E2171 Authorized Disclosure REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES Public FADC III CADRE de GESTION ENVIRONNEMENTAL et SOCIAL Authorized (Rapport Provisionnel10/30/2003) Disclosure Public ALKA KOTHARI Authorized Disclosure Public Authorized Disclosure Public REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTALet SOCIAL (FADC III) TABLE OF CONTENTS Page No. List ofAcronyms 3 Executive Summary 4 1.0 Introduction 7 2.0 Project Description 8 3.0 Safeguard Screening Procedures 11 4.0 Baseline Data 13 5.0 Description of the Policy,Legislative, and InstitutionalFrameworks 18 6.0 Guidance on Impacts 23 7.0 Reporting and Responsibilities for the ESME 27 8.0 Proposed Screening Mechaniism and Checklist ofRisks and 31 Capacity Building 9.0 Environmental Management Plan, Review and Clearing 33 Process for Sub-projects Annex 1 Sample Screening Form 38 Annex 2 Procedures for Sub-project Investments Requiring EA 43 Annex 3 Sample Checklist 44 Annex 4 List of Documents Reviewed 46 Annex 5 Villages Visited duringField Mission 47 Amnex 6 Country and Island Maps 48 2 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) List of Acronyms EMP - Environment Management Plan ESIA - Environment and Social Impact Assessment (for sub-projects) ESMF - Enviromnent and Social Management Framework GoC - Government of Comoros FADC - Fonds d'Appui au Developpement Communautaire SEN - Secretariat Executif National SER - Secretariats Executifs Regionaux CP - Comite de Pilotage CGL - Comite de Gestion de l'Eau RPF - Resettlement Policy Framework IEE - Proj et Infrastructure, Eau et Environnement FP - Focal Point 3 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) 1.0 EXECUTIVE SUMMARY The Government of Comoros has requested support for the preparation and financing of an Environmental and Social Management Framework (ESMF) for the third phase of the Comoros Social Fund project. The project intends to support the Government of Comoros' efforts to address the incidence of poverty among the country's poorer communities through the replenishment of a social fund designed to (a) increase access to basic social services for the poorest; (b) stimulate economic activities at the community level; and (c) promote institutional development at the local government and community levels. The proposed credit will support financing for the following four components: a) Community based activities This component would continue to finance small-scale social and economic sub-projects identified by communities, with an expanded menu of services to include social protection programs and capacity building initiatives. Support to community health services will also be financed. Direct community financing will also be piloted and scaled up based on lessons learned. By the end of the project, it is expected that targeted communities would have developed and implemented community based development plans through a participatory planning process. b) Urban water supply and periodic road maintenance on Anjouan and Moheli These activities were already identified under the IEE project and include rehabilitation/maintenance of 184 kilometers of existing national roads, and rehabilitation/extension of water supply in three towns in Anjouan and the capital in Moheli. This component would also finance capacity building of water management committees and Information and Education Campaigns (IEC) on water management, the environment, and hygiene. 3) Support to Rural Development through Income-Generating Activities This component would finance demand-driven income-generating sub-projects to finance small productive infrastructure with beneficiary contribution of at least 20 percent ofthe total sub-project cost. Eligible beneficiaries would be producer organizations and rural communities. Productive infrastructure and off-farm activities would be financed along with support services needed for the identification and implementation of the sub- projects. Finally this component would provide extension and training services, capacity building for the relevant stakeholders, and technical assistance to local financial institutions. 4) Monitoring & Evaluation (M&E) and Project Management This component would support M&E activities, including moving beyond monitoring of project outputs to undertake an impact assessment of the activities of the community based activities over the life of the project. FADC operating costs and key technical assistance are also included under this component. It is expected that the project will be successfully implemented in a cost effective and decentralized mamler. Furthennore, the project will emphasize the participatory monitoring and evaluation approach by involving 4 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) beneficiary communities throughout the project cycle; and use external monitors to build strong transparency in the management of project components. The Main Tasks of the Study are: * To develop an enviromnental and social management framework that establishes methodologies for environmental and social impact assessment within project implementation; * Identify potential policy issues regarding the environment and propose means of resolution that could be undertaken during project implementation; * Develop a capacity building program for stakeholders to carry out Environmental Impact Assessments for micro-projects and to design potential mitigation measures in line with the World Bank's safeguard requirements and environmental legal requirements ofthe Government ofComoros. The ESMF study was carried out by Alka Kothari after a site visit to Comoros from the 18th of August to the 2nd of September 2003. The consultant visited all three islands i.e. Grande Comore, Anjouan and Moheli. Though this is the third phase of the Bank's Social Fund credit to Comoros, it is the first ESMF to be carried out and so special attention was paid by the consultant to ensure that the government, executing agency, and stakeholders were consulted about the type of instrument being prepared and the obligations for its proper implementation. The list of field visits by the consultant is listed in Annex 1together with the list of various stakeholders whom the consultant met during the entire Mission. The list of documents reviewed is given in Annex 3. The GoC by the Decree on Environment Impact Assessment in 2001 and the World Bank's own Operational and Procedural Policies, specifically OP 4.01 requires the government to prepare an ESMF report, which will establish a mechanism to determine and assess future potential environmental and social impacts of project investments for the proposed Social Fund III, and then to set out mitigation, monitoring and institutional measures to be taken during design, implementation and operation of the subprojects to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. This is precisely what is required at this stage of project preparation since the location of the sub-projects have not yet been identified. OP 4.01 further requires that the ESMF report must be disclosed as a separate and stand alone by the GoC and the World Bank as a condition for Bank Appraisal. The disclosure should be both in Comoros where it can be accessed by the general public and local communities and at the Infoshop of the World Banlk and the date for disclosure must precede the date for appraisal of the project. The key highlights in this ESMF report are as follows: (i) For the sub-project activities envisaged in the third Social Fund, the ESMF establishes the screening process mechanism for the implementation of the project activities to enable the local communities and the Comites de Pilotage 5 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) to simultaneously identify adverse potential environmental and social impacts of their project activities and to address them by incorporating the relevant mitigation measures into the designs before they submit them for review and subsequent approval. The main feature of this mechanism requires the project implementers (Comites de Pilotage) to screen their projects at the preparation stage using the screening form in Annex 1 and the environmental and social checklist in Annex 2 to identify potential adverse effects/impacts. The next requirement is for the iinplementers to incorporate the necessary mitigation measures into the project design following which they are to submit the project proposals accompanied by the completed screening form and checklist to the reviewing body, which is the FADC-SER for approval. (ii) The ESMF identified and assessed to the extent possible, potential environmental and social impacts and appropriate mitigation measures and presented this in the forn of a checklist contained in Anlex 1. (iii) The ESMF also developed an environmental and social screening form that would assist in deternining potential adverse environmental and social impacts during project implementation pertaining to the project activities. This fonn is contained in Annex 2. (iv) The capacity of the FADC to manage the ESMF was assessed. It was found that the FADC required further strengthening through training in order to properly manage the Framework. A training program and budget was developed and is contained in the body of the ESMF. The Comites de Pilotage, which are to be elected bodies that would represent the local communities and help them to meet their responsibilities in the EA process as outlined in this ESMF would greatly benefit from technical assistance and training. The Department of Environment will also benefit from technical assistance to facilitate their monitoring and supervision of training role. (v) Finally the ESMF contains an extensive and comprehensive environmental and social monitoring plan to ensure that environmental and social issues will be managed effectively. (vi) Meaningful consultations with local communities were held during the in- country study part of the preparation, during which they were sensitized on the requirements ofthe RPF and ESMF. This Environment and Social Management Framework Report presents definitive, conclusive and clear procedures consistent with the Laws in Comoros and the World Bank Safeguard Policies. 6 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) 1.0 INTRODUCTION The Government of Comoros has requested support for the preparation and financing of an Environmental and Social Management Framework (ESMF) for the third phase of the Comoros Social Fund project. The project intends to support the Government of Comoros' efforts to address the incidence of poverty among the country's poorer communities through the replenishment of a social fund designed to (a) increase access to basic social services for the poorest; (b) stimulate economic activities at the community level; and (c) promote institutional development at the local government and community levels. This is the report of a study to produce an environmental and social management framework (ESMF) for the proposed Social Fund III. 1.1 The Objectives of the Study are: * To assess the potential environmental and social impacts of the Social Fund Project, whether positive or negative, and propose mitigation measures which will effectively address these impacts; * To inform the project preparation team and the Comorian Government of the potential impact of different anticipated sub-projects, and relevant mitigation measures and strategies; * To establish clear directives and methodologies for the environmental and social screening of micro-projects to be financed by the project through the FADC. 1.2 The Main Tasks of the Study are: * To develop an environmental and social management framework that establishes methodologies for environmental and social impact assessment within project implementation; * Identify potential policy issues regarding the environment and propose means of resolution that could be undertaken during project implementation; * Develop a capacity building program for stakeholders to carry out Environmental Impact Assessments for micro-projects and to design potential mitigation measures in line with the World Bank's safeguard requirements and environmental legal requirements of the Government of Comoros. 7 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) The ESMF study was carried out by Alka Kothari after a site visit to Comoros between the 2003. The consultant visited all three islands, 18th of August to the nd of September 2 i.e. Grande Comore, Anjouan and Moheli. Though this is the third phase of the Bank's Social Fund credit to Comoros, it is the first ESMF to be implemented, and so special attention was paid by the consultant to ensure that the government, executing agency FADC, and stakeholders were consulted about the type of instrument being prepared and the obligations for its proper implementation. The list of field visits by the consultant is listed in Annex 5. The list of documents reviewed is given in Annex 3. 1.3. Purpose of the Environmental and Social Management Framework Study The consultant has been charged with the development of an Environmental and Social Management Framework, because the precise details of the demand driven micro- projects - in terms of exact location, materials required, key communities, etc. - to be financed under the Social Fund Project are not yet determined. This is the case for the community-driven development component but will also apply in the Infrastructure, Water and Environmental component of the proposed project. These components are discussed in greater detail in Chapter 2 under proj ect description. The principal purpose of the Environmental and Social Management Framework (ESMF) is to screen the sub-projects on their environmental and social merits and manage their potential environimental and social impacts. 