period at the Minor

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Landscape and site as a result of security lighting. Presence of vehicles and equipment Visual Receptors during construction, and the introduction of a new structure/ building will affect the existing landscape. Impact on traffic Construction vehicles/trucks will be required to travel to and from site with Minor construction materials/ equipment and spoil and will impact on existing traffic in the development area. Impacts on soil/ Change in soil structure likely to occur as site appears largely sandy and will Moderate soil erosion require introduction of laterite soil for engineering purposes during construction of the CLS building. Exposed land surfaces from site preparatory activities may induce soil erosion from rain events Sea pollution Sediment laden surface runoffs from exposed sites during construction/ Moderate excavations. Improper disposal of sanitary waste and waste oil/oil spills may pollute the sea Impact on The construction of the landing station facilities will not impact on surface Negligible hydrology or ground water flow. No rivers or streams will be directly impacted by the construction activities. The design of the landing station includes proper drainage system. Impact on flora/ (a) The proposed CLS site is not a wildlife habitat/ terrestrial fauna site. Negligible fauna and habitat The grass is not of any conservation importance. (b) The proposed BMH site at Bijilo beach is not a wildlife habitat/ Minor terrestrial fauna site. However, the presence of the terns and gulls at the site suggest some ecological significance Impacts on There are no protected areas within the BMH and CLS sites to be affected Negligible wetlands/ by construction activities. sensitive sites/ protected areas Submarine Cable Activities Air pollution Exhausts/ fumes emissions from cable laying vessels as well as diesel- Minor powered engines/ generators will occur. Noise/vibration Small increases in noise and vibration levels in the marine environment will Minor Nuisance occur during pre-installation and installation activities from survey and cable vessel movements. Impact on visual Increased numbers of vessels within the marine environment during Minor receptors marine surveys and cable laying Impacts on Soil Cable installation activities will physically impact on sea bed geology (ocean Minor and Geology trenches, seabed outcrops etc). Impact will be limited to cable corridor and will vary in magnitude depending on the installation method (e.g. cable burial or laying cable on seabed). Scarring may occur. Impact on marine (a) Damage to marine habitats/flora along cable corridor caused by Minor habitat and flora disturbance & sedimentation during trenching/ cable installation will occur. (b) Habitat damage and degradation may occur as a result of unplanned events such as accidental spills of fuel and waste. Moderate

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Impacts on (a) Pre-installation/ installation vessels may strike species such as marine Moderate Marine Fauna mammals and sea turtles if they are in the area (b) Pre-installation/installation vessels cause temporary increases in noise and physical disturbance which can result in marine species leaving the areas where they may be feeding, breeding, or nesting. (c) Sediment caused by cable laying and survey activities may also smother marine organisms that dwell in the upper sections of the sediment layer. Impacts on The proposed marine protected areas in The Gambia are not within the Negligible Marine Protected footprints of the fibre optic cable right of way. Areas /Sensitive Sites

Impacts on Habitats could be damaged during construction onshore (shore crossing). Minor terrestrial flora As the habitat is continuous with uniform fauna and flora, diversity will not and fauna be reduced. The main macrofauna on the beach is ghost crabs. Impact on No adverse impacts envisaged Negligible offshore birds Impact on Marine Disturbance to marine sediments and benthos will occur during pre- Minor Biology and installation and installation activities. Disturbance to fisheries will also Fisheries occur. Impacts on (a) Cable survey/ installation could cause temporary disruption to flow of Minor marine traffic shipping traffic. The proposed landing stations not close to any major transport network such as ports, ferries, speed boats etc and the cable route should also avoid major ports, shipping and ferry routes. Impact on marine a) There would be a temporary increase in the quantity of suspended Minor water quality sediments (i.e. turbidity) during trenching and installation activities but this will subside/clear up naturally in a few days.

b) Release of wastewater from vessels and accidental spills or discharge of Moderate fuel, waste oil, and oily waste into water could cause pollution concerns Impact on coastal All sand and soil that is disturbed during trenching and installation of cable Minor processes and at the shore crossing will be restored to original levels as the trench is back- sediment filled. Disturbed marine sediments will settle naturally. The sandy beach movement nature of the area is a positive confirmation of the natural restoration after any excavations. Down-drift sediment movement is negligible as the trench will fill up rather quickly. Impact on The entire Gambian territorial waters have been segmented into oil blocks. Major Offshore Oil This poses a critical conflict to the proposed ACE submarine cable project. Drilling/ Propecting Activities

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7.3.2 Potential Adverse Social Impacts/ Issues

These are discussed in the Table 16.

Table 16 Potential Adverse Social Impacts/ Issues Type of impact Description of Potential Impact/ Issue Social Significance BMH and CLS Activities Physical displacement and The Project will not result in the physical displacement of any Minor loss of livelihood community or household.

Deprivation of use of land The proposed BMH and CLS sites will not cause a deprivation of negligible anyone’s land Loss of structures/ There are no structures on the BMH and CLS sites negligible properties Impact on vulnerable No negative impacts on vulnerable groups in the society (such as the Negligible groups elderly, disabled, women, children and minority groups) will occur as a result of the proposed development. The Project has no inherent negative impact or bias towards any vulnerable group. Impact on Social and The Project will have no negative impacts on social and cultural Minor Cultural Structures structures as the Project activities will have very little interaction with or impact upon population, social or cultural processes and activities or customs. Impact on educational No negative impacts on educational and health facilities are Negligible and health facilities predicted. There are no health/educational facilities at or close to the proposed site Impact on Cultural There are no known sites of significant cultural heritage or Minor Heritage/ Archaeological archaeological interest in the vicinity of the proposed landing site. interest The risks to cultural heritage would be on buried resources encountered during excavation on land. Impacts on recreation The Bigilo beach is used by revellers for recreation. However, there Minor are alternate areas along the beach front for revellers to use Public health and safety Public health and safety could be compromised through road traffic Moderate accidents involving construction vehicles/equipment. Noise nuisance and air pollution concerns Occupational health and Risks to safety and health of workers during construction will arise Major safety from operation of construction machinery/equipment, transportation of construction materials, inhalation of dust and fumes, injury from sharp objects or falling objects and fire/ explosion risks from welding. Traffic Impacts The proposed crossing of the Kombo Coastal road will necessitate Moderate trenching of the road which will impact on commuters imensely Submarine Cable Activities Impacts on artisanal (a) Artisanal fishing occurs at the Bijilo beach area and the fishermen Minor

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fishing and fish landing make use of drag nets or beach seining which has been legalised in sites that area alone. This activity will however be avoided by the project and therefore very minor impact is expected. The project will not Minor affect artisanal fish landing sites. Impact on livelihoods of The local fishermen can operate outside the cable route corridor Minor artisanal fishermen during the installation period. No local fish mongering site exist at the beach front of the proposed landing station site. Impacts on cultural It is not known whether there are significant cultural heritage heritage/archaeological resources or archaeological interests near the shore. However, Minor interest confirmed is that no known wrecks occur in the marine or near-shore environment. This will be confirmed during the marine survey studies Impact on existing marine There are no known existing marine infrastructure networks (other Minor infrastructure and submarine cables and pipelines) within the proposed fibre optic services corridor to be damaged Public health and safety (a) Accidents and unplanned events could occur during project Major (safety of other sea users) activities and could result in collision of Project vessels with fishing boats and nets or other vessels causing damage of vessels and equipment, or injury or loss of life. At particular risk are artisanal fishermen and other vessels that may move at night-time or in reduced visibility conditions when the Project activities are taking place. . Occupational health and Old and poorly maintained project vessels could breakdown at sea Major safety resulting in threat of life and equipment. Accidents at sea could result in injury or death of workers.

