Union of Comoros

MINISTRY OF REGIONAL DEVELOPMENT AND URBAN PLANNING DIRECTORATE-GENERAL OF ROADS RESPONSABLE FOR LAND MANAGEMENT AND ROAD TRANSPORT (DGRTR)

PROJECT : ROAD NETWORK REHABILITATION PROJECT, PHASE II – NATIONAL ROAD 2 (PANDA-IFOUNDIHE SECTION)

COUNTRY : UNION OF COMOROS

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) SUMMARY 9 September 2019

June 2019 Page 1 of 30 Road Network Rehabilitation -Panda-Ifoundihé Section of the NR 2 ESMP Summary

1 INTRODUCTION

This document presents a summary of the Environmental and Social Management Plan (ESMP) of the Road Network Rehabilitation Project on the Panda-Ifoundihé Section of the NR 2 prepared in 2019. From an environmental and social standpoint, this project is classified in Category 2 in compliance with the environmental and social safeguard requirements of the African Development Bank (AfDB). This ESMP summary was prepared on the basis of the EIA relating to the Panda- Ifoundihé section of the NR2 on the island of Grande Comore for phase 2 of the project, in compliance with the environmental and social requirements in force in the Union of the Comoros (Annexes 3 and 4) and AfDB’s Integrated Safeguards System.

The project description and rationale are presented first, and the options compared in terms of feasibility. The environmental and social impacts are summarised and approved for publication (Annex 5). The negative impact mitigation and enhancement measures are presented as well as the monitoring programme. The public consultations held during the ESIA are described as well as the complementary initiatives linked to the project.

The ESIA was prepared to provide the Ministry of Agriculture, Fisheries and Environment as well as the other Government Authorities, project stakeholders and the general public, with detailed knowledge of the project’s environmental and social challenges and the support measures associated with its implementation.

The DGRTR required an ESIA review and the conclusion mentions the project’s acceptability for which Environmental Authorisation No.19-0018 MAPE/CAB of 9 September 2019 (Annex 3) confirms the authorisation issued in the Union of the Comoros by the Directorate-General of Environment and Forests (DGEF) (issued on 10 June 2016) [Annexe 4] under the oversight of the Ministry of Regional Development and Urban Planning responsible for Land Management and Land Transport. The ESIA complies with the legal framework in Burundi, in particular Law No. 94- 018/AF of 22 June on environmental protection amended by Law No.0095-007-AF of 19 June 1995 of the Union of the Comoros and Decree No. 94-100 /PR enacting the Framework Law on the Environment.

Apart from some compensation which was the subject of an Abbreviated Resettlement Plan all the planned works, including the assessment of impacts on road works, coupled with civil and marine engineering activities, if required, will be carried out within the existing boundaries of the current NR 2 right-of-way.

2. PROJECT DESCRIPTION, RATIONALE AND DESCRIPTION OF THE ENVIRONMENTS

2.1. Project Rationale

The rehabilitation of this section of the NR2 is in line with the country’s National Road Transport Master Plan, in particular its Pillar 1 ‘to safeguard and upgrade road infrastructure’ in the regions where the population is experiencing very serious difficulties in travel and trade within the islands and with the rest of the country’s islands, through ports, jetties and airports linking the islands.

The NR 2 on the island of Grand Comore connects the major agricultural or high potential basins with the consumption, export and import zones. The project’s implementation will also contribute to the removal of one of the main constraints which is the poor condition of the roads which seriously impedes the removal of one of the main constraints which is the transportation of agricultural products from the PA and its supply of inputs of other staple products.

This project is fully in keeping with the priorities expressed in the Accelerated Growth and Sustainable Development Strategy (SCA2D) of Comoros for the 2015-2019 period and is consistent with the transport sector policy of Comoros which aims ‘to improve and modernise transport infrastructure so as to provide users with enhanced service at the lowest possible cost, thereby developing trade and tourism within the union and promote regional integration". The project is also in line with the single pillar, i.e. ‘Development of basic energy and road infrastructure in support of economic diversification" and with the Bank’s 2013-2022 Ten-Year Strategy, in particular with its strategic priorities (High 5s).

The project’s overall objective is to improve the movement of goods and people in order to consolidate the foundations for strong and sustainable growth through trade facilitation. More specifically, the project aims to (i) reduce transport costs; (ii) open up production areas in order to improve the living conditions for the population of the impact area; and (iii) adapt the road network to the transport needs of the population and the impacts of climate change.

2.2. Project Description

The project components are described as follows: A. Road works: (1) rehabilitation of 5km of road on this section of the NR2 in the Grande Comore; (2) coastal protection from marine erosion; (3) construction of parking areas along the road; (4) works control and supervision; and (5) sensitisation of the population on STDs and other pandemics, environmental protection as well as to road safety in the project area of influence. B. Support to women’s financial empowerment in the PAI: (i) protection of the coast against marine erosion; (ii) construction of a bridge over the M'poundre River (KP25+825 of the Anjouan RN23); (iii) sales outlet at Panda; and (iv) control and supervision of ancillary works. C. Institutional Support: this component concerns capacity building and technical assistance. It will comprise activities aimed at planning and managing public works more efficiently and transparently, improving road safety and axle load control and providing the country with a regulatory framework that will foster the emergence of road transport enterprises. D. Project Management and Monitoring: (1) support to the project executing agency; (2) monitoring and evaluation of the project’s socio-economic impact; (3) financial and accounting audit; and (4) monitoring and evaluation of the project’s socio- economic impacts. E. Clearing the Project Right-of-Way.

At this stage, the total estimated cost is UA 18.17 million, i.e. EUREUR 22.16 million.

KP: 41+235 Bridge surrounded by a downstream surface run-off area PK: 41+586 bridge and surface water downstream

PK: 44+500 Run-off area PK 47+ 100 Foumbouni coastal area

Photos 1 to 4: State of degradation of the NR 2 road pavement

Figure 1. Location of the Panda-Ifoundihe Section and the Road Network of the Union of Comoros

This map has been provided by the Project Executing Agency to the African Development Bank exclusively for the use of readers of the report to which it is attached. The names used and the boundaries shown on the map do not imply on the part of the AfDB Group or/and its Members any judgment on the legal status of any territory or any endorsement or acceptance of such boundaries.

