ADAMAWA RAMP II ESIA for Rehabilitation of 29 Rural Roads in Adamawa State

``` Rural Access Mobility Project

Public Disclosure Authorized

Public Disclosure Authorized RAMP II

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA)

Public Disclosure Authorized FOR 270.059KM OF RURAL ROADS IN Final Report Public Disclosure Authorized

DECEMBER 2019

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Contents

Contents ...... ii List of Tables ...... v List of Figures ...... v Abbreviations and Acronyms ...... vii EXECUTIVE SUMMARY ...... ix 1 CHAPTER ONE: INTRODUCTION ...... 1 1.1 Background ...... 1 1.1.1 Project Development Objective ...... 1 1.1.2 Project Components ...... 1 1.2 Rationale for the ESIA ...... 1 1.3 Objectives of the ESIA ...... 2 1.4 Technical Approach and Methodology to the ESIA ...... 3 2 CHAPTER TWO: POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORKS ...... 4 2.1 Policy and Legal Framework ...... 4 2.2 Administrative Framework ...... 5 2.2.1 Federal Ministries, Departments and Agencies (MDAs) ...... 5 2.2.2 Federal Ministry of Environment ...... 5 2.2.3 Federal Ministry of Agriculture and Rural Development ...... 5 2.2.4 Other Acts and Legislations ...... 6 2.2.5 State Ministries, Departments and Agencies (MDAs) ...... 6 2.2.6 Gender Based Violence in ...... 7 2.2.7 World Bank Safeguard Policies ...... 8 2.2.8 World Bank Environment and Social Safeguards Policies Applicability to RAMP 2 ...... 9 2.2.9 International Treaties Relevant to Social Protection ...... 10 2.2.10 Regional Treaties Relevant to Gender based Violence (GBV) ...... 11 2.2.11 Assessment of the Policy and Regulatory Framework for Environmental & Social Issues ...... 11 3 CHAPTER THREE: PROJECT DESCRIPTION ...... 14 3.1 Introduction ...... 14 3.2 Description of the Project ...... 14 3.2.1 Description of the Roads and Scope of Works ...... 14 4 CHAPTER FOUR: ANALYSIS OF PROJECT ALTERNATIVES ...... 23 4.1 Project Alternatives ...... 23 4.1.1 Do Nothing Project Alternative ...... 23 4.1.2 Using Alternative Travel Modes ...... 23 4.1.3 Alternative Alignment ...... 23 4.1.4 Construction of New Roads...... 23 4.2 Development Options ...... 24 4.2.1 No Project Development ...... 24

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

4.2.2 Delayed Project Development ...... 24 4.2.3 Road Surfacing Alternative ...... 24 4.2.4 Immediate Project Development ...... 25 5 CHAPTER FIVE: DESCRIPTION OF THE PROJECT ENVIRONMENT AND BASELINE STUDIES ...... 26 5.1 General Overview of Enugu State and the Project locations ...... 26 5.2 Site-specific Biophysical and Social Description of the Project Areas ...... 27 5.3 Areas within Erosion and Flooding Issues ...... 49 5.4 Assessment of Environmental Media in the Project Areas ...... 49 5.4.4 WATER QUALITY ...... 51 5.5 Socioeconomic Characteristics of the project area ...... 53 5.5.1 Land Use ...... 55 5.5.2 Health Assessment ...... 55 5.5.3 Social Structure/Trends and Social Groups ...... 55 5.5.4 Agriculture ...... 55 5.5.5 Infrastructure ...... 55 5.5.6 Social Amenities Likely to be affected during civil works ...... 56 5.5.7 Transportation ...... 56 5.5.8 Security Challenges ...... 56 CHAPTER SIX: DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS ...... 58 6.1 Background ...... 58 6.2 Associated and Potential Environmental and Social Impacts ...... 58 6.2.1 Physical Environmental & Social Media Influence ...... 58 6.3 Identified Potential Positive and Adverse Impacts and their ratings (by Project Phases) ...... 58 6.3.1 Summary of Potential Beneficial Impacts ...... 58 6.4 Labor Influx, Gender Based Violence (GBV) and Gender Mainstreaming ...... 64 6.4.1 Labor Influx ...... 64 6.4.2 Gender Based Violence ...... 65 6.4.3 GBV Risk Management Mechanisms ...... 66 7 CHAPTER SEVEN: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) ...... 68 7.1 Institutional Arrangement for Implementation ...... 68 7.2 Environmental and Social Management Plan ...... 70 7.3 Monitoring and Reporting ...... 104 7.3.2 Monitoring Activities ...... 105 7.3.3 Reporting Procedures ...... 109 7.3.4. Record Keeping and Control ...... 110 7.3.5 Implementation Schedule ...... 110 7.4 Capacity Building for Implementation of ESMP and Permit Conditions ...... 112 7.5 Objectives of the training ...... 112 7.6 Output of the training ...... 113 7.7 Contractual Measures ...... 113

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

7.8 Estimated Budget for ESMP Implementation ...... 113 7.10 ESIA Disclosures ...... 114 8 CHAPTER EIGHT: STAKEHOLDER CONSULTATIONS ...... 116 8.1 Introduction ...... 116 8.2 Stakeholders Engagement Plan (SEP) ...... 116 8.2.1 How Stakeholders were Categorized and Identified ...... 117 8.2.2 Fundamentals of Stakeholder Engagement Approach for Implementation ...... 117 8.3 Public Consultations ...... 118 8.3.1 Consultation Plan ...... 118 8.3.2 Implementation of Consultation Plan ...... 120 8.4 Summary of Meetings with Stakeholders ...... 121 8.5 Outcome of Stakeholder Consultations carried out during ESIA Preparation ...... 122 8. Requests from Stakeholders ...... 125 9 CHAPTER NINE: GRIEVANCE REDRESS MECHANISM (GRM) ...... 127 9.0 Introduction ...... 127 9. 1 Grievance Redress Committee ...... 127 9.2 Grievance Redress Awareness at Project Communities ...... 129 9.3 Grievance Redress Process ...... 129 9.4 Expectation When Grievances Arise ...... 130 9.5 Grievance Log ...... 131 9.6 Monitoring Complaints ...... 131 10 CHAPTER TEN: RECOMMENDATIONS ...... 132 REFERENCES ...... 133 ANNEXES ...... 134 ANNEX 1: Terms of Reference ...... 134 ANNEX 2: LIST OF PERSONS MET DURING ESIA STUDY ...... 138 ANNEX 3: QUESTIONNAIRE SAMPLE ...... 143 ANNEX 4: CODE OF CONDUCT ON GBV, SEA AND VAC ...... 145 ANNEX 5: Best Practice Guidelines for the Integrated Planning and Design of Economically Sound and Environmentally Friendly Roads in Floodplains ...... 150 ANNEX 6: Traffic Management Plan ...... 156 ANNEX 7: Waste Management Plan ...... 158 ANNEX 8: Community Security, Health and Safety Management Plan ...... 161 ANNEX 9: Minutes of Meeting with Stakeholders ...... 163 ANNEX 10: Attendance List and Pictures of Consultations ...... 164 ANNEX 11: AIR QUALITY ANALYSIS ...... 169 ANNEX 12: SURFACE AND GROUND WATER ANALYSIS ...... 171 ANNEX 13: SOIL ANALYSIS ...... 173 ANNEX 14: NOISE LEVEL ANALYSIS ...... 174 ANNEX 15: CULTURAL HERITAGE MANAGEMENT (CHM)/CHANCE FIND PROCEDURE ...... 177 ANNEX 16: LABOUR INFLUX MANAGEMENT PLAN ...... 180

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

ANNEX 17: BORROW PIT REMEDIATION PLAN ...... 181 ANNEX 18: WORKERS CAMP SITE MANAGEMENT PLAN ...... 182 ANNEX 19: CONTRACTORS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (CESMP) ...... 183 ANNEX 20: EMERGENCY PREPAREDNESS AND RESPONSE PLAN ...... 184 ANNEX 21: SOCIO-ECONOMIC CHARACTERISTICS OF PROJECT AREA ...... 189

List of Tables

Table 1: Relevant Federal/State Policies, Legislations, Regulations & Guidelines ...... 4 Table 2: Other Existing National Environmental Instruments ...... 6 Table 3: Comparison between Nigeria EIA Guidelines & World Bank Policy ...... 8 Table 4: Triggered Safeguard Policies ...... 9 Table 5: International Treaties and Conventions on Environment to which Nigeria is a Party...... 10 Table 6: Assessment of the adequacy of the environmental and social instruments to guide the RAMP 2 ...... 12 Table 7: List of Roads to Be Rehabilitated ...... 14 Table 8: Proposed Activities for Road Intervention Works ...... 17 Table 9: Site-specific Biophysical and Social Description of the Project Areas ...... 35 Table 10: Main Crops Cultivated in the Project Areas ...... 55 Table 11: Summary of Social Amenities likely to be impacted ...... 56 Table 12: Means of Transportation ...... 56 Table 13: Security challenges observed ...... 57 Table 14: Evaluation of potential positive impacts ...... 59 Table 15: Identified Potential Negative Impacts and their Ratings (by Project Phases) ...... 61 Table 16: Institutional Arrangement for Implementation ...... 68 Table 17: Environmental and Social Management Plan ...... 71 Table 18: Role and responsibilities ...... 101 Table 19: Specific Environmental & Social Parameters Monitoring Plan (270.059km selected roads) ...... 106 Table 20: Internal and External Monitoring ...... 109 Table 21: Reporting Procedures ...... 109 Table 22: Tentative ESMP Implementation Schedule for the selected 270.059km roads ...... 111 Table 23: Capacity building plan for implementation of the ESMP & permit conditions ...... 112 Table 24: Contractual Measures ...... 113 Table 25: ESMP Budget ...... 114 Table 26: ESIA Disclosures ...... 114 Table 27: Proposed Stakeholder engagement approach ...... 119 Table 28: Consultation with communities ...... 121 Table 29: Consultation with communities ...... 122 Table 30: Consultation with Communities ...... 122 Table 31: Typical Reporting format for Grievance Redress ...... 131

List of Figures

Figure 1: Engineering design of typical cross-section of road in built up areas with reinforced concreted lined drains ...... 21 Figure 2: Typical Road Cross-Section in Build Areas with Stone Pitched Drains ...... 22 Figure 3: Typical normal cross section in farm/forest areas ...... 22 Figure 4: Lateritic Base Course Base Surface Treatment ...... 24 Figure 5: Map of Enugu State Showing LGAs where Intervention Works will be Implemented ..... 26 Figure 6: Map of Lot 1 Roads Showing Environmental Sensitivities ...... 28 Figure 7: Map of Lot 1 Roads Showing Social Sensitivities ...... 29 Figure 8: Map of Lot 2 Roads Showing Environmental Sensitivities ...... 30

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 9: Map of Lot 2 Roads Showing Social Sensitivities ...... 30 Figure 10: Map of Lot 3 Roads Showing Environmental Sensitivities ...... 31 Figure 11: Map of Lot 3 Roads Showing Social Sensitivities ...... 31 Figure 12: Map of Lot 4 Roads Showing Environmental Sensitivities ...... 32 Figure 13: Map of Lot 4 Roads Showing Social Sensitivities ...... 32 Figure 14: Map of Lot 5 Roads Showing Environmental Sensitivities ...... 33 Figure 15: Map of Lot 5 Roads Showing Social Sensitivities ...... 33 Figure 16: Map of Lot 6 Roads Showing Environmental Sensitivities ...... 34 Figure 17: Map of Lot 6 Roads Showing Social Sensitivities ...... 34 Figure 18: Chart representing age distribution in project area ...... 53 Figure 19: Chart representing gender distribution in project area ...... 53 Figure 20: Chart representing Length of Stay in Project Area ...... 53 Figure 21: Chart representing educational level in Project Area ...... 54 Figure 22: Chart showing occupation distribution in project area ...... 54 Figure 23: Stakeholders Engagement Plan (SEP) Implementation Process ...... 116 Figure 24: Flow Chart Depiction of Enugu RAMP-2 Project based GRM Process ...... 130

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Abbreviations and Acronyms

AFD French Development Bank AIDS Acquired Immune Deficiency Syndrome EN-RAMP Enugu Rural Access and Mobility Project ENSACA Enugu State Agency for HIV/AIDS Control ACHPR African Charter on Human and Peoples’ Rights ACRWC African Charter on the Rights and Welfare of the Child ARAP Abbreviated Resettlement Action Plan ESMEnv Enugu State Ministry of Environment ESRMA Enugu State Road Maintenance Agency ESMWR Enugu State Ministry of Water Resources BOQ Bill of Quantity CBA Cost Benefit Analysis CBOs Community Based Organizations CEA Cost Effectiveness Analysis CoC Code of Conduct CEDAW Convention on the Elimination of All Forms of Discrimination against Women CESMP Contractors Environmental and Social Management Plan CHM Cultural Heritage Management CMP Conservation Management Plan CSOs Civil Society Organizations DH District Head DBST Double Bitumen Surface treatment DHS Demographic Health Survey EHS Environmental Health and Safety EA Environmental Assessment EEDC Enugu Electricity Distribution Company EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESME Enugu State Ministry of Environment ESMP Environmental and Social Management Plan EMS Environmental Management System ESMS Environmental and Social Management System ESSC Environmental and Social Safeguards Consultants ESSO Environmental and Social Safeguard Officers ESMoH Enugu State Ministry of Health ESMoP Enugu State Ministry of Power ESWAMA Enugu State Waste Management Authority ESWC Enugu State Water Corporation ESSU Environmental and Social Safeguard Unit FERMA Federal Road Maintenance Agency FGDs Focus Group Discussions FGN Federal Government of Nigeria FMARD Federal Ministry of Agriculture and Rural Development FMEnv Federal Ministry of Environment FPMU Federal Project Monitoring Unit FRSC Federal Road Safety Corps GBV Gender Based Violence GDP Gross Domestic Product GIIP Good International Industry Practice GRC Grievance Redress Committee GRM Grievance Redress Mechanism GRS Grievance Redress Service HIV Human Immune-deficiency Virus HSE Health, Safety and Environment ICCPR International Covenant on Civil and Political Rights ICESCR International Covenant on Economic, Social and Cultural Rights ICRC International Committee of the Red Cross IDSR Integrated Disease Surveillance and Response LEEDS Local Economic Empowerment and Development Strategy LGAs Local Government Areas

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

MCDM Multi Criteria Decision Model MDAs Ministries, Departments and Agencies NEEDS National Economic Empowerment and Development Strategy NEMA National Emergency Management Agency NESREA National Environmental Standards and Regulations Enforcement Agency NGOs Non-Governmental Organizations NPC National Planning Commission NPF Nigeria Police Force NSCDC Nigeria Security and Civil Defense Corps OHSP Occupational Health and Safety Plan PAPs Project Affected Persons RAMP Rural Access and Mobility Project RAP Resettlement Action Plan RPF Resettlement Policy Framework RTTP Rural Travel and Transport Program PC Project Coordinator SEA Sexual Exploitation and Abuse SEP Stakeholders Engagement Plan SPIU State Project Implementation Unit STIs Sexually Transmitted Infections STD Sexually Transmittable Diseases SEEDS State Economic and Empowerment Development Strategy SIA Social Impact Assessment SOP Standard Operating Procedure TC-GRC Technical Committee on Grievance Redress Committee ToR Terms of Reference VAC Violence Against Children VH Village Head VIO Vehicle Inspection office WB World Bank WBG World Bank Group

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

EXECUTIVE SUMMARY

ES 1: Background

The Federal Government of Nigeria through the Federal Ministry of Agriculture and Rural Development (FMARD) is being supported by the World Bank (WB) and the French Development Agency (AFD) for the implementation of the Rural Access and Mobility Project (RAMP) in the country. The RAMP is in line with achieving the Federal Government’s Rural Travel and Transport Program (RTTP), which is aimed at improving and enhancing accessibility and mobility in the rural areas. Accessibility and mobility are crucial to the lives of rural populations since they are predominantly farmers, petty traders and artisans. The movement of their agricultural inputs and outputs are dependent on accessibility and mobility. The existing carriageway width of these rural roads varies from 3–6 m. The existing roads are earthen roads and are deteriorated due to inadequate maintenance and impact of weather elements. These roads act as a major economic corridor of the rural villages and links them up with their neighboring villages, local government headquarters and the state(s) capital. Thus, improvement of these project roads is very necessary and important.

ES 2: Rationale for the ESIA

The RAMP activities will involve medium-sized civil works during the rehabilitation of roads and river-crossings. These could result in environmental and social impacts thus triggering the World Bank’s Safeguard Policies including Environmental Assessment OP 4.01; Involuntary Resettlement OP4.12; Natural Habitats OP 4.04; and Physical Cultural Resources OP 4.11. Based on the environmental and social screening criteria set out in the ESMF, an Environmental and Social Impact Assessment (ESIA) is required for the proposed project at the State level to ensure that the adverse environmental and social impacts are identified, assessed and appropriately mitigated. Against this background, the Enugu State Project Implementation Unit (SPIU) has prepared this ESIA report for 270.059km of 29 selected rural roads organized into 6-Lots.

ES 3: Policy, Legal and Administrative Frameworks for the ESIA

Several state, national and international policies, legal and regulatory framework have been enumerated in this report. These legal instruments specifically address or are related to road infrastructure development, environment and social development. Importantly, policies and conventions that address gender-based violence, child rights and sexual exploitation are also enlisted.

ES 4: Description of the Proposed Roads Rehabilitation and Construction Works

Broadly, the intervention works will involve the upgrading, rehabilitation and maintenance of 29 rural roads, across the State with a total length of 270.059km. The selected rural roads are existing roads which present varying levels of deterioration. The predominant issues associated with the roads include:

i) Erosion ii) Flooding iii) Lack of hydraulic structures necessary to control flooding and preserve road integrity

The proposed Design width for the 29 rural roads is 8 meters (m) (6m carriageway and 1m outer shoulder on each side in areas bordered by dense vegetation). In built-up areas or urban areas, the carriage width is 6 m with concrete-lined drains on both sides. The Pavement Structure of the road will consist of Earth work embankment (variable) as per site requirements, including Sub- base (15 cm) and (base course 15 cm). For hydraulic structures, most designs include 900 mm diameter pipe culvert (single and double cell) as per catchment area and hydrological data. However, for some locations, (with regards to site conditions and requirements), box culverts measuring 2x2 (single and double cell) 3x3 (single and double cell) will be installed. Concrete lined drains have been considered suitable for channeling water in built up areas or in very steep (high

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State gradient area) to mitigate and control erosion. Around the culverts and at high embankment areas the SPIU has proposed and designed grouted riprap for the flood protection to control erosion and future damage to hydraulic structures and embankment. No bridge has been designed for phase 2 roads.

ES 4 Table 1: List of Roads to be Rehabilitated

Lot Roads Description / Location Length GPS LOCATION No. in the (Km) Lot Start Point End Point

1 40 Nkpologu-Uvuru-Ukpata-Adaba- 39.221 E304840.603M E292674.023M AkunyiUmulokpa Road N748069.113M N726397.468M

119 Odenigbo- Ani-UgwuiyiMpi- 11.562 E: 320834.316 E: 319793.554 OfuluOnu Road with Spurs to N:757921.405 Imilike-Ubogidi Road and Catholic N:758671.482 Parish Road 125 Nguru-Akpotoro-St Mary Obimo 9.100 E: 321694.473 E: 316309.934

N:753357.350 N:752065.518 Total Length 59.883

2 129 EnyazuruOhomorba Rd 2.220 E331348.795M E333348.548M

N758848.218M N757985.862M 142 Umu-Ezejor-Agu-Udele-Itabor 2.930 E: 351280.013 E: 352894.870 Road with Spur at Ubahor N:759347.176 N:759038.321

136B OgboUmuokere-Mbanato- 6.110 E: 318579.892 E: 335294.584 ImufuUmundu-ObeguIgugu- N:760442.546 N:763737.896 Nkporogwu- Ngbede- NkwoUmunduOhullor Road

138 ObolloOgbelle-Ezimo Road with 6.138 E:336455.245 Spur to AMA-Ogbelle UNO N:764591.937

141 Express- Odobodo- Amalla- 2.410 E330219.409M E332060.418M OkpuOrba Rd N756401.184M N757005.340M

161 OnuaffaAmallaOrba - Amaedem- 3.260 E330013.337M E331877.232M Ofuluonu - Agudele Road N757236.087M N754851.576M

95 Igogoro-Amachalla-Ikpoiga- 9.680 E332934.727E E338110.708E UmuagbedoAgu N773649.120N N776531.352N

101 Amufie-Ugbaike-InyiObollo Road 7.640 E331404.957E E338628.679E

N769089.792N N771178.86N

97 Onichadugo-Olido-Amube 6.600 E327648.515M

N764492.394M Total Length 46.988

70 Aku-Udueme Road 9.200 E314445.808M E306371.356M

N741574.265M N739163.678M 3 86 Umudinwogo-Amabokwu-Useh 1.500 (with Spur to UwaniAmabokwu Road)

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Lot Roads Description / Location Length GPS LOCATION No. in the (Km) Lot Start Point End Point

87 UwaniOtobo-Ugwunani=Oshigo- 2.944 Oda Aku (with spur obie- Ugwunani-Abokwe-Umudiukwu Road

89 AcharaOhodo through Achara 9.701 E329367.399M E321356.005M Primary School to old primary school ohodo to union primary N739047.112M N749230.106M school ohodo to Lejja

90 Ohodo Express Road Junction 10.940 E325646.224M E316133.189M Through St Thomas Catholic Church + Ohodo Through Central N747024.605M N741752.376M Primary School Ohodo To Central School + Ozalla Through IjoOzalla To AmaEzikeOhemjeAku

80A Ohebedim - Ozalla - Lejja Road 10.100 E319895.555M E319257.600M

N739350.905M N746887.281M Total Length 44.385

5 Uhuogiri-Railway Road 3.100 E341155.356M E341011.490M

N668951.175M N666473.700M

13 Ogbaku-Ogugu-Owelle-Ihe Road 8.580 E333998.560M E328479.480M (From Ogbaku Town) N685532.834M N688222.122M

24 Obeagu - Ugwuaji with Spur to 7.680 E337728.692M Uzamdunu Road N704149.837M

50 UmuajiAguobuOwa- 12.560 E308785.307M E306479.691M 4 UmuajiMgbagbuowaAgbaUmuna - Ebenebe Road (with Spur to N704688.389M N705935.135M AugobuOzom through T-Junction, Umuaji)

57B AbonuzuOwa - Ajali Water Works 4.640 E316420.623M E312111.042M

N706376.212M N705473.712M

66 MTN Exp Junction-Umueze- 5.657 E313539.647M E315860.505M Aguawu Farm Settlement Road- Spur to Okposi N697112.918M N705596.337M

Total Length 42.212

116 Eha Uno-EhaNdiagu 16.940 E332581.652M E330058.883M

N713057,969M N754653.531M

122 Owere-Umuabor-EdemUmabor- 23.600 E329457.157M E344718.256M Aguudene-Mbu 5 N753376.436M N745609.043M

127 ObiaguOhomOrba Rd- 0.880 E331399.302M E333348.548M AmubeOhomOrba Rd. N758904.495M N757985.862M Total Length 41.42

117+1 Ohebe-AguOrba-AguImilike Farm 19.766 E334450.432M E334532.095M 6 40 Road + ImilikeEtiti-Ezimo Road

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Lot Roads Description / Location Length GPS LOCATION No. in the (Km) Lot Start Point End Point

N760510.840M N756075.502M

38* Neke - Umualor - Ehamufu Railway 15.400 E350040.990M E362850.970M Line Road N743132.419M N736479.282M

Total Length 35.166

Grand Total 270.059

The Proposed Intervention Works Include:

ES 4 Table 2: Proposed Intervention Works

Project Phase Activities Staffing Support Facilities Schedule

Pre-Construction • Marking of road right of way (ROW) Skilled:7 • Base camp Month 1 – 3 Phase by surveyors • Borrow pit • Preparation of staging area • Staging area • Mobilization of plant, equipment & • Work site personnel to site Unskilled:20 (3 months) • Removal of trees and vegetation • Relocation of public utilities • Siting and Preparation of base camps including sanitary facilities • Assessment of existing project location Construction • Groundworks Skilled:34 • Base camp Month 4 – 15 Phase • Rehabilitation works; • Borrow pit • Mobilization of equipment, materials • Staging area and personnel to site • Work site • Scarification unskilled:45 (12 months) • Sub-grade preparation • Earthworks • Construction of base course • Preparation of borrow pits • Construction of drainage structures and facilities • Construction of retaining walls and earth filling • Other ancillary works • Demolition and removal of old structures • Excavation • Piling • Construction of pile caps • Construction of reinforced concrete retaining wall and construction of superstructures including parapets, bridge bearings and expansion joints • Disposal of construction wastes Operation Phase • Housekeeping Skilled:5 • Road Month 16 –17 • Waste management (collection and Maintenance disposal) workshop • Clearing of culverts and trenches of • Road Corridor solid waste and silt Unskilled:15 (2 months) • Routine inspection of drainage structures and road (pavement) surface • Scheduled & unscheduled integrity checks for culvert structural components (foundation joins etc.)

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

• Maintenance of erosion control structures, fencing walls screens and other environmental barriers • Routine maintenance and replacement of wearing/faulty/damaged parts (e.g. binder) • Maintenance of road traffic controls Decommissioning • Removal of construction equipment; Skilled:5, Month 18 Phase • Disposal of construction spoil and waste in general; • Decommissioning of burrow pit • Dismantling of temporary work camp Unskilled:15 (1 month) of the contractor; and Waste management.

The Project Implementation Period is estimated at 18months. The Implementation Schedule is summarized in the chart below.

ES 5: Analysis of Alternatives

Different alternatives and options have been evaluated and considered for the proposed project in Enugu State. Consequently, the project alternatives considered are enumerated as follows:

1. “Do Nothing” Alternative 2. Using Alternative Travel Modes 3. Alternative Alignment 4. Construction of New Roads

The Project Development Options include:

1. No Project Development 2. Delayed Project Development 3. Immediate Project Development

Alternative Options for Roadway Surfacing

Three major roadway-surfacing options have been proposed for the Enugu RAMP2 road intervention project. Lateritic Base Course has been selected as the most preferred and recommended option.

ES 6: Assessment of Environmental and Social Baseline in the Project Areas

The assessment of the 270km of 29-roads in the 6 Lots showed that there are several environmental & social sensitivities that upon which the project activities may influence. The environmental sensitivities showed erosion concerns and in many areas formation of gullies, run- off, drainage & flooding, high tension cables & transformers, while social sensitivities observed included presence of churches, schools, markets, electric poles, buildings & fences, shops and along some roads, shrines.

Physico-chemical Parameters of Water

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Surface and groundwater samples were taken for each road. The pH Levels of surface and groundwater were all within the FMEnv limits of 6-9 though slightly acidic. Acidity of surface water has been shown to cause damage to roads, it is advised that in addition to laterite, limestone could be mixed with concrete for roads to be rehabilitated in areas where there is slight acidity of surface waters. Limestone has been known to make roads more resistant to the effects of acidic surface waters and acid rains.

Physico-chemical Properties of Soil Samples

The physico-chemical properties of soils from the sample locations revealed that the pH of the top soil ranged from 6.15 - 7.91 while the sub surface soil ranged from 6.29 – 6.50. The moderately low value of the soil pH indicates that the soil is slightly acidic. This maybe as a result of use of agro-chemicals like fertilizers and pesticides for agricultural practices within project area, as observed during field visit.

Socio-Economic Assessment Socio-economic assessment was conducted in the project areas through interviews, focus group discussions and distribution of questionnaires. A total of 235 questionnaires were distributed within the project area. The methodology adopted, indices measured, and results obtained are presented in chapter 5. The results show that adequate workforce can be gotten from the communities to minimize labour influx, 36.6% of the respondents are farmers while 23.4% are trader and artisans. 20.8% indicated that they were students waiting for the release of their WASCE results and the other 6.4% are civil servants with some working in the neighboring LGA secretariats. This shows that any activity that will boost agriculture and create job opportunities in the area will be highly commendable. Also based on the existence of artisans, local labour can be sourced within the project area.

Issues Affecting Transportation of Agricultural Products and other Commodities on Project Roads

Road transportation is the most common means of movement in the area surveyed. The response on the nature of roads leading to villages within the survey area indicated that majority of the roads were rated as bad with 55.3%, where some of these bad roads have serious erosion problems. The major problems affecting rural transportation in the project areas include erosion, flooding of roads by off-course Rivers and adjacent flood plains, sand piles, vegetation encroachment, potholes, and gullies. These collectively make travel slow, unsafe and hinder access to the communities.

ES 7: Impacts Identification

Summary of Potential Beneficial Environmental and Social Impacts

Environmental Impact Social Impact • Control of floods and Erosion • Employment Generation • Reclamation of Right of Way (ROW) on • The Project will see to a timely and early roads where villages, markets and sensitization and awareness of direct and indirect farmlands have encroached (A stakeholder groups through a Stakeholders’ standalone RAP has been prepared for engagement which will ensure for the provision of any issue of displacement that arise) suggestions, raising of concerns and integration of • Improved rural road infrastructure and these into decision making as regards the sustainable hydraulic structures implementation of civil works on the selected rural • Increased opportunity to develop roads. environmentally sound and safe • Capacity building opportunities for stakeholders and fadama agriculture and pastoral project personnel on effective community potential participatory mechanisms, Grievance redress, ESMP • Long term and sustained engineered implementation and Monitoring, Occupational Health control of flooding of roads and flood and Safety risks assessments etc. plains through application of resistance • Promote community inclusion and resilience flood plain management • Creation of investment opportunities strategies (Annex 5) • Provision of a lead way to drive the Enugu State • Development of a Waste Management Government towards ensuring improved Integrated

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Plan to address associated construction Water Resources Management (rivers, streams and wastes within the project corridor flood plains in the project areas) • Increased accessibility for local companies to access project communities so as to fulfil their Corporate and Social Responsibilities • Enhanced and easy transportation of agricultural produce and other commodities • Enhancement of the food/crop value chain in the project corridors • Improved access to social amenities- markets, schools, mosques/churches, recreational areas and health care centers • Improved rural road security • Strengthening of roads rehabilitation works and supervision systems including improvement in institutional responsibilities for roads construction and maintenance • Improvement of Local and State trade/business opportunities • Improvement of public goodwill and satisfaction towards governance in Enugu State • Development and acquisition of non-technical and technical skills for civil and mechanical activities during construction.

Summary of Potential Negative Environmental and Social Impacts Environmental Impact Social Impact • Increase in fugitive dusts • Likely disruption of farming activities. (This will be • Surface water contamination from addressed in a standalone Resettlement Policy sediment-laden runoffs Framework [RAP]. • Loss of vegetation and fauna • Possible relocation and destruction of markets, huts, habitat destruction petty trading shops and farms encroaching in • Vulnerability to erosion and road identified project roads. (It is noteworthy to state breakage during construction of that the Enugu RAMP 2 PIU is currently preparing a side drains Resettlement Action Plan (RAP) to address all forms • Increase in noise levels and of physical and economic displacement. Furthermore, vibration disturbances from all issues triggering OP 4.12 highlighted in this ESIA operation of heavy-duty vehicles report will be firmly and appropriately addressed in • Waste generation has the potential the RAP. The mention of any such issues in this ESIA to become public nuisance, report is for the purpose of highlighting envisaged breeding grounds for disease socioeconomic impacts. The RAP as mentioned earlier vectors and cause contamination of will address all OP 4.12 related issues, risks or soil and water impacts). • Occupational accidents and injuries to • Risks attributed to labour influx such as Gender workers Based Violence, Violence Against Children, and Sexual • Impact on physical cultural Exploitation and Abuse resources (PCRs) e.g. shrines • Increased risk of communicable diseases such as • Land degradation and increased HIV/AIDS and other STIs: due to influx of migrant susceptibility to erosion due to workers, hawkers etc. excavation of earth materials in • Increased demand on existing community health and borrow pit. sanitation infrastructure • Increased traffic with potential to increase the rate of traffic accidents and injuries. • Disturbance of fishing activities and recreation areas (to be addressed in standalone RAP) • Occupational accidents and injuries to workers • Risks related to community health and safety • Increased respiratory and eye problems from exposure to dusts and gaseous • Potential impact such as disruption or displacement of public utilities such as public hand pump boreholes, electric poles and transformers, schools, churches,

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etc. (See maps in chapter 5 and Table 9). Envisaged impacts have been mitigated for and costed in the ESMP table (Table 17), Chapter 7 of this report. • Security to personnel & workers ES 8: Environmental and Social Management Plan and estimated costs

The ESMP has been developed to meet World Bank and national standards on environmental and social (E&S) assessment and performance and covers the project implementation phases (i.e. Pre- construction, construction and operation & maintenance phases) of the project. It also presents the cost of mitigation measures of potential adverse impacts resulting from the proposed works, including monitoring responsibilities and cost. The total cost of mitigation is N 68,189,000.00 1(Sixty-Eight Million, One Hundred and Eighty-Nine Thousand naira) and equivalent of USD 222,840.20 (Two Hundred and Twenty-Two Thousand, Eight Hundred and Forty Dollars, Twenty Cents). Table below gives a detailed breakdown of mitigation and monitoring from pre-construction phase to operation phase.

It is noteworthy to state that the cost of mitigation measures are indicative of the twenty-nine (29) rural roads

Indicative cost of implementing the Environmental and Social Management Plan (ESMP)

Total* Source of # Item Unit financing Local (N) US$ World Bank intervention loan 1 Mitigation Sum 33,080,000.00 108,105.00 2 Capacity Sum 8,000,000.00 26,144.00 Building 3 GRM Sum 2,000,000 6,536.00 4 Monitoring Sum 17,910,000.00 58,529.00 5 Budget for Sum 1,000,000.00 3,268.00 Disclosure Sub-Total 61,990,000.00 202,582.00 Contingency 6,199,000.00 20,258.20 (10% of sub Total) 68,189,000.00 222,840.20

ESIA Disclosure

All safeguard reports (ESIA/ESMP/RAP) shall be disclosed by the SPIU in conjunction with the FPMU, after clearance from the World Bank. Disclosure shall be in line with the requirements as stipulated by the FMEnv, and also the World Bank. Budget for disclosure is estimated at NGN 1,000,000.00 (USD 3,268.00) as shown in the table below.

ESIA Disclosure s/n Action Remarks Cost Estimate NGN USD 1. Registration at FMEnv The FPMU shall register the ESIA at 50,000 163.40 the FMEnv 2. Disclosure on 2 state The SPIU will disclose the ESIA/ESMP 200,000 653.60 newspapers as required by the Nigeria EIA public (@ 100,000 notice and review procedures each)

1 Please Note: This budget has been prepared for all 6 Lots, and 29 roads selected for the intervention works. The total cost is indicative of approximately NGN 2,000,000 per road, per lot and shall cover for all mitigation, monitoring, capacity building, GRM implementation, disclosure and contingency costs.

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3. Disclosure on 2 The FPMU will disclose the ESIA/ESMP 400,000 1,307.20 national newspapers as required by the Nigeria EIA public (@ 200,000 notice and review procedures each) 4. Printing costs and About 25 copies will be printed for 350,000 1,144.00 circulation of copies to distribution both at the Federal be used during (FMEnv, FPMU) and State level disclosure at ESMEnv, (SMenv, SMoW, SPIU) across the Enugu Ministry of LGAs covering the 29 roads etc.-The Works & Transport, SPIU will bare responsibilities for and Enugu LGA office logistics costs and implications for circulation of copies to designated disclosure points in the state. 5. Disclosure at the The SPIU will disclose the ESIA/ESMP - - Enugu State Ministry of as required by the Nigeria EIA public Environment notice and review procedures 6. Disclosure at the The SPIU will disclose the ESIA/ESMP - - Enugu Ministry of as required by the Nigeria EIA public Works & Transport notice and review procedures (SPIU) office 7. Disclosure at Enugu The purpose will be to inform - - LGA offices stakeholders about the project activities; E&S impacts anticipated and proposed E&S mitigation measures. 8. Disclosure on the The ESIA will be disclosed according - - World Bank’s external website TOTAL 1,000,000.00 3,268.00 Exchange Rates are based on the Central Bank of Nigeria (CBN) rate of USD 1 to NGN 306

ES 9: Stakeholder Consultation

Stakeholder Consultations were held from the 5th-11th of July 2019. Consultations were conducted with all relevant levels of stakeholders following a proper stakeholder identification and mapping. Specific details of consultation with stakeholder in the decision-making category are provided in the Executive Summary. More specific details on consultations are provided in chapter 8, and the annexes 9 and 10 of this report.

Consultation with Communities

Date: July 5th, 2019

Location: Onu Ihe Market-Awkunanaw-uno Ogba Ihe Road & Amumkpa-Amaeguelu Road, Uhuogiri- Railway Road Participants: Community Members of Lot 1 roads S/N Stakeholder Concerns raised Response of Group PIU/ESIA Consultant 1. Community Commencement of road They were assured members construction and continual that they will be engagement during the project engaged by the implementation phase. contractors during the implementation of the project and that the project will commence soon. 2. Community Fear of Road Accidents as the They were assured members improved roads may lead to reckless that Contractors will driving and consequently accidents. erect caution signs, They also feared that construction warning signs and vehicles and equipment may cause speed limit signs

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accidents within the project during and after communities. construction including speed breakers. Contractors and drivers will be trained on occupational health and safety (OHS) procedures.

Date: July 5th, 2019

Location: Obeagu-Ugwuaji, Ubahu-Amankanu-Umualor-Nike RD, Oruku Afo Ezza Road Participants: Community Members of Lot 2 roads S/N Stakeholder Concerns Response of PIU/ESIA Consultant Group 1. Community Commencement of road They were assured that the project will members construction and commence soon and that they will be provision of employment considered for employment during the project opportunities during implementation phase. project implementation phase. 2. Community Concerns about the dust They were guaranteed that their concern members that would be generated would be mitigated by ensuring wetting of the during the road roads during the civil works construction work, especially in the dry season.

3 Community Destruction of people’s This will be addressed by a Resettlement members farms and properties Action Plan (RAP) for subsequent during the project. compensation. The RAP will identify and enumerate potential project affected persons; their assets and livelihood and indicate measures such as compensations and livelihood restoration activities that will be provided to them.

Date: July 5th, 2019

Location: Onu Ihe Market-Awkunanaw-uno Ogba Ihe Road & Amumkpa- Amaeguelu Road, Uhuogiri- Railway Road Participants: Community Members of Lot 3 roads S/N Stakeholder Concerns Response of PIU/ESIA Consultant Group 1. Community Commencement of road They were assured that the project will members construction. commence soon. 2. Women groups Enquiries were put The Team answered that as part of the ESIA, forward to ask if the adequate planning measures would be taken project will affect schools to ensure that it will not affect the pupils and school children. negatively, by regular community consultations to ensure updates on school calendar, which would be aligned with work schedule to prevent closures or disruptions, while also providing adequate mitigation in the ESMP.

3. Community Tampering with Waste SPIU is aware and has been discouraging the members bins during construction, practice. Also, ESMP in this ESIA has provided indiscriminate dumping mitigation to prevent continual reoccurrence. of excavated material and littering of road with soil and debris.

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Requests from Stakeholders

The stakeholders made the following requests and recommendations.

• The construction companies should employ youth from the project communities for the required labor. • The project proponents should be considerate in paying compensation to all displaced persons; • The project proponents should consult with other stakeholders like the Water Board, electricity supply companies, and NNPC for their inputs before implementing the project to avoid disruption of other infrastructure and to minimize damaging of the roads after construction in the process of fixing infrastructural utilities, services and facilities. • The project should be able to optimize the utilization of the existing facilities such as burrow pits and quarries if available, to reduce the economic, environmental and social impacts of creating new ones; • Women who are interested should be considered for offices such as site secretaries and record keepers during the construction stage; • Project communities should be sensitized on the effect of STDs HIV/AID and on the need to maintain their cultural values; • Community welfare should be considered by the project proponent to construct amenities e.g., clinics and boreholes for the various communities.

Vulnerable Groups

Vulnerable groups in the project areas were identified. Consistent with the South-Eastern states of Nigeria, these include:

• Children • Old men and women • Physically challenged individuals

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1 CHAPTER ONE: INTRODUCTION

1.1 Background

The Federal Government of Nigeria through the Federal Ministry of Agriculture and Rural Development (FMARD) is being supported by the World Bank (WB) and the French Development Agency (AFD) for the implementation of the Rural Access and Mobility Project (RAMP) in the country. The RAMP is in line with achieving the Federal Government’s Rural Travel and Transport Program (RTTP), which is aimed at improving and enhancing accessibility and mobility in the rural areas. Accessibility and mobility are crucial to the lives of rural populations since they are predominantly farmers, petty traders and artisans. The movement of their agricultural inputs and outputs are dependent on accessibility and mobility. The existing carriageway width of these rural roads varies from 3–6 m. The existing roads are earthen roads and are deteriorated due to inadequate maintenance and impact of weather elements. These roads act as a major economic corridor of the rural villages and links them up with their neighboring villages, local government headquarters and the state(s) capital. Thus, improvement of these project roads is very necessary and important.

In all the RAMP implementing states, as is the case in other states of Nigeria, the rural populace suffers a lot from the absence of, or poor conditions of roads, river crossings and drainages. The absence of, or the poor conditions of these facilities hinder the rural populace from easy transportation, access and conveyance of their commodities and agricultural inputs and outputs. Currently, RAMP 2 is presently being implemented in Five (5) States: namely, Adamawa, Enugu, Imo, Osun, and Niger States.

Considering the need to implement civil works which may pose potential adverse environmental and social impacts; the Enugu State RAMP 2 has prepared an Environmental and Social Impact Assessment (ESIA) for its proposed rehabilitation of 29 rural roads across the State.

1.1.1 Project Development Objective The Project's Development Objective (PDO) is to improve transport conditions and bring sustained access to the rural population, through rehabilitating and maintaining key rural transport infrastructure in a sustainable manner in selected Nigerian states.

1.1.2 Project Components The RAMP 2 project has three primary components:

• Component 1: Rehabilitation of Rural and State Roads - This component would finance rehabilitation works for an indicative 270.059km of rural and state roads in Enugu State as well as the related design studies and external supervision activities. • Component 2: Roads Maintenance and Local Development – This component would finance road maintenance activities on rehabilitated roads and support state mechanisms for maintenance funding. The model to be used in the maintenance mechanism involves community-based approach to among others. • Component 3: Capacity Building and Project Administration – This component would finance Institutional Strengthening activities at state level as well as project administration costs. NB: As part of the credit agreement with the World Bank, projects supported by the Bank’s funding are usually subjected to safeguard screening to determine the environmental and social risk before approval.

