E4109
Environmental and Social
Management Framework
Local Governance and Service Delivery Project
Republic of South Sudan
DRAFT
Dege Consult
December 2012
ESMF - LGSDP South Sudan
List of Content
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Executive Summary ............................................................................................................ 1
1.1 Introduction ................................................................................................................ 1
1.2 Objective and Scope of Work .................................................................................... 1
1.3 Rationale for Preparing the ESMF ............................................................................. 2
1.4 Policy and Legal Framework ..................................................................................... 2
1.5 ESMF Implementation ............................................................................................... 3
1.6 Capacity Building for ESMF implementation ........................................................... 3
1.7 Environmental and Social Impacts ............................................................................. 3
LGSD and its components................................................................................................... 6
Purpose and methodology ................................................................................................. 10
3.1 Purpose ..................................................................................................................... 10
3.2 Methodology ............................................................................................................ 10
Socio-economic and environmental context ..................................................................... 11
4.1 Socio-economic and cultural setting ........................................................................ 12
4.2 Environment and natural resource setting ................................................................ 13
Regulatory and Administrative framework ....................................................................... 16
5.1 Transitional Constitution .......................................................................................... 16
5.2 Land Act ................................................................................................................... 16
5.3 Draft Environment Policy ........................................................................................ 17
5.4 South Sudan Development Plan ............................................................................... 17
5.5 Existing institutional setup ....................................................................................... 18
Applicable World Bank Safeguard Policies ...................................................................... 19
6.1 OP 4.01 Environmental Assessment ........................................................................ 22
6.2 OP 4.10 Indigenous Peoples..................................................................................... 22
6.3 Chance find of physical cultural resources .............................................................. 23
Potential impacts and mitigating measures ....................................................................... 23
Capacity development ....................................................................................................... 32
8.1 Safeguards staff ........................................................................................................ 32
8.2 Training .................................................................................................................... 32
8.3 Technical assistance ................................................................................................. 37
8.4 Operational support .................................................................................................. 37
Subproject management procedures.................................................................................. 37
9.1 Subproject preparation and application .................................................................... 37
9.2 Screening, appraisal and approval of subprojects .................................................... 38
9.3 Disclosure of subproject information ....................................................................... 38
Environmental Management Plan (EMP) ......................................................................... 38
Chance find of physical cultural resources ....................................................................... 41
ESMF Monitoring, reviews and evaluation ...................................................................... 42
12.1 Monitoring ................................................................................................................ 42
12.2 Reviews .................................................................................................................... 42
12.3 End-of-project evaluation ......................................................................................... 42
ESMF implementation Budget .......................................................................................... 43
Public consultation, disclosure and grievances ................................................................. 43
14.1 Public consultation ................................................................................................... 43
14.2 Disclosure ................................................................................................................. 43
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ESMF - LGSDP South Sudan
14.3 Feedback and Grievance mechanism ....................................................................... 44
Annex A - Literature ............................................................................................................... 45
Annex B - List of people consulted ......................................................................................... 46
Annex C - Checklist for screening of subprojects................................................................... 47
Annex D - List of subproject that are not eligible for funding ................................................ 50
Annex E - Procedures for chance find of physical cultural resources .................................... 51
Annex F - Form for appraisal of subproject ............................................................................ 53
Annex G - Form for field appraisal ......................................................................................... 56
Annex H Format for Documenting Voluntary Land Donation by Individual for Subprojects
58
Annex I - Template safeguards procedures for contracts ........................................................ 59
Annex J - ESMF reporting form ............................................................................................. 62
Annex K - Guidelines for annual reviews ............................................................................... 63
Annex L: Template for Environmental Management Plan (EMP) ......................................... 65
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ESMF - LGSDP South Sudan
Abbreviations
Abbreviation
BDC
CBO
CDC
CDD
CDG
EIA
EMP
ESMF
FP
FTI
GRSS
IDP
LGB
LGSD
MoCYS
M&E
MoE
MoFEP
MoGCSW
NGO
OP
PCSO
PDC
PDG
PMU
RoSS
SSDP
TA
UNDP
UNICEF
USD
WB
Explanation
Boma Development Committee
Community Based Organization
Community Development Committee
Community-Driven Development
County Development Grants
Environmental Impact Assessment
Environmental Management Plan
Environmental and Social Management Framework
Facilitating Partner
Fast Track Initiative
Government of the Republic of South Sudan
Internally Displaced Person
Local Government Board
Local Governance and Service Delivery Project
Ministry of Culture, Youth and Sports
Monitoring and Evaluation
Ministry of Environment
Ministry of Finance and Economic Planning
Ministry of Gender, Child and Social Welfare
Non-Governmental Organization
Operational Policy
Project Coordination and Support Office
Payam Development Committee
Payam Development Grants
Project Management Unit
Republic of South Sudan
South Sudan Development Plan
Technical Assistance
United Nations Development Programme
United Nations Children's Fund
United States Dollar
World Bank
iv
1 Executive Summary
1.1 Introduction
In order to support the Government of the Republic of South Sudan's (GRSS) efforts to
deliver services to the population, the World Bank (WB) and bilateral donors are supporting
the development of the Local Government Service Delivery Project (LGSD). LGSD aims at
supporting improvements in local governance and deliver services to communities through
strengthening of community engagement and local government capacities in planning,
implementation and oversight of local development activities.
The project development objective of the LGSD is to improve local governance and service
delivery in participating counties in South Sudan. LGSD will support a simple process for
planning, implementation and oversight of small-scale public infrastructure subprojects
corresponding to community priorities, through four inter-related components.
a. Component 1: Block Grants to Counties for Payam Development. The objective of
this component is to incentivize citizen engagement and county capacity development
by providing grants (rule-based resources) through the intergovernmental fiscal
transfer system to finance community-driven public infrastructure investments.
b. Component 2: Community Engagement. The objective of this component is to
facilitate and strengthen the engagement of communities in the planning,
implementation and oversight of local development activities, with a particular focus
on vulnerable social groups (including women, elderly, youth, disabled, displaced,
returned, minority ethnic groups etc.) and their access to social and economic
infrastructure.
c. Component 3: Institutional Strengthening. The objective of this component is to
increase the capacity of county governments to fulfill the roles and functions required
to effectively implement the local development investment cycle.
d. Component 4: Project Management Support. This component will support the
management of the project, including technical, financial, procurement, social and
environment safeguards, monitoring and evaluation; spot checks and Annual
Performance Audits of county grant management and individual subprojects as well as
annual Project Financial Audits; implementation of a grant monitoring system, project
monitoring framework and system as well as project evaluations; and implementation
of a grievance mechanism related to all project supported activities.
These components operate in an integrated and complementary manner to strengthen
elements of the annual local public investment management cycle of counties, which
progresses from participatory identification of and allocation of resources to subprojects,
sub-project implementation, reporting and oversight mechanisms. The efficacy of this cycle
is dependent on relationships between three main stakeholders—the county governments,
communities and higher tiers of government.
1.2 Objective and Scope of Work
The objective of this assignment is to assist the Ministry of Finance and Economic Planning
(MoFEP) and the Local Government Board (LGB) in assessing the potential impacts of
ESMF - LGSDP South Sudan
LGSD with respect to the applicable World Bank safeguards policies and to draft an ESMF
with the following objectives:
 To identify the potential positive and negative social and environmental impacts of project
supported subprojects;
 To identify measures for mitigating adverse social and environmental impacts and
measures to enhance positive impacts;
 To establish clear procedures and methodologies for the environmental and social
screening, planning, review, approval and implementation of subprojects to be financed
under LGSD;
 To specify appropriate roles and responsibilities, and outline the necessary reporting
procedures, for managing and monitoring environmental and social concerns related to
subprojects;
 To determine the training, capacity building and technical assistance needed to
successfully implement the provisions of the ESMF;
 To establish the project funding required to implement the ESMF; and
 To provide practical resources for implementing the ESMF.
The ESMF was developed based on an extensive literature review, as well as discussions and
interviews with key resource persons working for GRSS ministries and donors. Discussions
were also held with the civil society representatives and more consultations with community
representatives are scheduled and will inform finalization of the ESMF.
1.3 Rationale for Preparing the ESMF
It is anticipated that the proposed subproject activities under LGSD will generate potential
environmental and social impacts, and measures need to be put in place in order to mitigate
the negative impacts and enhance the positive impacts. This involved the review of the
relevant environmental and social policies of RoSS namely the draft Environment Policy and
draft Environmental Bill, the Land Act 2009 and the relevant World Bank Safeguards Policies
including the environmental and social management requirements outlined in the
Environmental Assessment policy (OP.4.01). LGSD activities will generate small, reversible
and localized impacts, and since the specific activities and exact locations are not known, the
indicative list of subprojects was used to identify the likely positive and negative
environmental and social impacts. The ESMF, as a safeguard instrument, has been prepared to
identify, analyze and mitigate any potential impacts of the project.
1.4 Policy and Legal Framework
Only a limited number of RoSS policies and legislations have been developed since
independence. The main ones of relevance to environmental and social safeguard measures
are the Transitional Constitution, the 2009 Land Act, the National Development Plan, the
draft Environmental Policy and draft Environmental Bill.
OP 4.01 World Bank (WB) Operational Policy on Environmental Assessment and
Operational Policy 4.10 on indigenous people are triggered by the LGSD. Several
subprojects to be financed under Component 1 will have positive environmental and social
impacts. Others could potentially result in adverse impacts on the environment. However,
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ESMF - LGSDP South Sudan
given the anticipated small scale of the subprojects, the negative environmental impacts are
likely to be localized, temporary, and easily mitigated through sensible construction
management techniques, and diligent management practices. This ESMF therefore helps the
project comply with the OP 4.01 World Bank. OP 4.11 on Physical Cultural Resources is not
triggered. Any project activity that would affect physical cultural resources (graves, sites of
religious/spiritual significance, known or unknown sites of cultural significance, etc.) will be
excluded from the project.
OP 4.10 on Indigenous Peoples is triggered. Analysis by Bank and other experts confirms
that the majority or all people in the project area meet the requirements of the policy. As
Indigenous Peoples are the sole or the overwhelming majority of direct project beneficiaries
in South Sudan and the elements of an Indigenous Peoples Plan (IPP) have been incorporated
into the overall project design. OP 4.12 on Involuntary Resettlement is not triggered as no
land acquisition will be required for subproject implementation. Any subproject requiring
land acquisition will be excluded. The ESMF provides a format for recording voluntary
community donations of land for subprojects.
1.5 ESMF Implementation
The capacity for implementation of the environmental and social management measures as
laid out in the Laws and Policies is very limited across the five administrative units, namely National, State, County, Payam and Boma. The existing capacity of the implementing
institutions - MoFEP, LGB, state Ministries of Local Government and Ministries of Finance,
and participating counties- to implement the ESMF and other environmental and social
safeguard instruments is very limited. However, checklists for screening; formats for
preparation, appraisal and approval of LGSD subprojects along with a format for
Environmental Management Plan (EMP) as well as procedures for public disclosure and
addressing grievances are included in the ESMF.
1.6 Capacity Building for ESMF implementation
The project has provided for capacity building and technical support to MoFEP, LGB, PMU,
FPs, state ministries of Local Government and Ministries of Finance, and county level
institutions in environmental and social safeguards management including implementing and
monitoring to increase their effectiveness. A senior safeguards specialist and safeguards
officer at the national PMU will oversee safeguards implementation in LGSD; liaise with
National and State Environmental Ministries on a regular basis; ensure compliance with
ESMF and other safeguard instruments; build capacity and troubleshoot for the state and
county level focal points; prepare and implement EMP and other instruments as required; and
raise awareness and build capacity of various stakeholders at the state, county and payam
levels. Earmarked budget of USD 86,000 will support capacity development of these focal
points..
1.7 Environmental and Social Impacts
Based on the indicative list of subprojects, consultations and professional judgment, the
following are the indicative list of positive and negative social and environmental impacts.
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ESMF - LGSDP South Sudan
The identified key positive environmental and social impacts include:
 Increased employment opportunities (laborers, guards etc. during construction)
 Increased employment opportunities (guards and small-scale craftsmen: plumbers,
carpenters etc. during use and maintenance)
 Increased income (improved market access, increased agricultural production)
 Improved access to basic social services (e.g. education, health care, water, etc)
 Improved health
 Improved aesthetics due to more environmentally friendly construction.
 Improved capacity of state and county focal points due to on-the-job training in
environmental and social assessment.
 Improved capacity of MoE to handle chance find of physical cultural resources.
The ESMF has also identified the following key potential negative environmental and social
impacts during construction and use and maintenance of subproject facilities:
 Loss of vegetation cover causing erosion of soil and siltation of streams
 Dumping of construction debris
 Use of limited or sensitively located local construction materials such as aggregate and
wood
 Dust and noise pollution due to movement of equipment, digging
 Pollution of surface and ground water due to oil and fuel spills and exposure of ground
water table
 Chance find of physical cultural resources
 Health hazards due to inadequate cleaning and maintenance of latrines
 Stagnant water causing health hazards
 Health hazards caused by inadequate storage and disposal of medical and other wastes
 Pollution of soil and water resources due to inappropriate collection and disposal of refuse
and waste
 Change of water flow causing water shortage, change of water course, etc. downstream
 Safety concerns due to speeding vehicles
 Lowering of water table
Mitigation measures identified for key adverse environmental and social impacts of the
subprojects that relate to construction and/or rehabilitation of physical structures are presented
below.
Subproject
Environmental
impacts
Potential negative impact
 Loss of vegetation cover causing erosion
of soil and siltation of streams
Mitigating measures
 Cutting of vegetation to be kept at a
minimum, replanting around construction
 Application of appropriate erosionprotection measures, in particular when
working on slopes
 Works adjacent to a water resource require
temporary barriers on slopes to prevent silt
from entering the water resource
 Dumping of construction debris
 Disposal of construction debris should occur
at waste dumps
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ESMF - LGSDP South Sudan
Subproject
Social Impacts
Potential negative impact
Mitigating measures
 Use of limited or sensitively located local  Ensure aggregate is only obtained from
construction materials such as aggregate
locations with no risk of river bank collapse,
and wood
landslides, loss of flora and fauna, etc.
 Minimize the use of wood for construction
 Dust pollution due to movement of
 Prevention of excessive dust emissions
equipment, digging
including cement dust by careful handling
and working under moist conditions as much
as possible
 Noise pollution due to use of equipment  Use of noisy equipment should be
concentrated during day-light hours
 Pollution of ground water due to oil and
 All solid waste, fuels or oils should be
fuel spills and exposure of ground water
collected
table
 Ensure the presence of oils spill containment
at the construction site
 The bottom of the pit is at least 1.5 m above
the water table
 Latrines should be located at least 30 m
from any water source
 Occupational health and safety due to
 The contractor should protect workers by
hazards from handling of equipment
ensuring the use of protective equipment
 Chance find of physical cultural resources  Follow procedures in chapter 11 for chance
find of physical cultural resources
 Stemming of water flow during
 Leave some channels to allow for continued
construction of bridges causing water
flow downstream.
shortage, change of water course, etc.
