Madagascar - Rural Transport Project : environmental and social impact assessment (Vol. 1 of 5)

Ministry of Transportation and Meteorology World Bank Ministry of Public Works E524 Volume 1 Rural Transportation Project Environmental and Social Impact Assessment December 2001 Prepared by Transport Sector Project (TSP) NGO Lalana Basler & Hofmann Based on the preliminary designs of the following consulting firms: DINIKA (Tananarive) MICS - ECR - AEC - SECAM (Fianarantsoa) ESPACE - MAHERY (Taomasina) EC PLUS - JR SAINA (Mahajanga) 4 A OSIBP - SOMEAH (Toliary) F CO PY EIIRA - ANDRIAMBOLA - BIC (Antsiranana)  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux Table of Contents 1 Summary of Environmental and Social Assessment .................................................. 1 1.1 Proposed Project ........................................ 1 1.2 Transport Sector Environmental Assessment ...................................... 1 1.3 Environmental Assessment for APL 2 ...................................... 1 1.4 Policy and Legislative Framework ....................................... 1 1.5 Methodology ...................................... 2 1.6 Participatory approach ...................................... 2 1.7 Rural transport rehabilitation component ....................................... 3 1.8 Potential environmental impacts ...................................... 3 1.9 Resettlement and cultural heritage ....................................... 4 1.10 Rail and port infrastructure rehabilitation component ....................................................... 5 1.11 Community Environmental Management ....................................................... 6 1.12 Environmental Management/Monitoring Plan ................. ...................................... 6 1.13 Implementation of EMP ....................................................... 6 2 Environmental impacts .................................................. 7 2.1 General description ........................................................ 7 2.2 Environmental impacts and abatement measures ........................................................ 8 2.2.1 Province of Antananarivo ........................................................ 8 2.2.2 Province of Fianarantsoa ....................................................... 8 2.2.3 Province of Taomasina ....................................................... 9 2.2.4 Province of Mahajanga ....................................................... 10 2.2.5 Province of Toliary ........................................................ 11 2.2.6 Province of Antsiranana ........................................................ 11 3 Social impacts .................................................. 13 3.1 Improved access ....................................................... 13 3.1.1 Summary estimate of project impact ....................................................... 13 3.1.2 Current transportation situation and characteristics of provinces .................................................. 14 3.2 Job creation ........................................................ 15 4 Summary and conclusion ....................................................... 16 4.1 Project financing package and scope ....................................................... 16 4.2 Impacts ....................................................... 16 4.3 Implementation of environmental management plans ....................................................... 17 Annex 1 List of roads studied, by province ........................................................ 18 Section 1.01 Tananarive ....................................................... 18 Section 1.02 Fianarantsoa ....................................................... 22 Section 1.03 Taomasina ........................................................ 25 Section 1.04 Mahajanga ........................................................ 28 Section 1.05 Toliara ........................................................ 29 Section 1.06 Antsiranana ........................................................ 31 Annex 2 List of communities selected for socio-economic study ...................................... 33 17.0 1.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux Annex 3 Model Environmental Management Plan (example of Road No. 41201 Befandrino - Ambararata) .................... 36 Note: The graphs used in this rcport werc copicd from UNDP and NEO publications and are intended solely for internal use. 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 1 Summary of Environmental and Social Assessment 1.1 Proposed Project The purpose of the transport sector program is to reduce transport costs and to improve accessibility in rural areas. This project is one of the parallel phases of an Adaptable Program Loan (APL) aimed at helping the Government of Madagascar to implement its transport sector policy and strategy. The entire APL program consists of various investment phases/packages, which include support to the various transport sub-sectors, i.e., essential reforms of the transport sector, and of critical and high priority investments, strengthening the civil aviation and railway sub- sectors, and providing major investments in the road sub-sector. Given Madagascar's unique ecological assets, environmental degradation is a major concern in the country. Its devastating effects are far-reaching, ranging from siltation of rice fields to the destruction of transport infrastructures. This project will finance the rehabilitation of existing transport infrastructure: i.e., provincial roads, and railway and port infrastructures in the Fiananrantsoa-Manakara corridor. 