Environmental and Social Assessment Framework for the ...
Decentralized Health System Development Project (DHSDP)
Environmental and Social Assessment Framework
(Adopted from the CDF Guidelines for Environmental and Social Assessment)
Introduction to Environmental Issues
1.1 Background
The main development objectives of the Decentralized Health System Development Project (DHSDP) is to meet the urgent health issues and needs in the war affected and underdeveloped areas of North Sudan including the Three Areas by providing basic health services including the required social and economic services and infrastructure. This emergency project aims to improve access to basic health care services in four conflict-affected and poor states by supporting, rebuilding and developing the decentralized health system, with particular focus on health financing reform. Within the target states, where public sector primary health care (PHC) services exist, they are hampered by insufficient funding which leads to poorly paid and motivated staff, insufficient equipment and pharmaceutical supply and generally poor quality services. Further, access to services, particularly by the poor, is limited due to user fees and drug prices, along with geographic, social and gender factors. As well, in many parts of these states, particularly the Three Areas, government health services are not present and the limited current services are provided by non-governmental organizations (NGOs).
The emergency project will support immediate improvements in PHC services, focusing on underserved regions including the Three Areas, by injecting resources into existing public sector health services, contracting service delivery to NGOs, and providing high-impact health interventions to households. The project will also reconstruct and develop key inputs to the PHC system in the four states, investing in state and local health administration capacity, health human resources, infrastructure and equipment. At the same time as working to improve services in these conflict-affected areas, the project will address the crucial system-wide policy issue of sustainable financing of PHC services under the decentralized system, with the objective of channeling greater national government resources towards secondary and primary health care services for which the states and localities are responsible. The project itself, with two-thirds co-financing from the national government, represents such an increase. The capacity of the federal and target state MoH will be developed to effectively translate increased fiscal resources into accessible and equitable health services. Monitoring and evaluation will be a particular so that government can measure the results of improved financing and system investments in terms of better household access to health care, particularly by the poorest.
This Report has been prepared to help develop and implement Environmental Guidelines for the Project. The report provides guidance in identifying environmental assessment and management needs for the various subprojects that are funded by the DHSDP under its different components.
1.2 Project components
Component 1: Expanding access to primary health care services by underserved populations
The objective of this Component is, in the immediate term, to improve access to primary health care services and high-impact health interventions by conflict-affected and underserved populations in the target states.
Sub-component 1.1: Expansion of coverage of primary health care services and high-impact interventions. This Sub-component will support expansion of basic health services to improve coverage of conflict-affected and underserved populations in the immediate term.
i) In underserved areas with some functional government health services, the project will support injection of resources into the existing PHC system allowing reductions in user fees and drug prices. This will involve an integrated package of support to targeted health services to be implemented by existing government systems, with technical assistance by contracted consultants.
ii) In areas with no existing government services, the project will finance mobile and temporary clinics managed and supplied by the State MoHs and staffed by government health workers reallocated from better-served areas and States.
iii) Another strategy for areas with no government health services is to finance private for-profit and non-profit firms and organizations to provide services on a contractual basis. This could include expansion of coverage of services provided by non-governmental organizations (NGOs) already operating in underserved areas.
iv) Prioritizing populations with little or no access to facility-based health services, the project will support the provision of high-impact health interventions directly to communities and households, with particular focus on reducing barriers to accessing care for women and vulnerable groups. This is intended to put knowledge and resources into the hands of households to improve their own health and will include interventions such as distribution of long-lasting insecticidal nets (LLINs) for malaria prevention.
Planning and consultation in each of the target States, ongoing during project preparation, will determine the implementation strategies to be followed in each targeted locality as well as resource allocation and phasing within the States. Consultation will include the Federal and State MoHs, other government stakeholders, local authorities – particularly representatives of conflict-affected and underserved populations in the Three Areas – and non-governmental and community-based organizations.
Sub-component 1.2: Pilot experiences to reduce barriers to access to primary health care services. The objective of this Sub-component is to improve the knowledge and experience of the health authorities with possible strategies and interventions to reduce barriers to access to primary health care services, particularly by women, vulnerable groups and the poor in general. Pilot experiences will:
i) Evaluate the implementation, effect on service utilization, and financial feasibility of subsidies for primary health care services with a large impact on morbidity and mortality.
ii) Measure the cost and impact on service utilization of financing the health insurance premiums for all children under-five and pregnant women in an area where the State Health Insurance Fund is functioning.
iii) Assess the effect on health service utilization by women of interventions designed to address gender-related barriers to access.
Other pilot experiences will be implemented as needs and opportunities for learning are identified during project implementation.
Component 2: Establishing the basis for reform and development of the decentralized health system
The objective of this Component is to increase the capacity of the decentralized health system to establish the basis for sustainable financing, reform and development. This will involve three Sub-components.
Sub-component 2.1: Capacity-building and policy development. The objective of this Sub-component is to lay the groundwork for reform and development of the decentralized health system through technical assistance and studies on priority systemic issues as well as capacity-building in selected areas. This is to set the basis for reforms, the implementation of which is anticipated to be beyond the timeframe of the project.
i) Health care financing. The project will support technical assistance to provide a stronger information base on current health financing in Sudan, including household out-of-pocket expenditures, National Health Accounts (NHA), and support the development of a reform strategy to improve financing of basic health services under the fiscal federal system. Work related to federal fiscal transfers and their allocation will be closely coordinated with other programs supporting the Fiscal and Financial Allocation and Monitoring Commission (FFAMC) created under the CPA. An in-depth study of the National Health Insurance Fund will be supported.
ii) Pharmaceutical supply. Technical assistance and studies will examine availability and barriers to access to affordable medication in order to inform the ongoing development and expansion of the Revolving Drug Fund system as well as improvement in the supply and logistics chain of the Central Medical Supplies (CMS).
iii) Health planning, budgeting and management by target State and Locality health administrations. Capacity-building and training will focus in the first phase of the project on the four target State MoHs. It will include institutional assessments to provide recommendations on organizational reform and development, and technical assistance and training in planning, budgeting, management and supervision. The project will support the Government’s Locality health system development efforts in the four target states, starting in phase one with support to the development of the policy framework in each state, including clear definition of roles and responsibilities, staffing and resource requirements, and sustainable financing arrangements. With the policy framework in place, the project will support in phases two and three training of local health administrators in planning, budgeting, and resources management.
iv) Monitoring and evaluation. Of particular focus for capacity building will be the monitoring and evaluation (M&E) functions of all three levels of government, including strengthening health management information systems (HMIS) and the capacity of administrators to effectively analyze and use data. Technical assistance at the federal and four target state levels will provide advice on the shape and structure of an effective M&E system in the context of a decentralized system. M&E of the project itself will contribute to the government’s experience and capacity in this area.
Sub-component 2.2: Development of primary health care human resources. This Sub-component will provide support to implementation of the FMoH human resources for health (HRH) strategy in the four target states, establishing the basis for improvements in the production, quality, and deployment and retaining of the PHC workforce. Of particular priority are medical technicians, nurses and midwives. The project will support the following:
i) National human resources for health (HRH) strategy development. The project will finance technical assistance to assist the development of sector-wide HRH strategies and policies, with a focus on PHC cadres.
ii) State PHC human resource development strategies. The project will support technical assistance to the State MoHs to carry out a needs assessment to determine HRH needs in the four target states, with a focus on PHC workers.
iii) Curriculum review and instructor in-service training. The project will support technical assistance to review PHC training programs and curricula. This will form the basis for support to refresher training for instructors.
iv) Rationalization and investment in training schools and equipment. In line with State-level HRH strategies, nurse and midwifery schools will be upgraded with physical renovation and equipment. Rationalization of training institutions will be done at the same time as new schools may be established in under-served states.
In Phase 1 of the project, situation analysis, policy and strategy development will receive the initial focus, as well as work on improving training curricula and programs. Teacher in-service training programs will be developed and limited rehabilitation of PHC training institutes will start. At the same time, the necessary assessments, planning and tender documents will be done to rationalize training institutions and plan new investment in subsequent phases.
Sub-component 2.3: Investment in primary health care infrastructure and equipment. This Sub-component will upgrade and expand the PHC infrastructure in the four target states, focusing on the areas where the network of health facilities is weakest. PHC facilities include health centers and district hospitals providing first-referral services, notably emergency obstetric care. The first phase of investment will consist of detailed planning, including assessment of the physical and functional status of PHC facilities, equipment needs, geographical distribution, identification of priorities for rehabilitation, and construction work, including the initiation of architectural studies. It is anticipated that the bulk of rehabilitation and construction will be carried out in phases two and three of the project.
Investment in PHC infrastructure and equipment will be closely coordinated with project’s immediate support to service delivery under Component 1. Health services in underserved areas receiving support under Component 1 will have priority in terms of capital investments so that they can transition to routine service delivery in permanent structures.
Sub-component 2.4: Project implementation. This Sub-component will finance the personnel and resources necessary to manage the project and coordinate the project activities at the federal and state levels. A Federal and State Project Implementation Units (PIUs) will be established with the necessary technical, procurement, financial management and monitoring and evaluation staff, recruited on a competitive basis.
1.3 Project location
The project will provide support to the poor, underserved and conflict-affected states of Southern Kordofan, Blue Nile, Kassala, and Red Sea, which have a total population of approximately 5.1 million. These states include the “Three Areas”.
1.4 The Purpose of the Environmental Guidelines
The project implementation will be designed to fit within the organization of the Multi Donor Trust Fund (MDTF) implementation framework. The Ministry of Finance and National Economy (MFNE) would have overall oversight on the MDTF Funded Projects. The Ministry of Health will oversee DHSDP implementation through a Project Implementation Unit (PIU) established under the Project. The PIU delegates day – to – day operations to States, localities or NGOs based on the implementation of project activities in rural areas. Among its mandates, the PIU will ensure that any sponsored subproject is environmentally sustainable. The PIU shall ensure the following:
- Environmental considerations are included as criteria for site selecting and developing activities to be supported by the project;
- Environmental assessment would become an integral part of the project cycle of any subproject;
- Environmental guidelines are followed and used.
The execution of the DHSDP sub-projects will be undertaken by States and localities through the establishment within each locality of a Locality Implementation Unit (LIU), while the community based subprojects will be implemented under the supervision of eligible Community Based Organizations (CBOs) or selected NGOs. The LIU shall ensure the following:
- Environmental guidelines are followed and used through out the project cycle;
- Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects.
The report is structured as follows:
• Chapter (1) – Introduction to Environmental Issues
• Chapter (2) – Overview of Environmental Impacts and Good Practice Mitigation Measures
• Chapter (3) – Policy, Legal and Administrative Environmental Framework for Sudan
• Chapter (4) – Environmental Assessment & Incorporation into the Program Cycle
• Chapter (5) – Environmental Assessment
• Chapter (6) – Environmental Management Plan
• Chapter (7) – Management Challenges
1.5 Environmental Assessment (EA)
The World Bank has several policies governing environmental safeguards, the most central of which is the Operational Policy (OP 4.01) on Environmental Assessment (EA) which defines the Bank’s environmental assessment requirements to ensure that funded projects are environmentally sound and sustainable. A screening process is undertaken for all funded projects to assess the magnitude and adversity of predicted environmental impacts and to determine the appropriate extent and type of EA. Depending on the type, location, sensitivity and scale of the project as well as the nature and magnitude of environmental impacts, all World Bank supported projects are classified into one of three categories:
Category (A) Projects those are likely to cause significant and possibly irremediable environmental impacts.
Category (B) Projects likely to cause lesser adverse impacts than those of Category A and the impacts are often remediable or mitigate able.
Category (C) Projects likely to cause minimal or no adverse environmental impacts.
All subprojects funded by the DHSDP are classified as Category B or Category C. For instance all income enhancement subprojects will be classified as Category C, while most social and infrastructure subprojects will be Category B. Subprojects that are likely to cause substantial negative impacts and are expected to fall in Category A will not be approved for funding.
The following Sections of the Environmental Guidelines provide guidance with respect to the preparation of environmental assessment for the various funded subprojects. These Guidelines are based on the World Bank Operational Policies (OP 4.01), the World Bank Environmental Assessment Sourcebook (1991) and its Updates. The user of these Guidelines should consult these references and should be also aware of the following World Bank’s environmental and social safeguard policies (Appendix C4):
- Environmental Assessment (OP4.01)
- Natural Habitats (OP 4.04)
- Water Resources Management (OP4.07)
- Pest Management (OP 4.09)
- Cultural Property (OP 4.11)
- Indigenous Peoples (OP 4.20)
- Involuntary Resettlement (OP 4.30)
- Forestry (OP 4.36)
2. Overview of Environmental Impacts and Good Practice Mitigation Measures
2.1 Positive Environmental Impacts
Most subprojects financed by the DHSDP will have positive impacts on the surrounding environment if they were well designed and properly implemented. For example, provision of adequate potable water supplies through boreholes or hand pumps, if linked to sanitation and health education, will improve health and socio – economic conditions of local communities. The implementation of appropriate water – harvesting techniques will have positive impacts on water and soil conservation and the enhancement of soil fertility leading to improvement of crop productivity and the generation of employment opportunities. Further, such activities, if combined with tree planting, can lead to the protection of the environment.
New rural roads (although are not expected to be financed under this project) can have significant economic and social impacts. These roads can facilitate access to health care, access to markets, social links and access to basic health, education and other community services.
The DHSDP will also generate environmental benefits through a variety of other mechanisms among which are:
- Generation of environmental assessment guidelines that can be used by other organizations or ministries, or could be adopted by the Ministry of Environment and other sectors for more general use;
- Training of government staff, NGOs and local community officials;
- Training of environmental specialists, thus increasing the number of environmental professionals in the country;
- Improved environmental awareness in the local communities.
2.2 Negative Environmental Impacts
2.2.1 Overview of Negative Environmental Impacts
The DHSDP will finance a considerable number of different types of subprojects associated with health care throughout much of Northern Sudan. A percentage of the funding will be allocated for: infrastructure and social development including potable water supply, wells and surface water protection; small wastewater collection, treatment and disposal schemes; land reclamation and rehabilitation of land terraces; rehabilitation and upgrading of health centers. Though intended to improve environmental and social conditions, these subprojects can generate a variety of negative environmental impacts during the construction and/or the operation. These impacts may be direct or indirect or cumulative.
Under certain conditions, some proposed subprojects may have considerable irreversible negative impacts and will not be approved for funding. These include:
- Land terracing on slopes greater than 40%
- Subprojects requiring deforestation
- Subprojects adversely affecting natural habitats and biodiversity.
- Subprojects that would affect cultural heritage sites.
- Subprojects that include the purchase and use of pesticides and herbicides.
(See Appendix A for elaboration)
The mitigation of negative environmental impacts may be achieved through various management routines including Environmental Management Plans (EMP), Operational Manual (OM) and Contract Clauses. Environmental impacts arising from the operation of the different subprojects can be minimized by appropriate site selection, good engineering design and appropriate construction techniques. The mitigation of construction impacts is usually achieved by ensuring the Contractor undertakes his work in accordance with good construction practices. Construction negative impacts are best dealt with by incorporating mitigation clauses into the Bidding Documents. Examples of good practice mitigation measures are given in Appendix (B). Site supervision staff must check that the works are carried out in accordance with these good practice measures throughout project implementation. Typical examples of negative environmental impacts that might arise from the construction of the various subprojects are given in Appendix (B).
A brief description of the different types of subprojects, the most common negative environmental impacts that might arise and possible mitigation measures are discussed in the following Sections.
