Ghana - Highway Sector Credit Project : the environmental impact assessment study

FILE .COPY GHANA IIGHWAY SECTOR INVESTMENT CREDIT PROJECT DRAFT FINAL REPORT OF THE ENVIRONMENTAL IMPACT ASSESSMENT STUDY Prepared for GHA and submitted to the World Bank by: Associates in Rural Development, Inc. 110 Main Street Burlington, Vermont March 1995  TABLE OF CONTENTS ABBREVIATIONS AND ACRONYMS ....................................iii PREFACE ....................................................... iv EXECUTIVE SUIMARY ............................................ 1 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK ................... 4 BACKGROUND AND PROJECT DESCRITION ........................... 7 BASELINE DATA COLLECTION AND ENVIRONMENTAL DESCRIPTION .... ... 10 ENVIRONMENTAL IMPACTS OF THE HSIC PROGRAM .................... 13 MITIGATION AND MONITORING ..................................... 18 ENVIRONMENTAL MANAGEMENT AND TRAINING ...................... 26 i  APPENDICES Appendix 1 - Terms of Reference Appendix 2 - Persons Met Appendix 3 - Environment in Ghana Appendix 4 - Road Deterioration Process Appendix 5 - List of roads in HSIP (as of February 1995) Appendix 6 - Roads Sections Assessed in HSIP Field Study Appendix 7 - Detailed EIAS of HSIP Roads Appendix 8 - Organization charts of GHA and MRH Appendix 9 - Mitigation Plan / Terms of Reference for Long-term GHA Environmental Consultant Appendix 10 - Training Plan for GHA Appendix 11 - Sample Guideline of an EIA Outline for road projects Appendix 12 - Minutes of Public Hearings from HSIP road Sections ii  ABBREVIATIONS AND ACRONYMS AGS Accelerated Growth Strategy ARD Associates in Rural Development, Incorporated BMU Bridge Maintenance Unit BRRI Building and Road Research Institute BMS Bridge Condition and Maintenance System DFR Department of Feeder Roads DUR Department of Urban Roads EPC Environmental Protection Council ERP Economic Recovery Program EIA Environmental Impact Assessment EPA Environmental Protection Agency FRP2 Second Feeder Roads Project GHA Ghana Highway Authority GHAEU Ghana Highway Authority Environment Unit GWSC Ghana Water and Sewerage Corporation GIS Geographic Information System GOG Government of Ghana HSIC Highway Sector Investment Credit HGV Heavy Goods Vehicle MFEP Ministry of Finance & Economic Planning MRH Ministry of Roads and Highways MOTC Ministry of Transport and Commnunications MTP Multimodal Transport Project MRHEU Ministry of Roads and Highways Environment Unit MPBS Maintenance Performance Budgeting System MMU Mobile Maintenance Unit MIS Management Information System NDPC National Development Planning Commission NGO Non-Governmental Organizations NFRRMP National Feeder Roads Rehabilitation and Maintenance Project NECC National Environment Coordinating Council PPF Project Preparation Facility PMU Project Management Unit RTPU Road Training Production Unit TRP-1 First Transport Rehabilitation Project TRP-2 Second Transport Rehabilitation Project UTP Urban Transport Project iii  PREFACE From 5 December 1994 to 3 February 1995 Associates in Rural Development, Inc. consultants Dr. Andrea Katz and Dr. Anthony Tawia Amuzu undertook an Environmental Impact Assessment of the Highway Sector Investment Credit Project (HSIC) in Ghana. This assessment is to be included in the World Bank's pre-appraisal documentation for the project. The consultants wish to thank Dr. Anil Bhandari, the World Bank Task Manager for HSIC, staff of the Ghana Highway Authority and Ghana Environmental Protection Agency and numerous other individuals, including those listed in Appendix 2. This draft final report will be finalized in the light of comments received, and when complete cost information has been compiled for the mitigation plan (see Table 1). iv  EXECUTIVE SUMMARY 1. Ghana has experienced a series of major economic crises during the 1970s and early 1980s. The transport infrastructure, which is essential for the movement of key exports and of farm products to market, faced virtual collapse during this period due to shortage of foreign exchange and prolonged neglect of maintenance and rehabilitation. Resulting high costs of transport have imposed critical barriers to Ghana's continued economic growth. 2. In 1983, the Government of Ghana (GOG) launched an Economic Recovery Program (ERP) which provided for successive devaluations of the currency and, a return to a system of market prices and cost recovery. Reform and (in some cases) divestiture of state enterprises increases reliance on the private sector whenever possible. This program emphasized restoration of agricultural production, the restoration of exports, and the provision of essential imported inputs for agriculture and domestic industry. To implement the ERP, GOG has given high priority to rehabilitation and maintenance of all types of transport infrastructure. 3. In accordance with the goals of the ERP, GOG's Ghana Highway Authority (GHA) will receive funding from the World Bank to embark on a multi-year program of trunk road rehabilitation. The objectives of GHA's program, the Highway Sector Investment Credit Project (HSIC), are to: accelerate implementation of the road network stabilization program; remove physical bottlenecks to the expansion of exports, farm production and labor mobility; protect the investment in road infrastructure; reduce the high vehicle operating costs through improved riding surfaces; strengthen GHA and the Ministry of Roads and Highways' (MRH) institutional capacity; and strengthen the local construction industry. HSIC is projected to rehabilitate approximately 140 km of paved trunk roads and 1,900 km of paved/gravel trunk roads over a four-year implementation period. 4. In cooperation with the GHA, and in compliance with the World Bank and GOG's requirements, Associates in Rural Development Inc. (ARD) provided consultants who conducted an environmental impact assessments (EIA) of HSIC during the period 5 December 1994 to 3 February 1995. In accordance with the Terms of Reference provided, the ARD team: (i) identified environmental issues which relate to road rehabilitation, while providing definition of those issues which illustrate the type and scope of issues which should be addressed during project implementation; 1  (ii) identified potential adverse environmental changes which are normally associated with road maintenance in general and, specifically, with the participating areas in Ghana; (iii) identified environmental mitigation measures for each ecological region of Ghana; (iv) prepared recommendations for ensuring that suggested environmental standards and mitigation measures are complied with; and (v) analyzed the EIA system in Ghana and suggested ways to strengthen institutional capacity of GHA to conduct environmental impact assessments and environmental management of road sector project. 5. The methodology utilized to conduct the site-specific environmental impact surveys of the road sections included in HSIC was based on guidelines in the World Bank Environmental Assessment Sourcebook. 6. EIA field observations of HSIC road sections indicate that impacts will be fairly benign and limited to the local area where the road works will be carried out. Severe environmental impacts necessitating resettlement of communities, or causing damage to fragile ecosystems will not occur to a significant extent as a result of the project. 7. As no new road alignments are envisaged, direct negative impacts of HSIC will be limited to soil erosion which may be due to improper designs of embankments or side drains;-scouring of the landscape due to opening of borrow pits; destruction of vegetation due to clearing rights-of-way and a lack of adequate provisions for revegetation; dust, fumes, noise, and vibrations during road work; increased sediment loads in streams and rivers where road crossings occur; and safety hazards created by increased traffic flows and speed. 8. Secondary impacts from the HSIC reconstruction will also occur. Prominent among them is the possibility of induced development along more accessible road corridors and opening up areas to natural resources to exploitation. Examples of the latter include easing access to protected areas or forest reserves, thereby increasing the chances of over-exploitation of wildlife, timber and fuel wood. HSIC road rehabilitation may also cause land use changes and affect land ownership systems as improved roads may increase market opportunities and, therefore, the value of land. 9. Positive impacts from HSIC road irnprovement activities occur and indeed provide the rationale for the project. Example include increase in value of agricultural products due to improved access to markets, enhanced roadside commerce and increases in social mobility. 2  I- 10. GHA is giving increasing attention to strengthening its capabilities in the area of environmental management of road projects including the production of EIAs. Plans are underway to develop an environmental unit within the Planning division of GHIA. 11. Recommendations to mitigate and monitor adverse environmental impacts of HSIC are divided into the following categories: i) on-site maintenance; ii) institutional strengthening and training; iii) environmental management of road construction and maintenance actions; and iv) compliance with environmental requirements by rehabilitation contractors. 