ENVIRONMENTAL MANAGEMENT PLAN (EMP) - World …€¦ · · 2016-07-09Section Four Environmental...

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FEDERAL REPUBLIC OF NIGERIA

RURAL ACCESS AND MOBILITY PROJECT

(RAMP I, KADUNA)

CR 4408

ENVIRONMENTAL MANAGEMENT PLAN (EMP)

FOR THE

PROPOSED OPRC ROADS PROJECT

(MOW&T/KADRAMP/C/12/10)

Final Report

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TABLE OF CONTENTS

Table of Contents 2 List of Tables 3 List of Figures and Plates 3 Acronyms and Abbreviations 4 Executive Summary 6

Section One Background and Introduction 13 1.1 Introduction and Overview 13 1.2 Objectives of this EMP 14 1.3 Report Structure 14 Section Two Legal and Administrative Framework 16 2.1 Introduction 16 2.2 Overview of Pertinent National Regulations 16 2.3 Relevant Kaduna State Regulation 20 2.4 Relevant International Regulations 21 Section Three Project Description and Environmental Conditions

around Kaduna 22

3.1 Project Location 22 3.2 Scope and Description of the Project 22

3.3 Summary of Existing Environmental Conditions around Kaduna 26

Section Four Environmental Management Plan (EMP) 30

4.1 Introduction 30 4.2 Objectives of the EMP 30 4.3 General Environmental Management Planning,

Training and Responsibilities 31 4.4 Specific Environmental Management Practices 32 4.5 Environmental Monitoring 40

Section Five Cost Estimates and Institutional Framework Requirement for EMP 42 5.1 Introduction 42 5.2 Cost Estimates for Mitigation measures and Monitoring Activities 42 5.3 Institutional Framework for Implementation of the EMP 48 Section Six Conclusions and Recommendations 51

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LIST OF TABLES

Page

Table ES 1: Cost Estimates for the Relevant Mitigation Measures 8

Table ES 2: Cost Estimates for Monitoring Activities 11

Table 2.1: National Environmental legislations Lists 11

Table 3.1: Overview of Road Network in Northern Lot 1 of the RAMP Project 19

Table 3.2: Overview of Road Network in Northern Lot 2 of the RAMP Project 19

Table 3.3: Overview of Road Network in Southern Lot 1 of the RAMP Project 20

Table 3.4: Overview of Road Network in Southern Lot 2 of the RAMP Project 20

Table 4.1: Monitoring Requirement 36

Table 5.2: Cost Estimates for the Relevant Mitigation Measures 38

Table 5.2: Cost Estimates for Monitoring Activities 42

LIST OF FIGURES AND PLATES

Figure 3.1: Administrative map of Kaduna State showing the lots covered by the project 18

Plate 3.1: Farmlands in the Area 24

Plate 3.2: Farmlands in the Area 24

Plate 3.3: Avian Species Observed in the Area 24

Plate 3.4: Avian Species Observed in the Area 24

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ACRONYMS AND ABBREVIATIONS

ABBREV. FULL MEANING

AIDS Acquired Immune Deficiency Syndrome

APC Air Pollution Control

BAT Best Available Technology

BP Bank Policy

BPT Best Practicable Technology

CCMP Contractor Camp Management Plan

CET Contractor Environmental Team

CO Carbon Monoxide

CSP Contractors Safety Plan

dB Decibels

EA Environmental Assessment

EIA Environmental Impact Assessment

EIS Environmental Impact Statement

EM & A Environmental Management and Audit

EMP Environnemental Management Plan

EMS Environmental Management Systems

EPB Environmental Project Brief

EPC Engineering Procurement and Construction

ER Engineers Representative

ESMF Environmental and Social Management Framework

ESIA Environmental and Social Impact Assessment

EMP Environmental Management Plan

ET Environmental Team

FEPA Federal Environmental Protection Authority

FGN Federal Government of Nigeria

FMEnv Federal Ministry of Environment

FRSC Federal Road Safety Corps

GEF Global Environment Facility

GPS Global Positioning System.

HIV Human Imuno-defficiency Virus

HSE Health Safety and Environment

IDA International Development Agency

IEC Independent Environmental Consultant

ISO International Organization for Standardization

ITCZ Inter-tropical Convergence Zone

KEPA Kaduna State Environmental Protection Agency

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ABBREV. FULL MEANING

LFN Law of the Federation of Nigeria

LGA Local Government Authority

LTI Lost Time Injury

NO2 Nitrogen Oxide

NPE National Policy on Environment

OD Operational Directive

OP Operational Policy

OPRC Output Performance-based Road Contracts

PC Project Coordinator

PCF Prototype Carbon Fund

PASP Project Activity Safety Plan

PHS Public Health Safety

PPE Personnel Protective Equipment

PRC Public Road Construction

QA Quality Assurance

QC Quality Control

RAMP Rural Access and Mobility Project

RCEMP Roads Construction Environmental Management Plan

ROW Right of Way

RTTP Rural Travel and Transport

SEA Site Environmental Audit

SI Special Instrument

SO2 Sulphur Dioxide

SPIU State Project Implementation/Coordinating Unit

TSP Total Suspended Particulates

UES Uniform Effluent Standards

WB World Bank

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EXECUTIVE SUMMARY

1.0 Introduction

The FGN applied for, and received funds from the World Bank (WB), through its international

development agency (IDA), to support and finance its policy on Rural Travel and Transport. Kaduna

state is one of the states of the federation designated to benefit from this planned Rural Travel and

Transport projects, and its implementation in Kaduna State is coordinated by the State Project

Implementation Unit (SPIU) under the Kaduna State Ministry of Works and Transport. In compliance

with regulatory requirements, a contract was awarded for the preparation of an all-encompassing EMP

for the implementation of RAMP projects in Kaduna state.

2.0 Legal and Administrative Framework

Local regulations for the construction/transportation sector, under the jurisdiction of the Federal Ministry

of Environment (FMEnv), and the Kaduna State Environmental Protection Agency (KEPA) were

considered in this section. In addition, regulations from international agencies such as the World Bank

were considered.

3.0 Project Description and Summary of Environmental Conditions

The Rural Access and Mobility Project (RAMP) is divided into two main components namely;

• Transport Infrastructure and

• Institutional strengthening.

Kaduna State lies between latitude 90 02′N – 110 32′N and longitude 60 15’E – 80 50′E. With a lot of rock

outcrops which vary in height up to 1370m above sea level and an undulating landscape. Kaduna State

has a dense network of drainages with Rivers Kaduna and Gurara being the two major rivers. Generally

the soil is made up of reddish brown to reddish yellow lateritic soils, in the upland areas the soils are rich

in red clay and sand, but poor in organic matter. The soils generally are freely drained in rocky, hilly

areas, and well-drained in the plains. Kaduna State has basically two vegetation zones; the Guinea

Savannah and Sudan Savannah. Each zone has the southern and northern fringes.

In the northern part of Kaduna State comprising about ten (10) local governments, Hausa is the

predominant tribe and language spoken, followed by Fulani. Other minority tribes include Gbagyi, and

settlers like Yoruba, Igbos and others. The southern part of Kaduna is made up of eleven (11) local

governments and has over 35 different tribes and languages. The predominant ones are Bajju, Atyap,

Jaba and Ninzo Agorok. Hausas and Fulanis are also found in the south, but as minorities.

4.0 Environmental Management Plan

The EMP highlights the required activities and commitments of the Kaduna State Project Implementation

Unit (SPIU) to the implementation of mitigation measures built into project design as well as the

monitoring requirements for the entire project phase, starting from implementation, through operation

and maintenance, to decommissioning. The specific areas focused on by this EMP are:

• Traffic and Traffic Management

• Air Quality and Noise

• Flood Waters, Runoff and Soil Management

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• Hydrological Issues

• Waste Management

• Hazardous Materials Storage

• Fire Safety and Emergency Management Plans

• Health and Safety

Environmental monitoring requirements and plans were also identified for each of these various

components identified above. A summary of the various impacts and their relative severity is presented

in Table ES1 below:

S/N ASSOCIATED IMPACT RELATIVE SEVERITY

OF IMPACT

MITIGATION MEASURES

1. Routine traffic movement may be impeded by

construction activities and lead to traffic build

up in the vicinity

Negligible Enlist the support of traffic management

agencies such as FRSC

Dust from construction activities could lead to

elevated suspended materials levels in

ambient air and affect the health of project

workers and nearby communities

Minor Provide respiratory protection for project

personnel

Undertake periodical sprinkling of road

surface during the dry season particularly, to

minimize dust impact

Noise from construction vehicles and

machinery could lead to increased ambient

noise levels

Minor Provide hearing protection for project

personnel in high noise areas

Ensure personnel do not work for more than

the regulatory 8-hr shift

Waste generation, especially solid and

domestic/sanitary wastes could become an

issue, if not properly handled

Minor Ensure collection and segregation at source

Provide for collection and disposal of oily

wastes in approved state facilities

If road construction activities block existing

natural drainages, it could lead to enhanced

inundation, flooding upstream and drying up

downstream

Moderate Road alignments shall take this into

consideration

Alternative flow routes shall be provided,

where road works tamper with natural

drainage and flow regimes

Possible fire outbreak in fuel storage areas if

adequate care is not taken during various

operational activities

Moderate Provide muster points;

Provide fire-fighting equipment

Provide fire breaks around stacking areas

Undertake regular fire drills and train

personnel on fire fighting

5.0 Cost Estimates and Institutional Framework Requirement for the EMP

An overview of the estimated costs for the implementation of the various mitigation measures indicated

and the costs of carrying out environmental monitoring was estimated. Generally, many of the mitigation

measures are routine and do not require financial inputs. However some of them require financial

investments and these are indicated in Table ES 1 of this report. Also, Table ES 2 indicates the cost

requirements for environmental monitoring activities. However, a summary of the costs associated with

mitigation, monitoring and capacity building training is presented below

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ES 1: Cost Estimates for the Relevant Mitigation Measures

S/N

ENVIRONMENTAL/SOCIAL

ISSUES

COST OF MITIGATION

MEASURES

TOTAL COSTS FOR

FOUR (4) LOTS

RESPONSIBLE PARTIES

1 Traffic and Traffic Management

Traffic is not a serious issue in virtually all

of the designated roads, since they are

mostly rural feeder roads, subject to

minimal traffic normally.

