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AUGUST 24 2015

Environmental and Social Management Plan (ESMP)

Refuse Collection and Disposal Activity in Six Pilot Cities in Delta State,

State Employment and Expenditure for Results (SEEFOR) Project

E4839

AUGUST 24 2015

Table of ContentsEXECUTIVE SUMMARY.........................................................................................................................vii

CHAPTER ONE INTRODUCTION.....................................................................................................15

1.1 Project Background....................................................................................................................15

1.2 Purpose of the ESMP.................................................................................................................16

1.3 Objectives of the ESMP..............................................................................................................17

1.4 Objective of the Consultancy Service.........................................................................................17

1.4.1 Scope of Works..........................................................................................................18

1.5 Overview of Institutional Responsibilities..................................................................................18

1.6 Project Categorization...............................................................................................................18

1.7 Technical Approach and Methodology......................................................................................19

CHAPTER TWO DESCRIPTION OF THE PROJECT AREAS........................................................................20

2.1 Overview of the Project State.................................................................................................20

2.2 Physical Environment of Delta State.......................................................................................21

2.2.1 Climate...........................................................................................................................21

2.2.2 Temperature..................................................................................................................21

2.2.3 Rainfall...........................................................................................................................21

2.2.4 Relative humidity................................................................................................................22

2.2.5 Wind Speed.........................................................................................................................22

2.2.6 Wind Direction...............................................................................................................22

2.2.7 Geology..........................................................................................................................22

2.2.8 Soil......................................................................................................................................23

2.2.9 Drainage..............................................................................................................................23

2.3 Biological Environment..............................................................................................................24

2.3.1 Flora...............................................................................................................................24

2.3.2 Fauna.............................................................................................................................24

2.3.3 Ecological Issues..................................................................................................................24

2.4 Social Environment....................................................................................................................25

2.4.1 Demographics............................................................................................................25

2.4.2Local Economy.....................................................................................................................27

2.4.3Land Use/Tenure.................................................................................................................28

2.4.4Historic and Cultural Resources...........................................................................................28

2.4.5Unemployment Rate in Delta State.....................................................................................28

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2.5 Socio-economics Assessment....................................................................................................28

2.5.1 Methodology...............................................................................................................29

2.5.2 Transport and access..........................................................................................................33

2.5.3 Conflicts and Grievance Redress Mechanism.....................................................................33

2.6 Overview of the current waste management situation in pilot cities.....................................33

2.6.1 Waste characterisation and quantification.........................................................................34

2.6.1 Existing Refuse Management Conditions............................................................................35

2.7 Health Assessment....................................................................................................................42

CHAPTER THREE PROJECT DESCRIPTION.............................................................................................43

3.1 Introduction...............................................................................................................................43

3.2 Fundamentals of Sound Waste Management............................................................................43

3.2.1 Guideline for classification of waste...................................................................................44

3.2.2 Waste Generation...............................................................................................................46

3.2.3 Waste segregation..............................................................................................................47

3.2.3 Collection and on-site transportation.................................................................................47

3.2.5 On-site storage...................................................................................................................48

3.2.6 Off-site transportation........................................................................................................48

3.2.7 Treatment and disposal......................................................................................................49

3.3 Delta State SEEFOR Sanitation Project.......................................................................................49

3.3.1 PROPOSED ENUMERATION PLAN.......................................................................................50

3.3.2 PROPOSED COLLECTION AND DISPOSAL PLAN...................................................................57

CHAPTER FOUR POLICY LEGAL AND REGULATORY FRAMEWORK...................................................58

4.1 Introduction...............................................................................................................................58

4.2 Some Relevant Regulatory Instruments....................................................................................58

4.3 Federal Policy/Legislation..........................................................................................................58

4.4 Other Acts and Legislation.........................................................................................................61

4.5 The World Bank Environmental and Social Safeguards.............................................................64

CHAPTER FIVE ASSESSMENT OF POTENTIAL IMPACTS AND MITIGATION/ENHANCEMENT MEASURES.............................................................................................................................................................68

5.1 Introduction...............................................................................................................................68

5.2 Associated and Potential Environmental Impacts......................................................................68

5.2.1 Rating of Impacts......................................................................................................68

5.2.2 Associated and Potential Impacts Determination.........................................72

5.3 Potential Positive Impacts of The Refuse collection and Disposal Project.................................72

5.4 Potential Negative Impacts of the Refuse collection and Disposal Project................................74

5.5 Environmental and Social Management Plan............................................................................81

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5.6.1 Overview.......................................................................................................................81

5.6.2 ESMP and Monitoring Plan Budget...................................................................81

5.5 Health and Safety Management Plan...................................................................................106

5.6 General procedures to be followed in case of spillages...........................................................106

5.7 Post Exposure Prophylaxis Guidelines for Occupational Exposure..........................................107

5.7 Mitigation Measures for Refuse collection and Disposal Project..........................................110

5.8 Monitoring Program................................................................................................................111

5.9 REQUIREMENTS.......................................................................................................................111

CHAPTER SIX STAKEHOLDERS ENGAGEMENT....................................................................................113

6.1 Introduction.............................................................................................................................113

6.2 Objectives of the Public Consultation...................................................................................113

6.3 Stakeholders Identification..................................................................................................113

6.4 Consultation Methodologies................................................................................................114

6.5 Major Point of the Consultation...........................................................................................114

6.6 Major Findings from Public Consultation..............................................................................114

CHAPTER SEVEN INSTITUTIONAL ARRANGEMENT.............................................................................117

7.1 Introduction.............................................................................................................................117

7.2 Administrative Framework......................................................................................................117

7.3 SEEFOR Institutional Arrangements.........................................................................................117

7.4 Roles and Responsibilities........................................................................................................118

7.4.1 Federal Level Institutions.............................................................................................119

7.4.2 State Level Institutions.................................................................................................122

7.4.3 Local Government Level Institutions............................................................................125

7.4.4 Community Level and other Institutions......................................................................125

7.4.5 World Bank..................................................................................................................125

7.5 DELTA STATE MINISTRY OF ENVIRONMENT............................................................................126

7.6 MINISTRY OF ECONOMIC PLANNING.......................................................................................127

7.6.1 MINISTRY OF LANDS, URBAN AND REGIONAL PLANNING............................................127

7.6.2 MINISTRY OF WORKS...................................................................................................128

7.6.3 MINISTRY OF AGRICULTURE AND NATURAL RESOURCES.............................................128

7.6.4 MINISTRY OF WATER RESOURCES DEVELOPMENT......................................................128

7.6.5 MINISTRY OF WOMEN AFFAIRS COMMUNITY AND SOCIAL DEVELOPMENT...............129

7.6.6 MINISTRY OF YOUTH, CULTURE AND EMPLOYMENT...................................................130

ANNEXURES.......................................................................................................................................131

ANNEX ONE SUMMARY OF WORLD BANK SAFEGURAD POLICIES................................................131

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ANNEX TWO GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS.......................................................................................................................................135

ANNEX THREE SUMMARY OF THE DATABASE OF INFORMATION COLLECTED FOR ESMP.................144

Questionnaire - Households..........................................................................................................144

Questionnaire - Waste Collectors..................................................................................................144

Questionnaire – Min of Environment, SEEFOR, Waste Management Board.................................144

Questionnaire – Scavengers..........................................................................................................145

ANNEX FOUR GRIEVANCE REDRESS MECHANISM.............................................................................146

ANNEX FIVE LIST OF STREETS WITHIN THE ZONES IN EACH OF THE PILOT CITIES.............................157

Table 1 Representation Number of Zones in the Pilot Cites in Delta State............................................................................................................19

Table 2 Some Common Plants found within project community..............24Table 3 Estimated waste generation per city...........................................34Table 4 Likelihood of occurance of Impact...............................................70Table 5 Potential Consequences Classification Matrix.............................70Table 6 Potential Consequences...............................................................70Table 7 Degree of Impact Significance.....................................................71Table 8 Impact Assessment Matrix...........................................................71Table 9 Identified Potential Impact Ratings.............................................75Table 10 ESMP and Monitoring Plan- Refuse Collection and

Transportation Phase for Asaba.........................................................82Table 11 ESMP and Monitoring Plan- Refuse Disposal Phase for Asaba. 84Table 12ESMP and Monitoring Plan- Refuse Collection and

Transportation Phase for Warri..........................................................86Table 13 ESMP and Monitoring Plan- Refuse Disposal Phase for Warri..88Table 14 ESMP and Monitoring Plan- Refuse Collection and

Transportation Phase For Ughelli......................................................90Table 15 ESMP and Monitoring Plan- Refuse Disposal Phase For Ughelli

............................................................................................................92Table 16 ESMP and Monitoring Plan- Refuse Collection and

Transportation Phase For Sapele.......................................................94Table 17 ESMP and Monitoring Plan- Refuse Disposal Phase for Sapele96Table 18 ESMP and Monitoring Plan- Refuse Collection and

Transportation Phase Uvwie..............................................................98Table 19 ESMP and Monitoring Plan- Refuse Disposal Phase Uvwie....100Table 20 ESMP and Monitoring Plan- Refuse Collection and

Transportation Phase Udu................................................................102Table 21ESMP and Monitoring Plan- Refuse Disposal Phase Udu.........104Table 22 Safeguards responsibility for SEEFOR....................................120

Figure 1 Map showing Delta State and the Six pilot cities......................20Figure 2Waste Bins at a Residential Area................................................36Figure 3Waste Collector at Dumpsite......................................................36Figure 4 Pay loader at work at the Dumpsite...........................................36

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Figure 5 one of the Inaccessible area at Cable point...............................36Figure 6Waste Bin at a Private Healthcare Facility.................................36Figure 7Scavengers at work.....................................................................36Figure 8Dumpsite overflowing into access road......................................37Figure 9Illegal Dumpsite behind the Court..............................................37Figure 10one of the PSPs at work............................................................37Figure 11One of the Inaccessible areas due to flood...............................37Figure 12 Blocked drainage by refuse......................................................38Figure 13Private (unapproved) dumpsite.................................................38Figure 14 refuse dumped in the Middle of the road................................39Figure 15 Private dumpsite Near a Market at Okpe Road.......................40Figure 16 PSP and Waste Collector at a Private Dumpsite......................40Figure 17 Illegal dumpsite near Residential Building..............................40Figure 18 materials sorted by Scavangers...............................................40Figure 19Blocked drainage and illegal Refuse dump at residential area 40Figure 20Refuse dumped in-between main road......................................40Figure 21Illegal dumpsite and Blocked drainage.....................................41Figure 22Refuse dump at the Centre of the Market................................41Figure 23an Illegal Dumpsite...................................................................41Figure 24Illegal Dumpsite........................................................................41Figure 25 temporary approved dumpsite.................................................42Figure 26 an Illegal Dumpsite..................................................................42Figure 27 Map of Warri showing some of the zones................................51Figure 28Map of Ughi showing some of the zones..................................52Figure 29Map of Asaba showing some of the zones.................................53Figure 30 Map of Udu showing some of the zones..................................54Figure 31Map of sapele showing some of the zones................................55Figure 32Map of Uvwie showing some of the zones................................56Figure 33 Impact Rating tool....................................................................68

List of Acronyms and Their Definitions

DELSEPA Delta State Environmental Protection Board

DELSWMB Delta State Waste Management Board

EA Environmental Assessment

EIA Environmental Impact Assessment

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Impact Assessment

FMENV Federal Ministry of Environment

HCW Healthcare waste

HCF Healthcare facility

HSE Health, Safety and Environment

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IDA International Development Agency

JHA Job Hazard Analysis

LGA Local Government Area

NSPCU National Project Coordinating Unit

OHS Occupational Health and Safety

PDO Project Development Objective

PFM Public Financial Management

PPE Personal Protective Equipment

PSPs Private Sector Participants

SEEFOR State Employment and Expenditure for Results

SMENV State Ministry of Environment

SPCU State Project Coordination Unit

WB World Bank

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EXECUTIVE SUMMARYIntroduction

The Federal Government of Nigeria is implementing the multi-state and multi-sectoral State Employment Expenditure for Results (SEEFOR) Project in four Niger-Delta region states (Bayelsa, Delta, Edo and Rivers States), which is financed through credit from the International Development Association (IDA) and grants from the European Union towards the cost of implementing the project. The project development objective (PDO) is to enhance opportunities for employment and access to socio-economic services, while improving the public expenditure management systems in the participating states. The main beneficiaries of the project are the four state governments with selected ministries, departments and agencies and communities in Bayelsa, Edo, Delta and Rivers states.

As one of the beneficiary state, Delta state intends to apply part of the proceeds for provision of consultancy services for the Preparation of an Environmental Management Plan (EMP) for Sanitation Activities in six pilot cities (Asaba, Sapele, Udu, Ughelli, Uvwue, and Warri).

The project will give rise to the:

Improved hygiene within the selected propjet cities Creation of Employment for youths within project area and state as

a whole

Objectives of the project

The project aims to ensure employment generation through small public works and access to socio-economic services while improving the Public

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Financial Management system of participating State. This is tailored towards promoting accountability and transparency in the utilization of public finances, which in turn translates into employment opportunities for the youths. The public works on Road construction and maintenance activity will enable small contractors employ local resident in the participating states to undertake activities in the areas of labour for the projects.

The purpose of the Environmental and Social Management Plan (ESMP) is to:

Identify the beneficial and adverse impacts of the sub-activities on the physical, biological and socio-economic environments.

Proffer suitable mitigation measures for potentially adverse environmental and social impacts, and measures for enhancement of positive impacts. This will be accomplished through a comprehensive Environmental and Social Management Plan (ESMP) for the project and a viable Monitoring Plan for evaluating ESMP implementation.

Define the specific actions required, roles and responsibilities for these actions, and associated costs and,

Define a proposed institutional structure to govern the implementation of the ESMP.

The need to prepare an Environmental and Social Management Plan (ESMP) is to provide a framework of procedures through which SEEFOR Project will develop and implement environmental, social, health, and safety management systems, programs, processes and procedures that will establish a foundation for sound mitigation of adverse impacts, enhancement of positive impacts, institutional responsibilities, indicative costs for mitigation and eventual monitoring of the ESMP.

The methodology used for the conduct of the Environmental and Social Management Plan (ESMP) for the project was based on guidelines as proposed by the following:

Federal Government of Nigeria EIA Law and subsequent Federal Ministry of Environment standard procedures for conducting EIA/ESIA in Nigeria.

Guidelines documented under the World Bank Environmental Assessment Operational Policy OP 4.01.

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Policy, Legal and Regulatory Framework

The ESMP documents relevant national and international environmental guidelines applicable to the proposed small public works activities including the safeguard policies of the World Bank. Some of the national legal instruments identified include the Environmental Impact Assessment Act No. 86, 1992 (FMEnv), National Guidelines and Standards for Environmental Pollution Control in Nigeria, Delta State Environmental Sanitation Authority Edict, 1999, etc. The safeguard policies triggered by the project on which the ESMP has been prepared is OP 4.01 Environmental Assessment of the World Bank. The bank’s polices identify Environmental and Social Management Plan (ESMP) as a critical safeguard instrument for assessing the potential environmental and social risks and benefits (impacts) associated with investment lending operations.

In the case of divergence between the Nigerian EIA law and safeguard policies of the Bank, the more stringent policy(s) takes precedence, which in this case is the policy of the donor agency (the World Bank).

Project Description and Justification

The project is designed around two main components - public financial management (PFM and service delivery - under which selected activities will be implemented to produce outputs that will contribute towards the achievement of the PDO. The latter will have three sub-components: a) training and skills development; (b) youth employment and (c) Community Driven Development (CDD).

The SEEFOR sub-project involves refuse collection and disposal within the selected six pilot cities of Delta state. The Refuse Collection and Disposal Project is tailored towards maintaining good hygiene while promoting accountability and transparency in the utilization of public finances which in turn translates into employment opportunities for the youths.

The improvement in refuse collection and disposal system will play an important role in enabling ca conducive and health environment for trade

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and investment as well as ecstatic. This system will also improve livelihoods and promoting goodwill between the people and the state government.

Proposed Sanitation ActionsThese will include;

Refuse Collection Refuse Transportation Refuse Disposal

Description of the Project Area

Delta State is located in the South-south geopolitical zones of Nigeria with a population of 4,098,291 (2006 Census). The states bordering Delta State are Edo to the north, Ondo to the northwest, Anambra to the east and Bayelsa and Rivers to the southeast. On its southern flank is 160 km of the coastline of the Bight of Benin. The ethnic groups found in Delta State include Urhobo, Isoko, Anioma, Ijaw and Itsekiri. The natural vegetation is of rainforest with swamp forest in some areas. The forest is rich in timber trees, palm trees, as well as fruit trees.

Climate and Geology of Delta StateDelta State is located within the lower delta plain believed to have been formed during the Holocene of the quaternary period by the accumulation of sedimentary deposits. The major geological characteristic of the state is sedimentary alluvium. The entire state is formed of abandoned beach ridges and due to many tributaries of the River Niger in this plain, considerable geological changes still abound.

Delta State has a semi-hot, humid equatorial climate with wide variations from one part of the state to another. This is a place of uniformly high temperatures throughout the year, high relative humidity and intense rainfall, which occurs almost year round in the core delta, but becomes markedly seasonal further inland with increasing distance from the ocean. Copious rainfall coupled with the low relief and high water table produce frequent.

Baseline DataBaseline data were acquired during several field trips made to the various project sites and communities where construction works will be done. And results gathered.

Potential Impacts and Mitigation Measures

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Potential Positive Impacts of the Road Construction and Rehabilitation Project

The beneficial environmental and social impacts of the project will include:

Beneficial Impacts

Job creation to the teeming youth of the project communities.

Decrease in social vices.

The project will undertake focal group consultation, which will inform the basics for project concept decision-making and implementation and inform the basis for focal group discussions.

Proper maintenance of drainages.

Capacity building for the waste collectors, SEEFOR Project Office.

Encourage investment of interested stakeholders in exploring the waste management sector of Delta State.

Reduction in ecological issues e.g., flooding.

Intensifying community development programme.

Encourage livelihood-enhancing opportunities.

Improve health and safety in the waste collection processes.

Ensure clean environment within the cities and Delta State at large.

Minimization of nuisance e.g. odour

Reduction in pest and disease within the areas.

Adverse Impacts

Possible air pollution as the waste is transported from source to dumpsite

Possible introduction of new pests, vermin and birds at the dumpsites due to increased activity

Possible destruction of fences during passage of vehicle on the narrow streets.

Possible land acquisition as new dumpsites may be acquired.

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Environmental and Social Management Plan (Enhancement and Mitigation Measures)

Mitigation measures proffered are generally preventive and based on best practices with regards to impacts arising from identified specific activities to be carried out in the course of the project.

GHG Emissions: Proffered mitigation measures for these include regular maintenance of Compact trucks for collection, use of specified fuel etc

Occupational Health and Safety Risks: Measures for these enforce training of contractor’s personnel in safe work procedures prior to commencement of works.

Waste Disposal: Waste shall be transported in compact trucks or covered trucks to designated dumpsites approved by the SME and/or DELSEPA.

Traffic: Line configurations should be used to help reduce road traffic. Also the collection and disposal should be performed during low traffic period (early in the morning or late at night). This will coincide with the time when the road will be less busy. Creation of alternate route for road users during operation. Use of adequate machinery in relation to street size and capacity (e.g. wheel barrow/smaller vans for smaller streets) to avoid damage to buildings and properties, Training of drivers on road use, Use of caution signs during operation will mitigate traffic accidents.

Social impacts: Social mobilization and awareness programs will be conducted on the project and its benefits to enhance performance of the project. Hospitals, Schools, residents etc. should be provided facemasks in during work hours to reduce the inhalation of foul odor and emissions. Incorporate the youths of the project communities into the project from the inception to minimise conflict, Trainings and capacity building for the youths will be of importance. Provision of financial/technical assistance to enable PSPs meet required performance target and procure equipment. Alternative inexpensive yet environmentally sound methods can be employed or recommended for use (eg dina (15-25 ton) trucks covered with netting or trampoline), incorporate private dumpsite owners and cart pushers into the project to avoid loose of income: assign them other duties and responsibilities, develop Capacity building and skill acquisition programs,

Other mitigation measures for potential contamination of surface water, soils have been provided.

Monitoring Program

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It is planned that the environmental and social impacts and their designed mitigation measures shall be monitored during implementation of the refuse collection and disposal project. The roles and responsibilities for monitoring the environmental and social impacts and mitigation measures are as follows:

The State Employment and Expenditure for Results (SEEFOR) Project SPCU will ensure implementation of all mitigation measures. The State Ministry of Environment (SME), National Environmental Standards Regulatory Enforcement Agency (State), and Delta State Environmental Protection Agency (DELSEPA) will ensure implementation of measures that concern the environment. The Federal Road Safety Corps (FRSC) and Delta State Transport Management Authority will ensure that mitigation measures for impacts on traffic are implemented. Contractors will be responsible for task-specific mitigation. Independent Consultants will be responsible for the development of management plans as described in the ESMP (e.g. site-specific safety management plans, site-specific waste management plans, workers, respiratory protection program. Public Health departments in the project cities will be responsible for monitoring distribution of face masks to schools, offices etc.

The SME/DELSEPA will undertake compliance monitoring and periodic inspection of work areas. The Ministry of Works will also be involved in some level of monitoring.

All the mitigation measures specified in this plan shall be included in the bid documents for the successful enterprise to implement. Campaigns on HIV/AIDS, environmental protection and personal hygiene and sanitation shall also be undertaken. For this purpose, services of experienced NGOs in the fields would be sought.

The Cost Estimate and Responsibility for the Environmental and Social Managements Plan

The total cost for Implementing the ESMP and Monitoring Plan based on the two assessed phases is estimated at One hundred and Twenty Four Thousand US dollars ($124,000.00) for the Six (6) sites.

Public Consultation

The Stakeholder engagement (Focus Group Consultations) for the Environmental and Social Management Plan (ESMP) was conducted from26th of February to 4th of March, 2014. The consultation meetings were held at different locations within each of the six project cities. The

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consultation was done to ensure the effective participation and awareness of the stakeholders and Project Affected Persons (PAPs).

The small group consultations where conducted during field surveys and data gathering. Groups such as residents, market groups, and Youth leaders, shops, traditional leaders etc. where consulted to identify their perception of the project and document concerns.

General responses made by groups about the project where optimistic, however the major concerns where based on the frequency of visit by the PSPs. Other concern noted was the request to give the waste bags for free.

The public consultation process included:

Enumeration of the objectives for the public consultation

Identification of the major stakeholders

Interactive sessions

Documentation of concerns raised

Groups consulted include, SMEnv, DELSWMB, Market associations, traditional leaders, SEEFOR SPCU, Dumpsite manager, scavengers, youth associations, residents, shop owners, hospitals etc.

The issues, concerns and demands raised by the stakeholders during the Public consultation, and responses provided by the ESMP Consultant have been summarized and are provided below:

ISSUES/CONCERNS/DEMANDS REACTIONS BY SPCU, SMENV, WMB, CONSULTANT

That the Government should provide them with approved Dumpsite in cities such as Warri, Udu, Uvwie, Sapele and Ughelli

Also that Bulldozers be provided at the Dumpsites to enable 24hour work so as to avoid over flowing of dirt at dumpsites

The SMEnv, DELSWMB and the Local Government Authorities will provide designated dumpsites within close proximity of each of the cities.

SEEFOR highlighted their effort towards getting the government to procure the needed machinery and/or contract the management of

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The PSPs expressed their fear that politicians and rich businessmen may hijack the project and dump the existing Waste collectors. Also the PSPs pleaded that the SEEFOR SPCU should try and make the criteria for qualification too stringent for middle/low income earners to participate

Also that the SEEFOR SPCU should assist them in getting Loan facility from Banks to buy Compactor trucks or Tipping Trucks

That they will need regular training on Health and Safety

That the government should create access roads especially in the areas that are not accessible for easy movement of their truck.

That the SEEFOR should help enforce the use of the Waste Collectors (PSPs) by residents

That the Zones should be further sub-divided and more PSPs involved as each zone contains more than the stated number of

these dumpsites to a private contractor while the WMB monitors their activities.

They were assured that the criteria for selection which is in the PIM would be followed strictly. And expressed that the project was primarily to create jobs and not remove people from their jobs.

They SPCU stated that it is not in their power to assist the PSP to get loans, however, they will give technical support where need be.

SEEFOR inform the PSPs the need to have Health safety offices in their team and also stated that trainings may be arranged in due time.

Stated that there is currently ongoing road constructions within the state. Also that they inaccessible areas may need alternative means of waste evacuation( eg. smaller vans/wheel barrows)

There may be need to form a task force to monitor and ensure compliance. The members of the taskforce should include people living within their respective zones.

The SPCU stated that the enumeration exercise will

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houses recommended for the project. This will give room for better service.

The Residents stated that the SEEFOR should make the tariff affordable and uniform for the different categories

The PSPs also stated that the Government should look into the attacks by youths at the dumpsites (e.g. Ughelli)

Also other local revenue collector should be harmonized within the state to avoid double billing on the PSPs

That the government should also create more awareness to allow for maximum participation and cooperation by the residents.

The scavengers suggested that segregation at source should be encouraged to make their sorting easier and reduce risk of exposure especially with HealthCare Waste (needles and sharps).

assist in knowing the exact modality to use in dividing the zones. Also that after a few years, the performance will be assessed and then determine the need to further divide the zones.

The tariff will be worked out by a financial/billing expert to suit individuals, buildings, industries etc.

Constant awareness and incorporation of the youths and traditional rulers which is ongoing will prevent this in the future.

Since the project is backed by the government, in conjunction with waste management board and SMEnv, there will be harmony. So there will not be avenue for double billing.

There will be continues awareness campaign as part of the program. This will involve the media (TV and Radio), NGOs and other advertising agencies

They were told it may take a while but something can be started through the awareness and sensitization. Private sector companies were also encouraged to buy into the project as they can recover wealth from waste generated

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Budget: A total of $124,000.00 is required for the implementation of this ESMP. The break down for each of the cities is as follows: Asaba $24,800.00; Sapele $24, 800.00; Udu $12,400.00.; Ughelli $24,800.00; Uvwue $12,400.00.; and Warri $24,800.00.

In conclusion, the proposed mitigation and monitoring plan for the identified potential adverse impacts for the Delta SEEFOR sanitation project in six pilot cities in Delta state if adhered to will be adequate for the project. Based on this, the activities should be allowed to proceed.

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CHAPTER ONE INTRODUCTION

1.1 Project Background

The Federal Government of Nigeria has requested the assistance of the World Bank in implementing the multi-state and multi-sectoral State Employment and Expenditure for Results (SEEFOR).

The project development objective (PDO) is to enhance opportunities for employment and access to socio-economic services, while improving the public expenditure management systems in the participating states.

The main beneficiaries of the project are the four state governments with selected ministries, departments and agencies and communities in Balyesa, Edo, Delta and Rivers states.

Specifically the direct beneficiaries of Component A – Youth Employment and Access to Socio-Economic services – are mainly youths who are unemployed and/or seeking to be trained in vocational and technical courses in order to find jobs or set up on their own, the technical and vocational training institutions themselves and the state ministries of education and agriculture. In addition, the state agencies responsible for public works and waste management will be provided with technical assistance for their oversight function on the sub-component for youth employment. The beneficiaries of the CDD sub-component are community groups and associations in the four participating states, including farmers, women groups and youths in the rural areas. The PFM component will provide technical assistance to support reforms and capacity building in MDAs that deal with state public finance. These will include offices and staff of Ministries of Budget and/or Economic Planning, Finance, Due Process/Public Procurement, Board of Internal Revenue and State Houses of Assembly.

Achievement of the PDO will be measured by the following key performance indicators:

(a)Number of people employed under SEEFOR youth employment program in participating states (disaggregated by self-employed, formal employment, and gender);

(b)Number of people with access to services supported in targeted communities (disaggregated by specific services: water points, classrooms, electricity connections, improve sanitation facilities, etc.);

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(c) Percentage deviation of actual aggregate expenditure from budgeted expenditure in the participating states; and

(d)Percentage of public contracts above threshold awarded through competitive process in each participating state.

Despite being the second largest economy in Africa, unemployment of the youths in Nigeria is a vital issue that needs urgent intervention. Overall unemployment rate is about 21.4% and youth (15- 24 years) unemployment is about 25.2% and has been rising (NBS, 2011). The SEEFOR Project seeks to ensure that interventions through the various sub-projects address the unemployment issue in the various project states where the project will be implemented.

The SEEFOR Project consist of three components:

Component A: Youth Employment and Access to Socio-Economic Services

Component A will support three main activity areas:

Sub-component A1: Youth employment through small public works contracts and institutional strengthening.

Sub-component A2: Grants to public technical, vocational and agricultural training institutions.

Sub-component A3: Grants for community driven development initiatives.

Component B: Public Financial Management Reforms

Component C: Project Implementation Support and Coordination

The sub-project, for which this consultancy service is prepared for, focuses on the Sub-component A1. The overall objective of the sub-project is to ensure employment generation through small public works and access to socio-economic services while improving the Public Financial Management system of the four participating State. This is tailored towards promoting accountability and transparency in the utilization of public finances, which in turn translates into employment opportunities for the youths. The public works on Refuse collection and disposal activity will enable small contractors employ local labour resident in the participating states to undertake activities in the areas of Collection, Disposal and Sorting of Refuse.

As one of the beneficiary state, Delta state intends to apply part of the proceeds for provision of consultancy services for the Preparation of an


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Environmental and Social Management Plan (ESMP) for the Public Works Activity (Refuse Collection and Disposal) in six pilot cities; Asaba, Warri, Uvwie, Udi, Sapele and Ughelli.

Several documents have been prepared in line with the SEEFOR Project and they include: an Environment and Social Management Framework (ESMF), SEEFOR Project Appraisal Document (PAD) and SEEFOR Project Implementation Manual (PIM).

1.2 Purpose of the ESMP

The ESMP is an instrument that details the measures to be taken during the implementation and operation of a project to eliminate or offset adverse environmental and social impacts or to reduce them to acceptable levels; and the actions needed to implement these measures. The ESMP is an integral part of Category “A” Environmental Assessments (EAs) (irrespective of other instruments used). EAs for Category “B” projects may also result in an ESMP. However, the sub-projectis a Category B project as the impacts are envisaged to be minor and reversible with more likely beneficial impacts in the short and long- term.

The Environmental and Social Management Plan (ESMP) provides a framework of procedures through which SEEFOR will develop and implement environmental, social, health, and safety management systems, programs, processes and procedures that will establish a foundation for sound mitigation of adverse impacts, enhancement of positive impacts, institutional responsibilities, indicative costs for mitigation and eventual monitoring of the ESMP.

The ESMP outlines DELTA STATE SEEFOR SPCU corporate commitment to managing the project in a responsible, safe and sustainable manner whereby the protection of the environment, safety of people and social concerns take priority above all other business concerns.

The ESMP will also ensure compliance with applicable environmental standards all through the life span of the projects. If the recommendations and guidelines in this ESMP document are followed, it is envisaged that the anticipated potential negative environmental and social impacts associated with the sub-project will be markedly minimized, and the positive impacts enhanced.

The Bank will disclose the ESMP document publicly, in Nigeria and at the World Bank Info- shop before project appraisal.


