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Federal Republic of Nigeria Federal Ministry of Agriculture and Rural Development Staple Crop Processing Zones Support Project (scpz)


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7.5.1 Mechanism for Engagement/Consultation of PAPs


Two or more ways are suggested for meaningful engagement of farmers and communities members as well as other stakeholders. The first is to use the existing recognized traditional structure in which consultation is conducted through the village/community leadership. This means of engagement is widely acceptable and an easy way to reach to all the groups in the community based on the existing traditional governance structure.

The use of social gatherings such as churches and mosques will also be important for dissemination of information to PAPs, and finally, there is the need to segment consultations into smaller targeted groups. This is premised at giving a voice to less advantage groups, minority settlers and groups in the resettlement planning. To do this effectively, the attendance records of the various groups having phone numbers and contacts will be used to call or reach out to direct stakeholders, including coordinating them for group meetings as and when necessary.



7.5.2 Tools for Consultation of Stakeholders


Depending on the target stakeholder and objective of consultation at any point, one or a combination of the following tools should be used.

Table 7.3: Future Consultations and Communication Tool


Stakeholder

Consultation Tools







Direct Stakeholders/Project affected persons and groups

  • Farmers groups

  • Land owners, tenants, squatters

  • Herdsmen

  • Vulnerable group/women

Focus group discussions, questionnaire, worship centres, Fadama group/desk officers, community town hall meetings, Print materials, texting by phone

Project partners

  • FADAMA

  • GEMS 3

  • Contractors

Phone calls, e-mails, visit, facilitation meetings, electronic media

Government Agencies/Ministries

Phone calls, e-mails, visit, meetings, electronic media

Potential Investors

Phone calls, e-mails, visit, meetings, electronic media




7.5.3 Plan for Future Consultations and Communication


Consultation will continue before, during and after project implementation (Annex..). The proponent is required to provide relevant materials in a timely manner prior to consultation and in a form and language that are understandable and accessible to the groups being consulted.

This requirements and phasing of consultations are as follows:



  • Consultation on the finalization of ESMF – to include:

    • Circulation of the draft ESMF for comments toll relevant institutions (Federal Ministry of Environment, FMARD, Kogi State Ministry of Environment, Kogi State Ministry of Agriculture, etc.)

    • Organization of public stakeholder workshops and comments incorporated in the final ESMF document

    • Public disclosure of Final ESMF (cleared by WB) in-country at designated centres accessible to stakeholders and at the WB info shop prior to appraisal

  • During the preparation of individual ESIA/ESMP

    • Potential investors, Farmers, interested groups and communities with LGCs affected will be consulted and informed about the proposed subproject activities and how they stand to be impacted environmental and socially speaking

    • Identification of impacts and appropriate mitigation measures shall be sought through consultation with the relevant local stakeholders community members and expert knowledge gained elsewhere and judgement in the light of best practice

    • Consultation of the proponent and implementing government agencies on relevant policy terms.

  • During the Implementation of the ESMP

    • Stakeholder communities and farmers will be informed about the date/schedule of project commencement who will be involved in site selection, screening and planning administration of needed mitigation measures and monitoring and evaluation

  • During audit/monitoring and evaluation of the ESMP to determine the performance of the ESMP

    • Farmers and community members will be consulted to appreciate their understanding of the impacts that have been generated and whether the mitigation measures are working or if there will be need to change the entire ESMP. This will take place 6months after the start of the implementation of ESMP and 2 years after for the audit.


CHAPTER EIGHT ESMF IMPLEMENTATION AND MANAGEMENT



8.0 Introduction

The successful implementation of the ESMF depends on the commitment of the PMU and other institutions relevant to it. In addition, the capacity within the institutions to apply or use the framework effectively, and the appropriate and functional institutional arrangements, among others will go a long way to ensure the adherence to the framework.


This CHAPTER addresses the key ESMF areas relevant to its successful implementation:

  • Institutional arrangements;

  • Participation/consultation Framework

  • ESMF Communication Plan in the Project Cycle

  • Measures for Strengthening Organizational Capability - Capacity building;

  • Environmental and Social Mitigation Principles and Clauses

  • Environmental and Social Monitoring

  • Budgets for the ESMF

  • Update and Revision of ESMF

  • Disclosures of Safeguard Instruments


8.1 Institutional Arrangements

Since one of the main purposes of the ESMF is to establish roles and responsibility for the activities that have to be undertaken, this sub-section details below, institutional arrangements and the roles and responsibilities of the various institutions relevant to the successful implementation of the ESMF as outlined in Table 8.1.


