sanitation and water project for the greater...

E4089

MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT (MLGRD)

SANITATION AND WATER PROJECT FOR THE

GREATER ACCRA METROPOLITAN AREA (GAMA)

REVISED DRAFT REPORT

ENVIRONMENT AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

FOR SANITATION AND WATER PROJECT FOR GAMA

Prepared By: Dyson T. Jumpah

[email protected]

DECEMBER 2012

7TH FLOOR, TRUST TOWERS

FARRAR AVENUE, ADABRAKA

ACCRA, GHANA.

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DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 ii

LIST OF ABREVIATIONS AND ACRONYMS

ARAP

ARIC

Abbreviated Resettlement Action Plan

Audit Review Implementation Committee

BOD Biochemical Oxygen Demand

BP Best Practice

DACF District Assemblies Common Fund

DANIDA

DDF

Danish International Development Agency

District Development Fund

EA

EIA

EMP

ESO

EPA

ESIA

ESMF

ESMP

Environmental Assessment

Environmental Impact Assessment

Environmental Management Plan

Environment and Social Officer

Environmental Protection Agency

Environmental and Social Impact Assessment

Environmental and Social Management Framework

Environmental and Social Management Plan

GAMA Greater Accra Metropolitan Area

GoG Government of Ghana

IGF Internally Generated Funds

ILGS Institute of Local Government Studies

L.I. Legislative Instrument

LG Local Government

MDA Ministries, Departments and Agencies

MLGRD

MMA

Ministry of Local Government and Rural Development

Metropolitan and Municipal Assemblies

MMDA Metropolitan, Municipal and District Assemblies

MOFEP Ministry of Finance and Economic Planning

MPCU

NDAP

Metropolitan/Municipal Planning and Development Unit

National Decentralisation Action Plan

NEAP

NGO

OP

PEFA

National Environmental Action Plan

Non Governmental Organization

Operational Policy

Public Expenditure and Financial Accountability

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 iii

PFM Public Financial Management

RAP

RCC

RPF

SPEFA

UDU

Resettlement Action Plan

Regional Coordinating Council

Resettlement Policy Framework

Social Public Expenditure and Financial Accountability Groups

Urban Development Unit in MLGRD

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 iv

Table of Contents

LIST OF ABREVIATIONS AND ACRONYMS ............................................................................................................................. II

EXECUTIVE SUMMARY ..................................................................................................................................................... VIII

1.0 INTRODUCTION ...................................................................................................................................................... - 1 -

1.1 BACKGROUND ................................................................................................................................................................ - 1 - 1.2 PURPOSE AND STUDY OBJECTIVES OF ESMF .............................................................................................................. - 3 -

2.0 OVERALL APPROACH AND METHODOLOGY FOR ESMF PREPARATION ................................................................... - 5 -

2.1 APPROACH .................................................................................................................................................................... - 5 - 2.2 METHODOLOGY ............................................................................................................................................................. - 6 -

3.0 DESCRIPTION OF WATER AND SANITATION PROJECT FOR GAMA ........................................................................... - 7 -

3.1 CONTEXT AND OBJECTIVES OF GAMA ............................................................................................................................... - 7 - 3.2 PROJECT COMPONENTS ................................................................................................................................................... - 8 -

3.2.1 Component 1 – Provision of Water and Sanitation Services ............................................................................- 8 - 3.2.2 Component 2 – Improvement and Expansion of Water Distribution Network ................................................- 9 - 3.2.3 Component 3 – Improvement and Expansion of Wastewater and Feacal Sludge Collection, Transportation and Treatment .......................................................................................................................................................................- 9 - 3.2.4 Component 4 - Institutional and Project Management Support ......................................................................- 9 -

4.0 RESULTS OF THE PUBLIC CONSULTATION PROCESS .............................................................................................. - 10 -

4.1 CONSULTATIONS WITH MMAS ....................................................................................................................................... - 10 - 4.2 CONSULTATIONS MINISTRIES DEPARTMENTS AND AGENCIES .................................................................................................. - 11 -

5.0 GAMA BASELINE PROFILE ..................................................................................................................................... - 12 -

5.1 BACKGROUND .............................................................................................................................................................. - 12 - 5.2 ADMINISTRATIVE STRUCTURE ................................................................................................................................. - 12 - 5.3 PHYSICAL CHARACTERISTICS ............................................................................................................................................ - 13 - 5.4 GEOLOGY AND CLIMATE ................................................................................................................................................. - 14 - 5.5 VEGETATION ................................................................................................................................................................ - 15 - 5.6 DRAINAGE ................................................................................................................................................................... - 17 - 5.7 AIR QUALITY ................................................................................................................................................................ - 20 - 5.8 DEMOGRAPHY .............................................................................................................................................................. - 21 -

6.0 POLICY, LEGAL, INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT ........................................ - 24 -

6.1 NATIONAL ENVIRONMENTAL REQUIREMENTS ..................................................................................................................... - 24 - 6.1.1 Ghana’s Environmental Policy........................................................................................................................- 24 - 6.1.2 National Water Policy ....................................................................................................................................- 24 - 6.1.3 Environmental Sanitation Policy ....................................................................................................................- 25 - 6.1.4 The Environmental Protection Agency Act .....................................................................................................- 26 - 6.1.5 EA Regulations and Procedures .....................................................................................................................- 27 - 6.1.6 EA (Amendment) Regulations, 2002 ..............................................................................................................- 27 - 6.1.7 Local Government Act, 1993 (Act 462) ..........................................................................................................- 27 -

6.2 NATIONAL LABOUR, SAFETY AND HEALTH REQUIREMENTS ................................................................................................... - 28 - 6.2.1 Factories, Offices and Shops Act ....................................................................................................................- 28 - 6.2.2 Occupational Safety and Health Policy of Ghana (Draft) ...............................................................................- 28 - 6.2.3 National Workplace HIV/AIDS Policy .............................................................................................................- 28 - 6.2.4 Labour Act ......................................................................................................................................................- 28 -

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 v

6.3 THE GHANA SHARED GROWTH AND DEVELOPMENT AGENDA (GSGDA) ................................................................................. - 28 - 6.4 THE POVERTY REDUCTION STRATEGY OF GHANA ................................................................................................................ - 29 -

6.4.1 GPRS I and II ...................................................................................................................................................- 29 - 6.5 THE WORLD BANK REQUIREMENTS .................................................................................................................................. - 29 -

6.5.1 The Bank’s Safeguard Policies ........................................................................................................................- 29 - 6.5.2 Triggered Safeguard Policies ..........................................................................................................................- 32 -

6.6 ENVIRONMENTAL SANITATION POLICY .............................................................................................................................. - 32 - 6.6.1 Solid Waste Management ..............................................................................................................................- 32 -

6.7 INTERNATIONAL CONVENTIONS ....................................................................................................................................... - 33 - 6.8 INSTITUTIONAL FRAMEWORK .......................................................................................................................................... - 33 -

6.8.1 Ministry of Environment, Science and Technology ........................................................................................- 33 - 6.8.2 Ministry of Local Government and Rural Development .................................................................................- 34 - 6.8.3 Ministry of Water Resources Works and Housing ..........................................................................................- 34 - 6.8.4 Ministry of Finance and Economic Planning ..................................................................................................- 35 - 6.8.5 Ministry of Roads and Highways ....................................................................................................................- 35 -

7.0 POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE GAMA PROJECTS AND MITIGATION ....................... - 36 -

7.1 POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS............................................................................................................... - 37 - 7.1.1 Maternal Mortality: .......................................................................................................................................- 38 - 7.1.2 Other Diseases: ..............................................................................................................................................- 38 - 7.1.3 Environmental Sustainability: ........................................................................................................................- 38 - 7.1.4 Improvement of the living conditions ............................................................................................................- 38 - 7.1.5 Water Supply Project .....................................................................................................................................- 39 - 7.1.6 Excreta and Wastewater Services ..................................................................................................................- 40 - 7.1.7 Economic Benefits to MMAs ..........................................................................................................................- 40 - 7.1.8 Enhanced Institutional Capacity to Support Decentralization .......................................................................- 41 - 7.1.9 Conclusion ......................................................................................................................................................- 41 -

7.2 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS, ................................................................. - 42 - 7.2.1 Environmental Impact Assessment ................................................................................................................- 42 - 7.2.2 Operational Phase Impacts ............................................................................................................................- 43 - 7.2.3 Social Impacts ................................................................................................................................................- 47 -

7.3 MITIGATION MEASURES ................................................................................................................................................ - 48 - 7.3.1 Construction Phase Impacts ..........................................................................................................................- 48 - 7.3.2 Post Constructional Phase impacts ...............................................................................................................- 50 -

7.4 INTEGRATION OF THE EMP ...................................................................................................................................... - 55 - 7.4.1 Environmental Management ..........................................................................................................................- 55 - 7.4.2 Objectives of Program ...................................................................................................................................- 55 - 7.4.3 Resources for Programme Implementation....................................................................................................- 56 -

7.5 MONITORING ............................................................................................................................................................ - 58 - 7.5.1 Construction Phase ........................................................................................................................................- 58 - 7.5.2 Operation and Maintenance Phase ................................................................................................................- 59 -

8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) ................................................................. - 60 -

8.1 THE ENVIRONMENTAL AND SOCIAL SCREENING PROCESS ...................................................................................... - 60 - 8.1.1 The Screening Process ...................................................................................................................................- 61 - 8.1.2 Responsibilities for the Implementation of the Screening Process ................................................................- 72 -

8.2 MITIGATION MEASURES ................................................................................................................................................ - 73 - 8.2.1 General mitigation measures .........................................................................................................................- 73 - 8.2.2 Specific construction impacts mitigation measures .......................................................................................- 74 -

8.3 MONITORING PLAN ...................................................................................................................................................... - 76 - 8.4 RESPONSIBILITY AND INSTITUTIONAL ARRANGEMENT FOR IMPLEMENTATION AND MONITORING ................................. - 78 -

8.4.1 Institutions responsible for implementation ................................................................................................- 78 - 8.4.2 Project Institutional and Implementation Arrangements ..............................................................................- 79 -

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 vi

8.5 CAPACITY STRENGTHENING FOR ESMP IMPLEMENTATION ................................................................................................... - 82 - 8.5.1 Capacity Building Program and Awareness ...................................................................................................- 83 - 8.5.2 Technical strengthen measures .....................................................................................................................- 83 -

8.6 ESMF IMPLEMENTATION SCHEDULE ................................................................................................................................ - 84 - 8.7 ESTIMATED BUDGET ..................................................................................................................................................... - 84 - 8.8 ESMF/ ESMP DISSEMINATION AND PUBLIC DISCLOSURE ..................................................................................................... - 86 -

9.0 REFERENCES ......................................................................................................................................................... - 92 -

10.0 ANNEXES .......................................................................................................................................................... - 93 -

ANNEX 1A: ENVIRONMENTAL AND SOCIAL SCREENING (ESS) OF SUB-PROJECTS ............................................................. - 93 - ANNEX 1B: STANDARD FORMAT FOR SCREENING REPORT ................................................................................................ - 95 - ANNEX 1C: SCREENING REPORT-ENVIRONMENTAL AND SOCIAL CHECKLIST .................................................................... - 98 - ANNEX 2: STANDARD FORMAT FOR ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) .................................. - 99 - ANNEX 3: GUIDANCE ON ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN BY PROJECT PHASES ................................. - 100 - ANNEX 4: DRAFT TERMS OF REFERENCE FOR SUB-PROJECT REQUIRING AN ESIA ......................................................... - 103 - ANNEX 5: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS .......................... - 105 - ANNEX 6: SUMMARY OF WORLD BANK SAFEGUARD POLICIES AND HOW THEY WILL APPLY TO THE FUTURE PROJECT ACTIVITIES ............. - 113 - ANNEX 7: LIST OF INDIVIDUALS/INSTITUTIONS CONTACTED ........................................................................................... - 115 - ANNEX 8: TERMS OF REFERENCE FOR GAMA ESMF .................................................................................................................. - 117 -

LIST OF TABLES

TABLE 5-1: DEMOGRAPHIC FIGURES OF AMA BY SUB-METROS .......................................................................................................... - 21 - TABLE 5-2: POPULATION AND POPULATION GROWTH RATE ................................................................................................................ - 22 - TABLE 5-3: POPULATION PROJECT OF AMA BY SUB-METROS ............................................................................................................. - 22 - TABLE 5-4: PROJECTED POPULATION DENSITY PER HECTRE ................................................................................................................. - 23 - TABLE 7-1: STATUS OF SAFEGUARD WORK ...................................................................................................................................... - 36 - TABLE 8-1: STRUCTURES INVOLVED IN THE GAMA ENVIRONMENT AND SOCIAL MANAGEMENT ................................................................ - 61 - TABLE 8-2: CATEGORY OF ENVIRONMENTAL STUDIES ........................................................................................................................ - 66 - TABLE 8-3: PROCEDURES FOR EIA ................................................................................................................................................. - 67 - TABLE 8-4: PROCESS MONITORING INDICATORS OF ESMP MEASURES ................................................................................................. - 70 - TABLE 8-5: INDICATORS AND MONITORING MECHANISM OF ENVIRONMENTAL AND SOCIAL ISSUES ............................................................ - 71 - TABLE 8-6: SUMMARIZED ENVIRONMENTAL SCREENING PROCESS AND RESPONSIBILITIES ......................................................................... - 72 - TABLE 8-7: GENERAL MITIGATION MEASURES ................................................................................................................................. - 73 - TABLE 8-8: SUMMARY OF ENVIRONMENTAL MITIGATION MEASURES ................................................................................................... - 74 - TABLE 8-9: RESULTS AND INDICATORS FOR THE SANITATION AND WATER SECTOR .................................................................................. - 77 - TABLE 8-10: INSTITUTIONS RESPONSIBLE FOR IMPLEMENTATION OF ESMP ........................................................................................... - 78 - TABLE 8-11: INSTITUTIONAL ARRANGEMENTS FOR ESMP IMPLEMENTATION ......................................................................................... - 81 - TABLE 8-12: TRAINING SCHEDULE ................................................................................................................................................. - 83 - TABLE 8-13: TIME TABLE FOR IMPLEMENTATION AND MONITORING OF ENVIRONMENTAL ACTIVITIES ........................................................ - 84 - TABLE 8-14: ESTIMATED COSTS OF TECHNICAL MEASURES ................................................................................................................. - 85 - TABLE 8-15: TRAINING AND AWARENESS MEASURES COSTS ............................................................................................................... - 85 - TABLE 8-16: SUMMARIZED ESTIMATED BUDGET FOR ENVIRONMENTAL AND SOCIAL IMPACT MANAGEMENT ............................................... - 86 - TABLE 8-17: ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ....................................................................................................... - 87 - TABLE 10-1: ENVIRONMENTAL AND SOCIAL CHECKLIST ...................................................................................................................... - 98 - TABLE 10-2: GUIDANCE ON ESMP BY PROJECT PHASES .................................................................................................................. - 100 -

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 vii

LIST OF FIGURES

FIGURE 5-1 : MAP OF GREATER ACCRA AREA .................................................................................................................................. - 12 - FIGURE 5-2: MAP OF GREATER ACCRA AREA ................................................................................................................................... - 14 - FIGURE 8-1: ESMP IMPLEMENTATION ARRANGEMENT ..................................................................................................................... - 82 -

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 viii

EXECUTIVE SUMMARY

INTRODUCTION

The Ministry of Local Government and Rural Development (MLGRD), with support from the World Bank, is

currently preparing a Sanitation & Water Project for the Greater Accra Metropolitan Area (GAMA). The

proposed project may be structured as a two-phase Adaptable Program Loan (APL) or as a Specific Investment

Loan (SIL) that would be followed by other operations, given the long term engagement required to increase

access to sanitation and water services in low income areas of GAMA and to attain an efficient and sustainable

operation and management of the services.

PPROJECT OBJECTIVES

The objective of the project is to increase access to safe water and improved sanitation to people in the GAMA,

with emphasis on low income communities, and to improve operation and management of wastewater facilities.

In order to achieve this objective, the project would support the expansion and improvement of the water

distribution network, the expansion of community water points and private water connections, the development of

on-site and sewered sanitation facilities and the improved collection and treatment of wastewater and faecal

sludge. Behaviour Change Campaign on hygiene, sanitation and safe water will also be promoted through social

mobilization activities, as well as social accountability to ensure the sustainability of the facilities and services.

The proposed project will therefore focus on providing low income communities located in the 11MMAs with

increased water supply and improved sanitation services. The beneficiary MMAs are Accra Metropolitan

Assembly, Tema Metropolitan Assembly,La Dade-Kotopon Municipal Assemby, Adenta Municipal Assembly,

Ga South Municipal Assembly, Ga Central Municipal Assembly, Ga West Municipal Assembly, Ga East

Municipal Assembly, La Nkwanta Municipal Assembly, Ledzokuku Krowor (Teshine Nungua( Municipal

Assembly and Ashaiman Municipal Assembly.

The proposed project weather the first phase of an APL or a SIL APL would have the following four components:

Component 1 - Provision of water and environmental sanitation services to priority low income

areas of the GAMA.

Component 2 – Improvement and expansion of the water distribution network in the GAMA .

Component 3 – Improvement and expansion of wastewater and fecal sludge collection,

transportation and treatment in the GAMA

Component 4 – Institutional Strengthening.

Description of Prospective Projects under Components 1, 2 and 3

Under Component 1, 2 and 3, the World Bank is funding proposed Sanitation and Water Projects located in the 11

MMAs to increase water supply and improved sanitation services. The Table 7.1 below presents a non-exhaustive

the list of some of the likely investments and the safeguards status (Please note that this list is not

comprehensive).

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 ix

Table ES-1: Status of Safeguard Work

Component 1 :

Provision of water

and environnemental

sanitation services to

priority income areas

of the GAMA

Location

Implementation

Status of Safeguard Work (OP 4.01 and OP 4.12)

EIA RPF RAP

MMAs Construction To be done if

required

Done To be done if required

MMAs Rehabilitation To be done if

required


LIST OF POTENTIAL SUB-PROJECTS

Water supply and sanitation facilities for communities

Water Supply and sanitation facilities for households

Water supply and sanitation facilities for schools, health centrers and in public areas such as markets

Engagement of community and particularly women to provide oversight of water and sanitation services such as

Water and Sanitation Development Board (WSDBs)

Construction of water supply system;

Drilling of boreholes;

Mechanization of boreholes;

Construction of KVIPs;

Construction of water closet seaters;

Rehabilitation of public toilet;

Construction and lining of drains;

Component 2 :

Improvement and

expansion of the

water distribution

network in the

GAMA

Location

Implementation


EIA RPF RAP


required



required



Investments to improve and expand the existing network to provide piped water to the targeted people living in low

income communities in the GAMA

Installation of transmission mains, boster pumps and other facilities

Support acquisition and installation of meters and other equipment as well as provision of services aimed at

improving water demand management

Component 3 :

Improvement and

expansion of

wastewater and fecal

sludge collection,

transportation and

treatment in the

GAMA

Location

Implementation


EIA RPF RAP


required



required



Collection and/or treatment of wastewater and fecal sludge to be generated from the low income communities and

rest of GAMA

Improve the safe collection, transport and treatment of fecal sludge

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 x

ENVIRONMENTAL AND SOCIAL ISSUES RELEVANT TO THE PROJECT

The potential environmental and social impacts of these investments are not currently known, even though they

are likely to be significant. Since the exact location, nature and number of sanitation and water facilities and/or

services are not known, MLGRD is required to prepare an Environmental and Social Management Framework

(ESMF) to ensure that all investments are adequately screened for their potential environmental and social

impacts, and that correct procedures to be followed, depending on the types of investments to be carried out, and

these will be reflected in the ESMF document.

In pursuant to the requirements of the World Bank, including OP / BP 4.01, an ESMF is prepared by the

Government of Ghana (GoG) as a requirement for the implementation of the GAMA. Furthermore, the World

Bank requires that the description of measures taken by the GoG represented by the Ministry of Local

Government and Rural Development (MLGRD) (the Borrower) to address the safeguard policy issues and

undertake an assessment of MMAs and MLGRD’s capacity to plan and implement the measures proposed to be

addressed in the ESMF.

PURPOSE AND STUDY OBJECTIVES OF ESMF

The objective of the assignment is to prepare an ESMF which will:

Establish the legal framework, procedures, and methods for the environmental and social planning,

review, approval and implementation investments to be financed using the performance grant funds;

Identify roles and responsibilities, including reporting procedures and monitoring and evaluation;

Identify capacity and/or training needs for different stakeholders to ensure better implementation of the

provisions in the ESMF and;

Identify funding requirements and resources to ensure effective implementation of the framework.

METHODOLOGY

The ESMF study has been prepared in accordance with applicable World Bank safeguard policies and Ghana

environmental assessment guidelines. The distinct phases of the study include:

Data Gathering;

Consultations and discussions with MLGRD, MWRWH, GAMA, MMAs, EPA and NGOs;

Literature review;

Environmental screening and scoping;

Determination of potential impacts;

Identification of impact mitigation measures;

Preparation of an Environmental and Social Management Plan; and

Preparation of sub-project guidelines.

GAMA BASELINE PROFILE

As shown in the maps, the city of Accra actually covers AMA, as well as parts of Ga West, Ga South, Ga East,

Tema Metropolitan Area (TMA), Ashaiman and Adenta.

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xi

The report of the fifth round of the Ghana Living Standards Survey (GSS, 2008), defines the Accra Metropolitan

Area (AMA), Tema Municipal Area (TMA) (which at that time also covered Ashaiman and Adenta municipality),

and the urban areas in Ga East and Ga West (which at that time included Ga South) Districts as the Greater Accra

Metropolitan Area (GAMA). The GAMA area covers a total area of about 1,261 km2 (Twum, 2002).

Demographic Characteristics

The 2010 estimated population of Accra, pending the result of the 2010 PHC, is about 4.3 million with additional

daily influx population of 1 million who commute to the City for various socio-economic activities, which most

often are nonexistent thereby resorting to social vices and economic crimes.

POLICY, LEGAL, INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT

The environmental policy and EA legislation and procedures of Ghana and those of the World Bank, which are

relevant to the Project, are outlined. In principle the two sets of policies and procedures on environmental and

social assessment are similar in many respects.

NATIONAL ENVIRONMENTAL REQUIREMENTS

Ghana’s Environmental Policy

The environmental policy of Ghana formulated in the National Environmental Action Plan (NEAP) of 1993

hinges strongly on ‘prevention’ as the most effective tool for environmental protection. The policy aims at a

sound management of resources and environment, and the reconciliation between economic planning and

environmental resources utilization for sustainable national development. It also seeks among others, to institute

an environmental quality control and sustainable development programs by requiring prior EA of all

developments, and to take appropriate measures to protect critical eco-systems, including the flora and fauna they

contain against harmful effects, nuisance or destructive practices. The adoption of the NEAP led to the enactment

of the EPA Act 1994 (Act 490); and subsequently the passing of the Ghana EIA Procedures into the EA

Regulations, 1999 (LI 1652).

National Water Policy

Consistent with the GPRS, the overall goal of the National Water Policy is to "achieve sustainable development,

management and use of Ghana's water resources to improve health and livelihoods, reduce vulnerability while

assuring good governance for present and future generations". This will be achieved by addressing relevant issues

under water resources management, urban water supply and community water and sanitation. For each broad area,

a number of focus areas for policy considerations have been identified. Within each the main principles and

challenges are listed followed by policy objectives and the corresponding measures.

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xii

Environmental Sanitation Policy

The Environmental Sanitation Policy (Revised, 2010) responds to the various reviews carried out to assess how

effectively the previous policy published in 1999 has been implemented. The revised policy objectives and

measures are presented in a way that enhances strategic planning and subsequent implementation.

The Environmental Protection Agency Act

The Environmental Protection Agency (EPA) Act, 1994 (Act 490) grants the Agency enforcement and standards

setting powers, and the power to ensure compliance with the Ghana EA requirements/procedures. Additionally,

the Agency is required to create environmental awareness and build environmental capacity as relates all sectors,

among others. The Agency (including its Regional and District Offices) is also vested with the power to

determine what constitutes an ‘adverse effect on the environment’ or an activity posing ‘a serious threat to the

environment or public health’, to require EAs, EMPs, Annual Environmental Reports (AERs), etc of an

‘undertaking’, to regulate and serve an enforcement notice for any offending or non-complying undertaking.

The Agency is required to conduct monitoring to verify compliance with given approval/permit conditions,

required environmental standard and mitigation commitments. Furthermore, a requirement by EPA for an EA

precludes any authorising MDA from licensing, permitting, approving or consenting such undertaking, unless

notified otherwise.

EA Regulations and Procedures

The EA Regulations combine both assessment and environmental management systems. The regulations prohibit

commencing an undertaking/activity without prior registration and environmental permit (EP). Undertakings are

grouped into schedules for ease of screening and registration and for EP. The schedules include undertakings

requiring registration and EP (Schedule 1), EIA mandatory undertakings (Schedule 2), as well as Schedule 5-

relevant undertakings (located in Environmentally Sensitive Areas).

The Regulations also define the relevant stages and actions, including: registration, screening, preliminary

environmental assessment (PEA), scoping and terms of reference (ToR), environmental impact assessment (EIA),

review of EA reports, public notices and hearings, environmental permitting and certification, fees payment,

EMP, Annual Environmental Report (AER), suspension/revocation of permit, complaints/appeals, etc.

Local Government Act, 1993 (Act 462)

The Local Government Act (Act 462) seeks to give a fresh legal expression to government’s commitment to the

concept of decentralization. It is a practical demonstration of a bold attempt to bring the process of governance to

the doorstep of the populace at the Regional and more importantly, the District level. The Metropolitan,

Municipal and District Assemblies (MMDAs) created under the law, constitute the highest political authority in

each district, municipality and metropolis.

Other relevant legislative, regulative and administrative regimes considered are:

The Factories, Offices and Shops Act of 1970 (Act 328);

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xiii

Occupational Safety and Health Policy

National Workplace HIV/AIDS Policy;

Labour Act, 2003 (Act 651);

Ghana Shared Growth and Development Agenda (2010-2013);

Ghana Poverty Reduction Strategy (GPRS I & II);

World Bank Safeguards Policies

Ghana Environmental Sanitation Policy;

Relevant International Conventions and Protocols; and

Institutional Framework.

POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE GAMA PROJECTS AND MITIGATION


Under Component 1,2 and 3, the World Bank is funding this proposed Sanitation and Water Project that aims

at increasing access to improved sanitation and safe water in the GAMA, with particular emphasis on low

income areas. The GoG is seeking support from the WBG given its experience with the implementation of

water and environmental sanitation projects in Ghana and in dealing with low income areas and institutional

aspects. The proposed project will therefore focus on providing low income communities located in the 8

MMAs with increased water supply and improved sanitation services. The Table ES.1above presents the list of

some of the likely investments and the safeguards status (Please note that this list is not comprehensive).

POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS

POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS

The overall environmental impact of the project is expected to be positive. Significant positive impacts to the

natural and socioeconomic environments will be achieved by the participating MMAs. By developing

infrastructure, the capacity of the MMAs to deliver quality services will be improved.

The positive environmental and social impacts for Water and Sanitation include information relevant to the

construction, operation and maintenance of (i) potable water treatment and distribution systems, and (ii) collection

of sewage in centralized systems (such as piped sewer collection networks) or decentralized systems (such as

septic tanks subsequently serviced by pump trucks) and treatment of collected sewage at centralized facilities. Key

expected positive results or outcomes are as follows:

Improved Conservation and Preservation of Water

Sustainable Water Supply

Reduced vulnerability of ecosystem to climatic events

Improved use of Water and Sanitation

Sustainable water supply


Increase Employment

Improved conditions for economic growth

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xiv

General economic growth

Poverty reduction

Increased affordability of water and sanitation

Increased access to water

Reduced rate of water related diseases

Improved social development

Improved health

Poverty reduction

Greater equity in allocation of water and sanitation

Increased access to basic sanitation



Improved health

Improved quality of water and sanitation



Improved health

Improved water and sanitation , health and hygiene behaviour

The Sanitation and Water Facilities Project in the GAMA will result in:

Generic improvement within the Metropolis and Municipalities for water and sanitation projects:

Improvement in the hygienic conditions and public health

There will be an improvement in the environment, and hygienic conditions of the city due to provision of

efficient water and sanitation facilities. The prevailing trends of morbidity and mortality are likely to

change. The present health statuses of these communities are characterized by high morbidity rate from

occasional outbreak of preventable and infectious diseases like cholera and typhoid fever. High

occurrence of Malaria is also prevalent as a result of poor drainage facilities and the malaria, which is

endemic, will be reduced as a result of the drainage to be provided.

Employment generation

There will be employment generation for unskilled labourers during the construction stage of various

Sanitation and Water facilities. Thus the project has the potential to contribute to economy through labour

absorption and the supply of construction materials.

Improve access to basic water and sanitation services

There will be an access to basic services like water supply as these will be supplied and be connected.

Gender-Status of Women

The provision of the water and sanitation facilities is expected to enhance the lot of women in the project

areas. Apart from those who will be employed directly on the project, others will be engaged in trading at

the construction sites supplying the workforce with food and other consumables. Although the numbers

will not be disproportionately high a vibrant and booming trade for the women implies an improvement in

living standards of the people.

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xv

IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS,

The proposed Sanitation and Water works will have an impact on the environment. The potential impacts of the

development are both adverse and beneficial. An assessment of the negative impacts can be classified into

construction phase and post-construction phase impacts.

Environmental Impact Assessment

Constructional Phase Impacts

The constructional works would present negative environmental impacts. The construction phase includes the

following operations: site clearing, excavation and grading, upgrading of drains, installation of utility services

(electricity and water supply). These activities will have direct impact on the environment. Some of the negative

impacts are:

Soil and Land Degradation

Air Quality

Vehicular Traffic Implication

Noise Levels and Ground Vibration

Constructional Wastes Generation

Occupational Health and Safety

Operational Phase Impacts

Water Withdrawal Impact

Water Treatment

Environmental issues associated with water treatment include:

Solid waste generation

Wastewater generation

Hazardous chemicals

Air emissions

Water Quality

Water system leaks and loss of pressure

Water discharges

Sanitation

Fecal Sludge and Septage Collection

Sewerage treatment and disposal The most significant potential environmental impacts associated with wastewater collection arise from:

Domestic wastewater discharges

Industrial wastewater discharges

Leaks and overflows

Wastewater and Sludge Treatment and Discharge

The most significant environmental impacts related to wastewater and sludge treatment, discharge, and use

include:

Liquid effluents

Solid waste

Air emissions and odors

Hazardous chemicals

Ecological impacts

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xvi

Social Impacts The Potential Negative Impacts

Disruption of Utility Services

Dumping of solid waste and rubbish into the drains

Accidents

Inconvenience to be caused due to delays in payment

Restricted Access to Source of Livelihood

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

During the implementation of Sanitation and Water Project activities in the GAMA , potential environmental and

social impacts must be considered and managed. The impacts must be mitigated, minimized or preferably avoided

particularly to meet the requirements of World Bank safeguards policies and Ghana national law requirements.

The objective of the ESMF is to outline the institutional arrangements relating to: (i) identification of

environmental and social impacts arising from activities under the GAMA projects, (ii) the implementation of

proposed mitigation measures, (iii) Capacity Building and (iv) Monitoring.

The ESMP will be included in a manual of Operations. The ESMF outlines mechanisms for:

Screening of proposed sub-projects, identifying potential environmental and social impacts and

management of safeguard policies implications;

Institutional arrangements for implementation and capacity building

Monitoring ESMF measures implementation;

Public consultation;

The estimated costs related to the ESMF.

ESMF Implementation Arrangement

MLGRD is the lead implementing agency for the GAMA. The Project Coordinating Unit (PCU) of the Ministry

of Local Government and Rural Development is the entity designated by MLGRD to manage the project. PCU

will also supervise the implementation of the ESMF by the MMAs. The Municipal/Metropolitan Planning and

Coordination Committees (MMPCUs) (and directly the Planning Officer) of the MMAs will execute the

provisions of the ESMF on the ground.

The Ministry of Local Government and Rural Development (MLGRD) will recruit an Environmental and Social

Officer (ESO). The ESO’s main task is ensure that MMA comply with environmental and social safeguards

requirements, including reviewing screening documents from MMAs, reviewing, overseeing, and participating in

EIA reviews and implementation, monitoring activities of mitigation measures implementation and act as the

interlocutor of the GAMA, MLGRD and MMAs (MMPCUs). MLGRD will also disseminate and disclose the

ESMF/EMP and any EIA.

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xvii

Responsibilities for the Implementation of the Screening Process

The ESMF will be implemented by MLGRD. MLGRD will collaborate with the EPA and the World Bank to

ensure effective execution. Table ES.2 provides a summary of the stages and institutional responsibilities for the

screening, preparation, assessment, approval and implementation of the GAMA activities.

