Post on 09-May-2018
transcript
reve
ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (Draft Report)
For
The Liberia ACE Cable Landing Project
Prepared by:
Environmental Resources Managers Limited Plot 107A Imam Abibu Adetoro Street Off Ajose Adeogun Street Victoria Island Lagos, Nigeria
November, 2010
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Pub
lic D
iscl
osur
e A
utho
rized
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
ii November, 2010
TABLE OF CONTENTS
Table of Contents
List of Tables
List of Figures
Executive Summary xi
CHAPTER ONE: BACKGROUND AND INTRODUCTION 1
1.1 Introduction 1 1.2 Project Objective 2
1.3 Program Description 2
1.4 Structure of the Report 4
CHAPTER TWO: ENVIRONMENTAL AND SOCIAL
MANAGEMENT FRAMEWORK; OBJECTIVES AND
SCOPE OF WORK 5
2.1 ESMF Objectives 5
2.2 Scope of Work 6
CHAPTER THREE: METHODOLOGY 8
3.1 Data Gathering 8
3.2 Environmental and Social Screening Tool 8
3.3 Environmental Impact Analysis 9
3.4 Mitigation Measures 9
3.5 Environmental Management Plan 9
3.6 Capacity Building and Training 9
CHAPTER FOUR: POLICY AND REGULATORY FRAMEWORK 10
4.1 National Environmental Legislation 10
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
iii November, 2010
4.1.1 The Liberian National Constitution (1986) 10
4.1.2 The National Environmental Policy 10
4.1.3 The Liberian Environmental Protection Agency (EPA) Act 12
4.1.3.1 The EPA EIA Process 12
4.1.4 The Land Use Act (1929) 13
4.1.5 The Liberian Labour Law 13
4.2 International Environmental Legislation 14
4.2.1 The IMO Convention for Prevention of Pollution from Ships 14
4.2.2 UN Convention on Law of the Sea 14
4.3 International Labour Laws 15
4.4 The Core Labour Standards 15
4.5 World Bank Policies 16
4.5.1 Triggered World Bank Policies 16
4.5.2 Other World Bank Policies 18
4.6 Adequacy of Environmental Legislation 19
CHAPTER FIVE: PROJECT DESCRIPTION 20
5.1 Project Overview 20
5.2 Project Justification 21
5.3 Benefits of the Project 22
5.3.1 Direct Benefits 22
5.3.2 Indirect Benefits 22
5.4 Cable Description 23
5.5 Cable Technology 25
5.6 Repeaters and Branching Units 26
5.7 Landing Sites 26
5.8 Project Alternatives 26
5.8.1 Technology Alternatives 26
5.8.2 Routing Alternatives 27
5.8.3 Landing Site Alternatives 27
5.9 Project Phases 31
5.9.1 Construction Phase 31
5.9.2 Operations Phase 33
5.9.3 Repair /Recovery Activities 34
5.9.4 Decommissioning Phase 34
5.10 Cable Laying Personnel 34
5.11 Project Schedule 35
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
iv November, 2010
CHAPTER SIX: ENVIRONMENTAL CHARACTERISITCS OF THE
PROJECT AREA 36
6.1 Geographical Location 36
6.2 Topography 38
6.3 Geology and Soils 38
6.4 Climate 38
6.5 Marine and Coastal Wildlife 39
6.5.1 Marine Species 40
6.6 Threats to Coastal and Marine Resources 41
6.7 Governance 41
6.8 Ethnic Groups 42
6.9 Culture 43
6.10 Religion 44
6.11 Macro Economy and Livelihood 45
6.12 Health Situation 46
CHAPTER SEVEN: STAKEHOLDER AND ENGAGEMENT AND
PUBLIC DISCLOSURE 47
7.1 Stakeholder Identification 47
7.2 Stakeholder Engagement Phases 49
7.3 General Guidelines for Stakeholder Engagement 50
7.4 ESMF Disclosure 50
CHAPTER EIGHT: ENVIRONMENTAL IMPACT ASSESSMENT 51
8.1 Positive Impacts 51
8.2 Potential and Associated Adverse Impacts 51
CHAPTER NINE: IMPACT MITIGATION 55
9.1 Introduction 55
9.2 Project Mitigation Principles 56
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
v November, 2010
CHAPTER TEN: ENVIRONMENTAL AND SOCIAL
MANAGEMENT IMPLEMENTATION PROCESS 60
10.1 Overview of ESMF Implementation Process 60
10.2 Project Screening and Categorization 61
10.2.1 Categorization for EIA 61
10.2.2 Applicable Standards, Limits and Permit Requirements 62
10.2.3 Screening Report 63
10.3 Preparation of EIA Reports 63
10.4 Environmental Management Plan 63
10.4.1 Policy 64
10.4.2 Environmental and Social (E &S) Management Department 64
10.4.3 Training 65
10.4.4 Communications 66
10.4.5 Monitoring and Reporting 67
10.5 Budget to Implement ESMF 67
APPENDICES Appendix 1 Documents Consulted 70 Appendix 2 Illustrated EPA EIA Process 71 Appendix 3 Guidelines for Preparing Terms of Reference for an
Environmental Impact Assessment (EIA) Study 72
Appendix 4 List of Participants at Stakeholder Workshops and Meetings 79
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
vi November, 2010
LIST OF TABLES
Table 4-1: Summary of Other Key International Environmental Agreements,
Treaty, Convention, Regulation Ratified By Liberia 14
Table 4-2: Labour Convention/Treaty Ratified by Liberia 15
Table 5-1: Submarine Telecommunication Cable Types 24
Table 6-1: Ethnic Groups and Tribes of Liberia 42
Table 7-1: ACE Cable Project in Liberia - Stakeholder Categories 48
Table 8-1: Types of Project -Related Occupational and Public Health
Hazards 54
Table 9-1: Impact Mitigation Principles for Sub Project Activities 56
Table 10-1: Elements of Environmental and Social Management Process 60
Table 10-2: Project Categorization Checklist for EA 61
Table 10-3: Roles and Responsibility of Environmental and Social Management
Officer 65
Table 10-4: Estimated Annual Budget to Implement ESMF 67
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
vii November, 2010
LIST OF FIGURES
Figure 5-1: Cable Design Types 24
Figure 5-2: Modern Submarine Cable 25
Figure 5-3: Location of Landing Site Alternatives in Monrovia 29
Figure 5-4: Picture of Preferred Landing Site 29
Figure 5-5: Alternative Site Along 17th Street, Sinkor 30
Figure 5-6: Alternative Project Site around Fish Market 30
Figure 5-7: Alternative Project Site along Benard Beach, Congo Town 30
Figure 5-8: Typical Submarine Ploughs 33
Figure 6-1: Location of Liberia in Africa 36
Figure 6-2: Location of Liberia among Neighbouring Countries 37
Figure 6-3: Liberian Counties 37
Figure 6-4: Annual Climate Distribution of Liberia 39
Figure 6-5: Flow Chart of Local Administration 42
Figure 6-6: Distribution of Liberian Ethnic Groups Across the Country 43
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
viii November, 2010
LIST OF ACCRONYMS
ACE - Africa Coasts to Europe
BTC - Barclay Training Centre
Bus - Branching Units
BPEO - Best Practice Environmental Options
C&MA - Construction and Maintenance Agreement
CBD - Convention on Biological Diversity
CBO - Community Based Organisations
CCL - Cable Consortium of Liberia
CEO - Chief Executive Officer
CLS - Core Labour Standards
CSO - Civil Society Groups
E&S - Environmental and Social
EA - Environmental Assessment
ECOWAS - Economic Community of West African States
EEZ - Exclusive Economic Zone
EIS - Environmental Impact Study
EPA - Environmental Protection Agency
ESIA - Environmental and Social Impact Assessment
ESMF - Environmental and Social Management Framework
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
ix November, 2010
FONSI - Finding of No Significant Impact
GBPS - Gigabits per second
GEF - Global Environmental Facility
GHG - Green House Gas
GoL - The Government of Liberia
HIV/AIDS - Human Immuno deficiency Virus/ Acquired Immune
Deficiency Syndrome
ICT - Information and Communications Technology
IFC - International Finance Corporation
IMO - International Maritime Organisation
LCIP - Liberia Communications Infrastructure Program
LIBTELCO - Liberian Telecommunications Corporation
LMA - Liberian Maritime Authority
LTA - Liberia Telecommunications Authority
MDG - Millennium Development Goals
NGOs - Non Governmental Organisations
PIU - Project Implementation Unit
PPP - Polluter Pays Principle
ROV - Remotely Operated Vehicle
RPF - Resettlement Policy Framework
SAT-3 - South Atlantic-3
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
x November, 2010
SR - Screening Report
TOR - Term of Reference
UN - United Nations
UNCLOS - United Nations Convention on the Law of the Sea
UNDP - United Nations Development Programme
WARCIP - West Africa Regional Communications Infrastructure Program
WARCIPLP - West African Regional Communications Infrastructure Program
Liberia Project
WDM - Wavelength Division Mulitplexing
WGB - World Bank Group
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xi November, 2010
EXECUTIVE SUMMARY
ES 1 - BACKGROUND AND INTRODUCTION
The Government of Liberia in its plan to improve communication in the country and
international connectivity with the rest of the world, is planning to link to the ACE
submarine fibre optic cable, which is an approximately 17,000 km submarine cable
system, connecting South Africa to Europe and potentially connecting up to 24
countries including a landing station in Liberia.
Towards successful actualization of this goal, the government formed the Cable
Consortium of Liberia (CCL) to own and operate the ACE landing station in Liberia.
The benefit of the Liberia Communications Infrastructure Program (LCIP) will be
significant, as a direct access to broadband will set the foundation for digital
revolution.
The Project is supported by the World Bank as part of the Bank‟s West Africa
Regional Communications Infrastructure Program (WARCIP), which seeks to
contribute to lowering the cost and improving quality of regional and international
connectivity across the region.
The overall objective of the project is to improve communication in the country. In
order to achieve this objective, the project will focus on improved connectivity
through the connection of a submarine cable communications network in the
country, address missing infrastructure link, and create an enabling environment
and institutional strengthening to remove existing bottlenecks.
Although the details of the project implementation are yet unknown, it is timely to
develop and design a structure to address possible adverse effects of anticipated
project-environment interactions. To this end, the World Bank‟s environmental and
social safeguards policies require that the recipient country prepare an
Environmental and Social Management Framework (ESMF) (consistent with national
laws, any applicable treaty concerning international waters, and OP 4.01) and a
Resettlement Policy Framework (RPF) for the lateral cables and any associated
equipment that will be laid from the junction with the main cable through territorial
waters and onto the national shores.
ES2 – OBJECTIVES OF THE ESMF
This Environmental and Social Management Framework seeks to provide a clear
process including action plans to integrate environmental and social considerations
into the implementation of the ACE project in Liberia.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xii November, 2010
ES 3 - POLICY AND REGULATORY FRAMEWORK
In Liberia, there are a few National laws, policies, regulations and standards, which
seek to protect the natural environment and assure sustainable development in the
country. These include the provisions of Liberian National Constitution (1986), the
National Environmental Policy and the EPA Act of 2002.
The country is also a signatory to some international conventions, treaties and
agreements that seek to protect the environment. Examples include the United
Nations Convention of Law of the Sea, Convention on Biological Diversity, the
Kyoto Protocol, Ramsar Convention on Wetlands and some Labour Agreements.
The World Bank policies that have been triggered by the Project are:
- Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental
Assessment.
- Operational Policy/Bank Procedure 4.04 - Natural Habitat
- Operational Policy/Bank Procedure 4.36 - Forests.
- Operational Policy /Bank Procedure 4.11 - Physical Cultural Resources
- Operational Policy 4.12 - Involuntary Resettlement
-
ES4 - PROJECT DESCRIPTION
Overview
The Government of Liberia (GoL) in its plan to improve communication in the country
and international connectivity with the rest of the world, is planning to link to the ACE
submarine fibre optic cable. Towards successful actualization of this goal, the
government formed the Cable Consortium of Liberia (CCL) to own and operate the
ACE landing station in Liberia. CCL is a technology company that is partly owned by
the Government of Liberia, LIBTELCO, Lonestar Communications and Cellcom.
The submarine cable will be deployed over 17,000 km and will provide access to
more than 24 countries starting in 2012. It will include a new open-access fibre optic
submarine cable, which will expand international telecommunications services to
countries in the Atlantic Coast of Africa. It is envisaged that the system will facilitate
data transmission, voice, internet and television signals, allowing for inter country
transmission of information. With a planned capacity of about 1.92 Tbit/s, the ACE
system will provide sufficient and redundancy capacity for the future country needs.
Implementation of the ACE Cable Project in Liberia includes 3 distinct components;
i. A deepsea cable laying in the international waters from France to Liberia;
ii. a connecting cable from the submarine or deep sea cable to the shores of
Liberia in Monrovia; and
iii. A landing or cable station in Monrovia
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xiii November, 2010
Project Justification
Currently the SAT-3 system is the only international fibre optic cable serving the
West African coast since April 2002. Liberia could not be part of the SAT-3 system
primarily because of the 14 year civil unrest, which ended in 2003. Further, the
capacity on the SAT-3 system is severely constrained. The system currently has an
overall capacity of 120 gigabits per second (Gbps).
The ACE project is also in consonance with Target 8.F of the UN Millennium
Development Goals (MDG), which recognizes that:
Demand grows daily for information and communications technology;
Access to the World Wide Web is still closed to the majority of the world‟s
people; and
A large gap separates those with high-speed Internet connections, mostly in
developed nations, and dial-up users
Target 8.F therefore seeks to make available benefits of new technologies, especially
information and communications in cooperation with the private sector
Project Benefits
The direct benefits of the project include:
i. Increase in available international transmission capacity and the lower cost
for such access;
ii. Faster and more reliable transmission for data and voice as a result of
increased capacity and lower access cost;
iii. Improved business performance while creating additional opportunities for
business expansion;
iv. Improved mobile telecommunications availability across the country; and
v. Improved local content participation in the ICT industry, capacity building
and technology transfer.
The indirect benefits are those derived from the direct benefits earlier listed and
include:
i. Better economic integration of, and cooperation among African State
countries and linkage to global economy;
ii. Catalyzed start-up of new businesses;
iii. Support for gender-related advocacy and program activities;
iv. Exchange of experience and technical expertise with international community
and internally across various business sectors;
i. Expansion of technology-based into Liberia; and
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xiv November, 2010
ii. Employment generation and better inclusion of low-income communities in
ICT education.
Cable Description and Technology
The proposed cable system will comprise an optical fibre submarine
communications cable to carry telecommunications between France and Liberia. An
optical fibre is a glass or plastic fibre that carries light along its length. Optical fibres
are widely used in fibre-optic communication. They permit transmission over longer
distances and at higher data rates than other forms of communications.
The ACE system will deploy wavelength division multiplexing (WDM) technology,
which is currently the most advanced for submarine cables. With WDM, cable
capacity can be increased without additional submarine work. With an overall
potential capacity of 5.12 Tbit/s, the system will support the 40 Gbit/s technology at
day 1.
Cable Landing Site
A number of locations are being considered as options for the ACE Cable landing
site in Monrovia including:
Option 1: A 400-500m stretch of unencumbered land along Monrovia beach
immediately south of the Ministry of Defense Headquarters. The stretch has
no residents, squatters and fishing activities, but is only used by natives for
soccer.
Option 2: A portion of the beach within a well built area of Monrovia – this is
stretch of beach immediately southward of a slightly dense built up area also
in the city. The buildings along this stretch are about 40 – 50m from the beach.
Option 3: A portion of the Monrovia beach near shanty towns. The very poor
people live on both sides of a canal and derive their livelihood from the area.
Option 4: A portion of the beach used for landing fish by fisher folks.
Final selection of the landing site will however be done once necessary consultations
have been completed and clearances have been obtained.
Project Alternatives
Technology, Routing and Landing Site alternatives are being considered to
determine which location, technology process or other aspect of the project are best
in terms of cost-benefit, overall project objectives, environmental and social
sustainability.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xv November, 2010
Project Phases
The project will be implemented in three main phases:
Construction
The construction phase includes pre-installation activities which comprise cable
route geotechnical and geophysical survey to investigate the most cost effective and
safest possible environment for the cable and prepare for its installation followed by
cable engineering design. Cable installation will then be carried out by ploughing in
deeper marine sections while trenching options are likely to be used for shallower
areas. The cable will be installed using a special built ship, which accurately places
cables on or under the seabed along the route determined by the pre-installation
survey.
Operations
Once in place and connected, the cable system requires no intervention. Power is
provided to the system through electrical connection in the cable. This also provides
power to the repeaters. The electrical current is fully shielded from the environment.
During operations, cable repair or maintenance activities may be carried out as
required.
Decommissioning
As cables reach the end of their design life or become redundant due to technological
advances, their removal from the seabed or decommissioning may be considered. In
the case of a buried cable, its removal may result in some disturbance or impact.
