ETUDE D’IMPACT ENVIRONNEMENTAL ET SOCIAL …...93%. Identification, analysis and evaluation of the...

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WEST AFRICAN POWER POOL SYSTEME D’ECHANGES D’ENERGIE ELECTRIQUE OUEST AFRICAIN ETUDE D’IMPACT ENVIRONNEMENTAL ET SOCIAL DU PROJET D’INTERCONNEXION CÔTE D’IVOIRE LIBERIA SIERRA LEONE GUINEE COTE D’IVOIRE Projet de rapport final Septembre 2011 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

Transcript of ETUDE D’IMPACT ENVIRONNEMENTAL ET SOCIAL …...93%. Identification, analysis and evaluation of the...

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WEST AFRICAN POWER POOL SYSTEME D’ECHANGES D’ENERGIE ELECTRIQUE OUEST AFRICAIN

ETUDE D’IMPACT ENVIRONNEMENTAL ET SOCIAL DU PROJET D’INTERCONNEXION CÔTE D’IVOIRE – LIBERIA

– SIERRA LEONE – GUINEE

COTE D’IVOIRE

Projet de rapport final

Septembre 2011

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Executive Summary - ESIA

Project : Environmental Impact Assessment and Social Project

Interconnection Cote d'Ivoire-Liberia-Sierra Leone-Guinea

Owner : WAPP

Supervisor : Ministry of Mines and Energy / SOPIE

Financing : World Bank - European Investment Bank

Consultant : CEDA CONSULT KEPCO

Mission : Works topographic and Environmental Impact Assessment and

Social

Project Area : Axe Man - Liberia Border

As part of the implementation of its priority projects, the Secretariat of the West African Power Pool (WAPP), decided the project of constructing the 225 kV power line between the City of Man Coast Ivory and the border of Liberia through the town of Danane in Cote d'Ivoire. Such a project has impacts on the natural and human environment. Therefore, the guide Environmental Impact Assessment of ECOWAS in electricity requires an ESIA is carried out for this type of project. The Consultant CEDA CONSULT KEPCO has been committed to develop this study. He relied on the Bureau of Studies ENVAL Cote d’Ivoire

to achieve the ESIA on the Ivorian parties of the layout of interconnection project Ivory Coast - Liberia - Sierra Leone - Guinea.

Institutional and regulatory framework of the study

This study is based on three regulatory tools and institutions of the national policy on environmental protection, namely i) National Plan of Action for the Environment (NEAP) which is the guiding framework to better understand the environmental problems in Cote d’Ivoire, ii) Law No. 96-766 of 3 October 1996 on the code of the Environment, and iii) Decree No. 96-894 of 8 November 1996 laying rules and procedures applicable to studies on the environmental impact of development projects.

Project Presentation

The initiator of the project is West African Power Pool which is the structure of the ECOWAS sub-regional organization responsible for and development of interconnected power system. This institution is the developer of this project. The prime contractor for the Project for the Ivorian is provided by the Corporation Operation Ivory Electricity (SOPIE), on behalf of the Ministry of Mines and Energy. SOPIE is a State corporation established by Decree No. 98-728 of 16 December 1998 in favor of the liquidation of Electric Energy in Cote d'Ivoire (EECI).

Initial status of project site

Climate

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The climate is Sudanese-Guinean to two (2) distinct seasons with dry from November to March, with precipitation less than fifty (50) millimeters of water, and another rainy from April to October marked by an average of 1,600 millimeters of water. The average temperature of 24.5° is intermediate between the maxima in February-March to 33.3°, and the minimum from December to January to 16.5°.

Hydrography

Man on the border with Liberia through Danané Project successively through a number of rivers including those who have a certain size (more than 15-30 meters wide) are: south of the city Man, Ko, at the entrance to Sangouin, the N'Zo (tributary right bank of Sassandra), midway between Danane and Mahapleu, the upper Cavally out of Danane to the border, Moan , and the border Nipou which is the territorial limit Ivory Coast - Liberia

Geology

The path of the interconnection Man-Danan Frontier Liberia is fully included in the Archean is to say the area where you can find older basement rocks. Man near the border with Liberia. The project route recut successively ferruginous quartzites (which are iron ores), gneisses, granites, charnockites (hypersthene granite), granodiorite, syenite, migmatites, mafic and ultramafic rocks, intruded by either injections of norite and dolerite.

Soils

All along the route, there are two types of soils: Soil lateritic strongly desaturation, from hypersthene granites and lateritic soils and moderately strongly desaturated, from granites.

Biological Environment

Vegetation

The area for the 18 Mountain regions with its two departments that are Man and Danane. In this region, the vegetation is very degraded. The area is largely occupied by second regeneration fallow and cultivated areas. There are still relics of natural forest corresponding to sacred forests or forest galleries. The forest type is specific to this area the forest and Celtis spp Triplochiton scleroxylon.

On analysis, we found that vegetation is dominated by fallow, and rarely secondary forest types. On a floristic list of 259 plant species include the characteristics as Celtis brownii abres and Celtis mildbraedii, Triplochiton scleroxylon (samba), Chrysophyllum perpulchrum (which is also found in evergreen forest and in the east of the Coast ivory), Aningeria altissima, Aningeria robusta (Anigre), Chrysophyllum giganteum, Funtunia elastica (pri), Mansonnia altissima (Bete), Holopetea grandis (Kééé) Pterigota macrocarpa (koto), Tecla verdoniana, Nesogordonia papaverifera (kotibé) Chlorophora regia (iroko), Antiaris africana (ako).

Wildlife

The region was once rich in fish and wildlife. But most of these species have been decimated by poaching wild, so it is becoming increasingly rare to detect their presence

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today. An equally important cause of this situation is the disappearance of their natural habitat consists of forest patches and gallery forests. However, there are still group species of mammals, birds, snakes and amphibians, fish.

Human Environment

The demographic situation

The departments of Man and Danane, the project area are part of the region of 18 mountains located in western Cote d’Ivoire. Man is the administrative center of the region.

Population in the region of Man belongs to the large cultural group of South summoned specifically ethnicity or Dan Yacouba. According to data from the General Census of Population and Housing, 1998, people in departments of Man and Danane are respectively 366,916 inhabitants (187,178 men and 179,738 women) and 314,428 inhabitants (including 156 797 men and 157 631 women), a total of 681,344 persons including 343,975 men and 337,369 women. Based on the annual rate of growth of the Ivorian population of 3.8%, we can estimate the total population of these two departments (Man and Danane) to 1,065,945 inhabitants.