 Design bridge to ensure minimum changes
downstream
in water flow
 Health hazards due to inadequate cleaning  Maintenance plans for school latrines must
and maintenance of latrines
be developed
 Health hazard due to stagnant water at
 All water facilities must have proper
water points acting as breeding ground for
drainage
malaria carrying mosquitoes and other
vector-borne diseases
 Health hazards caused by inadequate
 Provide collection and disposal system for
storage and disposal of medical and other
medical or others wastes, e.g. incinerators or
wastes
transfer to special dump sites
 Safety hazards due to collapsing latrine
 Latrine design standards must be adhered to
pits
 Safety concerns due to speeding vehicles  Provide speed control bumps where road is
close to community to avoid accidents and
dust and noise pollution
 Interference with culturally sensitive sites,  Avoid siting haffirs/boreholes or other water
graveyards, spiritual sites
supply structures or any infrastructure even
if it involves changing the dimensions and
sizes
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ESMF - LGSDP South Sudan
2 LGSD and its components
LGSD aims to support improvements in local governance and service delivery by
strengthening community engagement and local government capacities in the planning,
implementation and oversight of local development activities. The project responds to the
unique imperatives in South Sudan—the need to deliver early benefits to communities in the
context of weak government capacity while at the same time strengthening government
institutions and legitimacy—by combining features of traditional local government and
community-driven development operations.
The project development objective of the LGSD is to improve local governance and service
delivery in participating counties in South Sudan. LGSD will support a simple process for the
planning, implementation and oversight of small-scale public infrastructure subprojects
corresponding to community priorities, through four inter-related components. These
components operate in an integrated and complementary manner to strengthen elements of the
annual local public investment management cycle of counties, which progresses from
participatory identification of and allocation of resources to subprojects, sub-project
implementation, reporting and oversight mechanisms. The efficacy of this cycle is dependent
on relationships between three main stakeholders - the county governments, communities and
higher tiers of government.
Component 1: Block grants to counties for payam development. The objective of this
component is to incentivize citizen engagement and county capacity development by
providing grants (rule-based resources) through the intergovernmental fiscal transfer system
to finance community-driven public infrastructure investments. Therefore the project will
support Payam Development Grant (PDG), which will complement the existing CDG (funded
by the GRSS budget and focusing on county government prioritized infrastructure
investment). The PDG will provide dedicated resources within county budgets that respond to
payam level priorities for small infrastructure investments. Counties will be the formal
budgeting, procurement and accounting authority for the PDG. County eligibility for the PDG
will require signature of a Participation Agreement, adequate reporting of prior grant use, and
a ‘clean’ audit report for the prior budget year. Allocations to participating counties will be
made on an annual basis through a population weighted formula from a national resource
envelope. By establishing clear criteria for eligibility of both counties (based on
administrative rigor and engagement with communities) and subprojects (based on their
responsiveness to community demand), the PDG will also contribute to institutionalizing
precedents for sound and responsive county management of the CDG and other resources.
An overview of the allocation of PDG, fund flow and reporting and oversight arrangements is
included in figure 2.1 below.
Figure 2.1: PDG allocation, fund flow, reporting and oversight arrangements
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ESMF - LGSDP South Sudan
The PDG menu includes mainly public goods such as social and economic infrastructure; it
may also include ‘club goods’ benefiting local associations where justified.1 In order to ensure
recurrent budget coverage, improvements to existing schools and health facilities may be
funded with the PDG, but unstaffed new facilities will not be eligible. Facilities with essential
staff that are currently being run from temporary or substandard structures will be eligible.
County governments will be permitted to reserve a maximum of US$5,000 from their annual
PDG allocation to cover their own administrative and logistical expenses related to grant
planning, management and monitoring. Counties will be responsible for implementing and
reporting on PDG financed subprojects, and will be supported to do so under Component 3.
Component 2: Community engagement. The objective of this component is to facilitate and
strengthen the engagement of communities in the planning, implementation and oversight of
local development activities, with a particular focus on vulnerable social groups (including
women, elderly, youth, disabled, displaced, returned, minority ethnic groups etc.) and their
access to social and economic infrastructure.
1
Eligibility criteria for club goods (i.e. semi-public collective assets) will be the number of beneficiary
households (at least 15-20), nature and equity of resulting benefits, contribution of the investment to enhancing
returns from ongoing social or economic activities, and a clear consensus and prioritization during the Boma and
Payam planning process.
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ESMF - LGSDP South Sudan
Activities supported under this component will include: (a) a carefully designed
communication campaign to disseminate the key features of the project and the processes to
ensure citizen voice and oversight as well as government accountability; (b) a social and
conflict analysis to map the social, ethnic and demographic composition of bomas and
payams, leadership structures and inter as well as intra-community tensions; (c) a facilitated
inclusive process to establish representative BDCs and PDCs consistent with the
government’s Participatory Planning and Budgeting Guide for Local Governments in
Southern Sudan2; (d) a facilitated planning process involving BDCs, PDCs and government
representatives to identify priority infrastructure investments for financing under the annual
grant envelope, and to determine the selection and phasing of subprojects for subsequent
years; (e) the participation of communities in the management and oversight of local public
infrastructure investments to ensure that they are used in accordance with agreed plans, that
infrastructure and service delivery meet established standards, and that access to benefits
corresponds to agreed development plans; and (f) a feedback and grievance mechanism
established to provide multiple channels and modalities to enable community members,
especially those from vulnerable groups, to ensure the integrity and responsiveness of
decision-making and resource management by PDCs, FPs, and county and project staff.
County Legislative Council
PLANNING UNIT
Planning Officer
SECTOR DEPARTMENTS
Education, Health, Agriculture,
Social Development, Public
Works (County Engineer)
GENERAL ADMINISTRATION
Commissioner
Executive Director
C
O
U
N
T
Y
FINANCE UNIT
County Accountant
Procurement Officer
Payam
Payam
Development
Committee
Payam
Administrato
r
Boma
Development
Committee
Subproject Management
Team/Subproject Supervision Team
Boma
Development
Committee
Boma
Boma
Development
Committee
Village
P
A
Y
A
M
B
O
M
A
Village
Village
Village
Through this facilitated local planning and prioritization process, communities will take into
consideration: available resources and service deficits at the boma and payam levels; the
particular needs of women, youth and vulnerable groups; the drivers and manifestations of
2
Membership guidelines that require representatives of women, youth, elders and special groups (disabled,
displaced, returnees as applicable) in addition to the traditional Chiefs, will be followed.
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ESMF - LGSDP South Sudan
local conflict; and the potential for subprojects to promote greater equity or mitigate potential
conflict. The payam planning process and resulting Payam Action Plan will also feed into the
County Development Plan, which in turn would provide the framework for activities by state
government and by non-governmental actors and other donor agencies operating in a
particular county so that their activities support the implementation of priority initiatives at
the level of both the county and the payams.
Component 3: Institutional Strengthening. The objective of this component is to increase
the capacity of county governments to fulfill the roles and functions required to effectively
implement the local development investment cycle. This component thus operates in
conjunction with the provision of PDG resources in Component 1, and community
engagement activities in Component 2. Institutional strengthening of county governments,
and of state governments in their roles to support and supervise them, will contribute to
improving local governance and thus ‘building the state from below.’ Training will prioritize
PDG recipient counties, although within resource constraints staff from other counties may be
eligible to participate. Priority areas for LGSD institutional strengthening include those
capacities supporting a responsive, effective and transparent local development investment
cycle, focusing on the following dimensions: (i) participatory local development planning and
budgeting; (ii) financial management; (iii) procurement; (iv) technical (engineering) aspects
of local infrastructure planning and implementation; (v) monitoring and reporting; (vi)
environmental and social safeguards; (vii) social accountability; and (viii) communication and
information dissemination.
Component 4: Project Management Support. This component will support: (a) the
management of the project, including technical, financial, procurement, social and
environment safeguards, monitoring and evaluation; (b) spot checks and annual County
Performance Audits of county grant management and individual subprojects as well as annual
Project Financial Audits; (c) implementation of a grant monitoring system, project monitoring
framework and system as well as project evaluations based on data collection at initiation,
mid-term and completion; and (d) implementation, in collaboration with the CA, of a
grievance mechanism related to all project supported activities. Recognizing that various
elements of the project (grant allocation and access, planning and budgeting, procurement,
institutional strengthening, and the application of safeguards, social accountability and
communication/information dissemination) could elicit feedback from participants or become
a focus for local disputes, the feedback and grievance mechanism will be integrated into the
design of each component, and described fully in the Operations Manual.
The Key institutional actors with respect to the implementation of the LGSD include:
a) MoFEP and LGB at national level and Ministries of Finance and Local Government at
state level, which will have overall responsibility for project implementation;
b) The National Project Management Unit (PMU) and state-level Project Coordination
and Support Offices (PCSOs) that will provide support to national and state
government in core project management and fiduciary functions, primarily financial
management, procurement, environmental and social safeguards, and monitoring and
evaluation;
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ESMF - LGSDP South Sudan
c) Technical Assistance (TA) through a competitive tendering process to provide
technical support to counties in the areas of local development planning, financial
management, procurement and small infrastructure engineering; and
d) NGO FPs that will provide facilitation support to communities to ensure that they can
effectively engage in the planning, implementation and oversight of local development
activities.
3 Purpose and methodology
3.1 Purpose
The purpose of this assignment is to assist the Ministry of Finance and Economic Planning
(MoFEP) and the Local Government Board (LGB) in assessing the potential impacts of
LGSD with respect to the applicable World Bank safeguards policies and to draft an ESMF
with the following objectives:
 To identify the potential positive and negative social and environmental impacts of
project supported activities, subprojects;
 To identify measures for mitigating adverse, and enhancing the positive social and
environmental impacts;
 To establish clear procedures and methodologies for the environmental and social
screening, planning, review, approval and implementation of subprojects to be
financed under the Project;
 To specify appropriate roles and responsibilities, and outline the necessary
reporting procedures, for managing and monitoring environmental and social
concerns related to subprojects;
 To determine the training, capacity building and technical assistance needed to
successfully implement the provisions of the ESMF;
 To establish the project funding required to implement the ESMF requirements;
and
 To provide practical resources for implementing the ESMF
3.2 Methodology
The ESMF is primarily based on an extensive literature review as well as discussions and
interviews with key resource persons working for donor agencies and government ministries.
The literature review provided information on the existing environmental and social context
of the RoSS. Furthermore, the review of relevant GRSS policies and laws, WB safeguard
policies, and the Bank’s Appraisal Document for LGSD, provided the background to
identification of potential environmental and social impacts. A list of relevant literature is
included in Annex A and a list of people consulted is included in Annex B.
Interviews with key resource persons, especially the staff from relevant GRSS ministries,
NGOs, UNDP, UNICEF as well as deliberations during workshops held in conjunction with
the WB Technical Mission, which took place from 22nd October to 2nd November in Juba,
provided additional information and qualified the literature review.
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ESMF - LGSDP South Sudan
More consultations with community representatives are scheduled and will inform finalization
of the ESMF.
Based on the potential adverse environmental and social impacts of the LGSD subprojects a
list of mitigating measures has been developed along with procedures for screening of these
subprojects. The potential positive social and environmental impacts have also been identified
with measures to enhance them. Finally, based on the above, the training and assistance
required ensuring appropriate screening, mitigation and follow-up on implementation is
included in this document.
4 Socio-economic and environmental context
RoSS is located in the Nile catchment area, bordering 6 countries: Sudan, Ethiopia, Kenya,
Uganda, Democratic Republic of Congo, and the Central African Republic. RoSS covers over
644,000 km2 with altitudes varying between 600 and 3,000 m above sea level, the lowest
point found in the extreme north of Upper Nile and the highest in the mountains of eastern
Equatoria. A map of RoSS is included below.
Map 5.1: Map of the Republic of South Sudan
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ESMF - LGSDP South Sudan
4.1 Socio-economic and cultural setting
RoSS has approximately 8 to 10 million people3, half of which are below 18 years old and 83
% live in the rural areas with an overall life expectancy of 42 years4. The average household
size is 7. RoSS is expected to be very close to the bottom of the HDI list5. There are
approximately 164,000 IDPs and 200,000 refugees in RoSS.4
RoSS has been marginalized during decades of rule by North Sudan, and indicators for basic
social services paint a dire picture of the present situation. Half of the population of RoSS
lives for less than 1.25 USD /day with 1.6 million people depending on food aid. The poverty,
however, is not equally spread with some states having more people below the poverty lines.
Poorest is Northern Bahr-El-Ghazal (NBG) with 76 % of the population living below the
poverty line; the population of Upper Nile is relatively better off with only 26 % living below
the poverty line.4
The under-five mortality rate is 135/1,000 live births, and the maternal mortality rate is 2,054
per 100,000 live births - one of the highest in the world. Only one in four of adults are
literate.4 Other basic indicators are included in table 4.1 below.
Table 4.1: Basic indicators4 and 6
Indicator
Poverty line
Proportion of population living in poverty
Poverty and
human
development
Health
HIV/AIDS
Education
Food Security
and Nutrition
Water,
sanitation and
hygiene
Average monthly consumption per capita
Proportion of households that used cash in the previous 7 days
Proportion of households that own a phone (urban, rural)
Youth aged 15-24 with comprehensive knowledge about
HIV/AIDS
Infant mortality (per 1,000 live births)
Under-five mortality (per 1,000 live births)
Maternal mortality (per 100,000 live births)
Estimate of HIV/AIDS prevalence among adults aged 15-49
Literacy rate above age 15 years (m, f)
Net enrolment rate, primary (m, f)
Average promotion rate, all primary grades
Primary school pupils per classroom
Proportion of arable land cultivated
Children under five severely or moderately underweight
Access to an improved water source (urban, rural)
Access to improved sanitation (urban, rural)
Proportion of households using sanitary means of excreta
disposal
Most recent data
$26 per month
51%
$33 (79% spent on
food)
53%
15% (59%, 8%)
11%
84
135
2,054
3.1%
27% (40%, 16%)
44% (51%, 37%)
64%
134
4%
30%
55% (67%, 53%)
20% (53%, 13%)
15%
3
According to the 2008 census it was 8.2 million, which was being criticised by some for not including all.
Considering that approximately 2 million IDPs and refugees have returned, the number could now exceed 10
million.
4
"South Sudan 2012 Consolidated Appeal-Mid Year Review", UN, 2012
5
The whole of Sudan ranked 154 in the 2011 Human Development Report.
6
"UN & Partners Work Plan 2011 Mid-Year Review", UN, 2011
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ESMF - LGSDP South Sudan
4.1.1 Conflict
There are numerous on-going and dormant conflicts in RoSS. Some of them arise from
tensions over the use of shared natural resources. Environmental issues such as
desertification, land degradation, and climate change are becoming factors in these conflicts,
both as causes and results. For example, the overlap of rangeland with land for cultivation is a
major source of conflict, especially when overstocking increases rangeland’s vulnerability to
degradation.
Four main categories of natural resources linked to conflict are oil and gas reserves, water,
timber, and land. Over the past decades, conflicts have increased among pastoral groups and
host communities. And there is the potential for growing inter-community conflicts due to
growing competition for land as a result of land degradation, displacement of pastoralists and
population growth among cattle herders and farmers, increased cattle raiding among
pastoralists in some of the states, and reduced food security and water availability due to
rainfall variability and extended and recurrent droughts.
4.1.2 Pollution
The industrial sector in RoSS is limited with industries typically being small-scale workshops
for wood processing and metalworking and a number of water purification companies. Largescale industrial activities are anticipated to increase in the future.
Pollution of water sources is increasing due to urbanization with waste water from
households, slaughter houses, hospitals, etc, that has been discharged directly into the
environment leading to pollution of soil, water and air.
4.1.3 Environmental health
The majority of the population lives with inadequate access to safe water and sanitation
facilities. Inappropriate waste management systems mean that they are exposed to health
risks. Limited access to safe water and inadequate sanitation coupled with inappropriate
hygiene behaviors is a major cause of diarrhea and other water-borne diseases contributing to
the high child mortality rate.
Waste management is mainly a problem in areas with high population density, especially
towns. Uncontrolled and open waste dumpsites promote vectors, flies, rodents, pathogens and
nasty odors. Insufficient management of waste from health facilities might cause health risks
due to unsafe disposal of medical wastes.