2.3 Comorian Administrative Framework

The Comorian administrative body with supervisory authority over the environment is the Directorate-General of the Environment and Forests (DGEF), under the oversight of MAPEATU, which is responsible for periodic monitoring. It has three offices covering the islands concerned by the project that verify compliance with environmental requirements. It is this Directorate that issues authorisations for development works and user rights. The Ministry of Regional Development, Urban Planning responsible for Land Management and Land Transport (MATUCAFTT) through the Directorate-General of Roads and Road Transport (DGRTR) is responsible for the project’s implementation on behalf of the Vice-Presidency responsible for the Ministry of Finance, Economy, Budget, Investment and Foreign Trade. It contains a Project Implementation Unit (PIU) with an environmentalist dedicated to monitoring the ESMP’s implementation.

2.4 Legislative and Regulatory Framework

The Union of Comoros relies on a national and international legal framework, in particular, conventions, agreements and treaties, development policies, programmes, plans and national legal and regulatory instruments on environmental and social protection. The environmental and social legislation and regulations relating to the project activities concern the following instruments.

In the Union of the Comoros, Law No. 94-018/AF of 22 June 1994 laying down the Framework Law on the Environment governs the environmental legal and regulatory framework.

Decree No. 01-052/CE of 19 April 2001 governs EIAs. Order No.12 – 012/VP- MPEEIA/CAB of March 2012 establishes and sets the terms of reference of the Evaluation Committee for Environmental Impact Studies (CEEIE). The DGRTR thus required a review of the environmental impacts of the proposed works and an assessment of the project’s socio- economic impact. These are incorporated in the economic studies.

- The Decree of 4 February 1911 organising the land tenure regime as amended by the Decrees of 20 July 1930, 9 June 1931, 15 August 1934 and 27 February 1946;

- The Decree of 9 June 1931 reorganising the land tenure regime, as amended by the Decrees of 15 August 1934 and 27 February 1946;

- The Decree of 6 January 1935 regulating expropriation for public interest;

- Two Orders (a) 061-281 sets the conditions for deliberation and (b) 061-180 of 14 June 1961 organises State land and land tenure services;

- Law No. 89-20 of 22 February 1989 relates to the operation of quarries;

- Law No. 94-037 of 21 December 1994 establishing the Water Code;

- Law No. 94-018/AF of 22 June 1994;

- Law No. 84-108 establishing the Labour Code; and

- Law No. 11-001/AU of 26 March 2011 establishing the Public Health Code.

The other instruments concern: (i) Law No. 95-007 on biodiversity; (ii) Order No. 01/031/MPE/CAB on the protection of animal and plant species and the 15 agreements and conventions ratified: Multilateral Environmental Agreements (MEAs), including the three United Nations Framework Conventions:

 The Convention on Biological Diversity (CBD);

 The United Nations Framework Convention on Climate Change (UNFCCC); and

 The Framework Convention to Combat Desertification (CCD), followed by the NAP/CD National Action Plan in 2013.

The country also prepared and adopted (1) the National Self-Assessment Report on Environmental Management Capacity Building (ANCAR); (2) the Strategic Programming Framework (CSP) on Climate Change; (3) the Growth and Poverty Reduction Strategy Paper (GPRSP); and (4) the Vulnerability study on climate change.

2.5 For the African Development Bank (AfDB)

This section describes the main project aspects for triggering the applicable operational safeguards of the African Development Bank’s (AfDB) Integrated Safeguards System (ISS)

 Operational Safeguard 1: Environmental and Social Assessment. This operational safeguard is triggered because this is a road project that automatically requires an environmental and social assessment. The project is classified in Category 2.

 Operational Safeguard 2: Operational Safeguard – Involuntary Resettlement. This operational safeguard is triggered to a lesser extent because all the works planned, apart from some compensation which was the subject of an Abbreviated Resettlement Plan, including the assessment of impacts on road works coupled with civil and marine engineering activities if required, will be carried out within the existing boundaries of the current NR 2 right-of-way.

 Operational Safeguard 3: Biodiversity, renewable resources and ecosystem services. This operational safeguard is triggered because the project includes activities which could impact on marine fauna in particular the Kartala protected area which is, however, located 5km from the road.

 Operational Safeguard 4: Pollution Prevention and Control, Greenhouse Gases, Hazardous Materials and Resource Efficiency. This operational safeguard is triggered because the activities of the preparation, construction and operational phase are sources of pollution and various nuisances.

 Operational Safeguard 5: Labour Conditions, Health and Safety. This operational safeguard is triggered because of the existence of risks for the health and safety of workers during the implementation of works for this type of project.

OS 4 refers to the environmental, health and safety guidelines of the World Bank for pollution standards and control measures and good practices.

2.6. Description of Scope and Sensitivity Assessment of Areas Crossed

2.6.1 Project’s Direct Impact Area

For the project, the direct impact area is the spatial extent of the project footprint and associated installations on the host environment. This includes the areas where the planned project activities will be implemented (project area, ancillary infrastructure and immediate environs). In the case of the project, this concerns the right-of-way of the NR 2 road to be rehabilitated.

The project’s direct impact area (PIA), which covers all sites on which road rehabilitation work will have negative or positive environmental impacts, is shared between: (i) the right-of-way for the Panda-Ifoundihé roadworks, (ii) quarries: Ifoudihé and Dzahadjou Mbadjini, (iii) deposits: pozzolanic deposits (Dzahadjou Mbadjini, Mindradou Mlimani and Ifoundihé).

This section forms part of the NR2 which is a coastal road linking Moroni to Foumbouni and crosses several major urban areas. These administrative localities make up part of one (1) of Grande Comore’s 8 prefectures. This island accounts for 52% of the total population of the Union of Comoros.

