IEE: Regional: Bemobile Expansion Project · Bemobile Expansion Project (Papua New Guinea and...

Environmental Assessment Report

Initial Environmental Examination Project Number: 44937 March 2011

Proposed Equity Investment and Loan Bemobile Expansion Project (Papua New Guinea and Solomon Islands)

The initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature.

Prepared by Bemobile Limited

ABBREVIATIONS

ADB – Asian Development Bank Asl – above sea level BTS – base transceiver station CAA – Civil Aviation Authority DEC – Department of Environment and Conservation EIA – environmental impact assessment EMF – electric and magnetic fields EMI – electro-magnetic interference EMP – environmental management plan GDP – gross domestic product GSM – global system for mobile ICT – information and communication technology IEE – initial environmental examination IFC – International Finance Corporation MGW – media gateway MSC – mobile switch centre PNG – Papua New Guinea RDS – rapid deployment structure REA – Rapid Environmental Assessment Checklist RF – radio frequency RoW – right-of-way SST – self-supporting tower VSAT – very small aperture terminal

WEIGHTS AND MEASURES

oC – degree Celsius dB(A) – average A-weighted decibels Ghz – gigahertz ha – hectare kHz – kilohertz km – kilometer m – meter m2 – square meter MHz – megahertz mm – millimeter

CONTENTS

I. INTRODUCTION 1

II. PROJECT DESCRIPTION 2

A. Network Improvement and Establishment 2 B. Facility Purpose and Location 4 C. Facility Design 4 D. Project Implementation 6

III. PLANNING REQUIREMENTS 8

A. PNG Approvals and Permits 8 B. Solomon Islands Approvals and Permits 9 C. ADB Project Due Diligence 10

IV. PROJECT ALTERNATIVES 11

A. With or Without the Project 11 B. Tower Sharing 12 C. Base Transceiver and Repeater Station Sites 12 D. Facility Design 12

V. DESCRIPTION OF THE ENVIRONMENT 13

A. Physical Environment 13 B. Biological Environment 14 C. Socioeconomic and Cultural Environment 14

VI. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 16

A. Land Use Change and Land Degradation 17 B. Habitat Loss/Change 18 C. Land Leasing, Resource Compensation and Production Loss 19 D. Visual Impact 20 E. EMF and EMI 20 F. Aircraft Navigation 21 G. Hazardous Materials and Waste 22 H. Emissions 23 I. Noise 23 J. Safety 24 K. Cumulative Impact 25

VII. ENVIRONMENTAL MANAGEMNT PLAN 25

A. Environmental Management System 25 B. Management Responsibilities 25 C. Project Mitigation Measures 25 D. Environmental Monitoring 30 E. Institutional Arrangements, Environmental Reporting and Record Keeping 30

VIII. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE 31

IX. GRIEVANCE REDRESS MECHANISM 31

X. FINDINGS, RECOMMENDATIONS AND CONCLUSION 32

XI. REFERENCES 33

I. INTRODUCTION 1. Bemobile is seeking a direct term loan from the Asian Development Bank (ADB) to partially fund the PNG and Solomon Islands: Bemobile Telecommunications Investment Project (the Project). The loan will be used to partly finance (i) the construction of up to 300 base transceiver stations (BTS) and network upgrading across twenty provinces in PNG and (ii) around 33 BTSs and two repeater stations in three provinces across the Solomon Islands, to improve mobile phone telecommunications and (iii) expansion of existing facilities, covering several sites. Bemobile will own and operate this private development. 2. In PNG, Bemobile will use the loan to:

(i) build its own backbone infrastructure to reduce dependence on Telikom PNG infrastructure and thus improve service reliability which is currently subject to periodic outages of microwave transmission links;

(ii) accelerate the coverage of its network to access more people and improve existing reception in some areas, allowing Bemobile to secure additional customers;

(iii) add capacity to the existing network in Port Moresby, enabling the supply of data services; and

(iv) rationalise BTS equipment across the network, aggregating equipment from each vendor in different areas to rationalize the system and for ease of maintenance.

3. In the Solomon Islands Bemobile has 50 BTS in operation and the loan will be applied to Bemobile’s further network rollout. 4. Both sub-projects will help to provide strong competition in the mobile phone sector by improving Bemobile’s network coverage and reliability in PNG and by establishing an additional competitor in the mobile phone market in the Solomon Islands. The sub-projects will also provide telecommunication services in some areas that are unserviced by land lines and wireless communications. 5. ADB’s environmental due diligence for the project has included a review of the potential environmental impacts related to the Project’s locations, planning and design, construction, and operation. These impacts are assessed to be either insignificant or temporary in nature. The Project is unlikely to have adverse environmental impacts. Therefore, the Project is classified as environmental category B1 in accordance with ADB’s Safeguard Policy Assessment (SPS, 2009). An Initial Environmental Examination (IEE) was prepared by Bemobile and will be disclosed on ADB’s website in accordance with the ADB’s SPS requirements. 6. The scope of the IEE includes direct, indirect, and associated impacts that the Project may have. It takes account of the standards contained in the International Finance Corporation (IFC) Environmental, Health and Safety Guidelines for Telecommunications (2007) as required under ADB guidelines. The IEE:

(i) delineates and assesses the Project’s significant environmental impacts, including the potential cumulative impacts that it contributes to;

1 Category B. A proposed project is classified as category B if its potential adverse environmental impacts are less

adverse than those of category A projects. These impacts are site-specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. An initial environmental examination is required.

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(ii) describes feasible mitigation measures for avoiding, minimizing or offsetting unavoidable adverse effects; and

(iii) recommends the most appropriate mitigation and/or enhancement measures. 7. This IEE focuses on the significant environmental issues associated with telecommunication network improvement and establishment, from pre-construction, through construction to operation. It has been prepared by Bemobile with specialist input from Rongbuk Environmental on impact assessment and management planning.

II. PROJECT DESCRIPTION A. Network Improvement and Establishment 8. The Project involves wireless telecommunications network improvement and expansion in PNG and wireless network establishment in the Solomon Islands. The Project has been classified as environmental category ‘B’ as the most significant potential adverse environmental impact is considered to be of moderate significance only. PNG 9. The PNG component of the Project forms part of Bemobile’s on-going network improvement and expansion, covering Phases 1B, 2, 3 and 4 of its rollout, as well as Port Moresby capacity upgrade and swapping of BTS equipment, as summarized in Table 1. The facilities will improve network backbone infrastructure and extend existing network coverage out from the main cities and towns to smaller population centres and along major roads. The works are likely to cover 11 provinces and the National Capital District. Phases 1B and 2 are illustrated in Figure 1. Table 1: PNG Project Facilities

Phase / Works

Facilities Provinces Commence Complete

Phase 1B

23 BTSs Central (10), Eastern Highlands (13) Nov 09 May 10

Phase 2 60 BTSs Enga & Highlands (37), Morobe & Madang (23)

June 11 Dec 2012

Phase 31 100 BTSs Enga, Southern Highlands, Eastern Highlands, East Sepik, Northern, Milne Bay, West New Britain

Feb 2012 Dec 2012

Phase 41 63 BTSs Western Highlands, East New Britain, & capacity upgrades to previous phase rollouts

August 11 March 12

Port Moresby Capacity Upgrade

30 BTSs National Capital District (Port Moresby) Apr 10 Aug 10

BTS Gear Swap Out2

24 BTSs Various Feb 10 June 10

1 – at the conceptual design stage only. 2 – improvement of existing BTS telecommunications gear.

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Figure 1: Location of PNG Project Facilities - Phases 1B and 2

10. This component of the Project is required to improve Bemobile’s network reliability, coverage and capacity, allowing it to gain more customers to strengthen its position as an alternative mobile phone service provider. By doing so, it will contribute to achieving some of the major objectives set out in the Department of Communication’s National Information & Communications Technology (ICT) Policy (2008) that include (i) securing the social and economic benefits of an efficient ICT sector, (ii) substantially increasing access to basic telecommunications services across PNG with service to be available at affordable prices, and (iii) effective and sustainable market competition to deliver market discipline and economic benefits. At present the industry is dominated by a single provider that has over 80% of the market, with Bemobile having the remainder of the market. 11. Specific areas where network coverage will be extended under Phase 1B are the Hiritano Highway (105 km section) and Magi Highway (145 km) leading out of Port Moresby, and the Highlands Highway between Goroko and Morobe (112 km). Phase 2 will continue to expand the network and provide additional capacity in key areas that are already serviced. Phases 3 and 4 are proposed to further expand network coverage and improve capacity. Solomon Islands 12. The Solomon Islands component of the Project involves rolling out Bemobile’s initial network infrastructure over four phases in 2010-11 (Table 2). Bemobile has committed to providing service coverage to at least 25% of the population of the Solomon Islands by mid June 2010 (six months after the date of license issuance) and to 81% of the population by September 2011 (21 months after the license date).

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Table 2: Solomon Islands Project Facilities

Phase

Facilities Regions Population Coverage

(%)

Commence Complete

Phase 1 20 BTSs Mobile Switch Centre

Honiara, Guadalcanal, Malaita, Western

25 Nov 09 Jun 10

Phase 2 29 BTSs Western,Mailiata,Central 50 Jun 10 Sep 10 Phase 31 25 BTSs Choiseul, Western 75 Sep 10 Mar 11 Phase 41 25 BTSs Temotu, Renbel 81 Mar 11 Sep 11

13. Bemobile’s entry into the market has establish competition in a market which before had a single, state-owned provider, Solomon Telekom Co. Ltd., and has provided telecommunication services in some unserviced areas. Total population of the Solomon Islands is 580,000. Competition has contributed to the achievement of the Government’s objectives under the Telecommunications Act 2009 that include promoting a competitive industry that delivers cost effective communications to the Solomon Islands. B. Facility Purpose and Location 14. A mobile telecommunications network consists of a series of BTSs that send and receive signals from customers, and are linked to form the network via microwave transmission links. Each BTS serves a geographical area as part of network coverage, sending and receiving radio frequency signals to and from customers. Bemobile’s Global System for Mobile (GSM) network transmits at a low frequency (at 900 MHz) that provides antennas with a wide coverage. A single BTS may service a 30 km radius depending upon topography. Telecom equipment installed in the BTS relays the call to switches located in the network, rerouting the call to the recipient. 15. BTSs are located to optimize the service area and signal strength received by customers, and provide reliable link connections to the network. BTSs are primarily located based on customer demand. Where customers have requested Bemobile service or indicated that the existing reception is poor, or where Bemobile has identified an unserviced area that may be economically feasible to service, these areas are investigated. All proposed BTSs under the PNG sub-Project are on greenfield sites located outside urban areas, therefore there are no rooftop sites. 16. Microwave links transmit signals between BTSs. Microwave antennas are mounted on the BTS tower and require line-of-sight to another tower or repeater station to transmit traffic and signaling to the Mobile Switch Center (MSC). Alternatively, when the BTS cannot be connected due to line-of-sight blockage, satellite terminals, known as very small aperture terminals (VSAT - 2.4 m diameter antenna) are utilized, whereby the signals are transmitted via reliable satellite link facilities. Both the VSAT terminals and the VSAT hub are part of the sub-Project. The proposed VSAT hub is dimensioned for a 7.3 m (diameter) plus the electronics to support both voice and data services from the remote VSAT terminals. C. Facility Design 17. BTSs and associated facilities are designed to be compatible with the existing Bemobile telecommunication network, to provide broad coverage, be safe and be suitable for the location

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where they are installed. A BTS facility typically consists of a small parcel of leased land (around 400 m2), a tower or mast, a microwave antenna and RH antenna mounted on the tower, switch gear at the base of the tower, a diesel generator and fuel tank, security fencing and an earth access road leading to the site (Figure 2).