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1.3 Objectives of the ESMP

The Overall objective of the ESMP is to ensure that the environmental and social issues likely to arise from the project activities are addressed and appropriate mitigation actions are integrated into the project implementation phase to protect the environment.

Specific objectives of this ESMP include the following:

To examine the project in terms of its major activities and identify the aspects associated with the project construction which generate environmental impacts,

Identify the environmental issues associated with the major activities,

Develop mitigation measures for the aspects identified as having environmental impacts,

Incorporate environmental mitigation measures into activities and develop corrective actions and ensure monitoring.

Define the specific actions required, roles and responsibilities for these actions, and associated costs and,

Define a proposed institutional structure to govern the implementation of the ESMP.

1.4 Objective of the Consultancy Service

The objective of the Consultancy Services under this sub-component of the SEEFOR project is to provide detailed information on the environmental and social impacts of the public works activities (refuse collection and disposal) to generate an Environmental and Social Management Plan (ESMP) for possible mitigation of environmental and social impact triggered in the cause of project implementation.

This report therefore, focuses on the Environmental and Social Management Plan for the Refuse collection and Disposal Activities in six (6) pilot cities in Delta State. The cities include Asaba, Warri, Uvwie, Udi, Sapele and Ughelli.

1.4.1 Scope of Works

The Consultant is required to carry out the following:

Identify the potential environmental and social impact of the project activities on the environment and people in the project area.


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Identify feasible and cost effective measures that may reduce potentially significant adverse environmental and social impact to acceptable levels;

Identifying monitoring objectives and specify the type of monitoring with linkages to the impacts assessed and mitigation measures

Provide specific description of institutional arrangements: the agencies responsible for carrying out the mitigation and monitoring measures (e.g. operations, supervision, enforcement, monitoring and implementation, remedial action, financing, reporting, and staff training) and contractual arrangements for assuring the performance of each implementing agency;

Define technical assistance programs that could strengthen an environmental management capability in the agencies responsible for implementation;

Provide an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plan;

Provide the expected capital and recurrent cost estimate for implementing the EMP so that these costs are duly taken into consideration in the (State Project Coordinating Unit) SSPCU work plan;

The consultant shall assist the SSPCU to: i. Register the EMP with the Environmental Assessment

(EA) Department at the Federal level and State levels; and ii. Disclose the finalized EMP at National, State LGAs and

Community levels Any other related tasks that may be assigned.

1.5 Overview of Institutional Responsibilities

The project is viewed to exhibit multi-sector operation, as the institutional arrangements need to pragmatically involve Federal and State ministries, and Ministries Department and Agencies (MDAs). The lead agency at the Federal level is the National Planning Commission and Federal Ministry of Finance while that of State is the Ministry responsible for Finance, State and Local Governments, State Ministries of Economic Planning, Environment, Works, Agriculture and Natural Resources, Ministry of Water Resources Development. Ministry of Lands, Urban and Regional Planning The Local Communities and Civil Societies Organization (CSOs) will also be involved in the project, given that the project is a multi-sector operation involving Activity Executing Agencies (AEAs) concerned with public works.


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1.6 Project Categorization

The Adverse impacts of the Refuse Collection and Disposal Activities under the SEEFOR Project will be largely reversible, indirect and short term. Considering the aforementioned, the project falls suitable into the World Bank’s category B, hence the most suitable safeguard instrument to address beneficial and adverse impacts is an Environmental and Social Management Plan (ESMP).

1.7 Technical Approach and Methodology

This ESMP has been prepared in accordance with standard procedures for environmental assessment including the applicable World Bank (WB) safeguard policies and Nigerian environmental assessment guidelines.

Literature Review: The methodology adopted for the ESMP studies involved an intensive application of desk reviews & collection of all relevant information in order to achieve successful outputs. Information was garnered from the Delta SEEFORSPCU.

These include;

1. Project Implementation Manual (PIM) for the SEEFOR Project2. Project Appraisal Document (PAD) for the SEEFOR Project3. Environmental and Social Management Framework (ESMF) for the

SEEFOR Project4. List of Zones within the Area and respective PSPs

Table 1 Representation Number of Zones in the Pilot Cites in Delta State

S/No. Cities Number of Zones1 Asaba 40 zones including the dumpsite

2 Uvwie 25 zones including the dumpsite

3 Sapele 19 zones including the dumpsite

4 Warri 30 zones including the dumpsite

5 Udu 32 zones including the dumpsite

6 Ughelli 11 zones including the dumpsite

Field Visit: This activity involved:

Visit to SEEFOR project Office


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The six project cities ( Asaba, Sapele, Udu, Ughelli, Uvwie and Warri)

Impact Identification and Assessments

Potential Impacts Assessment and definitions

Oral interview with Residents, PSPs, DELSWMB

Stakeholders Engagement/Consultation

CHAPTER TWO DESCRIPTION OF THE PROJECT AREAS

2.1 Overview of the Project State

Delta State is located in the South-south geopolitical zones of Nigeria with a population of 4,098,291 (2006 Census). The states bordering Delta State are Edo to the north, Ondo to the northwest, Anambra to the east and Bayelsa and Rivers to the southeast. On its southern flank is 160 km of the coastline of the Bight of Benin. The ethnic groups found in Delta State include Urhobo, Isoko, Anioma, Ijaw and Itsekiri.

The state lies between longitudes 5°00 and 6o45'E and latitudes 5°00 and 6°30'N. The State has a total land mass area of 16,842 sq.km and consists of 25 local government areas. They include: Aniocha North, Aniocha South, Bomadi, Burutu, Ethiope East, Ethiope West, lkaNorthEast, lka South, Isoko North, Isoko South, Ndokwa East, Ndokwa West, Okpe, Oshimili North, Oshimili South, Patani, Sapele, Udu, Ughelli North, Ughelli South, Ukwani, Uvwie, Warri North, Warri South and Warri South West.


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2.2 Physical Environment of Delta State

2.2.1 ClimateDelta State has a semi-hot, humid equatorial climate with wide variations from one part of the state to another. This is a place of uniformly high temperatures throughout the year, high relative humidity and intense rainfall, which occurs almost year round in the core delta, but becomes markedly seasonal further inland with increasing distance from the ocean. Copious rainfall coupled with the low relief and high water table produce frequent.

The natural vegetation is of rainforest with swamp forest in some areas. The forest is rich in timber trees, palm trees, as well as fruit trees.

2.2.2 TemperatureTemperatures are high and fairly constant throughout the year. The area is has a mean annual temperature of 32.8 °C. Average monthly temperatures for the warmest months (February to April) range from 28 °C to 33 °C, while the average monthly temperatures for the coolest months, June to September, range from 21 °C to 23 °C.

Delta State SEEFOR

Jan F eb Mar A p r May Jun Ju l A ug S ep t O c t Nov D ec05

10152025303540

average temperatureWarmest Coldest

25

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2.2.3 RainfallThe region experiences moderate rainfall and moderate humidity for most part of the year. The climate is equatorial and is marked by two distinct seasons: the dry season and the rainy season. The dry season lasts from about November to April and is significantly marked by the cool "harmarttan" dusty haze from the north-east winds. The rainy season spans May to October with a brief dry spell in August, but it frequently rains even in the dry season. The area is characterized by tropical equatorial climate with annual rainfall amount of 2673.8 mm

2.2.4 Relative humidityThe pattern of relative humidity correlated with that of the rainfall described above. High values (over 95%) occurred in the rainy season. In the dry season, the high daily relative humidity values ranged from 86.5 to 92.0% and occurred between 2100 and 2400hrs and later from 0100 to 0800hrs.

2.2.5 Wind SpeedWind speed is usually about 4 m/s under calm conditions most of the year. Relatively higher wind speeds may occur mainly in the afternoons inducing convective activities and creating diffusion characteristics. Incidences of these are often associated with thunder and lightning especially during changing seasons. Atmospheric disturbances such as line squalls and disturbance lines often induce the variability that results in speeds higher than 6 m/s. Such increases characterize the beginning of rainy season (March-April) and end of heavy rains (September-October), during which storms are more frequent. The harmattan season (December to February) can give rise to occasional high wind regimes.

2.2.6 Wind DirectionWind directions are quite variable over the region. Data shows that about 60% of the winds are south-westerlies and westerlies during the day in the wet season (NIMET). Southerlies, south easterlies and south

Delta State SEEFOR

Jan F eb Mar A p r May Jun Ju l A ug S ep t O c t Nov D ec05

10152025303540

average temperatureWarmest Coldest

26

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westerlies prevail more in the night during the period. This implies that directions are usually more variable in the nights than in the mornings.

The winds are mostly northerlies, north easterlies and north westerlies in the dry season particularly in the mornings. They are more of sourtherlies, south easterlies and/or westerlies during the evenings, indicating the fairly strong influences of the adjoining maritime oceanic air masses, contrasting land and sea breezes as well as appreciable degree of differential heating of the two surfaces.

2.2.7 GeologyThe geology consists of three major sedimentary cycles have occurred since the early Cretaceous. The subsurface stratigraphic units associated with the cycles are, the Benin, the Agbada and the Akata Formations (Kogbe, 1976). The surface rock throughout the state consists of the OgwashiUku formation. The Benin formation is about 1800m and consists of loose and unconsolidated sands. The underlying Agbada Formation, which consists of sandstone and shales, is, however, rich in hydrocarbons. It is up to 3000m and is underlain by the Akata Formation. The OgwashiAsaba Formation that underlies the northeast consists of an alternation of lignite seams and clay.

There are four broad ecological zones in the region defined by both relief and hydrological characteristics. These are, from the coast inland;

the coastal sandy barrier ridge zone the mangrove swamp zone the freshwater swamp zone and the lowland rainforest zone.

The coastal sandy barrier zone, as the name suggests, is made up of a chain of sandy barrier islands, which are separated by numerous estuaries and inlets. The islands are generally less than one metre above the sea level at high tide. They extend along the outer coastline from the Benin River to the Imo River. Typically, they are 16 to 20 kilometres wide. Because of their relatively higher topography, which keeps them from the tidal influence of the marine and brackish waters, the coastal barrier islands support freshwater forests and associated fauna. These islands are also often flooded during the year when rainfall is heavy.

The mangrove swamp zone occurs immediately after the barrier islands. It is the swampiest of the ecological zones, being essentially a massive swamp dotted with islands of dry land covering about 10,240 square kilometres (Mosunmolu, 1998). Most of the zone is at elevations of less than one metre, and it is generally muddy and under tidal influence.


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Within the zone are feeder channels that move tidal waters into the swamp, connecting channels and inter-fluves.

The freshwater swamp zone is characterized by seasonal flooding. It is during the rainy season that its swampy characteristics are vividly obvious. It has the most distinct subdivisions, is most diverse in terms of biology and supports a similar ecology to the one in the coastal barrier islands. The zone's three subdivisions are the flood forest zone or 'upper delta', the marsh forest zone and the eastern flank. The flood forest subdivision has large sand river channels, permanent creeks and seasonal flood creeks, and is inundated annually by the Niger River flood. Flood-free levees are common, while back swamps and cane forests help give the zone a highly diverse habitat. The marsh forest subdivision is also referred to as the transition zone. It is permanently swampy and under flooding from freshwater. Muddy swamp channels and raffia swamps can be found in the zone, and its species of wildlife are usually different from those of the flood forest zone.

The lowland rainforest zone is in the northern part of this region, beyond the areas of dense river and creek networks. It is not considered within the area defined by the natural limits of the Niger Delta, but falls within the broader Niger Delta area. This is the least swampy part of the region. It has a varied geology and terrain, but sedimentary rock formations, mostly sandstone with some shale and limestone, underlie most areas.

2.2.8 SoilThere are three types of soil in Delta State. These consist of alluvial soil on the marine deposits along the coast; alluvial and hydromorphic soils on marine and lacustrine deposits found in the area closest to the Niger and Benin rivers; and the ferral soils on loose sandy sediments in the dry land areas of the north and northeast.

2.2.9 DrainageThe River Niger drains the eastern flank of the state and discharges into the sea through its several distributaries such as the Forcados, Escravos and Warri rivers and creeks such as the Bomadi creeks, amongst others. Rivers Jamieson and Ethiope rise from the north and northeast respectively, and subsequently join and form the Benin River, which eventually dis charges into the sea in the West.

2.3 Biological Environment

The ecologically sensitive areas are the mangrove and freshwater swamp forests. The mangrove forest is a productive area. It serves as spawning


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and nursery grounds for shell and finfishes. The mangroves also serve as nesting sites for aquatic and migratory birds and other animals. The swamp forest was rich in biodiversity (wide variety of economic plants, medicinal plants and animal life).

2.3.1 FloraThe vegetation varies from the mangrove swamp along the coast, to the evergreen forest in the middle, and the savannah in the northeast. Table 2 Some Common Plants found within project community

S/NO COMMON NAME BOTANICAL NAME

1. Maize /corn Zeamays

2. Cassava Manihotesculenta

3. Banana Musasapientum

4. Water leaf Talinumtriangulare

6. Pineapple Ananascomosus

7 Yam Dioscorea species

8. Cocoyam Colocasiaesculenta

9. Pumpkin Cocurbitapepo

10. Pineapple Ananasconosus

11 Oil Palm Elaeisguineensis

12. Mango Magniferaindica

13. Pawpaw Caricapapaya

14 Rubber plant Heveabrasiliensis

2.3.2 FaunaThe area is known for its fishing activities especially in the southern parts. Several species of freshwater fish are found in the area. The area is also blessed with shrimps, crabs and dried fish. Other wildlife found in the project area include grass cutters, Antelopes, etc. Furthermore, cattle, goat, sheep, poultry and pig were some of the livestock sited within the project area.

2.3.3 Ecological IssuesThe Niger Delta coast is currently faced with a gamut of environmental problems, including: Soil and coastal erosion; oil pollution; population pressure; and flooding. Flooding is one of the commonest, given the existing hydro-climatologic conditions. In this coastal area high tidal


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range, which causes diurnal flooding and the creation of brackish water is common (Oni, 2003). On the whole, economic activities can be truncated and infrastructure destroyed in an event of sea level rise caused by climate change, while the already common problems associated with the local rainfall regime and tidal influences, can be accentuated, thus increasing the physical and socio-economic vulnerability.

2.4 Social Environment

2.4.1 Demographics

The study was conducted to identify and document the demographic data of the project communities such as population, literacy level, occupation, dependency level, housing and social amenities. These data will be useful not only in establishing the importance of the SEEFOR project but equally in quantifying the environmental and social impacts of the planned works which will help determine the management plans for the said project. More importantly, the baseline data will be useful for monitoring and evaluating the post implementation condition of the community and by implication the success of the project.

2.4.1.1Delta State

Delta State is an oil and agricultural producing state of Nigeria, situated within the region known as the Niger Delta region of the South-South geo-political zone with a population of 4,098,291 (males: 2,674,306; females: 2,024,085).

The capital city is Asaba, located at the northern end of the state, with an estimated area of 762 square kilometres (294 sq mi), while Ogwashi-Uku has the biggest land space for any industry, Warri is the economic nerve of the state and also the most populated located in the southern end of the state. The state has a total land area of 16,842 Km2.

It comprise distinct Igbo subgroups of Enuani, Ukwani, Ndokwa and Ika, collectively referred to as Anioma, and the Delta people made up of the Urhobo, Itsekiri, Ijaw and Isoko ethnic groups.

The first group has a historical affiliation with the Igbos of eastern Nigeria, although some parts of it are more Igbo than others while the second group occupy the Central and South Senatorial districts of the state. They speak different languages but have a loosely related culture as they traded and intermarried for centuries before colonization. Most inhabitants of the state practice Christianity and very few traditional faiths.


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2.4.1.1.1 Asaba

Asaba, is strategically located on a hill at the western edge of the majestic River Niger. The historic River Niger is a trans-African link beginning from West Africa and down into the Atlantic Ocean. Asaba forms a connector between western, eastern and northern Nigeria through the River Niger from the north and via the Asaba Niger Bridge, an east west link and a Nigeria landmark.

Asaba lies approximately 6 degrees north of the equator and about the same distance east of the meridian; about 100 miles north of where the River Niger flows into the Atlantic Ocean. The greater Asaba occupies an area of about 300 square kilometers. It maintains an average tropical temperature of 90 degrees during the dry season and an average fertile rainfall of 6 inches during the rainy season.

2.4.1.1.2 Sapele

Sapele was established as a trading village, occasionally visited by Europeans. In 1891, the British government established a vice-consulate at Sapele. The population grew to 33,638 by 1952, including people from many Nigerian tribes.

Today, the city has one of Nigeria's major ports. Its industries include the processing of timber, rubber, and palm oil, as well as furniture, tamarind balm and footwear manufacturing. As of 1995, its population was 135,800. And as of 2005/2006, the population of this advancing city is 142,652.

2.4.1.1.3 Udu

Udu is a Local Government Area in Delta State, Nigeria. Udu is one of the Urhobo kingdoms, and it has its own king, or ovie. It has a population estimate of approximately 100,000 people and it is about 5 minutes’ drive away from Warri Airport. Its local government headquarters is Otor-Udu.

Udu's natural resources include rubber and rubber products, palm oil and palm products, cassava, fruits, vegetables and maize available in large quantities. Silica is available in a nearby town for the manufacture of glass and also is crude oil, natural gas and other minerals for the petrochemical industry.

2.4.1.1.4 Ughelli

Ughelli is a town in Delta State, Nigeria. The city of Ughelli has an 'Ovie', which is the traditional ruler. The indigenes of Ughelli town have a yearly celebration festival called 'Omanuku'. According to the 1991 census


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Ughelli had a population of 54,206; a 2007 estimate places its population at 82,994.

The town was originally an agricultural center, but industry has now developed there. Petroleum extraction by Shell occurs in the vicinity. The major schools in are the Anglican Girls Grammar School and St Theresa's College. Government College, Kogbodi International School, Noble Crest Secondary School. The town is also the home of Our Lady of the Waters Cathedral, seat of the Roman Catholic Apostolic Vicariate of Bomadi. A famous producer of glass bottles Frigoglass's factory is located here.

2.4.1.1.5 Uvwie

Uvwie is a Local Government Area (LGA) in Delta State. It is one of the Urhobo Kingdoms and has a king, Ovie, who rules over the traditional institution of the town. It is a gateway town in and out of the city of Warri. A centre of civilization for the Urhobo people, Effurun is the headquarters of the Uvwie local government area.

It is a densely populated region and has many of the city's finest exotic hotels for relaxation such as Wellington Hotel, Hotel Excel, Mega Hilton Hotel, GT Maines Hotels and Suites, Casa De Pedro Hotel.

2.4.1.1.6 Warri

Warri is one of the hubs of petroleum related businesses in the southern Nigeria. It is a commercial city in Delta State, Nigeria, with a population of over 311,970 people according to the national population census figures for 2006. The city is one of cosmopolitan cities in southern Nigeria comprising mainly Urhobos, Isokos, Itsekiris, and Ijaws. Warri is predominantly Christian, as is most of Southern Nigeria. The city is known nationwide for its unique Pidgin English.

Warri is regarded as a modern metropolitan area with expanded infrastructural development in other Local Government Areas (L.G.A.) such as Uvwie, Udu, Ughelli and Okpe in recent years, with various road networks linking these places into one. Each of these L.G.A has its own administrative structure.

2.4.2Local EconomyFishing and agriculture are the two major traditional occupations of the Niger Delta peoples. During the colonial era, forestry was introduced as the third major economic activity in the region. Today, agriculture, fishing and forestry still account for about 44 per cent of employment. However, all three economic activities have declined since the ascendancy of the oil industry.


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The urban sector, with its concentration of informal sector activities, plays a growing role in the economy of the region. Trading, services, and miscellaneous activities are the most important areas of employment, after agriculture, fishing and forestry overall.

One major contemporary challenge facing the region's economy may be how to revamp the rural economy by optimizing and modernizing agriculture as well as fishing.

Various companies and facilities are located within the state. These include:

Federal and State Universities,

Federal University of Petroleum Resources

Petroleum Training Institute

Nigeria National Petroleum Corporation

Refinery

Oil and Gas Companies

Modern market

Timber and Plywood industry

Glass Manufacturing Industry

Steel Company

Textile mill

Rubber industry

Ceramic industries

Cement and block industries

Livestock feed industry

Plastic industries etc.

2.4.3Land Use/Tenure While majority of the land use is for agricultural purposes others

are for residential settlement, market places and public reserve for future development uses.

A combination of traditional land ownership system and government ownership of land is observed in the area.


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2.4.4Historic and Cultural ResourcesCultural resources in any country are very important in identifying any particular group of people. In some cultures, rivers, mountains, trees, etc are revered. There are sacred groves and shrines, religious artifacts and places of worship- churches, Masjid (Mosques), cemeteries, etc, which people tend to have emotional attachment and sensibility.

In Delta State, scared shrines, lakes and forests are scattered throughout the study area. Sacred forests, streams and lakes are categorized as cultural and natural resources, to which most of communities had access. While some of these resources which are revered or worshipped are within the community, others are some distance away. (e.g. a shrine near a burial ground along Reclamation Rd in Sapele).

2.4.5Unemployment Rate in Delta StateThe unemployment rate in Delta state is typical to most of the Niger-Delta state is still very high. Lack of employment has led to the increase of young people going into the militant and violent tendencies. The SEEFOR project intends to ensure that youth are gainfully employed in the most parts of the cities. Thus, ensuring that livelihoods are improved and more youth employed.

2.5 Socio-economics Assessment

The socio-economic assessment studies were aimed at examining the socioeconomic conditions of the communities living around the six projects areas in Delta state. This is to ensure that the potential impacts of the proposed project is captured and described while proffering solutions to possible negative impacts to human habitat, health and livelihoods.

The specific objectives of the study include:

To elicit information about the existing socioeconomic and demographic characteristics of the inhabitants living around the proposed project cities.

To document the distributional characteristics of the socioeconomic components in the project area.

To analyse the patterns of the relationships of the socioeconomic components

To discuss and deduce the effect of the patterns on the environment of the proposed Refuse Collection and Disposal Activity through the perceptions of the respondents.


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To provide a baseline data for the assessment of the socioeconomic impacts of the proposed project.

Suggest mitigation measures and environmental management plan for the proposed project.

2.5.1 Methodology

The general methodology used for the socio-economic impact assessment employed the collection of primary and secondary source data. The primary sources data gathering comprised of questionnaire administration, group interviews, discussions and direct observations. Secondary data was obtained from the National Population Commission. Structured questionnaires were administered to people in residential areas, administrative offices, commercial establishments, schools, families, youth leaders etc. Data collected was analysed using Microsoft Excel 2007.

Areas for socio-economic assessment studies were selected at random while taking into consideration likely areas to be affected during the operation of the project.

A random sampling survey was carried out in the communities within six project cities. Semi structured questionnaires (Annex 4) were administered to a total of 1500 respondents.

2.5.1.1Population and Gender characteristics

The survey shows that about 38% of the respondents in the 6 project areas are males while 62% are females. Warri accounts for the highest number of males (73%) while Sapele accounts for the lowest number of males (43%).


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2.5.1.2 Age profile

The overall mean result shows that about 23% of the respondents are 30-39yrs while 19% were between 20-29years old; about 18% fall between 40-49 years old, while 19.1% are between 30 and 39 years old. 8% and 4% of the respondents were above years and 15 0r bellow respectively. This goes to show that there is a good representation of able youths for work engagement in these areas.

2.5.1.3 Marital Status

Delta State SEEFOR

Asaba Sapele Udu Ughelli Uvwie Warri0

10

20

30

40

50

60

70

80

Population

Male Female

62%

38%

Gender

Male Female

15yrs and Bellow

16- 19yrs

20-29yrs

30-39yrs

40-49yrs

50-59yrs

above 60yrs

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Age Profile

Asaba Sapele Udu Ughelli Uvwie Warri

Single

Married

Divorced

Widowed

0 10 20 30 40 50 60

56.1

43.4

0.3

0.2

36

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The survey result shows that the single persons are predominant among the respondents in all the project areas (56.1%), followed by married persons (43.4%). Divorced and widowed persons were 0.3% and 0.2% respectively.

2.5.1.4 Religion

The overall mean result show that Christianity is the predominant religion in the area with a representation of about 98.9%. Islam is 0.8%, while traditional religion and others account for 0.7%.

2.5.1.5 Duration of Respondents residency in the Project area

Result from the survey show that at least 82.5% of the respondents have lived in their various neighbourhoods and communities for 5 years and above. The overall mean proportion of those who have lived in their community for less than 1 year is 0.3%. The above result implies that the majority of the respondents have lived within the project area long enough to provide valid information on the socio-economic conditions of their areas.

Delta State SEEFOR

Single

Married

Divorced

Widowed

0 10 20 30 40 50 60

56.1

43.4

0.3

0.2

2% 16%

82%

Below 1yr1-2yrs3-4rs5yrs and above

37

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2.5.1.6 Occupation

The Survey on occupational distribution shows that the private sector is the economic main-stay (23%) for the people. However, business/petty trading (self-employment- 20%) plays a major role in the economy of the people within these areas.

2.5.1.7 Household size

Results show a homogenous distribution pattern of household sizes in the project areas, with majority of sampled households having 5-6 persons as members. This implies a moderately high consumption of goods which translates directly to Waste generation within the project areas.

2.5.1.8

Income

80% of the respondents have an annual earning of ₦500,001 and above with 20% earning between ₦51,000 to ₦500,000.

2.5.1.9 Expenditure on Waste Disposal

While 20% of respondents spend about ₦1,000 to ₦2,000 monthly on waste disposal, 70% of respondents dispose waste at illegal dumpsites therefore do not pay for waste disposal. As little as 10% of the respondents pay less than ₦1000 most of which patronise the existing Waste Collection system (PAPs).

Delta State SEEFOR

17%

20%

9%12%

23%

19%

StudentSelf employedJunior civil servantSenior civil servantPrivate SectorUnemployed

10%

33%

11%4%

22%

20%

Method of Waste Disposal

Waste Collectors (PSPs) Illegal dumpsites Along highwayBurning Bush/Swamp Others

38

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2.5.1.10 Willingness to pay for Waste Disposal

Survey results show that 78.5% of respondents are willing to pay for Waste disposal under the project. 31.6% of the respondents prefer to pay between ₦200 to ₦300 while 30% are willing to pay ₦500- ₦1000. 9% of the respondents expressed willingness to pay ₦1500 monthly for waste disposal.

Reason given for the unwillingness of some respondents to pay for waste disposal was that they have swamps/ bush behind and around their houses where they can easily dispose of the waste without pay. Others were of the opinion that they government should give them good access roads and drainages around their homes before the issue of payment for waste disposal. Most of those not willing to pay live within the cluster settlements and villages.

2.5.2 Transport and accessField studies showed that traffic congestion is a critical issue along major roads within the project LGAs particularly Effurun-Sapelle Road, Airport Road, Olu Palace Road, Effurun Round About, Eneren junction, Udu Secretariat Road etc. This occurrence is always at its peak during the early hours of the morning and at close of work. It was noticed that the movement of people to places of business/work is a major contributing factor to traffic congestion. Another contributing factor is the major road expansion and rehabilitation going on within the state. This has resulted in closure of some lanes and constitute hindrance to access.

However, the road expansion and rehabilitation projects are envisaged to alleviate the issues of heavy traffic congestion in the near future.

Delta State SEEFOR

10%

33%

11%4%

22%

20%

Method of Waste Disposal

Waste Collectors (PSPs) Illegal dumpsites Along highwayBurning Bush/Swamp Others

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2.5.3 Conflicts and Grievance Redress MechanismThe people of the project area strongly believe that their various governments (state and local) have failed them. Stating that directly or indirectly, the government and its agencies, through negligence or outright failure, have over the years been implicated in most conflicts in the region.

For instance, the government is seen to have fallen short on maintaining an environmentally sound dumpsite in Ughelli which has on several occasions lead to the youths preventing the PSPs from using the dumpsite and in most cases extort money or even impound their trucks.

Also regulations have been inadequate in terms of requiring companies to adopt and operate uniform corporate responsibility measures. Declining economic performance leading to rising unemployment or underemployment; a lack of access to basic necessities of life like water, shelter, health facilities, food and clothing; discriminatory policies that deny access to positions of authority and influence so people can participate in shaping the rules by which they are governed have also played major roles in conflicts within the area.

Due to the inter-and-intra community conflicts, government and community conflicts, oil companies and community conflicts which had existed conflict resolution strategy does exist in a number of the communities.

The following strategies are used in resolving conflict in the communities: community meetings, elders-in-council, dialogue, council of chiefs, appeals and summons, elders’ assembly, religious leaders, juju priests, youth council, women groups, the police and courts.

Conflict resolution could attract penalties such as fines, seizures of assets and ostracisation. A grievance redress mechanism has is included in Annex five.

2.6 Overview of the current waste management situation in pilot cities

This study focuses on Delta State and the pilot cities that are considered for the implementation of the sub-project includes; Asaba, Warri, Uvwie, Udi, Sapele and Ughelli. The study areas currently have ongoing waste collection systems; however the system is faced with several operational challenges. Comingled waste are collected weekly at the collection points from houses, industries, health facilities, industries, schools and other relevant facilities. The waste collectors are called Private Service Providers (PSPs). These PSPs usually have a functional office, with


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vehicles and workers. The PSPs collect wastes form allocated zones and dump them at the dumpsites. These wastes are not segregated from source nor sorted by the PSPs. Most of the dumpsites are also not state approved.

Field visits indicated some irregularities with the system of waste collection in the cities. Most members of households or facilities as the case maybe do not cooperate with modus operandi of the PSPs. Payments for waste collections services are not made.

The types of wastes generated are mostly from domestic, agricultural, fishing, commercial, industrial and trading activities, as well as human/animal fecal deposits.

Generally, in the location within the rural and urban areas, the identified refuse disposal methods in the communities include: open dumping, bush dumping, Rivers, streams/creeks and swamps and organized collection.

In some parts of the urban area of Asaba, Sapele, Warri, Uvwie, Udu, and Ughelli, domestic wastes, commercial/trading center wastes are collected in Bins, plastic basins or buckets, nylon bags, and paper cartons. The State Waste Management Board in collaboration with some Private Sector Partners (Waste Collectors) collect these waste from residence, markets, industries and healthcare facilities with the use of trucks for onward disposal at designated dumpsites.

While Asaba has a government-approved dumpsite, Uvwie, Udu and Warri have none but make use of land owned by indigenes (Private dumpsite) that collect payment from the PSPs. One is managed by Donparker which is almost full.

Ughelli with a new government designated dumpsite is not utilized as the area is inaccessible especially during the rainy season. The old designated dumpsite for the area is full and overflowing into adjacent road. This causes nuisance to residence and has caused the youths of the area preventing PSPs from dumping at this location.

It was observed that most of the dumpsites used are either illegal sites or full and encroaching into roads causing nuisance as observed in Ughelli, Sapele

Thus in general, wastes generated are disposed indiscriminately along kerbs, on main roads, along the highway, bushes, rivers/stream, and creeks. Only few compliant residence dispose their waste through the organized Refuse collection by the PAPs.


