Cadre de gestion environnementale et sociale du PRAO Sénégal

Project background and objective

In order to strengthen the achievements of their partnership in the fisheries sector, the Government of Senegal, the World Bank and the Sub-Regional Fisheries Commission (CSRP) are preparing the second phase of the Regional Fisheries Project in West Africa (PRAO-Senegal).

The objective of PRAO-Senegal / Phase II is to improve the management of the targeted fisheries, increase the post-harvest value of fish products in targeted landing sites, and strengthen an environment conducive to aquaculture development.

PRAO-Senegal / Phase II is articulated around these three technical components:

  • Component 1: Improved management of selected fisheries
  • Component 2: Improved processing of fish and fish products
  • Component 4: Project Management, Monitoring and Evaluation, and Communication

The implementation of the proposed activities is expected to generate a range of benefits for the country in general and for the fisheries sector in particular, but this implementation could result in potential negative environmental and social impacts that must be identified, analyzed and addressed starting from the project preparation phase.

In order to minimize these potential adverse effects, the development of this Environmental and Social Management Framework (ESMF) has been requested. At this stage of the project, it is a scoping document because all the activities planned in the project have not been identified definitely and fully, and the intervention sites are not yet identified in a precise and definitive way.

Major environmental and social challenges and risks in the potential implementation areas

The coastal erosion challenge

The area of ​​intervention of the PRAO (1 and 2) includes the regions of Dakar, Saint-Louis, Thies and Ziguinchor.

The Senegalese coastline is particularly vulnerable to the impacts of climate change (PANA, 2006 ; Etude économique et spatiale de la vulnérabilité et de l’adaptation des zones côtières aux changements climatiques au Sénégal, Synthèse finale, Banque Mondiale, 2013). By 2080, due to sea-level rise, 75% of the coastline will be at risk of erosion, compared to 25% today (World Bank, 2013).  The risk of flooding during storm season is already high, as it concerns more than 50% of the coastline. By 2080, this risk is expected to affect two-thirds of the coastline (World Bank, 2013).

Today, with the current floods, the lowest areas are flooded, 37% of urban areas and 17% of the areas of equipment and infrastructure are affected.  By 2030, the size of flooded ​​degraded areas will increase: 53% of the urban areas will be flooded, as well as 32% of the other areas. It is worth noting that this situation of vulnerability is severely aggravated by human activity. Hence the need to take action in favor of the sustainable development of this important area.

Environmental and social challenges and risks in potential areas of intervention

  • Streamlining the exploitation of fishing resources
  • Fighting against the sea-level rise and protecting erosion sites
  • Fighting against the anarchic occupation of the maritime public territory 
  • Protecting mangroves in coastal areas;
  • Improving the sanitary quality and value of fish products;
  • Managing the hygiene of fisheries
  • Preserving Community Marine Protected Areas;
  • Integrating restrictions of access to the sea and loss of income
  • Physical and economic displacement not duly dealt with leading to further impoverishment
  • Capacity building and stakeholder participation in the sustainable management of fisheries resources and the preservation of the environment;

National legal and institutional framework for environmental and social assessments and World Bank Safeguards Policies whose requirements are met by the ESMF 

The objectives of the project align perfectly with the orientations of the Republic of Senegal, stated in various documents of policies and strategies for economic and social development: the Plan Senegal Emergent (PSE); the National Strategy for Economic and Social Development (SNDES 2013-2017, Act III of Decentralization, the Letter of Sector Policy for Fisheries and Aquaculture, LPSDPA); the Maritime Fisheries Code (Law No. 2015-18 of 13 July 2015); the Municipal Development Plans and local plans for developing local authorities in the project area. The country has different environmental strategies and policies that the program must comply with: the National Action Plan for the Environment (PNAE); the National Action Program Against Desertification (PAN/LCD); the strategy and action plan for the conservation of biodiversity; the National Plan for Adaptation to Climate Change (PNACC); the National Adaptation Plan for the Fisheries and Aquaculture Sector (NAP-Fisheries) in the face of Climate Change Horizon 2035; the Forest Action Plan of Senegal, etc. At the legislative and regulatory level, several texts provide for the environmental and social aspects including management of the environment, pollution and nuisances, natural resources (fauna, flora, water), the ESIA procedure, land tenure. The PRAO II must comply with the provisions of these texts. 