PANDA

IFOUNDIHE

Figure 2: Extract from the map of the project area (PANDA-IFOUNDIHE section (in yellow)

2.6.2 The Project’s Indirect Impact Area

The indirect impact area covers: (i) areas potentially affected by the cumulative impacts; and (ii) areas that could be indirectly impacted by the project activities. The indirect impact area distinguishes between the different resources and receivers depending on dependencies. For example, the indirect impacts on soils will be confined to areas close to the direct footprint whereas indirect impacts linked to the contamination of underlying water tables concern a broader area. The indirect impact on social resources extends to neighbouring communities likely to be affected by the project.

2.6.3 Description of the Physical Environment

A summary of the project area’s physical environment is described below.

Relief: The relief of Grande Comore is made up of two units (Karthala watersheds in the Bambao and Hambou regions) and the Karthala and La Grille mountains in the Mbadjini region (volcanic cones and lava flows). The soils are very permeable.

Climate and Precipitation. The climate is tropical with year-round sunshine and an annual average temperature of 25°C with peaks of 24°C to 25.4°C during the hottest periods. The main city of Bujumbura like the rest of the country experiences 4 seasons: long and short dry seasons, long and short rainy seasons. Average annual rainfall is 1000 mm /yr. Regarding precipitation, fluctuations and trends observed between 1960 and 1989 are expected to continue in the future, despite the absence of complete data.

However, according to IPCC projections of the Atmosphere-Ocean General Circulation Model (AOGCM), climate change scenarios for small Indian Ocean islands for the 2040-2069 period point to an increase in the annual average rainfall by 3.1% (+ or - 0.45%) with a decrease of between -2.6 and -1.8% during the dry periods (June-August). According to projections carried out, the average annual temperature will rise by 1°C by 2050. IPCC temperature scenarios for the islands of the south-west Indian Ocean point to an increase of 2.1°C between 2040 and 2069.

Geology. In Chindini, RN2 cuts across the Coelacanth marine area in the process of being classified. The areas considered sensitive close to the RN2 are: the Ouroveni mangroves, and the coral reefs and white sandy beach of Chindini. The degradation of natural environments by human activity mainly through intensive deforestation, in addition to the Karthala volcanic dust deposits, has had an undoubted impact on the area’s vulnerability to hydro-meteorological and geological hazards. There has been increased run-off, with the following consequences: (i) slow and widespread floods; (ii) flash floods after violent storms and/or cyclones. They are often followed by mudslides or landslides. The calculated rise in sea level is expected to reach 20 cm by 2050. Extreme weather and climate events are expected to increase in frequency and intensity in the future.

2.6.4 Description of the Socio-Economic and Cultural Environmental

Demographic and Gender Data. According to the GPHC carried out from 16 December 2017 to 26 January 2018, the total resident population was 742,267 inhabitants comprising 372,010 men and 370,000 women i.e., a women/men ratio of 49.9%. The project’s direct beneficiaries are, therefore, the PIA population in general, and particularly road users, women members of associations who will be supported, beneficiaries of capacity building activities, businesses, and various service providers that will be mobilized. According to World Bank 2018 data, the age- dependency ratio was 74% (% of working age population). The unemployment rate was 20% (in the ILO sense) (% of working age population).

In terms of gender specificities, women play an important role in trade. They are active in trade between urban and rural areas. Female labour workforce participation is relatively low (36% compared to about 81% for men) and more women are unemployed than men. Women's employment is also more likely to be precarious - there are very few women in non-farm wage labour (13.7%) and more women than men are self-employed.

Economic Situation. In 2016, 42% of the Archipelago’s population (almost 320,000 people) was poor, with real monthly consumption per capita below the national poverty threshold. About 18% of the population lives below the international poverty line set at USD 1.9 per capita per day (expressed in purchasing power parity for 2011). However, according to the most recent World Bank forecasts of June 2018, poverty has fallen by 10 points in both urban and rural areas.

The female population represents 49.48% of the PIA’s total population. The most vulnerable segment of the population is the large unemployed family. A high percentage of women work in the informal agricultural sector (about two-thirds). Although the country has ratified the Convention on the Elimination of All Forms of Discrimination Against Women, women remain under-represented in all spheres of socio-economic activities in the Comoros, in national politics (3 %), at the local level, in the administration, and in legal and judicial professions.

Social and Cultural Framework.

In Grande Comore, the grand wedding is an unavoidable tradition. It represents the savings of a lifetime and allows people to assume the rank of high-level dignitary. It is the cause of the considerable social precariousness on the island, on the one hand, but strong social cohesion and significant diaspora remittances, on the other. Matrilineality is justified in myths. The Comorian considers brothers and sisters, their children, his mother and brothers and sisters of his mother and their children, as well as his maternal grandparents as family. Property is inherited based on the matrilineal system, that is, from mother to daughter, and it is the collective property of the lineage. The matrimonial home belongs to the woman and the husband lives there as long as he is her husband.

For agricultural land, the man has access to his sister’s land and, through marriage, that of his wife, but has no right over it. Gender-based violence is a reality in the Comoros, but efforts to combat this situation are still limited.

In terms of health, the PIA island has a single health service operating under favourable conditions. It is in Moroni, capital of the Union of the Comoros, for the RN2. This centre is located 32 km from Ifoundihé.

3. POTENTIAL IMPACTS, AND MITIGATION AND ENHANCEMENT MEASURES

3.1 Negative Impacts

The impact assessment was carried out on the road works activities associated with civil and maritime engineering activities where necessary, on the existing NR2 right-of-way as well as on the adjacent maritime domain according to the different project phases:

(1) In the preparatory phase; i) optimization/materialization of road delineation; (ii) supply of equipment and site installation; and (iii) recruitment of labour.

(2) In the construction phase: i) scarification of the existing pavement and storage of excavated material; (ii) earthworks and excavations for the construction/reconstruction of gutters and crossing structures; (iii) clearing and grubbing of some trees on the surrounding area; (iv) waste generation; and (v) transportation and placing of rip-rap.