1.2 Environmental Assessment of the Transport Sector Prior to program appraisal, an environmental assessment was prepared for the transport sector. The three-volume Transport Sector Environmental Assessment provided an overview of the context in which the sector currently operates. The EA report: a) defined and analyzed the general environmental impacts relevant to each sub-sector; b) identified the potential environmental impacts of activities planned under APLI; and c) recommended an environmental management plan (EMP). The EA report provides project managers in the sector with a permanent working document enabling them to better understand the situation at each project site, taking social, biological, and physical factors into account. The EA was prepared and disclosed in accordance with World Bank guidelines and national environmental policies concerning infrastructure and environmental protection. The sectoral environmental assessment also provides the basis for the separate environmental and social assessments to be undertaken for each APL phase. The preparation of environmental and social assessments is a built-in trigger for each APL phase. 1.3 Environmental Assessment for APL 2 Environmental and social assessments were undertaken for 8,500 km of rural roads in various provinces throughout Madagascar. A general EMP was prepared that included moderate and high impact roads. Provincial workshops were held to select roads to be rehabilitated under this APL phase. It was determined that only those road links with low environmental impact would be selected, and individual EMPs will now be prepared for those selected roads. These EMPs will be prepared, disclosed and approved prior to project effectiveness. However, the environmental and social assessments resulted in a general EMP that describes the likely magnitude and range of negative impacts and their mitigation measures. Following the selection carried out in the provinces, it has been established that no resettlement or compensation would be necessary. The Fiananrantsoa-Manakara corridor relies heavily on the FCE railway and the port of Manakara. The Government has committed itself to placing both the railway and the port under a concession regime. It has been established that the Project will not finance any works under this component until this concessioning agreement has been worked out. It is estimated that it will take about a year for this to be completed. It has been agreed that, in order to comply with national environmental regulations and those of the Bank, an environmental audit and EMP will be prepared for the rail infrastructure rehabilitation and an environmental assessment and EMP will be prepared for the proposed port infrastructure rehabilitation within this timeframe to supplement/complement various existing feasibility studies. This requirement/condition has been articulated in the project's legal agreements in the sector policy letter contained in the DCA package. 1.4 Policy and Legislative Framework The impact assessment is based on the following material: * 'Environmental Charter" (Charte de l'Environnement), 1990 * Decree on incorporation of environmental investments into national accounts (Decret de Mise en Compatibilite des Investissements avec l'Environnement) (MECIE), Nov. 2000 * NEO: Maps of the national parks (Management Plan for National Parks - "Plan de Gestion du Reseau National des Aires Protegees de Madagascar", May 2001); natural reserves and national forests (GEF Design 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 2 Assistance to PE2, Dec. 1995); "Priority for preserving Madagascar's Biodiversity" (Priorite de conservation de la biodiversite a Madagascar), 1999 * Transport Sector Environmental Study (Etude environnementale du secteur des transports), MOT. MOW (report for the transport project), July 1999 * "Use of Labor-Intensive Technology" (Utilisation de la technologie HIMO), NORAD/BIT, Feb. 2001 * Procedures Manual for Preliminary Designs (Manuel de procedures pour avant-projets sommaires (APS)), SEP/NGO Lalana/Basler & Hofmann, July 2001, with comments provided to firms dealing with engineering and social aspects during the workshops (June-July 2001) by specialists from the PES, the World Bank and the NGO Lalana * Preliminary designs provided by firms handling engineering and social aspects for each province, Sept./Oct 2001. 1.5 Methodology The environmental and socio-economic studies carried out by the environmental and social firms for the preliminary designs are based on the Procedures Handbook for Rural Roads and include in particular: * a description of the current environmental situation (as evaluated on the field); * an assessment of the potential impacts of road rehabilitation during the preparation, implementation, and operation and maintenance phases; * the specification of mitigation measures and an estimate of their associated costs (to be included in total costs); * a detailed socio-economic study carried out in the selected communes (listed in the annex) with communal and household level surveys used as the baselines for future project impacts. The Handbook describes the approach to defining appropriate interventions and contains the following instructions for minimizing negative environmental and social impacts: * changes in road alignment can be made only if they are absolutely necessary and do not require resettlement of people or property; * care will be taken in the siting of construction camps, borrow pits and quarries to avoid resettlement, and measures will be taken to rehabilitate after completion; * there will be an effort to identify drainage areas and other zones which could be stabilized through local community involvement, i.e., through in-kind contributions. The preliminary designs and conclusions prepared by the environmental firms have been reviewed by experts at the PES, by Lalana (the NGO charged with oversight), and by the World Bank's rural transport specialists, to ensure that: * studies were carried out in a timely manner; * NEO's environmental maps (i.e., integrated maps of biological assets, eco-regional maps) were integrated into the analysis. 