REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES FADC...

REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES

FADC III

CADRE de GESTION ENVIRONNEMENTAL et SOCIAL

(Rapport Provisionnel 10/30/2003)

ALKA KOTHARI

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REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL

(FADC III)

TABLE OF CONTENTS

Page No.

List of Acronyms 3

Executive Summary 4

1.0 Introduction 7

2.0 Project Description 8

3.0 Safeguard Screening Procedures 11

4.0 Baseline Data 13

5.0 Description of the Policy, Legislative, and Institutional Frameworks 18

6.0 Guidance on Impacts 23

7.0 Reporting and Responsibilities for the ESME 27

8.0 Proposed Screening Mechaniism and Checklist of Risks and 31

Capacity Building

9.0 Environmental Management Plan, Review and Clearing 33

Process for Sub-projects

Annex 1 Sample Screening Form 38

Annex 2 Procedures for Sub-project Investments Requiring EA 43

Annex 3 Sample Checklist 44

Annex 4 List of Documents Reviewed 46

Annex 5 Villages Visited during Field Mission 47

Amnex 6 Country and Island Maps 48

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List of Acronyms

EMP - Environment Management PlanESIA - Environment and Social Impact Assessment (for sub-projects)ESMF - Enviromnent and Social Management FrameworkGoC - Government of ComorosFADC - Fonds d'Appui au Developpement CommunautaireSEN - Secretariat Executif NationalSER - Secretariats Executifs RegionauxCP - Comite de PilotageCGL - Comite de Gestion de l'EauRPF - Resettlement Policy FrameworkIEE - Proj et Infrastructure, Eau et EnvironnementFP - Focal Point

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1.0 EXECUTIVE SUMMARY

The Government of Comoros has requested support for the preparation and financing ofan Environmental and Social Management Framework (ESMF) for the third phase of theComoros Social Fund project. The project intends to support the Government ofComoros' efforts to address the incidence of poverty among the country's poorercommunities through the replenishment of a social fund designed to (a) increase access tobasic social services for the poorest; (b) stimulate economic activities at the communitylevel; and (c) promote institutional development at the local government and communitylevels.

The proposed credit will support financing for the following four components:

a) Community based activitiesThis component would continue to finance small-scale social and economic sub-projectsidentified by communities, with an expanded menu of services to include socialprotection programs and capacity building initiatives. Support to community healthservices will also be financed. Direct community financing will also be piloted andscaled up based on lessons learned. By the end of the project, it is expected that targetedcommunities would have developed and implemented community based developmentplans through a participatory planning process.

b) Urban water supply and periodic road maintenance on Anjouan and MoheliThese activities were already identified under the IEE project and includerehabilitation/maintenance of 184 kilometers of existing national roads, andrehabilitation/extension of water supply in three towns in Anjouan and the capital inMoheli. This component would also finance capacity building of water managementcommittees and Information and Education Campaigns (IEC) on water management, theenvironment, and hygiene.

3) Support to Rural Development through Income-Generating ActivitiesThis component would finance demand-driven income-generating sub-projects to financesmall productive infrastructure with beneficiary contribution of at least 20 percent of thetotal sub-project cost. Eligible beneficiaries would be producer organizations and ruralcommunities. Productive infrastructure and off-farm activities would be financed alongwith support services needed for the identification and implementation of the sub-projects. Finally this component would provide extension and training services, capacitybuilding for the relevant stakeholders, and technical assistance to local financialinstitutions.

4) Monitoring & Evaluation (M&E) and Project ManagementThis component would support M&E activities, including moving beyond monitoring ofproject outputs to undertake an impact assessment of the activities of the communitybased activities over the life of the project. FADC operating costs and key technicalassistance are also included under this component. It is expected that the project will besuccessfully implemented in a cost effective and decentralized mamler. Furthennore, theproject will emphasize the participatory monitoring and evaluation approach by involving

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beneficiary communities throughout the project cycle; and use external monitors to buildstrong transparency in the management of project components.

The Main Tasks of the Study are:

* To develop an enviromnental and social management framework that establishesmethodologies for environmental and social impact assessment within projectimplementation;

* Identify potential policy issues regarding the environment and propose means ofresolution that could be undertaken during project implementation;

* Develop a capacity building program for stakeholders to carry out EnvironmentalImpact Assessments for micro-projects and to design potential mitigation measures inline with the World Bank's safeguard requirements and environmental legalrequirements of the Government of Comoros.

The ESMF study was carried out by Alka Kothari after a site visit to Comoros from the18th of August to the 2nd of September 2003. The consultant visited all three islands i.e.Grande Comore, Anjouan and Moheli. Though this is the third phase of the Bank'sSocial Fund credit to Comoros, it is the first ESMF to be carried out and so specialattention was paid by the consultant to ensure that the government, executing agency, andstakeholders were consulted about the type of instrument being prepared and theobligations for its proper implementation. The list of field visits by the consultant islisted in Annex 1 together with the list of various stakeholders whom the consultant metduring the entire Mission. The list of documents reviewed is given in Annex 3.

The GoC by the Decree on Environment Impact Assessment in 2001 and the WorldBank's own Operational and Procedural Policies, specifically OP 4.01 requires thegovernment to prepare an ESMF report, which will establish a mechanism to determineand assess future potential environmental and social impacts of project investments forthe proposed Social Fund III, and then to set out mitigation, monitoring and institutionalmeasures to be taken during design, implementation and operation of the subprojects toeliminate adverse environmental and social impacts, offset them, or reduce them toacceptable levels. This is precisely what is required at this stage of project preparationsince the location of the sub-projects have not yet been identified.

OP 4.01 further requires that the ESMF report must be disclosed as a separate and standalone by the GoC and the World Bank as a condition for Bank Appraisal. The disclosureshould be both in Comoros where it can be accessed by the general public and localcommunities and at the Infoshop of the World Banlk and the date for disclosure mustprecede the date for appraisal of the project.

The key highlights in this ESMF report are as follows:

(i) For the sub-project activities envisaged in the third Social Fund, the ESMFestablishes the screening process mechanism for the implementation of theproject activities to enable the local communities and the Comites de Pilotage

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to simultaneously identify adverse potential environmental and social impactsof their project activities and to address them by incorporating the relevantmitigation measures into the designs before they submit them for review andsubsequent approval.

The main feature of this mechanism requires the project implementers(Comites de Pilotage) to screen their projects at the preparation stage using thescreening form in Annex 1 and the environmental and social checklist inAnnex 2 to identify potential adverse effects/impacts.

The next requirement is for the iinplementers to incorporate the necessarymitigation measures into the project design following which they are tosubmit the project proposals accompanied by the completed screening formand checklist to the reviewing body, which is the FADC-SER for approval.

(ii) The ESMF identified and assessed to the extent possible, potentialenvironmental and social impacts and appropriate mitigation measures andpresented this in the forn of a checklist contained in Anlex 1.

(iii) The ESMF also developed an environmental and social screening form thatwould assist in deternining potential adverse environmental and socialimpacts during project implementation pertaining to the project activities. Thisfonn is contained in Annex 2.

(iv) The capacity of the FADC to manage the ESMF was assessed. It was foundthat the FADC required further strengthening through training in order toproperly manage the Framework. A training program and budget wasdeveloped and is contained in the body of the ESMF. The Comites dePilotage, which are to be elected bodies that would represent the localcommunities and help them to meet their responsibilities in the EA process asoutlined in this ESMF would greatly benefit from technical assistance andtraining. The Department of Environment will also benefit from technicalassistance to facilitate their monitoring and supervision of training role.

(v) Finally the ESMF contains an extensive and comprehensive environmentaland social monitoring plan to ensure that environmental and social issues willbe managed effectively.

(vi) Meaningful consultations with local communities were held during the in-country study part of the preparation, during which they were sensitized onthe requirements of the RPF and ESMF.

This Environment and Social Management Framework Report presents definitive,conclusive and clear procedures consistent with the Laws in Comoros and theWorld Bank Safeguard Policies.

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1.0 INTRODUCTION

The Government of Comoros has requested support for the preparation and financing ofan Environmental and Social Management Framework (ESMF) for the third phase of theComoros Social Fund project. The project intends to support the Government ofComoros' efforts to address the incidence of poverty among the country's poorercommunities through the replenishment of a social fund designed to (a) increase access tobasic social services for the poorest; (b) stimulate economic activities at the communitylevel; and (c) promote institutional development at the local government and communitylevels.

This is the report of a study to produce an environmental and social managementframework (ESMF) for the proposed Social Fund III.

1.1 The Objectives of the Study are:

* To assess the potential environmental and social impacts of the Social Fund Project,whether positive or negative, and propose mitigation measures which will effectivelyaddress these impacts;

* To inform the project preparation team and the Comorian Government of the potentialimpact of different anticipated sub-projects, and relevant mitigation measures andstrategies;

* To establish clear directives and methodologies for the environmental and socialscreening of micro-projects to be financed by the project through the FADC.

1.2 The Main Tasks of the Study are:

* To develop an environmental and social management framework that establishesmethodologies for environmental and social impact assessment within projectimplementation;

* Identify potential policy issues regarding the environment and propose means ofresolution that could be undertaken during project implementation;

* Develop a capacity building program for stakeholders to carry out EnvironmentalImpact Assessments for micro-projects and to design potential mitigation measures inline with the World Bank's safeguard requirements and environmental legalrequirements of the Government of Comoros.

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(FADC 111)

The ESMF study was carried out by Alka Kothari after a site visit to Comoros betweenthe 18th of August to the 2nd of September 2003. The consultant visited all three islands,i.e. Grande Comore, Anjouan and Moheli. Though this is the third phase of the Bank's

Social Fund credit to Comoros, it is the first ESMF to be implemented, and so specialattention was paid by the consultant to ensure that the government, executing agencyFADC, and stakeholders were consulted about the type of instrument being prepared andthe obligations for its proper implementation. The list of field visits by the consultant islisted in Annex 5. The list of documents reviewed is given in Annex 3.

1.3. Purpose of the Environmental and Social Management Framework Study

The consultant has been charged with the development of an Environmental and Social

Management Framework, because the precise details of the demand driven micro-projects - in terms of exact location, materials required, key communities, etc. - to befinanced under the Social Fund Project are not yet determined. This is the case for thecommunity-driven development component but will also apply in the Infrastructure,Water and Environmental component of the proposed project. These components arediscussed in greater detail in Chapter 2 under proj ect description.

The principal purpose of the Environmental and Social Management Framework (ESMF)is to screen the sub-projects on their environmental and social merits and manage theirpotential environimental and social impacts.

