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FOOD AND AGRICULTURE ORGANIZATION

SOMALIA

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ENVIRONMENT AND SOCIAL MANAGMENT FRAMEWORK

(ESMF)

December 2008

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TABLE OF CONTENTS List of Tables and figures ……………………………………………………………. iii Abbreviations and Acronyms…………………………………………………………iv Executive summary …………………………………………………………………… v 1. INTRODUCTION AND BACKGROUND...................................................... 1

1.1 Introduction........................................................................................ 1 1.2 Project description............................................................................. 1

2 SUBPROJECT TYPOLOGIES AND THEIR POTENTIAL

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES............. 4 2.1 Sub-project typologies and location................................................ 4 2.2 Environmental context and Baseline conditions ……………..… 6 2.3 Sub-project characteristic ………………………………..………... 7 2.4 Environmental impacts of subprojects and proposed measures ………………………………….….................. 7 2.5 Analysis of alternatives ……………………….…………………. 14

3. SUBPROJECT SCREENING, REVIEW AND APPROVAL………………. 15

3.1 Implementing Agencies………………………………….………. 15 3.2 Screening and Review process…………………….…………….. 15 4. GUIDLINES FOR INSTITUTIONAL ARRANGEMENTS, TRAINING

NEEDS AND COST ESTIMATES FOR MITIGATION MEASURES – PROCEDURES FOR COST ESTIMATE.......................................................... 20

4.1 Institutional arrangements ……………………………………… 20 4.2 Training needs ……………………………………………………. 22 4.3 Cost estimates for mitigation measures ………………………... 22 5. COMPLIANCE OF RRRRLP ACTIVITIES WITH BOTH WORLD BANK

AND SOMALIAS’S POLICIES, GUIDELINES, LEGISLATION AND REGULATIONS................................................................................................. 24

5.1 Compliance with World Bank safeguards policies..................... 24 5.2 Compliance with Somalia’s environmental management policies …………………………...………….…… 27

6. PUBLIC CONSULTATION PROCESS........................................................... 28

6.1 Process for public consultation …………………………………. 28 6.2 Proposed disclosure plan ………………………………………... 28 6.3 Information and consultation means …………...…………….... 29

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Reference …………………………………………………………………...…. 30 Annex 1: Guidelines for Screening projects ……………………………….. 31 Annex 2: Environnemental Management Plan …………………................. 33 Annex 3: Environmental Impact Assessment TORs………………………. 35 Annex 4: Environmental Checklist for contractors ……………………….. 37 Annex 5: Land Acquisition Assessment …………. ……………………….. 41 Annex 6: World Bank Environmental and Social Safeguard Policies …... 42 Annex 7: Pest Management Plan …………………………………………… 45 EMSF Preparation team ………………………………………………........... 48

LIST OF TABLES AND FIGURES TablesTable 1: Main characteristic of irrigation rehabilitation sub-project ……….…….. 2 Table 2: Regional features, Potentials and Constraints in Somalia ……..……….... 6 Table 3: Potential environmental and social impacts and proposed mitigation

measures………………………………………………..……………………... 9 Table 4: Risk categories, based on the World Bank OP 4.01 ………..…………..... 17 Table 5: Estimated costs of training in environmental assessment …………………….. 23 Table 6: Summary of World Bank policies triggered …………..……….……..….. 24 Table 7: Key stakeholder groups in the RRRRLP ………………..…….………….. 28 FiguresFigure 1: Target districts and planned activities ……….…...……….………..….... 5

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ABBREVIATIONS AND ACRONYMS

CA Conservation Agriculture EA Environmental Assessment FAO United Nations Food and Agriculture Organization

FFS Farmer Field Schools GFRP Global Food Crisis Response Program

GAP Good Agricultural practices IPNS Integrated Plant Nutrition System IPPM Integrated Production and Protection Management IWM Integrated Weed Management M & E Monitoring and Evaluation

MoU Memorandum of Understanding

NGOs Non-Governmental Organizations

NTGS National Transitional Government of Somalia

RAP Resettlement Action Plan

RRRRLP Rapid Response Rehabilitation of Rural Livelihoods Project

SWALIM Somalia Water and Land Information Management TF Trust Fund

TOR Terms of Reference

WB World Bank

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EXECUTIVE SUMMARY

This document provides an Environmental and Social Management Framework (EMSF) outlining the screening, review and approval process for activities financed under the Rapid Response Rehabilitation of Rural Livelihoods Project (RRRRLP) in Somalia. The RRRRL project was prepared by the World Bank with the objective to increase crop and livestock production in areas affected by food crises in Somalia. The two main components (crops and livestock) pay attention to mainstreaming nutrition and gender concern in their interventions building on ongoing FAO projects in the country. Generally, RRRRL project will have minimal negative environmental or social impacts if any. Potential social impacts have to do with possible land acquisition for the construction of slaughter houses and auxiliary infrastructure, such as access roads, which could prompt the need for involuntary resettlement. However, this potential impact is considered very unlikely, given that most of the proposed facilities are expected to be constructed within existing infrastructure. The environmental impacts expected from this project are moderate to minimal. The slaughter houses and irrigation sub-projects could additionally trigger environmental impact, through increased use of pesticides and water abstraction. Thus, the safeguard policies triggered by the proposed project are OP/BP 4.01 environmental assessment, OP 4.09 pest management, and OP 7.50 projects on international waterways. The project is a category B project. The executing bodies responsible for ensuring social and environmental safeguards are adhered to include the project unit based within FAO Somalia, NGO’s and community based organizations sub-contracted for specific activities and contractors undertaking infrastructural work. However, to the extent that subprojects trigger safeguard policies, subproject specific safeguard documentation, such as sub-project pest management plans or even environmental impact assessment will be prepared. It is advised that an environmental specialist either in the project or from FAO Sub-regional office closely monitors project activities.

As poverty is widespread in both rural and urban areas of Somalia, and particularly severe due to the long recurrent conflict and failure in central governance, failure to institute sustainable agriculture and natural resource management practices would lead to loss of opportunity to correct this vicious cycle. Thus from an environmental, as well as socio-economic and humanitarian viewpoint, the ‘no RRRRL project’ alternative is not preferred.

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1 INTRODUCTION AND BACKGROUND

1.1 Introduction Environmental Assessment (EA) is a process used to evaluate projects potential environmental risks and impacts in the area of influence, examines alternatives, ways of improving selection, citing, planning, design, and implementation. It aims to prevent, minimize, mitigate, or compensate for adverse environmental and social impacts and enhance positive impacts throughout and after project implementation. Whenever feasible, preventive measures are favored over mitigatory or compensatory measures. This report provides guidelines for assessing possible environmental and social impacts of the subprojects of the Rapid Response Rehabilitation of Rural Livelihoods Project (RRRRLP) in Somalia. The guidelines indicate (i) how projects should be screened to determine their environmental and social impacts; (ii) how determination should be made and appropriate mitigating measures incorporated into the subprojects report and (iii) specify institutional responsibilities for undertaking environmental assessment including the social aspects, implementation of preventive, mitigatory or compensatory measures, and monitoring and evaluation

1.2 Project description The Food and Agriculture Organization of the United Nations (FAO) spearheaded the preparation of the Rapid Response Rehabilitation of Rural Livelihoods Project (RRRRLP) for Somalia and received the approval of a grant under the Global Food Response Program (GFRP) Trust Fund (TF) for an amount of US$7.0 million. The Global Food Crisis Response Program (GFRP) Trust Fund (TF), launched by the World Bank in May 2008 aims of minimize the threat posed by high food prices and sharply rising agricultural production and marketing costs to the livelihoods of poor urban and rural residents in developing countries. The project development objective is to increase crop and livestock production in areas affected by food crises in Somalia and would build on the ongoing FAO projects. The main components crops (component one) and livestock (component two) pay attention to mainstreaming nutrition and gender concern in the interventions.

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Component 1: Improving Food Production Capacity (USD 3.8 Million) The project aims to improve food production capacity by removing the main production constrains and expanding acreage under agricultural crops. These would be attained through distribution of improved inputs and rehabilitation and improvement of crop production infrastructure. Sub-component one, improving food production capacity will support provision of good quality seeds of maize and sorghum mainly sourced from surplus areas of Somalia highly productive in similar environmental conditions. Direct inputs (such as seeds and fertilizers) and complementary inputs (such as tools/implements) will also be availed. Specific activities under this sub-component are (a) distribution of technology packages (seeds, fertilizer and farm implements) and relevant training on appropriate use; (b) training of farmers—mainly women growing food crops—in improved agronomic and nutritional practices; which will be combined with vegetable seed distribution and (c) evaluation of use and impact of technology packages- will include post distribution review exercises carried out to inform/improve future assistance. However, if this will not be possible, i.e Somaliland seeds will be sourced from neighboring countries (Ethiopia), selecting varieties that have proved viable

Sub-component two, increased food production through rehabilitation and improvement of crop production infrastructure will support expanding acreages under agricultural crops that the long absence of stability and consequently lack of institutions has stifled especially in the productive sectors of Somalia. The project will support irrigation rehabilitation. FAO’s Somalia Water and Land Information Management (SWALIM) unit expertise will aid in appropriate project implementation of infrastructure rehabilitation activities.