1.6 Participatory approach Stakeholders have played a key role in preparation of the project as well as of the environmental and social assessment, and will continue to do so during project implementation. Decentralized levels of Government, i.e., the stakeholders' elected representatives, ensure the ownership and management of rural roads. Beneficiaries and their representatives have been consulted in the final selection of roads to be improved and will be advised on how to maintain these roads. Stakeholders will decide whether they want to take advantage of the project's intent to provide support for environmentally-sound exploitation of reforested areas. These environmental enhancement initiatives and/or micro-projects will then be executed under the responsibility of community-based organizations. During project preparation, a number of workshops were held to define the "Promotion of Intermediate Means of Transport" component. NGOs were instrumental in defining this component. NGOs and civil society also participated in the final selection of roads to be improved under the project and will thus have a major role in shaping this component. The local NGO Lalana played a leading role in providing guidance to the consulting engineers that performed the summary design studies on environmental and social impacts. NGOs will also play a key role by helping to define the project log frame. Some of these NGOs may be national (e.g., Lalana, FJKM), international (e.g., CARE, CRS, Veterinaires sans frontieres, Agro Action, Intercooperation), credit agencies, and community associations. Depending on their qualifications, they may be involved in outreach, technology transfer, micro-credit, etc. Community-based organizations will also be involved in informing communities about the 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 3 options for environmentally-sound watershed management and will assist those communities who opt to participate in this component. These initiatives will be coordinated by ANAE, an NGO with extensive experience in community-based environmental management and ecological services delivery. The environmental and social assessments have been prepared by a process involving built-in consultation. Communities, local provincial authorities, local NGOs/CBOs were consulted during these assessments. NEO was also consulted on the recommendations emerging from the assessments. As a quality assurance measure, a national NGO has been hired by the PES to oversee the environmental and social inputs for the feasibility studies and provide support to the environmental and social teams who prepared the studies/surveys. 1.7 Rural transport rehabilitation component Separate environmental and social analyses were carried out for the proposed roads and for a part of the work proposed for the Fiananrantsoa corridor. The planning process for the rehabilitation of provincial roads is similar to that of CDD projects. Roads will be selected based on a prescribed set of financial, technical, social and environmental criteria. On the basis of these criteria, the provinces will establish their annual road improvement programs each year through a consultative process. Preliminary environmental and social analyses were carried out for 8,500 km throughout Madagascar, with the likely impact of interventions being rated as high, medium, or low for each road segment. Prior to the assessment, teams of environmental and social specialists conferred at a workshop to establish a common framework for field visits, environmental and social inputs and levels of analyses. Direct and indirect environmental and social impacts at the road construction site and in the immediate environs of the right of way may include: stripping of top soil and loss of vegetation due to the creation of borrow pits; soil erosion on road cuts and fills and stripped borrow areas; silting of roadside ditches and subsequent downstream sedimentation of water; soil contamination and water pollution due to spillage of toxic materials; problems with slope stability due to erosion and/or poor drainage; various forms of temporary land occupation; and impacts on human settlements (e.g., spread of HIV/AIDS and other infectious diseases, higher accident rates). In order to mitigate these impacts, an Environmental Management Unit has been established and made responsible for overall environmental management of the Program and for the implementation and monitoring of separate environmental management plans for each road segment.. The first year's road rehabilitation program was established during a series of provincial workshops. It was determined that only those roads having little or no environmental and social impact were to be selected. Therefore, for the first year's program, no sensitive natural habitats will be affected and no resettlement and/or compensation will be necessary. For subsequent programs, based on these preliminary analyses, further environmental and social assessments will be prepared, disclosed and approved prior to any civil works, as required by the project's Environmental Management Unit, the National Environmental Office (NEO) and the Bank's safeguard policies, where applicable. 