(3) In the operational phase: (i) increased risks of accidents

Table 1: Matrix of Interactions between the Project Activities and Host Environments

Environmental Biophysical environment Human environment component

and and

iving iving

afety

ransport

ater ctivities

ater

yment

Project activities

ultural Heritage onditions

Air So Surface Ground Faun Landscape Healthand Emplo Movement Agriculture Tradeand Tourism Infrastructure c Women’s c

Site installation w S S w w S M M M

Clearing and cleaning of right-of- M M S w w S S M M w way

Earthworks, excavation, backfill M S S w w M S S M S and construction of pavement

mpact i Construction of

of of crossing-structure w M S w w w S M M S and drainage systems

Sources Works

Opening and operation of w M S w M M M M M S quarries and borrow pits

Transportation of w S S w w w M w w w materials

Presence of labour w S S w w w S M

Presence of the road and crossing w S w w S M S S M S structures

Routine and periodic w S S w w S w M maintenance

Operation Legend: w = weak impact, M = moderate impact; F = strong impact  positive impact  negative impact

Rehabilitation of the NR2 and NR23 Road Network ESMP Summary

3.1.1 In the Preparatory Phase

The project plans to adapt to the platform widths used when passing through urban areas which vary, on average, between 7m and 8m from KP27 to KP 33 of the NR2.

Repairs to the pavement and gutters will be carried out in built-up areas without affecting the residents’ property. Repairs to the pavement and gutters will be carried out in built-up areas without affecting local assets. Consequently, the road layout will not affect any property on the NR2, owing to strict implementation in collaboration with the DGRTR. Also, the transportation of equipment and materials may be a source of inconvenience for the local population and may become a potential source of conflict. This risk should be taken into consideration

3.1.2 In the Construction Phase

1. On the Physical Environment, and during the works, the quality of water will not be altered in any significant way. The impacts likely to be generated will be felt during the sanitation works (flood-proofing), their transverse extents, as well as multicellular structures to replace the fording sites. The dust and exhaust gas emissions to be encountered by the surrounding population will be very limited and temporary. Moreover, its implementation does not present major risks that cannot be controlled. The main risk to which the Union of Comoros is exposed is flooding which cuts off roads.

2. On the Biological Environment, no site of interest will be affected by the project. However, the RN2 route in Grande Comore is located almost 5 km downstream of the Karthala protected area’s perimeter and does not affect the Coelacanth marine area either. Both areas form part of the national network of protected areas (RNAP). These sites are already impacted by the existing right-of-way. Moreover, the project envisaged, as an activity in built-up areas, reinforcement that consists in building within the existing width, a new, stronger and more durable pavement structure than the existing one. Quarries and deposits have all been identified.

3. On the Social and Cultural Environment

Civil works along the roads and on the worksites will result in higher risks of traffic accidents, noise pollution by transport vehicles and machinery during working hours.

During construction, site personnel may adopt behaviour that may not respect the usual standards and practices. Moreover, the presence of the contractor’s employees with relatively high incomes could encourage a decline in morals (prostitution, banditry, etc.), that could increase STI and AIDS prevalence.

4. On the Socio-Economic Environment

A provision in the detailed BOQ will be used to carry out repairs/restoration of property and networks just a few metres off the right-of-way. These mainly concern fencing, energy, telecommunications, access stairs and pavement infrastructure in built-up areas.

3.2 Positive Impacts

During the construction phase, the project’s beneficial impacts will be socio-economic in nature, with employment opportunities offered to local youths: (i) direct employment on construction sites; and (ii) indirect employment related to the development around trading activities of workers' camps (sale of agricultural and handicraft products, and food); and (iii) social and environmental work that the contractor could carry out in the PIA.

In the operational phase, the beneficial impacts will all be linked to Project-financed facilities: (i) improvement of traffic conditions in terms of road safety; (ii) reduction of erosion on steep

13 sloping terrain through the use of adequately drained retaining walls and the flood-proofing of RN2; (iii) sustainability of roads through coastal protection, which also contributes to seafront buildings and vegetation and resilience to climate change; (v) creation of new sources of income for vulnerable groups in society; (vi) creation of temporary employment during the life of the project. It is expected that the project will facilitate travel on the island and will provide social benefits, by improving access to social centres (schools, dispensaries, the administration, markets, etc.). The time thus saved will be put to better use on other domestic chores and economic activities in which women are more present.

The project’s beneficial impacts on the biological environment will be linked to (i) reforestation, which will enable environmental and forestry officers to expand their knowledge of the areas they manage in collaboration with other sector services.

3.3 Mitigation and Enhancement Measures

3.3.1 Before the Construction Phase

The Authorities will insert environmental clauses in the bidding documents and the main requirements for the protection of the natural environment will concern: (i) possible site remediation and restoration; (ii) waste management requirements; (iii) time limits for new trenches and channel openings for new outlets and related deposits. The main human environment protection requirements will concern: (iii) a preferential recruitment mechanism for local staff; (iv) application of safety regulations (installation of barriers, signage of building sites, diversion road signs, etc.) for local residents and users; (v) enforcement of labour regulations and the wearing of personal protective equipment by construction site personnel (gloves, dust masks, noise-cancelling headsets.)

 Before the installation and establishment of living quarters and sites, the contractor should submit for the prior approval of the Contracting Authority and Project Implementation Unit for the site, a site traffic and possibly installation plan as well as a site environmental protection plan in accordance with the environmental guidelines of the legislation in force in the Union of the Comoros. This plan should include: (i) the establishment of living quarters and equipment warehouses in the vicinity of localities and/or urban centres to enable DGRTR to assume ownership of the infrastructure upon works completion; (ii) inert waste recovery and treatment; (iii) the recovery and transfer of inert waste to local NGOs for use in routine operations and house maintenance (timber processing, steel filings and medical waste by adequate incinerators, etc.); (iv) the organisation of collection and disposal of used objects (filters, batteries, empty cans, etc.) (v) the sale and recycling of drainage oils; and (vi) the training of staff by the contractor’s environmentalist or the Project Implementation Unit on the Environmental Management System (EMS).