2.0 DESCRIPTION du PROJET Les objectifs proposes du nouveau projet FADC sont l'amelioration des conditions de vie d'un nombre significatif des communautes defavorisees et des groupes vuln6rables specifiques; l'augmentation de la capacite des communautes et acteurs locaux dans le processus de planification pour le developpement ; et l'augmentation de la responsabilite au niveau local et la transparence. FADC III est structure pour atteindre ses objectifs a moins de quatre composants principaux d'investissements du projet, qui sont; * Finiancernentdes sous projets pour am6liorer les conditions de vie de la population; * Reniforcemnent des Capacitis stratigiques, au profit des partenaires du FADC et y compris des activites d'IEC s'adressant a l'ensemble de la population; * Appui au Developpemnent Rural Productif, a travers les activites generatrices de revenus (AGR), en faisant la liaison entre les micro credits et les infrastructures qui pourraient etre n6cessaires pour accompagner les cr6dits; et * Gestioni du Projet. COMPOSANTE 1 : FINANCEMENT DES SOUS PROJ ETS Cette composante pourra comprendre plusieurs sous volets, notamment (i) des petits investissements sociaux; (ii) des programmes de protection sociale; et (iii) les 8 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) investissements prioritaires en l'adduction d'eau et l'entretien p6riodique des routes (identifies dans le contexte du projet Infrastructure, Eau et Environnement - IEE r6cemment cl6tur6). En outre, un sous volet destine a appuyer la sante pourrait etre envisage. COMPOSANTE 2: RENFORCEMENT DE CAPACITE L'objectif de cette composante serait de renforcer la capacite aux niveaux locaux, y compris les communautes, les gouvemements locaux, et les autres partenaires, tels que les societ6s civiles, avec comme but final d'ameliorer les services sociaux et les infrastructures. Le proj et propose doit egalement augmenter la responsabilite et la transparence et doit aussi foumir des motivations pour le developpement d'une bonne gouvemance. L'exigence des communautes pour de meilleurs services publics et la responsabilite a leur egard peuvent etre stimulees par l'introduction des modeles de planification de developpement et de l'engagement des communautes comparable a ceux des fonds sociaux. La participation communautaire ainsi que le renforcement de sa capacite de planification de sous-projets, de leur mise en oeuvre, de leur gestion et de leur suivi seront renforcees, avec pour consequences une amelioration de la transparence dans la budgetisation et dans les d6penses. Cette composante pourrait appuyer deux types de renforcement de capacite: a)Activites pilotespour le developpement local: Ces activites pilotes pourraient promouvoir des activites telles que le financement direct des communautes, de la planification communautaire et de la planification au niveau des communes (inter-village); et b) Investissements strategiquespourle renforcementde capacitetelles que des activites visant a ameliorer la qualite du service public, a r6aliser une sensibilisation pour la prevention du SIDA, y compris le traitement des dechets medicaux, ou une sensibilisation aux problemes environnementaux, etc. COMPOSANTE 3: APPUI AU DEVELOPPEMENT RURAL ET ACTIVITES GENERATRICES DE REVENUS (AGR) Cette composante a l'objectif sp6cifique de l'augmentation de la productivite et de la production dans certains secteurs afin de promouvoir la croissance en milieu rural. I1est propose d'adopter une approche associative et de travailler avec les differentes formes d'organisations paysannes et de producteurs. I1est egalement propose de financer des sous-projets comprenant des infrastructures productives a travers des subventions incluant une contribution des beneficiaires ainsi que les fonds de roulement a travers des credits. La gestion et l'exploitation des infrastructures productives devraient se faire en commun mais la production resterait individuelle. I1est envisage que le financement des sous-projets se fera en collaboration avec les institutions de financement et de micro- finance a travers un systeme de co-financement. COMPOSANTE 4: GESTION DU PROJET Cette composante financera les cofits operationnels du projet, ainsi que l'assistance technique et le suivi et 6valuation du projet. Cette derniere activite constitue un element 9 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) cle pour assurer que cette phase du projet aura l'impact desire au niveau des populations plus defavoris6es. Pour ce faire, il y aura une evaluation d'iimpact des demieres phases du projet afin de pouvoir tirer des le,ons requises pour l'amelioration du systeme de suivi et evaluation. Le proj et financera egalement une etude institutionnelle pour evaluer les forces et faiblesses du FADC et pour formuler des recommandations sur les besoins en nouveau personnel ou en renforcement de capacit6 du personnel existant. 2.2. The Social Fund project will finance community-initiated development projects and is expected to finance mostly rehabilitation and/or construction ofbasic health and education infrastructure, feeder roads, income generating activities, community water supply schemes, road maintenance, and capacity building activities. It is envisaged that some of these sub-projects will involve the construction of water supply and sanitation facilities, primary education facilities, primary health care facilities, solid waste management (medical waste), etc. Since at the time of preparation the sub-projects had not yet been identified, the GoC by the Decret N°0 1-052/CE and Operational Policy 4.01 of the Bank require the GoC to prepare an Environment and Social Management Framework which establishes an instrument used to determine and assess future potential environmental and social impacts of sub-project investments under components one and two ofthe proposed Social Fund III. To this effect, the project will initiate a comprehensive Social and Environmental Awareness Building Program coupled with capacity building activities to enable the communities to better understand the essence of sustainable development through proper management of the natural resource base which they depend on for their livelihood. The project will hire an environmental/social specialist who will work under the FADC and in collaboration with the National Environment Department to implement the Social and Enviromnental Awareness Building Program, put in place monitoring, mitigation and institutional measures to eliminate any adverse environmental and social impacts, offset them, or reduce them to sustainable levels. 2.3. Target Areas The Social Fund project is expected to intervene on all three islands. These interventions will be managed by Regional FADC offices in collaboration with the Comites de Pilotage who implement the projects and represent the main beneficiaries. It is therefore essential that the proposed awareness building program goes hand in hand with the sub-project identification to allow for better understanding of the environmental and social consequences of their selection. (See screening process) Since the sub-projects mentioned above are to be created on a demand driven basis, each sub-project that is subsequently identified and promoted by the local community would be subjected to an environmental and social screening. The main feature ofthis screening mechanism requires the project's Coordination Unit, the Comites de Pilotage to understand the screening forms in Annex 1 and the environmental and social checklist in Anmex 2. Once identified, the process evaluates alternatives and designs appropriate mitigation, management and monitoring measures. The other important requirement is for the implementers to incorporate the necessary mitigation measures into the project design 10 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) following which they are to submit the project proposals accompanied by the completed screening form and checklist to the reviewing body, which is the FADC-SER for approval. 3.0 SAFEGUARD SCREENING PROCEDURES The proposed Environmental and Social Management Framework has been designed to fully comply with national environmental codes and legislations in Comoros and with the World Bank's environmental and social safeguard policies. This chapter sets out the key safeguard policies that provide the policy context to the ESMF including World Bank policies and Comoro's legal requirements on environmental assessment. More details of the policy context are provided in Annex 3. As part ofthe ESMF process, proposed micro-activities under the Social Fund III will be designed at the local level to ensure that they are screened for potential impacts and that they comply with the requirements set out under World Bank safeguard policies. The Social Fund III is anticipated to set the pace to ensure that negative impacts on the environment are minimized. One of its main objectives is therefore to promote sustainable land use and ecologically sound natural resources management through community driven development. Despite these efforts and due to the nature ofthe potential micro-projects to be financed under the project as well as the recently inherited Infrastructure, Water and Environment project, which involves infrastructure and water rehabilitation, the proposed project has been rated Category B under the World Bank's policy on environmental assessment (OP 4.01), requiring an Environmental and Social Management Framework (ESMF). The ESMF is required to assess the potential impacts associated with micro-projects. In addition to the OP 4.01, the Social Fund has also triggered the Bank Involuntary Resettlement Policy OP4. 12 Table3.1, and as such a Resettlement Policy Framework will be prepared. REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Table3.0 SafeguardPolicies Policy Applicability Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) Yes Natural Habitats (OP 4.04, BP 4.04, GP 4.04) No Forestry (OP4.36, GP 4.36) No Pest Management (OP 4.09) No Cultural Property (OPN 11.03) No Indigenous Peoples (OD 4.20) No Involuntary Resettlement (OP4. 12, BP 4.12) Yes Safety of Dames (OP 4.37, BP 4.37) No Projects in International Waters (OP 7.50, BP 7.50, GP 7.50) No Projects in Disputed Areas (OP 7.60, BP 7.60, GP 7.60) No 3.1 Justification for preparation of the ESMF and the RPF OP4.01 (EnvironmentalAssessment) The OP 4.01 has been triggered because there is the potential that implementation of the sub-projects in one of the most fragile ecological systems and by people whose knowledge of the fragility of these systems is limited ,may lead to negative environmental impacts. Site visits on executed past sub-projects has determined that there are no potential large-scale, significant or irreversible environmental impacts associated with the project. The potential impacts identified are mainly localized impacts associated with activities to be financed under the local investment funds (i.e. rural roads, feeder roads through forest zones, tracks and pathways in pastoral zones, small scale dams, piped water systems, wetlands and ecosystem management, and rangeland management), which can be effectively mitigated and are addressed in the ESMF and using the screening and review procedures in Chapter6. The ESMF identifies the major potential environmental issues that could arise as a result of project interventions and proposes measures to be taken to mitigate these effects, including proposed training and monitoring measures. OP4.12 (InvoluntaryResettlement) The Project will support community investments in various types of micro-projects, of which many, particularly those involving small-scale infrastructure, will require land for construction. To mitigate against the potential for involuntary resettlement, a Resettlement Policy Framework (RPF) has been prepared which provides the framework for resettlement planning under the Social Fund. The screening tools provided in Annex 2 have been designed to address issues of resettlement and land acquisition in parallel with the screening criteria developed under the RPF. The difficulty in Comoros is that there are no clearly followed land tenure laws or policies and the existing traditional and religious systems have been seriously tampered with during the several coup d'etats and countless changes of Govenmment. 12 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) 3.2. Mainstreaming Bank Safeguards into sub-project screening The screening criteria provided in the ESMF includes relevant questions on natural habitats/protected areas, involuntary resettlement and land acquisition, introduction of pesticides, impacts to forestry resources, impacts to cultural property and inclusion of indigenous people in the project identification process. This is meant to ensure that all concerns related to the Bank's safeguard policies are taken into account during the screening of micro-projects for potential impacts, and that the appropriate mitigation measures can be adopted to address them. 4.0 BASELINE DATA This Chapter provides key baseline information relevant to the proposed project sites and gives a detailed assessment of Comoro's baseline features as they relate to the social fund project. The Social Fund project is expected to intervene on all the three islands and these interventions will be managed by Regional FADC offices in collaboration with the Comite de Pilotage, thus the need to give detailed information ofthe country as a whole. The Islamic Federation of Comoros is an archipelago consisting of three islands, the largest being Grand Comore, then Anjouan and Moheli. Formerly a French colony, the fourth island, Mayotte, still remains a department of France. GNP per capita was estimated at US$414 in 2002, down from about US$520 in the late 1980s. 4.2.1 Physical Environment The islands are located in the Mozambique Channel, about two-thirds of the way between northern Madagascar and northern Mozambique. The islands are ofvolcanic origin and are mountainous with Grand Comore, the youngest of the islands and closest to mainland Africa, still housing a massive active volcano. The summit ofthe volcano Kartala is also the highest point on the islands, measuring 2361 m (7746 ft) above sea level. Seismic activity has increased dramatically since 2000 and experts are concerned that a very violent eruption may occur in the near future. 