This population consists of indigenous ethnic Yacouba and populations from diverse backgrounds of alien ethnic Baule, Malinke, Guere, Wobe, Agni, etc.. As foreigners they are composed of Liberians, Burkina Faso, Guinea, Mauritanians, Lebanese, etc.

The socio - cultural situation

The term is rooted in Mande linguistics. Mande peoples speaking related languages whose birthplace is located in the valley of the Niger in Segou Siguiri.

Apart Gagou and Ngan, the Mande - South can be considered essentially patrilineal societies.

The home unit is the most visible Yacouba tribe that called Sego. For Dan, one can speak of "micro-companies' policies grouped around a clan elder patriarch and his ruling religious-legal, ideological and more symbolic than material binding, and in times of intertribal war, around a conductor ad hoc war.

For Dan, the northern group of mountains or group speaks a language heavily influenced by Mahou. More or less converted to Islam with the intensification of the influence Malinke they take the names of their invaders Malinke. As the Kissi of Guinea forest, they are engaged in rice cultivation.

The second reference unit after the tribe is the clan. It is composed of descendants of a suspected male ancestor, a distant and more or less mythical. The clan has a name, its members adhere to a common person whose origin lies at the confluence of myth and history. The clan is not a territorial unit.

Within the clan is the village. It brings together several segments of clans, the so-called lineages, a space constructed in one piece, they are both independent as dependent on each other.

Each village consists of at least one district lineage, space occupied in one piece by

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members of a clan representatives. Its boundaries do his little apparent, it bears the name of the clan is represented.

The provision of housing which respects the social structure itself controls the land organization and distribution territory villagers. It is divided into many neighborhoods lineage available to the village, each managing its sector.

The method of resolving these conflicts is through negotiation of the institutionalized way. Indeed, in case of land disputes between two parties, there is the arrangement amicalby. In case of disagreement, the complainant appealed directly to the village head who settles the dispute in the presence of witnesses.

Once the village chief is seized and the two parties reach an agreement, it is requested the recipient of the parcel to provide Kolas nuts or a portion of income from land (not equally) to landowner with a view to reducing tension. Thus the leader reminds the landowner once it has sold its plot, it has a stronger claim on it under the contract.

The socio-economic

For the analysis of the factors identified throughout the trip, it is clear that agriculture is the main economic development in the villages immediately surrounding the project. These are agriculture shrub annuity focused on cocoa, coffee, rubber (up sharply), palm oil and kola.

In addition to these perennial crops, people who practice subsistence crops are mainly rice, cassava, corn, etc.. Vegetable crops are left. Indeed, people in the immediate vicinity of the project grow tomatoes, peppers, eggplant, okra, cabbage, green salad, etc.. Livestock is raised in the immediate vicinity of the project. This is cattle, sheep, poultry and swine. The breeding of cattle is in the hands of the Fulani.

The area of the project area electrical interconnection between Cote d’Ivoire and Liberia is

approximately 480 ha. While the area occupied is about 445 ha is an occupancy rate of 93%.

Identification, analysis and evaluation of the significance of project impacts

Negative impacts of the project

Laid bare soil with erosion risk

The earthworks for the opening of the corridor and for the eventual construction of mobile base camps promote differential erosion in areas that will be laid bare (the disappearing forest cover), as will be formed at the height of the ravine precipitation.

About borrow material, this study has the opportunity to inspect the existence of companies extracting gravel and sand that could contribute to the project. The use of these sub-contractors for the supply of borrow material will avoid new pressures on the environment.

Morphological changes

From the standpoint of morphology, the main impacts are related to the operations of

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excavation and sizing of the project area. Indeed, the work will lead to a slight modification of the topography and morphology. These impacts are small in geographic scope as confined to the project site.

Air pollution and noise

The work will have direct impacts on the atmosphere because they generate dust and exhaust from machinery, trucks and machinery for earthworks in their movements on site, and other noise-related work and movement of vehicles and equipment.

Water Contamination

Regarding the water in the project area, we observe the presence of many rivers that could suffer contamination from the effect of leaching and runoff from sewage. Groundwater may then be subject to contamination of mineral and organic matter due to infiltration of contaminated water. Drainage of oil spilled accidentally not be excluded.

Destruction of vegetation

As for the Vegetation, the work will generate more impact on formations located in the areas of direct and indirect influence of the project in terms of destruction and degradation. Samples from the vegetation contribute to the loss of biodiversity in the project area and especially to reduce carbon sinks that participate in reducing greenhouse gas emissions.

Destruction of wildlife habitat, wildlife migration-collision accidents

Destruction of vegetation that leads inevitably to wildlife habitats and thus the forced migration of wildlife in question. For some sensitive species, the work can disrupt or even derail the reproduction if the site is close to breeding sites or nesting areas. Throughout its operations, the line remains a source of permanent danger and risk should not be overlooked because of a collision can occur between birds and structures of power lines could cause a higher mortality rate among animal species especially birds.

Regarding particularly the aquatic fauna, it may suffer impacts due to contamination of surface waters by spills, leaching, drainage excavations which will increase turbidity and suspended solids, making the environment unsuitable for aquatic life.

Affect the quality of the environment by waste

The natural environment could be affected by pollution from construction waste reception facilities for workers (base camp or base site) and are comparable to domestic waste (office waste, canteen waste) or from construction (concrete, falling materials, packaging, welding slag, oils and lubricants). By polluting the environment in which the work is carried out, these wastes will degrade its quality.

Expropriation / Alienation of social space

The advent of a high voltage line proves to be a company that affects the spatial organization and social space of the riverside communities, but also economic activities including agriculture in the study area. This is alienation or expropriation of the social space of communities most often used in agricultural activities.

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Destruction of agricultural activities and income losses of farmers fields and many plantations are located in the direct control of the project. They will inevitably undergo a partial destruction or complete for some others, which represents operators for their substantial loss of income.

Desecration of cultural sites and cemetery desecration

Generally, in the project area, it is found that each village has its sacred forest. The work could lead to a "violation" and a partial destruction of these places so to be exposed to desecration.

In addition to these sacred forests, we note the presence of cemeteries near the corridor of power lines. These cemeteries may be desecrated by the work and the graves could be affected.

Undermine the peace, safety and health of people and workers.