The extent of environmental assessment that might be required prior to the commencement of the sub-projects

will depend on the outcome of the screening process. The key stages of the environmental and social screening

process leading to the review and approval of the GAMA activities to be implemented are described below:

Table ES.2: Summarised Environmental Screening Process and Responsibilities

Stage Management

responsibility

Implementation responsibility

1. Screening Environmental and Social Sanitation and

Water Project: Selection including public consultation

MLGRD/MMAs MMPCU Planning Officer1

2. Determination of appropriate environmental

categories

2.1 Selection validation

MMPCU, Planning Officer

2.2 Classification of Project

Determination of Environmental Work

Review of screening

MLGRD/MMAs

EPA, MMPCU and Planning

Officer

3. Implementation of environmental work MLGRD/MMAs MMPCU and Planning Officer

in the MMAs,

3-1. If EIA is necessary MMPCU

3.1.a Preparation of terms of reference MLGRD/MMA

MMPCU

3.1 b Selection of Consultant MLGRD MMA

3.1 c

Realization of the EIA, Public Consultation

Integration of environmental and social management

plan issues in the tendering and project implementation,

MMPCU/MLGRD

Procurement and

Works Department

Units of MMAs/

MLGRD

Environmental Consultant

MMPCU and Planning Officer

4 Review and Approval

4.1 EIA Approval EPA EPA, , World Bank

5. Public Consultation and disclosure MLGRD/EPA


6. monitoring /MMAs/EPA


7 Development of monitoring indicators for EIA as

may be stipulated under tbe environmental

permitting conditions.

MLGRD MMPCU and Planning Officer

1 If necessary, the MPCU can assign a designated, capable officer to carry out the screening process if MPCU sees that need.

However, the planning officer will still be the final signatory to the screening format.

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xviii

MONITORING PLAN

Oversight for the environmental and social management process of the sub-projects will be assured by the

Planning Officers (POs) and the Environmental Health Officers (EHOs) in collaboration with the MLGRD.

Monitoring will be conducted during all phases of the project. The monitoring plan does not restrain MPCUs to

take up their normal monitoring role at MMA level, including in areas of environment protection.

There will be two tracks for oversight and management of safeguards in sub projects. The screening process at

MMA level will take place as part of the annual planning and budgeting process. Any sub project under the Urban

Development Grant will be subject to screening led by Planning Officer and submitted to review for the

Development Planning Subcommittee. If any sub project is triggering safeguards, the MMA will inform the ESO,

submit the necessary documentation, and initiate preparation of the necessary mitigation measures.

The ESO at MLGRD will prepare a long term monitoring strategy that will encompass clear and definitive

parameters to be monitored for each sub-project that triggers the preparation of ESMP. The monitoring plan will

take into consideration the scope of development, the environmental and social sensitivity and the financial and

technical means available for monitoring. The plan will identify and describe the indicators to be used, the

frequency of monitoring and the standard (baseline) against which the indicators will be measured for compliance

with the ESMF. A number of indicators (see Table ES.3) would be used in order to determine the status of the

compliance of the ESMF provisions.

Table ES.3: Process monitoring indicators of ESMP Measures

Measures Intervention field Indicators

Technical

measures

(studies)

-Conducting Environmental Impact

Assessment (EIA and ESMP)

-Develop a health and safety plan

-Develop the TOR

-Number of ESIAs/ESMPs/ Health Safety Plans submitted

for each sub-project in a MMDA

-Number of study elaborated

Measures for

monitoring and

evaluating

projects

Perform monitoring and evaluation

ESMP (continuous monitoring, mid-

term and annual assessment)

-List of indicators identified for all sub-projects as may

stipulated under the environmental permitting conditions

-Number of monitoring missions for all sub-projects

-Number of monitoring reports submitted for all sub-

projects

Institutional

measures

Engage existing Environmental Units in

the MMAs

-Develop a TOR for the Environmental unit

-Environmental Units are functional in MMAs

Awareness and structured Training for

staff of MLGRD and MMAs working

on the GAMA

-Number of EA trainings conducted for staffs in MMAs

-number of attendance (male/female) at EA trainings

-Number of awareness trainings conducted before, during

and after project implementation in each MMA

-Number of staff tin attendance at the awareness trainings

(Male/Female)

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xix


Awareness

Awareness about HIV / AIDS

Communication campaign and

awareness before, during and after

construction

-Number of sub-project sites with adequate posters

CAPACITY STRENGTHENING FOR ESMF IMPLEMENTATION

In order for the MMAs to effectively carry out the environmental and social management responsibilities for sub-

project implementation, institutional strengthening will be required. Capacity building will encompass MLGRD,

and MMA staff.MLGRD should therefore ensure that the following concerns and needs are addressed:

Institutional structuring within the relevant departments to ensure that required professional and other

technical staff are available;

To successfully implement this ESMF, training programmes for MLGRD and MMAs is necessary. The World

Bank, MLGRD and EPA can take up the responsibility for the training. Proposed capacity building training needs

are as follows:

- Environmental and Social Management Process.

- Use of Screening form and Checklist

- Preparation of terms of reference for carrying out EA

- Design of appropriate mitigation measures.

- Review and approval of EA reports

- Public consultations in the ESMF/ESIA process.

- Monitoring mitigation measures implementation.

- Integrating ESMP into sub-projects implementation.

The proposed capacity building program will be carried out annually during the project.

ESTIMATED BUDGET FOR ESMF

The budget needed for ESMP / GAMA environmental and social management is the recapitulation of the

following:

- Institutional development activities

- Training program, awareness

- Allowances for the preparation / implementation of sub-projects EIA / EMP/RAPs. (The costs of

implementing such plans measures are included in the budgets of sub-projects.)

- Annual assessments.

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xx

The costs of environmental measures as well as training and awareness are summarized in tables ES.4, ES.5 and

ES.6 below. Under the GAMA Category A and B project will require the preparation of of EIAs.

Table ES.4: Estimated costs of technical measures

Activity Quantity Unit cost

($US)

Total cost

($US)

EIA / RAP development at MMA level and to be integrated

into projects budget

To be

determined

later at

MMA

To be

determined

later at

MMA

To be

determined

later at MMA

Supervision and permanent monitoring at MMAs level by

MPCUs, Planning officers Quarterly

Normal

MMA

Budget

Normal

MMA

Budget

Table ES.5: Training and awareness measures costs

Actors involved Topics Quantity Unit cost

($US)

Total cost

($US)

Training

MMAs

(Training of

members of

MMPCU at

MMA level,

including

planning officer,

and other

designated

officers

(This training

will be done by

the World Bank

in collaboration

with MLGRD

and EPA)

- Training on Environmental and Social

Assessment (screening and

classification of activities,

identification of impacts, mitigation

options and indicators)

- Involuntary Resettlement Issues

- Drafting ToR for EIA

- Selection of mitigation measures in the

checklists

- Legislation and national environmental

procedures

- Safeguard Policy World Bank

- Impact of sub-projects and mitigation

measures

- Environmental measures monitoring

- health and safety standards monitoring

Safety and hygiene at work and operation

2

workshops

per year

Y1-Y5 of

the project

covering all

11 MMAs

7,000 70,000

Awareness

- Commuities

- Local

associations

and NGOs

- Reps of

construction

companies

- Public awareness and advocacy on

projects environmental and social

issues, good environmental practices,

good conduct in the yards, respect for

hygiene and safety, compliance with

development standards

- Awareness Campaign HIV / AIDS

2

Normal

MMA

Budget

Normal

MMA

Budget

TOTAL 70,000

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 xxi

Table ES.6: Summarized estimated budget for Environmental and Social Impact Management

Measures Actions Responsible Costs USD

Institutional

measures

Recruitment of ESO at MLGRD Level

MLGRD

Technical

measures

Perform ESMP monitoring and evaluation (continuous

monitoring, mid-term and annual assessment)

EIAs / RAP development

Health and safety Plans development

Supervision and Monitoring

MMA

MLGRD

Covered by

normal MMA

Budgets

Covered by

ESO

Monitoring and

Evaluation

Budget

Training

Training of MMA staff in projects environmental and social

management and monitoring and enforcement of

environmental measures

MLGRD

Covered under

training above

Awareness - Information and awareness campaigns on the nature of

work, environmental and social issues

- Awareness on HIV / AIDS

MMA

Normal MMA

Budget

TOTAL

DRAFT ESMF of Water & Sanitation Project for GAMA, MLGRD, Ghana,, December, 2012 - 1 -

1.0 INTRODUCTION

1.1 BACKGROUND

The Ministry of Local Government and Rural Development (MLGRD), with support from the World Bank, is

currently preparing a Sanitation & Water Project for the Greater Accra Metropolitan Area (GAMA). The

proposed project may be structured as a two-phase Adaptable Program Loan (APL) or as a Specific Investment

Loan (SIL) that would be followed by other operations, given the long term engagement required to increase

access to sanitation and water services in low income areas of GAMA and to attain an efficient and sustainable

operation and management of the services.

While Ghana compares favorably along most economic and development indicators with countries in the region,

it drops to the bottom of the list where access to improved sanitation is concerned. With regard to water, although

Ghana is expected to attain the MDG target, the reality is that service expansion cannot keep up with the high

population growth in urban areas, especially in the Greater Accra Metropolitan Area (GAMA). This particularly

affects people living in low income communities and especially women and children who are usually in charge of

fetching the water. The provision of water and sanitation services in a metropolitan area like GAMA presents an

additional institutional challenge. Whereas water services fall under the responsibility of the national Ghana

Water Company Ltd. (GWCL), the responsibility for sanitation services is divided among eight local governments

that generally lack the required operational and financial capacity and do not properly coordinate their actions.

The rapid growth of GAMA, both in terms of population and area, has generally taken place in the absence of

adequate planning and little attention to the development of basic services, particularly sanitation. This,

combined with a lack of capacity to operate and maintain the few existing wastewater facilities, has created

serious health and environmental consequences. The provision of water supply also requires urgent attention,

particularly to reach people in low income communities who must rely on private vendors and pay significantly

more for water than those with access to the utility network.

Increasing access to safe water supply and improved sanitation is a priority for the GoG that is embedded in the

National Water Policy (2007) and in the recently revised Environmental Sanitation Policy (2010). It also

underpins the principles enunciated in the 2000-2005 Ghana Poverty Reduction Strategy (GPRS), the 2006-2009

GPRS-II, the 2010-2013 national Ghana Shared Growth Development Framework (GSGDF), the Millennium

Development Goals, and the “Africa Water Vision” of the New Partnership for Africa’s Development. In

addition, the commitment of the GoG has been affirmed by the signing of the 2010 SWA Compact.

This proposed Sanitation and Water Project aims at increasing access to improved sanitation and safe water in the

GAMA, with particular emphasis on low income areas. The GoG is seeking support from the WBG given its

experience with the implementation of water and environmental sanitation projects in Ghana and in dealing with

low income areas and institutional aspects. The proposed project will therefore focus on providing low income

communities located in the 11MMAs with increased water supply and improved sanitation services. The

experience to be gained from the design and implementation of this project, particularly in addressing the

technical and institutional challenges for the provision of services to low income areas, is expected to be

replicated in other urban areas by the GoG.


Improving sanitation is the top priority of the citizens of Accra, followed by drainage, solid waste and water,

according to a recent survey of 4,000 households. Sanitation is also a priority for local governments, which have

been preparing their District Environmental Sanitation Strategy and Action Plans (DESSAPs) and are now asking

for help to implement them.

1.2 PPROJECT OBJECTIVES

The objective of the project would be to increase access to safe water and improved sanitation to people in the

GAMA, with emphasis on low income communities, and to improve operation and management of wastewater

facilities. In order to achieve this objective, the project would support the expansion and improvement of the

water distribution network, the expansion of community water points and private water connections, the

development of on-site and sewered sanitation facilities and the improved collection and treatment of wastewater

and faecal sludge. Behaviour Change Campaign on hygiene, sanitation and safe water will also be promoted

through social mobilization activities, as well as social accountability to ensure the sustainability of the facilities

and services.

The proposed project weather the first phase of an APL or a SIL APL would have the following four components:

Component 1 - Provision of water and environmental sanitation services to priority low income areas of the

GAMA. The MMAs will propose the priority low income communities to benefit from the project based upon

selection criteria to be agreed during project appraisal. The type of water supply and sanitation facilities will be

thoroughly consulted and agreed with each community as to best suit their needs, while taking into consideration

particular conditions such as: soil characteristics, topography, space availability, etc.

In addition to facilities for households, this component will support the construction of institutional facilities in

schools, health centers and in public areas such as markets. This component will also provide support for

advocacy and other measures to help enforce current laws and regulations, such as the obligation of landlords to

provide sanitation facilities. Additionally, specific measures will be introduced to effectively engage communities

and particularly women in decisions relating to the delivery and oversight of water and sanitation services such as

Water and Sanitation Development Boards (WSDBs). This component will also support the establishment and

strengthening of social accountability mechanisms so citizens can report on the provision of services.

Component 2 – Improvement and expansion of the water distribution network in the GAMA . This component

will support investments required to improve and expand the existing network in order to provide piped water to

the target people living in low income communities in the GAMA. These investments include the installation of

transmission mains, booster pumps and any other facilities required to ensure that a share of the additional water

production reach the targeted low income areas. Therefore this component will be coordinated with current and

incoming projects supported by other development partners and private investors in the GAMA. This component

would also support the acquisition and installation of meters and other equipment, as well as the provision of

services, aimed at improving water demand management and reducing non-revenue water.

Component 3 – Improvement and expansion of wastewater and fecal sludge collection, transportation and

treatment in the GAMA This component will finance collection and/or treatment of wastewater and fecal sludge


to be generated from the low income communities and rest of GAMA. However, these facilities will be seized to

take care of the entire wastewater flows and sludge volumes generated in the GAMA, which currently end up

discharged untreated into drains and eventually into the sea. This component will also support the development of

solutions to improve the safe collection, transport and disposal of fecal sludge and solid waste.

Component 4 – Institutional Strengthening (USD 10 million). This component will provide technical assistance

(TA) to municipal, metropolitan and national institutions, including the promotion of private sector initiatives for

water and sanitation.

1.3 ENVIRONMENTAL AND SOCIAL ISSUES RELEVANT TO THE PROJECT

The potential environmental and social impacts of these investments are not currently known, even though they

are likely to be significant. Since the exact location, nature and number of sanitation and water facilities and/or

services are not known, MLGRD is required to prepare an Environmental and Social Management Framework

(ESMF) to ensure that all investments are adequately screened for their potential environmental and social

impacts, and that correct procedures to be followed, depending on the types of investments to be carried out, and

these will be reflected in the ESMF document.

In pursuant to the requirements of the World Bank, including OP / BP 4.01, an ESMF is prepared by the

Government of Ghana (GoG) as a requirement for the implementation of the GAMA. Furthermore, the World

Bank requires that the description of measures taken by the GoG represented by the Ministry of Local

Government and Rural Development (MLGRD) (the Borrower) to address the safeguard policy issues and

undertake an assessment of MMAs and MLGRD’s capacity to plan and implement the measures proposed to be

addressed in the ESMF.

1.2 PURPOSE AND STUDY OBJECTIVES OF ESMF

In World Bank-financed projects, a key goal is to enhance positive and sustainable environmental and social

outcomes of the project by minimizing and/or avoiding negative environmental and social impacts. Where

avoidance is not possible, an Environmental and Social Management Framework is developed which provides the

framework within which to address the issues. The objective of the assignment is to prepare an ESMF which will:

Establish the legal framework, procedures, and methods for the environmental and social planning,

review, approval and implementation investments to be financed using the performance grant funds;

Identify roles and responsibilities, including reporting procedures and monitoring and evaluation;

Identify capacity and/or training needs for different stakeholders to ensure better implementation of the


Identify funding requirements and resources to ensure effective implementation of the framework.

The EA Regulations of Ghana provide the general framework and procedures for EA and environmental

management (EM) of development actions. Most Development Partners (DPs) and funding institutions, including

the World Bank also have EA requirements. As part of funding arrangements for the GAMA, the World Bank’s

safeguards policies and national requirements must apply. The project has the following attributes (quite distinct

from project-specific level assessment):


Geographical coverage of 8 Metropolitan and Municipal Assemblies in the Greater Accra Metropolitan

Area (GAMA);

Implementation duration spread over 5years.

Involvement of several institutions at the national, regional, district and local levels;

Design of the sub-projects, types and numbers for implementation, and the specific project locations and

communities all not determined at this stage.

The ESMF spells out the World Bank safeguards policies, country’s institutional arrangements and capacity

required to implement the framework. This ensures that sub-projects meet the national and local E&S

requirements and are consistent with OP 4.01, OP 4.12, etc of the Bank. Other objectives of the ESMF include:

Assessment of potential adverse environmental and social impacts commonly associated with the listed

sub-projects and the way to avoid, minimize or mitigate them;

Establishment of clear procedures and methodologies for the environmental and social planning, review,

approval and implementation of sub-projects;

Development of an EA screening/initial assessment system to be used for sub-projects; and

Specification of roles and responsibilities and the necessary reporting procedures for managing and

monitoring sub-project environmental and social concerns.

Development of general environmental management conditions to be added to construction contracts.

The ESMF will be principally used by MMAs and other collaborators to ensure that adequate mitigation measures

and other environmental and social safeguards have been incorporated into the sub-projects to be implemented

under the GAMA.


2.0 OVERALL APPROACH AND METHODOLOGY FOR ESMF PREPARATION

2.1 APPROACH

The ESMF study has been prepared in accordance with applicable World Bank safeguard policies and Ghana

environmental assessment guidelines. The distinct phases of the study include:

Data Gathering;

Consultations and discussions with MLGRD, MWRWH, GAMA, MMAs, EPA and NGOs;

Literature review;

Environmental screening and scoping;

Determination of potential impacts;

Identification of impact mitigation measures;

Preparation of an Environmental and Social Management Plan; and

Preparation of sub-project guidelines.

Data Gathering

The ESMF Consultant assembled and evaluated relevant baseline data related to the biophysical and socio-

economic characteristics of the environment to be covered by the project. The baseline data reviewed included:

topography, soil, water resource, biological and socio-economic data.

- Consultations

During the assessment, consultations with key stakeholders such as impacted groups, local communities and non-

governmental organizations are being held from November-December 2012. Selected Project beneficiary MMAs

were also visited during the period. (see Annex 7)

Literature Review

The ESMF preparation involved document review. The GoG and the World Bank reference documents reviewed

included:

Project Concept Note (PCN), Ghana-Sanitation and Water Project for the Greater Accra Metropolitan

Area (GAMA)

Proposed GAMA Sanitation and Water Project-Aide Memoire

National Environmental Sanitation Strategy and Action Plan (NESSAP)

Environmental Protection Agency Act, 1994 (Act 490);

Environmental Assessment Regulations, 1999 (LI 1652);

National Environmental Action Plan;

Ghana EIA Procedures; and

World Bank’s Safeguards Policies.

The approach was based on review of available project literature and other strategic planning documents at the

national and sector level.


2.2 METHODOLOGY

KEY ACTIVITIES

SPECIFIC TASKS

Development of the

Environmental and

Social Management

Framework

1. Description of the project

2. Present the ESMF objectives

3. Describe the project activities and components

4. Present and analyze the baseline data (biophysical and socioeconomic

environment) for the participating Assemblies

5. Describe Legislative, Regulative and Administrative Regime regarding

the triggered Safeguards Policies of the World Bank safeguard policies

6. Analyze the country environmental and social management institutional

framework and within the framework of the project

7. Determination of Potential Impacts and Screening

8. Develop the Environmental and Social Management Plan including:

a. Screening process

b. Mitigation measures

c. Environmental monitoring plan

d. Responsibility and Institutional arrangements in

implementation and monitoring

e. Institutional Needs &Capacity Building

f. Consultation plan

g. Implementation schedule

h. Cost estimation

Technical appendices / recommendations/ List of individuals/institutions

contacted/ references


3.0 DESCRIPTION OF WATER AND SANITATION PROJECT FOR GAMA

3.1 CONTEXT AND OBJECTIVES OF GAMA

While Ghana compares favorably along most economic and development indicators with countries in the region,

it drops to the bottom of the list where access to improved sanitation is concerned. With regard to water, although

Ghana is expected to attain the MDG target, the reality is that service expansion cannot keep up with the high

population growth in urban areas, especially in the Greater Accra Metropolitan Area (GAMA). This particularly

affects people living in low income communities and especially women and children who are usually in charge of

fetching the water. The provision of water and sanitation services in a metropolitan area like GAMA presents an

additional institutional challenge. Whereas water services fall under the responsibility of the national Ghana

Water Company Ltd. (GWCL), the responsibility for sanitation services is divided among eight local governments

that generally lack the required operational and financial capacity and do not properly coordinate their actions.

The rapid growth of GAMA, both in terms of population and area1, has generally taken place in the absence of

adequate planning and little attention to the development of basic services, particularly sanitation. In addition to

the residents of the eight Metropolitan/Municipal Assemblies (MMAs) that constitute GAMA, there is a large

floating population that comes to the city to trade or work2. About 15 percent of GAMA population is served by a

sewerage network, 41 percent of residents use fee-for-use public toilet facilities, 33 percent have on-site facilities,

3 percent use bucket or pan latrines and about 7 percent of Accra residents still do not have access to any

improved sanitation facility3. This, combined with a lack of capacity to operate and maintain the few existing

wastewater facilities, has created serious health and environmental consequences. Indeed, by March 2011, a

significant number of cholera cases had been registered this year with several casualties4. The provision of water

supply also requires urgent attention, particularly to reach people in low income communities who must rely on

private vendors and pay significantly more for water than those with access to the utility network.

Increasing access to safe water supply and improved sanitation is a priority for the GoG that is embedded in the

National Water Policy (2007) and in the recently revised Environmental Sanitation Policy (2010). It also

underpins the principles enunciated in the 2000-2005 Ghana Poverty Reduction Strategy (GPRS), the 2006-2009

GPRS-II, the 2010-2013 national Ghana Shared Growth Development Framework (GSGDF), the Millennium

Development Goals, and the “Africa Water Vision” of the New Partnership for Africa’s Development. In

addition, the commitment of the GoG has been affirmed by the signing of the 2010 SWA Compact5 . The World

Bank Group (WBG) has been highly committed to contributing to the development of the Water and Sanitation

Sector (WSS) in Ghana. In coordination with other donors’ activities, the GoG has requested that the World Bank

Group continue its involvement in the WSS, as reflected under the FY08-11 CAS

Support is to be provided by means of two operations. The first7, which was approved in June of 2010, aims at

increasing access to safe water and improved sanitation in rural areas and improving the sustainability of these

decentralized services. The second is this proposed Sanitation and Water Project that aims at increasing access to

improved sanitation and safe water in the GAMA, with particular emphasis on low income areas. The GoG is

seeking support from the WBG given its experience with the implementation of water and environmental

sanitation projects in Ghana and in dealing with low income areas and institutional aspects. The proposed project

will therefore focus on providing low income communities located in the 8 MMAs with increased water supply

and improved sanitation services. The experience to be gained from the design and implementation of this project,


particularly in addressing the technical and institutional challenges for the provision of services to low income

areas, is expected to be replicated in other urban areas by the GoG with its own resources and with support from

other Development Partners that may also provide co-financing8 to this project.

Improving sanitation is the top priority of the citizens of Accra, followed by drainage, solid waste and water,

according to a recent survey of 4,000 households. Sanitation is also a priority for local governments, which have

been preparing their District Environmental Sanitation Strategy and Action Plans (DESSAPs) and are now asking

for help to implement them. There are also valuable lessons learned as a result of ongoing projects and pilot

studies by different institutions and NGOs10, especially in diverse low income areas. Tailored solutions for

providing services to such areas would be further developed through extensive community consultations during

project preparation and implementation in order to be scaled up by this and other projects to be supported by the

GoG and other donors.

B. Proposed project development objective(s)



facilities. In order to achieve this objective the project would support the expansion and improvement of the water

distribution network, the expansion of community water points and private water connections, the development of

on-site and sewered sanitation facilities, and the improved collection and treatment of wastewater and fecal

sludge. Behavior change campaign on hygiene, sanitation and safe water will also be promoted through social

mobilization activities, as well as social accountability to ensure the sustainability of the facilities and services.

Preliminary results indicators would include the following:

People in GAMA provided with sustainable access to improved drinking water sources under the

project (number);

People in GAMA provided with sustainable access to improved sanitation under the project

(number);

Improved community water points constructed or rehabilitated under the project (number);

New piped household water connections that are resulting from the project intervention (number)

Volume of wastewater and fecal sludge adequately treated (m3/d)

3.2 PROJECT COMPONENTS

3.2.1 Component 1 – Provision of Water and Sanitation Services

The MMAs will propose the priority low income communities to benefit from the project based upon selection

criteria to be agreed during project preparation. The type of water supply and sanitation facilities will be

thoroughly consulted and agreed with each community as to best suit their needs, while taking into consideration

particular conditions such as: soil characteristics, topography, space availability, etc.









3.2.2 Component 2 – Improvement and Expansion of Water Distribution Network

This component will support investments required to improve and expand the existing network in order to provide

piped water to the target people living in low income communities in the GAMA. These investments include the

installation of transmission mains, booster pumps and any other facilities required to ensure that a share of the

additional water production reach the targeted low income areas. Therefore this component will be coordinated

with current and incoming projects supported by other development partners and private investors in the GAMA.

This component would also support the acquisition and installation of meters and other equipment, as well as the

provision of services, aimed at improving water demand management and reducing non-revenue water.

3.2.3 Component 3 – Improvement and Expansion of Wastewater and Feacal Sludge Collection,

Transportation and Treatment

. This component will finance collection and/or treatment of wastewater and fecal sludge to be generated from

the low income communities and rest of GAMA. However, these facilities will be seized to take care of the entire

wastewater flows and sludge volumes generated in the GAMA, which currently end up discharged untreated into

drains and eventually into the sea. This component will also support the development of solutions to improve the

safe collection, transport and appropriate disposal of fecal sludge and solid waste.

3.2.4 Component 4 - Institutional and Project Management Support

This component will provide technical assistance (TA) to municipal, metropolitan and national institutions,

including the promotion of private sector initiatives for water and sanitation.


4.0 RESULTS OF THE PUBLIC CONSULTATION PROCESS

To adequately appreciate the views and concerns of stakeholders with regard to the project implementation,

field visits and consultation with key stakeholders, Ministries, Departments and Agencies, MMAs, and non-

governmental organizations are on-going. The consultations focused on:

Assessing the views and understandings of the MMAs on the GAMA;

Identifying and Assessing environmental and social impact of the GAMA

Proposed or ongoing Sanitation and Water Services rehabilitation activities under the MMAs

Reviewing the status of compliance and enforcement of environmental regulations within the MMAs.

Identifying capacity building needs for the MMAs and relevant regulatory institutions and recommending

actions to strengthen MLGRD and its partners to ensure sustained environmental and social compliance

monitoring.

The consultation was basically done in two forms:

- Group discussions with a cross-section of officials and professionals from government

Ministries, Departments, and MMAs.

- Interviews with key informants (MLGRD, EPA etc) so that views and concerns are more

broadly captured.

4.1 CONSULTATIONS WITH MMAS

Consultations are being held with the under-listed Ministries, Departments, Agencies (MDAs), Metropolitan and

Municipal Assemblies (MMAs):

1. Ministry of Local Government and Rural Development (MLGRD)/PCU

2. Ministry of Water Resources, Works and Housing (MWRWH)

3. Ghana Water and Company Limited (GWCL)

4. Community Water and Sanitation Agency (CWSA)

5. Accra Metropolitan Assembly (AMA)/UESP II, Greater Accra

6. Tema Municipal Assembly (TMA)

7. Ashaiman Municipal Assembly (Greater Accra);

8. Ga South Metropolitan Assembly

9. Ga West

10. Ga Central Municipal Assembly

11. La Nkwantanan Municipal Assembly

12. La Dade-Kotopon Municipal Assembly

13. Ledzokuku Municipal Assembly (LEKMA)

14. Adenta Municipal Assembly (AdMA)


4.2 CONSULTATIONS MINISTRIES DEPARTMENTS AND AGENCIES

Consultations are being held with the under-listed Regional EPA Offices:

1. Ministry of Local Government and Rural Development (MLGRD)/PCU

2. Ministry of Water Resources, Works and Housing (MWRWH)

3. Ghana Water Company Limited (GWCL)

4. Community Water and Sanitation Agency (CWSA)

5. EPA, Head Office-Accra

6. EPA, Tema Office – ; and

7. EPA, Greater Accra Regional Office, Amasama


5.0 GAMA BASELINE PROFILE

5.1 BACKGROUND

As shown in the maps, the city of Accra actually covers AMA, as well as parts of Ga West, Ga South, Ga East,

Tema Metropolitan Area (TMA), Ashaiman and Adenta.

The report of the fifth round of the Ghana Living Standards Survey (GSS, 2008), defines the Accra Metropolitan

Area (AMA), Tema Municipal Area (TMA) (which at that time also covered Ashaiman and Adenta municipality),

and the urban areas in Ga East and Ga West (which at that time included Ga South) Districts as the Greater Accra

Metropolitan Area (GAMA). The GAMA area covers a total area of about 1,261 km2 (Twum, 2002).

Figure 5-1 : Map of Greater Accra Area

5.2 ADMINISTRATIVE STRUCTURE

The eleven metropolitan and municipal areas that constitute the Greater Accra Metropolitan Area are managed by

Assemblies. The Metropolitan and Municipal Assemblies derive their mandate from the Local Government Act of

1993 (Act 462).The structure of these assemblies is also spelt out in the act. By this act, the Assemblies are the

highest political authorities mandated to govern a municipality or metropolitan area and to provide basic

Sanitation and Water services to support the social and economic development of the area. The area under the


assemblies is sub-divided into sub-metros, which are in turn further divided into town or areas councils and unit

committees.

Representatives from the sub-metro structures form the General Assembly. Members of the Assembly are voted

from Assembly elections which are held every four years. The general assembly is responsible for making

decisions and passing by-laws. This Assembly is chaired by a presiding member while the day-to-day

administration is handled by the chief executive (mayor or metropolitan/municipal chief executive), who is also a

member of the Assembly.

The Accra Metropolitan Assembly (AMA) was up to mid 2004 divided into six sub-metros. In 2004, the number

of sub-metros was increased to 13 by further sub-dividing the original six (Ghana Health Services 2008). In

February 2008, two sub-metros, Teshie and Nungua, were split off from AMA and joined to form the Ledzekuku-

Krowor municipal (with Teshie-Nungua as the district capital). Currently, AMA consists of 11 sub-metros:

Ablekuma Central, Ablekuma North, Ablekuma South, Ashiedu Keteke, Ayawaso Central, Ayawaso East,

Ayawaso West-Wuogon, La, Okaikoi North, Okaikoi South, and Osu Klottey.

5.3 PHYSICAL CHARACTERISTICS

Location and Size

The Accra Metropolitan Assembly (AMA) is one of the One Hundred and Seventy (170) Metropolitan, Municipal

and District Assemblies (MMDAs) in Ghana and one of the Ten (10) MMDAs in the Greater Accra Region.

Like all the District Assemblies, it was established by the Local Government Act, 1993, (Act 462) and Legislative

Instrument 1615 which also established the Six (6) Sub-Metropolitan District Councils. The L.I. 1718,

subsequently, increased the Sub-Metropolitan District Councils to Thirteen (13).

Following the creation of the Ledzokuku-Krowor Municipal Assembly (LEKMA) in 2008, AMA now operates

under a new L.I. 1926 which has also reduced the Thirteen (13) Sub-Metros to Eleven (11). It covers an area of

173 sq km. The Metropolis is located on Longitude05°35'N and on Latitude00°06'W.

The Northern boundary of the Assembly is Ga West Municipal Assembly (GWMA). It starts from the road

between the Institute of Professional Studies (IPS) and the Accra Teachers Training College (ATTRACO),

westwards crossing the Accra-Aburi Road to the University of Ghana behind the Great Hall to Kisiseman and

Christian Village to join the Accra-Nsawam Road at the Achimota Brewery Company (ABC) Road Junction.

It turns left for 500m to the Ayeayeefee Street junction and through the Ayeayeefee Street to the Bridge over the

Achimota Stream, then turns right along the stream to the high tension lines to the Achwilage Street and through

Achwilage Street to the range of the Awoshie Hills.

The Assembly is bounded to the West by Ga South Municipal Assembly (GSMA). The western boundary is along

the road from AwoshieHills to the boundary between GSMA and Awoshie. The boundary line then turns left

along the swampy area and crossing the Tema Motorway Extensionthrough the swampy area to the bridge on the

Sakumono Stream on the Accra-Winneba road and stretching along the stream to Gbegbeyese.


The Southern boundary stretches along the Gulf of Guinea from Gbegbeyese to the Kpeshie Lagoon at the La

Sub-Metropolitan District Council.The Eastern corridor of the Assembly is the LEKMA which was carved out of

the Accra Metropolitan Assembly.