2.2.2 Potable Water Supply Sub-projects
Water supply sub-projects funded by the DHSDP may include the provision of water distribution systems, hospital connections, well pumps and improvement of shallow hand dug wells. The most important environmental considerations associated with water supply subprojects include proper allocation and use of water resources, control and prevention of water contamination and adequate operation and maintenance of the system. Hence, it will be necessary to take the necessary measures to ensure adequate water quantity and quality at the source.
During the operation of the system, attention should be given to the proper prevention of contamination from livestock, solid wastes, agricultural practices, and human settlements. Testing of the water supply as required in each subproject monitoring plan should be performed on a regular basis to detect any contamination and to ensure the adequacy of the water quality. An operation and maintenance program should be also included as part of the subproject. Training of operators is an important measure to ensure sustainable Operation and Maintenance (O/M). It is important to link water supplies with sanitation and health education to change the behavior of water users in favor of sustainable development.
2.2.3 Wastewater Collection and Treatment Subprojects
Typical wastewater sub-projects for hospitals and health centers include septic tanks and small scale sewage collection systems not exceeding a total cost of US$ 100,000. The execution of wastewater treatment and disposal is not common in these subprojects, yet under certain circumstances such type of subprojects could be executed, particularly in small towns.
In most rural areas of the selected localities, the appropriate means of excreta disposal is through the construction of Ventilated Improved Pit latrines (VIP) as advocated by UNICEF and other international organizations. The VIP is found to be the most economical way to improve sanitation and to improve health conditions by linking it to programs of health education. However, special attention should be given to siting requirements as not to be close to shallow hand – dug wells to avoid contamination of water table. Construction of VIPs at hospitals or in health centers and other public buildings can have positive beneficial impacts, provided that mitigation measures are taken to avoid polluting the shallow water tables.
Septic tanks are provided to improve health conditions and to reduce the contamination of land and water resources. To meet these objectives, special attention should be given to technical siting requirements, the type of construction, and sanitary measures. Poor absorption, frequent runoff and contamination of water sources are among the major impacts that might arise from the poor conception and execution of septic tanks. Proper engineering design, acceptable to the World Bank, should be conducted.
Sewage collection subprojects generally involve the construction of underground collection pipelines and connections. In most cases the sewage collection system is designed and constructed without any type of treatment at the end of the pipeline. Collected sewage is either discharged to an existing sewage system or discharged without any treatment into water bodies. Connection to an existing sewage should not be conducted without ensuring that the capacity of the existing system is adequate to accommodate the additional collected sewage. Discharge of raw sewage to water bodies can adversely affect water quality and aquatic life. Treatment can include simple measures such as removal of debris by screening at the discharge point or use of settlement ponds prior to discharge.
Under certain conditions, the execution of a wastewater treatment and disposal subprojects could be justifiable particularly, in small hospitals. Though this subproject is intended to improve health and environmental conditions, it might have important negative impacts including, change in land use, pollution of natural resources from poorly treated wastewater, un-proper disposal and reuse of the treated effluent, etc. For such subprojects, an environmental assessment study will be required that addresses site analyses, type of treatment technology, operation and maintenance, etc (Appendix D).
2.2.4 Small Construction Subprojects
Small construction subprojects may include rehabilitation and upgrading of hospitals and health centers. In general, the construction of these subprojects will not cause significant negative impacts, however they should be screened for environmental considerations such as contamination from waste materials during construction, disturbances during construction (dust, noise, etc.) and environmental contamination during operation of the facilities such as inadequate sanitation facilities.
The most important considerations associated with hospitals and health centers, is the provision of adequate potable water, waste management and sanitation facilities. Handling and disposal of medical wastes is also an important environmental consideration for hospitals and health centers, and should be addressed during the design and operation of the facility. When rehabilitating or upgrading such subprojects, priority should be given to the rehabilitation of latrines and to the proper disposal of solid wastes and infectious wastes.
3. Policy, Legal and Administrative Environmental Framework for Sudan
3.1 Regulatory Framework for Environmental Impact Assessment (EIA)
The Sudan is a Federal country divided into 26 States with special consideration given to Southern Sudan according to the Interim Constitution of 2005. There are four levels of authority; National level, Southern Sudan Government, State level and Locality level. The powers are divided among the various levels as follows:
• At the National level, the federal organs exercise powers of planning, legislation and execution on Federal lands, natural resources, mineral and subterranean wealth, inter – State waters, national electricity projects, epidemics and natural disasters. Southern Sudan Government exercises powers within Southern Sudan and its States.
• The state organs within the boundaries of the State exercise power on: lands, natural resources, animal wealth, wildlife, non - Nile waters and electric power.
• There are concurrent powers where both Federal (National) and State organs exercise power on education, health, environment, tourism, industry and meteorology. The localities exercise powers within the locality boundaries through local orders to be approved by the locality legislative organ.
• The Interim Constitution provides for the creation of Commissions particularly, on land to assume among other things planning and allocation of lands and forests between Federal and State authorities.
Sudan is one of the first African countries that passed sectoral laws for the protection of the environment. However, these laws are further supported by an umbrella law enacted in 2001 "Environmental Conservation Act 2001". This Act provides general principles and guidelines to be considered in implementing any development project. The Law (Act) makes it the responsibility of the project proponents, before embarking on any development activity, to carry out an EIA to identify the positive and negative impacts of the project, together with recommendations to mitigate negative impacts. The Act provides definitions and clarifications regarding natural resources management, pollutants and sources of pollution, endorses the Polluter Pays Principle and specifies issues to be considered in EIAs (Article 18) which include:
• Description of the existing environment before the project;
• Description of the project activities;
• Assessment of potential environmental impacts, both positive and negative;
• Provision of recommendations to mitigate the negative environmental effects.
The implementation of the provisions of the Act, is entrusted to the Higher Council for Environment and Natural Resources (HCENR) established in 1991 and the Ministry for Environment and Physical Development (MEPD) established in 1995.
Environmental protection is further supported by the Interim National Constitution of the Republic of the Sudan 2005. This Constitution is based on the provisions and articles of the Comprehensive Peace Agreement (CPA) 2005, and relevant articles of the 1998 Constitution of the Sudan. The Interim Constitution endorses the rights of citizens to live in clean environment (Article 11) and directs attention to the protection and conservation of natural resources. Article 43 (2) of the Interim Constitution gives the National Government the right to expropriate land for development purposes and compensate the owners. There are a number of articles related to natural resource management, pollution control, protection of cultural heritage sites and respect of traditional and customary regulations related to land ownership. The Interim Constitution also specifies land issues which are under National powers (Federal level) and those under the control of states as well as joint powers (concurrent powers) shared by the Federal and States institutions. The states manage issues related to State lands which are not under the National control. These include; management, lease and utilization of lands belonging to States, town and rural planning and agricultural lands within the state boundaries. The concurrent powers include matters related to urban development, planning and housing, electricity generation, waste management, consumer safety and protection, water resources other than inter – state waters and regulation of land tenure and the rights on land.
Articles of the Constitution and the Environment Conservation Act (2001) of relevance to this project are the right to expropriate land and compensate the owners as well as issues related to the safety and protection of the inhabitants, beside penalties incurred for environmental damage and pollution as well as respect of the International Environmental Agreements, ratified by the Sudan.
Land Regulations
These regulations are specified in the Interim Constitution Part Thirteen under Chapter II – Land Resources, in Article 186. It is stated that:
1. The regulation of land tenure, usage and exercise of rights thereon shall be a concurrent competence, exercised at the appropriate level of government.
2. Rights in land owned by the government of the Sudan shall be exercised through the appropriate or designated level of government.
3. All levels of government shall institute a process to progressively develop and amend the relevant laws to incorporate customary laws, practices, local heritage and international trends and practices.
Specific details and procedure on land are found in sectoral laws such as:
• Land Registration and Settlement Act 1925: this Act provides rules to determine rights on land and other rights attached to it and ensure land registration.
• Unregistered Land Act 1970: this Act deems any unregistered land, before the enactment of this law, as being registered in the name of the government.
• Land Acquisition Act 1930: This Act gives the government the power to appropriate lands for development purposes in accordance with the provision of the Constitution and Civil Transaction Act 1984.
• The Civil Transactions Act 1984: this Act regulates the different issues related to civil transactions with respect to titles on land, means of land acquisition, easement rights and conditions to be observed by land users. And gives guidelines and details for practical implementation of the 1970 Act.
• Disposition of Lands and Physical Planning Act 1994: this Act regulated designation of lands for different purposes and urban planning.
Customary Land Tenure
The above are formal legislations passed by the government to organize land tenure. However, most of Sudan’s lands are organized by customary and traditional rules and regulations. Private ownership is found only in areas along the Nile where land registration was carried according to Land Registration & Settlement Act of 1925. Most of areas away from the Nile are under traditional communal tenure where rights over land less than full ownership are recognized. Hence, in these areas four forms of land tenure emerged. These are:
1. Government lands with community rights;
2. Government lands with no community rights (unoccupied lands, wetlands, water catchments, etc);
3. Hawakir (land recognized as tribal homeland – Dar, or areas granted to individuals by previous Sultans);
4. Lease (licence): land granted by the government to investors for a limited number of years.
Within the customary land tenure, there is the tribal homeland (Dar) with demarcated boundaries recognized by neighbouring tribes and local authorities (e. g. Dar Hamar where Wad Banda locality is located, or Dar Kababish where both Sodari and Jabra are located). The tribal land is organized and supervised by Nazir (the chief tribal leader). Within the tribal land, there is clan land organized by Omda. Within the clan land, there are a number of villages, each with its land organized and controlled by the village Sheikh. Within the village land, each villager practices his private ownership respected and recognized by all. The unclaimed land is used as range land or allotted to migrants by the village Sheikh provided that they respect the traditional rule of surrendering 1/10 of the crop to the Sheikh. As a general rule, land allotted to any person can not be withdrawn unless he/ she leave the village. Under such circumstances, the land abandoned by any person reverts to the community to be allotted to someone else. In all cases, the owner of the land is free to hire part of his land or dispose of it in the way he likes and after death, the land is inherited by his children or relatives.
These customary rules are to be respected in any development activity. Land needed for public use and according to Civil Transactions Act 1984, the owner must be compensated in any form – land for land, a small fee or in many cases, the village community willingly donate land needed for public use. It is not expected that the DHSDP projects in the areas selected will cause problems of compensation.
It should be noted here that pasturelands and water resources (pools) are communally owned and utilized. They are not appropriated by individuals and pasturelands are always defined as uncultivated lands. Nomads have corridors (Murhal) to avoid farms and allowed to utilize uncultivated areas. Tribal chiefs usually specify these routes and grazing areas for nomads.
Generally, these Acts provide procedures for land expropriation for development purposes and ways to specify rights in order to compensate the owner. The Urban Planning Act sets specific rules for the separation of industrial areas from the residential ones.
In carrying out EIA, the legal requirements are not confined to the above mentioned Acts. There are other important sectoral laws that must be considered and used as yard sticks to identify the negative environmental effects. The Environmental Health Act of 1975 and the Public Health Act 1975, provide regulations and restrictions for industries regarding water and air pollutions (standards). According to these Acts, protection obligations extend to cover animal and plant life. Specifically, the Acts cover issues related to collection, treatment and disposal of waste. Also, they prohibit water pollution by addition of any solid or liquid wastes, chemicals, sewage and remains of animals on water resources such as rivers, hafirs, and wetlands. On the other hand, the Electricity Act of 2001 controls the electricity market. It provides regulations regarding the protection of network and standards regarding environmental protection. Article 9 of the said Act requires that any developer (investor) must comply with existing laws regarding roads, water courses, communication network, environmental issues and archaeological sites. Article 13 explains the environmental standards that must be taken into consideration when establishing power plants. Article 17 requires compensation to any damage that the project may cause to life and property.
Other laws of relevance to this project include; the Investment Act of 1999 which requires an EIA study as a pre - condition for giving licence to implement the project, the Industrial Safety Act 1976 which tries to protect the work environment and safety of workers and the Location of Industries Act of 1977 which prohibits the location of industries in residential areas.
Beside these National Laws, the Sudan signed and ratified a large number of Multilateral Environmental Agreements. International agreements of relevance to this project include:
• Bio – diversity Convention.
• Desertification Convention.
• United Nations Framework on Climate Change.
• Bamako Convention on Trans - boundary Movement of Hazardous Waste.
• Vienna Convention (ozone layer depletion).
• Montreal Protocol.
• Ramsar (wetlands) Convention.
• Kyoto Protocol.
In fact, the ratified treaties become part of the National Laws and their provisions prevail in case of contradictions with the provisions of the National Laws. Accordingly, the Sudanese courts apply the provisions of the international treaties in issues raised before the courts. As the result of Sudan becoming a party to some treaties, the country received help in the preparation of the National Strategy and the Action Plan on Biodiversity, Sudan's National Communication on Climate Change and the National Action Plan to Combat Desertification.
3.2 Institutional Arrangements: National & Local Levels
The institutions at National Level responsible for the implementation and monitoring compliance to both national and international agreements include:
• The Higher Council for Environment and Natural Resources (HCENR);
• Ministry of Environment and Physical Development (MEPD);
• Federal Ministries of Health, Industry and Agriculture;
• Ministries and Councils at State Level.
The environmental acts and laws provide standards to be applied in assessing the probable environmental impacts of the project. It is important to note here that State Organs and Local laws deal with issues at State or Local levels, while the Federal Acts are more concerned with general directives and set limits and standards to certain environmental concerns without going into details of problems of local nature.
Based on the provisions of these legal requirements and sectoral laws as well as policies of different departments, the impacts of the proposed projects are to be assessed and appropriate mitigation measures recommended.
Although EIA is a requirement of the Sudan Environmental Conservation Act of 2001, EIAs were being undertaken before 2001 for most projects, especially those funded by international organizations and Agencies. In most cases, EIA is being conducted by prominent local and international consulting firms and submitted to the HCENR for approval. At the ministerial level, only the Ministry of Energy and Mining has established an Environmental Unit with guidelines for companies working in petroleum development.
Sudan’s Environmental Conservation Act (2001), particularly the Articles related to EIA, still requires incorporation of by – laws and adopts more specifications on standards. In this connection, the work of Sudan Standards and Metrology Organization (SSMO) adds to the legal requirements for environmental protection.
At the State Level, only few States have established State Environmental Councils and hence, the provisions of the Environmental Conservation Act (2001) are applied with modifications to suit local problems within the guidelines specified in the above Act.
Institutions at local level with environmental concerns
Beside the government institutions responsible for environmental management, there are also local ethnic institutions that play important roles in environmental management at local level. These include:
- Native Administration (Nazir, Omda, Sheikh); the Native Administration implements both traditional customary regulations as well as delegated the authority to implement forest and range and pasture regulations. In this respect, they organize village land for agriculture and areas to be left for grazing. They also organize nomadic corridors, specify their grazing areas and mobilize local communities to: open fire lines to protect rangelands from bush fires; to fight locust attack; prohibit illegal tree felling; and, organize use of water resources. Despite changes introduced by the government in the structure of Native Administration, they still play very important roles in natural resource management and in mobilization of local communities.
- At the village level, there are a number of institutions with inputs in environmental management, the most important of which is the village Sheikh who controls land allotment and takes part in specifying grazing areas.
In recent years, nearly all villages have elected popular committees to administer the village affairs in coordination and collaboration with the Sheikh. Any development activity at the village level starts with permits or requests issued by the Village Popular Committee to be raised to the locality for approval. In the environmental field, such committees play important roles in sanitation and garbage collection beside taking part in mobilization of local communities and providing direct links to the locality for any issues related to village affairs (Table 3.1).