7.4 Operation Phase Adverse Environmental/Social Impacts

7.4.1 Landing Station

The following impacts or risks will be of concern during the operational phase:  Noise/air pollution;  Fuel storage/oil spill risk;  Water pollution and waste disposal;  Security risk;  Occupational health and safety; and  Emergencies/power or service failure.

Noise and air pollution will occur during the use of standby generators as a result of power cuts. The impact will be localized though. The main receptors will be workers and nearby residents.

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Fuel storage and handling during operational stage should be done with care in order to avoid oil spills. Waste oil as well as wastes in general should be properly disposed of in order to avoid pollution of marine waters. Waste oil should not be discharged into drains.

The importance of the CLS and BMH sites to the development of The Gambia cannot be overemphasized. Adequate security is required for the station to ensure that nation wreckers or saboteurs do not easily have access to the station to cause damage or disturbance.

Adequate fire protection measures should be provided in the landing station building. Workers should be provided with adequate and appropriate personal protective equipment during the operational phase. Workers should not be exposed to the direct fibre optic light which could affect their vision or eye sight. Appropriate eye goggles should be provided for use by workers.

7.4.2 Submarine Cable

The operation phase of the submarine cable will not have any significant adverse impact on the bio-physical and social environment except during cable repairs and recovery. There will be very limited maintenance of the cable. The cable will have a passive influence on the environment. Impacts during cable repair and recovery activities will be similar to impacts during the construction phase activities.

Cable damage as a result of natural disasters and human activities (e.g. fish trawlers) will create considerable disruption in the service provided. Measures to handle such emergencies should be put in place to ensure that the public and the business community enjoy the service with very short suspension periods.

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8.0 RECOMMENDED MITIGATION MEASURES FOR ADVERSE IMPACTS

Specific mitigation measures have been recommended for the identified impact or concern to improve the environmental and social performance of the Project. The mitigation measures have been designed in order to avoid, minimize and reduce negative environmental and social impacts. The mitigation measures are presented in Tables 17 and 18 in a descriptive format.

Potential conflict situations are likely to arise, in particular, during installation of the cable from offshore to its arrival at the beach. Foremost of all, all relevant stakeholders offshore and onshore should be well informed prior to the cable laying. No matter how fast the activity will go, it will temporarily disrupt maritime traffic, oil exploration activities, fishing and tourism in the area. Prior and timely information sent to these stakeholders can help to ward off any potential conflicts. Markers such as brightly coloured buoys should be placed at both sides of the cable laying activity to prevent any disturbance from any other users.

Despite the fine technology to be employed in the laying of the cable offshore, the digging of a one metre deep hole to receive cable will certainly disturb sediment and result in fine sediment entraining in the water column over significant distances. The resulting turbidity will be detrimental to aquatic organisms especially sessile filter feeding invertebrates which can get smothered or have their breathing organs clogged. The most efficient way to mitigate such impacts will be to improve on speed of cable laying, use very fine technology which will reduce sediment plume or erect temporary curtains at both sides of the cable hole to help restrict and localise the turbidity to a smaller area and hence impact only a smaller population of aquatic organisms if any.

Onshore cable laying activity, despite its short length, will negatively impact tourist and beach seine fishing activity. An unmanned cable hole is a potential threat to tourist safety and should be well managed. Both installed security and bright markers will help ward off intruders. Tourist will briefly not be able to freely move from one end of the beach to the other. Clearly marked alternate pathways should be provided to allow tourist and the public to freely move about. Beach seine fishing activity at the beach will temporarily be starved of potential helpers such as tourist who normally help in pulling the gear. The tourist will either be attracted to the cable laying or will divert their courses because of movement restrictions at the beach. Further, a host of microscopic organisms such as plankton in the seawater might be lost when they find themselves in the created hole. The small area of sediment disturbed at the beach will house thousands of benthic organisms such as worms, amphipods and ghost crabs found in abundant numbers at the beach on the visit. In all these, efficient management of negative impact can be achieved by speed and replacement of all disturbed sediment at the beach.

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8.1 Mitigation Measures for Construction Phase Impacts

8.1.1 Mitigating Potential Environmental Impacts /Concerns

Table 17: Mitigation Measures for Potential Environmental Impacts for the Construction Phase Impact issues Description of mitigation measures Construction of Landing Station Facilities Waste disposal Solid waste  Adequate waste reception facilities should be provided at the project sites/camp sites  Final disposal should be at dump sites approved by the LGA Waste oil /fuel . Spent or waste oil from vehicles and equipment should be collected and temporarily stored in drums or containers at site . Waste oil should be disposed off by oil marketing companies or agents approved or recognized and have the capacity to undertake oil disposal

Human waste/liquid waste  Toilet facilities should be provided at or near the site for use by construction workers  It should be a policy that free-range defecation is prohibited and offenders could be suspended  Vehicles, trucks and construction equipment should not be washed on site or at the beach Air pollution  The Project should require that construction contractors operate only well maintained engines, vehicles, trucks and equipment. A routine maintenance program for all equipment, vehicles, trucks and power generating engines should be in place.  The project should ensure the use of good quality fuel and lubricants only  If dust generation at the project/construction site becomes a problem, limited wetting of batching plant site and or unloading and reloading points should be done to reduce dust raising  Construction traffic speed control measures should be enforced on unpaved roads (speed limits through communities should be ≤50km/hr on unpaved or untarred roads and near or at project site should be ≤30 km/hr).  Engines of vehicles/trucks and earth-moving equipment should be switched off when not in use. Noise and vibration  The Project should require contractors to use equipment and vehicles that are in good working order, well maintained, and that have some noise suppression equipment (e.g. mufflers, noise baffles) intact and in working order. This will be achieved by making it a component of contractual agreements with the construction contractors.  Contractors will be required to implement best driving practices when approaching and leaving the site (speed limit of ≤30 km/hr) to minimize noise generation created through activities such as unnecessary acceleration and breaking squeal.  Engines of vehicles/trucks and earth-moving equipment should be switched off when not in use.

