The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) Additional Financing Appraisal Environmental and Social Review Summary Appraisal Stage (AF ESRS Appraisal Stage) Public Disclosure Date Prepared/Updated: 04/19/2023 | Report No: ESRSAFA551 Apr 19, 2023 Page 1 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) BASIC INFORMATION A. Basic Project Data Country Region Borrower(s) Implementing Agency(ies) Comoros EASTERN AND SOUTHERN The Union of Comoros Ministry of Maritime and AFRICA Air Transport Project ID Project Name P180734 Comoros Interisland Connectivity Project Additional Finance Parent Project ID (if any) Parent Project Name P173114 Comoros Interisland Connectivity Project Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Transport Investment Project 4/11/2023 5/31/2023 Financing Public Disclosure Proposed Development Objective The Project Development Objective is to improve maritime transport climate resilience between the islands. Financing (in USD Million) Amount Current Financing 25.00 Proposed Additional Financing 15.00 Total Proposed Financing 40.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] Interisland connectivity is among the most important constraints to integrate domestic markets and reduce poverty and inequality in Comoros. While Grande Comores and Anjouan are relatively well connected by formal ferries and Apr 19, 2023 Page 2 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) large freight vessels, Moheli is most isolated. Comoros is highly vulnerable to extreme climate events. Port Boingoma was damaged by Cyclone Kenneth in 2019. Despite the government’s emergency repair work, the substructure continue eroding. The port remains vulnerable to climate events and operational subject to weather conditions. Ferries and cargo ships cannot access the port. Local travelers mainly use small “informal” boats for their daily transportation between the islands. While the government prohibits passenger operations by kwassa kwassa, the policy is not strongly enforced because there is no alternative transport means. The proposed program aims at improving maritime connectivity among the islands and ameliorating maritime transport resilience and safety by increasing the port capacity, installing proper infrastructure and protection at the primary and secondary ports and strengthening the regulatory and institutional framework to ensure efficient, affordable and safe interisland transportation. The program fully aligns with the World Bank Group’s twin goals: eradicating extreme poverty and boosting shared prosperity, specifically focused on the transport and market accessibility for local communities in Moheli Island, the poorest region in the Comoros. Supporting disaster recovery and resilience is also aligned with the country’s FY20– FY24 Country Partnership Framework (CPF), particularly, one of the priority objectives under Focus Area I: Crisis Response and Resilience. Given limited available resources, the operations take a programmatic approach through a series of projects (SOP) in collaboration with other development partners. The SOP1 approved in May 2022 is focused on improving maritime transport climate resilience between the islands, by investing two-thirds of breakwater and protection at Port Boingoma. Public Disclosure The proposed SOP1 Additional Financing (AF) complements SOP1 to complete the port resilience investment, by financing the reminder of the breakwater. The development objective is the same as SOP1: Improve maritime transport resilience between the islands. The AF will also augment support for project implementation and finance the installation of maritime communication and safety equipment at the primary and secondary ports, which are urgently needed to ensure maritime safety in the country. The remaining components, such as investment in secondary ports and support for a pilot program of new, safer passenger boats, will be financed by the following phase, SOP2. D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] Comoros is an archipelago of three major islands composed by volcanic islands, Grande Comore, Moheli and Anjouan, located off the coast of Mozambique in the Indian Ocean. Comoros has a population of about 830,000 with an estimated 44.8 percent of Comorians living below the national poverty line in 2020. Moheli is the poorest region in the country. While poverty incidence in Moroni and other parts of Grande Comores are relatively low at 30.7 percent and 32.7 percent, respectively, Moheli has the highest rate of 53.2 percent, while poverty on Anjouan island is 38.2 percent. Society is matrilineal, and women have access to property according to custom and law. However, women do not always have the right to use their property rights. The traditional system tends to exclude women from formal decision-making processes. Men hold the heads of villages positions. About 60 percent of the total labor force is Apr 19, 2023 Page 3 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) engaged in agriculture. Around 38 percent of the working-age adults have their main job in agriculture and 29 percent are employed in the service sector, while employment in industry or manufacturing and trade is relatively low. Less-educated workers are particularly concentrated in subsistence agriculture, and to a lesser extent trade, while those with higher educational training are engaged in the service sector. Fishing is mainly artisanal. Many fishers use traditional wooden canoes or small motorized fiberglass boats. The participation in the labor market and the nature of employment is characterized by some gender discrepancies. Only 32 percent of women are part of the workforce, compared to 54 percent for men. The proposed Additional Financing (AF) complements SOP1 to complete the Boingoma Port resilience investment on Moheli Island, by financing the reminder of the breakwater. However, no works approved under SOP1, including Boingoma Port construction, have begun to date. The development objective of the AF is the same as SOP1: Improve maritime transport resilience between the islands. The AF will also augment support for project implementation and finance the installation of