Mozambique - Municipal Development Project : environmental impact assessment

E437 MUNICIPAL DEVELOPMENT PROJECT, MOZAMBIQUE ENVIRONMENTAL ANALYSIS fr S .1 :t Maputo, Beira, Quelimane, Nampula and Pemba On Behalf of the World Bank FILE COPY C ~~~~~~October 2000  Municipal Development Project: Environmental Analysis 1. PROJECT CONCEPT ...................................................... 5 1.1 BACKGROUND ...................................................... 5 1.2 PROJECT DESCRIPTION ...................................................... 5 1.3 ENVIRONMENTAL ANALYSIS ...................................................... 6 2. REVIEW OF WORLD BANK OPERATIONAL POLICY FOR ENVrIRONMENTAL ASSESSMENT ....................................................... 7 2.1 RECOMMENDED APPROACH TO ENVIRONMENTAL ASSESSMENT ................................ 8 3. LEGAL AND INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENT IN MOZAMBIQUE ...................................................... 8 3.1 NATIONAL ENVIRONMENTAL MANAGEMENT PROGRAMME (NEMP) ................. 9 3.2 THE FRAMEWORK ENVIRONMENT LAW ....................................................... 9 3.3 MINISTRY FOR THE COORDINATION OF ENVIRONMENTAL AFFAIRS - MICOA. 10 Nampula ........................................................ 15 Quelimane ........................................................ 16 Mocuba ........................................................ 16 3.4 RELEVANT LEGISLATION RELATED TO MUNICIPALITIES .................................. 19 4. CAPACITY AND ACTIONS OF MUNICIPALITIES TO ADDRESS ENVIRONMENTAL IMPACTS ...................................................... . 20 4.1 APPROACH .20 4.2 MAPUTO MUNICIPALITY .20 4.3 BEIRA MUNICIPALITY .24 4.4 QUELIMANE MUNICIPALITY .26 4.5 NAMPULA MUNICIPALITY .28 4.6 PEMBA MUNICIPALITY .33 4.7 MINOR MUNICIPALITIES .36 Maxixe ............... 36 Angoche ............... 37 Cuamba and Manica .............. Error! Bookmark not defined. 4.8 COMPARATIVE ANALYSIS OF TECHNICAL CAPACITY ......................................... 38 5. THE CIVIL WORKS PROGRAM ........................................................ 39 5.1 PREAMBLE ........................................................ 39 5.2 DESCRIPTION OF CIVIL WORKS ........................................................ 39 Beira Municipality ......................................................... 42 Quelimane Municipality ......................................................... 42 Nampula Municipality .............. 43 Pemba Municipality .............. 44 5.3 ENVIRONMENTAL IMPACTS AND RECOMMENDED MITnGATION MEASURES ........ 45 6. GUIDELINES FOR IDENTIFYING ENVIRONMENTAL IMPACTS AND IMPLEMENTING MITIGATION MEASURES FOR THE MDP CIVIL WORKS PROGRAM ........................................................ 46 GENERAL ........................................................ 47 DRAINAGE CHANNEL CONSTRUCTION, REHABILITATION AND MAINTENANCE .............. 48 WASTE MANAGEMENT AND DISPOSAL ........................................................ 51 LATRINES AND SEWAGE ........................................................ 53 ROAD, BRIDGE, AND FOOTPATH REHABILITATION AND MAINTENANCE ........................ 55  Municipal Development Project: Environmental Analysis WATER SUPPLY SERVICES .............................................. 57 OTHER URBAN INFRASTRUCTURES ............................................... 59 7. TECHNICAL CAPACITY BUILDING ............................................... 60 7.1 COST ESTIMATES FOR COURSE PREPARATION AND FACLITATION .. 60 8. CONCLUSIONS AND RECOMMENDATIONS .............................................. 61 9. ANNEXES ............................................... 63 9.1 ANNEx I: MDP ENVIRONMENTAL ANALYSIS QUESTIONNAIRE ............................. 63 9.2 ANNEX II: PORTFOLIO OF PHOTOGRAPHS SHOWING EXAMPLES OF EXISTING URBAN INFRASTRUCTURES ............................................. 65  Municpal Development Project: Environmental Analysis Executive Summary This report presents the findings of an environmental analysis of the Municipal Development Project (MDP), which is the development stage of a long-term (10-15 years) program of Urban/Municipal Government strengthening funded by the World Bank. The project concept was developed in response to a general acknowledgement that the collapse of urban infrastructures in Mozambique is a consequence of their inability to withstand the ever-increasing human pressure, and that a major symptom of this decay process is chronic urban and peri-urban environmental degradation. The proposed MDP has four components: 1. Policy reform. 2. Municipal capacity building 3. Infrastructure investments 4. Project management design and supervision The MDP concept document identifies the environment as requiring special attention within the overall framework of the project. A critical assumption is that in general the project will bring about an improvement in environmental conditions in urban areas because one of its key development objectives is to improve urban infrastructures such as drainage, sanitation, water supply, and waste management. This can only be achieved through the successful implementation of civil works programs in parallel with dynamic awareness campaigns targeting user communities. The overall focus of the present analysis is technical capacity building to ensure effective environmental evaluation of the civil works component of the MDP, and specifically to: - Review World Bank operational guidelines for environmental