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Impacts on Landscape  The CLS should be boarded off from public view during construction and Visual Receptors  Good house-keeping at construction sites should be ensured Impact on traffic  Only road worthy vehicles and trucks should be used to avoid frequent breakdowns on the roads  Only experienced drivers should be employed Water pollution  No garbage/refuse, oily wastes, fuels/waste oils should be discharged into drains or shores/beach or onto site grounds  Fuel storage tanks/sites should be properly secured to contain any spillage  Maintenance and cleaning of vehicles, trucks and equipment should take place offsite in view of the proximity of the landing sites to the marine environment.  Toilet facilities should be provided for construction workers to avoid indiscriminate defecation in nearby bush or shores Impact on fauna and . Security lighting should be aimed at the project site and not extended to the beach area to habitat avoid impacts on sensitive fauna. Spillage of illumination outside the direct work area should be avoided. Submarine Cable Activities Air/ Noise pollution The Project should require that marine vessels/ equipment are well maintained and have a routine maintenance program in place. Impact on seabed The cable route design should avoid areas of potential geological sensitivity such as ocean geology trenches, bedrock outcrops etc. Detailed pre-installation surveys should be carried out and should identify potential geological sensitive areas and subsequently avoided by the detailed cable route design. Impacts on Marine  The Project should require that marine vessels implement a hazardous materials Fauna/habitat management plan that includes specification for proper storage and handling of fuels, oil, wastes, and other potentially hazardous materials as well as a plan for containment and cleanup of accidental spills into marine environment.  During pre-installation and installation, spotting of marine mammals and turtles should form part of the project work while at sea. Should these species be observed in the vicinity of the work area, the vessels should execute measures to avoid destruction or disturbance. Vessel operators should maintain a distance of at least 100m and should travel at 10 knots or less if safety permits until animals are more than 500 m away. Abrupt changes in direction should be avoided.  Vessel crews must report sightings of any injured or dead marine mammals and sea turtles immediately, regardless of whether the injury or death is caused by a Project vessel. The report should include the date and location of the animal/strike, and the species identification or a description of the animal. The report should be made to GAMTEL to be forwarded to NEA and other interested organisations.  The Project workforce and local communities should be educated to ensure that the importance of environmental protection and nature conservation are effectively communicated and that wider appreciation of environmental issues and construction best practice are fostered. Impacts on marine  Cable routes should avoid major ports, fish landing sites and shipping routes

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traffic  The Project should notify the Maritime Administration (GPA) of the submarine activities, so that vessels in the area would be warned in advance of the ongoing operations through a ‘Notice to Mariners’ report transmitted daily as well as potential dangers posed by and to other vessels when working in areas of higher traffic. Impact on marine  The Project should require that marine vessels implement a hazardous materials water quality /coastal management plan that includes specification for proper storage and handling of fuels, oil, processes wastes, and other potentially hazardous materials as well as a plan for containment and cleanup of accidental spills into the marine environment.  Marine vessels will be required to adhere to International Maritime Organization (IMO) regulations on bilge and ballast water discharge.  Areas of nearshore environment that are disturbed during installation activities (such as trench digging) should be rehabilitated as soon as possible after the cable has been installed.  All rehabilitated areas should be surveyed on weekly basis for the first month after rehabilitation, and a monthly basis for the subsequent five months, to monitor levels of coastal erosion in the vicinity of the development. If observations indicate that significant erosion and sediment transport is taking place (i.e. that rehabilitation has been unsuccessful) additional mitigation should be employed to reduce erosion.  Marine vessel anchors will not be dragged along the seabed and they will be retrieved vertically to avoid unnecessary sediment disturbance.  The maximum speed of the cable laying should not exceed 6 knots per hour so that the amount of seabed sediment disturbed and dispersed during the cable laying process can be kept to a minimum.  No waste oils, solid wastes, oily wastes as well as garbage will be discharged into sea. Marine vessels in consultation with the GPA will comply fully with the requirements of the MARPOL Protocol.

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8.1.2 Mitigating Potential Social Impacts/ Concerns

Table 18: Mitigation Measures for Potential Environmental Impacts for the Construction Phase Type of impact Description of mitigation measures Construction of lCLS and BMH Facilities Physical displacement No PAP will be displaced. Mostly, they will be disturbed and a Resettlement Plan has been and loss of livelihood prepared as part of this study to cater for any loss livelihoods

Local employment Contractors should use local labour as much as possible and where available. As much as possible, all unskilled labour should be contracted or obtained from the local community. GAMWORKS, a local unit that recruits contractors for projects in The Gambia is involved in the project to ensure local participation. Deprivation of use of No issues to be encountered land

Loss of structures/ No issues to be encountered properties

Impacts on recreation Appropriate notices and warning signs will be erected around working areas of beach or shore areas to warn prospective trespassers of any danger or risk Impacts on Human  There will be restricted access to the construction site. Security check point will be Health/ Safety and mounted at the entrance and exit to the site. sanitation  The construction site will be boarded off to prevent intruders and easy access by the public especially from the beach end. The retaining wall is short and can easily be climbed over.  All construction workers will be provided with ID cards  Trucks carrying construction materials such as sand, quarry dust, laterite etc will have the buckets covered with tarpaulin or appropriate polythene material from or to project site  Only road worthy vehicles/trucks will be used  Only experienced drivers/operators will be engaged  Except for areas secured by fencing, all active construction areas will be marked with high-visibility tape to reduce the risk of accidents.  All open trenches onshore and excavated areas will be backfilled after works have been completed.  Adequate sanitary facilities will be available for workers and open range defecation will not be countenanced.  Construction workers will be provided with and educated to wear suitable Personal Protective Equipment (PPE) including hard hats, overalls, high-visibility vests, safety boots, earplugs, gloves etc.  Every construction worker engaged will have an induction briefing on adherence to

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basic rules on occupational health and safety, environmental protection, public safety and work ethics, including most importantly hygiene and disease (HIV) prevention. Submarine cable activities Impacts on artisanal  GAMTEL/PIU will notify local fishermen /local communities early of the marine fishing activities or programme for the area.  Artisanal fishing activities will not be stopped because of the project but the fishermen will be advised or educated to move away from the proposed cable route corridor. Impacts on cultural  Should the pre-installation/marine surveys identify wrecks or marine cultural heritage heritage/archaeological resource or marine infrastructure such as pipelines or cable routes, the cable route interest /existing marine design will avoid and by-pass these resources. infrastructure and  The project will adopt and implement a chance find procedure and reporting system to services enable contractors report on any cultural heritage feature or marine infrastructure encountered. Impacts on Human  The Project will require all contractors to implement an Environmental, Health and Health and Safety Safety (EHS) plan which will outline procedures for avoiding health and safety incidents and for emergency medical treatment. This will be achieved by making it a component of contractual agreement.  All workers on board a cable vessel will be required to wear suitable Personal Protective Equipment (PPE) including hard hats, high-visibility vests, safety boots and gloves and life vests as appropriate.  All construction and cable repair workers will be sufficiently trained in the safe methods of working with fiber optic cables to avoid injury associated with laser lights and fibers.  Vessels will increase watch when navigating in areas that are known to be used by fishermen and other vessels. If other vessels are observed within the near vicinity, the Project vessel will stop moving, make contact with the other vessel if possible, and wait until it has been confirmed that the course of both vessels will not result in collision or damage to equipment.  While a vessel is laying cable its manoeuvrability is restricted, as such it will display the day signals and lights of a hampered vessel to avoid collision with other vessels at sea.