Figure 2: Typical BTS Facility 18. The BTS yard is commonly between 9 x 9 m (81 m2) and 15 x 15 m (225 m2), providing sufficient space for the tower/mast and yard area to house the required gear and provide a setback from the fence. Towers/masts are either: (i) a self-supporting lattice tower (SST); (iii) a rapid deployment structure (RDS - also a lattice tower); or (ii) a monopole mast. Lattice towers with a height of between 30-60 m (commonly 45 m) are usually constructed on greenfield rural sites. Self-supporting towers have three legs set into concrete block footings at around 3 m depth, depending upon foundation conditions (Figure 2). These towers are preferred where there is adequate time available to construct the facility and good road access for concrete delivery. RDSs are installed to save on construction time, taking as little as seven days for tower installation. They consist of a four legs bolted to interlocking steel beams and plates that form a raft foundation installed partly under ground level. The voids created by the beams and plates are backfilled with soil to provide weight to prevent tower movement. Monopole masts are used

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in urban areas to minimize visual impact (i.e. less obvious and less intrusive than a lattice tower), commonly to a height of 25-30 m. 19. Depending on the type and height of towers, around of 600-800 m2 of ground is temporarily cleared of vegetation at each site to provide sufficient space to store tower beams and other components during construction only and to establish a small workforce camp. 20. Most new facilities have two generators: one for the primary source of power and the second to provide back-up power. A connection to main electricity is preferred, with back-up power provided by a generator, but this option is rare outside Port Moresby and Lae precincts due to a lack of distribution lines in the vicinity of BTS sites. Generator fuel tanks are typically either a 2,600 L overhead tank or a 1,300 L underground tank. 21. Telecommunications antennas, consisting of microwave link transmission dishes (usually two to provide a network link between several nearby BTSs) and radio frequency (RF) communications transceiver panel antennas are installed on the tower. Telecom and related gear at the base of the tower consists of the BTS connected to the antennas by cables and a battery cabinet. Towers in areas deem potentially hazardous to aviation have a nighttime light on the crest of the tower. 22. Security fencing consists of either mesh steel panels bolted to the RDS foundation beams or a chain wire fence around self-supporting towers and monopole masts. Safety signs are placed on the fence prohibiting entry and warning of the safety hazard of doing so. 23. An earth access road is constructed to BTS sites where vehicle access is not possible. Where there is an existing track this may be upgraded to improve access. In PNG around 75% of sites require road access to ensure the site can be built effectively and that subsequent fuel delivery is possible. New roads range from 50 m and 2,500 m in length, average length is around 500 m per site, and is typically 4 m wide. D. Project Implementation

1. Implementation Schedule PNG 24. Project implementation commenced with the Phase 1B in November 2009. Seven BTSs have been installed and commissioned under Phase 1B as of mid February 2010, with construction due to be completed in July 2010. Phase 2 construction will commence in June 2011, Phase 3 is likely to commence in February 2012 and Phase 4 in August 2011, with all Project construction activities scheduled to be completed by mid 2012 (Table 1). Each BTS is progressively commissioned as it is completed, providing rapid expansion of network coverage. Solomon Islands 25. The license was awarded to Bemobile in mid December 2009, and Phase 1 implementation commenced in early January 2010. A total of 50 sites have been completed as Part of Phase 1 and 2. Phase 3 commenced in November 2010 and Phase 4 is likely to commence in March 2011 respectively (Table 2). Each BTS is progressively commissioned as it is completed, providing rapid expansion of network coverage.

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2. Pre-Construction Activities 26. Pre-construction activities commence with the identification of potential network expansion areas based on customer feedback and Bemobile planning. Key determinants in deciding the value of a potential site to the network are the number of customers that can be serviced and the cost-effectiveness of constructing and operating the BTS. 27. A desktop assessment of the area is undertaken to identify the optimum BTS site in terms of (i) achieving a microwave transmission link (signal transmission) to an existing Bemobile facility and (ii) RF coverage of the local population or areas frequented by people (e.g. along highways). RF coverage is modeled using digital terrain data to determine the theoretically best site for the BTS. A site “search ring” from 500 to 1,000 m in diameter is established, centered on the theoretically best location, and at least three “candidate” sites are identified with a recommendation on candidate priority. 28. A technical site visit is undertaken in accordance with Bemobile’s Site Acquisition Process (2009) to assess the feasibility of the candidate sites and micro-site BTSs and repeater stations. Site information is collected such as current use, ownership details and disputes, and existing site infrastructure. Where the preferred site is not feasible then an alternative site is selected. Preliminary discussions occur with the landowner/s to determine their willingness to lease the land, while discussions also occur with local authorities in relation to site acquisition and permitting. Whilst the site visit is underway, an environmental assessment, hazardous radiation assessment and structural engineering assessment are prepared. 29. Site leasing negotiations are undertaken to reach in-principle agreement. Once this is reached a cadastral survey of the site is undertaken to provide the necessary land ownership details and drawings for the lease agreement. Geotechnical site investigations are conducted to assess the suitability of foundation conditions or, for rooftop sites, a structural assessment of the building is undertaken. Final local authority approvals are obtained, including Building Board and Civil Aviation Authority (CAA) approval and an existing condition assessment of the site is completed. The Lease Agreement is then finalised by Bemobile’s legal department and entered into with the landowner/s.

3. Construction Activities 30. A number of BTSs are concurrently constructed by contractors at any one time to install the facilities within the short program timeframe. BTS installation involves road construction or upgrading (as required), site clearance, tower foundation installation, tower erection and equipment installation. BTS sites and adjoining land are usually temporarily cleared of vegetation with a bulldozer when the roadworks are completed, with the total cleared area commonly around 600-800 m2. Self-supporting tower and monopole mast foundations are excavated using an excavator, and assisted by pneumatic tools where required or in some cases (helicopter sites) manual labour. The foundation pylons for each tower are laid out using a steel framework guide. Pre-mixed concrete for foundation blocks is trucked on to site, poured then allowed to cured, then the remaining void is backfilled and compacted with excavated subsoil and the surface is spread with topsoil. Excess spoil is disposed of by spreading it on customary or private land where requested by local landowners or at other sites where the erosion hazard is low. 31. RDSs are constructed in a similar manner except the base of the foundation beams is laid just under the ground surface by hand digging trenches to set the beams and plates in. The

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voids between the beams are backfilled with soil and gravel and compacted. Windrowed topsoil from site clearance is then spread around the cleared area around the BTS. 32. Lattice towers are assembled using a manually operated boom to lift components. Masts are assembled using gin poles along with block and tackle (pulleys). BTS construction can be completed in three weeks, from site clearance to commissioning the facility.

4. Operational Maintenance and Repair 33. A caretaker is employed at each BTS to conduct general visual inspections of the facility at least once a week, cut grass around the facility to reduce the fire hazard as needed and report any incidents such as vandalism or theft. 34. Routine generator maintenance is undertaken every 4-6 weeks when refueling occurs. A series of quarterly, six monthly and annual inspections are undertaken to check electrical, tower, civil works and telecom gear. All inspections are documented in reports. Other maintenance activities undertaken as required include access road improvement. 35. Remote alarms fitted to telecom gear automatically transmit reports when a fault occurs (e.g. no fuel). Emergency inspections and repairs are undertaken when faults occur to rectify the problem.

III. PLANNING REQUIREMENTS 36. The Project is subject to Government of PNG and Government of the Solomon Islands approvals and permits, as well as ADB due diligence assessment. A. PNG Approvals and Permits 37. Approval to install telecommunication towers is required from the Building Board in urban areas and from the Civil Aviation Authority in proximity to aerodromes. Building Board 38. Proposed BTSs in urban areas must be approved by the local Building Board before construction commences (PNG 1001-182). The main locations where this is required are Port Moresby and Lae. Bemobile lodges an application with the Board to seek approval for the structure. The application contains location and design information. After approval and construction Bemobile obtains independent structural certification from a qualified engineer and submits this to the Board for its records. Civil Aviation Authority 39. An application has to be lodged with the Civil Aviation Authority (CAA) to gain approval to erect a new tower, titled Application for Issue or Renewal of a Certificate under CAR Part 77 to Construct or Alter a Structure. Details required in the application include type and height of the structure, location, distance to the airport and construction program. Upon receipt of the application the CAA undertakes an aeronautical study to determine whether the structure will constitute a hazard and, if approved, what measures are required to improve its safety. The CAA usually requires towers in close proximity to an aerodrome to be lit and painted in accordance with its rules.

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Department of Environment and Conservation 40. The Department of Environment and Conservation (DEC) generally prohibits the installation of towers in national parks as per the National Parks Act 1982. Under the Act the Minister has the right to “grant a licence as prescribed or other right to use and occupy – (i) a camp, caravan park, kiosk, hostel, hotel or place of entertainment; or (ii) refreshment rooms or facilities for amusement”, but there are no provisions for other uses. In addition, the National Parks Regulation 1984 includes the provision: “Where a structure is erected, built or maintained contrary to Section 7(1)(p), the Director may cause that structure to be removed”. 41. Bemobile has adopted the policy of not proposing towers in National Parks since permission was sought from DEC to locate a BTS in Variarate National Park in late 2009 and this was subsequently declined by the Department. It has been reported that at least one telecommunications tower (not owned by Bemobile) was been constructed in a National Park (DEC – pers. comm.) without prior approval, most likely in error, and that retrospective approval was granted for this tower. 42. Despite the above provisions of the Act, DEC has indicated that it would consider approving BTSs on public land under its control where such a facility would contribute to the sustainable development of a protected area, such as strengthening park management. Valuer General / National Statistics Office 43. Where trees are proposed to be felled and crops removed or disturbed, the owner of the land must be compensated as per the conditions and rates set out by the Valuer General or in line with economic tree prices published in the National Statistics Office bulletin. B. Solomon Islands Approvals and Permits 44. Approval to install telecommunication towers is variously required from the Ministry of Infrastructure and Development, the relevant provincial Planning Board or city Council, and potentially from the CAA, Ministry of Lands and Ministry of Agriculture. Ministry of Infrastructure and Development 45. Typical cell site technical specifications, designs and supporting calculations have to be submitted to the Ministry of Infrastructure and Development for its review and approval. The documentation required includes civil engineering and structural designs and calculations, electrical and earthing design, and the radiation plan. In addition, a basic/generic environmental impact assessment must be submitted for review and approval. Provincial Planning Boards and Council 46. After Ministry of Infrastructure and Development approval is obtained, construction permits can be requested from provincial Planning Boards and the local city council if applicable. An application for a construction permit has to include a copy of the documentation approved by the Ministry of Infrastructure and Development, a layout plan of the site/s including site orientation and coordinates, location plan/s and soil test results. Construction may only commence once a construction permit is granted.

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Civil Aviation Authority 47. Flight path clearance is required from the CAA under the Civil Aviation Act 1986 and any related Regulation/s for the purpose of ensuring the safety of aircraft flying in accordance with normal aviation practice. This relates to the power to prohibit and restrict the erection of buildings, structures or other things in any area specified, and the display of lights of an approved type, on buildings or structures within the area customarily used by aircraft within the vicinity of airports. 48. An application has to be lodged containing a map indicating the site location, coordinates and elevation, accompanied by a copy of the documentation approved by the Ministry of Infrastructure and Development. Structure construction may only commence once clearance from the CAA has been obtained. Ministry of Lands 49. Approval of a road right-of-way (RoW) is required from the Ministry of Lands. The application has to indicate the purpose, length, width, location and route of the RoW. Ministry of Agriculture 50. Where trees are proposed to be felled and crops removed or disturbed, the owner of the land must be compensated as per the conditions and rates set out by the Ministry of Agriculture. C. ADB Project Due Diligence 51. ADB’s environmental due diligence for the project has included a review of the potential environmental impacts related to the Project’s locations, planning and design, construction and operation. These impacts are assessed to either insignificant or temporary in nature. The proposed ADB assistance will finance improvement and expansion of existing facilities, covering several sites. An environmental and social compliance audit was undertaken to assess Bemobile’s current ESMS and the company’s past and current performance against the objectives, principles and requirements of ADB’s Safeguard Policy Statement . 52. The environmental and social compliance audit findings show that Bemobile has adopted strict selection criteria in line with its Site Acquisition Process (2009) in order to avoid involuntary resettlement and adverse Indigenous Peoples impacts. For each telecom tower site, Bemobile identifies several sites and follows strict selection criteria whereby only lands that are vacant, unproductive, and undisputed are selected and the final site, including road access, is selected based on the landowner’s full consent to lease the land and agreement to the rental fee. The lease terms include unimpeded access by Bemobile to the land for 5 years. However, if Bemobile fails to pay the rent for more than 21 days and if this happens continuously, the indigenous landowner can terminate the lease agreement and Bemobile is required to restore the land to its former state and condition upon expiration or termination of a lease agreement. Upon expiration of the lease agreement the indigenous landowner can again renegotiate the terms of lease.

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IV. PROJECT ALTERNATIVES

53. The main Project alternatives are:

with and without the Project; tower sharing with other providers; tower sites; and tower/facility design.

A. With or Without the Project 1. Without Project Option 54. The “without project” option would result in:

1. PNG - current outages of Telikom’s network backbone links continuing and the expansion of Bemobile’s coverage restricted to a slow rollout, thus delaying the establishment of broad coverage and higher capacity that will allow strong competition in the market place.

2. Solomon Islands – the slow rollout of infrastructure, hampering Bemobile delivering the agreed services on time, and thereby limiting competition in the market for some time, resulting in the people of Solomon Islands continuing to suffer from low quality of service, outages and limited mobile phone coverage.