Table 1: Main characteristics of irrigation rehabilitation sub-project • Canals to be rehabilitated 150Km • River embankment 40Km • Water Catchments 65 • Sluice gates 20 • Feeder roads 110km

The specific activities are (a) carrying out of profile surveys for all canals, embankment and roads that need to be rehabilitated; and (b) rehabilitation of infrastructure through a combination of private sector contracts and labor sourced from the community (with explicit commitment to employment of women).

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Component 2: Support Strategies for using Livestock Resources to address Current Food Crisis (USD 3. 2 Million)

About 55% of Somalis are directly engaged in livestock production and livestock provides 55% of calorie intake making it of direct importance for livelihood and food security. Constrains in production, animal health and marketing compounded by animal diseases and repeated trade bans by major trading partners in the Middle East exacerbates the current food crisis. Sub-component one, support to fodder production and marketing aims to secure livestock assets through fodder production and marketing as feed is a scarce resource in almost all parts of Somalia. It aims to increase access to fodder and “guarantee” better returns to producers and traders and promote supply response. The specific activities will include (a) improving fodder production and productivity by using selected lines of improved local grasses and sorghum; (b) improving fodder harvesting (introduce better tools), storage (baling) and conservation (silage fodder with added of feed additives including molasses and nitrogen sources, fortification of maize stoves with molasses (energy source) and ammonium (nitrogen source); (c) enhancing fodder market access (d) creating employment by training youth to be manual balers to provide services for a fee; (e) training of farmers/pastoralist in preparation of silage and in appropriate range rehabilitation techniques; (f) increasing the area under fodder production by stabilizing rivers and irrigation canals with grasses, while creating awareness on the need to improve range and water harvest. Sub- component two, improving slaughter houses with value addition services proposes a range of infrastructural intervention aimed at the rehabilitation of slaughter related basic infrastructures at community level. The specific activities under this sub-component are (a) rehabilitation of two slaughter facilities; (b) training of laborers in the facilities in efficient and hygienic meat production; (c) improving hides and skins collection and preparation; (d) harvesting and processing by-products alongside hides and skins (blood, bones and manure); (e) promotion of by-product use for improved nutrition and increased incomes, including consumption of what might be considered inferior products and use of manure for agricultural; (f) support for the production and sale of local traditional processed meat and (g) Improving recovery, sale and consumption of offals.

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2. SUBPROJECT TYPOLOGIES AND THEIR POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

2.1 Sub-project typologies and Locations The RRRRL project detailed work plan indicates the project would focus on activities that can generally be categorized into agricultural technologies, soil fertility and better land management, inputs and outputs marketing and physical infrastructures themes that fall into the crop and livestock components. The activities are as illustrated in figure one. Overall, the project will operate in the Northern (Somaliland and Puntland), Central and Southern Somalia regions. Figure 1 illustrates the districts and planned activities in the project areas.

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Figure 1: Target districts and planned activities

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2.2 Environmental context and Baseline conditions

The project sites could well be understood in terms of their differences, potentials and constraints among the different parts of the country. These are summarized in table 3 below. Table 2: Regional features, Potentials and Constraints in Somalia

Region Features Potential Constraints

Northern • Gulf countries provides livestock markets

• Predominately consumes imported staples

• Can homogeneity

• High reliance on social assets

• Developed milk marketing system

• Institutional setting and security relatively in place

• Localized water related problems

• Localized physical inaccessibility

• High human pressure on fragile ecosystems

Central • Hash ecological conditions

• More self-subsistence

• Low population density

• Wider migration patterns

• Flexible livestock trade routes.

• Water related problems

• Localised insecurity and mobility restrictions

• In accessibility and poor facilities

• Fragility of ecosystems

Southern • Favourable ecological conditions

• Kenya provides main livestock market

• Consumption of mainly local cereals

• Diversified economies (exchange with agricultural procedures and labour opportunities)

• Water access in river basins (Juba and Shabelle)

• Enhanced livestock diseases

• Clan diversity and options for conflict insecurity

• Weaker social networks.

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2.3 Subproject characteristics Anticipated sub-projects are generally expected to have some or all of the following characteristics: • Labour intensity: Sub-projects would be generally labour-intensive and use

simple tools as much as possible. • Communal benefits: The subprojects will benefit the community as a whole or

groups of households within a given area. • Community acceptance: Subprojects should be accepted and approved by the

community. They should have active community support and commitment. • Feasibility and sustainability: The subprojects should be feasible technically,

socially and economically. To the extent possible, they would be simple and manageable in implementation and maintenance to be sustainable.

• Gender sensitivity: Wherever possible, priority will be given to projects in which women are able to participate and from which they can benefit.

2.4 Environmental impacts of RRRRLP subprojects and proposed

mitigation measures

Environmental and Social benefits are likely to represent a substantial portion of RRRRLP subprojects. The proposed RRRRLP subproject has been designed, to create many beneficial impacts related to environmental regeneration and sustainable agriculture that are long-term rather than short-term, and will not be limited to the members of village community as well expounded in the proposal. However, they may also have adverse environmental impacts, if good practice is not followed in their citing, design and implementation. Generally, the project is not expected to have any significant negative social impacts. The two potential significant impacts have to do with possible land acquisition for the construction of slaughter houses and ancillary infrastructure, such as access roads, which could prompt the need for involuntary resettlement of the affected populations. However, this potential impact is considered very unlikely, given that most of the proposed facilities are expected to be constructed within existing infrastructure. Secondly, the proposed interventions could affect the sub-clan cohesion. Somalia is made up of several recognized sub-clans historically prone to tension due to resource allocation and leadership. To avert such tensions, the sub-clan would be the typically dominate group in their distinct geographical areas and their priorities would be address through participatory approach to planning and implementation. In fact, the RRRRLP shouldn’t finance any intervention that is determined through the ESMF process to be potentially detrimental to any sub-clan.

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The environmental impacts expected from this project are moderate to minimal. The slaughter house and irrigation sub-projects are the only ones likely to have some environmental impact, either due to temporary disruption through the construction of ducts for water channels or from the construction of ancillary infrastructure, notably access roads, associated rural access to markets. Table 3 sets out typical adverse impacts that need to be avoided, managed and mitigated and sets out a range of mitigating measures that have been found to be useful to offset potential adverse impacts to ensure optimum results from subprojects expected. Detailed mitigating measures recommended to offset adverse impacts for specific types of sub-projects will be integrated into the technical specifications, work norms and information kits guiding the implementation of sub-projects under the RRRRL project.

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Table 3: Potential environmental and social impacts and proposed mitigation measuresIssue Potential Impacts Recommended mitigation measures

Terrestrialhabitatalteration

Terrestrial and aquatic habitats maybe altered primarily duringconstruction of infrastructuredepending on the type ofinfrastructure component andproposed location. Potential impactsto habitat may be more significantduring construction and installationof slaughter house, irrigationchannels, as well as access roadsalong previously undeveloped land.

• Sites to avoid critical habitat through use of existingutility and transport corridors, whenever possible;

• Avoidance of construction activities during thebreeding season and other sensitive seasons ortimes of day;

• Re-vegetation of disturbed areas with native plantspecies;

• Management of construction site activities asdescribed n relevant sections annex 4.

Aquatichabitatdisruption

Depending on their location andnature, irrigation works includingconstruction of dykes and accessroads to farms and other fixedinfrastructure, may requireconstruction of corridors crossingaquatic habitats with the potential todisrupt watercourses, wetlands, andriparian vegetation.

• Sites to avoid critical aquatic habitat such aswatercourses, wetlands, and riparian areas,whenever possible;

• Maintaining fish access when road crossings ofwatercourses are unavoidable by utilizing clearspan bridges, open-bottom culverts, or otherapproved methods;

• Minimizing clearing and disruption to riparianvegetation;

• Management of construction site activities asdescribed in annex 4.

Disruption ofexisting waterusers

The irrigation sub-project maydisrupt existing water users, downstream water flow, and affectsensitive down stream habitats and

• Assess water supply and existing demands, andmanage sustainability.

• Establish or strengthen a water users committee,where appropriate, and/or by laws and provide

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water bodies where appropriate, and/or by laws and providetraining to water users.

• Adherence to water rights by irrigationassociations.

• Identify and avoid effects of diversion or extractionon downstream ecosystems that depend on thesurface or groundwater supply

• Floods early warning system is needed.Soildegradation

Vulnerability to water logging andother soil related problems

Degradation of soil cover anddecreasing soil fertility

• Assess soil characteristics and either avoid orprovide drainage for areas prone to water logging.

• Irrigation expert to assess the potential for highsalinity and ensure appropriate irrigation practices tominimize impacts.