2.0 DESCRIPTION du PROJET

Les objectifs proposes du nouveau projet FADC sont l'amelioration des conditions de vied'un nombre significatif des communautes defavorisees et des groupes vuln6rablesspecifiques; l'augmentation de la capacite des communautes et acteurs locaux dans leprocessus de planification pour le developpement ; et l'augmentation de la responsabiliteau niveau local et la transparence. FADC III est structure pour atteindre ses objectifs amoins de quatre composants principaux d'investissements du projet, qui sont;

* Finiancernent des sous projets pour am6liorer les conditions de vie de lapopulation;

* Reniforcemnent des Capacitis stratigiques, au profit des partenaires du FADCet y compris des activites d'IEC s'adressant a l'ensemble de la population;

* Appui au Developpemnent Rural Productif, a travers les activites generatricesde revenus (AGR), en faisant la liaison entre les micro credits et lesinfrastructures qui pourraient etre n6cessaires pour accompagner les cr6dits; et

* Gestioni du Projet.

COMPOSANTE 1 : FINANCEMENT DES SOUS PROJ ETS

Cette composante pourra comprendre plusieurs sous volets, notamment (i) des petitsinvestissements sociaux; (ii) des programmes de protection sociale; et (iii) les

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investissements prioritaires en l'adduction d'eau et l'entretien p6riodique des routes(identifies dans le contexte du projet Infrastructure, Eau et Environnement - IEEr6cemment cl6tur6). En outre, un sous volet destine a appuyer la sante pourrait etreenvisage.

COMPOSANTE 2: RENFORCEMENT DE CAPACITE

L'objectif de cette composante serait de renforcer la capacite aux niveaux locaux, ycompris les communautes, les gouvemements locaux, et les autres partenaires, tels queles societ6s civiles, avec comme but final d'ameliorer les services sociaux et lesinfrastructures. Le proj et propose doit egalement augmenter la responsabilite et latransparence et doit aussi foumir des motivations pour le developpement d'une bonnegouvemance. L'exigence des communautes pour de meilleurs services publics et laresponsabilite a leur egard peuvent etre stimulees par l'introduction des modeles deplanification de developpement et de l'engagement des communautes comparable a ceuxdes fonds sociaux. La participation communautaire ainsi que le renforcement de sacapacite de planification de sous-projets, de leur mise en oeuvre, de leur gestion et de leursuivi seront renforcees, avec pour consequences une amelioration de la transparence dansla budgetisation et dans les d6penses.

Cette composante pourrait appuyer deux types de renforcement de capacite: a) Activitespilotes pour le developpement local: Ces activites pilotes pourraient promouvoir desactivites telles que le financement direct des communautes, de la planificationcommunautaire et de la planification au niveau des communes (inter-village); et b)Investissements strategiques pour le renforcement de capacite telles que des activitesvisant a ameliorer la qualite du service public, a r6aliser une sensibilisation pour laprevention du SIDA, y compris le traitement des dechets medicaux, ou une sensibilisationaux problemes environnementaux, etc.

COMPOSANTE 3: APPUI AU DEVELOPPEMENT RURAL ET ACTIVITES GENERATRICES DE

REVENUS (AGR)

Cette composante a l'objectif sp6cifique de l'augmentation de la productivite et de laproduction dans certains secteurs afin de promouvoir la croissance en milieu rural. I1 estpropose d'adopter une approche associative et de travailler avec les differentes formesd'organisations paysannes et de producteurs. I1 est egalement propose de financer dessous-projets comprenant des infrastructures productives a travers des subventionsincluant une contribution des beneficiaires ainsi que les fonds de roulement a travers descredits. La gestion et l'exploitation des infrastructures productives devraient se faire encommun mais la production resterait individuelle. I1 est envisage que le financement dessous-projets se fera en collaboration avec les institutions de financement et de micro-finance a travers un systeme de co-financement.

COMPOSANTE 4: GESTION DU PROJET

Cette composante financera les cofits operationnels du projet, ainsi que l'assistancetechnique et le suivi et 6valuation du projet. Cette derniere activite constitue un element

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cle pour assurer que cette phase du projet aura l'impact desire au niveau des populationsplus defavoris6es. Pour ce faire, il y aura une evaluation d'iimpact des demieres phasesdu projet afin de pouvoir tirer des le,ons requises pour l'amelioration du systeme de suiviet evaluation. Le proj et financera egalement une etude institutionnelle pour evaluer lesforces et faiblesses du FADC et pour formuler des recommandations sur les besoins ennouveau personnel ou en renforcement de capacit6 du personnel existant.

2.2. The Social Fund project will finance community-initiated development projects andis expected to finance mostly rehabilitation and/or construction of basic health andeducation infrastructure, feeder roads, income generating activities, community watersupply schemes, road maintenance, and capacity building activities. It is envisaged thatsome of these sub-projects will involve the construction of water supply and sanitationfacilities, primary education facilities, primary health care facilities, solid wastemanagement (medical waste), etc. Since at the time of preparation the sub-projects hadnot yet been identified, the GoC by the Decret N° 0 1-052/CE and Operational Policy 4.01of the Bank require the GoC to prepare an Environment and Social ManagementFramework which establishes an instrument used to determine and assess future potentialenvironmental and social impacts of sub-project investments under components one andtwo of the proposed Social Fund III. To this effect, the project will initiate acomprehensive Social and Environmental Awareness Building Program coupled withcapacity building activities to enable the communities to better understand the essence ofsustainable development through proper management of the natural resource base whichthey depend on for their livelihood. The project will hire an environmental/socialspecialist who will work under the FADC and in collaboration with the NationalEnvironment Department to implement the Social and Enviromnental AwarenessBuilding Program, put in place monitoring, mitigation and institutional measures toeliminate any adverse environmental and social impacts, offset them, or reduce them tosustainable levels.

2.3. Target Areas

The Social Fund project is expected to intervene on all three islands. These interventionswill be managed by Regional FADC offices in collaboration with the Comites de Pilotagewho implement the projects and represent the main beneficiaries. It is therefore essentialthat the proposed awareness building program goes hand in hand with the sub-projectidentification to allow for better understanding of the environmental and socialconsequences of their selection. (See screening process)

Since the sub-projects mentioned above are to be created on a demand driven basis, eachsub-project that is subsequently identified and promoted by the local community wouldbe subjected to an environmental and social screening. The main feature of this screeningmechanism requires the project's Coordination Unit, the Comites de Pilotage tounderstand the screening forms in Annex 1 and the environmental and social checklist inAnmex 2. Once identified, the process evaluates alternatives and designs appropriatemitigation, management and monitoring measures. The other important requirement is forthe implementers to incorporate the necessary mitigation measures into the project design

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following which they are to submit the project proposals accompanied by the completedscreening form and checklist to the reviewing body, which is the FADC-SER forapproval.

3.0 SAFEGUARD SCREENING PROCEDURES

The proposed Environmental and Social Management Framework has been designed tofully comply with national environmental codes and legislations in Comoros and with theWorld Bank's environmental and social safeguard policies. This chapter sets out the keysafeguard policies that provide the policy context to the ESMF including World Bankpolicies and Comoro's legal requirements on environmental assessment. More details ofthe policy context are provided in Annex 3.

As part of the ESMF process, proposed micro-activities under the Social Fund III will bedesigned at the local level to ensure that they are screened for potential impacts and thatthey comply with the requirements set out under World Bank safeguard policies.

The Social Fund III is anticipated to set the pace to ensure that negative impacts on theenvironment are minimized. One of its main objectives is therefore to promotesustainable land use and ecologically sound natural resources management throughcommunity driven development. Despite these efforts and due to the nature of thepotential micro-projects to be financed under the project as well as the recently inheritedInfrastructure, Water and Environment project, which involves infrastructure and waterrehabilitation, the proposed project has been rated Category B under the World Bank'spolicy on environmental assessment (OP 4.01), requiring an Environmental and SocialManagement Framework (ESMF). The ESMF is required to assess the potential impactsassociated with micro-projects. In addition to the OP 4.01, the Social Fund has alsotriggered the Bank Involuntary Resettlement Policy OP4. 12 Table 3.1, and as such aResettlement Policy Framework will be prepared.


(FADC III)

Table 3.0 Safeguard Policies

Policy Applicability

Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) YesNatural Habitats (OP 4.04, BP 4.04, GP 4.04) NoForestry (OP4.36, GP 4.36) NoPest Management (OP 4.09) NoCultural Property (OPN 11.03) NoIndigenous Peoples (OD 4.20) NoInvoluntary Resettlement (OP4. 12, BP 4.12) YesSafety of Dames (OP 4.37, BP 4.37) NoProjects in International Waters (OP 7.50, BP 7.50, GP 7.50) NoProjects in Disputed Areas (OP 7.60, BP 7.60, GP 7.60) No

3.1 Justification for preparation of the ESMF and the RPF

OP 4.01 (Environmental Assessment)The OP 4.01 has been triggered because there is the potential that implementation of thesub-projects in one of the most fragile ecological systems and by people whoseknowledge of the fragility of these systems is limited ,may lead to negativeenvironmental impacts. Site visits on executed past sub-projects has determined that thereare no potential large-scale, significant or irreversible environmental impacts associatedwith the project. The potential impacts identified are mainly localized impacts associatedwith activities to be financed under the local investment funds (i.e. rural roads, feederroads through forest zones, tracks and pathways in pastoral zones, small scale dams,piped water systems, wetlands and ecosystem management, and rangeland management),which can be effectively mitigated and are addressed in the ESMF and using thescreening and review procedures in Chapter 6. The ESMF identifies the major potentialenvironmental issues that could arise as a result of project interventions and proposesmeasures to be taken to mitigate these effects, including proposed training andmonitoring measures.

OP 4.12 (Involuntary Resettlement)

The Project will support community investments in various types of micro-projects, ofwhich many, particularly those involving small-scale infrastructure, will require land forconstruction. To mitigate against the potential for involuntary resettlement, aResettlement Policy Framework (RPF) has been prepared which provides the frameworkfor resettlement planning under the Social Fund. The screening tools provided in Annex2 have been designed to address issues of resettlement and land acquisition in parallelwith the screening criteria developed under the RPF. The difficulty in Comoros is thatthere are no clearly followed land tenure laws or policies and the existing traditional andreligious systems have been seriously tampered with during the several coup d'etats andcountless changes of Govenmment.

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3.2. Mainstreaming Bank Safeguards into sub-project screening

The screening criteria provided in the ESMF includes relevant questions on naturalhabitats/protected areas, involuntary resettlement and land acquisition, introduction ofpesticides, impacts to forestry resources, impacts to cultural property and inclusion ofindigenous people in the project identification process. This is meant to ensure that allconcerns related to the Bank's safeguard policies are taken into account during thescreening of micro-projects for potential impacts, and that the appropriate mitigationmeasures can be adopted to address them.

