Below is description of procedure for implementation of mitigation measures and management controls of environmental and social impacts identified during impacts assessment process for the proposed sub-project. The process hinges on implementation of the ESMP and ESMoP by different actors including Contractors and their supervisors; environmental management authorities at local and higher levels; and local management committees and communities at large.
8.1 PURPOSE OF THE SUB-PROJECT IMPLEMENTATION PROCEDURE
The purpose of this process is to enable the various subprojects / ESMP implementing entities to:
ensure that the implementation of the sub-project ESMP is part of the Contractor's contractual obligations
ensure the ESMP is implemented and approval conditions are observed during the mobilization, construction and operation of the sub-project including preparation and execution of environmental and social decommissioning plan in case the project or its component reaches the end of its life.
monitor compliance to laws, regulation and standards including local by-laws
monitor performance and report on all aspects articulated in the ESMP and ESMoP including record of and responding to grievances.
Main steps of the environmental and social management and monitoring process including mandatory initial preparation and implementation supervisionare described below. The salient aspects of the process to be established at ZMC and under each participating PTC and DoURP shall include 4 main steps with substeps:
The Project Teams will ensure that all relevant resources (human and financial) for proposed mitigations are complete before initiating subproject implementation. Execution of infrastructure development works and operation of some facilities (e.g. landfill) will be undertaken by ZMC/PTCs/DoURP through Contractors. Working with the Procurement Section (responsible for supervising the tendering process) the Project Team will ensure environment and social issues are taken onboard and incorporated in the contracts.
Construction phase: ZUSP-PMT shall award the development of entire sub-project to Contractor through one turnkey construction contract. ZUSP PMU, through the ZMC / DoURP Project Team and Design Consultants (with requisite capability/experience in environmental and social impacts mitigation / integration) shall develop the Scope of Work (SoW) including choice of location, technology, layout etc.) while the Subproject Contractor shall execute the SoW including detailed engineering and implementation of ESMP components relevant to mobilisation and construction/installation in accordance to international and Tanzania/Zanzibar specifications and standards.
Construction supervision consultancies experienced in environmental and social management will be procured to work with ZMC/PTCs /DoURP EOs to supervise construction of subprojects and to transfer skills to technical staff.
Operation & maintenance: Infrastructure, once complete, will be maintained by respective LGAs (ZMC / PTCs/DoURP) including implementation of operations aspects of the ESMPs linked to sub-projects. These tasks are long-term and will be done by infrastructure sector specialists. Depending on the nature of the subproject ZUSP shall award one contract for operations and maintenance of the facility such as landfill and septic sludge treatment facility. LGA/DoURP Environmental Officers shall undertake monitoring of operations aspects of the ESMP while coordinating input and involvement oflocal management committees and communities.
ZMC /PTCs /DoURP contributions: will continue to make in kind contributions in the form of staff time. ZUSP PMU will continue to provide support to assist ZMC in the implementation and monitoring of both the construction and operation aspects of the infrastructure sub-projects including organizing technical assistance and training to ZMC/PTCs/DoURP as relevant.
Permits and Notifications
The sub-project implementation shall be carried out in accordance to international and Tanzania/Zanzibar environment, health, safety and security requirements, standards and best practices including all conventions ratified by the RGoZ.The equipments and materials used will have all necessary certification/registration and fully compliant with specific requirements for subproject size and purpose.
ZUSP and ZMC/PTCs/DoURP will seek and obtain the necessary permits and / or MOUs from relevant authorities and undertake notifications as per environmental management regulations (Table ). The Project Teams will ensure that all relevant project approvals including ESIA Certificate, OSHA etc. are in place. Most of the authorities listed have been working with ZUSP and were visited by the ESIA Consultant and provided with information introducing the ZUSP-AF. ZUSP and ZMC/PTCs/DoURP will carry further the consultations before commencement and during the implementation of individual sub-project.
Table Permit Requirements and Notification to Relevant Authorities
Type Of Permit / Notification
Relevant Authority / Stakeholder
Use of existing Right of Ways ( e.g. road way-leaves)
Notification of key stakeholders in Unguja and Pemba
ZEMA (Director General and Directors of EIA and Enforcement).
Ministry for Environment (Minister & PS)
Department of Environment)
Regional and Local Government Authorities (Regional Commissioners, District Commissioner, Municipal /Town Directors; Chairpersons of Council Environment Committees.
District environmental officers, District health officers
Building permits – Stone town conservation development authority (STCDA)
ZMC- Building permits department (For Zanzibar Municipality)
Community / Public Mobilization and Sensitization
Community financial contributions (as condition of construction commencement) are not a requirement under ZUSP because, in urban settings, it could lead to delays.