maritime communication and safety equipment at the primary and secondary ports, which are urgently needed to ensure maritime safety in the country. The Environmental and Social Impact Assessment (ESIA) of the Boingoma port rehabilitation project did not include an analysis of the environmental and social risks and impacts of the material supply areas (rock quarrying sites, etc.) because no raw material supply sources were identified during the preliminary design phase. As part of this AF the technical studies have been progressing, and an environmental and social impact assessment(ESIA) on pre-identified quarries was prepared to complement the ESIA already prepared for the Boingoma Port Rehabilitation Project. The geological prospecting studies conducted by the Project identified six (06) quarry sites to be considered for use in the Boingoma port rehabilitation: the site near the Mohéli Airport, the Upstream Boingoma site, the Upstream Djoiezi site, the Komodjou Coastal site, the Domoni-Hoani site and the Msoutroni riverbed. Based on the intial ESIA prepared for the six sites, and a detailed geotechnical study Public Disclosure carried out for the Domoni site, it was determined that the Domoni site containes sufficient quantity and quality of materials to supply all the quarrying needs for the Port Boingoma contruction, and it was selcted to be the sole quarry for the project. A more detailed ESIA covering the Domoni quarry, as well as the transport corridor on Moheli island to bring materials to the port, using a combination of road transport and barges, will be completed prior to the start of operations in the quarry. A Resettlement Action Plan (RAP) covering the quarry and transport corridor also is being prepared and will be implemented prior to the start of quarry operations. The operation of Domoni quarry may generate : (i) cutting and cleaning of vegetation cover resulting in biodiversity disturbance and habitat degradation; (ii) particle dust and noise emissions; (iii) influx of foreign workers, conflicts between local and foreign workers, (iv) increased risk of accidents and health and safety hazards for the population; (v) soil and water quality degradation; (vi) relief modification and erosion phenomena enhancement; (vii) water use conflict between the existing local needs and the quarry operation needs; (viii) land and other economic assets losses; (ix) road network degradation and road traffic perturbations (x) GBV/SEA/SH risks and potential cultural degradation. D. 2. Borrower’s Institutional Capacity The Project is managed by a project implementation unit (PIU) created under the Ministry of Maritime and Air Transport (Ministère des Transports Maritime et Aérien, Chargé du Tourisme et de I’Artisanat), which is responsible for implementing all maritime transport policies in Comoros, including port regulations and PPP supervision. A Social Specialist and an Environmental Specialist have been recruited by the project to oversee the implementation of risk management aspects under SOP 1 and SOP1 AF. This ESF institutional Arrangement will be assessed during SOP 2 preparation. A new GBV/SEA/SH Specialist is being recruited under a hiring process and is expected to be in place by May 2023. During the SOP1, capacity building assessment was conducted for the PIU and all port sector stakeholders to ensure the implementation of environmental and social measures and the monitoring of the activities themselves. The Social Specialist has previously worked on World Bank projects using ESF guidelines. Thje Social Specialist and Environmental Apr 19, 2023 Page 4 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) Specialist in the PIU team received their first ESF training session in 2022, conducted by the WB team. They and the gender/GBV specialist once hired, will receive further training in relevant E&S topics as part of the capacity building efforts. As recommended under the ESIA for Boingoma Port and ESMF for the secondary Port, Ministry of Transport will implement an Environmental and Social Management System (ESMS) for operation of the Boingoma Port which includes measures for managing risks and impacts related to the operational phase. Further, technical support requirements have also been identified for the operational phase. These entities are not yet familiar with the WB's operations or with the ESF. The ESMF for the Secondary Ports and ESIA for Boingoma Port have identified the relevant E&S capacity building described in the ESCP. The PIU will cooperate closely with the SCP (Société Comorienne des Ports) for ports technical operation, the ANAM (Association Nationale des Affaires Maritimes) as the public organizations in charge of administrative actions related to hydrographic activities and other key actors involved in project preparation and implementation such as the Ministry of Environment, and RENAP (Réseau National des Aires Protégées). II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) High Environmental Risk Rating High The environment risk is assessed High related to activities to enhance the capacity of Port Boingoma and to install infrastructure at selected secondary ports. The SOP1 AF components are a continuity and complement to the SOP 1 Public Disclosure activities at Port Boingoma which will focus on the construction of a breakwater along the quays. SOP1 AF also includes an assessment of the Domoni quarry on Moheli island to be used for construction material, and of the transport corridor to bring material from the quarry to Boingoma, which combines road transport and and ocean barges. Key environmental risks and impacts related to the improvement of the existing Boingoma Port infrastructure on Moheli island and secondary Ports in the three islands under SOP1, SOP1 AF and future SOP2 include perturbation of marine habitat and potential damage to marine biotopes during dredging; port waste and pollution control, pollution from the dredged material; occupational and community health & safety issues and potential increase in road or traffic-related accidents especially during construction and transportation of dredged material. Secondary port landing sites will have their own ESIA and RAP