55. Continuing subdued competition in both markets that are dominated by a single provider inevitably adds to the cost of mobile phone services and therefore adds to household and business costs. Additional telecommunications coverage provides this basic service to more remote settlements and sections of major roads, thus providing essential communication in the event of emergencies. 2. With Project Option 56. The “with project” option will substantially improve mobile phone communications across large areas of PNG and the Solomon Islands by:

1. PNG - (i) improving service reliability by reducing backbone link outages, (ii) providing additional capacity that will allow voice/data transmission, and (iii) providing broader network coverage including servicing some areas currently without fixed line and mobile phone connection; and

2. Solomon Islands - the rapid rollout of infrastructure, facilitating Bemobile delivering the agreed services on time, and thereby bringing competition to the market as soon as possible, delivering a reliable service and increased coverage across the country.

57. The net impact of the Project should be stronger competition in the market, which in turn is likely to lead to a reduction in the cost of mobile phone services for households and businesses. Access to data transmission will improve personal access to information and facilitate business growth. Additional telecommunications coverage will provide this basic service to more remote settlements and sections of major roads, thus providing essential communication for everyday activities, in the event of emergencies and to facilitate development.

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B. Tower Sharing 58. Mobile network providers have the option to share towers, placing their equipment onto a tower that is also used by one or more other providers. The sharing of towers is either done through (i) an independent tower provider leasing space on a tower to phone providers, or (ii) a mobile phone provider leasing space from another phone service provider’s tower. 59. Tower sharing is not undertaken in PNG or the Solomon Islands as these markets are shared by a few highly competitive operators. Companies aim to maximise their customer base, which largely occurs by “churning” (winning) the competitor’s customers and by providing services where their competitors do not have cover, therefore it is not in Bemobile’s commercial interest to share towers, nor is it the interest of competitors to lease space on their towers. 60. The other advantages of operating separate towers is the ability to establish trouble-free structures (e.g. with a low chance of landowner disputes) and to maintain these structures as per Bemobile’s standard practices, thereby ensuring it has full control over the operational reliability of its facilities. C. Base Transceiver and Repeater Station Sites 61. BTSs are located to provide cost-effective coverage to a current and potential customer base. Sites for these facilities are selected to (i) establish a microwave link, (ii) optimize RF coverage of the target population, road, etc, and (iii) avoid or minimize environmental and social impacts (Appendix A). Repeater stations are sited to provide line-of-sight microwave transmission connections with other repeater stations or BTSs. 62. Sites are carefully selected based on a sequential modeling, site investigation and design process. Desktop RF and transmission modeling of an area is initially undertaken to identify a theoretical “search ring” (a 500-1,000 m diameter circle) where a tower needs to be sited to provide a microwave link and optimum RF signal. A preferred site and several alternative sites are identified in the search ring. The preferred and alternative sites are then inspected by a multi-disciplinary team consisting of an RF engineer, transmission engineer and site acquisition specialist to identify the “candidate” site. 63. Site selection criteria includes a preference for higher terrain to provide improved reception from a lack of line-of-site obstacles, good road access (or ease of road construction) for construction and maintenance, adequate setback from facilities that may cause interference. Micro-siting criteria involves a trade-off between engineering, access, land ownership, environmental and social factors to obtain the best overall site that complies with design specifications and statutory requirements (Appendix A). D. Facility Design 64. The design of towers and equipment must comply with PNG and Solomon Islands standards and good engineering practice, and telecommunications gear has to be compatible with the network, therefore facility and gear design alternatives are limited. 65. The relevant standards that have to be complied with include:

towers and foundations - engineering specifications;

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electrical works - PNG Power regulations (in particular Trade Practices 1982), SAA Electrical Wiring Regulations and Manufactures’ recommendations and requirements; and

lightening protection and earthing - PNG Power Trade Practice Direction of 1982.

V. DESCRIPTION OF THE ENVIRONMENT

66. The proposed works span large areas of PNG and the Solomon Islands, therefore this section provides an overview of the natural and social conditions of these countries. A. Physical Environment

1. Topography 67. PNG – the eastern half of the island of New Guinea forms 85% of the land mass of PNG, with the large islands of New Britain, New Ireland, Bougainville and Manus, plus around 600 smaller islands making up the remainder. Topography on the mainland is dominated by a complex chain of ranges interspersed by broad upland valleys that includes the valleys of the Sepik, Ramu and Markham Rivers. This spine of mountains running from east to west, the Owen Stanley Range, has many peaks over 4,000 m. A large delta plain of swamps occurs along the Daru coast. Offshore islands are generally characterized by a similar pattern of mountain range spines with swampy coastal plains. 68. Solomon Islands – the country is one of the largest Pacific island nations, with around 60 populated islands spread over a large area. The largest islands are Choiseul, New Georgia, Santa Isabel, Malaita, Guadalcanal and Makira (San Cristobal). Most major islands are volcanic in origin, with mountainous interiors falls to coral fringed coasts, although there are also low-lying coral atolls. The highest peak is Mt. Makarakomburu on Guadalcanal (2,447 m), an island that also has extensive alluvial grass plains. The islands contain several active and dormant volcanoes. Extensive coral reefs and lagoons surround the coastlines.

2. Climate 69. PNG – the climate is tropical monsoonal, characterized by defined wet (northwest monsoon from December to March) and dry (May to October) seasons, but subject to regional variation (especially in the islands). The significant range in altitude, principally on the eastern end of the main island of New Guinea that is PNG territory, influences rainfall and temperature. Hot and humid conditions occur at low altitudes throughout the year, with rainfall in these areas commonly around 2,000-3,000 mm per annum (although Port Moresby is comparatively dry receiving only 1,225 mm per annum). Cooler conditions and heavier rainfall occur in the highlands, with between 2,000 and 5,000 mm per annum. The highest mountain, on the western border, has an area of permanent snow. Temperatures in coastal regions can vary from 23-30°C, whilst highland areas are considerably cooler with temperatures occasionally falling to 0°C. 70. Solomon Islands – the climate is tropical monsoonal, characterised by high and uniform temperature and humidity and abundant rainfall throughout the year. From about January to March the Islands are subject to west to north-westerly monsoonal winds when the heaviest rainfall occurs. From May to October the Islands receive the southeast trade winds that also

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bring rainfall, with the heaviest falls occurring on the windward side of the Islands. Rainfall is influenced by topography, causing significant variations between locations. Average annual rainfall ranges between 3,000-5,000 mm. Temperature is uniform throughout the year, with the average maximum varying by only 2oC, with a mean daily range of only 7oC. An average of 1-2 tropical cyclones occur each year, however they are relatively small as they are usually just developing, but can still cause significant damage.

3. Land Use 71. PNG – land use is estimated to consist of arable land 0.49%, permanent crops 1.4% and other land types (forests, swamplands, etc) 98.11% (2005 estimate). Forests cover the majority of land, at around 80%. The main type of agriculture is subsistence cultivation. 72. Solomon Islands – land use consists of arable land 0.62%, permanent crops 2.04% and other 97.34% (2005 estimate). B. Biological Environment

1. Biodiversity and Protected Areas 73. PNG – New Guinea contains unique flora, with endemicity a result of mountainous isolation, topographic and soil habitat heterogeneity, high forest disturbance rates and high year-round rainfall. Tthe country is estimated to contain over 5% of the world's biodiversity in less than 1% of the world's total land area. Around 70% of PNG is covered in rainforest, with other terrestrial ecotypes including freshwater swamp forests, savanna, grasslands and sub-alpine grasslands. PNG is estimated to contain 15-21,000 species of plants, 250 species of mammals and 760 species of birds across the islands, with lowland rainforest having particularly high biodiversity. The country has 44 terrestrial protected areas as per IUCN categories, occupying 1.6% of the total land area, plus a number of terrestrial wildlife management areas (WMAs). 74. Solomon Islands – the islands contain two distinct terrestrial ecoregions: the Solomon Islands rainforests ecoregion and the Vanuatu rainforests ecoregion. The country has two terrestrial protected areas accounting just 0.15 of the total land area and eight marine protected areas. It has around 3,200 plant species, 53 mammals, 111 bird species and 11 reptiles, with threatened species comprising 16 plants, 20 mammals and 23 birds. C. Socioeconomic and Cultural Environment

1. Population and Administration

75. PNG – the country has an estimated population of 6.7 million (2009), with a high annual growth rate of 2.7% and approximately 40% under the age of 15 (2000). The majority lives in rural areas in traditional villages, with around 13% living in urban areas. The largest city is Port Moresby with a population of 254,000 (2000 census), while Lae is the second largest with an estimated population of 120,000. The Highlands region of the mainland contains around half the total population of PNG. The indigenous population is almost entirely Melanesian, although there are a small number of Polynesians north of Bougainville island. There is estimated to be over 1,000 cultural groups and around 840 indigenous languages in PNG due to fragmentation created by terrain. There are significant ethnic distinctions between population groups in different parts of the country but given the number of groups none are termed minorities.

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76. The country consists of 18 provinces, the National Capital District (Port Moresby) and the Autonomous Region of Bougainville. Each province is divided into districts, which in turn are divided into Local Level Government areas. Provinces form the primary administrative divisions of the country, with provincial governments forming branches of the national government. 77. Solomon Islands – the country has an estimated population of 596,000 (2009 estimate) and a high annual growth rate of 2.4% (2009 estimate), with approximately 39.5% under the age of 15. The majority (83%) live in rural areas in traditional villages, with around 17% living residing in urban areas. The largest city is the capital Honiara, with a population of around 55,000 (2007 estimate). The majority of the population is Melanesian, with minority groups including Polynesians and i-Kiribati. The central chain of high islands was historically occupied by Melanesians, while outlying islands, including coral atolls, were occupied by different Polynesian cultural groups. Many Polynesians have moved to the centre, especially into Honiara. The i-Kiribati were resettled from the Gilbert Islands (Kiribati) from the 1950s onwards due to land shortages. Around 80 Melanesian and 5 Polynesian languages are spoken. 78. The country is divided into nine provinces (Central, Choiseul, Guadalcanal, Isabel, Makira, Malaita, Rennell and Bellona, Temotu, Western) and the capital territory of Honiara. In 2003 the then Prime Minister sought assistance to restore order to the country. In July that year the Regional Assistance Mission to the Solomon Islands (RAMSI) was established, but this was scaled back in 2004.

2. Economy 79. PNG – a relatively small informal and a formal economy exists. The informal economy supports 85% of people through semi-subsistence agriculture. The formal economy is driven by petroleum and mining, principally oil, copper and gold resources, that generate around 72% of export earnings. PNG is in an economic recovery with GDP growing strongly in recent years, recorded at 6.6% in 2008. This translates to high employment growth and stronger investment. Improved growth is resulting from firm international commodity prices, improved political stability, prudent macroeconomic and fiscal policies, and low interest and inflation rates.

80. PNG is rich in natural resources, having large reserves of minerals, extensive forestry and fishery assets, and significant agricultural land. PNG’s development constraints include rugged terrain and the associated high cost of developing infrastructure, ethnic diversity, customary land title, and a rapidly growing and widely dispersed population. Increased development investment is needed as much of the population still lacks access to basic services. 81. Solomon Islands – the country has a narrow economic base with more than 80% of the population relying on subsistence agriculture and fishing. Forestry also has an important contribution to the economy. Most manufactured goods and petroleum products are imported. The country has substantial undeveloped mineral resources that include lead, zinc, nickel, gold and bauxite, as well as fish and forest resources. Sectors within the workforce consist of agriculture 75%, industry 5% and services 20% (2000 estimate), with the main exports being timber, fish, copra, palm oil and cocoa. 82. The economy was severely affected by ethnic violence, the closing of key businesses and government bankruptcy that resulted in economic collapse in 2002-03. The country is now

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in recovery, currently achieving modest economic growth. A key challenge is to broaden the productive economy beyond forestry and fisheries. 3. Social Indicators and Infrastructure 83. PNG - the main social indicators, such as life expectancy and maternal and child mortality rates are improving, but they are still well below the averages for lower middle income countries. Infant mortality is 57 per 1,000 live births, with life expectancy at birth being 57 years (2006). Primary health care is limited, with infectious diseases claiming many lives. Malaria incidence is high at 243 cases per 1,000 people (2002) and there is an emerging HIV/AIDS epidemic with an estimated 2.56% of adults carrying the HIV/AIDS virus. A large proportion of the population is illiterate, with literacy levels of 15-24 year olds estimated at 64.1% (2004). The net enrolment rate in primary education is 53% (2009). 84. Solomon Islands - infant mortality is 44 per 1,000 live births, with life expectancy at birth being 67 years for females and 65 years for men (2007). The delivery of health care and education is difficult in this dispersed island nation. The net primary school enrollment rate is around 64% for boys and girls. The national adult literacy rate is 77% (2007 estimate). 4. Land Tenure 85. PNG - the majority of land in PNG (around 97%) is owned under customary title by traditional landowners. The precise nature of customary title varies from one culture to another, however the smallest portions of land are held by the individual heads of extended families and their descendants. Only some 3% of land is in private hands, held under a 99 year State Lease or held by the State. The few existing freehold titles are automatically converted to State Lease when they are transferred between vendor and purchaser. 86. Customary land ownership poses a problem for economic development due to the difficulty in identifying rightful landowners, with disputes common. Limited cadastral information exists outside urban areas. 87. Solomon Islands – 80% of land is customary owned, around 11% privately owned and 9% Government owned. The registration of customary land by a landowner group can be voluntarily undertaken under the provisions of the Customary Lands Record Act [Chapter 132]. Customary land recording and registration provides certainty of title and thereby reduces or eliminates land disputes and helps to facilitate development.