4.2.2 Climate The Comoros climate is tropical with a monsoon season from November to April. The range of annual rainfall is from 109 to 551 cm (43 to 217 in) and there are frequent cyclones. There are approximately 2000 endemic plant species in Comoros and several species of marine life native to Comoros, including two species of sea turtles. Widespread conversion of forest to agricultural land and poaching of sea turtles has left many of the endemic species severely threatened while others have already gone extinct. Conservation of the remaining forested areas must be a priority for the conservation of 13 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) endemic species. Nonetheless, there are only two protected park areas, both on the island ofMoheli. There is a national park and a marine park funded by a UNDP-GEF grant. Comoros is a member ofmany regional and international organizations and is a signatory to many international agreements on the environment that address: Biodiversity, Climate Change, Desertification, Endangered Species, Hazardous Wastes, Law of the Sea, Ozone Layer Protection, Ship Pollution, and Wetlands. The most pressing environment issues and cause for concern are deforestation, soil erosion, coastal and beach erosion, and solid and liquid waste management. 4.3 SOCIO ECONOMIC ENVIORNMENT 4.3.1 Population and Migration The estimated population of the three islands as of July 2000 was over 550,000 people of which approximately 50% live in Grand Comore, 42% in Anjouan and 8% in Moheli. A fourth island of the archipelago, Mayotte, has remained under French sovereignty. Covering an area of only 2,336 km, Comoros has a very high population density, with the island ofAnjouan being the most populated. In recent decades the population was increased by the forced evacuation of Comorians from Madagascar and Zanzibar. These peoples resettled in the Comoros adding to an already difficult situation. Comorians can be found living in many parts of the world but most of the emigrants are in Europe or in Kenya and Zanzibar along the East African coast. There are an estimated 60,000 Comorians or people of Comorian descent living in France today. The present population increase is an estimated 3.5% per year with an annual birth rate of 47 births per 1,000 and an annual death rate of 12 deaths per 1,000. The most recent estimate of the total fertility rate is6.8 children born per woman. Life expectancy at birth is 54 years for males and 59 years for females. The inhabitants are a blend ofvarious peoples ofthe Indian Ocean littoral. African, Malagasy, and Arabic features are clearly evident. Maritime commerce before entry of Europeans into the Indian Ocean brought Comorians into contact with peoples from southern Africa to Southeast Asia. Since the end of the fifteenth century European influence has also impacted upon Comorian life. 4.3.2 National Economy In 2001, per capita GDP was US$380, the same as in 1982, which makes Comoros one of the poorest nations in the world and is ranked number 168. The country's poor economic performance has been due to a conglomeration of issues, chief among them is the continued political disturbances. National Comorian politics have been characterized by 14 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) rapid changes of direction and numerous coups with intervention of foreign mercenaries, all contributing to an instability that has not allowed strong institutions to emerge. The lack of government commitment toward socio-economic development has lead to widespread disillusion with the state. Agriculture is the most important sector of the economy, employing over 80% of the work force and accounting for almost 100% of exports. Two agricultural zones are generally defined: the coastal area, which ranges in elevation from sea level to 400 meters and which supports cash crops such as vanilla, ylang-ylang, and cloves; and the highlands, which support cultivation of crops for domestic consumption, such as cassava, bananas, rain rice, and sweet potatoes. As the population increased, food grown for domestic use met fewer and fewer of Cormorians' needs. The republic imports virtually all its meat and vegetables; rice imports alone often account for up to 30 percent of the value of all imports. France is Comoros' largest trading partner. 4.3.3 Public Health Life expectancy stands at 60 years and the infant mortality rate is 76 per 1000 births. High rates of malnutrition among children, such as the 43 % rate of chronic moderate malnutrition among children less than two years old, and its effect on resistance to infectious diseases indicate that the mortality rate will continue to be high. The crude birthrate is 48 per 1,000 and the crude death rate, 12 per 1,000. Malaria is ubiquitous in the islands, with 80 to 90 percent of the population said to be affected by the disease. Other prevalent maladies included tuberculosis, leprosy, and parasitic diseases. Despite improvements in life expectancy, infant mortality, and the number of physicians, the overall quality of care remains poor. About 80 percent of the population lives within one hour's walk of a health facility, usually headed by a trained nurse, but paramedical staff are in short supply and many health facilities are in poor condition. Some international medical aid has been provided, mostly by France and the World Health Organization (WHO). 4.3.4 Political History and Governance In 1978 the Comoros was proclaimed a federal Islamic republic; shortly thereafter, a one- party state was formed under President Ahmed Abdullah Abdurrahman. After his assassination in 1989, SaYd Mohamed Djohar became interim president and subsequently won election in a multiparty contest. He survived an impeachment attempt in 1991 and several coup attempts. In 1996 Mohamed Taki Abdulkarim was elected president. In 1997 rebels took control of the islands of Anjouan and Moheli, declaring their secession and desire to return to French rule. In 1999 the islands were granted greater autonomy. Following a coup in Apr. 1999, Col. Azali Assoumani assumed the Comorian presidency. Anjouan voted (2000) for independence, but in 2001 forces favoring reuniting with the Comoros seized power there, and a Comorian referendum approved additional autonomy for the three islands. Azali resigned in 2002 prior to new elections, and Prime Minister Hamada Madi became interim president. After two disputed elections, Azali was declared president in May 2002. 15 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) 4.3.5 Religion and Education Comoros is a Federal Islamic Republic, and officially the population is 100% Muslim. As Sunni Muslims, the Comorians follow religious observances conscientiously and strictly adhere to religious orthodoxy. During the period ofcolonization, the French did not attempt to supplant Islamic customs and practices and were careful to respect the precedents of Islamic law. Hundreds ofmosques dot the islands. Practically all children attend Quranic school for two or three years, starting around age five; there they learn the rudiments of the Islamic faith and some classical Arabic. When rural children attend these schools, they sometimes move away from home and help the teacher work his land. France established a system ofprimary and secondary schools based on the French model, which remains largely in place. Comoran law requires all children to complete eight years of schooling between the ages of seven and fifteen. Comoros has no university. Those desiring higher education must study abroad; a "brain drain" has resulted because few university graduates are willing to return to the islands. Teacher training and other specialized courses are available at the M'Vouni School for Higher Education, in operation since 1981 at a site near Moroni. As elsewhere in Comoran society, political instability has taken a toll on the education system. Routinely announced reductions in force among the civil service, often made in response to international pressure for fiscal reform, sometimes result in teacher strikes. When civil service cutbacks result in canceled classes or examinations, students have at times taken to the streets in protest. 4.4 ACCESS to RESOURCES 4.4.1 Access to Land Comoros' land tenure laws are archaic and contradictory and the tenure system is largely governed by traditional and religious systems which are complex. The reason for this complexity is due to a conglomeration of factors. There are three types of land tenure system in Comoros, customary, Islamic, and French administrative. The French laws are still on the books, though the islands have been independent since 1975, but the unwritten customary and Islamic laws are the ones most commonly respected and practiced. At present, there is no applicable Code Foncier addressing land holding, management control, dispute processing, expropriation and resettlement, or valuation principles for compensation. Comoros is clearly lacking in the needed regulatory and administrative framework for issues related to land tenure. The best recommendation that can be made within the framework of the RPF is to apply the World Bank policies until such time when the country prepares its own consistent land laws. 4.4.2 Access to Potable Water 16 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Social Funds I and II have been very successful in providing access to water to the majority of the population. From 1996 to 2001 the access to water went from 76% of the population to 92%. Nonetheless, as deforestation continues, both because of increased population density helped by a young and fertile population, and because of unsustainably heavy use of wood for the production of ylang-ylang, the rivers continue to dry up on Anjouan and Moheli and water grows scarcer. 4.4.3 Access to Capital The rural people of Comoros have the lowest access to capital and no access to financial services. The economy of the poor and vulnerable groups of the islands particularly in Moheli and Anjouan remain largely non-liquid due primarily to the absence of financial services and the lack ofmicro-credit organizations. For this particular reason, the proposed project toils with the idea of creating a micro-credit component to be managed by the FADC. This is a move in the right direction but with the lack of financial management capacity within the FADC, coupled with the fact that social funds are not usually designed to handle micro-credits, the Bank is skeptical. In my view and in the spirit of enhancing the investment and revenue earning capability ofthese poor and vulnerable communities, FADC's capacity can be built to take on this challenge. It is so far the most credible institution working with communities and which enjoys community trust. While providing collateral may be the main stumbling block, communal trust can be a way forward in testing the resolve ofthese groups in taking their destinies in their own hands. On the three islands, there are several and extremely important linkages between livelihoods and environmental resources, which are relevant to rural areas on all three islands. These are outlined below. Exploitation of local vegetation Wood har-vesting The forest cover in Comoros is seriously affected because wood is used for several purposes, the main one being a source of energy, building material and most importantly for distilling ylang-ylang for export. Wood represents an extremely high percentage of the domestic energy consumed on all the islands and the annual loss ofwooded surfaces in Comoros ifcontinued unabated will lead to severe erosion of fragile mountain slopes. Bushfires Fire is used for the following in Comoros: (i) clearing the fields; (ii) hunting; (iii) improving visibility; (iv) accelerating the re-growth ofperenlial grasses; and (v) customary rituals. Fire impoverishes the soil and reduces its productivity, by causing the loss ofcertain nutrients (nitrogen, sulfur), and organic matter. More than 75% of fires occur between October and December. 17 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Unsustainablefarmiingpractices Unsustainable farming in Comoros, particularly in the coconut and banana fanns on the hill slopes, soil degradation and de-vegetation and serious erosion has become major enviromnental issues. Eroded sites have been protected by external species which due to their dispersal systems and the lack ofpredators to control their expansion are rapidly competing with the indigenous plant spices. In some areas the rapid expansion of acacia with its effective dispersal system has led to significant impoverishment of the soils which in turn has reduced the agricultural productivity and in some areas led to zero productivity. Also, very important is the fact that the introduction of foreign species contributes to the loss of biodiversity. Soil Erosion Coastal zone erosion is a serous and real problem in Comoros which has led the communities to invest heavily in coastal zone protection through dykes and building of walls to protect the intrusion. 