Source: Urban Management Land Information System

Figure 5-2: Map of Greater Accra Area

5.4 GEOLOGY AND CLIMATE

Geology

The geology of the AMA consists of Precambrian Dahomeyan Schists, Granodiorites, Granites Gneiss and

Amphibolites to late Precambrian Togo Series comprising mainly Quartzite, Phillites, Phylitones and Quartz

Breccias. Other formations found are the Palaeozoic Accraian Sediments - Sandstone, Shales and Interbedded

Sandstone-Shale with Gypsum Lenses.


The coastline of Accra has a series of resistant rock outcrops and platforms and sandy beaches near the mouth of

the lagoons. The coastline is exposed and because of the close proximity of the continental shelf, a strong coastal

and wind action, it is subject to severe erosion. The lagoon systems are relatively small and flushing has been

impeded by siltation or the construction of embankments, which have restricted tidal flow. The largest of the

lagoons are Sakumo (Densu delta), and the Korle (Central Accra).

The soils in the Metropolitan area can be divided into four main groups: drift materials resulting from deposits by

windblown erosion; alluvial and marine motted clays of comparatively recent origin derived from underlying

shales; residual clays and gravels derived from weathered quartzites, gneiss and schist rocks, and lateritic sandy

clay soils derived from weathered Accraian sandstone bedrock formations.

In many low lying poorly drained areas, pockets of alluvial ‘black cotton’ soils are found. These soils have a

heavy organic content, expand, and contract readily causing major problems with foundations and footings. In

some areas, lateritic soils are strongly acidic and when saturated are prone to attack concrete foundations causing

honeycombing. Near the foothills are the large areas of alluvial laterite gravels and sands. Many of these

deposits are being won for constructional purposes.

Climate

The Accra Metropolitan Assembly lies in the Savannah zone. There are two rainy seasons. The average annual

rainfall is about 730mm, which falls primarily during the two rainy seasons. The first begins in May and ends in

mid-July. The second season begins in mid-August and ends in October. Rain usually falls in intensive short

storms and gives rise to local flooding where drainage channels are obstructed.

There is very little variation in temperature throughout the year. The mean monthly temperature ranges from

24.7°C in August (the coolest) to 28°C in March (the hottest) with annual average of 26.8°C. As the area is close

to the equator, the daylight hours are practically uniform throughout the year. Relative humidity is generally high

varying from 65% in the mid-afternoon to 95% at night.

The predominant wind direction in Accra is from the WSW to NNE. Wind speeds normally range between 8 to

16 km/hr. High wind gusts occur with thunderstorm activity, which pass in squall along the coast. The maximum

wind speed recorded in Accra is 107.4 km/hr (58 knots). Strong winds associated with thunderstorm activity

often cause damage to property and mostly removing roofing materials.

Several areas of Accra experience micro climatic effects. Low profile drainage basins with a North-South

orientation are not as well ventilated as those orientated East-West. Air is often trapped in pockets and an

insulation effect gives rise to local increase in air temperature of several degrees. This occurs in the Accra

Newtown and Azumah Nelson Sports Complex areas.

5.5 VEGETATION

Terrestrial Vegetation

There is evidence to suggest that the vegetation of the Metropolitan areas has been altered in the more recent past

century by climatic and other human factors. Much of the Metropolitan area was believed to have been covered


by dense forest of which only a few remnant trees survive. A climatic change combined with the gradient of the

plains and cultivation has imposed vegetational structures similar to those of the southern shale, Sudan and

Guinea Savannahs all of which lie north of the Accra plains.

There are three broad vegetation zones in Accra Metropolitan area, which comprise shrub land, grassland and

coastal lands. Only the shrub land occurs more commonly in the western outskirts and in the north towards the

Aburi Hills. It consists of dense clusters of small trees and shrubs, which grow, to an average height of five metres

(5m). The grasses are mixture of species found in the undergrowth of forests. They are short, and rarely grow

beyond One metre (1m). Ground herbs are found on the edge of the shrub. They include species, which normally

flourish after fire.

The coastal zone comprises of two vegetation types, wetland and dunes. The coastal wetland zone is highly

productive and an important habitat for marine and terrestrial-mainly bird life. Mangroves, comprising of two

dominant species, are found in the tidal zone of all estuaries sand lagoons. Salt tolerant grass species cover

substantial low-lying areas surrounding the lagoons. These grasslands have an important primary production role

in providing nutrients for prawns and juvenile fish in the lagoon systems. In recent times, wetlands are however

being encroached upon. Protection of the coastal wetland zone is very important to the long-term sustainability of

the fishing industry, which the Ga population of the City depend upon for survival.

The dune lands have been formed by a combination of wave action and wind. They are most unstable but stretch

back several hundred metres in places. There are several shrub and grassland species, which grow and play an

important role in stabilising dunes. Coconuts and palms grow well in this zone, providing protection and also as

an economic crop. Most of the coconuts were planted in the 1920s but it is estimated that over 80% of those

plantations have disappeared as a result of felling, disease and coastal erosion. The loss of these trees is one of

the principal reasons for the severity of erosion in some parts of the Metropolis.

In addition to the natural vegetation zones, a number of introduced trees and shrubs thrive in the Metropolitan

area. Neems, mangoes, cassias, avocados, and palms are prominent trees on the Accra landscape. Introduced

shrubs like bouganvilia are also very prominent. Achimota Forest is the only forest reserve in the AMA. These are

being damaged from residential encroachment, bush fire, sand collection and illegal tree felling.

Most of the open spaces in Accra are used for the cultivation of food crops like corn, okro, tomatoes and other

vegetables. Fertilizers and insecticides are used in these areas. Constant felling of trees, bad farming practices and

annual burning has altered the vegetation from “dry forest” and greatly depleted the fertility of the soil.

Aquatic Vegetation

Apart from mangroves and salt marsh grasses, which grow in the intertidal zone, sea grasses or attached algae

also occur mainly in rocky areas and wave cut platforms. These areas have increased as a result of erosion

exposing the underlying bedrock. They have an important role in the coastal ecosystem because of their high rate

of primary production in the provision of food and shelter for the survival of shrimps, prawns and many species of

fin fishes. Ocean floor sea gases are confined to a few sheltered areas of the coastline and the lagoons. The ocean

floor regime is too unstable to support large areas of sea grass.

Terrestrial Fauna


Different species of antelopes, squirrels, monkeys and reptiles live in Accra. Many animals such as the Togob

have grass cutter, bush baby and bossman potto are found in the Achimota Forest Reserve and outside the

urbanised area. Most animals have been pushed inland because for the rapid expansion of settlements in the

Metropolitan area. Many species of snakes (some venomous) and lizards are found throughout the Metropolitan

area. Apart from the above-mentioned fauna, a great number of domestic animals - donkey, sheep, goat and

chicken are kept domestically in the Metropolitan area.

Aquatic Fauna

The open lagoon systems support a wide range of crustacean, mollusks, gastropods, predatory and bottom feeding

fish. The lagoons are important breeding grounds giving adequate protection against large predator species and a

continual supply of nutrients and organisms for food. The habitat of the lagoons is or has been modified by

development and increasing levels of pollution. Some species in the lagoons - in particular the Korle lagoon - are

no longer suitable for human consumption. Protection of the water quality and vegetation in the lagoons is

important to the long-term sustainability of aquatic fauna along the coastline.

The ocean supports a wide range of pelagic and bottom feeding fish. Common species are grouper, mackerel,

cassava fish, African lookdown, sole shark and tiger fish. Stocks of off shore species have not been depleted

mainly because fishing techniques result in a significant loss of smaller fish from nets. Evidence suggests that on-

shore species are nearing exhaustion caused by excessive catches of juvenile and small fish. The loss of this

resource will have a substantial impact on the indigenous population of Accra whose livelihood is dependent on

fishing.

Weija reservoir, the marshes at the mouth of the Densu River, the Sakumo lagoon near the Panbros salt industry

constitute the most important fresh water wetlands for aquatic fauna. Apart from harbouring a variety of

important commercial fish species like tilapia and catfish, they also act as breeding grounds for animals, which

are adapted to the characteristic coastal Savannah vegetation.

5.6 DRAINAGE

The Metropolitan drainage catchment area extends from the eastern boundary of the Nyanyanu catchment on the

west of Greater Accra Regional boundary to Kpeshie Lagoon.

Densu River Catchment and Sakumo Lagoon

This is the largest of all the four coastal basins within the study area. The total drainage area is about 2500km2. It

is divided into two sections above and below the Weija dam. The northern section of the basin, which extends

inland along the Densu River and its tributaries 100 km, is hilly with the highest point reaching 230m above mean

sea level. The southern section of the basin is low lying land comprising the Sakumo lagoon and Panbros salt

pans. The Lafa steam flows into the lagoon and drains much of the western area of Accra including Dansoman,

Kwashieman, McCarthy Hill and Awoshie. Much part of this catchment is now urbanised.

Flooding is common along the 8km of the Densu River below the Weija dam whenever there is overtopping or

deliberate release of water over the spillway. Flooding is also prevalent in Dansoman area and along the Lafa

stream where it crosses the Winneba and Tema Motorway extension roads. Few of the drainage channels in the

catchments are constructed. As a result, there is heavy erosion of drainage channels - many of which flow down

existing tracks and roads. Access to this area is often cut off and roads become impassable during heavy rains.


Korle - Chemu Catchment

This catchment covers an area of 250 km2. It is bounded on the west by a line running roughly South-North from

Gbegbeyise, Dansoman, Kwashieman, and New Achimota; on the north by the Achimota -Legon axis; and to the

east by East Legon, the Airport and Ridge. The highest spot on the basin is about 308m above sea level. The

principal streams that drain the catchments are the Odaw River and its tributaries, the Nima, Onyasia, Dakobi and

Ado. The principal outlet for water in this catchment is the Korle Lagoon. There is a minor outlet at Chemu

Lagoon.

The Korle - Chemu catchment contains the major urbanised areas of Accra. Many of the drainage channels are

poorly developed and maintained. Erosion and siltation of drains is a serious problem. In low-lying areas

flooding is a serious problem, with many houses being inundated by floodwater during and after heavy rains.

Following the Netherlands Engineering consultants (NEDECO) report in 1963, a considerable amount of work

was done, particularly in connection with the Korle Lagoon and the Odaw River, but work was eventually

stopped. The drainage channels, until recently, had not been maintained resulting in the silting of the major

watercourses and the lagoon.

In low lying areas near the Accra Academy in Kaneshie, rapid run off from Asaredanho overflows into the Bank

of Ghana flats because inlet to the Kaneshie drains is inadequately designed. Similar problems occur in the

industrial land cemetery area around the Obetsebi Lamptey Circle where the interceptor drain and gullies are

inadequate. There are many other areas, like Nima, Dzorwulu, Darkuman and Alajo which have localised

flooding problems caused by inadequate drainage channels and the flat nature of the terrain.

Most roads in the catchment are not surfaced and side drains are mainly uncovered. The channels become

convenient places for the dumping of refuse. This, combined with erosion, results in choked and silted drain age

channels. These problems must be tackled by regular maintenance and the construction of new channels and

culverts where existing ones are shown to be inadequate. Until good access roads with properly constructed side

drains are provided in all urban areas, old and developing, drainage and flooding will continue to be a problem

every rainy season.

Kpeshie Catchment

The Kpeshie drainage basin covers a relatively small catchment area of 110 km2. It is bounded on the east by the

Military Academy at Teshie, on the north by a line south of Madina and Ajirignano. It covers the eastern part of

Accra, Ridge, Cantonments, Osu, Labadi and Burma camp areas. Streams in the catchment generally flow north

to south, emptying directly into the principal outlet to the sea at Kpeshie Lagoon or the small Korle Lagoon at

Osu.

Improvements have been made to straighten some of the watercourses in Christianborg and South La. Drainage

in the La Township is inadequate and many waterlogged areas become flooded with light rains. In heavy rains,

fence walls collapse and foundations are undermined.

Issues Affecting Urban Drainage


Poor drainage is the major problem, which affects many parts of the Metropolis. Natural features such as the

underlying geology, soil conditions and localised topographic features create some drainage problems.

Development should never have been permitted in these areas; however, poorphysical development control has

been unable to prevent urban land encroachment.

The majority of the problems are created by the high rate of urbanization (4.2%) of the City and its impact on

increase surface water runoff and flooding in low lying areas. The following issues require special attention in

developing a strategy for drainage within the Metropolis;

Flooding

The principal areas that are liable to flooding in the Metropolitan area are:

Panbros Salt Ponds

Dansoman - Mpoase - South Odorkor corridor

Dansoman - Sukura - Chorkor corridor

Mataheko - Abossey Okai - Korle Lagoon corridor

Odaw - Dzorwulu - Awudome - Industrial Areas System

Darkuman - North Kaneshie

Choked Drains

The inadequate drainage and poorly designed channels in many parts of the Metropolis have given rise to serious

flood problems. These problems are compounded by choked drains. A well-organised programme for seasonally

clearing drains is required to ensure they remain free flowing.

Impeded Drainage

Several low-lying areas along the Odaw and the Sakumo II catchment areas have natural low-lying areas of

impeded drainage. These are suitable habitat for vermin, snakes and disease carrying insects. Small-scale drainage

works are required to reduce the water table in these small-impeded drainage areas.

Dredging

Dredging of the Sakumo II and Korle lagoons is required to reduce flooding and provide improved flow in the

existing channel system. There are, however, a number of problems involved with the Korle Lagoon, which make

the dredging of this lagoon expensive. In other upper reaches of the lagoon, old car bodies and other wrecked

machinery and equipment have been carried or deposited in the lagoon and are now embedded in the floor of the

estuary. The removal of wreckage is necessary to create a proper channel to ensure adequate flushing once the

entrance is widened.

Against this background the Ministry of Water Resources, Works and Housing in collaboration with the AMA is

implementing the Korle Lagoon Ecological Restoration Project (KLERP). The project is financed by the

Government of Ghana, Kuwaiti Government fund and BADEA and the dredging of the lagoon is being done by

Dredging Ghana Limited. The second phase, which includes landscaping and the construction of canals has been

completed. However, the existence and activities of Old Fadama (Sodom and Gomorrah) pose great difficulties

for the continuation of the KLERP.


The cost of dredging is expensive (approximately US$85million) and it is therefore important that further

dumping of wrecks and waste is prohibited in the area. It is in this light that measures are currently been made to

remove the people of Sodom and Gomorrah, a squatter settlement near the project area.

Potential Ramser Sites and Conservation of the Lagoons

The disposal of silt from the lagoons has the potential to create a number of problems. There are opportunities to

utilise material for filling low-lying areas near the edge of the lagoons. However, the Sakumo II and Korle

lagoons are both under consideration as Ramsar (conservation) sites and excessive interference of the low-lying

area by filling will destroy much of the habitat for wildlife. Filling also destroys storage capacity. Dredging also

need to be well managed as the operation can release dangerous quantities of methane and other toxic gases into

the water in the estuary. This could have a dangerous impact on marine life. There is the need to consider

carefully the disposal of material taken by dredging so that undesirable environmental impacts of this operation

are minimised.

Lagoon Outfalls

Many of the lagoons along the coastline remain closed until opened by heavy rains. In the case of Korle and

Kpeshie Lagoons, these do not provide sufficient capacity for storm water discharge or adequate flushing of the

lagoon systems. Subsequently, these lagoons have become much polluted with a large buildup of sediment. In

order to improve the quality of water and provide sufficient channel clearance to enable floodwater to be

adequately discharged, the channel entrances at Korle have been widened substantially. There is also a need to

bypass the dry season flow around the edge of the lagoons to prevent the discharge of waste and maintain water

quality in the upper reaches.

Local Drains

Many of these are open sewers and a major health hazard. It must therefore be ensured that these drains are

cleaned as part of a public health programme. Many localised flooding problems in the urban area can be

attributed to poor design of storm water facilities. Under sizing of culverts and drainage channels, poor

consideration of maintenance requirements and under-estimation of siltation loads are common faults.

Conversely, concrete lined drainage channels on both sides of residential streets are often more expensive to

construct than the road itself. Simpler design standards could enable much larger areas to be serviced by storm

water drainage. There is the need to review many of the current design standards to ensure all drainage systems

have adequate capacity, but also that standards adopted are not excessively expensive. As the Metropolitan area

expands and more land comes under intensive cropping in catchments undergoing urbanisation, surface water

runoff will increase. This will lead to increased siltation and more severe floods down stream especially in areas

surrounding the lagoons. If this situation is to be avoided engineering and conservation measures will need to be

applied to reduce the rate of runoff. There is the need to introduce measures to protect the upper catchment areas

and streams where development and more intensive crop production are expected to take place.

5.7 AIR QUALITY

With the exception of the industrial area along the Odaw River, air quality in the Metropolitan area is good. Minor

incidents of localised pollution from automobile fumes arise during certain climatic conditions but these are

insignificant compared to those registered in some developed countries. During the months of December to


February, the effect of the Harmattan (fine windblown dust from the Sahara region) causes loss of visibility and

some health problems. These are seldom prolonged. Odour levels arising from decomposing rubbish and sanitary

wastes are high in inner city areas, especially, along the drainage system and in the region of the night soil dump

at Korle Gonno.

5.8 DEMOGRAPHY

Demographic Characteristics

The 2010 estimated population of Accra, pending the result of the 2010 PHC, is about 4.3 million with additional

daily influx population of 1 million who commute to the City for various socio-economic activities, which most

often are nonexistent thereby resorting to social vices and economic crimes.

Table 5-1: Demographic Figures of AMA by Sub-Metros

NO SUB METRO AREA

(KM2)

2000 POP *EST. 2010

POP

No. OF

HOUSES

(2000)

No. OF

HSEHDS (2000)

1. ABLEKUMA

CENTRAL

11.5 181,541 619554 15,606 40,219

2. ABLEKUMA

NORTH

13.6 140,063 483253 12,499 29,972

3. ABLEKUMA

SOUTH

15.1 211,493 729712 21,012 48,125

4. ASHIEDU

KETEKE

4.4 88,717 260174 4,599 20,440

5. AYAWASO

CENTRAL

6.0 155,947 435984 8,145 34,419

6. AYAWASO

EAST

5.8 128,641 359643 5,144 27,295

7. AYAWASO

WEST

35.2 50,334 140717 5,938 10,382

8. LA 36.0 133,721 373844 10,372 30,355

9. OKAIKOI

NORTH

21.1 141,085 394433 9,668 29,913

10. OKAIKOI

SOUTH

12.0 96,600 270066 7369 20,111

11. OSU KLOTTEY 12.0 96,634 270162 10,562 23,122

TOTAL 173 1,424,776 4,337,542 110,914 314,353 Source: 2000 P&HC (Ghana Statistical Service), UMLIS and Accra Metropolitan Authority

The high population figure of the City (4,337,542) is both an asset and source of worry to management. While the

relatively high population serves as a huge and vibrant market for investors, it also poses problem of sanitation

and waste management as well as traffic jam especially during the peak hours of the day.

The period between 1960 and 1970 saw the rapid industrialisation and expansion in the manufacturing and

commercial sectors in some major areas within the Metropolis. This factor contributed to high immigration to

Accra, and resultant in high population growth rate (6.32%) between 1960-1970 intercensal years. The stagnation

of the Ghanaian Economy during the 1970’s had adverse effect on the growth rate of Accra population as shown


in the growth rate (7.51%) of 1970-1984 intercensal years. The decline in agriculture in rural communities in

Ghana and industrialization in urban regions coupled with the late 1980s and 1990s boom in the service sector in

primate cities propelled immigration to Accra.

Table 5-2: Population and population Growth Rate

1960 1970 1984 2000

Population 338,396 636,667 969,195 1,658,937

Pop. Growth rate - 6.32% 7.51% 4.3%

Source: 1960, 1970, 1984 and 2000 National Population Census * Projected.

Projected Population (provisional) Figure the results of the 2010 PHC by GSS

The 2010 estimated population of Accra implies that the figure will be close to 5million by the 2013. The table

below shows the population projections of the various Sub-Metros in the Metropolis.

Table 5-3: Population Project of AMA by Sub-Metros

SUB METRO 2000 2010 2011 2012 2013

Ablekuma Central 181,541 619554 646195 673981 827950

Ablekuma North 140,063 483253 504033 525706 295200

Ablekuma South 211,493 729712 761089 793816 494679

Ashiedu Keteke 88,717 260174 271361 283030 408060

Ayawaso Central 155,947 435984 454731 474285 159661

Ayawaso East 128,641 359643 375107 391237 424173

Ayawaso West 50,334 140717 146768 153079 447534

La 133,721 373844 389919 406686 306424

Okaikoi North 141,085 394433 411394 429083 476533

Okaikoi South 96,600 270066 281678 293791 392149

Osu Klottey 96,634 270162 281778 293895 827950

Total 1,424,776 4,337,542 4,524,053 4,718,589 5,060,313

Source: Accra Metropolitan Assembly

The population figures above reflect the citizenry residing within the Metropolis. It is, therefore, estimated that

during the peak hours, Accra host about 25% of the national population and has influx population of about

1,000,000 on daily basis for economic activities aside the residential dimension captured by the 2000 National

Population Census. The primacy of Accra Metropolitan Area as an administrative, educational, industrial and

commercial centre is the main factor for this and continues to attract people from all over Ghana, and outside, as

its functional importance is on incremental ascendancy. Rural-urban migration accounts for over 35% of the

population increase.


Distribution and Density

The gross population density for Accra Metropolitan Area was 82.33 persons per hectare in 2000 compared to

6.23/ha in 1970. This is currently estimated to be 250.73/ha in 2010 and is projected to increase to 292.50 by the

end of the plan period in 2013 as depicted in the table below which will put pressure on the existing facilities and

will demand for direct efforts to meet the needs of the populace.

Table 5-4: Projected Population Density per Hectre

SUB METRO 2000 2010 2011 2012 2013

Ablekuma Central 157.86 538.74 561.91 586.07 719.96

Ablekuma North 102.99 355.33 370.61 386.55 217.06

Ablekuma South 140.06 483.25 504.03 525.70 327.60

Ashiedu Keteke 201.63 591.30 616.73 643.25 927.41

Ayawaso Central 259.91 726.64 757.89 790.48 266.10

Ayawaso East 221.79 620.07 646.74 674.55 731.33

Ayawaso West 14.30 39.98 41.70 43.49 127.14

La 37.14 103.84 108.31 112.97 225.12

Okaikoi North 66.86 186.94 194.97 203.37 145.28

Okaikoi South 80.50 225.06 234.73 244.85 320.24

Osu Klottey 80.53 225.14 234.82 244.91 689.96

TOTAL 82.36 250.73 261.51 272.75 292.50

Source: Accra Metropolitan Assembly

At the Sub-Metro level, Ashiedu Keteke is projected to be the most densely populated Sub-Metro in the

Metropolis followed by Ayawaso East and Ablekuma Central. These Sub-Metros, therefore, should be given

developmental attention to improve the living conditions of the projected population.

Population Distribution by Age and Gender

Accra’s population like that of other urban centres is a very youthful with 56% of the population under the age of

24years. It will be realised from the age-sex ratio that 51% of the population are females and the rest 49% males.

This gives a sex ratio of 1:1.04 males to females. The dominance of females over males is a reflection of the

nationwide trend where the estimated ratio is 1:1.03. The need to target women in any development programme in

the Metropolis can therefore not be over emphasised.

Age dependency ratio has been calculated to be at approximately 60%. 60 % of residents of Accra rely on the

other 40% for their livelihood. The table below is the projection of the population distribution by age and sex for

the Accra Metropolis for the plan period 2010-2013.


6.0 POLICY, LEGAL, INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT

The environmental policy and EA legislation and procedures of Ghana and those of the World Bank, which are

relevant to the Project, are outlined. In principle the two sets of policies and procedures on environmental and

social assessment are similar in many respects.

6.1 NATIONAL ENVIRONMENTAL REQUIREMENTS

6.1.1 Ghana’s Environmental Policy

The environmental policy of Ghana formulated in the National Environmental Action Plan (NEAP) of 1993

hinges strongly on ‘prevention’ as the most effective tool for environmental protection. The policy aims at a

sound management of resources and environment, and the reconciliation between economic planning and

environmental resources utilization for sustainable national development. It also seeks among others, to institute

an environmental quality control and sustainable development programs by requiring prior EA of all

developments, and to take appropriate measures to protect critical eco-systems, including the flora and fauna they

contain against harmful effects, nuisance or destructive practices. The adoption of the NEAP led to the enactment

of the EPA Act 1994 (Act 490); and subsequently the passing of the Ghana EIA Procedures into the EA


6.1.2 National Water Policy

OVERALL GOAL

Consistent with the GPRS, the overall goal of the National Water Policy is to "achieve sustainable development,

management and use of Ghana's water resources to improve health and livelihoods, reduce vulnerability while

assuring good governance for present and future generations". This will be achieved by addressing relevant issues

under water resources management, urban water supply and community water and sanitation. For each broad area,

a number of focus areas for policy considerations have been identified. Within each the main principles and

challenges are listed followed by policy objectives and the corresponding measures.

POLICY OBJECTIVES

The key policy objectives of applying the principles and meeting the challenges above to:

(i) Achieve sustainable management of water resources;

(ii) Ensure equitably sustainable exploitation, utilisation and management of water resources, while

maintaining biodiversity and the quality of the environment for future generations.

POLICY MEASURES AND/OR ACTIONS

Government will take the following measures and actions:

Facilitate availability of water resources for industrial uses through sustainable resources management;


Require industries, including mining operations, to develop and implement environmental management

systems which take into account the impact of industries on the country's water resources;

Fully implement the enacted requirements related to licensing of water uses (permits) and issuance of

waste water (effluent) discharge permits;

Encourage development of codes of practice for efficient water use and cleaner production technologies

in industrial activities; and

Formulate hydropower development plans to meet current and future demands in conjunction with other

uses, through sustainable water resources management.

PRINCIPLES AND CHALLENGES

The underlying principle in financing water resources management is meeting the social needs for water as a

priority, whilerecognis1ng the economic value of water and the goods and services it provides.

The main challenges are:

Ensuring sustainability in water resources management through appropriate pricing mechanisms while

ensuring equity;

Ensuring water resources management is adequately funded and appropriate levies instituted for raw

water abstraction to promote efficiency, sustainability and equity; and

Sustaining appropriate levels of funding to the sector to meet MDGs.

6.1.3 Environmental Sanitation Policy

The Environmental Sanitation Policy (Revised, 2010) responds to the various reviews carried out to assess how

effectively the previous policy published in 1999 has been implemented. The revised policy objectives and

measures are presented in a way that enhances strategic planning and subsequent implementation.

The broad principles underlying Ghana‟ s Environmental Sanitation Policy (Revised, 2010) are:

The principle of environmental sanitation services as a public good;

The principle of environmental sanitation services as an economic good;

The polluter-pays-principle;

The principle of cost recovery to ensure value-for-money ensuring economy, effectiveness and efficiency;

The principle of subsidiarity in order to ensure participatory decision-making at the lowest appropriate

level in society;

The principle of improving equity and gender sensitivity;

The principle of recognizing indigenous knowledge, diversity of religious and cultural practices;


The precautionary principle that seeks to minimize activities that have the potential to negatively affect

the integrity of all environmental resources;

The principle of community participation and social intermediation

The ESP defines the principal components of environmental sanitation to include;

(a) Collection and sanitary disposal of wastes, including solid wastes, liquid wastes, excreta,

industrial wastes, health-care and other hazardous wastes;

(b) Storm-water drainage;

(c) Cleansing of thoroughfares, markets and other public spaces;

(d) Control of pests and vectors of disease;

(e) Food hygiene;

(f) Environmental sanitation education;

(g) Inspection and enforcement of sanitary regulations;

(h) Disposal of the dead;

(i) Control of rearing and straying of animals;

(j) Monitoring the observance of environmental standards

Policy Focus Areas

In order to provide a clear basis for achieving the overall goal of the sector, the policy provides strategic elements

under seven (7) policy focus areas, as follows:

Capacity Development

Information, Education and Communication

Legislation and Regulation

Levels of Service

Sustainable Financing and Cost Recovery

Research and Development

Monitoring and Evaluation

6.1.4 The Environmental Protection Agency Act

The Environmental Protection Agency (EPA) Act, 1994 (Act 490) grants the Agency enforcement and standards

setting powers, and the power to ensure compliance with the Ghana EA requirements/procedures. Additionally,

the Agency is required to create environmental awareness and build environmental capacity as relates all sectors,

among others. The Agency (including its Regional and District Offices) is also vested with the power to

determine what constitutes an ‘adverse effect on the environment’ or an activity posing ‘a serious threat to the

environment or public health’, to require EAs, EMPs, Annual Environmental Reports (AERs), etc of an

‘undertaking’, to regulate and serve an enforcement notice for any offending or non-complying undertaking.

The Agency is required to conduct monitoring to verify compliance with given approval/permit conditions,

required environmental standard and mitigation commitments. Furthermore, a requirement by EPA for an EA

precludes any authorising MDA from licensing, permitting, approving or consenting such undertaking, unless

notified otherwise.


6.1.5 EA Regulations and Procedures

The EA Regulations combine both assessment and environmental management systems. The regulations prohibit

commencing an undertaking/activity without prior registration and environmental permit (EP). Undertakings are

grouped into schedules for ease of screening and registration and for EP. The schedules include undertakings

requiring registration and EP (Schedule 1), EIA mandatory undertakings (Schedule 2), as well as Schedule 5-

relevant undertakings (located in Environmentally Sensitive Areas).

The Regulations also define the relevant stages and actions, including: registration, screening, preliminary

environmental assessment (PEA), scoping and terms of reference (ToR), environmental impact assessment (EIA),

review of EA reports, public notices and hearings, environmental permitting and certification, fees payment,

EMP, Annual Environmental Report (AER), suspension/revocation of permit, complaints/appeals, etc.

6.1.6 EA (Amendment) Regulations, 2002

The EA (Amendment) Regulations were made to amend sections of the EA fees regime of LI 1652 (the ‘principal

enactment’) on fee payment for EP and certificate issued by the Agency.

6.1.7 Local Government Act, 1993 (Act 462)

The Local Government Act (Act 462) seeks to give a fresh legal expression to government’s commitment to the

concept of decentralization. It is a practical demonstration of a bold attempt to bring the process of governance to

the doorstep of the populace at the Regional and more importantly, the District level.

The Metropolitan, Municipal and District Assemblies (MMDAs) created under the law, constitute the highest

political authority in each district, municipality and metropolis.

Among the functions of the MMDAs are the following:

Formulate and execute plans, programmes and strategies for the effective mobilization of the resources

necessary for the overall development of the MMDAs;

Initiate programmes for the development of basic Sanitation and Water services and provide municipal works

and services in the MMDAs; and

Be responsible for the development, improvement and management of human settlements and the

environment.

6.1.7.1 Bye-Laws

One of the most important provisions of the law is the power of the MMDAs to make bye-laws for the purpose of

the functions conferred under Act 462 or any other enactment. Most MMDAs have adopted by-laws on sanitation

and waste. However, most MMDAs are still without sanitary engineered waste disposal facilities in place.


6.2 NATIONAL LABOUR, SAFETY AND HEALTH REQUIREMENTS

6.2.1 Factories, Offices and Shops Act

The Factories, Offices and Shops Act of 1970 (Act 328) mandates the Factories Inspectorate Department to

register factories and ensure that internationally accepted standards of providing safety, health and welfare of

persons are adhered to. It defines a factory to include any premises (whether in or not in a building) in which one

or more persons are employed in manual labour, among others.

6.2.2 Occupational Safety and Health Policy of Ghana (Draft)

The policy statement of the Occupational Safety and Health Policy (draft 2004) is: ‘to prevent accidents and

injuries arising out of or linked with or occurring in the course of work, by minimizing, as far as reasonably

practicable, the cause of the hazards in the working environment and, therefore, the risk to which employees and

the public may be exposed’. The policy is derived from provisions of the International Labour Organization (ILO)

Conventions 155 and 161. The policy document has specific sections on objectives, scope, strategies, activities

and promotion and awareness creation.

6.2.3 National Workplace HIV/AIDS Policy

The broad objectives of the policy among others, are to provide protection from discrimination in the workplace

to people living with HIV and AIDS; prevent HIV and AIDS spread amongst workers; and provide care, support

and counselling for those infected and affected.

6.2.4 Labour Act

The purpose of the Labour Act, 2003 (Act 651) is to amend and consolidate existing laws relating to labour,

employers, trade unions and industrial relations. The Act provides for the rights and duties of employers and

workers; legal or illegal strike; guarantees trade unions and freedom of associations, and establishes the Labour

Commission to mediate and act in respect of all labour issues. Under Part XV (Occupational Health, Safety and

Environment), the Act explicitly indicates that it is the duty of an employer to ensure that every worker works

under satisfactory, safe and healthy conditions.

6.3 THE GHANA SHARED GROWTH AND DEVELOPMENT AGENDA (GSGDA)

The 1992 Constitution provides a long-term national development imperative for Ghana through the Directive

Principles of State Policy which requires that every Government must pursue policies that would ultimately lead

to the “establishment of a just and free society”, where every Ghanaian would have the opportunity to live long,

productive, and meaningful lives.