4.2 Environment and natural resource setting
4.2.1 Climate
Overall the climate of RoSS is tropical with wet (April to December) and dry seasons with
annual rainfall varying between 200 mm in Eastern Equatoria to 1,200-2,200 mm in the forest
zone in Western Equatoria and 700-1,300 mm in the northern states. The rainy season causes
seasonal flooding of floodplains. The mean temperatures are between 26 and 32 ºC.
A report from FEWSNET concludes that the climate in Southern Sudan is changing quite
drastically: summer rains have declined by 10-20 % and temperatures have increased by more
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ESMF - LGSDP South Sudan
than 1 ºC since the 1970s. Roughly speaking, the productive rain fed crop area is shrinking
from the north and from the east, leaving the people in Kordofan, Upper Nile, Jonglei and
Eastern Equatoria states more food insecure - if present trends continue people of NBG,
Warrap, Unity and Central Equatoria states will also increasingly be affected by climate
changes.
Climate changes can, besides its direct impact on food production, also lead to increased
conflicts over scarce resources: pastoralists are forced to move to where there is pasture and
water, often leading to conflicts with other groups of pastoralists or with farmers. It is not
known how climate changes will affect the Nile.
4.2.2 Oil and minerals
Oil exploration is carried out mainly in the states of Jonglei, Lakes and Upper Nile with
potential significant negative impacts on the livelihoods of the local communities and the
environment, including land degradation and water contamination; dumping of hazardous
materials, human wastes, and solid wastes; disruption or relocation of human communities
and habitat loss.
There is believed to be substantial minerals in RoSS, including gold, copper and iron. Most of
the minerals are still to be explored and unless handled carefully has the potential to adversely
affect the environment.
4.2.3 Land resources
Land ownership in RoSS can be divided into three categories: customary, private and public.
For details of each category, please refer to table 4.2 below.
Table 4.2: Categories of land ownership7
Ownership
Characteristics
 Covers most of rural areas.
 Is used for residences, agricultural, forestry, and grazing.
 May be granted for life to the landholder and are inheritable.
Customary  Can be subject to usufruct rights and sharecropper agreements but cannot be alienated.
 Allocated by traditional authorities subject to pre-notification of local government
authorities and pre-approval of local government authorities for non-residential land over
250 feddans (about 105 hectares)
Private
 Held in perpetuity and includes the right to transfer and dispose of the land.
 Land pertaining to the State, including roads and other public transportation thoroughfares;
watercourses over which community ownership cannot be established; and forest and
Public
wildlife areas formally labelled as national reserves or parks.
 By default, land over which no private ownership including customary ownership is
established is declared public.
Although land in general is readily available, land ownership are not always clear with
powerful individuals claiming private ownership of community land.
Source: “South Sudan Food Security and Land Governance Fact Sheet”, LANDac – The IS
academy on land governance, compiled by the Royal Tropical Institute (www.landgovernance.org), 2012
7
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Erosion of land, particularly on sloping areas with poor vegetation cover is a serious problem
that is worsened by cultivation, over-grazing, and land clearing. Erosion can cause loss of soil
quality and siltation of water resources.
4.2.4 Water resources and wetlands
RoSS lies within the watershed of the Nile and has both ground and surface water. The
surface water is found in lakes and rivers, most notably the Nile. Pollution, construction of
dams, irrigation and other diversions of water can affect downstream ecosystems, depriving
people of their livelihood and destroy habitats.
The main wetlands of RoSS are the Sudd and Machar. The Sudd wetlands are designated as a
Ramsar Site. Three protected areas, the Shambe National Park, Zeraf and Fanyikang Game
Reserves are located in the Sudd wetlands. The Sudd wetlands are threatened with pollution
as a result of drainage for agricultural production, brick making and industrial expansion and
oil exploration.
4.2.5 Livestock
Despite the cultural and economic importance of livestock in RoSS the number of livestock is
not known. Livestock keeping depends on rangelands that are being degraded by recurrent
droughts and depletion of forests for fuel wood, construction and charcoal production.
Livestock grazing can result in degradation of land through overgrazing of rangelands that
reduces the vegetation cover and the production of organic matter, in turn increasing wind and
water erosion, and thus decreasing soil fertility and leads to desertification especially of semiarid and arid lands.
4.2.6 Agriculture
It is estimated that 90% of the total area of RoSS is suitable for agriculture, but that only 2%
is used for agricultural production. Agriculture remains largely traditional, limiting
households to cultivate an average of less than 1.5 ha. Agriculture is predominantly rain-fed
with main crops being maize, sorghum, finger millet, cassava, sweet potato, and groundnuts.
Despite the agricultural production potentials, especially in the green belt in the southern part
of the country, a large proportion of the population of RoSS is food insecure. Increased rainfed and irrigated agriculture could produce food for local consumption and export.
Agricultural production might affect the environment negatively through contamination from
pesticides and fertilizers and might reduce the diversity of flora and fauna. Soil erosion and
silting of surface water sources is also a potential consequence of increased agricultural
production.
4.2.7 Forest and woodland resources
Forest and woodlands cover approximately 30 % of RoSS. Cutting of trees for fuel, charcoal
production and construction as well as clearance for grazing and urbanization is causing
deforestation which might lead to soil erosion, habitat loss and changes in water flows. Illegal
and uncontrolled exploitation of forest resources contributes to this.
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ESMF - LGSDP South Sudan
Wild fires, overgrazing and over-cutting during successive wars with low and declining
productivity, have degraded the forests and woodlands. The vast majority of South Sudanese
depend on firewood or charcoal as their main source of energy, resulting in substantial cutting
of trees.
4.2.8 Fisheries
Lakes, wetlands, the Nile and other rivers not only sources of livelihood of a large proportion
of the population of RoSS but also an important source of food. There is a risk that the current
unregulated fishing compounded by pollution and siltation is not sustainable and could
eventually lead to a decline in fish productivity.
5 Regulatory and Administrative framework
Only a limited number of national policies and legislation have been developed by GRSS with
others being in the drafting and approval stages, most of which remains confidential and not
available for review. The main available relevant documents are the Transitional Constitution,
the 2009 Land Act, the draft Environment Policy and the National Development Plan.
5.1 Transitional Constitution
The supreme law of RoSS is the 2011 Transitional Constitution of the Republic of South
Sudan. The constitution states that all levels of GRSS shall "protect and ensure the sustainable
management and utilization of natural resources including land, water, petroleum, minerals,
fauna and flora for the benefit of the people" and shall "protect cultural heritage, monuments
and places of national, historic or religious importance from destruction, desecration,
unlawful removal or illegal export".
With regards to the environment, the constitution specifies that every person has the right to
live in a clean and healthy environment and that the environment shall be protected for future
generations; more specifically, the environment shall be protected from pollution and
degradation, and ecologically sustainable development and use of natural resources must be
ensured. The constitution also states that it is the duty of citizens to protect the environment
and preserve natural resources, and that communities must be involved in the use of natural
resources.
5.2 Land Act
The Land Act from 2009 is important for the sustainable management of land in South Sudan.
The purpose of the act is to regulate land tenure and protect rights to land in RoSS while
creating an enabling environment for economic development of land and natural resources.
The Land Act classifies land into public land, community land and private land. Public land is
owned collectively by the people of RoSS and is held in trust by GRSS. Community land is
owned by communities if it is registered, used or managed by communities.
The Land Act states that traditional leaders may grant customary rights for residential,
agricultural and grazing purposes provided the relevant authorities are notified.
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ESMF - LGSDP South Sudan
The Act contains provisions on protection of access to communal grazing land and water
points on communal grazing land.
Prior to any decision related to lands - whether in urban or rural areas - the land
administration shall consult with the communities concerned and land used for investment
purposes shall be subject to social, economic and environmental assessment.
Land can be appropriated by GRSS if the land is to be used for public purposes, including for
government premises, sanitary improvements, urban development, and roads construction.
The owner has the right to just and equitable compensation. Persons who lost their rights to
land due to displacement caused by the war also have the right to compensation.
5.3 Draft Environment Policy
An Environment Policy was drafted in 2010, and an Environment Bill, also drafted in 2010, is
to be presented to the Council of Ministers shortly. The draft Environment Policy will provide
guidance for sustainable management of the environment in view of anticipated developments
especially with regards to oil exploration, housing, roads, deforestation, pollution, resource
related conflicts, and overuse of fish resources.
The draft policy recognizes the limitations posed by inadequate institutional capacity and
limited budget allocations for environmental protection. The draft policy also recognizes the
need for decentralization and devolution of environmental management to the lowest levels of
government.
For implementation of the policy, a number of instruments are to be developed, including
development of an institutional framework, creation of environmental awareness, procedures
for environmental assessments and audits, and establishment of standards. For more details of
the envisioned institutional setup, please refer to section 5.5 below.
5.4 South Sudan Development Plan
The 2011 South Sudan Development Plan (SSDP) is the roadmap for the future development
of RoSS. The objective of the SSDP is "To ensure that by 2014 South Sudan is a united and
peaceful new nation, building strong foundations for good governance, economic prosperity
and enhanced quality of life for all." This is to be achieved through improved governance,
rapid improvement of livelihoods and expansion of employment opportunities, improvement
and expansion of education and health services, and by deepening peace and improving
security.
The focus of SSDP is on building the strong institutions required to promote a transparent and
accountable state and improving capacity at all levels of government. The plan also
emphasizes the importance of promoting private sector-led economic growth and the delivery
of basic services in reducing the incidence of poverty among the population. However, it also
recognizes that these actions can only be successful in the long run by maintaining relative
peace and security. The Economic Pillar of the SSDP includes improvements of roads while
the Social and Human Development Pillar includes health and sanitation facilities.
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ESMF - LGSDP South Sudan
SSDP identifies seven crosscutting issues as important, including environment and equality.
The SSDP recognizes the protection of the environment as a key policy and will address it in
legislation and policy development, and environmental impact assessments will be taken into
account. Natural resources are recognized as crucial to the economic development and are to
be used in an environmentally sustainable manner.
5.5 Existing institutional setup
GRSS has five administrative units: national, state, county, payam and boma. At national and
state level sectoral ministries are established and at county, payam and boma level there are
administrations with units for the various sectors. GRSS at present has 29 ministries of which
the most important with regards to environmental and social safeguards of the LGSD are the
Ministry of Environment (MoE); the Ministry of Gender, Child and Social Welfare
(MoGCSW); and the Ministry of Culture, Youth and Sports (MoCYS).
At present MoE, including the Directorate of Environment has approximately 30 staff at
national level (Juba) whereas only three states have environmental officers, two of which are
not MoE staff but falls under other ministries. MoE is responsible for development and
implementation of environmental policy and legislation, including performing the following
functions and duties:
 Develop and execute policies and programmes on environmental protection and
conservation throughout South Sudan;
 Establish the government's environmental policy and monitor its effectiveness and impact;
 Develop Environmental Impact Assessment standard methodologies and procedures for
GRSS development policies and for private sector investment; and
 Advise and support states and local governments in their responsibilities for environment
protection and build their capacity to assume all functions.
MoGCSW is responsible for promoting gender equality and equity with the following
functions:
 Articulate and execute GRSS policy on gender equity and social services;
 Develop policies and programmes to promote the welfare of physically and mentally
handicapped persons and other vulnerable groups;
 Develop policies and programmes in regards to social welfare for the aged, disabled,
orphans and street children;
 Develop policies and programmes in regards to women affairs; and
 Supervise and regulate all organizations, societies and unions that are concerned with
women and social welfare.
The vision of MoYCS is to transform RoSS into a culturally harmonious and vibrant society
with ethnic and cultural diversity. The functions include:
 Foster cultural interaction between different parts of Southern Sudanese society;
 Protect and preserve tangible and intangible cultural heritage records of Southern Sudan;
 Identify, gazette, maintain and oversee national monuments; and
 Advise and support states and local governments in their responsibilities for culture, youth
and sports and build their capacity.
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Furthermore, GRSS has established a land commission as an independent agency with
responsibility for management of land, involving issues such as ownership, registration,
conflict resolution and development of policy and legislation in this regard. The 2009 Land
Act lays out the institutional arrangement for land management at the lower administrative
levels, but has not yet been implemented.
The draft environment policy anticipates that state governments will be responsible for
ensuring that environmental and social impact assessments are undertaken. The counties are
expected to evaluate county and payam level applications and ensure mitigating measures are
implemented. The payam level is expected to support development of environmental
awareness and solve local conflicts over resources. The boma level is, amongst other things
responsible for promoting traditional best practices of environmental resource management
and to ensure that local communities are involved in all stages of decision-making.
6 Applicable World Bank Safeguard Policies
To ensure that World Bank funded initiatives does not have adverse impacts or cause harm,
10 operational safeguard policies - aimed at ensuring that interventions are implemented in
environmentally and socially appropriately - have been developed.
Depending on the context and the characteristics of the WB funded interventions none, some
or all of the operational policies are triggered. For the LGSD, five operational policies (4.01,
4.09, 4.10, 4.11, and 4.12) are of potential relevance. These five policies are listed in table 6.1
below along with the trigger of the operational policy and an analysis if the policy is triggered
or not. OP 4.01 on Environmental Assessment and OP 4.10 Indigenous Peoples are triggered.
Table 6.1: Potential relevant operational policies
Operational
Description
Policy
4.01
The objective of this policy is to
Environmental ensure that projects are
assessment
environmentally and socially
sound and sustainable, and that
decision-making is improved
through appropriate analysis of
their environmental impacts.
OP 4.01 covers impacts on the
natural environment (air, water
and land); social aspects, human
health and safety; physical
cultural resources; and
transboundary and global
environmental aspects.
Trigger
Triggered
The policy is
Yes, see details in section
triggered if a project 6.1 below
is likely to have
potential adverse
environmental and
social impacts.
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Operational
Policy
4.09
Pest
Management
4.10
Indigenous
Peoples
4.11 Physical
Cultural
Resources
Description
Trigger
Triggered
The objective of this policy is to
promote the use of biological or
environmental control and reduce
reliance on synthetic chemical
pesticides; and if necessary, to
strengthen the capacity of the
country’s regulatory framework
and institutions to promote and
support safe, effective and
environmentally sound pest
management.
The objective of this policy is to
ensure that the project respects
the dignity, human rights,
economies and cultural
uniqueness of indigenous
peoples.
The policy is
triggered if
procurement of
pesticides is
envisaged
No. Agricultural
subprojects involving
purchase of pesticides are
not eligible for funding.
The policy will ensure that
adverse effects during the
development process are avoided,
or when avoidance is not feasible,
ensure that adverse effects are
minimized, mitigated or
compensated. The policy will
also ensure that indigenous
peoples receive social and
economic benefits that are
culturally appropriate and gender
and intergenerational inclusive.
The objective of this policy is to
assist with avoiding or mitigating
adverse impacts of projects on
physical cultural resources, e.g.
movable or immovable objects,
sites, structures, groups of
structures, natural features and
landscapes that have
archaeological, paleontological,
historical, architectural, religious,
aesthetic, or other cultural
significance.
The policy is
triggered when the
project potentially
affects indigenous
peoples
Yes. Analysis by Bank
and other experts
confirms that the majority
or all people in the
project area meet the
requirements of the
policy. Per the
requirements of OP/BP
4.10, when Indigenous
Peoples are the sole or the
overwhelming majority
of direct project
beneficiaries, the
elements of an
Indigenous Peoples Plan
(IPP) should be included
in the overall project
design; a separate IPP is
not required.
