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Page 1: Saint Lucia Water Supply Infrastructure Improvement Project€¦ · The urgent need to improve the availability of good quality drinking water in the northern section of St. Lucia

Environmental Assessment (EA) Saint Lucia Water Supply Infrastructure

Improvement Project

]March 25, 2005

Prepared for the World Bank

E1134

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Page 2: Saint Lucia Water Supply Infrastructure Improvement Project€¦ · The urgent need to improve the availability of good quality drinking water in the northern section of St. Lucia

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TABLE OF CONTENTS

1. EXECUTIVE SUMMARY 1 2. INTRODUCTION 3 3. DESCRIPTION OF ALTERNATIVES 3

3.1. Alternative 1 – Improve Capacity of Existing System (Capacity Improvement) 4

3.2. Alternative 2 – Installation of a Mobile Desalination

Plant at Pigeon Point (Desal- Plant) 11 4. REGULATORY AND LEGAL FRAMEWORK 12

4.1. General Legislative Authorities 12

4.2. WASCO legislation 13

4.3. Public Health Legislation and Regulations 17

4.4. Employees (Occupational Health and Safety) Act No 10 of 1985 18

4.5. International Treaties 18

5. DESCRIPTION OF ENVIRONMENT 21

5.1. Physical 21

5.2. BIOLOGICAL 23

5.3. Socioeconomic 27 6. ANALYSIS OF IMPACTS AND MITIGATION 36

6.1. Summary Overview 36

6.2. Alternative 1 – Improve Capacity of Existing System (Capacity Improvement) 37

6.3. Alternative 2 – Installation of a Mobile Desalination

Plant at Pigeon Point (Desal- Plant) 44

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7. ENVIRONMENTAL MANAGEMENT PLAN 52

7.1. Contract development 52

7.2. Vigilance 53

7.3. Close out 53

7.4. WASCO Responsibilities 53 8. MANAGEMENT RECOMMENDATIONS 54 9. INSTITUTIONAL IMPLEMENTATION 54 10. CAPACITY BUILDING 54

APPENDICES - APPENDIX I, IUCN Criteria for Critically Endangered, Endangered and Vulnerable APPENDIX II, DRAFT ENVIRONMENTAL MANAGEMENT CONTRACT CLAUSES

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1. EXECUTIVE SUMMARY

The urgent need to improve the availability of good quality drinking water in the northern section of St. Lucia is obvious. Current inadequacies of the distribution system coupled with the demands for growth in the region are placing increasing pressure on the distribution system. The ability to service all population segments is a priority with the greatest benefit going to low income families. At risk groups include children under 5 and the elderly. These groups will realize a greater proportional benefit from improved access to public water supplies. The impacts associated with both alternatives differ widely given the technologies involved and the users served by the two options. Both options will result in induced development in the extreme northern service area (Rodney Bay, Grose Islet) as pent-up development demand is currently frustrated due to lack of water. Numerous communities have been designed and laid-out with supporting infrastructure but are not developing due to poor land sales. There are also plans for the construction of no less than 4 new hotel complexes in the region.

Environmental Impacts Generally, impacts associated with the first alternative – Capacity improvement, are related to construction activities at the work site. Only those portions of the project involving the construction of new pipelines will affect the community at large as these works will require access to private lands. Those works to occur in public roadways present additional but manageable impacts. The greatest positive impact associated with this option is that it improves the ability to provide a reliable supply of potable water throughout the Theobolds WTP service area and reaches into low income communities where service is poor or non-existent. These are the groups least able to afford developing alternative sources to public water supply. While this option will result in the continued development of the extreme northern service area, the infrastructure and current supply are adequate to meet the current and anticipated future demand. The second option, the Desal-plant, provides water only to a specific section of the Theobolds WTP area. While it would relieve the system of short term demands emanating from that area, it would not permit the other improvements necessary to reliably supply water throughout the Theobolds WTP service area. Aside from the greatly increased costs of water production, the desal option contains a variety of other environmental consequences. These include for example, aesthetic issues, management of seawater intake and brine discharge, chemical pollutants, ecological and marine habitat concerns, issues associated with endangered species and increased energy demands. Furthermore, it is clear, given the pressure for growth in the

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plants service region, that the demand on the system will quickly increase as new construction begins again in the belief that water is readily available. Finally, the service area for the desal plant represents one of the highest income areas of the island where the average household income is nearly double the national average. This indicates that the direct benefits of this option will not be distributed among the middle to lower income brackets more prevalent in the greater northern service area. The additional cost associated with the production of desalinated water would not be borne by the local service area but would necessarily be folded into the general cost of WASCO water production. Paying for this additional cost would have to be distributed across the entire population through the entire system. Absent a special use fee for the service area, the result is a form of water subsidy for the most affluent portion of the country.

Comparison of Alternatives Of the two options, option 1, Capacity upgrade, produces the greatest long-term benefit for the entire service area and addresses the total water demand over the next 10 – 15 years. The capacity upgrades clearly meet the long term growth requirements of the northern section with greater reliability, lower cost, and fewer significant direct environmental impacts than the desal option. Neither alternative has constructions planned in an area suspected of containing undiscovered artifacts or areas of cultural-historical significance.

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2. INTRODUCTION A program of improvements to the St. Lucian public water system is contemplated to alleviate the shortages currently experienced in the northern portion of the distribution system. The two scenarios examined include:

• Improvements to increase the capacity of the current system

• Installation of a 20,000m3/day desalination plant Of the two options, the improvements to existing capacity has the greatest impact on the service region by making water available to a wider segment of the population. The Desalination plant is planned in a sub-region of the northern part of the island and while alleviating the short-term demand for water, services a limited population in an explosive growth area. In either case, development in the north is hampered by the lack of water. This report explores the environmental impacts associated with the two alternative projects.

3. DESCRIPTION OF ALTERNATIVES Two alternatives are under consideration for the improvement of potable water services under this project. The first involves the improvements to existing infrastructure and the amplification of the existing water treatment facility at Cicero. As the map indicates, figure 3.1, this system is connected to the John Compton reservoir the principal source of water to the north end of the island. The second alternative is the installation of a containerized desalination plant at the north end of the island. This plant would be built with a 20,000 m3/day production capacity. The objective of both alternatives is to improve water availability to the northern end of St. Lucia and areas in the vicinity of Castries which currently receives limited or intermittent service. This program is part of a comprehensive strategy to strengthen the water sector, which is essential to the economic development and growth of Saint Lucia. The sector has tremendous impacts on health, agriculture, tourism, industry and the quality of life. It is important to note that the benefits of the recommendations outlined can only be realized with the implementation of the capacity upgrades recommended for the entire Roseau System. Calculations illustrate that the 2003 demand exceeds the capacity of many of existing components in the Roseau System. As indicated Table 3.0 below summarizes the current and projected demands as well as the existing capacities of the infrastructural components required for production.

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Table 3.0 Current & Projected Demands (Roseau System)

SYSTEM Existing Capacity (MGD)

Demand 2003* (MGD)

Demand 2010* (MGD)

Demand 2015* (MGD)

Demand 2020* (MGD)

Demand 2025* (MGD)

ROSEAU SYSTEM a) Pumps b) Pipeline c) Treatment Plant

6.20 (max) 6.00 (max) 6.20 (max) 6.20 (max)

7.19

8.66

9.92

11.41

13.16

Improvement to existing infrastructure comprises a 4 part program designed to improve treatment and distribution for the northern end of the Island. Project elements include:

• John Compton Dam Pumping Upgrade

• Removal of Vanard-Sarot Bottleneck

• Expansion of the Theobalds Water Treatment Plant (WTP)

• Upgrade of Morne-Bocage Distribution Line

3.1. Alternative 1 – Improve Capacity of Existing System (Capacity Improvement)

3.1.1. John Compton Dam Pumping Upgrade

The John Compton Dam pumping facility is the primary intake, transmission and distribution of raw water in St Lucia. The sequence of operations that form part of this facilty require extraction of water from a built-up dam using a parallel-pump configuration consisting of five (5) pumps, pumping in sequence to a collecting tank located at the Millet Ridge which flows by gravity to the Theobalds Water Treatment Plant at Ciceron in Castries. See Figure 3.1. Currently, the existing configuration cannot meet the forecasted demand for the year 2000 and beyond, to the year 2025. recommendations for an upgrade to the facility have been made. Some of the problems identified included Inadequate capacity to maintain current demand as well as the lack of back up capacity in the event of mechanical and or electrical failure.

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With the John Compton Dam as the primary source of supply, recommendations are to increase the output of the current facility to match current and future demands. The proposed solutions to the above stated problems are as follows:

• Upgrade of pumping capacity to match future demand (i.e. to the year 2025).

• Upgrade of pipework and other civil works Replacement of the current standby generating set to accommodate for the increased power supply requirements of the larger pump-motor assemblies. The scope of work required includes the replacement of the the existing pump-motor assemblies, as shown in the photo presented in figure 3.2, No.4 & No.5 (rated at 150 Hp (horsepower) each), with larger capacity pump-motor assemblies (rated at 200 Hp each). The pump-motor assembly unit No.3 is also to be replaced by a 150 Hp unit. This upgrade will facilitate a pumping capacity of approximately 10 MGD as opposed to the existing 6 MGD capacity. The resulting increase in power supply requirements will require an increase in the standby generating capacity and slight changes to the electrical appurtenances inclusive of the Motor Control Center to accommodate the increased electrical demand required to sustain at least four pumps in the event of a power loss to the station. These works are planned as upgrades or replacements for existing infrastructure, and fall with the the existing operational design parameters of the system. This pipeline would be installed parallel to the existing 18” pipeline which would upgrade the raw water transmission pipeline capacity of up to 10 MGD from the Roseau dam and Millet intake. The joint restraints will be installed on pipe sections between Millet and Vanard stations at river crossings to improve the integrity and reduce the disaster vulnerability of the pipeline particularly when exposed to heavy river flows.

Figure 3.1

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Project Area and Generalized Infrastructure

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Figure 3.2 Pumps at the John Compton Dam

3.1.2. Expansion of the Theobalds Water Treatment Plant (WTP) The T.R.Theobalds Water Treatment Plant , or the Ciceron Water Treatment Plant as it was formerly known, was commissioned in March 1993 as part of the upgrade of the general water works that formed part of the Roseau Basin Water Development Project. The components completed under that project included the construction of a 750,000,000 gallon rock filled water dam complete with a pumping station, a new water intake and raw water transmission pipeline at Millet stream extraction station, construction of a 100,000 gallon header tank at Millet, a raw water transmission pipeline between Millet and Ciceron, construction of a modern water treatment plant at Ciceron (T.R.Theobalds ) and finally the first phase installation of a new treated water transmission main from T.R.Theobalds to Port Castries. The T.R.Theobalds Water Treatment Plant is designed to meet the needs of persons living the northern portions of the island. The areas serviced by this facility plant include all of Castries, the Roseau Basin, Babonneau and Gros Islet and associated rural areas. Demand calculations for the north of the island indicate a current domestic demand (2003) of 5.39 MGD. The demand from the commercial sector such as hotels, cruise

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ships and other large consumers is an additional 2.5 MGD. This represents a total daily demand of 7.89 MGD. To date the plant is treating on average a total of 6 MGD. This increase in treatment capacity is in keeping with the maximum design capacity of the plant of 6.5 MGD. Minor modifications have already been made to the plant with respect to the filter media in two of the bays and the use of a coagulant aid – Polymer (PAX-18) for sediment flocculation to improve throughput in the existing facility. The original design of the system included the installation of a duplicate plant on space reserved at the same site in order to ultimately produce a maximum of 10.0 MGD. This was anticipated to meet the population demands beyond 2005. Limiting the productivity of the future system however, is the raw water transmission pipeline capacity. New larger pipe (24 inch) was connected to 18 inch lines during the initial project resulting in flow restrictions to the system. The intention was to address replacement of these older lines in the future program phase bringing transmission capacity up the original system design specifications. For the additional treatment capacity to have its desired effect, transmission line upgrades will be required as the available supply will be insufficient to realize the benefit of increased treatment capacity. Specifically, the expansion of the Theobalds Water Treatment Plant (WTP) will include the following elements:

• Expansion of the existing facility – This to meet the capacity of the raw water transmission system which is expected to be approximately 10 MGD.

• Modification of receiving chamber - to allow for the increase in flows.

• Introduction of plate or tube settlers – to improve the efficiency of the clarifiers by 40% to 50%. The settlers will increase the surface area in the clarifier, thereby reducing the settling time by more then 50%.