4.0 BASELINE DATA

This Chapter provides key baseline information relevant to the proposed project sites andgives a detailed assessment of Comoro's baseline features as they relate to the social fundproject. The Social Fund project is expected to intervene on all the three islands andthese interventions will be managed by Regional FADC offices in collaboration with theComite de Pilotage, thus the need to give detailed information of the country as a whole.

The Islamic Federation of Comoros is an archipelago consisting of three islands, thelargest being Grand Comore, then Anjouan and Moheli. Formerly a French colony, thefourth island, Mayotte, still remains a department of France.

GNP per capita was estimated at US$414 in 2002, down from about US$520 in the late1980s.

4.2.1 Physical Environment

The islands are located in the Mozambique Channel, about two-thirds of the way betweennorthern Madagascar and northern Mozambique. The islands are of volcanic origin andare mountainous with Grand Comore, the youngest of the islands and closest to mainlandAfrica, still housing a massive active volcano. The summit of the volcano Kartala is alsothe highest point on the islands, measuring 2361 m (7746 ft) above sea level. Seismicactivity has increased dramatically since 2000 and experts are concerned that a veryviolent eruption may occur in the near future.

4.2.2 ClimateThe Comoros climate is tropical with a monsoon season from November to April. Therange of annual rainfall is from 109 to 551 cm (43 to 217 in) and there are frequentcyclones.

There are approximately 2000 endemic plant species in Comoros and several species ofmarine life native to Comoros, including two species of sea turtles. Widespreadconversion of forest to agricultural land and poaching of sea turtles has left many of theendemic species severely threatened while others have already gone extinct.Conservation of the remaining forested areas must be a priority for the conservation of

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endemic species. Nonetheless, there are only two protected park areas, both on the island

of Moheli. There is a national park and a marine park funded by a UNDP-GEF grant.

Comoros is a member of many regional and international organizations and is a signatoryto many international agreements on the environment that address: Biodiversity, Climate

Change, Desertification, Endangered Species, Hazardous Wastes, Law of the Sea, Ozone

Layer Protection, Ship Pollution, and Wetlands.

The most pressing environment issues and cause for concern are deforestation, soil

erosion, coastal and beach erosion, and solid and liquid waste management.

4.3 SOCIO ECONOMIC ENVIORNMENT

4.3.1 Population and Migration

The estimated population of the three islands as of July 2000 was over 550,000 people of

which approximately 50% live in Grand Comore, 42% in Anjouan and 8% in Moheli. A

fourth island of the archipelago, Mayotte, has remained under French sovereignty.

Covering an area of only 2,336 km, Comoros has a very high population density, with the

island of Anjouan being the most populated.

In recent decades the population was increased by the forced evacuation of Comoriansfrom Madagascar and Zanzibar. These peoples resettled in the Comoros adding to an

already difficult situation. Comorians can be found living in many parts of the world but

most of the emigrants are in Europe or in Kenya and Zanzibar along the East African

coast. There are an estimated 60,000 Comorians or people of Comorian descent living in

France today.

The present population increase is an estimated 3.5% per year with an annual birth rate of

47 births per 1,000 and an annual death rate of 12 deaths per 1,000. The most recentestimate of the total fertility rate is 6.8 children born per woman. Life expectancy at birthis 54 years for males and 59 years for females.

The inhabitants are a blend of various peoples of the Indian Ocean littoral. African,Malagasy, and Arabic features are clearly evident. Maritime commerce before entry of

Europeans into the Indian Ocean brought Comorians into contact with peoples from

southern Africa to Southeast Asia. Since the end of the fifteenth century Europeaninfluence has also impacted upon Comorian life.

4.3.2 National Economy

In 2001, per capita GDP was US$380, the same as in 1982, which makes Comoros one ofthe poorest nations in the world and is ranked number 168. The country's poor economicperformance has been due to a conglomeration of issues, chief among them is thecontinued political disturbances. National Comorian politics have been characterized by

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rapid changes of direction and numerous coups with intervention of foreign mercenaries,all contributing to an instability that has not allowed strong institutions to emerge. Thelack of government commitment toward socio-economic development has lead towidespread disillusion with the state.

Agriculture is the most important sector of the economy, employing over 80% of thework force and accounting for almost 100% of exports. Two agricultural zones aregenerally defined: the coastal area, which ranges in elevation from sea level to 400meters and which supports cash crops such as vanilla, ylang-ylang, and cloves; and thehighlands, which support cultivation of crops for domestic consumption, such as cassava,bananas, rain rice, and sweet potatoes. As the population increased, food grown fordomestic use met fewer and fewer of Cormorians' needs. The republic imports virtuallyall its meat and vegetables; rice imports alone often account for up to 30 percent of thevalue of all imports. France is Comoros' largest trading partner.

4.3.3 Public HealthLife expectancy stands at 60 years and the infant mortality rate is 76 per 1000 births.High rates of malnutrition among children, such as the 43 % rate of chronic moderatemalnutrition among children less than two years old, and its effect on resistance toinfectious diseases indicate that the mortality rate will continue to be high. The crudebirthrate is 48 per 1,000 and the crude death rate, 12 per 1,000.

Malaria is ubiquitous in the islands, with 80 to 90 percent of the population said to beaffected by the disease. Other prevalent maladies included tuberculosis, leprosy, andparasitic diseases. Despite improvements in life expectancy, infant mortality, and thenumber of physicians, the overall quality of care remains poor. About 80 percent of thepopulation lives within one hour's walk of a health facility, usually headed by a trainednurse, but paramedical staff are in short supply and many health facilities are in poorcondition. Some international medical aid has been provided, mostly by France and theWorld Health Organization (WHO).

4.3.4 Political History and Governance

In 1978 the Comoros was proclaimed a federal Islamic republic; shortly thereafter, a one-party state was formed under President Ahmed Abdullah Abdurrahman. After hisassassination in 1989, SaYd Mohamed Djohar became interim president and subsequentlywon election in a multiparty contest. He survived an impeachment attempt in 1991 andseveral coup attempts. In 1996 Mohamed Taki Abdulkarim was elected president. In1997 rebels took control of the islands of Anjouan and Moheli, declaring their secessionand desire to return to French rule. In 1999 the islands were granted greater autonomy.Following a coup in Apr. 1999, Col. Azali Assoumani assumed the Comorian presidency.Anjouan voted (2000) for independence, but in 2001 forces favoring reuniting with theComoros seized power there, and a Comorian referendum approved additional autonomyfor the three islands. Azali resigned in 2002 prior to new elections, and Prime MinisterHamada Madi became interim president. After two disputed elections, Azali wasdeclared president in May 2002.

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4.3.5 Religion and Education

Comoros is a Federal Islamic Republic, and officially the population is 100% Muslim.As Sunni Muslims, the Comorians follow religious observances conscientiously andstrictly adhere to religious orthodoxy. During the period of colonization, the French didnot attempt to supplant Islamic customs and practices and were careful to respect theprecedents of Islamic law. Hundreds of mosques dot the islands.

Practically all children attend Quranic school for two or three years, starting around agefive; there they learn the rudiments of the Islamic faith and some classical Arabic. Whenrural children attend these schools, they sometimes move away from home and help theteacher work his land.

France established a system of primary and secondary schools based on the Frenchmodel, which remains largely in place. Comoran law requires all children to completeeight years of schooling between the ages of seven and fifteen. Comoros has nouniversity. Those desiring higher education must study abroad; a "brain drain" hasresulted because few university graduates are willing to return to the islands. Teachertraining and other specialized courses are available at the M'Vouni School for HigherEducation, in operation since 1981 at a site near Moroni.

As elsewhere in Comoran society, political instability has taken a toll on the educationsystem. Routinely announced reductions in force among the civil service, often made inresponse to international pressure for fiscal reform, sometimes result in teacher strikes.When civil service cutbacks result in canceled classes or examinations, students have attimes taken to the streets in protest.

4.4 ACCESS to RESOURCES

4.4.1 Access to Land

Comoros' land tenure laws are archaic and contradictory and the tenure system is largelygoverned by traditional and religious systems which are complex. The reason for thiscomplexity is due to a conglomeration of factors. There are three types of land tenuresystem in Comoros, customary, Islamic, and French administrative. The French laws arestill on the books, though the islands have been independent since 1975, but the unwrittencustomary and Islamic laws are the ones most commonly respected and practiced. Atpresent, there is no applicable Code Foncier addressing land holding, managementcontrol, dispute processing, expropriation and resettlement, or valuation principles forcompensation. Comoros is clearly lacking in the needed regulatory and administrativeframework for issues related to land tenure. The best recommendation that can be madewithin the framework of the RPF is to apply the World Bank policies until such timewhen the country prepares its own consistent land laws.

4.4.2 Access to Potable Water

16


(FADC III)

Social Funds I and II have been very successful in providing access to water to themajority of the population. From 1996 to 2001 the access to water went from 76% of thepopulation to 92%. Nonetheless, as deforestation continues, both because of increasedpopulation density helped by a young and fertile population, and because ofunsustainably heavy use of wood for the production of ylang-ylang, the rivers continue todry up on Anjouan and Moheli and water grows scarcer.

4.4.3 Access to Capital

The rural people of Comoros have the lowest access to capital and no access to financialservices. The economy of the poor and vulnerable groups of the islands particularly inMoheli and Anjouan remain largely non-liquid due primarily to the absence of financialservices and the lack of micro-credit organizations. For this particular reason, theproposed project toils with the idea of creating a micro-credit component to be managedby the FADC. This is a move in the right direction but with the lack of financialmanagement capacity within the FADC, coupled with the fact that social funds are notusually designed to handle micro-credits, the Bank is skeptical. In my view and in thespirit of enhancing the investment and revenue earning capability of these poor andvulnerable communities, FADC's capacity can be built to take on this challenge. It is sofar the most credible institution working with communities and which enjoys communitytrust. While providing collateral may be the main stumbling block, communal trust canbe a way forward in testing the resolve of these groups in taking their destinies in theirown hands.

On the three islands, there are several and extremely important linkages betweenlivelihoods and environmental resources, which are relevant to rural areas on all threeislands. These are outlined below.

Exploitation of local vegetationWood har-vesting

The forest cover in Comoros is seriously affected because wood is used for severalpurposes, the main one being a source of energy, building material and most importantlyfor distilling ylang-ylang for export. Wood represents an extremely high percentage ofthe domestic energy consumed on all the islands and the annual loss of wooded surfacesin Comoros if continued unabated will lead to severe erosion of fragile mountain slopes.

