E4515 REPUBLIC OF GHANA GHANA SECONDARY EDUCATION IMPROVEMENT PROJECT (GSEIP) ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) March 25, 2014 TABLE OF CONTENTS 1.0 INTRODUCTION ________________________________________________________ 10 2.0 PROJECT DESCRIPTION __________________________________________________ 11 2.1 Component 1: Increase Access with Equity _______________________________________ 11 2.2 Component 2: Quality and Relevance of Secondary School Teaching and Learning ____ Error! Bookmark not defined. 2.3 Component 3: Technical Assistance and Management Support Error! Bookmark not defined. 2.4 Description of Civil Works ____________________________________________________ 13 2.5 Implementation Arrangements ________________________________________________ 13 3.0 RELEVANT LEGAL AND INSTITUTIONAL FRAMEWORK _________________________ 17 3.1 Ghana’s Environmental Policy _________________________________________________ 17 3.2 Environmental Protection Agency and Environmental Impact Assessment (EIA) _________ 17 3.3 Public Health Act ___________________________________________________________ 18 3.4 National Sanitation Policy ____________________________________________________ 18 3.5 Planning Policies ____________________________________________________________ 19 4.0 DESCRIPTION OF THE ENVIRONMENTAL & SOCIAL IMPACTS AND MITIGATION MEASURES _________________________________________________________________ 21 4.1 Introduction _______________________________________________________________ 21 4.2 Potential Environmental and Social Impacts______________________________________ 21 4.3 Pre-Constructional Phase _____________________________________________________ 21 5.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK _____________________ 31 5.1 Introduction __________________________________________________________________ 31 5.2 Screening for Site Selection ______________________________________________________ 31 5.3 Screening for Potential Environmental and Social Impacts _____________________________ 32 5.4 Mitigation of Impacts ___________________________________________________________ 34 5.5 Guidelines for Community Involvement ____________________________________________ 34 5.6 Guidelines for Project Site Selection _______________________________________________ 35 5.7 Guidelines for the Timing of Constructional Activities _________________________________ 36 5.8 Guidelines for Construction Work _________________________________________________ 36 6.0 ENVIRONMENTAL AND SOCIAL ADMINISTRATIVECONSIDERATIONS __ Error! Bookmark not defined. 6.1 Institutional Arrangements and Responsibilities _______________ Error! Bookmark not defined. 6.2 The Environmental and Social Technical Planning Guidelines _____ Error! Bookmark not defined. 6.3 Internal Compliance Monitoring ____________________________ Error! Bookmark not defined. GSEIP-ESMF Page 2 6.4 Trainings and Capacity Building _____________________________ Error! Bookmark not defined. 6.5 ESMF Costs _____________________________________________ Error! Bookmark not defined. 6.6 Actors _________________________________________________ Error! Bookmark not defined. 6.7 Project Management Structure Guidelines ____________________ Error! Bookmark not defined. 6.8 Environmental Management Guidelines______________________ Error! Bookmark not defined. 6.9 Guidelines of the Role of the EPA in the Project ________________ Error! Bookmark not defined. 6.10 Guidelines for EPA’s Registration of the Projects ______________ Error! Bookmark not defined. 6.11 Guidelines for Capacity Building ___________________________ Error! Bookmark not defined. 6.12 Guidelines for Cost Estimates of the Implementation of the Mitigation Measures and Monitoring ________________________________________________ Error! Bookmark not defined. 7.0 ENVIRONMENTAL MITIGATION PLAN (EMP) ___________________________________ 48 7.1 Introduction __________________________________________________________________ 48 7.2 The role of stakeholders in ESMF Implementation____________________________________ 48 8.0 CONSULTATIONS _________________________________________________________ 56 8.1Introduction___________________________________________________________________ 56 8.2 Methodology _________________________________________________________________ 56 8.3 General Concerns ______________________________________________________________ 57 ANNEXES ___________________________________________________________________ 58 Annex 1: Methods and Techniques Used in Assessing and Analyzing Impacts ____________ 58 General Approach to the Assignment _________________________________________________ 58 Methods of Data Collection _________________________________________________________ 58 Assessing and Analysing of Environmental Social Impacts _________________________________ 60 Annex 2. Consultations with key Stakeholders _____________________________________ 61 Annex 3. Socioeconomic and Environmental Characteristics in the Education Sector ______ 65 Annex 4. School Planning and Construction Checklist _______________________________ 71 Annex 5. Terms of reference for ICU Environmental Consultant _______________________ 78 Annex 6. Example of environmental contract clauses _______________________________ 79 Annex 7. SEIP Environmental and social screening form _____________________________ 83 Annex 8. E&S Due Diligence Checklist ____________________________________________ 86 GSEIP-ESMF Page 3 ABBREVIATIONS AND ACRONYMS ADEOP Annual District Education Operational Plan AESOP Annual Education Sector Operational Plan APW Annual Programs of Work BECE Basic Education Certificate Examination CAGD Controller and Accountant General Department CBO Community Based Organization CCT Conditional Cash Transfer CREATE Consortium for Research on Educational Access, Transitions & Equity CS Circuit Supervisor CSA Civil Service Agency DACF District Assembly Common Fund DEO District Education Office DEOC District Education Oversight Committees DFID UK Department for International Development DP Development Partner EDI EFA Development Index EFA Education for All EFA-FTI Education for All Fast Track Initiative EMIS Education Management Information System ERP Economic Reform Program ERRC Education Reform Review Committee ESP Education Strategic Plan ESPR Education Sector Performance Report FCUBE Free Compulsory Universal Basic Education FTI Fast Track Initiative GAR Gross Admission Rate GDHS Ghana Demographic and Health Survey GDP Gross Domestic Product GER Gross Enrolment Ratio GES Ghana Education Service GET-Fund Ghana Education Trust Fund GLSS Ghana Living Standards Survey GNAT Ghana National Association of Teachers GNI Gross National Income GoG Government of Ghana GPE Global Partnership for Education GPEF Global Partnership for Education Fund GPI Gender Parity Index GPRS Growth and Poverty Reduction Strategy GSFP Ghana School Feeding Program GSS Ghana Statistical Service HDI Human Development Index HE Higher Education HEI Higher Education Institute ICT Information and Communication Technology IMF International Monetary Fund INSET In-Service Education and Training JHS Junior High School GSEIP-ESMF Page 4 JICA Japan International Cooperation Agency KVIP Kumasi Ventilated Improved Pit LEAP Livelihood Empowerment Against Poverty MDBS Multi-Donor Budget Support MDG Millennium Development Goals MLGRD Ministry of Local Government and Rural Development MMDAs Metropolitan, Municipal and District Assemblies MoE Ministry of Education MoFEP Ministry of Finance and Economic Planning MoLG Ministry of Local Government MTEF Medium Term Expenditure Framework NAB National Accreditation Board NAR Net Admission Rate NCTE National Council for Tertiary Education NDC National Democratic Congress NEA National Education Assessment NER Net Enrolment Ratio NERIC National Education Reform Implementation Committee NERP National Education Reform Program NESAR National Education Sector Annual Report NGO Non-Governmental Organization NIB National Inspectorate Board NVTIs National Vocation Training Institutes PBME Planning, Budgeting, Monitoring and Evaluation Department PCE Per child recurrent expenditure PE Personnel Emoluments PER Public Expenditure Review PPP Purchasing Power Parity PRSCs Poverty Reduction Strategy Credits PRSP Poverty Reduction Strategy Paper PTA Parent Teacher Association PTE Per teacher recurrent expenditure PTR Pupil Teacher Ratio PTTR Pupil Trained Teacher Ratio REO Regional Education Office SHS Senior High School SMC School Management Committee SPAM School Performance Assessment Meeting SPIP School Performance Implementation Plan SSA Sub-Saharan Africa SSSCE Senior Secondary School Certificate Examination TED Teacher Education Department TIMSS Trends in International Mathematics and Science Study TTIs Technical Training Institutes TVET Technical and Vocational Education and Training UBC Universal Basic Completion UBE Universal Basic Education UCC University of Cape Coast UNICEF United Nations Children’s Fund UPC Universal Primary Completion GSEIP-ESMF Page 5 USAID United States Agency for International Development VAT Value Added Tax WAEC West African Examination Council WASSCE West African Senior Secondary Certificate Examination WFP World Food Program GSEIP-ESMF Page 6 EXECUTIVE SUMMARY Introduction This current Environmental and Social Management Framework (ESMF) has been developed to provide environmental and social management guidance for the Secondary Education Improvement Project (SEIP) being prepared for IDA support of US$155 million (one hundred and fifty five million United States dollars). The ESMF will provide guidance to project implementation operatives, districts, institutions, contractors, and other stakeholders including beneficiaries of the senior secondary school rehabilitation and construction under the project. The SEIP will support senior secondary education in Ghana, through a five-year Investment Project Financing (IPF) using a results-based approach. The project development objective is to increase access to upper secondary education in underserved school districts and improve quality in low-performing senior high schools in Ghana. The project’s two components will: (i) provide support to increase access with equity and quality in senior high schools using results-based financing; and (ii) strengthen capacity of Ministry of Education, Ghana Education Service to monitor, coordinate, evaluate and analyze policies for the first component. A matrix of indicators has been developed to measure performance of component 1 annually and to monitor the results achieved as reflected in the results framework. Component 1 will support and monitor key activities to accomplish these goals through construction of new schools, quality improvement and expansion of existing schools where demand is high and in areas where schools have the potential to absorb and retain students, and through scholarships to girls and low income students. Component 2 will strengthen the implementation capacity of the Ministry of Education and Ghana Education Service in monitoring and evaluation, coordination, planning, communication, financial management, procurement, and safeguards. It will also support research, social targeting, teacher rationalization, curriculum relevance, strengthen data collection for school mapping, and establish priorities for new construction, renovation and maintenance of schools. The establishment of a web platform for school reporting and real time monitoring of all SHS implementation activities would enhance and strengthen the Education Management Information System (EMIS) in order to help government report on achievement of results. Activities the Government plans to undertake in the project that trigger the use of the ESMF are: (i) the construction of new senior secondary schools in 14 districts which currently have no senior secondary schools; (ii) new construction in (possibly 10) selected districts based on district criteria for population demand, poverty indicators, etc; and (iii) upgrading, expansion and rehabilitation of existing selected low performing schools. The new construction projects will require the acquisition of parcels of land of approximately 10 acres (4.16 ha) at the respective locations. Schools that run agricultural programs will require additional land for demonstration or practical lessons. Civil works under the project will comprise the construction of a classroom and laboratory complex, a headmaster’s residence, an assistant headmaster’s residence, staff residential quarters, an open sports area, a multi-purpose hall and an administration block. Gender considerations have also been made in the inclusion of gender specific changing rooms and toilets. This updated ESMF will be used to mainstream environment and social safeguards into the design and planning of the SEIP. The choice of ESMF (instead of EIA) was made for the project because of the following reasons: GSEIP-ESMF Page 7  Wide geographical spread – 24 potential districts where new construction will be undertaken and about 100 districts where senior secondary school facilities will be improved. These activities will be in all the ten (10) regions of Ghana;  Implementation duration – will be over five years from 2014 - 2019;  Cross sectoral involvement and scope –Ministries, Departments, Agencies and Schools at national, regional and district levels;  Site specific activities – which may cover a range of different components e.g. classroom block, sanitation, borehole, solar energy, staff residential facilities- the level of site specific project will be determined based on the situation of the location. It is imperative under these considerations to have an Environmental and Social Management Framework which provides guiding principles and outlines procedures for mitigating identified environmental and social impacts and risks as a result of the project. The current ESMF provides:  Screening checklist for site selection under the project;  Legal framework for the implementation of the ESMF,  The basis for identifying potential environmental and social impacts and risks of project activities and proposes appropriate mitigation measures,  Institutional structure that assigns responsibility for various activities within the framework. Legal and Administrative Frameworks A number of policies as well as legal and administrative frameworks have been considered in the ESMF. Ghana’s National Environmental Policy aims at ensuring a sound management of resources and the environment and to avoid any exploitation of these resources in a manner that might cause irreparable damage to the environment. The policy endorses the preventive approach to environmental management and emphasizes the need to promote socio-economic development within the context of prescribed acceptable environmental standards and safeguards. In effect, it seeks reconciliation between economic planning and environmental resource development with the view to achieving sustainable national development. The Policy Statement seeks among other things:  to ensure environmentally sound use of both renewable and non- renewable resources in the process of national development,  to develop procedures for the utilization of land resources in a manner that would ensure the maximum degree of economy in the use of land and avoid or minimize conflicts, and  to institute and implement the concept of sustainable development by requiring prior environmental impact assessments of new investments and developments that would be deemed to affect the quality of the environment. The environmental policies and legal framework and procedures considered in preparation of the SEIP ESMF include the following:  Ghana’s Environmental Policy;  The Environmental Protection Agency Act of 1994 (Act 490);  The Environmental Assessment Regulations (LI 1652), and EIA procedures;  Laws and Regulations pertaining to the protection of the environment and health;  National Sanitation Policy;  Town and Country Planning Ordinance 1951 (Cap84);  The Local Government Act 462 of 1993; and GSEIP-ESMF Page 8  The World Bank’s safeguard policies which include guidance on EA requirements - Environmental Assessment (OP4.01), and also the Involuntary Resettlement (OP/BP 4.12), etc. Likely Environmental and Social Impacts and Mitigation Measures The SEIP ESMF considers likely potential environmental and social concerns likely to arise from the construction and rehabilitation of buildings, water points and sanitation facilities under the project, and their proposed mitigation measures. Work at the District levels across other World Bank sponsored infrastructure projects shows that issues such as community involvement, community ownership and selection of appropriate sites for schools construction are some of the key concerns, which influence the success, and sustainability of such projects. That the project is a reimbursable process paying against results means that there is no traditional investment procedure (e.g., no objections) nor a PIU and the Bank will have to be provided verification that environmental and social provisions meeting Bank policy standards have been followed. This will require a due diligence checklist demonstrating that all World Bank Environmental and Social policy requirements are met. Potential environmental and social concerns and impacts at the pre-constructional and constructional stages include under site selection, for example, concerns about the siting of school projects in sacred groves or burial grounds, on disputed land, and in ecologically sensitive areas. Mitigation measures include giving priority to unencumbered land and in cases where people are inevitably affected, according to the World Bank OP 4.12 on Involuntary Resettlement, applying the necessary mitigation measures. Other mitigation measures will include community sensitization and involvement, site preparation and timing which does not leave the land susceptible to erosion, and the destruction of crops, staggering site clearing for school construction and facilities improvement. Construction phase impacts may include air quality impact from dust generation of excavation, noise generation from construction activities, public health and safety from unconsolidated material left at the construction site, and occupational health and safety effects on construction site workers who may be endangered. In all these cases, mitigation measures and procedures including relevant budget have been outlined for easy follow up on mitigation. The responsibilities for screening for potential project impacts as well as the institutional arrangements for environmental and social management frameworks are also outlined. Institutional Arrangements and Responsibilities In order to ensure proper management of the environmental and social concerns, responsibilities and roles of focal persons, monitoring mechanisms, training and capacity building are detailed in the ESMF. Oversight of SEIP implementation will be in the Ministry of Education (MOE) with the Ghana Education Service providing their mandated implementation role for service delivery. The institutional arrangements will facilitate environmental and social soundness and sustainability. A Steering Committee and Project Management Team will be established to coordinate and oversee implementation. The Project Management Team will derive from the Project Implementation Committee at the national level and will assume project control and monitor civil works executed in the four (4) zones of the country. The PMT will include 2 environmental and social safeguards consultants; 1 procurement specialist (MOE); 1 technical advisor (MOE); 4 architects (FPMU + 3 others); 4 quantity surveyors (FPMU, GETFund and 2 others); 4 civil engineers (FPMU + 3 others); 1 electrical engineer (on retainer basis) and a Project management consultancy firm (providing other needed capacity). The implementation and monitoring of the ESMF, the identification of affected persons and compensation levels, the payment of compensation and dispute resolution roles include the Project Management Team, the District Education Oversight Committee (DEOC), the Environmental Protection Agency (EPA), and the Project Steering Committee. The cost of ESMF implementation for duration of three years is estimated at GHC1,657,520 (approx. US$635,000). GSEIP-ESMF Page 9 1.0 INTRODUCTION The Ghana Secondary School Project will support senior secondary education through a five-year US$155 million Investment Project Financing (IPF) instrument using a results-based-lending approach. This framework builds on existing government systems and also on the key objectives of the Education Strategic Plan 2010-2020, especially in its focus equity and quality of services and on efficiency and accountability of education management. The Ghana Secondary Education Improvement Project is being developed as part of a larger program of government to support the secondary education s u b -sector. The Ghana Secondary Education Improvement Project supports areas that complement the government’s expenditures. The SEIP supports the Government’s long term vision for expansion of Secondary Education. Government strategy aims to rapidly expand both access and quality of secondary education making it gradually universal and also progressively free for students who are unable to afford access to secondary education. Among other plans, the Government is proposing to build about 200 secondary schools above and beyond recent investments into the current infrastructure documented in a recent policy document, the Community Day School Construction Program. The prioritization and better targeting of resources will help ensure more equitable availability of SHS and redress the growing disparities in access to quality secondary education. GSEIP-ESMF Page 10 2.0 PROJECT DESCRIPTION The proposed project will support senior secondary education through a five-year US $155 million Investment Project Financing (IPF) instrument using a results-based-lending approach. The project development objective is to increase access to upper secondary education in underserved school districts and improve quality in low-performing senior high schools in Ghana. 