assessment, and project concept documents, and identify the appropriate project category for the proposed spectrum of civil works. * Assess Municipal level capacity to conduct environmental assessments of the civil works component of the MDP. * Make recommendations concerning the level of capacity building required to ensure appropriate environmental assessment of civil works This analysis generated the following major conclusions: 1. According to World Bank operational guidelines for environmental assessment (EA), the construction envisaged for the civil works program are best classified as category C projects, as they are likely to have minimal or no adverse environmental impacts. Therefore, according to Bank requirements, beyond screening, no further EA of the civil works program is required. Consequently, simple guidelines for EA of the civil works program that can be implemented and monitored by Municipality technical staff have been developed for the MDP.  Muniapdal Developrent Project. Environmental Analysis 2. To facilitate EA of the civil works program a set of guidelines have been developed that specify the range of impacts and practical preventative or mitigation measures associated with individual civil works projects. Technical personnel involved in the day-to-day management of the civil works programs should use these guidelines. 3. The capacity to conduct environmental assessments is weak to non-existent across all Municipalities regardless of size, technical staff compliment, and range and level of academic qualifications. However, these are not considered to be critical selection criteria for training in EA. The knowledge required is more of a practical nature (common sense), and the most suitable candidates are those that have a working knowledge of civil works and/or have a management role during construction. 4. A one-week training workshop is recommended as the best approach to developing Municipal-level capacity to ensure effective EA of the civil works program. The workshop will begin with an overview of EA and current environmental legislation and then switch to a case study approach focusing on: . Analysis of environmental problems commonly experienced by Provincial Municipalities Practical application of the EA guidelines developed for the MDP * Site visits to civil works in progress and existing urban infrastructures that illustrate impacts and their prevention or mitigation Designing effective environmental awareness campaigns  Municipal Development Project: Environmental Analysis 1. Project Concept 1.1 Background The prolonged armed conflict (1 975-1992) had a profound impact on the urban centres of Mozambique. As the fighting escalated so did the rate of influx of rural people to urban centres. This migration trend did not stop after the signing of the peace accord; by 1995 the country's urban population had tripled. This large-scale process of resettlement by mostly poor migrants triggered the collapse and decay of urban infrastructure systems, which were simply not designed to cope with such a massive migrant influx. Some of the major urban service deficiencies include deteriorated roads, inadequate supplies of potable water, inadequate waste management, and poor drainage and sanitation resulting in widespread proliferation of water-borne diseases. The surrounding peri-urban environment has also suffered from the unsustainable exploitation of natural resources, notably fuel wood. Starting in 1998, new Municipal governments have been established in the country's major urban centres. In parallel, a process of legal reform gave rise to a new legal framework that gives Municipalities extensive administrative and financial autonomy. However, true empowerment of Municipalities requires a transition from the traditional thinking that was largely reliant on central government for decision-making. Furthermore, the lack of available investment funds and resources has hindered the development of systematic approaches to the provision of urban infrastructures and services by Municipalities. It is against this background that the World Bank formulated the Municipal Development Project (MDP) as a possible remedial intervention mechanism for the widespread inadequacies of urban infrastructures and services throughout Mozambique. 1.2 Project description The current project is the development stage of a long-term (10-15 years) program of Urban/Municipal government strengthening; targeting policy, legal, financial and institutional issues affecting three key areas: * Municipal governance and management * Municipal provision of infrastructures and services * Municipal finance and fiscal decentralisation In this context, the proposed MDP has four components: 1. Policy reform - consultants to assist with review of relevant legislation, regulations etc that relate to the policy reform agenda. 2. Municipal capacity building - technical assistance and training. 3. Infrastructure investments - high priority civil works (road rehabilitation, street paving, sewerage, sanitation, surface drainage, solid wastes, markets, and bus terminals). 4. Project management design and supervision - contract staff and consultants for design and supervision of civil works, equipment and operating costs.  Municipal Development Project: Environmental Analysis The first and second components include all 33 Municipalities, while the third and fourth component cover the country's five largest cities: Maputo, Beira, Nampula, Quelimane, and Pemba. In summary, the MDP expects to achieve three long-term development objectives: 1. Continue to develop the policy and institutional framework for Municipal governance, focusing on the Municipal finance and human resources systems. 