E1 565Vol. 5

ELECTRICIDADE DE MO(AMBIQUE, EP

ADDENDUM TO THE ENVIRONMENTAL IMPACTSTUDY OF THE 220kV MOZAMBIQUE - MALAWI

TRANSMISSION LINE PROJECT

JANUARY 2007

SUBMITTED BY:IMPACTO LdaAv Martires da Machava, 968 ______Is___

Maputo PI .a A-d*

Mozambique

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ADDENDUM TO THE ENVIRONMENTAL IMPACT STUDY OF THE220kV MOZAMBIQUE - MALAWI TRANSMISSION LINE PROJECT

COMPRISING THE FOLLOWING SECTIONS:

SECTION 1: CAPACITY BUILDING FOR ENVIRONMENTAL MANAGEMENTWITHIN EDM

SECTION 2: BUDGET FOR ENVIRONMENTAL MANAGEMENT ACTIONSFALLING OUTSIDE THE RESPONSIBILITY OF THE CONTRACTOR.

SECTION 3: ENVIRONMENTAL MANAGEMENT PROCEDURES ASSOCIATEDWITH THE OPENING AND OPERATION OF BORROW PITS

SECTION 4: CONTROL OF ILLEGAL HUNTING AND USE OF FIREWOODAND CHARCOAL

SECTION 5: COMPLIANCE WITH WORLD BANK ENVIRONMENTAL ANDSOCIAL SAFEGUARD POLICIES AND PROCEDURES

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SECTION 1

CAPACITY BUILDING FOR ENVIRONMENTAL MANAGEMENTWITHIN EDM

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Table of Contents

1 MOZAMBIQUE'S ENERGY STRATEGY ............................. 42 LEGAL FRAMEWORK FOR ENVIROMENTAL MANAGEMENT IN MOZAMBIQUE43 CAPACITY BUILDING FOR ENVIRONMENTAL MANAGEMENT WITHIN EDM .7

3.1 Current Capacity in EDM ..................................... 73.2 Current EDM Environmental Management Policy, Procedures and Guidelines73.3 Capacity Building Strategy .................................... 8

3.3.1 Production of a Policy, Procedures and Guidelines Manual for EdM staff.... 83.3.2 Develop a framework for transforming existing EU into Environment, Healthand Safety Unit ................................................ 93.3.3 Develop environmental capacity within EDM by conducting a training needsassessment and training staff ..................................... 103.3.4 Indicative time required and budget for implementation .............. 12

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1 MOZAMBIQUE'S ENERGY STRATEGY

Some of the overriding concerns of the Government of Mozambique (GoM), as stated inthe National Energy Strategy (NES), are to alleviate poverty and improve access tomodern sources of energy for rural and urban communities through the progressivereduction in the role of the State, the establishment of effective policy and regulatoryframeworks and the promotion of private sector investment in the development andmanagement of the country's diverse energy resources. The key challenge in thedesign and implementation of the NES will be to harness and mobilise the extremelylimited institutional and human resource capacity in both the public and private sectors.The main implementation measures of the NES are:

* Improving access to energy services in urban and rural areas;* Promoting the development of energy resources for the domestic market and for

exports;* Institutional capacity building in the energy sector;* Ensuring good energy sector management;* Guaranteeing the sustainability of biomass resources; and* Promoting the implementation of sustainable environmental practises.

The energy sector in Mozambique involves a diversity of role players and stakeholdersfrom both the public and private sectors.

The Ministry of Mineral Resources and Energy (MIREME) has overall responsibility forpolicy and regulation with respect to the energy sector. Electricidade de Mocambique(EdM) was transformed from a state company to a public company in 1995 and now hasthe mandate to generate, transmit and distribute electricity on a commercial basis. Anumber of much smaller private and public entities are also involved in generating andsupplying electricity in parts of the country, particularly in more isolated rural areas. Anumber of programmes have also been initiated recently to promote the participation ofthe private sector in the energy sector.

2 LEGAL FRAMEWORK FOR ENVIROMENTAL MANAGEMENT INMOZAMBIQUE

The Ministry for the Co-ordination of Environmental Affairs (MICOA) was created in 1994as the principal organ to implement the NEMP and associated policy and legislation. Ithas legislative power regarding the environment and part of its mandate is to:

* Develop sector policies and sustainable inter-sector development plans forimproved environmental management;

* Promote sector legislation and the establishment of guidelines for environmentalprotection;

* Co-ordinate policy implementation* Educate and promote public awareness and* Create regulations and conditions for law enforcement and environmental

monitoring.

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Due to its role as a co-ordinating ministry, MICOA's performance depends largely on thedegree to which it manages to co-operate with other ministries and sectors that workwith the environment (including the energy sector) as these sectors remain responsiblefor the integration of environmental matters in their own sector programmes. Thismeans that MICOA has to establish working relationships with each of these sectors.