VI. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

88. The main potential adverse environmental and social impacts from BTS and repeater installation and operation are:

land use change and land degradation; habitat loss/change; land leasing, resource compensation and production loss; EMF; visual impact; and aircraft navigation.

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89. Secondary potential impacts include the generation of hazardous materials and waste, emissions to the air and noise. A. Land Use Change and Land Degradation 90. Each ground-based BTS or repeater station site will affect around 600-800 m2 of land, consisting of the BTS yard (81-225 m2) and a temporarily disturbed area around the yard used for construction purposes (350-700 m2). Land use change also occurs where a new access road is installed, averaging between 2,000-4,000 m2 per BTS where required (500 m average length x 4-8 m wide formation). Accordingly, total land use conversion per BTS averages 0.3-0.5 ha where an access road is constructed and less than 0.1 ha where adequate access exists. 91. BTSs are sited on lower value production land wherever possible, avoiding cropping land, plantations and forest in most instances. The main land type converted to telecommunications use is ridgeline supporting grassland with scattered trees. Other land cover types that are affected to a lesser degree are cultivation and plantations where there are no better alternative sites, and degraded land which is preferred where available (e.g. disused quarries). The BTS site is usually leveled to create a platform, requiring cut and fill earthworks with fill batters up to several meters high. 92. The area disturbed around a BTS site is kept to the minimum area required for the temporary storage of tower components and facility equipment, construction activities and a temporary workforce camp. Likewise, disturbance from earth road construction is minimized by generally limiting the road surface width to 4 m and cut and fill batters to the minimum area required. 93. Land degradation can occur on disturbed areas. BTS yards generally have no erosion hazard as these areas are graveled. The area surrounding the BTS that is temporarily disturbed is usually flat and located on the crest of a ridge, hence no run-on flow crosses the site and these areas have a low erosion hazard. The earth access road installed to the BTS often has to be constructed with steep grades (in excess of 12%) up to ridgeline BTS sites. Unless adequate cross-road drainage is installed then rill erosion is likely along the road surface as runoff flows down wheel ruts. Gully erosion at watercourses may also result if these areas have been disturbed. Mitigation Measures

Selection of stable, relatively flat sites with good existing access or the ability to construct access.

Recording site conditions in an Existing Condition Assessment prior to any site works, documenting the state of the land/premises and adjoining area, including photographs of the existing condition of the land.

Restricting ground disturbance to the minimal area required for the BTS/repeater station and road construction.

Clearly pegging out the works, including the extent of the site to be disturbed. Stripping topsoil off the site area to be leveled, then respreading this material on the

surface to revegetate and stabilise the area. Compacting fill in BTS/repeater station platforms and forming cut and fill batters with

stable grades.

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Careful alignment of the earth access road to keep the road grade below 12% wherever possible and avoid crossing unstable and erosion prone slopes.

Installation of earth drainage banks across all new and upgraded earth access roads as required to provide good cross-road drainage.

Seeding disturbed areas with a cover crop and suitable perennial grass immediately following landforming.

Gravelling BTS/repeater station compounds to minimize weed growth and prevent erosion.

Regular maintenance of access road surface and cross-road drainage as required to minimise erosion.

B. Habitat Loss/Change 94. The construction of a BTS or repeater station involves the removal of vegetation at the site and along the new road alignment if required. Significant habitat is avoided in the site selection process, with no facilities sited within protected areas proclaimed by DEC in accordance with the National Parks Act 1982 (Section 3.1). Forest is avoided wherever possible during site selection, with many selected sites having been previously disturbed due to close proximity to settlements. Sites are also preferred with existing access or in close proximity to access to avoid or minimize the need for road construction. 95. Vegetation to be cleared commonly consists of grassland with scattered trees, but may include crops, plantation and forest. Where required, large individual trees that have the potential to block or reduce microwave or RF reception in close proximity to a tower site are lopped in preference to being cleared. The 350-700 m2 that is temporarily cleared around the BTS/repeater station is managed as grassland, regularly cut to maintain a reduced fire hazard zone. 96. The total habitat area at each BTS/repeater station permanently converted to telecommunication facilities and associated access averages just over 0.2-0.4 ha where a new road is constructed and 0.01-0.02 ha where access exists. Given this relatively small area permanently converted per site, the preference for land with low habitat value (including the avoidance of protected areas), the impact on habitat is usually low. Mitigation Measures

Preference for sites with low habitat value, including being free of trees or requiring limited tree clearance.

Preference for sites with existing road access or in close proximity to road access. Vegetation removal kept to the minimum to construct the facility and access and to

maintain safe conditions. Vegetation to be removed or lopped clearly marked prior to the commencement of

clearance, and clearing strictly controlled within the marked area. Construction workers strictly prohibited from hunting and collecting forest products in

and around facility sites. Revegetation of disturbed areas immediately following construction to stabilize the

ground and minimize weed invasion. Grass cutting and tree and shrubs clearance/ pruning is strictly undertaken in

accordance with the site management plan.

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C. Land Leasing, Resource Compensation and Production Loss 97. All land required for BTSs, repeater stations and new access roads is leased from customary landowners or the government, with no land permanently acquired by Bemobile. Government land is preferred for BTS sites wherever possible due to the avoidance of customary land ownership issues, but this land is uncommon outside urban areas. All PNG Phase 1B and 2 sites are on customary land, while all Phase 3 and 4 sites are also expected to be on customary land. Sites in the Solomon Islands are likely to be primarily on customary land, although some private and government land may also be utilised. 98. Bemobile identifies the rightful owner/s of an area of land by consulting with a village elder / church leader / councilor, then convening an open community forum (Section 8). Leases over customary land are entered into by mutual agreement with the landowner/s once they are fully informed about the design and function of the proposed facility, construction procedure and operational activities, any access requirements and the land area required to be leased. If a landowner does not wish to lease his/her land then Bemobile finds another site or road RoW. 99. The standard area leased for a BTS or repeater station is 400 m2, providing an adequate area for the facility plus the establishment of a grassed area around the yard as a fire reduction zone. The leased road easement is usually 8 m wide, covering the full formation width (road surface plus cut and fill batters). The average area leased for an access road is around 4,000 m2 based on the average road length of 500 m. 100. The lease rate paid by Bemobile per site is well in excess of the rate that would be payable for the existing land use at the site (commonly grassland, but occasionally cultivation land, plantation, forest or degraded land). The lease rate is based on the suitability of the land for the proposed BTS or repeater station (i.e. prominence of site for RF reception and microwave links), availability of alternative sites with similar features, location and industry rates for communication towers. The final lease price is negotiated with the landowner and the lease agreement signed prior to site clearance. Before Bemobile takes possession of the land compensation is paid for the loss or disturbance of crops and trees at the rate published by the relevant Government authority. The value of foregone annual agricultural or forest production off the leased site is exceeded by the annual site lease rate plus resource compensation. In addition, one of the landowners is usually engaged as a part-time caretaker to guard the site and undertake general maintenance activities outside the facility (grass cutting etc), thereby receiving small additional on-going payments. Accordingly, no adverse impact on indigenous customary landowners is expected. 101. Leases are initially entered into for a 10 year period plus two consecutive option terms each of five. The initial lease payment is made at the commencement of the lease, when Bemobile takes possession of the site, with annual payments made each year. A rent review occurs every five years. Upon expiry of the complete term of the lease the lease terms and conditions are re-negotiated by Bemobile and the landowner/s. Mitigation Measures

Preference for sites that will not require physical or economic displacement of people or cause any adverse socio-economic impacts on customary owners of land.

All utilized land is leased with full consent of the customary landowner/s. All utilized land is leased at fair market rate based on industry benchmarks for this type

of facility.

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Any crops that are disturbed or removed, and private production trees that are felled, lopped or damaged, are compensated for based on rates set out by (i) in PNG, the Valuer General or in line with economic tree prices published in the National Statistics Office bulletin, and (ii) in the Solomon Islands, the Ministry of Agriculture.

A site landowner is engaged as a part-time caretaker of the facility. D. Visual Impact 102. The visual impact of a built structure on a landscape is subjective, based on an individual’s perception of the structure and the aesthetic value of a landscape in which it is located. To many people BTS towers create an obvious visual impact on the landscape due to two key design features of these structures that make them highly visible against the skyline. Towers are usually installed:

on the highest local ridge or land, with the upper section sitting above surrounding structures and features, to provide the greatest possible RF coverage and line-of-sight microwave links; and

in proximity to areas frequented by people (i.e. residential and business areas and transport infrastructure).

103. Towers and masts in built environments may be perceived to be more obvious than those in rural locations due to the closer proximity of these structures to people, although this impact is ‘softened’ or may be partly shielded by tower proximity to other built structures. In rural areas towers are commonly on ridges at a distance of 200 m or more from the nearest dwelling and set back similar distances from major roads, therefore the visual impact may be considered lower than if the tower was within or on the edge of a rural village or large residential area. Mitigation Measures

Siting towers to minimize the land area required. Tower height limited to the maximum height required to achieve the desired signal

quality. Use of grey-coloured towers that partly blends in with the surroundings (except towers

required to be painted in other colours to make them visible to air traffic). In urban areas / built environments masts are installed in preference to lattice towers as

they create a lower perceived visual impact due to the narrower, single ‘pole’ compared to a tower supported by 3-4 legs spaced at 8-9 m with a tapering lattice arrangement of beams to the crest of the structure.

E. EMF and EMI 104. Electric and magnetic fields (EMF) are “invisible lines of force emitted by and surrounding any electrical device, such as power lines and electrical equipment” (IFC, 2007). Concern exists over the potential health effects from EMF exposure, although there appears to be no conclusive evidence demonstrating adverse health effects from exposure to typical EMF levels from power transmissions lines and equipment (IFC, 2007). 105. RF energy and microwaves emitted by transmitting antennas are a form of electromagnetic energy. Microwave and satellite system antennas transmit and receive highly concentrated directional beams at higher power levels. Evidence suggests that a mobile phone

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to the head will result in the person absorbing considerably greater RF energy than the maximum possible from tower-mounted wireless antennas (Strickland, R., 2009). 106. IFC recommendations applicable to the management of EMF exposure include:

Evaluating potential exposure to the public against the reference levels developed by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). Average and peak exposure levels should remain below the ICNIRP recommendation for General Public Exposure (Table 3);

Limiting public access to antennae tower locations; Following good engineering practice in the siting and installation of directional links (e.g.

microwave links) to avoid building structures; Taking into account public perception about EMF issues by consulting with the local

community during the siting of antenna towers. Table 3: ICNIRP Exposure Guidelines for General Public Exposure to EMF

Frequency Electric Field

(v/m)

Magnetic Field

(uT)

3 - 150 kHz 87 6.25

10 – 400 MHz 28 0.092

2 – 300 GHz 61 0.20

Source: IFC, 2007. Environmental, Health and Safety Guidelines for Telecommunications.

107. Electro-magnetic interference (EMI) is interference with a desired signal caused by the coupling of an undesired signal due to electromagnetic radiation. EMI can result from wireless communication equipment usage. EMI that is in the radio frequency range is known as radio frequency interference (RFI). The sources of EMI from Bemobile’s operation are burst transmission necessary for GSM TDMA Technique and DTX (Discontinuous Transmission) mode of operation for power saving by the equipment. Bemobile operates a GSM/GPRS network that is in general compliance with national and international standards requirements. Mitigation Measures

Bemobile complies with standards set forth by the following standards and regulatory bodies: 3GPP/ETSI Standards (GSM TS 05.90 version 7.0.0): March 1999/2001); and Pangtel, PNG.

Avoidance of buildings with directional microwave links. Average and peak exposures to radio waves designed below ICNIRP recommendations

and measured at ground level to check compliance during facility operation. Work sites monitored for exposure to electromagnetic waves, ensuring that conditions

are below ICNIRP recommendations. Public access to BTSs and repeater stations prevented by security fencing.