2. Improve technical and financial capacity of Municipal governments to provide sustainable infrastructures and services. 3. Establish a replicable mechanism for financing urban infrastructure in five secondary cities. 1.3 Environmental Analysis The MDP concept document identifies the environment as requiring special attention within the overall framework of the project. A critical assumption is that in general the project will bring about an improvement in environmental conditions in urban areas because one of its key development objectives is to improve urban infrastructures such as drainage, sanitation, water supply, and waste management. This can only be achieved through the successful implementation of civil works programs, and hence with a prior knowledge of the general nature of the development activity, key potential environmental impacts can be predicted. Of major concern is to prevent or adequately mitigate against potential adverse effects of sewerage, sanitation and solid waste processing facilities on ground and surface waters. Where civil works proposals equate to large-scale development, environmental impact assessments will need to be conducted and must therefore adhere to the protocols outlined by MICOA. It is generally acknowledged that the collapse of urban infrastructures in Mozambique is a consequence of their inability to withstand the ever-increasing human pressure, and that a major symptom of this decay process is chronic environmental degradation. However, there are many causal factors linked to the environmental degradation that characterises urban and peri-urban areas, and it would be short-sighted to assume that the simple process of upgrading and rehabilitation of infrastructures will automatically result in environmental remediation. Human pressure per se may not necessarily be the cause of infrastructure system failure but rather it is the way in which such systems are used and maintained. In this context there exists a fundamental need to raise human awareness to enable the people to better understand the consequences of their actions. For example, under the high-density living conditions that characterise the informal settlements of the urban environment, conditions are optimal for the rapid spread of water-borne transmissible diseases typically associated with poor hygienic conditions (e.g. dysentery, diarrhoea, cholera etc). This example highlights the importance of conducting environmental education campaigns in parallel with the process of upgrading infrastructures to ensure that appropriate levels of awareness are achieved. This in fact may be the key to ensuring that the urban infrastructures essential to both human and environmental health are not allowed to decay or are misused in the same way again.  Municipal Development Project: Environmental AnalysiS 2. Review of World Bank Operational Policy for Environmental Assessment In this section the following World Bank documents are reviewed. * The World Bank Operational Manual (Operational Policies) - Environmental Assessment, January 1999. OP 4.01 (6 pages). * The World Bank Operational Manual (Operational Policies) - Definitions. January 1999 - Annex A. OP 4.01 (2 pages) * The World Bank Operational Manual (Operational Policies) - Environmental Management Plan. OP 4.01 - Annex C (2 pages) The purpose of this review is twofold: 1. To ensure that the present bank financed MDP project concept is environmentally sound, and 2. To assess the relevance of these documents to the proposed Mozambique MDP. The World Bank's environmental assessment (EA) operational policy establishes the fact that some level of environmental assessment is required for all Bank financed development projects. EA is presented as a dynamic process dependent on the nature, scale, and potential environmental impact of the proposed project. A typical EA will: * Evaluate a project's potential environmental risks and impacts in its area of influence. * Examine project alternatives. * Identify ways of improving project selection, siting, planning, design, and implementation by preventing, minimising, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts. * Include the process of mitigating and managing adverse environmental impacts throughout project implementation. * The Bank favours preventive measures over mitigatory or compensatory measures, whenever feasible. Depending on the nature and scope of EA, the following factors may need to be taken into consideration, and in an integrated way: * The natural environment (air, water, and land) * Human health and safety * Social aspects (involuntary resettlement, indigenous peoples, and cultural property) * Transboundary and global environmental aspects  Munmcipal Development Project. Environmental Analysis Other important factors that may require consideration include: * Varations in project and country conditions * The findings of country environmental studies * National environmental action plans * The country's overall policy framework, national legislation, and institutional capabilities related to the environment and social aspects - * Obligations of the country, pertaining to project activities, under relevant intemational environmental treaties and agreements Bank policy also requires that EA is initiated as early as possible in project processing and is integrated closely with the economic, financial, institutional, social, and technical analyses of a proposed project. The commissioning of EA work is the responsibility of the borrower, and the Bank reviews the findings and recommendations of the EA to determine whether they provide an adequate basis for processing the project for Bank financing. When the borrower has completed or partially completed EA work prior to the Bank's involvement in a project, the Bank reviews the EA to ensure its consistency with this policy. 