P171933 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) FOR PROPOSED CIVIL WORKS IN AND AROUND MOLE NATIONAL PARK Submitted by Environmental Protection Agency (EPA)- PCU January 2025 ESIA-MNP, GLRSSMP-EPA PCU, 2025 i LIST OF ABREVIATIONS BA Beneficiary Agency CDP Community Development Programme EA Environmental Assessment EMS Environmental Management Systems EPA Environmental Protection Agency ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework GBV Gender-Based Violence GLRSSMP Ghana Landscape Restoration and Small-Scale Mining Project GoG Government of Ghana HSE Health, Safety and Environment I&APs Interested and Affected Parties IA Implementing Agency MMDAs Municipal, Metropolitan and Districts Assemblies MNP Mole National Park NGOs Non-Governmental Organisations NOx Oxides of Nitrogen PAD Project Appraisal Document PAPs Project Affected Persons PCDP Public Consultation and Disclosure Plan PDO Project Development Objectives PIM Project Implementation Manual PM Particulate Matter RAP Resettlement Action Plan RFP Request for Proposal SEA Sexual Exploitation and Abuse SH Sexual Harassment SOx Oxides of Sulphur WB World Bank WD Wildlife Division ESIA-MNP, GLRSSMP-EPA PCU, 2025 ii TABLE OF CONTENTS LIST OF ABREVIATIONS ....................................................................................................................................... II LIST OF FIGURES ................................................................................................................................................. VII LIST OF TABLES ................................................................................................................................................... VII EXECUTIVE SUMMARY ................................................................................................................................... VIII 1.0 INTRODUCTION .................................................................................................................................... 1 1.1 BACKGROUND ................................................................................................................................................. 1 1.2 JUSTIFICATION FOR THE SUB-PROJECTS ....................................................................................................... 2 1.3 AIMS OF THE ESIA STUDY ............................................................................................................................. 2 1.4 STUDY METHODOLOGY.................................................................................................................................. 3 1.4.1 Field Visits .............................................................................................................................................3 1.4.2 Desktop Study and Documents/Literature Review .................................................................................4 1.4.3 Data Analysis and Reporting .................................................................................................................5 2.0 POLICY, LEGAL, REGULATORY AND INSTITUTIONAL FRAMEWORK ............................... 6 2.1 RELEVANT POLICIES AND PLANS ................................................................................................................... 6 2.2 ENVIRONMENTAL PROTECTION AGENCY ACT, 1994 (ACT 490) .................................................................. 9 2.3 LEGISLATIVE AND REGULATORY FRAMEWORK ......................................................................................... 10 2.4 NATIONAL ENVIRONMENTAL STANDARDS .................................................................................................. 16 2.5 INSTITUTIONAL FRAMEWORK ..................................................................................................................... 17 2.5.1 Ministry of Environment, Science, Technology and Innovation ...................................................... 17 2.5.2 Environmental Protection Agency ..................................................................................................... 18 2.5.3 Wildlife Division of Forestry Commission ......................................................................................... 18 2.6 RELEVANT WORLD BANK ENVIRONMENTAL AND SOCIAL STANDARDS .................................................... 18 2.7 WORLD BANK ENVIRONMENT, HEALTH AND SECURITY GUIDELINES (EHSGS). ..................................... 33 INTERNATIONAL CONVENTIONS AND REQUIREMENTS......................................................................................... 33 3.0 PROJECT DESCRIPTION AND ALTERNATIVES ......................................................................... 37 3.1 PROPOSED CIVIL WORKS............................................................................................................................. 37 3.2 DESCRIPTION OF PROPOSED WORKS LOCATIONS ...................................................................................... 37 3.3 DESCRIPTION OF PROJECT CIVIL WORKS ................................................................................................... 40 3.3.1 Water Systems ...................................................................................................................................... 40 3.3.2 Game Viewing Platforms ..................................................................................................................... 40 3.3.3 Campsites ............................................................................................................................................. 41 3.3.4 Completion of Existing Lovi Research Centre at Mole ........................................................................ 41 3.4 LABOUR REQUIREMENTS ............................................................................................................................. 42 3.5 ALTERNATIVES CONSIDERED....................................................................................................................... 43 3.5.1 Identified Alternatives .......................................................................................................................... 43 4.0 ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION ................................................ 46 4.1 INTRODUCTION ............................................................................................................................................. 46 ESIA-MNP, GLRSSMP-EPA PCU, 2025 iii 4.2 CLIMATE ....................................................................................................................................................... 46 4.3 GEOLOGY AND SOILS ................................................................................................................................... 47 4.4 VEGETATION AND ANIMAL SPECIES ............................................................................................................ 49 4.4.1 Main Vegetation Types ........................................................................................................................ 50 4.4.2 Fauna ................................................................................................................................................... 53 4.4.3 Birds..................................................................................................................................................... 54 4.4.4 Reptiles ................................................................................................................................................ 54 4.4.5 Butterflies ............................................................................................................................................. 54 4.5 AIR QUALITY ................................................................................................................................................ 55 4.6 AMBIENT NOISE............................................................................................................................................ 56 4.7 WATER BODIES............................................................................................................................................. 57 4.8 FRINGE COMMUNITIES................................................................................................................................. 57 4.9 ARCHAEOLOGY............................................................................................................................................. 59 4.10 SAFARI FACILITIES AND ACTIVITIES ........................................................................................................... 60 4.11 LOCAL ECONOMY OF MNP FRINGE COMMUNITIES ................................................................................... 63 5.0 CITIZEN/STAKEHOLDER ENGAGEMENT ................................................................................... 67 5.1 INTRODUCTION ............................................................................................................................................. 67 5.2 STAKEHOLDER CONSULTATION APPROACH ............................................................................................... 68 5.3 IDENTIFIED STAKEHOLDERS ........................................................................................................................ 68 5.3.1 Community leaders ............................................................................................................................. 68 5.3.2 Consultations with Municipal and District Assemblies ....................................................................... 69 6.0 IMPACT IDENTIFICATION AND PREDICTION ........................................................................... 72 6.1 IMPACT ASSESSMENT APPROACH ................................................................................................................ 72 6.2 COMMUNITY INFLUENCE AND VULNERABLE GROUPS ................................................................................. 73 6.3 IMPACT ASSESSMENT APPROACH ................................................................................................................ 73 6.4 CRITERIA FOR IMPACT EVALUATION .......................................................................................................... 73 6.5 MAGNITUDE OF THE IMPACT ....................................................................................................................... 75 6.6 POSITIVE IMPACTS ....................................................................................................................................... 76 6.6.1 Employment Generation ...................................................................................................................... 76 6.7 POTENTIAL NEGATIVE ENVIRONMENTAL AND SOCIAL IMPACTS .............................................................. 76 6.7.1 Construction Phase Impacts ................................................................................................................ 77 6.7.2 Operational Phase Impacts ................................................................................................................. 81 7.0 IMPACT MITIGATION AND ENHANCEMENT MEASURES ...................................................... 83 7.1 TYPE OF MITIGATION MEASURES ............................................................................................................... 83 7.1.1 Preventive Measures ............................................................................................................................ 83 7.1.2 Control Measures ................................................................................................................................ 84 7.1.3 Compensatory Measures ...................................................................................................................... 84 7.2 MITIGATION MEASURES FOR SIGNIFICANT POTENTIAL NEGATIVE IMPACTS........................................... 84 7.3 MITIGATION OF CONSTRUCTION PHASE IMPACTS ..................................................................................... 85 ESIA-MNP, GLRSSMP-EPA PCU, 2025 iv 7.3.1 Habitat and Biodiversity protection measures ..................................................................................... 85 7.3.2 Air quality control measures ................................................................................................................ 85 7.3.3 Noise reduction and vibration control measures ................................................................................. 85 7.3.4 Water contamination prevention measures.......................................................................................... 85 7.3.5 Visual Intrusion management measures .............................................................................................. 86 7.3.6 Erosion and Siltation control ............................................................................................................... 86 7.3.7 Fire hazard control and safety ............................................................................................................. 86 7.3.8 Conflict prevention and management measures .................................................................................. 86 7.3.9 Construction waste management Waste Management ......................................................................... 86 7.3.10 Occupational health and safety measures ........................................................................................... 87 7.3.11 HIV/AIDS prevention and management ............................................................................................... 87 7.3.12 Gender Based Violence Child Abuse and Child Labour prevention measures .................................... 87 7.3.13 Child Protection and Child Labour ..................................................................................................... 88 7.3.14 Mitigation measures for Potential Oil contamination of Soil .............................................................. 89 7.4 MITIGATION OF OPERATIONAL PHASE MEASURE ...................................................................................... 89 7.4.1 Water Quality Deterioration prevention and control measures .......................................................... 89 7.4.2 Potential Drowning Hazard/ Fall prevention measures ...................................................................... 89 7.4.3 Conflicts prevention and management measures ................................................................................. 90 7.4.4 Fire prevention and control measures ................................................................................................. 90 7.4.5 Potential Flooding and Diseases prevention and management measures ........................................... 90 7.4.6 Cultural Heritage ................................................................................................................................. 91 8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ......................................................... 92 8.1 OBJECTIVES OF THE ESMP ......................................................................................................................... 92 8.2 ENVIRONMENTAL AND SOCIAL RISK MANAGEMENT TEAM....................................................................... 92 8.3 ENVIRONMENTAL AND SOCIAL MANAGEMENT STRUCTURE ...................................................................... 93 8.3.1 Project Coordinating Unit (PCU) ....................................................................................................... 93 8.4 GENERAL HEALTH AND SAFETY PROCEDURES ........................................................................................... 93 8.4.1 Fire Prevention and Safety System ...................................................................................................... 94 8.4.2 Change Management ........................................................................................................................... 94 8.4.3 Documenting Voluntary Donation of Community Lands ................................................................. 95 8.5 COST OF ENVIRONMENTAL MANAGEMENT ................................................................................................ 95 8.6 ENVIRONMENTAL MANAGEMENT DURING CONSTRUCTION PHASE ........................................................... 96 8.6.1 Responsibilities of the Project Engineer .............................................................................................. 96 8.7 ENVIRONMENTAL AND SOCIAL MANAGEMENT RESPONSIBILITIES ........................................................... 96 8.7.1 Environmental Management Responsibilities of the Engineer ............................................................ 97 8.7.2 Environmental Management Responsibilities of the Contractor ......................................................... 97 8.8 REVIEWS BASED ON MONITORING OUTCOMES .......................................................................................... 98 8.9 PROGRAMME TO MEET REQUIREMENTS OF THE ESMP ............................................................................. 98 8.9.1 Development and Implementation of Construction Management Plan (CMP) ................................... 99 8.9.2 Adoption of Environmental, Health and Safety Management Plan ..................................................... 99 8.9.3 Contractors’ ESMP (C-ESMP) .......................................................................................................... 100 8.9.4 Worker’s Training and Awareness Creation ..................................................................................... 100 8.9.5 Environmental and Social Monitoring Programme ........................................................................... 101 8.9.6 Archaeological and Cultural Heritage Chance Find Procedure ....................................................... 101 8.10 GRIEVANCE REDRESS MECHANISM........................................................................................................... 101 8.10.1 Workers GRM .................................................................................................................................... 103 8.11 ENVIRONMENTAL AND SOCIAL BUDGETING ............................................................................................. 103 ESIA-MNP, GLRSSMP-EPA PCU, 2025 v 9.0 INSTITUTIONAL ARRANGEMENTS ............................................................................................. 108 9.1 TRAINING/CAPACITY BUILDING FOR ENVIRONMENT, HEALTH AND SAFETY MANAGEMENT ................ 110 10.0 ENVIRONMENTAL AND SOCIAL MONITORING PLAN .......................................................... 112 11.0 DECOMISSIONING ............................................................................................................................ 116 11.1 CLOSURE PROCEDURES.............................................................................................................................. 116 11.2 VEGETATIVE COVER (SEEDING) ................................................................................................................ 116 11.3 POST CLOSURE/AFTER CARE .................................................................................................................... 116 12.0 CONCLUSION ..................................................................................................................................... 117 13.0 REFERENCES ..................................................................................................................................... 118 14.0 ANNEXES ............................................................................................................................................. 119 ESIA-MNP, GLRSSMP-EPA PCU, 2025 vi LIST OF FIGURES Figure 3-1: Mole National Park and its fringe Districts ............................................................... 39 Figure 3-2 : Existing Game Viewing Platform at Mole ................................................................ 41 Figure 4-3 : Boundary & Core Area and Buffer zone Maps......................................................... 46 Figure 4-4 : Geological and Soil Map........................................................................................... 48 Figure 4-5: Topographical and Vegetation Maps ......................................................................... 49 Figure 4-6 : Boval vegetation in the Mole National Park ............................................................. 50 Figure 4-7 : Vegetative Map ......................................................................................................... 52 Figure 4-8 : A bird Specie at MNP ............................................................................................... 54 Figure 4-9 : Anthene talboti butterfly specie at MNP................................................................... 55 Figure 4-10 : Distribution of Fringe Communities around MNP ................................................. 59 Figure 4-11 : Archaeological Sites ............................................................................................... 60 Figure 4-12 : Existing Tree Hide at MNP ..................................................................................... 61 Figure 4-13 : Foot safari ............................................................................................................... 61 LIST OF TABLES Table 3-1: Civil Works in/around MNP and Site Characteristic .................................................. 37 Table 3-2 : Workforce estimates for sub-projects......................................................................... 42 Table 4-3 : Geology & Soils of Mole National Park .................................................................... 48 Table 4-2 : Summary Results of Ambient Air Quality Monitoring .............................................. 56 Table 4-3 : Ambient Noise Level Measurements ......................................................................... 57 Table 4-4 : Mole National Park Fringe Communities and Districts ............................................. 58 Table 4-7 : Demography of the Fringe Districts of Mole National Park ...................................... 63 Table 8-1: Estimated Budget for Environmental and Social Management ................................ 103 Table 8-2: Environmental and Social Management Plan: Proposed Civil Works in and around Mole National Park ..................................................................................................................... 104 Table 9-1: Institutional Roles and Responsibilities .................................................................... 108 Table 9-2: Training and Capacity Building Requirements ......................................................... 110 Table 10-1: Environmental and Social Monitoring Plan ............................................................ 113 ESIA-MNP, GLRSSMP-EPA PCU, 2025 vii EXECUTIVE SUMMARY Background The Environmental Protection Agency (EPA) and the Ministry of Lands and Natural Resources (MLNR) are currently implementing the Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP) in support of targeted actions to address land degradation through sustainable Integrated Landscape Management (ILM). Under the GLRSSMP, the EPA is responsible for landscape restoration activities while the MLNR is responsible for formalization of Artisanal Small-scale Mining (ASM). The GLRSSMP is funded by the World Bank / International Development Association credit, with leveraged grant financing from the Global Environment Facility (GEF), the PROGREEN Trust Fund, and the Extractives Global Programmatic Support Trust Fund to upscale and support the Government of Ghana in sustainable land management to address land degradation in Ghana. Project Goal, Description and Alternative The goal of the six-year project is to strengthen integrated natural resource management and increase benefits to communities in targeted savannah and cocoa forest landscapes. The project involves five basic components: ▪ Component 1. Institutional Strengthening for Participatory Landscape Management. ▪ Component 2. Enhanced Governance in Support of Sustainable Artisanal Small-Scale Mining ▪ Component 3: Sustainable Crop and Forest Landscape Management ▪ Component 4: Project Monitoring and Knowledge Management ▪ Component 5: Contingency emergency response The project intends to undertake construction of a number of water systems (i.e., dugouts, mechanised boreholes and water holes), game viewing platforms, camping sites, and the completion of the Lovi Research Centre in and around the Mole National Park. The construction of these infrastructure aims to improve access to water and watering of wild animals and livestock in fringe communities respectively, and to contribute to the ecotourism capacity of the Mole National Park. Detailed description for each of the civil works has been provided in the report. Alternatives considered include design, site, and no action scenario. Justification for the Sub-projects The development of the civil works in the Mole National Park is needed to boost the ecotourism capacity of the park. Constructing the dugouts in the fringes of the national park is to prevent the transfer of zoonotic diseases by limiting interactions between domestic animals and the wildlife because there will be no competition for water. ESIA-MNP, GLRSSMP-EPA PCU, 2025 viii Objectives of the Assignment The main objective of the assignment is to incorporate Environmental and social sustainability considerations into the planning, design, construction, operation and decommissioning of the various proposed facilities, identify potential E&S risks and impacts and propose measures to mitigate them. ESIA Study Methodology The approach and methodology for the ESIA study covered the following: ▪ Site inspections and field works ▪ Analysis of project alternatives ▪ Stakeholder identification and consultations ▪ Desktop study and document/literature review ▪ Specialist surveys, sampling and data analysis ▪ Identification and assessment of potential environmental and social risks and impacts ▪ Development of environmental and social management and monitoring/management plan ▪ Reporting Policy, Legal, Regulatory and Institutional Framework The following are national laws, regulations and policies relevant to the GLRSSMP: • The Constitution of Ghana, 1992 • Forest and Wildlife Policy (2012) • Forest Development Master plan (2016-2036) • Ghana Forest and Plantation Strategy (2015-2040) • Food and Agricultural Sector development policy (FASDEP II, 2016) • Medium Term Agricultural Sector Investment Plan (METASIP, 2011-2016) • Gender and Agricultural Development Strategy (GADS II, 2023) • National Climate Change Policy (NCCP). 2013 • National Land Policy (1999) • Land Act, 2020 (Act 1036) • Environmental Protection Agency Act, 1994 (Act 490) • Environmental Assessment Regulations, 1999 (LI 1652) • National Environmental Policy (2010) • Forestry Commission Act of 1999 (Act 571) • Wildlife Resources Management Act, 2023 (Act 1115) • Land use and Spatial Planning Act, 2016 (Act 925) • The Labour Act, 2003 (Act 651) • Children’s Act, 1998 Amended in 2016 (Act 937) ESIA-MNP, GLRSSMP-EPA PCU, 2025 ix • Workman’s Compensation law, 1987 (PNDCL 187) • Public Health Act, 2012 (Act 851) • Ghana Disability Act, 2006 (Act 715) • Fees and Charges (Miscellaneous Provisions) Act, 2022 (Act 1080) • Water Resources Commission Act, 1996 (Act 522) • Water Use Regulations, 2001 (LI 1692) • Hazardous and Electronic Waste Control and Management Act, 2016 (Act 917) • Hazardous Electronic and other Waste (Classification), Control and Management Regulations, 2016 (LI2250) National Environmental Standards The National Environmental Standards provide for permissible levels for ambient air quality, noise levels and effluent quality standards for discharge into natural water bodies. The environmental standards being adopted for this project include; ▪ Ghana Standards for Ambient air quality and point source air emissions (GS1236:2019) ▪ Ghana Standards Environmental Protection - Requirements for Effluent Discharge (GS1212:2019) ▪ Ghana Standards Health Protection - Requirements for Ambient Noise control (GS1222:2018) Relevant World Bank Environmental and Social Standards The World Bank integrates environmental and social considerations into all its investments to ensure that adverse project risks/impacts are managed appropriately while enhancing the positive impacts. The Bank policy of ‘do no harm’ to the environment has over the years changed into ‘do good’ which presupposes that undertakings ought not to have negative environmental impacts and at the same time improve the environment through biodiversity management, waste management etc. The Environmental and Social Framework of the World Bank, with its 10 standards, is anchored on the concept of sustainable development and sets out the requirements for Governments/borrowers relating to the identification and assessment of environmental and social risks and impacts associated with various undertakings is applicable to the project. The ESF rates environmental risk of investment as either high risk, substantial risk, moderate risk or low risk. The proposed project is rated as substantial and therefore requires the preparation of this ESIA. The relevant standards applicable to the project include ESS1, ESS2, ESS3, ESS4, ESS5, ESS6, ESS8, and ESS10. ESIA-MNP, GLRSSMP-EPA PCU, 2025 x Environmental and Social Baseline The proposed civil works are located in and around the Mole National Park which spans four political/administrative districts (Sawla-Tuna-Kalba, West Gonja, Mamprugu-Moagduri, and Wa East). Mole National Park is the largest national park in Ghana and has the widest range of wildlife. It has a total land area of 4,577 square kilometres. It is the most visited park, of the four national parks to be covered by the project, attracting an annual average of eighteen thousand (18,000) tourists. The average temperature in Mole National Park is about 28°C. The dry season usually lasts from November till March, whilst rainy season usually lasts from April to October, and the vegetation is lush during this period. Geologically, the area is characterized by widespread Birimian granite rocks, and the lands have a height range of 180-300 meters, above sea level. There are high plains and gentle rolling land, interspersed with small rounded hills or inselbergs. The vegetation of Mole National Park can be grouped into the following broad vegetation types; open savannah woodland, boval, riverine forest, flood plain grasslands and swamps. There are about 93 species of mammals within thin park, however, the lions (pantheraleo) and elephants (Loxodonta africana) found in Mole National Park are currently listed as vulnerable on the IUCN red list of 2004. Ambient air and noise measurements were found to be within national permissible levels. Two main rivers, Mole and Lovi drain the area with other smaller streams. The park has 32 fringe communities located in five districts. The Mole Park, with 32 fringe communities has a total population of about 40,000. The main economic activity of the people living in these fringe communities is farming, with the major crops cultivated being yam, maize, groundnuts, millet, sorghum, beans, soya beans, rice and cassava. Livestock reared includes sheep, goats, cattle, guinea fowls and chickens. Citizen/Stakeholder Engagement Citizen/Stakeholder engagement activities were carried out as an important aspect of the assessment process to specifically • Identify concerns and expectations with the project implementation; • Assess the degree to which relevant stakeholders could be impacted by the project; • Dialogue on the main potential E&S constraints and risks requiring mitigation; • Evaluate mitigation measures and project alternatives with stakeholders; and • Dialogue on E&S opportunities and other benefits that could be enhanced. ESIA-MNP, GLRSSMP-EPA PCU, 2025 xi Identification of Impacts Positive Environmental and Social Impacts The sub-projects to be constucted will have several positive impacts including employment generation, and, improved livelihoods through increased production of livestock, as water availability for watering livestock in the beneficiary communities will be enhanced. Also, the facilities (viewing platforms, waterholes, camping sites, etc.) to be built in the Mole National Park will enhance the ecotourism capacity of the park. The potential adverse impacts identified have been summarised in the table below. And to ensure that the potential negative impacts from development of the civil works are adequately managed, appropriate mitigation and enhancement measures for the significant potential adverse impacts have been proposed. These measures i.e. preventive, control and compensatory (section 7.0) have been developed based on the mitigation hierarchy which ensures that potential environmental and social impacts are avoided, reduced or compensated to acceptable levels. These preventive measures will be integrated into the project design at the pre-construction phase. Summary Risks/Mitigation Table Risks Sources Effects Mitigation measure Significance Loss of habitat Clearing of land for Ecosystem disturbance Selective felling Protect and conserve and biodiversity construction Education of workers biodiversity Air and noise Excavation during Adverse effects on Contractors will be Protect workers and Pollution construction and use workers and community required to regularly community health of Obsolete health service their construction equipment equipment and undertake water dousing to minimise the release of particulate matter and dust pollution Water Muddying of nearby Siltation of streams Implement controlled Maintaining and contamination streams excavation methods to ensuring quality of reduce sediment stream water displacement into water bodies. Where necessary, create sediment basins or traps to collect runoff and allow sediment to settle before water is discharged Visual intrusion Open construction Disturbing sights of cordoning -off Avoiding visual sites people passing by the construction sites intrusion sites Erosion Storm water run-off Development of gullies Construction will be Landscape integrity and siltation phased, to minimize the will be maintained ESIA-MNP, GLRSSMP-EPA PCU, 2025 xii Risks Sources Effects Mitigation measure Significance area of disturbance at any one time, thereby limiting erosion potential Fire Hazards Improper storage of Harm to workers, Keeping of petroleum Maintain safety of petroleum products equipment and eco- products in bunded and workers, equipment for equipment system safe area and eco-system leading to leakages and possible explosions Disposal of Improper disposal of Causing of nuisance to Debris will be deposited at Avoiding conflict construction construction debris communities appropriate locations after with human and debris discussions with Park wildlife movements Management Transmission of Labour influx to Infection of HIV/Aids Education of workers and Maintaining health HIV/AIDS and construction sites &STDs communities on and safety of communicable preventive measures and workers and diseases management strategies communities Gender based Poor sensitisation of Abuses on women and Contractors will be Human rights of violence, child workers and project children and engaging obliged to adhere to an people will be labour and child communities on minors on construction established code of upheld abuse issues of sites. conduct enshrined in their GBV/SEA/SH and operational documents child labour and lack of related site policies This report also includes an Environmental and Social Management Plan (ESMP) that has been developed in compliance with the requirements of the Ghana Environmental Assessment Regulations of 1999, (LI 1652), and the relevant World Bank Environmental and Social Standards to guide the implementation of the proposed subprojects in an environmentally sound and sustainable manner. The management commitments and the required training programmes for the sustainable implementation of the proposed projects have been presented in the ESMP. An estimated budget for the implementation of the mitigation measures including training and capacity building is indicated below. No Activity Cost/p.a (USD) 1 Implementation of mitigation measures-ESMP (see Table 9-2): • Construction Phase In contractor’s fees • Operational Phase In project’s Environment and safeguard Budget ESIA-MNP, GLRSSMP-EPA PCU, 2025 xiii 2 Training and Capacity Building (See Table 10-2) 73,000.00 3 Environmental Auditing and Reporting: 15,000.00 Quarterly environmental, health and safety audits Returns of Monitoring Reports to EPA (In compliance with LI 1652) Preparation of Environmental and Social Management Plan every 3 years (In compliance with LI 1652) 4 Environmental and Social Monitoring Plan (See Table 11-1) 50,000.00 5 ESMP and Implementation of Grievance Redress Mechanism (Existing - GLRSSM-EPA-PCU Budget) Total 138,000.00 Environmental and Social Monitoring Plan This section presents a detailed Environmental and Social Monitoring Plan (ESMP-Monitoring) to guide the monitoring of the environmental and social impacts and the implementation of mitigation and enhancement measures during the construction and operation phases. The monitoring plan will enable the EPA to confirm the effectiveness or otherwise of the mitigation measures contained in the ESIA and help enhance the effectiveness of the implementation of the mitigation measures. The monitoring plan includes identification of the responsible institutions or persons and estimated budget/cost requirements. The ESMP-Monitoring includes social and environmental protection measures/indicators addressing at a minimum: • Workers’ rights and responsible labour behaviour (including GBV/SEA/SH issues) • Prevention and identification of child labour • Induced development, both short term during construction and long term, from the presence of the Project. • Occupational health and safety requirements for workers. • Project related incidents such as traffic accidents and risks to public safety. • Waste management, including construction wastes and hazardous wastes. • Security issues including material and equipment storage and potential vandalism. • Removal of vegetation and measures for landscaping. • Ongoing information disclosure, consultation and engagement in next project phases, and • Management systems and capacity for implementing them. CONCLUSION The goal of the six-year project is to strengthen integrated natural resource management and increase benefits to communities in targeted savannah and cocoa forest landscapes. ESIA-MNP, GLRSSMP-EPA PCU, 2025 xiv The scope of civil works has been clearly defined under the project, including construction of camping sites for rangers in some areas, small-scale ecotourism infrastructure (bird hides/ viewing platforms), small water dugouts/water holes, completion of the Lovi Research Centre in the Mole National Park and some of its fringe communities. The construction of these infrastructure aims to improve access to water and watering of wild animals and livestock and contribute to the development of the Mole National Park and the fringe communities. The proposed interventions may have both positive and negative environmental and social impacts and therefore an environmental and social assessment studies have been conducted in accordance with national environmental assessment regulations (LI1652) and relevant World Bank Environmental and Social Standards culminating in the preparation of this Environmental and Social Impact Assessment (ESIA). Notwithstanding the above potential positive impacts, a broad range of adverse impacts on the natural and human environments could arise from the pre-construction, construction, maintenance and operation and decommissioning phases of the proposed civil works. The various civil works have been designed and will be developed in a manner that will avoid or minimize the environmental and social impacts through careful planning, designing, construction and operation. Residual negative environmental impacts are expected to be limited and easy to mitigate as appropriate mitigation measures exist and are well known to the implementing agencies. ESIA-MNP, GLRSSMP-EPA PCU, 2025 xv 1.0 INTRODUCTION Ghana is largely agrarian and natural resource dependent. The agriculture, forestry, and fishing sector (Ghana Living Standards Survey Report 2015) employs about 3.3 million of the rural population; the cocoa sector is reported to employ 1 million households. Together, renewable and non-renewable natural resources contribute significantly to livelihoods for the most vulnerable rural communities. Rural employment makes up 49.1 percent (4.6 million) of total employment in Ghana. Informal employment, including a huge number of unskilled workers in agriculture and forestry, provides livelihoods for more than 70 percent of the rural population, particularly to the country’s poorest households. However, with the advent of climate change and resulting impacts and more recently, the COVID- 19 pandemic, most rural livelihoods have become stressed. It is also evident that natural resources, including land and forests, will continue to serve as the vehicle for long-term inclusive growth recovery and economic empowerment. Efforts have to be made to provide alternative livelihood opportunities to the rural population, largely smallholders, to cushion them against the effects of changes in the global climate and disease patterns. In introducing such interventions, it is very critical to put up infrastructure that will respond to the environmental, social and economic dynamics prevailing in the zones and make communities more resilient. 