F. Aircraft Navigation 108. BTS and repeater station towers have the potential to create an aviation hazard, primarily where they are proposed to be sited on a flight path and/or within close proximity to an airport. As described in Section 3, approval to erect a tower has to be sought from the CAA. An

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application is submitted to the CAA to gain approval to erect a new tower as per CAA Rule Part 77. The CAA conducts an aeronautical study to determine whether the structure will constitute a hazard and, if approved, what measures are required to improve its safety. 109. CAA usually requires that the tower is lit and, where the tower is in close proximity to an airstrip, it is usually required to be painted in accordance with its rules. Mitigation Measures As directed by the CAA:

Lighting the tower with a nighttime light mounted on the peak. Painting the tower in accordance with CAA requirements as directed by the CAA at

hazardous sites (usually red and white). G. Hazardous Materials and Waste 110. Diesel is stored on BTS and repeater station sites to supply the generators that are used to supply either the primary and/or secondary power source for the facility. Diesel tanks are either 2,600 L overhead tanks or 1,300 L under-generator tanks. This volume of fuel is sufficient to run the generator full-time for 22-40 days. Tanks are refueled from either 205 L drums or small tankers. No spill collection provision such as bunding is provided beneath the fuel tanks to retain diesel that leaks or spills when filling. 111. Waste materials generated during construction include cleared vegetation, packaging from telecommunications equipment and other components, and general construction camp waste (perishable and non-perishable). Waste from facility operation includes filters and used oil from generators, material packaging and BTS components replaced during maintenance and repair. Mitigation Measures

Waste materials are segregated, reused or recycled where possible to minimise the volume of waste generated.

Cleared vegetation is made available to the site landowner/s for use or used during site revegetation.

Temporary toilet facilities provided for construction workers, usually consisting of a simple pit toilet.

All other construction waste and waste generated from maintenance and repair activities is removed from site following the completion of works.

A manifest of all on-site dangerous goods is posted at a location conveniently accessible to emergency services, detailing the location and normal quantity of dangerous goods stored.

All storage of hazardous materials will meet PNG and Solomon Islands standards, with quantities requiring licensed storage will be identified and license obtained.

Hazardous materials are stored to prevent spills and leaks enter stormwater drains, contaminating food stuffs and exposing other materials or general equipment to damage.

Bulk storage of hazardous materials is in bunded areas and identified by hazard (HAZCHEM) signage.

Any spills or leaks of fuel shall be immediately contained and moped up. Collection and storage of waste oils, fuels and chemicals in sealed containers in bunded

areas for subsequent on-site recycling or safe disposal.

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H. Emissions 112. The main sources of emissions to the air come from (i) the full-time (24 hours per day) operation of a diesel generator at each BTS and repeater station that is not connected to mains power and (ii) vehicle and machinery movements during construction and the servicing of these facilities. Facilities that use a generator for its primary power source are generally located at distance from the nearest dwelling or settlement, usually on ridges or higher land, therefore good dispersion of exhaust gases occurs. 113. Vehicle and machinery use during construction is usually limited to a three week period, while vehicles only access the facilities for maintenance and repairs once every 4-6 weeks on average, therefore these emissions are insignificant. Mitigation Measures

Use of deep cycle batteries to limit the run time of generators. Use of fuel-efficient diesel generators. Regular maintenance of generators to ensure they are in good working order. The use of solar panels to supplement BTS power requirements are being considered in

future designs. I. Noise 114. Construction noise is generated from earthmoving undertaken by a bulldozer or excavator to construct access roads and clear and level sites, and from vehicle movements transporting men and gear to the site. Earthmoving occurs over a short period – less than a day to clear the BTS site and between 1-5 days to construct the access road depending upon the length and conditions. These activities generate maximum noise levels in the order of 85-90 dB(A) at 7 m from the source. 115. Operational noise is primarily generated by the continuous operation of the diesel generator at facilities not connected to mains power, while a secondary operating noise source is the occasional movement of vehicle travelling to and from the site for maintenance and repair activities occurring (every 4-6 weeks). 116. Diesel generators used for the primary source of facility power run for 24 hours a day and emit noise levels of less than 60 dB(A) at 7 m under a 75% load. Generators are housed in noise reduction paneled walls with noise dampening insulation. The exhaust system is also constructed to minimize excessive noise. All facilities that utilize generators for their primary power source are located outside urban areas, with most of these facilities set back between 100-400 m from the nearest dwelling and commonly located on ridgelines at a higher elevation than nearby dwellings. Accordingly, noise is attenuated between the generator and receptor sites and thus causes a relatively minor disturbance at most. No complaints have been received about generator noise. Mitigation Measures

BTS and repeater stations that require generator power are located away from residences and other noise-sensitive receptors.

Site and nearby landowners and local communities informed of the construction schedule.

Construction activities restricted to daylight hours.

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Diesel generators and batteries designed for the site designed for the site and surrounding environment.

Generators housed in noise reduction paneled walls with noise dampening insulation, with an exhaust system designed to minimize excessive noise.

J. Safety 117. Safety hazards occur during BTS and repeater station construction, operation, maintenance and repair, relating to working with heavy materials and equipment, excavation and confined spaces, working at heights and in remote areas, working with electrical equipment, working in close proximity to RF and microwave energy, hot works and the use of explosive power tools. The safety hazard occurs for Bemobile staff during planning, field supervision of construction, and operation and maintenance of facilities, and for contractor staff employed to construct BTSs and repeater stations. 118. Bemobile implements its Risk Management & Health, Safety, Security and Environment Policy Manual (2009) “to protect the safety of employees, contractors, customers and community while having proper regards for protection of lives, property and the environment”. The Manual contains a system of aims, procedures, responsibilities, monitoring/auditing, reporting and review. It sets out required training, permitting requirements and procedures for hazardous activities that include hot works, digging, working in confined spaces and use of explosive power tools. It also includes an Emergency Programme with the purpose of providing for the safety of employees and the public, protecting the assets of the company, minimising the loss of customer and public confidence in Bemobile, and facilitating the prompt and selected targeted resumption of operations. Mitigation Measures

All employee and contractor activities are required to be undertaken in accordance with the occupational health and safety provisions of Bemobile’s Risk Management & Health, Safety, Security and Environment Policy Manual (2009), including hazardous work and emergency response procedures.

Induction training provided to all employees and contractors potentially exposed to hazardous conditions.

All staff required to wear hardhats in construction area, etc. Working at height during tower installation and repair carried out by fully trained/certified

tower riggers using industry-approved safety gear while climbing or working around towers.

Towers equipped with adequate railings and work platforms. Fire controls at BTS/repeater station sites include maintaining a grassed area 5-10 m out

from security fencing and lopping or removing overhanging trees and shrubs. Small bottle-type fire extinguishers provided at all BTSs and repeater stations and

maintained in working order. Security fencing erected around each BTS and repeater station to prevent access by the

public and stray animals, with signs placed on the fencing prohibiting entry and warning of the safety hazard.

Staff working in isolated areas equipped with two mobile phones (Bemobile and competitor) and a satellite phone to provide a good communication link.

Local people (usually the site landowner) employed to monitor and maintain the site.

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K. Cumulative Impact 119. The Project plus competitor facilities will create a limited cumulative visual impact as most towers will be located at least 1 – 2 km from each other, with the common rate of towers in a given rural area being only one per 3-5 km assuming that Bemobile and a single competitor’s facilities are servicing the same area. The cumulative impacts of soil erosion and noise are all deemed to not be excessive as the proposed facilities add very little.

VII. ENVIRONMENTAL MANAGEMENT PLAN A. Environmental and Social Management System 120. Bemobile’s environmental management system consists of a series of formal plans setting out procedures and measures to be implemented to effectively manage environmental, social and safety issues relating to site acquisition, facility operation and maintenance, and general work practices. The main plans that set out environmental management measures in PNG are:

Risk Management & Health, Safety, Security and Environment Policy Manual (2009); Site Acquisition Process (2009); and Schedule B – Maintenance Schedule (2010).

121. Bemobile Solomon Islands is adapting these plans to its territory. B. Management Responsibilities 122. Bemobile is responsible for the implementation of the Project, including all environmental and social management activities. All site selection and site investigation activities are undertaken by Bemobile. Tower construction is undertaken by contractors under Bemobile’s close supervision. Bemobile then undertakes all maintenance and repair activities during facility operation. 123. Bemobile will implement and monitor all environmental and social management measures during facility design, construction and operation. Duties will include acquiring all necessary approvals, permits and permission for Project construction and operation from Government authorities and landowners, incorporating appropriate controls into site selection and facility design, supervising and monitoring the implementation of environmental measures by the construction contractors, implementing environmental management measures during Project operation, and auditing compliance with EMP conditions and statutory requirements. C. Project Mitigation Measures 124. The avoidance and mitigation of potentially adverse environmental impacts will be undertaken by Bemobile commencing during pre-construction and continuing through construction to Project operation, as summarized in Table 4. The supervision, evaluation, and reporting of activities implemented as per the EMP will be carried out strictly and punctually to provide feedback to the Project management team.

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Table 4: Project Environmental and Social Management Measures

Project Activity Potential Environmental and Social Impact

Impact Mitigation Measure Responsibility1

PRE-CONSTRUCTION

Structure stability/safety Selection of stable, relatively flat sites with good existing access or the ability to construct access.

Geotechnical investigation of foundation conditions.

Structures designed for peak local wind speeds and foundation conditions.

Bemobile

Habitat loss / change Preference for sites with low habitat value, including being free of trees or requiring limited tree clearance.

Preference for sites with existing road access or in close proximity to existing road access.

Bemobile

Land degradation Site condition recorded in an Existing Condition Assessment that forms part of the Site Acquisition Report, including photographs of the area.

Bemobile

Noise BTS and repeater stations that require generator power are located away from residences and other noise-sensitive receptors.

Bemobile

Site selection and investigation

Land acquisition and involuntary resettlement impacts

Towers and other support infrastructure such as access roads will be sited on (i) registered land or land clearly owned by one clan, (ii) land that is away from any commercial development to avoid disrupting ongoing commercial activities, (iii) low-value land to avoid the loss of productive agricultural land, and (iv) uninhabited land to ensure that physical displacement from housing is avoided.

Bemobile

Consultation Landowner and community disputes

Consultation with senior local community representative/s to introduce the proposed development and determine the rightful landowner.

Convening a community open forum to introduce and discuss the proposed facility – design, operation, local communication benefits, etc.

Landowner/s discussion to introduce the proposed facility and leasing requirements, and negotiate a lease.

Bemobile

Aviation hazard Application to CAA for approval to construct the tower. Bemobile Approvals and permits

Building approval Application to Building Board (where applicable) for approval to construct the tower. Bemobile

CONSTRUCTION

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Land use change & land degradation

Restricting ground disturbance to the minimal area required for the BTS/repeater station and road construction.

Clearly pegging out the works, including the extent of the site to be disturbed.

Stripping topsoil off the site area to be leveled, then re-spreading this material on the surface following structure installation to revegetate and stabilise the area.

Compacting fill on BTS/repeater station platforms and forming cut and fill batters with stable grades.

Disposing of excess spoil from foundation excavation on sites where land degradation and erosion will not occur, such as placement along roadsides if permitted by the government or local road owners, or at nearby house blocks if requested by landowners, to improve these features.

Careful alignment of the earth access road to keep the road grade below 12% wherever possible and avoid crossing unstable and erosion prone slopes.

Installation of earth drainage banks across all new and upgraded earth access roads as required to provide good cross-road drainage.

Seeding disturbed areas immediately following landforming.

Gravelling BTS/repeater station compounds to minimize weed growth and prevent erosion.

Bemobile

Habitat Loss / Change Minimal vegetation removal, particularly tree clearance.

Vegetation to be removed or lopped clearly marked prior to the commencement of clearance, and clearance strictly controlled within the marked area.

Construction workers strictly prohibited from hunting and collecting forest products in and around facility sites.

Bemobile

Site clearance and landforming, road construction and ground stabilization

Business/employment opportunities for local population and compliance with national laws and core labor standards2

Bemobile will ensure that the contracts for goods and services provided by contractors, consultants and sub-contractors will contain provisions prohibiting them from engaging in (1) harmful or exploitative forms of forced labor, (2) child labor, (3) discrimination in respect of employment and occupation, and (4) restrictions of freedom of association and the effective recognition of the right to collective bargaining.

Bemobile

Landowner dealings Land leasing, resource compensation and production loss

All utilized land leased by mutual agreement with the landowner/s at fair market rate based on industry benchmark rates.