2.1 Recommended approach to environmental assessment The operational policy provides a mechanism for project classification (four categories) according to project type, sensitivity, location and scale, and the range and magnitude of adverse environmental impacts. This classification process provides a simple mechanism whereby the appropriate EA approach can be determined. A screening exercise was undertaken to establish first, the nature and scale of the proposed civil works program (see section 5 below) and second, the range and scale of predicted impacts and pragmatic preventative or mitigation measures (see section 6 below) 3. Legal and Institutional Framework for Environmental Management in Mozambique In this section the legal and institutional frameworks for environmental management in Mozambique are summarised. In the context of the MDP, the key elements of these frameworks are: * The National Environment Management Program * The Environmental Law * EIA Regulations * The Municipal Law * The role of MICOA and Municipalities regarding environmental management in. Municipal areas  Municipal Oevelopment PrQject: Environmental Analysis 3.1 National Environmental Management Programme (NEMP) The National Environmental Management Programme (NEMP), approved by the Council of Ministers in 1995, seeks to promote and implement sound environmental policy. The NEMP represents the culmination of a series of initiatives and activities co- ordinated by the Ministry for Co-ordination of Environmental Affairs (MICOA). It is the master plan for the environment in Mozambique and contains a National Environment Policy, Framework Environmental Legislation, and Environmental Strategy. The NEMP consists of Sectoral Plans, for the medium and long term, which are intended to lead to sustainable development in Mozambique. Three policy areas are defined: * Rural * Coastal * Urban For rural areas, agriculture and forestry issues are considered the most important. In coastal areas mangrove degradation, coastal pollution, and erosion are the main issues to be addressed under the programme. For urban areas the degradation of sanitation systems and poor water quality are the most urgent issues. MICOA has been given the authority to oversee the implementation of the NEMP. To this effect, environmental rules and regulations are being devised and enforced. MICOA will evaluate policies of other sectors as well as their capacity to promote and implement sound environmental policy. The implementation of the NEMP will require a range of actions at all levels and across sectors. In accordance with the NEMP, MICOA, in close co-ordination with other ministries, private and civil groups, will work towards: * Development of inter-sectoral policies for sustainable development * Development and promotion of integrated resource-use planning * Promotion of sector legislation and of establishment of norms and criteria for environmental protection and sustainable use of the countries' natural resources * Creating conditions for law enforcement and environmental monitoring 3.2 The Framework Environment Law The Framework Environmental Law was passed by the Mozambican Parliament in July 1997. It was published in the official government gazette and is, therefore, in force. (Law No. 20/97, Boletim de Republica No. 40, 15t Series, 3d Supplement of the 7th October 1997). This law acknowledges the responsibility of the Government of Mozambique in the promotion and implementation of the National Environmental Management Programme. The aim of this law is to provide a legal framework for the use and correct management of the environment and its components such that it assures sustainable development.  Municipal Development Project: Environmental Analysis The Environmental Law is applicable to all public or private activities, which may influence the environment either directly or indirectly.' The salient features of the Law include the following: * The Law forbids pollution of the soil, subsoil, water or atmosphere. * With regard to liability, those who pollute, or in any way degrade the environment, are always under obligation to rehabilitate it or to compensate for the resulting damage. * The law also forbids the importation of wastes, except for that laid down in specific legislation.3 * Projects and operations that are likely to have a negative impact on the environment are subject to an Environmental Impact Assessment carried out by independent assessors. It also forbids all activities that may threaten the conservation, reproduction, quality and quantity of biological resources, especially those in danger of extinction.4 Licensing of activities that are liable to cause significant environmental impacts shall be required. The issuance of an environmental license shall be based upon an environmental impact assessment. In order to protect areas of recognized ecological and socio-economic value, environmental