The Environmental Law was passed in July 1997. The Law is applicable to all publicand private initiated activities that may influence the environment either directly orindirectly. Salient features of the Law include that:

* Those who pollute or, in any way, degrade the environment are liable and underobligation to rehabilitate the environment or to compensate for the resultingdamage;

* Pollution of the soil, sub-soil, water or atmosphere by any polluting substances,or any other form of degradation of the environment which falls outside the limitsstipulated by the Law, is forbidden;

* Projects and operations that are likely to have a negative effect on theenvironment are subject to an environmental impact assessment (ElAs) byindependent assessors;

* All activities that may threaten the conservation, reproduction, quality andquantity of biological resources, especially those in danger of extinction, areprohibited;

* In order to protect environmental components that have a recognised ecologicaland socio-economic value, environmental protection zones may be created; and

* Licensing of activities that are likely to cause significant environmental impacts isrequired. The issuance of an environmental licence is dependant upon anappropriate level of EIA being completed and accepted.

New Environmental Impact Assessment Regulations were passed by the Council ofMinisters in July 2004 (Decree NO 45/2004).

Three categories of project are defined by the new Regulations (Article 3):

Category A: Activities presented in Annex 1 are considered to have significant adverseimpacts on the environment and are subject to an Environmental Impact Study (EIS).

Category B: Activities listed in Annex II are those for which potential environmentalimpacts are less adverse than those of Category A projects and are subject to aSimplified Environmental Assessment (SEA).

Category C: Activities listed in Annex IlIl are exempt from an EIA and SEA but stillrequire observance of good management practices.

In addition, any projects that may affect directly or indirectly, sensitive areas, areclassified as Category A viz.,:

a) coral reefs

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b) mangrovesc) natural forestsd) small islandse) zones of potential erosion, including dunes along the coastlinef) areas exposed to desertificationg) conservation or protected zones or areash) wetlandsi) zones where the habitats and ecosystems are in danger of extinctionj) zones of outstanding landscape beautyk) zones of archaeological, historical and cultural value that should be

preserved, zones where plant or animal species threatened withextinction are located

I) ground waters used for public consumption

In terms of the EIA Regulations MICOA has the responsibility to:

* Classify projects according to category A. B or C.* Approve Terms of Reference (TOR) proposed by a project proponent which will

guide the environmental impact studies;* Undertake reviews of environmental impact studies, in collaboration with

interested public entities, civil society and affected communities; and* Issue environmental licences, based on the EiAs.

Relevant energy sector projects classified as Category A that will require an EIA include:

* Hydro-electric power stations of any capacity;* High tension electrical energy transmission lines with a capacity of or greater

than 110 kV;* Clearing, dividing and exploiting the natural vegetation cover of individual or

cumulative areas greater than 10 ha;* Projects that imply the temporary or permanent displacement of people and

communities

The preparation of the environmental studies (e.g. an EIA) is entirely the responsibility ofthe project proponent. All ElAs must include an assessment of environmental impacts ofthe project and its alternatives, identification and assessment of mitigation measures andan EMP, including the monitoring of impacts and accident prevention and contingencyplans, as applicable. All ElAs are supposed to be reviewed by MICOA which may grantor refuse and environmental licence, depending on the outcome of the review.

It is thus necessary that the proponent (in this case EdM) has the capacity to ensure thatenvironmental management interventions are included in all projects being developedunder their mandate in accordance with Mozambican environmental legislation.

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3 CAPACITY BUILDING FOR ENVIRONMENTAL MANAGEMENT WITHINEDM

3.1 Current Capacity in EDM

Electricidade de Morambique (EdM) is a public company with a Board of Directors. Thecompany is wholly owned by the Government of Mozambique. A small EnvironmentalUnit (EU) has already been established and is functioning within EdM. It is currentlystaffed by one highly trained and experienced professional (electrical engineer) who,however, has other responsibilities within the projects department.

3.2 Current EDM Environmental Management Policy, Procedures andGuidelines

EdM is a high profile company whose activities are a prominent feature of the growthand development of the energy sector for a long time to come. EdM recognises theneed to improve its level of competence in routine environmental management and isalready implementing a number of environmental management measures as part of itsday-to-day operations. However, EdM does not have any overarching environmentalpolicy and strategy to guide environmental management within the company. There is,however, commitment from the highest corporate level to develop an environmentalpolicy for the company and implement an environmental management system of aninternationally acceptable standard (e.g. ISO 1400). Progress in this regard has alreadybeen made through EdM's work with the SAPP.

The present practice in EdM is that it is usually during or after the preparation offeasibility studies for proposed projects (e.g. for a transmission line) that a decision hasto be made as to whether and EIA (Category A Project) or a Simplified EnvironmentalAssessment (Category B Project) is required.

Consulting engineers engaged to undertake the detailed design of projects areresponsible for ensuring that the required environmental studies (i.e. full ElAs or SEAs)are completed as part of the design process and are submitted to MICOA for approval.The environmental studies themselves are often undertaken by specialist environmentalconsultants sub-contracted to the consulting engineers.

Approved EMPs are generally included as part of the contractual obligations of theconstruction company awarded the tender to undertake construction. However, EdM isoften unable to determine whether or not the environmental requirements have beencomplied with by the contractor because the consulting engineers do not haveenvironmental expertise within their teams or EdM supervisors overseeing andmonitoring construction lack the awareness, capacity or skills to check on environmentalmanagement issues.

After construction and commissioning, the operation and maintenance of facilitiesbecomes the responsibility of EdM operational staff. For projects for which EMPs havebeen prepared these plans are supposed to include routine operational environmental

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management activities. There is still weakness in this area, due to lack of environmentalawareness and even rudimentary skills among operational staff although EdM is makingprogress in this regard.