Table (3.1) Institutional Arrangements in Environmental Decision – Making
|Institution |Mandate |
|A. At National Level: | |
|Ministry of Environment & Physical Development |Minister chairs the Higher Council for Environment |
| |Environmental Physical Development Policies |
| |Supervision |
|Higher Council for Environment & Natural Resources|Environmental Policies / Plans |
|(HCENR) |Guidelines |
| |Approves EIAs |
| |Sign International Conventions |
| |Monitoring |
|Line Ministries |Implementation of environmental policies and plans |
| |Implement Sectoral Laws |
| |Coordinate with State Ministries |
|B. At State Level: | |
|State Ministries |Implement State Policies |
| |Implement Sectoral Laws (National or State Laws) |
| |Approval of development activities |
|C. At Local Level: | |
|Localities |Implement local orders on Public Health |
|Popular Communities, CBOs and NGOs |Implement local orders on locality natural resources |
| |Implement State Laws |
| |Approval of projects at Locality Level |
| |Implement local orders |
| |Mobilize local communities |
| |Submit requests for development activities |
3.3 Other Existing Legislation
Beside the laws mentioned in section 2.1, there are more than 150 sectoral laws, orders and related regulations addressing environmental issues. The enforcement of these laws is entrusted to about 33 different Government Institutions. The major legislations of relevance to the DHSDP project include (Appendix A):
1. Forest Act, 1989, which identifies three types of reserved forest: National, Regional, and others which may belong to communities, local institutions or individual citizens.
2. Wildlife Protection Act, 1936.
3. Agricultural Pest Control Act, 1919.
4. Animal Diseases Act, 1973.
5. Quarries and Mines Act, 1973 and its by – low of 1973.
6. Environmental Protection in Petroleum Industry, 2001 (draft).
7. Industrial Safety Act, 1976.
8. Water Policy, 2001 (draft), other water – related legislations.
9. Investment Promotion Act, 1999.
10. Sudan Antiquities Act, 2002.
Beside these sectoral laws implemented by Federal Institutions, there are also State Level Laws based on National Laws with emphasis on particular local or State problems. However, most of these are considered local orders issued by localities to address problems related to pasture and grazing which are based on customary tenure to specify corridors to be followed by nomads.
3.4 Permit Procedures
Depending on the type and size of the subprojects to be implemented and according to the National and State legislation requirements, a number of approvals and permits might be required from various governmental agencies (Table 3.2).
Table (3.2) Permits Required for Various Projects in Urban & Rural Areas
|Project Type |Permit required & authority issuing it |
|Health Centres |Locality and State Ministry of Health |
|Boreholes |Locality and State Ministry of Engineering Affairs |
|Hafirs |Locality and State Ministry of Engineering Affairs |
|Hand Pumps |Village Popular Committee, Locality & State Ministry of Engineering Affairs |
4. Environmental Assessment & Incorporation into the Program Cycle
Following the approval of the DHSDP, the subprojects will be identified, and consequently, will be selected and developed with the assistance of the Project Implementation Unit (PIU), Locality Implementation Unit (LIU) and the community. The environmental requirements are detailed in the Guidelines, including the institutional and legal framework based on site visits and taking into consideration the provisions of Sudan’s Environmental Act (2001). This section therefore addresses the procedures and guidelines for carrying out the DHSDP environmental requirements at the program and project level.
4.1 Institutional Arrangements
The Project Appraisal Document (PAD) provides the following management arrangements:
- PIU: responsible for the project administration
- LIU: responsible for design and implementation of regional programs.
For Category B programs and/or subprojects, the PIU need the services of an Environmental specialist who will be responsible for:
- Reviewing the environmental screening of the program submitted by the LIU;
- Reviewing and approving the environmental assessment;
- Obtaining the approval of the Higher Council for Environment for projects requiring an environmental assessment report;
- Conducting periodic monitoring of the programs;
- Preparing annual report of the environmental situation of the DHSDP.
The LIU will be in charge of the environmental operation of the program. They will have environmental specialists familiar with community development projects. Some LIU may not have an environmental specialist and would be required to have the services of an environmental consultant for performing the following duties:
- Promote the environmental requirements and guidelines of the DHSDP among NGOs, communities and contractors;
- Ensure that Environmental Checklist is properly filled;
- Provide assistance to NGOs in preparing the environmental assessment;
- Conduct site specific environmental review in order to review the current environmental conditions of site and assess the potential environmental impact associated with the proposed subproject;
- Identify mitigation measures in construction and operation;
- Supervise the implementation of environmental management plans;
- Prepare necessary reports.
4.2 Program Cycle
The DHSDP operates in accordance with procedures documented in the Project Implementation Manual (or Operational Manual) that defines steps required for implementing subprojects supported by procedures, reviews and measures to ensure accountability. Critical steps in the DHSDP project cycle include: identification, preparation, appraisal, approval, implementation, supervision, monitoring and evaluation.
Environmental review procedures will be incorporated in the project cycle at the program and subproject level. The timeframe for the completion of the environmental procedures will be the same as that given in the Operational Manual for the completion of the administrative and technical procedures. Table 4.1 summarizes the environmental requirements of each stage of the DHSDP program / subproject cycle.
Table 4.1: Environmental Requirements within each Stage of the DHSDP Program / Subproject Cycle
|Program Development |Environmental Requirements |
|1. Program identification: | |
|Identification of demand driven subprojects. |Increase awareness of beneficiaries about proposed projects and |
|Preparation of subprojects concepts. |introduction of environmental issues. |
| |Screening of subprojects by Locality Implementation Unit (LIU). |
| |Preparation of environmental checklist by Locality Implementation Unit |
| |(LIU). |
| |Approval of Environmental Data Sheets (EDS) by Project Implementation Unit|
| |(PIU). |
|2. Program Preparation: | |
|Description and analysis of subprojects. |Preparation by LIU or consultants of: |
| |Environmental Assessment (EA) report in case of subprojects or; |
| |Environmental Management Plan (EMP) on the basis of generic mitigation |
| |Ensure that environmental impacts have been analyzed and appropriate |
| |mitigation measures designed. |
| | |
| | |
|3. Appraisal and Subproject Approval: |Inclusion of mitigation measures in: |
|Select the most needed and environmentally sound projects for |Subproject design |
|funding. |In tender documents for civil works |
|Screen proposals to categorize subprojects according to the type of |Ensure that environmental requirements are costed in subproject agreement |
|environmental review that will be necessary. |with civil works contract and NGOs as appropriate. |
| |Approval of the Higher Council for Environment and Natural Resources |
| |(HCENR) and the World Bank in case an EA report is required. |
|Program Development |Environmental Requirements |
|4. Program Implementation & Supervision: | |
|(i) At Subproject Level: | |
|Implementation of most needed and environmentally sound subprojects. |(i) At Subproject Level: |
| |Locality Implementation Unit to ensure that mitigation measures and |
| |monitoring measures are implemented through field visits. |
| |Prepare contracts with environmental clauses for companies, NGOs and |
| |communities that execute subprojects. |
| |Undertake site visits to ensure that environmental criteria and mitigation|
| |measures, as required by contracts, have been implemented. |
| |Changes may be introduced to subproject design and / or implementation if |
| |unforeseen impacts occurred. |
| |Locality Implementation Unit is to prepare annual report on the status of |
| |Environmental Management Plans. |
| | |
| |(ii) At Program Level: |
| |Preparation by Project Implementation Unit of annual report summarizing: |
| |The number of subprojects that have significant environmental impacts. |
| |The number of projects for which EMPs were prepared. |
| |The mitigation measures implemented for subprojects that have significant |
|(ii) At Program Level: |environmental impacts. |
|Supervision of contracts / works |Number of training workshops implemented. |
|5. Monitoring & Evaluation: | |
|Site visits to assess performance |Assess how environmental and mitigation measures are succeeding or have |
| |succeeded in minimizing impacts. |
| |Determine if changes in the project design or implementation are needed to|
| |improve environmental conditions or assessment process. |
| |Meet with contractors and community representatives to get feedback. |
| | |
| | |
4.3 Environmental Screening at the Program Level
With respect to environment, the first step would be to screen each subproject and identify whether any further environmental considerations are required. The purpose of this is to identify early in the subproject cycle the need to address potential environmental impacts during the project preparation and design. On the other hand, an effective screening will identify subprojects that will generate negligible or no negative environmental impacts so that they can be excluded from unnecessary environmental review. Once all the subprojects of a program have been screened, an environmental data sheet (EDS) for the program should be prepared. A sample EDS form is included in Appendix (C).
As mentioned earlier, the DHSDP will fund a number and a variety of subprojects. While most subprojects will not require environmental assessment, the approval of some subprojects may be subject to the completion of an environmental assessment. Depending on the type and size of the subproject, different levels of environmental assessment instruments might be required. Subprojects that should be screened to identify the type, magnitude and severity of their potential environmental impacts include:
- Rehabilitation and upgrading of health centers
- Community potable water supply
- Shallow hand – dug wells or Hafirs
- Small wastewater disposal schemes
- Land reclamation and rehabilitation
- Protection of natural and cultural heritage sites
- Water harvesting projects
For these projects, environmental screening for potential environmental impacts should be conducted using the environmental checklist given in Appendix (C). This environmental review would be prepared by the LIU with technical assistance, if necessary, from PIU Environmental Specialist. The purpose of this checklist is to better identify the likely impacts and to classify the subprojects into one of the following categories:
- No further environmental assessment
- Identification and implementation of mitigation measures according to the Environmental Management Plan (EMP).
- Environmental Assessment Study required
The decision to conduct an environmental assessment will be based on Sudan Environmental Act (2001). Where an EA is required, the PIU and the LIU will prepare TOR, including attention to public participation. After preparing the EA, the PIU requires the approval of the HCENR before financing particular subprojects may proceed.
4.4 Promotion of Subprojects within the Regional Program
The first stage in the DHSDP program cycle is to initiate promotional activities and prepare demand driven subprojects. The PIU and the LIU’s primary responsibility would be to initiate promotional programs that aim at disseminating information about the DHSDP’s objectives, guidelines and procedures among targeted community groups. Promotional activities will include environmental considerations in the promotional programs in order to ensure that environment is integrated in the project cycle. LIU would have to educate communities and to raise awareness on environmental issues and requirements of DHSDP subprojects. This process of awareness will help communities to better appreciate environmental concerns and to select environmentally sound and beneficial subprojects. Environmental NGOs may be sub – contracted to raise community awareness about environmental issues and project funding environmental requirements.
4.5 Preparation of Subprojects
Following the initiation of promotional programs and identification of the needs and priorities, project proposals will be prepared and a program will be submitted to the PIU for appraisal. Subprojects that necessitate environmental assessment will either require the identification and implementation of mitigation measures or the preparation of an environmental assessment report.
Projects requiring the identification and implementation of mitigation measures are those considered to have minor environmental impacts. For these subprojects, the environmental expert of the LIU will identify appropriate mitigation measures to be incorporated in the project design and in the bidding documents (Appendix B).
An Environmental Assessment would be required whenever significant environmental impacts are likely to arise from a specific subproject. In this case an environmental impact assessment report should be prepared and shall follow the terms of references provided in (Appendix D). The EA will require the involvement of a highly skilled environmental expert or a team of experts. Several site visits would be undertaken, subproject specific measures would have to be planned and a detailed EMP developed.
DHSDP subprojects will rarely need an EA. Subprojects most likely to require an environmental assessment report would be based on the Environmental Conservation Act (2001) and include (see Appendix A):
- Wastewater collection, treatment and disposal subprojects;
- Subprojects adjacent to critical natural habitats or protected areas
- Waste management, collection and disposal.
Subproject requiring an EA are subject to review and approval of the HCENR and the World Bank.
4.6 Appraisal and Approval of Proposed Programs
Once prepared, the proposed program is submitted to the PIU for appraisal and approval (Appendix C). Desk and field appraisals will be conducted by the PIU to ensure the eligibility of the program and to validate the information included in the proposal package. The environmental assessment of the program will be undertaken during program formulation so that the PIU Environment Specialist may review the environmental assessment requirements (screening checklist, Environmental Data Sheet (EDS), environmental assessment, reports, etc) and assess whether the suggested mitigation measures are appropriate and integrated effectively into subproject design. Based on the LIU proposals, the PIU will either conduct desk review or a field review depending on the nature, magnitude and severity of predicted environmental impacts determined during preparation.
4.6.1 Desk Review
The PIU environmental specialist will first check whether subprojects under the program have been screened properly and whether an EDS has been prepared. The EDS will then be checked for completeness and consistency with the other submitted technical data. Any missing information or apparent inconsistencies will be reported and the LIU will be requested to provide the necessary clarification and information.
Once any required clarification is received and the EDS has been satisfactorily completed, the PIU Environmental Specialist will assess whether field review of any subprojects would be required. In such instances, the LIU will be informed that the PIU, with the assistance of the LIU, will need to conduct a field review (see below). If only a desk review is requested, the PIU Environment Specialist will proceed with the revision of the documents.
4.6.2 Field Appraisal
Once the desk review has been completed, the PIU Environment Specialist will undertake a field visit to agree with the LIU and the stakeholders on the requirements of an environmental assessment.
Discrepancies between the environmental information presented and the PIU Environment Specialist’s findings will be dealt with as follows:
- For issues that can be clarified on site, the PIU Environment Specialist will make his / her own assessment of the situation during the field visit.
- For issues that may have significant environmental problems, the PIU Environment Specialist will require the applicant to collect additional information and to properly address the problem either through undertaking further environmental analysis or through the inclusion of additional requirements in the Operational Manual and / or bidding documents.
4.6.3 Approval of Program
The results of the appraisal of the various environmental documents will be summarized in an environmental appraisal form shown in (Appendix C), and will be included with the Sub-project Appraisal Report. For subprojects requiring a full environmental assessment, the PIU will be required to obtain the HCENR prior approval. During the first year of project implementation, the World Bank will be required to review and approve the environmental assessment after the HCENR’s approval and before financing is authorized. Post review of EA will be subsequently undertaken as part of the regular Bank supervision missions provided that the World Bank is fully satisfied that the EA requirements comply with OP 4.01 during the first year. The PIU will have to ensure that the recommendations of the environmental assessment are included in the technical specifications of the construction bidding documents and in the mitigation measures developed for each subproject incorporated in the Operational Manual (Appendix B)..
4.7 Implementation and Supervision
Upon approval of the program proposal, arrangements regarding construction, implementation and supervision will be contained in the agreement between the LIU and PIU. It will be necessary that the PIU ensures that the results of the environmental assessment (special mitigation measures, design specifications, supervision plans and monitoring arrangements) are incorporated into the document.
The execution of the subproject contract and construction supervision is the responsibility of the LIU. Where they do not have adequate in-house resources, the LIU will be responsible for the appointment of a supervision consultant. Part of the construction supervision duties is to ensure that mitigation measures are properly implemented, good practice environmental procedures are respected and that no unforeseen negative impacts are occurring as a result of subproject execution.
4.8 Monitoring & Evaluation
Environmental monitoring of a project performance will start with the construction phase and will extend to the operation phase. It measures how a subproject is performing regarding implementation of mitigation measures during construction and operation. Hence, site visits during subproject execution and operation are to be carried to assess how environmental screening and mitigation measures are succeeding or have succeeded in minimizing impacts. Based on the results of the monitoring and evaluation of how well the subproject has addressed environmental considerations, changes may be needed to improve the environmental performance of the subproject.
5. Environmental Impact Assessment
5.1 Environmental Impact Assessment Objectives
Environmental Assessment (EA) is a tool that enables decision making to assess the impacts of a development activity on the environment and to identify and evaluate the applicability of mitigating measures for potential negative environmental impacts. The EA also ensures that:
- The project under consideration is environmentally sound and sustainable;
- Any environmental consequences are recognized early in the development stage and incorporated into the project design;
- The project is implemented with full awareness of environmental issues;
- The public participates in the decision-making and is well informed about when and how project implementation may affect their environment.