The Powerline is a source of disturbance to the peace, safety and health of local populations because of the sound effects, radio interference, especially the risk of diseases associated with prolonged exposure to high voltage or accidents related to the step voltage.

In addition, with the opening of corridors or trenches and clearing of access roads, the permanent displacement of trucks, vehicles and machines may be factors of traffic accidents which may be suffered by the residents.

Finally, the problem of worker safety is related to the setting pylons that carry risks of loss of some elements which could be a source of danger to personnel working on the site.

The risk of spread of HIV/AIDS should not be dismissed because the project will result in recruitment of manpower from various origins and therefore a significant mixing of people who may favor the eventual spread of HIV/AIDS due contacts between the workforce and the local female population.

Affect the quality of the landscape

Located a distance of 116 km it overlooks at a distance of 20 meters from the ground at least, the high voltage line in the project, when completed, would prove an intruder presence, that is to say a body abroad in the social and spatial organization of communities and populations. Indeed, it can be considered an element of inconsistency in a natural landscape as it transforms the visual fields of agro-pastoral landscapes throughout his career.

Positive impacts of the project on the human environment

Many jobs

The project is a factor in creating many jobs and thus consumer of manpower in different categories. It will generate the creation of several temporary jobs for local labor in construction phase, which will reduce the unemployment rate at the level of local residents including those in towns and villages, and so contribute to the fight against poverty .

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Development of economic activities

The work will also promote development of economic activities circumstantial due to the presence of site personnel who will source during working hours in shops nearby.

Revitalization of Local Development

By creating new income generating opportunities related to the creation of jobs during construction work (for wages paid to the local workforce, economic development activities circumstantial), using local resources ( for good and services) provided by the surrounding towns and villages (fuel, lubricants and oils for different engines and trucks, housing managers in hotels, restaurants and underground attendance, etc..), we can say that the project should encourage the increase of local populations, so it should be a factor in boosting local development by participating significantly to the economic and commercial growth and hence development of the Departments of Man and Danane, at least during the construction period. Anything that will help in a last result, improving the quality of life of people in target communities.

Improving conditions of access to surrounding villages

In operation phase, the development of service roads or access to the corridor of high voltage is a factor of opening up many coastal villages where access is difficult due to impassable in rainy seasons especially tracks . After construction of the line, are rare interviews, the groomed trails facilitate access to these villages.

Mitigation measure for the negative impacts

Mitigation of impacts on the biophysical

Measures to prevent and reduce impacts on soils and morphology

In order to minimize the loss of soil "plants", it is recommended during excavation to strip superficial separately with an interest in their rich soil, then proceed with the excavation deeply of other land .

Topsoil may at the end of proceedings to be replacing material surface coverage. Then it can be made a revegetation with grasses suitable surface. This revegetation will be done as soon as possible after installation of the towers to reduce the effects of erosion on soil.

It should also develop and implement stabilization measures to minimize soil erosion on the construction site, verify the performance of stabilization measures after the rains and take necessary remedial action to be assured that these measures will continue to stop erosion during the next rains. At the end of the work, it must match the site of any pile of rubble.

Measures to prevent / reduce impacts on air quality

The air pollution on the dust emission related to the work and exhaust from vehicles. Thus, vehicles for transportation of materials and powder should be sheeted. In addition, the dust hazard to areas of waterfront activities will be minimized by compacting the land and watering tracks and leveled surfaces in dry weather.

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On the exhaust, it is recommended that the company work justifies the roadworthiness of vehicles used to ensure, among other things, compliance with standards for exhaust emissions regulations.

Measures to prevent / reduce impacts on water

Regarding the major rivers, they will be bypassed by deviations that lead to the main track. In the case of rivers, construction of riffles will help save wildlife and aquatic flora to promote rapid return to normal after work.

Reduction measures / compensation impacts on vegetation

To mitigate impacts on natural ecosystems, the following measures are recommended:

Compensate for loss of biodiversity by undertaking reforestation for villagers, failing to replant the deforested areas during operations. To this end, the study proposes that the Client to create for each of the villages and camps have suffered loss of vegetation, planting native species of good value as teak. This reforestation will not only participate in the restoration of local biodiversity but also to contribute to the fight against global warming by greenhouse gases.

In open areas, vegetation maintained at the base of the towers (Bush fallow) is a relay medium for small game and thus has a positive impact.

Measures to prevent / reduce impacts on wildlife

This is a part to restore natural ecosystems through the creation of new forests of village, and secondly to maintain the vegetation at the base of the towers to create natural habitats for wildlife that had migrated during work.

Furthermore, it should be installed on the pylons of equipment to protect birds: insulating sleeves, hoods, perches, nesting platforms, etc..

Measures to prevent the natural environment against pollution by waste from

construction sites

Solid waste from the site must be regularly collected and removed from the natural environment. General waste will be collected and disposed of in accordance with the standards of environmental protection. Industrial waste, toxic or contaminated (oil, filters, containers ....) Will be transported to reprocessing facilities approved.

Specifically regarding the vegetable waste from felling trees and Debrousse, and waste from the excavation, management measures have on their cutting boards in 1.50 meters. These boards can be reused by the company for the operations of shuttering if necessary, or be made available to local women, many of whom are sellers of firewood.

Measures to prevent / reduce impacts on the biophysical bases for the facility life

The sites where the mobile base camps often in this kind of project will be identified at the start of construction. A map or plan supplied by the contractor locate these sites. The company will define the equipment necessary to operate the quarters to accommodate the equipment, machinery and building personnel.

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The location of sites will be based on criteria of rationality for planning and operations but also neighborhood protection and natural resources. It must comply with standards does not affect the natural environment and human environment. If use of pollutants and hazardous storage will be made safe from the elements, under the code of practice guaranteeing the absence of risk of rupture of the packages and frequent spills.

Where the contractor provides a machine shop capable of accommodating craft and construction vehicles for servicing and routine maintenance, this workshop will include mandatory special equipment to collect used oil from garbage. Measures to be considered will also focus on the development of impervious platform for storage of oil products in containers adapted.