2.1 Component 1: Program Support to Increase Access with Equity and Quality in SHS Component 1 uses a results-based financing (RBF) modality. Disbursements up to a capped absolute amount will be made against specific line items in the Education sector annual budgets, referred to as eligible expenditure programs (EEPs). These disbursements will be conditioned on achievement of specified results, as measured by disbursement-linked indicators (DLIs). A matrix of indicators has been developed to measure performance annually and monitor the results achieved as reflected in the results framework. Policies and interventions to be supported under the first component of SEIP are grouped into two pillars: (i) increasing access with equity (geographic, gender, poverty, etc.); and (ii) enhancing quality of low performing SHS. Pillar 1: Increase Access with Equity: The objective of this pillar is to improve access to senior secondary education and improve equity in underserved districts and subsidize students especially girls from low income households. This pillar will support and monitor key activities to accomplish these goals through the construction of new schools and the improvement and expansion of existing schools where demand is high and the schools have inadequate facilities to absorb and retain students. The SEIP is expected to finance results of the Government’s ambitious program to expand space through the construction of new senior secondary schools in underserved areas, rehabilitation and expansion of existing low performing schools and through support for SHS attainment of disadvantaged students. The Government plans include new construction in the 14 districts where there are no current operating public SHS. In addition, using the agreed selection criteria for eligible student population compared with available school capacity (effective demand) combined with district level poverty indicators, an additional 10 districts have been identified for new construction. The ultimate objective is to create new spaces for those demanding seats in SHS and to fill these spaces with new students coming from previously underserved communities. In addition to new schools, this component would focus on improving existing SHS, particularly those with capacity for expansion, meeting criteria of school age population not attending SHS, and low performance criteria in addition to a needs assessment which will determine level of deficiency (bathrooms, science labs, computer facilities, etc.) and scope for upgrading. This pillar will improve the government’s targeting of resources to support increased access by further supporting scholarship and other demand side investments to encourage girls’ attendance and poorer students. Given the operation’s focus on under-served areas and promoting access with equity, disbursement will be linked to indicators (disbursement linked indicators) that measure increases in seat availability in these targeted locations for new construction. In addition a second indicator would be used to measure progress of utilization of existing schools where new seats are made available in selected schools. Targeting resources for girls and students from low income families in underserved communities would strengthen equity reforms. Therefore, the release of IDA credit funds will be linked to achievement of the following DLIs: (i) selection based on targeting of school expansion in underserved school districts (DLI1); (ii) increasing new seats for SHS students in underserved school districts (DLI 2); (iii) increasing GSEIP-ESMF Page 11 utilized seats in existing low-performing schools (DLI 3); and (iv) increased enrolment in SHS in targeted districts (for girls and low-income students) (DLI 4). Pillar 2: Enhancing quality in low-performing Senior High Schools: The objective of this pillar is to improve the quality of SHS, with a focus on math and science education in selected low performing schools. The SEIP would also strengthen school management, leadership and expansion of ICT in the selected low-performing schools. The low performing schools typically have inadequate: infrastructure, management, equipment, learning resources and sources of internally generated funding. In order to improve quality, the Project will support the government’s program to (i) strengthen school management, leadership and accountability; (ii) target interventions to improve the quality of science and math education; and (iii) introduce School Performance Partnerships based on School Improvement Plans to capture quality improvements. The School Performance partnerships would develop mutual accountability between school management and the MOE to improve learning performance with the commitment from government agencies to provide the necessary resources and the responsibility of schools to implement quality improvement activities with verifiable outcomes. In addition to school- based quality inputs, training and financing, this pillar will support the systematic collection and publication of school data for stakeholders, (i.e., parents, guardians and wards to make better informed decisions about the choice of senior secondary school to attend. The focus on math and science subjects is aligned with the government strategy to encourage these program areas throughout all education levels. The expansion of ICT wireless connectivity would also allow strengthened science, math and other subject education through digital content for teachers and students. Schools will have access to an education portal1 where teachers and students can utilize multiple online resources that are expected to support improved teaching and learning. ICT will be used for intensive in-service support to teachers to improve content knowledge as well as lesson plan preparation, teaching and learning aids, and videos on good teaching practices and classroom management. The portal could also serve as a platform for knowledge exchange with national and international networks and for participation in relevant discussion forums. The SEIP will provide connectivity to 200 secondary schools. As an intermediate result, completion rates in the targeted schools would be expected to increase. A longer term impact would be an increase in student achievement in science and math (as measured by performance in the WASSCE) which is a year 4 DLI. For this pillar, release of IDA credit funds would be linked to the achievement of the following DLIs: (i) annual publication of School Performance Report (DLI 5); (ii) School Performance Partnerships in beneficiary schools (DLI 6); (iii) improved skills in math and science among teachers and students (DLI 7); and (iv) improved information, communication and technology capacity in selected secondary schools (DLI 8). 2.2 Component 2: Management, Research and Monitoring and Evaluation This component aims to strengthen the implementation capacity of the Ministry of Education and Ghana Education Service and its related implementing agencies and assist them to achieve the objectives of the Government’s SHS strategy. This component will support monitoring and evaluation, coordination, planning, communication, financial management, procurement, and safeguards. In addition it will support an active and evolving research agenda to continue to inform Government SHS 1 Education portal is being established with funding from USAID, GoG and future support from the Ghana e- Transform project approved by the Bank Board on DATE, and expected to be effective by DATE. GSEIP-ESMF Page 12 policy, particularly with regard to financing, social targeting, quality initiatives, teacher rationalization, and curriculum relevance. This component would complement implementation of the program pillars with ongoing analyses, strengthening data collection for school mapping, and establish priorities for new construction, renovations and maintenance. The establishment of a web platform for school reporting and real time monitoring of all SHS implementation activities would enhance and strengthen the Education Management Information System (EMIS) and ongoing school mapping in order to help government report on achievement of results. In addition, funding will be provided to support the independent verification of disbursement linked indicators and achievement of results. Support would also be provided to help the MOE to design and realize policy reforms, including piloting and evaluating innovative approaches. This component would finance training, recruitment of short and long-term technical experts, procurement of goods needed for specific activities, and incremental operating costs. 2.3 Description of Civil Works The project will be implemented in selected administrative districts as identified by the Ministry of Education using specific selection criteria based on education indicators and poverty data. Most of the planned activities would be located at the district and school level. A number of districts will be identified for new construction of SHS. The Government has already identified the first fourteen (14) districts undergoing new construction projects in those districts with no SHS. Of the new construction projects, 10 of them are to be located in newly created districts while 4 will be in existing districts with no SHSs. Additional districts will also be selected based on the selection criteria during the implementation of the project (estimated at another 10 districts). The new construction projects will require the acquisition of land parcels at the respective locations, which are expected to be approximately 10 acres (4.16 ha). Schools that run agricultural programs will require additional land for demonstration or practical lessons. Civil works under the project will comprise the construction of a classroom and laboratory complex, a headmaster’s residence, an assistant headmaster’s residence, staff residential quarters, an open sports area, a multi-purpose hall and an administration block. In addition, a number of districts will focus on rehabilitation or add-on projects to existing low performing schools. These districts would be selected based on meeting the criteria of those with capacity for expansion, school age population not attending SHS, and low performance in standardized exam in addition to a needs assessment which will determine level of deficiency (bathrooms, science labs, computer facilities, etc.) and scope for upgrading. These civil works would not require the acquisition of land parcels. The selection criteria for the beneficiary communities are i. District size (weighted 30%), ii. Capacity to absorb JHS graduates (weighted 40%), and iii. Poverty level of the beneficiary district (weighted 30%), in line with government policy to target support and resources to reduce poverty. The design concept for the new construction has environmental enhancements such as wide windows that allow natural lighting and ventilation, rainwater harvesting, and the inclusion of solar photovoltaic cells to generate electric power especially for the laboratories. On the side of gender considerations, there is the inclusion of changing rooms in the toilets for girls who may need to change or freshen up during their monthly menses. This is a concern for many young girls, some of whom stay out of school for days during their monthly menses. The provision of a changing room with running water at the female washrooms will address this concern. 2.4 Implementation Arrangements As with previous education projects, a Project Steering Committee comprising the Ministry of Education, the Ghana Education Service and the Ministry of Finance will provide oversight on the project’s GSEIP-ESMF Page 13 implementation activities. During the initial implementation phase, the PSC will meet on a monthly basis to provide the necessary boost to the project’s implementation. Subsequently, the PSC will meet each quarter to provide guidance and to help resolve key implementation bottlenecks. The implementing agency will be the Ministry of Education in close collaboration with the Ghana Education Service. The MOE will be responsible for the project’s coordination, procurement and contract management, financial management, and oversight of environmental and social due diligence. The M&E unit in Ministry of Education and the Ghana Education Service will be responsible for all sector level monitoring and evaluation under the SEIP. The Ministry of Education (MOE) is responsible for policy formulation, programming, coordination and monitoring and evaluation in the education sector. At the head of the MOE is the Chief Director who leads the technical team and who reports to the Minister for Education. The Ministry of Education will be responsible for Pillar 1 of the SEIP specifically programming, coordinating and supervising with the assistance of relevant units, the expansion of senior secondary schools in order to increase access with equity in upper secondary education in underserved districts. The responsibility of the MOE includes: (i) coordination and support of all implementing departments of the SEIP; (ii) reporting on progress against the indicators and DLIs, EEP and TA; (iii) ensuring timely and comprehensive reporting of results for disbursements; including Withdrawal Applications; (iv) ensuring that Bank fiduciary (financial reporting, procurement) and safeguard regulations and requirements are followed; (v) ensuring timely communication to all stakeholders on the SEIP progress; and (vi) managing and coordinating the Technical Assistance component with relevant departments. A newly instituted Project Management Team comprising the Infrastructure Coordination Unit and the Project Management Consultancy will coordinate all construction and facilities improvement under the project. The Regional and District Directorates for Education will be responsible for supervising all senior secondary school related interventions with respect to senior secondary institutional heads and will monitor the activities of senior secondary schools in their districts and regions. The Ghana Education Service will oversee all activities including senior secondary subject teacher training, institutional leadership training, preparation of school partnership for quality plans, resourcing of schools for quality improvement, improvement of mathematics and science teaching, improvement of senior secondary school programs, ICT interventions, monitoring and evaluation, as well as school standards adherence and quality assurance. Figure 2.1 below presents the implementing structure for the SEIP. GSEIP-ESMF Page 14 Figure 2.1 SEIP IMPLEMENTATION ARRANGEMENTS Institutional Responsibilities Task Institution(s) Responsible PRESIDENCY - Hon Minister (CHAIRPERSON) Hon Deputy Minister (Pre-tertiary)- (VICE-CHAIR) The Chief Director (MoE) Ministry of Finance (representative) MLGRD (representative) PROJECT STEERING COMMITTEE MGCSP (Representative) Director Finance (MoE) DG- GES Head of Project management Team (Technical Coord.) Head of Results Based Team (Results Based .Coord.) Chief Director Representative of MOF Project Financial Manager Project Supervision Consultant Hd. Procurement DG- GES Head of National Office (WAEC) PROJECT IMPLEMENTATION Government Statistician (Representative) COMMITTEE Land Valuation Division/EPA/Lands Commission Exec Sec National Teaching Council Exec Sec National Inspectorate Board Exe Sec National Council for Curriculum Assessment Project Management Team (FPMU, ICU, PMC) Result-Based Team (SRIMPR, PBME, GES, Regional Coordinating Director Regional Director of Education REGIONAL EDUCATION OVERSIGHT Regional Planning Officer COMMITTEE Regional Engineer MCE/DCE District Director of Education DDE DISTRICT EDUCATION OVERSIGHT District Engineer COMMITTEE District Planning Officer An independent evaluator in collaboration with the DAs, RCCs, and Land Valuation Board Headmaster/mistress/Assistant Head School Board Chairperson, PTA Chairperson Representatives of School Board SCHOOL MANAGEMENT Areal Council (representative) SRC President. GSEIP-ESMF Page 15 The Ministry of Education will have overall responsibility for achieving outcomes and agreed Disbursement Lending Indicators (DLI) under the project and be responsible for implementing the results-based Component 1 (US$135 million) of the project. The Ghana Education Service will be responsible for implementing Component 2 (US$20 million). Implementation will be through existing disbursement, funds flow and financial management arrangements from the Budget office of the MOF with execution management and control of the budget within the MOE. The accounting and reporting of expenditures will use country financial management systems within the MOE. The MOE/PBME and GES will be responsible for coordinating and overseeing all M&E activities under the SEIP. The project’s M&E framework will build upon established systems and will strengthen the Government’s capacity to routinely collect, analyze and verify education data from schools, regional authorities, district education offices and budget offices. The MOE/PBME will be responsible for providing the following: (i) status reports on project implementation by activity, including summary description of outputs and outcomes achieved at the school- and district levels (annually) (ii) status reports on the progress made on all PDO and intermediate-level indicators specified in the RF; (iii) and level of achievement for the various milestones within each DLI; and (iv) consolidated annual progress reports. GSEIP-ESMF Page 16 3.0 RELEVANT LEGAL AND INSTITUTIONAL FRAMEWORK This section provides an overview of relevant policies, laws and regulations specifically addressing this education sector project. It focuses first on the environmental legislation, the land administration and then the pertinent planning and other related PLRs. 3.1 Ghana’s Environmental Policy Ghana’s National Environmental Policy aims at ensuring a sound management of resources and the environment and to avoid any exploitation of these resources in a manner that might cause irreparable damage to the environment. The policy endorses the preventive approach to environmental management and emphasizes the need to promote socio-economic development within the context of prescribed acceptable environmental standards and safeguards. In effect, it seeks reconciliation between economic planning and environmental resource development with the view to achieving sustainable national development. The Policy Statement seeks among other things:  to ensure environmentally sound use of both renewable and non- renewable resources in the process of national development,  to develop procedures for the utilization of land resources in a manner that would ensure the maximum degree of economy in the use of land and avoid or minimize conflicts, and  to institute and implement the concept of sustainable development by requiring prior environmental impact assessments of new investments and developments that would be deemed to affect the quality of the environment. 3.2 Environmental Protection Agency and Environmental Impact Assessment (EIA) The Environment Protection Agency (EPA) was established under Section (1) of the EPA Act, 1994, Act 490. Consistent with Section 28 of Act 490, the Parliament of the Republic of Ghana, on 24 June1999, passed the Environmental Assessment Regulations, 1999, L.I. 1652 to regulate Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP) procedures, LI 1652. The trust of the Agency’s overall approach includes compliance promotion to facilitate good environmental practice and to seek co-operation and collaboration from those whose activities could potentially injure the environment. The fundamental principle underlying Ghana’s formal Environmental Impact Assessment (EIA) Procedures is the preventive approach to environmental management in which EIA is applied as a tool, especially at the project-specific level. EA is recognized and applied in Ghana to development projects as well as other undertakings as an environmental permitting pre-requisite and a major environmental management tool. The existing procedures have evolved over time since EA became a requirement in Ghana in 1989, to screen and evaluate all developments, undertakings, projects and programs, which have the potential to give rise to significant environmental impacts. The procedures establish an EA process of which one principal objective is the requirement to provide enough relevant information to enable the Environmental Protection Agency to set an appropriate level of assessment of any proposed undertaking, investment or program for the assessment for the necessary review and to facilitate the decision-making process for EA approval. The information may be gathered through an environmental impact assessment study and published in an Environmental Impact Statement (EIS), Preliminary Environmental Report (PER), or by completing an GSEIP-ESMF Page 17 Environmental Assessment Preliminary Registration, Form EA1 or EA2, depending on the complexity, nature, and location of the proposed undertaking. EPA is mandated by law to ensure compliance with laid down Environmental Impact Assessment (EIA) procedures in the planning and execution of development projects, including compliance in respect of existing projects. The basic objectives of the EIA system are to integrate environmental management and economic decisions at the earliest stages of planning an undertaking or investment and to provide avenues for the involvement of the public, proponents, private and government agencies in the assessment and review of proposed undertakings, among others. 3.3 Public Health Act Ghana does not as yet have a Public Health Act; however, it does have laws and regulations pertaining to the protection of the environment and health. These laws could be traced from the criminal code, ordinances, legislative and executive instruments, acts, bye-laws of the District Assemblies etc. Some of these laws include:  Law on Statutory Nuisances (Towns Ordinance Cap 86 of 1954), which deals with animals, overgrowth of weeds, overcrowding, waste disposal, street and premise cleansing, trades, vermin, water etc.  Criminal Code - Act 29 of 1960 (chapters 8 and9);  Mosquitoes Ordinance - Cap 75;  Vaccination Ordinance - Cap 76;  The Quarantine Ordinance - Cap 77;  Infectious Disease Ordinance - Cap 78 of 1908 amended in 1924;  Food and Drugs Law of 1992 (PNDCL 305b);  Bye-laws of the various Assemblies (e.g. Local Government Bulletin 1995 of the Accra Metropolitan Assembly);  Model Bye-Laws (by the Ministry of Local Government and Rural Development, e.g. Control of Restaurants and Eating Houses);  Registration of Births and Deaths – Act 301 of1965; 3.4 National Sanitation Policy The National Environmental Sanitation Policy aims at developing and maintaining a clean, safe and pleasant physical environment in all human settlements, to promote the social, economic and physical well-being of all sections of the population. The principal components of environmental sanitation identified in the policy include:  Collectionandsanitarydisposalofwastes,includingsolidwastes,liquid wastes, excreta, industrial wastes, clinical and other hazardous wastes;  Storm-water drainage; GSEIP-ESMF Page 18  Cleansing of thoroughfares, markets and other public spaces;  Control of pests and vectors of disease;  Food hygiene;  Environmental sanitation education;  Inspection and enforcement of sanitary regulations;  Disposal of the dead;  Control of rearing and straying of animals;  Monitoring the observance of environmental standards. These services, the policy noted, must be provided reliably and continuously to mitigate the negative effects of social and economic activity in human settlements. The policy also recognizes the importance of the legislation, technical and human resource capacities, the roles of various institutions, the community and the private sector in the delivery of sanitation services. The Ministry of Local Government and Rural Development is in the process of consultation to start implementing the policy. The formulation of clearly defined waste management and sanitation policy seeks to achieve the objective of protecting public health and improving the quality of life. The benefits of such policies are fully realized when all sectors of the economy are fully served with appropriate sanitation facilities. Once all sectors of the population are served with basic level of sanitation, incremental improvements can be made, as economic development provides funding and/or as public perceptions change. 3.5 Planning Policies The Town and Country Planning Ordinance 1951 (Cap84) is the principal legislation in force regulating the general planning and development of human settlements. Its principal object was: “the orderly and progressive development of land, town and other areas whether urban or rural for conserving and developing resources and to preserve and improve amenities thereof�. The Towns Ordinance, Cap 86 (1951) was also passed for the more efficient regulating of towns and promoting public health. Ghana is operating a new decentralized development planning system. The system is part of a wider public administration reform, which was instituted to improve the effectiveness of national institutions, administration, environment and development. The four underlying laws that give effect to the reforms and establish the new decentralized planning system are:-  The Civil Service law, PNDCL 327 of 1993.  The Local Government Act 462 of 1993.  The National Development Planning Commission Act 479 of 1994.  