1.8 Potential Environmental Impacts Road rehabilitation has a positive overall impact, particularly on the social and economic environments. The major potential downsides are physical (e.g., damage to soil, flora and fauna, loss of habitat, deforestation) and social (disruption of life, resettlement, loss of cultural sites). The potential effects of road rehabilitation on soil, flora and fauna have been assessed on every road, especially in the biologically diverse eco-regions. Five of the 350 roads provide greater access to sensitive areas (i.e., national forests). This could intensify existing pressure on virgin forests and on native fauna. Nevertheless, such effects will be mitigated by measures such as the creation of the Gestions Locales de Securite (GELOSE) and other similar institutions to protect the environment. About 25 roads traverse sensitive areas that have already been damaged or that are close to virgin forests. For damaged areas, rehabilitation will have a fairly positive impact, whereas nearby virgin forests may experience a fairly negative impact. For these roads, a detailed EMP, including responsibilities and follow-up measures, will be prepared and implemented. For roads going through damaged areas, environmental measures (e.g., reforestation, drainage pit stabilization) will be appraised in the field during preparation of the detailed design studies. Such measures will be adapted/modified appropriately for every road segment having any negative environmental impact. No physical works will be implemented until an EMP for each road segment is prepared, approved, included in contract documentation and costed. In conclusion, the few potential negative impacts on the environment can be adequately offset. 17.01 .02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 4 1.9 Resettlement and cultural heritage The project will improve existing roads, which are often in very poor condition. These improvements will provide more reliable access throughout the year (including the rainy season). Preliminary designs prepared thus far by the engineering and social firms show that very few road layouts should be modified. So far, no one is expected to be resettled, nor is any cultural site expected to be damaged. The overall assessment of impacts is shown in the following table. Rough studies provide a general view of the project. Detailed studies analyze roads on a case-by-case basis. Potential impact Assessment Phase Importance Study Environmental Soil: erosion, silting Erosion (e.g., bush fires, creation of "lavaka") is a - Execution, Medium Detailed problem relevant to Madagascar. Roads that traverse /+ operation already-damaged areas have a positive effect in general, since they help supplant wood fuel with kerosene, and educate the population. The impact is enhanced when environmental measures (e.g., reforestation, stabilization of drainage areas) are promoted in the form of local contributions to road rehabilitation. Water: pollution, Road drainage will be improved. However, during -/+ Execution. Low No drainage modification project execution, pollution may be an issue at operation construction sites/camps. Air: dust, emissions There are very few engine-powered vehicles on rural - Execution, Low No roads, which are generally unpaved. Paving roads in operation villages and using labor-intensive methods can prevent dust cloud problems, especially during works. Fauna: loss of habitat Madagascar's broad biodiversity suffers from human - Execution. Medium Detailed activities. Today, there are 46 natural reserves and operation national parks. Roads provide access to them, which is both good (in terms of audits and tourism) and bad (since it facilitates illegal exploitation of natural resources). Road works may temporarily disturb a reserve or a park. Flora: deforestation, Same assessment as for the fauna. -/+ Execution, High Detailed reforestation Deforestation has always been a problem in operation Madagascar, mainly due to movements of the population, which needs wood and fields for agriculture and cattle. In the highlands, deforested slopes are deteriorating quickly (causing so-called "lavaka" to appear). The proj ect should have a positive impact, especially through the promotion of environmental measures (e.g., reforestation, stabilization of drainage areas, etc.). See "Soil: erosion." Illegal deforestation is closely linked to road access. Improved access to forests will facilitate these illegal activities. Landscape: esthetic Roads are not being built and are fairly narrow. - Execution, Low No modification operation Potential impact Assessment Phase Importance Study Social Providing access People will have increased access to basic services. + Operation High Rough, Roads will be more reliable, providing access at any detailed time of the year (spot maintenance/rehabilitation). low-level 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 5 study, appraisal later on Improved access Transportation costs and times will be reduced. + Operation Medium Detailed Moreover, better access can discourage local low-level monopolies on agricultural goods in some areas. Such study, monopolies have often prevented similar works from appraisal being carried out in the past. The environmental and later on social consulting firms have taken