1.2 Rationale for the ESIA

The RAMP activities will involve medium-sized civil works during the rehabilitation of roads and river-crossings. These could result in environmental and social impacts thus triggering the World Bank’s Safeguard Policies including Environmental Assessment OP 4.01; Involuntary Resettlement OP4.12; Natural Habitats OP 4.04; and Physical Cultural Resources OP 4.11. The environmental

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State and social safeguards have been preliminary addressed through the national instruments already prepared under the project: An Environmental and Social Management Framework (ESMF) and a Resettlement Policy Framework (RPF) respectively and disclosed in country and on the World Bank website. These were prepared when the exact project locations were not known. Based on the environmental and social screening criteria set out in the ESMF, an Environmental and Social Impact Assessment (ESIA) is required for the proposed project at the State level to ensure that the adverse environmental and social impacts are identified, assessed and appropriately mitigated. Against this background, the Enugu State Project Implementation Unit (SPIU) has prepared this ESIA report for 270.059km of 29 selected rural roads organized into 6-Lots. The preparation of this safeguard instrument is in compliance with the World Bank Environmental and Social Safeguard requirements, the Federal Government of Nigeria (FGN) Environmental Impact Assessment (EIA) Law, and Enugu State Environment and Social laws and guidelines.

The ESIA aims to assess the potential environmental and social impacts that could occur as a result of the implementation of the proposed project activities in Enugu State. It will also proffer mitigation measures at the pre-construction, construction and operation phases of the project as well as define roles and responsibilities of all critical stakeholders throughout the project life cycle. This will ensure that the proffered mitigation measures are adequate, effective and are implemented in such a way that overall sustainability of the project is assured taking into cognizance social accountability on the part of the SPIU and its Contractors and other service providers.

1.3 Objectives of the ESIA

The ESIA is set to achieve the following objectives:

✓ Describe the proposed project by providing a synthetic description of the project relevant components and presenting plans, schematics, maps, figures and tables of the project area of influence. ✓ Identify the policy, legal and administrative framework relevant to the project. ✓ Define and justify the project study area for the assessment of environmental and social impacts. ✓ Describe and evaluate the current environmental and social situation; ✓ Establish social baseline information before project intervention ✓ Determine the project’s social impacts on health and social well-being; quality of the living environment; economic material well-being; Family and community; and gender relations ✓ A summary of the impacted communities for the project: location, access, population (number, demographic and social characteristics); economy (employment rate, income distribution); land use and land tenure; services (types, capacity, and adequacy) and housing. ✓ A summary of the views of the population including vulnerable groups, determined through thoroughly documented discussions with local communities. These meetings and discussions must be documented and should show how issues and problems raised are or will be resolved. ✓ Detail measures that will need to be taken to mitigate the negative social impact identified and the procedures for their implementation; ✓ Identify the preliminary ‘social area of influence’ of the project, likely impacted and beneficiary communities (nearby and distant), and stakeholders. ✓ Through analysis, determine the environmental and social changes and impacts that will likely result from the project and its various alternatives. ✓ Describe and analyse the physical, biological and human environment conditions in the study area before project implementation, and describe how these may be affected by the project either positively or negatively. This analysis shall include the interrelations between environmental and social components and the importance that the society and local populations attach to these components, to identify the environmental and social components of high value or presenting a particular interest. ✓ Taking into consideration; Climate, Air and Noise, Topography, Surface Water Quality, Ground Water Quality, Storm Water runoff, drainage pattern and aquifer characteristics, Soil, biological aspects: flora and fauna, endemic and endangered species. ✓ Sampling of relevant biophysical parameters within the project area of influence including air, noise, water and soil using in-situ and laboratory analysis as appropriate. Discuss the

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

results and its implications for the project. Sampling should be done in an accredited Federal Ministry of Environment Laboratory. ✓ Outline environmental sensitivities that may affect the project and propose recommended change to project design as required ✓ Present and analyze alternatives to the proposed project, including the “without project” option, by identifying and comparing the alternatives on the basis of technical, economic, environmental and social criteria. ✓ For the selected alternative, identifying and assessing potential importance of beneficial and adverse environmental and social, direct and indirect, short and long-term, temporary and permanent impacts, based on a rigorous method. ✓ Present the potential environmental and social risks and impacts of the proposed project ✓ Define appropriate mitigation/enhancement measures to prevent, minimize, mitigate, or compensate for adverse environmental and social impacts or to enhance the project environmental and social benefits, including responsibilities and associated costs. ✓ Develop an environmental and social monitoring program, including indicators, institutional responsibilities and associated costs. ✓ As appropriate, prepare an occupational/community health and safety plan including an analysis of the risk of accident, the identification of appropriate security measures and the development of a preliminary contingency plan. ✓ Assess the capacity available to implement the proposed mitigation measures and identify institutional responsibilities and needs for capacity building if necessary, to implement the recommendations of the environmental and social assessment and associated costs ✓ Carry out consultations with primary and secondary stakeholders in order to obtain their views on and preoccupations about the project. These consultations shall occur during the preparation of the ESIA Report to identify key environmental and social issues and impacts, and after completion of the draft ESIA Report to obtain comments from stakeholders on the proposed mitigation/enhancement measures.

1.4 Technical Approach and Methodology to the ESIA

The methodology used in the preparation of the Environmental and Social Impact Assessment (ESIA) for the project is based on guidelines as proposed by the following:

• Federal Government of Nigeria EIA Law and subsequent Federal Ministry of Environment standard procedures for conducting EIA in Nigeria • World Bank Environmental Assessment Operational Policies OP 4.01

The approach adopted involved obtaining environmental and social baseline data from desktop, field and laboratory studies, interviews, socio-economic survey and consultations with stakeholders and the affected project communities. This approach provided adequate information for establishing the environmental and social baseline status of the study area.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

2 CHAPTER TWO: POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORKS

This Chapter presents a summary of the relevant national, state and sector policies and plans; legal and institutional frameworks and World Bank safeguards policies, which are essential for guiding decision-making and implementation of the road intervention sub-project(s) in Enugu State.

A number of international environmental and social guidelines are also applicable to the operations of the Enugu RAMP-2, are also presented, and their applicability discussed.

2.1 Policy and Legal Framework

The act establishing the Federal Ministry of Environment places on it the responsibility of ensuring that all developments and industrial activities, operations and emissions are within the limits prescribed in the National Guidelines and Standards, and comply with relevant regulations for environmental pollution management in Nigeria as may be released by the Ministry. Environmental management in Nigeria is based on the National Policy on the Environment and various environmental legislations, regulations and guidelines. The relevant policy and regulatory instruments are summarized in Table 1.

Table 1: Relevant Federal/State Policies, Legislations, Regulations & Guidelines S/N Policy Instrument Year Provisions

1 National Policy on the 1989 Describes the conceptual framework and Environment revised strategies for achieving the overall goal of 1991 sustainable development in Nigeria.

2. National Policy on Agriculture 2001 Nigeria’s agricultural policy is designed to achieve overall agricultural growth and development; protection and improvement of agricultural land resources and preservation of the environment for sustainable agricultural production

Legal/Regulatory Instrument

3. Environmental Impact 1992 Provide guidelines for activities of Assessment (EIA) Act No. 86 developmental projects for which EIA is mandatory in Nigeria. The Act also stipulates the minimum content of an EIA as well as a schedule of projects, which require mandatory EIAs.

4. Land Use Act 1978 The Act vests all land comprised in the territory modified of each State on the Governor of the state and requires that such land shall be held in trust 1990 and administered for the use and common benefit of all Nigerians in accordance with the provisions of the Act.

5. Forestry Act 1994 Provides for the preservation of forests and the setting up of forest reserves.

6. Endangered Species Act 1985 Provides for the conservation and management of Nigeria’s wildlife and the protection of some of the endangered species as a result of over- exploitation

7. FEPA/FMEnv EIA Procedural 1995 The Procedural Guidelines indicate the steps to be followed in the EIA process from project

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

S/N Policy Instrument Year Provisions

Guidelines conception to commissioning in order to ensure that the project is implemented with maximum consideration for the environment.

8. National Guideline and 1991 Provide guidelines for management of pollution Standard for Environmental control measures Pollution Control

9. S.I.15 National Environmental 1991 Regulates the legal framework for the effective Protection (Management of control of the disposal of toxic and hazardous Solid and Hazardous Wastes) waste into any environment within the confines Regulations of Nigeria.

10. Urban and Regional Planning 1993 Planned development of urban areas (to include Decree No. 88 and manage waste sites).

11. Workmen Compensation Act 1987 Occupational Health and Safety reviewed 2010

12. Child’s Right Act Act No. Best interests of a child are to be paramount in 26 of all actions and clearly states the rights of the 2003 child.

2.2 Administrative Framework

2.2.1 Federal Ministries, Departments and Agencies (MDAs) The federal MDAs responsible for regulating and monitoring environmental issues at the federal level include the Federal Ministry of Environment (FMEnv), the Federal Ministry of Agriculture and Rural Development (FMARD) and the National Environmental Standards and Regulations Enforcement Agency (NESREA).

2.2.2 Federal Ministry of Environment The Ministry of Environment is the apex policy making body responsible for addressing environmental issues in Nigeria. To fulfill this mandate, the main instrument in ensuring that environmental and social issues are mainstreamed into development projects is the Environmental Impact Assessment (EIA) Act No. 86 of 1992. With this Act, the FMEnv prohibits public and private sectors from embarking on major prospects or activities without due consideration, at early stages of environmental and social impacts. The act makes an EIA mandatory for any development project, and prescribes the procedures for conducting and reporting EIA studies.

The responsibilities of the ministry include:

• Monitoring and enforcing environmental protection measures; • Enforcing international laws, conventions, protocols and treaties on the environment • Prescribing standards for and making regulations on air quality, water quality, pollution and effluent limitations, atmosphere and ozone protection, control of toxic and hazardous substances • Promoting cooperation with similar bodies in other countries and international agencies connected with environmental protection.

2.2.3 Federal Ministry of Agriculture and Rural Development

The Ministry provides credible and timely information on government activities, programs and initiatives in the development of agriculture and food production; while creating an enabling technological environment for socio-economic development of the nation.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

2.2.3.1 Other Existing National Environmental Instruments Table 2: Other Existing National Environmental Instruments S/N Regulations Year Provisions 1 National Environmental 2007 Established to ensure compliance with Standards and Regulations environmental standards, guidelines and Enforcement Agency (NESREA regulations. Act) 2 State waste management laws 1991 Ensure proper disposal and clearing of wastes 3 Public Health Law 2014 Covering public health matters 4 National Guidelines on 1999 Recognizes the value of EMS to EIA and sets out Environmental Management objectives and guidelines on general scope and Systems (EMS) content of an EMS 5 National Guidelines and 1999 It deals with the quality of water to be discharged Standards for Water Quality into the environment, sets standards and discharge measures for a wide range of parameters in water discharged from various industries. It also sets out the minimum/maximum limits for parameters in drinking water 6 National Air Quality Standard 1991 The World Health Organization (WHO) air quality Decree No. 59 standards were adopted by the then Federal Ministry of Environment (FMEnv) in 1991 as the national standards. These standards define the levels of air pollutants that should not be exceeded in order to protect public health. 7 National Policy on Flood and 2006 This policy addresses the need to combat erosion Erosion Control (FMEnv) in the country utilizing the procedures outlined in the National Action Plan for Flood and Erosion Control and Technical Guidelines, developed by the WIC Environmental Committee which was set up to plan an operational platform for these issues

2.2.4 Other Acts and Legislations 2.2.4.1 National Gender Policy (2006) It substitutes the Women's Policy adopted in 2000. The goal includes the elimination of cultural/ religions gender-based biases and harmful cultural and religious practices which rise to inequalities in gender-role relations in the Nigerian society, by ensuring: ensure equal access to women, boys and girls to both formal and informal education; ensure that women have access to critical resources and invest in their human capital as a means of reducing extreme poverty in families; and eliminate the high risks linked to many harmful traditional cultural practices, which still threaten the health of women.

2.2.4.2 Factories Act, 1990 The Factories decree 1990 is a landmark in legislation in occupational health in Nigeria. It provides a substantial revision of the colonial legislation, Factories Act 1958, in which the definition of a factory was changed from an enterprise with 10 or more workers to a premise with one or more workers thereby providing oversight for the numerous small-scale enterprises that engage the majority of the workforce in Nigeria. It stipulates the enforcement of compliance on factories, industries and organizations that employ labour on the protection of the right of workers to friendly environment, health and safety.

2.2.4.3 Worker’s Compensation Act (2010) The Workmen’s Compensation Act makes provisions for the payment of compensation to workmen for injuries suffered in the course of their employment.

2.2.5 State Ministries, Departments and Agencies (MDAs)

2.2.5.1 Enugu State Ministry of Environment and Mineral Resources; the major function of the Enugu State Ministry of Environment & Mineral Resources is to pursue the attainment of environmental sustainability and to accomplish this:

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

✓ To carry out activities that would uplift the environmental status of the state ✓ To prosecute sanitation offenders ✓ To ensure house collection of wastes among others.

2.2.5.2 Enugu State Ministry of Works and Infrastructure Enugu State Ministry of Works & Infrastructure has been mandated to coordinate all planning and implementing of State policies on works and infrastructure development, which includes road maintenance /rehabilitation activities.

2.2.5.3 Relevant State Legislations Enugu State Violence Against Persons Prohibition Act (VAPP ACT) (2015), signed into law on 23rd May 2015. This act prohibits all forms of violence against private and public life and provides maximum protection and effective remedies for victims and punishment of offenders.

2.2.6 Gender Based Violence in Nigeria

Nigeria ranks 118 out of 134 countries on the Gender Equality Index.2 Women’s disadvantaged position and lack of decision-making power in the social, economic and political spheres is reflected in policies, laws and resource allocation that thwart progress towards gender equality in the country. More than 70 percent of women live below the poverty line, and maternal mortality ratio is among the highest in the world at 576 per 100,000.3 More than half of people living with HIV (3.2 million) are women (55 percent).4 Girl enrollment in school lags behind boys, and represents one third to one quarter of classroom participants depending the state; and two-thirds of the 10.5 million out-of-school children, are girls.5

The wide diversity and distinct socio-economic, cultural and political contexts across Nigerian geopolitical regions and states results in different gender related vulnerabilities. While gender inequitable norms prevail throughout the country, these vary by region and interact with other structural, community and individual factors exposing women, girls and boys to some forms of GBV more than others. The socioeconomic status of women and girls in the northern zones lags behind those in the south: only 3 percent of girls in the North complete secondary school, over two-thirds aged 15-19 years are unable to read compared to less than 10 percent in the South, and 76 percent are married by age 18 in the northwest.6 Child marriage, acceptance of wife beating, restricted movement of women and girls are more pronounced in the North, and the prevalence of sexual violence, conflict related GBV and SEA is higher than in the South. In the South FGM, IPV, physical violence by any perpetrator, trafficking and harmful widowhood practices are more prevalent.

The term ‘gender-based violence’ reflects the underlying and systemic gender inequality which is a key driver of violence. Gender inequality exists in Nigerian households and communities, as in every society in the world; it results in women and girls experiencing limited choices, as well as restricted access to resources and opportunities compared to men and boys. The unequal distribution of power between men and women, along with engrained norms and rigid expectations on gender roles are the core drivers of GBV. GBV cuts across culture, level of education and income, religion, ethnicity, and other demographic indicators.

National Legal and policy framework

Nigeria’s national government has taken steps to penalize and address GBV and SEA, although a clear leadership with the leverage to garner multi sectoral support to address this complex problem seems absent. The institutional champion of women’s and children’s

2 British Council Nigeria. Gender in Nigeria report 2012; UNDP Human Development Report 2016. See: http://hdr.undp.org/en/content/gender-inequality-index-gii. 3 The 2013 Nigeria Demographic and Health Survey (NDHS). See: https://dhsprogram.com/pubs/pdf/PR41/PR41.pdf. 4 UNAIDS 2017 Data. See: http://www.unaids.org/sites/default/files/media_asset/20170720_Data_book_2017_en.pdf 5 NDHS 2013. 6 NDHS 2013; British Council Nigeria, 2012.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State rights and GBV issues within the government is the Federal Ministry of Women Affairs and Social Development (FMWASD). But it has limited influence on sectoral ministries who need to enforce policy, insufficient budgetary resources7 and insufficient institutional capacity to enact its mandate.

The regulatory framework to address both GBV, SEA and VAC is uneven because the Nigerian legal system is plural, and different legal systems co-exist, namely, the statutory law, Sharia law in the northern regions, and customary law in rural areas. The simultaneous application of this three-tier system creates differentiated degrees of protection to women’s and children’s rights8 which varies in every state and its enforcement is weak. There is a lack of clear mandates regarding which institutions oversee child protection and the design and implementation of violence prevention strategies and provision of services. Insufficient budget allocation both at national and state levels, coupled with inadequately trained and staffed structures to provide social welfare, justice, education and health services that are women, child and survivor centered. While efforts to provide GBV survivors with basic response services is concentrated in the NE by international non-governmental organizations or the UN system, there are very limited government or non-governmental services in the rest of the country, those that exist are for the most part unregulated, uncoordinated and unpredictable.9 This is aggravated by a generalized lack of trust of citizens, particularly women, in the criminal justice system to enforce the existing laws. Moreover, lack of awareness of laws and knowledge of rights, amidst a context dominated by social norms that legitimate the perpetration of abuse, stigma and underreporting, results in the consequent impunity of perpetrators, possible re-victimization of survivors and the reproduction of the cycle of violence.

Two key national laws addresses GBV, the Child Rights Act (CRA, 2003), and the Violence Against Persons Prohibition Act (VAPP, 2015) which have been passed by the Federal Capital Territory (FCT) but not by many of the 36 states, making them inapplicable in those that have not adopted them. While CRA has been passed in 24 states, VAPP has been passed in 4 states in addition to the FCT. Where laws are domesticated, implementation remains weak as institutional capacities are weak (social welfare, police, family courts). In practice, the legal and judicial systems provide women and children with little protection against violence, and timely and adequate support services are scarce and often ill-equipped to respond to survivors’ needs.

2.2.7 World Bank Safeguard Policies The World Bank's environmental and social safeguard policies are a cornerstone of its support to sustainable poverty reduction. The objective of these policies is to prevent and mitigate undue harm to people and their environment in the development process. These policies provide guidelines for bank and borrower staff in the identification, preparation, and implementation of programs and projects. The effectiveness and development impact of projects and programs supported by the Bank has substantially increased as a result of attention to these policies.

The World Bank safeguard policies contains ten (10) Environmental and Social Safeguard Policies which are designed basically to mitigate the adverse effects of development projects, and to improve decision making. Specifically, the RAMP-2 triggers four of these policies: Environmental Assessment OP/BP 4.01, Involuntary Resettlement OP/BP 4.12, OP/BP 4.04: Natural Habitats and OP 4.11 Physical Cultural Resources. The Enugu RAMP2 intervention works need to comply with the requirements of triggered safeguard policies as well as those of the Nigeria. Table 3 below presents a comparison between OP 4.01 and the EIA guidelines is illustrated in Table 3.

Table 3: Comparison between Nigeria EIA Guidelines & World Bank Policy Nigerian EIA Guidelines World Bank Policies The Environmental Impact The World Bank categorization (A, B, & C) corresponds in Assessment Act No. 86 of 1992 principle with the Nigeria EIA requirements of Category I, II requires that development projects and III, which in actual practice is done with regard to the be screened for their potential level of impacts associated with a given project or activity impact. Based on the screening, a

7 UN Women data from 2011. 8 UN CEDAW 2017. 9 UNICEF 2018.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Nigerian EIA Guidelines World Bank Policies full, partial, or no Environmental impact assessment may be required. Guidelines issued in 1995 direct the screening process. Category I projects will require a Category A - projects are those whose impacts are full Environmental Impact sensitive, diverse, unprecedented, felt beyond the Assessment (EIA). immediate project environment and are potentially irreversible over the long term. Such projects require full EA. Category II projects may require Category B - projects are those whose impacts are only a partial EIA, which will focus reversible, indirect, site-specific, localized and short-term. on mitigation and Such projects may require full or partial EA Environmental planning measures, unless the project is located near an environmentally sensitive area-- in which case a full EIA is required. Category III projects are Category C - Projects are mostly benign and are likely to considered to have “essentially have minimal or no adverse environmental impacts. Beyond beneficial impacts” on the screening, no further EA action is required for a Category C environment, for which the Federal project, although some may require environmental and Ministry of the Environment will social action plans prepare an Environmental Impact Statement. Category FI- A proposed project is classified as Category FI if it involves investment of Bank funds through a financial intermediary, in projects that may result in adverse environmental impacts Generally, with regards to environmental and social management issues, legislation is in a continuing process of development in Nigeria. Nevertheless, in the event of divergence between the two, the World Bank safeguard policy shall take precedence over Nigeria EA laws, guidelines and or standards for this intervention project.

2.2.8 World Bank Environment and Social Safeguards Policies Applicability to RAMP 2

As discussed in section 2.2.7, the description and applicability of the triggered policies are shown in Table 4.

Table 4: Triggered Safeguard Policies Policy Yes No Applicability due to How this Project Addresses Policy Requirements Environmental X Construction, rehabilitation As targeted sites have been Assessment and installation of hydraulic identified, a proper assessment (OP 4.01) structures will trigger site- has been carried out to determine specific impacts. the actual environmental and social impacts of the proposed rehabilitation works in the project area. Involuntary X Project impacts that may A separate Resettlement Action Resettlement (OP result in loss of assets, Plan (RAP) shall be prepared to 4.12) physical and economic ensure potential project affected displacement, loss of access persons (PAPs) in the project area to livelihood or are adequately compensated in disturbances. line with the requirements of this policy. Natural Habitats X From conversion or The project includes mitigation OP/BP 4.04 degrading of natural measures acceptable to the Bank. habitats. Such mitigation measures include, as appropriate, minimizing habitat loss. Physical Cultural X The project may include The project includes measures to

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Resources OP/BP sites having archaeological assist in their preservation, and to 4.11 (prehistoric), avoid their elimination of cultural paleontological, historical, heritage. In the event that a religious, and unique natural cultural heritage or a sensitive site values. is encountered during the implementation of the civil works, a chance find procedure which indicates actions to take is attached in Annex 13 of this report.

2.2.8.1 International Treaties and Conventions on Environment to which Nigeria is a party Some of the international Treaties and Conventions on environment to which Nigeria is a party are summarized in Table 5.

Table 5: International Treaties and Conventions on Environment to which Nigeria is a Party S/N Treaties and Conventions Year Agreement

1. The United Nations 1972 Provide guidelines for protecting the integrity of Environmental Guidance the global environment and the development Principles system 2. Montreal Protocol on Substances 1987 An international treaty to eliminate Ozone that deplete the Ozone Layer depleting chemical production and consumption.

3. United Nations Convention on 1992 Places general obligations on countries to Biological Diversity observe sustainable use and equitably share the plants and animals of the earth 4. United Nations Framework 1992 It calls on developed countries and economies to Convention on Climate Change limit her emissions of the greenhouse gases which cause global warming 5. Convention on International 1973 Restricts the trade of fauna and flora species Trade in Endangered Species of termed as endangered Species Wild Fauna and Flora 6. Convention on Conservation of 1979 Stipulates actions for the conservation and Migratory species of Wild animals management of migratory species including (Bonn Convention) habitat conservation

7. Vienna Convention for the 1985 Places general obligation on countries to make Protection of the Ozone Layer appropriate measures to protect human health and the environment against adverse effects resulting from human activities, which tend to modify the ozone layer.

2.2.9 International Treaties Relevant to Social Protection

Some relevant international treaties include:

• The International Covenant on Civil and Political Rights (ICCPR) (2004); which pursues the promotion of self-realization by upholding the right of self-determination. By virtue of that right they freely determine their political status and freely pursue their economic, social and cultural development. Also, all peoples may, for their own ends, freely dispose of their natural wealth and resources without prejudice to any obligations arising out of international economic co-operation, based upon the principle of mutual benefit, and international law. In no case may a people be deprived of its own means of subsistence.

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• The International Covenant on Economic, Social and Cultural Rights (ICESCR) (2004); which undertakes to take steps, individually and through international assistance and co-operation, especially economic and technical, to the maximum of its available resources, with a view to achieving progressively the full realization of the rights recognized in the present Covenant by all appropriate means, including particularly the adoption of legislative measures.

• The Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT) (1993) that promotes the protection of people from "torture", which means any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession, punishing him for an act he or a third person has committed or is suspected of having committed, or intimidating or coercing him or a third person, or for any reason based on discrimination of any kind, when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity. It does not include pain or suffering arising only from, inherent in or incidental to lawful sanctions. • The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) (1984), discourages the discrimination against women by any distinction, exclusion or restriction made on the basis of sex which has the effect or purpose of impairing or nullifying the recognition, enjoyment or exercise by women, irrespective of their marital status, on a basis of equality of men and women, of human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field.

• The Convention on the Rights of Persons with Disabilities (CRPD) (2012); which adopts a broad categorization of persons with disabilities and reaffirms that all persons with all types of disabilities must enjoy all human rights and fundamental freedoms. It clarifies and qualifies how all categories of rights apply to persons with disabilities and identifies areas where adaptations have to be made for persons with disabilities to effectively exercise their rights and areas where their rights have been violated, and where protection of rights must be reinforced.

• International Convention on the Elimination of All Forms of Racial Discrimination (1976), which discourages any distinction, exclusion, restriction or preference based on race, colour, descent, or national or ethnic origin which has the purpose or effect of nullifying or impairing the recognition, enjoyment or exercise, on an equal footing, of human rights and fundamental freedoms in the political, economic, social, cultural or any other field of public life.

• UNESCO 1970 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Cultural Property. • The Convention on the Rights of the Child (CRC) (1990), • The National Action Plan for the Implementation of United Nations Security Council Resolution 1325 (2009);

In addition, Nigeria also has obligations to protect the environment through various commitments to the African Union, the Economic Community of West African States and the Commonwealth. It is also committed through relations with the European Community under the Lome IV Convention.

2.2.10 Regional Treaties Relevant to Gender based Violence (GBV)

• The African Charter on Human and Peoples’ Rights (ACHPR) (1982); • The African Charter on the Rights and Welfare of the Child (ACRWC) (2007); • The Protocol to the ACHPR on the Rights of Women in Africa (the “Maputo Protocol”) (2007).

2.2.11 Assessment of the Policy and Regulatory Framework for Environmental & Social Issues Generally, with regards to environmental and social management issues, legislation is in a continuing process of development in Nigeria. Amongst the existing pieces of legislations highlighted above, there are a number of state, national and international environmental

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State guidelines applicable to the proposed project. An assessment of the adequacy of this framework to guide the Enugu RAMP 2 is provided in Table 6 below: Table 6: Assessment of the adequacy of the environmental and social instruments to guide the RAMP 2 Regulatory and Institutional Framework Implications for RAMP 2 Summary The Enugu State Government through the Enugu The Enugu State Ministry of Environment and State Ministry of Environment and Mineral Mineral Resources is conversant with the Resources implements environmental protection Environmental Assessment (EA) legislation, policies and monitoring in the State. procedures and framework applicable based on the Federal EIA Act. With adequate training, monitoring and implementation of mitigation measures for negative environmental and social impacts of the RAMP will be well accounted for. i. The FMEnv through the National Policy on i. The EIA Act provides the backing and Environment provides a basis for precedence to ensure that the required environmental protection, more-so, the environmental assessments are conducted Policy was reviewed in 2016 to align with prior to implementation of the RAMP, emerging global environmental concerns like based on the project been categorized as B climate change, sustainable development, (Nigeria EIA category II) which allows for circular economy and stronger environmental all associated assessments to be carried regulations in general. The reviewed Policy is out. currently in the process of being approved by the relevant authorities. ii. The EIA guideline mandates a disclosure procedure for 21 days to enable public review of the environmental and social ii. Nation-wide, there has been good management reports. Furthermore, the compliance with disclosure procedures both World Bank’s OP/BP 17.50 stipulates a for nationally funded projects and donor process for Public Disclosure assisted projects. The SPIU in collaboration with the FPMU will ensure that all safeguard instruments including this ESIA are adequately disclosed for the mandatory period of 21 days and in the minimum designated locations.

The National Gender Policy provides a The RAMP through the social safeguard/ GBV framework for ensuring gender inclusion and officer will ensure that there is gender sensitivity in developmental plans and programs consideration in every phase of the program at the national and sub-national levels and also ensure the implementation of GBV procedures. The Child’s right Act provides a platform for States are becoming more aware of the Act protection of children against child labor, and the need for child protection and exploitation and other forms of social vices preservation. RAMP 2 will strictly adhere to this legislation in line with mitigation measures in the ESMP table. This will be enforced and monitored by the Supervisory Consultant, SPIU, and other relevant bodies as identified in the ESMP. The Factories Act and Workmen Compensation The State Ministries, SPIU, Supervisory Act allow for protection of the right of workers to Consultants involved in the project will ensure friendly environment, health and safety. strict compliance to Worker’s protection laws. The Federal Government has robust agricultural The Federal Government EIA sectoral policies which provides a framework for guidelines exist for the agricultural sector investments in the sector. In addition, there are which will guide the safeguard instruments emerging environmentally friendly and socially required for sub-projects and allow for inclusive policies including the Green Alternative mitigation of potential negative impacts. (Agricultural Sector Roadmap), the Agricultural

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Regulatory and Institutional Framework Implications for RAMP 2 Summary Promotion Policy (APP) which embeds factoring Climate change and Environmental sustainability as one of the policy’s thrust.

Thus, for the RAMP 2, there are sufficient social and environmental guidelines to ensure that the entire project succeeds. In order to support the due diligence process, to avoid causing harm and to ensure consistent treatment of environmental and social issues across the sub-project intervention areas, institutional capacity strengthening, and funding have been recommended in this report.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

3 CHAPTER THREE: PROJECT DESCRIPTION

3.1 Introduction

This Chapter presents an overview of the project description in the context of the requirements as presented in the engineering design reports.

3.2 Description of the Project

The Enugu State Project Implementation Unit (SPIU) has identified and selected 29 high priority rural roads across the state (termed as Phase 2 Roads) for prompt intervention. These rural roads when rehabilitated, could present opportunities for high economic and social benefits to the rural people serviced by them.

3.2.1 Description of the Roads and Scope of Works Broadly, the intervention works will involve the upgrading, rehabilitation and maintenance of 29 rural roads, across the State with a total length of 270.059km. The selected rural roads are existing roads which present varying levels of deterioration. The predominant issues associated with the roads include:

i) Erosion ii) Flooding iii) Lack of hydraulic structures necessary to control flooding and preserve road integrity

The identified roads for rehabilitation are presented below

Table 7: List of Roads to Be Rehabilitated Lot Roads Description / Location Length GPS LOCATION No. in the (Km) Start Point End Point Lot 1 40 Nkpologu-Uvuru-Ukpata-Adaba- 39.221 E304840.603M E292674.023M AkunyiUmulokpa Road N748069.113M N726397.468M 119 Odenigbo-Edem Ani-UgwuiyiMpi- 11.562 E: 320834.316 E: 319793.554 OfuluOnu Road with Spurs to N:758671.482 N:757921.405 Imilike-Ubogidi Road and Catholic Parish Road 125 Nguru-Akpotoro-St Mary Obimo 9.100 E: 321694.473 E: 316309.934 N:753357.350 N:752065.518

Total Length 59.883

2 129 EnyazuruOhomorba Rd 2.220 E331348.795M E333348.548M N758848.218M N757985.862M

142 Umu-Ezejor-Agu-Udele-Itabor 2.930 E: 351280.013 E: 352894.870 Road with Spur at Ubahor N:759038.321 N:759347.176 136B OgboUmuokere-Mbanato- 6.110 E: 318579.892 E: 335294.584 ImufuUmundu-ObeguIgugu- N:760442.546 N:763737.896 Nkporogwu- Ngbede- NkwoUmunduOhullor Road 138 ObolloOgbelle-Ezimo Road with 6.138 E:336455.245 Spur to AMA-Ogbelle UNO N:764591.937

141 Express- Odobodo- Amalla- 2.410 E330219.409M E332060.418M OkpuOrba Rd N756401.184M N757005.340M 161 OnuaffaAmallaOrba - Amaedem- 3.260 E330013.337M E331877.232M Ofuluonu - Agudele Road N757236.087M N754851.576M 95 Igogoro-Amachalla-Ikpoiga- 9.680 E332934.727E E338110.708E UmuagbedoAgu N773649.120N N776531.352N 101 Amufie-Ugbaike-InyiObollo Road 7.640 E331404.957E E338628.679E N769089.792N N771178.86N 97 Onichadugo-Olido-Amube 6.600 E327648.515M N764492.394M Total Length 46.988

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Lot Roads Description / Location Length GPS LOCATION No. in the (Km) Start Point End Point Lot 70 Aku-Udueme Road 9.200 E314445.808M E306371.356M N741574.265M N739163.678M

86 Umudinwogo-Amabokwu-Useh 1.500 E325648.405M E316538.327M (with Spur to UwaniAmabokwu N745754.125M N745714.195M Road) 87 UwaniOtobo-Ugwunani=Oshigo- 2.944 E325148.835M E306738.317M Oda Aku (with spur obie- N735754.075M N745714.135M Ugwunani-Abokwe-Umudiukwu Road 89 AcharaOhodo through Achara 9.701 E329367.399M E321356.005M Primary School to old primary N739047.112M N749230.106M 3 school ohodo to union primary school ohodo to Lejja 90 Ohodo Express Road Junction 10.940 E325646.224M E316133.189M Through St Thomas Catholic N747024.605M N741752.376M Church + Ohodo Through Central Primary School Ohodo To Central School + Ozalla Through IjoOzalla To AmaEzikeOhemjeAku 80A Ohebedim - Ozalla - Lejja Road 10.100 E319895.555M E319257.600M N739350.905M N746887.281M

Total Length 44.385 5 Uhuogiri-Railway Road 3.100 E341155.356M E341011.490M N668951.175M N666473.700M 13 Ogbaku-Ogugu-Owelle-Ihe Road 8.580 E333998.560M E328479.480M (From Ogbaku Town) N685532.834M N688222.122M 24 Obeagu - Ugwuaji with Spur to 7.680 E337728.692M Uzamdunu Road N704149.837M 50 UmuajiAguobuOwa- 12.560 E308785.307M E306479.691M UmuajiMgbagbuowaAgbaUmuna - N704688.389M N705935.135M 4 Ebenebe Road (with Spur to AugobuOzom through T-Junction, Umuaji) 57B AbonuzuOwa - Ajali Water Works 4.640 E316420.623M E312111.042M N706376.212M N705473.712M 66 MTN Exp Junction-Umueze- 5.657 E313539.647M E315860.505M Aguawu Farm Settlement Road- N697112.918M N705596.337M Spur to Okposi Total Length 42.212 116 Eha Uno-EhaNdiagu 16.940 E332581.652M E330058.883M N713057,969M N754653.531M 122 Owere-Umuabor-EdemUmabor- 23.600 E329457.157M E344718.256M 5 Aguudene-Mbu N753376.436M N745609.043M 127 ObiaguOhomOrba Rd- 0.880 E331399.302M E333348.548M AmubeOhomOrba Rd. N758904.495M N757985.862M Total Length 41.42 117+140 Ohebe-AguOrba-AguImilike Farm 19.766 E334450.432M E334532.095M 6 Road + ImilikeEtiti-Ezimo Road N760510.840M N756075.502M 38* Neke - Umualor - Ehamufu Railway 15.400 E350040.990M E362850.970M Line Road N743132.419M N736479.282M Total Length 35.166 Grand Total 270.059

The proposed civil works details are documented in the Engineering Design Report (2019). In line with the Engineering Design Report, the scope of civil works to be carried out on the 270.059km of 29-selected roads include:

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

1. Rehabilitation/construction of rural roads on existing alignments as well as realigning of portions where required 2. Site clearance; earthworks; 3. Provision of sub-base; 4. Provision of lateritic base course (generally as surfacing); 5. Trapezoidal earth side drains; with turnouts/off-shoots; 6. Lined side drains; single and multiple 900 mm concrete pipe culvert extensions and new culverts; 7. Reinforced concrete box culverts; possibly reinforced concrete bridges on bored piles; and 8. Road signs and other road furniture.

The Works contract also includes for traffic management, and strict social and environmental measures, to be included in the Contractor’s Environmental and Social Management Plan (C-ESMP) which shall also be supervised by a Supervisory Consultant procured by the SPIU.

1. For the proposed intervention works, road design is based on the Low Volume Design Road Manual for RAMP 2. The proposed Design width for the 29 rural roads is 8 m (6 m carriageway and 1 m outer shoulder on each side in areas bordered by dense vegetation10).

2. In built-up areas , the carriage width is 6 m with concrete-lined drains on both sides. The Pavement Structure of the road will consist of Earth work embankment (variable) as per site requirements, including Sub-base (15 cm) and (base course 15 cm).

3. For hydraulic structures, most designs include 900 mm diameter pipe culvert (single and double cell) as per catchment area and hydrological data. However, for some locations, (with regards to site conditions and requirements), box culverts measuring 2x2 (single and double cell) 3x3 (single and double cell) will be installed.

4. Concrete lined drains have been considered suitable for channeling water in built up areas or in very steep (high gradient area) to mitigate and control erosion. Around the culverts and at high embankment areas the SPIU has proposed and designed grouted riprap for the flood protection to control erosion and future damage to hydraulic structures and embankment. No bridge has been designed for phase 2 roads. The detailed activities in each phase including staffing, support activities and services are described in Table 8 below.

10 According to the engineering designs and site visits, some roads are bordered by dense vegetation of which minimal vegetation clearing may be required so as to meet with the proposed road dimensions. In such cases, the contractor will ensure that appropriate mitigation measures such as “limit zone of vegetation clearance”, “re vegetate”, are carried out (See Table 16 Construction Phase – Environmental Impacts). In instances where vegetation clearing may impact adversely on any property or result in economic or physical displacement, appropriate mitigation will be captured in a stand-alone RAP. Such roads are described in Table 9.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Table 8: Proposed Activities for Road Intervention Works Project Phase Proposed Intervention Works Activities Staffing per Support Schedule Lot Activities and (Months) Services Preparatory • Marking of road right of way (ROW) by Skilled Staging Area Works: surveyors Labour: 7 3 Months Pre-construction Marking • Preparation of staging area • Mobilization of plant, equipment & Unskilled Clearing personnel to site Labour: 20 • Removal of trees and vegetation • Relocation of public utilities Mobilization • Siting and Preparation of base camps

including sanitary facilities Rehabilitation/ • Assessment of existing project location Construction works Civil Works: • Groundworks Skilled Burrow pit 12 Month for 270.059 km Road works • Rehabilitation works; Labour: 34 roads of Enugu • Mobilization of equipment, materials and Earth-filling RAMP2 Groundworks personnel to site Unskilled machinery • Scarification Labour: 45 • Sub-grade preparation Temporary Side drains • Earthworks construction

• Construction of base course waste collection

• Preparation of burrow pits areas Construction Culverts & River • Construction of drainage structures and Crossing facilities • Construction of retaining walls and earth filling • Other ancillary works • Demolition and removal of old structures • Excavation • Piling • Construction of pile caps • Construction of reinforced concrete retaining wall and construction of superstructures including parapets, bridge bearings and expansion joints • Disposal of construction wastes Operation Maintenance • Housekeeping Skilled Supervisory and 2 Months Works: • Waste management (collection and Labour: 5 Auditing Services disposal) Road, culverts & • Clearing of culverts and trenches of solid Unskilled Maintenance and river waste and silt Labour: 15 operations crossing/bridge • Routine inspection of drainage structures and road (pavement) surface maintenance works • Scheduled & unscheduled integrity checks

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Project Phase Proposed Intervention Works Activities Staffing per Support Schedule Lot Activities and (Months) Services for culvert structural components (foundation joins etc.) • Maintenance of erosion control structures, fencing walls screens and other environmental barriers • Routine maintenance and replacement of wearing/faulty/damaged parts (e.g. binder) • Maintenance of road traffic controls Demobilization Closure Works: • Removal of construction equipment; Skilled Landscaping 1 Month Site demobilization • Disposal of construction spoil and waste in Labour: 5 services activities general; • Decommissioning of burrow pit Unskilled • Dismantling of temporary work camp of Labour: 15 the contractor; and • Waste management.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

3.3. Project Implementation Schedule and Activities

The road rehabilitation and ancillary civil works are estimated to be implemented over an 18 months’ period. See the Implementation Chart below.

Phase Activities Implementation Period (Months)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

1. Pre-Construction Preparatory Works

2. Construction Civil Works

3. Operation Maintenance Works

4. Decommissioning Closure Works

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

3.3.1 Raw Material Supply

Major inputs in the Enugu State RAMP2 road intervention sub-project will include various construction equipment and machinery for vegetation (bush) clearing, earth (soil) movement, topographic leveling, alignment and re- alignment of road segments, creation of road drainage, gravel and fill material usually excavated on-site from borrow pits that may be established for this purpose (Annex 15 details a borrow Pit Management Plan, for proposed intervention works and project sites).

3.3.2 Sources of Energy Available to the Project

Energy will be provided from machines dependent on petroleum products, which include motor gasoline, dual-purpose kerosene, and automotive gas oil, which represent major energy sources in Enugu available to the project.

3.3.3 Labour, Manpower and Human Resource

The project will require specialized (skilled) and unskilled human resource and labour. The contractor’s workforce will mostly consist of skilled personnel such as engineers, surveyors, and technicians, environmental and social safeguard officers, health and safety officer, etc. Majority of the ancillary workforce will comprise of local labour.