8.2 Mitigation Measures for Operational Phase Impacts

8.2.1 Minimizing Air Pollution and Noise Nuisance

Standby generators/Plant will be kept in proper housing or cage in order to localise noise generated from these equipment and not to exceed 70dB(A). Routine maintenance regime of engines, generators and equipment will be instituted to reduce incidence of smoke/fume and noise generation. Good quality fuel and lubricants will be used and engines of machines/equipment will be switched off when not in use. The government through GAMTEL will tar or pave access road to the site and around the main buildings to minimise the incidence of dust emissions especially in the dry season through vehicular movements.

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8.2.2 Minimizing Water Pollution and indiscriminate disposal of waste

No waste fuel/oil, oily waste as well as solid wastes such as garbage, scrap materials will be disposed of into the sea or onto the beach. Waste oils will be kept in drums and given to oil marketing companies for disposal. Servicing of equipment/machinery will only be undertaken at recognised mechanical workshops. No washing or cleaning of equipment/vehicles will be done at the beach but will be carried out at recognised washing bays with oil recovery facilities.

Adequate waste bins will be provided for office, and canteen use. Hazardous and non- hazardous wastes will be kept separately in different waste bins and properly labelled for disposal at approved sanitary sites only.

8.2.3 Security risk

A permanent fence wall will be constructed around the landing station facility with steel gates at both entrance and exit. A 24-hour security will be provided at the entrance and exit gates. All workers will be provided with appropriate Identification (ID) cards. The premises should have CCT surveillance monitoring system for effective security monitoring.

8.2.4 Managing Occupational Health and Safety Risks

The facility will be installed with smoke detectors, and fire alarms. Fire extinguishers will be positioned at all strategic areas and fire hydrants will be provided. An emergency assembly point will be created. Directions for exit within the facility will be provided and well labelled.

Workers will be provided with adequate and appropriate personal protective equipment including safety boots, overalls, rain coats, hand gloves, and eye goggles. Workers will not be exposed to the direct fibre optic light which can affect their vision or eye sight.

8.2.5 Emergencies

Standby generators will be purchased for use during power cuts. GAMTEL/PIU will enter into a standby agreement with the ACE submarine cable contractors to undertake cable repairs as and when required. An emergency preparedness and response plan will be adopted to handle fire emergencies.

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9.0 ENVIRONMENTAL AND SOCIAL ACTION PLANS AND PROGRAMMES

The aim of the Environmental and Social Action Plans and Programmes (ESAPP) is to act as a guiding manual with respect to the mitigation of adverse impacts as well as baseline parameters during construction and operation of the facilities.

It is the policy of GAMTEL/PIU to establish and maintain high standards of occupational health, safety and environmental protection at work, so as to prevent personal injury or illness, property damage, fires, security losses and environmental pollution.

The ESAPP is to ensure that the adverse impacts are managed fully and that unforeseen or unidentified impacts of the Project are detected and resolved. The ESAPP is also to provide assurance to regulators and stakeholders that their requirements with respect to biophysical and social performance will be met.

9.1 Environmental Policy

GAMTEL/PIU is committed to ensuring that environmentally conscious practices are carried out during construction and operation of the submarine and landing station project. In this respect, it shall:  Incorporate environmental considerations into its planning, management and operational activities;  Have an Environmental and Safety Coordinator to be directly responsible for environmental and safety issues during construction and operation;  Allocate and maintain resources for the effective implementation of the ESIA/ ESMP;  Ensure environmental knowledge, communication and participation among facility users, subcontractors, employees, and local community;  Demand that constructional activities are done in a way that minimizes negative environmental impacts;  Relate with the Environmental Protection Agency and other regulatory bodies to ensure compliance of all relevant statutory provisions;  Prevent environmental accidents and maintain a high level of preparedness to reduce the effect, in case of an accident;  Ensure that all wastes generated are collected and disposed of in an environmentally responsible manner and in compliance with appropriate national legislation;  Ensure that good housekeeping practices are observed by all workers and subcontractors at all workplaces;  Ensure that environmental resources such as energy, water are judiciously utilized and conserved; and  The cost of polluting the environment and the beach frontage is transferred and directly recovered from the polluter.

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9.2 Health and Safety Policy

GAMTEL/PIU will ensure that workers, contractors, vessel operators, and visitors comply with relevant health and safety regulations and standards. In this regard, it shall ensure that:  Employee awareness of hazard identification, prevention, minimization and avoidance is adequately created and developed;  Routine and curative medical examinations on employees are conducted periodically to monitor their medical conditions and fitness  Appropriate personal protective equipment and gears are provided and used by worker;  Appropriate fire protective equipment and adequate security are provided at the premises;  Employee morale and worker health are improved;  Occupational related diseases and personal accidents are reduced through education, training, enforcement of rules and regulations;  Unsafe acts and unsafe conditions are eliminated;  Incident/accident reporting procedures are instituted and workers are made aware;  Relevant national and international regulations on worker health and safety are integrated into its policy; and  All workers are educated or provided information on personal hygiene, and risks and dangers of HIV/AIDS.  9.3 Responsibilities

9.3.1 Role of GAMTEL/PIU

GAMTEL/PIU, being the project proponent, have the ultimate responsibility for ensuring that the measures set out in the ESMP are implemented or delivered. GAMTEL and PIU will have jurisdiction over the project in the construction phase, while GAMTEL will have jurisdiction during the operation phase.

In this respect, the PIU together with GAMTEL will review and approve contractor plans for delivery of the actions contained in this ESIA/ ESMP and during project installation will review contractor performance through monitoring, audits and inspection.

9.3.2 Appointment of an Environmental and Safety Coordinator (ESC)

GAMTEL/PIU will appoint an Environmental and Safety Coordinator (ESC) to be responsible for environmental and safety compliance issues set out in the ESIA/ ESMP during construction and operation of the project.