For similar reasons, adequate OHS measures are often not implemented duringconstruction, whether these are what could be considered to be the appropriatestandards for the sector, even in the absence of official regulations or standards, orwhether specific health and safety measures have been included in EMPs. OHSguidelines for transmission and distribution lines were produced for EdM in 1992 and it isunderstood that these are generally complied with.

3.3 Capacity Building Strategy

A key requirement of the electrification and projects department at EdM and its EU is todevelop a clear understanding of environmental management requirements for theconstruction, operation and maintenance of transmission and distribution lines anddiesel and hydro power stations. This will enable EdM to ensure that appropriateclauses concerning all aspects of environmental management (especially mitigation andclean up) are included in future construction contracts. This will enable EdM to clearlydefine and implement monitoring programs to ensure compliance with these contractualobligations.

The proposal to develop environmental capacity in EdM comprises three inter-relatedactions viz.,

* Production of a Policy, Procedures and Guidelines Manual for EdM staff

* Map out framework for transforming existing EU into Environment, Health andSafety Unit

* Develop environmental capacity within EDM by conducting a training needsassessment and training staff

3.3.1 Production of a Policy, Procedures and Guidelines Manual for EdM staff

Foremost it is necessary for EdM to clearly define its corporate environmental policy andstrategy. This activity should be driven by the EU in EdM and the resultant policy shouldbe approved by the EdM Board. Development of an environmental policy should not bea difficult task given that there are numerous power utilities within the region which havedeveloped environmental policies which could be used as a point of departure fordeveloping a policy for EdM. Following this it will be possible to establish anenvironmental management system.

With only one person in EdM currently dealing, mostly on a part time basis, withenvironmental issues, there is a critical deficit in capacity within EdM to developappropriate corporate procedures and guidelines for the company. Such an exerciserequires one or more people to remain focused on the exercise until completion or, atleast, until the main framework has been devised. It is for this reason that a local orregional environmental consulting firm should be contracted to identify and assess the

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various possibilities and produce a corporate environmental policy, procedures andguidelines manual for EdM covering the planning, construction and operation of projects.

The proposed manual should detail the corporate regulations and procedures applicableto:

* Determination of the level of environmental (including socio-economic) study towhich a proposed project is to be subjected;

* Ensuring that the requirement to undertake environmental studies is included inTerms of Reference for consulting engineers undertaking detailed project designstudies (for example, that the EU should review all such terms of reference);

* Compensation and resettlement;* Appraisal and approval of ElAs, SEAs and EMPs;* Ensuring that EMPs are included in the tender and contract documents for

construction companies;* Monitoring of compliance by construction companies with the required measures

of the EMP during construction, including health and safety concerns;* Reporting on compliance with environmental requirements during construction;* Environmental aspects during operation and maintenance of facilities* OHS aspects;* Reporting on environmental and health and safety aspects during operation and

maintenance of facilities (e.g. dedicated progress report or incident report forms);and

* Co-ordination and collaboration with MICOA in respect of environmental andhealth and safety issues.

3.3.2 Develop a framework for transforming existing EU into Environment, Health andSafety Unit

The development of a comprehensive set of policies, procedures and guidelines is onestep to achieving integration of environmental management into the day-to-day work ofthe company. However, it is important that personnel responsible for implementing thepolicy and strategy are equipped with the necessary knowledge and skills to fulfil theirfunctions. However, it is recognised that environmental management activitiesconstitute only one part of the operational activities of EdM as a whole and that the mainfocus must remain on the core business of the company.

The main areas where increased capacity is required include management of theenvironmental assessment and planning process undertaken either internally or byconsultants and compliance with national and corporate environmental, health andsafety policies, regulations and practices during the planning, construction and operationstages.

The level of environmental knowledge and skills required by personnel will varyaccording to their level of exposure to environmental management issues. For example,

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personnel in the EdM EU require a set of skills to enable them to manage and monitorimplementation of the corporate environmental policy and procedures. Field staff,supervising construction activities, for example, need to be able to monitor compliancewith EMPs while operation and maintenance staff need to be able to comply with andrespond to routine environmental, health and safety requirements and issues.

It is recommended that the capacity of the existing EU in EdM be enhanced throughfurther consolidation of the unit and the provision of the necessary support. Because ofthe close relationship between environmental, health and safety issues it is alsorecommended that the existing EU evolve into a single Environmental, Health andSafety Unit, with the responsibility of implementing and monitoring EdM policies andprocedures related to these three elements. Such units have been established in manypower utilities and in industrial and mining companies in the region and internationally.This is a long-term goal but it is recommended that the initial steps be mapped out bythe same consultancy engaged to develop the company's environmental policies,procedures and guidelines.

3.3.3 Develop environmental capacity within EDM by conducting a training needsassessment and training staff

Continuous in-service training in respect of environmental issues needs to be providedat the various levels within EdM. It is recommended that emphasis be placed ondeveloping capacity within the company to deliver training on a continuous basis toexisting and new staff (i.e. training of trainers), rather than providing once-off training tostaff in general. EdM already has a comprehensive training programme and facility forits staff members and environmental, health and safety training, at various levels, shouldbe viewed as one aspect of staff development.

Technical capacity to identify, manage, and monitor the environmental impactsassociated with the implementation of energy projects by EdM is considered to be low.