The National Development Planning (Systems) Act 480 of 1994. The new planning system establishes an institutional and administrative framework for providing and effecting national development, taking comprehensive account of socio- economic development in order to attain functional efficiency and environmental harmony. The current management of physical growth of urban areas is carried out through a system of: GSEIP-ESMF Page 19  Land use planning and management that provides a zoning framework to guide physical development;  Detailed technical examination and guidance of individual physical developments to conform to the provisions of approved land use plans and building regulations;  Delivery of basic settlement infrastructure and services by various agencies of central and local government. GSEIP-ESMF Page 20 4.0 DESCRIPTION OF THE ENVIRONMENTAL & SOCIAL IMPACTS AND MITIGATION MEASURES 4.1 Introduction This section deals with the main potential environmental and social concerns likely to arise from the construction and rehabilitation of buildings, water points and sanitation facilities under the Ghana SEIP, and their proposed mitigation measures. Work at the District levels across other World Bank sponsored infrastructure projects shows that issues such as community involvement, community ownership and selection of appropriate sites are some of the key concerns, which influence the success, and sustainability of such projects. That the project is a reimbursable process paying against results means that there is no traditional investment procedures (e.g., no objections) nor a PIU and the Bank will have to be provided verification that environmental and social provisions meeting Bank policy standards have been followed. This will require a due diligence checklist demonstrating that all World Bank Environmental and Social policy requirements are met. 4.2 Potential Environmental and Social Impacts The school project designs will require approximately 10 acres (2.41 ha) land take at each location for the construction of all facilities, including land for future expansion. Some schools that will run agricultural programs will require more. 4.3 Pre-Constructional Phase Pre-Construction Phase impacts have been identified as comprising the following. Their respective mitigation measures are also presented below Site Selection Sitting of project components within a community poses a whole range of problems which impact on project’s success and sustainability. Some of the key issues are:  Locating projects near cultural sites such as sacred groves and burial grounds, which could be regarded as insulting and frowned upon or shunned by the people.  Conflict with existing or proposed land use which could create problems of incompatibility  Conflict with nearby communities leading to tension in the use of the facility  Sitting facilities on land where the ownership is disputed  The population of the micro location of the school would have to be considered in order that the facility is not located in sparsely populated catchment areas.  Sufficient land area for facility installation and future expansion  Ecologically sensitive sites such as plains, which liable to flooding, aquifer recharge zone, which may be lost, steep terrain prone to erosion and threat to fragile habitat and endangered species. Land Acquisition As indicated above, the project designs require approximately 10 acres (2.41 ha) land take. (Some schools that will run agricultural programs will require more). It is envisaged that the beneficiary communities would donate land for the projects, which will be expected to meet the selection criteria outlined above. Thus, these could be prime lands that could be used for agriculture or some other GSEIP-ESMF Page 21 activity. In some cases, such lands may be occupied by some local farmers. Acquiring such lands would be at some costs to the beneficiary communities. Mitigation As per the Screening checklist, priority will be given to unencumbered land. However, wherever people are inevitably affected, the dictates of the World Bank OP 4.12 on Involuntary Resettlement will be applied. This will ensure that all project-affected persons are appropriately compensated and resettled prior to the commencement of the project. Involuntary Resettlement and Compensation The acquisition of such lands in the communities could engender involuntary resettlement for users of the lands. Such affected persons would need to be resettled on other suitable land and/or compensated, as the situation may determine. The acquisition of land for the construction of school buildings will not be financed under this project. Mitigation The dictates of OP 4.12 will be applied to ensure that all project-affected persons are appropriately compensated and resettled prior to the commencement of the project. Community Sensitization, Involvement and Ownership Not involving communities in projects that are benefited by them, usually leads to serious setbacks. If community involvement issues are not handled properly, they could create suspicion, tension and misunderstanding; eventually leading to beneficiaries not fully identifying with the project or in rare cases rejection or sabotage. The major issues to consider with regards to major obstacles to effective project implementation and sustainability are the siting, timing of construction work, and extent and level of involvement of beneficiary communities. Site Preparation and Leveling Preliminary site preparation involving clearing the site of its top vegetation and removal of top soil, to facilitate the setting out of the layout plan, usually provokes erosion particularly in areas of heavy rainfall and poor drainage, and could potentially reduce rain water percolation into the ground. Site leveling could interfere with the natural drainage pattern of the area. Storm water run-off could increase. This potential increase in runoffs could enhance erosion, which could cause silting of the natural drainage channel. This in turn could adversely affect the hydrological properties of the area and receiving streams, and could lead to flooding. The work of the surveyors could have effects on farms. They usually slash and clear their paths in carrying out their work. The selection of the site for the facility could also be on a farm of member(s) of the community. Site Clearing Lands at the project sites will be cleared of all vegetation to allow for the construction of the buildings. This would result in the loss of vegetative cover at the project area, and may expose the land to the elements of the weather. GSEIP-ESMF Page 22 Mitigation Vegetation clearing will be staggered; it will be done only at sites where construction work is ready to begin. This will limit the exposure of the soil surface to erosion and other factors. 4.3.2 Construction Phase Impacts Construction phase impacts will comprise the following:  Air quality impacts (Dust and Exhaust emissions)  Noise generation  Traffic Impacts  Occupational Health and Safety  Public Health and Safety  Solid Waste management  Liquid waste management These are briefly described below, with their proposed mitigation measures: Air Quality Impacts Dust generation from excavation and construction activities could compromise air quality in the project area, especially during the dry season. Exhaust emissions from construction machinery could also affect air quality via their exhaust emissions. Noise generation Construction activity could generate noise from machinery and equipment. Traffic Impacts Haulage trucks delivering building materials to site could generate traffic impacts by adding to vehicular traffic on roads serving the project area. Occupational Health and Safety Construction site workers will be exposed to risks of accidental collisions with moving vehicles, strains from repeated movements or from lifting and heaving of heavy objects, slips and falls, including falls from heights. Accidental cuts from tools and machines are also safety risks. Wet cement as a building material is corrosive on contact to with human skin. Public Safety Excavations, pits and heaps of unconsolidated material will be left overnight at the end of a working day at the construction site. These would make the construction site dangerous to stray animals and vagrants who might walk across the site at night. Solid Waste Generation GSEIP-ESMF Page 23 Construction activity will generate considerable amount of solid waste, include earth material, wood cut-offs, wood shavings, plastic cut-offs, empty cement sacks, paint cans etc. These would need to be appropriately disposed of. Liquid Waste Generation Liquid waste streams will include equipment wash-out after daily construction activity, and human wastes from construction workers. Table 4.1 below summarizes the identified environmental and social impacts and their proposed mitigation measures at the various phases of the project, assigns roles and responsibilities, and indicates the expected outcomes of the mitigation measures. GSEIP-ESMF Page 24 Table 4.1 Impact - Mitigation Table POTENTIAL PROPOSED MONITORING/ FOLLOW- PROJECT ACTIVITY ENVIRONMENTAL LOCATION MITIGATION NET EFFECTS ESTIMATED BUDGET UP MEASURE (S) IMPACTS/ACTIVITY Land acquisition Project site Site selection Project Management Suitable site criteria will be Team selected used. PRE-CONSTRUCTION Vegetation clearing Selective and PHASE. staggered Avoidance of vegetation will be exposure of done only when land surface to construction is erosion ready to begin. Air quality Project site and Areas to be Project Contractor Controlled dust vicinity excavated will be generation; doused with Reduced water to minimize exhaust dust emissions emissions CONSTRUCTION Regular PHASE Project site and maintenance of Noise vicinity machinery and PMT/Project Contractor Reduced noise equipment. impacts Restriction of Roads serving construction immediate activity to daylight project area hours PMT/Project Contractor Reduced traffic impacts Reduced Traffic impacts Project site Restriction of PMT/Project Contractor incidence of delivery of accidents and materiel to site to injuries. off-peak traffic hours. Use of traffic wardens to coordinate traffic flow Proper site Occupational Project site and PET/Project Contractor Reduced risk of sanitation and Health and Safety vicinity accidents and housekeeping. issues injuries to Provision and enforced use of public Public safety Project Contractor Project site PPE. Strict adherence to safety precautions Solid waste as per Factories, Project Contractor management Project site Offices and Shops Act, 1970 (Act 328) Liquid waste Cordoning off of Safe disposal of management pits and Project Contractor generated solid excavations with waste physical barriers and appropriate signages. GSEIP-ESMF Page 26 Employment and Project site Excess earthen Income material will be used in Safe disposal of landscaping. generated solid Waste skips will waste be provided to collect wastes for appropriate disposal at municipal disposal site. Equipment washout will be Safe disposal of discharged away generated liquid from water waste courses; mobile toilets will be provided for construction workers. Income Hired hands will generation earn some regular income to support themselves and their families. GSEIP-ESMF Page 27 Increased demand Project site and DA will ensure DA/Project Environmental Adequate on transport environs that transport Team transport infrastructure facilities and facilities and infrastructure are infrastructure. improved. Solid waste Waste skips will generation School site be provided for waste collection, to be evacuated School authorities/DEMC Proper sanitary by DA waste conditions on management school facilities compound. periodically. Liquid waste School site OCCUPANCY AND Provision and generation Proper sanitary MAINTENANCE maintenance of SEIP/School authorities PHASE suitable toilet conditions on facilities on school school compound compound. Security and Safety School site Engagement of Enhanced security personnel security on DEOC/School to protect school school administration facilities compound Run-off School site Installation of rain Reduced run-off management gutters to harvest SEIP/School authorities impacts rain into designated receptacles for use in toilets, laboratories. GSEIP-ESMF Page 28 Sources of Raw Materials Raw materials such as laterite and sand are won from engineered borrow pits where these materials are naturally available. Permits are required from regulatory agencies for accessing these materials, which also require some remediation works to be done at the borrow pits in order to mitigate environmental damage after winning the material. It will be the contractor’s responsibility to acquire the relevant permits for borrow sites, from where laterite and other earth materials for the construction activity will be won. This responsibility will be captured in Annex E Contractor’s Clauses. 4.3.3 Occupancy and Maintenance Phase Impacts Occupancy and Maintenance phase impacts would include:  Demographic changes and increased demand on social infrastructure in host communities  Traffic Impacts  Solid Waste generation  Liquid Waste generation  Security and Safety issues  Run-off management  Ground water depletion  Employment opportunities These are briefly described below. Demographic changes and increased demand on social infrastructure in host communities – Each school in the project is expected to have a population capacity of 1,000 students. As a community day school, it will draw its students from communities within a 5-kilometre radius of its location. A daily influx of such a population will affect the population dynamics of the host community and potentially impinge on community infrastructure and services, especially on transport facilities. Students from the surrounding communities will need to commute to and from school. Initially, this could create inadequacy and then opportunities for investors in the transport sector. Solid Waste Generation Paper wastes, food packaging and residues will comprise the bulk of solid wastes to be generated from the school. Liquid Waste Generation Liquid waste will comprise washroom wastes, as well as wastes from the chemistry laboratories. Security and Safety issues At the operational phase, the schools could attract thieves and social miscreants like robbers. The risk of fire outbreaks and other related incidents on the facility could present challenges to the safety and security of the school facilities. Run-off management The development of the school project will ensure that a considerable part of 10 acres of soil surface will be covered by materials impermeable to rain water. Roofs of the facilities and paved areas will reduce percolation and increase run-off within the project area. This could increase the risk of flooding in the project area. Groundwater depletion/Aquifer Recharge Sinking of wells and boreholes to draw water depletes groundwater aquifers, which are recharged naturally. Where abstraction rate exceeds the aquifer recharge rate, the aquifers could dry up, Withdrawal of large amounts of ground water causes porous formations to collapse resulting in subsidence. In such instances, changes in the topography could result in flooding. Employment Opportunities The project is expected to create employment for local artisans and manual laborers in the districts, where the facilities would be rehabilitated or built. The project will be expected to boost trade in construction materials such as cement, iron rods, lumber, etc. GSEIP-ESMF Page 30 5.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK 5.1 Introduction P il ar 1 u n der co m po n e nt 1 of the Ghana SEIP will be implemented by various organizations including Government agencies, District Administrations, Architectural firms, and Construction Contractors. The environmental concerns raised earlier therefore require that some aspects of project design and implementation and tender and contractual document preparation should be environmentally sensitive. The organization for the construction activities and implementation of the Ghana SEIP, under this section, are expected to screen for site selection; potential environmental and social impacts; mitigation of impacts; and to be able to outline steps for monitoring of potential impacts, with a process for triggering subsequent environmental and / or social assessments, where necessary. 5.2 Screening for Site Selection Screening for site selection is perhaps the most important task, apart from the design works, in the pre-constructional phase. In doing this, it is imperative to take into consideration the adjoining land uses to locate a School together with a water point and a sanitation facility. In general, technical considerations may limit the range of alternative sites for some components, particularly water projects. It is expected that all necessary studies, e.g. hydrological, climatic, soils etc., for relevant components will be carried out by appropriate authorities. However the following must be considered when sitting the new schools of the GHANA SEIP. Cultural Sites Avoid locating projects near cultural sites such as sacred groves and burial grounds and other places that may give offence to the people. Adequate Land Area Ensure sufficient land area is available for facility installation and future expansion Sanitation and Public Health Avoid sitting facilities near unsanitary locations, e.g. rubbish dumps, which might lead to outbreak and spread of infectious diseases. Pollution of Water Bodies The sanitation facilities should not be sited near water bodies. Conflict with Nearby Communities Involve nearby communities that might benefit from the facility in order to avoid conflict, which could lead to tensions in the use of the facility. GSEIP-ESMF Page 31 Population’s Impact on the Facility The population of the micro location of the facility (the communities in which the facility is constructed) would have to be considered in sitting the facility in order that it is not extremely under-utilized Ecologically Sensitive Sites Avoid ecologically sensitive sites such as flat plains, which are liable to flooding, aquifer recharge zones, which may be lost, steep terrain prone to erosion and areas that pose threat to fragile habitats and endangered species. Conflict with Nearby Land Uses It is important to avoid sitting a primary school close to other land uses, such as major highways, hospitals, quarry, etc. that may impact negatively on the pupils or vice-versa. Available Land Ensure that there are no existing land disputes pertaining to the existing site and that no involuntary acquisition of the land is required. 5.3 Screening for Potential Environmental and Social Impacts Under this section those responsible for the construction and implementation of the component 1 of the Ghana Secondary School Project are expected to screen for potential project impact as per t h e checklist. The potential project impacts as per the mentioned checklist include the following:  Farm Lands: Are there farm lands in the project area? Will project result in more or improved farm lands? Will projects result in loss or damaged farm land?  Soil Erosion: Will project help to prevent soil loss or erosion? Will project directly cause or worsen soil loss or erosion? Could project indirectly lead to practices that could cause soil loss or erosion?  Slope Erosion: Does project involve modification of slopes? Will project affect stability of slopes directly or indirectly? Could project cause people or property to be located where existing unstable slopes could be a hazard?, and Is it necessary to consult a geotechnical engineer?  Surface Water Quantity: Do surface water resources exist in project area? Is information available on present and future demands on water resources as a result of the project? Will project help to increase or preserve available surface water supplies? Will project increase demand or cause loss of available surface water? Is it necessary to consult a hydrologist?  Surface Water Quality: Is current data available on existing water quality? Will project lead to additional natural or man-made discharges into surface water? Will project help to improve or protect surface water quality? Could project cause deterioration of surface water quality and Is it necessary to consult a water chemist?  Ground Water Quantity: Do ground water resources exist in project area? Is information available on demands on ground water resource as a result of the project? Will project help to increase or preserve available ground water supplies? Will project increase demand or cause loss of available ground water? Is it necessary to consult a hydrologist?  Ground Water Quality: Is information available on present water quality?, Will project cause any natural or man-made discharge into ground aquifer, Will project help to improve or protect ground water quality, Could project cause deterioration of ground water quality, and Is it necessary to consult a to consult a chemist or hydrologist? GSEIP-ESMF Page 32  Air Quality: Is information available on existing or quality?, Will project produce any air emission directly?, Will project help to reduce existing air pollution sources?, Could project lead to practices that worsen air quality, Could project lead to a change in engine or fuel use that could cause serious air problem ?, Is it necessary to consult an air quality specialist?  Noise: Is noise now a problem in project area? Will project help in reducing undesirable noise conditions? Will project cause increases in noise generating conditions? And Could project cause movements of people to high noise level locations  Aquatic Ecosystems: Are there any aquatic ecosystems in the project area such as rivers, streams, lakes or ponds which might be considered significant? Will project affect the use of these systems for human consumption?  Wetland Ecosystems: Are there any wetlands ecosystems in the project area such as marsh, swamp, flood plains, or estuary which might be considered significant? Will project affect the use or condition of such wetlands?  Terrestrial Ecosystems: Are there any terrestrial ecosystem in the project area such as forest, savannah, grassland or desert which might be considered significant, Will project affect the use or condition of such system  Endangered Species: Is the existence of endangered species in the project area known? And Will project affect the habitat of any such species  Natural Habitat: Is the project degrading, removing or converting any natural habitats which include forested areas, and other habitats for wildlife?  Migratory Species: Do migratory fish, birds, or mammals use the project area? Will project affect the habitat of such species?  Beneficial Plants: Do non-domesticated plants occur in the project area, which are used or sold by local people? And will project affect these species by reducing their habitat in any way?  Beneficial Animals: Do non domesticated animals occur in the project area, which are used or sold by local people and Will project affect these species by reducing their habitat in any way  Pest-Plants and Animals: Are there currently any problems with pest (plants or animals) in the project area? Are there any plants or animals in the area, which might become pests because of ecological changes brought about by the project? Will project improve increase he habitat for such species?  Disease Vector: Are there known diseases in the project area transmitted through vectors? Will project increase vector habitat? Will project decrease vector habitat or provide opportunity for control?, Are there clinics or other disease control programs in operation or planned for the area?, Is it necessary to consult a public health officer?  Resource / Land Use: Is the land owned/leased by the project proponent?  Are there any known disputes on the land? Will the land be acquired by the government? Are lands in the project area intensively developed? Will project increase pressure on land resources? Will project result in decreased holdings by small land owners? And should a land use planner be used?  Distribution Systems: Will project enhance the equitable distribution of agricultural and/or manufactured products? Will project increase demand for certain commodities within or outside the project area? Will project result in decrease in production of certain vital commodities?  Employment: Will the project increase employment? And will project remove job opportunities from the area?  At-Risk Population: Are the adverse impacts of the project unequally disturbed in the large population? And have the at-risk groups been identified?  Existing Population: Are there currently any people living in or near the project area? Will project affect people in or near the project area? Has liaison been established with the community? Will community participation in projects design and implementation be necessary? Is it necessary to consult a sociologist? GSEIP-ESMF Page 33  Migrant Populations: Are there currently any mobile groups in the target population? And is it necessary to consult a sociologist?  Cultural and Religious Values: Is it necessary to consult a sociologist? Are there special superstitions or taboos that will affect acceptance of the project?  