5.2 Environmental Assessment Requirements
As mentioned earlier, all DHSDP subprojects that require environmental assessment fall under Category B and consequently would require some form of environmental analysis, the detail depending on the type, scale and location of the subproject. For the majority of these subprojects, the identification and implementation of mitigation measures will be sufficient.
For large scale subprojects that include construction of wastewater collection, treatment and disposal, or construction near or adjacent to critical natural habitats or protected areas, an Environmental Assessment will be required. The EA should provide a clear understanding of the environmental issues and the remediation measures. The EA is an important requirement according to Sudan's Environmental Act 2001 and should be prepared in accordance with the World Bank operational, environmental and social policies. The latter requires the following coverage in the EA:
– Executive Summary;
– Relevant Policy, Legal and Administrative Framework;
– Subproject Objectives and Description;
– Summary of Environmental Baseline Data;
– Significant Environmental Impacts;
– Analysis of Alternative Proposals for the Subproject;
– Environmental Management Plan (EMP) that includes:
• Environmental Mitigation Measures;
• Environmental Monitoring Plan;
• Institutional Responsibilities and Capacity Building Requirements;
• Appendices;
A general description of the expected content for each section of the EA report is given in (Appendix D).
5.3 Terms of Reference for EA Report
The terms of reference (TOR) for an EA report should provide background and guidance for the EA team on the issues to be addressed and the actions to be undertaken during the EA study, set the schedule and deliverables of the EA study report, and serve as the contractual basis. In addition to the description of the information required in the EA report, the TOR should provide background information on the proposed project and would include:
a brief description of the major components of the proposed project
a statement of the need for the project and the objectives it intends to meet
the implementing agency
a brief history of the project, including alternatives considered
its current status and timetable
a brief description of any associated projects
The general requirements for each EA report will be similar and should follow World Bank’s OP/BP/GP 4.01 – Environmental Assessment at the World Bank. However, there are likely to be minor variations related to the type and location of individual subprojects.
Sample TORs that should be considered in an EA of a new road subproject are given in (Appendix D).
6. Environmental Management Plan (EMP)
6.1 Objectives and Structure of the EMP
The Environmental Management Plan (EMP) will be used to verify that predictions of environmental impacts developed during design phase are accurate and that unforeseen impacts are detected at an early stage. The objectives of the EMP are to mitigate the adverse environmental impacts identified in each subproject and will consist of three kinds of activities:
- Implementation of mitigation measures;
- Strengthening the capacities of PIU, LIU, local NGOs and contractors;
- Monitoring and evaluation of mitigation measures identified during subproject formulation or within the environmental assessment report.
6.2 Implementation of Mitigation Measures
Mitigation measures identified following the desk/or field review shall be properly implemented. Typical environmental impacts and possible mitigation measures are given in Table 6.1 for guidance. LIU will be required to adapt the generic mitigation measures for the various subprojects included in the proposed program.
Table 6.1: Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects
|Project Component |
|Potential Impacts |
|Mitigation Measures |
|Responsibility |
| |
| |
| |
| |
| |
| |
|Improvements to Water Supply and Sanitation |
|Cross contamination sewage and water lines due to pressure differentials and leaks) |
|Improper disposal of construction debris |
|Destruction of historical sites |
|Risk of damage to archaeological sites |
|Coordinate with appropriate agency |
| |
| |
| |
|Proper disposal of construction wastes |
|Use chance find procedures and coordinate with appropriate agency |
|State Ministry of Energy and Water |
| |
| |
|Contractor |
| |
|PIs/Archeology department |
| |
| |
|Rehabilitation of Health centers and Hospitals |
| |
| |
| |
| |
| |
| |
| |
| |
| |
| |
| |
| |
| |
| |
|Improper disposal of wastes |
| |
| |
| |
| |
| |
|Improper disposal of medical wastes |
| |
| |
| |
| |
| |
| |
| |
| |
| |
|Proper disposal of solid wastes |
|Priority given to rehabilitation of toilets |
|Installation of sanitation (cesspools) |
| |
|Containerize infectious wastes |
|Public health awareness |
| |
| |
| |
| |
| |
|PIs/Municipality |
| |
|PIs/community |
| |
| |
| |
| |
|PIs/community |
| |
|State Ministry of Health |
| |
| |
| |
| |
| |
6.3 Environmental Monitoring
Environmental Monitoring will be the responsibility of the LIU and will include:
- Compliance monitoring during construction
- Monitoring of significant impacts during the operation of the subproject.
The Environment Specialist of the PIU will also conduct periodic monitoring by visiting the sites of the various programs at least twice a year.
Monitoring indicators shall be developed for both the construction and the operation phase of the subprojects. Monitoring of construction activities ensure that mitigation measures of construction impacts are being implemented properly, while the monitoring of operation activities is to ensure that no unforeseen negative impacts arise.
6.4 Training Program and Capacity Building
Environmental expertise within the implementing and executing bodies will be strengthened. Training programs will be designed and implemented with the assistance of a local or international expert and will target three levels:
i) PIU and LIU: at the initiation of the promotional program, and prior to bidding and selection of LIU, a workshop will be provided and will include an environmental session to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the DHSDP subprojects.
Another training workshop will be provided to the PIU, LIU and selected partners and will cover the following topics:
- EIA techniques
- Screening projects for environmental review
- Use of practical checklists
- Best environmental practices in design and implementation of projects
- Effective implementation of mitigation measures
- Project supervision
- Monitoring and evaluation
ii) Local NGOs and Contractors: PIU will be required to provide workshops for local NGOs and contractors, focusing on public awareness, case studies of environmental issues experienced in similar projects, use of environmental guidelines and implementation of mitigation measures.
iii) Beneficiaries and Executing Agencies.
A sample training requirements for various groups is included in table (6.3)
|Training Requirements for Various Groups of Participants |Local |LIU & Local |NGOs / CBOs |Community |
| |Government |Government | |Leaders/ |
| |Approval |Staff | |Workers & |
| |Authorities | | |Contractors |
|Linkages between environmental, social and natural resource management |A |T |S |A |
|and sustainable rural livelihoods | | | | |
|Local EA legislation and relevant environmental policies |A |T |S |A |
|Potential localized impacts of subprojects and suitable mitigation |A |T |T |S |
|measures | | | | |
|Addressing and land acquisition and access to resources through |A |T |T |S |
|resettlement planning and compensation | | | | |
|Use of the Environmental Guidelines & WB Safeguards |A |T |T |A |
|Methods of community involvement – PRA |A |T |T |A |
|Cumulative impacts assessment |A |T |A |A |
|Potential environmental and social subprojects |A |S |T |A |
|Inter-community lesson-learning and review |A |T |- |- |
| |
|Legend: T = Detailed training, S = Sensitization to the issues, A = Awareness-raising |
Source: Adapted from World Bank (2005), ESMF Toolkit
7. Management Challenges
7.1 Background
The development model and environmental agenda that dominated the national scene until recently, had several limitations which are still not yet removed. Most important of these were the following:
a) Most interventions and actions to reverse or check environmental degradation were focused on effects rather than the root causes – poverty;
b) Responses were rather curative, adhoc and un - integrated hence, lacking the ability for comprehensive attack on environmental and social problems;
c) Plans and policies treated problems as environmental issues rather than as environment and development concerns neglecting the social, economic and ecological linkages;
d) Policies and plans ignored the important role played by NGOs and CBOs and failed to coordinate or integrate NGO activities in the development plans.
Since 1992, the country established the Higher Council for Environment & Natural Resources (HCENR) with mandates to coordinate, supervise and formulate long term plans for environmental protection and sustainable use of natural resources. The HCENR, as an advisory and coordinating body, handles broad issues of policy formulation and integration of sectors to achieve proper natural resource management, whereas program implementation, development and conservation of natural resources are undertaken by line Ministries at national level or State Ministries at local level. The HCENR is also entrusted with the review and approval of EIAs before implementation of development projects. However, by – laws for review of EIAs are still lacking. In 1995 the HCENR became affiliated to the Ministry of Environment and Physical Development (MEPD) in a loose manner, as the Minister of Environment chairs and supervises the activities of the HCENR. Beside the HCENR and the MEPD, there are other sectoral institutions at national or State level that exercise functions of environmental nature according to their sectoral laws but in conformity with the Sudan Environmental Act 2001.
Since 1992, and as the National Comprehensive Strategy (1992 – 2002) emphasized the country’s concern of creating self – reliant society, NGO’s, CBOs and Civil Society Organizations (CSOs) began to play a major role in the development and decision – making at local level. Hence, villages established Village Popular Committees, Village Development Committees and Cooperative Societies. In many cases, all work in harmony with the traditional leadership and Native Administration.
In matters related to the environment, and as the result of the federal system, responsibilities are divided between the Federal and State governments. However, in case of conflicts, the Federal Jurisdiction over environment and natural resources prevails over the States. Some issues are considered joint or with concurrent powers. There is some confusion in the division of responsibilities between the Federal and the State Governments. The Land Commission is to be established after the CPA clarifies these responsibilities.
7.2 Coordination
Environmental matters are still divided among different bodies which are supposed to act as coordinating institutions. Beside the HCENR and line Ministries, there are: the Water Council, Public Health Council, National Council for Physical Planning, the Population Council and several other councils with mandates of coordination. However, and due to lack of capacities, strong horizontal and vertical linkages are lacking leading in many cases to conflicts or duplication of efforts. All this puts more pressure on the HCENR to improve its performance as the lead institution in environmental issues.
7.3 Limitations and Constraints
There are a number of challenges and constraints to be identified that may impede the country’s environmental performance. These may be outlined in the following:
A) Limited awareness
There is limited awareness about the environment and its social, economic and ecological interactions that prevents the holistic attack on the root causes of environmental problems.
B) Limited capacity of the HCENR and the MEPD
Both institutions are supposed to play a coordinating role and guide the process leading to environmentally sustainable development. Yet, their structure and budgetary resources are so limited that they are handicapped in playing their roles as stated in their mandates. The HCENR, which is the technical arm of the MEDP in the field of environment, has limited technical capacity in terms of human resources and budgetary allocations. In fact, the activities currently performed by the HCENR are only those supported by foreign donors and linked to international conventions.
C) Inadequate technical capacity of key Ministries and States
Most of the technical Ministries at national or State level suffer from the lack of qualified and / or committed cadre as the result of brain drain, political retirements or lack of motivation. At the State level or locality level, the situation is even worse and serious.
D) Poor mechanisms for effective participation
Effective community participation in the development activities is constrained by lack of appropriate structures and the political environment. The rural people are developmentally mobilized but constraint by lack of appropriate structures to be able to respond to their needs. Hence, mechanisms for effecting participation of communities, Civil Society Organizations (CSOs), NGOs, CBOs and private sector are necessary by creating conducive atmosphere for participation.
7.4 Emerging and Critical Issues
There are three issues that emerge as the most critical challenges to the achievement of sustainable development. These include:
A) Decentralization of Environmental Activities
Most environmental problems have roots in local activities. Participation and cooperation of communities and local authorities are important in finding solutions to these problems. Creation of adequate local organizational structures with capacities is an important input to guide grassroots environmental activities. The locality is the appropriate level to guide environmental decentralization at village level.
B) Capacity building
It is important to disseminate the philosophy and approaches of sustainable development through training, learning by doing, institutional building and decentralization of activities. Concerted efforts are needed to create environmental awareness for government staff, NGOs, CBOs, contractors and local communities to be able to integrate environmental dimensions in social and economic development plans.
C) Conflict transformation
Negative environmental impacts as the result of civil war or local conflicts between farmers and nomads have increased substantially during the last decade with impacts extending beyond the conflict zones. Ecological conflicts represent a challenge to the DHSDP subprojects. However, careful approach, involvement of all stakeholders, involvement of Native Administration and efforts in peace building are expected to reduce tensions among resource users.
7.5 Organizational Challenges at Locality & Village Levels
At the locality level, there will be a Locality Steering Committee (LSC) comprised of LIU manager as Chairperson and representatives from each of the locality technical departments. The LSC may draw technical expertise from NGOs, academic and research institutions, line Ministries and individual specialists to provide essential advisory services to the LCS in carrying out its functions. The challenge here is how the Locality Manager (LM) will be able to liaise with related government departments at locality and State levels in addition to community structures as he is recruited by the PIU, while the remaining LIU staff shall be drawn from the locality staff to the LIU on a full time basis. The main challenges here are the capacities of locality staff assigned to LIU in ensuring the incorporation of social and environmental safeguards in subprojects and ability to promote sense of community involvement and accepting joint decision – making with communities.
At the village level, there are a number of local organizations with different names and some with political affiliation complicating the issues of identifying priority needs. In some cases, there may be local politics involved which may affect positive participation. However, this may be solved by establishing specific committee through a democratic process to assist in effective participation of the community. Successful examples of this approach are the methods followed by Child Friendly Villages Project implemented in Damazin Locality.
The institutional arrangements for the implementation of the environmental guidelines involve the inclusion of an Environment Specialist in PIU and establishing focal points at various levels within the government agencies responsible for implementation of the project. Hence, training in the application of the environmental and social safeguards must be conducted for relevant staff as well as for NGOs, CBOs, contractors and other partners involved in project implementation.
References
1) Gaafar Karrar & Partners (1994), Social and Environmental Impacts of Heightening Roseiris Dam, Ministry of Irrigation.
2) Hassan A. Ati (2002), Sustainable Development in Sudan, Environmentalists Society, Khartoum.
3) Government of Sudan (2005), Sudan Interim Constitution, Ministry of Justice.
4) Government of Sudan (2001), Environment Conservation Act.
5) High Council for Environment (1996), Towards National Environmental Action Plan in Sudan, Khartoum.
6) Khalid A. El Amin (1999), Land Tenure Forms in Darfur, Sudan, DSRC, Khartoum.
7) Ministry of Environment and Physical Development (1995), List of Environmental Legislation in Sudan, Khartoum.
8) Sudan Standards and Metrology Organization (2002), Standards for Drinking Water, Khartoum.
9) World Bank (2005), the Republic of Sudan – Multi Donor Fund – Project Proposal, Decentralized Health Services Development Project (DHSDP).
10) World Bank (2005), the Republic of Sudan – Multi Donor Fund – Project Proposal, Community Development Fund Project (CDF).
11) World Bank (1991), Environmental Assessment Sourcebook, Environment Department, Washington DC.
12) World Bank (2005), Environmental and Social Management Framework for World Bank Projects with Multiple Small – Scale Subprojects, a Toolkit, Africa Region.
13) World Bank (1999), Operational Policies (OP 4.01), Environmental Assessment.
14) World Bank (1999), Operational Policies (OP 4.01), Annex A - Environmental Assessment.
15) Yagoub Abdalla Mohamed (2002), Sudan Policy and Institutional Changes for the Implementation of Agenda 21, in Hassan A. Ati (ed.) Sustainable Development in Sudan, Environmentalists Society.
16) Yagoub Abdalla Mohamed (2005), Land Tenure, Land Use and Conflicts in Darfur, Paper presented in a workshop organized by University for Peace and University of Khartoum.
