USAID WULA NAFAA ENVIRONMENTAL MITIGATION AND MONITORING PLANS JANVIER 2010 Cette publication a été produite pour l Agence Internationale du Développement des États-Unis par International Resources Group (IRG).
USAID WULA NAFAA ENVIRONMENTAL MITIGATION AND MONITORING PLANS January 2010 Prepared by Tom Catterson, IRG Environmental Compliance Specialist (Final- January 19, 2010) Avertissements: Les points de vue des auteurs exprimés dans cette publication ne reflètent pas nécessairement ceux de l USAID ou du Gouvernement des USA.
TABLE OF CONTENTS USAID WULA NAFAA ENVIRONMENTAL MITIGATION AND MONITORING PLANS ERROR! BOOKMARK NOT DEFINED. ANNEX 1. FICHE D INFORMATIONS DU BUREAU AFRIQUE DE L USAID SUR L ENGRAIS 19 ANNEX 2. ENVIRONMENTAL PLANNING CHECKLIST FOR SMALL-SCALE IRRIGATION 24 ANNEX 3. ENCAP VISUAL FIELD GUIDE: WATER SUPPLY 26 ANNEX 4. ENCAP VISUAL FIELD GUIDE: SANITATION 28
ACRONYMS EMMPs ERF GIE IEE IREF IRG PCR PEA VIP WN Environmental Mitigation and Monitoring Plans Environmental Review Form Economic Interest Groups Initial Environmental Examination Inspection Régional des Eaux et Forêts International Resources Group Président Communauté Rural Programmatic Environmental Assessment Ventilated Improved Pit USAID Wula Nafaa
INTRODUCTION This document has been prepared by International Resources Group (IRG) in response to the comments made by USAID/Senegal about the USAID Wula Nafaa (WN) Annual Work Plan and the need to ensure that project activities were being implemented in the light of the findings of the Initial Environmental Examination (IEE). 1 Please note that IRG and its partners involved in Wula Nafaa are fully cognizant of the Reg. 216 threshold determinations that USAID/Senegal has chosen under its SO-11 IEEs (original of 2006 and amendment of 2009) and which have been subject to the review and approval of the USAID Africa Bureau Environment Officer. These USAID/Senegal-generated environmental compliance documents and their findings underscore the need for preparing Environmental Mitigation and Monitoring Plans (EMMPs) for the following activities foreseen under and being implemented by Wula Nafaa (quoting from the IEE): For IR 1: Increased Trade of Agricultural and Natural Resources Based Products: a) A negative with conditions is recommended per 22CFR216.3(a)(2) (iii) for activities creating or expanding income-generating enterprises and resources management systems. These include, among others: agricultural processing, textiles production, harvest and marketing of timber and non-timber forest products, horticulture, fisheries, domestic energy, tourism as well as all technical services and training provided in these sectors. This IEE describes a specific set of steps that will be taken to ensure adequate environmental review and mitigation. With implementation of the recommended mitigation and monitoring measures, these activities are not expected to have significant adverse impacts on the environment. For IR 2: Improved Sustainable Management of Natural Resources and Biodiversity: b) A negative with conditions is recommended per 22CFR216.3 (a)(2)(iii) for the following activities that are not expected to have significant adverse effects on the environment but could lead to negative impacts if not designed and implemented with the viability of the natural area in question: development of protected area management plans; development of sustainable financing mechanisms for national parks; co-management of protected areas with local communities; promotion of agreements, approved plans or memorandums of understanding to solidify community rights to a resource. Furthermore, as the original IEE clearly states, As required by ADS 204.5.4, the SO 11 Team and activity implementing partners (in this case IRG and its subcontractors) will actively monitor and evaluate whether these conditions associated with these activities are being implemented effectively and whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in accordance with sound environmental management. (USAID/Senegal 2006). OTHER PRINCIPLES FOR ADDRESSING ENVIRONMENTAL COMPLIANCE MATTERS WITHIN USAID WULA NAFAA Implementation, not just documentation: The IRG approach to meeting its obligations as an Implementing Partner within the USAID/Senegal program is focused on ensuring that the implications of the Environmental Procedures are translated into positive actions. Too often the basic rationale for Reg. 216 gets lost in the shuffle related to the multi-faceted requirements for compliance. Sometimes the overwhelming focus on ensuring that the appropriate documentation is in place an IEE, an EMMP or even 1 See memorandum of the COTR of Oct. 15, 2009. ENVIRONMENTAL MITIGATION AND MONITORING PLANS 1
a Programmatic Environmental Assessment (PEA) becomes the raison d etre of the process. Within Wula Nafaa, we will do our very best to ensure that the real expectations of Reg. 216, i.e., that something affirmative is being done to avoid the adverse environmental impacts that may arise from the nature of USAID s programs in the country. Integration rather than segregation: Similarly, we will strive to integrate the mitigation measures as a routine part of the management practices we are promoting rather than treating them, as so often happens, as a separate or segregated implementation requirement. The basic premises behind Wula Nafaa of increased production and natural resources management are grounded in the notion of sustainability, that one uses natural resources within the carrying capacity of the resource base whatever it is. Capacity Building for Environmental Management: That the guidance contained in the various USAID guidance documents mentioned below for each of the program components will be used, beyond design and implementation of the component, for awareness raising and training both technical staff and community participants in the environmental management of their improved farming systems and/or natural resources management related value chains. PROGRAM COMPONENTS AND THEIR SECTORAL EMMPS The tables which follow provide the Environmental Mitigation and Monitoring Plans for each of the activities of WN that were accorded a threshold determination of negative with conditions. By implementing these EMMPs we seek to avoid the possibility of adverse socio-environmental impacts that might be foreseen as an outcome of the planned activities. While in many cases, our mitigation plans will essentially follow the sectoral guidance provided by USAID, in some instances we will highlight cause and effect and provide more explicit information about the mitigation measures associated with particular potential adverse impacts. And as required, our EMMPs also include monitoring because of their very nature; it is essential to ensure that in fact the mitigation measures are effectively avoiding adverse environmental impacts. 2 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