The policy is
No. Any project that
applicable to all
would have an impact on
projects requiring a physical cultural
category A or B
resources will be not be
Environmental
funded. However, there
Assessment under
might be “chance finds”
OP 4.01 and to
that would require
projects located in or avoidance or mitigating
in the vicinity of
measures. For more
cultural heritage
details, see section 6.3
sites.
below.
Physical cultural resources may
be above ground, underground, or
underwater. The cultural interest
may be at the local, provincial or
national level, or within the
international community.
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ESMF - LGSDP South Sudan
Operational
Policy
4.12
Involuntary
Resettlement
Description
Trigger
Triggered
The objective of this policy is to
(i) avoid or minimize
involuntary resettlement
where feasible, exploring all
viable alternative project
designs;
(ii) ensure community
participation in planning and
implementation of
resettlement programmes;
(iii) assist displaced persons in
improving their livelihoods
and standards of living
standards, or at least in
restoring them.
The policy covers
not only physical
relocation, but any
activities resulting
in: (i) relocation or
loss of shelter; (ii)
loss of assets or
access to assets; (iii)
loss of income
sources or means of
livelihood, and iv)
restrictions on access
to parks and
protected areas.
No. Given the generally
low population density in
RoSS, land is generally
available for construction
of small-scale
infrastructure facilities,
be it community or public
land or through
documented voluntary
community donations.
Any sub-project activities
that will require
acquisition of land will be
not be eligible for
funding.
The Policy 4.01 requiring environmental assessments is triggered. The Environmental
Assessment policy calls for the LGSD as a whole to be screened to determine the extent and
type of environmental assessment process. Projects are assigned one of four project
categories:
Category “A” projects:
Category A project have impacts that are expected to have ‘significant adverse environmental
impacts that are sensitive, diverse8, or unprecedented. The environmental assessment is to
consider the project's negative and positive environmental impacts and compare them with
those of feasible alternatives. An Environmental Impact Assessment (EIA) is always required
for projects that are in this category.
Category “B” projects:
Category B projects have "potential adverse environmental impacts on human populations or
environmentally important areas - including wetlands, forests, grasslands, and other natural
habitats - that are less adverse than those of Category A projects". Category A projects are
site-specific and most or all are reversible, and in most cases mitigating measures can be
readily designed. Like for Category A projects, the environmental assessment it considers the
project's positive and negative impacts and compare them with alternatives and proposes
preventive, minimising, mitigating OR compensatory measures. Although an EIA is not
always required, some environmental analysis is necessary, typically in the form of en
Environmental Management Plan (EMP) - for details of this, please refer to chapter 10.
Category “C” projects:
Category C projects have "minimal or no adverse environmental impacts". After classification
of a project as a Category C project, no further action is required.
8
A project is sensitive" if it may be irreversible (e.g., lead to loss of a major natural habitat) or raise issues
covered by OP 4.04 - Natural Habitats; OP/BP 4.10 - Indigenous Peoples; OP/BP 4.11 - Physical Cultural
Resources or OP 4.12 - Involuntary Resettlement.
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ESMF - LGSDP South Sudan
Category “FI” projects: A proposed project is classified as Category FI if it involves
investment of Bank funds through a financial intermediary, in subprojects that may result in
adverse environmental impacts.
The subprojects of LGSD will be of small-scale, site-specific in nature and are expected to i)
have only limited environmental impact on humans and the environment, ii) will be
reversible, and iii) for most subprojects mitigating measures can be easily designed. The
LGSD is thus classified as Category B (see definition of categories above).
More details on OP 4.10 on Indigenous Peoples are in section 6.2 .
All subprojects that would trigger OP 4.11 on Physical Cultural Resources and OP 4.12 on
Involuntary Resettlement will not be eligible for funding. However, there is the possibility of
chance find of physical cultural resources for which mitigating measures have to be
developed.
6.1 OP 4.01 Environmental Assessment
This policy requires environmental assessment of projects proposed for World Bank financing
to ensure that they are environmentally and socially sound and sustainable. The breadth,
depth, and type of analysis of the environmental assessment depend on the nature, scale, and
potential environmental impact of the proposed project, in the case of LGSD of the proposed
subprojects.
Some of the subprojects could potentially have adverse environmental impacts, e.g.
construction or repair of health and educational facilities, markets, roads, drainage and dikes,
water and sanitation facilities, cattle dips, and small-scale irrigation facilities. Details on the
potential impacts of these subprojects are included in chapter 7.
The ESMF checklist is designed to identify the potential impacts, and assist the
implementing bodies at local level, communities and extension teams with practical measures
of avoiding or mitigating them. Moreover, for some subprojects with impacts on the nearby
environment, the ESMF will assist the implementing bodies and the local government
authorities in preparing an acceptable EMP before commencement of the work.
6.2 OP 4.10 Indigenous Peoples
OP 4.10 on Indigenous Peoples is triggered. In South Sudan indigenous peoples are the sole
or overwhelming majority of the population, and thus also of the beneficiaries of the LGSD.
The LGSD will eventually cover the entire country, with its main approach being a local
participatory planning process that aims at including all vulnerable sub-groups (whether
ethnic/tribal/kinship minority groups, women, youth and displaced) in consultations to agree
on the subprojects to be implemented. The LGSD supports the intentions and outcomes of OP
4.10 by (a) including as an early activity in the participatory county planning process a
mapping of ethnic tribal groups with identification of particularly vulnerable minority groups
and the nature of their vulnerabilities, so that measures can be taken to ensure their inclusion
in the planning process; (b) applying the principle of “equitable access to benefits” across all
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ESMF - LGSDP South Sudan
vulnerable sub-groups (whether ethnic/tribal/kinship minority groups, women, youth and
displaced) within the county; (c) monitoring delivery of equitable benefits across ethnic
groups with particular emphasis on the vulnerable (e.g. by accountability arrangements that
disclose information on budgets and spending and that involve communities in monitoring);
and (d) establishing a simple feedback and grievance mechanism that is accessible to the
different groups. The LGSD is thus embedding the basic principles of OP 4.10 of a free, prior,
and informed consultation leading to broad community support for the project.
Due to the above reasons, no separate Indigenous Peoples Plan (IPP) is required.
6.3 Chance find of physical cultural resources
Although subprojects that will have a negative impact on physical cultural resources are on
the negative list, physical cultural resources might unexpectedly be encountered (chance find)
during implementation of subprojects, e.g. in conjunction with excavation for construction of
infrastructure facilities. For more on this, please see chapter 11.
7 Potential impacts and mitigating measures
Table 7.1 below contains a summary of eligible subprojects that can be funded using the
participatory process for planning under the LGSDP, involving development of payam and
county development plans based on inputs from bomas and communities.
Table 7.1: Indicative subprojects
Type
Sector
Items
Local Public Water
Construction or repair of hand-pumps (non-motorized), tanks, dug wells,
Infrastructure
and haffirs for public use or in primary health care or education facilities
Sanitation
Provision or repair of latrines for public use or in primary health care or
education facilities
Storm water Repair of flood protection infrastructure (drainage / guttering / dykes)
Roads
Rehabilitation of local roads (using labor based methods only);
construction or rehabilitation of foot paths; culverts and bridges
Health
Construction, repair or extension of existing PHCC or PHCU where
health worker is already present
Purchase of furniture or equipment for existing PHCC or PHCU
Education
Construction, repair or extension of existing primary schools where
teacher is already present
Purchase of furniture or equipment for existing primary schools
Economic
Markets
Construction or repair of public market places
Infrastructure Livestock
Construction or repair of livestock dips
Irrigation
Repair of small scale community irrigation schemes, subject to approval
of technical design
Not all of the above subprojects will necessarily be implemented and others not on the list
might be included as experience is gained with implementation of the various subprojects
during the first year of LGSD.
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Common for most of the subprojects are that some kind of physical infrastructure will be
constructed or rehabilitated which might have adverse environmental and social impacts.
Furthermore, the use and maintenance of facilities can also have adverse impacts. The exact
scale of the impact will be site-specific as will the mitigating measures to be taken.
For most of the subprojects it is expected that they will have positive economic and social
impacts. These include improved service delivery; improved access to markets; increased
employment opportunities especially for subprojects that involve construction or
rehabilitation, be it through a contractor or through communities; development of the private
sector; and increased accountability downwards as well as upwards in the public sector.
An overarching issue related to construction of physical infrastructures is allocation of land.
Such lands might restrict use or access to livelihoods of individuals or communities. As
described in chapter 6 subprojects requiring involuntary resettlement will not be eligible for
funding. All land for construction of facilities will have to be obtained through voluntary
donations and it has to be ensured that the construction of facilities will not restrict use and
access of the land and its resources itself or of neighboring land and resources, e.g. water
points. Public lands allocated by the Government for subprojects, will be without any
encumbrances. A format for documenting the voluntary donation a of land for the purpose of
subprojects is presented in annex H.
Subprojects on lands with physical cultural resources will also not be eligible for funding.
However, there is the potential of discovering physical cultural resources during excavation.
Procedures for how to deal with such chance finds have been developed (see chapter 11 for
details).
A list of other subprojects not eligible for funding is included in annex D.
Table 7.2 contains the potential impact of the different subprojects anticipated. The first row
of the table contains potential impacts and mitigating measures of construction of general
physical infrastructures applicable to all construction work. Depending on the level of
rehabilitation required, some or all of the impacts and mitigating measures might also be
relevant for rehabilitation. A standard template for safeguard measures to be included in
contracts for construction or rehabilitation of infrastructure is included in annex I.
Some of the subprojects also have specific impacts and accompanying mitigating measures,
e.g. construction of pits latrines requires digging pits that might potentially pollute the
groundwater. These subproject specific impacts and mitigating measures are described in
subsequent rows in the table.
Use and maintenance of the physical infrastructure might also have subproject-specific
impact. These and mitigating measures are also included in separate rows in table 7.2.
24
ESMF - LGSDP South Sudan
Table 7.2: Potential impact and mitigating measures of subprojects
Subproject
Construction or
rehabilitation
of physical
structures
Potential negative impact
 Loss of vegetation cover causing
erosion of soil and siltation of streams
 Dumping of construction debris
 Use of limited or sensitively located
local construction materials such as
aggregate and wood
 Dust pollution due to movement of
equipment, digging
 Noise pollution due to use of
equipment
 Pollution of ground water due to oil
and fuel spills and exposure of ground
water table
 Pollution of surface water due to oil
spills
 Occupational health and safety due to
hazards from handling of equipment
 Chance find of physical cultural
resources
Use and
 Health hazards due to inadequate
maintenance of
cleaning and maintenance of school
schools
latrines
 Safety hazards due to collapsing latrine
pits
 Health hazard due to stagnant water at
school water points acting as breeding
ground for malaria carrying mosquitoes
and other vector-borne diseases
Dege Consult
Mitigating measures
 Cutting of vegetation to be kept at a minimum, replanting around
construction
 Application of appropriate erosion-protection measures, in
particular when working on slopes
 Ensure aggregate is only obtained from locations with no risk of
river bank collapse, landslides, loss of flora and fauna, etc.
 Minimize the use of wood for construction
 Works adjacent to a water resource require temporary barriers on
slopes to prevent silt from entering the water resource
 Disposal of construction debris should occur at waste dumps
 Prevention of excessive dust emissions including cement dust by
careful handling and working under moist conditions as much as
possible
 Use of noisy equipment should be concentrated during day-light
hours
 All solid waste, fuels or oils should be collected
 The contractor should protect workers by ensuring the use of
protective equipment
 The bottom of the pit is at least 1.5 m above the water table
 Latrines should be located at least 30 m from any water source
 Follow procedures in chapter 11 for chance find of physical cultural
resources
 Ensure the presence oils spill containment at the construction site
 Maintenance plans for school latrines must be developed
 Latrine design standards must be adhered to
 All water facilities must have proper drainage
Potential positive impact
 Increased employment
opportunities for community
members (laborers, guards etc.
during construction)
 Improved aesthetics due to more
environmentally friendly
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessment.
 Improved capacity of MoE to
handle chance find of physical
cultural resources.
 Improved access to education
 Increased employment
opportunities for community
members (guards) and smallscale craftsmen (plumbers,
carpenters etc.)
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ESMF - LGSDP South Sudan
Subproject
Potential negative impact
Use and
 Health hazards caused by inadequate
maintenance of
storage and disposal of medical and
health facilities
other wastes
 Health hazards due to inadequate
cleaning and maintenance of latrines
 Health hazard due to stagnant water at
water points acting as breeding ground
for malaria carrying mosquitoes and
other vector-borne diseases
Use and
 Pollution of soil and water resources
maintenance of
due to inappropriate collection and
markets
disposal of market refuse and waste
 Noise pollution from movement of
trucks etc. carrying market goods.
 Health hazards due to poor storage of
market goods providing breeding
grounds for disease carrying rodents
and vectors.
 Health hazards due to inadequate
cleaning and maintenance of latrines
 Safety hazards due to collapsing latrine
pits
 Privacy concerns and sexual violence
due to lack of gender separated latrines
 Health hazard due to stagnant water at
water points acting as breeding ground
for malaria carrying mosquitoes and
other vector-borne diseases
Dege Consult
Mitigating measures
 Provide collection and disposal system for medical or others
wastes, e.g. incinerators or transfer to special dump sites
 Maintenance plans for latrines must be developed
Potential positive impact
 Improved access to health care
 Increased employment
opportunities for community
members (guards) and smallscale craftsmen (plumbers,
carpenters etc.)








 Improved access to markets
 Increased employment
opportunities for community
members (guards) and smallscale craftsmen (plumbers,
carpenter etc.)

Establish waste collection procedures
Identification of suitable locations for waste disposal
Establish timing rules for movements of trucks
Undertake public awareness campaign on storage of market goods
Maintenance plans for latrines must be developed
Latrine design standards must be adhered to
Ensure all water facilities have proper drainage
Create awareness on safe collection and disposal of wastes
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ESMF - LGSDP South Sudan
Subproject
Construction or
rehabilitation
of roads and
bridges
Potential negative impact
In addition to the potential impacts
mentioned in the section on general
construction or rehabilitation impacts at
the top of this table:
 Stemming of water flow during
construction of bridges causing water
shortage, change of water course, etc.
downstream
Use and
 Dust and noise pollution due to
maintenance of
movement of vehicles etc
roads and
 Erosion during rain due to drainage
bridges
 Safety concerns due to speeding
vehicles
 Pot holes with stagnant water providing
breeding ground for disease-carrying
vectors
 Bridges causing changes in water flow
causing flooding, erosion or siltation
Dege Consult
Mitigating measures
In addition to the mitigating measures described in the section on
general construction mitigating measures at the top of this table:
 Leave some channels to allow for continued flow downstream.
 Design bridge to ensure minimum changes in water flow
Potential positive impact
 Increased employment
opportunities for community
members (laborers, guards etc.
during construction)
 Improved aesthetics due to more
environmentally friendly
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessments.
 Improved capacity of MoE to
handle chance find of physical
cultural resources
 Provide speed control bumps where road is close to community to
avoid accidents and dust and noise pollution
 Adequate design of drainage systems
 Ensure adherence to design quality and regular maintenance to
avoid pot holes
 Design bridge to ensure minimum changes in water flow
 Improved access to basic social
services
 Improved access to markets
 Increased employment
opportunities for small-scale
craftsmen (carpenter etc.)
