E4089 MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT (MLGRD) SANITATION AND WATER PROJECT FOR THE GREATER ACCRA METROPOLITAN AREA (GAMA) REVISED DRAFT REPORT ENVIRONMENT AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FOR SANITATION AND WATER PROJECT FOR GAMA Prepared By: Dyson T. Jumpah dyson.jumpah@gmail.com 7TH FLOOR, TRUST TOWERS FARRAR AVENUE, ADABRAKA ACCRA, GHANA. www.eemcgh.com DECEMBER 2012 LIST OF ABREVIATIONS AND ACRONYMS ARAP Abbreviated Resettlement Action Plan ARIC Audit Review Implementation Committee BOD Biochemical Oxygen Demand BP Best Practice DACF District Assemblies Common Fund DANIDA Danish International Development Agency DDF District Development Fund EA Environmental Assessment EIA Environmental Impact Assessment EMP Environmental Management Plan ESO Environment and Social Officer EPA Environmental Protection Agency ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan GAMA Greater Accra Metropolitan Area GoG Government of Ghana IGF Internally Generated Funds ILGS Institute of Local Government Studies L.I. Legislative Instrument LG Local Government MDA Ministries, Departments and Agencies MLGRD Ministry of Local Government and Rural Development MMA Metropolitan and Municipal Assemblies MMDA Metropolitan, Municipal and District Assemblies MOFEP Ministry of Finance and Economic Planning MPCU Metropolitan/Municipal Planning and Development Unit NDAP National Decentralisation Action Plan NEAP National Environmental Action Plan NGO Non Governmental Organization OP Operational Policy PEFA Public Expenditure and Financial Accountability DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 ii PFM Public Financial Management RAP Resettlement Action Plan RCC Regional Coordinating Council RPF Resettlement Policy Framework SPEFA Social Public Expenditure and Financial Accountability Groups UDU Urban Development Unit in MLGRD DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 iii Table of Contents LIST OF ABREVIATIONS AND ACRONYMS ............................................................................................................................. II EXECUTIVE SUMMARY ..................................................................................................................................................... VIII 1.0 INTRODUCTION ...................................................................................................................................................... - 1 - 1.1 BACKGROUND................................................................................................................................................................ - 1 - 1.2 PURPOSE AND STUDY OBJECTIVES OF ESMF .............................................................................................................. - 3 - 2.0 OVERALL APPROACH AND METHODOLOGY FOR ESMF PREPARATION ................................................................... - 5 - 2.1 APPROACH .................................................................................................................................................................... - 5 - 2.2 METHODOLOGY ............................................................................................................................................................. - 6 - 3.0 DESCRIPTION OF WATER AND SANITATION PROJECT FOR GAMA ........................................................................... - 7 - 3.1 CONTEXT AND OBJECTIVES OF GAMA ............................................................................................................................... - 7 - 3.2 PROJECT COMPONENTS ................................................................................................................................................... - 8 - 3.2.1 Component 1 – Provision of Water and Sanitation Services ............................................................................- 8 - 3.2.2 Component 2 – Improvement and Expansion of Water Distribution Network ................................................- 9 - 3.2.3 Component 3 – Improvement and Expansion of Wastewater and Feacal Sludge Collection, Transportation and Treatment .......................................................................................................................................................................- 9 - 3.2.4 Component 4 - Institutional and Project Management Support ......................................................................- 9 - 4.0 RESULTS OF THE PUBLIC CONSULTATION PROCESS .............................................................................................. - 10 - 4.1 CONSULTATIONS WITH MMAS ....................................................................................................................................... - 10 - 4.2 CONSULTATIONS MINISTRIES DEPARTMENTS AND AGENCIES .................................................................................................. - 11 - 5.0 GAMA BASELINE PROFILE ..................................................................................................................................... - 12 - 5.1 BACKGROUND.............................................................................................................................................................. - 12 - 5.2 ADMINISTRATIVE STRUCTURE ................................................................................................................................. - 12 - 5.3 PHYSICAL CHARACTERISTICS ............................................................................................................................................ - 13 - 5.4 GEOLOGY AND CLIMATE ................................................................................................................................................. - 14 - 5.5 VEGETATION ................................................................................................................................................................ - 15 - 5.6 DRAINAGE ................................................................................................................................................................... - 17 - 5.7 AIR QUALITY ................................................................................................................................................................ - 20 - 5.8 DEMOGRAPHY .............................................................................................................................................................. - 21 - 6.0 POLICY, LEGAL, INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT ........................................ - 24 - 6.1 NATIONAL ENVIRONMENTAL REQUIREMENTS..................................................................................................................... - 24 - 6.1.1 Ghana’s Environmental Policy........................................................................................................................- 24 - 6.1.2 National Water Policy ....................................................................................................................................- 24 - 6.1.3 Environmental Sanitation Policy ....................................................................................................................- 25 - 6.1.4 The Environmental Protection Agency Act .....................................................................................................- 26 - 6.1.5 EA Regulations and Procedures .....................................................................................................................- 27 - 6.1.6 EA (Amendment) Regulations, 2002 ..............................................................................................................- 27 - 6.1.7 Local Government Act, 1993 (Act 462) ..........................................................................................................- 27 - 6.2 NATIONAL LABOUR, SAFETY AND HEALTH REQUIREMENTS ................................................................................................... - 28 - 6.2.1 Factories, Offices and Shops Act ....................................................................................................................- 28 - 6.2.2 Occupational Safety and Health Policy of Ghana (Draft) ...............................................................................- 28 - 6.2.3 National Workplace HIV/AIDS Policy .............................................................................................................- 28 - 6.2.4 Labour Act ......................................................................................................................................................- 28 - DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 iv 6.3 THE GHANA SHARED GROWTH AND DEVELOPMENT AGENDA (GSGDA) ................................................................................. - 28 - 6.4 THE POVERTY REDUCTION STRATEGY OF GHANA ................................................................................................................ - 29 - 6.4.1 GPRS I and II ...................................................................................................................................................- 29 - 6.5 THE WORLD BANK REQUIREMENTS.................................................................................................................................. - 29 - 6.5.1 The Bank’s Safeguard Policies ........................................................................................................................- 29 - 6.5.2 Triggered Safeguard Policies ..........................................................................................................................- 32 - 6.6 ENVIRONMENTAL SANITATION POLICY .............................................................................................................................. - 32 - 6.6.1 Solid Waste Management ..............................................................................................................................- 32 - 6.7 INTERNATIONAL CONVENTIONS ....................................................................................................................................... - 33 - 6.8 INSTITUTIONAL FRAMEWORK .......................................................................................................................................... - 33 - 6.8.1 Ministry of Environment, Science and Technology ........................................................................................- 33 - 6.8.2 Ministry of Local Government and Rural Development .................................................................................- 34 - 6.8.3 Ministry of Water Resources Works and Housing ..........................................................................................- 34 - 6.8.4 Ministry of Finance and Economic Planning ..................................................................................................- 35 - 6.8.5 Ministry of Roads and Highways....................................................................................................................- 35 - 7.0 POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE GAMA PROJECTS AND MITIGATION ....................... - 36 - 7.1 POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS............................................................................................................... - 37 - 7.1.1 Maternal Mortality: .......................................................................................................................................- 38 - 7.1.2 Other Diseases: ..............................................................................................................................................- 38 - 7.1.3 Environmental Sustainability: ........................................................................................................................- 38 - 7.1.4 Improvement of the living conditions ............................................................................................................- 38 - 7.1.5 Water Supply Project .....................................................................................................................................- 39 - 7.1.6 Excreta and Wastewater Services ..................................................................................................................- 40 - 7.1.7 Economic Benefits to MMAs ..........................................................................................................................- 40 - 7.1.8 Enhanced Institutional Capacity to Support Decentralization .......................................................................- 41 - 7.1.9 Conclusion ......................................................................................................................................................- 41 - 7.2 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS, ................................................................. - 42 - 7.2.1 Environmental Impact Assessment ................................................................................................................- 42 - 7.2.2 Operational Phase Impacts ............................................................................................................................- 43 - 7.2.3 Social Impacts ................................................................................................................................................- 47 - 7.3 MITIGATION MEASURES ................................................................................................................................................ - 48 - 7.3.1 Construction Phase Impacts ..........................................................................................................................- 48 - 7.3.2 Post Constructional Phase impacts ...............................................................................................................- 50 - 7.4 INTEGRATION OF THE EMP ...................................................................................................................................... - 55 - 7.4.1 Environmental Management ..........................................................................................................................- 55 - 7.4.2 Objectives of Program ...................................................................................................................................- 55 - 7.4.3 Resources for Programme Implementation....................................................................................................- 56 - 7.5 MONITORING ............................................................................................................................................................ - 58 - 7.5.1 Construction Phase ........................................................................................................................................- 58 - 7.5.2 Operation and Maintenance Phase ................................................................................................................- 59 - 8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) ................................................................. - 60 - 8.1 THE ENVIRONMENTAL AND SOCIAL SCREENING PROCESS ...................................................................................... - 60 - 8.1.1 The Screening Process ...................................................................................................................................- 61 - 8.1.2 Responsibilities for the Implementation of the Screening Process ................................................................- 72 - 8.2 MITIGATION MEASURES ................................................................................................................................................ - 73 - 8.2.1 General mitigation measures .........................................................................................................................- 73 - 8.2.2 Specific construction impacts mitigation measures .......................................................................................- 74 - 8.3 MONITORING PLAN ...................................................................................................................................................... - 76 - 8.4 RESPONSIBILITY AND INSTITUTIONAL ARRANGEMENT FOR IMPLEMENTATION AND MONITORING ................................. - 78 - 8.4.1 Institutions responsible for implementation ................................................................................................- 78 - 8.4.2 Project Institutional and Implementation Arrangements ..............................................................................- 79 - DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 v 8.5 CAPACITY STRENGTHENING FOR ESMP IMPLEMENTATION ................................................................................................... - 82 - 8.5.1 Capacity Building Program and Awareness ...................................................................................................- 83 - 8.5.2 Technical strengthen measures .....................................................................................................................- 83 - 8.6 ESMF IMPLEMENTATION SCHEDULE ................................................................................................................................ - 84 - 8.7 ESTIMATED BUDGET ..................................................................................................................................................... - 84 - 8.8 ESMF/ ESMP DISSEMINATION AND PUBLIC DISCLOSURE ..................................................................................................... - 86 - 9.0 REFERENCES ......................................................................................................................................................... - 92 - 10.0 ANNEXES.......................................................................................................................................................... - 93 - ANNEX 1A: ENVIRONMENTAL AND SOCIAL SCREENING (ESS) OF SUB-PROJECTS ............................................................. - 93 - ANNEX 1B: STANDARD FORMAT FOR SCREENING REPORT ................................................................................................ - 95 - ANNEX 1C: SCREENING REPORT-ENVIRONMENTAL AND SOCIAL CHECKLIST .................................................................... - 98 - ANNEX 2: STANDARD FORMAT FOR ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) .................................. - 99 - ANNEX 3: GUIDANCE ON ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN BY PROJECT PHASES ................................. - 100 - ANNEX 4: DRAFT TERMS OF REFERENCE FOR SUB-PROJECT REQUIRING AN ESIA ......................................................... - 103 - ANNEX 5: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS .......................... - 105 - ANNEX 6: SUMMARY OF WORLD BANK SAFEGUARD POLICIES AND HOW THEY WILL APPLY TO THE FUTURE PROJECT ACTIVITIES ............. - 113 - ANNEX 7: LIST OF INDIVIDUALS/INSTITUTIONS CONTACTED ........................................................................................... - 115 - ANNEX 8: TERMS OF REFERENCE FOR GAMA ESMF .................................................................................................................. - 117 - LIST OF TABLES TABLE 5-1: DEMOGRAPHIC FIGURES OF AMA BY SUB-METROS .......................................................................................................... - 21 - TABLE 5-2: POPULATION AND POPULATION GROWTH RATE ................................................................................................................ - 22 - TABLE 5-3: POPULATION PROJECT OF AMA BY SUB-METROS ............................................................................................................. - 22 - TABLE 5-4: PROJECTED POPULATION DENSITY PER HECTRE................................................................................................................. - 23 - TABLE 7-1: STATUS OF SAFEGUARD WORK ...................................................................................................................................... - 36 - TABLE 8-1: STRUCTURES INVOLVED IN THE GAMA ENVIRONMENT AND SOCIAL MANAGEMENT ................................................................ - 61 - TABLE 8-2: CATEGORY OF ENVIRONMENTAL STUDIES ........................................................................................................................ - 66 - TABLE 8-3: PROCEDURES FOR EIA ................................................................................................................................................. - 67 - TABLE 8-4: PROCESS MONITORING INDICATORS OF ESMP MEASURES ................................................................................................. - 70 - TABLE 8-5: INDICATORS AND MONITORING MECHANISM OF ENVIRONMENTAL AND SOCIAL ISSUES ............................................................ - 71 - TABLE 8-6: SUMMARIZED ENVIRONMENTAL SCREENING PROCESS AND RESPONSIBILITIES ......................................................................... - 72 - TABLE 8-7: GENERAL MITIGATION MEASURES ................................................................................................................................. - 73 - TABLE 8-8: SUMMARY OF ENVIRONMENTAL MITIGATION MEASURES ................................................................................................... - 74 - TABLE 8-9: RESULTS AND INDICATORS FOR THE SANITATION AND WATER SECTOR .................................................................................. - 77 - TABLE 8-10: INSTITUTIONS RESPONSIBLE FOR IMPLEMENTATION OF ESMP ........................................................................................... - 78 - TABLE 8-11: INSTITUTIONAL ARRANGEMENTS FOR ESMP IMPLEMENTATION......................................................................................... - 81 - TABLE 8-12: TRAINING SCHEDULE ................................................................................................................................................. - 83 - TABLE 8-13: TIME TABLE FOR IMPLEMENTATION AND MONITORING OF ENVIRONMENTAL ACTIVITIES ........................................................ - 84 - TABLE 8-14: ESTIMATED COSTS OF TECHNICAL MEASURES................................................................................................................. - 85 - TABLE 8-15: TRAINING AND AWARENESS MEASURES COSTS............................................................................................................... - 85 - TABLE 8-16: SUMMARIZED ESTIMATED BUDGET FOR ENVIRONMENTAL AND SOCIAL IMPACT MANAGEMENT ............................................... - 86 - TABLE 8-17: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ....................................................................................................... - 87 - TABLE 10-1: ENVIRONMENTAL AND SOCIAL CHECKLIST ...................................................................................................................... - 98 - TABLE 10-2: GUIDANCE ON ESMP BY PROJECT PHASES .................................................................................................................. - 100 - DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 vi LIST OF FIGURES FIGURE 5-1 : MAP OF GREATER ACCRA AREA .................................................................................................................................. - 12 - FIGURE 5-2: MAP OF GREATER ACCRA AREA ................................................................................................................................... - 14 - FIGURE 8-1: ESMP IMPLEMENTATION ARRANGEMENT ..................................................................................................................... - 82 - DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 vii EXECUTIVE SUMMARY INTRODUCTION The Ministry of Local Government and Rural Development (MLGRD), with support from the World Bank, is currently preparing a Sanitation & Water Project for the Greater Accra Metropolitan Area (GAMA). The proposed project may be structured as a two-phase Adaptable Program Loan (APL) or as a Specific Investment Loan (SIL) that would be followed by other operations, given the long term engagement required to increase access to sanitation and water services in low income areas of GAMA and to attain an efficient and sustainable operation and management of the services. PPROJECT OBJECTIVES The objective of the project is to increase access to safe water and improved sanitation to people in the GAMA, with emphasis on low income communities, and to improve operation and management of wastewater facilities. In order to achieve this objective, the project would support the expansion and improvement of the water distribution network, the expansion of community water points and private water connections, the development of on-site and sewered sanitation facilities and the improved collection and treatment of wastewater and faecal sludge. Behaviour Change Campaign on hygiene, sanitation and safe water will also be promoted through social mobilization activities, as well as social accountability to ensure the sustainability of the facilities and services. The proposed project will therefore focus on providing low income communities located in the 11MMAs with increased water supply and improved sanitation services. The beneficiary MMAs are Accra Metropolitan Assembly, Tema Metropolitan Assembly,La Dade-Kotopon Municipal Assemby, Adenta Municipal Assembly, Ga South Municipal Assembly, Ga Central Municipal Assembly, Ga West Municipal Assembly, Ga East Municipal Assembly, La Nkwanta Municipal Assembly, Ledzokuku Krowor (Teshine Nungua( Municipal Assembly and Ashaiman Municipal Assembly. The proposed project weather the first phase of an APL or a SIL APL would have the following four components:  Component 1 - Provision of water and environmental sanitation services to priority low income areas of the GAMA.  Component 2 – Improvement and expansion of the water distribution network in the GAMA .  Component 3 – Improvement and expansion of wastewater and fecal sludge collection, transportation and treatment in the GAMA  Component 4 – Institutional Strengthening. Description of Prospective Projects under Components 1, 2 and 3 Under Component 1, 2 and 3, the World Bank is funding proposed Sanitation and Water Projects located in the 11 MMAs to increase water supply and improved sanitation services. The Table 7.1 below presents a non-exhaustive the list of some of the likely investments and the safeguards status ( Please note that this list is not comprehensive). DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 viii Table ES-1: Status of Safeguard Work Component 1: Status of Safeguard Work (OP 4.01 and OP 4.12) Provision of water Location Implementation EIA RPF RAP and environnemental MMAs Construction To be done if Done To be done if required sanitation services to required priority income areas MMAs Rehabilitation To be done if Done To be done if required of the GAMA required LIST OF POTENTIAL SUB-PROJECTS  Water supply and sanitation facilities for communities  Water Supply and sanitation facilities for households  Water supply and sanitation facilities for schools, health centrers and in public areas such as markets  Engagement of community and particularly women to provide oversight of water and sanitation services such as Water and Sanitation Development Board (WSDBs)  Construction of water supply system;  Drilling of boreholes;  Mechanization of boreholes;  Construction of KVIPs;  Construction of water closet seaters;  Rehabilitation of public toilet;  Construction and lining of drains; Component 2: Status of Safeguard Work (OP 4.01 and OP 4.12) Improvement and Location Implementation EIA RPF RAP expansion of the MMAs Construction To be done if Done To be done if required water distribution required network in the MMAs Rehabilitation To be done if Done To be done if required GAMA required LIST OF POTENTIAL SUB-PROJECTS  Investments to improve and expand the existing network to provide piped water to the targeted people living in low income communities in the GAMA  Installation of transmission mains, boster pumps and other facilities  Support acquisition and installation of meters and other equipment as well as provision of services aimed at improving water demand management Component 3: Status of Safeguard Work (OP 4.01 and OP 4.12) Improvement and Location Implementation EIA RPF RAP expansion of MMAs Construction To be done if Done To be done if required wastewater and fecal required sludge collection, MMAs Rehabilitation To be done if Done To be done if required transportation and required treatment in the GAMA LIST OF POTENTIAL SUB-PROJECTS  Collection and/or treatment of wastewater and fecal sludge to be generated from the low income communities and rest of GAMA  Improve the safe collection, transport and treatment of fecal sludge DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 ix ENVIRONMENTAL AND SOCIAL ISSUES RELEVANT TO THE PROJECT The potential environmental and social impacts of these investments are not currently known, even though they are likely to be significant. Since the exact location, nature and number of sanitation and water facilities and/or services are not known, MLGRD is required to prepare an Environmental and Social Management Framework (ESMF) to ensure that all investments are adequately screened for their potential environmental and social impacts, and that correct procedures to be followed, depending on the types of investments to be carried out, and these will be reflected in the ESMF document. In pursuant to the requirements of the World Bank, including OP / BP 4.01, an ESMF is prepared by the Government of Ghana (GoG) as a requirement for the implementation of the GAMA. Furthermore, the World Bank requires that the description of measures taken by the GoG represented by the Ministry of Local Government and Rural Development (MLGRD) (the Borrower) to address the safeguard policy issues and undertake an assessment of MMAs and MLGRD’s capacity to plan and implement the measures proposed to be addressed in the ESMF. PURPOSE AND STUDY OBJECTIVES OF ESMF The objective of the assignment is to prepare an ESMF which will:  Establish the legal framework, procedures, and methods for the environmental and social planning, review, approval and implementation investments to be financed using the performance grant funds;  Identify roles and responsibilities, including reporting procedures and monitoring and evaluation;  Identify capacity and/or training needs for different stakeholders to ensure better implementation of the provisions in the ESMF and;  Identify funding requirements and resources to ensure effective implementation of the framework. METHODOLOGY The ESMF study has been prepared in accordance with applicable World Bank safeguard policies and Ghana environmental assessment guidelines. The distinct phases of the study include:  Data Gathering;  Consultations and discussions with MLGRD, MWRWH, GAMA, MMAs, EPA and NGOs;  Literature review;  Environmental screening and scoping;  Determination of potential impacts;  Identification of impact mitigation measures;  Preparation of an Environmental and Social Management Plan; and  Preparation of sub-project guidelines. GAMA BASELINE PROFILE As shown in the maps, the city of Accra actually covers AMA, as well as parts of Ga West, Ga South, Ga East, Tema Metropolitan Area (TMA), Ashaiman and Adenta. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 x The report of the fifth round of the Ghana Living Standards Survey (GSS, 2008), defines the Accra Metropolitan Area (AMA), Tema Municipal Area (TMA) (which at that time also covered Ashaiman and Adenta municipality), and the urban areas in Ga East and Ga West (which at that time included Ga South) Districts as the Greater Accra Metropolitan Area (GAMA). The GAMA area covers a total area of about 1,261 km2 (Twum, 2002). Demographic Characteristics The 2010 estimated population of Accra, pending the result of the 2010 PHC, is about 4.3 million with additional daily influx population of 1 million who commute to the City for various socio-economic activities, which most often are nonexistent thereby resorting to social vices and economic crimes. POLICY, LEGAL, INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT The environmental policy and EA legislation and procedures of Ghana and those of the World Bank, which are relevant to the Project, are outlined. In principle the two sets of policies and procedures on environmental and social assessment are similar in many respects. NATIONAL ENVIRONMENTAL REQUIREMENTS Ghana’s Environmental Policy The environmental policy of Ghana formulated in the National Environmental Action Plan (NEAP) of 1993 hinges strongly on ‘prevention’ as the most effective tool for environmental protection. The policy aims at a sound management of resources and environment, and the reconciliation between economic planning and environmental resources utilization for sustainable national development. It also seeks among others, to institute an environmental quality control and sustainable development programs by requiring prior EA of all developments, and to take appropriate measures to protect critical eco-systems, including the flora and fauna they contain against harmful effects, nuisance or destructive practices. The adoption of the NEAP led to the enactment of the EPA Act 1994 (Act 490); and subsequently the passing of the Ghana EIA Procedures into the EA Regulations, 1999 (LI 1652). National Water Policy Consistent with the GPRS, the overall goal of the National Water Policy is to "achieve sustainable development, management and use of Ghana's water resources to improve health and livelihoods, reduce vulnerability while assuring good governance for present and future generations". This will be achieved by addressing relevant issues under water resources management, urban water supply and community water and sanitation. For each broad area, a number of focus areas for policy considerations have been identified. Within each the main principles and challenges are listed followed by policy objectives and the corresponding measures. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xi Environmental Sanitation Policy The Environmental Sanitation Policy (Revised, 2010) responds to the various reviews carried out to assess how effectively the previous policy published in 1999 has been implemented. The revised policy objectives and measures are presented in a way that enhances strategic planning and subsequent implementation. The Environmental Protection Agency Act The Environmental Protection Agency (EPA) Act, 1994 (Act 490) grants the Agency enforcement and standards setting powers, and the power to ensure compliance with the Ghana EA requirements/procedures. Additionally, the Agency is required to create environmental awareness and build environmental capacity as relates all sectors, among others. The Agency (including its Regional and District Offices) is also vested with the power to determine what constitutes an ‘adverse effect on the environment’ or an activity posing ‘a serious threat to the environment or public health’, to require EAs, EMPs, Annual Environmental Reports (AERs), etc of an ‘undertaking’, to regulate and serve an enforcement notice for any offending or non-complying undertaking. The Agency is required to conduct monitoring to verify compliance with given approval/permit conditions, required environmental standard and mitigation commitments. Furthermore, a requirement by EPA for an EA precludes any authorising MDA from licensing, permitting, approving or consenting such undertaking, unless notified otherwise. EA Regulations and Procedures The EA Regulations combine both assessment and environmental management systems. The regulations prohibit commencing an undertaking/activity without prior registration and environmental permit (EP). Undertakings are grouped into schedules for ease of screening and registration and for EP. The schedules include undertakings requiring registration and EP (Schedule 1), EIA mandatory undertakings (Schedule 2), as well as Schedule 5- relevant undertakings (located in Environmentally Sensitive Areas). The Regulations also define the relevant stages and actions, including: registration, screening, preliminary environmental assessment (PEA), scoping and terms of reference (ToR), environmental impact assessment (EIA), review of EA reports, public notices and hearings, environmental permitting and certification, fees payment, EMP, Annual Environmental Report (AER), suspension/revocation of permit, complaints/appeals, etc. Local Government Act, 1993 (Act 462) The Local Government Act (Act 462) seeks to give a fresh legal expression to government’s commitment to the concept of decentralization. It is a practical demonstration of a bold attempt to bring the process of governance to the doorstep of the populace at the Regional and more importantly, the District level. The Metropolitan, Municipal and District Assemblies (MMDAs) created under the law, constitute the highest political authority in each district, municipality and metropolis. Other relevant legislative, regulative and administrative regimes considered are:  The Factories, Offices and Shops Act of 1970 (Act 328); DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xii  Occupational Safety and Health Policy  National Workplace HIV/AIDS Policy;  Labour Act, 2003 (Act 651);  Ghana Shared Growth and Development Agenda (2010-2013);  Ghana Poverty Reduction Strategy (GPRS I & II);  World Bank Safeguards Policies  Ghana Environmental Sanitation Policy;  Relevant International Conventions and Protocols; and  Institutional Framework. POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE GAMA PROJECTS AND MITIGATION Description of Prospective Projects under Components 1, 2 and 3 Under Component 1,2 and 3, the World Bank is funding this proposed Sanitation and Water Project that aims at increasing access to improved sanitation and safe water in the GAMA, with particular emphasis on low income areas. The GoG is seeking support from the WBG given its experience with the implementation of water and environmental sanitation projects in Ghana and in dealing with low income areas and institutional aspects. The proposed project will therefore focus on providing low income communities located in the 8 MMAs with increased water supply and improved sanitation services. The Table ES.1above presents the list of some of the likely investments and the safeguards status (Please note that this list is not comprehensive). POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS The overall environmental impact of the project is expected to be positive. Significant positive impacts to the natural and socioeconomic environments will be achieved by the participating MMAs. By developing infrastructure, the capacity of the MMAs to deliver quality services will be improved. The positive environmental and social impacts for Water and Sanitation include information relevant to the construction, operation and maintenance of (i) potable water treatment and distribution systems, and (ii) collection of sewage in centralized systems (such as piped sewer collection networks) or decentralized systems (such as septic tanks subsequently serviced by pump trucks) and treatment of collected sewage at centralized facilities . Key expected positive results or outcomes are as follows:  Improved Conservation and Preservation of Water  Sustainable Water Supply  Reduced vulnerability of ecosystem to climatic events  Improved use of Water and Sanitation  Sustainable water supply  Reduced vulnerability of ecosystem to climatic events  Increase Employment  Improved conditions for economic growth DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xiii  General economic growth  Poverty reduction  Increased affordability of water and sanitation  Increased access to water  Reduced rate of water related diseases  Improved social development  Improved health  Poverty reduction  Greater equity in allocation of water and sanitation  Increased access to basic sanitation  Increased access to water  Reduced rate of water related diseases  Improved health  Improved quality of water and sanitation  Increased access to basic sanitation  Reduced rate of water related diseases  Improved health  Improved water and sanitation , health and hygiene behaviour The Sanitation and Water Facilities Project in the GAMA will result in:  Generic improvement within the Metropolis and Municipalities for water and sanitation projects:  Improvement in the hygienic conditions and public health There will be an improvement in the environment, and hygienic conditions of the city due to provision of efficient water and sanitation facilities. The prevailing trends of morbidity and mortality are likely to change. The present health statuses of these communities are characterized by high morbidity rate from occasional outbreak of preventable and infectious diseases like cholera and typhoid fever. High occurrence of Malaria is also prevalent as a result of poor drainage facilities and the malaria, which is endemic, will be reduced as a result of the drainage to be provided.  Employment generation There will be employment generation for unskilled labourers during the construction stage of various Sanitation and Water facilities. Thus the project has the potential to contribute to economy through labour absorption and the supply of construction materials.  Improve access to basic water and sanitation services There will be an access to basic services like water supply as these will be supplied and be connected.  Gender-Status of Women The provision of the water and sanitation facilities is expected to enhance the lot of women in the project areas. Apart from those who will be employed directly on the project, others will be engaged in trading at the construction sites supplying the workforce with food and other consumables. Although the numbers will not be disproportionately high a vibrant and booming trade for the women implies an improvement in living standards of the people. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xiv IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS, The proposed Sanitation and Water works will have an impact on the environment. The potential impacts of the development are both adverse and beneficial. An assessment of the negative impacts can be classified into construction phase and post-construction phase impacts. Environmental Impact Assessment Constructional Phase Impacts The constructional works would present negative environmental impacts. The construction phase includes the following operations: site clearing, excavation and grading, upgrading of drains, installation of utility services (electricity and water supply). These activities will have direct impact on the environment. Some of the negative impacts are:  Soil and Land Degradation  Air Quality  Vehicular Traffic Implication  Noise Levels and Ground Vibration  Constructional Wastes Generation  Occupational Health and Safety Operational Phase Impacts  Water Withdrawal Impact  Water Treatment Environmental issues associated with water treatment include:  Solid waste generation  Wastewater generation  Hazardous chemicals  Air emissions  Water Quality  Water system leaks and loss of pressure  Water discharges  Sanitation  Fecal Sludge and Septage Collection Sewerage treatment and disposal The most significant potential environmental impacts associated with wastewater collection arise from:  Domestic wastewater discharges  Industrial wastewater discharges  Leaks and overflows Wastewater and Sludge Treatment and Discharge The most significant environmental impacts related to wastewater and sludge treatment, discharge, and use include:  Liquid effluents  Solid waste  Air emissions and odors  Hazardous chemicals  Ecological impacts DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xv Social Impacts The Potential Negative Impacts  Disruption of Utility Services  Dumping of solid waste and rubbish into the drains  Accidents  Inconvenience to be caused due to delays in payment  Restricted Access to Source of Livelihood ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) During the implementation of Sanitation and Water Project activities in the GAMA , potential environmental and social impacts must be considered and managed. The impacts must be mitigated, minimized or preferably avoided particularly to meet the requirements of World Bank safeguards policies and Ghana national law requirements. The objective of the ESMF is to outline the institutional arrangements relating to: (i) identification of environmental and social impacts arising from activities under the GAMA projects, (ii) the implementation of proposed mitigation measures, (iii) Capacity Building and (iv) Monitoring. The ESMP will be included in a manual of Operations. The ESMF outlines mechanisms for:  Screening of proposed sub-projects, identifying potential environmental and social impacts and management of safeguard policies implications;  Institutional arrangements for implementation and capacity building  Monitoring ESMF measures implementation;  Public consultation;  The estimated costs related to the ESMF. ESMF Implementation Arrangement MLGRD is the lead implementing agency for the GAMA. The Project Coordinating Unit (PCU) of the Ministry of Local Government and Rural Development is the entity designated by MLGRD to manage the project. PCU will also supervise the implementation of the ESMF by the MMAs. The Municipal/Metropolitan Planning and Coordination Committees (MMPCUs) (and directly the Planning Officer) of the MMAs will execute the provisions of the ESMF on the ground. The Ministry of Local Government and Rural Development (MLGRD) will recruit an Environmental and Social Officer (ESO). The ESO’s main task is ensure that MMA comply with environmental and social safeguards requirements, including reviewing screening documents from MMAs, reviewing, overseeing, and participating in EIA reviews and implementation, monitoring activities of mitigation measures implementation and act as the interlocutor of the GAMA, MLGRD and MMAs (MMPCUs). MLGRD will also disseminate and disclose the ESMF/EMP and any EIA. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xvi Responsibilities for the Implementation of the Screening Process The ESMF will be implemented by MLGRD. MLGRD will collaborate with the EPA and the World Bank to ensure effective execution. Table ES.2 provides a summary of the stages and institutional responsibilities for the screening, preparation, assessment, approval and implementation of the GAMA activities. The extent of environmental assessment that might be required prior to the commencement of the sub-projects will depend on the outcome of the screening process. The key stages of the environmental and social screening process leading to the review and approval of the GAMA activities to be implemented are described below: Table ES.2: Summarised Environmental Screening Process and Responsibilities Stage Management Implementation responsibility responsibility 1. Screening Environmental and Social Sanitation and MLGRD/MMAs MMPCU Planning Officer1 Water Project: Selection including public consultation 2. Determination of appropriate environmental categories 2.1 Selection validation MMPCU, Planning Officer 2.2 Classification of Project EPA, MMPCU and Planning Determination of Environmental Work MLGRD/MMAs Officer Review of screening 3. Implementation of environmental work MLGRD/MMAs MMPCU and Planning Officer in the MMAs, 3-1. If EIA is necessary MMPCU 3.1.a Preparation of terms of reference MLGRD/MMA MMPCU 3.1 b Selection of Consultant MLGRD MMA 3.1 c Realization of the EIA, Public Consultation MMPCU/MLGRD Environmental Consultant Integration of environmental and social management MMPCU and Planning Officer plan issues in the tendering and project implementation, Procurement and Works Department Units of MMAs/ MLGRD 4 Review and Approval 4.1 EIA Approval EPA EPA, , World Bank 5. Public Consultation and disclosure MLGRD/EPA MMPCU and Planning Officer 6. monitoring /MMAs/EPA MMPCU and Planning Officer 7 Development of monitoring indicators for EIA as MLGRD MMPCU and Planning Officer may be stipulated under tbe environmental permitting conditions. 1 If necessary, the MPCU can assign a designated, capable officer to carry out the screening process if MPCU sees that need. However, the planning officer will still be the final signatory to the screening format. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xvii MONITORING PLAN Oversight for the environmental and social management process of the sub-projects will be assured by the Planning Officers (POs) and the Environmental Health Officers (EHOs) in collaboration with the MLGRD. Monitoring will be conducted during all phases of the project. The monitoring plan does not restrain MPCUs to take up their normal monitoring role at MMA level, including in areas of environment protection. There will be two tracks for oversight and management of safeguards in sub projects. The screening process at MMA level will take place as part of the annual planning and budgeting process. Any sub project under the Urban Development Grant will be subject to screening led by Planning Officer and submitted to review for the Development Planning Subcommittee. If any sub project is triggering safeguards, the MMA will inform the ESO, submit the necessary documentation, and initiate preparation of the necessary mitigation measures. The ESO at MLGRD will prepare a long term monitoring strategy that will encompass clear and definitive parameters to be monitored for each sub-project that triggers the preparation of ESMP. The monitoring plan will take into consideration the scope of development, the environmental and social sensitivity and the financial and technical means available for monitoring. The plan will identify and describe the indicators to be used, the frequency of monitoring and the standard (baseline) against which the indicators will be measured for compliance with the ESMF. A number of indicators (see Table ES.3) would be used in order to determine the status of the compliance of the ESMF provisions. Table ES.3: Process monitoring indicators of ESMP Measures Measures Intervention field Indicators -Develop the TOR Technical -Conducting Environmental Impact -Number of ESIAs/ESMPs/ Health Safety Plans submitted measures Assessment (EIA and ESMP) for each sub-project in a MMDA (studies) -Develop a health and safety plan -Number of study elaborated -List of indicators identified for all sub-projects as may Measures for Perform monitoring and evaluation stipulated under the environmental permitting conditions monitoring and ESMP (continuous monitoring, mid- -Number of monitoring missions for all sub-projects evaluating term and annual assessment) -Number of monitoring reports submitted for all sub- projects projects -Develop a TOR for the Environmental unit Engage existing Environmental Units in -Environmental Units are functional in MMAs the MMAs -Number of EA trainings conducted for staffs in MMAs Institutional Awareness and structured Training for -number of attendance (male/female) at EA trainings measures staff of MLGRD and MMAs working -Number of awareness trainings conducted before, during on the GAMA and after project implementation in each MMA -Number of staff tin attendance at the awareness trainings (Male/Female) DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xviii Measures Intervention field Indicators Awareness about HIV / AIDS Communication campaign and -Number of sub-project sites with adequate posters Awareness awareness before, during and after construction CAPACITY STRENGTHENING FOR ESMF IMPLEMENTATION In order for the MMAs to effectively carry out the environmental and social management responsibilities for sub- project implementation, institutional strengthening will be required. Capacity building will encompass MLGRD, and MMA staff.MLGRD should therefore ensure that the following concerns and needs are addressed:  Institutional structuring within the relevant departments to ensure that required professional and other technical staff are available; To successfully implement this ESMF, training programmes for MLGRD and MMAs is necessary. The World Bank, MLGRD and EPA can take up the responsibility for the training. Proposed capacity building training needs are as follows: - Environmental and Social Management Process. - Use of Screening form and Checklist - Preparation of terms of reference for carrying out EA - Design of appropriate mitigation measures. - Review and approval of EA reports - Public consultations in the ESMF/ESIA process. - Monitoring mitigation measures implementation. - Integrating ESMP into sub-projects implementation. The proposed capacity building program will be carried out annually during the project. ESTIMATED BUDGET FOR ESMF The budget needed for ESMP / GAMA environmental and social management is the recapitulation of the following: - Institutional development activities - Training program, awareness - Allowances for the preparation / implementation of sub-projects EIA / EMP/RAPs. (The costs of implementing such plans measures are included in the budgets of sub-projects.) - Annual assessments. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xix The costs of environmental measures as well as training and awareness are summarized in tables ES.4, ES.5 and ES.6 below. Under the GAMA Category A and B project will require the preparation of of EIAs. Table ES.4: Estimated costs of technical measures Unit cost Total cost Activity Quantity ($US) ($US) To be To be To be EIA / RAP development at MMA level and to be integrated determined determined determined into projects budget later at later at later at MMA MMA MMA Normal Normal Supervision and permanent monitoring at MMAs level by Quarterly MMA MMA MPCUs, Planning officers Budget Budget Table ES.5: Training and awareness measures costs Unit cost Total cost Actors involved Topics Quantity ($US) ($US) Training MMAs - Training on Environmental and Social (Training of Assessment (screening and members of classification of activities, MMPCU at identification of impacts, mitigation MMA level, options and indicators) - Involuntary Resettlement Issues 2 including - Drafting ToR for EIA workshops planning officer, - Selection of mitigation measures in the per year and other checklists Y1-Y5 of 7,000 70,000 designated - Legislation and national environmental the project officers procedures covering all (This training - Safeguard Policy World Bank 11 MMAs will be done by - Impact of sub-projects and mitigation the World Bank measures in collaboration - Environmental measures monitoring with MLGRD - health and safety standards monitoring and EPA) Safety and hygiene at work and operation Awareness - Public awareness and advocacy on - Commuities projects environmental and social - Local issues, good environmental practices, Normal Normal associations good conduct in the yards, respect for and NGOs 2 MMA MMA hygiene and safety, compliance with - Reps of Budget Budget development standards construction - Awareness Campaign HIV / AIDS companies 70,000 TOTAL DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xx Table ES.6: Summarized estimated budget for Environmental and Social Impact Management Measures Actions Responsible Costs USD Recruitment of ESO at MLGRD Level Institutional MLGRD measures Covered by normal MMA Perform ESMP monitoring and evaluation (continuous Budgets monitoring, mid-term and annual assessment) Technical EIAs / RAP development MMA Covered by measures Health and safety Plans development MLGRD ESO Supervision and Monitoring Monitoring and Evaluation Budget MLGRD Training of MMA staff in projects environmental and social Covered under Training management and monitoring and enforcement of training above environmental measures MMA - Information and awareness campaigns on the nature of Normal MMA Awareness work, environmental and social issues Budget - Awareness on HIV / AIDS TOTAL DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xxi 1.0 INTRODUCTION 1.1 BACKGROUND The Ministry of Local Government and Rural Development (MLGRD), with support from the World Bank, is currently preparing a Sanitation & Water Project for the Greater Accra Metropolitan Area (GAMA). The proposed project may be structured as a two-phase Adaptable Program Loan (APL) or as a Specific Investment Loan (SIL) that would be followed by other operations, given the long term engagement required to increase access to sanitation and water services in low income areas of GAMA and to attain an efficient and sustainable operation and management of the services. While Ghana compares favorably along most economic and development indicators with countries in the region, it drops to the bottom of the list where access to improved sanitation is concerned. With regard to water, although Ghana is expected to attain the MDG target, the reality is that service expansion cannot keep up with the high population growth in urban areas, especially in the Greater Accra Metropolitan Area (GAMA). This particularly affects people living in low income communities and especially women and children who are usually in charge of fetching the water. The provision of water and sanitation services in a metropolitan area like GAMA presents an additional institutional challenge. Whereas water services fall under the responsibility of the national Ghana Water Company Ltd. (GWCL), the responsibility for sanitation services is divided among eight local governments that generally lack the required operational and financial capacity and do not properly coordinate their actions. The rapid growth of GAMA, both in terms of population and area, has generally taken place in the absence of adequate planning and little attention to the development of basic services, particularly sanitation. This, combined with a lack of capacity to operate and maintain the few existing wastewater facilities, has created serious health and environmental consequences. The provision of water supply also requires urgent attention, particularly to reach people in low income communities who must rely on private vendors and pay significantly more for water than those with access to the utility network. Increasing access to safe water supply and improved sanitation is a priority for the GoG that is embedded in the National Water Policy (2007) and in the recently revised Environmental Sanitation Policy (2010). It also underpins the principles enunciated in the 2000-2005 Ghana Poverty Reduction Strategy (GPRS), the 2006-2009 GPRS-II, the 2010-2013 national Ghana Shared Growth Development Framework (GSGDF), the Millennium Development Goals, and the “Africa Water Vision� of the New Partnership for Africa’s Development. In addition, the commitment of the GoG has been affirmed by the signing of the 2010 SWA Compact. This proposed Sanitation and Water Project aims at increasing access to improved sanitation and safe water in the GAMA, with particular emphasis on low income areas. The GoG is seeking support from the WBG given its experience with the implementation of water and environmental sanitation projects in Ghana and in dealing with low income areas and institutional aspects. The proposed project will therefore focus on providing low income communities located in the 11MMAs with increased water supply and improved sanitation services. The experience to be gained from the design and implementation of this project, particularly in addressing the technical and institutional challenges for the provision of services to low income areas, is expected to be replicated in other urban areas by the GoG. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -1- Improving sanitation is the top priority of the citizens of Accra, followed by drainage, solid waste and water, according to a recent survey of 4,000 households. Sanitation is also a priority for local governments, which have been preparing their District Environmental Sanitation Strategy and Action Plans (DESSAPs) and are now asking for help to implement them. 1.2 PPROJECT OBJECTIVES The objective of the project would be to increase access to safe water and improved sanitation to people in the GAMA, with emphasis on low income communities, and to improve operation and management of wastewater facilities. In order to achieve this objective, the project would support the expansion and improvement of the water distribution network, the expansion of community water points and private water connections, the development of on-site and sewered sanitation facilities and the improved collection and treatment of wastewater and faecal sludge. Behaviour Change Campaign on hygiene, sanitation and safe water will also be promoted through social mobilization activities, as well as social accountability to ensure the sustainability of the facilities and services. The proposed project weather the first phase of an APL or a SIL APL would have the following four components: Component 1 - Provision of water and environmental sanitation services to priority low income areas of the GAMA. The MMAs will propose the priority low income communities to benefit from the project based upon selection criteria to be agreed during project appraisal. The type of water supply and sanitation facilities will be thoroughly consulted and agreed with each community as to best suit their needs, while taking into consideration particular conditions such as: soil characteristics, topography, space availability, etc. In addition to facilities for households, this component will support the construction of institutional facilities in schools, health centers and in public areas such as markets. This component will also provide support for advocacy and other measures to help enforce current laws and regulations, such as the obligation of landlords to provide sanitation facilities. Additionally, specific measures will be introduced to effectively engage communities and particularly women in decisions relating to the delivery and oversight of water and sanitation services such as Water and Sanitation Development Boards (WSDBs). This component will also support the establishment and strengthening of social accountability mechanisms so citizens can report on the provision of services. Component 2 – Improvement and expansion of the water distribution network in the GAMA . This component will support investments required to improve and expand the existing network in order to provide piped water to the target people living in low income communities in the GAMA. These investments include the installation of transmission mains, booster pumps and any other facilities required to ensure that a share of the additional water production reach the targeted low income areas. Therefore this component will be coordinated with current and incoming projects supported by other development partners and private investors in the GAMA. This component would also support the acquisition and installation of meters and other equipment, as well as the provision of services, aimed at improving water demand management and reducing non-revenue water. Component 3 – Improvement and expansion of wastewater and fecal sludge collection, transportation and treatment in the GAMA This component will finance collection and/or treatment of wastewater and fecal sludge DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -2- to be generated from the low income communities and rest of GAMA. However, these facilities will be seized to take care of the entire wastewater flows and sludge volumes generated in the GAMA, which currently end up discharged untreated into drains and eventually into the sea. This component will also support the development of solutions to improve the safe collection, transport and disposal of fecal sludge and solid waste. Component 4 – Institutional Strengthening (USD 10 million). This component will provide technical assistance (TA) to municipal, metropolitan and national institutions, including the promotion of private sector initiatives for water and sanitation. 1.3 ENVIRONMENTAL AND SOCIAL ISSUES RELEVANT TO THE PROJECT The potential environmental and social impacts of these investments are not currently known, even though they are likely to be significant. Since the exact location, nature and number of sanitation and water facilities and/or services are not known, MLGRD is required to prepare an Environmental and Social Management Framework (ESMF) to ensure that all investments are adequately screened for their potential environmental and social impacts, and that correct procedures to be followed, depending on the types of investments to be carried out, and these will be reflected in the ESMF document. In pursuant to the requirements of the World Bank, including OP / BP 4.01, an ESMF is prepared by the Government of Ghana (GoG) as a requirement for the implementation of the GAMA. Furthermore, the World Bank requires that the description of measures taken by the GoG represented by the Ministry of Local Government and Rural Development (MLGRD) (the Borrower) to address the safeguard policy issues and undertake an assessment of MMAs and MLGRD’s capacity to plan and implement the measures proposed to be addressed in the ESMF. 1.2 PURPOSE AND STUDY OBJECTIVES OF ESMF In World Bank-financed projects, a key goal is to enhance positive and sustainable environmental and social outcomes of the project by minimizing and/or avoiding negative environmental and social impacts. Where avoidance is not possible, an Environmental and Social Management Framework is developed which provides the framework within which to address the issues. The objective of the assignment is to prepare an ESMF which will:  Establish the legal framework, procedures, and methods for the environmental and social planning, review, approval and implementation investments to be financed using the performance grant funds;  Identify roles and responsibilities, including reporting procedures and monitoring and evaluation;  Identify capacity and/or training needs for different stakeholders to ensure better implementation of the provisions in the ESMF and;  Identify funding requirements and resources to ensure effective implementation of the framework. The EA Regulations of Ghana provide the general framework and procedures for EA and environmental management (EM) of development actions. Most Development Partners (DPs) and funding institutions, including the World Bank also have EA requirements. As part of funding arrangements for the GAMA, the World Bank’s safeguards policies and national requirements must apply. The project has the following attributes (quite distinct from project-specific level assessment): DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -3-  Geographical coverage of 8 Metropolitan and Municipal Assemblies in the Greater Accra Metropolitan Area (GAMA);  Implementation duration spread over 5years.  Involvement of several institutions at the national, regional, district and local levels;  Design of the sub-projects, types and numbers for implementation, and the specific project locations and communities all not determined at this stage. The ESMF spells out the World Bank safeguards policies, country’s institutional arrangements and capacity required to implement the framework. This ensures that sub-projects meet the national and local E&S requirements and are consistent with OP 4.01, OP 4.12, etc of the Bank. Other objectives of the ESMF include:  Assessment of potential adverse environmental and social impacts commonly associated with the listed sub-projects and the way to avoid, minimize or mitigate them;  Establishment of clear procedures and methodologies for the environmental and social planning, review, approval and implementation of sub-projects;  Development of an EA screening/initial assessment system to be used for sub-projects; and  Specification of roles and responsibilities and the necessary reporting procedures for managing and monitoring sub-project environmental and social concerns.  Development of general environmental management conditions to be added to construction contracts. The ESMF will be principally used by MMAs and other collaborators to ensure that adequate mitigation measures and other environmental and social safeguards have been incorporated into the sub-projects to be implemented under the GAMA. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -4- 2.0 OVERALL APPROACH AND METHODOLOGY FOR ESMF PREPARATION 2.1 APPROACH The ESMF study has been prepared in accordance with applicable World Bank safeguard policies and Ghana environmental assessment guidelines. The distinct phases of the study include:  Data Gathering;  Consultations and discussions with MLGRD, MWRWH, GAMA, MMAs, EPA and NGOs;  Literature review;  Environmental screening and scoping;  Determination of potential impacts;  Identification of impact mitigation measures;  Preparation of an Environmental and Social Management Plan; and  Preparation of sub-project guidelines.  Data Gathering The ESMF Consultant assembled and evaluated relevant baseline data related to the biophysical and socio- economic characteristics of the environment to be covered by the project. The baseline data reviewed included: topography, soil, water resource, biological and socio-economic data. - Consultations During the assessment, consultations with key stakeholders such as impacted groups, local communities and non- governmental organizations are being held from November-December 2012. Selected Project beneficiary MMAs were also visited during the period. (see Annex 7)  Literature Review The ESMF preparation involved document review. The GoG and the World Bank reference documents reviewed included:  Project Concept Note (PCN), Ghana-Sanitation and Water Project for the Greater Accra Metropolitan Area (GAMA)  Proposed GAMA Sanitation and Water Project-Aide Memoire  National Environmental Sanitation Strategy and Action Plan (NESSAP)  Environmental Protection Agency Act, 1994 (Act 490);  Environmental Assessment Regulations, 1999 (LI 1652);  National Environmental Action Plan;  Ghana EIA Procedures; and  World Bank’s Safeguards Policies. The approach was based on review of available project literature and other strategic planning documents at the national and sector level. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -5- 2.2 METHODOLOGY KEY ACTIVITIES SPECIFIC TASKS Development of the 1. Description of the project Environmental and 2. Present the ESMF objectives Social Management 3. Describe the project activities and components Framework 4. Present and analyze the baseline data (biophysical and socioeconomic environment) for the participating Assemblies 5. Describe Legislative, Regulative and Administrative Regime regarding the triggered Safeguards Policies of the World Bank safeguard policies 6. Analyze the country environmental and social management institutional framework and within the framework of the project 7. Determination of Potential Impacts and Screening 8. Develop the Environmental and Social Management Plan including: a. Screening process b. Mitigation measures c. Environmental monitoring plan d. Responsibility and Institutional arrangements in implementation and monitoring e. Institutional Needs &Capacity Building f. Consultation plan g. Implementation schedule h. Cost estimation Technical appendices / recommendations/ List of individuals/institutions contacted/ references DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -6- 3.0 DESCRIPTION OF WATER AND SANITATION PROJECT FOR GAMA 3.1 CONTEXT AND OBJECTIVES OF GAMA While Ghana compares favorably along most economic and development indicators with countries in the region, it drops to the bottom of the list where access to improved sanitation is concerned. With regard to water, although Ghana is expected to attain the MDG target, the reality is that service expansion cannot keep up with the high population growth in urban areas, especially in the Greater Accra Metropolitan Area (GAMA). This particularly affects people living in low income communities and especially women and children who are usually in charge of fetching the water. The provision of water and sanitation services in a metropolitan area like GAMA presents an additional institutional challenge. Whereas water services fall under the responsibility of the national Ghana Water Company Ltd. (GWCL), the responsibility for sanitation services is divided among eight local governments that generally lack the required operational and financial capacity and do not properly coordinate their actions. The rapid growth of GAMA, both in terms of population and area1, has generally taken place in the absence of adequate planning and little attention to the development of basic services, particularly sanitation. In addition to the residents of the eight Metropolitan/Municipal Assemblies (MMAs) that constitute GAMA, there is a large floating population that comes to the city to trade or work2. About 15 percent of GAMA population is served by a sewerage network, 41 percent of residents use fee-for-use public toilet facilities, 33 percent have on-site facilities, 3 percent use bucket or pan latrines and about 7 percent of Accra residents still do not have access to any improved sanitation facility3. This, combined with a lack of capacity to operate and maintain the few existing wastewater facilities, has created serious health and environmental consequences. Indeed, by March 2011, a significant number of cholera cases had been registered this year with several casualties4. The provision of water supply also requires urgent attention, particularly to reach people in low income communities who must rely on private vendors and pay significantly more for water than those with access to the utility network. Increasing access to safe water supply and improved sanitation is a priority for the GoG that is embedded in the National Water Policy (2007) and in the recently revised Environmental Sanitation Policy (2010). It also underpins the principles enunciated in the 2000-2005 Ghana Poverty Reduction Strategy (GPRS), the 2006-2009 GPRS-II, the 2010-2013 national Ghana Shared Growth Development Framework (GSGDF), the Millennium Development Goals, and the “Africa Water Vision� of the New Partnership for Africa’s Development. In addition, the commitment of the GoG has been affirmed by the signing of the 2010 SWA Compact5 . The World Bank Group (WBG) has been highly committed to contributing to the development of the Water and Sanitation Sector (WSS) in Ghana. In coordination with other donors’ activities, the GoG has requested that the World Bank Group continue its involvement in the WSS, as reflected under the FY08-11 CAS Support is to be provided by means of two operations. The first7, which was approved in June of 2010, aims at increasing access to safe water and improved sanitation in rural areas and improving the sustainability of these decentralized services. The second is this proposed Sanitation and Water Project that aims at increasing access to improved sanitation and safe water in the GAMA, with particular emphasis on low income areas. The GoG is seeking support from the WBG given its experience with the implementation of water and environmental sanitation projects in Ghana and in dealing with low income areas and institutional aspects. The proposed project will therefore focus on providing low income communities located in the 8 MMAs with increased water supply and improved sanitation services. The experience to be gained from the design and implementation of this project, DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -7- particularly in addressing the technical and institutional challenges for the provision of services to low income areas, is expected to be replicated in other urban areas by the GoG with its own resources and with support from other Development Partners that may also provide co-financing8 to this project. Improving sanitation is the top priority of the citizens of Accra, followed by drainage, solid waste and water, according to a recent survey of 4,000 households. Sanitation is also a priority for local governments, which have been preparing their District Environmental Sanitation Strategy and Action Plans (DESSAPs) and are now asking for help to implement them. There are also valuable lessons learned as a result of ongoing projects and pilot studies by different institutions and NGOs10, especially in diverse low income areas. Tailored solutions for providing services to such areas would be further developed through extensive community consultations during project preparation and implementation in order to be scaled up by this and other projects to be supported by the GoG and other donors. B. Proposed project development objective(s) The objective of the project would be to increase access to safe water and improved sanitation to people in the GAMA, with emphasis on low income communities, and to improve operation and management of wastewater facilities. In order to achieve this objective the project would support the expansion and improvement of the water distribution network, the expansion of community water points and private water connections, the development of on-site and sewered sanitation facilities, and the improved collection and treatment of wastewater and fecal sludge. Behavior change campaign on hygiene, sanitation and safe water will also be promoted through social mobilization activities, as well as social accountability to ensure the sustainability of the facilities and services. Preliminary results indicators would include the following:  People in GAMA provided with sustainable access to improved drinking water sources under the project (number);  People in GAMA provided with sustainable access to improved sanitation under the project (number);  Improved community water points constructed or rehabilitated under the project (number);  New piped household water connections that are resulting from the project intervention (number)  Volume of wastewater and fecal sludge adequately treated (m3/d) 3.2 PROJECT COMPONENTS 3.2.1 Component 1 – Provision of Water and Sanitation Services The MMAs will propose the priority low income communities to benefit from the project based upon selection criteria to be agreed during project preparation. The type of water supply and sanitation facilities will be thoroughly consulted and agreed with each community as to best suit their needs, while taking into consideration particular conditions such as: soil characteristics, topography, space availability, etc. In addition to facilities for households, this component will support the construction of institutional facilities in schools, health centers and in public areas such as markets. This component will also provide support for DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -8- advocacy and other measures to help enforce current laws and regulations, such as the obligation of landlords to provide sanitation facilities. Additionally, specific measures will be introduced to effectively engage communities and particularly women in decisions relating to the delivery and oversight of water and sanitation services such as Water and Sanitation Development Boards (WSDBs). This component will also support the establishment and strengthening of social accountability mechanisms so citizens can report on the provision of services. 3.2.2 Component 2 – Improvement and Expansion of Water Distribution Network This component will support investments required to improve and expand the existing network in order to provide piped water to the target people living in low income communities in the GAMA. These investments include the installation of transmission mains, booster pumps and any other facilities required to ensure that a share of the additional water production reach the targeted low income areas. Therefore this component will be coordinated with current and incoming projects supported by other development partners and private investors in the GAMA. This component would also support the acquisition and installation of meters and other equipment, as well as the provision of services, aimed at improving water demand management and reducing non-revenue water. 3.2.3 Component 3 – Improvement and Expansion of Wastewater and Feacal Sludge Collection, Transportation and Treatment . This component will finance collection and/or treatment of wastewater and fecal sludge to be generated from the low income communities and rest of GAMA. However, these facilities will be seized to take care of the entire wastewater flows and sludge volumes generated in the GAMA, which currently end up discharged untreated into drains and eventually into the sea. This component will also support the development of solutions to improve the safe collection, transport and appropriate disposal of fecal sludge and solid waste. 3.2.4 Component 4 - Institutional and Project Management Support This component will provide technical assistance (TA) to municipal, metropolitan and national institutions, including the promotion of private sector initiatives for water and sanitation. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 -9- 4.0 RESULTS OF THE PUBLIC CONSULTATION PROCESS To adequately appreciate the views and concerns of stakeholders with regard to the project implementation, field visits and consultation with key stakeholders, Ministries, Departments and Agencies, MMAs, and non- governmental organizations are on-going. The consultations focused on:  Assessing the views and understandings of the MMAs on the GAMA;  Identifying and Assessing environmental and social impact of the GAMA  Proposed or ongoing Sanitation and Water Services rehabilitation activities under the MMAs  Reviewing the status of compliance and enforcement of environmental regulations within the MMAs.  Identifying capacity building needs for the MMAs and relevant regulatory institutions and recommending actions to strengthen MLGRD and its partners to ensure sustained environmental and social compliance monitoring. The consultation was basically done in two forms: - Group discussions with a cross-section of officials and professionals from government Ministries, Departments, and MMAs. - Interviews with key informants (MLGRD, EPA etc) so that views and concerns are more broadly captured. 4.1 CONSULTATIONS WITH MMAS Consultations are being held with the under-listed Ministries, Departments, Agencies (MDAs), Metropolitan and Municipal Assemblies (MMAs): 1. Ministry of Local Government and Rural Development (MLGRD)/PCU 2. Ministry of Water Resources, Works and Housing (MWRWH) 3. Ghana Water and Company Limited (GWCL) 4. Community Water and Sanitation Agency (CWSA) 5. Accra Metropolitan Assembly (AMA)/UESP II, Greater Accra 6. Tema Municipal Assembly (TMA) 7. Ashaiman Municipal Assembly (Greater Accra); 8. Ga South Metropolitan Assembly 9. Ga West 10. Ga Central Municipal Assembly 11. La Nkwantanan Municipal Assembly 12. La Dade-Kotopon Municipal Assembly 13. Ledzokuku Municipal Assembly (LEKMA) 14. Adenta Municipal Assembly (AdMA) DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 10 - 4.2 CONSULTATIONS MINISTRIES DEPARTMENTS AND AGENCIES Consultations are being held with the under-listed Regional EPA Offices: 1. Ministry of Local Government and Rural Development (MLGRD)/PCU 2. Ministry of Water Resources, Works and Housing (MWRWH) 3. Ghana Water Company Limited (GWCL) 4. Community Water and Sanitation Agency (CWSA) 5. EPA, Head Office-Accra 6. EPA, Tema Office – ; and 7. EPA, Greater Accra Regional Office, Amasama DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 11 - 5.0 GAMA BASELINE PROFILE 5.1 BACKGROUND As shown in the maps, the city of Accra actually covers AMA, as well as parts of Ga West, Ga South, Ga East, Tema Metropolitan Area (TMA), Ashaiman and Adenta. The report of the fifth round of the Ghana Living Standards Survey (GSS, 2008), defines the Accra Metropolitan Area (AMA), Tema Municipal Area (TMA) (which at that time also covered Ashaiman and Adenta municipality), and the urban areas in Ga East and Ga West (which at that time included Ga South) Districts as the Greater Accra Metropolitan Area (GAMA). The GAMA area covers a total area of about 1,261 km2 (Twum, 2002). Figure 5-1 : Map of Greater Accra Area 5.2 ADMINISTRATIVE STRUCTURE The eleven metropolitan and municipal areas that constitute the Greater Accra Metropolitan Area are managed by Assemblies. The Metropolitan and Municipal Assemblies derive their mandate from the Local Government Act of 1993 (Act 462).The structure of these assemblies is also spelt out in the act. By this act, the Assemblies are the highest political authorities mandated to govern a municipality or metropolitan area and to provide basic Sanitation and Water services to support the social and economic development of the area. The area under the DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 12 - assemblies is sub-divided into sub-metros, which are in turn further divided into town or areas councils and unit committees. Representatives from the sub-metro structures form the General Assembly. Members of the Assembly are voted from Assembly elections which are held every four years. The general assembly is responsible for making decisions and passing by-laws. This Assembly is chaired by a presiding member while the day-to-day administration is handled by the chief executive (mayor or metropolitan/municipal chief executive), who is also a member of the Assembly. The Accra Metropolitan Assembly (AMA) was up to mid 2004 divided into six sub-metros. In 2004, the number of sub-metros was increased to 13 by further sub-dividing the original six (Ghana Health Services 2008). In February 2008, two sub-metros, Teshie and Nungua, were split off from AMA and joined to form the Ledzekuku- Krowor municipal (with Teshie-Nungua as the district capital). Currently, AMA consists of 11 sub-metros: Ablekuma Central, Ablekuma North, Ablekuma South, Ashiedu Keteke, Ayawaso Central, Ayawaso East, Ayawaso West-Wuogon, La, Okaikoi North, Okaikoi South, and Osu Klottey. 