In the first instance a functional analysis should be used to define the capacity buildingrequirements (e.g. training and communications equipment) for EdM. The functionalanalysis and capacity needs assessment should be carried out across all the sectors ofEdM. This will also allow for a harmonised training programme to be institutedparticularly where personnel from different sectors attend common training courses atthe same time.

It is proposed that a single consultancy be engaged by EdM to perform the trainingneeds assessment at the central and provincial levels and develop a sector-wide trainingprogramme. The outputs of this exercise could include, for example, a long-term trainingplan for professional personnel involving:

* The identification of appropriate local or regional environmental training courses;* Long term planning to enable key staff members to take leave of absence to for

longer term courses (e.g., the Swedish International Development Agency runs

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excellent four week courses for government staff on environmentalmanagement).

* Various forms of in-house training in environmental management.

The design (and running) of the courses should be carried out in participation withMICOA. It is envisaged that most environmental training will directed towards technicalpersonnel who are involved with identification, approval and monitoring of projects and inroutine environmental management activities. Three levels of training are envisaged:

* In-depth training, including technical procedures where relevant, to a level thatallows trainees to go on to train others;

* Sensitisation, in which the trainees become familiar with the issues to a sufficientextent that they are able to precisely define their requirements for furthertechnical assistance; and

* Awareness-raising, in which the participants acknowledge the significance orrelevance of the issues but are not required to have technical or in-depthknowledge of the issues.

Much of the capacity building can be provided through the mechanism of two, three orfour day workshops. The training materials developed for the workshop should includeat least the following components:

* Case studies (where possible developed by the workshop participants) based onthe environmental studies of other energy projects in Mozambique or the regionthat can be used to demonstrate the basic principles of environmentalassessment and management planning and highlight issues related to protectedareas, wetlands, sensitive habitats and affected people;

* Workshopping the screening guidelines as laid out in the new EnvironmentalImpact Assessment Regulations (Decree N° 45/2004) will be an importanttraining component;

* An overview of environmental assessment (scoping, baseline methodologies,impacts and mitigation measures, environmental management planning, publicparticipation, monitoring and evaluation and health and safety.

* Review of relevant national, corporate and donor environmental policies,legislation, regulations, procedures and guidelines;

* Designing effective public awareness campaigns; and* Training of trainers to provide in-house capacity development (to be developed

as a distinct separate component).

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3.3.4 Indicative time required and budget for implementation

The indicative time required and budget for implementing these capacity buildingcomponents are shown in Table 1 below

Table 1: Capacity building measures per component

Indicative IndicativeIssue Actions required Individual(s) Time Budget

required (US Dollars)ProduceEdM

Corporate Poue Policy, Environmentalenvironmental Procedures and Specialist inpolicy, Guidelines manual collaboration with 4 m/m US$35 200procedures and for EdM staff localguidelines environmental

consultant

Map out framework EdMEnvironmental Map tranmenr Environmentalmanagement for transforming Specialist in US$ 17 600and co- Environment, collaboration with 2 m/m

ordination in Health and Safety loalEdM UntenvironmentalUnit consultant

Conduct needs Local US$ 52 000Capacity assessment. environmental (conultngfees)Development in Tainsseset.f eranvirnmenal 6 in/in overthe Environment Trainstafltainin a two year US$ 40 000

coslatperiod (logisticalsupport: trainingin provinces)

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SECTION 2

BUDGET FOR ENVIRONMENTAL MANAGEMENT ACTIONSFALLING OUTSIDE THE RESPONSIBILITY OF THE

CONTRACTOR.

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BUDGET FOR ENVIRONMENTAL MANAGEMENT ACTIONS FALLING OUTSIDETHE RESPONSIBILITY OF THE CONTRACTOR.

The EMP includes a section for monitoring of the implementation of the EMP. The EMPstates that "EdM personnel should participate in this process in the context ofinstitutional capacity-building for environmental management".

Monitoring, inter alia, of the following is required:

* Camp site location

* Location of storage yards for materials storage and maintenance areas

* Management of hazardous and chemical substances (HCS)

* Prevention of fuel and lubricants spills

* Solid waste management

* Workers' and local communities' health and safety management

* Rainwater and wastewater management

* Protection of sacred places

* Control of hunting and use of charcoal

A budget is thus required in order for EdM to carry out regular monitoring of theimplementation of management actions outlined in the EMP. It is recommended thatmonitoring is carried out by the technical staff member currently responsible for theEnvironmental Unit. The monitoring will contribute to the capacity building of the EUthrough "on job training".

The monitoring should be carried out at regular two-monthly intervals. It is envisagedthat the mobilization and construction period for the Tete-Malawi section of thetransmission line will be in the order of 18 months. The budget thus covers nine (9)monitoring site visits by the EdM technician.

Backstopping by a local consultant will also be required in order to assist in thepreparation of environmental monitoring protocols and checklists and initially in fieldvisits the, analysis of results and report preparation. It is envisaged that the localconsultant will participate in at least two (2) site visits

The budget for monitoring of implementation of the EMP by EdM is given below.