5.0 DESCRIPTION of the POLICY, REGULATORY, LEGISLATIVE, and INSTITUTIONAL FRAMEWORKS 5.1 Legislative and Policy Framework The legislative and policy framework for environmental protection and management is extremely weak in Comoros. There is a National Environmental Policy that has been articulated, but most of the legislation outlined in the policy is yet to be written and/or made operational. It speaks of sectoral policies that require definition, namely a land tenure system, a water policy and a policy on waste management. It is of critical importance to the sustainable development of all three islands that this legislation is passed and applied to all future projects with the Bank and other lenders. Even where there is legislation already in place, there is a grave lack of capacity and funds to implement this legislation. As of April 19, 20001, a decree specific to environmental assessment was put in place, but the Director of Environment complained that there has yet to be any enforcement of the decree. With Bank requirements in mind for those sub-projects which require additional environmental work, as determined under the screening and review process, the building of the capacity at the national, regional, and local level is called for. This is the only way to allow the national enviromnental agency to exercise its mandate. This will also ensure that sub-projects that may have potentially significant impacts and require more detailed study, receive national, regional, and local level attention and approval. There are several Decret and Arrete relating to protection of biodiversity, including Arr6te N 01/3]/MPE/CABportantprotectiondes especes defaune etflore sauvages des Conmores du 14/05/2001, and Arr6te N 01/32/MPE/CABportantadoption de la Strategie Nationaleet duPland 'Actionpourla Conservationde la DiversiteBiologiquede 14/05/2001. The creation of the Parc Marin in Moheli is an extremely promising model, 18 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) which built on these Arretes to develop an organization that protects the marine life, especially les tortues marins, from fishing and poaching, the coral reefs, vegetation and surrounding forest. The Decret N 01-053/CE creating the Park mandates a Conservator to a committee to manage the Park, forbids any industrial or commercial activity with the limits ofthe Park, plans for eco-tourism, and strictly enforceable penalties for violation of the rules. Land Tenure and Ownership Conceming land take, at present, based on the field visits and consultations and with beneficiaries, it is clear that there will not be any land take, loss of economic activities, and/or relocation. 5.2 Administrative Structures and Responsibilities FADC is made up ofthe following groups: 1- Le Comite Central de Coordination (CCC) 2- Le Secrtariat Executif National (SEN) 3- Les Comites Regionaux (CR) 4- Les Bureaux Regionaux denommes Secretariats Ex6cutifs Regionaux (SER) 5- Les Comites de Pilotage (CP) Table5.2 FADCAdministration Unit Responsibility National Level Le Comite Central de Coordination . Comprised of representatives of relevant Ministries and civil (CCC) society, * Adopts the Manual of Procedures * Charged with financial management and definition of overall policy * Review quarterly reports from FADC-SEN and FADC-SER FADC National a etudier et proposer au CCC les elements de la politique et de la strategie de financement des projets de developpement communautaire sur la base des orientations arretees par le CCC conformrment aux objectifs d'ensemble de l'Etat * apporter un appui au montage des dossiers de sous-projets exigeant des competences techniques qui ne se trouvent pas au niveau regional * contribuer a l'evaluation a posteriorides sous-projets et des interventions du FADCE * pr6parer le budget et assurer la gestion administrative et financiere du FADC * requerir toute assistance expatriee ou etude specifique necessa re ' la bonne r.alisati...des.pro.ets Regionial Level 19 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) Unit Responsibility Comites Regionaux . elaborer et proposer une politique et une strategie de developpement communautaire regional * collaborer avec les SER en vue d'assurer la liaison necessaire avec les communautes locales pour d6finir les projets repondant aux besoins communautaires des populations les plus desheritees * servir de premier recours au personnel des SER ainsi qu'aux comites de pilotage pour regler d'eventuels diff6rends. · diriger les assemblees generales des Comites de pilotage .................................................................................................................................................... ................... ............................................................................................................... ............. ............................. ................. FADC-SER · animer la campagne de sensibilisation, d'information et de (Les Secr6tariats Executifs formation au niveau des communautes de la region R6gionaux) . etudier et proposer aux CR les elements d'une strategie de financement des projets de developpement communautaire * foumir un appui technique et financier aux communautes dans la preparation et lexecution des sous-projets * Organiser les assemblees g6nerales des comites de pilotage * assurer le suivi des sous-projets realises et veiller au respect des conventions de financement par les communautes beneficiaires * Responsible for reviewing sub-project applications for technical and financial feasibility before submission for . ~~~~~~~~~~~~~.a................ ppvafo finacig .................................................... ............................. .............. ...................................................................................................... ...... ....... . . ....................................................... ........................ Local Level Comite de pilotage . identifier, en liaison avec le SER, les sous-projets d'int6r&t public * sensibiliser les communaut6s sur limportance des projets identifies * preparer, en collaboration avec le SER, un projet de budget couvrant les depenses d'execution et d'entretien, et definir les differentes contributions de la population interessee; * obtenir un engagement ferme de la ou des conimunautes villageoises sur la participation effective de celles-ci a lVex6cution et au suivi des travaux d6coulant des projets agrees par le FADC * mobiliser les ressources locales tant humaines, materielles que financieres n6cessaires a l'execution des sous-projets, et de rendre compte p6riodiquemnent au SER et ala communaute sur l'etat d'avancement des travaux 5.2 INSTITUTIONAL FRAMEWORK At the national level, the principal institutional agency dealing with the environment in Comoros is the Ministry of Rural Development, Fisheries and the Environment. The Department ofEnvironment was established as an autonomous institution by the Federal Government of Comoros in 1997 and has three regional offices on each island, with the main office in Moroni. The Department has a staff of four technicians with no staff in the regional offices. Its mandate includes the follow tasks: prepare and implement environmental policy and laws, recently institute a system for EA, set environmental standards, combat erosion and deforestation, take regulatory action to protect the environment, enhance environmental awareness, implement international treaties, and provide support to the three islands. 20 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) The Comite Central de Coordination (CCC) ofthe executing agency, FADC, acts as a Board ofDirectors setting the overall policies of FADC. It is composed of 15 members who are appointed by decree: 7 representatives from the Government Ministries and 8 representatives from associations (2 from each island and 2 from national associations). It meets twice a year. Its responsibilities are to set FADC policies, approve the manual of procedures and annual work programs and budgets, decide on the level of community contribution to the cost of the sub-projects, analyze and audit reports, and appoint the National Executive Director and Regional Executive Directors. The Comites Regionals (CR) are in place in each ofthe three islands. They are composed of eight members: 2 representatives from the regional directorates of Government Ministries and 6 other non-governmental members representing regional associations and chosen on the basis of their qualifications and their knowledge of communities. Their primary responsibilities are to endorse the annual work programs proposed by the Regional Secretariats (FADC-SER), approve (through a regional project sub-committee) all grants of less than CF 15 million, and submit to the Directeur Executif National ofFADC for decision ofproposals for grants equal to or greater than CF 15 million. A Presidential Ordinance established FADC, an "organization in the public interest with administrative and financial autonomy", on January 6, 1993. A Presidential Decree of April 13, 1993 defines its organization and management. The Secretariat Executif National (SEN) and the three Secretariat Executif Regional (SER) are the administrative/executing entities, which deal with the day-to-day operations of the FADC on the three islands. FADC has clear operating procedures, which are defined in a Manual of Procedures. This manual contains the criteria and procedures for identifying, preparing, appraising, selecting, and implementing sub-projects. FADC will review community proposals against the criteria defined in the Manual of Procedures, including community participation, impact, and priorities. Once approved by FADC, the local communities or beneficiaries will implement the sub-projects, which is in most cases by the Comite de Pilotage. These village committees work with FADC-SER in identifying, preparing and implementing sub-projects. In accordance with the contracts that they enter into with FADC, the village committees are also responsible for mobilizing communities to provide labor, materials, and cash for the sub-projects. Given the lack of capacity at the national or regional level within the Department of Environment, and the demonstrated ability to successfully manage both previous Social Funds, FADC will remain the executing agency for the third phase of the project. The successful application of the environmental and social assessment process (contained in this ESMF) at the level of the sub-projects will identify adverse environmental and social impacts as they relate to sub-project activities. To mitigate the project impacts effectively, the proposed institutional arrangements provide for environmental and social assessment capacity building for the CPs at the local level, and environmental and social oversight capacity building at the regional and central levels for FADC-SER and FADC- SEN. 21 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) Functions of Key Institutions for the Successful Implementation of this ESMF; 1) Comites de Pilotage: Consistent with OP 4.01 Environment Assessment, the CPs will screen their sub-projects for environmental and social impacts at the time of identification. They will apply the environmental and social assessment process for sub- projects outlined in this Framework document, and thus prepare their sub-project proposals consistent with the provisions of this ESMF. The key elements for successful sub-project implementation by the CPs are: * Capacity to manage the environmental and social management process for sub-projects: To enable CPs to apply the environmental assessment process for sub-projects effectively, they will require technical support. At the sub-project identification stage, this technical support would be provided through FADC-SER and an environmental and social specialist who would be responsible for assisting the CPs in the preparation of sub-project proposals, including resettlement plans (if needed) and environmental and social screening and preparation of mitigation measures as necessary and environmental and social assessment reports consistent with this framework document. * Capacity to manage potential social impacts of sub-projects: To ensure that social impacts of sub-projects are addressed appropriately, a separate Resettlement Policy Framework (RPF) has been prepared. It outlines the principles to be applied in the event that negative social impacts arise due to the need for land acquisition, or access to economic resources is loss, denied or restricted to sub-project activities. CPs will be assisted by a social specialist to prepare the resettlement plans required by the RPF document. FADC will support the CPs to avail them of expert advice when needed by hiring a qualified environmental and social assessment specialist to assist and work with them to carry out their tasks. Following training and assistance, the ability of the CPs to conduct environmental and social screening and to prepare appropriate mitigation measures for sub-projects will be greatly enhanced and will not only raise the environmental awareness among CPs, but will also ensure that the sub-projects are environmentally and socially sustainable. Over time, the CPs will develop the capacity to screen potential investments for environrmental and social impacts and to prepare and implement simple enviromnental mitigation measures independently. FADC-SER will also be responsible for the monitoring of (i) the environmental and social assessment work to be carried out by the CPs assisted; (ii) environmental and social monitoring of sub-projects; and (iii) overseeing the implementation ofresettlement plans. Capacity of FADC will be enhanced by environmental and social assessment specialists who will be hired by FADC to work with FADC at the national and regional level to ensure that they carry out their role effectively. 