ES5 – ENVIRONMENTAL AND SOCIAL CHARACTERISTICS OF THE
PROJECT AREA
Project Location
The ACE Submarine project will be implemented within deep and shallow marine
waters of Liberia, and a shore location along the coast of metropolitan Monrovia.
Liberia is located on the west coast of Africa and is bordered on the north by Guinea,
on the east by Côte d‟Ivoire, on the south and southwest by the Atlantic Ocean, and
on the northwest by Sierra Leone.
Monrovia is the capital and the country‟s largest city. It is located in the Montserrado
County. Monrovia has an estimated population of about 1.5 million inhabitants.
Liberia is divided into 15 counties with an estimated country wide population of 3.5
million. The project landing site is located in the Montserrado county.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xvi November, 2010
Topography
The proposed project will occur in the region of Liberia known as the flat Coastal
Plain. It is the land region of the country just next to the Atlantic Ocean. Indeed, the
selected landing site is less than 50 meters from the Atlantic Ocean.
Geology and Soils
The project area is located in what is known as the Pan African Age Province. The
rock type in this region is less than 500 million years. There is a zone of fluvial and
deltaic deposit which extends from the Freeport of Monrovia. This zone comprises
buff silt and sand deposits, which are characteristic of very low terrain along the
coast. The preferred landing site is composed mainly of beach sand, nearly pure
white quartz sand, less than 5 meters in thickness and above sea level.
Climate
As is the case with the rest of Liberia the climate of the project area is tropical and
humid, with little change in temperature throughout the year. The temperature
rarely exceeds 36oC (97oF) or falls below 23oC (73.4oF), with a mean annual
temperature of about 26oC (78.8oF). The climate is characterized by a monsoon (wet)
season and a dry season. The monsoon season extends from late April through
October, with the majority of the rainfall occurring between mid-April and mid-
October. During this time frame the average humidity is about 82%. The dry season
extends from mid-October to mid-April.
Marine and Coastal Wildlife
Liberia animal life is exceptionally diverse, with a high population of species that are
endangered outside the country. There are approximately 125 mammal species, 590
bird species, 165 native fish species, 74 unknown reptiles and amphibians and over
1000 described insects species in Liberia.
The rich wildlife population of the coastal area is currently threatened by two major
factors: first, loss and fragmentation of habitat caused by deforestation resulting
from uncontrolled logging, construction of logging road network, and slash-and
burn agriculture. Secondly, marine wildlife remains a critical source of protein for
rural Liberians, as well as a cash income earner.
Four of the seven remaining species of marine turtles in the world can be found in
Liberia where they lay eggs at selected places along the shores. The four species are
the Atlantic Green Turtle Chelonian Mydas), the leather back (Dermochelys
Coriacea), the Hawksbill (Eretmochelys Imbricate) and the Olive Ridley
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xvii November, 2010
(Lepidochelys Olvacea). The Green Turtles are classified as endangered and the
Hawksbill. Turtles are classified as critically endangered (WCMC, 1996).
Governance
Liberia has a Republican form of government, similar to that of the United States of
America. There are three (3) branches of government: the Executive, the Legislative
and the Judicial Branches. The Legislative Branch is responsible for making law and
legislations; the Judiciary is responsible for interpreting laws and operates the court
systems; and the Executive is responsible for the management and enforcement of
laws of the country.
The Ministry of Internal Affairs through its Superintendents administers the fifteen
(15) counties of Liberia, assisted by other local officials. The Superintendent is
appointed by the President of Liberia, along with the Development Superintendent
and Commissioners. The Paramount chiefs, Clan Chiefs and Town chiefs are elected
by the people in keeping with the laws of Liberia
Ethnic Groups
Liberia is comprised of approximately seventeen (17) major tribal groups divided
into five categories namely; Mel, Kwa, Mande-fu, Mande-tan and English speaking.
The majority of the tribal people of Liberia emigrated from ancient empires in West
Africa, namely Ghana, Songhai and Mali Empires. As these empires failed and
internal and regional conflicts ensued, the tribal people migrated toward the south
and settled in what is today Liberia. The English-speaking people were however
descendents of former slaves brought from the United States of America
Culture
The culture of Liberia reflects this nation's diverse ethnicities and long history.
Liberia was founded by freed slaves that returned from the United States of America
and other areas. However, before the coming of the freed slaves, the land area of
Liberia was inhabited by people from the ancient empires of West Africa.
The official language of Liberia is English. There are also more than 16 indigenous
languages, a few of which have their own unique alphabets.
Religion
Liberia was established by freed slaves returning from the United States of America.
Most of those returning were Christians. Upon their interaction with natives, they
evangelized them, thus raising the Christian population. Interaction with European
sailors and missionaries also led to Christianization of Liberia.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xviii November, 2010
Liberia has always been recognized as a Christian country, but the Constitution of
1986 presents Liberia as a secular nation.
Macro Economy and Livelihood
Liberia is one of the world's poorest countries, with a formal employment rate of
only 15%. Historically, the Liberian economy depended heavily on iron ore and
rubber exports, foreign direct investment, and exports of other natural resources,
such as timber. Agricultural products include livestock (goats, pigs, cattle) and rice,
the staple food. Fish are raised on inland farms and caught along the coast. Other
foods are imported to support the population.
Liberia continues to suffer with poor economic performance due to a fragile security
situation, the devastation wrought by its long war, its lack of infrastructure, and
necessary human capital to help the country recover from the scourges of conflict
and corruption.
Health Situation
Many years of civil crisis adversely affected Liberia in various respects, including the
health sector. This sector experienced extensive destruction of its infrastructure, the
displacement of health personnel, the massive looting and destruction of equipment,
including drugs and medical supplies.
Malaria, diarrhea, acute respiratory infections, neonatal tetanus, measles and
malnutrition are the major causes of morbidity. Malaria is the leading cause of death
and accounts for over 40% of all cases dealt with in health facilities. Those with the
highest risk to malaria are pregnant women, children and people with compromised
immunity such as those living with HIV/AIDS.
ES 6 - STAKEHOLDER ENGAGEMENT AND PUBLIC DISCLOSURE
The LTA recognizes that stakeholder involvement is an important element of the Ace
Cable Project and the EA process and that stakeholder identification and analysis at
an early stage of a project is critical in the assessment of interests, concerns,
relationships, assumptions, their level of influence and the ways in which they affect
project risks.
Through wide consultation therefore, the LTA sought to achieve public involvement
for better and more acceptable decision-making especially with regard to the
sustainability, scope, significance and mitigation of adverse project impacts.
Consultation and stakeholder engagement have been pursued positively with the
aim of utilizing outputs to assure the overall project sustainability and improve
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xix November, 2010
environmental management planning. Additionally, it is anticipated that early
consultation as embarked upon by the LTA will lay the foundation for ongoing
positive relationships on the project among the variety of stakeholders. Stakeholder
engagement involved planning and implementation stage activities.
This ESMF and copies of the environmental reports on the project will be made
available to the public at selected locations for information and comments. Members
of the public will be notified of report displays through electronic and print media.
Such notification should provide:
Title and brief description of the Project;
List of venues where the ESMF report is on display and available for viewing;
Duration of the display period; and
Contact details and procedure for comments
ES - 7 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT
Positive Impacts
If successfully implemented, the ACE Cable project is set to provide a number of
direct and indirect benefits to Liberia. Although anticipated benefits will be in the
area of economic growth and improved human development, some environmental
benefits are expected.
Potential and Associated Adverse Impacts
Adverse impact analysis of the ACE Cable Project in Liberia has been carried out
using typical, known project activities and how they interact with the environment.
Impact analysis has involved impact identification and qualitative assessment using
indicators. Possible impacts of the project include those arising from the with the
following biophysical and social components of the environment.
- Air Quality
- Landscape and Visual Receptors
- Noise and Vibration Receptors
- Transportation
- Geology and Soils
- Marine Biology and Fisheries
- Vulnerable Groups
- Cultural Heritage
- Infrastructure
- Economic Activities
- Solid Wastes Generation and Handling
- Population
- Labour
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xx November, 2010
- Occupational and Public Health
ES 8 - MITIGATION MEASURES
Mitigation measures, which are actions taken to enhance positive impacts and
minimize negative ones have been recommended for the ACE Cable Project.
Impact mitigation measures proffered in this report are general guidelines for
dealing with the project impacts. In recommending mitigation measures and as has
been considered appropriate and practical, the following principles have been taken
into consideration.
Design changes
Avoidance
Preservation
Minimization
Rehabilitation
Restoration
Replacement
Resource compensation
Improvement
Development
Diversification
It is noted that the application of each mitigation measure will be affected by
specifics of the project implementation and environmental and social nuances that
are documented from future studies.
ES - 9 - IMPLEMENTING THE ESMF
This ESMF document incorporates a number of elements into an overall
Environmental and Social Management process for the ACE Project. The process
involves distinct steps and associated activities that are linked to deliver a robust
and veritable management framework in line with the stated objectives of the ESMF
Project Screening and Categorization
The Ace Cable Project will be required to go through Environmental and Social
(E&S) Screening in accordance with World Bank and the Liberian EPA procedures.
The screening process will involve an assessment of the project to determine the
appropriate project categorization EA and applicable World Bank environmental
and social safe guards. Although it has been Categorized as B by the World Bank the
project should be screened to confirm category when project details become known.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
xxi November, 2010
The Screening Report will among other things, establish the EA categorization, and
environmental and social performance standards applicable to a particular sub-
project. All EA studies will be required to comply with the EIA procedural
guidelines of the Liberia EPA.
Environmental Management Plan
The Environmental Management Plan (EMP) provides the procedures and processes
that will be incorporated into the CCL activities to check and continuously monitor
compliance effectiveness of commitments on mitigation and enhancement measures.
In addition, the EMP focuses on policy, management personnel, competence
building, communications with the public and monitoring and is used to ensure
compliance with statutory requirements on safety and environmental issues.
Budget to Implement ESMF
To achieve the stated goals of this ESMF, it is important to identify financial resource
requirements even if indicative. This ensures upfront appreciation of the financial
requirements and allows early planning and budgeting accordingly.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
1 November, 2010
CHAPTER ONE
BACKGROUND AND INTRODUCTION
1.1 Introduction
The Government of the Republic of Liberia (GoL) has received a Project Preparation
Advance (No Q-723) from the World Bank toward the cost of the West Africa
Regional Communications Infrastructure Program – Liberia Project (WARCIPLP),
and intends to apply part of the proceeds for consultant services. The services
include advising the Liberia Telecommunications Authority (LTA) on the necessary
regulatory instruments (e.g., license, interconnection agreements, capacity sale/lease
agreements) to enable the Cable Consortium of Liberia (CCL) to effectively operate
the landing station and to distribute capacity on “open access” terms, as required by
the Africa Coast to Europe (ACE) Construction & Maintenance Agreement (C&MA)
and distribute broadband services more widely within Liberia in accordance with
Government‟s policy for ICT.
As part of its effort to promote regional co-operation and integration, and to create a
unified economic space, Economic Community of West African States (ECOWAS)
member states are committed to the development of a sustainable regional West
African telecommunications market to increase connectivity through the region. The
West Africa Regional Communications Infrastructure Program seeks to contribute to
lowering the cost and improving quality of regional and international connectivity
by facilitating i) the connection of all countries in West Africa to global broadband
fiber optics infrastructure, and ii) the creation of a coordinated regional and national
transmission network which would ensure that all countries in West Africa are able
to connect effectively within and between national borders.
The Government of Liberia in its plan to improve communication in the country and
international connectivity with the rest of the world, is planning to link to the ACE
submarine fibre optic cable, which is an approximately 17,000 km submarine cable
system, connecting South Africa to Europe and potentially connecting up to 24
countries including a landing station in Liberia. Towards successful actualization of
this goal, the government formed the Cable Consortium of Liberia (CCL) to own and
operate the ACE landing station in Liberia. The benefit of the Liberia
Communications Infrastructure Program (LCIP) will be significant, as a direct access
to broadband will set the foundation for digital revolution.
The involvement of the World Bank follows on from extensive contributions made
by the Bank to date in the country and the ECOWAS Connectivity Program fits well
with World Bank Group‟s (WBG) strategy in the region. The WBG is well placed to
support the region and Liberia in pushing for key reforms and strategies for
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
2 November, 2010
harmonizing policy and regulatory frameworks, mobilizing private investment,
structuring PPPs, as well as leveraging existing infrastructure investment in Africa.
The IFC has gained a good reputation for its expertise in structuring PPPs for
telecom transactions at both the national and regional levels.
The LCIP will have a positive impact on the overall growth of the economy. At the
microeconomic levels ICT investment will reduce transaction costs, increase market
coverage and competitiveness and create significant opportunities for job creation
and income generation. In addition, it will foster economic growth and development
through affordable, reliable and seamless regional communication (voice and data
services).
1.2 Project Objective
The overall objective of the project is to improve communication in the country. In
order to achieve this objective, the project will focus on improved connectivity
through the connection of a submarine cable communications network in the
country, address missing infrastructure link, and create an enabling environment
and institutional strengthening to remove existing bottlenecks.
1.3 Program Description
The West African Infrastructure Program has been designed around three
preliminary components:
Component 1: Infrastructure Component: Supporting Connectivity
International Connectivity: International connectivity component will focus on (i)
support to provide access to those countries without established access to
international submarine cable connectivity and (ii) supporting countries with
limited/ indirect access to have alternative access to improve terms of access to
capacity and lower cost.
Regional backhaul links: The main activity of the regional backhaul links component
would include leveraging cross-border alternative infrastructure, including roads,
railways and power transmission infrastructure, in order to create a seamless
regional transmission network and interconnect countries in West Africa. Proposed
activities would include (i) Financing investment required to equip existing fiber or
lay fiber on existing transmission lines, (ii) Financing additional links to national
infrastructure and landing points as per detailed feasibility studies, (iii) Purchase of
capacity on fiber-based transmission networks for targeted users (eg. schools,
universities, hospitals, and other priority groups) with discounted capacity prices
and (iv) the establishment of national and regional Internet Exchange Points (IXPs).
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
3 November, 2010
National connectivity: In order to ensure the viability of international and regional
connectivity initiatives, it is important to ensure adequate traffic made possible by an
acceleration of national infrastructure roll-out and application building. The
individual countries may not be in a position to achieve low-cost broadband access
and therefore may not be in a position to advance their growth agenda and overall
global competitiveness without adequate national infrastructure. This component
could also include financing the purchase of capacity for targeted users (eg. schools,
universities, hospitals, and other priority groups).
Component 2: Designing PPP framework and Institutional strengthening
This component will focus on the transaction design and operating model for
ownership and management of submarine cable landing stations and infrastructure
considered in Component 1. A PPP framework will be designed to address
structural and ownership questions, access and management of network, rights and
obligation of different players. The PPP framework would focus on principles of
open and non-discriminatory access while maximizing the role of the private sector.
Significant institutional strengthening support is needed to ensure that the PPP
agreements and principles are implemented effectively.
Component 3: Creating an Enabling Environment for regional and national
connectivity and applications
This component will focus on creating an enabling environment to (i) address policy
and regulatory bottlenecks at both regional and national levels to maximize the
benefits of the proposed connectivity agenda, and (ii) to enable regional e-
government applications.
Implementation of the ACE Cable Project in Liberia will include a number of
activities that will lead to varied project-environment interactions across biophysical
and social components within the project's area of influence. Potential and associated
impacts of these interactions could range from small-scale and site-specific to less
localized far reaching effects.
Although the details of the project implementation are yet unknown, it is timely to
develop and design a structure to address possible adverse effects of anticipated
project-environment interactions. To this end, the World Bank‟s environmental and
social safeguards policies require that the recipient country prepare an
Environmental and Social Management Framework (ESMF) (consistent with national
laws, any applicable treaty concerning international waters, and OP 4.01) and a
Resettlement Policy Framework (RPF) for the lateral cables and any associated
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
4 November, 2010
equipment that will be laid from the junction with the main cable through territorial
waters and onto the national shores.
These safeguards documents will be prepared, disclosed and consulted before
appraisal. Once the specific sites and project details are known, Environmental and
Social Impact Assessments (ESIAs) and Resettlement Action Plans (RAP) considered
appropriate to the project area of influence will be prepared as part of project
implementation but before the cable is laid.
The Liberian Telecommunications Authority (LTA) has therefore commissioned this
ESMF to comply with World Bank environmental and social safe guard
requirements, and the Liberian Environmental Management laws.
1.4 Structure of the Report
Chapter One – Provides the project objective and background
Chapter Two - Gives the ESMF objectives and scope of work
Chapter Three - Highlights the methodology employed to prepare this ESMF
Chapter Four – Provides an overview of National and international laws, regulations
and standards that are considered relevant to the ESMF.
Chapter Five – Is the Project Description including alternatives and implementation
phases
Chapter Six – Provides a general discussion of the environmental and social
characteristics of Liberia with emphasis on the coastal and marine environment.
Chapter Seven – Covers the stakeholder engagement and public disclosure
requirements and procedure for the project.