12. Major recommendations in the mitigation plan include: (i) hiring a long-term environmental specialist for two years to assist the fledgling environmental unit of GHA in implementing environmental management aspects of HSIC; (ii) to alleviate chronic road dust problems in settlements, road stretches through busier towns and villages should be tarred; (iii) to reduce accidents the road corridor in the vicinity of settlements, speed limits should be clearly posted and rumble strips and pedestrian crossings provided; (iv) GHA should establish an environmental unit in the Planning Division to oversee environmental management of trunk roads in concert with finalizing and implementing a training plan to ensure that environmental management is institutionalized into GHA work; (v) public hearings should be used to provide a forum for localities to discuss their concerns about environmental aspects of upcoming road rehabilitation activities with staff from GHA; (vi) GHA should develop plans to undertake an awareness campaign for communities on environmental aspects of road works so that the public can provide informed input to the EIA and environmental monitoring processes; (vii) strengthened institutional coordination and interagency arrangements are necessary at district and national levels to ensure effective mitigation of road work on the surroundinigs, and the impacts of other activities on the roads themselves; (viii) environmental protection clauses should be included in the construction bid documents with clear penalties for non-compliance. 3  POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK 13. The transport sector in Ghana is the main responsibility of two Ministries. The Ministry of Transport and Communications (MOTC) is responsible for formnulation and monitoring of policies and programs relating to public and private sector organizations, and for overseeing the work of public sector agencies in ports, shipping, railways, road, air and lake transport. Planning, construction, and maintenance of highways, trunk roads, urban roads and feeder roads is the responsibility of the Ministry of Roads and Highways (MRH). 14. Within MRH three entities, the Department of Feeder Roads (DFR), the Department of Urban Roads (DUR), and the Ghana Highway Authority (GHA), oversee different parts of the national road system. DUR is responsible for about 1,920 km of urban roads, DFR is responsible for approximately 22,000 km of feeder roads, while GHA is accountable for 14,724 km trunk roads. HSIC will be implemented by the GHA under MRH auspices. GHA was created in 1974 to serve as an semi-autonomous authority to construct and maintain Ghana's trunk road system. 15. In the past GHA has not undertaken extensive environmental impact assessments (EIAs) as there was no regulatory authority systematically requiring such assessments. Environmental issues were addressed, in a general way. Engineering/feasibility studies were carried out either by GHA staff who were not trained in EIA preparation or by consultants who did not work closely with GHA staff to transfer skills in EIA preparation. There are currently no staff trained in environmental management and there is no unit established in GHA (or in MRH) responsible for EIA and environmental management of road projects. 16. EIA procedures in Ghana have evolved since 1989 when a requirement was instigated to screen and evaluate all developments, undertakings, and projects which may give rise to significant environmental impacts. 17. However, with recent passage of the Environmental Protection Act making it mandatory for contractors to submit EIAs to the newly constituted Environmental Protection Agency (EPA), and the increasing number of donor projects in the road sector requiring ELAs, it is necessary for the GHA to strengthen its capacity to conduct environmental management. Consequently, MRH is considering adding an Environmental Unit (EU) within the Planning Divisions of GHA, DFR, and DUR to oversee responsibilities for EIA and environmental monitoring, planning and management. 18. The primary responsibility for environmental protection in Ghana rests with EPA which was officially established in January 1995 as a result of passage of the 1995 Environmental Protection Act. EPA has taken over the responsibilities and mandates of what was previously known as the Environmental Protection Council (EPC). EPAs functions are:  (i) to develop legal regulations and environmental standards pertaining to all development activities; (ii) to enforce environmental regulations and apply sanctions in cases where there is non-compliance with such regulations; (iii) to oversee the new legal requirements resulting from the Environmental Protection Act which make it mandatory that all development projects submit ELAs to the EPA and to assist in the systematic strengthening of the EIA process in Ghana; (iv) to advise the Government generally on all environmental matters relating to the social and economic life of Ghana; (v) to co-ordinate the activities of all bodies concerned with environmental matters and to serve as a channel of communications between those bodies and the Government; (vi) to conduct and promote investigations, studies, surveys, research and analysis (including the training of personnel) relating to the improvement of Ghana's environment and the maintenance of sound ecological systems; (vii) to serve as the official national body for co-operating and liaising with other national bodies and international organizations on environmental matters; (viii) to undertake such studies and submit such reports and recommendations as the Government may request; (ix) to embark upon general environmental educational programs for the purpose of creating an enlightened public opinion regarding the environment and an awareness of the public's individual and collective role in its protection and improvement; (x) to ensure the observance of proper safeguards in the planning and execution of all development projects, including those already in existence, that are likely to interfere with the quality of the environment; (xi) preparing legislation required for maintaining sound environmental standards. Several laws already exist, but many of these require updating and new ones are called for to meet the country's rapidly changing economic and social conditions; and 5  (xii) establishing standards for the Government and private individuals on how best any project can be set up so as to avoid the creation of environmental problems. 19. At present, EPA is concentrating on establishing EIA as a more widely accepted practice. Detailed guidelines for ELAs for all sectors are also being developed. A draft "Guidelines for Environmental Impact Assessment in Ghana" has been prepared. This draft includes guidelines and instructions for preparing and submitting ELAs to EPA (see Appendix 11). EPA is preparing a separate appendix to the draft guidelines, in conjunction with GHA, detailing the preparation of road sector EIAs. EPA also plans to conduct training workshops for relevant GOG agencies including GHA, on preparation of EIAs based on the draft guidelines. 20. EPA maintains offices in each region in Ghana (i.e. ten regional offices, including the central office in Accra). The organizational structure of each office and of EPA as a whole is currently undergoing substantial revisions as a result of the transition from EPC in January 1995. EPC was an advisory council with no enforcement or regulatory mandate. The result of current revisions in the EPA structure and mandate reflect the increasing priority which GOG is placing on environmental matters and conservation of natural resources in the context of national planning and development activities. 6  BACKGROUND AND PROJECT DESCRIPTION Background 21. Ghana has experienced a series of major economic crises during the 1970s and early 1980s. The transport infrastructure, which is essential for movement of key exports and farm products to market, faced virtual collapse due to shortage of foreign exchange and prolonged neglect of maintenance and rehabilitation. Resulting high costs of transportation ramified through most of the economy. In 1983, Ghana launched an Economic Recovery Program (ERP). This provided for successive devaluations of the currency, a return to a system of market prices and cost recovery, reform and, in some cases, divestiture of state enterprises with reliance on the private sector whenever possible. This program emphasized, as part of its strategy, restoration of food and agricultural production, restoration of exports, and provision of essential imported inputs for agriculture and domestic industry. To achieve this restructuring, the Government has given high priority to rehabilitation and maintenance of transport infrastructure. 22. Under the ERP, with considerable support from donors, Ghana undertook emergency repairs and rehabilitation of parts of its transport network, and initiated generally sound and pragmatic institutional reforms. While these measures averted complete breakdown of the transport system, much remains to be done to restore its capacity to meet current and future needs, to strengthen management, rebuild sector institutions and to make transport operations competitive, cost-effective and efficient. 