Functions of the ESC The functions of the ESC include to:  Ensure that the mitigation measures/action plans outlined in the ESIA/ ESMP are implemented;

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 Work closely with the Project Coordinator of the PIU, contractors, and other supervisors to ensure as far as reasonable practical, environmental protection, safe and healthy conditions and safe acts at all workplaces;  Coordinate environmental, social and safety activities between GAMTEL/ PIU, and all contractors/organizations providing services at the project site.  Ensure clear communication of safety, health, environmental and socio-cultural information to all categories of workers;  Liaise with all relevant stakeholders such as the NEA, GPA etc on all statutory approvals and compliance issues;  Liaise with management in deciding which environmental and safety concerns could be handled in-house and which ones will require external assistance; and  Investigate and review environmental and safety incidents and complaints and maintain separate site incident and complaint log books.

Authority of the ESC The ESC in consultation with the Project Coordinator has the authority to stop work or any activity which poses danger to the environment or workers or the general public during the construction phase, until appropriate measures are instituted to eliminate the dangers or threat.

9.3.3 Contractor’s Role

The contractor in this case refers to any individual or firm engaged during pre-installation and installation periods to provide technical services (e.g. design, surveys, construction, installations or any works associated with the project) with regard to BMH, CLS or submarine cable activities.

The contractor will be responsible for ensuring compliance with all relevant legislation as well as managing the potential environmental, social, health and safety impacts of all contract activities specified in this ESIA/ ESMP and or as may be recommended by NEA, GAMTEL and PIU.

The contractor will be expected to demonstrate commitment to the ESIA/ ESMP at all levels in the Contractor’s management structure. The Contractor will be required to appoint an Environmental and Safety Supervisor (ESS) who shall be responsible for overall environment, worker health and safety issues at the workplaces.

The contractor implementation of the requirements set out in the ESIA/ ESMP will form part of contractual agreement with the contractor. The contractor project reporting requirements or deliverables to the GAMTEL/ PIU will include sections on environmental, social and safety issues.

9.4 Contractor Specific Action Plans

The contractor will develop specific action plans as relevant to the works to operationalise the ESAPP. The specific action plans will cover the following:

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• Construction Site Management Plan (for onshore construction activities); • Marine Logistics Plan (for marine activities); • Spill Prevention and Control Plan; • Waste Management Plan; • Hazardous Materials Management Plan; • Chance Finds Procedure; and • Erosion Control and Restoration Plan (for onshore construction activities).

9.5 Awareness Creation and Training

9.5.1 During construction phase

Induction Briefing The contractor will provide an induction briefing to every construction worker to be engaged in respect of the project. The briefing which will centre on the ESAPP will include:  the proposed tasks for the new worker;  the worker and safety consciousness;  importance of the use of PPEs and warning notices;  personal hygiene and site sanitation issues;  environmental protection concerns; and  hazard recognition and incident reporting.

Weekly Safety and Environmental Forum There shall be a weekly environmental and safety awareness forum for construction workers at the project site to be organized in the mornings, preferably on Wednesdays from 8.00am to 9.00am. The Environmental and Safety Supervisor (ESS) shall be responsible and the PIU Environmental and Safety Coordinator will participate in the meetings. At each meeting, a specific issue in the ESAPP shall be discussed. This will help workers to acquaint themselves with major issues in the EASPP.

9.5.2 During Operation Phase

The objectives of the ESIA/ ESMP can only be achieved if every worker is adequately enlightened and environmentally conscious. GAMTEL will educate all workers from Management to labourers on environment, health and safety issues. GAMTEL will use the following means to disseminate environmental and safety information to staff and workers:  Staff and workers meetings;  Local area network and the internet; and  Annual bulletins on GAMTEL operations.

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9.6 Public Participation/Involvement

The PIU/ GAMTEL will consider suggestions and advice from all stakeholders, contractors, visitors and the general public, which will help improve its operations in order to minimise impact on the environment and worker health and safety. The office of the Project Coordinator of the PIU is open to the general public for complaints reporting and suggestions.

Complaints received from the general public will be recorded and follow-ups made to ensure that such grievances are addressed accordingly and in line with the grievance redress mechanism provided.

9.7 Monitoring Programme

The lead contractor will develop a monitoring programme to regularly monitor the environmental and safety practices of its own activities as well as all subcontractors in respect of this ESIA/ ESMP. The Environmental and Safety Coordinator of the PIU will undertake weekly site inspections and random spot checks during Project implementation to check on compliance with the ESIA/ ESMP. Major inspection findings will be reviewed by the Project at monthly project meetings. Remedial actions will be agreed upon at project meetings to address any adverse findings.

The site inspections shall cover sanitation, noise generation/air pollution issues, waste generation/disposal, trenching and public safety signs, use of PPEs, public complaints, and equipment/machinery status among others.

Environmental and safety issues and performances will be discussed at every project meeting as a way of monitoring compliance level of all stakeholders directly involved in project implementation.

9.8 Reporting

Environmental/Social and Safety Reports Contractors will provide PIU/ GAMTEL with monthly reports on environmental and safety management practices and issues. GAMTEL/ PIU will provide periodic reports to the World Bank on the Project’s environmental and social performance as agreed with the Bank.

Incident Reporting The contractor shall report all incidents both major and minor to the PIU/ GAMTEL within 24 hours from the time of occurrence, indicating why the incident occurred, remedial actions taken and recommendations to forestall future occurrence.

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9.9 Emergency Preparedness and Response Plan

The emergency preparedness and response plan is developed with the aim of addressing potential emergencies including fire and explosion occurrences during operation phase with the objective of minimizing hazards to workers, public and the general environment. An Emergency Assembly Area (EAA) shall be created at the CLS premises.

9.9.1 Responsibilities

Management is responsible for implementation of the Plan including allocation of adequate resources to ensure adherence to applicable regulations as well as corporate policy of safety. The Managing Director of GAMTEL or his representative, or in his absence the Environmental and Safety Coordinator (ESC), is responsible for initiating emergency procedures and ensuring that fire prevention systems and procedures provide sufficient protection of employees and facility assets.

The plan shall be reviewed and amended in the event of any changes in operations or maintenance procedures, introduction of new technologies and other circumstances which indicate a need for changes to the Plan. The Managing Director of his representative has the responsibility to develop and implement an emergency training programme and occasional emergency evacuation drills.

9.9.2 Notification

Management will report major fire outbreaks or any emergencies to the following:  The NEA; and  The Gambia Fire Service.

9.9.3 Fire/emergency preparedness

Formation of Fire Response Team GAMTEL shall train and maintain a Fire and Emergency Response Team (FERT). The FERT shall be called immediately into action on any fire case or other emergencies. The Environmental and Safety Coordinator will head the FERT. The FERT shall undergo periodic training from The Gambia Fire Service to equip and enhance their preparedness for fire fighting.