8.1.1 Project Management Unit

As a point of emphasis, the Project Management Unit (PMU) with a Project Coordinator (PC) as the head to be established, shall serve as the implementing body with the mandate to:



  • Co-ordinate the project programmes and actions in the SCPZ, especially and by extension any SCPZ activities in the ABIR

  • Plan, coordinate, manage and develop the various sub-project activities safeguard sections and parts

  • Prepare plans for SCPZ as a whole for effective project development and management.

  • Coordinate all environmental and social issues through a Safeguard unit.

Nevertheless, the PMU shall liaise with the various levels of government and other identified stakeholders, namely relevant Federal MDAs, State MDAs, Local Government Council Offices, the communities, NGOs/CSOs, Traditional Rulers; Trade Unions/Local social and professional groups e.g., farmers, market women, and the General Public



8.1.2 Environmental and Social Safeguards Unit

To ensure sustainability in all the SCPZ sub-project activities, an environmental and social development safeguards unit shall be formed which includes the environmental and social development safeguards officers that reports directly to the PMU PC.

The paramount objective of the environmental/social safeguards officers is to ensure the effective consideration and management of environmental and social concerns in all aspects of SCPZ, from the design, planning, implementation, monitoring and evaluation of initiatives. Thus, a key function of the environmental and social development safeguard officers is to engender a broad consensus, through participatory methods and extensive dialogue on the potential environmental and social concerns from project civil works as incorporated into the World Bank's environmental and social safeguards policies triggered by the project and environmental compliance with the EA.

With this, particular attention is directed at minimizing environmental and social risks associated with the development of sub-project initiatives, as well as the identification and maximization of social development opportunities arising from investments thus, the recruitment of assistant environmental and social officers.

In the implementation of the project, and for or all environmental and social issues the safeguard unit, shall work closely with other relevant MDAs in preparing a coordinated response on the environmental and social aspects of the sub-projects.



The roles and responsibilities of the environmental and social safeguards officers to anchor environmental and social issues distinctively are described below.

  • Review all ESIAs/ESMPs documents prepared by environmental and social consultants and ensure adequacy under the World Bank Safeguard policies.

  • Ensure that the project design and specifications adequately reflect the recommendations of the ESIAs/ ESMPs;

  • 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 program for the PMU staff, the contractors and others involved in the project implementation, in collaboration with the PMU;

  • Review and approve the Contractor’s Implementation Plan for the environmental measures, as per the ESIA and any other supplementary environmental and social studies that may need to be carried out by the PMU;

  • Liaise with the Contractors and the PMU / MDAs on implementation of the ESMPs;

  • 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 and social concerns and suggestions are incorporated and implemented in the project;

  • Review the performance of the project through an assessment of the periodic environmental and social monitoring reports; provide a summary of the same to the Project Manager, and initiate necessary follow-up actions;

  • Provide support and assistance to the Federal and State Government Agencies and the World Bank to supervise the implementation.



Table 8.1: Safeguard Responsibilities

S/No

Category

Roles




1

PMU

Implementing authority, has the mandate to ensure:

  • Compliance with World Bank Safeguards Policies and other relevant laws in Nigeria in the SCPZ and ABIR in line with this ESMF

  • Smooth and efficient implementation of the project

  • Faithful implementation of the ESMF and other safeguard instruments developed for each subproject




2

PMU Safeguards Unit/Safeguards Officer

  • Assists PMU to comply with and fully implement World Bank Safeguards Policies and other relevant laws in Nigeria.

  • Take lead in ensuring adequate screening and scoping of project in the SCPZ for the appropriate safeguard instrument.

  • Ensure adequate review of all safeguard reports before sent to the Bank

  • Supervision of the contractors, supervisors, training of contractors and workers, monitoring of the implementation of the ESMF and other safeguard instruments.




3

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

  • Lead role -provision of advice on screening, scoping, review of draft EA/ESMP 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, ensuring conformity with applicable standards, Environmental and social liability investigations, Monitoring and evaluation process and criteria




4

State Ministry of Environment/EPA



  • Collaborate FMEnv and Pparticipate in the EA processes and in project decision-making that helps prevent or minimize impacts and to mitigate them and ensures conformity with applicable standards, environmental and social liability investigations, monitoring and evaluation process, etc.