Provision of Alternative routes will be required

only at river/stream crossings. For

Seasonal streams, if construction is

undertaken in the dry season, only

minimal grading and filling of alternative

crossings will be required. This is

estimated to cost =N=300,000/crossing

and estimating about 5 crossings per lot

Estimates for involvement of traffic management

agencies is put at =N=250,000 in each lot

=N=6,000,000.00

=N=1,000,000.00

Alternative routes will be provided by construction

contractors, while contractors will work in

conjunction with RAMP SPIU to involve traffic

control agencies for traffic control

2 Air Quality and Noise Levels

A. Air Quality

The primary concern in terms of air

quality is the health of project workers,

and nearby communities, who are

designated as sensitive receptors for this

project. Generally, dust from construction

activities will lead to elevated suspended

particulate matter levels in ambient air.

This, in turn, could predispose project

workers and host communities to

respiratory infections and ailments.

Noise

Noise from vehicles associated with

construction activities and subsequently,

those that will ply the roads, will lead to

Cost of monitoring is provided in Table 5.2.

Provision of respiratory protection (masks) will

cost an estimate of =N=250,000/lot

Provision of water tankers to sprinkle the roads

will cost an estimate of =N=100,000/km and

estimated that 10km per lot will need to be

sprinkled over the period of construction

Noise monitoring costs are provided in Table

5.2

Hearing protection will cost an estimated

=N=250,000/lot

=N=1,000,000.00

=N=4,000,000.00

=N=1,000,000.00

Respiratory protection will be provided by

contractors, and they will work in conjunction with

RAMP Environmental Officers to ensure the

appropriate usage of these equipment

Water sprinklers shall be provided by construction

contractors

Hearing protection will be provided by contractors

Regular maintenance of machinery shall be

undertaken by construction contractors

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S/N


ISSUES

COST OF MITIGATION

MEASURES

TOTAL COSTS FOR

FOUR (4) LOTS

RESPONSIBLE PARTIES

an increase in ambient noise level.

However, because noise during

operations will be intermittent, rather than

continuous, therefore, effort will need to

be paid to construction period noise

levels. This is in order to ensure that

regulatory limits are not exceeded

3 Waste Management

Different categories of wastes will

typically be generated around the project

area. These will include domestic/food

wastes, sanitary waste and some level of

oil wastes. These need to be properly

handled to prevent environmental

degradation

Provision of waste bins at construction sites

shall cost an estimated =N=120,000/lot

Contracting of hazardous waste disposal

contractors will cost =N=250,000/lot/month

=N=480,000.00

=N=1,000,000.00

Provision of waste bins and contracting of waste

management contractors shall be undertaken by

contractors but will be monitored by RAMP SPIU

Safety Officer attached to the lot.

4 Hazardous Materials Storage

The main hazardous materials that are

likely to be stored within and around the

project area include diesel fuels for

powering generating sets and for running

machinery and equipment to be used for

the project; paints and lubricants.

Because these materials are highly

flammable, they need to be carefully

handled.

Provision of signage and cordoning of stacking

sites will cost an estimate of =N=200,000/lot

PPE per personnel will cost an estimate of

=N=50,000/personnel. Assuming 20 personnel

per lot

Personnel training will cost =N=45,000/person;

assuming 5 key personnel per lot

=N=800,000.00

=N=4,000,000.00

=N=900,000.00

This will be the responsibility of the construction

contractors per lot

5 Hydrological Issues

Generally, some portions of the project

location, especially in the southern lots,

are quite susceptible to inundation and

water logging during the rainy season.

Therefore, in the event that road

construction activities block existing

natural drainage routes, it could

exacerbate inundation in upstream areas

No cost is associated with these measures as

these options are expected to have been taken

into consideration by the contractor

Contractor will be responsible for these actions but

will be monitored by RAMP

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S/N


ISSUES

COST OF MITIGATION

MEASURES

TOTAL COSTS FOR

FOUR (4) LOTS

RESPONSIBLE PARTIES

and cause drying up in downstream

areas, leading to negative modifications

in existing hydrological regimes.

6 Fire Safety and Emergency Management

Fire outbreak is a major possibility in the

storage area, where flammable materials

like diesel, petrol and engine oil is stored.

It is therefore necessary that a

comprehensive fire safety and

emergency management option be

provided as part of overall project

environmental management plans.

Fire fighting equipment per lot is estimated to

cost =N=350,000

Construction of fire breaks around stacking

areas is expected to cost =N=150,000/lot

=N=1,400,000.00

=N=600,000.00

Contactor will be responsible for these actions but

will be monitored by RAMP

7 Health and Safety

The health and safety of personnel

working in the project area is important.

Cost of quarterly fire drills and health checks

prior to employment should already be

incorporated into contractors HSE plan for the

project and as such, no costs are associated

with these measures

Contractor will be responsible for this, but will be

monitored by RAMP’s Environmental officer

8 Accidents/Incidents

An accident is an unplanned,

uncontrolled or undesired event that

could result in personal injury, property

damage or loss of time. Since they are

not planned, specific mitigation measures

cannot be provided for

accidents/incidents. However, preventive

plans and palliative measures must be

put in place

The cost of preparing a detailed and

comprehensive Emergency Response Plan for

each lot is estimated at =N=500,000.00

=N=2,000,000.00

Contractor shall handle the preparation of

Emergency Response Plans and will share these

with RAMP SPIU

Total Cost of Mitigation in the Four (4) Lots =N=11,180,000.00

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Table ES 2: Cost Estimates for Monitoring Activities

S/N ENVIRONMENTAL/

SOCIAL

ATTRIBUTE

RELEVANT

PARAMETERS

FREQUENCY OF

MONITORING

LOCATIONS TO BE

MONITORED

COST ESTIMATE

FOR

MONITORING

RESPONSIBLE

PARTY

1 Air Quality and Noise Levels • NO2,

• SO2,

• CO,

• SPM,

• Noise Levels

Monitoring shall be carried out monthly during construction and quarterly during operations and maintenance, for the first 3years.

Monitoring shall be undertaken within construction areas and control points

=N=250,000/month/lot Assume 6 months for construction =N=18,000,000 for the 4 lots over the 3yr period

• RAMP SPIU

• EMP Consultant

• KEPA

2 Soil • pH;

• Conductivity;

• Heavy Metals;

• Total Organic Carbons and Total Nitrogen

• Hydrocarbons

• Anions and cations

• Microbiology



=N=300,000/lot/month =N=21,600,000 over the entire period

• RAMP SPIU

• EMP Consultant

• KEPA

3. Occupational Health and Safety

• Personnel health

• Health of nearby communities

Monitoring shall be carried out half yearly during construction and yearly during operations

Monitoring shall cover project workers and communities within construction areas

=N=250,000/lot/monitoring =N=4,000,000.00

• RAMP SPIU

• EMP Consultant

• KEPA 4 Traffic Management Traffic situation within and around

construction sites shall be regularly monitored to ensure that construction activities do not negatively affect baseline traffic situations

Monitoring shall be undertaken half yearly during construction

Construction areas will be covered during each monitoring

=N=325,000/lot/monitoring =N=1,300,000.00

• RAMP SPIU

• EMP Consultant

• KEPA

Total Cost of Monitoring for the four (4) lots over construction and operation monitoring period =N=44,900,000

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Stakeholders for the RAMP project and their roles were also identified. These stakeholders are:

The stakeholders in the KADRAMP project are:

• International institutions – World Bank

• National institutions: Federal Ministry of Agriculture and Rural Development

• State Institutions : Kaduna State Ministry of Works ; Kaduna State Environmental Protection

Agency (KEPA)

• Local Government Institutions : The LGA Authorities of the various road projects

• Community – Traditional rulers, village heads of all the areas covered in the project

• Others – Private sector (Contractors, Consultants) NGOs.

6.0 Conclusion and Recommendations

The conclusions drawn from the foregoing are:

• The planned project is a good project, with a number of associated positive benefits;

• The environmental sustainability of the project is premised on the implementation of a sound and

cost-effective environmental management program (EMP)

• The EMP presented above is comprehensive and is deemed adequate to ensure the

sustainability of the project;

• It is the responsibility of the RAMP SPIU in Kaduna, and its contractors to ensure that the EMP is

properly implemented;

• Monitoring reports and other environmental compliance activities shall be periodically reported to

the Federal Ministry of Environment (FMEnv),the Kaduna State Environment Protection

Authority (KEPA) and the World Bank.

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SECTION ONE

BACKGROUND AND INTRODUCTION

1.1 Introduction and Overview

The Federal Government of Nigeria (FGN) recognizes that rural access and mobility is a critical

requirement towards the improvement of the lives and living conditions of rural dwellers in the

country. This is particularly critical for agrarian communities, considering that there is a need for

them to transport farming inputs like fertilizers, etc, to their farms and to ferry out their bulky and,

quite often, perishable produce to the markets.

