AFRICAN DEVELOPMENT BANK

MULTINATIONAL

EAST AFRICAN SUBMARINE CABLE SYSTEM (EASSy) PROJECT

EXECUTIVE SUMMARY OF THE ENVIRONMENTAL SOCIAL IMPACT ASSESSMENT (ESIA)

May 2007

TABLE OF CONTENTS

Page

1. INTRODUCTION ................................................................................................................... 1

2. PROJECT DESCRIPTION .................................................................................................... 1

3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK......................................... 1

4. PROJECT ALTERNATIVES............................................................................................... 2

5. DESCRPTION OF PROJECT ENVIRONMENT ............................................................... 2

PROJECT SETTING........................................................................................................................... 2 SENSITIVE ENVIRONMENT ALONG THE EASSY ROUTE................................................................... 3 PROTECTED AREAS ALONG OR NEAR THE EASSY ROUTE ............................................................. 4 PROTECTED/ ENDANGERED SPECIES............................................................................................... 4 SUMMARY OF IN COUNTRY CONDITIONS ........................................................................................ 5

6. POTENTIAL IMPACTS....................................................................................................... 7

ENVIRONMENTAL IMPACTS ............................................................................................................ 7 SOCIAL IMPACTS ............................................................................................................................ 8 POSITIVE IMPACTS.......................................................................................................................... 9

7. IMPACT MITIGATION..................................................................................................... 10

MITIGATION IN THE OPEN SEA ..................................................................................................... 10 IMPACT SCALE.............................................................................................................................. 12 MITIGATION FOR COASTAL IMPACTS............................................................................................ 12 MITIGATION FOR NATIONAL IMPACTS.......................................................................................... 12

8. PUBLIC CONSULTATIONS............................................................................................... 14

9. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) ......................... 14

UMBRELLA ESMP........................................................................................................................ 14 NATIONAL ESMP......................................................................................................................... 15 SHALLOW WATER CABLE LAYING................................................................................................. 15

10. CONCLUSIONS .................................................................................................................. 16

LIST OF ACRONYMS

AEWA African-Eurasian Migratory Waterbirds BMH Beach Man Hole C&MA Construction and Maintenance Agreement CMS Convention on Migratory Species

EAP Environmental Action Plan EASSy East African Submarine Cable System EPCM Engineering, Procurement, Construction, Management ESIA Environment and Social Impact Assessment ESMP Environmental and Social Management Plan GDP Gross Domestic Product ICT Information and Communication Technologies LSA Local Study Area nESIA national Environmental Impacts Assessment NGO Non-Governmental Organization SAFE South Africa Far East cable system TOR Terms of Reference

Figure :The proposed EASSy Telecommunication Network

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1. INTRODUCTION 1.1 This document contains a summary of the Environmental and Social Impacts Assessment

(ESIA) for the proposed East African Submarine Cable System (EASSy) submarine cable project. The ESIA Report was prepared and finalized by the Earth Science & Survey (EGS) in February 2007. The ESIA Summary is prepared in accordance with the African Development Bank’s 2001 Environmental & Social Impacts Assessment Procedures (ESAP). The summary will be posted on the Bank’s website and also distributed to the Bank’s Boards in at least 60 days prior to presenting the investment proposal for Board approval to comply with the Bank’s Information disclosure and public consultation requirements. As part of the ESIA, visits were made to all the participating countries except Somalia between 1st and 21st November 2006. Meetings were held with the Somalia EIA consultant to ascertain conditions in Mogadishu. An Environmental and Social Management Plan (ESMP) has been developed to monitor compliance with the required Standards during installation, maintenance and decommissioning of the EASSy cable system.

2. PROJECT DESCRIPTION

2.1 In the past most African countries’ telecommunication carriers heavily relied on radio or satellite system to carry the bulk of their international traffic. With the advent of optical fiber cable systems and the inherent quality and increased bandwidth that they provide, carriers have switched to submarine cables as their primary communication medium. Currently, Eastern Africa lacks a fiber optic cable system and has to rely exclusively on satellite links for voice and data transmission at about ten times the cost and transmission speeds of less than a quarter of those of fiber optic links. The EASSy project is therefore an optimum means to improve the communication sector in the region, allowing more people to access at the same time and at cheaper rates. The EASSy project involves laying of approximately 9,900km of submarine communication cable (Figure 1), from South Africa to Sudan, with connecting cables from trunk route to landing points in Mozambique, Madagascar, Tanzania, Kenya, Somalia and Djibouti.

2.2 The EASSy backbone transmission network will consist of a submarine fiber cable and state-of-

the-art transmission technology. The network will facilitate transmission of voice, data of various bandwidths, Internet and television signals. Of particular significance is the fact that the network will facilitate inter-country transmission thereby reducing and to a large extent eliminating the need to transit via third countries outside the region for country to country communication and information exchange. The configuration extends from Mtunzini (South Africa) northward through the Indian Ocean and the Red Sea to Port Sudan. As shown in Figure 1. EASSy will allow closing of the ring of submarine fiber optic cables around the African continent and will allow EASSy to integrate into the global backbone network of existing submarine cable systems.