23. To successfully restore adequate transport capacity, particularly for the road system, and rebuilding of efficient sector institutions, the GOG sought donor support. The International Development Agency (IDA) sponsored First Transport Rehabilitation Project (TRP-1), which started in 1988, marked the beginning of a phased programn for sector-wide rehabilitation and strengthening. The Second Transport Rehabilitation Project (TRP-2) and the National Feeder Roads Rehabilitation and Maintenance Project (NFRFIP) followed. Future support in the pipeline, in addition to HSIC, includes the IDA sponsored Urban Transport Project (UTP), a proposed Multimodal Transport Project (MTP), a proposed Second Feeder Roads Project (FRP). These projects constitute a well conceived program for phased rehabilitation. 24. The road network is the most important part of Ghana's transport infrastructure and consists of: (i) 14,724 km of trunk roads; (ii) 22,000 km of feeder roads; and (iii) 1,920 km of urban roads. Road transport, carries some 94 percent of national freight traffic and 97 percent of passenger traffic, much of it on trunk roads; the balance is handled mainly by the railways. 25. While recent road projects have made improvements in some areas, almost half the trunk road network remains physically run down, disrupting goods and passenger  traffic, causing a high incidence of vehicle breakdowns and high vehicle operating costs. Poor trunk roads continue to be a major constraint in all productive sectors of the economy. Despite increases in external assistance and significant improvements in domestic resource mobilization for rehabilitation and maintenance work, a continuing backlog of work will result in further deterioration in the trunk road network without additional resources. This situation has led to development of HSIC to focus on improvement of conditions of the trunk road network. Proiect Description 26. HSIC will complement and reinforce IDA's ongoing assistance to Ghana in support of its Accelerated Growth Strategy (AGS), and will continue efforts started under TRP-1 and TRP-2. The main objectives of the project are to: (i) accelerate implementation of GHA's trunk road stabilization program developed in 1987; (ii) remove physical bottlenecks to expansion of exports, farm production and labor mobility; (iii) protect earlier investment in trunk road infrastructure; (iv) reduce high vehicle operating costs through improved riding surfaces; (v) improve policies for road user charging, road maintenance funding, axle load control and enforcement; (vi) strengthen GHA, MRH, the Development Planning Commission (NDPC), and Ministry of Finance (MOF) institutional capacities; and (vii) strengthen the domestic private sector construction industry. 27. The project will cover portions of the Government's 1995 to 1998 trunk road stabilization program and consist of the following components: (i) reconstruction of 135 km of the following paved trunk roads: (a) Accra - Yamoransa - 115 km (b) Anwiankwanta - Kumasi - 20 km (ii) rehabilitation and periodic maintenance (resurfacing, resealing, regravelling) of 1,380 km of paved and gravel trunk roads under International Competitive Bidding (ICB) and Local Competitive Bidding (LCB) packages. 8  I- (iii) purchase of equipment, tools and spare parts for road maintenance, workshops, laboratory and training; (iv) purchase of equipment, tools and other provisions for road safety, axle load control and highway patrol; (v) consultant services for engineering design and studies, and for supervision of contract works; (vi) strengthening of GHA, MRH, NDPC and domestic private sector contractor capacities through training, technical assistance, and through demonstration on practical field operations, in particular on bitumen surface dressing operations. 28. HSIC rehabilitation work focuses on trunk roads which are not amenable to labor intensive types of road work. Although labor-intensive methods would employ and involve local communities in road rehabilitation work, such methods for trunk roads would make HSIC much too time consuming and would decrease the effectiveness of the project. Therefore, capital-based methods will be used in the rehabilitation works. 29. GOG expects positive economic impacts from HSIC, especially increased agricultural production due to improved road access to markets and improved distribution of inputs. Significant impacts are expected in cocoa and maize production especially. Improved transportation of agricultural products will enable farmers to obtain higher prices since goods will be of higher quality when they reach the market. According to a review for the Medium Term Agricultural Development Programme, recent improvements in rural road rehabilitation have already begun to improve marketing of agricultural commodities. Also, it is expected that rehabilitated roads will increase transport of cocoa, other agricultural products and charcoal from more remote areas as a result of decrease transportation costs. Further, the rehabilitation of roads will increase social mobility, domestic market distribution system and information exchange. 30. The World Bank is planning a detailed study of the effects of HSIC on rural income redistribution and related socioeconomic impacts. This study will be carried out during the second or third quarter of 1995. 31. Increases in local economic activity, such as marketing of rural products including cocoa and charcoal may have negative environmental impacts. For example, pressure to expand land area used for agriculture and excessive exploitation of forest resources often lead to environmental deterioration. 32. The EIA described in this report was undertaken before final determination of roads to be included in HSIC. After completion of fieldwork several roads sections were added which were not surveyed (see Environmental Impacts Section and Appendix 7). 9  BASELINE DATA COLLECTION AND ENVIRONMENTAL DESCRIPTION 33. Procedures adopted during this environmental assessment are intended to meet both World Bank requirements and those of the GOG. Report format specifically follows that suggested by the World Bank for the most part. As noted above, the EPA of Ghana is developing its own procedures and guidelines for EIA in general and the road sector in general (see also Appendix 11). Methodologv 34. ELAs of specific road corridors earmarked for rehabilitation in HSIC (as in the World Bank list of road sections from November 1994) were undertaken through site visits from 13 December until 20 January 1995, to assess the primary and secondary impact of the HSIC on the environment. Appendix 6 details the dates and names of the road sections visited. 35. Environmental impact surveys of the road sections in the HSIC (see Appendix 8 for site-specific EIAs) followed guidelines in the World Bank Environmental Assessment Sourcebook (1991): (i) Each environmental survey included a review of both direct and secondary impacts of a particular road section as well as mitigation measures for minimizing impacts in terms of: a. critical issues related to sensitivity of the ecological sites adjacent to the road works; b. land-use patterns and related socioeconomic effects; c. impacts to specific sites of importance such as protected areas and areas of cultural or religious significance; d. impacts to the socioeconomic environment, including impacts to existing homes, community market sites, and prevailing sources of livelihood at a particular site; and e. critical issues related to impacts from the operations of the road work, such as impacts from noise, operation of machinery and winning of raw materials for rehabilitation.  (ii) Information was collected by: a. visiting each road section to observe the present environmental situation and writing qualitative reviews of likely impacts to the physical environment at that site; b. undertaking consultations with local authorities and affected populations, both with beneficiaries as well as disadvantaged groups; C. undertaking discussions with NGOs and community groups or their representatives; and d. reviewing existing written data on the physical, cultural, and socioeconomic environment at that site. Baseline Environmental Conditions 36. HSIC trunk roads pass through a variety of broad ecological zones throughout the country. An understanding of these basic environmental features and concomitant human activities is vital to EIA and resultant planning of appropriate mitigation measures. Roads visited during the EIA fieldwork covered all six ecological zones relevant to HSIC. Descriptions of each zone are given in Appendix 3. More detailed ecological, land use, impact and mitigation information for each road section visited is provided in Appendix 6. 