Chapter Eight– Is a discussion of the positive and potential adverse effects of the
project
Chapter Nine – Outlines a general approach to mitigate potential adverse affects
Chapter Ten – Discusses the process and steps to implement the ESMF including
required budget.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
5 November, 2010
CHAPTER TWO
ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK
OBJECTIVES AND SCOPE OF WORK
2.1 ESMF Objectives
This Environmental and Social Management Framework seeks to provide a clear
process including action plans to integrate environmental and social considerations
into the implementation of the ACE project in Liberia. The specific objectives of the
ESMF are to:
Ensure that the project is carried out in accordance with today‟s sustainable
development tenets;
Provide a structure/strategy for the integration of social and environmental
consideration at all stages of the project planning, design, execution and
operation;
Ensure overall positive social and environmental impacts of the project and
avoid/minimize, and manage any potential adverse impacts;
Establish clear procedures and methodologies for incorporating
environmental management requirements including stake holder
engagement in the implementation of the project;
Provide a framework for environmental and social screening, and assessment
of cable construction and landing, as well as backbone and transmission
telecommunications infrastructure development in Liberia;
Provide guidelines for appropriate roles and responsibilities, and outline the
necessary reporting procedures, for managing and monitoring environmental
and social concerns of the project;
Determine the training, capacity building and technical assistance needed to
successfully implement the provisions of the ESMF;
Comply with regulatory and policy requirements (local and international)
that are applicable to the project and individual activities;
Provide as much information as possible about environmental and social
impacts (including possible land acquisition and resettlement) at the project‟s
current state of preparation;
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
6 November, 2010
Inform the project planning and design process by comparing the potential
impacts of alternative locations, configurations, and construction techniques
that are under consideration; and
Ensure stakeholder interaction during the project implementation to manage
negative social effects
. This ESMF will be used by the Liberian Telecommunications Authority (LTA) and
the CCL, together with the separate report providing a Resettlement Policy
Framework (RPF) for the project. The RPF provides a structure to address possible
involuntary physical and economic displacement associated with the project.
2.2 Scope of Work
The Scope of Work (SOW) for the ESMF was designed to ensure attainment of the
stated objectives throughout the ACE Cable project implementation. The key
elements of the SOW are highlighted below.
Task 1-Project Description
Will cover a brief description of the project, focusing on those aspects that could
have positive or negative impacts on the natural and human environments.
Task 2 - Description of the Environment
Relevant biophysical and socio economic characteristics of the project‟s area of
influence will be described to provide a general overview of the project
environment.
Task 3 - Legislative and Regulatory Considerations
A compilation of relevant local and international legislation, including, those on
environmental and social assessment, and land tenure.
Task 4 - Determination of the Potential Impacts of the Proposed Project
This task covers the analysis of project-environment interactions to provide broad
descriptions of the nature of potential positive and adverse effects of the proposed
project. The task covers both biophysical and socio economic environments.
Task 5 - Analysis of Alternatives
Typical project alternatives such as no project option, alternative technology,
alternative landing site and cable routes will be discussed briefly mostly in the
context of environmental and social safeguards.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
7 November, 2010
Task 5 - Identification of Mitigation and Monitoring Measures
Broad recommendations will be made to mitigate to acceptable levels, identified
potential adverse impacts of the project, and for enhancing positive ones.
Task 6 - Definition of Environmental and Social Impact Management Procedures, Guidelines
and Responsibilities
This includes scoping of the project‟s field of influence, and categorization for the
purpose of Environmental and Social Impact Assessment (ESIA) using standard
World Bank EIA categorization process. Additionally, the approach to
environmental and social management including responsible parties, policy
requirements, public consultation and disclosure, and interaction with project team
will be covered.
Task 7 – Capacity Building and Training Needs
Identify broad capacity building and training requirements for the implementing
agency (CCL) and other relevant stakeholders to ensure adequate monitoring and
enforcement of environmental standards.
Task 8- Public Consultation
This activity will identify and carry out consultations with project stakeholders to
ensure disclosure and elicit issues and related mitigants, as may be relevant to the
ACE Cable Project Implementation. The ESMF will also provide a procedure for
further consultation during the project construction and implementation phase.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
8 November, 2010
CHAPTER THREE
METHODOLOGY
This ESMF has been prepared in accordance with standard procedures for
environmental assessment including the applicable World Bank safeguard policies
and Liberian environmental assessment guidelines. The study methodology
generally followed the scope of services earlier outlined.
3.1 Data Gathering
Data gathering involved visits to various government offices, private libraries and
internet searches to obtain information on:
- The ACE Cable Project in general and the Liberian scope in particular;
- Baseline environmental characteristics relevant to the proejct ;
- Applicable local and international policies and regulations;
- Lessons learned from other marine cable projects in other parts of
Africa and globally;
- Environmental and social impacts of marine cable laying projects and
including land based interactions; and
- Environmental and social management plans for marine cable laying
projects.
3.2 Environmental and Social Screening Tool
To ensure the project is appropriately screened for environmental and social issues
at the design stage, a check -list tool has been developed to screen each project in
terms of:
- Appropriate EIA category;
- Applicable local and international regulations and standards (e.g.,
labour, pollution, occupational health and other standards);
- Appropriate World Bank safe guards;
- Level of stakeholder engagement (both sectoral and project level);
- Existing environmental and other (e.g., pension or compensation)
liabilities; and
- Location sensitivities (e.g., sensitive environments and culture)
The screening tool provides necessary information to appropriately scope EIA
studies.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
9 November, 2010
3.3 Environmental Impact Analysis
Since specific project details are not known at this stage, the environmental impact
analysis has focused on mostly qualitative identification of a broad range of typical
potential adverse impacts associated with marine based cable projects. As much as
possible, the impact analysis has taken into consideration possible alternative
scenarios for design, construction and operation of the project.
3.4 Mitigation Measures
Mitigation measures are often proffered to either eliminate or minimize adverse
environmental and social impacts of specific actions, projects or programs while also
enhancing positive effects. The approach to mitigation has been primarily preventive
based on well known negative outcomes of project-environment interactions. As
with the impact analysis, considerations have been given to the nuances in impacts
as a result of project alternatives.
3.5 Environmental Management Plan
A critical outcome of the Environmental Assessment (EA) process is the
Environmental Management Plan (EMP) document. This document describes the
processes that the project implementing agency will follow to maximize its
compliance and minimize harm to the environment. The EMP document also helps
an organization map its progress towards achieving continual improvements. For
the ACE Cable Project, an EMP framework has been provided to assure the
environmental and social sustainability of the project.
3.6 Capacity Building and Training
Capacity building requirements have been dealt with at two levels. The first is the
capacity building for the CCL/LTA, while the second is capacity building for other
participating stakeholders. It is recognized that the nature of capacity building for
each group in the second category may differ.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
10 November, 2010
CHAPTER FOUR
POLICY AND REGULATORY FRAME WORK
There are a number of relevant national and international environmental policies
and regulations that are applicable to the ACE Cable Project in Liberia. Some labour
laws considered relevant to the project are also discussed.
4.1 National Environmental Legislation
In Liberia, there are a few National laws, regulations and standards, which seek to
protect the natural environment and assure sustainable development in the country.
These laws were developed relatively recently as is discussed below.
4.1.1 The Liberian National Constitution (1986)
Article 7 of Chapter II of the New Constitution of Liberia, which came into force and
effect on January 6, 1986, provides for full public participation of all citizens in the
protection and management of the environment and natural resources of Liberia. The
constitution also encourages the government to pursue bilateral, regional and
international cooperation in areas of mutual concerns. As a result, Liberia is party to
some treaties and laws and a member of international and regional organizations for
global protection of the environment and sustainable use of natural resources
4.1.2 The National Environmental Policy
The overall policy goal is to ensure long-term economic prosperity of Liberia
through sustainable social and economic development which enhances
environmental quality and resource productivity on a long-term basis that meets the
requirements of the present generation without endangering the potential of future
generations to meet their own needs.
Policy Statement
Environmental Protection in Liberia shall be guided by the following principles of
sustainable development:
The precautionary principle - This means that in certain cases action has to
be taken without waiting for substantial proof.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
11 November, 2010
The polluter pays principle - This means that the polluter or the person
responsible for causing the environmental damage should bear the cost of
repairs or protecting the environment.
Individual responsibility - Is the responsibility of every to ensure that
emission from individuals and households shall not amount to total to large
volumes that will have subsequent impacts on the environment.
Consideration for our neighbors - Each nation/individual should ensure that
activities within its own boundaries do not cause harm to the environment in
their neighbors/neighboring countries.
Promoting sustainable development - Denote development that satisfies our
contemporary needs without endangering the potential for future generations
to satisfy theirs.
Particularly the Government will:
a. Commit itself to the sound scientific and sustainable use of both renewable and
non-renewable resources of the environment in the process of implementation of
socio-economic national development;
b. Create environment awareness among all sections of the community, including
children, stressing the environment relationship to socio-economic development,
and of the necessary for rational resource use;
c. Develop procedures for the utilization of land resources in a manner that will
ensure the maximum degree of economic value;
d. Institute and implement an environmental quality control program by requiring
prior environmental impact assessments for all investments that would be
deemed to affect the quality of the environment;
e. Institute the appropriate measures to control pollution and the importation and
use of potentially toxic chemicals;
f. Take appropriate measures to protect critical ecosystems against harmful effects,
or destructive practices;
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
12 November, 2010
g. Develop and maintain a professional agency within the country to supervise,
coordinate, implement and enforce procedures and legislation essential for
safeguarding the environment and maintenance of sound ecological systems;
h. Oblige all concerned to provide the relevant information needed for
environmental protection and for the enforcement of relevant environmental
regulations and legislation;
i. Promote and support research programs for understanding of the different
environmental zones and the factors affecting them, also for health-related
environment problems, and development of appropriate technologies for sound
management of the environment and use of local resources, including renewable
energy resources; and
j. Establish an adequate legislative and institutional framework for monitoring,
coordinating and enforcing environmental programs and issues.
The fundamental goals and objectives of the National Environmental Policy shall be
pursued and achieved through the harmonization and enforcement of the
environment protection and management law and the implementation of national
plan. The plan will attempt to provide a coherent framework for the various policy
interventions necessary to safeguard the environment.
4.1.3 The Liberian Environmental Protection Agency (EPA) Act
The EPA Act of 2002 set up the agency to monitor, coordinate, supervise the
sustainable management of the environment in partnership with regulated
Ministries and organizations and in a close and responsive relationship with the
people of Liberia. The agency is empowered to carry out a wide range of functions.
Including in relation to environmental protection, advising the state, setting out
policies, guidelines, regulations, monitoring, interfacing with international
organisations, gathering data, developing capacity and others.
4.1.3.1 The EPA EIA Process
EPA has issued EIA procedural guidelines for Liberia. The process commences with
the submission of an application to the Environmental Protection Agency (EPA) of
Liberia. The application is followed by a Project Brief, providing a brief description
of the project. After the screening of the document, the EPA may consider the
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
13 November, 2010
project as having little or no significant impact on the environment and issued a
“Finding of No Significant Impact” (FONSI). However, should the EPA consider the
project of having significant impacts to the environment, the agency will authorize
the publication of a Notice of Intent and request for the conduct of a Scoping Study.
The study will ensure early public participation in the project and narrows the issues
to be addressed in an environmental impact study. A Term of Reference (TOR) to
define the scope of the Environmental Impact Study (EIS) is formulated at the
conclusion of the Scoping Study. The TOR is reviewed with the EPA and approval
granted for the conduct of a full EIS.
The EIS will identify the nature of the project and address the nature and magnitude
of the anticipated impacts of the project; predict the extent/scale/location of the
impacts; Identify the timing, the stage at which the anticipated impact is likely to
occur and the duration of the impact; and predict the reversibility/irreversibility of
anticipated impacts. An Environmental Impact Assessment Report/Statement is
submitted to the EPA for review. This document is circulated to line ministries and
agencies for review. The document is subsequently reviewed through a public
hearing. If the issues addressed in the document are considered inadequate, the
project proponent is requested to review its study and revise the document. If the
document is satisfactory, a permit is issued for the implementation of the project.
The generalized Environmental Impact Assessment of the EPA of Liberia is
illustrated in Appendix 2.
4.1.4 The Land Use Act (1929)
The Act lays down the procedure for obtaining rights to any piece of land in Liberia
through purchase. The Act distinguishes land in Liberia into two categories viz: the
Hinterland, and the County area
4.1.5 The Liberian Labour Law
The government of Liberia, Labor Law (Title 18 and 18A), (1956 and 1989), provides
guidelines, restrictions and penalties relating to recruitment, wages, hours of work
and other general conditions of employment. Additionally, chapter 2d, section 74,
sets the minimum age for work at 16 years. Children under 16 years are prohibited
from working during the school day and may only work for wages if the employer
can demonstrate that they are attending school regularly and have a basic education.
Labor recruiters are permitted to hire children between 16 and 18 years for
occupations approved by the Ministry of Labor.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
14 November, 2010
4.2 International Environmental Legislation
Liberia is signatory to a number of international treaties and conventions on the
protection of the environment. These include those on climate, desertification,
biodiversity conservation, coastlands and others. Some of the key ones are discussed
while others are listed.
4.2.1 The IMO Convention for Prevention of Pollution from Ships
The IMO International Convention for the Prevention of Pollution from Ships, 1973,
as modified by the Protocol of 1978 relating thereto (MARPOL 73/78) is the most
important convention regulating and preventing marine pollution by ships. It covers
accidental and operational oil pollution as well as pollution by chemicals, goods in
packaged form, sewage, garbage and air pollution.
4.2.2 UN Convention on Law of the Sea
United Nations Convention on the Law of the Sea (UNCLOS), (Part XII: Articles 192
– 237) which addresses Protection and Preservation of the Marine Environment and
gives basic obligations to prevent, reduce and control pollution from land-based
sources; pollution from sea-bed activities subject to national jurisdiction; pollution
from activities in the Area; pollution by dumping; pollution from vessels; and
pollution from or through the atmosphere.
UNCLOS also introduces a number of provisions relating to limits, navigation,
archipelagic status and transit regimes, exclusive economic zones (EEZs), continental
shelf jurisdiction, deep seabed mining, the exploitation regime, scientific research,
and settlement of disputes. The convention set the limit of various areas, measured
from a carefully defined baseline.
Other conventions and their years of adoption are given in Table 4-1 below.
Table 4-1: Summary of Other Key International Environmental Agreements, Treaty, Convention, Regulation Ratified By Liberia
Year Adopted
Convention on Biological Diversity (CBD)
The Cartagena Protocol on Biosafety to the Convention on Biological Diversity
United Nations Convention to Combat Desertification
The United Nations Framework Convention on Climate Change
Kyoto Protocol
Abidjan Convention And Protocol on Management And Protection Of Coastal and
Marine Environment In the Sub-Region
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
15 November, 2010
Ramsar Convention On Wetlands
4.3 International Labour Laws
Liberia is party to a number of labour related conventions. The most relevant ones are highlighted in the Table 4-2.
Table 4-2 Labour Convention/Treaty Ratified by Liberia Year Adopted
Seamen's Articles of Agreement Convention, 1926 (No. 22) 1977
Repatriation of Seamen Convention, 1926 (No. 23) 1977
Forced Labour Convention, 1930 (No. 29) 1931
Officers' Competency Certificates Convention, 1936 (No. 53) 1960
Shipowners' Liability (Sick and Injured Seamen) Convention, 1936 (No. 55) 1960
Minimum Age (Sea) Convention (Revised), 1936 (No. 58) 1960
Penal Sanctions (Indigenous Workers) Convention, 1939 (No. 65) 1962
Labour Inspection Convention, 1947 (No. 81) 2003
Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87)
1962
Accommodation of Crews Convention (Revised), 1949 (No. 92) 1977
Right to Organise and Collective Bargaining Convention, 1949 (No. 98) 1962
Abolition of Penal Sanctions (Indigenous Workers) Convention, 1955 (No. 104) 1962
Abolition of Forced Labour Convention, 1957 (No. 105) 1962
Seafarers' Identity Documents Convention, 1958 (No. 108) 1981
Discrimination (Employment and Occupation) Convention, 1958 (No. 111) 1959
Minimum Age (Fishermen) Convention, 1959 (No. 112) 1960
Medical Examination (Fishermen) Convention, 1959 (No. 113) 1960
Fishermen's Articles of Agreement Convention, 1959 (No. 114) 1960
Accommodation of Crews (Supplementary Provisions) Convention, 1970 (No. 133) 1978
Tripartite Consultation (International Labour Standards) Convention, 1976 (No. 144) 2003
Merchant Shipping (Minimum Standards) Convention, 1976 (No. 147) 1981
Labour Administration Convention, 1978 (No. 150) 2003
Worst Forms of Child Labour Convention, 1999 (No. 182) 2003
4.4 The Core Labour Standards
Although other labour standards exist, four labour standards are internationally accepted as the “core” labor standards (CLS).
i. Effective Abolition of Child Labor
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
16 November, 2010
ii. Elimination of Discrimination in Employment and Occupation
iii. Elimination of All F Forms of Forced or Compulsory Labor
iv. Freedom of Association and the Effective Recognition of the Right to
Collective Bargaining
The standards are a set of internationally recognized basic rights and principles at
work. There is a global recognition that the CLS are generally applicable to all
countries including Liberia. They do not establish a particular level of working
conditions, wages, or health and safety standards to be applied internationally nor
do they seek to change the comparative advantage of any country.