• Construction of settling tank or pond for the re-cycling of back wash water and

sludge collection - asettling tank or pond would be constructed for the treatment of back wash water which is normally discharged with the solids. At an operating volume 9.0 MGD, the total backwash water volume is about 400,000 gallons per back wash cycle. In order to reuse the backwash water it will be necessary to construct a pond to contain this water and to recycle it. With planned improvements to the system, the projected backwash interval when operation at 9.0 MGD is every 2 days.

• Trucking of Sludge – the installation of water recovery and sludge drying areas

will allow the removal of solids to the Beausejour Sewage Treatment Facility for further processing and drying. Sludges are currently discharged directly to a nearby surface stream.

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3.1.3. Upgrade of Morne-Bocage Distribution Line This component focuses on the Morne, Bocage and Morne Du Don Water Distribution System. Demand calculations for the north of the island indicate a total daily demand of 7.89 MGD, not including the storage demand, can be expected. Combined supply figures for the Roseau and Hill 20 systems vary between 7.4 MGD and 6.5 MGD during the wet and dry seasons respectively. Domestic demand for the Babonneau region is estimated at 0.7 MGD. The high elevation areas in the Castries region, (such as Upper Morne Du Don, Bocage, Upper Entrepot and Carillie) are supplied by both the Theobalds and Hill 20 water treatment systems. Hill 20 derives its raw water from two stream extraction stations.. During the rainy season, excess water produced by the Hill 20 System is the primary source of potable water. During the dry season, however the stream flows are greatly reduced and raw water available to the Hill 20 plant is often not capable of supplying the Babonneau region. Under these conditions, water is diverted from the Roseau System to Hill 20. Water is pumped from the Theobalds WTP to Morne via an 8” PVC pipeline. This line flows by gravity to the Bocage reservoir tank through a badly corroded 6” cast iron pipeline. Current domestic demand (2003) requires a pumping capacity at Theobalds WTP of approximately 1.84 MGD and a gravity line with a capacity of 1.69 MGD. Current capacities for the pumping and gravity system are 0.9 MGD and 0.76 MGD respectively. Table 3.1 summarizes the existing system capacities and present and projected demands. During the dry season, poor infrastructure and the lack of raw water in the Hill 20 System, dictate that stringent rationing schedules be implemented. Most of the high elevation communities in the Castries and Babonneau areas which enjoy a daily supply during the rainy season, only receive water for a few hours once or twice weekly. This is a rural area and residents most effected include numerous low income families who are unable to purchase storage tanks to compensate for the interruptions in supply.

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Table 3.1 Current & Projected Demands (Roseau System & Hill 20 System)

SYSTEM Existing Capacity (MGD)

Demand 2003* (MGD)

Demand 2010* (MGD)

Demand 2015* (MGD)

Demand 2020* (MGD)

Demand 2025* (MGD)

ROSEAU SYSTEM Ciceron P.S. Morne to Morne

Du Don Pipeline

6.20 (max) 0.90 (max) 0.76 (max)

7.19 1.84 1.69

8.66 2.10 1.93

9.92 2.31 2.13

11.41 2.53 2.34

13.16 2.78 2.57

HILL 20 SYSTEM Wet Season Dry Season

1.20 (max) 0.24 (min)

0.70

0.80

0.89

0.97

1.06

TOTAL Wet Season Dry Season

7.40 (max) 6.44 (min)

7.89

9.46

10.81

12.38

14.22

* Figures do not include demand generated by private storage tanks.

The specific system upgrades to be constructed include the following:

• New Ciceron Pump Station at Theobalds WTP - Installation of three duty pumps and one standby pump at Ciceron to meet the estimated water demand of 2.31 MGD by 2015.

• New dedicated 12” Pumping Main - Install a 1900m pipeline to improve supply

flows from Theobalds WTP to Morne Fortune. Pipeline upgrades are designed to meet water demands estimated at 2.53 MGD in 2020.

• New 200,000 Imperial Gallon (Igal) tank at Morne Fortune - Install a 200,000

Igal tank at Morne Fortune to provide additional storage for Flow stabilization during peak demand, Flow stabilization required for firefighting, and Emergency storage.

• New 12” gravity main, 4900m - Install a dedicated transmission pipeline directly

to existing storage tanks at the Morne and Morne Du Don. This special pipeline link and valve assembly will allow the Theobalds WTP to feed the Bocage Reservoir tank and the Hill 20 WTP.

• New 100,000 Imperial gallon (Igal) tank at Babonneau - This storage facility will

be required Install a 100,000 Igal tank at Babonneau, near the Hill 20 WTP to accept flows from the Morne. This is to provide additional storage for Flow

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stabilization during peak demand and flow stabilization required for firefighting, and Emergency storage

3.2. Alternative 2 – Installation of a Mobile Desalination Plant at Pigeon Point (Desal- Plant)

The second alternative is the installation of a 20,000 M3 desalination plant along the east end of the Pigeon Point causeway. The proposed site is on the west coast of the island, north of Rodney Bay. This alternative involves the installation of a portable, containerized facility covering approximately 2,200 sq. ft. in the vicinity of the Rodney Bay public beach. The installation will include necessary upgrades to electrical supply and the installation of backup power systems. A transmission line of approximately 700 meters in length is to be constructed along the causeway to connect with WASCO transmission system. Water would then pass to the local pumping network to service the extreme northern portion of the island including Rodney Bay, Cap estates and surrounding areas. The proposed location is undeveloped and covered with vegetation typical of the region; acacia and other dry adapted flora adapted typical of the island’s dry coastal environs. The planned service area is the northern segment of the current WASCO distribution system and includes Gros Islet, Rodney Bay , Cap estates Casen Ba and surrounding areas. The service area is currently experiencing significant water shortages as the restrictions in the current WASCO transmission system permit pumping to the area 2 or 3 days per week. Additionally, current capacity limitations in the WASCO system do not permit the development of sufficient water pressures to reach houses constructed at higher elevations. The area is located behind a critical elevation in the WASCO system where water originating at the Theobalds WTP is pumped. After the topographic rise, the flow is by gravity to a series of local pumping stations used to maintain distribution pressures in this portion of the network. The result is that the water produced by the desalination plant will only service the local area as the WASCO system cannot distribute this water beyond the gravity fed portion of the line. This portion of the Island is an important tourism and commercial area which is under intense development pressure. Several hotels are in operation in the area and several more are planned for future construction. This is an affluent area filled with large homes and vacation residences. Additionally, the area supports a golf course and plans are for the development of several housing areas for residents and vacation homes. Also in this area is the Rodney Bay complex which supports the island’s largest recreational port. It is the “dry” end of the island and alternative water supplies, apart from rainwater storage, do not currently exist. One hotel, on the Pigeon Point causeway has installed a

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desalination unit to augment the public water supply. Intakes and brine returns are located in the sea on the north side of the causeway. Residents and businesses in the area have constructed a large number of personal storage tanks to help alleviate the shortages due to the limited mainline supply. These tanks can reach as much as 10,000 Igal in capacity. As a result, when water is available, WASCO is constantly supplying future water demand, by filling tanks, rather than satisfying the much lower daily end-of-pipe demand. Tanks at lower elevations are filled first with those at higher elevations having access to water on a much shorter time schedule. This has created an artificial drought return period that only increases as residents continue to install large storage tanks. Specifically, this alternative involves:

• Construction of a mobile desalination plant at the pigeon point causeway

• Construction of appropriate office, laboratory spaces and sanitary services fro operating staff.

• Construction of a transmission line to link with the WASCO system

• Providing sufficient pumping capacity to move water to the local WASCO

pumping stations. Water would be drawn either from Rodney Bay or the sea along the northern side of the causeway via 12 inch buried pipeline. Brine discharges would be routed either to Rodney bay or the sea to the north as well.

4. REGULATORY AND LEGAL FRAMEWORK

4.1. General Legislative Authorities There are four main institutions with shared responsibility for the management of inland water resources and related environmental policy in St Lucia. These are:

• Ministry of Agriculture, Forestry and Fisheries

• Ministry of Physical Development, Housing & Infrastructure

• National Water & Sewerage Commission (NWSC)

• Ministry of Health The principal environmental regulatory instruments in St. Lucia are dispersed among the four principal government agencies as presented in table 4.1. While conservation law is

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fairly strong, laws pertaining to the use of lands and management of their environmental impacts are relatively new and not well enforced. Additional supporting environmental management instruments are presented in table 4.2. As a resource manager, the Ministry of Agriculture, Forestry and Fisheries has overall responsibility for the protection of both land and marine resources for conservation as well as managed exploitation. The Ministry of Planning is in the process of strengthening its capabilities in both land use planning and in the establishment of a new building code. In their enabling legislation, the Physical Planning & Development Act, 2001, the ministry is also responsible for the review of environmental impact statements, which are only required for major projects. A land rationalization and titling program is underway but a significant amount of land remains untitled. Finally, in theory, the Ministry of planning grants use and building permits for constructions. This process is co-managed by WASCO as the Ministry should not grant permits unless WASCO has approved the connection to the public water and sewage system. Inefficiencies and poor communication between WASCO and Ministry of Planning have limited the effectiveness of this process.

4.2. WASCO legislation The Water and Sewerage Act (No. 13 of 1999) repealed the Water and Sewerage Authority Act (No 18 of 1984) and provides for establishment of a National Water and Sewerage Commission to regulate the granting of licenses, the development and control of water supply and sewerage facilities and related matters. The Act requires that all existing gathering grounds be retained as forest reserve or protected forest in accordance with the Forest, Soil and Water Ordinance, or be declared controlled areas, in which no person or public authority can claim or obtain the right to abstract and use water or construct works except in accordance with the Act. The Act also provides for proclamation of additional gathering grounds, to forest reserve, protected forest, or controlled areas. The Act protects the storage capacity or sanitation of gathering grounds from deforestation and animals, via the Minister responsible under the Forest, Soil and Water Conservation Ordinance, the Ministry of Health under the Public Health Act of 1975, or directly (in the case of animals) should responsible agencies not take appropriate action. The National Water and Sewerage Commission, established under the Water and Sewerage Act of 1999 is also required to regulate the granting of licenses and development and control of water supply and sewerage facilities. The Commission must work with WASCO for the purpose of conserving, redistributing or otherwise augmenting water resources.

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Table 4.1 Key Environmentally Related legislation

Agency Legislative Mandate

Ministry of Agriculture, Forestry and Fisheries

Department of Forestry Department of Agriculture Forest, Soil & Water Ordinance, 1946 Wildlife Protection Act, 1980 Water Resources Policy (Draft) Land Conservation & Improvement Act, 1992 Pesticides & Toxic Chemicals Act, 2001 Agricultural Small Tenancies Act, 1983

National Water & Sewerage Commission (NWSC)

Water & Sewerage Act, 1999

Ministry of Physical Development, Housing & Infrastructure

Physical Planning & Development Act, 2001

Ministry of Health

Environmental Heath Department Public Health Act, 1975 Public Health (Water Quality Control) Regulations, 1978 etc. ENVIRONMENTAL RESOURCES MANAGEMENT GOVERNMENT OF ST. LUCIA

Table 4.2 Government of St. lucia

Selected Water and Environmentally related Mandates

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Agency Instrument Notes

Land Conversation and Improvement Act (1992)

Provision for improved land drainage conservation

Establishment of Pesticides Control Board Control of import, use, labeling and storage of pesticides

Pesticides & Toxic Chemicals Act (2001) Pesticides Control Regulations (1987)

Registration of and licenses for use and storage of pesticides

Agricultural Small Tenancies Act (1983)

Enforcement of regulations requiring sound soil and water conservation practices on small holdings Control of plant pests and diseases

Department of Agriculture, MAFF

Plant Protection Act (1988) Regulations SI (1995)

Prevent the introduction of exotic species

Management of forest resources

Establishment of forest reserve and protected forests

Protection of forest, soil, water and wildlife resources

Forest, Soil and Water Conservation Act (1946)

Management of water catchments

Department of Forestry, MAFF

Wildlife Protection Act (1980) • Conservation of wildlife

Designation of wildlife reserves

Water Resources Policy (draft)

Promotion of the integrated management of water resources

National Water & Sewerage Commission

Water & Sewerage Act (1999) • Management of water resources (ensure sustainability of water resources, promote public awareness and disseminate information about water resources management)

Regulatory oversight of water supply and sewerage services

Ministry of Physical Development, Environment and Housing

Physical Planning & Development Act (2001)

Land use planning, development control, formulation and implementation of housing policy, environmental management

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Agency Instrument Notes

Environmental Health Department, Ministry of Health

Public Health Act (1975), Public Health Regulations (1978, 1980)

Regulatory oversight of water quality, domestic waste disposal, sanitary facilities, food safety and drainage

National Conservation Authority

National Conservation Authority Act (1999)

Establishment of an authority to manage public parks and beaches

Under the Water and Sewerage Act (No. 13 of 1999), WASCO is required to carry out Government policy in relation to water supply and sewerage, provide the public with a safe and reliable water supply, and provide dependable sewerage services. WASCO shall, as far as reasonably possible, provide the public with potable water for domestic purposes and satisfactory supplies for agricultural, industrial or commercial purposes. The Minister may make regulations for water conservation, prescribing water fittings to be used, forbidding the illegal reconnection or use of water fittings that are deemed unsuitable, prescribing the method of water storage on any premises, and the installation, operation and maintenance of a water supply system in a private development. WASCO is required to comply with directives, instructions, regulations and standards for water quality set by the Ministry responsible for public health. Persons authorized by WASCO may enter upon any land with such equipment as may be necessary, for the purposes of carrying out its functions, providing reasonable notice to the owner or occupier has been given. WASCO may enter any land and construct or operate (water or sewerage) works, providing reasonable notice to the owner or occupier has been given. A person whose property is affected has a right to compensation. The Act provides for the declaration of discharges or deposition of wastes onto land, sewer or drain, water or watercourse, and of wastes or classes of waste, as controlled water quality areas, or controlled wastes or classes of wastes respectively. This is to protect public health, established and intended uses of water resources, protection of flora and fauna, and scenic and environmental values. The Minister may take action to prevent polluting matter from entering water, or remove and dispose of polluting matter to remedy or mitigate any pollution. The legislation is currently being revised under the Water Sector Reform Project.