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2.6.1 Waste characterisation and quantificationThe table below gives a picture of quantity of waste generated within each of the cities in the project area. Estimate was gotten from household observations, dumpsite truck count and interviews from dumpsite managers, and PSPs/waste workers.Table 3 Estimated waste generation per city

S/N City Waste Generation (tons)Daily estimate Weekly estimate Monthly estimate

1 Asaba 687 4,122 16,4882 Sapele 275 1,650 6,6003 Udu 152 912 3,6484 Ugheli 375 2,250 9,0005 Uvwie 152 912 3,6486 Warri 437 3,534 14,136TOTAL 2,378 11,775 53,520

It was observed that an average family of 4 living within the project area generate about 25kg waste/week. This gives a total of 100kg/month. From field count at the dumpsite and interview of waste workers and dumpsite managers it was estimated that about an average of 500tons of comingled waste is generated in Asaba on daily bases (i.e. 20 trucks) and deposited at the dumpsite. About 125tons of waste is generated in Uvwie and Udu each. Warri generates about 500tons daily while Ugheli and Sapele generate average of 240tons and 200tons daily respectively.

Majority of the waste were organic wastes (79%). About 6.9% of waste generated in all the cities were recyclable wastes. This consist of mainly plastics, nylon and glasses. The non-recyclable wastes made up 14.1% of the total waste stream generated in the project area.

2.6.1 Existing Refuse Management Conditions

Asaba

In Asaba, the existing refuse collection structure includes PSPs. These PSPs have been in existence before the SEEFOR project. A total of 40 zones (See AnnexThree), which includes the dumpsite, was created by the PSPs within the town and are currently working according to their delegated zones. They (PSPs) source customers within their individual zones and also follow up with collection of payment. PSPs use small trucks (e.g. Daina) for collection and disposal. They have an average staff of 5. The PSPs provide waste management workers with PPEs but do not completely enforce the use. There is also little HSE training provided.


Figure 2Waste Collector at Dumpsite Figure 3Waste Bins at a Residential Area

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Currently, there is a government allocated dumpsite in place along Asaba-Benin expressway. This dumpsite is managed by the Waste Management Board with an appointed member of the PSP Association. Scavengers also were seen at the site sorting and collecting different material (clothes, metal, plastic etc.).

The PSPs register yearly with the WMB and also pay money at the dumpsite part of which is used by the board for the management of the dumpsite while the remainder is kept in the PSPs Association purse. There is No segregation of waste at source and disposal (dumpsites). Even medical wastes are also muddled up with household and industrial wastes.

The government approved dumpsite is currently full and the only available pay loader works daily trying to push back the overflowing refuse further into the site.

There is high compliance of households and businesses to waste collection operation. However some pockets of illegal dump spots were observed. This is usually the case in areas that are inaccessible to the PSPs due to bad road, flooding or street planning (e.g. cable point).


Figure 7Scavengers at workFigure 6Waste Bin at a Private Healthcare Facility

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Ughelli

In Ughelli, the existing refuse collection structure includes PSPs. Just as seen in Asaba, these PSPs have been in existence before the SEEFOR project. A total of 11 zones (See Annex 5) were created within the town. With the help of pick-up trucks and Daina trucks, PSPs work within their delegated zones. They (PSPs) source customers within their individual zones and also follow up with collection of payment. The PSPs provide waste management workers with PPEs but do not completely enforce the use. There is also little HSE training provided.

The allocated dumpsite by the Local government in Ekiugbo is overfull and obstructing access road, causing a nuisance to nearby communities.

It was also observed that there is poor compliance by residences as only about 8% of the Ughelli populace is being served by the PSPs. This is due to awareness (50%) of the importance, income status and poor access road (e.g. Upagbaru extension). This has resulted in multiple illegal


Figure 10one of the PSPs at work Figure 11One of the Inaccessible areas due to flood

Figure 9Illegal Dumpsite behind the Court Figure 8Dumpsite overflowing into access road

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dumpsites which were observed particularly along Ughelli-Warri express road.

There is also No segregation of waste at source and disposal (dumpsites).

Udu

In Udu, the existing refuse collection structures include PSPs. Just as seen in Asaba, these PSPs have been in existence before the SEEFOR project. A total of 32 zones (See Annex 5) were created within the town. With the help of pick-up and Daina trucks, PSPs work within their delegated zones. The PSPs source for clients individually, provides different tariffs and collects payments individually. The PSPs provide waste management workers with PPEs but do not completely enforce the use. There is also little HSE training provided.


Figure 13Private (unapproved) dumpsiteFigure 12 Blocked drainage by refuse

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The government allocated dumpsite was closed in 2012 as it was overfull and causing nuisance to nearby residents as development began around the area. This has led to most PSPs resorting to dumping refuse at illegal (privately owned) dumpsite at high cost for disposal. As a result large number of illegal dumpsites was observed particularly along the major express road. However, recently one of the PSPs executives agree to allow his dumpsite to be used for the program but the hindering factor is poor access road into the site. The road needs to be covered with bitumen and latarite to enable access.

It was also observed that there is little compliance by households and business premises. This is due to awareness (40%) of the importance, income status and poor access road. This has resulted in multiple illegal dumpsites which were observed particularly along Ughelli-Warri express road.

There is also No segregation of waste at source and disposal (dumpsites) as also seen in Asaba.


Figure 14 refuse dumped in the Middle of the road

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Uwvie and Warri

In Uwvie and Warri, the existing refuse collection structure includes PSPs. The PSPs have been in existence before the SEEFOR project. A total of 25 zones (See Annex 5) were created within Uvwie while Warri has 30 zones (includes Ubeji-4 Zones; Edjeba-3 Zones) (See Annex 5). The operation is similar to that seen in Udu.

There is NO government allocated dumpsite. This has led to most PSPs resorting to dumping refuse at illegal (privately owned) dumpsite at high cost for disposal. As a result large number of illegal dumpsites was observed particularly along the major express road. However negotiations to use a private owned dumpsite managed by Donparker is ongoing.

It was also observed that there is little compliance of households and businesses to proper waste management practices. Most engage in illegal dumping on streets, in swamps and open burning particularly those in village settings and cluster areas. This has resulted in multiple illegal dumpsites which were observed particularly along express road and in-between kurbs on streets

There is generally No segregation of waste at source and disposal (dumpsites).


Figure 17 materials sorted by Scavengers

Figure 20Refuse dumped in-between main road Figure 19Blocked drainage and illegal Refuse dump at residential area

Figure 18 Illegal dumpsite near Residential Building

Figure 15 PSP and Waste Collector at a Private Dumpsite Figure 16 Private dumpsite Near a Market at Okpe Road

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Figure 21Illegal dumpsite and Blocked drainage Figure 22Refuse dump at the Centre of the Market

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Sapele

In Sapele, the existing refuse collection structure also includes PSPs as seen in the other metropolis. The structure and operation here, is similar to those seen in Ughelli and Udu. A total of 19 zones (See Annex 5) which includes the dumpsite were created by the PSPs within the town and are currently working according to their delegated zones. They (PSPs) source customers within their individual zones and also follow up with collection of payment. PSPs use small trucks (e.g. Daina) for collection and disposal. They have an average staff of 5. The PSPs provide waste management workers with PPEs but do not completely enforce the use. There is also little HSE training provided.

The Government approved dumpsite was closed and reclaimed due to development. There is a temporary government allocated dumpsite in place along New Ogorode Road. This dumpsite is managed by Sapelle LGA authority. There is also an area acquired to be used for the project. This area is about 4Acres swamp that the owner asked the government to help fill.

There is No segregation of waste at source and disposal (dumpsites). Even medical wastes are also muddled up with household and industrial wastes.

There is poor compliance of households and businesses to waste collection operation. This is attributed to the fact that there are a lot of bush and swamp behind and around buildings the less developed areas where the residence can simply dump their refuse at no financial cost. Others patronise cart pushers to dispose their waste at a high cost in the long run.

A lot of illegal dumpsites were observed along reclamation road, mission road, and general hospital and even on streets.


Figure 23Illegal Dumpsite Figure 24an Illegal Dumpsite

Figure 25 temporary approved dumpsite Figure 26 an Illegal Dumpsite

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2.7 Health Assessment

Visits were made to some of the healthcare facilities within the project area and interviews were also conducted during the scoping exercise.

Field observation showed that there are a good number of available healthcare centers within the project areas. Available secondary data showed that there are over 800 Primary Health Care facilities in the state. 102 Secondary Health Care facilities, 2 Tertiary facilities and numerous private health facilities are also located within the state. Udu have a total of 29 HCF, Ughelli North and south have 56 and 33 HCF respectively. Uvwie has 69, Warri North has 12, Warri South have 101, and Warri South-West have 18 HCF. Asaba have over 200 HCF. (Directory of Health Facilities in Nigeria, FMH, 2011)


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Preventable infections were identified from secondary data as the major causes of morbidity and mortality especially in children <5 years of age. These diseases/conditions in the area include malaria, diarrheal diseases, respiratory tract infections and sepsis. Major causes of death were complicated malaria (24.4%), sepsis (19.9%), diarrheal diseases (18.1%) and RTIs (7.7%). (Ezeonwu BU et al 2014).


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CHAPTER THREE PROJECT DESCRIPTION

3.1 Introduction

The project is designed around two main components - public financial management (PFM and service delivery - under which selected activities will be implemented to produce outputs that will contribute towards the achievement of the PDO. The latter will have three sub-components: a) training and skills development; (b) youth employment and (c) Community Driven Development (CDD).

3.2 Fundamentals of Sound Waste Management

Waste management involves the proper organization and systematic channeling of wastes to proper treatments and disposal methods. This safeguards the environment, making it a habitable place for all (Kofoworola, 2007). Effective waste management strategies cannot be implemented if there are no laid down plans implemented in any area.

To achieve a reasonable and well-functioning SWM system, the principles of sustainable development, integrated solid waste management and the waste management hierarchy must be included and practice at all the possible levels (e.g. national, state and local government levels) (World bank 2001; European commission 2003).

Waste generated within a facility or residence should always follow an appropriate and well-identified stream from their point of generation until their final disposal. This stream is composed of several steps that include: generation, segregation collection and on-site transportation, on-site storage, off- site transportation (optional), treatment and disposal of the waste. The waste management strategies selected should therefore be in accordance with the principles for best practice, improving public health, improving ecosystems and encouraging sustainability.


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This section provides basic information on these different steps, which are summarized in the table below, and presents the minimal procedures that should be respected in each of these steps.

Step

Location Waste stream Key points

0 Waste minimization Purchasing policy; stock management; recycling of certain types of waste

1 From source (residence, industries

etc.)2 One of the most important steps to reduce risks and amount of hazardous waste

3Outside source (within compound/facility)

Protective equipment; sealed bins/containers, bags

4 Designated easy to clean storage room/ section

5 Appropriate storage room; limited time of 48hrs

6 Outside of compound/facility

Appropriate vehicle and consignment note

7 Appropriate vehicle and consignment note

3.2.1 Guideline for classification of wasteThough there is no hard and fast rule towards the classification of waste because of the possibility of change with time, these general guidelines are employed in the classification;

Is the waste special? Special waste’ is a class of waste that has unique regulatory requirements. The potential environmental impacts of special waste need to be managed to minimise the risk of harm to the environment and human health.

Is the waste liquid? Liquid waste means any waste that:

Delta State SEEFOR

Segregation at source

Generation

Collection + onsite transportation

Onsite storage

Onsite treatment/ disposal

Off-site transport

Off-site treatment/ disposal

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has an angle of repose of less than 5 degrees above horizontal, or

becomes free-flowing at or below 60 degrees Celsius or when it is transported, or

is generally not capable of being picked up by a spade or shovel

Is the waste pre-classified? If the waste is neither special nor liquid waste, establish whether the waste has already been classified by the FMEnv. Some commonly generated wastes have been pre-classified as hazardous waste, general solid waste (putrescible) or general solid waste (non-putrescible). Wastes that have been classified by the FMEnv cannot be reclassified by any other party

Does the waste possess hazardous characteristics? Waste must be classified as ‘hazardous waste’ if it is a dangerous good under any of the following classes or divisions;

Explosives, Gases (compressed, liquefied or dissolved under pressure),

Flammable solids (excluding garden waste, natural organic fibrous material and wood waste, and all physical forms of carbon such as activated carbon and graphite),

Substances liable to spontaneous combustion (excluding garden waste, natural organic fibrous material and wood waste, and all physical forms of carbon such as activated carbon and graphite)

Substances which when in contact with water emit flammable gases Oxidising agents and organic peroxides Toxic substances Corrosive substances.

Determining a waste’s classification using chemical assessment. Waste generators should chemically assess their waste to determine its classification where:

the waste is not special waste, liquid waste, a waste pre-classified by the FMEnv or a waste possessing hazardous characteristics, and

the composition of the waste is not known. Is the waste putrescible? Where chemical assessment of a waste

results in classification of the waste as general solid waste, further assessment may be undertaken to determine whether the waste can be classified as ‘general solid waste (putrescible)’ or ‘general solid waste (non-putrescible)’.

Special waste

Special waste’ is a class of waste that has unique regulatory requirements. The potential environmental impacts of special waste need


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to be managed to minimise the risk of harm to the environment and human health.

Special waste means any of the following:

clinical and related waste asbestos waste Waste tyres.

Generators of special waste (except asbestos mixed with other waste – see below) do not need to make any further assessment of their waste if it falls within the definitions of special wastes below.

Note: Where asbestos is mixed with other waste to form asbestos waste, the generator must continue to assess the waste in accordance with the remainder of the steps in this guide. Asbestos waste can only be disposed of at a waste facility that can lawfully receive asbestos and the other class of waste with which it is mixed (if any).

Liquid waste

Liquid waste means any waste that:

has an angle of repose of less than 5 degrees above horizontal, or becomes free-flowing at or below 60 degrees Celsius or when it is

transported, or is generally not capable of being picked up by a spade or shovel.

If the waste meets the criteria outlined above, there is no need for any further assessment. If the waste does not satisfy any of these criteria, move to Step 3 to classify the waste. The waste generator may choose to separate the waste into the liquid and solid fractions so that only the solid fraction needs to be further classified in accordance with the following steps.

Hazardous waste

The following wastes have been pre-classified by the FMEnv as ‘hazardous waste’:

the tarry residue from the heating, processing or burning of coal or coke comprising of more than 1% (by weight) of coal tar or coal tar pitch waste

lead-acid or nickel-cadmium batteries (being waste generated or separately collected by activities carried out for business, commercial or community services purposes) lead paint waste arising otherwise than from residential premises or educational or child care institutions

Any mixture of the wastes referred to above.


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Restricted solid waste

Currently, no wastes have been pre-classified by the FMEnv as ‘restricted solid waste’.

Restricted solid waste therefore only includes wastes assessed and classified as such in accordance with the procedures in Step 5 of this guide.

General solid waste (putrescible)

The following wastes have been pre-classified by the FMEnv as ‘general solid waste (putrescible)’:

household waste that contains putrescible organics waste from litter bins collected by or on behalf of local councils manure and night soil disposable nappies, incontinence pads or sanitary napkins food waste

3.2.2 Waste GenerationOur everyday activities generate waste that should always be discarded by the person who used the item to be disposed of. This we cannot avoid, therefore it is advice that the quantity of waste generated should always be minimized.

Waste minimization and recycling

Before producing waste, it should be investigated whether the amount of waste generated could be minimized in order to reduce efforts in subsequent handling, treatment and disposal operations. The reuse of equipment has almost disappeared due to the marketing of single use items and the need to prevent the spread of nosocomial diseases. This is particularly the case for medical items such as syringe needles.

There are however other opportunities for recycling or reuse, in particular of objects / items which are not directly used for health-care (paper, cardboard, glass, metal containers, plastic wrapping). One of the most efficient measures for waste reduction lies in the careful management of household and industrial material purchases and medical stocks in the hospital pharmacies.


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Recycling of potentially contaminated items such as the plastic and metal from syringes/needles is not recommended for the moment in most Sub-Saharan countries due to the absence of availability of appropriate technologies, lack of specific training / awareness as well as adequate management procedures. However household or non-contaminated items may be recycled.

3.2.3 Waste segregationSegregation is one of the most important steps to successfully waste management. Treatment and disposal costs could be greatly reduced if a proper segregation were performed. Segregating hazardous from non- hazardous waste reduces also greatly the risks of infecting workers handling HCW. Also segregating biodegradable from non-bio degradable materials give room for recovery of materials for recycling. This serves as a form of income generation.

The segregation consists in separating the different waste streams based on the hazardous properties of the waste, the type of treatment and disposal practices that are applied. A recommended way of identifying waste categories is by sorting the waste into colour-coded and well-labelled bags or containers.

Segregation should:

Always take place at the source;

Be simple to implement

Be safe and guaranty the absence of infectious HCW in the domestic waste flow;

Be well understood and well known by the medical and ancillary staff of HCFs;

Be regularly monitored to ensure that the procedures are respected.

Colour coding system


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The application of a colour coding system aims at ensuring an immediate and non- equivocal identification of the hazards associated with the type of waste that is handled or treated. In that respect, the colour coding system should remain simple and be applied uniformly throughout the country.

Labelling

Here, the container is sealed and labelled indicating the type of material it contains. The sign “Danger” or “Caution” should be included on the label for dangerous materials. This is especially so for infectious, radioactive materials and their likes. This helps to identify content and possibly know the procedures to take in the case of spills or contamination.

3.2.3 Collection and on-site transportationIn order to avoid accumulation of the waste, it must be collected on a regular basis and transported to a central storage area within the compound/residence/facility before being treated or removed. The collection must follow specific routes through the source to reduce the passage of loaded wheelbarrow through other clean areas.

The wheelbarrow/trucks should be

easy to load and unload,

have no sharp edges that could damage waste bags or containers and

easy to clean.

Waste handling

Great care should be taken when handling waste in general. The most important risks are linked with the injuries that sharps can produce. When handling waste, one should always wear protective clothing including, as minimum, overalls or industrial aprons, boots and heavy duty gloves.


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3.2.5 On-site storageWaste generated at source are temporarily stored before being treated / disposed of on-site or transported off-site. A maximum storage time should not exceed 24 hours. (Non-risk HCW should always be stored in a separate location from the infectious / hazardous HCW in order to avoid cross-contamination).

A storage facility, sized according to the volume of waste generated as well as the frequency of collection, must be found inside all HCFs. Storage facility should not be situated near to food stores or food preparation areas and its access should always be limited. It should also be easy to clean, have good lighting and ventilation, and designed to prevent rodents, insects or birds from entering. Bins with tight lid is advised for use especially in households/residences.

3.2.6 Off-site transportationThe waste producer is then responsible for the proper packaging and labelling of the containers that are transported. One of the reasons for colour coding or labelling waste bags or containers is that in case of an accident, the content can be quickly identified and appropriate measures taken. The labelling system should comply with the WHO/UN Recommendations and contain at least:

The United Nations substance class (e.g. class 6, division 6.2, UN n° 3291 for infectious waste);

The proper shipping name and the total quantity of waste covered by the description (by mass or volume);

The date of collection.

The transportation should always be properly documented and all vehicles should carry a consignment note from the point of collection to the treatment facility. (Furthermore, the vehicles used for the collection of hazardous / infectious HCW should not be used for any other purpose). They shall be free of sharp edges, easy to load and unload by hand, easy


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to clean / disinfect, and fully enclosed to prevent any spillage in the hospital premises or on the road during transportation.

3.2.7 Treatment and disposalEach class of HCW require specific treatment, however, in order to be pragmatic, it is advisable to distinguish three major classes polarizing around 90 % of the biomedical waste production. These major categories could be:

Waste sharps;

Infectious and cytotoxic wastes;

Organic wastes (blood and body fluid wastes, human anatomical waste)

Household/solid waste may be categorised into two; degradable and non-degradable

Hazardous / infectious HCW can be treated to reach a level of hazard / infectiousness that is considered as acceptable. Thus, after treatment, they follow the non-risk waste stream and are disposed of with the general solid waste. They can also be directly disposed of by incineration or in sanitary landfills.

Hazardous / infectious HCW can be treated on-site (i.e. in the HCF itself) or off-site (i.e. in any other HCF or in a dedicated treatment plant).

3.3 Delta State SEEFOR Sanitation Project

The project has three components: Component A will support three main activities: (1)

Carrying out of small public works and institutional strengthening to generate youth employment in urban areas; (2) Carrying out technical, vocational and agricultural training by providing grants to TVT and agricultural training institutions and (b) State ministries responsible for education and agriculture; and (3) Carrying out of eligible Community Development subprojects by providing grants to (a) FCAs and (b) CSDAs.


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Component B will support reforms by the participating states of their public finance management systems, processes and institutions.

Component C is Project Implementation Support and Coordination, including providing logistical and technical support to NSPCU and SPCUs, and support the federal ministry responsible for Niger Delta Affairs.

The SEEFOR Project is designed to re-orientate the youths and entrepreneurs and allow them to meaningfully and productively live their lives while contributing to society. Sustainable livelihoods hinge on job creation and high-value products that yield income for poor and vulnerable groups.

The Refuse Collection and Disposal Project is tailored towards maintaining good hygiene while promoting accountability and transparency in the utilization of public finances which in turn translates into employment opportunities for the youths.

The refuse collection and disposal project will comprise two main phases;

1. Enumeration

2. Collection and Disposal

3.3.1 PROPOSED ENUMERATION PLANIn the course of implementing this project, there will be a proper enumeration exercise where houses and offices will be counted and divided into zones. Each town has been divided into different zones to ease the collection and disposal of these wastes. These zones are made up of streets, main roads and suburbs. The PSPs will be assigned different zones where they will operate in. at the end of the enumeration, there may also be the creation of new zones as necessity may warrant facilitating the functions of the PSPs. Below are schematic maps of the pilot cities showing the delineation of some of the existing zones identified and dumpsites (illegal and approved).


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Figure 27 Map of Warri showing some of the zones

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Figure 28Map of Ughi showing some of the zones

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Figure 29Map of Asaba showing some of the zones

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Figure 30 Map of Udu showing some of the zones

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Figure 31Map of sapele showing some of the zones

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Figure 32Map of Uvwie showing some of the zones

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3.3.2 PROPOSED COLLECTION AND DISPOSAL PLANThe wastes (household, industrial, biomedical, etc.) generated from houses, industries and health facilities will be collected by designated Private Sector Partners (PSP) within each zone for efficiency and effectiveness and to avoid work area encroachment. These PSPs will be made up of workers who are properly trained and supervised in handling these different domestic and hazardous wastes. They will put health, safety and environment expertise into work practices. The use of Personal Protective Equipment (PPEs) will be strictly adhered to. These wastes will be bagged and/or put in waste bins placed in front of the waste generation point, within the waste generation point or at a designated spot close to the waste generation point.

The waste bins from the collection point will be collected using compactor trucks or tipping trucks covered with trampoline or netting to avoid spill while on transit. The collected waste will be transported through the major highway and then disposed at a designated and approved dumpsite. Only registered PSPs will be allowed to dispose waste in these dumpsites.

The households, offices, hospitals and industries will make payment at designated banks from the SEEFOR office will remit payment for services to the PSPs.


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CHAPTER FOUR POLICY LEGAL AND REGULATORY FRAMEWORK

4.1 Introduction

A number of national and international environmental guidelines are applicable to the operation of the SEEFOR. In Nigeria, the power to enforce all activities that might have impacts on the environment is vested in the Federal Ministry of Environment (FMEnv). Internationally, agencies such as the World Bank, IFC and other financial organizations usually set environmental criteria for projects, which must be met by project proponents before the agencies invest in them.

4.2 Some Relevant Regulatory Instruments

Outline of the relevant regulatory instrument framework and administration to this project is given as they relate to the Federal, State and International arenas.

4.3 Federal Policy/Legislation

National Policy on Environment

The National Policy on Environment, 1989 (revised 1999), provides for “a viable national mechanism for cooperation, coordination and regular consultation, as well as harmonious management of the policy formulation and implementation process which requires the establishment of effective institutions and linkages within and among the various tiers of government – federal, state and local government”. Prior to the launching of this policy, there was no unified coordination of activities of the 3 tiers of government responsible for the environment.


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The thrust of the policy is the achievement of sustainable development in Nigeria. Guidelines and strategies are therefore defined for:

Securing for all Nigerians a quality of environment adequate for their health and well-being;

Conserving and using the natural resources for the benefit of present and future generations;

Restoring, maintaining and enhancing the ecosystem and ecological processes essential for the preservation of biological diversity;

Raising public awareness and promoting understanding of the essential linkages between the environment, resources and development; and

Cooperation with other countries, international organizations and agencies to achieve optimal use of trans-boundary in order to prevent environmental recourses.

Further, the defined guidelines and strategies provide for the effective management of the environment in the following 14 major areas: Human population; Land use and soil conservation; Water resources management; Forestry, wildlife and protected areas; Marine and coastal area resources; Toxic and hazardous substances; Energy production and use; Air pollution; Noise pollution; Working environment (occupational health and safety); and Settlements, recreational space, greenbelts monuments and cultural property.

The Federal Ministry of Environment

The act establishing the Ministry places on it the responsibility of ensuring that all development and industry activity, operations and emissions are within the limits prescribed in the National Guidelines and Standards, and comply with relevant regulations for environmental pollution management in Nigeria as may be released by the Ministry.

Of particular note amongst these instruments in ensuring that environmental and social issues are mainstreamed into development projects is the Environmental Impact Assessment (EIA) Act No. 86 of 1992. With this Act, the FMENV prohibits public and private sectors from embarking on major prospects or activities without due consideration, at early stages, of environmental and social impacts. The act makes an EIA mandatory for any development project, and prescribes the procedures for conducting and reporting EIA studies.

As part of the effective utilization of the EIA tool, the Ministry has produced Sectoral guidelines detailing the necessary requirements of the EIA process from each Sector. One of these Sectoral Guidelines that


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apply to the proposed project is the ‘Sectoral Guidelines on Infrastructure Development.’

Procedurally, in Nigeria, it is worthy to note that before commencement of an EIA, the FMENV issues a letter of intent on notification by the proponent, approve the terms of reference, ensure public participation, review and mediate. However, the categorization of the project into I, II and III determines the level of this latter part.

The possible technical activities expected for a proposed project include screening, full or partial EIA Study, Review, Decision-making, Monitoring Auditing and Decommissioning/Remediation post-closure.

National Legal Instrument on the Environment

Environmental Impact Assessment Act No. 86, 1992 (FMEnv)

This Act provides the guidelines for activities of development projects for which EIA is mandatory in Nigeria. The Act also stipulates the minimum content of an EIA and is intended to inform and assist proponents in conducting EIA studies as well as a schedule of projects, which require mandatory EIAs.

According to these guidelines:

Category I projects will require a full Environmental Impact Assessment (EIA).

Category II projects may require only a partial EIA, which will focus on mitigation and Environmental planning measures, unless the project is located near an environmentally sensitive area--in which case a full EIA is required.

Category III projects are considered to have “essentially beneficial impacts” on the environment, for which the Federal Ministry of the Environment will prepare an Environmental Impact Statement.

Other National Legal Instruments on Environment

The National Environmental Standards and Regulations Enforcement Agency Act 2007 (NESREA Act)

After the retracting of the Federal Environmental Protection Act of 1988, the NESREA Act, 2007 became the major statutory regulation or instrument guiding environmental matters in Nigeria. The NESREA Act


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consolidates all previously fragmented legal requirements pertaining to solid waste management. It specially makes provision for solid waste management and its administration and prescribes sanction for offences or acts which run contrary to proper and adequate waste disposal procedures and practices.

National Policy on Environmental Sanitation (2005)

The primary goal of the National Environmental Sanitation Policy is to ensure a clean and healthy environment by adopting efficient, sustainable and cost-effective strategies, so as to safeguard public health in line with the national objectives. The National Environmental Sanitation Policy (2005) seeks to maintain sound public health through environmental sanitation. In addressing environmental and public health issues, prominent targets of the policy include: solid waste management, food sanitation, sewage management, pest and vector control and environmental education programmes.

National Environmental (Sanitation and Wastes Control) Regulations, 2009

This regulation that was promulgated in 2009 among other things makes adequate provisions for waste control and environmental sanitation including punishments in cases of malfeasances.

The Harmful Waste Act

The Decree prohibits the Carrying, depositing and dumping of harmful waste on any land, territorial Waters, contagious zone, Exclusive Economic Zone of Nigeria or its inland Water ways and prescribes severe penalties for any person found guilty of any Crime relating thereto. The following sections are notable:

Section 6 provides for a punishment of life imprisonment for offenders as well as the forfeiture of land or anything used to commit the offence.

Section 7 makes provision for the punishment accordingly, of any conniving, consenting or negligent officer where a company commits the offence.

Section 12 defines the civil liability of any offender. He would be liable to persons who have suffered injury as a result of his offending act.


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National Environmental Protection (Pollution abatement in Industries and Facilities generating Waste) Regulations, 1991

Restrictions are imposed hereunder on the release of toxic substances and requirement of Stipulated Monitoring of pollution to ensure permissible limits are not exceeded; Unusual and accidental discharges; Contingency plans; Generator's liabilities; Strategies of waste reduction and safety for workers.

National Environmental Protection (Management of Solid and Hazardous Wastes) Regulation

These regulate the collection, treatment and disposal of solid and hazardous waste for municipal and industrial sources and give the comprehensive list of chemicals and chemical waste by toxicity categories.

The National Guidelines and Standards for Environmental Pollution Control In Nigeria

This was launched on March 12th 1991 and represents the basic instrument for monitoring and controlling industrial and urban pollution.

Federal Environmental Protection Agency (Amendment) Act No 59 of 1992

The National Guidelines and Standards for Environmental Pollution Control in Nigeria

Public Health Law 2006 The National Effluents Limitations. Regulation 1991 The National Environmental Policy (Pollution Abatement in

Industries and Facilities Generating Waste) Regulations 1991 The Management of Solid and Hazardous Wastes. Regulations 1991 National Guidelines on Environmental Management Systems (1999) National Guidelines for Environmental Audit National Policy on Flood and Erosion Control 2006 (FMEnv) National Air Quality Standard Decree No. 59 of 1991 The constitution of the Federal Republic of Nigeria 1999

4.4 Other Acts and Legislation

Land Use Act of 1978


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The Land Use Act of 1978 states that ’… It is also in the public interest that the rights of all Nigerians to use and enjoy land in Nigeria and the Natural fruits thereof in sufficient quality to enable them to provide for the sustenance of themselves and their families should be assured, protected and preserved’. This implies that acts that could result in the pollution of the land, air, and waters of Nigeria negates this decree, and is therefore unacceptable.

Furthermore, the Land Use Act of 1978 (modified in 1990) remains the primary legal means to acquire land in the country. The Act vests all land comprised in the territory of each state in the Federation in the Governor of the state and requires that such land shall be held in trust and administered for the use and common benefit of all Nigerians in accordance with the provisions of this Act.

According to the Act, administration of land area is divided into urban land which will be directly under the control and management of the Governor of each State; and non-urban land, which will be under the control and management of the Local Government. State Governors are given the right to grant statutory rights of occupancy to any person or any purpose; and the Local Government will have the right to grant customary rights of occupancy to any person or organization for agricultural, residential and other purposes.

Forestry Act

This Act of 1958 provides for the preservation of forests and the setting up of forest reserves. It is an offence, punishable with up to 6 months imprisonment, to cut down trees over 2ft in girth or to set fire to the forest except under special circumstances.