prepared as part of SOP2 preparations (not under the current SOP1 AF), and are expected to retain the same high environmental risk rating. The infrastructure improvement in the Boingoma Port will likely involve heavy civil works, with noise, vibration, dust, traffic, and possible community safety concerns. Potential impacts to biodiversity may arise because the port site is within the boundary of the protected area of Moheli. Quarrying activities, which are considered Substantial risk, could generate occupational and community health & safety issues related to the quarry itself, as well as a potential increase in road or traffic-related accidents especially during quarry operations and and transportation of materials with noise, vibration, dust, traffic, and possible community safety concerns. During the operation of the port and improved landing sites, environmental risks may include storm-water runoff, handling or storage of hazardous cargo and its movement through populated areas, health, safety and security issues in the Port areas. Social Risk Rating Substantial Social Risk is assessed as Substantial, due to likely labor influx, some resettlement, traffic safety risks from quarry actvities and transport of materials from quarry to port, and port construction activities. Port infrastructure Apr 19, 2023 Page 5 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) improvements and quarrying and transport of materials for Boingoma port (and other ports as needed) will require laborers. While most labor will be be hired locally for civil works, there will be some labor influx from outside Comoros or between the three islands. The risk of poor working conditions that are not in line with ESS 2 and Comorian labor laws also require mitigation measures. Labor risks include use of child labor, forced/bonded labor and discrimination in hiring, unless specific measures are in place to check these practices. Other risks related to infrastructure building and port improvements are community health and safety risks during quarrying, infrastructure construction,and through increased traffic, movement of machinery and materials etc. This can lead to impacts on health through emissions, increased noise and road accidents. An ESIA (for Boingoma Port), and a Resettlement Policy Framework (RPF) prepared under SOP1 were revised for SOP1 AF. There is little, if any, land taking involved within Boingoma port itself, which belongs to the Government, to be verified and confirmed during ESMP screening. Risks and impacts from the quarry and materials transport corridor have been addressed in an ESIA and Resettlement Action Plan (RAP) prepared for SOP1 AF, including some land near the quarry that is used for agriculture. Secondary ports, which are still being selected for inclusion in SOP2, may also require RAPs, to be carried out as necessary during SOP2 preparations. Any economic impacts such as crop losses and other livelihood losses at any of the sites will be captured in RAP Compensation Plans or Livelihood Restoration Plans (LRP). The ESIA for Boingoma Port prepared for SOP 1, ESIA for Quarries and road corridor prepared for SOP 1 AF include guidance on traffic management and managing the spread of infectious diseases including COVID-19. The risk of GBV/SEA/SH was assessed as substantial, mainly due to the potential for labor influx to Modeli island for quarry and port construction actvities. The risk of conflicts with communities and lack of awareness about the project will also need to be addressed as this can create resentment among local residents. Illiterate, poor, disabled and marginalized groups (e.g. women) can be left out of consultations unless consultations are specifically designed to include such groups. The SOP1 Stakeholder Public Disclosure Engagement Plan (SEP) was revised for SOP 1 AF and includes assessment of stakeholders according to their influence and impact, and outlines measures for consulting them during various stages of implementation. During SOP1, SOP 1 AF (and early SOP 2) preparations, consultations were held with a range of stakeholders including women, fishermen, local residents. Consultations will continue during implementation. B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: ESS1 is assessed as relevant. The Project is likely to generate a wide range of significant adverse risks and impacts on human populations and the environment because of the complex nature of the Project and environmental context. Long term, permanent and irreversible impacts due to the nature of Project activities are anticipated. A standalone ESIA/ESMP for the port of Boingoma and an ESMF for the construction of secondary ports were prepared and disclosed by the PIU, both in January 2022, for the programmatic approach under SOP 1. An initial scoping ESIA did an initial assessment of six potential quarry sites for SOP1 AF, and an additional separate ESIA/ESMP was then prepared for the selected Domoni quarry site and transport corridor, also under SOP1 AF. Based on the project design and the social and environmental profile from ESMF and the two prepared ESIAs (Boingoma Port and quarry scoping ESIA) will be financed by the SOP1-AF, the potential risks and impacts of SOP1 and SOP1 AF activities are related to the following: (i.) Land acquisition required for the construction area, (ii.) Environmental pollution (soil, Apr 19, 2023 Page 6 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) air, noise) related to water turbidity, demolition, dredging operation, accidental spills, solid waste and effluent, concrete laitance, exhaust gas, noise and vibration, asbestos contaminated materials (from demolition of existing structures), sludge generation by the dredging and the demolition operations …etc, (iii.) Road degradation due to equipment and construction materials transportation, (iv.) Loss of marine habitat/resources, (v.) Pressure and competition on drinking water resources due to the needs of the quarry and port construction site, (vi.) Community health and safety such as risks related to Gender Based Violence (GBV) and Sexual Exploitation and Abuse (SEA) and spread of infectious diseases, accidents, and road safety during