 Before works commencement, the project manager should proceed on the basis of construction drawings and the final stakeout study. This concerns: (i) identifying property owners liable to suffer damage (fences, access stairs, etc.); (ii) defining access to properties that must be maintained during construction and/or restored afterwards. The engineering design retained a useable width of 6m. These values remain compliant with instruments relating to the road domain in the Union of Comoros (types 2 and 3). The village chiefs, prefects and mayors will provide assistance to the AMPF and PIU in order to move the works forward, especially during the clearing of the right-of-way.

3.3.2 During the Construction Phase

The mitigation measures by the Administration will concern: (i) organisation by specialised NGOs or, if necessary by the PIU, of information and sensitisation campaigns for technical services, schoolchildren, local residents, local customary chiefs and imams, local, regional and national authorities, users and municipal authorities, using all possible means of information. They will also concern: (i) issues of safety, risk and global climate change (mainly targeting 14 young people in schools, clubs and youth centres); (ii) incentives to encourage local hiring and sub-contracting to local SMEs and NGOs during construction in such areas as sensitisation or collection of climatic, agricultural, forestry and wildlife data. During the civil works, the contractor must ensure the preservation of terrestrial fauna and water resources by applying safeguard measures.

Furthermore, the company should respect the living environment of local communities since the works take place in existing rights-of-ways: (i) by installing mobile signage in works areas, especially at night, and road signs and speed limit signs in hazardous areas; (iv) by restoring access by local residents that had been restricted by the works. It will also protect the health of local residents; (v) by ensuring that its personnel respect local customs and practices; and (vi) by periodic health checks for its staff.

The mitigation measures set out in the specifications are not specifically limited to environmental aspects. Both in the construction and operational phases, they mainly concern the mainstreaming of principles of good environmental practices and technical measures in line with road standards, both for improvements and the construction of structures. They relate to: (i) personnel management; (ii) basic site construction and hygiene conditions; (iii) organisation and management of hydrocarbon storage areas (control of risks of leakage, groundwater contamination, explosions or fire); (iv) origin of materials (quarries or deposits) and conditions of their transport and the organisation of storage areas required for works or generated by the works and rehabilitation/construction of road structures; (v) traffic regulation, regulations for exceptional loads and works phasing; (vi) solid and liquid waste management; (vii) site restoration and dismantling of interim facilities upon completion of the works. The contractual documents stipulate all the necessary requirements to minimise site-related negative impacts. They, therefore, focus mainly on the organisation of works and equipping of living quarters in order to mitigate general nuisances. Since the main measure is adaptation by proper sizing, key activities concerning coastal protection with retaining walls, drainage structures, coping for gutters and downpipes are the main project items.

3.3.3 During the Operational Phase

In order to reinforce the positive impacts on the human environment, the project also makes provision for capacity building in component B through: (i) the rehabilitation and equipping of socio-economic infrastructure; and (ii) capacity building in business management. Ultimately, the project will generate beneficial outcomes in the operational phase.

3.4 Cumulative Impacts

The cumulative impacts are those resulting from the combined action of activities related to the project itself and those of actions and/or associated projects or in the same project area. These are mainly cumulative impacts generated by: (i) the NR1 Moroni - Mitsouiouli rehabilitation project (Moroni towards the north); (ii) the Moroni port extension; and (iii) installation of fibre- optic cable throughout the island of Grande Comore.

In this regard, coordination with DGRTR services will focus on:

(i) measures for the rational management of pozzolanic materials in the existing quarries identified both for supplies for the rehabilitation works on the two roads and the Port of Moroni extension as well as the cumulative sound nuisance, dust emissions and risk of accidents. It should be noted that for all three projects, the intensity of these impacts is gauged according to a situation of convergence towards the city of Moroni. In this regard, close coordination of worksite traffic is required, particularly for quarries. The objective is the decongestion of NR1 and NR 2.

(ii) Close coordination with the Ministry responsible for ICT is also necessary concerning the revisiting of segments where fibre-optic cable has already been installed in addition to network displacements already considered in the road project’s BOQ. 15

3.5 Residual Impacts

Residual impacts are those resulting after the application of the mitigation measures at the end of the project. However, technological risks will remain such as (i) fires and/or (ii) accidents. To reduce these risks:

(i) Hydrocarbons will be stored away from the rest of the site’s facilities in an enclosed area, with a locked entry gate after working hours. A fire extinguisher will be accessible close to the pump access area. Since the soils in Comoros are highly permeable, a concrete slab will first be cast, and a low wall built on top of this slab close to the tank. Furthermore, a fire extinguisher will be installed in all the sites with risks of fire (wooden frames, welding stations, tanker trucks, etc.);

(ii) The company's ESMP must include a description of the procedures to be followed for accidents resulting from traffic, worksite activity or site installation. For all worksite activities and for all on-site work or site installation activities, employees will be informed of the nearest health centres. A list of useful telephone numbers will be provided. Each of the living quarters must have a first- aid kit.

Rehabilitation of the NR 2 and NR 23 Road Network ESMP Summary

4. ENVIRONMENTAL RISK MANAGEMENT AND CLIMATE CHANGE

4.1 Project-Related Environmental Risks

The main environmental risk will be environmental pollution and it is linked to the poor management of works-related waste such as pollutants (storage, transport and use). To mitigate this risk, a Waste Management Plan is required in the specifications. It will include the recovery of all types of waste, sorting them, reusing them and disposing of them in controlled sites. It should be noted that, given the nature of the works, almost 85% of the scarification of existing pavements has been reused as a sub-base for the rehabilitated road.

During the construction phase, there will also be another road accident-related risk. To mitigate this risk, security, sensitisation and training measures are planned for locally recruited staff, the population, personnel involved and competent services, in particular, civil protection. The measures include: (i) sensitising and training of site workers and ad hoc teams from local communities in rapid response techniques in the event of disasters; (ii) safety measures to be followed in hazardous or risky areas; (iii) providing communication and rapid evacuation equipment; (iv) contracting with workers' health services and health centres; (v) establishing and supplying local pharmacies; (vi) sensitising the population on health risk prevention and road safety; (vii) organising epidemiological surveys to assess the project impact on the environment and human health. For temporary diversions, the contractor will have to negotiate with the owners of impacted land. The contractor is fully responsible for site restoration before removing its machinery, but this restoration must be carried out in consultation with local residents and local and national authorities in order to prevent conflicts.