• Provide appropriate technologies for integrated soilfertility management

Landacquisition/private assetsdisplacement

Sub-projects such as slaughter houseand feeder road construction maydisplace or restrict access withinformal or informal land uses andcreate new settlement pressures

• Avoid occupied land as far as possible.• Construction within existing infrastructure• Prepare procedures to ensure equitable resolution

where unavoidable.• Ensure road development is coordinated with local

land use plans and discuss with existing governancestructures.

Low capacityformanagement

Insufficient capacity to managevarious sub-projects and undertakeEMSF may lead to negativeenvironmental and social impactsand may further create new conflicts.

• Carry out the environmental and social screeningprocess outline in the ESMF.

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Use ofinorganicfertilizers

Could affect both physical andbiological environment throughsalinization of soils, contamination ofground water, promotion of weedgrowth, increased pest problems andincreased health risks.

• Appropriate quality and quantity use of fertilizersaccording to soil capacity

• Adherence to provisions of the subproject-specificpest management plan (annex 6).

• Disease surveillance.• Proper screening of herbicides

Constructionnuisance

Negative impacts of minor civilworks include noise pollution,generation of construction wastes anddust during the construction phase.In some cases, open pits could be leftbehind after the excavation of sandand aggregate materials. Loss ofvegetation and habitat fromexcavation sites.

• Adhere to contractor’s terms (annex 4).

Overstocking Improved livestock production couldlead to overgrazing causingdegradation of land and vegetation,soil erosion, gas emissions and loss ofnatural habitats.

• Observing land carrying capacity• Development of livestock stabulation

Increase insolid wastes

The potential environmental impactsof slaughter units and initialprocessing of livestock products aresolid wastes, contamination, noisepollution, vibrations and dust. Solidwaste including abdominal content,inedible meat, most of the offals,pregnant uteruses, bones, hooves,

• Provide for proper waste disposal.• Slaughter and ancillary facility effluent treatment

unit must not drain into rivers or contaminateunderground water sources

• Ensure hygienic conditions• Adherence of industrial and occupation health

regulation.• Provide for water supply and sanitation facilities.

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horns, camel pads and tails andpieces of hides and skins.

• Provision for manure transfer to farm and rangelands

Poor personnelworkingconditions

Slaughter houses and other auxiliarystructures have the potential tointroduce low or even hazardousworking conditions.

• Provide first aid kits.• Personnel trained in provision of basic emergency

aid or back up or in-house laboratory services.• Protective clothing and boots for workers.• Appropriate working tools.• Follow ILO code for workers.

Gender bias In such societies where roles forhundreds of years are clearly dividedbetween men and women there arepossibilities for gender bias.Unfortunately, women are often asuncomfortable with the idea ofchange as the men are. Gender issuesare moreover seen as political andideological issues.

• Gradual push through training and awareness foraacceptance of the concept of rights-basedprogramming.

• Combating increasing poverty of Somali women byinvolving them more in livestock and cereals trade.

• Improving women’s access to education onagriculture and livestock development.

• Highlighting the special concerns of girl-child inagriculture and livestock management.

Poor citing ofslaughterhouse

Infrastructure and especiallyslaughter houses have a higherpotential for negative environmentaland social impacts due to their citing

• Must stick to approved town or rural plans, if theseare not available then the facility must not be in aresidential or commercial sections of the town orrural area.

• Must NOT be next to a seasonal river bed.• Provide for holding pens, sick animal isolation pens

or condemned material pits or incinerators.• The area needs to be accessible by road and where

available be served with utilities including waterand power.

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Project andsub-projectssustainability

Projects and sub-projects often havethe potential to slow down andeventually collapse after withdrawalof donors/technical assistanceleading to a combination of negativesocial and environmental impacts.

• Training of the farmers for crop management,ownership of the projects, natural resourcemanagement, marketing and revolving fundsmanagement among others.

• Farmers’ co-operatives could be created andsupported to maintain sustainability.

• Training and capacity building of the local NGOs.• Consideration of local blacksmiths for producing

agriculture tools locally.• Women participation in subproject activities.

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2.5 Analysis of alternatives Sub- projects will assess alternative strategies for achieving objectives of improved agricultural productivity, environmental improvement and more sustainable livelihoods. Alternatives considered would include but go beyond the no-alternative option. Their anticipated outcomes will be discussed with relevant stakeholders in the course of the environment and social screening process.

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3 SUBPROJECT SCREENING, REVIEW AND APPROVAL This section outlines the screening, review and approval process for activities to be financed under the RRRRL project. It is important to have appropriate tools in place to assist the project implementing agencies in screening activities for potential impacts and to provide guidelines for implementing measures to effectively address them. Once the subprojects locations have been selected, the project should use this section as the guidelines to screening subprojects and implementing the appropriate measures while ensuring that all respective legislative requirements for screening and EIAs are adhered to as shown in section 5.2. 3.1 Implementing Agencies As RRRRL project will cover Somalia but in different regions with different governance system and the project unit (based within FAO Somalia office), NGO’s and Community Based organizations sub-contracted to implement, and contractors under taking infrastructural works are the three main executing bodies under the project with responsibility of ensuring proposed screening and impact mitigation mechanisms are implemented. It is advised that an environmental specialist either in the project or from the FAO sub-regional office closely monitors the activities. 3.2 Screening and Review Process Since the sub-projects supported by RRRRLP are small and because rural people will be the drivers of the projects, the process of environmental screening must be simple and informative. The process will consist of the following steps: Step 1: Environmental and Social Screening of subproject activities Once the subproject activity location has been selected, a screening form will be filled out. The form will allow for identification of the potential environmental and social impacts associated with the proposed activity. As the ESMF and Resettlement Screening Form should be utilized in tandem, the screening form will also allow for the identification and assessment of impacts related to potential land acquisition and involuntary resettlement if triggered. A template for screening is provided in annex 1 and 5.

Step 2: Scoping and field appraisal Based on the information provided in the screening form, the reviewer (i.e. the relevant environmental ministry official/project manager/ FAO Somalia or Sub-

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regional office) will make a decision as to whether or not the subproject will require a more detailed investigation of the impacts through a field appraisal. Information collection will be achieved through observation and use of professional expertise and in some cases, interviews with the local people could provide information regarding human use values and/or environmental significance. As part of the field appraisal, the project shall identify the major stakeholders /community groups within the affected area that are likely to be impacted. A list of potentially affected groups shall be compiled and appended to the appraisal report. Step 3: Assessment and classification of impacts Based on the screening form and field appraisal (when required), the impacts are classified based on their risk category and decision made as outlined below:- (a) Category A: A proposed project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. These impacts may affect an area broader than the sites or facilities subject to physical works. EA for a Category A project examines the project’s potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the "without project" situation), and recommends any measures needed to prevent, minimize, mitigate or compensate for adverse impacts and improve environmental performance. For a Category A project, the borrower is responsible for preparing a report, normally an EIA (or a suitably comprehensive or sectoral EA) that includes as necessary, elements such as environmental audits or hazard or risk assessments. Should RRRRLP sub-projects be assigned category A they will either have to be redesigned and re-screened, or dropped, because the RRRRL Project has been assigned the environmental category B. (b) Category B: A proposed project is classified as Category B if its potential adverse environmental impacts on human populations or environmentally important areas - including wetlands, forests, grasslands, and other natural habitats - are less adverse than those of Category A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigatory measures can be designed more readily than for Category A projects. The scope of EA for a Category B project may vary from project to project, but it is narrower than that of Category A. Like Category A, it examines the project’s potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance.

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(c) Category C: A proposed project is classified as Category C if it is likely to have minimal or no adverse environmental impacts. Beyond screening, no further EA action is required for a Category C project.

The following table illustrates the risk categories, based on the World Bank OP 4.01 environmental categories (A, B, and C). As mentioned earlier, category A sub-project cannot be funded under the RRRRLP.

Table 4: Risk categories, based on the World Bank OP 4.01 Medium

Cat. B Types of Activity High

Cat. A

B2 B1

Low Cat. C

Construction and maintenance of access roads, crop production infrastructure or other existing linear infrastructure which does not require expansion i.e improved slaughter house

�

Construction of new slaughter house �Rehabilitation of slaughter house �Rehabilitation of irrigation channels �Provision of seeds/ direct inputs �Support to fodder production and marketing �

In cases where the results of the screening process indicate that the sub-project will not have significant adverse environmental and social impacts, if any, no additional environmental work will be required and sub-project implementation can proceed immediately

Since not all category B sub-projects are likely to require a separate EIA report, the screening process will recommend the assignment of (i) category B1 to sub-projects requiring only the application of simple mitigation measures (using the Environmental Management Plan – Annex 2 of the ESMF); and (ii) B2 for those sub-projects requiring a separate EIA report due to the severity of their potential adverse environmental and social impacts (using the generic EIA Terms of Reference – Annex 3 of the ESMF).

