25340 - EASSy Cable

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Environmental & Social Review Summary

Project Number

25340

Company Name

WEST INDIAN OCEAN CABLE COMPANY LTD

Date ESRS Disclosed

Apr 27, 2007

Country

Eastern Africa Region

Region

Africa

Last Updated Date

Jun 3, 2021

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Aug 2, 2007
Signed : Nov 21, 2007
Invested : Jun 12, 2008

Sector

Cable and Broadband

Industry

Telecommunications and Technology

Department

TMT, Venture Capital & Funds

Project Description

The East African Submarine Cable System (EASSy) is an initiative to construct and operate a submarine fiber optic cable along the east coast of Africa to connect eight coastal countries and island nations to each other and to the rest of the world. A special purpose vehicle (SPV) has been established by EASSy which consists of a small management and marketing team who will manage the implementation of the project. The SPV has contracted Alcatel, a specialist international company, to construct the project in coordination with the respective national telecom operators.

The cable will have an initial equipped capacity of 20Gbits/sec, and an ultimate capacity when fully upgraded of 320Gbits/sec. The route will be from South Africa to Sudan, covering about 8,500 km, and connecting the following countries: South Africa, Mozambique, Madagascar, Tanzania, Kenya, Somalia, Djibouti and Sudan. Twenty-eight leading telecommunications operators (the Operators) from East and Southern Africa signed a Memorandum of Understanding (MOU) in December 2003 to carry out the construction and maintenance of EASSy. EASSy will be the first optical fiber connection for most of these countries to the global optical fiber network. In separate projects, EASSy signatories are working on the development of terrestrial backhaul connections to link land-locked countries of the region to the cable (including Botswana, Burundi, Ethiopia, Lesotho, Malawi, Rwanda, Uganda, Zambia and Zimbabwe). IFC has been asked to provide financing to the SPV, along with five other DFIs including EIB, AfDB, DBSA, AFD/Proparco, and KfW.

The terrestrial backhaul connections are separate from but associated with the project and are to be developed by the respective national operators. These components are being financed by the World Bank who will ensure adherence to their Safeguard Policies in implementing these projects.

Overview of IFC's Scope of Review

The scope of the project review with IFC’s Performance Standards included site visits, coordination with other lenders, and review of the documents as listed and described below:

- EASSy Detailed Feasibility Study, completed by Axiom, May 2005;
- Environmental and Social Impact Assessment (East African Submarine Cable System Project ESIA, February 2007, completed by EGS Ltd. - see link below);
- assessment of EASSy’ current and proposed management capacity and management systems; and
- review of EASSy’s framework Environmental and Social Management System (ESMS dated February 2007).
Site visits to selected landing stations were completed by the project team and meetings were held with senior management of the EASSy consortium, the ESIA consultants and national telecom operators (including Telkom Kenya, TELMA, Dalkom and Zantel) in February 2007.

In coordination with EASSy, Kreditanstalt für Wiederaufbau (KfW) and the African Development Bank (AfDB), and the World Bank/IDA who are lenders to the associated terrestrial backbone and backhaul components, a two phased approach to the Environmental and Social due diligence has been established. Phase I, now complete (see link below), included an assessment of international/deep water impacts, audits of national level requirements, and completion of a framework Environmental and Social Management System (ESMS). Phase II involves completion of national level ESIAs focusing on national/shallow water impacts and terrestrial impacts at landing points. IFC has been coordinating with these partners (and the World Bank) on the scope and depth of the ESIAs required. KfW and the AfDB are providing Technical Assistance for the two respective phases; IFC review of the Phase II will continue in coordination with these partners.

E & S Project Categorization and Applicable Standard

Applicable Performance Standards (PS):

- PS1: Social and Environmental Assessment and Management System
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health, Safety and Security
- PS5: Land Acquisition and Involuntary Resettlement
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management

There are no known Indigenous Groups (PS7) in the project area and no impacts on Cultural Property (PS8) are anticipated. No physical displacement will occur as a result of land acquisition for the landing point stations or manholes.