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ESMF - LGSDP South Sudan
Subproject
Construction or
rehabilitation
of water
facilities, e.g.
drilling and
installation of
hand pumps
Potential negative impact
In addition to the potential impacts
mentioned in the section on general
construction or rehabilitation impacts at
the top of this table:
 Contaminated water due to a proximity
of latrines and waste disposal sites
 Interference with culturally sensitive
sites, graveyards, spiritual sites
Use and
 Lowering of water table
maintenance of  Health hazard due to stagnant water at
water facilities
water points acting as breeding ground
for malaria carrying mosquitoes and
other vector-borne diseases
 Health hazard due to bacteriological
contamination of water
 Health hazard due to poisonous
substances in ground water, e.g.
arsenic, fluoride
Dege Consult
Mitigating measures
Potential positive impact
In addition to the mitigating measures described in the section on
 Increased employment
general construction or rehabilitation mitigating measures at the top
opportunities for community
of this table:
members (laborers, guards etc.
 Water facilities should be located at least 30 m from any latrine or
during construction)
waste disposal site
 Improved aesthetics due to more
 Avoid siting haffirs/boreholes or other water supply structures even
environmentally friendly
if it involves changing the dimensions and sizes
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessments.
 Improved capacity of MoE to
handle chance find of physical
cultural resources




Establish abstraction limit
Ensure water facilities have proper drainage
Bacteriological and chemical testing of water
Ensure adequate chlorination procedures for water source
 Improved access to safe water
 Increased employment
opportunities for small-scale
craftsmen (plumbers, masons
etc.)
 Improved health
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ESMF - LGSDP South Sudan
Subproject
Construction or
rehabilitation
of sanitation
facilities
Potential negative impact
In addition to the potential impacts
mentioned in the section on general
construction or rehabilitation impacts at
the top of this table:
 Contamination of groundwater due to
inappropriate location of latrines
Mitigating measures
In addition to the mitigating measures described in the section on
general construction or rehabilitation mitigating measures at the top
of this table:
 The bottom of the pit is at least 1.5 m above the water table
 Latrines should be located at least 30 m from any water source
Use and
 Health hazards due to inadequate
 Maintenance plans for latrines must be developed
maintenance of
cleaning and maintenance of latrines
 Latrine design standards must be adhered to
sanitation
 Safety hazards due to collapsing latrine  Separate latrines for men/boys and women/girls must be
facilities
pits
constructed
 Privacy concerns and sexual violence
due to lack of gender separated latrines
Dege Consult
Potential positive impact
 Increased employment
opportunities for community
members (laborers, guards etc.
during construction)
 Improved aesthetics due to more
environmentally friendly
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessments.
 Improved capacity of MoE to
handle chance find of physical
cultural resources
 Improved access to latrine
facilities
 Increased employment
opportunities for small-scale
craftsmen (plumbers, masons
etc.)
 Improved privacy for girls
 Improved health
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ESMF - LGSDP South Sudan
Subproject
Construction of
flood
protection
infrastructure
Potential negative impact
In addition to the potential impacts
mentioned in the section on general
construction or rehabilitation impacts at
the top of this table:
 maintenance of latrines
 Stemming of water flow during
construction., change of water course,
etc. downstream
Construction or
rehabilitation
of livestock
dips
In addition to the potential impacts
In addition to the mitigating measures described in the section on
mentioned in the section on general
general construction mitigating measures at the top of this table:
construction or rehabilitation impacts at  Livestock dips should be located at least 30 m from any water
the top of this table:
source
 Contamination of groundwater due to
inappropriate location of livestock dips

Use and
 Health hazards due to unsafe storage
maintenance of
and use of chemicals
livestock dips  Health hazards due to unsafe disposal
of expired chemicals and empty
containers
 Pollution of soil and groundwater due
to spillage
 Erosion of nearby areas due to
(temporary) high density of livestock
Dege Consult
Mitigating measures
In addition to the mitigating measures described in the section on
general construction or rehabilitation mitigating measures at the top
of this table:
 Leave some channels to allow for continued flow downstream
 Estimate and allow the minimum ecological flow to downstream
 Training of livestock herders in safe storage and use of chemicals
 Training of livestock herders in safe disposal of expired chemicals
and empty containers
 Provision of proper onsite safe chemical storage
 Establish separator and containment pond in case of significant
impact
Potential positive impact
 Increased employment
opportunities for community
members (laborers, guards etc.
during construction)
 Improved aesthetics due to more
environmentally friendly
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessments.
 Improved capacity of MoE to
handle chance find of physical
cultural resources
 Increased employment
opportunities for community
members (laborers, guards etc.
during construction)
 Improved aesthetics due to more
environmentally friendly
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessments.
 Improved livestock health
 Improved income
30
ESMF - LGSDP South Sudan
Subproject
Construction or
rehabilitation
of small-scale
irrigation
schemes
Potential negative impact
In addition to the potential impacts
mentioned in the section on general
construction or rehabilitation impacts at
the top of this table:
 Stemming of water flow during
construction., change of water course,
etc. downstream
Mitigating measures
In addition to the mitigating measures described in the section on
general construction mitigating measures at the top of this table:
 Design water intake to ensure minimum changes in water flow
Use and
 Over-use of water deprives downstream  Ensure design does not deprive downstream communities of water
maintenance of
communities access to water
 Estimate and allow minimum ecological flow to downstream
small-scale
irrigation
schemes
Dege Consult
Potential positive impact
 Increased employment
opportunities for community
members (laborers, guards etc.
during construction)
 Improved aesthetics due to more
environmentally friendly
construction.
 Improved capacity of state and
county focal points due to onthe-job training in
environmental and social
assessments.
 Improved capacity of MoE to
handle chance find of physical
cultural resources
 Improved agricultural
production
 Improved income
 Increased employment
opportunities for small-scale
craftsmen (plumbers, masons,
etc.)
31
ESMF - LGSD South Sudan
8 Capacity development
Taking into consideration the limited institutional capacity of GRSS and the lack of an
explicit legislative environmental framework, support to develop the capacity to sufficiently
screen and assess the environmental impact of the LGSD is required.
8.1 Safeguards staff
It is envisaged that the LGSD PMU will employ a full-time Senior Safeguards Specialist who
will be recruited internationally/regionally and nationally recruited Safeguards Officer. These
experts will oversee implementation of LGSD social and environmental safeguards measures;
liaise closely with the Ministry of Environment at national and state level; will be responsible
for implementation of the ESMF, and will provide support to and supervise state and countylevel safeguard focal points. The Senior Specialist will conduct a detailed training needs
assessment and based hereupon develop detailed training programmes for the state and county
level focal points. The senior specialist together with the safeguard officer and state safeguard
focal points will also be responsible for monitoring and audit of safeguards implementation in
subprojects as per chapter 12.
The state, county and payam level focal points will be appointed among existing staff. The
state focal points will support and supervise the county level safeguard focal points. The focal
points at state and county level will regularly follow up and monitor the implementation of
subprojects to guarantee compliance with the ESMF and will work in collaboration with the
State Ministry/Directorate of Environment to manage the environmental and social safeguards
issues in the project.
State and County level safeguard focal points will also apply screening checklists to
subprojects; conduct environmental and social management activities; ensure sound
implementation of ESMF; be responsible for development, implementation and monitoring of
the environmental and safeguard tools (EIA, EMP); provide training and capacity building
activities to local government staff at county, payam and boma levels and to community
members; conduct regular supervision; and prepare progress reports.
8.2 Training
The objective of the training activities are to ensure that relevant state and county government
staff are able to design and contract community-driven subprojects taking into consideration
environmental and social aspects, and to ensure that local government officials have the
capacity to analyze environmental and social impacts, prescribe mitigating measures and
appraise, approve and supervise implementation of subprojects.
The Senior Safeguards Specialist is expected to require some additional exposure to regional
and international standards. Such training is expected to be available at the regional and
international level. Participating in one regional and one international training course is
foreseen.
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ESMF - LGSD South Sudan
The state focal points will require initial training on environmental issues in general, on the
safeguards policies, and on the use of the checklists. The Senior Safeguard Specialist will
provide the training. Annual follow-up training is anticipated. The training will take place in
Juba.
Training of county focal points will be required, both on general environmental issues and on
the specific screening procedures and mitigating measures described in the ESMF/LGSD
Operations Manual. Initial as well as annual follow-up training is anticipated, taking into
consideration also the turnover of staff.
As the state focal points might not be identified, or have not yet received training during the
Fast Track Initiative (FTI), the Senior Safeguards Specialist in collaboration with other
institutions at national level will organize the training of the county focal points in the 8
counties selected for participation in the FTI. Training of county focal points will provide a
good opportunity for the Senior Safeguards Specialist to obtain solid experience from the
county level that will be useful for subsequent training of state focal points and for the
development/refinement of county focal point training materials.
Initial training of the remaining county focal points (32) will be done by the state focal points
and the Safeguard Officer at PMU as will all annual follow-up training. Training of county
focal points will take place in state capitals.
Training courses on environmental and social issues, possible impacts of subprojects, and
grievance mechanisms to payam/boma/community levels will be undertaken by the FPs. The
FPs will be organizing other training/awareness sessions for the communities, into which
these aspects will be integrated.
Based on the general guidelines indicated below, annual detailed training plans with details of
topics to be covered and selection of participants will be developed by the Senior Safeguards
Specialist.
As a general guideline, training and awareness/ sensitization of LGSD environmental
officers, engineers, and line agency staff at the state and county level on issues of
environmental and social impacts is required. The sensitization/awareness training will
aim to build awareness and sensitize a broad audience, particularly LGB/MOFEP officials,
staff of MOFEP/LGB, professional staff in the relevant line ministries, etc. to the
requirements and key aspects of LGSD ESMF.
In addition, a more detailed and specific training module will be developed and delivered
to the state and county level focal points, and other relevant staff in the line ministries,
including from the Ministry/directorate of Environment, involved in implementation of the
LGSD. This training will include regular updates and refresher modules delivered during
ESMF implementation.
The training and capacity building activities proposed to support ESMF implementation are:
 General training and awareness/sensitization for relevant stakeholder at national,
state, county, payam level and local communities on the contents and
implementation requirements of the LGSD ESMF.
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ESMF - LGSD South Sudan
 In depth training for focal points at state and county level on implementation of the
ESMF including all aspects of environmental management, EIA, public consultation,
and integration of environmental management into development planning.
Table 8.1 sets out the training requirements for each of these groups, which will be updated
by Senior Safeguards Specialist at PMU. For each training session, the value of inviting
participation of other stakeholders, such as those from local authorities will be considered.
The Senior Safeguards Specialist and Safeguards Officer at PMU will design the generalized
and in-depth training modules; and deliver the training in state capital cities.
Table 8.1: Training and Sensitization Requirements
EIA
Public consultation
Integrating
environmental and social
management into
development planning
Applying ESMF
International standards
on environmental and
social management
issues
Safeguard State
officer at focal
PMU
points
T
T
T
T
T
T
T
T
T
S
County
focal
points
T
T
T
T
A
Participants
Payam
State Line County Line Executive
Extension Agencies Agencies
Chief at
officers
and LGB and LGB
Boma level
NA
NA
NA
NA
A
NA
NA
NA
S
A
A
A
S
NA
S
NA
S
NA
A
NA
T = detailed training, S = sensitization to the issues, A = raised awareness, NA=not applicable
For each group, training will be provided to enhance the expertise of participants on the
relevant areas:
 In-depth training to a level that allows trainees to go on to train others, including technical
procedures where relevant;
 Sensitization, in which the trainees become familiar with the issues to a sufficient extent
that it allows them to specify requirements for further technical assistance; and
 Awareness-raising in which the participants acknowledge the significance or relevance of
the issues, but are not required having technical or in-depth knowledge of the issues.
Training to state and county level staff and line agency staff at the payam level on issues of
environmental management, is required in the form of initial training followed by regular
refresher courses and updates.
The Senior Safeguards Specialist and Safeguards Officer at national PMU level and
Safeguards Focal Points at state level will provide training to others, e.g. state focal points
will train county focal points. A cascade model of training will be adopted with regular
oversight from the PMU level. Details of the training are set out in table 8.2. Programs will
also include refresher courses from time to time in all of the topics identified.
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ESMF - LGSD South Sudan
Table 8.2: Proposed Training Packages
Audience
Safeguards
Officer at
PMU
Training Component
Detailed Training in EIA, Public Consultation
and Integrating Environment into
Development Planning, Applying ESMF,
International Standards on Environmental and
Social Management issue.
Detailed Training in EIA, Public Consultation
and Integrating Environment into
Development Planning, Applying ESMF,
International Standards on Environmental and
Social Management issue.
Length
5-day workshop for
the first year and 1day refresher
courses annually
Detailed Training in EIA, Public Consultation
and Integrating Environment into
Development Planning, Applying ESMF,
International Standards on Environmental and
Social Management issues (less detailed than
for state officers).
Payam
Sensitization and raised awareness in Public
Extension
Consultation and Integrating Environment and
officers
Social management concern into Development
Planning, Applying ESMF.
State Line
Sensitization and raised awareness in
Agencies
Integrating Environment and Social
and LGB
management concern into Development
staff
Planning and Applying ESMF.
County Line Sensitization and raised awareness in
Agencies
Integrating Environment and Social
and LGB
management concern into Development
staff
Planning and Applying ESMF.
Executive
Raised awareness in Integrating Environment
chief at
and Social management concern into
Boma level Development Planning and Applying ESMF.
3-day workshop for
the first year and 2days refresher
courses annually
State focal
points
County
focal points
4-day workshop for
the first year and 2day refresher
courses annually
1-day sensitization
workshop as
required
Timing
Regular training to
bring Safeguards
Officer up to required
level, and regularly
updating
Regular training to
bring selected State
safeguard focal points
up to required level,
and regularly update
them
Regular training to
build capacity of
County-level staffs
1-day sensitization
workshop per state
as required
Sensitize and raised
awareness to build
capacity of Payam
Extension officers
Coinciding with some
of these topics in other
LGSDP staff’s training
1-day sensitization
workshop per state
as required
Coinciding with some
of these topics in other
LGSDP staff’s training
Half-day awareness
raised workshop
during project
implementation
period
Coinciding with some
of these topics in other
LGSDP staff’s training
and consultation
during project
implementation period
An example of an agenda for a proposed 2 day training workshop on ESMF implementation
and integration of environment and social management concerns into development planning is
provided in table 8.3 below.
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ESMF - LGSD South Sudan
Table 8.3: Sample training agenda
Day Session
1
Introduction to
Environmental and
Social
Management Plans
2
Content
This session will introduce participants to the theory and application of ESMF as
a decision making tool. It will outline the principles of ESMF and provide clear
definitions on EMP practice terminology (e.g. classification of impacts, natural
resource base (water, soil, land, biodiversity, air, etc., mitigation and monitoring)
and social baseline (employment, social, health, etc).
World Bank
This section will discuss the relevant principal World Bank safeguard policies
Safeguard Policies and their application to subprojects under the LGSDP. In addition, the applicable
and national
South Sudan legislation will be discussed in terms of the relevant environmental
legislation
and social laws and policies which apply to activities under the program.
Screening of
A list of potential activities to be financed under the projects will be discussed.
LGSD subprojects Application of the screening checklist will be explained using case studies.
Impact
Potential impacts related to various types of activities will be discussed, in terms
identification
of their significance (adverse or minimal, positive or negative), magnitude (long
term versus short term), and impact category (localized or cumulative).
Mitigation and
Mitigation measures as they apply to irrigation and drainage investments will be
monitoring
discussed, in terms of their application, cost and feasibility. Monitoring measures
will also be recommended to measure the effectiveness of mitigation plans and to
monitor performance.
Responsibilities for For each target audience, responsibilities for environmental and social
planning and
management will be discussed as they relate to LGSDP implementation. This will
reporting
include responsibilities for planning, management of impact identification and
mitigation/monitoring, partnerships with NGOs and technical service providers,
partnerships among community members, and reporting.