Tourism and Recreation: Is there at present a significant degree of tourism in the area? Is there unexploited tourism or recreation potential in the area? Will project adversely affect existing or potential tourist or recreation attractions? Undertaking the identification of the potential project impacts as explained above would facilitate the filling of EPA’s Environmental Assessment Preliminary Registration Form EA1. Those responsible for the screening process would be provided with training on how to fill the forms and on Environmental Impact Assessment procedures. It must be mentioned that based on the information gathered during the screening exercise and provided on the EPA’s EA1 Form, the EPA officers would visit the proposed project sites to assess the adequacy of the information provided and also the appropriateness/suitability of the selected site, among others and they would decide whether to give approval at this stage or require further analysis in the form of Preliminary Environmental Assessment or a more thorough assessment in the form of a complete Environmental Impact Assessment. In the case of the Preliminary Environmental Assessment, a less detailed form of EIA, which leads to a Preliminary Environmental Report (PER). The Terms of Reference (TOR) are determined by the EPA. For the Environmental Impact Assessment (EIA), detailed study based on an initial scoping report is to be carried out on TOR agreed with the EPA. 5.4 Mitigation of Impacts The proposed measures to mitigate the potential impact of the implementation of the Ghana SEIP components have been prepared in the form of guidelines. The guidelines are provided to ensure that good environmental practices are adopted to avoid and/or limit adverse consequences from the proposed interventions. Some of the guidelines given below are of a general nature, applicable to all components, while others are component specific. These guidelines are not exhaustive, project implementation should be guided by experience and knowledge gained from other projects. 5.5 Guidelines for Community Involvement Selection of Contact Persons Efforts should be made to identify opinion leaders particularly those who appear to catch the vision and can assist in sensitizing the people. This however is the prerogative of the implementation committees. They should be on the lookout for opinion leaders, who could be employed to sensitize the rest of the community members. Contact should be made, as much as practicable, with all groups that would be affected one way or the other by the project, i.e. school leavers, parents, women groups, Community Based Organization (CBOs), teachers, members of the District Assembly, traditional authorities, and school management committees. In doing this, gender balance has to be ensured in order to promote dialogue and capture the inputs of the women in the beneficiary communities. These groups would assist in the sensitization process. GSEIP-ESMF Page 34 Community Sensitization Selected beneficiary communities should be educated on aspects of the intended intervention well ahead of time. This should include the benefits, problems and financial implications among others. Animation, film shows, drama and posters are some of the methods that could be used to educate the people. Community participation/involvement is a vital issue that has been identified to ensuring sustainability of any project. Most of the communities targeted by the Ghana SEIP are among the most deprived in the country. This makes it more meaningful that they identify themselves with the project and its success by ensuring that assistance is provided to sitting and constructing of the project’s components and to teachers, who would work in the establishment. Steps should thus be taken to sensitize and involve the beneficiary communities from the start of the project. Conflict Resolution All issues of conflict and misunderstanding identified prior to implementation should be exhaustively addressed. The tendency of using the Project itself as a means of overruling potential conflict and misunderstanding should be avoided. 5.6 Guidelines for Project Site Selection The site selection of the project components is perhaps the most important stage, except for the construction work. Here, consultations should be made with the District Environmental Management Committees (DEMC), the Land Commission and the Water Resource Commission. The guidelines for site selection of projects should consist of the following:  Avoid locating projects near cultural sites such as sacred groves and burial grounds and other places that may give offence to the people.  Avoid sitting facilities near unsanitary locations, e.g. rubbish dumps, which might lead to outbreak and spread of infectious diseases.  The sanitation facilities should not be sited near water bodies.  Involve other nearby communities that might benefit from the facilities in order to avoid conflict, which could lead to tensions in the use of the facilities  The population of the communities in the catchment area would have to be consulted in sitting the facility in order that the it is not extremely under-utilized  In considering the catchment area, the sustainability of enrolment over the years should also be looked at.  Ensure that the project site has sufficient land area for the construction of all the project’s components, facility installation and for future expansion, if necessary.  Avoid ecologically sensitive sites such as flat plains, which are liable to flooding, aquifer recharge zones, and steep terrain prone to erosion and threat to fragile habitat and endangered species.  Avoid sites close to other land uses, such as major highways, hospitals, quarry, etc. that may impact negatively on the pupils or vice-versa.  Do not use involuntary land acquisition that will negatively impact people’s livelihoods and avoid sites that are subject to land ownership disputes. GSEIP-ESMF Page 35 5.7 Guidelines for the Timing of Constructional Activities Some of the construction work e x p e c t e d under the Ghana SEIP would require community labor involvement, especially in the rural areas. In order to ensure availability of labor the following points should be considered.  Cultural and Religious Activities – Some religious and cultural activities may engage the attention of the people over an extended period of time, such periods should be avoided as much as possible.  Seasonal Migration – Periods and seasons when some of the people migrate out of their communities to seek employment elsewhere should be factored into the planning.  Favorable Climatic Conditions – Activities requiring extensive excavation work like water projects must be timed to coincide with periods of conductive climate. In some areas, especially northern Ghana, the rainy season renders inaccessible parts of the regions, thus construction work has to be planned in the dry season. 5.8 Guidelines for Construction Work The mitigation measures for the environmental concerns raised with regards to the construction of the building and general construction work of the other components have been addressed as follows:  Erosion during Constructional Phase – The site should not be cleared and left unused for a long time. The contractors are to ensure that the site clearance, topsoil removal, compacting, cutting and filling, and foundation construction follow each other in order to avoid or minimize the incidence of erosion. The construction work could also be timed to avoid the rainy season.  Erosion during Operational Phase – Steep areas are generally prone to erosion. Lands selected for project components should be level or have minimum slope. Where this is unavoidable due to the terrain, the surrounding of the project’s components should be covered with green grass.  Destruction of Farms - The issue of destruction of farms falls under Ghana’s Land Policy, which stipulates that prior agreement of compensation payment with the potential affected parties has to be reached even before setting off to survey the sites and for construction work to begin. It must be mentioned that the user of a farmland, whether he/she is owner of the land or not, should be compensated. The compensation must be an amount not less than replacement cost including cost of labor.  Destruction of Natural Habitats- The project should not destroy or convert any natural forest or other natural habitat to ensure that the Bank’s Safeguard on O.P 4.04 is not triggered. Selected areas should therefore assess this potential risk before site selection is finalized.  Risk of Water Body Pollution – One part of this issue is related to erosion, which has already been addressed. With regards to human activities, especially indiscriminate defecation and disposal of waste materials, the contractors engaged in the construction activities should have on site mobile toilet facilities and garbage cans and ensure that their workers do not resort to free ranging and indiscriminate dumping of rubbish.  Resettlement and Compensation – Any person or group of people to be affected by the project in the form of loss of farms, houses and other landed property should be compensated or resettled. It must be mentioned also that any people that due to the project, lose access to natural resource, income, or livelihood should be compensated, and that users of land, regardless of the owners, should also be compensated. It is the policy of the Government of Ghana to pay compensation to people, whose properties, lands or landed property are affected by projects being undertaken by the Government. GSEIP-ESMF Page 36 The State Lands Act 1963 section 6(1) provides that any person, whose property is affected by public projects shall be entitled to compensation. The same Act provides avenues for people, who are not satisfied with the compensation to seek redress. Although the Lands Act provides for payment of compensation and resettlement of displaced people, whose lands or landed property are affected by projects being undertaken by Government, where there are gaps or discrepancies between the Land Act and the World Bank Policy, the World Bank Policy would apply.  Burrow Pit – Excavating for laterite, sand and gravel create stagnant water bodies in borrow pits. These become habitats for breeding of mosquitoes and other diseases vectors. Methods of control include filling, draining and improved landscaping.  Drainage Interface and Water Quality - Site selection is to be done properly to avoid interference with the natural drainage pattern of the project area.  Source of Raw Materials - The project consultant should ensure that the contractor procures building materials such as sand, stones, and laterite from licensed and approved sites. The contractors should be urged not to employ chain-sawn lumber in the construction of any of the components of the project.  Noise - Ear protection gadgets are to be provided to workers on the construction site, who would be exposed to high noise intensities  Dust –. The impact of dust generation from construction work is more of a residual problem. However, during construction, efforts should be made to reduce dust impacts by frequent watering, providing of dust masks for workers and undertaking good work practices.  Operation / Maintenance and Odor - Good housekeeping of sanitation facilities e.g. KVIP, VIP, Pit Latrine, and Pan Latrine is to be enshrined in the operations of the school, and to be carried out either by the pupils or by a private company in order to ensure the facility’s sustainability  Quality of Work and Workmanship Specification - All building works contracted for the Government of Ghana are to be executed according to the General Specification for Building Works published by the Government of Ghana in November 1995. These specifications are Ghana Standard Board and British Standards specifications. The MMDAs are to ensure that the contractors apply, as applicable, the guidelines prepared herein for the mitigation of impacts, in order to achieve quality of work.  Quality of Materials - All the materials to be used in the construction of the project components are to be new, of best quality and manufacture and in accordance with the current British Standard and Ghana Standard Board specifications, where they exist. Where they do not exist, samples are to be provided for tests to be carried out on the materials. When samples have previously been submitted and approved, all subsequent deliveries should be in accordance with the sample.  Storage of Materials - The materials would have to be stored under cover clear of the ground and protected from dampness and the weather in such a way as to prevent decay or attack by fungus or insects.  Supervision of the Works - Supervision of the works would be done by the District Implementation Committees in order to have proper control of the construction of the components of the project. This is further mentioned in the Guidelines for Institutional Framework.  Selection of Types of Project Component’s Design - The design of the project components and the selection of types of water points and sanitation facilities are to be carried out in conjunction with or by the District Assemblies and District Implementation Committees. The DAs have their developmental plans and know, for example, which communities would be served with pipe borne water within a year. This proposal is also to avoid the selection or design of impractical project components, which could be imposed on the beneficiaries. GSEIP-ESMF Page 37  Disease Vectors – These are associated with the tiny impoundments and wet patches that form near wells and boreholes and recommended preventive measures include: Avoidance of stagnant little ponds or wet patches round the water points, preventing users from washing their hands, pans, feet, or clothes, etc. close to the water point; and Disease prophylaxis.  Security – The water points must be protected to prevent misuse, accident and intentional pollution. Wells and boreholes should be secured by raising concrete barrier structure and provided with cover and lock. The sanitation facilities must be secured by lock when the schools are not in session.  Pollution of Surface Water - The site of the construction of sanitation facility would be properly selected to avoid low lying areas, and drainage pattern or water flow paths in order to avoid overflows in the case of flooding of the area.  Groundwater Depletion / Aquifer Recharge – This is relevant for wells and boreholes. Design considerations should ensure that abstraction rates are consistent with natural aquifer recharge. Consultations with the regional CWSA would provide information on the aquifer recharge.  Groundwater Contamination - Work on the septic tanks and pits would have to be carried out professionally and to the highest quality to avoid contamination of groundwater during the constructional phase, and leachate into groundwater during the operational phase.  Groundwater Quality – Water is intended for human consumption and should be subjected to quality analysis by the Community Water and Sanitation Agency (CWSA) to determine, whether it meets the required standards before giving approval. Supposing the groundwater does not pass the standard tests, CWSA would advise on exactly which steps to take. It is imperative to mention that during the operational phase regular quality analysis has to be carried out to ensure that the water meets the set standards.  Occupational Hazards and Public Accidents at Project Sites Materials and equipment used for the construction of the project components should be marked to explain visually their potential impact. The workers should always use helmets on the site. The construction areas for the water points and sanitation facilities should be marked and delimited in order to avoid accidents. Reasonably practicable precautions are to be taken and instructions given in the identification, use, handling, storage, transport and disposal of hazardous substances, e.g. petroleum products on the construction site.  Odor - Good housekeeping of sanitation facilities e.g. KVIP, VIP, Pit Latrine, Pan Latrine, Aqua Privy, and WC is to be enshrined in the operations of the school, and to be carried out either by an employee of the DA or by a private company in order to ensure the facility’s sustainability.  Flies and Pest - Good housekeeping of sanitation facilities e.g. KVIP, VIP, Pit Latrine, and Pan Latrine is to be incorporated into the maintenance schedule of the school, and to be carried out either by the pupils or by a private company in order to prevent the proliferation of flies and pest.  Operation/Maintenance – The management and maintenance of the components of the project would be in the hands of the District Assembly through the District Directorate of Education. Spare parts for the Water points would have to be made available, as they are difficult to come by in the rural areas. It should be the responsibility of the DA to see to the management and maintenance of the sanitation facility.  Danger of Explosion - A ventilation tube with the right height, would have to be incorporated properly in the design of the sanitation facility in order to diffuse the generated gases in the pits and the septic tanks. It would also have to be included in the contract’s technical specification. GSEIP-ESMF Page 38 6.0 ENVIRONMENTAL AND SOCIAL ADMINISTRATIVECONSIDERATIONS This section describes the environmental and social management framework and the environmental guidelines for avoiding and or preventing the adverse environmental and social impacts of the project activities. Institutional setup for implementing the ESMF, roles and responsibilities of the focal persons, monitoring mechanisms, and training and capacity building programs have also been detailed in this section. 6.1 Institutional Arrangement and Responsibilities Oversight of the SEIP implementation will be in the Ministry of Education (MOE) with the Ghana Education Service providing their mandated implementation role for service delivery. This section deals with the relevant institutional arrangements–existing and proposed –which would facilitate environmental and social soundness and sustainability. 6.1.1 Project Oversight A Steering Committee and Project Management Team of the MOE will be established to coordinate and oversee implementation. The Project Steering Committee (PSC) will:  Provide guidance on strategic, policy and implementation issues;  Coordinate activities of the ministries, agencies and other stakeholders involved in the project implementation;  Review and approve annual work plans, budget and annual reports;  Review and discuss quarterly and annual project progress reports and make necessary recommendations; and  Assess the progress towards achieving the project’s objectives and take corrective action if necessary.  Resolving cross-sectoral and issues above the Project Management Team. The PSC will be chaired by the minister of MOE or his/her designee. The PSC will include representatives at the chief director level for the ministries and at the director levels for the agencies of relevant ministries and institutions and civil society organizations, including: (i) Ministries of Finance; and Ministry of Local Government and Rural Development; (ii) Ghana Statistical Service; Environmental Protection Council; and West African Examination Council; (iii) Civil Works Contractors Associations; and Ghana National Education Campaign Coalition. The PSC will meet quarterly to assess the project implementation progress on the ground and undertake site visits as necessary. 6.1.2 Project Management Team The Project Management Team will derive from the Project Implementation Committee at the national level (see figure). The PMT’s main functions (i) assume project control, (ii) monitor the actual construction of work executed in the four (4) zones of the country namely: Zone 1- Northern, Upper East and Upper West regions; Zone 2- Ashanti and Brong Ahafo regions; Zone 3- Central, Western and Greater Accra regions; and Zone 4- Volta and Eastern regions; (iii) review reports submitted by the supervising consultant on a zonal basis and bring up issues to the Project Implementation Committee for resolution; (iv) liaise with the District Assemblies to ensure their full participation in the supervision of the project; (v) prepare and update the schedule of activities/procurement plans to be executed under the project; (vi) vetting claims submitted by the consultants on behalf of the contractors; (vii) vetting GSEIP-ESMF Page 39 consultancy claims submitted by the supervising consultants; (viii) agree on design modification to suit topography of the land; (ix) prepare bi-monthly briefs to the Ministerial leadership; (xi) follow up and ensure that contractors and consultants are paid for properly prepared claims; (xii) review any recommendations for the payment of fluctuations/variations and for advice to the PSC; (xiii) take over completed structures and commission them for usage by the schools; and (xiv) accompany Ministerial leadership on monitoring in the respective zones. The PMT will include the following:  2 environmental and social safeguards consultants  1 procurement specialist (MOE)  1 technical advisor (MOE)  4 architects (FPMU + 3 others)  4 quantity surveyors (FPMU, GETFund and 2 others)  4 civil engineers (FPMU + 3 others)  1 electrical engineer (on retainer basis  Project management consultancy firm (providing the others) Figure 6.1 below is a tabular arrangement of the institutional arrangements and responsibilities for environmental assessment and resettlement. Figure 6.1: Institutional Arrangements/Responsibilities for Environmental Assessment and Resettlement Institutional Responsibilities Task Institution(s) Responsible Project coordination and - Project Steering Committee (PSC) management - Project Management Team - District Education Oversight Committee - School Management Implementation and monitoring of - PMT (E&S Consultants) ESMF and RPF - DEOC (including Land Valuation Division) - Environmental Protection Agency (EPA) Determination of affected persons - PSC and compensation levels - PMT - DEOC Payment of compensation - PMT - DEOC Dispute resolutions - DEOC GSEIP-ESMF Page 40 District Level. District Assemblies (DAs) are empowered under Act 462 of 1993 to be responsible for development, improvement and management of human settlements and the environment in their districts. In order to facilitate the work of the DAs in this regard, the District Education Oversight Committee (DEOC) which includes the (i) MCE or DCE; (ii) District Director of Education; (iii) District Engineer; (iv) District Planner; (v) District Environmental/Social Officer; and (vi) representative from the Land Valuation Division of the Lands Commission will have responsibility for the project implementation in collaboration with the beneficiary communities. The District Environmental/Social Officer will be responsible for site screening and reporting to the DEOC. There will be the need for capacity building at the DEOC level. The District Engineer will lead in the monitoring and supervision of contractors and recommend the signing of work certificates against work done. Role of DEOC The key functions envisaged for the DEOCs with regard to environmental issues are:  Responsible for liaising with EPA and other relevant agencies  Work with project environmental consultants (PM Consultancy) when required  Responsible for registering all project components within the zones with the EPA, including completing Form EA1, any other documentation, and/or the attached project environmental screening checklist.  Ensure compliance with all recommendations by EPA and other regulatory agencies  Play a lead role in site selection for relevant SEIP components within the district and initiating collation of baseline data  Inspecting and Monitoring of environmental components of pre- constructional, constructional and operational stages and providing the PMT with reports on a regular basis. Figure 6.2 below illustrates the organizational structure of the DEOC. STEERING COMMITTEE PROJECT MANAGEMENT TEAM MCE/DCE DEO C LAND DISTRICT VALUATION DISTRICT DISTRICT DISTRICT ENVIRONMENT BOARD ENGINEER. PLANNING DIRECTOR AL OFFICER OFFICER. FOR EDUCATIO N GSEIP-ESMF Page 41 The following table outlines the institutional setup for timely identification and reporting of the environmental issue relating to the SEIP and for taking necessary preventive or corrective measures at the national and district levels of responsibility under the ESMF: Organizations and Focal Persons for ESMF Implementation Organization Role Focal Person Jurisdiction Project Responsible for Environmental and Ministry of Management implementing various Social Safeguards Education Team activities required for Consultants (to be safeguard compliance recruited) under the ESMF and RPF. District Education Responsible for project District Respective Oversight implementation in Environmental/Soc Districts Committee collaboration with the ial Officer beneficiary communities as well as site screening and reporting to the DEOC. The two environment consultants to be recruited as part of the PMT will be required as part of their TOR to strengthen the capacity of the DEOC. 6.2 Environmental Enhancement pertaining to Design The environmental and social enhancements pertaining to project design include (i) wide windows to optimize natural lighting and ventilation; (ii) rain water harvesting facilities capturing rainwater for use and mitigating the effect of run-offs; and (iii) inclusion of solar photo-voltaic cells to generate power for use in the laboratories. The primary objective of the guidelines is to optimize the use of green technology to minimize project footprint. 