5.3 PHYSICAL CHARACTERISTICS Location and Size The Accra Metropolitan Assembly (AMA) is one of the One Hundred and Seventy (170) Metropolitan, Municipal and District Assemblies (MMDAs) in Ghana and one of the Ten (10) MMDAs in the Greater Accra Region. Like all the District Assemblies, it was established by the Local Government Act, 1993, (Act 462) and Legislative Instrument 1615 which also established the Six (6) Sub-Metropolitan District Councils. The L.I. 1718, subsequently, increased the Sub-Metropolitan District Councils to Thirteen (13). Following the creation of the Ledzokuku-Krowor Municipal Assembly (LEKMA) in 2008, AMA now operates under a new L.I. 1926 which has also reduced the Thirteen (13) Sub-Metros to Eleven (11). It covers an area of 173 sq km. The Metropolis is located on Longitude05°35'N and on Latitude00°06'W. The Northern boundary of the Assembly is Ga West Municipal Assembly (GWMA). It starts from the road between the Institute of Professional Studies (IPS) and the Accra Teachers Training College (ATTRACO), westwards crossing the Accra-Aburi Road to the University of Ghana behind the Great Hall to Kisiseman and Christian Village to join the Accra-Nsawam Road at the Achimota Brewery Company (ABC) Road Junction. It turns left for 500m to the Ayeayeefee Street junction and through the Ayeayeefee Street to the Bridge over the Achimota Stream, then turns right along the stream to the high tension lines to the Achwilage Street and through Achwilage Street to the range of the Awoshie Hills. The Assembly is bounded to the West by Ga South Municipal Assembly (GSMA). The western boundary is along the road from AwoshieHills to the boundary between GSMA and Awoshie. The boundary line then turns left along the swampy area and crossing the Tema Motorway Extensionthrough the swampy area to the bridge on the Sakumono Stream on the Accra-Winneba road and stretching along the stream to Gbegbeyese. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 13 - The Southern boundary stretches along the Gulf of Guinea from Gbegbeyese to the Kpeshie Lagoon at the La Sub-Metropolitan District Council.The Eastern corridor of the Assembly is the LEKMA which was carved out of the Accra Metropolitan Assembly. Source: Urban Management Land Information System Figure 5-2: Map of Greater Accra Area 5.4 GEOLOGY AND CLIMATE Geology The geology of the AMA consists of Precambrian Dahomeyan Schists, Granodiorites, Granites Gneiss and Amphibolites to late Precambrian Togo Series comprising mainly Quartzite, Phillites, Phylitones and Quartz Breccias. Other formations found are the Palaeozoic Accraian Sediments - Sandstone, Shales and Interbedded Sandstone-Shale with Gypsum Lenses. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 14 - The coastline of Accra has a series of resistant rock outcrops and platforms and sandy beaches near the mouth of the lagoons. The coastline is exposed and because of the close proximity of the continental shelf, a strong coastal and wind action, it is subject to severe erosion. The lagoon systems are relatively small and flushing has been impeded by siltation or the construction of embankments, which have restricted tidal flow. The largest of the lagoons are Sakumo (Densu delta), and the Korle (Central Accra). The soils in the Metropolitan area can be divided into four main groups: drift materials resulting from deposits by windblown erosion; alluvial and marine motted clays of comparatively recent origin derived from underlying shales; residual clays and gravels derived from weathered quartzites, gneiss and schist rocks, and lateritic sandy clay soils derived from weathered Accraian sandstone bedrock formations. In many low lying poorly drained areas, pockets of alluvial ‘black cotton’ soils are found. These soils have a heavy organic content, expand, and contract readily causing major problems with foundations and footings. In some areas, lateritic soils are strongly acidic and when saturated are prone to attack concrete foundations causing honeycombing. Near the foothills are the large areas of alluvial laterite gravels and sands. Many of these deposits are being won for constructional purposes. Climate The Accra Metropolitan Assembly lies in the Savannah zone. There are two rainy seasons. The average annual rainfall is about 730mm, which falls primarily during the two rainy seasons. The first begins in May and ends in mid-July. The second season begins in mid-August and ends in October. Rain usually falls in intensive short storms and gives rise to local flooding where drainage channels are obstructed. There is very little variation in temperature throughout the year. The mean monthly temperature ranges from 24.7°C in August (the coolest) to 28°C in March (the hottest) with annual average of 26.8°C. As the area is close to the equator, the daylight hours are practically uniform throughout the year. Relative humidity is generally high varying from 65% in the mid-afternoon to 95% at night. The predominant wind direction in Accra is from the WSW to NNE. Wind speeds normally range between 8 to 16 km/hr. High wind gusts occur with thunderstorm activity, which pass in squall along the coast. The maximum wind speed recorded in Accra is 107.4 km/hr (58 knots). Strong winds associated with thunderstorm activity often cause damage to property and mostly removing roofing materials. Several areas of Accra experience micro climatic effects. Low profile drainage basins with a North-South orientation are not as well ventilated as those orientated East-West. Air is often trapped in pockets and an insulation effect gives rise to local increase in air temperature of several degrees. This occurs in the Accra Newtown and Azumah Nelson Sports Complex areas. 5.5 VEGETATION Terrestrial Vegetation There is evidence to suggest that the vegetation of the Metropolitan areas has been altered in the more recent past century by climatic and other human factors. Much of the Metropolitan area was believed to have been covered DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 15 - by dense forest of which only a few remnant trees survive. A climatic change combined with the gradient of the plains and cultivation has imposed vegetational structures similar to those of the southern shale, Sudan and Guinea Savannahs all of which lie north of the Accra plains. There are three broad vegetation zones in Accra Metropolitan area, which comprise shrub land, grassland and coastal lands. Only the shrub land occurs more commonly in the western outskirts and in the north towards the Aburi Hills. It consists of dense clusters of small trees and shrubs, which grow, to an average height of five metres (5m). The grasses are mixture of species found in the undergrowth of forests. They are short, and rarely grow beyond One metre (1m). Ground herbs are found on the edge of the shrub. They include species, which normally flourish after fire. The coastal zone comprises of two vegetation types, wetland and dunes. The coastal wetland zone is highly productive and an important habitat for marine and terrestrial-mainly bird life. Mangroves, comprising of two dominant species, are found in the tidal zone of all estuaries sand lagoons. Salt tolerant grass species cover substantial low-lying areas surrounding the lagoons. These grasslands have an important primary production role in providing nutrients for prawns and juvenile fish in the lagoon systems. In recent times, wetlands are however being encroached upon. Protection of the coastal wetland zone is very important to the long-term sustainability of the fishing industry, which the Ga population of the City depend upon for survival. The dune lands have been formed by a combination of wave action and wind. They are most unstable but stretch back several hundred metres in places. There are several shrub and grassland species, which grow and play an important role in stabilising dunes. Coconuts and palms grow well in this zone, providing protection and also as an economic crop. Most of the coconuts were planted in the 1920s but it is estimated that over 80% of those plantations have disappeared as a result of felling, disease and coastal erosion. The loss of these trees is one of the principal reasons for the severity of erosion in some parts of the Metropolis. In addition to the natural vegetation zones, a number of introduced trees and shrubs thrive in the Metropolitan area. Neems, mangoes, cassias, avocados, and palms are prominent trees on the Accra landscape. Introduced shrubs like bouganvilia are also very prominent. Achimota Forest is the only forest reserve in the AMA. These are being damaged from residential encroachment, bush fire, sand collection and illegal tree felling. Most of the open spaces in Accra are used for the cultivation of food crops like corn, okro, tomatoes and other vegetables. Fertilizers and insecticides are used in these areas. Constant felling of trees, bad farming practices and annual burning has altered the vegetation from “dry forest� and greatly depleted the fertility of the soil. Aquatic Vegetation Apart from mangroves and salt marsh grasses, which grow in the intertidal zone, sea grasses or attached algae also occur mainly in rocky areas and wave cut platforms. These areas have increased as a result of erosion exposing the underlying bedrock. They have an important role in the coastal ecosystem because of their high rate of primary production in the provision of food and shelter for the survival of shrimps, prawns and many species of fin fishes. Ocean floor sea gases are confined to a few sheltered areas of the coastline and the lagoons. The ocean floor regime is too unstable to support large areas of sea grass. Terrestrial Fauna DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 16 - Different species of antelopes, squirrels, monkeys and reptiles live in Accra. Many animals such as the Togob have grass cutter, bush baby and bossman potto are found in the Achimota Forest Reserve and outside the urbanised area. Most animals have been pushed inland because for the rapid expansion of settlements in the Metropolitan area. Many species of snakes (some venomous) and lizards are found throughout the Metropolitan area. Apart from the above-mentioned fauna, a great number of domestic animals - donkey, sheep, goat and chicken are kept domestically in the Metropolitan area. Aquatic Fauna The open lagoon systems support a wide range of crustacean, mollusks, gastropods, predatory and bottom feeding fish. The lagoons are important breeding grounds giving adequate protection against large predator species and a continual supply of nutrients and organisms for food. The habitat of the lagoons is or has been modified by development and increasing levels of pollution. Some species in the lagoons - in particular the Korle lagoon - are no longer suitable for human consumption. Protection of the water quality and vegetation in the lagoons is important to the long-term sustainability of aquatic fauna along the coastline. The ocean supports a wide range of pelagic and bottom feeding fish. Common species are grouper, mackerel, cassava fish, African lookdown, sole shark and tiger fish. Stocks of off shore species have not been depleted mainly because fishing techniques result in a significant loss of smaller fish from nets. Evidence suggests that on- shore species are nearing exhaustion caused by excessive catches of juvenile and small fish. The loss of this resource will have a substantial impact on the indigenous population of Accra whose livelihood is dependent on fishing. Weija reservoir, the marshes at the mouth of the Densu River, the Sakumo lagoon near the Panbros salt industry constitute the most important fresh water wetlands for aquatic fauna. Apart from harbouring a variety of important commercial fish species like tilapia and catfish, they also act as breeding grounds for animals, which are adapted to the characteristic coastal Savannah vegetation. 5.6 DRAINAGE The Metropolitan drainage catchment area extends from the eastern boundary of the Nyanyanu catchment on the west of Greater Accra Regional boundary to Kpeshie Lagoon. Densu River Catchment and Sakumo Lagoon This is the largest of all the four coastal basins within the study area. The total drainage area is about 2500km2. It is divided into two sections above and below the Weija dam. The northern section of the basin, which extends inland along the Densu River and its tributaries 100 km, is hilly with the highest point reaching 230m above mean sea level. The southern section of the basin is low lying land comprising the Sakumo lagoon and Panbros salt pans. The Lafa steam flows into the lagoon and drains much of the western area of Accra including Dansoman, Kwashieman, McCarthy Hill and Awoshie. Much part of this catchment is now urbanised. Flooding is common along the 8km of the Densu River below the Weija dam whenever there is overtopping or deliberate release of water over the spillway. Flooding is also prevalent in Dansoman area and along the Lafa stream where it crosses the Winneba and Tema Motorway extension roads. Few of the drainage channels in the catchments are constructed. As a result, there is heavy erosion of drainage channels - many of which flow down existing tracks and roads. Access to this area is often cut off and roads become impassable during heavy rains. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 17 - Korle - Chemu Catchment This catchment covers an area of 250 km2. It is bounded on the west by a line running roughly South-North from Gbegbeyise, Dansoman, Kwashieman, and New Achimota; on the north by the Achimota -Legon axis; and to the east by East Legon, the Airport and Ridge. The highest spot on the basin is about 308m above sea level. The principal streams that drain the catchments are the Odaw River and its tributaries, the Nima, Onyasia, Dakobi and Ado. The principal outlet for water in this catchment is the Korle Lagoon. There is a minor outlet at Chemu Lagoon. The Korle - Chemu catchment contains the major urbanised areas of Accra. Many of the drainage channels are poorly developed and maintained. Erosion and siltation of drains is a serious problem. In low-lying areas flooding is a serious problem, with many houses being inundated by floodwater during and after heavy rains. Following the Netherlands Engineering consultants (NEDECO) report in 1963, a considerable amount of work was done, particularly in connection with the Korle Lagoon and the Odaw River, but work was eventually stopped. The drainage channels, until recently, had not been maintained resulting in the silting of the major watercourses and the lagoon. In low lying areas near the Accra Academy in Kaneshie, rapid run off from Asaredanho overflows into the Bank of Ghana flats because inlet to the Kaneshie drains is inadequately designed. Similar problems occur in the industrial land cemetery area around the Obetsebi Lamptey Circle where the interceptor drain and gullies are inadequate. There are many other areas, like Nima, Dzorwulu, Darkuman and Alajo which have localised flooding problems caused by inadequate drainage channels and the flat nature of the terrain. Most roads in the catchment are not surfaced and side drains are mainly uncovered. The channels become convenient places for the dumping of refuse. This, combined with erosion, results in choked and silted drain age channels. These problems must be tackled by regular maintenance and the construction of new channels and culverts where existing ones are shown to be inadequate. Until good access roads with properly constructed side drains are provided in all urban areas, old and developing, drainage and flooding will continue to be a problem every rainy season. Kpeshie Catchment The Kpeshie drainage basin covers a relatively small catchment area of 110 km2. It is bounded on the east by the Military Academy at Teshie, on the north by a line south of Madina and Ajirignano. It covers the eastern part of Accra, Ridge, Cantonments, Osu, Labadi and Burma camp areas. Streams in the catchment generally flow north to south, emptying directly into the principal outlet to the sea at Kpeshie Lagoon or the small Korle Lagoon at Osu. Improvements have been made to straighten some of the watercourses in Christianborg and South La. Drainage in the La Township is inadequate and many waterlogged areas become flooded with light rains. In heavy rains, fence walls collapse and foundations are undermined. Issues Affecting Urban Drainage DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 18 - Poor drainage is the major problem, which affects many parts of the Metropolis. Natural features such as the underlying geology, soil conditions and localised topographic features create some drainage problems. Development should never have been permitted in these areas; however, poorphysical development control has been unable to prevent urban land encroachment. The majority of the problems are created by the high rate of urbanization (4.2%) of the City and its impact on increase surface water runoff and flooding in low lying areas. The following issues require special attention in developing a strategy for drainage within the Metropolis; Flooding The principal areas that are liable to flooding in the Metropolitan area are:  Panbros Salt Ponds  Dansoman - Mpoase - South Odorkor corridor  Dansoman - Sukura - Chorkor corridor  Mataheko - Abossey Okai - Korle Lagoon corridor  Odaw - Dzorwulu - Awudome - Industrial Areas System  Darkuman - North Kaneshie Choked Drains The inadequate drainage and poorly designed channels in many parts of the Metropolis have given rise to serious flood problems. These problems are compounded by choked drains. A well-organised programme for seasonally clearing drains is required to ensure they remain free flowing. Impeded Drainage Several low-lying areas along the Odaw and the Sakumo II catchment areas have natural low-lying areas of impeded drainage. These are suitable habitat for vermin, snakes and disease carrying insects. Small-scale drainage works are required to reduce the water table in these small-impeded drainage areas. Dredging Dredging of the Sakumo II and Korle lagoons is required to reduce flooding and provide improved flow in the existing channel system. There are, however, a number of problems involved with the Korle Lagoon, which make the dredging of this lagoon expensive. In other upper reaches of the lagoon, old car bodies and other wrecked machinery and equipment have been carried or deposited in the lagoon and are now embedded in the floor of the estuary. The removal of wreckage is necessary to create a proper channel to ensure adequate flushing once the entrance is widened. Against this background the Ministry of Water Resources, Works and Housing in collaboration with the AMA is implementing the Korle Lagoon Ecological Restoration Project (KLERP). The project is financed by the Government of Ghana, Kuwaiti Government fund and BADEA and the dredging of the lagoon is being done by Dredging Ghana Limited. The second phase, which includes landscaping and the construction of canals has been completed. However, the existence and activities of Old Fadama (Sodom and Gomorrah) pose great difficulties for the continuation of the KLERP. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 19 - The cost of dredging is expensive (approximately US$85million) and it is therefore important that further dumping of wrecks and waste is prohibited in the area. It is in this light that measures are currently been made to remove the people of Sodom and Gomorrah, a squatter settlement near the project area. Potential Ramser Sites and Conservation of the Lagoons The disposal of silt from the lagoons has the potential to create a number of problems. There are opportunities to utilise material for filling low-lying areas near the edge of the lagoons. However, the Sakumo II and Korle lagoons are both under consideration as Ramsar (conservation) sites and excessive interference of the low-lying area by filling will destroy much of the habitat for wildlife. Filling also destroys storage capacity. Dredging also need to be well managed as the operation can release dangerous quantities of methane and other toxic gases into the water in the estuary. This could have a dangerous impact on marine life. There is the need to consider carefully the disposal of material taken by dredging so that undesirable environmental impacts of this operation are minimised. Lagoon Outfalls Many of the lagoons along the coastline remain closed until opened by heavy rains. In the case of Korle and Kpeshie Lagoons, these do not provide sufficient capacity for storm water discharge or adequate flushing of the lagoon systems. Subsequently, these lagoons have become much polluted with a large buildup of sediment. In order to improve the quality of water and provide sufficient channel clearance to enable floodwater to be adequately discharged, the channel entrances at Korle have been widened substantially. There is also a need to bypass the dry season flow around the edge of the lagoons to prevent the discharge of waste and maintain water quality in the upper reaches. Local Drains Many of these are open sewers and a major health hazard. It must therefore be ensured that these drains are cleaned as part of a public health programme. Many localised flooding problems in the urban area can be attributed to poor design of storm water facilities. Under sizing of culverts and drainage channels, poor consideration of maintenance requirements and under-estimation of siltation loads are common faults. Conversely, concrete lined drainage channels on both sides of residential streets are often more expensive to construct than the road itself. Simpler design standards could enable much larger areas to be serviced by storm water drainage. There is the need to review many of the current design standards to ensure all drainage systems have adequate capacity, but also that standards adopted are not excessively expensive. As the Metropolitan area expands and more land comes under intensive cropping in catchments undergoing urbanisation, surface water runoff will increase. This will lead to increased siltation and more severe floods down stream especially in areas surrounding the lagoons. If this situation is to be avoided engineering and conservation measures will need to be applied to reduce the rate of runoff. There is the need to introduce measures to protect the upper catchment areas and streams where development and more intensive crop production are expected to take place. 5.7 AIR QUALITY With the exception of the industrial area along the Odaw River, air quality in the Metropolitan area is good. Minor incidents of localised pollution from automobile fumes arise during certain climatic conditions but these are insignificant compared to those registered in some developed countries. During the months of December to DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 20 - February, the effect of the Harmattan (fine windblown dust from the Sahara region) causes loss of visibility and some health problems. These are seldom prolonged. Odour levels arising from decomposing rubbish and sanitary wastes are high in inner city areas, especially, along the drainage system and in the region of the night soil dump at Korle Gonno. 5.8 DEMOGRAPHY Demographic Characteristics The 2010 estimated population of Accra, pending the result of the 2010 PHC, is about 4.3 million with additional daily influx population of 1 million who commute to the City for various socio-economic activities, which most often are nonexistent thereby resorting to social vices and economic crimes. Table 5-1: Demographic Figures of AMA by Sub-Metros NO SUB METRO AREA 2000 POP *EST. 2010 No. OF No. OF (KM2) POP HOUSES HSEHDS (2000) (2000) 1. ABLEKUMA 11.5 181,541 619554 15,606 40,219 CENTRAL 2. ABLEKUMA 13.6 140,063 483253 12,499 29,972 NORTH 3. ABLEKUMA 15.1 211,493 729712 21,012 48,125 SOUTH 4. ASHIEDU 4.4 88,717 260174 4,599 20,440 KETEKE 5. AYAWASO 6.0 155,947 435984 8,145 34,419 CENTRAL 6. AYAWASO 5.8 128,641 359643 5,144 27,295 EAST 7. AYAWASO 35.2 50,334 140717 5,938 10,382 WEST 8. LA 36.0 133,721 373844 10,372 30,355 9. OKAIKOI 21.1 141,085 394433 9,668 29,913 NORTH 10. OKAIKOI 12.0 96,600 270066 7369 20,111 SOUTH 11. OSU KLOTTEY 12.0 96,634 270162 10,562 23,122 TOTAL 173 1,424,776 4,337,542 110,914 314,353 Source: 2000 P&HC (Ghana Statistical Service), UMLIS and Accra Metropolitan Authority The high population figure of the City (4,337,542) is both an asset and source of worry to management. While the relatively high population serves as a huge and vibrant market for investors, it also poses problem of sanitation and waste management as well as traffic jam especially during the peak hours of the day. The period between 1960 and 1970 saw the rapid industrialisation and expansion in the manufacturing and commercial sectors in some major areas within the Metropolis. This factor contributed to high immigration to Accra, and resultant in high population growth rate (6.32%) between 1960-1970 intercensal years. The stagnation of the Ghanaian Economy during the 1970’s had adverse effect on the growth rate of Accra population as shown DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 21 - in the growth rate (7.51%) of 1970-1984 intercensal years. The decline in agriculture in rural communities in Ghana and industrialization in urban regions coupled with the late 1980s and 1990s boom in the service sector in primate cities propelled immigration to Accra. Table 5-2: Population and population Growth Rate 1960 1970 1984 2000 Population 338,396 636,667 969,195 1,658,937 Pop. Growth rate - 6.32% 7.51% 4.3% Source: 1960, 1970, 1984 and 2000 National Population Census * Projected. Projected Population (provisional) Figure the results of the 2010 PHC by GSS The 2010 estimated population of Accra implies that the figure will be close to 5million by the 2013. The table below shows the population projections of the various Sub-Metros in the Metropolis. Table 5-3: Population Project of AMA by Sub-Metros SUB METRO 2000 2010 2011 2012 2013 Ablekuma Central 181,541 619554 646195 673981 827950 Ablekuma North 140,063 483253 504033 525706 295200 Ablekuma South 211,493 729712 761089 793816 494679 Ashiedu Keteke 88,717 260174 271361 283030 408060 Ayawaso Central 155,947 435984 454731 474285 159661 Ayawaso East 128,641 359643 375107 391237 424173 Ayawaso West 50,334 140717 146768 153079 447534 La 133,721 373844 389919 406686 306424 Okaikoi North 141,085 394433 411394 429083 476533 Okaikoi South 96,600 270066 281678 293791 392149 Osu Klottey 96,634 270162 281778 293895 827950 Total 1,424,776 4,337,542 4,524,053 4,718,589 5,060,313 Source: Accra Metropolitan Assembly The population figures above reflect the citizenry residing within the Metropolis. It is, therefore, estimated that during the peak hours, Accra host about 25% of the national population and has influx population of about 1,000,000 on daily basis for economic activities aside the residential dimension captured by the 2000 National Population Census. The primacy of Accra Metropolitan Area as an administrative, educational, industrial and commercial centre is the main factor for this and continues to attract people from all over Ghana, and outside, as its functional importance is on incremental ascendancy. Rural-urban migration accounts for over 35% of the population increase. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 22 - Distribution and Density The gross population density for Accra Metropolitan Area was 82.33 persons per hectare in 2000 compared to 6.23/ha in 1970. This is currently estimated to be 250.73/ha in 2010 and is projected to increase to 292.50 by the end of the plan period in 2013 as depicted in the table below which will put pressure on the existing facilities and will demand for direct efforts to meet the needs of the populace. Table 5-4: Projected Population Density per Hectre SUB METRO 2000 2010 2011 2012 2013 Ablekuma Central 157.86 538.74 561.91 586.07 719.96 Ablekuma North 102.99 355.33 370.61 386.55 217.06 Ablekuma South 140.06 483.25 504.03 525.70 327.60 Ashiedu Keteke 201.63 591.30 616.73 643.25 927.41 Ayawaso Central 259.91 726.64 757.89 790.48 266.10 Ayawaso East 221.79 620.07 646.74 674.55 731.33 Ayawaso West 14.30 39.98 41.70 43.49 127.14 La 37.14 103.84 108.31 112.97 225.12 Okaikoi North 66.86 186.94 194.97 203.37 145.28 Okaikoi South 80.50 225.06 234.73 244.85 320.24 Osu Klottey 80.53 225.14 234.82 244.91 689.96 TOTAL 82.36 250.73 261.51 272.75 292.50 Source: Accra Metropolitan Assembly At the Sub-Metro level, Ashiedu Keteke is projected to be the most densely populated Sub-Metro in the Metropolis followed by Ayawaso East and Ablekuma Central. These Sub-Metros, therefore, should be given developmental attention to improve the living conditions of the projected population. Population Distribution by Age and Gender Accra’s population like that of other urban centres is a very youthful with 56% of the population under the age of 24years. It will be realised from the age-sex ratio that 51% of the population are females and the rest 49% males. This gives a sex ratio of 1:1.04 males to females. The dominance of females over males is a reflection of the nationwide trend where the estimated ratio is 1:1.03. The need to target women in any development programme in the Metropolis can therefore not be over emphasised. Age dependency ratio has been calculated to be at approximately 60%. 60 % of residents of Accra rely on the other 40% for their livelihood. The table below is the projection of the population distribution by age and sex for the Accra Metropolis for the plan period 2010-2013. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 23 - 6.0 POLICY, LEGAL, INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT The environmental policy and EA legislation and procedures of Ghana and those of the World Bank, which are relevant to the Project, are outlined. In principle the two sets of policies and procedures on environmental and social assessment are similar in many respects. 6.1 NATIONAL ENVIRONMENTAL REQUIREMENTS 6.1.1 Ghana’s Environmental Policy The environmental policy of Ghana formulated in the National Environmental Action Plan (NEAP) of 1993 hinges strongly on ‘prevention’ as the most effective tool for environmental protection. The policy aims at a sound management of resources and environment, and the reconciliation between economic planning and environmental resources utilization for sustainable national development. It also seeks among others, to institute an environmental quality control and sustainable development programs by requiring prior EA of all developments, and to take appropriate measures to protect critical eco-systems, including the flora and fauna they contain against harmful effects, nuisance or destructive practices. The adoption of the NEAP led to the enactment of the EPA Act 1994 (Act 490); and subsequently the passing of the Ghana EIA Procedures into the EA Regulations, 1999 (LI 1652). 6.1.2 National Water Policy OVERALL GOAL Consistent with the GPRS, the overall goal of the National Water Policy is to "achieve sustainable development, management and use of Ghana's water resources to improve health and livelihoods, reduce vulnerability while assuring good governance for present and future generations". This will be achieved by addressing relevant issues under water resources management, urban water supply and community water and sanitation. For each broad area, a number of focus areas for policy considerations have been identified. Within each the main principles and challenges are listed followed by policy objectives and the corresponding measures. POLICY OBJECTIVES The key policy objectives of applying the principles and meeting the challenges above to: (i) Achieve sustainable management of water resources; (ii) Ensure equitably sustainable exploitation, utilisation and management of water resources, while maintaining biodiversity and the quality of the environment for future generations. POLICY MEASURES AND/OR ACTIONS Government will take the following measures and actions:  Facilitate availability of water resources for industrial uses through sustainable resources management; DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 24 -  Require industries, including mining operations, to develop and implement environmental management systems which take into account the impact of industries on the country's water resources;  Fully implement the enacted requirements related to licensing of water uses (permits) and issuance of waste water (effluent) discharge permits;  Encourage development of codes of practice for efficient water use and cleaner production technologies in industrial activities; and  Formulate hydropower development plans to meet current and future demands in conjunction with other uses, through sustainable water resources management. PRINCIPLES AND CHALLENGES The underlying principle in financing water resources management is meeting the social needs for water as a priority, whilerecognis1ng the economic value of water and the goods and services it provides. The main challenges are:  Ensuring sustainability in water resources management through appropriate pricing mechanisms while ensuring equity;  Ensuring water resources management is adequately funded and appropriate levies instituted for raw water abstraction to promote efficiency, sustainability and equity; and  Sustaining appropriate levels of funding to the sector to meet MDGs. 6.1.3 Environmental Sanitation Policy The Environmental Sanitation Policy (Revised, 2010) responds to the various reviews carried out to assess how effectively the previous policy published in 1999 has been implemented. The revised policy objectives and measures are presented in a way that enhances strategic planning and subsequent implementation. The broad principles underlying Ghana‟ s Environmental Sanitation Policy (Revised, 2010) are:  The principle of environmental sanitation services as a public good;  The principle of environmental sanitation services as an economic good;  The polluter-pays-principle;  The principle of cost recovery to ensure value-for-money ensuring economy, effectiveness and efficiency;  The principle of subsidiarity in order to ensure participatory decision-making at the lowest appropriate level in society;  The principle of improving equity and gender sensitivity;  The principle of recognizing indigenous knowledge, diversity of religious and cultural practices; DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 25 -  The precautionary principle that seeks to minimize activities that have the potential to negatively affect the integrity of all environmental resources;  The principle of community participation and social intermediation The ESP defines the principal components of environmental sanitation to include; (a) Collection and sanitary disposal of wastes, including solid wastes, liquid wastes, excreta, industrial wastes, health-care and other hazardous wastes; (b) Storm-water drainage; (c) Cleansing of thoroughfares, markets and other public spaces; (d) Control of pests and vectors of disease; (e) Food hygiene; (f) Environmental sanitation education; (g) Inspection and enforcement of sanitary regulations; (h) Disposal of the dead; (i) Control of rearing and straying of animals; (j) Monitoring the observance of environmental standards Policy Focus Areas In order to provide a clear basis for achieving the overall goal of the sector, the policy provides strategic elements under seven (7) policy focus areas, as follows:  Capacity Development  Information, Education and Communication  Legislation and Regulation  Levels of Service  Sustainable Financing and Cost Recovery  Research and Development  Monitoring and Evaluation 6.1.4 The Environmental Protection Agency Act The Environmental Protection Agency (EPA) Act, 1994 (Act 490) grants the Agency enforcement and standards setting powers, and the power to ensure compliance with the Ghana EA requirements/procedures. Additionally, the Agency is required to create environmental awareness and build environmental capacity as relates all sectors, among others. The Agency (including its Regional and District Offices) is also vested with the power to determine what constitutes an ‘adverse effect on the environment’ or an activity posing ‘a serious threat to the environment or public health’, to require EAs, EMPs, Annual Environmental Reports (AERs), etc of an ‘undertaking’, to regulate and serve an enforcement notice for any offending or non-complying undertaking. The Agency is required to conduct monitoring to verify compliance with given approval/permit conditions, required environmental standard and mitigation commitments. Furthermore, a requirement by EPA for an EA precludes any authorising MDA from licensing, permitting, approving or consenting such undertaking, unless notified otherwise. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 26 - 6.1.5 EA Regulations and Procedures The EA Regulations combine both assessment and environmental management systems. The regulations prohibit commencing an undertaking/activity without prior registration and environmental permit (EP). Undertakings are grouped into schedules for ease of screening and registration and for EP. The schedules include undertakings requiring registration and EP (Schedule 1), EIA mandatory undertakings (Schedule 2), as well as Schedule 5- relevant undertakings (located in Environmentally Sensitive Areas). The Regulations also define the relevant stages and actions, including: registration, screening, preliminary environmental assessment (PEA), scoping and terms of reference (ToR), environmental impact assessment (EIA), review of EA reports, public notices and hearings, environmental permitting and certification, fees payment, EMP, Annual Environmental Report (AER), suspension/revocation of permit, complaints/appeals, etc. 6.1.6 EA (Amendment) Regulations, 2002 The EA (Amendment) Regulations were made to amend sections of the EA fees regime of LI 1652 (the ‘principal enactment’) on fee payment for EP and certificate issued by the Agency. 6.1.7 Local Government Act, 1993 (Act 462) The Local Government Act (Act 462) seeks to give a fresh legal expression to governme nt’s commitment to the concept of decentralization. It is a practical demonstration of a bold attempt to bring the process of governance to the doorstep of the populace at the Regional and more importantly, the District level. The Metropolitan, Municipal and District Assemblies (MMDAs) created under the law, constitute the highest political authority in each district, municipality and metropolis. Among the functions of the MMDAs are the following:  Formulate and execute plans, programmes and strategies for the effective mobilization of the resources necessary for the overall development of the MMDAs;  Initiate programmes for the development of basic Sanitation and Water services and provide municipal works and services in the MMDAs; and  Be responsible for the development, improvement and management of human settlements and the environment. 6.1.7.1 Bye-Laws One of the most important provisions of the law is the power of the MMDAs to make bye-laws for the purpose of the functions conferred under Act 462 or any other enactment. Most MMDAs have adopted by-laws on sanitation and waste. However, most MMDAs are still without sanitary engineered waste disposal facilities in place. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 27 - 6.2 NATIONAL LABOUR, SAFETY AND HEALTH REQUIREMENTS 6.2.1 Factories, Offices and Shops Act The Factories, Offices and Shops Act of 1970 (Act 328) mandates the Factories Inspectorate Department to register factories and ensure that internationally accepted standards of providing safety, health and welfare of persons are adhered to. It defines a factory to include any premises (whether in or not in a building) in which one or more persons are employed in manual labour, among others. 6.2.2 Occupational Safety and Health Policy of Ghana (Draft) The policy statement of the Occupational Safety and Health Policy (draft 2004) is: ‘to prevent accidents and injuries arising out of or linked with or occurring in the course of work, by minimizing, as far as reasonably practicable, the cause of the hazards in the working environment and, therefore, the risk to which employees and the public may be exposed’. The policy is derived from provisions of the International Labour Organization (ILO) Conventions 155 and 161. The policy document has specific sections on objectives, scope, strategies, activities and promotion and awareness creation. 6.2.3 National Workplace HIV/AIDS Policy The broad objectives of the policy among others, are to provide protection from discrimination in the workplace to people living with HIV and AIDS; prevent HIV and AIDS spread amongst workers; and provide care, support and counselling for those infected and affected. 6.2.4 Labour Act The purpose of the Labour Act, 2003 (Act 651) is to amend and consolidate existing laws relating to labour, employers, trade unions and industrial relations. The Act provides for the rights and duties of employers and workers; legal or illegal strike; guarantees trade unions and freedom of associations, and establishes the Labour Commission to mediate and act in respect of all labour issues. Under Part XV (Occupational Health, Safety and Environment), the Act explicitly indicates that it is the duty of an employer to ensure that every worker works under satisfactory, safe and healthy conditions. 