EASSy Cable

Environmental & Social Review Summary

This Environmental and Social Review Summary is prepared and distributed in advance of the IFC Board of Directors’ consideration of the proposed transaction. Its purpose is to enhance the transparency of IFC’s activities, and this document should not be construed as presuming the outcome of the Board of Director’s decision. Board dates are estimates only.
Any documentation which is attached to this Environmental and Social Review Summary has been prepared by the project sponsor and authorization has been given for public release. IFC has reviewed this documentation and considers that it is of adequate quality to be released to the public but does not endorse the content.

Project number	25340
Country	Eastern Africa Region
Sector	Information
Department	Global Inform. & Comm. Tech.
Company name	West Indian Ocean Cable Company Ltd
Environmental category	B
Status	Active

Date ESRS disclosed	April 27, 2007

Previous Events	Invested: June 12, 2008 Signed: November 21, 2007 Approved: August 2, 2007

View Summary of Proposed Investment (SPI), click here

Overview

Category & Applicable Standards

Key Issues & Mitigation

Community Engagements

Client's Documentation

Overview of IFC's scope of review

The scope of the project review with IFC’s Performance Standards included site visits, coordination with other lenders, and review of the documents as listed and described below:

- EASSy Detailed Feasibility Study, completed by Axiom, May 2005;
- Environmental and Social Impact Assessment (East African Submarine Cable System Project ESIA, February 2007, completed by EGS Ltd. - see link below);
- assessment of EASSy’ current and proposed management capacity and management systems; and
- review of EASSy’s framework Environmental and Social Management System (ESMS dated February 2007).
Site visits to selected landing stations were completed by the project team and meetings were held with senior management of the EASSy consortium, the ESIA consultants and national telecom operators (including Telkom Kenya, TELMA, Dalkom and Zantel) in February 2007.

In coordination with EASSy, Kreditanstalt für Wiederaufbau (KfW) and the African Development Bank (AfDB), and the World Bank/IDA who are lenders to the associated terrestrial backbone and backhaul components, a two phased approach to the Environmental and Social due diligence has been established. Phase I, now complete (see link below), included an assessment of international/deep water impacts, audits of national level requirements, and completion of a framework Environmental and Social Management System (ESMS). Phase II involves completion of national level ESIAs focusing on national/shallow water impacts and terrestrial impacts at landing points. IFC has been coordinating with these partners (and the World Bank) on the scope and depth of the ESIAs required. KfW and the AfDB are providing Technical Assistance for the two respective phases; IFC review of the Phase II will continue in coordination with these partners.

Project description

The East African Submarine Cable System (EASSy) is an initiative to construct and operate a submarine fiber optic cable along the east coast of Africa to connect eight coastal countries and island nations to each other and to the rest of the world. A special purpose vehicle (SPV) has been established by EASSy which consists of a small management and marketing team who will manage the implementation of the project. The SPV has contracted Alcatel, a specialist international company, to construct the project in coordination with the respective national telecom operators.

The cable will have an initial equipped capacity of 20Gbits/sec, and an ultimate capacity when fully upgraded of 320Gbits/sec. The route will be from South Africa to Sudan, covering about 8,500 km, and connecting the following countries: South Africa, Mozambique, Madagascar, Tanzania, Kenya, Somalia, Djibouti and Sudan. Twenty-eight leading telecommunications operators (the Operators) from East and Southern Africa signed a Memorandum of Understanding (MOU) in December 2003 to carry out the construction and maintenance of EASSy. EASSy will be the first optical fiber connection for most of these countries to the global optical fiber network. In separate projects, EASSy signatories are working on the development of terrestrial backhaul connections to link land-locked countries of the region to the cable (including Botswana, Burundi, Ethiopia, Lesotho, Malawi, Rwanda, Uganda, Zambia and Zimbabwe). IFC has been asked to provide financing to the SPV, along with five other DFIs including EIB, AfDB, DBSA, AFD/Proparco, and KfW.

The terrestrial backhaul connections are separate from but associated with the project and are to be developed by the respective national operators. These components are being financed by the World Bank who will ensure adherence to their Safeguard Policies in implementing these projects.

Key environmental and social issues and mitigation

The EASSy management team has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures listed in the ESIA, comply with the environmental and social requirements of the national level ESIAs, the host country laws and regulations and the IFC PS. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the Phase I ESIA.

- PS1: Social and Environmental Assessment and Management System (SEMS)

National operators are developing their respective plans and components of the project at different schedules, accordingly, as defined above, a two phased approach to the Environmental and Social due diligence has been established. Phase II, which will cover the 8 landing point countries, will include completion of ESIAs to meet national and IFC PS requirements and addressing shallow water and landing point impacts. Phase II ESIAs are underway and it is anticipated they will be completed over the next 6 months. Phase I includes development of a framework ESMS, which Phase II ESIAs will follow in developing their respective management systems. This will result in an integrated and consistent ESMS which will govern all national and international level operations resulting in an integrated ESMS for the EASSy project. IFC and other donors will review Phase II ESIAs as these are completed. In addition, the Phase I international consultant has been retained by KfW to review all Phase II draft ESIAs to ensure consistentcy with applicable standards and the model ESMS. As detailed in the Phase I ESIA, Phase I requires EASSy to engage an environmental auditor for each landing point, to monitor contractor (including Alcatel) operations during construction and cable laying.