22 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) Finally, the recently adopted Infrastructure, Water and Enviro1nmenlt Project will be administered by FADC and finances will be channelled through the FADC which works at the national, regional and community levels. Approval of sub-project EAs by the Department of Environment To ensure that the Environment Department is given the recognition and role it deserves in the country's overall development process and to also ensure that it exercises its mandate, it should be part of the approval process of any sub-project with potential impacts. 6.0 GUIDANCE ON POTENTIAL IMPACTS This section of the report presents guidance on the environmental and social impacts of the Social Fund III project, and potential impacts of the anticipated sub-project activities. The main focus of the guidance is to provide a set ofprocedures for the FADC staff who will be charged with the responsibility of implementing the Environmental and Social Management Framework. We discuss both the positive and negative impacts of both programs. We begin with conclusions on the overall impacts and specific impacts are described in greater detail for community sub- projects to be funded through the FADC. 6.1 Overall Environmental and Social Impacts Environmental and social sustainability are key to sustainable rural development, natural resources management and conservation and poverty alleviation, particularly in countries like Comoros with its fragile ecological system as well as instable and erratic political climate. Lessons learned from Social Fund projects I and II and from the recently inherited Infrastructure, Water and Environment project demonstrate that the lack of proper environmental management and lack of inclusion of the social aspects have led to serious environmental and social impacts which are costly to rehabilitate if reversible at all. .It is therefore important to recognize that environmental and social inclusion at the design stages ofprojects is fundamental to the success ofthe social fund project. Discussions with different groups and during the workshops which were held on all three islands indicate that they are fully appreciative of this important injection into the process. 6.2 Potential Positive Impacts The overall positive environmental and social impacts predicted under the Social Fund project are based on several facts key among them are; 23 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) (i) the National Executing Agency and its partners have now recognized that inclusion of environumental and social management are fundamental to the success and sustainability of the sub-projects; (ii) this notion will help strengthen the traditional systems of environmental and social management; (iii) local institutional strengthening and empowernent can be achieved through improved understanding and use oftools and mechanisms for environmental (iv) management and social impact assessment and participatory community development The Social Fund III project has the potential to make a significant contribution to Comoros' policy to protect the natural resource base which the country's population depends on for their livelihood while also reducing poverty in rural Comoros. At this time, the overall environmental and social impacts are difficult to predict since they are demand driven. Nonetheless, considering the susceptibility of the country's ecological system and the potential needs of the rural population, it is likely to predictthe potential impacts however challenging they may be. Based on this assumption, the potential positive impacts of the project are likely to be: (a) Improved land tenure security in a country where formal land tenure system does not exist and the traditional and religious system is complex and difficult to apply; (b) Reduction of soil erosion and gully erosion particularly on steep hill sites; (c) Removal of threats and barriers to integrated ecosystem management and in particular to conservation and sustainable use ofbiological diversity in natural habitats such as marine and forest parks, tortoises, marine mammals, and other ecologically important species in Comoros; (d) Contribution to the decentralization process through community management of natural resources and integrated ecosystem management and decision making process; (e) Reduction in land degradation and coastal erosion mitigation benefits expected to arise from improvements in coastal zone management; (f) Building partnerships between and among rural communities and with intemational and public/private institutions dealing with natural resources management for shared resources conservation, knowledge sharing and management; (g) Provision of opportunities through training and capacity building to local communities for integrated enviromnental and social management. 6.3 Potential Negative Impacts The overall potential negative environmental and social impacts predicted under the social fund project are based on the following reasons: (a) Comorian life in general and rural life in particular is complex and this is also coupled with the fact that rural livelihoods vary from one island to the other and so does the level of complexity vis-a-vis the environment. 24 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) (b) It is recognized from this study that there is a significant lack of both human and institutional capacity at all levels ofthe system to be able to carryout environmental and social screening of the anticipated sub-projects. This may increase the existing environmental and social impacts within the areas of intervention; (c) Differential impacts of training and level of investment may result in some vulnerable groups relying to a greater extent than their wealthier counterparts on unsustainable use of natural resources; (d) Introduced land tenure systems and systems of govemance versus traditional /religious systems may create conflict, or contradictions may result in unsustainable agricultural and natural resources management practices and for a fragile ecosystem as Comoros that can have severe consequences on the environment and social fabric; (e) Rising population pressures, a deteriorating resource base, climate change and agricultural extensification can lead to an increase in land-related conflicts on all the three islands. The Environmental and Social Management Framework and the Resettlement Policy Framework commissioned by the Government of Comoros have taken these potential risks carefully into consideration both at the preparation and design of the third Social Fund project, especially considering the experience gained through the implementation of the first and second Social Fund projects. 6.4 Localized Negative Impacts Most of the sub-projects planned under the proposed social development fund will be small scale, therefore the significance of the direct negative social and environmental impacts are likely to be minimal. This is especially the case in comparison with the recently adopted Infrastructure, Water and Environment Project which concentrated on enlarging the national roads networks on the islands. Despite the potential small size of the sub-projects, they could have significant environmental impacts particularly due to the fragility of the ecosystems like the slopes of the hills of Anjouan and Moheli as well as those of Grande Comore. Experience in high land development has shown that unless highland sites are properly selected and any necessary infrastructure, improvements and protection measures are well designed and constructed, this can lead to serious impacts. The national roads network in Comoros is experiencing serious problems and the cost of rehabilitation by the Bank and other donors is a continuous problems. Also, developing the infrastructure can and has created additional population pressure on fragile ecosystems. Intensification of agriculture on all three islands can also result in decreasing existing biodiversity and loss of ecologically, economically and scientifically important species. 6.5 Cumulative Impacts of Sub-Projects Experience from the previous social fund projects in Comoros, i.e. Social Funds I and II, 25 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) have shown that minimal as the environmental and social impacts of some sub-projects may be, together they can create bigger problems on the natural resource base. Examples of such impacts which have been noticed on the islands are: * Forest clearing for extensive agricultural practices which due to the sloppy nature ofthe terrain leads to depletion ofthe soil fertility; * Deforestation due to the exploitation ofthe forest resources for distillation of ylang-ylang, construction and for fuel wood; * Impacts on ground water resources due to the construction of numerous wells; * Waste and dumping sites due to the inappropriate disposal of waste materials during and after construction. 6.6 Solid Waste Disposal Indiscriminate disposal of solid waste in general and contaminated waste in particular is of great concern to the project. Water courses in Comoros may be vulnerable to pollution due to increased solid waste, and disposal ofwaste water, in association with pharmaceuticals, animal drugs and medical waste, or construction ofinfrastructure without adequate sanitation facilities. A number of clinics will be constructed and without the requisite medical waste disposal methods human and animal health will be at risk. Water resource and land resource contamination is likely to happen. As Medical Waste Management Planning has not yet been introduced to the Government of Comoros as is the case with most client countries which are part of the HIV/AIDS Program, it is necessary to help prepare a small medical waste management checklist/plan to handle such aspects as: * Laboratory waste-specimen or microbiologic cultures, stocks or infectious agents, live and attenuated vaccines, ands culture mediums; * Blood or body fluids, liquid blood elements or other regulated body fluids, or articles contaminated with blood or body fluids; * Sharps items such as syringes, needles, blades, broken glass; * Contaminated animals - animals carcasses, body parts, bedding materials; Surgical specimens - human or animal parts or tissues removed surgically or by autopsy; * Isolation waste. 6.7 Pest Management and Chemical Use As Comoros' economy is predominantly dependent on agriculture and agricultural activities albeit small may result in intensification of crop production. Also certain livestock activities like tick dips and other agricultural practices may lead to the increased use of agricultural chemicals to promote growth. It is important that appropriate 26 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAI, (FADC III) planming, design and management be adopted for the proper and judicious handling of agricultural chemicals to avoid potential negative environmental and human health impacts. While the anticipated sub-projects are mostly social infrastructure, small agricultural activities may occur and as such, putting in place guidelines to assist in pest management planning is important. The introduction of local pest management plans is therefore encouraged during the implementation of the social fund project. Such a plan should cover areas such as: * proper use of agricultural chemicals; * prevention of chemical runoff into surface water sources to avoid negative impacts on the aquatic environment; * proper use and handling of chemicals to avoid contamination of crops, soils, and water bodies; * proper storage and handling to avoid adverse health impacts or rural farmers; * proper policing to ensure that banned chemicals are not distributed to fanning communities. 6.8 Inaccessibility and the Poor and Vulnerable Communities The amount of anticipated infrastructure development in the Comoros Social Fund III project is important in many aspects, principal among which is the urgent need to access the poor and vulnerable groups. This may however not necessarily be the case as these groups may not afford the required contributions to qualify for a sub-project. Such may contribute to the inequitable distribution of resources and further marginalization of these groups. The development oflocal development plans by FADC seeks to avoid this potential for marginalization but the consistent participation of these vulnerable groups can easily be limited by the mere fact that they are inaccessible and therefore automatically isolated. The third social fund project team recognized these facts and intends on introducing a method of inclusion of these vulnerable groups. The sliding scale as it is called is meant to accommodate such groups irrespective of whether or not they can afford to meet the financing requirements for sub-project approval. This method will be further development during project appraisal and implementation. The project team and the national executing agency FADC recognize that while it is critical for the communities to receive guidance and support from the skilled facilitators of the FADC in methods of comnmunity participation, project planning and management, it is equally important that the Regional FADC offices and their counterpart Comites de Pilotage continue to work with vulnerable communities to ensure that their concerns are taken into consideration. Failing to do so will defeat the development objective of the project and the World Bank's fundamental objective of poverty alleviation. 