4.3. Public Health Legislation and Regulations The principal source of mandatory environmental standards for water and sewage works in St. Lucia is the Public Health Act (Act No.8 of 1975. Regulations made under this Act include Water Quality Control Regulations, Sewage and Disposal of Sewage etc (No. 24

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of 1978), Disposal of Offensive Matter (1976) and the Public Health (Nuisance) Regulations (1978). Generally, these legal instruments impose absolute prohibitions or qualitative restraints on activities, including the disposal of sewage and industrial effluents, that are intended to protect water supplies from contamination at source. Some applicable standards are imposed by the Public Health (Sewage and Disposal of Sewage and Industrial Waste Works) Regulations 1978, which prohibit the unauthorized disposal of any sewer fluid or liquid industrial effluent into any watercourse. The Regulations provide that authorization may only be granted if the quality and rate of dilution of the effluent prevents the creation of a nuisance or the effluent is treated to the satisfaction of the Public Health Board. The Regulations contain detailed specifications for the construction of sewage treatment plants, including septic tanks, Imhoff tanks, settling tanks, biological filters, package sewage treatment plants, oxidation ditches and ponds, and intermittent sand filters. As regards the allowable standards of biological oxygen demand (BOD), suspended solids and other chemicals in any effluent to be released into the environment. The Public Health (Water Quality Control) Regulations also address issues like the construction of water supply systems, construction and location of wells and penalties for infringement. As regards the inspection, repair or renewal of water and sewerage mains, however, the only relevant provisions appear in the Public Health (Nuisance) Regulations 1978, under which the matters designated as nuisances include any water supply system that is not maintained in a sanitary manner and any sanitary convenience not constructed and maintained according to law. The MOH issues licenses to hotels for occupancy, food, swimming pool, but not for sewage plant operations.

4.4. Employees (Occupational Health and Safety) Act No 10 of 1985 The Employees (Occupational Health and Safety) Act No 10 of 1985 sets standards for occupational health and safety in places of employment, and requires employers to, as far as practicable, maintain work conditions that are safe and without risk of injury to health, provide safe means of access and egress, ensure risks of injury or accident do not arise from the handling, storage, transport, use or disposal of dangerous substances, provide information, training, supervision, protective clothing and first aid facilities to ensure employee protection. Employees are required to take reasonable care, cooperate with the employer in carrying out the provisions of the Act, not tamper with safety devices, ensure that risks do not arise in the handling, storage, transport, use or disposal of dangerous substances, properly use and care or protective clothing, report defects which may cause accident or injury, and report accidents or injuries to his immediate supervisor. The Act provides for disposal of wastes and effluents, ventilation, drinking water, latrines and urinals, first aid appliances, medical examination, notification of accidents and dangerous occurrence, guarding of machinery, training and supervision of operators, toxic substances, work in

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confined spaces, personal protective equipment and protective tools, protection of eyes and precautions in case of fire.

4.5. International Treaties St. Lucia is party to fourteen environmentally relevant treaties or conventions. As presented in table 4.3, these deal variously with protection of resources, pollution management and abatement, endangered species protection, management of hazardous chemicals and protection of marine resources. Of particular interest are the treaties dealing with marine protection and management of natural resources. While the preferred alternative, strengthening the existing water infrastructure, is unaffected by these instruments, the proposal for the installation of a desalination plant will affect the coastal zone. Therefore, treaties relating to the protection of endangered species and protection of marine environments have particular relevance.

Table 4.3 International Environmental Treaties And Conventions

Ratified by St. Lucia

Subject Title Summary Information

Hazardous Wastes

Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and Their Disposal

Opened for signature - 22 March 1989 Entered into force - 5 May 1992

objective - to reduce trans-boundary movements of wastes subject to the Convention to a minimum consistent with the environmentally sound and efficient management of such wastes; to minimize the amount and toxicity of wastes generated and ensure their environmentally sound management as closely as possible to the source of generation; and to assist LDCs in environmentally sound management of the hazardous and other wastes they generate.

Biodiversity

Convention on Biological Diversity

Opened for signature - 5 June 1992 Entered into force - 29 December 1993

objective - to develop national strategies for the conservation and sustainable use of biological diversity.

Marine Life Conservation

Convention on Fishing and Conservation of Living Resources of the High Seas

Opened for signature - 29 April 1958 Entered into force - 20 March 1966

objective - to solve through international cooperation the problems

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Subject Title Summary Information

involved in the conservation of living resources of the high seas, considering that because of the development of modern technology some of these resources are in danger of being overexploited.

Endangered Species

Convention on the International Trade in Endangered Species of Wild Flora and Fauna (CITES)

Opened for signature - 3 March 1973 Entered into force - 1 July 1975 objective - to protect certain endangered species from overexploitation by means of a system of import/export permits.

Marine Dumping

Convention on the Prevention of Marine Pollution by Dumping Wastes and Other Matter (London Convention)

Opened for signature - 29 December 1972 Entered into force - 30 August 1975 objective - to control pollution of the sea by dumping and to encourage regional agreements supplementary to the Convention.

Environmental Modification

Convention on the Prohibition of Military or Any Other Hostile Use of Environmental Modification Techniques

Opened for signature - 10 December 1976 Entered into force - 5 October 1978 objective - to prohibit the military or other hostile use of environmental modification techniques in order to further world peace and trust among nations.

Whaling

International Convention for the Regulation of Whaling

Opened for signature - 2 December 1946 Entered into force - 10 November 1948 objective - to protect all species of whales from over-hunting; to establish a system of international regulation for the whale fisheries to ensure proper conservation and development of whale stocks; and to safeguard for future generations the great natural resources represented by whale stocks.

Climate Change-Kyoto Protocol

Kyoto Protocol to the United Nations Framework Convention on Climate Change

Opened for signature - 16 March 1998, but not yet in force objective - to further reduce greenhouse gas emissions by enhancing the national programs of developed countries aimed at this goal and by establishing percentage reduction targets for the developed countries.

Ozone Layer Protection

Montreal Protocol on Substances That Deplete the Ozone Layer

Opened for signature - 16 September 1987 Entered into force - 1 January 1989 objective - to protect the ozone layer by controlling emissions of substances that deplete it.

Ship Pollution

Protocol of 1978 Relating to the International Convention for the Prevention of Pollution From Ships, 1973 (MARPOL)

Opened for signature - 17 February 1978 Entered into force - 2 October 1983 objective - to preserve the marine environment through the complete elimination of pollution by oil and other harmful substances and the minimization of accidental discharge of such substances.

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Subject Title Summary Information

Law of the Sea

United Nations Convention on the Law of the Sea (LOS)

Opened for signature - 10 December 1982 Entered into force - 16 November 1994 objective - to set up a comprehensive new legal regime for the sea and oceans; to include rules concerning environmental standards as well as enforcement provisions dealing with pollution of the marine environment.

Desertification

United Nations Convention to Combat Desertification in Those Countries Experiencing Serious Drought and/or Desertification, Particularly in Africa

Opened for signature - 14 October 1994 Entered into force - 26 December 1996 objective - to combat desertification and mitigate the effects of drought through national action programs that incorporate long-term strategies supported by international cooperation and partnership arrangements.

Climate Change United Nations Framework Convention on Climate Change

Opened for signature - 9 May 1992 Entered into force - 21 March 1994 objective - to achieve stabilization of greenhouse gas concentrations in the atmosphere at a low enough level to prevent dangerous anthropogenic interference with the climate system.

5. DESCRIPTION OF ENVIRONMENT

5.1. Physical

5.1.1. General St. Lucia has an area of approximately 616 square kilometers, making it one of the largest islands in the Organization of East Caribbean States (OEC’S). The island lies between latitude 130 43’N and 140 07’N and longitude 600 53’W to 610 05’W and is approximately 43 km long by 22 km wide. The Atlantic Ocean washes the windward or eastern coast and the Caribbean Sea, the leeward or western coast of the island. Therefore, many of the sheltered bays and bathing beaches lie on the western coast of the island. The northwestern coast of the island, has been developed for tourism, light industry and housing. The island’s principal recreational beaches and yacht harbor are located along Rodney bay.

5.1.2. Topography The topography of the island could be described as mountainous. It has a central mountain ridge, known as the Barre de L'lsle, running parallel to the West Coast rising to a maximum elevation of 950 m at Mt. Gimie. All of the other mountain ridges rise to elevations below 400m.

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Many rivers and streams cut the mountain ridges forming steep sided gullies and narrow valleys. Over half the island has slopes greater than 200 and more than 70% of the island has slopes over 10°. The island could be divided into 37 main watersheds. One such watershed in the upper reaches of the Roseau valley has been dammed to form the John Compton Dam and impounding reservoir that feeds the Theobalds Water Treatment Plant. This forms the largest water supply system on the island. The slopes created by mountain rises are steep and cuts are often unstable. When exposed these slopes are susceptible to landslide. On the coast, the rivers flow into narrow alluvial flood plains often forming small alluvial deltas.

5.1.3. Climate St. Lucia enjoys a tropical climate with little annual or diurnal variation in temperature. Maximum daily temperatures ranges between 30 to 33 C with minimums ranging between 16 to 21 C. Rainfall distribution across the island varies considerably. The total annual rainfall is approximately 1,200 mm at the northern and southern ends of the island, the dry regions. Higher amounts are realized in the central mountains owing to orographic effect and reaches up to 3,500 mm near Mt. Gimie. Although the distribution of rainfall across the island is variable, the pattern of rainfall across the island is the same. There is a dry season that runs from January to June and a wet season from June to December. The island is vulnerable to hurricanes and the hurricane season runs from June to November.

5.1.4. Geology Almost all of St. Lucia is composed of volcanic rocks of Tertiary to Quaternary age. Radiocarbon dating gives the last volcanic eruptive phase at some 30,000 to 40,000 years ago although, at present, there are signs of volcanic activity at the sulphur springs at Soufriere on the West Coast. The oldest rocks are found mainly in the region north of an imaginary line joining the Cul de Sac Valley to Grand Anse Bay. A central series of younger rocks forms the main mountain mass with a third younger series in the south and southwest centered on 8 Soufriere. In the south, around Vieux Fort, the rocks are older, and comparable to the northern series. The rocks of the northern series, north of the Barre de L'isle systern, are mainly basaltic and comprise lava flows, agglomerates and mudflows. Andesites also occur in this area. Agglomerates formed by explosive eruption of volcanoes and consisting of a mixture of boulders, cobbles and ash are also found in the northern area. Where there are no gravelsized particles, the deposit is an ash. If the ash is consolidated, a luff is formed. Tuffs are not widespread in the northern part of the Island.

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Mudflows are found resembling agglomerates, but consisting of boulders in a matrix. These boulders are sometimes large. The central area, corresponding to the Barre de L’lsle land system contains hard columnar andesites. Towards the East Coast, the rock consists mainly of andesitic agglomerates and ashes and are similar to those found in Anse La Raye on the West Coast. At the southern border of the central series, basaltic rocks occur in the Mt. Gimie and Piton St. Esprit systems. Andesitic agglomerates are also found north of Soufriere but, also occur further south. To the south and east of Soufriere the main deposit is a pumice flow, consisting of a loose light-colored porous sandy deposit. Regarding earthquakes, the island lies on the western margin of the Caribbean tectonic plate and is seismically active. Earthquakes occur with regularity but seldom reach magnitudes sufficient to produce damage.