construction phase, (vii.) Potential labor influx into the project area during construction owing to opportunistic settlements and migrant workers seeking employment, (viii.) Navigation disruption and related accident risks within the fairway and the turning circle, (ix.) Change in the current and sedimentation dynamics due to the embankment and the breakwater construction, (x.) Exposure of construction site staff and residents to COVID-19 and other diseases including HIV/AIDS, (xi.) Pressure on the quarries and borrow pits for raw construction materials. The initial ESIA for the Boingoma Port construction was already approved and disclosed under SOP1, while the supplementary assessments for quarry sites were prepared for SOP1 AF appraisal. The detailed esia prepared for the selected Domoni quarry, will accompany the Port ESIA and be completed before the actual work is commenced. The ESIA for Boingoma (Fomboni) SOP 1 phase defined mitigation measures for construction and operational phases, roles and responsibilities, time plans, costs and implementation procedures for each mitigation measure recommended. A marine biodiversity assessment was conducted as part of the ESIA prepared for Boingoma port under SOP 1, which concluded that the marine ecosystem is composed of modified habitat. The risks and impacts could be reduced to acceptable levels by using of dredging technologies and protective screens to limit the dispersion Public Disclosure of resuspended particles and materials. It was recommended to develop a coral reef restoration plan in collaboration with the forestry services before launching of works. The project’s susceptibility to climate change related hazards, such as sea level rise, erosion, flooding has been assessed and the port rehabilitation design and civil works have considered specific measures to manage and reduce the risks to include in the C-ESMP and ESMS for the Port Authority. The Boingoma Port ESIA also provides assessment and guidance on managing community health and safety risks related to GBV and COVID-19, management of labor and GRM. For the quarry, an ESIA/ESMP is under preparation by the PIU and will be reviewed and approved by the World Bank and disclosed before the launching of the bidding process for the construction of Port Boingoma. For SOP1 AF, multiple quarry sites were screened as part of a scoping quarry ESIA, followed by a detailed ESIA and RAP focusing on the selected Domoni quarry site and transport corridor which is under preparation. The ESIA and RAP will be completed, and RAP implemented before the beginning of works and taking of any lands for borrow pits or the quarries. The scoping Quarry ESIA did not identify any particular significant adverse risks and impacts related to quarrying activities necessitating non-standard mitigation measures for these activities as provided in the World Bank Group EHS Guidelines for Construction Materials Extraction. Before the start of civil works, the contractor will prepare the Contractor Environmental and Social Management Plan (C-ESMP) for the construction of Port Boingoma and the C-ESMP for the selected quarry sites. These instruments will be submitted for World Bank approval. Labor Management Procedures and suggested measures to address SEA/GBV/SH Risks for the project are contained in separate updated standalone LMP and SEA/SH Action plan.. Construction Contractors for the Boingoma port and quarry actvities will be required, as a condition of their contracts, to develop, implement and comply with the C- ESMP, that will include all necessary specific management plans and procedures provided in the ESIA. Apr 19, 2023 Page 7 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) During the SOP 1 preparation, the ESIA for the port of Boingoma (Fomboni) and the ESMF for the secondary ports were disclosed in the country on January 18, 2022 and on the External WB website on January 20, 2022. The remaining ESF instruments (RPF, LMP, SEP, and GRM) were consulted and disclosed prior to the SOP1 Appraisal, both in-country and on the Bank's website. These ESF documents were revised to include additional information on SOP1 AF activities and redisclosed.. Prior to the operation phase, the Ministry of Maritime and Air Transport will be expected to develop and implement an ESMS for the operation of the Boingoma (Fombini) Port and the two secondary Ports consistent with good international industry practice. This ESMS will include measures for managing risks and impacts related to the operational phase consistent with ISO 14001 and ISO 45001 standards, and a GRM for all stakeholders during the operation phase. Prior study has indicated that the potential private sector contribution to capital investment may be limited due to the small size of Port Boingoma. If any additional donors decide to invest in Port infrastructure construction, all ESF principles and requirements will be applied on all project components. If the CERC component is triggered, the secondary port ESMF will be updated to cover the CERC Component while carrying out technical studies, to screen and propose mitigation measures related to implementing emergency activities in case the CERC component is activated. ESS10 Stakeholder Engagement and Information Disclosure Public Disclosure A Stakeholder Engagement Plan (SEP) was developed for the program during SOP1 preparation, which will continue to guide the consultation processes and stakeholder engagement throughout the life cycle of the project, starting from preparation through implementation, including for SOP1 AF. During the ESIA exercise, stakeholder mapping was conducted and stakeholders were identified in the different project intervention zones. Potential stakeholders are Ministry of Maritime and Air Transport, boat operators, commercial users of Boingoma port, coastal communities, travelers and service providers for travelers and port operations. Given that the Boingoma port is located within the protected area of Moheli, RENAP must be involved in the stakeholder engagement process. Stakeholder mapping has also analyzed the influence of these stakeholders to the project design and implementation and the project's impacts