protection zones can be created. These protected zones may be national, regional or local and may cover land areas, lakes, rivers, marine waters and other distinctive nature zones. To ensure the effective co-ordination and integration of sectoral policies and plans related to environmental management at the highest level, a National Commission for Sustainable Development (NCSD), linked to the Council of Ministers, has been created (September 2000) by a provision in the Framework Environmental Law. 3.3 Ministry for the Coordination of Environmental Affairs - MICOA Central level The Ministry for the Coordination of Environmental Affairs (MICOA) was created from National Environmental Council in 1995. MICOA is responsible for implementing the National Environmental Management Programme and associated environmental policy and legislation. The main responsibilities of MICOA are: * To revise and develop sectoral policies * Formulate sustainable inter-sectoral development plans 'Article 3, of the Envirornmental Law 2 Idem, paragraph (g) 3 Idem 'Article 12 of the EnvironImental Law  Municipal Development Project. Environmental Analysis * Promote sectoral legislation * Co-ordinate policy implementation * Promote public awareness * Create regulations (e.g., for Environmental Impact Assessments) * Ensure that Environmental Impact Assessments (ElAs) are carried out as per Terms of Reference * Coordinate, assess and control the utilization of natural resources and, in doing so, to promote their conservation and rational use The Ministry, as indicated by its title has, primarily, a co-ordinating role. As environmental management is shared across sectors MICOA should promote the incorporation environmental dimensions into sectoral policies, programmes and activities. This signifies that a working relationship with all the other sectors has to be established. The success of MICOA's performance, therefore, depends to a large extent on the degree to which it manages to co-operate with the other sectors (including municipalities) as these sectors remain responsible for the integration of environmental matters in their own sectoral programmes. Municipalities, dealing with urban environmental issues are important partners. Enhanced cross-sectoral co-operation, in turn, is contingent upon confidence building with the sector partners and the clear definition of their respective roles and responsibilities. As MICOA is a new ministry, the process of building confidence with other sectors and defining and responsibilities and roles has taken time. The beginning of MICOA's first mandate (1995 to 1999) was characterized by limited co-operation with other sectors and a certain reluctance on the part of other the sectors to have their policies and programmes reviewed with regards to environmental issues. Since the establishment of MICOA in 1995, the situation has gradually improved. By the end of 1999, with the closing of it's first mandate, MICOA has become an accepted ministry with increased co-operation with other sectors of government, private sector and civil society. During the first mandate, the level of co-operation between municipalities and MICOA was variable and often dependent on personal relationships between individuals in the provincial directorates of MICOA and the municipalities5. Following the holding of Mozambique's second democratic elections in 1999 MICOA was awarded a second mandate under a new minister. The Ministry is now seeking to consolidate and strengthen its acquired position. In early 2000 MICOA was restructured and currently comprises five national directorates viz.: * The Directorate for Environmental Impact Assessment * The Directorate for the Management of Natural Resources * The Directorate for Land Planning * The Directorate for the Promotion of Environmental Awareness * The Directorate for Planning Each directorate comprises several departments (see Figure 1 below). SThis only refers to municipalities in provincial capitols as MICOA is currently only represented at the provincial level and not lower levels of govemment.  Municipal Development Project: Environmental Analysis Minister | ntltosunder MICOA| His Exec. Kachamila Vice-Minister His Exec., Mabjaia i| National l , Environment Fund| Provincial Directorates General Inspection . Training Centre To be nominated , for Territorial l__ __ __ I Planning | Permanent Secretary | | Ministers Offce |CentresMof (PS) Sustainable Dev. To be nominated Rural; Coastal; Urban Nat. Dir. of Human Dept. of Adm. And Dept. of International Legal Nat. Dir. of Human Dept. of Adm. And Cooperation Department Resources Finance Ms. Rosa Cesaltina Sr. Andre Sr. Samuel Sr. Francisco Lichacha Augusto Silva Nat. Dir. Territorial Nat. Dr. Env. Nat. Dir. EIA Nat. Dir. Env. Promotion Nat. Dir. Planning Planning Management Dra. Felicidade Dra. S6nia Silveira Dr. Banze Dr. A. Salazar Dgedge Dr. Evaristo Baquete Munguambe Dept. of Coastal Dept. of Quality Dept. of Env. Auditing Dept. of Training Dept. of Dissemination Zone (DGZ) Control (DQA) Dept. of Urban Dept. of Natural Environment Resources Dept. of EIA Review (DAU) Conservation l l (DCRN) l 'Office for Coordination of Conventions Figure 1: Central level MICOA organisational structure 12  Municipal Development Prcject: Environmental Analysis The role of MICOA regarding environmental impact assessment Regulating Environmental Impact Assessments (ElAs) is one of the most important roles of MICOA. This role requires significant interaction and coordination with