Towards this end, the FGN, applied for, and received funds from the World Bank (WB), through

its International Development Agency (IDA), to support and finance its policy on Rural Travel and

Transport. Rural Access and Mobility Projects (RAMP) are seen as a major way of fostering and

achieving the FGN’s Rural Travel and Transport policy. The RAMP is aimed at improving and

enhancing accessibility and mobility in rural areas. Kaduna state is one of the states of the

federation designated to benefit from this planned RAMP projects, and the implementation of

RAMP in Kaduna State is coordinated by the State Project Implementation Unit (SPIU) under the

Kaduna State Ministry of Works and Transport.

The Kaduna State RAMP projects currently include a total of forty (40) rural feeder roads, based

on priority. These 40 roads have been subdivided into four (4) lots. Each of the Northern and

Southern parts of Kaduna State has two (2) lots. The 40 rural roads selected are of three

categories; paved (tarred), unpaved (untarred with standard and uniform carriageway) and

unpaved tracks/paths (rough and irregular carriageway). 17 of the 40 roads are in the north while

23 are in the southern part of the state.

In compliance with national regulations and the requirements of the World Bank’s safeguard

policies, there is a need for proper and enhanced, environmental management plans and

programs, in the course of implementing these projects. Therefore, this document has been

prepared to present a concise but all-encompassing Environmental Management Plan (EMP) for

the implementation of the RAMP project in Kaduna state.

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1.2 Objectives of this EMP

In broad terms, the objectives of this EMP report include the following:

� to monitor compliance with all the mitigation measures and commitments as

discussed in the ESMF report prepared for this project;

� to ensure best practices management as a commitment for continuous

improvement in environmental performance;

� to monitor compliance with legal standards and limits for wastes discharges;

� to identify monitoring requirements, allocate responsibilities and identify areas

where institutional strengthening is required;

� to provide early warning signals on potential environmental degradation for

appropriate actions to be taken so as to prevent or minimize environmental

consequences;

1.3 Report Structure

This EMP has been put together to meet the objectives stated above, for the successful and

sustainable implementation of RAMP projects in Kaduna state. The EMP is organized as follows:

Section One : Background and Introduction: This section presents background information on

the proposed project and an overview of the objectives of this EMP report.

Section Two: Legal and Administrative Framework: An overview and summary of relevant

regulations at the State, Federal and International levels are presented in this section of the

report.

Section Three: Overview of the Project and Existing Environment in Kaduna State: This

section of the report presents a concise description of the planned projects in the four (4) lots and

a summary of the biophysical and socio-economic conditions of the project environment.

Section Four: The Environmental Management Plan: In this section of the report, an overview

of the pertinent environmental and social issues relating to the planned RAMP projects, mitigation

measures for negative impacts, as well as a monitoring schedule for the project phases is

presented

Section Five: Cost Estimates and Institutional Framework Requirement for the EMP: This

section of the report presents an overview of cost-estimates for the implementation of the

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mitigation measures and the monitoring requirements identified for the project phases. It also

presents the institutional framework required for the effective implementation of the EMP

Section Six: Conclusion and Recommendations: A summary of the conclusions drawn from

the EMP and recommendations on the optimal steps to be undertaken in implementing the EMP

during various phases of the project is presented in this section.

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SECTION TWO

LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1 Introduction

In Nigeria, several legislation and regulations guide the operations of various sectors of its

industries, including oil and gas, transportation, infrastructure, and food and drugs. These

regulations include local laws as well as some international treaties, acts and conventions. In

this section, an overview of the laws that closely or remotely relate to the RAMP project is

presented.

Local regulations for the construction/transportation sector are under the jurisdiction of the

Federal Ministry of Environment (FMEnv)1, and the Kaduna State Environmental Protection

Agency (KEPA). FMEnv regulations applicable to current project are briefly discussed here.

The pertinent regulations are listed in Table 2.1.

Table 2.1

National Environmental Legislations list

APPLICABLE REGULATIONS YEAR Federal Environmental Protection Agency Act 1988/91/92

Environmental Impact Assessment Act No. 86 1992

Guidelines and Standards for Environmental pollution Control in Nigeria Effluent Limitation Regulations (S.I.8) Pollution Abatement in Industries and Facilities Producing Waste (S.I.9) Management of Solid Hazardous Wastes (S.I.15)

1991/ 2002

Harmful Waste Act 1988

Oil in Navigable Waters Regulation 1968

2.2 Overview of Pertinent National Regulations

2.2.1 The Federal Ministry of Environment (FMEnv), formerly the Federal Environmental

Protection Agency (FEPA) Regulations 1988, 1991 and 1992.

Act 58 of 1988 established the Federal Environmental Protection Agency (FEPA) as the chief

regulatory body for environmental protection in Nigeria with the responsibility of ensuring that all

industries meet the limits prescribed in the national guidelines and standards and associated

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regulations for environmental pollution management. From time to time, the FMEnv (formerly

FEPA) may update the national guidelines and standards. Relevant specific standards and

other environmental requirements are outlined as follows.

FMEnv has put in place statutory documents to aid the control and abatement of industrial wastes

and indiscriminate pollution of the environment. Statutory documents include:

� EIA Act No 86 of 1990;

� S.I.8 - National Environmental Protection (Effluent Limitations) Regulations of 1991;

� S.I.9 - National Environmental Protection (Pollution Abatement in Industries and

Facilities Generating Wastes);

� S.I.15 - National Environmental Protection Management of Solid and Hazardous

Wastes Regulations of 1991;

� The Harmful Wastes (Criminal Provisions) Act No. 42 of 1988;

� The 1989 National Policy on the Environment;

These statutory documents clearly spell out the restrictions imposed on the release of toxic

substances into the environment and the responsibilities of all industries whose operations are

likely to pollute the environment. Such responsibilities include provision of anti-pollution

equipment, adequate treatment of effluent before discharge into the environment, etc. (S.I.8 & 9).

For example, paragraph 15(2) of S.I.9 states that no oil in any form shall be discharged into public

drains, rivers, lakes, seas, atmosphere or underground injection without a permit being issued by

FMEnv or any organisation designated by the ministry. Also paragraph 17 states that an industry

or a facility which is likely to release gaseous, particulate, liquid or solid untreated discharges shall

install into its system, appropriate abatement equipment in such a manner as may be determined

by the FMEnv.

Specifically, S.I.15 provides a comprehensive list of wastes that are classified as being dangerous

to the environment. It also gives detail on the contingency planning and emergency procedure to

be followed in case of sudden release of any of these hazardous wastes into the environment.

1

Formerly the Federal Environmental Protection Agency (FEPA).

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2.2.2 National Policy on Environment (1989, Revised 1999). Issued by Federal

Environmental Protection Agency (FEPA)

The goal of the National Policy on the Environment is to achieve sustainable development in

Nigeria, and in particular to:

• Secure a quality of environment adequate for good health and well-being;

• Conserve and use the environment and natural resources for the benefit of present and

future generations;

• Restore, maintain, and enhance the ecosystem and ecological processes essential for

the functioning of the biosphere to preserve biological diversity and the principle of

optimum sustainable yield in the use of living natural resources and ecosystems;

• Raise public awareness and promote understanding of the essential linkages between

the environment, resources, and development, and encourage individual and community

participation on environmental improvement efforts; and

• Co-operate in good faith with other countries’ international organizations and agencies to

achieve optimal use of Trans-boundary natural resources and effective prevention or

abatement of Trans-boundary environmental degradation (Article 2.0).

2.2.3 National Guidelines and Standards for Environmental Pollution Control

in Nigeria, 1991

Effluent Limitations Regulations

This regulation was made pursuant to Section 37 of the FEPA Act Cap 131 LFN, to regulate

ways and manners of treating effluent as well as installation of anti-pollution equipment by

industries operating in Nigeria.

The regulation mandates every industry to install anti-pollution equipment for the detoxification

of effluent and chemical discharges emanating from the industry (Regulation 1(1)). Such

installed anti-pollution equipment shall be based on Best Available Technology (BAT), BPT or

the Uniform Effluent Standards (UES) (Regulation 1(2)). An industry which discharges effluent

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shall treat the effluent to a uniform level as specified in the schedule to the receiving water into

which the effluent is discharged (Regulation 3(1)).

2.2.4 Pollution Abatement in Industries and Facilities Generating Wastes

This regulation is made pursuant to FEPA Act, CAP 131 LFN Section 37, to designate and

regulate the management of solid and hazardous wastes generated from facilities in Nigeria.

Unless with the approval of the Agency (FEPA, now FMEnv), no industry or facility shall release

hazardous or toxic substances into the air, water or land of Nigeria’s ecosystem and such limits

approved by the Agency shall not be exceeded. Storage, treatment, and transportation of

harmful toxic waste without permit is also prohibited (Regulations 1, 10, and 15).

It mandates that an industry or facility has a pollution monitoring unit within its premises, sets up

a machinery for combating pollution hazard and maintains equipment in the event of an

emergency, and assigns the responsibility for pollution control to a person or corporate body

accredited by the Agency (Regulations 2 and 8).

Solid waste generated by an industry or facility, including sludges and all by-products resulting

from the operation of pollution abatement equipment shall be disposed of in an environmentally

safe manner, and no industry solid waste shall be disposed of in any municipal landfill

(Regulation 16).

It further enjoins every industry or facility which is likely to release gaseous particles or solid

untreated discharges to install into its system prescribed abatement equipment by the Agency

(Regulation 17).