Monitoring of Fire Detection and Protection Systems The fire detection and protection systems will be monitored to identify any abnormal conditions, which could prevent fire protection systems and equipment from performing their intended function. Included in this program are inspections for:  Hand-held portable extinguishers located throughout the Premises;  Fire detection and alarm systems;  Fire/emergency exit doors; and

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 Accessibility and functionality of any onsite hydrant or nearby hydrants.

Testing, Inspection and Maintenance Upon installation, all fire protection systems shall be inspected and acceptance tested by a competent person before being put into operation. All fire protection systems and equipment shall be inspected periodically by safety auditors with follow-up corrective actions recorded and tracked for completion. This is the responsibility of the ESC and will be tracked in a Maintenance log.

Portable Extinguishers

All fire extinguishers will be visually inspected and checked in designated locations every month by Security personnel. This will be recorded on a monthly checklist.

Fire Detection, Warning and Alarm Systems

The fire/smoke detection and alarm systems will be inspected and tested every 6 months. The alarm systems shall be audible throughout the whole premises.

Fire/ Emergency Doors

Fire/Emergency doors will be inspected and tested biannually. All exits can be opened easily. Exit directional signs shall be provided at vantage points on the premises.

9.9.4 Fire Response Actions

This section describes the response actions that will be taken in the event a fire is discovered or occurs at the premises. i. Any worker(s) discovering fire or suspicious smoke should immediately shout “Fire!! Fire!!” and activate nearest emergency/fire alarms continuously to draw the attention of all on the premises. ii. Any member(s) of the fire response team should attempt to extinguish the fire with the nearest fire extinguishers. iii. Call the nearest Fire Service or emergency line on …….…………if Step ii is not being effective. iv. All operations must cease and the Managing Director or his representative shall ensure that all workers (except those assigned to fire) evacuate the building or premises if Step iii is triggered. v. The electrical supervisor/engineer or his/her deputy shall ensure that the main electrical switch is switched off if Step iii is triggered. vi. Upon hearing the siren or horn of the fire unit, the security person(s) shall ensure that the main gates are open wide and standby to let in fire personnel into the Premises. vii. If there are any injuries arrange to convey to hospital/clinic

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9.9.5 General Evacuation Procedures

When evacuating or leaving the premises during an emergency: 1. Stay calm, do not rush or panic; 2. Safely stop your work; 3. Gather your personal belongings if it is safe to do so; 4. Move quickly away from the emergency and use the nearest but safe passage or exit doors and proceed to the designated Emergency Assembly Area (EAA) and wait for any instruction from the emergency responders; and 5. Do not re-enter the building or work area until you have been instructed to do so by the emergency responders.

9.10 Environmental and Social Action Plans

The environmental and social action plans are as provided in Table 19 and Table 20. The mitigation measures are reflected in this ESAPP as a set of actions.

9.11 Uncertainty and Change Management

Uncertainty in the development of the ACE Submarine Cable System derives from a number of factors including: • unconfirmed design features; • unconfirmed detailed data on seabed conditions; and • unforeseen events.

The pre-installation/marine survey activities may unearth new data and together with the project designs may require new mitigation and management actions. GAMTEL/ PIU will liaise with the NEA and contractors to assess any change and the way forward.

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Table 19 Environmental Action Plan Impact issue Proposed Action Implementation tool/ Monitoring/ Verification Project stage Responsibility criteria indicators BMH and CLS Construction and Operation Solid waste -Provide adequate waste reception -Waste Management Number of site Weekly checks by Construction Contractors disposal facilities at construction/work camp Plan/Construction site waste bins PIU/ GAMTEL sites management plan -Dispose of waste at Freetown City Final disposal Operation GAMTEL Council approved waste dump sites records Waste oil/fuel Provide drums or containers for Spill prevention and control Waste oil drums or Monthly checks by Construction Contractors disposal temporarily storage of spent or plan containers on site PIU/ GAMTEL waste oil from vehicles and equipment

Dispose of waste oil through Waste oil collection Operation GAMTEL recognized oil marketing company and disposal records or approved agent Air/noise -Purchase sound equipment/ -Part of contract agreement -Maintenance plan -Independent checks Construction Contractors / pollution machinery for project with contractor implementation by GAMTEL GAMTEL -Operate well maintained engines, -A routine maintenance -Grievance records vehicles, trucks and equipment. program or plan for Maintenance records -Use good quality fuel and equipment/ machinery verified by GAMTEL lubricants -Purchase fuel at recognized -Suppress dust generation at fuel/ filling stations -Self check by project sites contractor -Reduce traffic speed on unpaved Speed limits on unpaved roads through communities and at roads through communities project sites should be ≤50km/hr and -Switch off engines of near or at project site should vehicles/trucks and earth-moving be ≤30 km/hr

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equipment when not in use. Impacts on The project site (landing station) Construction site Neat site -verified by PIU Construction Contractors / Landscape should be boarded off from public management plan arrangement, fence GAMTEL and Visual view and ensure good house- in place Receptors keeping at construction sites Impact on -Use only road worthy vehicles and Purchase sound vehicles and -Traffic incidence GAMTEL to verify Construction Contractors / traffic trucks trucks /machinery for project records GAMTEL Driver qualification -Grievances Self check by -Use experienced drivers recorded contractor Water -No garbage/refuse, oily wastes, ESMP/ waste management -Visibility of oil on -Daily self checks by Construction Contractors / pollution fuels/waste oils should be plan nearshore waters contractors GAMTEL discharged into drains or shores/ -On site erosion -Periodic reports on beach or onto site grounds Spill prevention and control features performance by -Fuel storage tanks/sites should be plan/ESMP contractor to properly secured GAMTEL -Maintenance and cleaning of Construction site Proposed actions -Spot checks/audits vehicles, trucks and equipment management plan implemented by GAMTEL Operation GAMTEL should take place offsite. -Provide toilet facilities for ESMP construction workers Impact on -Security lighting should be aimed To consult NEA for necessary Presence of -Daily self checks by Construction Contractors / fauna and at construction site and not action to be taken when any endangered fauna contractor GAMTEL/NEA habitat extended to the beach area. endangered fauna is located at project - area/beach

Submarine cable installation and usage Air/ Noise Marine vessels/ equipment to be Vessel maintenance plan Maintenance -Daily self checks by Pre-installation Contractors / pollution well maintained records contractors and installation GAMTEL -Periodic reports on performance

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Impact on The cable route design and cable Pre-installation surveys to -Periodic reports on Pre-installation, Contractors / seabed laying should avoid areas of identify potential geological performance by installation and GAMTEL geology potential geological sensitivity sensitive areas contractor to client repairs