Agriculture Component-Rehabilitation of degraded small-scale irrigation perimeters General Conditionality associated with small-scale irrigation activities. First of all it is essential to note that USAID Wula Nafaa will mostly be working on sites that have been under irrigation programs for some time and are currently degraded and not meeting production goals. Many are in low-lying areas that have been subject to human interventions for some time. These activities will be implemented following the sectoral guidance prepared and recommended by USAID in its Environmental Guidelines for Small-Scale Activities in Africa (http://www.encapafrica.org/egssaa.htm) and especially the Chapter 1 on Agriculture and Irrigation (http://www.encapafrica.org/sectors/agriculture.htm ). In addition and building on the efforts within USAID itself to further develop the guidance available on environmental sound management of small-scale irrigation, IRG and its partners will pay particular attention to the guidance available in the Programmatic Environmental Assessment of Small-Scale Irrigation in Ethiopia which is also available on the ENCAP Africa Website (http://www.afr-sd.org/publications/pea.pdf ). Of particular interest for local implementers of small-scale irrigation will be Appendix H of this PEA which is an Environmental Planning Checklist for Small-Scale Irrigation (See Appendix A of this EMMP). It should be noted that IRG and its local partners fully understand that the full potential and productivity of these improved agriculture schemes, where for staple crops (consumption) or for horticulture (for sale) will rest on an ability to bring appropriate modern technology and incorporate it into the present farming systems. This includes both fertilizer use and pesticide use. In the case of fertilizer, WN will follow the guidance provided by USAID developed by the Africa Bureau of USAID, Office of Sustainable Development in the Fertilizer Fact Sheet for Africa (http://www.encapafrica.org/meo_course/specialtopics.htm #fertilizer ) which has been included as an annex to this EMMP for ease of reference. WN has translated this document into French so that it can be more widely assimilated here in Senegal and elsewhere in francophone Africa (See Appendix B). In light of the fact that these production systems will also likely require the use of pesticides, as part of an integrated approach to pest management, that WN will conduct a small-scale irrigation and horticulture related PERSUAP (Pesticide Evaluation Report-Safe User Action Plan) to ensure that these agrochemicals are properly used. It should be noted that the PERSUAP will take into account current national and regional (CILSS) practices regarding pesticide registration and use. The EMMP which follows addresses some of the most typical socio-environmental risks associated with the development and rehabilitation of small-scale irrigation perimeters in Senegal. The list is not exhaustive nor does it address all of the parameters of the restoration of the productivity of wetland areas used for agriculture within the Wula Nafaa project area as this would be beyond the scope of the present exercise. Any environmental compliance reviews supposes that the chosen technology is being applied more or less correctly. One does not mitigate mistakes, those are corrected. Furthermore, the rather ample environmental guidance documents noted above are part of the extensive and detailed literature generally available for the sub-sector of small-scale irrigation and on which the activities of this component will be based. Activity Possible Adverse Impact Proposed Mitigation Measures Monitoring Indicators Monitoring/ Reporting Frequency Responsible Parties Observations and/or Verification Checklist Restoration of an existing small-scale irrigation perimeter and its productivity. Water Resources development related social conflict, such as property rights, farmer/livestock conflict, and water The basis for this investment must be an agreement with the participant community that results in signed local convention Monitoring of the number of times the participants must appeal to the CR for interventions about conflicts that they As required during the entire year. The Scheme Management Committee and the traditional authorities will be the main persons to resolve these issues Transparent management of the Scheme Management Committee and its regular meetings should be part of the training package, and ENVIRONMENTAL MITIGATION AND MONITORING PLANS 3
availability constraints. (accompanied by indepth awareness raising and training as part of the early steps to set up the work site) attesting to a high degree of social cohesion related to the investment and/or recognition of these potential issues and a willingness to abide by the need for negotiation and solution. are unable to resolve themselves. A review of the local convention to ensure that it covers the full range of the experiences of the participants as the scheme is launched and operated. and monitor the situation. They may appeal to the CR and/or Wula Nafaa personnel (eg. local facilitator or ACF) to assist them as needed. Wula Nafaa should verify that it is working well. Engineering and drainage works within the site being restored. Stagnant water or poor drainage within the perimeter can lead to an increase in the incidents of water related diseases, such as malaria or bilharzias. Careful use of leveling technology to ensure correct bunding and drainage works. Visual inspections during the production season to be sure that water spreads evenly across the perimeter and drains as well. At the height of the rainy season and at the end of the production season. Wula Nafaa water resources engineer with support from the local facilitator and the ACF, in collaboration with the leaders of the management committee. Verify that the site has been traced using appropriate leveling technology. Expansion of the perimeter. Although the sites being chosen are mainly very flat, the actual extent of the expansion is sometimes hard to foresee because of micro-changes in topography, leading to possible displacement of Here again, appropriate leveling technology will be employed to ensure that the bunding or diguettes established within the perimeter are well done, and also do not lead to siltation or Visual inspections during the production season to be sure that water spreads evenly across the perimeter and drains as well. At the height of the rainy season and at the end of the production season. Wula Nafaa water resources engineer with support from the local facilitator and the ACF, in collaboration with the leaders of the management committee. Verify that the site has been traced using appropriate leveling technology. 4 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