1.1 Background The Environmental Protection Agency (EPA) and the Ministry of Lands and Natural Resources (MLNR) are currently implementing the Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP) in support of targeted actions to address land degradation through sustainable Integrated Landscape Management (ILM). Under the GLRSSMP, the EPA is responsible for landscape restoration activities while the MLNR is responsible for formalization of Artisanal Small-scale Mining (ASM). The goal of the six-year project is to strengthen integrated natural resource management and increase benefits to communities in targeted savannah and cocoa forest landscapes. The GLRSSMP is funded by the World Bank / International Development Association credit, with leveraged grant financing from the Global Environment Facility (GEF), the PROGREEN Trust Fund, and the Extractives Global Programmatic Support Trust Fund to upscale and support the Government of Ghana in sustainable land management to address land degradation in Ghana. The project involves five components: ▪ Component 1. Institutional Strengthening for Participatory Landscape Management. ▪ Component 2. Enhanced Governance in Support of Sustainable Artisanal Small-Scale Mining ESIA-MNP, GLRSSMP-EPA PCU, 2025 1 ▪ Component 3: Sustainable Crop and Forest Landscape Management ▪ Component 4: Project Monitoring and Knowledge Management ▪ Component 5. Contingent Emergency Response Component The sub-projects covered by this ESIA for MNP fall under component three (3) of GLRSSMP. The component aims to link improved food production and ecological integrity. Among others, the component activities are directed towards supporting income generation and income diversification at community levels, with a view to integrated natural resource management in target cocoa and savannah landscapes. In this regard, facilities to be constructed include water systems (waterholes), game viewing platforms and safari trails within the park; boreholes and toilet facilities for admitted settlements within the park; and dugouts, shea and mini cassava processing facilities in some fringe communities. This Environmental and Social Impact Assessment (ESIA) has been prepared as part of the Ghana EPA regulatory requirements for decision making and environmental permitting. This ESIA includes an Environmental and Social Management Plan (ESMP) which will be used in the preparation of bid documents for the selection of Contractor(s) for the execution of the GLRSSMP and will be required to integrate the recommended mitigation measures through the construction phase of the civil works. 1.2 Justification for the Sub-projects Tourism continues to be a major earner to many countries, especially in Eastern Africa, and can also enhance livelihoods of communities around these tourist sites. The Mole National Park is one of the busiest ecotourism sites in Ghana and has the potential to increase the tourist traffic. The development of the civil works in the Mole National Park is needed to boost the ecotourism capacity of the Park. It is also important to note that constructing the dugouts within the fringe communities of the national park is to improve water availability for livestock and to prevent the transfer of zoonotic diseases by avoiding competition with other sources 1.3 Aims of the ESIA Study The ultimate aim of the ESIA studies is to integrate environmental and social considerations into sub-project designs and to assess and predict potential adverse social and environmental impacts and to develop appropriate mitigation measures. Specific objectives of the study are to: a. Delineate and describe the project components and activities; these activities fall under component three including waterholes, game viewing platforms, safari trails and sheanut processing facilities. ESIA-MNP, GLRSSMP-EPA PCU, 2025 2 b. Characterise the valued environmental and social environments (fundamental elements of the physical, biological or socio-economic environment, including land use that may be affected by the proposed project); i.e. biodiversity c. Identify and assess potential environmental and social impacts that are likely to arise from the construction, operation and decommissioning of the civil works d. Recommend feasible and cost-effective measures and processes to respectively mitigate or enhance potential adverse and positive environmental and social impacts that could result from construction, operation and decommissioning of the subprojects; e. Prepare an Environmental and Social Management and Monitoring Plan (ESMMP) for mitigating the potential environmental and social impacts (including preventing Child Labour, Gender-based Violence (GBV), Sexual Exploitation and Abuse (SEA), and Sexual (SH) Harassment) of the proposed interventions and for monitoring the effectiveness of the mitigation measures, and; f. Integrate environmental and social considerations into the technical engineering designs of the subprojects and inform the implementation of sustainable measures during the construction, operation and decommissioning of the subprojects. 1.4 Study Methodology The approach and methodology for the ESIA study covered the following: ▪ Field visits and site inspections ▪ Analysis of project alternatives ▪ Stakeholder identification and consultations ▪ Desktop study and document/literature review ▪ Specialist surveys, sampling and data analysis ▪ Identification and assessment of environmental and social impacts ▪ Development of environmental and social management and monitoring plan ▪ Reporting 1.4.1 Field Visits Field visits and inspection of sites selected for various sub-projects were undertaken as part of the preparation of the ESIA report. Consultations with major stakeholders were undertaken during this exercise in the project districts (West Gonja, Sawla-Tuna-Kalba, Wa East, Sissala East, Sissala West, Builsa South, Bawku west and West Mamprusi), to sensitize major stakeholders, including Beneficiary Agencies, Metropolitan, Municipal and District assemblies (MMDAs), the Mole ESIA-MNP, GLRSSMP-EPA PCU, 2025 3 National Park Managers and Rangers, and fringe communities within the project area. The citizen engagement and stakeholder consultation took place between 21st and 30th January 2024. The purpose of the team visit was to ▪ assess the baseline conditions of the proposed sites for the civil works ▪ gather relevant data and have first-hand information for the preparation of the report ▪ consult with relevant stakeholders for their feedback to enrich the ESIA Community leaders in Community Resource Management Areas (CREMA) and fringe communities i.e. Chiefs, opinion leaders, CREMA committee members and assembly members have been involved in decision making processes. Other groups in the beneficiary communities such as women, and other vulnerable groups were also engaged. These groups were given information on all aspects of the project intervention including the benefits, challenges and their obligation to the successful implementation of the project. Methods used to achieve this included focus group discussions and public announcements using existing community channels of information dissemination. Details of consultation outcomes, stakeholder concerns, and how their concerns informed the design and implementation of the sub-projects are contained in chapter 5 of this report. The Stakeholder Engagement Plan prepared for the project provided guidance to the stakeholder engagement during the field visits. 1.4.2 Desktop Study and Documents/Literature Review As part of preparation of the ESIA, relevant documents have been reviewed to provide insight into the proposed civil works. These include the following: ▪ Existing reports/documents, maps and data related to the execution of the Project. ▪ Existing field designs under the Sustainable Land and Water Management Project ▪ Design for Waterholes ▪ Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP) Environmental and Social Screening of selected civil works, Screening Report Environmental Protection Agency (EPA) ▪ International Development Association Project Appraisal Document for Ghana Landscape Restoration and Small-Scale Mining Project August 10, 2021 ▪ Environmental Protection Agency/Ministry of Environment Science Technology and Innovation, Ministry of Lands and Natural Resources Ghana Landscape Restoration and Small-Scale Mining Project (P171933) Environmental and Social Management Framework (ESMF), February 2021 ESIA-MNP, GLRSSMP-EPA PCU, 2025 4 ▪ Environmental Protection Agency and Ministry of Lands and Natural Resources Ghana Landscape Restoration and Small-Scale Mining Project (P171933) Negotiated Environmental and Social Commitment Plan (ESCP), June 27, 2021 ▪ Environmental Protection Agency (EPA) and the Ministry of Lands and Natural Resources (MLNR), Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP) Project Implementation Manual (PIM), June 2021 ▪ Centre pour le Développement de la Production Faunique Wildlife Production Development Centre, Inception Report, 30 December 2023 ▪ Centre pour le Développement de la Production Faunique Wildlife Production Development Centre, Site Evaluation and Summary Construction Plan, Community : Sakalo, Site: Sata Optimised Dugout, 31 January 2024 ▪ Lovi Research Centre Drawings 1.4.3 Data Analysis and Reporting A collation and analyses of relevant data, pieces of information extracted from the desktop study or literature review, field visits and environmental media sampling have been carried out to produce this draft Environmental and Social Impact Assessment (ESIA). The ESIA has been presented and organized under the following headings ▪ Executive Summary ▪ Introduction ▪ Description of the Proposed Project and Alternatives ▪ Policy, Legal and Regulatory Framework ▪ Description of the Baseline Biophysical and Socio-Economic Environments ▪ Citizen Engagement and Stakeholder Consultation ▪ Identification of Potential Impacts ▪ Mitigation and Enhancement Measures ▪ Environmental and Social Management Plan (ESMP) ▪ Environmental and Social Monitoring Plan ▪ Conclusion ESIA-MNP, GLRSSMP-EPA PCU, 2025 5 2.0 POLICY, LEGAL, REGULATORY AND INSTITUTIONAL FRAMEWORK National and sector legislation and policies relevant to the development of the civil works under the GLRSSMP have been reviewed in this section. Also, institutional requirements, World Bank Environmental and Social Standards (ESSs) and national environmental quality standards for the management of environmental and social issues potentially associated with the proposed interventions have been considered. 2.1 Relevant Policies and plans The relevant national Policies and Plan to guide the implementation of the project include the following • National Land Policy, 1999; • National Water Policy, June 2007; • National Climate Change Policy, 2013; • National Gender Policy, 2015; • Ghana Accelerated Action Plan Against Child Labour (2023-2027) • Riparian Buffer Zone Policy, 2014; • National Environmental Action Plan/Policy, 1994; • National Workplace HIV/AIDS Policy • Forest and Wildlife Policy (2012) A detailed narrative of Ghana’s laws/policies, World Bank’s environmental and social standards and relevant international treaties, conventions and protocols are presented in this document. Table 2-1: Relevant Policies and Applicability No Policies/Plans Applicability to the project 1 National Environmental Policy, 2012 The proposed project seeks to The ultimate aim of the Policy is to improve the surroundings, promote sustainable development living conditions and the quality of life of the entire citizenry, both by including economic, social and present and future. It seeks to promote sustainable development environmental considerations through ensuring a balance between economic development and natural resource conservation. The policy thus makes a high-quality environment a key element supporting the country’s economic and social development 2 National Land Policy, 1999 Some of the subprojects are in the The key aspects of the policy relevant to the project include: The protected area that is Mole use of any land in Ghana for sustainable development, the National Park, whiles others are in protection of water bodies and the environment and any other the fringe communities. The socioeconomic activity will be determined through national land implementation of the project will ESIA-MNP, GLRSSMP-EPA PCU, 2025 6 use planning guidelines based on sustainable principles in the long- conform to the environmental laws term national interest. Land categories outside Ghana's permanent of the country which includes the forest and wildlife estates are available for such uses as agriculture, conduct of environmental and timber, mining and other extractive industries, and human social impact assessment and settlement within the context of a national land use plan. All land obtaining of an environmental and water resources development activities must conform to the permit from the EPA environmental laws in the country and where Environmental Impact Assessment report is required this must be provided. Environmental protection within the 'polluter pays' principle will be enforced 3 National Water Policy, 2007 The project's Environmental and The objective of Section 2.2.3 Focus Area 3 –Water for Food Social Management Plan (ESMP) Security is to ensure availability of water in sufficient quantity and will include mitigation measures quality for the cultivation of food crops, watering of livestock and against over- exploitation of water sustainable freshwater fisheries to achieve sustainable food security resources potentially arising from for the country. The relevant policy measures and/or actions to be the development of waterholes and undertaken include: encouraging efficient water from the dugout also against water pollution which for livestock watering to ensure conservation of water could emanate from construction activities or waste management at the operation phase and use of other chemicals in riparian zones. 4 National Environmental Action Plan/Policy, 1994 The design and implementation of The National Environmental Action Plan was initiated to define a the proposed civil works will take set of policy actions, related investments and institutional into consideration measures to strengthening activities that would make Ghana’s development promote the sustainable use of strategy more environmentally sustainable. The Plan formulated a natural resources and ensure national environmental policy as the framework for implementing environmental management. the Action Plan. The Policy aims at ensuring a sound management of resources and the environment and to avoid any exploitation of these resources in a manner that might cause irreparable damage to the environment. Specifically, it provides for maintenance of ecosystems and ecological processes essential for the functioning of the biosphere, sound management of natural resources and the environment, and protection of humans, animals and plants and their habitats. 5 National Climate Change Policy, 2013 The sub-projects seek to build the The Policy is built on seven (7no.) systematic pillars and the resilience of beneficiary objective of the Policy is to mitigate and ensure an effective communities by supporting value adaptation in key sectors of the economy, such as agriculture and addition to their primary food security, natural resources management, energy, industry and agricultural produce, to enhance infrastructure among others. The objective is to build climate incomes of beneficiaries, and also resilient technology reduce fringe communities’ ESIA-MNP, GLRSSMP-EPA PCU, 2025 7 overdependence on natural resources from the parks. It will also ensure that wildlife is not impacted negatively through water stress since there will be enough for livestock watering through the construction of dugouts 6 Buffer Zone Policy, 2014 The project will ensure that the The policy aims at providing comprehensive measures and actions necessary buffer distances are that would guide the creation of vegetative buffers for the observed around the Mole and preservation and functioning of the nation’s water bodies and vital Lovi rivers which are the main ecosystems. rivers draining the park. The Nyenge, Blue and Motel are also rivers within the park. 7. Ghana Accelerated Action Plan Against Child Labour The project will raise awareness on (2023-2027) what child labour is in the The Plan aims to strengthen communities and awareness raising communities, ensure clear labour and behavioural change to prevent and remediate child labour, standards for civil works, including decent youth employment and skills development. Priority sectors age-verification and awareness, of relevance for the GLSRSSMP and civil works activities where and collaborate with mandated child labour needs to be proactively identified and prevented ministries to monitor, identify and include child labor in street hawking, begging and porterage which help remediate any potential cases could happen around work-sites, illegal Small-Scale Mining of child labour that might occur. (“galamsey�) and Quarrying which could take place in mining sites covered by the project, and transportation i.e. driving tricycle and small van, commercial sex exploitation of children, type of exploitation of children which could be occurring around project sites as a result of an increase in works and economic activities in the area. 8 National Gender Policy, 2015 The project will mainstream gender The National Gender Policy aims at mainstreaming gender equality issues including not discriminating concerns into the national development processes by improving the against women and the vulnerable social, legal, civic, political, economic and socio-cultural in the local communities. The conditions of the people of Ghana. It also seeks to empower the ESMP has made provisions for vulnerable groups particularly women, children, and people with managing GBV risks/issues. special needs such as persons with disabilities and the marginalized ESIA-MNP, GLRSSMP-EPA PCU, 2025 8 9 National Workplace HIV/AIDS Policy The project duration will be The broad objectives of the National Workplace HIV/AIDS Policy, short-term and use just a few among others, are to provide protection from discrimination in the migrant workers for some of the workplace to people living with HIV and AIDS; prevent HIV and facilities. This will reduce the AIDS spread among workers; and provide care, support and potential for HIV spread but an counselling for those infected and affected. The project will HIV policy will be provided as institute a plan of action to prevent HIV/AIDS spread through required by the national policy awareness creation. 2.2 Environmental Protection Agency Act, 1994 (Act 490) The Environmental Protection Agency Act 1994 (Act 490) is the main legislation for ESIA studies in Ghana. The Act grants the Environmental Protection Agency (EPA) enforcement and standards- setting powers, and the power to ensure compliance with the Ghana environmental assessment requirements/procedures. Additionally, the EPA is required to create environmental awareness and build environmental capacity among all sectors. The EPA, including its Regional and District Offices, is also vested with the power to determine what constitutes an ‘adverse effect on the environment’ or an activity posing ‘a serious threat to the environment or public health’, to require environmental assessments and environmental management plans of an undertaking, and to regulate and serve enforcement notices for any offending or non-complying undertaking. The EPA is required to conduct monitoring to verify compliance with given approval/permit conditions, required environmental standards and mitigation commitments. The Environmental Assessment (EA) Regulations,1999 combine both assessment and environmental management systems. The regulations prohibit commencing an undertaking/activity without prior registration and environmental permit (EP). Undertakings are grouped into schedules for ease of screening and registration and environmental permitting. The schedules include undertakings requiring registration and EP (Schedule 1), EIA mandatory undertakings (Schedule 2), as well as Schedule 5-relevant undertakings (located in Environmentally Sensitive Areas). The proposed civil works in the Mole National Park falls under schedule 5. The Regulations also define the relevant stages and actions, including registration, screening, preliminary environmental assessment, scoping and terms of reference (ToR), environmental impact assessment, review of EA reports, public notices and hearings, environmental permitting and certification, fee payments, environmental management plan, suspension/revocation of permit and complaints/appeals. Under the EA Procedures it is required that an Environmental Impact Statement is prepared by the proponent to clearly present an assessment of the impacts of the proposed project on the ESIA-MNP, GLRSSMP-EPA PCU, 2025 9 environment based on the terms of reference as stipulated in the scoping report. The EA Procedures requires that potential direct and indirect impacts of the project on the environment covering the pre-construction, construction, operation, decommissioning and post decommissioning stages are addressed. 2.3 Legislative and Regulatory Framework The project will be implemented and guided by relevant legal and legislative frameworks to ensure sustainability and compliance. They include the following • Environmental Protection Act, 1994 (Act 490) • Environmental Assessment Regulations 1999 (LI 1652) • Forestry Commission Act of 1999 (Act 571) • Mining and Minerals Act of 2006 (Act 703) • Land use and Spatial Planning Act 2016 (Act 925) • Land Act, 2020 (Act 1036) • The Labour Act 2003 (Act 651) • Workman’s Compensation law 1987 (PNDCL 187) • Public Health Act 2012 (Act 851) • Ghana Disability Act 2006 (Act 715) • Fees and Charges (Miscellaneous Provisions) Act, 2022 (Act 1080) • Water Resources Commission Act, 1996 (Act 522) • Water Use Regulations 2001 (LI 1692) • Hazardous and Electronic Waste Control and Management Act 2016 (Act 917) • Hazardous Electronic and other Waste (Classification), Control and Management Regulations, 2016 (LI2250) • Wildlife Resource Management Act 2023 (Act 1115) • Local Governance Act, 2016 (Act 936) • Children’s Act, 1998 Amended in 2016 (Act 937) • The Child Labour Hazardous Activity Framework (2021) • The Children's Act 2016 (Act 937) • Wild Animals Preservation Act 1961 (Act 43) • Wildlife Conservation Regulation, 1971 (L.I. 685) • National Building Regulations, 1996 (LI 1630) • Ghana Building Code (GhBC; GS 1207), 2018 • Factories, Offices and Shops Act, 1970 (Act 328) • Ghana National Fire Service Act, 1997 (Act 537) • Fire Precaution (Premises) Regulations, 2003 (LI1724) ESIA-MNP, GLRSSMP-EPA PCU, 2025 10 The relevance of the above listed framework is provided in the table below Table 2-2: Relevant Legal Framework and their applicability No Legal Framework and Key Compliance Requirement Applicability to Proposed project 1 Environmental Protection Agency (EPA) Act 1994, Act The project will be in 490 compliance with the The Environmental Protection Agency (EPA) Act 1994 Environmental Assessment (Act 490) gives a mandate to the Agency to ensure (EA) procedures for approval of the compliance of all investments and undertakings with laid EPA. down Environmental Assessment (EA) procedures in the The proposed project will planning and execution of development projects, including involve the clearing of vegetation compliance in respect of existing ones. The Environmental and generation and disposal of Protection Agency (EPA) Act 490 Section 12 of 1994 waste. Also, an EPA permit will be confers enforcement and control powers on the EPA to obtained compel existing companies to submit environmental or pollution management plans on their operations as a management tool for effective pollution control. The EPA is the responsible for issuing environmental permits for operations such as this project subject to EPA review 2 Environmental Assessment Regulations 1999, LI 1652 The project will be guided by LI The Environmental Assessment Regulations 1999 (LI 1652 including registering 1652) enjoins any proponent or person to register an project with the EPA and undertaking with the Agency and obtain an Environmental obtaining an environmental Permit prior to the commencement of the project. This permit. regulation allows the EPA to place proposed undertakings at the appropriate level of environmental assessment. The LI 1652 seeks to ensure that development is undertaken in a sustainable environment 3 Fees and Charges (Miscellaneous Provisions) Act, 2022 The processing and permit fees are (Act 1080) required for initial registration, and The Fees and Charges (Miscellaneous Provisions) Act, permit issuance respectively 2022 (Act 1080) sets out the fee regime for processing and issuing environmental permits, in line with the Environmental Assessment Regulations 1999, (LI1652). 4 Water Resources Commission Act, 1996 (Act 522) The dugouts and boreholes will be It establishes and mandates the Water Resources constructed in compliance with this Commission (WRC) as the sole agency responsible for the requirement. The PCU, upon the regulation and management of the utilisation of water approval of the ESIAs and ESMPs, resources and for the co-ordination of any policy in will secure environmental permits relation to them. Section 13 prohibits the use of water and water permits from EPA and (divert, dam, store, abstract or use water resources or WRC respectively. construct or maintain any works for the use of water resources) without authority. Section 16 empowers the Commission to grant Water Rights (water use permits) to prospective users. The Act states under Section 24 that any person who pollute or fouls a water resource beyond the ESIA-MNP, GLRSSMP-EPA PCU, 2025 11 No Legal Framework and Key Compliance Requirement Applicability to Proposed project level that the EPA may prescribe commits an offence and is liable on conviction to a fine or a term of imprisonment or both. 5 Water Use Regulations, 2001 (LI 1692) The PCU will ensure compliance The Water Use Regulations 2001, LI 1692 prohibits the with this regulation by obtaining the use of water resources without authority from the Water necessary permits. The approval of Resources Commission. It provides procedures for ESIA and ESMP reports is required allocating permits for various water uses including for such permits domestic, commercial, municipal, industrial, agricultural, power generation, water transportation, fisheries (aquaculture), environmental, recreational and underwater (wood) harvesting. The Act provides under section 16 for any person to apply to the Commission in writing for the grant of water right. The Regulations also prescribe the raw water charges and processing fees to be paid by prospective water users with respect to the water use permits. The Commission is also mandated to request for evidence that an environmental impact assessment or an environmental management plan has been approved by the EPA before issuance of the Water Use Permit 6 Local Governance Act, 2016 (Act 936) Technical advice will be sought from This Act establishes and regulates the local government the Physical Planning Department of system and gives authority to the Regional Coordinating the District Assembly on the siting Council (RCC) and the District Assembly to exercise of processing facilities and dugouts political and administrative power in the regions and in the fringe communities. districts respectively. This includes initiation of development programmes as well as development, improvement and management of human settlements and the environment through departments such as the Environmental Health (EHD) and Social Welfare and Community Development (SWCD) Departments Land Act, 2020 (Act 1036) The Land Act provides a framework This Act harmonises and consolidates the laws on to guide the project proponent in the land, to ensure sustainable land administration and acquisition of land for facilities to be management, effective and secure land tenure. It also constructed in the fringe provides for related matters. communities. It also defines the various approaches the state (including the project proponent) may acquire land for public purposes, including gifts or voluntary donations of land to the state. Furthermore, it provides for how the land so acquired should be documented, and registered etc. 7 The Children's Act 2016 1998 Amended in (Act 937) Provisions against exploiting child It seeks to reform and consolidate the law relating to labour have been included in the children, provide for the child's rights, maintenance, and ESMP adoption, regulate child labour and apprenticeship for ESIA-MNP, GLRSSMP-EPA PCU, 2025 12 No Legal Framework and Key Compliance Requirement Applicability to Proposed project ancillary matters concerning children generally, and to provide for related matters. Section 87 of this Act states, "No person shall subject a child to exploitative labour". Therefore, no project activities shall engage children below the legal working age (18 years for hazardous work). 8 Wild Animals Preservation Act 1961 (Act 43) The project activity will not trigger The Act provides for the protection of selected animals this regulation. through restrictions on export and hunting of scheduled species. This empowers the President to exercise the overall control over wildlife and also provides for the creation of Wildlife Reserves. 9 Wildlife Conservation Regulation, 1971 (L.I. 685) The project will contribute to the The Wildlife Conservation Regulation provides for conservation of wildlife by ensuring hunting restrictions in relation to different species of that the Contractor will have the animals which are classified into wholly and partly responsibility to educate and control protected animals. workers against actions that will The Regulation further prohibits hunting without a license disturb wildlife i.e. unauthorised and exporting game or trophies without permit and hunting of animals. provides for rules and procedures in relation to game licenses and export permits. Lastly rules of operation for game officers are included in the regulation. 10 Wildlife Resources Management Act, 2023 (Act 1115) Some of the project interventions The Wildlife Resources Management Act aims to promote will be managed by established sustainable wildlife management, conservation, and CREMAs in the fringes of the Mole community involvement in protecting Ghana's National Park biodiversity. It sets clear guidelines for wildlife protection, The PAMACs are district structures licensing, and enforcement to safeguard the country's that addresses complaints relating to natural heritage for future generations. The Act outlines sub-project implementation activities the functions of the Forestry Commission including and management of the parks and managing protected areas, establishing advisory also integrate local community needs committees, and promoting sustainable tourism and ensure conservation efforts align development within these areas, while ensuring with national objectives. environmental safeguards and community involvement. Additionally, it assists local communities in establishing and managing Community Resource Management Areas (CREMAs), enforces regulations on hunting and trading of wildlife, and represents the government in international wildlife conventions. It establishes Protected Area Management Advisory Committees (PAMACs) for each area to integrate local community needs and ensure conservation efforts align with national objectives 11 National Building Regulations, 1996 (LI 1630) The project will involve The National Building Regulations, 1996 (LI 1630) make development of infrastructure it an offence for any individual to undertake any particularly the mini processing development without the acquisition of a Building Permit facilities the necessary building from the appropriate authority. This ensures that buildings permit will be acquired are well planned and are in conformity with the ESIA-MNP, GLRSSMP-EPA PCU, 2025 13 No Legal Framework and Key Compliance Requirement Applicability to Proposed project Assembly’s plan designs of an area. The LI 1630 ensures that buildings are well planned, consistent with the Assembly’s spatial plan for an area. 12 Ghana Building Code (GhBC; GS 1207), 2018 The project activities will be The Ghana Building Code sets out the requirements, undertaken according to the recommendations, planning, management and practices specification of the Ghana Building that will lead to the country's smooth operation and Code. construction of residential and non-residential buildings. 