They are basic rights that have been repeatedly articulated in international human
rights instruments and declarations, such as the Universal Declaration of Human
Rights in 1948 and the Convention on the Rights of the Child, 1989. 4.5 World Bank Policies
The World Bank is committed to a number of operational and safeguard policies
which aim to prevent and mitigate undue harm to people and their environment in
any development initiative involving the bank. These policies provide guidelines for
bank and borrower staff in the identification, preparation, and implementation of
programs and projects. There are ten World Bank Environmental/Safeguard
Policies. As discussed below not all these policies are triggered by the ACE Cable
Landing Project in Liberia. 4.5.1 Triggered World Bank Policies
The World Bank policies that have been triggered by the proposed ACE Cable
Project are:
- Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental
Assessment.
This is the umbrella policy for the Bank's environmental 'safeguard policies' which
among others include: Natural Habitats (OP 4.04), Forests (OP 4.36), Pest
Management (OP 4.09), Physical Cultural Resources (OP 4.11), and Safety of Dams
(OP 4.37)
The Bank requires environmental assessment (EA) of projects proposed for Bank
financing to help ensure that they are environmentally sound and sustainable, and
thus improve decision making.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
17 November, 2010
Such EA are carried out by the borrower to evaluate a project's potential
environmental risks and impacts in its area of influence. The EA process analyzes
project alternatives; identifies ways of improving project selection, siting, planning,
design, and implementation by preventing, minimizing, mitigating, or compensating
for adverse environmental impacts and enhancing positive impacts; and includes the
process of mitigating and managing adverse environmental impacts throughout
project implementation. The Bank favors preventive measures over mitigatory or
compensatory measures, whenever feasible.
EA looks at the interaction of the project with the natural environment (air, water,
and land); human health and safety; social aspects (involuntary resettlement,
indigenous peoples, and physical cultural resources); and where applicable,
transboundary and global environmental aspects.
The Bank has categorized projects based on the type of EA required.
Category A - projects are those whose impacts are sensitive, diverse,
unprecedented, felt beyond the immediate project environment and are
potentially irreversible over the long term. Such projects require full EA.
Category B - projects involve site specific and immediate project environment
interactions, do not significantly affect human populations, do not
significantly alter natural systems and resources, do not consume much
natural resources (e.g., ground water) and have adverse impacts that are not
sensitive, diverse, unprecedented and are mostly reversible. Category B
projects will require partial EA, and environmental and social action plans.
Category C - Projects are mostly benign and are likely to have minimal or no
adverse environmental impacts. Beyond screening, no further EA action is
required for a Category C project, although some may require environmental
and social action plans.
Category FI - A proposed project is classified as Category FI if it involves
investment of Bank funds through a financial intermediary, in subprojects
that may result in adverse environmental impacts.
The World Bank Pollution Prevention and Abatement Handbook describes pollution
prevention and abatement measures and emission levels that are normally
acceptable to the Bank. However, taking into account borrower country legislation
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
18 November, 2010
and local conditions, the Bank works with alternative emission levels and
approaches to pollution prevention and abatement for projects. The EA report must
provide full and detailed justification for the levels and approaches chosen for the
particular project or site.
- Operational Policy/Bank Procedure 4.04 - Natural Habitat - seeks to ensure
that World Bank-supported infrastructure and other development projects
take into account the conservation of biodiversity, as well as the numerous
environmental services and products which natural habitats provide to
human society
- Operational Policy/Bank Procedure 4.36 - Forests. This policy aims to reduce
deforestation, enhance the environmental contribution of forested areas,
promote afforestation, reduce poverty, and encourage economic
development.
- Operational Policy /Bank Procedure 4.11 - Physical Cultural Resources seeks
to avoid, or mitigate, adverse impacts on cultural resources from
development projects that the World Bank finances.
- Operational Policy 4.12: Involuntary Resettlement is concerned with
situations involving involuntary taking of land and involuntary restrictions of
access to legally designated parks and protected areas. The policy aims to
avoid involuntary resettlement to the extent feasible, or to minimize and
mitigate its adverse social and economic impacts.
It promotes participation of displaced people in resettlement planning and
implementation, and its key economic objective is to assist displaced persons
in their efforts to improve or at least restore their incomes and standards of
living after displacement.
4.5.2 Other World Bank Policies
Other Bank policies that are not considered relevant to the ACE Cable Project are:
- Operational Policy (OP)/Bank Procedure (BP) 4.10 - Indigenous Peoples.
- Operational Policy 4.09 - Pest Management.
- Operational Policy (OP) 4.37 - Safety on Dams
- Operational Policy (OP)/Bank Procedure (BP) 7.50 - Projects on International
Waterways
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
19 November, 2010
- Operational Policy (OP)/Bank Procedure (BP) 7.60 - Projects in Disputed Areas
- World Bank Interim Guidelines for Addressing Legacy Issues
4.6 Adequacy Of Environmental Legislation
Sections 4.1 to 4.5 have provided an overview of existing laws, regulations and
standards available in Liberia. International laws that are relevant to the ACE Cable
Project were also highlighted. As is evident, there are legislative instruments to
assure sustainable development in Liberia. As most of these laws are relatively
recent, their adequacy and implementation performance will be evaluated over time.
For now, they are considered adequate for protection of the Liberian environment
and sustainability of the ACE Cable Project.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
20 November, 2010
CHAPTER FIVE
PROJECT DESCRIPTION
5.1 Project Overview
The Government of Liberia (GoL) in its plan to improve communication in the country
and international connectivity with the rest of the world, is planning to link to the ACE
submarine fibre optic cable. Towards successful actualization of this goal, the
government formed the Cable Consortium of Liberia (CCL) to own and operate the
ACE landing station in Liberia. CCL is a technology company that is partly owned by
the Government of Liberia, LIBTELCO, Lonestar Communications and Cellcom.
The submarine cable will be deployed over 17,000 km and will provide access to
more than 24 countries starting in 2012. It will include a new open-access fibre optic
submarine cable, which will expand international telecommunications services to
countries in the Atlantic Coast of Africa. It is envisaged that the system will facilitate
data transmission, voice, internet and television signals, allowing for inter country
transmission of information. With a planned capacity of about 1.92 Tbit/s, the ACE
system will provide sufficient and redundancy capacity for the future country needs.
The ACE cable system will be the first international submarine cable to land in a
number of African countries including the Democratic Republic of Congo,
Equatorial Guinea, The Gambia, Guinea, Liberia, Mauritania, Namibia, Sao Tome
and Principe and Sierra Leone. Other countries benefiting from the ACE project are
Angola, Benin, Cameroon, Côte d‟Ivoire, France, Gabon, Ghana, Mali, Niger,
Nigeria, Portugal, Senegal, South Africa and Spain (Tenerife).
The ACE submarine cable system is configured into 4 segments as follows:
Segment 1: Between the Penmarch (France) and the Dakar (Senegal) Terminal
Stations
Segment 2: Between the Dakar (Senegal) and the Abidjan (Cote D‟Ivoire)
Terminal Stations
Segment 3: Between the Abidjan (Cote D‟Ivoire) and the Santana (Sao Tome)
Terminal Stations, and
Segment 4: Between the Santana (Sao Tome) and the Cape Town (South
Africa) Terminal Stations (however the contract for this segment is not
effective yet).
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
21 November, 2010
Liberia and Sierra Leone are expected to be included in Segment 2. Liberia opted for
the less costly option to have branching units which allows the cable to split while in
deep sea to serve multiple countries.
Liberia‟s participation in the project is supported by the World Bank through the Bank‟s
West Africa Regional Communications Infrastructure Program (WARCIP). The program
aims to contribute to lowering the cost and improving quality of regional and
international connectivity by facilitating: i) the connection of all countries in West
Africa to global broadband fiber optics infrastructure, and ii) the creation of a
coordinated regional and national transmission network which would ensure that all
countries in West Africa are able to connect effectively within and between national
borders. The first phase of the program will be implemented in Liberia, and Sierra
Leone where there is least access to submarine cables.
Implementation of the ACE Cable Project in Liberia includes 3 distinct components;
iv. A deepsea cable laying in the international waters from France to Liberia;
v. a connecting cable from the submarine or deep sea cable to the shores of Liberia in Monrovia; and
vi. A landing or cable station in Monrovia
5.2 Project Justification
The South Atlantic 3 (SAT-3) Cable is an existing submarine communications cable
linking Portugal and Spain to South Africa, with connections to several West African
countries along the route. It forms part of the SAT-3/WASC/SAFE cable system,
where the SAFE cable links South Africa to Asia. Currently the SAT-3 system is the
only international fibre optic cable serving the West African coast since April 2002.
The landing towns and beneficiary countries include Melkbosstrand-South Africa,
Luanda-Angola, Libreville-Gabon, Douala-Cameroon, Lagos-Nigeria, Cotonou-
Benin, Accra-Ghana, Abidjan-Ivory Coast, Dakar-Senegal, Alta Vista-Gran Canary
Island, Chipiona-Spain, Sesimbra-Portugal. Liberia could not be part of the SAT-3
system primarily because of the 14 year civil unrest, which ended in 2003.
Additionally, capacity on the SAT-3 system is severely constrained. The system
currently has an overall capacity of 120 gigabits per second (Gbps). Access to the
SAT-3 system is by contractual agreement and this has limited the number of
telecommunication companies and other commercial businesses who wish to access
the system. One effect of the SAT-3 pricing structure and the high demand for access
is a relatively high price for usage.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
22 November, 2010
The project is also in consonance with Target 8.F of the UN Millennium
Development Goals (MDG), which recognizes that:
Demand grows daily for information and communications technology;
Access to the World Wide Web is still closed to the majority of the world‟s
people; and
A large gap separates those with high-speed Internet connections, mostly in
developed nations, and dial-up users
Target 8.F therefore seeks to make available benefits of new technologies, especially
information and communications in cooperation with the private sector.
5.3 Benefits of the Project
The Project will have both direct and indirect benefits as discussed below.
5.3.1 Direct Benefits
The direct benefits are those directly associated with telecommunication services and
include:
vi. Increase in available international transmission capacity and the lower cost
for such access;
vii. Faster and more reliable transmission for data and voice as a result of
increased capacity and lower access cost;
viii. Improved business performance while creating additional opportunities for
business expansion;
ix. Improved mobile telecommunications availability across the country; and
x. Improved local content participation in the ICT industry, capacity building
and technology transfer.
5.3.2 Indirect benefits
The indirect benefits are those derived from the direct benefits earlier listed and
include:
v. Better economic integration of, and cooperation among African State
countries and linkage to global economy;
vi. Catalyzed start-up of new businesses;
vii. Support for gender-related advocacy and program activities;
viii. Exchange of experience and technical expertise with international community
and internally across various business sectors;
iii. Expansion of technology-based into Liberia; and
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
23 November, 2010
iv. Employment generation and better inclusion of low-income communities in
ICT education.
5.4 Cable Description
The proposed cable system will comprise an optical fibre submarine
communications cable to carry telecommunications between France and Liberia. An
optical fibre is a glass or plastic fibre that carries light along its length. Optical fibres
are widely used in fibre-optic communication. They permit transmission over longer
distances and at higher data rates than other forms of communications.
Sub-sea systems are designed to have very high resilience against failure. The most
common reason for failure is through physical cable damage from shipping,
particularly in shallow seas.
The construction of subsea cables varies with manufacturer and seabed conditions.
Cable engineering specifications for the proposed Project will be based on cable
industry standards. The diameter of subsea cables varies between 17 and 20 mm for
sections without protective armor; armored cables may be as large as 50 mm in
diameter. The cable consists of an inner optical fibre, surrounded by a polyethylene
or fibre-glass core for strength and fibre separation. The core is normally surrounded
by two polyethylene jackets and copper conductor layer and the outer layers
comprise a steel wire protective armour layer and an outer protection and wire
containment (polypropylene yarn). The physical cable system will comprise two
fiber pairs that provide two separate bi-directional paths (i.e., one fiber in each pair
carries signals in the outbound direction and the other fiber in the return or inbound
direction). The cable system is likely to have a submerged or „wet plant‟ part, and a
„dry plant‟ part which interfaces at proposed Landing Stations.
The ACE C&MA states that countries own their terminal landing station (segment T)
as well as the „R‟ section of the respective „wet segment‟. The „wet segment‟ consists
of two components: R section; and M section. R sections are sections that fall in
territorial water. M sections are sections of the branch that fall in international water.
Countries do not own the M section.
A summary of cable types that may be used for the ACE submarine cable route,
including the stub segments, is provided in Table 5-1 below. Illustrations of typical
cable designs are also shown in Figure 5-1 and 5-2.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
24 November, 2010
Table 5-1: Submarine Telecommunication Cable Types
Cable type Approximate length Application Feature
Double armour buried 90 km -Rocky terrain -High risk of trawler damage -Moderate abrasion risk -Depth to 600 m
Two armour wire layers applied to core cable
Single armour Single armour buried
10 km 30 km
-Very rocky terrain -High risk of trawler damage -Depth to 1,200 m
Heavy armour wire layer applied to core cable
Light weight armour 10 km -Rocky terrain -Moderate risk of trawler damage -Depth to 1,500 m -Normally used for burial
Light armour wire layer applied to core cable
Light weight 7,150 km -Benign, sandy bottom -Depth to 8,000 m
Core cable, light protection
Figure 5-1: Cable Design Types
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
25 November, 2010
Figure 5-2: Modern Submarine Cable
5.5 Cable Technology
The ACE system will deploy wavelength division multiplexing (WDM) technology,
which is currently the most advanced for submarine cables. With WDM, cable
capacity can be increased without additional submarine work. With an overall
potential capacity of 5.12 Tbit/s, the system will support the 40 Gbit/s technology at
day 1.
In fiber-optic communications, wavelength-division multiplexing (WDM) is a
technology which multiplexes a number of optical carrier signals onto a single
optical fiber by using different wavelengths (colours) of laser light. This technique
enables bidirectional communications over one strand of fiber, as well as
multiplication of capacity.
The term wavelength-division multiplexing is commonly applied to an optical carrier
(which is typically described by its wavelength), whereas frequency-division
multiplexing typically applies to a radio carrier (which is more often described by
frequency). Since wavelength and frequency are tied together through a simple
relationship, the two terms actually describe the same concept.
WDM systems are popular with telecommunications companies because they allow
them to expand the capacity of the network without laying more fiber. By using
WDM and optical amplifiers, they can accommodate several generations of
technology development in their optical infrastructure without having to overhaul
the backbone network. Capacity of a given link can be expanded by simply
upgrading the multiplexers and demultiplexers at each end.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
26 November, 2010
5.6 Repeaters and Branching Units
Repeaters are installed along the cable to boost the signal because the signal loses
strength en route. Branching Units (BUs) are pieces of equipment used in submarine
telecommunications cable systems to allow the cable to split to serve more than one
destination.
5.7 Landing Sites
The landing site/station is where the underwater cable makes landfall. The landing
or termination station can also be the point at which the submarine cable connects
into the land-based telecommunication infrastructure or network.
Four options are being considered as landing site locations for the Project (Section 5-
8). One of the options - a 400m-500m stretch of land along the beach immediately
south of the Ministry of Defense Headquarters in Monrovia appears to be more
suitable and appealing to GoL because it is Government owned,
secured (close to the Ministry of Defense) and does not require relocation and
resettlement of people. Further, its use will not lead to any form of
economic displacement. The final selection of a landing site will however be
done once necessary consultations have been completed and clearances have been
obtained.
5.8 Project Alternatives
Project alternatives are often considered to determine which location, technology
process or other aspect of a project are considered best in terms of cost-benefit,
overall project objectives, environmental and social sustainability. A summary of
alternatives considered are discussed below.
5.8.1 Technology Alternatives
Technology alternatives considered are fibre optic versus satellite technology. Fibre
optic networks have greater advantages over satellite, microwave and radio
transmissions. Radio has largely been phased out due to restricted bandwidth and
poor data transmission. Modern fibre optic networks transmit high volumes of voice
and data traffic with higher security and reliability and at a lower cost than satellite
systems. Cable also has a more dependable installation and repair record.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
27 November, 2010
Bandwidth demand, particularly as a result of internet activity far exceeds satellite
capacity at the present time (Hogan and Hartson, 1999).
5.8.2 Routing Alternatives
Land-based fibre optic cables are an alternative to the proposed submarine system.
