REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES FADC .REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES FADC III

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  • 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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  • REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL

    (FADC III)

    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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  • REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL

    (FADC III)

    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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  • REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL

    (FADC 111)

    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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  • REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL

    (FADC III)

    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 po