Impacts on -Ensure proper storage and -Hazardous material Implementation -Daily self-checks by Pre-installation, Contractors / Marine handling of fuels, oil, wastes, and management plan/ oil spill tools contractor installation and GAMTEL Fauna/ other potentially hazardous prevention and control plan -Periodic reports on repairs habitat materials by vessels. -Marine fauna protection Marine fauna performance by -Spotting of marine mammals and procedure accidents/incidents contractor to client turtles should form part of the -Daily fauna observation recorded -Spot checks and project work while at sea. Vessel report audit by GAMTEL operators should maintain a -Awareness raising for -Grievances recorded distance of at least 100m and contractor personnel should travel at 10 knots or less if safety permits until animals are more than 500 m away. Abrupt changes in direction should be avoided. -Vessels should avoid collision or disturbance of marine animals in working area. -Vessel crews must report sightings of any injured or dead marine mammals and sea turtles immediately Impacts on -Cable routes should avoid major Project policy Marine traffic -Daily self-checks by Pre-installation, Contractors / marine traffic ports, fish landing sites and incidence records contractor installation and GAMTEL/ GPA shipping routes -Periodic reports on repairs -Notify the Maritime Administration Notification procedure performance by of the submarine activities, so that contractor to client

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vessels in the area would be -Periodic review of warned in advance of the ongoing grievances operations through a ‘Notice to Mariners’ report transmitted daily as well as potential dangers posed by and to other vessels when working in areas of higher traffic. Impact on -Ensure proper storage and -Hazardous material -Daily self-checks by Pre-installation, Contractors / marine water handling of fuels, oil, wastes, and management plan/ oil spill Occurrence of contractor installation and GAMTEL quality other potentially hazardous prevention and control plan coastal/ beach -Periodic reports on repairs /coastal materials by vessels. -Wastewater management erosion in the performance by processes -Marine vessels to adhere to IMO plan/waste oil disposal plan project area contractor to client regulations on bilge and ballast -Spot checks and water discharge/waste oil disposal. Erosion control and Visibility of oil on audits by GAMTEL -Areas of near-shore environment restoration plan marine/ near-shore -Periodic review of that are disturbed during waters grievances recorded installation activities should be -Rehabilitated areas rehabilitated as soon as possible to be observed on after the cable has been installed. weekly basis for first -Marine vessel anchors not to be month, and monthly dragged along seabed and should basis for subsequent be retrieved vertically. five months. -Maximum speed for cable laying should not exceed 6 knots per hour in order to limit sediment disturbance

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Table 20 Social Action Plan Type of impact Description of mitigation Implementation tool/ Monitoring indicator Verification Project stage Responsibility measures criteria BMH and CLS Construction and Operation Physical No persons will be physically PAPs identified and RoW clear of any Records to confirm Pre- PIU/ GAMTEL displacement displaced Resettlement Plan potential structure caretakers received or construction provided provided with relocation assistance

Employment and Use local labour as much as Community concerns Community concerns GAMTEL to verify Construction Contractors livelihood possible and where readily quota to locals prior to available. recruitment of construction workers through GAMWORKS Deprivation of Site properly acquired with ESIA/ ESMP Evidence of payment World Bank to verify Pre- GAMTEL use of land compensation and all fees paid for land / records construction

Impacts on Place notices and warning signs at ESIA/ ESMP Inspection/grievance Warning signs/ notices Construction Contractors / recreation working areas of beach or shore records in place GAMTEL areas Impacts on -Cover buckets of trucks carrying ESIA/ ESMP -Health and safety ESC inspections Construction Contractors Human Health/ construction materials such as incident register Safety and sand, quarry dust, etc -Grievance records -Daily self checks and sanitation -Use road worthy vehicles/trucks Vehicle maintenance verification by and experienced drivers/operators programme/plan in place contractor -Active construction areas to be -Spot checks by marked with high-visibility tape Construction site GAMTEL -Backfill and or secure open management plan -Periodic reports by trenches and excavated areas. contractor to GAMTEL

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-Provide adequate sanitary ESMP facilities -Provide PPEs for construction ESMP workers. -Educate construction workers on ESMP site rules/regulation and hygiene and disease (HIV) prevention.

Fire risk control Emergency response plan Fire detection, Emergency plan Operation GAMTEL warning systems in implementation place Submarine cable installation and usage Impacts on -Inform local fishermen /local Notification plan/ Level of awareness Awareness created Pre- GAMTEL/ Dept artisanal fishing communities of project activities procedure installation of Fisheries and loss of or programme for the area. and livelihood -Do not stop or ban ongoing Notification fishing activities installation, artisanal fishing activities but ongoing and repairs educate fishermen to move away from proposed cable route corridor. Impacts on -Identify marine cultural heritage Pre-installation surveys / Cultural/ -Chance finds Pre- Contractors cultural heritage/ resources and existing marine Chance finds procedure archaeological procedure under installation archaeological infrastructure such as pipelines or resources/ existing implementation and interest /existing cable routes. infrastructure -Daily self checks and installation marine encounter incidence verification by and repairs/ infrastructure register contractor recovery and services Periodic reports by contractor to GAMTEL Impacts on -Use suitable Personal Protective ESIA/ ESMP -Health and safety -Spot checks and Pre- Contractors Human Health Equipment (PPE). incident register observations by installation

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and Safety -Train all construction and cable -Grievance records GAMTEL and repair workers in safe methods of installation, working with fiber optic cables. -Periodic reports on and repairs/ -Increase watch when navigating in performance by recovery areas that are known to be used by contractor to GAMTEL fishermen and other vessels. -Cable laying vessel to display day signals and lights of a hampered vessel

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10.0 INSTITUTIONAL CAPACITY FOR ESMP IMPLEMENTATION

10.1 Instructional Collaboration

The main institutions which will work together to ensure sound management of the environmental and social aspects of the project include GAMTEL/PIU, NEA, and the GPA.

10.1.1 GAMTEL/PIU

GAMTEL being the local partner to the ACE Submarine cable project is responsible for the construction of the facilities in the Gambia. The corporate structure as it exist may be maintained with the current management team deeply involved in the operations of the CLS. GAMTEL will however, require some capacity building to assist with the implementation of the ESIA/ ESMP during the operation stage. The already established PIU is coordinating activities for implementation of the project.

10.1.2 NEA

The NEA is responsible for ensuring compliance with laid down EIA procedures in The Gambia in accordance with the NEMA Act 1994 and its amendment and the Agency is expected to give environmental approval for the Project. The ESIA/ ESMP falls in line with the EIA requirements. The NEA will support the project by exercising its permitting and monitoring powers.

NEA which is an agency under the Office of the President will have the needed resources and with experience in EIA review and monitoring, will be able to oversee the review of the ESIA/ ESMP.

It is noted that NEA has already given the environmental approval for the project following the completion of the EIA Forms and screening by the EIA officials (see Annex 1).