other users or land-use change. sedimentation of the water course into which the wetlands drains. Biodiversity and Natural Resource Management Component Natural Forest Management Timber and Charcoal General conditionality associated with the natural forest management activities. The activities foreseen for this component of the project were planned on the basis of a comprehensive study financed by the project in 2006 and reflect the commitment to move towards more sustainable harvesting and management of natural forests in Senegal (Grosenick et al 2006). Indeed and as specifically and emphatically stated in the USAID IEE, Mitigation against adverse environmental impact from trade in forest products will be established within local forest management plans that are environmentally responsible, social beneficial and economically viable The management plan will in effect constitute an environmental assessment with the added value of being done locally, under local laws and considering local input (USAID/Senegal 2006). The agreements with local people to establish the management plan and the use limits will be part of a consultative process that results, similar to many of the Wula Nafaa CBNRM arrangements, in a local convention that binds the concerned communities to respect both their resource rights and responsibilities. It is also important to note that the sites being chosen for the community forestry management plans are typically areas where the forests have long been used by local people and local communities, sometimes in unsustainable ways. Across the forested landscape of the Wula Nafaa project area, it would difficult to find forest areas, adjacent to local communities, that might be considered relatively undisturbed and therefore outside the findings of the present IEE. Even in Kedougou, fire and/or livestock tend to penetrate into almost all of the forested landscape and have a sometimes profound effect on natural conditions. Furthermore and finally, the least disturbed forest areas where WN might consider working are probably too inaccessible (and hence still in close to relatively undisturbed condition) to allow for economically sustainable forest products extraction because of transport costs. It should be further noted that these activities will be planned and implemented following the sectoral guidance prepared and recommended by USAID in its Environmental Guidelines for Small-Scale Activities in Africa (http://www.encapafrica.org/egssaa.htm) and especially the Chapter 7: Forestry: Reforestation, Natural Forest Management, and Agroforestry (http://www.encapafrica.org/sectors/forestry.htm). In addition, the Wula Nafaa team will also use the guidance contained in the Etude d Impact Environnemental Programmatique de la Cogestion des Forêts Classées de Guinée (http://www.encapafrica.org/docs.htm#sec_spec). And finally, in addition to following this USAID provided sectoral guidance, the Wula Nafaa team has prepared the following EMMP for this project component. Activity Possible Adverse Impact Proposed Mitigation Measures Monitoring Indicators Monitoring/ Reporting Frequency Responsible Parties Observations and/or Verification Checklist Community Forestry Agreement Opening forestry activity areas in relatively undisturbed forest. Verify that the extent of the community forest being proposed for management is limited to their traditional usage Trace the border of community forest, with a GPS to establish the accepted boundaries, and to verify with the Président Once at the outset of the participatory forest management planning exercise. Community forestry committee, with the President of the PCR and/or the PCE (President de la Commission Environnement) The idea is to prioritize forest area that have been traditionally used by local communities to improve their management and sustainability.verify ENVIRONMENTAL MITIGATION AND MONITORING PLANS 5
areas. Highlight the strategic importance of these forests as part of the forest estate in Senegal Communauté Rural (PCR) that indeed these forests are part of the community s traditional usage areas. here that this is the case. The present group of community forests where WN is working, for example, the Foret de Sare Bidji, are all heavily disturbed by human interventions and use. Forest management planning With the forest there may be sensitive areas, such as chimp habitat, riparian areas, wetlands or steep areas that should neither be disturbed nor harvested. Include estimates of the status of wildlife populations within the forest and make plans for their conservation and management. Management planning includes the preparation of a site map that deliminates sensitive areas and ensures that tree cutting or access roads are not being built there. This includes 100 meter wide buffer strips around wetlands and 50 meter strips along watercourses or riparian areas. Each year the cutting area will be delimited using a GPS and this will be plotted on the map. Annually, at the start of the timber harvest season and at the end. Community Forestry Management Committee (en particulier les RT: Responsables Techniques) should verify that the limits have been respected and report to the PCR. Confirm the existence of a suitably scaled forest map with sensitive areas clearly denoted. Consider the establishment of a permanent sample plots to track the impact of the forest management practices. Forest exploitation for timber Over-cutting could lead to deforestation. An inventory has been carried out within the annual coupe plots and the annual allowable cut calculated on the basis of growth information and distribution of stems per diameter Management records should show the amount of timber extracted on the annual cutting plot. Additionally, it will be possible to control the tree cut by reviewing the Annually at the end of the timber harvest season. Wula Nafaa will take some digital photos at designated points within the sites Community Forestry Management Committee should verify that the limits have been respected and report to the PCR and to the Inspection Régional Compare forest inventory estimates with extraction records and confirm that the limits have been respected an important point to be mentioned as part of the WN annual report. 6 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