6.3 Internal Compliance Monitoring Compliance to environmental and social guidelines will be effected through an internal compliance monitoring mechanism comprising the channels, as described below: 1. The head of institution being the environmental moderator at the school site level will ensure observance of the ESMF guidelines at the construction and operational phase. He/she approaches the contractor to do the right thing as the first level of resolution. The next level is to bring the issue to the attention to the DEOC through the District Director of Education. 2. The DEOC of the respective districts will make routine as well as surprise visits to the schools during construction/rehabilitation as well as occupancy phases of the project. They will act on resolving issues and will submit their monitoring reports to the PSC. 3. The DEOC will process monitoring reports and forward the consolidated report of the district to the PMT for decision making. The PMT will analyze and summarize the report for the information and guidance of the PSC. GSEIP-ESMF Page 42 4. The PMT will engage the services of an independent auditor (technical audit) to provide final completion reports. Each completed school project will submit to MOF the E&S Due Diligence Checklist (annex xx), which will serve as the evidence of compliance with all national and equivalent World Bank safeguards. 6.4 Trainings and Capacity Building The principle objective of the trainings is to ensure long-term sustenance of the ESMF and RPF principles for sound and sustainable project implementation. Social conflict can best be addressed by bringing all stakeholders on board through sustained and regular training. The training will also correlate with means of empowering the community, for social conflict resolution. 6.4.1 District Level Training It is recommended to hold one-day training workshops at the District level for DEOCs. These workshops will focus on identifying and discussing environmental and social issues that will arise during the implementation of the ESMF and RPF. These will also sensitize participants about environmental and social considerations of the SEIP, managing the site relevant problems, and strategizing implementation of the ESMF guidelines. 6.4.2 National Level Training Similarly, a one- day workshop will be held at the national level every year during which key stakeholders involved in SEIP field implementation will focus primarily on policy issues and share ideas and experiences. The E&S consultants in the PMT will be responsible organizing and reporting on these annual trainings. At the national level, it is also recommended that contractors working in the various districts are trained. The training of contractors will focus on their responsibilities as outlined in Annex 6: Example of Contractors’ Clauses. 6.4.3 Development of Training Manual In order to make the training efforts meaningful, the PMT, in consultation with the two environmental and safeguards consultant, will develop comprehensive “Training Manuals� for the participants. The training manuals will contain outline of the program, training methodology, glossary of terms, methodologies for avoiding and correcting environmental and social impacts, gender issues, tips on observing the guidelines, problem solutions with examples, excerpts of the relevant literature/legislations, and linkages to further sources of information and guidelines. The environmental and social consultants will be responsible for reviewing and updating the training manuals as necessary. 6.5 ESMF Costs The ESMF implementation involves three broad categories of costs:  Training and capacity building costs; and  External monitoring costs;  Information and Communication costs The estimated cost of ESMF implementation for duration of three years is about GHC1,657,520 (approx. US$635,000). The detailed budget is explained in the following table: GSEIP-ESMF Page 43 Unit Costs Total Cost/Annum Hotel Perdiem Transport 1. Hiring of two (2) Environmental and Social GHC15,600/month GHC374,400 Consultants for a year 2 2. Zonal Training (156 participants for four (4) GHC200 GHC80 GHC100 GHC102,960 zones for two days) 3. National Level Training for 26 contractors for GHC250 GHC100 GHC130 GHC12,480 one day 4. National Level Workshop for 50 participants 5. Monitoring Costs for quarterly monitoring GHC250 GHC100 GHC130 GHC29,500 visits at the district and annual monitoring visits at the national—15 monitors for 5 days 6. Training Manuals (150) and other training GHC10 GHC1,500 materials 7. Information and Communication Costs- radio GHC15,000 GHC15,000 announcements; print media adverts, announcements 8. Developing Technical Planning Guidance GHC 50,000 TOTAL GHC585,840 Table 6.2 Environmental and Social Focal Persons and their Areas of Responsibility Focal Person/Organization Areas of Environmental Responsibility  Coordinate the pre-design, planning, and funding stages with the TPG Environmental and Social  Incorporate ESMF Guidelines into contractors’ agreement Safeguards consultants  Coordinate capacity building and training activities  Act as an arbiter or dispute resolution in case of difference on issues beyond the district level  Call for due diligence and compliance reports from districts and update the national database.  Facilitate the Implementation of ESMF.  Organize and conduct national and district level trainings  Design manuals and modules for capacity building and awareness creation.  Facilitate monitoring and auditing process.  Ensure effective compliance of the ESMF at the district level District Environmental and  Receive environmental compliance reports from schools and forward Social Focal Person them to DEOC  Work as the dispute resolution authority for the district  Coordinate district level capacity building and training activities 2 Based on average perdiem and transport for workshops in 2014 GSEIP-ESMF Page 44  Carry out periodic and surprise inspection schools in the district DEOC  Complete the prescribed environmental compliance and monitoring forms/checklists and report non-compliance/ deviation  Submit the completed forms to PMT  Liaise between the contractor and the PMT  Ensure that construction stage guidelines are complied with by the Institutional Head contractor and report deviations to DEOC  Liaise between the contractor and the local community  Safe removal/reuse of demolition debris  Forward completed monitoring forms/ check lists to DEOC  Implement the ESMF guidelines relating to school operation e.g., ensure proper working of the septic tank, fill up and forward operation stage completed forms to DEOC  Create awareness about the project activities at the school level  Follow and observe the construction stage guidelines Construction Contractor  Comply with instructions and directions given by the PMT 6.6 Actors 6.6.1 Beneficiary Districts The beneficiary districts include schools and communities which are the main focus and recipients of the projects. Beneficiaries include secondary school students, teachers, parents, communities and other stakeholders. 6.6.2 Political Authorities The District Assembly is the highest political authority at the district level and together with the District Directorate of Education are of key importance to the project sustainability. 6.6.3 Chiefs, Opinion Leaders and CSOs These groups are critical to the project, as they usually wield considerable influence on decisions relating to the siting, establishment and location of facilities. 6.6.4 Ministry of Education and Ghana Education Service The MOE and the GES lead in the implementation of the project and see to the training and deployment of teachers, institutional leaders, equipment and materials to the schools to ensure the sustainable provision of quality education services. 6.6.5 Environmental Protection Agency (EPA) The EPA will assist, monitor, and ensure that the DEOC complies with laid down Environmental Assessment (EA) procedures on the implementation of the SEIP, especially when it comes to site selection and the issue of compensation and involuntary resettlement. 6.7 Project Management Structure Guidelines The major requirement of the project management arrangements is the formation of an autonomous unit responsive to beneficiaries and working to ensure: GSEIP-ESMF Page 45  Strong co-ordination on policy matters  Effective co-ordination on technical matters including environmental issues  Capacity building for implementation officials of the Ghana SEIP and DEOC . The management structure for the Ghana SEIP implementation with regards to environmental and social management is focused largely on the recruitment of two environmental and social specialists. The environmental and social specialists will be responsible for monitoring and ensuring that the checklists are completed accurately and that the contractor is applying the relevant mitigation measures. However, the implementing agency specifically the Chairman of the Project Implementation Committee is responsible overall for recruitment of the environmental and social specialist and the monitoring of the specialist’s work. 6.8 Environmental Management Guidelines As indicated, with regards to the Ghana’s EPA requirements, the Ghana SEIP falls within the Environmental and Social Management Framework (ESMF). It is expected though that, individual site specific activities will be subjected to appropriate project level assessment. In this regard, it is proposed that the implementing agency has a permanent focal point (likely to be the Monitoring and Evaluation Specialist) that can, with the contracted environmental and social specialist, liaise with representatives of the construction contractors to be responsible for ensuring that project specific level assessment requirements are met. The contractors would receive initial training and orientation from the Environmental and Social Consultant in order to obtain the requisite skills. 6.9 Guidelines of the Role of the EPA in the Project For individual projects, the EPA will implement monitoring programs on project-by-project basis once the site specific assessment is considered satisfactory. The level of assessment for any individual project would depend on the following factors. 1. Size or scale of project 2. nature/type and magnitude of impacts 3. location(land use consideration, compatibility and sensitivity) 4. resource base and resource at risk In general, there are three environmental assessments available under the Ghana EIA procedures. These are: Individual Projects for which only Registration Assessment may be required Registration Assessment (RA) is based on information provided in completing Form EA1, which is the starting point in Ghana’s EIA procedures. The appropriate EPA Regional office would receive a duly completed EA registration form EA1 and Environmental Assessment Checklist, in duplicate, in respect of the particular project to be developed. The EPA officers would visit the proposed projects sites to assess the adequacy of the information provided and also the appropriateness/ suitability of the selected site, among others criteria. Individual Projects for which Preliminary Environmental Assessment may be required Preliminary Environmental Assessment– a less detailed form of EIA, this leads to a Preliminary Environmental Report (PER). The Terms of Reference (TOR) are determined by the EPA after the Registration Assessment (RA). If there is the need for further analysis, after the appropriate RA, the GSEIP-ESMF Page 46 relevant EPA Regional office would advise on the scope of the Preliminary EA to cover the development. The officers would assist by assessing the adequacy of information provided and the suitability of proposed mitigation actions in the PER. Individual Projects for which Environmental Impact Assessment may be required. Environmental Impact Assessment (EIA)– detailed study based on an initial scoping report and carried out on the TOR agreed with the EPA. These are sub-projects, which may be located in environmentally sensitive or critical areas. It has been found from the site screening check list that the micro natures of the proposed Ghana SEIP components are such that full scale EIA may not be necessary. However, certain water projects (e.g. boreholes) have potential for environmental sensitivity, and it is important that greater attention is paid to siting them. Finally, the EPA would assist, monitor, and ensure that the DEOC complies with laid down EIA procedures in the implementation of the individual projects, especially when it comes to site selection and the issue of Compensation and Resettlement. 6.10 Guidelines for EPA’s Registration of the Projects The EPA Regional Offices will register all SEIP site specific activities located in their respective regions and monitor environmental compliance following implementation. EPA Head office would also maintain a register of all SEIP site specific activities in all the regions and prompt the regional officers to monitor the projects and provide updated information on their performance and status. Monitoring of Potential Impacts The monitoring of environmental effects is necessary to ensure that predicated impacts are addressed effectively and efficiently through the mitigating measures indicated. The three main objectives of the monitoring exercises are:  To ensure that the proposed mitigating actions are appropriate for addressing the identified impact.  To ensure that any additional impacts not identified in the analysis of the potential environmental and social impacts of the rehabilitation and/ or construction of school buildings, etc. and provision of water points and sanitation facilities are captured as early as possible.  To ensure feedback information to the Ministry of Education and the EPA in order that appropriate modifications can be made to either the operational activities or to the environmental management plan in terms of mitigating measures to be applied. GSEIP-ESMF Page 47 7.0 ENVIRONMENTAL MITIGATION PLAN (EMP) 7.1 Introduction Considering the various environmental and social impacts of Ghana Secondary School Project, it is imperative for mitigation measures to be put in place so as to avoid any negative consequences. 7.2 The role of stakeholders in ESMF Implementation Environmental and social planning, implementation and management are undertaken by Ministry of Education for its development projects to cover environmental and social assessment (ESA) and the pre- project/project planning processes. Key stages of the ESA include proposal screening, EIA and mitigation measures, while the pre-project/planning process involves project concept, identification, design and appraisal. The ESA process links up with the pre-project/planning process signifying the importance of the two processes (i.e. EA and feasibility) to influence one another in the development of the Ghana Secondary Education Improvement Project. In the context of the ESMF, environmental and social planning identifies and assesses the potential concerns and implications that may arise with the implementation of the Ghana Secondary Education Improvement Project, in order to influence the design and other engineering feasibility options and decisions, for informed and sustainable project development. The successful implementation of the ESMF depends on the commitment of Ministry of Education and related institutions, the capacity within the institutions and the appropriate and functional institutional arrangements among others. The Ministry of Education, EPA were identified as directly associated with the preparation, review and the implementation of the ESMF. The Ministry of Health (MoH), Lands Commission (LC) and the project communities were involved for their inputs regarding the appropriate environmental, social and health safeguards to be observed when the sub-projects are being implemented. The contractor(s) to be employed to undertake construction works will also have a role to play in the implementation of the sub-projects. This section addresses the following key areas of the ESMF implementation:  Roles of Key Stakeholders in the ESMF implementation;  Capacity building;  Environmental and social monitoring and reporting; and  ESMF implementation budget. Roles of Key Stakeholders in the ESMF Implementation The ESMF provides the environmental and social safeguards for the Ghana Secondary Education Improvement Project and its successful implementation will depend largely on the key stakeholder institutions. This will ensure that the sub-projects are undertaken with due regard for the integrity of the resources to be affected by the project development activities. The roles of the major stakeholders are identified in an institutional role in which the various components of the Ghana Secondary Education Improvement Project were matched with the institutions which have jurisdiction in the areas of licensing, permitting, assessment, monitoring, etc. are stated below. These institutions and stakeholders were identified as having roles to play in the Ghana Secondary Education Improvement Project ESMF preparation as well as implementation of the sub-projects:  Ministry of Education (MoE);  Environmental Protection Agency (EPA);  Ministry of local government and rural development;  Ministry of Health (MoH); GSEIP-ESMF Page 48  Ghana Water Company;  Community Water and Sanitation Agency;  Ministry of Environment, Science and Technology (MEST); and  NGOs.  Land Valuation Board The recommendations for the Ghana Secondary Education Improvement Project have been prepared in the form of guidelines (ESMF) and monitoring procedures. The major recommendations have been summarized below: Community Involvement and Ownership Selection of Contact Persons: Although their support and involvement is essential, community leaders like Chiefs and Assembly Members do not always make the best contact persons for project implementation. In some situations, efforts should be made to identify other opinion leaders particularly those who appear to catch the vision and can assist in sensitizing the people. Contacts should be made with children, women, groups, the poor, teachers, and parents, as they constitute the major beneficiary group of the project. Education Selected beneficiary communities should be educated on all aspects of the intended intervention well ahead of time. This should include the benefits, problems and financial implications among others. Animation, film shows, drama and posters are some of the methods that could be used to educate the people. This is the responsibility of the MMDAs. Grievance Redress Mechanism -Conflict Resolution All issues of conflict and misunderstanding identified prior to implementation should be exhaustively addressed and resolved by the MMDAs, using e.g. public forum to arrive at compromises. The tendency of using the project itself as a means of overruling potential conflict and misunderstanding should be avoided. Community Ownership Community participation/involvement is a vital issue that has been identified to ensuring sustainability of any project. Most of the communities targeted by the Ghana Secondary Education Improvement Project are among the most deprived in the country. This makes it more meaningful that they identify themselves with the project and its success by ensuring that assistance is provided to sitting and constructing of the project’s components and to teachers, who would work in the establishment. Steps should thus be taken by the MMDAs to sensitize and involve the beneficiary communities from the start of the project. Monitoring A third party, consultant, should be engaged to determine the level of involvement, sensitization and understanding or otherwise of the project in the beneficiary communities prior to the start of the project. Report on findings should be sent to the Project Steering Committee (PSC). GSEIP-ESMF Page 49 Project Site Selection TheMOE and Contractors should hold consultations with the District Environmental Management Committees (DEMC), the Land Commission and the Water Resource Commission in sitting the project components. The recommendations for site selection of projects should consist of the following:  Avoid locating projects near cultural sites such as sacred groves and burial grounds and other places that may give offence to the people.  Avoid sitting facilities near unsanitary locations, e.g. rubbish dumps, which might lead to outbreak and spread of infectious diseases.  The sanitation facilities should not be sited near water bodies.  Involve other nearby communities that might send their children to the schools too in order to avoid conflict, which could lead to tensions in the use of the school  The population of the communities in the catchment area would have to be consulted in sitting the school in order that the school facility is not extremely under-utilized  In considering the catchment area, the sustainability of enrolment over the years should also be looked at.  Ensure that the project site has sufficient land area for the construction of all the project’s components, facility installation and for future expansion, if necessary.  Avoid ecologically sensitive sites such as flat plains, which are liable to flooding, aquifer recharge zones, steep terrain prone to erosion and threat to fragile habitat and endangered species.  Avoid sites close to other land uses, such as major highways, hospitals, quarry, etc. that may impact negatively on the pupils or vice-versa. Timing of Constructional Activities The construction work should be planned by the contractors taking cognizance of the following: Cultural and Religious Activities Some religious and cultural activities may engage the attention of the people over an extended period of time, such periods should be avoided as much as possible.  Seasonal Migration – Periods and seasons when some of the people migrate out of their communities to seek employment elsewhere should be factored into the planning.  Favorable Climatic Conditions – Activities requiring extensive excavation work like water projects must be timed to coincide with periods of conductive climate. In some areas, especially northern Ghana, the rainy season renders inaccessible parts of the regions, thus construction work has to be planned in the dry season. Inspections should be carried out by the EPA and District Implementation Committees to determine whether there are destruction of farms, displacement of households, loss of land, and property or landed property, in order to determine whether the right procedures have been followed with regards to compensations and resettlements. Source of Raw Materials  The project consultant should ensure that the contractor procures building materials such as sand, stones, and laterite from licensed and approved sites.  