Appendix (A)
Existing Legislations
Appendix (A1): List of Environmental Legislation in Sudan
Appendix (A2): List of Protected Natural Resources
Appendix (A3): Standards for Drinking Water SSMO – Sudan
Appendix (A1)
List of Environmental Legislation in Sudan
A. Land Tenure and Land Use Planning
1. Encouragement of Environment Act (1991)
2. Unregistered Land Act (1970) – repealed
3. Acquisition Act (1970)
4. Town and Village Planning Act
5. Taxation of Land and Date Trees Ordinance (1925), and Regulations
6. Land Settlement and Registration Act (1925)
7. Road Traffic Ordinance (1922)
8. Mechanized Farming Public Corporation (Establishment) Regulations (1975)
9. Rural Water and Development Corporation (1967)
10. Survey Department (Organization) Act (1974)
11. Demarcation and Survey Act (1930)
12. Land Acquisition Act (1930)
13. Town Replanning Act (1930)
14. Lands and Planning Act (1994)
15. Gezira Land Act (1922)
16. Gezira Scheme (1960)
17. Premises Rents Act (1992)
18. Rahad Agricultural Corporation Act (1972)
19. Relief and Rehabilitation Corporation Act (1985)
B. Soil Conservation
1. Rural Water Development Corporation Act (1967)
2. Allotment of Lands for the Development of the Mechanized Farming Corporation Act
3. Parts of the National Parks, Sanctuaries and Reserves Regulation (1939), issued under the Preservation of Wild Animals Ordinance (1935)
4. Gezira Scheme (1960)
5. Mining and Quarries Act (1972)
6. Mining and Quarries Act (1973)
7. Mechanized Farming Corporation (Establishment) Regulations (1975)
8. Plant Disease Act (1913)
9. Agricultural Pest Control Act (1919)
10. Seeds Act (1990)
C. Forest Conservation
1. Forests Act (1989)
2. Forests National Corporation Act (1932)
3. Central Forests Act (1932) - repealed but rules and regulations effective until repealed
4. Provisional Forests Acts (1932) - repealed but rules and regulations continue in effect until repealed
D. Wildlife and Protected Areas
1. Wildlife Conservation and National Park Act (1987)
2. Wildlife Conservation Forests Act (1981)
3. Wildlife Protection Act (1936)
4. Hides and Animals Skins Act (1935)
5. Preservation of Wild Animals Act (1935)
6. Game Regulations (1935)
7. National Parks, Sanctuaries and Reserves Regulation (1939)
8. Arms Ammunition and Explosives Ordinance (1939)
9. Local Government Act
E. Water Resources
1. Nile Water Pump Control Act (1939)
2. Irrigation and Flood Control Act (1990)
3. Environmental Health Act (1975), amended (1993)
4. Public Health Act (1935)
5. Rural Water Development Corporation Act (1966)
6. General Electricity and Water Corporation Act (1966)
7. Water Hyacinth Control Act (1960)
8. Fresh Water Fisheries Ordinance (1954)
9. River Transport Ordinance (1958)
10. Nile Pumps Control Ordinance (1939)
11. Nile Pumps Use Control (Tendencies) Regulations (1969)
12. Nile Pumps Control (Standby) Regulations (1953)
13. Nile Pumps Control (general) Regulations (1951)
14. Public Ferries Ordinance (1939)
15. Regulations of Inland Navigation Act (1980)
F. Marine Resources and Coastal Zone Management
1. Maritime Act (1961)
2. Marine Fisheries Act (1973)
3. General Regulations and Control of Merchant Shipping Act (1971)
4. Harbours and Shipping Ordinance (1961)
5. Terrestrial Waters and Continental Shelf Act (1970)
G. Animal Resources
1. Rabies Act (1974)
2. Animal Disease Free Zone Act (1973)
3. Diseases of Animals Act (1901)
4. Hides and Animal Skins Act (1954)
5. Animals Export and Import Act (1913)
H. Hazardous Substances
1. Pesticides Act (1974)
2. Food Control Act (1973)
3. Pharmacy and Poisons Act (1913)
4. Narcotics Act
5. Industrial Safety Act (1978)
6. Sulphur Ordinance (1932)
I. Energy and Mining
1. Mines and Quarries Act (1974)
2. Mining and Quarries Regulations (1973)
3. Investment Act (1989)
4. Petroleum Act (1931)
J. Environmental Health (Including Pollution Control)
1. Environmental Health Act (1975) amended (1993)
2. Public Health Act (1975)
3. Locusts Destruction Act (1907)
4. Plant Diseases Act (1913)
5. Investment Act (1989)
6. Industrial Safety Act (1976)
7. Road Traffic Act (1983)
8. Quarantine Act (1974)
9. Industrial Waste Local Order (1971), Khartoum North
K. Cultural Environment
1. Antiquities Ordinance (1952)
2. Organization of Higher Education Act (1990)
Appendix (A2)
List of Protected Areas According to Ecological Zones
|Ecological Zone |National Parks |Protected Areas |Hunting Zones |
|Desert |Wadi Hawar |- |- |
|Semi – Desert |Sanganeib Marine Park |Tokar |Erkawit |
| |Dungunab Marine Park | |Sinkat |
| |Jebel El Hassania |Sabalouka |Khartoum Sunt Forest |
| | | | |
|Savanna |Dinder National Park |Shekow |- |
| |Radom N. P. |Ashana |- |
| |Southern N. P. |Nimatine |- |
| |Nimole N. P. |Juba |- |
| |Boma N. P |Kideibo |- |
|Wetlands |Badinglo N. P. |Fani Kang |- |
| |Shambei N. P. |Zaraf Island |- |
|Equatoria Rainforest |- |Mebarzanga |- |
| |- |Bningai |- |
| |- |Birkibts |- |
|Mountainous |- | |- |
|Total |11 |12 |3 |
Areas Proposed for the Establishment of Bird Sanctuaries
1. Khasm El Girba Dam
2. Abyad Lake
3. Keilak Lake
4. Kundi Lake
5. Lake Nubia
6. Sennar Dam
7. Maschar Marches
8. Wadi Hawar
9. Port Sudan
10. Suakin Island
11. Imatong Mountains
12. Jebel Merra
13. Roseiris Dam
14. Jebel Aulia Dam
15. Red Sea Hills
16. Sabaloka Are
Appendix (A3)
Standards for Drinking Water Bacteriological Value Limits
|Organisms |Guideline Value |
|1. all water intended for drinking | |
|E. Coli or thermo - tolerant coli - form bacteria |Must not be detectable in any 100 ml sample |
|Pathogenic intestinal protozoa | |
|2. Treated water entering the distribution system | |
|E. Coli or thermo - tolerant coli - form bacteria | |
|Total coli – form bacteria |Must not be detectable in any 100 ml sample |
|Pathogenic intestinal protozoa | |
|3. Treated water in the distribution system | |
|E. Coli or thermo - tolerant coli - form bacteria |Must not be detectable in any 100 ml sample. |
|Total coli – form bacteria |Must not be detectable in any 100 ml sample. In the case of |
| |large supplies where sufficient samples are examined, must not |
| |be detectable in 95% of samples examined throughout any |
| |consecutive 12 – month’s period. |
| |Must not be detectable in any 100 ml sample |
| | |
| | |
|Pathogenic intestinal protozoa | |
Heavy Metals – Max. Permissible Limits
|Parameter |Max. permissible limit in µg / l |
|Antimony |0.004 |
|Arsenic |0.007 |
|Barium |0.5 |
|Boron |0.2 |
|Cadmium |0.003 |
|Chromium (Total) |0.04 |
|Copper |1.5 |
|Cyanide |0.05 |
|Fluoride |1.5 |
|Lead |0.007 |
|Manganese |0.5 |
|Mercury (Total) |0.0007 |
|Molybdenum |0.05 |
|Nickel |0.014 |
|Nitrate as NO3 |50 |
|Nitrate as NO2 |2 |
|Selenium |0.007 |
Max. Permissible Limits
|Parameter |Max. permissible limit in µg / l |
|Chlorinated Alkanes: | |
|Carbon tetrachloride |1.3 |
|Dichloroethane |14 |
|1,2 Dichloroethane |20 |
|Chlorinated Ethanes: | |
|Vinyl Chloride |3.5 |
|1,1 Dichloroethane |20 |
|1,2 Dichloroethane |35 |
|Trichloroethane |50 |
|Tetra Chloroethane |30 |
|Aromatic Hydrocarbons: | |
|Benzene |7 |
|Toluene |500 |
|Xylenes |350 |
|Ethyl Benzene |200 |
|Styrene |15 |
|Benzo (a) Pyrene |0.5 |
|Chlorinated Benzene: | |
|Monochlorobenzene |200 |
|1,2 Dichlorobenzene |700 |
|1,4 Dichlorobenzene |200 |
|Trichlorobenzene (Total) |15 |
|Miscellaneous: | |
|Di (2 – ethylexyl) adipate |55 |
|Di (2 – ethylexyl) phthalate |5.4 |
|Acrylamide |0.4 |
|Epichlorohydrine |0.3 |
|Edetic acid (EDTA) |150 |
|Nitrilotriacetic acid |150 |
|Tributylin oxide |1.5 |
|Hexachlorobutadiene |0.4 |
Max. Permissible Limits
|Parameter |Max. permissible limit in µg / l |
|Pesticides: | |
|Alachlor |15 |
|Aldrin / Dieldrin |0.02 |
|Aldicarb |7.5 |
|Atrazine |1.5 |
|Bentazone |20 |
|Carbofuran |3.5 |
|Chlorodane |0.15 |
|Chlorotoluron |20 |
|1,2 – Bromo – 3 – Chloropropane |0.7 |
|DDT |1.5 |
|2,4 – D |20 |
|1,2 Dichloropropane |15 |
|1,3 Dichloropropane |15 |
|Heptachlor and heptachlor epoxide |0.02 |
|Hexachlorobenzene |0.7 |
|Isoproturon |7 |
|Lindane |1.5 |
|MCPA |1.5 |
|Methoxychlor |15 |
|Metolachlor |7.0 |
|Molinate |4.0 |
|Pendimethaline |15 |
|Pentachlorophenol |7.0 |
|Permitherin |15 |
|Propanil |15 |
|Pyridate |75 |
|Simazine |1.5 |
|Trifluralin |1.5 |
|Parameter |Max. permissible limit in µg / l |
|Chlorophenoxy Herbicides other than 2,4 and MCPA: | |
|2,4 – DB | |
|Dichloroprop |67 |
|Fenoprop |75 |
|Mecoprop |6 |
|2,4,5 – T |7 |
| |6 |
|Disinfectants: | |
|Monochloramine |2000 |
|Chlorine |3400 |
|Disinfectants by products: | |
|Bromate |17 |
|Chlorite |150 |
|2,4,6 – Trichlorophenol |150 |
|Formaldehyde |600 |
|Bromoform |75 |
|Dibromochloromethane |75 |
|Bromodichloromethane |40 |
|Chloroform |150 |
|Dichloroacetic acid |35 |
|Trichloroacetic acid |75 |
|Chloral Hydrate (Trichloroacetaldehyde) | |
|Dichloroacetonitrile |7 |
|Dibromoacetonitrile |60 |
|Trichloroacetonitrile |75 |
|Cyanogen Chlorides (CN) |0.7 |
| |50 |
Max. Permissible Limits for Radioactive material
|Parameter |Screening Value in Bq / l |
|Cross alpha activity |0.07 |
|Cross beta activity |0.7 |
Max. Permissible Limits for Organoleptic, Physical and Chemical Properties affecting Drinking Water Acceptability by Consumers
|Parameter |Levels Likely to Give Rise to Consumer Complains |
|Physical parameters: | |
|Colour |15 TCU |
|Taste and odour |Acceptable |
|Temperature |Acceptable |
|Turbidity |5 NTU |
|pH |6.5 – 8.5 |
|Inorganic Constituents: | |
|Aluminium |0.2 µg / l |
|Ammonia |1.5 µg / l |
|Chloride |250 µg / l |
|Hydrogen sulphide |0.05 µg / l |
|Iron (Total) |0.3 µg / l |
|Sodium |200 µg / l |
|Sulphate |250 µg / l |
|Total dissolved solids (TDS) |1000 µg / l |
|Zink |3 µg / l |
|Organic Constituents: | |
|2 – Chlorophenol |5 µg / l |
|2,4 Dichlorophenol |2 µg / l |
Appendix (B)
Environmental Impacts & Good Practice Procedures
Appendix B1: Good Practice Environmental Procedures.
Appendix B2: Typical Construction Environmental Impacts and Mitigation Measures
Appendix B3: Draft Environmental Contract Clauses
Appendix B4: Best Practice and Recommendations
Appendix (B1)
Good Practice Environmental Procedures
1. Introduction
The prevention of injury and/or illness to site personnel and the public, damage to the Works and to public and private property, protection of the environment, and compliance with applicable laws, shall be the primary objectives of the contractor. All work shall be carried out in a way as to minimize disturbance and avoid dangers to the public. Selected minimum requirements are outlined in these Good Practice Environmental Procedures with which contractors shall comply. Given that these Procedures cannot cover every eventuality, the contractor shall be expected to exercise good judgment in all such matters, even though not mentioned in these Procedures, and shall take all necessary measures to meet his responsibility with respect to environmental matters.
The Contractor shall, throughout the execution and completion of the Works and remedying of any defects therein:
• Have full regard for the safety of all persons on Site and keep the Site and the Works in an orderly state appropriate to the avoidance of danger to any person;
• Know and understand all laws governing his activities along with any site requirements and work site hazards;
• Take all necessary measures to protect his personnel, other persons, the general public and the environment;
• Avoid damage or nuisance to persons or to property of the public or others resulting from pollution, noise or other causes arising as a consequence of carrying out the Works.
2. Protection of the Environment
The Contractor shall comply with all environmental requirements, rules and regulations under Sudanese laws, laid down by Sudanese Authorities or issued by the Employer or the Engineer. Specific attention should be paid to regulations for materials, including hazardous substances or wastes under his control. The Contractor shall not dump, release or otherwise discharge or dispose of any such dump without the authorization of the Engineer. When releases resulting from Contractor action occur, the Contractor shall take proper precautionary measures to counter any known environmental or health hazards associated with such releases. These would include remedial procedures such as spill control and containment and notification of the proper authorities.
3. Air Pollution
The Contractor shall take all necessary measures to limit pollution from dust and any wind blown materials during the Works, including wetting down with water on a regular basis during construction.
The Contractor shall ensure that all trucks leaving the Site are properly covered to prevent discharge of dust, rocks, sand, etc.
4. Water Pollution
The Contractor shall not dispose of waste solvents, petroleum products, toxic chemicals or solutions in the village drainage system or watercourse, and shall not dump or bury any garbage on the Site. He shall maintain the Site in a sanitary condition and shall remove from the Surface of the ground all rubbish, surplus spill, and litter which may have been left on site.
All wastes shall be taken to an approved disposal facility regularly as specified by the locality. The Contractor shall dispose of all fluids and test pumping discharge in a manner that does not cause contamination or nuisance. He shall also be responsible to control all run-offs, erosion, etc.
Where a temporary reduction in downstream flow or discoloration by suspended solids from excavations is, in the opinion of the Engineer, unavoidable, the Contractor shall make alternative arrangements for supplying all effected users throughout the period of flow reduction or coloration.
5. Solid Waste
General Housekeeping:
The Contractor shall maintain the Site and any ancillary areas used and occupied for performance of the Works in a clean, tidy and rubbish-free condition at all times. Upon completion of work, the Contractor shall clear away and remove from the Site all Contractors’s Equipment, surplus material, rubbish and temporary works of any kind, and leave the Site in a clean condition to the satisfaction of the Engineer.
Rubbish Removal and Disposal:
The Contractor shall comply with the local orders of the locality and requirements for the disposal of rubbish and waste. No waste shall be burnt on site unless approved by the Engineer.
6. Noise Control
The Contractor shall adopt the best practicable means of minimizing noise. All equipment shall be maintained in good mechanical order and fitted with the appropriate silencers, mufflers, or acoustic covers where applicable. Stationary noise sources shall be sited as far away as possible from noise-sensitive areas, and where necessary acoustic barriers shall be used to shield them.