3.3.4 Campsite & Staging Areas

To ensure ease of coordination of operations, a site office and campsite will be established for each LOT, while each contractor will be required to identify a staging area for plant & equipment. In the interim, the SPIU has engaged communities within the allocated Lots with regards the identification of suitable locations for campsites and staging areas. It has been agreed that Contractors will include aspects of campsite management and community health and safety in their C-ESMPs. Exact locations are not known at this point but will be secured by Contractors in liaison with community representatives prior to implementation. The location for the establishment of the contractor's and the Resident Engineer's camps and sites should be determined in consultation with the Resident Engineer, the SPIU and the local communities, taking into account the following aspects:

✓ Be located outside the protection zone of watercourses (100m) and wetlands; ✓ Be located within an acceptable distance from existing residential areas; ✓ Not located in areas with intact vegetation; ✓ The contractor must first obtain the necessary licenses and consents from the relevant local government actors or from the owner of the needed area; ✓ Although it is the contractor's decision, it is recommended that whenever possible the camps should be handed over to the administrative or community authorities for future

use; ✓ The contractor must submit for the prior approval of the Resident Engineer, the implementation design and other project structures and specifications related to the camps and sites that are intended to be built; ✓ The contractor shall take all necessary measures and precautions to ensure that the execution of the works is carried out in accordance with environmental, social, legal and regulatory requirements, including those set out in this document; ✓ The contractor shall take all measures and precautions to avoid any disturbance in the local communities and among the users of the road, as a result of the project execution; ✓ The contractor shall, whenever possible, apply measures to reduce or eliminate any sources of disturbances;

✓ The contractor shall follow the provisions of this document, as well as the applicable legislation and standards, during the use, operation and maintenance of the camps and sites, in particular with regard to water supply and sanitation, solid waste management, handling and storage of dangerous substances, etc., and ✓ The areas occupied by the camps and sites must be recovered at the end of the project, when the contractor is demobilized, through the replacement of previously existing conditions, unless other uses are intended.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

3.3.5 Sourcing of Other Materials

Naturally occurring construction materials such as water, fine sand and aggregates are available in the project area; where applicable approvals may be required for the extraction of raw materials. Materials proposed to be used are presented subsequently.

a) Water: Water for the proposed road rehabilitation and construction works can be sourced from streams/rivers within the vicinity of some of the project areas.

b) Fine Sand: Like water, river sand is obtainable from some of the rivers along the project area. The river sand may be compensated with fine aggregates (quarry dust) if river sand is found not to be in sufficient quantity for the roads’ rehabilitation and construction.

c) Aggregates: Aggregates (coarse sand) and laterite can be purchased, and stock piled from existing quarries in the local government areas of the State. The aggregates must meet the requirements stipulated in relevant sections of Federal Ministry of Works General Specification, Vol II (Roads and Bridges).

A Cross section of the road engineering designs is shown in Figure 1,2 and 3.

Figure 1: Engineering design of typical cross-section of road in built up areas with reinforced concreted lined drains

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 2: Typical Road Cross-Section in Build Areas with Stone Pitched Drains

Figure 3: Typical normal cross section in farm/dense vegatation areas

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

4 CHAPTER FOUR: ANALYSIS OF PROJECT ALTERNATIVES

4.1 Project Alternatives Different alternatives and options have been evaluated and considered for the proposed project in Enugu State. Consequently, the project alternatives considered are enumerated as follows:

1. “Do Nothing” Alternative 2. Using Alternative Travel Modes 3. Alternative Alignment 4. Construction of New Roads

The Project Development Options include:

1. No Project Development 2. Delayed Project Development 3. Immediate Project Development

4.1.1 Do Nothing Project Alternative A do nothing or no-development scenario is one in which the road intervention project is not executed. With the “do nothing” option, poor agricultural marketing services, coupled with increased safety risks from the worsening road conditions as a consequence of the persistent gully erosion and flooding in the project area will be exacerbated. Thus, reducing safe conveyance of agricultural produce; potential for beneficial agricultural linkages; amount of traffic on the roads etc. This will inadvertently drive prices of basic items higher and probably beyond the reach of the rural dwellers. Additionally, this may ultimately have an undesirable impact on the state economy. This scenario is therefore inappropriate, as it would inhibit meeting the RAMP2 development objectives and the state’s growing transport needs.

4.1.2 Using Alternative Travel Modes Other modes of efficient passenger travel and goods movement over long distances include; air, rail, and marine. With regards to goods movement in Enugu State and the South-East generally, the only realistic alternative to trucking that has the advantage of cost effectiveness and preservation of the quality of goods, is rail. Rail transit is a feasible alternative for transporting passengers and goods in Enugu State. However, currently, there are no passenger and goods rail services that would offer this extensive linkage between the neighboring communities. Furthermore, the other modes of travel are not seen as effective alternatives.

4.1.3 Alternative Alignment Alternative alignment options can be achieved from modification or changes to the engineering design. However, this could be more expensive as this implication would attract more costs in terms of additional raw materials required for the work. Also, it would be more disruptive as a result of the associated matter of physical and economic displacement, prolonged road closures and traffic diversions, which can lead to loss of revenues from diverted traffic. It would further entail very high costs for property acquisitions from land-take and compensation claims, loss of employment and reduced access. This alternative is not acceptable as the additional cost implications are high.

4.1.4 Construction of New Roads The Nigeria road network is relatively dense consisting of about 194,000 km of roads. This includes 34,000 km of federal roads, 30,000 km of state roads and 130,000 km of registered rural roads. The road density is about 0.21 km of roads per square km. Despite the relatively high road density, the rural accessibility index for Nigeria (defined as the proportion of the rural population living within 2kms away from an all-weather road) is low, at only 25.5 percent, leaving about 92 million rural dwellers unconnected. Rural access is limited where the poor population is concentrated. The 29 roads under consideration in this sub-project are already in existence, however, due to deteriorating conditions, over time, there is an increasing demand for the rehabilitation and improvement of the vehicular usefulness of these rural roads and the conservation of rural road/transport assets network in Enugu State, as most are no longer in their proper state. Unfortunately, due to the terrain challenges, the attendant costs required for the construction of new roads translates to a higher aggregated expenditure on associated costs such as the fuel for running equipment and bituminous product prices locally, technology used in road works, contract management practices, and the availability and quality of road construction materials. Thus, considering the timelines available for the accomplishment of the goals of this

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State project, the holistic assessment is that embarking on the construction of entirely new roads, as opposed to rehabilitation of existing roads would attract significantly higher intervention costs, that will undoubtedly require more materials and will in the long run take a longer time before the benefits of the project can be enjoyed by the communities and rural dwellers. Thus, the option of constructing entirely new roads is not practicable, in this regard.

4.2 Development Options 4.2.1 No Project Development This option assumes the status quo is maintained with no development of the proposed road intervention works. Ultimately, the adoption of this option will imply that the envisaged benefits such as socioeconomic and health benefits of the project will not be realized. With the deepening focus of the government at both the Federal and State levels on the agricultural sector, a lack of development of the roads infrastructure to enhance the rural linkages in Enugu State could hamper the envisaged socioeconomic development of Enugu State and the neighboring States to which Enugu has strong economic ties. Inadvertently, rural dwellers would continue to experience post- harvest losses from a lack of appropriate means of transporting the agricultural goods, while the forces of demand and supply would mean that the prices of the agricultural items will remain high in the markets and may remain uncompetitive in comparison with goods from other States, thereby stifling the potentials of economic growth. The No development option is therefore not appropriate on the basis that the rural roads are a necessity for transport of people, goods and socioeconomic growth.

4.2.2 Delayed Project Development This option implies that the planned road intervention project will be delayed until a much later date. Adopting this option will mean that there is a strong likelihood that population within the project area will continue to grow, with a relational increasing demand for road infrastructure to service the population, while unintentionally, the deplorable access to the rural areas would continue to challenge socio-economic development. In addition, the delay may also result in unnecessary increase in the cost of the intervention project in the future, especially considering the impact of the inflationary forces on prices of materials. For these reasons, a “delayed Project Option” will be rejected.

4.2.3 Road Surfacing Alternative Roadway surfacing is an increasingly relevant consideration for the RAMP interventions. Consequently, three major roadway-surfacing options have been proposed for the Enugu RAMP2 road intervention project. Lateritic Base Course is the most preferred and recommended option.

Figure 4: Lateritic Base Course Base Surface Treatment

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

4.2.4 Immediate Project Development This option implies that the project will go ahead as planned. The “immediate project” option will ensure the rehabilitation of rural access roads will be carried out, by mobilizing all materials, plants and equipment necessary for execution of intervention works. This would essentially improve transport conditions and bring sustained access to the rural populace. Consequently, the rural communities in these areas will begin to enjoy the environmental, social, economic and health benefits of this intervention project as highlighted in this ESIA report. This option is therefore considered the most viable and is therefore recommended for implementation.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

5 CHAPTER FIVE: DESCRIPTION OF THE PROJECT ENVIRONMENT AND BASELINE STUDIES

5.1 General Overview of Enugu State and the Project locations

Enugu state is an inland state in southeastern Nigeria. It is located at 6o30' North of Equator, and 7o30' East of Latitude. It is bordered by the following states: Abia and Imo to the south; Ebonyi to the east, Benue to the north-east, Kogi to the north-west and to the west. It covers an area of 7,161 km2 (2,765 sqm), and ranks 29th out of the 36 States of Nigeria in terms of land size.

Enugu State is currently made up of 17 Local Government Areas, which are: , , , , , , Igbo-Etiti, Igbo-Eze North, Igbo-Eze South, Isi-Uzo, , , , , , Udi and . Eleven (11) of which the Enugu RAMP 2 interventions will be implemented. See Figure 5 below.

Figure 5: Map of Enugu State Showing LGAs where Intervention Works will be Implemented

Topography: Enugu is located in the Cross-River basin and the Benue trough, and has the best developed coal in this area. Precambrian basement rock in this region is overlaid with sediments bearing coal from the Cretaceous and Tertiary age. Coal seams in the Enugu coal district measure between 1 and 2 metres (3.3 and 6.6 ft) in thickness and the reserves have been estimated to be more than 300 million tonnes. Enugu's hills at the extreme may reach an elevation of 1,000 metres (3,300 ft). Highlands surrounding Enugu for the most part are underlain by sandstone, while lowlands are underlain by shale. Much of the escarpment stretching from Enugu to Orlu has been ravaged by soil and gully erosion. Other features in Enugu include the Nike Lake.

Drainage and Hydrology: The State lies partly within the semi-tropical rain forest belt of the south, its physical features change gradually from tropical rain forest to open wood-land and then to Savannah. Apart from a chain of low hills, running through , in the east to Nsukka in the north-west, and southwards through Enugu and Agwu, the rest of the state is made up of lowland separated by numerous streams and rivulets, the major ones of which are the Adada River and the Oji River. The Ekulu, Asata, Ogbete, Aria, Idaw and Nyaba rivers are the six largest rivers located in the State Capital City. The Ekulu River is the largest body of water in Enugu urban and its reservoir contributes to part of the city's domestic water supply.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Climate/Meteorology: Enugu is located in a tropical rain forest zone with a derived savannah. Enugu's climate is humid and this humidity is at its highest between March and November. As in the rest of West Africa, the rainy season and dry season are the only weather periods that recur in Enugu. The average annual rainfall in Enugu is around 2,000mm, which arrives intermittently and becomes very heavy during the rainy season. Other weather conditions affecting Enugu include Harmattan, a dusty trade wind lasting a few weeks of December and January. Like the rest of Nigeria, Enugu is hot all year round.

Temperature: Enugu State has good climatic condition all the year round. In the entire State, the mean daily temperature is 26.7 °C (80.1 °F). Other weather conditions affecting the city include Harmattan, a dusty trade wind lasting a few weeks of December and January. Like the rest of Nigeria, Enugu is hot all year round. The hottest month is February with about 87.16 oF (30.64 oC), while the lowest temperature is recorded in November/December, reaching about 60.54 oF (15.86 oC).

Geology: Two formational units characterize the study area and they include the Ajali Formation and the Mamu Formation. The Ajali Formation whose age is Upper Maastrichtian is false-bedded and highly friable sandstone while the Mamu Formation (Lower Maastrichtian) which is also known as the Lower Coal measure is mainly made up of shale with intercalations if sand and siltstone. The Nsukka Formation, first described by as the upper coal measures, lies conformably on the Ajali sandstone. The lithology is very similar to that of Mamu Formation and the rocks consists of an alternating succession of sandstone, dark shale and sandy shale, with thin coal seams at various horizons. Eroded remnants of this formation constitute outliers and the thickness varies from over 200m around Aku to a mean of about 100m further South.

Soils: Enugu falls into the category of the interior zone of laterite soil. Laterite (a name which originated from the Latin word ‘Later’, meaning ‘Brick’) is a red tropical soil - a reddish mixture of clayey iron and aluminum oxides and hydroxides formed by the weathering of basalt under humid, tropical conditions. Laterite is a dense, porous, iron-bearing soil that can be quarried like stone and capable of withstanding intensive development. This is also the soil type found at the project site.

Vegetation: The vegetation in Enugu state lies in two main vegetation zones: The Woodland and Tall Grass Savannah and the Rain Forest. Most common, are dumps of 20feet tall trees- commonly isoberline, locust bean, Shea butter, almond tree and oil bean trees that lose their leaves in the dry season and elephant trees covered the plains between the trees.

5.2 Site-specific Biophysical and Social Description of the Project Areas

The content of this sub-section is presented in the subsequent matrix table of the biophysical and social conditions of the 29 roads proposed for rehabilitation and their surrounding communities. Some pictures of the project roads are provided subsequently. Additionally, Figures 6 - 17 present maps of all roads in each of the 6 Lots. Table 9 presents the Site-specific Biophysical and Social Description of the Project Areas.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 6: Map of Lot 1 Roads Showing Environmental Sensitivities

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 8: Map of Lot 2 Roads Showing Environmental Sensitivities

Figure 9: Map of Lot 2 Roads Showing Social Sensitivities

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 10: Map of Lot 3 Roads Showing Environmental Sensitivities

Figure 11: Map of Lot 3 Roads Showing Social Sensitivities

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 12: Map of Lot 4 Roads Showing Environmental Sensitivities

Figure 13: Map of Lot 4 Roads Showing Social Sensitivities Page | 32

ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 14: Map of Lot 5 Roads Showing Environmental Sensitivities

Figure 15: Map of Lot 5 Roads Showing Social Sensitivities Page | 33

ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Figure 16: Map of Lot 6 Roads Showing Environmental Sensitivities

Figure 17: Map of Lot 6 Roads Showing Social Sensitivities Page | 34

ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Table 9: Site-specific Biophysical and Social Description of the Project Areas S/N General Road and Project Environmental Social Risks Proposed Intervention Pictures Area Description Risks Lot 1 1. Nkpologu-Uvuru-Ukpata- Vulnerability to sheet Vulnerability to Lateritic Base Course Treatment; Adaba-Akunyi erosion noise disturbances Rehabilitation of Culverts Road is approximately for structures close Installation of Box Culverts 39.221 km in length. It is an to the road Construction of Concrete lined earth road linking five (5) drains major rural areas (Nkpoloku, Uvuru, Ukpata, Adaba and Akunyi Umlokpa). Major Community Secondary features which could be sited School located off the road along the shoulders of the road include the Nkpologu Town hall, the Ukpata Presbyterian Church and other churches, and the Akunyi Umulokpa Community Secondary School. The road and its T- Junctions consist of several culverts.

2. Odenigbo-Edem Ani Vulnerability to Though not a Lateritic Base Course Treatment Ugwuiyi Mpi-Ofulu Onu Flooding and Erosion regular occurrence, Installation of side drains and box Road with Spurs to consultation with culverts Imilike-Ugbogidi Road stakeholders Temporary relocation of electric and Catholic Parish Road revealed that poles is approximately 11.526km robbery and long. The road has a number extortion of road of stream crossings and gully users occur along Vegetation along the Road erosion. The road is this road due to the bordered by bamboo and deplorable condition palm tree vegetation. Some of the road, and the electric poles can be seen denseness of along; and on the road bamboo and palm (These will be temporarily trees along the road relocated): Small scale which serve as livelihood activities can be hideouts for the Electric Pole on the Road

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

seen in villages along the hoodlums. road specifically at Onu Road with Spurs to Imilike- Ugbogidi Road. Other social features include one Primary healthcare facility; Markets, schools and churches. Note: All Issues triggering OP 4.12 in this ESIA Report will be addressed in a stand- alone Resettlement Action Plan; RAP). 3. Nguru-Akpotoro-St Mary Vulnerability to Vulnerability to Road Levelling; Obimo is about 9.1km. The Flooding and Erosion noise disturbances Rehabilitation and Installation of road is defined by portions of for structures close culverts; rill erosion. At the T junction to the road Installation of Side Drains which leads to the town hall. The middle of the road is overgrown with short grasses. At the end of the T-Junction with short grass road the existing culvert is growing in the middle of the road silted and partly visible, thus navigating water run-off onto the road; which results in the formation of rills and small gullies.

Dilapidated and Silted box culvert

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

S/N General Road and Project Environmental Social Risks Proposed Intervention Pictures Area Description Risks Lot 2 4. Enyazuru-Ohomorba Road Vegetation Proximity to a shrine Lateritic Base Course Treatment; is approximately 2km long. encroachment and at Enyazuru Construction of side drains and The road is mainly an earth overgrowth installation of culverts. road with no drainage. There is a shrine along the road at Enyazuru, which can be seen while driving on the road.

Enyazuru Road on the Left with

Shrine located 2m from ROW

5. Umu-Ezejor-Agu-Udele- Vulnerability to sheet Vulnerability to Installation of side drains; Itabor Road with Spur at erosion and flooding noise disturbances Rehabilitation and Construction of Ubahor is about 2.93 km. A for structures close ring and box culverts; Left turn on the road at Unu- to the road Temporary relocation of electric Ezejor, leads to Agu Udele. poles The road allows for

movement and

transportation to rural

settlements along its route. Narrowing section of the road At some sections, there is a narrowing of the road with eroded portions. Important social features seen along the road included markets, schools, churches and primary healthcare facilities. Several Electric poles can be seen; some of which will be

temporary relocated. The Road bordered by vegetation road is also bordered by a diversity of vegetation

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

6. Ogbo Umuokere- Vulnerability to sheet Nkwo Umundu Lateritic Base Course Treatment; Mbanato-ImufuUmundu- erosion and flooding Market could be Earth works and expansion; ObeguIgugu-Nkporogwu- vulnerable to Installation of hydraulic structures Ngbede- temporary economic at required sections NkwoUmunduOhullor displacement Road is approximately

A double ring culvert silted 6.11km. It is a reasonably Vulnerability to good earth road with good power outage if surface in most sections. In transformer needs Transformer located at Nkwo

close proximity to the road is to be relocated Umundu Nkwo Umundu Market and the servicing transformer for Nkwo Umundu. During the rainy season, shallow streams of water could be seen crossing the road.

Nkwo Umundu Market 7. Obollo Ogbelle-Ezimo Vulnerability to Physical and Lateritic Base Course Treatment; Road with Spur to AMA- erosion economic Earth works; Ogbelle UNO Road is displacement Installation of ring and box approximately 6.2 km long. culverts At the start-point of the Installation of side drains road, few buildings and vulcanizing shops can be seen on the ROW. The road

is also damaged at various Road Start-Point sections by erosion washouts which make it difficult for vehicles to navigate. Important social features seen along the road included markets, schools, churches and primary healthcare facilities. Erosion washout showing need

for hydraulic structures

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

8. Express- Odobodo- Vulnerability to Physical Desilting of one ring culvert; Amalla-Okpu Orba Road is Erosion displacement Construction of box culverts approximately 2.4km long. This road links other small villages along the way. The road has lots of undulation, erosion wash outs and failed hydraulic structures.

Orba Road 9. Onuaffa Amalla Orba - Vulnerability to Physical Amaedem- Ofuluonu - Erosion and Flooding displacement Agudele Road is approximately 2.4km long. This road is a narrow road bordered closely by rural buildings, walls and fences at some sections along the ROW.

Walls/cement-block fences on

the ROW

10. Igogoro-Amachalla- Negligible Physical and Rehabilitation of Hydraulic Ikpoiga-Umuagbedo Agu economic Structures Road is approximately displacement 9.68km long. Important social features seen along the road included markets, schools, churches and Provision Shop Located on the

primary healthcare facilities, ROW some of which have encroached into the ROW. The hydraulic structures mainly require rehabilitation. The environmental risks are minimal or almost negligible

Other structures along the road

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

11. Amufie-Ugbaike-Inyi Vulnerability to Noise Nuisance Earthworks; Obollo Road is Flooding and Erosion Road Levelling; approximately 7.64km long. Installation of side drains and The road is bordered by culverts schools, churches, markets, private homes and a shrine. Erosion washout is visible at some sections of the roads including hydraulic Erosion Washout on the Road structures in need to desilting or rehabilitation and replacement.

12. Onichadugo-Olido-Amube Vulnerability to Negligible Road realignment, Road is approximately Flooding and Erosion Construction of hydraulic 6.6km in length. It is an structures such as Pipe or Box undulating road with several culverts, lined drains. Demolition erosion rills and patches of of some damaged structures may short grasses in most also be required sections. Along the road are schools, churches, a shrine and settlements

Road crossing stream

13. Aku-Udueme Road is Vulnerability to Sexual Exploitation Road realignment, 9.2km in length. It is a Erosion and Abuse (SEA); Lateritic Base Course Treatment; slightly rough road with Gender-Based Construction of hydraulic patches of erosion washout. Violence11 structures such as Pipe or Box It is bordered by trees and culverts, lined drains. short grasses. Major features seen along the road include Amaebokwu Primary School,

Aku- Udueme Road Central School, Udueme community boreholes,

11 Considering the fact that some primary and secondary schools are located along the selected rural roads, and that these schools have a large population of minors, the proposed intervention works are likely to increase the risks of SEA and GBV especially if there are interactions between workers and pupils/students. Additionally, at certain public utilities such as community boreholes and hand pumps, the tendency for regular and increased interactions between workers and locales is an expected occurrence which may increase GBV risks such as SEA, rape, sexual harassments, etc.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Methodist Church, Community School Aku, Transformers, surface channels and crossing streams. Traffic on the road is very low, consisting mostly of motorcycles, bicycles, pickup trucks and Class A vehicles (small and medium sized sedans). 14. Umudinwogo-Amabokwu- Vulnerability to Negligible Earthworks; Useh (with Spur to Uwani Flooding and Erosion Road Levelling; Amabokwu Road - Road starts is mainly characterized by areas of erosion and prone to flooding

Erosion at Umudinwogo-Amabokwu- Useh road

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

15. Uwani Otobo-Ugwunani- Water logging Nil Road realignment, Oshigo-Oda Aku (with Construction of hydraulic spur obie- Ugwunani- structures such as Pipe or Box Abokwe-Umudiukwu culverts, lined drains. Road is mainly characterized by water logging. There are no critical social sensitivities on its corridors.

Uwani Otobo-Ugwunani-Oshigo-Oda Aku road

16. Achara Ohodo through Water Logging SEA and GBV Surface Treatment; Achara Primary School to Relocation of 2 Electric Poles; Old Primary school Ohodo Installation of hydraulic structures to Union Primary school Ohodo to Lejja – is approximately 9.7km, and a major link between Achara Primary School and Union Primary School Ohodo. It has some pockets of water Trail of water logging on the

logging and is bordered by road vegetation. Other notable features along the road include Umuifo Health Centre & Maternity; Elue Security Post Ohodo; Electric Pole and Settlements.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

17. Ohodo Express Road Vulnerability to SEA and GBV Surface Treatment; Junction Through St Flooding and Erosion Road Realignment; Thomas Catholic Church Installation of Side Drains Ohodo, Through Central Primary School Ohodo To Central School Ozalla, Through Ijo-Ozalla to Ama-Ezike Ohemje Aku is 10.94km. There is evidence

Erosion Washout of erosion at Nnaru Ozalla and Ohemuje Aku. Significant features along the road include St. Thomas Catholic Church, Ozalla Community Primary School, Central School Ohodo, Central School Ozalla, St. Lukes Catholic Parish Ozalla and a transformer.

18. Ohebedim - Ozalla - Lejja Vulnerability to Negligible Surface Treatment; Road is approximately Flooding and Erosion Road Realignment; 10km - The road is Installation of Side Drains bordered by schools, churches, markets and buildings. Erosion washout is visible at some sections of Erosion Washout the roads

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

19. Uhuogiri-Railway Road Water run-off Children were seen Desilting of the side drains; starts at the river side about resulting in rill hawking along the Surface Treatment with Lateritic 3.1km and has a hilly formation as a result road; in addition, Base Course. topography. It consists of of silted drains intervention works silted side drains and may further expose clusters of petty trading children to hawking. shops on its boarders. These however, are not encroaching the ROW.

20. Ogbaku-Ogugu-Owelle- Nil Nil Road Leveling; v Road (From Ogbaku Lateritic Base Course Treatment; Town) Road is about Maintenance and desilting of 8.58km in length. It is an culverts. irregular road, that is wide and narrow at some sections consisting of several culverts. Electric poles can be seen bordering the road and at some 1.5km from the starting point, is the located Irregular road surface due to

water run-off

the St. Mary’s Catholic Section of the Road Church, Ogbaku.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

21. Obeagu - Ugwuaji with Vulnerability to Obstruction in Construction of hydraulic Spur to Uzamdunu Road Flooding movement on the structures; is about 7.68km. It is a wet road during civil Lateritic Base Course Surface and damp road works. Treatment characterized mainly with flooding as a result of a nearby River occasionally overflowing its banks. Flooding on the Road at Obeagu

Flooding on the Road at

Uzamdunu 22. Umuaji Aguobu Owa- Vulnerability to Power outages Construction of hydraulic Umuaji Mgbagbuowa Flooding during relocation of structures; Agba Umuna -Ebenebe electric poles Lateritic Base Course Surface Road (with Spur to Treatment Augobu Ozom through T- Obstruction in Junction, Umuaji) is about movement on the 12.56km in length. road during civil Important social features works. seen along the road included markets, schools, churches, 4 shrines and primary healthcare facilities. Several

Electric poles can be seen; Flooding some of which will be temporary relocated. The road is flooded.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

23. Abonuzu Owa - Ajali Vulnerability to Noise Nuisance and Surface Treatment; Water Works is 4.64km in Erosion Expected Grievances Road Realignment length. There is a gully on Civil Works the road which is a few kilometers towards Ajali Water Works. The Salvation Pentecostal church can be seen along the road

Pentecostal Church

24. MTN Exp Junction- Vulnerability to Nil Construction of hydraulic Umueze-Aguawu Farm Erosion structures; Settlement Road-Spur to Lateritic Base Course Surface Okposi is approximately Treatment 5.6km long. The road is characterized by several erosion rills and gullies. Important social features seen along the road include

markets, schools, churches, Erosion Rills 4 shrines and primary healthcare facilities. Several Electric poles can be seen; some of which will be temporary relocated 25. Eha Uno-Eha Ndiagu is Vulnerability to SEA and GBV Construction of Hydraulic approximately 16.94km Flooding and Erosion Structures; long. Small streams can be Road Levelling and Surface seen crossing the road at Treatment several sections including several gullies. Some settlements are also visible along the roads including churches, healthcare centres, markets and

Eroded road surface schools.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

26. Owere-Umuabor-Edem Nil Nil Lateritic Base Course Treatment Umabor-Aguudene-Mbu is and rehabilitation of hydraulic approximately 23.6km long. structures The road has a hard surface and does not have any significant environmental or social issues. Along the road is the Daughters of Divine Love Hospital at Eha- Alumona Umuabor; Agu-Umuabor Community Secondary School at Agu Udeme-Umuabor, the Daughters of Divine Love village square and Hospital Agu Udeme-Umuabor primary school.

Eroded road surface 27. Obiagu Ohom Orba Road- Nil Nil Amube Ohom Orba Road is less than a km long. This road connects Obiagu Ohom and Amube Ohom. Settlements can be seen along the road. The road does not have significant environmental and social Section of the Road issues.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

28. Ohebe-Agu Orba-Agu Vulnerability to Accidents, Injury Road filling; Imilike Farm Road + Flooding and Erosion and Death Construction of Hydraulic Imilike Etiti-Ezimo Road Features; is approximately 19.76km. Surface Treatment The road is characterized by several gullies. At a section of the road, erosion has eaten up some part of the road which has created a gully. Important social features seen along the road Major Gully on the Road include, schools, and churches,

Eroded Road Surface

29. Neke - Umualor - Vegetation Road realignment and levelling at Ehamufu Railway Line overgrowth or some sections; Road is 15.4km Important encroachment social features seen along Surface Treatment the road include, schools, and churches.

Road Surface

Roads Bordered by Dense Vegetation Lot 1: Odenigbo-Edem Ani Ugwuiyi Mpi-Ofulu Onu Road with Spurs to Imilike-Ugbogidi Road and Catholic Parish Road Lot 2: Umu-Ezejor-Agu-Udele-Itabor Road with Spur at Ubahor Ogbo Umuokere-Mbanato-ImufuUmundu-Obegulgugu-Nkporogwu-Ngbede-Nkwo Umundu Ohullor Road Lot 6: Ohebe-Agu Orba-Agu Imilike Farm Road + Imilike Etiti-Ezimo Road Page | 48

ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

5.3 Areas within Erosion and Flooding Issues

The Enugu RAMP2 SPIU in its engineering design report has proposed and designed grouted riprap for the flood protection to control erosion and future damage to hydraulic structures and embankment (Resilience Strategy), Concrete lined drains have been considered suitable for channeling water in built up areas or in very steep (high gradient area) to mitigate and control erosion around the culverts and at high embankment areas (Resistance Strategy) See Annex 5. Mitigation measures for the stated flood management activities are provided for and costed in the ESMP matrix table – Construction Phase. No bridge has been designed for phase 2 roads.

5.4 Assessment of Environmental Media in the Project Areas

5.4.1 AIR QUALITY

Air quality assessment was conducted using HAZZ Digital Dust Monitor. All values of major air quality parameters were within FMEnv limits. This could be attributed to the predominantly rural environment where there is low traffic, fewer populace thus, low carbon monoxide emissions and CO2 concentrations. (See Annex 11 for Data on Air Quality).

Air Quality

3

2

1

0 LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

NO2 (ppm) H2S (ppm) CO2 SO2 (%) CO(ppm)

5.4.2 NOISE LEVEL

For monitoring ambient noise levels, an environment multi-meter Instruments Noise Meter (Model 407735) was employed. The average noise levels in the project areas ranges from 33.5 dB to 47.0 dB within the proposed project sites. These recorded values fall below FMEnv’s FEPA permissible noise level of 90dB for an 8hour-working period (FMEnv’s FEPA, 1991), indicating the absence of significant noise sources with the vicinity of the proposed project sites. Data on noise levels is contained in annex 14. Noise level

60

40

20

0 Noise (dB) LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

5.4.3 SOIL ANALYSIS

Soil samples were collected at depths of 0-30cm (top-soil), and 30-60cm (sub-soil). The soils on the road surfaces are sandy, silty as well as clayey.

Particle size Grading

100 80 60

40 20

0 LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6 Sand Silt Clay

Physico-chemical properties of Soil Samples

The physico-chemical properties of soils from the sample locations revealed that the pH of the top soil ranged from 6.15 - 7.91 while the sub surface soil ranged from 6.29 – 6.50. The moderately low value of the soil pH indicates that the soil is slightly acidic. This maybe as a result of use of agro-chemicals like fertilizers and pesticides for agricultural practices within project area, as observed during field visit.

The Total Organic Matter (TOM) of soil samples collected across the project area ranged between 0.220% - 5.173%. The TOM content in the soil was high and will account for adequate nitrogen (main growth nutrient) that is required for rapid growth of plant leaves and stems. This can be substantiated with the lush growth of maize, cassava and other food crops in the area.

7

6

5 4

3 2

1 0 LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

pH Total Organic Matter (%)

Electrical conductivity (EC) is a measure of the amount of soluble salts present in the soil. The conductivity of soils in the area under study was between 1.0µg– 8µg/cm at the time of study. FMEnv limits of 1000 ug/cm. (Laboratory analysis for soil is provided in Annex 13).

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State Nitrate, Sulphate and Chloride Chloride and Sulphate levels were within the FMEnv limits. The nitrate levels in the soil samples were in trace quantities and their values are all within the FMEnv acceptable limits. (See Annex 13 for laboratory results on soil quality).

8

6

4

2

0 LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

Electrical Conductivity, µg/cm Sulphates (SO42-), mg/kg

Chlorides (CL-), Mg/Kg Nitrates mg/kg

Heavy Metals Lead, Calcium, Iron, Zinc, Chromium and Nickel were all within the FMEnv prescribed limits. These results are shown in table annex 13.

100 80

60

40

20

0 LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

Calcium (Ca2+), Mg/Kg Iron (Fe2+), mg/kg Zinc (Zn3+), mg/kg

Lead (Pb2+), mg/kg Chromium (Cr2+), Mg/kg Nickel (Ni), Mg/Kg

5.4.4 WATER QUALITY Physico-chemical Parameters of Water

Surface and groundwater samples were taken for each road. The pH Levels of surface and groundwater were all within the FMEnv limits of 6-9 though slightly acidic. Acidity of surface water has been shown to cause damage to roads, it is advised that in addition to laterite, limestone could be mixed with concrete for roads to be rehabilitated in areas where there is slight acidity of surface waters. Limestone has been known to make roads more resistant to the effects of acidic surface waters and acid rains.

The Electrical conductivity value of the water in the project area under study was between 0.48µS–0.79µS/cm. Dissolved oxygen level in the project areas ranged from 4.11–7.8mg/l that is between the acceptable ranges of the FMEnv of 2-8mg/l.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

8 7 6 5 4 3 2 1 0 GW SW GW SW GW SW GW SW GW SW GW SW LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

pH EC(ds/m) Dissolved Oxygen (mg/l) BOD (mg/l)

Chlorides, Phosphates, Nitrate & Sulphates In surface water and groundwater samples, chloride and phosphate levels were within the FMEnv limits (250mg/l) and (5mg/l) respectively. The nitrate and sulphate levels in the water samples were in trace quantities and their values are all within the FMEnv acceptable limits. (See Annex 12 for laboratory results on water quality).

2

1.5

1

0.5

0 GW SW GW SW GW SW GW SW GW SW GW SW LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

Chloride (mg/l) Phosphate (mg/l) Sulfate (mg/l) Nitrate (mg/l)

Heavy Metals Iron, Zinc, Manganese and Copper were all within the FMEnv prescribed limits. These results are shown in table annex 12.

3

2.5

2 1.5 1

0.5 0

GW SW GW SW GW SW GW SW GW SW GW SW LOT 1 LOT 2 LOT3 LOT 4 LOT 5 LOT 6

Iron (mg/l) Zinc (mg/l) Manganese (mg/l) Copper (mg/l) Page | 52

ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

5.5 Socioeconomic Characteristics of the project area

A total of 235 questionnaires were distributed within the project area. Results were analyzed using SPSS.

Age distribution in project area

The Age distribution of the respondents shows that 51.0% falls within the age Age distribution range of 45–65 years, 18–45 years with 8 in project area 60yrs - above 41.0% and 65 and above 8.0%. This shows that the majority of the 41 Age distribution respondents are active population and in project area ample labour force for the contractors. 45-60yrs This is as illustrated in Figure 18. 51 Age distribution

in project area 18-45yrs

Figure 18: Chart representing age distribution in project area

Gender distribution in project area

The gender distribution of the respondents of the project study area Gender distribution in Project shows an almost even gender Area distribution, with the men slightly higher at 51.9 percent (122 persons) of persons 49.1 interviewed in comparison with the 49.1 51.9 percent of females (113 persons) Sex MALE interviewed. This is illustrated in Figure 19. Thus, indicating that men and women Sex FEMALE within the project areas would provide an almost equal labour force.

Figure 19: Chart representing gender distribution in project area

Length of Stay in project area

As shown in Figure 20, majority of persons interviewed in the communities Length of Stay Below 5 years in Community have lived there from birth with around From Birth 180 respondents (77.6 percent), while 55 5-9 years Length of Stay respondents (23.4 percent) indicate that in Community Above 15 years they have been living in the community 10-14 years Length of Stay for over fifteen years, which is likely due in Community 10-14 years to the rural nature of the community, Above 15 years Length of Stay

where the more active indigenes grow Communityin ofStay Length in Community and move out of the community in From Birth 5-9 years search of a more urban lifestyle. Length of Stay in Community Nevertheless, this indicates that the 0 50 100 Below 5 years persons in these communities would have more intimate knowledge of the project terrain. Figure 20: Chart representing Length of Stay in Project Area

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Educational Level in project area

The educational level of respondents shows that 122 persons, over half (52 percent) are educated up to WASC/SSCE Educational 12% 21% level, while the remainder half of the Level population are distributed between the 50 Uneducated persons uneducated (12 percent), 28 Educational 52% persons with higher certificates (11.9 15% Level FSLC percent) and 35 persons (12 percent) with first school leaving certificates. Indicating Educational that majority can read and write if Level WASC/SSCE employed by the contractors on the project. This is shown in Figure 21. Figure 21: Chart representing educational level in Project Area

Occupational distribution in project area

36.6 About 36.6% of the respondents are 40 Occupation Civil farmers while 23.4% are trader and 35 Servants 30 23.4 20.8 artisans. 20.8% indicated that they were 25 Occupation students waiting for the release of their 20 12.8 Fishermen 15 6.4 WASCE results and the other 6.4% are civil 10 Occupation Farmers 5 servants with some working in the 0 neighboring LGA secretariats. This is shown Occupation Self employed in Figure 22.

Traders Occupation Traders

Farmers Students

Fishermen Civil Servants Civil

Self employed Self Occupation Students Occupation

Figure 22: Chart showing occupation distribution in project area

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

5.5.1 Land Use

One of the major land use features that were observed in the project area is the intensification of the urban spatial structure as it deepens urbanization from the outwards spread of the metropolis into the hinterlands. The rural-urban interdependence and interaction is characterized by the flow of people (migration), natural resources, agricultural commodities and services, information and money, or in the form of income diversification such as urban agriculture and non-farm rural employment between rural and urban areas (Tacoli, 2002). Nevertheless, in the rural areas of the project area, land use is basically agricultural and residential with a small commercial and cultural mix; which would consequently imply that land acquisition concerns would have more impact on economic crops & residential properties.

5.5.2 Health Assessment

Primary health care is provided in the communities of the project area by the primary health centers. The most prevalent illness treated is malaria-forming majority of reported cases. Family planning activities are poor, while disease surveillance in the health centers were very poor as only cases of dysentery and diarrheal disease were being surveyed. In addition, the capacity of these primary health care facilities is weak and would require strengthening to handle Occupational Health & Safety issues that may arise in the worksite.

5.5.3 Social Structure/Trends and Social Groups This unique combination of communalism and high individual motivation in , for instance, creates a system of decentralized power that is found in multiple centres in society such as the Umunna (male kindred), Umuada (female kindred), Inyom di (wives of the kindred), Ohanaeze (general assembly of the kin group), and Otu ogbo (age grades), among many others. This decentralized yet very cohesive system of social power is a characteristic of the people of the South East of Nigeria in the post-colonial era, and it is very important in charting a historiography of civil society organizations in the zone.

5.5.4 Agriculture Most of the families in communities bordering the project roads are engaged in agricultural practices predominantly subsistence. Extensive cultivation of the conventional staples of yam, cassava, maize, sweet potato, grain legumes, pawpaw, banana, plantain and vegetables. Income from the farm is supplemented by earnings from the sale of products from local economic tree crops. Most of these tree crops are located on the compound land farmland plots.

Given the proximity of farm activities to the road, it is very likely that these crops may be affected as a result of component 1 and 2 activities. The main crops cultivated in the project areas are presented in Table 10 below.

Table 10: Main Crops Cultivated in the Project Areas

Crops Frequency Percent Valid Percent Cumulative Percent

Yam, cassava, maize, sweet potato 104 44.3 44.3 44.3

Grain legumes, pawpaw, banana, plantain 58 24.7 24.7 69 and vegetables Tree crops (oil palm, cashew, kola nut, coconut, mangoes, breadfruit (ukwa), 73 31 31 100.0 castor beans, oil beans)

Total 235 100.0 100.0

5.5.5 Infrastructure

Many of the respondents in the communities about 78.6% in the project area rely on water from the river or streams for their basic needs. However, some communities such as Abonuzu Owa – Ajali water works & MTN Express junction – Umueze – Aguawu farm settlement road – Spur to Okposi Road enjoy more consistent water supply due to the water facilities domiciled in their communities.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Approximately 84% of the respondents do not have electricity available to them whereas, 16% of the respondents have occasional electricity available in their community. Alternative sources of electricity generation in the communities include use of small generator set (especially for barbers and kiosk owners).

5.5.6 Social Amenities Likely to be affected during civil works

The Table 11 below presents the summary of numbers of social amenities likely to be directly or indirectly impacted during the civil works.

Table 11: Summary of Social Amenities likely to be impacted Description Frequency Percent Valid Percent Cumulative Percent Churches 30 28.0 28.0 28.0

Schools 39 36.4 36.4 64.4

Electric Poles 3 2.8 2.8 67.2

Electric Transformers 7 6.5 6.5 73.7 B Markets 11 10.4 10.4 84.1

Public Boreholes 5 4.7 4.7 88.8

Shrines 6 5.6 5.6 94.4

Health Care Centers 6 5.6 5.6 100

Total 107 100 100

5.5.7 Transportation

Road transportation is the most common means of movement in the area surveyed. The response on the nature of roads leading to villages within the survey area indicated that majority of the roads were rated as bad with 55.3%, where some of these bad roads have serious erosion problems. Table 12 below provides information on the means of transportation in the project areas.

Table 12: Means of Transportation Description Frequency Percent Valid Percent Cumulative Percent Motorcycles, bicycles, buses 81 34.5 34.5 34.5

Motorcycles, bicycles 16 6.8 6.8 41.3

Buses, keke napep 31 13.2 13.2 54.5

Motorcycles, keke napep 24 10.2 10.2 64.7

BPickup trucks, motorcycles, bicycles 18 7.7 7.7 72.4 Pickup trucks, motorcycles, bicycles, 30 12.8 12.8 85.2 keke napep Pickup trucks, motorcycles, bicycle 20 8.5 8.5 93.7

Pickup trucks, motorcycles 15 6.3 6.3 100.0

Total 235 100.0 100.0

5.5.8 Security Challenges

The response from the communities on the type of security challenges experienced by communities due to the nature of the road indicates that robbery is one of the security challenges experienced (25.5% reported), while snatching of motorcycles (17.9%) and herdsmen attacks (7.7%) on farmers

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

have also been reported as shown in Table 13. Table 9 provides, specifically, the roads that were identified to be prone to this challenges. They include: Odenigbo-Edem Ani Ugwuiyi Mpi-Ofulu Onu Road with Spurs to Imilike-Ugbogidi Road and Catholic Parish Road.

