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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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Assessment of a No Project and Go Ahead Project Alternatives


The Analysis of Alternatives is an analytical comparison of multiple alternatives and has long been a part of environmental assessment practice. The purpose of the analysis of the alternatives is to determine which alternative best meets the threshold criteria of sustainable development. The following alternative actions were considered in relation to the proposed project-

Analysis of alternatives is done to establish the preferred or most environmentally sound, financially feasible and benign option for achieving project objectives. This requires a systematic comparison of proposed investment design in terms of site, technology, processes etc in terms of their impacts and feasibility of their mitigation, capital, recurrent costs, suitability under local conditions and institutional, training and monitoring requirements. For each alternative, the environmental cost should be quantified to the extent possible and economic values attached where feasible, and the basic for selected alternative stated. The analysis of alternative should include a NO ACTION alternative.

The following alternative actions were considered for the study areas –
The “No Action” alternative assumes that there will be no alteration to the existing areas. This would imply that the SCPZ AND ABIR investment proposed area/location would be left in their present states with a real potential for worsening. Specifically, if the area is left unimproved, environmental degradation as a result of the ongoing agricultural practices by the locals would continue and in turn will continue to lead to an ever increasing destruction of the habitat without proper or sustainable management leading to soil erosion, deforestation, etc.. In other words, damage and loss rates may increase even in the remaining forest reserve as there will not be proper and systematic management, monitoring and guidance from the appropriate authorities which had characterise the area over the years. Furthermore, poverty level amongst the local population will remain high and the objective of the ATA of the Federal Government for the country will suffer a setback.
A no-action or no project alternative is certainly not recommended.
A “Go Ahead Project Alternative,” though more expensive in terms of cost in every respect at the start, is seen to be the most feasible than do nothing alternative. Go ahead alternative is expected to reduce operational costs for cassava processors by up to 30% and create 7,500 new jobs and contribute overall up to US$ 0.5b to Nigeria’s economy. The development of Alape ABIR / SCPZ will strengthen national food security, improve regional economic growth and generally improve livelihoods in the rural farming communities in the SCPZ/ABIR through increased household incomes arising from opportunities for secured markets, improved productivity, reduced post-harvest losses and increased employment of the locals. In addition, the negative impacts on the environmental resources due to the unsustainable manner in which the local farmers devastate the forest resources to eke out a living in the area will be reduced if not eliminated as there will be enhanced knowledge on how these environmental resources could better be mined or used through knowledge to be created by the project. This in turn will reduce the overall level of poverty noticed in the communities.

The two scenarios considered herewith are summarized in ES Table c. The inference from this consideration is that even though the go ahead option is more extensive, it is a the preferred or most environmentally sound, financially feasible and benign option for achieving project objectives and ensuring economic growth and sustainable development both at the micro and macro scale.



Thus the advantages of the “go ahead” alternative makes it a better option than the “No-Action” alternative.



ES Table c Analysis of the Alternatives

Criteria

No Project Alternative

Go Ahead Project Alternative

Overall Protection of the environment and social well being

The field visits revealed the level of poverty in the communities, the unsustainable manner in which environmental resources are being devastated to the extent that taking a "no action” alternative will not benefit members of the study areas or their environment and even the national economy as the government moves away from petroleum to non-petroleum-focused economy

Intervention would lead to strengthening agriculture in a more professionalized and highly organized manner which provides room for best practice soil conservation and sustainable management of natural resources. It will further generate income, which in turn increases the living standard of the locals and overall improvement of the national economy even in the absence of petroleum product

Long-term Effectiveness and Permanence

No action alternative does not meet the long-term effectiveness and permanence criteria of the national and local economy including the agenda to improve the overall management of environmental resources for sustainable development

Go ahead option will further improve the local and national economy with sustainable development agenda in mind through careful planning based on informed decision making by all parties including the locals of the project environment

Compliance with Applicable or Relevant Appropriate Requirements

Does not require compliance with applicable or relevant appropriate requirements even at local levels

All undertakings will go through an established system of screening to ensure the necessary standard and permit requirements even at the local levels are met.

Short-term Effectiveness

No action alternative will not add any input under this criteria

The go ahead alternative will be completed in a long-term period based on the projections. However the benefits when completed outweighs a “no action” alternative because of the systematic manner of development






ESMF Implementation and Management

The successful implementation of the ESMF depends on the commitment of the sector and related institutions, and the capacity within the institutions to apply or use the framework effectively, and the appropriate and functional institutional arrangements, among others. Hence these key ESMF areas relevant to its successful implementation were included in the ESMF, namely: institutional arrangements, capacity building, environmental and social monitoring. . The roles and responsibilities of these levels of institutions with regard to this ESMF are outlined in the ES Table d.