37. Ecological zones of relevance to HSIC range from 750 mm to 2100 mm mean annual rainfall; from dry savanna to rain forest; and from mangrove swamps and coastal grasslands in the south to bushland in the north. The roads in question traverse areas where forest products and wildlife are significant resources. However, the main economic activities of local communities are agricultural. A wide variety of crops is grown. Maize (Zea mays) is a common staple in most areas, although Guinea corn (Sorghum spp.) is grown in drier regions. Cacoa is an important cash crop in the moist forest zones. 38. Road sections visited are in poor condition. Appendix 5 illustrates the factors leading to and the overall process of deterioration in the absence of adequate maintenance. Tarred roads have broken shoulders and potholes; gravel roads are badly corrugated and, in some instances, reduced to virtually impassable bush tracks. Many bridges are in poor repair and are too narrow for two-way traffic. During EIA fieldwork it was noted that a few HSIC road section appear to have been rehabilitated already (see Appendix 7). 39. In most road corridors soil erosion is a serious problem due to inadequate design of runoff drains and culverts. Additionally, improper revegetation of embankments on 11  bridge abutments and gravel borrow pits leads to increased water and wind erosion. Road segments in the vicinity of settlements invariably have eroded shoulders, and in extreme cases shoulder drops and gully erosion are often severe. Foundations of many roadside buildings are extensively eroded. The erosion is caused by increased runoff from the roads which have inadequate drainage for runoff control. This problem is exacerbated by negative environmental practices such as denuding of vegetation on hillsides and burning of ground cover vegetation in some areas. 40. In many settlements houses and other buildings are built too close to the road. This problem will make road rehabilitation and operation of road machinery difficult. These buildings also constitute a potential safety hazard to road traffic and pedestrians. 41. Road safety measures in most settlements are poorly implemented. Speed limits are not enforced and pedestrian crossings are absent or ignored. Pull-off areas for vehicles in settlements are either absent or in need of rehabilitation. 42. Borrow pits have not been rehabilitated. They have neither been levelled nor revegetated. These pits fill up with water during the rains when they may be used for livestock watering. They normally dry up during the dry season. During wet seasons they pose a significant health hazard for water borne diseases such as malaria and schistosomiasis. 12  ENVIRONMENTAL IMPACTS OF THE HSIC PROGRAM 43. HSIC will rehabilitate existing roads, the alignments of which already exist. However, in many cases, these roads have deteriorated to such an extent that the rehabilitation work in HSIC will be similar to new road construction in many areas. Although direct effects on land tenure and related factors will be unimportant, secondary impacts such as greater use of natural resources or growth of roadside settlements as a result of increased access could be significant. 44. Following are some of the more significant primary, or direct, environmental impacts commonly associated with road construction, or the extensive rehabilitation envisaged under HSIC. (i) Clearing around the right-of-way or for borrow pits may damage ecologically sensitive areas such as forests, wetlands and wildlife refuges during capital- intensive rehabilitation of the type envisaged in HSIC. (ii) Sedimentation or pollution of streams and other water bodies may result from road works such as vegetation clearing, and from operation of heavy machinery itself. (iii) After road rehabilitation further sedimentation may occur as a result of inadequate or poorly designed erosion control and drainage measures. Pollution levels may increase as a result of improved access for people and livestock as a result of drinking, waste water and washing activities. (iv) Direct effects on roadside communities may include health problems resulting from excessive noise and dust during road work, and as a result of increased traffic after completion. Road safety problems may also be increased during and after rehabilitation work. 45. Secondary impacts commonly resulting from extensive road rehabilitation are listed below. These result from increased access and commercial activity for the most part. Although these impacts are indirect, they are often as important as direct effects, in both positive and negative aspects. However, negative secondary aspects are often more difficult to mitigate, since they spread beyond direct responsibilities of road agencies. (i) Shifts in land-use and ownership may occur due to increased land value, opening of new areas to markets and delivery of inputs and social services. (ii) Settlement patterns may change (for example, growth of existing villages or formation of new settlements) as a result of increased commercial activity along the road corridor.  (iii) Exploitation of forest products and wildlife may increase as result of market access or land use changes, leading to a decline in the natural resource base and biodiversity. (iv) Changes may occur in cultural practices and traditions as a result of increased exposure to outside influences. General impacts of HSIC 46. HSIC will have positive impacts on road management since one of the objectives of HSIC is to strengthen public sector agencies involved in the road sector. Part of this improvement will include strengthening GHA's capability to supervise or undertake ElAs and to monitor enviromnental impacts of road rehabilitation activities. Details of proposed plans for institutional strengthening of GHA with regard to environmental management are found in the section on Environmental Management and Training of this report. 47. Use of capital-based technologies for HSIC will involve use of graders, bulldozers and large rollers to shape and compact the roads, and position reinforced precast concrete culverts for drainage. These technologies utilize large amounts of soil for the road bed, and for covering culverts to meet engineering requirements. Capital-based roads also feature side drains and runouts. However, because they are periodically maintained by large equipment, scour checks cannot be placed in the side drains to control erosion and watercourse sedimentation. 48. Capital-based construction methods require excavation leaving large areas that tends to fill with water. The contractor is required to remove and store the topsoil and then replace it and revegetate the area after completion of the work. However, contractors interviewed have not done this and do not appear to consider it a contractual obligation. The larger pits collect rainwater and runoff which potentially contributes to an increase in diseases such as malaria and schistosomiasis. These borrow pits also contribute to increased soil erosion. In some cases, excavated pits are left open for future maintenance activities. 49. The most notable direct adverse socioeconomic impacts from HSIC are those related to increased safety hazards to pedestrians caused by: expansion of automobile traffic (and speed); greater pedestrian road traffic resulting from expected increased commerce as road conditions improve; and the proximity of houses sited too close to the road to permit road rehabilitation to proceed efficiently. Positive impacts expected from the road rehabilitation, which form the basis of project viability, include: (i) savings in transport costs, both in time and through modal transfers; (ii) more efficient transport of produce to markets; and 14  I- (iii) increased access to social and health services. Summarv of ETA of HSIC Roads Sections 50. The following paragraphs summarize EIA field work on road sections visited in Volta, Eastern, Central, Western, Ashanti, Brong Ahafo, Upper East and West and the Northern Regions between 13th December, 1994 and 16th January. As noted earlier, roads visited were those expected to be included in HSIC at that time. Since then, there has been some modification to the planned road sections falling under the project. Nevertheless, the types of impacts listed for each ecological zone will likely be applicable to any new road sections in those zones included in HSIC. Detailed EIAs of each road section surveyed are found in Appendix 7. Road sections added to HSIC after the EIA fieldwork, but before completion of this report are also listed in Appendix 7. 51. Primary impacts listed above are prevalent on most HSIC road sections. It is unnecessary to repeat these impacts, for the most part, therefore. Secondary impacts are more subtle and are highlighted in the following paragraphs. 52. Most HSIC road sections do not traverse ecologically sensitive or protected areas, as demarcated in Appendix 3. If any road section are added to HSIC which pass through protected areas, GHA must ensure that construction is in accordance with guidelines for protected areas as specified by the Ghana Game and Wildlife Department (GGWD) and the EPA. It should be noted that HSIC improved roads may increase visitor (or illegal activity) access to sensitive areas even where such areas are some distance from the road. GGWD may wish to monitor such impacts. 