It also empowers the Agency to demand environmental audit from existing industries and

environmental impact assessment from new industries and major development projects and the

industries shall comply within 90 days of the receipts of the demand (Regulation 21).

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2.2.5 Management of Hazardous Waste Regulation

This regulation designates those solid wastes, which are dangerous or extremely hazardous to

the public health and environment.

In order to determine if the waste generated is to be designated as “dangerous i.e. hazardous

waste” or “extremely hazardous waste” in accordance with the stipulations under Part II of the

Regulations, the generator or operator has to consult the dangerous waste list, characteristics

and criteria set out under schedules 6-13 and follow the detailed cross checking procedures

established there.

It provides for surveillance and monitoring of dangerous and extremely hazardous waste and

substances, until they are detoxified, reclaimed, neutralized, or disposed of safely.

It also provides the form and rules necessary to establish a system for manifesting, tracking,

reporting, monitoring, record keeping, sampling and labeling dangerous, and extremely

hazardous wastes.

It further encourages recycling, reuse, reclamation, and recovery to the maximum extent

possible.

2.3 Relevant Kaduna State Regulation

Kaduna State Environment Protection Authority (KEPA) Amendment Edict 1997

The Kaduna State Environment Protection Authority (KEPA) Edict came into operation on the

1st day of January, 1997. Under the edict, the Authority (KEPA) has the general responsibility

for all matters relating to environment. Its main duties are to:

• Enact and enforce State regulations control criteria, procedures, guidelines and

environmental standards for effective prevention, remediation, control and

prevention of point and non-point sources of pollution and degradation;

• Formulate, implement, and review environmental policy in the State and in particular to

demand and review Environmental Impact Assessment and Statements for new

21

development projects and to also demand and review environmental audit reports for

existing developments and such other operations which are deemed to have

significant impact on the environment;

• Prepare, in accordance with the State Policy and Edict on the environment, periodic

master plans for the development and the financial requirements for implementation

of such plans;

• Prevent, stop any act of omission or commission which consequences are likely to

adversely affect the environment and to generally deal with any discharge solid, liquid or

gaseous, deposited willfully or otherwise in the environment and to deal generally with

any violations which the Authority may deem hazardous to the environment and

ecosystem.

2.4 Relevant International Regulations

2.4.1 World Bank OP/BP 4.01; Environmental Assessment (EA)

This is one of the 10+1 Environmental and Social Safeguard Policies of the World Bank. It is

used in the Bank to examine the potential environmental risks and benefits associated with

Bank lending operations. Under OP/BP 4.01, Bank lending operations are broadly defined to

include investment lending, sector lending, rehabilitation lending through financial

intermediaries, and investment components of hybrid lending. Prototype Carbon Fund (PCF)

and Global Environment Facility (GEF) co-financed projects are also subject to the provisions of

OP/BP 4.01.

Under this guideline, The Bank requires environmental assessment (EA) of projects proposed

for Bank financing to help ensure that they are environmentally sound and sustainable, and thus

to improve decision making. EA evaluates a project's potential environmental risks and impacts

in its area of influence; examines project alternatives; identifies ways of improving project

selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or

compensating for adverse environmental impacts and enhancing positive impacts; and includes

the process of mitigating and managing adverse environmental impacts throughout project

implementation. The Bank favours preventive measures over mitigatory or compensatory

measures, whenever feasible.

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SECTION THREE

PROJECT DESCRIPTION AND ENVIRONMENTAL CONDITIONS AROUND KADUNA

3.1 Project Location

The project is located in Kaduna State of Nigeria. The project covers four (4) lots, two each in

northern and southern ends of the state. Figure 3.1 shows an administrative map of Kaduna

state, with the various roads and the affected Local Government Areas (LGAs).

3.2 Scope and Description of the Project

The Rural Access and Mobility Project (RAMP) is divided into two main components namely;

• Transport Infrastructure and

• Institutional strengthening.

Component A: Transport Infrastructure

This component, which has to do with more of civil works, is made up of River crossing (A2)

and Output Performance based Road Contracts (A1). The River Crossing makes up 40% of this

component A and is aimed at rehabilitating rivers crossings, culverts, etc. On the other hand,

the Output Performance based Road Contracts (OPRC) makes up 60% and is aimed at

improving and/or upgrading the existing rural feeder roads and tracks. There are two categories

of roads under OPRC, namely; existing paved roads which are degraded and require re-

sealing, and existing unpaved roads and tracks which would be upgraded to laterite surface

dressed roads.

The improvement of the existing rural roads will be carried out using the Output and

Performance Based Road Contracts (OPRC). The OPRC means that the contractors will be

paid based on the quantity of actual work done, and the payment would be fee per kilometer

(km) per month only if the defined (contract) service levels have been achieved.

23

Figure 3.1: Administrative map of Kaduna State showing the lots covered by the project

A total of forty (40) rural feeder roads have been selected under the RAMP in Kaduna State

based on priority. These 40 roads have been subdivided into four (4) lots. The Northern part of

Kaduna State has two (2) lots while the Southern part has two (2) lots. The 40 rural roads

selected are of three categories; paved (tarred), unpaved (untarred with standard and uniform

carriageway) and unpaved tracks/paths (rough and irregular carriageway). 17 of the 40 roads

are in the north while 23 are in the southern part of the state.

Tables 3.1 to 3.4 show the various lots of roads in the northern and southern parts of the state

and the estimated distance and scope of works to be carried out

24

Table 3.1: Overview of Road works in Northern Lot 1 of the RAMP Project

LOT N 1

Surface Scope of works

Road # Name

LGA Total km paved Unpaved

Construct to gravel 7.3m

Upgrade to paved 7.3m

Patch and reseal 7.3m

R1-1 Dogon Dawa – U/Danko-Kwashi Birnin Gwari

13.8 13.8 13.8

R1-2 Kidanda – S/Gari Yadi and Galadimawa – Gamba

Giwa 24 24 24

R1-3 Gwada-Sabon Birnin Giwa 6.5 6.5 6.5

R1-12 U/Liman-Fatika-U/Kanawa Giwa 27.4 27.4 27.4

R1-24a Unguwan Fari - Bugai Birnin Gwari

12 12 12

R1-24b Bugai (End of Village) – U’n Alhaji Shehu

Birnin Gwari

12.8 12.8 12.8

R1-26 Nasarawa – Gangara - Dundubus

Giwa 12.4 12.4 12.4

R1-27 Giwa town - Yakawada Giwa 12.2 12.2 12.2

Total 131.7 27.4 104.3 104.3 0 27.4

Table 3.2: Overview of Road works in Northern Lot 2 of the RAMP Project

LOT N 2


Road No. Name

LGA Total km paved Unpaved

Construct to gravel 7.3 m


Patch and reseal 7.3m

R2-4 Kerawa-Gedage Giwa 8.2 8.2 8.2

R2-5b Dunki –Labar – Jaji Igabi 11.1 11.1 11.1

R2-6 Kerawa-Sako Giwa 9.8 9.8 9.8

R2-7 Kakangi-Murai-Karaukarau Giwa 9 9 9

Giwa/ R2-8a Wazata-Kwaba-Rafin Yashi-Sabon Birni-Kugu Zaria

12.5 12.5 12.5

Giwa/ R2-8b Wazata-Kwaba-Rafin Yashi-Sabon Birni-Kugu Zaria

7 7 7

Tami-Birni-Yaro-Rahama-Kabomo-

R2-10

Kwarakwara-Kasangwari-R/Chikun Rail Crossing

Igabi 29.8 29.8 29.8

R2-25 Sabon Birni Yero – Dallatu Igabi 10.1 10.1 10.1

Total 97.6 0 97.6 97.6 0 0

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Table 3.3: Overview of Road works in Southern Lot 1 of the RAMP Project

LOT S1


Road # Name

LGA Total km

Paved

Unpaved Construct to gravel 7.3 m


Patch and reseal 7.3 m

R3-3a F/Kagoma-Jaginidi Tasha Jema’a 5.8 1.5 4.3 4.3 1.5

R3-3b F/Kagoma-Jaginidi Tasha Jema’a 12.5 12.5 12.5

R3-4 Bakinkogi-Godogodo-Dangoma Jema’a 29.4 22.8 6.6 6.6 22.8

R3-6 Jaginidi Tasha-Kogum Jema’a 12.7 12.5 0.2 0.2 12.5

R3-8 Jaginidi Tasha-Amere-Gerti Jema’a 7.0 7.0 7.0

R3-9a F/Kamantan-Zagon-Anza-Gorasegwaza-Gora Gan-ung Ruhogo-Takanai-U/Wakili

Zangon Kataf 10.5 10.5

10.5

R3-9b From Federal Rd to Sako Village Zangon Kataf 6.7 6.7 6.7

R3-9ab F/Kamantan-Zagon-Anza-Gorasegwaza-Gora Gan-ung Ruhogo-Takanai-U/Wakili

Zangon Kataf 13.3

13.3 13.3

R3-10 Fadan Kamantan-Yangil-Walijo-Kurmi Sidi Zangon Kataf/Kachia

21.8 21.8 21.8

R3-21 Zonkwa junction – lenak Village – Zuturun Turan Village

Zangon Kataf 8.2 8.2 8.2

R3-21a Zonkwa Junction – Zuturun Achi Village Zangon Kataf 4.3 4.3 4.3

Total 132.3 36.8 95.4 73.4 22.0 36.8

Table 3.4: Overview of Road works in Southern Lot 2 of the RAMP Project

LOT S2


Road # Name

LGA Total km

Paved

Unpaved Construct to gravel 7.3 m


Patch and reseal 7.3 m

R4-1 Sabon Gida-Kudiri-Rafan Kimba-kagarko Kagarko 12.9 12.9 12.9

R4-2 Kagaroko-Akote-Kushe-Kahir-Kasru Kagarko 36.1 36.1 36.1

R4-2a Karajan – Kasaru – Junction with Federal Road Kagarko 15.2 15.2 15.2

R4-13 Sabon Itche-Kuse-U/Dankarami-T/Wada-Kagunyi

Kagarko 6.7 6.7 6.7

R4-14a Kubacha-A/Madaki-Kukui-Kusam1 Kusam2 Kagarko 7.4 7.4 7.4

R4-14b Kubacha-A/Madaki-Kukui-Kusam1 Kusam2 Kagarko 10.0 10.0 10.0

R4-16 From state road to Mai Ido Kufai Kachia 14.7 14.7 14.7

R4-17 From state road to Mai Gora Village Kachia 2.2 2.2 2.2

R4-18 From state road to U/Fari Kachia 1.4 1.4 1.4

R4-19 From state road to Kabara Aribi Village Kagarko 7.9 7.9 7.9

R4-20 From state road to Goraa village Jaba 3.4 3.4 3.4

Total 127.0 127.0 127.0

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Component B: Institutional Strengthening This will focus on;