6.3 THE GHANA SHARED GROWTH AND DEVELOPMENT AGENDA (GSGDA) The 1992 Constitution provides a long-term national development imperative for Ghana through the Directive Principles of State Policy which requires that every Government must pursue policies that would ultimately lead to the “establishment of a just and free society�, where every Ghan aian would have the opportunity to live long, productive, and meaningful lives. The Ghana Shared Growth and Development Agenda (GSGDA, 2010-2013), Government responds to the 1992 constitutional injunction within the context of its Better Ghana Agenda. The “Better Ghana Agenda� encompasses, but is not limited to the understated social and economic goals:  Putting food on people’s tables;  Providing citizens with secure and sustainable jobs; DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 28 -  Rehabilitating and expanding infrastructural facilities;  Expanding access to potable water and sanitation, health, housing and education;  Guaranteeing the security of persons and their property;  Embarking on an affirmative action to rectify errors of the past, particularly as they relate to discrimination against women;  Reducing geographical disparities in the distribution of national resources;  Accelerating economic growth rate to at least 8% per annum;  Ensuring environmental sustainability in the use of natural resources through science, technology and innovation;  Pursuing an employment-led economic growth strategy that will appropriately link agriculture to industry, particularly manufacturing;  Creating a new social order of social justice and equity, premised on the inclusion of all hitherto excluded and marginalized people, particularly the poor, the underprivileged and persons with disabilities;  Ensuring that the benefits of economic growth are fairly shared among the various segments of society; and  Maximizing transparency and accountability in the use of public funds and other national resources. It is the belief of Government that the policies and programmes emanating from the Ghana Shared Growth and Development Agenda (GSDA) will lay the foundation to move Ghanaians closer to the long-term aspiration of a just, free and prosperous society. 6.4 THE POVERTY REDUCTION STRATEGY OF GHANA 6.4.1 GPRS I and II The GPRS I was a comprehensive framework of policies and development strategies, programs and projects to facilitate macro-economic stability, sustainable growth and poverty reduction (2003-2005). The central goal of GPRS II (2006-2009), which built on GPRS I was to accelerate the growth of the economy to attain a middle- income status. The GPRS II emphasizes the implementation of growth-inducing policies and programs with the potential to support wealth creation and sustainable poverty reduction. The document refers to the need to apply environmental impact assessment and environmental audit to ensure that the growth arising from the GPRS is environmentally sustainable. 6.5 THE WORLD BANK REQUIREMENTS 6.5.1 The Bank’s Safeguard Policies The Bank’s ten (10) safeguard policies are designed to help ensure that programs proposed for financing are environmentally and socially sustainable, and thus improve decision-making. The Bank’s Operational Policies DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 29 - (OP) is meant to ensure that operations of the Bank do not lead to adverse impacts or cause any harm. They include guidance on EA requirements. The Safeguard Policies are lumped into Environment, Rural Development, Social Development and International Law. The following seven out of the ten are relevant for considerations under the Project. These are:  Environmental Assessment (OP 4.01);  Natural Habitat (OP 4.04);  Pest Management (OP 4.09);  Indigenous Peoples (OP 4.10);  Physical Cultural Resources (OP 4.11);  Involuntary Resettlement (OP 4.12);  Forestry (OP 4.36);  Safety of Dams (OP/ 4.37);  Projects in International Waterways (OP 7.50);  Projects in Disputed Areas (OP 7.60); Plus  Public Disclosure (OP 17.50). 6.5.1.1 Environmental Assessment (OP 4.01) The OP 4.01 requires among others that screening for potential impacts is carried out early, in order to determine the level of EA to assess and mitigate potential adverse impacts. The Bank’s project screening criteria group projects into three categories:  Category A – Detailed Environmental Assessment;  Category B - Initial Environmental Examination and  Category C – Environmentally friendly The EA ensures that appropriate levels of environmental and social assessment are carried out as part of project design, including public consultation process, especially for Category A and B projects. The OP 4.01 is applicable to all components of the Bank’s financed projects, even for co-financed components. 6.5.1.2 Involuntary Resettlement (OP 4.12) The Policy on Involuntary Resettlement is intended to assist displaced people arising from development projects, in order not to impoverish any affected people within the area of influence of projects. An action plan that at least restores the standard of living must be instituted, in cases where resettlement is inevitable or loss of assets and impacts on livelihood occurs. 6.5.1.3 Forestry (OP 4.36) The OP/BP 4.36 aims at enhancing the environmental and social contribution of forested areas, and the need to reduce deforestation. The protection of forests through the control of forest-related impact of all investment operations is a concern of the policy. It promotes the restriction of operations affecting critical forest and DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 30 - conservation areas, while requiring that the sector and other relevant stakeholders should be consulted as appropriate. 6.5.1.4 Physical Cultural Property (OP 4. 11) The policy is premised on the need to investigate and take inventory of cultural resources likely to be affected. Mitigations are provided for in cases of adverse impacts on physical cultural resources. Mitigation measures should be undertaken in conjunction with the appropriate authorities, organizations and institutions that are also required to be consulted and involved in the management of cultural property. 6.5.1.5 Natural Habitats (OP 4.04) This policy recognises that the conservation of natural habitats is essential for long-term sustainable development. The Bank, therefore, supports the protection, maintenance, and rehabilitation of natural habitats in its project financing. The Bank supports, and expects the borrowers to apply, a precautionary approach to natural resource management to ensure opportunities for environmentally sustainable development. 6.5.1.6 Safety of Dams (OP 4.37) The Policy seeks to ensure that appropriate measures are taken and sufficient resources provided for the safety of dams the Bank finances. The Bank distinguishes between small and large dams, and the policy is triggered for large dams. Small dams are normally less than 15m in height; this category includes farm ponds, local silt retention dams, and low embankment tanks. For small dams, generic dam safety measures designed and supervised by experienced and competent professionals are usually adequate. 6.5.1.7 Indigenous People (OP 4.10) The objective of the policy is: (i) ensure that the development process encourages full respect of dignity, human rights and cultural features of indigenous people; (ii) ensure they do not suffer from the detrimental effects during the development process; and (iii) ensure indigenous people reap economic and social advantages compatible with their culture. Measures to address issues pertaining to indigenous people must be based on the informed participation of the indigenous people themselves. 6.5.1.8 Bank’s Policy on Disclosure (OP 17.50) The Bank’s policy on disclosure currently under review requires that all the people residing in the given areas of a project have the right to be informed of the proposed development project. Prior to project appraisal therefore, the summary of the study of the development action along with other relevant information should be disclosed to or at the level of the Bank and the project area. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 31 - 6.5.2 Triggered Safeguard Policies The World Bank Safeguard Policies that are triggered are OP 4.01 -Environmental Assessment, OP 4.01 Annexes A, B, and C on Environmental Assessment, OP 4.12-Involuntary Resettlement. The construction of the proposed sanitation and water facilities in the GAMA could have irreversible environmental impacts unless mitigating measures recommended are carried out during the construction and operation stages. Some of the potential adverse impacts that may occur relating to the physical environment are:  Groundwater pollution;  Surface water pollution;  Loss of top soil;  Loss of useful subsoil;  Changes in drainage of soils;  Changes in runoff characteristics;  Changes in water quality.  Other receiving environments that may be affected are the ecological environment, land use, human health and economic issues. Arising from the potential adverse environmental impacts enumerated above, the significance of the impacts, the extent of displacement for proposed projects there may be the need to resettle displaced persons whose settlements will have to give way for the project. This scenario that may pertain to the Sanitation and Water Project in the GAMA means that the Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) and Involuntary Resettlement policies (OP/BP 4.12) will be triggered. 6.6 ENVIRONMENTAL SANITATION POLICY In 1999 the Ministry of Local Government published an Environmental Sanitation Policy. This Policy was prepared long after the NEAP. Sanitation is construed to have a broader meaning than waste. The Policy describes the objectives of environmental sanitation to include developing a clean, safe and pleasant physical environment in all human settlements, promoting the social, economic and physical well-being of all sections of the population. It comprises of various activities including the construction and maintenance of sanitary infrastructure, the provision of services, public education, community and individual action, regulation and legislation. 6.6.1 Solid Waste Management The Policy confers primary responsibility for solid waste management on the Assemblies. However, the private sector will be invited to provide the actual services under contract or franchise, as appropriate. The Policy lists the following as acceptable technologies for solid waste disposal:  Sanitary landfill;  Controlled dumping with cover;  Incineration;  Composting; and  Recycling DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 32 - 6.7 INTERNATIONAL CONVENTIONS Ghana is party to many international agreements such as:  Treaty on Marine Life Conservation, 1966  The Convention on Prevention of Marine Pollution by Dumping of Waste and other Matter, 1972  Convention on the Prevention of Pollution from Ship, 1973/1978  Convention on the International Trade in Endangered Species of Wild Flora and Fauna, 1981  Law of the Sea, 1982  International Agreement on the Protection of Tropical Timber, 1994  Comprehensive Nuclear Test Ban Treaty (CTBT), 1996  Vienna Convention on the Protection of the Ozone Layer, 2001  United Nations Framework Convention on Climate Change (UNFCCC), 1994  The Convention on Biological Diversity (Biodiversity Treaty), 1993  Environmental Modification Treaty, 1997. 6.8 INSTITUTIONAL FRAMEWORK 6.8.1 Ministry of Environment, Science and Technology The Ministry of Environment, Science and Technology (MEST) was established in 1994. Its creation was in response to a national development need to integrate environmental, scientific and technological considerations into the country’s sectoral, structural and socio-economic planning processes at all levels. The declared mission of MEST is to establish a strong national scientific and technological base for accelerated sustainable development of the country to enhance the quality of life for all. Among other things, this will be done through the development and promotion of cost-effective use of appropriate technologies. Among the main areas of policy thrust for MEST, are Sanitation and Waste Management (Technical Options) and Science and Technology promotion, education and acculturation. 6.8.1.1 Functions The functions of MEST are:  Protection of the environment through policy formulation and economic, scientific and technological interventions needed to mitigate any harmful impacts caused by development activities;  Standard setting and regulatory activities with regard to the application of science and technology in managing the environment for sustainable development;  Promotion of activities needed to underpin the standards and policies required for planning and implementation of development projects; and  Co-ordination, supervision, monitoring and evaluation of activities that support goals and targets of the Ministry and national sustainable development. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 33 - It is noted that MEST is the political focal point for United Nations Convention on Climate Change (UNFCCC) in Ghana and therefore plays a key role in activities that arise out of the implementation of the Convention. 6.8.2 Ministry of Local Government and Rural Development The Ministry of Local Government and Rural Development (MLGRD) exists to promote the establishment and development of a vibrant and well resourced decentralized system of local government for the people of Ghana to ensure good governance and balanced rural based development. This will be done by:  Formulating, implementing, monitoring, evaluating and co-ordinating reform policies and programmes to democratise governance and decentralise the machinery of government.  Reforming and energising local governments to serve effectively as institutions for mobilising and harnessing local resources for local national administration and development.  Facilitating the development of all human settlements through community and popular participation.  Facilitating the promotion of a clean and healthy environment.  Facilitating horticultural development.  Improving the demographic database for development planning and management.  Promoting orderly human settlement development. The pursuance of the Ministry’ vision is based on two divisions:  Local government - Strong Structures, Revenue Mobilisation and Collection, and Sanitation.  Rural Development - Rural roads, Information and Communications Technology, Tourism and Agric Processing. The following, among other are the main objectives of the Ministry:  To formulate appropriate policies and programs to accelerate the implementation of decentralization of the machinery of government. This is to avoid re-centralization of government machinery.  To improve upon the human resources and institutional capacities for all levels of the decentralized government machinery (District, town and Unit)  To improve the capacity of communities and local government institutions to mobilize, and manage resources for accelerated rural and urban development.  To promote community based registration, collation, analysis and publication of data on all births and deaths occurring in Ghana.  To promote human development and sustain the orderly and healthy growth of rural and urban settlements in Ghana.  To monitor and evaluate the effectiveness of local government institutions for improved management performance. 6.8.3 Ministry of Water Resources Works and Housing The Ministry of Water Resources, Works and Housing has as its main functions the formulation and co-ordination of policies and programmes for the systematic development of the country's Sanitation and Water Services DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 34 - requirements in respect of Works, Housing, Water Supply and Sanitation and Hydrology. The Ministry co- ordinates and supervises, by way of monitoring and evaluation of the performance of both public and private agencies responding to and participating in the realisation of the policy objectives established for the sector. 6.8.4 Ministry of Finance and Economic Planning The ministry of Finance and Economic Planning is the agency that manages the central government’s budget. The ongoing management of the fiscal framework for local government is a core competence of the Ministry of Finance and Economic Development (MoFEP). The Ministry has recently expressed a strong commitment to develop dedicated capacity through the decision to establish a Fiscal Decentralisation Unit within the Budget Office of the Ministry. This project component will provide support directly to the Unit to assist in its establishment and the performance of its functions. Staff costs and basic administrative overheads have already been budgeted for by the Ministry from the 2011 financial year. Simultaneously, MLGRD has established the Fiscal Decentralization Secretariat (FDS). The Fiscal Decentralization Unit will work in close collaboration with the FDS as part of rolling out its activities in particular in relation to preparation of PFM reform strategies for the five core reform areas. 6.8.5 Ministry of Roads and Highways The Ministry of Roads and Highways is a government establishment responsible for policy formulation, monitoring and evaluation with regard to the transport sector which consists of the following: a) Road Infrastructure sub-sector b) Road Transport Services and Safety sub-sector. c) Road Transport Training d) Road Maintenance Financing The Departments and Agencies relevant to the GAMA that operate under the direct ambit of the Ministry are following with respect to Road Infrastructure:  Department of Feeder Roads (DFR)  Department of Urban Roads (DUR) DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 35 - 7.0 POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE GAMA PROJECTS AND MITIGATION Description of Prospective Projects under Components 1, 2 and 3 Under Component 1,2 and 3, the World Bank is funding this proposed Sanitation and Water Project that aims at increasing access to improved sanitation and safe water in the GAMA, with particular emphasis on low income areas. The GoG is seeking support from the WBG given its experience with the implementation of water and environmental sanitation projects in Ghana and in dealing with low income areas and institutional aspects. The proposed project will therefore focus on providing low income communities located in the 8 MMAs with increased water supply and improved sanitation services. The Table 7.1 below presents the list of some of the likely investments and the safeguards status (Please note that this list is not comprehensive). Table 7-1: Status of Safeguard Work Component 1: Status of Safeguard Work (OP 4.01 and OP 4.12) Provision of water Location Implementation EIA RPF RAP and environnemental MMAs Construction To be done if Done To be done if required sanitation services to required priority income areas MMAs Rehabilitation To be done if Done To be done if required of the GAMA required LIST OF POTENTIAL SUB-PROJECTS  Water supply and sanitation facilities for communities  Water Supply and sanitation facilities for households  Water supply and sanitation facilities for schools, health centrers and in public areas such as markets  Engagement of community and particularly women to provide oversight of water and sanitation services such as Water and Sanitation Development Board (WSDBs)  Construction of water supply system;  Drilling of boreholes;  Mechanization of boreholes;  Construction of KVIPs;  Construction of water closet seaters;  Rehabilitation of public toilet;  Construction and lining of drains; Component 2: Status of Safeguard Work (OP 4.01 and OP 4.12) Improvement and Location Implementation EIA RPF RAP expansion of the MMAs Construction To be done if Done To be done if required water distribution required network in the MMAs Rehabilitation To be done if Done To be done if required GAMA required LIST OF POTENTIAL SUB-PROJECTS  Investments to improve and expand the existing network to provide piped water to the targeted people living in low income communities in the GAMA  Installation of transmission mains, boster pumps and other facilities  Support acquisition and installation of meters and other equipment as well as provision of services aimed at improving water demand management Component 3: Status of Safeguard Work (OP 4.01 and OP 4.12) Improvement and Location Implementation EIA RPF RAP DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 36 - expansion of MMAs Construction To be done if Done To be done if required wastewater and fecal required sludge collection, MMAs Rehabilitation To be done if Done To be done if required transportation and required treatment in the GAMA LIST OF POTENTIAL SUB-PROJECTS  Collection and/or treatment of wastewater and fecal sludge to be generated from the low income communities and rest of GAMA  Improve the safe collection, transport and treatment of fecal sludge 7.1 POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS The overall environmental impact of the project is expected to be positive. Significant positive impacts to the natural and socioeconomic environments will be achieved by the participating MMAs. By developing infrastructure, the capacity of the MMAs to deliver quality services will be improved. The positive environmental and social impacts for Water and Sanitation include information relevant to the construction, operation and maintenance of (i) potable water treatment and distribution systems, and (ii) collection of sewage in centralized systems (such as piped sewer collection networks) or decentralized systems (such as septic tanks subsequently serviced by pump trucks) and treatment of collected sewage at centralized facilities . Key expected positive results or outcomes are as follows:  Improved Conservation and Presevation of Water  Sustainable Water Supply  Reduced vulnerability of ecosystem to climatic events  Improved use of Water and Sanitation  Sustainable water supply  Reduced vulnerability of ecosystem to climatic events  Increase Employment  Improved conditions for economic growth  General economic growth  Poverty reduction  Increased affordability of water and sanitation  Increased access to water  Reduced rate of water related deseases  Improved social development  Improved health  Poverty reduction  Greater equity in allocation of water and sanitation  Increased access to basic sanitation  Increased access to water  Reduced rate of water related deseases  Improved health  Improved quality of water and sanitation DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 37 -  Increased access to basic sanitation  Reduced rate of water related deseases  Improved health  Improved water and sanitation , health and hygiene behaviour 7.1.1 Maternal Mortality: A reduction in maternal mortality depends strongly on the water supply and sanitation situation. A contributory factor to poor maternal health is contaminated water and poor hygiene, leading to infection and slow postnatal recovery. Good water supply facilities will support fewer miscarriages from heavy water transport and safer home birth. At the same time a better general health condition due to reduced health risks linked to insufficient water and sanitation will also have a positive impact on maternal mortality. However, reducing the health risk by improving water supply and sanitation needs to be linked to improving hygiene practices in order to bring about the desired impacts. 7.1.2 Other Diseases: Insufficient water supply and sanitation as well as inappropriate hygiene practices are associated with number of different diseases. Eliminating stagnant, standing water around the households and water points can contribute to reducing the incidence of malaria, in particular in dry areas with few natural mosquito breeding places. At the same time, reducing the incidence of water-borne, water-washed and waterbased diseases through improved services and hygiene behaviors will have a positive impact on reducing the susceptibility to other illnesses. For people living with HIV/AIDS, water, sanitation and hygiene is extremely important in reducing the incidence of opportunistic infections. 7.1.3 Environmental Sustainability: Insufficient or inadequate water supply and sanitation is very often associated with an unsustainable exploitation of natural resources. Improved water management, including industrial pollution control and water conservation is a key factor for maintaining ecosystem integrity. Adequate treatment and disposal of excreta and both household and industrial wastewater contribute to less pressure on freshwater resources. Furthermore, improved sanitation reduces flows of human excreta into waterways and reducing the respective health and environmental risks. Furthermore, water, sanitation and hygiene is important for improving the lives of slum dwellers, by reducing the risks of contracting water-related illnesses, relieving the burden on women and opening opportunities for small- scale enterprises. 7.1.4 Improvement of the living conditions An overall improvement of living conditions will be achieved by the population. The length of time women spent providing water for the family will be reduced significantly. An improved water supply will increase the opportunities for women to improve their economic productivity. The time dedicated to fetching water will be freed up for income generation. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 38 - The next sections explore some of the identified prospective projects related benefits and general positive impacts: 7.1.5 Water Supply Project  Construction and rehabilitation of water and sanitation facilities will have significant positive impacts on the health of the communities and populations in all the targeted districts,  Safe water fully available to the populations as well as their assets emanating from projects in livestock watering points and associated animal tracks (reducing or eliminating prevailing agriculturalist/pastoralist conflicts) and small scale agricultural activities and essentially improve their quality of life. Water supply services A variety of water service delivery models can be identified in the Greater Accra Metropolitan Area with different sources of water providing different levels of water services. These include utility water supply services, private (intermediary and independent) water supply services and community managed water supply services. Households can rely on a mix of different service delivery models for their water supply. The main source of water for AMA and TMA is the utility system, which produces almost 365,000 m3 per day, about 99 percent of all water produced in GAMA. Although the utility, the Ghana Water Company Limited (GWCL) produces most of the water that is used in the Greater Accra Metropolitan Area, only about 51 percent of the population has direct access to utility water supply services. The rest depend on private and community service providers, many of whom get their water from the GWCL system, either directly (through a connection to the network) or indirectly (e.g. through tanker services). There is a variety of alternative service providers. Each provides different services in different areas at different costs per unit water, which are considerably higher than the costs per unit water charged for water supplied through household connections. A number of communities on the fringes of Accra are being served by systems independent from the utility system, including community- managed small town piped water supply systems implemented by the Community Water and Sanitation Agency (CWSA), and privately-operated and managed water supply kiosks, like the WaterHealth Centres which can be found in the northwest of Accra. The issues the project aims at addressing are:  Increased water demand to be higher or at least equal to the supply needs.  Reduction in the amount of non-revenue water in the GWCL system. Physical losses (27 percent of the amount of water produced), as well as economic losses (33 percent of the amount of water produced) will be reduced significantly.  Improved reliability of the GWCL system through improved reliable electricity supply, increased storage capacity in the distribution system.  Some equity will be achieved as against the current situation whereby large parts of the GAMA population depend on expensive alternative service providers: DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 39 - 7.1.6 Excreta and Wastewater Services Different sanitation service delivery models can be identified in the Greater Accra Metropolitan Area. Sanitation service providers can be broadly grouped into three categories: municipal service providers, private service providers and self-supply. The municipal providers include septic emptiers, servicing both private WCs as well as public facilities; the sewer system, with household and institutional connected WCs; and human waste transfer stations where human waste from pan and bucket latrines is collected. There are also private sector septic emptiers, servicing the same target group as the municipal septic emptiers. Finally, a number of people and institutions provide their own sanitation services. These include institutional sewer systems and on-site treatment sanitation facilities like pit latrines and KVIPs. The main challenges related to sanitation in the GAMA can be summarised as:  The vast majority of the waste treatment plants are not working:  There is a lack of treatment capacity:  The lack of use of safe and hygienic sanitation facilities:  Many people depend on public sanitation facilities, paying more for access to lower level services than people with access to private sanitation services. A successful implementation of the proposed water and sanitation project in the GAMA will yield the following positive impacts:  Improved access to private sanitation facilities, which can be achieved through the enforcement of by- laws for the construction of household latrines, the facilitation of appropriate technology choice and awareness creation and education.  Improved public latrine services by increasing the number of public latrines, ensuring adequate water supply to public latrines and improving the management of public latrines.  Increased treatment capacity. Under the Accra sewerage improvement project, there are plans to extend the sewer system. However, even when fully successful, the impact of this intervention will be relatively small. Therefore, additional strategies are needed like securing, acquiring and maintaining sludge treatment sites; rehabilitating existing ones; and using natural systems.  Improved the use of existing treatment capacity by increasing the number of connections to the sewer system and by building the capacity of the sewerage unit staff. 7.1.7 Economic Benefits to MMAs Improved Sanitation and Water through rehabilitation and maintenance provides such socio-economic benefits as accessibility which will significantly enhance economic prospect and integration. Lack of access has been traditionally linked to poverty in Ghana. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 40 - 7.1.8 Enhanced Institutional Capacity to Support Decentralization The Project will offer important contribution and legacy to the decentralization program by providing capacity building opportunities to the MMAs. The support to MMAs will particularly enhance community involvement in decision processes affecting their interests, gender issues and other environmental and social related activities in their immediate neighbourhoods. Institutional coordination and planning Institutionally the sector is fragmented, with overlapping areas of responsibility. There is poor-to-no enforcement of existing (planning) regulations and lack of frameworks for integrated planning. The situation can be improved through the following:  Facilitation of a ‘Greater Accra Metropolitan Area (GAMA) Integrated Urban Water Management Planning and Coordination Platform’ for city wide planning alignment and development of water and sanitation services  Resolution of ambiguities regarding the respective roles of the municipalities and Ghana Water Company Limited in providing water services.  Resolution of ambiguities on responsibilities for drainage  Resolution of ambiguities regarding responsibilities for wastewater management at the local authority (Metro/Municipal Authority) level 7.1.9 Conclusion The Sanitation and Water Facilities Project in the GAMA will result in:  Generic improvement within the Metropolis and Municipalities for water and sanitation projects:  Improvement in the hygienic conditions and public health There will be an improvement in the environment, and hygienic conditions of the city due to provision of efficient water and sanitation facilities. The prevailing trends of morbidity and mortality are likely to change. The present health statuses of these communities are characterized by high morbidity rate from occasional outbreak of preventable and infectious diseases like cholera and typhoid fever. High occurrence of Malaria is also prevalent as a result of poor drainage facilities and the malaria, which is endemic, will be reduced as a result of the drainage to be provided.  Employment generation There will be employment generation for unskilled labourers during the construction stage of various Sanitation and Water facilities. Thus the project has the potential to contribute to economy through labour absorption and the supply of construction materials. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 41 -  Improve access to basic water and sanitation services There will be an access to basic services like water supply as these will be supplied and be connected.  Gender-Status of Women The provision of the water and sanitation facilities is expected to enhance the lot of women in the project areas. Apart from those who will be employed directly on the project, others will be engaged in trading at the construction sites supplying the workforce with food and other consumables. Although the numbers will not be disproportionately high a vibrant and booming trade for the women implies an improvement in living standards of the people. 7.2 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS, The proposed Sanitation and Water works will have an impact on the environment. The potential impacts of the development are both adverse and beneficial. An assessment of the negative impacts can be classified into construction phase and post-construction phase impacts. 7.2.1 Environmental Impact Assessment Constructional Phase Impacts The constructional works would present negative environmental impacts. The construction phase includes the following operations: site clearing, excavation and grading, upgrading of drains, installation of utility services (electricity and water supply). These activities will have direct impact on the environment. The negative impacts are discussed and assessed below: 7.2.1.1 Soil and Land Degradation Access road upgrading normally involves the use of earth-moving equipment such as bulldozers and excavators. The use of earth moving equipment or machinery during the clearing of the access way will not only expose the soils but also compact the soil and break down the soil structure. This and the sealing of the road surface with tar or another petroleum-based material would potentially reduce rainwater percolation into the ground water. In addition, site-levelling activities will interfere with the natural drainage pattern and this has the potential of causing siltation of the natural drainage channel. 7.2.1.2 Air Quality The main impact on air quality will be experienced during the construction phase. Particulates (dust) from site preparation, haulage of plant and equipment and construction materials on the untarred access road will cause deterioration in the quality of air at the site. Other sources of dust will be earthworks such as excavation and the delivery of coarse aggregates. The excessive generation of dust will have a significant impact on the health of the workers and persons living in nearly residences. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 42 - 7.2.1.3 Vehicular Traffic Implication The construction works will result in an increase in traffic volume on the roads in the area. The transport of raw materials will introduce a number of heavy trucks on the main road and this could increase the risk of motor accidents and also result in vehicular-pedestrian conflicts. These impacts are localised and regarded as short term. 7.2.1.4 Noise Levels and Ground Vibration Minimal and intermittent noise would be generated during the construction phase of the project. The background noise levels and ground vibrations at the access roads will increase as a result of the movement of a number of tipper trucks delivering materials, heavy earthmoving equipment and the use of machinery such as concrete mixtures. The anticipated noise levels and ground vibrations will however, not have devastating effects on the work force and immediate environment. Other inconveniences will be created to the adjoining communities during the construction stage 7.2.1.5 Constructional Wastes The constructional activities on the access ways will produce wastes such as excavated soils and redundant materials such as broken block and pieces of wood. The haphazard collection of constructional wastes could obstruct the movement of the workers and trucks as well as affect the beauty of the estates. These wastes will therefore have to be managed at various times during the construction period. 7.2.1.6 Occupational Health and Safety Safety of the local population and workforce may be threatened during constructional phase. The movement of trucks to and from the access roads, the operation of the various equipment and machinery and the actual construction will expose the workers to work-related accident and injuries. Pollutants such as dust and noise in the workplace environment could also have negative implications for the health of the workers. 7.2.2 Operational Phase Impacts 7.2.2.1 Water Withdrawal Some of the issues relating to urban water management in the GAMA stem from other municipalities and regions. For example, water supply to the Accra depends to a large extent on sources from outside the city and indeed the region. This means that pollution of water sources or even problems with the pipelines in the areas through which they pass before getting to Accra, cuts across municipalities and district assemblies. Traditional sources for potable water treatment include surface water from lakes, streams, rivers, etc. and groundwater resources. Development of water resources often involves balancing competing qualitative and quantitative human needs with the rest of the environment. This is a particularly challenging issue in the absence of a clear allocation of water rights which should be resolved with the participation of appropriate stakeholders DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 43 - such as the Water Commission, Water Research Institute (WRI), Community Water and Sanitation Agency (CWSA) in advance of project design and implementation. 7.2.2.2 Water Treatment Environmental issues associated with water treatment include: Solid waste Solid waste residuals generated by water treatment include process residuals, used filtration membranes, spent media and miscellaneous wastes. Process residuals primarily consist of settled suspended solids from source water and chemicals added in the treatment process, such as lime and coagulants. Pre-sedimentation, coagulation (e.g. with aluminum hydroxide [alum] or ferric hydroxide), lime softening, iron and manganese removal, and slow sand and diatomaceous earth filtration all produce sludge. Composition of the sludge depends on the treatment process and the characteristics of the source water, and may include arsenic and other metals, radionuclides, lime, polymers and other organic compounds, microorganisms, etc. Damaged or exhausted membranes are typically produced from water treatment systems used for desalination. Spent media may include filter media (including sand, coal, or diatomaceous earth from filtration plants), ion exchange resins, granular activated carbon [GAC], etc. Wastewater Wastewater from water treatment projects include filter backwash, reject streams from membrane filtration processes, and brine streams from ion exchange or demineralization processes. These waste streams may contain suspended solids and organics from the raw water, high levels of dissolved solids, high or low pH, heavy metals, etc. Hazardous chemicals Water treatment may involve the use of chemicals for coagulation, disinfection and water conditioning. In general, potential impacts and mitigation measures associated with storage and use of hazardous chemicals are similar to those for other industrial projects Air emissions Air emissions from water treatment operations may include ozone (in the case of ozone disinfection) and gaseous or volatile chemicals used for disinfection processes (e.g., chlorine and ammonia). Measures related to hazardous chemicals discussed above will mitigate risks of chlorine and ammonia releases. In addition, specific recommended measures to manage air emissions include installation of an ozone-destroying device at the exhaust of the ozone-reactor (e.g., catalytic oxidation, thermal oxidation). DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 44 - 7.2.2.3 Water Distribution The most fundamental environmental health issues associated with distribution networks is the maintenance of adequate pressure to protect water quality in the system as well as sizing and adequate maintenance to assure reliable delivery of water of suitable quality. The most significant environmental issues associated with operation of water distribution systems include: Water system leaks and loss of pressure Water system leaks can reduce the pressure of the water system compromising its integrity and ability to protect water quality (by allowing contaminated water to leak into the system) and increasing the demands on the source water supply, the quantity of chemicals, and the amount of power used for pumping and treatment. Leaks in the distribution system can result from improper installation or maintenance, inadequate corrosion protection, settlement, stress from traffic and vibrations, frost loads, overloading, and other factors. Water discharges Water lines may be periodically flushed to remove accumulated sediments or other impurities that have accumulated in the pipe. Flushing is performed by isolating sections of the distribution system and opening flushing valves or, more commonly, fire hydrants to cause a large volume of flow to pass through the isolated pipeline and suspend the settled sediment. The major environmental aspect of water pipe flushing is the discharge of flushed water, which may be high in suspended solids, residual chlorine, and other contaminants that can harm surface water bodies. 