Mitigation of impacts on the human environment

Measures of compensation for land expropriation and destruction of property

Compensating fields, crops, plantations and land traversed allows authority to dispose of the Interconnection spaces occupied by the line as compensation, according to the regulations in this area, whether national or international: The decree of November 25,

1930 detailing the entire procedure the expropriation for public purposes, Decree No. 95-

817 of 29 September 1995 laying down the rules for compensation for destruction of crops, Order No. 028, March 12, 1996 on establishing the scale of compensation for crops destroyed by public works, Decree No. 96-884 of October 25, 1996 regulating the serving of customary land rights for public interest and the Guidelines for the Protection of the World bank.

Therefore, the study proposes that compensation covers the following:

Compensation for lost crops. Compensation for loss of agricultural land. Compensation for temporary loss of income.

Such compensation is personal, it should be stated that all measures are taken to be served as customary land rights.

All procedures for compensation and the details of compensation costs are analyzed in the report entitled "Resettlement Action Plan".

Measures to protect the safety and human health

The presence of a line nearby metal plant (fence, shed, antennas), requires the management of specific ground facilities for all these facilities. Uncertainties in long-term effects on the individual does not currently allow to rule on the matter, the precautionary principle in the context of public health must be observed. To observe this principle, the adoption of new standards for safety clearances for easements involve 80 to at least 100 meters of any dwelling place.

Furthermore, during construction, measures can be taken to limit the risk of collapse of the towers including the installation of anti-cascading towers to prevent chain collapse. The risk of electrocution through contact with conductors will be avoided by adhering to safe distance.

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Ways to reduce the discharges are essentially almost follow that of insulators, as they age, are the source of discharges by perforating or circumvention. The continuity of the grounding and a good resistance of the earth will allow the removal of electrostatic charges. Therefore, it is important to hold regular inspections and maintenance of power lines.

Against the risk of traffic accidents, it is necessary to provide adequate signage at the crossing of rural roads and tracks, so to minimize the risk of traffic accidents. Particularly in regard to persons outside the site.

Construction workers must be provided with all necessary safety equipment for civil engineering and electricity.

To this extent, it should put an emphasis on educating local populations, by including in the response plan an awareness campaign on environmental protection, the fight against HIV / AIDS and security Road.

The work will generate noise due to the movements of machinery, equipment and vehicles. These nuisances should be reduced as much as possible using good quality materials that emit little noise (appliances and new cars for example) and working standard hours of work.

Measures of waste management sites

Solid waste from the site must be collected in containers regularly removed and transferred into appropriate disposal areas (landfills formalized).

No waste should be buried or burned on site. The Contractor may, however be allowed to burn some waste fuels provided they meet all conditions of safety and avoiding the release of toxic fumes.

Only paper and cardboard packaging unpolluted, and the dried leaves and branches may be burned.

In order to prevent improper management and disposal of construction waste but also a scattering or burial of such waste with the risk of pollution of soil, water and landscape, it should meet the following environmental measures:

Cleaning of vehicles, Cleaning of the site during and after completion, and Maximum limit for submitting materials that do not undergo for immediate use.

Ordinary waste from the base camp will be collected and disposed of in accordance with the standards of environmental protection. Industrial waste, toxic or contaminated (oil, filters, containers,) will be transported to reprocessing facilities approved.

Regarding specifically the vegetable waste from felling trees and Debrousse, and waste from the excavation, management measures in cutting deals with their boards of 1.50 meter. These boards can be reused by the company for the operations of shuttering if necessary, or be made available to local women, many of whom are sellers of firewood.

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Measures to prevent / reduce impacts on the landscape

To limit the impact on the landscape in some areas it is possible to use reduced towers sheet. In this way it is possible to reduce the overhead cables by half but against these towers are taller by about a dozen meters. The impact brought by the introduction of high voltage line can be reduced by: Choosing a suitable design of the tower: Former media monopods whose silhouette

is thinner than the metal trusses supports. Extensive use of the capacity of absorption / integration landscape.

The selection and proper sizing of towers and other facility components, the integration of lines in the landscape (color tops avoided) are measures to reduce pollution at the end of aesthetic construction.

Environmental and Social Management Plan (ESMP)

An Environmental and Social Management Plan (ESMP) in two phases (construction

phase and operation phase), is proposed in this study to holistic management of project

impacts on the environment of the area. The institutional framework for implementing this

ESMP includes entities such as i) the contractor who will ensure compliance with

environmental measures, ii) an environment officer appointed by the company who will be

responsible for ensuring the application of environmental measures during the

construction phase, iii) environmental monitoring, in accordance with the applicable

provisions in Cote d’Ivoire, will be conducted by the National Environment Agency

(ANDE), which is empowered to verify the application on Field of the provisions of the

ESIA records, and finally, iv) The Monitoring Committee who will resolve any disputes that

may occur before, during and after the completion of the course.

On this basis, the company in charge of the work will be responsible for implementing

environmental measures. The company will rely on an official Environment. This provision

is the guarantee of the effective consideration of the environment in the implementation of

this project. Environmental monitoring will be the activity of ANDE. This institution may

utilize the expertise of specialized agencies in monitoring the environmental and social

parameters, both on the basis of environmental indicators proposed in the ESMP. In

addition, a Brief environmental and social clauses attached to the corporate market will be

useful for the effective implementation of environmental measures on the ground. Finally,

the monitoring committee, an advisory entity that will combine the local administrative

authorities and the Chieftaincy and NGOs active in the environmental field. A program of

activities and regular meetings will be prepared for its missions.

Contractors’ Environmental and Social Management Plan (CESMP)

Prior to the commencement of construction works, all contractors should be required to

prepare their own ESMPs (CESMP). The plan should be included in the bidding

documents and in the contractor’s contract and spell out environmental targets and

objectives as outlined in the ESIA/ESMP and how these could be achieved. The

Contractor’s ESMP (CESMP) shall include, to the extent practicable, all steps to be taken

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by the Contractor to protect the environment in accordance with the current provisions of

national environmental regulations, the World Bank Groups Environmental Health and

Safety General Guidelines and the Environmental, Health and Safety Guidelines for

Electric Power Transmission and Distribution, 2007 as well as the ESIA/ESMP for this

project. Provision should be made for the disposal of chemical/ hazardous wastes as the

local facilities do not exist for hazardous waste disposed. Also, for more complex

environmental management aspects, the Contractor needs to prepare and implement

Method of Statement which needs to be approved by the Supervising Engineer and the

SPC upon request. In this perspective, within 60 days of notification of contract award, the

Contractor shall demonstrate an understanding of environmental and social obligations.

In order to ensure adequate implementation of the CESMP and specific Method of

Statement, the Contractor needs to employ environmental staff for the proposed Project.

