Nigeria - Towards the Development of an Environmental Action Plan for Nigeria

Report No. 9002-UNI Towards the Development of an Environmental Action Plan for Nigeria December 18, 1990 Western Africa Department FOR OFFICIAL USE ONLY . 3 '.9 ~ ~ ~ ~ ~~~~~~~~~. Document of the world Bank _ A This document has a restricted distribution attd may be wged-by reciplients only in the performnance of their official duties. Its contents may not otherwise be disclosed without World Bank auth-orization. 'N~~~~~~~~~~~~~~~~~~~~~~ .  TOWARDS THE DEVELOPMENT OF AN ENVIRONMENTAL ACTION PLAN FOR NIGERIA Abbreviations and Acronyms Used ADP Agricultural Development Program BAT Best Available Technology BPM Best Practicable Means CBA Cost-benefit Analysis CFC Chlorofluorocarbons CITES Convention on International Trade in Endangered Species CR Capitalization Requirement DFN Debt For Nature DTS Direct Transfer Scheme EA Environmental Assessment EARP Environmental Assessment Review Process ECOVWAS Economic Community of West African States EE Economic Equity EG Economic Growth EIA Envit,nmental Impact Assessment EIS Environmental Information System FEPA Federal Environmental Protection Agency FEPAD Federal Environmental Protection Agency Decree FGN Federal Government of Nigeria FOS Federal Office of Statistics GNP Gross National Product GDP Gross Domestic Product IUCN International Union for Conservation of Nature IUCNPA International Union for Conservation of Nature Protected Area LGA Local Government Authority NCE National Council on the Environment NCF National Conservation Foundation NGO Non-governmental Organization NRCC Natural Resources r-onservation Council OAU Organization on African Unity OD Operational Directive ODA Overseas Development Administration OECD Organization for Economic Cooperation and Development PDC Pollution Discharge Charge PEA Policy Effectiveness Analysis PRA Policy Reform Analysis RBDA River Basin Development Authority REDF Rural Environmental Development Fund RI Resource Integrity SAP Structural Adjustment Program SEB State Environmental Board SEF State Environmental Function SES State Environmental Strategy SNA System of National Accounts SP "Shadow Project" TFAP Tropical Forestry Action Plan UNEP United Nations Environment Program VER Village Environmental Royalty WCED World Commission on Environment and Development  FOR OFFICIAL USE ONLY TOWARDS THE DEVELOPMENT OF AN ENVIRONMENTAL ACTION PLAN FOR NIGERIA Table of Contents Page PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EXECUTIVE SUMMARY. . ............... ii CHAPTER I: INTRODUCTION . . . . . . . . 1 . . . . . . . . . . . . . CHAPTER II: BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . 4 A. Economic Structure, Background and Prospects. . . . 4 B. Legislative and Institutional Framework . . . . . . 7 CHAPTER III: GEO-PHYSICAL REVIEW BY ECOLOGICAL ZONE . . . . . . . . . 11 A. Introduction. . . . . . . . . . . . . . . . . . . . 11 a) Deforestation .12 b) Soil Degradation. . . . . . . . . . . . . . . 13 c) Industrial Waste. . . . . . . . . . . . . . . 14 d) Biodiversity. . . . . . . . . . . . . . . . . 15 e) Fisheries and Wildlife. . . . . . . . . . . . 15 f) Water Hyacinth. . . . . . . . . . . . . . . . 16 B. Northern Zone ..16 C. Southern Zone ..17 D. Mid-Zone. . . . . . . . . . . . . . . . . . . . . . 19 E. Urban Ares .21 CHAPTER IV: DIRECT AND INDIRECT CAUSES. . . . . . . . . . . . . . . . 25 A. Introduction . . . . . . . . . . . . . . . . . . . 25 B. Indirect Causes for Environmental Degradation . . . 27 a) Population Growth and Selective Concentration 28 b) Land Resource Ownership Issues. . . . . . . . 29 c) Lack of Controls, Enforcement Measures and Jurisdictional Overlaps . . . . . . . . . . . 31 (i) FEPA and NRCC . . . . . . . . . . . . . 32 (ii) Institutional Issues Relating to Water Supply and Quality . . . . . . . 33 d) Negative Externalities and Economic Policy Issues . . . . . . . . . . . 34 e) Lack of Consumption Alternatives. . . . . . . 35 f) Use of Inappropriate Technology . . . . . . . 35 g) Other Relevant Factors. . . . . . . . . . . . 35 This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization.  TOWARDS THE DEVELOPMENT OF AN ENVIRONMENTAL ACTION PLAN FOR NIGERIA Table of Contents CHAPTER V: CRITERIA FOR ASSESSING PRIORITIES . . . . . . . . . . . . 37 A. Primary Criteria For Ranking Overall Priorities . . 37 B. Indication of Environmental Priorities to Illustrate the Consequences of Inaction . . . . 39 CHAPTER VI: STRATEGIC OPTIONS . . . . . . . . . . . . . . . . . . . . 43 CHAPTER VII: ILLUSTRATIVE OPTIONS FOR ENVIRONMENTAL ACTION PLANNING . 50 A. Overview. . . . . . . . . . . . . . . . . . . . . . 50 B. Potential Institutional and Legislative Reforms . 56 C. Specific Legislative and Institutional Measures to Address Identified Problem Areas. . . . . . . . 59 D. Potential Policy Inititiatives. . . . . . . . . . . 63 E. Measures Related to Specific Environmental Problems 67 F. Conclusion. . . . . . . . . . . . . . . . . . . . . 74 ANNEXES BIBLIOGRAPHY  TOWARDS THE DEVELOPMENT OF AN ENVIRONMENTAL ACTION PLAN FOR NIGERIA TABLES AND FIGURES TABLE 4.1 SUMMARY OF CAUSES OF ENVIRONMENTAL PROBLEMS AND THEIR LOCATION ................... . 26 TABLE 5.1 CRITERIA FOR RANKING OVERALL PRIORITIES. . . . . . . . . . 38 TABLE 5.2 INDICATORS OF ENVIRONMENTAL PRIORITIES . . . . . . . . . . 39 TABLE 6.1 MECHANISMS TARGETED TO DEFORESTATION . . . . . . . . . . . 46 TABLE 6.2 CRITERIA FOR RANKING POLICY EFFECTIVENESS. . . . . . . . . 47 FIGURE 7.1 ILLUSTRATIVE ORGANIZATION CHART OF ENVIRONMENTAL INSTITUTIONS ...................... . 53  TOWARDS THE DEVELOPMENT OF AN ENVIRONMENTAL ACTION PLAN FOR NIGERIA ANNEXES ANNEX I. SUSTAINABLE DEVELOPMENT AND CRITERIA FOR RANKING ENVIRONMENTAL PRIORITIES ANNEX II. EXAMPLE OF DIRECT TRANSFER SCHEME FCR PROMOTING COMMUNITY ENVIRONMENTAL DEVELOPMENT ANNEX III. LEGISLATIVE SUMMARIES ANNEX IV. PROJECT ECONOMIC EVALUATION GUIDELINES ANNEX V. EXAMPLES OF MECHANISMS TARGETED TO ADDRESS ENVIRONMENTAL PROBLEMS ANNEX VI. ECONOMIC GROWTH IMPACTS ANNEX VII. GENDER AND SUSTAINABLE DEVELOPMENT ANNEX VIII. GEO-PHYSICAL DATA: MAPS OF ECOLOGICAL ZONES ANNEX IX. IUCN CATEGORIES OF PROTECTED AREAS  PREFACE 1/ Sustainable development has become an important issue in both developing and developed countries as a result of the UN Brundtland Commission report in 1987. Moving from commitment at the conceptual level into a pragmatic operational framework is now the challenge. The importance of environmentally sustainable development practices and policies is now an integral part of the planning of the Federal Government of Nigeria (FGN) and the World Bank. FGN has signalled its commitment to the environment through the promulgation of the Federal Environmental Protection Agency Decree, setting up the Federal Environment Protection Agency (FEPA), to carry out the effective management and control of pollution in Nigeria. FGN has also recently approved a comprehensive National Policy on Environment and set up a Natural Resources Conservation Council, by Decree, to address conEervation issues in the country. The World Bank has instituted policies and procedures that require the integration of environmental priorities into all project planning and lending operations. The Western Africa Department initiated the task of carrying out, in conjunction with Federal and State governments, an assessment of the major environmental problems facing the country, and developing an analytical framework within which strategies would be formulated to deal with these problems. The purpose of this evaluation of Nigeria's environmental priorities is to identify the key causes of environmental degradation, as well as to illustrate the role which economic policies might play in reversing environmental degradation in Nigeria. It also provides an operational framework of practical use in the design of projects that successfully integrate environmental and economic concerns. I/ This Report was prepared by Jasdip Singh (AF4), Task Manager, Indu Hewawasam (AF4), Rosemary McCarney (Consultant), Elizabeth Rose (Consultant) and Jack Ruitenbeek (Consultant). Other contributors were: Gautam Datta (AF4CO), Ken Newcombe (AFTIE), John English (ENVPR), Hassan Hassan (ENVAP), Paatii Ofosu-Amaah (LEGAF), Abigail Osae-Addu (ENVAP), Takao Ikegami (AFTIN), Lars Rasmusson (AFTIN), Walter Haessel (Consultant), Mike Holland (ODA), Vijay Jagannathan (Consultant), Jonathon Okafor (Consultant, Nigeria), and Himraj Dang (Summer Intern). Nigerian Consultants from Obafemi Awolowo University, Ile Ife and other experts from Federal and State Government sources in Nigeria provided background papers and valuable comments on previous drafts of the report. Production support was provided by Mr. Brian Bridget-DeBerry.  - ii - EXECUTIVE SUMMARY I. OVERVIEW 1. The World Bank and the Federal Government of Nigeria initiated a series of measures to define environmental priorities in the country and to reach agreement on the type and scope of reform which would be required to redress the prevailing environmental degradation. The Western Africa Department, in December 1989, initiated the task of carrying out an assessment of the major environmental problems facirg the country. The Report is based primarily on substantial research which already had been carried out by both local and foreign experts in the different sectors. The Report develops a framework within which to formulate an environmental strategy for the country and identifies specific options to redress the current degradation. The framework as well as the proposals were discussed with FGN officials at a technical level, as well as with academicians, non- governmental organizations and members of the donor community during a recent mission to Nigeria. Comprehensive reports from sectoral teams which carried out analytic work during this mission, reports from local experts, the recent report of the Overseas Development Agency (ODA, U.K.) 1/ and contributions from within the Bank provided valuable inputs for the preparation of the Report. 2. The purpose of the Report is to provide policy makers with a framework for determining Nigeria's environmental priorities; a strategy for developing solutions to the country's environmental problems; and options for initial programs which could be introduced to alleviate the environmental concerns. The Report provides a holistic approach to the environment. It focuses its approach on the development of policies, institutional capacities, data management systems and economic mechanisms designed to integrate the need for environmental quality with economic growth in Nigeria. 3. The Report focuses on four main areas: (a) identification of the direct and indirect causes of the key environmental problems of the country; (b) examination of the linkages between economic policies and environmental concerns and illustration of the role which economic policies might play in reversing these trends; (c) development of a framework within which to integrate environmental and economic concerns and to outline policy options targeted at redressing the environmental imbalance which currently exists; and 1/ Overseas Development Agency, Assistance to Federal Environmental Protection Agency: Nigeria Environmental Resources Limited, London, April 1990.  - iii - (d) identification of areas whRre specific programs and projects could be developed in the pursuit of sustainable development for the country. 4. The Report also provides a preliminary identification of options for addressing the environmental problems. These include: (a) legislative reforms in environmentally sensitive areas, as well as institutional reforms at the federal and state levels, designed to streamline the implementation of environmental policies and actions; (b) economic policy initiatives directed at reversing the prevailing degradation; (c) preliminary identification of sectoral priorities and areas for policy reform, and identification of areas for further study where potential policy options are not readily available; (d) establishment of a baseline data network for the country; and (e) initiation of public education programs for generating awareness of environmental and conservation issues. II. METHODOLOGY 5. The Report analyzes the severity of each environmental problem in the country, which is tested initially against five criteria: (a) economic growth, in terms of the impact of environmental degradation on sustainable income; Cb) distributional equity, in terms of the number of people affected by environmental degradation; Cc) distributional equity, in terms of the relative burden of environmental degradation on the poor; (d) resource integrity, in terms of the threat of environmental degradation to overall environmental integrity and human health; (e) resource integrity, in terms of the threat of environmental degradation and poor harvesting practices to renewable resources. A methodology is proposed in the Deport for examining environmental issues on a national level and further provides a means for quantifying economic losses which result from environmental degradation. Preliminary estimates of economic losses are reported in terms of the long-term effect which  . iv - inaction would have on Nigeria's 'Sustainable Net National Product" (SNNP) 2/. 6. In order to evaluate the effectiveness of suggested policy reforms or programs intended to mitigate the environmental degradation in Nigeria, the following criteria are tentatively selected: (a) impact on economic growth; (b) impact on the distribution of wealth; (c) effect on environmental integrity and human health; (d) effect on renewable resource integrity; (e) budgetary requirements; (f) consistency with the "polluter pays" principle; (g) consistency with national macroeconomic policies; (h) consistency with jurisdictional authority; (i) ease of administrative implementation; Cj) potential to target beneficiaries effectively; (k) direct physical impact on other zones; (1) negative economic effects (price distortions); and (m) time frame for implementation (short, medium or long-term). 2/ The SNNP is a measure which, although still in its early stages of theoretical development in the field of environmental accounting. provides an estimate of what the sustainable level of production is in an economy. Unlike conventional GNP and GDP income measures, the SNNP excludes investment which is necessary for maintaining environmental integrity intact ("defensive expenditures"); it also excludes income from resource harvesting which involves depletion of known resource stocks ("depreciation of national cRpital"). In most cases in this study, the defensive expenditure approach was used to estimate SNNP impacts. Where this was not possible due to lack of data, proxies were developed by estimating direct impacts on GDP through other methods (such as import substitution or sustainable income losses). A complete picture of impacts on SNNP would require a thorough analysis of the timing of economic losses, and the effective productivity of near-term investments for meeting long-term environmental goals. Data limitations (both for technical and economic impacts) precluded such an analysis from being undertaken at this stage, hence economic growth impacts presented in this Report reflect primarily the impacts on long-term output if no near-term initiatives are taken.  