The Ghana Shared Growth and Development Agenda (GSGDA, 2010-2013), Government responds to the 1992

constitutional injunction within the context of its Better Ghana Agenda. The “Better Ghana Agenda”

encompasses, but is not limited to the understated social and economic goals:

Putting food on people’s tables;

Providing citizens with secure and sustainable jobs;


Rehabilitating and expanding infrastructural facilities;

Expanding access to potable water and sanitation, health, housing and education;

Guaranteeing the security of persons and their property;

Embarking on an affirmative action to rectify errors of the past, particularly as they relate to

discrimination against women;

Reducing geographical disparities in the distribution of national resources;

Accelerating economic growth rate to at least 8% per annum;

Ensuring environmental sustainability in the use of natural resources through science, technology and

innovation;

Pursuing an employment-led economic growth strategy that will appropriately link agriculture to industry,

particularly manufacturing;

Creating a new social order of social justice and equity, premised on the inclusion of all hitherto excluded

and marginalized people, particularly the poor, the underprivileged and persons with disabilities;

Ensuring that the benefits of economic growth are fairly shared among the various segments of society;

and

Maximizing transparency and accountability in the use of public funds and other national resources.

It is the belief of Government that the policies and programmes emanating from the Ghana Shared Growth and

Development Agenda (GSDA) will lay the foundation to move Ghanaians closer to the long-term aspiration of a

just, free and prosperous society.

6.4 THE POVERTY REDUCTION STRATEGY OF GHANA

6.4.1 GPRS I and II

The GPRS I was a comprehensive framework of policies and development strategies, programs and projects to

facilitate macro-economic stability, sustainable growth and poverty reduction (2003-2005). The central goal of

GPRS II (2006-2009), which built on GPRS I was to accelerate the growth of the economy to attain a middle-

income status. The GPRS II emphasizes the implementation of growth-inducing policies and programs with the

potential to support wealth creation and sustainable poverty reduction. The document refers to the need to apply

environmental impact assessment and environmental audit to ensure that the growth arising from the GPRS is

environmentally sustainable.

6.5 THE WORLD BANK REQUIREMENTS

6.5.1 The Bank’s Safeguard Policies

The Bank’s ten (10) safeguard policies are designed to help ensure that programs proposed for financing are

environmentally and socially sustainable, and thus improve decision-making. The Bank’s Operational Policies


(OP) is meant to ensure that operations of the Bank do not lead to adverse impacts or cause any harm. They

include guidance on EA requirements.

The Safeguard Policies are lumped into Environment, Rural Development, Social Development and International

Law. The following seven out of the ten are relevant for considerations under the Project. These are:

Environmental Assessment (OP 4.01);

Natural Habitat (OP 4.04);

Pest Management (OP 4.09);

Indigenous Peoples (OP 4.10);

Physical Cultural Resources (OP 4.11);

Involuntary Resettlement (OP 4.12);

Forestry (OP 4.36);

Safety of Dams (OP/ 4.37);

Projects in International Waterways (OP 7.50);

Projects in Disputed Areas (OP 7.60); Plus

Public Disclosure (OP 17.50).

6.5.1.1 Environmental Assessment (OP 4.01)

The OP 4.01 requires among others that screening for potential impacts is carried out early, in order to determine

the level of EA to assess and mitigate potential adverse impacts. The Bank’s project screening criteria group

projects into three categories:

Category A – Detailed Environmental Assessment;

Category B - Initial Environmental Examination and

Category C – Environmentally friendly

The EA ensures that appropriate levels of environmental and social assessment are carried out as part of project

design, including public consultation process, especially for Category A and B projects. The OP 4.01 is applicable

to all components of the Bank’s financed projects, even for co-financed components.

6.5.1.2 Involuntary Resettlement (OP 4.12)

The Policy on Involuntary Resettlement is intended to assist displaced people arising from development projects,

in order not to impoverish any affected people within the area of influence of projects. An action plan that at least

restores the standard of living must be instituted, in cases where resettlement is inevitable or loss of assets and

impacts on livelihood occurs.

6.5.1.3 Forestry (OP 4.36)

The OP/BP 4.36 aims at enhancing the environmental and social contribution of forested areas, and the need to

reduce deforestation. The protection of forests through the control of forest-related impact of all investment

operations is a concern of the policy. It promotes the restriction of operations affecting critical forest and


conservation areas, while requiring that the sector and other relevant stakeholders should be consulted as

appropriate.

6.5.1.4 Physical Cultural Property (OP 4. 11)

The policy is premised on the need to investigate and take inventory of cultural resources likely to be affected.

Mitigations are provided for in cases of adverse impacts on physical cultural resources. Mitigation measures

should be undertaken in conjunction with the appropriate authorities, organizations and institutions that are also

required to be consulted and involved in the management of cultural property.

6.5.1.5 Natural Habitats (OP 4.04)

This policy recognises that the conservation of natural habitats is essential for long-term sustainable development.

The Bank, therefore, supports the protection, maintenance, and rehabilitation of natural habitats in its project

financing. The Bank supports, and expects the borrowers to apply, a precautionary approach to natural resource

management to ensure opportunities for environmentally sustainable development.

6.5.1.6 Safety of Dams (OP 4.37)

The Policy seeks to ensure that appropriate measures are taken and sufficient resources provided for the safety of

dams the Bank finances. The Bank distinguishes between small and large dams, and the policy is triggered for

large dams. Small dams are normally less than 15m in height; this category includes farm ponds, local silt

retention dams, and low embankment tanks. For small dams, generic dam safety measures designed and

supervised by experienced and competent professionals are usually adequate.

6.5.1.7 Indigenous People (OP 4.10)

The objective of the policy is: (i) ensure that the development process encourages full respect of dignity, human

rights and cultural features of indigenous people; (ii) ensure they do not suffer from the detrimental effects during

the development process; and (iii) ensure indigenous people reap economic and social advantages compatible

with their culture. Measures to address issues pertaining to indigenous people must be based on the informed

participation of the indigenous people themselves.

6.5.1.8 Bank’s Policy on Disclosure (OP 17.50)

The Bank’s policy on disclosure currently under review requires that all the people residing in the given areas of a

project have the right to be informed of the proposed development project. Prior to project appraisal therefore, the

summary of the study of the development action along with other relevant information should be disclosed to or at

the level of the Bank and the project area.


6.5.2 Triggered Safeguard Policies

The World Bank Safeguard Policies that are triggered are OP 4.01 -Environmental Assessment, OP 4.01 Annexes

A, B, and C on Environmental Assessment, OP 4.12-Involuntary Resettlement.

The construction of the proposed sanitation and water facilities in the GAMA could have irreversible

environmental impacts unless mitigating measures recommended are carried out during the construction and

operation stages. Some of the potential adverse impacts that may occur relating to the physical environment are:

Groundwater pollution;

Surface water pollution;

Loss of top soil;

Loss of useful subsoil;

Changes in drainage of soils;

Changes in runoff characteristics;

Changes in water quality.

Other receiving environments that may be affected are the ecological environment, land use,

human health and economic issues.

Arising from the potential adverse environmental impacts enumerated above, the significance of the impacts, the

extent of displacement for proposed projects there may be the need to resettle displaced persons whose

settlements will have to give way for the project. This scenario that may pertain to the Sanitation and Water

Project in the GAMA means that the Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) and Involuntary

Resettlement policies (OP/BP 4.12) will be triggered.

6.6 ENVIRONMENTAL SANITATION POLICY

In 1999 the Ministry of Local Government published an Environmental Sanitation Policy. This Policy was

prepared long after the NEAP. Sanitation is construed to have a broader meaning than waste. The Policy describes

the objectives of environmental sanitation to include developing a clean, safe and pleasant physical environment

in all human settlements, promoting the social, economic and physical well-being of all sections of the population.

It comprises of various activities including the construction and maintenance of sanitary infrastructure, the

provision of services, public education, community and individual action, regulation and legislation.

6.6.1 Solid Waste Management

The Policy confers primary responsibility for solid waste management on the Assemblies. However, the private

sector will be invited to provide the actual services under contract or franchise, as appropriate.

The Policy lists the following as acceptable technologies for solid waste disposal:

Sanitary landfill;

Controlled dumping with cover;

Incineration;

Composting; and

Recycling


6.7 INTERNATIONAL CONVENTIONS

Ghana is party to many international agreements such as:

Treaty on Marine Life Conservation, 1966

The Convention on Prevention of Marine Pollution by Dumping of Waste and other Matter, 1972

Convention on the Prevention of Pollution from Ship, 1973/1978

Convention on the International Trade in Endangered Species of Wild Flora and Fauna, 1981

Law of the Sea, 1982

International Agreement on the Protection of Tropical Timber, 1994

Comprehensive Nuclear Test Ban Treaty (CTBT), 1996

Vienna Convention on the Protection of the Ozone Layer, 2001

United Nations Framework Convention on Climate Change (UNFCCC), 1994

The Convention on Biological Diversity (Biodiversity Treaty), 1993

Environmental Modification Treaty, 1997.

6.8 INSTITUTIONAL FRAMEWORK

6.8.1 Ministry of Environment, Science and Technology

The Ministry of Environment, Science and Technology (MEST) was established in 1994. Its creation was in

response to a national development need to integrate environmental, scientific and technological considerations

into the country’s sectoral, structural and socio-economic planning processes at all levels.

The declared mission of MEST is to establish a strong national scientific and technological base for accelerated

sustainable development of the country to enhance the quality of life for all. Among other things, this will be

done through the development and promotion of cost-effective use of appropriate technologies.

Among the main areas of policy thrust for MEST, are Sanitation and Waste Management (Technical Options) and

Science and Technology promotion, education and acculturation.

6.8.1.1 Functions

The functions of MEST are:

Protection of the environment through policy formulation and economic, scientific and technological

interventions needed to mitigate any harmful impacts caused by development activities;

Standard setting and regulatory activities with regard to the application of science and technology in

managing the environment for sustainable development;

Promotion of activities needed to underpin the standards and policies required for planning and

implementation of development projects; and

Co-ordination, supervision, monitoring and evaluation of activities that support goals and targets of the

Ministry and national sustainable development.


It is noted that MEST is the political focal point for United Nations Convention on Climate Change (UNFCCC) in

Ghana and therefore plays a key role in activities that arise out of the implementation of the Convention.

6.8.2 Ministry of Local Government and Rural Development

The Ministry of Local Government and Rural Development (MLGRD) exists to promote the establishment and

development of a vibrant and well resourced decentralized system of local government for the people of Ghana to

ensure good governance and balanced rural based development. This will be done by:

Formulating, implementing, monitoring, evaluating and co-ordinating reform policies and programmes to

democratise governance and decentralise the machinery of government.

Reforming and energising local governments to serve effectively as institutions for mobilising and

harnessing local resources for local national administration and development.

Facilitating the development of all human settlements through community and popular participation.

Facilitating the promotion of a clean and healthy environment.

Facilitating horticultural development.

Improving the demographic database for development planning and management.

Promoting orderly human settlement development.

The pursuance of the Ministry’ vision is based on two divisions:

Local government - Strong Structures, Revenue Mobilisation and Collection, and Sanitation.

Rural Development - Rural roads, Information and Communications Technology, Tourism and Agric

Processing.

The following, among other are the main objectives of the Ministry:

To formulate appropriate policies and programs to accelerate the implementation of decentralization of

the machinery of government. This is to avoid re-centralization of government machinery.

To improve upon the human resources and institutional capacities for all levels of the decentralized

government machinery (District, town and Unit)

To improve the capacity of communities and local government institutions to mobilize, and manage

resources for accelerated rural and urban development.

To promote community based registration, collation, analysis and publication of data on all births and

deaths occurring in Ghana.

To promote human development and sustain the orderly and healthy growth of rural and urban

settlements in Ghana.

To monitor and evaluate the effectiveness of local government institutions for improved management

performance.

6.8.3 Ministry of Water Resources Works and Housing

The Ministry of Water Resources, Works and Housing has as its main functions the formulation and co-ordination

of policies and programmes for the systematic development of the country's Sanitation and Water Services


requirements in respect of Works, Housing, Water Supply and Sanitation and Hydrology. The Ministry co-

ordinates and supervises, by way of monitoring and evaluation of the performance of both public and private

agencies responding to and participating in the realisation of the policy objectives established for the sector.

6.8.4 Ministry of Finance and Economic Planning

The ministry of Finance and Economic Planning is the agency that manages the central government’s budget. The

ongoing management of the fiscal framework for local government is a core competence of the Ministry of

Finance and Economic Development (MoFEP). The Ministry has recently expressed a strong commitment to

develop dedicated capacity through the decision to establish a Fiscal Decentralisation Unit within the Budget

Office of the Ministry. This project component will provide support directly to the Unit to assist in its

establishment and the performance of its functions. Staff costs and basic administrative overheads have already

been budgeted for by the Ministry from the 2011 financial year. Simultaneously, MLGRD has established the

Fiscal Decentralization Secretariat (FDS). The Fiscal Decentralization Unit will work in close collaboration with

the FDS as part of rolling out its activities in particular in relation to preparation of PFM reform strategies for the

five core reform areas.

6.8.5 Ministry of Roads and Highways

The Ministry of Roads and Highways is a government establishment responsible for policy formulation,

monitoring and evaluation with regard to the transport sector which consists of the following:

a) Road Infrastructure sub-sector

b) Road Transport Services and Safety sub-sector.

c) Road Transport Training

d) Road Maintenance Financing

The Departments and Agencies relevant to the GAMA that operate under the direct ambit of the Ministry are

following with respect to Road Infrastructure:

Department of Feeder Roads (DFR)

Department of Urban Roads (DUR)


7.0 POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS OF THE GAMA PROJECTS AND

MITIGATION


Under Component 1,2 and 3, the World Bank is funding this proposed Sanitation and Water Project that aims

at increasing access to improved sanitation and safe water in the GAMA, with particular emphasis on low

income areas. The GoG is seeking support from the WBG given its experience with the implementation of

water and environmental sanitation projects in Ghana and in dealing with low income areas and institutional

aspects. The proposed project will therefore focus on providing low income communities located in the 8

MMAs with increased water supply and improved sanitation services. The Table 7.1 below presents the list of

some of the likely investments and the safeguards status (Please note that this list is not comprehensive).

Table 7-1: Status of Safeguard Work

Component 1 :

Provision of water

and environnemental

sanitation services to

priority income areas

of the GAMA

Location

Implementation


EIA RPF RAP


required



required



Water supply and sanitation facilities for communities

Water Supply and sanitation facilities for households

Water supply and sanitation facilities for schools, health centrers and in public areas such as markets

Engagement of community and particularly women to provide oversight of water and sanitation services such as

Water and Sanitation Development Board (WSDBs)

Construction of water supply system;

Drilling of boreholes;

Mechanization of boreholes;

Construction of KVIPs;

Construction of water closet seaters;

Rehabilitation of public toilet;

Construction and lining of drains;

Component 2 :

Improvement and

expansion of the

water distribution

network in the

GAMA

Location

Implementation


EIA RPF RAP


required



required



Investments to improve and expand the existing network to provide piped water to the targeted people living in low

income communities in the GAMA

Installation of transmission mains, boster pumps and other facilities

Support acquisition and installation of meters and other equipment as well as provision of services aimed at

improving water demand management

Component 3 :

Improvement and

Location

Implementation


EIA RPF RAP


expansion of

wastewater and fecal

sludge collection,

transportation and

treatment in the

GAMA


required



required



Collection and/or treatment of wastewater and fecal sludge to be generated from the low income communities and

rest of GAMA

Improve the safe collection, transport and treatment of fecal sludge

7.1 POSITIVE ENVIRONMENTAL AND SOCIAL IMPACTS

The overall environmental impact of the project is expected to be positive. Significant positive impacts to the

natural and socioeconomic environments will be achieved by the participating MMAs. By developing

infrastructure, the capacity of the MMAs to deliver quality services will be improved.

The positive environmental and social impacts for Water and Sanitation include information relevant to the

construction, operation and maintenance of (i) potable water treatment and distribution systems, and (ii) collection

of sewage in centralized systems (such as piped sewer collection networks) or decentralized systems (such as

septic tanks subsequently serviced by pump trucks) and treatment of collected sewage at centralized facilities. Key

expected positive results or outcomes are as follows:

Improved Conservation and Presevation of Water

Sustainable Water Supply


Improved use of Water and Sanitation

Sustainable water supply


Increase Employment

Improved conditions for economic growth

General economic growth

Poverty reduction

Increased affordability of water and sanitation


Reduced rate of water related deseases

Improved social development

Improved health

Poverty reduction

Greater equity in allocation of water and sanitation




Improved health

Improved quality of water and sanitation




Improved health

Improved water and sanitation , health and hygiene behaviour

7.1.1 Maternal Mortality:

A reduction in maternal mortality depends strongly on the water supply and sanitation situation. A contributory

factor to poor maternal health is contaminated water and poor hygiene, leading to infection and slow postnatal

recovery. Good water supply facilities will support fewer miscarriages from heavy water transport and safer home

birth. At the same time a better general health condition due to reduced health risks linked to insufficient water

and sanitation will also have a positive impact on maternal mortality. However, reducing the health risk by

improving water supply and sanitation needs to be linked to improving hygiene practices in order to bring about

the desired impacts.

7.1.2 Other Diseases:

Insufficient water supply and sanitation as well as inappropriate hygiene practices are associated with number of

different diseases. Eliminating stagnant, standing water around the households and water points can contribute to

reducing the incidence of malaria, in particular in dry areas with few natural mosquito breeding places. At the

same time, reducing the incidence of water-borne, water-washed and waterbased diseases through improved

services and hygiene behaviors will have a positive impact on reducing the susceptibility to other illnesses. For

people living with HIV/AIDS, water, sanitation and hygiene is extremely important in reducing the incidence of

opportunistic infections.

7.1.3 Environmental Sustainability:

Insufficient or inadequate water supply and sanitation is very often associated with an unsustainable exploitation

of natural resources. Improved water management, including industrial pollution control and water conservation is

a key factor for maintaining ecosystem integrity. Adequate treatment and disposal of excreta and both household

and industrial wastewater contribute to less pressure on freshwater resources. Furthermore, improved sanitation

reduces flows of human excreta into waterways and reducing the respective health and environmental risks.

Furthermore, water, sanitation and hygiene is important for improving the lives of slum dwellers, by reducing the

risks of contracting water-related illnesses, relieving the burden on women and opening opportunities for small-

scale enterprises.

7.1.4 Improvement of the living conditions

An overall improvement of living conditions will be achieved by the population. The length of time women spent

providing water for the family will be reduced significantly. An improved water supply will increase the

opportunities for women to improve their economic productivity. The time dedicated to fetching water will be

freed up for income generation.


The next sections explore some of the identified prospective projects related benefits and general positive

impacts:

7.1.5 Water Supply Project

Construction and rehabilitation of water and sanitation facilities will have significant positive impacts

on the health of the communities and populations in all the targeted districts,

Safe water fully available to the populations as well as their assets emanating from projects in livestock

watering points and associated animal tracks (reducing or eliminating prevailing

agriculturalist/pastoralist conflicts) and small scale agricultural activities and essentially improve their

quality of life.

Water supply services A variety of water service delivery models can be identified in the Greater Accra Metropolitan Area with different

sources of water providing different levels of water services. These include utility water supply services, private

(intermediary and independent) water supply services and community managed water supply services.

Households can rely on a mix of different service delivery models for their water supply.

The main source of water for AMA and TMA is the utility system, which produces almost 365,000 m3 per day,

about 99 percent of all water produced in GAMA. Although the utility, the Ghana Water Company Limited

(GWCL) produces most of the water that is used in the Greater Accra Metropolitan Area, only about 51 percent of

the population has direct access to utility water supply services. The rest depend on private and community

service providers, many of whom get their water from the GWCL system, either directly (through a connection to

the network) or indirectly (e.g. through tanker services). There is a variety of alternative service providers. Each

provides different services in different areas at different costs per unit water, which are considerably higher than

the costs per unit water charged for water supplied through household connections. A number of communities on

the fringes of Accra are being served by systems independent from the utility system, including community-

managed small town piped water supply systems implemented by the Community Water and Sanitation Agency

(CWSA), and privately-operated and managed water supply kiosks, like the WaterHealth Centres which can be

found in the northwest of Accra.

The issues the project aims at addressing are:

Increased water demand to be higher or at least equal to the supply needs.

Reduction in the amount of non-revenue water in the GWCL system. Physical losses (27 percent of the

amount of water produced), as well as economic losses (33 percent of the amount of water produced) will

be reduced significantly.

Improved reliability of the GWCL system through improved reliable electricity supply, increased storage

capacity in the distribution system.

Some equity will be achieved as against the current situation whereby large parts of the GAMA

population depend on expensive alternative service providers:


7.1.6 Excreta and Wastewater Services

Different sanitation service delivery models can be identified in the Greater Accra Metropolitan Area. Sanitation

service providers can be broadly grouped into three categories: municipal service providers, private service

providers and self-supply. The municipal providers include septic emptiers, servicing both private WCs as well as

public facilities; the sewer system, with household and institutional connected WCs; and human waste transfer

stations where human waste from pan and bucket latrines is collected. There are also private sector septic

emptiers, servicing the same target group as the municipal septic emptiers. Finally, a number of people and

institutions provide their own sanitation services. These include institutional sewer systems and on-site treatment

sanitation facilities like pit latrines and KVIPs.

The main challenges related to sanitation in the GAMA can be summarised as:

The vast majority of the waste treatment plants are not working:

There is a lack of treatment capacity:

The lack of use of safe and hygienic sanitation facilities:

Many people depend on public sanitation facilities, paying more for access to lower level services than

people with access to private sanitation services.

A successful implementation of the proposed water and sanitation project in the GAMA will yield the following

positive impacts:

Improved access to private sanitation facilities, which can be achieved through the enforcement of by-

laws for the construction of household latrines, the facilitation of appropriate technology choice and

awareness creation and education.

Improved public latrine services by increasing the number of public latrines, ensuring adequate water

supply to public latrines and improving the management of public latrines.

Increased treatment capacity. Under the Accra sewerage improvement project, there are plans to extend

the sewer system. However, even when fully successful, the impact of this intervention will be relatively

small. Therefore, additional strategies are needed like securing, acquiring and maintaining sludge

treatment sites; rehabilitating existing ones; and using natural systems.

Improved the use of existing treatment capacity by increasing the number of connections to the sewer

system and by building the capacity of the sewerage unit staff.

7.1.7 Economic Benefits to MMAs

Improved Sanitation and Water through rehabilitation and maintenance provides such socio-economic

benefits as accessibility which will significantly enhance economic prospect and integration. Lack of

access has been traditionally linked to poverty in Ghana.


7.1.8 Enhanced Institutional Capacity to Support Decentralization

The Project will offer important contribution and legacy to the decentralization program by providing capacity

building opportunities to the MMAs. The support to MMAs will particularly enhance community involvement in

decision processes affecting their interests, gender issues and other environmental and social related activities in

their immediate neighbourhoods.

Institutional coordination and planning

Institutionally the sector is fragmented, with overlapping areas of responsibility. There is poor-to-no enforcement

of existing (planning) regulations and lack of frameworks for integrated planning.

The situation can be improved through the following:

Facilitation of a ‘Greater Accra Metropolitan Area (GAMA) Integrated Urban Water Management

Planning and Coordination Platform’ for city wide planning alignment and development of water and

sanitation services

Resolution of ambiguities regarding the respective roles of the municipalities and Ghana Water Company

Limited in providing water services.

Resolution of ambiguities on responsibilities for drainage

Resolution of ambiguities regarding responsibilities for wastewater management at the local authority

(Metro/Municipal Authority) level

7.1.9 Conclusion

The Sanitation and Water Facilities Project in the GAMA will result in:

Generic improvement within the Metropolis and Municipalities for water and sanitation projects:

Improvement in the hygienic conditions and public health

There will be an improvement in the environment, and hygienic conditions of the city due to provision of

efficient water and sanitation facilities. The prevailing trends of morbidity and mortality are likely to

change. The present health statuses of these communities are characterized by high morbidity rate from

occasional outbreak of preventable and infectious diseases like cholera and typhoid fever. High

occurrence of Malaria is also prevalent as a result of poor drainage facilities and the malaria, which is

endemic, will be reduced as a result of the drainage to be provided.

Employment generation

There will be employment generation for unskilled labourers during the construction stage of various

Sanitation and Water facilities. Thus the project has the potential to contribute to economy through labour

absorption and the supply of construction materials.


Improve access to basic water and sanitation services

There will be an access to basic services like water supply as these will be supplied and be connected.

Gender-Status of Women

The provision of the water and sanitation facilities is expected to enhance the lot of women in the project

areas. Apart from those who will be employed directly on the project, others will be engaged in trading at

the construction sites supplying the workforce with food and other consumables. Although the numbers

will not be disproportionately high a vibrant and booming trade for the women implies an improvement in

living standards of the people.

7.2 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS,

The proposed Sanitation and Water works will have an impact on the environment. The potential impacts of the

development are both adverse and beneficial. An assessment of the negative impacts can be classified into

construction phase and post-construction phase impacts.

7.2.1 Environmental Impact Assessment

Constructional Phase Impacts

The constructional works would present negative environmental impacts. The construction phase includes the

following operations: site clearing, excavation and grading, upgrading of drains, installation of utility services

(electricity and water supply). These activities will have direct impact on the environment. The negative impacts

are discussed and assessed below:

7.2.1.1 Soil and Land Degradation

Access road upgrading normally involves the use of earth-moving equipment such as bulldozers and excavators.

The use of earth moving equipment or machinery during the clearing of the access way will not only expose the

soils but also compact the soil and break down the soil structure. This and the sealing of the road surface with tar

or another petroleum-based material would potentially reduce rainwater percolation into the ground water. In

addition, site-levelling activities will interfere with the natural drainage pattern and this has the potential of

causing siltation of the natural drainage channel.

7.2.1.2 Air Quality

The main impact on air quality will be experienced during the construction phase. Particulates (dust) from site

preparation, haulage of plant and equipment and construction materials on the untarred access road will cause

deterioration in the quality of air at the site. Other sources of dust will be earthworks such as excavation and the

delivery of coarse aggregates. The excessive generation of dust will have a significant impact on the health of the

workers and persons living in nearly residences.


7.2.1.3 Vehicular Traffic Implication

The construction works will result in an increase in traffic volume on the roads in the area. The transport of raw

materials will introduce a number of heavy trucks on the main road and this could increase the risk of motor

accidents and also result in vehicular-pedestrian conflicts. These impacts are localised and regarded as short term.

7.2.1.4 Noise Levels and Ground Vibration

Minimal and intermittent noise would be generated during the construction phase of the project. The background

noise levels and ground vibrations at the access roads will increase as a result of the movement of a number of

tipper trucks delivering materials, heavy earthmoving equipment and the use of machinery such as concrete

mixtures. The anticipated noise levels and ground vibrations will however, not have devastating effects on the

work force and immediate environment. Other inconveniences will be created to the adjoining communities

during the construction stage

7.2.1.5 Constructional Wastes

The constructional activities on the access ways will produce wastes such as excavated soils and redundant

materials such as broken block and pieces of wood. The haphazard collection of constructional wastes could

obstruct the movement of the workers and trucks as well as affect the beauty of the estates. These wastes will

therefore have to be managed at various times during the construction period.

7.2.1.6 Occupational Health and Safety

Safety of the local population and workforce may be threatened during constructional phase. The movement of

trucks to and from the access roads, the operation of the various equipment and machinery and the actual

construction will expose the workers to work-related accident and injuries. Pollutants such as dust and noise in

the workplace environment could also have negative implications for the health of the workers.

7.2.2 Operational Phase Impacts

7.2.2.1 Water Withdrawal

Some of the issues relating to urban water management in the GAMA stem from other municipalities and regions.

For example, water supply to the Accra depends to a large extent on sources from outside the city and indeed the

region. This means that pollution of water sources or even problems with the pipelines in the areas through which

they pass before getting to Accra, cuts across municipalities and district assemblies.

Traditional sources for potable water treatment include surface water from lakes, streams, rivers, etc. and

groundwater resources. Development of water resources often involves balancing competing qualitative and

quantitative human needs with the rest of the environment. This is a particularly challenging issue in the absence

of a clear allocation of water rights which should be resolved with the participation of appropriate stakeholders


such as the Water Commission, Water Research Institute (WRI), Community Water and Sanitation Agency

(CWSA) in advance of project design and implementation.

7.2.2.2 Water Treatment

Environmental issues associated with water treatment include:

Solid waste

Solid waste residuals generated by water treatment include process residuals, used filtration membranes, spent

media and miscellaneous wastes. Process residuals primarily consist of settled suspended solids from source water

and chemicals added in the treatment process, such as lime and coagulants. Pre-sedimentation, coagulation (e.g.

with aluminum hydroxide [alum] or ferric hydroxide), lime softening, iron and manganese removal, and slow

sand and diatomaceous earth filtration all produce sludge. Composition of the sludge depends on the treatment

process and the characteristics of the source water, and may include arsenic and other metals, radionuclides, lime,

polymers and other organic compounds, microorganisms, etc. Damaged or exhausted membranes are typically

produced from water treatment systems used for desalination. Spent media may include filter media (including

sand, coal, or diatomaceous earth from filtration plants), ion exchange resins, granular activated carbon [GAC],

etc.

Wastewater

Wastewater from water treatment projects include filter backwash, reject streams from membrane filtration

processes, and brine streams from ion exchange or demineralization processes. These waste streams may contain

suspended solids and organics from the raw water, high levels of dissolved solids, high or low pH, heavy metals,

etc.

Hazardous chemicals

Water treatment may involve the use of chemicals for coagulation, disinfection and water conditioning. In

general, potential impacts and mitigation measures associated with storage and use of hazardous chemicals are

similar to those for other industrial projects

Air emissions

Air emissions from water treatment operations may include ozone (in the case of ozone disinfection) and gaseous

or volatile chemicals used for disinfection processes (e.g., chlorine and ammonia). Measures related to hazardous

chemicals discussed above will mitigate risks of chlorine and ammonia releases. In addition, specific

recommended measures to manage air emissions include installation of an ozone-destroying device at the exhaust

of the ozone-reactor (e.g., catalytic oxidation, thermal oxidation).


7.2.2.3 Water Distribution

The most fundamental environmental health issues associated with distribution networks is the maintenance of

adequate pressure to protect water quality in the system as well as sizing and adequate maintenance to assure

reliable delivery of water of suitable quality. The most significant environmental issues associated with operation

of water distribution systems include:

Water system leaks and loss of pressure

Water system leaks can reduce the pressure of the water system compromising its integrity and ability to protect

water quality (by allowing contaminated water to leak into the system) and increasing the demands on the source

water supply, the quantity of chemicals, and the amount of power used for pumping and treatment. Leaks in the

distribution system can result from improper installation or maintenance, inadequate corrosion protection,

settlement, stress from traffic and vibrations, frost loads, overloading, and other factors.

Water discharges

Water lines may be periodically flushed to remove accumulated sediments or other impurities that have

accumulated in the pipe. Flushing is performed by isolating sections of the distribution system and opening

flushing valves or, more commonly, fire hydrants to cause a large volume of flow to pass through the isolated

pipeline and suspend the settled sediment. The major environmental aspect of water pipe flushing is the discharge

of flushed water, which may be high in suspended solids, residual chlorine, and other contaminants that can harm

surface water bodies.

7.2.2.3 Sanitation

A sanitation system comprises the facilities and services used by households and communities for the safe

management of their excreta. A sanitation system collects excreta and creates and effective barrier to human

contact; transports it to a suitable location; stores and/or treats it; and reuses it or returns it to the environment. In

addition to excreta, sanitation systems may also carry household wastewater and storm water. Transport, storage,

and disposal facilities may also manage wastes from industries, commercial establishments, and institutions.

Fecal Sludge and Septage Collection

In communities not served by sewerage systems, sanitation may be based on on-site systems, such as pit latrines,

bucket latrines or flush toilets connected to septic tanks. While pit and bucket latrines must be emptied frequently

(typically daily to weekly), solids that accumulate in septic systems (septage) must also be removed periodically,

usually every 2 to 5 years depending on design and usage to maintain proper function and prevent plugging,

overflows, and the resulting release of septic tank contents. If suitable facilities for storage, handling and

treatment of fecal sludge are not available, it may be indiscriminately dumped into the environment or used in

unhygienic manner in agriculture.


Sewerage

Where population density or local conditions preclude effective on-site sanitation systems (e.g., septic tanks and

drain fields), sewage is typically conveyed via a system of pipes, pumps, and other associated infrastructure

(sewerage) to a centralized storage and/or treatment system. Solids and liquids may be transported to a centralized

location, or sewage solids may be collected in and periodically removed from on-site interceptor tanks (see

Septage and Fecal Sludge Collection, above) while the liquids are transported to a centralized location for storage,

treatment, or disposal. Users of the sewerage system may include industry and institutions, as well as households.