As long as chain-sawn lumber remains illegal, contractors should be urged not to employ them in the construction of any of the facilities of the project. GSEIP-ESMF Page 50  Visual inspection of the Construction materials should be carried out by the Contractors and MMDAs, paying particular attention to lumber. They should not be chain-sawn lumber. Operation /Maintenance and Odor The management and maintenance of the components of the project should be in the hands of the District Assembly through the District Directorate of Education. Spare parts for water points should be made available, as they are difficult to come by in the rural areas. Inspection should be carried out on the project components during the operational phase in order to assess the condition, proper management or otherwise and to determine the availability of back up spare parts especially for the water points. This inspection is to be carried out by the MMDAs. Good housekeeping of sanitation facilities (KVIP, VIP, Pit Latrine, and Pan Latrine) should be enshrined in the operations of the school, and to be carried out either by the pupils or by a private company in order to ensure the facility’s sustainability Periodic monitoring and evaluation of the sanitation facilities should be undertaken to assess their condition with regards to cleanliness and use or otherwise. This should be supervised by the MMDAs and crosschecked by GES and MOE/MOH. Quality of Work and Workmanship Specification All building works contracted for the Government of Ghana are to be executed according to the General Specification for Building Works published by the Government of Ghana in November 1995. These specifications are Ghana Standard Board and British Standards specifications. The District Tender Boards and MMDAs are to ensure that the contract documents are in accordance with the General Specification for Building Works published by the Government of Ghana in November 1995, which mainly are Ghana Standard Board and British Standards specifications. They would also inspect the construction while it is in progress with the help of the Public Works Department Engineers of the Districts to assess whether the specifications are being adhered to correctly. The MMDAs are to ensure that the contractors apply, as applicable, the guidelines prepared herein for the mitigation of impacts, in order to achieve quality of work. Quality of Materials All the materials to be used in the construction of the project components are to be new, of best quality and manufacture and in accordance with the current British Standard and Ghana Standard Board specifications, where they exist. Where they do not exist, samples are to be provided for tests to be carried out on the materials. When samples have previously been submitted and approved, all subsequent deliveries should be in accordance with the sample. The contract documents prepared for the execution of the project should insist on the use of materials of the highest quality, which are of the current Ghana Standard Board or British Standard specifications. The MMDAs and members of NIC would visit sites to inspect the materials and would ensure that subsequent deliveries would be in accordance with the samples previously inspected and approved. GSEIP-ESMF Page 51 Supervision of the Works Supervision of the works would be done by the consultants and MOE in order to have proper control of the construction of the components of the project and reports prepared and sent to the PSC. Selection and Design of Types of Project Components The design of the project components and the selection of types of water points and sanitation facilities are to be carried out in conjunction with or by the MMDAs andMOE/GES. The DAs have their developmental plans and know, for example, which communities would be served with pipe borne water within a year or two. This proposal is also to avoid the selection or design of impractical project components, which would be imposed on the beneficiaries. The selection of type of school building, teachers’ quarters, water points and sanitation facilities should be done by the MMDAs and MOE/GES. Report on the project component selections made would be sent to the NIC. Security The water points must be protected to prevent misuse, accident and intentional pollution. Wells and boreholes should be secured by raising concrete barrier structure and provided with cover and lock. The sanitation facilities must be secured by lock when the schools are not in session. Visual inspection of the water points and sanitary facility is required to determine whether they are secured by concrete barriers and with locks. The MMDAs and GES are to undertake this inspection. Groundwater Depletion/Aquifer Recharge This is relevant for wells and boreholes. Design considerations should ensure that abstraction rates are consistent with natural aquifer recharge. Consultations with the regional CWSA would provide information on the aquifer recharge. Questionnaires could be applied to the teachers and pupils to determine, whether there are times that the groundwater gets depleted or the yield is observed to reducing. This would be carried out by the MMDAs and CWSA. Groundwater Quality Water is intended for human consumption and should be subjected to quality analysis by the Community Water and Sanitation Agency (CWSA) to determine, whether it meets the required standards before giving approval. Supposing the groundwater does not pass the standard tests, the CWSA would advise on exactly which steps to take. It is imperative to mention that during the operational phase regular quality analysis would also have to be carried out to ensure that the water continues to be suitable for drinking. The MMDAs are to liaise with the CWSA in monitoring the groundwater quality, document the data properly and to prepare reports to be submitted to EPA, GES andMOE. GSEIP-ESMF Page 52 Groundwater Contamination Work on septic tanks and pits would have to be carried out professionally and to the highest quality to avoid contamination of groundwater during the constructional phase, and leachate into groundwater during the operational phase. Work quality inspections are to be carried out by MMDAs. Liquid Waste Management in Secondary School Measures to guide the operation of schools with regards to Liquid Waste Management in order to ensure the project’s sustainability include:  Provide enough toilet seats and urinal points to cater for the school  Ensure that the pupils use these facilities without resorting to “free- ranging�  Ensure that the pupils are sensitized to understand the reasons why they are to use these facilities.  Sanitation and hygiene could be incorporated into their school work.  Incorporate waste water disposal in the design to ensure that waste water from wash basins flow into proper gutters, where they are available  Put in place a program, including inspection of schools, to ensure Proper House Keeping of the facility  Put in place a program to periodically empty septic tanks of the Aqua Privy or WCs, either through private entities or the District Assembly, to ensure that they do not overflow.  The DAs would be required to have a septic emptier or an improvised one, as it was apparent from the field work that Aqua Privy is better for schools in areas, where there is no pipe borne water, than the KVIP. Liquid waste management should be monitored during operational stages of the project. This should be undertaken by the MMDAs, GES and crosschecked by the Ministry of Education. Solid Waste Management in Secondary School Measures to guide the operation of schools with regards to Solid Waste Management in order to ensure the project’s sustainability include:  Provide enough garbage cans of right sizes and with covers to cater for the school’s rubbish collection needs  Ensure that the pupils use these facilities and that they do not throw rubbish anywhere else  Ensure that the pupils are sensitized to understand the reasons why they are to use these facilities. Sanitation and hygiene could be incorporated into their school curricula.  Incorporate garbage cans and rubbish collection points in the design of the school to make garbage cans easily accessible to the pupils and teachers.  Put in place a program, including inspection of schools, to ensure Proper House Keeping of the school.  Put in place a program for the evacuation of the collected rubbish, either by private entities or the District Assembly, once every day or every other day. Periodic monitoring and inspections should be undertaken by the MMDAS, GES and MOEduring the constructional and operational phases of the project. The condition of solid waste management should be determined. The parameters to use are sitting of garbage cans, number, and proximity to one another. GSEIP-ESMF Page 53 Project Management Structure for Environmental and Social Sustainability The management structure for the Ghana Secondary Education Improvement Project implementation with regards to environmental management is proposed to be coordinated by a Project Management Team (PMT), which falls under the Project Steering Committee (PSC). This PMT is expected to provide project implementation guidelines as per the ESMF and RPF at the Regional level. Working under the PMT at the District level will be a District Education Oversight Committee which would comprise the District Director of Education (DDE), the District Engineer, the District Planning Officer, the District Environmental and Social Office and a representative of the district office of the Lands Valuation Division, with the Municipal/District Chief Executive as the chair. The responsibility for the overall project management is proposed to be vested in the PMT. Environmental Management The Ghana Secondary Education Improvement Project under EPA requirement is categorized under Environmental and Social Management Framework (ESMF). It is expected however that, individual components would be subjected to appropriate project level assessment following approval of the SEA prior to the project implementation. In this regard, it is proposed that the District Education Oversight Committee liaising with representatives of the Construction Contractors be responsible for ensuring that project specific level assessment requirements are met. They should receive initial training and orientation from Environmental Consultants in order to have the requisite skills. The Role of the EPA in the Project The EPA plays a lead role in the administration of EIA in Ghana. The EPA Act (Act 490, 1994) and the Environmental Assessment Regulation (LI 1652) 1999 mandate the Agency to ensure compliance with laid down EIA procedures provided comprehensively for site- specific project impact assessment. The Ghana Secondary Education Improvement Project in its preparatory assessment is to be considered under the Environmental and Social Management Framework (ESMF). A single Environmental Approval would be issued for the Ghana Secondary Education Improvement Project, on the basis of the ESMF, by the EPA. For individual projects, the EPA will implement monitoring programs on project-by-project basis once the site specific assessment is considered satisfactory. The level of assessment for any individual project would depend on size or scale of project, nature/type and magnitude of impacts, location (land use consideration, compatibility and sensitivity), and resource base and resource at risk. In general, there are three environmental assessments available under the Ghana EIA procedures: (a) Individual Projects for which only Registration may be required using Form EA1 (b) Individual Projects for which Preliminary Environmental Assessment may be required (c) Individual Projects for which Environmental Impact Assessment may be required  The EPA would register all SEIP sites and monitor environmental compliance following implementation.  EPA would also maintain a register of all SEIP components in all the regions and prompt its regional officers to monitor the projects and provide up- dated information on their environmental performance and status  Finally, the EPA would assist, monitor, and ensure that the District Implementation Committees comply with laid down EA procedures in the implementation of the individual projects, especially when it comes to Site Selection and the issue of Compensation and Resettlement. GSEIP-ESMF Page 54 Capacity Building The members of the (MOE/GES), MMDAs and the groups of potential contractors are to be provided with Environmental Awareness Training. For the last two groups the training would also be aimed at developing and improving on skills to screen for site selection and potential environmental and social impacts, fill the environmental forms, be able to comprehend and take mitigation measures and take steps to monitor the potential impacts of the Project. Cost Estimates of the Implementation of the Mitigation Measures and Monitoring Not all the mitigation measures and monitoring procedures require expenditure of funds. For any money to be spent, quotations or cost estimates should be collected from at least three entities, and evaluated for the appropriate one (with high points both financial and technical terms) to be selected before approving the works’ execution, unless of course the work is to be carried out by employees of the District Assembly. Estimates however have been presented in the EMP. GSEIP-ESMF Page 55 8.0 CONSULTATIONS 8.1 Introduction Consultations play a major role in identifying the potential impacts of any proposed transmission system project. Community consultations assist in the identification of socio-economic, religious and cultural impacts. Stakeholder consultation to support the ESMF and the resettlement process, if any, specifically aims to achieve the following objectives:  To provide information about the project and its potential impacts to those interested in or affected by the project, and solicit their opinion in that regard  To manage expectations and streamline misconceptions regarding the project  To agree on resettlement preferences, if any, and discuss concerns  To ensure participation and acceptance of the project by the communities Information obtained during consultations can be used to make an inventory of existing infrastructures and to collect information on land management, socio-economic activities, infrastructure, and expectations of the local residents. 8.2 Methodology A team consisting of the staffs of Ministry of Education and representatives of the Environmental Consulting Firm collected data for the consultations. Community opinion leaders such as assemblymen/women, faith based organization leaders, youth leaders, chiefs, or headmen served as key contacts to encourage meeting attendance. The meetings that were held either at the community center were interactive, with questions from the communities and answers and explanations from the consultant and Ministry of Education Staff. The main issues discussed were regarding compensations, jobs creation, and provision of schools. Presented below are the list of people consulted, attendees, contact details of the opinion leaders and the socioeconomic and cultural issues forming the bases of the discussions. Attendees List Attendees at the meeting Designation Contact numbers GSEIP-ESMF Page 56 8.3 General Concerns The concerns raised were unanimous across all the districts and communities:  Prompt, fair and adequate compensation payment for affected properties  Job creation for the youth. There was a cyclical request for employment particularly unskilled labor to be sourced from the various affected communities.  Compensation for affected lands for the project. An appeal was made across all the communities who wish to donate3 lands for the proposed project to be compensated instead of only the structural properties.  Upholding and respect of community values (reverence towards the communities’ cultural heritage- shrines, sacred groves, etc).  The health implication of the proposed school project without adequate provision of water facilities  Request for the provision of basic social amenities, not necessarily in the context of the proposed project. GSEIP-ESMF Page 57 ANNEXES Annex 1: Methods and Techniques Used in Assessing and Analyzing Impacts General Approach to the Assignment The Consultants adopted a participatory approach towards the execution of the assignment. This approach entailed the involvement of all key stakeholders in the education sector in the process of data collection and analysis, and the development of interventions. The purpose was to build consensus on the formulation of the project and commitment to project implementation. The Consultants held preliminary meetings with the Chief Director of the Ministry of Education, to agree on the general approach, level of collaboration and essential inputs to be provided by the Ministry. Methods of Data Collection The consultants employed a mixture of methods and techniques to collect data for the execution of the assignment. Both primary and secondary data were collected. The methods/techniques used are highlighted below: Literature Review/Desk Study The consultants collected and reviewed a number of documents relevant to the assignment. The main documents reviewed and which provided valuable secondary data included:  The Ghana Education Strategic Plan (ESP) – Volumes 1 and 2.  Draft Project Appraisal Document of the Secondary Education Improvement Project.  World Bank Environmental Health and Safety Guidelines (Ten-Point Safeguard Policies).  Ghana Poverty Reduction Strategy (GRPS) Poverty Reduction Framework.  Constitution of the Republic of Ghana (1992).  Environmental Protection Agency (1996), Environmental Assessment Procedures in Ghana.  Conventions and Protocols relating to Environmental Protection Assessment to which Ghana is a signatory.  Organizational Structure of the MOE.  Education Sector Policies and Procedures of the MOE.  Maps (administrative and geographical) and Profiles of the 216 Districts (Topographic sheets, vegetation, terrain, climatic conditions, population densities, cultural and traditional practices, social development, occupations, sacred grooves, reserves, streams etc.)  World Bank’s Involuntary Resettlement Policy  World Bank’s Operational and Safeguard Policies Design and Administration of Data Collection Instruments The Consultants designed interview guides and questionnaires to help in the data collection process. The first phase of data collection involved the administration of questionnaires and interviews with officials of the following institutions:  Ministry of Education  Ministry of Local Government  Ministry of Environment and Science GSEIP-ESMF Page 58  Ministry of Works and Housing  Ghana Education Service (GES)  Environmental Protection Agency  Lands Commission  Land Valuation Board  World Bank  Ministry of Local Government and Rural Development  Survey Department  Town and Country Planning The second phase of data collection involved field visit to the selected Districts. Field Work The Consultants carried out field visits to ten (10) project districts. The selected districts, based on quantum and geographical spread are as follows: Region District i. Northern West Gonja ii. Northern Tolon-Kumbungu iii. Upper East Bolgatanga iv. Western Ahanta West v. Brong Ahafo Kintampo vi. Upper West Sisala vii. Eastern Birim South viii. Ashanti Offinso ix. Central Gomoa x. Volta Kete Krachi The underlying reasons for this selection were: 1. This was not a specific Environmental Impact Assessment but rather Environmental and Social Management Framework. 2. Limited time (4 weeks) within which to undertake the study. As part of the fieldwork, focus group discussions were held with identified groups, which included teachers, school management boards and school children. In each of the above districts, interviews were held with officials of various agencies and questionnaires were also administered to same. The following provided data inputs:  District Chief Executives  District Coordinating Directors  District Planning Officers  District Engineers  District Director of Education  Head teachers  Teachers  Community Water and Sanitation Engineers  Ghana Water Company Chemists GSEIP-ESMF Page 59  Members of Parent-Teachers Associations  Members of School Management Committees  School Children The school children and parents talked to were both male and female. Almost all the parents interviewed were farmers and traders. About half of the teachers and head teachers interviewed were women. Lastly, one District Director of Education and one District Coordinating Directors were women. In view of the limited time frame, two (2) teams of consultants undertook the fieldwork concurrently. The full list of Institutions contacted is given as Appendix 3. Assessing and Analyzing of Environmental Social Impacts The methodology adopted for assessing and analyzing the impacts was from consultations with stakeholders. The main objectives of the environmental and social analysis were to:  Assess any potential environmental and social impacts that could emanate from investing in the pre-construction, construction and operational phases of the Project.  Assist MOE in determining actions to mitigate the environmental and social adverse effects of Ghana SEIP activities.  Enable MOE in playing the capacity building in the long-term to address Ghana SEIP environmental issues. In order to determine potential impacts and develop the relevant mitigation measures the following factors were considered:  Pre-constructional phase social impacts  Constructional phase impacts  Operational phase impacts o Environmental Impacts such as solid and liquid waste generation, collection, disposal and management o Social Impacts such as resettlement issues Following the analysis, a draft report was prepared and submitted to the Client. GSEIP-ESMF Page 60 Annex 2. Consultations with key Stakeholders The various institutions, organizations, Ministries, Departments and Agencies, individuals and stakeholders consulted were: Ministry of Education The Ministry of Education was contacted for the following information:  The Ghana Education Strategic Plan (ESP)–Volumes1 and2.  Draft Project Appraisal Document of the Ghana Secondary Education Improvement Project.  Ghana Poverty Reduction Strategy (GRPS) Poverty Reduction Framework.  Organizational Structure of the MOE.  Education Sector Policies and Procedures of the MOE.  Introductory letters were obtained from the Chief Director of the Ministry to all areas that were visited to facilitate the administration of questionnaires.  Policy issues were also obtained from top personnel of the Ministry. The MOE by itself has some capacity for environmental assessment and management as its Departments/Agencies like the GES. Ministry of Lands and Forestry The Ministry of Lands and Forestry was contacted on land acquisition procedures. They in turn directed the consultants to Lands Commission and Land Evaluation Board. Lands Commission The Lands Commission coordinates with relevant public agencies and government bodies to perform functions such as:  On behalf of the Government, manage public lands and any land vested in the President by the 1992 Constitution or by another law or any land vested with the Commission.  Advise the Government, local Authorities and Traditional Authorities on the framework for the development of a particular area of Ghana to ensure that the development of individual piece of land is coordinated with the relevant development plan for the area in concern  Formulate and submit to Government on national policy with respect to land use and capability  Advise on and assist in the execution of a comprehensive program for the registration of title to land throughout Ghana. Policy and plan implementation and enforcement under the Commission are also carried out by various agencies in their respective areas of competence such as Town and Country Planning, Lands Department, Forestry Department, and Forestry Commission. GSEIP-ESMF Page 61 The Lands Commission has not developed any capacity in environmental assessment and management. Land Valuation Board Article 20 Clause 2 stipulates that compulsory acquisition of property by the State shall be made under a law which makes provision for the prompt payment of fair and adequate compensation. The Lands Valuation Board is the body that determines what is the appropriate compensation payable for any landed property compulsorily acquired by the State. The Lands Valuation Board was therefore consulted for modalities of claims and compensation payments. In instances where there are discrepancies between the Ghanaian law and the World Bank Policies, the World Bank policy apply. The Land Valuation Board has no capacity for environmental assessment and management. The Ministry of Local Government and Rural Development This Ministry was contacted on the role the District and Municipal Assemblies are playing in the environmental management. The municipal assemblies are responsible for waste management. Similarly, the DAs are responsible for waste disposal and management in the Districts. Environmental Protection Agency The EPA plays a lead role in the administration of EIA in Ghana. The EPA Act (Act490, 1994) mandates the Agency to ensure compliance with laid down EIA procedures provided comprehensively for site- specific project impact assessment. The Ghana Secondary Education Improvement Project in its preparatory assessment is to be considered under the Environmental and Social Management Framework (ESMF). A single Environmental Approval would be issued for the Ghana SEIP, on the basis of this ESMF by the EPA. For individual projects, the EPA will implement monitoring programs on project-by-project basis once the site-specific assessment is considered satisfactory. The level of assessment for any individual project would depend on the following factors.  