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Step 4: Identifying alternatives to subproject design For subprojects which are deemed high risk, as they may result in significant impacts, the project will re-assess the location and design of the subproject to ensure that there are no alternatives which may minimize or avoid these potential environmental and/or social impacts. If an alternative is not feasible, then the project must prepare an EIA and/or RAP. Step 5: Appraisal and Approval

(a) Environmental permitting requirements

• For Category B2 (subprojects requiring an EIA): The project will submit a copy of the EIA to the relevant authority for review. This should include all relevant information (as outlined in the country’s legislative requirements (refer to Chapter 5.2), namely an EMP, a set of environmental contract clauses and a summary of public consultations carried out. Annex 3 provides the Terms of Reference for preparation of an EIA.

• For Category B1 (subprojects which require an EMP): The project will prepare an EMP (refer to Annex 2). The objective of the EMP is to identify and mitigate the environmental and social needs of the project in a simple, responsive and cost effective manner that will not unnecessarily overload or impede the project cycle. The EMP should be a simple two to four page document that outlines the main environmental and social mitigation measures; environmental training and capacity program; and environmental and social monitoring program.

Criteria for Approval

i. For those EIAs which meet the country’s EIA requirements and World Bank OP 4.01, an environmental permit can be granted.

ii. For those EIAs which do not meet the country’s EIA requirements and World Bank OP 4.01, an environmental permit is rejected and the relevant environmental authority (i.e. Ministry of Environment or Environmental Council) may want to carry out an audit. The Project will resubmit the EIA based on recommendations of the audit. As emphasized in the World Bank’s guidelines, a subproject should not be approved and funded until such reports are received, approved and disclosed. The EIA reports will also need to be reviewed and approved by the Bank.

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Step 6: Disclosure of Subproject Information

Disclosure of subproject information would be undertaken as indicated in section 6.2 - public consultation process. Step 7: Monitoring Reports Compliance monitoring comprises on site-inspection of subproject technical, infrastructural and construction activities to verify that measures identified in the EMP and/or RAP and included in the clauses for contractors are being implemented. This type of monitoring is similar to the normal tasks of a project manager or designated officer whose task is to ensure that the implementation is within prescribed standards and specification. Once implementation of the subproject has started, regular supervision missions should be carried out and annual monitoring report must be submitted to the lead implementing agency for each region and compiled to the World Bank for review. The purpose of these reports is to provide a record of project and subproject transactions, environmental and social issues, a record of experience and issues running from year-to-year throughout the project that can be used for identifying difficulties and improving performance; and practical information for undertaking an annual review.

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4 GUIDLINES FOR INSTITUTIONAL ARRANGEMENTS, TRAINING NEEDS AND COST ESTIMATES FOR MITIGATION MEASURES

4.1 Institutional arrangements

4.1.1 Implementation arrangements

The implementation of the RRRRLP will take place at different levels and at times not all levels given governance differences within Somalia but will take into account the coordination and implementation arrangements set out. This involves agencies and entities at the national level, state/regional level, locality level and community level. The lead implementing agency will be the Food and Agriculture Organization Somalia Office (FAOSO). It would be supported, as needed, by officers from FAO technical departments of agriculture, natural resource and technical co-operation on issues related to crops, livestock, natural resource management and emergency response. These would be drawn from FAO Eastern Africa Sub- regional Office in Addis Ababa, Ethiopia and whenever needed from FAO HQ. Partner NGO’s and CBOs will consist of both local and international organizations at state and district levels and will form the backbone of distribution networks. Seeds, equipments will be normally procured from the local market and distributed through such partner organizations by contract agreements and if necessary through new partners. This would also form a reliable channel to ensure activity sustainability. The overall responsibility for agricultural development in Somaliland rests with the Ministries of Agriculture, while in Puntland with the Ministry of Livestock, Agriculture and Environment (MOLAE). A strategic plan for agriculturalrehabilitation and development was developed with a goal to ensure household food security by ensuring an equitable allocation of resources, improving crop production, and capacity building within the Ministry of Agriculture. The ministry of Water and Mineral Resources is responsible for the management of freshwater resources and for water withdrawal. In northeast Somalia, the Ministry of Pastoral Development and Environment is responsible for natural resource management, including the use of forest and surface water and groundwater resources. These government arms would be significant in planning, implementation and monitoring. Members of the Community through their representatives will undertake - after training - both compliance monitoring and effects monitoring. This will be done throughout the sub-project cycle namely:

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i. During the planning phase, the communities will participate in the identification of indicators for monitoring the mitigating measures;

ii. During implementation (construction phase), monitoring the execution of works with respect to environmental aspects, e.g. verify the compliances of the Contractors with their obligations;

iii. During operation and maintenance phase, the overall environmental monitoring and alerting on any emerging environmental hazards in conjunction with the ongoing sub-project activities. The communities will be enabled to pass on their observations and concerns through the review team and project management.

4.1.2 Implementation challenges RRRRLP will operate in a generally unstable, diverse and precarious governance region. Although implementation challenges will vary from one region to another, ease of movement would generally be restricted among international staff and has to be carefully monitored from time to time. Minimum security operation standards (MOSS) for such areas as per UN regulation will have to be strictly adhered to and would to a certain extent affect operations. These would however be minimized through use of FAO’s extensive experience in the country who include trained local staff. Potential challenges which could affect the quality and effectiveness of the environmental standards of the anticipated projects is mainly the national level implementing agencies lack the necessary capacity and are less able to provide technical assistance to grantee implementation of the ESMF. Moreover, in a number of cases, the capacity of local organizations for sustainable work, accountability and maintenance of assets are not well developed, and therefore would require training in order to perform to the required standards.

Thus, RRRRLP program would finance training in the ESMF for the relevant international, national, and locality staff. In a number of cases where the governance capacity is limited, the program would finance consultants to provide supplementary assistance.

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4.2 Training needs A two day training seminar on familiarization with the EMSF framework is recommended for the project management team based in Nairobi and Somalia to become familiar with the principals of the ESMF. It would highlight the environment assessment process. Environmental assessment process (2 days)

• Screening process • Assignment of environmental categories • Rationale for preparing an EMP • Preparation of terms of reference for carrying out EIA • How to review and evaluate EIA reports • How to review and approve screening results • The importance of public consultations in the EIA process • How to monitor project implementations

Additionally, a three to four day training program is proposed for the RRRRL project staff and review team in Somalia. In addition to familiarization with the environmental assessment process, the training should cover:- Environmental policies, procedures and sectoral guidelines (1 day)

• Review and discussion of Somalia’s environmental policies, procedures, and legislation

• Review and discussion of the Bank’s safeguard policies • Review and discussion of Somalia’s existing sectoral guidelines • Collaboration with institutions at the local, regional, national levels

Selected topics on environmental protection (1 days)

• Soil erosion • Desertification • Deforestation • Water quality control • Waste disposal • Pest management

4.3 Cost estimates for mitigation measures The design of crop and livestock production activities, will and have taken into account environmental and social concerns and such would form part of the subproject costs. In construction and infrastructural works, it is expected that compliance with environmental and social conditions will be part of standard

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good workmanship and state of art as will generally be required under Contract (annex 4). The item “Compliance with Environmental Management Conditions” would imply these costs. No other payments will be made to the Contractor for compliance with any request to avoid and/or mitigate an avoidable environmental and social impact(s). For EMSF, an estimated US$ 200,000 would be required to arrange for and coordinate training in environmental assessment, World Bank and Somalia’s governance policies, monitoring and follow up as summarized in table 5 below. Table 5: Estimated costs of training in environmental assessment Area of activity Responsible Target Outcomes Proposed

timing Cost Estimates US$

Train project management team

RRRRLP Project management team in Kenya and Somalia

Increased appreciation and skills for ESMF

March 2009

15,000

Conduct training needs assessments for RRRRLP, Government and local authorities and communities

RRRLP RRRRLP Authorities

community

Training needs identified and documented

March 2009

5,000

Establish and train review committee in Somaliland, Puntland and Central Somalia

RRRRLP, government and local authorities

RRRRLP Authorities

community

Project review team established

April 2009 and progressively as required

40,000

Arrange for and coordinate training in environment in general & EA, WB & Somalia policies

RRRRL project

RRRRLP staff, government and local authorities, review team members

Increased environmental awareness, appreciation of EA, skills for EA

May 2009 and quarterly as implementation progress

100,000

Implementation, monitoring and follow-up of environmental and social screening

RRRRLP Review team Env. expert

Sub-projectcommittees

local authorities

Subproject EMPs outlined in ESMF successfully

Continuous

40,000

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process

implemented

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5 COMPLIANCE OF RRRRLP ACTIVITIES WITH WORLD BANK AND SOMALIA’S POLICIES, GUIDELINES, LEGISLATION AND REGULATIONS

5.1 Compliance with World Bank safeguards policies A list of World Bank environmental and social safeguard polices is summarized in annex 5. The proposed project has triggered OP 4.01 Environmental Assessment OP 4.09 Pest Management, OP 4.12 Involuntary Resettlement and OP 7.50 Projects on International Waterways. The environmental category of the project is B, and the safeguards category is S2. Project response to triggered safeguards policies are as in table 6 below:- Table 6: Summary of World Bank policies triggered

The objective of this policy is to ensure that Bank-financed projects are environmentally sound and sustainable, and that decision making is improved through appropriate analysis of actions and of their likely environmental impacts. This policy is triggered if a project is likely to have potential (adverse) environmental risks and impacts on its area of influence. OP 4.01 covers impacts on the natural environment (air, water and land); human health and safety; physical cultural resources; and transboundary and global environment concerns.