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Item US Dollars9 return flights Tete-Malawi (EdM Technical Staff) @ US$ 350 3150per flight2 return flights (local consultant @ US$ 350 per flight 70054 days field per diems @ US$ 65 351022 days backstopping by local consultant @ US$ 450 p.d. 9990Total 17,350

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SECTION 3

ENVIRONMENTAL MANAGEMENT PROCEDURES ASSOCIATEDWITH THE OPENING AND OPERATION OF BORROW PITS

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ENVIRONMENTAL MANAGEMENT PROCEDURES ASSOCIATED WITH THEOPENING AND OPERATION OF BORROW PITS

During construction phase of the transmission line borrow pit fill material will be required.The opening and operation of borrow pits may result in several negative environmentalimpacts.

Short-time impacts:

* Destruction of vegetation* Loss of income from lost production and land exclusion from farm operations* Dust and noise pollution* Stream pollution* Erosion* Aesthetics affected scarred landscape* High density of pioneer species in early regeneration phase, due to disturbance and

increased water collection* Increased activity of native and feral animals due to water ponding

Long term impacts:

* Changed environment due to increased water collection in the pit* Slow change of pit to totally rehabilitated state (may up to a hundred years in

woodland areas)* Slow return of native fauna due to changed vegetation communities and soil

structures* Loss of a soil horizon change in soil structure

Impact Classification

Status: NegativeProbability: HighExtent: LocalizedDuration: Medium-termIntensity: HighSignificance without mitigation: Moderate to HighSignificance with mitigation: Moderate

Environmental Management Procedures

Planninq* Before starting any borrow pit operation, the contractor should obtain approval

from the authorities (Ministry of Mineral Resources and MICOA).

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* Landowner approvals will be obtained prior to opening borrow pits. The approvalwill identify the future land-use required by the landowner for the area utilized asa borrow pit.

* Prior to borrow development, site specific plans will be developed to optimize theextraction of granular resources, minimize disturbance and facilitate restoration.

* Site specific development plans will be used by the operator(s) duringdevelopment planning, operations, and final restoration.

* The requirements and conditions issued by the relevant authorities for the borrowpit operations will at all times be meet.

Site Location* Where possible, existing borrow pits and associated roads, trails or cut lines will

be used in preference to developing new pits.* New borrow pits shall be located at least 100 m from a main road.* Where practicable, borrow pits for aggregate sources will be located in upland

locations and separated from streams and lakes by a 100 meter wide buffer stripof undisturbed terrain in order to minimize siltation. Where upland borrow pitsare unavailable or where the environmental disturbances associated with uplandaggregate removal would be acceptable, the use of borrow materials fromfloodplains may be acceptable.

* Areas identified as possible borrow areas should consider the following aspects:

* Existing land use;* Surrounding land use• Natural vegetation• Depth and quality of available topsoil• Estimated depth of the water table.

Access Roads

* To avoid unnecessary rehabilitation work later, confine vehicles to a single accesstrack, unless job safety is a risk or a scraper is to be used.

* The access track should enter the pit above the pit's lowest natural ground level.* Keep one-way access tracks less than 5 metres wide, and two-way less than 8

metres* Apply the same clearing and rehabilitation rules to access tracks as to the pit itself.

Site Preparation* All vegetation will be carefully stripped from the area and windrowed adjacent to

the site for use in reinstatement.* The borrow development area, stockpile area and limits of clearing will be staked

to prevent over-extension of the pit area.* Topsoil and overburden will be salvaged and placed in separate stockpiles on a

level and stable area. Topsoil stripping depth and storage locations will beidentified on plan diagrams as final designs become available.

* A minimum space of 5 meters will be maintained between the clearing edge andthe stockpile base. A minimum spacing of 10 meters will be maintained betweenexcavation perimeter and the stockpile base.

* Where practicable, pit excavation will not extend below the water table.* Drainage and erosion associated with each borrow operation will be controlled so

as to minimize terrain disturbance and siltation of water bodies.

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* Equipment movement will be restricted to a 30 meter working area at the pitentrance and to the \excavation area during pit development to preventunnecessary disturbance of the soil stockpiles and surrounding cleared areas.

* Pit slopes will be contoured to a 2:1 slope or less to minimize erosion instability.

Reinstatement and rehabilitation* Restoration and appropriate drainage and erosion control measures will be

implemented following site use and abandonment to prevent erosion and assistthe natural recovery.

* Spoils will be smoothed and gradients flattened to <25% and topsoil replacedand spread over the spoil.

* Rootstock material and cleared vegetation will be spread over the topsoil toencourage natural revegetation.

* Future potential site uses will be accommodated where practicable.

A schematic diagram for opening of a borrow pit is shown in Figure 1 below:

ALTERNATIVE OVERBURDEN

STOCKPILE WHERE2ACCESS USED

VEGETATIONREMOVED

TOP SOIL

OVERBURDEN

OVERBURDENACCESS..~ DEP.H PS

OPPITVEGETATION

ONE MACHINE REMOVED STANDINGLENT OmaF VEGETATION

Figure 1. Schematic diagram of a borrow in operation

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SECTION 4

CONTROL OF ILLEGAL HUNTING AND USE OF FIREWOOD ANDCHARCOAL

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CONTROL OF ILLEGAL HUNTING AND USE OF FIREWOOD AND CHARCOAL

Potential Impacts

Although the proposed transmission line passes through habitats that are depauperatein large mammals, small mammal species such as duiker, small antelope species andrabbits still occur. Hippopotamus occur in the Zambezi River and reedbuck ("chango")are occasionally found in riverine habitats.