class for these forest types and conditions. Here also, for both timber and charcoal, one can speak about a very conservative methodology with a rotation of 16 years and fixed minimum cutting diameters by species following verified calculations about regrowth after exploitation. numbers on the cut stumps and their respective diameters (during the inventory, all of the exploitable individuals were marked with distinctive numbers to allow them to be traced following exploitation. harvested. des Eaux et Forêts (IREF). Selection of preferred timber species There is a risk of changing forest stand composition if these preferred species do not regenerate on the sites from which they have been harvested. A study has been conducted of the regeneration typically found on these sites (Polansky 2008) and its findings will be used to gauge the need for additional interventions. Cutting will be selective and not remove all potential seed trees from the plots under exploitation. Quick studies of the harvested plots after cutting to determine the composition of the existing regeneration. Annually at the end of the rainy season. Community Forestry Management Committee (specially the RT : les Responsables Techniques) will perform this task and report to the PCR and IREF. Could be a very useful research topic for a Master s student or university faculty member. Rationalizing charcoal production in community forests The demand for charcoal is very high and overcutting could lead Charcoal harvesting plans are based on a very conservation methodology involving every Management records will show the amount of charcoal extracted and it will be easy Annually at the end of the current years exploitation activities for Community forest committee members should control and verify the cutting intensity Compare estimates of charcoal on the sites with extraction records and confirm that the limits have ENVIRONMENTAL MITIGATION AND MONITORING PLANS 7
(e.g Sare Bigiy to deforestation. other tree over 10 cms diameter on the designated plots of the preferred Combretum spp charcoal species and waiting 8 years for the recutting of the coppice growth on the same plot. to verify that only half the trees in the stand have been cut. charcoal. Wula Nafaa will take some digital photos for the record at designated points within the sites harvested. limits have been respected as part of the Convention they signed. been respected an important point to be mentioned as part of the WN annual report. Access road building Access roads built within the forest could open new areas, cause erosion in wetlands or at stream crossings or disturb critical wildlife. Actually, within the current forests being brought under management, there will be little or no access roads required because the amount of timber per hectare to be extracted is small and can be managed without adding new roads and by making use of the existing access network in each forest. Inspection visit verifies that no new roads have been built. Annually at the end of the timber harvest season. Community Forestry Management Committee should verify that the limits have been respected and report to the PCR. Community comanagement of the forest resource base Social conflict and a lack of respect for the parameters of the forest management plan. Community forestry committee will be responsible for ensuring that their members respect the plan (the expectations of the convention signed with them) and that they protect the forest Need for intervention by the PCR to resolve conflicts. Annually after the harvest season. President of the Conseil Rural with the representatives of the Community Forestry Committees. As part of the annual process of preparing the Plan de Gestion Annual, the Community should evaluate their satisfaction with the Forest Management Plan and how it has been implemented, and a synopsis of this 8 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
from depredations by other neighboring communities. process is a worthy note for the WN annual report. Potable Water Component Construction of Wells and Latrines General Conditionality: The activities foreseen under the water and sanitation component of Wula Nafaa will be financed in part under the aegis of the WADA Grant from Coca Cola. As a grant activity and following conventional environmental procedures for same, during the preparation of the proposal for this sponsor, an Environmental Review Form (ERF) was completed for these activities. This form includes a very specific set of mitigation and monitoring measures which have accordingly been used to provide the details of the EMMP outlined here below. However, since the water and sanitation component was not really covered in detail under the existing IEE, we should reiterate that the IEE for the component would have allocated a categorical exclusion for all but the watsan infrastructure activities (wells and latrines) foreseen as part of this component including: carrying out a participatory socio-economic diagnosis; developing a participation framework at the local level; carrying out technical feasibility studies; preparing a communication and extension plan; strengthening the skills (training) of the local participants; and putting in place a maintenance and management plan for the infrastructure being established. The activity foreseen having direct impact on the ground, that of constructing 24 wells and 15 sets of sanitation works, is being treated as small-scale water and sanitation infrastructure and accorded a threshold determination of negative with conditions (again, spelt out in the details of the EMMP below). USAID experience in general is rich with guidance