• Strengthening the road management as well as planning, procuring and supervising road

maintenance contract skills both on State and Local Government levels;

• Assisting with the development and implementation of institutional reform proposals and

reporting systems to assist with efficient management of rural transport infrastructure;

• Support with the implementation of RTTP to empower the local government and

communities to participate in the management and provision of rural transport

infrastructure and services; and

• Capacity building in the procurement, supervision and execution of labour based and

small scale contracting.

3.3 Summary of Existing Environmental Conditions in Kaduna State

A summary of the general environmental conditions around Kaduna State is presented below:

Geology, Drainage and Hydrology

The state is underlain generally by metamorphic rocks of the Precambrian basement complex,

consisting of biotite, gneisses and older granites. Younger granites and batholites predominate

in the South-Eastern parts of the state .The Central; North-East and South-Eastern parts of the

state are dominated by older granites. Giwa local government and Birnin Gwari areas and some

parts of Zaria have undifferentiated meta-sediments. The valleys around Kaduna are extensive

up to the watershed areas, having gentle sloping valleys containing moist/marshy alluvial flood

plains. These flood plains are the “Fadamas” which are used for dry season crop cultivation.

Mineral deposits of the state include; Iron Ore, Manganese, Kyanite, Sillimanite, Graphite, Talc,

Feldspar, Gold, Fassiterite, Columbite, various Gemstones, Clay, Sand and Laterite derived

from weathered Granite.

Kaduna State has a dense network of rivers/drainages with Rivers Kaduna and Gurara being

the two major rivers. The sources of these rivers include Kauru, Lere and Plateau State area

which form the source of the biggest river, Kaduna; The Zangon Kataf/Kaura to Plateau state

27

area which form the source of the river Shayu, Kagom, Mada and Sanga; Kachia and Kagarko

from where rivers Gurara and Dinya flow; Birnin Gwari areas form the source of rivers

Udawa/Baban ,Damari ,Kusheriki, Kwingi and Mairiga; then the Ikara, Kubau and Lere/Plateau

areas provide the source for rivers Karami, Galma and Kubani. All of these rivers have their

tributaries and distributaries which forms the dense network of drainage in the state.

The state has a lot of surface and groundwater. The large number of rivers, streams and ponds

in the state provides surface water. The total reserve for the state is about 8,000m3. About 80%

of this comes from surface water, while 20% comes from wells and boreholes. There area no

major surface waters that are directly affected by the planned RAMP projects, except for a few

seasonal streams and minor streams that need to be crossed in some portions

Climate

Kaduna State experiences a typical tropical continental climate in which pronounced seasonal

regimes reflect the influence of tropical continental and equatorial maritime air masses, with a

cool to hot dry season November to February, and a rainy season May to October. The spatial

and temporal distribution of rain varies from an average of some 1600 mm in the south to less

than 700 mm in the north. High storm intensities, ranging from 60-99 mm/hour, and the nature

of surface runoff have led to the development of an extensive river system. Rainfall is

associated with the northwards movement or the Inter-Tropical Convergence Zone (ITCZ)

across Kaduna State. During the rainy season, relative humidity is high and winds are mainly

south-westerly. The southward movement of the ITCZ occurs in October-November and

indicates the onset of the dry season, with low relative humidity.

Air Quality

The measured air quality parameters (CO, SO2, NO2, TSP etc) of the study area are within the

FMEnv regulatory limits. However, the harmattan winds of the dry season are often dust laden

and contrive to lead to an increase in ambient levels of suspended particulate matter. Project

activities are likely to further exacerbate this, especially if undertaken in the dry season. Noise

levels are generally low in the state, ranging between 40 and 65dB(A), except in urban areas

like Kaduna metropolis, some parts of Zaria, etc., where traffic and human activities contrive to

28

elevate noise levels to 75dB and above. In all cases however, ambient noise levels are below

the Federal limit of 90dB for a maximum of 8 hours exposure.

Soil

The soils of most part of project area are sandy with very low organic content. Anions and

cations are within acceptable ranges to support the growth of some plants. Heavy metal

contamination has not occurred as records from previous studies in the state recorded low

ranges of metals that are within acceptable limits.

Vegetation Study

The entire project area falls within the guinea savannah vegetation type with two basic habitat

types; savannah grassland and farmland/grassland mosaic. In the savannah grassland, trees

are few and spaced wide apart. Plants recorded within the project area include trees such as

Parkia biglobosa, Adansonia digitata and Azadirachta indica. Grassy species such as Panicum

maximum, Andropogon gayanus and Imperata cylindrica are also present.

The communities immediately around the project site are primarily agrarian and engage in

subsistence and semi-commercial farming of food crops and cash crops. The main food crops

include maize, guinea-corn, Hungry rice, rice, cassava, and millet. Some vegetables such as

pepper, tomatoes, okra, pumpkin and corchorus are planted along the river course. Livestock

farming, especially cattle and sheep is very prominent.

Wildlife

The faunal diversity in the project area presents a wide variation of both vertebrate (amphibians,

reptiles, mammals and aves) and invertebrate animals. Birds are typically abundant within the

project area, while reptiles such as snakes, crocodiles and monitor lizards, which are very shy

animals, were not easily observed. However, the rainbow lizard (Agama agama) is very

ubiquitous in the area and is therefore seen regularly all over the project area.

Plates 3.1 to 3.4 show some of the vegetation and wildlife typically associated with the area.

29

Plates 4.1 and 4.2: Farmlands in the area

Plates 3.3 and 3.4: Avian species observed in the area

30

SECTION FOUR

ENVIRONMENTAL MANAGEMENT PLAN (EMP)

4.1 Introduction

Environmental Management Plan (EMP) is a management application tool used to monitor the

effectiveness of mitigation measures and project commitments to environmental protection,

especially as may have been contained in the ESIA report. The EMP is incorporated into the

project implementation process, to minimize or eliminate identified negative impacts, assess

compliance with environmental regulatory standards and corporate safety policies.

This EMP highlights the required activities and commitments of the Kaduna State Project

Implementation Unit (SPIU) to the implementation of mitigation measures built into project

design as well as the monitoring requirements for the entire project phase, starting from

implementation, through operation and maintenance, to decommissioning.

4.2 Objectives of the Environmental Management Plan (EMP)

The objectives of the EMP contained in this Section are as follows:

� to monitor compliance with all the mitigation measures and commitments as

discussed in the Environmental and Social Management Framework (ESMF)

prepared specifically for this project, during the implementation of the proposed

project;

� to ensure best practices management as a commitment for continuous

improvement in environmental performance;

� to monitor compliance with legal standards and limits for various environmental

requirements, such as wastes discharges, ambient air, occupational exposure

limits for workers, etc.;

31

� to provide early warning signals on potential environmental degradation for

appropriate actions to be taken so as to prevent or minimize environmental

consequences;

The EMP is in two parts:

• Part 1: General Environmental Management and personnel training issues;

• Part 2: Environmental monitoring requirements and schedule

Details are presented in the following sub-sections.

4.3 General Environmental Management Planning, Training and Responsibilities

Environmental Awareness Training and Skills Training for Personnel

All staff and/or contractors involved in work in the project are to be briefed on their obligations

towards environmental controls and methodologies in terms of this EMP prior to work commencing.

The briefing will usually take the form of an onsite talk and demonstration by the SPIU

environmental officer. The education / awareness programme shall be aimed at all levels of

management within the operations team.

Personnel

• Working hours must be communicated to all personnel and strictly enforced, so that

personnel do not suffer exposure beyond regulatory limits

• No fires shall be permitted within the project area unless for specific activities such as

welding and/or temporary illumination during blackouts.

• Personnel shall ensure that waste generation is kept to a barest minimum. Waste bins shall

be provided in each booth to handle wastes such as stationers, food wastes, etc.

• Awareness training that includes health programmes containing as a minimum, HIV/AIDS

and Malaria awareness training that focuses on the symptoms and effective control mechanisms

for early detection and effective control, will be provided.

32

Record Keeping

All records related to the implementation of this management plan (e.g. site instruction book) must

be kept together in an office where it is safe and can be readily retrieved. These records shall be

kept throughout project duration and shall at any time be available for scrutiny by any relevant

authorities.