Bushfires

Fire is used for the following in Comoros: (i) clearing the fields; (ii) hunting; (iii)improving visibility; (iv) accelerating the re-growth of perenlial grasses; and (v)customary rituals. Fire impoverishes the soil and reduces its productivity, by causing theloss of certain nutrients (nitrogen, sulfur), and organic matter. More than 75% of firesoccur between October and December.

17


(FADC III)

Unsustainablefarmiing practices

Unsustainable farming in Comoros, particularly in the coconut and banana fanns on thehill slopes, soil degradation and de-vegetation and serious erosion has become majorenviromnental issues. Eroded sites have been protected by external species which due totheir dispersal systems and the lack of predators to control their expansion are rapidlycompeting with the indigenous plant spices. In some areas the rapid expansion of acaciawith its effective dispersal system has led to significant impoverishment of the soilswhich in turn has reduced the agricultural productivity and in some areas led to zeroproductivity. Also, very important is the fact that the introduction of foreign speciescontributes to the loss of biodiversity.

Soil ErosionCoastal zone erosion is a serous and real problem in Comoros which has led thecommunities to invest heavily in coastal zone protection through dykes and building ofwalls to protect the intrusion.

5.0 DESCRIPTION of the POLICY, REGULATORY, LEGISLATIVE, andINSTITUTIONAL FRAMEWORKS

5.1 Legislative and Policy Framework

The legislative and policy framework for environmental protection and management isextremely weak in Comoros. There is a National Environmental Policy that has beenarticulated, but most of the legislation outlined in the policy is yet to be written and/ormade operational. It speaks of sectoral policies that require definition, namely a landtenure system, a water policy and a policy on waste management. It is of criticalimportance to the sustainable development of all three islands that this legislation ispassed and applied to all future projects with the Bank and other lenders. Even wherethere is legislation already in place, there is a grave lack of capacity and funds toimplement this legislation.

As of April 19, 20001, a decree specific to environmental assessment was put in place,but the Director of Environment complained that there has yet to be any enforcement ofthe decree. With Bank requirements in mind for those sub-projects which requireadditional environmental work, as determined under the screening and review process,the building of the capacity at the national, regional, and local level is called for. This isthe only way to allow the national enviromnental agency to exercise its mandate. Thiswill also ensure that sub-projects that may have potentially significant impacts andrequire more detailed study, receive national, regional, and local level attention andapproval.

There are several Decret and Arrete relating to protection of biodiversity, includingArr6te N 01/3]/MPE/CAB portant protection des especes defaune etflore sauvages des

Conmores du 14/05/2001, and Arr6te N 01/32/MPE/CAB portant adoption de la Strategie

Nationale et du Plan d 'Action pour la Conservation de la Diversite Biologique de

14/05/2001. The creation of the Parc Marin in Moheli is an extremely promising model,

18


(FADC III)

which built on these Arretes to develop an organization that protects the marine life,especially les tortues marins, from fishing and poaching, the coral reefs, vegetation and

surrounding forest. The Decret N 01-053/CE creating the Park mandates a Conservatorto a committee to manage the Park, forbids any industrial or commercial activity with the

limits of the Park, plans for eco-tourism, and strictly enforceable penalties for violation of

the rules.

Land Tenure and Ownership

Conceming land take, at present, based on the field visits and consultations and withbeneficiaries, it is clear that there will not be any land take, loss of economic activities,and/or relocation.

5.2 Administrative Structures and Responsibilities

FADC is made up of the following groups:

1- Le Comite Central de Coordination (CCC)2- Le Secrtariat Executif National (SEN)3- Les Comites Regionaux (CR)4- Les Bureaux Regionaux denommes Secretariats Ex6cutifs Regionaux (SER)5- Les Comites de Pilotage (CP)

Table 5.2 FADC Administration

Unit Responsibility

National Level

Le Comite Central de Coordination . Comprised of representatives of relevant Ministries and civil

(CCC) society,* Adopts the Manual of Procedures* Charged with financial management and definition of overall

policy* Review quarterly reports from FADC-SEN and FADC-SER

FADC National a etudier et proposer au CCC les elements de la politique et de lastrategie de financement des projets de developpementcommunautaire sur la base des orientations arretees par le CCCconformrment aux objectifs d'ensemble de l'Etat

* apporter un appui au montage des dossiers de sous-projetsexigeant des competences techniques qui ne se trouvent pas auniveau regional

* contribuer a l'evaluation a posteriori des sous-projets et desinterventions du FADCE

* pr6parer le budget et assurer la gestion administrative etfinanciere du FADC

* requerir toute assistance expatriee ou etude specifiquenecessa re ' la bonne r.alisati...des.pro.ets

Regionial Level

19


(FADC 111)

Unit Responsibility

Comites Regionaux . elaborer et proposer une politique et une strategie de

developpement communautaire regional* collaborer avec les SER en vue d'assurer la liaison necessaire

avec les communautes locales pour d6finir les projets repondantaux besoins communautaires des populations les plus desheritees

* servir de premier recours au personnel des SER ainsi qu'auxcomites de pilotage pour regler d'eventuels diff6rends.

• diriger les assemblees generales des Comites de pilotage

.................................................................................................................................................... ......... .......... .... ..... ................................................ ............. .................. .................................... ........ ..................... .................

FADC-SER • animer la campagne de sensibilisation, d'information et de(Les Secr6tariats Executifs formation au niveau des communautes de la regionR6gionaux) . etudier et proposer aux CR les elements d'une strategie de

financement des projets de developpement communautaire* foumir un appui technique et financier aux communautes dans la

preparation et lexecution des sous-projets* Organiser les assemblees g6nerales des comites de pilotage* assurer le suivi des sous-projets realises et veiller au respect

des conventions de financement par les communautesbeneficiaires

* Responsible for reviewing sub-project applications fortechnical and financial feasibility before submission for

. ~~~~~~~~~~~~~.a................ ppvafo finacig.................................................... ............................. .............. ..................................................................... ................................. ...... ....... . . ....................................................... ........................

Local Level

Comite de pilotage . identifier, en liaison avec le SER, les sous-projets d'int6r&tpublic

* sensibiliser les communaut6s sur limportance des projetsidentifies

* preparer, en collaboration avec le SER, un projet de budgetcouvrant les depenses d'execution et d'entretien, et definir lesdifferentes contributions de la population interessee;

* obtenir un engagement ferme de la ou des conimunautesvillageoises sur la participation effective de celles-ci alVex6cution et au suivi des travaux d6coulant des projets agreespar le FADC

* mobiliser les ressources locales tant humaines, materielles quefinancieres n6cessaires a l'execution des sous-projets, et derendre compte p6riodiquemnent au SER et a la communaute surl'etat d'avancement des travaux

5.2 INSTITUTIONAL FRAMEWORK

At the national level, the principal institutional agency dealing with the environment inComoros is the Ministry of Rural Development, Fisheries and the Environment. TheDepartment of Environment was established as an autonomous institution by the FederalGovernment of Comoros in 1997 and has three regional offices on each island, with themain office in Moroni. The Department has a staff of four technicians with no staff in theregional offices. Its mandate includes the follow tasks: prepare and implementenvironmental policy and laws, recently institute a system for EA, set environmentalstandards, combat erosion and deforestation, take regulatory action to protect theenvironment, enhance environmental awareness, implement international treaties, andprovide support to the three islands.

20


(FADC 111)

The Comite Central de Coordination (CCC) of the executing agency, FADC, acts as aBoard of Directors setting the overall policies of FADC. It is composed of 15 memberswho are appointed by decree: 7 representatives from the Government Ministries and 8representatives from associations (2 from each island and 2 from national associations).It meets twice a year. Its responsibilities are to set FADC policies, approve the manual ofprocedures and annual work programs and budgets, decide on the level of communitycontribution to the cost of the sub-projects, analyze and audit reports, and appoint theNational Executive Director and Regional Executive Directors.

The Comites Regionals (CR) are in place in each of the three islands. They arecomposed of eight members: 2 representatives from the regional directorates ofGovernment Ministries and 6 other non-governmental members representing regionalassociations and chosen on the basis of their qualifications and their knowledge ofcommunities. Their primary responsibilities are to endorse the annual work programsproposed by the Regional Secretariats (FADC-SER), approve (through a regional projectsub-committee) all grants of less than CF 15 million, and submit to the Directeur ExecutifNational of FADC for decision of proposals for grants equal to or greater than CF 15million.

A Presidential Ordinance established FADC, an "organization in the public interest withadministrative and financial autonomy", on January 6, 1993. A Presidential Decree ofApril 13, 1993 defines its organization and management. The Secretariat ExecutifNational (SEN) and the three Secretariat Executif Regional (SER) are theadministrative/executing entities, which deal with the day-to-day operations of the FADCon the three islands. FADC has clear operating procedures, which are defined in aManual of Procedures. This manual contains the criteria and procedures for identifying,preparing, appraising, selecting, and implementing sub-projects. FADC will reviewcommunity proposals against the criteria defined in the Manual of Procedures, includingcommunity participation, impact, and priorities. Once approved by FADC, the localcommunities or beneficiaries will implement the sub-projects, which is in most cases bythe Comite de Pilotage. These village committees work with FADC-SER in identifying,preparing and implementing sub-projects. In accordance with the contracts that theyenter into with FADC, the village committees are also responsible for mobilizingcommunities to provide labor, materials, and cash for the sub-projects.

Given the lack of capacity at the national or regional level within the Department ofEnvironment, and the demonstrated ability to successfully manage both previous SocialFunds, FADC will remain the executing agency for the third phase of the project. Thesuccessful application of the environmental and social assessment process (contained inthis ESMF) at the level of the sub-projects will identify adverse environmental and socialimpacts as they relate to sub-project activities. To mitigate the project impactseffectively, the proposed institutional arrangements provide for environmental and socialassessment capacity building for the CPs at the local level, and environmental and socialoversight capacity building at the regional and central levels for FADC-SER and FADC-SEN.

21


(FADC 111)

Functions of Key Institutions for the Successful Implementation of this ESMF;

1) Comites de Pilotage: Consistent with OP 4.01 Environment Assessment, the CPs will

screen their sub-projects for environmental and social impacts at the time of

identification. They will apply the environmental and social assessment process for sub-

projects outlined in this Framework document, and thus prepare their sub-project

proposals consistent with the provisions of this ESMF.