Notwithstanding the Contractor’s obligation spelt out above, the Contractor shall, in

addition, endeavor to implement all necessary measures to restore the project sites to

acceptable standards and abide by environmental performance indicators specified in the

ESIA/ESMP to measure progress towards achieving objectives during execution or upon

completion of any works. It will be largely based on the ESIA and ESMP include the

following information:

organizational staff with clear identification of the leader (s) responsible (s) of the

environment, responsible environmental management of the project and its (their) CV,

A general description of the methods that the Company proposes to adopt to reduce

the impact on the physical and biological environment of each phase of work.

A description of the actions that will implement the Contractor in each of the following

(not exhaustive):

These measures shall include but not limited to the following;

- Minimizing the effect of dust on the surrounding environment resulting from

concrete mixing sites, asphalt mixing sites, dispersing coal ashes, vibrating

equipment, temporary access roads, etc. to ensure safety, health and the

protection of workers and communities living downwind of dust generating

activities;

- Ensuring that noise levels emanating from machinery, vehicles and noisy

construction activities are kept at a minimum for the safety, health and protection

of workers within the vicinity of high noise levels and communities near rock-

blasting areas;

- Ensuring that existing water flow regimes in rivers, streams and other natural or

irrigation channels is maintained and/or re-established where they are disrupted

due to civil works being carried out;

- Preventing bitumen, oils, lubricants and waste water used/produced during the

execution of works from entering into rivers, streams, irrigation channels and

other natural water bodies/reservoirs and also ensure that stagnant water in

uncovered borrow pits is treated in the best way to avoid creating possible

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breeding grounds for mosquitoes;

- Preventing and minimizing the impacts of quarrying, earth borrowing, piling and

building of temporary construction camps and access roads on the biophysical

environment including protected areas and arable lands; local communities and

their settlements. In as much as possible restore/rehabilitate all sites to

acceptable standards;

- Ensuring that the discovery of ancient heritage(Chance Find Procedure), relics or

anything that might or believed to be of archaeological or historical importance

during the execution of works is reported to the Museums and Monuments Board

in fulfilment of measures aimed at protecting such historical or archaeological

resources;

- Discouraging construction workers from engaging in the exploitation of natural

resources such as hunting, fishing, and collection of forest products or any other

activity that might have a negative impact on the social and economic welfare of

the local communities;

- Implementing soil erosion control measures in order to avoid surface run off and

prevents siltation, etc.;

- Ensuring that garbage, sanitation and drinking water facilities are provided in

construction workers camps;

- Ensuring that in as much as possible, local materials are utilized to avoid

importation of foreign material and long distance transportation;

- Ensuring public safety and meeting traffic safety requirements for the operation of

moving machinery in order to avoid accidents;

- Discouraging the use of foul or infuriating words on project-affected persons

(PAPs) or any other persons seeking information on the project by construction

workers. All such persons and grievances should be politely referred to the

appropriate authority for redress.

- The overall management of the movement of land that the operation and

rehabilitation of borrow areas and quarries (anti-erosive planned redevelopment

planned); erosion control operations will be scheduled;

- Management of human resources;

- The prevention and mitigation of STDs and HIV / AIDS;

- Communication and information directed to people as well as to local and national

authorities;

- Conflict management;

- The use of commercial or business environment for local subcontracting;

- Description of the monitoring and control of the Environmental and Social

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Management Plan of the site. The measures will include the submission of

monthly reports to the supervisor. Any significant event or incident should be an

immediate report from the company.

This Environmental Management Plan will be submitted for technical approval of the

Supervisor, who will share his observations and his decision within 20 days of receipt.

Cut-off date

The public consultation was held from May 2010. So the beginning of Census(cut-off date)

is May 2010 by the definition of the World Bank OP 4.12. During the public consultation with

the PAPs, the consultant clearly informed and explained the concept of the “cut-off date” to

the PAPs in the presence of the village’s population. The consultant also informed that no

one shall be registered on the PAPs after the cut-off date..

The modification of the PAPs is unable to provide that by changing the line route.

Grievance Mechanism and Grievance Redress Committee

Dissatisfactions may arise through the process of compensation for a variety of reasons

including disagreement on the compensation value during valuation of assets,

controversial issue on property ownership etc.

To address the problem of PAPs during implementation of compensation, establishment

of a grievance redress committee is recommended with a participation of project affected

persons.

The main function of the committee would be arbitration and negotiation based on

transparent and fair hearing of the cases of the parties in dispute, Project Affected

Persons (PAPs), the implementing agencies and local government. The committee gives

solution to Grievances related to compensation amount, delays in compensation payment

or provision of different type of resettlement assistance.

Rational operational procedure is essential for Grievance mechanism with reflection to

aspects as described below:

All PAPs will be informed in case of any grievance regarding compensation can

approach to chair man of the grievance committee or the project implementer.

Any PAPs who have grievance would present his /her all case to the grievance

redress committee. The committee examines the case and responds with in period

of 15 days.

If the PAPs are not satisfied with the decision of the Grievance Redress

Committee (GRC), they can approach the regular court.

The objective of the grievance procedure stated above seeks to address the following:

Provide PAPs with avenues for making compliant or resolve any dispute that may

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the course of land, structure and any assets acquisition, including the process of

moving.

Ensure that appropriate and mutually acceptable corrective actions are identified

and implemented to address complaints; verify that complainants are satisfied with

outcomes of corrective actions; and avoid the need to resort to judicial

proceedings

Livelihood restoration program

The destruction of crops will result in loss of livelihood for some families. With the return

of exiled Liberian populations and displaced persons, poverty and insecurity have been

increased.

Assistance should be given to these people so they find ways to survive. Knowing that the

crops are short in 3-5 months to be harvested, and on the basis of the Agricultural

Minimum Wage (SMAG) adapted to current realities, it will take at least 30 000 FCFA for

each head of household. An allocation of 83.04 million FCFA will meet the needs of 692

PAPs for at least 4 months.

The overall cost of the ESMP and RAP amounts to 1,008,648,165 FCFA (USD

2,192,704)

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Executive Summary – ESMP

The WAPP Secretariat has decided the 225 KV power line interconnection project from the City of Man (Ivory Coast) to Sierra Leone, through Liberia and Guinea. This project of construction and the creation of new transmission facilities of electric power is part of the West African regional policy for electricity.