13 Land Use and Spatial Planning Act, 2016 (Act 925) The project design will be The Land Use and Spatial Planning Act, 2016 (Act 925) guided by planning schemes regulates land use through a decentralised planning system and local plan guides to ensure judicious use of land in order to improve quality developed by the Land Use and of life, promote health and safety in respect of human Spatial Planning settlements and generally provide for spatial aspects of Departments/District Assemblies socio-economic development and related matters. 14 Labour Act, 2003 (Act 651) Construction activities could result The Labour Act 2003 (Act 651) Section 118(1) stipulates in injuries and fatalities. HSE issues that it is the duty of an employer to ensure that will be duly assessed and mitigated satisfactory, safe and healthy conditions are provided for against in the proposed ESMP for every worker. Under these provisions, a worker is required the project to report situations that he believes may pose “an imminent and serious danger to his or her life, safety or health 15 Workmen’s Compensation Law, 1987 (PNDCL 187) The Labour policy and employment It is to provide for the payment of compensation to contracts will provide for workmen workmen for personal injuries caused by accidents arising compensation in the event of injury. out and in the course of their employment. The tenets of the law place a large share of the burden of supporting workers injured at the workplace on the shoulders of the employers. 16 The Public Health Act, 2012 (Act 851) Measures will be put in place to The Public Health Act, 2012 (Act 851) is an Act to revise ensure project activities do not cause and consolidate the law relating to public health to prevent any public health risks to humans disease, promote, safeguard, maintain and protect the and animals in accordance with the health of humans and animals and to provide for related Act. matters. 17 The Persons with Disability Act 2006. (Act 715) The project will comply with this An Act to provide for persons with disability, to establish a Act and ensure that there is no National Council on Persons with Disability and to discrimination against disabled provide for related matters. Provisions include the right to persons. Non-discrimination policies a family life and participation in social, creative or will be put in place and enforced, , recreational activities; the prohibition of differentia including ensuring that infrastructure treatment for residential purposes, the right to the same developed are accessible by people living conditions as persons without disability when with disabilities persons with disability are placed in special institutions. No exploitation, abuse, discrimination or disrespect to persons with disability, appropriate facilities when involved in court proceedings; and access to public places. ESIA-MNP, GLRSSMP-EPA PCU, 2025 14 No Legal Framework and Key Compliance Requirement Applicability to Proposed project 18 Hazardous and Electronic Waste Control and Substances hazardous to health such Management Act, 2016 (Act 917) as waste oils and residual chemicals The Hazardous and Electronic Waste and Control Act will be disposed of properly 2016 (Act 917) provides list of hazardous and other waste. It also provides control, management and disposal of electrical and electronic waste. Hazardous waste generally refers to waste with properties that makes it potentially dangerous or harmful to human health or the environment and they include liquids, solids or gases which cannot be treated or disposed of by common mean 19 Hazardous, Electronic and Other Wastes Management of hazardous (Classification) Regulations,2016 (LI2250) waste e.g. chemicals or other toxic The purpose of these Regulations is to (a) regulate the wastes will be guided by the classification control and management of waste: (b) Schedules in LI2250 establish a mechanism and procedure for the listing of waste management activities that do not require a Waste Management Permit; (c) prescribe requirements for the establishment of take-back systems, (d) prescribe requirements and timeframes for the management of wastes listed in the First Schedule; (e) prescribe general duties of waste generators, waste transporters and waste managers; and (f) prescribe requirements for the disposal of wastes 20 Factories, Offices and Shops Act, 1970 (Act 328) Processing facilities will be operated The Act requires all proponents to register every in accordance with this Act. factory/workplace with the Chief Inspector of Factories Accidents/incidents will be captured Inspectorate Division (FID), report accidents, dangerous in the HSE policy. Also, relevant occurrences and industrial diseases, post in a prominent safety notices will be posted at position in every factory the prescribed abstract of the vantage points. Act and other notices and documentations, as well as outlines the regulations to safeguard the health and safety of worker 21 Ghana National Fire Service Act, 1997 (Act 537) Fire incidents are common in Ghana The Ghana National Fire Service (GNFS) Act, 1997 (Act and in the project area so the Fire 537) re- established the National Fire Service to provide Service will be engaged to provide for the management of undesired fires and to make education/ sensitization on fire provision for related matters. The objective of the Service prevention and fighting as part of the is to prevent and manage undesired fire. For the purpose of overall project implementation achieving its objective, the Service shall organise public fire education programmes to create and sustain awareness of the hazards of fire, heighten the role of the individual in the prevention of fire and provide technical advice for building plans in respect of machinery and structural layouts to facilitate escape from fire, rescue operations and fire management. 22 Fire Precaution (Premises) Regulations, 2003 (LI1724) Fire certificates will be obtained for Lovi Research Centre ESIA-MNP, GLRSSMP-EPA PCU, 2025 15 No Legal Framework and Key Compliance Requirement Applicability to Proposed project The Fire Precaution (Premises) Regulations 2003 (LI 1724) requires all premises intended for use as workplaces to have Fire Certificates 23 Child Labour Hazardous Activity Framework, 2021 The project will ensure through the Defines light work permitted to children under the contractors that employment and minimum age of employment and hazardous work hazardous work is prohibited for prohibited to children under 18. children under 18 during constructional activities 2.4 National Environmental Standards The National Environmental Standards provide for permissible levels for ambient air quality, noise levels and effluent quality standards for discharge into natural water bodies. The environmental standards being adopted for this project include; ▪ Ghana Standards for Ambient air quality and point source air emissions (GS1236:2019) ▪ Ghana Standards Environmental Protection - Requirements for Effluent Discharge (GS1212:2019) ▪ Ghana Standards Health Protection - Requirements for Ambient Noise control (GS1222:2018) ▪ Ghana Standards for Environment and Health Protection - Requirements for Motor Vehicle Emissions (GS1219, 2018) Table 2-3: Ghana Standards and their relevance No. Standard Applicability 1 Ghana Standard for Environmental Protection - Effluent from processing Requirements for Effluent Discharge (GS1212, facilities during operation 2019) phase will be managed as Ghana Standard for Environmental Protection - specified in the proposed Requirements for Effluent Discharge (GS1212, ESMP 2019); specifies requirements for sector specific effluent quality and also gives guideline discharge into the environment. ESIA-MNP, GLRSSMP-EPA PCU, 2025 16 2 Ghana Standards for Environment and Health Dust and vehicular emissions Protection -Requirements for Ambient Air Quality will be controlled as specified and Point Source/Stack Emissions (GS 1236, 2019) in the proposed ESMP Ghana Standards for Environment and Health Protection - Requirements for Ambient Air Quality and Point Source/Stack Emissions (GS 1236, 2019) specifies the requirements and methods of analysis for ambient air. It also specifies the requirements and test methods for point source or stack emissions based on the sources of energy. 3 Ghana Standards for Health Protection - Noise generated at both the Requirements for Ambient Noise Control (GS construction and operation 1222, 2018) stages will be monitored as Ghana Standards for Health Protection - stated in the proposed ESMP Requirements for Ambient Noise Control (GS 1222, to ensure it does not exceed 2018) specifies the requirements for acceptable acceptable limits ambient noise levels within categorized locations. According to the Standards, the test method should be in accordance with the relevant test methods given in GS 1253:2018 (Acoustics- Guide for the measurement of outdoor A-weighted sound levels 4 Ghana Standards for Environment and Health Vehicles for transportation of Protection - Requirements for Motor Vehicle materials and workers will Emissions (GS1219, 2018) produce fumes but will be Ghana Standards for Environment and Health managed with regular Protection - Requirements for Motor Vehicle maintenance as stipulated in Emissions specifies the requirements for exhaust the proposed ESMP emissions of motor vehicles as well as tractors, farm equipment, mobile industrial /construction machines (such as excavators) 2.5 Institutional Framework 2.5.1 Ministry of Environment, Science, Technology and Innovation The Ministry is the parent ministry that oversees the activities of the EPA and is responsible for formulating policies aimed at safeguarding the country’s environment and ensuring accelerated socio-economic development of the nation through the formulation of sound policies and a regulatory framework to promote the use of appropriate, environmentally friendly, scientific and technological practices and techniques. Specific medium-term objectives include: ESIA-MNP, GLRSSMP-EPA PCU, 2025 17 • Intensification of the application of safe and sound environmental practices • Development and promotion of a science and technology culture at all levels of society; and strengthening of compliance of human settlements standards in communities. 2.5.2 Environmental Protection Agency The EPA is a statutory body mandated to deal with environmental protection and regulation of environmental issues and its related purposes and it is also an implementing Agency for the GLRSSMP. The EPA coordinates other beneficiary agencies who are part of the implementation and is the main proponent of these subprojects 2.5.3 Wildlife Division of Forestry Commission The Wildlife Division (WD) is one of the three divisions of the Forestry Commission, and it is a beneficiary agency under the GLRSMMP. The mission of WD is to ensure conservation, sustainable management and development of Ghana’s wildlife resources for socio-economic benefit to all segments of society. It has the mandate to conserve wildlife in Ghana in general and manage wildlife protected areas in particular within representative ecological zones of the country. The Division will manage the infrastructure that will be constructed within the Mole National Park and its fringes. It is also relevant to note that the Mole National Park under the WD has an estate and works units that undertakes the development of some works within the park. The Lovi Research Centre for instance was constructed by the unit and will lead in the completion of the centre. 2.6 Relevant World Bank Environmental and Social Standards The World Bank through the development of its Environmental and Social Framework (ESF) set out standards to be applied to an investment. The ten standards replace the former operational policies that guided project implementation. The ten Environmental and Social Standards (ESSs) set out the obligations that a project must comply with throughout its life cycle. Among these, eight (8) are triggered by the project and they are discussed below: ESS 1-assessment and management of environmental and social risks and effects: it calls for an environmental and social assessment that is proportionate to the risks and effects of the Projects to ensure that the Projects are environmentally and socially viable and sustainable. This assessment will serve as a basis for Project design and will help to identify mitigation measures and actions and improve decision-making. ESS 2-Labour and working conditions: it defines, within the framework of the jobs created by the Project, inter alia, conditions for fair treatment and equal opportunity, obligation to prevent the ESIA-MNP, GLRSSMP-EPA PCU, 2025 18 use of forced labour and child labour, to protect and secure Project workers, especially those who are vulnerable such as women, disabled persons, etc., and to ensure that the Project can meet the requirements of the ESS2 ESS 3-Rational Use of Resources, Prevention and Management of Pollution: This standard recognizes that economic activity is often the source of air, water and soil pollution and depletes already limited resources. It calls for 1- Promoting the sustainable use of resources, including energy, water and raw materials; 2- Avoiding or minimizing the adverse effects of the Project on human health and the environment by avoiding or minimizing pollution from Project activities; 3- Avoiding or minimizing emissions of short- and long-lived air pollutants associated with the Project; 4- Avoiding or minimizing the generation of hazardous and non-hazardous waste. ESS 4 Community health and safety of the population: It addresses the risks and effects of the Project on the health, safety and security of Persons Affected by the Project (PAPs), and the Proponent's responsibility to avoid or minimize these risks and effects, with particular attention to vulnerable groups. The proponent is responsible for "1-Preventing or avoiding adverse effects on the health and safety of people affected by the Project throughout the Project, whether in normal or exceptional circumstances; 2-Encouraging the consideration of quality and safety considerations and climate change issues in the design and construction of infrastructure, including dams; 3- Avoid or minimize community exposure to risks related to Project traffic and road safety, diseases and hazardous materials; 4- Implement effective measures to deal with emergency situations; 5- Ensure that the protection of personnel and property avoids or minimizes risks to communities affected by the Project". ▪ Annex 1 of ESS 4: "Dam Safety": It imposes specific safety measures for dams, including the recruitment of independent, experienced and competent professionals to supervise the design and construction of new dams or to inspect and assess the safety level of the existing or under construction dam, their operation and maintenance procedures, and make recommendations for any refurbishment or safety measures necessary to bring the existing or under construction dam to an acceptable level of safety. It is mentioned that "dam safety reports" will have be prepared, ESS 5-land acquisition, land use restrictions and forced resettlement: which is the standard of reference in the event of population displacements necessitated by the Project. ESS 5 advocates the avoidance or, failing that, the minimization of physical or economic displacement through a rigorous and careful study of the various Project design options. Where displacement cannot be avoided, ESS 5 provides the mechanisms for carrying out the process in a participatory manner with a view to achieving peaceful, sustainable and mutually acceptable resettlement and compensation solutions. It also states that displaced populations should receive "prompt compensation for the replacement cost of their property" and that the Project should "help displaced persons to improve, or at least restore in real terms, their livelihoods and standard of living prior to their displacement or prior to the commencement of Project implementation". ESS ESIA-MNP, GLRSSMP-EPA PCU, 2025 19 5 also provides for handling instances of land acquisition where people or communities willingly donate a portion of their land for project purposes, for no compensation or reduced compensation. Voluntary land donations may involve some monetary or nonmonetary benefits or incentives provided to the land donor by the project or by community members benefiting from a project. Both can be broadly classified as a voluntary land donation, because the transfer of assets takes place without payment of compensation at replacement value. Such situations will be considered subject to the World Bank’s Voluntary Land Donation Protocol and prior Bank approval. In any case, the following conditions and requirements, as foreseen in ESS5, should be verified, demonstrated and documented: 1. the potential donor or donors have been appropriately informed and consulted about the project and the choices available to them; 2. potential donors are aware that refusal is an option, and have confirmed in writing their willingness to proceed with the donation; 3. no household relocation is involved; 4. the donor is expected to benefit directly from the project; and 5. for community or collective land, donation can only occur with the consent of individuals using or occupying the land. 6. All family members (including spouses) must be aware of the donation, in order to minimize the risks of women users of the land to be donated being passed over in decision- making on land donation and the risks of cross-generational conflicts being avoided. 7. Individuals using or occupying community or collective lands must also be aware of the donation to minimize risks of settlers or migrants being passed over in decision-making on land donation. 8. The PCU establishes that the land to be donated is free of encumbrances and encroachment and 9. registers the donated land in an official land registry (i.e., the Lands Commission in this case) 10. Any donated land that is not used for its agreed purpose is returned to the donor by the PCU in collaboration with the Lands Commission. 11. The PCU will decide, when necessary, whether the land donated is no longer needed for the intended purpose of the project. 12. a transparent record of all consultations and agreements reached is kept by the PCU. 13. There is documentation of the land indicating clearly, the size, the location/situated, and signatories of the parties (consent). ESS6 recognizes the importance of maintaining core ecological functions of habitats, including forests, and the biodiversity they support. Habitat is defined as a terrestrial, freshwater, or marine geographical unit or airway that supports assemblages of living organisms and their interactions with the non-living environment. All habitats support complexities of living organisms and vary in terms of species diversity, abundance and importance ESS 8 on cultural heritage: to be considered if a cultural heritage site is present in the Project area. It sets out general requirements relating to the consideration of cultural heritage as an ESIA-MNP, GLRSSMP-EPA PCU, 2025 20 "integral aspect of sustainable development", and its protection (both tangible cultural heritage, such as natural elements, and intangible cultural heritage such as beliefs, traditions, practices, representations, skills, etc.). Cultural heritage will need to be identified and inventoried through in-depth consultations with communities. Its protection during both the construction and operational phases must be a priority of any Project. ESS 10: Stakeholder Engagement and Information Disclosure: This standard recognizes the importance of open and transparent collaboration between the Borrower and Project stakeholders as an essential element of good international practice. It is recommended that : 1- Establish a systematic approach to identifying and mobilizing stakeholders that will enable a constructive relationship to be established and maintained with them, particularly those affected by the Project; 2- Assess the level of interest and commitment of stakeholders and allow their opinions to be taken into account in the design of the Project and its environmental and social performance; 4- Ensure that stakeholders receive timely, understandable, accessible and appropriate information on the Project's environmental and social risks and effects A gap analysis of national regulation as compared with the ESS is presented in table 2-4 covers ESS1, ESS2, ESS3, ESS4, ESS5, ESS6, ESS8, and ESS10. The columns describe the scope and objectives of the aforementioned ESS’s, description of WB policies, description of government regulation, identified gaps and how these gaps will be addressed during project implementation. ESS7 and ESS9 are not relevant to this project. ESIA-MNP, GLRSSMP-EPA PCU, 2025 21 Table 0-4 : Gap Analysis – Comparison of Ghana’s Regulations/Policies and World Bank ESF for Handling Environmental and Social Risks Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation ESS 1: Assessment and Management of Environmental and Social Risks and Impacts - identify, The standard Environmental Even though the - Assistance evaluate and provides Assessment. regulation seeks /compensations are manage the guidance on Regulation 1 (2) of to anticipate and provided for the environment and assessing the LI 1652 mandates mitigate/avoid affected parties by social risks and Project’s that no person risks and government through impacts of the potential shall commence an impacts, it does the district and project in a environmental undertaking which not fully address municipal manner and social risks in the opinion of potential impacts assemblies at consistent with and impacts and the Agency has or and mitigation various project the ESSs. addressing is likely to have hierarchy locations. - To adopt a potential impacts adverse effects on approach e.g. - The MDAs were mitigation through planning the environment or content wise it fully involved in the hierarchy and mitigation public health does not address project preparatory approach to: hierarchy unless, prior to the impacts on the stage through (a) Anticipate approach. commencement, vulnerable consultations for and avoid risks the undertaking them to become and impacts has been registered abreast with project (b) Where by the EPA and an components roles avoidance is not environmental they will play possible, permit has been during minimize or issued by the implementation. reduce risks and Agency in respect - The capacities of impacts to of the undertaking. the MDAs staff on acceptable levels; world bank ESF (c) Once risks will also be built at and impacts have the early stage of been minimized project or reduced, implementation to mitigate; and enable them (d) Where collaborate significant effectively in residual impacts addressing this gap remain, compensate for or offset them, where technically and financially feasible. ESS2: Labour and Working Conditions ESIA-MNP, GLRSSMP-EPA PCU, 2025 22 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation - To promote ESS2 promotes - The Labour Act The Ghanaian -The project will safety and health the fair 2003 (Act 651) laws do not adopt and enhance at work, fair treatment, non- provides for the explicitly or and existing treatment, non- discrimination rights and duties of specifically transparent GRM discrimination and provision of employers and consider which addresses and equal equal workers; legal or protection of concerns promptly opportunity of opportunities for illegal strike; vulnerable group - It has also project workers workers engaged guarantees trade and prevention developed labour including on projects it unions the freedom of all forms of management vulnerable supports. It of associations and forced and child procedures e.g. workers such as strongly establishes Labour labour. working conditions, women, persons encourages Commission to - it does not occupational health with disabilities, protection of all mediate and act in provide for and safety, child children project workers, respect of all grievance labour etc. (section - To prevent the including labour issues. mechanism that 5.4) which will use of all forms of vulnerable Under Part XV addresses guide project forced labour groups such as (Occupational concerns implementers in and child labour. women, persons Health Safety and promptly and managing labour • To support the with disabilities, Environment), the transparent related issues. For principles of children (of Act explicitly process that instance, in to avoid freedom of working age) and indicates that it is provides timely child labour the association and migrant workers, the duty of an feedback acceptable age will collective contracted employer to ensure be 18 years and the bargaining of workers and the worker works The minimum Ghana 2010 risks project workers primary supply under satisfactory, age for light assessment in a manner workers, as safe and healthy work is lower in technique of child consistent with appropriate. It conditions. Ghanaian labour monitoring national law. • To provides certain - The Workmen's legislation than (CLM) described provide project requirements that Compensation the standard set under (section workers with the project must Law 1987 (PNDC in ESS2. 5.4.4) will also be accessible means meet in terms of 187) seeks to observed to ensure to raise working address the - Currently that labour workplace conditions, necessary Ghana does not management concerns. protection of the compensations have a national procedures in work force needed to be policy on respect of child (especially the awarded to occupational labour is respected. prevention of all workers for health and safety forms of forced personal injuries The 3 main and child labour), arising out of and regulations that and provision of in the course of deals with OHS a grievance their employment issues are mechanism that Ghanaian Factories, Offices addresses legislation defines and Shops Act concerns on the the minimum age 1970, (Act 328), project promptly for light work to Workmen's ESIA-MNP, GLRSSMP-EPA PCU, 2025 23 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation and uses a 13, minimum age Compensation Law transparent for employment to 1987 (PNDC 187) process that 15 and minimum and the Labour Act provides timely age for hazardous 2003 (Act 561), feedback to those work to 18 years have regulations concerned. ESS2 that deal with defines the health and safety minimum age for management at the work to 14 years, work environment. unless national OHS issues are standards set a regulated by the higher age, and Department of the minimum age Factories for hazardous Inspectorate of the work to 18 years Ministry of Employment and Labour Relations (MELR). The project will work closely with the department to ensure that issues on OHS are dealt with to meet standards set out in the ESS2 ESS3: Resource Efficiency and Pollution Prevention and Management To achieve the The ESS3 The Act 490 The regulation The Project has sustainable use of provides mandates the ensure that developed a pest resources, requirements for EPA to enforce measures are put management plan including energy, projects to compliance with in place by (PMP)to be water and raw achieve the established EIA polluters through implemented materials, as well sustainable use of procedures routine holistically by all as implement resources, among monitoring by implementing measures that including energy, companies and regulatory Agencies i.e. avoids or reduces water and raw businesses in the agencies and MOFA, EPA and pollution materials, as well planning and institutions i.e. FC to ensure that resulting from as implement execution of EPA, WRC etc. pesticides use is project activities measures that development it does not reduced to the and to minimize avoids or reduces projects, address the risks barest minimum and manage the pollution including existing associated with whilst promoting risks and impacts resulting from projects. the use of integrated pest associated with project activities. - Part II of the Act pesticides by management pesticide use. The standard also mandates the prospective users techniques. places specific Agency to register ESIA-MNP, GLRSSMP-EPA PCU, 2025 24 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation consideration on and manage all hazardous wastes pesticides to or materials and ensure that the air emissions approved ones are (climate used. pollutants) given - There are also that the current national standards and projected for wastewater atmospheric discharges and concentration of ambient air and greenhouse gases noise quality. (GHG) threatens These are: the welfare of 1. Ghana standards present and for environmental future lives. protection and health requirement for effluent discharges, GS1212, 2019 2. Ghana standards for environmental protection and health requirement for ambient air quality and dust/point source emissions GS 1236, 2019 3. Ghana standards for environmental protection and health requirement for ambient noise control GS1222, 2018 4. Ghana standards for acoustic guide for measurement of outdoor weighted sound level, GS1253, 2018 5. Ghana standards for environment and health ESIA-MNP, GLRSSMP-EPA PCU, 2025 25 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation protection requirement for motor vehicle emissions GS1219, 2018 ESS4: Community Health and Safety - To anticipate This standard The Public Health The regulation The law provides and avoid recognizes that Act, 2012, Act 851 does not the platform to adverse impacts project activities, revises and consider engage with on the health and project consolidates all the assessment of stakeholders and safety of project equipment and laws and events and with the stakeholder affected infrastructure regulations measures to deal engagement plan in communities increase the pertaining to the with occurrences place for project during the exposure of prevention of and emergencies implementation project life-cycle project disease, promote, community needs from both stakeholder safeguard and with respect to routine and non- communities to maintain and project activities routine various health, protect the health will be assessed and circumstances. safety and of human and necessary measures - To promote security risks and animals, and to taken. The national quality and impacts and thus provide for related disaster safety, and recommends that matters. The law management considerations projects has merged all organisation relating to implement provisions in the (NADMO) and climate change, measures that criminal code, Ghana National in the design and avoids or limits ordinances, Fire Service are construction of the occurrence of legislative and represented in the infrastructure, such risks. It executive zonal TCOs and including dams. provides further instruments, acts, have the - To ensure that requirements or bye-laws of the responsibility to safeguarding of guidelines on District deal with personnel and managing safety, Assemblies etc. emergency issues property is including the The Act enjoins e.g. bushfires, carried out in a need for projects the provision of flooding etc. manner that to undertake sanitary stations avoids or safety assessment and facilities, minimizes risks for each phase of destruction of to the project- the project, vectors including affected monitor incidents mosquitoes, communities. and accidents and protection of water preparing regular receptacles and the reports on such promotion of monitoring. environmental ESS4 also sanitation. provides ESIA-MNP, GLRSSMP-EPA PCU, 2025 26 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation guidance on emergency preparedness and response. ESS5: Land Acquisition, Restriction on Land Use and Involuntary Resettlement -To avoid ESS5 recognizes No constitutionally Bank Policies The Project by involuntary that project or legislatively provide for design do not resettlement or related land recognized compensation anticipate any form when acquisition and resettlement rights for all category of displacement unavoidable, restrictions on or assistance for of land users (physical or minimize by land use can those without Ghanaian laws economic) in exploring project have adverse recognized do not. implementing its design impacts on (formal) rights to activities. For lands alternatives communities and land donated for - To avoid forces persons. For community eviction those without infrastructure, the - To mitigate formal rights to proponent will unavoidable lands or claims conduct due adverse social to such land that diligence in and economic could be accordance with the impacts from recognized under World Banks’s land acquisition the laws of the Voluntary Land or restrictions on country, the Donation Protocol; land use. government secure the World should provide Bank’s clearance to resettlement accept the assistance in lieu donations; draft an of compensation ESS 5-complaint for land to help land agreement, livelihoods discuss agreement improve or at with the traditional least restore authorities in those affected charge of land; person. explain content of Implement all agreement to the relevant community resettlement members, and then plans before execute the project agreement between completion and the proponent and provide the traditional resettlement authorities entitlements responsible for before land. ESIA-MNP, GLRSSMP-EPA PCU, 2025 27 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation displacements or restriction of access. ESS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources - To protect and ESS6 promotes The 1994 Forest All national laws The project conserve the conservation and Wildlife relate to implementing biodiversity and of biodiversity or Policy was revised protection and agencies in habitats. • To natural habitats in 2011 and management of collaboration with apply the and supports the subsequently forest and PCU will take mitigation protection and approved in 2012 wildlife and not measures to protect hierarchy and the maintenance of aims at the biodiversity and conserve precautionary the core conservation and holistically biodiversity and approach in the ecological sustainable habitats and all design and functions of development of requirements implementation natural habitats forest and wildlife specified in the of projects that and the resources for the ESS6 could have an biodiversity they maintenance of impact on support. environmental biodiversity. It also stability and - To promote the encourages continuous flow of sustainable projects to optimum benefits management of incorporate into from the socio- living natural their cultural and resources. development, economic goods - To support environmental and services that livelihoods of and social the forest local strategies that environment communities, address any provides to the including major natural present and future Indigenous habitat issues, generations, whilst Peoples, and including fulfilling Ghana’s inclusive identification of commitments economic important natural under international development, habitat sites, the agreements and through the ecological conventions. adoption of functions they Ghana has ten practices that perform, the other regulations integrate degree of threat on fest (refer to conservation to the sites, and annex…..) but they needs and priorities for are established to development conservation. manage forests priorities. ESS8: Cultural Heritage ESIA-MNP, GLRSSMP-EPA PCU, 2025 28 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation - To protect This standard The Fourth The regulations The National cultural heritage sets out general Republican and policies do commission on from the adverse provisions on Constitution not address culture provides a impacts of cultural heritage (1992) recognizes cultural heritage platform for project activities preservation and culture as a as an integral collaboration with and support its recommends necessary tool for part of Chiefs, opinion preservation. protecting national sustainable leaders and - To address cultural heritage integration and development and community cultural heritage from the adverse development and, promotion of representatives and as an integral impacts of under the Directive equitable sharing other institutions to aspect of project activities. Principles of State of benefits protect cultural sustainable It addresses Policy (Article assets. The project development. physical or 39), declares as will go by the - To promote tangible cultural follows: procedures outlined meaningful resources, which “(1) Subject to by the Commission consultation with are defined as clause (2) of this in respect of stakeholders movable or article, the State cultural assets. The regarding immovable shall take steps to project will also go cultural heritage. objects, sites, encourage the extra mile to - To promote the structures, groups integration of complement this equitable sharing of structures, and appropriate collaboration with of benefits from natural features customary values stakeholder the use of and landscapes into the fabric of engagement cultural heritage. that have national life procedures archaeological, through formal and enshrined in the paleontological, informal education SEP to educate historical, and the conscious communities to architectural, Introduction of appreciate the role religious, cultural of cultural values aesthetic, or dimensions to and assets in other cultural relevant Aspect of sustainable significance. national planning. development and Physical cultural (2) The State shall also the need to resources may be ensure that share benefits in urban or rural appropriate accruing from the settings, and may