3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

3.1 The financing of the EASSy project is under consideration by the various Development Financial Institutions (DFIs) and the Bank. The EASSy ESIA study was carried out with in accordance with the Environmental Policy, Procedures and Guidelines of the DFIs and the Bank, which are typified by International Finance Corporation (IFC) Performance Standards

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PS1 to PS8. The ESIA also conform with the African Development Bank’s Environmental and Social Assessment Procedures (ESAP, 2001). The ESIAs for the near shore and the onshore portion also conform to the national regulations of countries in which the landing points are situated.

4. PROJECT ALTERNATIVES

4.1 Many of the countries along the EASSy system currently rely on terrestrial cable, satellite and microwave links for their data and communication transmissions. Without fibre optic connections to the rest of the world, internet services will remain slow and expensive, hampering the integration of the region into the global economy. In principle, land based fibre optic cables offer an alternative to the proposed EASSy system for parts of the configuration, though clearly not for connections to Madagascar. In practice, it has been found that the installation costs are higher for terrestrial systems, permitting is complex and time consuming, and cable faults are more frequent. In addition to these practical and security issues, there are also clearly potential environmental and social impacts associated with terrestrial cable burial and the microwave and radio link alternatives for a system of several thousand km. Thus a marine optical fibre system offers the best practical alternative for a substantial increase in bandwidth at the present time.

5. DESCRPTION OF PROJECT ENVIRONMENT

Project Setting 5.1 Geography: The project spans an area from around 29°S to 20°N, with onshore habitats ranging

from Savannah through semi-arid coastal regions and tropical rain forest. Offshore, the route heads northwards from Mtunzini in South Africa up the coast of East Africa to pass through the Mozambique Channel separating Madagascar from the mainland before heading northeast round the Horn of Africa and the island of Socotra to enter the Gulf of Aden. It travels west along the Gulf of Aden to enter the Red Sea through the Straits of Bab el-Mandeb and then north to Port Sudan in Sudan. Spurs join this trunk route to landing points at Maputo in Mozambique, Toliary in Madagascar, Dar es Salaam in Tanzania, Mombasa in Kenya, Mogadishu in Somalia and Djibouti town in Djibouti. Water depths range from zero at the Landing Points to over 5000m on the Abyssal Plains offshore of Somalia.

5.2 Geology: The regional geology of Southern and East Africa, including South Africa,

Mozambique, Tanzania, Madagascar and Kenya, comprises ancient crystalline rocks mostly covered by unconsolidated recent sediments along the coast. The entire Southern and East African coastal plain has essentially been “sculptured” by sea level changes over the last million years. Of particular importance to the coastal plain and continental shelf was the Last Glacial Maximum low sea level stand (approximately 130m below present), about 18,000 years ago. These sea level changes have resulted in the formation of narrow bands of rock outcrop (“beachrock” and lithified dune sequences) that follow palaeo-coastlines. Some are found onshore, but the vast majority are located in 0 to 100m water depth offshore. These rocks often provide the base for coral reef formation. The geology of the Red Sea and Gulf of Aden is

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characterized by the rifting caused by the movement of Africa away from the Arabian Peninsula. Coastal sediments tend to be of Quaternary age (< 1million years).

5.3 Oceanography: The main oceanography characteristics are: Strong currents associated with the

Agulhas Current, in the order of 3-4 knots, flow in a southerly direction may hamper both survey and installation; The presence of sandwaves, sediment abrasion and cable “strumming” may be associated with strong currents; Strong tidal currents will be experienced on the inshore approaches to Maputo due to the macro-tidal regime; Swell dominated coastline at Mtunzini; Extreme waves are associated with Cyclones; and Elevated salinities (>40ppt) and temperatures within the Red Sea.

5.4 Meteorology: The climate of east Africa varies from moist sub-tropical in the south (South

Africa) through to tropical (Mozambique, Madagascar, Tanzania, Kenya). Northern parts of the route, in countries bordering the Red Sea, Gulf of Aden and Arabian Sea, are typically very dry.

5.5 Biological Environment: The Eastern African region is a unique environment, including

extensive coral reefs, beaches and mangrove forests. Those coastal and marine environments are home to a rich diversity of marine creatures, many endemic to the tropical world and protected. In the absence of environmentally conscious policies, increased volumes of commercial activity, tourism and marine exploitation represent potentially serious risks to the coastal ecosystem.

Sensitive Environment along the EASSy Route 5.6 Coral reefs: These occur along most shallow, tropical coastlines, where the water is clear and

warm, and the salinity is constant. Corals provide food, shelter and nursery areas for many fishes and crustaceans. Reefs protect coastal areas from storms and erosion by forming natural breakwaters. Much of the white sand found on beaches originated from coral skeletons, or from the skeletons of creatures and algae associated with the reef.