Table 13: Security challenges observed Description Frequency Percent Valid Percent Cumulative Percent Herdsmen attack 18 7.7 7.7 7.7 None 108 46 46 53.7 Robbery 60 25.5 25.5 79.2

Snatching of motorcycles, robbery 42 17.9 17.9 97.1 Others (Kidnapping etc.) 7 2.9 2.9 100.0 Total 235 100.0 100.0

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

CHAPTER SIX: DESCRIPTION OF ENVIRONMENTAL AND SOCIAL IMPACTS

6.1 Background

Field inspections and observations, studies and concerns arising from stakeholder consultations and project description and designs formed the basis for the identification of potential environmental and social risks and impacts likely to be associated with the proposed Enugu RAMP2 roads intervention sub-project.

The activities associated with the proposed works especially the civil engineering aspects can result in varying degrees of impacts on the biophysical and social environment. The potential impacts of the proposed project are identified and assessed to determine their significance. Subsequently, mitigation measures are proffered to avoid, reduce or compensate for all potentially significant impacts. Impacts triggering OP 4.12 will be addressed in a stand-alone RAP.

The proposed mitigation measures were derived from comprehensive reviews of the proposed project activities, existing relevant mitigation guidance prescribed in the FMEnv EIA Guidelines for infrastructure, the outcome of the engagement process with affected communities, World Bank EHS Guidelines and Good International Industry Practice (GIIP). The measures to expand or enhance the benefits of the project especially as it relates to the socioeconomic well-being of the members of local communities and the project region are also described.

6.2 Associated and Potential Environmental and Social Impacts

For the identification and rating of key risks and impacts that are likely to occur during the phases of this project and the significance of the associated impacts, a “5-Step-Tool” was used. These impacts are as a result of the interaction of the proposed works (as shown in Table 4) and the environmental and social sensitivities in the project locations.

6.2.1 Physical Environmental & Social Media Influence

The physical environmental media to be potentially influenced by the activities of the proposed project are; land (landscape), air quality, groundwater and any adjacent drain to any of the project sites. The landscape features include soil, flora and fauna at the proposed project site, which will be impacted by the project activities. Any adjacent drain to any of the project sites will be the recipient of runoff water from the project site. Any percolation of fuels through the soil may impact on groundwater resources. The air quality may also be impacted by dust and gaseous emissions from construction activities.

Also, to be considered, are the activities, which could result in negative social impacts, such as acquisition of land, physical or economic displacement and mobilization of workforce with accompanying challenges such as labour influx, GBV etc.

However, all contractors will be required to prepare their Contractors-ESMP (C-ESMP) based on the ESMP provided in Table 16 in this ESIA. The C-ESMP will contain detailed mitigation measures for identified negative impacts and will be reviewed and approved by the Supervision Consultant/PIU.

6.3 Identified Potential Positive and Adverse Impacts and their ratings (by Project Phases)

Identified potential beneficial and adverse environmental and social impacts respectively, are discussed in the subsequent sub-sections and their ratings, by project phase provided.

6.3.1 Summary of Potential Beneficial Impacts

Environmental Impacts • Control of floods and Erosion Reclamation of Right of Way (ROW) on roads where villages, markets and farmlands have encroached (A standalone RAP will be prepared to address any issue triggering OP 4.12) • Improved rural road infrastructure and sustainable hydraulic structures • Long term and sustained engineered control of flooding of roads through application of resistance and resilience flood plain management strategies (Annex 5)

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

• Development of a Waste Management Plan to address associated construction wastes within the project corridor • Development of an Occupational Health and Safety Management Plan to protect workers and communities from occupational risks of the project • Development of a Borrow Pit Management Plan, for reclamation of borrow pits (See Annex 16)

Social Impacts • Employment Generation • The Project will see to a timely and early sensitization and awareness of direct and indirect stakeholder groups through a Stakeholders’ engagement which will ensure for the provision of suggestions, raising of concerns and integration of these into decision making as regards the implementation of civil works on the selected rural roads. • Capacity building for stakeholders and project personnel on effective community participatory mechanisms, Grievance redress, ESMP implementation and Monitoring, Occupational Health and Safety risks assessments etc. • Promotion of community inclusion • Creation of investment opportunities • Provision of a lead way to drive the Enugu State Government towards ensuring improved Integrated Water Resources Management (rivers, streams and flood plains in the project areas) • Increased accessibility for local companies to access project communities so as to fulfil their Corporate and Social Responsibilities • Enhanced and easy transportation of goods and other commodities • Improved access to social amenities- markets, schools, churches, recreational areas and health care centers • Improved rural road security • Strengthening of roads rehabilitation works and supervision systems including improvement in institutional responsibilities for roads construction and maintenance • Improvement of Local and State trade/business opportunities • Improvement of public goodwill and satisfaction towards governance in Enugu State. • Transfer of skills • Development of a Traffic Management Plan (TMP) to address issues arising from traffic build- up during implementation of intervention works (See Annex 6 for sample of TMP) • Development of an Occupational Health and Safety Management Plan to protect workers and communities from occupational risks of the project (See Annex 8) • Labour Influx Management Plan (See Annex 15) and mandatory Contractor commitment to prevention of Violence Against Children (VAC), SEA and GBV.

Table 14: Evaluation of potential positive impacts Project Phase Potential Positive Impacts

Preconstruction Phase

Social Impacts • Stakeholders’ Engagement: The public consultation process is perceived to be a positive impact, as it will form a basis for project concept decision-making and implementation. • Reclamation of Right of Way (ROW): This phase will also allow for reclaiming the Right-of-Way (ROW) on roads where villages, markets, farmlands and public utilities have encroached. The RAP will address issues of compensation and resettlement • Capacity Building: The critical stakeholders will benefit from trainings on: - Environmental and Social Management Plan (ESMP) implementation and monitoring. - Local labourers will benefit from trainings in occupational health and safety. - Public awareness and social mobilization programs on the project will be conducted in order to keep the public abreast of the development. - There will be transfer of skills from skilled contractors/workers to local helpers • Promote Community Participation: This phase of the project will promote community participation, by establishing project

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Project Phase Potential Positive Impacts

supervision committees at the Local Government and community levels to enable participation, monitoring and evaluation when rehabilitation works commence.

Occupational Health & • Safety Awareness: Design and conduct of Occupational Health Safety (OHS) and Safety (OHS) awareness programs Construction Phase Environmental • Erosion/Flood Control: Reduction in the risk of erosion and Impacts flooding as a result of proper drainage and culvert construction • Waste Management: Development of a waste management plan for project activities. Specifically, construction wastes Social Impacts • Employment: Employment of local skilled and unskilled labour will be promoted • Livelihoods: Encouragement of economic opportunities for petty traders and food-spot owners • Social Cooperation: The construction phase will encourage cooperation of different tribal groups from amongst contractor staff, Enugu RAMP2, and others in an event where the Contractor engages local and non-local workforce. • Provision of market for supply of construction materials: The project will require supply of large quantities of construction materials, most of which will be sourced locally around project communities and in the cities of Enugu State • Capacity Building: - Local labourers will benefit from trainings in occupational health and safety. - Locals will benefit immensely from awareness, sensitization and trainings on Gender Based Violence, Sexual Exploitation and Abuse, STIs and STDs respectively. • Promote Community inclusion: By the establishment of project supervision committees at the Local Government and community levels, these will enable participation, monitoring and evaluation during construction. • Occupational Health & Safety: Occupational health and safety efforts will be intensified during the construction phase as traffic signs, warning and hazard signs will be put up to inform communities about hazards Occupational Health & • Safety Awareness: Occupational Health and Safety (OHS) Safety (OHS) awareness programs will be conducted. Awareness programs and interactive sessions will benefit primarily the contractors’ personnel, and community residents. Operation Phase Social Impacts • Access: There will be easy inter and intra state access Easy access to schools, marketplaces, healthcare centres, sources of livelihood, farmlands etc. • Road Utilization: There will be increased utilization of rural roads as a result of rehabilitation works. Transport of commodities will be more frequent, and accessibility to communities guaranteed. • Ease of movement of goods, services and people: Easy movement of farm produce to and fro market places • Promote Community participation: Increased opportunities for community leaders to collaborate in supervisory and feedback activities with regards ongoing rehabilitation works Decommissioning Phase Social Impacts • Employment: Employment of local labour for the removal of construction equipment and materials, as well as disposal of construction waste will be promoted.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Table 15: Identified Potential Negative Impacts and their Ratings (by Project Phases) Project Phase Potential Impacts Rating

Preconstruction Phase Environmental • Air: Increase in fugitive dusts and frequent exhaust Moderate Impacts emissions into the atmosphere as equipment are transported to where the proposed road rehabilitation and hydraulic installations works will be done. • Soil: Moderate - Leakages from stacked equipment containing oil such as engine oil - Vegetation clearing could exacerbate the risk of soil erosion and compaction

• Noise: Mobilization of equipment could lead to Noise Moderate level increases, above WHO/FME permissible levels (90dB/70dB respectively)

• Surface water: Vegetation clearing could intensify Moderate sediment runoff into waterways

Social Impacts • Traffic: It is envisaged that there will be slight Moderate increase in traffic, as a result of movement of equipment and materials • Noise: Noise from heavy-duty project vehicles and Moderate equipment may exceed the WHO/FME acceptable noise level limits, resulting in nuisance. Grievances Moderate • Grievances from Project Affected Persons (PAPs) will be a likely occurrence. • Contractors’ negligence in utilizing workforce from host communities • Grievance as a result of contractors and external workers loitering around community shrine which is located at one of the intervention sites at Enyazuru Ohom Orba road, Lot 2 is likely. Physical Cultural Resources Major • Trespassing in sacred land and shrines e.g Enyazuru Ohom Orba road, Lot 2 Sanitation and Hygiene: Moderate • Indiscriminate defecation and increase special local sanitation • Public Utilities/Displacement: Displacement of Major some public utilities like electric poles at Odenigbo- Edem Ani Ugwuiyi Mpi-Ofulu Onu road in Lot 1 and hand pump water facility, located at Umu-Ezejor-Agu- Udele-Itabor Road in Lot 2 (This will be addressed in the stand-alone RAP) • Accidents: Accidents involving vehicles or pedestrians Major are likely to occur during vehicle and equipment movement to work areas, as community streets are small with moderate pedestrian usage.

• Air: Exposure to occupational health risk (respiratory Moderate Occupational Health & infections and diseases), especially for personnel Safety conveying equipment to the project site (OHS)/Community • Risk of flooding and possible drowning of workers in Health and Safety areas with rivers • Risk of biological hazards such as snakes and scorpions during land clearing activities Construction Phase

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Project Phase Potential Impacts Rating

Environmental • Air: Increase in fugitive dusts during movement of Moderate Impacts vehicles

• Soil: Improper channeling of water used during road Moderate rehabilitation may increase current road erosion which is already a major issue facing most roads • Waste generation: The construction phase will lead Moderate to increase in on and off-site quantities of generated construction wastes • Pollution: Possible pollution to surface water via Moderate oil/lubricant spills, Heavy plants Batteries acid and gases • Respiratory Diseases: Respiratory diseases are likely Moderate to occur, due to air contamination by exhaust fumes and dust resulting from civil works • Vulnerability to Natural Hazards (road Minor breakages): Where project roads pass through steep terrain with deep steep scarps on either or one side of the road, vibration of construction equipment can trigger road breakages/slips in already collapsed roads. • Noise: Noise level may exceed the WHO/FME Moderate permissible noise level (90dB/70dB respectively) due to blasting, quarry, mixing etc. during construction phase of heavy machinery to work areas during preconstruction phase • Water Quality Moderate - Accidental spillage of chemicals and fuels from the operation and maintenance of construction vehicles and equipment will pose negative impacts to surface and future groundwater quality. - Project activities may affect water and sanitation conditions, increase chances of stagnated water, which may lead to Water Borne diseases. - Possible accidental spillages and discharge of cements and other construction materials into surface water during bridge and culvert construction, which will lead to surface water contamination. • Increase in Carbon Emissions: Increase in carbon Minor monoxide emissions from engine systems during rehabilitation works • Borrow-pit formation: Road rehabilitation works may Major lead to formation of borrow pits which in-turn may encourage other environmentally unsafe conditions

Social Impacts Temporary relocation of electric poles: This is Major likely to occur during construction of drains; specifically, along the Odenigbo-Edem Ani Ugwuiyi Mpi- Ofulu Onu road. This may lead to damages or cause power outages or trigger negative responses from MDAs and electricity companies with the mandate to manage and monitor this infrastructure • Traffic & Nuisance: Slight increase in traffic Moderate • Grievances: Possible causes of Grievances include: Moderate - Adverse impacts on host community dynamics - Gender-based violence, including sexual harassment, child abuse and exploitation - Increased risk of communicable diseases (including STDs and HIV/AIDS) - No adherence to community cultures and traditions by externals and contractors

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Project Phase Potential Impacts Rating

- Grievance due to temporary loss of livelihood for downstream fishermen, as result of temporary blockage of water during bridge construction • HIV-AIDS Infections: Risk of STIs and STDs Minor transmission during project implementation

• Gender Mainstreaming: Job opportunity presented Minor by the project may generate gender inequality and equity issues if hiring is not gender sensitive • Physical and Economic Displacement: Moderate Implementation of civil works may result to land acquisition and impact on livelihoods. Some shops, electric poles, markets and farms may be destroyed or require being relocated. Thus, the need to compensate affected persons may arise (which is be addressed in the RAP) • Labour Influx: Labour influx may lead to: Moderate - Potential pressure on community resources, likely situation of increase of transactional sex, HIV/AIDs and family disintegration - Risk of social conflict between the local community and construction workers resulting from religious, cultural or ethnic differences, or based on competition for local resources. - Risk of illicit behaviour and practices such as theft, physical assaults, substance abuse, prostitution and human trafficking. - Increase in migrant workers/followers who in addition to the labour force, may migrate to the project site, especially if the community lacks the capacity to provide necessary goods and services. • Gender-Based Violence (GBV) and Sexual Moderate Exploitation and Abuse (SEA): Women and girls may be exposed to sexual harassment and violence as a result of interaction with construction workers • Violence Against Children (VAC): Children may be Moderate exposed to various forms of violence from construction workers and overbearing parents who may send them hawking at the project site • Risk of Robbery and Extortion Activities along Minor some selected roads: Construction Workers may be susceptible to robbery and extortion from local hoodlums along Odenigbo-Edem Ani Ugwuiyi Mpi-Ofulu Onu Road with Spurs to Imilike-Ugbogidi Road and Catholic Parish Road Occupational Health & General: In the course of the construction and general Moderate Safety (OHS) civil works, there would be a moderate to severe likelihood of the occurrence of workplace hazards. Activities such as trench Hazardous conditions or practices likely to impact on occupational health and safety will include: - Operating of heavy machines and equipment - Horseplay during work hours - Using vibrational, cutting and electrical equipment - Work requiring use of hazardous materials Others - Occupational accidents and injuries to workers - Respiratory diseases to workers due to inhalation of dust and fumes - Burns from fire, explosion or leakages of hazardous materials like battery acids, explosives, etc.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Project Phase Potential Impacts Rating

- Hearing impairment from excessive exposure to noise from running engines and heavy-duty equipment - Operation Phase Environmental Impacts • Air: Increase in vehicular movements will lead to Minor increase in air pollution from exhaust fumes • Surface Water: The use of aggregates for road Minor rehabilitation and construction may increase quantities of heavy metals in surface waters which are also used by locales for domestic purposes Social Impacts • Security: The rural communities may become more Minor accessible and more exposed to people and activities from outside their communities including criminals, armed robbers, kidnappers etc. • Accidents: Accidents involving vehicles or pedestrians Major are likely to occur as a result of drivers exceeding speed limits and exhibiting negligence especially in community roads that are small and have moderate pedestrian numbers • Gender Based Violence: Women and girls may be Moderate exposed to sexual harassment and violence during community-based maintenance activities • Discrimination against gender and vulnerable Minor groups: Issues of discrimination against gender and vulnerable groups may arise during community-based maintenance activities Decommissioning Phase Environmental Impacts • Air: Increase in dust generation as a result of Minor decommissioning activities

• Waste: Generation of solid waste as a result of Minor decommissioning activities Occupational Health & Risk injuries and cuts during decommissioning & Minor Safety (OHS) removal of all material & equipment used during construction

6.4 Labor Influx, Gender Based Violence (GBV) and Gender Mainstreaming

6.4.1 Labor Influx The Enugu RAMP 2 road rehabilitation project may face an influx of non-local labor and working conditions issues as skilled laborers might not be available within the community. The influx of workers and followers can lead to adverse social and environmental impacts. Such adverse impacts may include increased demand and competition for local social and health services, as well as for goods and services, which can lead to price hikes and crowding out of local consumers, increased volume of traffic and higher risk of accidents, increased demands on the ecosystem and natural resources, social conflicts within and between communities, increased risk of spread of communicable diseases such as HIV/AIDS, and increased rates of illicit behavior and crime.

Therefor Enugu RAMP 2 will take concrete measures to mitigate potential labor influx-related risks such as workers’ sexual relations with minors and resulting pregnancies, presence of sex workers in the community, the spread of HIV/AID, sexual harassment of female employees, child labor and abuse, increased dropout rates from school, inadequate resettlement practices, and fear of retaliation, failure to ensure community participation, poor labor practice, and lack of road safety. These risks require careful consideration to improve social and environmental sustainability, resilience and social cohesion.

In view of the above, Enugu RAMP2 SPIU will include mitigation measures such as: (a) assessing living conditions of workers’ camps and ensuring appropriate living conditions; (b) establishing and enforcing a mandatory Code of Conduct for the company, managers and workers, and an Action Plan for implementation; (c) ensuring appropriate location for these camps; (d) taking countermeasures -

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indicated in the Social Management Plan - to reduce the impact of the labor influx on the public services; and, (e) devising and implementing a strategy for maximizing employment opportunities for local population, including women.

The following guidelines lays out the principles that are key to properly assessing and managing the risks of adverse impacts on project area communities that may result from temporary Enugu RAMP2 induced labor influx. a) Reduce labor influx by tapping into the local workforce. The most effective mitigation measure against labor influx is to avoid or reduce it. Depending on the size and the skill level of the local workforce, a share of the workers required for the project may be recruited locally. b) Assess and manage labor influx risk based on appropriate instruments. The assessment and management of labor influx should be based on risks identified in the ESIA, other Bank-required assessments, and the Bank’s sector-specific experience in the country. Depending on the risk factors and their level, appropriate mitigation instruments need to be developed. This may range from broad requirements set out in the ESMP in a low-risk environment, to the need to develop more specialized instruments, such as a site-specific Labor Influx Management Plan and/or a Workers’ Camp Management Plan (or other instruments with similar purpose) in a high-risk environment. Risk factors to the SPIU that should be considered, include;

• weak institutional capacity of the implementing agency; • predominant presence of contractors without strong worker management and health and safety policies; anticipated high volumes of labor influx; • pre-existing social conflicts or tensions; • weak local law enforcement; prevalence of gender-based violence and social norms towards it in the community (acceptance of gender-based violence); • prevalence of transactional sex; • local prevalence of child and forced labor; • existing conflict situation between communities; absorption capacity of workers to the community c) Incorporate social and environmental mitigation measures into the civil works contract. Most adverse impacts from labor influx can only be mitigated by the contractor commissioned by the Borrower to carry out the works. It is therefore paramount that the responsibilities for managing these adverse impacts are clearly reflected as a contractual obligation, with appropriate mechanisms for addressing non-compliance.

The Supervision Consultant shall be responsible for monitoring the contractor’s performance and adherence to the labor influx guideline and that of its Sexual Exploitation and Abuse (SEA) obligations, with a protocol in place for immediate, timely, mandatory and confidential reporting in case of incidents to project community. This allows the Enugu RAMP2 SPIU to enforce the implementation of such mitigation measures, which are required to ensure the consultant’s own compliance with Bank policy requirements. While the Bank reviews and clears project-level safeguard instruments such as the ESIA/ESMP, it is the SPMU’s responsibility to: (i) ensure the safeguard instruments are reflected in the C-ESMP), and (ii) ensure the project is implemented in accordance with the C-ESMP, safeguard instruments and other relevant contractual provisions.

6.4.2 Gender Based Violence Nigeria is among the 10 percent of countries worldwide that exhibit the highest levels of gender discrimination according to the OECD’s Social Institutions and Gender Index, with an assessment of “high” or “very high” in all of the evaluated categories (discriminatory family code, restricted physical integrity, son bias, restricted resources and assets, restricted civil liberties). It also falls into the group of countries with highest gender inequality in human development outcomes (UNDP 2016).

Gender-Based Violence (GBV) remains pervasive and underreported in the country, largely constraining women’s autonomy and life chances. The 2013 Demographic Health Survey (DHS) indicates that nationally, 38 percent of women between the ages of 15-49 have experienced some form of physical or sexual violence from the age of 15, and 11 percent experienced physical violence within the 12 months prior to the survey. 45 percent of women who experienced violence never sought help or never told anyone about the violence. Besides interpersonal and sexual violence, child marriage and Female Genital Mutilation are the other culturally harmful practices prevalent across Nigeria. Conflict in the North East has further contributed to a steep rise in targeted violence against women and children by Boko Haram increasingly for abduction and violence. Women and girls are increasingly being used as instruments of war, making them vulnerable to stigmatization and rejection from their families and communities.

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As a State party to the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) and the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa (the “Maputo Protocol”), Nigeria has made legally binding commitments to exercise due diligence to combat gender-based violence and discrimination.

Accordingly, Nigeria has an obligation to take all appropriate measures to prevent rape, ensure that there are adequate sanctions for rape in law and in practice, and ensure access to reparation for the victims. Furthermore, several human rights instruments require Nigeria to take special measures to protect the rights of individuals who are vulnerable to sexual violence, namely women, children, and persons with disabilities.

Individual due diligence focuses on the needs of individual survivors and “places an obligation on the State to assist victims in rebuilding their lives and moving forward,” for instance through the provision of psychosocial services. Individual due diligence “requires States to punish not just the perpetrators, but also those who fail in their duty to respond to the violation.” As for systemic due diligence, it includes ensuring “a holistic and sustained model of prevention, protection, punishment and reparations for acts of violence against women.

6.4.3 GBV Risk Management Mechanisms A GBV workshop was conducted to sensitize the SPIU staff on the key principle and specific requirements to address GBV/SEA have been included in the bidding documents (‘pre-qualification’ and ‘employers’ requirements’). As such specific measures to reduce and mitigate the risk of GBV/SEA in the project were developed. These include: a) GBV/SEA assessment of project; b) Mandatory contractors’ code of conduct on sexual harassment; c) Appointment of NGO to monitor GBV/SEA in Enugu RAMP; d) Community and workers’ sensitization on GBV/SEA; e) Provision of referral units for survivors of GBV/SEA; f) Provisions in contracts for dedicated payments to contractors for GBV/SEA prevention activities against evidence of completion; g) Contractor and SPIU requirement to ensure a minimum target of female employment with incremental rewards of the obtainment of this target.

Based on the above, these actions are recommended for immediate implementation:

1. Hiring a dedicated GBV/SEA specialist and planning for trainings, 2. Including in the focal NGO’s ToR services for managing social risks associated with GBV/SEA in the project, 3. Building and improving FPMU/SPIUs, local communities and other relevant stakeholders’ capacities to address risks of GBV/SEA by developing and providing guidance, training, awareness, and dissemination of relevant GBV/SEA materials to communities, 4. Developing a clear Enugu RAMP2 specific internal “Reporting and Response Protocol" to guide relevant stakeholders in case of GBV/SEA incidents, 5. Strengthening operational processes of Enugu-RAMP 2 state project area on GBV/SEA, 6. Identifying development partners and cultivating pragmatic partnership on GBV/SEA prevention measures and referral services, 7. Developing Codes of Conduct for civil works contractors with prohibitions against GBV/SEA, 8. Strengthening consultations and operationalizing GBV/SEA specific grievance redress mechanisms, 9. Providing financial support implementation of the GBV/SEA actions described herein, including training and awareness building for various stakeholders, 10. Establishing inter-ministerial committee to advance GBV/SEA actions described above.

Overall, GBV risks in the project target areas might include Intimate Partner Violence (IPV), public harassment including harassment, verbal insults, physical abuse, rape, harmful widowhood practices and women and child trafficking. Targeted support to women under the program could likely exacerbate these risks. Development and implementation of specific GBV risk prevention and mitigation strategies, tailored to local contexts, will be critical. Guidelines for situation analysis of GBV and safe reporting guidelines in line with international best practices will be implemented. Further, all risks related to labor influx will have to be mitigated by participation of project beneficiaries/communities, and involvement of project contractors and contractors’ workers and consultant employees, in identifying mitigation and implementing measures, including developing mitigation instruments such as “Labor Influx Management Plan” and “Workers Camp Site Management Plan” (The “Labor Influx Management Plan” and “Workers Camp Site Management Plan” will be part of the C-ESMP) which must be submitted to the State PMU prior to commencement of civil works. See Annexes 15 and 17 respectively for sample plans).

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7 CHAPTER SEVEN: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

7.1 Institutional Arrangement for Implementation

The successful implementation of this ESMP depends on the commitment and capacity of various institutions and stakeholders to implement the ESMP effectively. Thus, the arrangement as well as the roles and responsibilities of the institutions and persons that will be involved in the implementation, monitoring and review of the ESMP are discussed below.

Table 16: Institutional Arrangement for Implementation Institution Responsibilities Enugu RAMP2 SPIU • Management, implementation, monitoring and compliance of the ESMP, and any approval conditions, including construction supervision and performance of all Project staff, contractors and subcontractors. • Review of ESMP performance and implementation of corrective actions such as Stop work procedures, in the event of breaches of ESMP conditions that may lead to serious impacts on local communities, or affect the reputation of the Project • Ensure effective communication and dissemination of the content and requirements of the ESMP to contractors and subcontractors Ensure compliance to all project social commitments, including implementation of the social management plans • Ensure effective community liaison and fulfill commitments to facilitate public consultation throughout the project cycle • Liaise with other relevant State Government MDAs, Federal Government MDAs, CBOs and NGOs for effective implementation of the ESMP Environmental and • Prepare Terms of Reference for environmental and social safeguards Social Safeguard Unit – studies SPIU • Review all ESIAs/ESMPs documents prepared by environmental and social consultants and ensure adequacy under the World Bank Safeguard policies • Ensure that the project design and specifications adequately reflect the recommendations of the ESIAs/ ESMPs • Co-ordinate application, follow up processing and obtain requisite clearances required for the project • Liaise with the Federal and State Ministries of Environment to disclose safeguard documents • Develop, organize and deliver training program for the SPIU staff, the contractors and others involved in the project implementation, in collaboration with the SPIU Review and approve the C-ESMP • Liaise with various Central and State Government agencies on environmental, resettlement and other regulatory matters • Continuously interact with the NGOs and community groups that would be involved in the project • Establish dialogue with the affected communities and ensure that the environmental and social concerns and suggestions are incorporated and implemented in the project • Review the performance of the project through an assessment of the periodic environmental and social monitoring reports; provide a summary of the same to the Project Manager, and initiate necessary follow-up actions • Prepare monthly environmental and social safeguards reports for the attention of the FPMU Safeguards unit ESSU-FPMU • Provide guidance for ESMP implementation • Conduct safeguard due diligence to the State • Review safeguard reports including ESIA/ESMP/RAP/ARAP • Review monthly safeguard reports and provide recommendations and action plan to the ESSU-SPIU Grievance Redress • Receive and record complaints and redress accordingly Committee (GRC) • A critical actor in the operation of the Grievance Redress Mechanism (GRM) set for the project. (Chapter 8 of this report provides the GRM

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Institution Responsibilities framework for this project). Enugu State Ministry of • Responsible for environmental performance of RAMP Environment and • Monitor, evaluate and audit the implementation of the ESMP to ensure Mineral Resources that the rehabilitation works and project operations meet “best environmental practices”. Enugu State Ministries • Handle issues of consent or approval for aspects of the project by of Works; Enugu government and its Agencies Electricity Distribution • Monitoring and supervisory oversight during construction and Company operational phases • Supervise issue of temporary relocation of electric poles Construction • Ensure all contractors and workers sign the Code of Conduct (CoC) Contractor and are routinely trained on the contents of the CoC (See Annex 4) • Compliance to BOQ specification in procurement of material and construction • Prepare C-ESMP for approval of ESSU-SPIU • Ensure that all construction personnel and subcontractors are trained on the content of the C-ESMP and are made aware of the required measures for environmental and social compliance and performance • Prepare and implement Workers’ Campsite Management Plan (Annex 17) which will also provide guidance for management of staging areas for the pre-construction phase, construction and decommissioning phase • Prepare OHS manual and abide by labor laws as set out in the agreement • Provide adequate basic amenities and PPEs to workers, and ensure that the PPEs are worn by workers during work. • Prepare and maintain records and all required reporting data as stipulated by the ESMP, for submission to the Supervising Consultant Supervision Consultant • Prepare and implement Environmental Monitoring Plan during (Environmental and construction Supervise contractor performance of implementation of Social Officers) the Workers’ Campsite Management Plan to be included in the Contractor’s C-ESMP • Report any incidents or non-compliance with the C-ESMP to the ESSU- SPIU • Ensure adequate training and education of all staff involved in environmental supervision • Prepare monthly safeguards report including recommendations to the RAMP regarding ESMP performance as part of an overall commitment to continuous improvement Federal Ministry of • Register ESIAs/ESMPs in the Ministry’s database Environment • Provide guidance for disclosure of safeguard documents in-country

Federal Ministry of • Supervise the Enugu state rural access road projects implementation, Agriculture and Rural management and monitoring program. Development World Bank/AFD • Overall supervision and provision of technical support and guidance • Recommend additional guidance for strengthening the management framework and implementation performance • Conduct due diligence to ensure project environmental and social sustainability Local Govt/ Community • Inform communities about the project leaders/ Traditional • Ensure conducive social atmosphere for the execution of the project in Leaders their various communities • Act as intermediaries between the project implementation team and the communities • Assist in the recruitment of local workers during the construction activities and be involved in all grievance and conflict resolutions Communities • Communities to participate fully in road maintenance activities • Nominate vigilantes to support project security concerns NGOs/CBOs • Work with community members throughout the project. • Drive community approaches to road maintenance • Be involved in the monitoring activities, participate in Health awareness campaigns

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Institution Responsibilities • Assisting in their respective ways to ensure effective response actions during the palliative works, Awareness campaigns and as 3rd party monitors CDA • Ensure community participation by mobilizing, sensitizing community members Federal Road Safety • Control and manage traffic throughout project implementation Corps (FRSC), Enugu • Ensure vehicles operate within allowable emission limits State/Vehicle • Discourage counter road safety practices among road users Inspection office (VIO), Enugu State; Enugu State Traffic Management Authority (ESTMA); Enugu State Road Maintenance Authority (ESRMA) Nigeria Police Force • Work with community leaders to ensure security during construction (NPF), Enugu State and operation phases of the project Command GBV Specialist • Mapping of services for survivors of SEA and addressing GBV risk and protection from SEA Public Health Dept. • In collaboration with the Contractor, shall implement mitigation measures that address public health issues. Supervising Engineer • Provides an independent oversight ensuring contractor adhere strictly to the engineering specifications Enugu State • will ensure implementation of measures that concern the bio-physical Environmental environment Protection Agency • Waste management

7.2 Environmental and Social Management Plan

This section presents the ESMP Matrix for the proposed works highlighting adverse impacts, mitigation measures, responsibility, mitigation costs monitoring parameters and frequency, monitoring responsibilities and costs. The total cost of implementing the ESMP is N 68,189,000.00 (Sixty-Eight Million, One Hundred and Eighty-Nine Thousand naira) and equivalent of USD 222,840.20 (Two Hundred and Twenty-Two Thousand, Eight Hundred and Forty Dollars, Twenty Cents). Table 17 below gives a detailed breakdown of mitigation and monitoring from pre- construction phase to operation phase.

It is noteworthy to state that mitigation measures costed are indicative of the twenty-nine (29) rural roads.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Table 17: Environmental and Social Management Plan No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

I. Pre-Construction Phase A. Environmental Impacts 1. Mobilization Deterioration of ▪ Maintain equipment Contractors NGN: Air quality In-situ FMEnv Weekly in the SPIU NGN: of local air quality & machinery to 900,000 parameters measurement permissible surrounding Environmental 350,000 construction due to the manufacturers’ (CO, NO2, limit communities Safeguards equipment, gaseous specifications by USD: SO2, CO2, throughout Specialist USD: 1,144 regular servicing to machinery, emissions, 2,941 SPM) mobilization (ESS); plants and dusts and reduce carbon emissions. heavy-duty increased Enugu State ▪ Use water to wet vehicles to suspended Ministry of active areas for dust Environment project site particles that suppression. exceeds FMEnv (ESME) ▪ Conduct regular Maintenance permissible visual inspection of records limit for air dust pollution and LOT 1 - 6 quality ensure appropriate intervention if dust

levels are high. ▪ Train drivers/

workers on proper Driver’s Visual operation of vehicles observation of training and equipment to records records & include fuel interviews efficiency and anti- idling; also ensure speed limits are maintained. 2. 2Same as Noise and ▪ Select and use Contractors NGN: Noise level In situ Noise level at Weekly at SPIU ESS NGN: . I(A1) vibration vehicles/equipment 600,000 measurement sensitive Construction UNIT; 240,000 disturbances with lower sound receptors not site and from operation power levels.; Install USD: to exceed nearby ESME USD: 784 of heavy-duty suitable mufflers on 1,961 FMEnv communities vehicles engine exhausts and recommended throughout compressor level (90 dBA) mobilization components. for an 8hour ▪ Enforce appropriate period speed limit to reduce vehicle noise levels. ▪ Restrict noise- generating activities strictly to normal working hours (i.e. 9am – 5pm). ▪ Respond promptly to

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

noise complaints. ▪ Maintain equipment & machinery to manufacturers’ specifications by regular servicing to ensure minimal noise generation from running engines and equipment. 3. 3Same as Contamination ▪ Ensure proper Contractors NGN: Soil quality In-situ Soil and Soil and Project site SPIU ESS NGN: I(A1) of soil and tightening of oil 350,000 Water Quality Water and along UNIT; 300,000 nearby water containing or Water quality Measurement parameters transport bodies from oil operating parts in USD: are within corridors. ESME USD: 980 and other stacked equipment; 1,144 permissible hydrocarbon ▪ Use materials that limits disallow permeation leakages from of fluid and liquid stationary Twice monthly substances such as equipment oil. 4. 4Site clearing Loss of • Restrict removal of Contractors NGN: Clearly Visual Available Weekly at SPIU ESS NGN: for staging vegetation, vegetation and trees 300,000 defined observation number and camp site and UNIT; 300,000 area & removal of to the area of need boundaries of diversity of staging area Workers’ trees and only. USD: 980 protected plant species during this ESME USD: 980 camp shrubs and • Protect all vegetation areas within phase including habitat not required to be baseline sanitation destruction removed against conditions facilities damage;

• Undertake quick Evidence of revegetation of re-vegetation exposed soils with indigenous plant species once clearing LOT 1 - 6 activities are completed. Sub-Total NGN: NGN: 2,150,000 1,190,000 USD: USD: 3,889 7,026

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

B. Social Impacts 5. Same as Minor traffic • Install appropriate Contractors NGN: Traffic flow Visual Travel time; Access routes FRSC; SPIU NGN: I(A1) congestion (in safety signage 750,000 Observation to project sites Social 350,000 affected built and/or use signallers Adequate Safeguards up or urban at strategic USD: road signs Specialist (SSS) USD: 1,144 areas) and risk locations. 2,451 Along Project of road traffic • Inform local Site within accidents communities in built up areas between advance of road pedestrians and diversions & major Daily during moving activities likely to mobilization construction affect traffic. vehicles • Enforce road safety standards, traffic rules including speed limits

NOTE: The • Schedule large and roads have slow-moving vehicles

mostly low for off peak period volumes of • Develop and traffic (i.e. implement a traffic less than 250 Management Plan Evidence of AADT) (TMP) (See Annex 6) signed TMP

6. Same as Air pollution • Provide and enforce Contractors; NGN: Gaseous In-situ Air, Soil Contractor’s Daily at SPIU ESS UNIT; 1 NGN: I(A1) from carbon the usage of 800,000 Pollutants and Water Compliance Project site 420,000 emissions, appropriate PPE such as SO2, Quality and along ESMoH, Enugu dusts and (facemasks) USD: NO2, CO2, Measurement transport SMENv, & USD: 1,373 2,614 ESWAMA increased • Ensure no burning of CO, VOCs, corridors suspended combustible waste H2S, particles may on sites TSP/SPM expose Visual • Use of tarpaulins to observation construction cover trucks workers and transporting earth Contractor’s surrounding materials or spoil on Compliance communities to public roads public health • Ensure rehabilitation risk. of disturbed areas once completed • Maintain equipment & machinery to manufacturers’

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

specifications by regular servicing to reduce carbon emissions. • Use water to wet active areas for dust suppression 7. Mobilisation Increase • Establish workers’ Contractor NGN: Availability of Visual Public Monthly at SPIU ESS NGN: of personnel; demand on camp and provide all 1,200,000 amenities in inspection perception; project site UNIT; 350,000 existing basic amenities workers’ and community (water, sanitation USD: camp Contractor’s surrounding Enugu LGA USD: 1,144 health and etc.). 3,922 Compliance communities sanitation • Prohibit workers infrastructure from unauthorized LOT 1 – 6 access to community infrastructure 8. Preparation Increased • Deploy competent Contractor, in NGN: No of Records and Zero security Monthly at Environmental NGN: of staging security risks security personnel to liaison with 960,000 security Interviews incidents Construction & Social 420,000 areas due to storage secure project site. Local Vigilante personnel site and Safeguard of materials • Provide adequate USD: engaged surrounding officers of SPIU USD: 1,373 and equipment training of security 2,667 communities on site personnel. • Disclose site security arrangements to the Police Police and host communities. • Depending on the location, the Contractor shall provide temporary perimeter fencing to secure the environment and serve as a barrier from interference. 9. Labour influx Threat to • Labour Influx Contractor; 600,000 Workers Visual Community Monthly at Supervision 350,000 from community Management Plan: manual, observation perception Construction Consultant; employment culture, safety Ensure community employment and interviews and level of site and on project and security have priority codes etc. satisfaction. surrounding SPIU ESS UNIT; due to presence opportunity to communities of workers employment for Enugu LGA; skilled and semi- including risks skilled work Police of Gender • Promote equal Based Violence opportunities for

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

(GBV), Sexual employment for all Exploitation and (both male & Abuse (SEA) female) • GBV Mapping for survivors of SEA and GBV Specialist; GBV/SEA WB GBV Risk Ascribe GBV addressing GBV risk issues and Assessment risk rating LOT 1 - 6 and protection from cases Tool SEA • Develop an induction Compliance program including a to induction code of conduct for program for all workers (See CoC. Annex 4 for samples of Workers Code of Conduct). The code of conduct will address the following aspect: Respect for local residents; No hunting or unauthorized taking of products or livestock; VAC, SEA, GBV, purchase or use of illegal drugs,

fighting; • Provide cultural

sensitization training Level of to improve awareness of

awareness of local culture by workers to local migrant cultures, traditions workers. and lifestyles. • Employment process to include procedures for engagement

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

10. Land Grievances and • Liaise with local Enugu RAMP2 Cost of No of Complaints log Record of Weekly site SPIU ESS Same as in acquisition disputes from authority for proper SPIU, GRM grievances/ grievances activities UNIT; GRM for siting of acquisition of land acquisition and resolved workers’ land for explore leasehold (Cost of Disputes GRCs; camp workers’ options; GRM is reported including campsite and • Establishment and Grievance presented Supervisory operation of an sanitary staging area Redress in the Consultant effective GRM facilities and Committees summary (Social, accessible to (GRCs); table of Environment, staging areas community members ESMP HSE) • Encourage regular engagement Budget in this meetings with community and chapter) periodic special meetings with vulnerable & women groups in a safe place to ensure social inclusiveness on the project. • Explore all available options while Resident selecting worker’s Engineer of the camp with the Supervision objective of avoiding Firm or minimizing negative impacts on communities and maintaining constructive relationships. • Ensure compliance to information on establishing a camp site provided in Chapter 3 of this report.