7.2.2.3 Sanitation A sanitation system comprises the facilities and services used by households and communities for the safe management of their excreta. A sanitation system collects excreta and creates and effective barrier to human contact; transports it to a suitable location; stores and/or treats it; and reuses it or returns it to the environment. In addition to excreta, sanitation systems may also carry household wastewater and storm water. Transport, storage, and disposal facilities may also manage wastes from industries, commercial establishments, and institutions. Fecal Sludge and Septage Collection In communities not served by sewerage systems, sanitation may be based on on-site systems, such as pit latrines, bucket latrines or flush toilets connected to septic tanks. While pit and bucket latrines must be emptied frequently (typically daily to weekly), solids that accumulate in septic systems (septage) must also be removed periodically, usually every 2 to 5 years depending on design and usage to maintain proper function and prevent plugging, overflows, and the resulting release of septic tank contents. If suitable facilities for storage, handling and treatment of fecal sludge are not available, it may be indiscriminately dumped into the environment or used in unhygienic manner in agriculture. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 45 - Sewerage Where population density or local conditions preclude effective on-site sanitation systems (e.g., septic tanks and drain fields), sewage is typically conveyed via a system of pipes, pumps, and other associated infrastructure (sewerage) to a centralized storage and/or treatment system. Solids and liquids may be transported to a centralized location, or sewage solids may be collected in and periodically removed from on-site interceptor tanks (see Septage and Fecal Sludge Collection, above) while the liquids are transported to a centralized location for storage, treatment, or disposal. Users of the sewerage system may include industry and institutions, as well as households. Greywater (water from laundry, kitchen, bath, and other domestic activities that norma lly does not contain excreta) is sometimes collected and managed separately from sewage. Though greywater is generally less polluted than domestic or industrial wastewater, it may still contain high levels of pathogenic microorganisms, suspended solids and substances such as oil, fat, soaps, detergents, and other household chemicals and can have negative impacts on human health as well as soil and groundwater quality. The most significant potential environmental impacts associated with wastewater collection arise from:  Domestic wastewater discharges  Industrial wastewater discharges  Leaks and overflows 7.2.2.4 Domestic Wastewater Discharges Uncontrolled discharge of domestic wastewater, including sewage and greywater, into aquatic systems can lead to, among other things, microbial and chemical contamination of the receiving water, oxygen depletion, increased turbidity, and eutrophication. Wastewater discharge onto streets or open ground can contribute to spread of disease, odors, contamination of wells, deterioration of streets, etc. Measures to protect the environment as well as public health include:  Provide systems for effective collection and management of sewage and greywater (separately or combined);  If greywater is managed separate from sewage, implement greywater source control measures to avoid use and discharge of problematic substances, such as oil and grease, large particles or chemicals. 7.2.2.5 Wastewater and Sludge Treatment and Discharge Sewage will normally require treatment before it can be safely discharged to the environment. The degree and nature of wastewater and sludge treatment depends on applicable standards and the planned disposal or use of the liquid effluent and sludge and the application method. The various treatment processes may reduce suspended solids (which can clog rivers, channels, and drip irrigation pipes); biodegradable organics (which are consumed by microorganisms and can result in reduced oxygen levels in the receiving water); pathogenic bacteria and other disease-causing organisms; and nutrients (which stimulate the growth of undesirable algae that, as they die, can result in increased loads of biodegradable organics). Wastewater discharge and use options include discharge to natural or artificial watercourses or water bodies; discharge to treatment ponds or wetlands (including aquiculture); and direct use in agriculture (e.g., crop irrigation). In all cases, the receiving water body use (e.g. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 46 - navigation, recreation, irrigation, or drinking) needs to be considered together with its assimilative capacity to establish a site-specific discharge quality that is consistent with the most sensitive use. The most significant environmental impacts related to wastewater and sludge treatment, discharge, and use include:  Liquid effluents  Solid waste  Air emissions and odors  Hazardous chemicals  Ecological impacts 7.2.3 Social Impacts The Potential Negative Impacts Social impacts may emanate from the various Sanitation and Water services delivery activities under the GAMA funded sub projects within the MMAs. The following are some of the potential social negative impacts: 7.2.3.1 Disruption of Utility Services There will be interruption of utility services such as electricity and water and this will cause temporary disruption of these services. Such disruptions will be a nuisance to the affected communities in the area. As far as possible such connections would be carried out as soon as possible to reduce the inconvenience. 7.2.3.2 Dumping of solid waste and rubbish into the drains Some unscrupulous residents will resort to anti-social practices whereby, rubbish and other solid waste matter will be dumped into open drains, to await storm waters to wash them away. 7.2.3.3 Accidents Work at water and sanitation facilities is often physically demanding and may involve hazards such as open water, trenches, slippery walkways, working at heights, energized circuits, and heavy equipment. Work at water and sanitation facilities may also involve entry into confined spaces, including manholes, sewers, pipelines, storage tanks, wet wells, digesters, and pump stations. Methane generated from anaerobic biodegradation of sewage can lead to fires and explosions. 7.2.3.4 Inconvenience to be caused due to delays in payment Inconvenience, delayed payment and lower than market value payment for households whose lands are expropriated by MMAs during access road upgrading. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 47 - 7.2.3.5 Restricted Access to Source of Livelihood The population staying or working next to the construction site will be temporarily inconvenienced by restricted mobility. 7.3 MITIGATION MEASURES Various mitigating measures are proposed below in order to ensure an efficient environmental management of the construction and sustainability of the Sanitation and Water facilities provision. The mitigation measures are proposed for the impacts identified under both the construction and post construction phases of the project. 7.3.1 Construction Phase Impacts 7.3.1.1 Air Quality Dust pollution will be temporal since it will be restricted mainly to the constructional phase. However, all the exposed surfaces will be watered regularly and finally tarred with bitumen in order to enhance dust suppression. Moreover, all the exposed surfaces will be paved. Besides, transportation of raw materials will be covered with tarpaulin to avoid dust blow and spills. In addition there will be speed limits for vehicles plying the road. 7.3.1.2 Noise and Vibration To ensure that the noise generated during construction is not a nuisance to the residents of the neighbourhood, constructional activities will be restricted to the daytime. In this way, the noise generated will be confined to working machinery only and diffuse into the existing background noise. The plant and equipment that will be used at the site will also be maintained and serviced regularly in order to ensure their smooth operation so as to reduce the noise they generate. In addition, all heavy construction machinery must be equipped with appropriate and functional noise suppresser (muffler). 7.3.1.3 Constructional Waste Management Excavated soils will be stock piled and be transported elsewhere. In addition, the sand would be used to level holes or pits created by the construction activities and landscape the area. Re-usable pieces of block will be packed and used elsewhere. In addition, the site offices and stores of the contractors will be decommissioned and the planks of wood and other materials, which could be used again, will be carted away and kept for other projects elsewhere. 7.3.1.4 Occupational Health and Safety The health and safety of the work force must be of paramount concern. Contractors will be required to adopt extensive policies to minimise accidents and to improve the health and safety of its workers. This will be done through the provision of protective clothing. All workers on site will be provided with helmets, Wellington boots, ear plugs, nose pad and hand gloves to protect them from injuries. The use of protective clothing will be strictly enforced. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 48 - Besides the provision of protective clothing, a first-aid kit stocked with enough drugs and materials will be provided on site so that workers who unfortunately get injured or sick on the job would be given first aid. However, workers who may sustain serious injuries will be given some initial treatment and rushed to the Hospital for professional medical care. In addition, provision for workers to include:  Proper management of sanitary wastes  Adequate supply of safe water  Adequate protection against dust and excessive noise  An education program is a component of occupational health and safety. An orientation on proper values on safety and environmental awareness shall be inculcated among contractors and in turn among their workers. Furthermore, there should be in addition to the above:  Vehicle safety signals  Speed ramps  Loading and off-loading procedures  Only drivers with Vehicle license and permit are to drive 7.3.1.5 Adherence to specification and Environmental Standards by Contractors MMAs shall be responsible for the strict compliance of its contractors and sub-contractors with the highest standards of social responsibility and environmental management. Contractors shall be required to follow and incorporates environmental mitigation measures. This is the basis for monitoring by the proponent’s MMA Development Planning Subcommittee (or, where applicable, the Environment Management Committee). The contractors shall also be responsible for the proper disposal of their wastes subject to monitoring. . Generally, concerns are raised about some contractors who do not observe the proper specifications in the civil works, have no safety signs, etc. Stakeholders are interested to help monitor not only observance of commitments on social and environmental compliance as a result of the Environmental Impact Statement, but would like to be part of a mechanism that will review quality of civil works by eradicating leakage in the application and purchase of materials. Such a mechanism may be strengthened or established if none yet exists. The appropriate monitoring body should also address feedback on alleged corruption and poor implementation by contractors. A policy may be issued whereby erring contractors may be blacklisted for using substandard specifications and for not observing environmental guidelines, provided that they shall be released only upon proper compliance. 7.3.1.6 Social Problems from Work Sites Social problems created by migratory workers in work sites areas should be discussed by contractors, local officials and women representatives. The appropriate sanctions and enforcement mechanism, as agreed upon, shall be made known to the workers. Concern about workers transmitting sexually transmitted diseases can be addressed through worker education. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 49 - 7.3.1.7 Housing and Sanitation for Non-Resident Workers Priority shall be given to residents of those low-income areas for employment as a way to help regulate the in- flow of migrant workers. On the other hand, there shall be proper planning of worker facilities. Necessary non- resident workers shall be provided with housing facilities with adequate provisions for water and sanitation. Malaria is endemic in the MMAs. There shall be schedules for measures of the workers’ camp for mosquito control. Monitoring shall be done to ensure that solid wastes are properly disposed. 7.3.1.8 Addressing Fear of Non-Compensation There may be homeowners, businesses, etc in proposed project areas and elsewhere who may be apprehensive about non-compensation because they do not possess building construction permits. Awareness raising activities and orientation meetings at MMA level, carried out by the MMAs, can address undue fears and facilitate discussion on acceptable compensation packages. Details can be seen in the RPF report. 7.3.1.9 Resettlement For sub projects that trigger a resettlement action plan (identified on the initial screening process), a resettlement action plan (RAP) and /or an Abbreviated Resettlement Action Plan (ARAP), based on the guidelines provided in the RPF, shall be prepared to make sure that all issues are settled satisfactorily and that any compensation package for loss of livelihood, property, etc., is just and acceptable. Addressing concerns of vulnerable groups, e.g. women-headed households, the poor and landless, shall consider the following:  Provision of adequate compensation and alternative opportunities and facilities for resettlement.  Preferential access to jobs and employment, credit and other related services.  A resettlement plan that complies with World Bank requirements 7.3.2 Post Constructional Phase impacts 7.3.2.1 Water Withdrawal Measures to prevent, minimize, and control environmental impacts associated with water withdrawal and to protect water quality include:  Evaluate potential adverse effects of surface water withdrawal on the downstream ecosystems and use appropriate environmental flow assessment3 to determine acceptable withdrawal rates;  Design structures related to surface water withdrawal, including dams and water intake structures, to minimize impacts on aquatic life.  Avoid construction of water supply wells and water intake structures in sensitive ecosystems;  Evaluate potential adverse effects of groundwater withdrawal, including modeling of groundwater level changes and resulting impacts to surface water flows, potential land subsidence, contaminant mobilization and saltwater intrusion. Modify extraction rates and locations as necessary to prevent unacceptable adverse current and future impacts, considering realistic future increases in demand. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 50 - 7.3.2.2 Water Treatment Measures to manage solid wastes from water treatment include:  Minimize the quantity of solids generated by the water treatment process through optimizing coagulation processes;  Dispose of lime sludges by land application, limiting application rates to about 20 dry metric tons per hectare (9 dry tons per acre) to minimize the potential for mobilization of metals into plant tissue and groundwater;  Dispose of ferric and alum sludges by land application, and if such application can be shown through modeling and sampling to have no adverse impacts on groundwater or surface water (e.g. from nutrient runoff). Balance use of ferric and alum sludges to bind phosphorous (e.g. from manure application at livestock operations) without causing aluminum phytotoxicity (from alum), iron levels in excess of adulteration levels for metals in fertilizers, or excessively low available phosphorous levels;  Potential impact on soil, groundwater, and surface water, in the context of protection, conservation and long term sustainability of water and land resources, should be assessed when land is used as part of any waste or wastewater treatment system;  Sludges may require special disposal if the source water contains elevated levels of toxic metals, such as arsenic, radionuclides, etc.;  Regenerate activated carbon (e.g. by returning spent carbon to the supplier). Wastewater Measures to manage wastewater effluents include:  Land application of wastes with high dissolved solids concentrations is generally preferred over discharge to surface water subject to an evaluation of potential impact on soil, groundwater, and surface water resulting from such application;  Recycle filter backwash into the process if possible;  Treat and dispose of reject streams, including brine, consistent with national and local requirements.  Disposal options include return to original source (e.g. ocean, brackish water source, etc.) or discharge to a municipal sewerage system, evaporation, and underground injection. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 51 - Hazardous Waste Measures to prevent, minimize, and control potential environmental impacts associated with the storage, handling and use of disinfection chemicals in water treatment facilities include:  For systems that use gas chlorination:  Install alarm and safety systems, including automatic shutoff valves, that are automatically activated when a chlorine release is detected  Install containment and scrubber systems to capture and neutralize chlorine should a leak occur  Use corrosion-resistant piping, valves, metering equipment, and any other equipment coming in contact with gaseous or liquid chlorine, and keep this equipment free from contaminants, including oil and grease  Store chlorine away from all sources of organic chemicals, and protect from sunlight, moisture, and high temperatures  Store sodium hypochlorite in cool, dry, and dark conditions for no more than one month, and use equipment constructed of corrosion-resistant materials;  Store calcium hypochlorite away from any organic materials and protect from moisture; fully empty or re-seal shipping containers to exclude moisture. Calcium hypochlorite can be stored for up to one year;  Isolate ammonia storage and feed areas from chlorine and hypochlorite storage and feed areas;  Minimize the amount of chlorination chemicals stored on site while maintaining a sufficient inventory to cover intermittent disruptions in supply;  Develop and implement a prevention program that includes identification of potential hazards, written operating procedures, training, maintenance, and accident investigation procedures;  Develop and implement a plan for responding to accidental releases. 7.3.2.3 Water Distribution System Leaks and Loss of Pressure Water System Leaks and Loss Pressure Measures to prevent and minimize water losses from the water distribution system include:  Ensure construction meets applicable standards and industry practices;  Conduct regular inspection and maintenance;  Implement a leak detection and repair program (including records of past leaks and unaccounted- for water to identify potential problem areas); DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 52 -  Consider replacing mains with a history of leaks of with a greater potential for leaks because of their location, pressure stresses, and other risk factors. Water Discharges  Recommended measures to prevent, minimize, and control impacts from flushing of mains include:  Discharge the flush water into a municipal sewerage system with adequate capacity;  Discharge the flush water into a separate storm sewer system with storm water management measures such as a detention pond, where solids can settle and residual chlorine consumed before the water is discharged;  Minimize erosion during flushing, for example by avoiding discharge areas that are susceptible to erosion and spreading the flow to reduce flow velocities. 7.3.2.4 Sanitation Measures to prevent, minimize, and control releases of septage and other fecal sludge include:  Promote and facilitate correct septic tank design and improvement of septic tank maintenance. Septic tank design should balance effluent quality and maintenance needs;  Consider provision of systematic, regular collection of fecal sludge and septic waste;  Use appropriate collection vehicles. A combination of vacuum tanker trucks and smaller hand-pushed vacuum tugs may be needed to service all households;  Facilitate discharge of fecal sludge and septage at storage and treatment facilities so that untreated septage is not discharged to the environment. 7.3.2.5 Wastewater and Sludge Treatment and Discharge Sewage will normally require treatment before it can be safely discharged to the environment. The degree and nature of wastewater and sludge treatment depends on applicable standards and the planned disposal or use of the liquid effluent and sludge and the application method. The various treatment processes may reduce suspended solids (which can clog rivers, channels, and drip irrigation pipes); biodegradable organics (which are consumed by microorganisms and can result in reduced oxygen levels in the receiving water); pathogenic bacteria and other disease-causing organisms; and nutrients (which stimulate the growth of undesirable algae that, as they die, can result in increased loads of biodegradable organics). Wastewater discharge and use options include discharge to natural or artificial watercourses or water bodies; discharge to treatment ponds or wetlands (including aquiculture); and direct use in agriculture (e.g., crop irrigation). In all cases, the receiving water body use (e.g. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 53 - navigation, recreation, irrigation, or drinking) needs to be considered together with its assimilative capacity to establish a site-specific discharge quality that is consistent with the most sensitive use. The most significant environmental impacts related to wastewater and sludge treatment, discharge, and use include:  Liquid effluents  Solid waste  Air emissions and odors  Hazardous chemicals  Ecological impacts 7.3.2.6 Information Campaign/Public Hearing An information campaign shall be undertaken to inform and get the feedback of the people on sub projects that trigger EMPs and RAPs, its potential impacts and proposed mitigating measures. This can be in the form of a public hearing or meetings to inform officials, traditional and community leaders, etc. In Ghana, a public hearing is scheduled only if there are significant concerns against a project. On the other hand, meeting among stakeholders can be a management tool to inform, clarify misconceptions, give feedback on proposed mitigating measures to issues that were raised, plan for cooperative action – i.e. land use, traffic management, implementation of MMAs Development Plan, etc. These can also be occasions to firm up recommendation on a monitoring mechanism and as venues to reach consensus on outstanding issues. Misconceptions about MMAs/Department of Urban Roads requirements for compensation without building permits may be clarified or further discussed. The officials and representatives of the various sectors of the population shall be properly briefed on their role in the proper implementation of the Environmental Impact Assessment System in such phases as project planning, implementation, and environmental and social impact monitoring and evaluation. This is designed to increase stakeholder participation – host community, local governments, NGO, etc., role in environmental management and social development in cooperation with the proponent. This can be part of the program during a public hearing/meeting. Information dissemination shall also be done on a regular basis to communicate the result of project monitoring. Results of periodic monitoring shall also be given to the districts and localities. 7.3.2.7 Continuing Dialogues and Consultations on Resettlement Consultations shall be conducted on site identification regarding the process of relocation, the terms of compensation and other issues relative to resettlement. The negotiation of an acceptable package and the settlement of important concerns may be settled through dialogue which shall be a continuing feature of problem solving and cooperation among Department of Urban Roads, the local government and affected and host populations. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 54 - 7.3.2.8 Dissemination of Monitoring Results Information dissemination is also done on a regular basis to communicate the result of project monitoring and evaluation. In addition to the MMPCU, results of periodic monitoring shall be submitted to the assembly, which shall be enjoined to disseminate critical information to their constituents and submit recommendations on the resolution of issues when necessary. 7.3.2.9 Environmental Information and Awareness Raising Campaign The MMAs should educate the general public through the local media to desist from dumping rubbish and other solid waste matter into the open drains, a practice which prevents road side drains from functioning properly. 7.3.2.10 Prompt payment of Compensation The time lag between field measurements of affected properties and preparation of compensation for the beneficiaries by the Land Valuation Board should be reduced, as work sometimes had to be suspended pending receipt of approval. Secondly, such delays tend to bring untold hardship to the affected persons (beneficiaries) and a great inconvenience to both the Contractor and the Consultants on the project. 7.4 INTEGRATION OF THE EMP Impact mitigation, Sanitation and Water Services improvement can be achieved through management and monitoring programmes. This section outlines a programme that accomplishes environmental protection and monitoring, as well as contributing to governmental strengthening of institutions. 7.4.1 Environmental Management The critical point of any Sanitation and Water project is the implementation phase where the immediate environment could be degraded or improved upon. The negative impacts identified as of potential concern relate to the construction phase of the project. This implies that the activities of the Contractor, therefore, have a direct impact on the environment. In order to be effective, environmental management must be fully integrated with the overall project management effort, which in itself should aim at providing a high level of quality control. Environmental Management is carried out during all stages of the project planning, design and implementation. Environmental Protection can be achieved through the effective mitigation of anticipated adverse impacts or drawbacks associated with the project and enhancement of the project benefits. To ensure that the mitigation measures proposed are well implemented, an environmental management program is recommended. 7.4.2 Objectives of Program Environmental management deals with how mitigation measures proposed are implemented and assign the responsibility and costs, if appropriate, in its implementation. The programme has the following objectives:  Management of potential environmental impacts from water and sanitation facilities and related activities, and vice versa;  Enhancement of water and sanitation facilities attributes, especially with regard to integrated local development; and DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 55 -  Government institutional strengthening in conducting environmental protection and monitoring of water and sanitation projects. These objectives can be achieved through the following components of the environmental programme: (a) MMPCUs will be engaged in the following:  Checking the progress of the Contractor in implementing the mitigation measures outlined in the Contract documents and EIA report.  Liaising with an advisory group (e.g. EPA) regarding policies, procedures, contracts and approaches for administering and monitoring environmental protection activities;  Coordinating parties involved in the impact mitigation and enhancement process, including: Contractors, Consultants, Governmental and Non-Governmental Officials at all levels, as well as the public;  Facilitating environmental monitoring and evaluation of the bio-physical and socio-economic concerns pertaining to the Sanitation and Water Facility Projects;  Helping to administer resources designated for assistance at the local level; and  Conducting studies as well as performing other project related tasks. (b) Contractor requirements for environmental protection to be implemented during the construction phase of the project. (c) The requirements of the Construction Supervision Consultant regarding monitoring during the period of the project, (i.e. both construction and operation phases). 7.4.3 Resources for Programme Implementation The resources required for implementing the environmental management programme are basically personnel and finance. The key stakeholders in the environmental management activities are the members of the MMPCUs, Environmental Management Subcommittee the Contractor, MLGRD and the public. 7.4.3.1 Pre-Construction Phase If the screening process of a sub project triggers a RAP, EIA or ESMP, the following principles apply. Prior to Contractor mobilization and the commencement of construction, environmental management will cover the following:  Environmental review of the water and sanitation facility to be completed  Detailed EIA including Environmental Management and Monitoring Plan which will be developed by a consultant on the basis of a ToR agreed with the MLGRD, but contracted by the respective MMA.  Works Department of MMAs, reparation of detailed designs which gives due consideration to minimization of adverse impacts and benefit enhancement. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 56 - 7.4.3.2 Construction Phase Environmental management during the construction phase is essentially concerned with controlling impacts, which could result from the activities of the Contractor. This can be done through the enforcement of Contract Clauses relating to environmental protection. These clauses will not themselves, however, have any effect unless they are fully implemented and enforced. 7.4.3.3 Operation and Maintenance Phase Some of the impacts, which are expected to occur during the operational phase, are essentially related to the design of the sub project. In this respect, the principal environmental management functions are the responsibility of the design consultant. Matters relating to routine and periodic maintenance will be the responsibility of Works Department of MMAs who will as well be responsible for the environmental management of the water and sanitation facilities where relevant. 7.4.3.4 Responsibilities at MMA Level The Project Phase (i) Feasibility – Propose environmentally friendly project and design method.  Proposed a project requiring felling of the lowest feasible number of trees. (ii) Detailed Design – Design the project for the least negative environmental impact during the operational life of the project.  Design the project for environmentally friendly construction methods.  Design the project proscribing materials with the least negative environmental impact.  Incorporate any feasible safety measure within the project design  Design environmentally friendly projects with drainage systems. (iii) Implementation Phase  Supervise and enforce the Contractor’s performance on all environmental requirements included in the Contractor Documents.  Monitor the overall environmental impact of the project and recommend additional mitigation measures for implementation when deemed necessary.  Liaise with the local health, traffic and educational authorities to plan agreed awareness raising campaigns. 7.4.3.5 Responsibilities of the Contractor The Project Phase (i) Mobilization: Ensure that all staff, including managers and foremen are well informed about all environmental issues of the project.  Train all site managers and foremen in environmentally friendly construction methods.  Ensure that all equipment mobilized fulfill the environmental requirements in the Contract Documents. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 57 -  Establish and maintain environmentally friendly construction camps well provided with sanitary facilities.  Obtain necessary approvals for all burrow pits and quarries.  Establish a spoil and waste management plan comprising all types of wastes. (ii) Project Implementation: Apply environmentally friendly equipment and construction methods.  Ensure occupational health and safety for all workers and visitors to the sites.  Inform the Supervisory Engineer if the occurrence of any unforeseen negative environmental impact should occur. (iii) Demobilization: Ensure that all affected project areas have been properly cleaned of waste, graded and revegetated. 7.5 MONITORING 7.5.1 Construction Phase The aim will be to assess the mitigation measures for noise, vibration, water quality, dust, air quality and public safety using visual assessment by the management and feedback from the other stakeholder. Transportation: Equipment, motor vehicles and transport of materials and personnel shall be closely monitored to include the following activities:  Speed limits of vehicles  Motor vehicles condition and maintenance  Vehicle safety signals  Loading and off-loading procedures  Vehicle license and permit to drive, and  Kit for first aid and fire extinguisher Civil Works: The monitoring criteria should include the following:  Working gear and protective clothing  Noise levels  Plant and equipment maintenance  Concrete works  Dust levels  Vehicular and pedestrian safety  Destruction/Disruption of Utilities  Socioeconomic/Cultural Issues Wastes: Solid and liquid wastes which will be generated will have to be disposed off accordingly. These are expected to include:  Vegetation  Solid wastes DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 58 -  Mud and top soil  Liquid waste from concrete works and pumping water from excavations  All wastes such as vegetation and mud will be sent to recognised dump sites or used to fill holes left after construction of drains 7.5.2 Operation and Maintenance Phase The monitoring plan will ensure that the negative impacts of the operation and maintenance of the upgrading of water and sanitation facility are reduced to the barest minimum. This will guarantee the safety and health of the employees and the public at large. This would include:  Cleaning/de-silting of the drains or removal of wastes from the drains  Monitor the regular watering of the un-tarred surface  Monitor speed of vehicles and traffic loads to assess the necessity for road upgrade  Repairs service pipes for water, drains and walkways  Hygiene education and education on the proper use of the facilities DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 59 - 8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) During the implementation of Sanitation and Water Project activities in the GAMA , potential environmental and social impacts must be considered and managed. The impacts must be mitigated, minimized or preferably avoided particularly to meet the requirements of World Bank safeguards policies and Ghana national law requirements. The objective of the ESMF is to outline the institutional arrangements relating to: (i) identification of environmental and social impacts arising from activities under the GAMA projects, (ii) the implementation of proposed mitigation measures, (iii) Capacity Building and (iv) Monitoring. The ESMP will be included in a manual of Operations. The ESMF outlines mechanisms for:  Screening of proposed sub-projects, identifying potential environmental and social impacts and management of safeguard policies implications;  Institutional arrangements for implementation and capacity building  Monitoring ESMF measures implementation;  Public consultation;  The estimated costs related to the ESMF. 8.1 THE ENVIRONMENTAL AND SOCIAL SCREENING PROCESS A screening process, selection and evaluation of GAMA projects are required to manage environmental and social aspects of these activities. The sections below show the various stages of this environmental and social screening process: i. Screening: identify actions that have negative environmental and social impacts; ii. Determination of environmental categories: identify appropriate mitigation measures for activities with adverse impacts; iii. Implementation of environmental work: activities that require separate EIA; iv. Review and approval of the selection. v. Dissemination of EIA. vi. Supervision and monitoring These steps are explained in the following paragraphs and incorporate those responsible for implementing each step. The stakeholders identified and their roles are developed in detail in the chapter "Strengthening institutional capacity�. The screening process determine which project and sub-project activities are likely to have negative environmental and social impacts; to determine appropriate mitigation measures for activities with adverse DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 60 - impacts; to incorporate mitigation measures into the project as appropriate and to monitor environmental parameters during the implementation of activities. The extent of environmental assessment that might be required prior to the commencement of the projects will depend on the outcome of the screening process. The seven stages of the environmental and social screening process leading to the review and approval of the GAMA project activities to be implemented are described below. 8.1.1 The Screening Process The purpose of the screening process is to determine whether sub-projects are likely to have potential negative environmental and social impacts; to determine appropriate mitigation measures for activities with adverse impacts; to incorporate mitigation measures into the sub-projects design; to review and approve sub-projects proposals and to monitor environmental parameters during implementation. The extent of environmental and social work that might be required for the projects prior to implementation will depend on the outcome of the screening process. This process should include screening for possible resettlement impacts. Table 8-1: Structures involved in the GAMA Environment and Social Management Intervention Environmental structures Comment Other environmental level stakeholder MMAs  Metropolitan/Municipal Functional NGO Planning and Coordinating Unit(M/MPCU)  Metropolitan/Municipal Works Unit  Regional EPA Officers (EPA) National EPA, MLGRD Functional MWRWH, Ghana Water Company Limited, Community Water and Sanitation (CWSA),Lands Commission/Land Valuation MLGRD/PCU Functional  Environment and Social Officer  MLGRD  M&E officer DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 61 - Step 1 Screening of Sub-projects The screening process is the first step in the ESMF process. One of the objectives of the screening process is to rapidly identify those subprojects which have little or no environmental or social issues so that they can move to implementation in accordance with pre-approved standards or codes of practices or other pre-approved guidelines for environmental and social management. For each sub-project proposal the MMA, led by the Planner, will carry out a screening process. The Planning Officer will complete the Environmental and Social Screening Form (Annex 2b) and submit to the MMPCU for review as part of the project package. Completion of this screening form will facilitate the identification of potential environmental and social impacts, determination of their significance, assignment of the appropriate environmental category, proposal of appropriate environmental mitigation measures, or recommend the execution of an Environmental Impact Assessment (EIA), if necessary. Step 2: Determination of appropriate environmental categories Act 490 created a corporate body called the Environmental Protection Agency (the Agency) to replace the Environmental Protection Council, which was created under NRCD 239. Among its functions, the Agency was mandated: “... to ensure compliance with any laid down environmental assessment procedures in the planning and execution of development projects, including compliance in respect of existing projects,� section 2(i). Under section 12 (1) of the Act, the Agency: “... may by notice in writing require any person responsible for any undertaking which in the opinion of the Agency, in respect of the undertaking, an environmental impact assessment containing such information within such period as shall be specified in the notice.� Section 28 of the Act deals with Regulations. It provides under subsection 2(b) that regulations may be made to provide for: “... the category of undertakings, enterprises, constructions or developments in respect of which environmental impact assessment or environmental management plan is required by the Agency.