In this alternative, the cable would be routed on land, generally along the coastal
areas where telecommunications use is concentrated. The cable would need to be
installed below ground and given the lack of existing infrastructure, this would
require extensive trenching to bury the cable. The cable would also have to be
installed across surface water bodies (e.g. rivers, streams, and wetlands). In practice
it has been found that installation costs are higher for terrestrial systems due to the
increased complexity. Further, trenching and cable laying across built up areas will
result in more physical and economic displacement concerns. In addition, permitting
can be more complex and time consuming and cable faults are known to be more
frequent. There are other practical and security issues as well as greater potential for
environmental and social impacts associated with terrestrial cable burial for a system
of several thousands of kilometers. A submarine system therefore currently offers
the better option.
5.8.3 Landing Site Alternatives
Landing site alternatives were evaluated for their capability to attain the project
goals and objectives with very little environmental and resettlement problems,
security concerns for the facility, as well as nearness to supporting facilities. Four
landing site options were considered as shown in Figure 5-3.
Option 1 – Near Ministry of Defense: This 400-500m beach stretch (see
Figure 5-4) has no residents, squatters and fishing activities, but is only used
by natives for soccer. It is located on the beach along the Redemption Drive,
behind the Barclay Training Center (BTC), presently housing the Ministry of
National Defense. Further, the area is Government-owned land and provides
other facilities and space for the construction of further facilities to enhance
the project. The location also has the advantage of security because of its
proximity to the Ministry of National Defense and the Executive Mansion,
official residence of the Present of the country. The land is owned by the GoL
and clearance for its use would be sought from the Ministry of Interior.
Option 2 - 17th Street-Sinkor Site - A portion of the beach within a well built
area of Monrovia along the southern end of 17th Street, in the Sinkor area. It is
approximately 30 m in width and similarly composed of sand of different
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
28 November, 2010
grain sizes. The site is about 300 m from an existing facility of the LTA, which
formerly housed the Liberia Telecommunication Authority. The buildings
along this stretch are about 40m–50m from the beach. However, the site is
privately owned and situated amidst private residential structures. Further,
its use may require resettlement costs, demolition of structures and the time
for the exercise may prolong the project-implementation schedule. A picture
of the area is shown in Figure 5-5.
Option 3 - Fish Market Area, Sinkor - This alternative is situated along the
beach in the area known as Fish Market, located in the Sinkor area. It is
approximately 25m in width and similarly composed of sand of different
grain sizes. Though the location seems favorable as a landing site, there are
shanty structures nearby, inhabited by locals engaged in fishing activities.
Their relocation and resettlement will be avoidable additional project costs
while also delaying project implementation. The area is shown in Figure 5-6.
Option 4 - Bernard Beach Area, Congo Town: This alternative (Figure 5-7) is
situated in the area known as Bernard Beach, located in Congo Town,
Monrovia. It is approximately 35 m in width, similarly composed of sand of
different grain sizes and provides adequate space for the project objective.
Though the location seems favorable as a landing site, there are swamp and
marshland near, which serve as nesting grounds for marine fishes, birds and
other organisms. Disturbance of this area may adversely affect the ecosystem.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
29 November, 2010
Figure 5-3: Location of Landing Site Alternatives in Monrovia
Figure 5-4: Picture of Preferred Landing Site
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
30 November, 2010
Figure 5-5: Alternative Site Along 17th Street, Sinkor
Figure 5-6: Alternative Project Site around Fish Market
Figure 5-7: Alternative Project Site along Benard Beach, Congo Town
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
31 November, 2010
5.9 Project Phases
The ACE Cable Project in Liberia will be implemented in the following Phases:
5.9.1 Construction Phase
This phase includes pre-installation and cable laying activities.
Pre-Installation
Pre-installation activities will include a detailed cable route survey to investigate the
most cost effective and safest possible environment for the cable and prepare for its
installation as well as engineering design and fabrication of the subsea equipment.
Cable Route Survey
A marine geophysical and geotechnical survey will be performed to investigate the
safest route for the cable system. The surveys indicate the characteristics of the
sediments and presence of rocks or rock beds below the seabed that may hinder the
cable burial work. The geophysical survey will be complemented by diver surveys in
the area of the shore approach to the landing sites. A detailed topographic survey
will be performed to assess the conditions and feasibility of the landing. A limited
seabed-sampling program will also be conducted to supplement the side-scan sonar
and sub-bottom profiler data in the areas where the cable will be buried.
The marine survey equipment will be capable of collecting quality bathymetry and
side-scan intensity data. The survey will investigate the conditions of the seafloor
and shallow subsurface layers, including sediment characteristics along the corridor
and taking into consideration the seabed profile or water depth variations.
The diver work will include probing of the seabed and visual recording in order to
assess the feasibility of cable burial. After the detailed cable route surveys a pre-
installation grapple run will be undertaken along the exact route of the cable to
ensure that no debris, fishing materials or other pipelines far within the route of the
cable.
Engineering and Cable Design
The engineering approach and design of the cable to the deployed on the project will
be designed ahead of installation using input from the from the cable route survey.
Design considerations include protection options that best suit the project
environment.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
32 November, 2010
Cable Installation (Trenching and Burial)
The cable will be installed using a special built ship, which accurately places cables
on or under the seabed along the route determined by the pre-installation survey.
Cables are typically buried under the seabed to protect the cable from fishing and
other marine activities particularly in shallower waters. Backfilling and or cementing
as appropriate for cable trench should be done to ensure proper burial.
Actual final depth of cable trench is confirmed after the seabed survey or geological
and general condition is established. It is often recommended that the cable should
be buried wherever possible to a target depth of between 0.5 m and 1 m below the
seabed.
Deepwater Sections In deeper offshore sections, cables will be buried in a narrow (≤1 m wide) trench that
is cut by a water jet or plough while the cable is being laid. A cable plough works by
lifting a wedge of sediments just enough to insert a cable below the seabed.
Examples of such ploughs are shown in Figure 5-8. The cable will be laid most
probably with the aid of remotely operated vehicles (ROV).
A remotely operated vehicle (ROV) is a guided underwater robot commonly used in
deepwater industries such as offshore hydrocarbon extraction. ROVs are
unoccupied, highly manoeuvrable and operated by a person aboard a vessel. They
are linked to the ship by a tether (sometimes referred to as an umbilical cable), a
group of cables that carry electrical power, video and data signals back and forth
between the operator and the vehicle. High power applications will often use
hydraulics in addition to electrical cabling.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
33 November, 2010
Figure 5-8: Typical Submarine Ploughs
Shallow Waters Sections Cable installation in shallower sections will typically require trenching using a single
grab dredger or similar equipment, and through the placing of the cable within the
trench by divers. After the cable has been laid inside the trench, it would be covered
with concrete mats and backfill materials. It is expected that this method of cable
installation will only be necessary for shallow water depths where the cable burial
machine or plough cannot be used.
It is noted that the best protection against external risks, such as cable damage from
fishing or shipping activities, is achieved by burial. However, some seabed areas are
not suitable for burial such as rocky and highly mobile sand areas. The pre-
installation survey will confirm the potential threats existing in the nearshore and
offshore marine environment with regard to cable burial.
5.9.2 Operations Phase
Once in place and connected, the cable system requires no intervention. Power is
provided to the system through electrical connection in the cable. This also provides
power to the repeaters. The electrical current is fully shielded from the environment.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
34 November, 2010
5.9.3 Repair /Recovery Activities
Cable repair and maintenance may be required as a result of damage, failure, age,
redundancy or clearance of congested routes. To effect repairs on deep cables, the
damaged cable is cut at the seabed and each end separately brought to the surface,
whereupon a new section is spliced in. The repaired cable is longer than the original,
so the excess is deliberately laid in a „U‟ shape on the seabed.
5.9.4 Decommissioning Phase
As cables reach the end of their design life or become redundant due to technological
advances, their removal from the seabed or decommissioning may be considered. In
the case of a buried cable, its removal may result in some disturbance or impact.
To ensure that due consideration is given to all the relevant issues it is recommended
that a detailed evaluation of facility decommissioning options (options to include
leaving the submarine cable in-sit) is carried out. The evaluation should consider
environmental issues in conjunction with technical, safety and cost implications to
establish the best practicable environmental options (BPEO) for the
decommissioning of the cable.
The International Maritime Organisation (IMO) guidelines adopt the following
recommendations when determining decommissioning procedures for offshore
installations;
A general presumption in favour of full removal with recovered
infrastructure reused, recycled or incinerated with energy recovery or
disposal at a licensed site,
Exceptions to this general presumption will apply, where individual
circumstances may not allow for full recovery resulting in all or part of the
device remaining in situ
Installations can remain in situ where a second use had been identified and
confirmed, or the process of removal presents an unacceptable level of risk to
the marine environment and/or personnel involved, or made unfeasible by
the occurrence of technical obstacles.
5.10 Cable Laying Personnel
The submarine cable will be laid from a purpose built ship with crew working 24
hours a day. Most of the crew onboard are required to operate at 2 or 3 shifts
during the cable laying operation. The number of persons on board for staffing the
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
35 November, 2010
day and night shifts can range between 40 and 65, although this number varies
depending on the duration of the operation and the capacity of the ship. All
personnel work on board for the period from the start to the end of the work,
which may sometimes be for as long as three to four months.
5.11 Project Schedule
The ACE submarine cable is expected to be landed in Liberia between the last
quarter of 2011 and the second quarter of 2012.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
36 November, 2010
CHAPTER SIX
ENVIRONMENTAL CHARACTERISTICS OF THE PROJECT
AREA
6.1 Geographical Location
The ACE Submarine project will be implemented within the deep and shallow
marine waters of Liberia, and a shore location along the coast of metropolitan
Monrovia.
Liberia is located on the west coast of Africa and is bordered on the north by Guinea,
on the east by Côte d‟Ivoire, on the south and southwest by the Atlantic Ocean, and
on the northwest by Sierra Leone (Figure 6-1 and 6-2).
Monrovia is the capital and the country‟s largest city. It is located in the Montserrado
County. Monrovia has an estimated population of about 1.5 million inhabitants.
Liberia is divided into 15 counties with an estimated country wide population of 3.5
million. The project landing site is located in the Montserrado county (Figure 6-3).
Figure 6-1: Location of Liberia in Africa
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
37 November, 2010
Figure 6-2: Location of Liberia among Neighbouring Countries
Figure 6-3: Liberian Counties
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
38 November, 2010
6.2 Topography
Liberia can be divided into three distinct topographical areas. Moving landward
from the coast, first is a flat coastal plain which extends up to 80 km inland, with
creeks, lagoons, and mangrove swamps; second, an area of broken, forested hills
with altitudes from 180–370 m, which covers most of the country; and third, an area
of mountains in the northern highlands, with elevations reaching 1,384 m.
The proposed project will occur in the region of Liberia known as the flat Coastal
Plain. It is the land region of the country just next to the Atlantic Ocean. Indeed, the
selected landing site is less than 50 meters from the Atlantic Ocean.
6.3 Geology and Soils
The project area is located in what is known as the Pan African Age Province. The
rock type in this region is less than 500 million years. There is a zone of fluvial and
deltaic deposit which extends from the Freeport of Monrovia. This zone comprises
buff silt and sand deposits, which are characteristic of very low terrain along the
coast.
The preferred landing site is composed mainly of beach sand, nearly pure white
quartz sand, less than 5 meters in thickness and above sea level. The soil profile in
the project area is uniform. There is mostly one unit of soil, the sandy soil
The main types of soils found in Liberia include: latosols, which are of low to
medium fertility, sandy soils or regosols, which are infertile; shallow, coarse lithosols
found in hilly and rugged terrain; highly fertile alluvial soils which are suitable for
agriculture; and humus-rich swamp soils. In general, the soils are characterized by a
shallow layer of humus content and high acidity as a result of deficiency in
magnesium and calcium
6.4 Climate
As is the case with the rest of Liberia the climate of the project area is tropical and
humid, with little change in temperature throughout the year. The temperature
rarely exceeds 36oC (97oF) or falls below 23oC (73.4oF), with a mean annual
temperature of about 26oC (78.8oF). Figure 6-4 shows a graph of the annual climate
distribution of Liberia.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
39 November, 2010
(Source: Climatetemp.info)
Figure 6-4: Annual Climate Distribution of Liberia
The climate of the project area is characterized by a monsoon (wet) season and a dry
season. The monsoon season extends from late April through October, with the
majority of the rainfall occurring between mid-April and mid-October. During this
time frame the average humidity is about 82%. The dry season extends from mid-
October to mid-April.
During the dry season, the average humidity is 78%; however, it may drop to 50% or
lower between December and March when the dust-laden Harmattan winds blow
from the Sahara. Wind velocity is greatest in the rainy season and lowest in the dry
season.
6.5 Marine and Coastal Wildlife
Liberia animal life is exceptionally diverse, with a high population of species that are
endangered outside the country. There are approximately 125 mammal species, 590
bird species, 165 native fish species, 74 unknown reptiles and amphibians and over
1000 described insects species in Liberia.
In December 1999, the Global Environmental Facility (GEF) funded West African
Conservation priority-setting exercise for the Upper Guinea Ecosystem. The project
identified Liberia as a top priority country in West Africa for conservation purposes
since 41 percent of its area is designated as being of exceptionally high biological
importance.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
40 November, 2010
The rich wildlife population of the coastal area is currently threatened by two major
factors: first, loss and fragmentation of habitat caused by deforestation resulting
from uncontrolled logging, construction of logging road network, and slash-and
burn agriculture. Secondly, marine wildlife remains a critical source of protein for
rural Liberians, as well as a cash income earner. Animals of all sizes and species are
indiscriminately hunted and killed, caught in snares (traps) and eaten locally. Raw
and smoked meats are also sent to urban centers or across the border for sale in the
markets although hunting is governed by a permit system managed by the Wildlife
and National Parks Division of the Forestry Development Authority (FDA).
Logistical reasons and a lack of implementation and enforcement of legislation have
been problematic. On the other hand, marine resources are not protected by any
conservation practices or legislation. The emphasis is on fishing licensing for the
sole purpose of revenue generation for the government.
6.5.1 Marine Species
Liberia is rich in marine species including mollusks and crustaceans, small mammals
such as statungas, other, atilax paludinosus, dasymys incomtus, and large mammals
such as cephalophus ep. Mollusks found in this habitat include crassostrea gasar
clams), arca senilis (volutes), cymbium pepo, cones, cowries and conches.
These mollusks form all-important basis for fish and bird food chains as well as
being a major food source for humans. Mangroves also habor some species of
crocodiles and the endangered West African manatee, tichechus senegalese.
Four of the seven remaining species of marine turtles in the world can be found in
Liberia where they lay eggs at selected places along the shores. The four species are
the Atlantic Green Turtle Chelonian Mydas), the leather back (Dermochelys
Coriacea), the Hawksbill (Eretmochelys Imbricate) and the Olive Ridley
(Lepidochelys Olvacea). The Green Turtles are classified as endangered and the
Hawksbill. Turtles are classified as critically endangered (WCMC, 1996). Despite
international initiatives to protect these endangered species, marine turtles are still
secretly hunted for food throughout Liberia. Their eggs are also collected by humans
and destroyed by dogs and pigs on the beaches.
There has not yet been any fish stock assessment undertaken for the country to
standardize fisheries resources.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
41 November, 2010
6.6 Threats to Coastal and Marine Resources
The coastline of Liberia is 560 kilometers long and about 58% of its population lives
along the coasts. With a continental shelve area of 14,894km2 and territorial sea
produces annually 7,616 metric tons of fish and 126 metric tons of mollusks and
crustaceans. The coastal area consists of swamp-related vegetation, which includes
mangroves forests and savannah related vegetation that extends 25 miles inland.
The coastal area and marine environments are subjected to a variety of pressures
such as erosion due to sand mining, oil pollution, waste dumps, human settlement
and the discharge of municipal wastes due to lack of proper water and
environmental sanitation facilities.
Except for few places in southeastern Liberia, primary mangrove has been replaced
by secondary ones. Much of the mangroves destruction appears to concentrate along
the edges of creeks, river, and estuaries and particularly more wide spread around
the large towns and cities such as Monrovia, Robertsport, Greenville, Harper and
Rivercess. The coastal ecosystem is under severe threat as a result of habitat loss and
fragmentation caused by the deforestation, excessive hunting and poaching of wild
animals for protein sources. Excessive hunting and poaching have eliminated most
animal species especially in areas that are accessible. The deforestation has been
estimated at an annual rate of 3% as a result of uncontrolled logging, shifting
cultivation and establishment of plantation.
Invasive species identified in the country are the water hyacinth (Eichornia
Crossipes), Nile Salad, Lececenea Leucocephalus and Chromoleana Odorata. The
most offensive of these are the water hyacinth and often covers the entire surface of
water bodies near towns and villages.
6.7 Governance
Liberia has a Republican form of government, similar to that of the United States of
America. There are three (3) branches of government: the Executive, the Legislative
and the Judicial Branches. The Legislative Branch is responsible for making law and
legislations; the Judiciary is responsible for interpreting laws and operates the court
systems; and the Executive is responsible for the management and enforcement of
laws of the country.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
42 November, 2010
The Executive Branch is headed by the President and comprises of ministries and
agencies. One of such ministries is the Ministry of Internal affairs, whose minister is
appointed by the President.