It is common practice in Mozambique for mobile construction brigades to hunt for the potor purchase illegal bushmeat from local inhabitants. This will have a negative impact onthe remaining mammal populations which are already under threat.

Similarly, mobile brigades and staff at residential camps may use large quantities offirewood and charcoal if other alternative energy sources are not available. In somecases workers may resort to the production of charcoal or the purchase and sale ofcharcoal to make additional money.

Impact classification:

Likelihood: CertainExtension: LimitedDuration: Short-termIntensity: MediumSignificance in the absence of mitigation: Medium to lowSignificance with mitigation: Low

Mitigating Measures

By way of contract, the illegal hunting of wildlife (mammals, reptiles and birds) by allworkers must be forbidden. Penalties for illegal hunting must be applied by thecontractor in accordance with Mozambican labor laws.

The use firewood and charcoal should be discouraged through the provision ofalternative energy sources such as gas or kerosene at permanent and temporary(mobile) camps.

The Tete Provincial Services for Land and Forests (falling under the ProvincialDirectorate of Agriculture) should be informed about the Project by EdM and shouldhave an active role in the monitoring of illegal hunting and charcoal use. This could becarried out in parallel with the independent monitoring carried out by the EdMEnvironmental Unit.

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SECTION 5

COMPLIANCE WITH WORLD BANK ENVIRONMENTAL ANDSOCIAL SAFEGUARD POLICIES AND PROCEDURES

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COMPLIANCE WITH WORLD BANK ENVIRONMENTAL AND SOCIAL SAFEGUARDPOLICIES AND PROCEDURES

In this section the following World Bank documents are reviewed.

* The World Bank Operational Manual (Operational Policies and Bank Procedures)- Environmental Assessment, OP/BP 4.01 (January 1999).

* The World Bank Operational Manual (Operational Policies and Bank Procedures)- Natural Habitats. OP/BP 4.04 (January 1999)

* The World Bank Operational Manual (Operational Policies and Bank Procedures)- Involuntary Resettlement, OP/BP 4.12 (December 2001).

* The International Finance Corporation's Environmental Guidelines forOccupational Health and Safety (June 24, 2003).

* International Finance Corporation's Environmental, Health and Safety Guidelinesfor Electric power Transmission and Distribution (Jull 1, 1998)

The purpose of this review is twofold:

1. To ensure that the proposed project concept is environmentally sound, and

2. To assess the relevance of these documents to the proposed project.

Environmental Assessment (OP and BP 4.01)

The World Bank's environmental assessment operational policy establishes the fact thatsome level of environmental assessment is required for all Bank financed developmentprojects.

According to OP 4.01 the Bank classifies proposed projects into one of four categories,depending on the type, location, sensitivity, and scale of the project and the nature andmagnitude of its potential environmental impacts:

Category A: A proposed project is classified as Category A if it is likely to have significantadverse environmental impacts that are sensitive, diverse, or unprecedented. For aCategory A project, the borrower is responsible for preparing a report, normally an EIA (ora suitably comprehensive regional or sectoral EA).

Category B: A proposed project is classified as Category B if it's potential adverseenvironmental impacts on human populations or environmentally important areas-including wetlands, forests, grasslands, and other natural habitats-are less adverse than

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those of Category A projects. These impacts are site-specific; few if any of them areirreversible; and in most cases mitigatory measures can be readily designed.

Category C: A proposed project is classified as Category C if it is likely to have minimal orno adverse environmental impacts. Beyond screening, no further EA action is required fora Category C project.

A typical EA will:

* Evaluate a project's potential environmental risks and impacts in its area of influence.

* Examine project alternatives.

* Identify ways of improving project selection, siting, planning, design, andimplementation by preventing, minimizing, mitigating, or compensating for adverseenvironmental impacts and enhancing positive impacts.

* Include the process of mitigating and managing adverse environmental impactsthroughout project implementation.

* The Bank favors preventive measures over mitigatory or compensatory measures,whenever feasible.

Depending on the nature and scope of EA, the following factors may need to be taken intoconsideration, and in an integrated way:

* The natural environment (air, water, and land)

* Human health and safety

* Social aspects (involuntary resettlement, indigenous peoples, and cultural property)

* Transboundary and global environmental aspects

* The findings of country environmental studies

* The country's overall policy framework, national legislation, and institutionalcapabilities related to the environment and social aspects

* Obligations of the country, pertaining to project activities, under relevant internationalenvironmental treaties and agreements

Bank policy also requires that EA is initiated as early as possible in project processingand is integrated closely with the economic, financial, institutional, social, and technicalanalyses of a proposed project.

The commissioning of EA work is the responsibility of the borrower and the Bank reviewsthe findings and recommendations of the EA to determine whether they provide anadequate basis for processing the project for Bank financing. When the borrower has

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completed or partially completed EA work prior to the Bank's involvement in a project, theBank reviews the EA to ensure its consistency with this policy.

OP 4.01 also determines that (a) before the Bank proceeds to project appraisal, the EAreport must be made available in a public place accessible to affected groups and localNGOs and must be officially submitted to the Bank; and (b) once the Bank officiallyreceives the report, it will make the report available to the public through its InfoShop.