Depending on the project and nature of impacts, a range of instruments can be used: EA, environmental audit, hazard or risk assessment and environmental management plan (EMP). When a project is likely to have sectoral or regional impacts, sectoral or regional EA is required. The Borrower is responsible for carrying out the EA.

OP 4.01 EnvironmentalAssessment

Investments under RRRRLP will be subject to environmental and social screening during the planning stage, and appropriate steps will be taken based on the results of the environmental and social screening process outlined in this document

OP 4.09 Pest Management

The objective of this policy is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides; and (ii) strengthen the capacity of the country’s

The policy is triggered if : (i) procurement of pesticides or pesticide application equipment is envisaged (either directly through the project, or

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regulatory framework and institutions to promote and support safe, effective and environmentally sound pest management. More specifically, the policy aims to (a) Ascertain that pest management activities in Bank-financed operations are based on integrated approaches and seek to reduce reliance on synthetic chemical pesticides IPM in agricultural projects and Integrated Vector Management (IVM) in public health projects. (b) Ensure that health and environmental hazards associated with pest management, especially the use of pesticides are minimized and can be properly managed by the user. (c) As necessary, support policy reform and institutional capacity development to (i) enhance implementation of IPM-based pest management and (ii) regulate and monitor the registration distribution and safe use of pesticides.

indirectly through on-lending, co-financing, or government counterpart funding); (ii) the project may affect pest management in a way that harm could be done, even though the project is not envisaged to procure pesticides. This includes projects that may (i) lead to substantially increased pesticide use and subsequent increase in health and environmental risk; (ii) maintain or expand present pest management practices that are unsustainable, not based on an IPM approach, and/or pose significant health or environmental risks.

RRRRLP has prepared pest management guidance for sub-project (Annex 7).

OP 4.12 Involuntary Resettlement

The objective of this policy is to (i) avoid or minimize involuntary resettlement where feasible, exploring all viable alternative project designs; (ii) assist displaced persons in improving their former living standards, income earning capacity, and production levels, or at least in restoring them; (iii) encourage community participation in

This policy covers not only physical relocation, but also any loss of land or other assets resulting in: (i) relocation or loss of shelter; (ii) loss of assets or access to assets; (iii) loss of income sources or means of livelihood, whether or not the affected people must move to another location.

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planning and implementing resettlement; and (iv) provide assistance to affected people regardless of the legality of land tenure.

This policy also applies to the involuntary restriction of access to legally designated parks and protected areas resulting in adverse impacts on the livelihoods of the displaced persons.

Given that all sub-projects are planned and implemented based on decisions made by the communities in this regard, it is highly unlikely that OP 4.12 will be triggered. However, a resettlement screening form is as attached in annex 5 to safeguard compliance. In the event it is triggered a Resettlement Action Plan (RAP) will be developed in compliance with OP 4.12.

OP 7.50 Projects in International Waters

The objective of this policy is to ensure that Bank-financed projects affecting international waterways would not affect: (i) relations between the Bank and its borrowers and between states (whether members of the Bank or not); and (ii) the efficient utilization and protection of international waterways.

This policy is triggered if (a) any river, canal, lake or similar body of water that forms a boundary between, or any river or body of surface water that flows through two or more states, whether Bank members or not; (b) any tributary or other body of surface water that is a component of any waterway described under (a); and (c) any bay, gulf strait, or channel bounded by two or more states, or if within one state recognized as a necessary channel of communication between the open sea and other states, and any river flowing into such waters.

The project involves rehabilitation of existing canals, and does not involve works and activities that would exceed original scheme, change its nature, or alter and expand its scope and extent to make it appear a new or different scheme. Consequently, given its rehabilitation works, the project falls under the exception set forth in paragraph 7 (a) of OP 7.50 as (a) it will not adversely affect the quality or quantity of water flows to the other riparians; and (b) it will not be adversely affected by other riparians’ water use. A memorandum to this effect has been drafted and approved by the Regional Vice President.

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5.2 Compliance with Somalia’s environmental management policies

Since 1991 Somalia has not functioned as a unitary state. The state has effectively fragmented into distinct regional blocks, loosely reflecting the territorial distribution of major clans, which remain the dominant force in the country’s affairs. In areas where public administration has been established, advances have been made in restoring the former juridical system that incorporated environmental management policies spread within different acts.

For instance in Somaliland, the 1971 law governing the Water Development Agency was amended in a draft Water Act and a Water Policy prepared in 2004. Two key Ministries of Pastoral Development and Environment and Agriculture have each sponsored a law: the Conservation and Protection Act of May 1998 by the Ministry of Pastoral Development and Environment and the Agricultural Land Property Law of August 1999 by the Ministry of Agriculture that are quite prolific in environmental management but do not apply in other regions.

Additionally, in most rural communities, traditional Somali law (xeer) and the Islamic Sharia law continue to be upheld. The ownership of land and water is based on the Somali social organization where each clan is associated with a particular territory. The law for instance says that water is public property but allows appropriation and usage is acquired by administrative permits.

The existence of a failed state presents opportunities for non compliance in most regions of Somalia. It is advised that general environmental procedure for issuing environmental permits as shown below be adapted to selected locality in the RRRRL project (even though the specific regulation may not exist):-

• Preliminary scoping and screening (No specific regulation in Somalia) • Environmental Impact Assessment (EIA)

o Should it be required, the project is responsible for the EIA process. o An EIA report is prepared (annex 3)

• Application for the Environmental Permit o Written application prepared by the project (EIA report + other

required documents) o Public consultation Information in accessible notice areas (within 10

days upon submitting an application) o Public review of EIA report and written remarks (within 2 months

upon reception of application) o Possibility for the public to carry an independent EIA

• State Ecological Expertise o Organized by an environmental administration body/Commission

of independent experts

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• Decision and Delivering of Environmental Permit • Post-project monitoring (No specific regulation in Somalia)

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6 PUBLIC CONSULTATION PROCESS

6.1 Process for Public Consultation

During the screening process,, consultations will be carried out with relevant stakeholders (table 7) including potentially affected persons.. Table 7: Key stakeholder groups in the RRRRLP Government and regulatory agencies

Agencies outlined in section 5.2, as well as other relevant government and public sector agencies.

Public and private sector operators

lead private sector companies, such as existing slaughter house companies and seeds and construction companies

Non-government organizations

International and local stakeholder groups, including environmental NGOs

Local stakeholders

Community based organizations (CBOs), Municipal and district level committees, unions and other local groups

Academic and research institutions

Environmental research groups, universities and technical institutes

Potentially affected persons

Communities, Individuals and even local authorities

The key elements of a communication strategy for this project are: i. the provision of correct information about the decision-making and

implementation process of the project, ii. the creation of mechanisms which allow people to express their views and

grievances about the process, collect concerns and suggestions, iii. the creation of mechanisms which create confidence and effectively

answer people’s concern.

6.2 Proposed Disclosure Plan

As RRRRLP has been processed as an emergency operation, the World Bank procedures require that an ESMF is prepared and publicly disclosed within six months of effectiveness of the operation. Towards this end, this document(s) will be publicly released through the FAO Somalia Office and project sites, and in public locations in project implementation areas and at the Bank’s Infoshop for project appraisal. The

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documents should be made available in compliance with the World Bank’s Public Consultation and Disclosure Policy. 6.2.1 Disclosure of subproject EMPs EMPs prepared for subprojects under the RRRLP will also need to be disclosed to the public. Copies of the EMPs should be made available to communities and interested parties in accessible locations, through the local government authorities, i.e. local councils, district offices, etc. Copies of the EMPs should also be provided to the implementing agencies in each of the areas and submitted to FAO Somalia and the World Bank. This will ensure record keeping of all activities implemented under the ESMF, and ensure that the third-party audits have the adequate information required when undertaking the annual environmental audits. 6.3 Information and consultation means

i. Leaflets and Newsletters: Leaflets on the Project (related to key issues and schedule of implementation) will be disseminated (in both electronic and paper versions) to inform the general public.

ii. Workshops: Workshops will be held both at the district and local levels during the technical feasibility and EIA processes, to ensure appropriate information and its disclosure to the population and civil society. A report of each workshop will be available in the project office site and at the FAO offices.

iii. Public Hearings: In order to ensure that public is well informed and has the opportunity to express its opinions especially in sensitive matters (EA and relocation) should they be triggered public hearings will be held. The project, would organize transport from every part of the district to ensure that everybody has the possibility and means to attend the public hearing. Each public hearing will be recorded and followed by a public hearing report.