v III. MAIN FINDINGS A. Environmental Priorities 7. There are three key national environmental problems facing Nigeria: soil degradation, water contamination and deforestation. Six additional problems form a partial. subset of the primary problems. However, due to the degree of severity of these six problems in their local area or region, they are highlighted independently. 8- In applying the aggregated criteria to these nine problems to determine the national aanking of environmental priorities. the results were as follows: Problem Impact of Problem On: Economic Distributional Resource Gro.,th Equity Integrity Soil degradation High High High Water contamination High High High Deforestation High High High Gully erosion Moderate Moderate High Fisheries LosE Moderate Moderate High Coastal erosion Moderate Moderate Moderate Wildlife & Biodiversity Loss Low Low High Air pollution Low High Moderate Water hyacinth Moderate Low Low Application of the same criteria to the same problems could, at local or regional levels, substantially alter this ranking. However, no such regional rankings have been made in the Report. 9. Long-term Impact of Natural Resource Degradation. The following paragraphs will discuss the long-term impacts of natural resource degradation in quantitative terms. Research carried out by both local and foreign experts indicate that the prevalent degradation, if allowed to continue unchecked, would result in long-term losses to the nation which would be of very large magnitudes. Inadequate data exists at the present time and much more detailed analytic work would need to be carried out before exact estimates of the long-term losses associated with natura'. resource degradation can be quantified. A Defensive Expenditure approach is used in this report to derive estimates of the long-term impact on Sustainable Net National Product (SNNP) of Nigeria. The methodology used and the numbers derived are intended to illustrate to policymakers the magnitude of losses to the na_ion if no action is taken to arrest the prevailing degradation. 10. Soil Degradation and Loss is considered the most serious environmental problem facing Nigeria from an economic perspective. It affects about 50 million people and could have long-term impacts in excess  - v4 - of US$3 billion annually. This is a conservative estimate as it reflects the cost of food replacement required through net imports and does not reflect costs which might be associated with general health deterioration if national food losses are not replaced by imports. 11. Water Resource Integritt threatens to place about 40 million people at risk. Conservative estimates suggest that it would cost in excess of US$1 billion annually to correct if ground and surface water contamination goes unchecked. The people most affected tend to be the urban and landless poor. The overall environmental degradation is such that it could create health problems caused by water borne diseases for most of this populstion over the long term. Many are already affected through the consumption of unsafe drinking of water. Water contamination also places other resources at risk; fisheries and land resources are nlready significantly affected. 12. Deforestation. If continued, deforestation will result in the loss of the services from existing forests and the loss of sustainable production of wood products (timber and fuel wood) as well as non-wood products (such as traditional foods, spices, and medicJnes used by populations on che periphery of the forests). Conservative estimates suggest that, if uncorrected, about 50 million people will be directly affected by the impacts of deforestation, mostly through declining fuel supplies. Sustainable production from the forestry resources represents about U_$750 million annually in value. Fuelwood substitutes exist, such as LPG; to date, however, supply and distribution constraints have limited their effectiveness as an alternative domeEtic fuel supply for households. 13. Aggregating all of the sources of environmental degradation, complete inaction would involve ultirnate long-term losses which are estimated to be as high as US$5 billion per annum. Inadequate data exists to estimate the time profile of these losses and the current investment requirements to offset these losses. Although the bulk of the scil degradation and losses is likely to be a long-term problem (>20 years), the impacts of both water integrity and deforestation are much more immediate (<10 years). Current investment programs could be put into place to offset these losses, and depending on the productivity of capital and the actual timing of future losses, such programs could require a dedication of anywhere from 3 percent to 20 percent of current GNP. 3/ 3/ As shown in Annex VI, the investment out of current GNP would depend on timing and discount rate. As a very conservRtive example, for instance, a 20 year delay in losses and an assumed average real return of 10 percent on capital would translate to US$0.81 billion per year in current terms (i.e., 3Z of current GNP). If average environmental losses accelerate (to 10 years) and capital in Nigeria is less productive (say, 5X), then the environmental losses are significantly higher in current terms: US$3.1 billion per year, or 13 percent of current GNP. In the extreme, with poor economic performance or rapid environmental deterioration, the full 20 percent of current GNP would apply.  - vii - 14. Other significant environmental concerns which are identified are the issues of global warming and the depletion of the ozone layer. The FGN considers these issues to be of crucial global importance and is an active participant in the international community which is addressing them. As the focus of this Report is on environmental problems faced within Nigeria, these global concerns are not addressed in this Report. B. Causes of Environmental Degradation 15. The identification of the causes of environmental degradation in the country is crucial, since these causes in turn point to targets for suggested action. 1. Direct Causes 16. The direct causes of the environmental problems include: improper resource management, destructive logging overgrazing/overcropping, flooding and wind erosion, raw sewage discharges, industrial pollution, hunting/poaching, habitat losses, improper construction techniques, strip mining, oil industry activities which create emissions, spillages, accidents, and land degradation, as well as natural causes. 2. Lndirect Causes 17. There are a number of significant indirect causes of environmental degradation. There is, for example, growing evidence that high population density increased agricultural demands, and declining environmental integrity will reinforce each other to a point where the overall health and sustainability of the system is threatened. Such indirect factors often require long term solutions and resolutions on a national scale to be effectively addressed. The Report focuses on identifying options for minimizing the impact of "indirect causes" on the environment. Although more detailed analysis is required in the specific sectors, the following indirect causes of environmental degradation have been identified: (a) Population Growth and Influx: Increase in population places increased demands on the environmental resources for potable water and effective sewage disposal, and it puts pressure on forest, wildlife and land resources. (b) ProRerty Ownership Issues: Where no clearly defined property rights are attached to resources (such as the Lagos lagoon, Nigerian rivers, coastal waters, lands and forests), they tend to be overused or overdeveloped. Also, current market mechanisms and property ownership patterns do not provide adequate incentives to conserve Nigeria's wildlife and ecological biodiversity. (c) Lack of Controls, Enforcement Measures and Jurisdictional Overlaps: Environmental problems have been exacerbated in the past because of unclear designation of authority and respunsibility, overlapping of responsibilities, lack of monitoring systems, and lack of adequate enforcement.  - viii - (d) Negative Externalities and Economic Policy Distortionst Certain economic policies have had undesirable impacts; creating price distortions and exacerbating specific problems leading to increased degradation of the natural resource base. For example, in an attempt to hold down fuel costs, kerosene prices have been controlled at low levels. Adulteration of the higher priced gasoline with kerosene as well as smuggling of kerosene across the border have resulted in uncertainties of supplies resulting in consumers resorting to other types of energy sources, especially fuelwood. (e) Lack of Consumption Alternatives: Logistical and supply constraints such as the under-supply of alternative fuels puts pressure on resources such as fuelwood. Similarly the non- availability of technologies for increased domestic production of alternative protein sources, has placed increased pressures on wildlife resources. (f) Use of Inappropriate Technology: Capital subsidies in various forms have encouraged some unsuitable large-scale farming methods, such as mechanization, which have in some cases resulted in the deterioration of the soil quality leading to the degradation of the land resource base. Some of these indirect causes are related to other environmental problems: deforestation, for example, exacerbates fisheries losses. IV. OPTIONS FOR MITIGATING THE EFFECTS OF ENVIRONMENTAL PROBLEMS 18. While the environmental problems - and some of their direct and indirect causes - are becoming clearer, the strategies available for addressing these problems are still in the early stages of development. In many cases it is not clear what the best solutions are to any particular problem. It is expected that strategies and projects will emerge as a result of ongoing discussions within Nigeria. Further, it is clear that additional sectoral information is necessary before specific policy prescriptions can be made. At this time, however, the Report does identify many proposals, for consideration by policy-makers, for redressing environmental degradation. It is important to note that these options are not mutual.ly exclusive and, indeed, complementary actions will often be required. The proposals identified in the Report are: (a) Modification to the organizational structure of environmental functions at the federal level; (b) Additions and modifications to the federal and state environmental responsibilities; (c) Economic policy initiatives; (d) Energy policy initiatives; (e) Development of environmental data management systems;  - ix - (f) Surport for local initiatives; (g) Development of educational programs; (h) Debt for Nature swaps; and (i) Sectoral projects and areas for policy review in environmentally sensitive areas. A. Organization of the Environmental Function at the Federal Level 19. Two federal bodies have been established with environmental responsibilities: The Federal Environmental Protection Agency (FEPA) and the National Resources Conservation Council (NRCC). FEPA is u.ader the jurisdiction of the Ministry of Works and Housing (MWH) while the NRCC is in the Office of the Presidency. The Decrees under which they were established seem to divide their responsibilities into "environmental" issues and "conservation" issues respectively. Potential areas of dispute are foreseen between the two bodies because of: (a) the jurisdictional overlap of responsibilities, especially in the areas of reporting and monitoring of natural resource conservation; (b) the jurisdictional ambiguities, for example, in connection with water resources and coastal zone management; and (c) the ability of both agencies to determine grants for environmental activities. In this case both FEPA and NRCC could be competing for funds. 20. Some options are available in the near term to resolve these potential conflicts and to reduce the problems of jurisdictional overlap: (a) FEPA made independent of the MWH. This would result in the removal of potential conflict of interest issues associated with monitoring the activities of the MWH. As an independent body, FEPA would be able to ensure cooperation between all Ministries, rather than rivalry. Hence, it could be more effective in its role of monitoring all national activities which have a negative impact on the environment; (b) NRCC develop a national conservation strategy and action plan. It is understood that the process for strategy formulation is being currently initiated under the ongoing Land Management Study; and (c) FEPA and NRCC establish a working agreement with respect to their relative responsibilities and operations. Such a working agreement in accordance with the spirit and intentions of the Decrees which established these instituions would be preferred over the more time-consuming alternative of making amendments to the Decrees. 21. Although these near-term options provide a practical solution to Nigeria's immediate needs, an important long-term option is that of consolidating all federal environmental functions within a single entity. By establishing such a single body, the following benefits will be realized:  x (a) it would become an effective instrument to implement the National Policy on the Environment and would support the expressed political will of all levels of government; (b) it would be more efficient in administering the affairs of the environment more effectively; and (c) it would be easier to provide budget allocations from national revenues which would enable it to fulfil its mandate more effectively. B. Modifications to the Responsibilities of the Federal and State Environmental Functions 22. Federal Responsibilities. To streamline environmental procedures, one approach is that institutions at the federal level play a coordinating function, and take on primary responsibility for establishing guidelines and procedures. Under this approach, the actual monitoring and implementation tasks would be conducted at the state and local authority levels with audits of these tasks being undertaken on a routine basis by federal representatives. 