related to water and sanitation given its longstanding basic commitment to humanitarian and development programs. As part of the conditionality associated with these activities, Wula Nafaa will be following several of the sectoral guidance prepared and recommended by USAID in its Environmental Guidelines for Small-Scale Activities in Africa (http://www.encapafrica.org/egssaa.htm) and especially the Chapter 16 on Water Supply and Sanitation (http://www.encapafrica.org/sectors/watsan.htm ) which is also available in French on the same website, as Approvisionnement en eau et systemes sanitaires. Similarly, the information contained in another USAID/Ethiopia related report is also a good source of guidance. It is titled Water and Sanitation: Water and Food-Aid in Environmentally Sustainable Development: An Environmental Study of Potable Water and Sanitation Activities with the Title II Program in Ethiopia (http://www.encapafrica.org/docs.htm#specificwater ). And finally, IRG has acquired a hard copy of the CRS report also prepared for USAID/Ethiopia titled Guidelines for the Development of Small-Scale Rural Water Supply and Sanitation Projects in Ethiopia (CRS/Ethiopia 2003). Activity Possible Adverse Impact Proposed Mitigation Measures Monitoring Indicators Monitoring/ Reporting Frequency Responsible Parties Observations and/or Verification Checklist Potable Water Component Building Wells at the Village Level Developing the community water development plan and agreement Improper choice of the well site could affect sensitive areas or the wells could be contaminated by Develop a plan with the community for the well site, avoiding areas adjacent to sensitive areas (bas- A community agreement about the choice of the well site that meets the guidelines (suggest Wula Use the Visual Field Guide as the major steps of the well drilling program are put in place. Wula Nafaa watsan personnel with community water infrastructure management committee. A copy of the Visual Field Guide Water Supply becomes part of the program record, initialed and dated by those reviewing the ENVIRONMENTAL MITIGATION AND MONITORING PLANS 9
either subsurface sources or surface drainage into the well head. fonds), being too close to nearby latrines, or sites where drainage would run into the well head. Community committee should be trained to understand basic choices in well siting. Nafaa personnel with utilize the USAID ENCAP Visual Field Guide: Water Supply, (see Appendix C of this EMMP) as a checklist to verify the design and implementation dimensions of this well building component. work. This simple checklist will also be translated into French and shared with the Village Committee as a training tool and for their use. Wells to be used manually or with solar pumps. Overuse of the well could lead to depletion of ground water resources and/or conflict among neighbors. Well construction should include: bringing in a qualified hydrogeological engineer to assist in siting the multiple well locations in each participating village and to provide basic design guidance in terms of the size, expected depth to ground water and probable usage characteristics, well head cap and apron design and pump specifications. Community well management and maintenance committee should maintain records of water use and modify participant use if necessary during the dry season. Further verify that there has been no apparent impact on nearby surface water resources or other nearby wells. Community well committee should develop an understanding of the behavior of the water table throughout the year (hence the need for records). Critical period, however, will be at the end of the dry season. Consulting water resources engineer or hydrogeologist should have provided an estimate of the recharge rate and usage rate. Community committee keeps records. A copy of the Visual Field Guide Water Supply becomes part of the program record, initialed and dated by those reviewing the work. Well water use as a primary source of drinking water in Natural or human caused biological or chemical contamination of Any USAID supported potable water supply project must Water quality testing is essential at the commissioning of Wula Nafaa watsan personnel will certify water potability before Semi-Annual water testing to be outsourced to the Govt. of Senegal Ibid. 10 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
the village. groundwater sources in the wells, including: naturally occurring arsenic; improper leveling that leads to drainage of surface run-off into the well head and possible fecal contamination. adhere to the guidance provided by State cable 98 108651 regarding mandatory testing for arsenic. It also requires that Missions follow the practical guidelines for sampling and testing for arsenic which are now available for use by the responsible SO Team, from the Africa Bureau as Guidelines for Determining the Arsenic Content of Ground Water in USAID-Sponsored Water Supply Projects in Sub- Saharan Africa. the wells to ensure that the water quality is safe to drink and to establish a baseline against which future monitoring can detect water quality problems. Before water sampling and commissioning, 2 well casing water volumes will be pumped out to remove water contaminated by construction activities. handover. Potability is determined by water quality tests for arsenic and fecal coliform at a minimum (Simple test kits are available for both arsenic and fecal coliform.) Ministry of Water and Sanitation Wells receive daily and rigorous use by the village population and need adherence to use rules agreed by the community and regular maintenance to continue to operate properly. Inappropriate use by people and/or animals causing contaminated runoff into the well head. The basic design consists of a raised apron around a covered well head with a lip, ideally located on a raised dry site. Livestock is watered by means of distant troughs established away from the well head. Community management committee appoints someone to be in charge of opening the well each day and ensuring that the apron is clean and rules for use established in the convention are being respected. Proper use must be something that the community itself enforces because of their mutual interests in continuing to be able to have clean water. Maintenance is a daily task. Community water infrastructure management committee. Ibid Watering livestock Continuous use of these wells for Community agreements on The designated community well Same as above. Community water infrastructure Ibid ENVIRONMENTAL MITIGATION AND MONITORING PLANS 11