The Ministry of Internal Affairs through its Superintendents administers the fifteen
(15) counties of Liberia, assisted by other local officials. The Superintendent is
appointed by the President of Liberia, along with the Development Superintendent
and Commissioners. The Paramount chiefs, Clan Chiefs and Town chiefs are elected
by the people in keeping with the laws of Liberia. Figure 6-5 illustrates the local
administration.
Figure 6-5: Flow Chart of Local Administration
6.8 Ethnic Groups
Liberia is comprised of approximately seventeen (17) major tribal groups divided
into categories shown in Table 6-1. Figure 6-6 shows their distribution across the
country.
Table 6-1: Ethnic Groups and Tribes of Liberia Regional Groups Tribes
Mel Speaking Gola and Kissi
Kwa (Kru) Speaking Bassa, Belle, Dei, Grebo, Krahn and Kru
Mande-fu Speaking Gbandi, Gio, Kpelle, Lorma, Mano and Mande
Mande-tan Speaking Mandingo and Vai
English Speaking Descendants of the settlers
Superintendent
District Commissioner
Township
Commissioner
Clan Chief
Paramount Chief
General Town chief
Development Superintendent
Town Chief
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
43 November, 2010
The majority of the tribal people of Liberia emigrated from ancient empires in West
Africa, namely Ghana, Songhai and Mali Empires. As these empires failed and
internal and regional conflicts ensued, the tribal people migrated toward the south
and settled in what is today Liberia. The English-speaking people were however
descendents of former slaves brought from the United States of America
Figure 6-6: Distribution of Liberian Ethnic Groups Across the Country
While the rest of the tribal groups are spread across the country, the English-
speaking people settled mainly in Monrovia and surrounding settlements and major
towns along the coast.
The largest tribal group in Liberia is the Kpelle, followed by the Bassa, Grebo, Gio,
Mano, Kru and Lorma. Of the approximately 3.5 million people, Montserrado and
Grand Kru counties are the most populated and under populated counties with a
total population of 1,118,241 and 57,913 respectively in the final census results of
2008.
Because of intermarriage and an aggressive national unification program, tribal
divisions are rapidly becoming less distinct, especially around the capital.
Nevertheless, there is a strong tendency among the indigenous people to preserve
their tribal identities.
6.9 Culture
The culture of Liberia reflects this nation's diverse ethnicities and long history.
Liberia was founded by freed slaves that returned from the United States of America
and other areas. However, before the coming of the freed slaves, the land area of
Liberia was inhabited by people from the ancient empires of West Africa.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
44 November, 2010
The official language of Liberia is English. There are also more than 16 indigenous
languages, a few of which have their own unique alphabets. Among the most widely
studied Liberian languages in schools and universities are Bassa and Vai languages
and to a lesser extent, Kpelle. Loma and Mende also have their own unique
alphabets but are studied less. Both languages are noted for their unique alphabets
and phonetics.
The different tribal groups of Liberia have their own distinct culture. However,
some cultural practices are common to many groups.
Rice is by far the most important staple of Liberians. However, as a primarily
agrarian culture Liberia does produce and eat cassava, bananas, citrus fruit,
plantains and coconut. Sweet potatoes and fish are are also an important part of
Liberian meal.
Liberia is renowned for its detailed decorative and ornate masks, large and
miniature wood carvings of realistic human faces, people, scenes of everyday life
and accessories particularly combs, spoons and forks which are often enlarged
sculptures. Sculptures are produced in both the countryside and cities. Due to its
strong relationship with the United States, Liberia‟s culture, particularly along the
coastal areas, has been influenced by American culture.
Liberia has its own ancient music and instruments. While Liberian music is part of
wider West African music heritage, it is also distinct from its neighbors. Christian
music is heavily influenced by its counterpart in United States regardless of region.
6.10 Religion
Liberia was established by freed slaves returning from the United States of America.
Most of those returning were Christians. Upon their interaction with natives, they
evangelized them, thus raising the Christian population. Interaction with European
sailors and missionaries also led to Christianization of Liberia.
Liberia has always been recognized as a Christian country, but the Constitution of
1986 presents Liberia as a secular nation. Christianity of various denominations is
the largest religious group in Liberia. The recent population censor of 2008 shows
that of the approximately 3.5 million people, 2,975,675 or 85.6% are Christians. There
are 424,685 or 12.2% Muslims, according to the report. The remaining 2% of
Liberians subscribe to traditional beliefs, other religions or no religion.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
45 November, 2010
6.11 Macro Economy and Livelihood
Liberia is one of the world's poorest countries, with a formal employment rate of
only 15%. Historically, the Liberian economy depended heavily on iron ore and
rubber exports, foreign direct investment, and exports of other natural resources,
such as timber. Agricultural products include livestock (goats, pigs, cattle) and rice,
the staple food. Fish are raised on inland farms and caught along the coast. Other
foods are imported to support the population.
While official export figures for commodities declined during the 1990s‟ civil war as
many investors fled, Liberia's wartime economy featured the exploitation of the
region's diamond wealth.
Other commodity exports continued during the war, in part due to illicit agreements
between Liberia's warlords and foreign concessionaires. Looting and war
profiteering destroyed nearly the entire infrastructure of the country, such that the
Monrovian capital was without running water and electricity (except for fuel-
powered generators) by the time the first elected post-war government began to
institute development and reforms in 2006.
Once the hostilities ended, some official exporting and legitimate business activity
resumed. For instance, Liberia signed a new deal with steel giant ArcelorMittal for
the export of iron ore in summer 2005. But, as of mid-2006 Liberia was still
dependent on foreign aid, and had a debt of $3.5 billion, which has recently been
written off by international and bilateral partners.
The Liberia dollar currently trades against the US dollar at a ratio of 71:1. Liberia
used the US dollar as its currency from 1943 until 1982. Liberia is trying to revive its
economy post civil war. Various sanctions imposed by UN on diamond and timber
exports were removed by 2007. The country has the second-largest maritime registry
in the world, with some 3500 vessels registered under its flag (over 110 million gross
tons).
Liberia continues to suffer with poor economic performance due to a fragile security
situation, the devastation wrought by its long war, its lack of infrastructure, and
necessary human capital to help the country recover from the scourges of conflict
and corruption. However, since the election of the Ellen Johnson-Sirleaf government
in 2005, the country has signed several multi-billion dollar concession agreements
with numerous multinational corporations, including BHP Billiton, ArcelorMittal,
Chevron and APM Terminals.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
46 November, 2010
6.12 Health Situation
Many years of civil crisis adversely affected Liberia in various respects, including the
health sector. This sector experienced extensive destruction of its infrastructure, the
displacement of health personnel, the massive looting and destruction of equipment,
including drugs and medical supplies.
Pervasive poverty, coupled with the effects of the war and the low level of funding
of the health sector by the national government has grossly affected the level and
quality of health services. This has accounted for the major causes of the country‟s
high morbidity and mortality rates. The situation is worse in the rural areas, where
health services have greatly deteriorated or non-existence.
Malaria, diarrhea, acute respiratory infections, neonatal tetanus, measles and
malnutrition are the major causes of morbidity. Malaria is the leading cause of death
and accounts for over 40% of all cases dealt with in health facilities. Those with the
highest risk to malaria are pregnant women, children and people with compromised
immunity such as those living with HIV/AIDS.
The gross insufficiency of midwifery and inadequacy of medical staff, and the
limited functional health facility have limited access to quality maternal and child
health care services. Currently, HIV/AIDS is estimated at 8.2% of the population.
Prior to 1990, the government provided about 60% of health care services with the
remaining 40% being provided by religious missions and non-governmental
organizations. Church-sponsored facilities were the forerunners.
Currently, non-governmental organizations (NGOs) are contributing immensely to
the health sector, as the capacities of the government and religious-missions have
eroded significantly due to the years of war. However, the government has begun
tremendous effort to revamp the health sector with the construction of medical
facilities across the country and provision of equipment and drugs.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
47 November, 2010
CHAPTER SEVEN
STAKEHOLDER ENGAGEMENT AND PUBLIC DISCLOSURE
7.1 Stakeholder Identification
Stakeholder engagement has been increasingly identified as a key to business
success both within private and government sectors. The IFC (2007) defines
"stakeholder engagement” as a means of describing a broader, more inclusive, and
continuous process between a company and those potentially impacted, that
encompasses a range of activities and approaches, and spans the entire life of a
project.
The LTA recognizes that stakeholder involvement is an important element of the
overall Environmental Assessment process for the ACE Cable Project in Liberia, and
that stakeholder identification and analysis at an early stage of a project is critical in
the assessment of interests, concerns, relationships, assumptions, their level of
influence and the ways in which they affect project risks.
For the ACE Project, a contemporary definition of stakeholders is used thus: those
individuals or organisations, who can influence the project and who the project can
impact either positively or negatively.
Through wide consultation therefore, the LTA seeks to achieve public involvement
for better and more acceptable decision making especially with regard to the
sustainability, scope, significance and mitigation of adverse project-impacts.
Consultation and stakeholder engagement have been pursued positively with the
aim of utilizing outputs to assure the overall sustainability of the project and
improve environmental management planning. Additionally, it is anticipated that
early consultation as embarked upon by the LTA will lay the foundation for ongoing
positive relationships regarding the project, among the variety of stakeholders.
Stakeholder identification and engagement commenced early, from project
conceptualization and will be continuous throughout its implementation.
A number of key stakeholders have so far been identified. They fall into various
categories as shown in Table 7-1.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
48 November, 2010
Table 7-1: ACE Cable Project in Liberia - Stakeholder Categories
Stakeholder Category Description Functions/Role
i Federal Government
Agencies
Liberian Telecommunications
Authority (LTA)
Regulates the telecommunications industry in
Liberia, issues licenses to operators, monitors
their activities and advises the Minister on
policy for telecommunications.
Liberia Telecommunications
Corporation (LIBTELCO)
LIBTELCO is Liberia’s National Operator and
sole licensed fixed line telephone provider in
the country. LIBTELCO is the incumbent fixed
lines and associated communications services
provider. Corporation is part of the CCL to
implement the ACE Project in Liberia
Ministry of Postal Affairs Has authority over all telecommunication
activities in the country. Is also the national
partner, liaising with international
organizations for the connection ACE Project.
Supervises activities of the Liberia
Telecommunication Authority (LTA), which is
implementing the connection
ii Ministry of Defense The ministry is responsible for the national
defense and protection of the country. Any
communication installation of this nature has
significant effect on national security. Further,
the landing site is expected to be near the
ministry’s location.
iv Ministry of Internal Affairs Formulates and implements policies relating
to defense, security, law and order. Is also
responsible for immigration. The Ministry
approved the preferred landing site for the
ACE Cable Project in Monrovia.
Environmental Protection
Agency (EPA)
The principal authority in Liberia responsible
for management of the environment. To
coordinate, monitor, supervise and consult
with relevant stakeholders on all activities in
the protection of the environment and
sustainable use of natural resources.
Liberian Maritime Authority
(LMA)
Formerly Bureau of Maritime, has the
statutory mandate to Control Marine Safety
& Environment. Under this mandate, the
LMA has control over all coastal state
obligations. Some of these activities include
Marine Pollution Prevention and Maritime
Security.
v Financial Institutions World Bank, Liberian Banks, Provide funding and advisory services for
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
49 November, 2010
Financial Intermediaries aspects of the project implementation in
Liberia
vi Private Sector Members of the Cable
Consortium of Liberia
Participate in the planning, decision making
and funding in relation to technical and
administrative aspects of the project
vii Civil Society Groups
(CSO)
All non-market and non-state
organizations and structures in
which people organize to
pursue shared objectives and
ideals e.g., farmers, fishers,
professional associations,
Community based
organizations (CBOs),
religious groups, research
institutions, legal practitioners
and others
May be involved in information dissemination,
organizing focus groups, monitoring project
implementation with regard to its social
interactions and benefits.
viii The General Public Any interested or potentially
affected individual or group
Express concerns on project impacts and also
provide suggestions on sustainable options
7.2 Stakeholder Engagement Phases
Stakeholder engagement for the project will be carried out at various levels as the
project progresses. Stakeholder engagements include consultations government
agencies, key individuals in the metropolis, and focus group discussions.
Planning Phase Engagement - This stakeholder engagement commenced at the
project conceptualization and involved discussions among the relevant stakeholders
(e.g., LTA, LIBTELCO, World Bank, EPA and CCL members) on the general
technical and administrative aspects of the project, and environmental and social
safeguard requirements were also covered. Meetings were also held with key
officials to appreciate concerns over project implementation and issues for special
focus.
Implementation Stage Consultations – This will include workshop type meetings or
one-on-one interviews with key individuals to discuss overall project
implementation plans including possible environmental and social interactions
while also eliciting opinions and options for sustainable project implementation
from meeting attendees. Consultations at this stage will cover the general public,
NGOs, CSOs, opinion leaders, the EPA and others.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
50 November, 2010
7.3 General Guidelines for Stakeholder Engagement
The general approach to stakeholder consultation and engagement should be
participatory and embrace the following key elements of successful public
involvement in EIA.
Proper identification of stakeholders using definition provided earlier
Profiling of stakeholders including their description, and identification of key
contact persons and details
Selection of suitable venue and timing for stakeholder meetings to allow and
encourage participation of maximum attendance and free exchange of ideas
by all stakeholders.
Provision of sufficient relevant information in an easy to understand (non
technical) format.
Allowing sufficient time for stakeholders to read, discuss and provide input
on the information provided.
Providing response (where available) on issues raised during stakeholder
interactions and as may be necessary, committing to provide responses to un
answered issues within a given time.
Obtaining feedback from stakeholders on agreed action items from earlier
stakeholder engagement meetings.
7.4 ESMF Disclosure
Environmental Assessment procedures of the Liberia EPA and the World Bank
require public disclosure of project details, impacts and measures to mitigate them.
To this end, environmental reports for ACE Project will be made available to project
affected groups, local NGOs, and the public at large. Starting with this ESMF, copies
of the environmental reports on the project will be made available to the public at
selected locations for information and comments. Members of the public will be
notified of report displays through electronic and print media. Such notification
should provide:
Title and brief description of the Project;
List of venues where the ESMF report is on display and available for viewing;
Duration of the display period; and
Contact details and procedure for comments.
The substantive project EIA will be similarly disclosed upon completion of a
satisfactory report in accordance with EPA and World Bank requirements.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
51 November, 2010
CHAPTER EIGHT
ENVIRONMENTAL IMPACT ASSESSMENT
This Chapter discusses the possible environmental and social impacts of the Ace
Cable Project in Liberia on the biophysical and social (including health)
environment. The discussion covers both positive and adverse impacts.
8.1 Positive Impacts
If successfully implemented, the ACE Cable project is set to provide a number of
direct and indirect benefits to Liberia. Although anticipated benefits will be in the
area of economic growth and improved human development, some environmental
benefits are expected. Benefits have been discussed in Chapter 5.
8.2 Potential and Associated Adverse Impacts
Adverse impact analysis of the ACE Cable Project in Liberia has been carried out
using typical, known project activities and how they interact with the environment.
Impact analysis has involved impact identification and qualitative assessment using
indicators. For this ESMF, quantitative impact analysis is not possible and has not
been carried out.
Air Quality - Impacts to air quality may occur during cable laying as a result of
combustion engines such as diesel-powered generators used for the cable laying
ship and from dust if the cable is landed on shore during the dry season.
Landscape and Visual Receptors - Cable laying activities will lead to minimal
increased light both in deepwaters and shallower areas.
Noise and Vibration Receptors - There may be some increased noise in the marine
environment and shore landing area during construction activities. Impacts to
sensitive local receptors such as nearby residences may also minimally occur due to
Protected Areas – Protected areas are locations which receive protection because of
their environmental, cultural or similar value. A large number of kinds of protected
areas exist, which vary by level of protection and by the enabling laws of each
country or rules of international organization. Examples include parks, reserves and
wildlife sanctuaries. There are no known marine or terrestrial protected areas within
the project‟s area of influence
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
52 November, 2010
Geology and Soils –Trenching and ploughing for cable installation will cause some
minor physical impact on sea bed geology. Onshore, there will be some soil
excavation over a small area around the landing site.
Marine Biology and Fisheries - Some minor disturbance to marine sediments and
benthos will occur during surveys and cable installation activities as a result of
coring, trenching or ploughing and when the cable is installed on the sea bed. Thes
activities could lead to temporary water quality impairment which in turn affects
fish and other marine biota.
Vulnerable Groups – According to the World Bank (2005), a vulnerable group is a
population that has some specific characteristics that make it at higher risk of falling
into poverty than others living in areas targeted by a project. Vulnerable groups
include the elderly, the mentally and physically disabled, at-risk children and youth,
ex-combatants, internally displaced people and returning refugees, HIV/AIDS-
affected individuals and households, religious and ethnic minorities and, in some
societies, women.
Cultural Heritage - There are no known sites of significant cultural heritage or
archaeological interest within the project‟s area of influence both onshore and in the
marine environment. Some cultural heritage could be buried and encountered
during excavation on land or by trench ploughing at sea (e.g., coastal wrecks).