Emergency Plan and Contingency Plans

The SPIU shall ensure that contractors handling the different lots prepare and make available

emergency plans for the typical emergencies and any other emergencies, as deemed necessary by

the Health and Safety Officer. These plans shall include any other contingency plans for events

such as Lost Time Injury (LTI), accidental fires from fuel storage facilities; community issues, etc.

4.4 Specific Environmental Management Practices

This section contains specific environmental management practices and procedures applicable to

the Kaduna RAMP projects. Based on the outcome of the scoping exercise carried out for the

purpose of the development of this EMP, it was concluded that the following sections require

attention in the EMP:




• Hydrological Issues • Waste Management




The following sub-sections present general environmental management practices that shall be put

in place to ensure that the operating environment around the project area is safe and healthy for all

personnel and host communities.

4.4.1 Traffic and Traffic Management

33

Traffic is not a serious issue in virtually all of the designated roads, since they are mostly rural

feeder roads, subject to minimal traffic normally. However, the occasional vehicular traffic may be

impeded by construction activities. Therefore, traffic management schemes shall be put in place to

manage traffic in the area, especially during peak periods, which coincide with harvest periods,

when farm produce have to be ferried from the local communities to the markets. Thus, traffic

management schemes shall be provided by contractors handling the projects. The schemes shall

take into consideration, as a minimum, the following:

• Minimization of obstruction to normal traffic flow in the area;

• Provision of temporary alternative routes, in the event that absolute obstruction of traffic is

inevitable.

• In addition to the foregoing, RAMP shall work in conjunction with traffic management

agencies such as the Federal Road Safety Corps (FRSC), to optimize traffic flow, by

minimizing traffic obstruction

.

4.4.2 Air Quality and Noise Level

Air Quality

The primary concern in terms of air quality is the health of project workers, and nearby

communities, who are designated as sensitive receptors for this project. Generally, dust from

construction activities will lead to elevated suspended particulate matter levels in ambient air. This,

in turn, could predispose project workers and host communities to respiratory infections and

ailments. Therefore, RAMP and its contractors shall ensure that:

• Regular monitoring of air quality around the project area are carried out, on a monthly basis,

so that negative trends can be promptly detected and addressed;

• Personnel are not allowed to exceed their regular shift durations

• Adequate respiratory protection is provided for project workers on site, so that their exposure

to respiratory irritants is minimized

34

• In the dry season, there will be need for periodic sprinkling of the road surface with water,

especially were road works are taking place within and around communities to minimize

suspendable dust levels in ambient air.

A detailed monitoring schedule is presented in subsequent sections of this report.

Noise Control

Noise from vehicles associated with construction activities and subsequently, those that will ply the

roads, will lead to an increase in ambient noise level. However, because noise during operations

will be intermittent, rather than continuous, therefore, effort will need to be paid to construction

period noise levels. This is in order to ensure that regulatory limits are not exceeded.

Therefore, RAMP and its contractors will implement the following measures to protect its workers

and nearby host communities from the hazards of high noise levels in the area:

• Provide hearing protection for project personnel, who are in high noise areas, close to the

machinery that will be used for project activities;

• Ensure that project personnel do not exceed the normal 8-hr duration of their shifts;

• Provide for regular monitoring of noise levels around the project locations, to facilitate early

detection of exceedance of regulatory noise levels

• Undertake regular monitoring of personnel to ensure that they adhere to the relevant health

and safety standards pertaining to noise, such as wearing ear protection when noise levels

are getting high.

• Ensure that machinery to be used for project construction activities have functional silencers

that ensure that noise emissions meet international regulatory standards

4.4.3 Waste Management

Different categories of wastes will typically be generated around the project area. These will

include domestic/food wastes, sanitary waste and some level of oil wastes. These need to be

properly handled to prevent environmental degradation. To this end therefore, the following waste

management options shall be instituted:

35

• Wastes shall be collected and properly segregated at source. Typical segregation options

include separation into: food waste; paper and stationeries; and recyclables (plastic and

glass).

• Oily wastes shall be collected and disposed in approved facilities in the state;

4.4.4 Hazardous Materials Storage

The main hazardous materials that are likely to be stored within and around the project area include

diesel fuels for powering generating sets and for running machinery and equipment to be used for

the project; paints and lubricants. Because these materials are highly flammable, they need to be

carefully handled. Thus hazardous materials storage must make provision for:

• Storage in unobtrusive locations, with restricted access. Access to storage areas shall be

limited to only authorized personnel

• Adequate signage must be provided in the storage area. These signage shall warn on the

dangers of naked flames in the area as well as need for proper dressing and use of

appropriate PPEs

• Areas where flammable materials are stored must be isolated from nearby communities.

They must be shaded from the sun.

• Personnel working in such areas shall be provided with necessary PPEs, including oil-proof

safety boots and coveralls.

• Personnel must be subject to training on handling of hazardous materials and duly certified.

The will also be subject to periodic refresher training

4.4.5 Hydrological Issues

Generally, some portions of the project location, especially in the southern lots, are quite

susceptible to inundation and water logging during the rainy season. Therefore, in the event that

road construction activities block existing natural drainage routes, it could exacerbate inundation in

upstream areas and cause drying up in downstream areas, leading to negative modifications in

existing hydrological regimes. In order to manage this possibility, the following measures shall be

undertaken:

36

• Road alignments shall take into due cognizance, the existing drainage in the area

• Where it is inevitable to tamper with hydrological flows, alternative flow routes shall be

created. This could include the use of underground conduit pipes and/or culverts

4.4.6 Fire Safety and Emergency Management Plans

Fire outbreak is a major possibility in the storage area, where flammable materials like diesel, petrol

and engine oil is stored. It is therefore necessary that a comprehensive fire safety and emergency

management option be provided as part of overall project environmental management plans.

Specifically, the following shall be instituted:

• Muster points shall be provided for all personnel to gather in the event of accidental fires

• Adequate fire fighting gadgets shall be made available and distributed around

construction sites, especially where flammable materials are stored. These includes:

1) Fire extinguishers (H20, dry powder & CO2)

2) Fire hydrant and foam.

o Instructions shall be readable on the body of the fire extinguisher.

o Personnel should be familiar with the operations of fire extinguishers

• Given the agrarian nature of the project location, and the fact that many of the locations are

grasslands, where fire can spread easily. Therefore, adequate fire breaks shall be

constructed around project fuel storage sites, to prevent the spread of accidental fires;

• Regular training on fire-fighting and handling shall be provided. The details of such training

shall include the following:

o Prevent a fire from starting, by minimising ignition sources, oil/gas leaks, enforcing

“no smoking” rules etc

o Protect high fire risk facilities with automatic detectors, early warning devices, and

where feasible automatic extinguishers.

o Provide adequate and suitable fire fighting equipments in all installations.

o Train all personnel, especially those on key installation, in the efficient use of

equipments and extinguishing of fire.

37

o Consequently, everyone is expected not only to prevent, but also to fight fires. It is

important for every person to:

- Know where the nearest extinguisher is installed, and how to operate and use

it.

- Obey “No smoking” signs. Smoke only in designated places and use smoke-

extinguishing equipments safely.

- Not obstruct fire exits and extinguishers.

- Dispose of all combustible wastes, rags, papers and other rubbish in proper

containers.

- Not to overload power sockets.

- Become familiar with the company’s fire emergency procedures applicable to

your workplace.

- Ensure that there are no welding or naked wires in hazardous areas. A written

work permit is a must before a source of ignition is introduced into such areas.

- Attend first aid and fire-fighting training to learn how to extinguish fires using

the equipments provided in your work area.

4.4.7 Health and Safety

The health and safety of personnel working in the project area is important. Therefore, regular

safety training and drills must be carried out to enhance the sensitivity of personnel to safety issues.

Specifics of drills that have to occur include the following:

• Fire drills must be held at least quarterly. Such drills will include mustering at designated

muster points, responding to fire alarms, handling fire-fighting equipment, etc.

• Such drills must be coordinated by the Health and Safety Officer attached to the construction

site, who must be a certified safety practitioner.

• Personnel must be subject to comprehensive health checks prior to employment, so that a

baseline can be established. Attention shall also be paid to trend of common ailments

among toll collection staff, such that any recurrent ailment among the staff that can be

remotely or directly related to their work shall be investigated, as the need arises.

4.4.8 Accidents/Incidents

38

An accident is an unplanned, uncontrolled or undesired event that could result in personal

injury, property damage or loss of time.

Cause of Accidents

In general, accidents are caused by either unsafe acts, unsafe conditions, or a combination of

both. Accidents are rarely as a result of a dramatic failure of equipment; they are mainly due to

human failure. Even an apparent failure of equipment may be due to the human factor in failing

to recognize signs of impending trouble.

Analyses of accidents have shown that over 80% of accidents are caused by such human

factors as persons failing to take proper precautions, ignoring safety regulations or carrying out

jobs incorrectly. These are referred to as unsafe acts and may arise in any or combination of

the following ways:

• using improper methods

• operating without authority

• failing to use proper mechanical aids

• using improper tools/equipment

• failing to wear personal protective clothing

• over-confidence

• impulsiveness

• horseplay

• impatience

• showing off

• laziness

• ill health

• supervisory failure

• poor training

• lack of discipline

• poor house keeping

To minimize unsafe acts there should be:

39

• the fullest possible information to the employee regarding the job

• training appropriate to the work

• adequate and effective supervision

The train of events leading up to an accident to personnel or property follows the sequence

below:

HUMAN UNSAFE ACT PERSONAL UNJURY

ERROR UNSAFE CONDITION ACCIDENT PROPERTY

OR BOTH DAMAGE OR BOTH

Accident Reporting and Investigation

An efficient system of accident investigation and reporting is invaluable in improving safety

performance. Prompt investigation is essential; otherwise vital information may be lost, thus

preventing the correct remedial measures to be taken.