at these wells. water local livestock (and perhaps that of other communities) could deplete the water resources and/or lead to degradation of the sites adjacent to the well. water supply and demand must be respected. Livestock milling around the well head waiting for water will degrade the site causing soil compaction, erosion and surface contamination as well as overgrazing. manager should be able to enforce rules about livestock use and staging around the well heads. management committee. Standing water or poor drainage around well heads. Standing water or poor drainage around well heads could lead to an increase in the vectors responsible for water-borne diseases. Careful choice of the site of the well at the outset. Opening drainage channels away from the well head may be necessary to avoid standing water. Local clinic personnel should monitor the site for the presence of conditions suited to water borne disease vector proliferation. Periodically, perhaps every six months or so, depending on the incidence of water borne diseases in the village. Community water infrastructure management committee. Ibid Sanitation Component Building Latrines for Public Places at the Village Level Choosing the sites for public latrines Poorly sited/designed, operated, or maintained sanitary facilities significantly increase the chances of ground and surface water contamination and thus of such disease transmission. Pit latrines located too close to wells could inadvertently Latrines will be built far enough (50 meters minimum) away from shallow wells, cisterns, springs or boreholes. The pits themselves must be dug in the unsaturated soil zone above the water table and will be protected against flooding from seasonal rains Wula Nafaa personnel (Component leader and consultant sanitary engineer) will utilize the USAID ENCAP Visual Field Guide: Sanitation, (see Annex 4 of this EMMP) as a checklist to verify the design and implementation dimensions of this At the outset of the component s activities in each village. Community Sanitation Management and Maintenance committee, in conjunction with the Wula Nafaa component leadership and consultant sanitary engineer. A copy of the Visual Field Guide Sanitation becomes part of the program record, initialed and dated by those reviewing the work. 12 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
drain into the groundwater and contaminate it. or overflow. well building component. This simple checklist will also be translated into French and shared with the Village Committee as a training tool and for their use. Construction of public latrines in the designed villages. Unless properly vented, screened and maintained, latrines can be a source of noxious fumes and odors and insect pests (flies), especially in a semi-urbanized village setting. Wula Nafaa resources will be used to construct VIP (Ventilated Improved Pit) Latrines which are vented with a pipe into the pit that is further protected with a fly screen to avoid contact with insects that could spread disease through contamination with fecal matter. Community Sanitation Management Committee will be organized to clean and maintain these facilities, and monitor their condition. Village users will abide by a code of conduct agreed as part of the Community Convention for these activities, and do their best to properly use these new sanitary facilities. As part of the local convention, Wula Nafaa will suggest a routine maintenance plan for these latrines, including regular cleaning, inspections and trimester sanitation treatments (pouring quicklime in the pit) and whitewashing. Community Sanitation Management and Maintenance committee. Here again, the Visual Field Guide, translated into French, can be used by the Community Sanitation Management and Maintenance Committee to inspect and verify that the system is being properly used and maintained. Risk of fecal contamination from public latrines. A lack of handwashing facilities near each new latrine set can increase the risk of fecal route infection diseases such as cholera. Hand-washing facilities and training for the user community will be an important part of the capacity building associated with this program so as to ensure and facilitate hand Local health clinic personnel will be sensitized to the increased risk of fecal contamination among children and if there is an outbreak, training and monitoring of hand washing will Continuous peer pressure among users to keep the facilities clean and to use them properly including the hand washing facilities. Community Sanitation Management and Maintenance committee. Ibid. ENVIRONMENTAL MITIGATION AND MONITORING PLANS 13
washing after use of the latrine. These hand washing facilities and the training associated with them will receive special emphasis if the new latrines are established as part of the facilities of the village schools where children have a propensity for the fecal contamination route. be reiterated. Component Assistance to the Traditional Gold Mining Sector Introduction: The activities foreseen as part of a Wula Nafaa support program for the traditional gold mining sector in the Kedougou Region of Senegal were not analyzed in detail in the existing IEEs. Therefore, the proposed activities were first scrutinized with a view to establishing a threshold environmental decision for them. The traditional gold mining activities of southeastern Senegal do indeed radically change the landscape but certainly no more so than, for example, small-scale agriculture. Thousands of people in the Kedougou Region depend on small-scale traditional gold mining for their subsistence and indeed survival. Furthermore, although it is very difficult work, the current record high prices for gold suggest that it is highly likely to be continued by this sector of society and that it would be virtually impossible to curtail it as an economic activity in the Region. There is indeed some potential for adverse socioenvironmental impacts and these will need some attention in the course of Wula Nafaa s efforts to support the gold miners and enhance their returns for the enterprise. However, we firmly believe that like so many other environmental issues, the challenge is that of behavioral change to modify the actions