Size or scale of project  nature/type and magnitude of impacts  location(land use consideration, compatibility and sensitivity)  resource base and resource at risk The EPA has environmental assessment and management capacity. The Agency has offices in all the 10 regions of the country, staffed with highly qualified personnel. Town and Country Planning The Town and Country Planning in districts would scrutinize and approve, or otherwise, the building plans and would provide a Zoning Report. The Building Plans and the Zoning Report are to be attached to the Form EA1 and submitted to EPA. The Town and Country Planning Department has limited environmental assessment and management capacity. GSEIP-ESMF Page 62 Metropolitan Authorities & District Assemblies Ghana has a system of local government and an administration, which is as far as practicable decentralized. The District Assemblies and Metropolitan Authorities are the highest political authorities in the districts and they have the deliberative, legislative and executive powers. The functions of these local authorities include the formulation and execution of plans, programs and strategies for the effective mobilization of resources necessary for the overall development of the districts. More importantly, the management and final disposal of wastes at landfill sites or into sewerage systems is the responsibility of the district and the metropolitan assemblies. An effective management of school waste in Ghana cannot be possible without a deep involvement and participation of the assemblies. The concerns of some of the District and Metropolitan Assemblies have been sought and factored into this document. District Directorate of Education (Including Head teachers and Teachers) The District Directorate of Education comprises of the District Director and the Assistant District Directors. There are four Assistant District Directors in the Structure of the Ministry of Education and the Ghana Education Service at the District level. The Assistant Directors are in charge of the following:  Planning, Monitoring and Data Collection  Administration, Budget, and Financial Control  Human Resource Management and Supervision and Management of Teaching and Learning The Assembly in consultation with the above Directorate plan, implement and monitor the development of any education facility in the District. However, this is not the case in some of the districts where the directorate of education are not involved in decision-making regarding the planning and implementation of school projects. Traditional Authorities Almost all the Districts visited had the Chiefs as the custodians of the land. They were therefore directly responsible for the acquisition of any piece of land. In some few places however the Tindanes (The Chief Priests) had much control over the land. In that regard any acquisition of any piece of land in the any area had to pass through these Lords. Usually the District Assembly would have to be consulted first before one is lead to the Chief and Elders for a release of any portion of a land. In all the Districts visited, the District Chief Executives and the District Directors of Education indicated that land for public school buildings were mainly released by the Chiefs. Beneficiary Communities (PTA and Pupils) for the Ghana Secondary Education Improvement Project Community participation/involvement is a key factor in the sustainability of projects of the nature of the Ghana SEIP. The Beneficiary Communities therefore have a role to play. They have to be involved right from the beginning in the decision-making processes at the pre- constructional stage. For instance they need to be consulted in the sitting of the facilities. Most districts that neglected these key GSEIP-ESMF Page 63 stakeholders at the pre-constructional stages of projects in the district faced problems in the end. Projects had to with low patronage. The sense of ownership has to be built right from the start of the project. District Environmental Management Committees (DEMC) The above committees are directly responsible for environmental issues in the district. They have direct oversight responsibility concerning issues of water and sanitation. They play a key role in terms of organization for cleanliness within the district. They have representatives in almost all the schools in the districts. Their representatives are also teachers in the schools. Their opinion in the Pre-constructional and especially the operational stage of the SEIP facility is very paramount, as it would go a long way to ensure project sustainability. Members of the DEMC have had some training in Environmental Management. District Public Works Departments The District Public Works Departments are responsible for the civil works of the districts. Construction of school buildings and their maintenance rests more with the DAs and the GES. Contractors Most contractors who had been awarded contracts had come from outside the district. Except for DA funded schools, the contractors are hired from outside. Community Water and Sanitation Agency The Community Water and Sanitation Agency is a semi-autonomous agency established by Act 564 of 1998 with its own Board of Directors. As a main agency for local level development within the governmental machinery the DAs are to work through District Water and Sanitation teams to establish district water and sanitation programs and promote the project in eligible communities. The DAs will open separate accounts and contribute a certain percentage of funds to the cost of facilities demanded by the communities within their area of operation. The agency’s roles among other thing are to:  Preparation and review of annual district water and supply and sanitation plans  Promotion and dissemination of information on Community and water  Sanitation Projects and arouse the interest of the Communities  Identification of interested communities and prioritization of communities and based upon established criteria  Ensuring all members of the community, especially women actively participate in decision making The CWSA has responsibility for facilitating the animation, construction and operation of water and sanitation facilities. GSEIP-ESMF Page 64 Annex 3. Socioeconomic and Environmental Characteristics in the Education Sector The total population of the selected districts is computed, as per formula (1) to be 6,124,068 by the end of 2003, out of which 3,034,028 are males and 3,090,040 are females. It must be mentioned that 4,848,469 people in the area are found in the rural areas and 1,274,600 people are in the urban areas. Distribution of Rural–Urban Population The study area is predominantly rural. The rural-urban split of the study area is 20.8- 79.2%. Rural-Urban Distribution Source: Computed from 2000 Population & Housing Census: Ghana Statistical Service Education While literacy can be acquired through reading and private informal channels, the formal schooling system remains the best process for improving access to information and broadening the horizon of the people. According to the 2000 Population and Housing Census, educational attainment in Ghana (3 years and more) was pre-school (3.2%), primary (18.6%), Middle/JSS (21.1%), Secondary SSS (6%), Vocational/Technical (2.2%), Post Secondary (1.5%), Tertiary (2.8%), and None (43.3%), and the school attendance (3 years and more) was pre-school (13.8%), primary (54.3%), Middle/JSS (16.5%), Secondary SSS (8.3%), Vocational/Technical (2.0%), Post Secondary (1.7%), and Tertiary (3.5%). Availability of Schools in Rural Areas About 86% of rural households live in communities that have access to a primary school; 62% of households live in areas, which have access to a junior secondary school, while 10% live in communities, which have access to a senior secondary school. Almost all rural schools are public schools. About 19.5% of the Secondary School in the districts visited during the fieldwork have sanitation facilities. A good number of these Secondary Schools are relatively new. The table below shows the rural households with access to schools. Rural Households with access to schools Ecological Zone Primary JSS SSS/technical Coastal 88% 64% 5% Forest 91% 71% 15% Savannah 80% 51% 11% 86% 62% 10% Distance rural households travel to get to the nearest primary school The Secondary Schools are usually in the communities, where the rural households live. Other households however have to travel between 1 and 10 miles to get to the nearest primary school depending on the ecological zones, as per the table below: Distance rural households travel to get to the nearest primary school Ecological Zone <1 mile 1 mile 2miles 3miles 4miles >5 miles Coastal 88.0% 5.0% 2.5% 0.0% 2.5% 2.0% 100% GSEIP-ESMF Page 65 Forest 91.0% 3.0% 2.0% 2.0% 1.0% 1.0% 100% Savannah 80.0% 4.0% 8.0% 3.0% 1.0% 4.0% 100% 86.3% 4.0% 4.2% 1.7% 1.5% 2.3% 100% Proportion of boys and girls of primary school age enrolled Boys and girls in the Forest zone appear to be much more likely to be enrolled in primary schools than their counterparts from the Coastal and Savannah zones. In the Savannah zone, girls are less likely than boys to be enrolled in Secondary School. This is illustrated in Tables below: Proportion of boys of primary school age enrolled Ecological Zone Almost all At least half Less than half Coastal 27.0% 44.0% 29.0% Forest 54.0% 41.0% 5.0% Savannah 16.0% 46.0% 38.0% 32.3% 43.7% 24.0% Proportion of girls of primary school age enrolled Ecological Zone Almost all At least half Less than half Coastal 23.0% 42.0% 35.0% Forest 53.0% 41.0% 6.0% Savannah 16.0% 28.0% 56.0% 30.7% 37.0% 32.3% Main reasons why some children in rural communities are not enrolled in Secondary School The most common reasons why children some children in the rural communities are not enrolled in Secondary Schools, by ecological zones have been summarized in the table below. Lack of finance appears to be the main reason for non-enrolment of children in rural areas in Secondary Schools. It must be mentioned that, due to the same reasons, a lot of the enrolled children in Secondary School miss classes continuously. It was observed in a primary school visited in Kintampo District (Savannah Zone) during the fieldwork that more than half the children skip school during market days. Main reasons why some children in rural communities are not enrolled in Secondary School Ecological A B C D E F G Zone H Coastal 58.0% 10.0% 10.0% 6.0% 3.0% 2.0% 0.0% 11.0% Forest 70.0% 7.0% 5.0% 2.0% 7.0% 2.0% 0.0% 7.0% Savannah 64.0% 6.0% 7.0% 8.0% 0.0% 1.0% 11.0% 3.0% 64.0% 7.7% 7.3% 5.3% 3.3% 1.7% 3.7% 7.0% A: Inability of parents to fund child’s education B: Lack of Parental Interest C: Lack of Interest in School going children D: School too far away E: Inadequate schools/classrooms F: Dangers faced by children on their way to school e.g. getting drowned in rivers GSEIP-ESMF Page 66 G: Children are used for work e.g. work in the field, work during market days, and taking care of younger siblings or weak and aged parents H: Other Reasons Schooling Problems The most serious schooling problems in the rural communities include lack of school building, insufficient furniture, lack of qualified teachers, high cost of schooling, lack of textbooks, and lack of accommodation for teachers, among others. It was noted in all the districts visited during the fieldwork that some primary school children carry their chairs to school. The Parent and Teachers Associations contacted during the said fieldwork also indicated that they usually fund the purchase of furniture for their children in school. The table below summarizes the schooling problem. The most serious schooling problems in the rural communities Ecological A B C D E F G H Zone Coastal 43.0% 25.0% 2.0% 5.0% 5.0% 10.0% 0.0% 10.0% Forest 38.0% 19.0% 10.0% 10.0% 6.0% 2.0% 3.0% 12.0% Savannah 59.0% 8.0% 9.0% 1.0% 4.0% 3.0% 1.0% 15.0% 46.7% 17.3% 7.0% 5.3% 5.0% 5.0% 1.3% 12.3% A: Lack of school building B: Insufficient Furniture C: Lack of Qualified Teachers D: High Cost of Schooling E: Lack of Textbooks F: Inadequate supply of stationery and other school materials G: Lack of accommodation for teachers H: Other Reasons Secondary Schools with Sanitation Facilities About 19.5% of the Secondary Schools in the districts visited during the fieldwork have sanitation facilities. A good number of these Secondary Schools are relatively new. The practice with regards to schools without sanitation facilities is either free ranging or walking to the nearest public toilet in the community. Secondary Schools with Water Points With regards to water points, only about 3.47% of the Secondary School of the districts visited during the fieldwork have water points. The water points are pipe borne water taps and boreholes. In almost all the cases, the surrounding residents were noted to be patronizing the water points. In most of the schools without water points, the school authorities each day buy or fetch water, which is kept in each classroom in a bucket with cover and a cup for the pupils. Secondary Schools with Electricity It was observed during the fieldwork that about 4.6% of the Secondary School in the visited districts have electricity. They are new and are found in the urban sections of the districts. It has been recommended in the guidelines that electricity be incorporated into the designs of the project facilities, GSEIP-ESMF Page 67 even if the area, where the school is sited does not have electricity. This is to make it easy to access electricity without extra costs and inconvenience, when the facility reaches the area. Secondary Schools with Telephone All of the SHS in the districts visited has telephone. Secondary Schools with Refuse Cans With regards to refuse cans, only 0.83% of the schools in the districts, which were visited during the fieldwork, have refuse or garbage cans. The pupils in the bulk of the primary schools pick the rubbish around the schools and dump them onto a chosen site or burn them. Secondary Schools with Landscape 10% of the Secondary School in the districts visited during the fieldwork have some sort of landscape, which is of utmost importance in checking erosion. It must be mentioned that in the forest zone, due to the abundance of rainfall, landscape is easily carried out and maintained. The Need for Facilities as per Order of Importance The need for sanitation facility, water points, electricity, telephone, refuse disposal system, and landscape was discussed during the fieldwork with District Authorities, District Directorate of Education, members of Parent-Teachers Associations, Head teachers, Teachers, and school pupils. It was observed that water points and sanitation facilities were chosen equally as the most important necessity of Secondary School. These were followed by electricity, refuse disposal system, landscape and telephone, in that order. Adult Literacy Adult literacy programs appears to have been most active in the savannah zone, with three quarters of the households living in communities, where there is or has been an adult literacy program. The table below shows households living in communities, where there is or has been an adult literacy program. Households living in communities, where there is or has been an adult literacy program Ecological Households living in communities, where there is or has Zone been adult literacy program Coastal 61.0% Forest 56.0% Savannah 76.0% Major Health Problems Facing Households in Rural Communities Rural community dwellers are exposed to a host of health problems related directly to inadequate water (quality) and quantity) and lack of proper sanitary provisions. These problems are compounded by absence of basic health infrastructure and health education. Some of the common diseases are malaria, guinea worm, kwashiorkor, cholera and diarrhea. The table below shows the major health problems facing household in rural communities by ecological zones. GSEIP-ESMF Page 68 Major Health Problems Facing Households in Rural Communities Ecological Malaria Hernia Guinea Bilharzias Measles Cholera Others Total Zone Worm Coastal 59% 5% 19% 2% 3% 5% 7% 100% Forest 63% 2% 2% 13% 4% 6% 10% 100% Savannah 40% 25% 11% 1% 11% 0% 12% 100% 54% 11% 11% 5% 6% 4% 10% 100% Industry of economically active Population The economically active population as per ecological zone are employed or engaged in different sectors i.e. agriculture, mining and quarry, manufacturing, construction, public administration, and education among others. The details have been presented in the table below: Industry of Economically Active Population Industry Savannah Forest Coastal Agriculture, Hunting, Forestry 71.81% 54.34% 50.04% Fishing 3.04% 3.86% 6.12% Mining and Quarry 1.18% 1.87% 1.71% Manufacturing 7.27% 9.49% 11.89% Electricity. Gas, Water 0.53% 0.50% 0.42% Construction 0.72% 1.65% 2.24% Wholesale and Retail Trade 6.60% 13.19% 11.70% Hotels and Restaurants 1.42% 2.68% 2.89% Transport, Storage and Communication 1.15% 2.87% 2.94% Financial Intermediation 0.17% 0.29% 0.34% Real Estate & Business Activity 0.78% 0.66% 1.14% Public Administration 0.54% 0.86% 0.91% Education 1.49% 2.91% 3.09% Health and Social Work 0.36% 0.79% 0.74% Other Community Service 1.47% 3.49% 3.30% Private Households 1.43% 0.51% 0.50% Extra-territorial organization 0.04% 0.03% 0.03% Source: Computed from 2000 Population and Housing Census Household Expenditure The mean annual household expenditure and the mean annual per capita expenditure according to ecological zones have been presented in the Table below: Household Expenditure Mean annual household expenditure, ¢ Mean annual per capita expenditure,¢ Savannah 8,689,724 1,393,150 Forest 15,056,307 3,704,038 Coastal 16,937,427 4,255,723 Source: Ghana Living Standard Survey, 2000 GSEIP-ESMF Page 69 Solid Waste Management Practices Solid Waste Management forms an essential part of the primary school construction and operation. It involves technical, managerial, administrative, logistical and financial support at the local level. It is aimed at:  Ensuring and protecting public health within communities and the schools and  Promoting environmental hygiene and cleanliness in the schools and the communities. Solid Waste Composition Knowledge on the source and types of solid wastes, along with the data on its composition and generation rates, is basic to the design and operation of all elements of the Solid Waste Management System. The term solid waste is all- inclusive and encompasses all source, classifications, compositions and properties. The following major solid waste categories related to this project can be distinguished: i. Domestic Solid Waste ii. Commercial Solid Waste iii. Constructional/Demolition waste. Visits to the schools showed little variations in composition as well as in quantities generated per capita. The similarities are mainly linked to the similarities in socio- economic conditions, climate, school size, personal consumption habits etc. The solid waste generation is estimated to be between 0.2 – 0.5kg per capita per day. Solid Waste Collection, Transportation, and Disposal Mostly, solid waste bins are placed at vantage points in the schools for waste collection. The waste after having been collected is mostly not segregated. The means of transportation have been either wheelbarrows or carried by pupils to the various disposal sites. These disposals sites are some pits 10-30m away from the schools where they are dumped and at times burnt. Because of the nature of the waste, not all are burnt and thus rendering the pits full within a very short time. The waste usually contains large quantities of sand which also contribute to making the pits full very fast. Pits are therefore dug very often all around the school premise with its associated environmental impact. Generally, solid waste from within the communities are collected and transported to selected solid waste dumpsites by the District or Metropolitan Assemblies. In most urban areas, private companies have been involved in the collection, transportation and disposal of solid waste. Estimating Quantity of Solid Waste Generation An average weight of 0.2 – 0.5-kg/capital/day of solid waste is generated in the schools visited. A class should have an average of 25-35 pupils. Normally a primary school would have six classes, and a head teachers office. The average population of the schools visited including the teachers is 220. The teachers’ accommodation, which is part of the project, is likely to provide an additional population of 20 making the total population to be 240. This population multiplied by the average capita waste generation per day is 84 –120 kg/day per school. GSEIP-ESMF Page 70 Annex 4. School Planning and Construction Checklist ENVIRONMENTAL AND SOCIAL MANAGEMENT AND MONITORING GUIDELINES A) Design and Planning Stage Environmental Guidelines Responsibility Design Aspects: • Design Engineer / (1) Building’s Design and Layout should: Architect (a) not infringe easement rights of the neighbors (b) have architectural features in conformity to general landscape of the area (c) 3 cater for required capacity of approximately 5-6 m space per child • PIC (d) be in consonance with local climatic, environmental, and meteorological conditions (e) prefer local construction materials • Dy. DEO / Head (f) incorporate proper ventilation and provision of sunshine, air movement, and maximum usage of the Teacher Concerned daylight (g) cater for requirements of special children (children with disabilities), e.g., provision of wheelchair-ramp, side rails along stairs, and studded floors for blinds, where needed (h) incorporate toilet facilities separate for boys and girls (j) make provision for drainage of the spilled water away from hand pump borehole by providing a concrete platform (k) provide for floor platform of the hand pump with a slope so that water does not stay (l) provide safe access by having culverts on watercourses or ditches on school route (m) provide for internal footpaths and or pavements to ensure all weather access (n) provide hand washing arrangement outside lavatories and display instructions for washing hands after attending toilet (o) provide for toilet wastewater's outlet connection to the nearest sewer / wastewater-draining channel. It should not open to the ground outside (see Fig. 13 and 14). If public sewer system not available, a septic GSEIP-ESMF Page 71 tank of adequate capacity be included in the design (p) be in accordance with the applicable building code (q) provide for availability of safe drinking water at convenient locations in the premises (2) The Architectural Layout should not: (a) place toilets close to the classroom block (b) place the toilets at such a location wherein the general wind direction is from toilets towards classrooms (c) place toilets near to drinking water source (d) allow hanging electricity wiring (prefer concealed wiring) (e) place electricity switches and panels within reach of toddlers (3) Do not install electricity poles in the middle of playground or school compound (4) No high voltage electric lines be passing over the school premises (see Fig. 1) GSEIP-ESMF Page 72 B) Construction Stage Environmental Guidelines Responsibility Air Quality Concerns Construction Contractor (1) Carryout dust and emission producing activities (Operating machinery, loading/offloading materials) preferably after school hours to minimize exposure to schoolchildren (2) Keep machinery and vehicles adequately tuned up and well serviced School Incharge (3) Use only new and unadulterated fuels and lubricants. Do not use spent oil (4) Avoid operating machinery and equipment in windy conditions (5) Cover