customary and use of cultural be above or cultural values are assets. below ground, or adapted and underwater. It developed as an also addresses integral part of the intangible growing needs of cultural heritage the society as a such as practices, whole; and in representations, particular, that expressions, traditional ESIA-MNP, GLRSSMP-EPA PCU, 2025 29 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation instruments, practices which are objects and injurious to the cultural spaces health and well- that communities being of the person recognize as part are abolished. of their cultural (3) The State shall heritage. Projects foster the involving development of significant Ghanaian excavations, languages and demolition, pride in Ghanaian movement of culture. earth, flooding, - The Ghana or other cultural policy environmental (2004) enjoins the changes are to National take cognizance Commission on of this standard Culture to in the ESMF. undertake the following actions to protect and preserves monument, forests reserves, national parks and recreational facilities ESS10: Stakeholder Engagement and Information Disclosure - To establish a ESS10 seeks to The key laws most The national - The project has systematic encourage open relevant to regulations and developed a approach to and transparent stakeholder policies do not stakeholder stakeholder engagement engagement are: have structures Engagement Plan. engagement that between the - Article 21(1) (f) through which The SEP also will help Borrower and the of the 1992 grievances could includes a GRM Borrowers project Constitution of be addressed and based on an existing identify stakeholders Ghana which mechanisms to grievance redress stakeholders and project-affected recognizes the disclose or mechanism for build and parties) right to disseminate resolving maintain a throughout the information for all information to grievances for the constructive project life cycle. citizens as a the required Sustainable Land relationship with The standard fundamental audiences and Water them, in establishes a human right. To Management particular systematic fully Project (SLWMP). project-affected approach to operationalize the ESIA-MNP, GLRSSMP-EPA PCU, 2025 30 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation parties. To stakeholder right to The GRM is a assess the level of engagement that information, decentralized and stakeholder potentially helps people need to be transparent system interest and the Borrower to effectively which ensured support for the identify engaged and quick resolution of project and to stakeholders and provided with complaints and enable build and information on disputes, it also has stakeholders’ maintain a issues that affect the structure for views to be taken constructive their lives. disclosing vital into account in relationship with - The Right to information to project design them, as well as Information Act, requisite and disclose 2019 (Act 989), stakeholders environmental information on which was also - It also provides and social the passed into law in means for effective performance environmental 2019 by Ghana’s and inclusive - To promote and and social risks parliament is engagement This provide means and impacts to meant to put into instrument which for effective and stakeholders in a effect the satisfy almost all inclusive timely, aforementioned the requirements of engagement with understandable, article in the ESS 10 will project-affected accessible and constitution of the jealously be applied parties appropriate Republic of during project throughout the manner and Ghana. implementation to project life-cycle format. It bridge the gaps in on issues that recommends that - Articles 40 to 48 national regulations could potentially stakeholder of the Local and policies affect them. engagements are Governance Act, - To ensure that commenced as 2016 (Act 936), appropriate early as possible mandate local project in the project authorities to information on development create environmental process and opportunities for and social risks continued residents and other and impacts is throughout the stakeholders to disclosed to lifecycle of the access information stakeholders in a Project. This and to participate timely, allows for in decision understandable, stakeholders’ making. accessible and views to be appropriate considered in the - Stakeholder manner and project design engagement is an format. and integral part of the - To provide environmental Environmental project-affected and social Impact parties with performance. Assessment ESIA-MNP, GLRSSMP-EPA PCU, 2025 31 Scope/Objective Description of Description of Gaps Identified Gap Bridging Bank Policy Government of Actions Ghana Regulation accessible and The Borrower is process. Ghana inclusive means also expected to Environmental to raise issues implement a Assessment and grievances, grievance Regulation LI and allow mechanism to 1652 (1999), as Borrowers to receive and amended (2002), respond to and facilitate requires effective manage such resolution of public consultation grievances. concerns and and participation grievances. as an integral component of Environmental and Social Impact Assessment (ESIA) procedures - Strategic goal 4 of the National Environmental Policy, which focuses on participation and coordination in environmental governance, charges the lead institutions in environmental governance to ensure active participation in all environmental matters. ESIA-MNP, GLRSSMP-EPA PCU, 2025 32 2.7 World Bank Environment, Health and Security Guidelines (EHSGs). The Environmental, Health and Safety (EHS) Guidelines are technical reference documents that address IFC’s expectation regarding the industrial pollution management performance of projects. This information supports actions aimed at avoiding, minimising, and controlling EHS impacts during the construction, operation, and decommissioning phase of a project or facility. In the context of the proposed project, the most relevant EHS Guidelines to be considered are: • World Bank Group General EHS Guidelines (2007); • World Bank Group EHS Guidelines for Construction Materials Extraction (2007) Guidance provided in the General EHS Guidelines will be applicable in the areas of environment, occupational Health and Safety, Community Health and Safety, and Construction and Decommissioning. Section four of the General EHS Guidelines focuses on construction and decommissioning of infrastructure. During the construction through to the decommission phase, cognizance will be taken of the specific directives for construction and align mitigation of risk and impact measures alongside with the specific performance indicators. Key issues to be considered include the following a. Environment • Noise and Vibration • Soil Erosion • Air Quality • Solid Waste • Wastewater Discharges b. Occupational Health and Safety c. Community Health and Safety • General Site Hazards • Disease Prevention • Traffic Safety International Conventions and Requirements Healthy ecosystems and forests play an important role in the resilience of local communities. Sustainable forest management and access to services and benefits from forests and wildlife PAs can help vulnerable communities better absorb and adapt to the impacts of shocks and stressors, among them climate change. Ghana’s NDC to the Paris Climate Agreement place a strong emphasis on adaptation to ensure that all people and communities are resilient to climate impacts. ESIA-MNP, GLRSSMP-EPA PCU, 2025 33 Sustainable land use, including food security and sustainable forest management have been identified as two priority sectors in the NDC. Table 2-5 below summarizes the international and regional treaties, conventions and protocols to which the Government of Ghana is a signatory and identifies those aspects of the Project where they may be relevant. Table 0-5: International Treaties, Conventions and Protocols Applicable to Project Treaty/Convention/ Objective Relevance to the Project Protocol Convention on Preserving and sustaining biological diversity. Biodiversity studies and Biological Diversity management/preservation (CBD) (1992) Convention on An international regime for the protection of Biodiversity studies and Migratory Species migratory animals and their habitats, and the management of migratory (CMS) of Wild prevention, reduction and control of factors that species of wild animals. Animals (1983) endanger them. Convention on To conserve and protect the wise use of The project will ensure that Wetlands of wetlands through local, regional and national contractors during International actions and international cooperation. construction works and other Importance especially operations (carting of scooped as Waterfowl Habitat earth) for waterholes sites (Ramsar Convention) close to wetlands are well (1993) managed to preserve them to augment water volumes of these water systems. Vienna Convention Protection of the Ozone Layer Compliance with standards for the Protection of and protocols by limiting the Ozone Layer biodiversity destruction during construction activities and use of obsolete equipment. United Nations The reduction of negative changes to the earth’s Manage GHG emissions Framework climate, with focus on greenhouse gases. Places associated with the Project. Convention on focus on industrialized countries to reduce Climate Change emissions. Developing countries like Ghana are (1992) currently exempt from the reduction requirement; however, this may change Convention The Convention encourages that employers in Project occupational health Concerning the consultation with their workers understand and safety Protection of Workers project hazards related to air pollution, noise Against Occupational pollution, and vibrations ESIA-MNP, GLRSSMP-EPA PCU, 2025 34 Hazards in the Working Environment due to Air Pollution, Noise, and Vibration (ILONo.148) Convention on the Provides the standards for protecting children The project will protect Rights of the Child from all forms of exploitation and abuse children from exploitation and (CRC) abuse ILO Conventions 182 Defines and prohibits the worst forms of child The project will ensure age and 138 labour, and defines the minimum age for light verification of workers and work and employment. that child labor is prevented, and in case identified, is remediated in accordance with standards set in the CRC and the Children’s Act, 1998 Amended in 2016 (Act 937) . African Convention The objectives of this Convention are: to This project is providing a on the Conservation enhance environmental protection; to foster the number of interventions that of Nature and Natural conservation and sustainable use of natural would promote conservation Resources resources; and to harmonize and coordinate and the sustainable use of policies in these fields with a view to achieving natural resources. ecologically rational, economically sound and socially acceptable development policies and program Universal Declaration The law provides for the promotion of respect Employment (conditions of on Human Rights for rights and freedoms and for progressive engagement, safety of work national and international measures to secure environment, etc.) or the effective recognition and observance among management of labour issues people of signatories themselves and among the and protection of worker territories under their jurisdiction. Key welfare would be promoted provisions include: during project activities. Article19: Everyone has the right to freedom of opinion and expression. Article 20: (1) Everyone has the right to freedom of peaceful assembly and association. (2) No one may be compelled to belong to an association. Article 24: Everyone has the right to rest and leisure, including reasonable limitation of working hours and holidays with pay ESIA-MNP, GLRSSMP-EPA PCU, 2025 35 Arhaus Convention Protection of the right of present and future Enhance Project information on Public Access to generations to live in an environment adequate disclosure, public consultation Information and to their health and well-being. Each party would and stakeholder engagement Participation in promote the rights of access to information, for the Project Decision Making and public participation in decision-making and Access to Justice in access to justice in environmental matters in Environmental accordance with the provision of this Matters (1998) Convention. ESIA-MNP, GLRSSMP-EPA PCU, 2025 36 3.0 PROJECT DESCRIPTION AND ALTERNATIVES 3.1 Proposed Civil Works The specific civil works for which this ESIA Studies covers are Civil Works in, and around the Mole National Park (MNP) in the West Gonja, Sawla-Tuna-Kalba, Mamprugu-Moagduri, and Wa East Districts (see figure 3-1) of the Savannah and Upper West Regions. They include the following: • Water Hole (Jang beat) • Viewing Platform (Asibey Pond) • Water Hole (Grupe) • Complete and operationalize Field Research Centre in MNP • Construction of Tree Hides, Camping Sites at Brugbani, Directional Signage and medium/long Range Foot Safari trails (km) with rest stops (camping sites) • Dugout (Livestock watering) at Jang • Dugout (Livestock watering) at Dabore • Dugout (Livestock watering) at Chassie • Shea processing facilities at Larabanga and Soma The proposed interventions may have both positive and negative environmental and social impacts and therefore environmental and social due diligence is to be conducted in accordance with national Environmental Assessment Regulations (LI 1652) and relevant World Bank Environmental and Social Standards 3.2 Description of Proposed Works Locations The proposed civil works project listed above will be located in the Mole National Park and some of its fringe communities. Table 3-1: Civil Works in/around MNP and Site Characteristic S/N Site/Community District Civil works Site Characteristics 1. Mole National Park West Tree Hide The site is in the park and Gonja generally slopes towards the south 2. Mole National Park West Water Hole (Jang beat) Generally flat and Gonja waterlogged 3. Mole National Park West Game Viewing Platform Generally flat with patches Gonja (Asibey Pond) of vegetation ESIA-MNP, GLRSSMP-EPA PCU, 2025 37 4. Mole National Park West Water Hole (Grupe) The site close to an Gonja existing drain (Grupe stream) 5. Mole National Park West Complete and operationalize The current state is an Gonja Field Research Centre in existing uncompleted MNP structure 6. Mole National Park West Tree hides, Camping Sites at The sites are flat with trees Gonja Brugbani, Directional and shrubs Signages and medium/long Range Foot Safari trails (km) with rest stops (camping sites) 7. CREMA Sawla Dugout (Livestock watering) The land is bare, with Community/Jang Tuna sparse shrubs, and drained Kalba by the Henag Conbre Stream 8. CREMA Sawla Dugout (Livestock watering) The site has an existing Community/Dabore Tuna dugout surrounded with Kalba vegetation 9. Agricultural Wa East Dugout (livestock watering) The site is a fallow land Landscape/Chassie about a kilometre away from the community, generally flat with sparse vegetation 10. Larabanga (fringe West Shea processing facility The area is flat with shrubs community of MNP) Gonja and few trees and close to the community 11. Soma (fringe Sawla- Shea processing facility The site is flat and about 50 community of MNP) Tuna- meters away from the main kalba road with shrubs and few trees. . ESIA-MNP, GLRSSMP-EPA PCU, 2025 38 Figure 3-1: Mole National Park and its fringe Districts ESIA-MNP, GLRSSMP-EPA PCU, 2025 39 3.3 Description of Project Civil works 3.3.1 Water Systems A total of five (5) water systems (three dugouts and two water holes) will be constructed. The design will have the minimum depth required to render a water point permanent and can vary according to its size and circumstance, but for small to medium sized water points, the depth must be at least 4 m deep in order to support the loss of depth and volume due to seepage and evaporation, the consumption by animals that will concentrate around the water hole and provide residual depth of at least 50 cm in order to avoid the growth of algae that renders the water unwholesome for animals at the end of the dry season. The dugout will be an optimized type, as described under section 3.5.1.2 of this report. Processing Facilities Two shea processing facilities will also be constructed at Larabanga and Soma, both of which are fringe communities of the MNP. The processing facilities consist of buildings that house the processing machines. The facility will be multi-purpose that is can be used for groundnut and shea. The facilities will be powered by electricity. An artistic impression of the facility including other facilities is attached to this report as appendix 5. 3.3.2 Game Viewing Platforms The Wildlife Division has an existing Game Viewing Platforms (See figure 3-2 below) at Gbele Resource Reserve and Mole National Park which are designed with the following technical details and would serve as a guide to improve those to be constructed within the Mole National Park under the GLRSSMP a. Reinforced Concrete Structure b. Height is at about 4.5 meters c. The structure’s platform is about 6 meters high. d. A meeting area made of concrete stools (to be used by the Forest Guards and guests) The proposed platforms to be constructed will have the following features to allow tourist/guest who may be interested in wildlife viewing, photography and at the same time environmentally friendly to have the maximum satisfaction a. Structure to be between 4.5 meters and 6.0 meters b. Power Supply from Solar Cells c. Rainwater harvesting with reasonably sized holding tanks d. A borehole would be done to complement water supply during the dry season. e. Sanitary facilities for Forest Guards and Guests f. Good seating Facilities to enable meetings for Forest Guards and Guests g. Facilities to enable photography. ESIA-MNP, GLRSSMP-EPA PCU, 2025 40 Figure 3-2 : Existing Game Viewing Platform at Mole 3.3.3 Campsites These will be a fairly flat area with basic facilities such as platforms for tents, ablution facilities, chapel facilities, water, and rest benches to be used by tourist who intend to stay in tents / open instead of using the available lodges. 3.3.4 Completion of Existing Lovi Research Centre at Mole The Research Centre Project is at the roof stage (See Figure 3-4 below). It is completed with double leaf brick walls. The Lovi Research Centre (LRC) is an initiative of the Wildlife Division of the Forestry Commission to establish an ultra-modern research facility within the Mole National Park (MNP) to facilitate the implementation of research that contributes to effective and practical conservation and management of ecosystems, wildlife, habitat and biodiversity in MNP, its fringe areas and the savannah ecological zone as a whole. Initial funding was from the Italian Ministry of Foreign Affairs and Development Cooperation and implemented by Ricerca e Cooperazione (RC), the Wildlife Division and the University della Tuscia between 2012 and 2016. The GLRSSMP proposes to complete and operationalized the facility to achieve the expected objectives. The following works will be done as part of the operationalization: a. Reorienting the walls for the washrooms to bring in a lot more natural lighting. b. Re-design the honeycomb wall to increase lighting intensity into the internal spaces. ESIA-MNP, GLRSSMP-EPA PCU, 2025 41 c. Complete external and internal plumbing and electrical layout. d. Complete furnishings for the centre. Figure 3-0 : East and West Wing-Inner Corridors of the Lovi Research Centre-27/01/2024 West Wing -Inner Corridors of the Lovi Research centre- East Wing-Inner Corridors of the Lovi Research Centre 3.4 Labour Requirements The Contractor for each of the facilities shall employ the key personnel and use the equipment identified in its Bid, to carry out the works or other personnel and equipment approved by the Project Manager. The Project Manager shall approve any proposed replacement if key personnel and equipment only if their relevant qualifications or characteristics are substantially equal to or better than those proposed in the Bid. The contractor will employ unskilled labour from the beneficiary communities/fringes around the Mole National Park in order to reduce cost of accommodation and transportation which will be incurred if such labour are hired from outside the community as well as create some employment opportunities which will improve their livelihoods Table 3-2 : Workforce estimates for sub-projects Construction Activity Estimated No. of Workers Dugout 12 Game Viewing Platform 7 Processing Facility 10 Camp Sites 6 Lovi Research Center completion 10 Total 45 ESIA-MNP, GLRSSMP-EPA PCU, 2025 42 3.5 Alternatives Considered The Ghanaian EA Regulations LI 1652 of 1999 require the provision of an outline of the main alternatives considered with the main reasons for the choice selected. This section provides a full description of the process followed to select the proposed preferred activity, technology, site and location within the project site, including details of all the alternatives considered In order to achieve the goals and objectives of the GLRSSMP, alternatives analysis of the proposed investments that would meet the expected objective developing the infrastructures have been considered. As part of the alternative analysis of the proposed investments the following were considered: ▪ location/site, ▪ design, ▪ technology/resource management strategy and ▪ Operational alternatives vis-à-vis baseline information. ▪ No action scenario 3.5.1 Identified Alternatives 3.5.1.1 Location/Site Analysis Water Systems The water systems will be located in the Mole National Park and its fringe communities. Evaluations have been made to evaluate and propose the actual location of each site, choose, confirm or re-select the best-fit model that may be proposed for that specific site and determine precisely the site’s physical characteristics such as soils and dimensions of the drainage. For sites of optimized dugouts and the river weir, the drainage characteristics such as the size of the drainage basin, average rainy-season flows, 5-year, 10-year and 50-year peak flows have been calculated, the width and height of the spillway and of the freeboard between the spillway level and the dike have been calculated so that the structure will accommodate the highest flows without endangering the structure’s integrity. These parameters were critical in selecting the site. The siting of the water holes in the park were based on tourist optimization i.e. close to the viewing platforms where more wildlife will congregate. ESIA-MNP, GLRSSMP-EPA PCU, 2025 43 3.5.1.2 Design Analysis Water Systems The different models for construction of waterholes range from cleaning and deepening old natural ponds that are no longer permanent, digging new artificial ponds or dugouts, constructing small dams that will provide substantial depth and volumes of water as well as develop community fishing, larger dams for community areas, as well as in Protected Areas (PA) where biodiversity conservation considerations can be important, to weirs and spillway dikes across seasonal rivers. The following options were considered for the various site 1. “Cleaned� dugouts: in the national parks where ecological and touristic considerations are important (dumping excavated earth away from the dugout so as to avoid: 1) transport back into the pond by rain or elephant, 2) carnivores on the earth-pile ambushing drinking animals, and 3) the unseemly pile of earth with an “unfinished� look, inimical to international tourism). This model is 4 m deep, 50 m wide at the surface and 10 m wide at the bottom, with 20% (1/5) slopes that permit wildlife to descend to drink as the water level reduces during the dry season, and at the beginning of the dry season retains about 3,570 m3 of water. This option is selected for the water holes in the park. 2. “Optimized� dugouts: in community areas to provide the most cost-efficient structure for water supplies that will be adequate for multiple community uses of cattle watering, fishing and/or gardening, where the full potentials of given sites can be attained through the use of relatively low but wide bulldozer-packed dikes to impound and send the outlet flow over a laterite shield lining the drainage that can serve as a natural and inexpensive anti-erosion structure. This option will be used for the dugout in the fringe communities 3. “Non-cleaned� dugouts: (earth classically piled to the side of the dugout) in community areas where none of the local drainages fit the profile required for optimization. As an alternate model for the same cost as an optimized dugout where the terrain is not conducive to an optimized dugout, the average non-cleaned dugout will be designed to provide at least 6,000 m3 of water. This model may be used as a secondary option for the optimized dugout in fringe communities Game Viewing Platforms The main alternatives considered for the design of the platforms are the materials and the height. Options for the material was either a concrete or wooden structure. Each of these have their merits whiles the concrete is economically expensive, it will last longer than a wooden structure though cheaper due to the temperature conditions. The option selected was therefore a concrete platform ESIA-MNP, GLRSSMP-EPA PCU, 2025 44 with stone cladding or a suitable paint to blend with the environment. The choice for this option was also based on its durability compared to old existing wooden structures which are out of use at the moment. The height alternative was based on structural integrity and most importantly tourist ability to view game. The optimum height selected that will not be too short or too tall was 4.5m. Shea/Groundnut Processing Facilities The main alternatives considered for the design of the housing for the processing facility are the materials and the purpose for the use of the processing machine. The option for the material was either sand block or bricks. The use of each of these materials have their merits, whilst the bricks may be expensive there will be no need to paint the structure. The use of the processing machine could be single purpose i.e. for processing of shea only or multi-purpose i.e. processing of shea and other cereals. Even though the multi-purpose facility will be more expensive beneficiaries will derive more benefits and this was selected as the best option. 3.5.1.3 Technology/Resource Analysis Water Systems Two bulldozers will be used at each site at the same time. Another possible measure to accelerate the construction of the proposed water facilities will be to bring in and use more than 1 bulldozer at each pond or dugout. This would also help to continue the cadence if a machine breaks down (as some inevitably will, needing to be as rapidly as possible repaired or replaced). 3.5.1.4 Do-Nothing Alternative Among the goals of the GLRSSMP is to strengthen integrated natural resource management and increase benefits to communities in targeted savannah and cocoa forest landscape. It is evident that doing nothing with respect to the proposed civil works in and around the Mole National Park will not bring about the expected socio-economic development and improvement in wildlife as well as boosting ecotourism. There will be significant negative effects on biodiversity, communities will be deprived of the expected benefits, an outcome much worse than the impacts of the proposed projects activities such as the dugout and game viewing platforms. The do-nothing alternative is therefore not an option. ESIA-MNP, GLRSSMP-EPA PCU, 2025 45 4.0 ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION 4.1 Introduction Mole National Park is the largest national park in Ghana and has the widest range of wildlife. The park was established in 1958 and gazzeted in 1971. It has a total land area of 4,577 square kilometres. It is the most tourists attracted park of the four to be covered by the project with an annual average of eighteen thousand (18,000) tourists. Figure 4-3 : Boundary & Core Area and Buffer zone Maps 4.2 Climate The average temperature in Mole National Park is about 28°C. In December, the average temperature can fall to 26°C, and can rise up to 31°c in March. The dry season usually lasts from November till March, with average temperatures falling as low as 26°C and rising as high as 31°C in March. The rainy season usually lasts from April to October, and the vegetation is lush during ESIA-MNP, GLRSSMP-EPA PCU, 2025 46 this period. Individual temperatures are highest in March and April, sometimes reaching into the 40°c. The dry harmattan winds may blow between December and February, bringing dusty, hazy weather. According to the MNP Management Plan of 2005, the average annual rainfall in Mole National Park is 1,100 mm, decreasing to 1,000 mm in the north of the park. The relative humidity in the Park reaches 90% at night in the rainy season, and falls to about 70% in the afternoons. In the dry season, the figures are 50% and 20% respectively. 4.3 Geology and Soils The lands located to the far west of West Gonja District, close to the Cote d’Ivoire border, fall within the north–south physiographic zone geographically dubbed ‘Savannah High Plains’. The towns and villages located in this zone include Bole, Sawla, Tuna, Mankuma and Kuntasi. Geologically, the region is characterized by widespread Birrimian granite rocks, and the lands have a height range of 180-300 meters, above sea level. There are high plains and gentle rolling land, interspersed with small-rounded hills or inselbergs. The Northern Region (from which the Savannah region was created) has a distribution of two major types of soil that critically influence agricultural and other subsistence activities. The first, and commonest, which covers nearly 70% of the savannah region, is the ‘Groundwater lateritic soil’. The second is known as the savannah Ochro soil (The Greek ‘Ochro’ means highly coloured), and covers 30% of the savannah area. Groundwater lateritic soil is yellowish brown or yellowish grey in colour. It is highly acidic, and poor in organic matter and nutrients. This kind of soil, therefore, poses problems to farmers in the northern savannahs. The other major northern savannah soil type, the savannah ochrosol is developed over sandstones, granites and Birrimian rocks. It is an acidic, well–drained, porous loamy soil. Because it is developed in savannah land with less rainfall than occurs in forestlands, it does not undergo leaching. This means that it does contain appreciable amount of nutrients and is generally alkaline (Dickson and Benneh 2001: 37–38). It is well attested that the relatively deep savannah ochrosols of the Voltaian sandstone in Gonja and Dagomba have long been the leading areas in Ghana for the production of yam, guinea corn and millet. ESIA-MNP, GLRSSMP-EPA PCU, 2025 47 Table 4-3 : Geology & Soils of Mole National Park Soil Type Characteristics Location Geology Ferrasol Ferraltic B horizon i.e. highly Upper slopes. Voltaian System weathered and a high content of central ridge and Kaolinite and sesquioxides. Cape Coast granitoids. Nitisol Argic B horizon, i.e. clay content Middle slopes and flat valley higher than in overlying horizon. plains away from streams. Vertisols Clay .rich (> 30% in the top 18 Valley floor in the centre of cm) dark soil. the Park. Solonchak Halomorphic soil (high salinity). Around Mole and Lovi rivers. Figure 4-4 : Geological and Soil Map ESIA-MNP, GLRSSMP-EPA PCU, 2025 48 Figure 4-5: Topographical and Vegetation Maps 4.4 Vegetation and Animal Species Mole National Park has fairly undisturbed Guinea Savanna vegetation type. Human impact has been limited to annual burning, former localized farming, tsetse fly control and intensive hunting, as well as the collection of fruits and firewood. The dominant vegetation is open savanna woodland with grasses that can reach 3m during the rainy season. Burning plays an integral part in the maintenance of this vegetation. Bovals are open areas of short grassland which are found on areas with shallow soils and iron pans. Narrow bands of riverine forest grow along most of the streams. Other plant communities, such as swamps and flood-plain grasslands, cover only small areas. ESIA-MNP, GLRSSMP-EPA PCU, 2025 49 Figure 4-6 : Boval vegetation in the Mole National Park Most of the 742 plant species found in Mole are widespread throughout the savanna zone. However, the species of conservation value (4 endemic, 12 disjunct and 24 species which are rare or have a very limited distribution) is relatively high. Their abundance is generally low and they are often confined to small areas. (MNP Management Plan, 2005) According to Management the Mole National Park as a recognized protected area has no classified areas, recognized wetlands or Ramsar sites, generally is a natural habitat and no critical habitats exists around the sub-project areas. Similar sub-projects i.e. dugouts were constructed during the erstwhile Sustainable Land and Water Management (SWMP) and implementation activities did not have any significant adverse environmental and social impacts due to the mitigation measures put in place. The proposed mitigation measures will also be implemented to ensure that implementation activities will not pose threat to the ecosystem. 4.4.1 Main Vegetation Types The vegetation of Mole National Park can be grouped into eight broad vegetation types, as described below and shown in the following map. Their distribution is mainly determined by soil depth and drainage. (see Schmitt and Adu-Nsiah, 1993 for full details). Open savanna woodland: This is the dominant vegetation type. The tree cover varies from 5% to 65%, with an average of 30%. The average tree height is 11 m with individuals reaching 22m. The ground cover, which can reach up to 100%, is dominated by grasses up to 3m tall. The main grasses are species of Andropogon and scattered herbs are found between them. ESIA-MNP, GLRSSMP-EPA PCU, 2025 50 The savanna woodland is divided into three main groups: 1. The Burkea - Terminalia savanna woodland with Vitellaria paradoxa (the shea-nut tree) comprises all savanna woodland on well-drained and often deep soils. 2. The Burkea - Terminalia savanna woodland with Detarium microcarpum is confined to shallow and rocky soils. 3. Anogeissus with Vitellaria paradoxa is found on the granite outcrops. Boval: The boval vegetation (Loudetiopsis kerstingii - Polycarpaea tenuifolia community) comprises all plant communities on flat iron pans with patches of shallow soil. Only annual species can compete on such sites which are flooded and species-rich during the rains and subject to extreme water-stress during the dry season. Riverine forest: This is found along most of the rivers in the park. It often forms bands of generally dense and species-rich forests of up to 38m in height. The width of these bands varies from a few metres to more than 100m on either side of the river and is mainly determined by topography and geology. ESIA-MNP, GLRSSMP-EPA PCU, 2025 51 Mole boundary Rive rs FO RES TS Rive rine forest Scarp fore st SAV ANNA WO ODLANDS AND G RAS SLANDS De tarium microc arpum sub- group ( on shallow , rocky s oil) Vitella ria sub-group with Anogeissus sta nds a nd gra nite outcrops Flood- plain gras sland, sw am ps a nd forest on w et sites Mos aic of com munit ie s on top of Konkori sca rp (rocky sites ) Bov al Vitella ria paradoxa sub-group (deep soil) Figure 4-7 : Vegetative Map Flood plain grassland and swamps: This vegetation type comprises four plant communities of seasonally water-logged valley bottoms and badly-drained depressions and areas around water- holes which are mainly dominated by grasses and sedges. Communities covering small areas: These are sites with special vegetation such as old termite mounds or depressions in the sandstone plateau on top of the Konkori escarpment, which are water- filled during the rainy season. There is also a scarp forest along the foot of the Konkori escarpment. ESIA-MNP, GLRSSMP-EPA PCU, 2025 52 4.4.2 Fauna There are over 93 species of mammals, about 300 species of birds, 9 amphibian, 33 reptilian and several insectivorous species, and 56 endemic butterfly species have been recorded, in particular (MNP Management Plan, 2005). 