Stakeholders should be directly involved in project implementation and monitoring however. Public awareness and mobilization shall be mandatory before commencement and throughout implementation of a subproject financed by ZUSP-AF. Affected people and stakeholders shall be informed about the outcome and decisions on the ESIA approval process, schedules of project implementation and who, how, where, when they will participate.
STEP 2: IMPLEMENTATION SUPERVISION
Implementation of RAP
Subprojects will be mostly sited on the current location of existing infrastructure. Where land is required, i.e. rerouting, expansion or extension, or establishment of new infrastructure, the subproject will utilize land designated by LGA or land acquired from individuals. Compensation procedures and payment of compensation costs by ZMC/PTCs/DoURP will be in accordance with RAPs prepared and approved for respective subprojects in accordance with the Resettlement Policy Framework which is a separate document that has been developed in parallel to this ESMF, as required by World Bank Op 4.12. Support will be provided to assist LGAs in the implementation of the RAPs prior to commencement of construction contracts including payment of compensation costs. (See Resettlement Policy Framework for details)
Implementation of Subproject ESMP
The preparation of an Environmental and Social Management Plan (ESMP) is a requirement of the Zanzibar EIA Regulations / Procedure and World Bank OP 4.01 The plan should provide guidance for implementation of the identified mitigation measures, and indicate costs14, timeframe and assign responsibilities. ZUSP and its Partners (ZMC/PTCs/DoURP) shall be responsible for overall implementation of the ESMP.
Management Controls by ZUSP / Partners (ZMC/PTCs/DoURP)
Implementation of the ESMP is solely the responsibility of the sub-project proponent. ZUSP shall supervise and monitor all components implemented by the Contractor(s). ZUSP shall provide the necessary supervisory oversight to ensure the mitigation measures are implemented. All aspects of the proposed subproject development and operation will be managed to comply with ZUSP’s ESMF and Zanzibar’s environmental regulatory requirements and standards (see above)
During the construction and operation of the subproject, ZUSP will apply a systematic approach to optimize the Health, Safety, Security and Environment (HSSE) performance for the project and ensure that its HSSE objectives and management standards are achieved. The project will continuously undergo a comprehensive planning process to ensure that the management requirements identified are implemented on site through clear designation of roles and responsibilities. The management requirements will be incorporated into implementation strategy for the project via the following key procedures and plans:
Pre-tender HSSE qualification process including development of environmental specifications
Contractual and procedural controls on the selected subproject Contractor (i.e. inclusion of environmental conditions in contractual documents)
General Management Programms and ZMC/PTCs/DoURP management plans to guide the subproject Contractor include:
Waste Management Plan
Health, Safety and Security Plan
Stakeholder Management Plan
Emergency Response Plan (ERP)
Direct project supervision
Review/auditing and reporting of environmental performance/improvement of implementation.
Management Controls by Sub-project Contractor
The Contractor shall ensure that those mitigation measures that are to be implemented during mobilisation and construction and operation are attended to according to ESMP and specific work plans. The Contractor shall simultaneously undertake monitoring and reporting of environmental performance/improvement of implementation. Mitigation implementation shall specifically entail:
Development of sub-project specific work plans to include:
Waste Management Plan
Health and Safety Plan
Stakeholders Engagement Plan
Emergency Response Plan (ERP)
Basic environmental and social guidelines for contractors and the Project Teams are included in Annex D.
The purpose of the induction is to encourage environmental and social responsibility among all personnel and ensure that the personnel are made fully aware of the measures required to be implemented to minimize the potential impacts on the environment, prior to the commencement of the project. The personnel with responsibilities in specific environmental practices will be adequately trained to ensure effective implementation of the works instructions and procedures for which they have responsibilities. This induction should address the subproject Health Safety, Security and Environment Plan (use of PPE, fire fighting facilities); good site practices and housekeeping; sound waste management (handling/clean-up of contaminating spills, storage, use and disposal of hazardous materials/wastes); and interactions with local community.
Taking cognizant of the fact that much of the sub-project activities will take place within urban local government authority (ZMC/PTCs/DoURP) sub-projects are likely to interact with a number stakeholders currently known and unknown. It will be the responsibility of ZMC/PTCs/DoURP EOs working with the sub-project Contractor’s Environment Liaison Officer to coordinate the involvement of relevant government authorities and service providers and meet related costs.
Stakeholders Engagement Plans For Sub-project
The Stakeholder Engagement Plan (SEP) developed during ESIA and RAP preparations identifies the roles of key stakeholders that should be further elaborated in the relevant sections of the ESMP. These would include government authorities at all levels responsible for Environmental and social impacts monitoring as well as community mobilization and awareness15; infrastructure and utilities authorities (for water supply, wastewater disposal services, electricity power supply services (if relevant), connection of access road to highway) as well as local communities and their leaders and committees in area of influence. Other stakeholders include private and public entities providing support and facilities for waste disposal, materials supply etc.