Nigeria is at present a wood deficit nation. In order to ameliorate the situation, the policy on forest resources management and sustainable use is aimed at achieving self-sufficiency in all aspects of forest production through the use of sound forest management techniques as well as the mobilization of human and material resources. The overall objectives of forest policy are to prevent further deforestation and to recreate forest cover, either for productive or for protective purposes, on already deforested fragile land.

Specifically, the National Agricultural Policy of 1988 in which the Forestry Policy is subsumed, provides for:

Consolidation and expansion of the forest estate in Nigeria and its management for sustained yield.


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Regeneration of the forests at rates higher than exploitation. Conservation and protection of the environment viz: forest, soil,

water, flora, fauna and the protection of the forest resources from fires, cattle grazers and illegal encroachment.

Development of Forestry industry through the harvesting and utilisation of timber, its derivatives and the reduction of wastes.

Wildlife conservation, management and development through the creation and effective management of national parks, game reserves, tourist and recreational facilities, etc.

Criminal Code

The Nigerian Criminal Code makes it an offence punishable with up to 6 month imprisonment for any person who:

Violates the atmosphere in any place so as to make it noxious to the health of persons in general dwelling or carry on business in the neighbourhood, or passing along a public way: or

Does any act which is, and which he knows or has reason to believe to be likely to spread the infection of any disease dangerous to life, whether human or animal?

State Legislations

Largely, the federal legislation serves as the benchmark in the execution of standards in the states. Some laws in the States include:

Environmental Sanitation Edicts, Laws and Enforcement Agencies: They cover general environmental health and sanitation. Enforcement of necessary laws.

State waste management laws: Ensure proper disposal of waste and clearing of wastes.

Building Line Laws: To ensure proper buiding plans within stipulated areas.

Prohibition of Indiscriminate Dumping of Refuse Edicts: To prevent indiscriminate dumping.

Environmental Pollution Control and Compensation Laws and Edicts: Control pollution and ensure compensation as necessary.

State Waste Disposal Edicts: To ensure proper disposal of wastes.


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Some of these laws include

1. State Waste Disposal Lawso State Environmental Protection Agency (SEPA) Lawo Waste Management Authority Lawo State Environmental Sanitation Authority Law

2. State Rural Water & Sanitation Agency Law3. State Waste Management Law4. State Environmental & Waste Management Law5. State Environmental Sanitation & Protection Agency Law6. Bureau for Sanitation & Transport Law7. Refuse Management & Sanitation (REMASA) Law8. State Environmental Protection Law9. State Sanitation & Water Management Law

Some Specific Delta State laws

Delta State Law No. 7 of 2007 (Ecology Law, 2006).

Delta State Waste Management Board Law No 4, 2004

Delta State Environmental Protection Agency (DELSEPA), Edict No. 5 of 1997

4.5 The World Bank Environmental and Social Safeguards

The World Bank has a number of operational and safeguards policies, which aim to prevent and mitigate undue harm to people and their environment in any development initiative involving the Bank. The Nigerian EIA Act and the World Bank safeguard policies are similar; designed to help ensure that projects proposed for Bank financing are environmentally and socially sustainable, and thus improve decision-making. The Bank has eleven safeguards policies and these are:

Environmental:

OP 4.00 Use of Country Systems OP 4.01 Environmental Assessment; OP 4.04 Natural Habitats; OP 4.36 Forests; OP 4.09 Pest Management; OP 4.11 Physical Cultural Resources OP 4.37 Safety of Dams;

Social:


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OP 4.12 Involuntary Resettlement;

Environmental Assessment (EA) (OP/BP 4.01)

Environmental Assessment is used in the World Bank to identify, avoid, and mitigate the potential negative environmental and social impacts associated with Bank’s lending operations early on in the project cycle. In World Bank operations, the purpose of Environmental Assessment is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted and their concerns addressed. This policy is triggered if a project is likely to have potential adverse environmental and social risks and impacts in its area of influence. The EA has various tools that can be used, including amongst others Environmental & Social Impact Assessment (ESIA) or Environmental and Social Management Plan (ESMP), which is the case with this sub-project.

Natural Habitats (OP/BP 4.04)

Any project or sub-project with the potential to cause significant conversion (loss) or degradation of natural habitats, whether directly (through construction) or indirectly (through human activities induced by the project). This policy is triggered because some project activities may take place close to critical natural habitats (forests, wetlands, mangroves, etc.) or environmentally sensitive areas and some mitigation measures may be necessary to minimize any adverse environmental and social impacts. The project is not being implemented in any area with critical natural habitats, nor does it involve the significant conversion or degradation of natural habitats.

Forests (OP 4.36)

This operational policy aims to reduce deforestation, enhance the environmental contribution of forested areas, promote afforestation, reduce poverty, and encourage economic development. The policy recognizes the role forests play in poverty alleviation, economic development, and for providing local as well as global environmental services. Success in establishing sustainable forest conservation and management practices depends not only on changing the behavior of all critical stakeholders, but also on a wide range of partnerships to accomplish what no country, government agency, donor, or interest group can do alone.


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This policy applies to the following types of Bank financed investment projects:

a. Projects that have or may have impacts on the health and quality of forests;

b. Projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests;

c. Projects that aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned.

Involuntary Resettlement (OP/BP 4.12)

This project may require land acquisition for dumpsites, receptacle locations and temporary storage areas. This policy is triggered because most of the sub-projects will involve minimal or moderate land acquisition, physical resettlement or restriction of access to usual means of livelihood. Impacts in this regard are expected to be limited as the sub-projects will largely be land acquisition for dumpsite. The main objective of this policy is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects.

Pest Management OP 4.09

This policy is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides; and (ii) strengthen the capacity of the country’s regulatory framework and institutions to promote and support safe, effective and environmentally sound pest management. It is envisaged that the Project activities on one side may affect the habitats of native fauna (most likely pests such as wild rodents etc.) and on the other, lead to movement of displaced pests to local farm lands and homes (as farmland is the next abundant mass of land in the project states besides forests) or introduction of new pests into the dumpsite area.. In the event of this, the policy aims to (a) Ascertain that pest management activities in Bank-financed operations are based on integrated approaches and seek to reduce reliance on synthetic chemical pesticides (Integrated Pest Management (IPM) in agricultural projects and Integrated Vector Management (IVM) in public health projects. (b) Ensure that health and environmental hazards associated with pest


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management, especially the use of pesticides are minimized and can be properly managed by the user. (c) As necessary, support policy reform and institutional capacity development to (i) enhance implementation of IPM-based pest management and (ii) regulate and monitor the distribution and use of pesticides.

World Bank performance Standards (OP 4.30/BP 4.30)

The aim of this policy is to facilitate Bank financing1 for private sector led economic development projects by applying environmental and social policy standards that are better suited to the private sector, while enhancing greater policy coherence and cooperation across the World Bank Group.

The eight IFC Performance Standards have been adopted by the Bank as the World Bank Performance Standards for Projects Supported by the Private Sector (“WB Performance Standards”) for application to Bank support for projects (or components thereof) that are designed, owned, constructed and/or operated by a Private Entity, in lieu of the World Bank’s safeguard policies (“WB Safeguard Policies”). The eight World Bank Performance Standards are:

Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts

Performance Standard 2: Labor and Working Conditions

Performance Standard 3: Resource Efficiency and Pollution Prevention

Performance Standard 4: Community Health, Safety, and Security

Performance Standard 5: Land Acquisition and Involuntary Resettlement

Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Performance Standard 8: Cultural Heritage

This OP sets forth the circumstances under which the WB Performance Standards may be applied, the roles and responsibilities of the Private Entity implementing the project, and of the Bank in supporting environmental and social sustainability aspects of the project.


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The Stockholm Convention on Persistent Organic Pollutants (POPs)

The Stockholm Convention on Persistent Organic Pollutants is a global treaty to protect human health and the environment from chemicals that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of humans and wildlife, and have adverse effects to human health and the environment. Given their long-range transport, no one government acting alone can protect its citizens or its environment from POPs.

According to the Stockholm Convention chemical listing, the chemicals are grouped into annex A, B and C. Unintentionally released persistent organic pollutants are listed under Annex C. “Parties must take measures to reduce the unintentional release of chemicals listed under Annex C with the goal of continuous minimization and, where feasible, ultimate elimination”.


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CHAPTER FIVE ASSESSMENT OF POTENTIAL IMPACTS AND MITIGATION/ENHANCEMENT MEASURES

5.1 Introduction

The proposed project will lead to several impacts on the environmental and socio-economic status of the project area. A good number of these impacts will be beneficial, especially the creation of employment for the youth, reduction of hygiene related health issues, and the establishment of an environmentally sound, safe and sustainable waste management system.

This chapter presents a summary of the identified potential beneficial and adverse impacts associated with Refuse collection and disposal in Asaba, Sapele, Udu, Ughelli, Uvwie and Warri under in the SEEFOR project.

5.2 Associated and Potential Environmental Impacts

For the identification and rating of key issues and impacts that are likely to occur during the phases of this project and the significance of the associated impacts, a “5-Step-Tool” was used.

5.2.1 Rating of Impacts

Five steps were followed sequentially in order to rate the impacts of the various activities of the project as shown below:

Delta State SEEFOR

Stage 1 Impacts IdentificationInteractions b/w project

activities and environmental and social sensitivities

Stage 2 Qualification of Impacts

Positive/negative, Direct/indirect, Short /long

term, local/wide spread, reversible/irreversible

Stage 3 Rating of Im pactsLikleihood

Stage 4 Degree of Im pact Significance

M ajor, M oderate, M oderately High, M oderately

Low

Stage 5 Im pact TableList impact source and

ratings

82

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Step 1: Identification of Potential Impacts

Expected impacts were determined based on anticipated interactions between project activities and major environmental and social sensitivities. The environmental and social sensitivities likely to be affected by project activities include the following:

Delta State SEEFOR

Environmental Components

Air (physical and chemical properties) Noise - vibrations, sound waves etc. Surface Water Ground Water and Hydro-geology Soil Topography and Landscape Climate Change Terrestrial Habitats Waste Management

Social Components

Air (odour) Noise – nuisance Visual Sensitivity Economic Activities Employment Public Health Occupational Health and Safety Education Land Use

Figure 33 Impact Rating tool

83

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Steps 2 and 3: Qualification of Impacts

Qualification of impacts was based on two assessment characteristics:

Step 2: Likelihood of occurrence – This is an assessment of the probability of the effect occurring.

Step 3: Potential consequence – This is the actual result and scale that an effect might have. The application of each of the two characteristics is described below.

Table 4 Likelihood of occurrence of Impact

Impact Probability Likelihood Frequency

High probability (80-100%) A very likely impact

Very frequent impacts

Medium high probability (60-80%)

A likely impact Frequent impacts

Medium probability (40-60%)

A possible impact Occasional impacts

Medium low probability (20-40%)

An unlikely impact Few impacts

Low probability (0-20%) A very unlikely impact

Rare impacts

The magnitude of the potential changes to the physical and social environment caused by the impact of an activity or hazard, and the level

Delta State SEEFOR

Social Components

Air (odour) Noise – nuisance Visual Sensitivity Economic Activities Employment Public Health Occupational Health and Safety Education Land Use

84

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of sensitivity of the receiving environment determine the potential impact of the activity. This is shown below:

Table 5 Potential Consequences Classification Matrix

Magnitude of Effect

Receptor Sensitivity Low change Medium change

High change

Low receptor sensitivity

Trivial effect Slight effect Substantial effect

Medium receptor sensitivity

Slight effect Substantial effect

Big effect

High receptor sensitivity

Substantial effect

Big effect Massive effect

The rating of the potential consequences of an impact and its effects are shown below:

Table 6 Potential Consequences

Potential Consequence Effect

Extreme consequence A massive effect

Great consequence A big effect

Considerable consequence A substantial effect

Little consequence A slight effect

Hardly any consequence A trivial effect

Step 4: Degree of Significance

The table below shows the impact significance with associated impact ratings.


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Table 7 Degree of Impact Significance

Impact Significance Impact Ratings

Major significance Major Impact

Moderate Significance Moderate Impact

Minor Significance Minor Impact

Negligible Significance Negligible Impact

Step 5: Impact Assessment Matrix

The potential impacts were evaluated using the Impact Assessment Matrix shown below

After the rating of each impact, the determination of mitigation measures followed. Only moderate and major impacts were considered for impact mitigation. Continuous improvement practices will address low impacts. The positive impacts shall be monitored and enhanced when expedient.

5.2.2 Associated and Potential Impacts Determination

The results of the evaluation of the interactions between the proposed rehabilitation activities and their impacts on environmental and social sensitivities are shown in subsequent pages of this chapter. The identified negative impacts were rated as minor, moderate and major. Beneficial impacts arising from the project were rated as positive. Hence, no further classifications were made on the beneficial impacts.

Delta State SEEFOR

Considerable Little

Negative

Moderate

Moderate

Major

Major

Major

Extreme

Minor

Moderate

Moderate

Major

Major

Great

Minor

Minor

Moderate

Moderate

Major

Negligible

Minor

Minor

Moderate

Moderate

Negligible

Negligible

Minor

Minor

Moderate

Hardly any

Low

Medium low

Medium

Medium high

High

Positive Likelihood

Potential consequences

Table 8 Impact Assessment Matrix

86

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5.3 Potential Positive Impacts of The Refuse collection and Disposal Project

The beneficial environmental and social impacts of the project will include:

Environmental Impacts

Enhancement of the capacity of the PSPs in collection and disposal of refuse- the project will have significant positive impacts by creating employment for unemployed youths within the project area.

Eliminate multiple sources of environmental and surface water pollution from poorly/ indiscriminate dumping of refuse.

Provide Delta State government with the technical and financial capacity to collect and dispose waste in environmentally sound manner.

The project will directly and indirectly encourage investments in the Delta State Waste Management sector.

Aid in the reduction or elimination of public and environmental health conditions resulting from poorly managed refuse disposal system.

Encourage acquisition of land for establishing additional dumpsite and/or establishment of an integrated waste management facility.

Facilitate sanitation in residence, business places, industries and public places such as motor parks and market places.

Promote the integration of environmental economics and financial management methodologies [Cost-Effectiveness Analysis (CEA) and Cost-Benefit Analysis (CBA)- health, environmental and socio-economic, Return on Investments (ROI), Total Cost of Ownership (TCO) etc.] in the administrative and technical functions of PAPs for the Refuse collection and disposal project.

Reduce ecological problems such as flooding by preventing blocking of drainage by refuse.

Improve health and safety of the indigenes through awareness and training.

Improved livelihood

Social Impacts


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The project will improve and increase access to proper refuse disposal services in Asaba, Sapele, Udu, Ughelli, Uvwie, and Warri

It will provide a platform to establish efficiency in the institutional (administrative and technical) performance of the Waste Management Board towards proper Refuse collection and disposal and other related services sanitation services in project areas.

It will ensure sustainability of waste management provision in the long term, meeting the needs of the present population of approximately 1.3 million and the projected population of 4 million by 2040.

The proposed Refuse collection and disposal project will promote human health and ensure the right to safe sanitary conditions for the populace of Asaba, Sapele, Udu, Ughelli, Uvwie, and Warri.

It will serve as a positive benchmark for future developments within the state.

Improvement of public goodwill and satisfaction towards governance in Delta State.

Reduce the time, expenditure and stress of refuse disposal through cart-pushers or along expressway.

Reduce health risks, man-hour losses and financial burden associated with waste related infections, diseases, and metabolic disorders.

Relieve youths from engaging in social vices resulting from being idle.

Exert positive impacts on education by improving school attendance, classroom performance and concentration especially of youth who would otherwise have been engaged in refuse disposal for their households by waking up very early to dispose them at illegal sites or walking long distances to expressways.

Reduce risks (harassment, child molestation, rape, accidents etc.) associated with the disposing of waste in the early hours of the morning or late at night.

Enhance personal and environmental hygiene and promote self-confidence.

Reduce favourable conditions for waste related disease vectors and diseases (malaria, giardiasis, salmonellosis, E. coli intoxication)


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Provide low-income earners with adequate refuse disposal system which will prevent them from resorting to indiscriminate disposal.

Directly and indirectly contribute to reducing mortality rates thereby increasing life expectancy.

Increase opportunities for job creation and employment.

Encourage behavioural changes in hygiene and sanitation amongst the peoples of Asaba, Sapele, Udu, Ughelli, Uvwie, and Warri.

Encourage training and capacity building for the waste management sector of Delta state at large and also increase public awareness on waste management and sanitation.

Create the potential for private sector involvement and participation especially in the areas of Private Sector Partnerships (PSPs) in Refuse collection and management of payment for refuse disposal services provided to consumers.

Scavengers will have better opportunity of collection of materials from the dumpsite due to increased quantity and consolidated refuse dumpsite.

5.4 Potential Negative Impacts of the Refuse collection and Disposal Project

Environmental Impacts

Possible air pollution as PSPs are collecting and transporting waste through streets and neighbourhoods

Possible introduction of new pests and scavenger birds at new dumpsites leading to possible introduction of new diseases within the area.

Social Impacts

Some existing PSPs may be displaced for not being able to meet up with the requirements for the project due to finance.

Possible displacement of cart-pushers from source of livelihood

Private dumpsite owners may also lose their source of livelihood

Their maybe possible increase in Traffic congestion as the trucks will be navigating the roads at the same time when other road users will be on the road.


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Possible accidental destruction of properties as trucks navigate through tight streets

Possible road accidents involving pedestrians while trucks are at work.

Possible land acquisition as government may acquire land for new dumpsite


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Table 9 Identified Potential Impact Ratings

Project Phase Component

Sub-component

Potential Impact Description Likelihood Consequence Rating

Operation ( Collection, Transportation and Disposal) Phase

Environment

Climate Change

GHG Emissions Direct /indirect

Negative

short-term/Long-term

Local/widespread

Irreversible

Medium low Considerable Minor

Air Fugitive dust, exhaust fumes, hazardous gases (NOx, CO, SOx, PM 2.5, PM 10)

Direct

Negative


Local/widespread

Irreversible

Moderate Considerable Moderate

Foul Smell from Refuse being carried along the streets

Direct

Negative


Local/widespread

Irreversible

Moderate


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Soil

Destabilization of soil structure/ Increase of erosion site

Direct

Negative

short-term

Local

Reversible

Medium Considerable Moderate

Compaction of top soil due to movement of heavy vehicles and equipment

Direct

Negative

short-term

Local

Reversible

Medium-high Considerable Moderate

Contamination of soil by oil spills, fuel, etc.

Direct

Negative

short-term

Local

Reversible

Medium-low Considerable Minor

Water quality/hydrology

Discharge of sediment laden run-off into water bodies

Direct/Indirect

Negative

Short-term/Long-term

Local/Widespread

Reversible


Contamination from (oils, fuel, chemical substances etc.)

Direct/indirect

Negative

short-term/long-term



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Local/widespread

Reversible


Environment

Water quality/hydrology

Contamination by human faecal wastes

Direct/indirect

Negative

short-term/long-term

Local/widespread

Reversible


Noise and Vibration

Noise pollution and vibration nuisance resulting from vehicles during Waste collection.

Direct

Negative

short-term

Local

Reversible

Medium-high Considerable Moderate

Soil destabilization due to vibrations from moving trucks

Direct

Negative

short-term

Local

Reversible

Medium low Considerable Minor

Waste Increased generation of solid and liquid wastes

Direct

Negative

short-term

Local

Reversible



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Sub-component



Social Socio-economic activities

Disruptions to resident activities within the project area

Direct

Negative

short-term

Local

Reversible


Blocked access route/Restricted access

Direct

Negative

short-term

Local

Reversible


Public Negative perception among residents and commercial establishments etc. about the project.

Direct

Negative

short-term

Local

Reversible

Medium Little Minor

Traffic Delay in travel time Direct Medium low Little Minor


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Sub-component


Negative

short-term

Local

Reversible

Education Noise disturbances to the serene learning environments. (Lumen Christi Primary and Secondary School)

Direct

Negative

short-term

Local

Reversible


Health and Safety

Incidence of respiratory diseases due to air contamination by fugitive dusts and exhaust fumes

Direct

Negative

short-term

Local

Reversible


Residents and workforce exposed to accidents and injuries

Direct

Negative

short-term

Local

Reversible

Medium Great Moderate

Incidence of water borne diseases (e.g. Dysentery, cholera)

Direct

Negative

short-term



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Sub-component


Local

Reversible


Social Behaviour Occurrence of social vices (e.g. theft, drug use etc.)

Indirect

Negative

short-term

Local

Reversible


Noise Nuisance due to increase in noise levels

Direct

Negative

short-term

Local

Reversible

Medium Little Minor

Project Performance

Conflict between community/residence members and Waste collectors

Direct

Negative

short-term

Local

Reversible


Grievance and resistance from communities

Direct/Indirect

Negative

Short-term/long-term

Local



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Sub-component


Reversible


Occupational Health and Safety

Personnel safety

Injuries, falls, accidents, leakages, accidents etc.

Direct/Indirect

Negative

Short-term/Long-term

Local/widespread

Reversible

Medium high Considerable Moderate


5.5 Environmental and Social Management Plan

5.6.1 Overview

The range of environmental, social and occupational health and safety issues associated with the Refuse Collection and Disposal Project is described in a matrix table format for the Environmental and Social Management Plan (ESMP). This will outline the corresponding management strategies that will be employed in mitigating the adverse environmental and social impacts; and occupational health and safety issues

The table also includes a column for Monitoring Indicators and Monitoring Frequencies.

Measures have been developed to ensure that identified negative impacts of the project are effectively mitigated and controlled.

The ESMP table is divided into two phases:

Refuse Collection and Transportation phase Refuse Disposal Phase

5.6.2 ESMP and Monitoring Plan Budget

The total cost for Implementing the ESMP and Monitoring Plan based on the two assessed phases is estimated at One hundred and Twenty Four Thousand US dollars ($124,000.00) for the Six (6) sites.


Table 10 ESMP and Monitoring Plan- Refuse Collection and Transportation Phase for Asaba

Component Sub-component

Activities Potential Impact

Mitigation Measures Monitoring Indicators

Monitoring Frequency

Institutional Responsibility

Costs (USD)

Environment Air Increased Vehicle movement

Increase of road users on Major streets and Roads

Air sampling and monitoring Compliance Monthly Monitoring: SME, NESREA (state), DELSEPA

500

Soil

Change of topography

Change in soil profile

Increase in soil salinity

Change in land use

Training on Sustainable Land Management (SLM) practices

Trainings are conducted Monthly

Mitigation: SPCU, SME, FMARD

Monitoring: SME, NESREA (state), DELSEPA

3,000

Noise Increase of road users on Major Streets and Roads

Noise nuisance to local residents

Noise level sampling and monitoring

- One-off Monitoring: SME, NESREA (state), DELSEPA

500

Water Quality

Roadway runoff Potential surface water pollution

Water sampling and monitoring

Compliance Bi-Annual Monitoring: SME, NESREA (state), DELSEPA

1,000

Waste Waste generation

Social and health concerns arising due to poor waste management practices

Dispose waste streams through the municipal waste management system in the project area.

Proper waste management

Monthly Monitoring: SME, DELSEPA, DELSWMB

1200

Blocked drainage due to poor waste

Flooding on roads







Costs (USD)

disposal

Others Negligence of PSPs to collect and dispose Refuse from residences

Illegal Refuse dumps

Regular collection and Disposal of refuse at approved dumpsites

SPCU Compliance Weekly SPCU 700

SUB-TOTAL – 6,900






Costs (USD)

Social Health Use of Waste Bins and Bags around residences

Breeding site for mosquitoes and disease vectors

Possible spread of water borne diseases (Cholera, dysentery)

Combined use of Bin liners and Waste Bins with Covers

Regular Maintenance and Monitoring

Compliance weekly PSPs, DELSEPA, SME, SPCU

-

Increase in number of vehicles using roads

Increase in respiratory problems amongst local residents

Regular sampling and monitoring

Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict

Control land use conflicts through Land use planning that should be participatory to designate areas for ecological, grazing and farming, etc.

Inspections are conducted

Contractors

Monitoring: SPCU

500

Safety Increase in number of road users

Increase in vehicular accidents

Ensure that vehicles for waste collection are used on specific day and avoid

Monitoring: FRSC

-







Costs (USD)

unnecessary movement.

SUB-TOTAL – 500


Personnel safety

Tasks implementation

Injuries, accidents, deaths

Implement on-site occupational health and safety management plan; Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Conduct OHSRA, Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis

Independent Consultants, Contractors Compliance.

Monthly SME, SPCU 5,000

SUB-TOTAL – 5,000

WASTE COLLECTION TRANSPORTATION PHASE TOTAL – 12,400

Table 11 ESMP and Monitoring Plan- Refuse Disposal Phase for Asaba






Costs (USD)

Air Increased Vehicle movement



500







Costs (USD)

Soil

Change of topography Change in

soil profile


Change in land use





3,000





500

Water Quality




1,000



Blocked drainage due to poor waste disposal


Flooding on roads Proper waste management Monthly

Monitoring: SME, DELSEPA, DELSWMB

1200

Others Negligence of PSPs to dispose Refuse at approved dumpsites




SUB-TOTAL – 6,900

Component Sub- Activities Potential Mitigation Measures Monitoring Monitoring Institutional Costs







Costs (USD)

component Impact Indicators Frequency Responsibility (USD)

Social Health Operation of Approved Dumpsite





-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict

Control land use conflicts through Land use planning that should be participatory to designate areas for ecological, grazing and farming


Contractors

Monitoring: SPCU

500



Monitoring: FRSC

-

SUB-TOTAL – 500


Personnel safety



Implement on-site occupational health and safety management plan; Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire









Costs (USD)

prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis

SUB-TOTAL – 5,000

WASTE DISPOSAL PHASE TOTAL – 12,400

Table 12ESMP and Monitoring Plan- Refuse Collection and Transportation Phase for Warri






Costs (USD)




500

Soil




Change in land use



Mitigation:SPCU, SME, FMARD


3,000





500

Water Quality




1,000







Costs (USD)




Proper waste management Monthly


1200


Flooding on roads





SUB-TOTAL – 6,900






Costs (USD)







-

Increase in number of

Increase in respiratory


Regular monitoring

Monitoring: -







Costs (USD)

vehicles using roads

problems amongst local residents

NESREA, SMH

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

500



Ensure that vehicles for waste collection are used on specific day and avoid unnecessary movement.

Monitoring: FRSC

-

SUB-TOTAL – 500


Personnel safety






SUB-TOTAL – 5,000



Table 13 ESMP and Monitoring Plan- Refuse Disposal Phase for Warri






Costs (USD)




500

Soil


soil profile


Change in land use





3,000





500

Water Quality




1,000







1200







Costs (USD)





SUB-TOTAL – 6,900






Costs (USD)






-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

500



Monitoring: FRSC

-

SUB-TOTAL – 500

Occupational Health and

Personnel safety


Injuries, accidents,

Implement on-site occupational health and








Costs (USD)

Safety deaths

safety management plan; Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis


SUB-TOTAL – 5,000


Table 14 ESMP and Monitoring Plan- Refuse Collection and Transportation Phase For Ughelli






Costs (USD)




500

Soil




Change in land use





3,000

Noise Increase of road users on Major

Noise nuisance to


- One-off Monitoring: SME, NESREA

500







Costs (USD)

Streets and Roads

local residents

(state), DELSEPA

Water Quality




1,000






1200


Flooding on roads





SUB-TOTAL – 6,900






Costs (USD)






-







Costs (USD)





Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

500




Monitoring: FRSC

-

SUB-TOTAL – 500


Personnel safety



Implement on-site occupational health and safety management plan; Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls









Costs (USD)

procedure; Conduct OHSRA, Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis

SUB-TOTAL – 5,000


Table 15 ESMP and Monitoring Plan- Refuse Disposal Phase For Ughelli






Costs (USD)




500

Soil


soil profile


Change in land use





3,000





500

Water Quality




1,000

Waste Waste Social and health

Dispose waste streams through the municipal waste Proper waste Monthly Monitoring:

SME, 1200







Costs (USD)

generation

concerns arising due to poor waste management practices


management system in the project area.

Flooding on roads management DELSEPA,

DELSWMB





SUB-TOTAL – 6,900






Costs (USD)






-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict

Control land use conflicts through Land use planning

Inspections are Contractors 500







Costs (USD)

that should be participatory to designate areas for ecological, grazing and farming

conducted Monitoring: SPCU



Monitoring: FRSC

-

SUB-TOTAL – 500


Personnel safety



Implement on-site occupational health and safety management plan; Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis



SUB-TOTAL – 5,000



Table 16 ESMP and Monitoring Plan- Refuse Collection and Transportation Phase For Sapele






Costs (USD)




500

Soil




Change in land use





3,000





500

Water Quality




1,000




Proper waste management

Monthly Monitoring: SME, DELSEPA, DELSWMB

1200

Blocked drainage due to poor waste

Flooding on roads







Costs (USD)

disposal





SUB-TOTAL – 6,900






Costs (USD)







-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

500



Ensure that vehicles for waste collection are used on specific day and avoid

Monitoring: FRSC

-







Costs (USD)

unnecessary movement.

SUB-TOTAL – 500


Personnel safety






SUB-TOTAL – 5,000


Table 17 ESMP and Monitoring Plan- Refuse Disposal Phase for Sapele






Costs (USD)




500







Costs (USD)

Soil


soil profile


Change in land use





3,000





500

Water Quality




1,000







1200





SUB-TOTAL – 6,900

Component Sub- Activities Potential Mitigation Measures Monitoring Monitoring Institutional Costs







Costs (USD)

component Impact Indicators Frequency Responsibility (USD)






-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

500



Monitoring: FRSC

-

SUB-TOTAL – 500


Personnel safety



Implement on-site occupational health and safety management plan; Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire









Costs (USD)

prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis

SUB-TOTAL – 5,000


Table 18 ESMP and Monitoring Plan- Refuse Collection and Transportation Phase Uvwie






Costs (USD)




250

Soil




Change in land use





1,500





250

Water Quality




500







Costs (USD)






600


Flooding on roads





SUB-TOTAL – 3,450






Costs (USD)







-

Increase in number of

Increase in respiratory


Regular monitoring

Monitoring: -







Costs (USD)

vehicles using roads

problems amongst local residents

NESREA, SMH

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

250




Monitoring: FRSC

-

SUB-TOTAL – 250


Personnel safety






SUB-TOTAL – 2,500



Table 19 ESMP and Monitoring Plan- Refuse Disposal Phase Uvwie






Costs (USD)




250

Soil


soil profile


Change in land use





1,500





250

Water Quality




500







600







Costs (USD)





SUB-TOTAL – 3,450






Costs (USD)






-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

250



Monitoring: FRSC

-

SUB-TOTAL – 250







Costs (USD)


Personnel safety






SUB-TOTAL – 2,500


Table 20 ESMP and Monitoring Plan- Refuse Collection and Transportation Phase Udu






Costs (USD)




250







Costs (USD)

Soil




Change in land use





1,500





250

Water Quality




500






600


Flooding on roads





SUB-TOTAL – 3,450







Costs (USD)






Costs (USD)







-




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

250




Monitoring: FRSC

-

SUB-TOTAL –250


Personnel safety



Implement on-site occupational health and safety management plan;








Costs (USD)

Routine OHS training and education; Conduct routine JHA/PHA; Use of PPE; Implement fall protection program;; Implement HazCom; Conduct hazard identification, control and analysis; Implement fire prevention program; Use material safety data sheets (MSDS); Implement hierarchy of controls procedure; Conduct OHSRA, Cost Benefit Analysis(CBA), Return on Investment (ROI)/pay-back period analysis


SUB-TOTAL – 2,500


Table 21ESMP and Monitoring Plan- Refuse Disposal Phase Udu






Costs (USD)




250

Soil


soil profile


Change in land use





1,500







Costs (USD)





250

Water Quality




500







600





SUB-TOTAL – 3,450






Costs (USD)



Possible spread of water borne diseases



-







Costs (USD)

(Cholera, dysentery)




Regular monitoring

Monitoring:

NESREA, SMH

-

Land use conflicts

Land use conflicts

Land use conflict



Contractors

Monitoring: SPCU

250



Monitoring: FRSC

-

SUB-TOTAL – 250


Personnel safety






SUB-TOTAL – 2,500








Costs (USD)


5.5 Health and Safety Management Plan

The health and safety issues arising from various activities have also been addressed in the ESMP. Provision of standard health and safety equipment are pre-requisite for implementation of health and safety management plan. The following personal safety equipment (PPE) are recommended ensure health and safety of workers. These will be used as per requirement.