other govemment sectors involved in development and investment projects and, consequently MICOA has assumed a much more visible and high profile. Initially, EIA in Mozambique was applied through the Law of Foreign Investment that was passed in 1993. However, there were no clear guidelines for carrying out ElAs under this Law. Nevertheless, the Law of Foreign Investment gave a certain level of legal support to control potential environmental impacts arising from project applications for investments, which were submitted to the Investment Promotion Centre. The Framework Environmental Law passed July 1997 specifically referred to the formulation of EIA regulations. In 1998 EIA Regulations were passed by the Council of Ministers and an EIA Department (within the National Directorate for the Management of Natural Resources) was created in MICOA in order to oversee the implementation of EIA regulations and procedures in Mozambique. During it's first mandate the EIA Department was small (comprising a department head plus four to five technical staff). This period was also characterized by high staff turnover including several changes of head. Due to the lack of human resources and operational support the EIA Department was generally unable to efficiently implement EIA procedures and regulations although this in no way reflects on the capacity of the staff per se: the staff in place attempted to carry out their tasks under difficult circumstances. In December 1999, an independent consultancy mission performed functional analysis and capacity needs assessment on the EIA Department. Based on the recommendations arising from this mission the EIA department has been upgraded to a national directorate and, consequently, the institutional and political importance of EIA is increasingly recognised both within, and outside of, MICOA. Concomitantly, co-ordination with other government sectors involved in development and investment projects has also improved. The competence of MICOA to review and process EIA Terms of Reference and reports has improved. Agreements of understanding have been informally negotiated with and accepted by the national directors in charge of tourism, industry and forestry and wildlife. Currently the EIA Directorate is working with the National Administration for Roads (ANE) in order to develop EIA guidelines for the roads sector. There have been comments, however, regarding the lack of specific information about the EIA procedures and the varying levels of cooperation. The role of MICOA regarding environmental standards Since 1997 MICOA has been developing environmental quality standards through the Environmental Quality Standards of Mozambique Projects (PEPA) with the following objectives: * To define and prepare adequate environmental quality standards for the country. * Through the establishment of a national committee, prepare regulations to be submitted to the Council of Ministries for approval.  Municipal Development Project: Environmental Analysis Draft environmental standard regulations have been prepared and discussed with representatives of relevant agencies. However, the draft is still (as of October 2000) undergoing revision before submission to the Council of Ministers. The role of MICOA regarding environmental management plans The National Institute of Physical Planning (INPF) has, until recently, been, responsible for urban and rural planning (mainly the former). In this role the INPF has coordinated the formulation of physical plans for all Provincial capitols, although only one (Nampula City) has been approved. Other cities have failed to institute and implement their plans on account of the lack of financial resources and technical capacity. After several years of negotiations, the INPF has been integrated into MICOA as the National Directorate for Territorial Planning (DNOT). The precise organizational aspects of DNOT are currently under discussion by MICOA's Consultative Council. Municipalities will, therefore, be working more closely with MICOA regarding urban planning. This provides opportunities for closer collaboration between MICOA and the municipalities and the development of modern principles of urban environmental planning. The Role of MICOA regarding environmental audit and inspection Environmental audit and environmental inspection are the tools specified in the Environmental Law for the control of activities that were in operation before the passing of environmental legislation in 1997 as well as all subsequent activities that have been implemented since 1997 with or without an environmental licence. Environmental audits should be required for all activities of high impact and pollution potential and should be performed by an independent environmental audit company. MICOA has started to draft environmental audit and inspection regulations for internal discussion and future external consultation. However, the present versions of the draft regulations still require considerable technical review and improvement prior to submission to the Council of Ministries for approval. Provincial level Since 1995 MICOA has been establishing Provincial Directorates in all the Provincial capitols. The level of organisation and capacity varies from Province to Province. MICOA is not represented at lower levels of government (i.e. District level) in any of the Provinces. The Provincial structures follow, but do not strictly adhere to, the structure at central level. Maputo The Provincial Directorate for