53. A few HSIC roads are in ecologically or culturally sensitive areas which were identified during field work. Sensitive Area Road Corridor (i) Esem Epam Forest Reserve; Swedru - Akim Oda (ii) Kakum Forest Reserve; Jukwa - Asebu (iii) Gbele Game Reserve; Fian - Wahabu (iv) Brenya Lagoon; Abandze - Elmina (v) Asukese Forest Reserve; Sunyani - Acherensua Shrine Road Corridor (i) Sambo Shrine; Kwahu Tafo - Adawso (ii) Shrine at Faaman; Berekum - Sampa 15  54. Rehabilitation of these roads will increase access to these areas. In the case of the Gbele Game Reserve the rehabilitation of the Fian-Wahabu Road will impact positively by facilitating access of tourists to the reserve. This should indirectly generate income for the area which is considerably underdeveloped. The roads will have a positive impact on shrines by facilitating travel for those who wish to consult the oracles. Although visitor regulation to these areas is beyond the scope of GHA, the relevant authorities should monitor, and if necessary control increased visitor use (see Environmental Management and Training Section of this report). 55. A large number of unimproved roads in HSIC are almost impassable. Rehabilitation of such roads will increase access to rural areas in a similar way to new road construction. Larger-scale commercial agriculture (including cocoa) will benefit in similar ways. However, enhanced transport could induce a shift in land use if more land is put into production. Demand for agricultural land could result in increased pressure on forest resources, since land for expansion of production is generally scarce in many areas. 56. Improved roads may also affect logging of national forest. It is not expected that this will result in increased production by licensed timber concessionaires, since their quotas are strictly imposed and regulated. However, unlicensed loggers are harder to monitor and may increase pressure on forest products. The Forestry Department monitors cutting of all primary species. Class 1 species are individually identified and concessionaires cannot cut these trees until they reach a specified girth. Due to the encroachment of agriculture, certain species, such as odum (Milicia excelsa and Milicia regia) are facing extreme pressure. Export of these hardwoods is now controlled, but rehabilitation of trunk roads could increase illicit felling. 57. In charcoal-producing areas, road improvement could increase cutting of trees. A rehabilitated road will make it easier to get the charcoal out of the area, increasing the economic potential of the product, but to the potential detriment of local wood stocks. An economic analysis of charcoal production, including transport costs, has not been done, but rehabilitation of roads will affect the amount and price of charcoal produced. 58. A significant secondary impact of rehabilitated roads could be the increased soil erosion if the roads are not routinely maintained. Sustainability depends on the contribution of labor by the communities served by the roads. Although beyond the immediate scope of this EIA, it is crucial that a planning process be developed that provides methodologies and techniques for facilitating community participation in the road maintenance to minimize future environmental impacts. 59. In most settlements, very few pedestrian crossings, traffic control systems and overpasses have been erected. Safety patrol personnel were also non-existent. There is potential for increased pedestrian-vehicle and vehicle-vehicle conflicts as traffic volume and speeds increase as a result of rehabilitation. 16  60. In some of settlements, houses are too close to the road resulting in pedestrian - vehicular conflict and potential accidents. Again this problem will likely grow as traffic increases. 61. Dust is a major environmental problem on gravel roads. When vehicles pass (or during high winds in the absence of vehicles), road dust in settlements is an extreme inconvenience and health hazard. In the Northern Sector cyclists and passengers in open vehicles on untarred roads were seen to have nose guards for protection against dust. Dust also pollutes surface water used for drinking purposes. 62. In the northern half of the country, negative environmental practices such as burning of vegetation have almost eliminated ground vegetation cover and could be increasing runoff which in turn erodes the road corridors 17  MITIGATION AND MONITORING 63. The following recommendations to mitigate potential direct and secondary impacts of HSIC rehabilitated roads, and monitor implementation of those mitigation measures, have been written in accordance with the MRH/GHA Twenty Year Road Development Plan (1995-2015). Table 1 at the end of this section lists specific mitigation recommendations including, who should carry them out and when, and implications for project costs. Note that several recommendations in Table 1 stem from more detailed discussion in the "Environmental Management and Training" section of this report. 64. Recommendations to mitigate potential adverse environmental impacts of the HSIC are divided into the following categories: i) on-site environmental monitoring and supervision; ii) institutional strengthening and training; iii) environmental management; and iv) contractual compliance. On-site Environmental Monitoring and Supervision 65. Monitoring to ensure compliance with environmental mitigation measures will entail close collaboration with consultant(s) hired for HSIC to supervise the road rehabilitation work of contractors. 66. Development of the proposed EU within GHA will take time. Therefore, technical assistance from a specialist (i.e., a long-term consultant) with a background in environmental management, should be sought to work within GHA's Environmental Unit (EU), for a period of two years. EU staff will gradually assume the duties of this consultant, achieving full responsibility before the end of the second project year. This environmental specialist (a proposed Terms of Reference is presented in Appendix 9) will assist the three staff members proposed for the EU to: (i) oversee environmental aspects of the contractors work (in conjunction with the consultant who will be hired to manage the overall contractors work); (ii) establish an ongoing monitoring program to ensure that the recommendations made for mitigating the on-site impacts of HSIC are closely adhered to; 67. Cutting of hills for roads disturbs ecosystems in diverse ways. The environmental specialist should be enlisted before taking up hill road construction to help prevent landslides and soil erosion and the resulting severe damage to orchards, agricultural channels, natural streams and built-up areas which are sources of nuisance and expenditure. The environmental specialist, in consultation with site supervisor consultants should have authority to halt work or impose financial penalties on contractors for non-compliance with Ghanaian environmental laws or rehabilitation contracts.  68. Criteria should be established for tarring sections of gravel roads which pass through settlements with population equal to or more than , and with traffic flows equal to or more than . This provision will help ameliorate the widespread problem of dust which is especially important on road sections of gravel/laterite which run through settlements. The cost of tarring will be absorbed within the overall cost of the HSIC project. 69. Local public hearings, already initiated by GHA, on rehabilitation of road sections should continue and be expanded to include environmental concerns. GHA's EU, in conjunction with the long-term consultant, should attend these public hearings early in the project to ensure that environmental concerns are expressed. Over time, district GHA staff should be trained to assume this role. Assistance from EPA staff could be enlisted, also. 70. GHA should work closely with the EPA to develop road sector-specific EIA guidelines which will serve as a reference to assist local consultants and GHA staff to undertake road ELAs in the future. 71. Before final payment is made to contractors, stockpiling of topsoil and its replacement and revegetation of the road corridor and gravel pits should be required. The number of excavated pits should be minimized. 72. Design and contract specifications for HSIC, should include measures and costs regarding ways in which the highway landscape will be enhanced, through the use of such activities as group plantations, multiple row plantations and plantation of shrubs, grassing of embankment slopes and shoulders, filling borrow-pits or considering converting them to aquaculture ponds, and treating scars on the hill faces by planting shrubs and trees. These provisions should be specified in the bill of quantities of future tender documents so that contractors recognize the requirements during the preparation of tenders. 73. The GHA long-term environmental consultant, in conjunction with the consultant(s) hired to supervise on-site construction activities, will conduct EIAs for each road section prior to rehabilitation work in order to identify site and region specific impacts and to make certain that each road section utilizes environmentally sound practices. If the pace of the project requires it, additional short-term consultants will be hired to assist with these EIAs. 74. Proper environmental guideline documents (see bibliography) should be consulted when the environmental specialist or any other staff on the HSIC project assesses the conditions and structural adequacy of existing drainage structures and facilities with a view toward recommending improvements to meet hydrological and hydraulic needs. 