The World Bank environmental and social safeguard policies triggered by the project: OP 4.01 "Environmental Assessment"; OP 4.04 "Natural Habitats"; OP 4.11 Physical Cultural Resources; and OP 4.12 "Involuntary Resettlement" . Other World Bank safeguard policies are not triggered by the project.

At the institutional level, the environmental policy is led by the Ministry of the Environment and Sustainable Development (in particular, the Department of the Environment and Classified Institutions). Other stakeholders are involved in the environmental and social management of the PRAO II : the Project Coordination Unit (UCP), the Department of Maritime Fisheries, the Directorate of Marine Protected Areas (DMPC), the Directorate of Labor, Community fisheries organized around Local Fishermen's Committees (CLP) and Local Artisanal Fisheries Councils (CLPA), etc. In view of the environmental and social requirements for the management of resources and fishing infrastructures, it is necessary to strengthen the capacities of the main stakeholders of the sector in the management of environmental and social measures (training, management and monitoring tool, etc.).

General impacts/risks by sub-project type

Potential positive impacts of the ZIRA, ZPP and development and co-management plans of the volutes fishery

The project aims to sustainably improve the management and conservation of the country's fishing resources by involving all stakeholders (administration, technical services, local authorities, private sector, civil society, communities and populations). The project, through an inclusive approach, will combine the requirements of resource protection and conservation with those of improving the income of relevant communities and stakeholders, by implementing a major capacity-building program, enforcing good management practices and responsible governance, adopting ecosystem conservation and monitoring measures, restoring biological productivity, improving biodiversity, and using fishing resources in a sustainable way that ensures more added value.

Potential adverse environmental and social impacts / risks of ZIRA, ZPP, local co-management initiatives and management plans of the volutes fishery

  • Restriction of access to fisheries resources and livelihoods of fisheries actors;
  • Risks of social conflicts related to non-compliance with sustainable management measures of artisanal fisheries;

Risks of conflict and disintegration of the social consensus around management measures in the event of non-support to groups of actors (beach purse seiners, paddle boats, divers, etc.) whose fishing activities are affected by the fishing plan. management of the ZPP Petite Côte;

  • Risks of social conflicts in case of discrimination in the access authorizations to the buffer zone of the ZIRA of Yenne;
  • Risks of disproportionate negative impacts stemming from co-management initiatives on women and other vulnerable stakeholders in the fisheries sector;
  • Risks of tensions and clashes related to the lack of codification of participatory surveillance;
  • Risk of overexploitation of fishery resources in areas authorized for fishing and in case of rehabilitation of resources-compliance with management measures
  • Risk of pollution and seabed disturbance when using unsuitable types of artificial reefs
  • Risk of over-frequentation (birth and / or increased conflict) in the vicinity of Protected Community Marine Areas

Potential positive impacts of infrastructures (fishing docks, artisanal processing sites, fisheries control posts, etc.):

During the construction phase

  • Jobs for local populations

During the operational phase

  • Protection of marine and coastal resources and the environment;
  • Improvement of fishing conditions, conservation, processing and processing of fish products
  • Improvement of livelihoods in targeted fishing villages;
  • Improvement of livelihoods of vulnerable groups, including women, in targeted fishing villages;
  • Enhancement of transparency, governance and participatory processes linked to infrastructure management;
  • Development and competitiveness of the sector.

Potential adverse environmental and social impacts/risks of the infrastructures

Although this is a small-scale development, carrying out these activities could have different negative effects on the marine and coastal environment. The installation of construction sites, the clearing of the rights of way and the constructions will require the clearing of the vegetation cover and could also create various conflicts and possible nuisances.

In addition, infrastructure construction or rehabilitation may also cause physical and economic displacement of populations with the correlated negative impacts linked to this type of activities.  

During the construction phase

  • Risks of conflicts between entrepreneurs and local populations in case of non-use of the local workforce in the construction of infrastructure and demotivation of actors in the community monitoring of structures;
  • Degradation of the terrestrial habitat, deforestation and biodiversity loss
  • Pollution of air, soil, and water
  • Degradation of the aquatic habitat and seabed
  • Health and safety risks for workers and local populations
  • Gender based violence impacting women, girls and boys           
  • Disruption of socio-economic activities and risks of social and land conflicts

During the operational phase:

  • Pollution by used oils from the repair and maintenance of artisanal canoes;
  • Solid waste pollution from fish conservation and processing in fishing wharves and artisanal processing sites;
  • Marine pollution by wastewater discharges from wharves in the absence of a functional purification system;
  • Lack of environmental and sanitary hygiene related to lack of drinking water and lack of sanitation; etc.
  • Limited access to infrastructure and infrastructure provided services for disadvantaged groups within the community, including women, the elderly, and people living with HIV-AIDS;
  • Poor management skills and lack of transparency resulting in the quick deterioration of infrastructures

 

Potential positive impacts of alternative livelihood activities to fisheries

  • Diversification of income sources for fishing families and economic activities of fishing communities
  • Increased livelihoods of fishing families
  • Better social acceptance / ownership of sustainable management measures for small-scale fisheries to be implemented as part of management plans, management plans and local co-management sub-projects
  • Access to alternative livelihood activities is provided to vulnerable groups, including women, improving their living conditions
  • Development of a culture of entrepreneurship and diversification in fishing communities

Potential negative environmental and social impacts and risks of alternative livelihood activities

  • Risks of negative impacts of alternative livelihood activities if the environmental and social dimension is not taken into account in the analysis of their eligibility
  • Risks of conflicts in case of lack of fairness and transparency in the selection of beneficiaries eligible for the microcredit fund
  • Risks of elite capture
  • If appropriate measures are not adopted, women and other vulnerable groups may not have a fair and equitable access to alternative livelihoods activities

Consultations carried out

The general objective of the public consultations was to ensure the participation of the populations in the action planning process of the project. That included: (i) informing populations about the project and its activities; (ii) allowing populations to express themselves, voice their opinion about the project and take into consideration their insights in the identification of potential impacts and mitigation measures; (iii) identifying and collecting populations' concerns (needs, expectations, fears, etc.) regarding the project, as well as their recommendations and suggestions. Consultations were held in Bargny and Yenne (region of Dakar); Nianing, Pointe Sarène, Mdodiene and Mbaling (Department of Mbour, Region of Thiès).

After analyzing the opinions gathered from the stakeholders of the PRAO at the grassroots, it appears that the stakeholders have, unanimously, a clear and precise understanding of the major challenges posed by PRAO II. These challenges are the protection and restoration of the marine environment, particularly the critical habitats, degraded or threatened (nursery, spawning or refuge areas) for sustainable fishing, and the economic and social development of the populations in general and the fishing communities in particular. The stakeholders have also understood that responding to these challenges leads to negative impacts, the most important of which is the restriction of access, even if temporarily, to the fishing resources and, thereby, to a source of income. However, concerns have been raised about the restriction and access measures in the Little Coast SPA Management Plan (notably at Pointe Sarène and Nianing). In addition, because of the sensitive and vital nature of the fishing resources and the fishing activity in these localities, (it is the main source of income for the populations) social measures will have to be thought out and implemented to mitigate the inevitable effects of access restriction.

After analyzing the data collected on the ground, restitution sessions were organized with the fishing communities that are likely to be affected by the project in order to give them the results of the preparation of the project’s environmental and social safeguards frameworks (ESMF, RPF, OF).

Environmental and social management measures

The environmental and social management of the project will be ensured through the following measures:

  • Recruitment of an Environment and Social Safeguards Specialists (ESSS) (to be included in the team of the Project Coordination Unit)
  • Realization of Environmental and Social Impact Studies (ESIA)
  • Improving the safety of fishery sites
  • Development and dissemination of a manual of good environmental practices of the sector
  • Targeted reforestation of fishing sites, (including mangrove, (protection,) fight against coastal erosion)
  • Improve the environmental hygiene of fishery sites Mid-term and final evaluations of the implementation of the ESMF
  • Training of the stakeholders involved in the implementation and monitoring process
  • Iterative consultation with targeted communities / stakeholders
  • Information and awareness raising of the relevant populations.
  • Establishment of an accessible, equitable and transparent feedback and redress mechanism
  • Environmental and social supervision (Included in the control missions)
  • Environmental and social participatory monitoring

Environmental and social management procedure for eligible sub-projects

The ESMF includes a procedure for the environmental and social selection of activities to be carried out within the framework of the PRAO II funding, which inform future interventions when it comes to integrating national environmental and social requirements and the World Bank safeguard policies. The stages are:

Select the sub-projects

  • Identify the location/site and main technical characteristics of the sub-project 
  • Carry out environmental and social selection (Screening, filling forms). Determine the specific type of safeguards instrument
  • Approve the categorization