7. Additional Requirements for Work in Public Areas
1. Method Statements
The Contractor shall submit to the Engineer in a timely manner a method statement which will include:
- A general description of the identified mitigation measures and methodology of how it will be carried out;
- Details of the measures and temporary works to minimize disturbance and safeguard the public. These shall include temporary diversions, safety barriers, screens, signs, lighting and arrangements for control of traffic and pedestrians and advance warning to be given to the public.
2. Site Clearance and Removal of Topsoil
Site clearance shall be carried out over the areas to be occupied by the permanent Works before beginning excavation or filling or other work, and shall include the clearance of all trees, stumps, bushes and other vegetation and the removal of all boulders.
Materials arising from site clearance shall be disposed by the Contractor off the Site, or where approved by the Engineer, on the site in a manner and place approved by the Engineer and in accordance with the locality local orders.
The Contractor shall preserve as far as practicable all grass and other vegetation outside the limits of trenches and permanent works and shall not unnecessarily destroy crops or any vegetation whose removal would not be essential to his operations.
3. Existing Services
The Contractor shall be responsible for maintaining all existing services such as electricity, telephone, water, sewerage and drainage. Any curtailment of these services shall only be undertaken with the prior approval of the Engineer. The Engineers approval of proposals for alternative services shall only be given after consultation with the effected consumers.
Any accidental curtailment of services resulting from the Contractor’s activities shall be treated as an emergency and repaired without undue delay, notwithstanding that the Engineer may not be immediately available. All such accidents shall be reported in writing to the Engineer with details of the remedial action undertaken.
4. Closure of Roads
The closure or partial closure of roads, pavements and other public areas will only be permitted if approved by the Relevant Authorities and closure permit has been issued by the Authority. The Contractor shall detail for each closure the extent of area to be closed, the reasons and duration of the closure and, where appropriate, proposed diversion.
5. Protection of Buildings and Properties
When working adjacent to existing properties, the Contractor shall:
- Advise owners or occupiers of adjoining property of the dates on which work is to be executed;
- Obtain permission of the owners if it is necessary to erect Temporary Works or otherwise use adjoining property and pay all charges;
- Take all reasonable precautions to prevent damage to adjoining property and, if any damage is caused as a result of the execution of the Works, make good to the satisfaction of the owner.
7.6 Protection of Archeological and Historical Sites
Excavation in sites of known archaeological interest should be avoided. Where this is unavoidable, prior discussions must be held with the Department of Antiquities, who should be given the opportunity to undertake pre-construction excavation or assign an archaeologist to log discoveries as construction proceeds.
Where historical remains are unexpectedly discovered in an area not previously known for its archaeological interest, work should be curtailed and the finds reported to the Department of Antiquities, who will be given the opportunity to visit the site and undertake rescue excavation.
7. Excavation
The following guidelines apply to all types of excavation and shall be observed by the Contractor.
i) before commencing work the contractor shall:
- Obtain an excavation permit from the relevant local authority.
- Notify the Engineer on the location and duration of the work. An excavation permit signed by the Engineer must be issued before excavation proceeds in any work location.
- Erect all temporary works such as barriers, warning signs, lighting, etc.
- Not deposit excavated materials on public or private land except where directed by the Engineer or with the consent in writing of the relevant Authority or of the owner or responsible representative of the owner of such land and only then in those places and under such conditions as the relevant Authority, owner or representative may prescribe.
7. Safety Barriers
Safety barriers shall be provided to the perimeter of work areas and to trench and other types of excavations and to existing openings such as manholes, draw pits and the like. When exposed to the public, safety barriers shall be provided to both sides of trenches and around all sides of openings.
The Contractor shall provide details of the type or types of safety barriers for each excavation for approval of the Engineer prior to commencing work. No work shall commence until the safety barriers are in place.
7. Use of explosives
Explosives shall not be used on any part of the Works without the approval of the Engineer and permission from the relevant authorities. The Contractor shall:
- Observe all regulations regarding proper purchasing, transportation, storage handling and use of explosives;
- Ensure that explosives and detonators are stored in separate and approved building, located and clearly marked in English and Arabic “DANGER – EXPLOSIVES” to the approval of the Engineer;
- Ensure that all possible precautions are taken against accidental fire or explosion, and that all explosives are kept in a proper and safe condition;
- Ensure explosives and detonators are always transported in separate vehicles and kept apart until the last possible moment and that metallic tools are not used to open boxes.
Blasting Procedures: the Contractor shall carry out blasting operations in a manner that will not endanger the safety of the persons and property. Adequate warning of blasting shall always be given and all persons cleared from the area, before blasting take places. The Contractor shall:
- Ensure that police and other relevant authorities are kept fully informed of the blasting program so they may be present during blasting if they so require.
- Erect warning notices around the area affected indicating that blasting operations are in progress.
- Ensure explosive charges are not excessive charged, that boreholes are properly protected, and appropriate precautions are taken for the safety of persons and property.
- Maintain an up-to-date inventory of all explosive devices and submit a monthly report to the Engineer, detailing the use of explosives by date and location.
Appendix (B2)
Typical Construction Environmental Impacts and Mitigation Measures
|IMPACT |GOOD PRACTICE MITIGATION MEASURES |
|Obstruction of Access: | |
|Installation of pipelines may require partial or total |Avoiding total closure of roads and maintain single line traffic; diversion of |
|closure for the duration of construction, causing |traffic through suitable roads to the expected traffic loading; provision of |
|obstruction and necessitating the diversion of vehicular |adequate diversion signs; minimizing lengths of open trench; expeditious completion |
|and pedestrian traffic. |of backfill and reinstatement |
|Disruption of Services | |
|Existing services such as water, sewerage, electricity and |Minimizing the period of disconnection; provision of alternative arrangements when |
|telephones may be temporarily disconnected, thus causing |disruption for an extended period is unavoidable. |
|inconvenience to consumers. They may also be subject to | |
|accidental damage during construction. | |
|Increased Traffic Generation | |
|Contractors’ heavy transport and construction equipment |Restriction of heavy transport and equipment activity to normal working hours. |
|will result in increased traffic. | |
|Soil and Water Pollution | |
|Improper dumping of excavated and construction materials, |Collection and disposal of demolition and excavated materials at appropriate |
|chemicals, solvents and oils may contaminate the soil as |locations; collection and recycling of lubricants; precaution to avoid accidental |
|well as surface and ground waters. Runoff contamination may|spills. |
|also affect flora and fauna. | |
|Soil Erosion | |
|Soil erosion may occur from excavations, road cuttings and |Limitation of earth moving to dry periods so major excavations and movements of |
|other exposed surfaces during periods of rain. This may |spoil are undertaken during the summer months; protection of most susceptible |
|result in alteration to landforms and natural drainage and |surfaces with mulch; covering open trenches with plastic sheeting and supporting |
|in accumulation of sediments in rivers and streams. |their sides. |
|Disruption of Drainage | |
|New roads traversing surface water catchment areas can |The excavation of cut-off trenches and diversion channels may need to be constructed|
|reduce runoff or divert natural drainage, thus causing a |as Temporary Works until land re-grading, concrete culverts or permanent diversion |
|diminution in flow downstream to the detriment of bank-side|channels can be completed. |
|vegetation and aquatic invertebrate fauna. | |
|Increased Noise | |
|High noise levels from equipment, machinery and vehicles |Restriction of work to normal working hours; using the quietest available plant/and or|
|will cause disturbance to surrounding residences and |machinery; maintaining all equipment in good mechanical order and fitting them with |
|particularly impact upon hospital, schools, churches, |the appropriate silencers, mufflers…. |
|mosques, and upon cultural and recreational facilities | |
|that require quiet conditions for their enjoyment. | |
|Reduced Air Quality | |
|Dust and particulate matter from the works may have a |Keeping access and haul roads swept and sprayed with water especially during the |
|particularly serious impact upon people with respiratory |dry/hot season; spraying of spoil heaps with water; ensuring that vehicle and other |
|problems, as well as on adjacent vegetation and |engines are not kept running needlessly; preventing any lorries which expel high |
|buildings. Increased traffic will increase vehicle fumes |levels of exhaust from further work until they have been rectified. |
|and odors, and tire and exhaust particles can coat | |
|roadside vegetation. | |
|Damage to Vegetation | |
|The removal of vegetation may affect both local |Minimizing loss of natural vegetation during construction; replanting any damaged |
|ecological communities and the physical environment. The |trees or shrubs. |
|immediate result is the intensification of physical | |
|factors such as sunlight, desiccation, wind and water | |
|erosion. This, in turn, may lead to a paucity of food, | |
|shelter, nesting materials and habitats for birds and | |
|small animals. | |
|Accumulation of Spoil | |
|Accumulations of spoil generated from road cuttings and |Reusing spoil for backfill and reinstatement, or transporting to an approved site for |
|other excavations are visually unsightly and may be |such disposal; grading small quantities in adjacent land where this does not result in|
|rapidly eroded by rainfall. The suspended solids content |the deterioration of soil fertility; balancing the quantities of ‘cut’ and ‘fill’ to |
|of surface runoff may increase and culverts and drainage |minimize the generation of excess spoil. |
|channels become silted. Spoil tipped on hillsides may be| |
|inherently unstable and subject to slippage. | |
|Destruction of Archaeological Sites | |
|Excavations may result in the destruction of |Avoiding excavation in sites of known archaeological interest; undertaking |
|archaeological remains. |pre-construction excavation in sites with potential historical remains; assigning an |
| |archaeologist to log discoveries as construction proceeds. |
|Contractors’ Yards | |
|Sites containing offices, storage areas, maintenance |Careful siting, construction and management of contractor’s yards |
|shops, prefabrication yards generate domestic and | |
|industrial waste, including spent oils and chemicals, | |
|damaged materials and abandoned equipment. The | |
|excavation, crushing, washing, treatment and transport of| |
|rock materials and the construction of pre-cast units | |
|will cause increased noise, air pollution and heavy | |
|traffic. | |
Appendix (B3)
Draft Environmental Contract Clauses
Clause No. ___ Environmental Management, Safety and Security
1. Before the order to commence civil works, the contractor is required to implement the Environmental Management Plan (EMP) as specified in the Environmental Impact assessment (EIA) prepared for the particular road works. The plan shall spell out how the contractor should achieve environmental targets and objectives specified in the EMP and agreed upon by the Environmental Coordinator, Environmental Management Unit, and the Ministry of Environment and Physical Development. The plan shall include, to the extent practicable and reasonable, all steps to be taken by the Contractor to protect the environment in accordance with the provisions of the Environment Act, 2001 and Environmental Guidelines for Transport Projects, 2005. Where the EMP does not exist, the clauses obtained herein shall form the basis of a rehabilitation plan.
2. Not withstanding the contractor’s obligation under the above clause, the Contractor shall implement all measures necessary to restore the sites to acceptable standards and abide by environmental performance indicators specified under the EMP to measure progress towards achieving objectives during execution or upon completion of civil works. These measures shall include, but not limited to the following:
a) Minimize the effect of dust on the surrounding environment resulting from earth mixing sites, asphalt mixing sites, dispersing coal ashes, vibrating equipment, temporary access roads, etc to ensure safety, health and the protection of workers and communities living downward of dust producing activities.
b) Ensure that noise levels emanating from machinery, vehicles and noisy construction activities are kept at a minimum for the safety, health and protection of workers within the vicinity of high noise levels and communities near rock – blasting areas.
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 civil works being carried out.
d) Prevent bitumen, oils, lubricants and waste water used / 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 bio – physical 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 archaeological or historical importance during the execution of works, report such findings to the Department of Antiquities, in fulfillment of the Environment Act, 2001, and outline 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, 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 prevent siltation, etc.
i) Ensure that garbage, sanitation and drinking water facilities are provided in construction workers camps.
j) Ensure in as much as possible that local materials are utilized 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 significant perturbations arising from such works have been taken into account.
4. The contractor shall adhere to the proposed activity implementation schedule and the monitoring plan / strategy to ensure effective feedback of monitoring information to both project management and the Environmental Coordinator and the Environmental Management Unit (EMU), so that impact management can be implemented properly and if necessary, adapt to changing and unforeseen conditions.
5. the Project Coordinator, EMU, in conjunction with the Ministry of Environment and Physical Development, shall inspect significant sites where civil works have been carried out and proposed mitigation measures implemented and shall give certification regarding the adequacy or inadequacy of rehabilitation measures carried out in the bio – physical environment and compensation for socio – economic disruption resulting from implementation of civil works.
6. If the contractor fails to implement the approved EMP, the Project Coordinator and EMU shall seek legal redress through the Ministry of Environment and Physical Development and appropriate penalties shall be instituted in accordance with the provisions of the Environment Act, 2001.
Specific environmental issues to be considered
Worksite / Camp Site Waste Management
• All vessels (drums, containers, bags, etc) containing oil, fuel, surfacing material and other hazardous chemicals must be bonded 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 the provisions of the Environment Act, 2001 and Locality orders.
• 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 the provisions of the Environment Act, 2001.
• Used oil from maintenance shall be collected and disposed off appropriately at designated sites or be re – used or sold for re – use locally.
• Entry of runoff to the site shall be restricted by construction diversion channels or holding structures such as banks, drains, dams, etc to reduce the potential of soil erosion and water pollution.
• Construction waste shall not be left in stockpiles along the road. Waste and other excess material shall be used fro rehabilitating borrow areas and landscaping around the road.
• If other spoil disposal sites are necessary, they shall be located in areas of low land use value and where they will not result in material being easily washed into drainage channels. Whenever possible, spoiled materials should be placed in low – lying areas and should be compacted and planted with species indigenous to the locality.
Material Excavation
• Contractors shall obtain the appropriate license / permits from relevant authorities to operate quarries or borrow areas.
• The location of quarries and borrow areas shall be subject to approval by relevant authorities including traditional authorities if the land on which the quarry or borrow area falls is traditional land, Environmental Coordinator and EMU.
• Extraction sites shall not be located in the vicinity of settlement areas, cultural sites, wetlands or any other valued ecosystem component.
• Extraction sites 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.
• Extraction sites shall not be located in forest reserves. However, where there are no other alternatives, permission shall be obtained from the Department of Forestry and an Environmental Impact Assessment shall be conducted.
• Extraction sites shall not be located on high or steep ground or in areas of high scenic value.
• Only sites that can easily be rehabilitated shall be chosen. Areas with minimal vegetation cover such as flat and bare ground or areas covered with grass only or covered with shrubs of height less than 1.5 m.
• Extraction site boundaries shall clearly be demarcated and marked to minimize vegetation clearing.
• Vegetation clearing shall be restricted to the area required for safe operation of construction work. Vegetation clearing shall be done for not more than three months in advance of operation.
• Extraction sites 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 staff from the Antiquities Department.
• 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 exist from workings.
Rehabilitation and Soil Erosion Prevention
• To the extent practicable, rehabilitate the site progressively so that the rate of rehabilitation is similar to the rate of construction.
• Always remove and retain top soil for subsequent rehabilitation. Soils shall not be stripped when they are wet as this can lead to soil compaction and loss of structure.
• Top soil shall not be stored in large heaps. Low mounds of no more than 1 – 2 m high are recommended.
• Revegetate the stockpile to protect the soil from erosion, discourage weeds and maintain an active population of beneficial soil microbes.
• Locate stockpiles where they will not be disrupted by future construction activities.
• To the extent practicable, reinstate natural drainage patterns where they have been altered or impaired.
• Remove toxic materials and dispose them off in designated sites. Backfill excavated areas with soils or overburden that is free of foreign material that could pollute ground water and soil.