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

11. Site Clearing Loss of assets • Implement the RAP Social Cost is Implementati Number of Level of Project SPIU, NGN: for and sources of to ensure affected Safeguard provided in on of PAPs satisfaction location; 240,000 construction livelihood asset owners are Officer (SSO) RAP Report compensatio compensated by PAPs FPMU adequately n and or provided At least twice USD: 784 compensated for loss livelihood with livelihood before of assets and assistance assistance construction economic crops. measures commences • Ensure all issues outlined in relating to the RAP compensation are handled in a transparent, consistent and equitable manner. • Provide employment opportunities to affected persons and local communities. Sub-Total NGN: NGN 4,610,000 2,130,000

USD: USD: 6,960 14,085

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

C. Occupational Health and Safety (OHS) Impacts 12. Mobilisation Occupational • Develop and Contractor NGN: Compliance Visual Safety of Project Site SPIU ESS UNIT NGN: of workforce, accidents and implement a project 800,000 to OHS Plan; workers and and SSS; 420,000 Machinery, injuries to specific Occupational Observation project Plant & workers; Health and Safety USD: Occurrences personnel ESMoH USD: 1,373 Equipment Plan (OHSP). (See 2,614 of accidents and Site Respiratory Annex 8) and injuries • Provide PPEs and Interview clearing for diseases to as a result of enforce its usage by staging area workers due to project workers and site inhalation of related personnel LOT 1 - 6 dust and activities

fumes;

leakages from • Ensure installation of hazardous fire-fighting materials like equipment such as battery acids, fire extinguishers at explosives, etc. strategic and accessible locations Hearing in areas where fire impairment outbreak is possible from excessive exposure to noise from running engines and heavy-duty equipment

Predisposition • Fumigation of site area with healthy snake bites and and environmentally scorpion stings friendly chemicals during land • Provide first aid box clearing containing, among activities others, antivenin injections

Sub-Total NGN: NGN: 800,000 420,000

USD: USD: 1,373 2,614

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

TOTAL 7,260,000 3,500,000

II. Construction Phase A. Environmental Impacts 13. Groundworks Vegetation loss • Areas where clearing Contractors NGN: Contractors’ Visual Compliance to Daily SPIU ESS UNIT; NGN: including: during land activities are 900,000 Compliance Observation limiting area 350,000 land clearing clearing necessary should be of vegetation ESME along road activities along properly bounded USD: clearing. USD: 1,144 path, road and extent of 2,941 Project site Scarification, construction/re clearing activities Compliance to should be re-vegetation Sub-grade habilitation considerably of areas preparation, path minimized (within Earthworks, the Right of Way). and • After construction Construction works are of base completed, affected course areas must be revegetated with at least 2 trees for every 1 tree removed. Contamination • Collect sediment Contractors; NGN: Contractor’s In Situ air, Safe handling, Weekly SPIU ESS UNIT; NGN: of soil and runoff in containers 1,400,000 Compliance water and soil usage and 600,000 nearby water for proper treatment quality storage of Supervisory bodies from oil before discharge; USD: hazardous Engineer USD: 1,961 leakages from • Ensure safe handling 4,575 materials; use Project site machines and and storage of of non- ESME hazardous hazardous equipment, and materials/chemicals alternatives from sediment (hazardous runoff chemicals should be stored at least 500m away from water bodies) • Use of environmentally friendly and non- hazardous alternatives where available Risk of • Vegetation (grasses) Contractors; NGN: Developed Visual Revegetation Quarterly at SPIU ESS UNIT; NGN: exacerbating shall be cleared only 420,000 site observation of affected Project site 420,000 erosion when contractor is Engineering Reclamation areas- ESME fully mobilised for USD:

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

concerns; construction. Consultant 1,373 Plan Number of USD: 1,373 • Vegetation clearance trees planted Land (where necessary) degradation and excavations and increased shall be limited to susceptibility to the demarcated Backfilling erosion due to construction site. activities sourcing of • Backfill with excavated soil construction material where materials appropriate. 14. Operation of Decreased air • Impose a speed limit Contractor Same as Air quality In-situ FMEnv Weekly in the SPIU ESS Same as equipment quality from for all vehicles and I(A1) parameters measurement permissible surrounding UNIT; I(A1) and automobile and construction (CO, NO2, limit communities machines; other equipment. Shall be SO2, CO2, throughout ESME less than 30km/h Earthworks; mechanical SPM) mobilization Transportatio equipment- • Haulage trucks Visual carrying sand shall n of materials based effluents, observation of be covered with and and dusts records & tarpaulin. equipment Maintenance interviews • Develop proper records excavation procedures for workplace • Hydraulic concrete Driver’s mixing machines training shall be used as records much as possible; • Ensure regular servicing of all construction equipment and machinery. • Fit all heavy equipment and machinery with air pollution control devices, which are operating correctly. Vibration and • Hydraulic concrete Contractor Same as Noise level Noise Noise level at Weekly at SPIU ESS Same as noise nuisance mixing machines I(A2) measurement sensitive Construction UNIT; I(A2) shall be used as receptors not site and much as possible to exceed nearby ESME; and regularly service FMEnv communities all construction

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

equipment and recommended machinery. level (90 dBA) • Minimize noise from for an 8hour construction period equipment by using vehicle silencers, fitting jackhammers with noise-reducing mufflers • Maintain maximum sound levels not exceeding 80 decibels (dba) when measured at a distance of 10m or more from vehicles, plants and machinery. • Train the operators on proper use and maintenance of tools, proper positioning of machinery on site • Maintain noise levels below 80 dB 15. Construction Aggravated soil Stabilize road sections Contractors NGN: Compliance Visual Reduced Project roads NGN: of drainage erosion, rain that are prone to 750,000 to observation vulnerability 350,000 structures fall runoff and rainfall run off, erosion engineering to erosion and Twice Monthly and facilities road breakages and road breakages USD: designs for road USD: 1,144 prior to drain 2,451 drainages breakages Affected construction Areas: Especially in:

Ohodo

Express Road Junction

Through

St.Thomas Catholic Church Ohodo through Central

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No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

Primary School Ohodo to Central School Ozalla Through Ijo Ozalla to Ama Ezike Ohemje Aku Road, Odenigbo- Edem Ani Ugwuiyi Mpi- Ofulu Onu Road with Spurs to Imilike- Ugbogidi Road and Catholic Parish Road

16. Flood Temporary • Increase height of Contractors’ NGN: In Situ Water Compliance to Project site Weekly during SPIU ESS UNIT NGN: Management disruption of road and construct Compliance 1,800,000 Quality proffered and this stage of Unit; 750,000 activities natural flow necessary drainage mitigation surrounding implementatio along road to USD: USD: 2,451 regime of rivers measures. Communities n activity and streams; prevent excess water 5,882 saturating roads Visual Enugu SMENV;

Affected from rainfall events Observation Areas: such as along Obeagu- Water pollution Ubahu-Amankanu- Ugwuaji With Umualor-Nike Road Spur To and Obeagu-Ugwuaji (Lot 2); Obeagu- Supervisory Uzamdunu Ugwuaji; Uzamdunu Consultant Road (Lot 4) Exacerbation of Road and Oruku- is water logging and Akpawfu Road (Lot experiencing 2) flooding • Carry out proper events, channeling/training/ similarly, Disruption of guiding of rivers into Umu-Ezejor- natural habitats nearby larger river Agu-Udele- of aquatic and course unpaved channel including Itabor Road amphibious life with Spur at provision of a main

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

Ubahor Road forms. relief and double (Lot 2) also relief structures after experience the bridge to drain floods. the flood; and construction of multi-cell box culverts. • Install grouted riprap for the flood protection to control erosion and future damage to hydraulic structures • Proper channeling of smaller streams/tributary contributing to flood plains to existing and proposed culverts/bridges. • Minimal inhibition of natural water courses by using viable alternatives as stated in the analysis of alternatives; • Minimize direct interaction of construction materials and equipment with water surface to avoid pollution/ contamination. 17. Construction Damage to • Minimize impact on Contractor; NGN: Contractor’s Visual Compliance to Weekly at SPIU ESS UNIT; NGN: and natural habitats natural habitats 960,000 Compliance observation proffered Project Site 420,000 operation of such as trees; • Provision of waste mitigation Supervisory bins in strategic workers’ soil USD: Number of measures Consultant USD: 1,373 points within the 2,667 waste bins in camps compaction; including increased solid project site within project ESME; • Proper excavation of sanitary waste sites waste from project ESWAMA; facilities generation site Implementati Adequacy of • Siting of labour on progress Waste ESMoH camp on a clearance management

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

of 500m from nearby of WMP, local communities; • Adequate training on environmental sanitation and hygiene, and proper use of toilet facilities on camp for construction workers on camp; • Prohibition of animal hunting Generation of • Develop and Contractor; NGN: Presence of Visual Contractor’s Weekly at SPIU ESS UNIT; NGN: solid and implement site 1800,000 functional Observation Compliance Project Site 800,000 sanitary waste specific waste Engineering sanitary ESME; management plan Consultant USD: facilities on USD: 2,614 (WMP) (See Annex 7 5,882 site; ESWAMA; for WMP) Interview • Ensure provision of Waste vendor ESMoH sanitary facilities on licenses and site for workers and enforce usage. waste Additionally, workers evacuation should be sensitized documentatio on the need for n; personal hygiene and sanitation. evidence of • Ensure usage of Enugu ESWAMA signed WMP approved waste vendor for waste evacuation & disposal. • Provide bins on site for temporary storage of domestic waste such as lubricant containers, drinking water sachets and carrier bags/packaging materials. • Dispose all construction and domestic waste at

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

the approved dumpsites and in a manner approved by the ESWAMA. • Ensure all trenches or excavations made during the construction works do not collect stagnant water, which could breed mosquitoes. • Ensure access to toilets for construction crew or provide temporary toilets (mobile toilets) for use where there are no existing ones. • Ensure mobile toilets/sanitary provisions are provided to reflect gender types. 18. Rehabilitation Burrow Pit • Develop and Contractor; NGN: Clearly Visual Site Monthly at SPIU ESS UNIT; NGN: works formation implement Burrow 420,000 defined observation; restoration construction 350,000 pit remediation plan Engineering boundaries of and zero no area ESME (See Annex 16) Consultant USD: protected of materials & USD: 1,144 • Ensure burrow pit 1,373 areas equipment on site considered is in site after a place jointly construction agreed between SPIU and community • Ensure rehabilitation of disturbed areas once completed to restore the visual and landscape integrity of the area • Ensure proper backfilling 19. Construction Generation of • Develop and Contractor NGN: Contractor’s Visual Contractor’s Weekly at SPIU ESS UNIT; NGN: work construction implement a site- 750,000 WMP Observation Compliance Project Site 700,000 waste including specific Waste

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

activities spoils, debris Management Plan USD: ESWAMA USD: 2,288 and concrete (WMP) (See Annex 7 2,451 for sample) Evidence of Interview • Ensure segregation waste of waste to facilitate segregation reuse and recycling opportunities. • Ensure hazardous wastes are stored in Waste labeled closed storage containers with facility secondary containment with storage containers. • Ensure no burning of Waste vendor waste on site. licenses and • Ensure usage of Enugu ESWAMA waste approved waste evacuation vendor for waste documentatio evacuation, n processing & disposal. Sub-Total 9,200,000 4,740,000

B. Social Impacts 20. Construction Possible impact • Early notification and Contractor; NGN: Contractors’ Visual Compliance to Monthly SPIU ESS Unit NGN: and to road side sensitization of PAPs SPIU ESS UNIT 960,000 Compliance Observation proffered Supervision 540,000 rehabilitation markets12, • Limit demolition to Unit; key mitigation Consultant 13 temporary structures / schools officials from USD: measures. USD: 1,765 facilities, petty and utility lines on the SPIU; Site 3,137 Realignment trading shops the ROW committee

of roads and houses Implement • Implement RAP for narrowed or existing on the costs compensation of blocked by proposed project roads or affected PAPs village in the RAP on the ROW markets,

schools,

Record of grievances 12 Markets wereGrie vancesobserved along these roads: Obeagu-Ugwuaji Road (Lot 4), Nkpologu-Uvuru-Ukpata-Adaba-Akunyi-Umulokpa Road (Lotresolved 1), Umuaji Aguobu Owa-Umuaji MgbagbuowaSPIU ESS Unit Agba 13 Schools were observed in communities• Implement along GRM these roads: Uhuogiri-Railway Road (Lot 4), ObeaNogu of-Ugwuaji RoadRecords (Lot 4) & fromOruku -Afo-Ezza Road, Nkpologu-Uvuru-Ukpata-Adaba-Akunyi- Umulokpa Road (Lot 1), Umuaji Aguobu Owa-Umuaji Mgbagbuowa Agba Umuna-Ebenebe Road (Lot 4), MTN Exp Junction-Umueze-Aguawu Farm Settlement Road-Spur to Okposi (Lot 4), Achara grievances/ GRM Logbook One-off Grievance Ohodo-Old Pry Sch Ohodo-Union Pry Sch Ohodo-Lejja & Obodoamagu Umudele to eke Amanefi pry School (Lot 3) Redress Disputes Visual Committee reported observation Page | 86

ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

community Displacement • The contractor shall, Contractor; Same as No of Implement Record of Weekly site SPIU ESS NGN: structures, or destruction in the areas, ensure RAP grievances/ RAP grievances activities UNIT; 360,000 etc. as in of public that the existing EEDC; Enugu resolved; LOT 1 – 6 infrastructures services are not Water Disputes GRC; USD: 1,176 and utilities damaged or Corporation/ reported on Replacement such as water disrupted, unless power of affected ESMoP this is essential to pipelines, Water Board outages public the implementation electric poles, infrastructure of the project and electric upon prior transformers, authorization of the and shrines in client/ Resident some affected Engineer. areas14. • If relocation is recommended during RAP assessment, conduct sensitization of community stakeholders on likelihood of temporary outage of power due to relocation, and relocation of shrines. • Inform appropriate Interruption in institution electricity specifically, Enugu services and Electricity temporary Distribution power outages Company (EEDC), or EEDC; Enugu Enugu State Water Corporation (ESWC) State Water of relocation Corporation requirements of (ESWC) power or water 14 Affected Areas: infrastructure. Electric Poles: (LOT 1, 2, 4) Ogbaku• Conduct-Ogugu sensitization-Owelle-Ihe Road, From Ogbaku Town – LOT 1), Odenigbo-Edem Ani Ugwuiyi Mpi-Ofulu Onu Road with Spurs to Imilike-Ugbogidi Road and Catholic Parish Road Nguru-Akpotoro-St Maryof community Obimo Road Umu-Ezejor-Agu-Udele-Itabor Road with Spur at Ubahor Road, Obollo Ogbelle-Ezimo Road Electric Transformers: (LOT 1, 2,stakeholders 4) Neke –Umualor on – Ehamufu – Railway Line Road, Umuaji Aguobu Owa – Umuaji Mgbagbu Owa Agba Umuna – Ebenebe road (with Spur to Aguobu Ozom through T-Junction Umuaji) , Aku-Uduemelikelihood Road, of Road Junction Through St.Thomas Catholic Church Ohodo through Central Primary School Ohodo to Central School Ozalla Through Ijo Ozalla to Ama Ezike Ohemje Aku Road temporary outage of Shrines: (LOT 2, 4, 5, 6) Umuajipower Aguobu due Owa to – Umuaji Mgbagbu Owa Agba Umuna – Ebenebe road (with Spur to Aguobu, MTN Express junction – Umueze – Aguawu farm settlement road – Spur to Okposi Road relocation under the Water Pipelines: Abonuzu Owa – RAPAjali water works (Lot 4), Ogbo Umuokere-Mbanato-ImufuUmundu-Obegulgugu-Nkporogwu-Ngbede-Nkwo Umundu Ohullor Road (Lot 2) • The contractor shall, in coordination with the local authorities and the providers of the service being Page | 87 discontinued (EEDC or ESWC), inform affected parties, at least 3 days in advance, using the ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

Grievances and • Contractor should Contractor, key Implement No of Records from Record of One-off SPIU ESS Unit NGN: disputes from endeavor to avoid officials from costs grievances/ GRM Logbook grievances 360,000 Physical interference with the the SPIU, Site proposed resolved Cultural areas with cultural committee; in the RAP Disputes Visual USD: 1,176 Resources implications. reported observation Grievance (PCR) such as • Where avoidance is Redress impossible, there will relocation of Committee be need to Conduct shrines and proper consultations other cultural with all project sites affected persons (PAPs) to ensure adequate information is obtained on relocation requirements. The SPIU key officials must lead these consultations. • Implement GRM SPIU • Pay full Safeguards compensation for Unit; GRC land acquired for road project (standalone RAP to address) and implement all traditional rites associated with the relocation or compensation process

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

21. Road Potential • Ensure interface with Contractor; Part of Records of Visual FMEnv/ WHO Quarterly at Enugu State Part of rehabilitatio damage to Enugu State Water ESWC Operationa inspection, observation Guidelines the reservoir Ministry of operation n, buried pipes Corporation (ESWC) l cost maintenance value for during Water cost groundworks to identify pipeline and water drinking- operation Resources & network route prior sample water quality (ESMWR) construction to commencement of analysis Water road construction/ activities sampling and rehabilitation work such as laboratory/ in- • Disconnect pipes, situ analysis Abonuzu where necessary Owa – Ajali water works (LOT 4)

22. Road Increase in ▪ The contractor shall Contractor; NGN: Level of Visual Awareness Project SPIU ESS Unit; NGN: rehabilitation spread of ensure, through a 1,800,000 awareness observation Conducted community 840,000 , Communicable local service Local Service and project Supervisory groundworks diseases, STDs provider, that the Providers; USD: camps consultant; USD: 2,745 & such as team is aware of the 5,882 construction HIV/AIDS and risks of contracting ESMoH ESMoH and spreading activities; other STIs sexually transmitted Monthly diseases, particularly LOT 1 – 6 HIV/AIDS and other STIs, and prevent such risks ▪ Ensure access into construction site is restricted ▪ Free testing kits ▪ Provision of condoms ▪ Vaccinating workers against common and locally prevalent diseases; ▪ Monitoring of local population health data, in particular for transmissible diseases. ▪ Implementation of HIV/AIDS education program; • Awareness campaigns on STDs among the workers

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

and local community in collaboration with relevant HIV/AIDS management organizations in Enugu State. • Ensure compliance to workers’ Code of conduct as stated in CESMP (See Annex 4 for sample) 23. Road Risk of • Commitment / policy Contractor NGN: Records of Visual Awareness Monthly at SPIU ESS Unit; NGN: rehabilitation GBV/SEA and to cooperate with 2,800,000 training and observation; campaign Project Supervisory 960,000 , VAC as a result law enforcement awareness Interviews; conducted community Consultant; groundworks of Labour Influx agencies USD: conducted; Records GBV Specialist USD: 2,667 & investigating 9,150 inspection construction perpetrators of gender-based activities violence; Evidence of • Provision of LOT 1 - 6 signed Code opportunities for of Conducts; workers to regularly return to their families; • Provision of Evidence of opportunities for inclusion in workers to take the bid advantage of advert and entertainment contract opportunities away from rural host communities. • Capacity building for local law enforcement and the Enugu State ministry of Women Affairs and child development to act on GBV complaints; • Information and awareness raising campaigns for community members,

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

specifically women and girls, on GBV issues; • Provision of information to the project corridor about the contractor’s policies and Workers’ Code of Conduct (where applicable). (See sample in Annex 4) • Enforcement of laws on sexual violence and human trafficking. • Include in the bid document and also in the contract the need for contractor to draft and sign the following: a. Company’s code of conduct for prevention of GBV and VAC (See sample in Annex 4); b. Manager’s Code of Conduct for prevention of GBV and VAC (See sample in Annex 4) c. Individual’s Code of Conduct (CoC) for prevention of GBV and VAC (See sample in Annex 4) • Ensure all contractors and workers sign the Code of Conduct (CoC) (See sample in Annex 4) and are routinely trained on the contents of the

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

CoC. Training should also be done in local languages to ensure understanding by all. • Community and workers’ training and community sensitization on GBV/SEA/VAC; • Developing a specific internal “Reporting and Response Protocol and GRM" to guide relevant stakeholders in case of GBV/SEA/VAC incidents. 24. Same as Labour influx • Contractor to hire Contractor NGN: Contractor’s Visual Compliance to Monthly at SPIU ESS UNIT; NGN: II(B23) from additional workers through 960,000 Compliance Observation proffered Project site Supervisory 420,000 population recruitment offices and records mitigation and project Consultant and avoid hiring “at USD: USD: 1,373 (“Followers”) measures community the gate” to 3,137 Social Vices discourage including spontaneous influx robbery and of non-local job seekers, and extortion of prioritize/monitor construction engagement of local workers along labour some selected • Local government 15 roads prone should ensure that to these all forms of illegal occurrences. settlements as a result of the project implementation is discouraged early. 25. Same as Noise nuisance • Mitigation at source Contractor Same as Number of In-Situ Contractor’s Monthly SPIU ESS Unit; NGN: II(B23) from running • Inform PAPs prior to I(A2) Compliance around project Supervisory 600,000 engines commencement of Complaints Measurement community Consultant works of USD: 1,961 from affected

15 Identified roads prone to robbery and extortion include: Odenigbo-Edem Ani Ugwuiyi Mpi-Ofulu Onu Road with Spurs to Imilike-Ugbogidi Road and Catholic Parish Road

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

communities noise level

Sub-Total NGN: NGN: 6,520,000 4,320,000

USD: USD: 21,307 14,118

C. Occupational Health and Safety Impacts 26. Earthworks, Public safety, • Develop and Contractor; NGN: Availability of Procurement Contractor’s Daily at SPIU ESS Unit; NGN: Groundworks road accidents implement a project 1,200,000 an planning Compliance project site 900,000 , Excavation leading to specific Occupational Engineering Occupational procedures ESMoH & road injuries and Health and Safety Consultant/Mini USD: Health and USD: 2,941 rehabilitation fatalities Plan (OHSP). (See stry of Works & 3,922 Safety Plan activities affecting host Annex 8 for OHSP) Transport; (OHSP). • Ensure QA/QC community control is established population, SPIU ESS Unit on inspection of which could materials, which are lead to conflict/ Availability of to be of best quality QA/QC plan unrest and to prevent defective LOT 1 - 6 for the works stoppage of outcomes on activities. construction sites • Use tarpaulins to cover sand and other loose material when transported by trucks • Ensure burrow pits are used for extraction of material only for project purposes and not commercial 27. Operation of Occupational • Implement OHSP Contractor NGN: OHSP Visual Contractor’s Monthly at SPIU ESS Unit; NGN: Machinery & accidents and (See Annex 8 for 2,000,000 developed observation Compliance to Construction 840,000 Equipment injuries to OHSP) OHSP Site ESMoH; USD: Supervisory USD: 2,745 workers and • Provide appropriate 6,536 Consultant risk to security measures in No of trained community place to prevent first Aiders health and harassment or kidnapping of

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

Movement of safety workers materials • Provide and enforce the usage of PPE Usage of appropriate • Provide appropriate PPE signage and

demarcations with

Earthworks clear notations in English, and Usage of translated in Igbo signage and demarcations

28. Construction Occupational • Ensure location is Contractor; NGN: OHS Visual Contractor’s Monthly at SPIU ESS Unit; NGN: of culverts, accidents and properly cordoned 1,200,000 Procedures observation Compliance Construction Supervisory 600,000 drainage injuries to off before developed Site Consultant basins, River workers and construction USD: USD: 1,961 crossings/cul risk to activities are carried 1,961 verts community out. (Depending on the location there health and maybe need to safety provide temporary perimeter fencing to

secure the environment and LOT 1 – 6 serve as a barrier from interference).

• Create awareness in neighbouring communities to ensure road users are aware of road intervention work

• As much as possible, ensure community

minimises movement

around the site and should be informed

before this type of work is carried out

• Use appropriate Usage of signage along road Risk of flooding signage and to show work in demarcations and possible progress drowning of • Use of flagmen to

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

workers divert traffic where required • Apply flood protection during works; workers must Compliance wear safety harness, to use of lifejackets and appropriate lifebuoys when PPEs working in river- areas Sub-Total NGN: NGN: 4,400,000 2,340,000 USD: USD: 7,647 14,379 TOTAL NGN: NGN: 20,120,00 11,400,000 0 USD: USD: 37,255 65,752

III. Operation Phase A. Environmental Impacts 29. Increased The drainages • Routine maintenance SPIU ESS Unit; NGN: Flow rate of Visual Implementati Quarterly at NESREA NGN: Vehicular may become of drainages 1,200,000 water observation on of project site 420,000 activities conveyors for • Proper waste ESWAMA through the proffered and within the surface debris management system USD: drainage mitigation community USD: 1,373 communities and improperly in the communities 3,922 systems disposed wastes during a Adequate heavy rain, waste leading to treatment in drainage the blockage and communities disruption of free flow. This may result in stagnated water, and

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

water contamination downstream.

Increase in • In collaboration with SPIU ESS UNIT; Gaseous In-situ General Project site NESREA vehicular the State FRSC; VIO Pollutants measurement compliance movements will Government, such as SO2, of air quality lead to increase implement regular NO2, CO2, in air pollution sensitization via CO, VOCs, from exhaust mass media on the H2S, TSP, PM allowable vehicular fumes 10 and PM emission limit and 2.5 the need for regular vehicle maintenance and the effect of excessive emissions into the atmosphere • Routine inspection of motorists’ compliance Possibility of • To follow proper Contractor; NGN: Structural Visual Efficient Quarterly at Enugu State NGN: bridge collapse, design and best 600,000 and observation; Durability of project sites Ministry of 300,000 flooding, or available practices to RAMP SPIU; performance roads and Works and erosion from rural road USD: integrity of hydraulic Infrastructure USD: 980 post construction Enugu State 1,961 hydraulic structures construction • Strict adherence to Ministry of features Routine terms of reference which may Works and inspection and specifications of result from Infrastructure engineering design poor designs, for bridge and road non-compliance construction to designs, sub- • Adequate and standard regular maintenance materials, poor maintenance

Sub-Total NGN: NGN: 1,800,000 720,000

USD: USD: 2,353 5,882

Social Impacts

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

30. Continuous The rural • The communities, NPF Enugu NGN: - - - Quarterly at RAMP SPIU 340,000 road communities with government State 1,200,000 Communities operation will become support will Command; along project more accessible constitute Community USD: path and more community vigilante executives and 3,921 exposed to groups and request Traditional for police posts for people and Leaders regular surveillance activities from of the communities.

outside their • The concept of local communities community alertness including system will be criminals, useful, to alert armed robbers, neighbors in case of kidnappers, invaders or criminals etc.,

Accidents • Installation of speed FRSC; ESTMA NGN: - - - Communities RAMP SPIU NGN: involving bumps at specific 800,000 400,000 vehicles or locations pedestrians are • Adequate road signs USD: USD: 1,307 likely to occur for motorists and 2,614 as a result of pedestrians

increased

vehicle operation and increased speed.

Sub-Total NGN: NGN: 2,000,000 740,000

USD: USD: 2,418 6,535

TOTAL NGN: NGN: 3,800,000 1,460,000

USD: USD: 4,771 12,418

D. Decommissioning Phase

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

I. Environmental Impacts 31. Demobilisatio Solid Waste • Ensure proper Contractor; NGN: Plan in place Complaints Adherence to Once during SPIU ESS Unit, NGN: n of facilities, generation handling of all Supervisory 1,300,000 & Executed received; WMP decommission Supervisory 350,000 plant & associated waste Consultant, resolution ing Consultant, equipment; generated from the USD: documented ESWAMA USD: 1,143 Demolition of demolition of camp 4,248 labour camps sites and staging area, in collaboration LOT 1 – 6 with the ESWAMA; • Ensure dumping of collected wastes at the designated dump site by the state waste management authority • Ensure proper sorting of wastes into recyclable and reusable waste; only non-recyclable and non-reusable wastes must be disposed, and this must be done in a safe manner as provided in the WMP. • Re-vegetate areas around workers’ camp & Maintenance equipment sites to restore the landscape. • Ensure that any remaining waste streams created during Maintenance activities and waste generated during decommissioning activities are collected from the project sites and properly disposed before handing over the project.

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

Sub-Total NGN: NGN: 1,300,000 350,000

USD: USD: 1,143 4,248

II. Occupational Health and Safety Impacts 32. Demobilisatio Risks of • Use proper signage Contractor No Number of Visual Contractor’s throughout ESMoH; NGN: n of facilities, occupational to additional accidents or observation Compliance demobilization 600,000 plant & accidents and • Use of PPE cost near and demolition SPIU ESS Unit equipment; injuries to • Implement specific accidents USD: 1,961 Demolition of workers. OHS Plan for these incidents labour camps activities

LOT 1 – 6

33. Burrow pit Public health • Level out hollow area Contractor/ NGN: Number of Visual Contractor’s Once during ESMoH; NGN: decommissio of burrow to reduce Engineering 600,000 Complaints observation Compliance decommission 600,000 ning ponding of water & Consultant received, and inspection; ing SPIU ESS Unit stagnation USD: resolution Interview USD: 1,961 • Revegetate area 1,961 documented around the burrow pit to re-introduce natural habitat LOT 1 – 6 formation • Maintain drainage channels of burrow to reduce water collection in hollow • Use of brickets in stagnant pond formation areas to eliminate insect breeding • Carry out burrow pit reclamation according to remediation plan Sub-Total NGN: NGN: 600,000 1,200,000

USD: USD: 3,922 1,961

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Project Potential Proposed Mitigation Responsibility Mitigation Parameters Method of Performance Frequency Responsibility Monitoring Activity Impact Measures/ Actions for mitigation Cost to be Measurement Indicator &Location of for Monitoring Cost Measured Monitoring

TOTAL NGN: NGN: 1,900,000 1,550,000

USD: USD: 5,065 6,209

GRAND TOTAL NGN: NGN: 33,080,000 17,910,000

USD: USD: 108,104 58,529

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

Record Keeping • The contractor should keep records providing evidence of ongoing mitigation activities. These documents should be made available upon request. • The Safeguard Unit should keep records to provide evidence of monitoring activities and effectiveness of the monitoring plan to include monitoring Plan, identified problems/corrective actions and monitoring Reports.

Table 18: Role and responsibilities

No Steps/Activities Responsible Collaboration Service Provider

1. Identification and/or Enugu RAMP2 • Local authority Enugu State siting of the sub-project • Enugu State Ministry of Works Ministry of Water & Transport Resources Implementation of Env. Safeguards Enugu RAMP2 mitigation measures specialist (ESS) and Safeguards Unit 2. included in ESMP Social Safeguards • Local authority • Social Specialist (SSS) on the Safeguards Enugu RAMP2. Specialist (SSS) on the Enugu RAMP2 • FMENV • Enugu State Ministry of Environment • ENUGU ESWAMA • Grievance Redress Committee (GRC) 4. Preparation and disclosure of safeguard documents/instruments in Enugu RAMP2 accordance with the national legislation/procedure

5. Report validation and Env. Safeguards • Procurement • FMEnv issuance of the permit Specialist (ESS) on the specialist (PS- • The World Bank (when required) Enugu RAMP2 Enugu RAMP2) • Enugu RAMP2 social safeguards • Local authority 6. (i) Oversee process of Social Safeguards Project • Enugu RAMP2 land acquisition to ensure Specialist (ESS) on the Coordinator Safeguards Unit GRM redress mechanism Enugu RAMP2 Enugu SPIU is in use, where Grievance necessary. Redress Committee (GRC)

Supervision (ii) Supervision of Communities Contractor labor Consultants recruitment process to monitor GBV issues such as SEA, & child labour issues

(i) Integrating the Procurement, • Supervising • Project construction phase Safeguard Unit, Project consultant Coordinator 7. mitigation measures and Coordinator (Enugu E&S clauses in the

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ENUGU RAMP 2 ESIA for Rehabilitation of 270.059km of Rural Roads in Enugu State

No Steps/Activities Responsible Collaboration Service Provider

bidding document prior to RAMP2) advertisement; (ii) ensuring that contractors prepare Contractor’s ESMP, gets it approved and integrates the relevant measures in the works breakdown structure (WBS) or execution plan.

Implementation of all ESS- Enugu RAMP2 • PS-Enugu • Consultant safeguard measures, RAMP2) • Relevant Federal 9. including, review of • SSS-Enugu RAMP2) • TS-Enugu & State safeguard documents RAMP2) Regulators environmental and social • Financial Staff • NGOs monitoring (when (FS-Enugu RAMP2) relevant) and activities • Local authority such as:

• Prepare Terms of Reference for environmental and social safeguards studies • Review all ESIAs/ESMPs documents prepared by environmental and social consultants and ensure adequacy under the World Bank Safeguard policies • Ensure that the project design and specifications adequately reflect the recommendations of the ESIAs/ ESMPs • Co-ordinate application, follow up processing and obtain requisite clearances required for the project • Liaise with the FPMU to disclose safeguard documents • Develop, organize and deliver training program for the PIU staff, the contractors and others involved in the project implementation, in collaboration with the PIU • Review and approve the Contractor’s ESMP

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No Steps/Activities Responsible Collaboration Service Provider

• Liaise with various Central and State Government agencies on environmental, resettlement and other regulatory matters • Continuously interact with any identified NGOs and community groups that would be involved in the project • Establish dialogue with the affected project areas and ensure that the environmental and social concerns and suggestions are incorporated and implemented in the project • Review the performance of the project through an assessment of the periodic environmental and social monitoring reports; provide a summary of the same to the Project Manager, and initiate necessary follow-up actions • Prepare monthly environmental safeguards reports for the attention of the FPMU Safeguards unit 10. Oversight of safeguards SSES • Monitoring and • Control Firm implementation (internal) Evaluation (Supervisor) specialist (M&E- Enugu RAMP2) • FS-Enugu RAMP2) • Local authority Reporting on project Coordinator • M&E-Enugu safeguards performance RAMP2 and disclosure • ESS-Enugu RAMP2 • SSS-Enugu RAMP2 External oversight of the Enugu State • M&E-Enugu • FMEnv project safeguards Environmental RAMP2 • ENUGU compliance/performance Protection Agency • ESS-Enugu ESWAMA RAMP2 • SSS-Enugu RAMP2

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No Steps/Activities Responsible Collaboration Service Provider

• PS-Enugu RAMP2 • Supervisor 11. Building stakeholders’ ESS-Enugu RAMP2 • SSS-Enugu • Consultant capacity in safeguards RAMP2 • Other qualified management • PS-Enugu public RAMP2 institutions

Independent evaluation ESS- Enugu RAMP2 • SSS-Enugu • Consultant of the safeguards RAMP2 12. performance (Audit) • PS-Enugu RAMP2

The Enugu RAMP2, and any institution participating in the implementation, will not issue a Request for Proposal (RFP) of any activity without the construction phase’s Environmental and Social Management Plan (ESMP) inserted in, and will not authorize the works to commence before the contractor’s ESMP (C-ESMP) for the selected 270.059km of roads has been approved and integrated into the overall planning of the works.

7.3 Monitoring and Reporting

7.3.1 Environmental and Social Monitoring

Environmental and Social monitoring is a crucial component of this ESMP during project implementation. This systematic monitoring will comprise both effects and compliance monitoring of the implementation of the Enugu RAMP2 sub-projects throughout the entire life cycle and shall oversee the effectiveness of impact mitigation measures, including the extent to which mitigation measures are successfully implemented. Particularly, monitoring shall:

• Improve environmental and social management practices; • Check the efficiency and quality of the ESMP processes; • Establish the scientific reliability and credibility of the ESMP for the project (as well as the quality of specialists providing ESMP consultancy services • Provide the opportunity to report the results on safeguards and impacts and proposed mitigation measures implementation.

Upon commencement of sub-projects implementation in the road construction & rehabilitation works, the environmental and social specialist of the safeguard unit of Enugu RAMP2 will begin monitoring and supervision as an important feedback mechanism to ensure compliance and implementation of mitigation measures described in the ESMP.

Methods for monitoring the implementation of mitigation measures should be as simple as possible, consistent with collecting useful information, so that the sub project implementer can apply them. For instance, they could just be regular observations of the sub project activities or sites during construction and then when in use.

Some indicators that could be used to ensure participation process involved in subproject activities include:

• Number and percentage of affected households/individuals/institutions consulted during the planning stage; • Levels of decision-making of affected people; • Level of understanding of project impacts and mitigation; • Effectiveness of local authorities to contributing and making relevant decisions; • Frequency and quality of public meetings; with community heads and general public

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7.3.2 Monitoring Activities

Monitoring shall be conducted to ensure compliance with regulatory requirements as well as to evaluate the effectiveness of operational controls and other measures intended to mitigate potential impacts. The Monitoring Plan for this ESMP including monitoring parameters, frequency, responsibility and cost are included in Table 19.

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Table 19: Specific Environmental & Social Parameters Monitoring Plan (270.059km selected roads)

Impact Time of Impact/Project Impact Indicator FMEnv Limits Sampling Sampling Sampling Monitoring Monitoring Parameter Phase Location Frequency Method Duration Personnel Ambient Air Site preparation, TSP 600g/m3 Receiving air - Daily, during site Short-term SPIU-RAMP2 Quality & upwind & preparation, Construction/rehabilitation & NO Air Sampler Contractor particulate 2 100 g/m3 downwind of construction; and gaseous Operation of facility the site (E&S SO2 Once every Officers in emission 300 g/m3  three months the CO 20 ppm during operation Contractors HC of facility Long-term Supervision Team)

Enugu SMENv & FMEnv

Noise Site preparation, Noise Level 80 dBA (8-hr) Work Site and Daily (During Decibel Noise SPIU-RAMP2 site preparation, Meter Construction/rehabilitation & 200m away construction Short-term Contractor Operation of facility (E&S Officers in the Contractors Supervision Team)

Enugu SMENv & FMEnv

Water Site preparation, pH As specified in Receiving Daily during Water Sampler, water body/ Turbidi-meter Quality Construction/rehabilitation & Temperature FMEnv drainage Land preparation Short-term SPIU-RAMP2 Operation of facility Guidelines (upstream & & construction & and pH-meter (Surface) Oil & Grease for 1- month at Contractor Down-stream operation. (E&S Salinity of discharge Officers in the COD point). Contractors

BOD Supervision

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Impact Time of Impact/Project Impact Indicator FMEnv Limits Sampling Sampling Sampling Monitoring Monitoring Parameter Phase Location Frequency Method Duration Personnel Turbidity Team)

TDS Enugu SMENv & TSS FMEnv Heavy Metals

Soil Site preparation, Particle Size, As specified in Within and Once, before and Visual Inspection Short-term SPIU-RAMP2 around after Construction/ Total Org C, FMEnv construction construction and Soil Contractor Guidelines area. Sampler (E&S rehabilitation Oil & Grease Heavy Officers in Metals, the

Contractors Nutrients, Supervision Team)

Enugu SMENv & FMEnv

Socio- Construction/ Absence of National/ Host Monthly during Socio-economic Short term SPIU-RAMP2 economics Contractor/community World Bank communities construction survey, Rehabilitation stage conflict, increase/ guidelines & observations Contractor decrease in economic procedures and interviews (E&S activities Officers in the Contractors Supervision Team)

Enugu SMENv & FMEnv

Health Construction/ Presence/ absence of National Host Monthly at Interview & Long term SPIU- alien diseases health survey communities construction and medical RAMP2, Rehabilitation & operation guidelines bi-annually at examinations & operation stages records ESMoH, Enugu

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Impact Time of Impact/Project Impact Indicator FMEnv Limits Sampling Sampling Sampling Monitoring Monitoring Parameter Phase Location Frequency Method Duration Personnel SMENv, & ENUGU ESWAMA

Land Pre-construction Complaints of land National/ Host Weekly before Complaints Long term SPIU-RAMP2 acquisition take or economic World Bank communities construction received by displacement guidelines & SPIU (Grievance Log) procedures

Grievance Economic redress displacement mechanism

Risk of Construction & Operation Increase in reported National/ Host During and after Interview & Long term SPIU-RAMP2 Increase in cases World Bank communities construction medical records spread of guidelines & works Enugu Communicable procedures State MoH diseases, STDs such as HIV/AIDS and other STIs

Risk of Construction & Operation Presence/ absence of National/ Host During and after Interview & Long term SPIU-RAMP2 GBV/SEA and reported cases World Bank communities construction medical records VAC as a guidelines & works Enugu result of procedures State MoH Labour Influx

Impacts on Site Preparation, Developed and Signed ISO 14001 Project/work Daily Visual Short term SPIU- Occupational Construction/Rehabilitation, OHSP Occupational sites observation RAMP2; Health and and Operation stages Health & ESMoH Safety (OHS) Safety Standards

Reconnection Operation & Visual inspections and National/ Host During operation Interview & Long term SPIU-RAMP2 of utilities Decommissioning reported cases State, World communities & records of such as Bank decommissioning inspections Enugu MoP existing power guidelines & cables procedures

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The monitoring activities, which shall include both Internal and External Monitoring for the ESMP presented in this ESIA is as shown in Table 20 below. Monitoring results shall be documented with preventive/corrective actions to be implemented.

Table 20: Internal and External Monitoring

Monitoring Action Responsibility When Deliverables

Internal Regular site visit to ensure Environmental During Monitoring Monitoring that the mitigation and Social Preconstruction, Reports and measures and actions Safeguard Construction documentation specified in the monitoring Officers from and Operation as described in plan are followed as bound SPIU. Phases Sub-section by the contract is 7.3.3 satisfactorily implemented.

Site visit for monitoring Independent During Observations and inspection to ensure Supervising Preconstruction and Monitoring contractor adhere strictly Engineer Construction Reports to be to the engineering designs and Operation compiled and and specifications for the Phases presented to the project SPIU.

External Regular site visits to check FMEnv, Enugu During Inspect Monitoring adherence to mitigation State Ministry of Preconstruction, monitoring measures and standards Environment, Construction reports from using the monitoring Representatives and Operation Safeguard units indicators specified in the of affected Phases and provide monitoring plan and other communities, feedback on national and international and other observations. environmental & social relevant MDAs. Enforce requirements. corrective actions where necessary.

7.3.3 Reporting Procedures

The reporting and responsibility matrix presented in Table 21 is developed in order to ensure that the SPIU is able to receive feedback on the implementation of the ESMP on an ongoing basis and to take rapid corrective actions if there are issues of non-conformance.

Table 21: Reporting Procedures Phase Responsibility Deliverables Accountability

Preconstruction Safeguard Unit Report of monitoring activities including SPIU, also ESME & any specific events FMEnv on request

Construction Safeguard Unit Monthly monitoring Reports SPIU, also ESME & FMEnv on request First to be prepared mid-way into the civil works and the other upon completion of all construction activities.

Safeguard Unit Additional Reports according to specific SPIU, also ESME & conditions e.g. Accidents, serious FMEnv on request environmental/social impacts

Completion of Safeguard Unit Final Monitoring Report including all SPIU. Report to be construction monitoring activities throughout project archived and made and implementation available to the demobilization World Bank, ESME &

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7.3.4. Record Keeping and Control

The contractor is required to keep records providing evidence of ongoing mitigation activities on specific sites in the entire selected 270.059km roads. Such records may include site monitoring plan, HSE Policy, Site Specific OHS Plan (See Annex 8), Waste Management Plan (See Annex 7), Traffic Management Plan (See annex 6), Emergency response and preparedness plan (See Annex 20), site instructions, training records, complaints records, incident report, Inspection, maintenance and equipment calibration records. These documents should be made available to the Safeguard Unit upon request.

The E&S Safeguard Unit is also required to keep records to provide evidence of monitoring activities and effectiveness of the monitoring plan. The site-monitoring plan identified problems/corrective actions and monitoring Reports highlighted in sub-section 7.3.3 are to be kept by the Safeguard unit and be made available to relevant regulators upon request. In addition, all significant communications with FMEnv, ESME and other relevant authorities should be documented and kept. These documents are required to track performance in order to achieve and demonstrate compliance with the monitoring plan and applicable regulatory requirements.

7.3.5 Implementation Schedule

The activities related to environmental and social management and monitoring must be integrated in the overall construction schedule. The project implementation phase is estimated for 18 months. The implementation schedule is presented in Table 22.

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Table 22: Tentative ESMP Implementation Schedule for the selected 270.059km roads

S/N Activity Description Responsible Preconstrution Constructiuon (Month) Operation Decomissioning (Month) (Month) (Month) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1. Clearance and Formal SPIU Disclosure of ESIA/ESMP 2. Inclusion of E&S SPIU Requirements in bid documents 3. Allocating Budget for SPIU ESMP 4. Appointing Support SPIU Staff for ESMP 5. Review & Approval of SPIU Contractor’s E&S Plans 6. Finalization of SPIU/ Consultant Engineering Designs 7. Mobilization to site Contractor 8. Site Clearing Contractor 9. Implementation of SPIU/Contractor RAP 10. Construction Phase Contractor 11. Implementation of SPIU/ Contractor Mitigation 12. Supervising ESMP SPIU Implementation 13. Monitoring & SPIU/MDAs Reporting on ESMP Implementation 14. Environmental and E&S Consultant Social Training 15. Environmental and SPIU/SME Social Auditing /Consultant

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7.4 Capacity Building for Implementation of ESMP and Permit Conditions

An initial assessment indicates that the capacity of the SPIU for implementing this ESMP will require strengthening, especially in the area of implementing the World Bank’s environmental safeguards policies, and the application & management, therefore requiring consolidation in order to close these gaps.

