The likely locations for subprojects under LMCP are not yet known, but will most definitely include rural and peri-urban areas of Kenya. Further preparatory work needs to be concluded as to the specific geographic reach of the proposed project (e.g. selection and location of infrastructure investment). Further details on the state/county and social/physical environment of the project activities will be provided in the later stage.
The activities in the LMCP are for the moment expected to trigger only OS 1 (Environmental Assessment) and OS5 (Labor Conditions, Health and Safety). However, future phases of the LMCP may trigger other OSs, such as OS 3 (Biodiversity and Ecosystem Services). The safeguards instruments prepared for any subprojects will address the requirements of any applicable policies.
OPERATIONAL SAFEGUARDS TRIGGERED BY THE PROJECT(FOR THE MOMENT)
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YES
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NO
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OS1 -Environmental Assessment
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x
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OS2 Involuntary Resettlement: Land Acquisition, Population Displacement and Compensation
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x
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OS3 Biodiversity and Ecosystem Services
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x
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OS 4: Pollution Prevention and Control, Greenhouse Gases, Hazardous Materials
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x
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OS 5 Labor Conditions, Health and Safety
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x
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1.32.1Environmental Assessment (OP4.01)
This policy requires Environmental Assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus to improve decision making. The EA is a process whose breadth, depth, and type of analysis will depend on the nature, scale, and potential environmental impact of the proposed investments under the LMCP.
The EA process takes into account the natural environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples, and cultural property) and transboundary and global environmental aspects.
The environmental and social impacts under LMCP will come from the proposed investment activities. However, since the exact location of these investments will not be identified before bank appraisal of the project, the EA process calls for the Kenya Power to prepare an Environmental and Social Management Framework (ESMF).
OS 1 is triggered in case of LMCP, as the AFDB will finance project works including the rehabilitation and refurbishment of existing infrastructure, as well as the construction of new infrastructure. The exact locations and impacts of the sub-projects have not yet been identified, though the potential impacts for such project are known from experience with the past and ongoing projects.
This report which will establish a mechanism to determine and assess future potential environmental and social impacts during implementation of LMCP activities, and then to set out mitigation, monitoring and institutional measures to be taken during operations of these activities, to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels.
Operational Safeguard 1 further requires that the ESMF report must be disclosed as a separate and stand-alone document by the Government of Kenya and the AfDB as a condition for bank appraisal. The disclosure should be both in Kenya where it can be accessed by the general public and local communities and at the Banks website and the date for disclosure must precede the date for appraisal of the program/project. The policy further calls for the LMCP as a whole to be environmentally screened to determine the extent and type of the EA process. The Africa Development Bank system assigns a project to one of the four project categories, as defined below:
Category 1 Projects
An ESIA or SESA is always required for projects that are in this category. Impacts are expected to be ‘adverse, sensitive, irreversible and diverse with attributes such as pollutant discharges large enough to cause degradation of air, water, or soil; large-scale physical disturbance of the site or surroundings; extraction, consumption or conversion of substantial amounts of forests and other natural resources; measurable modification of hydrological cycles; use of hazardous materials in more than incidental quantities; and involuntary displacement of people and other significant social disturbances which require the preparation of FRAP.
Category 2 Projects
Although an EIA is not always required, some environmental analysis is necessary. Category 2 projects have impacts that are ‘less significant, not as sensitive, numerous, major or diverse. Few, if any, impacts are irreversible, and remedial measures can be more easily designed.’ Typical projects include rehabilitation, maintenance, or upgrades, rather than new construction. Although an EIA is not always required, some environmental analysis is necessary. Category 2 projects are likely to have detrimental site-specific environmental and / or social impacts that are less adverse than those of Category 1 projects and can be minimized by applying appropriate management and mitigation measures or incorporating internationally recognized design criteria and standards.
Category 3 Projects
Category 3 projects do not directly impact the environment adversely and are unlikely to induce adverse social impacts. They do not require an environmental and social assessment. Beyond Categorization, no action is required. Nonetheless, to design a Category 3 project properly, it may be necessary to carry out gender analyses, institutional analyses, or other studies on specific, critical social issues in order to anticipate and manage unintended impacts on the affected communities.
Category 4 Projects
Category 4 projects involve Bank lending to Financial Intermediaries (FIs) who on lend or invest in sub-projects that may produce adverse environmental and social impacts. FIs include banks, insurance, re-insurance and leasing companies, microfinance providers and investment funds that use the Bank’s funds to on-lend or provide equity finance to their clients. FIs shall also be understood to include private or public sector companies that receive corporate loans or loans for investment plans from the Bank used to finance a set of sub-projects.
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