4.2 Climate Change

The Comoros Archipelago is vulnerable to the adverse effects of climate change. It is faced with the combined action of very violent precipitations associated with strong winds, given that it is located at the edge of cyclone-prone areas. Climatic hazards mean that the main climatic risk in the project area is land erosion due to violent precipitation associated with the frenzied rate of deforestation noted by the MTEF, as well as marine erosion due to the rise in sea level associated with strong swells and extreme rainfall in a frequent cyclonic situation.

A UNDP-financed study reports the risks of submersion of some coastal areas through the combined action of sea-level rise through a tsunami simulation, with parameters based on the 2006 tsunami. The Comoros developed a National Tsunami Warning Action Plan that was submitted to the Indian Ocean Consortium coordinated by ISDR. It should be noted in this context that the rehabilitated road is one of the measures of the disaster relief organisation process.

The options retained in the project design contribute to the mitigation of this risk.

5. ENVIRONMENTAL AND SOCIAL MONITORING/SUPERVISION PROGRAMME AND INSTITUTIONAL RESPONSIBILITIES

5.1 Organisation of Environmental and Social Supervision and Monitoring

As part of this project, a monitoring programme will first aim to ensure that the mitigation and enhancement measures proposed in the ESMP will be effectively applied during each of the successive phases of the project (installation, construction and operation).

It will include: (i) project management (MATUAF), represented in Comoros by the PIU as Delegated Contracting Authority including an environmentalist to check the compliance of reports submitted by the contractor’s environmentalist and the control mission report by site environmental audits but also to sensitise the local population no later than 3 months before site restoration and conduct the final environmental audit upon final works acceptance which will occur 12 months after the completion of works and their provisional acceptance; (ii) one environmental focal point on the site designated by the works contractor to ensure the application of environmental measures during the construction phase; (iii) project management or technical assistance for supervising and monitoring implementation which also includes an environmentalist; (iv) the decentralised structures of the Directorate-General of Environment and Forests (DGEF), under the oversight of the Ministry of Agriculture, Fisheries and Environment responsible for periodic monitoring.

This supervision will aim to verify the effectiveness of: (i) proposed environmental and social measures, in particular, the mitigation measures; (ii) the conditions stipulated in the various legal and regulatory texts; (iii) commitments by the delegated contracting authority and the project manager; (iv) requirements relating to other laws and regulations on hygiene and public health, and the management of the population’s living environment.

In the operational phase, the monitoring programme will aim to ensure that mitigation or compensation measures for negative impacts actually play their expected role, as well as ensure that the expected positive impacts of the project’s operation will indeed be achieved.

The main objectively verifiable indicators that will be used to monitor these positive impacts will be: (i) the length of rehabilitated paved roads; (ii) the level of household income; (iii) the number of jobs created directly and indirectly and filled by men and women; (iv) the number of equipped and operational infrastructure; (v) the number of boys and girls initiated and trained; (vi) increase in the annual average daily traffic (AADT); and (vii) reduction of travel time on the project roads.

6. COST OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PROGRAMME

The total cost of the ESMP includes ISC campaigns, plans under the responsibility of the contractor, provisions for repairs to assets and other networks as well as fees for environmentalists of the Delegated Contracting Authority, the one recruited by the Contracting Authority, as well as the one at the Directorate-General of Environment responsible for periodic monitoring.

It amounts to almost KMF 89,250,000, i.e. almost EUR 181,414,524. It, therefore, represents 0.82% of the project cost. The breakdown by road is presented in Table 4 below.

Table 2: Breakdown of ESMP Costs

Items Amount Indemnification/compensation 24 000 000 Organisation, sensitisation, communication, education and implementation 4 000 000 Fees for agro-forester / 3 months 2 250 000 Fees for sociologist / 3 months 2 250 000 Fees for environmentalist / 3 months 2 250 000 Seed purchases 2 000 000 Organic fertiliser purchases 3 000 000 Training 2 500 000 Environmental control of works 16 000 000

Implementation of resettlement 19 000 000 Environmental capacity building training for local authorities 3 000 000 Training for women on the sustainability of achievements 3 000 000 Proposed cost of HSE training for this NR 2 section 6 000 000 Total 89 250 000

7. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE

The environmental assessment and the Resettlement Action Plan were carried out on the basis of a participatory process which had been initiated from the upstream stage of the project.

Finally, it is the result of the use of basic documents, digitised topographic maps and field visits, as well as interviews with representatives of the various technical departments of the ministries concerned, international organisations such as the UNDP, NGOs, private operators, socio- professional groups, people living in the road environs, government and local authorities, village chiefs and opinion leaders.

Prior to each meeting, the content of the project was presented to the group consulted in terms of economic, social, cultural and environmental challenges and in terms of mitigation and enhancement measures. Thus, the opinions and comments of the target population and groups were incorporated into this summary. Public consultations were held on the roads on this section of the NR2 in January 2019. Community meetings were held in each village involved in the project in the presence of dignitaries and imams in most cases. The population expressed its basic concerns and expectations and expressed its support for the project from a development perspective. Minutes of these meetings were prepared and can be consulted at the DGRTR.

On every occasion, the population expressed its acceptance of the project from a development perspective. The consultations resulted in an analysis of the positions, interests and influence of the various stakeholders, and the proposal of strategies for their involvement and participation in the project's implementation. Their expectations and suggestions are summarised in Table 3 below. They were taken into consideration in the project. Their questions and concerns were discussed.

Table 3: Expectations of people consulted

Expectations/suggestions  Safety measures for children relating to the works;  Integration and direct or indirect employment of mainly young people.  Development of a table of positive and negative impacts for better understanding by the population;  Installation of safety mechanisms;  Project support at social level, including women’s empowerment and youth employment;  Works will be adapted in consultation with the dignitaries when crossing villages to reduce the risk of accidents;  Recruitment of local labour force;

 Information on procedures for compensation and possible repairs to access structures and their restoration;  Recruitment of local labour force; and  Establishment of a grievance management mechanism.