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References

1. FAO/EC. 2004. Somalia Water and Land Information Management System (SWALIM),

2. FAO/EU/World Bank. 2004. “Somalia: Towards a Livestock Sector Strategy.” Report No. 04/001 IC-SOM. 29 April. FAO, Rome.

3. Food and Agriculture Organization (Content source); Jim Kundell (Topic Editor). 2008. "Water profile of Somalia." In: Encyclopedia of Earth. Eds. Cutler J. Cleveland (Washington, D.C.: Environmental Information Coalition, National Council for Science and the Environment). [First published in the Encyclopedia of Earth May 25, 2007; Last revised May 14, 2008; Retrieved December 22, 2008]

4. World Bank, 1999, Bank procedures BP 4.01. Environmental assessment. The World Bank Operational Manual.

5. World Bank, 1999, Environmental Assessment Sourcebook and update – Operational Policies.

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Annex 1 Somalia Rapid Response Rehabilitation of Rural Livelihoods Project

Guidelines for Screening Projects

Project Screening Checklist

A. Irrigation subprojects

Indicator None

Low Med High Unknown

Existing water sources supply/yield depletion Existing water users disrupted Downstream water users disrupted Upsetting existing land tenure system Water storage requirement and viability (soil permeability)

Vulnerability to water logging (poor drainage) Vulnerability to soil and water salinization Loss or damage to wetlands, and their environmental services and biodiversity. Environmentally sensitive areas disturbed Cultural or religious sites disturbed Increased agric. chemicals (pesticides, etc) Increased social tensions over water allocation Local incapacity/inexperience to manage facilities

Local incapacity/inexperience with irrigated agriculture

Creating habitats in canals and ditches for disease carriers (mosquitoes/malaria) Other (specify):

B. Roads and foot paths Indicator None Low Med High Unknown

Soil erosion or flooding concerns (eg, due to highly erodible soils or steep gradients)

Number of stream crossings or disturbances Wet season excavation Creation of quarry sites or borrow pits Significant vegetation removal Wildlife habitats or populations disturbed Environmentally sensitive areas disturbed Cultural or religious sites disturbed

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New settlement pressures created Other (specify):

C. Slaughter house

Indicator None


New access (road) construction Existing water sources supply/yield affected

Existing water users disrupted Wastes disposed Downstream Sensitive ecosystems tempered with Local incapacity/inexperience to manage facilities

Local incapacity/inexperience with safe meat handling

Significant vegetation removal Involuntary resettlement New settlement pressures created Cultural or religious sites disturbed Other (specify):

D. Liquid and Solid Waste generation

Indicator None


Soil and water pollution due to seepage

Sludge disposed of indiscriminately and causing health risks

Incompletely treated waste water contaminating surface water streams

Sensitive ecosystems tempered with Local incapacity/inexperience to manage facilities

Animals accessing sewage ponds and transmitting diseases to people

Significant vegetation removal Erosion along banks of drainage channel causing siltation of channel and loss of land

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Other (specify):

RECOMMENDED ENVIRONMENTAL CATEGORY AS PER OP 4.01:

Category B2: A separate EIA report needs to be prepared.

Category B1: An EMP needs to be prepared

Category C: No additional environmental work is required

Category A: The sub-project will have to be re-designed and re-screened or dropped because the parent project is a category B project. Therefore, category A sub-projects cannot be funded.

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Environmental Management Plan (EMP) 1. A project’s environmental management plan (EMP) consists of the set of

mitigation, monitoring, and institutional measures to be taken during implementation and operation to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. The plan also includes the actions needed to implement these measures. Management plans are essential elements of EA reports for Category B2 projects; for many Category B2 projects, the EA may result in a management plan only. To prepare a management plan, the borrower and its EA design team (a) identify the set of responses to potentially adverse impacts; (b) determine requirements for ensuring that those responses are made effectively and in a timely manner; and (c) describe the means for meeting those requirements. More specifically, the EMP includes the following components. Mitigation

2. The EMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. Specifically, the EMP

(a) Identifies and summarizes all anticipated significant adverse environmental impacts;

(b) describes—with technical details— each mitigation measure, including the type of impact to which it relates and the conditions under which it is required, together with designs, equipment descriptions, and operating procedures, as appropriate;

(c) Estimates any potential environmental impacts of these measures; and

(d) Provides linkage with any other mitigation plans required for the project.

Monitoring

3. Environmental monitoring provides information particularly on the environmental impacts of the project and the effectiveness of mitigation measures. Such information enables the borrower and the Bank to evaluate the success of mitigation as part of project supervision, and allows corrective action to be taken when needed. Therefore, the EMP identifies monitoring objectives and specifies the type of monitoring. Specifically, the monitoring section of the EMP provides

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(a) a specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions; and

(b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures.

Capacity Development and Training 4. To support timely and effective implementation of environmental project

components and mitigation measures, the EMP draws on the EA’s assessment of the existence, role, and capability of environmental units on site or at the agency and ministry level. If necessary, the EMP recommends the establishment or expansion of such units, and the training of staff, to allow implementation of EA recommendations. Specifically, the EMP provides a specific description of institutional arrangements— who is responsible for carrying out the mitigatory and monitoring measures. To strengthen environmental management capability in the agencies responsible for implementation, most EMPs cover one or more of the following additional topics: (a) technical assistance programs,(b) procurement of equipment and supplies, and (c) organizational changes.

Implementation Schedule and Cost Estimates 5. For all three aspects (mitigation, monitoring, and capacity development),

the EMP provides (a) an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans; and (b) the capital and recurrent cost estimates and sources of funds for implementing the EMP. These figures are also integrated into the total project cost tables.

Integration of EMP with Project 6. The borrower’s decision to proceed with a project, and the Bank’s decision

to support it are predicated in part on the expectation that the EMP will be executed effectively. Thus, EMP must be integrated into the project’s overall planning, design, budget, and implementation. Such integration is achieved by establishing the EMP within the project so that the plan will receive funding and supervision along with the other components.

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Environmental Impact Assessment (EIA) Terms of Reference (TOR)

I. Introduction and context This section will be completed at the appropriate time, and will provide the necessary information with respect to the context and methodological approaches to be undertaken. II. Objectives of the study This section will (i) outline the objectives and particular activities of the planned subproject (e.g construction of slaughter house) and any other activities that will require a full EIA; and (ii) indicate which activities are likely to have environmental and social impacts that will require appropriate mitigation. III. Terms of Reference The consultant will perform the following tasks: (a) Carry out a description of the biophysical characteristics of the

environment in which subproject will be constructed, and highlight the major constraints that need to be taken into account during construction as well as during operation of the facility;

(b) Review socio-economic description and related impacts and recommend mitigation measures.

(c) Assess the potential environmental and social impacts due to construction or rehabilitation activities, and recommend mitigation measures as appropriate, including cost estimates;

(d) Assess the potential environmental and social impacts due to the provision of water supply and sanitation facilities that might be needed for the planned facility and make appropriate recommendations;

(e) Assess the need for liquid and solid waste collection, disposal and management in the facility, and make recommendations accordingly;

(f) Carry out a review of the Somalia national environmental policies, legislation, regulatory and administrative frameworks in conjunction with the World Bank’s ten safeguard policies, indicate which of these policies is triggered by the planned subproject, identify any gaps that might exist, and make recommendations as to how potential gaps should be bridged in the context of the planned activity;

(g) Review the Conventions and Protocols to which Somalia is a signatory;

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(h) Assess Somalia environmental assessment and management capacity, as well as the capacity to implement the proposed mitigation measures, and make appropriate recommendations, including potential capacity building and training needs, and their costs;

(i) Prepare an Environmental Management Plan (EMP) for the subproject. The EMP should outline (a) potential environmental and social impacts resulting from the subproject; (b) proposed mitigation measures; (c) institutional responsibilities for implementation of the mitigation measures; (d) monitoring indicators; (e) institutional responsibilities for monitoring the implementation of the mitigation measures; (f) cost estimates for these activities; and (g) time horizons for implementing the EMP.

(j) Public consultations. EIA results and proposed mitigating measures will then be shared with the potentially affected population, NGOs, local authorities and the private sector working in the area where the activity will take place. Minutes of this consultation will form an integral part of the report.

IV. Profile of the consultant The Consultant must have a post-graduate diploma in environmental impact assessment, social or environmental sciences with a 5-year experience in preparing EIAs. The consultant must provide enough references regarding his/her environmental and social impact assessment work. The consultant must be computer-literate. V. Duration and specialization The duration of the study will be determined according to the type of activity. VI. Production of the final report The consultant will produce a final report after receiving comments from the governance structures, the World Bank, the FAO and other parties interested in this study. The final report must take into account all these comments. VII. Supervision of the study The work of the consultant will be supervised by the project together with local committee and environmental agency responsible for EIAs.