7.0 REPORTING and RESPONSIBILITIES for the ESMF/RPF This chapter of the report sets out reporting systems and responsibilities of the executing agency for implementation ofthe Enviromnental and Social Management Framework. The section begins with details of issues that will be addressed by the ESMF, specific next steps to be taken to ensure adherence to the recomnmendations of the ESMF including: 27 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) The institutional arrangements for reporting and advice; The Screening checklist for community micro-projects; The Awareness Building Program; The role of the Environment/Social Specialist and the TOR. 7.1 Key Principles and Proposed Actions The ESMF has been prepared on the basis of the following principles: In collaboration with the FADC National and members of the Comites de Pilotage, the consultant sought to avoid considering environmental sustainability of the Social Fund project in isolation. Instead we considered how sustainability can be ensured at the community level and how the Social Fund III's contribution can be maximized. The consultant recognized that it would be unproductive if the social fund project was to focus solely on the environmental implications of the Social Fund Financed sub-projects alone, without also creating partnerships with the island communities, with NGOs and most importantly to encourage collaboration between the various CP on the same islands as well as between islands. Secondly, in accordance with the fact that there are natural separations between the three islands, the consultant considered that the bulk of the environmental inputs to the social fund project are required at the community level. At the village community level, there is an opportunity to build on the close relationship of agriculture with environmental, social and health groups, and improve awareness ofthe complexity of sustainable agricultural livelihoods among all groups. Third, while the ESMF proposes an elaborate system of screening for sub-project activities, it also proposes that environmental and social considerations are fully mainstreamed into the participatory process for identification, planning, implementation and monitoring of sub-project activities. The screening forms and checklist are therefore intended to be integrated fully into the Project Implementation Manual of the FADC and the overall system of project management. 7.2 Mainstreaming Environmental Management into the FADC Program Environmental management and protection as earlier discussed is clearly one of the weakest links on the agenda of the government of the Republic of Comoros. The Environmental Policy and National Environmental Law are the basis for sectoral and cross-sectoral coordination among ministries and line agencies in addressing environmental concerns of the three island country. While this coordination exists on paper, it is very weak in reality. There is also a clear indication in the review of the institutional structure and on meeting with the Department of Environment that there are no officers or offices on the different islands. The department itself is weak in both human and institutional resources and this renders it poor in bringing the environmental agenda to the forefront of the national development process. 28 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) 8.0 BUILDING CAPACITY for ENVIRONMENTAL MANAGEMENT In discussions with the Executive Director ofthe FADC, the World Bank's environmental adviser and the Task Team Leader, it was agreed that the first step in building the human resources capacity for environmental management under the Social Fund III Project is to identify the key players involved in the coordination and implementation of the project. There are three levels of administration, namely National, Regional, and Community. The ESMF of the Social Fund project will be coordinated by the National FADC and the implementation ofthe project's screening process will be the responsibility of the Regions and the CP. Environmlental inputs will be mainstreamed at every level of the project thus the need to enhance the awareness of these key actors. To achieve these objectives, the project will hire an environmental/social specialist with clear Terms of Reference to advise and coordinate the implementation of the Environmental and Social Management Framework and the Resettlement Framework and also to work closely with the Department of Environment and other partners in carrying out the Awareness Building Program. At the Regional level, the FADC regional offices will continue to work with the specialist and communities to ensure that these aspects become part and parcel ofthe sub-project identification process as well as the planning and implementation ofthese sub-projects. Table 7.0 Identifying Focal Points for Capacity Building Focal Point FADC Coordination Recommendation Appoint an environmental specialist to manage the ESMF Administrative Representative Position at FADC * Action: To supervise the implementation ofthe ESMF and to monitor the reporting of the project output in relation to the ESMF; * To liaise with the relevant Government agencies at the National, Regional and Community levels and particularly with the Department of Environment, fisheries, forestry and water resources and other environmental bodies in the country; * To Implement the Awareness Building Program as proposed in the PAD through information dissemination, organizing training on the different islands, workshops, and identifying institutional needs for environmental management. The cost ofhiring the specialist is to be priced as a local consultant under a fixed term contract and the cost of the program is as indicated in the PAD. 29 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) 7.1 Regional Level At the Regional level the specialist should identify a focal point at each Committee de Pilotage to support the community in implementing the Screening Process and approving sub-projects. The focal point can either be an existing staff member from a regional FADC or Government bureau with background in the environment, i.e. soils, water, and biodiversity conservation, or, if one is not available, then an individual with such expertise can be identified and given short term assignments to assist the specialist as and when required. The role ofthe Regional Focal Point will be to: * assist FADC-SER in implementing the sub-projects' environmental and social screening process; * To provide technical guidance and advice in environmental and social issues as it relates to sub-project location and design; * To liaise with communities, government offices on the islands, and with NGOs. 7.2 Community Level At the Community level it should be ensured that in each CP/CGL, there is a focal point to support communities in screening and approving sub-projects. The FP works closely with the FADC environmental specialist and with the Regional Focal Point to assist their CP/CGL in using the screening forms to assess the potential impacts of proposed projects and to liaise with Regional FADC Officers and Regional Focal Point for guidance and technical assistance on environmental and social matters. 7.3 The Awareness Building Program for Environmental Management In recognizing the apparent weakness and poor understanding of environmental issues and their relations to development in Comoros, the Awareness Building Program proposed in this report will attempt to address the following on the three islands: * Sensitization among the Regional staff ofthe FADC and members of the CP as they relate to agricultural and other economic activities and their coping strategies towards environmental degradation in Comoros; * Appreciation of the unpredictable, complex and dynamic nature of their livelihoods as they relate to the complex and fragile ecological systems as well as the weakness of the environmental agenda in the country; * To help minimize the potential damage of the anticipated activities of the proposed social fund project, sensitization of the key stakeholders will be required in advance of the commencement of the project activities on the ground; * Awareness building among the key players and Community leaders on how to integrate local traditional knowledge with modem environmental management practices particularly in relation to the sub-projects; * Training of the FADC staff and community leaders on the use of the screening process and reporting mechanisms for sub-project approval as set out in the screening forms. This type of training should be mainstreamed into the training that will be required for the smooth operation of the sub-project approval process. 30 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) As is already proposed, the hired environmental specialist will draw up a training plan that will include the training of Regional FADC officers and Community leaders. They in turn will be training members of their committees. * Collaboration between members of the different CP, from the different islands (sharing experience among regions) particularly those involved in sub-project identification, natural resources management, and the screening process. This portion of the program will involve training in the use of environmental and social guidelines in identifying and costing mitigation measures as well as advising on social safeguard issues. As there is a great of traditional knowledge that has been applied over the years through trial and error, a key focus of the training and sensitizationprogram should be on integrating this knowledge in enviromnental management system of the proposed project. 7.4 Integrating Tradition Knowledge in the Environmental Management Framework Traditional knowledge as it relates to Environmental Management will be taken into consideration in the development of the Awareness Building Program ofthe proposed Social Fund project as follows: (a) As the traditional land tenure system in Comoros is very complex, its understanding and appreciation is fundamental to the location ofthe anticipated sub-projects, particularly as they relate to land acquisition, land take, and loss of economic activities. Its importance in relation to the World Bank's safeguard policy on Involuntary Resettlement cannot be overemphasized. (b) Traditional land rehabilitation for agricultural development in an ecosystem that is fragile and complex is key to the sustainability ofthis sector as well as the concomitant infrastructure development that goes with it. The Comorians have over the years applied different conservation and rehabilitation methods albeit insufficient and have to entertain new and more effective methods if their systems are to be sustainable. (c) Dependence on the forest cover for the distillation of ylang-ylang and the use of wood for energy and building material need to be carefully looked into and alternative methods introduced; (d) As water is a major limiting factor in both domestic and agricultural practices, the assessment of water resources and proper harnessing of these resources is critical to the development ofthe country. 8.0 THE ENVIRONMENTAL MANAGEMENT AND SCREENING SYSTEM The screening process as introduced in Annex 1 of this report is a compilation of the methods that will be applied in screening and evaluating sub-projects for environmental and social impacts. The main ingredients of the process are outlined below: 31 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) (a) A basic enviromnental and social screening form for the members of the Cp to complete when applying for sub-project financing. (b) Basic environmental and social review form if there is the need for more detailed environmental and social appraisal of the project is required. (c) Content of such forms should be clearly spelled out in FADC's Project Implementation Manual for community evaluation ofprojects following completion. (d) Format for lesson learning review of EIA by stakeholders in particular members of the CP and other interested parties. 