5.7 Seagrass: Large seagrass meadows usually occur in the protected waters landward of coral

reefs. Grazers, such as green turtles, fishes, and sea urchins feed directly on the grasses. Seagrass blades provide surfaces for epiphytes like algae and invertebrates to attach to. Seagrass beds also serve as nursery grounds for the juveniles of many commercially important fish species. Seagrasses help keep the water clear. The blades of the grasses act as baffles, inducing the settling of sediment particles, while the rhizome and root system stabilize the bottom, preventing the re-suspension of sediments. Clear water is an important requirement for the maintenance of healthy coral reefs.

5.8 Mangroves: These are found along the coasts of tropical and subtropical regions, representing a

group of unrelated tree species that are grouped together because they can tolerate having their roots submerged in salt water. Their prop roots provide a surface of attachment for marine organisms in a muddy environment where hard surfaces are in short supply. Mangroves also trap and bind sediments and filter land based nutrients, promoting water clarity. Mangroves, like seagrasses, serve as nursery grounds for the juveniles of many commercially important fisheries species, while also providing habitat for a variety of small fishes, crabs and birds. Mangroves protect coasts against erosion by breaking storm waves and dampening tidal currents.

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5.9 Estuaries, wetlands and Salinas: Estuaries, coastal lagoons, and other inshore marine waters are very fertile and productive ecosystems. They serve as important sources of organic material and nutrients, and also provide feeding, nesting and nursery areas for various birds and fishes. These ecosystems act as sinks of terrestrial run-off, trapping sediments and toxins, which may damage the fragile ecosystems offshore like coral reefs.

5.10 Beaches: The beach serves as a buffer zone between the land and the water. It is usually made

up of unconsolidated sediments, such as sand, stones, coral rubble, and boulders. Beaches are dynamic environments, constantly changing as a result of natural processes, including storms, hurricanes, tidal changes, and sea level rise. Beaches also change as a result of man’s actions. Removing sand from the beach for construction, vegetation clearance, and building of seawalls are major problems in many areas of the world. Animals occupying this environment have adapted to the constant motion of the sand, gravel, or shell. The beach also provides habitat for a multitude of burrowing species, such as crabs, clams, and other invertebrates.

Protected Areas Along or Near the EASSy Route 5.11 Mtunzini, South Africa: The cable route passes through the Mlalazi Nature Reserve, and the

dune area is designated as ecologically sensitive. The St Lucia Marine Reserve is well to the north of the cable route, Glenton Reef lies to the south of the route.

5.12 Dar es Salaam, Tanzania: All shallow water is designated marine reserve except in special cases

of development. 5.13 Mombasa, Kenya: There are Marine Parks north and south of Mombasa and a WWF marine

priority ecoregion extends around Mombasa coast. Fort Jesus, where the cable lands, is a protected and highly important cultural, historical and archaeological site.

5.14 Djibouti, Djibouti: The area of the landing site, together with much of the Djibouti coast, is

registered on the Ramsar List as a protected area for migratory sea birds. 5.15 Port Sudan, Sudan: The Sangeneb atoll, around 10km northeast of the route, is a World Heritage

site

Protected/ Endangered Species

5.16 In addition to the protection afforded by MPA’s, various species regarded as endangered by human exploitation are protected by International and/or National status. Principles among these are:

5.17 Sea Turtles: All Indian Ocean sea turtles are designated under the Endangered Species Act

(ESA) as either threatened or endangered. Marine Mammals. Humpback whales, Dugong and Dolphins are under varying threats and have been afforded protection under a number of schemes

5.18 Seabirds: Coastal wetlands, Mangroves, the shallow waters adjacent to reefs and islands, and

the numerous islands throughout the Eastern African and Red Sea Region provide ideal habitat for a large number of seabirds. Generally, the Red Sea is a flyway for many species of birds

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which seasonally migrate between Europe and Africa, and the islands of the southern Red Sea, utilized by many hundreds of thousands of birds in the spring and autumn migrations. The Convention on Migratory Species (CMS) concluded on 16 June 1995 in The Hague, the Netherlands, an agreement to conserve the African-Eurasian Migratory Waterbirds (AEWA), and entered into force on 1 November 1999.

5.19 Others: The particularly rich ecosystem of Eastern Africa and Red Sea hosts various endemic

protected species not listed in the Endangered Species Act but are protected as part of Programmes for the conservation of the region’s biodiversity, such as sharks, sea cucumbers, etc.

Summary of in Country Conditions 5.20 The site visits identified the following in-country conditions relevant to this ESIA: 5.21 South Africa: The Manhole area is in a swamp with high groundwater levels; the route to the

Terminal building passes through environmentally sensitive Mlalazi Nature Reserve, but the existing SAFE (South Africa Far East cable system) infrastructure is to be used. The dune area is designated as ecologically sensitive. A shallow rocky reef offshore of the route is not environmentally sensitive. Tourist activities will affect the beach, especially during December and Easter. Surf fishing, ski boat fishing and kayaking occur in the local area; there are many hotels and restaurants. There is an existing water intake infrastructure immediately to the north of the SAFE route for a prawn farm, but this is currently inactive. All premises (ducts, Beach Man Hole (BMH) and Terminal Station) are existing and owned by Telkom SA. Dune mining occurs to the north of the landing. Occasional fishing in adjacent estuary.