5.2. BIOLOGICAL

5.2.1. Environmental Features Variations in altitude, rainfall and soil characteristics have contributed to the wide variety of vegetation cover of St. Lucia that ranges from tropical wet forest, tropical dry forest; tropical moist forest, sub-tropical moist forest to sub-tropical rain forest and wetlands. Approximately 43% of the island’s coverage falls under the category of tropical wet forest. It is estimated that the rate of deforestation is approximately 1.9% per annum. By 1988 St. Lucia had lost up to 40% of its wetlands through reclamation and other forms of physical land transformation.

5.2.2. Habitats The variation in vegetation cover is matched by great heterogeneity of habitats and ecosystems. In the coastal zone areas, the ecosystems comprise mangroves, sea grass beds, coral reefs and sandy beaches. According to Devaux, Rj., 3 in the terrestrial environment, the diversity continues with wetlands; varying vegetation zones; riverine ecosystems and ecosystems created by micro-climatic, edaphic and other factors in valleys, canyons and on mountains. The northern end of the island supports a dry forest ecology composed of acacia and related species. Of particular note is the plight of the endangered Jacquot (St. Lucia Parrot) which has its habitat in the mountainous tropical wet forest areas. The John Compton Dam was built within the natural habitat of Jacquot. As part of the environmental mitigation measures for that project, a plan was successfully put in place for the protection of this natural

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treasure of St. Lucia. There is no evidence to suggest that the construction of the dam significantly affected the population of the bird.

5.2.3. Protected areas St. Lucia has designated a number of sites across the island as protected areas. These protected areas have been put under special management status to ensure that the resources they contain are maintained and made accessible for sustainable uses compatible with conservation requirements. The first protected area in St. Lucia dates back to 1916 when the Castries Waterworks Reserve was set up. This reserve now forms part of the St. Lucia Forest Reserve. Since that time, Other protected areas comprising archaeological and historic sites; and marine, nature and forest reserves have been established. A full listing together with annotated maps of St. Lucia", protected areas can be found in the publication ’A System of Protected Areas for St. Lucia’ put out by the SLNT in 1992. Pigeon Island, located on the western north coast is the site of a colonial fort and enjoys national park status as a cultural historic site.

5.2.4. Endangered Species Eight internationally recognized endangered species are noted for St. Lucia under the Convention for Trade in Endangered Species CITES. Aside from the St. Lucian parrot and the Peregrine Falcon, the remaining extant species, presented in table 5.0, are reptiles. Notably the majority are marine turtles with their attendant critical habitat requirements. These include feeding grounds, nesting beaches, and other requirements relating directly to marine water quality.

Note: 1. Annexes I, II and III list the species covered by the Convention and may be amended pursuant to Articles XV (Appendices I and II) and XVI (Appendix III). a). Appendix I includes all species threatened with extinction which are or may be affected by trade. Trade in specimens of these species must be subject to particularly strict regulation in order not to endanger further their survival and must only be authorized in exceptional circumstances.

Table 5.0 St. Lucia Appendix 1

CITES Endangered Species

Group Scientific Name Common Name Caretta caretta Loggerhead Turtle Chelonian mydas Green Turtle Eretmochelys imbricata Hawksbill Turtle Dermochelys coriacea Leatherback Turtle

Reptiles

Boa constrictor Boa Constrictor Mammals Megaptera novaeangliae Humpback Whale

Amazonia versicolor

St. Lucian Parrot Birds

Falco peregrinus Peregrine Falcon

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5.2.5. IUCN Red List In addition to the species listed under CITES, the IUCN* (the World Conservation Union), maintains a separate list of species it deems endangered, threatened or of special concern. While the listing carries no regulatory or legal force it is the result of a rigorous application of scientific criteria and peer review and compliments the CITES listing by considering those species not necessarily threatened by trade or commerce. The criteria for listing are presented in appendix I. In St. Lucia and its adjacent marine environment, there are 27 species listed as vulnerable or endangered including birds, mammals, reptiles, fish and plants. Presented in table 5.1, the majority of the species are listed due to the general decline in populations as a result of habitat loss and changes in habitat quality. These are largely due to human interactions through development and economic pressures. Over half of those species listed are marine wildlife largely dependent on nearshore and reef environments. Of particular interest is the White-Breasted Thrasher, Ramphocinclus brachyurus. By IUCN criteria this species is considered endangered and depends on the dry forest habitats found on the island. The northern portion of St. Lucia supports this species however development is threatening this habitat. Presently, land planning efforts have done little to assist in managing the remaining habitats in this portion of the island *(Formerly International Union for Conservation of Nature and Natural Resources (IUCN))

Table 5.1 St. Lucia IUCN Redlist of Species of Concern

Group Scientific Name Common Name(s) Red List Status

Amazona versicolor

SAINT LUCIA AMAZON (E) SAINT LUCIA PARROT (E) ST LUCIA AMAZON (E) ST LUCIA PARROT (E)

VULNERABLE

Cichlherminia lherminieri

FOREST THRUSH (E)

VULNERABLE

Leucopeza semperi

SEMPER’S WARBLER (E)

CRITICALLY ENDANGERED

Melanospiza richardsoni

ST LUCIA BLACK FINCH (E)

ENDANGERED

BIRDS

Ramphocinclus brachyurus

WHITE-BREASTED THRASHER (E)

ENDANGERED

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Group Scientific Name Common Name(s) Red List Status

Megalomys luciae

SANTA LUCIA GIANT RICE RAT (E)

EXTINCT

MAMMALS

Megalomys luciae

BUNCH (E) HUMP WHALE (E) HUMPBACK WHALE (E) HUNCHBACKED WHALE (E)

VULNERABLE

Scarus guacamaia

RAINBOW PARROTFISH (E)

ENDANGERED

Epinephelus striatus

NASSAU GROUPER (E) CHERNA CRIOLLA (S)

VULNERABLE

Balistes vetula

QUEEN TRIGGERFISH (E)

VULNERABLE

Carcharodon carcharias

GREAT WHITE SHARK (E)

VULNERABLE

Lachnolaimus maximus

HOGFISH (E)

VULNERABLE

Lutjanus analis

MUTTON SNAPPER (E)

VULNERABLE

Lutjanus cyanopterus

CUBERA SNAPPER (E)

VULNERABLE

Dermatolepis inermis

MARBLED GROUPER (E)

CRITICALLY ENDANGERED

FISH

Epinephelus itajara

GOLIATH GROUPER (E) JEWFISH (E)

CRITICALLY ENDANGERED

Dermochelys coriacea

LEATHERBACK (E) LEATHERY TURTLE (E) LUTH (E)

CRITICALLY

Eretmochelys imbricata

HAWKSBILL TURTLE (E)

ENDANGERED

Caretta caretta

LOGGERHEAD (E)

ENDANGERED

REPTILES Chelonia mydas

GREEN TURTLE (E)

ENDANGERED

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Group Scientific Name Common Name(s) Red List Status

Liophis ornatus

ST LUCIA RACER (E)

VULNERABLE

Cnemidophorus vanzoi ST LUCIA WHIPTAIL (E)

VULNERABLE

Juniperus barbadensis

No common name ENDANGERED

Pouteria pallida

No common name VULNERABLE

Pouteria semecarpifolia

No common name ENDANGERED

Swietenia mahagoni

AMERICAN MAHOGANY (E)CUBAN MAHOGANY (E) SMALL-LEAVED MAHOGANY (E) WEST INDIAN MAHOGANY (E)

VULNERABLE

PLANTS

Cedrela odorata

CIGAR-BOX WOOD (E) RED CEDAR (E) SPANISH CEDAR (E)

**EXTINCT (EX) - A taxon is Extinct when there is no reasonable doubt that the last individual has died. CRITICALLY ENDANGERED (CR) - A taxon is Critically Endangered when it is facing an extremely high risk of extinction in the wild in the immediate future, as defined by any of the criteria (A to E) as described Appendix I. ENDANGERED (EN) - A taxon is Endangered when it is not Critically Endangered but is facing a very high risk of extinction in the wild in the near future, as defined by any of the criteria (A to E) as described Appendix I. VULNERABLE (VU) - A taxon is Vulnerable when it is not Critically Endangered or Endangered but is facing a high risk of extinction in the wild in the medium-term future, as defined by any of the criteria (A to E) as described in Appendix I.

5.3. Socioeconomic The Government Statistics Department estimates the current population at 156,260 with a growth rate at 1.21% per annum. The capital city, Castries, with a population density of 710 persons per sq. km is the most densely populated area in St. Lucia. Other areas of high to moderately high population densities include Vieux Fort in the south of the island and Gros Islet to the northwest. The Gros Islet area the area of highest tourism infrastructure.

5.3.1. Economic Conditions Notwithstanding its small land area, exacerbated by its rugged terrain; its small population; and limited natural resource base; St. Lucia’s economy could be regarded as having performed well over the last two decades fueled by activity in the agricultural and tourism sectors.

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The country’s fertile volcanic soils have provided the resource base for a vibrant agricultural sector. This sector, which is dominated by banana production, has, between 1995 to 1999, contributed an annual average of 8.5% of GDP. However a combination of:

• Recent changes in the European Union’s import preference regime and increased competition from Latin American bananas

• Unfavourable weather conditions

• Efforts by GOSL for crop diversification

have contributed to a steady decline in banana output and farmers leaving the industry. The island’s natural beauty and long expanses of white sandy beaches, has been exploited in support of tourism. The tourism sector (as measured by the hotel and restaurant sub-sector) has. between 1995 to 1999. contributed an average of 18.5% of GDP. Total visitor arrivals continue to grow at an average rate of 3.5% per annum. In 1999, St. Lucia recorded a modest rate of inflation of 3.5%, the highest for the period 1996 to 1999. In keeping with worldwide trends, the country could be expected to maintain low rates of inflation in the short to medium term. Its average exchange rate which is set by the Eastern Caribbean Central Bank and has been fixed since 1976, is pegged at EC$2.7 per US$. On the whole, economic growth in St Lucia has been relatively slow in the period since 1995 (see Figure 5.1 below). GDP has grown at approximately 2.5 per cent per annum in real terms, with the exception of the period 2000-01 where growth was zero or negative. This compares with the 1980s when GDP growth was much higher at around 7 per cent per annum.

Figure 5.1 Real GDP growth, St Lucia, 1993-2003

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-6

-4

-2

0

2

4

6

1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

GD

Pg

row

th(p

erce

nt)

Source: IMF Statistics and World Bank, World Development Indicators

This level of economic growth has not been enough to significantly reduce unemployment, which has remained at around 15-20 per cent, while per capita income has grown by a total of approximately 11 per cent in total in real terms since 1995 (see Figure 5.2 below).

Figure 5.2 Per capita income and unemployment

St Lucia, 1993-2002

0

5

10

15

20

25

1993199419951996199719981999200020012002

Unem

ploy

men

trat

e(p

erce

nt)

0

2000

4000

6000

8000

10000

12000

GNI

perc

apita

(EC

dolla

rs)

Unemployment

GNP per capita

Source: St Lucia Statistics Department

5.3.2. Factors influencing income distribution Figure 5.3 shows the level of unemployment in St Lucia since 1996. Over this period unemployment has fluctuated roughly between 15-20 per cent. In 2001, the last year for which figures are available, unemployment was marginally greater than in 1995.

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Income distribution may also be affected by the level of growth in individual industrial sectors that are important employers for low income households. Perhaps the most significant structural shift in the economy since 1996 has been the decline in banana production as favorable market access conditions for banana exports have been removed. The total number of banana farmers has declined from 13,000 at the time of the 1996 Poverty Assessment Report to less than 3,000 today. This change has been reflected in the declining contribution of agriculture to GDP, which was around 11 per cent in 1995 falling to around 6 per cent in 2002. The decline in banana production and the number of banana farmers might have been expected to contribute to an increase in poverty since 1996. However, this is not necessarily the case. First, there were a significant number of marginal banana producers already living in poverty prior to the structural adjustment that has been observed in the industry. Second, whether poverty has increased will depend on whether the former banana producers have been able to find employment elsewhere in the economy, or whether there has been sufficient growth in other economic sectors to offset the decline in banana farming. At a macro-level, the unemployment figures would seem to indicate that the decline in banana farming has not shown up as a long term increase in the unemployment rate. Labor force participation has also been constant at around 69 per cent over the period 1997-2000 (indicating that former banana farmers have not left the labor force to become unemployed). Also, the total level of employment over 1997-2000 increased from 56,000 persons to 64,000 persons in 2000. It seems likely that growth in tourism prior to 2000 largely offset the impact of the decline in banana farming and minimized any impact from this structural shift in the distribution of income in St Lucia. Since 2000, there has been a slow down in the tourist trade, particularly since the events of 2001. This may have had some impact on low income households to the extent that hotels and other tourism related employers have had to reduce staff numbers. No quantitative data is available at this stage to assess this impact.