The key elements for successful sub-project implementation by the CPs are:

* Capacity to manage the environmental and social management process forsub-projects: To enable CPs to apply the environmental assessment process for

sub-projects effectively, they will require technical support. At the sub-project

identification stage, this technical support would be provided through FADC-SER

and an environmental and social specialist who would be responsible for assisting

the CPs in the preparation of sub-project proposals, including resettlement plans

(if needed) and environmental and social screening and preparation of mitigation

measures as necessary and environmental and social assessment reports consistent

with this framework document.

* Capacity to manage potential social impacts of sub-projects: To ensure that

social impacts of sub-projects are addressed appropriately, a separateResettlement Policy Framework (RPF) has been prepared. It outlines the

principles to be applied in the event that negative social impacts arise due to the

need for land acquisition, or access to economic resources is loss, denied or

restricted to sub-project activities. CPs will be assisted by a social specialist to

prepare the resettlement plans required by the RPF document.

FADC will support the CPs to avail them of expert advice when needed by hiring a

qualified environmental and social assessment specialist to assist and work with them to

carry out their tasks. Following training and assistance, the ability of the CPs to conduct

environmental and social screening and to prepare appropriate mitigation measures for

sub-projects will be greatly enhanced and will not only raise the environmental awareness

among CPs, but will also ensure that the sub-projects are environmentally and socially

sustainable. Over time, the CPs will develop the capacity to screen potential investments

for environrmental and social impacts and to prepare and implement simple enviromnentalmitigation measures independently.

FADC-SER will also be responsible for the monitoring of (i) the environmental and

social assessment work to be carried out by the CPs assisted; (ii) environmental and

social monitoring of sub-projects; and (iii) overseeing the implementation of resettlement

plans.

Capacity of FADC will be enhanced by environmental and social assessment specialistswho will be hired by FADC to work with FADC at the national and regional level to

ensure that they carry out their role effectively.

22


(FADC 111)

Finally, the recently adopted Infrastructure, Water and Enviro1nmenlt Project will beadministered by FADC and finances will be channelled through the FADC which worksat the national, regional and community levels.

Approval of sub-project EAs by the Department of Environment

To ensure that the Environment Department is given the recognition and role it deservesin the country's overall development process and to also ensure that it exercises itsmandate, it should be part of the approval process of any sub-project with potentialimpacts.

6.0 GUIDANCE ON POTENTIAL IMPACTS

This section of the report presents guidance on the environmental and social impacts ofthe Social Fund III project, and potential impacts of the anticipated sub-project activities.The main focus of the guidance is to provide a set of procedures for the FADC staff whowill be charged with the responsibility of implementing the Environmental and SocialManagement Framework.

We discuss both the positive and negative impacts of both programs. We begin withconclusions on the overall impacts and specific impacts are described in greater detail forcommunity sub- projects to be funded through the FADC.

6.1 Overall Environmental and Social Impacts

Environmental and social sustainability are key to sustainable rural development, naturalresources management and conservation and poverty alleviation, particularly in countrieslike Comoros with its fragile ecological system as well as instable and erratic politicalclimate. Lessons learned from Social Fund projects I and II and from the recentlyinherited Infrastructure, Water and Environment project demonstrate that the lack ofproper environmental management and lack of inclusion of the social aspects have led toserious environmental and social impacts which are costly to rehabilitate if reversible atall. .It is therefore important to recognize that environmental and social inclusion at thedesign stages of projects is fundamental to the success of the social fund project.Discussions with different groups and during the workshops which were held on all threeislands indicate that they are fully appreciative of this important injection into theprocess.

6.2 Potential Positive Impacts

The overall positive environmental and social impacts predicted under the Social Fundproject are based on several facts key among them are;

23


(FADC 111)

(i) the National Executing Agency and its partners have now recognized thatinclusion of environumental and social management are fundamental to thesuccess and sustainability of the sub-projects;

(ii) this notion will help strengthen the traditional systems of environmental andsocial management;

(iii) local institutional strengthening and empowernent can be achieved throughimproved understanding and use of tools and mechanisms for environmental

(iv) management and social impact assessment and participatory communitydevelopment

The Social Fund III project has the potential to make a significant contribution toComoros' policy to protect the natural resource base which the country's populationdepends on for their livelihood while also reducing poverty in rural Comoros. At thistime, the overall environmental and social impacts are difficult to predict since they aredemand driven. Nonetheless, considering the susceptibility of the country's ecologicalsystem and the potential needs of the rural population, it is likely to predict the potentialimpacts however challenging they may be. Based on this assumption, the potentialpositive impacts of the project are likely to be:

(a) Improved land tenure security in a country where formal land tenure system doesnot exist and the traditional and religious system is complex and difficult to apply;

(b) Reduction of soil erosion and gully erosion particularly on steep hill sites;(c) Removal of threats and barriers to integrated ecosystem management and in

particular to conservation and sustainable use of biological diversity in naturalhabitats such as marine and forest parks, tortoises, marine mammals, and otherecologically important species in Comoros;

(d) Contribution to the decentralization process through community management ofnatural resources and integrated ecosystem management and decision makingprocess;

(e) Reduction in land degradation and coastal erosion mitigation benefits expected toarise from improvements in coastal zone management;

(f) Building partnerships between and among rural communities and withintemational and public/private institutions dealing with natural resourcesmanagement for shared resources conservation, knowledge sharing andmanagement;

(g) Provision of opportunities through training and capacity building to localcommunities for integrated enviromnental and social management.

6.3 Potential Negative Impacts

The overall potential negative environmental and social impacts predicted under thesocial fund project are based on the following reasons:

(a) Comorian life in general and rural life in particular is complex and this is alsocoupled with the fact that rural livelihoods vary from one island to the other andso does the level of complexity vis-a-vis the environment.

24


(FADC 111)

(b) It is recognized from this study that there is a significant lack of both human andinstitutional capacity at all levels of the system to be able to carry outenvironmental and social screening of the anticipated sub-projects. This mayincrease the existing environmental and social impacts within the areas ofintervention;

(c) Differential impacts of training and level of investment may result in somevulnerable groups relying to a greater extent than their wealthier counterparts onunsustainable use of natural resources;

(d) Introduced land tenure systems and systems of govemance versus traditional/religious systems may create conflict, or contradictions may result inunsustainable agricultural and natural resources management practices and for afragile ecosystem as Comoros that can have severe consequences on theenvironment and social fabric;

(e) Rising population pressures, a deteriorating resource base, climate change andagricultural extensification can lead to an increase in land-related conflicts on allthe three islands.

The Environmental and Social Management Framework and the Resettlement PolicyFramework commissioned by the Government of Comoros have taken these potentialrisks carefully into consideration both at the preparation and design of the third SocialFund project, especially considering the experience gained through the implementation ofthe first and second Social Fund projects.

6.4 Localized Negative Impacts

Most of the sub-projects planned under the proposed social development fund will besmall scale, therefore the significance of the direct negative social and environmentalimpacts are likely to be minimal. This is especially the case in comparison with therecently adopted Infrastructure, Water and Environment Project which concentrated onenlarging the national roads networks on the islands. Despite the potential small size ofthe sub-projects, they could have significant environmental impacts particularly due tothe fragility of the ecosystems like the slopes of the hills of Anjouan and Moheli as wellas those of Grande Comore. Experience in high land development has shown that unlesshighland sites are properly selected and any necessary infrastructure, improvements andprotection measures are well designed and constructed, this can lead to serious impacts.The national roads network in Comoros is experiencing serious problems and the cost ofrehabilitation by the Bank and other donors is a continuous problems. Also, developingthe infrastructure can and has created additional population pressure on fragileecosystems. Intensification of agriculture on all three islands can also result indecreasing existing biodiversity and loss of ecologically, economically and scientificallyimportant species.

6.5 Cumulative Impacts of Sub-Projects

Experience from the previous social fund projects in Comoros, i.e. Social Funds I and II,

25


(FADC III)

have shown that minimal as the environmental and social impacts of some sub-projectsmay be, together they can create bigger problems on the natural resource base. Examplesof such impacts which have been noticed on the islands are:

* Forest clearing for extensive agricultural practices which due to the sloppy natureof the terrain leads to depletion of the soil fertility;

* Deforestation due to the exploitation of the forest resources for distillation ofylang-ylang, construction and for fuel wood;

* Impacts on ground water resources due to the construction of numerous wells;* Waste and dumping sites due to the inappropriate disposal of waste materials

during and after construction.

6.6 Solid Waste Disposal

Indiscriminate disposal of solid waste in general and contaminated waste in particular isof great concern to the project. Water courses in Comoros may be vulnerable to pollutiondue to increased solid waste, and disposal of waste water, in association withpharmaceuticals, animal drugs and medical waste, or construction of infrastructurewithout adequate sanitation facilities. A number of clinics will be constructed andwithout the requisite medical waste disposal methods human and animal health will be atrisk. Water resource and land resource contamination is likely to happen. As MedicalWaste Management Planning has not yet been introduced to the Government of Comorosas is the case with most client countries which are part of the HIV/AIDS Program, it isnecessary to help prepare a small medical waste management checklist/plan to handlesuch aspects as:

* Laboratory waste-specimen or microbiologic cultures, stocks or infectious agents,live and attenuated vaccines, ands culture mediums;

* Blood or body fluids, liquid blood elements or other regulated body fluids, orarticles contaminated with blood or body fluids;

* Sharps items such as syringes, needles, blades, broken glass;

* Contaminated animals - animals carcasses, body parts, bedding materials;

Surgical specimens - human or animal parts or tissues removed surgically or byautopsy;

* Isolation waste.

6.7 Pest Management and Chemical Use

As Comoros' economy is predominantly dependent on agriculture and agriculturalactivities albeit small may result in intensification of crop production. Also certainlivestock activities like tick dips and other agricultural practices may lead to the increaseduse of agricultural chemicals to promote growth. It is important that appropriate

26

REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAI,

(FADC III)

planming, design and management be adopted for the proper and judicious handling ofagricultural chemicals to avoid potential negative environmental and human healthimpacts. While the anticipated sub-projects are mostly social infrastructure, smallagricultural activities may occur and as such, putting in place guidelines to assist in pestmanagement planning is important. The introduction of local pest management plans istherefore encouraged during the implementation of the social fund project. Such a planshould cover areas such as:

* proper use of agricultural chemicals;* prevention of chemical runoff into surface water sources to avoid negative

impacts on the aquatic environment;* proper use and handling of chemicals to avoid contamination of crops, soils, and

water bodies;* proper storage and handling to avoid adverse health impacts or rural farmers;* proper policing to ensure that banned chemicals are not distributed to fanning

communities.