Infrastructure – Existing marine infrastructure (if any) such as other submarine
cables and pipelines could be damaged during surveys and cable-laying if their
routes are not identified a priori and avoided.
Transportation - Cable surveys and installation could lead to temporary disruption
to the flow of shipping traffic and other users in the nearshore environment.
Similarly, road traffic disruptions may occur during onshore based construction
Economic Activities – Marine based activities such as those to be carried out as part
of the ACE Cable Project could affect fishing and other socio-economic activities if
within the project‟s area of influence.
Solid Wastes Generation and Handling - Waste management is perhaps one of the
most challenging environmental problems facing Liberia. In many areas, wastes are
comingled and dumped indiscriminately on the road side, in open unlined dump
sites, in inland and coastal waters and in constructed drainage lines. Thankfully,
only minimal wastes will be generated from the ACE Cable landing project. Wastes
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
53 November, 2010
from marine based activities will handled in accordance with statutory shipping and
maritime laws, while land based waste will require appropriate waste handling
plans.
Use of Natural Resources – The ACE Cable Project will not lead to unsustainable
use of any natural resources.
Population Influx - The construction phase of many projects requires a relatively
large number of construction workers. Much more than urban areas, rural and peri
urban areas typically feel the effects of the resulting influx of people, whose
population comprises project workers and job seekers. Others are itinerant traders.
Thus while there is often increased commerce around project areas, some types of
infrastructure (e.g., housing, transport, health care and others) become stretched as
these social services are often inadequate for the pre-project population and become
even more stretched as a result of project-associated influx. Additionally, social
pathologies such as crime, prostitution, erosion of traditional authority are well
known risks associated with influx and so are health risks from increased
communicable and non-communicable diseases and HIV/AIDS. Infractions on
cultural norms and beliefs, and changes in the micro-economic structure leading to
increased prices of general goods and services in affected areas have also been
recorded.
Labour Relations – The ACE Cable Project will involve hiring and disengagement of
workers at various stages of the project implementation. Conflicts between the
project owner or contractor and locals are known to occur during project
implementation. UNDP, 2006 suggests that conflicts associated with labour relations
can be caused by:
Dissatisfaction among local populations on the quantum and sharing of
employment; and
Disengagement of workers hired over relatively short periods (less than 0-
3years) leading to boom-bust situations
Further, child labour has been observed at some construction sites while in other
areas, there is discrimination against women or other ethnic groups. These practices
contravene Liberian World Bank statutory requirements on labour.
Occupational and Public Health - Infrastructure projects present several
occupational health hazards. The public including communities are also exposed to
some of these hazards. Health hazards may be either, physical, chemical or
biological. Common examples are shown in Table 8-1.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
54 November, 2010
Table 8-1: Types of Project -Related Occupational and Public Health Hazards
Physical Hazards Chemical Hazards Biological Hazards
Increased vehicle and boat accidents
Accidental chemical, fuel and other spills
Release of biological agents
Increased noise - Fire and Explosions
Rotating and moving equipment
Environment temperature
Poor ergonomics
Welding/hot work
Working in water bodies
Accidents cause direct impacts through physical harm to affected persons or
indirectly, impairment of livelihood base as in the case of chemicals or oil spilled in
farmlands and water bodies. Dependants of affected persons will also suffer if
accidents result in significant time away from work. In addition, hazards leading to
permanent disability or death can threaten the success or timely delivery of
infrastructure projects. Adverse occupational and community health incidents can
therefore lead to more costly projects with severe implications for the project owner.
Biodiversity Loss, Endangered and Exotic Species - The loss of the world's
biological diversity is causing major concern worldwide (Pearce and Moran, 1994).
They also suggest that the global rate of biodiversity loss is directly related to the
expanding human niche. Liberia‟s rich biodiversity is currently being threatened by
various factors. Exotic non-native species such as water hyacinth are also threats.
Moreover, four of the globally listed endangered turtle species nest on Liberian
coasts. The ACE Cable Project can further contribute to the biodiversity challenge
through impacts on turtles during construction and the inadvertent introduction of
non native species.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
55 November, 2010
CHAPTER NINE
IMPACT MITIGATION
9.1 Introduction
Mitigation measures are actions taken to enhance positive impacts and minimize
negative ones. They aim to improve the environmental and social sustainability of a
project. Depending on the nature of the impact they seek to address, they can
already be applied during the design, strategic planning or implementation stage of
the project. To assure environmental sustainability, mitigation measures are
implemented on a continuous basis through the project‟s life-cycle.
The approach to mitigating adverse impacts of the ACE Cable Landing Project in
Liberia is to proactively design strategic measures which can be applied at the
overall project stage and the individual project activities.
Impact mitigation measures proffered in this report are general guidelines for
dealing project impacts. As has been considered appropriate and practical, the
following principles have been taken into consideration.
Design changes
Avoidance
Preservation
Minimization
Rehabilitation
Restoration
Replacement
Resource compensation
Improvement
Development
Diversification
It is noted that the application of each mitigation measure will be affected by
differences in project types, and environmental and social nuances. Moreover, some
measures may be too costly or completely impractical to implement under certain
conditions. In pursuing any of the proffered mitigation measures, therefore, it is
important for the project further assess the following:
Feasibility;
Ease of implementation;
Local suitability;
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
56 November, 2010
Institutional requirements;
Training requirements;
Monitoring requirements;
Cost (capital and operating); and
Cost-effectiveness.
9.2 Project Mitigation Principles
Chapter 8 identified a number of typical project-environment interactions associated
with the ACE Project. Details of the project construction activities are not known and
so the magnitude, frequency, duration and other characteristics of the interactions
cannot be discussed at this stage. However, the general approach to mitigating
adverse impacts will generally be similar regardless of which construction options
are finally selected. Table 9-1 provides generic impact mitigation
principles/measures for possible project impacts.
Table 9-1: Impact Mitigation Principles for Sub Project Activities
Possible Cause of Impact
Type of Impact Impact Mitigation Principles
Increased Traffic
Hardship to other road/waterway users and lost productive time
- As much as possible plan work for least busy hours
- Work with appropriate authorities to Implement traffic procedures that help reduce jams and bottle necks
- Train drivers and enforce their compliance with traffic rules
- Where possible, work with relevant authorities to establish effective alternative routes especially in urban areas
- In rural areas, provide support to rural dwellers to reduce the burden of increased traffic
- Notify other road/water way users on plans
Economic displacement - As much as possible plan work for least busy hours
- Notify other road/waterway users and other affected persons of possible effects
- Avoid active fishing areas - If traffic will cause sustained impacts on
livelihood, compensate affected persons in accordance with the Program's Resettlement Framework
Air Emissions
Air Pollution - Ensure combustion engines used on the project are serviced and running efficiently
- Select technologies that meet applicable air emissions standards (Liberia and World Bank)
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
57 November, 2010
Table 9-1: Impact Mitigation Principles for Sub Project Activities
Possible Cause of Impact
Type of Impact Impact Mitigation Principles
- If working during dry season, implement dust reduction procedures
- If working in arid environments, implement dust reduction measures
- If working with batching plants, implement suspended particle reduction procedures
- Model GHG balance for carbon intensive projects
- Model air quality for projects that interact significantly with air (e.g., power, oil and gas, waste management)
Noise
Noise Pollution/Hearing Impairment
- Use combustion engines fitted with noise mufflers
- As much as possible, avoid nighttime work - Erect noise barriers for projects with
extensive noise - Model noise levels for project operations
- Comply with applicable noise standards
Solid Wastes
Soil and water pollution and odour
- Identify expected solid waste streams and characterize
- Develop waste management plan for all solid wastes
- Maintain a cradle to grave approach for solid waste
- Use only approved waste management contractors
- Dispose wastes only in accordance with regulatory requirements
- Monitor waste handling by waste contractors
Use of Natural Resources
Changes to natural resources availability and supported functions
- Consider using designs that limit use of natural resources
- Model use of natural resources such as surface and ground water to determine safe threshold
Chemical Handling Chemical pollution and health hazards
- Identify and characterize all chemicals to be used during all project phases
- Prohibit the use of banned chemicals e.g.,
- Develop and implement chemical handling and disposal plans for all chemicals
- Ensure proper storage and labeling of chemicals on project sites and when being transported
Labour Relations
Poor wage structure, conflicts and boom-bust scenario
- Develop hiring and disengagement plans for all project work in accordance with core labour standards and other applicable labour regulations
- Consider local area and cultural sensitivities when hiring labour
- Implement a disengagement strategy to
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
58 November, 2010
Table 9-1: Impact Mitigation Principles for Sub Project Activities
Possible Cause of Impact
Type of Impact Impact Mitigation Principles
address the boom-bust situation - Implement a grievance mechanism for
labour issues
Population Influx
Inflation in local area, pressure in infrastructure, increase in disease burden including HIV /AIDS, desecration of cultural sites, conflicts, erosion of traditional authority structure
- As much as possible use workers from the local area around the project
- If project will result in significant influx, implement influx management plan which addresses: inflation, pressure on infrastructure, increase in social pathologies (e.g., crime, prostitution, increased disease burden
- Provide HIV/AIDS awareness program and materials to workers and public
- Give non-local area workers orientation on cultural norms
- Respect traditional beliefs and festival days
Occupational and Public Health
Occupational and Public Health Hazards
- Develop and enforce occupational health/safety policy and plans for all project activities. As may be applicable, plan should address: use of personal protection equipment (e.g., for hearing, gloves, coveralls, hard hats, safety shoes, goggles)
- Monitor compliance with safety plans - Maintain applicable standards on exposure
to all types of radiation - Maintain minimum life saving equipment on
facility as required by appropriate law - Maintain workers health care program
including clinic on or around work site - Maintain retainership for workers with well
equipped hospital - Maintain signage around work areas
including traffic routes for public - Regularly provide early warning to the
public on movement of heavy equipment and vehicles
- Maintain applicable minimum standards on distances from dwelling and work areas, for installation of various facilities
- Work with minimum safety standards for fire and prevention
- Maintain minimum fire fighting facilities commensurate to type of fire hazard exposure
- Maintain and implement emergency contingency plan including chemical and oil spill contingency plan where applicable
- Store combustible and other hazardous materials in accordance with approved procedures
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
59 November, 2010
Table 9-1: Impact Mitigation Principles for Sub Project Activities
Possible Cause of Impact
Type of Impact Impact Mitigation Principles
Biodiversity, Endangered and Exotic Species
Biodiversity loss, threat to endangered species, invasion of non-native species
- As much as possible, avoid critical habitats - If high biodiversity areas are affected,
compensate by supporting conservation initiatives in association with locals
- Develop and implement biodiversity action plan
- If working around beaches, identify nesting areas and implement turtle conservation plans
- Ensure visiting ships discharge ballast waters outside coastal areas
Vulnerable Groups
Susceptibility to increased poverty and deprivation
- Identify and profile vulnerable groups in the project area
- Develop plans to support vulnerable groups during project implementation
Cultural Resources Desecration of cultural sites, loss of cultural resources
- Identify cultural resources around project areas
- Implement chance find procedure - Design and implement appropriate
grievance mechanism in consultation with affected persons
- Develop and implement relocation procedures in consultation with affected persons
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
60 November, 2010
CHAPTER TEN
ENVIRONMENTAL AND SOCIAL MANAGEMENT
IMPLEMENTATION PROCESS
10.1 Overview of ESMF Implementation Process
This ESMF document incorporates a number of elements into an overall
Environmental and Social Management process for the ACE Cable Project in Liberia.
The process involves distinct steps and associated activities that are linked to deliver
a robust and veritable management framework in line with the stated objectives of
the ESMF. Table 10-1 below gives an overview of the processes, linkages and
responsible parties for each element of the process.
Table 10-1: Elements of Environmental and Social Management Process
Element Chapter in
ESMF Report
Project Phase Responsible Party
Environmental
Screening
Chapter 10 At the conceptual stage of the
project
LTA in consultation with World Bank
and Liberia EPA
Environmental Impact
Assessment
Chapter 10 Upon completion of negotiation
and tendering and after contract
and financial close-out but prior
to commencement of activities.
CCL in accordance with minimum
scope of work for EIA as agreed with
EPA and World Bank
Environmental
Management Plan
Chapter 10 At tendering and negotiating
stage
As part of EIA for the Project
Contractors and CCL
Training and Capacity
Building
Chapter 10 At the conceptual and planning
stage - Introduction to EA,
Screening, Scoping and
Budgeting for EIA,
Implementation stage -
Monitoring and Evaluation
LTA, EPA, CCL
Monitoring and
Evaluation
Chapter 10 Post EIA and after project
commences during Project
Governance
LTA, EPA, CCL
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
61 November, 2010
10.2 Project Screening and Categorization
10.2.1 Categorization for EIA
The ACE Cable Project will be required to go through Environmental and Social
(E&S) Screening in accordance with World Bank and the Liberian EPA procedures.
The screening can be carried out by a designated officer of the LTA. The screening
process will involve an assessment of the project to determine the appropriate
project categorization EA and applicable World Bank environmental and social safe
guards. Although it has been Categorized as B by the World Bank the project should
be screened to confirm category when project details become known.
The checklist to be used for this screening is shown below. In general, if the response
to two or more of the questions in the check list is yes, then the sub-project is
Categorized as A and will require a full Environmental Impact Assessment. The
Remarks column is used to provide additional information on the basis for the
categorization.
Table 10-2: Project Categorization Checklist for EA
Check Items Y N Remarks
1 Is the project situated in a sensitive environment e.g., wetlands wild lands or close to coral reefs?
2 Is the project situated in a conflict zone?
3 Will the project lead to direct pollutant discharges to air, water or land that could affect the carrying capacity of the environment (e.g., extensive air emissions, large volume of effluents, large volume of solid wastes).
4 Is the project currently or will expansion/enhancement make the project carbon-intensive?
5 Will the project result in large scale land clearing, loss/conversion of forest resources?
6 Does the project require large scale and extensive extraction of natural resources currently or in future e.g., ground water?
7 Will the project lead to involuntary physical or economic displacement?
8 Will the project affect natural biophysical processes such as hydrology and coastal dynamics?
9 Does the project generate hazardous wastes that cannot be handled locally?
10 Does the project portend significant security risks to employees or to the public?
If a sub project has been classified as A, then the LTA or sponsoring agency will be
required to:
i. Retain independent EA experts not affiliated with the project to carry out the
EA in accordance with Liberian regulatory and World Bank EA process;
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
62 November, 2010
ii. Engage an advisory panel of independent, internationally recognized
environmental specialists to advise on all aspects of the project relevant to
the EA if the project is highly risky or contentious or involves serious and
multidimensional environmental concerns;
iii. Convene an EA scoping meeting, which attendance will include EA
practitioners, regulatory authorities (Federal and State), potentially
affected stakeholders and selected NGOs;
iv. Ensure extensive stakeholder engagement for the project. The EA process will
include a stakeholder identification and engagement process;
v. Ensure that all EA Reports for Category A projects are not only duly
authorized by the Liberian environmental regulators but also the World
Bank.
vi. Ensure the EA Report includes a stand-alone Environmental Management
Plan that can be implemented.
Projects that do not meet two or more of the checklist criteria in Table 10-2 will be
either Category B or C Projects.
Category B Projects will result in adverse environmental impacts on human
populations or environmentally important areas--including wetlands, forests,
grasslands, and other natural habitats, that are less adverse than those of Category A
projects. In general, such impacts are localized, do not affect sensitive
area/resources, and reversible. All category B projects will also require EA.
However, the scope will be reduced but the PIU will also be required to:
i. Retain independent EA experts not affiliated with the project to carry out the
EIA in accordance with Liberian regulatory EIA process;
ii. Ensure appropriate stakeholder engagement for the project.
Category C - Projects are generally benign and typically do not require EA.
However, all such progress should be screened to determine if specific
environmental management plans (e.g., waste management plan) are required.
10.2.2 Applicable Standards, Limits and Permit Requirements
The project will also be screened to determine applicable occupational health,
environmental and other standards. The permitting requirements to implement the
project including estimated processing time will also be identified at this stage.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
63 November, 2010
10.2.3 Screening Report
At the end of the screening and scoping exercise, a Screening Report (SR) will be
prepared. The report will provide the following information that will be used for
decision making:
- Brief description of project
- Project Category for EA including rationale
- Applicable World Bank Safeguards
- Overview of anticipated wastes
- Indicative list of stakeholders to be engaged and guidelines for
engagement
- Applicable environmental standards e.g., for emissions, effluents and
others
- Permit requirements and typical timelines for obtaining each permit
- Discussion of existing liabilities including recommendations on
responsibility sharing
- Key environmental and social risks
The SR will be submitted to the LTA, CCL and EPA
10.3 Preparation of EIA Reports
The SR will among other things, establish the EA categorization, and environmental
and social performance standards applicable to a particular sub-project. All EA
studies will be required to comply with the EIA procedural guidelines of the Liberia
EPA (Appendix 1).