of the gold miners and mitigate their adverse impacts on themselves, their families and the environment. Many of the premises of this component are manifest in the local convention that Wula Nafaa will seek to sign with each of the Economic Interest Groups (GIE) it is organizing and which stresses their rights and responsibilities in a legalized gold mining setting. Accordingly, Wula Nafaa has devised the Environmental Mitigation and Monitoring Plan which follows in response to a Negative with Conditions situation. The basic approach, that of organizing and supporting GIE is the only real approach that stands a chance of providing enhanced benefits to the participants and getting them to recognize that their rights to the rational use of the resources base come with responsibilities for sustainable socio-environmental management. Here again, Wula Nafaa commits to implementing this component taking into account the guidance found in the guidance prepared and recommended by USAID in its Environmental Guidelines for Small-Scale Activities in Africa (http://www.encapafrica.org/egssaa.htm) and especially the Chapter 4.5-Small-Scale Mining: Cleaner Production Fact Sheet and Resources Guide (http://www.encapafrica.org/sectors/mining.htm ), which also provides bibliographic information on a wide variety of other reference materials concerned with the small-scale mining sector, including traditional gold mining. 14 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
Activity Possible Adverse Impact Proposed Mitigation Measures Monitoring Indicators Monitoring/ Reporting Frequency Responsible Parties Observations and/or Verification Checklist Establishing GIEs for the Gold Miners and allocating exploitation rights on a given area. Possibility that newly authorized GIE mining areas infringe on sensitive areas (esp. in Kedougou, unique ecosystems such as Chimp habitat) Wula Nafaa working with the leaders of the proposed GIE will verify that the areas being proposed are not close to sensitive areas and incorporate this understanding into the local convention. Prepare a scaled map of the site with GPS and record any indications of special conditions prior to authorization; map serves as record later. At the outset of the proposed activities with candidate groups of gold miners forming a GIE. Wula Nafaa ACF with the elected leaders of the GIE. Map prepared with GPS technology and digital photos becomes part of the file of the activity and the organization (the GIE). GIE become more effective miners and abide by a set of rules for more sustainable mining with the assistance of Wula Nafaa. Long-term usage rights lead to more intensive site disturbance and destruction. Wula Nafaa working with the GIE will devise a plan for reclaiming and restoring the mined over areas at the same time that the resources is being extracted (site organization, planning, filling old holes, etc.). Bi-annual digital photos from specified and marked reference points will be taken to monitor the impact of mining and the restoration of the site. Bi-annually after the rainy season and at the end of the dry season. Wula Nafaa with assistance from its partners and in collaboration with the GIE in question. Wula Nafaa will provide grant resources to a research group to begin a study of the natural regeneration of abandoned traditional mining sites so as to develop a methodology for restoration. Plan should include leaving enough vegetation to prevent wholesale erosion and serve as a source of seeds for natural and/or assisted regeneration with local species. ENVIRONMENTAL MITIGATION AND MONITORING PLANS 15
Provision of enhanced mining equipment. More intensive site disturbance and destruction The premises of the long-term usufruct agreement between the GIE and the Govt. include both rights and responsibilities for the users. They will use the site intensively but stay within its perimeter and agree to restore as they go if possible but certainly before allocation of a new site. The bornage and marking of the perimeter will be monitored to ensure that GIE participants do not stray outside the area designated as their site. A perennial task part of the management agreement for the site authorized by the Government and agreed to by the GIE. Elected leaders of the GIE are responsible for ensuring that the usage rules, including staying within the perimeter are respected. Annual report of the workings of the GIE will report on any problems or issues including members working outside the boundaries of the established mining perimeter. Provision of enhanced mining equipment. Noise, dust, and sedimentation of water courses resulting from the use of the broyeur or the trammel. A newer model of the broyeur is being built that seals in more of the dust. Machine will be used amidst heavy vegetation to trap dust. Participants should use dust masks and ear plugs for protection. Trammel will not be used in the bed of small water courses and will have a small holding pond for used water to capture sediments rather Wula Nafaa will maintain a working relationship with the Ecole Polytechnique and PASMI, at least at the outset, to monitor these issues associated with the introduction of new technology. Leaders of the GIE will ensure machinery is being properly used, that masks, ear plugs and gloves are being used, etc. At the outset of the program and for approximately six months thereafter during the continued testing phase of this equipment. Thereafter, regularly as part of routine management and maintenance of the machinery. Wula Nafaa, PASMI and the Ecole Polytechnique de Kedougou. As part of the agreement with the Ecole Polytechnique, they will prepare technical reports on the operations of this new equipment and how it has been improved. 16 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