5.22 Mozambique: The landing point lies in an area of 3-4m high scrubby dunes and beach.

Vegetation comprises mainly exotics, with stabilising function. There are intertidal areas with marine algae of limited environmental importance. Offshore is a large intertidal sand flat. The route has not been used before but there are few buildings in the area and the Terminal station will use an existing building. Artisanal fishing, mostly beach and gill netting, takes place inshore near the route and there are offshore trawling grounds. Maputo is a thriving tourist centre with hotels, restaurants, beaches, yachting. The beach is 5km long with limited tourist activity except during the December holiday season.

5.23 Madagascar: The landing point is a sandy shore (mainly dunes) with minimal ecological

interest and some wetlands behind (1 km away, avoided by cable route). The Manhole area is in sand dunes, far above water level. The cable will follow an existing dam and roads in an area remote from centres of population and therefore generally quiet and undisturbed except for local weekend tourists. The route has not been used before. There will be no relocation issues provided the ducts are constructed along the centre of the roads to avoid private settlements on each side of the road. The Terminal Station is within an existing telecom compound. Fishing is restricted to artisanal vessels operating close to the reefs, well clear of the cable route. The landing point is situated just at the entrance of Toliara Port channel, used by relatively large vessels. The main area for tourism is the Ifaty lagoon 20km north of the cable.

5.24 Tanzania: The landing beach is approx 2km long and 50 m wide within an urban area. The back

beach is a recreational area with grass and scattered tree cover, of no significant ecological

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value. The beach area is generally quiet all year around and is not designated as a tourist beach. All shallow water is a designated marine reserve except in special cases of development. There are fringing reefs in the area and scattered reefs within the embayment. The cable route lies in an urban area with roads of generally poor quality. The (existing) Terminal Station is owned by Zantel and constructions of BMH and ducts will avoid any settlement. There is no fishing within the Bay; navigational traffic consists only of yachts. Further offshore bottom fishing (including licencing of foreign vessels) makes an important contribution to the economy. Tourism provides employment, but the main tourist area is further away in Zanzibar. The currently proposed route is different to that of desk study.

5.25 Kenya: The small landing beach is bounded on each side by rocks, with areas of dead coral,

inside the urban area. There are Marine Parks north and south of Mombasa and a WWF marine priority ecoregion extends around the Mombasa coast. The route has been used before and. BMH, ducts and Terminal Station are already in place. The landing is at Fort Jesus, a protected and highly important cultural, historical and archaeological site. There is no fishing or shipping in the cable landing area, but fishing (generally artisanal) is an important activity in Mombasa. There is no tourist activity at the landfall beach, but some tourist activity in the town.

5.26 Somalia: The Manhole area is situated on a rocky outcrop of old coral. Dunes on the cable route (behind the BMH) are well stabilised. There are no marine parks or coral reefs in the vicinity. The BMH is within the airport perimeter and well isolated, close to the Terminal Station. The cable route, which has not been used before, will pass around the airport and follow a small road, avoiding houses. There are no relocation issues as the Terminal Station and BMH are already in place and the planned ducts will avoid any settlement. The area offshore of the site is an anchorage for vessels entering Mogadishu Port, 2km to the east. There is no fishing in the BMH area due to security restrictions but fishing is a major employer in Somalia. There is no tourism activity at the present time. Security is a continuing concern in Mogadishu and steps must be taken to protect personnel working on the project.

5.27 Djibouti: The Manhole and adjacent terminal Station are situated on a hard sand field of no

particular environmental interest. Although the Landing area is registered on the Ramsar List but there are no wetlands in the vicinity. Possibly some seagrass in vicinity (but not confirmed) where Dugongs feed. There are protected islands (MPA) 10 km and 100km northwest of landfall, and Haramous Island offshore of the site must be avoided. Sea cows, other marine mammals and sea turtles are protected in all Djibouti waters. The Cable Station, BMH and ducts are to be constructed on land owned by Djibouti Telecom. Presidential and Ministries’ residencies close to the landfall ensure security to the cable as well as preventing fishing and tourism in the area. The landfall is in a noisy residential area (army barracks to the west, presidential residences to the east and busy highway 100m from BMH). Fishing is a small activity but important for local diet; trawlers are forbidden in Djibouti coastal waters due to protected marine resources, marine parks and cable presence. Jobs that would be provided as a result of this project will potentially raise the development level. The international tourist industry is not very developed due to the very short coastline and military presence.