10.4 Environmental Management Plan
This EMP provides the procedures and processes that will be incorporated into the
CCL activities to check and continuously monitor compliance effectiveness of
commitments on mitigation and enhancement measures. In addition, the EMP
focuses on policy, management personnel, competence building, communications
with the public and monitoring and is used to ensure compliance with statutory
requirements on safety and environmental issues.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
64 November, 2010
10.4.1 Policy
The CCL should developed an Environmental and Social (E&S) Policy and a
Sustainability Commitment which together state the their commitment to
conducting business in a socially responsible and ethical manner, and to protecting
health, safety and the environment. In its E and S Policy, the LTA/CCL should
commit to:
i. Integrate health, safety and environmental matters into every aspect of its
activities and set objectives to drive continual improvement;
ii. Comply with all relevant health, safety and environmental laws and
regulations;
iii. Initiate and maintain effective arrangements for communication within the
organisation, other agencies, public or its agents and other stakeholders
regarding health, safety and environmental matters;
iv. Require relevant standards, good engineering practices and principles of risk
management to protect health, safety and the environment and to ensure
the integrity, reliability and efficiency of all sub projects;
v. Exhibit socially responsible leadership, demonstrate exemplary health, safety
and environmental performance and publicly report performance;
vi. Support loss prevention for assets and natural resources, and minimize the
impact of sub-project activities on the environment, by ensuring EA are
conducted on projects and ensuring responsible management of
emissions, discharges and waste streams. This includes efficient use of
energy.
vii. Identify present or future potential health, safety and environmental hazards
resulting from project activities, conduct risk assessments and select and
implement appropriate measures to manage the risks;
viii. Effectively communicate the health, safety and environmental
requirements to all contractors, and require them to manage E&S in
accordance with the LTA/CCL Policy;
ix. Ensure conformity with this policy by a comprehensive compliance program
including audits; and
x. Adequately resource health, safety and environment functions in the
LTA/CCL.
10.4.2 Environmental and Social (E &S) Management Department
The CCL will be required to establish an E and S Management Department that
defines roles, responsibilities and authority to put into practice the PIU's policies,
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
65 November, 2010
including undertaking any training necessary to do so. The specific roles of the key
positions in the unit are given in Table 10-3.
Table 10-3: Roles And Responsibility of Environmental and Social Management Officer
Designation Functions
Officer, E & S Management Department - Oversee and coordinate all activities pertaining to the Environmental and Social Management of the project;
- Ultimately responsible for mainstreaming environmental and social management into all project activities in accordance with this ESMF.
- Will report directly to the CEO of the CCL - Primary liaison person with other government agencies,
the public and other stakeholders on environmental and social issues.
- Prepare technical papers and other documentation to progress his/her functions
- Identify and coordinate training programs for employees and other stakeholders
- Develop effective monitoring procedure for E&S considerations
Assistant Officer, E &S Management Department
- He will support the Officer in carrying out his functions. - Act on behalf of the Officer in his absence - Conduct necessary research to mainstream E&S
considerations into overall program activities
10.4.3 Training
The CCL shall identify, plan, monitor, and record training needs for personnel
whose functions may have a direct or indirect impact on the environment or social
management policy.
The CCL will also ensure that all its employees have basic understanding of its
environmental, social, and health policy; potential impacts of the program, their
activities; roles and responsibilities in achieving conformance with the policy and
procedures.
This will be achieved through a formal training process. Employee training will
include awareness of and competency with respect to:
- Environmental Assessments
- Regulatory requirements on environmental issues
- Environmental due diligence
The E&S Officer is responsible for coordinating the training, maintaining employee-
training records, and ensuring that these are monitored and reviewed on a regular
basis. The Officer will also periodically verify that staff are performing competently
through discussion and observation.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
66 November, 2010
Given the nature of the environmental and social management requirements and
provisions outlined in this ESMF, competencies and capacity building will be
required in the following areas:
- Environmental Impact Assessment Process - Basic concepts,
screening, scoping, impact analysis, mitigation measure and
monitoring, reviewing EIA Reports
- Environmental Due Diligence - Types of due diligence, screening
projects for liabilities, scoping due diligence investigations and
reviewing due diligence reports
- Monitoring and Evaluation - Understanding the importance of
M&E in project implementation, M&E requirements for
environmental and social sustainability of projects
Training and capacity building may also be required for other project stakeholders.
To build the required capacity, it is critical that the CCL allocate sufficient resources
to training and capacity building especially at the early stage of the project. The
CCL's budget should therefore include adequate provision for training and capacity
building on an ongoing basis. Budgeting should cover:
- Trainer's fees
- Logistics (as may be applicable) - training location, accommodation,
transportation for participants and or trainers
- Useful resources
- Participation at seminars workshops
10.4.4 Communications
The E&S department is responsible for communications with the public and with
public stakeholder organizations on environmental and social issues.
With regard to E&S issues, the department facilitates dissemination of information
necessary to mitigate impacts through coordinating public notifications (e.g.,
meetings, media announcements, written postings) and through stakeholder
interaction.
The E&S Officer is responsible for communication on all E&S issues to and from
regulatory authorities. The CCL CEO is kept informed of such communications.
The E&S Officer will maintain a written register of stakeholder interactions to
effectively track communications and so that commitments made to follow up
actions can be tracked and implemented. This includes grievances that are also
tracked through the formal grievance procedure and communications that come
through other stakeholders.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
67 November, 2010
10.4.5 Monitoring and Reporting
Monitoring will be conducted to assure the project‟s compliance with mitigation
measures, and the effectiveness of operational controls and other measures intended
to mitigate potential adverse impacts.
Periodic Monitoring Reports shall be issued by the E&S Department on compliance
with mitigation measures.
10.5 Budget To Implement ESMF
To achieve the stated goals of this ESMF, it is important to identify financial resource
requirements even if indicative. This ensures upfront appreciation of the financial
requirements and allows early planning and budgeting accordingly.
An indicative budget (Table 10-4) has been prepared for the implementation of the
ESMF bearing in mind the elements that make up the implementation process
Assumptions to provide clarity on the basis of the budget have also been given. The
budget covers:
- Routine E & S duties of the CCL;
- Capacity Building for the CCL and other stakeholders;
- Engagement of Environmental and Social Specialists
- Environmental Impact Assessment (EIA) Studies
- Monitoring and Evaluation
Table 10-4: Estimated Annual Budget to Implement ESMF
ACE Project Stage
ESMF Requirements Budget Basis and Assumptions Total Cost per Annum (US$)
Project Management at CCL
Capacity Building for CCL Personnel
Two Training Programs held in-country
70,000
Meetings, Workshops and Stakeholder Engagement
Four large meetings and some one –on-one interactions
35000
Project Planning Stage
Environmental Screening of transactions
Screening and scoping in accordance with EPA requirements
15000
EIA Studies Assume Category B EIA 65000
Project Implementation Phase
Monitoring Compliance with EMP
Assume monitoring at start, midway and months after project implementations
45000
TOTAL Estimated Budget US$230,000
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
68 November, 2010
APPENDICES
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
69 November, 2010
APPENDIX 1
DOCUMENTS CONSULTED
Environmental Protection Agency of Liberia (2007) - National Report on the Marine
and Coastal Environment in Liberia
Ministry of Foreign Affairs Liberia (2003)- An Act Creating the Environment
Protection Agency of the Republic of Liberia
United Nations Environment Program (2000) - Municipal Solid Waste Management
in Liberia, Regional Overviews and Information Sources.
United States Agency for International Development (2002) -Annual Report.
UNDP (2000) - Human Development Report
UNEP (2004) - Desk Study on the Environment in Liberia
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
70 November, 2010
APPENDIX 2: THE ILLUSTRATED EPA EIA PROCESS
Figure A1: Illustrated Liberia EPA Process
PROPOSAL
IDENTIFICATION
SCREENING
NO EIA EIA REQUIRED INITIAL
ENVIRONMENTAL
EXAMINATION
SCOPING *PUBLIC INVOLVEMENT
*PUBLIC INVOLVEMENT TYPICALLY OCCURS AT THESE POINTS. IT MAY ALSO OCCUR AT ANY OTHER STAGE OF THE EIA PROCESS
IMPACT
ANALYSIS
MITIGATION & IMPACT MANAGEMENT
*PUBLIC INVOLVEMENT EIA REPORT
RESUBMIT INFORMATION FROM THIS PROC ESS CONTRIBUTES TO EFFECTIVE
FUTURE EIA REVIEW
REDESIGN
DECISION
MAKING
APPROVE
D
NOT
APPROVED
IMPLEMENTATION & FOLLOW UP
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
71 November, 2010
APPENDIX 3
GUIDELINES FOR PREPARING TERMS OF REFERENCE FOR AN
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) STUDY
1.0 INTRODUCTION
A Terms of Reference (TOR) is essentially a document that describes the purpose
and structure of a project, committee, meeting, negotiation, study or contract.
Standard EIA Process requires that project proponents prepare Terms of Reference
(TOR) for projects that require Environmental Impact Assessment (EIA). The TOR
should be submitted to the authorizing agency (Federal Ministry of Environment)
for review and approval.
1.1 Objectives of the Terms of Reference
The TOR provides the necessary guidance for undertaking an EIA for a proposed
project in accordance with the project's categorization for EIA. The basic objectives
of the TOR are to:
Define what types of information are to be presented in the Environmental Impact
Assessment (EIA) Report;
Delineate the relevant issues to be discussed;
Define what studies will be performed;
Explain who will conduct the studies;
Ensure issues identified in scoping have been properly addressed in the EIA;
State when the studies will be conducted; and
Outline the basic structure of the EIA.
The contents of the TOR should include the critical environmental issues identified
from the Scoping process. The format for the TOR is given in....
Scoping identifies the issues to be addressed, whereas the TOR provides a complete
guidance on how to address these issues in the process of the EIA.
1.2. Appropriate Time for Developing Terms of Reference
Following the completion of Scoping, a TOR should be developed based entirely on
the results of Scoping. The most appropriate time for preparation of TOR is at the
feasibility and design stage of the project cycle.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
72 November, 2010
1.3. Responsibility for Developing TOR
The TOR evolves from the Scoping process in EIA. The critical issues identified
during the Scoping exercise, to be carried out in EIA study, should be included in
the TOR. The project proponent should prepare a TOR that both delineates the
scope of the EIA and provides complete guidance for undertaking the EIA study.
After approval from the authorizing agencies the TOR becomes an official
document. In the EIA report review process the TOR serves as a standard
document against which the subject matter covered by the EIA report will be
evaluated.
2.0 CONTENT OF TERMS OF REFERENCE
The recommended content of a TOR document is as discussed in the following
sections.
2.1. Name and Address of the Person/Institution Preparing the Report
This section of the TOR should provide a concise description (corporate
overview) of the organization that will be responsible for carrying out the EIA. The
information given will be used by the concerned agencies to evaluate the
institutional capabilities for carrying out the EIA. The information should at least
include:
The name of organization, address and contact numbers (telephone, fax, e-mail,
web site);
The year the organization was established; and,
The approximate number of full-time professional staff.
A similar format should be used to list any other organizations to be subcontracted
by the lead organization.
2.2. General Information on the Project
This section must clearly state the objectives of the EIA, and the relationship of its
results to project planning, design and implementation. It should highlight critical
points in the decision making process linking environmental and social assessment
and project execution.
The section will also provide brief descriptions of the various project-stages
including site preparation, construction and operations. This description should
include the project's:
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
73 November, 2010
Location and accessibility;
Design and layout;
Size and capacity;
Land requirements;
Raw materials;
Construction activities;
Energy and power source for construction;
Schedule;
Staffing plan;
Support facility services;
Labor requirements;
Operation and maintenance activities; and
A map showing the key project facilities around and environmental
features for appreciation of the project's area of influence at a glance.
2.3 Data Required for Preparation of EIA Report and Methodology of Data
Collection
The evaluation of the effects of a given infrastructure project on biophysical, social
and health characteristics of the environment requires adequate knowledge of the
ecosystems, including the human communities, which exist within and around
project's area of influence.
Based on the outcome of the scoping exercise the TOR should therefore provide a
summary of information required for the EIA and comments on data sources and
how they will be used. It is important to keep the data collection well focused. The
study goals should also be highlighted.
The methodologies to be used for data collection should be briefly described,
together with an explanation of how precise the information needs to be for
decision-making. Predictive, quantitative models and standards should be
proposed wherever possible to avoid vague and subjective predictions. In addition,
public involvement to focus the analysis on locally important concerns and issues,
and to ensure peoples' participation, should be employed.
2.4. Policies, Laws, Rules and Directives
The purpose of this section is to establish that the organization responsible for
carrying out the EIA is familiar with all of the various laws and regulations
applicable to the EIA of the specific project. A summary should be made of the
guidelines, procedural aspects, acts, rules, regulations and policies e.g., national
and sectoral guidelines including international laws, conventions and treaties.
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
74 November, 2010
2.5. EIA Report Preparation Requirements
The TOR should provide the following information on the EIA Report
Timelines
Using appropriate bar graph and simple critical path chart, the proposed plan for
carrying out the EIA study should be indicated so that the project will be completed
within a realistic time period. The graph or chart should indicate which studies are
seasonally dependent, and the time frame must match the activities to be carried out.
Estimated Budget
The total estimated cost of the proposed EIA study should be given, together with
estimates of the probable costs for preparing Resettlement Action Plan (if
applicable), Mitigation Plans, Monitoring Plan, Auditing Plan, and
Environmental Management Plan. Roughly, the total cost for environmental
integration in the project implementation can be expected to be in the range of 0.5% to
5% of the total cost of project construction which should be borne by the project
proponent.
Also to be included in the budget are the costs required for various stakeholder
engagement during the EIA, public hearings where applicable, notices in
newspapers, and electronic media and logistic support required for conducting all
stakeholder engagement and public hearings.
Specialist/Experts
Starting with the team leader, a list of the key EIA project staff should be given,
together with their key qualifications and affiliations.
A description of proposed the roles of each team staff should be presented
including qualification summaries. A single individual should be designated as the
EIA Team Leader, to be assigned full time for the duration of the project. It is most
important that the expertise of the project staff is shown to cover all of the major
issues identified from the scoping exercise.
2.6 Approved Scope for the Preparation of the Report
In this section, all impacts/issues determined and approved during the Scoping
exercise shall be incorporated. The section should also provide a summary of impacts
identified from the scoping exercise.
The impacts should be grouped into two basic categories as follows:
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
75 November, 2010
a) Biophysical
b) Socio-Economic, Cultural and Health
2.7 Mitigation Measures
Based on the issues identified from the scoping exercise, the areas of focus for mitigation
should be summarized, and their budgetary requirements should be estimated.
2.8 Environmental Management Plan
Following the format of an EIA report (Section 3.0) the outline of an
Environmental Management Plan (EMP) considered appropriate to deal with the
issues identified from the scoping exercise hould be described.
3.0 THE EIA REPORT FORMAT
A standard EIA Report format is given below.
EIA REPORT WRITING FORMAT
1. Table of contents
a. Chapters and their titles
b. List of maps, illustrations and figures.
c. List of tables
d. List of acronyms
e. E.I.A preparers.
2. Executive Summary
3. Acknowledgements
4. Introduction- Background information, Administrative and legal
framework, Terms of Reference.
5. Project Justification
- need for the project
- value of the project
- envisaged sustainability
6. Project and/or Process Description
- type (e.g., food processing or infrastructure)
- input and output of raw materials and products
- location
- technological layout
- production process
- project construction, operation and maintenance
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
76 November, 2010
- project schedule
7. Description of the Environment including data acquisition.
- study approach
- baseline data acquisition methods
- geographical location
- field data
- climatic conditions
- air quality assessments
- noise level assessment
- vegetation cover characteristics.
- potential land use and landscape patterns
- ecologically sensitive areas.
- terrestrial fauna and wildlife
- soil studies
- aquatic studies, including hydrobiology and fisheries
- groundwater resources
- socio-economic studies
- infrastructural services.
8. Associated and Potential Environmental Impacts
- impact prediction methodology
- significant positive impacts
- significant negative impact
- site preparation and construction impacts
- transportation impacts
- raw materials impacts
- process impacts
- project specific incremental environmental changes (if any)
- project specific cumulative effects
- project specific long/short term effects
- project specific reversible/irreversible effects
- project specific adverse/beneficial effects
- Project specific risk and hazard assessments.
9. Mitigation Measure/Alternatives
- best available control technology/best practicable technology
- liability compensation/resettlement
- site alternative, location/routes
- no project option
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
77 November, 2010
- insert a table listing impact with corresponding mitigation
measures.
- Compliance with health & safety hazard requirements.
10. Environmental Management Plan
- scope monitoring
- parameters to be monitored
- methodology
- monitoring schedule
11. Remediation plans after decommissioning/closure
12. Conclusions and recommendations
13. Bibliography
14. Appendices
Environmental and Social Management Framework for ACE Cable Landing Project in Liberia Draft Report
78 November, 2010
APPENDIX 4
LIST OF PARTICIPANTS AT STAKEHOLDER WORKSHOPS AND
MEETINGS