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Environmental Guidelines for Contractors General Environmental Management Conditions

General: Applicability of These Environmental Guidelines and ESMP 1. These general environmental guidelines apply to any work to be undertaken under

the RRRRL Project. For certain work sites entailing specific environmental and/or social issues, a specific Environmental and Social Impact Assessment, including an Environmental and Social Management Plan (ESMP), has been prepared to address the above-mentioned specific issues in addition to these general environmental guidelines.

2. In addition to these general conditions, the Contractor shall comply with any specific Environmental Management Plan (EMP) for the works he is responsible for. The Contractor shall inform himself about such an EMP, and prepare his work strategy and plan to take into account relevant provisions of that EMP. If the Contractor fails to implement the approved EMP after written instruction by the project manager or designated officer within the requested time, the organization reserves the right to arrange for execution of the missing action by a third party on account of the Contractor.

3. Notwithstanding the Contractor’s obligation under the above clause, the

Contractor shall implement all measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore work sites to acceptable standards, and abide by any environmental performance requirements specified in an EMP. In general these measures shall include but not be limited to: (a) Minimize the effect of dust on the surrounding environment resulting

from earth mixing sites, vibrating equipment, temporary access roads, etc. to ensure safety, health and the protection of workers and communities living in the vicinity dust of producing activities.

(b) Ensure that noise levels emanating from machinery, vehicles and noisy construction activities (e.g. excavation, blasting) are kept at a minimum for the safety, health and protection of workers within the vicinity of high noise levels and nearby communities.

(c) Ensure that existing water flow regimes in rivers, streams and other natural or irrigation channels is maintained and/or re-established where they are disrupted due to works being carried out.

(d) Prevent bitumen, oils, lubricants and waste water used or produced during the execution of works from entering into rivers, streams,

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irrigation channels and other natural water bodies/reservoirs, and also ensure that stagnant water in uncovered borrow pits is treated in the best way to avoid creating possible breeding grounds for mosquitoes.

(e) Prevent and minimize the impacts of quarrying, earth borrowing, piling and building of temporary construction camps and access roads on the biophysical environment including protected areas and arable lands; local communities and their settlements. In as much as possible restore/rehabilitate all sites to acceptable standards.

(f) Discourage construction workers from engaging in the exploitation of natural resources such as hunting, fishing, and collection of forest products or any other activity that might have a negative impact on the social and economic welfare of the local communities.

(g) Implement soil erosion control measures in order to avoid surface run off and prevents siltation, etc.

(h) Ensure that, in as much as possible, local materials are used to avoid importation of foreign material and long distance transportation.

(k) Ensure public safety, and meet traffic safety requirements for the operation of work to avoid accidents.

4. The Contractor shall indicate the period within which he/she shall maintain status on site after completions of civil works to ensure that significant adverse impacts arising from such works have been appropriately addressed.

5. The Contractor shall adhere to the proposed activity implementation schedule and the monitoring plan / Strategy to ensure effective feedback of monitoring information to project management so that Impact management can be implemented properly, and if necessary, adapt to changing and unforeseen conditions.

6. Besides the regular inspection of the sites by the project manager/ designated officer for adherence to the Contract conditions and specifications, the project may appoint an Inspector to oversee the compliance with these environmental conditions and any proposed mitigation measures. State environmental authorities may also carry out similar inspection duties.

Material Excavation and Deposit 7. The Contractor shall obtain appropriate licenses/permits from relevant

authorities to operate quarries or borrow areas. 8. The location of quarries and borrow areas shall be subject to approval by

relevant local and national authorities, including traditional authorities if the land on which the quarry or borrow areas fall in traditional land.

9. New extraction sites:

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a) Shall not be located in the vicinity of settlement areas, cultural sites, wetlands or any other valued ecosystem component, or on high or steep ground or in areas of high scenic value, and shall not be located less than 1km from such areas.

b) Shall not be located adjacent to stream channels wherever possible to avoid siltation of river channels. Where they are located near water sources, borrow pits and perimeter drains shall surround quarry sites

c) Shall not be located in archaeological areas. Excavations in the vicinity of such areas shall proceed with great care and shall be done in the presence of government authorities having a mandate for their protection.

d) Shall not be located in forest reserves. However, where there are no other alternatives, permission shall be obtained from the appropriate authorities and an environmental impact study shall be conducted.

e) Shall be easily rehabilitated. Areas with minimal vegetation cover such as flat and bare ground, or areas covered with grass only or covered with shrubs less than 1.5m in height, are preferred.

f) Shall have clearly demarcated and marked boundaries to minimize vegetation clearing.

10. Vegetation clearing shall be restricted to the area required for safe operation of construction work. Vegetation clearing shall not be done more than two months in advance of operations.

Rehabilitation and Soil Erosion Prevention 11. To the extent practicable, the Contractor shall rehabilitate the site

progressively so that the rate of rehabilitation is similar to the rate of construction.

12. Always remove and retain topsoil for subsequent rehabilitation. Soils shall not be stripped when they are wet as this can lead to soil compaction and loss of structure.

13. Topsoil shall not be stored in large heaps. Low mounds of no more than 1 to 2m high are recommended.

14. Re-vegetate stockpiles to protect the soil from erosion, discourage weeds and maintain an active population of beneficial soil microbes.

15. To the extent practicable, reinstate natural drainage patterns where they have been altered or impaired.

16. Ensure reshaped land is formed so as to be inherently stable, adequately drained and suitable for the desired long-term land use, and allow natural regeneration of vegetation.

17. Compacted surfaces shall be deep ripped to relieve compaction unless subsurface conditions dictate otherwise.

18. Re-vegetate with plant species that will control erosion, provide vegetative diversity and, through succession, contributes to a resilient ecosystem. The choice of plant species for rehabilitation shall be done in

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consultation with local research institutions, forest department and the local people.

Water Resources Management 19. The Contractor shall at all costs avoid conflicting with water demands of

local communities. 20. Abstraction of both surface and underground water shall only be done

with the consultation of the local community and after obtaining a permit from the relevant Water Authority.

21. Abstraction of water from wetlands shall be avoided. Where necessary, authority has to be obtained from relevant authorities.

22. No construction water containing spoils or site effluent, especially cement and oil, shall be allowed to flow into natural water drainage courses.

Cost of Compliance 23. It is expected that compliance with these conditions is already part of

standard good workmanship and state of art as generally required under this Contract. The item “Compliance with Environmental Management Conditions” covers these costs. No other payments will be made to the Contractor for compliance with any request to avoid and/or mitigate an avoidable environmental and social impact(s).

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Annex 5: Somalia Rapid Response Rehabilitation of Rural Livelihoods Project

Land Acquisition Assessment

The Land Acquisition Assessment serves as a screening tool to determine any potential issues that might emerge in relation to land acquisition for sub-projects such as slaughter houses, roads, ancillary facilities etc. Based on the screening results, the qualified member of the review team in consultation with potentially affected persons and relevant partners will discuss whether to (a) redesign the sub-project to avoid the need for land acquisition; or (b) retain the original sub-project location and develop a comprehensive plan to compensate affected persons in accordance with OP 4.12 Involuntary Resettlement and the Banks procedures. Thus, as part of the environmental and social screening process, a qualified member of the review team will address the points below using the land acquisition assessment tool; the latter will be used to collect the following information: 1. Location of the site 2. Size of the site 3. Status of the site: Is the land owned privately, publicly, collectively? Does

someone hold a title to the land? Who is the legal owner of the land? 4. Present use of the land: Is it used for agricultural purposes? Is the land not

used by anybody? 5. Who currently benefits from the use of the land in question: Are the

current beneficiaries’ legal owners, renters, squatters, or do they hold legal contracts?

6. What is the value of the land, the structures that have been built on this land?

7. Who is donating/selling the site, and how is the donation/sales process to take place?

In the event that private land will be donated/sold, the qualified member of the review team will ensure that this transaction is documented to show that the land was donated/sold willingly; the document is signed and notarized by the donor/seller and counter-signed by the local administrator and the relevant project staff; and a copy of this document is placed in the files of the local administrator for future reference.

