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Rwanda

New Bugesera International Airport

$150 million
Infrastructure
Environmental and Social Review Summary
Proposed
twitteremail

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only. Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.

MIGA has been approached to cover a US$120 million equity investment into the Bugesera Airport Company (BAC), for the purposes of designing, building, and operating, the New Bugesera International Airport (NBIA or the “Project”). The Project involves the design, construction, operation and maintenance of a new airport, including airport terminal and associated structures and infrastructure; temporary 5 kilometers (km) water pipeline for the construction phase; upgrades to the road linking an existing quarry northeast of the proposed Project; and a 14.5 km expressway. The Project is located 23 km southeast of Kigali in the Rilima and Juru sectors of the Bugesera District of Rwanda. The Project is fully owned by BAC, a special purpose vehicle responsible for the construction and operation of the Project, which is 25% owned by Aviation Travel and Logistics (ATL) - an institution of the Government of Rwanda, and 75% owned by Mota Engil - an international construction and infrastructure management company. Mota Engil is also the project developer and Engineering, Procurement and Construction (EPC) contractor. It is proposed the ground services will be provided by RwandAir as the anchor airline for the airport. Airport Consulting Vienna (ACV), an international firm specializing in commercial airport planning and development, has been engaged as technical advisor for the construction of the Project, and is also being considered to provide technical support during operations.

It is proposed that the Project will be developed in 5 phases to add capacity as demand grows. The airport will support an estimated 70 flights per day initially, expected to rise to approximately 171 flights per day by the end of Phase 5. The MIGA guaranteed investment will be used for Phase 1, which will include: passenger terminal with 3 boarding bridges, presidential terminal, cargo terminal, heliport, air traffic control tower, 3.5 km runway, maintenance hangar, ancillary buildings (e.g. police, catering, airport administration, airport rescue and firefighting), fuel farm, substation and wastewater treatment plant. The fuel farm will initially include one above ground 2,200 cubic meter (m3) storage tanks and an airside fueling station. Phases 2 – 5 comprise incremental additions to the infrastructure constructed as part of Phase 1 to gradually increase the capacity of the airport. For example, Phase 2 will include construction of a fourth boarding bridge, a second tank at the fuel farm, a third maintenance bay and a new office building. The Project will also include the construction of a 14.5 km expressway, 5 km temporary water pipeline and upgrade of an existing road linking the Project site with an existing quarry. As it is already operational and services other projects in the region, the quarry is not considered an associated facility of the Project. It is currently proposed that permanent energy and water supply will be provided to the Project by the Government through existing regional power and water distribution expansion plans. These will be constructed and managed by the Rwanda Energy Group (REG) and the Rwanda Water and Sanitation Corporation (WASAC) respectively.

Approximately 4,000 ha has been acquired by the Government for the Project and a surrounding industrial zone. The land acquired for the Project had previously been used for subsistence farming. The total area of land required for the Project (all 5 phases) is 2,500 ha.  Approximately 2,000 households were physically displaced and 400 households were economically displaced for the development of the airport. Approximately 50 ha of land will be required for construction of the expressway, which will affect 561 households (of which, 34 land owners and their dependents will be physically displaced).

Construction of Phase 1 of the Project started in August 2017, and is expected to be completed by the end of 2020. A construction camp has been constructed within the airport area. The camp comprises site offices, laboratories, canteen, vehicle parking and maintenance sheds, gas station / fuel tank area and water treatment plant. Prior to the water treatment plant being constructed, a temporary septic tank system will be utilized. The camp will also include a steel yard and two concrete batching plants. No worker accommodation will be provided onsite for the construction workforce. Subsequent phases of construction will commence as specific thresholds for passenger and air traffic volumes are met. The Project is expected to employ around 1,800 people during peak construction and approximately 1,200 during operations.

Environmental and Social Categorization

The Project is a Category A under MIGA’s Policy on Environmental and Social Sustainability (2013) because it has potentially significant adverse environmental and social (E&S) risks and impacts. The most significant potential E&S risks are related to physical and economic displacement and impacts on biodiversity, including potential impact on Tier 2 critical habitat. Other potentially significant E&S risks and impacts include those typically associated with construction (e.g. waste generation; noise and air emissions; impact on archaeology and cultural resources; population influx; labor issues and workers’ and community health and safety risks) and those associated with the operations of the airport (e.g. hazardous materials use and storage; solid waste generation; air and noise emissions; risk of bird strikes; security risks; worker health and safety and general airport safety risks).

While all Performance Standards (PSs) are applicable to this Project, based on our current information indicates that the Project will have impacts which must be managed in a manner consistent with the following Performance Standards:

  • PS1: Assessment and Management of Environmental and Social Risks and Impacts
  • PS2: Labor and Working Conditions
  • PS3: Resource Efficiency and Pollution Prevention
  • PS4: Community Health, Safety and Security
  • PS5: Land Acquisition and Involuntary Resettlement
  • PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource

There is no evidence of indigenous people (as defined by PS7 Indigenous Peoples) residing in or having cultural ties to the Project area; therefore, PS7 does not apply.