on them. Special attention has been given to inclusion of women, vulnerable and project affected people, as well as other interested groups. The SOP1 SEP was revised and updated for SOP1 AF, including additional community consultations during SOP1 AF and early SOP2 preparations, including a schedule of planned engagement activities for the various stakeholders during the project cycle. The SEP will ensure all consultations are inclusive and accessible. It also includes a project Grievance Redress Mechanism (GRM), which became operational in January 2023. Local GRM committees, government officials and other community stakeholders on the three islands received awareness raising and training on GRM processes in December 2022 and January 2023. Construction acitvities have not yet begun and there is limited field activity being carried out by project staff and ESF instrument consultants. As such, no grievances have been reported to date. The SEP will be updated for each new investment phase of the project and annually during project implementation or as needed when major project developments occur. B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. Apr 19, 2023 Page 8 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) ESS2 Labor and Working Conditions ESS2 is relevant for this project. The proposed program (including SOP1 and SOP1 AF) will involve direct workers, contracted workers and primary supply workers. Labor/contracted workers during construction are expected to be employed by the project. In Comoros, where overseas migration to find work is prevalent, labor requirements are often supplied from outside the project areas. Labor Management Procedures (LMP) were outlined in the ESIA, and a standalone LMP including a labor GRM was prepared for SOP1 and was revised, updated and redisclosed for SOP1 AF by appraisal. The PIU currently comprises 17 workers, which will rise to over 20 under the SOP1 AF, including indirect and direct workers. The due diligence assessment of Boingoma port estimated an amount of 150 workers are needed for construction and supervision contractors. Quarry and transport corridor labor needs remain to be determined by the contractor. The potential for workers camps was assessed in the Boingoma ESIA and requirements and guidance to develop a Workers Camp Management Plan will be elaborated as part of the C-ESMP for Boingoma port and the quarry site, and reviewed and approved by the Bank before the beginning of works. The information related to the number of workers for secondary ports will be provided and analyzed in the standalone ESIA to these ports as part of SOP2 preparations. s. The PIU is also contracts consultants for specialist studies. No community workers will be employed by the project. The project will also use primary supply workers. These will be employed by parties expected to provide material to the project such as construction material, suppliers of trucks for port construction sites and other services etc. Public Disclosure The LMP prepared under SOP1 and updated to include SOP1 AF activities includes an assessment of labor related risks for direct and contract workers such as those related to working conditions, Occupational Health and Safety, inequality and discrimination and provides guidance on their mitigation. These risks include inadequate and inappropriate working conditions for workers which are not aligned with local legislation and ESS2, discrimination, inequality of opportunity, violence (particularly SEA/GBV/SH), child and forced labor, inappropriate health and safety conditions, and denial of right for workers to organize. Labour risks related to other categories of workers were as well taken into consideration in the LMP. To ensure Health and Safety (H&S) of workers during the construction and operational phases of the project, the project will require contractors to prepare and implement their Occupational Health & Safety Plan (OHSP) following the World Bank Group Environment, Health and Safety General Guidelines and Industry Sector Guidelines for Construction Materials Extraction. The OHSP will also include procedures on incident investigation and reporting, recording and reporting of non-conformance, emergency preparedness and response procedures and on-going worker training/awareness. A SEA/SH Action Plan will also be in place to mitigate and manage workplace SEA/SH risks, includng a Code of Conduct to be signed by all workers. The PIU is responsible for overseeing measures related to labor management and working conditions. The PIU will hire one or more staff directly responsible to undertake the overall implementation of the Project in compliance with the provisions on labor and working condition, in addition to the current environmental and social specialists; ensure that contractors prepare their work management procedures which comply with the LMP, OHSP and the C-ESMP before the work commences, ensure that contractors/ sub-contractors respect their obligations towards contract workers, ensure that the potential risks of child labor, forced labor and serious safety concerns for primary supply Apr 19, 2023 Page 9 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) workers are addressed, monitor the training of workers affected by the project; ensure that the complaints mechanism for project workers and PIU is established and implemented and that procedures are in place for workers to sign the Code of Conduct for Workers and any other measures aimed at addressing the risks of sexual exploitation and abuse (SEA) / sexual harassment (SH). The Supervision Engineer will also employ staff to monitor the implementation of labor related measures on behalf of the PIU. Construction companies will be responsible for appointing specialists to manage labor, occupational health and safety issues. They will include measures related to health and safety and labor in their Construction ESMPs which will be approved before civil works. Contractors will also oversee the adherence of their subcontractors to the LMP, maintain records of recruitment and employment of contract workers (including subcontractors) with age verification to avoid child labor, provide induction