5.28 Sudan: The landfall is on a raised limestone platform within the busy Port area. The Sangeneb

atoll World Heritage site lies to the north. Although coral reefs in the area are generally abundant with aquatic life, the reef around the port development is dead though still covered by

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seagrass. A port development currently under way will bury the reef at this location below a reclamation. The Fringing Reefs N and S of the Landfall have been excavated to provide vessel berths. This is a busy shipping area in the Port approaches and the Dama Dama oil jetty lies immediately to the south. There are no relocation issues as EASSy will use the Terminal Station, BMH and ducts already in place for SAS-1. There are numerous old telegraph cables in this area. There is no fishing in the immediate area, but artisanal fishing vessels from Abu Hashish fishing village north of the landfall occasionally transit the area. There is a diving industry but the sites used for tourism (diving sites) are far from the cable location. There are salt pans along the coast to the south of the Landfall

6. POTENTIAL IMPACTS

Environmental Impacts 6.1 The Matrix below summarizes the potential negative or unexpected impacts from the general

cable installation techniques. These impacts are not applicable in all cases. 6.2 The different period of impacts were defined as followed:

- Survey: marine survey prior to cable installation, both inshore and offshore - Construction: installation of the cable offshore or construction of onshore buildings or

services - Repair/ Recovery: Repair relates to rare requirements to rectify cable breaks. Recovery

relates to final decommissioning of the System. The cable is considered to have little impact during normal operation.

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Construction phase

Potential Impact Survey Landing Station

Submarine Cable

Operation phase

and cable life

Repairs/ Decommissioning

Dust × + × × × Noise + + × × × Generation of waste × + × + Gaseous Emissions × × × × Odour × × × × Traffic Generation × + × × × Night-time operations + × + × + Manufacturing, storage, use, transport or disposal of hazardous materials

× × × ×

Vibration × + + × + Heat × × × × Radiation × × × × Water pollution from Liquid effluents, discharges

× × × ×

Disruption of bottom sediment or water movement

+ + × +

Visual Pollution × + × × × Cultural and heritage × + × × × Ecological/Economic impact: − Terrestrial/ Coastal − Marine − Fisheries − Tourism

× × + ×

+ + + ×

× × PPP PPP

+ + + ×

Risk of accidents resulting in pollution or hazard × × + × ×

Disposal of soil material × + × × ×

Notes: + Likely adverse impacts, ×= Adverse impacts unlikely or not expected PPP = Positive

Social Impacts 6.3 The World Wildlife Fund (WWF) has identified a range of human interactions with the marine

environment posing a degree of threat to the natural resources of the area. These are:

• Increased population pressure: Population trends indicate an upward swing in almost all the coastal towns in the area. It is important to address population growth in order to minimize pressure on the resources.

• Poverty: Increasing poverty among communities in all the coastal regions is both a cause

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and effect of environmental degradation. Income data indicate a widening gap between the rich and the poor. Poverty also manifests itself in non-income parameters such as inadequate access to water, health, education and poor housing.

• Destructive fishing practices: Destructive practices such as dynamiting, poisoning, beach

seining and bottom trawling damage the marine ecology and resources. It is important to address this issue because fishing is a major economic activity in the region.

• Overfishing: Local communities complain that certain types of fish are not easily available

these days. This suggests that overfishing is a problem in some areas. Licenses are issued to foreign fishing companies to operate in the region and clashes between foreign and local fishermen have been reported.

• Tourism development: Pollution, cultural problems and land degradation are the main

adverse impacts of tourism. Tourist arrival trends indicate that the coastal zones will continue to receive too many tourists, exerting more pressure to the marine environment and the coastal population.

• Extractive activities: Mining, quarrying and coral mining destroy coastal habitats.

Extractive activities pose major threats as they exacerbate land degradation and pollution. Salt production and sand mining are some of the critical issues that require immediate attention.

• Mangrove destruction: Overexploitation and illegal harvesting of mangrove forests poses a

threat to this resource. • Resettlement: Involuntary resettlement, economic displacement and social disruption occur

as a result of project-related land acquisition. New development projects threatening communities in Africa, particularly the most vulnerable populations such as indigenous peoples, are being started in increasing numbers.

Positive Impacts 6.4 The project will have a positive impact on the employment situation in the participating

countries. The enhancement of communications and global connectivity will directly affect local businesses, education and employment opportunities within the country, and is likely to have an indirect effect of attracting more tourism to current tourist centres because of the ease of communication.

6.5 Regional governments have identified EASSy as a priority project for the enhancement of

Information and Communication Technology (ICT) infrastructure in the region and believe that a robust and reliable international telecommunications link will have significant benefits for the citizens of the region, regardless of gender or ethnic community, in the following ways:

- Providing better quality services at reduced operational costs and user charges, - Providing more reliable international communications, - Providing competitive prices for national and international connectivity,

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- Stimulating investment and economic growth, - Increasing employment opportunities, - Easing access to education and broad knowledge such as medicine

6.6 These impacts support African government, UN and World Bank goals of reducing poverty,

increase economic development and opportunity for citizens of the region, and enable social changes through equal opportunities.