The archaeology and cultural heritage surveys conducted in the area have found only potsherds, which were not considered of archaeological significance. Therefore, PS 8 Cultural Heritage does not apply. However, a Chance Find Procedure has been prepared and is being implemented during the construction phase. The Chance Find Procedure will also be applied during the operations phase, and during construction of Phases 2 – 5.  

In addition to the Performance Standards, the World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines and Guidelines for Airports will be applied to the Project.

The following key documents were reviewed by MIGA:

·         New Bugesera International Airport (NBIA) Environmental and Social Impact Assessment (ESIA) Non-Technical Summary. Ramboll Environ UK. October 2017.

·         NBIA ESIA Study Report and Technical Appendices. Ramboll Environ UK. January 2018.

·         NBIA Post-Resettlement Audit Report. Ramboll Environ UK. September 2017.

·         NBIA Environmental and Social Management System Manual. Bugesera Airport Company. January 2018.

·         NBIA Biodiversity Action Plan. Ramboll Environ UK. February 2018.

·         NBIA ESIA. Gibb Africa Consulting and Design. April 2010.

·         NBIA Draft Resettlement Action Plan (RAP). Gibb Africa Consulting and Design. May 2010.

·         NBIA Expressway Resettlement Action Plan (RAP). Ramboll Environ UK. March 2018.

·         NBIA Resettlement Outcomes Audit and Potential Future Mitigation Actions: Final Report. Ramboll Environ UK. February 2018.

·         NBIA ESIA Phase Stakeholder Engagement Plan. Ramboll Environ UK. August 2017.

·         NIBA Gap Analysis Report and Environmental and Social Action Plan (ESAP). Ramboll Environ UK. July 2017.

·         NBIA EIA Certificate and Conditions of Approval. Rwanda Development Board. March 2018.

MIGA’s review also included a site visit in April 2018. During the visit, the team visited the Project area (including the airport site, expressway route and water intake site) and had meetings with MIGA’s client, Bugesera Airport Company, Mota Engil, representatives of Project Affected Persons (PAPs) and relevant Government authorities (i.e. Rwanda Environment Management Authority, Ministry of Infrastructure and Rwanda Transport Development Authority).

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project, and identified gaps, if any, between these and MIGA’s E&S requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this Environmental and Social Review Summary (ESRS). Through the implementation of these measures, the Project is expected to be designed and operated in accordance with MIGA’s Performance Standards.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment:

An Environmental and Social Impact Assessment (ESIA) was prepared for the Project by an independent consultant in 2010 per local requirements. In 2017, an international consultant was engaged to undertake a gap analysis of the 2010 ESIA against E&S requirements of the Project Lenders (DEG, AFC and African Development Bank), and to develop an updated ESIA to comply with those requirements. The revised ESIA, prepared with reference to the IFC Performance Standards (2012), was completed at the end of 2017 and submitted to the Rwanda Development Board (RDB) for approval. RDB provided approval in March 2018.

The revised ESIA baseline and impact assessment provide a comprehensive review of the potential risks and impacts of the Project (construction, operation and decommissioning phases), and appropriate mitigation measures are recommended in line with MIGA’s requirements.

Management Program and Monitoring:

The ESIA includes an Environmental and Social Management Plan (ESMP), and several other supporting management plans have also been prepared (e.g. Community Health, Safety and Security Management Plan; Biodiversity Action Plan; Air Quality Management and Dust Control Plan). BAC has developed an overall Environmental and Social Management System (ESMS) for the Construction Phase of the Project. The ESMS will be adapted for the operational phase at a later date (ESAP action item #9). The ESMS, which is consistent with the requirements of PS1, includes the Project’s Environmental Policy; identification of applicable environmental and social obligations; identification of environmental and social aspects and impacts relevant to the Project; an overview of the environmental procedures to ensure compliance with the Project’s environmental and social obligations; auditing requirements and reporting requirements. The ESMS also includes an organization structure for E&S management and statements of responsibility and authority. Appropriate ESMPs and procedures have been developed under the ESMS for the construction phase. Plans and procedures will need to be developed for the operations phase prior to operations (ESAP action item #10). BAC has committed to implementing good international industry practices in the operation of the airport, including monitoring and adaptive management of noise impacts; airport safety management and implementing resource efficiency measures.

At the corporate level, Mota Engil has an integrated management system that covers quality, environment, health and safety. The integrated management system is designed and certified to International Organization for Standardization (ISO) 9001:2015 for Quality Management System, ISO 14001:2015 for Environmental Management Systems, and the British Standard International for Occupational Health and Safety Assessment Series (OHSAS) 18001:2007 for Occupational Health and Safety Management System. Construction environmental management plans have been prepared, which include an organizational chart for environment, health and safety management during construction. Mota Engil also has a system in place to manage sub-contractors. All sub-contractors are required to comply with the environmental, health and safety requirements of Mota Engil.