19  75. Design specifications and contracts for HSIC should include provisions for adequate drainage for all roads, especially where they pass through human settlements, as these are prone to erosion when no drainage channels have been provided. Roadside drains in settlements should be covered to prevent accidents. 76. To reduce traffic accidents the road corridor in the vicinity of settlements, speed limits should be clearly posted and rumble strips and pedestrian crossings provided. Institutional Strengthening and Environmental Training 77. These issues are discussed in detail in the "Environmental Management and Training" section of this report. To ensure completeness of this mitigation section they are briefly listed as follows: (i) GHA should establish an EU in the Planning Division which will be staffed by three persons to oversee the management of all environmental activities of GHA; (ii) GHA should finalize and cost its a training plan, to ensure that environmental management is institutionalized into all GHA work (see Appendix 10). As a matter of urgency, GHA should recruit environmental science personnel to train highway engineers and managers in environmentally sound practices; and (iii) GHA should develop plans and a budget to allow the long-term consultant and staff from the EU to undertake environmental awareness campaigns including mobile training seminars on public participation in determining environmental impacts of road projects, and the public role in monitoring implementation of mitigating measures. Environmental Management 78. By the end of the two year tenure of the environmental specialist, EU staff should be trained and be ready to take over the ongoing supervision of environmental management of GHAs' activities, including HSIC. 79. EU staff should liaise and coordinate with EPA to develop environmental standards and policies for road construction, rehabilitation and maintenance activities. These provisions would include, but not be limited to, roads that cause direct impacts in crossing or passing close to wetlands, forests, wildlife sanctuaries, religious sites and other environmentally sensitive areas. 80. Interagency coordination arrangements should be developed to enable EU staff to L confer with other relevant government agencies at district and national levels to deal 20  with specific road sector issues (such as conferring with the Forestry Department to ensure that improved access does not cause forest loss). Contractual Compliance 81. Environmental protection clauses should be included in the construction bid documents and resulting contracts, with clear penalties for non-compliance. These clauses should define drainage requirements, dust control, erosion control, stream crossing, road safety, tree cutting, illegal poaching, or harassing of wildlife and control of contaminants such as fuel and lubricants. Landscape rehabilitation and enhancement clauses should also be included. 21  Table 1 Mitigation Plan for HSIC .~~~~~~~~~~~~~L' 1.1 GHA Within first four months of 2 years consultant Hire long-term project start-up salary, vehicle, running environmental specialist costs, benefits, housing, office equipment, secretarial support 1.2 Contractors supervised Throughout Absorbed as part of Tar road sections in by GHA consultants implementation construction cost of settlements HSIC Project 1.3 GHA District offices in Throughout No additional project Public hearings conjunction with long- implementation prior to cost term environmental rehab. of each section consultant and EU staff 1.4 EPA in conjunction with By end of 1995 Production and Develop Road-specific long-term environmental distribution costs EIA Guidelines consultant and EU staff 1.5 contractor supervised by Throughout Absorbed as part of Rehabilitate gravel pits GHA consultants implementation construction cost of HSIC Project 1.6 contractor supervised by Throughout Absorbed as part of Rehabilitate landscape GHA consultants implementation construction cost of HSIC Project 1.7 long-term environmental Throughout Absorbed in cost of Road section specific consultant and EU staff implementation prior to long-term environmental ElAs with GHA consultants rehab. of each section specialist 1.8 long-term environmental First quarter of start-up Expect that documents Collect and use World consultant and EU staff can be obtained free of Bank and other cost environmental guideline documents 1.9 Contractor in consultation Throughout No additional cost Drainage design with long-term implementation specifications environmental consultant and EU staff with GHA consultants 1.10 Contractor in consultation Throughout Absorbed as part of Road safety measures with long-term implementation construction cost environmental consultant and EU staff with GHA consultants 22  Table 1 Mitigation Plan for HSIC TASK. WHO WHEN :.'7~~~~>< :.:K<;:1'COSTM 2.1 GHA Within six months of Cost of 3 full time Establish Environmental project start-up professional staff and Unit (EU) support staff will be bome by GHA. Provision of additional equipment and supplies to be agreed upon between GHA and HSIC/WB. 2.2 GHA Training Division Finalization prior to (See Training Plan) Finalize and implement with assistance of long- project start-up Environmental Training term environmental Plan. This includes in- consultant and EU staff country and foreign training and study tours. 2.3 GHA, long-term Throughout implemen- Video production, Mobile public awareness environmental consultant tation, but prior to fielding mobile unit, l seminars and EU staff in rehabilitation of each information collaboration with Ghana road section dissemination materials Information Services and Ghana Education Service 3.1 GHA Six months prior to end Absorbed as part of Fully operational EU of two year tenure of training and long-term environmental establishment of EU specialist 3.2 EU staff Throughout implemen- In accordance with legal Legal compliance with tation, but prior to compensation compensation rehabilitation of each regulations regulations road section 3.3 Long-term environmental During first two years of No additional cost Develop road-related consultant and EU staff project implementation environmental policy in collaboration with EPA and other appropriate GOG line agencies 3.4 Long-term environmental Prior to and during No additional cost Inter-agency coordination consultant and EU staff rehabilitation of each with local GHA office and road section other GOG line agency representatives 4.1 and 4.2 Long-term environmental Prior to issuing Absorbed as part of Environmental protection consultant in conjunction rehabilitation contracts construction costs clauses in rehabilitation wcth HSIC FMU contract 23  Additional Mitigation Measures 82. The measures listed above (and in Table 1) are regarded as the minimum required to ensure that HSIC's environmental impacts are minimized. In the following paragraphs a series of suggestions is made which would further enhance road rehabilitation work. Their incorporation into HSIC should be considered during negotiations between GHA and the World Bank. 83. GHA should consider the development of a spatial data base, such as a Geographic Information System (GIS), to assist in recording maintenance activities, designing drainage systems and storing information on land-use patterns adjacent to roads. In developing such a system, GHA should consult with EPA and other government agencies to ensure compatibility with other existing or planned GIS systems. 84. GHA will be hiring consultants, including local consultants, in the near future to conduct studies on engineering details for development of HSIC tender documents. These consultants should consider all of the recommendations in this report and the EIA Guidelines found in Appendix 11. 85. Increase in truck transport will increase demands for rest places, toilet facilities, eating places, vulcanizing shops, and repair facilities along the trunk roads. The present unsightly growth of shacks and service shops along the highways cause a visual intrusion and unhealthy and unsanitary conditions. Private-enterprise should be required to develop properly planned wayside amenities for truck-drivers. 86. Truck parking places should be planned and constructed along busy roads. Operation and maintenance of the complexes, including the construction of building, could be met from a revolving fund operated by a Society of Truck Operations. 87. In areas where erosion of foundations of roadside houses is very severe it was noticed that stones are piled around the foundations to counteract erosion. This is an indigenous method of erosion control which could be propagated country-wide. 88. Burning of vegetation on the road shoulders is a countrywide practice which should be discouraged. In addition to broader environmental concerns, darnage to the fabric of the road occurs due to heat and indirectly as a result of erosion in the denuded landscape. This problem was noticed in several areas during the field visit such as on the Kpandu-Adomi-Ho corridor. Cutting the weeds by the edge of the road or the use of an environmentally benign chemical could reduce this problem. 