6.8 Inaccessibility and the Poor and Vulnerable Communities

The amount of anticipated infrastructure development in the Comoros Social Fund IIIproject is important in many aspects, principal among which is the urgent need to accessthe poor and vulnerable groups. This may however not necessarily be the case as thesegroups may not afford the required contributions to qualify for a sub-project. Such maycontribute to the inequitable distribution of resources and further marginalization of thesegroups. The development of local development plans by FADC seeks to avoid thispotential for marginalization but the consistent participation of these vulnerable groupscan easily be limited by the mere fact that they are inaccessible and thereforeautomatically isolated. The third social fund project team recognized these facts andintends on introducing a method of inclusion of these vulnerable groups. The slidingscale as it is called is meant to accommodate such groups irrespective of whether or notthey can afford to meet the financing requirements for sub-project approval. This methodwill be further development during project appraisal and implementation. The projectteam and the national executing agency FADC recognize that while it is critical for thecommunities to receive guidance and support from the skilled facilitators of the FADC inmethods of comnmunity participation, project planning and management, it is equallyimportant that the Regional FADC offices and their counterpart Comites de Pilotagecontinue to work with vulnerable communities to ensure that their concerns are taken intoconsideration. Failing to do so will defeat the development objective of the project andthe World Bank's fundamental objective of poverty alleviation.

7.0 REPORTING and RESPONSIBILITIES for the ESMF/RPF

This chapter of the report sets out reporting systems and responsibilities of the executingagency for implementation of the Enviromnental and Social Management Framework.The section begins with details of issues that will be addressed by the ESMF, specificnext steps to be taken to ensure adherence to the recomnmendations of the ESMFincluding:

27


(FADC III)

The institutional arrangements for reporting and advice;The Screening checklist for community micro-projects;The Awareness Building Program;The role of the Environment/Social Specialist and the TOR.

7.1 Key Principles and Proposed Actions

The ESMF has been prepared on the basis of the following principles:

In collaboration with the FADC National and members of the Comites de Pilotage, theconsultant sought to avoid considering environmental sustainability of the Social Fundproject in isolation. Instead we considered how sustainability can be ensured at thecommunity level and how the Social Fund III's contribution can be maximized.

The consultant recognized that it would be unproductive if the social fund project was tofocus solely on the environmental implications of the Social Fund Financed sub-projectsalone, without also creating partnerships with the island communities, with NGOs andmost importantly to encourage collaboration between the various CP on the same islandsas well as between islands.

Secondly, in accordance with the fact that there are natural separations between the threeislands, the consultant considered that the bulk of the environmental inputs to the socialfund project are required at the community level. At the village community level, there isan opportunity to build on the close relationship of agriculture with environmental, socialand health groups, and improve awareness of the complexity of sustainable agriculturallivelihoods among all groups.

Third, while the ESMF proposes an elaborate system of screening for sub-projectactivities, it also proposes that environmental and social considerations are fullymainstreamed into the participatory process for identification, planning, implementationand monitoring of sub-project activities.The screening forms and checklist are therefore intended to be integrated fully into theProject Implementation Manual of the FADC and the overall system of projectmanagement.

7.2 Mainstreaming Environmental Management into the FADC Program

Environmental management and protection as earlier discussed is clearly one of theweakest links on the agenda of the government of the Republic of Comoros. TheEnvironmental Policy and National Environmental Law are the basis for sectoral andcross-sectoral coordination among ministries and line agencies in addressingenvironmental concerns of the three island country. While this coordination exists onpaper, it is very weak in reality. There is also a clear indication in the review of theinstitutional structure and on meeting with the Department of Environment that there areno officers or offices on the different islands. The department itself is weak in bothhuman and institutional resources and this renders it poor in bringing the environmentalagenda to the forefront of the national development process.

28


(FADC 111)

8.0 BUILDING CAPACITY for ENVIRONMENTAL MANAGEMENT

In discussions with the Executive Director of the FADC, the World Bank'senvironmental adviser and the Task Team Leader, it was agreed that the first step inbuilding the human resources capacity for environmental management under the SocialFund III Project is to identify the key players involved in the coordination andimplementation of the project. There are three levels of administration, namely National,Regional, and Community. The ESMF of the Social Fund project will be coordinated bythe National FADC and the implementation of the project's screening process will be theresponsibility of the Regions and the CP. Environmlental inputs will be mainstreamed atevery level of the project thus the need to enhance the awareness of these key actors.

To achieve these objectives, the project will hire an environmental/social specialist withclear Terms of Reference to advise and coordinate the implementation of theEnvironmental and Social Management Framework and the Resettlement Framework andalso to work closely with the Department of Environment and other partners in carryingout the Awareness Building Program.

At the Regional level, the FADC regional offices will continue to work with the specialistand communities to ensure that these aspects become part and parcel of the sub-projectidentification process as well as the planning and implementation of these sub-projects.

Table 7.0 Identifying Focal Points for Capacity Building

Focal Point FADC Coordination

Recommendation Appoint an environmental specialist tomanage the ESMF

Administrative Representative Position at FADC

* Action: To supervise the implementation of the ESMF and to monitor thereporting of the project output in relation to the ESMF;

* To liaise with the relevant Government agencies at the National, Regional andCommunity levels and particularly with the Department of Environment,fisheries, forestry and water resources and other environmental bodies in thecountry;

* To Implement the Awareness Building Program as proposed in the PAD throughinformation dissemination, organizing training on the different islands,workshops, and identifying institutional needs for environmental management.

The cost of hiring the specialist is to be priced as a local consultant under a fixed termcontract and the cost of the program is as indicated in the PAD.

29


(FADC 111)

7.1 Regional Level

At the Regional level the specialist should identify a focal point at each Committee dePilotage to support the community in implementing the Screening Process and approvingsub-projects. The focal point can either be an existing staff member from a regionalFADC or Government bureau with background in the environment, i.e. soils, water, andbiodiversity conservation, or, if one is not available, then an individual with suchexpertise can be identified and given short term assignments to assist the specialist as andwhen required.The role of the Regional Focal Point will be to:

* assist FADC-SER in implementing the sub-projects' environmental and socialscreening process;

* To provide technical guidance and advice in environmental and social issues as itrelates to sub-project location and design;

* To liaise with communities, government offices on the islands, and with NGOs.

7.2 Community Level

At the Community level it should be ensured that in each CP/CGL, there is a focal pointto support communities in screening and approving sub-projects. The FP works closelywith the FADC environmental specialist and with the Regional Focal Point to assist theirCP/CGL in using the screening forms to assess the potential impacts of proposed projectsand to liaise with Regional FADC Officers and Regional Focal Point for guidance andtechnical assistance on environmental and social matters.

7.3 The Awareness Building Program for Environmental Management

In recognizing the apparent weakness and poor understanding of environmental issuesand their relations to development in Comoros, the Awareness Building Programproposed in this report will attempt to address the following on the three islands:

* Sensitization among the Regional staff of the FADC and members of the CP asthey relate to agricultural and other economic activities and their coping strategiestowards environmental degradation in Comoros;

* Appreciation of the unpredictable, complex and dynamic nature of theirlivelihoods as they relate to the complex and fragile ecological systems as well asthe weakness of the environmental agenda in the country;

* To help minimize the potential damage of the anticipated activities of theproposed social fund project, sensitization of the key stakeholders will be requiredin advance of the commencement of the project activities on the ground;

* Awareness building among the key players and Community leaders on how tointegrate local traditional knowledge with modem environmental managementpractices particularly in relation to the sub-projects;

* Training of the FADC staff and community leaders on the use of the screeningprocess and reporting mechanisms for sub-project approval as set out in thescreening forms. This type of training should be mainstreamed into the trainingthat will be required for the smooth operation of the sub-project approval process.

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(FADC 111)

As is already proposed, the hired environmental specialist will draw up a trainingplan that will include the training of Regional FADC officers and Communityleaders. They in turn will be training members of their committees.

* Collaboration between members of the different CP, from the different islands(sharing experience among regions) particularly those involved in sub-projectidentification, natural resources management, and the screening process. Thisportion of the program will involve training in the use of environmental and socialguidelines in identifying and costing mitigation measures as well as advising onsocial safeguard issues.

As there is a great of traditional knowledge that has been applied over the years throughtrial and error, a key focus of the training and sensitization program should be onintegrating this knowledge in enviromnental management system of the proposed project.

7.4 Integrating Tradition Knowledge in the Environmental Management Framework

Traditional knowledge as it relates to Environmental Management will be taken intoconsideration in the development of the Awareness Building Program of the proposedSocial Fund project as follows:

(a) As the traditional land tenure system in Comoros is very complex, itsunderstanding and appreciation is fundamental to the location of the anticipatedsub-projects, particularly as they relate to land acquisition, land take, and loss ofeconomic activities. Its importance in relation to the World Bank's safeguardpolicy on Involuntary Resettlement cannot be overemphasized.

(b) Traditional land rehabilitation for agricultural development in an ecosystem that isfragile and complex is key to the sustainability of this sector as well as theconcomitant infrastructure development that goes with it. The Comorians haveover the years applied different conservation and rehabilitation methods albeitinsufficient and have to entertain new and more effective methods if their systemsare to be sustainable.

(c) Dependence on the forest cover for the distillation of ylang-ylang and the use ofwood for energy and building material need to be carefully looked into andalternative methods introduced;

(d) As water is a major limiting factor in both domestic and agricultural practices, theassessment of water resources and proper harnessing of these resources is criticalto the development of the country.

8.0 THE ENVIRONMENTAL MANAGEMENT AND SCREENING SYSTEM

The screening process as introduced in Annex 1 of this report is a compilation of themethods that will be applied in screening and evaluating sub-projects for environmentaland social impacts.

The main ingredients of the process are outlined below:

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(FADC III)

(a) A basic enviromnental and social screening form for the members of the Cp tocomplete when applying for sub-project financing.

(b) Basic environmental and social review form if there is the need for more detailedenvironmental and social appraisal of the project is required.

(c) Content of such forms should be clearly spelled out in FADC's ProjectImplementation Manual for community evaluation of projects followingcompletion.

(d) Format for lesson learning review of EIA by stakeholders in particular membersof the CP and other interested parties.

8.1 COSTS

The cost of implementing the Awareness Building Program as spelled out in the ProjectAppraisal Document (PAD) is properly incorporated in the project design.

* The cost of the environmental training and sensitization program has been agreedwith the Borrower and the project team and will be addressed under the projectbudget allocated for the entire Capacity Building component.

* Cost associated with the recruitment of an environmental /social specialist willalso be covered under the budget allocated for awareness building and training.

* Costs related to the mitigating of impacts associated with sub-projects financedunder the Social Fund are also allocated under the same budget, while the cost ofmitigating the impacts of the adopted roads, water and environment componentwill be assessed and internalized as part of the overall project budget. This willbe discussed with the Borrower and the project TTL during Project Appraisal.