Standard PPE generally includes:

1. Gloves: Always wear gloves when handling health care waste. Puncture-resistant gloves should be used when handling sharps containers or bags with unknown contents. Heat-resistant gloves should be worn when operating an incinerator

2. Boots: Safety boots or leather shoes provide extra protection to the feet from injury by sharps or heavy items that may accidentally fall. Boots must be kept clean.

3. Overalls: Overalls should be worn at all times.

4. Goggles: Clear, heat-resistant goggles can protect the eyes from accidental splashes or other injury.

5. Mouth respirators

6. Helmet (for incinerator operators): Helmets protect the head from injury and should be worn at all times during the incineration process.

Others include;

Ear plugs/ muffs

Full body harnesses

First aid kits

Safety signs and tape

Medical examinations

Waste handlers and should be medically examined prior to initial employment and undergo regular medical examinations every 6 months. They should also be immunized for Tetanus and Hepatitis B Virus.


5.6 General procedures to be followed in case of spillages

This section describes the general procedure to be followed by workers, client and relevant stakeholders in the case of spillage. However, this applies mainly for hazardous/dangerous wastes.

It is recommended that all precautions to prevent spillage should be adhered to strictly. This includes;

i. Covering of waste bins,ii. Lightening of waste bags, iii. Covering of tipping trucks with netting or trampoline iv. Use of compactor trucks andv. Avoiding overfilling of trucks.

Also the workers should wear the recommended/provided PPEs for the job as this will go a long way in preventing spillage and contamination.

Evacuate the contaminated area. Decontaminate the eyes and skin of exposed personnel

immediately. Inform the designated person who should coordinate the

necessary actions. Determine the nature of the spill. Evacuate all the people not involved in cleaning up. Provide first aid and medical care to injured individuals. Secure the area to prevent exposure of additional individuals. Provide adequate protective clothing to personnel involved in

cleaning-up. Limit the spread of the spill. Neutralize or disinfect the spilled or contaminated material if

indicated. Collect all spilled and contaminated material. [Sharps should

never be picked up by hand; brushes and pans or other suitable tools should be used]. Spilled material and disposable contaminated items used for cleaning should be placed in the appropriate waste bags or containers.

Decontaminate or disinfect the area, wiping up with absorbent cloth. The cloth (or other absorbent material) should never be turned during this process, because this will spread the contamination. The decontamination should be carried out by working from the least to the most contaminated part, with a change of cloth at each stage. Dry cloths should be used in the case of liquid spillage; for spillages of solids, cloth impregnated with water (acidic, basic, or neutral as appropriate) should be used.

Rinse the area, and wipe dry with absorbent cloths. Decontaminate or disinfect any tools that were used.


Remove protective clothing and decontaminate or disinfect it if necessary.

Seek medical attention if exposure to hazardous material has occurred during the operation.

5.7 Post Exposure Prophylaxis Guidelines for Occupational Exposure

An occupational exposure that may place a worker at risk of tetanus, HIV, Hepatitis B or Hepatitis C infection will require Post-exposure prophylaxis (PEP). PEP is short-term antiretroviral (ARV) or immune globulin treatment to reduce the likelihood of viral infection after exposure to the blood or body fluids of an infected person.

Modes of Exposure:

Types of injury requiring PEP include;

I. Percutaneous injury Needle stick Injuries from scalpels, wires, surgical pins, saws, etc.

II. Mucous membrane exposure—splashes and other contact with mucous membranes (includes eyes, nose, mouth)

III. Non-intact skin exposureIV. Direct contact (without barrier protection) to a concentrated

virus in a research laboratory or production facilityV. Human bites resulting in blood exposure to either person

involved

Factors affecting transmission

1) Whether PPE was worn2) Amount of blood in the exposure3) Amount of virus in patient's blood from who the injury material was

from4) Whether P.E.P. taken or not

The following steps are to be taken in the case of such exposures during work

3. Begin PEP starter pack

4. Evaluation of the source

5. Evaluation of the exposed person


A. Treatment on injury (First Aid):1) Skin Exposure, wash the skin thoroughly with soap and water.2) Skin Wound, immediately wash thoroughly the wound with soap

and water and pat dry.3) Splash to Eye(s), Nose or Mouth, immediately flush the area

with running water for at least 5-10 minutes.B. Exposure/Injury Reporting

In the event of an acute injury or exposure, the injured worker should report to the supervisor.

C. Post Exposure Prophylaxis

Tetanus toxoid: Administer tetanus toxoid to exposed worker.

HIV: If the source person is not known, consider the infection risk high. If the source person refuses a test, it should be assumed that the source is positive. PEP should be initiated as soon as possible, preferably within 2 hours of exposure, and not after 72 hours.

HBV: In case of exposure to HBV, prophylaxis is indicated for susceptible health workers. Those who have a negative HBV surface antigens and no history of receiving immune serum globulin

HCV: There is no vaccine or PEP for hepatitis C. Prevention of exposure is the only effective strategy against HCV infection Following exposure to blood or other body fluids, the source person should be tested for HCV (with consent)

D. Evaluation of Source and Exposed person

Evaluation of the source person is performed when the exposed health worker agrees to take PEP. The following factors should be considered:

If the source is known: If HIV, HBV, and HCV status of source person is unknown, these tests should be performed after obtaining consent. The exposed health worker should not be involved in obtaining consent for testing from the source

If the source is unknown: The exposure should be treated as high risk for infection. Needles and syringes do not need to be tested for viral contamination

WORKER’S RESPONSIBILITIES


First Aid: Perform recommended first aid and decontamination according to the posted instructions. Decontaminate any exposed skin surfaces.

Report to the supervisor on the type of injury.

Identify the equipment/material involved in the exposure and the mechanism of exposure.

Follow up: Contact available healthcare service provider

SUPERVISOR’S RESPONSIBILITIES

First Aid and Decontamination: Verify that the worker has washed and decontaminated himself/herself.

Ensure that appropriate medical treatment has been received.

Confirm that the area has been secured and that notification of contamination has been posted to prevent other individuals from entering the area.

Report the exposure: The report must include the following:

A brief description of the exposure event, a description of the area involved, and the extent of employee exposure

Corrective action taken to prevent the re-occurrence of the incident Decontamination procedures

Follow-Up: Confirm that the worker has called for an appointment at the available healthcare provider.

SEEFOR SPCU RESPONSIBILITIES

The SEEFOR SPCU will ensure that personnel are trained in the use of safe procedures to prevent accidental exposure before assignment to any field work.

The SEEFOR SPCU will carefully explain the necessity of immunization with tetanus toxoid. The SEEFOR SPCU will ensure that all laboratory workers are either fully immunized against, or sign a written declination form.

The SEEFOR SPCU may request assistance from Ministry of Health or SMEnv in providing information about safe work procedures and the necessity of immunization with tetanus toxoid. For assistance, the SEEFOR SPCU should call the SMEnv Public Health Officer


5.7 Mitigation Measures for Refuse collection and Disposal Project

Mitigation measures proffered are generally preventive and based on best practices with regards to impacts arising from identified specific activities to be carried out in the course of the project.

GHG Emissions: Proffered mitigation measures for these include regular maintenance of Compact trucks for collection, use of specified fuel etc

Occupational Health and Safety Risks: Measures for these enforce training of contractor’s personnel in safe work procedures prior to commencement of works.

Waste Disposal: Waste shall be transported in compact trucks or covered trucks to designated dumpsites approved by the SME and/or DELSEPA.

Traffic: Line configurations should be used to help reduce road traffic. Also the collection and disposal should be performed during low traffic period (early in the morning or late at night). This will coincide with the time when the road will be less busy. Creation of alternate route for road users during operation. Use of adequate machinery in relation to street size and capacity (e.g. wheel barrow/smaller vans for smaller streets) to avoid damage to buidlings and properties, Training of drivers on road use, Use of caution signs during operation will mitigate traffic accidents.

Social impacts: Social mobilization and awareness programs will be conducted on the project and its benefits to enhance performance of the project. Hospitals, Schools, residents etc. should be provided facemasks in during work hours to reduce the inhalation of foul odor and emissions. Incorporate the youths of the project communities into the project from the inception to minimise conflict, Trainings and capacity building for the youths will be of importance. Provision of financial/technical assistance to enable PSPs meet required performance target and procure equipment. Alternative inexpensive yet environmentally sound methods can be employed or recommended for use (eg dina trucks covered with netting or trampoline), incorporate private dumpsite owners and cart pushers into the project to avoid loose of income: assign them other duties and responsibilities, develop Capacity building and skill acquisition programs.

Other mitigation measures for potential contamination of surface water, and soils will include prevention of spill during transportation of the collected refuse to dumpsite. This can be achieved by using recommended vehicles and machinery for operation. Also preventing


runoff and leaches from the dumpsite into surface water or filtration into ground water may be achieved by good design and selection of dumpsite.

5.8 Monitoring Program

It is planned that the environmental and social impacts and their designed mitigation measures shall be monitored during implementation of the refuse collection and disposal project. The roles and responsibilities for monitoring the environmental and social impacts and mitigation measures are as follows:

The State Employment and Expenditure for Results (SEEFOR) Project SPCU will ensure implementation of all mitigation measures. The State Ministry of Environment (SME), National Environmental Standards Regulatory Enforcement Agency (State), and Delta State Environmental Protection Agency (DELSEPA) will ensure implementation of measures that concern the environment. The Federal Road Safety Corps (FRSC) and Delta State Transport Management Authority will ensure that mitigation measures for impacts on traffic are implemented. Contractors will be responsible for task-specific mitigation. Independent Consultants will be responsible for the development of management plans as described in the ESMP (e.g. site-specific safety management plans, site-specific waste management plans, workers, respiratory protection program. Public Health departments in the project cities will be responsible for monitoring distribution of face masks to schools, offices etc.

The SME/DELSEPA will undertake compliance monitoring and periodic inspection of work areas. The Ministry of Works will also be involved in some level of monitoring.

All the mitigation measures specified in this plan shall be included in the bid documents for the successful enterprise to implement. Campaigns on HIV/AIDS, environmental protection and personal hygiene and sanitation shall also be undertaken. For this purpose, services of experienced NGOs in the fields would be sought.

5.9 REQUIREMENTS

Following the general observations and findings during the conduct of field visits, environmental assessment, potential impacts identification, consultations with the SEEFOR SPCU, and stakeholders, the under-listed are required to ensure quality assurance throughout the phases of the rehabilitation works.


1. There should be provision for laid down standard procedures to manage conflicts, which may arise during project implementation. Envisaged conflicts may result from increased vehicular flow during the operation phases, interference with water pipeline, comingling of staff, security and safety issues.

2. PSPs staff should be identified with distinct uniforms in order to facilitate easy and accurate identification and should always be kitted with appropriate and durable and appropriate Personal Protective Equipment (PPE).

3. Contractor should have a project Health and Safety manager, who will coordinate and implement health and safety mitigation, measures as addressed in this ESMP.

4. All illegal dumpsites should be cleared and barricaded to avoid further use by residents.

5. Awareness and enlightenment campaign should be carried out to sensitize the residence of the importance of the project and health and environmental implications of their continuous improper disposal of refuse

6. New and Approved dumpsites should be provided for each of the cities to enhance adequate disposal. These dumpsites should be fenced to prevent refuse flowing out to roadsides. Only approved/certified PSPs should be allowed to dispose of Refuse at these sites.

7. Buildings or shades should be provided for the Dumpsite mangers/supervisors

8. More Equipment should be provided for the dumpsite mangers to enhance their activities. These include PPEs, Raincoats, Rakes, Shovels and most importantly Bulldozers.

9. The Dumpsite management should regularly push the refuse daily to avoid overflow (7 days for Warri and 6 days for others).

10. The PSPs that are currently collecting refuse in these cities should be maintained. This is because they have a good understanding of the area and the customers and have been servicing these zones over sometime.

11. The Waste Cart pushers should be integrated with the PSPs so as not to take them off their source of livelihood.

12. The PSPs should be assisted in any way possible to access funds for equipment (Compact Trucks/ Tipping Trucks) as most of them are middle income earners and may not have enough funds to acquire such. This may be in the form of loan which they can repay over a short period.


13. In areas that are not accessible (e.g. Cable point, flood areas etc.), there should be waste bins at strategic and accessible spot where the PSPs can collect and evacuate the refuse at stipulated days.

14. There should be enforcement by the government on residence to use the PSPs and punishment for defaulters. Also individuals caught disposing at illegal sites should be prosecuted. Residents within each community should be used as members of task force or enforcement/compliance team.

15. Regular Health and Safety Trainings for the waste collectors should be encouraged

16. Healthcare insurance scheme should also be made available for the waste collectors and those the work at the dumpsites

17. Segregation of Medical waste at source and dumpsite should be enforced. If possible one PSP should be assigned in each city for collection and disposal of healthcare waste

18. There should be a good working relationship between the Health officers from the LGAs, Waste Management Board, PSPs and The SEEFOR SPCU.

CHAPTER SIX STAKEHOLDERS ENGAGEMENT

6.1 Introduction

The Stakeholder engagement (Focus Group Consultations) for the Environmental and Social Management Plan (ESMP) was conducted from26th of February to 4th of March, 2014. The consultation meetings were held at different locations within each of the six project cities. The consultation was done to ensure the effective participation and awareness of the stakeholders and Project Affected Persons (PAPs).

The following had been taken into full account:

That sub-project activity will not impact negatively on the PAPs


and social sensitivities activities, and if so, that suitable mitigation measures will be implemented by the proponent

That positive impact of sub-project activities will be enhanced. The priority concerns raised by PAPs and other relevant

stakeholders in order to enable the SEEFOR SPCU have accurate knowledge of the potential adverse impacts of the project’s activities, concerns raised by the stakeholders and the “suitable way forward”.

6.2 Objectives of the Public Consultation

To create general public awareness and understanding of the project, and ensure its acceptance;

To develop and maintain avenues of communication between the project proponent, stakeholders and PAPs in order to ensure that their views and concerns are incorporated into project design and implementation with the objectives of reducing, mitigating or offsetting negative impacts and enhancing benefits from the project;

To inform and discuss about the nature and scale of adverse impacts and to identify and prioritize the mitigation measures for the impacts in a more transparent and direct manner;

To document the concerns raised by stakeholders and PAPs so that their views and proposals are mainstreamed to formulate mitigation and benefit enhancement measures; and

To sensitize local authorities of the impacts and solicit their views on the project and discuss their share of the responsibility for the smooth functioning of the overall project operations.

6.3 Stakeholders Identification

The Consultant and the SEEFOR SPCU worked together to identify the key stakeholders that should be consulted during project implementation. This process was completed with the identification of project- affected areas.

The identified stakeholders for consultations were selected as follows:

Government Organization: This level of public consultation constituted staff and representatives from the SEEFOR SPCU

Community Level: At this level, the major communities consulted were members resident within the six project cities. Industries, Market Associations, Youths Associations, Waste Collectors (PSPs), Push cart waste collectors.


6.4 Consultation Methodologies

A combination of various consultation methods were used to assess knowledge, perception and attitude of the groups consulted concerning the Proposed Refuse collection and Disposal Project and their potential environmental and social impacts with regards to their business. The methods used during the consultation process included interviews with key informants/people and small group discussion.

During the consultation process, the stakeholders identified a number of project implementation related issues and these are presented in this report.

6.5 Major Point of the Consultation

Key agenda points that were discussed with the stakeholders included:

Project understanding Identification of potential impacts of the project-both positive and

negative; Stakeholders perception/attitudes about the sub-project; Other relevant issues as raised by the stakeholders.

6.6 Major Findings from Public Consultation

The issues, concerns and demands raised by the stakeholders during the Public consultation, and responses provided by the ESMP Consultant have been summarized and are provided below:

ISSUES/CONCERNS/DEMANDS REACTIONS BY SPCU, SMENV, WMB, CONSULTANT

That the Government should provide them with approved Dumpsite in cities such as Warri, Udu, Uvwie, Sapele and Ughelli

Also that Bulldozers be provided at the Dumpsites to enable 24hour work so as to avoid over flowing of dirt at dumpsites

The SMEnv, DELSWMB and the Local Government Authorities will provide designated dumpsites within close proximity of each of the cities.

SEEFOR highlighted their effort towards getting the government to procure the needed machinery and/or contract the management of


The PSPs expressed their fear that politicians and rich businessmen may hijack the project and dump the existing Waste collectors. Also the PSPs pleaded that the SEEFOR SPCU should try and make the criteria for qualification too stringent for middle/low income earners to participate

Also that the SEEFOR SPCU should assist them in getting Loan facility from Banks to buy Compactor trucks or Tipping Trucks

That they will need regular training on Health and Safety

That the government should create access roads especially in the areas that are not accessible for easy movement of their truck.

That the SEEFOR should help enforce the use of the Waste Collectors (PSPs) by residents

That the Zones should be further sub-divided and more PSPs involved as each zone contains

these dumpsites to a private contractor while the WMB monitors their activities.

They were assured that the criteria for selection which is in the PIM would be followed strictly. And expressed that the project was primarily to create jobs and not remove people from their jobs.

They SPCU stated that it is not in their power to assist the PSP to get loans, however, they will give technical support where need be.

SEEFOR inform the PSPs the need to have Health safety offices in their team and also tated that trainings may be arranged in due time.

Stated that there is currently ongoing road constructions within the state. Also that they inaccessible areas may need alternative means of waste evacuation( eg smaller vans/wheel barrows)

There may be need to form a task force to monitor and ensure compliance. The members of the taskforce should include people living within their respective zones.

The SPCU stated that the enumeration exercise will


more than the stated number of houses recommended for the project. This will give room for better service.

The Residents stated that the SEEFOR should make the tariff affordable and uniform for the different categories

The PSPs also stated that the Government should look into the attacks by youths at the dumpsites (e.g. Ughelli)

Also other local revenue collector should be harmonized within the state to avoid double billing on the PSPs

That the government should also create more awareness to allow for maximum participation and cooperation by the residents.

The scavengers suggested that segregation at source should be encouraged to make their sorting easier and reduce risk of exposure especially with HealthCare Waste (needles and sharps).

assist in knowing the exact modality to use in dividing the zones. Also that after a few years, the performance will be assessed and then determine the need to further divide the zones.

The tariff will be worked out by a financial/billing expert to suit individuals, buildings, industries etc.

Constant awareness and incorporation of the youths and traditional rulers which is ongoing will prevent this in the future.

Since the project is backed by the government, in conjunction with waste management board and SMEnv, there will be harmony. So there will not be avenue for double billing.

There will be continues awareness campaign as part of the program. This will involve the media (TV and Radio), NGOs and other advertising agencies

They were told it may take a while but something can be started through the awareness and sensitization. Private sector companies were also encouraged to buy into the project as they can recover wealth from waste generated


CHAPTER SEVEN INSTITUTIONAL ARRANGEMENT

7.1 Introduction

It is necessary to highlight and define the roles, responsibilities and institutional arrangements for the implementation of the SEEFOR project, as they are fundamental to the effective implementation of the environmental safeguard measures outlined in this ESMP. Accordingly, details of institution arrangements and the roles and responsibilities of the various institutions in the implementation of the ESMP are highlighted below.

7.2 Administrative Framework

In Nigeria, the power of regulation of all environmental matters is vested in the Federal Ministry of Environment (FMENV), hitherto, the now defunct Federal Environmental Protection Agency (FEPA) which was set up by Act 88, of 1988).


In Part III of the Act 88, the State Governments are encouraged to set up “their own Environmental Protection Bodies for the purpose of maintaining good environmental quality in the area of related pollutants under their control.”

Nigeria subscribes to a number of International Regulations and Conventions relating to Environmental Protection.

International Development Partners/Agencies such as World Bank and other financial organizations interested in development projects have sets of environmental categorizations, assessments and management standards, which must be complied with by project proponents before these institutions invest in them.

7.3 SEEFOR Institutional Arrangements

Generally, the SEEFOR project is expected to run at two levels, namely the Federal and State. At the Federal level, the Coordination and Program Support will be managed by the National Project Coordinating Unit (NSPCU) supervised by the Federal Ministry of Finance. The NSPCU will establish coordination and support relationship with the State counterpart Agencies.

Thus at the State level, the governments of the four States are expected to set up by State Law, agencies that would work in collaboration with the FPSU, though operating independently. Albeit, the Ministry of Finance, Budget and /Economic Planning, as the case may be in the various State is at present taking the lead in the coordination of the SEEFOR preparatory programs. In the case of Delta state this is coordinated by the Ministry of Finance. The law or legal agreement used in establishing the agencies will insulate the agencies and specifically the management unit from undue political or administrative interference. In addition, to implement the SEEFOR project according to the agreed terms and conditions, a formal agreement is needed between the State Governments, the Implementing Agencies (SPCU) and other MDAs outlining the tasks, responsibilities, schedules, procedures, deliverables


etc., required for preparation and implementation of the approved sub-projects.

Furthermore, the State Agency/Project Coordinating Unit (SPCU) will have an advisory board or a technical steering committee and a management unit. The board will include representatives from civil society and the government.

The Project Coordinating Unit (SPCU) shall be headed by a Project Coordinator who will supervise activities of staff within three (3) major departments of the Agency, namely: Operations, Finance and Administration, and Monitoring & Evaluation.

To capture the inflow and use of credit proceeds in a transparent manner through the Office of the Accountant General [Project Financial Management Unit (PFMU) set up for financial management of donor assisted projects at the state level], the SPCU shall establish a relationship with PFMU.

This relationship would entail:

o A copy of the annual budget and work plan will be made available to the PFMU by the SPCU;

o PFMU internal auditors will be responsible for regular internal audit in the SPCU and submit quarterly reports to the government (copied to IDA).

o A copy of monthly progress reports, quarterly reviews and interim Financial Reports (IFRs) shall be sent regularly to the PFMU;

o The PFMU internal auditors shall participate in quarterly monitoring visits to communities as organized by the SPCU.

7.4 Roles and Responsibilities

The successful implementation of the ESMP depends on the commitment of the sector and related institutions, and the capacity within the


institutions to apply or use the ESMP effectively, and the appropriate and functional institutional arrangements, among others.

Thus details of institutions arrangements, the roles and responsibilities of the institutions that would be involved in the implementation of the ESMP are highlighted herewith. For the purpose of this ESMP, the institutions identified could be categorized at three levels, namely:

Federal Level Institutions

o Federal Ministry of Environment and other relevant Ministries, Departments and Agencies (MDAs).

State Level Institutions

o SPCUs and other relevant Ministries, Departments and Agencies (MDAs).

Local Government Level Institutions

o Local Government Review Committee (LGRC)

o Local Government Desk Office (LGDO)

Community Level and other Institutions

o Direct and Other Stakeholder/Groups

Community Project Management Committee (CPMC)

CDA

CBO/NGOs

World Bank

7.4.1 Federal Level InstitutionsThe Federal institutions are responsible for the establishment of national policy goals and objectives and the appropriate provision of technical and financial assistance to State and local governments.


For this ESMP specifically, the Federal Ministry of Environment and her relevant agencies like NESREA shall play the role of lead environmental regulator, overseeing compliance requirements, granting consent and also monitoring or providing supervisory oversight for the SEEFOR projects. It also shall receive comments from stakeholders, public hearing of project proposals, and convening technical decision-making panel as well as provide approval and needed clearance for EA/EMP or other environmental clearance.

The Roles and responsibilities of the various institutions which are summarized in the Table below.

Table 22 Safeguards responsibility for SEEFOR

S/N Category Roles I Federal

Government MDAs(Federal Ministry of Environment and her agencies (Such as NESREA)

Lead role -provision of advice on screening, scoping, review of draft RAP/EA report (in liaison with State Ministry of Environment), receiving comments from stakeholders, public hearing of the project proposals, and convening a technical decision-making panel, Project categorization for EA, Applicable standards, Environmental and social liability investigations, Monitoring and evaluation process and criteria

II State Government MDAs (Ministry of Lands, Survey and Urban Development, Ministry of Environment, etc.

Compliance overseer at State Level, on matters of Land Acquisition and compensation and other resettlement issues,Lead role -provision of advice on screening, scoping, review of draft RAP/EA report (in liaison with Federal Ministry of Environment), receiving comments from stakeholders, public hearing of the project proposals, and convening a technical decision-making panel, Monitoring and evaluation process and


S/N Category Roles criteria

Other MDAs Come in as and when relevant areas or resources under their jurisdiction or management are likely to be affected by or implicated sub-projects. They participate in the EA processes and in project decision-making that helps prevent or minimize impacts and to mitigate them. These institutions may also be required, issue a consent or approval for an aspect of a project; allow an area to be included in a project; or allow impact to a certain extent or impose restrictions or conditions, monitoring responsibility or supervisory oversight

III World Bank - Assess and supervise the implementation of the ESMP- Recommend additional measures for strengthening the management framework and implementation performance.

IV SEEFOR SPCU Safeguards Unit

Ensure that World Bank Safeguards Policies are complied with by the projectEnsure that this ESMP is implemented and that the project is in compliance with World Bank Safeguards Policies and the relevant extant laws in Nigeria, including the EIA Act.Liaise closely with Ministry of Environment in preparing a coordinated response on the environmental and social aspects of project development.

V Local government

Liaising with the SPCU to verify adequacy of resettlement location and provide approval for such sites, Providing additional


S/N Category Roles resettlement area if the designated locations are not adequate, Provide necessary infrastructures in relocated areas, engage and encourage carrying out comprehensive and practical awareness campaign for the proposed sub-projects, amongst the various relevant grass roots interest groups.

VI CDA Ensure Community participation by mobilizing, sensitizing community members;

VII NGOs/CSOs Assisting in their respective ways to ensure effective response actions, Conducting scientific researches alongside government groups to evolve and devise sustainable environmental strategies and rehabilitation techniques, Organizing, coordinating and ensuring safe use of volunteers in a response action, and actually identifying where these volunteers can best render services effectively & Providing wide support assistance helpful in management planning, institutional/governance issues and other livelihood related matter, Project impacts and mitigation measure, Awareness campaigns

The other institutions, on the other hand, come in as and when relevant areas or resources under their jurisdiction or management are likely to be affected by or implicated in the execution of the project. These institutions are grouped broadly into two – resource based ones and the utility service providers. They all have a significant role and are consulted as appropriate. They participate in the EA processes and in project decision-making that helps prevent or minimize impacts and to mitigate them. These institutions may also be required:


To issue a consent or approval for an aspect of a sub- project;

To allow impact to a certain extent or impose restrictions or conditions.

Furthermore, the institutions may have monitoring responsibility or supervisory oversight during in an area of concern or interest to them during implementation.

7.4.2 State Level InstitutionsThe State level institutions include the SPCUs and other relevant Ministries, Departments and Agencies (MDAs).

7.4.2.1 State Agencies/Project Management Unit (SA/SPCU)The SA/SPCU, as the implementing authority, has the mandate to:

Co-ordinate all policies, programs and actions of all related agencies in the States

Ensure the smooth and efficient implementation of the project’s various technical programs

Cooperate through a Steering Committee that provides guidance to the technical aspects of all project activities;

Maintain and manage all funds effectively and efficiently for the sub-projects

Plan, coordinate, manage and develop SEEFOR projects to ensure success.

Coordinate activities of the State Licensing Authority and all vehicle inspection units.

Recommend on policy issues to the Governor including mechanisms for implementation.

Prepare plans for the management and development of SEEFOR project.

Facilitate the discussion between PAPs and communities regarding compensation for land acquired for the subprojects micro-projects;


Monitor the project work to ensure that the activities are carried out in a satisfactory manner;

Organize the necessary orientation and training for the departmental officials so that they can carry out consultations with communities, support communities in carrying out RAPs and implement the payment of compensation and other measures (relocation and rehabilitation entitlement) to PAPs in a timely manner;

Ensure that progress reports are submitted to the World Bank regularly

7.4.2.1.1 SPCU Safeguard Units

To ensure environmental and socially friendliness of all SEEFOR projects, an Environmental/Social Safeguards Unit that reports directly to the Project coordinator shall exists. The paramount objective of the Environmental/Social Safeguards unit is to ensure the effective consideration and management of environmental/social concerns in all aspects of SEEFOR project, from the design, planning, implementation, monitoring and evaluation of initiatives in the various States. Thus a key function of the Unit is to engender a broad consensus, through participatory methods and extensive dialogue with affected and interested parties, on fair and adequate methods by which rights of way can be cleared of occupants as needed, taking account of international standards for involuntary displacement as incorporated into the World Bank's OP 4.12 on Involuntary Resettlement and environmental compliance with the EA.

With this, particular attention is directed at minimizing environmental/social risks associated with the development of sub-project initiatives, as well as the identification and maximization of social development opportunities arising from investments.

In the implementation of the SEEFOR, the Safeguard Unit will be expected to advice on the environmental and social costs/benefits of the different options, putting this ESMP under consideration.


For all environmental and social issues, the Safeguard Unit shall work to closely with other relevant MDAs in preparing a coordinated response on the environmental and social aspects of the SEEFOR sub-projects.

To achieve this made, the SPCU would have in each State Steering Committee (Board) and a Project Implementation Unit (PIU) for coordinating the day to day activities with the relevant line departments.

Two members of the SPCU will be designated as Environmental & Social Officers to oversee the implementation of Safeguard instrument as well as any other environmental and social provisions as deemed fit for project implementation as per the regulations of the World Bank and Government of Nigeria and the respective State government. The roles and responsibilities of the Safeguard Specialists (Environmental and Social Officers to anchor environmental and social issues distinctively) to be appointed are indicated Box 2.

7.4.2.2 MDAs- State Ministries of Environment/EPAsThe State Ministries of Environment/EPAs as the compliance overseers have the lead role in providing the State Government’s response to developers on EA matters. This includes provision of advice on screening, scoping, review of draft

Delta State SEEFOR

Box 2: Roles & Responsibilities of Safeguard Specialist

• Review all EA / SA Documents prepared by consultants and ensure adequacy under the World Bank Safeguard policies including the OP4.01.