• Identify potentially toxic overburden and screen with suitable material to prevent mobilization of toxins.
• Ensure the reshaped land is formed so as to be inherently stable, adequately drained and suitable for the desired long - term land use and that would allow natural regeneration of vegetation.
• Minimize the long – term visual impacts by creating landforms, which are compatible with the adjacent landscape.
• Minimize erosion by wind and water both during and after the process of reinstatement.
• Compacted surfaces shall be deep ripped to relieve compaction unless subsurface conditions dictate otherwise.
• Revegetate the area with plant species that will control erosion, provide vegetative diversity, and that will through succession; contribute to a stable and compatible ecosystem. The choice of plant species for rehabilitation shall be done in consultation with local research institutions, Forest Department and the local people, as they will be long – term beneficiaries.
Water Resources Management
• The contractor shall at all costs avoid conflicting with water demands for local communities.
• Abstraction of water, both surface and underground, shall only be done with the consultation of the local community and after obtaining a permit from the relevant Water Authority.
• Abstraction of water from wetlands shall be avoided. Where necessary, permits have to be obtained from relevant authorities.
• Temporary damming of streams and rivers shall be done in such a way that disruption of water supplies to communities downstream is avoided and maintain the ecological balance of the river system.
• No construction water containing spoils or site effluents, especially cement and oil, shall be allowed to flow into natural water drainage courses.
• Wash water from washing out of equipment shall not be discharged into watercourses or road drains.
• 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
• Location of access roads / detours shall be done in consultation with the local community especially, where access road may traverse important ecosystem components. Access roads shall not traverse wetland areas.
• Upon the completion of civil works, all access roads shall be ripped off and rehabilitated.
• 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
• Blasting activities shall not take place in the vicinity of settlement areas, cultural sites, or wetlands.
• Blasting activities shall be done during working hours and local communities shall be consulted on the proposed blasting times.
• Noise levels reaching the communities from blasting activities shall not exceed 90 decibels.
Health and Safety
• The contractor, in advance of the construction work, shall amount an awareness and hygiene campaign. Workers and local residents shall be sensitized on health risks particularly of AIDS.
• Adequate road signs to warn pedestrians and motorists of construction activities, diversions, etc shall be provided at appropriate points.
• Construction vehicles shall not exceed maximum speed limit of 40 km per hour.
1 Appendix (C)
2 Environmental Screening
Appendix C1: Environmental Checklist
Appendix C2: Environmental Data Sheet (EDS)
Appendix C3: Environmental Appraisal Form
Appendix C4: World Bank Safeguard Policies
Appendix (C1)
Environmental Checklist
1. SUBPROJECT DESCRIPTION
The project description must be very complete. Describe the total amount of new structures, parking, landscaping, removal/demolition proposals, mitigation measures proposed by applicant, hours of operation, number of employees, limitation on use, etc. Describe the proposed water, sewage disposal means and the proposed access to the site. Include reference to a Figure that depicts the site plan and proposed project. A reduced copy of the map should be provided by the applicant.
Description of the project and its major components.
2. SUBPROJECT LOCATION
|2.1 Site Information |
|Name of Locality |Comp Maps |
|Community |Land use designation, total population and density |
|Present Use & Development | |
|Surrounding Uses/Zoning |North: |
| |South: |
| |East: |
| |West: |
|Access |Name of roadway if direct access, description of easement from public or private roadway |
| | |
|Public Services |Water Supply: name of district, or if private, note "private onsite well" or "shared |
| |well" |
| |Sewage: name of district or "septic system" |
| |Other: e.g. school, health clinic… |
| | |
3. POTENTIAL SIGNIFICANT ENVIRONMENTAL EFFECTS
The following checklist indicates the potential level of impact and is abbreviated as follows:
Known Sig.: Known significant environmental impacts.
Poten. Sig. and Mitig.: Potentially significant impacts which can be mitigated to less than significant levels.
Not Sig.: Impacts which are not considered significant.
3.1 GEOLOGIC PROCESSES
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Exposure to or production of unstable earth conditions such as landslides, soil creep, mudslides, ground | | | |
|failure (including expansive, compressible, collapsible soils), or similar hazards? Review available soils maps,| | | |
|Dibblee maps, seismic safety element, consult with staff geologist as necessary. Significant impacts occur when| | | |
|grading activity results in hazards that include landslides, soil creep, mudslides, ground failure, etc. or when| | | |
|the proposed project will potentially be impacted by the existence of these conditions. Proposed structures | | | |
|located on or adjacent to faults would also represent potentially significant impacts. | | | |
|b. Disruptions, displacements, compaction or over covering of the soil by cuts, fills, or grading? Will the | | | |
|project involve or require extensive grading that will change topography, create major height changes, etc. | | | |
|Does the project involve cut slopes exceeding a grade of 1.5 to 1? Will the cut slopes be over 15 feet in | | | |
|height? Is the project proposed to involve grading on slopes over 20%? Ensure that your project information is| | | |
|detailed enough to make this determination. If your project does include items listed above, the activity could| | | |
|be considered significant, subject to mitigation. | | | |
|c. Permanent changes in topography? Analyze whether or not permanent, substantial changes in topography will | | | |
|occur which could result in significant environmental impacts. Obviously, many projects involve grade changes; | | | |
|however, not all projects will be considered to have significant impacts due to these changes. An example of a | | | |
|substantial change would be infilling of ravines, creeks, etc. to create level building sites, or mining or a | | | |
|hillside where the face of the slope will be excavated into steep, terraced benches. | | | |
|d. The destruction, covering or modification of any unique geologic or physical features? There are no maps in | | | |
|this office that depict these types of features. Consult with the staff geologist for any available information| | | |
|and review applicable EIR's. | | | |
|e. Any increase in wind or water erosion of soils, either on or off the site? Review the soil types described in| | | |
|the Soil Survey Books to determine the potential for soil erosion on site. Consider that generally large areas | | | |
|of soil would need to be exposed without any proposed reseeding, etc. for impact to be significant. Consider | | | |
|the slope and drainage of the site. If the soil type is rated high for erosion consider whether an impact will | | | |
|be significant. If there is going to be a large exposed area that has been subject to grading there is the | | | |
|potential for wind blown dust to occur. Steep slopes with erosive soils that are subject to grading could also | | | |
|have the potential for erosion to be significant. | | | |
|f. Changes in deposition, or erosion or siltation which may modify the channel of a river, or stream, or any | | | |
|water body? Evaluate whether or not your project involves construction of a bridge or other device that will be | | | |
|located near a watercourse described above. Consider if a creek, stream, river, slough, or other water body is | | | |
|located near your project and if impacts will occur as a result. Evaluate if beach sands or dunes are proximate| | | |
|to your project site or could be impacted because of the proposed project | | | |
|g. The placement of septic disposal systems in impermeable soils with severe constraints to disposal of liquid | | | |
|effluent? Review the soil types on site to determine their potential for being constrained for placement of | | | |
|sewage disposal systems. Is there a high clay content, very steep slopes, high ground water, limited building | | | |
|sites or parcels on acre or less? Parcels greater than or equal to 5 acres are usually large enough to support | | | |
|some type of septic system according to Environmental Health. Consult with the staff geologist if you have any | | | |
|concerns prior to the application complete stage. You may need drywell testing, a geologic report and/or | | | |
|percolation tests to complete your analysis. | | | |
|h. Excessive grading on slopes of over 20%? Review the site plans and project description. When a majority of | | | |
|the proposed project's grading involves grading on slopes of over 20 percent, a determination of significance | | | |
|can be made | | | |
|j. Sand or gravel removal or loss of topsoil? Mining operations or similar activities will usually trigger the | | | |
|significance of this section. | | | |
|i. Vibrations, from short-term construction or long-term operation, which may affect adjoining areas? Does your | | | |
|project require significant compaction due to construction of roadways, building pads, removal of existing soils| | | |
|and replacement with non-expansive soils, and is your project adjacent to existing residences? Does your | | | |
|project involve boring under a creek? or concrete crushing? | | | |
|j. Excessive spoils, tailings or over-burden? Does the project propose balanced cut and fill or is there a | | | |
|significant amount of over-burden soils that will need to be removed or is proposed to remain on site? | | | |
Impact Discussion:
In each of the impact sections in the Initial Study, your discussion should focus on why you checked the box you checked. Be brief and concise and include references as appropriate (for example, to reference material or to specific sections/pages of a previous document). Preface each impact discussion with the alphabetic reference item number. Clearly state the cut, fill and import/export soil volumes.
Mitigation Measures:
If no mitigation is needed simply state this. Otherwise, summarize the proposed mitigation and mention residual impact level.
3.2 WATER RESOURCES/FLOODING
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Changes in the course or direction of water movements? Consider if the project will impact existing | | | |
|water bodies and the extent of this impact. | | | |
|b. Changes in percolation rates, drainage patterns or the rate and amount of surface water runoff? Will | | | |
|development of your project cause major changes to existing drainage patterns, create additional water | | | |
|runoff potential because of increased impervious surfaces? or change the existing percolation rate of | | | |
|the soil surface that will create a significant problem? Most single family dwellings will not result | | | |
|in these changes at a level of significance. Large tracts are examples of projects that have the | | | |
|potential for this type of significant impact.. | | | |
|c. Change in the amount of surface water in any water body? Will the project cause an increase or | | | |
|decrease in the water levels of potentially affected water bodies, streams, lakes, ocean, rivers, etc.)?| | | |
|An example is stream diversions. | | | |
|d. Discharge into surface waters, or alteration of surface water quality, including but not limited to | | | |
|temperature, dissolved oxygen, turbidity, solids?Does the project cause introduced impacts to a water | | | |
|body such as extreme siltation, sewage waste leakage, oil or grease contamination (nutrient loading) | | | |
|form proposed development, etc? | | | |
|e. Alterations to the course or flow of flood waters, or need for private or public flood control | | | |
|projects? Is your project located in a floodway or floodplain? Contact Flood Control if you have | | | |
|concerns about the potential project impacts. Review the notes you were given pertaining to flooding. | | | |
|f. Exposure of people or property to water related hazards such as flooding, or accelerated runoff? | | | |
|Review the FIRM maps to determine if your project is located in a potential flood zone. The FIRM maps | | | |
|indicate that a study has been done of this area as it pertains to flooding. If an area is not | | | |
|indicated on these maps as being in a flood zone, it does not mean that there is no flood danger. | | | |
|Mitigations available through implementation of Flood Ordinance 3898 will provide self-mitigating | | | |
|regulations. Contact Flood Control staff to confirm whether your project impacts could be significant. | | | |
|g. Alteration of the direction or rate of flow of groundwater? According to Flood Control staff, | | | |
|development of one or several single family dwellings is not going to create a significant change in the| | | |
|rate or flow of groundwaters. This type of impact will occur when you have large tracts or large areas | | | |
|of non-residential development that creates a significant amount of impervious surfaces. | | | |
|h. Change in the quantity of ground waters, either through direct additions or withdrawals? This | | | |
|question is related to 2(i) below in terms of groundwater withdrawals. "Additions" to groundwater would| | | |
|involve recharge projects (recharge basins or injection wells) which would be analyzed primarily for | | | |
|potential groundwater quality impacts. (See 2(j)). | | | |
|i. Overdraft of any groundwater basin? Or, an increase in the existing overdraft of any groundwater | | | |
|basin? Use the groundwater threshold manual section to make this determination and contact the staff | | | |
|geologist for confirmation of your findings | | | |
|j. The substantial degradation of groundwater quality? Potential water quality impacts of (1) any | | | |
|project involving groundwater recharge, (2) in the vicinity of the coast, or (3) adjacent to a creek or | | | |
|river should be reviewed. The staff geologist will analyze potential salt water intrusion. | | | |
|k. Substantial reduction in the amount of water otherwise available for public water supplies? This | | | |
|question would relate to the loss of yield of major water supply sources (eg. large siltation events in | | | |
|a major reservoir caused by vegetation removal in the watershed; a major pollution event which renders | | | |
|some surface water or groundwater unusable) | | | |
Impact Discussion:
Mitigation Measures:
3.3 TRANSPORTATION/CIRCULATION
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Generation of substantial additional vehicular movement (daily, peak-hour, etc.) in relation to existing| | | |
|traffic load and capacity of the street system? During the initial application completeness determination, | | | |
|discuss the project specifics with Public Works transportation staff and P&D staff which have or had nearby| | | |
|projects to determine if specific information about the project that you do not already know is needed. | | | |
|Decide if a traffic study will be needed to determine the number of new traffic trips generated by the | | | |
|project and where trips would be distributed on the area roadway network etc. with the assistance of Public| | | |
|Works. You need to know how much traffic will be generated by your project, the existing traffic status of| | | |
|affected roadways/intersection, and the impact your project's traffic will have on the roadway/intersection| | | |
|system. Use the traffic threshold guidelines to complete this analysis. | | | |
|b. A need for private or public road maintenance, or need for new road(s)? Will your project require the | | | |
|need for a new road that currently does not exist and is not proposed as part of the project application? | | | |
|Will your project's traffic trips create a significant maintenance problem to existing roads which do not | | | |
|have an existing maintenance agreement or arrangement? | | | |
|c. Effects on existing parking facilities, or demand for new parking? Is your project proposing an adequate| | | |
|number of parking spaces? or will there be overflow parking in the adjacent areas. Will your project | | | |
|significantly exacerbate an existing lack of available parking? Consider both average and peak use parking| | | |
|demand and ability of adjacent streets to accommodate on-street parking during potential overflow period. | | | |
|d. Substantial impact on alteration of present patterns of circulation or movement of people and/or goods? | | | |
|Will your project create the need for added or expanded transit service that is not currently provided or | | | |
|able to be provided? Will your project cause a noticeable change in the established movement patterns of | | | |
|traffic that could cause secondary effects on area roadways such as alternative routing and associated | | | |
|changed in roadways an intersection volumes, pedestrian safety, etc. | | | |
|e. Increase in traffic hazards to motor vehicles, bicyclists or pedestrians (including short-term | | | |
|construction and long-term operational)? Consider the existing roadways and parking areas that will need to| | | |
|accommodate construction equipment and vehicles as well as long-term traffic associated with the | | | |
|operational aspect of the project. Is there room on site to park? Do bicyclists use adjacent roads on a | | | |
|frequent basis and is the number of additional traffic trips generated by the project significant to cause | | | |
|a potential safety problem? Are there sidewalks or wide shoulders on nearby roads to accommodate | | | |
|pedestrians? Are area roadways heavily utilized by children (near schools, parks) or elderly? | | | |
Impact Discussion:
Mitigation Measures:
If a traffic study has been done, the consultant should have identified mitigations needed to reduce any significant impacts. Supplement this information with ideas of your own in conjunction with traffic staff.
3.4 AIR QUALITY
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. The generation of air pollutants, a contribution to an existing or projected air quality violation or | | | |
|exposure of sensitive receptors to substantial pollutant? Refer to Threshold Manual and Jan. 20, 1992 | | | |
|handout from Cheri Savage titled Air Quality data to perform calculations. | | | |
|b. The creation of smoke, ash or odors? This is a straight forward question where a determination should | | | |
|be easy to make. Odors may be associated with H2S from a well or specific industrial projects. | | | |
|c. Dust generation? Since short-term threshold/dust threshold has been deleted, note that AQAP requires | | | |
|dust control measures for any project involving grading. For extremely large projects, it may be | | | |
|appropriate to quantify dust generation and base significance on CEQA Guidelines, particularly Appendix | | | |
|G. | | | |
Impact Discussion:
Mitigation Measures:
Review proposed mitigations with APCD staff.