8.1 COSTS The cost of implementing the Awareness Building Program as spelled out in the Project Appraisal Document (PAD) is properly incorporated in the project design. * The cost of the environmental training and sensitization program has been agreed with the Borrower and the project team and will be addressed under the project budget allocated for the entire Capacity Building component. * Cost associated with the recruitment of an environmental /social specialist will also be covered under the budget allocated for awareness building and training. * Costs related to the mitigating of impacts associated with sub-projects financed under the Social Fund are also allocated under the same budget, while the cost of mitigating the impacts of the adopted roads, water and environment component will be assessed and internalized as part of the overall project budget. This will be discussed with the Borrower and the project TTL during Project Appraisal. Other additional costs to the project are potential relocation and compensation plans should any proposed sub-project lead to land take, loss of economic activities and/or relocation. When this happens, the Bank's team together with the Borrower (FADC) will determine the resources and budget needed to finance these plans. Proposed Training Program Duration Environmental and Social assessment process 5days * Screening process * Assignment of environmental categories * Rationale for using Screening form and Environmental and Social Checklists * Preparation of terms of reference for carrying out ESIA * How to review and approve sub-project proposals * The importance of public consultations in the EA process * How to monitor project implementation * Case studies 32 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) Environmental and Social policies and procedures 3 days * Review and discussion of Comoros' environmental policies, procedures, and legislation * Review and discussion of the Bank's safeguards policies * Review of ESIA, Resettlement Plan * Collaboration with institutions at the local, regional and union levels Selected topics on environmental protection 2 days * Soil erosion * Flood protection * Waste disposal, including medical/veterinary waste, hazardous chemical wastes such as pesticides, insecticides, herbicides, etc. * Ground and Surface Water Management * Deforestation 8.2 Implementing the ESMF The project is planned to be appraised in November 2003 and it is recommended that the following steps be taken to implement the Framework: Immediately after project effectiveness, the Awareness Building Program will commence at all three levels, i.e. National, Regional and Local levels. This will be carried out once the specialist is recruited and is in place. The program will take place in the form of workshops and seminars in environmental assessment, the use of the screening process and training on filling the screening and review forms as well as the reporting forms. By the second year of project implementation, the FADC and its partners would have learnt from the first year projects to allow them to refine the screening process and enviromnental and social review forms to better fit the types of sub-projects being implemented. The environmental and social specialist would also be able to use this experience to develop guidelines for the various types of sub-projects since by the second year ofproject implementation a clear idea of the type of sub-projects being demanded by the communities will emerge. It is also envisaged that by the second year of implementation and based on the lessons learnt, the team should be able to establish a monitoring and evaluation mechanism suitable for regular and efficient reporting. 9.0 ENVIRONMENTAL AND SOCIAL PLANNING, REVIEW AND CLEARING PROCESS FOR SUB-PROJECTS 33 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) As stated earlier, at the time the Social Fund III project was being prepared, the sub- projects were not identified. Consequently, specific information on numbers of sub- projects, site location of sub-projects, land requirements, localcommunities, geo-physical land features, nature, type and use of equipment/plant, etc. was not available. Therefore, exact details and intensity of social and environmental impacts and their effective mitigation cannot be determined during project preparation. This document referred to as the Environmental and Social Management Framework (ESMF) is thus prepared to establish the mechanism to determine and assess future potential adverse environmental and social impacts of sub-projects that are to be identified and cleared based on a community demand driven process described here below, and then to set out mitigation, monitoring and institutional measures to be taken during implementation and operation of the sub-projects to eliminate adverse environmental and social impacts, offset them , or reduce them to acceptable levels. This section therefore, identifies and illustrates the specific steps involved in the environmental and social assessment process leading towards the clearance and approval of the EA process for sub-projects. The steps incorporate both, relevant Comoros guidelines/requirements and the Bank's policy OP 4.01 Environmental Assessment, and on Involuntary Resettlement (the safeguard policies that apply for this project as discussed earlier) and are; (a). The Comite de Pilotage will screen their own sub-projects to identify environmental and social impacts using the screening form in Annex 1. In a few cases the checklist may require that a sub-project conducts a sub- project environmental and social impact assessment (ESIA) for certain types of impacts. (b). Then the implementers will introduce into the sub-project design the required measures to mitigate impacts identified from use of the checklist before submission of the sub-project for review and subsequent approval. (c). Review and clear the sub-projects by ensuring sub-project designs have identified environmental and social impacts, mitigated these impacts and have monitoring plans and institutional measures to be taken during implementation and operation. Using the screening form, revised enviromnental and social checklists and technical assistance from service providers and information resources supported by FADC, proposed sub-projects will be screened by their respective implementers, to identify any potential adverse impacts/effects from sub-project activities. Once impacts are identified the necessary mitigation measure would then be identified from the checklist and then the sub-project would be designed to implement these mitigation measures. For example, from a social standpoint if the screening form identifies land acquisition needs that trigger OP 4.12 on Involuntary Resettlement, then the required mitigation measure would be to chose an alternative land site that does not 34 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) trigger this policy or, the implementer of the sub-project prepares a resettlement and compensation plan consistent with the disclosed RPF. From an environmental stand point, the screening form and checklist may identify impacts from sub-project activities, such as contamination of ground water sources due to inappropriate waste disposal. The mitigation measure may be to choose a site far away from the water source so that chances of contamination are not possible and/or incorporate appropriate waste disposal measures into the design such as channeling all waste to a closed system that is periodically emptied and disposed of safely. For some cases (a minority of cases) where the impacts from sub-project activities are determined by use of the checklist to be severe or difficult to mitigate, the recommendation may be that a sub-project ESIA be carried out following which the sub- project would then be designed to incorporate the required mitigation measures. ESIA will be required for sub-projects involving new roads, incorporating the use of hazardous chemicals and/or managing solid, liquid or medical wastes and for any sub- project costing overUS$100,000. See Annex 2 forprocedures for sub-projects requiring ESIA. Once the implementers have completed the screening of their sub-projects and designed into them the necessary mitigation measures, sub-project proposals would then be sent to the FADC-SER for review and to check for compliance with this EA process. The completed screening forms and completed checklists must accompany the sub- projects that are sent for review. If the screening form has any "Yes" entries, or evidently unjustified "No" entries, the application would need to adequately explain and demonstrate from its design that the issue has been managed to avoid unacceptable adverse effects/impacts. If the application has satisfactorily addressed these issues it will be recommended for approval to the respective approving body. For approved sub- projects, the FADC-SER as reviewer will determine enviromnental and social approval conditions the implementer must adhere to in the detailed planning, construction and operation of the investment. These conditions may include, for example, such measures as public involvement, siting or routing restrictions, construction and operation practices, restoration of disturbed areas, the complete implementation of a plan for resettlement or compensation for land acquisition and, construction supervision to ensure the approval conditions are being followed. If, however the sub-project application unsatisfactorily addresses these issues it may be rejected out right or rejected with the requirement to carry out a sub-project ESIA in cases where one was not done before or with specific recommendations such as to change site, or re-design waste management, reduce air pollution, etc. The rejected sub-project will then have to be re-designed and re-screened by the implementer and then re-submitted for review. The revised application will then have to be reviewed again and, if now acceptable, will be recommended for consideration for 35 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) approval. If it is not acceptable for the second time, it would be referred back to the implementer for more work or denied clearance altogether. Any proposed sub-projects that do not comply with the requirements of the Environment Law 1997 of Comoros and the requirements of the World Bank Safeguards policies will not be cleared for approval. This process is designed to ensure that the environmental and social assessment process is part of and conducted during the sub-project design process thereby ensuring that sub- project activities are environmentally and socially sound and sustainable. Environmental Management Plan (EMP): sub-project proposals must contain as part of the sub-project proposal an EMP that will consist of a set of mitigation measures, monitoring and institutional measures to be taken during the implementation and operation of the sub-projects to eliminate adverse environmental and social impacts, offset them or reduce them to acceptable levels. The EMP should also include the actions needed to implement these measures, including the following features: Mitigation: Based on the environmental and social impacts identified from use of the checklists, the EMP should describe with technical details each mitigation measure, together with designs, equipment descriptions and operating procedures as appropriate. Monitoring: Environmental and social monitoring during the implementation of the sub-projects, in order to measure the success of the mitigation measures. The EMP should include monitoring objectives that specify the type of monitoring activities that will be linked to the mitigation measures. Specifically, the monitoring section of the EMP provides: * A specific description and technical details of monitoring measures that include the parameters to be measured, the methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions, e.g. the need for on site construction supervision. * Monitoring and reporting procedures to ensure early detection of conditions that necessitate particular mitigation measures and to furmish information on the progress and results of mitigation, e.g. by annual audits and surveys to monitor overall effectiveness of the ESMF. The EMP should also provide a specific description of institutional arrangements, i.e. who is responsible for carrying out the mitigating and monitoring measures (for operation, supervision, enforcement, monitoring of implementation, remedial action, financing, reporting and staff training.) Additionally, the EMP should include an estimate of the costs of the measures and activities recommended so that the FADC can budget the necessary funds. The mitigation 36 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) and monitoring measures recommended in the EMP should be developed in consultation with all affected groups to include their concerns and views in the design of the EMP. Public Consultations: Public consultations are critical in preparing an effective and sustainable sub-project. The first step is to hold public consultations with the local communities and all other interested /affected parties. These consultations should identify key issues and determine how the concerns of all parties will be addressed in the terms of reference of the design of sub-project activities. To facilitate meaningful consultations, the local governments through their implementers will provide all relevant material and information concerning the sub-projects in a timely manner prior to the consultation, in a form and language that are understandable and accessible to the groups being consulted. Depending on the public interest in the potential impacts of the sub-projects, a public hearing may be requested to better convey concerns. Once the sub-project has been reviewed and cleared by FADC-SER, the implementers will inform the public about the results of the review. This approach would be consistent with the Bank's OP 4.01 Environmental Assessment as well as Comoros' efforts to enhance its participatory planning process. 