• Ensure that the project design and specifications adequately reflect the recommendations of the EIA / SIA

• Co-ordinate application, follow up processing and obtain requisite clearances required for the project, if required

• Prepare compliance reports with statutory requirements.• Develop, organize and deliver training programme for the PIU

staff, the contractors and others involved in the project implementation, in collaboration with the SPCU

• Review and approve the Contractor’s Implementation Plan for the environmental measures, as per the EIA and any other supplementary environmental studies that may need to be carried out by the PIU

• Liaise with the Contractors and the PIU / State Implementing agency on implementation of the EMP / RAP

• Liaise with various Central and State Government agencies on environmental, resettlement and other regulatory matters

• Continuously interact with the NGOs and Community groups that would be involved in the project

• Establish dialogue with the affected communities and ensure that the environmental concerns and suggestions are incorporated and implemented in the project

• Review the performance of the project through an assessment of the periodic environmental monitoring reports; provide a summary of the same to the Project Manager, and initiate necessary follow-up actions

• Provide support and assistance to the Government Agencies and the World Bank to supervise the implementation

154

EA report (in liaison with Federal Ministry of Environment), receiving comments from stakeholders, public hearing of the project proposals, and convening a technical decision-making panel.

By the provision of acts, edicts and laws the states have also set up State Ministry of Environments (SMEnvs) as the regulatory bodies to protect and manage the environmental issues in the states.

Enforcement of all environmental legislations and policies;

Coordination and supervision of environmental assessment studies;

Minimization of impacts of physical development on the ecosystem;

Preservation, conservation and restoration to pre-impact status of all ecological processes essential to the preservation of biological diversity;

Protection of air, water, land, forest and wildlife within the states;

Pollution control and environmental health in the states; and

Co-operation with FMEnv and other agencies to achieve effective prevention of abatement of trans-boundary movement of waste.

7.4.2.3 Other MDAsThe roles of the relevant MDAs shall be in correspondence with the earlier spelt out statutory mandates in Section 3.

Suffice it to say that like the Federal counterparts, the State MDAs shall also come in as and when relevant areas or resources under their jurisdiction or management are likely to be affected by or implicated in the execution of the SEEFOR project.

7.4.3 Local Government Level InstitutionsThe Local Government has become accepted as the government nearest to the people or the masses. For any meaningful development to take place, this level of government needs to be galvanized, to execute people oriented programs, which seek to lower poverty level as is designed in SEEFOR, The LG would create enabling environment for improved relationship between the Local Governments and Private and Civil Organization for development

Cooperate with the State Governments to ensure that projects within their domains are sustainable in every sense.


The Local Government Council has to be fully briefed and enlightened in the process and steps to be taken in the ESMF/EA/EMP and the overall project execution. The Council should in turn engage and should be encouraged to carry out a comprehensive and practical awareness campaign for the proposed project, amongst the various relevant grass roots interest groups.

7.4.4 Community Level and other InstitutionsThis includes direct and other concerned stakeholders/groups. This may have complaints/views that need to be resolved in the choosing and execution of the various sub-projects. It is obvious that villages and youth leaders shall ensure that social values are not interfered with.

7.4.5 World BankIt is pertinent to note that during Project supervision, the World Bank will assess the implementation of the ESMP and recommend additional measures for strengthening the management framework and implementation performance, where need be. The reporting framework, screening procedures and preparation of management and mitigation plans shall be discussed and agreed by the Bank team and SPCU during the early part of project implementation.

A comprehensive review of ESMF’s application could be undertaken 12 months after Project effectiveness.

7.5 DELTA STATE MINISTRY OF ENVIRONMENT

The State Ministry of Environment is assigned the following responsibilities:

1. Environmental Policies

2. Environmental protection and control

3. Environmental Technology including initiation of policy in relation to environmental research and technology

4. Planning designing and construction of ecological and environmental facilities;

5. Environmental Sanitation and Urban Waste Disposal and Management

6. Provision of Sanitary means of human disposal;


7. Liaising with oil companies on pollution and Environmental Matters: Forestry, Soil and water conservation, Wild life Preservation, Botanical Gardens, etc.

Parastatals in the Delta State Ministry of Environment

a. Delta State Waste Management Board

The Agency has the following functions:

i. Clear refuse from designated refuse dumps and bins along the streets and corners of the villages, towns and cities in the state;

ii. Manage the disposal and recycling of refuse and other waste materials in a manner that will cause little or no harm to the environment and people living in the state.

iii. Acquire and maintain refuse dumpsites and recycling facilities in all Local Government Areas of the state;

iv. Procure and maintain all vehicles and equipment necessary for proper management of refuse and waste materials in the state;

v. Control, recycle and manage effluent discharge industrial and domestic waste from households and companies operating within the state;

vi. License, register and regulate the operations of all waste management companies in the state;

vii. Formulate and foster private sector participation schemes in waste management in partnership with registered waste management companies;

viii. Educate the public on the importance and different methods of waste management for the purpose of maintaining a clean and sustainable environment and improving public sanitary habits and health standards;

ix. Monitor and enforce complaints with waste management standards and practices prescribed under this law;


x. Monitor and evaluate from time to time as the Board may determine the possible effects of the dumpsites waste on the environment and cast effective restoration;

xi. Develop the skills and knowledge of its employees and provide facilities for training, education and research;

xii. Undertake research in waste management methodology and technology;

xiii. Establish waste treatment and recycling facilities in the states;

xiv. Advise Government in the formulation of waste management policies and in the preparation review of action plans on waste management; and

xv. Perform such other functions as may be prescribed by a law of the House of Assembly.

7.6 MINISTRY OF ECONOMIC PLANNING

7.6.1 MINISTRY OF LANDS, URBAN AND REGIONAL PLANNINGThe Ministry has the responsibilities for the following:

Land policies;

Advice on Land Tenure;

Management of Land and Government properties;

Administration of Land Use Decree;

Town Planning;

Urban Development;

City and Town Rejuvenation.

Parastatals

Urban Planning Board;

Land Use and Allocation Committee.

Office of the Surveyor-General with responsibility for:

Boundary Surveys;


Mapping and Geo- Informatics;

Cadastral and Special Surveys

7.6.2 MINISTRY OF WORKSThis Ministry has the responsibilities for:

Public Works including the construction and maintenance of State Government Urban and Rural Roads, Bridges and Drainages;

Explosives;

Sewage and Waste Water Control.

7.6.3 MINISTRY OF AGRICULTURE AND NATURAL RESOURCESThe Ministry of Agriculture has the major responsibilities in the followings:

Agricultural Services;

Produce Inspection;

Livestock;

Veterinary Services;

Fisheries;

Special Agricultural Projects.

Parastatals

Agricultural Development Programme;

Delta Agricultural Procurement Agency;

Tree Crop Unit;

Tractor Hiring Unit;

Communal Farms

7.6.4 MINISTRY OF WATER RESOURCES DEVELOPMENTThis Ministry was created in 2001 with the following functions:

i. Urban and Rural Water Supply;

ii. Dam Development

iii. Control of water bodies of both surface and underground


iv. Hydrological and hydro geological research

v. Supervision of:

- Urban Water Board; and

- Rural Water Supply Agency.

The Ministry is made up of Seven Departments:

(i) Administration

(ii) Planning, Research & Statistics

(iii) Finance and Accounts

(iv) Technical Services

(v) Hydrology & Hydrogeology

(vi) Rural Water Supply

(vii) Urban Water Supply

Parastatals:

Urban Water Board.

Rural Water Supply Agency/Board

7.6.5 MINISTRY OF WOMEN AFFAIRS COMMUNITY AND SOCIAL DEVELOPMENTEstablished to in 1998, to serve as a veritable catalyst for the actualization programs and services. Its functions and activities permeate all spheres of human interests and caters for the needs of diverse group of individuals across the state, ranging from aged, youths, women, physically challenged destitute and children

Carries out quite a number of activities which include

o Commercial Snacks Productions

o Grants to Widows living with HIV/AIDS

o Residential Life Skill Acquisition Programme- The team visited the center where about 21 young women are undergoing rehabilitation. It was exciting to know that the young women are being taught a number of skills ranging from snailry, fishery, catering, tailoring, hairdressing, etc.

o Organizations of workshops on Women and Climate change


7.6.6 MINISTRY OF YOUTH, CULTURE AND EMPLOYMENT This is charged with, among other things the responsibilities for:

• Youth Registration and Development;

• Development of Youth Skill Acquisition Centers and Poverty Eradication Programme;

• Youth Clubs;


ANNEXURES


ANNEX ONE SUMMARY OF WORLD BANK SAFEGURAD

POLICIES

World Bank Operational Policies

The Bank has ten safeguards policies and these are:

OP 4.00 Use of Country Systems

OP 4.01 Environmental Assessment;

OP 4.30 Performance Standards

OP 4.04 Natural Habitats;

OP 4.09 Pest Management;

OP 4.11 Physical Cultural Heritage;

OP 4.12 Involuntary Resettlement;

OP 4.10 Indigenous People;

OP 4.36 Forests;

OP 4.37 Safety of Dams;

OP 7.50 Projects on International Waterways;

OP 7.60 Projects in Disputed Areas

The triggered safeguard policies for this project are discussed below.

Environmental Assessment (EA) (OP/BP 4.01)

Environmental Assessment is used in the World Bank to identify, avoid, and mitigate the potential negative environmental and social impacts associated with Bank’s lending operations early on in the project cycle. In World Bank operations, the purpose of Environmental Assessment is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted and their concerns addressed. This


policy is triggered if a project is likely to have potential adverse environmental and social risks and impacts in its area of influence. The EA has various tools that can be used, including amongst others Environmental & Social Impact Assessment (ESIA) or Environmental and Social Management Plan (ESMP), which is the case with this sub-project.

Natural Habitats (OP/BP 4.04)

Any project or sub-project with the potential to cause significant conversion (loss) or degradation of natural habitats, whether directly (through construction) or indirectly (through human activities induced by the project).

Forests (OP 4.36)

This operational policy aims to reduce deforestation, enhance the environmental contribution of forested areas, promote afforestation, reduce poverty, and encourage economic development. The policy recognizes the role forests play in poverty alleviation, economic development, and for providing local as well as global environmental services. Success in establishing sustainable forest conservation and management practices depends not only on changing the behavior of all critical stakeholders, but also on a wide range of partnerships to accomplish what no country, government agency, donor, or interest group can do alone.

This policy applies to the following types of Bank financed investment projects:

a. Projects that have or may have impacts on the health and quality of forests;

b. Projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests;

c. Projects that aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned.

Involuntary Resettlement (OP/BP 4.12)

This policy can be triggered if the project will involve involuntary taking of land and involuntary restrictions of access to property, protected areas, etc. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic


impacts. It promotes participation of displaced people in resettlement planning and implementation. The main objective of this policy is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects.

Pest Management OP 4.09

This policy is to (i) promote the use of biological or environmental control and reduce reliance on synthetic chemical pesticides; and (ii) strengthen the capacity of the country’s regulatory framework and institutions to promote and support safe, effective and environmentally sound pest management. It is envisaged that the Project activities on one side may affect the habitats of native fauna (most likely pests such as wild rodents etc.) and on the other, lead to movement of displaced pests to local farm lands and homes (as farmland is the next abundant mass of land in the project states besides forests). In the event of this, the policy aims to (a) Ascertain that pest management activities in Bank-financed operations are based on integrated approaches and seek to reduce reliance on synthetic chemical pesticides (Integrated Pest Management (IPM) in agricultural projects and Integrated Vector Management (IVM) in public health projects. (b) Ensure that health and environmental hazards associated with pest management, especially the use of pesticides are minimized and can be properly managed by the user. (c) As necessary, support policy reform and institutional capacity development to (i) enhance implementation of IPM-based pest management and (ii) regulate and monitor the distribution and use of pesticides.

World Bank performance Standards (OP 4.30/BP 4.30)

The aim of this policy is to facilitate Bank financing1 for private sector led economic development projects by applying environmental and social policy standards that are better suited to the private sector, while enhancing greater policy coherence and cooperation across the World Bank Group.

The eight IFC Performance Standards have been adopted by the Bank as the World Bank Performance Standards for Projects Supported by the Private Sector (“WB Performance Standards”) for application to Bank support for projects (or components thereof) that are designed, owned, constructed and/or operated by a Private Entity, in lieu of the World


Bank’s safeguard policies (“WB Safeguard Policies”). The eight World Bank Performance Standards are:

Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts

Performance Standard 2: Labor and Working Conditions

Performance Standard 3: Resource Efficiency and Pollution Prevention

Performance Standard 4: Community Health, Safety, and Security

Performance Standard 5: Land Acquisition and Involuntary Resettlement

Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Performance Standard 7: Indigenous Peoples

Performance Standard 8: Cultural Heritage

This OP sets forth the circumstances under which the WB Performance Standards may be applied, the roles and responsibilities of the Private Entity implementing the project, and of the Bank in supporting environmental and social sustainability aspects of the project.


ANNEX TWO GENERAL ENVIRONMENTAL MANAGEMENT CONDITIONS FOR CONSTRUCTION CONTRACTS

1. In addition to these general conditions, the Contractor shall comply with any specific Environmental and Social Management Plan (ESMP) for the works he is responsible for. The Contractor shall inform himself about such an ESMP, and prepare his work strategy and plan to fully take into account relevant provisions of that ESMP. If the Contractor fails to implement the approved ESMP after written instruction by the Supervising Engineer (SE) to fulfil his obligation within the requested time, the Owner reserves the right to arrange through the SE for execution of the missing action by a third party on account of the Contractor.

2. Notwithstanding the Contractor’s obligation under the above clause, the Contractor shall implement all measures necessary to avoid undesirable adverse environmental and social impacts wherever possible, restore work sites to acceptable standards, and abide by any environmental performance requirements specified in an ESMP. In general these measures shall include but not be limited to:

a) Minimize the effect of dust on the surrounding environment resulting from earth mixing sites, asphalt mixing sites, dispersing coal ashes, vibrating equipment, temporary access roads, etc. to ensure safety, health and the protection of workers and communities living in the vicinity of dust producing activities.

b) Ensure that noise levels emanating from machinery, vehicles and noisy construction activities (e.g. excavation, blasting) are kept at a minimum for the safety, health and protection of workers within the vicinity of high noise levels and nearby communities.

c) Ensure that existing water flow regimes in rivers, streams and other natural or irrigation channels is maintained and/or re-established where they are disrupted due to works being carried out.

d) Prevent bitumen, oils, lubricants and waste water used or produced during the execution of works from entering into rivers, streams, irrigation channels and other natural water bodies/reservoirs, and also ensure that stagnant water in uncovered borrow pits is treated in the best way to avoid creating possible breeding grounds for mosquitoes.


e) Prevent and minimize the impacts of quarrying, earth borrowing, piling and building of temporary construction camps and access roads on the biophysical environment including protected areas and arable lands; local communities and their settlements. In as much as possible restore/rehabilitate all sites to acceptable standards.

f) Upon discovery of ancient heritage, relics or anything that might or believed to be of archaeological or historical importance during the execution of works, immediately report such findings to the SE so that the appropriate authorities may be expeditiously contacted for fulfilment of the measures aimed at protecting such historical or archaeological resources.

g) Discourage construction workers from engaging in the exploitation of natural resources such as hunting, fishing, and collection of forest products or any other activity that might have a negative impact on the social and economic welfare of the local communities.

h) Implement soil erosion control measures in order to avoid surface run off and prevents siltation, etc.

i) Ensure that garbage, sanitation and drinking water facilities are provided in construction worker scamps.

j) Ensure that, in as much as possible, local materials are used to avoid importation of foreign material and long distance transportation.

k) Ensure public safety, and meet traffic safety requirements for the operation of work to avoid accidents.

3. The Contractor shall indicate the period within which he/she shall maintain status on site after completion of civil works to ensure that significant adverse impacts arising from such works have been appropriately addressed.

4. The Contractor shall adhere to the proposed activity implementation schedule and the monitoring plan / strategy to ensure effective feedback of monitoring information to project management so that impact management can be implemented properly, and if necessary, adapt to changing and unforeseen conditions.

5. Besides the regular inspection of the sites by the Supervising Engineer for adherence to the contract conditions and specifications, the Owner may appoint an Inspector to oversee the compliance with these environmental conditions and any proposed mitigation


measures. State environmental authorities may carry out similar inspection duties. In all cases, as directed by the SE, the Contractor shall comply with directives from such inspectors to implement measures required to ensure the adequacy rehabilitation measures carried out on the bio-physical environment and compensation for socio-economic disruption resulting from implementation of any works.

6. All vessels (drums, containers, bags, etc.) containing oil/fuel/surfacing materials and other hazardous chemicals shall be bonded in order to contain spillage. All waste containers, litter and any other waste generated during the construction shall be collected and disposed of at designated disposal sites in line with applicable government waste management regulations.

7. All drainage and effluent from storage areas, workshops and camp sites shall be captured and treated before being discharged into the drainage system in line with applicable government water pollution control regulations.

8. Used oil from maintenance shall be collected and disposed of appropriately at designated sites or be reused or sold for re-use locally.

9. Entry of runoff to the site shall be restricted by constructing diversion channels or holding structures such as banks, drains, dams, etc. to reduce the potential of soil erosion and water pollution.

10. Construction waste shall not be left in stockpiles along the road, but removed and reused or disposed of on a daily basis.

11. If disposal sites for clean spoil are necessary, they shall be located in areas, approved by the SE, of low land use value and where they will not result in material being easily washed into drainage channels. Whenever possible, spoil materials should be placed in low-lying areas and should be compacted and planted with species indigenous to the locality.

12. The Contractor shall obtain appropriate licenses/permits from relevant authorities to operate quarries or borrow areas.

13. The location of quarries and borrow areas shall be subject to approval by relevant local and national authorities, including traditional authorities if the land on which the quarry or borrow areas fall in traditional land.

14. New extraction sites:


a) Shall not be located in the vicinity of settlement areas, cultural sites, wetlands or any other valued ecosystem component, or on high or steep ground or in areas of high scenic value, and shall not be located less than 1km from such areas.

b) Shall not be located adjacent to stream channels wherever possible to avoid siltation of river channels.

c) Where they are located near water sources, borrow pits and perimeter drains shall surround quarry sites.

d) Shall not be located in archaeological areas. Excavations in the vicinity of such areas shall proceed with great care and shall be done in the presence of government authorities having a mandate for their protection.

e) Shall not be located in forest reserves. However, where there are no other alternatives, permission shall be obtained from the appropriate authorities and an environmental impact study shall be conducted.

f) Shall be easily rehabilitated. Areas with minimal vegetation cover such as flat and bare ground, or areas covered with grass only or covered with shrubs less than 1.5m in height, are preferred.

g) Shall have clearly demarcated and marked boundaries to minimize vegetation clearing.

15. Vegetation clearing shall be restricted to the area required for safe operation of construction work. Vegetation clearing shall not be done more than two months in advance of operations.

16. Stockpile areas shall be located in areas where trees can act as buffers to prevent dust pollution. Perimeter drains shall be built around stockpile areas. Sediment and other pollutant traps shall be located at drainage exits from workings.

17. The Contractor shall deposit any excess material in accordance with the principles of these general conditions, and any applicable ESMP, in areas approved by local authorities and/or the SE.

18. Areas for depositing hazardous materials such as contaminated liquid and solid materials shall be approved by the SE and appropriate local and/or national authorities before the commencement of work. Use of existing, approved sites shall be preferred over the establishment of new sites.


19. To the extent practicable, the Contractor shall rehabilitate the site progressively so that the rate of rehabilitation is similar to the rate of construction.

20. Always remove and retain topsoil for subsequent rehabilitation. Soils shall not be stripped when they are wet as this can lead to soil compaction and loss of structure.

21. Topsoil shall not be stored in large heaps. Low mounds of no more than 1 to 2m high are recommended.

22. Re-vegetate stockpiles to protect the soil from erosion, discourage weeds and maintain an active population of beneficial soil microbes.

23. Locate stockpiles where they will not be disturbed by future construction activities.

24. To the extent practicable, reinstate natural drainage patterns where they have been altered or impaired.

25. Remove toxic materials and dispose of them in designated sites. Backfill excavated areas with soils or overburden that is free of foreign material that could pollute groundwater and soil.

26. Identify potentially toxic overburden and screen with suitable material to prevent mobilization of toxins.

27. Ensure reshaped land is formed so as to be inherently stable, adequately drained and suitable for the desired long-term land use, and allow natural regeneration of vegetation.

28. Minimize the long-term visual impact by creating landforms that are compatible with the adjacent landscape.

29. Minimize erosion by wind and water both during and after the process of reinstatement.

30. Compacted surfaces shall be deep ripped to relieve compaction unless subsurface conditions dictate otherwise.

31. Re-vegetate with plant species that will control erosion, provide vegetative diversity and, through succession, contribute to a resilient ecosystem. The choice of plant species for rehabilitation shall be done in consultation with local research institutions, forest department and the local people.

Water Resources Management


32. The Contractor shall at all costs avoid conflicting with water demands of local communities.

33. Abstraction of both surface and underground water shall only be done with the consultation of the local community and after obtaining a permit from the relevant Water Authority.

34. Abstraction of water from wetlands shall be avoided. Where necessary, authority has to be obtained from relevant authorities.

35. Temporary damming of streams and rivers shall be done in such a way avoids disrupting water supplies to communities downstream, and maintains the ecological balance of the river system.

36. No construction water containing spoils or site effluent, especially cement and oil, shall be allowed to flow into natural water drainage courses.

37. Wash water from washing out of equipment shall not be discharged into water courses or road drains.

38. Site spoils and temporary stockpiles shall be located away from the drainage system, and surface run off shall be directed away from stockpiles to prevent erosion.

39. Location of access roads/detours shall be done in consultation with the local community especially in important or sensitive environments. Access roads shall not traverse wetland areas.

40. Upon the completion of civil works, all access roads shall be ripped and rehabilitated.

41. Access roads shall be sprinkled with water at least five times a day in settled areas, and three times in unsettled areas, to suppress dust emissions.

42. Blasting activities shall not take place less than 2km from settlement areas, cultural sites, or wetlands without the permission of the SE.

43. Blasting activities shall be done during working hours, and local communities shall be consulted on the proposed blasting times.

44. Noise levels reaching the communities from blasting activities shall not exceed 90 decibels.

45. Unusable materials and construction elements such as electro-mechanical equipment, pipes, accessories and demolished structures will be disposed of in a manner approved by the SE. The Contractor has to agree with the SE which elements are to be surrendered to the


Client’s premises, which will be recycled or reused, and which will be disposed of at approved landfill sites.

46. As far as possible, abandoned pipelines shall remain in place. Where for any reason no alternative alignment for the new pipeline is possible, the old pipes shall be safely removed and stored at a safe place to be agreed upon with the SE and the local authorities concerned.

47. AC-pipes as well as broken parts thereof have to be treated as hazardous material and disposed of as specified above.

48. Unsuitable and demolished elements shall be dismantled to a size fitting on ordinary trucks for transport.

49. In advance of the construction work, the Contractor shall mount an awareness and hygiene campaign. Workers and local residents shall be sensitized on health risks particularly of AIDS.

50. Adequate road signs to warn pedestrians and motorists of construction activities, diversions, etc. shall be provided at appropriate points.

51. Construction vehicles shall not exceed maximum speed limit of 40km per hour.

52. Should the Contractor, deliberately or accidentally, damage private property, he shall repair the property to the owner’s satisfaction and at his own cost. For each repair, the Contractor shall obtain from the owner a certificate that the damage has been made good satisfactorily in order to indemnify the Client from subsequent claims.

53. In cases where compensation for inconveniences, damage of crops etc. are claimed by the owner, the Client has to be informed by the Contractor through the SE. This compensation is in general settled under the responsibility of the Client before signing the Contract. In unforeseeable cases, the respective administrative entities of the Client will take care of compensation.

54. Within 6 weeks of signing the Contract, the Contractor shall prepare an EHS-MP to ensure the adequate management of the health, safety, environmental and social aspects of the works, including implementation of the requirements of these general conditions and any specific requirements of an EMP for the works.

The Contractor’s EHS-MP will serve two main purposes:


• For the Contractor, for internal purposes, to ensure that all measures are in place for adequate HSE management, and as an operational manual for his staff.

• For the Client, supported where necessary by a SE, to ensure that the Contractor is fully prepared for the adequate management of the HSE aspects of the project, and as a basis for monitoring of the Contractor’s HSE performance.

55. The Contractor’s EHS-MP shall provide at least:

• A description of procedures and methods for complying with these general environmental management conditions, and any specific conditions specified in an EMP;

• A description of specific mitigation measures that will be implemented in order to minimize adverse impacts;

• A description of all planned monitoring activities (e.g. sediment discharges from borrow areas) and the reporting thereof; and

• The internal organizational, management and reporting mechanisms put in place for such.

56. The Contractor’s EHS-MP will be reviewed and approved by the Client before start of the works. This review should demonstrate if the Contractor’s EHS-MP covers all of the identified impacts, and has defined appropriate measures to counteract any potential impacts.

57. The Contractor shall prepare bi-weekly progress reports to the SE on compliance with these general conditions, the project EMP if any, and his own EHS-MP. An example format for a Contractor HSE report is given below. It is expected that the Contractor’s reports will include information on:

• HSE management actions/measures taken, including approvals sought from local or national authorities;

• Problems encountered in relation to HSE aspects (incidents, including delays, cost consequences, etc. as a result thereof);

• Lack of compliance with contract requirements on the part of the Contractor;

• Changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects; and

• Observations, concerns raised and/or decisions taken with regard to HSE management during site meetings.


58. It is advisable that reporting of significant HSE incidents be done “as soon as practicable”. Such incident reporting shall therefore be done individually. Also, it is advisable that the Contractor keeps his own records on health, safety and welfare of persons, and damage to property. It is advisable to include such records, as well as copies of incident reports, as appendices to the bi-weekly reports. Example formats for an incident notification and detailed report are given below. Details of HSE performance will be reported to the Client through the SE’s reports to the Client

59. The Contractor shall provide sufficient training to his own personnel to ensure that they are all aware of the relevant aspects of these general conditions, any project EMP, and his own EHS-MP, and are able to fulfill their expected roles and functions. Specific training should be provided to those employees that have particular responsibilities associated with the implementation of the EHS-MP.

General topics should be:

• Occupational Health and Safety Basics

• Occupational Health and Safety in water supply pipeline installation

• Safety Practices in Borehole installation and Aquifer Abstraction

• Electrical Safety Basics

• Hazard Identification and Control

• Hazard Communication Program

• Accident Investigation

• Asbestos Management

• Safe work Procedures

• Fall Protection

• Noise Management Program

• Workers Respiratory Program

• Work place Violence Management

• Fire Safety

• Emergency Management; and

• Social and cultural awareness


60. It is expected that compliance with these conditions is already part of standard good workmanship and state of the art as generally required under this Contract. The item “Compliance with Environmental Management Conditions” in the Bill of Quantities covers these costs. No other payments will be made to the Contractor for compliance with any request to avoid and/or mitigate an avoidable HSE impact.

Example Format: HSE Report

Contract:

Period of reporting:

HSE management actions/measures:

Summarize HSE management actions/measures taken during period of reporting, including planning and management activities (e.g. risk and impact assessments), HSE training, specific design and work measures taken, etc.

HSE incidents:

Report on any problems encountered in relation to HSE aspects, including its consequences (delays, costs) and corrective measures taken. Include relevant incident reports.

HSE compliance:

Report on compliance with Contract HSE conditions, including any cases of non-compliance.

Changes:

Report on any changes of assumptions, conditions, measures, designs and actual works in relation to HSE aspects.

Concerns and observations:

Report on any observations, concerns raised and/or decisions taken with regard to HSE management during site meetings and visits.

Signature (Name, Title Date):

Contractor’s Representative

Example Format: HSE Incident Notification

Provide within 24 hrs to the Supervising Engineer

Originators Reference No:


Date of Incident: Time:

Location of incident:

Name of Person(s) involved:

Employing Company:

Type of Incident:

Description of Incident:

Where, when, what, how, who, operation in progress at the time (only factual)

Immediate Action:

Immediate remedial action and actions taken to prevent reoccurrence or escalation

Signature (Name, Title, Date):

Contractor’s Representative

ANNEX THREE SUMMARY OF THE DATABASE OF INFORMATION COLLECTED FOR ESMP

Questionnaire - Households

1. Household size (number of people in a household)?2. Marital status?


3. Age of people in the households?4. Means of waste disposal (e.g. burning, dumping, burying, and

organised collection)?5. Frequency of waste disposal per household?6. If waste is collected, who is provides the service?7. Frequency of waste collection?8. Do you pay for waste? If yes how much?9. Frequency of payment?10. Willingness to pay for (waste bins/waste collection)? If yes,

amount willing to pay?11. Estimated size of waste bin?12. Do you bag your waste? 13. Do you segregate your waste?14. Current issues with waste collection?

Questionnaire - Waste Collectors

1. Means of transporting waste from household to dumpsites?2. Equipment used?3. Frequency of waste collection?4. Is waste sorting carried out? If yes, is it during collection or at

disposal?5. Accessibility to collection points (households) and disposal points

(dumpsites)? Any difficulties (traffic or bad roads )Rating: Very Good - Good - Fair - Bad - Very Bad

6. Availability of PPE? If yes do you use them?7. Issues or Complaints? 8. Records of injuries?

Questionnaire – Min of Environment, SEEFOR, Waste Management Board

1. How are dumpsite locations selected? 2. Legacy issues for dumpsites? (Are they government owned land or

are bought) 3. Sizes of dumpsites of pits?4. Number of government specified dumpsites?5. Are dumpsites fenced?6. Proximity of dumpsites to households, water bodies etc.?7. Availability of security at dumpsites?8. Availability of dumpsite management personnel?9. Is there a sustainable management plan for dumpsites?10. Presence of Scavengers? Accessibility for Scavengers?11. How do you manage illegal dumpsites?


12. Do you provide PPE for workers?13. What is the Household/Business payment collection system

for waste collection services? Please specify the amount?14. Is there a health and safety management plan?15.How are the dumpsites managed during different seasons?

Questionnaire – Scavengers

1. Types of materials collected? Please specify the amount?2. Approximate number of scavengers per dumpsite?3. Earnings from selling reusable?4. High in demand materials?5. Are there buyers of reusable from dumpsites? Examples?6. Equipment used for scavenging activities?7. Availability of PPE? Use of PPE?8. Records of injuries?


ANNEX FOUR GRIEVANCE REDRESS MECHANISM

Grievance redress mechanisms (GRMs) are institutions, instruments, methods, and processes by which a resolution to a grievance is sought and provided. The redressal of grievance will serve as a forum for people to express their dissatisfaction over resettlement plans. It will also limit unnecessary delays and cost overrun of the project.

The SEEFOR Project could will bring about dramatic changes within the affected communities. These changes may lead to opportunity for some or may put others at risk.

Purpose of Grievance Redress Mechanism

The people affected by the SEEFOR Project will raise their grievances about actual or perceived impacts in order to find a satisfactory solution. This is an important aspect in this dam project because land acquisition is indispensable through the course of the project.

These grievances, influenced by their physical, situational (e.g., employment), and/or social losses, can surface at different stages of the project cycle. Some grievances may arise during the project design and planning stage, while others may come up during project implementation. Not only should affected persons (APs) be able to raise their grievances and be given an adequate hearing, but also satisfactory solutions should be found that mutually benefit both the APs and the Federal Ministry of Power. It is equally important that APs have access to legitimate, reliable, transparent, and efficient institutional mechanisms that are responsive to their complaints.