10.1.3 GPA

The GPA is responsible for the registration of ships and other vessels, the licensing and safety of navigation in the marine, coastal and inland waters with regard to personnel, ships and other vessels. It is also involved with marine pollution issues arising out of international maritime conventions (MARPOL Conventions), codes and other instruments.

GPA will register all vessels to be used for the work and approve of the qualifications of the personnel to be involved through shipping agents. The Administration will also ensure that the MARPOL Conventions with regard to vessel wastewater, waste oil /oily waste are handled properly without any pollution concerns.

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10.2 Capacity Building Requirement

The capacity building requirements will mostly be in the form of a training workshop. A training workshop on the ESIA/ ESMP, the World Bank safeguard policies of OP 4.12 and OP 4.01 and the MARPOL Conventions should be organized for the following stakeholders:  GAMTEL/PIU;  NEA;  GPA; and  Project consultants/contractors including GAMWORKS.

The capacity of GAMTEL/PIU should be enhanced to provide guidance, and ensure adequate overall environmental supervision of the project. An environmental and safety coordinator should be attached to the PIU/ GAMTEL during construction and operation phases for effective monitoring and supervision.

The Gambia has ratified the MARPOL convention and the implementation of the convention will help minimise seawater pollution during cable laying. The MARPOL convention addresses five major issues namely:  Handling of oil from ships;  Discharge into the marine environment of noxious liquid substances, or chemicals carried in bulk;  Accidental washing of deck cargoes into seawater;  Pollution from sewage generated on board ships/vessels; and  Pollution of the marine environment by garbage from ships/vessels.

A consultant with knowledge and understanding of the implementation of the World Bank policies of OP 4.12 and OP 4.01 as well as MARPOL convention should be contracted to undertake the training. The training cost for key stakeholders involved in the implementation of the Project may be between US$ 15,000-30,000.

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11.0 DECOMMISSIONING

11.1 Work Camp Facilities

Temporary work camp facilities which will be installed to house mainly equipment and materials and also serve as site offices during construction and laying of subsea cables will be dismantled and given out to local subcontractors for use at other project sites. All debris and waste generated will be disposed off at waste disposal sites approved by the Freetown City Council.

11.2 Cable Landing Station and Other Facilities

The landing station building will be reused for other new submarine cable to ensure continuity of service. Otherwise GOTG will reuse the main building as an office space for other agencies or rent out the property to interested organizations for use as an office space. All underground cables will be recovered for land disposal. The BMH and other trenches or holes will be permanently sealed off.

11.3 Submarine Cable

The ACE cable system is designed for a life span of about 25 years. As cables reach the end of their design life or become redundant due to technological advances, their removal from the seabed or decommissioning may be considered.

Two options are likely to occur at the decommissioning stage. Option 1 is where the cable is likely to be abandoned at the end of the Project’s lifespan. In such cases, no significant impacts are expected to occur. The cable will continue to have a passive influence on the submarine environment and will be benign, so will not degrade or pollute the environment.

Option 2 is where the cable will be recovered for land disposal. In such cases, impacts associated with cable recovery which may be similar to the construction phase impacts are likely to arise. However, before any decommissioning exercise is undertaken, an evaluation of the two options will be carried out taking into consideration environmental (to include the recycle or reuse options of the subsea cable), social, technical, safety and cost implications. The best practicable environmental option (BPEO) will be selected for the decommissioning of the cable.

GAMTEL or the government of GOTG will engage experts to carry out the evaluation and subsequent decommissioning as appropriate. Stakeholders will also be involved in the decommissioning stage and the decommissioning project will be registered with the NEA to ensure that the environmental assessment procedures are followed.

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12.0 CONCLUSION

The PIU and the MOICI will undertake the submarine cable and landing station project activities in accordance with the laws of The Gambia as well as International standards governing development projects of this nature. The laying and monitoring of the submarine cable and the construction and operation of the landing station facilities will satisfy the relevant local environmental protection laws and international conventions.

The major environmental, safety issues and impacts associated with the Project during implementation include land acquisition and compensation concerns, worker health and safety concerns, public safety and security concerns. The minor impacts include noise nuisance, air pollution, sanitation problems which will occur during the construction stage.

The coastal and marine environment of the Gambia has unique features that support a range of biodiversity. The activities of the ACE Submarine cable project including the coming to shore of the cable will not pose any environmental threat to the natural environment of the Gambia neither will the activities of fishers, marine traffic and other seafaring activities.

The recommended mitigation measures will be implemented to help minimise any significant adverse effects. An environmental and social management plan to be carried out during project implementation will help maintain environmental quality within acceptable limits.

Extensive consultations have been carried out to cover both governmental and non- governmental organisations including local community and landowners and no objections to the project were raised. Appropriate grievance redress mechanisms have been put in place to help manage any complaints or dispute that may arise as a result of project implementation.

The benefits of the project are immense both direct and indirect. The project will ensure faster and more reliable transmission of data and voice at a much lower cost than it exist at the moment. It will also improve connectivity between The Gambia and the rest of the world. It will also enhance business performance as well as create opportunities for expansion. New businesses will spring up creating avenues for employment and economic expansion among others.

If the project is not implemented, it would be a major setback for the overall development objectives of the GOTG, stifle investor interest in the country and increase the cost of doing business in The Gambia as compared to other African countries with submarine cable facilities.

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13.0 REFERENCES

1. Feasibility Study for the Landing Station (by Sofrecom) 2. Provisional Cable Route Study (Alcatel Lucent) 3. Site Visit Report (Alcatel Lucent) 4. Analysis of Actors on the Gambia Coastal Environment (Asberr Natoumbi Mendy) 5. Impact of Beach Seine on the Environment, the Livelihoods of BS Stakeholders and National Food Security in the Gambia (Asberr Natoumbi Mendy) 6. Constitution of the Republic of the Gambia 7. Resettlement Policy Framework for the Gambia Community Development Project 8. 1998 National Household Poverty Survey Report Banjul, June 2000 by Hon. Famara Jatta (Secretary of State for Finance and Economic Affairs) 9. Aide Memoire of the Pre-Appraisal Mission (March 16 -24, 2011) 10. Feasibility Study for the Landing Station 11. Provisional Cable Route Study 12. Site Visit Report 13. Analysis of Actors on the Gambia Coastal Environment 14. Impact of Beach Seine on the Environment, the Livelihoods of BS Stakeholders and National Food Security in the Gambia 15. Constitution of the Republic of the Gambia 16. Resettlement Policy Framework for the Gambia Community Development Project 17. Aide Memoire of the Pre-Appraisal Mission 18.

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ANNEXES

ANNEX 1: COMMUNICATIONS WITH NEA ON PROPOSED ACE SUBMARINE CABLE PROJECT

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ANNEX 2: CLS SITE DOCUMENTATION PAPERS

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ANNEX 3: CLIMATIC DATA

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