INTEGRATED SAFEGUARDS DATA SHEET CONCEPT STAGE

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized INTEGRATED SAFEGUARDS DATA SHEET CONCEPT STAGE Date ISDS Prepared/Updated: 13-Dec-2012 I. BASIC INFORMATION A. Basic Project Data Country: Ghana Project ID: P Project Name: GH-GAMA Sanitation and Water Project (P119063) Task Team Ventura Bengoechea Leader: Estimated 04-Mar-2013 Appraisal Date: Managing Unit: AFTU2 Estimated Board Date: Lending Instrument: Report.: ISDSC Apr-2013 Adaptable Program Loan Sector: Sanitation (50%), Water supply (25%), Sub-national government administration (15%), Central government administration (5%), Other so cial services (5%) Theme: Urban services and housing for the poor (85%), Rural services and infrastructure (5%), Infrastructure services for private sector de velopment (5%), Micro, Small and Medium Enterprise support (5%) Financing (In USD Million) Financing Source Amount BORROWER/RECIPIENT 0.00 International Development Association (IDA) Total Environmental A - Full Assessment Category: Is this a Repeater project? B. Project Objectives The objective of the project would be to increase access to safe water and improved sanitation to people in the GAMA, with emphasis on the poor, and to improve operation and management of wastewater facilities. In order to achieve this objective the project would support the expansion and improvement of the water distribution network, the expansion of on-site and sewered sanitation facilities and of community and private water connections, and the improved collection and treatment of wastewater and fecal sludge. Behavior change campaign on hygiene, total sanitation, and safe water will also be promoted through social mobilization activities. C. Project Description

2 The proposed project may be structured as a two-phase Adaptable Program Loan (APL) or as a Specific Investment Loan (SIL) to be followed by other operations, given the long term engagement required to increase access to water and sanitation in low income areas of GAMA and to attain an efficient and sustainable operation and management of the services. The proposed project, whether the first phase of an APL or a SIL, would have the following four components: Component 1 - Provision of water and environmental sanitation services to priority low income areas of the GAMA. The MMAs will propose the priority low income communities to benefit from the project based upon selection criteria to be developed during project preparation and agreed during appraisal. The type of water supply and sanitation facilities will be thoroughly consulted and agreed with each community as to best suit their needs, while taking into consideration particular conditions such as: soil characteristics, topography, space availability, etc. In addition to facilities for households, this component will support the construction of institutional facilities in schools, health centers and in public areas such as markets. This component will also provide support for advocacy and other measures to help enforce current laws and regulations, such as the obligation of landlords to provide sanitation facilities. Additionally, specific measures will be introduced to effectively engage communities and particularly women in decisions relating to the delivery and oversight of water and sanitation services, such as Water and Sanitation Development Boards (WSDBs). This component will also support the establishment and strengthening of social accountability mechanisms so citizens can report on the provision of services. Component 2 Improvement and expansion of the water distribution network in the GAMA. This component will support investments required to improve and expand the existing network in order to provide piped water to the target people living in low income communities in the GAMA. These investments include the installation of transmission mains, booster pumps and any other facilities required to ensure that a share of the additional water production reaches the targeted low income areas. Therefore this component will be coordinated with current and incoming projects supported by other development partners and private investors in the GAMA. This component would also support the acquisition and installation of meters and other equipment, as well as the provision of services, aimed at improving water demand management and reducing non-revenue water. Component 3 Improvement and expansion of wastewater and fecal sludge collection, transportation and treatment in the GAMA. This component will finance collection and/or treatment of wastewater and fecal sludge to be generated from the low income communities and rest of GAMA. However, these facilities will be seized to take care of the entire wastewater flows and sludge volumes generated in the GAMA, which currently end up discharged untreated into drains and the sea. This component will also support the development of solutions to improve the safe collection, transport and disposal of fecal sludge and solid waste. Component 4 Institutional Strengthening. This component will provide technical assistance (TA) to municipal, metropolitan and national institutions, including the promotion of private sector initiatives for water and sanitation. The subcomponents would be further developed during preparation but initially may include: (a) TA to the MMAs, particularly to their Waste Management Departments for: (i) strengthening capacity for the planning of sanitation services with active community participation; (ii) capacity