6.7 With respect to land acquisition and involuntary resettlement issues that may arise from the

project, EASSy has no significant negative impacts on human settlement nor on indigenous peoples’ right, culture, belief, lands and natural and cultural resources. Cable routings avoid human settlements and sensitive areas of special interest and do not disturb or affect any marginalized and vulnerable populations.

7. IMPACT MITIGATION

Mitigation in the Open Sea 7.1 The open sea is taken to consist of Exclusive Economic Zone (EEZ) waters traversed by the

EASSy system. These are mainly the EEZ waters claimed by participants in EASSy, but also include the waters of Eritrea, Yemen, Comores, Bassas Da India and Europa Island. Within these waters, the cable will be surface laid in the Red Sea and the Gulf of Aden (where aggressive bottom fishing is absent) and in water depths of >1000m elsewhere. The cable will be buried in water depths of <1000m S of Somalia, and thus the comments here are taken to apply up to the territorial limits of the participants in EASSy. Trawling is a potential hazard on the Continental Shelf and represents the main reason for cable burial in this area. Mitigation measures were developed to minimise general impacts such as sediment disturbance during cable burial, discharges from marine vessels, random waste disposal, noise and dust from construction works and uncontrolled run-off and specific impacts such as sensitive ecological resources or cultural heritage area. The impacts and associated relevant to offshore operations are tabulated below.

7.2 The cable is considered to have zero impact during normal operation.

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Operation Degree of

impact Type of mitigation

Area of impact

Description of impact

Surv

ey

Inst

alla

tion

Rep

air/

R

ecov

er

Sediment disturbance causing turbidity

0 2 1 Temporary, reversible, indirect

Construction methods used, monitoring, timing of works, restricting area of works

Water

Discharges from works vessels (wastewater, oil)

1 2 1 Temporary, reversible, indirect

Monitoring, training, education

Accidents which cause spills of dangerous chemicals

1 2 1 Temporary, reversible, indirect

Monitoring of vessels and procedures

Runoff during excavation

N/A N/A

Waste Generation of wastes 1 1 1 Temporary, reversible, indirect

Define disposal procedures, monitoring

Disposal of soil material – potential for contamination

0 1 1 Temporary, reversible, indirect

None required

Ecology Terrestrial ecology N/A N/A Reef damage (sea

grasses) N/A N/A

Coral damage (marine parks)

N/A N/A

Fishing gear impacting cables

N/A N/A

Abrasion of cable by waves – damage to corals

N/A N/A

Noise Night time operations 0 0 0 Insignificant N/A Air Dust 0 0 0 N/A N/A Gas emissions from

vessels 0 1 1 Insignificant N/A

Traffic Impacts on traffic in area N/A N/A Cultural Impacts to sites of

cultural or archaeological interest

N/A N/A

Social Impacts on fisheries. – forced relocation, stop fishing, etc.

2 2 2 Temporary, reversible, indirect

Timing of works, communications, monitoring

On tourism – diving sites 0 0 0 Insignificant N/A

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Operation Degree of impact

Type of mitigation

Area of impact

Description of impact

Surv

ey

Inst

alla

tion

Rep

air/

R

ecov

er

Relocation of people N/A N/A Impact on shipping

routes 1 1 1 Temporary,

reversible, indirect

N/A

Impact on employment +1 +1 +1 Monitoring teams

N/A

Visual Creation of new buildings, impact on landscape

N/A N/A N/A N/A N/A

Impact Scale 0:- No impact; 1:- Minimal impact – no need for specific mitigation; 2:- Low to medium impact

– needs basic mitigation; 3:- Medium to high (reversible and irreversible) – need specific mitigation measures and careful monitoring programme to ensure no adverse effects.

Mitigation for Coastal Impacts 7.3 During the survey phase at Djibouti vessel operations will ensure no damage to sea grasses and

additional security will be provided offshore Somalia. 7.4 During the installation phase to vessel operations will ensure minimum sediment disturbance

from cable laying causing turbidity. Discharges from works vessels (wastewater, oil) and accidental spills of dangerous chemicals will be avoided. Other impacts that will be mitigated through good marine practices include avoidance of runoff during excavation; generation of ship wastes; disturbance to terrestrial ecology; night time operations will be avoided; dust and impacts on other traffic in the area to be minimized; and security for personnel when working in Somalian waters; etc.

7.5 During the maintenance/recovery phases measures will be put in place to avoid runoff during

excavation; disturbance to terrestrial ecology; impact on shipping routes; security risk to personnel offshore Somalia.

Mitigation for National Impacts 7.6 South Africa: Ecological impacts are unlikely in the Mlalazi Nature Reserve because the

SAFE cable route can be utilised. In the ecologically sensitive dune area potential impacts may occur in the absence of appropriate construction methods and careful access. Potential impacts may occur on prawn water intakes at the beach site.