Organizational Capacity and Training:

As mentioned above, the Project ESMS includes an organization chart, roles and responsibilities for environmental, health, safety and social management. While BAC has only a limited number of staff and capacity, Mota Engil, as the majority shareholder, has adequate capacity at the corporate, regional, and national levels to manage the environment, health and safety (EHS) risks associated with construction. BAC will engage a social performance manager to oversee the development and implementation of the Project's social commitments, including supporting establishment of the resettlement unit and implementation of the livelihood restoration plan.  BAC will also engage an E&S consultant to facilitate implementation of the Biodiversity Action Plan, if required.

Mota Engil has a qualified health, safety and environment manager on site. The Health, Safety and Environment (HSE) team is currently comprised of 7 people (one manager supported by an HSE officer, 1 senior safety officer, 3 safety officers and 1 community liaison officer). Sub-contractors are also required to have safety officers. HSE training is provided to all construction workers, including sub-contractor employees.

Reporting:

Reporting activities for the construction phase, including daily and monthly reports, are described in the ESIA and ESMS. Safety officers prepare daily reports (including pictures), which are submitted to the HSE Manager. A monthly report is prepared, which includes (inter alia) training records, accidents and incidents, waste generation, and energy consumption. This report is submitted to BAC and Mota Engil. BAC has also confirmed that MIGA will have access to the E&S monitoring reports submitted to Project Lenders. The Project will also be required to provide MIGA with an Annual Environmental and Social Monitoring Report (AMR).

Emergency Preparedness and Response:

An Emergency Preparedness and Response Plan (EPRP) has been prepared for the construction phase. Prior to airport operations, a comprehensive EPRP will need to be developed, which will include emergency response procedures in the event of an airplane crash, bomb threat, act of unlawful interference, fire, handling of dangerous goods, contagious diseases and natural disasters (ESAP action item #10). It will also define roles and responsibilities and include a communications protocol for notifying relevant local authorities, emergency services, and local communities (as required). BAC will have a security manager, who will be responsible for coordinating an Airport Emergency Committee, which will include representatives from relevant stakeholders, including BAC, Airport Civil Defense, Airport Police Department, Airport fire and emergency services and the military.  The fuel farm contractor will be required to have their own environmental and social management plans and emergency procedures, which will be integrated into the overall plans and procedures for the airport (ESAP action item #11).

 

Stakeholder Engagement

Stakeholder Engagement was initially carried out as part of the 2010 Draft ESIA process, whereby consultations were held with representatives from twenty-five villages including: six public meetings; focus groups of ‘opinion leaders’; group discussions with Sector Officials and opinion leaders in Rilima and Juru Sectors; and discussions with women and youth at sector level. The names of the twenty-five villages were not provided within the draft 2010 ESIA Report and neither were the numbers of those consulted. Generally, the community was supportive of the Project, however people within the project area felt that as it was a Government project and they did not have any other choice but to provide their consent. The main concerns were related to relocation and compensation. Consultations were also held with central government ministries and agencies, Non-governmental Organizations (NGOs) and Community-Based Organizations (CBOs).

Informed consultation and participation (ICP) was carried out as part of the 2017 ESIA stakeholder engagement process, in line with PS 1 requirements. A range of stakeholders, including the affected communities were identified, mapped and thereafter consulted through: (i) community meetings, where 295 PAPs attended and approximately 34% of the attendees were women (women were also represented at all the meetings); and (ii) workshops for international/national as well as local NGOs. Disclosure of information was carried out through: (i) the distribution of leaflets with key information on the Project; and (ii) presentations of the Project provided at the beginning of each consultative meeting followed by a question and answer session. Community concerns identified through this engagement process mainly related to: land acquisition and compensation arrangements; expectations regarding potential job opportunities and development benefits; and environmental and health impacts on the local community.

In line with PS1 requirements, a Stakeholder Engagement Plan (SEP) was prepared for the Project ESIA phase in July 2017 and thereafter updated in August 2017. The SEP includes a community grievance mechanism, which is available to affected communities and local authorities. The SEP will be updated for the construction and operational phases of the Project (ESAP action items #7 and #8).

Broad Community Support (BCS) for the Project will however be assessed as part of the MIGA due diligence.

PS2:  Labor and Working Conditions

It is estimated that the proposed Project will generate approximately 1,800 jobs during the peak construction period, between October 2018 and September 2019, with initially 200 permanent jobs. During operations, the Project will permanently employ approximately 200 people in Phase 1 (i.e. from 2020) and thereafter reaching 500 after 2045 (Phase 5). 