23. Complementing this, and to ensure that all development activity in Nigeria is sustainable, the following principles could be adopted: that permit or licensing structures De tied to Envircnmental Impact Assessments (EIAs) and associated economic analyses; and that an environmental assessment (EA) and review process be a routine component of government policy development and/or review. The environmental assessment and review process would normally consist of two principle components: an environmental assessment screening process; and an environmental impact assessment. The purpose of the EA screening is to establish what type of EIA should actually be done. This preliminary screening could be done, for example, by the Ministry of Budget and Planning as a routine component of its project selection. It would then be FEPA's mandate to establish guidelines for both the EA screening and the EIA 4/. It is expected that the actual EIA would be contracted out to the private sector, although some government departments (FEPA and State Ministries, for example) would require adequate in-house expertise to review the EIAs and to assess whether they conform to the recommended guidelines. 24. If the above measures were adopted, the federal level institutions would be responsible for: (a) establishing regulatory, monnitoring and enforcement guidelines; (b) establishing project and policy EA screening and EIA guidelines and developing the capacity necessary to 4/ The screening categories A-D which currently form the World Bank's screening guidelines would be an appropriate model for FEPA to use for the EA screening procedure. For those projects (A-B) for which an EIA is deemed necessary, the project proponent would be required to initiate an EIA. The principle that the project proponent is responsible for initiating the EA would be followed for all EA procedures, regardless of whether the proponent is in the public or private sector.  - xi - initiate and review them; (c) establishing a Federal Environmental Action Plan for execution by federal institutions; (d) establishing consistent guidelines for designing state and regional environmental action plans; (e) facilitating coordination of state programs and communication on environmental issues between jurisdictions; (f) conducting a review of federal policies which might have an impact on environmental integrity; (g) collecting, analyzing and distributing data of relevance to EIAs; and (h) liaising with international environmental interests. 25. Other available options with regard to modifying federal institutions are as follows: (a) The FEPA Board could have permanent representation from the Federal Ministry of Finance and Economic Development and the Feleral Ministry of Justice; (b) Protected Areas could be expanded to include a wider range of types of protected areas to allow efficient land-use, such as those recommended by the International Union for the Conservation of Nature 5/. The guidelines for establishing such areas could be set by the National Parks Department, FEPA or the NRCC, and federal institutions could participate in the management of the National Parks and the buffer areas around them; and (c) NRCC and FEPA representatives could be included in the planning of "Debt for Nature' swaps with members from the Federal Ministry of Finance and Economic Development, the Central Bank and the foreign donor community. 26. State responsibilities. Currently some states have a Ministry for Environmental concerns and other states work through Councils. The exact nature of the institutions used by the state governments will differ, but the capacity to carry out specific uniform functions should exist in each state. Technical assistance to develop the capacity to provide these services may be required. Further, government policy should encourage clear demarcation of responsibilities within and among the different institutions carrying out these functions. 27. In complementing the federal functions, it is proposed that the state institutions could be responsible for the following: (a) monitoring and enforcing industrial regulations and standards set Federally, and subject to Federal overview and audit. These may be supported by national economic mechanisms, such as fines, licensing fees, bonding and insurance requirements; (b) monitoring environmental conditions in rural areas and identifying programs which would decrease environmental degradation in those areas. It is proposed that the state be responsible for targeting direct transfers at the village level. The state could also assist LGAs to 5/ Currently, the only effective federal tegislation measures for protecting sensitive environmental areas (forests, wetlands, and game reserves) are contained in the proposed National Park Act. All other land-use decisions are made at the state levels.  - xii - develop their capacity for effective monitoring and assessment of local environmental conditions; (c) ensuring that all projects with potential environmental impacts within the state undergo an EIA process and recommending reforms or mitigative projects where desirable; (d) developing a State Environmental Action Plan, following the national guidelines, and identifying priority areas for action; (e) developing the capacity to react to environmental emergencies and to respond with appropriate actions. When implementing emergency action programs within the state, be responsible for monitoring the use of federal funds for such programs; (f) collecting, analyzing and distributing data of relevance to EIA, policy analyses and environmental monitoring within the state; (g) establishing appropriate ties with federal and local government authorities and delegating appropriate functions to the local level. 28. Legislative, Institutional and Programming Reforms. A large proportion of the laws of the country are derived from the English laws of the early 1900s and may consequently be obsolete or inappropriate to deal with present day conditions. A serious question is thus raised whether the existing legislative framework and the institutional structures associated with it are adequate in supporting the implementation of the objectives of the National Policy on the Environment adopted in 1989. Preliminary studies indicate that apart from the inadequacy of some of the existing laws, to deal with old problems, new environmental problems are not contemplated. In addition, there are substantial overlaps and conflicts among the laws enacted at the federal, state and local government levels. Often subsidiary legislation has not been issued to assist in the implementation of the enabling law. Penalties under most laws are uniformly low, and seldom enforced. With respect to the institutional framework, the responsibilities at the federal, state and local government levels are not clearly defined and there is often some overlap. The complex set of relationships created has led to a degree of shared responsibilities and functions which undermines accountability. 29. Legislative, institutional and programming reforms will be required in order to address effectively the environmental problems identified in the Report. As this would entail a massive law reform exercise in the environment related sectors, it is proposed that legislative reform should be initially restricted to the highest priority areas: soil degradation, water contamination, and deforestation. It is recognized that prior to commencing such reforms, the following activities are required: (a) zomplete an inventory of all the laws, regulations and other subsidiary legislation applicable to the priority areas; (b) review the pieces of legislation to determine whether the substantive provisions are consistent with the objectives of the National Policy on the Environment and to determine whether any gaps and overlaps exist with other related legislation; (c) review decisions of the courts which interpret the provisions of the relevant legislation; hold discussions and appraise the institutions responsible for the implementation of the legislation with a view to identifying problem areas which may be dealt with in the process of law reform; and, (d) determine which areas of the legislation need revision or whether legislation should be repealed, in which case the new legislation should be drafted taking into consideration whether it should be an independent piece of legislation or consolidated with other laws.  - xiii - 30. While the report has not concentrated on global environmental problems, it is important to note that Nigeria is signatory to a number of global conventions dealing with environmental concerns. There still exists in some instances, however, a need to pass domestic legislation which conforms to Nigeria's international obligations respecting environmental protocols. C. Economic Policy Initiatives 31. As mentioned earlier, quantitative estimates of the long-term losses to Nigeria from environmental degradation have been calculated to be in the region of US$5 billion annually in the absence of near-term mitigative measures. This figure highlights the need to take remedial measures on short term economic grounds alone. Major economic reforms under the Structural Adjustment Program have been successful in stabilizing the economy and have led to a resumption of economic growth. A new three year rolling plan has been formulated for the 1990-1992 period, taking into account the overall availability of domestic resources and foreign assistance. A long term perspective plan is also being prepared. It is crucial that these plans incorporate environmental concerns to avert further environmental degradation as well as a decline in economic well- being. 32. A general conclusion of the Report is that environmental integrity and economic well-being in Nigeria are complementary in the long-term. Policies which increase economic well-being are likely to provide added capacity for Nigeria to adjust to any environmental problem which it might have; policies which promote environmental integrity are likely to provide the necessary inputs of natural capital to support sustainable economic growth. Economic reforms can provide a potentially important contribution to Nigeria's environment. Some economic policies may, because of their far-reaching nature, result in negative externalities, particularly at the local level, which would contribute to environmental degradation. To minimize the negative consequences of such measures, and to take advantage of some of the potentially significant benefits of using economic policy instruments to promote environmental goals, a brief review was made of potential economic incentive mechanisms and economic policy initiatives with a view to identifying those which could be used most effectively in the Nigerian context. 33. Some of the economic incentive mechanisms which could be considered are the following: (a) Indirect Taxes and Subsidies: Direct interventions in the prices of inputs or outputs can be used to provide economic incentives to promote environmental policy. Producers as well as consumers can thus be forced to internalize some of the negative externalities caused by their activities. Where any indirect taxes or subsidies currently exist, it is important to evaluate whether their removal will improve environmental standards. Any reform relating to taxes and subsidies should concentrate on how their removal or imposition might enhance environmentally sound resource use such as sustainable land use,  - xiv - especially through sound agricultural practices and sustainable forest management practices. (b) Direct Transfers: Direct transfers are an appropriate mechanism for correcting distortions caused locally, by severe externalities and through broader policy initiatives. Direct transfers can also be used to compensate producers and consumers, who may be caused additional hardships through the pursuit of environmentally sound policies. The primary practical requirements are that the affected group is readily identifiable, and that mechanisms exist to transfer funds to these groups. Direct transfers could, for examplet (i) provide funds for installing pollution abatement equipment, targeted to existing polluters; (ii) provide targeted funds to rural dwellers where credit or price distortions are preventing intensive and efficient land use in environmentally sensitive areas; (iii) provide funds to rural dwellers for improving their local environment where it has undergone serious degradation in the past; and (iv) provide compensation for rural dwellers where other initiatives (such as national park projects) directly affect their immediate income. (c) Regulatorv Policies Fines. Fees, and Licenses: Regulations and standards that are not carefully monitored and enforced are subject to abuse. They should be used only where the institutional capacity exists to monitor and enforce them effectively (primarily in the industrial sector) through fines or fees. The general principle should be that the level of the penalty or fee should be proportional to the expected level of damage which will result from the pollution. For example, a fee structure with three components could be used: (i) a modest fixed charge which is applied towards funding the monitoring and regulatory process; (ii) an annual license fee which is proportional to the amount of effluent discharged in the previous year; (iii) for large industries, posting of an "environmental performance bond", sufficiently large to cover the costs of environmental damages if emissions or effluents exceed licensed amounts (this could also be required on all construction, oil drilling, and mining operations to ensure that the required reclamation occurs).  - xv - This system is consistent with national economic policies, has a sound economic basis, is consistent with the "Polluter Pays Principle", creates no drain on public funds, and is readily targeted to priority industries and areas. (d) Credit Policy: Lack of collateral at the small-holder level can, in some instances, accelerate environmental degradation especially when inappropriate production techniques are being used. Readily available credit can play an effective role in providing alternatives to producers and consumers in areas where current practices exacerbate environmental degradation. It is therefore proposed that a review be undertaken to determine in what manner institutional obstacles in the system, which prevent small farmer groups from accessing credit schemes, may be removed. Since the removal of institutional obstacles can mostly be achieved over the longer term, some targeted credit to small farmer and small business groups for example, women's cooperatives, may be justified. (e) Trade Policy: A number of trade policies have potential impacts on the environment and, at this stage, it is not possible to determine to what extent such policies are affecting the environment. It is therefore proposed that, to assist future policy decisions, a comprehensive review of Nigeria's trade policy be conducted from an environmental viewpoInt. It should concentrate on trade policies which might have the greatest impact on the priority areas identified in this Report: for example, the export ban on round logs; the lack of export restrictions on non-wood forest products; bans on textile and certain food imports; and trade in toxic chemicals, pesticides, and hazardous materials. (f) Public Investment Program: In the longer term, the EA process could be fully integrated into the on-going review of the public investment program (PIP). In the near term, it is proposed that two initiatives be pursued in this area to assist future policy decisions: (i) a review of projects in the current Three Year Rolling Plan to identify those which have a strong environmental impact. Those with positive impacts would form the initial basis for a project list for potential donor funding; those with negative impacts would form the basis for identifying complementary projects to offset the negative impacts; (ii) an enumeration and review of past and planned environmental expenditures in Nigeria to assist in determining whether enough is being spent in the conservation/environment area.  - xvi - D. Energy Policy Initiatives 34. Distortions in energy prices in Nigeria have a major impact on the level of energy related environmental effects. The most obvicus and universal impact is that through subsidizing petroleum products; their consumption is both very much higher and less efficiently managed, leading to an unevenly heavy burden of air pollutants detrimental to the health in heavily populated urban areas. 35. In the area of household energy, policy issues arise when private and social least cost solutions do not correspond, implying market imperfections, including pricing distortions and other constraints to the reflection of economic costs in market prices. Resolving market imperfections may require non-distortionary interventions and policy reform, including strengthening capacity to undertake required corrective measures. 36. Evidence indicates that target beneficiaries of the kerosene subsidy policy, the urban poor and the rural community, are either not beneficiaries at all or that the objective can be best served by alternative means. For example kerosene supply is far above conceivable levels of household energy consumption in the country. There are compelling reasons to increase kerosene prices and reduce demand, which include external and internal balance of payments issues, safety and economic losses resulting from adulteration with kerosene of higher priced gasoline, and smuggling. These concerns and associated implications for environmental integrity could be addressed in the Energy Pricing Component of the proposed Nigeria Energy Sector Study. 37. Further, Nigeria is one of the few countries in the African continent, where the superior cooking fuel LPG is available in quantities greater than foreseeable demand, for a cost substantially less than the market cost of fuelwood. Moreover, there is an aggressively competitive market for LPG, which is mostly dominated by the private sector, and sufficient private capital available in the country to expand distribution. The proposed Energy Sector Study could investigate further the need for pricing reforms and the regulatory framework for LPG market development. 38. In order to relieve pressures on woodfuels, it is proposed that the following options be considered: (a) de-linking of urban and rural fuelwood markets by displacing firewood and other biomass fuels with socially lower cost fuels inlcuding LPG if available and feducing the flow of firewood to urban markets to a sustainable level; (b) restoring the supply demand balance in rural areas which would include providing demand management opportunities (ex: improving cooking efficiency in rural households wherever possible) and augmenting the sustainable supplies of woody biomass for cooking purposes. The least cost means of meeting the cooking fuel needs of the rural and urban poor should be identified in the course of the proposed Household Energy Strategy. E. Establishing a Baseline Data Network 39. The current state of natural resources and environmental data collection and information management at all levels (federal, state and local) is very poor. Many of the maps used by federal and state agencies are outdated. A study carried out in the area of soil mapping revealed that  - xvii - most of the arable soil maps are of a very small scale and only show major soil distribution and soil association groups. Detailed soil surveys are limited to ad-hoc surveys on limited scale and scattered. With the reorganization of the Ministry of Agriculture and Natural Resources, it is hoped that more intensive soil survey and investigation programs will be conducted. 40. An up-to-date information system is vital for economic planning targeted at achieving sustainable development and to design and implement environmental policies and guidelines. The need for current information on natural resources and environmental concerns is recognized at all levels of government: federal, state, and local. The scale and resolution of environmental data collection vary with the level of management programs and with the type of environmental problems in the respective regions. 41. Towards the establishment of an environmental data network which is dynamic and flexible to monitor changing environmental patterns, the following steps would be required: (a) FEPA could establish the technical guidelines for natural resources data collection and management in close collaboration with the line agencies and relevant institutions. A technical information committee could be formed under the chairmanship of FEPA to develop these guidelines. (b) The environmental information network could be established alorg the lines of nodes and subnodes proposed in the Report. The level, scale, resolution and periodicity of monitoring would depend on the particular layer end the resources available. (c) The technical information com.ittee could set priorities and propose tentative work programs that are agreeable to their own line agencies responsible for collecting the information needed. The priorities would lead to a strategy for implementing feasible short and medium term contributions to the baseline data in the network. 42. A working paper is being prepared by a team of consultants who have commenced a review of the status of natural resources and environmental information in the different line agencies at federal, state and local levels. The paper would recommend programs for filling the data gaps identified. F. Local Initiatives to be Encouraged 43. Targeted programs will be required to address many of the environmental problems encountered at the rural level. These programs may include initial direct transfers to promote local environmental initiatives (such as seed funding to improve access to credit in environmentally sensitive areas, compensatory payments where the establishment of protected areas leads to short-term rural income los1,as, or shelter-belt planting projects). While many rural development initiatives are currently underway in Nigeria, none focuses on environmental issues. One function of the state level 'rural operations divisions, could be to target transfers to environmentally sensitive rural areas to fund state investment prngrai.z towards intensified sustainable development.  - xviii - G. Education and Public Awareness Programs 44. Significant progress has been made in environmental education. A draft proposal for a National Conservation Education Strategy has been submitted to the Federal Ministry of Education for adoption as part of the National Policy on Education. It is expected that an environmental component would be incorporated into the National Policy on Education; the education curriculum is already in some aspects "environmentally sensitive". There are, for example, State Environmental Education Coordinators in each of the 21 states. They have been involved in organizing and implementing educational programs either in coordination with the Nigerian Conservation Foundation (NCF) or by themselves. Some states also have established conservation education centers. An example is the education center set up in the local government headquarters in which the Cross River National Park is situated: an education program on conservation issues is being coordinated there with the assistance of NCF. It is proposed that, in order to augment these programs an environmental education unit and a conservation/environmental center be established within each state. Other proposals include: (a) establishing an environmental education divisicn within the Federal Ministry of Education; (b) initiating a national environmental awareness campaign by the Federal Ministry of Education; and (c) establishing as an extra-curricular activity at the community level a "Conservation Club Program" that includes development, provision and distribution of print and non-print media, and liaison with foreign environmental organizations for specific project funding and technical support. To assist in long term planning, it is recommended that an implementation plan be propo-ed for the establishment of environmental education units in the states. H. Debt for Nature Swaps 45. The "debt-for-nature" swap involves suspension or elimination of debt obligations in exchange for diversion of service payments towards environmental initiatives. Experience in other countries suggests that NGO's are an effective vehicle for identifying and managing the start-up of long-term projects initiated by these swaps. To pursue more extensive use of this option would require that: (a) FGN gives support in principle to the use of "debt-for-nature" swaps to promote environmental concerns; (b) liaison officers be designated within the NRCC and FEPA to participate in discussions with the Central Bank, the Federal Ministry of Finance, local NGO's, and foreign donors; and (c) technical support be provided to NGO's to participate in this process, until the necessary resources are mobilized through the process.  - xix - 1. Sectoral Projects and Areas for Policy Review in Environmentally Sensitive Areas 1. Soil Degradation and loss 46. Soil degradation and loss has been identified as a serious environmental problem affecting the country, both in terms of its economic impact as well as the number of people affected. The prevailing problem is identified in many cases as a direct result of the breakdown of traditional fallowing practices in the face of increasing population pressure on the land. It is recognized that in order to avert a crisis of considerable magnitude, mitigative actions are required urgently. 47. A number of appropriate soil conservation practices were identified by FAO/CP (1990) 6/. Some low cost solutions are of particular interest, to the extent that they avoid the need for large amounts of credit. Priority should be given by Agricultural Development Programs (ADPs) to designing an implementation plan for the development of additional support services. These support services would focus on including soil conservation and land management advice within the extension services of the ADPs. This plan would include (a) an assessment of the differential intensity of support needed in the various states and (b) training requirements for subject matter specialists and extension agents. 48. The informal, traditional lana tenure system of communally managed resources provided, in most cases, an effective mechanism for efficient use of these resources. It is recommended that, where possible, the existence of such informal tenure systems be identified and used to advantage in designing environmentally appropriate land-use systems. 49. In order to develop a strategy for long-term policy reforms to limit soil degradation, the following areas need to be examined in more detail: (a) Investigation of the use of "off-farm' land resources (non- gazetted forest and woodland, tree and shrub grassland and uncultivatable land) 7/; (b) Examination of the economic implications of resource degradation, demonstrating the costs and benefits of recommended technologies to society as well as to the farmer; (c) Examination of the institutional arrangements for a program of land resource management; and (d) Development of proposals for a National Conservation Strategy. These areas would be addressed by the proposed Nigeria Land Resources Management Study (Phase II). 6/ FAO/CP, NiReria, Soil and Water Management Study, 1990. 7/ Ibid.  - xx - 2. Water Contamination 50. Poor sanitation and waste water treatment, inadequate solid waste disposal and stormwater drainage, weak institutions and poorly located water supply intakes have been identified as the key problems affecting water quality, and presenting significant water pollution problems and potential health threats. 51. The contamination of water resources in Nigeria has been caused by the discharge of untreated domestic and industrial waste water into water bodies, affecting downstream water supply in urban and rural communities. Pollution has also affected riverine and marine eco-systems in two important ecological zones -- in the Lagos lagoon (through industrial and domestic pollution) and in the Niger delta area (because of oil spillages). In many of the urban areas risks of contamination extend not only to surface water, but also to ground water because of relatively high water tables. In Lagos, for example, the water table is between one and three meters below the land surface, and leaching of solid wastes and septage is a public health risk for the large urban population dependent on groundwater supplies. 