Environmental and Social sensitization and awareness
The purpose of the awareness and sensitization programme developed by ZUSP and Partners and implemented with participation of the subproject Contractors is to ensure continued project acceptance by the stakeholders groups, manage expectations and minimize conflicts. The programme shall be developed mindful of type of communication information, awareness creation tools, communication channels and messages fit for specific targets/audience. The key aspects shall include but are not limited to:
Sub-project development and operation schedules and activities
Management of expectations – employment services provision; access to Project facilities and services (water supply, reusable items etc.)
Defining issue of land take, user rights and access
Project’s health, safety, and security procedures and requirements concerning the communities (site hazards during construction; vehicle movements and traffic accident; interactions with project personnel; exposure to disease and transmissions (HIV/AIDS).
Grievances Redress Procedures
Grievance redress mechanisms are essential tools for facilitating project affected people (PAPs) to voice their concerns about the resettlement and compensation process as they arise and, if necessary, for corrective action to be taken promptly. Such mechanisms are fundamental to achieving transparency in the acquisition and resettlement processes, as well as provide a clear way for PAPs to voice concerns about overall project activities. Greater detail on grievance procedures specific to resettlement can be found in the RPF. This section outlines general grievance procedures applicable for any PAPs with concerns about broader project activities.
First, three committees are being established to address grievances:
Table Committees for grievance redress mechanisms
Principal secretary of Ministry of Finance (Chair)
Representative of District Commissioner
Representative of ZMC
Representative of Ministry of Lands
Representative from the ZUSP - AF of the Ministry of Finance
Representative of PAPs
District Commissioner (Chair)
Representative of ZMC
Representative of Ministry of Lands
Representative from ZUSP – AF of the Ministry of Finance
Representative of PAPs
Representative of a local NGO
All attempts would be made to settle grievances. Those seeking redress and wishing to state grievances would do so by notifying their Sheha who is the government representative at the village level. For resettlement issues, the Sheha will inform and consult with the Resettlement Committee for compensation issues, to determine claims validity. If valid, the local Sheha will notify the complainant and s/he will be settled. If the complainants’ claim is rejected, then the matter will be brought before the Regional Administration for settlement. The decision of the Regional Administration would be final and all such decisions must be reached within a full growing season after the complaint is lodged.
If a complaint pattern emerges, the ZMC, Regional Administration and the Department of lands will discuss possible remediation. The local leaders will be required to give advice concerning the need for revisions to procedures. Once they agree on necessary and appropriate changes, then a written description of the changed process will be made. The ZMC, the Regional Administration and Sheha will be responsible for communicating any changes to future potential PAPs when the consultation process with them begins.
A Grievance Redress Committee will be constituted to register the grievance raised by the PAPs and address the grievance forwarded by the PAPs representative committee. The Grievance Redress Committee will try as much as possible to arrive at a compromise for the complaints raised. This may be obtained through series of conciliations, mediations and negotiations exercises conducted with the PAPs.
If PAPs accept the recommendations made by the committee, the committee along with PAPs who are willing to take part in these proceedings may hold mediations at the appointed places. In situations where PAPs are not satisfied with the decision of Grievance Redress committee, the PAPs can approach the Tribunal/ court of law. The response time for cases handled in both committees will depend on the issues addressed but it should be as short as it is possible.
STEP 3: SUBPROJECT MONITORING AND REPORTING
Objectives for Monitoring
The objectives for monitoring are: (i) to alert project implementing institutions and to provide timely information about the success or otherwise of the EIA process as outlined in this ESMF in such a manner that changes to the system can be made, if required; (ii) to make a final evaluation in order to determine whether the mitigation measures designed into the infrastructure projects have been successful in such a way that the pre-infrastructure project environmental and social condition has been restored, improved upon or worse than before.
Monitoring Indicators In order to assess whether these goals are met, the infrastructure projects will indicate parameters to be monitored, institute monitoring milestones and provide resources necessary to carry out the monitoring activities. Monitoring indicators which should be included in the Project Monitoring Manual include:
Efficiency of infrastructure projects maintenance and operating performance;
Water quality and soil quality at site and outlet (e.g. final exit of storm water drains) of infrastructure sub-projectt meets local standards
Compliance with the Environmental Guidelines for Contractors
Safe disposal of hazardous wastes
Number of people provided with environmental training to implement the ESMF
The number of local workers used during implementation of the works
Savings in costs for resources and services required to maintain the infrastructure (water, energy, management of liquid and solid waste etc.)
STEP 4: SUBPROJECT REVIEW AND AUDIT
After a period of implementation the ESMPs of sub-project should be subject to annual reviews / audits. Annual Reviews of the ZUSP sub-projects will be carried out using external / independent reviewers /auditors as commissioned by ZUSP PMT. These are to be Third Party audits (by independent Local Consultant, NGO or Service provider) which will review the implementation of environmental and social management in the project.