Human Resource Policy and Procedures:

The Project has developed a Human Resources (HR) Policy as part of its Construction ESMS and this will be revised/updated for the operations phase (ESAP action item #15).  A Labor, Working Conditions and Employment Management Plan has also been developed as part of the Construction Environmental and Social Management Plan (C-ESMP) and will be updated for the operations phase (ESAP action item #10). The HR Policy and procedures will be updated to the requirements of PS2, as detailed in the Sections below.

Working Conditions and Terms of Employment:

The Project will avoid discrimination and ensure equality of opportunity during the recruitment processes of its own employees and workers engaged by third parties. BAC has a target of 80% for hiring local people and as such, priority will be given to Project Affected People (PAPs) for unskilled employment during airport construction and operations (at least over next 10 years). The PAPs should receive responses on their job applications, whether or not they are successful (ESAP action item #16). The HR policy and procedures will also be updated to the requirements of PS2 to include measures to ensure freedom of association and collective bargaining.

Employee Grievance Mechanism:

As part of the Construction ESMS, BAC has developed and are in the process of implementing the following procedures in line with PS2 requirements: Internal and External Communication Procedure; and Internal Complaints Procedure. Grievances are raised verbally or in writing to the supervisor or departmental head. The receiver of the complaint prepares the report of the grievance, which is thereafter sent to the HR Manager/Community Liaison Officer (CLO), to capture in the internal complaints register, which currently is under development. A copy of the grievance is thereafter sent to the relevant departmental head to address. The Internal Complaints Procedure will be adapted to allow for anonymous complaints from both employees and contractors, and the internal complaints register will be finalized (ESAP action item #18).

Retrenchment Plan:

In the event of any retrenchment, BAC will develop and implement a Retrenchment Plan in line with PS2 requirements, in consultation with workers, their organization and if appropriate, the Government (ESAP action item #20). 

BAC is currently interviewing Kigali International Airport (KIA) staff to negotiate and arrange their transfers to the Project, where possible. ATL (as a BAC shareholder and an arm of the public and regulatory aviation bodies) will represent and defend KIA’s staff interests and make sure they are considered on a priority basis, subject to their qualifications. The staff will be integrated into the NBIA personnel, if they are deemed competitive and qualified to contribute efficiently to the operations of the new facility and the same will apply to the shops at KIA (ESAP action item #19). KIA will continue to operate but will focus on cargo and military flights.

Occupational Health and Safety (OHS):

As part of the Design and Construction ESMS, BAC management has developed and implemented a Health, Safety and Environmental (HSE) Policy specific to the NBIA project. BAC has also developed the following procedures:

·         Health, Safety, Social and Environmental (HSSE) Aspects and Risk Assessment;

·         Training and Awareness;

·         Incident, Investigation and Reporting;

·         Incident Investigation and Reporting;

·         Recording and Reporting of Non-Conformances; and

·         Emergency Preparedness and Response Procedure.

An HSSE committee has been developed, with representation from both BAC and the workers. Contractors will have to comply with PS2 requirements and this will be stated in the contractual agreement between BAC and the contractors (ESAP action item #13). BAC will also ensure that contractor OHS procedures and practices are in place and being implemented adequately.

Worker Accommodation:

There will be no onsite accommodation. Accommodation has been provided to a limited number of senior employees at the Gashora Lodge, located to the east of Lake Rumira, approximately 9 km southeast of the Construction Camp. All other employees will live offsite in their own accommodation and will be transported to the Project Site by buses. It is estimated that 13 mini-buses (25 seats each) and 25 light vehicles will be used daily for the transport of construction personnel. The Traffic Management Plan developed for the construction phase of the NBIA will be adapted for the operational phase and include measurers to ensure that the drivers of these buses comply with traffic, transport and safety regulations (ESAP action item #26).

Supply Chain:

Rwanda's Labor Law sets the minimum age for work at 16 and the minimum age for hazardous work at 18. However, the Project will not employ workers under 18 years of age. The potential for child and forced labor in the primary supply chain will also be monitored and contracts with sub-contractors and suppliers will include Environmental Health and Safety (EHS) requirements and provisions consistent with PS2 requirements to address labor issues including child and forced labor (ESAP action item #14).

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency

The Rwanda Water and Sanitation Corporation (WASAC) and Rwanda Energy Group (REG) will be responsible for supplying water and power respectively for the operations phase. There is currently limited information available about the source and design of these services; however, both will be subject to independent environmental impact assessment processes. It is understood that a new water treatment plant, which will treat water from the Kanzenze well fields, will be constructed near the Project area, and this plant will supply water to the Project.

Greenhouse gases (GHG):

During construction, the Project will generate GHG emissions from the use of electrical energy and fuel for construction vehicles. During operations, GHG emissions will result from the use of electrical energy for the operation of the airport and aircraft emissions. As per the requirements of PS3, BAC will quantify direct and indirect GHG emissions annually in accordance with international recognized methodologies and good practices.