and regular training to contract workers on environmental, social, occupational health and safety issues, require primary suppliers to identify and address the risks of child labor, forced labor, and serious safety concerns, as well as the risks of equity and discrimination. Contractors will also develop and implement a Grievance Redress Mechanism (GRM) for contract workers, ensure that all contractor and subcontractor workers understand and sign the Code of Conduct before work begins and take all other measures to deal with the risks of sexual exploitation and abuse (SEA) / sexual harassment (SH). ESS3 Resource Efficiency and Pollution Prevention and Management ESS3 is assessed as relevant. During the SOP1 preparation for the Program, due diligence identified that dredging and rehabilitation of Boingoma Port and the two secondary Ports in the Islands could generate pollution from the construction materials, disturb the marine habitat and cause potential damage to marine ecosystem. Analysis Public Disclosure conducted as part of the ESIA prepared for Boingoma Port concluded that the material subject to dredging is not contaminated with heavy metals and hazardous substances. Disposal options for the dredged material were identified and evaluated in accordance with ESS3. It was determined in the port civil works design that the dock is used for storage of the dredging and de-rocking materials. A Dredging Management Plan has been prepared to minimize the impacts on the water quality and marine habitats. This plan is expected to be included as an Annex to the upcoming C-ESMP. For Boingoma port, it is expected up to 10,500 m3 of dredged materials will be produced. These materials are likely to be reused for construction projects at the Island. However, an onshore dumping site, combined with mechanical and/or physico-chemical dehydratation processes are planned to appropriately manage the dredged materials. Construction of temporary worker camps for the construction/rehabilitation of ports are also activities expected to generate pollution. The implementation of mitigation measures such as management plans for construction materials will be applied to reduce and minimize the impact of contamination and pollution to marine and terrestrial areas during construction will be included in contractors’ ESMPs, and residual impacts are expected to be limited in scope and duration. During construction phase, air emissions will include exhaust from heavy vehicles and machinery, and fugitive dust generated by construction activities. Those most likely to be affected are workers on site and people living within the proximity of the construction sites. The implementation of mitigation measures such as dust suppression and vehicle maintenance will be applied to minimize the impact of air emissions during construction, and residual impacts are expected to be limited in scope and duration. The ESIA under preparations for the Domoni quarry will indicate if any Apr 19, 2023 Page 10 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) additional impacts, possibly including blasting, will occur and describe the necessary mitigation measures needed for addressing those impacts. For the Boingoma port expansion under SOP 1, and quarry operations beginning under SOP1 AF, construction activities will generate solid and liquid waste which will primarily include excavated soil and hazardous waste such as hydrocarbon oils from construction machinery and vehicles. The waste generated by the construction works will largely be disposed of at approved sites according with the national laws and regulations. During the operation of the port and improved landing sites, environmental risks may include storm-water runoff and handling or storage of hazardous cargo. Site-specific Waste Management Plans shall be developed for Boingoma port, the Domoni quarry and the secondary ports, respectively in the C-ESMP before launching civil works. The site-specific ESIAs/ESMPs for Boingoma Port, the quarry, and (under SOP2) each secondary Port, as recommended in the ESMF prepared under SOP 1 and which will be updated for SOP2 activities will manage risks relevant to this standard during preparation, construction. Project susceptibility to Climate change related hazards, such as sea level rise, erosion, and flooding have been assessed. The port rehabilitation design and civil works have considered specific measures to manage climate hazard risks. The ESMS to be developed for the port will develop a natural hazard risk preparedness plan before port operation phase. During construction, the greenhouse gas emissions generated by the project are not expected to be substantial given the rehabilitation nature of the works. During operation, the proposed project is expected to contribute to the reduction of greenhouse gas emissions through the reduction of vessel fuel consumption intensity, resulting from the Public Disclosure improved operational capacity of Boingoma port, which will allow a wider range of ships and better utilization, reducing emissions per unit of freight-carriage, the more efficient cargo transportation among the islands due to the adoption of larger vessels serving the secondary ports under SOP2 and more fuel-efficient vessels. The site-specific ESIAs/ESMPs for Boingoma Port and each secondary Port shall manage risks relevant to this standard during preparation, construction, and operational phases. During the operational phase of Boingoma port, it is recommended that ships implement a ballast water management plan with record system, and the harbor master's office must keep records of the types of waste landed on the vessels. A monitoring system of the physical and chemical quality of water should be maintained in collaboration with the regional direction of the environment, the ANAM and the National Park of Mohéli. A water resources study on the availability of water and the estimation of the quantity of water needed by the local population and the quarry operation is being undertaken to strengthen the E&S assessment in the standalone ESIA and the RAP under preparation. ESS4 Community Health and Safety ESS4 is assessed as relevant. During the construction