52. In all of these cases, it is stressed that urban problems have to be viewed holistically, rather than in terms of individual sectors. In this light, urban sanitation issues could be subsumed under a broader urbar. community development approach for on-site project execution. Under this approach, the government, private sector and local community function as partners in i.entifying, implementing and maintaining on-site infrastructural programs. Public amenities in poor settlements are improved with local participation in both the construction and maintenance phase. A preventive health care component - by which local women workers train other women in household sanitation practices and advise them on when to seek medical care - can be simultaneously introduced. This low cost component also enables a city to maintain current data on morbidity trends. A third component could be an informal sector credit program modelled on the Small Scale Enterprises Program of Calcutta cr BKK Program of Java. 53. To counter water contamination, it is proposed that specific action be pursued on three broad fronts. First, economic incentives be designed through the fiscal system for reducing pollution by industries, petroleum and mining companies. Second, national legislation to regulate the discharge of pollutants into water, land and atmospheric resources of the country be enacted. Along with this, institutions at the federal, state and local levels of Government be strengthened to monitor and enforce compliance of the proposed national environmental standards. Third, the forthcoming Urban Sanitation Strategy and Action Plan (USSAP) be used to develop a national program, within the urban policy framework, to tackle the complex problems of drinking water contamination, drainage and waste water disposal in Nigerian cities. 3. Air Pollution 54. Rapid expansion and diversification of industry in Nigeria, oil and gas production, refining and consumption, and emissions from poorly maintained vehicles, have also contributed to the poor atmospheric quality in urban industrial centers in the country.  - xxi - 55. To address pollution from existing facilities, one option is to target technological interventions to primary polluters; such interventions will, for example, involve retrofitting pollution abatement equipment. The overall implications of the experiences gained in industrial pollution control in other countries indicates that pollution abatement can be effectively accomplished within a short time fr; a, if certain economic incentives are provided and adopted. Sb. The options available, include, typically, a rigorous enforcement program and control mechanisms, complemented with economic incentives to induce polluters to refrain from continuing these practices. A specific alternative relates to those industries causing serious air pollution: these industries could retrofit pollution abatement equipment on their existing facilities in the near-term. Direct funding or tax incentives may be required to support this. 4. Pollution Through Industrial Effluents 57. Industrial expansion in Nigeria has taken place without much attention being paid to the implications of industrial activity on the environment. Industrial waste treatment systems are almost non-existent, and the few treatment plants installed at some industrial sites are either technically incapable of handling the huge industrial wastes discharged by these industries or have broken down. Further, legislation for controlling industrial effluents has only recently been drafted by FEPA. Hazardous waste disposal, water pollution resulting from liquid industrial effluents, and air pollution from gaseous and particle emissions constitute the three primary aspects of industrial pollution. 58. Industrial pollution control in Nigeria will involve a three- pronged approach relying on: (a) the implementation of incentive systems that will induce the adoption of these te,hnical/physical measures to reduce industrial discharges; (b) the implementation of cost effective technical/physical measures to reduce the discharges from industry. (c) the strengthening and reform of existing institutions. This includes coordination and integration among the various relevant state agencies responsible for environmental planning, enforcement, monitoring and the imposition and implementation of incentives required for waste/residual minimization; and 59. To assist future policy development, each state could prepare a short-to medium-term strategy which establishes and addresses the priorities of its pollution problems in an effective and economically feasible manner. In order to do so, the state would need to: identify its industrial pollution problems; complete an inventory of sources of industrial emissions; develop an inventory of monitoring capabilities; and, determine the current institutional capacity and evaluate any specialized training needs.  - xxii - 5. Deforestation 60. Deforestation is identified in the Report as one of the top priority environmental problems in Nigeria. The Tropical Forestry Action Plan (TFAP), which is supported by the World Bank and the FAO and which commenced work in 1990, will address a number of important long term concerns. To avoid duplication with the TFAP, the efforts of any environmental initiative should concentrate on actions which could be undertaken immediately, yet would not interfere with the long-term goals of the TFAP. 61. For example, some specific options for addressing deforestation concerns include: (a) establishing tighter controls on fuelwood extraction from the reserved forests; (b) ensuring that management of forests outside reserves be coordinated with activities in the forest areas. Existing systems governing the harvesting and sale of timber and fuelwood from forests outside of forest reserves are inefficient and inadequate for the protection and regeneration of the resources; and (c) adopting recommendations contained in the forest revenue systems study for Nigeria. 8/ Royalties and related charges are very low and evidence suggests that they have been much less than what the market can bear. Low charges not only constitute loss of revenue to the governments but in most cases create pressures from timber contractors to obtain large timber concessions at relatively cheap rates. 62. To assist future policy development, it is recommended that studies be undertaken to (a) provide a comprehensive review of the forestry fee system; (b) assess the non-wood forest product utilization and export strategies; and (c) assess what role the local communities could play, in forest resource management. In addition, it is anticipated that the proposed Nigeria Forestry Sector Analysis complementing the TFAP will, at an early stage, identify projects of significant potential in environmentally sensitive areas. 6. Gully Erosion 63. Gully erosion is best addressed through a combination of land use/biological and engineering approaches. The immediate cause of many gullies is the concentration of water because of poorly designed engineering structures, e.g., roads, buildings, etc. and remedial measures will include steps to spread or divert into "safe" channels the water flow. At the same time, measures are required to stabilize the perimeters of gullies (e.g., ensuring the maintenance of permanent vegetation within several meters of the gully and, to the extent possible, within it) and the maintenance of permanent vegetation along water courses and the adoption of 8/ Report on the Forest Revenue Systems Study for Nigeria, Federal Ministry of Agriculture.  - xxiii - appropriate agricultural practices, e.g., contour planting and use of vegetative barriers to minimize runoff and concentration of surface water. 7. Fisheries Loss 64. Most fisheries losses have resulted from habitat loss due to industrial pollution, upstream deforestation, and the construction of upstream dams. There are presently no near-term policies available for restoring fish stocks in natural habitats. Long term re-establishment of natural fish stocks would, however, be assisted by the promotion of short term aquaculture development projects in environmentally sensitive areas. Policies and economic mechanisms which encourage the development of aquaculture and fisheries could be designed and introduced. Moreover, public education programs could be developed to teach new fishing techniques which have less of a negative impact on the fisheries industry. Over the long term, most effective policy options will involve industrial and construction controls coupled with economic incentives to limit effluent. 8. Wildlife and Biodiversity Losses 65. As the major direct causes for wildlife and biodiversity loss involve ht.iting and habitat loss, any short-term actions will generally require direct intervention to protect remaining resource stocks, perhaps using local NGO's. The increased use of the IUCN protected area classifications would provide an important start to improving wildlife and biodiversity protection. It will, however, be difficult to provide complete protection until policy commitments and economic incentives are put in place to reinforce the protected areas. At present there is little institutional support for promoting the economic benefits of biodiversity. Some options available to improve this situation are: (a) allowing activities which promote the export or local sale of sustainable harvested products tied to promoting biodiversity (such as butterfly pupae, traditional medicines, minor forest products) to be included within programs such as the Small and Medium Enterprise Project financed by the World Bank; (b) encouraging research (Nigerian or Joint ventures with foreign participants) into products which promote biodiversity; and (c) strengthening, patenting and licensing systems to protect research more effectively in natural products that may result in commercial product development. 9. Coastal Erosion 66. Reclamation projects may be justified in some cases, but as with gully erosion, they should be considered as a technical option only if the reclamation procedures do not pose an additional threat. In cases where only partial erosion has occurred because of past improper construction techniques, reclamation and preventive measures could be considered to control the situation. These might include investments in breakwaters or artificial reefs. Over the longer term, controls, guidelines and economic incentives (such as performance bonds) cculd be used to minimize the impact  - xxiv - of coastal erosion. A potentially broader approach is to develop a "Coastal Zone Management Program" for Nigeria. 10. Water Hyacinths 67. The primary options for addressing the water hyacinth problem which currently exists in the rivers of Nigeria will be through direct intervention (such as mechanical harvesting). Direct projects could be targeted first to combat the water hyacinths in the most critical areas. Studies should also be undertaken to determine the causes for water hyacinth propagation in Nigeria's waterways. 11. Gas Flaring 68. Environmental and economic costs of gas flaring have not been accounted for in the Report since these costs are largely global instead of being national. FGN is already pursuing all economic uses of natural gas. Giving due consideration to the global warming impact of large scale gas flaring, this effort can well be strengthened and accelerated with donor assistance. IV. CONCLUSION 69. The report provides a framework for developing a better understanding of the linkages between the environment, national economic policies, and sectoral work. It prepares the groundwork to assist in the development of a set of policies which will address the environmental problems in Nigeria. I 70. In general, policymakers in Nigeria are faced with five broad long-term approaches to addressing the environmental problems facing the country: (a) strengthening of institutional capacity; (b) initiation of legislative reforms and policy initiatives to address the environmental problems identified in the Report; (c) development of economic incentives and mechanisms to promote environmental management; (d) establishment of a national environmental data management system; and (e) creation of significant educational and public awareness programs. 71. While in many cases the political will exits to pursue long-term policies in the interests of ameliorating environmental problems, substantial research and analysis will still be required to guide policy formulation and to complement the evolution of institutional roles within Nigeria. Near-term efforts must therefore concentrate on initiating research and analysis, through specific sectoral studies, and on integrating the results of these analyses into the decision-making framework of policy-makers in Nigeria.  CHAPTER I. INTRODUCTION 1.01 The purpose of this Report is to develop a meaningful framework to assist in the analysis, evaluation, and discussion of the inter- dependence between the environment and the economy in Nigeria. Nigeria in many respects typifies the "nexus" which arises as growing population, increasing agricultural demands, and environmental pressures exacerbate each other under conditions of high population density which, in turn, threatens economic, social and cnvironmental sustainability over the long run. The Report identifies selected reforms and projects which are thus consistent with the principle of "sustainable development". While there are a number of definitions of sustainable development, many do not provide a useful operational focus in a developing country context. For the purposes of this report, sustainable development is defined as: "Projects and policies which prorrote per capita economic growth without jeopardizing the integrity of the physical stock of renewable and environmental resources." 1.02 This Report is based on an extensive review of relevant materials written by the various World Bank sector divisions over the last few years as well as findings of a major Environmental Mission in May-June 1990. In addition, the Report relied on other works written by Nigerian experts, environmental economists, and international organizations as well as on interviews with Bank staff, FGN officials, and others familiar with Nigeria. Where information sources were incomplete or where protracted analysis is required, additional work programs are suggested. The Report builds on the earlier Bank work undertaken by a Bank Consultant in 1988. 2/ The Overseas Development Administration (ODA), U.K., completed a major study in May, 1990, that identified the key environmental issues facing Nigeria and provided recommendations concerning the institutional framework of the Federal Environmental Protection Agency. 1.03 Rather than duplicate other efforts, this Report first seeks to provide an assessment of Nigeria's environmental priorities and an identification of options for mitigating the impact of environmental degradation in the country. The contents of the Report include: (a) a review of the current factors influencing environmental degradation in Nigeria; (b) an examination of the substantive provisions of existing legislation, federal, state and regional policies and institutions which focus specifically on environmental issues; 2/ Ludwig, Harvey F., "Nigeria: Proposed Environmental Action Program," March 1988.  (c) a general discussion of the impact of economic policies on the environment; (d) a geo-physical assessment of the environmental quality of each ecological zone as it affects the assessment of the state of the environment in Nigeria as a whole as well as a brief description of environmental problems common to most zones; (e) an identification of the key environmental concerns in each ecological zone with an explanation as to the probable causes (both direct and indirect) of these developments; (f) an explanation of specific local distortions indirectly caused by broader economic considerations; (g) the development of a preliminary rationale for taking action to mitigate environru-.tal degradation. The Report provides a formal framework for ranking environmental priorities and concerns according to various indicators of sustainable development (Annex I - Economics and the Environment: Sustainable Development Goals and Criteria); and (h) an outline of options to redress the environmental imbalance which currently exists. In order to select the options best suited to the current economic, social, and political situation in Nigeria, evaluation criteria and required reforms are established and applied to the options. 1.04 The Report provides some preliminary analysis in the Nigerian context, of the economic losses, if measures to mitigate environmental degradation were not adopted. A specific objective of this report therefore, is to demonstrate the complementarity between economic considerations and environmental quality. Economic growth, for example, will provide important financial resources for investments which promote environmental integrity. Adjustment policies which promote growth without threatening the integrity of natural and environmental capital can thus contribute importantly to long-term environmental integrity and, hence, to human well-being. 1.05 However, existing policies in Nigeria have, in some cases, incidentally contributed to environmental degradation. Some, because of inappropriate incentive structures, can be reformed through direct intervention. For example, the lack of incentive mechanisms to ensure reforestation has often resulted in forest loss. Others are due to local distortions brought on by important, broader, national economic policy initiatives which are not properly accounted for by the policy-makers. For example, in some circumstances, tight credit markets can divert farm activity from intensive practices to those at the extensive margin. While it is not appropriate to introduce wholesale changes in these policies,  targeted reforms are possible that minimize the adverse local environmental effects of these policies. 1.06 Economic mechanisms can be used in a proactive manner to protect environmental resources. For example, disincentives such as fees and fines, as well as positive incentives such as direct transfers or input subsidies can be effective. While some mechanisms do impose some direct requirements for public expenditures, those with no net impact on government revenues are of particular interest. 1.07 Economic techniques can be used to determine how different categories of environmental investment should be evaluated. The Bank has a four-part project classification (Classes A-D) for categorizing environmental projects subject to environmental assessments. To this classification, is added a "Class PI in this Report, which relates to environmentally relevant policies rather than projects. Within this context, reactive evaluation procedures will normally be required at the appropriate decision-making levels within the country, which provide environmental and economic assessments. 1.08 An implementatior. program will require appropriate policies, economic incentives, operational guidelines, and public understanding and awareness at the local, regional and national levels. The Bank is committed to supporting the initiatives of FGN and endorses the philosophy of sustainable development, recognizing the interdependence between economic development, social equity, and resource integrity required to achieve global harmony and prosperity.  - 4 - CHAPTER II. BACKGROUND A. Economic Structure. Background and Prospects 2.01 Nigeria enjoyed considerable macroeconomic growth during the 1970s on the strength of oil sector exports. Real GNP increased by about 150 percent over the second half of the decade, allowing Nigeria to reinvest its export earnings into improved domestic infrastructure and services. Further, on the forecast strength of future export earnings, Nigeria was able to finance borrowing initiatives which further heightened domestic investment and government spending. Entering into the 1980s, however, the collapse of petroleum and cocoa prices in international commodity markets undermined Nigeria's income base and, coupled with escalating interest rates, the economy started to stagnate in the early 1980s. Persistent soft commodity markets and high interest rates eventually resulted in massive real declines in GNP over the 1980s. GNP declined 75 percent between 1981 and 1987, and in the process effectively converted Nigeria from a "middle income" to a "low income" country. 3/ Debt service payments have thus continued to grow as a percentage of total domestic production: debt service is projected to be 35 percent of export earnings in 1990, 11 percent of GDP, and almost 50 percent of government expenditures. The total debt is currently about US$30 billion: approximately equal to the country's GDP. 2.02 In response to declining economic fortunes, the government reacted by instituting a structural adjustment program (SAP) in mid-1986. The overall decline in GNP has stopped since 1986, although real wages continue to fall. Nigeria's growth through the 1990s is targeted to be about 5 percent per year, which, given population growth in excess of 3 percent annually, will allow for only modest increases in per capita GDP. Given the strong dependence on the petroleum sector, however, realization of this target will be dependent, in part, on exogenous trends in petroleum prices. Much of the medium term growth is forecast to be driven by new investment which will cause construction and manufacturing to grow by about 8 percent annually on average and, appropriately, merchandise imports are forecast to stay strong. Outlining a demanding strategy for agricultural growth, over the medium term, in excess of the population growth rate, the recent report on Agricultural Growth in Nigeria 4/ concludes that a growth rate of 4 percent per annum could be achieved within the next 5 years. 2.03 The SAP, introduced in 1986, was a response to falling oil prices and the sharp downturn in economic growth. It is intended to liberalize the trade and payments regime and increase reliance on the 3/ GDP in 1989 consisted of: Agriculture 31.6Z; Manufacturing 8.6Z; Construction 1.42; Services 26.3Z; Petroleum 29.8Z; Indirect Taxes 2.32. 4/ World Bank, Nigeria: Strategy for Agricultural Growth, December 1989, Report No. 7988-UNI.  provision of goods and services by the private sector. Policy formation on the environment must be taken within the context of the overall framework of SAP, so that the two are mutually reinforcing. This can be accomplished by identifying economic adjustment mechanisms and policy instruments to create the incentives to change attitudes and behavior consistent with environmentally sound economic growth. 2.04 The most significant, and perhaps least obvious, positive contribution which SAP has made to the environment in Nigeria arises from the important complementary linkages which exist between economic productivity and environmental integrity. Under conditions where capital formation is not very productive, such as those which existed even in the oil-boom years before the mid 19809, individuals, companies and governments fail to retain the financial resources which would facilitate undertaking environmentally benign investments. The adjustments initiated by SAP have, in principle, provided the required economic climate for investing in sustainable activities. In general, therefore, the adjustment process is positive for long-term environmental integrity. There are, however, some instances in which broad economic policies create distortions which are detrimental to the short-tenm environment. To an extent, such negative side effects are inevitable if the productivity of the economy is to be raised. The implication simply is that, part of the increase in economic growth will have to be invested to offset the negative side effects of productivity enhancing economic policies. The following paragraphs provide some examples of side effects, which may need to be offset through targeted environmental policies. 2.05 In a move to market-based pricing, SAP initiatives have generally promoted the deregulation of domestic prices for all but a number of selected strategic commodities (such as petroleum products). The most notable price deregulation has occurred in the agricultural sector where farm-gate input and output prices have increased by as much as four-fold for some items. Although in some circumstances this has resulted in short-term farm losses when output price increases lagged input price increases, the general impact has been to improve rural incomes as the economic incentive to increase production has been strong. This increase in income increases the potential pressures on rural land resources and, although to an extent dependent on factor proportions and the choice of technology, by implication places an additional burden on certain environmental resources. The price adjustment has been accompanied by fiscal and monetary interventions to ensure that inflation does not get out of hand during the adjustment process. 2.06 SAP has also attempted to increase non-oil export revenues. Cocoa prices to domestic producers, for example, have been at historically high levels even though international cocoa prices have been at their lowest levels in years. From an economic perspective, this program has a number of merits: (a) it encourages exports; (b) it diversifies production; and  (c) it redistributes income to the traditionally poor rural sector. From an environmental perspective, however, the program potentially contributes to increased environmental pressures as high prices provide incentives to increase land-use without due attention being paid to ecological concerns. For example, the encouragement of cocoa exports has resulted in new pressures on the rainforest. 2.07 The small-holder sector, where many of the current incentives to increase output exist, has only limited access to credit in Nigeria, largely due to lack of collateral, the high cost of lending in rural areas, and overall tight monetary policies coexisting with a small deposit base. When faced with incentives to increase production, intensification of current efforts is often not possible in the absence of access to credit facilities. In some areas the use of inappropriate production technologies of increasing production can be expected to increase pressure on marginal land resources and create commensurate environmental pressures. In the long run financial sector reform measures undertaken as a part of the structural adjustment effort are expected to remove institutional obstacles which prevent smallholders from accessing credit supplies and credit would be allocated in response to economic criteria which would increase the deposit base. This would encourage the use of appropriate technologies and thereby contributing to proper management of scarce resources and to increased small-holder investment. 2.08 An important component or SAP is to promote diversification away from the petroleum sector. Petroleum exports represent about 90 percent of Nigeria's export earnings. First, diversification will decrease the single sector dependence and thus decrease the potential fluctuations in economic performance; planning is thus simplified. Second, distributional equity is improved as other regions, sectors and individuals will benefit directly from diversification rather than just those involved in the petroleum sector. As a result of diversification initiatives, decreases in rural income and production are expected to be halted as private producers take advantage of economic incentives to increase productivity. 2.09 Although population increase and improper resource management are often cited as the primary structural causes for environmental degradation, the growth profile and certain economic factors in Nigeria will also influence the pressures on the country's environmental resources. Examples are: (a) diversification and price deregulation will increase rural incomes and thus could slow, or even reverse migratory trends to the cities and alleviate some pressures on urban requirements, but increase pressures on rural land rescurces; (b) in the absence of targeted land-use intensification programs, persistent tight credit may prevent smallholders from investing intensively and may result in more extensive land use; and  (c) expectations of future growth driven by new investment (especially construction and manufacturing) will tend to accentuate some "industrial" environmental problems. B. Legislative and Institutional Framework 2.10 Nigeria is a Federation of 21 states which are comprised of 450 local government authorities. There is a Federal Constitution which determines the areas of jurisdiction for each level of government. Laws have existed on many aspects of environmental issues from the time of amalgamation in 1914. Some of these are still in effect in different parts of the country and as such, their objectives may not coincide with those set forth in the National Policy in the Environment adopted by FEPA in 1989. 2.11 Federal Actions. Conservation of valued natural resources is accorded priority in the Constitution of Nigeria. While there is no specific constitutional provision dealing with the environment, section 16(2)(b) provides that the State shall direct its policy towards ensuring that the material resources of the community are harnessed and distributed as best as possible to serve the common good. Section 17(2)(d) provides that the exploitation of human and natural resources in any form whatsoever for reasons other than the good of the community shall be prevented. These two constitutional provisions come under Chapter II which deals with Fundamental Objectives and Directive Principles of State Policy. As such, they are goals or aspirations which the country is expected to strive to achieve. 