Impacts to crops and productive trees will be avoided. In the unlikely even that crops are disturbed or removed and production trees are felled, lopped or damaged, these will be compensated for at the rates published by the Valuer General or in line with economic tree prices published in the National Statistics Office bulletin in PNG, and the Ministry of Agriculture in the Solomon Islands.

Felled trees and other cleared or pruned vegetation (wood, branches and foliage) retained by owner/s of the vegetation for his/her use, or removed if requested by owner.

Bemobile

2 Core labor standards are a set of four internationally recognized basic rights and principles at work: (i) freedom of association and the effective recognition of the right to collective

bargaining, (ii) elimination of all forms of forced or compulsory labor, (iii) effective abolition of child labor, and (iv) elimination of discrimination in respect of employment and occupation.

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Visual impact Siting towers sited to minimize the land area required.

Use of grey-coloured towers that partly blends in with surroundings.

Tower height limited to the maximum height required to achieve the desired signal quality.

Masts installed in built environments in preference to lattice towers as they create a lower perceived visual impact due to the narrower, single ‘pole’ compared to a tower supported by 3-4 legs spaced at 8-9 m with a tapering lattice arrangement of beams to the crest of the structure.

Bemobile

EMF and EMI BTS designed in compliance with (i) 3GPP/ETSI Standards (GSM TS 05.90 version 7.0.0): March 1999/2001) and (ii) Pangtel, Papua New Guinea.

Avoidance of buildings with directional microwave links.

Average and peak exposures to radio waves designed to be below ICNIRP recommendations.

Public access to BTSs and repeater stations prevented by security fencing.

Bemobile

Waste Waste materials are segregated, reused or recycled where possible to minimise the volume of waste generated.

Cleared vegetation made available to the site landowner/s for use or used during site revegetation.

All other construction waste removed from site following the completion of works.

Bemobile

Hazardous materials Hazardous materials are stored so that spills and leaks will not enter stormwater drains, contaminate food stuffs of any kind and expose to damage other materials or general equipment.

Bulk storage of hazardous materials is in bunded areas and identified by hazard (HAZCHEM) signage.

Any spills or leaks of fuel shall be immediately contained and moped up.

Collection and storage of waste oils, fuels and chemicals in sealed containers in bunded areas for subsequent on-site recycling or safe disposal.

Bemobile

Emissions Use of fuel-efficient diesel generators.

The use of solar panels to supplement BTS power requirements is being considered in future designs.

Bemobile

Facility design and installation

Noise Affected and nearby landowners and local communities informed of the construction schedule.

Construction activities restricted to daylight hours.

Diesel generators and batteries designed for the site designed for the site and surrounding environment.

Diesel generators housed in noise reduction paneled walls with noise dampening insulation, with an exhaust system designed to minimize excessive noise.

Use of deep cycle batteries to limit the run time of generators.

Bemobile

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Safety All activities undertaken in accordance with the occupational health and safety provisions of Bemobile’s Risk Management & Health, Safety, Security and Environment Policy Manual (2009), including hazardous work and emergency response procedures.

Induction training provided to all employees and contractors potentially exposed to hazardous conditions.

All staff required to wear hardhats in construction area, etc.

Working at height during tower installation and repair carried out by fully trained/certified tower riggers using industry-approved safety gear while climbing or working around towers.

Towers equipped with adequate railings and work platforms.

Security fencing erected around each BTS and repeater station, and warning signs placed on fencing prohibiting entry and warning of the safety hazard.


Bemobile

OPERATION AND MAINTENANCE

Habitat loss / change Grass cutting and tree/shrub removal and pruning strictly undertaken in accordance with the site management plan. Bemobile

Land degradation Regular maintenance of access road surface and cross-road drainage to minimise erosion as required. Bemobile

Waste Waste generated by maintenance and repairs removed from site following the completion of works. Bemobile

Emissions Regular maintenance of generators to ensure they are in good working order. Bemobile

Maintenance and repair of facilities

Safety All activities undertaken in accordance with the occupational health and safety provisions of Bemobile’s Risk Management & Health, Safety, Security and Environment Policy Manual (2009), including hazardous work and emergency response procedures.

Work sites monitored for exposure to electromagnetic waves to ensure conditions remain below ICNIRP recommendations.

Fire controls at BTS/repeater station sites include maintaining a grassed area 5-10 m out from security fencing and lopping or removing overhanging trees and shrubs.

Small bottle-type fire extinguishers provided at all BTSs and repeater stations and maintained in working order.


Bemobile

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D. Environmental Monitoring 125. Environmental monitoring will occur during Project design, construction and operation to provide baseline data, confirm Project compliance and detect any adverse impacts/non-compliances. The focus of environmental monitoring is to ensure that construction and operational activities strictly comply with management plan provisions and avoid or minimise environmental impacts. 126. Regular internal environmental monitoring of construction works, associated activities and the implementation of environmental management measures will be undertaken by the bemobile during project design and construction as per the frequency set out in Table 5. The key environmental parameters that will be monitored during construction and operation are vegetation clearance and site disturbance, revegetation, drainage and erosion. Table 5: Summary of Project Environmental Monitoring

Environmental Monitoring Task Parameters Monitored Responsibility Frequency / Schedule

PRE-CONSTRUCTION

Recording of site environmental details in Site Acquisition Report

Existing land use Land condition

Bemobile Once prior to construction

Audit of approvals, permits & landowner Lease Agreement

Approvals, permits & landowner Lease Agreement


Audit of staff training in environmental management

Approvals, permits & landowner Lease Agreement


CONSTRUCTION

Site pegged to minimizing vegetation clearance / land disturbance

Bemobile Once prior to construction.

Extent of land disturbance / vegetation clearance

Bemobile Once during construction. Construction contractor compliance with environmental management requirements

Topsoil / spoil spread Drainage & revegetation measures installed

Bemobile Once following completion of construction

OPERATION AND MAINTENANCE

Condition review of facility, surrounding area and road, including completion of Incident Report Form if applicable

Damage to fence / evidence of illegal entry Vegetative cover / fire hazard around the site Erosion & sedimentation around the site & along the access road Trafficable road

Bemobile

Ongoing by caretaker Every 4-6 weeks when generators are refueled by Bemobile

Submission of Monitoring Report to the ADB

General environmental compliance of Project facilities, complaints and landowner disputes

Bemobile Every 12 months

E. Institutional Arrangements, Environmental Reporting and Record Keeping 127. Bemobile will liaise with Government authorities as required during Project implementation and undertake any required corrective actions as directed by these authorities. The Project will maintain an environmental record system that records (i) significant environmental and social matters, including monitoring data, occupational accidents, fire, and other emergencies, and (ii) public complaints, concerns and accidents involving the public. This information will be reviewed and evaluated to improve the effectiveness of the environmental, health, and safety program, and an annual summary will be prepared and reported to the ADB.

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Bemobile’s environmental and social monitoring reports will include (i) information on the sites acquired during the reporting period and that site acquisition did not entail involuntary resettlement and indigenous peoples and (ii) compliance of contractors, subcontractors and consultants with national laws and core labor standards.

VIII. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE 128. Public consultation is undertaken during the site investigation process for each proposed BTS or repeater station. Consultation focuses on the potentially affected community and site landowner/s to explain the design and functioning of the proposed facility, answer questions about the facility and local mobile phone reception following installation, and to identify the rightful landowner/s. Consultation commences with a discussion with a village elder / church leader / councilor to identify the rightful landowner/s and to convene an open community forum. The community forum is open to any member of the local community who wishes to attend and assists in identifying the rightful site landowner/s where there may be doubt. 129. The community forum commences with Bemobile explaining the purpose of the proposed structure, including the communication benefits to local communities that will occur, the structure’s design, function and operational requirements, and Bemobile’s desire to lease site and access RoW land. Attendees ask a range of questions and make comments that are responded to by Bemobile. Common questions and issues of concern raised by communities include EMF health hazards, improvement in local mobile phone coverage and the casual employment of local people to assist with facility maintenance and monitoring. Bemobile’s responses to these commonly raised issues include discussing the World Health Organization’s finding that EMF is not a health issue, describing the improved phone coverage that will occur and discussing the casual employment requirements for the facility. A list of attendees and meeting minutes are not normally recorded for the semi-formal open forums. 130. Lease discussions then occur with the affected landowner/s to arrive at a fair rental rate based on industry benchmarks. Negotiations usually occur with the leaders of the clan/family that is confirmed as the rightful owner/s of the site. 131. On-going discussions with the local community may occur where an issue arises, but this is rare. Press releases are occasionally made to provide information to the public about facilities and services, usually via local media.

IX. GRIEVANCE REDRESS MECHANISM 132. Grievance and dispute resolution for site landowners and the community regarding environmental performance and lease issues is undertaken through Bemobile’s complaint handling process. Site landowners who have leased land to Bemobile can formally or informally lodge a complaint or grievance with the Site Acquisition Team during or following the lease period. This complaint is recorded in a Complaints Register. Bemobile undertakes to resolve all issues within 30 days of receiving the complaint. The resolution process usually involves discussing the issue and inspecting the site (where required) with the complainant. The Existing Condition Assessment completed prior to the commencement of the site lease, before facility construction commenced, is commonly used as evidence of pre-lease site baseline conditions where the issue relates to site damage. Where a complaint has merit, options to resolve the issue are discussed with the complainant and agreement is reached on appropriate action, responsibility for implementation and the timeframe for completing the action. Follow-up contact

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is made with the complainant following implementation of the agreed action to check that the issue has been satisfactorily resolved. Grievances and disputes that cannot be resolved through Project-related mechanisms or mutually acceptable mediation channels have recourse to national law through the judiciary. 133. Community complaints are handled in a similar manner to site landowner complaints. Each complaint is recorded in the Complaints Register, with Bemobile aiming to resolve each issue within 30 days of receiving the complaint. The issue is discussed with the complainant on site if required or by phone. Where both parties agree that the complaint has merit, options to resolve the issue are discussed with the complainant and agreement reached on appropriate action, responsibility for implementation and the timeframe for completing the action, with follow-up made to gauge / ensure satisfaction with the corrective action.

X. FINDINGS, RECOMMENDATIONS AND CONCLUSION 134. BTSs and repeater stations are relatively low impact structures during construction and operation. The principal measure available to avoid or reduce the environmental impact of these facilities is site selection. Bemobile applies a logical, sequential and well documented site selection procedure to balance economic, engineering, environmental and social considerations to achieve facilities that:

optimize facility operation (RF reception and microwave links); minimize environmental and social impacts; are acceptable to the affected landowner/s; and are safe.

135. A very small land area is required for each facility (400 m2), and a number of site options usually exist in the desired area that allow the selected site to avoid sensitive areas and create minimal environmental and social impacts. 136. Construction involves small scale land disturbance per site (up to 800 m2) over a short duration (around three weeks), creating minimal impact on most sites due to the avoidance of higher value land uses, structures and forest where possible. Earth road construction, required to around 50% of BTSs in PNG, usually requires more land than the BTS or repeater station site, averaging between 2,000-4,000 m2 (0.2-0.4 ha) per site. 137. The operation of these facilities also creates minimal environmental impact. The facilities are essentially ‘static’ structures, with the main impacts being exhaust emissions and noise from the generator and erosion of the road surface and resulting sedimentation if drainage is inadequate. Maintenance and repair activities are relatively simple, involving limited inputs every 4-6 weeks. 138. The implementation of measures contained in the environmental management plan will adequately avoid or mitigate the potential environmental impacts associated with the Project. Provision shall be made in the Project budget to cover the environmental mitigation and monitoring costs. 139. The installation of BTSs and repeater stations usually receives broad community support since the principal benefit of these developments is improved communications from increased

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network coverage and improved mobile phone reception. These facilities are also usually strongly supported by site landowner/s as they receive a direct economic benefit from the facility in the form of lease payments and usually part-time employment as the caretaker of the facility. 140. This IEE and the Environmental and Social Compliance Audit Report (Appendix B) are an adequate environmental assessment for the proposed Project as no significant environmental impacts have been identified in either PNG or the Solomon Islands, therefore an EIA is not required nor are any supplementary studies. In the event that a BTS, repeater station or associated access road is proposed in a protected area (e.g. within a National Park) or on another type of sensitive site then a site-specific assessment will be require.

XI. REFERENCES ADB, 2003. Environmental Assessment Guidelines. Asian Development Bank. Manila.

ADB, 2009. Safeguard Policy Statement. Asian Development Bank. Manila.

AusAID, 2009. http://www.ausaid.gov.au/country/png/png_intro.cfm. October 2009.

AusAID, 2009. http://www.ausaid.gov.au/country/country.cfm?CountryID=16. January 2010.