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7.7 Madagascar: The proposed cable landing site lies within the Littoral de Toliara Biosphere

Reserve. However, the nESIA Report and the audits of NGO (WWF) and authorities (Ministry of Tourism and Environment and Environment ministry) establish that landing the cable in the area will have no significant impacts on the preserved biosphere and there is therefore no objection to the project.

7.8 Tanzania: Shallow waters up to the 10 m bathymetric contours are protected and designated

as a marine reserve. As such, activities in Tanzanian shallow waters (such as fishing) are banned. The main features of ecological importance are scattered reefs, which the proposed route avoids. However, since shallow water environments have been found to recover quickly from a cable installation with improved biodiversity, and installation of the EASSy cable is considered to be of National importance, a dispensation has been granted for the cable to cross through this protected area.

7.9 Kenya: The landing site is located between Fort Jesus heritage site and old Mombasa city,

both of cultural heritage significance. The BMH and ducts, which already exist and only need some renovations and excavations, are situated 150 m away from the Fort. Cable installation within the existing ducts is considered to have no significant impacts on the surrounding environment and will not cause degradation of this heritage site.

7.10 Somalia: Security of marine survey and cable installation operators, as well as other workers

involved in construction, might be a concern. However, during in country site-visit and audit, Dalkom as well as the Somali Ministries and authorities understood the security concerns and guaranteed that everything in their power will be realized to ensure safe working conditions to employees, non-employee workers and security personnel contracted to safeguard its personnel and property.

7.11 Djibouti: The landing site lies in an area registered on the Ramsar List in March 2003. This is

concerned with the protection of migrating birds and although the protected wetlands are situated well south of the landfall area, the coast is protected to safeguard migratory seabird feeding grounds. The BMH and Terminal Station lie within the Djibouti urban area and it is unlikely that seabirds are present near these locations. Any additional noise or activity generated during cable installation is not considered to have a significant additional impact on wild birds in this noisy residential and army barracks area. However, noise during BMH and Terminal Station construction should be minimized to avoid any possible impacts on seabirds. The marine cable activities will have no greater impact than normal vessel movements, but Haramous Island (Haramous-Loyada, 11°35'N 043°09'E), close to the landing site, is a highly protected sanctuary for numerous seabirds and this area should be avoided.

7.12 Sudan: The cable passes from the BMH to the open sea across a fringing coral reef. However,

the coral in this area is reported to be dead due to the proximity to Port Sudan, and associated dredging and reclamation. The fringing reef in this area will be covered by a reclamation as part of the Port expansion, prior to installation of the EASSy system.

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8. PUBLIC CONSULTATIONS

8.1 During in-country site surveys, no resettlement issues were identified for any landing site. Even though no expropriation will be necessary for this project, public participation and consultation for cable-routing and construction permitting are still essential to comply with National and DFI Social Performance Standards. Public consultation were organised, or will be planned in the future during construction, as part of the national ESIA (n ESIA) requirements.

8.2 Public involvement to date has involved the following actions:

• Consultation during Desk Top Study preparation • Consultation during nESIA preparation (where applicable) • Consultation during ESIA preparation • Promulgation by Telecom companies (where applicable)

8.3 In accordance with relevant DFI guidelines two public participation events were required: a

scoping session to define the contents of the environmental impact assessment study, and a session to discuss the results of the draft environmental impact assessment study. The responsibility for public disclosure of information rests with the licensing authority and public participation was part of the ESIA process executed by the public administration. The Telcom companies and their EIA consultant will of course be the main executors of the public participation process.

9. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

Umbrella ESMP 9.1 The umbrella ESMP provides guidelines for the implementation of mitigation measures to

reduce impacts during the laying of the cable in deep offshore waters that are governed by international laws and regulations. Contracts for cable installation would include the obligation of contractors and other workers involved in constructions to comply with the ESMP, DFI Performance Standards, National and International Laws, and other DFI requirements. An Environmental Auditor will ensure the fulfilment of those requirements during cable works.

9.2 This ESIA has concluded that the potential for significant impacts to occur during cable laying

in deep offshore waters is minimal. However, recommended monitoring is summarized below: 9.3 The Purchaser will have a representative on board at the time of survey and cable laying to

ensure that the works are carried out in accordance with the work programme. This is normal practice during cable installations, with the representatives drawn from the participating Telecom companies. The Purchaser representative’s duties usually cover monitoring of the sufficiency of the vessel to carry out the work (pre-mobilization check), ensuring safety requirements are covered and auditing the adequacy of the cable laying operation. The Purchaser representative also performs the duties of environmental auditor (EA) during the deep water cable laying activities.

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9.4 Since the monitoring will be carried out by personnel already required to be present, the costs of compliance with the ESMP (other than training) will be absorbed in items already allowed for by the Contractor and Purchaser.

National ESMP 9.5 Contracts for onshore and shallow water cable laying operations would all include the

obligation of contractors and other workers involved in constructions to comply with the ESMP, IFC Performance Standards, National and International Laws, and other DFI requirements. An Environmental Auditor (EA) will ensure the fulfillment of those requirements during cable works. The EA would be familiar with marine cable laying operations and the associated environmental impacts, mitigation measures and monitoring techniques.