4.4.2.1 Species of Conservation and Tourist interest in Mole Mole National Park has over 90 species of mammals. Elephant, buffalo, kob, warthog, waterbuck, bushbuck, roan antelope, hartebeest, duikers, oribi, patas monkey and green (vervet) monkey are the species commonly seen at Mole National Park (MNP Management Plan, 2005). Aerial surveys of the large mammals have been carried out between periodically 1993 and 2019. Predators in the Park include spotted hyenas, leopards, caracal, civets, genets, jackals and mongooses. Even though there are lions in the park, their population and home range has declined, making their presence and sighting rare. 4.4.2.2 Endangered Species The lions (pantheraleo) and elephants (Loxodonta africana) found in Mole National Park are currently listed as vulnerable on the IUCN red list of 2004. The spotted hyena, buffalo, oribi, roan antelope, kob, duiker and reedbuck are listed as lower risk on the same publication. These species require particular management to thrive. The GLRSSMP is assisting the management of MNP through the WD to implement the following measures: strict protection of wildlife through regular patrols to preserve various species, conservation education for communities around the park and formation of Community Resource Management Areas (CREMAs) to enhance knowledge and protection of natural resources. The IUCN Red List of Threatened Species (IUCN 2004) lists the following species which are present in Mole National Park Common name Scientific name Red List status Lion Panthera leo Vulnerable (2004) Elephant Loxodonta africana Vulnerable (2004) Spotted hyaena Crocuta crocuta Lower Risk (2004) Buffalo Syncerus caffer Lower Risk (1994) Oribi Ourebia ourebi Lower Risk (1994) Roan antelope Hippotragus equinus Lower Risk (1994) Kob (Buffon’s kob) Kobus kob Lower Risk (1994) Gambian mongoose Mungos gambianus Data deficient (1994) Yellow-backed duiker Cephalophus silvicultor Lower Risk (1994) Bohor Reedbuck Redunca redunca Lower Risk (1994) ESIA-MNP, GLRSSMP-EPA PCU, 2025 53 4.4.3 Birds Studies have been made of the avian life in Mole National Park, and a full report can be consulted (Dowsett, 2005). Over 300 bird species have been recorded, many of which are migratory birds heading to or from Northern Europe. Including the Carmine bee-eater and Saddle-billed stork. All 37 recorded Guinea-Sudanian biome species found in Ghana are found at this National Park. There have been sightings of martial eagles, the white-headed and palm-nut vultures, herons, egrets, the Abyssinian roller, the violet turaco and the red-throated bee-eater, to name a few. Figure 4-8 : A bird Specie at MNP 4.4.4 Reptiles There are 33 reptile species in the Park. The Nile crocodile, slender snouted crocodile and dwarf crocodile can be seen in the rivers within the Park. (Park Management Plan) 4.4.5 Butterflies More than 50 butterfly species have been spotted in Mole National Park, including the Anthene talboti1, which is usually limited to East Africa. Mole is the only part of West Africa where this species has been recorded. (Park Management Plan, 2005). 11 The scientific name "Anthene talboti" refers to a species of butterfly in the family Lycaenidae, commonly known as the gossamer- winged butterflies or blues. Here's a breakdown of the scientific name: - Anthene: This is the genus name, which is a grouping of related species within the Lycaenidae family. - talboti: This is the specific epithet, which is a unique identifier for the species within the genus. The name "talboti" is likely derived from the name of a person, possibly a naturalist or collector who discovered or described the species. Anthene talboti is a relatively small butterfly species, with a wingspan of around 20-25 millimetres. They are found in various parts of Africa, including Ghana, Nigeria, and Cameroon. These butterflies are known for their striking colour patterns, which often feature shades of blue, brown, and white. They are also notable for their unique habits and habitats, which can provide valuable insights into the ecology and conservation of these fascinating creatures. ESIA-MNP, GLRSSMP-EPA PCU, 2025 54 The total butterfly fauna is probably about 120. Most are typical of the Guinea savannah belt. Two species of Euphaedra were found: the genus is mainly one of the understorey of true evergreen forest, but the two species in question seem well established in dense woodland in the park. The West African savannah habitats are generally not species rich, and there is virtually no endemism. True savannah butterflies constitute about 15% of the total Ghana butterfly fauna of more than 900 species. The best season for butterfly studies in Mole is between late May and early June. Approximately 38% of the plants recorded in Mole are also found in the forest zone. 39% of them (or 15% of all Mole plants) were classified as 'non forest species' by Hawthorne and Juam Musah (1993). 461 or 62% of the plants found in Mole are savannah species. Figure 4-9 : Anthene talboti butterfly specie at MNP 4.5 Air Quality Baseline air quality data was collected to understand the level of deterioration or otherwise of the project site. This will help to determine any changes in the quality during the construction and operational phases of the facilities to be constructed within the Mole National Park and fringe communities. The parameters of concern were Total Suspended Particulates, and Respirable Dust (PM10 and PM2.5). Ambient air quality refers to the standard quality of the air within a defined environment that supports ecosystem functioning. The ambient air quality standards are the concentrations of ESIA-MNP, GLRSSMP-EPA PCU, 2025 55 pollutants in the air, and typically refer to outdoor air. The standards are meant to ensure the protection of human health. Two (2) sampling locations were selected in order to give a fair idea of the air quality in and around the project site. These were the west of the site which is close to the Fufulso-Sawla highway and the centre of the site. The instrument used was a 224-52TX Air Sampling Pump. The equipment was mounted at about 1.5 meters above the ground. The results of the monitoring are presented in table 4-2 below. Table 4-4 : Summary Results of Ambient Air Quality Monitoring Sampling Point TSP PM10 PM2.5 West 163.4 67.5 33.2 Centre 144.2 66.1 29.4 GS 1236: 2019 Standard 150.0 70 35 Source: Field Data, February, 2024 Particulate The TSP in the ambient air were found to be above the permissible levels of 150µm-3 for a 24-hour averaging time as prescribed in the GS 1236:2019 with values of 163.4µm-3 in the west however the centre recorded 144.2µm-3 which is within the permissible limits. PM10 in the ambient air were found to be within the permissible levels in all sampling locations in the west with 67.5µm-3 and south with 66.1µm-3 as compared to 70µm-3 for a 24-hour averaging time as prescribed in the GS1236:2019. PM2.5 in the ambient air were also within the permissible levels in all the sampling locations west recorded 33.2µm-3 and centre recording 29.4µm-3 as compared to the ambient air quality standard value of 35µm-3 for a 1-hour averaging time prescribed in the GS 1236:2019. 4.6 Ambient Noise The project location currently has no activity that generate noise which may impact negatively on the environment. The two locations used for the ambient air monitoring were also used for the noise level assessment, i.e., west and centre of the project site. The noise levels were captured in-situ in decibels on the A scale, i.e., dB (A) using a CR: 812B Sound Level Meter. Readings were taken at 1.5 m above ground level for 24 hours, which is for daytime and night-time periods. The results of the noise measurement are presented in table 4-3 below. ESIA-MNP, GLRSSMP-EPA PCU, 2025 56 Table 4-5 : Ambient Noise Level Measurements Location Leq dB(A) Leq dB(A) (Day time) (night time) West 54.9 48.9 Center 53.2 47.7 Ghana* Standard Value (GS 1222:2018) 55 50 Source: Field Data, February, 2024 Leq: The equivalent continuous sound pressure level EPA*: Guideline value set for day and night time The results, presented in Table 4-5, indicate that the measured Integrated Equivalent Noise Levels (Leq) ranged from 54.9 dB(A) to 53.2dB(A) for day time and 48.9 dB(A) to47.7 dB(A) for night time. Thus, all the baseline noise level measurements fell within the relevant Ghana standard for Health Protection- Requirement for Ambient Noise Control (GS 1222: 2018 and Ghana Standard- Acoustic Guide for Measurement of Outdoor A-Weighted Sound Levels (GS 1253: 2018). 4.7 Water Bodies Mole National Park forms part of the White Volta catchment, and numerous rivers cross or originate in the Park to drain into the White Volta. Most of the rivers, with Mole and Lovi being the major ones, are seasonal and drain into the White Volta. The Polzen, Kparia, Kulpawn and many other smaller rivers on the North-Eastern part of the park are perennial, although dry season flows are much less than wet season flows. Almost all the rivers drain eastwards into the White Volta. The park has a fairly good proportion of gallery forest, which occurs along the major rivers and streams: notably, the Mole, Lovi, Polzen, Kparia and Mbonwura. These gallery forests are significant in providing suitable habitat for species such as the Yellow-backed duiker and the Black and White Colobus monkey, which are typical forest species. In addition to these rivers, there are other waterbodies in the Park, in the form of, springs, waterfalls, creeks and ponds. There is also a natural freshwater pool, known as Haraba Pool, where a lot of fish can be found. 4.8 Fringe Communities The park is surrounded by 32 communities with an estimated population of about 40,000 people, who still make use of the Park’s resources in diverse ways. Each of the 32 communities is under one of the three traditional areas – Gonja, Wa and Mamprugu. Community members are mainly subsistence farmers who also rear livestock, hunt, and gather wild fruits and other non-timber forest products (NTFPs). Some of the communities surrounding the park are involved in a CREMA while others are not. Dugouts will be constructed in Dabore, Jang in the Sawla-Tuna Kalba and Chassia in the Wa East Districts ESIA-MNP, GLRSSMP-EPA PCU, 2025 57 Table 4-6 : Mole National Park Fringe Communities and Districts DISTRICTS FRINGE COMMUNITIES2 NUMBER Sawla-Tuna Kalba Jelinkon, Jang, Soma, Kong, Dabori 5 Murugu, Mognori, Larabanga, Kananto, West Gonja Kabampe, Grupe, Sehyri 7 Kparia, Wawato, Grubagu, Bawena, Jinfronu, North Gonja Kpulumbo, Yazori, Kaden 8 Mamprugu Goriba, Garigu, Sagiya, Tantala, Yagbon, Moagduri Yirangu, Zanwara 7 Wa East Chasia, Ducie, Grunbele, Holomunie, Belepong 5 Total 32 2 All communities in bold are CREMAs ESIA-MNP, GLRSSMP-EPA PCU, 2025 58 Figure 4-10 : Distribution of Fringe Communities around MNP 4.9 Archaeology Mole National Park territory is linked to the slave trade. The ancient caravan route from Salaga to Wa and beyond to Mali passed through the heart of what today is Mole National Park. This route was used for both trading and to transport slaves to coastal markets. The Park Headquarters is located right at a place where two famous slave raiders (Samore and Babatu) raided and razed a village to the ground. The Headquarters is named after one of them, Samore There is a cave in the Konkori escarpment that was used as a refuge from slave raiders by the local indigenes. In the ESIA-MNP, GLRSSMP-EPA PCU, 2025 59 immediate vicinity of Mole National Park there are important archaeological sites, namely, among others: • Ykpabongo, with its Komaland archaeological excavations, the first of which were conducted in 1985; Ykpabongo at the extreme north of Mole National Park. • Daboya, situated in Gonjaland in Northern Ghana, on the East of Mole National Park, with finds at the site including traditional burial mounds and comb-decorated pottery, as well as an extant mosque from the 16th or 17th century. • Nyange, the traditional seat of the Yagbongwura, the Paramount Chief of the Gonja State. Nyange served as the capital until 1944, when that function was transferred to Damongo. The Archaeological site is made, among others, of the remains of the Yagbongwura’s Palace and Court House. # Hipp o po ol Wa Po lze n Falls # Ducie Gba nwe le cave Gba nwe le # # Ko nkori ca ve # Ston e spring An ya nto ca ve Slave Route Ba we na # Dab oya Slave Routes Nakp anzo cave Be vo r cave # # Ba batu a nd Samo ri's # sla ve raid ing ba se Sa wla Asibe y Poo l # # Laraba nga Mosque and Mystic Sto ne Figure 4-11 : Archaeological Sites 4.10 Safari Facilities and Activities 4.10.1 Existing Tree Hide at MNP ESIA-MNP, GLRSSMP-EPA PCU, 2025 60 The Tree Hide is a viewing platform built on a strong tree, which enables visitors to get a close feel of nocturnal wildlife while the animals visit the nearby saltlick (a place where animals go to lick salt from the ground). Hyenas, buffaloes, baboons, leopards, antelopes and birds are some of the animals you might see. Throughout the night there are over a hundred birds chirping, and this, combined with the cries of hyenas and baboons, is very exciting for any animal lover. Figure 4-12 : Existing Tree Hide at MNP 4.10.2 Foot, Bicycle, Motorbike and Car Safaris The Foot Safari involves walking through the Park. Animals that you may see on a Foot Safari are birds, antelope, kobs, elephants, baboons, warthogs, buffalos and monkeys. Foot Safaris are conducted between the hours of 7 am and 11 am, and between 3:30 pm and 5:30 pm. Each trip lasts for two hours or more in the case of ling-range safari. Figure 4-13 : Foot safari ESIA-MNP, GLRSSMP-EPA PCU, 2025 61 4.10.3 Wilderness Nature Ride/Drive/Cycle This is a two-day motorcycle, 4x4 vehicle or foot trip mostly from January to June which is organized upon request and tourist have to come with their own motor cycles. Visitors are likely to see Elephants, Buffalo, Roan Antelopes, Hartebeests, Waterbucks, Kobs, activities of Leopards and Hyenas, and so on. For pre-trip preparation, bring along water, food, protective gear, closed footwear, mosquito net, insect repellent, warm bedding, clothing, bright torchlight, sleeping bag, and motorbike. All visitors shall depart from the Information Centre at 7:30am and shall receive briefing before departure. 4.10.4 Kparia Waterfalls Cycling This is a two-day safari trip using a 4x4 vehicle or motorcycling mostly in the dry season from January to June. Visitors will have the opportunity to see a range camp, fringe communities, the Daboya Smock Weaving Industry, Kparia Waterfalls and its natural environment, the old settlement, and burial grounds. Visitors may also take the opportunity to stay with people in the community. 4.10.5 Short by Foot This is a two-hour foot safari which runs throughout the year. Visitors will have the opportunity to exercise, as well as see Elephants, Roan Antelopes, Hartebeests, Waterbucks, Kobs, Bushbuck, etc. Cyclists should bring along water, food, protective clothing, closed footwear, and insect repellent. All visitors shall depart from the Information Centre at 7:30am and shall receive a briefing before departure. 4.10.7 The Mole Circuit Drive This is a three-hour driving trip that runs all year round. It is a community-based tourist attraction around MNP, mostly at Mognori, Laranbanga, etc. Prices will be determined by the Information Centre, depending on the number of participants on the tour. Visitors will depart from the Information Centre at 11:00am, and shall receive a briefing before departure. With a guide from the Park, visitors will drive to Mognori Eco-village, where a local tour guide from the community will take the visitors through the various attractions, while the Mole Tour Guide will provide security and boost the confidence of the visitors. Visitors can enjoy various activities such as Canoe Safari, Cultural Dance, Community Walk, and Shea Butter Processing. From Mognori, visitors will drive to Larabanga, where a local tour guide from the Larabanga community will take them through the various attractions: the Ancient Larabanga Mosque and Mystic Stone, Cultural Dance, ESIA-MNP, GLRSSMP-EPA PCU, 2025 62 Community Walk, etc. Again, the Mole tour guide will provide security and boost the confidence of the visitors. 4.10.8 Night Safari The Night Safari involves a trip from the Information Centre into the wild. Prices will be determined by the Information Centre, depending on the number of participants on the tour. Visitors are taken on a ride through the Park, where they may get a chance to see a number of nocturnal animals. The night safari begins at 7:00 pm and lasts for two hours, in order not to disturb the animals unduly. An armed guide in a rental jeep escorts visitors on this adventure, which is booked for at the Information Centre. Visitors have the choice of viewing the animals from the roof of the jeep or from the inside, as most of the rental jeeps have rooftop seating. Some of the animals that visitors may see on this safari are buffaloes, hyenas, roan antelopes, leopards, elephants and hartebeest. 4.10.9 Historical and Archaeological Tour A major pre-19th century slave trading route passes through the Park, linking Damongo to the south of the Park, with the interior areas to the north. The route generally follows the Konkori Escarpment. The Gbanwele caves in the centre of the Park also have archaeological and historic importance. Archaeological tours are always part of a larger tour. 4.11 Local Economy of MNP Fringe Communities The Mole National Park with about thirty-two fringe communities has a total population of about 40,000. These communities are distributed among four main districts namely West Gonja, Sawla- Tuna-Kalba, Wa East and Mamprugu Moagduri districts (refer to table 4-4). With the exception of West Gonja the population of the other three districts are largely rural as depicted in the table below. Table 4-7 : Demography of the Fringe Districts of Mole National Park DISTRICT TOTAL MALE FEMALE Wa East 91,457 46,621 44,836 Urban 5,632 2,881 2,751 Rural 85,825 43,740 42,085 Sawla-Tuna-Kalba 112,664 53,004 59,660 Urban 22,531 10,726 11,805 Rural 90,133 42,278 47,855 ESIA-MNP, GLRSSMP-EPA PCU, 2025 63 West Gonja 63449 32,270 31,179 Urban 39,150 19,618 19,532 Rural 24,299 12,652 11,647 Mamprugu Moagduri 68,746 34,053 34,693 Urban 12,805 6,261 6544 Rural 55,941 27,792 28,149 Source: General Report Volume 3A, 2021 Population and Housing Census The main economic activity of the people living in these fringe communities is farming, with the major crops cultivated being yam, maize, groundnuts, millet, sorghum, beans, soya beans, rice and cassava. Livestock reared includes sheep, goats, cattle, guinea fowls and chickens. Other income generating activities include honey production, broom-making, basket and mat weaving, pottery, alcohol brewing, soap making, shea butter, and groundnut oil extraction. Smock (traditional shirt) production is a major economic activity in North Gonja District. Gari and shea butter processing are among the major commercial activities for women. Living conditions, existing infrastructure, road and telecommunication status and networks are still challenging in the majority of these communities. However, recent developments are gradually improving roads and infrastructure, thus putting in motion a broader development process. Sustainable tourism is increasingly generating sustainable income activities for people living in Mole National Park’s fringe communities: mainly Mognori, Larabanga and Kparia, and also nearby Nyange, Yikpabongo and Daboya. Their outstanding cultural, archaeological, architectural, socio economic and environmental tours offer unique opportunities to share their life, culture and environment. Other communities are becoming aware of their potential in sustainable tourism and will soon offer a range of distinctive attractions such as architecture, traditional housing, eco-tours and culture. 4.12 Land Tenure System MNP, together with its fringe communities3, covers three (3) customary/ traditional jurisdictions – the Gonja Kingdom, the Mamprugu kingdom and Wa traditional area. Gonja and Mamprugu Kingdoms are under the skin land tenure regime, while Wa traditional area is under the Family/Clan land tenure regime. The Gonja and Mamprugu Kingdoms are superintended by Overlords, and while the Gonja Kingdom has 17 Paramount chiefs, the Mamprugu Kingdom has 33 Paramount chiefs. Each Paramountcy constitutes a traditional area, and each traditional area is headed by a Paramount Chief. Paramount Chiefs are therefore directly below the level of an 3 Fringe communities as defined by the GLRSSMP ESIA-MNP, GLRSSMP-EPA PCU, 2025 64 Overlord in the traditional governance hierarchies. However, there are some variations in dynamics, due to the different histories, traditions, and leaderships of the different skins. Overlords of the Gonja and Mamprugu Kingdoms are the custodians of the Allodial interest – the ultimate authority – in all the lands under their respective kingdoms. Unlike in Stool land ownership regime, Paramount Chiefs here are semi-autonomous, given that they have reporting relationships to their Overlords, in respect of both community and land governance issues. Each traditional area may have several communities under them. The type of interest held by Paramount Chiefs in Gonja and Mamprugu may therefore be described as semi-Allodial, given the nature of authority they exercise on land in their respective jurisdictions. Generally, traditional areas in Skin land jurisdictions may be divided into divisional areas or communities, depending on the size of the traditional area. Divisional Chiefs are below the level of the Paramount Chief in the hierarchy. Paramount Chiefs, in the discharge of their mandate, are supported by Divisional Chiefs directly below them. Where divisional areas are large, they may be subdivided into communities and a Community Chief is appointed to oversee each community. Community Chiefs report to Divisional Chiefs on the discharge of their mandate. Where there are no divisional areas within a traditional area, then Community Chiefs are the ones who directly support Paramount Chiefs in the discharge of his mandate. There are also spiritual leaders called Tendamba4 in skin land areas. Tendamba are Earth Priests who are responsible for the pacification of deities associated with land. In some areas, there are Tendamba at levels of paramountcies, divisions and communities. Tendamba perform land-related customary cleansing rites at the beginning of the farming season, for example, in traditional areas under the Gonja and Mamprugu Kingdoms. In land transactions, including voluntary donations, how consent is given, and who gives it, vary across skin land owning areas of Northern Ghana, depending on the level of authority delegated from an Overlords down the hierarchy to their Community Chiefs. Some Community Chiefs have the capacity to give consent, and to seal certain types of land transactions at their level, without the need to involve those up the hierarchy. Other transactions have to travel up to be consented to by the Overlord, in order to be customarily valid. In Wa, which is under the Family/ Clan landowning regime, the land governance arrangement is acephalous. There is a Paramount Chief at the top of the chieftaincy hierarchy, and below whom are eleven (11) Divisional Chiefs. However, unlike in Skin landowning areas, Chiefs in the hierarchies under the Family/Clan land regime do not have authority over land, given that land governance is separate from community governance matters at all levels of the chieftaincy hierarchy. Land ownership, and the authority over land resides in Families/ Clans. Each community is divided into sections, and each section is occupied by a (extended) Family/ Clan. A Family/Clan in this case would usually consist of several nuclear families. Therefore, the membership of a Family/Clan could be quite large, but usually with a common head. Heads of 4 Singular form is Tendana. ESIA-MNP, GLRSSMP-EPA PCU, 2025 65 Families/ Clans are the recognized persons who superintend the administration of lands held by their respective families. In a typical landowning Family/ Clan, the head is supposed to be supported by the Principal Elders of the Family/ Clan, in the decision-making processes concerning the Family/ Clan’s land. However, in recent times, some heads tend to make these decisions unilaterally, with very little consultation. However, there are some Families/ Clans that are quite organized, with well laid out structures to promote accountability. Here too, the grant of consent for land transactions vary, depending on the rules agreed by the landowning Family/ Clan. ESIA-MNP, GLRSSMP-EPA PCU, 2025 66 5.0 CITIZEN/STAKEHOLDER ENGAGEMENT 5.1 Introduction A stakeholder to the project refers to any individual or group potentially affected directly or indirectly by the proposed project or has an interest in or influence on the proposed Project. The rationale for stakeholder engagement is that it is an essential part of good international practice and can help projects succeed. Effective stakeholder engagement can improve the environmental and social sustainability of projects, enhance project acceptance, contribute to successful project design and implementation, and support project's risk management process. Stakeholder consultations play a major role in identifying the potential impacts of any proposed project. Consultations with the state agencies and regulatory agencies have assisted in defining the regulatory and institutional framework within which the sub-projects should be carried out. Community consultations also assist in the identification of environmental and social risks and impacts that needs to be considered and addressed by the borrower. Ghana’s EA regulations provide for the consultation and participation of stakeholders in the Environmental Assessment process in order to ensure that their concerns and inputs are considered as part of the project design and planning. There are enormous benefits that come with ensuring that there is an effective engagement with all stakeholders. Stakeholder engagement and participation is a process, not a single event. It provides an opportunity for all stakeholders to influence decisions that affect their lives. The objectives of the stakeholder engagement are to; • provide information about the project and its potential impacts to those interested in or affected by the project, and solicit their opinion in this regard; • provide opportunities for stakeholders to make inputs into decisions on undertakings that may affect their lives • bring local knowledge to bear on the project planning process • provide the opportunity for stakeholders to raise issues and concerns at an earlier phase of the project planning in order to avoid conflicts during project implementation • build a constructive relationship between proponent and stakeholders throughout the entire life cycle of the project • facilitate the consideration of alternatives, mitigation measures and trade-offs and • manage expectations and misconceptions regarding the project; ESIA-MNP, GLRSSMP-EPA PCU, 2025 67 5.2 Stakeholder Consultation Approach A stakeholder consultation with the Implementing Agencies, MDAs and communities at the district and community levels took place between 21st and 30th January, 2024. A field visit was organised by the EPA-PCU in collaboration with the Wildlife Division of the Forestry Commission, the EPA, Project Works consultants and the Ministry of Food and Agriculture as per the team in annex 2 to the various sites. There are a number of approaches that can be used for effective engagement of stakeholders. The following tools and approach were adopted; • Field visits and observations • Community engagements • Key Informant Interviews The information obtained was then analysed and summarized to identify the baseline socio- economic conditions, to determine the potential project risks and impacts, to develop the mitigation measures and to enable monitoring and evaluation of the project implementation activities. 5.3 Identified Stakeholders The following stakeholders were identified and engaged on the preparation of the Environmental and Social Impact Assessment (ESIA): • Beneficiary District Assemblies • Beneficiary Communities • Traditional Authorities • Community Leaders/representatives • Management of Mole National Park 5.3.1 Community leaders Community leaders in CREMA communities and other fringe communities i.e. Chiefs, opinion leaders, CREMA committee members and assembly members have been involved in engagement processes. Other vulnerable groups such as women were consulted as they constitute the major beneficiary group of the project. These groups were given information on all aspects of the project intervention including the benefits, challenges and their obligations to ensure successful implementation. Methods used to achieve this included focus group discussions and public announcements using existing community channels of information dissemination. The separate stakeholder engagement plan prepared for the project provided some good guidance to the stakeholder engagement during the field visits, engagement with community members and subprojects site selection processes. ESIA-MNP, GLRSSMP-EPA PCU, 2025 68 5.3.2 Consultations with Municipal and District Assemblies Consultations were held with the relevant four (4) district assemblies that falls within the proposed civil works. The specific objectives for these consultations were: • To provide detailed information about the project as a follow up to mails sent to introduce and explain the project objectives and components • To participate in subprojects site selection and solicit their views that could inform the project design • To collect and find ways of collating data to enrich project design • To identify other relevant stakeholders within the project area for further engagement The district authorities provided the following documents and information: • Current Medium-Term Development Plan • District Maps • Land Use Maps • List of organizations working in the Municipality or District i.e. private companies, NGO’s, CBO’s, farmer associations etc. • Cultural/historical sites present that can be develop for ecotourism These documents were used to ascertain existing activities, evaluate sites selected and determine their suitability, to develop synergies, identify gaps, and avoid duplication of activities, mainstream issues and to identify potential risks/impacts that could result from implementation of project activities. Tables 5-1 and 5-2 outlines the consultation process and key consultees and outcome of consultation respectively. ESIA-MNP, GLRSSMP-EPA PCU, 2025 69 Table 5-2: Outcome of consultations No Stakeholder/ Issues/Concerns/views Responses Facility 1 Mole • An existing field wildlife research center MNP should provide soft copy National • Some of the components of the facility are of the complete design plan and Park (MNP) Kitchen, Dinning, 3 bedroom and washrooms, drawing to the architect. electrical/generator room, offices, lab, MNP should come up with the conference room, classrooms, borehole. commencement and completion • The door/window frames of the facility must plan for phase 1 be replaced. MNP should also list all • The roofing must be extended to prevent rain equipment and procedure for falling on the walls. equipping the facility as phase 2 2 Jang • The chief was grateful that the project will The construction will start after Community provide water for the animals and the the preparation of all E&S community will benefit. instruments • The community members wanted to find out when actual construction will start • There is land available for the dugout 3 Dabore • The community welcomes the project The community dugouts will Community • Domestic animals will drink from the dugout serve livestock watering during when it is constructed the dry season. The project will • The possibility of using the water for dry put in place water management season farming committees to oversee the • The land will be protected, vegetation will be maintenance and use of the conserved and contribute to climate change dugouts. Signage will be placed mitigation and adaptation to give clear use of the dugouts • The area around the dugout will serve as a being constructed, habitat for wildlife • The water can be used for domestic purposes • Land was released by a collective decision by the opinion leaders of the community • No one has complained about his/her land being taken away from them • Community members do not anticipate any negative impacts from the project • The project will be co-managed by all the beneficiary communities • Community access to grasses for roofing will further be improved ESIA-MNP, GLRSSMP-EPA PCU, 2025 70 4 Chassia • The area selected is very good and can sustain the dugout 5 Larabanga • The community was grateful for being considered for the processing facility though they are not part of the CREMA • They have been involved in the projects over the years as a community that fringes the park and has been supportive and therefore the support will be given to the GLRSSMP. 6 Soma • The community expressed their appreciation for being selected to benefit from the shea processing facility • The processing when it starts operation will help boost their income especially the women • They are ready to donate land (no matter the size) for the construction ESIA-MNP, GLRSSMP-EPA PCU, 2025 71 6.0 IMPACT IDENTIFICATION AND PREDICTION The report has identified, qualitatively assessed and classified environmental and social risks and impacts and their respective management options based on the general project design concepts. The proposed project is expected to have both positive and negative social, economic, and environmental impacts at different levels of significance. Potential impacts on the physical, biological and social environments have been identified and are assessed below. The identified potential environmental and social issues and impacts have been discussed based on the nature of the project, project area of influence, field inspections and observations, concerns from stakeholder consultations 6.1 Impact Assessment Approach To assess and quantify the identified impacts, factors considered to assess significance included: • Relationship of the impact to temporal scales - the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact. • Relationship of the impact to spatial scales - the spatial scale defines the physical extent of the impact. • The severity of the impact - the severity/beneficial scale is used in order to scientifically evaluate how severe negative impacts would be, or how beneficial positive impacts would be on a particular affected system (for ecological impacts) or a particular affected party. The severity of impacts can be evaluated with and without mitigation in order to demonstrate how serious the impact is when nothing is done about it. The word ‘mitigation’ means not just ‘compensation’, but also the ideas of containment and remedy. For beneficial impacts, optimization means anything that can enhance the benefits. However, mitigation or optimization must be practical, technically feasible and economically viable. • The likelihood of the impact occurring - the likelihood of impacts taking place as a result of project actions differs between potential impacts. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance The assessment of impacts is to include direct, indirect as well as cumulative impacts as provided in the EPA’s guidelines for the preparation of Environmental Impact Statement as well as the World Bank’s ESS1. The impact and risk predicted/identified will have the following attributes. ESIA-MNP, GLRSSMP-EPA PCU, 2025 72 6.2 Community influence and vulnerable groups The Mole National Park is the main area to be affected by the proposed project infrastructure and as well as some fringe communities (Jang, Dabore, Soma, Larabanga and Chassia), the first four are CREMAS communities while Chassia is within the agricultural landscape. These will be the main areas of impact such as noise, dust, biodiversity loss etc. Vulnerable groups including women and girls within the fringe communities and even staff of the park may be vulnerable to gender- based violence, sexual harassment, teenage pregnancy from potential influx of migrant labour. Mitigation measures proposed will minimize these impacts during the construction and operational phases. 6.3 Impact Assessment Approach Table 6-1: Impact Types Term Definition Beneficial / Positive An impact that is considered to represent an improvement on the baseline or introduces a positive change. Adverse / Negative An impact that is considered to represent an adverse change from the baseline, or introduces a new undesirable factor. Direct Impacts that arise directly from activities that form an integral part of the Project (e.g. new infrastructure). Indirect Impacts that arise indirectly from activities not explicitly forming part of the Project (e.g. noise changes due to changes in road traffic resulting from the operation of Project). Secondary or induced Secondary or induced impacts caused by a change in the Project environment (e.g. employment opportunities created by the supply chain requirements). Cumulative Impacts arising from the combination of multiple impacts from existing projects, the Project and / or future projects. Transboundary Impacts that extend to multiple countries, but are not global in nature (e.g. air pollution extending to neighboring countries and use or pollution of international waterways). Global Impacts that, when taken together with impacts created by other human activities, can become nationally, regionally or globally significant. 