Other additional costs to the project are potential relocation and compensation plansshould any proposed sub-project lead to land take, loss of economic activities and/orrelocation. When this happens, the Bank's team together with the Borrower (FADC) willdetermine the resources and budget needed to finance these plans.

Proposed Training Program Duration

Environmental and Social assessment process 5days* Screening process* Assignment of environmental categories* Rationale for using Screening form and Environmental and Social Checklists* Preparation of terms of reference for carrying out ESIA* How to review and approve sub-project proposals* The importance of public consultations in the EA process* How to monitor project implementation* Case studies

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(FADC 111)

Environmental and Social policies and procedures 3 days

* Review and discussion of Comoros' environmental policies, procedures, andlegislation* Review and discussion of the Bank's safeguards policies* Review of ESIA, Resettlement Plan* Collaboration with institutions at the local, regional and union levels

Selected topics on environmental protection 2 days

* Soil erosion* Flood protection* Waste disposal, including medical/veterinary waste, hazardous chemical wastes such aspesticides, insecticides, herbicides, etc.* Ground and Surface Water Management* Deforestation

8.2 Implementing the ESMF

The project is planned to be appraised in November 2003 and it is recommended that thefollowing steps be taken to implement the Framework:

Immediately after project effectiveness, the Awareness Building Program will commenceat all three levels, i.e. National, Regional and Local levels. This will be carried out oncethe specialist is recruited and is in place. The program will take place in the form ofworkshops and seminars in environmental assessment, the use of the screening processand training on filling the screening and review forms as well as the reporting forms.

By the second year of project implementation, the FADC and its partners would havelearnt from the first year projects to allow them to refine the screening process andenviromnental and social review forms to better fit the types of sub-projects beingimplemented. The environmental and social specialist would also be able to use thisexperience to develop guidelines for the various types of sub-projects since by the secondyear of project implementation a clear idea of the type of sub-projects being demanded bythe communities will emerge. It is also envisaged that by the second year ofimplementation and based on the lessons learnt, the team should be able to establish amonitoring and evaluation mechanism suitable for regular and efficient reporting.

9.0 ENVIRONMENTAL AND SOCIAL PLANNING, REVIEW AND CLEARINGPROCESS FOR SUB-PROJECTS

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(FADC III)

As stated earlier, at the time the Social Fund III project was being prepared, the sub-projects were not identified. Consequently, specific information on numbers of sub-projects, site location of sub-projects, land requirements, local communities, geo-physicalland features, nature, type and use of equipment/plant, etc. was not available. Therefore,exact details and intensity of social and environmental impacts and their effectivemitigation cannot be determined during project preparation. This document referred to asthe Environmental and Social Management Framework (ESMF) is thus prepared toestablish the mechanism to determine and assess future potential adverse environmentaland social impacts of sub-projects that are to be identified and cleared based on acommunity demand driven process described here below, and then to set out mitigation,monitoring and institutional measures to be taken during implementation and operation ofthe sub-projects to eliminate adverse environmental and social impacts, offset them , orreduce them to acceptable levels.

This section therefore, identifies and illustrates the specific steps involved in theenvironmental and social assessment process leading towards the clearance and approvalof the EA process for sub-projects. The steps incorporate both, relevant Comorosguidelines/requirements and the Bank's policy OP 4.01 Environmental Assessment, andon Involuntary Resettlement (the safeguard policies that apply for this project asdiscussed earlier) and are;

(a). The Comite de Pilotage will screen their own sub-projects to identifyenvironmental and social impacts using the screening form in Annex 1. Ina few cases the checklist may require that a sub-project conducts a sub-project environmental and social impact assessment (ESIA) for certaintypes of impacts.

(b). Then the implementers will introduce into the sub-project design therequired measures to mitigate impacts identified from use of the checklistbefore submission of the sub-project for review and subsequent approval.

(c). Review and clear the sub-projects by ensuring sub-project designs haveidentified environmental and social impacts, mitigated these impacts andhave monitoring plans and institutional measures to be taken duringimplementation and operation.

Using the screening form, revised enviromnental and social checklists and technicalassistance from service providers and information resources supported by FADC,proposed sub-projects will be screened by their respective implementers, to identify anypotential adverse impacts/effects from sub-project activities.

Once impacts are identified the necessary mitigation measure would then be identifiedfrom the checklist and then the sub-project would be designed to implement thesemitigation measures. For example, from a social standpoint if the screening formidentifies land acquisition needs that trigger OP 4.12 on Involuntary Resettlement, thenthe required mitigation measure would be to chose an alternative land site that does not

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(FADC III)

trigger this policy or, the implementer of the sub-project prepares a resettlement and

compensation plan consistent with the disclosed RPF.

From an environmental stand point, the screening form and checklist may identifyimpacts from sub-project activities, such as contamination of ground water sources due to

inappropriate waste disposal. The mitigation measure may be to choose a site far awayfrom the water source so that chances of contamination are not possible and/or

incorporate appropriate waste disposal measures into the design such as channeling all

waste to a closed system that is periodically emptied and disposed of safely.

For some cases (a minority of cases) where the impacts from sub-project activities are

determined by use of the checklist to be severe or difficult to mitigate, therecommendation may be that a sub-project ESIA be carried out following which the sub-project would then be designed to incorporate the required mitigation measures.

ESIA will be required for sub-projects involving new roads, incorporating the use ofhazardous chemicals and/or managing solid, liquid or medical wastes and for any sub-

project costing overUS$100,000. See Annex 2 forprocedures for sub-projects requiringESIA.

Once the implementers have completed the screening of their sub-projects and designedinto them the necessary mitigation measures, sub-project proposals would then be sent tothe FADC-SER for review and to check for compliance with this EA process.

The completed screening forms and completed checklists must accompany the sub-

projects that are sent for review. If the screening form has any "Yes" entries, or evidently

unjustified "No" entries, the application would need to adequately explain anddemonstrate from its design that the issue has been managed to avoid unacceptableadverse effects/impacts. If the application has satisfactorily addressed these issues it willbe recommended for approval to the respective approving body. For approved sub-

projects, the FADC-SER as reviewer will determine enviromnental and social approvalconditions the implementer must adhere to in the detailed planning, construction andoperation of the investment. These conditions may include, for example, such measuresas public involvement, siting or routing restrictions, construction and operation practices,restoration of disturbed areas, the complete implementation of a plan for resettlement orcompensation for land acquisition and, construction supervision to ensure the approvalconditions are being followed.

If, however the sub-project application unsatisfactorily addresses these issues it may berejected out right or rejected with the requirement to carry out a sub-project ESIA incases where one was not done before or with specific recommendations such as to changesite, or re-design waste management, reduce air pollution, etc.

The rejected sub-project will then have to be re-designed and re-screened by theimplementer and then re-submitted for review. The revised application will then have tobe reviewed again and, if now acceptable, will be recommended for consideration for

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(FADC III)

approval. If it is not acceptable for the second time, it would be referred back to theimplementer for more work or denied clearance altogether.

Any proposed sub-projects that do not comply with the requirements of the EnvironmentLaw 1997 of Comoros and the requirements of the World Bank Safeguards policies willnot be cleared for approval.

This process is designed to ensure that the environmental and social assessment processis part of and conducted during the sub-project design process thereby ensuring that sub-project activities are environmentally and socially sound and sustainable.

Environmental Management Plan (EMP): sub-project proposals must contain as partof the sub-project proposal an EMP that will consist of a set of mitigation measures,monitoring and institutional measures to be taken during the implementation andoperation of the sub-projects to eliminate adverse environmental and social impacts,offset them or reduce them to acceptable levels. The EMP should also include the actionsneeded to implement these measures, including the following features:

Mitigation: Based on the environmental and social impacts identified fromuse of the checklists, the EMP should describe with technical details eachmitigation measure, together with designs, equipment descriptions andoperating procedures as appropriate.

Monitoring: Environmental and social monitoring during the implementationof the sub-projects, in order to measure the success of the mitigationmeasures. The EMP should include monitoring objectives that specify thetype of monitoring activities that will be linked to the mitigation measures.Specifically, the monitoring section of the EMP provides:

* A specific description and technical details of monitoring measures thatinclude the parameters to be measured, the methods to be used, samplinglocations, frequency of measurements, detection limits (whereappropriate), and definition of thresholds that will signal the need forcorrective actions, e.g. the need for on site construction supervision.

* Monitoring and reporting procedures to ensure early detection ofconditions that necessitate particular mitigation measures and to furmishinformation on the progress and results of mitigation, e.g. by annual auditsand surveys to monitor overall effectiveness of the ESMF.

The EMP should also provide a specific description of institutional arrangements, i.e.who is responsible for carrying out the mitigating and monitoring measures (foroperation, supervision, enforcement, monitoring of implementation, remedial action,financing, reporting and staff training.)

Additionally, the EMP should include an estimate of the costs of the measures andactivities recommended so that the FADC can budget the necessary funds. The mitigation

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(FADC 111)

and monitoring measures recommended in the EMP should be developed in consultationwith all affected groups to include their concerns and views in the design of the EMP.

Public Consultations: Public consultations are critical in preparing an effective andsustainable sub-project. The first step is to hold public consultations with the localcommunities and all other interested /affected parties. These consultations should identifykey issues and determine how the concerns of all parties will be addressed in the terms ofreference of the design of sub-project activities. To facilitate meaningful consultations,the local governments through their implementers will provide all relevant material andinformation concerning the sub-projects in a timely manner prior to the consultation, in aform and language that are understandable and accessible to the groups being consulted.Depending on the public interest in the potential impacts of the sub-projects, a publichearing may be requested to better convey concerns. Once the sub-project has beenreviewed and cleared by FADC-SER, the implementers will inform the public about theresults of the review. This approach would be consistent with the Bank's OP 4.01Environmental Assessment as well as Comoros' efforts to enhance its participatoryplanning process.

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(FADC 111)

Annex 1 ENVIRONMENTAL AND SOCIAL SCREENING FORM

The Environmental and Social Screening Form (ESSF) has been designed to assist in theevaluation of sub-components of the Social Fund III in Comoros. The form is designedto place information in the hands of implementers and reviewers (FADC and CPs) so thatimpacts and their mitigation measures, if any, can be identified and/or that requirementsfor further environmental analysis are determined.

The ESSF contains information that will allow reviewers to determine thecharacterization of the prevailing local biophysical and social environment with the aimto assess the potential sub-project impacts on it. The ESSF will also identify potentialsocio-economic impacts that will require mitigation measures and or resettlement andcompensation.