3.5 BIOLOGICAL RESOURCES
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|FLORA |
|a. Removal or disturbance of natural vegetation? | | | |
|b. A loss or disturbance to a unique, rare or threatened plant community? Review the Natural Diversity data| | | |
|base maps to identify if these type of plants occur on-site; review local community plans that identify | | | |
|protection to important habitats of local concern known on site, review State/Federal rare, endangered | | | |
|plant/animal lists, review the bio. threshold criteria and consult with staff or consultant biologist to | | | |
|determine significance. The terms: rare and threatened and species of special concern (Federal Category | | | |
|2) are defined at a Federal and State level and in CEQA. Only certain categories of plants are protected. | | | |
|The County also lists sensitive plants regionally rare within the County, and requires assistants on a case| | | |
|by case basis. See CEQA guideline section 15380, 15065(a), Appendix G (a.c.d.t). Once again, be certain | | | |
|that the plant or habitat you are evaluating is protected through Federal, State or County policies. Is | | | |
|there going to be a significant reduction in the numbers of this species or habitat according to our new | | | |
|threshold guidelines? Consult with staff or consultant biologist | | | |
|c. A reduction in the numbers or restriction in the range of any unique, rare or threatened species of | | | |
|plants? | | | |
|d. A reduction in the extent, diversity, or quality of native vegetation (including bush removal for fire | | | |
|prevention and flood control improvements)? Evaluate the extent of the brush removal that will be required | | | |
|with development of the project? Is it significant given the size of the parcel and the extent of the | | | |
|native vegetation on site? Need to look at neighboring parcels to determine if habitat fragmentation would| | | |
|occur. Is there going to be a loss of landscape plants or other non-native vegetation that is of | | | |
|significant habitat value? | | | |
|e. Introduction of herbicides, pesticides, or other factors that would change or hamper the existing | | | |
|habitat? The introduction of these elements into an undeveloped area could be significant. An example | | | |
|could be something as large as the development of a golf course into a pristine, undeveloped canyon | | | |
|adjacent to stream beds, or something as small as an access ridge in an environmentally sensitive habitat | | | |
|area. This depends on location, remoteness, and quality of habitat. | | | |
|FAUNA |
|f. A reduction in the diversity or numbers of animals onsite? Review section above on flora. Also a | | | |
|reduction in the quantity or quality of habitat reduces the diversity of species on the site. | | | |
|g. A deterioration of existing fish or wildlife habitat ? The habitat must be identified and the impact | | | |
|quantified as to significance. Consult with staff/consultant biologist. | | | |
|e. Introduction of barriers to movement of any resident or migratory wildlife species? An example could be | | | |
|the construction of fence lines that limit the range movement of animals, dams, bridges, roads, pipelines, | | | |
|splash crossings across creeks, etc. Also look at surrounding parcels to see if fragmentation of existing | | | |
|habitat is a possibility. | | | |
|h. Introduction of any factors (light, fencing, noise, human presence and/or domestic animals) which could | | | |
|hinder the normal activities of wildlife? Carefully evaluate the factors that may be significant with | | | |
|regard to this issue. The mere presence of fencing does not necessarily trigger a finding of significance.| | | |
|However, human presence in a remote area may be a significant impact as well as conflicts which may arise. | | | |
Existing Plant and Animal Communities/Conditions:
The initial study section is set up for you to include a discussion of the flora/fauna present on site. Need to describe the existing setting and describe habitat on site. Discuss quantity and quality (pristine, degraded, etc.). Also species present on the project site and note if they are rare, endangered, threatened or species of special concern. Keep this as brief as possible and describe only those elements that raise the issue of a significant impact or justify that no discussion is needed
Impact Discussion:
Mitigation Measures:
3.6 ARCHAEOLOGICAL RESOURCESReview the County Guidelines on Assessment of Archaeological Resources and Appendix K of CEQA
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Disruption, alteration, destruction, or adverse effect on a recorded historic or archaeological | | | |
|site? Review county archaeological maps to determine if a known site is present on the property. | | | |
|Additional survey work is in the form of a Phase I or II may be needed prior to application | | | |
|completeness. | | | |
|b. Disruption or removal of human remains? | | | |
|c. Increased potential for vandalizing, or sabotaging archaeological resources? Will development of | | | |
|the project site create the increased possibility for people to trespass on the property where | | | |
|significant resources have been identified? | | | |
|d. Ground disturbances in an area with potential cultural resource sensitivity based on the location | | | |
|of known historic sites? Again, once it has been determined that significant cultural resources exist| | | |
|on site, determine if there is potential for ground disturbances in the area from the project through| | | |
|review of grading plans cut/fill, evaluations. | | | |
Impact Discussion:
Mitigation Measures:
3.7 HISTORIC RESOURCES
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Adverse physical or aesthetic impacts on a structure or property at least 50 years old and/or of | | | |
|historic or cultural significance to the community? Review Jan. '93 Cultural Resource Guidelines, | | | |
|Historic Resources Element. | | | |
|b. Beneficial impacts to a historic resource by providing rehabilitation, protection, conservation, | | | |
|etc.? | | | |
Impact Discussion:
Mitigation Measures:
3.8 NOISE
| | |Poten. | |
| |Known |Signif. | |
|Will the proposal result in: |Signif. |and |Not |
| | |Mitig. |Signif. |
|a. Long-term exposure of people to noise levels? County Thresholds define noise sensitive uses as | | | |
|residential, transient lodging, medical care facilities, and educational facilities, churches, | | | |
|libraries. See pg. 106 of Threshold Manual. Noise affecting sensitive receptors in excess of 65 dB | | | |
|CNEL outdoor and 45 dB CNEL indoor are considered significant. | | | |
|b. Short-term exposure of people to noise levels? Construction activity that occurs within 1600 feet | | | |
|of noise sensitive uses is considered significant. However, dept. policy states that if this is the | | | |
|only issue area we will rely on project conditions to mitigate impact and we will not do an ND on | | | |
|this issue alone. | | | |
|c. Project-generated substantial increase in the ambient noise levels for adjoining areas (either day| | | |
|or night)? Will traffic, people, movement other than vehicles create a noise nuisance for neighbors. | | | |
|Nursery with late night operations is example of potential situation; however, to create a | | | |
|substantial increase the noise must be of a long duration. A noise study may be necessary to analyze| | | |
|project impacts on noise sensitive uses. | | | |
Impact Discussion:
Mitigation Measures:
3.9 LAND USE
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Structures and/or land use incompatible with existing land use? | | | |
|b. The induction of substantial growth or concentration of population? | | | |
|c. The extension of sewer trunk lines or access roads with capacity to serve new development beyond | | | |
|this proposed project? Review site plans and application. | | | |
|d. The conversion of prime agricultural land to non-agricultural? See ag. thresholds review | | | |
|e. The loss of open space? | | | |
|f. An economic or social effect that would result in a physical change? | | | |
Impact Discussion:
Mitigation Measures:
3.10 PUBLIC FACILITIES
| | |Poten. | |
|GENERAL SERVICES- | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. A need for new health care services? We usually don't contact the police or health care for | | | |
|their input on the issue unless the project is large. Use your judgement on when to contact | | | |
|these officials. | | | |
|b. Student generation exceeding school capacity and/or facilities? During the incomplete stage | | | |
|contact the school district to determine current status of enrollment and check whether they | | | |
|think impact will be significant from the proposed project. Review pertinent internal memos | | | |
|pertaining to state law and current limitations on mitigation measures that can be imposed. | | | |
|c. Additional amounts of solid waste and wastewater generation? See County Threshold Manual for| | | |
|solid waste calculation | | | |
|d. A need for new or altered sewer system facilities (sewer lines, lift-stations, etc.)? Contact | | | |
|sewer district to determine if project can be served by existing lines, and whether it is in the | | | |
|sewer boundary. Can and will serve from sewer district. | | | |
Impact Discussion:
Mitigation Measures:
3.11 ENERGY
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Substantial increase in demand, especially during peak periods, upon existing sources of | | | |
|energy? There are very few times when we have a project which will create a significant impact | | | |
|on energy. Contact the local utility companies if the project is large and/or high energy use | | | |
|type | | | |
|b. Requirement for the development or extension of sources of energy? Again, contact the local | | | |
|utility companies if you are uncertain. | | | |
Impact Discussion:
Mitigation Measures:
3.12 FIRE PROTECTION
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Introduction of development into an existing high fire hazard area? Check fire hazard | | | |
|location maps to determine if your project is in a high fire hazard area. Then contact Fire | | | |
|Dept. rep. to see if the project will create a significant impact because of its proposed | | | |
|location. | | | |
|b. Project-caused fire hazard? Infrequently, a project will intensity an existing situation | | | |
|that could lead to new fire hazard. | | | |
|c. Introduction of development into an area without adequate water pressure, fire hydrants or| | | |
|adequate access for fire fighting? If this is true then the impact should be mitigated with | | | |
|requirements for fire tanks, sprinklers, etc. | | | |
Impact Discussion:
Mitigation Measures:
3.13 RECREATION
See draft rec. impact guidelines, Park Dept. review trail maps, site visit.
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Conflict with established recreational uses of the area? | | | |
|b. Substantial impact on the quality or quantity of existing recreational opportunities? | | | |
Impact Discussion:
Mitigation Measures:
3.14 AESTHETIC/VISUAL RESOURCES
Site visit; review site plan and elevations; may require a visual analysis by an expert.
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. The obstruction of any view open to the public or the creation of an aesthetically offensive | | | |
|site open to public view? | | | |
|b. Change to the visual character of an area? | | | |
|c. Glare or night lighting which may affect adjoining areas? | | | |
|d. Visually incompatible structures? | | | |
Impact Discussion:
Mitigation Measures:
3.15 HOUSING
| | |Poten. | |
| | |Signif. | |
|Will the proposal result in: |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. Loss of existing dwellings through demolition, conversion, or removal? | | | |
|b. Displacement of current residents? | | | |
Impact Discussion:
Mitigation Measures:
3.16 RISK OF UPSET/HAZARDOUS MATERIALS
| | |Poten. | |
| | |Signif. | |
| |Known |and |Not |
| |Signif. |Mitig. |Signif. |
|a. In the known history of the Project Area, have there been any past uses, storage, or | | | |
|discharge of hazardous materials? Examples of hazardous materials include, but are not | | | |
|limited to, fuel or oil stored in underground tanks, pesticides, solvents, or other chemicals.| | | |
|b. Will the proposed project involve the use, storage, or distribution of hazardous or toxic | | | |
|materials? | | | |
|Will the proposal result in: | | | |
|c. A risk of an explosion or the release of hazardous substances (including, but not limited | | | |
|to oil, gas, pesticides, or chemicals) in the event of an accident or upset conditions? | | | |
|d. Possible interference with an emergency response plan or an emergency evacuation plan? | | | |
|e. The creation of a potential public health hazard? | | | |
|f. Public safety hazards? | | | |
|g. The contamination of a public water supply? | | | |
Impact Discussion:
Mitigation Measures:
Appendix (C2)
Environmental Data Sheet (EDS) for Proposed Program
|Geographical Location: |Program Reference No.: | |
|Program Name: | |
Subprojects included in the Program:
Program Location: (besides geographic location, information about the key environmental characteristics of the area likely to be affected by the program, and proximity of any protected areas or sites or critical natural habitats)
Environmental Issues: (identified or suspected in project)
Proposed Actions: (to mitigate environmental issues described above)
Justification/Rationale for Environmental Category: (presents reasons for environmental category selected)
Reporting Schedule: (Is there a separate environmental analysis? If yes, when is it due?)
| | |
|Date for first draft | |
|Current status | |
Remarks: (gives status of any other environmental studies, lists local groups and local NGOs consulted.)
Appendix (C3)
Environmental Appraisal Form
| |Program Name: | | | |
|1. |Type of Sub-Projects included | | | | | | | |
| | | | | | | | | |
| | | | | | | | | |
| | | | | | | | | |
| | | | | | | | | |
| | | | | | | | | | |
| | | | | | | | | |
| | | | | | | | | | |
| | | | | | | | | |
| | |Ministry of Federal Government | |Council for the South | | | | |
| | |State Ministries of Agriculture | |State Ministries of Education | | | | |
| | |State Ministries of Engineering Affairs | |State Ministries of Social Affairs | | | | |
| | |Other (name) | |Directorate of Antiquities | | | | |
|14 |Have these consultees given written approval for the program or sub-projects? |Yes | | | |No |
| | | | | | | | | | |
| | | | | | | | | |
| | | | | | | | | |
| |within the program budget? | | | | | | | |
| |Before the program goes to execution? | | | | | | |Y| |
| | | | | | | | |e| |
| | | | | | | | |s| |
| | | | | | | | |
| | | | | | | | | |
| | | | | | | | | | |
| |been agreed with the PIU? | | | |
| | | | | |
| | |
|Policy, Legal, and |Describe the pertinent regulations, permitting conditions and standards governing environmental |
|Administrative Framework: |quality, health and safety, protection of sensitive areas, land use control, etc. |
| | |
| |Tables should be used to list applicable standards and note which authorities are responsible for their|
| |application. Where there are no relevant local standards, suitable international norms may be used. |
|Project Objectives and |This section should describe the need for the project in the context of the local and national |
|Description: |situation and strategy. The effect on economic and social development goals of the locality, country |
| |and region should be described. If the project is an element of an overall development program in the |
| |area, then a description of the other program elements must be presented. |
| | |
| |A description of the relevant parts of the project should be provided using maps and including the |
| |following information: location; general layout; size; capacity; etc.; pre-construction activities; |
| |construction activities; operation and maintenance activities; and life span. |
|Baseline Data |This section should include descriptions of the area of influence or study area and the relevant |
| |physical, biological and socioeconomic conditions. This should include any topics falling under the |
| |safeguard polices of the World Bank. The data presented should be relevant to decision making |
| |regarding project location, design, operation, and mitigation measures for adverse impacts. The |
| |source, accuracy and reliability of the data should be clearly stated. |
|Environmental Impacts & |A prediction of the changes in the environment resulting from project construction and operation are to|
|Mitigation Measures: |be considered, and an assessment of the effect on the surrounding physical, biological, and social |
| |environment, should be presented. This should include positive as well as negative impacts. |
| |Mitigation measures should be identified as well as any negative impacts for which there are no |
| |mitigative measures. This section should also identify and estimate the extent and quality of |
| |available data, key data gaps, and uncertainties associated with predictions, and specific topics that |
| |do not require further attention. |
|Analysis of Alternatives: |This section should provide a brief description of possible alternatives to the project including the |
| |‘no action’ alternative. These may include alternative location, site layout, technologies, design |
| |options, and management systems. |
| |The reasons why the various alternatives considered were rejected should be documented. |
|Environmental Management |This section should include details of the management initiatives to be implemented during both the |
|Plan: |construction and operational phase of the project. The EMP should have three main components: |
| |(i) Environmental mitigation plan: Recommend feasible and cost-effective measures to prevent or reduce|
| |significant negative impacts to acceptable levels. Estimate the impacts and costs of those measures, |
| |and of the institutional and training requirements to implement them. Consider compensation to |
| |affected parties for impacts which cannot be mitigated. Prepare a management plan including proposed |
| |work programs, budget estimates, schedules, staffing and training requirements, and other necessary |
| |support services to implement the mitigating measures. |
| |(ii) Institutional capacity and needs: Review the authority and capability of institutions and |
| |recommend steps to strengthen or expand them so that the management and monitoring plans in the |
| |environmental assessment can be implemented. The recommendations may extend to management procedures |
| |and training, staffing, operation and maintenance training, budgeting, and financial support. |
| |(iii) Monitoring Plan: Prepare a detailed plan to monitor the implementation of mitigating measures |
| |and the impacts of the project during construction and operation. |
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