Consequently, a training Workshop will be organized to guide the implementation of the ESMP and topical areas of discussion would include the Permit Schedule, World Bank’s Safeguards Policy triggered and environmental management. The training on the ESMP implementations will include the Code of conduct for contractor and his/her labour force, public health and safety issues, occupational health, Grievance Redress Mechanism for the project, ESMP monitoring and reporting. The capacity building will also involve sensitisation of workers on issues such as child sexual exploitation, labour influx, Gender Based Violence, HIV/AIDS and their mitigation measures.

7.5 Objectives of the training

The main objective of the capacity building and training activities is to create, enhance and develop the necessary awareness, skills and abilities for successful implementation of the proposed project. It is also further recommended that the monthly site meetings discuss the issues identified in the ESIA and the mitigation measures flagged in the ESMP. Such issues, which would include attention to occupational health and safety issues, have been identified. Non-compliances identified during monitoring should be reviewed and corrective actions taken. The capacity building plan proposed to achieve this is provided in Table 23.

Table 23: Capacity building plan for implementation of the ESMP & permit conditions

Activity Target Timeline/Duration Proposed Cost NGN Group/Participants Facilitator Training on State Ministry of Prior to resumption/ Implementation Environment, Works, commencement of of the ESIA/ESMP Project LGAs, State construction works. SPIU 1,500,000 Environmental Traffic Mgt Agencies, (1 day) Community Liaison and Social Officers/ FPMU World Bank Officers from the 29 (cost of roads etc. Safeguard venue and Safeguards Policy Officers/ triggered and refreshment, World Bank training environmental Safeguards management. packs)

*Sensitisation of Prior to resumption/ Social 3,500,000.00 Contractors and commencement of Safeguards their workers on construction works. Specialist/ Code of conduct, (1 day each Lot) = 6 Consultant sexual All construction/ Days exploitation and contractor workers HIV/AIDS, labour influx, Gender Based Violence, and their mitigation measures

Training on GRM

Training on Preparation of C- ESMP and

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Activity Target Timeline/Duration Proposed Cost NGN Group/Participants Facilitator Implementation

Induction on All construction/ Prior to HSE-OHS 3,000,000.00 occupational and contractor workers commencement of Specialist public health and construction works. safety (OHS) (2 days for each Lot requirements of x 6 Lots) = 12 days the works and environmental management

Total 8,000,000.00

7.6 Output of the training

Capacity building on the health, safety, environmental and social management measures provided in this chapter is required to ensure the effective implementation of the ESMP and the permit conditions. All monthly and progress reports should capture health, safety and environment capacity building activities carried out.

7.7 Contractual Measures

Most of the mitigation measures in place for the 29 selected roads are the obligation of the Contractor during the pre-construction and construction phases of the project. Consequently, the potential contractor will have to prepare their proposals taking into account the measures in Table 24 as well as the detailed general environmental management conditions during civil works.

Table 24: Contractual Measures

Action Remarks

The measures as described in this ESMP shall be The non-inclusion of these measures in the included in the tender documents with proposal will lead to a disqualification of the appropriate flexibility to adjust these measures proponent; to site circumstances, and that the potential contractor will have to prepare their proposals The contract with the successful bidder should taking into account these measures. contain these environmental and social management measures as firm conditions to which compliance must be ensured.

Specifically, the measures should be translated This approach will ensure that the into a suite of environmental specification that environmental and social controls integrate are written in the same language style and seamlessly into the tender document and are format as the rest of the contract document presented in a familiar form to the Contractor.

Cost of mitigation measures be added to the The contactor must take into account and put cost of the contractual document the cost for the environmental and social requirements specified in the ESMP.

7.8 Estimated Budget for ESMP Implementation

The ESMP mitigation cost for the selected 270.059km roads is estimated at N 68,189,000.00 (Sixty-Eight Million, One Hundred and Eighty-Nine Thousand naira) and equivalent of USD 222,840.20 (Two Hundred and Twenty-Two Thousand, Eight Hundred and Forty Dollars, Twenty Cents). . This is as shown in Table 25.

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Table 25: ESMP Budget16 Total* Source of # Item Unit financing Local (N) US$ World Bank intervention loan 1 Mitigation Sum 33,080,000.00 108,105.00 2 Capacity Sum 8,000,000.00 26,144.00 Building 3 GRM Sum 2,000,000 6,536.00 4 Monitoring Sum 17,910,000.00 58,529.00 5 Budget for Sum 1,000,000.00 3,268.00 Disclosure Sub-Total 61,990,000.00 202,582.00 Contingency 6,199,000.00 20,258.20 (10% of sub Total) 68,189,000.00 222,840.20 Exchange Rates are based on the Central Bank of Nigeria (CBN) rate of USD 1 to NGN 306

Budget for GRM Item Unit Mitigation Monitoring Cost (N) Cost (USD) Cost (N) Cost (USD) GRM - 1,800,000 5,882 200,000 654

7.10 ESIA Disclosures

All safeguard reports (ESIA/ESMP/RAP) shall be disclosed by the SPIU in conjunction with the FPMU, after clearance from the World Bank. Disclosure shall be in line with the requirements as will be stipulated by the FMEnv, and also the World Bank infoshop. Budget for disclosure is estimated at NGN 1,000,000.00 (USD 3,268) as shown in the table 26 below.

Table 26: ESIA Disclosures S/n Action Remarks Cost Estimate NGN USD 1. Registration at FMEnv The FPMU shall register the ESIA at 50,000 163.40 the FMEnv 2. Disclosure on 2 state The SPIU will disclose the ESIA/ESMP 200,000 653.60 newspapers as required by the Nigeria EIA public (@ 100,000 notice and review procedures each) 3. Disclosure on 2 The FPMU will disclose the ESIA/ESMP 400,000 1,307.20 national newspapers as required by the Nigeria EIA public (@ 200,000 notice and review procedures each) 4. Printing costs and About 25 copies will be printed for 350,000 1,144 circulation of copies to distribution both at the Federal be used during (FMEnv, FPMU) and State level disclosure at ESMEnv, (SMenv, SMoW, SPIU) across the Enugu Ministry of LGAs covering the 29 roads etc.-The Works & Transport, SPIU will bare responsibilities for and Enugu LGA office logistics costs and implications for circulation of copies to designated disclosure points in the state. 5. Disclosure at the The SPIU will disclose the ESIA/ESMP - - Enugu State Ministry of as required by the Nigeria EIA public Environment notice and review procedures 6. Disclosure at the The SPIU will disclose the ESIA/ESMP - -

16 Please Note: This budget has been prepared for all 6 Lots, and 29 roads selected for the intervention works. The total cost is indicative of approximately NGN 2,000,000 per road, per lot and shall cover for all mitigation, monitoring, capacity building, GRM implementation, disclosure and contingency costs.

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Enugu Ministry of as required by the Nigeria EIA public Works & Transport notice and review procedures (SPIU) office 7. Disclosure at Enugu The purpose will be to inform - - LGA offices stakeholders about the project activities; E&S impacts anticipated and proposed E&S mitigation measures. 8. Disclosure at the World The ESIA will be disclosed according - - Bank Info Shop TOTAL 1,000,000.00 3,268.00 Exchange Rates are based on the Central Bank of Nigeria (CBN) rate of USD 1 to NGN 306

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8 CHAPTER EIGHT: STAKEHOLDER CONSULTATIONS

8.1 Introduction

In this section, consultations with key stakeholders are discussed. A Consultation Strategy was developed in order to achieve the objectives of the screening in a timely manner. The objectives focused on obtaining the views of relevant stakeholders in the project, preliminary identification of potential environmental and social issues relating to all the proposed activities.

Consultation with stakeholders at the project LGAs and communities formed an integral part of the ESIA process. Consultations also influenced the project design to be more environmentally friendly and socially inclusive.

Emphasis was placed on consultations throughout the lifecycle of the project as a means to allay grievances, enhance project positive impacts, mitigate negative impacts, and ensure project buy- in and sustainability.

The following issues were given emphasis and particular attention during the consultation process:

• Provision of sufficient and timely information about the proposed project to the Project Affected Persons (PAPs); • Provision of engagement opportunities to ensure no major potential impacts or probability have been overlooked; • Provision of engagement opportunities for stakeholders to influence project design in a positive manner; • Securing the local and traditional knowledge to inform the ESIA process; • Reduction of conflict through the early identifications of contentious issues and findings; • Creation of a sense of Project ownership or involvement in the minds of stakeholders; • Identification of issues of concern to stakeholders so these can be addressed appropriately before project implementation; and • Effective management of expectations and misconceptions regarding the Project.

8.2 Stakeholders Engagement Plan (SEP)

The following steps were taken for the stakeholders’ engagement plan

a. Identification of Stakeholders b. Prioritization of Stakeholders c. Understanding the Identified Stakeholders and their areas of influence/interest d. Mapping of Stakeholders

The SEP implemented during the ESIA process is outlined below:

Reconnaissance Engagement Database creation of visits to sub- Sessions with issues and concerns projects sites Stakeholders Incorporation of Feedback from feedbacks to sub-projects stakeholders’ owners register

Figure 23: Stakeholders Engagement Plan (SEP) Implementation Process

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8.2.1 How Stakeholders were Categorized and Identified This ESIA categorized stakeholders into primary and secondary categories. Primary stakeholders are those that are directly affected by the adverse impacts of the proposed works (PAPs) and those who are to benefit from use of the feeder roads to be constructed, examples are community members, farmers and transporters. On the other hand, secondary stakeholders are those with some form of interest and influence on the project such as local NGOs and local and state governments, State Ministry of Environment.

Consultations were held in two folds: Stakeholders converged at central venues for community wide consultations and subsequently in smaller common groups. Meeting with common groups such as vulnerable groups and women was helpful in determining the need, voice and concerns that may not have been fully expressed during the general community consultations.

Stakeholders engaged during the ESIA process include:

• Federal Ministries of Environment and Finance, • Traditional and community leaders • Communities along the proposed routes • NGOs and vulnerable groups • Hunters and Vigilante Groups and • Other Agencies whose activities relate to the project.

8.2.2 Fundamentals of Stakeholder Engagement Approach for Implementation

Consultations

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

Consultations with key stakeholders, including project-affected people and civil society, are mandatory in development projects so as to satisfy “best practices”. Consultation methods include public hearings or meetings, focus group discussions, household surveys and interviews, electronic consultations, and advisory/expert groups. In addition, consultations can include informal structures at the local level, such as village councils and women’s groups. Good practice approaches to consultation, including closing the feedback loop, need to be applied more systematically.

Collaboration

Collaboration with stakeholders in decision-making processes and events can make decisions more responsive to stakeholder needs and improve the sustainability of program and project outcomes through increased ownership by stakeholders. Mechanisms for collaboration include stakeholder/user membership in decision-making bodies, integrity pacts, participatory planning and budgeting, and stakeholders’ juries.

Collecting, Recording, and Reporting on Inputs from Stakeholders

Stakeholder feedback can be collected periodically on various dimensions of public services provided, such as effectiveness, inclusiveness, quality, delivery time, transaction costs, and targeting, as well as on resource utilization or engagement processes. Tools include satisfaction surveys, focus group discussions, hotlines, community scorecards, stakeholder report cards, or SMS/online feedback.

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Stakeholders-led Monitoring

Involving stakeholders in monitoring service delivery, revenues, budget execution, procurement, contract awards, and reform policies can increase transparency, improve efficiency of service delivery or budget execution, and reduce opportunities for corruption. Some mechanisms for stakeholders-led monitoring include public expenditure tracking surveys, social audits, or stakeholder report cards.

Additional entry points for stakeholder’s engagement in monitoring include collaboration with local CBOs/NGOs, communities, local academia, or think-tanks in gathering results data and conducting joint evaluations of project results after project completion (including in the preparation of project Implementation Completion Reports).

Capacity Building for Stakeholder Engagement

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

8.3 Public Consultations

The following considerations guided the public consultations:

• Site visit to each of the proposed road route for rehabilitation/construction; • Identification of the administrative leadership in the project areas, and visits to the community leadership • Identification of PAPs and notification of meeting in collaboration with community leaderships • Public forum with stakeholders on the project

8.3.1 Consultation Plan The objectives of the consultation process are to: • Establish and sustain a consultation process for the entire life cycle of the project that shall be aimed at shaping & informing the public of the nature, scope & feedback on the project intervention. • Shape and inform the development of an integrated framework for addressing issues relating to economic displacement triggered by the project. • Build a base for dialogue between the project implementation team and various stakeholders so that implementation of the outcome of the project will continue to benefit from diverse perspectives beyond the life span of this project.

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Table 27: Proposed Stakeholder engagement approach N Activity Identified Focus of Timelines/ Forms of Facilitator o Stakeholders Consultatio Frequency communication n/ Engagemen t Preparation1. of • FMPU Throughout • Focus Group Enugu ESIA • State Project the ESIA study Discussion/worksho RAMP2 Coordinating Large scale period ps Unit forum • Phone calls • Federal • One on one Ministry of Key interview Environment stakeholder • Distribution of • State Ministry s’ pamphlets of interviews • Public meetings Environment • Newspapers/magaz • Community Mapping of ines and community Community interests Based and Organisations concerns • FMF • World Bank Communiti es need to know what the project is all about.

Site2. • SPIU • Informatio Two weeks • Announcements in Enugu preparation • Contractor n prior to village meetings; RAMP2 prior to road • Supervising Disclosure construction • Announcement construction & Engineers at Federal through town criers Federal rehabilitation • Consultant Ministry of Ministry of • FME Environme Environme nt, State nt Ministry of Environme nt and Local Governme nt level. Start3. of road • SPIU • Affected Throughout • Phone calls Enugu construction & • Contractors Communiti the • Newspapers RAMP2 rehabilitation • Supervising es construction • Radios Engineers • Governme period • Pamphlets FMF • Consultant nt Officials • One on One • Suppliers • World WORLD • Businessmen Bank BANK • NGOs/vulnera ble groups • Communities End4. of road • SPIU • Governme Decommissioni • Phone calls Governme construction • Government nt Officials ng phase • Televisions nt Officials and Officials • Affected • Radios rehabilitation • Affected Communiti • Newspapers Enugu Decommissioni Communities es • Emails RAMP2 ng of • World Bank • Pamphlets construction equipment & machinery

Commissioning5. • Government • Governme Prior to • Newspapers Enugu and handing Officials nt Officials operation of • Television RAMP2 over of priority • SPIU • Benefitting the facility • Radio • Beneficiary Communiti

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N Activity Identified Focus of Timelines/ Forms of Facilitator o Stakeholders Consultatio Frequency communication n/ Engagemen t roads Communities es

Operation6. and • Beneficiary • Beneficiary During • One on one Enugu maintenance Communities Communiti operation and • Workshops/FGD RAMP2 of priority es maintenance • Television roads period • Radio

• Enugu RAMP2 • Beneficiary 3 times a • Visits Enugu Communiti week RAMP2 es • Enugu RAMP2 • Beneficiary Fortnightly • Visits • Government Communiti Officials es • Other • Beneficiary 3 times a • Visits Communities Communiti week es • Beneficiary 3 times a • Visits communiti week es • NGOs/CBOs • Beneficiary Once a term • Visits Communiti es • World Bank • Beneficiary Once a term • Visits Enugu communiti RAMP2 es

8.3.2 Implementation of Consultation Plan Pre- construction stage

This stage could involve clearing of vegetation, design measurements and survey. Consultation at this stage will be necessary to inform the community and affected population about the entrance of the construction workers for purpose of security of workers and the community and to also enable people with certain assets along the Right of Way to possibly move them away.

Construction stage

This stage entails actual civil work by use of heavy equipment and labour. Consultation will be needed at this stage to mainstream the participation of the stakeholders including the community and Project Affected Persons in the work implementation.

Operation stage

At this stage, the RAMP construction/rehabilitation work activities would have been completed and in operation. Consultation at this stage may center on maintenance and sustainability of the investment. Feedback from communities directly affected by the RAMP that shall implement these safeguard policies is particularly important. Channels for consultation will include face-to-face meetings, focus groups with project- affected communities and issue-specific topics will continue through the process.

This ESIA recommends that consultation will commence with this safeguards preparation and shall continue, during and after project implementation. The requirements and phasing of consultations are as follows:

• Consultation on the finalization of the ESIA – to include: o Circulation of the draft ESIA for comments to relevant institutions and stakeholders

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o Public disclosure of Final ESIA cleared by World Bank (WB) in-country at designated centers accessible to stakeholders and at the WB info shop prior to appraisal • During the preparation of individual ESMPs/RAPs/ARAPs o PAPs, groups and communities will be consulted and informed about their rights and entitlements with respect to their range of impacts; o Consultation should include census of PAPs; o Cut-off date should be announced to the community at the end of the census exercise to avoid opportunistic entrants into the land; o Consultation of the proponent and implementing government agencies on relevant policy terms such as replacement value, livelihood restoration measures, vulnerable group, etc. • During the Implementation of the ESIAs/ESMPs/RAP/ARAP o PAPs will be informed about the date/schedule of resettlement/compensation; o They should be involved in site selection, screening and planning for land and housing compensation; o PAPs should be notified on the start off time of project implementation to enable them relocate their assets early and without losses. • During audit/monitoring and evaluation of the ESIAs/ESMPs/RAP/ARAP to determine the livelihood restoration performance of the PAPs o PAPs will be consulted to assess the condition of their livelihood prior and after the implementation of ESMPs/RAP. This will take place 6 months after ESMPs/RAP/ARAP or 2 years after ESMPs/RAP implementation.

Based on the stakeholder meetings held, the issues raised and how they were addressed are presented in section 8.4 below while consultation pictures and attendance are presented in Annex 10 respectively.

8.4 Summary of Meetings with Stakeholders

Key stakeholders of the project were identified for consultations and these included stakeholders from the Enugu State Office of the Federal Ministry of Environment (FMEnv), Enugu State Ministry of Environment, Enugu State Ministry of Works & Infrastructure, Enugu State Waste Management Agency (ESWAMA), village heads, local community leaders and women groups in communities along the roads. The vulnerable groups identified include children old people and physically challenged individuals

Generally, stakeholders at all levels (State, LGA, Community) were very pleased with the project and commented on the poor state of the roads which has become a nightmare to the rural communities. However, general concerns raised across board are presented in the tables below.

Table 28: Consultation with communities Date: July 5th, 2019

Location: Onu Ihe Market-Awkunanaw-uno Ogba Ihe Road & Amumkpa- Amaeguelu Road, Uhuogiri- Railway Road Participants: Community Members of Lot 1 roads S/N Stakeholder Concerns Response of PIU/ESIA Consultant Group 1. Community Commencement of road They were assured that they will be engaged members construction and by the contractors during the implementation continual engagement of the project and that the project will during the project commence soon. implementation phase. 2. Community Fear of Road Accidents They were assured that Contractors will erect members as the improved roads caution signs, warning signs and speed limit may lead to reckless signs during and after construction including driving and consequently speed breakers.

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accidents. They also Contractors and drivers will be trained on OHS feared that construction and safety procedures. vehicles and plants may cause accidents within the project communities.

Table 29: Consultation with communities Date: July 5th, 2019

Location: Obeagu-Ugwuaji, Ubahu-Amankanu-Umualor-Nike RD, Oruku Afo Ezza Road Participants: Community Members of Lot 2 roads S/N Stakeholder Concerns raised Response of PIU/ESIA Consultant Group 1. Community Commencement of road They were assured that the project will members construction and commence soon and that they will be provision of employment considered for employment during the project opportunities during implementation phase. project implementation phase. 2. Community Concerns about the dust They were guaranteed that their concern members that would be generated would be mitigated by ensuring wetting of the during the road roads. construction work, especially in the dry season.

3 Community Destruction of people’s This will be addressed by a Resettlement members farms and properties Action Plan (RAP) for subsequent during the project. compensation.

Table 30: Consultation with Communities Date: July 5th, 2019

Location: Onu Ihe Market-Awkunanaw-uno Ogba Ihe Road & Amumkpa- Amaeguelu Road, Uhuogiri- Railway Road Participants: Community Members of Lot 3 roads S/N Stakeholder Concerns raised Response of PIU/ESIA Consultant Group 1. Community Commencement of road They were assured that the project will members construction. commence soon. 2. Women groups Enquiries were put The Team answered that as part of the ESIA, forward to ask if the adequate planning measures would be taken project will affect schools to ensure that it will not affect the pupils and school children. negatively, by regular community consultations to ensure updates on school calendar, which would be aligned with work schedule to prevent closures or disruptions, while also providing adequate mitigation in the ESMP.

3. Community Tampering with Waste SPIU is aware and has been discouraging the members bins during construction, practice. Also, ESMP in this ESIA has provided indiscriminate dumping mitigation to prevent continual reoccurrence. of excavated material and littering of road with soil and debris.

8.5 Outcome of Stakeholder Consultations carried out during ESIA Preparation

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Site visits were carried out in order to undertake physical assessment of the roads in the different Lots (Lot 1 – Lot 6). Fieldwork was carried out from the 2nd - 15th April 2019 and also from 5th June – 13th July 2019 to assess the environmental & social impacts of the project. From 8th – 31st July 2019, additional meetings were held with other vital stakeholders such as the Federal Ministry of Environment, Enugu State Ministry of Environment, Enugu State Waste Management Agency, the manager of the water treatment plan and the village heads of the various communities in the project area. Pictures of consultation meetings are shown below.

Focus Group Discussion at Obeagu- Focused Group Discussion at Oruku Ugwuaji Uhuogiri- Railway Road (lot 4) Afo Ezza Road

Ikem – Umualor – Agbogazi- Nike – Nkplogu-Uvuru-Ukpata-Adaba-Akunyi Road Focus Group Discussion at Ubahu- Amankanu-Umualor-Nike RD Umulokpa-Road

UBA Express Junction Imezi Owa – Abonuzu Road (Ajali Water Works Road) Ako-Nike Community Imeama Ezema Cps Upata Ezema Abonuzu Road

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With Udueme Community Achara Ohodo Community Nkpuru-Orugu Ohodo Community

Ozalla Uwani Community Ekwegbe Community KII at Umuogbo-Agu

Consultations with women groups in KII at Umuegbudu Agu Community Secondary School, Imufu Orie Market, Aguibeje

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Consultations with Enugu State Ministry Nkwo Market Square, Eha Ndi Agu Nweke Edem Ani Market, road of Works & Infrastructure

Consultations with Enugu State Ministry Consultations with Enugu field Consultations with Enugu State Waste of Environment Office of FMEnv Management Authority

Pictures of Consultation Meetings

8. Requests from Stakeholders

The stakeholders made the following requests and recommendations.

• The construction companies should employ youth from the project communities for the required labor. • The project proponents should be considerate in paying compensation to all displaced persons; • The project proponents should consult with other stakeholders like the Water Board, electricity supply companies, and NNPC for their inputs before implementing the project to avoid disruption of other infrastructure and to minimize damaging of the roads after construction in the process of fixing infrastructural utilities, services and facilities. • The project should be able to optimize the utilization of the existing facilities such as burrow pits and quarries if available, to reduce the economic, environmental and social impacts of creating new ones; • Women who are interested should be considered for offices such as site secretaries and record keepers during the construction stage; • Project communities should be sensitized on the effect of STDs HIV/AID and on the need to maintain their cultural values; • Community welfare should be considered by the project proponent to construct amenities e.g., clinics and boreholes for the various communities.

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Vulnerable Groups

Vulnerable groups in the project areas were identified. Consistent with the South-Eastern states of Nigeria, these include:

• Children • Old men and women • Physically challenged individuals

Stakeholders’ Consultation Meetings - Summary of Concerns by community members

S/N Concerns Response 1 Commencement of road construction and They were assured that they will be continual engagement during the project engaged by the contractors during the implementation phase. implementation of the project and that the project will commence soon. 2 Fear of Road Accidents as the improved roads They were assured that Contractors will may lead to reckless driving and consequently erect caution signs, warning signs and accidents. They also feared that construction speed limit signs during and after vehicles and plants may cause accidents within construction including speed breakers. the project communities. Contractors drivers will be trained on OHS and safety procedures 3 Commencement of road construction and They were assured that the project will provision of employment opportunities during commence soon and that they will be project implementation phase. considered for employment during the project implementation phase. 4 Concerns about the dust that would be generated They were guaranteed that their during the road construction work, especially in concern would be mitigated by ensuring the dry season. wetting of the roads.

5 Destruction of people’s farms and properties This will be addressed by a during the project. Resettlement Action Plan (RAP) for subsequent compensation.

6 Enquiries were put forward to ask if the project The Team answered that as part of the will affect schools and school children. ESIA, adequate planning measures would be taken to ensure that it will not affect the pupils negatively, by regular community consultations to ensure updates on school calendar, which would be aligned with work schedule to prevent closures or disruptions, while also providing adequate mitigation in the ESMP.

7 Tampering with Waste bins during construction, SPIU is aware and has been indiscriminate dumping of excavated material discouraging the practice. Also, ESMP in and littering of road with soil and debris. this ESIA has provided mitigation to prevent continual reoccurrence.

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CHAPTER NINE: GRIEVANCE REDRESS MECHANISM (GRM) 9.0 Introduction

Grievance redressed mechanism is an important aspect in projects involving land acquisition, displacement and implementation of civil works. The redress of grievance is important to avoid unnecessary legal delays and cost overrun of the project. Also, this is a forum for people to express their dissatisfaction over compensation. Grievance mechanisms are increasingly important for development projects where ongoing risks or adverse impacts are anticipated. For the proposed subprojects, grievances are likely to arise due to the following:

i) Delay in civil works; ii) Conflict between the Contractors and host community; iii) Unmanaged expectations; iv) Lack of information about the project v) Delay in payment of compensation vi) Inadequate consultations with members of the communities; vii) Losses not identified correctly; viii) Dispute about ownership; ix) Delay in disbursement of assistance and improper distribution of assistance, etc.

To manage these social risks and others, which cannot be foreseen now with a view to ensuring successful project development and implementation, experience has revealed that open dialogue and collaborative grievance resolution represent the best practice. The grievance mechanisms shall at a minimum be targeted at the following:

i) Provide a way to reduce risk for projects, ii) Provide an effective avenue for expressing concerns and achieving remedies for communities; iii) Promote a mutually constructive relationship; iv) Prevent and address community concerns, and v) Assist larger processes that create positive social change.

9. 1 Grievance Redress Committee The main functions of the Committee are:

• Receive grievances from member of the public; especially from communities located along the prioritised phase 2 roads considered for maintenance • Evaluate grievances from affected persons concerning the application to them of the Entitlement Policy; • Recommend to the Social Officer, SPIU as the case may be, solutions to such grievances from affected persons; • Communicate the decisions to the claimants; • Hear appeals from persons, households or groups who, not being affected persons, believe that they are qualified to be recognized as affected persons, to recommend to the SPIU whether such persons should be recognized as affected persons, and to communicate the decision of the SPIU in that regard to the claimants; • Ensure that all notices, forms, and other documentation required by aggrieved persons are made available in Local language understood by people • Made provision for complainants to submit claims without fear of retaliation.

The GRC’s will include: A First Level Grievance Redress Committee (Community Based GRC) shall be constituted for the Community to address complaints and ensure satisfactory resolution of grievances. This committee will comprise persons appointed or selected by the Igwe (or traditional ruler) and the other community stakeholders during consultations with capability of working in the interest of the community in providing necessary support to SPIU and the Contractor, in delivering the objectives of the project. This committee to be headed by the Igwe or traditional ruler shall comprise of:

▪ The Igwe or Traditional Ruler -Chairman ▪ A representative of Council of Elders ▪ A representative of the Community Development Association

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▪ A representative of Youth Organization ▪ Representative of the Women Group ▪ Social Safeguards Officer of the SPIU-Secretary

Complaints shall be received using the following means and media: (1) Written: Use of Complaint box; (2) Electronic: Mobile Application including WhatsApp, Telegram, etc. (3) Oral: Toll-free/hot lines.

NOTE: Grievances at this level will be normally solved within 14 working days. Concerned parties will be notified through a disclosure form. If the grievance is not adequately or satisfactorily resolved, this would be referred to the next level of the grievance redress process.

A Second Level Grievance Redress Committee shall be further constituted to address cases of complaints that are escalated beyond the community based GRC for resolution. The SPIU shall ensure persons selected are willing and committed to serve for the purpose of delivering a successful intervention project and not for personal aggrandizement. These may comprise:

▪ Permanent Secretary, Enugu State Ministry of Lands ▪ Permanent Secretary, Enugu State Ministry of Environment ▪ Project Coordinator, SPIU ▪ Social Safeguards Officer, SPIU

Complaint and grievances brought to the second level are expected to the satisfactorily resolved within 14 days. In any case where no satisfactory solution is reached at the end of the 14 days, the complaint shall be directed to the next level of the redressal process. However, if a solution is being reached, the duration for resolution at this level can be extended to 21 days, beyond which, the case is referred to the next level.

A Third Level Grievance Redress Committee (GRC at the State Technical Committee Level TC-GRC) is setup to address lingering grievances or grievances that are yet to receive satisfactory resolution at the Community-based GRC and SPIU GRC levels. The TC-GRC is facilitated by the State Ministry of Works and Infrastructure. This committee shall comprise of the following:

▪ The Permanent Secretary-Chairman; ▪ Director Ministry of Environment ▪ Director Bureau of Lands & Survey ▪ The Project Coordinator of RAMP 2 ▪ A witnessing NGO

The decisions of the TC-GRC would be final from the Project side and the Complainant may decide to take a legal or any other recourse if he/she is not satisfied with the resolutions due to the deliberations of the Third Level GRC. The Complainant also has the option of approaching the Donor (World Bank), if they find that the established GRM cannot resolve the issue.

Court/Mediation Center for Grievances

The possibility of seeking for grievance resolution in the court may be a last resort and should be expected, especially, where the complainant felt dissatisfied with resolution of the GRC.

The provision of the Resettlement Policy Framework (RPF) for RAMP 2 on this matter is that grievances concerning non-fulfilment of contracts, levels of compensation, or seizure of assets without compensation shall be addressed to the state local courts system of administration of justice. The court hierarchy would in ascending order therefore, be land dispute tribunals/chiefs, followed by magistrate courts and then finally the high courts. The high court of the state is being designated as the highest appellate court to settle grievances.

This, admittedly; is a costly and time-consuming procedure. Nevertheless, affected persons will be exempted from administrative and legal fees incurred pursuant to this grievance redress procedure.

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9.2 Grievance Redress Awareness at Project Communities

At the time that the sub projects intervention contracts are approved, and contracts are signed, communities would be informed of the availability of a process for expressing dissatisfaction and to seek redress. The grievance procedure will be simple and administered as far as possible at the local levels to facilitate access, flexibility and ensure transparency. All the grievances will be channeled via the Grievance redress committees (GRCs) constituted.

This GRM shall be given a wide publicity among stakeholder groups such as affected parties, government agencies, and civil society organizations. Effective awareness of GRM process makes people better understanding about their options, depending on the types of complaints. However, measures should also be taken to encourage stakeholders not to submit false claims. Criteria for eligibility need to be communicated and also awareness campaigns should be launched to give publicity to the roles and functions of the GRM.

9.3 Grievance Redress Process

The overall process of grievance shall take the following way:

▪ During the initial stages of the valuation process, the affected persons are given copies of grievance procedures as a guide on how to handle the grievances; ▪ The process of grievance redress will start with registration of the grievances to be addressed for reference, and to enable progress updates of the cases. ▪ The response time will depend on the issue to be addressed but it should be addressed with efficiency. Nevertheless, Grievance form will be filled by person affected by the sub- project with the Community based Grievance Redress Committee, which will act on it within 7 working days on receipt. If no understanding or amicable solution is reached, or the affected person does not receive a response from the local Grievance Redress Committee within 14 working days, the affected person can appeal to a designated officer in the SPIU (as the 2nd level of the GRC), which should act on the complaint/grievance within 14 working days of its filing. ▪ The appeals process will use a local mechanism, which includes peers and local leaders of the affected people. These will ensure equity across cases; they eliminate nuisance claims and satisfy legitimate claimants at low cost. ▪ Compensation will be paid to individual PAPs where applicable (and upon the amendment of the RAP) only after a written consent of the PAPs, including both husband and wife has been received by the Committee ▪ All reasonable moves shall be made to settle any grievance that arises, amicably. If affected person is not satisfied with the decision received, he/she can, as a last resort, appeal to a court of competent jurisdiction. Affected persons will be exempted from all administrative and legal fees incurred pursuant to grievance redress procedures. ▪ If discussions break down at this stage, or the grievance remains unresolved, the matter would be escalated to the GRC of the FPMU. All the grievances will be channeled via the Grievance redress committees (GRCs) constituted. This is depicted in flow chart Figure 24 below.

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Complainant report Community GRC (Oral/Written/Electronic) (1st Level)

Site/Community Level

Case Grievance Unresolved passed to 2nd Level GRC in 7 days

Enugu SPIU GRC

(2nd Level)

Case passed to GRC in 14 days Grievance Unresolved

InstitutionCollaborating State Technical GRC

Arbitration

Complainant Unsatisfied case passed to GRC in

21 days

Enugu Citizen’s Mediation Level Center

Law Court

Figure 24: Flow Chart Depiction of Enugu RAMP-2 Project based GRM Process

9.4 Expectation When Grievances Arise In instances when the local people in the communities located along these priority roads selected for intervention present a grievance, they would generally expect to receive one or more of the following:

• acknowledgement of their problem; • an honest response to questions/issues brought forward; • an apology; • adequate compensation; • modification of the conduct that caused the grievance; and some other fair remedies.

In expressing their concerns, complainants also expect to be heard and taken seriously. Therefore, the contractors, or government officials must convince people that they can detail their challenges and work to resolve them without retaliation or negative backlash.

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9.5 Grievance Log A grievance log will be established by the project and copies of the records kept with all the relevant authorities. A review of grievances will be conducted at least once in every three months during implementation in order to detect and correct systemic problems.

The SPIU Social Safeguards Officer will ensure that each complaint has an individual reference number which is appropriately tracked, and recorded actions are completed. The log also contains a record of the person responsible for an individual complaint, and records dates for the following events:

• Date the complaint was reported. • Date the Grievance Log was uploaded onto the project database. • Date the information on proposed corrective action sent to complaint. • The date the complaint was closed out. • Date response was sent to complainant. • Monitoring Complaints

Table 31: Typical Reporting format for Grievance Redress Community Type of Grievance Grievance Resolution

project & Name of

Complainant

Affected, but but Affected, informed not impacts about options and Compensation is awarded inadequate Compensation paid not assets before acquisition Resettlement benefits are awarded provided not other of Date complaint received Date Pending referred Case Court to the Community Project 1

Complainant A

Complainant B

Complainant C

Community Project 2

Complainant D

Complainant E

TOTAL

9.6 Monitoring Complaints

The Social Safeguard Officer will be responsible for:

▪ Providing the grievance committee with a weekly report detailing the number and status of complaints ▪ Outstanding issues to be addressed ▪ Monthly reports, including analysis of the type of complaints, levels of complaints, actions to reduce complaints and initiator of such action.

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10 CHAPTER TEN: RECOMMENDATIONS

The recommendations below have been provided for the proposed project.

• Considering that over two-thirds (2/3) of the roads to be rehabilitated in Enugu State are either affected by flooding or erosion to some degree, it is best practice to manage the root-causes of the erosion and flood occurrences, especially if they are due to topographical or engineering defects. Roads prone to or affected by flooding and erosion will require adequate attention from the Enugu State government and the Enugu SPIU. Decision making as regards most suitable, environmentally sound and cost-effective hydraulic controls in flood plains is critical. Decision makers need to weigh the pros and cons associated with resistance and resilience flood control strategies so as to ensure long- term viability of proposed rehabilitation and construction works. • Where possible, options of avoidance of impacts resulting to physical and economic displacement should be promoted rather than seeking compensation and resettlement. Nonetheless, in situations where compensations are inevitable, the requirements of the World Bank Operation Policy 4.12 should be adhered to. Additionally, as informed by the SPIU, in situations where social features and structures, especially in built-up areas may prevent keeping to the proposed road width and designs, the SPIU should aim at embarking on any rehabilitation works such that they are within the available17 dimensions of the road-section of concern. • Improved transportation is a definite, foreseeable benefit of the proposed intervention works. With this in view, the Enugu SPIU should engage local communities on road safety and transportation safety awareness and sensitization programs. The SPIU should also collaborate with the state traffic management agencies, as well as local security agencies. • The implementation of rural roads development should involve public hearings and participation and a well-established community relation to create a sense of ownership of the project by the communities and to make the projects successful and sustainable. The project shall ensure compliance with, and implementation of the Environmental and Social Management Plan (ESMP). • For temporary relocation of electric poles, the SPIU must effectively ensure that there is collaboration and guidance provided by the Ministry of Works and EEDC in selecting alternative sites during the pre-construction and construction phases. • The SPIU should effectively key-into the existing GBV services available in the State. Women and children are likely to suffer GBV and VAC in project related matters. Gender mainstreaming is thus important and should be given high consideration by the SPIU. • Subsequently, labour influx is likely to aggravate GBV, SEA and VAC issues. Contractors must prepare and sign all levels of CoCs requested and present a C-ESMP that specifically addresses the aforementioned. The submission and acceptance of the C-ESMP is a mandatory process, essential prior to the commencement of any form of civil works. • For Physical and Cultural aspects which may be impacted on; the SPIU and its Contractors should have effective collaboration and liaison with the communities. Furthermore, “Chance Find Procedures” must be adhered to and compliance monitored.

17 Social features along the roads vary, such that some property and other structures have encroached into the existing roads and thus may make it difficult for the proposed road dimensions according to the engineering designs to be followed through. In such cases, the SPIU has decided that the Contractor should make use of the available road width so as to avoid issues of physical and economic displacement, resettlement or compensation.

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REFERENCES

DFID (2000) Achieving sustainability: Poverty reduction and the environment DFID policy paper

DFID 2002 Making connections: Infrastructure for poverty Reduction consultation document London: DFID.

Emea, O. A. and Eugene, C. O. (1997). Multidimensional analysis of land tenure systems in eastern Nigeria.

FEPA (1991): National Environmental Protection (effluent Limitation) Regulations. Federal Environmental Protection Agency, Nigeria.

IFC performance Standards on Environmental and Social Sustainability, World Bank (2012).

Igbokwe, et al. (2008): Mapping and Monitoring the Impact of Gully Erosion in South-Eastern Nigeria with Satellite Remote Sensing and Spatial Information Science. In: Intl. Archives of Photog. Remote Sensing and Spatial Information Sciences. vol. 37, Part B, pp. 865-71, Beijing. China

Mackworth-Praed, C.W., & Grant, C.H.B. (1970-1973). African Handbook of Bird Series, Series III. Birds of West Central and Western Africa.2 Vols. Longman, London.

Norwegian Refugee Council (NRC) (2009): Climate changed: people displaced. Report No.3 Nwajide, S.C. and Hoque, M. (1979): Gullying processes in south-eastern Nigeria. In: The Nigerian Field Journal. 44(2), 64-74

Ofomata, G.E.K. (2002): Soils and soil erosion. In: Ofomata, G.E.K(Ed): A survey of the Igbo nation. Africana First Publishers Ltd, . pp 99-116.

Rural Access and Mobility Project 2, (2012), Environmental and Social Management Framework

Rural Access and Mobility Project 2, (2012), Project Appraisal Document

Rural Access and Mobility Project 2, (2012), Project Implementation Manual

Rural Access and Mobility Project 2, (2012), Revised Environmental and Social Impact Assessment (ESIA) report

Rural Access and Mobility Project 2, (2012), Resettlement Policy Framework (RPF)

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ANNEXES

ANNEX 1: Terms of Reference

Terms of Reference

1. INTRODUCTION

1.1. The Second Rural Access and Mobility Project (RAMP-2) support the implementation of the Federal Government of Nigeria’s Rural Travel and Transport Policy (RTTP) in the States of Adamawa, Enugu, Niger, and Osun. The Project is implemented in each of the four States by the respective State Project Implementation Unit (SPIU). In addition to the states’ counterpart funds, the Project is co-financed by the World Bank and French Development Agency. 1.2. The main objective of the Project is to improve transport conditions and bring sustained access to the rural population, through rehabilitating and maintaining key rural transport infrastructure in a sustainable manner in the selected Nigerian states. 1.3. Enugu State being one of the RAMP-2 participating States has already initiated, under a first phase of RAMP-2, the rehabilitation/reconstruction of 115.36km of rural roads.

2. GOAL OF THE ASSIGNMENT

The project has triggered four environmental and social safeguards policies namely: Environmental Assessment OP/BP 4.01, Natural Habitats OP/BP 4.04, Physical Cultural Resources OP/BP 4.11 and Involuntary Resettlement OP/BP 4.12. The project has been assigned an Environmental Assessment (EA) Screening Category “B”. This rating is based on the scope of the project, which indicates limited adverse environmental and social impacts. It is expected that no adverse negative impacts are likely during project implementation; especially as the project does not contemplate constructing new roads and will essentially remain within the existing right-of-way.

Enugu State now intends to engage the services of a Consultant, with satisfactory experience on assignments similar in size and nature to that described in this Terms of Reference, to carry out the environmental and social impact assessment of the rehabilitation of approximately 480km of rural roads across the State, under a second phase, as described in these Terms of Reference.

The goal of the assignment is to manage the social and environmental risks and impact sustainably by an assessment of the social and environmental impact and developing the social and environmental instruments for managing the impacts.

2.1. The scope of civil works to be carried out includes rehabilitated/construction of rural roads on existing alignments as well as realigned portions where required. The roads have mostly low volumes of traffic (i.e. less than 250 AADT). The works generally include: site clearance; earthworks; provision of sub-base; provision of lateritic base course (generally as surfacing); limited quantities of Lateritic Base Course (LBC); trapezoidal earth side drains; with turnouts/off-shoots; lined side drains; single and multiple 900 mm concrete pipe culvert extensions and new culverts; reinforced concrete box culverts; possibly reinforced concrete bridges on bored piles; and road signs and other road furniture. The Works contract also includes for traffic management, and strict social and environmental measures, which shall also be supervised.