Water Resource Use:

During construction, water will be required primarily for concrete mixing and dust suppression. Water will be transported to site via a temporary pipeline from Lake Kidogo, and it is estimated that approximately 600 m3 per day will be required. The ESIA indicates that this amount is likely to have negligible impact on Lake Kidogo. During operations, water will be required primarily for domestic use – sanitation, drinking, catering and washing. Water resource efficiency measures have been included in the design of the airport (e.g. installation of low-flush toilets; efficiency heating and cooling systems).

Air Emissions:

During construction, air emissions will include exhaust from heavy vehicles and fugitive dust generated by construction activities. Those most likely to be affected are people living along the expressway corridor. The implementation of mitigation measures (e.g. dust suppression; vehicle maintenance) will minimize the impact of air emissions during construction; and any residual impact is expected to be limited in scope and duration. Measures to mitigate air emissions are incorporated into the Air Quality Management and Dust Control Plan. During operations, the primary air emissions will be related to: (i) aircraft operations during landing and take-off, emitting fuel combustion gases (carbon dioxide, nitrogen oxides, carbon monoxide, and to a lesser extent, sulfur dioxide and hydrocarbons); (ii) fuel handling and refueling of aircrafts (fuel vapors); (iii) ground support vehicles (exhaust gases); and (iv) exhaust fumes along the expressway route. Mitigation measures, such as the optimization of the aircraft ground traffic and traffic flows along the expressway, will be implemented to keep identified impacts to an acceptable level. An air quality management plan will be prepared for the operations phase, which will include mitigation measures, monitoring plan and adaptive management measures (ESAP action item #10).

Noise:

Noise and vibration impacts during the construction phase will be generated from site clearance and construction machinery and vehicular movements to and from the quarry and to transport workers attending the construction site. Noise from construction work is expected to have a minor, temporary impact on the closest residential areas, which are located approximately 500 m from the proposed airport area.

During the operations phase, the primary impact from the proposed Project will be noise from aircraft operations and road traffic on the Expressway. Road traffic noise is estimated to affect between 25 and 50 households living within 75m of the expressway. Aircraft operations are expected to cause a noise impact above the ambient noise guidelines in the WBG EHS Guidelines at a large number of dwellings in a predominantly rural environment along the flightpaths into and out of the airport. Mitigation measures to reduce noise impact from aircraft operations include the development of departure and approach procedures (ESAP action item #10), including identifying noise preferential routes, and use of night time or other operating restrictions, as well as ensuring that, in the medium to longer term, development planning ensures that noise sensitive receptors such as further dwellings are positioned outside of the unavoidable noise impact envelopes identified in this assessment. The operations ESMPs will include procedures for regular monitoring of ambient noise levels. The construction of the Project, and the movement of aircraft operations from Kigali International Airport to NBIA will reduce noise impacts from aircraft operations on some densely populated areas in Kigali.

Water Resources:

During construction and operations, potential impacts to surface water bodies and downstream receptors is primarily related to storm water run-off. A storm water management plan has been developed and is being implemented during the construction phase to minimize water quality impacts.

The Project includes the construction of a wastewater collection and treatment system to collect both sewage and industrial wastewater from the airport facilities. The wastewater treatment plant with a capacity of 270 m3/day will be designed to satisfy national standards and WBG EHS guideline requirements. Storm water drainage infrastructure is included in the design of the proposed Project to manage surface water runoff across the Project area. This and the implementation of management plans (ESAP action item #10) will ensure that no significant impacts will occur in surface water flows to hydrological receptors and downstream receptors. This will also control pollutants and prevent discharge of polluted surface water off-site. The Expressway, which crosses wetland and floodplain areas, also incorporates drainage and storm water control systems into the design.

Hazardous and Solid Waste Management:

The construction and operation of the Project will result in the generation of solid and hazardous waste. During construction, waste streams primarily include inert waste (concrete, excavated soil etc.), non-hazardous waste (plastic bottles, paper, etc.) and hazardous waste streams (waste oils, contaminated soils, etc.). A construction phase waste management plan has been prepared, which describes and estimates the waste streams, outlines the key management measures and identifies storage areas and waste contractors. Expressway design has been optimized to re-use excavated soil as clean fill such that the need for borrow areas and spoil disposal areas is not anticipated.

Wastes generated during operations will include wastes generated from aircraft and by airport users and staff (non-hazardous waste), recyclable wastes (such as scrap metal), tires and hazardous waste (such as used oil and solvents). The Project includes construction of a central waste collection and management area. Phase 1 operations are anticipated to generate approximately 30 m3 of mixed waste per month. This waste will be managed by the airport operator, similarly to how waste is currently being managed at the Kigali International Airport. A detailed waste management plan will be prepared for the operations phase (ESAP action item #10). The fuel farm contractor will be expected to prepare a waste management plan specifically for the fuel farm, which will be integrated into the overall site waste management plan (ESAP action item #11).