The WB categories are broadly in agreement the those of the new Environmental ImpactAssessment Regulations passed by the Council of Ministers in July 2004 (Decree N°45/2004). With regards to energy sector projects classified as Category A that willrequire an EIA include:

* High tension electrical energy transmission lines with a capacity of or greaterthan 110 kV;

* Projects that imply the temporary or permanent displacement of people andcommunities

The preparation of a Category A EIA has been carried out by the project proponent(EdM). The EIA included a full Public Consultation process the findings of which areinclude and an Annex to the EIA Report. The EIA Report is a public document and hasbeen made available to the pubic for comments and review as part of the PublicConsultation process in Mozambique In commissioning the formulation of the EIA and bymaking the document available to the public, the proposed project is in compliance withOP 4.01.

Natural Habitats (OP & BP 4.04)

The Bank supports the protection, maintenance, and rehabilitation of natural habitats andtheir functions in its economic and sector work, project financing, and policy dialogue andexpects borrowers to apply, a precautionary approach to natural resource management.

In the context of current project implementation and development the following elementsof Bank policy will apply:

1. The Bank does not support projects that, in the Bank's opinion, involve the significantconversion or degradation of critical natural habitats.

2. Wherever feasible, Bank-financed projects are sited on lands already converted(excluding any lands that in the Bank's opinion were converted in anticipation of theproject). The Bank does not support projects involving the significant conversion ofnatural habitats unless there are no feasible alternatives for the project and its siting,and comprehensive analysis demonstrates that overall benefits from the projectsubstantially outweigh the environmental costs. If the environmental assessmentindicates that a project would significantly convert or degrade natural habitats, theproject includes mitigation measures acceptable to the Bank. Such mitigationmeasures include, as appropriate, minimizing habitat loss (e.g., strategic habitatretention and post-development restoration) and establishing and maintaining anecologically similar protected area.

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3. The Bank will not finance subprojects "involve the significant conversion ordegradation of critical natural habitats".

The EIA has taken into account the routing of the proposed transmission line in order toprevent the transformation of undisturbed natural habitat and OP4.04 is consequently nottriggered.

Involuntary resettlement (OP & BP 4.12)

The World Bank's policy on Involuntary Resettlement (OP 4.12) applies to all landacquisition and any changes in access to resources due to a subproject. The policyapplies whether or not affected persons must move to another location. The Bank's policyrequires a Resettlement Action Plan (RAP) for any subproject that involuntarily displacespeople from land or productive resources, and the displacement results in:

* relocation, the loss of shelter, the loss of assets or access to assets important toproduction;

* the loss of income sources or means of livelihood; or* the loss of access to locations that provide higher incomes or lower expenditures

to businesses or persons.

The transmission line route will result in minimal displacement and the temporary loss ofland and crops. These project thus will result in either land acquisition, or displacement ofpeople, or both, so OP/BP 4.12 on Involuntary Resettlement is triggered. A separateResettlement Policy Framework (RPF) document has been prepared and wheneverresettlement is required resettlement planning and implementation will adhere to theguidelines laid out in RPF document. The RPF describes when the preparation of aResettlement Action Plan (RAP) is required and how to prepare a RAP.

The Safeguard polices of concern for the proposed Tete-Malawi Transmission lineProject are summarized in Table 3.

Table 1. Safeguard policies triggered by the proposed projectSafeguard Policy Yes NoEnvironmental Assessment (OP/BP 4.01) [X1 I11Natural Habitats (OP/BP 4.04) [ [XIPest Management (OP 4.09) [ [X ICultural Property (OPN 11.03, being revised as OP [I [XI4.11) ]_[_]Involuntary Resettlement (OP/BP 4.12) [XIIndigenous Peoples (OP/BP 4.10) [XIForests (OP/BP 4.36) [ [XISafety of Dams (OP/BP 4.37) [ [XIProjects in Disputed Areas (OP/BP 7.60) [XProjects on International Waterways (OP/BP 7.50) n [x I

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IFC Environmental Guidelines for Occupational Health and Safety (June 24, 2003).

These Guidelines contains the performance levels and measures that are normallyacceptable to IFC and are generally considered to be achievable at reasonable costs byexisting technology.

During the construction phase of the proposed Mozambique - Malawi transmiion line acertain amount of hazardous materials will be used. These include fuel, engine oils,paints and anti-corrosives. The proper, strorage and handling of these material is ofconcern. The following aspects of the IFC Environmental Guidelines for OccupationalHealth and Safety are, therefore, of relevance,

Signaqe

Hazardous and risky areas, installations, materials,safety measures, emergency exits,etc. shall be adequate for safe execution of all activities appropriately marked. Signageshall be in accordance with international standards, be well known to, and easilyunderstood by workers, visitors and the general public as appropriate.

Hazardous Materials

Organizations that produce, handle, store, transport ad dispose of hazardous materials(chemicals, gases, vapors, fumes, dust, fibers, etc.) shall in addition to the presentguidelines fulfill the requirements of the FC Hazardous Materials ManagementGuidelines.

The employer shall avoid the use of any hazardous substance by replacing it with asubstance that under its normal conditions of use is not dangerous or less dangerous tothe workers, if the nature of the activity so permits. Precautions must be taken to keepthe risk of exposure as low as possible. The employer must ensure that all chemicalsand hazardous materials are labeled and marked according to national and internationalrecognized standards and requirements

The Environmental Management Plan in the EIA Report specifically emphasizes theneed for sound management of hazardous and chemical substances (HCS). Thefollowing (in italics) is laid down in the EMP:

All the HCS should be handled, stored and discarded in a safe and responsible way, soas to avoid soil contamination, water pollution and/or harm to people or animals resultingfrom their use.