Integrating
Defining process, procedures and responsibilities for environment and social
Environmental and management related activities and actions into the preparation of sub project
Social management development plans and budgets.
concerns into
development
planning
A budget for the cost of training activities is included in table 8.4 below. A contingency is
included to cater for training of new county or state focal points in instances where the first
appointed focal point has resigned and for re-training of non-performers.
Table 8.4: Budget for training activities
Training activity
Safeguard Officer
Regional training course
International training course
Subtotal
State focal points
Initial training
Annual follow up training
Subtotal
County focal points
Initial training of 8 FTI counties
Initial training of remaining 32 counties
Annual follow up training
Subtotal
Total
Contingency for additional training due to staff
turnover and non-performance (13 %)
Dege Consult
Duration Cost/participant/
No. of
[days]
day* [USD]
participants
Total cost
[USD]
5
5
650
1,000
1
1
3,250
5,000
8,250
4
2
450
450
10
15
18,000
13,500
31,500
3
3
2
425
125
125
8
32
50
10,200
12,000
12,500
34,700
74,450
11,550
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ESMF - LGSD South Sudan
Training activity
Duration Cost/participant/
No. of
[days]
day* [USD]
participants
Total cost
[USD]
Grand total
86,000
* Inclusive of participants' transport and per diems and, if applicable, trainers' (state focal points and in the case
of initial training of FTI counties the safeguard officer/specialist) transport and per diems.
8.3 Technical assistance
As most of the expected subprojects under the LGSD are expected to have small-scale and
limited impacts that can be easily mitigated (environmental categories B or C) by employing
best practices, it is anticipated that the state focal points and the safeguards officer/senior
safeguards specialist will be able to provide the required technical assistance on safeguards
management to county and payam-level focal points.
In cases where the environmental assessments are more complicated the county and payamlevel focal points will request assistance from the senior safeguards specialist and safeguards
officer at national level and focal points at state level.
8.4 Operational support
To ensure that monitoring and supervision is provided as intended the LGSD budget
incorporates budget lines for travel cost of the senior safeguards specialist and the safeguards
officer employed at the PMU. It is anticipated that the senior safeguards specialist and the
safeguards officer will visit each state regularly, and the counties as requested by the state
focal point officers. The state focal points will visit all participating payams twice a year9 and
any time as necessary and requested by the implementing bodies at payam level. The cost of
travelling for focal points will be covered through the allocation for county administrative and
logistical expenses.
9 Subproject management procedures
This chapter describes the overall procedures that all subprojects must go through in order to
ensure adequate attention to environmental and social safeguards. To ensure that the
procedures described here conform to the detailed subproject grant approval procedures as per
the Operations Manual for the LGSD, these procedures will be elaborated and incorporated as
relevant in the final Operations Manual.
9.1 Subproject preparation and application
During planning and preparation of subprojects, the FP’s are required to ensure that
environmental and social impacts of subprojects are minimized. Table 7.2 in chapter 7 will be
used by FPs to obtain an overview of potential environmental and social impacts.
As numerous subprojects applications are likely to be submitted for funding, the final
assessment of environmental and social impacts is most effectively done only after the
9
Each payam is likely to have approximately 2 projects per 2 year.
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subproject has been approved in principle. Subprojects will thus not be finally approved until
a detailed impact assessment has been approved and disclosed. The Operations Manual will
contain detailed procedures and formats for this purpose.
9.2 Screening, appraisal and approval of subprojects
Once a subproject has been approved in principle, a screening of the subprojects potential
environmental and social impacts are undertaken using the checklist in Annex C. The
screening of the subproject might result in a request for development of an Environmental
Management Plan (EMP) (see chapter 10 for more information on the EMP). If an EMP is
developed, it must be disclosed as described in section 9.3 below.
A number of subprojects are not eligible for funding, e.g. if they potentially have a negative
impact on physical cultural resources, require land acquisition, or significant impacts on
natural habitats, forests and other. A list of such subprojects is included in Annex D.
If there is the potential of chance find of physical cultural resources, the contract for
construction or rehabilitation have to include reference to procedures to follow as per chapter
11 and annex E.
After screening of the subproject, the application is submitted for appraisal. A format for use
for the appraisal of the subproject application is included in Annex F.
The appraisal might require a field appraisal mission to the location of the subproject in order
to obtain additional or more detailed information. A form for underting the field appraisal is
included in Annex G.
Depending on the field appraisal mission, the appraisal might reconsider the need for
development of an EMP for the subproject (see chapter 10). As part of the appraisal, the
subproject's corresponding EMP has to be made publicly available as per section 9.3 below.
Only when the disclosure procedure has been followed can the subproject be approved.
9.3 Disclosure of subproject information
The World Bank's Policy on Disclosure of Information requires that EMPs are made available
for public review as well as forwarded to the World Bank for disclosure through the World
Bank's Infoshop.
Only when the subproject information has been made publicly available can it be finally
approved. The detailed procedures for public disclosure will be according to the procedures
for grievances as described in the LGSD Operations Manual.
10 Environmental Management Plan (EMP)
The EA process involves the identification and development of measures aimed at
eliminating, offsetting and/or reducing environmental and social impacts to levels that are
acceptable during implementation and operation of the subprojects. As an integral part of EA,
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EMP provides an essential link between the impacts predicted and mitigation measures
specified within the EA and implementation and operationalization of activities. The World
Bank guidelines state that detailed EMPs are essential elements for Category ‘A’ projects, but
for many Category ‘B’ projects, a simple EMP will suffice. While there are no standard
formats for EMPs, it is recognized that the format needs to fit the circumstances in which the
EMP is being developed and the requirements, which it is designed to meet.
EMPs should demonstrate that proposed monitoring activities will encompass all major
impacts and how they will be integrated into project supervision. The EMP should also
describe proposed mitigation measures and to facilitate public consultation. It is important
that the EMP identifies linkages to other plans relating to the project, such as plans dealing
with resettlement or indigenous peoples issues. LGB/MOFEP, as the PMU, is responsible for
preparing a standard EMP in a format suitable for inclusion as technical specifications in the
contract documents - a template is included in Annex L.
EMPs should be prepared after taking into account comments and clearance conditions from
both the relevant agency (MoE) and WB. Given below are the important elements that
constitute an EMP:
i)
Impacts: Predicted adverse environmental and social impacts (and any uncertainties
about their effects) for which mitigation is necessary should be identified and
summarized.
ii) Description of Mitigation Measures: Each measure should be briefly described in
relation to the impact(s) and conditions under which it is required. These should be
accompanied by, or referenced to, designs, development activities (including equipment
descriptions) and operating procedures and implementation responsibilities. Proposed
mitigation measures to facilitate public consultation should be clearly described and
justified. Feasible and cost-effective measures to minimize adverse impacts to acceptable
levels should be specified with reference to each impact identified. Further, the EMP
should provide details on the conditions under which the mitigation measure should be
implemented. The EMP should also distinguish between the type of solution proposed
(structural and non-structural) and the phase in which it should become operable (design,
construction and/or operation). Efforts should also be made to mainstream environmental
aspects wherever possible.
iii) Description of monitoring program: The EMP identifies monitoring objectives and
specifies the type of monitoring required; it also describes performance indicators which
provide linkages between impacts and mitigation measures identified in the EA report,
parameters to be measured (for example: national standards, engineering structures,
extent of area replanted, etc), methods to be used, sampling location and frequency of
measurements, detection limits (as appropriate) and definition of thresholds to signal the
need for corrective actions. Monitoring and supervision arrangements should be agreed
by the Bank and the borrower to: ensure timely detection of conditions requiring remedial
measures in keeping with good practice; furnish information and the progress and results
of mitigation and institutional strengthening measures; and, assess compliance with
national and Bank environmental safeguard policies
iv) Institutional arrangements: Institutions/parties responsible for implementing mitigation
measures and for monitoring their performance should be clearly identified. Where
necessary, mechanisms for institutional coordination should be identified, as often,
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monitoring tends to involve more than one institution. This is especially important for
projects requiring cross-sectoral integration. In particular, the EMP specifies who is
responsible for undertaking the mitigating and monitoring measures, e.g., for
enforcement of remedial actions, monitoring of implementation, training, financing, and
reporting. Institutional arrangements should also be crafted to maintain support for agreed
enforcement measures for environmental protection. Where necessary, the EMP should
propose strengthening the relevant agencies through such actions as: establishment of
appropriate organizational arrangements; appointment of key staff and consultants; and,
arrangements for counterpart funding and on-lending.
v) Implementing schedules: The timing, frequency and duration of mitigation measures
and monitoring should be included in an implementation schedule, showing phasing and
coordination with procedures in the overall project implementation /operations manual.
Linkages should be specified where implementation of mitigation measures is tied to
institutional strengthening and to the project legal agreements, e.g. as conditions for loan
effectiveness or disbursement.
vi) Reporting procedures: Feedback mechanisms to inform the relevant parties on the
progress and effectiveness of the mitigation measures and monitoring itself should be
specified. Guidelines on the type of information wanted and the presentation of feedback
information should also be highlighted.
vii) Cost estimates and sources of funds: Implementation of mitigation measures mentioned
in the EMP will involve an initial investment cost as well as recurrent costs. The EMP
should include cost estimates into the sub-project design, bidding and contract documents
to ensure that the contractors will comply with the mitigation measures. The costs for
implementing the EMP will be included in the sub-project design, as well as in the
bidding and contract documents. It is important to capture all costs – including
administrative, design and consultancy, and operational and maintenance costs – resulting
from meeting required standards or modifying project design.
The development of an EMP with mitigation measures and monitoring is done by the use the
format included in Annex L.
Annex L also contains a description of information that will assist in identifying the
subproject, e.g. information on the state, county, payam and boma/community where the
subproject is located. Also included is the subproject code, as prescribed in the LGSD
Operations Manual. To ensure unique identification and to cater for changes in administrative
borders or names, the EMP further requires entering of GPS coordinates of the location.
For each potential impact of the subproject, corresponding mitigating measures and who is
responsible for implementation is indicated. For each potential environmental impact there
can be more than one mitigating measure. Each mitigating measure might require a more
detailed description, including bill of quantities, materials to use, timing of the intervention,
etc. Such detailed descriptions will be part of the contract for the construction or rehabilitation
of the subproject.
Responsibility for implementation of mitigating measures will typically rest with the
contractor or community during construction or rehabilitation, and for impacts occurring
during use and maintenance, the responsibility will typically - given the anticipated types of
subproject - rest with the users.
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The monitoring section of the EMP prescribes indicators for monitoring the environmental
impact and the effects of mitigating measures. The responsibility for this will typically rest
with the county safeguard focal points in collaboration with payams, bomas and communities.
The schedule for collection of data on indicators is also indicated.
For each mitigating measure the cost and source of funds is indicated. The cost of mitigating
measures required during construction will typically be included in the subproject grant, i.e.
included in the construction contract with the contractor or community as applicable. The cost
of mitigating measures during use and maintenance will typically be the responsibility of the
users.
11 Chance find of physical cultural resources
Although subprojects that will impact on physical cultural resources not eligible for funding
under the LGSD (for a list of subprojects not eligible for funding, please refer to Annex D),
there is the possibility of chance find of physical cultural resources, most notably during
excavation as part of construction or rehabilitation of infrastructure.
Such physical cultural resources may take the form of work of art, building structures, graves
or other sites of importance, including sites of archaeological, historical or religious
significance.
All chance finds of such physical cultural resources will lead to temporary suspension of all
activity that will adversely impact the cultural resource. Contracts will include detailed
procedures for ensuring the protection of the cultural resources, including cessation of
activities until the significance of the find has been determined and until appropriate
mitigating measures has been implemented. Annex E contains standard provisions to be
annexed to contracts that potentially will lead to chance finds of physical cultural resources.
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12 ESMF Monitoring, reviews and evaluation
12.1 Monitoring
The ESMF implementation indicators to be monitored during project implementation include:
 Number of field appraisals undertaken,
 Number of EMPs developed,
 Number of written warnings of violations of EMPs issued to project contractors in
case of non-compliances,
 Number of chance find procedures for physical cultural resources invoked.
The ESMF training component is monitored through indicators of number of safeguard
specialist/officer, state focal points, county focal points, community members etc. trained and
the topics covered.
Follow up on previous recommendations is monitored through the number of
recommendations from the annual review that have been implemented
The indicators are deliberately very simple. Despite their simplicity, the integration of these
indicators into the LGSD project M&E system provides a guarantee that the ESMF will be
implemented in full during the LGSD implementation period.
A template for monitoring is included in Annex J.
12.2 Reviews
Annual reviews of the ESMF implementation will be undertaken by external consultants. The
reviews will amongst other things be assessing the LGSD's performance in complying with
the procedures described in this document, the need for future training, and the environmental
and social impact of the LGSD.
The annual reviews will take place after preparation of the annual reports as described in the
section above.
Guidelines for annual reviews are included in Annex K.
12.3 End-of-project evaluation
Based on the comprehensive annual reviews, an end-of-project evaluation will take place,
going into more details with some of the issues raised in the annual reviews and the impact of
the capacity development activities provided to the GRSS officials. The evaluation will be
performed as per the OECD/DAC criteria of relevance, effectiveness, efficiency, impact, and
sustainability10.
10
For more information on the OECD/DAC criteria, please refer to
http://www.oecd.org/dac/evaluationofdevelopmentprogrammes/daccriteriaforevaluatingdevelopmentassistance.h
tm
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13 ESMF implementation Budget
The estimated total cost for implementation of the ESMF is indicated in table 13.1 below. A
detailed breakdown of costs related to capacity development of safeguard specialists and focal
points can be found in chapter 8.
Monitoring is not included in the ESMF budget as it will be covered directly or indirectly by
the LGSD, i.e. through allocation for county administrative and logistical expenses or through
inclusion of cost for mitigating measures in contracts with contractors or communities.
Table 13.1: ESMF budget
Activity
Capacity development
Annual reviews of ESMF
End-of-project ESMF evaluation
Description
As per chapter 8
Based on four annual reviews (the last
annual review is replaced by the end-ofproject evaluation)
An evaluation of the impact of the
ESMF and the subprojects
Total
Total cost [USD]
86,000
120,000
30,000
236,000
14 Public consultation, disclosure and grievances
14.1 Public consultation
The process of developing the draft ESMF included consultation with stakeholders in South
Sudan, including GRSS, CBO, NGO and development partner staff. Furthermore, the draft
ESMF was distributed to relevant stakeholders and a workshop was held with participation of
national NGOs.
The workshop was organized by PACT, the international NGO responsible for
implementation of the Fast Track Initiative. During the workshop, the environmental and
social views and concerns of participants in relation to the LGSD were raised and discussed.
Participants' concerns and experiences were shared and used for improving the ESMF.
The project processes embed an ongoing consultation process as part of subproject planning,
implementation and oversight. These participatory consultative processes will be also include
environmental and social impacts of subprojects implementation, operations and maintenance.
14.2 Disclosure
Operational Policy 4.01 requires that the GRSS and the World Bank disclose the ESMF report
as a separate and stand-alone document. The disclosure should be both in RoSS where it can
be accessed by the general public, including affected groups and NGOs, and at the InfoShop
of the World Bank.
The MoFEP/LGB will make copies of the ESMF available in selected public places
(possibly at state government offices) for information and comments. It is proposed that the
locations of copies are announced through radio announcement as newspaper circulation
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remains limited. The announcement will include a brief description of the LGSD, references
to where and when the ESMF can be viewed, duration of the display period, and contact
information for comments.
14.3 Feedback and Grievance mechanism
A detailed feedback and grievance mechanism will be included in the Operations Manual for
the overall functioning of the LGSD. It will be ensured that the grievance mechanisms will
include the necessary procedures for disclosure and resolution of environmental and social
related grievances of subprojects.