Environmental Coordination Affairs Maputo Province is located in Matola, having a greater liaison with this Municipality. This Directorate is divided into three technical departments: * Department of Environmental Education * Department for Environmental Management * Department for Land Planning  Municipal Development Project: Environmental Analysis Only the Department for Land Planning has one technician with a university degree - an architect, who works with nine medium-level technical staff. In the Department of Environmental Education there are three medium-level technical staff and in the Department for Land Planning there are four medium-level technical staff. Medium- level technical staff are eligible to attend short-term courses on environmental management and environmental education on an ad hoc basis. This Provincial Directorate is relatively new, and to date all interventions by the Directorate have centred on Matola city and not Maputo. This is due to the fact that historically, Maputo Municipality was not part of Maputo Province but was a separate Province, which still today has vestiges of a Provincial govemment. This situation led to the establishment of links with MICOA at Central rather than Provincial level. Beira In Beira the Provincial Directorate for the Co-ordination of Environmental Affairs comprises four Departments plus one inspectorate under the Directorship of a senior level technician (Bachelors' degree in forestry). * Department of Environmental Management, headed by a senior level technician (Bachelors' degree in Chemistry). * Department of Territorial Planning, headed by a senior level technician (Bachelors' degree in Geography). * Department for the Promotion of Environmental Awareness, headed by a mid- level technician. * Department of Administration and Finance, headed by a mid-level technician. There is also a Provincial Inspectorate comprising two mid-level technical staff responsible for environmental monitoring and enforcement. There is currently no EIA Department. The Provincial Director oversees the implementation of EIA regulations and procedures. The EIA Department needs, therefore, to be established and strengthened. The Organogram for the Provincial Directorate of Coordination of Environmental Affairs in Sofala Province is given below. Director | Provincial | Department of Department Department for the Department of Environmental of Territorial Promotion of the Administration Management t Planning Environmental Awareness & Finances  Municipal Development Project: Environmental Analysis Quelimane In Zambezia Province co-operation between Provincial MICOA and the Municipalities of Quelimane and Mocuba (Zambezia's second largest city) is good due to links forged through the implementation of a two-year pilot project started in 1998 (the Urban Environmental Rehabilitation Project) and financed by DANIDA. Activities include: Quelimane * Improved access roads to the airport neighbourhood * Urbanisation of the airport neighbourhood * Cleaning of drainage ditches * Awareness education regarding health implications of defecation in the open * Support for the centre for environmental development and education (the project finances and monitors the centre's activities). Mocuba * Organisation of the central and the 25 de Setembro Bairro * Improved access roads within the town * Combating urban erosion These activities are coordinated by MICOA although their implementation is carried out by a local NGOs viz. the Centre for the Development of Environmental Education CEDEA. In Quelimane Nucleus of the Friends of the Environment (NANA) in Mocuba. Currently the Provincial Directorate for the Coordination of Environmental Affairs in Zambezia comprises four departments with a staff of three senior level technicians (including the Director) and eight medium level technicians (two of whom recently received training in environmental management in Portugal) and eight basic level staff. - The Department of Environmental Management and EIA6 headed by a senior level technician (a graduate forestry engineer) plus two mid-level technical staff. * Department of Territorial Planning headed by one mid-level technician (ex Provincial Institute for Physical Planning) plus five mid-level technical staff. * Department for the Promotion of Environmental Awareness headed by a senior level technician (a graduate forestry engineer) plus one mid-level technician. * Department of Administration and Finances (headed by a basic level technical staff member). The Director is a senior level staff member with a degree in financial management. In addition, there are eight basic level technical staff. The capacity to oversee EIA regulations and procedures is considered weak and needs to be strengthened. The simplified organogram of the Provincial Directorate for the Co-ordination of Environmental affairs is shown below. 6 Note that EIA and Environmental Management roles are grouped under one Department, whereas at central level they are separated  Municipal Development Project: Environmental Analysis Director Department of Department of Department for the Department of Environmental Territorial Planning Promotion of Administration Management and EIA Environmental and Finance Awareness Nampula In Nampula Province, the structure of the Provincial Directorate is similar to central level, and comprises five Departments: e Department for EIA comprising only one mid-level technician who is also the head and the only staff member in this Department.