During the preparation and appraisal mission, all public administration actors (MATUAF, DGRTR, PIU, etc.) were consulted as well as local communities.

During project implementation, all partners will be regularly consulted through village meetings. The ESMP summary has also been published on the Bank's website.

8. CONCLUSION

The environmental and social assessment shows that the project’s implementation will have some localised negative impacts on the socio-cultural and socio-economic environments during 19 rehabilitation of this NR 2 section. It will also have significant positive impacts, in particular, resilience to the effects of climate change-induced marine erosion. Potential negative impacts will have no ecological effects both in the immediate area of the project and in its vicinity, as they are technically confined within reasonable limits or sometimes offset by appropriate corrective measures set out in the proposed ESMP. Measures to improve the positive impacts have reinforced the project scope.

The project is considered to be environmentally and socially acceptable. It was issued a certificate by the National Directorate of Environment and Forests/Ministry of Production, Environment, Energy, Industry and Handicrafts (DNEF/MPEEIA).

9. REFERENCES and CONTACTS

• ESIA_ESMP Technical Report on the Panda-Ifoundihé Section R3 version, June 2019

• RAP Technical Report on NR 2- R3 version, June 2019

Contacts: For further information, please contact the following country contact resource persons:

COUNTRY CONTACT

MPEEIA Moustadroine ABDOU, +269 75 00 01 DGRTR / Ministry of Bakari MOINDJIE, [email protected] Transport r Directorate-General of Youssouf Elamine elamine_youssouf@yah Environment and Forests MBECHEZI oo.fr Stakeholders Ministry of Finance, Economy, Said Ali CHAYHANE Budget, Investment and Cabfinances.km@gmail. External Trade com PIU, Consultant Ibrahim ATHOUMANI ibrahimassoumani70@g mail.com

AfDB Contacts J. NDIKUMWAMI, Principal Team Leader RDGC.1/COCM 6830 Transport Engineer B.I. BCHIR, Environmentalist, RDGN.4 1447 O. FALL, Environmentalist SNSC, HQ 4636 M. DIOMANDE, Financial RGDE.4 8243 Management Specialist H. YAMUREMYE, Social RDGE.2/COBI 7006 Development Specialist Team Members A. NUGU, Procurement RDGE 8362 Project Team Specialist, Consultant R. BEN GHANEM, Transport RDGE.3/ COBI Engineer, Consultant H. ETENDE NKODO, Transport Economist, RDGE.3 Consultant Director-General Gabriel NEGATU RDGE 8232 Sector Director Amadou OUMAROU PICU 3075 Deputy Director-General Nnenna NWABUFO RDGE 8343 Sector Division Manager Hussein Yusuf IMAN RDGE.3 2525

Road Network Rehabilitation RN2 Annex 1: ESMP Matrix

Impact receiver Impact Recommended measures Implement Actors Objectively verifiable Verification means Order of priority description ation indicators period

Biophysical Environment Dust and smoke - water sections affected by Commence -Contractor Road sections are generated by the the works ment of and watered during works, Control and works on site and - regularly change machine during Machines have oil Supervision Report by borrow areas engine oil construction changed regularly and contractor’s - ensure that workers wear normally (with labels) environmentalist Air Quality dust masks (PPE: Personal Essential (monthly report), Protective Equipment) in all control mission cases (monthly report) and PIU (quarterly mission report), Groundwater - Clean the rights-of-way of During - Contractor’s QHSE Application of hygiene Control and pollution the different workshops upon works manager and safety rules Supervision Report by Water Quality completion of works implementat - Project manager’s PIU environmentalist, Very high priority - regularly collect liquid waste ion environmentalist control mission and from sites for disposal contractor

- Risk of - Establish a used oil During and - Contractor’s QHSE No contaminated sites Site and DGRTR log deterioration of soil collection system after works manager books quality - Stabilise the slopes -PIU environmentalist - Erosion control in -after each intervention Soil run-off area restore everything to original Very high priority -modification of soil state morphology

No destructive Take every precaution to During - Local population Ecology not disturbed Population surveys impact on wildlife prevent accidents with wildlife works - DGE Fauna habitats Priority

Nuisances to Replant borrow areas, level During and - Contractor Borrow area restored Visits to borrow areas Borrow pits, wildlife and slopes and restore water after works - Project manager Ecology not disturbed and site facilities Quarries and Site population flows - DGE Priority Facilities

Reduce visual Reforestation and On works - local population - presence of trees Visit to borrow areas impact on afforestation where road completion - DGE - number reforested landscape crosses small urban areas -natural state observed Landscape Essential and at borrow area level and restored Prevent natural environment phase-shifts Human Environment - Risk of personal Apply hygiene and safety During - Contractor Number of on-site Site log injury and material rules at work works - Project manager accidents Verification by DBE incidents Provide all field workers with implementat Report the number of and DGRTR HSE Health and Safety Very high priority - Risk of PPE ion accidents per day officer pulmonary infection