2.12 Nigeria championed the cause against importation of hazardous industrial wastes and contaminated foods at the Organization of African Unity (OAU) in May 1988, and at the Summit Conference of the Economic Community of West African States (ECOWAS). In furtherance of the Resolutions adopted at the conference, prohibiting the importation and dumping of wastes in the African region, FGN promulgated the Harmful Wastes (Special Criminal Provisions etc.) Decree No. 42 of November, 1988. Nigeria has also been an active participant in other international conventions besides the Hazardous/Toxic Waste Convention. Examples are conventions such as The Convention on International Trade in Endangered Species (CITES), the Africa Convention, and the Heritage Conservation. Although Nigeria is signatory to many international treaties in the field of the environment, many of these treaties have not yet been enacted into law as required by Section 12(1) of the 1979 Constitution. 2.13 FGN's commitment to the preservation of natural resources and the protection of the environment is evidenced by the promulgation of the Federal Environmental Protection Agency (FEPA) Decree (No. 58, December 30, 1988) and the Natural Resources Conservation Council (NRCC) Decree (No. 50, December 29, 1989.) FEPA is given the function of advising the FGN on national environmental policies and priorities, and on scientific and technological activities affecting the environment amongst other responsibilities. NRCC on the other hand has the responsibility for coordinating matters concerning the conservation of natural resources.  - 8 - 2.14 The NRCC is expected to concentrate and focus on the coordination of all matters pertaining to the conservation of the eco- systems in the country. It has the power: (a) to monitor the activities of the various natural resources conservation agencies with regard to implementation of their respective programs and projects; (b) to resolve any conflict that may arise; (c) to take fiscal measures to encourage conservation of natural resources; (d) to designate sites and species of conservation interest; and (e) to develop programs to minimize the erosion of the national coastline. 2.15 The mandate of FEPA is targeted towards preventing atmospheric pollution, issuing guidelines, and setting criteria and standards for monitoring air and water quality, effluent limitations and atmospheric protection. The mandate of NRCC is targeted towards conservation issues. As previously mentioned, FEPA was assisted by the ODA in the development of a Master Plan and Action Plan on Environment, and UNEP assisted in the formulation of a National Action Plan on Sustainable Development. 2.16 FEPA has commenced work on establishing a new Headquarters at Abuja, a Central Laboratory in Lagos and six Zonal Laboratories at Jos, Abuja, Benin-City, Kaduna, Kano and Port-Harcourt. It is expected that both the Central Laboratory as well as the Zonal Laboratories would be functional in the very near future. FEPA has also initiated two projects in collaboration with researchers from two Federal Universities to establish a network of seven permanent air pollution and air-borne radiation monitoring stations, and to conduct a systematic study of dust pollution and health-related hazards. 2.17 Towards the furtherance of its commitment to provide all Nigerians with an enhanced quality of life through environmental protection and conservation of natural resources, FGN formulated a National Environmental Policy on November 27, 1989 with the achievement of sustainable development in Nigeria as its objective. The Policy has been drawn up with a deeper appreciation of the interdependent linkages among development processes and the multi-disciplinary and multi-sectoral nature of environmental concerns. The Policy provides for detailed guidelines and strategies to be drawn up by the respective authorities for attaining national environmental goals in all the vital sectors. 2.18 In terms of resource allocation, FGN has allocated a sum of N500 million annually for a period of two years to FEPA, to be used for the establishment of the required facilities and for its infrastructure to become fully operational. In addition, 1 percent of the Federation Account is allocated towards an Ecological Problems Fund (EPF), which finances programs for both temporary and permanent alleviation of pressing environmental and ecological problems. 2.19 Over the last twenty years, numerous legislative enactments and regulations have been passed at the Federal, State, and local levels which contain provisions having a bearing on environmental concerns. The main protective legislation at the Federal level for the conservation of sensitive environmental areas is contained in the National Park regulations while all other land-use decisions are vested with the State governments.  (The major enactments and regulations and the relevant provisions in the various sectors are discussed in detail in Annex III - Legislative Summaries.) 2.20 State Actions. At the state level, the FEPA Decree encouraged the States and Local Government Councils to set up their own Environmental Protection Bodies. Under Section V of the National Policy on the Environment (Institutional and Intergovernmental Arrangements), a National Council on the Environment (NCE) was established to facilitate cooperation and coordination between FEPA and the states. It is mainly through the NCE that FEPA will address specific state environmental problems. The states in turn monitor their own environment through their state "bodies" which include representation from local governments. 2.21 Different states have different environmental priorities reflecting the different environmental conditions among them. Anambra is a good example of one state which, faced with serious sheet and gully erosion, established a Task Force on Erosion. In Anambra, a Directorate for Environmental Protection and Management operates under the direct control of the Governor's office and cooperates with FEPA and other international organizations. There are other states which have initiated or are in the process of initiating such Task Forces and committees; they have expressed great interest in formulating their own State Environmental Action Plans. (The World Bank is currently investigating the possibility of assisting these states in tackling environmental concerns under ongoing State Agricultural Development Projects.) 2.22 The Role of Non-Governmental Organizations. The role of NGO's in dealing with environmental issues is significant as has been demonstrated in many countries around the world. They are often able to obtain funds both from their national governments as well as from international sources. Moreover, they are able to raise public awareness on many significant issues. 2.23 In Nigeria there are several prominent NGO's which have an important part to play in advising FEPA and NRCC. They include: National Universities Council (NUC); Manufacturers Association of Nigeria (MAN); Nigerian Academy of Sciences (NAS); Forestry Association of Nigeria (FAN); Nigerian Environmental Society (NES); National Chamber of Commerce and Industries (NCCI); and the Nigerian Conservation Foundation (NCF). 2.24 It is of vital importance to Nigeria that NGOs receive support and are encouraged to participate actively in environmental policy and operations in Nigeria. The NCF is one of the major NGOs which has been active in bringing conservation issues to public and official attention, publicizing issues like illegal trade in endangered species and protection of forests and soils from abuse. NCF was instrumental in getting the National Conservation Strategy and the National Conservation Education Strategy passed by the government, and it holds a seat on the NRCC. NCF has been responsible for the implementation of the Okomu Forest Project in Bendel State and the Nguru-Hadijia Wetlands Project in Kano/Borno as well as the Oban Hills Park Project in Cross River State. Recently NCF has been  - 10 - successful in opening a Conservation Education Center on the Lekki Peninsula. 2.25 NCF has also been the proponent of: (a) building a national conservation center and developing a public awareness program; (b) providing management support for the game reserves at Yankari in Bauchi State and Gashaka Gumti in Gongola State; and (c) developing integrated management plans for the Lake Chad Basin Wetlands. 2.26 The Role of Gender in Development. The need for the effective involvement of women in the development and execution of the programs and policies to guide efforts aimed at sustainable development is well recognized. In all of the key economic sectors, they play essential roles that may unknowingly challenge environmental quality. The Bank and FGN have recently completed an Assessment Report on Nigerian Women that encompasses a plan of action to assist decision makers on how to involve Nigerian women in the design, execution and maintenance of projects and programs for Nigeria's economic development. The objectives of that report and those of sustainable development are complementary and reinforcing (Annex VII - Gender and the Environment).  - 1i - CHAPTER III. GEO-PHYSICAL REVIEW BY ECOLOGICAL ZONE A. Introduction 3.01 Nigeria is situated in West Africa bordering the Sahel desert in the north and the Bight of Benin in the south. The climate ranges from dry/arid to moist tropical with corresponding vegetation of desert/savannah to tropical rainforest. The estimated population for Nigeria in 1990 is 113 million people; Nigeria accounts for one in five Africans today. There are 450 tribes, speaking 395 different dialects or languages. The total land area is about 91.1 million hectares, of which 34 percent is used for crops, 23 percent is used for permanent pasture, 16 percent is forests and woodland, and 26 percent is in other uses. About 17 percent of the land area is developed for residential, commercial, industrial or other .infrastructural construction. 3.02 In order to reflect this diversity and assess the environmental priorities in Nigeria in a pragmatic way, four principal zones were identified. Three of the zones are based on a simplification of the agro- ecological zones as proposed by the Overseas Development Natural Resources Institute (ODNRI). 5/ An additional ecological zone, characterized as "urban" has been identified in this Report as it contains unique problems os its own. ZONE INCLUDES 1. Southern Zone Very humid and flood areas. 2. Northern Zone Semi-arid and dry sub-humid areas; part of the sub-humid area with the southern border being taken as the northern limit of bimodal rainforest. 3. Mid-Zone Humid area plus part of the sub-humid areas up to the northern limit of bimodal rainfall. This zone includes all of the Plateau areas in central Nigeria. 4. Urban Zone All Urban areas with populations greater than 500,000. Annex VIII includes maps of the zones used in this Report, as well as those used by ODNRI for comparative purposes. 3.03 The boundaries of the ecological zones are often disregarded by political borders. In the north east in Borno state, the desert extends into Chad; in the south-east the forests it. Cross River state extend into Cameroon; and the Niger River has its source in the Guinean Highlands. 5/ ODNRI Nigeria: Profile of Agricultural Potential, Chatham, ODA, 1989.  - 12 - Economic activities, such as coastal fisheries, extend into the nearby waterways of the Cameroon and Benin. The characteristics of the zones are also not sharply divided but shift gradually with slight changes in temperature, rainfall, and climactic conditions. This fact is pronounced in the north as the desert merges into the savanna as a result of increased droughts. The few remaining tropical rainforests in the south have an important bearing on the coastal regions as the animal and plant species which exist there are dependent upon the close proximity aad interaction of the diverse ecological regimes for their survival. 3.04 Solutions to environmental problems lie in the cooperation of many political and institutional groups both inside and outside the zone or zones. Bureaucratic and jurisdictional complexity have been traditional barriers to reaching international agreement on issues of common concern. Efforts at collaboration on environmental matters must continue at all levels of government if programs and policies are to be successfully implemented. Each ecological zone presents major environmental challenges and varying constraints and limitations to development initiatives. Since the country's major environmental problems have been discussed at length by many experts, both local and foreign, it is considered sufficient in this Report to provide brief descriptions of environmental problems which are common to more than one zone. These are set out below prior to descriptions of the zones themselves. (a) Deforestation 3.05 Deforestation is one of the most serious environmental problems facing Nigeria. It is a problem faced by a number of states falling within the Northern, Southern and mid-zones. Nigeria's fore3t lands have traditionally provided three important economic products: timber exports, traditional hunting and non-wood product gathering, and fuelwood. Timber products still make an important contribution to GDP, representing about 7 percent of the agricultural product for the country, but exports have declined while domestic demand has risen considerably as historical rates of forest production exceeded the sustainable yield and have thus resulted in the reduction of timber stocks. In the primary and secondary forest areas, the forest has also provided an important local source of meat and non-wood products which have been used as food or medicine. Increased pressures on the forest have reduced the habitat for the game and, where the habitat is still intact, reduced its availability from over-hunting. Perhaps the most important locally used forest product, however, is fuelwood: about 90 percent of all wood consumption in the country is estimated to be for fuelwood. 3.06 The deforestation in Nigeria has generally led to declines in accessibility of both the wood and non-wood products. This is especially marked in the increased efforts needed for fuelwood and forest product gathering. It is not unusual for household members to spend substantial portions of their time collecting fuelwood to meet cooking and heating requirements. In short, the deforestation and itinerant loss of species can largely be characterized as non-sustainable from the following direct pressures: conversion to agriculture land-uses by expanding populations; non-sustainable logging; and fuelwood gathering. Primary forest is also being converted to plantations of rubber and palm oil, and to a lesser extent for timber, fuelwood, or pulp-wood.  - 13 - 3.07 One of the characteristics of the forests is that they create strong linkages to other ecological zones. Some animals have historically migrated between forest areas and the savanna or plateau areas. Primary forest is often credited with protecting important coastal watersheds and mangrove areas, and forest losses can often lead to increased flooding, silting of rivers or wind erosion which in turn leads to soil loss or degradation, and in extreme cases to gully erosion. Flooding, soil loss and gully erosion which is attributed to loss of vegetation cover are serious problems in different parts of Nigeria. 3.08 An important characteristic of the forestry sector in Nigeria is that it is often the subject of apparently conflicting jurisdictions. The jurisdictional uncertainties and apparent overlaps have created incentives for abuses of privilege; as audit trails are often not clear because of the lack of clear responsibilities, the abuse of privilege has often gone unchecked. In principle, forests are State lands falling under the management responsibilities of the Forestry Department of each state. Yet the Federal Government has traditionally had jurisdiction over what types of exports (round-log or finished product, for example) were acceptable and thus in effect has significant control over the economics of the forestry sector. Concessions are normally granted to timber companies which are owned by public, private, and foreign interests, and the concessions are normally granted with some requirement for the company to manage the tract properly with follow-up reforestation. With a lack of stability of ownership and jurisdiction, companies typically find that it is not in their commercial interests to fulfil their obligations and the forest stock suffers as a result. Recent developments with the addition of National Park projects have not clarified the jurisdictional problems: forests are still State managed yet it is up to the Federal Government to decree National Parks and control activities within the park once the decree is made. The general implication of this from an environmental perspective is that ownership, control, and jurisdiction are all uncertain or divided; decisions are often made at both the individual and institutional level which reflect only short-term interests and, as a result, issues of long- term sustainability are overlooked. (b) Soil Degradation 3.09 Soil degradation, due to declining soil fertility is also a problem which is present throughout Nigeria, although the seriousness of the problem varies with the different ecological conditions within the different states and localities. When tree cover diminishes, organic matter is very rapidly mineralized. The application of the application of inorganic fertilizers while it will enhance the nutrient status of the soil, will do little to reduce the collapse of soil structure and is, therefore, unlikely to be a solution to the problem. In this high rainfall zone, soils of this type are typically highly leached and fertilizer losses would be high. The only long term solution is likely to be the adoption of agroforestry farming systems combining deep rooted trees with agricultural crops and penned livestock enterprises to allow recycling of deep nutrients and maintenance of soil organic matter content by mulching. 3.10 Soil erosion is often an ultimate consequence of declining soil fertility caused by population pressures and inappropriate farming methods. Declining yields per hectare are forcing farmers to cultivate marginal  - 14 - lands, and the depleted soil organic matter reduces the ability of the soil to resist erosion. Indiscriminate bush burning is also a major factor in reducing the vegetative cover of the soil, thus predisposing the soil to loss of fertility and erosion. These factors can be cumulative. In many of these soils the limited organic content is concentrated in the top few centimeters of the soil. The impact of heavy rain breaks up surface parcels and selectively removes the finer soil fractions and organic materials, thus reducing further both fertility and soil structure which in turn reduces the ability of the soils to support plant growth and resist further erosion. 3.11 Engineering practices probably outweigh agricultural systems as direct casual agents of this type of erosion. However, the devegetation of land and the reduction of organic matter content, caused by the increased intensity of land use under traditional agricultural practices resulting from population growth, must, by increasing potential run-off and decreasing stability of already fragile soils, predispose these areas to gully erosion. Examples of engineering practice seen to provoke severe gully erosion in these areas are: (i) site levelling operations for road or building work; (ii) inadequate number and protection (mechanical or vegetative) of drains to dispose of road run-off water; (iii) concentrations of run-off water released from buildings or compounds; (iv) quarrying of sand, gravel or laterite, particularly from roadside banks or drains; (v) mechanical grading of rural earth roads resulting in reduced road elevation and loosened soil surface. Control measures may be biological/or engineering in nature. The former, in most cases are likely to be most cost effective with the emphasis on ensuring permanent vegetative cover adjacent to the gully and elimination of the source of concentrated water flows. (c) Industrial Wastes 3.12 In Nigeria, industry has developed with no enforceable legislation on industrial pollution control. Textile plants, breweries, slaughtering factories, sugar refineries, pulp and paper plants, and petroleum industries all discharge raw, untreated and liquid effluents into open gutters, drains, streams, channels and lagoons. The river Kaduna is a common sink for all waterborne wastes produced by the industries on its banks. The effect of the uncontrolled pollution renders surface waters and the underground water systems unsafe for human, agricultural and recreational use, destroys biotic life, poisons the natural ecosystems, and causes severe threats to human life. 3.13 Industrial water pollution, if uncontrolled, could represent a significant technical problem for the future management of the public water supply system. Not only is the treatment of such water costly, but in  - 15 - addition, the quality of this water, even after treatment, is frequently unsatisfactory from the point of view of health, odor, and taste. Secondary and often dangerous pollutants are also formed during treatment of low quality intake water, since in many cases chlorine which is used for disinfection, results in the formation of organochlorine and other suspected carcinogens. 3.14 Primarily, it will be enforced regulation coupled with economic incentives which affects behavioral change on the part of the industries. There are other pertinent issues that will have to be considered in industrial control efforts in Nigeria such as: (a) the problem of waste disposal is not regarded as an internal problem of industry; (b) many of the major polluters are state owned enterprises which are in financial difficulty; (c) industry is concerned about the high costs associated with pollution control equipment especially during these difficult economic times; (d) many industries do not have the land or space to install effluent treatment systems; and (e) the availability of industrial pollution abatement equipment is minimal. 3.15 Some industries have treatment facilities already installed. However, the plants are left unattended or are very poorly managed. It is anticipated that other action will come forth on a national level as FEPA, which is legally charged with the responsibility of environmental monitoring and control, establishes its role. (d) Biodiversity 3.16 One of Nigeria's important renewable resource assets is the "biodiversity" of the various ecological zones. Biodiversity relates to the diversity of ecosystems, species, and genetic traits within species which exist in a particular area: wetland, rainforest, savanna grasslands, plant and animal diversity, and various primate sub-species, for example, all characterize biodiversity. Biodiversity resources themselves are regarded as an important economic asset, especially over the long term, as they are the source of genetic material which can contribute to pharmaceutical development, diseases or pest resistance crops, as well as economic amenities. Nigeria's cultivated oil palm, for instance, is derived from a wild species originally found in Nigeria's abundant rainforest belt. Unfortunately, biodiversity loss has been significant as other land-use pressures in Nigeria have encroached on unique habitats. (e) Fisheries and Wildlife 3.17 The pressures which have exacerbated biodiversity losses have also resulted in the loss of habitat for economically important fisheries and wildlife in many areas of Nigeria. Coastal and on-shore fisheries have  - 16 - been destroyed by pollution, river siltation, and inappropriate fishing techniques. Wildlife losses, originally due primarily to over-hunting, are now resulting increasingly from land-clearing, deforestation, and uncontrolled bush fires. (f) Water Hyacinth 3.18 Water hyacinths art nervasive in many of Nigeria's waterways and have received considerable at.ention within the country as an environmental menace. Their proliferation can in some instances be exacerbated by water contamination, although the primary impact of water hyacinth is to disrupt the navigability of waterways and the operations of traditional fishermen. Its potentially more serious impacts include choking of irrigation channels, infestation of irrigated fields and providing a breeding habitat for mosquitoes. Mechanical harvesting techniques have been the only consistently successful methods for eliminating water hyacinths. B. Northern Zone 3.19 This zone is characterized by unimodal rainfall which peaks in August. Annual rainfall decreases of the south to north from 1200 to 400 mm. It falls an average of 90 days per annum in the north to 180 days in the south. It covers the ODNRI's semi-arid and dry sub-humid zones with the southern border being part of the sub-humid zone with bimodal rains. Droughts are common and dry Harmattan winds carry dust from the north and increase high temperatures. The dry sub-humid zone was formerly a wooded plain extending across northern Nigeria, rising over 600m in the west and south of Kano to less than 300m in the eastern and western borders. The geology is dominated by sedimentary formation to the east, giving rise to sandy soils of low fertility, and by basement complex formation in the west-central forming a range of more fertile soils, but affected by the presence of ironstone and gravel. 3.20 In the north east of Nigeria is the driest part of the country receiving from 400-600 mm of rain per year. The plains near Lake Chad are affected by cyclic fluctuations in lake levels and advances and recessions in the desert. The vegetation is sparse grassland, woodland or shrubland, heavily grazed and browsed. Forest reserves are located in the north west and east central portions of the zone and there are some game reserves in the south. 3.21 The expanding desert in the north is considered to be one of the most severe environmental problems facing Nigeria. Desertification has been reported in Nigeria and other parts of West Africa since the 1920's. A combination of climatic factors and general increases in population and livestock pressure on the land and vegetation are accepted as the chief causes of desertification. 3.22 Debates continue over the degree to which changes in climatic conditions have had an impact on the process. Statistics indicate climatic fluctuations in rainfall in the region, but the overall picture does not verify this as the principal cause of the desertification in the zone. The reduction in tree cover through bush burning, cutting of trees for firewood and other purposes, and overgrazing have accelerated the process. It is accentuated in intensity by the rapid rate of increase in human and animal  - 17 - population in the zone which is estimated to be about 2.5 to 3 percent per annum. 3.23 An additional factor of importance is the increasing use of mechanical land clearance and cultivation techniques on medium and large scale farms when not combined with appropriate cultivation techniques and cropping patterns. Mechanical clearance favors complete removal of all vegetation from large sized fields. Thus the land is vulnerable to both wind and water erosion. Combining erosion with mechanization tillage (which can damage soil structures), reduces the ability of fallows to restore fertility. Bush burning further exacerbates this scenario. This pressure has shortened and eliminated in some parts of the zone the traditional periods of bush fallow, during which farmlands were allowed to recuperate and increase fertility. Dry spells lead to crop failures and livestock mortality which lead to famines and other hardships. Repeated cycles of this sequence lead to migration of individuals and communities to other locations where the whole process of desertification is set in motion again. With the decrease in vegetation and forests, the soil becomes particularly vulnerable to large scale soil erosion by wind and water (splash, sheet, rill and gully). 3.24 It is recognized that one of the most effective means of reducing degradation in the northern zone is to increase the amount of tree cover on the land. Where successfully established, shelterbelts have been a technical success. By reducing windspeed they have reduced the desiccating effects of the wind with corresponding increases in the yields of crops planted in their protection: they have reduced the extent of soil erosion by wind and, most importantly, reduced the risk of total crop loss from wind damage. Current methods of shelterbelt establishment are very expensive and the costs of treating all the areas in need of such protection would be prohibitive. These high costs are largely due to fence and patrol of the belts to prevent their destruction by grazing animals or wood-choppers. This reflects the perception by local communities that the shelterbelts are government projects in which they have little involvement and no financial stake. A major requirement is thus to integrate tree planting with local land tenure and farming systems. This may require changes either to the tree species used, or their spatial arrangements. In any case, more work needs to be done in assessing the perceived needs of the farmers if their interest and cooperation is to be captured. C. Southern Zone 3.25 The Southern Zone extends from the Bight of Benin to approximately 8