89. While it is not recommended that existing buildings be removed, in the future planning and zoning laws should be strictly enforced to reduce these conflicts to prevent construction of buildings too close to roadways. Existing regulations are 24  regularly flouted throughout the country. The Town and Country Planning Department should enforce these laws more rigorously. 90. Problems with consistent labor supply for routine maintenance of smaller trunk roads have developed due to lack effective incentive systems. A better understanding of available labor and incentive structures of rural communities is necessary to facilitate community participation in road maintenance. To enhance this understanding, an applied research effort is proposed. Several communities in diverse ecological and socioeconomic situations should be selected for case studies that identify the following key variables affecting community participation in road maintenance: (i) public opinion on the effect of a road section on their socioeconomic condition and the relative importance road rehabilitation to the community; (ii) seasonal household and community labor profiles (by sex) and constraints; (iii) spatial location of households in relation to the rehabilitated roads and their participation in maintenance; (iv) the role and influence of traditional and other leaders in mobilizing community work efforts; (v) the role of direct incentives in community participation in road maintenance; (vi) major beneficiaries of the road in the community and their contribution to routine maintenance; (vii) the influence of proposed GHA and other training programs on community- based maintenance; and (viii) the potential role of communities in evaluating direct environmental impacts of road rehabilitation; Results of these case studies could be used by GHA and road committees to develop rapid techniques for identifying the key incentives and constraints within specific communities and facilitate community participation in maintenance of smaller trunk roads. 25  ENVIRONMENTAL MANAGEMENT AND TRAINING 91. To date, there is no specific environmental management entity in the structure of GHA. For the road sector, limited environmental reviews, often a few paragraphs, are presently conducted for rehabilitation projects. Furthermore, findings of these limited environmental studies are not necessarily incorporated into projects. EIAs are not systematically undertaken of road projects. 92. Recent passage of the Environmental Protection Act legally mandates that developers submit EIAs to the Environmental Protection Agency (EPA) for all infrastructure projects, including road rehabilitation. To reflect this increasing attention being focused on environmental protection in the framework of Ghana's development programs it has been recommended that GHA add a new dimension to their organizational structure, that of environmental management and impact assessment.1/ Appendix 11 provides proposed guidelines for road-related ELAs and EPAs formatting requirements for EIAs. 93. The following recommendations are made to enhance environmental management capability in the road sector. These recommendations cover institutional structure within MRH and GHA; intersectoral coordination at national and local levels; training in environmental aspects of road development; and public consultation and participation. Although recommendations pertain to HSIC in particular, they reflect a broader interest in strengthened environmental management for the road sector as a whole. HSIC could usefully function as a pilot program in this broader context. Key recommendations are included in Table 1 of the "Mitigation and Monitoring" section of this report. Institutional Structure 94. GHA's institutional capacity should be strengthened to prepare ELAs of plans and projects in order to ensure that biophysical and human environmental concerns are considered in the planning and implementation of roads programs. The specific objectives should be to: (i) enhance the capacity of GHA to commission, supervise and critically assess ELMs (and in some circumstances to undertake ELAs itself); I/Based upon the results of two recent organization and management duties undertaken for the GHA (Report on the Organizational, Management, and Institutional capacity Assessment study of the GHA, Practical Management Associates, 1994 and The Report on the Revision of Organizational Structure for GHA, PAS 1994) a revised management structure is currently under consideration. However, no provisions were made in either of these two studies for incorporating environmental impact assessment capability into the proposed GHA structure. 26  (ii) identify prevalent negative environmental impacts of typical road projects on ecosystems of the country and determine practical measures that would result in the reduction of environmental damage; (iii) identify or develop appropriate training materials on environmental management of road development, and arrange training; (iv) create or strengthen an interdisciplinary capability throughout the country, especially intersectoral coordination at the local level, to assess environmental impacts (primary and secondary) of projects and ensure implementation of mitigation measures; and (v) promote environmentally sound development through the application of engineering techniques which reduce environmental deterioration to the lowest feasible level. 95. An Environmental Unit (EU) within the Planning Division of GHA should be established as a condition of HSIC implementation (see Appendix 8 for current and recommended organizational structure of MRH and GHA). In the first instance, this GHAEU should comprise an environmental manager overseeing two environmental supervisors, all of whom are suitably qualified in environmental management issues. The unit will have responsibility for commissioning and supervision of EIAs, monitoring ongoing environmental aspects of road construction and rehabilitation projects, and coordination with regional GHA staff who will also be trained in environmental management. GHAEU will be responsible, as necessary, for hiring and developing terms of reference for outside specialists to undertake EIAs and monitor implementation of mitigation measures. 96. A functional EU will take several months to be established, and longer to become functional. To ensure proper environmental supervision of HSIC in the meantime, it is recomnmended that GHA hire a (preferably local) long-term environmental consultant for the first two years of the project. This consultant would work with staff of the embryonic EU in initiating the tasks outlined above, in addition to monitoring on-site rehabilitation activities listed in the "Mitigation and Monitoring" sections of this report. 97. More specifically, the long-term consultant would work with the other HSIC consultants, hired to supervise rehabilitation contractors, to ensure compliance with established environmental standards developed as a result of this ELA. If new road sections are included in HSIC, this consultant would perform such site specific ELAs as are necessary. Suggested Terms of Reference for the long-term environmental consultant are provided in Appendix 9. L 27  98. Although outside the immediate scope of HSIC, it is recommended that other MRH departments (DFR and DUR) establish similar environmental units. A coordinating Environmental Committee (MRHEC), composed of representatives senior staff of each EU, will be essential to ensure consistency in environmental procedures throughout MRH. MRHEC will help formulate environmental policy and standards for road projects on an ongoing basis; discuss factors that hinder effective implementation and enforcement and ways to improve the system; discuss ways to improve EIA procedures (including incorporation of expertise from existing academic, NGO, and private sector firms); and review experience of other countries in Africa, and other regions in formulating effective strategies for dealing with environmental aspects of road projects. 99. Activities of MRH EUs and MRHEC must be coordinated closely with EPA. For example. EPA is currently working with MRH in developing EIA guidelines for the road sector. This relationship should be a starting point for close consultation on environmental management issues. EPA representatives should be present as advisors and active participants in MRHEC meetings to ensure that MRH policies and practices comply with national requirements. At the local level also, EPA should be intimately involved in ensuring consultations with local groups during EIA preparation, monitoring implementation of mitigation measures, and coordination with other government agencies (see below). Interagencv coordination 100. At the national level it is desirable to create a National Environmental Coordination Commnittee (NECC) to determine policy and provide guidelines for the formation of environmental policies which relate to roadways and other infrastructure development. This committee would be convened by EPA with representation from key ministries and agencies involved in infrastructural activities, including MRH, the Ghana Water and Sewerage Corporation, the Electricity Corporation of Ghana, the Volta River Authority, Posts and Telecommunication and Town and Country Planning. NECC would guide the development of industry and infrastructure in Ghana to ensure that environmental considerations are included in planning and policy formulation processes. 