3. OBJECTIVES of the Services

The specific objective of the study will be to assess the potential environmental and social risks and impacts of the proposed works as described below in the scope of work and prepare an Environmental and Social Impact Assessment (ESIA) that will include a detailed Environmental and Social Management Plan (ESMP). The ESIA will outline the main procedures and responsibilities to manage environmental and social risks and impacts associated with the implementation of civil

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works. The study will be carried out to establish modalities of implementing the projects in line with Nigeria environmental and social policies and laws and the World Bank Safeguard policies.

All work undertaken and output produced must comply with:

• World Bank safeguard policies, while taking into consideration the environmental and social procedures of the Federal Government of Nigeria and respective State Governments. • World Bank guidance and structure provided on ESIA and ESMP.

4. Scope of Works for the Environmental and Social Impact Assessment

The principal duties and responsibilities of the Consultant in respect to the Engineering designs and feasibility studies are, but not limited to:

i. Review the existing ESMF prepared for the RAMP. ii. Review Environmental Safeguards policies of the World Bank safeguards policies triggered on the project; iii. Describe the proposed project by providing a synthetic description of the project relevant components and presenting plans, schematics, maps, figures and tables of the project area of influence iv. Identify the policy, legal and administrative framework relevant to the project. v. Define and justify the project study area for the assessment of environmental and social impacts. vi. Describe and evaluate the current environmental and social situation; vii. The following socio-economic issues shall be addressed in the ESIA: viii. Establish social baseline information before project intervention ix. Determine the project’s social impacts on health and social well-being; quality of the living environment; economic material well-being; Family and community; and gender relations x. A summary of the impacted communities for the project: location, access, population (number, demographic and social characteristics); economy (employment rate, income distribution); land use and land tenure; services (types, capacity, and adequacy) and housing. xi. The report should identify and assess social impact identified during the public consultation process and those that, based on consultant’s experience, are also likely to occur. In some instances, the affected communities may not be aware of or be in a position to identify all the social impact that may occur. However, this does not mean that they will not occur. In such cases the consultant should use his/her experience to identify additional social impact that have not been raised by the public. A summary of the views of the population including vulnerable groups, determined through thoroughly documented discussions with local communities. These meetings and discussions must be documented and should show how issues and problems raised are or will be resolved.18 xii. Pay attention to the impacts of the project on people and groups in a situation of vulnerability (including but not limited to people with disabilities) xiii. Detail measures that will need to be taken to mitigate the negative social impact identified and the procedures for their implementation; xiv. Identify key uncertainties and risks: Identify and communicate any key uncertainties and risks associated with the accuracy of the findings of the social assessment, as well as of

18 In terms of GBV, there should be absolutely no data collection related to GBV with anyone who may be a survivor without making referral services available to support them. If data collection is necessary, Task Teams should confirm that protocols are in place to enable referral of participants disclosing experiences of violence before data collection commences to avoid retraumatizing survivors. Training of researchers must cover all safety and ethical guidelines related to GBV. No focus group discussions with community members asking about personal experiences of GBV should be undertaken. For ethical guidelines on GBV see https://www.who.int/reproductivehealth/publications/violence/9241546476/en/

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the proposed project. Some sources of uncertainty and risk commonly associated with projects are linked to: (a) Lack of adequate information at the community level; (b) Creation of employment and business opportunities for members from the local, historically disadvantaged communities; (c) The influx of job seekers and construction workers to the area and the impact on services; etc. xv. Assess the impact of the construction on individuals and groups whose livelihoods are tied to the route/road (motor cycle taxi and tricycle operators etc.). As part of consultations, the ESIA should identify the potential negative impact on the livelihoods of these individuals and groups and propose appropriate mitigation measures xvi. Assess potential impact of the project on property access and suggest measures to minimize the effects on property access xvii. Information will be gathered from field surveys and secondary data sources (interviews, structured questionnaires, in-depth interviews and focus group discussions). xviii. Identify the preliminary ‘social area of influence’ of the project, likely impacted and beneficiary communities (nearby and distant), and stakeholders. xix. Through analysis, determine the environmental and social changes and impacts that will likely result from the project and its various alternatives. xx. Consider how the project will contribute to the cumulative impacts being experienced by the host communities. xxi. Assist the proponent in facilitating stakeholder input and drafting a Social Impact Management Plan (SIMP) which puts into operation the benefits, mitigation measures, monitoring arrangements and governance arrangements as well as plans for dealing with any ongoing unanticipated issues as they may arise. xxii. Put processes in place to enable proponents, government authorities and civil society stakeholders to implement the arrangements implied in the SIMP, establish respective roles and responsibilities throughout the implementation of those action plans, and maintain an ongoing role in monitoring. xxiii. Describe and analyse the physical, biological and human environment conditions in the study area before project implementation, and describe how these may be affected by the project either positively or negatively. This analysis shall include the interrelations between environmental and social components and the importance that the society and local populations attach to these components, to identify the environmental and social components of high value or presenting a particular interest. xxiv. The following biophysical issues shall be taken into consideration; Climate, Air and Noise, Topography, Surface Water Quality, Ground Water Quality, Storm Water runoff, drainage pattern and aquifer characteristics, Soil, biological aspects: flora and fauna, endemic and endangered species. xxv. Sampling of relevant biophysical parameters within the project area of influence including air, noise, water and soil using in-situ and laboratory analysis as appropriate. Discuss the results and its implications for the project. Sampling should be done in an accredited Federal Ministry of Environment Laboratory. xxvi. Outline environmental sensitivities that may affect the project and propose recommended change to project design as required xxvii. Present and analyse alternatives to the proposed project, including the “without project” option, by identifying and comparing the alternatives on the basis of technical, economic, environmental and social criteria. xxviii. For the selected alternative, identifying and assessing potential importance of beneficial and adverse environmental and social, direct and indirect, short and long-term, temporary and permanent impacts, based on a rigorous method. xxix. Present the potential environmental and social risks and impacts of the proposed project xxx. Define appropriate mitigation/enhancement measures to prevent, minimise, mitigate, or compensate for adverse environmental and social impacts or to enhance the project environmental and social benefits, including responsibilities and associated costs.

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xxxi. Address potential cumulative environmental and social effects taking into account other initiatives planned in the study area. xxxii. Develop an environmental and social monitoring program, including indicators, institutional responsibilities and associated costs. xxxiii. As appropriate, prepare an occupational/community health and safety plan including an analysis of the risk of accident, the identification of appropriate security measures and the development of a preliminary contingency plan. xxxiv. Assess the capacity available to implement the proposed mitigation measures and identify institutional responsibilities and needs for capacity building if necessary, to implement the recommendations of the environmental and social assessment and associated costs xxxv. Carry out consultations with primary and secondary stakeholders in order to obtain their views on and preoccupations about the project. These consultations shall occur during the preparation of the ESIA Report to identify key environmental and social issues and impacts, and after completion of the draft ESIA Report to obtain comments from stakeholders on the proposed mitigation/enhancement measures. xxxvi. Assess the risk of Sexual Exploitation and Abuse associated with the project and provide mitigation measures. xxxvii. For ESIAs to capture the socio-economic, cultural and risk context for women. The following should be considered: xxxviii. Existing gender country diagnostics/country action plans; xxxix. Data on partner/non-partner physical violence against women; xl. Data and/or information on cultural practices vis-à-vis women (early marriage, physical practices); xli. Existing services available from GBV Services Providers; xlii. Where health centres are located and what types of services are offered (e.g., whether they treat sexually transmitted diseases, provide reproductive health services, have supplies of rape kits including post-exposure prophylactics and emergency contraception, etc.); xliii. Whether women have easy access to these services, and if they have mobility and/or economic constraints that may impede access; and, xliv. Information obtained from consultations carried out in the preparation of the project. xlv. Assess labour influx risk and develop a Labour Influx, Sexual Exploitation and Abuse, and Occupational Health and Safety Response Plan xlvi. Prepare an Environmental and Social Management Plan (ESMP). The ESMP should capture: • The potential environmental and social impacts resulting from project activities • The proposed mitigation measures; • The institutional responsibilities for implementation; • The monitoring indicators; • The institutional responsibilities for monitoring and implementation of mitigation measures; • The estimated costs of activities; and • A calendar for implementation.

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ANNEX 2: LIST OF PERSONS MET DURING ESIA STUDY

S/N NAME Position Community Phone Number

1 Mr Jude Okye Community Umuoye Village 07075211772 Member

2 Utaka Patrick Community Umulumgbe 07031526944 Member

3 Mr Nze Oliver Udeh Community Udi 07036572366 Member

4 Mrs Nneka Nze Community Amansiodo 08030514212 Member

5 Egwu Cynthia Community Amansiodo 08183339469 Member

6 Mr Simon Nnameani Community Amachara 08136439821 Member

7 Mrs Obasi Jesd Community Ezema 07038705109 Member

8 Clementina Owakwe Community UBA Express N/A Member

9 Godwin Micheal Community UBA Express 07012269291 Member

10 Famella Chigbo Community UBA Express 080868888378 Member

11 Chintdu Amarachi Ofor Community Ezeagwu 09030276548 Member

12 Ani Agbogogo Community Oye Market 08030882230 Member

13 Igwe Chigoba Community Oye Market 08107073835 Member

14 Nwadi Celetine Community Agbagugu N/A Member

15 Okeke Community Agbagugu 08067696008 Member

16 Nwangwu Uchenna Community Agbagugu 08037356829 Member

17 Reginal Adaeze Community Ndvagu N/A Member

18 Romanus Ude Community Ezema Owa 07061205796 Member

19 Andeke David Community Nddolu 07064924280 Member

20 Mrs Chukwu Chineye Community Obinotia Unduno 08030445666 Member

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21 Thomas Nwelu Community Ozalla 07031609715 Member

22 Ezeugwu Obooma Community Aku 08154277604 Member

23 Okwu Chioma Community Aku 0814945628 Member

24 Eze Ujunwa Community Ekwegbe 08033060144 Member

25 Agbeze Ngozika Community Umuna 07065403754 Member

26 Fadelis Enu Community Ozalla 07061680795 Member

27 Eze Chikamso Community Ozalla 08038646004 Member

28 Ugwu Ifeanyi Community Ohodo 08072957802 Member

29 Asogwa Chidima Community Ohodo 08165294224 Member

30 Okuo Chinyere Community N/A Member Ohebedim

31 Okwa Collins Community Umuna 08136085737 Member

32 Eze Juliet Community Umuna 09031655955 Member

33 Ezeamongu Wialliam Amobi Community Aku Igbo Etiti 08060441261 Member

34 Ezea Cynthia Chiemerie Community Aku Igbo Etiti 08159006548 Member

35 Ikechukwu Uwawze Community Aku Oseh 07051538072 Member

36 Igwe Community Okado 08037792087 Leader

37 Madam Rose B. Community Nnyia 07036024219 Member

38 Chibueze Community Aku Oseh 080865825739 Member

39 Mrs Mgbo Community Aku Oseh 070644834417 Member

40 Mrs Agu Community Aku Oseh 07060847131 Member

41 Ogbu Ignatius Oz Community Nkeriffi-Ebonyi 08170949454 Member

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42 Presidential General Community Umuika Village N/A Member

43 Comrade Nwigioe Community Umuika Village 08063574783 Leader

44 Onu Sunday Community Umuika Village 08038377394 Member

45 Engr Owo Obinna Community Umuika Village 08061683818 Member

46 Ifeoma Ugwuozo Community Umulumgbe 09063959588 Member

47 Augustine Mbaeye Community Umulumgbe 08039665596 Member

48 Eethel Ozoh Community Umulumgbe 07033798741 Member

49 Ngwu Joseph Community Umulumgbe 07060646843 Member

50 Franklin Asogide Community Umulumgbe 08089563750 Member

51 Aghius Ndumi Community Umulumgbe 07017720151 Member

52 Oluchi Achigigde Community Umulumgbe 07089619268 Member

53 Ugwuani Chibueze Community Umulumgbe 07062231703 Member

54 Attamah Joy Community Umulumgbe 08086299078 Member

55 Mama Ukamaka Community Umulumgbe 08131696871 Member

56 Otti Emmanuel Community Umulumgbe 07064772821 Member

57 Ugwuke Hanison Community Umulumgbe 07080868485 Member

58 Ifeoma Enyi Community Umulumgbe 09065594382 Member

59 Obe Chikaochili Community Umulumgbe 08034668164 Member

60 Agu Ifeanyi Community Umulumgbe 07062496957 Member

61 Omeh Udoka Community Umulumgbe 09026293370 Member

62 Ozota Harrison Community Umulumgbe 08164363574 Member

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63 Ayaka Chukwuereka Community Aku-Odume 07033474238 Member

64 Ezeorah Fidelis Community Aku-Odume 08106655964 Member

65 Ikechukwu Ik Community Aku-Odume 08085651609 Member

66 Omeja Nnaemeka Community Aku-Odume 09069703194 Member

67 Ezeagu Chijioke Community Aku-Odume 08106440198 Member

68 Ochu Amadaeze Community Aku-Odume 08124402001 Member

69 Omeife Shedrack Community Aku-Odume 08151268055 Member

70 Ozor Ejike Community Aku-Odume 08136135382 Member

71 Ejima Fidelis Community Aku-Odume 09066305609 Member

72 Micheal Iyioke Community Omoro Village 08148408740 Member

73 Alpeyius Iyioke Community Omoro Village 07081371651 Member

74 Sunday Samson Community Omoro Village 07062164142 Member

75 Nwonu Joseph Community Omoro Village 07039877031 Member

76 Chibueze Nwaechukwu Community Omoro Village 08140764771 Member

77 Chief Clement Community Omoro Village 08152011919 Member

78 Chukuma Nwamgbowo Community Eke Ogbaku 07082233992 Member

79 Mr Pius Nwamgbowo Community Eke Ogbaku 07062974260 Member

80 Chief Ndeinya Anthony Community Eke Ogbaku 08164071568 Member

81 Stiphen Dibia Community Eke Ogbaku N/A Member

82 Ogbuefi Ekpete Community Eke Ogbaku 08034113977 Member

83 Lawrence Ogbu Community Eke Ogbaku N/A Member

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84 Millicent Ikenna Community Eke Ogbaku 08163295040 Member

85 Engr.Hon.Geoffrey Ozor Community Amankwo Ndugwu 08033448671 Member

86 Emeka Ojiogu Community Amankwo Ndugwu 08033185800 Member

87 HRH. Igwe F.O Okafor Community Umuaji Agbuogu 08037617505 Leader

88 Ezi I of Eziowa Community Umuaji Agbuogu 08086668833 Leader

89 Christian Okeke Community Umuaji Agbuogu N/A Member

90 Ikenna Annichebe Community Umuaji Agbuogu 08030831301 Member

91 Chief Chukwedi Eziowa Community Umuaji Agbuogu 08033205222 Leader

92 Robert Enginwa Community Umuaji Agbuogu 07062782833 Member

93 Chief C.Y Okonta Community Umuaji Agbuogu 08173934264 Leader

94 Mrs Chikwelu Grace Community Umuaji Agbuogu 08068113603 Member

95 Afam Efuna Community Umuaji Agbuogu 08068708601 Member

96 Anselem Okonkwo Community Umuaji Agbuogu 07033211040 Member

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ANNEX 3: QUESTIONNAIRE SAMPLE

RURAL ACCESS AND MOBILITY PROJECT (RAMP-2)

Questionnaire for the Preparation of Environmental and Social Management for RAMP2 Projects in Enugu State

Preamble:

The Federal Project Management Unit (FPMU) of the Federal Ministry of Agricultural and Rural Development (FMA&RD) wishes to carry out the rehabilitation/Maintenance of 270.059km of rural roads in Enugu State under the second Rural Access and Mobility Project (RAMP-2).

This questionnaire, which is expected to take about 20 minutes to complete, is aimed at eliciting your view/opinion on the social and environmental implications of the RAMP2 project activities in your community. Your input would assist in the preparation of an Environmental and Social Management Plan (ESMP) that would enable the RAMP-FPMU to manage the various project activities in a manner that guarantees socio-environmental sustainability of the project.

My name is ………………………………………………………………………………………………..

………………………………………………………………………………………………………………………………………………………………… …………………………………………………………..

DATE:……………………………Questionnaire No……………………

Community:……………………………………………….

LGA:………………………………………………………………………GPS Location:………………..

Please simply tick (x) or write in brief detail where appropriate

SECTION A: BIO-DATA

Name: ……………………………………………………………………………………………………..

Phone Number: ………………………………………………………………………………………………………

Address (optional): ………………………………………………………………………………………………………

Age (years): ˂18 18-30 30-50 50-70 above 70

Sex: Male Female

What is your religion: Christian Muslim Pagan traditionalist others

Marital Status: Single Married Separated/Divorcee

No. of children: Non 1-2 3-4 5-6 above

Level of education: ( ) No formal educ. ( ) Primary ( ) Secondary ( ) Tertiary ( ) others (specify) …………………………………………………………….

What do you do for a living (your primary occupation/nature of business)?

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( ) Self-employed ( ) fisherman ( ) hunter ( ) public sector ( ) others (specify)………………………………………………

11. How long have you been resident in this community?

( ) Since birth ( ) above 15 years ( ) 10 – 15 years ( ) 5 – 10 years ( ) below 5 years

12. What are the transportation means to this community?

( ) Car/bus ( ) motorcycle ( ) bicycle ( ) lorry ( ) others

SECTION B

11. What is your general opinion of this road Maintenance /rehabilitation project?

………………………………………………………………………………………………………

12. How do you think the project will affect the community? How will it affect the individual families?

………………………………………………………………………………………………………

Please explain the benefits or negative impacts of this project in the community?

………………………………………………………………………………………………….

How do you seek redress when there is a grievance among people in this community?

…………………………………………………………………………………………………

Can you let us know how much you earn in a day/month?

………………………………………………………………………………………………………

How far or how close is the nearest market?

………………………………………………………………………………………………………

Please describe the leadership structure in this community

………………………………………………………………………………………………………

Please describe the health care facilities in this village. Where is the nearest hospital located?

……………………………………………………………………………………………………..

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ANNEX 4: CODE OF CONDUCT ON GBV, SEA AND VAC

CONTRACTOR’S CODE OF CONDUCT

Our company, ______is obliged to create and maintain an environment, which prevents Gender Based Violence (GBV) and Sexual Exploitation & Abuse (SEA) issues. The company is also required to maintain an environment where the unacceptability of GBV and actions against children are clearly communicated to all those involved in the project. In order to prevent GBV and SEA, the following core principles and minimum standards of behaviour will apply to all employees without exception: 1. GBV/SEA constitutes acts of gross misconduct and are therefore grounds for sanctions, penalties and/or termination of employment. All forms of GBV/SEA including grooming are unacceptable, be it on the work site, the work site surroundings, project neighborhoods or at worker’s camps. Prosecution of those who commit GBV or SEA will be followed.

2. Treat women, children (persons under the age of 18), and men with respect regardless of race, colour, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status.

3. Do not use inappropriate language or behaviour towards women, children and men. This includes harassing, abusive, sexually provocative, derogatory, demeaning or culturally inappropriate words, gestures or actions.

4. Sexual activity with children under 18—including through digital media—is prohibited. Mistaken belief regarding the age of a child and consent from the child is not a defense.

5. Sexual favours or other forms of humiliating, degrading or exploitative behaviour are prohibited.

6. Sexual interactions between contractor’s and consultant’s employees at any level and member of the communities surrounding the work place that are not agreed to with full consent by all parties involved in the sexual act are prohibited. This includes relationships involving the withholding/promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex – such sexual activity is considered “non-consensual” within the scope of this Code.

7. All employees are required to attend an induction-training course prior to commencing work on site to ensure they are familiar with the GBV/SEA Code of Conduct.

8. All employees must attend a mandatory training course once a month for the duration of the contract starting from the first induction training prior to commencement of work to reinforce the understanding of the institutional GBV and SEA Code of Conduct.

9. All employees will be required to sign an individual Code of Conduct confirming their agreement to support GBV and SEA activities.

I do hereby acknowledge that I have read the foregoing Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to GBV and SEA. I understand that any action inconsistent with this Code of Conduct or failure to take action mandated by this Code of Conduct may result in disciplinary action.

FOR THE COMPANY

Signed by ______

Title: ______Date: ______

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MANAGER’S CODE OF CONDUCT

Managers at all levels have particular responsibilities to create and maintain an environment that prevents GBV and SEA. They need to support and promote the implementation of the Company Codes of Conduct. To that end, Project Managers are required to sign up to Codes of Conduct applicable to their managerial duties within the context and also sign the Individual Codes of Conduct. This commits them to support and develop systems that facilitate the implementation of this action plan and maintain a GBV-free, child-safe and conflict-free work environment. These responsibilities include but are not limited to:

Mobilization 1. Establish a GBV/SEA Compliance Team from the contractor and consultant’s staff to write an Action Plan that will implement the GBV and SEA Codes of Conduct.

2. The Action Plan shall, as a minimum, include the

i. Standard Reporting Procedure to report GBV and SEA issues through the project Griev- ance Redress Mechanism (GRM); ii. Accountability Measures to protect confidentiality of all involved; and, iii. Response Protocol applicable to GBV survivors/survivors (including access to support coping and post-trauma management strategies) and perpetrators. iv. Engagement of the services of social service providers (NGOs) with requisite skill in the prevention and management of GBV and SEA.

3. Coordinate and monitor the development of the Action Plan and submit for review to the RAMP-PIU safeguards teams, as well as the World Bank prior to mobilization. 4. Update the Action Plan to reflect feedback and ensure the Action Plan is carried out in its entirety. 5. Provide appropriate resources and training opportunities for capacity building so members of the compliance team will feel confident in performing their duties. Participation in the Compliance tame will be recognized in employee’s scope of work and performance evaluations. 6. Ensure that contractor, consultant and client staff are familiar with the RAMP GRM and that they can use it to anonymously report concerns over GBV and SEA. 7. Hold quarterly update meetings with the compliance team to discuss ways to strengthen resources and GBV/SEA support for employees and community members. 8. In compliance with applicable laws and to the best of your abilities, prevent perpetrators of sexual exploitation and abuse from being hired, re-hired or deployed. Use background and criminal reference checks for all employees. 9. Ensure that when engaging in partnership, sub-grant or sub-recipient agreements, these agreements a) Incorporate this Code of Conduct as an attachment; b) Include the appropriate language requiring such contracting entities and individuals, and their employees and volunteers to comply with this Code of Conduct; and c) Expressly state that the failure of those entities or individuals, as appropriate, to take preventive measures against GBV and SEA, to investigate allegations thereof, or to take corrective actions when GBV/SEA has occurred, shall constitute grounds for sanctions and penalties.

Training 1. All managers are required to attend an induction manager-training course prior to commencing work on site to ensure that they are familiar with their roles and responsibilities in upholding the GBV/SEA Codes of Conduct.

2. Provide time during work hours to ensure that direct recruits attend the mandatory induction training, which covers GBV/SEA training required of all employees prior to commencing work on site.

3. Managers are required to attend and assist with the NGO-facilitated monthly training courses for all employees. Managers will be required to introduce the trainings and announce results of consequential evaluations.

4. Collect satisfaction surveys to evaluate training experiences and provide advice on improving the effectiveness of training.

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Prevention 1. All managers and employees shall receive a clear written statement of the company’s requirements with regards to preventing GBV/SEA in addition to the training.

2. Managers must verbally and in writing explain the company and individual codes of conduct to all direct recruits.

3. All managers and employees must sign the individual ‘Code of Conduct for GBV and SEA, including acknowledgment that they have read and agree with the code of conduct.

4. To ensure maximum effectiveness of the Codes of Conduct, managers are required to prominently display the Company and Individual Codes of Conduct in clear view in public areas of the workspace. Examples of areas include waiting, rest and lobby areas of sites, canteen areas, health clinics.

5. Managers will explain the GRM process to all employees and encourage them to report suspected or actual GBV/SEA

6. Mangers should also promote internal sensitization initiatives (e.g. workshops, campaigns, on- site demonstrations etc.) throughout the entire duration of their appointment in collaboration with the compliance team, service providers and in accordance to the Action Plan.

7. Managers must provide support and resources to the compliance tea and service provider NGOs to create and disseminate the internal sensitization initiatives through the Awareness- raising strategy under the Action Plan.

Response 1. Managers will be required to provide input, final decisions and sign off on the Standard Reporting Procedures and Response Protocol developed by the compliance team as part of the Action Plan.

2. Once signed off, managers will uphold the Accountability Measures set forth in the Action Plan to maintain the confidentiality of all employees who report or (allegedly) perpetrate incidences of GBV/SEA (unless a breach of confidentiality is required to protect persons or property from serious harm or where required by law).

3. Once a sanction has been determined, the relevant manager(s) is/are expected to be personally responsible for ensuring that the measure is effectively enforced, within a maximum timeframe of 14 days from the date on which the decision was made.

4. Managers failing to comply with such provision can be in turn subject to disciplinary measures, to be determined and enacted by the company’s CEO, Managing Director or equivalent highest-ranking manager. Those measures may include:

i. Informal warning ii. Formal warning iii. Additional Training iv. Loss of up to one week’s salary. v. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. vi. Termination of employment.

I do hereby acknowledge that I have read the foregoing Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to GBV and SEA. I understand that any action inconsistent with this Code of Conduct or failure to take action mandated by this Code of Conduct may result in disciplinary action. FOR THE EMPLOYER Signed by ______Title: ______

Date: ______

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EMPLOYEE’S CODE OF CONDUCT

I, ______(name of employee), acknowledge that preventing Gender-based Violence (GBV) and Sexual Exploitation & Abuse are important. GBV/SEA activities constitute acts of gross misconduct and are therefore grounds for sanctions, penalties or termination of employment. All forms of GBV or SEA are unacceptable either on the work site, neighbouring project communities, or at worker’s camps. Prosecution of those who commit GBV/SEA will be followed as appropriate according to applicable laws. I also acknowledge the need to maintain peaceful relationships and interactions with residents of project areas.

Specifically, I agree that while working on projects of the Rural Access and Mobility Project (RAMP), I will:

i. Maintain conflict-free relationships with residents of project areas when such relationships and interactions become necessary.

ii. Consent to police background check.

iii. Treat women, children (persons under the age of 18), and men with respect regardless of race, colour, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status.

iv. Not use language or behaviour towards women, children or men that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate.

v. Not participate in sexual activity with children—including grooming or through digital media. Mistaken belief regarding the age of a child and consent from the child is not a defence.

vi. Not engage in sexual favours or other forms of humiliating, degrading or exploitative behaviour.

vii. Not have sexual interactions with members of the communities surrounding the work place and worker’s camps that are not agreed to with full consent by all parties involved in the sexual act. This includes relationships involving the withholding or promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex—such sexual activity is considered “non-consensual” within the scope of this Code.

viii. Attend and actively partake in training courses related to HIV/AIDS, GBV and SEA as requested by my employer.

ix. Report through the GRM or to my manager suspected or actual GBV and/or SEA by a fellow worker, whether in my company or not, or any breaches of this code of conduct.

With regard to children under the age of 18: x. Wherever possible, ensure that another adult is present when working in the proximity of children.

xi. Not invite unaccompanied children into my home, unless they are at immediate risk of injury or in physical danger.

xii. Not sleep close to unsupervised children unless absolutely necessary, in which case I must obtain my supervisor’s permission, and ensure that another adult is present if possible.

xiii. Use any computers, mobile phones, or video and digital cameras appropriately, and never to exploit or harass children or to access child pornography through any medium (see also “Use of children’s images for work related purposes”).

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xiv. Refrain from physical punishment or discipline of children.

xv. Refrain from hiring children for domestic or other labor, which is inappropriate given their age, or developmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury.

xvi. Comply with all relevant local legislation, including labour laws in relation to child labour.

Use of children’s images for work related purposes When photographing or filming a child for work related purposes, I must: xvii. Before photographing or filming a child, assess and endeavour to comply with local traditions or restrictions for reproducing personal images. xviii. Before photographing or filming a child, obtain informed consent from the child and a parent or guardian of the child. As part of this, I must explain how the photograph or film will be used.

xix. Ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive.

xx. Ensure images are honest representations of the context and the facts.

xxi. Ensure file labels do not reveal identifying information about a child when sending images electronically.

I understand that it is my responsibility to use common sense and avoid actions or behaviour that could be construed as GBV or SEA or breach this code of conduct. I do hereby acknowledge that I have read the foregoing Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to GBV and SEA. I understand that any action inconsistent with this Code of Conduct or failure to take action mandated by this Code of Conduct may result in disciplinary action and may affect my ongoing employment.

Signed by ______Signed by ______(Employee) (Employer/Manager) Title: ______Title: ______Date: ______Date: ______

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ANNEX 5: Best Practice Guidelines for the Integrated Planning and Design of Economically Sound and Environmentally Friendly Roads in Floodplains

Best Practice Guidelines for the Integrated Planning and Design of Economically Sound and Environmentally Friendly Roads in Floodplains

1. Developments in floodplains: resistance versus resilience strategies

A common strategy is the so-called resistance strategy where embankments and roads are constructed to protect and/or extract areas from the influence of floods (Figure 1a). This strategy, however, has its disadvantages as pressure on the structure can be severe causing damage - thus high maintenance costs resulting from the inevitable repair - as well as the fact that the floodplain hydraulics are disrupted which negatively impacts on the floodplain ecosystem (Table 1). In addition, water quality problems may arise because dirt and polluted water are no longer removed by the floodwaters. Internationally, there is increased attention for so-called resilience strategies in flood risk management (e.g. Bruijn de, 2005; Vis et al. 2003). The resilience strategy basically employs a more natural way to mitigate flood risk, as it aims at minimizing the consequences of floods, but at the same time intends to maintain the natural floodplain dynamics as much as possible. This strategy hence could present a way to sustainability. The hypothesis behind the resilience strategy study is that although the strategy might require higher initial investment, the longer-term costs in terms of road damage and ecological impacts will be lower.

a b . .

Figure 1: Strategies in roads development in vulnerable floodplains: resistance (a) versus resilience (b).

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An example demonstrating this is the ‘room for the river’ approach adopted in the Netherlands, which creates safety against extreme river floods by widening river cross sections to lower flood levels (Ministry of Transport, Public Works and Water Management, 2006). This is done by situating the dikes further away from the river, or by lowering the river forelands, thereby reducing velocities and water levels by providing space for the watercourse. Within this approach, old secondary branches in the floodplain will be opened again for floods, but roads should maintain passable. This requires properly designed flow-through structures that can withstand the high flow velocities.

Pros and cons of the resistance and resilience strategies of road development in vulnerable floodplains.

Pros Cons

Resistance Better protection against floods Fragmentation of floodplains and strategy hydraulic changes and impact on Reduction damage in high density areas flood- related functions

Downstream impacts

More expensive to protect roads against damage

Potential for increased complacency towards the dangers of floodplain living

Resilience Less fragmentation floodplains and More costly due to construction strategy hydraulic changes through- flow structures

Less damage to roads Reduced access (lower roads)

Long-term benefits to both financial More need for integrated planning investment in development and and management biodiversity conservation

Increased awareness of dangers of floodplain living

A similar approach to flood management has been adopted in the UK where DEFRA (Department of Food and Rural Affairs) has developed the ‘Making Space for Water’ cross government programme for England and Wales. This attempts to reduce risks to people, property and the environment from flooding and coastal erosion.

The Making “Space for Water” Programme is arranged around four themes:

• Holistic approach. • Achieving sustainable development. • Increasing resilience to flooding. • Funding.

It aims to reduce vulnerability by utilizing a range of approaches to flood risk management from the i) provision of defenses, ii) flood forecasting and warning systems, iii) increased flood resilience of property, iv) beneficial land management changes and v) discouragement of inappropriate development in areas at risk of flooding. A number of best practice examples can be found on the DEFRA website where recent land planning and resilience strategies have been employed with the purpose of reducing vulnerability.

English (PPS25, Planning Policy Guidance) and Scottish guidance (SPP7 – Scottish Planning Policy) follows the same approach, which shapes development policy with regard to flood risk within the UK. The latter states that no new development should increase the probability of flooding

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elsewhere. This would require that the design of any bridge across a major river or floodplain would require to demonstrate minimal change to flood levels either upstream or downstream of the structure (www.sepa.org.uk/flooding). These examples indicate the European trend towards a different approach to flood risk and resilience and this has recently been translated into a strategic directive at the European level. The EU Floods Directive 2007/60/EC controls the management of flood risk considerations within Member States. It requires that all members should assess flood risk (both fluvial and coastal), ascertain vulnerable people and assets and take measures to reduce the risk, with the focus on prevention, protection and preparedness. Sustainable flood management is now at the heart of the European strategic level approach to flooding and indicates the trend to towards the adoption of Integrated Flood Management principles.

2a. Integrated River Basin Management

The discussion on the two strategies of road development in floodplains and their pros and cons shows the need for integration, as road development in floodplains relate to many aspects, including regional development, agriculture, ecology, water management, social welfare. Integrated Water Resources Management (IWRM) and Integrated Flood Risk Management (IFRM) are two concepts that address this integration, although from different perspectives.

Integrated Water Resources Management (IWRM) is based on the understanding that in order to promote efficiency, equity and ecological integrity of natural resources, an integrated approach to engineering, policies, institutional development and management is essential. IWRM, particularly in the Enugu RAMP II project areas concerned with this ESIA study, implies allocation of water resources, implementation of strategies, and the operation of agencies and utilities in doing so. It brings together major technical and non-technical aspects, including hydrological, biophysical, chemical, economic, institutional, legal, policy-making and planning aspects. Integrated River Basin Management (IRBM) can be considered as a tool to deliver IWRM at the basin scale (3rd World Water Forum). See also Box 1.

Box 1: Integrated Water Resources Management (IWRM) and Integrated River Basin Management (IRBM).

IWRM is a process that (GWP, 2000):

• Favours the co-ordinated management and development of water resources and of related land and other resources. • For the purpose of maximizing in an equitable way the economic and the resulting social welfare. • Without compromising the sustainability of vital ecosystems.

‘IRBM is now recognized as the tool, perhaps the best tool, to deliver IWRM at the basin scale.’ (3rd World Water Forum)

As many project roads, are built on levees, they also have the purpose of flood protection. Hence, the development and planning of roads is strongly related to Integrated Flood Risk Management.

2b. Flood Risk Management

Flood risk management is an approach to identify, analyze, evaluate, control and manage the flood risks in a given system. The following steps are identified:

Definition of the system, the analyzed hazards and the scale and scope of the analysis.

A quantitative analysis where the probabilities and consequences are assessed and combined/ displayed into a risk number, a graph or a flood risk map

Risk evaluation: With the results of the former analyses, the risk is evaluated. In this phase, the decision is made whether the risk is acceptable or not.

Risk reduction and control: Dependent on the outcome of the risk evaluation measures can be taken to reduce the risk. Measures can be structural or non-structural. It should also be

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determined how the risks can be controlled, for example by monitoring, inspection or maintenance.

Flood risk management measures should be evaluated based on their environmental impacts, hence there is a need to identify measures that on the one hand reduce flood risk and on the other hand maintain benefits of floods.

An Integrated Approach to Road Development and Rehabilitation in Floodplains

Figure 2 presents a framework for integrated analysis of road planning and design. The figure shows the relation between road development design and planning (A) and the various effects (B), and links this to the use of standards and guidelines (C). In road development and planning, all effects should be taken into account through the use of economically sound and environmentally friendly guidelines for planning and construction of roads in floodplains.

Ultimately, policy makers determine what guidelines and standards to use depending on the objectives they find important. It is clear that in this process multiple objectives should be taken into account. Table 2 gives as an example several road development and rehabilitation objectives and different options for criteria that will be applied by decision-makers when selecting alternatives.

Conceptual framework of road design and planning in floodplains

External factors

floods and flood characteristics floodplain development (irrigation, structures, etc.) socio-economic floodplain ecological functions etc. A. ROAD DEVELOPMENT

design alignment B. EFFECTS

floods on roads (stability, damage) roads on floodplain hydraulics, morphology and ecology and on water quality transport road investment, operation and maintenance social (casualties, damage/loss, risk perception)

C. GUIDELINES AND STANDARDS

present (international, National, State, LGA) proposed improvements

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Sample objectives...

enhance regional transport reduce vulnerability to flooding minimise infra-structure investment and maintenance maintain floodplain hydraulics, ecology / biodiversity - Etc...

These objectives are often conflicting and then a compromise has to be made. This is illustrated by two examples.

A first example is that roads with more bridges, culverts and other measures to deal with floods are expensive. In developing countries budgets are limited and cheaper options may be preferred. Hence, it is important to locate bridges and culverts at the best possible locations and recommend solutions that have only small additional construction costs. This might imply that objectives on vulnerability or environment will not be completely met.

Example of road development and rehabilitation objectives and different options for criteria.

Objectives Criteria

Enhance Regional Travel Time Road flooding accepted (limited reduction travel time) Transportation Once in few years flooding accepted (medium reduction of travel time)

Road never flooded (large reduction of travel time)

Reduce Flood Damage of Flooding No damage accepted Vulnerability (Housing, Infrastructure, Yearly limited damage accepted Agriculture, Roads) 5 yearly limited damage accepted

Damage accepted

Maintain fisheries Fisheries and No change in harvest accepted and agricultural Agriculture Harvest Small decrease accepted harvest Increase harvest

Minimise Road Initial Investment No budget constraint Investment and Maintenance Medium budget Limited budget

Maintenance Cost No budget constraint

Medium budget

Limited budget

Maintain Flood Flood Pattern and No change accepted Plain Hydraulics Dynamics (within zone) Limited change accepted

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and Ecology Change accepted

Flood Pattern and No change accepted Dynamics (outside zone) Limited change accepted Change accepted in less valuable areas

Habitat Fragmentation No fragmentation loss accepted

Limited fragmentation is accepted if adaptation is possible

Fragmentation accepted

A second example is emergency works versus integrated design: many road improvement works focus on emergency repairs after roads have been damaged by floods; integrated design of roads has different investment and maintenance costs associated as roads may have less damage during floods, but are more expensive to build. The main point is that effects are to be considered in an integral manner and the best solutions found given objectives and constraints.

Another approach would be to search for a win-win solution where robust technical designs lead to benefits for various construction cost, infrastructure maintenance, ecology, natural resources and vulnerability of population. Will a greater initial investment be beneficial in the medium and long term, as it would reduce maintenance of the infrastructure and environmental and social mitigation measures. The question then is how to design standards in the face of these trade-offs. The floodplains, especially in the project area, offer potential for a more resilient planning and design of roads, by using more flow-through (culverts, bridges) or spill-over capacity within a design. This could have benefits on two sides: reducing annual damage to roads, thus ensuring a year-round transport service, and a more pristine floodplain from hydraulic, geo-morphological and ecological perspectives. Although investments on the short term may be higher, the longer- term overall benefits could be substantial especially for transportation and other like rural developmental activities directly or indirectly dependent on road rehabilitation such as agriculture, fisheries, markets, infrastructure environment.

Literature presents limited evidence that resilient planning and design of roads (ie by using more flow- through (culverts, bridges) or spillover capacity within a design) can effectively mitigate ecological impacts. However, several case studies have observed that if bridge openings are not so wide, the damage to roads and hydraulic structures was larger.

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ANNEX 6: Traffic Management Plan

Traffic Management Plan

In general, a Traffic Management Plan is required for all projects that could have an impact on: • MOBILITY - including interruptions to pedestrians, cyclists and vehicular traffic; and • COMMUNITY - including interruptions to surrounding businesses and residents from construction activity and worker parking needs.

The objective of this TMP is to provide safe passage for pedestrians, cyclists and vehicular traffic along the proposed 29 roads project areas.

Components of the Traffic Management Plan

The proposed TMP for the construction works should to a minimum address the following:

The Contractor should designate a TMP Supervisor who will oversee traffic management along major roads within the project corridors;

Traffic Management Plan for the project will address the following:

a) Safety Signage: Safety signage will be put up along all major roads in within the project corridors. This would inform motorists and other road users of the ongoing construction works within the area. These signage will indicate that there are “Men at Work”. Caution is most required by motorists and cyclists who transverse the project areas.

b) Road Diversion Signage: Diversion signage will be erected at sensitive places where diversions will exist from the project implementation.

c) Communication: The Contractor, with support from the RAMP-SPIU, will prepare a communication protocol which will be shared with the communities within the respective zones. The communication protocol will provide a stepwise approach to informing residents about traffic plan alterations 48hrs before they are implemented. Communication with communities will be directly facilitated by the Contractor’s Community Liaison Officer and the Secretary of each respective Community Association. Additionally, communications should be made with the PIU, FRSC and Community associations a week prior to notifying the general populace.

d) Liaisons with Government Traffic Agencies: The TMP will ensure liaisons with the FRSC at the State level. In situations where heavy traffic impacts are envisaged, the Contractor will liaise with the FRSC to ensure traffic coordination and mitigate adverse traffic impacts.

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e) Employee Transportation: To the extent possible employees will use buses provided by the contractor as transportation to and from the site, thereby reducing overall vehicle traffic. Project vehicles or will be utilized by staff, only when necessary.

f) Speed Limits: Speed limits will be enforced to and from the site and signage(s) shall be posted along the access and site roads (maximum 40 km/hr, reduced to 20 km/hr at blind corners and bridge crossings. Traffic along other access roads will be radio controlled for safety and speed control. Furthermore, employees and contractors will be educated on safety including traffic protocols and speed limits during mandatory orientation. Routine traffic inspections and/or speed indicator signs will be used to encourage safe and responsible driving.

g) Reporting: Records on traffic management and implementation of this plan should be kept and updated by the contractor as evidence of ongoing mitigation compliance, which will be submitted to SPIU as part of routine reports on progress of work.

The contractor shall ensure that all construction activities are performed in accordance with the approved Traffic Management Plan.