5.3.3. Average income by district Much of the commercial and tourism development is focused in the north of the island and, as a result, the administrative districts located in the northern region of the island might be expected to have significantly higher levels of income. This is generally true, with average income in Gros Islet (EC$3,069 per month) and Castries Suburban (EC$2,559 per month) significantly above the national average of EC$1,695 per month. That said, average monthly incomes in the remaining two administrative districts in the northern region (Castries City and Castries Rural), while significantly above the national average, are broadly similar to those in Viuex Fort, in the south of the island.

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Table 5.2 shows average monthly income in each of St Lucia’s administrative districts and incorporates a map showing the location of each of these administrative districts (as well as population distribution on the island).

5.3.4. Access to water supply services Based on 2001 census data, 86 per cent of households in St Lucia report that their primary source of water (table 5.3) is supplied by WASCO through either a house connection, yard tap or standpipe. This figure may be closer to 90 per cent when illegal connections are taken into account. This is a significant increase compared to 1991 when around 80 per cent of households (including an allowance for illegal connections) reported that their primary water supply was from WASCO. In terms of absolute numbers, the number of households where WASCO is the primary water supplier (according to census data and without any allowance for illegal connections) increased from approximately 25,000 in 1991 to around 36,000 in 2001, an increase of around 11,000 households. There has also been a significant increase in the number of households with house connections or yard taps and a corresponding decline in the number of households served by standpipes. Between 1991 and 2001, the number of in-house or yard tap connections increased by approximately 17,000, while the number of households served by standpipes declined from around 9,000 (28 per cent of all households) to around 3,500 (8.5 per cent of all households). Based on data from WASCO’s customer database, estimates are that by end-2003 this figure had dropped to 3,000 (about 6 per cent of all households).

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Table 5.2

Average Monthly Household Income By District (East Caribbean dollars per month)

District Number of

householdsAverage income (EC$ per month)

Gros Islet 5,794 3,069 Castries Suburban

7,659 2,559

Castries City 3,009 2,116 Castries Rural 6,389 2,013 Vieux Fort 4,159 1,974 Soufriere 1,827 1,763 Micoud 4,461 1,716 Laborie 1,971 1,680 Anse La Raye 1,733 1,556 Canaries 537 1,553 Choiseul 1,674 1,510 Dennery 3,485 1,501 National average

1,695

Source: St Lucia Population and Housing Census, 2001; St Lucia map courtesy of St Lucia Statistics Department

A number of factors have contributed to the significant increase (between 1991 to 2001) in the number of households being served by WASCO, particularly through house connections or yard taps. One factor has been the decline in private water systems. Apparently a number of private water systems, perhaps related to the operation of various banana plantations, were transferred to WASCO management over this period. Other factors contributing to the increase in yard tap or house connections over this period include:

• Free connections policy instituted for a limited period following WASA’s conversion to WASCO in 1999

• Investments in network infrastructure initiated and partly financed by PRF and

BNTF over this period;

• Network investment initiated by WASCO on its own over this period; and government policy to eliminate standpipes.

Table 5.3

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Sources of Water Supply, St Lucia

1991 2001 Number Proportion

(%) Number Proportion

(%) Private piped into dwelling

5351 16.2 1001 2.4

Private catchment not piped

697 2.1 491 1.2

Private catchment piped 245 0.6 Public piped into dwelling

10444 31.6 24221 58.4

Public piped into yard 4917 14.9 8070 19.5 Public standpipe 9361 28.3 3517 8.5 Public well or tank 226 0.7 138 0.3 Other 2083 6.3 2909 7.0 Not stated 889 2.1 Total 33079 100.0 41481 100.0 Source: Government of St Lucia, Ministry of Social Transformation, Culture and Local Government, Interim Poverty Reduction Strategy and Action Plan for St Lucia, 2003 drawing on Population and Housing Census, 1991 and Preliminary Population and Housing Census, 2001.

The ‘other’ category identified in table 5.3 is likely to include households that collect and store rainwater, self abstract from rivers, and may also include households obtaining water from relatives or neighbors with WASCO connections. WASCO considers that a large number of respondents in this category are also likely to have illegal connections. In the period since 2001, a review of WASCO customer records indicated that the trends have continued. In particular, the number of households depending on standpipes has declined from 3,500 in 2001 to an estimated 3,000 in 2003. The number of households directly connected to the WASCO network has also continued to increase. Table 5.4 provides details of settlements in St Lucia with more than 50 households reporting non-WASCO or ‘other’ water supply sources as their primary water supplier in the 2001 census. In 2001, 18 communities in St Lucia had more than 50 households that reported their primary source of water supply was either a private system, public tank or well, or ‘other’ water supply source. Half of the 18 communities are located in the Castries district. Six of the 18 communities (Ciceron, Morne Du Don, Victoria Street, Downing Street, Clark Street, Waterworks) are in predominantly urban areas. For these communities, the large number of ‘other’ water supplies may indicate a concentration of illegal connections

Table 5.4 Settlements in St Lucia with more than 50 households reporting non-WASCO or

‘other’ water supply sources

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Settlement Households reporting non-WASCO water

supplies Total Private

supply, public tank, well

‘Other’ Number Proportion of

households

Castries - Bexon/Ravine Poisson

86 274 360 19%

Gros-Islet - Monchy/Vieux-Sucr 96 119 215 24% Castries – Babonneau/Fond Assau

76 123 199 15%

Castries - La Croix Maingot/Ba 70 42 112 28% Castries – Forestiere 41 61 102 57% Castries - Ciceron/Millenium 8 89 97 10% Castries - Morne Du Don 26 55 81 8% Vieux-Fort – Augier 27 49 76 12% Vieux-Fort – La Resource 7 67 74 17% Dennery - Village/Victoria Street

11 53 64 7%

Micoud - Village/Downing Street

8 55 63 9%

Castries - Cul De Sac/Ferrand 16 44 60 32% Anse-La-Raye – Jacmel 8 51 59 33% Micoud - Pierrot/Tet Morne 6 53 59 30% Castries – Marigot 33 23 56 31% Vieux-Fort - Town/Clark Street 8 48 56 8% Castries – Waterworks 54 1 55 41% Dennery - Au Leon 12 39 51 12% Source: Statistics Department, Population and Housing Census data, 2001

5.3.5. Water expenditure by low income households The amount that each household spends on water is determined by their volume of water consumption (if they are metered) or the number of household occupants (if they are un-metered). A lack of relevant survey data means that it is not possible to generalize as to whether low income households are metered or un-metered or, if metered, the volume of their consumption. As a result a number of different billing scenarios for low income households have been considered. The three billing scenarios examined, presented in table 5.5 are that: the household water bill paid by a low income household is at the average level for the district; the household water bill paid by a low income household is the minimum bill for a metered customer (i.e. EC$14.70 per month); and the household

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water bill paid by a low income household is the minimum bill for an un-metered customer with five household occupants (i.e. EC$37.05 per month).

Table 5.5 Water expenditure as proportion of household

expenditure for low income households

District

Scenario 1 Average water

billa

(% of household income)

Scenario 2 Minimum water bill for a metered

household

(% of household income)

Scenario 3 Water bill for 5

person, unmetered household

(% of household income)

Anse La Raye

3.7-4.8% 1.6-2.1% 4.1-5.3%

Canaries 3.9-5.1% 2.0-2.6% 5.1-6.6% Castries 2.8-3.7% 1.3-1.7% 3.3-4.3% Choiseul 4.4-5.7% 2.5-3.2% 6.2-8.1% Dennery 3.0-3.9% 1.9-2.5% 4.8-6.3%

Gros Islet 3.8-5.0% 1.5-1.9% 3.7-4.8% Laborie 4.2-5.4% 2.1-2.7% 5.3-6.8% Micoud 3.4-4.4% 1.9-2.5% 4.8-6.3%

Soufriere 2.3-3.0% 1.3-1.7% 3.3-4.3% Vieux Fort 3.7-4.8% 1.6-2.1% 4.0-5.2% National Average

3.4-4.4% 1.6-2.1% 4.0-5.2%

a Average household water bill for each the administrative districts was calculated using WASCO’s billing records.

6. ANALYSIS OF IMPACTS AND MITIGATION

6.1. Summary Overview The urgent need to improve the availability of good quality drinking water in the northern section of St. Lucia is obvious. Current inadequacies of the distribution system coupled with the demands for growth in the region are placing increasing pressure on the distribution system. The ability to service all population segments is a priority with the greatest benefit going to low income families. At risk groups include children under 5 and the elderly. These groups will realize a greater proportional benefit from improved access to public water supplies. The impacts associated with both alternatives differ

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widely given the technologies involved and the users served by the two options. Both options will result in induced development in the extreme northern service area (Rodney Bay, Grose Islet) as pent-up development demand is currently frustrated due to lack of water. Numerous communities have been designed and laid-out with supporting infrastructure but are not developing due to poor land sales. There are also plans for the construction of no less than 4 new hotel complexes in the region. Generally, impacts associated with the first alternative – Capacity improvement, are related to construction activities at the work site. Only those portions of the project involving the construction of new pipelines will affect the community at large as these works will require access to private lands. Those works to occur in public roadways present additional but manageable impacts. The greatest positive impact associated with this option is that it improves the ability to provide a reliable supply of potable water throughout the Theobolds WTP service area and reaches into low income communities where service is poor or non-existent. These are the groups least able to afford developing alternative sources to public water supply. While this option will result in the continued development of the extreme northern service area, the infrastructure and current supply are adequate to meet the current and anticipated future demand. The second option, the Desal-plant, provides water only to a specific section of the Theobolds WTP area. While it would relieve the system of short term demands emanating from that area, it would not permit the other improvements necessary to reliably supply water throughout the Theobolds WTP service area. Aside from the greatly increased costs of water production, the desal option contains a variety of other environmental consequences. These include for example, aesthetic issues, management of seawater intake and brine discharge, chemical pollutants, ecological and marine habitat concerns, issues associated with endangered species and increased energy demands. Furthermore, it is clear, given the pressure for growth in the plants service region, that the demand on the system will quickly increase as new construction begins again in the belief that water is readily available. Finally, the service area for the desal plant represents one of the highest income areas of the island where the average household income is nearly double the national average. This indicates that the direct benefits of this option will not be distributed among the middle to lower income brackets more prevalent in the greater northern service area. The additional cost associated with the production of desalinated water would not be borne by the local service area but would necessarily be folded into the general cost of WASCO water production. Paying for this additional cost would have to be distributed across the entire population through the entire system. Absent a special use fee for the service area, the result is a form of water subsidy for the most affluent portion of the country. Of the two options, option 1, Capacity upgrade, produces the greatest long-term benefit for the entire service area and addresses the total water demand over the next 10 – 15 years. The capacity upgrades clearly meet the long term growth requirements of the

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northern section with greater reliability, lower cost, and fewer significant direct environmental impacts than the desal option. Neither alternative has constructions planned in an area suspected of containing undiscovered artifacts or areas of cultural-historical significance.

6.2. Alternative 1 – Improve Capacity of Existing System (Capacity Improvement)

Under this alternative, impacts are considered for the following four capacity improvement program components:

• John Compton Dam Pumping Upgrade

• Removal of Vanard-Sarot Bottleneck

• Expansion of the Theobalds Water Treatment Plant (WTP)

• Upgrade of Morne-Bocage Distribution Line

Negative impacts are generally restricted directly to the construction sites and are limited to the construction phase of the program. At the John Compton dam, works involve the replacement of existing equipment and require no additional intervention in the area beyond the existing facility. These are basically maintenance upgrades and involve the removal and installation of pipes and machinery. While the entire program will result in the increase availability of raw water to the system, the upgrades are within the water sector development initiative plans and well within the planned parameters of the long term design capacity of the reservoir. For this reason, further environmental analysis of equipment upgrades is not necessary. The remaining three components are discussed in the following.

6.2.1. Removal of Vanard-Sarot Bottleneck This element involves two components. The installation of 1300 m of 24 inch pipe and the replacement of joint restraints on existing lines. The replacement of restraints is a maintenance function with no significant impacts associated with the process. The result is wholly beneficial to the system as it improves the survivability of pipe connections when exposed to flood or earthquake forces.