- Deforestation and the excavation along the right of the line - The expropriation of land (regulation Ivory Coast) - The destruction of crops and homes - The public health problems related to the flow of labor phase of the project - Poor health and safety during construction - The social conflict and land - Loss of wildlife habitat and endangered plant species

The management of these impacts through the establishment of an Environmental and Social Management Plan will implement to advocate effectively for the environmental and social measures. The ESMP is also to identify all the actors and their responsibilities for its implementation. A schedule of intervention is also proposed taking into account the different responsibilities.

The development of the ESMP is a response to regulatory requirements and Ivorian politics of the World Bank. Indeed, a plan for environmental and social management is required following the Environmental and Social Impact Study in order to provide the implementation objective of the proposed measures for the organization.

In order to better optimize the management of environmental and social impacts of the project, the ESMP provides the following:

Organizing the implementation of measures recommended by the establishment: - unit of the project which will supervise the construction of the line and ensure

compliance with the ESMP by the provider. - unit of conflict management and community complaints that collect grievances

and complaints of those affected by the project and provide suitable answers to these concerns.

These units work closely with the administrative authorities of the region and local notables.

- Developing an environmental monitoring program and social responsibility for which is provided by the SOPIE

- The establishment of a program monitoring environmental and social responsibility which will be provided by ANDE or interministerial technical committee jurisdiction over the matter

- The mitigation measures contained in a matrix that shows the actions, responsibilities, monitoring indicators and costs.

Contractors’ Environmental and Social Management Plan (CESMP)

Prior to the commencement of construction works, all contractors should be required to

prepare their own ESMPs (CESMP). The plan should be included in the bidding

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documents and in the contractor’s contract and spell out environmental targets and

objectives as outlined in the ESIA/ESMP and how these could be achieved. The

Contractor’s ESMP (CESMP) shall include, to the extent practicable, all steps to be taken

by the Contractor to protect the environment in accordance with the current provisions of

national environmental regulations, the World Bank Groups Environmental Health and

Safety General Guidelines and the Environmental, Health and Safety Guidelines for

Electric Power Transmission and Distribution, 2007 as well as the ESIA/ESMP for this

project. Provision should be made for the disposal of chemical/ hazardous wastes as the

local facilities do not exist for hazardous waste disposed. Also, for more complex

environmental management aspects, the Contractor needs to prepare and implement

Method of Statement which needs to be approved by the Supervising Engineer and the

SPC upon request. In this perspective, within 60 days of notification of contract award, the

Contractor shall demonstrate an understanding of environmental and social obligations.

In order to ensure adequate implementation of the CESMP and specific Method of

Statement, the Contractor needs to employ environmental staff for the proposed Project.

Notwithstanding the Contractor’s obligation spelt out above, the Contractor shall, in

addition, endeavor to implement all necessary measures to restore the project sites to

acceptable standards and abide by environmental performance indicators specified in the

ESIA/ESMP to measure progress towards achieving objectives during execution or upon

completion of any works. It will be largely based on the ESIA and ESMP include the

following information:

organizational staff with clear identification of the leader (s) responsible (s) of the

environment, responsible environmental management of the project and its (their) CV,

A general description of the methods that the Company proposes to adopt to reduce

the impact on the physical and biological environment of each phase of work.

A description of the actions that will implement the Contractor in each of the following

(not exhaustive):

These measures shall include but not limited to the following;

- Minimizing the effect of dust on the surrounding environment resulting from

concrete mixing sites, asphalt mixing sites, dispersing coal ashes, vibrating

equipment, temporary access roads, etc. to ensure safety, health and the

protection of workers and communities living downwind of dust generating

activities;

- Ensuring that noise levels emanating from machinery, vehicles and noisy

construction activities are kept at a minimum for the safety, health and protection

of workers within the vicinity of high noise levels and communities near rock-

blasting areas;

- Ensuring that existing water flow regimes in rivers, streams and other natural or

irrigation channels is maintained and/or re-established where they are disrupted

due to civil works being carried out;

- Preventing bitumen, oils, lubricants and waste water used/produced during the

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execution of works from entering into rivers, streams, irrigation channels and

other natural water bodies/reservoirs and also ensure that stagnant water in

uncovered borrow pits is treated in the best way to avoid creating possible

breeding grounds for mosquitoes;

- Preventing and minimizing the impacts of quarrying, earth borrowing, piling and

building of temporary construction camps and access roads on the biophysical

environment including protected areas and arable lands; local communities and

their settlements. In as much as possible restore/rehabilitate all sites to

acceptable standards;

- Ensuring that the discovery of ancient heritage(Chance Find Procedure), relics or

anything that might or believed to be of archaeological or historical importance

during the execution of works is reported to the Museums and Monuments Board

in fulfilment of measures aimed at protecting such historical or archaeological

resources;

- Discouraging construction workers from engaging in the exploitation of natural

resources such as hunting, fishing, and collection of forest products or any other

activity that might have a negative impact on the social and economic welfare of

the local communities;

- Implementing soil erosion control measures in order to avoid surface run off and

prevents siltation, etc.;

- Ensuring that garbage, sanitation and drinking water facilities are provided in

construction workers camps;

- Ensuring that in as much as possible, local materials are utilized to avoid

importation of foreign material and long distance transportation;

- Ensuring public safety and meeting traffic safety requirements for the operation of

moving machinery in order to avoid accidents;

- Discouraging the use of foul or infuriating words on project-affected persons

(PAPs) or any other persons seeking information on the project by construction

workers. All such persons and grievances should be politely referred to the

appropriate authority for redress.

- The overall management of the movement of land that the operation and

rehabilitation of borrow areas and quarries (anti-erosive planned redevelopment

planned); erosion control operations will be scheduled;

- Management of human resources;

- The prevention and mitigation of STDs and HIV / AIDS;

- Communication and information directed to people as well as to local and national

authorities;

- Training;

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- Conflict management;

- The use of commercial or business environment for local subcontracting;

- Description of the monitoring and control of the Environmental and Social

Management Plan of the site. The measures will include the submission of

monthly reports to the supervisor. Any significant event or incident should be an

immediate report from the company.

This Environmental Management Plan will be submitted for technical approval of the

Supervisor, who will share his observations and his decision within 20 days of receipt.