Greywater (water from laundry, kitchen, bath, and other domestic activities that norma lly does not contain

excreta) is sometimes collected and managed separately from sewage. Though greywater is generally less polluted

than domestic or industrial wastewater, it may still contain high levels of pathogenic microorganisms, suspended

solids and substances such as oil, fat, soaps, detergents, and other household chemicals and can have negative

impacts on human health as well as soil and groundwater quality. The most significant potential environmental

impacts associated with wastewater collection arise from:

Domestic wastewater discharges

Industrial wastewater discharges

Leaks and overflows

7.2.2.4 Domestic Wastewater Discharges

Uncontrolled discharge of domestic wastewater, including sewage and greywater, into aquatic systems can lead

to, among other things, microbial and chemical contamination of the receiving water, oxygen depletion, increased

turbidity, and eutrophication. Wastewater discharge onto streets or open ground can contribute to spread of

disease, odors, contamination of wells, deterioration of streets, etc. Measures to protect the environment as well as

public health include:

Provide systems for effective collection and management of sewage and greywater (separately or

combined);

If greywater is managed separate from sewage, implement greywater source control measures to avoid

use and discharge of problematic substances, such as oil and grease, large particles or chemicals.

7.2.2.5 Wastewater and Sludge Treatment and Discharge

Sewage will normally require treatment before it can be safely discharged to the environment. The degree and

nature of wastewater and sludge treatment depends on applicable standards and the planned disposal or use of the

liquid effluent and sludge and the application method. The various treatment processes may reduce suspended

solids (which can clog rivers, channels, and drip irrigation pipes); biodegradable organics (which are consumed

by microorganisms and can result in reduced oxygen levels in the receiving water); pathogenic bacteria and other

disease-causing organisms; and nutrients (which stimulate the growth of undesirable algae that, as they die, can

result in increased loads of biodegradable organics). Wastewater discharge and use options include discharge to

natural or artificial watercourses or water bodies; discharge to treatment ponds or wetlands (including

aquiculture); and direct use in agriculture (e.g., crop irrigation). In all cases, the receiving water body use (e.g.


navigation, recreation, irrigation, or drinking) needs to be considered together with its assimilative capacity to

establish a site-specific discharge quality that is consistent with the most sensitive use.


include:

Liquid effluents

Solid waste


Hazardous chemicals

Ecological impacts

7.2.3 Social Impacts

The Potential Negative Impacts

Social impacts may emanate from the various Sanitation and Water services delivery activities under the GAMA

funded sub projects within the MMAs. The following are some of the potential social negative impacts:

7.2.3.1 Disruption of Utility Services

There will be interruption of utility services such as electricity and water and this will cause temporary disruption

of these services. Such disruptions will be a nuisance to the affected communities in the area. As far as possible

such connections would be carried out as soon as possible to reduce the inconvenience.

7.2.3.2 Dumping of solid waste and rubbish into the drains

Some unscrupulous residents will resort to anti-social practices whereby, rubbish and other solid waste matter will

be dumped into open drains, to await storm waters to wash them away.

7.2.3.3 Accidents

Work at water and sanitation facilities is often physically demanding and may involve hazards such as open

water, trenches, slippery walkways, working at heights, energized circuits, and heavy equipment. Work at water

and sanitation facilities may also involve entry into confined spaces, including manholes, sewers, pipelines,

storage tanks, wet wells, digesters, and pump stations. Methane generated from anaerobic biodegradation of

sewage can lead to fires and explosions.

7.2.3.4 Inconvenience to be caused due to delays in payment

Inconvenience, delayed payment and lower than market value payment for households whose lands are

expropriated by MMAs during access road upgrading.


7.2.3.5 Restricted Access to Source of Livelihood

The population staying or working next to the construction site will be temporarily inconvenienced by restricted

mobility.

7.3 MITIGATION MEASURES

Various mitigating measures are proposed below in order to ensure an efficient environmental management of the

construction and sustainability of the Sanitation and Water facilities provision. The mitigation measures are

proposed for the impacts identified under both the construction and post construction phases of the project.

7.3.1 Construction Phase Impacts

7.3.1.1 Air Quality

Dust pollution will be temporal since it will be restricted mainly to the constructional phase. However, all the

exposed surfaces will be watered regularly and finally tarred with bitumen in order to enhance dust suppression.

Moreover, all the exposed surfaces will be paved. Besides, transportation of raw materials will be covered with

tarpaulin to avoid dust blow and spills. In addition there will be speed limits for vehicles plying the road.

7.3.1.2 Noise and Vibration

To ensure that the noise generated during construction is not a nuisance to the residents of the neighbourhood,

constructional activities will be restricted to the daytime. In this way, the noise generated will be confined to

working machinery only and diffuse into the existing background noise. The plant and equipment that will be

used at the site will also be maintained and serviced regularly in order to ensure their smooth operation so as to

reduce the noise they generate. In addition, all heavy construction machinery must be equipped with appropriate

and functional noise suppresser (muffler).

7.3.1.3 Constructional Waste Management

Excavated soils will be stock piled and be transported elsewhere. In addition, the sand would be used to level

holes or pits created by the construction activities and landscape the area. Re-usable pieces of block will be

packed and used elsewhere. In addition, the site offices and stores of the contractors will be decommissioned and

the planks of wood and other materials, which could be used again, will be carted away and kept for other projects

elsewhere.

7.3.1.4 Occupational Health and Safety

The health and safety of the work force must be of paramount concern. Contractors will be required to adopt

extensive policies to minimise accidents and to improve the health and safety of its workers. This will be done

through the provision of protective clothing. All workers on site will be provided with helmets, Wellington boots,

ear plugs, nose pad and hand gloves to protect them from injuries. The use of protective clothing will be strictly

enforced.


Besides the provision of protective clothing, a first-aid kit stocked with enough drugs and materials will be

provided on site so that workers who unfortunately get injured or sick on the job would be given first aid.

However, workers who may sustain serious injuries will be given some initial treatment and rushed to the

Hospital for professional medical care.

In addition, provision for workers to include:

Proper management of sanitary wastes

Adequate supply of safe water

Adequate protection against dust and excessive noise

An education program is a component of occupational health and safety. An orientation on proper values

on safety and environmental awareness shall be inculcated among contractors and in turn among their

workers.

Furthermore, there should be in addition to the above:

Vehicle safety signals

Speed ramps

Loading and off-loading procedures

Only drivers with Vehicle license and permit are to drive

7.3.1.5 Adherence to specification and Environmental Standards by Contractors

MMAs shall be responsible for the strict compliance of its contractors and sub-contractors with the highest

standards of social responsibility and environmental management. Contractors shall be required to follow and

incorporates environmental mitigation measures. This is the basis for monitoring by the proponent’s MMA

Development Planning Subcommittee (or, where applicable, the Environment Management Committee). The

contractors shall also be responsible for the proper disposal of their wastes subject to monitoring.

.

Generally, concerns are raised about some contractors who do not observe the proper specifications in the civil

works, have no safety signs, etc. Stakeholders are interested to help monitor not only observance of commitments

on social and environmental compliance as a result of the Environmental Impact Statement, but would like to be

part of a mechanism that will review quality of civil works by eradicating leakage in the application and purchase

of materials. Such a mechanism may be strengthened or established if none yet exists. The appropriate

monitoring body should also address feedback on alleged corruption and poor implementation by contractors.

A policy may be issued whereby erring contractors may be blacklisted for using substandard specifications and

for not observing environmental guidelines, provided that they shall be released only upon proper compliance.

7.3.1.6 Social Problems from Work Sites

Social problems created by migratory workers in work sites areas should be discussed by contractors, local

officials and women representatives. The appropriate sanctions and enforcement mechanism, as agreed upon,

shall be made known to the workers. Concern about workers transmitting sexually transmitted diseases can be

addressed through worker education.


7.3.1.7 Housing and Sanitation for Non-Resident Workers

Priority shall be given to residents of those low-income areas for employment as a way to help regulate the in-

flow of migrant workers. On the other hand, there shall be proper planning of worker facilities. Necessary non-

resident workers shall be provided with housing facilities with adequate provisions for water and sanitation.

Malaria is endemic in the MMAs. There shall be schedules for measures of the workers’ camp for mosquito

control. Monitoring shall be done to ensure that solid wastes are properly disposed.

7.3.1.8 Addressing Fear of Non-Compensation

There may be homeowners, businesses, etc in proposed project areas and elsewhere who may be apprehensive

about non-compensation because they do not possess building construction permits. Awareness raising activities

and orientation meetings at MMA level, carried out by the MMAs, can address undue fears and facilitate

discussion on acceptable compensation packages. Details can be seen in the RPF report.

7.3.1.9 Resettlement

For sub projects that trigger a resettlement action plan (identified on the initial screening process), a resettlement

action plan (RAP) and /or an Abbreviated Resettlement Action Plan (ARAP), based on the guidelines provided in

the RPF, shall be prepared to make sure that all issues are settled satisfactorily and that any compensation package

for loss of livelihood, property, etc., is just and acceptable. Addressing concerns of vulnerable groups, e.g.

women-headed households, the poor and landless, shall consider the following:

Provision of adequate compensation and alternative opportunities and facilities for resettlement.

Preferential access to jobs and employment, credit and other related services.

A resettlement plan that complies with World Bank requirements

7.3.2 Post Constructional Phase impacts

7.3.2.1 Water Withdrawal

Measures to prevent, minimize, and control environmental impacts associated with water withdrawal and to

protect water quality include:

Evaluate potential adverse effects of surface water withdrawal on the downstream ecosystems and use

appropriate environmental flow assessment3 to determine acceptable withdrawal rates;

Design structures related to surface water withdrawal, including dams and water intake structures, to

minimize impacts on aquatic life.

Avoid construction of water supply wells and water intake structures in sensitive ecosystems;

Evaluate potential adverse effects of groundwater withdrawal, including modeling of groundwater level

changes and resulting impacts to surface water flows, potential land subsidence, contaminant mobilization

and saltwater intrusion. Modify extraction rates and locations as necessary to prevent unacceptable

adverse current and future impacts, considering realistic future increases in demand.


7.3.2.2 Water Treatment

Measures to manage solid wastes from water treatment include:

Minimize the quantity of solids generated by the water treatment process through optimizing coagulation

processes;

Dispose of lime sludges by land application, limiting application rates to about 20 dry metric tons per

hectare (9 dry tons per acre) to minimize the potential for mobilization of metals into plant tissue and

groundwater;

Dispose of ferric and alum sludges by land application, and if such application can be shown through

modeling and sampling to have no adverse impacts on groundwater or surface water (e.g. from nutrient

runoff). Balance use of ferric and alum sludges to bind phosphorous (e.g. from manure application at

livestock operations) without causing aluminum phytotoxicity (from alum), iron levels in excess of

adulteration levels for metals in fertilizers, or excessively low available phosphorous levels;

Potential impact on soil, groundwater, and surface water, in the context of protection, conservation and

long term sustainability of water and land resources, should be assessed when land is used as part of any

waste or wastewater treatment system;

Sludges may require special disposal if the source water contains elevated levels of toxic metals, such as

arsenic, radionuclides, etc.;

Regenerate activated carbon (e.g. by returning spent carbon to the supplier).

Wastewater

Measures to manage wastewater effluents include:

Land application of wastes with high dissolved solids concentrations is generally preferred over discharge

to surface water subject to an evaluation of potential impact on soil, groundwater, and surface water

resulting from such application;

Recycle filter backwash into the process if possible;

Treat and dispose of reject streams, including brine, consistent with national and local requirements.

Disposal options include return to original source (e.g. ocean, brackish water source, etc.) or discharge to

a municipal sewerage system, evaporation, and underground injection.


Hazardous Waste

Measures to prevent, minimize, and control potential environmental impacts associated with the storage, handling

and use of disinfection chemicals in water treatment facilities include:

For systems that use gas chlorination:

Install alarm and safety systems, including automatic shutoff valves, that are automatically activated

when a chlorine release is detected

Install containment and scrubber systems to capture and neutralize chlorine should a leak occur

Use corrosion-resistant piping, valves, metering equipment, and any other equipment coming in contact

with gaseous or liquid chlorine, and keep this equipment free from contaminants, including oil and grease

Store chlorine away from all sources of organic chemicals, and protect from sunlight, moisture, and high

temperatures

Store sodium hypochlorite in cool, dry, and dark conditions for no more than one month, and use equipment

constructed of corrosion-resistant materials;

Store calcium hypochlorite away from any organic materials and protect from moisture; fully empty or re-seal

shipping containers to exclude moisture. Calcium hypochlorite can be stored for up to one year;

Isolate ammonia storage and feed areas from chlorine and hypochlorite storage and feed areas;

Minimize the amount of chlorination chemicals stored on site while maintaining a sufficient inventory to

cover intermittent disruptions in supply;

Develop and implement a prevention program that includes identification of potential hazards, written

operating procedures, training, maintenance, and accident investigation procedures;

Develop and implement a plan for responding to accidental releases.

7.3.2.3 Water Distribution System Leaks and Loss of Pressure

Water System Leaks and Loss Pressure

Measures to prevent and minimize water losses from the water distribution system include:

Ensure construction meets applicable standards and industry practices;

Conduct regular inspection and maintenance;

Implement a leak detection and repair program (including records of past leaks and unaccounted- for

water to identify potential problem areas);


Consider replacing mains with a history of leaks of with a greater potential for leaks because of their

location, pressure stresses, and other risk factors.

Water Discharges

Recommended measures to prevent, minimize, and control impacts from flushing of mains include:

Discharge the flush water into a municipal sewerage system with adequate capacity;

Discharge the flush water into a separate storm sewer system with storm water management measures

such as a detention pond, where solids can settle and residual chlorine consumed before the water is

discharged;

Minimize erosion during flushing, for example by avoiding discharge areas that are susceptible to erosion

and spreading the flow to reduce flow velocities.

7.3.2.4 Sanitation

Measures to prevent, minimize, and control releases of septage and other fecal sludge include:

Promote and facilitate correct septic tank design and improvement of septic tank maintenance. Septic tank

design should balance effluent quality and maintenance needs;

Consider provision of systematic, regular collection of fecal sludge and septic waste;

Use appropriate collection vehicles. A combination of vacuum tanker trucks and smaller hand-pushed

vacuum tugs may be needed to service all households;

Facilitate discharge of fecal sludge and septage at storage and treatment facilities so that untreated septage

is not discharged to the environment.

7.3.2.5 Wastewater and Sludge Treatment and Discharge

Sewage will normally require treatment before it can be safely discharged to the environment. The degree and

nature of wastewater and sludge treatment depends on applicable standards and the planned disposal or use of the

liquid effluent and sludge and the application method. The various treatment processes may reduce suspended

solids (which can clog rivers, channels, and drip irrigation pipes); biodegradable organics (which are consumed

by microorganisms and can result in reduced oxygen levels in the receiving water); pathogenic bacteria and other

disease-causing organisms; and nutrients (which stimulate the growth of undesirable algae that, as they die, can

result in increased loads of biodegradable organics). Wastewater discharge and use options include discharge to

natural or artificial watercourses or water bodies; discharge to treatment ponds or wetlands (including

aquiculture); and direct use in agriculture (e.g., crop irrigation). In all cases, the receiving water body use (e.g.


navigation, recreation, irrigation, or drinking) needs to be considered together with its assimilative capacity to

establish a site-specific discharge quality that is consistent with the most sensitive use.


include:

Liquid effluents

Solid waste


Hazardous chemicals

Ecological impacts

7.3.2.6 Information Campaign/Public Hearing

An information campaign shall be undertaken to inform and get the feedback of the people on sub projects that

trigger EMPs and RAPs, its potential impacts and proposed mitigating measures. This can be in the form of a

public hearing or meetings to inform officials, traditional and community leaders, etc. In Ghana, a public hearing

is scheduled only if there are significant concerns against a project. On the other hand, meeting among

stakeholders can be a management tool to inform, clarify misconceptions, give feedback on proposed mitigating

measures to issues that were raised, plan for cooperative action – i.e. land use, traffic management,

implementation of MMAs Development Plan, etc. These can also be occasions to firm up recommendation on a

monitoring mechanism and as venues to reach consensus on outstanding issues.

Misconceptions about MMAs/Department of Urban Roads requirements for compensation without building

permits may be clarified or further discussed.

The officials and representatives of the various sectors of the population shall be properly briefed on their role in

the proper implementation of the Environmental Impact Assessment System in such phases as project planning,

implementation, and environmental and social impact monitoring and evaluation. This is designed to increase

stakeholder participation – host community, local governments, NGO, etc., role in environmental management

and social development in cooperation with the proponent. This can be part of the program during a public

hearing/meeting.

Information dissemination shall also be done on a regular basis to communicate the result of project monitoring.

Results of periodic monitoring shall also be given to the districts and localities.

7.3.2.7 Continuing Dialogues and Consultations on Resettlement

Consultations shall be conducted on site identification regarding the process of relocation, the terms of

compensation and other issues relative to resettlement. The negotiation of an acceptable package and the

settlement of important concerns may be settled through dialogue which shall be a continuing feature of problem

solving and cooperation among Department of Urban Roads, the local government and affected and host

populations.


7.3.2.8 Dissemination of Monitoring Results

Information dissemination is also done on a regular basis to communicate the result of project monitoring and

evaluation. In addition to the MMPCU, results of periodic monitoring shall be submitted to the assembly, which

shall be enjoined to disseminate critical information to their constituents and submit recommendations on the

resolution of issues when necessary.

7.3.2.9 Environmental Information and Awareness Raising Campaign

The MMAs should educate the general public through the local media to desist from dumping rubbish and other

solid waste matter into the open drains, a practice which prevents road side drains from functioning properly.

7.3.2.10 Prompt payment of Compensation

The time lag between field measurements of affected properties and preparation of compensation for the

beneficiaries by the Land Valuation Board should be reduced, as work sometimes had to be suspended pending

receipt of approval. Secondly, such delays tend to bring untold hardship to the affected persons (beneficiaries)

and a great inconvenience to both the Contractor and the Consultants on the project.

7.4 INTEGRATION OF THE EMP

Impact mitigation, Sanitation and Water Services improvement can be achieved through management and

monitoring programmes. This section outlines a programme that accomplishes environmental protection and

monitoring, as well as contributing to governmental strengthening of institutions.

7.4.1 Environmental Management

The critical point of any Sanitation and Water project is the implementation phase where the immediate

environment could be degraded or improved upon. The negative impacts identified as of potential concern relate

to the construction phase of the project. This implies that the activities of the Contractor, therefore, have a direct

impact on the environment. In order to be effective, environmental management must be fully integrated with the

overall project management effort, which in itself should aim at providing a high level of quality control.

Environmental Management is carried out during all stages of the project planning, design and implementation.

Environmental Protection can be achieved through the effective mitigation of anticipated adverse impacts or

drawbacks associated with the project and enhancement of the project benefits. To ensure that the mitigation

measures proposed are well implemented, an environmental management program is recommended.

7.4.2 Objectives of Program

Environmental management deals with how mitigation measures proposed are implemented and assign the

responsibility and costs, if appropriate, in its implementation. The programme has the following objectives:

Management of potential environmental impacts from water and sanitation facilities and related

activities, and vice versa;

Enhancement of water and sanitation facilities attributes, especially with regard to integrated local

development; and


Government institutional strengthening in conducting environmental protection and monitoring of water

and sanitation projects.

These objectives can be achieved through the following components of the environmental programme:

(a) MMPCUs will be engaged in the following:

Checking the progress of the Contractor in implementing the mitigation measures outlined in the

Contract documents and EIA report.

Liaising with an advisory group (e.g. EPA) regarding policies, procedures, contracts and approaches

for administering and monitoring environmental protection activities;

Coordinating parties involved in the impact mitigation and enhancement process, including:

Contractors, Consultants, Governmental and Non-Governmental Officials at all levels, as well as the

public;

Facilitating environmental monitoring and evaluation of the bio-physical and socio-economic

concerns pertaining to the Sanitation and Water Facility Projects;

Helping to administer resources designated for assistance at the local level; and

Conducting studies as well as performing other project related tasks.

(b) Contractor requirements for environmental protection to be implemented during the construction phase of

the project.

(c) The requirements of the Construction Supervision Consultant regarding monitoring during the period of

the project, (i.e. both construction and operation phases).

7.4.3 Resources for Programme Implementation

The resources required for implementing the environmental management programme are basically personnel and

finance. The key stakeholders in the environmental management activities are the members of the MMPCUs,

Environmental Management Subcommittee the Contractor, MLGRD and the public.

7.4.3.1 Pre-Construction Phase

If the screening process of a sub project triggers a RAP, EIA or ESMP, the following principles apply. Prior to

Contractor mobilization and the commencement of construction, environmental management will cover the

following:

Environmental review of the water and sanitation facility to be completed

Detailed EIA including Environmental Management and Monitoring Plan which will be developed by a

consultant on the basis of a ToR agreed with the MLGRD, but contracted by the respective MMA.

Works Department of MMAs, reparation of detailed designs which gives due consideration to

minimization of adverse impacts and benefit enhancement.


7.4.3.2 Construction Phase

Environmental management during the construction phase is essentially concerned with controlling impacts,

which could result from the activities of the Contractor. This can be done through the enforcement of Contract

Clauses relating to environmental protection. These clauses will not themselves, however, have any effect unless

they are fully implemented and enforced.

7.4.3.3 Operation and Maintenance Phase

Some of the impacts, which are expected to occur during the operational phase, are essentially related to the

design of the sub project. In this respect, the principal environmental management functions are the responsibility

of the design consultant. Matters relating to routine and periodic maintenance will be the responsibility of Works

Department of MMAs who will as well be responsible for the environmental management of the water and

sanitation facilities where relevant.

7.4.3.4 Responsibilities at MMA Level

The Project Phase

(i) Feasibility – Propose environmentally friendly project and design method.

Proposed a project requiring felling of the lowest feasible number of trees.

(ii) Detailed Design – Design the project for the least negative environmental impact during the operational

life of the project.

Design the project for environmentally friendly construction methods.

Design the project proscribing materials with the least negative environmental impact.

Incorporate any feasible safety measure within the project design

Design environmentally friendly projects with drainage systems.

(iii) Implementation Phase

Supervise and enforce the Contractor’s performance on all environmental requirements included in

the Contractor Documents.

Monitor the overall environmental impact of the project and recommend additional mitigation

measures for implementation when deemed necessary.

Liaise with the local health, traffic and educational authorities to plan agreed awareness raising

campaigns.

7.4.3.5 Responsibilities of the Contractor

The Project Phase

(i) Mobilization: Ensure that all staff, including managers and foremen are well informed about all

environmental issues of the project.

Train all site managers and foremen in environmentally friendly construction methods.

Ensure that all equipment mobilized fulfill the environmental requirements in the Contract

Documents.


Establish and maintain environmentally friendly construction camps well provided with sanitary

facilities.

Obtain necessary approvals for all burrow pits and quarries.

Establish a spoil and waste management plan comprising all types of wastes.

(ii) Project Implementation: Apply environmentally friendly equipment and construction methods.

Ensure occupational health and safety for all workers and visitors to the sites.

Inform the Supervisory Engineer if the occurrence of any unforeseen negative environmental impact

should occur.

(iii) Demobilization: Ensure that all affected project areas have been properly cleaned of waste, graded and

revegetated.

7.5 MONITORING

7.5.1 Construction Phase

The aim will be to assess the mitigation measures for noise, vibration, water quality, dust, air quality and public

safety using visual assessment by the management and feedback from the other stakeholder.

Transportation: Equipment, motor vehicles and transport of materials and personnel shall be closely monitored to

include the following activities:

Speed limits of vehicles

Motor vehicles condition and maintenance

Vehicle safety signals

Loading and off-loading procedures

Vehicle license and permit to drive, and

Kit for first aid and fire extinguisher

Civil Works: The monitoring criteria should include the following:

Working gear and protective clothing

Noise levels

Plant and equipment maintenance

Concrete works

Dust levels

Vehicular and pedestrian safety

Destruction/Disruption of Utilities

Socioeconomic/Cultural Issues

Wastes: Solid and liquid wastes which will be generated will have to be disposed off accordingly. These are

expected to include:

Vegetation

Solid wastes


Mud and top soil

Liquid waste from concrete works and pumping water from excavations

All wastes such as vegetation and mud will be sent to recognised dump sites or used to fill holes left

after construction of drains

7.5.2 Operation and Maintenance Phase

The monitoring plan will ensure that the negative impacts of the operation and maintenance of the upgrading of

water and sanitation facility are reduced to the barest minimum. This will guarantee the safety and health of the

employees and the public at large. This would include:

Cleaning/de-silting of the drains or removal of wastes from the drains

Monitor the regular watering of the un-tarred surface

Monitor speed of vehicles and traffic loads to assess the necessity for road upgrade

Repairs service pipes for water, drains and walkways

Hygiene education and education on the proper use of the facilities


8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

During the implementation of Sanitation and Water Project activities in the GAMA , potential environmental and

social impacts must be considered and managed. The impacts must be mitigated, minimized or preferably avoided

particularly to meet the requirements of World Bank safeguards policies and Ghana national law requirements.

The objective of the ESMF is to outline the institutional arrangements relating to: (i) identification of

environmental and social impacts arising from activities under the GAMA projects, (ii) the implementation of

proposed mitigation measures, (iii) Capacity Building and (iv) Monitoring.

The ESMP will be included in a manual of Operations. The ESMF outlines mechanisms for:

Screening of proposed sub-projects, identifying potential environmental and social impacts and

management of safeguard policies implications;

Institutional arrangements for implementation and capacity building

Monitoring ESMF measures implementation;

Public consultation;

The estimated costs related to the ESMF.

8.1 THE ENVIRONMENTAL AND SOCIAL SCREENING PROCESS

A screening process, selection and evaluation of GAMA projects are required to manage environmental and social

aspects of these activities. The sections below show the various stages of this environmental and social screening

process:

i. Screening: identify actions that have negative environmental and social impacts;

ii. Determination of environmental categories: identify appropriate mitigation measures for activities with

adverse impacts;

iii. Implementation of environmental work: activities that require separate EIA;

iv. Review and approval of the selection.

v. Dissemination of EIA.

vi. Supervision and monitoring

These steps are explained in the following paragraphs and incorporate those responsible for implementing each

step. The stakeholders identified and their roles are developed in detail in the chapter "Strengthening institutional

capacity”.

The screening process determine which project and sub-project activities are likely to have negative

environmental and social impacts; to determine appropriate mitigation measures for activities with adverse


impacts; to incorporate mitigation measures into the project as appropriate and to monitor environmental

parameters during the implementation of activities.

The extent of environmental assessment that might be required prior to the commencement of the projects will

depend on the outcome of the screening process. The seven stages of the environmental and social screening

process leading to the review and approval of the GAMA project activities to be implemented are described

below.

8.1.1 The Screening Process

The purpose of the screening process is to determine whether sub-projects are likely to have potential negative

environmental and social impacts; to determine appropriate mitigation measures for activities with adverse

impacts; to incorporate mitigation measures into the sub-projects design; to review and approve sub-projects

proposals and to monitor environmental parameters during implementation. The extent of environmental and

social work that might be required for the projects prior to implementation will depend on the outcome of the

screening process. This process should include screening for possible resettlement impacts.

Table 8-1: Structures involved in the GAMA Environment and Social Management

Intervention

level

Environmental structures Comment Other environmental

stakeholder

MMAs Metropolitan/Municipal

Planning and Coordinating

Unit(M/MPCU)

Metropolitan/Municipal

Works Unit

Regional EPA Officers

(EPA)

Functional NGO

National EPA, MLGRD Functional MWRWH, Ghana Water

Company Limited, Community

Water and Sanitation

(CWSA),Lands

Commission/Land Valuation

MLGRD/PCU Functional Environment and Social

Officer

MLGRD

M&E officer


Step 1 Screening of Sub-projects

The screening process is the first step in the ESMF process. One of the objectives of the screening process is to

rapidly identify those subprojects which have little or no environmental or social issues so that they can move to

implementation in accordance with pre-approved standards or codes of practices or other pre-approved guidelines

for environmental and social management.

For each sub-project proposal the MMA, led by the Planner, will carry out a screening process. The Planning

Officer will complete the Environmental and Social Screening Form (Annex 2b) and submit to the MMPCU for

review as part of the project package. Completion of this screening form will facilitate the identification of

potential environmental and social impacts, determination of their significance, assignment of the appropriate

environmental category, proposal of appropriate environmental mitigation measures, or recommend the execution

of an Environmental Impact Assessment (EIA), if necessary.

Step 2: Determination of appropriate environmental categories

Act 490 created a corporate body called the Environmental Protection Agency (the Agency) to replace the

Environmental Protection Council, which was created under NRCD 239. Among its functions, the Agency was

mandated:

“... to ensure compliance with any laid down environmental assessment procedures in the planning and

execution of development projects, including compliance in respect of existing projects,” section 2(i).

Under section 12 (1) of the Act, the Agency:

“... may by notice in writing require any person responsible for any undertaking which in the opinion of the

Agency, in respect of the undertaking, an environmental impact assessment containing such information

within such period as shall be specified in the notice.”

Section 28 of the Act deals with Regulations. It provides under subsection 2(b) that regulations may be made to

provide for:

“... the category of undertakings, enterprises, constructions or developments in respect of which

environmental impact assessment or environmental management plan is required by the Agency.”

In order to meet the immediate demand imposed by section 2 (i) of Act 490, the Ghana EIA Procedures were

developed, published and launched in 1995. The procedures formed the basis for the Environmental Assessment


LI 1652 follows in broad terms, the procedures for the preparation of an environmental assessment report. It

provides a graduated system for determining what will be demanded from a proponent on the basis of the size and

likely impacts of a particular project. On receipt of an application, including such information as may be required;

the Agency will carry out an initial assessment taking into consideration factors such as:

Location, size, and likely output of the undertaking;


Technology intended to be used;

Concerns of the general public, if any, and in particular concerns of immediate residents if any; and

Land use, and other factors of relevance to the particular, undertaking to which the application relates.

To enable the Agency make a determination as to the level of environmental assessment of any undertaking, the

applicant must submit to the Agency a report on the undertaking and indicate in the report:

The environmental, health and safety impact of the undertaking;

A clear commitment to avoid any adverse environmental effects which can be avoided on the

implementation of the undertaking;

A clear commitment to address unavoidable environmental and health impacts and steps where necessary

for their reduction; and

Alternatives to the establishment of the undertaking.

Where the Agency is satisfied with an initial screening, it registers the activity which is the subject of the

application and issues an environmental permit.

Since the coming into force of LI 1652, the EIA procedures have been applied fully and effectively to both

privately and publicly funded undertakings. The Agency is responsible for the implementation of the Regulations.

SCHEDULE 2 OF LI 1652

The Regulations prohibit the commencement of various undertakings listed in a schedule without prior

registration with the EPA and the issuance of a permit. The activities listed in Schedule 2 of the Regulations, fall

within the ambit of the activities for which an environmental impact assessment is mandatory. Among the

activities listed in schedule 2 under waste treatment and disposal are the following:

Construction of incineration plant;

Construction of recovery plant (off-site);

Construction of wastewater treatment plant (off-plant);

Construction of secure landfills facility; and

Construction of storage facility.

The undertakings under municipal solid waste that are subject to full EIA are:

Construction of incineration plant;

Construction of composting plant;

Construction of recovery/recycling plant;

Construction of municipal solid waste landfill facility; and

Construction of waste depots.

REPORTING UNDER L.I. 1652

The Regulations provide for a number of reports. These are:

Screening report;

Preliminary environmental report;


Scoping report;

Environmental Impact Statement; and

Annual environmental report.

SCREENING REPORT

The screening report is prepared at the earliest stages of the EIA process and allows a determination to be made

by the Agency about the level of environmental assessment of a particular undertaking.

PRELIMINARY ENVIRONMENTAL REPORT

In some instances, the Agency may come to the conclusion that an activity requires a preliminary environmental

report (PER). Where such a decision is arrived at, the applicant would be required to submit a PER. The PER will

contain details extending beyond that contained in the initial application. The new application must state

specifically the detailed effects of the proposed undertaking on the environment. Where a PER is approved, it is

registered and an environmental permit is issued.

In the event that on receipt of a PER the Agency is satisfied that there will be a significant and adverse impact on

the environment, the applicant will be expected to submit an environmental impact statement (EIS) on the

undertaking for assessment of the environmental impact of the proposed undertaking.

SCOPING REPORT

The Regulations require that the EIS shall be outlined in a scoping report. The scoping report sets out the scope or

extent of the EIA to be carried out by the applicant and includes draft terms of reference (TOR) which must

indicate the essential issues to be addressed in the EIS.

Among the issues that the draft TOR must address are the following:

Identification of existing environmental conditions;

Information on potential, positive and negative impacts from the environmental, social, economic and

cultural aspects in relation to the different phases of development of the undertaking;

Potential impact on health of people;

Proposals to mitigate any potential negative socio-economic, cultural and public health impacts of on the

environment;

Proposals for monitoring predictable environmental impact and proposed mitigating measures;

Contingency plans;

Consultation with members of the public likely to be affected by the operations of the undertaking;

Provisional environmental management plan; and

Proposals for payment of compensation for possible damage to land or property arising from the

operation of the undertaking.