The reporting of potentially serious accidents (near misses) is valuable in providing a pool of

information that can be usefully applied in preventing recurrence and or accidents.

The accident report should begin with a short summary giving the place, date and time of the

incident, the damage or injuries sustained to equipment and/or persons and the estimated out-

of-production time. A brief note to be given of the cause (or believed cause) and the remedial

action proposed.

Accident/Incident Reporting Procedure

• Contact safety officer on site as soon as the incident occurs.

• Safety officer to contact project supervisor who then reports to base.

o However, your knowledge of the response procedures and first aids may have a

dramatic positive consequence on your work facilities and on the life of your

friend.

o However, always remember the following:

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A. DON’T PANIC

B. IMMEDIATELY ALARM/INFORM

o Immediately alarm/inform because help is always required from professional

persons.

ACCIDENT INVESTIGATION

Since it is the desire of RAMP to prevent all forms of accidents in her operations, all efforts will

be geared towards achieving this policy objective. However, detailed investigation shall be

carried out to prevent re-occurrence in case of events that nevertheless occur.

This primary purpose of accident investigation is to establish the circumstances leading to the

accident and use the facts to prevent re-occurrence in the future. Consequently, the exercise

shall be conducted as a fact-finding and not a fault-finding activity.

The responsibility for accident investigation lies with the SPIU. Supervisors and safety officers

are therefore expected to promptly investigate any accident that occurs within and/or around the

project work areas.

4.5 Environmental Monitoring

This aspect of environmental management is specifically designed in the identification of

associated project impacts, equipment malfunction/failure and remedial action. Therefore, for

the purpose of monitoring, RAMP shall focus mainly on the aspects highlighted in an earlier

section of this report and reiterated below:




• Hydrological Issues

• Waste Management



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Based on the foregoing, and in addition to the management options presented above, it is

obvious that regular and periodic monitoring of relevant environmental attributes is necessary.

The specific environmental attributes, the relevant parameters, and the regularity of monitoring

is presented in Table 4.1 below:

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Table 4.1: Monitoring Requirement

S/N ENVIRONMENTAL/SOCIAL ATTRIBUTE

RELEVANT PARAMETERS

FREQUENCY OF MONITORING

LOCATIONS TO BE MONITORED

RESPONSIBLE PARTY


• SO2,

• CO,

• SPM,

• Noise Levels



• RAMP SPIU

• EMP Consultant

• KEPA

2 Soil • pH;

• Conductivity;

• Heavy Metals;


• Hydrocarbons


• Microbiology



• RAMP SPIU

• EMP Consultant

• KEPA

3. Occupational Health and Safety • Personnel health




• RAMP SPIU

• EMP Consultant

• KEPA

4 Traffic Management Traffic situation within and around construction sites shall be regularly monitored to ensure that construction activities do not negatively affect baseline traffic situations


• RAMP SPIU

• EMP Consultant

• KEPA

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SECTION FIVE

COST ESTIMATES AND INSTITUTIONAL FRAMEWORK REQUIREMENT FOR

THE EMP

5.1 Introduction

In this section of the report, an overview of the estimated costs of implementing the various

mitigation measures indicated in the previous section of this report, and the costs of carrying out

environmental monitoring is presented. Also presented in this section of the report, is an

overview of the institutional framework requirement for the implementation of the EMP.

5.2 Cost Estimates for Mitigation Measures and Monitoring Activities

The cost estimates for mitigation measures recommended for the various issues identified in

the previous section of this report are presented in Table 5.1 while Table 5.2 presents the cost

estimates for the monitoring activities identified as necessary for the various phases of the

project implementation, as described in the previous section of this report.

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5.1 Cost Estimates for the Relevant Mitigation Measures

S/N ENVIRONMENTAL/SOCIAL ISSUES MITIGATION OPTIONS COST OF MITIGATION MEASURES RESPONSIBLE PARTIES

1 Traffic and Traffic Management Traffic is not a serious issue in virtually all of the designated roads, since they are mostly rural feeder roads, subject to minimal traffic normally.

Traffic management schemes shall be provided by contractors handling the projects. taking into consideration, as a minimum, the following:

• Minimization of obstruction to normal traffic flow in the area;

• Provision of temporary alternative routes, in the event that absolute obstruction of traffic is inevitable.

• In addition to the foregoing, RAMP shall work in conjunction with traffic management agencies such as the Federal Road Safety Corps (FRSC), to optimize traffic flow, by minimizing traffic obstruction

Provision of Alternative routes will be required only at river/stream crossings. For Seasonal streams, if construction is undertaken in the dry season, only minimal grading and filling of alternative crossings will be required. This is estimated to cost =N=300,000/crossing

Estimates for involvement of traffic management agencies is put at =N=250,000 in each lot

Alternative routes will be provided by construction contractors, while contractors will work in conjunction with RAMP SPIU to involve traffic control agencies for traffic control

2 Air Quality and Noise Levels A. Air Quality The primary concern in terms of air quality is the health of project workers, and nearby communities, who are designated as sensitive receptors for this project. Generally, dust from construction activities will lead to elevated suspended particulate matter levels in ambient air. This, in turn, could predispose project workers and host communities to respiratory infections and ailments. Noise Noise from vehicles associated with construction activities and subsequently, those that will ply the roads, will lead to an increase in ambient noise level. However, because noise during operations will be intermittent, rather than continuous, therefore, effort will need to be paid to construction period noise levels. This is in order to ensure that regulatory limits are not exceeded

RAMP and its contractors shall ensure that:

• Regular monitoring of air quality around the project area are carried out, on a monthly basis, so that negative trends can be promptly detected and addressed;

• Personnel are not allowed to exceed their regular shift durations

• Adequate respiratory protection is provided for project workers on site, so that their exposure to respiratory irritants is minimized

• In the dry season, there will be need for periodic sprinkling of the road surface with water, especially were road works are taking place within and around communities to minimize suspendable dust levels in ambient air.

Noise

RAMP and its contractors will implement the following measures to protect its workers and nearby host communities from the hazards of high noise levels in the area:

• Provide hearing protection for project personnel, who are in high noise areas, close to the machinery that will be

Cost of monitoring is provided in Table 5.2. Provision of respiratory protection (masks) will cost an estimate of =N=250,000/lot Provision of water tankers to sprinkle the roads will cost an estimate of =N=100,000/km Noise monitoring costs are provided in Table 5.2 Hearing protection will cost an estimated =N=250,000/lot

Respiratory protection will be provided by contractors, and they will work in conjunction with RAMP Environmental Officers to ensure the appropriate usage of these equipment Water sprinklers shall be provided by construction contractors Hearing protection will be provided by contractors Regular maintenance of machinery shall be undertaken by construction contractors

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used for project activities;

• Ensure that project personnel do not exceed the normal 8-hr duration of their shifts;

• Provide for regular monitoring of noise levels around the project locations, to facilitate early detection of exceedance of regulatory noise levels

• Undertake regular monitoring of personnel to ensure that they adhere to the relevant health and safety standards pertaining to noise, such as wearing ear protection when noise levels are getting high.

• Ensure that machinery to be used for project construction activities have functional silencers that ensure that noise emissions meet international regulatory standards

3 Waste Management Different categories of wastes will typically be generated around the project area. These will include domestic/food wastes, sanitary waste and some level of oil wastes. These need to be properly handled to prevent environmental degradation

the following waste management options shall be instituted:

• Wastes shall be collected and properly segregated at source. Typical segregation options include separation into: food waste; paper and stationeries; and recyclables (plastic and glass).

• Oily wastes shall be collected and disposed in approved facilities in the state;

Provision of waste bins at construction sites shall cost an estimated =N=120,000/lot Contracting of hazardous waste disposal contractors will cost =N=250,000/lot/month

Provision of waste bins and contracting of waste management contractors shall be undertaken by contractors but will be monitored by RAMP SPIU Safety Officer attached to the lot.

4 Hazardous Materials Storage The main hazardous materials that are likely to be stored within and around the project area include diesel fuels for powering generating sets and for running machinery and equipment to be used for the project; paints and lubricants. Because these materials are highly flammable, they need to be carefully handled.

Hazardous materials storage must make provision for:

• Storage in unobtrusive locations, with restricted access. Access to storage areas shall be limited to only authorized personnel

• Adequate signage must be provided in the storage area. These signage shall warn on the dangers of naked flames in the area as well as need for proper dressing and use of appropriate PPEs

• Areas where flammable materials are stored must be isolated from nearby communities. They must be shaded from the sun.

• Personnel working in such areas shall be provided with necessary PPEs, including oil-proof safety boots and coveralls.

• Personnel must be subject to training on handling of hazardous materials and duly certified. The will also

Provision of signage and cordoning of stacking sites will cost an estimate of =N=200,000/lot PPE per personnel will cost an estimate of =N=50,000/personnel Personnel training will cost =N=45,000/person

This will be the responsibility of the construction contractors per lot

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be subject to periodic refresher training

5 Hydrological Issues Generally, some portions of the project location, especially in the southern lots, are quite susceptible to inundation and water logging during the rainy season. Therefore, in the event that road construction activities block existing natural drainage routes, it could exacerbate inundation in upstream areas and cause drying up in downstream areas, leading to negative modifications in existing hydrological regimes.