phase, project activities have the potential to expose communities to health and safety risks, especially in those communities that are situated immediately close to the Port construction activities. Communities could also be affected by the potential labor influx and GBV/SEA/SH risks. Apr 19, 2023 Page 11 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) During the preparation of SOP1, the Borrower assessed GBV/SEA/SH risks and prepared a GBV/SEA/SH Risk Assessment and Action Plan, which was updated for SOP1 AF. Influx of workers is the main underlying factor contributing to the risk of GBV/SEA/SH in the project. These risks can be increased mainly due to (i) the influx of a portion of the workforce, including foreign laborers and Comorians who move temporarily between islands for constructon work, some of whom may be far from their families; (ii) increasing the disposable income of workers which can increase the incidence of prostitution (iii) the proximity of the sites to establishments such as schools, markets or other places frequented by women and girls. The Risk Assessment identifies mitigation measures to address this risk including creating awareness on GBV/SEA/SH, instituting a GBV sensitive GRM operating in aress of project actvities, inclusion of GBV/SEA/SH requirements in tender documents, and ensuring that Contractors meet their obligation to establish an Action Plan for the prevention of SEA/GBV/SH, including an Accountability and Intervention Framework which will be integrated into ESMP development. GBV specialists are to be recruited at PIU, Supervision Engineer and Contractor level, and a GBV/SEA/SH Code of Conduct will be signed by all workers. The GBV/SEA/SH Risk Assessment and Action Plan was reviewed and revised for SOP1 AF to assess the risks of quarries and borrow pits and the transport corridor, as well as for new secondary ports, and it includes prevention and mitigation measures. Transportation of dredging materials related to the Boingoma port expansion SOP 1 and vehicle traffic during the civil works for SOP1 and and its AFwill expose communities to health and safety risks from increased traffic during construction. A Traffic Management Plan will be developed as part of the C-ESMP for quarry and transport corridor activities prior to launching civil works. Access to marine transport will also be impacted and measures will need to be in place to minimize health and safety risks where passenger access sites are re-located during construction. Public Disclosure Guidance on managing risks related to traffic has been provided in the ESIAs and ESMF. The Boingoma Port ESIA also includes detailed guidance on management of risks related to marine accidents during the operational phase. The ESIA for Boingoma port is composed of an existing safety and security zones. For the secondary ports to be financed under SOP2, additional ESIAs will include a social assessment to analyze the impacts on coastal livelihoods and recommend proper measures to keep the ecosystem providing regulating services or significant provisioning to local communities. These recommendations will be incorporated into ESMPs and implemented as Coastal Community Development and Livelihood Restoration Plans. For all the construction work, site-specific ESMPs will require contractors to install a safety system around the project sites (fences and safety guards) during the entire construction period. When civil works take place, equipment and vehicles will be brought together to one single well-secured area during the night to ensure both community and worker’s safety. A Community Health & Safety Plan will be required from contractors, which will also include procedures on incident investigation and reporting, recording and reporting of non-conformance, emergency preparedness and response procedures and community awareness raising activities. During the operations phase, measures to ensure the health and safety of passengers will be included in the ESMS to be developed for the Ministry of Maritime and Air Transport. This will provide guidance on managing boat and passenger safety. The C-ESMP shall conduct a traffic management plan, a Risk Hazard Assessment (RHA) for the activities during the civil works that have the potential to generate emergency events or incidents. Based on the results of the RHA, the enterprise shall prepare an Emergency Response Plan (ERP) part of C-ESMP in coordination with the relevant local authorities and the affected communities. For the operations phase of Boingoma Port, the borrower shall conduct a Risk Hazard Assessment (RHA) for the activities during the port exploitation that have the potential to generate emergency event. Based on the results of the RHA, Apr 19, 2023 Page 12 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) the port authority shall prepare an Emergency Response Plan (ERP) part of the ESMS in coordination with the relevant local authorities and the affected communities. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement Port improvement and construction is expected to require minimal, if any, land acquisition. Land occupied by ports belongs to the Government. However, screening and preparation of site-specific RAPs will provide evidence of land ownership and provide information about any existing claims and/or land use that will need to be compensated. For Boingoma Port, a screening was undertaken as part of the ESIA and has shown that no RAP will be needed, although some livelihood restoration measures may be needed for project affected persons in or near the port areas whose traditional livelihoods may be temporarily impacted by consutrctions actvtieis . Construction work will require access roads and borrow pits. In the case of Boingoma port (Fomboni), potential borrow pit sites were screened as part of the Boingoma ESIA. The ESIA and RAP for the Quarry and transport corridor will address any temporary or permanent physical or economic displacement. The RAP and LRP covering the quarry, transport corridor and Boingoma port must be implemented before port construction or quarrying activities commence. For secondary ports, to be financed under SOP2 (not this SOP1 AF), fields