37 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) Annex 1 ENVIRONMENTAL AND SOCIAL SCREENING FORM The Environmental and Social Screening Form (ESSF) has been designed to assist in the evaluation of sub-components of the Social Fund III in Comoros. The form is designed to place information in the hands of implementers and reviewers (FADC and CPs) so that impacts and their mitigation measures, if any, can be identified and/or that requirements for further environmental analysis are determined. The ESSF contains information that will allow reviewers to determine the characterization of the prevailing local biophysical and social environment with the aim to assess the potential sub-project impacts on it. The ESSF will also identify potential socio-economic impacts that will require mitigation measures and or resettlement and compensation. Name of Sub-project: Development Sector of Sub-project: Name of Sub-project Execution Organization: Name ofDistrict where is to be implemented: Name of Local Government: Name of Approving Authority: Name, job title, and contact details for the person who is responsible for filling out this form. Name: Job Title: Telephone number: Fax number: E-Mail address: Date: Signature: 38 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) 1. Brief Sub-project Description Please provide information on the type and scale of the sub-project (project area, area of required land, approximate size of total building floor areas, etc.) 2. The Natural Environment (a) Describe the land formation, topography, and vegetation in/adjacent to the Sub- project area (b) Estimate and indicate where vegetation might need to be cleared (c) Are there any environmentally sensitive areas or threatened species (specify below) that could be adversely affected by the project? (i) Intact natural forests Yes No_ (ii) Riverine forest Yes No_ (iii) Wetlands (lakes, rivers, seasonally inundated areas) Yes No_ (iv) How far are the nearest Wetlands (lakes, rivers, seasonally inundated areas)? km (v) Habitats of endangered species for which protection is required under Comorian laws and/or international agreements. Yes No_ (vi) Others (describe). Yes No_ 39 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) 3. Rivers and Lakes Ecology Is there a possibility that, due to construction and operation of the sub-project, the river and lake ecology will be adversely affected? Attention should be paid to water quality and quantity, the nature, productivity and use of aquatic habitats, and variations ofthese over time. Yes No_ 4. Protected areas Does the project area (or components of the project) occur within/adjacent to any protected areas designated by government (national park, national reserve, world heritage site etc.)? Yes No_ If the project is outside of, but close to, any protected area, is it likely to adversely affect the ecology within the protected area (e.g., interference with the migration routes of mammals or birds) Yes No_ 5. Geology and Soils Based upon visual inspection or available literature, are there areas of possible geologic or soil instability (erosion prone, landslide prone, subsidence-prone)? Yes No_ Based upon visual inspection or available literature, are there areas that have risks of large scale increase in soil salinity? Yes No_ 6. Landscape/aesthetics Is there a possibility that the sub-project will adversely affect the aesthetic attractiveness of the local landscape? 40 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Yes No_ 7. Historical, archaeological or cultural heritage site. Based on available sources, consultation with local authorities, local knowledge and/or observations, could the sub-project alter any historical, archaeological or cultural heritage site or require excavation near same? Yes No_ 8. Resettlement and/or Land Acquisition Will involuntary resettlement, land acquisition, or loss, denial or restriction of access to land and other economic resources be caused by sub-project implementation? Yes No_ 9. Loss of Crops, Fruit Trees and Household Infrastructure Will the project result in the permanent or temporary loss of crops, fruit trees and household infra-structure (such as granaries, outside toilets and kitchens, etc)? Yes No_ 10. Noise pollution during Construction and Operations Will the operating noise level exceed the allowable noise limits? Yes No_ 11. Solid or Liquid Wastes, including Medical Waste Will the sub-project generate solid or liquid wastes, including medical waste? Yes No_ If "Yes", does the project include a plan for their adequate collection and disposal? Yes No_ 12. Pesticides, Insecticides, Herbicides or any other Poisonous or Hazardous Chemicals. 41 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Will the sub-project require the use of such chemicals? Yes No_ If, "Yes", does the sub-project include a plan for their safe handling, use and disposal? Yes_ No_ 42 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Annex 2 Procedures for Sub-project Investments Requiring EA Step 1: Screeninzg To determine the depth of EA required, potential impacts in the following areas need to be considered: * Social issues * Health issues * Protected areas * Cultural heritage, archaeological sites * Existing natural resources such as forests, soils, wetlands, water resources * Wildlife or endangered species' habitats Step 2: Scoping To identify the relevant environmental and social issues, this step determines: * Level of detail required for the EA * Extent of the area to be covered in light of the potential impact zones * Timeframe for the EA based on the potential impact zones * Sequencing and scheduling of the various EA tasks * Preliminary budgets Step 3: Preparation of Terms ofReference for sub-project EAs Based on the screening and scooping results, EA terms of reference will be prepared. A local service provider will conduct the EA, and the report should have the following format: * Description of the study area * Description of the sub-project * Description of the environment * Legislative and regulatory considerations * Determination of the potential impacts ofthe proposed sub-projects * Public consultations process * Development ofmitigation measures and a monitoring plan, including cost estimates Annex 2: Typical Checklist to Identify Impacts and Mitigation Measures of Construction Sites under the Proposed FADC III 43 Environmentaland Social Components Impacts MitigationMeasures Physical Environment Soils - Erosion of lands down slope from borrow areas. Construction in dry season; protection of soil surfaces * Landslides and slips during construction; re-vegetation or physical *Contamination from waste materials, e.g. cement and paints, stabilization of erodable surfaces. Land restoration engine oils, etc. measures *Excavating borrow pits for aggregate materials (sand and stone) for Adequate protection from livestock entry by fencing the concrete site perimeters *Cutting of stone for use on fagades Control and daily cleaning at construction sites Provision ofadequate waste disposal services Proper disposal of chemicals and other hazardous materials Dust control by water, appropriate design and siting, restrict construction to certain times Appropriate and suitable storage ofbuilding materials on site Water Resources * Creation of stagnant water pools Special attention to drainage; prevention of erosion; *Increased sediments into streams consideration of alternative alignments; retention ponds; *Clogging of drainage works proper disposal of oil and other hazardous materials *Decline in water quality * Increase in runoff and flooding conditions Siting ofLatrines at safe distances from wells and using *Introduction of hazardous wastes closed systems for sewage drainage * Contamination ofwells Air Quality *Dust during construction Dust control by water or other means Acoustic Environment *Noise disturbance Restrict construction to certain hours Bio-physical Environment Natural Habitats *Disturbance ofnatural habitats Consideration of alternative alignments or sites *Disturbance to protected areas REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Fauna and Flora - Disruption or destruction of wildlife Minimize loss of natural vegetation during construction; * Threats to rare and endangered species alternative sites; various special measures for sensitive species Social Environment Aesthetics and Landscape * Marred landscapes Restoration of vegetation; cleanup of construction sites * Debris Historical/Cultural Sites - Degradation of sites Alternative alignments and/or sites * Disturbance to structures Special measures to protect cultural heritage sites Human Health * Transport ofhazardous substances Regulation oftransport of materials *Traffic accidents Safety designs (signage) *Pedestrian accidents Ensure availability of clean potable water for use in latrines, canteens and for drinking Use of appropriate building materials. No asbestos etc. Human Commnunities *Involuntary resettlement Prepare Resettlement and Compensation Plans * Loss of crops, buildings, property,or economic livelihood consistent with disclosed RPF as per OP 4.12 Environmentaland Social Components Impacts MitigationMeasures Physical Environment Soils * Erosion of lands down slope from borrow areas. Construction in dry season; protection of soil surfaces * Landslides and slips during construction; re-vegetation or physical *Contamination from waste materials, e.g. cement and paints, stabilization of erodable surfaces. Land restoration engine oils, etc. measures *Excavating borrow pits for aggregate materials (sand and stone) for Adequate protection from livestock entry by fencing the concrete site perimeters *Cutting of stone for use on fagades Control and daily cleaning at construction sites Provision of adequate waste disposal services Proper disposal of chemicals and other hazardous materials Dust control by water, appropriate design and siting, restrict construction to certain times Appropriate and suitable storage of building materials on site REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Water Resources - Creation of stagnant water pools Special attention to drainage; prevention of erosion; * Increased sediments into streams consideration of alternative alignments; retention ponds; * Clogging of drainage works proper disposal of oil and other hazardous materials *Decline in water quality * Increase in runoff and flooding conditions Siting ofLatrines at safe distances from wells and using * Introduction of hazardous wastes closed systems for sewage drainage * Contamination of wells Air Quality * Dust during construction Dust control by water or other means Acoustic Environment *Noise disturbance Restrict construction to certain hours Bio-physical Environment Natural Habitats *Disturbance of natural habitats Consideration of alternative alignments or sites * Disturbance to protected areas Fauna and Flora * Disruption or destruction ofwildlife Minimize loss of natural vegetation during construction; * Threats to rare and endangered species alternative sites; various special measures for sensitive species Social Environment Aesthetics and Landscape *Marred landscapes Restoration of vegetation; cleanup of construction sites *Debris Historical/Cultural Sites *Degradation of sites Alternative alignments and/or sites * Disturbance to structures Special measures to protect cultural heritage sites Human Health * Transport of hazardous substances Regulation oftransport of materials * Traffic accidents Safety designs (signage) * Pedestrian accidents Ensure availability of clean potable water for use in latrines, canteens and for drinking Use of appropriate building materials. No asbestos etc. Human Communities *Involuntary resettlement Prepare Resettlement and Compensation Plans * Loss of crops, buildings, property, or economic livelihood consistent with disclosed RPF as per OP 4.12 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC 111) Annexe 4 Liste des documents consultes 1. Les Termes de Reference 2. Project Concept Document (PCD) 3. The evolving Draft Project Appraisal Document (PAD) 4. The approved Integrated Safeguards Data Sheet (ISDS) 5. Aide Memoires de la Mission 6. L'Etude d'Impact sur L'Environnement Par la Societe Scetauroute, Decembre 1999 7. Le Manuel de Procedures pour FADC 8. Rapport National sur les Objectifs du Millenaire pour le Developpement 9. Loi-cadre N° 94-018 du 19 juin 1995 relative a l'environnement 10. Decret N°0 1-053/CE dul9 avril 2001 relatif au Parc Marin de Moheli 11. Decret N°01-052/CE dul9 avril 2001 relatif aux Etudes d'Impact sur l'Environnement 12. Rapport de Pre-evaluation du Programme National de Developpement Humain Durable 13. Politique Nationalede l'Environnement de la Republique Federale Islamique des Comores 14. Les Politiques de Sauvegarde de la Banque Mondiale 2 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTALet SOCIAL (FADC 111) Annex 5 Villages Visited during Field Mission Grand Comore * Moroni * Hahaya * Mitsamiouli * Vouvouni * Itsandra S Anjouan * Ouani * Mutsamudu * Moya * Domoni * M'Remani Moheli * Fomboni * Wanani * Miringoni * Salamani * Hoani 3 REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTION ENVIRONNEMENTAL et SOCIAL (FADC III) Annex 6 Country and Island Maps KENYA TANZANIA S, v_-_> CAMOZA BIOUE MADAGASCAR M , tWGRAN DE ZIM#5uFl 3> ;CO 1\10OR > E U ISwRZaAC; Grande Comore \ (Njazidja) ANJOUAN H...' An,at,an -.ssAjo! MOHELI (Mw^aI') Comoros ,o * N.it,o001 CopiloI l 5^S <<. 2 ..... Ma, MONt.i.LAP,, 101231.oounit 0..0.I o . ^ , ,. i zNlis~~~~~~M yotte 000.010727lo00221-211001' et SOCIAL REPUBLIQUE FEDERALE ISLAMIQUE DES COMORES CADRE de GESTIONENVIRONNEMENTAL (FADC III) tsamio li Mbeni soudjin Ngazidja IN' oudiin 4 oroni Icani Naa 23GIfi t Foumbouni Dembini) Hoani Miringoni Fomabon Nioumrachoua '17 Wanani Mwali NZVVAN Cuani Mutsamudu Sima 3575mTL Domoni l0yara Rmani -NRlamani