On the acceptance of a scoping report by the Agency, the applicant is informed to submit an EIS based on the

scoping report


ENVIRONMENTAL IMPACT STATEMENT

The EIS must address potential direct and indirect impact of the undertaking on the environment at the pre-

construction, construction, operation, decommissioning and post-decommissioning phases. Among the items to be

addressed are the following:

Concentration of pollutants in environmental media including air, water and land from mobile or fixed

sources;

Alteration in ecological processes such as transfer of energy through food chains, decomposition and

bioaccumulation which could affect any community, habitat or species of flora and fauna;

Ecological consequences of direct destruction of existing habitats from activities such as dumping of

waste and vegetation clearance and fillings;

Noise and vibration levels;

Odour; and

Additionally, changes in social, cultural and economic patterns must be dealt with in relation to the following:

Decline in existing or potential use arising out of matters referred to above;

Direct or indirect employment generation;

Immigration and resultant demographic changes;

Provision of infrastructure such as water and sanitation facilities;

Local economy;

Cultural changes including possible conflict arising from immigration and

ANNUAL ENVIRONMENTAL REPORT

A person granted an environmental permit under the Regulations is required to submit an annual environmental

report in respect to his undertaking after 18 months from the date of commencement of his operations and

thereafter on a 12 monthly basis to the Agency. The EPA is required to define the form and content of the Annual

Environmental Report.

PUBLIC CONSULTATION

Public participation is provided for in the Regulations. These provisions are secured through advertisement of the

scoping notice for comments and public hearings.

There is a Technical Review Committee that reviews Environment Impact Statements (EISs) prior to permitting

of all undertakings for which EIAs are required. The membership of this committee is constituted on the

discretion of the Agency through the use of administrative procedures.

Based on screening results, the appropriate environmental category for the GAMA proposed activity will initially

be determined by the Planner in the screening form, the rating and screening form will be reviewed by the

MMPCU and confirmed by the Statutory Planning Committee. After determining the correct environmental

category, he/she will determine the extent of environmental work required.


The distribution of appropriate environmental categories draws on provisions contained in the document OP 4.01

of World Bank on environmental assessment as well as Ghana EPA EA Procedures. The determination of

environmental categories of subprojects GAMA will be as follows:

If the screening form contains only the entries 'No or Not Applicable (NA) in the entries then' environmental

category C applies which indicates that environmental impacts and social issues are considered minor and do not

require mitigation. For example, some rehabilitation activities (minor repairs, etc.) could be classified as C;

The distinction between categories will be determined based on the implications of the Safeguard Policies as

stated in the instructions below. Table 8.2 summarizes the environmental work to be performed by classification

category of activity.

Table 8-2: Category of Environmental Studies

Sub-project Category Environmental work to be implemented

Category A Project

Projects in this category will require full EIA

Project Category B requiring an environmental and /

or social assessment

- Identify and assess potential environmental impacts of the

subproject;

- Prepare the ToR for the EIA (Cat. B);

-EIA prepared by a consultant

- To the EIA by service providers;

- Review and approve the EIA.

Implement all mitigation, institutional and monitoring

measures during implementation and operation of

achievements to eliminate, reduce or mitigate

environmental and social impacts

Project Category C

No environmental assessment is required

Step 3: Implementation of environmental and social work

The results of the determination of step 2 for both cases in (b), the following environmental work will be

performed:

Sub-projects of Category B – Separate Environmental Impact Assessment (EIA)

The planning and implementation of environmental work including the EIA are described in the box below. The

MMA prepares the Terms of Reference for the EIA, the recruitment of consultants for EIA will be conducted by

the MMAs.


To determine mitigation measures for inclusion in the sub-project TOR, the elements of the mitigation measures

section below (the impacts and associated mitigation measures) organized as a checklist will serve as the basis. In

addition, TOR must verify that the contents of ESMP sub-projects comply. To facilitate the formulation of TOR,

a TOR-type has been prepared and placed in the appendix.

The EIA will identify and evaluate potential environmental impacts for the proposed activities, evaluate

alternatives, and design mitigation measures. The preparation of the EIA will be done in consultation with

stakeholders, including people who may be affected. Public consultations are critical in preparing a proposal for

the activities of the GAMA likely to have impacts on the environment and population. The public consultations

should identify key issues and determine how the concerns of all parties will be addressed in the EIA. When an

EIA is necessary, the administrative process enacted by the EPA will be followed and executed.

Table 8-3: Procedures for EIA

Procedures for sub-projects requiring an EIA

First step: Preparation of Terms of Reference

The results of identification, and extent of the EIA (scoping), the terms of reference will be prepared

by the MMA in collaboration ESO at MLGRD.

Second step: Selection of consultant

Third stage: Preparation of the EIA with public consultation

The report will follow the following format:

Description of the study area

Description of the subproject

Discussion and evaluation of alternatives

Environment description

Legal and regulatory

Identifying potential impacts of proposed sub-projects

Process of public consultations

Development of mitigation measures and a monitoring plan, including estimates of costs and

responsibility for implementation of surveillance and monitoring

Step Four: Review and approval of the EIA for the sub-project; Publication / Dissemination of EIA

Step 4: Review and approval of EIA

The proponent submits the final draft EIA to EPA. The report is reviewed by the MMA and by the EPA.

Copies of the EIA are placed at vantage points including the EPA Library, relevant MMA, EPA Regional Offices.

EPA serves a 21-day public notice in the national and local newspapers about the EIA publication and its

availability for public comments.

Step 5: Public Hearing and Environmental Permitting Decision (EPD)

Public Hearing

Regulation 17 of the LI 1652 specifies three conditions that must trigger the holding of a public hearing on a

project by the Agency. These are:


Where a notice issued under regulation 16 results in great public reaction to the commencement of the

proposed undertaking;

Where the undertaking will involve the dislocation, relocation or resettlement of communities and

Where the Agency considers that, the undertaking could have extensive and far -reaching effects on the

environment.

Where a public hearing is held, the processing of an application may extend beyond the prescribed timelines

required for EPA’s actions and decision-making.

Environmental Permitting Decision (EPD)

Where the draft EIA is found acceptable, the proponent is notified to finalise the report and submit eight hard

copies and an electronic copy. Following submission to EPA, the proponent shall be issued an Environmental

Permit within 15 working days and issue gazette notices.

Where the undertaking is approved, the proponent shall pay processing and permitting fees prior to collection of

the permit. The fees are determined based on the Environmental Assessment Fees Regulations, 2002, LI 1703.

Step 6: Environmental Monitoring

Environmental monitoring aims to ensure compliance with: (i) the measures proposed in the ESMP and the EIA

of a sub-project, including mitigation measures, (ii) the commitments of Contractor in connection with the

permissions required, (iv) requirements relating to laws and regulations.

Environmental monitoring involves both the construction phase and the operation phase. The monitoring program

may allow, if necessary, to reorient the work and possibly improve the course of the construction and

implementation of different project components. Monitoring goes hand in hand with the establishment of impacts

and proposed measures for prevention, mitigation.

Monitoring is essential to ensure that: (i) the impact predictions are accurate (monitoring effect), (ii) prevention /

mitigation can achieve the desired objectives (monitoring effect), (iii) regulations and standards are met

(compliance monitoring), (iv) the criteria for use of the environment are respected (inspection and monitoring).

Environmental monitoring of GAMA activities will be conducted under the project general system of monitoring.

It will be done at two levels:

Performance monitoring at central level:

At central level, the GAMA will involve MLGRD.

Implementation of monitoring at local level /MMAs:

At the MMAs level, monitoring will be conducted by the MMPCU and Regional EPAs.


The tracking system relies on a set of sheets to prepare and submit to ensure that all recommendations regarding

environmental and social issues, mitigation and strengthening measures are applied. For monitoring, these reports

can be:

- A verification form: on the basis of individual project impacts and measures laid down a plan for

verification of their implementation is adopted.

- A control form: it is used to detect non-compliance with environmental requirements, potential

environmental risks unreported among impacts. This leads to demands for compliance and

implementation of preventive action.

Step 7: Development of Monitoring Indicators

Monitoring measures will focus on key indicators to be defined considering both the positive and negative

impacts of the projects. The monitoring indicators will be parameters which will provide quantitative and / or

qualitative information on the direct and indirect impacts of the GAMA environmental and social benefits. The

choice of indicators will be guided by the characteristics of relevance, reliability, usefulness and measurability.

To evaluate the effectiveness of mitigation measures of GAMA activities impacts, we propose to use the

indicators listed in the table below. Environmental guidelines for firms serve as indicators.


MMPCUs.. The environmental monitoring and supervision program for the implementation of the GAMA will

serve as an integral part of the operational activities of MLGRD and will generate the requisite information for

environmental management and environmental information dissemination and public disclosure.

The following monitoring indicators are proposed for assessing the efficiency of the mitigation measures:

Safe waste management related to construction works

Compliance with the MWRWH/EPA Environmental Guidelines for Contractors

Best practice in the implementation of project activities.


Table 8-4: Process Monitoring Indicators of ESMP Measures


Technical

measures

(studies)

-Conducting Environmental Impact


-Develop a health and safety plan

-Develop the TOR

-Number of ESIAs/ESMPs/ Health Safety Plans submitted

for each sub-project in a MMDA

-Number of study elaborated

Measures for

monitoring and

evaluating

projects

Perform monitoring and evaluation

ESMP (continuous monitoring, mid-

term and annual assessment)

-List of indicators identified for all sub-projects as may

stipulated under the environmental permitting conditions

-Number of monitoring missions for all sub-projects

-Number of monitoring reports submitted for all sub-

projects

Institutional

measures

Engage existing Environmental Units in

the MMAs

-Develop a TOR for the Environmental unit

-Environmental Units are functional in MMAs

Awareness and structured Training for

staff of MLGRD and MMAs working

on the GAMA

-Number of EA trainings conducted for staffs in MMAs

-number of attendance (male/female) at EA trainings

-Number of awareness trainings conducted before, during

and after project implementation in each MMA

-Number of staff tin attendance at the awareness trainings

(Male/Female)

Awareness

Awareness about HIV / AIDS

Communication campaign and

awareness before, during and after

construction

-Number of sub-project sites with adequate posters


Table 8-5: Indicators and Monitoring Mechanism of Environmental and Social Issues

Elements of

monitoring and

indicator

Methods and devices for monitoring Responsible Period

Water

Pollution

- Follow up of procedures and facilities for the

disposal of liquid wastes

- Monitoring of groundwater and surface water

around project site

- Monitoring surface water using activities

MMPCUsand Regional

EPAs

Start, mid-term and end

of

Rehabilitation /

construction activities

operating infrastructure

Soils

Erosion / gulling

Pollution /

degradation

- Visual assessment for soil erosion

- Availability of approved applications to open

career

- Availability of career opening statements

- Verification of suitable measures for the

management of lubricants / Diesel/ used oils

MMPCUs and Regional

EPAs


of activities

Vegetation /

Wildlife

Degradation rate of

reforestation

- Visual assessment of reforestation / plantation

measures

- Controls on clearing

- Control and monitoring of sensitive areas

- Control of attacks on wildlife

Forest

Commission/Parks and

Gardens


of activities

Human

environment

Hygiene and health

Pollution and

nuisances

Safety in

construction sites

- Hiring local labor priority

- Respect the heritage and sacred sites

- Monitoring the level of noise at construction

site

- Follow-up measures to reduce dust

- Verification of the use of landfill sites licensed

for construction waste

- Truck noise

MMPCUs and Regional

EPAs


of activities

Verification:

- Of disease vectors presence and the onset of

diseases related to work

- Diseases associated with various projects (HIV

/ AIDS, etc..)

- Respect of hygiene measures on the site

- Monitoring management practices of liquid

and solid waste (whole chain)

- Existence of liquid and solid waste

management plan and necessary equipment

- Existence of health and safety plan

MMPCUs and Regional

EPAs


of activities

operating infrastructure

Verification:

- Availability of safety guides in case of

accident

- Availability of appropriate signage

- Compliance with traffic regulation

- Respect the speed limit

- Appropriate protective equipment wearing

Works Department of

MMPCUs/Regional

EPAs

Monthly


8.1.2 Responsibilities for the Implementation of the Screening Process

The ESMF will be implemented by MLGRD. MLGRD will collaborate with the EPA and the World Bank to

ensure effective execution. Table 8.6 provides a summary of the stages and institutional responsibilities for the

screening, preparation, assessment, approval and implementation of the GAMA activities.

The extent of environmental assessment that might be required prior to the commencement of the sub-projects

will depend on the outcome of the screening process. The key stages of the environmental and social screening

process leading to the review and approval of the GAMA activities to be implemented are described below:

Table 8-6: Summarized Environmental Screening Process and Responsibilities

Stage Management

responsibility

Implementation responsibility

1. Screening Environmental and Social Sanitation and

Water Project: Selection including public consultation

MLGRD/MMAs MMPCU Planning Officer2

2. Determination of appropriate environmental

categories

2.1 Selection validation

MMPCU, Planning Officer

2.2 Classification of Project

Determination of Environmental Work

Review of screening

MLGRD/MMAs

EPA, MMPCU and Planning

Officer

3. Implementation of environmental work MLGRD/MMAs MMPCU and Planning Officer

in the MMAs,

3-1. If EIA is necessary MMPCU

3.1.a Preparation of terms of reference MLGRD/MMA

MMPCU

3.1 b Selection of Consultant MLGRD MMA

3.1 c

Realization of the EIA, Public Consultation

Integration of environmental and social management

plan issues in the tendering and project implementation,

MMPCU/MLGRD

Procurement and

Works Department

Units of MMAs/

MLGRD

Environmental Consultant


4 Review and Approval

4.1 EIA Approval EPA EPA, , World Bank

5. Public Consultation and disclosure MLGRD/EPA


6. monitoring /MMAs/EPA


7 Development of monitoring indicators for EIA as

may be stipulated under tbe environmental

permitting conditions.

MLGRD MMPCU and Planning Officer

2 If necessary, the MPCU can assign a designated, capable officer to carry out the screening process if MPCU sees that need.

However, the planning officer will still be the final signatory to the screening format.


8.2 MITIGATION MEASURES

8.2.1 General mitigation measures

Environmental mitigation consists of measures that can reduce the negative environmental impacts associated

with implementation (construction, expansion, rehabilitation etc) of the project. Mitigation measures have been

identified that would reduce both existing and potential impacts associated with GAMA activities. Potential

impacts and the mitigation measures are identified in Table 8.7.

Tables 8.7 and 8.8 below indicate the areas to which the potential impact applies. In addition, mitigation measures

are identified as either social or physical measures. Social mitigation includes the measures used to mitigate

effects such as noise and other effects to the human environment. Physical mitigation includes measures that

address impacts to the physical environment, such as vegetation, air quality, and others. The measures serve as

the basis for the cost estimates.

Design Measures

The quantities, specifications and estimated costs of design measures to avoid or mitigate negative impacts will be

assessed by the civil design contractor and incorporated into the bidding documents. The contractor will execute

all required works and will be reimbursed through pay items in the bill of quantities, which will be financed by

the project.

Table 8-7: General Mitigation Measures

Measures Proposed actions

Technical measures

- ESIA / ESMP Studies

Construction and

operational measures

- Conduct a communication campaign and advocacy before construction work

- Ensure compliance with hygiene and security in facilities sites

- Undertake the marking of site under construction site

- Use the local workforce as a priority

- Ensure adherence to safety rules at work

- Ensure the collection and disposal of waste arising from work

- Provide the project accompanying measures (connection to water networks, electricity and

sanitation, equipment, program management and maintenance)

- Conduct awareness campaigns on HIV / AIDS

- Engage closely MLGRD services in monitoring the implementation

- Rehabilitate quarries and other sites for loans

- Respect of protected species including trees

- Management of Environmental and Health Hazards.

DRAFT ESMF of GAMA for MLGRD, Ghana, December, 2012 - 74 -

8.2.2 Specific construction impacts mitigation measures

Table 8-8: Summary of Environmental Mitigation Measures

Potential Impacts Recommended Mitigation Measures

Physical

Land Use

Noise

Employees and communities exposed to high noise level

Disturbance of during construction works

Installation of sound insulation.

Schedule work periods to avoid peak hours

Air Quality

Emission of pollutants from mobile (vehicles) and stationary (mixers, etc)

sources.

Air pollution from burning of demolition wastes e.g. wood, paper etc

Introduction of dust reduction measures in construction sites

Safety measures put in place

Soil

Point source contamination from diesel, lubricants etc around workshop

areas.

Increased soil erosion due to vegetation clearing , soil trampling and

compaction

Increased rapid runoff due to vegetation clearing and soil compaction

diminishing infiltration capacity

Deterioration of soil characteristics due to increased erosion

Appropriate containment measures for all operational areas and proper

disposal of used lubricants.

Soil erosion control measures (e.g. reforestation, reseeding of grasses,

land preparation, terracing etc)

Water Quality

Potential pollution of surface and ground water though runoff of

pollutants e.g. lubricating oil, diesel fuel etc from workshop areas etc

Water pollution due to seepage from tanks (diesel, sanitary wastes etc)

Lack of water for sanitation or toilet facilities

Heavy water usage resulting in reduction of surface and groundwater

sources

Appropriate containment measures for all operational areas and proper

disposal of used lubrication oil.

Work sites Installed far from waterways

Regular collection of work sites wastes for proper disposal

Liquid waste discharged at designated outfalls after effluent treatment to

protect water resources

Regular emptying of on-site latrines and toilets

Biological Resources

Vegetation

Vegetation clearing resulting in loss of valuable habitat, species diversity

and population levels.

No siting and excavations in sensitive habitat

Careful planning and selection of sites

DRAFT ESMF of GAMA for MLGRD, Ghana, December, 2012 - 75 -

Impacts on protected areas; critical habitats for rare species or of ecologic

or domestic importance.

Forests and cultural heritage sites protection enforced.

Wetlands

Expansion and new construction encroaching on the wetland and directly

impact wetland plant communities.

Preservation, restoration, and enhancement of existing wetland.

Sensitive and critical habitats avoided

Solid/Hazardous Waste Management

Solid waste generated from demolition and construction activities

containing potentially hazardous materials (e.g. asbestos).

Waste generation during construction works

Quick sorting, collection and disposal of waste removed from the sites in

accordance with applicable regulations.

Social

Health and Safety

Risks of road accidents during work

Contamination risk by HIV from the labour force.

Conduct an awareness raising campaign for the work sites staff and the

users of Sanitation and Water Facilities or services under

construction/rehabilitation

Conduct awareness raising campaigns on HIV/AIDS

Land Use

Involuntary displacement of populations or economic activities

Changes of existing uses within affected communities.

Acquisition and relocation should occur in accordance with World Bank

OP/BP 4.12 Involuntary Resettlement.

Avoid facilities in areas that will need resettlement, the displacement; or

the encroachment on historic, cultural or traditional use areas

DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 76 -

8.3 MONITORING PLAN

The objective of the monitoring plan is to establish appropriate criteria to verify the predicted impact of the

project, and to ensure that any unforeseen impacts are detected and the mitigation adjusted where needed at an

early stage. It is expected that the proposed water and sanitation project will lead to Increased affordability of safe

water for the population, increased access to safe water, Reduced rate of water related diseases, Improved Health

and social development and POVERTY REDUCTION.

The plan will ensure that mitigating measures are implemented during rehabilitation, upgrading and maintenance.

Specific objectives of the monitoring plan are to:

Check the effectiveness of recommended mitigation measures;

Demonstrate that sub-project activities are carried out in accordance with the prescribed mitigation measures

and existing regulatory procedures; and

Provide early warning signals whenever an impact indicator approaches a critical level.


Planning Officers (POs) and the Environmental Health Officers (EHOs) in collaboration with the MLGRD.

Monitoring will be conducted during all phases of the project.

The MMA Planning Officer will prepare a long term monitoring strategy that will encompass clear and definitive

parameters to be monitored for each sub-project. The monitoring plan will take into consideration the scope of

development, the environmental and social sensitivity and the financial and technical means available for

monitoring. The plan will identify and describe the indicators to be used, the frequency of monitoring and the

standard (baseline) against which the indicators will be measured for compliance with the ESMP.

A number of indicators would be used in order to determine the impact of the sanitation and water project with

respect to increased employment, improved use of water and sanitation, greater equity in allocation of water and

increased affordability of water and sanitation, reduction in waterborne deseases etc. Key monitoring indicators to

measure these outcomes or results are presented in the table 8.9.

Other considerations to determine the status of the affected environment are as follows:

- Has the pre-project human and natural environmental state been maintained or improved through the

provision of the sanitation and water facilities and;

- Has the effectiveness of the ESMF technical assistance, review, approval and monitoring process been

adequate to pre-empt and correct negative impacts inherent in certain types of Sanitation and Water

Sanitation and Water Facilities projects?

- Environmental Indicators: Loss of vegetation; Land degradation; Compliance with Legislations.


Table 8-9: Results and Indicators for the Sanitation and Water Sector

Result/Outcome Indicators

1. Availability of water

- Change in water levels for lakes, rivers and water table

2. Preservation of water

- Area of protected wetlands, lakes and rivers

3. Irrigation requirements

- Amount of water needed to produce xm² of x food

4. Water leakages

- % of water lost through water systems due to leakages

5. Recycling of water

- Amount of sanitation water that is recycled

- Amount of water used in industry that is recycled

6. Employment resulting from water and

sanitation construction and maintenance

- Number of people directly and indirectly employed in water and

sanitation construction and maintenance projects

7. Pollution of water and soil

- Levels of chemicals, minerals, metals, pesticides etc in soil and water

(surface and ground water).

8. Treatment of waste water

- Proportion of domestic, agricultural and industrial waste water that is

treated before being discharged

9. Equity in domestic water and sanitation

allocation

- Rate of connection to water/sanitation network for slums/shanty towns

compared to national average

- Level of rural poor connection to water/sanitation network compared to

national average

10. Equity in allocation of water between

sectors

- Implementation of transparent public or public/private mechanisms to

allocate water

11. Household expenditure on water and

sanitation

- x% of household expenditure on water and sanitation by each income

group in society

12. Cost of water for businesses

- Water as a x% cost of agricultural value

- Water as a x% cost of industrial value

SPECIFIC IMPACTS INDICATORS

13. water and sanitation hygiene awareness - Improved collection and storage of drinking water

- Proportion of people hand washing

- Use of hygienic sanitation facilities

14. Domestic access to safe water (inc. time

savings)

- Number of households connected to water network for x months of year

- Number of households within 1km of safe water for x months of year

- Number of households who receive more than 20 litres of water

per day

15. Business access to water

- x% of agricultural water needs meet for x months of the year

- x% of industrial water needs meet for x months of the year

16. Access to basic sanitation

- Number of people with access to basic sanitation


8.4 RESPONSIBILITY AND INSTITUTIONAL ARRANGEMENT FOR IMPLEMENTATION AND MONITORING

8.4.1 Institutions responsible for implementation

The institutions responsible for implementation of ESMP activities are described below:

Table 8-10: Institutions Responsible for Implementation of ESMP

Measures Areas of intervention

Structures Responsible

Execution Supervisi

on

Oversight

Mitigation

measures

Mitigation of negative impacts of

construction and rehabilitation

(environmental monitoring)

Firms and

MMAs

MMA

ESO, MLGRD

and MPCU

Technical

measures

Conducting Environmental Impact


Consultant MPCUs ESO, MLGRD

Elaboration of health and safety plan Firms MMAs ESO

ESMP implementation assessment

(permanent, at mid-term and final)

Consultants

and ESO ESO

MLGRD

Training

Subprojects environmental and social

assessment,

Monitoring and enforcement of


Local NGOs ESO

MLGRD

SPECIFIC/INTERMEDIATE IMPACT INDICATOR

17. Business productivity

- x% change in food production/yield and processing costs

x% change in industrial production costs

INTERMEDIATE IMPACT INDICATORS

18. Sustainable extraction of water

- Annual extraction of from surface and ground water, in relation to its

minimum annual recharge (i.e. water balance sheet)

19. Rate of water borne diseases

- Inflection rates for diseases such as diarrhoea, intestinal worms,

parasitic infections etc.


Measures Areas of intervention

Structures Responsible

Execution Supervisi

on

Oversight

Awareness

Communication campaign and awareness

before, during and after construction

(HIV) (optional)

Execution Supervisi

on

Oversight

8.4.2 Project Institutional and Implementation Arrangements

As part of the institutional arrangements, MLGRD will recruit an ESO that will be responsible for following up

safeguards issues during project implementation. MLGRD will be responsible for (i) preparing TORs for the

ESIA/EMP and RAP/ARAP if needed (ii) supporting MMAs in ensuring the contractors comply with the

recommendations of these studies and environmental and social management clauses (inserted into the contract)

during construction phase. The Bank will provide guidance on the elaboration of the TORs and the Ghana

Environmental Protection Agency (EPA) will be responsible for providing overall quality control through the

review and clearance of the ESIAs , and validating the Environmental Audit reports to be prepared at the

completion of works by the contractors. EPA will also assist in enforcing compliance with Bank safeguards

policies and monitor the implementation of the EMPs. The EPA will also support the MMAs in coordinating

safeguards activities. Specific capacity building on environmental management and environmental assessment

will be provided to the MMAs in addition to key staff of MLGRD, and other implementing focal points. In

accordance with World Bank guidelines, all EIAs/EMPs will need to be reviewed and cleared by the Bank prior

to the commencement of the civil works.

Particular attention will be given to the development of the ARAPs/RAPs and their implementation given the

relatively strong focus of the EPA on environmental rather than social and resettlement issues. Where necessary,

other institutions like traditional authorities, the Lands Commission and the Land Valuation Board will be

requested to support the monitoring of agreed action plans.

The civil society and NGOs will be involved in the project implementation as part of the institutional

arrangements.. This intervention will improve transparency and accountability bythe MMAs.

DRAFT ESMF of GAMA for MLGRD, Ghana, December 2012 - 80 -

8.4.2.1 Institutional arrangements for implementation of ESMP

Management of safeguards under GAMA is anchored under MLGRD as the lead implementing agency wth

responsibility for management and ensuring compliance with ESMF, with the MMAs playing a key role in

screening, reviewing and monitoring projects at the MMA level. Below are summarized the tasks assigned to

different institutions in the screening process, monitoring and evaluation of mitigating measures implementation.

Environmental Protection Agency

The Environmental Protection Agency (EPA) is responsible for:

review and approve the environmental classification of subprojectsand also approval EIAs.

monitoring at national level implementation of environmental measures.

The Ministry of Local Government and Rural Development

MLGRD will be the lead implementing agency for the GAMA on the whole. The Planning, Budgeting,

Monitoring and Evaluation (PBME) Department is the entity designated by MLGRD to manage the project.

PBME will also supervise the implementation of the ESMF by the MMAs. The Planning and Development Unit

(PDU) of the MMAs will execute the provisions of the ESMF on the ground.

MLGRD is responsible for training in environmental and social assessment, and monitoring and evaluation of

compliance with social and environmental safeguards in all sub projects. MLGRD will recruit an Environmental

and Social Officer3 (ESO). The ESO’s main task is to analyze screening documents for sub projects triggering

RAP/ESMP and ARAP, participation in EIA review, monitoring of MMA compliance with ESMF, monitoring

activities of mitigation measures implementation and act as the interlocutor of the GAMA MLGRD and MMAs

(Planning Officers and Environmental Health Officers)..

Taking into account environmental and social aspects in the ESMP and the effective monitoring of environmental

and social performance indicators should ensure that subprojects implemented under the GAMA's objectives do

not result in effects that could negate any benefits. To this end, it is appropriate to establish an efficient

mechanism for the management of environmental and social aspects of the sub-projects to be executed.

MLGRD will provide staff to achieve the following objectives:

propose management rules and specific measures that are compatible with sustainable development while

implementing the project

promote awareness by its personnel and the general public regarding environmental protection,

Key recommendations for GAMA institutional strengthening to meet the needs of the ESMF are as presented in

the summary of institutional responsibilities of the table 8.10 and are presented in the following table:

:

3 The Environmental and Social Officer will the responsible for the monitoring of compliance with the ESMF and RPF

provisions at MMA level.


Table 8-11: Institutional Arrangements for ESMP Implementation

INSTITUTIONAL MEASURES

Proposed actions Responsible Means and schedule

Environmental and Social

Officer’s Recruitment

Head of the Planning,

Budgeting, Monitoring and

Evaluation Department of

MLGRD

At the start of project implementation

Orientation of MPCUs within

the MMAs

MLGRD/MMAs As part of GAMA and safeguards

orientation

The recruitment of an ESO meets the need to provide the ESMP &RPF of GAMA coordination mechanisms more

effective to ensure the inclusion of environmental and social aspects in the implementation of activities under the

GAMA. This position will be for an environmental/civil engineer or a person with environment and natural

resources management background and familiar with the environmental and social assessment procedures of

Ghana and World Bank Safeguard policies.

The ESO at MLGRD will be responsible for the implementation of the ESMP & RPF in close collaboration with

the EPA and MMAs. The ESO will also will be responsible for the implementation of the environmental

monitoring and the ESMP & RPF as illustrated in Figure 8.2 below. His/her responsibilities shall include:

Supervision of MMA compliance with ESMF

Coordination with MMAs PCUs (and where relevant, EMCs) liaison with and monitoring of the contractors;

Compilation and preparation of periodic environmental and social impacts reports from MMAs for

submission to the World Bank;

Review of ESIA reports from consultants in collaboration with EPA and MLGRD;

Facilitating the disclosure of ESIAs and RAPs/ARAPs in-country and with the World Bank infoshop

Data Management; and

Sub-project inspections and monitoring on a sample basis.


Figure 8-1: ESMP Implementation Arrangement

MLGRD has the overall responsibility to ensure that the World Bank Safeguards Polices is complied with. In

addition, MLGRD is responsible for the final review and clearance of the ESMPs (or ESIAs); as well as for the

review and approval of TORs for the ESIA and EMPs in consultation with EPA.

The MPCU will be overall responsible for monitoring of environmental and social safeguards compliance.

8.5 CAPACITY STRENGTHENING FOR ESMP IMPLEMENTATION

In order for the MMAs to effectively carry out the environmental and social management responsibilities for sub-

project implementation, institutional strengthening will be required. Capacity building will encompass MLGRD,

and MMA staff.MLGRD should therefore ensure that the following concerns and needs are addressed:

Institutional structuring within the relevant departments to ensure that required professional and other

technical staff are available;

To successfully implement this ESMF, training programmes for MLGRD and MMAs is necessary. The World

Bank, MLGRD and EPA can take up the responsibility for the training. Proposed capacity building training needs

are as follows:

- Environmental and Social Management Process.

- Use of Screening form and Checklist

- Preparation of terms of reference for carrying out EA

- Design of appropriate mitigation measures.

- Review and approval of EA reports

- Public consultations in the ESMF/ESIA process.

- Monitoring mitigation measures implementation.

WB/EPA

MLGRD

MMAs

Reorganized Env Mgt

Committees in MMAs

- Coordinate Project Team

ESO in GAMA of MLGRD

ESO in GAMA of MLGRD

-

- Review monitoring reports to

ensure regulatory compliance


- Integrating ESMP into sub-projects implementation.

The proposed capacity building program will be carried out annually during the project.

8.5.1 Capacity Building Program and Awareness

The effectiveness of environmental and social issues consideration in the implementation of activities goes

particularly through training of MLGRD key actors on validation, monitoring, implementation of identified

mitigation measures. The training activities target: MLGRD Staff working on the GAMA, MMA Environmental

Management Committees, construction companies, operating agents.

Training programmes will be determined and prepared the World Bank in collaboration with the Ministry and the

EPA in environmental and social impact assessment . Topics will be centred around: (i) environmental and social

issues of Sanitation and Water projects and environmental assessment procedures, (ii) hygiene and safety,

requirements of national legislation, World Bank safeguards requirements, environmental monitoring of

construction sites.

The training aims to enhance their competence in environmental assessment, environmental control of work and

environmental monitoring so they can play their roles more effectively in the implementation of subprojects. The

training schedule is shown in the table 8.11 below.

Table 8-12: Training Schedule

Participants Duration Period

- MLGRD Staff,, MPCUs, companies,

3 days training workshop

1st quarter First

Project Year

8.5.2 Technical strengthen measures

The technical measures include:

- A provision for conducting any Environmental Impact Assessment (EIA)

EIAs would be required for activities categorized as A or B to ensure they are sustainable environmentally and

socially. If the environmental classification of activities indicates the need to conduct EIA and specific

resettlement action plans where involuntary resettlement is triggeredthe MMAs will be required to fund these out

of the GAMA project funding,

- Inclusion of environmental and social guidelines in the Operational Manual

A environmental and social procedure manual with social and environmental provisions will be included in the

Operational Manual of the GAMA.