The grievance mechanism will detail procedures on how grievances related to subprojects are
dealt with, including how, when and where subproject information is disclosed, who will
receive and respond to grievances, when grievances are referred to higher levels, and how
grievances are ideally resolved. It is anticipated that the grievance mechanism will contain
procedures for addressing grievances at different levels, including at boma, payam, county,
state and national level with multiple lines of reporting and special attention to grievance
channels for vulnerable groups. Given the low level of literacy in RoSS, it is anticipated that
grievances can be put forward both in writing and orally.
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Annex A - Literature
"Climate Change and Conflict - Lessons for Conflict Resolution from the Southern Sahel of
Sudan", African Centre for the Constructive Resolution of Disputes (ACCORD), South
Africa, 2011
"A climate Trend Analysis of Sudan", June 2011, FEWSNET.
"Draft South Sudan National Environment Policy", Government of the Republic of South
Sudan, 2011
"The Land Act", Government of South Sudan, 2009
"Environmental Impacts, Risks and Opportunities Assessment", Ministry of Environment and
UNDP, July 16, 2011.
"South Sudan - Food security and land governance factsheet", Thea Hilhorst and Nicolas
Porchet, Royal Tropical Institute, Amsterdam, The Netherlands, 2012
(www.landgovernance.org)
"South Sudan's future: now for the hard part", The Economist, February 3, 2011
"Sudan Hand Book", Rift Valley Institute, London, United Kingdom, 2011
"Transitional Constitution of the Republic of South Sudan", 2011
"South Sudan Development Plan 2011-2013", Government of the Republic of South Sudan,
Juba, August 2011.
"The Joint Baseline Survey Report on the Agriculture and Animal Resources in Southern
Sudan", GRSS/FAO, October 2010
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Annex B - List of people consulted
The table below provides details of the people consulted. The date indicated is the date of the
first meetings, subsequent meetings are not recorded.
Table B.1: List of people consulted
Name
Position
Gorm Pedersen
Consultant
Karin Erikssen
Danida
Varalakshmi Vermuru Senior Social Development
Specialist
Bedilu Amare Reta
Environmental Specialist
Peter McCanny
Country Director
Paul L. Demetry
Acting Under
Secretary/Environmental Officer
Camilla Winther
Emergency Program Manager
Kragelund
Nina Petersen
Civil Society Advisor
Signe Atim Allimadi Senior Gender Advisor
Christianne Kivy
Advisor Civil Society
Peter Lilford
PFM and CB Adviser
Louis Helling
External Consultant
Johannes Wollf
Institutional Development Expert
Martin Maceik
Director Planning and Training
Sworo Yopesi
Assistant Emergency Coordinator
Melissa Brill
Deputy Country Director
Dina Parmer
Conflict and Policy Advisor
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Organization
Danida
Danish Ministry of Foreign
Affairs
World Bank
Date
24/10-12
25/10-12
World Bank
IBIS
Ministry of Environment
27/10-12
27/10-12
29/10-12
Danish Refugee Council
29/10-12
Norwegian Peoples Aid
Joint Donor Team
Joint Donor Team
Joint Donor Team
World Bank
UNDP
Local Government Board
FAO
PACT
PACT
29/10-12
30/10-12
30/10-12
30/10-12
30/10-12
30/10-12
30/10-12
31/10-12
31/10-12
31/10-12
27/10-12
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Annex C - Checklist for screening of subprojects
Subproject identification
Subproject title
Description of activity
State
Boma/community
Facilitating partner
Subproject
Construction or
rehabilitation of
physical structures
Use and maintenance
of schools
Use and maintenance
of health facilities
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Subproject code
County
Payam
Location GPS coordinates
Date
Will the subproject potentially have any of the following impacts
(please mark next to the relevant potential impact)
 Loss of vegetation cover causing erosion of soil and siltation of rivers and wetlands
 Dumping of construction debris in wetlands or other sensitive areas
 Use of limited or sensitively located local construction materials such as aggregate and
wood
 Dust pollution due to movement of equipment, digging
 Noise pollution due to use of equipment
 Pollution of ground water due to oil and fuel spills and exposure of ground water table
 Pollution of surface water due to oil spills
 Occupational health and safety due to hazards from handling of equipment
 Contamination of groundwater due to inappropriate location of accompanying latrines
 Chance find of physical cultural resources
 Health hazards due to inadequate cleaning and maintenance of school latrines
 Safety hazards due to collapsing latrine pits
 Privacy concerns and sexual violence due to lack of gender separated school latrines
 Health hazard due to stagnant water at school water points acting as breeding ground for
malaria carrying mosquitoes and other vector-borne diseases
 Health hazards caused by inadequate storage and disposal of medical and other wastes
 Health hazards due to inadequate cleaning and maintenance of latrines
 Safety hazards due to collapsing latrine pits
 Health hazard due to stagnant water at water points acting as breeding ground for malaria
carrying mosquitoes and other vector-borne diseases
Yes No If yes, please describe
mitigating measures
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Subproject
Will the subproject potentially have any of the following impacts
(please mark next to the relevant potential impact)
Use and maintenance  Pollution of soil and water resources due to inappropriate collection and disposal of
of markets
market refuse and waste
 Noise pollution from movement of trucks etc. carrying market goods.
 Health hazards due to poor storage of market goods providing breeding grounds for
disease carrying rodents and vectors.
 Health hazards due to inadequate cleaning and maintenance of latrines
 Safety hazards due to collapsing latrine pits
 Privacy concerns and sexual violence due to lack of gender separated latrines
 Health hazard due to stagnant water at water points acting as breeding ground for malaria
carrying mosquitoes and other vector-borne diseases
Construction or
 Stemming of water flow during construction of bridges causing water shortage, change of
rehabilitation of roads
water course, etc. downstream
and bridges
Use and maintenance  Dust and noise pollution due to movement of vehicles etc
of roads and bridges
 Erosion during rain due to drainage
 Safety concerns due to speeding vehicles
 Pot holes with stagnant water providing breeding ground for disease-carrying vectors
 Bridges causing changes in water flow causing flooding, erosion or siltation
Construction or
 Contaminated water due to a proximity of latrines and waste disposal sites
rehabilitation of water
facilities, e.g. drilling
and installation of
hand pumps
Use and maintenance  Lowering of water table
of water facilities
 Health hazard due to stagnant water at water points acting as breeding ground for malaria
carrying mosquitoes and other vector-borne diseases
 Health hazard due to bacteriological contamination of water
 Health hazard due to poisonous substances in ground water, e.g. arsenic, fluoride
Construction or
 Contamination of groundwater due to inappropriate location of latrines
rehabilitation of
sanitation facilities
Use and maintenance  Health hazards due to inadequate cleaning and maintenance of latrines
of sanitation facilities  Safety hazards due to collapsing latrine pits
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Subproject
Will the subproject potentially have any of the following impacts
(please mark next to the relevant potential impact)
 Privacy concerns and sexual violence due to lack of gender separated latrines
Construction of flood
protection
infrastructure
Construction or
rehabilitation of
livestock dips
 Maintenance of latrines
 Stemming of water flow during construction., change of water course, etc. downstream
Use and maintenance
of livestock dips
 Health hazards due to unsafe storage and use of chemicals
 Health hazards due to unsafe disposal of expired chemicals and empty containers
Yes No If yes, please describe
mitigating measures
 Contamination of groundwater due to inappropriate location of livestock dips
 Pollution of soil and groundwater due to spillage
 Erosion of nearby areas due to (temporary) high density of livestock
 Stemming of water flow during construction., change of water course, etc. downstream
Construction or
rehabilitation of smallscale irrigation
schemes
Use and maintenance  Over-use of water deprives downstream communities access to water
of small-scale
irrigation schemes
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Annex D - List of subproject that are not eligible for funding
Subproject that are not eligible for funding
Subprojects that require acquisition of land
Subprojects that will block the access to or use of land, water points etc. used by others
Subprojects that will construct or rehabilitate education or health facilities if relevant staff is not
already present.
Subprojects that encroach onto an important natural habitat ( e.g., wildlife reserves; ecologicallysensitive ecosystems; parks or sanctuaries; protected areas; natural habitat areas, forests and forest
reserves, wetlands, national parks or game reserve; any other environmentally sensitive areas)
Subprojects that will impact on physical cultural resources (archaeological sites; religious
monuments or structures; natural sites with cultural values; cemeteries; graveyards; graves; and
other sites of significance)
Subproject that will negatively affect ecologically sensitive ecosystems
Subprojects in protected areas
Subprojects that does not equally benefit all members of the community, including vulnerable and
minority groups
Any subproject for which benefits or use will mainly benefit a few
Agricultural projects requiring purchase of pesticides
Sub projects involving the use of hazardous substances
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Annex E - Procedures for chance find of physical cultural
resources
The below will be annexed to the contract in case there is the possibility of chance find of
physical cultural resources, i.e. in most instances of construction or rehabilitation of
infrastructures such as health, education, water and sanitation facilities etc.
Annex to contracts in case of potential chance find of physical cultural resources
If the Contractor discovers archaeological sites, historical sites, remains and objects, including
graveyards and/or individual graves during excavation or construction, the Contractor shall:
1: Excavation in sites of known archaeological interest should be avoided and as stated in
annex D, such subprojects are not eligible for funding. Where historical remains, antiquity
or any other object of cultural, historical or archaeological importance (including
graveyards) are unexpectedly discovered during construction in an area not previously
known for its archaeological interest, the following procedures should be applied:
a) Stop the construction activities in the area of the chance find.
b) Delineate the discovered area.
c) Secure the area to prevent any damage or loss of removable objects. In cases of
removable antiquities or sensitive remains, a night guard shall be present until the
responsible local authorities and the Ministry of Culture, Youth and Sports take over.
d) Notify the supervisory Engineer who in turn will notify the county safeguard focal point
to contact the responsible local authorities and the Ministry of Culture, Youth and
Sports immediately (less than 24 hours).
e) The Ministry of Culture, Youth and Sports will be in charge of protecting and
preserving the area until deciding on the proper procedures to be carried out. This might
require an evaluation of the findings to be performed by the archaeologists of the
relevant Ministry Culture, Youth and Sports (within 1 week). The evaluation of the
findings will take in consideration various criteria relevant to cultural heritage,
including the aesthetic, historic, scientific or research, social and economic values as
decided by the Ministry of Culture, Youth and Sports.
f) Decisions on how to handle the finding be taken by the responsible authorities and the
Ministry of Culture, Youth and Sports (within 2 weeks). This could include changes in
the location of the subproject layout (such as when the finding is an irremovable remain
of cultural or archaeological importance), conservation, preservation, restoration and
salvage.
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g) Construction or rehabilitation work will resume only after authorization is provided by
the responsible local authorities and the Ministry of Culture, Youth and Sports
concerning the safeguard of the heritage.
h) Authorization to resume work shall be communicated to the contractor in writing by the
Ministry of Culture, Youth and Sports.
2: In case of delays incurred in direct relation to any physical cultural resources findings not
stipulated in the contract (and affecting the overall schedule of works), the contractor may
apply for an extension of time. However the contractor will not be entitled to any kind of
compensation or claim other than what is directly related to the execution of the physical
cultural resources findings works and protections.
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Annex F - Form for appraisal of subproject
Completeness of subproject application:
Subproject identification
Subproject title
State
Boma/community
Facilitating partner
Subproject code
County
Payam
Location GPS coordinates
Date
Check if subproject is on list of subprojects that are not eligible for funding
Yes
Is the subproject on the list of subproject that can not be approved
If the answer is yes, please reject the application without further appraisal
No
Completeness of subproject application
Does the project contain as appropriate the following information
Yes No N/A
Description of the proposed subproject and its location
Reasons for proposing the project
Budget for construction and operation
Information about how the site was chosen, and what alternatives were considered
Map or drawing showing the location and boundary of the project, including land
required temporarily during construction
Plan for physical works (layout, buildings, construction materials, etc)
Any new access arrangements or changes to existing road layouts, water sources,
etc.
Description of the present ownership of the land
Description of who lives on/uses the land at present
Proof for voluntary donation of land for the subproject
Proof that the land is free of encumbrances
Work programme for construction, operation and decommissioning of physical
work as well as any site restoration needed afterwards
Description of construction methods
Resources used in construction and operation (e.g. materials, water, energy)
Information about mitigating measures included in the implementation of the
subproject to avoid or minimize environmental and social impacts
Details of any permits required for the project
If the answer to any of the above is no, please return the application with a request for the relevant
additional information to be provided
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Environmental and Social Checklist
Will the subproject
Yes
No
Construct or rehabilitate and structures or buildings
Support irrigation schemes
Support water supply schemes
Support sanitation schemes
Construct or rehabilitate roads, bridges, culverts, etc
Construct or rehabilitate flood protection structures
If the answer to any of the above questions is "Yes", please use table 7.1 in the ESMF document for
guidance on how to avoid or minimize typical impacts
Environmental Management Plan Checklist
Will the subproject
Risk causing pollution of water resources
Require significant natural resources, i.e. wood, or water
Create a risk of soil erosion or pollution
Produce dangerous waste, e.g. medical waste
Affect the flow or quantity of water resources (wetlands, rivers, ground water, etc)
If the answer to any of the above questions is "Yes", please submit an
Environmental Management Plan (EMP) with the subproject application
Yes
No
Certification:
We certify that we have thoroughly examined all the potential adverse effects of this
subproject. To the best of our knowledge, the subproject plan as described in the application
and associated planning reports (EMP), if any, will be adequate to avoid or minimize all
adverse environmental and social impacts.
Community representative (signature): ______________________
Facilitating partner (signature): _______________________
Date: ____________________
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Desk appraisal by review authority
The subproject can be considered for approval. The application is complete, all
significant environmental and social issues are resolved, and no further subproject
planning is required.
A field appraisal is required.




Note: A field appraisal must be carried out if the subproject:
Need land
May affect a protected area or a critical natural habitat
May encroach onto an important natural habitat, or have an impact on ecologically
sensitive ecosystems (e.g. rivers, streams, wetlands)
Involves, or results in:
 diversion or use of surface waters;
 construction or rehabilitation of latrines, septic or sewage systems;
 production of waste (e.g. medical waste, medical waste);
 new or rebuilt irrigation or drainage systems; or
 small dams, weirs, reservoirs or water points.
The following issues need to be clarified at the subproject site:
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
A field appraisal report has been completed and added to the subproject file.
Name of desk appraisal officer (print): _____________________________
Date: ________________ Signature: ______________________________
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Annex G - Form for field appraisal
Subproject identification
Subproject title
State
Boma/community
Date of field visit
Reason for field
appraisal (from
appraisal form)
Field appraisal
team members
(county safeguard
focal point,
community
representative,
facilitating partner
representative,
others)
Subproject code
County
Payam
Location GPS coordinates
Date
Subproject description
Provide details that are not
adequately presented in the
subproject application. If
needed to clarify subproject
details, attach sketches of
the subproject in relation to
the community and to
existing facilities
Date
Environmental Management Plan Checklist
Will the subproject
Yes
Risk causing pollution of water resources
Require significant natural resources, i.e. wood, or water
Create a risk of soil erosion or pollution
Produce dangerous waste, e.g. medical waste
Affect the flow or quantity of water resources (wetlands, rivers, ground water, etc)
If the answer to any of the above questions is "Yes", please indicate if the Environmental
Management Plan (EMP) submitted with the subproject application (tick on of the below)
The EMP is adequate, no further action required
The EMP included with the subproject application must be improved before the application
can be considered further
An EMP must be prepared and approved before the application can be considered further
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Tick
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Mitigating measures Checklist
Will the subproject
Yes
Risk causing pollution of water resources
Require significant natural resources, i.e. wood, or water
Create a risk of soil erosion or pollution
Produce dangerous waste, e.g. medical waste
Affect the flow or quantity of water resources (wetlands, rivers, ground water, etc)
If the answer to any of the above questions is "Yes", please tick one of the below
The application describes suitable mitigating measures for managing the potential adverse
environmental effects of these activities. No further action is required
The application does not describe suitable measures for managing the potential adverse
environmental effects of these activities. An Environmental Management Plan must be
prepared and approved before the application is considered further
No
Tick
Other environmental or social impacts
Describe any other environmental or social impacts that have not been adequately addressed above
If there are any other answer to any other impacts, please tick one of the below
Tick
Before the subproject application is considered further, the application needs to be amended
to include suitable measures for addressing these.