� In order to meet the immediate demand imposed by section 2 (i) of Act 490, the Ghana EIA Procedures were developed, published and launched in 1995. The procedures formed the basis for the Environmental Assessment Regulations, 1999 (LI 1652). LI 1652 follows in broad terms, the procedures for the preparation of an environmental assessment report. It provides a graduated system for determining what will be demanded from a proponent on the basis of the size and likely impacts of a particular project. On receipt of an application, including such information as may be required; the Agency will carry out an initial assessment taking into consideration factors such as:  Location, size, and likely output of the undertaking; DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 62 -  Technology intended to be used;  Concerns of the general public, if any, and in particular concerns of immediate residents if any; and  Land use, and other factors of relevance to the particular, undertaking to which the application relates. To enable the Agency make a determination as to the level of environmental assessment of any undertaking, the applicant must submit to the Agency a report on the undertaking and indicate in the report:  The environmental, health and safety impact of the undertaking;  A clear commitment to avoid any adverse environmental effects which can be avoided on the implementation of the undertaking;  A clear commitment to address unavoidable environmental and health impacts and steps where necessary for their reduction; and  Alternatives to the establishment of the undertaking. Where the Agency is satisfied with an initial screening, it registers the activity which is the subject of the application and issues an environmental permit. Since the coming into force of LI 1652, the EIA procedures have been applied fully and effectively to both privately and publicly funded undertakings. The Agency is responsible for the implementation of the Regulations. SCHEDULE 2 OF LI 1652 The Regulations prohibit the commencement of various undertakings listed in a schedule without prior registration with the EPA and the issuance of a permit. The activities listed in Schedule 2 of the Regulations, fall within the ambit of the activities for which an environmental impact assessment is mandatory. Among the activities listed in schedule 2 under waste treatment and disposal are the following:  Construction of incineration plant;  Construction of recovery plant (off-site);  Construction of wastewater treatment plant (off-plant);  Construction of secure landfills facility; and  Construction of storage facility. The undertakings under municipal solid waste that are subject to full EIA are:  Construction of incineration plant;  Construction of composting plant;  Construction of recovery/recycling plant;  Construction of municipal solid waste landfill facility; and  Construction of waste depots. REPORTING UNDER L.I. 1652 The Regulations provide for a number of reports. These are:  Screening report;  Preliminary environmental report; DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 63 -  Scoping report;  Environmental Impact Statement; and  Annual environmental report. SCREENING REPORT The screening report is prepared at the earliest stages of the EIA process and allows a determination to be made by the Agency about the level of environmental assessment of a particular undertaking. PRELIMINARY ENVIRONMENTAL REPORT In some instances, the Agency may come to the conclusion that an activity requires a preliminary environmental report (PER). Where such a decision is arrived at, the applicant would be required to submit a PER. The PER will contain details extending beyond that contained in the initial application. The new application must state specifically the detailed effects of the proposed undertaking on the environment. Where a PER is approved, it is registered and an environmental permit is issued. In the event that on receipt of a PER the Agency is satisfied that there will be a significant and adverse impact on the environment, the applicant will be expected to submit an environmental impact statement (EIS) on the undertaking for assessment of the environmental impact of the proposed undertaking. SCOPING REPORT The Regulations require that the EIS shall be outlined in a scoping report. The scoping report sets out the scope or extent of the EIA to be carried out by the applicant and includes draft terms of reference (TOR) which must indicate the essential issues to be addressed in the EIS. Among the issues that the draft TOR must address are the following:  Identification of existing environmental conditions;  Information on potential, positive and negative impacts from the environmental, social, economic and cultural aspects in relation to the different phases of development of the undertaking;  Potential impact on health of people;  Proposals to mitigate any potential negative socio-economic, cultural and public health impacts of on the environment;  Proposals for monitoring predictable environmental impact and proposed mitigating measures;  Contingency plans;  Consultation with members of the public likely to be affected by the operations of the undertaking;  Provisional environmental management plan; and  Proposals for payment of compensation for possible damage to land or property arising from the operation of the undertaking. On the acceptance of a scoping report by the Agency, the applicant is informed to submit an EIS based on the scoping report DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 64 - ENVIRONMENTAL IMPACT STATEMENT The EIS must address potential direct and indirect impact of the undertaking on the environment at the pre- construction, construction, operation, decommissioning and post-decommissioning phases. Among the items to be addressed are the following:  Concentration of pollutants in environmental media including air, water and land from mobile or fixed sources;  Alteration in ecological processes such as transfer of energy through food chains, decomposition and bioaccumulation which could affect any community, habitat or species of flora and fauna;  Ecological consequences of direct destruction of existing habitats from activities such as dumping of waste and vegetation clearance and fillings;  Noise and vibration levels;  Odour; and Additionally, changes in social, cultural and economic patterns must be dealt with in relation to the following:  Decline in existing or potential use arising out of matters referred to above;  Direct or indirect employment generation;  Immigration and resultant demographic changes;  Provision of infrastructure such as water and sanitation facilities;  Local economy;  Cultural changes including possible conflict arising from immigration and ANNUAL ENVIRONMENTAL REPORT A person granted an environmental permit under the Regulations is required to submit an annual environmental report in respect to his undertaking after 18 months from the date of commencement of his operations and thereafter on a 12 monthly basis to the Agency. The EPA is required to define the form and content of the Annual Environmental Report. PUBLIC CONSULTATION Public participation is provided for in the Regulations. These provisions are secured through advertisement of the scoping notice for comments and public hearings. There is a Technical Review Committee that reviews Environment Impact Statements (EISs) prior to permitting of all undertakings for which EIAs are required. The membership of this committee is constituted on the discretion of the Agency through the use of administrative procedures. Based on screening results, the appropriate environmental category for the GAMA proposed activity will initially be determined by the Planner in the screening form, the rating and screening form will be reviewed by the MMPCU and confirmed by the Statutory Planning Committee. After determining the correct environmental category, he/she will determine the extent of environmental work required. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 65 - The distribution of appropriate environmental categories draws on provisions contained in the document OP 4.01 of World Bank on environmental assessment as well as Ghana EPA EA Procedures. The determination of environmental categories of subprojects GAMA will be as follows: If the screening form contains only the entries 'No or Not Applicable (NA) in the entries then' environmental category C applies which indicates that environmental impacts and social issues are considered minor and do not require mitigation. For example, some rehabilitation activities (minor repairs, etc.) could be classified as C; The distinction between categories will be determined based on the implications of the Safeguard Policies as stated in the instructions below. Table 8.2 summarizes the environmental work to be performed by classification category of activity. Table 8-2: Category of Environmental Studies Sub-project Category Environmental work to be implemented Projects in this category will require full EIA Category A Project - Identify and assess potential environmental impacts of the subproject; - Prepare the ToR for the EIA (Cat. B); -EIA prepared by a consultant Project Category B requiring an environmental and / - To the EIA by service providers; or social assessment - Review and approve the EIA. Implement all mitigation, institutional and monitoring measures during implementation and operation of achievements to eliminate, reduce or mitigate environmental and social impacts No environmental assessment is required Project Category C Step 3: Implementation of environmental and social work The results of the determination of step 2 for both cases in (b), the following environmental work will be performed:  Sub-projects of Category B – Separate Environmental Impact Assessment (EIA) The planning and implementation of environmental work including the EIA are described in the box below. The MMA prepares the Terms of Reference for the EIA, the recruitment of consultants for EIA will be conducted by the MMAs. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 66 - To determine mitigation measures for inclusion in the sub-project TOR, the elements of the mitigation measures section below (the impacts and associated mitigation measures) organized as a checklist will serve as the basis. In addition, TOR must verify that the contents of ESMP sub-projects comply. To facilitate the formulation of TOR, a TOR-type has been prepared and placed in the appendix. The EIA will identify and evaluate potential environmental impacts for the proposed activities, evaluate alternatives, and design mitigation measures. The preparation of the EIA will be done in consultation with stakeholders, including people who may be affected. Public consultations are critical in preparing a proposal for the activities of the GAMA likely to have impacts on the environment and population. The public consultations should identify key issues and determine how the concerns of all parties will be addressed in the EIA. When an EIA is necessary, the administrative process enacted by the EPA will be followed and executed. Table 8-3: Procedures for EIA Procedures for sub-projects requiring an EIA First step: Preparation of Terms of Reference The results of identification, and extent of the EIA (scoping), the terms of reference will be prepared by the MMA in collaboration ESO at MLGRD. Second step: Selection of consultant Third stage: Preparation of the EIA with public consultation The report will follow the following format:  Description of the study area  Description of the subproject  Discussion and evaluation of alternatives  Environment description  Legal and regulatory  Identifying potential impacts of proposed sub-projects  Process of public consultations  Development of mitigation measures and a monitoring plan, including estimates of costs and responsibility for implementation of surveillance and monitoring Step Four: Review and approval of the EIA for the sub-project; Publication / Dissemination of EIA Step 4: Review and approval of EIA The proponent submits the final draft EIA to EPA. The report is reviewed by the MMA and by the EPA. Copies of the EIA are placed at vantage points including the EPA Library, relevant MMA, EPA Regional Offices. EPA serves a 21-day public notice in the national and local newspapers about the EIA publication and its availability for public comments. Step 5: Public Hearing and Environmental Permitting Decision (EPD) Public Hearing Regulation 17 of the LI 1652 specifies three conditions that must trigger the holding of a public hearing on a project by the Agency. These are: DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 67 -  Where a notice issued under regulation 16 results in great public reaction to the commencement of the proposed undertaking;  Where the undertaking will involve the dislocation, relocation or resettlement of communities and  Where the Agency considers that, the undertaking could have extensive and far -reaching effects on the environment. Where a public hearing is held, the processing of an application may extend beyond the prescribed timelines required for EPA’s actions and decision-making. Environmental Permitting Decision (EPD) Where the draft EIA is found acceptable, the proponent is notified to finalise the report and submit eight hard copies and an electronic copy. Following submission to EPA, the proponent shall be issued an Environmental Permit within 15 working days and issue gazette notices. Where the undertaking is approved, the proponent shall pay processing and permitting fees prior to collection of the permit. The fees are determined based on the Environmental Assessment Fees Regulations, 2002, LI 1703. Step 6: Environmental Monitoring Environmental monitoring aims to ensure compliance with: (i) the measures proposed in the ESMP and the EIA of a sub-project, including mitigation measures, (ii) the commitments of Contractor in connection with the permissions required, (iv) requirements relating to laws and regulations. Environmental monitoring involves both the construction phase and the operation phase. The monitoring program may allow, if necessary, to reorient the work and possibly improve the course of the construction and implementation of different project components. Monitoring goes hand in hand with the establishment of impacts and proposed measures for prevention, mitigation. Monitoring is essential to ensure that: (i) the impact predictions are accurate (monitoring effect), (ii) prevention / mitigation can achieve the desired objectives (monitoring effect), (iii) regulations and standards are met (compliance monitoring), (iv) the criteria for use of the environment are respected (inspection and monitoring). Environmental monitoring of GAMA activities will be conducted under the project general system of monitoring. It will be done at two levels:  Performance monitoring at central level: At central level, the GAMA will involve MLGRD.  Implementation of monitoring at local level /MMAs: At the MMAs level, monitoring will be conducted by the MMPCU and Regional EPAs. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 68 - The tracking system relies on a set of sheets to prepare and submit to ensure that all recommendations regarding environmental and social issues, mitigation and strengthening measures are applied. For monitoring, these reports can be: - A verification form: on the basis of individual project impacts and measures laid down a plan for verification of their implementation is adopted. - A control form: it is used to detect non-compliance with environmental requirements, potential environmental risks unreported among impacts. This leads to demands for compliance and implementation of preventive action. Step 7: Development of Monitoring Indicators Monitoring measures will focus on key indicators to be defined considering both the positive and negative impacts of the projects. The monitoring indicators will be parameters which will provide quantitative and / or qualitative information on the direct and indirect impacts of the GAMA environmental and social benefits. The choice of indicators will be guided by the characteristics of relevance, reliability, usefulness and measurability. To evaluate the effectiveness of mitigation measures of GAMA activities impacts, we propose to use the indicators listed in the table below. Environmental guidelines for firms serve as indicators. Oversight for the environmental and social management process of the sub-projects will be assured by the MMPCUs.. The environmental monitoring and supervision program for the implementation of the GAMA will serve as an integral part of the operational activities of MLGRD and will generate the requisite information for environmental management and environmental information dissemination and public disclosure. The following monitoring indicators are proposed for assessing the efficiency of the mitigation measures:  Safe waste management related to construction works  Compliance with the MWRWH/EPA Environmental Guidelines for Contractors  Best practice in the implementation of project activities. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 69 - Table 8-4: Process Monitoring Indicators of ESMP Measures Measures Intervention field Indicators -Develop the TOR Technical -Conducting Environmental Impact -Number of ESIAs/ESMPs/ Health Safety Plans submitted measures Assessment (EIA and ESMP) for each sub-project in a MMDA (studies) -Develop a health and safety plan -Number of study elaborated -List of indicators identified for all sub-projects as may Measures for Perform monitoring and evaluation stipulated under the environmental permitting conditions monitoring and ESMP (continuous monitoring, mid- -Number of monitoring missions for all sub-projects evaluating term and annual assessment) -Number of monitoring reports submitted for all sub- projects projects -Develop a TOR for the Environmental unit Engage existing Environmental Units in -Environmental Units are functional in MMAs the MMAs -Number of EA trainings conducted for staffs in MMAs Institutional Awareness and structured Training for -number of attendance (male/female) at EA trainings measures staff of MLGRD and MMAs working -Number of awareness trainings conducted before, during on the GAMA and after project implementation in each MMA -Number of staff tin attendance at the awareness trainings (Male/Female) Awareness about HIV / AIDS Communication campaign and -Number of sub-project sites with adequate posters Awareness awareness before, during and after construction DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 70 - Table 8-5: Indicators and Monitoring Mechanism of Environmental and Social Issues Elements of Methods and devices for monitoring Responsible Period monitoring and indicator Water - Follow up of procedures and facilities for the MMPCUsand Regional Start, mid-term and end Pollution disposal of liquid wastes EPAs of - Monitoring of groundwater and surface water Rehabilitation / around project site construction activities - Monitoring surface water using activities operating infrastructure Soils - Visual assessment for soil erosion MMPCUs and Regional Start, mid-term and end Erosion / gulling - Availability of approved applications to open EPAs of activities Pollution / career degradation - Availability of career opening statements - Verification of suitable measures for the management of lubricants / Diesel/ used oils Vegetation / - Visual assessment of reforestation / plantation Forest Start, mid-term and end Wildlife measures Commission/Parks and of activities Degradation rate of - Controls on clearing Gardens reforestation - Control and monitoring of sensitive areas - Control of attacks on wildlife Human Hiring local labor priority - MMPCUs and Regional Start, mid-term and end environment Respect the heritage and sacred sites - EPAs of activities Monitoring the level of noise at construction - site - Follow-up measures to reduce dust - Verification of the use of landfill sites licensed for construction waste - Truck noise MMPCUs and Regional Start, mid-term and end Verification: EPAs of activities - Of disease vectors presence and the onset of diseases related to work Hygiene and health - Diseases associated with various projects (HIV Pollution and / AIDS, etc..) nuisances - Respect of hygiene measures on the site - Monitoring management practices of liquid and solid waste (whole chain) operating infrastructure - Existence of liquid and solid waste management plan and necessary equipment - Existence of health and safety plan Works Department of Monthly Verification: MMPCUs/Regional - Availability of safety guides in case of EPAs accident - Availability of appropriate signage - Compliance with traffic regulation Safety in - Respect the speed limit - Appropriate protective equipment wearing construction sites DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 71 - 8.1.2 Responsibilities for the Implementation of the Screening Process The ESMF will be implemented by MLGRD. MLGRD will collaborate with the EPA and the World Bank to ensure effective execution. Table 8.6 provides a summary of the stages and institutional responsibilities for the screening, preparation, assessment, approval and implementation of the GAMA activities. The extent of environmental assessment that might be required prior to the commencement of the sub-projects will depend on the outcome of the screening process. The key stages of the environmental and social screening process leading to the review and approval of the GAMA activities to be implemented are described below: Table 8-6: Summarized Environmental Screening Process and Responsibilities Stage Management Implementation responsibility responsibility 1. Screening Environmental and Social Sanitation and MLGRD/MMAs MMPCU Planning Officer2 Water Project: Selection including public consultation 2. Determination of appropriate environmental categories 2.1 Selection validation MMPCU, Planning Officer 2.2 Classification of Project EPA, MMPCU and Planning Determination of Environmental Work MLGRD/MMAs Officer Review of screening 3. Implementation of environmental work MLGRD/MMAs MMPCU and Planning Officer in the MMAs, 3-1. If EIA is necessary MMPCU 3.1.a Preparation of terms of reference MLGRD/MMA MMPCU 3.1 b Selection of Consultant MLGRD MMA 3.1 c Realization of the EIA, Public Consultation MMPCU/MLGRD Environmental Consultant Integration of environmental and social management MMPCU and Planning Officer plan issues in the tendering and project implementation, Procurement and Works Department Units of MMAs/ MLGRD 4 Review and Approval 4.1 EIA Approval EPA EPA, , World Bank 5. Public Consultation and disclosure MLGRD/EPA MMPCU and Planning Officer 6. monitoring /MMAs/EPA MMPCU and Planning Officer 7 Development of monitoring indicators for EIA as MLGRD MMPCU and Planning Officer may be stipulated under tbe environmental permitting conditions. 2 If necessary, the MPCU can assign a designated, capable officer to carry out the screening process if MPCU sees that need. However, the planning officer will still be the final signatory to the screening format. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 72 - 8.2 MITIGATION MEASURES 8.2.1 General mitigation measures Environmental mitigation consists of measures that can reduce the negative environmental impacts associated with implementation (construction, expansion, rehabilitation etc) of the project. Mitigation measures have been identified that would reduce both existing and potential impacts associated with GAMA activities. Potential impacts and the mitigation measures are identified in Table 8.7. Tables 8.7 and 8.8 below indicate the areas to which the potential impact applies. In addition, mitigation measures are identified as either social or physical measures. Social mitigation includes the measures used to mitigate effects such as noise and other effects to the human environment. Physical mitigation includes measures that address impacts to the physical environment, such as vegetation, air quality, and others. The measures serve as the basis for the cost estimates. Design Measures The quantities, specifications and estimated costs of design measures to avoid or mitigate negative impacts will be assessed by the civil design contractor and incorporated into the bidding documents. The contractor will execute all required works and will be reimbursed through pay items in the bill of quantities, which will be financed by the project. Table 8-7: General Mitigation Measures Measures Proposed actions - ESIA / ESMP Studies Technical measures - Conduct a communication campaign and advocacy before construction work - Ensure compliance with hygiene and security in facilities sites - Undertake the marking of site under construction site - Use the local workforce as a priority - Ensure adherence to safety rules at work - Ensure the collection and disposal of waste arising from work Construction and - Provide the project accompanying measures (connection to water networks, electricity and operational measures sanitation, equipment, program management and maintenance) - Conduct awareness campaigns on HIV / AIDS - Engage closely MLGRD services in monitoring the implementation - Rehabilitate quarries and other sites for loans - Respect of protected species including trees - Management of Environmental and Health Hazards. DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 73 - 8.2.2 Specific construction impacts mitigation measures Table 8-8: Summary of Environmental Mitigation Measures Potential Impacts Recommended Mitigation Measures Physical Land Use Noise  Employees and communities exposed to high noise level  Installation of sound insulation.  Disturbance of during construction works  Schedule work periods to avoid peak hours Air Quality  Emission of pollutants from mobile (vehicles) and stationary (mixers, etc)  Introduction of dust reduction measures in construction sites sources.  Safety measures put in place  Air pollution from burning of demolition wastes e.g. wood, paper etc Soil  Point source contamination from diesel, lubricants etc around workshop  Appropriate containment measures for all operational areas and proper areas. disposal of used lubricants.  Increased soil erosion due to vegetation clearing , soil trampling and  Soil erosion control measures (e.g. reforestation, reseeding of grasses, compaction land preparation, terracing etc)  Increased rapid runoff due to vegetation clearing and soil compaction diminishing infiltration capacity  Deterioration of soil characteristics due to increased erosion Water Quality  Potential pollution of surface and ground water though runoff of  Appropriate containment measures for all operational areas and proper pollutants e.g. lubricating oil, diesel fuel etc from workshop areas etc disposal of used lubrication oil.  Water pollution due to seepage from tanks (diesel, sanitary wastes etc)  Work sites Installed far from waterways  Lack of water for sanitation or toilet facilities  Regular collection of work sites wastes for proper disposal  Heavy water usage resulting in reduction of surface and groundwater  Liquid waste discharged at designated outfalls after effluent treatment to sources protect water resources  Regular emptying of on-site latrines and toilets Biological Resources Vegetation  Vegetation clearing resulting in loss of valuable habitat, species diversity  No siting and excavations in sensitive habitat and population levels.  Careful planning and selection of sites DRAFT ESMF of GAMA for MLGRD, Ghana, December, 2012 - 74 -  Impacts on protected areas; critical habitats for rare species or of ecologic  Forests and cultural heritage sites protection enforced. or domestic importance. Wetlands  Expansion and new construction encroaching on the wetland and directly  Preservation, restoration, and enhancement of existing wetland. impact wetland plant communities.  Sensitive and critical habitats avoided Solid/Hazardous Waste Management  Solid waste generated from demolition and construction activities  Quick sorting, collection and disposal of waste removed from the sites in containing potentially hazardous materials (e.g. asbestos). accordance with applicable regulations.  Waste generation during construction works Social Health and Safety  Risks of road accidents during work  Conduct an awareness raising campaign for the work sites staff and the  Contamination risk by HIV from the labour force. users of Sanitation and Water Facilities or services under construction/rehabilitation  Conduct awareness raising campaigns on HIV/AIDS Land Use  Involuntary displacement of populations or economic activities  Acquisition and relocation should occur in accordance with World Bank  Changes of existing uses within affected communities. OP/BP 4.12 Involuntary Resettlement.  Avoid facilities in areas that will need resettlement, the displacement; or the encroachment on historic, cultural or traditional use areas DRAFT ESMF of GAMA for MLGRD, Ghana, December, 2012 - 75 - 8.3 MONITORING PLAN The objective of the monitoring plan is to establish appropriate criteria to verify the predicted impact of the project, and to ensure that any unforeseen impacts are detected and the mitigation adjusted where needed at an early stage. It is expected that the proposed water and sanitation project will lead to Increased affordability of safe water for the population, increased access to safe water, Reduced rate of water related diseases, Improved Health and social development and POVERTY REDUCTION. The plan will ensure that mitigating measures are implemented during rehabilitation, upgrading and maintenance. Specific objectives of the monitoring plan are to:  Check the effectiveness of recommended mitigation measures;  Demonstrate that sub-project activities are carried out in accordance with the prescribed mitigation measures and existing regulatory procedures; and  Provide early warning signals whenever an impact indicator approaches a critical level. Oversight for the environmental and social management process of the sub-projects will be assured by the Planning Officers (POs) and the Environmental Health Officers (EHOs) in collaboration with the MLGRD. Monitoring will be conducted during all phases of the project. The MMA Planning Officer will prepare a long term monitoring strategy that will encompass clear and definitive parameters to be monitored for each sub-project. The monitoring plan will take into consideration the scope of development, the environmental and social sensitivity and the financial and technical means available for monitoring. The plan will identify and describe the indicators to be used, the frequency of monitoring and the standard (baseline) against which the indicators will be measured for compliance with the ESMP. A number of indicators would be used in order to determine the impact of the sanitation and water project with respect to increased employment, improved use of water and sanitation, greater equity in allocation of water and increased affordability of water and sanitation, reduction in waterborne deseases etc. Key monitoring indicators to measure these outcomes or results are presented in the table 8.9. Other considerations to determine the status of the affected environment are as follows: - Has the pre-project human and natural environmental state been maintained or improved through the provision of the sanitation and water facilities and; - Has the effectiveness of the ESMF technical assistance, review, approval and monitoring process been adequate to pre-empt and correct negative impacts inherent in certain types of Sanitation and Water Sanitation and Water Facilities projects? - Environmental Indicators: Loss of vegetation; Land degradation; Compliance with Legislations. DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 76 - Table 8-9: Results and Indicators for the Sanitation and Water Sector Result/Outcome Indicators 1. Availability of water - Change in water levels for lakes, rivers and water table 2. Preservation of water - Area of protected wetlands, lakes and rivers 3. Irrigation requirements - Amount of water needed to produce xm² of x food 4. Water leakages - % of water lost through water systems due to leakages 5. Recycling of water - Amount of sanitation water that is recycled - Amount of water used in industry that is recycled 6. Employment resulting from water and - Number of people directly and indirectly employed in water and sanitation construction and maintenance sanitation construction and maintenance projects 7. Pollution of water and soil - Levels of chemicals, minerals, metals, pesticides etc in soil and water (surface and ground water). 8. Treatment of waste water - Proportion of domestic, agricultural and industrial waste water that is treated before being discharged 9. Equity in domestic water and sanitation - Rate of connection to water/sanitation network for slums/shanty towns allocation compared to national average - Level of rural poor connection to water/sanitation network compared to national average 10. Equity in allocation of water between - Implementation of transparent public or public/private mechanisms to sectors allocate water 11. Household expenditure on water and - x% of household expenditure on water and sanitation by each income sanitation group in society 12. Cost of water for businesses - Water as a x% cost of agricultural value - Water as a x% cost of industrial value SPECIFIC IMPACTS INDICATORS 13. water and sanitation hygiene awareness - Improved collection and storage of drinking water - Proportion of people hand washing - Use of hygienic sanitation facilities 14. Domestic access to safe water (inc. time - Number of households connected to water network for x months of year savings) - Number of households within 1km of safe water for x months of year - Number of households who receive more than 20 litres of water per day 15. Business access to water - x% of agricultural water needs meet for x months of the year - x% of industrial water needs meet for x months of the year 16. Access to basic sanitation - Number of people with access to basic sanitation DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 77 - SPECIFIC/INTERMEDIATE IMPACT INDICATOR 17. Business productivity - x% change in food production/yield and processing costs x% change in industrial production costs INTERMEDIATE IMPACT INDICATORS 18. Sustainable extraction of water - Annual extraction of from surface and ground water, in relation to its minimum annual recharge (i.e. water balance sheet) 19. Rate of water borne diseases - Inflection rates for diseases such as diarrhoea, intestinal worms, parasitic infections etc. 8.4 RESPONSIBILITY AND INSTITUTIONAL ARRANGEMENT FOR IMPLEMENTATION AND MONITORING 8.4.1 Institutions responsible for implementation The institutions responsible for implementation of ESMP activities are described below: Table 8-10: Institutions Responsible for Implementation of ESMP Structures Responsible Areas of intervention Measures Supervisi Execution on Oversight Mitigation of negative impacts of Mitigation construction and rehabilitation Firms and ESO, MLGRD measures (environmental monitoring) MMAs MMA and MPCU Conducting Environmental Impact Assessment (EIA and ESMP) Consultant MPCUs ESO, MLGRD Technical Elaboration of health and safety plan Firms MMAs ESO measures ESMP implementation assessment Consultants ESO (permanent, at mid-term and final) and ESO MLGRD Subprojects environmental and social assessment, MLGRD Training ESO Local NGOs Monitoring and enforcement of environmental measures DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 78 - Structures Responsible Areas of intervention Measures Supervisi Execution on Oversight Communication campaign and awareness Awareness before, during and after construction Supervisi Execution (HIV) (optional) on Oversight 8.4.2 Project Institutional and Implementation Arrangements As part of the institutional arrangements, MLGRD will recruit an ESO that will be responsible for following up safeguards issues during project implementation. MLGRD will be responsible for (i) preparing TORs for the ESIA/EMP and RAP/ARAP if needed (ii) supporting MMAs in ensuring the contractors comply with the recommendations of these studies and environmental and social management clauses (inserted into the contract) during construction phase. The Bank will provide guidance on the elaboration of the TORs and the Ghana Environmental Protection Agency (EPA) will be responsible for providing overall quality control through the review and clearance of the ESIAs , and validating the Environmental Audit reports to be prepared at the completion of works by the contractors. EPA will also assist in enforcing compliance with Bank safeguards policies and monitor the implementation of the EMPs. The EPA will also support the MMAs in coordinating safeguards activities. Specific capacity building on environmental management and environmental assessment will be provided to the MMAs in addition to key staff of MLGRD, and other implementing focal points. In accordance with World Bank guidelines, all EIAs/EMPs will need to be reviewed and cleared by the Bank prior to the commencement of the civil works. Particular attention will be given to the development of the ARAPs/RAPs and their implementation given the relatively strong focus of the EPA on environmental rather than social and resettlement issues. Where necessary, other institutions like traditional authorities, the Lands Commission and the Land Valuation Board will be requested to support the monitoring of agreed action plans. The civil society and NGOs will be involved in the project implementation as part of the institutional arrangements.. This intervention will improve transparency and accountability bythe MMAs. DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 79 - 8.4.2.1 Institutional arrangements for implementation of ESMP Management of safeguards under GAMA is anchored under MLGRD as the lead implementing agency wth responsibility for management and ensuring compliance with ESMF, with the MMAs playing a key role in screening, reviewing and monitoring projects at the MMA level. Below are summarized the tasks assigned to different institutions in the screening process, monitoring and evaluation of mitigating measures implementation. Environmental Protection Agency The Environmental Protection Agency (EPA) is responsible for:  review and approve the environmental classification of subprojectsand also approval EIAs.  monitoring at national level implementation of environmental measures. The Ministry of Local Government and Rural Development MLGRD will be the lead implementing agency for the GAMA on the whole. The Planning, Budgeting, Monitoring and Evaluation (PBME) Department is the entity designated by MLGRD to manage the project. PBME will also supervise the implementation of the ESMF by the MMAs. The Planning and Development Unit (PDU) of the MMAs will execute the provisions of the ESMF on the ground. MLGRD is responsible for training in environmental and social assessment, and monitoring and evaluation of compliance with social and environmental safeguards in all sub projects. MLGRD will recruit an Environmental and Social Officer3 (ESO). The ESO’s main task is to analyze screening documents for sub projects triggering RAP/ESMP and ARAP, participation in EIA review, monitoring of MMA compliance with ESMF, monitoring activities of mitigation measures implementation and act as the interlocutor of the GAMA MLGRD and MMAs (Planning Officers and Environmental Health Officers).. Taking into account environmental and social aspects in the ESMP and the effective monitoring of environmental and social performance indicators should ensure that subprojects implemented under the GAMA's objectives do not result in effects that could negate any benefits. To this end, it is appropriate to establish an efficient mechanism for the management of environmental and social aspects of the sub-projects to be executed. MLGRD will provide staff to achieve the following objectives:  propose management rules and specific measures that are compatible with sustainable development while implementing the project  promote awareness by its personnel and the general public regarding environmental protection, Key recommendations for GAMA institutional strengthening to meet the needs of the ESMF are as presented in the summary of institutional responsibilities of the table 8.10 and are presented in the following table: : 3 The Environmental and Social Officer will the responsible for the monitoring of compliance with the ESMF and RPF provisions at MMA level. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 80 - Table 8-11: Institutional Arrangements for ESMP Implementation INSTITUTIONAL MEASURES Proposed actions Responsible Means and schedule Environmental and Social Head of the Planning, At the start of project implementation Officer’s Recruitment Budgeting, Monitoring and Evaluation Department of MLGRD Orientation of MPCUs within MLGRD/MMAs As part of GAMA and safeguards the MMAs orientation The recruitment of an ESO meets the need to provide the ESMP &RPF of GAMA coordination mechanisms more effective to ensure the inclusion of environmental and social aspects in the implementation of activities under the GAMA. This position will be for an environmental/civil engineer or a person with environment and natural resources management background and familiar with the environmental and social assessment procedures of Ghana and World Bank Safeguard policies. The ESO at MLGRD will be responsible for the implementation of the ESMP & RPF in close collaboration with the EPA and MMAs. The ESO will also will be responsible for the implementation of the environmental monitoring and the ESMP & RPF as illustrated in Figure 8.2 below. His/her responsibilities shall include:  Supervision of MMA compliance with ESMF  Coordination with MMAs PCUs (and where relevant, EMCs) liaison with and monitoring of the contractors;  Compilation and preparation of periodic environmental and social impacts reports from MMAs for submission to the World Bank;  Review of ESIA reports from consultants in collaboration with EPA and MLGRD;  Facilitating the disclosure of ESIAs and RAPs/ARAPs in-country and with the World Bank infoshop  Data Management; and  Sub-project inspections and monitoring on a sample basis. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 81 - WB/EPA - Review monitoring reports to ESO in GAMA of MLGRD ensure regulatory compliance MLGRD MMAs ESO in GAMA of MLGRD - Reorganized Env Mgt Committees in MMAs - Coordinate Project Team Figure 8-1: ESMP Implementation Arrangement MLGRD has the overall responsibility to ensure that the World Bank Safeguards Polices is complied with. In addition, MLGRD is responsible for the final review and clearance of the ESMPs (or ESIAs); as well as for the review and approval of TORs for the ESIA and EMPs in consultation with EPA. The MPCU will be overall responsible for monitoring of environmental and social safeguards compliance. 8.5 CAPACITY STRENGTHENING FOR ESMP IMPLEMENTATION In order for the MMAs to effectively carry out the environmental and social management responsibilities for sub- project implementation, institutional strengthening will be required. Capacity building will encompass MLGRD, and MMA staff.MLGRD should therefore ensure that the following concerns and needs are addressed:  Institutional structuring within the relevant departments to ensure that required professional and other technical staff are available; To successfully implement this ESMF, training programmes for MLGRD and MMAs is necessary. The World Bank, MLGRD and EPA can take up the responsibility for the training. Proposed capacity building training needs are as follows: - Environmental and Social Management Process. - Use of Screening form and Checklist - Preparation of terms of reference for carrying out EA - Design of appropriate mitigation measures. - Review and approval of EA reports - Public consultations in the ESMF/ESIA process. - Monitoring mitigation measures implementation. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 82 - - Integrating ESMP into sub-projects implementation. The proposed capacity building program will be carried out annually during the project. 