Recruitment of Train population in LI Before site - Contractor Number of workers Contractor’s activity local labour techniques and in basic installation - Project manager hired and trained report Employment knowledge of the HSE and during Priority system to be applied in the works field Improve the level - place signposts in high risk During and -Contractor -Level of road traffic Activity reports of of road services, areas after works - DGRTR -risk of accidents DGRTR, the road and the movement - Install speed humps and -Road security reduced or zero brigade and Traffic Very high priority of goods and bumps (gendarmerie brigade) - traffic fluid contractor persons - Ensure police presence at specific points on the road Agriculture Development of Rapid disposal of agricultural After the Ngazidja Chamber of Routine maintenance Activity report of the Indispensable Agriculture products works Agriculture works performed Chamber of Agriculture Development of Carry out routine road During the - chambers of commerce Increase in volume of Activity Report by trade and transport maintenance for sustainable construction - haulier unions goods and travellers Regional Directorate Trade and sectors benefits and - DGRTR Road lifespan of Trade and Essential Transport Fight against highway operational Transport and robbers phases DGRTR Development of Carry out routine road During and National Directorate and Number of tourists Survey of hotels and tourism maintenance for sustainable after works Tourism Board Free movement travellers Tourism Activities Priority benefits Contractor Ensure road safety DGRTR - Minimise risks of - Identify pipes in Before and - contractor - quantity of damaged Activity reports of site reduction of underground networks during - underground network infrastructure engineer, the project underground - Establish site workshops far works operators - number of incidents coordinator control Infrastructure and networks from schools, mosques, and accidents in mission and Priority Cultural Heritage - Minimise sound public places and in schools and public contractor nuisances in interaction with other places… schools companies Improve women’s Create and finance income- During and - Contractor Number of projects for Economic and health living conditions generating activities for after works women survey of women and Women's living Spare women from women - Ministry of nearby hospitals conditions and the STDs Sensitise women in the area Health, Solidarity, Number of women fight against who benefit from small-scale Social Protection infected and sick Priority HIV/AIDS projects on the dangers of and Gender STDs Promotion Red Cross and health NGO

Annex 2:

Road Network Rehabilitation concerning the Panda-Ifoundihé Section on the NR 2

Environmental Technical Specifications

Environmental and social clauses relating to works implementation:

Provisions relating to the sensitisation of site personnel on the project’s environmental issues and accident risks

The contractor’s Q-HSSE should carry out sensitisation campaign for local residents and site personnel on the project’s environmental issues, especially the possible risks of accidents.

This campaign will continue throughout the duration of the works to mitigate the risks of accidents and various nuisances for the population and wildlife. The following will be prohibited:

- Night work in small urban centres;

- Movement of heavy machinery (trucks, bulldozers, etc..) during the night in small urban centres;

- The use of toxic and eco-toxic chemical products;

- Consumption of narcotics and alcohol on-site, in the quarry and living quarters.

Prior to the departure of an exceptional load all measures will be taken by the contractor’s environmentalist and, in the event of an accident, he/she will be the first to be questioned by the PIU and control mission environmentalist.

Provisions on hygiene, construction site cleanliness and remote site pollution prevention

Provisions for worksite and base camp hygiene and cleanliness will be added to the internal regulations of the company in charge of the works:

- Waste sorting is mandatory et waste containers and refuse bins must be available in the base camp and in the crushing quarry;

- It is forbidden to dispose of waste materials or volatile materials such as mineral spirits and oil or paint thinners or waste linked to geotechnical assay activities by pouring them on the ground, into water courses, and into coastal areas;

- Hazardous waste (oily liquid or solid) from the site should be collected regularly, stored in confined areas and disposed of by appropriate methods used in that field;

- Carry out maintenance work on vehicles and machinery in a designated place;

- Provide on-site a supply of absorbent materials as well as well-identified and sealed containers for petroleum residues and waste;

- Under constant supervision, undertake all handling of hazardous substances or

- Contaminants;

- Store hazardous substances in watertight containers in safe, weatherproof storage areas. Keep storage areas locked and check the inventory of these substances;

- The contractor must place dust detectors around the crushing quarry and in offices to allow the environmentalist to assess air quality;

- Every morning, drivers must take a breathalyser test to check their blood-alcohol level.

Provisions for combating soil erosion

The company should implement the following measures to combat erosion:

- Observe deadlines for earthworks in areas that do not impede the normal flow of water downstream of the structures;

- Place rip-rap or gabions in areas with strong currents or marshes;

- Reinforce embankments and backfills with rip-rap, gabions, masonry fragments or by plant protection; and

- Carry out works before the rainy season

Provisions related to marine wildlife protection

The contractor is prohibited from carrying out temporary improvements (storage and parking areas, bypass road or works) in wetlands and coastal areas.

Site Installation

• Construction of base camp and machinery parking area

The base camp will be installed 500m. from surface water points (water course, marshland), in order to reduce their pollution levels.

The base camp and parking area will be located away from built-up areas to avoid nuisances such as odours from hydrocarbons, noise, etc.

• Opening of detours, various access tracks

The choice of detours, access routes to borrow areas for materials and water collection stations for works purposes should be made carefully to avoid areas of biological diversity (flood-prone areas)

Clearing

Before clearing, the area to be cleared will be demarcated by the contractor and an inventory will be carried out in the presence of the PIU and the control mission to prevent social conflicts when clearing commences. The right-of-way will also be watered during clearing to avoid raising dust. Care should be taken to avoid destroying topographical markers and other works carried out by land registration services.

Earthworks

The requirement to water earthworks areas should be strictly observed. The areas will be watered as much as required by the control mission, especially the stretches of road crossing built-up areas.

Water collection for work purposes

Water pumps used for collecting water for construction must be in good working order to avoid diesel and oil leaks likely to pollute water (rivers or swamps) used for human and animal consumption.

Any spillage or discharge of any type of wastewater, hydrocarbons and pollutants into surface water and the soil will be strictly prohibited.

Construction of Sanitation Facilities

The earth from excavation works will be removed to ensure the premises are clean and function properly.

Dismantling of site and removal of equipment

The grounds of the living quarters and parking area will be rehabilitated after the cleaning of solid waste (used filters, used tyres, rubble, domestic waste, etc.) and liquids.

Safety instructions

Security measures will be implemented for people living near the sites: construction sites will be marked and signposted.

In built-up areas, barriers will be erected to prevent the public and outsiders from entering construction sites.

Provision will be made for workers’ safety: wearing of dust masks, gloves and safety shoes.

Road Network Rehabilitation - Panda-Ifoundihé Section on NR 2

Annex 3: Government’s 2019 Certificates of Environmental Compliance

Annex 4: Government’s 2016 and 2019 Certificates of Environmental Compliance

Road Network Rehabilitation - Panda-Ifoundihé Section on NR 2

Annex 5: Letter of no-objection for the dissemination of report summaries