Prepare the specific instrument of environmental and social safeguard for the sub-project

  • Prepare and approve the TORs
  • Carry out the study, including the inclusive public consultation 
  • Validate the document and obtain the environmental certificate
  • Publish the document
  • Integrate in the tender document (TD) of the sub-project, all the measures of the construction phase which can be taken with the company 
  • Approve the contractor’s ESMP
  • Carry out/implement non-contractual measures with the construction company (Measures not included in the works contracts, for example, the Manual of Good Environmental Practices for the Fishing Sector)
  • Internally supervise the implementation of environmental and social measures
  • Disseminate the supervision report
  • Environmental and social monitoring
  • Strengthen the capacity of stakeholders in the implementation of environmental and social measures
  • Carry out an audit of the implementation of environmental and social safeguards within the last year of the project

Main indicators of the ESMF implementation 

The following ESMF implementation indicators will be monitored by the ESS of the PRAO

  • Number of activities that have been screened;
  • Number of companies applying environmental and social mitigation measures
  • Number of actors trained / sensitized on the environmental and social management of fisheries
  • Number of environmental and social monitoring missions with close relationship
  • Number of fishing sites complying with environmental and social requirements
  • Number of fishing sites benefiting from environmental health and reforestation measures

Organizational framework for the efficient implementation of environmental and social measures

Institutional arrangements for implementing the ESMF:

  • The UCP/PRAO: it will have the overall responsibility for the implementation of this ESMF as well as the instruments and other measures for environmental and social safeguard related to the program. It ensures the preparation of the documents and acquisition of the certificates and permits required by the relevant national regulations before any action. It reports to the steering committee on all due diligence, and ensures that the Bank and other stakeholders receive all the environmental and social supervision reports. To this end, the UCP will have to recruit an Environmental and Social Safeguards Specialist (ESSS), preferably with a more social than environmental profile, given the magnitude of the social impacts related to the restrictions on access to fisheries resources, which far exceeds the environmental / ecological footprint of the project, which remains marginal at best. The UCP transfers the reports to the Technical Committee and Steering Committee of the PRAO.
  • The Directorate of the Environment and Classified Institutions (DEEC): The DEEC (i) will participate in the environmental classification of the activities, (ii) will ensure the environmental and social monitoring of project activities, and the approval of the potential ESIAs as well as the adoption and dissemination of all the information from the ESMF and the ESIAs. At the local level, the DEEC relies on the DREEC for local monitoring.

Roles and responsibilities for the implementation of environmental and social management measures

  • The UCP/PRAO is responsible for approving the categorization and dissemination of the supervision report
  • The Environmental and Social Safeguards Specialist is responsible for : environmental and social screening (Screening-filling of forms), and determining the specific type of safeguarding instrument; preparing the TORs and sending them for approval; conducting the study, including public consultation; validating the document and obtaining the environmental compliance certificate; publishing the document; approving the contractor’s ESMP; executing/implementing non-contractual measures with the construction company; internally monitoring the implementation of environmental and social measures; the facilitation of the establishment of the feedback and redress mechanism; capacity building of stakeholders on environmental and social implementation and the audit of the implementation of environmental and social measures. He or she ensures the quality of all the safeguard documents of the project, particularly those to be sent to the World Bank. He or she must also make sure that all environmental and social measures outlined in the ESMP are integrated in the tender document (TD) of the sub-project. 
  • Procurement Officer (PO) of the UCP: ensure that relevant safeguards studies to be conducted by the UCP are included in the procurement plan that environmental and social measures are included first in the bidding documents and  later in the contracts
  • The Monitoring and Evaluation Specialist (SSE) of the UCP: oversees the monitoring of the strategic order indicators listed above and integrates the results into its overall project monitoring report.
  • The Administrative and Financial Officer (AFO) of the UCP: is in charge of including in the financial statements the budget provisions allocated to executing/implementing the measures and supervising the implementation of environmental and social measures.
  • The Directorate of the Environment and Classified Institutions (DEEC): it supports the preparation and approval of TORs and is responsible for Environmental and Social Monitoring.
  • Construction companies: they prepare and submit an ESMP-business and implement the environmental and social measures

Construction Control Missions: they prepare and submit a plan for supervising the implementation of the ESMP-business and carry it out.

CGES Final PRAO II_Sénégal.pdf