Cut-off date

The public consultation was held from May 2010. So the beginning of Census(cut-off date)

is May 2010 by the definition of the World Bank OP 4.12. During the public consultation with

the PAPs, the consultant clearly informed and explained the concept of the “cut-off date” to

the PAPs in the presence of the village’s population. The consultant also informed that no

one shall be registered on the PAPs after the cut-off date..

The modification of the PAPs is unable to provide that by changing the line route.

Grievance Mechanism and Grievance Redress Committee

Dissatisfactions may arise through the process of compensation for a variety of reasons

including disagreement on the compensation value during valuation of assets,

controversial issue on property ownership etc.

To address the problem of PAPs during implementation of compensation, establishment

of a grievance redress committee is recommended with a participation of project affected

persons.

The main function of the committee would be arbitration and negotiation based on

transparent and fair hearing of the cases of the parties in dispute, Project Affected

Persons (PAPs), the implementing agencies and local government. The committee gives

solution to Grievances related to compensation amount, delays in compensation payment

or provision of different type of resettlement assistance.

Rational operational procedure is essential for Grievance mechanism with reflection to

aspects as described below:

All PAPs will be informed in case of any grievance regarding compensation can

approach to chair man of the grievance committee or the project implementer.

Any PAPs who have grievance would present his /her all case to the grievance

redress committee. The committee examines the case and responds with in period

of 15 days.

If the PAPs are not satisfied with the decision of the Grievance Redress

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Committee (GRC), they can approach the regular court.

The objective of the grievance procedure stated above seeks to address the following:

Provide PAPs with avenues for making compliant or resolve any dispute that may

the course of land, structure and any assets acquisition, including the process of

moving.

Ensure that appropriate and mutually acceptable corrective actions are identified

and implemented to address complaints; verify that complainants are satisfied with

outcomes of corrective actions; and avoid the need to resort to judicial

proceedings

Livelihood restoration program

The destruction of crops will result in loss of livelihood for some families. With the return

of exiled Liberian populations and displaced persons, poverty and insecurity have been

increased.

Assistance should be given to these people so they find ways to survive. Knowing that the

crops are short in 3-5 months to be harvested, and on the basis of the Agricultural

Minimum Wage (SMAG) adapted to current realities, it will take at least 30 000 FCFA for

each head of household. An allocation of 83.04 million FCFA will meet the needs of 692

PAPs for at least 4 months.

The overall cost of the ESMP and RAP amounts to 1,008,648,165 FCFA (USD

2,192,704)

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Executive Summary - RAP

The electrical interconnection project between the Ivory Coast, Liberia, Guinea and Sierra Leone is in the list of projects established in the regional master plan of the "West African Power Pool (WAPP).". To build strong capacity building within Liberia, Guinea and Sierra Leone, the WAPP Secretariat decided the 225 KV power line interconnection project from the City of Man (Côte Ivoire). This project of construction and installation of new transmission facilities of electric power is part of regional policy for electricity.

The project includes almost 116 km of line in the Ivory Coast and the corridor on the Ivorian territory covers an area of 468 hectares. Construction activities and electrical infrastructure equipment could cause the release of Right of Way and relocation in terms of displacement of economic activity, loss of activities including business / commercial, craft, agricultural loss of assets, means of production, sources of income or livelihood. More than 692 people from 33 villages (13 villages for the Department of Man and the other 20 villages for the Department of Danané) will be affected by this project. In accordance with the requirements of the World Bank and African Development Bank (ADB) on involuntary displacement of populations and those of the Ivory Coast in the field, a resettlement plan was prepared. This plan takes into account the costs of compensation, resettlement and rehabilitation of livelihoods of those affected by the project.

At the regulatory framework, the Decree of 25 November 1930 and the Decree on expropriation for public utility and temporary occupancy in French West Africa (BOC, p. 1892) as amended by Decree of 16 June 1931 and Decree of 20 December 1933) states the general procedure for the expropriation for public utility. Also, Articles 10 and 11 of Law No. 85-583 of 29 July 1985 organizing the production, transmission and distribution of electricity in Côte d'Ivoire shows that the organization which is licensed production, transport and distribution of electric power has the right to use, through the Government of the Republic of Cote d'Ivoire, the procedure for expropriation after declaration of public works or works by decree as part of the legislation and regulations.

Law No. 98-750 of 23 December 1998 on rural land defines the national domain, organized land tenure and establishes rules for the management and protection of public and private areas of the state.

The following institutions are involved in the measurement of resettlement and compensation: WAPP; SOPIE, Ministry of Mines and Energy, the regional and local authorities; ANDE (National Agency for the Environment), the Ministry Environment and the Ministry of Economy and Finance Commissions of expropriation, lands and property.

The eligibility criteria for compensation are:

(A) the holders of a formal and legal right to land, including customary rights are recognized by the Land Code of the Republic of Côte d'Ivoire;

(B) persons who have no formal law on land at the time of the census; (C) persons who have no formal law or securities that may be recognized on the land

they occupy. It should be noted that persons within paragraphs (a) and (b) above shall receive compensation for land lost. As for persons of concern (c), they receive only a relocation assistance.

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All those affected should have at their disposal a clear and transparent mechanism for complaint and conflict management potential: local mechanisms for amicable resolution, referral to the local application to the court of last resort. The steps for resettlement operations are:

(i) information of local (ii) definition of sub-components and determination of the possibility of

resettlement (iii) definition of a PAR if necessary; (iv) and approval of the RAP

Compensation will be made either in cash or in kind or form of support. Monitoring and evaluation will be performed to ensure that all those affected are compensated, moved and reinstalled in the same manner as the standards set. The total cost of resettlement, compensation and restoration of the means of susbsistance of people affected is 756,717,300 FCFA ($ 1,645,033)

Contractors’ Environmental and Social Management Plan (CESMP)

Prior to the commencement of construction works, all contractors should be required to

prepare their own ESMPs (CESMP). The plan should be included in the bidding

documents and in the contractor’s contract and spell out environmental targets and

objectives as outlined in the ESIA/ESMP and how these could be achieved. The

Contractor’s ESMP (CESMP) shall include, to the extent practicable, all steps to be taken

by the Contractor to protect the environment in accordance with the current provisions of

national environmental regulations, the World Bank Groups Environmental Health and

Safety General Guidelines and the Environmental, Health and Safety Guidelines for

Electric Power Transmission and Distribution, 2007 as well as the ESIA/ESMP for this

project. Provision should be made for the disposal of chemical/ hazardous wastes as the

local facilities do not exist for hazardous waste disposed. Also, for more complex

environmental management aspects, the Contractor needs to prepare and implement

Method of Statement which needs to be approved by the Supervising Engineer and the

SPC upon request. In this perspective, within 60 days of notification of contract award, the

Contractor shall demonstrate an understanding of environmental and social obligations.