Members of the Grievance Redress Committees (GRC)

The Grievance Redress Committees, GRC, will be mandated to deal with all types of grievances arising at the community level due to the SEEFOR Project. The GRC members will comprise of qualified, experienced, and


competent personnel who will be able to interact and gain the trust of the APs in their communities. The GRC should consist of both male and female representatives. They should be able to accept complaints, provide relevant information on the process, discuss the complainants’ situations with AP’s, and explore possible approaches for resolution

The committee will include the following members:

Resettlement Policy Framework Consultant

Social safeguard officer for the SEEFOR;

A representative of women residing the affected Project study area;

A representative from the Private sector (if a private company is located

within the affected area);

A representative of a voluntary organization, NGO;

Members of Local Government area included in the affected area;

A representative appointed by the Community head.

The Grievance Redress Committee will be responsible for:

Communicating with the Affected Persons (AP) and evaluate if they

are entitled to recompense:

to publicize within the Communities the list of affected persons and

the functioning of the established grievance redressal procedure;

to recommend to the Safeguards Officer of SEEFOR solutions to

such grievances from affected persons;

to communicate the decisions to the APs; and

to acknowledge appeals from persons, households or groups who

rightfully will not be affected by the SEEFOR, but claim to be, and

to recommend to the NPMU whether such persons should be recognized as AP, and to communicate back the decisions to the Claimants.


Summary of the Community Grievance Procedure

Many grievances arise due to failure to provide sufficient and timely information to communities. Accurate and adequate information about a project and its activities, and approximate implementation schedule, will be communicated to the communities, especially APs, regularly throughout the project process.

Stakeholders from the community and FPMU in the state and local level will be involved in the grievance mechanism design. SEEFOR Project will engage community representatives to identify key issues such as the kinds of disputes that could arise during the project activities, how people in the community actually want to raise concerns, the effectiveness of current SEEFOR procedures for resolving complaints, and the availability of local resources to resolve conflicts. This will assist in shaping both the design and future improvements.

All grievances related to resettlement will be managed though the Grievance Redress Committee (GRC). The objective of the Community Grievance Procedure is to receive, respond and address any grievances made to the Project. Grievances will be responded to as quickly and efficiently as possible, avoiding escalation of the issue, reducing negative impacts on the local population and maintaining a positive attitude towards the Project amongst stakeholders.

The Grievance Procedure will be available to local populations residing in the Project areas and other stakeholders directly affected by the Project (which may include landowners residing in urban centers). The Grievance Redress Committee representatives serving, as focal points are most effective if they are trustworthy, trained, knowledgeable, and approachable regardless of the ethnicity, gender, or religion of the complainant. Therefore, effort will be made to ensure this. Local populations residing in the Project areas and other stakeholders directly


affected by the Project will be informed about the grievance process transparency and credibility of the process and they will be provided with both verbal (through regular Stakeholder meetings) and written (such as newsletters) forms

Other channels of presenting complaints could include presentation of

complaints via third parties (e.g., village elites, community‐based organizations, lawyers, NGOs etc.); community meetings; suggestion boxes (maybe placed in churches, village and market squares) allowing

for anonymity; face‐to‐face meetings; written complaints etc. This will be accessible to all especially more vulnerable groups such as women and youth. Confidentiality and privacy for complainants should be granted.

The grievance mechanism will be open to a wide range of concerns both those based in factual data and those arising from perceptions or misperceptions. Perceived concerns can be as critical to address as actual hazards. The mechanism should also be able to address multi-party and multi-issue complaints.

Community consultations and dialogue for the project will be implemented. Efforts will be made to provide community members with opportunities to express their concerns, clarifying and respond to their issues and to find out their views. Receiving these feedbacks will benefit the community members, and GRC.

Capacity development for community facilitators, GRC and field-level staff will be implemented because they are the organs that will reach out to the communities, and it becomes necessary for these staff and representatives to be well grounded with adequate information on the project. They will be able to communicate effectively in the local languages, understanding community dynamics and processes, negotiation and conflict resolution, and empathizing with communities and their needs. Building trust and maintaining good rapport with the people in the Project areas by providing relevant information on the


project and responding effectively to their needs and concerns will help solve issues before they even become grievances. It is also important that the community facilitators, GRC and field-level staff provide feedback to the Federal Ministry of Power.

The design and operation of the grievance mechanism will consider cultural differences, such as communities’ preferences for direct or indirect negotiation; attitudes toward competition, cooperation, and conflict; the desire to preserve relationships among complainants; authority, social rank, and status; ways of understanding and interpreting the world; concepts of time management; attitudes toward third parties; and the broader social and institutional environment.

The GRC will make efforts to provide regular feedback to relevant stakeholders in order to clarify expectations about what the mechanism does and does not do; to encourage people to use the mechanism; to present results; and to gather feedback to improve the grievance system.

Scope of Grievances

Using the information gathered through the assessment of the situation in the community, the GRC will endeavor to review the type of grievances that are likely to arise. Generally, grievance mechanisms should be open to a wide range of concerns: both those based in factual data and those arising from perceptions or misperceptions. Perceived concerns can be as critical to address as actual hazards. They often arise when people do not have adequate information. The mechanism should also be able to address multiparty and multi-issue complaints. The members of the GRC have to establish the types of complaints that the mechanism will primarily target.

Community Expectations When Grievances Arise

The members of the community will expect that their grievances will be addressed by the SEEFOR, which we will aim to achieve through the GRC.


When local people present a grievance, they generally expect to receive one or more of the following:

A concession in recognition of their problem

An honest response to questions about SEEFOR Project activities

An apology

Compensation when applicable

Modification of the activities that caused the grievance

Some other fair remedy.

Steps in carrying out a Grievance Redress Mechanism

There is no ideal method of approach to grievance resolution however; the best solutions to conflicts are generally achieved through localized mechanisms that take account of the specific issues, cultural context, local customs, and the project state and its magnitude.

The Grievance Redress Committees of the SEEFOR will endeavor to be hold meetings with the aggrieved person(s) or groups within a maximum of 3 weeks from the time of receiving the complaint.

The following steps will be followed throughout the Grievance Redress Mechanism process in the various Communities.

Methods that can be used to Receive, & Register, Screen, Assess, and Respond to Grievances

To Receive and Register a Complaint

The channels for receiving and registering complaints is a simple process where local people can inform the GRC about concerns directly and, if necessary, anonymously or via third parties. Reception procedures are most effective if they are convenient, culturally appropriate, simple to understand, and easy to use.

Multiple channels should be available to gather and forward the AP’s concerns. At least one member of the network should be independent of


the Project team. The GRC will accept complaints, whether written or oral, record them on a simple form, to deal with the issue or if need be, forwarded to the focal point of contact at the Federal Ministry of Power for further action.

Diverse methods that are culturally appropriate should be used, including self-identified, confidential, or anonymous procedures (professional letter writers, suggestion boxes).

A member of the GRC should be available to receive complaints and log them into a central register.

Screening for Eligibility of Complaints

This process determines whether a complaint is eligible for inclusion in the grievance mechanism. The GRC should develop a screening procedure based upon few simple eligibility criteria that do not involve judging the substantive merit of the complaint.

Eligible complaints may include those where:

The complaint is related to the project.

The issues raised in the complaint fall within the scope of issues the

grievance mechanism is authorized to address.

The complainant has standing to file.

Ineligible complaints may include those where:

The complaint is not related to the SEEFOR project

The nature of the issue is outside the mandate of the grievance

mechanism.

The complainant has no standing to file

Other community procedures are more appropriate to address the issue.


If the complaint is rejected, the complainant is informed of the decision and the reasons for the rejection. If eligible, the complainant will be notified, and the grievance will be processed and the next stage that is assessment will follow.

The GRC will ensure that that all grievances are truly understood before they are responded. It must be established that all complaints received form the AP’s receive a favorable judgment before rejecting.

* Assessment procedures (who conducts the assessment and how is the assessment conducted)

* Procedures to identify appropriate people in company to whom a specific concern should be forwarded

*

Procedures to determine the appropriate resolution process (in consultation with complainant)

* Procedures for making decisions on proposed settlements


* Assessment procedures (who conducts the assessment and how is the assessment conducted)

* Appropriate time frames for each step in the grievance resolution process (including screening, assessment, and resolution)

* Notification procedures to the complainant about eligibility, assessment results, proposed settlement, and the like.

Assess the Grievance At this stage the GRC will gathers information about the case and the key issues of concerns which will help to determine whether and how the complaint might be resolved

Procedure for Assessing Grievance is as follows:

Determine who will conduct the assessment. A Complaints Coordinator

will be appointed to perform this task or directs it to an appropriate

person(s) for assessment (production, procurement, environment,

community relations, human resources).

A representative from the GRC will endeavor to engage directly with the

complainants to gain understanding of the nature of the complaint. Clarify the parties, issues, views, and options involved. Identify the

parties involved. Clarify issues and concerns raised by the complaint.


Gather views of other stakeholders, including those in the GRC and SEEFOR.

Determine initial options that parties have considered and explore

various approaches for settlement.

Classify the complaint in terms of its seriousness (high, medium, or low).

Using this category, seriousness, will measure the potential to impact the

community. The factors to consider will include: the gravity of the

allegation, the potential impact on an individual’s or a group’s welfare

and safety, or the public profile of the issue.

Engage more directly with the complainant in the assessment process,

and involve the complainant in influencing the resolution process to be

selected, and settlement options.

Formulate a Response Procedures to formulate responses are as follow:

The Complaint Coordinator will be responsible for preparing the

response which will consider the complainants’ views about the process

for settlement as well as provide a specific remedy. The response may

suggest an approach on how to settle the issues, or it may offer a

preliminary settlement.

Meeting may be coordinated which will serve as a forum for the

complainant to present the persons complaints, discussion amongst the

complainant, the Complaint Coordinator, member(s) of the GRC will

follow. If a direct meeting is not possible, consider meeting with a

neutral third party serving as facilitator. The group would also discuss

appropriate next steps during this meeting. If the proposal is a

settlement offer and it is accepted, the complaint is resolved successfully

and there is no need to proceed to the next step of selecting a resolution

approach. If the complainant is not happy with the response about a

resolution process or substance, the group should try to reach an

agreement that would be mutually acceptable.


If the case is complex and a resolution time frame cannot be met, provide

an interim response facilitated through oral or written communication

(best to the complainants preference) that informs the person of the

delay, explains the reasons, and offers a revised date for next steps.

Process of Selecting Select Grievance Resolution Approaches

A variety of Grievance Resolution Approach will be incorporated which will accommodate differences in personal and cultural preferences. The grievance mechanism will offer a variety of grievance resolution approaches and the complainant should have influence over which approach to select. They approaches include the following:

Scenario 1: Where the GRC proposes a solution

This should be conducted as an Informal approach which will involve direct involvement of the GRC or a representative with the complaint. The GRC will propose a solution and offers it to the complainant. The GRC and community would jointly decide if the solution is acceptable and, hence, share decision-making authority. This process can be facilitated if the GRC conducted an initial assessment, and then make a settlement proposal that they hope the complainant will accept. The proposal should be based on consistent standards and criteria so that similar complaints receive similar remedies.

The following measures can help increase the acceptability of responses:

There should be a rationale for the decision and presentation of any data that will be used to reach a conclusion (for example, value of land, crop, or animals; costs to repair a road).

There should be an opportunity for the complainant to verbally present his, her, or their case to a GRC or representative. The representative should listen to and acknowledge the complainant’s statement to help reach emotional closure and restore positive relations between the complainant and the SEEFOR.


Timely delivery of a response and rapid restitution once a decision has been made.

Delivery of the GRC’s response in writing and, when appropriate, a visit by a representative to explain the decision in person.

If the complainant rejects the proposal, the Scenario 2 may be used.

Scenario 2: Where the Community and the GRC decides to make the decision together.

This option involves the GRC representatives and complainants sharing the decision-making and jointly engaging in a problem-solving approach to reach a resolution of the grievance by themselves. The process may involve only the company and complainant, or may be facilitated by a neutral third party without decision-making authority, such as a mediator.

This approach is likened to be the most accessible, natural, and unthreatening ways for communities and Project team to resolve differences. With the potential to resolve perhaps 90 percent of all grievances, “decide together” should be the center of any grievance mechanism’s resolution options. The complaints and the GRC representative however need to furnish themselves in their communication skills, dialoguing and negotiating skills for ease in relating with the people.

Scenario 3: Formal independent redress approach, such as arbitration using a neutral third party.

This approach can be used when the GMC and the complainants are unable to resolve a complaint themselves. The decision making will lean on the independent, neutral party. The neutral party may be a trusted individual or a group in the community, a respected technical expert, or an independent arbitrator. In a typical arbitration case, the parties engaging in the process would decide if the decision is binding (the


parties promise at the beginning of the process to implement the intermediary’s decision) or non-binding (the intermediary’s decision is a recommendation to the company and the community, and can be appealed in court or to some higher authority).

Scenario 4: The company and community engage traditional and customary practices

Rights-based approach based on legal, contractual, local and customary ways of grievance resolution which will be evaluated and incorporated into the system. All societies have internal ways of handling their differences. The local people may decide to find succour in resolving the disputes from their traditional or religious leaders. Therefore the GRC will inventory traditional, religious and customary approaches for solving conflicts and consider how to adapt traditional, religious and customary dispute- resolution mechanisms to deal with community-company grievances. For this scenario, observers, testifiers, witnesses can be employed to verify the fairness, and assure that agreements comply with widely accepted community values and norms. Advisors and mediators can also be used which may include respected people in their communities. Members of traditional communities often seek advice from respected or wise members on how their differences can best be resolved. Disputants often ask for recommendations that comply with community norms and restore harmonious relationships.


ANNEX FIVE LIST OF STREETS WITHIN THE ZONES IN EACH OF THE PILOT CITIES

ASABA ZONING/DELINEATON FOR REFUSE COLLECTION AND DISPOSAL

ZONE 1:

FROM DBS ROAD TO MIDDLE MANAGEMENT QUARTERS TO INTER-BAU ROUNDABOUT TO SUMMIT AREA, ASABA.

ZONE 2:

FROM DAFIAGHOR OKPAKO STREET BY NTA ROAD AND OBIDIMA OKONNE BY AGRIC CO-OPERATIVE HOUSE TO DBS ROAD AND GOVT HOUSE ROAD, ASABA.

ZONE 3:

NNEBISI OBIEMENASHI TO OPPOSITE ZAPPA CHURCH UMUAGU/ISIEKE AREA. ASABA


FROM MADUEMEZIA HOSPITAL ROAD BY NNEBISI ROAD TO ISIEKE ROAD BESIDE UBA (UMUDAIKE AREA), ASABA.

ZONE 4:

FROM AGRIC ROAD TO JESUS SAVES TO SUMMIT BY THE RIGHT THROUGH INTER-BAU TO NNEBISI ROAD, ASABA.

OGBOTOBO CRESCENT BY WEST END TO GOVERNOR’S STREET TO LINK JESUS SAVES BY CHUKE ONUKWU CRESECENT, AGRIC ROAD, ASABA.

ZONE 5:

EUGENE OBA STREET TO DENNIS OSADEBAY TO ABRAKA FILLING STATION, ASABA

FROM STRUB STREET TO EUGENE OBA STREET, ASABA.

ZONE 6:

FROM ST. BRIDGIT’S ROAD TO BENIN/ASABA EXPRESSWAY TO ROAD SAFETY TO UMUNAJI STREET (1 2X) AREA, ASABA.

ZONE 7:

FROM MADUEMEZIA AVENUE BY HOPE MARK FILLING STATION TO STADIUM ROAD ON NNEBISI ROAD, ASABA.

ZONE 8:

FROM AMB. LEO OKOGWU STREET TO BIOSA AMATU STREET BY DLA DOWN TO SUMMIT ROAD BY THE LEFT, ASABA.

ZONE 9:

FROM UMEJI ADUDU WAY TO INFANT JESUS ACADEMY AREA TO OPPOSITE ANWAI RIVER TO GOVET HOUSE FENCE THROUGH PRINCE IYEKE IKECHUKWU WAY TO JASMINE SCHOOL BY THE LEFT, ASABA.

ZONE 10:

IDUMUGBE FROM IBUSA ROAD BY STOP- OVER JUNCTION TO MINISTRY OF JUSTICE AND ALONG UMUONAJE STREET (1 2X) TO ASABA/BENIN EXPRESS, ASABA.

ZONE 11:


FROM AGGS GATE TO OBI-EMENASHI STREET (MADUMEZIA HOSPITAL AREA) TO ZAPPA ROAD BY MOKOLO STREET, ASABA.

ZONE12:

FROM FEDERAL COLLEGE ROAD TO DENNIS OSADEBAY WAY TO ABRAKA FILLING STATION TO EXPRESS THROUGH EZENEI AVENUE TO CELESTRIAL CHURCH ROAD TO IKEJIUNOR CLUDESAC CLOSE, ASABA.

ZONE13:

JARRET STRUB STREET (NNEBISI ROAD) TO THE RIVER (ANCHORAGE), ASABA.

ZONE 14:

FROM LEO OKOWEZE BY EZENEI AVENUE TO TOM MAKWE STREET TO CELESTRIAL CHURCH ROAD TO IKEJIUNOR CLUDESAC.

FROM TRAFFIC LIGHT JUNCTION TO LEO OKONWEZE TO FEDERAL COLLEGE BACK FENCE TO THE GATE, ASABA.

ZONE 15:

FROM ZAPPA TO IBUSA ROAD TO DLA ROAD TO AMB. LEO OKONGWU STREET AND END AT LEO OKONGWU ROAD, ASABA.

ZONE 16:

FROM POLICE COMMISSIONER’S QUARTERS ROAD TO STOP AT EAGLE STREET, POLICE COMMISSIONER’S QUARTERS JUNCTION BY EXPRESS TO FEAR GOD STREET, ASABA.

ZONE 17:

AJAJI ROAD BY UMUEKWO STREET TO ONI EDOZIEN STREET TO EZENEI AVENUE TO ASABA/BENIN EXPRESSWAY, ASABA.

ZONE 18:

AGRIC ROAD BY NNEBISI ROAD TO JESUS SAVES, AMB. LEO OKOGWU TO AGGS GATE BACK TO ARCH. EMORDI CRESCENT, ASABA.

ZONE 19:

FROM SUMMIT TO CHIAGOZIEM STREET ON LEFT FROM THE NUEL OJEI OFFICE, ASABA.

ZONE 20:


FROM CHIAGOZIEM STREET TO FALCON CLUB ROAD ALONG DLA ROAD, UP TO ASABA/BENIN EXPRESSWAY, ASABA.

ZONE 21:

FROM FALCOM CLUB TO DLA ON THE LEFT AND IBUSA ROAD JUNCTION OF DLA BY IBUSA ROAD TO KOKA FILING STATION ALONG ASABA/BENIN EXPRESSWAY, ASABA.

FROM DESTINY HOTEL ROAD BY SMART IDIOMA ROAD TO ANISHIA STREET BY THE LEFT TO IBUSA ROAD (BENIN/ASABA EXPRESSWAY), ASABA.

ZONE 22:

FROM STADIUM ROAD TO LANDER BROTHER’S ANCHORAGE (EXCLUDING OGBEOGONOGO MARKET), ASABA.

ZONE 23:

DLA BY SUMMIT ROAD TO JESUS SAVES ROAD TO EMERALD HOTEL ROAD TO LINK BIOSA AMATU STREET, ASABA.

ZONE 24:

TRIANGLE AREA (OLD AND NEW ANWAI ROAD), ASABA.

HOPE MARK FILLING STATION TO FMC (ALONG NNEBISI ROAD), ASABA

ZONE 25:

FROM JUNIOR STAFF QUARTERS ROAD TO DBS ROAD TO EXPRESS BY NIPCO FILLING STATION TO SUMMIT, ASABA.

ZONE 26:

FROM FAMILY SUPPORT TO LABOUR HOUSE BY DIAFIAGHOR OKPAKO STREET TO THE EXPRESS (EXCLUSIVE OF THE LEGISLATIVE QUARTERS), ASABA.

ZONE 27:

FROM UMUJI ADUDU WAY TO FMC ALONG OLD ANWAI, ASABA.

ZONE 28:


FROM ONI EDOZIEN TO UMUEKWO STREET BY UMUAJI (ST. BRIDGITS ROAD) AND NNEBISI ROAD TO EZENEI AVENUE TO TRAFFIC LIGHT, ASABA.

ZONE 29:

FROM TRAFFIC LIGHT TO LEO OKONWEZE STREET TO FEDERAL COLLEGE BY NNEBISI ROAD, ASABA.

ZONE 30:

IBUSA JUNCTION BY NNEBISI TO STOP- OVER JUNCTION THROUGH IDUMUGBE TO ST. BRIDGIT’S ROAD BACK TO OGBEOGONOGO, ASABA.

ZONE 31:

FROM GOVT. HOUSE ROAD TO INTER-BAU TO GOVT HOUSE GATE BY ANWAI ROAD, ASABA.

ZONE 32:

FROM OBIDIMA OKONNE BY AGRIC CO-OPERATIVE HOUSE TO CABINET OFFICE ROAD TO GOVT HOSPITAL FENCE, BY GEORGE UWECHUE STREET THROUGH OPENE DRIVE BY RIGHT TO PRINCE IYEKE IKECHUKWU STREET THROUGH JASMINE SCHOOL ROAD TO GOVERNMENT HOUDE FENCE, ASABA.

ZONE 33:

FROM SCHOOL OF MIDWIFERY ROAD TO OBIDIMA OKONNE STREET BY AGRIC CO-OPERATIVE HOUSE, OKPANAM ROAD, ASABA.

ZONE 34:

FROM SCHOOL OF MIDWIFERY ROAD TO OKPANAM NEW LAYOUT BY THE RIGHT DOWN TO EZE OBI UJUKWU STREET, OPPOSITE MARBLE HILL, ASABA.

ZONE 35:

FROM SCHOOL OF MIDWIFERY ROAD TO OKPANAM NEW LAYOUT BY THE LEFT TO THE EXPRESS, ASABA

ZONE 36:

FROM HEAD BRIDGE TO OKWE BY POLICE COMMISSIONER’S QUARTERS ROAD, ASABA

ZONE 37:

FROM FEAR GOD STREET TO FORMER MINISTRY OF TRANSPORT ROAD, ASABA.


ZONE 38:

FROM FORMER MINISTRY OF TRANSPORT ROAD TO IBUSA ROAD BY THE EXPRESS, ASABA

ZONE 39:

FROM DESTINY HOTEL ROAD BY SMART IDIOMA ROAD TO PRINCE ANISHA STREET BY THE RIGHT TO AIRPORT ON BENIN/ASABA EXPRESSWAY, ASABA.

ZONE 40:

EAGLE STREET TO THE LEFT, OKWE TO THE RIGHT, ASABA

ZONE 41:

MEDICAL WASTE COLLECTION AND DISPOSAL.

WARRI ZONING/DELINEATON FOR REFUSE COLLECTION AND DISPOSAL

ZONE 1:

SHELL RAMP BY LEFT TO MCDERMONT JUNCTION, MCDERMONT TO THE LEFT TO MOROGUN STREET, MOROGUN ON THE LEFT TO THE RIVER, WARRI.

ZONE 2:

FROM MOROGUN BY THE RIGHT TO THE RIVER MOROGUN JUNCTION DOWN TO IYARA JUNCTION TO THE LEFT TO THE END OF CEMETRY ROAD BY LEFT, WARRI.

ZONE 3:

FROM MCDERMONT BY THE RIGHT TO MOROGUN JUNCTION, TURN RIGHT HAND SIDE THROUGH IYARA STREET TO IYARA JUNCTION BACK TO CEMETRY JUNCTION ON THE RIGHT BACK TO MCDERMONT JUNCTION STILL ON THE RIGHT, WARRI.


ZONE 4:

FROM CEMETRY JUNCTION BY RIGHT TO ODION ROUNDABOUT BY THE RIGHT THROUGH ODION ROAD BY THE RIGHT THROUGH BOWEN AVENUE JUNCTION IN WARRI/SAPELE ROAD TURN RIGHT TO CEMETRY JUNCTION, WARRI.

ZONE 5:

FROM ODION ROUNDABOUT THROUGH THE LEFT DOWN TO BOWEN AVENUE ON THE LEFT TO BOWEN AVENUE JUNCTION ALONG WARRI/SAPELE ROAD TO OLD PORT (EXCLUDING THE MARKET) AS TERMINATION POINT, WARRI

ZONE 6:

FROM MRS PETROL STATION 1ST , 2ND, AND 3RD MARINE GATES TO DECO JUNCTION TO THE RIGHT TO ETUWEWE RIGHT TO LINK 1ST MARINE TURN LEFT, ALL AREA ON RIGHT THROUGH IFIOGHO STREET BACK TO 3RD MARINE GATE, WARRI.

ZONE 7:

FROM ETUWEWE ON THE LEFT TO 1ST MARINE GATE ON LEFT, STOP AT THE END OF THE ROAD, ETUWEWEN JUNCTION BY DECO ROAD BY RIGHT TO EMEBIREN BY THE RIGHT TO MEET THE SWAMP AS TERMINATION POINT, WARRI.

ZONE 8:

FROM EMEBIREN JUNCTION ON THE LEFT SIDE TO SWAMP OKUMAGBA AVENUE AND FROM EMEBIREN JUNCTION TO RIGHT TO EJEMUDARHO TO THE RIGHT, WARRI.

ZONE 9:

FROM EJEMUDARHO JUNCTION BY THE LEFT, EJEMUDARHO TO ESTATE ROUNDABOUT ON THE RIGHT THROUGH UGBOROKOKO ROAD TO THE RIGHT TO SWAMP, WARRI.


ZONE 10:

FROM UGBERIKOKO JUNCTION THROUGH UGBERIKOKO ROAD ON THE LEFT TO ARUBAYI STREET JUNCTION, FROM ARUBAYI STREET JUNCTION, THROUGH ARUBAYI STREET TO GIWA AMU JUNCTION, FROM GIWA AMU JUNCTION, FROM GIWA AMU TO OKUMAGBA AVENUE (TOTAL FILLING STATION), TURN RIGHT BACK TO UGBORIKOKO JUNCTION BY THE ESTATE ROUNDABOUT ALL ON THE RIGHT, WARRI.

ZONE 11:

FROM DECO JUNCTION BY THE LEFT THROUGH DECO ROAD, STOP AT EBURU JUNCTION. EBURU TO THE LEFT TO EBOH ROAD TURN LEFT TO UPPER EREJUWA TURN LEFT TO GARAGE, TURN LEFT BACK TO DECO JUNCTION EXCLUDING IGBUDU MARKET, WARRI.

ZONE 12:

FROM EBURU JUNCTION BY RIGHT TO EBOH ROAD TURN LEFT ALONG THE EBOH ROAD, TO LINK (RIGHT) UPPER EREJUWA TURN RIGHT TO OKERE ROAD TO LINK OKUMAGBA ESTATE ROUNDABOUT (ALL RIGHT) TURN TO EBOH JUNCTION AS TERMINATION POINT, WARRI.

ZONE 13:

FROM LOWER EREJUWA JUNCTION BY LEFT TO OMETAN ROAD TURN LEFT STRAIGHT TO OKERE ROAD THROUGH GIWA (ALL LEFT SIDE). FROM OKERE ROAD BY GIWA JUNCTION TURN LEFT TO OKERE JUNCTION, TURN LEFT TO LOWER EREJUWA JUNCTION (BY GARAGE) ALL LEFT, WARRI.

ZONE 14:

FROM OMETAN JUNCTION TO OKERE ROAD THROUGH GIWA ALL RIGHT TURN RIGHT ALONG OKERE ROAD TO UPPER EREJUWA TURN TO THE JUNCTION RIGHT TO OMETAN ROAD JUNCTION ALL RIGHT, WARRI.

ZONE 15:

FROM OKERE JUNCTION ALONG THE WARRI/SAPELE ROAD TO ESISI ROAD JUNCTION TURN RIGHT ALONG ESISI ROAD LINK OKERE ROAD TURN RIGHT BACK TO OKERE JUNCTION, WARRI.

ZONE 16:


FROM ESISI JUNCTION ALONG WARRI WARRI/SAPELE TO SWAMP, ALL AREAS BY THE RIGHT OF MABIAKU TO AJAMIMOGHA LINK ROAD TO AJAMIMOGHA ROAD, TURN RIGHT TO ESISI ROAD JUNCTION (BY THE ROUNDABOUT) TURN RIGHT BACK TO ESISI JUNCTION BY WARRI/SAPELE ROAD, WARRI.

ZONE 17:

FROM AJAMIMOGHA LINK ROAD JUNCTION (BY AJAMIMOGHA ROAD TO OLU PALACE JUNCTION BY THE LEFT TO LINK NPA BYE-PASS TURN LEFT TO THE RIVER ALL LEFT, WARRI.

ZONE 18:

FROM OLU PALACE JUNCTION TO THE NPA BYE-PASS (RIGHT) TURN RIGHT TO NEW PORT ALONG THE NPA EXPRESSWAY TO THE FLY-OVER TURN RIGHT BACK TO OLU PALACE JUNCTION ALL RIGHT, WARRI.

ZONE 19:

FROM AJAMIMOGHA JUNCTION (OKERE MARKET) THROUGH AJAMIMOGHA ROAD ON THE RIGHT TO ANGLE PARK JUNCTION TURN RIGHT ALONG AIRPORT ROAD TO ANGLE PARK JUNCTION, TURN RIGHT ALONG AIRPORT ROAD OKUMABGA AVENUE JUNCTION (BY TOTAL FILLING STATION), TURN RIGHT TO ESTATE BACK TO AJAMIMOGHA JUNCTION (OKERE MARKET), WARRI.

ZONE 20:

FROM ANGLE PARK, TURN RIGHT TO LONDON OPI JUNCTION RIGHT TO THE SWAMP. ALL AREA FROM ANGLE PARK ALONG AIRPORT ON LEFT TO EDJEGBA JUNCTION AS TERMINATION POINT, WARRI.

ZONE 21:

FROM LONDON OPI STREET TO THE LEFT DOWN TO THE SWAMP. BACK TO THE JUNCTION AND ALL AREAS TO THE RIGHT DOWN TO THE FLY-OVER BY FGC AS TERMINATION POINT, WARRI.

ZONE 22:

ALL AREAS STARTING FROM UGBUWANGUE JUNCTION BY THE LEFT TO END AT UGBUWANGUE ROAD EXCLUDING THE MARKET, WARRI.

ZONE 23:


ALL AREAS STARTING FROM UGBUWANGUE JUNCTION BY THE LEFT HAND SIDE TO THE END OF THE STREET INCLUDING ALL AREAS COVERING OGUNU EXCLUDING SHELL, WARRI.

ZONE 24:

FROM NIGERIA GAS GOING TO UBEJI ALL RIGHT TO DEEPER LIFE JUNCTION, WARRI.

ZONE 25:

FROM NIGERIA GAS GOING TO UBEJI ALL LEFT TO DEEPER LIFE ROAD, ALL LEFT TO TERMINATE AT SETRACO YARD, WARRI

ZONE 26:

FROM DEEPER LIFE JUNCTION GOING TO EGBOKODO ITSEKIRI ALL RIGHT TO TERMINATE AT THE EGBOKODO RIVER, WARRI.