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The installation of 1300 meters of 24 inch pipe does have significant negative environmental consequences associated with the works. These however are reversible and limited to the construction phase. Impacts expected from the pipe installation include:

• Temporary loss of crops and use of agricultural land at the construction site

• Potential for soil erosion

• Worker sanitation management

• Interdiction of public roadways

• Possible contamination of work sites with fuels and hazardous materials.

• Pollution from construction wastes

• Noise from construction activities

• Dust control issues

• Discovery of cultural-historical antiquities

• Standing water and disease vector production

As the works are planned, no permanent modification to the landscape is expected and no natural areas will be intervened during the project. Finally, the routing of the new pipeline was chosen so that no persons or structures will require relocation.

6.2.2. Expansion of the Theobalds Water Treatment Plant (WTP) The Theobalds WTP was originally designed to accommodate two treatment units and a sludge dewatering tank. During the first phase of construction, space was set aside for the location of the sister unit within the WTP property. Land has already been prepared for the construction. As the entire system was originally designed to achieve the treatment throughput the additional unit will provide, there is no additional design demand being placed on the raw water supply. With this addition, the system will be brought up to 100% operational performance in accordance with original designs. Environmental impacts are limited to those associated with construction and include:

• Worker sanitation

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• Disposal of construction wastes

• Use and storage of fuels during construction

• Management of hazardous materials and hazardous wastes during construction

• Site management and erosion control.

• Noise from construction activities

• Dust control issues

The area is fenced and self contained. A positive direct impact of the project element is the elimination of the practice of discharging backwash water directly to a stream off property. With the additional facilities, provisions will be made for sludge drying and disposal will be managed using the local landfill. Of course, the major positive social benefit is the contribution of this element to the overall strategy for doubling the volume of available treatment capacity for improved service and distribution. As part of the long term strategy, this upgrade will meet the forecast demands into the year 2015.

6.2.3. Upgrade of Morne-Bocage Distribution Line This component will provide for the installation of :

• New Ciceron Pump Station at Theobalds WTP

• New dedicated 12” Pumping Main

• New 200,000 Imperial Gallon (Igal) tank at Morne Fortune

• New 12” gravity main, 4900m

• New 100,000 Imperial gallon (Igal) tank at Babonneau The Ciceron pump station is to be located in the same area as the existing pump station at the Theobalds WTP. It is essentially a rehabilitation fo the exsting facility. The remaining works will have the same basic impacts as envisioned for the installation of the Vanard – Sarot line. Negative impacts are generally limited to the construction phase and include:

• Potential for soil erosion

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• Worker sanitation management

• Interdiction of public roadways

• Possible contamination of work sites with fuels and hazardous materials.

• Pollution form construction wastes

• Noise from construction activities

• Dust control issues

• Discovery of cultural-historical antiquities

• Standing water and disease vector production

Sites chosen for tank installation are already occupied by older, smaller tanks therefore no new land will be required for those constructions. Pipes, as with Vanard – Sarot will follow existing roadway alignments. The principal impact associated with this is the possible interdiction of access through the affected communities. This is particularly important as essential services could be disrupted.

6.2.4. Summary of Impacts Taken together, the suite of projects are socially important and beneficial. The improvements in distribution and treatment supply provide benefits across the social spectrum in the service area. These works will:

• Improve health and welfare for the service region through improved potable water supply

• Reduce the need for the purchase of expensive bottled water particularly

beneficial to lower income groups.

• Differentially benefit populations at risk from water borne disease such as the elderly and children under 5

• Assist with reducing the overall reliance private storage tanks (which are beyond

the economic reach of low income groups)

• Improve the quality of treated water through improved treatment capacity

• Add distribution capacity to those currently not on the public water system Negative impacts are largely related to the construction phase and include:

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• Potential for soil erosion

• Worker sanitation management

• Interdiction of public roadways

• Possible contamination of work sites with fuels and hazardous materials.

• Pollution form construction wastes

• Noise from construction activities

• Dust control issues

• Discovery of cultural-historical antiquities

• Standing water and disease vector production

A lingering issue is the anticipated growth for the Grose Islet – Rodney Bay service area. There is no doubt that once water becomes reliably available that pent-up development demand will become unrestrained. While not an issue in terms of WASCO functions, this development will greatly alter the landscape impacting other public services and the remaining dry forest habitats of the area. This issue goes beyond the scope of WASCO’s programs and will require pro active involvement on the part of the Ministry of Planning to manage in a balanced manner.

6.2.5. Mitigation Measures The mitigation of direct impacts associated with the capacity expansion option are relatively simple and straightforward. The direct impacts are related to construction, compensation, and short-term impediments to transportation. These are managed by:

• Improved communication with the public

• Strong planning and coordination with emergency services and Ministry of Works

• Site management plans

• Enforcement and inspection through contract vehicles

Specific mitigations are outlined in table 6.0 and pertain to the construction phase of the works contemplated. To implement these requirements, a series of draft

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contract clauses have been developed and are presented in Appendix II. The use of these clauses is presented in the following section, Environmental Management Plan.

Impact Mitigation

Potential for soil erosion

Stabilize banks of excavations, erect erosion control barriers where necessary, cover removed soil and re-vegetate excavations when work is complete

Worker sanitation management

Provide sanitary facilities at the construction site or make arrangements for the use of existing sanitary facilities

Interdiction of public roadways

Informed the public through press releases and community meetings of planned works, coordinate with emergency services to assure no loss in community coverage, Coordinate with Min. Works to re-surface roads in a timely fashion, Plan works in order to minimize blockages and to facilitate traffic flows in general and around local traffic patterns

Possible contamination of work sites with fuels and hazardous materials.

Control or limit the use of hazardous materials substituting materials with less hazardous products, Provide for the safe storage and use of hazardous materials through protected storage and worker training, Provide for the safe disposal of used hazardous materials in accordance with St. Lucian law. Use existing commercial fueling stations, Provide for the secure storage of fuel supplies in the field, locate fueling areas away from environmentally sensitive areas such as water courses, Provide for spill control and prevention as part of the overall fuel management program, dispose of waste fuels and containers in accordance with St. Lucian law

Pollution form construction wastes

Minimize waste through judicious construction management practices, collect and dispose of construction waste through the St. Lucian waste management system, provide for the collection and management of worker generated waste (trash cans at work sites)

Noise from construction activities

Manage noise by conduction construction activities during normal working hours, alert the community when the construction is to take place, assure machinery used in construction is properly

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Impact Mitigation equipped with working muffler systems.

Dust control issues Prohibit the use of oils on roads for dust control, wet roads with water where necessary using water supplied from approved sources

Temporary loss of crops and use of agricultural land at the construction site

Identify lands where crops will be removed for construction and negotiate with farmers and pay appropriate compensation

Discovery of cultural-historical antiquities

Stop work, notify appropriate authorities to evaluate the site

Standing water and disease vector production

Prohibit the long-term accumulation of standing water suitable for mosquito reproduction

For the indirect impact – Induced Development, the solution is beyond the capabilities of WASCO and falls within the domain of the Ministry of Planning. The issue gets to the heart of the balance between economy, development, and preservation. For the present, institutional strengthening of the Ministry of Planning has produced a building code and resulted in improved planning capacity within the ministry. However, the agency is still unable to effectively manage regional development. Measures are recommended to improve the planning and enforcement of planning requirements within this ministry to help develop a coherent development strategy for the northern service area in particular.

6.3. Alternative 2 – Installation of a Mobile Desalination Plant at Pigeon Point (Desal- Plant)

6.3.1. Plant Siting

A new desalination facility changes the properties of a coastal site and can permanently alter land use options. Potential impacts can be expected during plant construction and operation, but also from the building itself, including intakes, outfalls, pumping stations, and supporting infrastructure like roads, pipelines or power transmission lines. Construction activity could result in soil disturbance (dunes, beaches, seafloor), erosion, and damage to archaeological sites; heavy machinery produces air emissions and noise, obstructs views and disturbs terrestrial and marine organisms. Plant operation causes atmospheric and marine emissions or noise from pumping stations, while the building complex and supporting infrastructure alter the visual properties (and thus attractiveness to tourists) of a landscape permanently. As a consequence, altered air, water and sediment quality, in addition to auditory and visual effects, have potential impacts on human activities and the coastal environment (including loss of habitat). Values of adjacent properties could be reduced as well.

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6.3.2. Sea Water Intake and Outfall Maritime structures such as intakes or outfalls could interfere with navigation, access to harbours or other activities such as fishing. Construction and intake and outfall systems can affect water currents and sediment transport as well. An open seawater intake usually results in the loss of marine organisms when these collide with screens at the intake (impingement) or are drawn into the plant with the seawater (entrainment). An open intake requires an above-ground intake structure that can affect surface currents and sediment transport, interfere with shipping or other maritime uses, and provides a surface for the attachment of marine organisms. Optimal chemical dosage may be difficult to establish and overdosing might ensure safe operation in the case of deteriorating feed water quality, in turn increasing the risk of chemical discharges to the marine environment. Besides requiring minimal chemical pre-treatment, underground intake structures eliminate impacts from entrainment and impingement. However, initial disturbance during construction is higher as sediments have to be replaced or become re-suspended.

6.3.3. Impacts of Brine Production Most substances in the desalination discharge have a limited dispersal range so the associated environmental effects will be usually be restricted to the discharge site and its immediate vicinity. Their environmental fate is characterized by processes such self-decomposition (e.g. chlorine) and transport into sediments (e.g. copper, coagulants) in addition to dilution. Local effects may be significant. Residual chemical concentrations in the desalination discharge are relatively low but may eventually amount to heavy loads due to the large effluent volumes produced. The waste stream resulting from the desalination process consists of highly concentrated saline brine that may be increased in temperature, contain residual chemicals from the pretreatment process, heavy metals from corrosion or intermittently used cleaning agents. Emission of this multi-component waste into the sea, either directly through coastal outfalls or disposal might therefore have potential adverse effects on water and sediment quality or impair marine ecosystems. The physical and chemical properties of seawater are modified during desalination, depending on the pre-treatment methods and desalination process used. Pre-treatment steps required for reverse osmosis plants include scale and biofouling control, removal of suspended material and the control of corrosion and fouling. The process has a significant influence on effluent salinity, which is typically higher in the RO brine. In addition to pre-treatment chemicals, the effluent may contain intermittently used cleaning solutions if these are blended with the brine. The single effluent properties have potential impacts on the marine environment and their combined discharge might result in additive or synergistic effects.

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Salinity is one environmental factor controlling the distribution of marine organisms. Although most organisms can adapt to minor changes or might temporarily cope with strongly deviating salinities, the continuous discharge of highly saline effluents will be harmful to marine life and cause a change in species composition and abundance. The thermal discharge may change variable localized temperature distribution and seasonal variability in the outfall site with potential impacts on biological activity, species abundance and distribution. increased water temperatures could result in stress or cause an abrupt decline in biological activity when a critical value is exceeded. Marine organisms could be attracted or repelled by the plume, and species more adapted to the higher temperatures could eventually predominate in the discharge site. Oxygen solubility declines because reducing agents such as sodium bisulfite are used for dechlorination. The effluent might cause an oxygen deficiency in the discharge site, possibly harmful to marine life. Chlorine is a highly effective biocide and residual concentrations may be hazardous to marine life. Although environmental concentrations are decreased by rapid self-degradation and dilution, the potential for adverse effects on the marine environment is high. An initial decrease of 90 % can be expected in warm sunlit seawater, resulting in environmental levels of 20-50 µg/l in the mixing zone of the effluent, which is consistent with observed concentrations in discharge sites of desalination plants. For comparison, the U.S. EPA recommends a quality criterion for seawater of 7.5 µg/l for long-term exposure, which is based on toxicological results from a wide spectrum of species. Residual chlorine levels in seawater increase the risk that organohalogen by-products are produced, of which a major part will contain bromine in addition to chlorine. Bromide ions are naturally present in seawater and transformed into highly reactive bromine in the presence of chlorine. Organohalogen compounds may be formed from precursors of natural or anthropogenic origin. For example, trihalomethanes (THMs) originate from naturally-occurring organics and have been detected as major by-products in desalination plant discharge sites. Chlorophenols and chlorobenzenes may arise in the presence of petroleum compounds. The number of by-products is difficult to quantify due to many possible reactions with organic seawater constituents. While the different organohalogen compounds may not be present in acutely toxic concentrations, sufficient evidence exists that some of them have carcinogenic properties or may cause chronic effects during long-term exposure. Coagulants:

Filter backwash is non-toxic, but marine disposal increases the amount of suspended material in the discharge site. A potential adverse effect of higher turbidity and lower light penetration is a decline in primary production, while increased sedimentation rates could cause a burial of sessile organisms.