Pesticide Use and Management:

BAC will develop and implement a procedure for the use of pesticides and agricultural chemicals for the maintenance of airport green areas (ESAP action item #22), and will follow international guidance on the use of mechanical operations (cutting and shearing).

PS4:  Community Health, Safety and Security

During construction, community health and safety risks are largely associated with traffic and heavy vehicle movement of construction materials and equipment along Project access roads (including the quarry access road) and unauthorized access to construction areas. Traffic impacts will be mitigated by minimizing the number of vehicles on the road, driver training, enforcement of speed limits and maximum load size and the installation of visual signage and pedestrian crossing areas. These measures have been incorporated into a traffic management plan for the construction phase. Site access is limited to authorized personnel only, which is controlled by security guards posted at checkpoints along the access roads to site.

For operations, the airport is designed in accordance with local and internationally accepted (International Civil Aviation Organization – ICAO) life and fire safety standards, consistent with WBG EHS Guidelines for Airports. During operations, BAC will develop plans and procedures to regularly maintain, test and audit life and fire safety systems to ensure operational readiness (ESAP action item  #27). A Fire Safety and Evacuation Plan will form part of the Airport Emergency Plan (ESAP action item #10).

Traffic safety:

Traffic flows during Phase 1 operations are expected to be approximately 1,021 vehicles visiting the airport per day, of which, approximately 133 will be heavy vehicles. The expressway will be constructed in an area that is sparsely populated, crossing areas of subsistence farming, rural homesteads, floodplains and a wetland. The Expressway will be designed and developed considering safety aspects such as traffic lights, pedestrian and animal crossing points, stop signs, speed humps, traffic calming zones, street lights, etc. The Government will be responsible for maintaining the expressway throughout the life of the Project.

Hazardous Materials Management and Community Safety:

Airport operations include the storage and handling of jet and diesel fuels primarily associated with aircraft fueling activities as well as with ground support vehicles. Fuel will be stored in aboveground tank farms within the Project area. Initially, with Phase 1, there will be one aboveground tank, and it is proposed that Phase 5 would have three aboveground tanks. The fuel storage area will be operated by a contractor (Societe Petroliere (SP) Ltd) and will store kerosene type-fuel Jet A-1 and AVGAS 100LL, a gasoline fuel for piston engine aircrafts. In addition, there will be 2 service stations for fuel distribution inside the airport. There will be a fixed exclusion zone around the fuel tanks within which no occupant and public building are allowed. The extent of the zone will be determined by a risk assessment, which will be undertaken by the fuel farm contractor and reviewed by an independent engineer. There are no residential areas in the vicinity of the fuel farm. The closest residential area may be an eventual airport hotel, proposed to be constructed in the adjacent special economic zone. The hotel will be constructed outside of the exclusion zone identified by the risk assessment. As indicated under PS1, the fuel farm contractor will be required to have their own environmental and social management plans and emergency procedures, which will be integrated into the overall plans and procedures for the airport.

Bird Control System:

Measures will be in place to manage wildlife hazards such as bird strikes. These may include devices that beep to scare birds, netting or draining of streams, grass management, removing waste disposal sites and limiting other attractions to birds. BAC will prepare a wildlife hazard management plan prior to operations (ESAP action item #10).

Obstacle Limitation Surfaces:

A zone will be implemented to define airspace around the proposed Project to be maintained free of obstacles to permit safe airport operations. This zone will extend approximately 8 km in all directions from the runway. There will be controls on placement and heights of structures within this zone.

Security Arrangements:

Security related to airport passengers and protecting the airport perimeter will be the responsibility of the Government of Rwanda via the police and managed by a security firm contracted directly by BAC. BAC will appoint a security manager who will participate in the coordination of civilian and military operation related to airport safety and security and to emergency situations, assess risks related to the interface with public authorities and provide recommendations on how such risks can be managed. The security manager will ensure that the risk assessment will include considerations of risks of the presence of public and private security forces at the airport (ESAP action item #28).

PS5: Land Acquisition and Involuntary Resettlement

The development of the Project will entail the permanent loss of land for populations in the main airport site and expressway. Resettlement Action Plans (RAP) have been prepared for both developments, details of which are provided below:

The Airport:

In 2010, a draft RAP for the airport was carried out to National Legislation and the World Bank’s Operational Directive (OD) 4.10 on Involuntary Resettlement. The RAP focused on the direct core area to be developed for the airport and identified 25 villages to be affected, of which 7,444 persons (2,079 households) would be physically displaced and approximately 1,500 persons (402 households) would be economically displaced. 90% of the PAPs relied on subsistence agriculture for their livelihood, while the remainder worked in the public sector.  The draft RAP also identified several businesses to be affected by the development of the airport. 