6.4 Criteria for Impact Evaluation Duration of the Impact ESIA-MNP, GLRSSMP-EPA PCU, 2025 73 A temporary impact can last days, weeks or months, but must be associated to the notion of reversibility. A permanent impact is often irreversible. It is observed permanently or may last for a very long term. Extent of the Impact The extent is regional if an impact on a component is felt over a vast territory or affects a large portion of its population. The extent is local if the impact is felt on a limited portion of the zone of study or by a small group of its population. The extent is site-specific if the impact is felt in a small and well-defined space or by only some individuals. Intensity of the Impact The intensity of an impact is qualified as strong when it is linked to very significant modifications of a component. An impact is considered of average intensity when it generates perceptible disturbance in the use of a component or of its characteristics, but not in a way to reduce them completely and irreversible. A weak intensity is associated with an impact generating only weak modifications to the component considered, without putting at risk its utilization or its characteristics. Impact Severity Major Impact: repercussions on the environment are very strong and cannot easily be reduced. Moderate Impact: repercussions on the environment are substantial but can be reduced through specific measures. Minor Impact: repercussions on the environment are significant but subdued and may or may not require the application of mitigation measures. Following international best practice, significant impacts will be determined by consideration of the following: i Sensitivity of the resource or receptor (rated as high, medium and low) by considering the importance of the receiving environment (international, national, regional, district and local), rarity of the receiving environment, benefits or services provided by the environmental resources and perception of the resource or receptor); For instance Schedule 5 (Regulation 30 (2)) of Ghana’s EA Regulations defines environmentally sensitive areas as ‘all areas declared by law as national parks, watershed reserves, wildlife reserves and sanctuaries including sacred groves’ which could be affected as a result of the development of civil works particularly in the Mole National Park; and ii Severity of the impact, measured by the importance of the consequences of change (high, medium, low, negligible) by considering inter alia magnitude, duration, intensity, likelihood, frequency and reversibility of the change. ESIA-MNP, GLRSSMP-EPA PCU, 2025 74 The following criteria were used to determine the sensitivity of the receptor / resource and severity of the impact. It should be noted that the definitions given are for guidance only, and not all the definitions will apply to all of the environmental/social receptors and resources being assessed. Therefore, the assessment will be further justified within each topic, referring to those tables where definitions are applicable. Table 6-2: Determination of Receptor Sensitivity High Medium Low Guideline Receptor is rare, legally protected, Receptor is of regional Receptor is common, definitions of international or national importance. or of local importance. designation. Resource may benefit Resource is not used or Population rely on resource for the local population, but is of no value to the health, subsistence or livelihood, they do not rely on it for population. or receptor is of high cultural health, subsistence or value. livelihood. Receptor is Human receptors – vulnerable of some cultural value. groups, Project Affected People (PAPs). 6.5 Magnitude of the Impact The assessment of magnitude have been undertaken in two steps. Firstly, the key issues associated with the Project are categorised as beneficial or adverse. Secondly, impacts have been categorised as major, moderate, minor or negligible based on consideration of the parameters such as: • Duration of the impact - ranging from temporary with no detectable impact to impacts still present beyond decommissioning • Spatial extent of the impact – for instance, within the site, boundary to regional, and national. • Reversibility - ranging from permanent requiring significant intervention to return to baseline to no change • Likelihood – ranging from occurring regularly under typical conditions to unlikely to occur • Compliance with legal standards and established professional criteria - ranging from substantially exceeds national standards and limits / international guidance to meets or exceeds minimum standards or international guidance. Table 6-3 illustrates generic criteria for determining magnitude. Table 0-3: Criteria for Determining Magnitude ESIA-MNP, GLRSSMP-EPA PCU, 2025 75 Magnitude (Beneficial Description or Adverse) Major Fundamental change to the specific conditions assessed resulting in long term or permanent change, typically widespread in nature, and requiring significant intervention to return to baseline; exceeds national standards and limits. Moderate Detectable change to the specific conditions assessed resulting in non-fundamental temporary or permanent change Minor Detectable but minor change to the specific condition assessed Negligible No perceptible change to the specific condition assessed 6.6 Positive Impacts The proposed civil works in and around the Mole National Park is expected to generate positive impacts. The water systems in the park will improve the population of the wildlife through the provision of watering points at the peak of the dry season. The viewing platforms will help boost the tourism capacity of the park and will also promote the sustainable management of natural resources and enhance the livelihoods of local communities depending on these natural resources. Other positive impacts include 6.6.1 Employment Generation The construction phase will generate direct employment opportunities, the majority being unskilled work. These workers will be hired by the construction contractor, which will mobilize the adequate workforce. Most of this workforce will likely be recruited locally, with a smaller percentage of specialized workers likely to be mobilized outside the locality. The jobs created by the Project, both directly and indirectly, will lead to an increase in family income of the workers hired locally, and the improvement of the wellbeing of their families. Note, however, that these are temporary jobs related to works duration 6.6.2 Economic Impacts The constructed water systems, particularly in the fringe communities, will provide enough water for the watering of animals during the dry season to improve the health of domestic animals which are source of income during the dry season.. Although dugouts constructed are mainly for watering of livestock those with large volumes of water could support dry season farming as additional livlihood spport activity which provide employment opportunities for the youth thereby reducing rural-urban migration by the youth in search of jobs , especially during the long dry season. 6.7 Potential Negative Environmental and Social Impacts The construction of the water systems (water holes and dugout) and game viewing platforms in and around the Mole National Park and the completion of the Lovi Research Centre will be ESIA-MNP, GLRSSMP-EPA PCU, 2025 76 associated with some potential impacts considering the locations of the projects. The projects are in a sensitive area (protected area-Mole National Park) in accordance with the Environmental Assessment Regulations. Both the water systems and viewing platform be constructed in the park are close to existing streams and rivers which have diverse and rich biodiversity. It is therefore important to ensure that any development that goes on within or close to them does not negatively affect their quality. 6.7.1 Construction Phase Impacts The perceived environmental consequences during the construction phase will include: ✓ Loss of Habitat and Biodiversity ✓ Air quality impacts ✓ Noise and vibration impacts ✓ Water quality deterioration ✓ Visual Intrusion ✓ Erosion and Siltation ✓ Potential fire hazard ✓ Conflict between construction activities and livestock watering ✓ Disposal of construction debris ✓ Impacts on occupational health and safety and community safety ✓ Transmission of HIV/AIDS ✓ Community health and safety e.g. traffic accidents ✓ Gender Based Violence, Sexual Exploitation and Abuse and Sexual Harassment (GBV/SEA/SH) ✓ Child labour and forced labour 6.7.1.1 Loss of Habitat and Biodiversity Site preparation for the construction of the water systems and game viewing platform would involve the clearing of vegetation to pave the way for the excavation of the reservoirs. The vegetation clearing may lead to the destruction of rare and endangered flora and the destruction of important habitats for some fauna. Though the construction will be in the national park and its fringes due to the mitigation measures prescribed it is anticipated that impact on, flora and fauna will be negligible 6.7.1.2 Impacts on Air Quality Ground preparation, excavation of the dugouts and waters holes and the movement of heavy-duty trucks to and from the site will lead to the loosening of the soil, emissions from the combustion of ESIA-MNP, GLRSSMP-EPA PCU, 2025 77 fuel and the re-entrainment of particulate material. Airborne pollution, in particular, dust resulting from clearing and excavation of the land may pose health risk to construction workers and any near-by residents in the vicinity. Though the construction activity will generate some amount of dust, the impacts will be limited to only the construction phase of the project and therefore short term and the impact is considered minor. 6.7.1.3 Noise and Vibration Impacts During construction noise and vibration nuisance are likely to emanate from the construction machinery, loading of construction spoils, tipping of raw materials, and movement of construction vehicles at the site. The generated noise and increase dust levels could further disturb the serene nature of the area. Noise to be generated during the construction stage will be intermittent and limited only to the construction phase. The impact is considered minor. The EPA permissible noise levels for residential areas is 50-60 dB, however, the construction sites are not close to the communities and therefore will not cause nuisance to these communities. Workers will be provided with appropriate PPEs when noise become excessive. 6.7.1.4 Water Quality Deterioration Some of the water systems that will be constructed within channels of streams that may serve as source of domestic water for downstream users i.e., the main rivers/stream; Mole, Lovi, Motel, Nyenge and blue. The likelihood of the water quality deterioration from constructional activities will be high. If the downstream users continue to use the water, it may have serious implications on their health and that of their livestock. In addition, if the flow of the water is blocked, it will deprive downstream users the use of the water. The impact is evaluated as negligible. 6.7.1.5 Visual Intrusion and Aesthetics The construction activities will result in temporal stockpile of soil because the they will be used for the establishment of the embankments for the dugouts and those of the waterholes in MNP and will conveyed to an accepted location agreed upon by the West Gonja and Sawla-Tuna-kalba district assemblies and the management of the park, . This impact will only be limited to the construction phase site and therefore rated as negligible. 6.7.1.6 Soil Erosion and Changes in Drainage Pattern Removal of vegetation and subsequent excavation activities required for water systems and the viewing platforms may impact the existing drainage pattern in the area if they are located near streams or rivers. Final selection of sites indicates that none of the water systems are located close ESIA-MNP, GLRSSMP-EPA PCU, 2025 78 to streams or rivers. The risks of soil erosion and changes in drainage patterns would not be a major risk, The sides of the embankments will also be vegetated with vertiva grass to curb erosion and reduce sedimentation of the dugout The impact for this anticipated risk will be negligible. 6.7.1.7 Potential Fire Hazards and Risks The proposed sites selected for the construction of the water systems, viewing platforms as well as the camps and renovation of the Lovi Research Centre are located in the northern part of Ghana with Savana vegetation. This type of vegetation dries up during the dry season and prone to fire outbreak. The use of sources of fire such as matches and lighters and smoking of cigarette especially in the park by construction workers may cause fire outbreak and therefore affect the integrity of the flora and fauna. 6.7.1.8 Conflict between construction activities and livestock One of the occupations of the beneficiary communities is rearing of livestock. The animals are not confined and roam about looking for food to eat and water to drink. The movement of these livestock are likely to pose a risk of interfering with the construction activities especially for the water systems in the fringes of the park. 6.7.1.9 Disposal of Construction Spoils The construction spoils and debris generated at the site will have to be disposed of at an approved site to avoid environmental problems. The loading of the construction spoil into trucks and the movement of these trucks to and from may pose safety risks to both the construction workers and the communities along the haulage route. If the site for the disposal of the construction spoil is not carefully chosen, it may generate additional environmental challenges especially if the site is environmentally sensitive. The impact is rated moderate. 6.7.1.10 Liquid and Solid Waste Disposal Inadequate provision of portable restrooms/mobile toilets and garbage receptacles at the construction site could lead to unsanitary conditions. Resulting impacts could vary from unsightly littering of the site, fly and vermin infestations. It is essential to ensure that there is no direct defecation and discharge of untreated effluent into the nearby environment. 6.7.1.11 Occupational Health and Safety Risks ESIA-MNP, GLRSSMP-EPA PCU, 2025 79 Particulate matter and noise to be generated during construction phase could affect the health of workers if not managed well. Dust emissions, noise nuisance, vibration and other risk factors in the work environment can pose serious occupational health and safety problems such as respiratory diseases among others. The combined exposure of dust and noise could increase the risk of hypertension among workers, asthma, bronchitis, heart and lung disorders, sleep disorders, hearing loss etc. Another area of safety concern is the possibility of a fall of workers into the reservoir when it starts filling with water while construction is still going on. The use of heavy equipment such as excavators can also pose serious safety risks. This impact is rated moderate. 6.7.1.12 Community Health and Safety Risks During the construction phase especially of water systems for the fringe communities there will be no issues of dust, traffic, and community health and safety concerns. The earth materials excavated from dugouts near fringe communities will be used to create the embankments so there will no haulage of materials. The truck movement will only be the transporting of equipment. Dust may only be generated during excavation at the construction sites which are not close to the communities. 6.7.1.13 Gender based violence including sexual harassment, child abuse and Child Labour Exploitation The contractor will at all times use local labour if they are available. The Works Contractor could use children (child labour) for the construction works if proper checks and monitoring is not enforced. It will be necessary to ensure age verification of all workers, since it is sometimes difficult to define a person’s age simply from the physical appearance. There is also a possibility that construction workers may engage in acts of sexual exploitation and other forms of exploitation of workers if proper checks and monitoring are not enforced. Female workers/ female community members are at risk of gender-based violence including sexual harassment and exploitation from their male counterparts. According to the Domestic violence in Ghana document, 2016 its incidence among women decreased from 17.2 percent in 2008 to 10.3 percent in 2015 and that of men from 12.7 to 11.2 percent during the same period and this was higher in urban areas than rural. The inference is that the assessment area being rural has limited rate of gender-based violence. This impact is rated moderate. 6.7.1.14 Transmission of STDs including HIV/AIDS During the construction phase workers are likely to move from their permanent place of residence to the communities. There is the possibility of sexual promiscuity and if the partners are unprotected there is the likelihood of transfer of sexuality transmitted diseases from one partner to ESIA-MNP, GLRSSMP-EPA PCU, 2025 80 the other, especially HIV/AIDS. The estimated district adult HIV prevalent rate for the five districts which falls under the MNP are Sawla-Tuna-Kalba (0.67), West Gonja (0.68), Mamprugu Moagduri (0.33), Wa East (0.32) and North Gonja (0.68) (Ghana HIV Facts Sheet, 2020). These figures in the northern regions of Ghana are lowest compared to those of the southern regions. 6.7.2 Operational Phase Impacts Operational phase impacts have been identified to include the following; ✓ Water quality deterioration ✓ Potential drowning hazard ✓ Employment generation ✓ Socio-economic impacts ✓ Conflicts ✓ Potential flooding and diseases 6.7.2.1 Water Quality Deterioration The water systems for the fringe communities are meant to water livestock in the beneficiary communities, however, due to scarcity of water resources, it may be used for other domestic purposes such as cooking and drinking. Animals which will drink from the dugout are likely to defecate and urinate into the water which can lead to the deterioration of the quality of the water and render it unwholesome for other uses. The stagnant water may also serve as a breeding grounds for disease vectors which will have implications for the health of the people. This impact is rated major. 6.7.2.2 Potential Drowning Hazard/Fall from Platform During the operational phase of the water systems in the fringe communities, the dugouts will be full of water with a depth of about four meters. This will pose a serious risk of drowning to users, both human and animals, if measures are not put in place to prevent such incidences. The operation of the viewing platforms may lead to accidental fall of tourist if adequate measures are not instituted. The impact is rated major. 6.7.2.3 Inter community Conflicts The presence of adequate water for watering animals will attract livestock from nearby communities in the fringes of the Mole National Park to also benefit from the water. This may generate inter-community conflicts if not properly managed. ESIA-MNP, GLRSSMP-EPA PCU, 2025 81 6.7.2.4 Potential Flooding and Diseases The construction activities may lead to impoundments and stagnation of water, the physical locations of these water systems are at the low-lying areas of the communities and water catchment areas. In the event of high and prolonged rainfall events, the possibility of the dugouts overflowing their banks is very low considering experiences on dugouts constructed during the erstwhile Sustainable Land and Water Management Project. However, variations in rainfall patterns due to climate change make the risk of flooding unpredictable and when it happens it may also be accompanied by disease-causing contaminants which may affect the community members. This impact is rated moderate. 6.7.2.5 Analysis of Cumulative Impacts Regarding the analysis of cumulative impacts, it is anticipated that the impacts of individual interventions may be small, the cumulative effects of the past, present and reasonably foreseeable actions on biological resources and communities can be considerable. No significant cumulative impacts are expected on archaeology and cultural heritage, land use, air and water quality, noise, geology and soils. Overall, the cumulative impacts of the proposed civil works in the study area would be manageable with diligent adherence to World Bank standards and national requirements. Communities and resource agencies affected by these interventions have been substantially involved in the project planning and design of processes of these facilities to be constructed. The fruitful engagement the PCU, consultants and contractor had with them which the project will continue regularly will ensure that communities are not adversely affected or otherwise minor impacts can easily be mitigated. ESIA-MNP, GLRSSMP-EPA PCU, 2025 82 7.0 IMPACT MITIGATION AND ENHANCEMENT MEASURES Mitigation measures are meant to ensure that project impacts are prevented from happening or its effects minimized to acceptable levels. It is always appropriate to apply the mitigation hierarchy of avoidance, minimization and offsetting. Proper site selection and engineering and design may help avoid certain impacts. Where avoidance is not possible, design can further minimize the impacts of the proposed civil works so that the intensity is reduced or can be mitigated. After mitigation measures are put in place, a monitoring regime can help evaluate the effectiveness of the measure, and if ineffective, corrective measures can be made. In situations where the impacts are positive, further measures are proposed to optimize the beneficial effects 7.1 Type of Mitigation Measures The mitigation measures proposed for consideration have been classified into three main groups, based on the mitigation hierarchy: • Preventative measures; • Control measures; and • Compensatory measures. 7.1.1 Preventive Measures At the design and pre-construction phase, preventative measures are developed and adopted. The avoidance or minimisation of potential major impacts at source is the aim of preventive measures. Avoiding or reducing an impact at source is essentially ‘designing’ the project so that a feature causing an impact is designed out (e.g., site selection to avoid sensitive areas) or altered (e.g., working at night where necessary) or avoided (e.g., community sensitisation programmes to avoid conflicts or confrontations). Regarding child labour, prevention measures would primarily include sensitization on the problem in the community, workforce and contractors, age verification of workers, and the planning of works activities in such a way it does not affect negatively the use of children’s time in the households. For example, if parents or adult household members are undertaking remunerated work for the project, this should not negatively affect children’s school attendance. This could happen if the works activities are not adapted to also take into account the time adult household members need to manage the household and undertake domestic chores. ESIA-MNP, GLRSSMP-EPA PCU, 2025 83 7.1.2 Control Measures The measures adopted to abate or remedy the impacts occurring during construction and operation/maintenance phases are the control measures. The abatement of impacts could be done on site or off site. In instances where there is unavoidable damage to a resource, repair or remedy of impacts may be applied, e.g., re-vegetation of the affected areas where vegetation is cleared during land preparation. Regarding child labour, contractors and workforce would be trained on age verification of workers, and overall, what child labour is, in order to be able to identify cases, and know what to do if a case has been identified. 7.1.3 Compensatory Measures Where other mitigation measures are not possible or fully effective, compensation, when required, will be provided in accordance with the local standards as set forth by the relevant entities. 7.2 Mitigation Measures for Significant Potential Negative impacts The assessment revealed some significant potential project impacts for which mitigation measures will be required to ensure environmental soundness, social acceptability and project sustainability of both the construction and operation phases. While some of the measures will be in-built into the project design, others will be implemented during project execution. The mitigation measures outlined to address their respective constructive phase impacts are: • Habitat and Biodiversity protection measures; • Air quality control measures; • Noise reduction and vibration control measures; • Water contamination prevention measures; • Visual Intrusion management measures; • Erosion and Siltation control; • Fire hazard control and safety; • Conflict prevention measures • Land acquisition and compensation management measures • Construction debris management; • Occupational health and safety measures; • HIV/AIDS prevention and management; • Community health and safety measures; and • Gender Based Violence Child Abuse and Child Labour prevention measures. ESIA-MNP, GLRSSMP-EPA PCU, 2025 84 7.3 Mitigation of Construction Phase Impacts 7.3.1 Habitat and Biodiversity protection measures During the construction period, clearing of the land will be limited to only the designated place and trees that can remain will not be felled. Where reforestation is required, the project will task the Forest Services and Wildlife divisions to undertake this activity in consultation with management of MNP and community leaders in fringe communities. Workers will not be allowed to capture any form of wildlife in spite of the regular patrol of park guards, they will also be educated on biodiversity protection. Selection of final sites with the assistance of park management will be don’t to jeopardize any critical habitat if any. 7.3.2 Air quality control measures Construction machinery will be serviced regularly according to manufacturer’s specifications to avoid/minimise the release of particulate matter into the air. It is expected that where the water systems will be built will be wet and therefore the soil will not be loosened to the extent of releasing suspended particulate matter. However, in areas where the soil is dry, water dowsing will be frequent especially during the dry season to avoid/minimise dust pollution as a result of wind action. Minimum amount of particulate matter is expected to be released from the construction of the viewing platforms and camps whiles the renovation work will have no particulate matter emissions. 7.3.3 Noise reduction and vibration control measures Drivers of trucks and operators of construction machinery and equipment will be sensitised and required through regular safety meetings to use their horns only as a last resort in order to keep down noise levels at the project site. Construction equipment and machinery will be serviced regularly in order to keep their noise levels low. 7.3.4 Water contamination prevention measures Where the dugouts/waterholes will be constructed within the channels of streams and rivers, there will be temporary diversion so that the construction activities do not muddy the water and render it unwholesome for downstream users. The construction of the other infrastructures will not cause disturbance to the water resources within the park ESIA-MNP, GLRSSMP-EPA PCU, 2025 85 7.3.5 Visual Intrusion management measures During construction the project site will be fenced off and prevented from direct public view. This will also prevent unauthorized persons from accessing the site whiles construction is ongoing. The fencing will also prevent stray animals/wildlife from getting to the site which could be injurious. 7.3.6 Erosion and Siltation control Exposed soil surfaces will be compacted as much as possible to reduce erosion and siltation into water bodies. Sediment traps will be installed during construction to intercept solids from the site to prevent transport into near drainage systems. However, it is anticipated that construction of the water holes and dugouts will take place during the dry season in order to avoid sediment-laden runoff and erosion incidences. Also exposed land surfaces will be landscape and vegetated immediately to minimize sediment movement. 7.3.7 Fire hazard control and safety Using naked fire or any instrument that has the potential to spark or start fire on the construction site will be prohibited and regarded an offence. Petroleum products to fuel construction machinery will be kept in a bunded and safe place to avoid leakages and possible fire explosion. Wildfires are controlled by creating fire belts as a preventive measure and control burning are intentionally done by park management to also prevent wildfires. Other emergencies are also the responsibility of park management to ensure that appropriate authorities are involved to address the issue depending on which part of the park such emergency situation occur. In addition, first aid facilities are made available for victims immediately the situation occurs. 7.3.8 Conflict prevention and management measures As indicated earlier, the construction site will be fenced to prevent any access to unauthorized persons and animals from the fringe communities. This will avoid the possibility of stray animals having access to the site. It will further eliminate any potential conflicts between the contractor and the owners of these animals. 7.3.9 Construction waste management Waste Management The main construction waste and debris will be the cleared vegetation, excavated soil, construction rubbles, paint containers and campsites waste which will require disposal. The cleared vegetation which will be mostly organic can be deposited near the construction site, while the excavated soil will be disposed of at an approved site where it will not generate further environmental problems. The disposal of the soil will be discussed with the relevant community leadership and the relevant ESIA-MNP, GLRSSMP-EPA PCU, 2025 86 District Assemblies (West Gonja and Sawla-Tuna-Kalba) so that there will be common understanding in order to also reduce conflicts. . Plastic used by workers will also be collected in dustbins and disposed of at the appropriate dumpsite. Littering of plastics by workers will also be prohibited to protect pristine conditions of the site. During construction workers will be entitled to sanitary facilities such as mobile toilets and urinals. The job specification given to the contractor will ensure that provision is made for sanitary facilities for construction workers at the site to avoid unhygienic conditions. 7.3.10 Occupational health and safety measures The contractor will ensure that adequate and appropriate Personal Protective Equipment (PPE) and other facilities are provided in accordance with the Factories, Offices and Shops Act 1970, Act 328 and the relevant Environmental and Social Standards of the World Bank. Operators of noisy equipment and machinery will be provided with earmuffs, whilst others who will be working in the trenches and on the walls of the dugouts will be provided with harnesses when required. The contractor will enforce the use of PPEs and will have powers to sanction or reward workers of good behaviour. Traffic notices will be posted in the communities where haulage trucks will be passing to warn them of the potential dangers associated with the movement of the trucks. Speed limits will be imposed on all vehicles that will commute on the access road. The control of traffic to and from the site will help to avoid instances of vehicular-pedestrian conflicts. The contractor will hold weekly safety meetings with workers. 7.3.11 HIV/AIDS prevention and management Construction workers as well as the communities will be taken through an awareness and education programme on STDs, especially HIV/AIDS and the need to abstain or protect themselves. Preventive materials such as condoms will also be made available at vantage points such as the washrooms 7.3.12 Gender Based Violence Child Abuse and Child Labour prevention measures Efforts should be made to prevent project related GBV issues during construction and operation of infrastructure. Some measures to be instituted include • Require all contractors to have a Code of Conduct for project workers that explicitly prohibits, and includes expectations on gender-based violence (including sexual exploitation and abuse and sexual harassment (SEA/SH) as well as child and forced labour) misconduct; prohibits sexual contact with persons under 18; and contains clear sanctions in the event of breach ESIA-MNP, GLRSSMP-EPA PCU, 2025 87 • Require all contractors to regularly train employees on the GBV/SEA/SH Codes of Conduct and how to report incidents; • Require all contractors to document other SEA/SH risk mitigation measures (including incident response procedures) in their ESMPs or other safeguards instruments • Ensure the implementation of the project’s Grievance Mechanism which has special procedures for confidentially responding to GBV/SEA/SH complaints with a survivor- centred approach; and put in place a referral pathway to GBV service providers linked to the Grievance Mechanism; • Develop an incident response protocol to guide the Wildlife Division’s response to GBV/SEA/SH incidents (Accountability and Response Framework) • Sensitize communities on GBV/SEA/SH risks as well as reporting mechanisms and expectations; • Post contact numbers of representative on the Grievance Redress Committee and GBV Service Providers around the construction site • Indicate a minimum requirement of female employment in the human resource policy of the facility manager/operator 7.3.13 Child Protection and Child Labour In order to prevent child labor, the community, workforce and contractors will be sensitized on what child labour is, and why it is harmful to children, age verification of workers will be undertaken During the construction, contractors should only engage the right category of persons meeting the requisite minimum age requirement under the Ghana Children Act 1998 and the provisions made in the related World Bank ESS 2. Photo Identification with DOB (voter ID, NHIS card, SSNIT) should be provided prior to engagement of persons as proof of their legal age and all contractors will be required to have a Child Labour Policy in place and ensure their implementation. Force labour issues will also be included in contractors’ agreement and the Social Welfare of the District Assemblies will regularly monitor construction sites to ensure compliance. Child labour will also be prevented through planning works activities in such a way it does not affect negatively the use of children’s time in the households. For example, if parents or adult household members are undertaking remunerated work for the project, and if the works activities are not adapted to also take into account the time that adult household members need to manage the household and undertake domestic chores, this should not negatively affect children’s school attendance and opportunity to benefit from education. Thus, the work activities and engagement of adult workers for the project need to be carefully planned. Community members, contractors and workforce would also be trained on what child labour is, in order to be able to identify cases, and would be told what to do if a case has been identified. ESIA-MNP, GLRSSMP-EPA PCU, 2025 88 7.3.14 Mitigation measures for Potential Oil contamination of Soil In order to prevent the potential for oil leakages from construction machinery, the contractor will adhere to strict maintenance and servicing regime so that any leaking part of the machines will be detected as early as possible and maintained to prevent soil contamination by oil leakages. 7.4 Mitigation of Operational Phase Measure The mitigation measures outlined to address the operational phase impacts include the following; ✓ Water quality deterioration prevention measures ✓ Potential drowning hazard prevention measures ✓ Socio-economic impacts mitigation measures ✓ Conflicts prevention and management measures ✓ Potential flooding and diseases prevention and management measures 7.4.1 Water Quality Deterioration prevention and control measures The dugout are being developed to serve the needs of the beneficiary communities mainly for livestock watering. In order to prevent deterioration of the water quality, the design will include water trough where little quantities may be collected where the animals will drink from instead of entering the reservoir. Notices such as ‘do not defecate’ will be posted around the dugout as a form of education and caution to community members to maintain the quality of water that will be collected in the dugout. 7.4.2 Potential Drowning Hazard/ Fall prevention measures The depth of the water at the deepest part may range from 2.5 to 4 meters. The potential risk for users’ drowning will be high. The design permits a slope of 20 % that permits animals and humans to fetch water from predetermined entrance to prevent drowning. Additional strategies to prevent drowning of humans may include the following: • Warning notice will be posted to indicate ‘no swimming’, ‘danger of drowning’ etc. • There will be extensive education in the communities on the use of the water including how to prevent the risk of drowning. There can be accidental fall of tourist from the viewing platforms. Forest/Tourist will be available to orient tourist on the precautionary measures to take when viewing game from the platform. The design of the platform will have some ‘benches’ where tourist can sit and view the game ESIA-MNP, GLRSSMP-EPA PCU, 2025 89 7.4.3 Conflicts prevention and management measures Conflicts may arise when there is disagreement between or among parties. The dugout will not be provided in every fringe community and therefore those who will not be direct beneficiaries may also want to send their livestock to drink from the dugout especially during the dry season when there is scarcity of water. This has the potential for conflicts between any two communities within the project area. Conflicts will be resolved through the following means; • A Water Management Committee (WMC) will be put in place in all the beneficiary communities where there are no existing ones, to oversee the use and management of the water. The committee will comprise representative from the traditional authority, cattle owners, women, youth, assemblyman/woman, farmers etc. • The Community Resource Management Committee (CRMCs) will be put in place in beneficiary communities where there are no existing ones to oversee the use and management of the processing facilities The Community Resource Management Committee (CRMCs) will be put in place in beneficiary communities where there are no existing ones to oversee the use and management of the processing facilities The committee will comprise representatives of all units within the community i.e. traditional authority, women representative, assemblyman/woman, leader of Fulani herdsmen, farmers association, unit committee members, youth groups, fisher folk etc. • A grievance redress mechanism will be put in place as part of the management of the dugout. This will spell out the processes for reporting and resolving the conflicts • Water sharing mechanisms among the communities will be developed to allow for the use of the water by other communities. 