- PS2: Labor and Working Conditions

The EASSy SPV (the sponsor) will employ a small number of professional marketing and administrative staff to sell cable connectivity. The SPV will develop an HR Policy consistent with PS2 and will provide all employees with access to this policy. Alcatel, EASSy’s construction contractor, will ensure that all cable laying operations comply with the ESIA requirements, including those related to labor, by implementing training programs and working coordinating all construction activities with the environmental auditor. With respect to other contractors or intermediaries employing non-employee workers, Alcatel will use commercially reasonable efforts to ensure that these intermediaries or contractors are reputable and legitimate enterprises and that they apply the applicable requirements of PS3. Alcatel will provide technical training to the staff of national operators who will maintain the cable in shallow water and on land to the landing station. The employees will receive state of the art training and equipment to perform cable maintenance and inspection. All employees will be provided with appropriate safety equipment; Alcatel will follow SOLAS requirements for marine operations and child labour will not be employed during any phase or portion of project construction or operation.

- PS3: Pollution Prevention and Abatement

Waste generated as part of project construction and operation is minimal. The main parameter of concern is sediment dispersal in the marine environment during cable laying. Depending on the depth of water and the condition of the sea bed (clay, rock, sand etc.) the cable will be buried or surface laid. The ESIA discusses, and independent evaluation of existing submarine cables demonstrates that impacts on the marine environment from cable laying are temporary and that marine organisms and habitats recover from the dispersion of sediment very rapidly. Alcatel’s sea vessels will adhere to MARPOL and IMO requirements with regard to waste disposal. Waste from excavation (dirt and rocks etc.) from terrestrial cable laying and manhole construction will either be buried in the duct/trench or disposed, along with other general waste (plastic, paper etc.), at designated municipal sites. Terrestrial operations entail laying a cable in the ground to a depth of approximately 0.5-1.0 meter in a concrete duct following an existing ROW or road. Contractors will be required to control run off and dust during duct construction through implementation of erosion and run off control measures, watering dirt roads and construction sites and providing training to all relevant management and staff on work procedures.

- PS4: Community Health, Safety and Security

During shallow water cable laying fishermen, tourism operators in the vicinity and maritime authorities will need to be informed by EASSy and Alcatel (in coordination the national operators) in advance of cable laying operations to prevent potential entanglement of anchors, vessels and fishing nets with the cable. According to procedures articulated in the Phase I ESIA; this will be incorporated into the consultation process during Phase II ESIAs and cable laying. Risks to communities from terrestrial construction involves only minor and temporary detours to traffic while the trench is established and cable is being laid along roads. EASSy must ensure contractors control traffic and ensure dust levels are controlled through proper work procedures and posting of signal men as needed. The landing points will have security guards posted; it is not anticipated that any of these will be armed. Training will be provided to these guards in accordance with the requirements of PS4 and the need to take action appropriate to the scale of the potential threat posed. Due to the political situation in Somalia the safety of cable installation staff, as well as other workers involved in construction, is a potential concern. Dalkom (an international operator) as well as the relevant Somali Ministries and authorities will implement the recommendations of the Phase II national ESIA to ensure provision of a safe working conditions to employees, non-employee workers and security personnel contracted to safeguard its personnel and property.

- PS5: Land Acquisition and Involuntary Resettlement

No land acquisition from local communities is anticipated for any landing points. Land acquired is from the government and is currently unoccupied. The ROW from the beach/coastal manhole will follow existing ROW and impacts anticipated are minimal. There may be temporary impacts on fishermen in some shallow water locations resulting in minor economic displacement associated with shortened fishing access for a period of days. The Phase I ESIA defines a detailed framework for identifying, consulting and compensating these fishermen; these groups will be compensated according to the respective Phase II ESIAs. Compensation will be agreed with these groups in a transparent manner consistent with agreed market rates.

- PS6: Biodiversity Conservation and Sustainable Natural Resource Management

There is no permanent loss of coral reefs or sensitive habitats (e.g., sea grass beds, coastal dunes, vegetation) and no significant impacts on these habitats expected and, as detailed in the ESIA, offsets are not needed. All beach manholes and landing stations are in urban/peri-urban areas. Where habitat is disturbed by sediment, construction or human activity it will recover in a short period of time. Some of the landing points and ROW pass through protected areas, however impacts are not significant as discussed for each landing point below.

- South Africa:

Impacts are unlikely in the Mlalazi Nature Reserve as the EASSy cable will follow the existing SAFE cable route. In the ecologically sensitive dune area potential impacts may occur in the absence of appropriate construction methods and careful access control.

- Madagascar:

The proposed cable landing site lies within the Littoral de Toliara Biosphere Reserve, the landing point will have no significant impacts on the reserve (as also audited by WWF-Madagascar). Appropriate measures for cable burial have been defined and the ROW to the landing station will follow an existing road.

- Tanzania:

Shallow waters up to the 10 m bathymetric contours are protected and designated as a marine reserve. The main features of ecological importance are scattered reefs, which the proposed route avoids. Reef in the landing point area is reported dead.

- Kenya:

The landing site is located between Fort Jesus and the old Mombasa town. An old cable, manhole and duct already exists and only require renovation and excavation. Cable installation within the existing ducts is considered to have no significant impacts on the surrounding environment and will not have any negative impacts on the nearby Ft. Jesus.

- Somalia:

The manhole and landing station are located near the airport and there is no fringing reef in the area. A new ROW for the duct will be established, it is expected this will pass over sandy areas and not interfere with or cross any sensitive habitats or community areas.

- Djibouti:

The manhole and Terminal Station lie within the Djibouti urban area and it is unlikely that operations will affect sensitive habitats/wildlife as the site is located near existing residential areas and an army barracks. During cable laying Alcatel will ensure they avoid vessel movements near Haramous Island (Haramous-Loyada, 11°35'N 043°09'E), close to the landing site, which is a highly protected sanctuary for seabirds.

- Sudan:

The cable will follow the existing SAS-1 cable routing to Saudi Arabia and passes over a former fringing coral reef now reported dead due to the proximity to Port Sudan and past impact associated with dredging and reclamation.

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