However, the draft RAP was not updated or implemented and expropriation was carried out initially by the Rwanda Civil Aviation Authority (RCAA) and thereafter by the Ministry of Infrastructure (MININFRA) between 2010 – 2014 in accordance with the Rwandan Organic Law NO 18/2007 of 19/04/2007 on Expropriation in the Public Interest. Compensation calculations were made according to the procedure in the Organic Law (Bill) NO 08/2005 of 14/07/2005. Both market value and replacement costs were used for calculating compensation amounts for structures and where replacement cost was used, depreciation was applied. Land and crops were compensated at market price, instead of full replacement cost.

Individual compensation was paid to the PAPs and the majority were given cash compensation for their structures, land and crops, and they relocated themselves in nearby villages. 62 households were identified as vulnerable by MININFRA and were relocated to Kingaju Village (Musovu Cell, Juru Sector), in housing developed as part of the Government’s Integrated Development Program (IDP). Those resettled in Kingaju were provided with a house, one acre of land for farming and a cow. To date, neither electricity nor water has not been connected to their homes; however, this has been addressed in the District Development Plan as both water and electricity will be connected to PAPs homes. MININFRA has confirmed that the financial resources for connections is included in the budget for the financial year starting July 1, 2018. A Post Resettlement Audit Report (2017) conducted for the resettlement process states that by 15 June 2017, 99.9% of the compensation payments had been disbursed and the balance of compensation amounts to be paid consisted of 34 case files (14 were in process of payment and 20 cases were held up due to incomplete documentation provided by PAPs). MININFRA is currently following up with local authorities to identify these PAPs and finalize payment of the compensation.  In sum, the number of property owners compensated by the Government was 5,972.

The NBIA Post-Resettlement Audit Report (September 2017) and NBIA Resettlement Outcomes Audit and Potential Future Mitigation Actions (February 2018) established:

  • a general decline in incomes and livelihood status of most PAPs
  • even though most PAPs had better housing conditions, most had smaller parcels of land with just enough for house construction, but not agricultural activities, even though cultivation was their main source of livelihood
  • there were no specific livelihood restoration programs for those PAPs who received cash compensation
  • no financial training was offered by way of non-cash livelihood support
  • no security of tenure (e.g. land ownership documentation) at the resettlement site in Kingaju
  • an inadequate grievance mechanism; and (vii) no follow-up monitoring of PAPs who resettled themselves

To address the above gaps, BAC and MININFRA have agreed to identify, fund and implement the following mitigation measures in line with the requirements of P5, which will be implemented by either party, jointly or in partnership with local government authorities (ESAP action item #34):

  • A Livelihood Restoration Plan (LRP) will be prepared and implemented for the Kingaju PAPs.
  • Transitional support, to be provided to PAPs identified as vulnerable (in line with PS5 requirements) or PAPs classified as being highly-impacted by the extent of land take and/or asset loss.
  • All other PAPs will be provided with the following livelihood assistance, which includes but is not limited to:
  • Priority to be given to PAPs for unskilled employment during airport construction and operations (at least over next 10 years). The PAPs should receive responses on their job applications, whether or not they are successful.
  • Provision of assistance/advice in securing legal title to land plots.
  • Capacity-building for improving agriculture production.
  • Small livestock improvement projects (men and women).
  • Farmer development services and agricultural value chain improvements.
  • Provision of community-level facilities, such as improved road infrastructure.
  • Enhanced access to micro-credit facilities.
  • Skills enhancement/training initiatives.
  • Training in business planning and financial management (for those with business).
  • Targeted community investment/development schemes in villages with comparatively high percentages of displaced people (such as improved access to potable water).

In addition, the following measures will also be implemented by the Government:

o   Water and electricity will be connected to PAPs homes in Kingaju Village.

o   The PAPs in Kinganju Village will be given land titles (title deeds) by 2021.

A timebound Action Plan will be prepared for the above mitigation measures, that includes, specific actions by PAP category, roles and responsibilities for BAC and MININFRA, budget, as well as the monitoring and evaluation process (ESAP action item #31).

A completion audit, in line with PS5 requirements, will be undertaken by competent external resettlement experts, once all mitigation measures have been substantially completed and the agreed monitoring period is completed (ESAP action item #36).

The Expressway

In 2018 a RAP for the 14-km expressway to link the airport to the national KK-15 Road was carried out to international standards, including the IFC Performance Standards (2012). The RAP identified 6 villages that will be affected and 561 PAPs that will be compensated for displacement, including 34 land-owners and their dependents who will be physical displaced. In addition, two businesses will also be affected. Of the total 561 PAPs, there are 392 landowners with legal titles. Those without land titles will be compensated once they have been verified by local leadership and the declaration of ownership forms filled. Compensation will be paid in cash; however, compensation for the loss of business facilities focuses only on the assets and does not include lost net income during the period of transition. MININFRA, through its implementation agency the Rwanda Transport Development Authority (RTDA), is responsible for the land acquisition process and anticipates that all compensation payments will be finalized by the end of June 2018. A grievance redress mechanism has also been developed for the land acquisition process, in line with PS5 requirements.