than returning the water directly to the water course. Enhanced productivity and greater returns from mining efforts among the members of the GIE. The potential of greater productivity and returns could lead to a need for more labor on the site which will in turn induce child labor. As part of its recognition of the responsibilities that come with the rights to use this site, the GIE will sign a local convention whose bylaws will preclude child labor on the site and also other safety and worker health measures among the participants. In general children are not allowed on these sites. Training and awareness raising activities will be held annually to continue to reinforce the need for positive behavioral change. A perennial task part of the management agreement for the site authorized by the Govt. and agreed to by the GIE. Wula Nafaa, partner or even Government mining personnel will visit these sites periodically and will be vigilant about children on the site and working. This indicator will be a very telling sign as to whether the socioenvironmental compact inherent in the local convention is being respected. Enhanced productivity and greater returns from mining efforts among the members of the GIE. The potential of greater productivity and returns could lead to more use of mercury for gold extraction, and with it greater releases into the environment and more risk to the user community of mercury poisoning. The Wula Nafaa program will introduce more of the simple amalgam treatment pipes for separation of gold and recovery of mercury, and insist on their use. More training and awareness, particularly among women about the dangers of mercury poisoning. Participants will be taught to recognize the symptoms of latent mercury poisoning, Wula Nafaa will work with local medical personnel to recognize, report on, and treat the incidents of mercury poisoning, and maintain records of its occurrence. The potential for adverse impacts from mercury release into the environment and/or cases of mercury poisoning are the greatest risk associated with the traditional gold mining sector in Kedougou, and monitoring of the use of mercury in the gold mining process will be rigorous and continuous so as to reinforce the need for behavioral The NGO La Lumiere will continue to work on awarenessraising and mercury-related training programs for GIE participants. Awareness-raising and training regarding mercury will not be limited to the established GIE groups; elders and women from other traditional gold mining villages will be invited to participate. The Wula Nafaa approach, that of engaging with the resources users, enabling and empowering them and providing support is the only really effective way to address this crucial issue, and with it the potential for developing traditional gold mining into a more sustainable community enterprise. ENVIRONMENTAL MITIGATION AND MONITORING PLANS 17
numbness and tingling of the fingers and hands. Participants will be encouraged to move the gold extraction process out of the family compound, and to use personal protection equipment when preparing amalgam (gloves, aprons, rubber boots). change on the part of the participants. 18 ENVIRONMENTAL MITIGATION AND MONITORING PLANS
ANNEX 1. FICHE D INFORMATIONS DU BUREAU AFRIQUE DE L USAID SUR L ENGRAIS Contexte La faible fertilité des sols est un problème dans la majeure partie de l Afrique au Sud du Sahara (ASS). En outre, la réduction drastique des périodes de jachère ainsi que l emblavement presque continu sans une restauration de la fertilité du sol ont détruit la base nutritive de la plupart des sols. Vers la fin des années 1990, tous les pays de l Afrique au Sud du Sahara affichaient un solde annuel en éléments nutritifs du sol négatif 2. Les pays qui ont le taux de perte d éléments nutritifs le plus élevé sont ceux pour lesquels l utilisation de l engrais est faible et où l érosion du sol est élevé. Parmi ces pays, on peut compter les hauts plateaux de l Afrique de l Est ainsi qu un certain nombre de pays de l Afrique de l Ouest. La faiblesse de la fertilité des sols est aussi un élément moteur de la conversion de certains espaces naturels au profit de l extension des terres agricoles. Il est maintenant généralement admis par tous que l intensification agricole est le seul moyen viable susceptible de préserver les espaces naturels clés tout en augmentant la sécurité alimentaire d une population grandissante sur le continent et en générant une croissance économique par une amélioration de la productivité agricole. La dégradation des sols empêche la capacité des pays à prendre cette direction, et la perte des éléments nutritifs du sol est le facteur qui contribue le plus au processus de dégradation des sols. L utilisation d engrais minéraux joue un rôle important dans la stratégie d arrêt de la dégradation des sols, de la restauration de la fertilité des sols et d une meilleure gestion des ressources du sol indispensables à un développement agricole et économique durable. Engrais et Procédures Environnementales de l USAID (22 CFR 216) On utilise souvent le terme générique de «produits chimiques agricoles» pour désigner à la fois les engrais et les pesticides. D un point de vue de conformité environnementale (22 CFR 216), ainsi que d un point de vue mise en œuvre au niveau du terrain, cela est inexact parce que cela implique qu il faut appliquer le même niveau de précautions aux engrais que celui réservé aux pesticides. Alors que les pesticides sont soumis à une évaluation de leur impact sur l environnement clairement définie [22 CFR 216.3 (b)(1)] et à un processus d approbation pour promouvoir un usage plus sécurisé et une gestion intégrée des pesticides, de telles procédures ne s appliquent pas aux engrais (des procédures d approvisionnement sont cependant appliquées en cas d achat en gros). Cependant, comme c est le cas pour toutes les technologies, on recommande que les engrais soient utilisés avec soin selon les meilleures pratiques, en encourageant une gestion intégrée de la fertilité des sols, dans le cadre des conditions biophysiques et socio-économiques du moment et des résultats recherchés. Cette fiche d informations à pour objet d aider à l atteinte de cet objectif. Importance de la gestion de l eau pour l assimilation des éléments nutritifs Une gestion correcte de l eau est importante pour maximiser l utilisation des éléments nutritifs par les cultures. Environ 97% de l assimilation des éléments nutritifs par les cultures vient de la solution du sol (éléments nutritifs solubles dans l eau), ce qui fait de l eau le milieu de loin le plus important pour l apport des éléments nutritifs ou des engrais. Cela veut également dire que, pour l essentiel, la circulation des éléments nutritifs est liée au mouvement de l eau. Dans les sols sableux, les éléments nutritifs 2 Henao, J. and Baanante, C. 1999. Estimating rates of nutrient depletion in soils of agricultural lands of Africa. Technical Bulletin. IFDC T 48. IFDC, Muscle Shoals, Alabama. 76p. ENVIRONMENTAL MITIGATION AND MONITORING PLANS 19