8.5.1 Capacity Building Program and Awareness The effectiveness of environmental and social issues consideration in the implementation of activities goes particularly through training of MLGRD key actors on validation, monitoring, implementation of identified mitigation measures. The training activities target: MLGRD Staff working on the GAMA, MMA Environmental Management Committees, construction companies, operating agents. Training programmes will be determined and prepared the World Bank in collaboration with the Ministry and the EPA in environmental and social impact assessment . Topics will be centred around: (i) environmental and social issues of Sanitation and Water projects and environmental assessment procedures, (ii) hygiene and safety, requirements of national legislation, World Bank safeguards requirements, environmental monitoring of construction sites. The training aims to enhance their competence in environmental assessment, environmental control of work and environmental monitoring so they can play their roles more effectively in the implementation of subprojects. The training schedule is shown in the table 8.11 below. Table 8-12: Training Schedule Participants Duration Period - MLGRD Staff,, MPCUs, companies, 1st quarter First 3 days training workshop Project Year 8.5.2 Technical strengthen measures The technical measures include: - A provision for conducting any Environmental Impact Assessment (EIA) EIAs would be required for activities categorized as A or B to ensure they are sustainable environmentally and socially. If the environmental classification of activities indicates the need to conduct EIA and specific resettlement action plans where involuntary resettlement is triggeredthe MMAs will be required to fund these out of the GAMA project funding, - Inclusion of environmental and social guidelines in the Operational Manual A environmental and social procedure manual with social and environmental provisions will be included in the Operational Manual of the GAMA. - GAMA Monitoring and evaluation activities DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 83 - The monitoring program will focus on continuous monitoring, supervision, mid-term and annual evaluation. Support provided in the budget is needed for local monitoring to be conducted by ESO. 8.6 ESMF IMPLEMENTATION SCHEDULE Timetable for implementation and monitoring of GAMA environmental activities will be as presented in table 8.12. Table 8-13: Time Table for Implementation and Monitoring of Environmental Activities Implementation period in the project Measures Proposed actions cycle Mitigation View list of mitigation measures During subprojects implementation measures Institutional ESO’s Recruitment Before subprojects implementation measures Development of EIA for certain projects and After screening of specific activities at RAPs for projects that may cause displacement a site Technical measures Development health and safety plan (construction After signing the contract by company companies) Training of ESMF implementing actors in environmental 1st quarter First project year Training and social assessment Close monitoring During the implementation of the Project Environmental Monitoring GAMA Follow-up Action Supervision Every month At mid-term ESMP Evaluation End of GAMA 8.7 ESTIMATED BUDGET The budget needed for ESMP / GAMA environmental and social management is the recapitulation of the following: - Institutional development activities - Training program, awareness - Allowances for the preparation / implementation of sub-projects EIA / EMP/RAPs. (The costs of implementing such plans measures are included in the budgets of sub-projects.) - Annual assessments. The costs of environmental measures as well as training and awareness are summarized in tables 8.13, 8.14 and 8.15 below. Under the GAMA Category A and B project will require the preparation of of EIAs. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 84 - Table 8-14: Estimated Costs of Technical Measures Unit cost Total cost Activity Quantity ($US) ($US) To be To be To be EIA / RAP development at MMA level and to be integrated determined determined determined into projects budget later at later at later at MMA MMA MMA Normal Normal Supervision and permanent monitoring at MMAs level by Quarterly MMA MMA MPCUs, Planning officers Budget Budget Table 8-15: Training and Awareness Measures Costs Unit cost Total cost Actors involved Topics Quantity ($US) ($US) Training MMAs - Training on Environmental and Social (Training of Assessment (screening and members of classification of activities, MMPCU at identification of impacts, mitigation MMA level, options and indicators) - Involuntary Resettlement Issues 2 including - Drafting ToR for EIA workshops planning officer, - Selection of mitigation measures in the per year and other checklists Y1-Y5 of 7,000 70,000 designated - Legislation and national environmental the project officers procedures covering all (This training - Safeguard Policy World Bank 11 MMAs will be done by - Impact of sub-projects and mitigation the World Bank measures in collaboration - Environmental measures monitoring with MLGRD - health and safety standards monitoring and EPA) Safety and hygiene at work and operation Awareness - Public awareness and advocacy on - Commuities projects environmental and social - Local issues, good environmental practices, Normal Normal associations good conduct in the yards, respect for and NGOs 2 MMA MMA hygiene and safety, compliance with - Reps of Budget Budget development standards construction - Awareness Campaign HIV / AIDS companies 70,000 TOTAL DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 85 - Table 8-16: Summarized Estimated Budget for Environmental and Social Impact Management Measures Actions Responsible Costs USD Recruitment of ESO at MLGRD Level Institutional MLGRD measures Covered by normal MMA Perform ESMP monitoring and evaluation (continuous Budgets monitoring, mid-term and annual assessment) Technical EIAs / RAP development MMA Covered by measures Health and safety Plans development MLGRD ESO Supervision and Monitoring Monitoring and Evaluation Budget MLGRD Training of MMA staff in projects environmental and social Covered under Training management and monitoring and enforcement of training above environmental measures MMA - Information and awareness campaigns on the nature of Normal MMA Awareness work, environmental and social issues Budget - Awareness on HIV / AIDS TOTAL 8.8 ESMF/ ESMP DISSEMINATION AND PUBLIC DISCLOSURE Under the approach advocated by the World Bank, environmental assessments are not only an expert analysis, but part of a participatory process involving all stakeholders in the project. The various stakeholders must be :(i) viewed as sources of information and points of view and different interests; (ii) systematically informed of the findings and progress of the project (through a communication plan), and iii) loans at any time to make their voices heard by decision makers. To do this, an information system and public communication must be established early of subproject assessment. The system also includes a provision of formal public reports, once the assessments are completed. The OP 4.01 outlines the requirements for consultation and dissemination of environmental assessments in accordance with the policy of dissemination of the World Bank (BP 17.50). The ESMF document has been disclosed in-country by advertising it in two newspapers and stating the locations where the copies could be found for review for 21 working days and at the World Bank Infoshop for 60 days according to the Public Disclosure Policy (OP 17.50). The ESIA of sub-projects will also be disclosed in country and at the Infoshop. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 86 - Table 8-17: Environmental and Social Management Plan Responsibility Cost Mitigation Implementation Monitoring Frequenc Estim Potential Impact Monitoring Supervisio Measures Schedule Indicators Implementation y ate n (US$) Soil Erosion MMPCUs $ Possible increase in Re-vegetate the During and after Monitor erosion Contractor/super Weekly soil erosion as a construction site by the construction occurrence within vising consultant result of the planting rapidly activities and around the construction growing construction site activities (clearing vegetation/plants of vegetation and soil excavation) During Soil Ensure that all the Use excavated soil construction excavated soil are Loss of productive for construction work used for topsoil resulting construction from soil Ensure immediate excavation clean up of the area During Monitor and by removing the construction document the Soil contamination contaminated topsoil contaminated soil resulting from the and disposing disposal release of chemicals properly in a procedure (lubricant, fuel, designated place paint) from the equipments Water Works $ Run-off erosion Attend to any Monitor BOD, Contractor/super Weekly During Sediments Department may occur from excavation area as Nitrate, pH, vising consultant excavation of unprotected quick as possible or Heavy metals of activities MMPCUs excavated areas create an the nearby water during heavy rain embankment to avoid bodies before the resulting to run off construction and sedimentation of thereafter weekly nearby water- during the FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 87 - Responsibility Cost Mitigation Implementation Monitoring Frequenc Estim Potential Impact Monitoring Supervisio Measures Schedule Indicators Implementation y ate n (US$) bodies Create barrier for Sediments construction appropriate During activities Run-off erosion containment construction may occur from measures heaps of excavated soils during heavy rain resulting to sedimentation of Proper disposal of Heavy metals nearby water- bodies construction waste During Potential water construction pollution through run off of hazardous construction waste (lubricants, paint) Air MMPCUs Particulate matters Spray water During PM Monitor PM, Contractor/super Weekly $ emission from periodically to excavation and NOx, SOx, THC vising consultant excavation and control dust construction and CO in the construction activities surrounding air activities before the NOx, SOx, construction and Potential emission Limit the vehicles During THC and CO thereafter hourly of pollutants from allowed into the site construction during the the construction and use efficient activities construction machineries (NOx, machineries SOx, CO, THC) FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 88 - Responsibility Cost Mitigation Implementation Monitoring Frequenc Estim Potential Impact Monitoring Supervisio Measures Schedule Indicators Implementation y ate n (US$) Noise Noise resulting Equipment (e.g. During Noise Contractor/super MMPCUs Daily $ from the cement-sand mixer construction vising consultant construction works machine) to be placed activities as far as possible from the sensitive area/ human Monitor staff settlement compliance to the use of ear Construction should muffs/plugs not be done during peak work hours Construction staff to wear ear muffs Ecosystem Destruction of During and after Vegetation Monitor the re- Contractor/super Works Monthly $ Re-vegetate the vegetation, loss of construction vegetation process vising consultant Department construction site by habitat and of planting rapidly biodiversity MMPCUs growing vegetation/plants Possible loss of endangered and rare specie Change in land use and disturbance of ecosystem FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 89 - Responsibility Cost Mitigation Implementation Monitoring Frequenc Estim Potential Impact Monitoring Supervisio Measures Schedule Indicators Implementation y ate n (US$) Social Provide alternative MMPCUs Possible loss of route for access to access to assets or Before Complaints Document Contractor/super resource. resource. construction from the relocation vising consultant begins affected procedures people Monitor the road traffic before and during construction activities Soil Contamination of Pre-treat waste before Before disposal pH, Monitor the Monthly $350 soil as a result of disposal (through BOD,COD, surrounding soil Contractor/super waste (reagent, neutralization, Nitrate etc pH, BOD,COD, vising consultant solid waste) thermal pretreatment, (based on the Nitrate etc (based disposal oxidation, etc) type of on the type of chemical chemical waste waste generated). generated) Monitoring to be before construction and monthly during the construction Water Depletion of water Reuse and recycle During operation Increase in Monitoring the Monthly $300 resources water, also minimize water utility water flow meter water usage payment. Contamination of Install water flow Before waste Increase in Monitor the surrounding water meter water disposal water flow surrounding water bodies through meter reading bodies pH, FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 90 - Responsibility Cost Mitigation Implementation Monitoring Frequenc Estim Potential Impact Monitoring Supervisio Measures Schedule Indicators Implementation y ate n (US$) improper disposal During site BOD,COD, of waste water Pre-treat waste water selection pH, Nitrate etc (based before disposal BOD,COD, on the type of Possible run off (through Nitrate etc chemical waste from the temporary neutralization, (based on the generated). solid waste storage thermal pretreatment, type of Monitoring to be site into the oxidation, etc) Implement chemical before drainage system mitigation waste construction and Avoid siting measures through generated) monthly during temporary solid waste the operation the construction storage close to phase drainage system or water ways. Dispose waste as soon as possible to avoid leachate generation Ensure proper containment of the temporary waste storage site FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 91 - 9.0 REFERENCES  Ghana Shared Growth and Development Agenda(GSGDA) (2010-2013)  Ghana Poverty Reduction Strategy Paper (GPRS I & II)  Project Appraisal Document (PAD) for GAMA  Republic of Ghana (2003): Labour Act, 2003 (Act 651)  Republic of Ghana (1994): Environmental Protection Agency Act, 1994 (Act 490)  Republic of Ghana (1999): Environmental Assessment Regulations 1999 (LI 1652)  Republic of Ghana (2002): Environmental Assessment (Amendment) Regulations, 2002 (LI 1703)  Environmental and Social Analysis for the Second Urban Environmental Sanitation Project (UESP II), Ghana, 2003  Handbook for Preparing a Resettlement Action Plan, International Finance Corporation  Ghana: GAMA Preparation Mission, Aide Memoire  State Land Act 1963 FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 92 - 10.0 ANNEXES ANNEX 1A: ENVIRONMENTAL AND SOCIAL SCREENING (ESS) OF SUB-PROJECTS This stage marks the beginning of the ESIA or ESMP process, which should be initiated as early as possible along with the sub-project planning process after the sub-project is conceived. During this stage, the important functions that need to be performed are: i. Establish the likely study area by identifying broad boundaries for the sub-project; ii. Make a preliminary assessment of the significance of potential environmental impacts, and likely mitigating measures; iii. Identify possible alternatives and the major potential environmental impacts associated with each, as well as the likely corresponding mitigation measures; iv. Estimate the extent and scope of ESIA to be performed, and offer an initial recommendation as to whether a full ESIA is required; v. Estimate the time frame of the ESIA study; vi. Identify the expertise and human resources needed for the ESIA study; and vii. Prepare the terms of reference for the conduct of an initial environmental examination. The value of conducting environmental and social screening at the early conception and planning phase of a development project is to provide useful technical input to the project team for their planning and budgeting, thereby eliminating the possibility of costly remedial environmental work and delays caused by problems with adverse environmental damage. Such early input on environmental considerations also provides useful information that helps the project team to gain government approval and win public acceptance. The environmental and social screening process considers the following aspects in the recommendation: project type, environmental and social setting, and magnitude and significance of potential environmental and social impacts. Some of the typical questions asked in the environmental and social screening process are outlined in the figure in the next page below. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 93 - Figure 10.1: Typical Environmental Screening Procedure FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 94 - ANNEX 1B: STANDARD FORMAT FOR SCREENING REPORT 1.0 Description of Sub-Project 1.1 Nature of Sub-Project and Duration …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… ………………………………………………………………………… 1.2 Scope of Sub-Project [Size of labour force, area covered or length &width of road, type of raw materials (quantities and sources), types of equipment, implements, machinery, etc. ] …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… ……………………………………………………………… ………………………………………………………………………………………………………… 1.3 Waste Generation i. Types: Solid □ Liquid □ Gaseous □ Other ……………………………….. ii. Quantity: ………………………………………………………………………………….. iii. Means/Place of Disposal: …………………………………………………………………. 2.0 Proposed Site for Sub-Project 2.1 Location [attach a site plan or a map (if available)] i. Location or Area (and nearest Town(s)): …..……………………….…………………… ii. Land take (total area for sub-project and related activities): ………………………………… 2.2 Land Use of the Area for the Sub-Project: Agriculture □ Residential □ Existing Dugout □ Existing Road □ Reservation □ Park/Recreation □ Industrial □ Other (specify) □ 2.3 Site Description [Attach photographs and sketches showing distances] i. Distance from nearest water body or drainage channel (minimum distance measured from the edge of proposed site to the bank of the water body or drain). More than 100 meters □ 100 meters □ Less than 100 meters □ ii. Number of water bodies and/or drainage channels/depressions crossed by the route/road corridor: …………………………………………………………………………………………….. iii. Distance to nearest community (house) and/or other existing structures from the proposed site: ………………………………………………………………………………………………… iv. Number of communities (structures) along the entire stretch of the Sub-project road: …………………………………………………………………….…………………………… 2.4 Land Cover and Topography i. Land cover of the site consists (completely or partly or noticeably) of: Vegetation □ Sparse Vegetation □ Physical Structure(s) □ Flood Plane □ Agriculture (Animals) □ Cultural Resource □ Water □ Agriculture (Crops) □ Other specify……… FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 95 - ii. Elevation and topography of the area for the Sub-Project: Flat □ Valley □ Slope □ Undulating □ Hill □ Mountain □ Depression □ iii. Elevation and topography of the adjoining areas (within 500 meters radius of the site): Flat □ Valley □ Slope □ Undulating □ Hill □ Mountain □ Depression □ 3.0 Infrastructure i. The Sub-project would be developed in/on: Undeveloped site □ Partly developed site □ Existing route □ Other (specify) ……………………… ii. The Sub-project would involve excavation Yes □ No □ iii. Estimated number and depth of the excavations, etc): ……………………………………………… vi. Are any of the following located on-site or within 50 metres from the edge of the proposed site? Water supply source Yes □ No □ Pipeline Yes □ No □ Power supply source (electric pylon) Yes □ No □ Drainage Yes □ No □ Other(s) specify: ……………………………………………. 4.0 Environmental and Social Impacts 4.1 Air Quality - Would the proposed Sub-project: i. Emit during construction Dust □ Smoke □ VOCs □ ii Expose workers or the public to substantial emissions? Yes □ No □ iii. Result in cumulatively increased emissions in the area? Yes □ No □ vi. Create objectionable odour affecting people? Yes □ No □ 4.2 Biological Resources - Would the proposed Sub-project: i. Have adverse effect on any reserved area? Yes □ No □ ii. Have adverse effect on wetland areas through removal, filling, hydrological Yes □ No □ interruption or other means? iii. Interfere substantially with the movement of any wildlife species or organisms? Yes □ No □ vi. Be located within 100m from an Environmentally Sensitive Area? Yes □ No □ 4.3 Cultural Resources - Would the proposed Sub-project: i. Disturb any burial grounds or cemeteries? Yes □ No □ ii. Cause substantial adverse effect on any archeological or historic site? Yes □ No □ iii. Alter the existing visual character of the area and surroundings, including trees and rock Yes □ No □ outcrops? 4.4 Water Quality and Hydrology - Would the proposed Sub-project: i. Generate and discharge during construction: Liquid waste □ Liquid with oily substance □ Liquid with human or animal waste □ Liquid with chemical substance □ Liquid with pH outside 6-9 range □ Liquid with odour/smell □ ii. Lead to changes in the drainage pattern of the area, resulting in erosion or siltation? Yes □ No □ iii. Lead to increase in surface run-off, which could result in flooding on or off-site? Yes □ No □ FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 96 - iv. Increase runoff, which could exceed the capacity of existing storm water drainage? Yes □ No □ 4.5 Noise Nuisance - Would the proposed Undertaking: i. Generate noise in excess of established permissible noise level? Yes □ No □ ii. Expose persons to excessive vibration and noise? Yes □ No □ 4.6 Other Environmental and Social Impacts ………………………………………………………………………………………………………………………… ………………………………………………………………………….……………………………………………… ………………………………………………….………………….…………………… 5.0 Management of (Environmental and Social) Impacts 5.1 Air Quality …………………………………………………………………………………………………..……………………… …………………………………………………………………………..……………………………………………… …………………………………………………………………………………………. 5.2 Biological Resources …………………………………………………………………………………………………..……………………… ………………………………………………………………………….……………………………………………… ……………………………………………………………………………………….. 5.3 Cultural Resources …………………………………………………………………………………………………..……………………… …………………………………………………………………………..……………………………………………… …………………………………………………………………………………………. 5.4 Water Quality and Hydrology …………………………………………………………………………………………………..……………………… …………………………………………………………………………..……………………………………………… ………………………………………………………………………………………… 5.5 Noise …………………………………………………………………………………………………..…………… ……………………………………………………………………………………..…………………………………… ………………………………………………………………………………………………….. 5.6 Any Other …………………………………………………………………………………………………..……………………… ………………………………………………………………………..………………………………………………… …………………………………………………………………………………………. ATTACHMENTS 1.1. Maps 1.2. Photos 1.3. Location and Administrative Maps 1.4. Environmental and Social Checklist FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 97 - ANNEX 1C: SCREENING REPORT-ENVIRONMENTAL AND SOCIAL CHECKLIST Table 10-1: Environmental and Social Checklist MMA: District: Date: GAMA Facility Name: Location: Issue Degree* Comment Land Resources Worksite/Campsite Areas Excavation Areas Disposal Areas Others Water Resources & Hydrology Sources of Water for Construction Drainage Issues Others Biological Resources Special Trees/Vegetation around Protected Areas directly affected Others Air Quality & Noise Special issues (e.g. quiet zone for working) Residential Areas Socio-Economic & Cultural Involuntary Resettlement** Graveyards and Sacred Areas affected Cultural Resources Population affected/provided access Others *Degree: N = Negligible or Not Applicable L = Low M = Moderate H = High **If yes, indicate # of persons likely to be affected and nature of the effect FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 98 - ANNEX 2: STANDARD FORMAT FOR ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) EXECUTIVE SUMMARY 1. PROJECT DESCRIPTION 1.1. Overview of the MMA where the GAMA Facility is located 1.2. List of GAMA Facilities 1.3. Environmental Screening Category 2. POLICY AND ADMINISTRATIVE AND LEGAL FRAMEWORK 3. MMAs -SPECIFIC ESMPs 3.1. Location 3.2. Proposed Works 3.3. Estimated Cost 3.4. Baseline Data 3.4.1. Land Resources 3.4.2. Hydrology and Water Resources 3.4.3. Air and Noise 3.4.4. Biological Resources 3.4.5. Socio-Economic and Cultural 3.5. Potential Impacts 3.5.1. Land Resources 3.5.1.1. Construction Phase 3.5.1.2. Post Construction Phase 3.5.2. Hydrology and Water Resources 3.5.2.1. Construction Phase 3.5.2.2. Post Construction Phase 3.5.3. Air Quality and Noise 3.5.3.1. Construction Phase 3.5.3.2. Post Construction Phase 3.5.4. Biological Resources 3.5.4.1. Construction Phase 3.5.4.2. Post Construction Phase 3.5.5. Socio-Economic and Cultural 3.5.5.1. Construction Phase 3.5.5.2. Post Construction Phase 3.6. Analysis of Alternatives 3.7. Mitigation Measures 3.7.1. Construction Phase 3.7.2. Post Construction Phase 3.8. Monitoring and Supervision Arrangements 3.9. Summary ESMP Table 4. ATTACHMENTS 4.1. Photos 4.2. Summary of Consultations and Disclosure 4.3. Other FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 99 - ANNEX 3: GUIDANCE ON ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN BY PROJECT PHASES Table 10-2: Guidance on ESMP by Project Phases Phases Issue/Potential Impact Mitigation Measure(s) Implementing Monitoring Cost Responsibility Responsibility Design Phase Impacts on physical Consider the impact of the construction activities on Design Consultant MPCU To be environment: air quality, the physical environment for the design of civil works determined hydrology, waste, soils, noise Impact on Air Quality: Bid document will include requirement to ensure: Design Consultant MPCU To be Emission of dust and other - Adequate watering for dust control determined pollutants - Prohibition of open burning - Ensure stockpile of materials are properly secured - Proper unloading/storage of construction materials - On-site mixing of materials in shielded area - Equipment and materials to be properly covered during transportation. Noise impact Bid document to include requirement to ensure: Design Consultant ESO/MPCU To be - Noise silencers be installed on all exhaust determined system - Use of ear plugs for construction workers - Equipment placed as far as possible from sensitive land users. Impact on hydrology: The contract document should specify: Design Consultant ESO/MPCU To be Degradation of surface water - use of good engineering practice during determined quality construction, including adequate supervision - Minimal water usage in construction area - Minimal soil exposure time during construction - Minimal chemical usage (lubricants, solvents, petroleum products. Alteration of surface drainage Contract document to include requirement to ensure: Design Consultant ESO/MPCU To be - installation of adequately sized drainage determined channels - stabilization of slopes to avoid erosion Waste generation and disposal Contract document to include requirement to ensure: Design Consultant ESO/MPCU To be (solid/ oily/hazardous) - Provision of waste management plan. determined - Proper handling and disposal /recycling of oily FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 100 - waste Impact on Soil: Contract document to include requirement to ensure: Design Consultant ESO/MPCU To be Increased soil erosion - Use of less erodable materials, determined - Lined down-drains to prevent erosion Socioeconomic Impact: - Avoid the creation of congested and unsafe road Design Consultant ESO/MPCU To be Disruption during work- demand conditions at intersections and in villages or determined for local Sanitation and Water cities. services increase Disruption to traditional - Ensures access to homes, businesses, other key Design Consultant ESO/MPCU To be lifestyles and other services services determined Construction Impact on Air Quality: - Periodically use water to spray areas under Contractor, ESO/MPCU To be Emission of dust and other construction Supervising determined pollutants - Construction workers to wear face masks and consultant gloves - Ensure that all equipment and materials loaded on trucks are covered during transportation Noise Impact - Noise standards to be enforced to protect Contractor, ESO/MPCU To be construction workers Supervising determined - Ensure that silencers are installed on all exhaust consultant systems. - Ear plugs to be worn by construction workers - Turn off construction equipment when not in use Impact on hydrology: - Use good engineering practice during Contractor, ESO/MPCU To be Degradation of surface water construction Supervising determined quality - Ensure wastewater from cleaning of equipment consultant is not disposed of in water course. - Wastewater should be collected and treated suitably before being disposed of in water courses. - Ensure minimal use of water in construction area - Minimal soil exposure time during construction Alteration of surface drainage - Install adequately sized drainage channels Contractor, ESO/MPCU To be - Ensure stabilization of slopes to avoid erosion Supervising determined consultant FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 101 - Solid waste generation and - Ensure all waste earth and materials associated Contractor, ESO/MPCU To be disposal with construction activities are disposed land Supervising determined without prior consent of PPT. consultant - Daily life rubbish and waste materials associated with construction activities should be daily collected and disposed of in suitable approved dumpsites. - Ensure that solid wastes are not disposed of in water courses. Poor Sanitation at construction - Provide adequately located and maintained Contractor ESO/PPT camp and site latrines Accidental spill of toxic - Design and implement safety measures Contractor ESO/PPT material/oil - Provide an emergency plan to contain accidental spill Impact on Soil: - Avoid erosion of cuts and fills by providing Contractor, ESO/MPCU Increased soil erosion proper drainage, Supervising - Lined down-drains to prevent erosion Consultant Impact on vegetation - Replanting of land within project area. Contractor, ESO/MPCU Supervising Consultant Health and Safety Impact - Enure adequate health facility systems are in Contractor, ESO/MPCU place on-site to deal with influx of temporary Supervising workers. Consultant - Ensure use of nets, insect repellent and other malaria preventive measure for workers on site. - Health education about STDs should be introduced. - Training of construction crew and supervisors on health and safety guidelines - Personal protective equipment to be worn by all workers Socioeconomic Impact: - Avoid or reduce loss of property Contractor Supervising To be Loss of property - Avoid land where farmers will be displaced. Consultant/ESO determined FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 102 - ANNEX 4: DRAFT TERMS OF REFERENCE FOR SUB-PROJECT REQUIRING AN ESIA Based on the screening and scoping results. ESIA terms of reference will be prepared. A local consultant will conduct the ESIA and the report should have the following format: Introduction and Context This part will be completed at a time and will include necessary information related to the context and methodology to carry out the study. Objectives of the Study This section will indicate (i) the objectives and the project activities; (ii) the activities that may cause environmental and social negative impacts and needing adequate mitigation measures. Mission/Tasks The Consultant should realize the following:  Describe the biophysical characteristics of the environment where the project activities will be realized; and underline the main constraints that need to be taken into account at the field preparation, during the implementation and exploitation/maintenance of equipments.  Assess the potential environmental and social impacts related to project activities and recommend adequate mitigation measures, including costs estimates;  Assess the need of solid and liquid waste management and suggest recommendation for their safe disposal;  Review political, legal and institutional framework, at national and international level, related to environmental, identity constraints and suggest recommendations for reinforcement;  Identify responsibilities and actors for the implementation of proposed mitigation measures;  Access the capacity available to implement the proposed mitigation measures, and suggest recommendation in terms of training and capacity building, and estimate their costs;  Develop an Environmental Management Plan (EMP) for the project. The EMP should underline (i) the potential environmental and social impacts resulting from project activities; (ii) The proposed mitigation measures; (iii) the institutional responsibilities for implementation; (iv) the monitoring indicators; (v) the institutional responsibilities for monitoring and implementation of mitigation measures; (vi) the costs of activities; and (vii) the schedule of implementation. Public consultations The ESIA results and the proposed mitigation measures will be discussed with population, NGOs, local administration and other organizations mainly involved by the project activities. Recommendations from this public consultation will be included in the final ESIA report. Plan of the ESIA Report  Cover page  Table of Contents  List of Acronyms  Executive Summary  Introduction  Description of project activities  Description of Environment in the project area FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 103 -  Description of policy, legal and Institutional Framework  Description of the methodology and techniques used in assessment and analysis of the project impacts  Description of environmental and social impacts for project activities  Environmental Management Plan (EMP) for the project including the proposed mitigation measures; institutional responsibilities for monitoring and implementation; Summarized table for EMP.  Recommendations  References  List of Persons/Institutions met Qualification of the Consultant The Consultant will be agreed upon by the EPA in carrying out the ESIA studies Duration of Study The Duration of study will be determined according to the type of activity Production of final Report The Consultant will produce the final report one (1) week after receiving comments from EPA and GAMA Secretariat. The final report will include comments from these institutions. Supervision of Study The consultancy will be supervised by the Environmental and Social Management Specialist (ESMS) of the GAMA Secretariat.  Description of the study area  Description of the sub-project  Legislative and regulatory considerations  Determination of the potential impacts of the proposed sub-projects  Environmental Management Plan  Public consultations process  Development of mitigation measures and a monitoring plan, including cost estimates. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 104 - ANNEX 5: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS General 1. In addition to these general conditions, the Contractor shall comply with any specific Environmental Management Plan (EMP) or Environmental and Social Management Plan (ESMP) for the works he is responsible for. The Contractor shall inform himself about such an EMP, and prepare his work strategy and plan to fully take into account relevant provisions of that EMP. If the Contractor fails to implement the approved EMP after written instruction by the Supervising Engineer (SE) to fulfill his obligation within the requested time, the Owner reserves the right to arrange through the SE for execution of the missing action by a third party on account of the Contractor. 2. Notwithstanding the Contractor’s obligation under the above clause, the Contractor shall implement all measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore work sites to acceptable standards, and abide by any environmental performance requirements specified in an EMP. In general these measures shall include but not be limited to: (a) Minimize the effect of dust on the surrounding environment resulting from earth mixing sites, vibrating equipment, temporary access roads, etc. to ensure safety, health and the protection of workers and communities living in the vicinity dust producing activities. (b) Ensure that noise levels emanating from machinery, vehicles and noisy construction activities (e.g. excavation, blasting) are kept at a minimum for the safety, health and protection of workers within the vicinity of high noise levels and nearby communities. (c) Ensure that existing water flow regimes in rivers, streams and other natural or irrigation channels is maintained and/or re-established where they are disrupted due to works being carried out. (d) Prevent oils, lubricants and waste water used or produced during the execution of works from entering into rivers, streams, irrigation channels and other natural water bodies/reservoirs, and also ensure that stagnant water in uncovered borrow pits is treated in the best way to avoid creating possible breeding grounds for mosquitoes. (e) Prevent and minimize the impacts of quarrying, earth borrowing, piling and building of temporary construction camps and access roads on the biophysical environment including protected areas and arable lands; local communities and their settlements. In as much as possible restore/rehabilitate all sites to acceptable standards. (f) Upon discovery of ancient heritage, relics or anything that might or believed to be of archeological or historical importance during the execution of works, immediately report such findings to the SE so that the appropriate authorities may be expeditiously contacted for fulfillment of the measures aimed at protecting such historical or archaeological resources. (g) Discourage construction workers from engaging in the exploitation of natural resources such as hunting, fishing, and collection of forest products or any other activity that might have a negative impact on the social and economic welfare of the local communities. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 105 - (h) Implement soil erosion control measures in order to avoid surface run off and prevents siltation, etc. (i) Ensure that garbage, sanitation and drinking water facilities are provided in construction workers camps. (j) Ensure that, in as much as possible, local materials are used to avoid importation of foreign material and long distance transportation. (k) Ensure public safety, and meet traffic safety requirements for the operation of work to avoid accidents. 3. The Contractor shall indicate the period within which he/she shall maintain status on site after completion of civil works to ensure that significant adverse impacts arising from such works have been appropriately addressed. 4. The Contractor shall adhere to the proposed activity implementation schedule and the monitoring plan / strategy to ensure effective feedback of monitoring information to project management so that impact management can be implemented properly, and if necessary, adapt to changing and unforeseen conditions. 5. Besides the regular inspection of the sites by the SE for adherence to the contract conditions and specifications, the Owner may appoint an Inspector to oversee the compliance with these environmental conditions and any proposed mitigation measures. State environmental authorities may carry out similar inspection duties. In all cases, as directed by the SE, the Contractor shall comply with directives from such inspectors to implement measures required to ensure the adequacy rehabilitation measures carried out on the bio-physical environment and compensation for socio-economic disruption resulting from implementation of any works. Worksite/Campsite Waste Management 6. All vessels (drums, containers, bags, etc.) containing oil/fuel/construction materials and other hazardous chemicals shall be bunded in order to contain spillage. All waste containers, litter and any other waste generated during the construction shall be collected and disposed off at designated disposal sites in line with applicable government waste management regulations. 7. All drainage and effluent from storage areas, workshops and camp sites shall be captured and treated before being discharged into the drainage system in line with applicable government water pollution control regulations. 8. Used oil from maintenance shall be collected and disposed off appropriately at designated sites or be re-used or sold for re-use locally. 9. Entry of runoff to the site shall be restricted by constructing diversion channels or holding structures such as banks, drains, dams, etc. to reduce the potential of soil erosion and water pollution. 10. Construction waste shall not be left in stockpiles along the road, but removed and reused or disposed of on a daily basis. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 106 - 11. If disposal sites for clean spoil are necessary, they shall be located in areas, approved by the SE, of low land use value and where they will not result in material being easily washed into drainage channels. Whenever possible, spoil materials should be placed in low-lying areas and should be compacted and planted with species indigenous to the locality. Material Excavation and Deposit 12. The Contractor shall obtain appropriate licenses/permits from relevant authorities to operate quarries or borrow areas. 13. The location of quarries and borrow areas shall be subject to approval by relevant local and national authorities, including traditional authorities if the land on which the quarry or borrow areas fall in traditional land. 14. New extraction sites: a) Shall not be located in the vicinity of settlement areas, cultural sites, wetlands or any other valued ecosystem component, or on high or steep ground or in areas of high scenic value, and shall not be located less than 1km from such areas. b) Shall not be located adjacent to stream channels wherever possible to avoid siltation of river channels. Where they are located near water sources, borrow pits and perimeter drains shall surround quarry sites. c) Shall not be located in archaeological areas. Excavations in the vicinity of such areas shall proceed with great care and shall be done in the presence of government authorities having a mandate for their protection. d) Shall not be located in forest reserves. However, where there are no other alternatives, permission shall be obtained from the appropriate authorities and an environmental impact study shall be conducted. e) Shall be easily rehabilitated. Areas with minimal vegetation cover such as flat and bare ground, or areas covered with grass only or covered with shrubs less than 1.5m in height, are preferred. f) Shall have clearly demarcated and marked boundaries to minimize vegetation clearing. 15. Vegetation clearing shall be restricted to the area required for safe operation of construction work. Vegetation clearing shall not be done more than two months in advance of operations. 16. Stockpile areas shall be located in areas where trees can act as buffers to prevent dust pollution. Perimeter drains shall be built around stockpile areas. Sediment and other pollutant traps shall be located at drainage exits from workings. 17. The Contractor shall deposit any excess material in accordance with the principles of these general conditions, and any applicable EMP, in areas approved by local authorities and/or the SE. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 107 - 18. Areas for depositing hazardous materials such as contaminated liquid and solid materials shall be approved by the SE and appropriate local and/or national authorities before the commencement of work. Use of existing, approved sites shall be preferred over the establishment of new sites. Rehabilitation and Soil Erosion Prevention 19. To the extent practicable, the Contractor shall rehabilitate the site progressively so that the rate of rehabilitation is similar to the rate of construction. 