7.4.4 Fire prevention and control measures The operational phase of the water systems especially those in the fringe communities will not have a direct linkage with fire hazards but the potential for water users to set fire into the vegetation around will be very high. The major tool for managing fire will be education and awareness creation. The community members will be educated on the hazards of fire and the need to prevent it from happening and more importantly maintain the vegetation around the dugout. 7.4.5 Potential Flooding and Diseases prevention and management measures Flood control measures such as weir and appropriate buffers will be provided so that in the event of flooding it will not affect any of the communities. The dugouts are also sited far away from communities in order to reduce the risk of flooding. In addition, District Engineers of the various Assemblies the locations of the dugout and the Ghana Hydrological Authority will be involved in the review of design sessions to be organised by the Consulting firm. ESIA-MNP, GLRSSMP-EPA PCU, 2025 90 7.4.6 Cultural Heritage The World Bank Environmental and Social Standard 8 recognizes the importance of cultural heritage for current and future generations and the need to preserve and protect cultural heritage from the adverse impacts of sub-project activities. It therefore requires the assessment of the project impact on cultural heritage of the people. The consultation therefore tried to solicit information on any cultural heritage within the project area of influence that may be affected by the project. There was no indication that there exists any cultural heritage that may be physically affected by the sub-projects. What could not be identified is cultural heritage that might have been buried underground and are previously unknown. Such cultural heritage that may be found by chance during implementation of sub-project activities will be managed using the chance finds procedure described in section 8.9.7. ESIA-MNP, GLRSSMP-EPA PCU, 2025 91 8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN This Environmental and Social Management Plan (ESMP) has been developed for the proposed civil works in and around the Mole National Park in compliance with the requirements of the Ghana Environmental Assessment Regulations of 1999, (LI 1652), and the relevant World Bank environmental and social standards to guide the implementation in an environmentally and socially sound and sustainable manner. 8.1 Objectives of the ESMP The following are the objectives for the implementation of the ESMP: ▪ Manage impacts during the implementation phase of the project ▪ Ensure satisfactory environmental and social performance ▪ Provide a platform to accommodate changes and uncertainties during project implementation. 8.2 Environmental and Social Risk Management Team In order to maintain control over the implementation of the project and also ensure that commitments made in the Environmental and Social Impact Assessment (ESIA) are acted upon in a comprehensive and acceptable manner to meet World Bank and national requirements. The ESRM team will comprise the existing structures at the national, regional, district and community level i.e. Safeguards officer (PCU), Technical Coordination office (TCO), EPA Area office/WD and CWMTs/CRMCs. The Project ESRM Team will be responsible for the following: • Ensuring project’s compliance with all relevant environmental, social, health and safety regulations • Liaising with all relevant regulatory bodies and organizations to ensure compliance • Formulating and reviewing environmental and social policies and practices associated with the projects • Assisting in the education and training of project staff in environmental, social and safety awareness • Making budgetary provisions for projects’ environmental programmes • Undertaking environmental and social safeguard monitoring activities for the subprojects ESIA-MNP, GLRSSMP-EPA PCU, 2025 92 8.3 Environmental and Social Management Structure The Project Coordinating Unit (PCU) and the Safeguard Officers are responsible, among others, for project development as well as the implementation of all ESRM-related activities. The post-construction or operational phase environmental management will be incorporated into the relevant MMDAs Medium Term Development Plans (MTDP) and implemented by the beneficiary communities. To ensure that the environment is managed efficiently, requisite training shall be provided for the members of the Project Coordinating Unit, Beneficiary Agencies, and the Community Watershed Management Teams, (CWMTs), CREMA Executive Committees (CEC) / Community Resource Management Committees (CRMCs). 8.3.1 Project Coordinating Unit (PCU) The PCU will be responsible for all project activities including management of environmental and social issues associated with the project. The PCU is responsible for: • Monitoring all environmental and social programs for pre-construction, construction and operational phases of the project, including issues relating to bio-physical and socio- cultural and economic components. • Working closely with project contractors to ensure that all monitoring and mitigation guidelines, recommendations for the project are adhered to. This includes compliance with all health, social and safety guidelines outlined and environmental policy guidelines. • Working closely and coordinating efforts with the EPA and other regulatory bodies including the MMDAs to ensure full compliance with all legal and regulatory requirements • Organizing activities to motivate and maintain the interest of the project staff in social and environmental issues through training programs and review meetings • Conducting investigations into all types of accidents and incidents • Conducting environmental and social audits in accordance with project monitoring guidelines • Serving as liaison between project contractors and the relevant regulatory agencies • Developing a work plan for the implementation of the ESMP • Establishing and running a reporting system on progress of implementing mitigation measures (including contractors’ obligations), training, etc. 8.4 General Health and Safety Procedures Procedures relating to occupational safety and health will be guided by the Occupational Safety and Health Policy for Ghana (Draft 2004), the Public Health Act, 2012 (Act 851) and the World Bank Group Guidelines on Environment, Health and Safety. Some highlights are provided below; ESIA-MNP, GLRSSMP-EPA PCU, 2025 93 • Manual lifting • Hearing protection • Protective equipment • Good house keeping • Fire prevention • Prevention of falls from heights • Electrical hazards • Machinery safety • Welding safety • Head protection • Feet protection • Provision of first aid items All the applicable occupational safety and health provisions in the Factories, Offices and Shops Act 328, (1970) shall be complied with during the implementation of the project. The mitigation measures recommended in the ESIA will also be fully implemented 8.4.1 Fire Prevention and Safety System The general fire precaution to be taken during construction includes: ✓ The posting of “no smoking� signs at fire sensitive areas (e.g. fuel storage areas at the work camp, etc.) ✓ Provision of appropriate and adequate number of fire extinguishers ✓ Proper storage of rags used in cleaning hazards and containing flammable liquids (e.g. in metal containers for safe disposal) ✓ Handling of flammable materials by competent persons only ✓ Provision of emergency fire alarm systems In addition, fire prevention and containment training would be carried out for all project employees at construction sites for civil works. At the end of the training, the personnel would have adequate knowledge of all fire prevention systems recommended in the ESIA. 8.4.2 Change Management The PCU recognizes that environmental and social issues that are covered by the project ESIA and ESMP could change (in terms of severity, magnitude, etc.) as the project proceeds. The Project Coordination Unit (PCU) will responsible for change management. The PCU shall specifically undertake the following. ESIA-MNP, GLRSSMP-EPA PCU, 2025 94 ✓ Preview internal environmental reports ✓ Monitor Project development, and observe significant issues as they arise ✓ Make decisions about modifications to mitigation and monitoring needs and requirements ✓ Advice on external reporting on environmental and social issues, as required 8.4.3 Documenting Voluntary Donation of Community Lands As their contribution, beneficiary communities have donated lands towards the delivery of the sub- projects. The Lands Act, 2020 (Act 1036) refers to such voluntary donation of land to the state as “gifts� and emphasises the need for documentation. Per ESS 5, a Voluntary Land Donation (VLD), as a method of acquisition of land for a Bank project is allowed, provided that the conditions set out in the VLD protocol are met, and certain confirmations concerning the donation are made by the proponent. In this regard, an agreement template (appendix 4.8.5) for documenting VLDs has already been prepared. The template contains the conditions set out in the VLD protocol and outlines the confirmations to be made as part of the documentation process. It is important to clarify that the template is applicable to the facilities to be constructed in the fringe communities, as lands there are customary owned lands. However, in respect of the facilities to be constructed within the boundaries of the Mole National Park itself, the Lands Commission and Forestry Commission will advise on land allocations processes and documentation. Also, The PCU will work closely with the Lands Commission (LC) and Land Use and Spatial Planning Authority (LUSPA) offices responsible for the location of each land. For each location, LUSPA will confirm the conformity of the planned development with the land use plan of the area, and grant permits accordingly. Before each agreement is signed/ executed with the relevant community representatives, a consultation session will be organized to sensitize the community people and their leaders on the agreement and its provisions. Any concerns raised would be addressed. A transparent record of all such consultations and agreements reached around the land donation will be kept by the PCU. As part of the efforts to ensure transparency and inclusion in the consultations, any Customary Land Secretariat (CLS) that exists in any location for a sub-project would be involved in the processes, and copies of executed agreements would be lodged with the CLS for safekeeping on behalf of their communities, aside copies to be given to the community leadership. 8.5 Cost of Environmental Management The PCU will make human resources available for environmental management and enhancement. In addition, financial provision shall be made to ensure that mitigation measures (including compensation), monitoring and training programs are effectively implemented. The PCU will ESIA-MNP, GLRSSMP-EPA PCU, 2025 95 make the necessary budgetary provisions to cover all commitments for the construction and management of the water systems (dugouts, waterholes), viewing platform, processing facilities, camps. Budgetary provision for environmental management during construction will be part of the contractor’s cost and would be adequately provisioned for. 8.6 Environmental Management during Construction Phase The construction phase negative impacts identified in the ESIA will be directly associated with the activities of the contractor E&S management during the construction phase is essentially concerned with controlling impacts, which could result from the activities of the Contractor. This would be done through the enforcement of Contract Clauses which relate to environmental and social protection. These clauses will have effect if they are fully implemented and enforced. The PCU will therefore ensure compliance through the following measures: • Monitor the progress of the contractor in implementing the mitigation measures outlined in the Contract documents and ESIA as well as the contractor ESMP. • Liaising with regulatory bodies to ensure that policies, procedures and environmental management issues are complied with. • Coordinating parties involved in the impact mitigation and enhancement process, including: contractors, consultants, as well as the general public 8.6.1 Responsibilities of the Project Engineer ➢ Supervise and enforce the Contractor’s performance on all environmental/social requirements included in the Contractor Documents. ➢ Monitor the overall environmental and social impacts of the project and recommend additional mitigation measures for implementation when deemed necessary. ➢ Liaise with the local health institutions and undertake educational awareness raising campaigns on issues of health and safety, GBV/SEA/SH and grievance redress. 8.7 Environmental and Social Management Responsibilities The negative impacts expected from the project were outlined and the corresponding mitigation measures were also proposed for implementation. An important consideration for this project is the implementation phase where the immediate environment could be degraded. The key stakeholders in the environmental management of the project are the Engineer (designer and supervisor), the Contractor and the general public. The plan outlined below allocates the responsibility for implementation of the proposed mitigation measures to the various stakeholders. ESIA-MNP, GLRSSMP-EPA PCU, 2025 96 8.7.1 Environmental Management Responsibilities of the Engineer • Design the project for the least negative environmental impact during the construction and operational phases of the project • Design the project for environmentally friendly construction methods • Design the project prescribing materials with the least negative environmental impact. • Incorporate any feasible safely measures within the project design • The Engineer shall incorporate all suitable clauses requiring the contractor to execute his work with due diligence and applying environmentally friendly methods. Any such requirement must be accompanied by the necessary methods for monitoring and enforcement. Clauses with principle content as outlined below are considered as the minimum requirement • The Engineer will supervise and enforce the Contractors performance on all environmental requirements included in the Contract Documents. • The Engineer will monitor the overall environmental impact of the project and recommend additional mitigation measures for implementation when deemed necessary • The Engineer will liaise with the local health and educational authorities to plan and implement an agreed awareness raising campaigns. 8.7.2 Environmental Management Responsibilities of the Contractor The responsibilities of the contractor are indicated below; • Mobilization: - Ensure that all staff, including managers and foremen are well informed about all environmental/social (including GBV/SEA/SH, Child Labour and grievance mechanism) issues of the project, and ensuring that they all sign on to a Code of Conduct (CoC) that explicitly include expectations and consequences for GBV/SEA/SH and Child Labour-related misconduct • Ensure that all site managers and foremen are trained in environmentally friendly construction methods • Ensure that all equipment mobilized fulfils the environmental requirements per the Contract Document • Obtain necessary approvals for all borrow pits • Requirement for the Contractor to prepare and submit plans for borrow pit management for approval by the relevant authorities and the Engineer in due time before starting any clearing activity at the site • Establish a waste management plan comprising all types of wastes • Apply environmentally friendly equipment and construction methods • The Contractor is responsible for maintaining and operating own and sub-contractors equipment in accordance with the original manufacturer’s specifications and service ESIA-MNP, GLRSSMP-EPA PCU, 2025 97 manuals to control noise, vibrations and particulate emissions. Faulty equipment must be rectified or replaced within 24 hours of being given notice. • Ensure occupational health and safety for all workers and visitors to the sites. • Fulfil all environmental requirements of the Contract Document • Inform the Supervising Engineer if any unforeseen negative environmental impact should occur Ensure that all affected project areas have been properly cleaned of waste, graded and re-vegetated • The Contractor is responsible for providing safe passage around or through his work site. • The contractor is responsible for conducting the necessary community entries, developing appropriate relationships with community folks and leadership, properly implementing the grievance redress mechanism, communicating proactively and conducting meaningful consultations with community people, providing the required sensitisation to manage risks of GBV/SEA/SH as well as managing any potential risk of influx of migrant workers. • The contractor must have adequate relevant knowledge of the rules and regulation for environmental protection in Ghana which must include; o Noise nuisance o Air quality o Water pollution o Waste management 8.8 Reviews Based on Monitoring Outcomes There will be continuous monitoring of the project activities during both the construction and operation phases. The outcome of these monitoring activities may require changes in the proposed mitigation measures to improve upon their effectiveness and adequacy. The monitoring plan is therefore very key to this ESMP 8.9 Programme to meet Requirements of the ESMP The programmes proposed to enhance mitigation measures and monitoring programmes include the following: ▪ Development and Implementation of a Construction Management Plan; ▪ Adoption of Environmental Health and Safety Plan; ▪ ▪ Environmental Health and Safety Committee ▪ Contractors’ ESMP (including the Community Safety and Traffic Management Plan, and the Occupational Health and Safety Plan) ▪ Workers’ training and awareness creation ▪ Environmental and Social Monitoring Programme ESIA-MNP, GLRSSMP-EPA PCU, 2025 98 ▪ Community Safety and Traffic Management Plan ▪ Occupational Health and Safety Plan ▪ GBV/Sexual Harassment & Abuse ▪ Child Labour ▪ Management Plan and Training/Capacity Building ▪ Emergency Response Plan with respect to the potential issues relating to the operational efficiencies and management of the GLRSSMP subprojects and infrastructure facilities ▪ Public and community participation; ▪ Grievance Redress Mechanism ▪ E&S Audits and Reviews; 8.9.1 Development and Implementation of Construction Management Plan (CMP) The GLRSSMP-EPA PCU will require bidders for the GLRSSMP subprojects to develop and implement a Construction Management Plan. This requirement will be spelled out in the GLRSSMP Subprojects’ contract, which will be performance-based. The plan will cover the following: ▪ Introduction - Indicating the contract Administrative Jurisdiction, Site Location, Site Overview and Development Overview. ▪ Construction Programme and Phasing. ▪ Site Establishment - Site Office and Compound, Site Hoarding and Security, Construction Personnel Numbers, Site Access (Pedestrian and Vehicle Access), Construction Vehicle Numbers, Onsite Construction Parking, Logistics Planning ▪ Site Monitoring and Management including Noise Monitoring, Vibration Monitoring, Air Quality, Dust Control and Monitoring, Site Management and Security, Covered Vehicles and Dust Suppression. ▪ Substructure and Superstructure Construction Methodology. ▪ Health and Safety including General Health, Safety and Environmental Considerations, Control of Substances Hazardous to Health, Environmental, Emergency and Accident Procedure. ▪ Construction Stage Community Liaison indicating Code of Practices, Respect for the Community, Community Liaison Manager and Community Programmes. 8.9.2 Adoption of Environmental, Health and Safety Management Plan The Contractor shall develop an environmental, health and safety plan to guide the sustainable implementation of the project. The GLRSSMP-EPA PCU shall ensure that contractors implement the EHS Plan. The plan, which should include Code of Conduct, GBV/SH/SEA Child Labour issues and standard operating procedures, will serve to guide the workers in their daily activities ESIA-MNP, GLRSSMP-EPA PCU, 2025 99 and also serve as a training manual for in-service training as well as induction of new workers engaged on the project. 8.9.3 Contractors’ ESMP (C-ESMP) The contractors executing the various GLRSSMP subprojects will prepare a Contractor’s ESMP to be approved by the GLRSSMP-EPA PCU prior to the commencement of civil works. The C- ESMP will be used for the implementation of the various environmental and social actions aimed at managing various potential impacts and risks from construction of the GLRSSMP Subproject. The following outline can be considered by the Contractor as a guide for preparation of the C- ESMP: • Introduction • Brief Description of the Civil works and Construction Activities • Legal and Other Requirements • Roles and Responsibilities • Environmental and Social Management • Health and Safety Management • Community Liaison and Grievance Redress • Compliance and Monitoring • Incidents, Non-Conformance and Preventive Actions • Reporting; • Implementation Schedule and Cost Estimates, and • Conclusion. 8.9.4 Worker’s Training and Awareness Creation The contractor will ensure effective dissemination of information to all staff on the GLRSSMP subproject. Training programmes will be regularly organised on environmental, health and safety. These will include formal in-service training, and induction for new staff. The trainings will include the following: • EHS policies and procedures; • Worker Code of Conduct • Standard operating procedures; • Machine/equipment handling and operation; • Road safety and traffic regulations; • Public health and sanitation; • Gender-based violence/Sexual harassment/Sexual exploitation and abuse ESIA-MNP, GLRSSMP-EPA PCU, 2025 100 • Emergency response; and • Occupational health and safety, including First aid. 8.9.5 Environmental and Social Monitoring Programme Comprehensive monitoring programmes will be developed based on the monitoring plan provided in Section 11 for relevant environmental and social monitoring parameters. 8.9.6 Archaeological and Cultural Heritage Chance Find Procedure In the event of finding previously unknown sites or feature of archaeological or cultural value during project implementation, the following standard procedures for identification, protection from theft, treatment and recording should be followed. Specifically the procedures will be to (a) Stop the activities in the area of the chance find. (b) Delineate the discovered site or area. (c) Secure the site to prevent any damage or loss of removable objects. (d) Notify the Supervising Engineer who in turn will notify the responsible authorities. (e) The Ministry of Tourism, in collaboration with responsible local authorities (where applicable), would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures. (f) The Ministry of Tourism and National Museums and Monument Board will make decisions on how to handle the findings. This could include changes in the layout (such as when finding irremovable remains of cultural or archaeological importance), conservation, restoration, and salvage. (g) The Ministry of Tourism shall communicate implementation of the authority decision concerning the management of the finding in writing. (h) Construction work could resume only after permission is given from Ministry of Tourism or other responsible authorities concerned with safeguarding the cultural heritage. These procedures shall be referred to as standard provisions in construction contracts, E&S Procedures for Inclusion in the Technical Specifications for Contracts. During project supervision, the Site Engineer shall monitor the above regulations relating to the treatment of any chance find encountered. Relevant findings will be recorded in the Monitoring Reports. 8.10 Grievance Redress Mechanism The GLRSSMP and the African Environmental Health and Pollution Management Project (AEHPMP), which are World Bank investment projects, have developed a common Grievance ESIA-MNP, GLRSSMP-EPA PCU, 2025 101 Redress Mechanism (GRM) because of the significant overlap of beneficiary districts and the role EPA plays on both projects. The objective of the Grievance Redress Mechanism (GRM) is to provide clear channels and platforms for receiving and addressing complaints raised by project affected persons (PAPS), communities and other interest groups on the implementation of project activities in a timely, impartial and transparent manner. The GRM consists of four levels and has various structures within these levels for receiving of complaints and addressing them. Complaints are escalated to the next higher level if they are not resolved. For the purpose of this report the levels and structures mentioned below are for the landscape component of the GLRSSMP. Community Level At the community level the structures for receiving and resolving complaints are; community watershed management team (CWMT) for farmers in beneficiary communities and community resource management committee (CRMC) for CREMA beneficiary communities. District Level At the district level two structures namely the district watershed management (DWMTs) and the protected areas management advisory units (PAMAUs). Regional Level The main regional structure for the Landscape component of the GLRSSMP is the two (2) Technical Coordination Offices in Bolgatanga for the northern savannah zone and in Kumasi for the transitional and cocoa forest landscape area. All the beneficial and implementing Agencies are represented in the TCO. National Level At the national level, all complaints from all the other three levels resolved or unresolved will be sent to the main portal. The EPA Project Coordinating Unit (PCU) manages this portal through the Client Relations Unit (CRU). However, gender based violence, sexual exploitation abuse/sexual harassment and child labour (GBV/SEA/SH, CL) complaints will be referred to the Domestic Violence and Victim Support Unit (DOVVSU) of the Ghana Police Service and the Department of Social Welfare to address such complaints and wherever such situations occurs the committee at that level will have the duty to map out public or private institutions whose operations cover such offences to also assist in addressing such issues. These national institutions shall provide feedback information to the EPA- PCU and consequently to victims. The various structures will be provided with complaint receiving forms developed to administer complaints and for record purposes (see annexe 7). In addition, active telephone numbers of beneficiary institutions (EPA, MoFA, WD and FSD) in the district will also be provided for the ESIA-MNP, GLRSSMP-EPA PCU, 2025 102 community structures for any clarification they may require concerning complaints. Field officers i.e. EPA PCU Safeguards officers, MoFA Schedule officers and Agricultural Extension Agents will always be available to assist community structures to administer complaints at that level. 8.10.1 Workers GRM Contractors engaged by the project shall implement a GRM system, which is part of their contractors environmental and social management plans (CESMP) and forms an integral part of the contractual agreement approved by the PCU. The GRM will ensure that complaints from workers engaged by the contractor shall be received and addressed in a timely and transparent manner. A complaint log will be made available to contractors for record and monitoring purposes. 8.11 Environmental and Social Budgeting An amount of USD 138,000 (excluding contractor and design consultant cost) will be required for environmental management including monitoring and reporting as shown in Table 8-1. Table 8-1: Estimated Budget for Environmental and Social Management No Activity Cost/p.a (USD) 1 Implementation of mitigation measures-ESMP (see Table 9-2): • Construction Phase In contractor’s fees • Operational Phase In project’s Environment and safeguard Budget 2 Training and Capacity Building (See Table 10-2) 73,000.00 3 Environmental Auditing and Reporting: 15,000.00 Quarterly environmental, health and safety audits Returns of Monitoring Reports to EPA (In compliance with LI 1652) Preparation of Environmental and Social Management Plan every 3 years (In compliance with LI 1652) 4 Environmental and Social Monitoring Plan (See Table 11-1) 50,000.00 5 ESMP and Implementation of Grievance Redress Mechanism (Existing - GLRSSM-EPA-PCU Budget) Total 138,000.00 ESIA-MNP, GLRSSMP-EPA PCU, 2025 103 Table 8-2: Environmental and Social Management Plan: Proposed Civil Works in and around Mole National Park No Potential Impacts Key Mitigation Measures Objective Budget/Cost Timeframe Responsibility (USD) Construction Phase ▪ Careful site selection for the infrastructure ▪ To protect key ▪ ▪ Engineering ▪ Contractor ▪ Development of Biodiversity management habitat ▪ Reforestation Design and ▪ MNP Management plant if required ▪ To avoid areas will be part of Construction (Ecologists) ▪ Careful planning and timing of of conservation PCU budget ▪ PCU (WD & FSD) 1 Biodiversity construction activities. interest ▪ Limit clearing to only designated areas needed for the infrastructure ▪ Reforestation to be done by the FSD and Wildlife as pert PCU activity ▪ Regular servicing and maintenance of ▪ Minimize Safeguards Construction Contractor, construction equipment particulate budget (PCU) GLRSSMP-EPA PCU Ambient Air 2 ▪ Water dousing in dry construction areas matter emission Quality/Noise ▪ Limit the use of horns in the community ▪ Reduce noise nuisance ▪ For in-stream works, use isolation ▪ To limit the ▪ In ▪ Engineering ▪ Contractor techniques such as diversion during exposure of Contractor’s Design and Disturbance to construction to limit the exposure of disturbed fees Construction 3 waterbodies/erosion disturbed sediments to moving water. sediments to and siltation ▪ Exposed surfaces will be compacted as moving water much as possible Construction sites will be fenced Not to disturb In Design and Contractor Visual For construction activities in the park, the aesthetics in Contractor’s construction 4 intrusion/aesthetics materials or appropriate colours will be the fees used park/community ESIA-MNP, GLRSSMP-EPA PCU, 2025 104 No Potential Impacts Key Mitigation Measures Objective Budget/Cost Timeframe Responsibility (USD) Petroleum products and other fire Eliminate the Construction Contractor flammable materials are kept risk of fires and PCU budget Park management and appropriately Reduce the PCU Ensure activities that are likely to cause incidence of fire fire are prevented at construction Fire Hazard and 5 Creation of fire-belts around construction sites other emergencies sites and dealing with emergency situation through collaboration between contractors and park management Provision of first aid facilities to deal with emergencies ▪ Establishing a waste management ▪ Ensure proper ▪ In ▪ Engineering ▪ Contractor hierarchy at the construction site management of Contractor’s Design and Solid and liquid ▪ Constructions waste should be disposed of solid and liquid fees Construction 6 wastes in partnership with the Assembly waste ▪ Provide sanitary facilities for construction workers ▪ Fenced off construction sites to prevent ▪ Ensure social ▪In ▪ Engineering • District falls and accidents cohesion Environmental Design and Assembly/ ▪ Sensitize the community on the objectives between the and social Tendering • PCU E&S 7 Social Conflict of the project project, safeguard ▪ construction Safeguards ▪ Contractor to use local labour as much as contractor and budget Officer possible community • Contractor ▪ Create awareness on the construction ▪ To ensure ▪ In ▪ Engineering • PCU E&S Safeguards activities including schedules of work community Environmental Design and Officer ▪ Promote education among workers to safety and and social Tendering ▪ Contractor Community Health 8 reduce the transmission of HIV/AIDS and prevent safeguard ▪ construction and Safety other sexually transmitted diseases transmission of budget (STDs). STDs ESIA-MNP, GLRSSMP-EPA PCU, 2025 105 No Potential Impacts Key Mitigation Measures Objective Budget/Cost Timeframe Responsibility (USD) Occupational ▪ Provision of appropriate PPEs and ensure ▪ To ensure ▪ In ▪ Engineering ▪ PCU E&S Health and Safety their use workers are safe Environmental Design and Safeguards 9 issues (accidents, ▪ Develop labour management plan from and social Tendering Officer injury/ailments to ▪ Continuous education and awareness on occupational risk safeguard ▪ construction ▪ Contractor workers) safety working and hazards budget Contractors to engage the right category of To prevent Child In Environmental Engineering • PCU E&S Safeguards persons for construction work in accordance labour and abuse and social Design and Officer with ESS 2 and Ghana’s Labour Law of construction safeguard budget Tendering ▪ Contractor Child labour and Verification of age of prospective workers workers construction abuse of with available means (photo identification) 10 construction workers Workforce and contractors will be sensitized on what child labour is, and why it is harmful to children, age verification of workers will be undertaken ▪ Contractor to ensure all workers sign and ▪ To prevent ▪ In ▪ Engineering • E E&S Safeguards abide by the code of conduct on GBV and workers from Environmental Design and Officer SEA/SH sexually and social Tendering ▪ Contractor 11 GBV/SH/SEA ▪ Sensitize the community on the project exploiting safeguard ▪ construction GRM especially on reporting of incidences community budget members Operational Phase ▪ ▪ Appropriate notices such as ‘do not Avoid pollution of ▪ In ▪ Operational ▪ E&S Safeguards defecate’, ‘do not farm’ will be posted in the the water systems Environmental period Officer 1 Water Quality vicinity of the dugouts and waterholes and social safeguard budget Potential • Warning notice will be posted to To ensure ▪ In ▪ Operational ▪ E&S Safeguards Drowning/Fall indicate ‘no swimming’, ‘danger of community safety Environmental period Officer 2 from Viewing drowning’ etc. and social ▪ Community Platform ESIA-MNP, GLRSSMP-EPA PCU, 2025 106 No Potential Impacts Key Mitigation Measures Objective Budget/Cost Timeframe Responsibility (USD) • There will be extensive education in safeguard the communities on the use of the budget water including how to prevent the risk of drowning. • A Water Management Committee Improve cohesion ▪ In ▪ Operational ▪ E&S Safeguards (WMC) will be put in place in all the among fringe Environmental Period Officer beneficiary communities to oversee communities and social ▪ Community the use and management of the water safeguard • A grievance redress mechanism will budget be put in place as part of the 3 Social Conflict management of the dugout. This will spell out the processes for reporting and resolving the conflicts • Water sharing mechanisms among the communities will be developed to allow for the use of the water by other communities • Education and awareness creation on Ensure the ▪ In ▪ Operational ▪ E&S Safeguards fire management practices infrastructures are Environmental period Officer 4 Fire • Undertake tree growing along the protected from and social ▪ Community boundaries of the water systems fires safeguards budget ESIA-MNP, GLRSSMP-EPA PCU, 2025 107 9.0 INSTITUTIONAL ARRANGEMENTS The project is being coordinated by the Environmental Protection Agency under the auspices of Ministry of Environment, Science, Technology and Innovation (MESTI). The Directorate of Crop Services and the Wildlife Division of the Forestry Commission, who are beneficiary institutions, are under the umbrellas of the Ministry of Food and Agriculture (MOFA) and the Ministry of Lands and Natural Resources (MLNR) respectively. Additionally, proposed institutional responsibilities for both the construction and operation phases as well as the monitoring of the proposed projects have been defined in table 9-1 below. Table 9-1: Institutional Roles and Responsibilities Institution Responsibility Phase of Implementation Environmental ▪ Overall responsibility for the design and Project lifespan Protection implementation of the civil works under (design and Agency/GLRSSMP- component 3 of GLRSSMP implementation) EPA-PCU ▪ Lead community entry processes with community leaders and chiefs disclosing project objectives and documentation of VLD processes ▪ Implementation, management, oversight, and