- GAMA Monitoring and evaluation activities


The monitoring program will focus on continuous monitoring, supervision, mid-term and annual evaluation.

Support provided in the budget is needed for local monitoring to be conducted by ESO.

8.6 ESMF IMPLEMENTATION SCHEDULE

Timetable for implementation and monitoring of GAMA environmental activities will be as presented in table

8.12.

Table 8-13: Time Table for Implementation and Monitoring of Environmental Activities

Measures Proposed actions Implementation period in the project

cycle

Mitigation

measures View list of mitigation measures During subprojects implementation

Institutional

measures

ESO’s Recruitment

Before subprojects implementation

Technical

measures

Development of EIA for certain projects and

RAPs for projects that may cause displacement

After screening of specific activities at

a site

Development health and safety plan (construction

companies)

After signing the contract by company

Training Training of ESMF implementing actors in environmental

and social assessment

1st quarter First project year

Follow-up Action

Project Environmental Monitoring

Close monitoring

During the implementation of the

GAMA

Supervision Every month

ESMP Evaluation At mid-term

End of GAMA

8.7 ESTIMATED BUDGET

The budget needed for ESMP / GAMA environmental and social management is the recapitulation of the

following:

- Institutional development activities

- Training program, awareness

- Allowances for the preparation / implementation of sub-projects EIA / EMP/RAPs. (The costs of

implementing such plans measures are included in the budgets of sub-projects.)

- Annual assessments.

The costs of environmental measures as well as training and awareness are summarized in tables 8.13, 8.14 and

8.15 below. Under the GAMA Category A and B project will require the preparation of of EIAs.


Table 8-14: Estimated Costs of Technical Measures

Activity Quantity Unit cost

($US)

Total cost

($US)

EIA / RAP development at MMA level and to be integrated

into projects budget

To be

determined

later at

MMA

To be

determined

later at

MMA

To be

determined

later at MMA

Supervision and permanent monitoring at MMAs level by

MPCUs, Planning officers Quarterly

Normal

MMA

Budget

Normal

MMA

Budget

Table 8-15: Training and Awareness Measures Costs

Actors involved Topics Quantity Unit cost

($US)

Total cost

($US)

Training

MMAs

(Training of

members of

MMPCU at

MMA level,

including

planning officer,

and other

designated

officers

(This training

will be done by

the World Bank

in collaboration

with MLGRD

and EPA)

- Training on Environmental and Social

Assessment (screening and

classification of activities,

identification of impacts, mitigation

options and indicators)

- Involuntary Resettlement Issues

- Drafting ToR for EIA

- Selection of mitigation measures in the

checklists

- Legislation and national environmental

procedures

- Safeguard Policy World Bank

- Impact of sub-projects and mitigation

measures

- Environmental measures monitoring

- health and safety standards monitoring

Safety and hygiene at work and operation

2

workshops

per year

Y1-Y5 of

the project

covering all

11 MMAs

7,000 70,000

Awareness

- Commuities

- Local

associations

and NGOs

- Reps of

construction

companies

- Public awareness and advocacy on

projects environmental and social

issues, good environmental practices,

good conduct in the yards, respect for

hygiene and safety, compliance with

development standards

- Awareness Campaign HIV / AIDS

2

Normal

MMA

Budget

Normal

MMA

Budget

TOTAL 70,000


Table 8-16: Summarized Estimated Budget for Environmental and Social Impact Management

Measures Actions Responsible Costs USD

Institutional

measures

Recruitment of ESO at MLGRD Level

MLGRD

Technical

measures

Perform ESMP monitoring and evaluation (continuous

monitoring, mid-term and annual assessment)

EIAs / RAP development

Health and safety Plans development

Supervision and Monitoring

MMA

MLGRD

Covered by

normal MMA

Budgets

Covered by

ESO

Monitoring and

Evaluation

Budget

Training

Training of MMA staff in projects environmental and social

management and monitoring and enforcement of


MLGRD

Covered under

training above

Awareness - Information and awareness campaigns on the nature of

work, environmental and social issues

- Awareness on HIV / AIDS

MMA

Normal MMA

Budget

TOTAL

8.8 ESMF/ ESMP DISSEMINATION AND PUBLIC DISCLOSURE

Under the approach advocated by the World Bank, environmental assessments are not only an expert analysis, but

part of a participatory process involving all stakeholders in the project.

The various stakeholders must be :(i) viewed as sources of information and points of view and different interests;

(ii) systematically informed of the findings and progress of the project (through a communication plan), and iii)

loans at any time to make their voices heard by decision makers.

To do this, an information system and public communication must be established early of subproject assessment.

The system also includes a provision of formal public reports, once the assessments are completed. The OP 4.01

outlines the requirements for consultation and dissemination of environmental assessments in accordance with the

policy of dissemination of the World Bank (BP 17.50).

The ESMF document has been disclosed in-country by advertising it in two newspapers and stating the locations

where the copies could be found for review for 21 working days and at the World Bank Infoshop for 60 days

according to the Public Disclosure Policy (OP 17.50). The ESIA of sub-projects will also be disclosed in country

and at the Infoshop.

FINAL DRAFT ESMF of GAMA for MLGRD, Ghana, January, 2011 - 87 -

Table 8-17: Environmental and Social Management Plan

Potential Impact Mitigation

Measures

Implementation

Schedule

Monitoring

Indicators Monitoring

Responsibility

Frequenc

y

Cost

Estim

ate

(US$)

Implementation Supervisio

n

Soil

Possible increase in

soil erosion as a

result of the

construction

activities (clearing

of vegetation and

soil excavation)

Loss of productive

topsoil resulting

from soil

excavation

Soil contamination

resulting from the

release of chemicals

(lubricant, fuel,

paint) from the

equipments

Re-vegetate the

construction site by

planting rapidly

growing

vegetation/plants

Use excavated soil

for construction work

Ensure immediate

clean up of the area

by removing the

contaminated topsoil

and disposing

properly in a

designated place

During and after

the construction

activities

During

construction

During

construction

Erosion

Soil

Monitor erosion

occurrence within

and around the

construction site

Ensure that all the

excavated soil are

used for

construction

Monitor and

document the

contaminated soil

disposal

procedure

Contractor/super

vising consultant

MMPCUs

Weekly

$

Water

Run-off erosion

may occur from

unprotected

excavated areas

during heavy rain

resulting to

sedimentation of

nearby water-

Attend to any

excavation area as

quick as possible or

create an

embankment to avoid

run off

During

excavation

activities

Sediments

Monitor BOD,

Nitrate, pH,

Heavy metals of

the nearby water

bodies before the

construction and

thereafter weekly

during the

Contractor/super

vising consultant

Works

Department

of

MMPCUs

Weekly

$



Measures

Implementation

Schedule

Monitoring


Responsibility

Frequenc

y

Cost

Estim

ate

(US$)


n

bodies

Run-off erosion

may occur from

heaps of excavated

soils during heavy

rain resulting to

sedimentation of

nearby water-

bodies

Potential water

pollution through

run off of

hazardous

construction waste

(lubricants, paint)

Create barrier for

appropriate

containment

measures

Proper disposal of

construction waste

During

construction

During

construction

Sediments

Heavy metals

construction

activities

Air

Particulate matters

emission from

excavation and

construction

activities

Potential emission

of pollutants from

the construction

machineries (NOx,

SOx, CO, THC)

Spray water

periodically to

control dust

Limit the vehicles

allowed into the site

and use efficient

machineries

During

excavation and

construction

activities

During

construction

activities

PM

NOx, SOx,

THC and CO

Monitor PM,

NOx, SOx, THC

and CO in the

surrounding air

before the

construction and

thereafter hourly

during the

construction

Contractor/super

vising consultant

MMPCUs

Weekly

$



Measures

Implementation

Schedule

Monitoring


Responsibility

Frequenc

y

Cost

Estim

ate

(US$)


n

Noise

Noise resulting

from the

construction works

Equipment (e.g.

cement-sand mixer

machine) to be placed

as far as possible

from the sensitive

area/ human

settlement

Construction should

not be done during

peak work hours

Construction staff to

wear ear muffs

During

construction

activities

Noise

Monitor staff

compliance to the

use of ear

muffs/plugs

Contractor/super

vising consultant

MMPCUs

Daily

$

Ecosystem

Destruction of

vegetation, loss of

habitat and

biodiversity

Possible loss of

endangered and rare

specie

Change in land use

and disturbance of

ecosystem

Re-vegetate the

construction site by

planting rapidly

growing

vegetation/plants

During and after

construction

Vegetation

Monitor the re-

vegetation process

Contractor/super

vising consultant

Works

Department

of

MMPCUs

Monthly

$



Measures

Implementation

Schedule

Monitoring


Responsibility

Frequenc

y

Cost

Estim

ate

(US$)


n

Social

Possible loss of

access to assets or

resource.

Provide alternative

route for access to

resource.

Before

construction

begins

Complaints

from the

affected

people

Document

relocation

procedures

Monitor the road

traffic before

and during

construction

activities

Contractor/super

vising consultant

MMPCUs

Soil

Contamination of

soil as a result of

waste (reagent,

solid waste)

disposal

Pre-treat waste before

disposal (through

neutralization,

thermal pretreatment,

oxidation, etc)

Before disposal

pH,

BOD,COD,

Nitrate etc

(based on the

type of

chemical

waste

generated)

Monitor the

surrounding soil

pH, BOD,COD,

Nitrate etc (based

on the type of

chemical waste

generated).

Monitoring to be

before

construction and

monthly during

the construction

Contractor/super

vising consultant

Monthly

$350

Water

Depletion of water

resources

Contamination of

surrounding water

bodies through

Reuse and recycle

water, also minimize

water usage

Install water flow

meter

During operation

Before waste

water disposal

Increase in

water utility

payment.

Increase in

water flow

meter reading

Monitoring the

water flow meter

Monitor the

surrounding water

bodies pH,

Monthly

$300



Measures

Implementation

Schedule

Monitoring


Responsibility

Frequenc

y

Cost

Estim

ate

(US$)


n

improper disposal

of waste water

Possible run off

from the temporary

solid waste storage

site into the

drainage system

Pre-treat waste water

before disposal

(through

neutralization,

thermal pretreatment,

oxidation, etc)

Avoid siting

temporary solid waste

storage close to

drainage system or

water ways.

Dispose waste as

soon as possible to

avoid leachate

generation

Ensure proper

containment of the

temporary waste

storage site

During site

selection

Implement

mitigation

measures through

the operation

phase

pH,

BOD,COD,

Nitrate etc

(based on the

type of

chemical

waste

generated)

BOD,COD,

Nitrate etc (based

on the type of

chemical waste

generated).

Monitoring to be

before

construction and

monthly during

the construction


9.0 REFERENCES

Ghana Shared Growth and Development Agenda(GSGDA) (2010-2013)

Ghana Poverty Reduction Strategy Paper (GPRS I & II)

Project Appraisal Document (PAD) for GAMA

Republic of Ghana (2003): Labour Act, 2003 (Act 651)

Republic of Ghana (1994): Environmental Protection Agency Act, 1994 (Act 490)

Republic of Ghana (1999): Environmental Assessment Regulations 1999 (LI 1652)

Republic of Ghana (2002): Environmental Assessment (Amendment) Regulations, 2002 (LI 1703)

Environmental and Social Analysis for the Second Urban Environmental Sanitation Project (UESP II),

Ghana, 2003

Handbook for Preparing a Resettlement Action Plan, International Finance Corporation

Ghana: GAMA Preparation Mission, Aide Memoire

State Land Act 1963


10.0 ANNEXES

ANNEX 1A: ENVIRONMENTAL AND SOCIAL SCREENING (ESS) OF SUB-PROJECTS

This stage marks the beginning of the ESIA or ESMP process, which should be initiated as early as possible along

with the sub-project planning process after the sub-project is conceived. During this stage, the important functions

that need to be performed are:

i. Establish the likely study area by identifying broad boundaries for the sub-project;

ii. Make a preliminary assessment of the significance of potential environmental impacts, and likely

mitigating measures;

iii. Identify possible alternatives and the major potential environmental impacts associated with each, as well

as the likely corresponding mitigation measures;

iv. Estimate the extent and scope of ESIA to be performed, and offer an initial recommendation as to whether

a full ESIA is required;

v. Estimate the time frame of the ESIA study;

vi. Identify the expertise and human resources needed for the ESIA study; and

vii. Prepare the terms of reference for the conduct of an initial environmental examination.

The value of conducting environmental and social screening at the early conception and planning phase of a

development project is to provide useful technical input to the project team for their planning and budgeting,

thereby eliminating the possibility of costly remedial environmental work and delays caused by problems with

adverse environmental damage. Such early input on environmental considerations also provides useful

information that helps the project team to gain government approval and win public acceptance.

The environmental and social screening process considers the following aspects in the recommendation: project

type, environmental and social setting, and magnitude and significance of potential environmental and social

impacts. Some of the typical questions asked in the environmental and social screening process are outlined in the

figure in the next page below.


Figure 10.1: Typical Environmental Screening Procedure


ANNEX 1B: STANDARD FORMAT FOR SCREENING REPORT

1.0 Description of Sub-Project

1.1 Nature of Sub-Project and Duration

……………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………

………………………………………………………………………… 1.2 Scope of Sub-Project [Size of labour force, area covered or length &width of road, type of raw materials (quantities

and sources), types of equipment, implements, machinery, etc.]

……………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………

………………………………………………………………

………………………………………………………………………………………………………… 1.3 Waste Generation

i. Types: Solid □ Liquid □ Gaseous □ Other ………………………………..

ii. Quantity: …………………………………………………………………………………..

iii. Means/Place of Disposal: ………………………………………………………………….

2.0 Proposed Site for Sub-Project

2.1 Location [attach a site plan or a map (if available)]

i. Location or Area (and nearest Town(s)): …..……………………….……………………

ii. Land take (total area for sub-project and related activities): …………………………………

2.2 Land Use of the Area for the Sub-Project:

Agriculture □ Residential □ Existing Dugout □ Existing Road □ Reservation □ Park/Recreation □ Industrial □ Other (specify) □

2.3 Site Description [Attach photographs and sketches showing distances]

i. Distance from nearest water body or drainage channel (minimum distance measured from the edge of

proposed site to the bank of the water body or drain).

More than 100 meters □ 100 meters □ Less than 100 meters □

ii. Number of water bodies and/or drainage channels/depressions crossed by the route/road corridor:

……………………………………………………………………………………………..

iii. Distance to nearest community (house) and/or other existing structures from the proposed site:

…………………………………………………………………………………………………

iv. Number of communities (structures) along the entire stretch of the Sub-project road:

…………………………………………………………………….……………………………

2.4 Land Cover and Topography

i. Land cover of the site consists (completely or partly or noticeably) of:

Vegetation □ Sparse Vegetation □ Physical Structure(s) □ Flood Plane □ Agriculture (Animals) □ Cultural Resource □ Water □ Agriculture (Crops) □ Other specify………


ii. Elevation and topography of the area for the Sub-Project:

Flat □ Valley □ Slope □ Undulating □ Hill □ Mountain □ Depression □

iii. Elevation and topography of the adjoining areas (within 500 meters radius of the site):

Flat □ Valley □ Slope □ Undulating □ Hill □ Mountain □ Depression □

3.0 Infrastructure

i. The Sub-project would be developed in/on:

Undeveloped site □

Partly developed site □ Existing route □ Other (specify)

………………………

ii. The Sub-project would involve excavation Yes □ No □

iii. Estimated number and depth of the excavations, etc): ………………………………………………

vi. Are any of the following located on-site or within 50 metres from the edge of the proposed site?

Water supply source Yes □ No □

Pipeline Yes □ No □

Power supply source (electric pylon) Yes □ No □

Drainage Yes □ No □

Other(s) specify: …………………………………………….

4.0 Environmental and Social Impacts

4.1 Air Quality - Would the proposed Sub-project:

i. Emit during construction

Dust □ Smoke □ VOCs □ ii Expose workers or the public to substantial emissions? Yes □ No □

iii. Result in cumulatively increased emissions in the area? Yes □ No □

vi. Create objectionable odour affecting people? Yes □ No □

4.2 Biological Resources - Would the proposed Sub-project:

i. Have adverse effect on any reserved area? Yes □ No □

ii. Have adverse effect on wetland areas through removal, filling, hydrological

interruption or other means?

Yes □ No □

iii. Interfere substantially with the movement of any wildlife species or organisms? Yes □ No □

vi. Be located within 100m from an Environmentally Sensitive Area? Yes □ No □

4.3 Cultural Resources - Would the proposed Sub-project:

i. Disturb any burial grounds or cemeteries? Yes □ No □

ii. Cause substantial adverse effect on any archeological or historic site? Yes □ No □

iii. Alter the existing visual character of the area and surroundings, including trees and rock

outcrops?

Yes □ No □

4.4 Water Quality and Hydrology - Would the proposed Sub-project:

i. Generate and discharge during construction:

Liquid waste □ Liquid with oily substance □ Liquid with human or animal waste □ Liquid with chemical substance □ Liquid with pH outside 6-9 range □ Liquid with odour/smell □

ii. Lead to changes in the drainage pattern of the area, resulting in erosion or siltation? Yes □ No □ iii. Lead to increase in surface run-off, which could result in flooding on or off-site? Yes □ No □


iv. Increase runoff, which could exceed the capacity of existing storm water drainage? Yes □ No □

4.5 Noise Nuisance - Would the proposed Undertaking:

i. Generate noise in excess of established permissible noise level? Yes □ No □

ii. Expose persons to excessive vibration and noise? Yes □ No □

4.6 Other Environmental and Social Impacts

…………………………………………………………………………………………………………………………

………………………………………………………………………….………………………………………………

………………………………………………….………………….……………………

5.0 Management of (Environmental and Social) Impacts

5.1 Air Quality

…………………………………………………………………………………………………..………………………

…………………………………………………………………………..………………………………………………

………………………………………………………………………………………….

5.2 Biological Resources

…………………………………………………………………………………………………..………………………

………………………………………………………………………….………………………………………………

………………………………………………………………………………………..

5.3 Cultural Resources

…………………………………………………………………………………………………..………………………

…………………………………………………………………………..………………………………………………

………………………………………………………………………………………….

5.4 Water Quality and Hydrology

…………………………………………………………………………………………………..………………………

…………………………………………………………………………..………………………………………………

…………………………………………………………………………………………

5.5 Noise …………………………………………………………………………………………………..……………

……………………………………………………………………………………..……………………………………

…………………………………………………………………………………………………..

5.6 Any Other

…………………………………………………………………………………………………..………………………

………………………………………………………………………..…………………………………………………

………………………………………………………………………………………….

ATTACHMENTS

1.1. Maps

1.2. Photos

1.3. Location and Administrative Maps

1.4. Environmental and Social Checklist


ANNEX 1C: SCREENING REPORT-ENVIRONMENTAL AND SOCIAL CHECKLIST

Table 10-1: Environmental and Social Checklist

MMA: District: Date:

GAMA Facility Name: Location:

Issue Degree* Comment

Land Resources

Worksite/Campsite Areas

Excavation Areas

Disposal Areas

Others

Water Resources & Hydrology

Sources of Water for Construction

Drainage Issues

Others

Biological Resources

Special Trees/Vegetation around

Protected Areas directly affected

Others

Air Quality & Noise

Special issues (e.g. quiet zone for working)

Residential Areas

Socio-Economic & Cultural

Involuntary Resettlement**

Graveyards and Sacred Areas affected

Cultural Resources

Population affected/provided access

Others

*Degree: N = Negligible or Not Applicable

L = Low

M = Moderate

H = High

**If yes, indicate # of persons likely to be affected and nature of the effect


ANNEX 2: STANDARD FORMAT FOR ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

EXECUTIVE SUMMARY

1. PROJECT DESCRIPTION

1.1. Overview of the MMA where the GAMA Facility is located

1.2. List of GAMA Facilities

1.3. Environmental Screening Category

2. POLICY AND ADMINISTRATIVE AND LEGAL FRAMEWORK

3. MMAs -SPECIFIC ESMPs

3.1. Location

3.2. Proposed Works

3.3. Estimated Cost

3.4. Baseline Data

3.4.1. Land Resources

3.4.2. Hydrology and Water Resources

3.4.3. Air and Noise

3.4.4. Biological Resources

3.4.5. Socio-Economic and Cultural

3.5. Potential Impacts

3.5.1. Land Resources

3.5.1.1. Construction Phase

3.5.1.2. Post Construction Phase

3.5.2. Hydrology and Water Resources



3.5.3. Air Quality and Noise



3.5.4. Biological Resources



3.5.5. Socio-Economic and Cultural



3.6. Analysis of Alternatives

3.7. Mitigation Measures

3.7.1. Construction Phase

3.7.2. Post Construction Phase

3.8. Monitoring and Supervision Arrangements

3.9. Summary ESMP Table

4. ATTACHMENTS

4.1. Photos

4.2. Summary of Consultations and Disclosure

4.3. Other


ANNEX 3: GUIDANCE ON ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN BY PROJECT PHASES

Table 10-2: Guidance on ESMP by Project Phases

Phases Issue/Potential Impact Mitigation Measure(s) Implementing

Responsibility

Monitoring

Responsibility

Cost

Design Phase

Impacts on physical

environment: air quality,

hydrology, waste, soils, noise

Consider the impact of the construction activities on

the physical environment for the design of civil works

Design Consultant MPCU To be

determined

Impact on Air Quality:

Emission of dust and other

pollutants

Bid document will include requirement to ensure:

- Adequate watering for dust control

- Prohibition of open burning

- Ensure stockpile of materials are properly secured

- Proper unloading/storage of construction

materials

- On-site mixing of materials in shielded area

- Equipment and materials to be properly covered

during transportation.

Design Consultant MPCU To be

determined

Noise impact Bid document to include requirement to ensure:

- Noise silencers be installed on all exhaust

system

- Use of ear plugs for construction workers

- Equipment placed as far as possible from

sensitive land users.

Design Consultant ESO/MPCU To be

determined

Impact on hydrology:

Degradation of surface water

quality

The contract document should specify:

- use of good engineering practice during

construction, including adequate supervision

- Minimal water usage in construction area

- Minimal soil exposure time during construction

- Minimal chemical usage (lubricants, solvents,

petroleum products.


determined

Alteration of surface drainage Contract document to include requirement to ensure:

- installation of adequately sized drainage

channels

- stabilization of slopes to avoid erosion


determined

Waste generation and disposal

(solid/ oily/hazardous)

Contract document to include requirement to ensure:

- Provision of waste management plan.

- Proper handling and disposal /recycling of oily


determined


waste

Impact on Soil:

Increased soil erosion

Contract document to include requirement to ensure:

- Use of less erodable materials,

- Lined down-drains to prevent erosion


determined

Socioeconomic Impact:

Disruption during work- demand

for local Sanitation and Water

services increase

- Avoid the creation of congested and unsafe road

conditions at intersections and in villages or

cities.


determined

Disruption to traditional

lifestyles and other services

- Ensures access to homes, businesses, other key

services


determined

Construction

Impact on Air Quality:

Emission of dust and other

pollutants

- Periodically use water to spray areas under

construction

- Construction workers to wear face masks and

gloves

- Ensure that all equipment and materials loaded

on trucks are covered during transportation

Contractor,

Supervising

consultant

ESO/MPCU To be

determined

Noise Impact - Noise standards to be enforced to protect

construction workers

- Ensure that silencers are installed on all exhaust

systems.

- Ear plugs to be worn by construction workers

- Turn off construction equipment when not in use

Contractor,

Supervising

consultant

ESO/MPCU To be

determined

Impact on hydrology:

Degradation of surface water

quality

- Use good engineering practice during

construction

- Ensure wastewater from cleaning of equipment

is not disposed of in water course.

- Wastewater should be collected and treated

suitably before being disposed of in water

courses.

- Ensure minimal use of water in construction area

- Minimal soil exposure time during construction

Contractor,

Supervising

consultant

ESO/MPCU To be

determined

Alteration of surface drainage - Install adequately sized drainage channels

- Ensure stabilization of slopes to avoid erosion

Contractor,

Supervising

consultant

ESO/MPCU To be

determined


Solid waste generation and

disposal

- Ensure all waste earth and materials associated

with construction activities are disposed land

without prior consent of PPT.

- Daily life rubbish and waste materials associated

with construction activities should be daily

collected and disposed of in suitable approved

dumpsites.

- Ensure that solid wastes are not disposed of in

water courses.

Contractor,

Supervising

consultant

ESO/MPCU To be

determined

Poor Sanitation at construction

camp and site

- Provide adequately located and maintained

latrines

Contractor ESO/PPT

Accidental spill of toxic

material/oil

- Design and implement safety measures

- Provide an emergency plan to contain accidental

spill

Contractor ESO/PPT

Impact on Soil:

Increased soil erosion

- Avoid erosion of cuts and fills by providing

proper drainage,

- Lined down-drains to prevent erosion

Contractor,

Supervising

Consultant

ESO/MPCU

Impact on vegetation - Replanting of land within project area. Contractor,

Supervising

Consultant

ESO/MPCU

Health and Safety Impact

- Enure adequate health facility systems are in

place on-site to deal with influx of temporary

workers.

- Ensure use of nets, insect repellent and other

malaria preventive measure for workers on site.

- Health education about STDs should be

introduced.

- Training of construction crew and supervisors on

health and safety guidelines

- Personal protective equipment to be worn by all

workers

Contractor,

Supervising

Consultant

ESO/MPCU

Socioeconomic Impact:

Loss of property

- Avoid or reduce loss of property

- Avoid land where farmers will be displaced.

Contractor Supervising

Consultant/ESO

To be

determined


ANNEX 4: DRAFT TERMS OF REFERENCE FOR SUB-PROJECT REQUIRING AN ESIA

Based on the screening and scoping results. ESIA terms of reference will be prepared. A local consultant will

conduct the ESIA and the report should have the following format:

Introduction and Context

This part will be completed at a time and will include necessary information related to the context and

methodology to carry out the study.

Objectives of the Study

This section will indicate (i) the objectives and the project activities; (ii) the activities that may cause

environmental and social negative impacts and needing adequate mitigation measures.

Mission/Tasks

The Consultant should realize the following:

Describe the biophysical characteristics of the environment where the project activities will be realized;

and underline the main constraints that need to be taken into account at the field preparation, during the

implementation and exploitation/maintenance of equipments.

Assess the potential environmental and social impacts related to project activities and recommend

adequate mitigation measures, including costs estimates;

Assess the need of solid and liquid waste management and suggest recommendation for their safe

disposal;

Review political, legal and institutional framework, at national and international level, related to

environmental, identity constraints and suggest recommendations for reinforcement;

Identify responsibilities and actors for the implementation of proposed mitigation measures;

Access the capacity available to implement the proposed mitigation measures, and suggest

recommendation in terms of training and capacity building, and estimate their costs;

Develop an Environmental Management Plan (EMP) for the project. The EMP should underline (i) the

potential environmental and social impacts resulting from project activities; (ii) The proposed mitigation

measures; (iii) the institutional responsibilities for implementation; (iv) the monitoring indicators; (v) the

institutional responsibilities for monitoring and implementation of mitigation measures; (vi) the costs of

activities; and (vii) the schedule of implementation.

Public consultations

The ESIA results and the proposed mitigation measures will be discussed with population, NGOs, local

administration and other organizations mainly involved by the project activities. Recommendations from this

public consultation will be included in the final ESIA report.

Plan of the ESIA Report

Cover page

Table of Contents

List of Acronyms

Executive Summary

Introduction

Description of project activities

Description of Environment in the project area


Description of policy, legal and Institutional Framework

Description of the methodology and techniques used in assessment and analysis of the project impacts

Description of environmental and social impacts for project activities

Environmental Management Plan (EMP) for the project including the proposed mitigation measures;

institutional responsibilities for monitoring and implementation; Summarized table for EMP.

Recommendations

References

List of Persons/Institutions met

Qualification of the Consultant

The Consultant will be agreed upon by the EPA in carrying out the ESIA studies

Duration of Study

The Duration of study will be determined according to the type of activity

Production of final Report

The Consultant will produce the final report one (1) week after receiving comments from EPA and GAMA

Secretariat. The final report will include comments from these institutions.

Supervision of Study

The consultancy will be supervised by the Environmental and Social Management Specialist (ESMS) of the

GAMA Secretariat.

Description of the study area

Description of the sub-project

Legislative and regulatory considerations

Determination of the potential impacts of the proposed sub-projects

Environmental Management Plan

Public consultations process

Development of mitigation measures and a monitoring plan, including cost estimates.


ANNEX 5: GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS

General

1. In addition to these general conditions, the Contractor shall comply with any specific Environmental

Management Plan (EMP) or Environmental and Social Management Plan (ESMP) for the works he is

responsible for. The Contractor shall inform himself about such an EMP, and prepare his work strategy and

plan to fully take into account relevant provisions of that EMP. If the Contractor fails to implement the

approved EMP after written instruction by the Supervising Engineer (SE) to fulfill his obligation within the

requested time, the Owner reserves the right to arrange through the SE for execution of the missing action by

a third party on account of the Contractor.

2. Notwithstanding the Contractor’s obligation under the above clause, the Contractor shall implement all

measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore

work sites to acceptable standards, and abide by any environmental performance requirements specified in an

EMP. In general these measures shall include but not be limited to:

(a) Minimize the effect of dust on the surrounding environment resulting from earth mixing sites, vibrating

equipment, temporary access roads, etc. to ensure safety, health and the protection of workers and

communities living in the vicinity dust producing activities.

(b) Ensure that noise levels emanating from machinery, vehicles and noisy construction activities (e.g.

excavation, blasting) are kept at a minimum for the safety, health and protection of workers within the vicinity

of high noise levels and nearby communities.

(c) Ensure that existing water flow regimes in rivers, streams and other natural or irrigation channels is

maintained and/or re-established where they are disrupted due to works being carried out.

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

into rivers, streams, irrigation channels and other natural water bodies/reservoirs, and also ensure that stagnant

water in uncovered borrow pits is treated in the best way to avoid creating possible breeding grounds for

mosquitoes.

(e) Prevent and minimize the impacts of quarrying, earth borrowing, piling and building of temporary

construction camps and access roads on the biophysical environment including protected areas and arable

lands; local communities and their settlements. In as much as possible restore/rehabilitate all sites to

acceptable standards.

(f) Upon discovery of ancient heritage, relics or anything that might or believed to be of archeological or

historical importance during the execution of works, immediately report such findings to the SE so that the

appropriate authorities may be expeditiously contacted for fulfillment of the measures aimed at protecting

such historical or archaeological resources.

(g) Discourage construction workers from engaging in the exploitation of natural resources such as hunting,

fishing, and collection of forest products or any other activity that might have a negative impact on the social

and economic welfare of the local communities.


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

(i) Ensure that garbage, sanitation and drinking water facilities are provided in construction workers camps.

(j) Ensure that, in as much as possible, local materials are used to avoid importation of foreign material and

long distance transportation.

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

3. The Contractor shall indicate the period within which he/she shall maintain status on site after completion of

civil works to ensure that significant adverse impacts arising from such works have been appropriately

addressed.

4. The Contractor shall adhere to the proposed activity implementation schedule and the monitoring plan /

strategy to ensure effective feedback of monitoring information to project management so that impact

management can be implemented properly, and if necessary, adapt to changing and unforeseen conditions.

5. Besides the regular inspection of the sites by the SE for adherence to the contract conditions and specifications,

the Owner may appoint an Inspector to oversee the compliance with these environmental conditions and any

proposed mitigation measures. State environmental authorities may carry out similar inspection duties. In all

cases, as directed by the SE, the Contractor shall comply with directives from such inspectors to implement

measures required to ensure the adequacy rehabilitation measures carried out on the bio-physical environment

and compensation for socio-economic disruption resulting from implementation of any works.

Worksite/Campsite Waste Management

6. All vessels (drums, containers, bags, etc.) containing oil/fuel/construction materials and other hazardous

chemicals shall be bunded in order to contain spillage. All waste containers, litter and any other waste

generated during the construction shall be collected and disposed off at designated disposal sites in line with

applicable government waste management regulations.

7. All drainage and effluent from storage areas, workshops and camp sites shall be captured and treated before

being discharged into the drainage system in line with applicable government water pollution control

regulations.

8. Used oil from maintenance shall be collected and disposed off appropriately at designated sites or be re-used

or sold for re-use locally.

9. Entry of runoff to the site shall be restricted by constructing diversion channels or holding structures such as

banks, drains, dams, etc. to reduce the potential of soil erosion and water pollution.

10. Construction waste shall not be left in stockpiles along the road, but removed and reused or disposed of on a

daily basis.


11. If disposal sites for clean spoil are necessary, they shall be located in areas, approved by the SE, of low land

use value and where they will not result in material being easily washed into drainage channels. Whenever

possible, spoil materials should be placed in low-lying areas and should be compacted and planted with

species indigenous to the locality.

Material Excavation and Deposit

12. The Contractor shall obtain appropriate licenses/permits from relevant authorities to operate quarries or

borrow areas.