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Antiscalants:

Organic polymers are non-hazardous to marine life as toxicity values (LC50) exceed required dosage levels by several orders of magnitude. However, biodegradation is relatively slow with half-lives of one month or longer and it must be expected that organic polymers are persistent in the marine environment. As these substances control scale formation by dispersing and complexing calcium and magnesium ions in the desalination plant, they could influence natural processes of other divalent metals in the marine environment. Heavy metals:

Trace amounts of stainless steel alloys pose relatively little risk to the marine environment, but copper is highly toxic to most marine organisms. Concentrations as low as 10 µg/l in seawater may have significant effects, but toxicity generally depends on bioavailability and species sensitivity. Background copper levels in the Mediterranean are low and range between 0.04-0.70 µg/l in open water and <0.01-50 µg/l in coastal areas (UNEP, 1996). Dissolved copper levels are decreased by chemical and physical processes in seawater (precipitation, complex formation, adsorption), while the element is enriched in suspended material and finally in sediments. The risk of copper accumulation is potentially high for soft bottom habitats and areas of restricted water exchange, where sedimentation rates are high. Many benthic invertebrates (including shellfish) feed on suspended or deposited material, with the risk that heavy metals are enriched in their bodies (bioconcentration) and passed on to higher trophic levels. Cleaning solutions:

Seawater has a good buffering capacity, i.e. the natural pH of about 8 is usually not affected by slightly alkaline or acidic discharges. The discharge of highly acidic or alkaline cleaning solutions, however, may become toxic to aquatic life if dilution in the discharge site is insufficient. Detergents such as dodecylbenzene sulfonate are hazardous to aquatic life as they have the potential to disturb the intracellular membrane system of organisms. Similarly, the oxidizing potential of some chemicals (e.g. sodium perborate) may affect marine organisms by oxidizing their organic tissue. If complexing agents are released into seawater, they could interact with dissolved metal ions and interfere with natural processes of these elements in the environment. Complexing agents, e.g. EDTA, are typically used in cleaning solutions, which is persistent in the marine environment. Oxidizing or nonoxidizing biocides (e.g. chlorine or formaldehyde) are used for membrane disinfection, which are particularly hazardous and may be toxic to marine life if released to the environment. Membrane storage solutions containing sodium bisulfite could also have detrimental effects on marine life by causing oxygen deficiency in the discharge site. Oceanographic Conditions and Behaviour of Water Mass

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A distinct water mass may be formed under limited mixing conditions, characterized by effluent properties such as increased salinity or residual chemical concentrations. The spreading of this discharge plume could affect marine organisms. The RO brine is negatively buoyant as a result of its high salinity, with the potential to sink to the bottom and spread over the ocean floor, where it could have detrimental effects on benthic habitats. Sinking and spreading of the brine plume along the seafloor may affect benthic organisms.

6.3.4. Socio-Economic Impacts of Desalination

• Possible positive socio-economic impacts of desalination include:

• ensuring access to sufficient and safe drinking water for domestic use

• creating wealth through tourism, industrial and agricultural development, or even new employment opportunities in the desalination industry

• decreasing the pressure on natural resources, protecting freshwater ecosystems,

preventing desertification or ground-water salinisation

• aiding in attaining stability and peace in the region. Possible negative socio-economic impacts of desalination include:

• changed consumption patterns or even misuse of water due to the impression that water is readily available

• a further concentration of development and activity in the coastal zone, migration

of people.

• dependency on a technology that may in turn depend on the import of know-how or energy, that is vulnerable to deteriorating seawater quality (e.g. oil spills), and is probably centralized in a few locations requiring the transport of water over large distances. The magnitude of socio-economic impacts depends on the future development of desalination activity in the Mediterranean region. Trend scenarios range from a restricted use in developed countries to a widespread applicability in the whole region if costs can be further reduced.

6.3.5. Increased Development

Related to the above-mentioned socio-economic impacts, the construction of a desalination plant to meet water supply needs will likely result in growth-inducing impacts. This is likely to result in explosive growth in the desal plant service area owing to the already pent up demand in the region. Limited water is the major constraint to development in the service area. Therefore, the addition of the desalination could result in

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rapid new development placing additional pressure on the already strained infrastructure. This growth must be considered together with the ability to provide other basic services such as sewage, access to education, electric power etc. This growth should also be considered with respect to the size of the plant to be installed. As growth continues, there is the possibility that the plant will not be sufficient to meet the anticipated demand resulting in water shortages again.

6.3.6. Water Balance Issues The addition of water into the local and regional water balances, and into an urban water supply system that has a design capacity for smaller amounts of water, may cause some major impacts. In the urban setting, the water treatment systems, if existing, may not be capable of handling the new fresh water provided. Therefore, when new water is introduced into a supply system, corresponding water treatment capacity must be developed. When new water is added into a water basin which has always had the same water balance, physical impacts such as rising of the water table and possible water logging may take place. These physical impacts may have further-reaching consequences.

6.3.7. Hurricane Risk The proposed desal site is located along the coastal margin and is vulnerable to Hurricane. The site is relatively unprotected and exposed.

6.3.8. Mitigation Measures

Construction Construction should be scheduled for time periods that guarantee a low interference with recreation and tourism or breeding and migration of coastal animals. Preventive actions further include noise buffering, visual screening and spatially restricted construction. The desalination plant can be designed to minimize visual and auditory impacts (sound-proofing of complexes where pumps are housed, limited height of the facility and blending into the surrounding landscape). Impairment of water and air quality should be minimized by implementing best available techniques (BAT/BATNEEC) to limit emissions. Siting should be optimized to reduce land use and to avoid impacts on sensitive marine areas and protected species. Pipelines should be placed underground and/or their number and length minimized without accessing sensitive areas. The different interests and activities in the coastal site should be regulated by the coastal development plan to avoid conflicts. Seawater Intake

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Screens should be used to avoid intake of larger marine organisms. Intakes should be sited where less productivity is taking place to avoid intake of eggs or larvae; as a result, somewhat less fouling should take place and chemical use may be reduced. Intakes should further be designed to avoid impingement and flows should be optimized to avoid same. Generally, beach wells should be used in preference to intakes. Mitigation for Impacts of Brine Discharge Salinity: To minimize impacts from elevated salinity levels, desalination effluents should be within 10% of the ambient value, achieved by blending desalination effluents with power plant cooling water in adequate mixing ratios. Options that improve mixing in the discharge site should further be considered. Thermal Discharges: Temperature increase in discharged water should be limited to 10% above normal. Adequate mixing of the effluent plume with surrounding seawater should be ensured to mitigate impacts from elevated temperature. Oxygen Content: To prevent oxygen deficiency, oceanographic conditions in the discharge site should provide for good mixing of effluent and seawater to adjust oxygen contents to ambient levels within close distance from the outfall. Biocides: Neutralization of residual chlorine levels is of importance regarding the desalination process. Several chemical treatment options exist: dosing of sodium bisulfite (used in RO) or sulphur dioxide. Alternative treatment methods should be considered where feasible, such as ultraviolet light in small, automated systems. Major advantages of UV-light are that storage and handling of chemicals is not required, physical and chemical seawater parameters are not altered and no toxic by-products are formed. Other non-chemical pre-treatment options include prefiltration with fine-pored membranes (microfiltration or ultrafiltration) or the use of beach-wells, so that continuous biocide dosing is replaced by intermittent treatment for disinfection and cleaning. Coagulants: The filter backwash should be sufficiently diluted, e.g. by continuous blending with the brine, or be removed from the filters and transported to a landfill. The disposal option will also depend on the amount of material produced. Deposition in a landfill should be considered for large plants, where more material accumulates and potential impacts are more likely. The plant would further have to include a process for removal and means of transportation to the landfill. Antiscalants: Organic polymers may be used to mitigate potential impacts from increased nutrient levels in the discharge site. Although these substances are relatively non-toxic, their environmental fate and potential impact on dissolved metals in seawater should be addressed. Pre-treatment with sulphuric acid might be considered for where piping is plastic or stainless steel. The intake water can further be pre-treated by nanofiltration, a membrane softening process that partially removes divalent cations such as calcium or magnesium from seawater.

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Heavy Metals: Expected discharge levels of copper should be well below an established discharge limit of 500 µg/l (Barcelona Convention), but may exceed the water quality objective of 8 µg/l. The outfall should be placed and configured as to achieve sufficient dilution of copper, so that the quality objective can be met at the edge of the mixing zone. To lower the risk of toxic effects in the mixing zone, it is desirable to decrease copper concentrations in the effluent as far as possible. Sediments and organisms should be monitored with regard to quality criteria. Discharge concentrations can be influenced by controlling corrosion, which is usually achieved by pre-treatment of the intake seawater, the choice of corrosion-resistant construction materials, and the use of corrosion inhibitors. Nonmetallic equipment should be used where possible, e.g. for intakes and outfall pipes or in RO plants. Cleaning Solutions: Prior to discharge, cleaning and storage solutions should be recovered to remove any potential toxicity. This requires neutralization of the alkaline or acidic pH values and specific treatment for detergents, oxidants, complexing agents, biocides or other compounds with detrimental effects on marine life and the coastal water body. A wastewater treatment section should be implemented in the desalination plant, while substances for which existing treatment methods are inadequate should be avoided or replaced by alternative chemicals. Mixture of effluent in receiving waters: Mixing of the effluent in the receiving water body should be optimized by making use of favorable oceanographic conditions and discharging at appropriate intervals. Good mixing results can be achieved on high-energy coasts, where turbulence is high and strong currents cause a rapid water exchange; sheltered sites may trap effluents, resulting in long residence times of pollutants. In this case, the outfall should be located further offshore. Similarly, outfalls near the surface prevent attachment of negatively buoyant plumes to the sea floor. The outfall can further be technically improved, for example by using multi-port diffusers or increasing the discharge velocity. Different discharge scenarios should be analyzed for a proposed desalination plant to determine the best method of disposal. Water Balance Issues The water balance of the given area should be properly researched, so that the exact effects of the increased water in the basin can be calculated within a reasonable error margin. Wastewater treatment capacity would have to be increased to compensate for the extra water so that water logging and excessive water table increases do not take place to an extreme level. Hurricane Risks Construction should be made hurricane resistant to the extent possible by observing modern architectural practices.

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7. ENVIRONMENTAL MANAGEMENT PLAN For the works contemplated under the preferred option, capacity improvement, environmental management is relatively straight forward. The negative impacts associated with the program are construction related. Environmental management should begin at the contracting phase of the project, be evaluated during the tendering process and enforced during the performance of the actual works. Ultimately, WASCO should be responsible for environmental enforcement on these projects.

7.1. Contract development At the time works contracts are developed, enforceable clauses should be included with the contract requiring contractor environmental performance. Draft contract clauses are presented in Appendix 2 for consideration. Performance should be guaranteed through the use of the contract “hold back” often used to guarantee the performance of the construction works themselves. The environmental holdback should be constructed so as to allow partial penalty for failure to comply with the management requirements. A system based on number of failed inspections can be used to assess penalties. For instance, a series of 10 violations noted results in forfeiting 1/3 of the environmental hold back . Failure to deal with noted deficiencies should be considered a violation in itself. At the tenders phase, contract bids should include an evaluation of the contractors ability to fulfill the environmental management requirements and this requirement should the highlighted in the tenders documents.

7.1.1. Initial Planning Once engaged, the contractor is required to develop a series of operational management plans in accordance with the project requirements. This includes the development of environmental plans for the specific areas identified in the tender documents. For the capacity improvement project, these will include:

1. A construction waste management plan 2. An oil and hazardous materials management plan 3. The worker sanitation plan 4. A traffic management plan 5. A site stabilization and erosion control plan

The WASCO project officer will approve the plans developed by the contractor to assure they accomplish the environmental management objectives of the program and address

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the needs associated with the specific works. Once approved, the contractor is given authorization to start work.

7.2. Vigilance As with the management of the construction works, the WASCO project officer should inspect fro compliance with the environmental management requirements on a regular basis. Weekly sight visits should be sufficient for works of this nature. Where deficiencies are found, these should be noted and brought to the attention of the contractor. A period of three days should be given for contractors to rectify any problems noted. As the anticipated environmental impacts are during the construction phase of the project, timeliness is important. The impacts are of short duration and reversible but failure to exercise control during construction promotes incremental damage. Regular inspections of contractor activities are critical to their successful management.