9.6 The environmental auditor will work closely with the cable contractor during construction and

subsequent operation (for example repairs) to monitor the methods used by the contractor in laying the cable are in line with the expectations of the ESIA and mitigation measures proposed in the ESMP are implemented as required.

9.7 During construction, close liaison should be maintained between the environmental auditor and

the contractor to ensure all aspects of the construction are monitored. The contractor should be prepared to provide method statements to the environmental auditor as required. The contractor should make the construction programme available to the environmental auditor as early as possible. The contractor should give adequate warning to the environmental auditor of any changes in programme.

Shallow water cable laying 9.8 This stage of the cable laying has the most potential to cause impacts and therefore requires the

EA to be on site continuously during survey and construction. As in the deep water cable laying stage, the EA will be responsible for briefing of the contractor on means of avoiding unacceptable damage and the importance of implementing recommended mitigation measures.

Onshore cable laying and construction 9.9 In a number of landing point countries, the BMH and the ducting required for the EASSy cable

is already present in the form of other cables laid. In these cases the potential for impacts is minimal. The EA would follow similar guidelines as those shown above for the shallow water cable laying, as appropriate for the onshore works. The main differences will be in the type of mitigation measures to be used. The potential for noise and dust impacts in areas close to sensitive receivers where construction is required, must be carefully monitored and appropriate measures taken to reduce impacts.

9.10 The EA must maintain good communication with local residents and relevant interest groups

and ensure the contractor establishes an effective means of giving advance warning of the proposed works to local residents. Reporting progress and environmental performance and maintaining contact with Purchaser and the Telecom operators for the landing country is an important part of the EA’s responsibilities.

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ESMP Costs 9.11 The contractor’s costs of compliance with the ESMP requirements will be absorbed in his

overall pricing. 9.12 The cost of compliance with the Umbrella ESMP in the offshore areas will largely be related to

the provision of Purchaser’s Representatives on the Survey and Installation vessels and the environmental training/briefing of these personnel. If no Purchaser’s Representative is in attendance, the Main Contractor will have to fulfill these duties, and the cost will be limited to training time and travel expenses.

9.13 The cost of provision of a nESIA consultant to oversee the inshore survey operations, inshore

installation and any terrestrial work required will vary from country to country but is likely to involve around 2 to 4 weeks of input for each Landing. This cost will be borne by the local Telecom Company.

10. CONCLUSIONS 10.1 The impact assessment has demonstrated that the impacts likely to be generated in the cable

laying operation in deep offshore water will be minimal. No impacts are expected on fisheries or shipping activities providing normal international marine activity procedures are followed. To avoid unnecessary environmental damage from inappropriate disposal of wastes and foul waters, environmental auditing and monitoring of the marine vessel facilities and the contractor’s waste handing methods is recommended.

10.2 Cable laying in shallow waters is potentially the most likely phase of the cable laying

operation when impacts may occur. In deeper sections of water there is potential for discharges of waste and foul water from the vessel. During burial of the cable (if required) across the shallow reef or sand areas, there is potential for sediment disturbance, local deterioration in water quality, impacts on local fishing activities, impact on the ecology of the area and impacts on tourist areas and possibly cultural heritage sites through noise disturbance. These impacts can be readily mitigated through appropriate briefing of the contractor and monitoring of their works by an Environmental Auditor, careful construction site and method management, minimization of sediment disturbance, and maintenance of good communication with the relevant authorities.

10.3 Impacts from onshore cable laying include noise and dust during BMH and duct construction

(if required), run-off especially in areas prone to flooding, impacts on sensitive coastal resources and on tourist activities have all been assessed. Mitigation will include briefing of the contractor about environmental requirements, monitoring of methods, timing, activities to avoid impacts on nearby sensitive receivers, route selection and avoidance of sensitive ecological resources on the shore, isolating areas for protection of the public and avoiding additional damage to the site, covering of stockpiled areas and good construction site housekeeping and management.

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10.4 Cable impacts on the sea floor and fauna is probably the major concern of this ESIA; fauna benefits from new substrate on the sea bed and although disturbance and degradation happen during cable installation, sensitive ecosystems recover shortly after. Special care would be taken during cable installation to avoid exposure of sensitive areas to prolonged high turbidity. Mitigations inshore will include the use of survey and video coverage before inshore cable laying to select routes that avoid live reef and seagrass areas. Tree planting and restoration of dune systems may be considered advisable after onshore cable laying.

10.5 Cable Installer and Survey Company would need to comply with the various DFI

requirements, Social/Environmental Management strategy, and the need to issue Environmental Compliance Reports will have to be stated and fully described in contracts. Contractors/workers will need to be briefed by an environmental auditor. Usually, good working practice, health and safety, and equal opportunity are a component of company’s procedures and vessels usually comply with International laws on vessel discharge and pollution.