20. Always remove and retain topsoil for subsequent rehabilitation. Soils shall not be stripped when they are wet as this can lead to soil compaction and loss of structure. 21. Topsoil shall not be stored in large heaps. Low mounds of no more than 1 to 2m high are recommended. 22. Re-vegetate stockpiles to protect the soil from erosion, discourage weeds and maintain an active population of beneficial soil microbes. 23. Locate stockpiles where they will not be disturbed by future construction activities. 24. To the extent practicable, reinstate natural drainage patterns where they have been altered or impaired. 25. Remove toxic materials and dispose of them in designated sites. Backfill excavated areas with soils or overburden that is free of foreign material that could pollute groundwater and soil. 26. Identify potentially toxic overburden and screen with suitable material to prevent mobilization of toxins. 27. Ensure reshaped land is formed so as to be inherently stable, adequately drained and suitable for the desired long-term land use, and allow natural regeneration of vegetation. 28. Minimize the long-term visual impact by creating landforms that are compatible with the adjacent landscape. 29. Minimize erosion by wind and water both during and after the process of reinstatement. 30. Compacted surfaces shall be deep ripped to relieve compaction unless subsurface conditions dictate otherwise. 31. Revegetate with plant species that will control erosion, provide vegetative diversity and, through succession, contribute to a resilient ecosystem. The choice of plant species for rehabilitation shall be done in consultation with local research institutions, forest department and the local people. Water Resources Management 32. The Contractor shall at all costs avoid conflicting with water demands of local communities. 33. Abstraction of both surface and underground water shall only be done with the consultation of the local community and after obtaining a permit from the relevant Water Authority. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 108 - 34. Abstraction of water from wetlands shall be avoided. Where necessary, authority has to be obtained from relevant authorities. 35. Temporary damming of streams and rivers shall be done in such a way avoids disrupting water supplies to communities down stream, and maintains the ecological balance of the river system. 36. No construction water containing spoils or site effluent, especially cement and oil, shall be allowed to flow into natural water drainage courses. 37. Wash water from washing out of equipment shall not be discharged into water courses or road drains. 38. Site spoils and temporary stockpiles shall be located away from the drainage system, and surface run off shall be directed away from stockpiles to prevent erosion. Traffic Management 39. Location of access roads/detours shall be done in consultation with the local community especially in important or sensitive environments. Access roads shall not traverse wetland areas. 40. Upon the completion of civil works, all access roads shall be ripped and rehabilitated. 41. Access roads shall be sprinkled with water at least five times a day in settled areas, and three times in unsettled areas, to suppress dust emissions. Blasting 42. Blasting activities shall not take place less than 2km from settlement areas, cultural sites, or wetlands without the permission of the SE. 43. Blasting activities shall be done during working hours, and local communities shall be consulted on the proposed blasting times. 44. Noise levels reaching the communities from blasting activities shall not exceed 90 decibels. Disposal of Unusable Elements 45. Unusable materials and construction elements such as electro-mechanical equipment, pipes, accessories and demolished structures will be disposed of in a manner approved by the SE. The Contractor has to agree with the SE which elements are to be surrendered to the Client’s premises, which will be recycled or reused, and which will be disposed of at approved landfill sites. 46. As far as possible, abandoned pipelines shall remain in place. Where for any reason no alternative alignment for the new pipeline is possible, the old pipes shall be safely removed and stored at a safe place to be agreed upon with the SE and the local authorities concerned. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 109 - 47. AC-pipes as well as broken parts thereof have to be treated as hazardous material and disposed of as specified above. 48. Unsuitable and demolished elements shall be dismantled to a size fitting on ordinary trucks for transport. Health and Safety 49. In advance of the construction work, the Contractor shall mount an awareness and hygiene campaign. Workers and local residents shall be sensitized on health risks particularly of AIDS. 50. Adequate road signs to warn pedestrians and motorists of construction activities, diversions, etc. shall be provided at appropriate points. 51. Construction vehicles shall not exceed maximum speed limit of 40km per hour. Repair of Private Property 52. Should the Contractor, deliberately or accidentally, damage private property, he shall repair the property to the owner’s satisfaction and at his own cost. For each repair, the Contractor shall obtain from the owner a certificate that the damage has been made good satisfactorily in order to indemnify the Client from subsequent claims. 53. In cases where compensation for inconveniences, damage of assets etc. are claimed by the owner, the Client has to be informed by the Contractor through the SE. This compensation is in general settled under the responsibility of the Client before signing the Contract. In unforeseeable cases, the respective administrative entities of the Client will take care of compensation. Contractor’s Health, Safety and Environment Management Plan (HSE-MP) 54. Within 6 weeks of signing the Contract, the Contractor shall prepare an EHS-MP to ensure the adequate management of the health, safety, environmental and social aspects of the works, including implementation of the requirements of these general conditions and any specific requirements of an EMP for the works. The Contractor’s EHS-MP will serve two main purposes:  For the Contractor, for internal purposes, to ensure that all measures are in place for adequate HSE management, and as an operational manual for his staff.  For the Client, supported where necessary by a SE, to ensure that the Contractor is fully prepared for the adequate management of the HSE aspects of the project, and as a basis for monitoring of the Contractor’s HSE performance. 55. The Contractor’s EHS-MP shall provide at least:  a description of procedures and methods for complying with these general environmental management conditions, and any specific conditions specified in an EMP;  a description of specific mitigation measures that will be implemented in order to minimize adverse impacts;  a description of all planned monitoring activities (e.g. sediment discharges from borrow areas) and the reporting thereof; and  the internal organizational, management and reporting mechanisms put in place for such. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 110 - 56. The Contractor’s EHS-MP will be reviewed and approved by the Client before start of the works. This review should demonstrate if the Contractor’s EHS-MP covers all of the identified impacts, and has defined appropriate measures to counteract any potential impacts. HSE Reporting 57. The Contractor shall prepare bi-weekly progress reports to the SE on compliance with these general conditions, the project EMP if any, and his own EHS-MP. An example format for a Contractor HSE report is given below. It is expected that the Contractor’s reports will include information on:  HSE management actions/measures taken, including approvals sought from local or national authorities;  Problems encountered in relation to HSE aspects (incidents, including delays, cost consequences, etc. as a result thereof);  Lack of compliance with contract requirements on the part of the Contractor;  Changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects; and  Observations, concerns raised and/or decisions taken with regard to HSE management during site meetings. 58. It is advisable that reporting of significant HSE incidents be done “as soon as practicable�. Such incident reporting shall therefore be done individually. Also, it is advisable that the Contractor keeps his own records on health, safety and welfare of persons, and damage to property. It is advisable to include such records, as well as copies of incident reports, as appendixes to the bi-weekly reports. Example formats for an incident notification and detailed report are given below. Details of HSE performance will be reported to the Client through the SE’s reports to the Client. Training of Contractor’s Personnel 59. The Contractor shall provide sufficient training to his own personnel to ensure that they are all aware of the relevant aspects of these general conditions, any project EMP, and his own EHS-MP, and are able to fulfill their expected roles and functions. Specific training should be provided to those employees that have particular responsibilities associated with the implementation of the EHS-MP. General topics should be:  HSE in general (working procedures);  emergency procedures; and  social and cultural aspects (awareness raising on social issues). Cost of Compliance 60. It is expected that compliance with these conditions is already part of standard good workmanship and state of art as generally required under this Contract. The item “Compliance with Environmental Management Conditions� in the Bill of Quantities covers these costs. No other payments will be made to the Contractor for compliance with any request to avoid and/or mitigate an avoidable HSE impact. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 111 - Example Format: HSE Report Contract: Period of reporting: HSE management actions/measures: Summarize HSE management actions/measures taken during period of reporting, including planning and management activities (e.g. risk and impact assessments), HSE training, specific design and work measures taken, etc. HSE incidents: Report on any problems encountered in relation to HSE aspects, including its consequences (delays, costs) and corrective measures taken. Include relevant incident reports. HSE compliance: Report on compliance with Contract HSE conditions, including any cases of non-compliance. Changes: Report on any changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects. Concerns and observations: Report on any observations, concerns raised and/or decisions taken with regard to HSE management during site meetings and visits. Signature (Name, Title Date): Contractor Representative Example Format: HSE Incident Notification Provide within 24 hrs to the Supervising Engineer Originators Reference No: Date of Incident: Time: Location of incident: Name of Person(s) involved: Employing Company: Type of Incident: Description of Incident: Where, when, what, how, who, operation in progress at the time (only factual) Immediate Action: Immediate remedial action and actions taken to prevent reoccurrence or escalation Signature (Name, Title, Date): Contractor Representative FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 112 - ANNEX 6: SUMMARY OF WORLD BANK SAFEGUARD POLICIES AND HOW THEY WILL APPLY TO THE FUTURE PROJECT ACTIVITIES  Environmental Assessment (OP 4.01). Outlines Bank policy and procedure for the environmental assessment of Bank lending operations. The Bank undertakes environmental screening of each proposed project to determine the appropriate extent and type of EA process. This environmental process will apply to major Sanitation and Water rehabilitation projects under GAMA.  Natural Habitats (OP 4.04). The conservation of natural habitats, like other measures that protect and enhance the environment, is essential for long-term sustainable development. The Bank does not support projects involving the significant conversion of natural habitats unless there are no feasible alternatives for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs. If the environmental assessment indicates that a project would significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to the Bank. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g. strategic habitat retention and post-development restoration) and establishing and maintaining an ecologically similar protected area. The Bank accepts other forms of mitigation measures only when they are technically justified. Should the sub-project-specific ESMPs indicate that natural habitats might be affected negatively by the proposed sub-project activities with suitable mitigation measures, such sub-projects will not be funded under the project.  Pest Management (OP 4.09). The policy supports safe, affective, and environmentally sound pest management. It promotes the use of biological and environmental control methods. An assessment is made of the capacity of the country’s regulatory framework and institutions to promote and support safe, effective, and environmentally sound pest management. This policy will most likely not apply to GAMA sub-projects.  Involuntary Resettlement (OP 4.12). This policy covers direct economic and social impacts that both result from Bank-assisted investment projects, and are caused by (a) the involuntary taking of land resulting in (i) relocation or loss of shelter; (ii) loss of assets or access to assets, or (iii) loss of income sources or means of livelihood, whether or not the affected persons must move to another location; or (b) the involuntary restriction of access to legally designated parks and protected areas resulting in adverse impacts on the livelihoods of the displaced persons. The GAMA project may entail taking of land for new development and there are aspects of the project that may cause displacement.  Indigenous Peoples (OD 4.20). This directive provides guidance to ensure that indigenous peoples benefit from development projects, and to avoid or mitigate adverse effects of Bank-financed development projects on indigenous peoples. Measures to address issues pertaining to indigenous peoples must be based on the informed participation of the indigenous people themselves. Sub-projects that would have negative impacts on indigenous people will not be funded under the GAMA.  Forests (OP 4.36). This policy applies to the following types of Bank-financed investment projects: (a) projects that have or may have impacts on the health and quality of forests; (b) projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests; and (c) projects that aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned. The Bank does not finance projects that, in its opinion, would involve significant conversion or degradation of critical forest areas or related critical habitats. If a project involves the significant conversion or degradation of natural forests or related natural habitats that the Bank determines are not critical, and the Bank determines that there are no feasible alternatives to the project FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 113 - and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs, the Bank may finance the project provided that it incorporates appropriate mitigation measures. Sub-projects that are likely to have negative impacts on forests will not be funded under GAMA.  Cultural Property (OP 11.03). The term “cultural property� includes sites having archeological (prehistoric), paleontological, historical, religious, and unique natural values. The Bank’s general policy regarding cultural property is to assist in their preservation, and to seek to avoid their elimination. Specifically, the Bank (i) normally declines to finance projects that will significantly damage non-replicable cultural property, and will assist only those projects that are sited or designed so as to prevent such damage; and (ii) will assist in the protection and enhancement of cultural properties encountered in Bank-financed projects, rather than leaving that protection to chance. The management of cultural property of a country is the responsibility of the government. The government’s attention should be drawn specifically to what is known about the cul tural property aspects of the proposed project site and appropriate agencies, NGOs, or MLGRD should be consulted; if there are any questions concerning cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist.  Safety of Dams (OP 4.37). For the life of any dam, the owner is responsible for ensuring that appropriate measures are taken and sufficient resources provided for the safety to the dam, irrespective of its funding sources or construction status. The Bank distinguishes between small and large dams. Small dams are normally less than 15 m in height; this category includes, for example, farm ponds, local silt retention dams, and low embankment tanks. For small dams, generic dam safety measures designed by qualified engineers are usually adequate. This policy does not apply to GAMA since the policy is not triggered under the project.  Projects on International Waterways (O 7.50). The Bank recognizes that the cooperation and good will of riparians is essential for the efficient utilization and protection of international waterways and attaches great importance to riparians making appropriate agreements or arrangement for the entire waterway or any part thereof. Projects that trigger this policy include hydroelectric, irrigation, flood control, navigation, drainage, water and sewerage, industrial, and similar projects that involve the use or potential pollution of international waterways. This policy will not apply to GAMA.  Disputed Areas (OP/BP/GP 7.60). Project in disputed areas may occur between the Bank and its member countries as well as between the borrower and one or more neighbouring countries. Any dispute over an area in which a proposed project is located requires formal procedures at the earliest possible stage. The Bank attempts to acquire assurance that it may proceed with a project in a disputed area if the governments concerned agree that, pending the settlement of the dispute, the project proposed can go forward without prejudice to the claims of the country having a dispute. FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 114 - ANNEX 7: LIST OF INDIVIDUALS/INSTITUTIONS CONTACTED MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT SANITATION AND WATER PROJECT FOR THE GREATER ACCRA METRPOLITAN AREA (GAMA) Accra Metropolitan Assembly (AMA), Accra Date: 17/11/2012 Name of Respondent(s) Designation Contacts 1 Metropolitan Development Planning Officer Consultation Issues Responses Formulation/Preparation of DMTDPs 1 How is the MTDP formulated? - Process begins at the grassroots, involving all relevant stakeholders including NGOs. - The process is an open participatory process where all views and concern are collated through a series of community meetings and public forums. 2 How does the MMA select projects/communities - Projects are selected based on their priority within the for inclusion into the MTDP? Are beneficiaries community. consulted?) - The consultations involved are extensive and all beneficiaries are consulted. 3 What MTDP is currently being implemented and - Upcoming projects are the Millenium City Projects (50 3-storey what environmental and social problems are 18 classroom blocks, library with sanitary facilities.), often associated with the execution of the MTDP Modernisation of Markets, Road projects, street lighting, projects? Sanitation projects etc. - Funding sources for these projects are USAID, SIF, GETFUND, Common Fund, Privates Companies etc . - These activities often results in dust, construction wastes generation, noise nuisance and interruption of access ways. EA Compliance in Implementing the MTDP Projects 4 Do the MMAs comply with the EA requirements Most major development Projects of the Assembly are subjected in implementing the MTDP projects? to the relevant environmental assessment requirements. However, ESIAs are not done some other Sanitation and Water projects. 5 Are environmental permits obtained for the Yes, Environmental permits are obtained prior to the execution projects prior to execution? Why not? Do the of some projects. MAs pay permit fees? Yes permit fees are paid. For some externally funded projects, (eg SIF) environmental permitting fees are always incorporated into the project cost.. 6 How is the lack of capacity a factor in EA non- The AMA lacks an in-house capacity for environmental compliance (no environmental and social assessment and management. The AMA therefore depends on safeguards for projects)? private consultancy services. The lack of the EA capacity affects the monitoring and compliance enforcement of environmental and social safeguards for projects. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 115 - 7 Are planning approvals obtained prior to the Yes execution of the MTDP projects? Why? Are fees paid? By & to whom? Environmental & Natural Disasters 8 What types of environmental & natural disasters Flooding is a common occurrence during the raining season, have been plaguing the Metro/Municipality and when there is a heavy down pour. how often? 9 How do these disasters affect the livelihood of It affects many households, and interrupts commercial the people – the most vulnerable and what activities, destroys assets of people and affects the livelihood of emergency response plans are available? the people. There are no proper emergency response plans readily available but NADMO assist victims in such circumstances. GAMA (Sanitation Water Facilities) 10 Is the second Urban Environmental Sanitation Yes, the Metropolis has been benefiting mmensely from the Project (UESP II) being implemented in the UESP II. There are ongoing UESP II project covering Metropolis/Municipality and how successful are sewerage improvement. these? 11 Any lessons for the GAMA (which is also has Technical and administrative structures and expertise in place urban Sanitation and Water facilities provisions)? will be useful to the GAMA 12 What are the likely environmental and social The GAMA will generate employment opportunities and impacts that could result from the GAMA improve Sanitation and Water services of the metropolis. Major investments? environmental and social impacts are not anticipated from the GAMA. The potential environmental and social impacts may relate to normal construction impacts, which could be addressed through effective EA compliance and monitoring. Land acquisition impacts and encroachment are potential social concerns that may arise. 13 Are there any institutional needs and capacities Capacity strengthening for environmental assessment and you may require to participate in the GAMA? management within the AMA is very necessary. Particularly capacities for implementing and monitoring the environmental and social management framework to achieve its objectives. 14 Are there personnel in the MMA who can be Yes trained to meet the needs of the GAMA? 15 What challenges can we foresee & how can we The success of the GAMA will depend on the MCEs so there is overcome them? the need for the MCEs to understand and accept the project for good success. The MCEs need to be fully involved in the project. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 116 - ANNEX 8: TERMS OF REFERENCE FOR GAMA ESMF MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT Sanitation and Water Project for the Greater Accra Metropolitan Area TERMS OF REFERENCE FOR PREPARATION OF AN ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 1.0 INTRODUCTION The assignment for which these Terms of Reference have been prepared involves the preparation of an Environmental and Social Management Framework (ESMF) to ensure that all investments envisaged under the proposed Sanitation and Water Supply Project for GAMA are adequately screened for their potential environmental and social impacts and that correct procedures to be followed to mitigate and minimize any potential negative impacts arising from these investments. The ESMF will be specific on the nature of mitigation measures but generic on the location and scope of interventions as these will not be known during project preparation. The ESMF will provide clear guidance for the preparation of site-specific EIAs and EMPs during project implementation. At this stage, specific environmental and social issues will be investigated in detail and a full Environmental and Social Impact Assessment undertaken. Though a full EIA will be carried out for some specific investments with known locations such as the septic sludge treatment facilities (anaerobic digesters), the potential environmental and social impacts of several other investments are not presently determinable as some of the proposed project interventions will be identified following a community consultative, participatory and to some extent demand-driven approach. In such cases, communities will be selected to participate in project activities based on prevailing needs among other factors and selected communities will be assisted to determine the specific nature and location of water and environmental sanitation improvements. The nature of the interventions under the proposed project are directed towards improving environmental conditions in communities as well as some city-wide enhancements in management of waste and therefore it is anticipated that when fully implemented, the project will contribute positively to overall environmental conditions within the project areas. 1.1 Project Development Objective(s) The objective of the project would be to increase access to safe water and improved sanitation to people in the GAMA, with emphasis on low income communities, and to improve operation and management of wastewater facilities. In order to achieve this objective, the project would support the expansion and improvement of the water distribution network, the expansion of community water points and private water connections, the development of on-site and sewered sanitation facilities and the improved collection and treatment of wastewater and faecal sludge. Behaviour Change Campaign on hygiene, sanitation and safe water will also be promoted through social mobilization activities, as well as social accountability to ensure the sustainability of the facilities and services. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 117 - Preliminary studies and assessment recognize the positive social and economic impact that the project can generate. These assessments also highlight the potential negative social impacts and therefore the need for mitigation measures. These concerns will trigger the World Bank’s safeguards policy on Involuntary Resettlement, O.P 4.12. This implies that this project is likely to have social impacts on land access, restriction of access to assets, displacement and loss of livelihood among others. 1.2 Project Description The proposed project is structured as a two-phase Adaptable Program Loan (APL) given the long term engagement required to increase access to sanitation and water in low income areas of GAMA and to attain an efficient and sustainable operation and management of the services. The latter will require the development of a satisfactory institutional arrangement for the integrated planning and management of water and sanitation services that will constitute the main trigger to move to the second phase. The proposed APL would be executed over the 2013-2020 period, with the two phases overlapping. The first phase (APL-1) would extend from 2013 to 2016 for a credit amount of USD130 million. The second phase (APL- 2) would extend from 2016 to 2020 for a credit amount of USD170 million, but could begin earlier, as soon as the trigger is met. The proposed APL-1 would have the following four components: Component 1 - Provision of water and environmental sanitation services to priority low income areas of the GAMA (USD20 million). The MMAs will propose the priority low income communities to benefit from the project based upon selection criteria to be agreed during project preparation. The type of water supply and sanitation facilities will be thoroughly consulted and agreed with each community as to best suit their needs, while taking into consideration particular conditions such as: soil characteristics, topography, space availability, etc. In addition to facilities for households, this component will support the construction of institutional facilities in schools, health centers and in public areas such as markets. This component will also provide support for advocacy and other measures to help enforce current laws and regulations, such as the obligation of landlords to provide sanitation facilities. Additionally, specific measures will be introduced to effectively engage communities and particularly women in decisions relating to the delivery and oversight of water and sanitation services such as Water and Sanitation Development Boards (WSDBs). This component will also support the establishment and strengthening of social accountability mechanisms so citizens can report on the provision of services. Component 2 – Improvement and expansion of the water distribution network in the GAMA (USD50 million). This component will support investments required to improve and expand the existing network in order to provide piped water to the target people living in low income communities in the GAMA. These investments include the installation of transmission mains, booster pumps and any other facilities required to ensure that a share of the additional water production reach the targeted low income areas. Therefore this component will be coordinated with current and incoming projects supported by other development partners and private investors in the GAMA. The priority of the interventions will be determined with the assistance of a hydraulic model for the GAMA to be developed during project preparation. This component would also support the acquisition and installation of DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 118 - meters and other equipment, as well as the provision of services, aimed at improving water demand management and reducing non-revenue water. Component 3 – Improvement and expansion of wastewater and fecal sludge collection, transportation and treatment in the GAMA (USD50 million) This component will finance collection and/or treatment of wastewater and fecal sudge to be generated from the low income communities and rest of GAMA. However, these facilities will be seized to take care of the entire wastewater flows and sludge volumes generated in the GAMA, which currently end up discharged untreated into drains and eventually into the sea. This component will also support the development of solutions to improve the safe collection, transport and treatment of fecal sludge. Component 4 – Institutional Strengthening (USD 10 million). This component will provide technical assistance (TA) to municipal, metropolitan and national institutions, including the promotion of private sector initiatives for water and sanitation. The subcomponents would be further developed during preparation but initially may include: a) TA to the MMAs, particularly to their Waste Management Departments for: i. Strengthening capacity for the planning of sanitation services with active community participation; ii. Capacity strengthening in oversight and enforcement of sanitation regulations and by-laws; iii. Facilitating interface between households and private sector actors in the expansion of access to on- site sanitation; iv. Hygienic removal and transportation of decal sludge; and v. Management of wastewater disposal and treatment sites, including delegation to private sector operators. b) TA to the MLGRD and the RCC of Greater Accra to: v. strengthen the planning and coordination capacity of the RPCU in the short term; and vi. support the development of a metropolitan institutional arrangement for integrated planning, implementation, operation and management of sanitation facilities in the long term. The discussion of this integrated institutional arrangement has already begun and will continue during project preparation by means of a series of workshops and consultations with key stakeholders. c) TA to GWCL for the establishment of a pro-poor unit to promote the access of water services to low income areas and the sustainability of those services. This will include strengthening coordination and collaboration with MMAs, NGOs, CBOs, WSDBs add local private sector. d) TA to the MWRWH to support the institutional restructuring and/or adoption of management options to improve the provision of water supply services in GAMA and other urban areas. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 119 - e) Support for the development and training of local private sector to provide sanitation services, especially latrine construction and sludge removal/transport. f) Carrying out of surveys to establish baselines and evaluate the impact of project supported activities in the low- income communities and other GAMA areas. 2.0 OBJECTIVE In World Bank-Financed projects, a key goal is to enhance positive and sustainable environmental and social outcomes of the project by minimizing and/avoiding negative environmental and social impacts. Where avoidance is not possible, an Environmental and Social Framework is developed which provides the framework within which to address the issues. The objective of the assignment is to prepare an ESMF which will: i. Establish the legal framework, procedures, and methods for the environmental and social planning, review, approval and implementation investments to be financed under the project; ii. Identify roles and responsibilities, including reporting procedures and monitoring and evaluation; iii. Identify capacity/or training needs for different stakeholders to ensure better implementation of the provisions in the ESMF and; iv. Identify funding requirements and resources to ensure effective implementation of the framework. 3.0 SCOPE OF WORK The Consultant shall undertake the following tasks: i. Description of Project: Provide a brief description of the GAMA project to place the ESMF in the relevant context. This would include a summary of the background to the project, the different components and most importantly, the consultant shall identify the possible environmental and social issues that each component and subcomponents are likely to generate and for which reason this ESMF is being developed. ii. Legislative, Regulative and Administrative Regime: The Consultant shall describe the legislative, regulatory and administrative regime regarding the triggered Safeguards Policies that the project will be operating. In addition the consultant shall include the requirements and approval processes/procedures for specific environmental issues. The Consultant shall clearly identify and highlight any significant changes in regulations/legislation and develop a stakeholders’ consultation process that ensures that all key stakeholders, including potentially affected persons, are aware of the objectives and potential environmental and social impacts of the proposed project and their views are incorporated into the projects’ design as appropriate. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 120 - iii. Description of Baseline The consultant shall describe the baseline which will include the biophysical and socio-economic environment for the participating Assemblies. iv. Determination of Potential Impacts and Screening: The Consultant shall determine the types of environmental and social impacts that could result from the likely investments. The consultant shall also develop a simple environmental and social screening form to assist in the evaluation and future reviews and assessments of investments. The form shall be attached to the main report as annex. v. Environmental and Social Checklist: The consultant shall develop an environmental and social checklist. The checklist shall outline simple mitigation measures for the identified potential negative environmental and social impacts. The implementation of these will be guided by an Environmental and Social Management Plan. The Management Plan shall consist of mitigation measures and monitoring indicators. vi. Institutional Needs and Capacity Building: The Consultant shall identify the existing institutional needs and the capacity of all participating institutions from the national through to the local level. This is to help assess what needs and capacities will be required for implementing and monitoring the ESMF to achieve the intended objectives. Based on this analysis, the consultant shall develop a training and capacity building programme on environmental and social safeguards for the identified institutions. Any other technical support considered important may also be outlined by the consultant. vii. Budget: The Consultant shall develop appropriate budget for the implementation of the entire ESMF. viii. Public Consultations and Disclosure: The Consultant will undertake public consultations with the relevant stakeholders including the different categories of project participants and other affected people like the elderly, the youth, women and the disabled. The Consultant shall prepare in close liaison with the Client, a Consultation Programme for the entire process, which: a. Defines the terminology and methodology. The following terms should be defined and distinguished from each other: consultation, information sharing, information dissemination, workshops, meetings, and public hearings. b. Identifies all stakeholders likely to be involved in the consultation process. The stakeholders will encompass and will include organizations, state authorities (Water Resources Commission, EPA, Ghana Water Company and relevant municipal/district assemblies), c. Specifies the roles of the Client, the Consultant and the key stakeholders during the consultation process. d. Presents an organization plan and schedule for the consultation of stakeholders.The program will define the form of consultations (focus group meetings, community meetings, workshops, etc.), the category of stakeholders to be included, and the schedule for consultation. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 121 - e. Includes a schedule for information dissemination to the public. f. The Consultant shall plan: (i) informal and formal meetings for information sharing,(ii) public dissemination of reports and studies, and (iii) public consultations as required by the Ghanaian EA Regulation 1999, art. 17 and 18 (public hearings). The location and schedule of which will be discussed and decided upon with key stakeholders. g. Is in compliance with the Ghana Environmental Assessment regulation, 1999 (in particular art.15 “scoping notice� and art. 17 “public hearing�) and with the World Bank policies, in a way which meets Bank and Ghanaian requirements. The consultation programme shall be designed very early during the studies and submitted to the Client. The Consultant shall (i) lead the consultation process on behalf of the Client, (ii) participate in planning and implementing the consultation process (iii) arrange workshops including relevant stakeholders (EPA, WRC, GWC), and shall participate in public hearings and other activities defined in the Ghanaian regulation and World Bank safeguard policies. Details of the consultations shall be attached to this report as an annex. The ESMF shall be disclosed in the country by the client. ix. The Outline for the ESMF Report: The minimum content of the ESMF Report should include an Executive summary and all sections outlined under the scope of works of this TOR. There shall also be technical annexes attached to the main report. 4.0 CONSULTANT QUALIFICATIONS The assignment will be carried out by an Individual Consultant with 10 years post qualification experience (postgraduate preferable) and at least five (5) years relevant working experience dealing with Environmental Safeguards, Environmental Assessments and related issues. S/he should have proven experience with World Bank Safeguard Policies and requirements as well as Government of Ghana environmental and social policies on safeguards. In particular, experience in preparation of Environmental and Social Assessments, Environmental and Social Management Frameworks, Environmental Management Plans is essential. The Consultant’s familiarity with the workings of international development institutions like the World Bank, IFC, African Development Bank among others will be an advantage. 5.0 ESTIMATED LEVEL OF EFFORT It is anticipated that about two (2) staff-months will be required for the assignment. The duration of the assignment will be for 10 weeks. 6.0 SCHEDULE AND DELIVERABLES a. Inception Report: This report will have detailed work plan with output indicators of performance. This will be discussed by the consultant, client and other experts to ensure quality of final outcome. Three (3) DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 122 - copies shall be submitted to the client in addition to an electronic version. This will be delivered one (1) week after signing of contract; b. First Draft Report: This report will be circulated for comments and relevant issues raised incorporated into revised version. Three copies shall be submitted to the client. In addition the consultant will provide an electronic version. This will be delivered four (4) weeks after signing of contract. b. Final Draft Report: This will be circulated for comments and relevant issues raised shall be incorporated into the revised version. Three copies shall be submitted to the client. In addition the consultant will provide an electronic version. This will be delivered three (3) weeks after submission of first draft. d. Final Report: The final report should include a concise Executive Summary and should have all annexes and bibliography and the dissemination/disclosure plan. This will be delivered one (1) week after receipt of comments from the Client. 7.0 PAYMENT SCHEDULE The payment schedule is outlined as follows and based on the stipulated deliverables:  20% of Contract Sum upon Submission of Inception Report  30% of Contract Sum upon Submission of First Draft Report  30% of Contract Sum upon Submission of Final Draft Report  20% of Contract Sum upon Submission and Acceptance of Final Report 8.0 ADMINISTRATIVE ARRANGEMENTS The Project Coordinating Unit (PCU) at MLGRD will supervise this assignment. MLGRD will provide the necessary administrative support and make available necessary documents, reports, data and contacts. In addition, MLGRD will convey copies of the draft and final reports from the consultant to the World Bank for comments prior to acceptance of the report and making final payments to the consultant. DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 123 -