13. The location of quarries and borrow areas shall be subject to approval by relevant local and national

authorities, including traditional authorities if the land on which the quarry or borrow areas fall in traditional

land.

14. New extraction sites:

a) Shall not be located in the vicinity of settlement areas, cultural sites, wetlands or any other valued ecosystem

component, or on high or steep ground or in areas of high scenic value, and shall not be located less than 1km

from such areas.

b) Shall not be located adjacent to stream channels wherever possible to avoid siltation of river channels. Where

they are located near water sources, borrow pits and perimeter drains shall surround quarry sites.

c) Shall not be located in archaeological areas. Excavations in the vicinity of such areas shall proceed with great

care and shall be done in the presence of government authorities having a mandate for their protection.

d) Shall not be located in forest reserves. However, where there are no other alternatives, permission shall be

obtained from the appropriate authorities and an environmental impact study shall be conducted.

e) Shall be easily rehabilitated. Areas with minimal vegetation cover such as flat and bare ground, or areas

covered with grass only or covered with shrubs less than 1.5m in height, are preferred.

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

15. Vegetation clearing shall be restricted to the area required for safe operation of construction work. Vegetation

clearing shall not be done more than two months in advance of operations.

16. Stockpile areas shall be located in areas where trees can act as buffers to prevent dust pollution. Perimeter

drains shall be built around stockpile areas. Sediment and other pollutant traps shall be located at drainage

exits from workings.

17. The Contractor shall deposit any excess material in accordance with the principles of these general conditions,

and any applicable EMP, in areas approved by local authorities and/or the SE.


18. Areas for depositing hazardous materials such as contaminated liquid and solid materials shall be approved by

the SE and appropriate local and/or national authorities before the commencement of work. Use of existing,

approved sites shall be preferred over the establishment of new sites.

Rehabilitation and Soil Erosion Prevention

19. To the extent practicable, the Contractor shall rehabilitate the site progressively so that the rate of

rehabilitation is similar to the rate of construction.

20. Always remove and retain topsoil for subsequent rehabilitation. Soils shall not be stripped when they are wet

as this can lead to soil compaction and loss of structure.

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

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

beneficial soil microbes.

23. Locate stockpiles where they will not be disturbed by future construction activities.

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

25. Remove toxic materials and dispose of them in designated sites. Backfill excavated areas with soils or

overburden that is free of foreign material that could pollute groundwater and soil.

26. Identify potentially toxic overburden and screen with suitable material to prevent mobilization of toxins.

27. Ensure reshaped land is formed so as to be inherently stable, adequately drained and suitable for the desired

long-term land use, and allow natural regeneration of vegetation.

28. Minimize the long-term visual impact by creating landforms that are compatible with the adjacent landscape.

29. Minimize erosion by wind and water both during and after the process of reinstatement.

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

31. Revegetate with plant species that will control erosion, provide vegetative diversity and, through succession,

contribute to a resilient ecosystem. The choice of plant species for rehabilitation shall be done in consultation

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

Water Resources Management

32. The Contractor shall at all costs avoid conflicting with water demands of local communities.

33. Abstraction of both surface and underground water shall only be done with the consultation of the local

community and after obtaining a permit from the relevant Water Authority.


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

relevant authorities.

35. Temporary damming of streams and rivers shall be done in such a way avoids disrupting water supplies to

communities down stream, and maintains the ecological balance of the river system.

36. No construction water containing spoils or site effluent, especially cement and oil, shall be allowed to flow

into natural water drainage courses.

37. Wash water from washing out of equipment shall not be discharged into water courses or road drains.

38. Site spoils and temporary stockpiles shall be located away from the drainage system, and surface run off shall

be directed away from stockpiles to prevent erosion.

Traffic Management

39. Location of access roads/detours shall be done in consultation with the local community especially in

important or sensitive environments. Access roads shall not traverse wetland areas.

40. Upon the completion of civil works, all access roads shall be ripped and rehabilitated.

41. Access roads shall be sprinkled with water at least five times a day in settled areas, and three times in

unsettled areas, to suppress dust emissions.

Blasting

42. Blasting activities shall not take place less than 2km from settlement areas, cultural sites, or wetlands without

the permission of the SE.

43. Blasting activities shall be done during working hours, and local communities shall be consulted on the

proposed blasting times.

44. Noise levels reaching the communities from blasting activities shall not exceed 90 decibels.

Disposal of Unusable Elements

45. Unusable materials and construction elements such as electro-mechanical equipment, pipes, accessories and

demolished structures will be disposed of in a manner approved by the SE. The Contractor has to agree with

the SE which elements are to be surrendered to the Client’s premises, which will be recycled or reused, and

which will be disposed of at approved landfill sites.

46. As far as possible, abandoned pipelines shall remain in place. Where for any reason no alternative alignment

for the new pipeline is possible, the old pipes shall be safely removed and stored at a safe place to be agreed

upon with the SE and the local authorities concerned.


47. AC-pipes as well as broken parts thereof have to be treated as hazardous material and disposed of as specified

above.

48. Unsuitable and demolished elements shall be dismantled to a size fitting on ordinary trucks for transport.

Health and Safety

49. In advance of the construction work, the Contractor shall mount an awareness and hygiene campaign.

Workers and local residents shall be sensitized on health risks particularly of AIDS.

50. Adequate road signs to warn pedestrians and motorists of construction activities, diversions, etc. shall be

provided at appropriate points.

51. Construction vehicles shall not exceed maximum speed limit of 40km per hour.

Repair of Private Property

52. Should the Contractor, deliberately or accidentally, damage private property, he shall repair the property to the

owner’s satisfaction and at his own cost. For each repair, the Contractor shall obtain from the owner a

certificate that the damage has been made good satisfactorily in order to indemnify the Client from

subsequent claims.

53. In cases where compensation for inconveniences, damage of assets etc. are claimed by the owner, the Client

has to be informed by the Contractor through the SE. This compensation is in general settled under the

responsibility of the Client before signing the Contract. In unforeseeable cases, the respective administrative

entities of the Client will take care of compensation.

Contractor’s Health, Safety and Environment Management Plan (HSE-MP)

54. Within 6 weeks of signing the Contract, the Contractor shall prepare an EHS-MP to ensure the adequate

management of the health, safety, environmental and social aspects of the works, including implementation

of the requirements of these general conditions and any specific requirements of an EMP for the works. The

Contractor’s EHS-MP will serve two main purposes:

For the Contractor, for internal purposes, to ensure that all measures are in place for adequate HSE

management, and as an operational manual for his staff.

For the Client, supported where necessary by a SE, to ensure that the Contractor is fully prepared for the

adequate management of the HSE aspects of the project, and as a basis for monitoring of the Contractor’s

HSE performance.

55. The Contractor’s EHS-MP shall provide at least:

a description of procedures and methods for complying with these general environmental management

conditions, and any specific conditions specified in an EMP;

a description of specific mitigation measures that will be implemented in order to minimize adverse

impacts;

a description of all planned monitoring activities (e.g. sediment discharges from borrow areas) and the

reporting thereof; and

the internal organizational, management and reporting mechanisms put in place for such.


56. The Contractor’s EHS-MP will be reviewed and approved by the Client before start of the works. This review

should demonstrate if the Contractor’s EHS-MP covers all of the identified impacts, and has defined

appropriate measures to counteract any potential impacts.

HSE Reporting

57. The Contractor shall prepare bi-weekly progress reports to the SE on compliance with these general

conditions, the project EMP if any, and his own EHS-MP. An example format for a Contractor HSE report is

given below. It is expected that the Contractor’s reports will include information on:

HSE management actions/measures taken, including approvals sought from local or national authorities;

Problems encountered in relation to HSE aspects (incidents, including delays, cost consequences, etc. as a

result thereof);

Lack of compliance with contract requirements on the part of the Contractor;

Changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects; and

Observations, concerns raised and/or decisions taken with regard to HSE management during site

meetings.

58. It is advisable that reporting of significant HSE incidents be done “as soon as practicable”. Such incident

reporting shall therefore be done individually. Also, it is advisable that the Contractor keeps his own records on

health, safety and welfare of persons, and damage to property. It is advisable to include such records, as well as

copies of incident reports, as appendixes to the bi-weekly reports. Example formats for an incident notification

and detailed report are given below. Details of HSE performance will be reported to the Client through the SE’s

reports to the Client.

Training of Contractor’s Personnel

59. The Contractor shall provide sufficient training to his own personnel to ensure that they are all aware of the

relevant aspects of these general conditions, any project EMP, and his own EHS-MP, and are able to fulfill

their expected roles and functions. Specific training should be provided to those employees that have

particular responsibilities associated with the implementation of the EHS-MP. General topics should be:

HSE in general (working procedures);

emergency procedures; and

social and cultural aspects (awareness raising on social issues).

Cost of Compliance

60. It is expected that compliance with these conditions is already part of standard good workmanship and state of

art as generally required under this Contract. The item “Compliance with Environmental Management

Conditions” in the Bill of Quantities covers these costs. No other payments will be made to the Contractor

for compliance with any request to avoid and/or mitigate an avoidable HSE impact.


Example Format: HSE Report

Contract:

Period of reporting:

HSE management actions/measures:

Summarize HSE management actions/measures taken during period of reporting, including planning and

management activities (e.g. risk and impact assessments), HSE training, specific design and work measures taken,

etc.

HSE incidents:

Report on any problems encountered in relation to HSE aspects, including its consequences (delays, costs) and

corrective measures taken. Include relevant incident reports.

HSE compliance:

Report on compliance with Contract HSE conditions, including any cases of non-compliance.

Changes:

Report on any changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects.

Concerns and observations:

Report on any observations, concerns raised and/or decisions taken with regard to HSE management during site

meetings and visits.

Signature (Name, Title Date):

Contractor Representative

Example Format: HSE Incident Notification

Provide within 24 hrs to the Supervising Engineer

Originators Reference No:

Date of Incident: Time:

Location of incident:

Name of Person(s) involved:

Employing Company:

Type of Incident:

Description of Incident:

Where, when, what, how, who, operation in progress at the time (only factual)

Immediate Action:

Immediate remedial action and actions taken to prevent reoccurrence or escalation

Signature (Name, Title, Date):

Contractor Representative


ANNEX 6: SUMMARY OF WORLD BANK SAFEGUARD POLICIES AND HOW THEY WILL APPLY TO THE FUTURE

PROJECT ACTIVITIES

Environmental Assessment (OP 4.01). Outlines Bank policy and procedure for the environmental assessment

of Bank lending operations. The Bank undertakes environmental screening of each proposed project to

determine the appropriate extent and type of EA process. This environmental process will apply to major

Sanitation and Water rehabilitation projects under GAMA.

Natural Habitats (OP 4.04). The conservation of natural habitats, like other measures that protect and

enhance the environment, is essential for long-term sustainable development. The Bank does not support

projects involving the significant conversion of natural habitats unless there are no feasible alternatives for the

project and its siting, and comprehensive analysis demonstrates that overall benefits from the project

substantially outweigh the environmental costs. If the environmental assessment indicates that a project would

significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to the

Bank. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g. strategic habitat

retention and post-development restoration) and establishing and maintaining an ecologically similar

protected area. The Bank accepts other forms of mitigation measures only when they are technically justified.

Should the sub-project-specific ESMPs indicate that natural habitats might be affected negatively by the

proposed sub-project activities with suitable mitigation measures, such sub-projects will not be funded under

the project.

Pest Management (OP 4.09). The policy supports safe, affective, and environmentally sound pest

management. It promotes the use of biological and environmental control methods. An assessment is made of

the capacity of the country’s regulatory framework and institutions to promote and support safe, effective, and

environmentally sound pest management. This policy will most likely not apply to GAMA sub-projects.

Involuntary Resettlement (OP 4.12). This policy covers direct economic and social impacts that both result

from Bank-assisted investment projects, and are caused by (a) the involuntary taking of land resulting in (i)

relocation or loss of shelter; (ii) loss of assets or access to assets, or (iii) loss of income sources or means of

livelihood, whether or not the affected persons must move to another location; or (b) the involuntary

restriction of access to legally designated parks and protected areas resulting in adverse impacts on the

livelihoods of the displaced persons. The GAMA project may entail taking of land for new development and

there are aspects of the project that may cause displacement.

Indigenous Peoples (OD 4.20). This directive provides guidance to ensure that indigenous peoples benefit

from development projects, and to avoid or mitigate adverse effects of Bank-financed development projects

on indigenous peoples. Measures to address issues pertaining to indigenous peoples must be based on the

informed participation of the indigenous people themselves. Sub-projects that would have negative impacts

on indigenous people will not be funded under the GAMA.

Forests (OP 4.36). This policy applies to the following types of Bank-financed investment projects: (a)

projects that have or may have impacts on the health and quality of forests; (b) projects that affect the rights

and welfare of people and their level of dependence upon or interaction with forests; and (c) projects that aim

to bring about changes in the management, protection, or utilization of natural forests or plantations, whether

they are publicly, privately, or communally owned. The Bank does not finance projects that, in its opinion,

would involve significant conversion or degradation of critical forest areas or related critical habitats. If a

project involves the significant conversion or degradation of natural forests or related natural habitats that the

Bank determines are not critical, and the Bank determines that there are no feasible alternatives to the project


and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially

outweigh the environmental costs, the Bank may finance the project provided that it incorporates appropriate

mitigation measures. Sub-projects that are likely to have negative impacts on forests will not be funded under

GAMA.

Cultural Property (OP 11.03). The term “cultural property” includes sites having archeological (prehistoric),

paleontological, historical, religious, and unique natural values. The Bank’s general policy regarding cultural

property is to assist in their preservation, and to seek to avoid their elimination. Specifically, the Bank (i)

normally declines to finance projects that will significantly damage non-replicable cultural property, and will

assist only those projects that are sited or designed so as to prevent such damage; and (ii) will assist in the

protection and enhancement of cultural properties encountered in Bank-financed projects, rather than leaving

that protection to chance. The management of cultural property of a country is the responsibility of the

government. The government’s attention should be drawn specifically to what is known about the cultural

property aspects of the proposed project site and appropriate agencies, NGOs, or MLGRD should be

consulted; if there are any questions concerning cultural property in the area, a brief reconnaissance survey

should be undertaken in the field by a specialist.

Safety of Dams (OP 4.37). For the life of any dam, the owner is responsible for ensuring that appropriate

measures are taken and sufficient resources provided for the safety to the dam, irrespective of its funding

sources or construction status. The Bank distinguishes between small and large dams. Small dams are

normally less than 15 m in height; this category includes, for example, farm ponds, local silt retention dams,

and low embankment tanks. For small dams, generic dam safety measures designed by qualified engineers

are usually adequate. This policy does not apply to GAMA since the policy is not triggered under the project.

Projects on International Waterways (O 7.50). The Bank recognizes that the cooperation and good will of

riparians is essential for the efficient utilization and protection of international waterways and attaches great

importance to riparians making appropriate agreements or arrangement for the entire waterway or any part

thereof. Projects that trigger this policy include hydroelectric, irrigation, flood control, navigation, drainage,

water and sewerage, industrial, and similar projects that involve the use or potential pollution of international

waterways. This policy will not apply to GAMA.

Disputed Areas (OP/BP/GP 7.60). Project in disputed areas may occur between the Bank and its member

countries as well as between the borrower and one or more neighbouring countries. Any dispute over an area

in which a proposed project is located requires formal procedures at the earliest possible stage. The Bank

attempts to acquire assurance that it may proceed with a project in a disputed area if the governments

concerned agree that, pending the settlement of the dispute, the project proposed can go forward without

prejudice to the claims of the country having a dispute.


ANNEX 7: LIST OF INDIVIDUALS/INSTITUTIONS CONTACTED

MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT

SANITATION AND WATER PROJECT FOR THE GREATER ACCRA METRPOLITAN AREA (GAMA)

Accra Metropolitan Assembly (AMA), Accra Date: 17/11/2012

Name of Respondent(s) Designation Contacts

1 Metropolitan Development Planning Officer

Consultation Issues Responses

Formulation/Preparation of DMTDPs

1 How is the MTDP formulated? - Process begins at the grassroots, involving all relevant stakeholders including NGOs.

- The process is an open participatory process where all views and concern are collated through a series of community meetings and public forums.

2 How does the MMA select projects/communities

for inclusion into the MTDP? Are beneficiaries

consulted?)

- Projects are selected based on their priority within the community.

- The consultations involved are extensive and all beneficiaries are consulted.

3 What MTDP is currently being implemented and

what environmental and social problems are

often associated with the execution of the MTDP

projects?

- Upcoming projects are the Millenium City Projects (50 3-storey 18 classroom blocks, library with sanitary facilities.), Modernisation of Markets, Road projects, street lighting, Sanitation projects etc.

- Funding sources for these projects are USAID, SIF, GETFUND, Common Fund, Privates Companies etc .

- These activities often results in dust, construction wastes generation, noise nuisance and interruption of access ways.

EA Compliance in Implementing the MTDP Projects

4 Do the MMAs comply with the EA requirements

in implementing the MTDP projects?

Most major development Projects of the Assembly are subjected

to the relevant environmental assessment requirements.

However, ESIAs are not done some other Sanitation and

Water projects.

5 Are environmental permits obtained for the

projects prior to execution? Why not? Do the

MAs pay permit fees?

Yes, Environmental permits are obtained prior to the execution

of some projects.

Yes permit fees are paid. For some externally funded projects,

(eg SIF) environmental permitting fees are always incorporated

into the project cost..

6 How is the lack of capacity a factor in EA non-

compliance (no environmental and social

safeguards for projects)?

The AMA lacks an in-house capacity for environmental

assessment and management. The AMA therefore depends on

private consultancy services. The lack of the EA capacity affects

the monitoring and compliance enforcement of environmental

and social safeguards for projects.


7 Are planning approvals obtained prior to the

execution of the MTDP projects? Why? Are fees

paid? By & to whom?

Yes

Environmental & Natural Disasters

8

What types of environmental & natural disasters

have been plaguing the Metro/Municipality and

how often?

Flooding is a common occurrence during the raining season,

when there is a heavy down pour.

9 How do these disasters affect the livelihood of

the people – the most vulnerable and what

emergency response plans are available?

It affects many households, and interrupts commercial

activities, destroys assets of people and affects the livelihood of

the people. There are no proper emergency response plans readily

available but NADMO assist victims in such circumstances.

GAMA (Sanitation Water Facilities)

10 Is the second Urban Environmental Sanitation

Project (UESP II) being implemented in the

Metropolis/Municipality and how successful are

these?

Yes, the Metropolis has been benefiting mmensely from the

UESP II. There are ongoing UESP II project covering

sewerage improvement.

11 Any lessons for the GAMA (which is also has

urban Sanitation and Water facilities provisions)?

Technical and administrative structures and expertise in place

will be useful to the GAMA

12 What are the likely environmental and social

impacts that could result from the GAMA

investments?

The GAMA will generate employment opportunities and

improve Sanitation and Water services of the metropolis. Major

environmental and social impacts are not anticipated from the

GAMA. The potential environmental and social impacts may

relate to normal construction impacts, which could be addressed

through effective EA compliance and monitoring. Land

acquisition impacts and encroachment are potential social

concerns that may arise.

13 Are there any institutional needs and capacities

you may require to participate in the GAMA?

Particularly capacities for implementing and

monitoring the environmental and social

management framework to achieve its objectives.

Capacity strengthening for environmental assessment and

management within the AMA is very necessary.

14 Are there personnel in the MMA who can be

trained to meet the needs of the GAMA?

Yes

15 What challenges can we foresee & how can we

overcome them?

The success of the GAMA will depend on the MCEs so there is

the need for the MCEs to understand and accept the project for

good success. The MCEs need to be fully involved in the project.


ANNEX 8: TERMS OF REFERENCE FOR GAMA ESMF

MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT

Sanitation and Water Project for the Greater Accra Metropolitan Area

TERMS OF REFERENCE FOR PREPARATION OF AN

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF)

1.0 INTRODUCTION

The assignment for which these Terms of Reference have been prepared involves the preparation of an

Environmental and Social Management Framework (ESMF) to ensure that all investments envisaged under the

proposed Sanitation and Water Supply Project for GAMA are adequately screened for their potential

environmental and social impacts and that correct procedures to be followed to mitigate and minimize any

potential negative impacts arising from these investments.

The ESMF will be specific on the nature of mitigation measures but generic on the location and scope of

interventions as these will not be known during project preparation. The ESMF will provide clear guidance for the

preparation of site-specific EIAs and EMPs during project implementation. At this stage, specific environmental

and social issues will be investigated in detail and a full Environmental and Social Impact Assessment

undertaken.

Though a full EIA will be carried out for some specific investments with known locations such as the septic

sludge treatment facilities (anaerobic digesters), the potential environmental and social impacts of several other

investments are not presently determinable as some of the proposed project interventions will be identified

following a community consultative, participatory and to some extent demand-driven approach.

In such cases, communities will be selected to participate in project activities based on prevailing needs among

other factors and selected communities will be assisted to determine the specific nature and location of water and

environmental sanitation improvements. The nature of the interventions under the proposed project are directed

towards improving environmental conditions in communities as well as some city-wide enhancements in

management of waste and therefore it is anticipated that when fully implemented, the project will contribute

positively to overall environmental conditions within the project areas.

1.1 Project Development Objective(s)



facilities. In order to achieve this objective, the project would support the expansion and improvement of the

water distribution network, the expansion of community water points and private water connections, the

development of on-site and sewered sanitation facilities and the improved collection and treatment of wastewater

and faecal sludge. Behaviour Change Campaign on hygiene, sanitation and safe water will also be promoted

through social mobilization activities, as well as social accountability to ensure the sustainability of the facilities

and services.


Preliminary studies and assessment recognize the positive social and economic impact that the project can

generate. These assessments also highlight the potential negative social impacts and therefore the need for

mitigation measures. These concerns will trigger the World Bank’s safeguards policy on Involuntary

Resettlement, O.P 4.12. This implies that this project is likely to have social impacts on land access, restriction of

access to assets, displacement and loss of livelihood among others.

1.2 Project Description

The proposed project is structured as a two-phase Adaptable Program Loan (APL) given the long term

engagement required to increase access to sanitation and water in low income areas of GAMA and to attain an

efficient and sustainable operation and management of the services. The latter will require the development of a

satisfactory institutional arrangement for the integrated planning and management of water and sanitation services

that will constitute the main trigger to move to the second phase.

The proposed APL would be executed over the 2013-2020 period, with the two phases overlapping. The first

phase (APL-1) would extend from 2013 to 2016 for a credit amount of USD130 million. The second phase (APL-

2) would extend from 2016 to 2020 for a credit amount of USD170 million, but could begin earlier, as soon as the

trigger is met.

The proposed APL-1 would have the following four components:

Component 1 - Provision of water and environmental sanitation services to priority low income areas of the

GAMA (USD20 million). The MMAs will propose the priority low income communities to benefit from the

project based upon selection criteria to be agreed during project preparation. The type of water supply and

sanitation facilities will be thoroughly consulted and agreed with each community as to best suit their needs,

while taking into consideration particular conditions such as: soil characteristics, topography, space availability,

etc.








Component 2 – Improvement and expansion of the water distribution network in the GAMA (USD50 million).

This component will support investments required to improve and expand the existing network in order to provide

piped water to the target people living in low income communities in the GAMA. These investments include the

installation of transmission mains, booster pumps and any other facilities required to ensure that a share of the

additional water production reach the targeted low income areas. Therefore this component will be coordinated

with current and incoming projects supported by other development partners and private investors in the GAMA.

The priority of the interventions will be determined with the assistance of a hydraulic model for the GAMA to be

developed during project preparation. This component would also support the acquisition and installation of


meters and other equipment, as well as the provision of services, aimed at improving water demand management

and reducing non-revenue water.

Component 3 – Improvement and expansion of wastewater and fecal sludge collection, transportation and

treatment in the GAMA (USD50 million) This component will finance collection and/or treatment of wastewater

and fecal sudge to be generated from the low income communities and rest of GAMA. However, these facilities

will be seized to take care of the entire wastewater flows and sludge volumes generated in the GAMA, which

currently end up discharged untreated into drains and eventually into the sea. This component will also support

the development of solutions to improve the safe collection, transport and treatment of fecal sludge.

Component 4 – Institutional Strengthening (USD 10 million). This component will provide technical assistance

(TA) to municipal, metropolitan and national institutions, including the promotion of private sector initiatives for

water and sanitation. The subcomponents would be further developed during preparation but initially may

include:

a) TA to the MMAs, particularly to their Waste Management Departments for:

i. Strengthening capacity for the planning of sanitation services with active community participation;

ii. Capacity strengthening in oversight and enforcement of sanitation regulations and by-laws;

iii. Facilitating interface between households and private sector actors in the expansion of access to on-

site sanitation;

iv. Hygienic removal and transportation of decal sludge; and

v. Management of wastewater disposal and treatment sites, including delegation to private sector

operators.

b) TA to the MLGRD and the RCC of Greater Accra to:

v. strengthen the planning and coordination capacity of the RPCU in the short term; and

vi. support the development of a metropolitan institutional arrangement for integrated planning,

implementation, operation and management of sanitation facilities in the long term. The

discussion of this integrated institutional arrangement has already begun and will continue during

project preparation by means of a series of workshops and consultations with key stakeholders.

c) TA to GWCL for the establishment of a pro-poor unit to promote the access of water services to low income

areas and the sustainability of those services. This will include strengthening coordination and collaboration with

MMAs, NGOs, CBOs, WSDBs add local private sector.

d) TA to the MWRWH to support the institutional restructuring and/or adoption of management options to

improve the provision of water supply services in GAMA and other urban areas.


e) Support for the development and training of local private sector to provide sanitation services, especially latrine

construction and sludge removal/transport.

f) Carrying out of surveys to establish baselines and evaluate the impact of project supported activities in the low-

income communities and other GAMA areas.

2.0 OBJECTIVE

In World Bank-Financed projects, a key goal is to enhance positive and sustainable environmental and social

outcomes of the project by minimizing and/avoiding negative environmental and social impacts. Where avoidance

is not possible, an Environmental and Social Framework is developed which provides the framework within

which to address the issues. The objective of the assignment is to prepare an ESMF which will:

i. Establish the legal framework, procedures, and methods for the environmental and social planning,

review, approval and implementation investments to be financed under the project;

ii. Identify roles and responsibilities, including reporting procedures and monitoring and evaluation;

iii. Identify capacity/or training needs for different stakeholders to ensure better implementation of the


iv. Identify funding requirements and resources to ensure effective implementation of the framework.

3.0 SCOPE OF WORK

The Consultant shall undertake the following tasks:

i. Description of Project: Provide a brief description of the GAMA project to place the ESMF in the

relevant context. This would include a summary of the background to the project, the different

components and most importantly, the consultant shall identify the possible environmental and social

issues that each component and subcomponents are likely to generate and for which reason this

ESMF is being developed.

ii. Legislative, Regulative and Administrative Regime: The Consultant shall describe the legislative,

regulatory and administrative regime regarding the triggered Safeguards Policies that the project will

be operating. In addition the consultant shall include the requirements and approval

processes/procedures for specific environmental issues. The Consultant shall clearly identify and

highlight any significant changes in regulations/legislation and develop a stakeholders’ consultation

process that ensures that all key stakeholders, including potentially affected persons, are aware of the

objectives and potential environmental and social impacts of the proposed project and their views are

incorporated into the projects’ design as appropriate.


iii. Description of Baseline The consultant shall describe the baseline which will include the biophysical

and socio-economic environment for the participating Assemblies.

iv. Determination of Potential Impacts and Screening: The Consultant shall determine the types of

environmental and social impacts that could result from the likely investments. The consultant shall

also develop a simple environmental and social screening form to assist in the evaluation and future

reviews and assessments of investments. The form shall be attached to the main report as annex.

v. Environmental and Social Checklist: The consultant shall develop an environmental and social

checklist. The checklist shall outline simple mitigation measures for the identified potential negative

environmental and social impacts. The implementation of these will be guided by an Environmental

and Social Management Plan. The Management Plan shall consist of mitigation measures and

monitoring indicators.

vi. Institutional Needs and Capacity Building: The Consultant shall identify the existing institutional

needs and the capacity of all participating institutions from the national through to the local level.

This is to help assess what needs and capacities will be required for implementing and monitoring the

ESMF to achieve the intended objectives. Based on this analysis, the consultant shall develop a

training and capacity building programme on environmental and social safeguards for the identified

institutions. Any other technical support considered important may also be outlined by the consultant.

vii. Budget: The Consultant shall develop appropriate budget for the implementation of the entire ESMF.

viii. Public Consultations and Disclosure: The Consultant will undertake public consultations with the

relevant stakeholders including the different categories of project participants and other affected

people like the elderly, the youth, women and the disabled. The Consultant shall prepare in close

liaison with the Client, a Consultation Programme for the entire process, which:

a. Defines the terminology and methodology. The following terms should be defined and distinguished from

each other: consultation, information sharing, information dissemination, workshops, meetings, and

public hearings.

b. Identifies all stakeholders likely to be involved in the consultation process. The stakeholders will

encompass and will include organizations, state authorities (Water Resources Commission, EPA, Ghana

Water Company and relevant municipal/district assemblies),

c. Specifies the roles of the Client, the Consultant and the key stakeholders during the consultation process.

d. Presents an organization plan and schedule for the consultation of stakeholders.The program will define

the form of consultations (focus group meetings, community meetings, workshops, etc.), the category of

stakeholders to be included, and the schedule for consultation.


e. Includes a schedule for information dissemination to the public.

f. The Consultant shall plan: (i) informal and formal meetings for information sharing,(ii) public

dissemination of reports and studies, and (iii) public consultations as required by the Ghanaian EA

Regulation 1999, art. 17 and 18 (public hearings). The location and schedule of which will be discussed and

decided upon with key stakeholders.

g. Is in compliance with the Ghana Environmental Assessment regulation, 1999 (in particular art.15 “scoping

notice” and art. 17 “public hearing”) and with the World Bank policies, in a way which meets Bank and

Ghanaian requirements.

The consultation programme shall be designed very early during the studies and submitted to the Client. The

Consultant shall (i) lead the consultation process on behalf of the Client, (ii) participate in planning and

implementing the consultation process (iii) arrange workshops including relevant stakeholders (EPA, WRC,

GWC), and shall participate in public hearings and other activities defined in the Ghanaian regulation and World

Bank safeguard policies. Details of the consultations shall be attached to this report as an annex. The ESMF shall

be disclosed in the country by the client.

ix. The Outline for the ESMF Report: The minimum content of the ESMF Report should include an

Executive summary and all sections outlined under the scope of works of this TOR. There shall also be

technical annexes attached to the main report.

4.0 CONSULTANT QUALIFICATIONS

The assignment will be carried out by an Individual Consultant with 10 years post qualification experience

(postgraduate preferable) and at least five (5) years relevant working experience dealing with Environmental

Safeguards, Environmental Assessments and related issues. S/he should have proven experience with World Bank

Safeguard Policies and requirements as well as Government of Ghana environmental and social policies on

safeguards. In particular, experience in preparation of Environmental and Social Assessments, Environmental and

Social Management Frameworks, Environmental Management Plans is essential.

The Consultant’s familiarity with the workings of international development institutions like the World Bank,

IFC, African Development Bank among others will be an advantage.

5.0 ESTIMATED LEVEL OF EFFORT

It is anticipated that about two (2) staff-months will be required for the assignment. The duration of the

assignment will be for 10 weeks.

6.0 SCHEDULE AND DELIVERABLES

a. Inception Report: This report will have detailed work plan with output indicators of performance. This

will be discussed by the consultant, client and other experts to ensure quality of final outcome. Three (3)


copies shall be submitted to the client in addition to an electronic version. This will be delivered one (1)

week after signing of contract;

b. First Draft Report: This report will be circulated for comments and relevant issues raised incorporated

into revised version. Three copies shall be submitted to the client. In addition the consultant will provide

an electronic version. This will be delivered four (4) weeks after signing of contract.

b. Final Draft Report: This will be circulated for comments and relevant issues raised shall be incorporated

into the revised version. Three copies shall be submitted to the client. In addition the consultant will

provide an electronic version. This will be delivered three (3) weeks after submission of first draft.

d. Final Report: The final report should include a concise Executive Summary and should have all annexes

and bibliography and the dissemination/disclosure plan. This will be delivered one (1) week after receipt

of comments from the Client.

7.0 PAYMENT SCHEDULE

The payment schedule is outlined as follows and based on the stipulated deliverables:

20% of Contract Sum upon Submission of Inception Report

30% of Contract Sum upon Submission of First Draft Report

30% of Contract Sum upon Submission of Final Draft Report

20% of Contract Sum upon Submission and Acceptance of Final Report

8.0 ADMINISTRATIVE ARRANGEMENTS

The Project Coordinating Unit (PCU) at MLGRD will supervise this assignment. MLGRD will provide

the necessary administrative support and make available necessary documents, reports, data and contacts.

In addition, MLGRD will convey copies of the draft and final reports from the consultant to the World

Bank for comments prior to acceptance of the report and making final payments to the consultant.