7.3. Close out At the completion of works, the project officer should inspect the works for both engineering adequacy and environmental compliance. In all cases work sites are to be returned to an acceptable condition and in the case of excavations in roadways and agricultural fields, returned to serviceable condition. A satisfactory close out releases all hold back funds.

7.4. WASCO Responsibilities Apart from the requirements on contractors, WASCO has the responsibility for informing the public and management the compensation of losses incurred as a result of the works. Prior to the initiation of contractor operations, WASCO should contact each landowner and farmer to identify the extent of loss anticipated and negotiate a compensation settlement. Where works will affect traffic patterns, WASCO should hold a series of information meetings with affected locals to explain the works and the project work schedule. Route changes and work schedules should be published in local newspapers so as to allow citizens to plan for changes in traffic patterns. Additionally, WASCO should meet with police, fire, and medical personnel to present their plans and alert these agencies to the possible changes in short term access.

8. MANAGEMENT RECOMMENDATIONS During the management of these works, WASCO should develop clear lines of communication with project management and field personnel. All persons associated

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with the performance and supervision of the works should understand the environmental requirements imposed and who should be notified in the event of a problem Public affairs and public information will represent a major requirement for WASCO. As the projects are planned,, WASCO should appoint a Public Affairs officer to handle citizen questions and complaints. As needed the public affairs officer should meet with citizens groups and emergency services to provide timely information concerning road closures and route changes. Because the Ministry of works is responsible fro resurfacing damaged roadways, a specific liaison should be appointed to keep works informed as to schedule changes and road repair requirements. 9. INSTITUTIONAL IMPLEMENTATION Implementation of the environmental management program for these works can be managed through the project contract officer. Field inspectors reporting to the project officer will provide vigilance over the works and written reports for performance should include environmental management observations as well. Implementation in this case, is simply a slight augmentation of the responsibilities associated with civil works project management. Liaison with the public should be managed by WASCOS public affairs officer andd clear lines of communication should be maintained with Ministry of Works. 10. CAPACITY BUILDING WASCO is presently involved in a program of institutional strengthening under the Water Sector Reform program which includes the development of enhanced environmental management capacity. To this end, the implementation of the recommendations under that effort should continued as designed.

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APPENDIX I IUCN

Criteria for Critically Endangered, Endangered and Vulnerable

CRITICALLY ENDANGERED (CR) A taxon is Critically Endangered when it is facing an extremely high risk of extinction in the wild in the immediate future, as defined by any of the following criteria (A to E):

A) Population reduction in the form of either of the following:

1) An observed, estimated, inferred or suspected reduction of at least 80% over the last 10 years or three generations, whichever is the longer, based on (and specifying) any of the following:

a) direct observation

b) an index of abundance appropriate for the taxon

c) adecline in area of occupancy, extent of occurrence and/or quality of habitat

d) actual or potential levels of exploitation

e) the effects of introduced taxa, hybridisation, pathogens, pollutants, competitors or parasites.

2) A reduction of at least 80%, projected or suspected to be met within the next 10 years or three generations, whichever is the longer, based on (and specifying) any of (b), (c), (d) or (e) above.

B) Extent of occurrence estimated to be less than 100 km2 or area of occupancy estimated to be less than 10 km2, and estimates indicating any two of the following:

1) Severely fragmented or known to exist at only a single location.

2) Continuing decline, observed, inferred or projected, in any of the following:

a) extent of occurrence

b) area of occupancy

c) area, extent and/or quality of habitat

d) number of locations or subpopulations

e) number of mature individuals 3) Extreme fluctuations in any of the following:

a) extent of occurrence

b) area of occupancy

c) number of locations or subpopulations

d) number of mature individuals C) Population estimated to number less than 250 mature individuals and either:

1) An estimated continuing decline of at least 25% within three years or one generation, whichever is longer or

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2) A continuing decline, observed, projected, or inferred, in numbers of mature individuals and population structure in the form of either:

a) severely fragmented (i.e. no subpopulation estimated to contain more than 50 mature individuals)

b) all individuals are in a single subpopulation

D) Population estimated to number less than 50 mature individuals.

E) Quantitative analysis showing the probability of extinction in the wild is at least 50% within 10 years or three generations, whichever is the longer.

ENDANGERED (EN) A taxon is Endangered when it is not Critically Endangered but is facing a very high risk of extinction in the wild in the near future, as defined by any of the following criteria (A to E):

A) Population reduction in the form of either of the following:

1) An observed, estimated, inferred or suspected reduction of at least 50% over the last 10 years or three generations, whichever is the longer, based on (and specifying) any of the following:

a) direct observation

b) an index of abundance appropriate for the taxon

c) adecline in area of occupancy, extent of occurrence and/or quality of habitat

d) actual or potential levels of exploitation

e) the effects of introduced taxa, hybridisation, pathogens, pollutants, competitors or parasites.

2) A reduction of at least 50%, projected or suspected to be met within the next 10 years or three generations, whichever is the longer, based on (and specifying) any of (b), (c), (d), or (e) above.

B) Extent of occurrence estimated to be less than 5000 km2 or area of occupancy estimated to be less than 500 km2, and estimates indicating any two of the following:

1) Severely fragmented or known to exist at no more than five locations.

2) Continuing decline, inferred, observed or projected, in any of the following:

a) extent of occurrence

3) Extreme fluctuations in any of the following:

a) extent of occurrence

b) area of occupancy

c) number of locations or subpopulations

d) number of mature individuals

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d) number of mature individuals

C) Population estimated to number less than 2500 mature individuals and either:

1) An estimated continuing decline of at least 20% within five years or two generations, whichever is longer, or

2) A continuing decline, observed, projected, or inferred, in numbers of mature individuals and population structure in the form of either:

a) severely fragmented (i.e. no subpopulation estimated to contain more than 250 mature individuals)

b) all individuals are in a single subpopulation.

D) Population estimated to number less than 250 mature individuals.

E) Quantitative analysis showing the probability of extinction in the wild is at least 20% within 20 years or five generations, whichever is the longer.

VULNERABLE (VU) A taxon is Vulnerable when it is not Critically Endangered or Endangered but is facing a high risk of extinction in the wild in the medium-term future, as defined by any of the following criteria (A to E):

A) Population reduction in the form of either of the following:

1) An observed, estimated, inferred or suspected reduction of at least 20% over the last 10 years or three generations, whichever is the longer, based on (and specifying) any of the following:

a) direct observation

b) an index of abundance appropriate for the taxon

c) adecline in area of occupancy, extent of occurrence and/or quality of habitat

d) actual or potential levels of exploitation

e) the effects of introduced taxa, hybridisation, pathogens, pollutants, competitors or parasites.

2) A reduction of at least 20%, projected or suspected to be met within the next ten years or three generations, whichever is the longer, based on (and specifying) any of (b), (c), (d) or (e) above.

B) Extent of occurrence estimated to be less than 20,000 km2 or area of occupancy estimated to be less than 2000 km2, and estimates indicating any two of the following:

1) Severely fragmented or known to exist at no more than ten locations.

2) Continuing decline, inferred, observed or projected, in any of the following:

a) extent of occurrence

3) Extreme fluctuations in any of the following:

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3) Extreme fluctuations in any of the following:

a) extent of occurrence

b) area of occupancy

c) number of locations or subpopulations

d) number of mature individuals

C) Population estimated to number less than 10,000 mature individuals and either:

1) An estimated continuing decline of at least 10% within 10 years or three generations, whichever is longer, or

2) A continuing decline, observed, projected, or inferred, in numbers of mature individuals and population structure in the form of either:

a) severely fragmented (i.e. no subpopulation estimated to contain more than 1000 mature individuals)

b) all individuals are in a single subpopulation

D) Population very small or restricted in the form of either of the following:

1) Population estimated to number less than 1000 mature individuals.

2) Population is characterised by an acute restriction in its area of occupancy (typically less than 100 km2) or in the number of locations (typically less than five). Such a taxon would thus be prone to the effects of human activities (or stochastic events whose impact is increased by human activities) within a very short period of time in an unforeseeable future, and is thus capable of becoming Critically Endangered or even Extinct in a very short period.

E) Quantitative analysis showing the probability of extinction in the wild is at least 10% within 100 years.

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APPENDIX II DRAFT ENVIRONMENTAL MANAGEMENT CONTRACT CLAUSES

Standard Contract Clauses To facilitate environmental management, the following clauses have been developed for inclusion in construction contracts. These are based on the findings of the environmental assessment conducted fro the proposed works. These clauses, may be modified to conform with Grenadian law and shall remain in force during the contract period. It is recommended that these clauses be included in an Environmental Appendix to the construction contract. In most cases, it is the responsibility of the contractor to present environmental plans to the contraction officer prior to the commencement of works. Plans developed need only be as detailed as the works require.

Specific Clauses

1. Site Security

The contractor shall be responsible for maintaining security over the construction site including the protection of stored materials and equipment. In the event of severe weather, the contractor shall secure the construction site and associated equipment in such a manner as to protect the site and adjacent areas from consequential damages. This includes the management of onsite wastes, construction and sanitary, additional strengthening of erosion control and soil stabilization systems and other conditions resulting from contractor activities that may increase the potential for damages.

2. Discovery of antiquities

If, during the execution of the activities contained in this contract, any material is discovered onsite which may be considered of historical or cultural interest, such as evidence of prior settlements, native or historical activities, evidence of any existence on a site which may be of cultural significance, all work shall stop and the supervising contracting officer shall be notified immediately. The area in which the material was discovered shall be marked and the evidence preserved for examination.

Work may resume, without penalty of prejudice to the contractor upon permission from the contracting officer with any restrictions offered to protect the site.

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3. Worker Sanitation

Sanitation facilities shall be provided to site workers. All sanitary wastes generated as a result of project activities shall be managed in a manner approved by the contracting officer. The contractor shall provide the contracting officer with a site sanitation plan for approval and implementation prior to the commencement of site activities.

4. Noise Control

The contractor shall control noise emissions generated as a result of contracting activities to the extent possible. In the case of site locations where noise disturbance will be a concern, the contractor shall ensure that the equipment is in good working order with manufacturer supplied noise suppression (mufflers etc.) systems functioning and in good repair. Where noise management is a concern, the contractor shall make reasonable efforts to schedule activities during normal working hours (between 8 am and 5 pm). Where noise is likely to pose a risk to the surrounding community, the contractor shall inform the contraction officer and shall develop a public notification and noise management plan for approval by the contracting officer.

5. Use and management of hazardous materials, fuels, solvents and petroleum products

Any use hazardous materials excluding pesticides, oils, fuels and petroleum products shall conform to the proper use recommendations of the product. Waste hazardous materials and their containers shall be disposed of in a manner approved by the contracting officer. A site management plan will be developed by the contractor if the operation involves the use of these materials to include estimated quantities to be consumed in the process, storage plans, spill control plans, and waste disposal practices to be followed. This plan is subject to the approval of the contracting officer.

6. Use of preservatives and paint substances

All paints and preservatives shall be used only with the approval of the contracting officer. Information shall be provided to the contracting officer that describes the essential components of the materials to be used so that an informed determination can be made as to the potential for environmental effects an suitability can be made.

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Storage, use, and disposal of excess paints and preservatives shall be managed in conformance with the manufacturers recommendations and as approved by the contracting officer. The contractor shall provide the contracting officer with a list of materials and estimated quantities to be used, storage, spill control and waste disposal plans to be observed during the execution of the contract. This plan is subject to the approval of the contracting officer.

7. Site stabilization and erosion control

Contractor shall implement measures at the site of operations to manage soil erosion through minimization of excavated area, preservation of existing ground cover to the extent possible, provision of approved ground cover.

Where excavations are made, contractor shall implement appropriate stabilizing techniques to prevent cave-in or landslide. Erosion control measures shall be approved by the contracting officer.

An erosion management plan will be required where the potential exists for significant sediment quantities to accumulate in wetlands, lakes, rivers and near-shore marine systems. This plan shall include a description of the potential threat, mitigation measures to be applied, and consideration for the effects of severe weather and an emergency response plan.

8. Management of standing water

Under no circumstances shall the contractor permit the collection of standing water as aconsequence of contractor activities without the approval of the contracting officer and consultation with the Ministry of Health’s environmental health unit.

9. Management of trash and debris

The contractor shall provide the contracting officer with a trash and debris management plan that conforms to the solid waste management policies and regulations of Grenada. Under no circumstances shall the contractor allow construction wastes to accumulate so as to cause a nuisance or health risk due to the propagation of pests and disease vectors. The site waste management plan shall include a description of how wastes will be stored, collected and disposed of in accordance with current law. Additionally the contractor shall provide for the regular removal and disposal of all site wastes and provide the contracting officer with a schedule for such removal.

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