ES Table d: 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



Capacity Building and Training


Based on the public consultation, the capacity assessment of implementing federal and state level Ministries, Departments and Agencies (MDAs) as well as the PMU, were carried out. The effective functioning of the MDAs is hindered by limited technical skills and resource constraints. Thus, institutional barriers include:

  • Limited knowledge of the relationship between World Bank Safeguards policies and the extant environmental and social laws in Nigeria;

  • Lack of enforcement of development control regulations;

  • Limited knowledge on EIAs and Environmental and Social Audits during construction/rehabilitation of drainages and culverts;

  • Limited knowledge on Strategic Environmental and Social Assessment;

  • Limited monitoring of water quality, river flow and lack of systemic hydrologic data collection;

  • Limited technical capacity on solid waste management;

In order to achieve the goal of the ESMF, there is a need for capacity building and strengthening of relevant competencies on environmental and social management at federal and state level MDAs – Kogi State Ministry of. It involves organizational development, the elaboration of management structures, processes and procedures, not only within organizations but also the management of relationships between the different organizations and sectors (public, private and community).

The environmental and social management requirements and provisions outlined in this ESMF, competencies and capacity building will be required in the following areas:


  • Environmental Impact Assessment Process - screening, scoping, impact analysis, mitigation measures and monitoring, reviewing ESIA reports;

  • Environmental Due Diligence - types of due diligence, screening projects for liabilities, scoping due diligence investigations and reviewing due diligence reports; and

  • Monitoring and Evaluation - understanding the importance of monitoring and evaluation (M&E) in project implementation, M&E requirements for environmental and social sustainability of projects.


Estimated Budget for Implementing the ESMF


To effectively implement the environmental and social management mitigation measures as part of the ESMF, necessary budgetary provisions have to be made for sub-projects. It is important to identify financial requirements even if indicative. This ensures upfront appreciation of the financial requirements and allows early planning and budgeting accordingly.


Tentative budget for each of the project includes the environmental and social mitigation cost, management costs, cost of environmental monitoring and capacity building. All administrative costs for implementing the ESMF shall be budgeted for as part of the project costing.


Table ES e below shows an indicative budget breakdown of the cost for implementing the due diligence in the project. The total cost for implementing the ESMF is estimated att N49.17m ($265,783.78)) (Table ES d).




ES Table e: Estimated Annual Budget to Implement ESMF

1

ESMF Requirements

Budget Basis and Assumptions

Total Cost per Annum (N)




2

Capacity Building for PMU Personnel

Training Programs held in-country

N5M




Meetings, Workshops and Stakeholder Engagement

Monthly estimated expenses of N35,000/person for 10persons/per year

N4.2m

(to based on actual expenses)






3

Environmental Screening of transactions

No additional budget

No additional budget




Engagement of Specialists

Assume specialists may be engaged times to investigate issues

To be worked out when is to be engaged




Field Visits to facility locations

Field visits estimated for 2 PMU personnel per year. Covers, transport, accommodation and daily allowances

N1.5m




Meetings, Workshops and Stakeholder Engagement

No additional budget

Based on actual expenses




4

ESIA Scoping Workshops

ESIA Scoping workshops per year

As part of the ESIA/EMP preparation




Typical ESIA Report for subprojects

Assume average cost of each ESIA depending on the extent of the road

N20m




Typical ESMP for subproject




N12m




Engagement of Environmental and Social Specialists




As part of the ESIA/EMP preparation




5

Monitoring Compliance with ESMP on E&S Issues during pre-operations activities

Assume quarterly monitoring activities over 5 days each quarter per year

N2m




6

Monitoring Compliance with ESMP and on E&S Issues during operations

Assume quarterly monitoring activities over 5 days each quarter per year

As part of item 5




 7

 

TOTAL Estimated Budget

N 44.7m




8

Contingency

10% of sub-total

4.47







Grand Total




N49.17m ($265,783.78)

$1=N185

Stakeholders Consultation


In accordance with World Bank safeguards policy governing EA Category A projects, the GoN recognizes that stakeholder consultation is an important element of the SCPZ and the EA process.

The objectives of the consultations were to:



  • Inform the affected communities within the ABIR about the project development objective,

  • Give them opportunity to express their perceptions and concerns about the project impact;

  • Collect useful local data/information/solutions that will help in the ESMF/ESMP/ESIA project preparation (e.g. Local grievance redress procedures).

  • Receive from, and deliberate with the stakeholders on measures to avoid or mitigate impacts as well as facilitate rehabilitation of affected persons

  • Empower their voice by mainstreaming their inputs into ESMF/ESIA implementation plan


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