An Environmental Management Plan needs to be prepared and approved before the subproject
application is considered further
Field Appraisal Decision
The subproject can be considered for approval. Based on a site appraisal and
consultations with interested and affected parties, the field appraisal determined that
the communities and its proposed subproject adequately address environmental and
social impacts as required by the LGSDP' ESMF.
Further subproject preparation is required before the subproject application can be
considered further.
The field appraisal mission has identified environmental or social impacts that have
not been adequately addressed. The following work needs to be undertaken before
further consideration of the application
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
All required documentation such as an amended application or EMP will be added to
the subproject file before the subproject is considered further.
Name of field appraisal officer (print): _____________________________
Date: ________________ Signature: ______________________________
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Annex H Format for Documenting Voluntary Land Donation by
Individual for Subprojects
The following agreement has been made on............................ day of...................……….
between ..............................................., resident of ............................................(the
Owner) and ……………………………………………….(the Recipient).
1. That the Owner holds the transferable right of the land/structure/other asset located at
........................…………………………………………………………………………….
2. That the Owner testifies that the land/structure is free of squatters or encroachers and not
subject to other claims.
3. That the Owner hereby grants to the Recipient this asset for the construction and development
of ............................................for the benefit of the villagers and the public at large.
4. That the Owner will not claim any compensation against the grant of this asset.
5. That the Recipient agrees to accept this grant of asset for the purposes mentioned.
6. That the Recipient shall construct and develop the ……………………………and take all
possible precautions to avoid damage to adjacent land/structure/other assets.
7. That both parties agree that the…………………………………so constructed/developed shall
be public premises.
8. That the provisions of this agreement will come into force from the date of signing of this
deed.
__________________________________
_______________________________
Signature of the Owner
Signature of the Recipient
Witnesses:
1.
_____________________________________________________________
2.
_____________________________________________________________
(Signature, name and address)
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Annex I - Template safeguards procedures for contracts
1. General
1.a
The Contractor and his employees shall adhere to the mitigation measures set out in the
environmental management plan (EMP) and take all other measures required by the
Engineer to prevent harm, and to minimize the impact of his operations on the social
and natural environment.
1.b
The Contractor shall not be permitted to unnecessarily strip clear the right of way. The
Contractor shall only clear the minimum width for construction and diversion roads
should not be constructed alongside the existing road.
1.c
Remedial actions, which cannot be effectively carried out during construction, should
be carried out on completion of each Section of the road (earthworks, pavement and
drainage) and before issuance of the Taking over certificate:
(a) These sections should be landscaped and any necessary remedial works should be
undertaken without delay, including grassing and reforestation;
(b) Water courses should be cleared of debris and drains and culverts checked for clear
flow paths; and
(c) Borrow pits should be reclaimed, dressed as fish ponds, or drained and made safe,
as agreed with the land owner.
1.d
The Contractor shall limit construction works to between 6 am and 7 pm if it is to be
carried out in or near residential areas.
1.e
The Contractor shall avoid the use of heavy or noisy equipment in specified areas at
night, or in sensitive areas such as near a schools, health centres and hospital.
1.f
To prevent dust pollution during dry periods, the Contractor shall carry out regular
watering of earth and gravel haul roads and shall cover material haulage trucks with
tarpaulins to prevent spillage.
2. Transport
2.a
The Contractor shall use selected routes to the project site, as agreed with the Engineer,
and appropriately sized vehicles suitable to the class of road, and shall restrict loads to
prevent damage to roads and bridges used for transportation purposes. The Contractor
shall be held responsible for any damage caused to the roads and bridges due to the
transportation of excessive loads, and shall be required to repair such damage to the
approval of the Engineer.
2.b
The Contractor shall not use any vehicles, either on or off road with grossly excessive,
exhaust or noise emissions. In any built up areas, noise mufflers shall be installed and
maintained in good condition on all motorized equipment under the control of the
Contractor.
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2.c
Adequate traffic control measures shall be maintained by the Contractor throughout the
duration of the Contract and such measures shall be subject to prior approval of the
Engineer.
3. Workforce
3.a
The Contractor should whenever possible locally recruit the majority of the workforce
and shall provide appropriate training as necessary.
3.b
The Contractor shall install and maintain a temporary septic tank system for any
residential labour camp and without causing pollution of nearby watercourses.
3.c
The Contractor shall establish a method and system for storing and disposing of all
solid wastes generated by the labour camp and/or base camp.
3.e
The Contractor shall not allow the use of fuel wood for cooking or heating in any labor
camp or base camp and provide alternate facilities using other fuels.
3.f
The Contractor shall ensure that site offices, depots, asphalt plants and workshops are
located in appropriate areas as approved by the Engineer and not within 500 meters of
existing residential settlements and not within 1,000 meters for asphalt plants.
3.g
The Contractor shall ensure that site offices, depots and particularly storage areas for
diesel fuel and bitumen and asphalt plants are not located within 500 meters of
watercourses, and are operated so that no pollutants enter watercourses, either overland
or through groundwater seepage, especially during periods of rain. This will require
lubricants to be recycled and a ditch to be constructed around the area with an approved
settling pond/oil trap at the outlet.
3.h
The contractor shall not use fuel wood as a means of heating during the processing or
preparation of any materials forming part of the Works.
4. Quarries and Borrow Pits
4.a
Operation of a new borrow area, on land, in a river, or in an existing area, shall be
subject to prior approval of the Engineer, and the operation shall cease if so instructed
by the Engineer. Borrow pits shall be prohibited where they might interfere with the
natural or designed drainage patterns. River locations shall be prohibited if they might
undermine or damage the river banks, or carry too much fine material downstream.
4.b
The Contractor shall ensure that all borrow pits used are left in a trim and tidy condition
with stable side slopes, and are drained ensuring that no stagnant water bodies are
created which could breed mosquitoes.
4.c
Rock or gravel taken from a river shall be far enough removed to limit the depth of
material removed to one-tenth of the width of the river at any one location, and not to
disrupt the river flow, or damage or undermine the river banks.
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4.d
The location of crushing plants shall be subject to the approval of the Engineer, and not
be close to environmentally sensitive areas or to existing residential settlements, and
shall be operated with approved fitted dust control devices.
5. Earthworks
5.a
Earthworks shall be properly controlled, especially during the rainy season.
5.b
The Contractor shall maintain stable cut and fill slopes at all times and cause the least
possible disturbance to areas outside the prescribed limits of the work.
5.c
The Contractor shall complete cut and fill operations to final cross-sections at any one
location as soon as possible and preferably in one continuous operation to avoid
partially completed earthworks, especially during the rainy season.
5.d
In order to protect any cut or fill slopes from erosion, in accordance with the drawings,
cut off drains and toe-drains shall be provided at the top and bottom of slopes and be
planted with grass or other plant cover. Cut off drains should be provided above high
cuts to minimize water runoff and slope erosion.
5.e
Any excavated cut or unsuitable material shall be disposed of in designated tipping
areas as agreed to by the Engineer.
5.f
Tips should not be located where they can cause future slides, interfere with agricultural
land or any other properties, or cause soil from the dump to be washed into any
watercourse. Drains may need to be dug within and around the tips, as directed by the
Engineer.
6. Disposal of Construction and Vehicle Waste
6.a
Debris generated due to the dismantling of the existing structures shall be suitably
reused, to the extent feasible, in the proposed construction (e.g. as fill materials for
embankments). The disposal of remaining debris shall be carried out only at sites
identified and approved by the project engineer. The contractor should ensure that these
sites (a) are not located within designated forest areas; (b) do not impact natural
drainage courses; and (c) do not impact endangered/rare flora. Under no circumstances
shall the contractor dispose of any material in environmentally sensitive areas.
6.b
In the event any debris or silt from the sites is deposited on adjacent land, the
Contractor shall immediately remove such, debris or silt and restore the affected area to
its original state to the satisfaction of the Supervisor/Engineer.
6.c
Bentonite slurry or similar debris generated from pile driving or other construction
activities shall be disposed of to avoid overflow into the surface water bodies or form
mud puddles in the area.
6.d
All arrangements for transportation during construction including provision,
maintenance, dismantling and clearing debris, where necessary, will be considered
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incidental to the work and should be planned and implemented by the contractor as
approved and directed by the Engineer.
6.e
Vehicle/machinery and equipment operations, maintenance and refuelling shall be
carried out to avoid spillage of fuels and lubricants and ground contamination. An oil
interceptor will be provided for wash down and refuelling areas. Fuel storage shall be
located in proper bounded areas.
6.f
All spills and collected petroleum products shall be disposed of in accordance with
standard environmental procedures/guidelines. Fuel storage and refilling areas shall be
located at least 300m from all cross drainage structures and important water bodies or
as directed by the Engineer.
Annex J - ESMF reporting form
This annex contains three templates to be used in conjunction with monitoring and reporting
on ESMF implementation.
Table J.1: ESMF reporting form
Subproject Subproject Application Field appraisal
title
code
received
undertaken
(date)
(date if
undertaken)
Table J.2: ESMF training form
Personnel
No. of people trained
Safeguard specialist/officer
State focal points
County focal points
Payam staff
Community members etc.
Table J.3: Follow up on previous recommendations
Date of
Recommendation recommendation Action taken
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Application EMP
Written
approved developed warnings of
(date if
(yes or no) violation of
approved)
EMP issued
(yes/no)
Chance find
procedures
invoked (yes
or no)
Training received
Recommendation
implemented (yes/no)
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Annex K - Guidelines for annual reviews
Objectives:
The objectives of annual reviews of ESMF implementation are two-fold:
a) To assess LGSDP performance in complying with ESMF procedures, learn lessons, and
improve future performance; and
b) To assess the occurrence of, and potential for, cumulative impacts due to the LGSDP
subprojects
The LGSDP management is expected to use the annual reviews to improve on procedures and
capacity for integrating natural resources and environmental/social management into LGSDP
operations. They will also be a principal source of information to Bank supervision missions.
Scope of Work:
ESMF Performance Assessment
The overall scope of the performance assessment work is to:
a) Assess the adequacy of the subproject approval process and procedures based on interviews
with Project participants, Project records, and the environmental and social performance of a
sample of approved subprojects;
b) Assess the adequacy of ESMF roles and responsibilities, procedures, forms, information
resource materials, etc.;
c) Assess the needs for further training and capacity building;
d) Identify key risks to the environmental and social sustainability of subprojects; and
e) Recommend appropriate measures for improving ESMF performance.
The following tasks will be typical:
a) Review central and district records of subproject preparation and approval (e.g. applications;
management in the country; screening checklists; EMPs, appraisal forms; approval
documents), as well as related studies or reports on wider issues of natural resources and
environmental management in the country
b) On the basis of this review, conduct field visits of a sample of approved subprojects to assess
the completeness of planning and implementation work, the adequacy of environmental/social
design, and compliance with proposed mitigation measures. The sample should be large
enough to be representative and include a substantial proportion of subprojects that had (or
should have had) a field appraisal according to established ESMF criteria. Subprojects in
sensitive natural or social environments should especially be included.
c) Interview LGSDP and county officials responsible for subproject appraisal and approval to
determine their experience with ESMF implementation, their views on the strengths and
weaknesses of the ESMF process, and what should be done to improve performance.
Improvements may concern, for example, the process itself, the available tools (e.g.
guidelines, forms, information sheets), the extent and kind of training available, and the
amount of financial resources available.
d) Develop recommendations for improving ESMF performance.
Cumulative Impacts Assessment
This part of the annual review assesses the actual or potential cumulative impacts of subprojects
with other subprojects or development initiatives on the environment, natural resources and
community groups. Cumulative impacts result from a number of individual small-scale activities
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that, on their own, have minimal impacts, but over time and in combination generate a significant
impact. For example:
a) Deforestation due to the overharvesting of poles and timber for small-scale construction;
b) Decline in groundwater levels or quality due to the construction of numerous wells and the
introduction of numerous small scale irrigation works;
c) Overwhelmed or illegal waste and dumping sites due to the inappropriate disposal of
increasing amounts of waste materials;
d) Illegal poaching of wildlife due to expansion of land under cultivation or increased proximity
and access to protected areas through construction of small access roads; and
e) Attraction of large migrant populations to communities that have successfully introduced
improved social infrastructure (such as schools, health facilities or water sources) resulting in
overcrowding, depletion of resources (e.g. space, supplies, water), etc.
The function of this assessment is primarily as an "early warning" system for potential cumulative
impacts that might otherwise go undetected and unattended to. It will be largely based on the
observations of people interviewed during the fieldwork, and trends that may be noticed by
county or state officials. Where cumulative impacts are detected or suspected, recommendations
will be made to address the issue, perhaps through more detailed study to clarify matters and what
should or can be done about them.
Qualifications for Undertaking Annual Reviews:
The annual reviews shall be undertaken by an individual, or small team, with experience relevant
to the likely issues to be encountered (e.g. environmental and natural resources management, land
acquisition and resettlement, indigenous peoples). They should also be familiar with the methods
and practices of effective community consultation, and with typical methods and processes for
preparing, appraising, approving and implementing small-scale community development projects.
Timing:
Annual reviews should be undertaken after the annual ESMF report has been prepared and before
WB supervision of the Project, at the closing of each year of the LGSDP. It is expected that each
review would require 4 to 5 weeks of work (interviews, examination of subprojects), and that the
review report would be completed within 2 weeks of completing the fieldwork.
Outputs:
The principal output is an annual review report that documents the review methodology,
summarizes the results, and provides practical recommendations. Distinct sections should address;
a) ESMF performance and
b) Cumulative impacts.
Annexes should provide the detailed results of the fieldwork, arid summarize the number of
approved subprojects by state and their characteristics according to the annual report format.
Copies of the annual review report should be delivered to the LGSDP management, to each state
and county office responsible for appraisal, approval and implementation of subprojects, and to
the World Bank. LGSDP management (central or state) may also want to host national or state
workshops to review and discuss the review findings and recommendations.
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Annex L: Template for Environmental Management Plan (EMP)
ENVIRONMENTAL MANAGEMENT PLAN
Subproject identification
Subproject code
County
Payam
Location GPS coordinates
Subproject title
State
Boma/community
a) Environmental Management Plan-Mitigation
Mitigation
Measures
Institutional
Potential
(incl.
Responsibilities
Environmental
legislation &
(incl. enforcement
Impacts
regulations)
and coordination)
Cost Estimates
Project Phase
Comments
(e.g.
secondary
impacts)
Construction Phase
Operation and maintenance phase
ii)
Project phase
Mitigation
Measures
Environmental Management Plan-Monitoring
Measurements
(incl. methods and
Frequency of
Responsibilities (incl.
Location equipment)
measurement
review and Reporting
Cost
(equipment &
individuals)
Construction
Phase
Operation and
maintenance
phase
Total cost for all
phases
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