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ANNEX 7: Waste Management Plan

Waste Management Plan

Potential Waste Streams Waste Recommended Measures Responsibility Costs Source Type 1. Civil Works Construction Concrete • Proper collection and disposal of solid Contractor Mitigation: during Waste debris and wastes from the project sites through USD 8,170 construction demolition organized collection by waste management NGN 2,500,000 phase and material operators within the state. removal of • Construction wastes shall be safely Monitoring: construction removed from project site by designated USD 4,640 materials during authorities within the state. NGN 1,420,000 decommissioning • Any waste material that is inadvertently phase disposed in or adjacent to watercourses will be removed immediately in a manner that minimizes adverse impacts, and the original drainage pattern should be restored. • All wastes that are not designated, as combustible waste on-site will be recycled, disposed off in any of the State’s approved dumpsites, landfills or waste treatment facilities (where they exist). • Waste materials should be placed and stored in suitable containers. Storage areas and containers will be maintained in a sanitary condition and shall be covered to prevent spreading of wastes by water, wind or animals. • .

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2. Leakages from Hazardous Waste Oil; • Safe removal and replacement of oil during Contractor Mitigation: vehicles and oil Battery construction activities; use of impermeable USD 2,614.5 containers Acid; materials to insulate nearby media such as NGN 800,000 explosives; soil, water. carbides; • Avoid indiscriminate disposal of oil cans Monitoring: tar; and containing materials within and outside USD 1,634 Cement; project sites; NGN 500,000 runoffs • Proper and safe handling of hazardous and corrosive materials; • Storage of hazardous materials within safe conditions and perimeter from nearby communities and project implementation sites when not in use. • There should be a designated site for washing of containers or trucks that contain cement wastes. • All runoffs shall be conducted into nearby drainages after treatment. Treating agents such as activated charcoal can be used to remove hazardous contaminants from runoffs before discharge • Control placement of all construction waste to approved disposal sites (>300 m from rivers, streams, lakes, or wetlands). • Concrete waste, including wastewaters from batching or cleaning, will only be disposed of at approved and designated disposal sites with containment facilities. • All cement-contaminated wastewater from cleaning or mixing is to be considered toxic, and must be prevented from entering any watercourse or drainage channel for at least 48 hours to allow the water to reach neutral pH level.

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3. Construction and Generation of Feces, • Ensure provision of sanitary facilities on Contractor Mitigation: operation of solid and sanitary urine, site for workers and enforce usage. USD 7,843 workers camp waste waste • Ensure usage of Enugu ESWAMA approved NGN 2,400,000 water etc. waste vendor for waste evacuation & disposal. Monitoring: • Provide bins on site for temporary storage USD 2,941 of domestic waste such as lubricant NGN 900,000 containers, drinking water sachets and carrier bags/packaging materials. • Dispose all construction and domestic waste at the approved dumpsites and in the approved manner. • Ensure all trenches or excavations made during the construction works do not collect stagnant water, which could breed mosquitoes. • Ensure access to toilets for construction crew or provide temporary toilets (mobile toilets) for use where there are no existing ones. • Ensure mobile toilets/sanitary provisions are provided to reflect gender types. • Ensure regular toolbox meetings are held among contractor workers to offer awareness on transmission of contagious or communicable diseases. Total (See ESMP Table for more Mitigation: Monitoring: details) USD 13,725 USD 6,863 NGN NGN 2,100,000 4,200,000

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ANNEX 8: Community Security, Health and Safety Management Plan

Community Security, Health and Safety Management Plan Potential Hazards Recommended Actions (HSE Measures/Safety Procedures) Responsibility Costs 1. Hazardous conditions The Enugu RAMP-2 has a responsibility to ensure the health and safety of all HSE Specialist; and unsafe persons working on the distribution networks and the headquarters construction RAMP-2 SPIU behaviours; i.e. sites including, their own employees, contractors, subcontractors and agency Contractors’ non- employees. compliance to • In this regard, the RAMP-2 SPIU shall: Define systems of work and overarching project requirements for contractors and subcontractors to ensure their health recommended and safety on the site. Occupational Health • Provide information needed by the contractors to document and carry and Safety out work in a safe manner Management System • RAMP II SPIU should provide information on hazards and their associated risks while working on any specific part of the construction site. • Any Safe Work Method Statements submitted at tender should be reviewed to ensure safety and environmental requirements have been fully met. • Ensure that Contractors follow all safety and environmental requirements. • RAMP-2 SPIU should monitor health and safety during construction works. Pre-start checks, inspections and audits will be conducted while on- site. These checks will look at work practices and methods, equipment conditions and suitability, and competency of people through checking the permits, licenses etc. Individuals are not permitted to bring, use or be under the influence of alcohol or non-prescribed drugs on site. 2. Compensation claims, • Contractors are responsible for ensuring that their work methods Contractor consider and incorporate best practice and Construction safety requirements. • Contractors are responsible for ensuring that safety and health hazards associated with the work they are performing, are satisfactorily controlled and do not pose a risk. In the process of carrying out their work, a Contractor may introduce other hazards. The identification and control of these hazards is the responsibility of the Contractor. These hazards and controls identified by the Contractor must be considered in the Safe Work Method Statements.

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Total (See ESMP and Monitoring Tables for more details) Mitigation: Monitoring: USD 22,222 USD 12,810 NGN NGN 6,800,000 3,920,000

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ANNEX 9: Minutes of Meeting with Stakeholders

Minutes of Meeting with Stakeholders

1. Stakeholders’ Consultation Meetings - Summary of Concerns by community members

S/N Concerns Response 1 Commencement of road construction and They were assured that they will be continual engagement during the project engaged by the contractors during the implementation phase. implementation of the project and that the project will commence soon. 2 Fear of Road Accidents as the improved roads They were assured that Contractors will may lead to reckless driving and consequently erect caution signs, warning signs and accidents. They also feared that construction speed limit signs during and after vehicles and plants may cause accidents within construction including speed breakers. the project communities. Contractors drivers will be trained on OHS and safety procedures 3 Commencement of road construction and They were assured that the project will provision of employment opportunities during commence soon and that they will be project implementation phase. considered for employment during the project implementation phase. 4 Concerns about the dust that would be They were guaranteed that their generated during the road construction work, concern would be mitigated by ensuring especially in the dry season. wetting of the roads.

5 Destruction of people’s farms and properties This will be addressed by a during the project. Resettlement Action Plan (RAP) for subsequent compensation.

6 Enquiries were put forward to ask if the project The Team answered that as part of the wil affect schools and school children. ESIA, adequate planning measures would be taken to ensure that it will not affect the pupils negatively, by regular community consultations to ensure updates on school calendar, which would be aligned with work schedule to prevent closures or disruptions, while also providing adequate mitigation in the ESMP.

7 Tampering with Waste bins during construction, SPIU is aware and has been indiscriminate dumping of excavated material discouraging the practice. In addition, and littering of road with soil and debris. the ESMP has provided mitigation to prevent continual reoccurrence.

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ANNEX 10: Attendance List and Pictures of Consultations

Attendance List and Pictures of Consultations

Focus Group Discussion at Focused Group Discussion at Obeagu-Ugwuaji Uhuogiri- Railway Road (lot 4) Oruku Afo Ezza Road

Ikem – Umualor – Nkplogu-Uvuru-Ukpata-Adaba- Agbogazi- Nike – Road Focus Group Discussion at Ubahu- Amankanu-Umualor-Nike RD Akunyi Umulokpa-Road

UBA Express Junction Imezi Abonuzu Road (Ajali Water Works Ako-Nike Community Owa –Imeama Ezema Cps Road) Upata Ezema Abonuzu Road

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With Udueme Community Achara Ohodo Community Nkpuru-Orugu Ohodo Community

Ozalla Uwani Community Ekwegbe Community KII at Umuogbo-Agu

Consultations with women KII at Umuegbudu Agu Community Secondary School, groups in Orie Market, Aguibeje Imufu

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Consultations with Enugu State Nkwo Market Square, Eha Nweke Edem Ani Market, road Ministry of Works & Ndi Agu Infrastructure

Consultations with Enugu State Consultations with Enugu Consultations with Enugu State Ministry of Environment field Office of FMEnv Waste Management Authority

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ANNEX 11: AIR QUALITY ANALYSIS

AIR QUALITY ANALYSIS

Road code Locations NO2 H2S NO Temp. TVOC(p CO2 (%) SO2 (%) CO(ppm) numbers (ppm) (ppm) (ppm) (oC) pm)

LOT 1

125 Nguru-Akpotoro-St Mary Obimo Road 0.06 0.30 0.00 31.3 625 0.01 0.00 1.47

119 Odenigbo-Edem Ani-UgwuiyiMpi-OfuluOnu 0.11 0.70 0.01 36.6 640 0.00 0.00 1.90 Road with Spurs to Imilike-Ubogidi Road and Catholic Parish Road 40 Nkpologu-Uvuru-Ukpata-Adaba-Akunyi- 0.02 0.30 0.00 31.4 430 0.00 0.00 2.21 Umulokpa Road LOT 2

95 Igogoro-Amachalla-Ikpoiga-Umuagbedo 0.02 0.80 0.00 31.7 343 0.01 0.00 1.24 Agu Road 97 Onichadugo-Olido-Amube Road 0.12 0.60 0.01 30.1 579 0.01 0.00 1.16

101 Amufie-Ugbaike-Inyi Obollo Road 0.05 0.30 0.00 29.5 276 0.01 0.00 1.85

129 Enyazuru Ohom Orba-Amube Ohom orba 0.03 0.50 0.01 33.0 412 0.00 0.00 1.70 Road 136b Ogbo Umuokere-Mbanato-Imufu Umundu- 0.12 0.70 0.01 36.6 613 0.01 0.00 1.90 Obegulgug-Nkporogwu-Ngbede-Nkwo Umundu Road 138 ObolloOgbelle-Ezimo Road with Spur to 0.06 0.30 0.00 31.3 625 0.01 0.00 1.49 AMA-Ogbelle UNO 141 Express-Odobodo-Amalla-Okpu Road 0.12 0.50 0.00 33.0 404 0.00 0.00 1.70

142 Umu-Ezejor-Agu-Udele-Itabor Road with 0.05 0.50 0.01 35.4 353 0.00 0.00 1.70 Spur at Ubahor

161 OnuaffaAmallaOrba - Amaedem- Ofuluonu 0.12 0.5 0.01 32.5 451 0.00 0.00 1.70 - Agudele Road Page | 169

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LOT 3

89 AcharaOhodo through Achara Primary 0.04 0.30 0.00 31.9 401 0.00 0.00 1.21 School to old primary school ohodo to union primary school ohodo to Lejja 90 Ohebedim-Ozalla-Lejja Road 0.06 0.40 0.00 31.8 400 0.01 0.00 0.90

70 Aku-Udueme-Odoaku-Odume 0.08 0.30 0.00 33.6 579 0.00 0.00 0.45

86 Umudinwogo-Amabokwu_Useh Road with 0.04 0.30 0.00 31.9 423 0.00 0.00 1.28 Spur to UwaniAmabokwu Road 87 Uwani Otobo-Ugwuanani-Oshigo-Oda Aku 0.06 0.40 0.00 31.8 407 0.00 0.00 0.93 Road with spur obie- Ugwunani-Abokwe- Umudiukwu Road 90 Ohodo Express Road Junction Through St 0.06 0.5 0.00 32.1 553 0.00 0.00 1.21 Thomas Catholic Church + Ohodo Through Central Primary School Ohodo To Central School + Ozalla Through IjoOzalla To AmaEzikeOhemjeAku LOT 4

24 Obeagu-Ugwuaji Road with spur to 0.05 0.50 0.00 38.1 691 0.01 0.00 2.40 uzamdunu road

13 Ogbaku-Ogugu-Owelli-Ihe Rd 0.05 0.50 0.00 36.4 621 0.00 0.01 2.40

50 UmuajiAguobuOwa- 0.04 0.20 0.01 31.8 355 0.01 0.01 0.65 UmuajiMgbagbuowaAgbaUmuna -Ebenebe Road (with Spur to AugobuOzom through T-Junction, Umuaji)

66 MTN Exp Junction-Umueze-Agauwu 0.04 0.10 0.00 32.0 482 0.00 0.00 2.25 Farm settlement road with spur to okposi

5 Uhuogiri-Railway Road 0.03 0.50 0.01 35.0 538 0.00 0.01 1.70

57B AbonuzuOwa - Ajali Water Works 0.05 0.50 0.00 34.0 538 0.00 0.00 1.70

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LOT 5

116 Eha Uno-Eha Ndiagu Road 0.02 0.70 0.00 38.6 867 0.00 0.01 4.50

122 Owere-Umuabor-Edem Umabor-Agu SURFACE0.05 AND GROUND0.60 WATER0.00 ANALYSIS 31.7 610 0.00 0.00 2.00 Udene-Ehalambu Parameters Surface Water Ground Water 127 Obiagu Ohom Orba-Amube Ohom Orba 0.12 0.40 0.00 42.8 467 0.00 0.00 1.55 Lot 1 Lot2 Lot3 Lot4 Lot5 Lot6 FMEnv Lot1 Lot2 Lot3 Lot4 Lot5 Lot6 WHO Road Limits Limits LOT 6 Temperature (oC) 26 27 26.5 25 28 27.5 <40 27 26 26.5 25.5 26 25 Ambient 117+140 Ohebe Agu Orba-Agu Imilike Farm Road + 0.08 0.80 0.00 35.9 691 0.00 0.00 2.40 pH imilike etiti-ezimo6.4 road6.2 6.2 6.1 6.3 6.3 6 -9 6.7 6.5 6.1 6.8 6..4 6.9 6.5 – 8.0

38 Neke-Umualor Raiway line-Ehamufe Road 0.06 0.30 0.00 35.4 614 0.00 0.00 1.43

Limits

Min 0.02 0.20 0.00 29.5 238 0.00 0.00 0.42

Max 0.06 0.80 0.01 42.8 867 0.01 0.02 4.50

Mean 0.06 0.37 0.00 33.48 407.61 0.01 0.00 1.47

FMEnv Limits 0.06 8.00 N/S N/S N/S N/S 0.14 10.00

ANNEX 12: SURFACE AND GROUND WATER ANALYSIS

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EC(ds/m) 0.48 0.64 0.55 0.7 0.69 0.53 - 0.70 0.58 0.68 0.79 0.60 0.65 1

TSS(mg/l) 4.12 4.55 3.55 4.97 3.23 3.74 30 2.20 2.10 2.29 2.35 2.01 2.40 0*

TDS(mg/l) 2.67 2.41 2.89 3.11 2.56 3.12 2000 3.15 3.00 2.87 3.55 3.21 3.17 600

Alkalinity(mg/l) 50.45 45.77 40.45 47.26 40.12 42.45 - 30.20 31.00 29.70 28.60 30.00 28.55 -

Hardness as CaCO3 mg/l 9.6 8.1 8.9 9.7 8.0 9.4 200 7.0 7.3 6.9 7.2 6.8 7.1 300

Dissolved Oxygen (mg/l) 5.5 6.0 7.1 7.3 7.8 6.4 2-8 4.5 5.0 7.3 4.9 5.7 4.11 7.5

BOD (mg/l) 3.57 4.39 4.56 4.68 3.97 4.25 30 0.48 0.30 0.28 0.35 0.4 0.45 0

Chloride (mg/l) 0.72 1.50 1.03 1.36 0.97 1.93 250 0.60 0.75 0.54 0.50 0.70 0.56 250

Phosphate (mg/l) 0.009 0.008 0.0085 0.0079 0.0078 0.0075 5 0.007 0.0079 0.008 0.0078 0.009 0.0065 -

Sulfate (mg/l) 0.09 0.05 0.04 0.03 0.03 0.08 500 0.08 1.20 1.50 0.09 0.70 0.50 500

Nitrate (mg/l) 0.58 0.50 0.48 0.56 0.52 0.50 20 0.49 0.47 0.56 0.59 0.50 0.90 50

THC (mg/l) 0.12 0.35 0.27 0.07 0.31 0.22 - ND ND ND ND ND ND -

Oil and Grease 0.04 0.03 0.02 0.06 0.05 0.01 10 ND ND ND ND ND ND -

Iron (mg/l) 2.01 2.35 2.54 1.44 1.59 1.87 20 2.00 2.09 2.13 2.11 2.03 2.07 0.3*

Zinc (mg/l) 0.59 0.53 0.44 0.76 0.81 0.43 <1.0 0.86 1.94 2.74 1.55 0.56 0.77 3.0

Manganese (mg/l) 0.01 0.04 0.23 0.25 0.20 0.07 5 0.01 0.03 0.02 0.00 0.10 0.35 0.4

Copper (mg/l) 0.45 0.21 0.26 0.19 0.18 0.33 <1.0 0.00 0.00 0.00 0.00 0.00 0.00 2.0

Lead (mg/l) ND ND ND ND ND ND <1.0 ND ND ND ND ND ND 0.01

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ANNEX 13: SOIL ANALYSIS

SOIL ANALYSIS

Determinations (Parameters) Lot 1 Lot 2 Lot 3 Lot 4 Lot 5 Lot 6 FME Limits

Electrical Conductivity, microgram/cm 3 3 3 3 8 4 1000

Nitrates (NO2-) mg/kg 0.08 0.109 0.007 0.009 0.129 0.11 -

2- Sulphates (SO4 ), mg/kg 0.185 0.385 0.325 0.180 0.185 0.185 500

Chlorides (CL-), mg/kg 0.177 0.177 0.178 0.282 0.177 0.177 250

Calcium (Ca2=), mg/kg 3.049 3.049 2.477 3.049 1.334 2.478 NS

Manganese (Mn2+), mg/kg Trace Trace Trace Trace Trace Trace NS

Iron (Fe2+), mg/kg 0.093 0.093 0.093 0.185 Trace 0.093 NS

Zinc (Zn3+), mg/kg 57.72 28.64 17.76 62.16 93.24 62.16 NS

Lead (Pb2+), mg/kg 0.027 0.04 Trace Trace Trace Trace NS

Chromium (Cr2+), mg/kg Trace Trace Trace Trace Trace Trace <1.00

Nickel (Ni), mg/kg 0.117 0.059 0.059 0.176 0.176 0.117 NS

Sand 80 72 77 79 77.5 85 -

Silt 12.5 12 15 11.5 11 15 -

Clay 9.5 6 10 12 15 9 -

Total Organic matter % 5.173 2.85 0.22 1.66 0.448 3.06 - pH 6.3 6.5 6.5 6.4 6.29 6.47 6 - 9

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ANNEX 14: NOISE LEVEL ANALYSIS

Road code Locations Noise (dB) numbers Lot 1 125 Nguru-Akpotoro-St Mary Obimo Road 33.5 119 Odenigbo-Edem Ani-UgwuiyiMpi-OfuluOnu Road with Spurs to 42.2 Imilike-Ubogidi Road and Catholic Parish Road 40 Nkpologu-Uvuru-Ukpata-Adaba-Akunyi-Umulokpa Road 52.1 Lot 2 95 Igogoro-Amachalla-Ikpoiga-Umuagbedo Agu Road 31.1 97 Onichadugo-Olido-Amube Road 41.2 101 Amufie-Ugbaike-Inyi Obollo Road 52.1 129 Enyazuru Ohom Orba-Amube Ohom orba Road 43.3 136b Ogbo Umuokere-Mbanato-Imufu Umundu-Obegulgug-Nkporogwu- 31.3 Ngbede-Nkwo Umundu Road 138 ObolloOgbelle-Ezimo Road with Spur to AMA-Ogbelle UNO 32.1 141 Express-Odobodo-Amalla-Okpu Road 42.1 142 Umu-Ezejor-Agu-Udele-Itabor Road with Spur at Ubahor 41.2 161 OnuaffaAmallaOrba - Amaedem- Ofuluonu - Agudele Road 31.2 Lot 3 89 AcharaOhodo through Achara Primary School to old primary school 32.9 ohodo to union primary school ohodo to Lejja 90 Ohebedim-Ozalla-Lejja Road 33.8 70 Aku-Udueme-Odoaku-Odume 41.9 86 Umudinwogo-Amabokwu_Useh Road with Spur to UwaniAmabokwu 28.7 Road 87 Uwani Otobo-Ugwuanani-Oshigo-Oda Aku Road with spur obie- 31.8 Ugwunani-Abokwe-Umudiukwu Road 90 Ohodo Express Road Junction Through St Thomas Catholic Church + 31.9 Ohodo Through Central Primary School Ohodo To Central School + Ozalla Through IjoOzalla To AmaEzikeOhemjeAku Lot 4 24 Obeagu-Ugwuaji Road with spur to uzamdunu road 37.4 13 Ogbaku-Ogugu-Owelli-Ihe Rd 35.8 50 UmuajiAguobuOwa-UmuajiMgbagbuowaAgbaUmuna -Ebenebe Road 48.7 (with Spur to AugobuOzom through T-Junction, Umuaji)

66 MTN Exp Junction-Umueze-Agauwu Farm settlement road with spur 43.9 to okposi 5 Uhuogiri-Railway Road 57.8 57B AbonuzuOwa - Ajali Water Works 58.4 Lot 5 116 Eha Uno-Eha Ndiagu Road 31.1 122 Owere-Umuabor-Edem Umabor-Agu Udene-Ehalambu 40.2 127 Obiagu Ohom Orba-Amube Ohom Orba Road 52.1 Lot 6 117+140 Ohebe Agu Orba-Agu Imilike Farm Road + imilike etiti-ezimo road 32.1 38 Neke-Umualor Raiway line-Ehamufe Road 40.1 Limits FMEnv/WHO Limits 70/90

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ANNEX 15: CULTURAL HERITAGE MANAGEMENT (CHM)/CHANCE FIND PROCEDURE

Identification and Assessment

For Cultural Heritage Management (CHM) under the Enugu RAMP-2, Inventory will always be a key management tool in the area of identification and assessment. The extent to which inventories are prepared will depend on criteria adopted by the PIU and in lines with requirements or guidelines by the WB.

The principal best practice in assessing cultural heritage issues around roads to be rehabilitated under the Enugu RAMP-2 is to have a thematic and individual value assessment procedure in place, so as to justify long-term conservation of an asset. The aim of an identification and assessment process should be not only the identification of places, but also the establishment of a hierarchy of significant places under a thematic system.

Best Practice Inputs 1. The Enugu RAMP-2 should have a standard inventory form, also available as a Standard Operating Procedure (SOP). 2. Inventory should be updated as new information becomes known, or as new technology is introduced e.g. GPS plotting of sites. 3. Inventory is thematically linked and has the primary aim of revealing a hierarchy of significant places under a variety of relevant themes. 4. Inventory work focuses on geographic areas or themes where there is little recorded inventory and a potential threat exists to unrecorded sites. 5. Each road project area has assessment criteria and an assessment process, both of which have been endorsed by the SPIUs Safeguard Unit and WB. 6. The Enugu RAMP-2 SPIU should maintain a CHM database containing all information relating to history and management of CHM assets with cross- reference to other state inventories. 7. Assessment of significance of heritage places by an external CHM specialist should be a prerequisite for major capital expenditure on any CHM asset.

Allocating Resources

Best Practice inputs/Indicators

1. There should be provision for access to a capital works budget for CHM catch up maintenance. 2. The Enugu SPIU should plan for an ongoing core funding base for cyclical maintenance of CHM assets within each institution responsible for CHM and the reflection of this responsibility in the expected outputs. 3. Ensure risk management actions for CHM emergencies. 4. Prioritisation of resource allocation to places on a thematic significance basis. This should be founded on an understanding of the history of land under management and broader state or national themes. 5. The proportion of CHM staff /institutional responsibilities to CHM assets managed should be similar to the proportion of staff to assets in other functional areas within the organisation. 6. Identification of core competencies for CHM staff/institutional responsibilities and competency-based recruitment procedures including assessment of competencies by a CHM specialist. 7. The SPIU should ensure that training in core CHM competencies are integrated into SPIU training programs. (Including instruction in broad CHM principles and specific standard operating procedures) 8. Development of a suite of partnership tools to expand CHM management options eg. Local government management, community participation. 9. Regular analysis of CHM assets to ensure that each asset is managed by the Enugu RAMP-2 SPIU with the best expertise, resources, motivation and local presence to

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effectively conserve that place, and to present the place if it is appropriate to do so. 10. Comprehensive guidelines and programs to promote and support active community involvement in CHM. 11. All leases on CHM assets include provision for specific ongoing works funded by lessee. 12. Revenue generated from CHM should be retained for CHM without a corresponding drop in budget funding, in order to encourage sustainable management.

Protection

1. The Enugu SPIU should ensure that the process of acquiring places with a range of conservation or heritage values (natural, historic and indigenous) should take into account all the identified values and provide for their future management. 2. If the SPIU considers acquisition is not an option, or is unnecessary, then other options including reserving, listing on a state heritage register, voluntary conservation agreement, covenanting, gazetting or referral to another relevant authority are pursued, with the co-operation of the owner. 3. The Enugu RAMP-2 risk management strategy addresses the need for staff training and appropriate checks and balances to minimise the threat to CHM assets by in-house staff.

Conservation

1. Conservation of places of cultural significance should be done according to a plan – a conservation management plan (CMP). 6. The breadth and detail of CMPs are commensurate with the needs of the place. 7. Shorter CMPs for individual sites, tailored to specific circumstances, should be prepared where; there is urgency to do the work, or the issues are simple and the vision statement for the place dictates action, or the plan forms part of a broader management plan. 8. Broad management plans or ‘historic area plans’ are prepared for larger land areas with predominantly historic values or places with multiple, geographically linked heritage assets. Work specifications or shorter CMPs are then prepared for each identified heritage asset in the area. 9. All CMPs are signed off by, at the minimum, by the SPIUS Safeguard Unit (or their equivalent) to ensure organisational ‘buy-in’. 10. Costed work specifications, together with plans, must be are prepared to relevant industry standards 11. Provision is made for a CHM specialist to inspect progress and ensure that work is proceeding according to the plan and that all work is supervised and conducted by skilled conservation practitioners or tradespeople. 12. Where sites have a multiplicity of values (e.g. natural and cultural as well as historic), then an overarching integrated management plan is prepared for that place. Cultural heritage is a component of such a plan.

Monitoring

Physical monitoring of sites of cultural heritage will require synergized involvement attention by several relevant state and national agencies e.g. State Ministry for Culture and Tourism.

Best Practice Inputs/Indicators

The Enugu RAMP-2 PIU should ensure:

1. The use of a formal asset management and monitoring system for CHM assets. 2. Annual reporting of agreed performance measures 3. Auditing of CHM to ensure management objectives are met 4. Integration of heritage places into organisational asset management systems. 5. A process existing for consistently reviewing plans, quality of planning and those who prepare them.

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6. Establishment of a register of contract CHM specialists that is regularly reviewed on the basis of existing contractors’ work, allows for the addition of new contractors and is open to public inspection. 7. Long term monitoring of the condition of cultural heritage places 8. Regular meetings of Enugu SPIU Staff and CHM specialists as a means of monitoring progress towards best practice and assisting agencies to set higher levels of best practice. 9. Ongoing market research to measure effectiveness of presentation in interpreting specific places, raising awareness of cultural heritage conservation and encouraging appropriate growth in visitor numbers. 10. A CHM strategy/policy document which is published and subject to public consultation and scrutiny 11. Monitoring of visitor numbers at all actively managed places

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ANNEX 16: LABOUR INFLUX MANAGEMENT PLAN

The Labour Influx Management Plan for the 29 rural roads rehabilitation Project, under the Enugu RAMP-2 should to a minimum address specific activities that will be undertaken to minimize the impacts of labour influx on the local project communities.

Elements for managing labour influx risks under the proposed project include:

• The Contractor should endeavour to reduce labour influx by tapping into the local workforce: This is the most effective mitigation measure against labour influx. To avoid and mitigate impacts of influx, it is paramount that the Enugu RAMP-2 SPIU, ensures that its Contractors make use of unskilled workforce which is recruited locally. Depending on the requirements of the sub-project and the skill level of the workforce, it may be possible to train local workers within a reasonable timeframe to meet project requirements. This may be more likely if such trained staff are needed afterwards for the operation and maintenance of the rehabilitated roads and upgraded hydraulic structures.

• Establishment of worker codes of conduct: The Supervising Engineer and Safeguards Unit of the SPIU should ensure that Contractors establish a workers’ Code of Conduct (CoC). The CoC will help mitigate some of the social and environmental impacts of labour influx such as risk of social conflict, Increased risk of illicit behaviour and crime, Increased burden on and competition for public service provision, Wastewater discharges, Increased demand on freshwater resources, and Inadequate waste disposal and illegal waste disposal sites etc., will help keep workers (local/foreign) in check on the rules and regulations binding their engagement.

• Training programs: Conduct and ensure key staff, including contractors, receive training regarding the likelihood, significance and management of influx-related issues such as HIV/AIDS, GBV, SEA, VAC etc.

• Carry out Regular Monitoring: The Enugu RAMP-2 SPIU should monitor for change throughout the project cycle on labour influx related mitigation compliance and on mitigation effectiveness from projects/contractors. Ensure a documented monitoring program that tracks key social outcomes, changes and issues at regular intervals throughout the project lifecycle

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ANNEX 17: BORROW PIT REMEDIATION PLAN

A borrow pit is an area from which material is excavated for use in the construction of a nearby infrastructure project.

Objectives of Borrow Pit remediation plan

The objectives for the restoration and aftercare of the borrow pits are to:

• Restore land to a condition suitable for its original use, post-excavation; • Essential mitigation for local environmental effects that occur as a consequence of the use of the borrow pits; and • Contribute to addressing the impact of climate change by taking opportunities to mitigate pre-existing and potential future flood risk and water stress risk issues.

Design Principles for borrow pits

The following design principles will be applied when siting the borrow pits

• All borrow pits will be excavated only for granular material for use within the Proposed Scheme (i.e. not for commercial extraction); • Borrow pits will be backfilled using natural uncontaminated material from Proposed Scheme excavations (including clay / fines which are a by-product of processing the granular material at the borrow pit sites), and restored using subsoil and topsoil stripped from and stored within the Proposed Scheme. Surplus topsoil, whether from within and outside the borrow pit sites, will not be used as backfill. Topsoil and subsoil will normally be stripped and stored separately within the footprint of the borrow pit for use in site restoration; • It is intended that the borrow pits will be restored to the original ground level and to a condition suitable for their previous land use, except where the land is proposed to be used for other purposes, such as for a replacement floodplain storage area, balancing pond or access track; • Where agricultural uses are to be resumed on land disturbed during the construction of the Proposed roads, the design objective is to avoid any reduction in long term capability, which would downgrade the quality of the disturbed land, through the adoption of good practice technique in handling, storing and reinstating soils on that land and to provide a sufficiently deep soil profile to manage both wetter and drier conditions in the future due to climate change impacts; • Backfill will be compacted as much as necessary to meet the relevant requirements for the intended end use of the land; • Ruminate groundwater control during borrow pit excavation with regards to hydrological regimes

Borrow pit Restoration Plans

The plan will consider these approaches:

• Soil reinstatement • Backfilling • Revegetation

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ANNEX 18: WORKERS CAMP SITE MANAGEMENT PLAN

The Workers Camp Site Management Plan for the 29 rural roads rehabilitation Project, under the Enugu RAMP-2 should to a minimum address specific activities that will be undertaken to minimize the impacts resulting from siting a workers camp on the local project communities.

Elements for managing risks associated with the Workers Campsite under the proposed project include:

• The Contractor shall ensure to site workers camp at a designated and approved location by the Enugu RAMP-2 SPIU. • On-site Social and Health Care Facilities: Provision of basic on-site social and medical facilities such as first aid, basic health care center, recreational center, food service, etc. in order to reduce pressure on community facility. • Campsite Safety and Security: Provision of 24 hours security stationed at the Campsite to ensure the security and safety of construction workforce and construction equipment. • Campsite Waste Management: Adequate waste management of sewage and other forms of waste within the campsite. The Campsite shall be equipped with independent toilet facilities for male and female workers respectively, in order to discourage irregular waste disposal. Furthermore, standards must be instituted for personal and public hygiene among project workers. Additionally, project workers shall be properly trained on personal hygiene. • Establishment of and Training on Workers on Code of Conduct: The Supervising Engineer and EnuguRAMP-2 Safeguards Unit shall ensure that Contractors establish a workers’ Code of Conduct (CoC). The CoC will help mitigate some of the social and environmental impacts of labour influx such as risk of social conflict, Increased risk of illicit behaviour and crime, Increased burden on and competition for public service provision, Wastewater discharges, Increased demand on freshwater resources, and Inadequate waste disposal and illegal waste disposal sites etc., will help keep workers (local/foreign) in check on the rules and regulations binding their engagement. Contractors to ensure provision of training to workforce on code of conduct and ensure strict compliance. Measures provided for in the ESMP to deter illicit behaviour and other social vices are adequately enforced. • Training programs: Conduct and ensure key staff, including contractors, receive training regarding the likelihood, significance and management of influx-related issues such as HIV/AIDS, GBV, SEA, VAC etc. • Carry out Regular Monitoring: The EnuguRAMP-2 SPIU shall monitor for change throughout the project cycle to ensure compliance and on mitigation effectiveness from projects/contractors. Ensure a documented monitoring program that tracks key social outcomes, changes and issues at regular intervals throughout the project lifecycle

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ANNEX 19: CONTRACTORS ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (CESMP)

It is expected that prior to commencement of construction works, the Contractor shall prepare and submit a Contractors Environmental and Social Management Plan (CESMP) for the rural roads rehabilitation under the Enugu RAMP-2 to the SPIU. The CESMP shall be approved by the Enugu RAMP-2 PIU for implementation by the Contractor.

This shall include: • A Traffic Management Plan (TMP); • A proper Waste Management Plan; • A Labour Influx Management Plan; • An Occupational Health and Safety Plan (OHSP); • Borrow Pit Remediation Plan • Emergency Preparedness and Response Plan • Procedures for siting workers camp; and • Key project personnel and their environmental and social responsibilities.

Additionally, the annexure shall include: - Individual Code of Conduct; - Workers Code of Conduct; and - Managers Code of Conduct

The Contractor shall ensure that the Codes of Conduct are appropriately signed, and laid down procedures are duly complied with.

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ANNEX 20: EMERGENCY PREPAREDNESS AND RESPONSE PLAN

This plan exists to satisfy the needs and to outline the steps to be taken to prepare for and respond to an emergency affecting the Rehabilitation of the 29 Rural Roads under the Enugu RAMP-2 Project.

Purpose

The aim of the Enugu RAMP-2 SPIU in responding to an emergency situation include:

• The safety of all project related staff, rural residents, contractors and their workforce and guests. • Their physical and emotional well-being. • The timely stabilization of an emergency situation. • The protection of Contractor facility, property, and the belongings of workforce, rural residents, and guests.

Applicability and Scope

This plan applies to all staff, contractors, consultants and any person residing within the project corridors to include guests, employees, farmers, rural residents etc.

The scope of this plan is intended to encompass all hazards. This plan may be consulted when responding to any and all emergencies. When encountering a situation which has not been expressly addressed in this plan, use good judgment and the guiding principles outlined below.

Responsibilities

The Emergency Preparedness and Response Plan is the responsibility of the EPRP Coordinator (the EnuguRAMP-2 SPIU will need to appoint our recruit one/or include this to the responsibilities of it safeguards unit). He/She will review and update this plan at least once annually. Revisions will be made as needed throughout the year. Any suggestions, comments, or questions should be directed to him/her.

In other instances, local emergency officials such as National Emergency Response Agency (NEMA) at the State-Level may assume certain responsibilities during emergencies such as evacuation and whatever other actions are necessary to save life and property.

Order of Succession

Leadership authority during an emergency shall flow downward through the following list of people:

1. Emergency Preparedness and Response Plan Coordinator 2. Chief Evacuation Coordinator 3. Evacuation Coordinators 4. Evacuation Wardens

Emergency Communication

During an emergency, the EPRP Coordinator will use the following means and methods of communication.

Possible means and methods:

✓ Landline Telephones ✓ Cell Phones (possible outages during emergency) ✓ Texting (more reliable during emergency) ✓ Two-way Radios ✓ Email ✓ Take time to develop specific communication procedures defining who will be responsible for communications and what information will be communicated

The following important contact should be available to report any emergency:

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• Safety & Security Agencies – NEMA, Federal Road Safety Corps (FRSC), Nigerian Army, Nigeria Security and Civil Defense Corps (NSCDC) • Environmental Health & Safety Organizations, NGOs, Community -Based Organizations, International Committee of the Red Cross (ICRC) • Enugu RAMP-2 SPIU; Facilities Operations & Management (Main Office and Troubleshooter) • Health Service Centers • Office of Communications

Emergency Contact Directory in a format below should be available.

Name Primary Phone Secondary Phone Pager

Media Inquiry

Inquiries from the media during or after an emergency will be addressed by the EPRP Coordinator. The Enugu RAMP-2 SPIU Communications Specialist will be consulted in releasing any information to the media (television and radio). At any time, the media can simply be referred to the SPIU Communications Specialist and vice versa.

Trainings

Before implementing the EPRP, the EPRP Coordinator should designate and train enough people to assist in the safe and orderly emergency evacuation of all staff, dam residence, and guests. The following activities should be carried out:

• Review the EPRP with all the employees and representatives of the PAPs • Train each new employee when he or she is initially assigned to the job. • Review the plan with each employee when their actions or responsibilities under the plan change. • Retraining employees annually to effectively implement the plan.

It is recommended that different departments discuss the content of the EPRP and other emergency plans and Project Affected Persons (PAPs) are educated on the types of emergencies that may occur, and are trained on the proper course of action.

Emergency Protocols

Fire Evacuation

In the Event of a Fire:

• Pull the Fire Alarm and Call the Fire Service • If you see smoke or flames:

Use CARE:

• Contain the fire by closing all doors as you leave

• Activate the nearest Fire Alarm pull station (Pull stations are located near all building exits)

• Report the fire by calling the fire Service

• Evacuate or extinguish (In most cases, it is best to Evacuate)

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Use a Fire Extinguisher only if:

• You have been trained

• You have your back to an unobstructed exit

• You have a fully charged and proper type unit for the fire you are fighting

• The fire is contained, and you have reported the fire by Fire Alarm or by calling the Fire Service.

• Everyone else has left the area

• There is little smoke or flames

Never fight a fire if:

• You lack a safe way to escape should your efforts fail

• It has left its source of origin

• You are unsure of the type of extinguisher you need or have

• If you cannot control the fire within 30 seconds, abandon your efforts, close the door(s) and evacuate immediately.

Building Evacuation

Employees and PAPs should be familiar with evacuation routes in all the project corridors. If an evacuation order is issued for a building, or if it were necessary to evacuate due to an emergency, full cooperation with Safety and Security/emergency personnel is necessary:

• Take only keys, wallets and essential belongings with you

• If possible, wear weather appropriate clothing

• If you are the last one to exit your room close, and lock doors

• Leave the building immediately

• Do not investigate the source of the emergency

• Walk, don’t run, to the nearest exit

• Use stairs, not elevators

• Assist people with special needs

• Get input from the individual how you can help before attempting any rescue technique or giving assistance. Ask how he or she can best be assisted or moved and whether there are any special considerations, methods, or any items that need to be brought with the person during the evacuation.

Vulnerable Groups

This consists of women, children, aged, sick and physically challenged individuals.

• Do not walk up and grasp the arm of a vulnerable individual and attempt to lead her/him out of the building. First, ask the person if s/he would like assistance or guidance in leading her/him out of the building to the Emergency Evacuation Meeting Location.

• If there is no immediate danger, persons with disability/mobility limitations should shelter in place and call Safety and Security to report location and number of people needing assistance

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• If there is imminent danger and evacuation cannot be delayed, the person with a disability should be carried or helped from the building in the best and fastest manner (the person with the disability is the best authority as to how to be moved out of the building)

• Follow instructions of identified emergency personnel

• Wait for instructions before returning to your building after an evacuation

Medical Emergency

If someone is injured or becomes ill:

• Stay Calm

• Call Health Clinic or Health Service Centers and explain the type of emergency, the location, condition, and number of victims

• Let the dispatcher know of any safety hazards - chemical spill, fire, fumes, etc.

• Do not hang up unless told to do so by the dispatcher

• Do not move the victim unless there is danger of further injury if s/he is not moved

• Render first-aid or CPR only if you have been trained

• Do not leave the injured person except to summon help

• Comfort the victim until emergency medical services arrive

• Have someone stand outside the building to flag down the ambulance and/or Safety and Security when they reach the vicinity

Utility Failure and Natural Disaster

Utility Failures

These may include electrical outages, plumbing failure/flooding, etc. For personal safety, in the event of a utility failure:

• Remain calm

• Immediately notify Safety and Security.

• If the building must be evacuated, follow the instructions on Building Evacuation

• Unplug all electrical equipment (including computers) and turn off light switches

• Use a flashlight: Do not light candles or use other kinds of flames for lighting

Floods

If Minor or area flooding on roads occurs:

• Secure vital equipment, records, and other important papers

• If present in your area, report all hazardous materials (chemical, biological, and/or radioactive) to SPIU Safeguards Unit or to NEMA

• Move to higher, safer ground

• Shut off all electrical equipment

• Do not attempt to drive or walk through flooded areas

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• Wait for further instructions on immediate action from Safety and Security

• If the building must be evacuated, follow the instructions on Building Evacuation

• Do not return to your building if you have been evacuated by flooding until you have been instructed to do so by the EPRP Coordinator.

If you are assisting with flood cleanup, report immediately to SPIU Safeguards Unit or NEMA any oil, chemical, or radioactive materials suspected of mixing wit

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ANNEX 21: SOCIO-ECONOMIC CHARACTERISTICS OF PROJECT AREA

Distribution Category Number Percentage

Sex Male 122 51.9 Female 113 49.1 Age 60 – above 19 8 45-60 120 51 18-45 96 41 Length of Stay in From Birth 180 76.6 Community Above 15 years 55 23.4 10-14 years Nil 0.0 5-9 years Nil 0.0 Below 5 years Nil 0.0 Religion Islam 0 0.0 Christianity 193 82.1 Others (traditional) 42 17.9 Marital Status Married 135 57.4 Single 60 25.5 Widowed 32 13.7 Divorced/Separated 8 3.4 Occupation Civil Servants 15 6.4 Fishermen Nil 0.0 Farmers 86 36.6 Self employed 30 12.8 Traders 55 23.4 Students 49 20.8 Income Level Below 5000 28 11.9 5100 – 10,000 70 29.8 10,000-20,000 110 46.8 20,000-35,000 27 11.5 35,000 + Nil 0 Educational Level Uneducated 50 21.2 FSLC 35 14.9 WASC/SSCE 122 51.9 Islamic Studies Nil 0.0 Higher Certificate 28 11.9 Source: Field Survey, April 2019.

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