In order to ensure adequate implementation of the CESMP and specific Method of

Statement, the Contractor needs to employ environmental staff for the proposed Project.

Notwithstanding the Contractor’s obligation spelt out above, the Contractor shall, in

addition, endeavor to implement all necessary measures to restore the project sites to

acceptable standards and abide by environmental performance indicators specified in the

ESIA/ESMP to measure progress towards achieving objectives during execution or upon

completion of any works. It will be largely based on the ESIA and ESMP include the

following information:

organizational staff with clear identification of the leader (s) responsible (s) of the

environment, responsible environmental management of the project and its (their) CV,

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A general description of the methods that the Company proposes to adopt to reduce

the impact on the physical and biological environment of each phase of work.

A description of the actions that will implement the Contractor in each of the following

(not exhaustive):

These measures shall include but not limited to the following;

- Minimizing the effect of dust on the surrounding environment resulting from

concrete mixing sites, asphalt mixing sites, dispersing coal ashes, vibrating

equipment, temporary access roads, etc. to ensure safety, health and the

protection of workers and communities living downwind of dust generating

activities;

- Ensuring that noise levels emanating from machinery, vehicles and noisy

construction activities are kept at a minimum for the safety, health and protection

of workers within the vicinity of high noise levels and communities near rock-

blasting areas;

- Ensuring that existing water flow regimes in rivers, streams and other natural or

irrigation channels is maintained and/or re-established where they are disrupted

due to civil works being carried out;

- Preventing bitumen, oils, lubricants and waste water used/produced during the

execution of works from entering into rivers, streams, irrigation channels and

other natural water bodies/reservoirs and also ensure that stagnant water in

uncovered borrow pits is treated in the best way to avoid creating possible

breeding grounds for mosquitoes;

- Preventing and minimizing the impacts of quarrying, earth borrowing, piling and

building of temporary construction camps and access roads on the biophysical

environment including protected areas and arable lands; local communities and

their settlements. In as much as possible restore/rehabilitate all sites to

acceptable standards;

- Ensuring that the discovery of ancient heritage(Chance Find Procedure), relics or

anything that might or believed to be of archaeological or historical importance

during the execution of works is reported to the Museums and Monuments Board

in fulfilment of measures aimed at protecting such historical or archaeological

resources;

- Discouraging construction workers from engaging in the exploitation of natural

resources such as hunting, fishing, and collection of forest products or any other

activity that might have a negative impact on the social and economic welfare of

the local communities;

- Implementing soil erosion control measures in order to avoid surface run off and

prevents siltation, etc.;

- Ensuring that garbage, sanitation and drinking water facilities are provided in

construction workers camps;

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- Ensuring that in as much as possible, local materials are utilized to avoid

importation of foreign material and long distance transportation;

- Ensuring public safety and meeting traffic safety requirements for the operation of

moving machinery in order to avoid accidents;

- Discouraging the use of foul or infuriating words on project-affected persons

(PAPs) or any other persons seeking information on the project by construction

workers. All such persons and grievances should be politely referred to the

appropriate authority for redress.

- The overall management of the movement of land that the operation and

rehabilitation of borrow areas and quarries (anti-erosive planned redevelopment

planned); erosion control operations will be scheduled;

- Management of human resources;

- The prevention and mitigation of STDs and HIV / AIDS;

- Communication and information directed to people as well as to local and national

authorities;

- Conflict management;

- The use of commercial or business environment for local subcontracting;

- Description of the monitoring and control of the Environmental and Social

Management Plan of the site. The measures will include the submission of

monthly reports to the supervisor. Any significant event or incident should be an

immediate report from the company.

This Environmental Management Plan will be submitted for technical approval of the

Supervisor, who will share his observations and his decision within 20 days of receipt.

Cut-off date

The public consultation was held from May 2010. So the beginning of Census(cut-off date)

is May 2010 by the definition of the World Bank OP 4.12. During the public consultation with

the PAPs, the consultant clearly informed and explained the concept of the “cut-off date” to

the PAPs in the presence of the village’s population. The consultant also informed that no

one shall be registered on the PAPs after the cut-off date..

The modification of the PAPs is unable to provide that by changing the line route.

Grievance Mechanism and Grievance Redress Committee

Dissatisfactions may arise through the process of compensation for a variety of reasons

including disagreement on the compensation value during valuation of assets,

controversial issue on property ownership etc.

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To address the problem of PAPs during implementation of compensation, establishment

of a grievance redress committee is recommended with a participation of project affected

persons.

The main function of the committee would be arbitration and negotiation based on

transparent and fair hearing of the cases of the parties in dispute, Project Affected

Persons (PAPs), the implementing agencies and local government. The committee gives

solution to Grievances related to compensation amount, delays in compensation payment

or provision of different type of resettlement assistance.

Rational operational procedure is essential for Grievance mechanism with reflection to

aspects as described below:

All PAPs will be informed in case of any grievance regarding compensation can

approach to chair man of the grievance committee or the project implementer.

Any PAPs who have grievance would present his /her all case to the grievance

redress committee. The committee examines the case and responds with in period

of 15 days.

If the PAPs are not satisfied with the decision of the Grievance Redress

Committee (GRC), they can approach the regular court.

The objective of the grievance procedure stated above seeks to address the following:

Provide PAPs with avenues for making compliant or resolve any dispute that may

the course of land, structure and any assets acquisition, including the process of

moving.

Ensure that appropriate and mutually acceptable corrective actions are identified

and implemented to address complaints; verify that complainants are satisfied with

outcomes of corrective actions; and avoid the need to resort to judicial

proceedings

Livelihood restoration program

The destruction of crops will result in loss of livelihood for some families. With the return

of exiled Liberian populations and displaced persons, poverty and insecurity have been

increased.

Assistance should be given to these people so they find ways to survive. Knowing that the

crops are short in 3-5 months to be harvested, and on the basis of the Agricultural

Minimum Wage (SMAG) adapted to current realities, it will take at least 30 000 FCFA for

each head of household. An allocation of 83.04 million FCFA will meet the needs of 692

PAPs for at least 4 months.