5

The Federal Ministry of Agriculture and Rural Development (FMARD)


  • Provides overall leadership and direction to the other MDAs by engaging all the critical stakeholders in SCPZ and ABIR to support, cooperate with and participate in established policy direction; and

  • Pursues an agenda of encouraging and ensuring investors comply with all environmental laws and policies




6

The Kogi State Ministry of Agriculture

  • Coordinates state-wide agricultural programmes including creation of awareness of farmers on the appropriate pesticides to use in consonance with this ESMF and IPMP




7

The Staple Crop Processing Zone Authority (SCPZA) -


Yet to be established but shall serve as principal body and agency of the Federal Government in all SCPZs in Nigeria. For the Kogi SCPZ and ABIR:

  • Responsible for the ensuring development and issuance of guidelines and standards for the effective operation of ABIR / SCPZs;

  • Ensures inclusion, as condition of approval to all investors in SCPZ and ABIR compliance clause on environmental and social standards and guidelines in accordance with this ESMF and subsequent ESIA/ESMP carried out in consonance with relevant local laws and triggered World Bank Safeguards policies;

  • Ensures SCPZ EMC prepare relevant safeguard reports for all proposed investments

  • Appoints qualified environmental and social safeguard officer who understands the germane issues and follow through with other relevant bodies in support of PMU




8

SCPZA Executive Management Committees (EMC)


  • EMC represents SCPZA at the level of each zone and responsible for implementation of the Master Plan for the SCPZ and oversees the day-to-day administration of the SCPZ and ABIR.

  • Ensure compliance by all investors with all relevant environmental and social guidelines and policies as contained in this ESMF and subsequent safeguard instruments to be developed in line with national laws and World Bank safeguard policies

  • Work with the PMU to ensure adequate review of draft ESIA/ESMP reports before sending it to FMEnv and the World Bank

  • Ensure inclusion of appropriate environmental and social clauses in all tender documents and requests for all projects/subprojects in SCPZ and ABIR




9

World Bank

  • Provides guidance on the compliance of safeguards policies

  • Will be involved in monitoring compliance with its safeguard policies via its oversight missions

  • Maintains an oversight role, review and provide clearance and approval for the ESMF and other relevant safeguard instruments developed for subprojects.

  • Conducts regular supervision for satisfactory ESMF/ESMP implementation, fulfillment of community liaison and provide support role throughout the project implementation, and monitor the progress of the project implementation.

  • Recommend additional measures for strengthening the management framework and implementation performance.

  • capacity building of the proponent as needed







10

Local government

  • Appoints Local Government Desk Officers (LGDOs) who visit communities and the ABIR / SCPZ operators on a regular basis to facilitate intensive participatory process and compliance to the local environmental laws

  • Support and work with the PMU by participating in environmental and social screening and scoping process of subprojects and public review of ESIA and ESMPs




11

Community Farmer Environmental Committee (CFEC)

Constituted by SCPZA EMC,

  • CFEC will assist to ensure sustainable agricultural practices,

  • identify the necessary environmental and social training needs and other areas of support for farmers,

  • participate in review of safeguard instruments and contribute to community mobilization.




12

Potential Investors / Developers


  • Adhere to the tenets of this ESMF and other relevant environmental and social guidelines and laws for best practice in carrying out their activities.

  • Mandatorily set up safeguard units for managing all safeguard activities to the full satisfaction of all stakeholders.







13

Zone Level Special Purpose Vehicle (SPV)


  • Zone-specific project company to provide specialized services be provided commercially and charged to operators within the SCPZ and ABIR.

  • Mainstream and ensure compliance with all environmental and social issues according to the dictates of this ESMF and subsequent safeguard instruments to be prepared into the implementation of all infrastructural developments




14

NGOs/CSOs/CDA

  • Assist to ensure effective response actions to relevant environmental and social issues,

  • Conducts scientific researches alongside government groups to evolve and devise sustainable environmental strategies and rehabilitation techniques,

  • Organizing, coordinating and ensuring safe use of chemicals and pesticides through awareness creation

  • Providing wide support assistance helpful in management planning, institutional/governance issues and other livelihood related matter, Project impacts mitigation and monitoring


8.2 ESMF Communication Plan

The ESMF Communication Plan refers to specific guidelines and protocols consistent with the principles of participation that will govern the project and which will be reflected in the Communication Plans, including the Communication Plans of the Social Safeguard Frameworks of the Project.


They are:

  1. establishment of feasible participation mechanisms ,

  2. establishment of participation mechanisms prepared with the basic objectives of transparency, responsibility of delivery of public service and an anticorruption approach;

  3. promotion of arenas of dialogue based on realistic and objective data avoiding the creation of expectations that cannot be met;

  4. positive discrimination for the most vulnerable groups, such as women, young persons, children, older persons and indigenous communities.



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