The following measures shall be undertaken:

• Road alignments shall take into due cognizance, the existing drainage in the area

• Where it is inevitable to tamper with hydrological flows, alternative flow routes shall be created. This could include the use of underground conduit pipes and/or culverts

No cost is associated with these measures as these options are expected to have been taken into consideration by the contractor

Contractor will be responsible for these actions but will be monitored by RAMP

6 Fire Safety and Emergency Management Fire outbreak is a major possibility in the storage area, where flammable materials like diesel, petrol and engine oil is stored. It is therefore necessary that a comprehensive fire safety and emergency management option be provided as part of overall project environmental management plans.

The following shall be instituted:

• Muster points shall be provided for all personnel to gather in the event of accidental fires

• Adequate fire fighting gadgets shall be made available and distributed around construction sites, especially where flammable materials are stored. These includes: 1) Fire extinguishers (H20, dry powder & CO2) 2) Fire hydrant and foam.

o Instructions shall be readable on the body of the fire extinguisher.

o Personnel should be familiar with the operations of fire extinguishers

• Given the agrarian nature of the project location, and the fact that many of the locations are grasslands, where fire can spread easily. Therefore, adequate fire breaks shall be constructed around project fuel storage sites, to prevent the spread of accidental fires;

• Regular training on fire-fighting and handling shall be provided.

Fire fighting equipment per lot is estimated to cost =N=350,000 Construction of fire breaks around stacking areas is expected to cost =N=150,000/lot

Contactor will be responsible for these actions but will be monitored by RAMP

7 Health and Safety The health and safety of personnel working in the project area is important.

Regular safety training and drills must be carried out to enhance the sensitivity of personnel to safety issues. Specifics of drills that have to occur include the following:

• Fire drills must be held at least quarterly. Such drills will include mustering at designated muster points, responding to fire alarms, handling fire-fighting

Cost of quarterly fire drills and health checks prior to employment should already be incorporated into contractors HSE plan for the project and as such, no costs are associated with these measures

Contractor will be responsible for this, but will be monitored by RAMP’s Environmental officer

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equipment, etc.

• Such drills must be coordinated by the Health and Safety Officer attached to the construction site, who must be a certified safety practitioner.

• Personnel must be subject to comprehensive health checks prior to employment, so that a baseline can be established. Attention shall also be paid to trend of common ailments among toll collection staff, such that any recurrent ailment among the staff that can be remotely or directly related to their work shall be investigated, as the need arises.

8 Accidents/Incidents An accident is an unplanned, uncontrolled or undesired event that could result in personal injury, property damage or loss of time. Since they are not planned, specific mitigation measures cannot be provided for accidents/incidents. However, preventive plans and palliative measures must be put in place

The most critical palliative measure that should be put in place towards preventing accidents/responding promptly, if and when they occur, is the preparation of a site-specific Emergency response plan. Such plans must take into cognizance, as a minimum, the specifics of each project lot

The cost of preparing a detailed and comprehensive Emergency Response Plan for each lot is estimated at =N=500,000.00

Contractor shall handle the preparation of Emergency Response Plans and will share these with RAMP SPIU

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Table 5.2: Cost Estimates for Monitoring Activities

S/N ENVIRONMENTAL/SOCIAL ATTRIBUTE

RELEVANT PARAMETERS FREQUENCY OF MONITORING

LOCATIONS TO BE MONITORED

COST ESTIMATE FOR

MONITORING

RESPONSIBLE PARTY


• SO2,

• CO,

• SPM,

• Noise Levels



=N=250,000/month/lot • RAMP SPIU

• EMP Consultant

• KEPA

2 Soil • pH;

• Conductivity;

• Heavy Metals;


• Hydrocarbons


• Microbiology



=N=300,000/lot/month • RAMP SPIU

• EMP Consultant

• KEPA

3. Occupational Health and Safety

• Personnel health




=N=250,000/lot/monitoring

• RAMP SPIU

• EMP Consultant

• KEPA

4 Traffic Management Traffic situation within and around construction sites shall be regularly monitored to ensure that construction activities do not negatively affect baseline traffic situations


Construction areas will be covered during each monitoring

=N=325,000/lot/permonitoring

• RAMP SPIU

• EMP Consultant

• KEPA

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5.3 Institutional Framework for Implementation of the EMP

In this sub-section, the stakeholders that have been identified as pertinent to this project, in

various respects and their allocated roles are presented.

5.3.1 Identity and Roles of Key Stakeholders

The stakeholders in the KADRAMP project are:

• International institutions – World Bank.

• National institutions: Federal Ministry of Agriculture and Rural Development.

• State Institutions : Kaduna State Ministry of Works ; Kaduna State Environmental Protection

Agency (KEPA).

• Local Government Institutions : The LGA Authorities of the various road projects.

• Community – Traditional rulers, village heads of all the areas covered in the project.

• Others – Private sector (Contractors, Consultants) NGOs.

5.3.2 Roles and Responsibilities of the Stakeholders

5.3.2.1 World Bank

• Review of Environmental and Social Management Reports such as the ESMF and the

Environmental Management Plan for each Lot.

• Provide financial support to carry out the recommended mitigations and monitoring

measures.

• Ensure that all its policies regarding the project design, construction and operation are

complied with. It is the duty of the Bank to ensure that all documents and reports relating to

the project meet its standard requirements.

5.3.2.2 Federal Ministry of Agriculture and Rural Development

• Supervise the Rural Access Mobility project (RAMP) in the implementation of the

mitigation measures and monitoring programme in Nigeria.

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5.3.2.3 Kaduna State Ministry of Works and Transport

• Supervise the Rural Access Mobility project (RAMP) in the implementation of the mitigation

measures and monitoring programme in Kaduna State.

• The issues of consent or approval for an aspect of a project. State RAMP may also have

monitoring responsibility or supervisory oversight during construction in an area of concern

or interest to them.

• Have monitoring responsibility or supervisory oversight during construction.

• Also is responsible for the project environmental performance during its construction and

operational phases.

5.3.2.4 Kaduna State Environmental Protection Agency (KEPA)

• The issuance of consent or approval for any aspect of a project.

• Allow impact to a certain extent or impose restrictions or conditions.

• May also have monitoring responsibility or supervisory oversight during construction in an

area of concern or interest to them.

• They are responsible for the project environmental performance during construction and

operational phases.

5.3.2.5 Local Government Authorities

• They have the duty of overseeing the operations going on within their jurisdictions and it

would be appropriate for them to contribute in one way or another.

• The Local Governments have the responsibility to inform the people about the project.

5.3.2.6 Community – Traditional rulers, village heads of all the areas

• Ensure a conducive social atmosphere for the execution of the project in their various

communities.

• They will act as intermediaries between the project implementation Team and the

communities.

• Assist in the recruitment of local workers during the construction activities.

• Will be involved in all grievance and conflict resolutions.

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5.3.3 Others – Private sector (Contractors, Consultants) NGOs.

The Contractor

The Contractor’s duties include but are not limited to the following:

• Compliance with relevant environmental legislative requirements;

• Work within the scope of contractual requirements and other tender conditions;

• Organize representatives of the construction team to participate in the joint site it sections

undertaken by the Environmental Team (ET), and undertake any corrective actions

instructed by the client and/or Independent Environmental Consultant (IEC);

• Provide and update information to the ET regarding works activities which may contribute,

or be continuing to the generation of adverse environmental conditions;

• In case of non-compliances/discrepancies, carry out investigation and submit proposals on

mitigation measures, and implement remedial measures to reduce environmental impact;

• Stop construction activities which generate adverse impacts upon receiving instructions

from the client/IEC. Propose and carry out corrective actions and implement alternative

construction method. If required, in order to minimize the environmental impact;

• Adhere to the procedures for carrying out compliant investigation; and

• Take responsibilities and strictly adhere to the guidelines of the Environmental Monitoring

and Audit (EM&A) program and complementary protocols developed by their project staff;

• The contractor shall read and understand the EMP and implement same as contained

therein.

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SECTION SIX

CONCLUSION AND RECOMMENDATIONS

Based on the foregoing and the comprehensive EMP that has been presented in the preceding

section of this document, the following conclusions can be drawn:

• The planned project has limited negative impacts that can be mitigated, with a number of

associated positive benefits;

• The environmental sustainability of the project is premised on the implementation of a

sound and cost-effective environmental management program (EMP)

• The EMP presented above is comprehensive and is deemed adequate to ensure the

sustainability of the project;

• It is the responsibility of the RAMP SPIU in Kaduna, and its contractors to ensure that the

EMP is properly implemented;

• Monitoring reports and other environmental compliance activities shall be periodically

reported to the regulatory agencies (specifically, the Federal Ministry of Environment,

FMEnv and the Kaduna State Environment Protection Authority (KEPA).

The Kaduna RAMP is committed to sustainable development and will ensure that all relevant

regulations are complied with. As a starting point therefore, and in compliance with the World

Bank Policy (B.P. 17.50), adequate public disclosure of this EMP document shall be undertaken

upon its finalization. In the course of public disclosure, this document shall be shown to the

various stakeholders, as identified in Section Five and any other stake holder that may be

identified in the course of project implementation. In addition, RAMP, Kaduna will ensure that

periodical reporting of the EMP implementation is made to the relevant agencies.

This document is seen as a living document and will be modified or corrected as the need arises,

either for the purpose of incorporating new issues into the document, or modifying existing issues

to cope with realities of the situation on ground as project implementation activities progress.

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