this potential consequence into account. The project focuses mainly on providing access and improving means of transport, without improving road surfaces significantly. However, spot maintenance/rehabilitation will shorten travel times. Job creation The private sector will execute works. This will + Execution High Rough provide jobs to local populations, especially in labor- intensive SMEs. The various training efforts are also aimed at promoting jobs for women in SMEs. Resettlement Since roads are being rehabilitated and not built, - Execution Medium Detailed resettlement should be minimal. Compensation will be available for relocated and/or affected populations. A resettlement policy framework is being prepared. For the first year's rehabilitation program, no one is expected to be relocated. Disruption of life Rehabilitation works (e.g., bush clearing, temporary -/+ Execution, Medium No widening) may cause disruptions. In addition, the operation great number of workers may disturb local populations, but will at the same time generate economic transactions. Labor-intensive training for SMEs will train site managers to deal with those issues. An information campaign on AIDS, in collaboration with the AIDS project, will be specifically aimed at road users (e.g., truck drivers). Loss of cultural sites Cultural sites in Madagascar are mainly cemeteries - Execution Medium Detailed and sites associated with the dead. The firms handling environmental and social aspects have been careful to avoid disturbing such sites. Under the first year's rehabilitation program, no cultural sites will be affected. 1.10 Rail and port infrastructure rehabilitation component The environmental assessment for rehabilitation of railroad infrastructures has been carried out. The 163 km railway traverses a unique ecosystem consisting of the last remnants of virgin forest in the highlands. The EA for the railway has highlighted the negative environmental and social impacts of a permanent closure of the railway, i.e., conversion from cash crop production to subsistence crops, especially manioc and rice, using slash-and-bum techniques on steep slopes. It is expected that an additional 110,300 ha would be put under cultivation. Secondary impacts due to erosion and reduced rainfall in the immediate vicinity of the corridor are estimated by NEO at US$16 million.. No estimates have been developed for the cventual loss in biodiversity and tourism potential. Ongoing community activities for slope stabilization have already demonstrated the positive effects of converting fields adjacent to the railway from manioc cultivation to vetiver, fruit trees and spice crops. Where appropriate, these experiences would be applied and adapted to mitigation measures for provincial roads rehabilitation programs. Several preliminary feasibility studies have been carried out for the rehabilitation of port infrastructures. A study examining various rehabilitation options was prepared, but an environmental assessment of the selected option has yet to be prepared. The port environment has been assessed as part of the preparation of a GEF project that is providing emergency equipment for oil spills. The project will finance the rehabilitation of the port, which includes rehabilitating a land-based oil pipeline and container facility. 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 6 The corridor relies heavily on the FCE railway and the port of Manakara. The Government has committed itself to placing both the railway and the port under a concession regime. It has been established that the Project will not finance any works under this component until this concessioning agreement has been worked out. It is estimated that it will take about a year for this to occur. It has been agreed that, in order to comply with national environmental regulations and those of the Bank, an environmental audit and EMP will be prepared for the rail infrastructure rehabilitation and an environmental assessment and EMP will be prepared for the proposed port infrastructure rehabilitation within this one-year timeframe. This requirement/condition has been articulated in the project's legal agreements in the sector policy letter contained in the DCA package. 1.11 Community Environmental Management On a pilot basis, community participation in environmental management (e.g., watershed management, reforestation activities, etc.) would be introduced in areas where NGOs are already active. Community contributions to road improvement could be in the form of making land available for reforestation and ensuring its environmentally-sound exploitation. Given the extreme poverty in Madagascar, it is clear that communities would only invest in the environment if there is a direct economic benefit. During project preparation, the project therefore explored the various forms of community-based environmental action that can be undertaken. Strategies for the sustainability of such environmental activities (e.g., inclusion in road maintenance programs) were also explored. 