Bemobile, 2009. Site Acquisition Process. Port Moresby.

Bemobile, 2009. Risk Management & Health, Safety, Security and Environment Policy Manual. Port Moresby.

Bemobile, 2010. Schedule B – Maintenance Schedule – version 1. Port Moresby.

Department of Communications, 2008. National Information & Communications Technology (ICT) Policy. Papua New Guinea.

IFC, 2007. Environmental, Health and Safety Guidelines for Telecommunications. International Finance Corporation, World Bank Group. Washington DC.

Independent State of Papua New Guinea, 2000. Civil Aviation Act 2000. In Consolidated Legislation of Papua New Guinea.

Independent State of Papua New Guinea, 1982. National Parks Act 1982. In Consolidated Legislation of Papua New Guinea - Chapter 157.

Independent State of Papua New Guinea, 1984. National Parks Regulation 1984. In Consolidated Legislation of Papua New Guinea - Chapter 157.

Solomon Islands Government, 2009. Telecommunications Act 2009. Solomon Islands Government, 1986. Civil Aviation Act. In Laws of the Solomon Islands - Chapter 47.

Strickland, R., 2009. “Tower-mounted Antennas Improve RF Safety for Cell Phone Users”. In Above Ground Level.

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APPENDIX A: TOWER SITING CRITERIA

The main factors considered when siting BTSs are: (i) Location Identification

adequate local population to achieve cost-effective coverage microwave link achievable RF coverage adequate for target population, road, etc.

(ii) Micro-siting Engineering - a preference for higher terrain for improved signal quality

- set back from other wireless communication facilities - at least 100 m from high voltage electricity transmission lines - no line-of-site obstacles to neighbouring network BTSs/repeater stations - slope not exceeding 1 in 5 (20%) - stable site with suitable soil/geology - not on a wetland (swamp) or rubbish dump

Access - access available via an existing road or a road can be constructed Land ownership - site within property boundary

- identifiable ownership - uncomplicated ownership (i.e. not in dispute & few owners) - landowner/s is willing to lease the land

Environment - not within a protected area

- not on an environmentally significant or sensitive site - will not create an aviation hazard - requiring minimal tree clearance - not excessively steep

Social - no resettlement required

- not on cultivated land - not on a heritage site, sacred site or locally significant area - avoiding services where possible (sewerage, water supply etc) - set back from playgrounds

APPENDIX B – ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT REPORT

A. Executive Summary 1. Bemobile is seeking a direct term loan from the Asian Development Bank (ADB) to partially fund the PNG and Solomon Islands: Bemobile Telecommunications Investment Project (the Project). 2. Base transceiver stations (BTSs) and repeater stations are relatively low impact structures during construction and operation. The principal measure available to avoid or reduce the environmental impact of these facilities is site selection. Bemobile applies a logical, sequential and well documented site selection procedure to balance economic, engineering, environmental and social considerations to achieve facilities that:


3. A very small land area is required for each facility (400 m2), and a number of site options usually exist in the desired area that allow the selected site to avoid sensitive areas and result in minimal environmental and social impact. 4. Construction involves small scale land disturbance per site (up to 800 m2) over a short duration (around three weeks), creating minimal impact on most sites due to the avoidance of higher value land uses, structures and forest where possible. Earth road construction, required to around 50% of BTSs in PNG, usually requires more land than the BTS or repeater station site, averaging between 2,000-4,000 m2 (0.2-0.4 ha) per site. 5. The operation of these facilities also creates minimal environmental impact as they are virtually ‘static’ structures. The main environmental impacts are erosion of the road surface and resulting sedimentation if drainage is inadequate, and exhaust emissions and noise from the generator. Maintenance and repair activities are relatively simple, involving limited inputs every 4-6 weeks. 6. Relatively minor improvements are recommended to Bemobile’s current environmental management practices to reduce impacts and improve facility management. These consist of: (i) expanding the greenfield site selection criteria contained in the Site Acquisition Process to include the full range of applied criteria; (ii) better marking of the vegetation clearance area boundary prior to commencing construction at facility sites; (iii) improved BTS / repeater station pad earthworks; (iv) improved road construction; and (v) formalizing guidelines for working at heights. 7. The implementation of these improvements and the measures contained in the environmental management plan in the Initial Environmental Examination for the Project, plus the measures in Bemobile’s other management plans and processes, will adequately avoid or mitigate the potential environmental impacts associated with the Project.

B. Facilities Description 8. Bemobile PNG currently has around 188 BTSs in operation. In the Solomon Islands Bemobile has 50 BTSs in operation. 9. Each BTS typically consists of a small parcel of leased land (usually 400 m2), a tower or mast, a microwave antenna and RH antenna mounted on the tower, switch gear at the base of the tower, a diesel generator and fuel tank, security fencing and an earth access road leading to the site. The BTS yard is commonly between 9 x 9 m (81 m2) and 15 x 15 m (225 m2). Towers/masts are either: (i) a self-supporting lattice tower (SST); (iii) a rapid deployment structure (RDS - also a lattice tower); or (ii) a monopole mast. Lattice towers with a height of between 30-60 m (commonly 45 m) are usually constructed on greenfield rural sites. Self-supporting towers have three legs set into concrete block footings at around 3 m depth and are preferred where there is adequate time available to construct the facility and good road access for concrete delivery. RDSs are installed to save on construction time. They consist of a four legs bolted to interlocking steel beams and plates that form a raft foundation installed partly under ground level. Monopole masts are used in urban areas to minimize visual impact, commonly to a height of 25-30 m. 10. Depending on the type and height of towers, around of 600-800 m2 of ground is cleared of vegetation at each site, providing sufficient space to store tower beams and other components during construction and to establish a small temporary workforce camp. 11. An earth access road is constructed to BTS sites where vehicle access is not possible (around 50% of sites in PNG). Where there is an existing track this may be upgraded to improve access. In PNG around 50% of sites require a new road. New roads range from 50 m and 2,500 m in length, averaging around 500 m in length per site, and are typically 4 m wide. This equates to an average of between 2,000-4,000 m2 (0.2-0.4 ha) per site. 12. Bemobile PNG proposes to use the ADB loan to:

(i) build its own backbone infrastructure to reduce dependence on Telikom PNG infrastructure and thus improve service reliability which is currently subject to periodic outages of microwave transmission links;

(ii) accelerate the coverage of its network to access more people and improve existing reception in some areas, allowing Bemobile to secure additional customers;

(iii) add capacity to the existing network in Port Moresby, enabling the supply of data services; and

(iv) rationalise BTS equipment across the network, aggregating equipment from each vendor in different areas to rationalize the system and for ease of maintenance.

13. In the Solomon Islands Bemobile proposes to apply the ADB loan to its further network rollout.

C. Summary of Applicable Environmental Laws, Regulations and Standards 14. The Project is subject to Government of PNG and Government of the Solomon Islands approvals and permits, as well as ADB due diligence assessment.

1. PNG Approvals and Permits 15. Approval to install telecommunication towers in PNG is required from the Building Board in urban areas and from the Civil Aviation Authority in proximity to airports. 16. Building Board. Proposed BTSs in urban areas must be approved by the local Building Board before construction commences (PNG 1001-182). The main locations where this is required are Port Moresby and Lae. Bemobile lodges an application with the Board to seek approval for the structure. The application contains location and design information. After approval and construction Bemobile obtains independent structural certification from a qualified engineer and submits this to the Board for its records. 17. Civil Aviation Authority. An application has to be lodged with the Civil Aviation Authority (CAA) to gain approval to erect a new tower, titled Application for Issue or Renewal of a Certificate under CAR Part 77 to Construct or Alter a Structure. Details required in the application include type and height of the structure, location, distance to the airport and construction program. Upon receipt of the application the CAA undertakes an aeronautical study to determine whether the structure will constitute a hazard and, if approved, what measures are required to improve its safety. The CAA usually requires towers in close proximity to an aerodrome to be lit and painted in accordance with its rules (Refer to Appendix B of Civil Aviation Rule Part 77 of the IEE). 18. Valuer General / National Statistics Office. Where trees are proposed to be felled and crops removed or disturbed, the owner of the land must be compensated as per the conditions and rates set out by the Valuer General or in line with economic tree prices published in the National Statistics Office bulletin.

2. Solomon Islands Approvals and Permits 19. Approval to install telecommunication towers in the Solomon Islands is variously required from the Ministry of Infrastructure and Development, the relevant provincial Planning Board or city Council, and potentially from the CAA, Ministry of Lands and Ministry of Agriculture. 20. Ministry of Infrastructure and Development. Typical cell site technical specifications, designs and supporting calculations have to be submitted to the Ministry of Infrastructure and Development for its review and approval. The documentation required includes civil engineering and structural designs and calculations, electrical and earthing design, and the radiation plan. In addition, a basic/generic environmental impact assessment must be submitted for review and approval. 21. Provincial Planning Boards and Council. After Ministry of Infrastructure and Development approval is obtained, construction permits can be requested from provincial Planning Boards and the local city council if applicable. An application for a construction permit has to include a copy of the documentation approved by the Ministry

of Infrastructure and Development, a layout plan of the site/s including site orientation and coordinates, location plan/s and soil test results. Construction may only commence once a construction permit is granted. 22. Civil Aviation Authority. Flight path clearance is required from the CAA under the Civil Aviation Act 1986 and any related Regulation/s for the purpose of ensuring the safety of aircraft flying in accordance with normal aviation practice. This relates to the power to prohibit and restrict the erection of buildings, structures or other things in any area specified, and the display of lights of an approved type, on buildings or structures within the area customarily used by aircraft within the vicinity of airports. 23. An application has to be lodged containing a map indicating the site location, coordinates and elevation, accompanied by a copy of the documentation approved by the Ministry of Infrastructure and Development. Structure construction may only commence once clearance from the CAA has been obtained. 24. Ministry of Lands. Approval of a road right-of-way (RoW) is required from the Ministry of Lands. The application has to indicate the purpose, length, width, location and route of the RoW. 25. Ministry of Agriculture. Where trees are proposed to be felled and crops removed or disturbed, the owner of the land must be compensated as per the conditions and rates set out by the Ministry of Agriculture.

3. ADB Standards 26. The ADB standards for environmental management relating to telecommunication facilities is contained in the International Finance Corporation (IFC) Environmental, Health and Safety Guidelines for Telecommunications (2007). In addition, a general standard for general environmental, health and safety practices is contained in the IFC Environmental, Health and Safety General Guidelines (2007). D. Audit and Site Investigation Procedure 27. This compliance audit, assessing the effectiveness of Bemobile’s existing environmental and social management system against (i) applicable laws and regulations, (ii) Bemobile’s management system and (iii) IFC guidelines for telecommunications, was conducted in PNG during two separate country visits by (i) S.L.Tu, Senior Environment Specialist, PSOC (Mission Leader) and J.E. Munsayac, Senior Social Safeguards Officer, PSOC (Member) between 21-23 January 2010; and (ii) M. Corbett, staff Environmental Consultant to PSOD between 5-10 February 2010. 28. This audit was based on field inspections of 10 Bemobile BTSs (either operating or under construction), as well as discussions with Bemobile staff and a review of Bemobile’s documented management processes and plans. A list of persons met during the Audit is provided in Attachment 1. 29. Bemobile’s environmental management system consists of a series of formal plans setting out procedures and measures to be implemented to effectively manage environmental, social and safety issues relating to site acquisition, facility operation and

maintenance, and general work practices. The main plans that set out environmental management measures for PNG that were reviewed as part of this audit are:

Risk Management & Health, Safety, Security and Environment Policy Manual (2009);

Site Acquisition Process (2009); and Schedule B – Maintenance Schedule (2010).

E. Findings and Areas of Concern 30. Bemobile PNG generally follows its documented procedures, adopting procedures that minimize reputational risks related to environmental and social impacts throughout the project cycle. In particular, the Site Acquisition Process has been found to save time and reduce the number of landowner disputes by setting out a clear process documented site selection and landowner and community engagement process.