The proposed expressway alignment is in an area that is relatively sparsely populated and the main land use along the proposed route is crop-based agriculture, supplemented by livestock rearing. Measures to minimize land acquisition have been implemented throughout the planning and design stages, which include re-alignment, where possible. 

All PAPs will be eligible for livelihood restoration measure and the measures will be targeted so that those who need most support can access it. Transitional support will be provided to: (i) areas that are the most impacted by the land take, i.e., priority areas; (ii) households most impacted by land take; and (iii) vulnerable PAPs. Once the cash compensation is paid, both agriculture and business/wages livelihood restoration measures will be implemented, similar to those of the airport.  Therefore, there will need to be coordinated mitigation and livelihood restoration measures for both the airport and expressway PAPs and as such, similar measures may be carried out jointly.

BAC will support MININFRA to establish a Resettlement Unit/Function to fund, manage and implement the livelihood restoration measures until a completion audit is undertaken by competent external resettlement experts, in line with PS5 requirements (ESAP action item #34).

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

The proposed Project area is within the Tropical and Subtropical Grasslands, Savannas, and Scrublands Biome and the Victorian Basin Forest-Savanna Mosaic Ecoregion. While the Project area is not within any national protected areas, the expressway alignment does include parts of the Nyabarongo Wetland Important Bird Area (IBA). The ecological baseline was characterized through a combination of secondary data and field surveys. A critical habitat assessment was undertaken as part of the ESIA, and the Nyabarongo Wetlands IBA was identified as Tier 2 Critical Habitat. This is associated with natural habitat swamp and aquatic vegetation and three IBA trigger bird species (Papyrus Gonolek, Black-lored Babbler and Whitewinged Swamp-Warbler), and the fish Labeo victorianus (Ningu).

The Project area (including the airport area, expressway and water pipeline) is characterized by five vegetation types: anthropic landscapes, grassland, wooded grassland, bushland and thicket and swamp and aquatic vegetation. The airport area is on a plateau, and is primarily anthropic, grassland and wooded grassland, while the expressway crosses swamp and aquatic vegetation. A total of 103 plant species were recorded as the different vegetation types. Birds, mammals, amphibians and reptiles have also been identified within and in the vicinity of the Project area, though no species of conservation significance have been identified within the airport area. Although the narrow edges of wetlands have been modified with human agricultural activities, the majority of swamp and aquatic habitats still perform the primary ecological functions and have species composition of native origin and are considered natural habitats (as defined by PS6).

Construction phase impacts relate to direct loss of habitat (with the majority of the terrestrial habitat within the airport area and expressway lost and small amounts of wetland habitat lost); and fragmentation of habitats used by birds and hippopotamus. Potential indirect impacts include hydrological changes to wetlands, introduction of invasive species, pollution, disturbance, and increased fishing pressure.

Operation impacts primarily relate to disturbance resulting from noise impacts, disturbance from lighting, influx of people, induced access, pollution and changes to hydrology, introduction of invasive species, bird strikes and bird control measures to avoid bird strikes.

A detailed biodiversity monitoring strategy and a Biodiversity Action Plan (BAP), focusing on critical habitat features as well as natural habitat, has been developed to manage construction and operation impacts, and to achieve a net gain for the biodiversity values that triggered the critical habitat designation (i.e. the three-bird species and one fish species). The BAP also provides measures to achieve no net loss of natural habitats affected by the Project. Implementation of the BAP has started with support from a consulting firm and Birdlife International Rwanda.

Environmental Permitting Process

The Rwanda General Guidelines and Procedure for Environmental Impact Assessment (EIA), 2006, describe three levels of assessment: (i) Impact Level 1, where no assessment is needed; (ii) Impact Level 2, where some assessment is needed; and (iii) Impact Level 3, where a full EIA is required. As the Project required a full EIA study, an initial Environmental and Social Impact Assessment (ESIA) was prepared by an independent consultant in 2010 per local requirements for approval, but it was not submitted to either the Rwandan Environmental Management Authority (REMA) or RDB for approval.

As mentioned previously, in 2017 an additional ESIA for the Project was prepared with reference to the IFC Performance Standards and submitted to RDB for approval. An EIA Certificate, with compliance conditions, was issued in March 2018.

Community Engagement

Two Community Liaison Officers (CLOs)  will, as part of their roles and responsibilities: (i) manage implementation of the SEP; (ii) assist the HSE Manager with on-going reporting to stakeholders on the ESMS and supporting management plans, as well as progress with implementation of management measures; (iii) assist with stakeholder communication where awareness and/or co-operation of stakeholders are required to implement management measures; and (iv) manage the internal and external grievance mechanism, including evaluating and addressing stakeholder grievances as stipulated within the Grievance Mechanism.  

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