Name of Sub-project:

Development Sector of Sub-project:

Name of Sub-project Execution Organization:

Name of District where is to be implemented:

Name of Local Government:

Name of Approving Authority:

Name, job title, and contact details for the person who is responsible for filling out thisform.

Name:

Job Title:

Telephone number:

Fax number:

E-Mail address:

Date:

Signature:

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(FADC III)

1. Brief Sub-project Description

Please provide information on the type and scale of the sub-project (project area, area ofrequired land, approximate size of total building floor areas, etc.)

2. The Natural Environment

(a) Describe the land formation, topography, and vegetation in/adjacent to the Sub-project area

(b) Estimate and indicate where vegetation might need to be cleared

(c) Are there any environmentally sensitive areas or threatened species (specify below)that could be adversely affected by the project?

(i) Intact natural forests Yes No_

(ii) Riverine forest Yes No_

(iii) Wetlands (lakes, rivers, seasonally inundated areas) Yes No_

(iv) How far are the nearest Wetlands (lakes, rivers, seasonally inundated areas)?km

(v) Habitats of endangered species for which protection is required underComorian laws and/or international agreements. Yes No_

(vi) Others (describe). Yes No_

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(FADC III)

3. Rivers and Lakes Ecology

Is there a possibility that, due to construction and operation of the sub-project, the riverand lake ecology will be adversely affected? Attention should be paid to water qualityand quantity, the nature, productivity and use of aquatic habitats, and variations of theseover time.

Yes No_

4. Protected areas

Does the project area (or components of the project) occur within/adjacent to anyprotected areas designated by government (national park, national reserve, world heritagesite etc.)?

Yes No_

If the project is outside of, but close to, any protected area, is it likely to adversely affectthe ecology within the protected area (e.g., interference with the migration routes ofmammals or birds)

Yes No_

5. Geology and Soils

Based upon visual inspection or available literature, are there areas of possible geologicor soil instability (erosion prone, landslide prone, subsidence-prone)?

Yes No_

Based upon visual inspection or available literature, are there areas that have risks oflarge scale increase in soil salinity?

Yes No_

6. Landscape/aesthetics

Is there a possibility that the sub-project will adversely affect the aesthetic attractivenessof the local landscape?

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(FADC III)

Yes No_

7. Historical, archaeological or cultural heritage site.

Based on available sources, consultation with local authorities, local knowledge and/orobservations, could the sub-project alter any historical, archaeological or cultural heritagesite or require excavation near same?

Yes No_

8. Resettlement and/or Land Acquisition

Will involuntary resettlement, land acquisition, or loss, denial or restriction of access toland and other economic resources be caused by sub-project implementation?

Yes No_

9. Loss of Crops, Fruit Trees and Household Infrastructure

Will the project result in the permanent or temporary loss of crops, fruit trees andhousehold infra-structure (such as granaries, outside toilets and kitchens, etc)?

Yes No_

10. Noise pollution during Construction and Operations

Will the operating noise level exceed the allowable noise limits?

Yes No_

11. Solid or Liquid Wastes, including Medical Waste

Will the sub-project generate solid or liquid wastes, including medical waste?

Yes No_

If "Yes", does the project include a plan for their adequate collection and disposal?

Yes No_

12. Pesticides, Insecticides, Herbicides or any other Poisonous or HazardousChemicals.

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(FADC III)

Will the sub-project require the use of such chemicals?

Yes No_

If, "Yes", does the sub-project include a plan for their safe handling, use and disposal?

Yes_ No_

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(FADC III)

Annex 2 Procedures for Sub-project Investments Requiring EA

Step 1: Screeninzg

To determine the depth of EA required, potential impacts in the following areas need tobe considered:

* Social issues* Health issues* Protected areas* Cultural heritage, archaeological sites* Existing natural resources such as forests, soils, wetlands, water resources* Wildlife or endangered species' habitats

Step 2: Scoping

To identify the relevant environmental and social issues, this step determines:

* Level of detail required for the EA* Extent of the area to be covered in light of the potential impact zones* Timeframe for the EA based on the potential impact zones* Sequencing and scheduling of the various EA tasks* Preliminary budgets

Step 3: Preparation of Terms of Reference for sub-project EAs

Based on the screening and scooping results, EA terms of reference will be prepared. Alocal service provider will conduct the EA, and the report should have the followingformat:

* Description of the study area* Description of the sub-project* Description of the environment* Legislative and regulatory considerations* Determination of the potential impacts of the proposed sub-projects* Public consultations process* Development of mitigation measures and a monitoring plan, including cost

estimates

Annex 2: Typical Checklist to Identify Impacts and Mitigation Measures of ConstructionSites under the Proposed FADC III

43

Environmental andSocial Components Impacts Mitigation Measures

Physical Environment

Soils - Erosion of lands down slope from borrow areas. Construction in dry season; protection of soil surfaces* Landslides and slips during construction; re-vegetation or physical* Contamination from waste materials, e.g. cement and paints, stabilization of erodable surfaces. Land restorationengine oils, etc. measures* Excavating borrow pits for aggregate materials (sand and stone) for Adequate protection from livestock entry by fencing theconcrete site perimeters

* Cutting of stone for use on fagades Control and daily cleaning at construction sites

Provision of adequate waste disposal services

Proper disposal of chemicals and other hazardousmaterials

Dust control by water, appropriate design and siting,restrict construction to certain times

Appropriate and suitable storage of building materials onsite

Water Resources * Creation of stagnant water pools Special attention to drainage; prevention of erosion;* Increased sediments into streams consideration of alternative alignments; retention ponds;* Clogging of drainage works proper disposal of oil and other hazardous materials* Decline in water quality* Increase in runoff and flooding conditions Siting of Latrines at safe distances from wells and using* Introduction of hazardous wastes closed systems for sewage drainage

* Contamination of wells

Air Quality * Dust during construction Dust control by water or other means

Acoustic Environment * Noise disturbance Restrict construction to certain hours

Bio-physicalEnvironment

Natural Habitats * Disturbance of natural habitats Consideration of alternative alignments or sites* Disturbance to protected areas


(FADC III)

Fauna and Flora - Disruption or destruction of wildlife Minimize loss of natural vegetation during construction;* Threats to rare and endangered species alternative sites; various special measures for sensitive

speciesSocial Environment

Aesthetics and Landscape * Marred landscapes Restoration of vegetation; cleanup of construction sites* Debris

Historical/Cultural Sites - Degradation of sites Alternative alignments and/or sites* Disturbance to structures Special measures to protect cultural heritage sites

Human Health * Transport of hazardous substances Regulation of transport of materials* Traffic accidents Safety designs (signage)* Pedestrian accidents Ensure availability of clean potable water for use in

latrines, canteens and for drinkingUse of appropriate building materials. No asbestos etc.

Human Commnunities * Involuntary resettlement Prepare Resettlement and Compensation Plans* Loss of crops, buildings, property, or economic livelihood consistent with disclosed RPF as per OP 4.12

Environmental andSocial Components Impacts Mitigation Measures

Physical Environment

Soils * Erosion of lands down slope from borrow areas. Construction in dry season; protection of soil surfaces* Landslides and slips during construction; re-vegetation or physical* Contamination from waste materials, e.g. cement and paints, stabilization of erodable surfaces. Land restorationengine oils, etc. measures* Excavating borrow pits for aggregate materials (sand and stone) for Adequate protection from livestock entry by fencing theconcrete site perimeters

* Cutting of stone for use on fagades Control and daily cleaning at construction sites

Provision of adequate waste disposal servicesProper disposal of chemicals and other hazardous

materials

Dust control by water, appropriate design and siting,restrict construction to certain times

Appropriate and suitable storage of building materials onsite


(FADC III)

Water Resources - Creation of stagnant water pools Special attention to drainage; prevention of erosion;* Increased sediments into streams consideration of alternative alignments; retention ponds;* Clogging of drainage works proper disposal of oil and other hazardous materials* Decline in water quality* Increase in runoff and flooding conditions Siting of Latrines at safe distances from wells and using* Introduction of hazardous wastes closed systems for sewage drainage* Contamination of wells

Air Quality * Dust during construction Dust control by water or other means

Acoustic Environment * Noise disturbance Restrict construction to certain hoursBio-physicalEnvironment

Natural Habitats * Disturbance of natural habitats Consideration of alternative alignments or sites* Disturbance to protected areas

Fauna and Flora * Disruption or destruction of wildlife Minimize loss of natural vegetation during construction;* Threats to rare and endangered species alternative sites; various special measures for sensitive

speciesSocial Environment

Aesthetics and Landscape * Marred landscapes Restoration of vegetation; cleanup of construction sites* Debris

Historical/Cultural Sites * Degradation of sites Alternative alignments and/or sites* Disturbance to structures Special measures to protect cultural heritage sites

Human Health * Transport of hazardous substances Regulation of transport of materials* Traffic accidents Safety designs (signage)* Pedestrian accidents Ensure availability of clean potable water for use in

latrines, canteens and for drinkingUse of appropriate building materials. No asbestos etc.Human Communities * Involuntary resettlement Prepare Resettlement and Compensation Plans

* Loss of crops, buildings, property, or economic livelihood consistent with disclosed RPF as per OP 4.12


(FADC 111)

Annexe 4 Liste des documents consultes

1. Les Termes de Reference

2. Project Concept Document (PCD)

3. The evolving Draft Project Appraisal Document (PAD)

4. The approved Integrated Safeguards Data Sheet (ISDS)

5. Aide Memoires de la Mission

6. L'Etude d'Impact sur L'Environnement Par la Societe Scetauroute, Decembre1999

7. Le Manuel de Procedures pour FADC

8. Rapport National sur les Objectifs du Millenaire pour le Developpement

9. Loi-cadre N° 94-018 du 19 juin 1995 relative a l'environnement

10. Decret N°0 1-053/CE dul9 avril 2001 relatif au Parc Marin de Moheli

11. Decret N°01-052/CE dul9 avril 2001 relatif aux Etudes d'Impact surl'Environnement

12. Rapport de Pre-evaluation du Programme National de Developpement HumainDurable

13. Politique Nationale de l'Environnement de la Republique Federale Islamique desComores

14. Les Politiques de Sauvegarde de la Banque Mondiale

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(FADC 111)

Annex 5 Villages Visited during Field Mission

Grand Comore

* Moroni* Hahaya* Mitsamiouli* Vouvouni* ItsandraS

Anjouan

* Ouani* Mutsamudu* Moya* Domoni* M'Remani

Moheli

* Fomboni* Wanani* Miringoni* Salamani* Hoani

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(FADC III)

Annex 6 Country and Island Maps

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(FADC III)

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REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES FADC...

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