3 strengthening in oversight and enforcement of sanitation regulations and by-laws; (iii) facilitating interface between households and private sector actors in the expansion of access to on-site sanitation; (iv) hygienic removal and transportation of fecal sludge; and (v) management of wastewater disposal and treatment sites, including delegation to private sector operators. (b) TA to the MLGRD and the RCC of Greater Accra to: (i) strengthen the planning and coordination capacity of the RPCU in the short term; and (ii) support the development of a metropolitan institutional arrangement for integrated planning, implementation, operation and management of sanitation facilities in the long term. The discussion of this integrated institutional arrangement has already begun and will continue during project pr eparation by means of a series of workshops and consultations with key stakeholders. (c) TA to GWCL for the establishment of a pro-poor unit to promote the access of water services to low income areas and the sustainability of those services. This will include strengthening coordination and collaboration with MMAs, NGOs, CBOs, WSDBs add local private sector. (d) TA to the MWRWH to support the institutional restructuring and/or adoption of management options to improve the provision of water supply services in GAMA and other urban areas. (e) Support for the development and training of local private sector to provide sanitation services, especially latrine construction and sludge removal/transport. (f) Carrying out of surveys to establish baselines and evaluate impact of project supported activities in the low income communities and other GAMA areas. D. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The project would be implemented in the Greater Accra Metropolitan Area for the 11 Metropolitan, Municipal and District Assemblies (MMDAs) within the GAMA. E. Borrowers Institutional Capacity for Safeguard Policies At the Ministry's level, the Ministry of Environment, Science and Technology (MEST) has the oversight responsibility for policy directions and implementation on environmental issues. However, the Environmental Protection Agency (EPA) of Ghana is the designated public body for setting environmental standards and ensuring their full compliance. The EPA is considered one of the experienced safeguard institutions in Africa particularly on environmental safeguards and is familiar with World Bank environmental safeguards policies. Although, overall, the EPA is better placed to handle environmental safeguard issues, it would still need capacity building in management and compliance monitoring, especially in involuntary resettlement enforcement since it has traditionally focused on environmental safeguards. For now, no public sector agency has direct oversight on ensuring social safeguards due diligence. Certain aspects such as land and property valuations related to compensation payments have been taken up by the various divisions under the Lands Commission. However, the Commission's overall capacity for safeguards as per the country's national safeguard frameworks and the World Bank's policies is limited. Thus, there will be the need for improving the capacity of relevant project staff at different levels and in different institutions to enable the effective implementation of safeguards measures and monitor outcomes of mitigation measures that may be developed. A key challenge will be the diligent implementation and enforcement of the World Bank's safeguards policies during project realization. Capacities for environmental site supervision, site management and compliance monitoring are often low among contractors and Engineering Consultants, who often see environmental due diligence as marginally important and not as part of overall project quality. Also, practical skills and experience of site personnel from both Contractor and Engineer are often

4 very low, resulting in either circumventing environmental site works and services, or implementing them only partially and with poor quality. This will have to be countered with tight contractual clauses combined with clear descriptions of environmental obligations and services in the TOR / SOW of the tender/contract documents, and introducing payable positions in the BoQ. Moreover, implementation skills will be enhanced by conducting compulsory environmental awareness and diligence trainings for Contractor's and Engineer's staff, both for site management and technical personnel (both skilled and unskilled workers). F. Environmental and Social Safeguards Specialists on the Team Moses Yao Duphey (AFTN3) Beatrix Allah-Mensah (AFTCS) II. SAFEGUARD POLICIES THAT MIGHT APPLY Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ BP 4.01 Yes The project includes large scale civil works such as the construction of water and sewage pipes, pumping stations, waste water and fecal sludge treatment plants, and other water and sewage infrastructure. Most of these works are of a routine nature and do not have large scale, long lasting environmental impacts, or such impacts which would reach beyond the immediate project area. Most impacts would be restricted to the construction phase and can be readily mitigated with available and well-tested, standard techniques and measures. The project's main environmental risk is associated with the construction or expansion of treatment plants for wastewater, sewage and fecal sludge. The key environmental risk associated with the treatment plants is their diligent, long term operation. If not operated diligently treatment plants may turn into polluters of significant scale, negatively affecting ground and surface water quality, spreading waterborne diseases, and causing nuisances to the adjacent population by odors and vectors. The diligent management of treatment plants depends on several factors, such as skilled personnel, a constant stream of sufficient operational budget, simple and robust technology and sufficient long term plant capacities. These are known issues and will be duly