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World Bank Environmental and Social Safeguard Policies

• Environmental Assessment (OP 4.01). As expounded in Section 5.1 • Natural Habitats (OP 4.04). The conservation of natural habitats, like other measures that protect and enhance the environment, is essential for long-term sustainable development. The Bank does not support projects involving the significant conversion of natural habitats unless there are no feasible alternatives for the project and its citing, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs. If the environmental assessment indicates that a project would significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to the Bank. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g. strategic habitat retention and post-development restoration) and establishing and maintaining an ecologically similar protected area. The Bank accepts other forms of mitigation measures only when they are technically justified. Should the sub-project-specific EAs indicate that natural habitats might be affected negatively by the proposed sub-project activities, such sub-projects will not be funded under the proposed RRRRL project. • Pest Management (OP 4.09). As expounded in Section 5.1 • Involuntary Resettlement (OP 4.12). The resettlement policy is triggered when people are affected by loss of land, loss of property and/or loss of access to resources. It is therefore irrelevant whether or not the impact will entail physically relocation of the affected people, the policy is triggered in all such cases. This means that the impact may be of such kind that only compensation in cash or kind is necessary. • Indigenous Peoples (OP 4.10). This directive provides guidance to ensure that indigenous people benefit from development projects, and to avoid or mitigate adverse effects of Bank-financed development projects on indigenous people. Measures to address issues pertaining to indigenous peoples must be based on the informed participation of the indigenous people themselves. Sub-projects that would have negative impacts on indigenous people will not be funded under the proposed RRRRL project. • Forests (OP 4.36). This policy applies to the following types of Bank-financed investment projects: (a) projects that have or may have impacts on the health and quality of forests; (b) projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests; and (c) projects that

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aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned. The Bank does not finance projects that, in its opinion, would involve significant conversion or degradation of critical forest areas or related critical habitats. If a project involves the significant conversion or degradation of natural forests or related natural habitats that the Bank determines are not critical, and the Bank determines that there are no feasible alternatives to the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs, the Bank may finance the project provided that it incorporates appropriate mitigation measures. Sub-projects that are likely to have negative impacts on forests will not be funded under the proposed RRRRL project. • Cultural Property (OP 4.11). The term “cultural property” includes sites having archaeological (prehistoric), paleontological, historical, religious, and unique natural values. The Bank’s general policy regarding cultural property is to assist in their preservation, and to seek to avoid their elimination. Specifically, the Bank (i) normally declines to finance projects that will significantly damage non-replicable cultural property, and will assist only those projects that are sited or designed so as to prevent such damage; and (ii) will assist in the protection and enhancement of cultural properties encountered in Bank-financed projects, rather than leaving that protection to chance. The management of cultural property of a country is the responsibility of the government. The government’s attention should be drawn specifically to what is known about the cultural property aspects of the proposed project site and appropriate agencies, NGOs, or university departments should be consulted; if there are any questions concerning cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist. The proposed RRRRL project will not fund sub-projects that will have negative impacts on cultural property. • Safety of Dams (OP 4.37). For the life of any dam, the owner is responsible for ensuring that appropriate measures are taken and sufficient resources provided for the safety to the dam, irrespective of its funding sources or construction status. The Bank distinguishes between small and large dams. Small dams are normally less than 15 m in height; this category includes, for example, farm ponds, local silt retention dams, and low embankment tanks. For small dams, generic dam safety measures designed by qualified engineers are usually adequate. The proposed RRRRL project will not fund sub-projects that will impacts dams.

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• International waterways (OP 7.50). As expounded in Section 5.1. • Disputed Areas (OP 7.60). Project in disputed areas may occur the Bank and its member countries as well as between the borrower and one or more neighboring countries. Any dispute over an area in which a proposed project is located requires formal procedures at the earliest possible stage. The Bank attempts to acquire assurance that it may proceed with a project in a disputed area if the governments concerned agree that, pending the settlement of the dispute, the project proposed can go forward without prejudice to the claims of the country having a dispute. This policy is not expected to be triggered by sub-projects. This policy is unlikely to be triggered by sub-projects to be funded by the proposed RRRRL project.

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Pest Management Plan Guideline

Small-scale agricultural and livestock sub-projects in RRRRLP may involve strengthening existing practices, introducing, diversifying or the intensification of crop production. Support for the development of small-scale agriculture and certain livestock activities may lead to the introduction or increased use of pesticides and other agricultural chemicals such as herbicides and fertilizers. It is critical that appropriate planning, design and management be adopted for the handling, use, and management of all agricultural chemicals to avoid potential negative environmental impacts. For the sub-projects funded under RRRRLP, a pest management plan will address issues under the principal of Good Agricultural practices (GAP) including post harvest management. GAP are composed of a series of inter-related protocols, to apply in on-farm production and post-production processes designed to improve sustainability of crop production in the scenario of ever-increasing agro-ecological zone (AEZ) fragility and are aimed at meeting consumer needs for products that are of high quality, safe and produced in an environmentally and socially responsible way. GAP protocols require being informed on integrated production techniques for each of the major agro-ecological areas, thus to collect, analyze and disseminate information of good practices in relevant geographical contexts and relies on four principles (i) economically and efficiently produced sufficient, safe and nutritious products; (ii) sustain and enhance natural resources; (iii) maintain viable farming enterprises and contribute to sustainable livelihoods; (iv) meet cultural and social demands of society. GAP provides a means to assess and decide upon farming practices at each step in the production process. For any given agricultural production system, a sound and comprehensive management strategy must be in place providing for the capability for tactical adjustments in response to changes in circumstances. Implementing such a management strategy requires knowing, understanding, planning, measuring, monitoring, and record keeping, with the aim of achieving production, safety and sustainability goals. Successful implementation depends upon developing the skill and knowledge bases, on continuous monitoring and analysis of performance, and the use of expert advice as required. The process of developing and supporting the adoption of GAP is to:

• Formulate a set of generic practices and indicators from which guidelines for good agricultural practices for on-farm production and post-

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production systems can be developed, collaboratively by the public and private sectors and civil society

• Focus existing knowledge, options, and solutions into effective product safety and environmental risk analysis guidelines available for use as policy instruments

• Review existing codes of practice • Translate codes of practice into management guidelines for crop and

livestock systems in specific agro-ecological zones. • Engage in discussion with governments on their strategies, priorities and

instruments to move towards sustainable agriculture and rural development practices.

The project will promote five practices that are considered the ‘core’ of on-farm GAP that are promoted by FAO as part of its overall programme in technical assistance and capacity building for agriculture development, poverty alleviation, food security, environmental services, and natural resources management. Conservation Agriculture (CA): Consists of three interlinked principles which have to be in place simultaneously or obtained gradually: minimal or no soil disturbance, permanent and maximum soil cover and crop rotations or associations/diversification. The outcome of well-applied CA provides the base for sustainable and profitable agriculture if combined with other elements of GAP. It subsequently aims at improved livelihoods of farmers. Integrated Production and Protection Management (IPPM): The objective of IPPM is to reduce the use of and the reliance on pesticides to control pest and diseases. This is achieved through the growing of adapted cultivars, combined with appropriate cultivation practices and production technologies. In this way IPPM is a further development of Integrated Pest Management (IPM) expressing a stronger integration into the entire crop management, with the objective to reduce and where possible eliminate the use of pesticides by the application of suitable crop management practices. The tenet followed focuses on six control areas;

• Cultural pest control; the manipulation of sowing and harvest dates to minimize damage, intercropping, vegetation management to enhance natural processes, crop rotation and tillage systems.

• Host plant resistance; the breeding of crop varieties that are less susceptible to pests.

• Biological control; the conservation and manipulation of natural enemies; the introduction of exotic natural enemies and the use of microbial pesticides.

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• The rational use of chemical pesticides with economic thresholds. • Mechanical control; use of tools or machinery; especially important for

weed control. • Legal control; the enforcement of measures and policies that control the

utilization of pesticides. Integrated Plant Nutrition Systems (IPNS): The concept of IPNS takes into consideration the nutrient cycle involving soils, crops and livestock, nutrient deficiencies, organic recycling, conjunctive use of organic manures and mineral fertilizers and biological nitrogen fixing potential. Of particular importance are not only the values of nutrients in the soil, but the relations between different groups of elements to achieve healthy and balanced plant nutrition. Nutrient dynamics in soils, the availability and accessibility of nutrients depends also of other soil characteristics, such as structure, moisture, biological activity and organic matter. Integrated Weed Management (IWM): The aim of IWM is to use a combination of different practices to maintain weed densities at manageable levels. An integrated weed management approach to land management combines the use of complementary weed control methods such as grazing, herbicide application, land fallowing and biological control. Farmer Field Schools (FFS): The FAO Farmer Field School (FFS) is a group-based learning process that has been used by a number of governments, NGOs and international agencies to promote IPM. FFS approach is increasingly used for learning and adoption of IPM, CA and other practices in Africa and in other regions. Training Sessions Below is a summary of training modules to be provided to trainers, extensionists and the Somali farmers in order to grow better crops, avoid poisoning by pesticides and increase production.

- Overview on IPPM principles - Pests and diseases in agriculture production and post harvest - Conventional pest management practices in Somalia - IPM in agriculture production and post harvest - Handling of chemicals - Major insect pests of stored cereal and pulse grains and their control

For further reading and Application, Please contact the FAO Plant protection department and the FAO Sub-regional Plant protection officer.

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ESMF Preparation Team Assignment was carried out by

1. Meshack O. Malo Team Leader Integrated Natural Resources Officer FAO Sub-regional Office for Eastern Africa (SFE) Addis Ababa- Ethiopia [email protected]

2. Jan Breithaupt Plant Production and Protection Officer FAO Sub-regional Office for Eastern Africa (SFE)

Contribution received from:-

3. Sergio Innocente Project Manager - RRRRLP FAO- Somalia

4. Laxman Reddy MSR Operations Manager - RRRRLP FAO- Somalia

5. FAO- Eastern Africa Multi-disciplinary team Addis Ababa Ethiopia

6. FAO Somalia Staff Somalia and Nairobi offices