101. Coordination with other sectors is also important. As noted in the "Environmental Impacts" section of this report, road rehabilitation has reciprocal implications for exploitation of natural resources. For example, agricultural land use changes may occur, patterns of exploitation of timber and fuelwood may be impacted, and bushfires may have detrimental effects on rehabilitated roads. Clearly, GHA is not responsible for regulating such activities. These impacts are most noticeable at the level of individual road sections. Therefore, coordination should be at the regional or district level involving relevant agencies and EPA and be in consultation with local communities. 28  Training 102. In view of the limited consideration of broad environmental concerns in the past, a significant training program is necessary to enhance environmental management capacity at MRH. While this effort must focus on GHA for the purposes of implementing HSIC, it will be more cost effective if DFR and DUR are included, rather than conducting separate training programs. Training should include MRH staff at central and local levels and be coordinated by the MRHEC recommended above (or by the GHAEU if other departments do not participate at this stage). 103. An appropriate training program will include workshops and seminars, field visits and on-the-job training. Although most training will be in Ghana, efforts should be made by GHAEU and EPA (with assistance from the World Bank) to identify suitable regional training programs and study tours which MRH staff could attend. 104. Details of suggested elements of a training program are included as Appendix 10 (along with GHA's proposed training plan. Salient recommendations for the shorter- term include: a) initial training for selected management and senior engineering staff at central and regional levels should consist of a training module of 3 - 5 days based on the World Bank Environmental Assessment Sourcebook and Roads and the Environment: A Handbook in addition to HSIC road section case studies; b) an Environmental Training Handbook for GHA staff should be developed that demonstrates procedures for environmentally sound methods of soil stabilization, drainage, gravel winning, and minimizing damage to and restoration of adjacent areas; c) during further design phases of HSIC, World Bank staff or consultants should help to identify methods, approaches and programs to train staff on integration of environmental concerns into GHA planning, design and training activities. d) GHA staff and potential private-sector consultants should participate in the upcoming training workshops which will be sponsored by the EPA on "preparing EIA reports in accordance with the EPA new requirements and guidelines." 105. In the longer-term MRH management, environmental and engineering staff should become conversant with EIA methodology and environmental management related to road construction, rehabilitation and maintenance procedures. Such training should include secondary impacts as well as the more obvious direct effects of roads, systems of interagency cooperation and public participation. 29  Public Participation 106. GHA has recently introduced a process of conducting public hearings as part of planning of road rehabilitation works. Public involvement can potentially provide diminished likelihood of subsequent environmental and socioeconomic problems along road corridors and surrounding areas. GHA plans to systematize such hearings as a regular part of the planning process. The minutes of three recent public hearings conducted for HSIC roads by GHA are found in Appendix 12. These minutes show the type of valuable information the public can provide with respect to their knowledge of local conditions and the planned road designs. However, it is clear that environmental issues are rarely mentioned at these hearings. 107. It is recommended that these public hearings be a requirement of rehabilitation of road sections under HSIC. However, their scope should be extended to specifically include environmental concerns. As local inhabitants may not be familiar with the means of mitigating adverse impacts that they routinely encounter, a public education campaign is required to familiarize the public about their rights and responsibilities concerning EIA. 108. GHA, with assistance from EPA, should develop, and use during implementation of HSIC, mobile training seminars for communities along or close to the road corridors. These seminars (perhaps eventually including videos) would describe the EIA process including primary and secondary impacts which may affect the environment and livelihood of these communities. Such seminars would precede public hearings. These seminars could also stress the importance of community involvement in road maintenance and long-term sustainability of road systems. Assistance should be sought from the Ghanaian Education and Information Services. 109. Public participation in monitoring implementation of mitigating measures during HSIC should be encouraged. Provided the public is made sufficiently aware of environmental requirements of rehabilitation contractors (see above), community members are a powerful influence upon compliance. GHA should ensure that consultants supervising the contractors canvass public opinion on environmental (and other aspects) of performance. 30  aA- APPENDICES  Appendix 1 Terms of Reference  APPENDIX I GHANA HIGHWAY AUTHORITY TERMS OF REFERENCE FOR CONSULTING SERVICES (EIA) FOR THE HIGHWAY SECTOR INVESTMENT PROJECT (1995-1997) 1. 0 INTRODUCTION 1.01 The transport infrastructure faced virtual collapse during the 1970's and early 1980's due to shortage of foreign exchange and prolonged neglect of maintenance and rehabilitation. However, in 1983, Ghana launched the Economic Recovery Program (ERP) to turn the economy round. This program emphasized, as part of its strategy, the rehabilitation and maintenance of * all modes of transport infrastructure. Under the ERP, with considerable support from IDA and other donor agencies, Ghana has undertaken emergency repairs and rehabilitation of parts of its road transport network.. However, the restoration of adequate transport capacity, particularly for the road system and the rebuilding of efficient sector institutions, will take about a decade or more of concerted efforts to complete. The Government has therefore formulated an Accelerated Growth Strategy to generate additional resources to facilitate improvement in overall standards of living and quality of life, which will necessitate even larger investment in the transport infrastructural base of the country. .Complementary to the foregoing in the .road 'sector bhave been a well-conceived program for phased rehabilitation of the transport -sector... and . its instituti9ns ... 'Included in.... the . packaged programme are- the. Transport' Rehabilitation. Project (TRP-1), the Second Transport Rehabilitation Project' (TRP-2), * the National. Feeder Roads Rehabilitation and Maintenance Project.. (NFRRMP), an Urban Transpor.t Project (UTP), the * proposed Highway Sector Investment. Credit (HSIC), a proposed Multi-modal Transport Project and a proposed' Second Feeder Roads Project. 1.02 The project will complement and reinforce IDA's 'ongoing assistance' to Ghana. in support of its Accelerated Growth StrategyJ(AGS), and will continue the efforts started under TRP-1 and TRP-2. The main objectives of the project are to: a) accelerate implementation of GHA's trunk road improvement program developed in 1978; b) remove physical bottlenecks to the expansions L. - .of exports, farm production and labour - mobility; 1  APPENDIX 1 c) protect earlier investment in trunK. road infrastructure; d) reduce the high operating costs through improved riding surfaces; e) improve policies for road user charging road rmaintenance funding, axle load control and road traffic-safety; f) strengthen GHA, MRH and MOTC institutional capacities, and g) strengthen the domestic private sector -construction industry. 1.03 DESCRIPTION OF THE PROJECT The programme is part of.the Government's 1995 to 1997 trunk road improvement programme and consists of the following components: a) periodic maintenance (resurfacing, resealing and regravelling) of 1600 km of paved and gravel trunk roads; b) rehabilitation of 300 km of paved trunk roads; -Yt5;-5--,it-;;;vj- -_-S-- recons c ;on`, v .ed'-.rink:-ro'ads;- * .i ,. .. \ - .-: .. .. - . - . -* w 'wrX ; . v' ' - .i-e - -a? ----purchas& -eo nd.spared.parts ,or ,-,,..,,...,.,.;-, R n.,-, wo,r3shops, .labporatory and - ~~trai'ning - - e): purchase..of equipment, tools and. other provis'ons o road s@fety, axle load control and- highway 'jpatr6l~t