The Contractor should comply with all the Mozambican laws and regulations, as well aswith the relevant conditions regarding applicable authorizations and approvals in thecase of storage, use and adequate disposal of hazardous materials.

The Contractor should prepare a method statement for hazardous and toxic materialsand waste management on the construction site and outside of it. This plan shouldinclude preventive measures for soil contamination, water pollution, accidental fires andrisks/harm to people and animals, but should however not be limited to these aspects.

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Landfills of hazardous materials and waste on the construction site will be prohibited.

DDT shall not be used in the area for malaria control or for any other purpose.

The Contractor's Health, Safety and Environment Procedures (HSE) must be followedfor the communication and control of accidents with chemicals.

In addition to these procedures, measures should be taken, with special emphasis onthe storage and handling of fuel and lubricants.

Prevention of fuel and lubricants spills

Storage and handling of fuel and lubricants

* The fixed fuel storage tanks should not be situated in any area different from theapproved one for the execution of the works and the construction of the camps.

* The fuel storage installations with a capacity over 1000 litres should be situatedin an even of slightly sloping terrain. There should be a bund around the areawith a capacity to contain at least 125% of the total capacity of the storage tanks.The bund and the floor of the storage area should be built with impermeablematerial or contain an impermeable layer to ensure that the petroleum productsdo not escape.

* All the fixed storage areas should be isolated by a security fence with a lockablegate. Symbolic safety signs should be posted at the area with indications such as'no smoking' 'no naked lights' and 'danger' in conformity with a recognizedstandard.

* Fuel storage and vehicles repair and refuelling should be done at a distance of atleast 100 metres from any housing area, watercourse or wetland, floodplain orwhere there is a potential risk of fuel spills contaminating the watercourse or thegroundwater. The fixed fuel store should always be situated within theboundaries of the camp.

* Where watercourses and wetlands are traversed, the instruments and equipmentto be used on-site, such as pumps, compressors and generators, should beinstalled on a impermeable layer (e.g., polyethylene or other similar material), toavoid hydraulic fluid or fuel spills contaminating the soil or the groundwater, or toenter some watercourse or wetland. All reasonable precautions should be takento avoid fuel or lubricant spills. To this end, the Contractor should ensure that:

> diesel drums and tanks are not filled above their maximum or securitycapacity;

> regular audits are performed to guarantee that no leaky or defectiveequipment is brought to the site;

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any fluids or lubricants spilled during vehicle routine maintenance iscollected in trays, in another type of recipient or through anotheradequate collection way.

> equipment should be inspected regularly to ensure that fuel, lubricant orhydraulic spills do not occur.

> oil, grease and other contaminating substances that may affect water lifeshould be cleaned in all equipment to be used in areas containing fishresources.

> there should be sufficient absorbent material available on-site for use inthe event of accidental spills. An inventory should be compiled of thismaterial and information spread about their location in the area; thisshould be included in the method statements.

> accidental fuel, lubricants or other hazardous substance spills must beimmediately cleaned and the incident reported through the incidentinformation transfer procedure and communicated to EdM. The measurestaken to remedy the spills problem should be entered into the incidentreport and communicated to EdM.

Provided that the guidelines laid down in the ENP the project will be in compliance withIFC Environmental Guidelines for Occupational Health and Safety with regards tohazardous materials.

International Finance Corporation's Environmental, Health and Safety Guidelinesfor Electric power Transmission and Distribution (July 1 1998)

The following components of these Guidelines are of particular relevance to theMozambique - Malawi transmission line project:

Right-Of-Way Alignment

a) All new rights-of way should be aligned taking environmental factors intoconsideration, in a manner which will minimize to the extent possible, the needfor physical alteration and the cultural resources, agricultural lands andresidential and commercial areas.

b) Land acquisition must be carried out in accordance with World Bank resettlementguidelines which require identification and quantification of any impacts on land-based livelihood, and compensation to landowners and people relying on theland for their livelihood.

Hazardous Material Handling and Storage

a) All hazardous (reactive, flammable, radioactive, corrosive and toxic) materialmust be stored in clearly labeled contained or vessels.

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b) Storage and handling of hazardous material must be in accordance with localregulations, and appropriate to their hazard characteristics.

Electrocution

a) Strict procedures for de-energizing and checking of electrical equipment must bein place before any maintenance work is conducted.

b) In case where maintenance work has to be performed on energized equipment, astrict safety procedure must be in place and work must be performed underconstant supervision.

c) Personnel training must be conducted in revival techniques for electrocution.

With regards to the right of way alignment: the EIA has taken environmental factors intoconsideration in order to minimize to the extent possible impacts on the naturalenvironment and social environments. A stand alone Policy Resettlement Framework hasalso been produced

With regards to Hazardous Material Handling and Storage: as highlighted above theEnvironmental Management Plan specifically emphasizes the need for soundmanagement of hazardous and chemical substances (HCS).

With regards to electrocution: EdM workers comply with the Manual for Personal Safetyin Electrical Installations (published in 1992) that provides details on techniques,reporting, and safety measures for working on high voltage transmission lines. Regulartraining courses in safety are also held for EdM staff.

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