1.12 Environmental Management/Monitoring Plan Under APL I of the transport program, several environmental management recommendations were implemented. The PES recruited an environmental specialist who will receive technical assistance not only to implement and monitor the EMPs of all APL activities, but also to assume leadership of the "Environmental and Social Protection" component of the project. This project will continue to support improved environmental management in the transport sector, particularly as this relates to rural transport. International technical assistance is currently being put in place at the PES to reinforce local staff. The socio-economic baseline study, which would be an integral and ongoing instrument of the project's M&E system, would monitor the project's impact on poverty. The surveys would collect economic data (e.g., the cost of traveling to the nearest market town, prices of consumer goods and basic staples) as well as socio-development data (e.g. number of children completing primary school, incidence of diseases, and assistance of agriculture extension workers.) The studies would also collect information about the quality of life in communities. 1.13 Implementation of EMP Measure Entity responsible Schedule Preparation of the EMPs Engineering and In the preliminary environmental/social design reports (Oct firms 2002) Incorporation of the plan's measures into the detailed Engineering and Depending on the phases design (description, quantity, costs) environmental/social (Ist phase early 2002) firms Inclusion of the measures in the request for proposals Engineering and Depending on the (specific clauses in the contracts) environmental/social phases (1st phase early firms 2002) Creation of local organizations dedicated to Province / GTDR Before the competitive environmental protection (GELOSE) for the five roads bidding selected Follow-up and decision to launch competitive bidding for PES and CE of the the five roads selected MOW Implementation of the measures that must be taken out Companies prior to and during the works Follow-up of the measures Audit firms, PES, ONE Audit of the measures PES and CE of the MOW 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 7 2 Environmental impacts 2.1 General description Based on the overall assessment of the project, the following environmental impacts are examined in greater detail: * soils: erosion, sand encroachment * fauna: habitat loss * flora: deforestation, reforestation Negative impacts are likely in areas of great biodiversity. Roads crossing or facilitating access to such a zone are described in this report under the summary of the consulting firms' notes and clarifications. The size of these areas is indicated on the NEO map presented below. Measures to mitigate negative impacts during the implementation phase are, in general, similar for all the roads, with specifications differentiated according to the placement or nature of critical spots. The measures are documented in the environmental management plans for each road, which are partially completed (see example in annex), to be completed at the time of the detailed designs and included in the bidding invitations and resulting contracts. The most important measures include the rehabilitation of borrow pits, construction of the necessary deviations while road works are occurring, defining and preventing access to sensitive areas, and measures to monitor the virgin forests with the relevant institutions. ONE: Plan de Gestion du Reseau National des Aires I tM*a. - Protegees, Mai 2001 Eco-r6gion Haute A S Terres du Nord La carte illustre la distribution des aires actuellement protegees (blanc) et les aires Eco-region Ouest protegees futures et UN"M potentielles (noir) p. -Ec6-i%gi. CLytrAbtag O ar i _ 1 L Fco-region Est AIxyZAwW ~ ~ ~ tt~nt 40 0 4 Kky*w. *,.".,~~~~~~~~~~d k& iFaS ~ ~ ~ ~ ~~~~~M kf bt' J i / ^ - U^~~ltst _ > % -'- AJwtfitsm pflS Eco-region Sud cAP mUd 17.01.02  Projet de Transport Rural, Madagascar - Evaluation des impacts environnementaux et sociaux 8 2.2 Environmental impacts and abatement measures 2.2.1 Province of Antananarivo The province belongs to the Central ecological region, according to NEO's classification. Practically all the region's natural vegetation has been cleared or modified by human activity. Roads mainly traverse agricultural areas. The environmental chapters of the consulting firms' preliminary designs are not yet available. In order to identify the sites with potential negative environmental impacts, maps of the roads under consideration and of the sensitive areas have been superimposed. The result shows that no road passes through a sensitive area. Most of the roads traverse areas of savanna-type vegetation (whether wooded or not), as indicated in the list attached as an annex. 2.2.2 Province of Fianarantsoa The province's terrain belongs to the ecoregions of the Center (like Antananarivo) and East. The latter region includes low- and medium-altitude virgin rain forest and mossy forest. It consists of a discontinuous band of natural habitats running from north to south in a strip ranging in width from 30 km at the widest point to only a few kilometers towards the south. According to NEO, the most severe pressure is being exerted on the low-altitude forest, with a large portion of the original natural habitats having been transformed, through human activity, into secondary habitats. Most of the medium-altitude forest is protected, to a certain extent, by its inaccessibility. Some of the project's roads will facilitate access to this region, and these have been examined more closely. Information provided by the consulting firm's environmental specialists indicates that the impacts of rehabilitation works are generally deemed low (see table in annex). Information provided by the consulting firms was merged with, and supplemented by, environmental databases such as the << Priorities in Biodiversity Preservation in Madagascar >>. Eighty-eight percent of the roads have low or non-existent environmental impacts, and 9 percent are judged to have moderate impact. One existing road (N