5 considered in project design and the overall operational planning, including technical, financial and organizational robustness. A careful analysis of current and future demand and the resulting required capacities will ensure sufficient dimensioning of the plants, to accommodate the predicted rapid increase of wastewater, sewage and fecal sludge quantities. Currently, since the specific sites are not known, the project will prepare Environmental and Social Management Framework (ESMF) and a framework EMP. The frame work EMP would be specific on the nature of mitigation measures, but generic on the location and dimensions of project activities since these would not be known during project preparation / before appraisal. The ESMF will provide clear guidance for the preparation of site-specific EIAs and EMPs during project implementation when specific environmental and social issues will be analyzed in detail and a comprehensive environmental and social impact assessment (ESIA) developed, as well as ESMPs with a long term operational planning perspective. Natural Habitats OP/BP 4.04 TBD TBD - t likely Forests OP/BP 4.36 TBD TBD - t likely Pest Management OP 4.09 Physical Cultural Resources OP/ BP 4.11 Indigenous Peoples OP/BP 4.10 Involuntary Resettlement OP/BP 4.12 TBD Yes TBD - t likely The project triggers the OP 4.12 as there is likely to be land take due to the expansion and improvement in existing networks for water distribution. The proposed expansion in the sewerage network, the development of new wastewater and fecal sludge, the construction of institutional toilets in schools, public areas and health centers will all require land take which may result in restriction of access and involuntary resettlement. Thus, activities proposed under 3 of the 4 project components will have impacts on land and possible restriction of access and access to assets. Although, the expansion works may take place

6 Safety of Dams OP/BP 4.37 within existing right of Ways (RoWs) for the utilities- Ghana Water Company Limited (GWCL), given the nature of urban settlements, these RoWs may be taken over by people who may not have any legal right to the sites but who may be occupying them for domestic or economic reasons. The project will prepare a Resettlement Policy Framework (RPF) which will be disclosed in country and at the World Bank's InfoShop before appraisal. The preparation of the RPF is proposed due to the fact that, at project preparation, it will not be possible to identify specific sites for any project activity likely to lead to involuntary resettlement. The RPF that will be developed by the Government of Ghana (GoG) will be used to guide the preparation of Resettlement Action Plans (RAPs) or Abbreviated Resettlement Action Plans (ARAPs), where required, after screening of project activities and sites for particular activities are done. RAPs/ARAPs would then be properly reviewed, cleared and disclosed as required. III. Projects on International Waterways OP/BP 7.50 Projects in Disputed Areas OP/BP 7.60 SAFEGUARD PREPARATION PLAN A. Tentative target date for preparing the PAD Stage ISDS: 15-Oct-2012 B. Time frame for launching and completing the safeguard-related studies that may be needed. The specific studies and their timing 1 should be specified in the PAD-stage ISDS: The safeguards related studies will begin after concept review and will be completed and appropriately disclosed by appraisal of the project scheduled for March 4, IV. APPROVALS Task Team Leader: Name: Ventura Bengoechea Approved By: Regional Safeguards Name: Alexandra C. Bezeredi (RSA) Date: 11-Jan-2013 Coordinator: Sector Manager: Name: Alexander E. Bakalian (SM) Date: 14-Dec Reminder: The Bank's Disclosure Policy requires that safeguard-related documents be disclosed before appraisal (i) at the InfoShop and (ii) in country, at publicly accessible locations and in a form and language that are accessible to potentially affected persons.