with crops may be impacted by access roads. Smaller ports may also require the development of worker camps which will entail temporary land acquisition. RAPs will be prepared and implemented for each port site where necessary. All RAPs will address permanent and temporary land acquisition as well as economic impacts related to formal and informal use of land. Public Disclosure An RPF prepared at SOP1 stage and revised and updated for SOP1 AF provides guidance on managing risks related to land acquisition and resettlement. RAPs will be prepared by a consulting firm and will be implemented by a RAP Service Provider firm during SOP1 AF and SOP2 Project implementation. A Social/Resettlement Specialist has been hired by the PIU and is responsible for overall guidance and supervision on resettlement. The expansion of the Boingoma port and the development of minor infrastructures offshore and at landing sites is expected to disturb the maritime traffic in the area e.g. for the artisanal fisherman and local people who are using the small boats for their daily transportation between the islands (potentially for their jobs). This perturbation will likely have economic impacts on fisherman. Guidance and procedures are indicated in the revised ESMF to develop LRPs with livelihood restoration measures for those affected by restriction of access to fishing sites or other sources of livelihoods. For Port Boingoma, an assessment will be conducted to evaluate if infrastructure poses a threat to fisherman’s Livelihood Resources. For secondary ports, livelihood impacts will be assessed as part of a social assessment of Kwassa Kwassa operators and crew and related port actvities under SOP 2, and any required ESIA/RAP processes. A Coastal Community Development Plan/LRP will be developed in participation with the communities before the implementation of these project subcomponents. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources ESS6 is assessed as relevant. The project has the potential to cause adverse impacts on marine and terrestrial biodiversity around each Port site. The project will also disturb the marine habitat and potentially damage marine biotopes during dredging operation. Apr 19, 2023 Page 13 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) A marine biodiversity assessment was conducted as part of the ESIA prepared for Boingoma port under SOP 1, which concluded that the marine ecosystem is composed of modified habitat. The Boingoma port site is outside the buffer zones of Moheli National Park. The risks and impacts could be reduced to acceptable levels by using of dredging technologies and protective screens to limit the dispersion of resuspended particles and materials. The preparation of a biodiversity management plan (BMP) is not required. But it is necessary to develop a coral reef restoration plan in standalone document prepared by the RENAP and the construction contractor prior to the Port operational phase, in collaboration with the forestry services, before launching of works and relevant experts. During the operational phase of the port, it is recommended that ships implement a ballast water management plan with record system, and the harbor master's office must keep records of the types of waste landed on the vessels. A monitoring system of the physical and chemical quality of water should be maintained in collaboration with the regional direction of the environment, the ANAM and the National Park of Mohéli. The Port Authority will prepare the ESMS to consider the integrity/fragmentation of marine habitats due to marine works, impacts resulting from both construction activities and O&M activities, emergency events and indirect impacts such as increased access to previously inaccessible marine resources / areas should be considered and implemented with the regional direction of the environment, the ANAM and the National Park of Mohéli. Similarly, the port authority ESMS include the requirement to verify inbound ships’ Ballast Water Management Plan, as per IMO’s International Convention for the Control and Management of Ships' Ballast Water and Sediments (2004). ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities Public Disclosure This ESS7 is not relevant as there are no communities nor peoples who meet the World Bank criteria for Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities in Comoros. ESS8 Cultural Heritage ESS8 is assessed as relevant. Based on preliminary information in the ESIA for Boingoma port and ESMF for the secondary ports prepared for the program during SOP1 preparation, the sites that could be potentially affected by the project do not include any cultural heritage. Guidance on “Chance Find Procedures” have been included in the ESMF and ESIAs and a chance find clause will be included in works contracts requiring contractors to stop construction if cultural heritage is encountered during construction and to closely coordinate with the relevant mandated Government authority for the salvaging and restoration of such cultural heritage. ESS9 Financial Intermediaries ESS9 is not relevant to this project. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No Apr 19, 2023 Page 14 of 15 The World Bank Comoros Interisland Connectivity Project Additional Finance (P180734) OP 7.60 Projects in Disputed Areas No B.3. Reliance on Borrower’s policy, legal and institutional framework, relevant to the Project risks and impacts Is this project being prepared for use of Borrower Framework? No Areas where “Use of Borrower Framework” is being considered: Borrower Framework not being considered for this project. IV. CONTACT POINTS World Bank Contact: Atsushi Iimi Title: Senior Transport Specialist Telephone No: +1-202-473-4698 Email: aiimi@worldbank.org Borrower/Client/Recipient Borrower: The Union of Comoros Public Disclosure Implementing Agency(ies) Implementing Agency: Ministry of Maritime and Air Transport V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Atsushi Iimi Practice Manager (ENR/Social) Africa Eshogba Olojoba Cleared on 17-Apr-2023 at 07:36:58 EDT Safeguards Advisor ESSA Martin Henry Lenihan (SAESSA) Concurred on 19-Apr-2023 at 09:40:37 EDT Apr 19, 2023 Page 15 of 15