monitoring of the project interventions ▪ Enter into contracts with Contractors/Consultants including the ESIA Consultant and Design Consultants. ▪ Ensure all design measures proposed in the ESIA are incorporated in the project design and implemented. ▪ Ensure all necessary environmental reports, permits and approvals such as ESIA, environmental permits, etc. are prepared/ obtained for the project. ▪ Ensure that all measures during the pre- construction phase are addressed by the GLRSSMP-EPA-PCU and the Supervision Consultants ▪ Managing administrative processes and related reporting, and public/community relations. ▪ Enter into and manage contracts with contractor(s) ▪ Supervision of contractor(s) and works at the GLRSSMP Civil works sites ESIA-MNP, GLRSSMP-EPA PCU, 2025 108 Institution Responsibility Phase of Implementation ▪ Lead in addressing grievances ▪ Facilitate/support stakeholder engagement Forestry ▪ Responsible for the monitoring and evaluation of Project lifespan Commission/Wildlif project activities which include reviewing of design (design and e Division/MoFA and other reports submitted by all project consultants to implementation) (Directorate of Crop the Agency Services) ▪ Ecologist from WD (MNP) will assess biodiversity and habitat changed Design Consultant/ Responsible for the E&S Due Diligence, design and Pre-Construction, Supervising overall supervision of construction works and conduct Construction, Engineer of the contractor. Operation and Ensure environmental and social management Decommissioning considerations in the project design are implemented Phases during construction. Contractor ▪ Implement all environmental and social management Construction measures in the project designs and ESIAs/ESMPs during construction. ▪ Responsible for environmental and social management of the project during construction. ▪ Responsible for the health and safety and welfare of workers and communities during construction. Traditional ▪ Local needs definition and prioritisation Project lifespan Authorities/Opinion ▪ Local knowledge and values (design, Leaders ▪ Community planning and mobilisation construction, ▪ Mobilisation of local assets and resources operation and ▪ Monitoring and evaluation maintenance and ▪ Internal organisation and conflict resolution monitoring) NGOs /CBOs ▪ Local needs assessment Project lifespan ▪ Community mobilisation and participation in project (design, delivery construction, ▪ Community project design and implementation operation and ▪ Leverage external funding for community support maintenance and ▪ Monitoring and evaluation monitoring) Respective ▪ Collaborate with various consultants to manage Project lifespan Beneficiary communication and information dissemination to (design, Municipal/District the public during the project duration construction, Assemblies ▪ Assist with community sensitization/ engagements operation and ▪ Monitoring maintenance and ▪ Play a role in grievance resolution. monitoring) ESIA-MNP, GLRSSMP-EPA PCU, 2025 109 Institution Responsibility Phase of Implementation ▪ Department of Social Welfare of the Assemblies will monitor child and forced labour issues Operator of the • Ensures the necessary water users committee is Project lifespan Proposed put in place and manages the water systems (operation and Project/Beneficiary • Ensures sustainable use of the infrastructures maintenance) communities 9.1 Training/Capacity Building for Environment, Health and Safety Management The training and capacity building requirements to ensure successful environmental, health and safety management of the sub-projects is provided in Table 9-2. Table 9-2: Training and Capacity Building Requirements No Activity Target Group/ Timeline/Duration Estimated . Participants Responsibi Cost/(US$) lity 1. Induction on environmental Contractors’ Prior to GLRSSMP 10,000.00 and social management, workers commencement of -EPA-PCU occupational and public GLRSSMP sub- E&S health and safety project activities Specialists requirements of the GLRSSMP sub-project activities 2 Training on environmental Contractor’s During project GLRSSMP 10,000.00 and social management, workers construction and -EPA-PCU occupational and public operational phases E&S health and safety Specialists requirements of the GLRSSMP sub-project activities 3. Public sensitization on -General public Throughout project GLRSSMP 15,000.00 GRM and SEA/SH and duration -EPA- GBV PCU/Benef • Human rights regulations iciary in Ghana Municipal • Sanctions against culprits Assemblies and remedies for victims ESIA-MNP, GLRSSMP-EPA PCU, 2025 110 No Activity Target Group/ Timeline/Duration Estimated . Participants Responsibi Cost/(US$) lity 4 Cultural heritage and its E&S officers Pre-constructional Safeguard 8,0000.00 relevance in sustainable Site Supervisors phase Specialist development Site Engineers /Consultant Procedures used in CF Formal site Resource workers persons, from National Museums & Monument Board 5 Community and project Beneficiary Throughout project Community 20,000.00 workers relationships Communities duration developme Stakeholder engagements in nt project development specialist/ Grievance Redress communica mechanism tions specialist Workplace Security Contractors and Pre-construction and Ghana 10,000.00 Preventive measure workers constructional Police Emergency response phases Service procedures Evacuation procedures etc TOTAL COST 73,000.00 ESIA-MNP, GLRSSMP-EPA PCU, 2025 111 10.0 ENVIRONMENTAL AND SOCIAL MONITORING PLAN This section presents a detailed Environmental and Social Monitoring Plan (ESMP-Monitoring) to guide the monitoring of the environmental and social impacts and the implementation of mitigation and enhancement measures during the construction and operation phases. The monitoring plan will enable the EPA to confirm the effectiveness or otherwise of the mitigation measures contained in the ESIA and help enhance the effectiveness of the implementation of the mitigation measures. The ESMP-Monitoring presents the comprehensive monitoring plan developed for the GLRSSMP CIVIL WORKS Project for all the potential substantial adverse environmental and social risks/impacts identified, assessed and mitigated in earlier sections of the report (See Chapters 6, 7 and 8). The monitoring plan includes identification of the responsible institutions or persons and estimated budget/cost requirements. The ESMP-Monitoring includes social and environmental protection measures/indicators addressing at a minimum: • Documentation of voluntary land donations in fringe communities. • Grievance redress system operationalisation and management • GBV/SEA/SH and child labour case management • Workers’ rights and responsible labour behaviour. • Induced development, both short term during construction and long term, from the presence of the Project. • Occupational health and safety requirements for workers, including HIV/AIDS awareness strategy. • Project related incidents such as traffic accidents and risks to public safety. • Waste management, including construction wastes and hazardous wastes. • Security issues including material and equipment storage and potential vandalism. • Removal of vegetation and measures for landscaping. • Archaeological/cultural protection. • Potential soil/water pollution. • Ongoing information disclosure, consultation and engagement in next project phases, and • Management systems and capacity for implementing them. ESIA-MNP, GLRSSMP-EPA PCU, 2025 112 Table 10-1: Environmental and Social Monitoring Plan Environmental/So Monitoring Parameters Frequency Method Location Responsibility Cost cial Component Estimates GHS) per annum Construction Phase Biodiversity Key habitat, areas of Monthly Observation and Construction Contractor In contractor’s conservation interest logging areas fees Ambient air quality Dust emissions: TSP + Monthly Instrument Construction Contractor/Safeguards In contractor’s PM10 sites officer fees Noise Levels Leq, Lmax, Lmin (dBA) Spot monitoring Instrument Construction Contractor/Safeguards In contractor’s near sensitive sites officer fees receptors, and upon receiving complaints Occupational Record of PPE disbursed Continuous Observation and Construction Contractor/Safeguards In contractor’s Health, safety, Good housekeeping logging sites officer fees environment practices Public Complaints Type and nature of Weekly Records Project area Contractor/Safeguards Included in and Grievances complaints and concerns, officer Grievance Complaint records (Record Redress Budget of grievance and number resolved/unresolved) Management and Stakeholder Meetings Gender Based Number of cases reported As and when Record Project area Contractor/Safeguards 10,000 Violence/Child to officer Abuse/SH/SEA the Grievance Redress ESIA-MNP, GLRSSMP-EPA PCU, 2025 113 Environmental/So Monitoring Parameters Frequency Method Location Responsibility Cost cial Component Estimates GHS) per annum Committee/Safeguards officer Number of conflicts/cases dealt with by the Grievance Redress Committee/Safeguards Officer Number of crimes such as defilement and rape reported, investigated, and concluded by the police involving the Contractor’s worker Child Labour Employee documents As and when Records Project area Contractor/Safeguards 15,000 confirming age i.e. voter officer ID, NHIS card, SSNIT Presence of a Child Labour Policy Operation Phase Public Complaints Type and nature of Weekly Records Project area Safeguards Officer 10,000 and Grievances complaints and concerns; Complaint records (Record of grievance and number resolved/unresolved) ESIA-MNP, GLRSSMP-EPA PCU, 2025 114 Environmental/So Monitoring Parameters Frequency Method Location Responsibility Cost cial Component Estimates GHS) per annum Management and Stakeholder Meetings Community health Incidents of drowning As and when Records Water systems Safeguard 15,000 and safety Record of safety awareness site officer/community training leaders Cases reported and dealt with respect to use of water systems Total ESIA-MNP, GLRSSMP-EPA PCU, 2025 115 11.0 DECOMISSIONING 11.1 Closure Procedures It is not anticipated that the infrastructure will be decommissioned, especially those in the Mole National Park, but in the event that they must be decommissioned, the Site Manager shall notify the Environmental Protection Agency, and the relevant Metropolitan, Municipal and District Assembly and other regulatory bodies of the intention to decommission. For the water systems, the first phase of the decommissioning will involve the creation of a channel at the side of the dugout with the lowest gradient. This will allow the water in the dugouts to drain out. Then the embankments will be pushed into the dugout to fill it to the top at the level of the normal height. In case the embankment material is not enough, additional material including loam soil will be sought from elsewhere to complete the filling. Efforts shall be made to restore the land after closure to fit the neighbouring landscape of the site. For the other infrastructure, a detailed decommissioning plan will be prepared and submitted for approval before carrying out the works. Temporal campsites will also be removed to ensure that construction sites are kept clean without any obstacles that will impede movements. 11.2 Vegetative cover (Seeding) All the areas that have been covered with good loam soil, shall be seeded with indigenous plants or grassed. Seeding or grassing will normally be done just before the rainy season. Surface runoff control measures such as drainage ditches and culverts where appropriate will be constructed prior to seeding. All grading and covering will also be finalized prior to seeding. Raking, disking, or other acceptable means shall be used to loosen the top layer of soil before seeding. 11.3 Post Closure/After Care The sites will be monitored for a year to ensure that there is adequate vegetation cover to prevent erosion. It is also to ensure that there are no invasive species among the vegetation. ESIA-MNP, GLRSSMP-EPA PCU, 2025 116 12.0 CONCLUSION The goal of the six-year GLRSSMP-EPA PCU project is to strengthen integrated natural resource management and increase benefits to communities in targeted savannah and cocoa forest landscapes. The project intends to undertake construction of a number of water systems (i.e., dugouts and water holes), game viewing platform, camps, and the completion of the Lovi Research Center in and around the Mole National Park. The construction of these infrastructure aims to improve access to water and watering of wild animals and livestock and contribute to the development of the Mole National Park. The proposed civil works in and around the Mole National Park will have both positive and negative environmental and social impacts and therefore an environmental and social assessment studies have been conducted in accordance with Government of Ghana precautionary principles and relevant World Bank Environmental and Social Standards culminating in the preparation of this Environmental and Social Impact Assessment (ESIA). The proposed civil works in and around the Mole National Park is expected to generate potential positive impacts. The water systems in the park will improve the population of the wildlife through the provision of watering points at the peak of the dry season. The viewing platforms will help boost the tourism of capacity of the park and will also promote the sustainable management of natural resources and enhance the livelihoods of local communities depending on these natural resources. Impacts such as air quality deterioration, noise, occupational health and safety, waste generation etc. will be mostly associated with construction phase activities thus the assessment showed that potential environmental and social impacts will be largely localised. The analysis and surveys undertaken to prepare this Environmental and Social Impact Statement has adequately considered and addressed the above potential impacts. Further analysis has been conducted to determine the level of significance of the impacts. Feasible mitigation measures and appropriate management and enhancement measures as well as a comprehensive environmental and social monitoring plan have been developed. Proper facility siting, design, and operation, among other measures, can address and mitigate these potential negative impacts on the surrounding natural environment, the community and ensure sustainability. Appropriate mitigation measures have been proposed and with the effective implementation of the ESMP, the residual impacts will be minimal. ESIA-MNP, GLRSSMP-EPA PCU, 2025 117 13.0 REFERENCES ▪ Architectural Design-Proposed Office Unit for EPA at Accra, Greater Accra ▪ Contract Agreement- Between Environmental Protection Agency (Ghana Landscape Restoration and Small-Scale Mining Project) and i-Shelter for the Construction of Additional 4-No. Offices for Project Staff on the Premises of the EPA Head Office (Phase 1 & 2), REF: GH-EPA-346837-CW-RFQNovember 2023 ▪ Design for Waterholes ▪ Design for processing facilities ▪ Architectural design for the proposed office unit for EPA at Accra ▪ Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP) Environmental and Social Screening of selected Civil works, Screening Report Environmental Protection Agency (EPA) and the Ministry of Lands and Natural Resources (MLNR) May 2002 ▪ International Bank for Reconstruction and Development and International Development Association Project Appraisal Document for Ghana Landscape Restoration and Small- Scale Mining Project August 10, 2021 ▪ Environmental Protection Agency/Ministry of Environment Science Technology and Innovation, Ministry of Lands and Natural Resources Ghana Landscape Restoration and Small-Scale Mining Project (P171933) Environmental and Social Management Framework (ESMF), February 2021 ▪ Environmental Protection Agency and Ministry of Lands and Natural Resources Ghana Landscape Restoration and Small-Scale Mining Project (P171933) Negotiated Environmental and Social Commitment Plan (ESCP), June 27, 2021 ▪ Environmental Protection Agency (EPA) and the Ministry of Lands and Natural Resources (MLNR), Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP) Project Implementation Manual (PIM), June 2021 ▪ Ministry of Environment Science Technology and Innovation (MESTI), Ministry of Lands and Natural Resources (MLNR) Ghana Landscape Restoration and Small-Scale Mining Project (P171933), Draft Stakeholder Engagement Plan, March 2021 ▪ Centre pour le Développement de la Production Faunique Wildlife Production Development Centre, Inception Report, 30 December, 2023 ▪ Centre pour le Développement de la Production Faunique Wildlife Production Development Centre, Site Evaluation and Summary Construction Plan, Community : Sakalo, Site: Sata Optimised Dugout, 31 January 2024 ▪ Lovi Research Centre Drawings ▪ Management plan for Mole National Park, 2011 ▪ Socio-economic assessment in the Mole Park area for the Savannah Integrated Biodiversity Conservation Initiative, Gordon Akon-Yamga, September, 2021 ESIA-MNP, GLRSSMP-EPA PCU, 2025 118 14.0 ANNEXES Annex 1: Registration/Correspondence with EPA Annex 2: Administrative Flow Chart of Environmental Assessment Procedure Annex 3: Land Donation Memorandum Template Annex 4: Architectural Drawings of proposed civil works Annex 5: Outline of Contractor’s C-ESMP Annex 6: Evidence of Consultations Annex 7: Grievance Redress Mechanism Forms ESIA-MNP, GLRSSMP-EPA PCU, 2025 119 Annex 1: Registration/ Correspondence with EPA ESIA-MNP, GLRSSMP-EPA PCU, 2025 120 Annex 2:Field Visit -Team A Members No Name Designation Organization Tel No. 1 Isaac C. Acquah Project Coordinator EPA-PCU 0501301385 2 Osei Karikari Safeguards Officer EPA-PCU 0501301413 3 John Donkoh APO EPA/HO 0269111161 4 Salifu Wahabu EPA Area Head-Tumu 05013010605 5 Umaru Farouk Dubuire Project Focal Point WD 0244358371 5 Maabier Polycarp Park Manager WD/GRR 0240611348 6 Derek Lungren Technician CDPF/WDPC 0249869372 7 Loren Lungren Technician CDPF/WDPC 0534909097 8 Batimay Albert Technician CDPF/WDPC 0534630411 9 Clark Lungren Coordinator/Contractor CDPF/WDPC +22607105078 10 Dyson Jumpah Project Director EEMC Ltd. 0244649873 11 Tony Asare Architect/Team Leader EEMC Ltd. 0244213405 12 Richard Osei Appiah Civil Engineer EEMC Ltd. 0244609635 13 Ama Bruwa Mbir Social Development Scientist EEMC Ltd. 0540711571 ESIA-MNP, GLRSSMP-EPA PCU, 2025 121 Annex 3: Administrative Flow of the EA Procedure ESIA-MNP, GLRSSMP-EPA PCU, 2025 122 Annex 4: Land Donation Memorandum Template XXX COMMUNITY DEED OF GIFT BETWEEN XXX (DONOR) AND XXX (DONEE) 1.0 DEED OF GIFT ESIA-MNP, GLRSSMP-EPA PCU, 2025 123 This Deed of Gift (hereafter called the “Agreement�) made on this ………… day of …………………………… 20……... is in respect of a parcel of land located in the xxx community of the xxx Traditional Area in the xxx District of the xxx Region of the Republic of Ghana between: 1.1 The xxx community acting per its lawful representative, xxx, hereafter called the “Donor�, and which expression shall where the context so requires or admits, include its agents, successors-in-title and assignees), with the consent and concurrence of the Principal Elders of the xxx Traditional Area, whose consent and concurrence is essential for the validity of this Agreement and which consent and concurrence are testified to by the execution of this Agreement) on one part; and 1.2 The xxx hereafter called the “Donee�, which expression shall where the context so admits or requires include its agents, successors-in-title and assignees) on the other part. Together referred to as “Parties� and individually as a “Party�. RECITALS A. WHEREAS xxx is one of many communities under the xxx Traditional Area. B. WHEREAS the Government of Ghana is implementing the World Bank-funded Ghana Landscape Restoration and Small-scale Mining Project (GLRSSMP) which has one of its core interventions focusing on strengthening the sustainable management of forest landscapes for biodiversity conservation and ecosystem services in targeted communities in the savannah and cocoa forest landscapes, including the xxx community. C. WHEREAS the Donee, as one of the implementing agencies of GLRSSMP, is responsible for implementing sub-component activities of GLRSSMP involving the xxx D. WHEREAS pursuant to implementing the said sub-component activities, it was agreed that xxx (hereafter referred to as the “Project�) will be established in the xxx community. E. WHEREAS the Donor is the Chief of xxx community, and the customarily recognised custodian of a parcel of land situate in the xxx community in the xxx Traditional Area in the xxx District in the xxx Region of Ghana, with an area of --------- acres (hereafter referred ESIA-MNP, GLRSSMP-EPA PCU, 2025 124 to as the “Land�), and more particularly described in the schedule hereto and delineated on the attached Site Plan. F. WHEREAS the Donor, in consultation with the x xx community people and elders, as well as the Principal Elders of the xxx Traditional Area, have voluntarily donated the Land in support of the Project. NOW THEREFORE THE PARTIES AGREE AS FOLLOWS: 2.0 REPRESENTATIONS AND WARRANTIES The Donor warrants that: 2.1 He has the capacity to enter into this Agreement on behalf of the xxx community; 2.2 The land being donated is a community land, and is free of all encumbrances and encroachment of any form or shape; 2.3 The decision to donate the Land was made in consultation with the xxx community people and elders, as well as the Principal Elders of the xxx Traditional Area; 2.4 The amount of land being donated is minor and will not reduce the xxx community’s remaining land area below that required to maintain the community people’s livelihoods at current levels; 2.5 He and the people of xxx community have been appropriately informed and consulted about the Project and its impacts, its land requirements, and its alternative activity sites, as well as rights to compensation for the Land if it were not donated. 2.6 He is aware that refusal to proceed with the donation of the Land is an option, and that execution of this Agreement is a testimony of their willingness to proceed with the donation; 2.7 No household has been relocated, or will be relocated as a direct or indirect result of the donation; The Donee warrants that: 2.8 They have conducted the required due diligence, and confirm that the land being donated is free of all encumbrances and encroachment. 2.9 No household has been relocated, or will be relocated as a direct or indirect result of the donation; 3.0 COVENANTS OF THE DONOR ESIA-MNP, GLRSSMP-EPA PCU, 2025 125 3.1 To provide the Donee with the required consent and assist with, at the cost of the Donee, the registration of this Deed of Gift in the name of the Donee, at the Ghana Lands Commission. 3.2 To ensure that the Donee develops and operates the Project on the Land without interruption by the Donor or any persons acting on behalf of the Donor. 4.0 COVENANTS OF THE DONEE 4.1 To use the Land solely for the development of the Project, as agreed by the Parties. 4.2 To conduct all Environmental and Social (E&S) risks and impacts assessments relevant to the Project, and design mitigation measures commensurate to the risks and impacts identified, in consultation with relevant stakeholders, including the Donor and members of the xxx community. 4.3 To secure all statutory permits, and comply with all legal requirements for the establishment and operation of the Project, from the Government agencies concerned. 4.4 Not to assign, sublet or otherwise part with possession of the Land or any part thereof. 5.0 THE PARTIES HEREIN AGREE that: 5.1 Where the Donee determines that the Land is no longer needed for the intended purpose of the Project, the Donee shall, in consultation with the Lands Commission, return the Land to the Donor in a tenable state. 5.2 The Land, and all rights to it afforded to the Donee by virtue of the donation, shall automatically terminate and revert to the Donor, in the event that the Donee alters the agreed use of the Land without any prior consultation with, and written consent of the Donor. 5.3 Where the donation and this Agreement, by extension, terminate per Clauses 5.1 and 5.2, the Land shall revert to its original status as a xxx-community land as was recognized prior to the donation. 5.4 If any covenant on either Party’s part herein contained is not performed or observed, the other Party shall give to the defaulting Party reasonable notice in writing but not less than two (2) months (“the Notice Period�) for the defaulting Party to make good the default. Should the defaulting Party fail to make good the default within the Notice Period, the other Party shall refer the issue to the Grievance Redress Mechanism (GRM) established under the GLRSSMP for redress, provided that the said GRM is still in force, or the agreed dispute resolution ESIA-MNP, GLRSSMP-EPA PCU, 2025 126 procedure under Section 8.0 of this Agreement, where the said GRM is no longer in force. 5.5 Any notice required to be given by either Party hereunder shall be in writing and shall be considered validly given when delivered by hand or sent by prepaid post to either Party or to their last known physical address per Section 6.0 of this Agreement. 6.0 ADDRESSES OF THE PARTIES Address of Donor Address of Donee Nana Awuni Karim II Ministry of Food and Agriculture P. O. Box…………………………….. P.O. Box 14 ……………………………………….. Ministries, Accra 7.0 VARIATION No variation or amendment of this Agreement or oral promise or commitment related to it shall be valid unless committed in writing and signed by or on behalf of the Parties. 8.0 DISPUTE RESOLUTION Any dispute, controversy, claim or difference of opinion between the Parties or any issue arising out of or relating to this the donated Land shall be settled amicably within 30 days by the Parties. Where the dispute is not settled amicably within 30 days, the Parties agree to submit the dispute for final settlement by arbitration by a sole arbitrator. In the event that the Parties are unable to appoint a sole arbitrator within two (2) weeks of the decision to refer the matter to arbitration, the matter shall be referred to the Ghana Arbitration Centre for appointment of the arbitrator. Where a dispute is not arbitrable, the jurisdiction of the Courts of the Republic of Ghana shall be invoked for the settlement of such dispute by the aggrieved Party. 9.0 GOVERNING LAW ESIA-MNP, GLRSSMP-EPA PCU, 2025 127 This Agreement, its interpretation, performance and the enforcement of the rights and remedies available to either Parties hereto shall be construed by and in accordance with the Laws of the Republic of Ghana. IN WITNESSWHEREOF the Parties hereto have hereunto set their hands, names and common seal the day and year first above written. SIGNED BY DONOR: xxx Chief of xxx Community Address: ____________________________ Signature: ___________________________ In the presence of (Donor’s witnesses): 1. Name:____________________________ After the contents herein have been Designation:_________________________ read over, interpreted and explained Address:_____________________________ to them respectively by……………………… Signature: ___________________________ …..………………………………………… … of ……………………………(address and mobile number of interpreter) in the…………………...language and 2. Name: ____________________________ they each seemed perfectly to understand and approve of the same Designation:_________________________ before making their marks respectively. Address: ____________________________ Signature: ___________________________ SIGNED FOR AND ON BEHALF OF DONEE BY: Name:________________________________ Designation:_________________________ Address: ____________________________ Signature: ___________________________ ESIA-MNP, GLRSSMP-EPA PCU, 2025 128 In the presence of (Donee’s witnesses): 1. Name:____________________________ Designation:_________________________ Address:_____________________________ Signature: ___________________________ 2. Name: ____________________________ Designation:_________________________ Address: ____________________________ Signature: ___________________________ ESIA-MNP, GLRSSMP-EPA PCU, 2025 129 OATH OF RECORDING OFFICER The content of this Agreement has been fully read and explained to both Parties and their witnesses and they confirm that they clearly understood all the terms in this Agreement and all the essential features of the Agreement. Both Parties therefore signed this Agreement in my presence. (signed) ………………………………………………. Date ……………………………………………………. CERTIFICATE I, .................................................................................................................................., officer of the Customary Land Secretariat for the xxx STOOL in the xxx Region of Ghana, hereby certify that the above record of a transfer of an interest in land under customary law incorporates the essential features of the transaction sought to be effected. .......................................................................................................................................... (name) Officer of the xxx Customary Land Secretariat Dated at......................................................... this...............................................day of....................................... , 20................................... OATH OF PROOF I…………………………………………………………………………………………………………… of ……………………………………………………………………… (full name and address of deponent), make Oath and say that on the ……. day of ……………………. 20….., I was present and saw the within-named DONOR duly execute the Instrument now produced to me and marked “A� and that the DONOR can read and write (where a party cannot read and write, a jurat is required)—: SWORN AT ………………………. THIS…………………DAY OF……………... 20......... DEPONENT (Witness of Donor) BEFORE ME ……………………………………………………... REGISTRAR OF LANDS ESIA-MNP, GLRSSMP-EPA PCU, 2025 130 CERTIFICATE OF PROOF On the ……… day of ……………………. 20……. at ………. o’clock in the ……………………… O’clock this instrument was proved before me by the Oath of the within-named ……………………………………… …………………………………………………………………………………… to have duly executed by the within-named DONOR: - ………………………………………………….. REGISTRAR OF LANDS SCHEDULE DESCRIPTION OF LAND SITE PLAN ESIA-MNP, GLRSSMP-EPA PCU, 2025 131 Annex 5: Architectural Drawings for the proposed civil works Block Plan for a viewing platform ESIA-MNP, GLRSSMP-EPA PCU, 2025 132 3D Design of Viewing platform Lovi Research Centre West Wing-Inner Corridors of the Lovi Research Centre- East Wing-Inner Corridors of the Lovi Research Centre- 27/01/2024 27/01/2024 3D Model of the Lovi Research Centre ESIA-MNP, GLRSSMP-EPA PCU, 2025 133 Lovi Research Centre-Compound-3D Model Sheanut/Groundnut Processing Facility – 3D Front View Sheanut/Groundnut Processing Facility – 3D Back View ESIA-MNP, GLRSSMP-EPA PCU, 2025 134 Annex 6 : Stakeholder Engagement Tools District/Com Engagement Tool/Approach munity/Facilit Interviews/Discussions Town Hall y One-On-One Focus Group Key Person Meeting Key Consultees discussions Discussions Interviews Wa East Chassie √ √ Imoro Sapora-Opinion leader (optimized (0544023793) dugout) IDDI Ngmendu Abdulai- Assemblyman (0248267372) Sman Jamal-deen-Outgone Assemblyman (0248243006) Issahaku Alhassan-Unit Committee Sawla Tuna Kalba Jang √ √ √ Chorowura Essaga Dramani (Optimized Kabasagya-Chief-0531616148 dugout) Haamaa Abdul-Latif- 0540750297 Kipo Jamani Dabore √ √ √ Mohammed Saka-CREMA (Optimized executive-(0502028292) dugout) Shaidu Prata Isha-(0550021113 Mole √ √ Osman Abubakar o541581687 National Park Patience Teteh-0241384990 Viewing Platform Water Hole Camp sites Completion of Lovi Research Centre ESIA-MNP, GLRSSMP-EPA PCU, 2025 135 Annex 7: Outline of Contractors’ C-ESMP Every contractor executing a civil works will prepare a Contractor’s ESMP to be approved by the GLRSSMP-EPA PCU prior to the commencement of civil works. The ESMP will be used for the implementation of the various environmental and social actions regarding the civil works. The following outline can be considered by the Contractor as a guide for preparation of the C- ESMP: • Introduction • Brief Description of the Civil works and Construction Activities • Legal and Other Requirements • Roles and Responsibilities • Environmental and Social Management • Health and Safety Management • Community Liaison and Grievance Redress • Compliance and Monitoring • Incidents, Non-Conformance and Preventive Actions • Reporting; • Implementation Schedule and Cost Estimates, and • Conclusion. Table: Details of GLRSSMP-EPA PCU Sites Selected, Geographical Coordinates, Districts and Remarks S/N Site/Community District Proposed Subproject Geographical Coordinates Lat. Long. 1 Mole National Park West Gonja Tree Hide 9.279597 -1.863359 2 Mole National Park West Gonja Water Hole (Lana Pool) 9.329656 -1.837813 3 Mole National Park West Gonja Viewing 9.372989 -1.842736 Platform (Asibey Pond) 4 Mole National Park West Gonja Water Hole (Beat) 9.255832 -2.185683 5 CREMA Sawla Tuna Dugout 9.461120 -2.2217850 Community/Jang Kalba (Livestock watering) 6 CREMA Sawla Tuna Dugout 9.544633 -2.212550 Community/Dabore Kalba (Livestock watering) 7 Chasia Wa East Dugout- 9.735819 -2.119988 livestock watering (Progreen) ESIA-MNP, GLRSSMP-EPA PCU, 2025 136 Annex 6: Evidence of Consultations Engagement with the elders of Dabori Community Brugbani Camp Facility site in the Mole National Park Assibey site for the tree hide Assibey Tree Hide Engagement at the Mole National Park Meeting with EPA, Wa Jang dugout site ESIA-MNP, GLRSSMP-EPA PCU, 2025 137 Chassia Dugout site Research centre at MNP ESIA-MNP, GLRSSMP-EPA PCU, 2025 138 Annex 7: Grievance Redress Mechanism Forms Complaint Submission Forms Reference No: Full Name: Contact information and By Post: Please provide postal address: preferred method of ____________________________________________________________________ communication ____________________________________________________________________ Please mark how you wish to be ________________________________ contacted (mail, telephone, e-mail). By Telephone: __________________________________________ By E-mail ______________________________________________ Nature of Grievance or Complaint Description of grievance: What happened? Where did it happen? Who was involved? What is the result of the problem? Source and duration of the problem? Date of incident/grievance One-time incident/grievance (date _______________) Happened more than once (how many times? _____) On-going (currently experiencing problem) Receiver Name: ____________________________________________________________________ Signature ______________________________________________ Date ______________________________________________ Filer Name: ____________________________________________________________________ ____________________________________________________________________ Signature ______________________________________________ Date ______________________________________________ Relationship to Complainant (if different from Complainant): ____________________________________________________________________ ____________________________________________________________________ Review/Resolution Level 1 (MDA) Level 2 (IA) Level 3 (PCU) Date of Conciliation Session: ____________________________________________________________________________ Was Filer/Complainant Present? Yes/ No Was field verification of complaint conducted? Yes/ No Findings of field investigation ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ESIA-MNP, GLRSSMP-EPA PCU, 2025 139 ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ Summary of Conciliation Session Discussion ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ Issues ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ Was agreement reached on the issues? Yes, No If agreement was reached, detail the agreement ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ If agreement was not reached, specify the points of disagreement ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ Signed (Conciliator): ___________________________________ Signed (Filer/Complainant): _____________________________________ Signed: _________________________________________________ (Independent Observer e.g. Assembly Member/Opinion Leader) Date: _______________________________ Implementation of Agreement Date of implementation: __________________________________________ Feedback from Filer/Complainant: Satisfied /Not Satisfied If satisfied, sign off & date_____________________________________________________ (Filer/Complainant) (Mediator) If not satisfied, recommendation/way forward ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ ___________________________________________________________________________________________________ (Signature & date of Filer/Complainant) ______________________________________________________ (Signature & date of Mediator) ________________________________________________________________ Complaint Register ESIA-MNP, GLRSSMP-EPA PCU, 2025 140 Unique reference number Date of incoming grievance Location (where the grievance was received/ submitted) Complainant’ s name Contact details (Leave it blank in ESIA-MNP, GLRSSMP-EPA PCU, 2025 case of anonymous enquiries and Summary of grievances) Complaint Identification of parties responsible Investigation for addressinglaunch and date resolution of Investigation complaint completion date Findings of investigation Proposed corrective actions Deadlines for internal actions required from staff Indication of satisfaction with compliant Close out date Any outstanding actions for non- closed grievances 141