ZONE 27:

FROM DEEPER LIFE JUNCTION GOING TO EGBOKODO ITSEKIRI ALL LEFT, DEEPER LIFE ROAD ALL RIGHT TO TERMINATE AT THE EGBOKODO ITSEKIRI, WARRI.

ZONE 28:

SCHOOL OF NURSING FENCE THROUGH SHELL GATE, THROUGH EDJEBA ROAD TO THE EXPRESS (ALL LEFT), WARRI

ZONE 29:

FROM SCHOOL OF NURSING THROUGH SHELL GATE, THROUGH EDJEBA ROAD TO NPA EXPRESSWAY (ALL RIGHT), WARRI.

ZONE 30:

EJEMUDARO-LOSY-ARUJOVWE-ONOFEGHARA-POLOKO SWAMP (ALL LEFT), WARRI.

ZONE 31:

MEDICAL WASTE ACROSS WARRI.


UVWIE ZONING/DELINEATON FOR REFUSE COLLECTION AND DISPOSAL

ZONE 1:

FROM OKORODUDU LEFT SIDE ALONG ENERHEN ROAD, DOWN TO MOTEL TO THE RIVER INCLUDING SEDECO IN THE LEFT HAND UP TO UDU BRIDGE, UVWIE.

ZONE 2:

FROM OKORODUDU MOTORS RIGHT HAND SIDE ALONG ENERHEN ROAD TO ENERHEN JUNCTION TO WARRI/SAPELE ROAD RIGHT HAND SIDE, BACK TO OKORODUDU MOTOR JUNCTION, UVWIE.

ZONE 3:


FROM SHELL RAMP ON WARRI/SAPELE ROAD TO ENERHEN JUNCTION ON THE RIGHT HAND SIDE TO KOLOKOLO ON THE RIGHT INCLUDING EDEWOR ESTATE, ESCO SUPER STORE DOWN TO GKM BY THE UDU BRIDGE, UVWIE.

ZONE 4:

FROM ALEGBO JUNCTION ON THE RIGHT HAND SIDE ALONG ALEGBO ROAD DOWN TO DSC EXPRESSWAY, FROM ALEGBO JUNCTION ON YOUR LEFT HANDSIDE ALONG ALEGBO ROAD DOWN TO DSC EXPRESSWAY BACK TO UTI STREET JUNCTION BY DSC EXPRESSWAY, AGOFURE MOTOR PARK, UVWIE.

ZONE 5:

FROM AIRPORT JUNCTION ON THE RIGHT HANDSIDE TO WATER RESOURCES JUNCTION THROUGH WATER RESOURCES ROAD TO IZAKPA JUNCTION BACK TO AIRPORT ROAD ON THE RIGHT TO AIRPORT JUNCTION, UWVIE.

ZONE 6:

FROM WATER RESOURCES ON WARRI/SAPELE ROAD ON THE RIGHT HANDSIDE TO OPPOSITE SHELL RAMP ON THE RIGHT HANDSIDE INCLUDING OIL FIELD ROAD LEFT AND RIGHT ON THE RIGHT INCLUDING ODIBO ESTATE, UVWIE.

ZONE 7:

FROM IZAKPA JUNCTION ON AIRPORT ROAD LEFT HANDSIDE TO SG JONES COMPANY INCLUDING UGBERIKOKO TOWN AND ITS ENVIRONS, UVWIE.

ZONE 8:

FROM AIRPORT JUNCTION ON THE RIGHT HANDSIDE TO DDPA JUNCTION, FROM THE JUNCTION TO THE RIVER ON THE RIGHT HANDSIDE, THEN SOKOH ESTATE ROAD THROUGH EGBE LAYOUT ON THE LEFT HANDSIDE TO THE RIVER, UVWIE.

ZONE 9:

FROM DDPA ROAD JUNCTION ON THE LEFT HANDSIDE TO DDPA TO THE RIVER FROM DDPA JUNCTION ON THE RIGHT HANDSIDE TO UGBOROKE LINK ROAD, INCLUDING TOWN DOWN TO EKPAN BRIDGE BY NNPC HOUSING ESTATE, UVWIE.

ZONE 10:


FROM JAKPA JUNCTION ON THE LEFT HANDSIDE ON JAKPA ROAD TO EZAVWA STREAM TO JOIN EGBE ROAD TO OKUBO ROAD ON THE LEFT FROM LEFT, FROM OKUBU ROAD TO JAKPA JUNCTION ON THE LEFT, UVWIE.

ZONE 11:

FROM JAKPA JUNCTION ON THE RIGHT HANDSIDE TO AKA AVENUE JUNCTION AND FROM THE RIGHT HANDSIDE OF AKA AVENUE TO REFINERY ROAD ON THE RIGHT TO REFINERY JUNCTION ON THE RIGHT BACK TO JAKPA JUNCTION, UVWIE

ZONE 12:

FROM AKA AVENUE JUNCTION ALONG JAKPA JUNCTION ON THE RIGHT TO EJOYOKA STREET JUNCTION ON THE RIGHT TO REFINERY ROAD NEAR CASA DE PEDRO ANNEX TO REFINERY ROAD TO AKA AVENUE ON THE RIGHT BACK TO AKA AVENUE JUNCTION ON JAKPA ROAD, UVWIE.

ZONE 13:

FROM EZAVWA STREAM ON THE LEFT OF JAKPA ROAD TO WHITE HOUSE JUNCTION ALONG JAKPA ROAD TO THE RIVER (EGBE ROAD AS BOUNDARY), UVWIE.

ZONE 14:

FROM EJOYOKA STREET JUNCTION TO MANSAL HOTEL JUNCTION ON THE RIGHT OF JAKPA ROAD, FROM MANSAL HOTEL JUNCTION TO REFINERY ROAD ON THE RIGHT HANDSIDE TO CIC COLD ROOM, UVWIE.

ZONE 15:

FROM WHITE HOUSE JUNCTION ON THE LEFT OF JAKPA ROAD TO SHOPPING COMPLEX AFTER GRAY MESSAGE ON THE LEFT TO THE RIVER AS BOUNDARY, UVWIE.

ZONE 16:

FROM NEW LAYOUT JUNCTION ON THE LEFT HANDSIDE ON JAKPA ROAD TO EKPAN JUNCTION ON THE LEFT, FROM EKPAN JUNCTION TO HOUSING COMPLEX BRIDGE ON THE LEFT, UVWIE.

ZONE 17:


FROM REGAL CLINIC ON THE RIGHT OF JAKPA ROAD TO EKPAN JUNCTION TO POLICE STATION ROAD ON THE RIGHT DOWN TO REFINERY ROAD TO OPPOSITE ARMY BARRACK LINK ROAD JUNCTION AS BOUNDARY, UVWIE.

ZONE 18:

FROM NIGER CAT ON THE RIGHT HANDSIDE ON THE EXPRESS TO CHEVRON AS BOUNDARY INCLUDING NIGER CAT LAYOUT, UVWIE.

ZONE 19:

FROM NIGER CAT ON THE LEFT HANDSIDE OF THE EXPRESS DOWN TO UMAH VILLAGE INCLUDING NNPC HOUSING COMPLEX AND EKPAN TOWN (EXCLUDING THE MARKET) TERMINATING AT THE BRIDGE ON THE RIGHT HANDSIDE INCLUDING THE EKPAN POLICE STATION, UVWIE.

ZONE 20:

FROM CONOIL PETROL STATION TO JAKPA JUNCTION ON THE RIGHT TO THE RIVER (EXCLUDING THE EFFURUN MARKET) PTI ROAD ON THE ROAD TO ALEGBO ROAD ON THE RIGHT TO UGBOLOKPOSO MARKET ON THE RIGHT TO THE EXPRESS TO THE RIVER, UVWIE.

ZONE 21:

FROM ALEGBO JUNCTION ON THE LEFT TO THE EXPRESS ON THE LEFT TO DSC ROUNDABOUT ON THE LEFT TO WOODBRIDGE HOTEL TO PTI ROAD JUNCTION ON THE LEFT TO AGOFURE MOTORS ON THE LEFT BACK TO ALEGBO JUNCTION, UVWIE.

ZONE 22:

FROM UGBOLOKPOSO BRIDGE TO DSC ROUNDABOUT RIGHT HANDSIDE TERMINATING AT ITERIGBI, FROM DSC ROUNDABOUT ON THE RIGHT HANDSIDE TO EFFURUN ROUNDABOUT RIGHT SIDE, FROM EFFURUN ROUNDABOUT TO OHORE 1 &2 LEFT AND RIGHT HANDSIDES, UVWIE.

ZONE 23:

FROM JAKPA JUNCTION RIGHT HANDSIDE UP TO ROUNDABOUT, FROM ROUNDABOUT RIGHT HANDSIDE TO PTI ROAD JUNCTION, FROM PTI ROAD JUNCTION RIGHT HANDSIDE BACK TO JUNCTION (THE MARKET AREA IS EXCLUDED FROM THIS ZONE), UVWIE.

ZONE 24:


MEDICAL WASTE ACROSS UVWIE

UDU ZONING/DELINEATON FOR REFUSE COLLECTION AND DISPOSAL

ZONE 1:

ALL AREAS STARTING FROM UDU BRIDGE (HARBOUR MARKET) RIGHT HAND SIDE DOWN TO EMMEDJOR STREET JUNCTION RIGHT BY ORHUWHORUN ROUUDABOUT DOWN TO EMEDJOR STREET JUNCTION BY OVWIAN ROAD RIGHT HAND SIDE AND TERMINATES AT ALAWURU UPSTAIR, OPPOSITE OVWIAN PRIMARY SCHOOL, EXCLUDING JIGBALE, UDU AND HARBOUR MARKET, UDU

ZONE 2:


ALL AREAS STARTING FROM EMEDJOR STREET JUNCTION LEFT HAND SIDE BY OVWIAN ROAD DOWN TO OVWIAN ROAD DOWN TO OVWIAN ROAD JUNCTION ALONG UDU ROAD, OPPOSITE NNPC FILLING STATION LEFT HANDSIDE DOWN TO EMEDJOR STREET JUNCTION BY ORHUWHORUN ROUNDABOUT BACK TO EMEDJOR STREET JUNCTION LEFT HANDSIDE BY OVWIAN ROAD, UDU.

ZONE 3:

ALL AREAS STARTING FROM ALAWURU UPSTAIRS, OPPOSITE OVWIAN PRIMARY SCHOOL BY THE RIVER, RIGHT HAND SIDE, DOWN TO NBTC JUNCTION BY EXPRESSWAY AS TERMINATION POINT EXCLUDING NBTC, UDU

ZONE 4:

ALL AREAS STARTING FROM OVWIAN ROAD JUNCTION BY CONOIL FILLING STATION, UDU ROAD RIGHT HAND SIDE DOWN TO EXPRESSWAY JUNCTION BY ORUGBO PLAZA TURN RIGHT HANDSIDE TO IZOMO ROAD JUNCTION BY EXPRESSWAY, TURN RIGHT HANDSIDE TO UPSTAIRS BUILDING BY ODJANIGBEKI ROAD JUNCTION OVWIAN ROAD TURN RIGHT HANDSIDE DOWN TO OVWIAN ROAD JUNCTION BY CONOIL, UDU.

ZONE 5:

ALL AREAS STARTING FROM IZOMO ROAD JUNCTION BY EXPRESSWAY, LEFT HANDSIDE TO UPSTAIR BUILDING BY ODJANIGBEKI ROAD JUNCTION LEFT HAND SIDE TO MATERNITY ROAD JUNCTION BY OVWIAN ROAD, TURN LEFT HANDSIDE TO NBTC JUNCTION BY EXPRESSWAY AS TERMINATING POINT, UDU

ZONE 6:

ALL AREAS STARTING FROM UDU ROAD BRIDGE (SAWMILL) LEFT HANDSIDE DOWN TO ORHUWHORUN ROUNDABOUT, TURN LEFT HAND SIDE ALONG ORHUWHORUN ROAD TO BORO STREET JUNCTION LEFT HANDSIDE TO BORO STREET BY OWHASE ROAD (OPPOSITE THE TRANSFORMER), TURN LEFT HANDSIDE DOWN TO OWHASE RIVER AS TERMINATING POINT EXCLUDING DADDY FASTFOOD, UDU.

ZONE 7:

ALL AREAS STARTING FROM BORO STREET JUNCTION BY ORHUWHORUN ROAD, TURN RIGHT HANDSIDE TO BORO STREET JUNCTION BY OWHASE ROAD (OPPOSITE THE TRANSFORMER), TURN RIGHT HANDSIDE DOWN TO OWHASE


RIVER. BACK TO BORO STREET BY ORHUWHORUN ROAD LEFT HANDSIDE TO KOTOKOTO ROAD JUNCTION OPPOSITE BEELAND HOTEL, TURN LEFT HANDSIDE TO DIVINE CHURCH ROAD BY THE LEFT HANDSIDE TO THE SWAMP, UDU.

ZONE 8:

ALL AREAS STARTING FROM KOTOKOTO ROAD JUNCTION BY ORHUWHORUN ROAD OPPOSITE BEELAND HOTEL TURN RIGHT HANDSIDE STRAIGHT TO THE SWAMP. BACK TO KOTOKOTO ROAD JUNCTION BY ORHUWHORUN ROAD OPPOSITE BEELAND LEFT HANDSIDE TO IGBOGIDI RIVER BY EXPRESSWAY, UDU.

ZONE 9:

ALL AREAS STARTING FROM ORHUWHORUN ROUNDABOUT RIGHT HANDSIDE ALONG ORHUWHORUN ROAD TO GHAVWAN STREET JUNCTION, TURN RIGHT HAND SIDE TO GHAVWAN/OLD EKETE ROAD JUNCTION, TURN RIGHT HANDSIDE TO OLD EKETE ROAD BY NNPC FILLING STATION, UDU ROAD, TURN RIGHT HAND SIDE TO ORHUWHORUN ROUNDABOUT AS TERMINATION POINT EXCLUDING SIZZLERS FASTFOOD, KWOFIA CLINIC, AND WETLAND, UDU.

ZONE 10:

ALL AREAS STARTING FROM GHAVWIAN STREET JUNCTION BY ORHUWHORUN ROAD RIGHT HANDSIDE TO THE EXPRESSWAY JUNCTION BY TRAILER PARK TURN RIGHT HANDSIDE TO OLD EKETE ROAD JUNCTION BY EXPRESSWAY (ISELEKEMES FILLING STATION), TURN RIGHT HANDSIDE ALONG OLD EKETE TO GHAVWAN STREET JUNCTION BY ORHUWHORUN ROAD AS TERMINATING POINT EXCLUDING BEELAND HOTEL, UDU.

ZONE 11:

ALL AREAS STARTING FROM OLD EKETE ROAD JUNCTION BY UDU ROAD, OPPOSITE CONOIL FILLING STATION LEFT HANDSIDE TO EXPRESSWAY JUNCTION BY ENERHEN JUNCTION TAXI PARK, TURN LEFT HANDSIDE TO OLD EKETE ROAD BY ISELEKEMES FILLING STATION, TURN LEFT HANDSIDE ALONG OLD EKETE ROAD TO STARTING POINT, THEN TO OLD EKETE ROAD JUNCTION BY UDU ROAD OPPOSITE CONOIL FILLING STATION, UDU.

ZONE 12:


ALL AREAS STARTING FROM MOFOR (EMU BAKERIES SIDE) TO POLICE POST , OPUTU ESTATE FENCE THROUGH BRUME ESTATE FENCE TO CAMP EXTENTION FENCE THROUGH THE FENCE TO EGINI DRIVE, OPPOSITE POLICE STATION TO UFUOMA STREET RIGHT HANDSIDE DOWN TO UFUOMA STREET JUNCTION BY EXPRESSWAY TO MOFOR STARTING POINT (EMU BAKERIES), UDU.

ZONE 13:

ALL AREAS STARTING FROM UFUOMA STREET JUNCTION BY EXPRESSWAY TURN LEFT HANDSIDE TO EXPRESSWAY JUNCTION OPPOSITE MOTORS & MOTORCYLCES GARAGE TURN LEFT HANDSIDE TO FLY-OVER BY OANDO FILLING STATION UDU ROAD, TURN LEFT HANDSIDE TO OPPOSITE POLICE STATION THEN TURN LEFT HANDSIDE TO EGINI DRIVE TO UFUOMA STREET LEFT HANDSIDE TO UFUOMA STREET JUNCTION BY EXPRESSWAY AS TERMINATING POINT, UDU.

ZONE 14:

ALL AREAS STARTING FROM EXPRESSWAY JUNCTION BY MOFORS AND MOTOCYCLES GARAGE RIGHT HANDSIDE TO DELTA CLINIC AND ENVIRONS THROUGH OLD UJEVWU ROAD TO BYE-PASS ROAD (OLD UJEVWU ROAD JUNCTION), TURN LEFT HANDSIDE TO ‘T’ JUNCTION, TURN RIGHT HANDSIDE TO ETEFIA MORTUARY, ALONG THE RIGHT HANDSIDE DOWN TO STARTING POINT (EXPRESSWAY JUNCTION BY MOTOR AND MOTORCYCLES GARAGE), UDU.

ZONE 15:

ALL AREAS STARTING FROM IGBOGIDI RIVER BY EXPRESSWAY LEFT HANDSIDE TO MOFOR TURN LEFT HANDSIDE TO IGBOGIDI JUNCTION ALONG ORHUWHORUN ROAD, TURN LEFT HANDSIDE DOWN TO THE IGBOGIDI RIVER AS TERMINATING POINT, UDU.

ZONE 16:

ALL AREAS STARTING FROM IGBOGIDI JUNCTION HANDSIDE TO IGBOGIDI RIVER, BACK TO IGBOGIDI JUNCTION LEFT HANDSIDE TO KHAKI ROAD JUNCTION BY THE ORHUWHORUN MARKET THROUGH EKRESIA STREET LEFT HANDSIDE TO THE RIVER, UDU.

ZONE 17:


ALL AREAS STARTING FROM KHAKI ROAD JUNCTION BY THE MARKET THROUGH EKRESIA RIGHT HANDSIDE TO THE RIVER. BACK TO KHAKI ROAD JUNCTION BY THE MARKET LEFT HANDSIDE TO GODWILL CHURCH AND ENVIRONS, UDU.

ZONE 18:

ALL AREAS STARTING FROM USIEFURUN JUNCTION TO OWHRODE ROAD TO THE RAILWAY ROAD, TURN TO THE LEFT HANDSIDE TO USIEFURUN ROAD, TURN LEFT HAND SIDE TO USIEFURUN AS TERMINATING POINT, UDU.

ZONE 19:

ALL AREAS STARTING FROM ACROSS THE RAILWAY ODJIKPATA LAYOUT INCLUDING OWHRODE JUNCTION OPPOSITE THE FOREST DOWN TO OLD EGINI JUNCTION LEFT HANDSIDE DOWN TO THE RAILWAY, UDU.

ZONE 20:

ALL AREAS STARTING FROM THE WATER CHANNEL OPPOSITE NIRVANA HOTEL BY THE RIGHT HANDSIDE TO GOD’S GRACE CHURCH, UDU.

ZONE 21:

ALL AREAS STARTING FROM ALAKA ROAD JUNCTION BY THE ORHUWHORUN MARKET LEFT HANDSIDE TO OPPOSITE OKAKA HALL, TURN LEFT HANDSIDE TO OWHRODE ROAD JUNCTION (OPPOSITE ASATA BLOCK INDUTRY) TURN LEFT HANDSIDE TO USIEFURUN JUNCTION, TURN LEFT HAND SIDE (CATHOLIC CHURCH SIDE), DOWN TO ALAKA ROAD JUNCTION BY MARKET AS TERMINATING POINT, UDU.

ZONE 22:

ALL AREAS STARTING FROM ALAKA ROAD JUNCTION BY ORHUWHORUN MARKET TO ADANIBO JUNCTION TURN LEFT HANDSIDE TO NIRVANA HOTEL JUNCTION, TURN LEFT HANDSIDE TO OPPOSITE OKAKA HALL, TURN LEFT HANDSIDE TO THE STARTING POINT (ALAKA ROAD JUNCTION BY THE MARKET), UDU.

ZONE 23:


ALL AREAS STARTING FROM OLD EGINI ROAD JUNCTION LEFT HANDSIDE TO NIRVANA HOTEL INCLUDING OKU LAYOUT DOWN TO OLD EGINI ROAD JUNCTION NEAR OKAKA HALL AS TERMINATING POINT, UDU.

ZONE 24:

ALL AREAS STARTING FROM ADANIBO JUNCTION RIGHT HANDSIDE TO THE WATER CHANNEL BY THE RIGHT HANDSIDE LINKING TO GOD’S GRACE BEHIND TO THE END OF JOS DRIVE JUNCTION BY THE RIGHT, THROUGH THE TARRED ROAD TO THE END OF THE CHURCH ROAD TO CAC JUNCTION BY THE RIGHT SIDE TO ADANIBO JUNCTION, UDU

ZONE 25:

ALL AREAS IN SECTOR A AND MOBILE CAMP AND NEW HOUSES IN THE ENVIRONS, UDU

ZONE 26:

ALL AREAS IN SECTOR B FROM 1ST GATE BY THE RIGHT TO ABUJA ROAD BY THE RIGHT TO KANO ROAD JUNCTION TO YOBE RIVER TO ABUJA ROAD BY THE RIGHT TO LAGOS STREET TO 2ND GATE BY THE RIGHT, BACK TO 1ST GATE AND OPPOSITE OF PLAZA TO THE POWER STATION, UDU.

ZONE 27:

ALL AREAS IN SECTOR C, UDU.

ZONE 28:\ZXCZF G\

ALL AREAS IN SECTOR D AND E, UDU.

ZONE 29:

ALL AREAS IN SECTOR F, UDU.

ZONE 30:

ALL AREAS IN EXTENSION CAMP, BRUME ESTATE AND OPUTU ESTATE, UDU.

ZONE 31:

ALL AREAS FROM POLICE POST TO 1ST GATE BY THE LEFT HANDSIDE TO SECTOR F GATE BY THE LEFT HANDSIDE BACK TO POLICE POST, UDU.

ZONE 32:


- DADDY FASTFOOD, PEEBODY HOTEL, SWIZZLERS, KWOFIA CLINIC, NBTC, BEELAND HOTEL AND WETLAND BANK, UDU.

ZONE 33:

MEDICAL WASTE ACROSS UDU.

SAPELE ZONING/DELINEATON FOR REFUSE COLLECTION AND DISPOSAL

ZONE 1:


FROM ETHIOPE RIVER BRIDGE TO STC SIDE TO SAPELE/WARRI ROAD BY OKIRIGHWERE MOTOR PARK (LEFT), TO AMUKPE MARKET EXTENDING TO VITAFOAM, SIIL & EUGHUART INDUSTRIES LEFT TO THE EXPRESS ROAD, SAPELE

ZONE 2:

FROM SHELL FLOW STATION ALONG HON. OVERAH ESTATES (RIGHT) TO NEW – ROAD JUNCTION (RIGHT) TO OKIRIGHWRE INCLUDING ZENITH BANK, OBULE SCHOOLS AND OKIRIGHWER AREAS UP TO OKPE GRAMMAR SCHOOL TO POWER LINE, SAPELE.

ZONE 3:

FROM ETHIOPE RIVER BRIDGE ON KOLOKO FACTORY (RIGHT) TO SAPELE/WARRI ROAD JUNCTION, OKIRIGHWRE (RIGHT) TOLLGATE (RIGHT) TO MALACHY JUNCTION (RIGHT) UP TO CAR DEALER SHOP AFER RAIN OIL BY SMALL BRIDGE, INTO UGBEYIYI AND UP TO FGS RUBBER FACTORY AND TO THE RIVER, SAPELE.

ZONE 4:

FROM TOTAL BY NEW-OGORODE ROAD JUNCTION TO OKPE ROAD JUNCTION AT AMUOGODO (LEFT) INTO OKPE ROAD UP TO AKINTOLA ROAD JUNCTION (LEFT) UP TO NEW-OGORODE ROAD (LEFT) BACK TO TOTAL FILLING STATION, SAPELE.

ZONE 5:

FROM AKINTOLA BY OKPE ROAD JUNCTION (LEFT) UP TO ADEOLA JUNCTION (OLYMPIA) LEFT TO NEW ROAD (SAPELE CLINIC) LEFT FACING OGORODE UP TO OJOLU ROAD, LEFT INTO IRETO ROAD BACK TO NEW ROAD UP TO HON. IGBUYA HOUSE BY AKINTOLA BY NEW ROAD JUNCTION, SAPELE.

ZONE 6:

FROM AKINTOLA JUNCTION AT OKPE ROAD (UBA RIGHT) TO ADEOLA (OLYMPIA RIGHT) THROUGH CEMETRY ROAD TO OGORO WATER-SIDE (RIGHT) INCLUDING CENTRAL HOSPITAL, KOKO GARAGE, FIRST BANK AND CUSTOMS OFFICE AREA, SAPELE.

ZONE 7:


FROM OGORO WATER-SIDE (RIGHT) TO URHOBO ROAD, JUNCTION AT CEMETRY ROAD (RIGHT) TO MCPHERSON ROAD (RIGHT) TO THE WATERSIDE; INCLUDING THE SAPELE MARKET AND THE SAND-BEACH, SAPELE.

ZONE 8:

FROM URHOBO ROAD AT CEMETRY (RIGHT) TO RECLAMATION ROAD (RIGHT TO MCPHERSON ROAD) RIGHT TO URHOBO ROAD (RIGHT) TO CEMETRY ROAD, SAPELE.

ZONE 9:

FROM FLOW STATION, SHELL ROAD, OPPOSITE HON. OVERAH HOUSE (LEFT) TO NEW OGORODE ROAD JUNCTION (LEFT) UP TO AKINTOLA ROAD BY NEW-OGORODE ROAD, SAPELE.

ZONE 10:

FROM MCPHERSON ROAD (WATERSIDE) RIGHT TO IKOMI ROAD JUNCTION (RIGHT) UP TO MISSION ROAD (GOVERNMENT CEMETRY) FACING WATERSIDE (LEFT AND RIGHT) ALONG MISSION ROAD INCLUDING SCOOMEI HOTEL AS THE BOUNDARY, SAPELE.

ZONE 11:

FROM IKOMI ROAD JUNCTION/MCPHERSON ROAD, THROUGH OKOTIE-EBOH GRAMMAR SCHOOL (RIGHT), OWUMI ROAD TO NEW OGORODE (RIGHT) UP TO FLOOR MILLS. INCLUDING IKOMI ROAD (LEFT) TO MISSION ROAD (LEFT) TO NEW OGORODE ROAD, SAPELE.

ZONE 12:

FROM OJOLU ROAD JUNCTION AT NEW OGORODE ROAD, (LEFT) TO ABEKE ROAD JUNCTION (LEFT) TO GANA MARKET (LEFT) INTO URHUAKPA ROAD (BOTH SIDES) TO THE END, INCLUDING PIPELINE AREAS, SAPELE.

ZONE 13:

FROM RECLAMATION (OLYMPIA) LEFT TO MCPHERSON ROAD (LEFT) THROUGH OWUMI ROAD (LEFT) AT NEW-OGORODE ROAD, LEFT TO ADEOLA JUNCTION AT NEW-OGORODE ROAD TO OLYMPIA, SAPELE.

ZONE 14:


FROM ABEKE ROAD AT NEW-OGORODE ROAD JUNCTION (RIGHT) UP TO GANA MARKET (THE STOREY BUILDING) INCLUDING AMORC ROAD (LEFT) INCLUDING ALSO THE OLD OGORODE ROAD THROUGH NEPA SCHOOLS UP TO ZARTARC ESTATE, SAPELE.

ZONE 15:

FROM GANA MARKET (THE SPEED BREAKER) ALONG UGBERIKOKO ROAD (BOTH SIDES) UP TO OTON VILLAGE WATER-SIDE, SAPELE.

ZONE 16:

FROM OKPE ROAD JUNCTION AT AMUOGODO THROUGH SAPELE/WARRI ROAD (LEFT TO AKINTOLA ROAD) LEFT TO OKPE ROAD AND LEFT AMUOGODO, SAPELE.

ZONE 17:

FROM THE BRIDGE AT AMUOGODO -(CHRIST EMBASSY) RIGHT INCLUDING EAGLE LINE UP TO AJIMELI VILLAGE, THROUGH AT&P, ATLETIC CLUB (EXCLUDING THE KOKO GARAGE) TO THE WAREHOUSE OPPOSITE FIRST BANK UP TO LONESTAR ON THE RIVER, SAPELE.

ZONE 18:

FROM LUKSON PETROL STATION (OKPE GRAMMAR SCHOOL) RIGHT ALONG THE SAPELE/WARRI ROAD TO AMUKPE (RIGHT) THROUGH IGBEKU, OKUOVWORI, MOVIG TABLE WATER FACTORY (RIGHT) T0 THE BENIN/WARRI EXPRESSWAY, SAPELE.

ZONE 19:

NEPA GENERATION, OGORODE, ASCA JETTY AND ASCA RINGARDERS, SAPELE.

ZONE 20:

MEDICAL WASTE ACROSS SAPELE.


UGHELLI ZONING/DELINEATON FOR REFUSE COLLECTION AND DISPOSAL

ZONE 1:

IGHAGBOMI, EVUETA, UP-AGBARHO, MAKOLOMI, ONOHARIGHO, EXTENTION, ODUOPHORI, NEW MARKET, UGHELLI.

ZONE 2:

FROM ULOHO AVENUE, IKPRUKPRU EXTENTION, DORTIE, OKIKI, OGODO, UGHELLI.

ZONE 3:

FROM OTERI, OHARISI, POST OFFICE ROAD, OLOTU, OTOR-IWHREKO, ESEDJERE, OLORI, SAM-OTERI, UGHELLI.

ZONE 4:

FROM OMOTOR, EGOR, EKUERHARE, OSIA, AROMANA, TEMILE, ST. THERESA, UGHELLI.

ZONE 5:

FROM OGBERODE, ATIKU, OGBEADJARHO, ACHOJA, OGBEREKI, OSERI, ONIRIGHO, IMOHWE, ATAVERHE, ONOSODE, OLD ERUEMUKOHWARIEN ROAD, UGHELLI.

ZONE 6:

FROM OKORODAFE, OTUVWIEVWIERE, AFIESERE ROAD, ORUBU, ALELUYA, ABAROVWE, ADONOVWE, EDOGE, UGHELLI.

ZONE 7:

FROM ADAGHARAGBA, OJOKO, 1ST AMEKPA, 2ND AMEKPA, EMUJUBUTO, EMUBAROVWE, OGHENEVWETA, UGHELLI.

ZONE 8:

FROM AKPODIETE, CEMETRY, EZENWU, EKUNUGBE, EKPETUKU, OGHENEBRORHIEN, AHORON, EKROBOGAN, UGHELLI.

ZONE 9:


FROM ARHO, OLORI, OKPOJIKO, UDUERE, KOGBODI, LOW COST, ESADJERE ESTATE, UGHELL.

ZONE 10:

FROM UPPER-AFIESERE, IMONIYAME, OVETO, AWOBI, IDIARISURE, OKEMU, LADY AKPOGUMA, UGHELLI.

ZONE 11:

- FROM OMOBA, AKPONANA, KES COLLEGE, SEEGO, UGHELLI.

ZONE 12:

MEDICAL WASTE ACROSS UGHELLI.