1. Environment 31. BTSs and repeater stations are relatively low impact structures during the construction and operation phases. The principal measure available to avoid or reduce the environmental impact of these facilities is site selection. Bemobile applies a logical, sequential and well documented site selection procedure to balance economic, engineering, environmental and social considerations to achieve facilities that:


32. The site selection process includes an Existing Condition Assessment that documents the state of the land/premises prior to the start of construction, thereby reducing the chance of disputes between the landowner/s and Bemobile and the construction contractor for perceived damage to these assets. 33. The design of facilities incorporates environmental mitigation measures, including towers and foundations designed to withstand peak wind conditions, use of grey-coloured towers that partly blends in with surroundings, tower height limited to the maximum height required to achieve the desired signal quality, masts installed in built environments in preference to lattice towers as they create a lower perceived visual impact, and towers deemed to create a potential aviation hazard fitted with a nighttime light mounted on the peak and painted in accordance with CAA requirements (usually red and white). 34. Facility construction is low impact, involving small scale land disturbance at each site (up to 800 m2) over a short duration (around three weeks). This creates minimal impact on most sites due to the avoidance of higher value land uses, existing structures and forest areas wherever possible. Site earthworks are relatively minor as flat to gently sloping sites are selected wherever possible. The proposed yard area (81-225 m2) and immediately surrounding land is leveled with an excavator or bulldozer, commonly

requiring less than a metre of cut and fills across the site. The tower, either a self-supporting structure or rapid deployment structure, is then installed on in-situ soil. 35. Earth road construction has the potential to create the most significant adverse environmental impact associated with BTSs and repeater station installation. An average of 2,000-4,000 m2 of land is disturbed per new road, usually involving cross-slope excavation. Excavated material is used to construct fill embankments on the low side of the road or disposed of nearby, with an average road generating 800 m3+ of fill. 36. Bemobile manages the construction contractor who is responsible for facility installation by closely monitoring their activities during construction, conducting a due diligence review of the completed works and ensuring that the construction contractor undertakes corrective actions as directed by Bemobile. 37. Standard environmental controls implemented during construction include surveying and pegging the facility yard, marking out the extent of clearing with pegs, pegging out the yard area within the broader clearance area, stripping and stockpiling topsoil from the site before it is leveled, removing construction waste from the site, and respreading of topsoil following construction to promote site revegetation. Vegetation removal was restricted to around 700-800 m2 per site, close to the minimum area needed for construction. 38. The operation of these facilities also creates minimal environmental impact. The facilities are essentially ‘static’ structures, with the main impacts being exhaust emissions and noise from the generator and erosion of the road surface and resulting sedimentation if drainage is inadequate. Environmental controls implemented during facility operation include maintaining vegetation at a low height 5-10 m out from the facility to reduce the fire hazard of the site and prevent vegetation growth on the facility, maintaining access roads, removal of waste and regular maintenance of generators. Established facilities were clean and tidy apart from the odd piece of litter and spoil or topsoil stockpile/windrow that had not been respread following the completion of construction. No spilled fuel was observed.

2. Social 39. Involuntary Resettlement and Land Leasing. Installation of BTS will require limited space for roof- or wall-mounted antennas or a small parcel of leased land (approximately 200-400 m'). Depending on the type and height of towers, around of 600-800 m2of ground is cleared of vegetation at each site, providing sufficient space to store tower beams and other components. To ensure adequate access to sites during construction and maintenance, existing all-weather roads will be improved or extended. New roads range from 50 m and 2,500 m in length, averaging around 500 m in length per site, and are typically 4m wide. Bemobile has adopted strict selection criteria in line with its Site Acquisition Process (2009) in order to avoid involuntary resettlement and adverse Indigenous Peoples impacts. For each telecom tower site, Bemobile identifies several sites and follows a strict selection criteria whereby only lands that are vacant, unproductive, and undisputed are selected and the final site, including road access, is selected based on the landowner's full consent to lease the land and agreement to the terms of lease including the lease price.

40. Resettlement is not required for the establishment of BTS or repeater stations. Site selection avoids sites with dwellings, only siting facilities on land devoid structures and of low productivity where ever possible. Any potential site requires the landowner’s full consent to lease the land before it is utilized. Bemobile minimizes the chance of landowner disputes by: (i) identifying the correct landowner/s through community consultation; (ii) only entering into lease negotiations once it is convinced it has found the rightful owner/s; and (iii) having the Existing Condition Assessment as part of the lease documentation, signed by the landowner prior to the start of construction. 41. The lease rate is based on fair market value provided by the Office of the Valuer General, Department of Lands (DOL) based on land location and capability, the proposed land use and current lease records as well as information on lease price gathered through informal interviews with residents in the area. If lease records are not available, the market value of land in adjacent site or towns are used. The final lease rate is negotiated with the landowner/s and is usually higher than the DOL market rate. Lease agreements are signed prior to any site clearing or tower installation. Generally, leases are 10 years plus two options to extend for 5 years each. However, if Bemobile fails to pay the rent for more than 21 days and if this happens continuously, the indigenous landowner can terminate the lease agreement. Bemobile is required to restore the land to its former state and condition upon expiration or termination of a lease agreement. Upon expiration of the lease agreement the customary owner can again renegotiate the terms of lease. Bemobile will avoid impacts to crops and productive trees. In the unlikely event, that crops are disturbed or removed and production trees are felled, lopped or damaged, these will be compensated for at the rates published by the Valuer General or in line with economic tree prices published in the National Statistics Office bulletin in PNG, and the Ministry of Agriculture in the Solomon Islands. Felled trees and other cleared or pruned vegetation (wood, branches and foliage) retained by owners of the vegetation for his/her use, or removed if requested by owner. 42. Indigenous Peoples. There are estimated to be over 1,000 cultural groups in PNG, but none are deemed to be minorities. Bemobile's Site Acquisition Process requires that only sites that will not entail any physical or economic displacement of people or cause any adverse Impacts on customary owners of land will be selected. The customary owner also provides full consent and indicates that the price offered will be acceptable. If sites are located near cultural or religious sites, rituals will be performed with full consultation and participation of the relevant communities. If there is no consent from customary owners, an alternative site is found. The clan or subclan (family) that owns the land directly benefit from lease fees that are greater than alternative land use revenue. In PNG, Bemobile has adopted a Guardianship Program which requires that the Company hires the indigenous landowner to provide on-site security services. The local guardian should be a member of the clan from whom the site is being leased. To ensure good working relationships with local guardians and regional customs and traditions are followed, the site advisor hired by the Company also comes from the same region where the site is located. During construction, construction workers are also strictly prohibited from hunting and collecting forest products in and around facility s'ites thereby avoiding impacts to common property resources of indigenous peoples in the area. The same arrangements will be implemented in Solomon Islands. 43. Gender, Labor and Social Protection. Ninety percent of Bemobile employees are local. Bemobile has an Equal Opportunities Policy (2010) which sets out the their

position on equal opportunity in all aspects of employment, including recruitment and promotion, and provides guidance and encouragement to employees at all levels to act fairly and to prevent discrimination on the grounds of sex, race, marital status, disability, part-time and fixed term contract status, age, sexual orientation or religions. Bemobile is committed not only to its legal obligations but also to the positive promotion of equality of opportunity in all aspects of employment. Employees may lodge their complaints regarding discrimination through the Bemobile's Grievance Procedure which will be followed by an investigation. Discrimination is considered an unacceptable conduct which may lead to disciplinary action under their Disciplinary Procedure. Bemobile’s policy is based on it being a meritocratic employer with no bias towards gender, health, disability, race or religion, and rewarding staff fairly for good performance and providing them with first class benefits to improve health and living standards. With respect to salaries and wages, Bemobile gives competitive wage rates which is twice the minimum wage for fulltime casuals. 44. During construction a small temporary workforce camp is sometimes established. Towers can be installed using highly efficient methods and practices, such as the Rapid Deployment Structure (RDS). The RDS can be, installed within four working days, therefore, providing least disruption to surrounding communities. Employment opportunities are generated for the local community since civil works contractors often hire local unskilled labor. For remote tower sites normally 10 to 16 “Casual” laborers are required to assist in the construction and provide security. These are from the local community. Similarly Bemobile creates permanent positions for these sites to local engineers /technicians/construction officers who are from the local area. 45. With respect to health and safety during construction and operation, contractors follow the occupational health and safety provisions of Bemobile's Risk Management & Health, Safety, Security and Environment Policy Manual (2009), including hazardous work and emergency response procedures. The contracts for civil works contractors in PNG and SOL include provisions to comply with national labor laws and core labor standards.1 The same arrangements will be adopted in Solomon Islands. 46. Consultation and Participation. Consent from customary owners is necessary for BTS sites as well as for any improvements made on access roads. If sites are located near cultural or religious sites, rituals are performed with full consultation and participation of the community. Grievance and dispute resolution for site landowners and the community regarding environmental performance and lease issues is undertaken through Bemobile's complaint handling process. Site landowners who have leased land to Bemobile can formally or informally lodge a complaint or grievance with the Site Acquisition Team durilig or following the lease period. This complaint is recorded in a Complaints Register. Bemobile undertakes to resolve all issues within 30 days of receiving the complaint. 47. Corporate Social Responsibility Policy (CSR). Bemobile adopted an official CSR Policy in July 2009, under which it is developing detailed procedures and guidelines. CSR activities involve a socially responsible commercial approach focusing

1 Core labor standards are a set of four internationally recognized basic rights and principles at work: (i) freedom of association and the effective recognition of the right to collective bargaining, (ii) elimination of all forms of forced or compulsory labor, (iii) effective abolition of child labor, and (iv) elimination of discrimination in respect of employment and occupation.

on building local capacity and promoting positive social values among its employees and in the broader community. Recognizing the difficulties of thousands of villagers who struggle to obtain clean water everyday, Bemobile has launched the Bemobile TRUST H2O Project(fresh water for villages). Through this project, Bemobile will provide 5,000 liter rainwater tanks for the use of school kids and the entire village (selected villages). Bemobile is sponsoring sporting events (rugby, cricket), radio programs, small-scale community water supply projects and local mobile health clinic services. Aside from its community development programs, Bemobile is also conscious on branding and has retained a qualified anthropologist to advise on its promotional materials. F. Corrective Action Plan 48. Minor improvements are recommended to Bemoblie’s current environmental management practices to improve outcomes.

1. Environment 49. It is recommended that the Site Acquisition Process Section 3.3.3 be improved by including the full range of greenfield site selection criteria that Bemobile applies. 50. Environmental management during construction can be improved in the following areas: (i) better marking of the vegetation clearance area boundary; (ii) improved BTS pad earthworks; and (iii) improved road construction. 51. The site area cleared of vegetation at inspected sites under construction appeared, in some instances, to exceed the minimum area required for the facility yard plus a surrounding temporary construction area incorporating material storage. It is recommended that the boundary of the area to be cleared is limited to the minimum area required for construction and more clearly marked using tape or additional pegs to minimize clearance. Clear marking allows the bulldozer or excavator operator to clearly see the extent of the site. 52. Several recently constructed access roads that were inspected had windrowed material deposited in small watercourses on the lower side of the road and little cross-road drainage had been installed, resulting in a raised erosion hazard along these roads. It is recommended that Bemobile develop a simple road construction standard that that are included in the specification of works. This specification should include (i) fill embankment grades and minimum compaction requirements, (ii) prohibition of windrowing along roadsides (that prevents drainage off the road), (iii) prohibition of soil being deposited in watercourses, and (iv) cross-road drainage installed at reasonable intervals along new roads (i.e. every 80-120 m depending upon the road grade, amount of run-on, etc). Drainage can be in the form of broad earth banks, causeways or pipe culverts. 53. Several recently leveled facility sites had been formed with steep, uncompacted fill embankments. It is recommended that Bemobile develop standard specifications for fill embankment grades and compaction that are included in the specification of works. 54. Bemobile does not appear to have guidelines for working at heights. It is recommended that such guidelines are developed.

2. Social 55. No specific actions are recommended to improve Bemobile’s social management practices apart from the recommended improvement of Section 3.3.3 of the Site Acquisition Process Section as described above.

Attachment 1: PEOPLE MET DURING AUDIT Roger Blott Chris Raps Chief Executive Officer, Bemobile Chief Commercial Officer, Bemobile [email protected] [email protected] John Papazian Doug Grapevine Chief Financial Officer, bemobile Chief Technical Officer, Bemobile [email protected] [email protected] Sainimere Veiogo Jack Tomon Manager, Human Resources, Bemobile Mobile Engineering Manager, Bemobile [email protected] [email protected] Simon Krahwazi Mark Schmid Project Manager, Bemobile Roaming & Interconnect Consult., Bemobile [email protected] [email protected] Joe Ginisi Petu Petueli Project Manager, Bemobile Site Acquisition, Bemobile [email protected] [email protected] Charles Ofoi Robert Agua, Bemobile RF Engineer, Bemobile [email protected] [email protected] Grant Hassell Operations Director, Bemobile [email protected] Nancy Sullivan Emil Patugarea Nancy Sullivan Ltd. & Associates Assistant Valuer General Anthropologist (on call to Bemobile) Valuation Co-ordination [email protected] Dept. of Lands and Physical Planning Ministry of Lands

[email protected] Rose Kualke Singadan David Kau Manager Program Officer Dept. of Environment and Conservation Dept. of Environment and Conservation [email protected] [email protected] Several members of Kone family Barakau Site

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