loose materials (e.g., sand, soil) with canvas/plastic sheets while stacked onsite or transporting on a vehicle. If sheeting is not possible, then lightly sprinkle the surface with water (6) Instruct the vehicle drivers to lower down the speed on earthen and narrow rural roads and road bends to reduce blowing of drag dust (7) Obscure and isolate the active construction zone by vertical shields / blinds Water and Wastewater Construction contractor (1) Do not draw water from a shared community water source without consent of the community (2) Dispose of the wastewater by draining into the nearby drain or through a soaking pit (3) Avoid throwing liquids/chemicals/paints into nearby water bodies or on land (4) Avoid washing machinery, vehicles, construction implements in nearby surface waters (5) Wastewater pipeline from toilets and lavatories be buried and well secured into the ground to avoid its damage by vehicles, animals, and miscreants (6) Provide containment structures or water diverting barriers in front of low lying rooms GSEIP-ESMF Page 73 Noise Pollution Construction Contractor (1) Operate noise producing construction machinery preferably after school hours (2) Avoid operating construction machinery at night time (3) Carryout fabrication and loading /unloading activities preferably after school hours School Incharge Public Utilities Construction Contractor (1) Carryout excavations / diggings after referring the local utilities layout map (2) Devise a standard operating procedure for dealing with accidental damage to utilities along with an immediate restoration plan (3) Relocation of any public utility or facility be carried out well ahead of start of construction Cultural and Archaeological Heritage Design Engineer (1) Avoid wastewater drainage to a nearby cultural and heritage site, if any (2) Avoid dumping of waste materials near to such sites or even at places which are objected to by the community (3) discovery of a site of historical, cultural, or archaeological importance be reported to concerned authority / Construction Contractor archaeology department GSEIP-ESMF Page 74 Social Environment / Worksite Safety Construction contractor (1) Make working staff aware of risks of personal injuries and the ways of avoiding (e.g., wearing helmets, dust masks, earmuffs, safety goggles, gloves, etc.) (2) Keep a first-aid box handy at the construction site (3) The Site supervisor should know the standard operating procedures (4) Keep schoolchildren off the active construction spots (5) Use indicative signage and warning boards (6) Stockpile the waste materials at a single spot preferably on one side the premises (7) Reuse the demolition waste, debris, and excess soil for filling depressions and for making pavements etc. (8) Do not leave the excavated foundations unfilled for long periods (9) Pay wages according to Government’s notified minimum wage rates (10) Pay same wages to women as to men for equal hours of work (11) Avoid child labour (12) Keep fire fighting arrangements ready at the site (13) Do not allow cigarette smoking and lighting of fire near work places and near inflammable materials (14) Store the ignitable and inflammable materials separately and at a safe place away from any source fire Ecological Environment and Habitat (1) Avoid undertaking construction activities in notified ecologically sensitive and protected areas (2) Avoid disturbance or damage to protected wildlife GSEIP-ESMF Page 75 C) Operation Stage Environmental Guidelines Responsibility Water and Wastewater School In charge (1) Install water storage tank of at least 4 hours supply, based on consumption pattern/needs (2) Carryout periodic cleaning and disinfection of storage tank, at least after every 6 months (3) Use Health Department’s recommended disinfectants only (4) Carryout regular and periodic laboratory testing of groundwater/drinking water quality (5) Install water filters, if required on the basis laboratory testing (6) Prefer source disinfection, wherever feasible (7) ensure proper working of the septic tank (8) Ensure regular cleaning and removal of grit from the drainage line (9) Display instructions at prominent places, particularly near the lavatories and water points, requesting the schoolchildren not to throw any solid article and paper into the wastewater drains or closets (10) Prevent flow of wastewater towards drinking water source (hand pump) in case of damage or leakage of the effluent pipeline (11) Keep an emergency plan handy for dealing with an emergency GSEIP-ESMF Page 76 Air Quality, Aesthetics, and Landscape School Incharge (1) Sweep the floors after light sprinkling with water (2) Carryout soaked cloth mopping of the furniture and other articles (3) Liaise with the Forest Department for obtaining and planting trees and vegetative cover during each plantation season. Protect saplings by observing the recommended watering schedule and trimming (4) Keep the fire fighting arrangements handy (5) Periodically check for adequacy of the fire fighting arrangements (6) Educate and make schoolchildren aware of dealing with emergency (7) Keep the stove, heater, and or other similar articles out of reach of children (8) Avoid open burning of solid waste in the school (9) Do not store any ignitable or inflammable material in the school (10) Display telephone numbers of the local rescue agency at prominent places GSEIP-ESMF Page 77 Annex 5. Terms of reference for ICU Environmental Consultant How this role and position will fit into the ICU administrative structure is yet to be determined. This TOR describes the essential tasks required to support the environmental and social screening, review, appraisal and monitoring requirements for all MOE school construction and rehabilitation. The Advisor/Consultant will support the overall ESMF and RPF environmental and social due diligence with:  Development of all MOE/ICU/PBME background information related to E&S application requirements for submission to EPA  ensuring that the applications are screened and reviewed using the E&S Checklist and Screening Form  the preparation of each School Screening Form, EPA Form 1, EPA Permit requirements and any Land Allocation./Donation documents  discussions with District Assembly officials all E&S requirements and integration with authorized construction engineers, contractors and supervisory contractors  technical advice, on an as needed basis to School planning and construction authorities and their representatives on E&S provisions and the requirements for final due diligence reports  monitoring school construction as it relates to adherence with the E&S requirements and associated guidelines,  resolving implementation bottlenecks, and ensuring overall that E&S requirements proceeds smoothly;  conducting the annual E&S audit for all completed school construction projects  collecting and managing E&S information relevant to the implementing authorities all the national and district levels (i.e. environmental monitoring and audit reports); and  developing the annual E&S school construction status report The Advisor/Consultant will be retained on a full or part time basis pending determination by the ICU and PBME management. In addition, provide technical advice on environmental management and mitigation practices for the MOE and District Assemblies to enhance E&S provisions by developing:  A series of Technical Planning Guidelines specific to the ICU based on the types of school construction projects coming into the program cycle built upon the checklists and other Guidelines provided with this ESMF.  Liaise with the appropriate District Officers to share knowledge and explain the objectives and E&S requirements in their Districts, and  Lead the delivery of capacity-building programmes for interested stakeholders. GSEIP-ESMF Page 78 Annex 6. Example of environmental contract clauses Proper environmental management of construction projects can be achieved only with adequate site selection and project design. As such, the EA for projects involving any new construction, or any rehabilitation or reconstruction for existing projects, should provide information as to screening criteria for site selection and design including the following: Site selection Sites should be chosen based on community needs for additional projects, with specific lots chosen based on geographic and topographic characteristics. The site selection process involves site visits and studies to analyze: (i) the site’s urban, suburban, or rural characteristics; (ii) national, state, or municipal regulations affecting the proposed lot; (iii) accessibility and distance from inhabited areas; (iv) land ownership, including verification of absence of squatters and/or other potential legal problems with land acquisition; (v) determination of site vulnerability to natural hazards, (i.e. intensity and frequency of floods, earthquakes, landslides, hurricanes, volcanic eruptions); (vi) suitability of soils and subsoils for construction; (vii) site contamination by lead or other pollutants; (viii) flora and fauna characteristics; (ix) presence or absence of natural habitats (as defined by OP 4.04) and/or ecologically important habitats on site or in vicinity (e.g. forests, wetlands, coral reefs, rare or endangered species); and (ix) historic and community characteristics. Project design Project design criteria include, but are not limited to, the consideration of aspects such as heating, ventilation, natural and artificial light energy efficiency, floor space (ft2) per bed/ward, requirements for x-ray rooms, adequacy of corridors for wheel chair/bed access, adequate water supply and sanitation systems , historical and cultural considerations, security and handicapped access. Construction activities and environmental rules for contractors The following information is intended solely as broad guidance to be used in conjunction with local and national regulations. Based on this information, environmental rules for contractors should be developed for each project, taking into account the project size, site characteristics, and location (rural vs. urban). After choosing an appropriate site and design, construction activities can proceed. As these construction activities could cause significant impacts on and nuisances to surrounding areas, careful planning of construction activities is critical. Therefore the following rules (including specific prohibitions and construction management measures) should be incorporated into all relevant bidding documents, contracts, and work orders. Prohibitions The following activities are prohibited on or near the project site: o Cutting of trees for any reason outside the approved construction area; o Hunting, fishing, wildlife capture, or plant collection; GSEIP-ESMF Page 79 o Use of unapproved toxic materials, including lead-based paints, asbestos, etc. o Disturbance to anything with architectural or historical value; o Building of fires; o Use of firearms (except authorized security guards); o Use of alcohol by workers. Construction Management Measures Waste Management and Erosion: Solid, sanitation, and, hazardous wastes must be properly controlled, through the implementation of the following measures: Waste Management: o Minimize the production of waste that must be treated or eliminated. o Identify and classify the type of waste generated. If hazardous wastes (including health care wastes) are generated, proper procedures must be taken regarding their storage, collection, transportation and disposal. o Identify and demarcate disposal areas clearly indicating the specific materials that can be deposited in each. o Control placement of all construction waste (including earth cuts) to approved disposal sites (>300 m from rivers, streams, lakes, or wetlands).Dispose in authorized areas all of garbage, metals, used oils, and excess material generated during construction, incorporating recycling systems and the separation of materials. Maintenance: o Identify and demarcate equipment maintenance areas (>15m from rivers, streams, lakes or wetlands). o Ensure that all equipment maintenance activities, including oil changes, are conducted within demarcated maintenance areas; never dispose spent oils on the ground, in water courses, drainage canals or in sewer systems. o Identify, demarcate and enforce the use of within-site access routes to limit impact to site vegetation. o Install and maintain an adequate drainage system to prevent erosion on the site during and after construction. Erosion Control o Erect erosion control barriers around perimeter of cuts, disposal pits, and roadways. o Spray water on dirt roads, cuts, fill material and stockpiled soil to reduce wind-induced erosion, as needed. o Maintain vehicle speeds at or below 10mph within work area at all times. GSEIP-ESMF Page 80 Stockpiles and Borrow Pits o Identify and demarcate locations for stockpiles and borrow pits, ensuring that they are 15 meters away from critical areas such as steep slopes, erosion-prone soils, and areas that drain directly into sensitive waterbodies. o Limit extraction of material to approved and demarcated borrow pits. Site Cleanup o Establish and enforce daily site clean-up procedures, including maintenance of adequate disposal facilities for construction debris. Safety during Construction The Contractor’s responsibilities include the protection of every person and nearby property from construction accidents. The Contractor shall be responsible for complying with all national and local safety requirements and any other measures necessary to avoid accidents, including the following: o Carefully and clearly mark pedestrian-safe access routes. o If school children are in the vicinity, include traffic safety personnel to direct traffic during school hours. o Maintain supply of supplies for traffic signs (including paint, easel, sign material, etc.), road marking, and guard rails to maintain pedestrian safety during construction. o Conduct safety training for construction workers prior to beginning work. o Provide personal protective equipment and clothing (goggles, gloves, respirators, dust masks, hard hats, steel-toed and –shanked boots, etc.,) for construction workers and enforce their use. o Post Material Safety Data Sheets for each chemical present on the worksite. o Require that all workers read, or are read, all Material Safety Data Sheets. Clearly explain the risks to them and their partners, especially when pregnant or planning to start a family. Encourage workers to share the information with their physicians, when relevant. o Ensure that the removal of asbestos-containing materials or other toxic substances be performed and disposed of by specially trained workers. o During heavy rains or emergencies of any kind, suspend all work. o Brace electrical and mechanical equipment to withstand seismic events during the construction. Nuisance and dust control To control nuisance and dust the Contractor should: o Maintain all construction-related traffic at or below 15 mph on streets within 200 m of the site. o Maintain all on-site vehicle speeds at or below 10 mph. o To the extent possible, maintain noise levels associated with all machinery and equipment at or below 90 db. GSEIP-ESMF Page 81 o In sensitive areas (including residential neighborhoods, hospitals, rest homes, etc.) more strict measures may need to be implemented to prevent undesirable noise levels. o Minimize production of dust and particulate materials at all times, to avoid impacts on surrounding families and businesses, and especially to vulnerable people (children, elders). o Phase removal of vegetation to prevent large areas from becoming exposed to wind. o Place dust screens around construction areas, paying particular attention to areas close to housing, commercial areas, and recreational areas. o Spray water as needed on dirt roads, cut areas and soil stockpiles or fill material. o Apply proper measures to minimize disruptions from vibration or noise coming from construction activities. Community Relations To enhance adequate community relations the Contractor should: o Following the country and EA requirements, inform the population about construction and work schedules, interruption of services, traffic detour routes and provisional bus routes, as appropriate. o Limit construction activities at night. When necessary ensure that night work is carefully scheduled and the community is properly informed so they can take necessary measures. o At least five days in advance of any service interruption (including water, electricity, telephone, bus routes) the community must be advised through postings at the project site, at bus stops, and in affected homes/businesses. Chance Find Procedures for Culturally Significant Artifacts The Contractor is responsible for familiarizing themselves with the following “Chance Finds Procedures�, in case culturally valuable materials are uncovered during excavation, including: o Stop work immediately following the discovery of any materials with possible archeological, historical, paleontological, or other cultural value, announce findings to project manager and notify relevant authorities; o Protect artifacts as well as possible using plastic covers, and implement measures to stabilize the area, if necessary, to properly protect artifacts o Prevent and penalize any unauthorized access to the artifacts o Restart construction works only upon the authorization of the relevant authorities. Environmental Supervision during Construction The bidding documents should indicate how compliance with environmental rules and design specifications would be supervised, along with the penalties for non-compliance by contractors or workers. Construction supervision requires oversight of compliance with the manual and environmental specifications by the contractor or his designated environmental supervisor. Contractors are also required to comply with national and municipal regulations governing the environment, public health and safety. GSEIP-ESMF Page 82 Annex 7. SEIP Environmental and social screening form Sub-project name: Subproject Location (include map/sketch): (e.g. district, etc). Type of activity : (e.g. new construction, rehabilitation, periodic maintenance) Estimated Cost: Proposed Date of Commencement of Work: Technical Drawing/Specifications Reviewed (circle answer): Yes No This report is to be kept short and concise. 1. Site Selection: When considering the location of a school project, check if the proposed site has the following potential impacts. They do indicate a real risk of causing undesirable adverse environmental and social effects, and that more substantial environmental and/or social assessment may be required to adequately avoid, mitigate or manage potential effects. Issues Impact or Risk Check if of Concern Natural habitats Critical natural habitats present Water quality and water Intensive water use; multiple water users; potential for conflicts resource availability and use is high; water quality issues are important Natural hazards vulnerability, Mountainous terrain; steep slopes; unstable soils; high erosion floods, soil stability/ erosion potential; volcanic, seismic or flood risks Cultural property Known heritage sites in project area Involuntary resettlement High population density; major towns and villages; low-income families and/or illegal ownership of land; communal properties; unclear land ownership rights 2. Checklist questions: Physical data: Yes/No answers and bullet lists preferred except where descriptive detail is essential. Site area in acres Extension of or changes to existing alignment Any existing property to transfer to sub-project Any plans for new construction Refer to project application for this information. GSEIP-ESMF Page 83 Preliminary Environmental Information: Yes/No answers and bullet lists preferred except where descriptive detail is essential. State the source of information available at this stage (proponents report, EIA or other environmental study). Has there been litigation or complaints of any environmental nature directed against the proponent or sub-project Refer to application and/or relevant environmental authority for this information. Identify type of activities and likely environmental impacts: Yes/No answers and bullet lists preferred except where descriptive detail is essential. What are the likely environmental impacts, opportunities, risks and liabilities associated with the sub-project? Refer to Technical Planning Guidelines – Impact, Mitigation and Monitoring Guidelines Determine environmental screening category: Yes/No answers and bullet lists preferred except where descriptive detail is essential. After compiling the above, determine which category the subproject falls under based on the EPA environmental categories A, B and C. Refer to Technical Planning Guidelines – Screening and Review Process Environmental Assessment Report or environmental studies required: Yes/No answers and bullet lists preferred except where descriptive detail is essential. If Screening identifies environmental issues that require an EIA or a study, does the proposal include the EIA or study? Indicate the scope and time frame of any outstanding environmental study. Required Environmental Monitoring Plan: If the screening identifies environmental issues that require long term or intermittent monitoring (effluent, gaseous discharges, water quality, soil quality, air quality, noise etc), does the proposal detail adequate monitoring requirements? Refer to Technical Planning Guidelines – Impact, Mitigation and Monitoring Guidelines Public participation/information requirements: Yes/No answers and bullet GSEIP-ESMF Page 84 lists preferred except where descriptive detail is essential. Has consultation been completed? Indicate the time frame of any outstanding consultation process. Refer to Chapter 2 – Relevant legislative acts Land and resettlement: Yes/No answers and bullet lists preferred except where descriptive detail is essential. What is the likelihood of land purchase for the project? How will land be acquired/purchased? What level or type of compensation is planned? Who will monitor actual payments? Refer to the Resettlement Policy Framework. Actions: List outstanding actions to be cleared before construction begins. Approval/rejection Yes/No answers and bullet lists preferred except where descriptive detail is essential. If proposal is rejected by EPA for environmental reasons, should the site be reconsidered, and what additional data would be required for approval? Recommendations: Requires an EIA and/or RAP, to be submitted on date: Requires EMP, to be submitted on date:. Does not require further environmental studies Reviewer : Name: Signature: Date: GSEIP-ESMF Page 85 Annex 8. E&S Due Diligence Checklist School Construction Environmental & Social Due Diligence Checklist School Name: ____________________________________________________ Location: _____________________________________________________ Construction Completion date: ____________________________________________________ Construction Plan—check all that apply:  Followed standard construction design  ICU review and approval  Construction completed and school in operation with all required facilities E&S Considerations—check all that apply:  Proper site selection  Land acquisition or donation properly documented  Documented process to assess Environmental and Social impacts and risks of its projects  Project site visits conducted as part of E&S screening and review  District and MOE authorities reviewed E&S process  Grievance process established and working EPA Approval and Permit—check all that apply:  EPA Form 1 Screening submitted  EPA Review documented  EIA required yes ____ no____  If EIA required, approved and permitted Third Party Audit E&S Specifications—check all that apply:  Conducted by _____________________________________  Confirms all E&S requirements completed E&S Authorized Certification:  Independent E&S performance reviewed and cleared  MOE Sustainability Advisor _________________________________________________  MOE PBME Director _______________________________________________________  MOF SEIP Representative ___________________________________________________ If any E&S Outstanding Issues Is There an Agreed Remedial Action Plan—list and explain:  Required additional actions  Any outstanding or unresolved grievances?  Target Dates  Management authority Attachments  Approved Engineering design  Photos GSEIP-ESMF Page 86