This is a Category B project according to IFC’s Environmental and Social Review procedures because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The project has three distinct physical components:

- international water cable;
- shallow/national water cable; and
- landing points and stations.

The deep water international cable laying results in minimal impact as there will be no interference with fishing activities and minimal disturbance to wildlife. None of the eight landing sites will result in significant impacts to shallow water or terrestrial habitats or resources. Four of the landing sites will utilize existing manholes and ROW (existing public roads). Avoiding direct impacts on seagrass, coral reefs and fishermen will be the basis of final ROW selection during the Marine Survey of shallow water. Impacts are thus anticipated to be easily identifiable and manageable to ensure compliance with PS requirements.

Environmental and Social Mitigation Measures

The EASSy management team has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures listed in the ESIA, comply with the environmental and social requirements of the national level ESIAs, the host country laws and regulations and the IFC PS. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the Phase I ESIA.

- PS1: Social and Environmental Assessment and Management System (SEMS)

National operators are developing their respective plans and components of the project at different schedules, accordingly, as defined above, a two phased approach to the Environmental and Social due diligence has been established. Phase II, which will cover the 8 landing point countries, will include completion of ESIAs to meet national and IFC PS requirements and addressing shallow water and landing point impacts. Phase II ESIAs are underway and it is anticipated they will be completed over the next 6 months. Phase I includes development of a framework ESMS, which Phase II ESIAs will follow in developing their respective management systems. This will result in an integrated and consistent ESMS which will govern all national and international level operations resulting in an integrated ESMS for the EASSy project. IFC and other donors will review Phase II ESIAs as these are completed. In addition, the Phase I international consultant has been retained by KfW to review all Phase II draft ESIAs to ensure consistentcy with applicable standards and the model ESMS. As detailed in the Phase I ESIA, Phase I requires EASSy to engage an environmental auditor for each landing point, to monitor contractor (including Alcatel) operations during construction and cable laying.

- PS2: Labor and Working Conditions

The EASSy SPV (the sponsor) will employ a small number of professional marketing and administrative staff to sell cable connectivity. The SPV will develop an HR Policy consistent with PS2 and will provide all employees with access to this policy. Alcatel, EASSy’s construction contractor, will ensure that all cable laying operations comply with the ESIA requirements, including those related to labor, by implementing training programs and working coordinating all construction activities with the environmental auditor. With respect to other contractors or intermediaries employing non-employee workers, Alcatel will use commercially reasonable efforts to ensure that these intermediaries or contractors are reputable and legitimate enterprises and that they apply the applicable requirements of PS3. Alcatel will provide technical training to the staff of national operators who will maintain the cable in shallow water and on land to the landing station. The employees will receive state of the art training and equipment to perform cable maintenance and inspection. All employees will be provided with appropriate safety equipment; Alcatel will follow SOLAS requirements for marine operations and child labour will not be employed during any phase or portion of project construction or operation.

- PS3: Pollution Prevention and Abatement

Waste generated as part of project construction and operation is minimal. The main parameter of concern is sediment dispersal in the marine environment during cable laying. Depending on the depth of water and the condition of the sea bed (clay, rock, sand etc.) the cable will be buried or surface laid. The ESIA discusses, and independent evaluation of existing submarine cables demonstrates that impacts on the marine environment from cable laying are temporary and that marine organisms and habitats recover from the dispersion of sediment very rapidly. Alcatel’s sea vessels will adhere to MARPOL and IMO requirements with regard to waste disposal. Waste from excavation (dirt and rocks etc.) from terrestrial cable laying and manhole construction will either be buried in the duct/trench or disposed, along with other general waste (plastic, paper etc.), at designated municipal sites. Terrestrial operations entail laying a cable in the ground to a depth of approximately 0.5-1.0 meter in a concrete duct following an existing ROW or road. Contractors will be required to control run off and dust during duct construction through implementation of erosion and run off control measures, watering dirt roads and construction sites and providing training to all relevant management and staff on work procedures.

- PS4: Community Health, Safety and Security

During shallow water cable laying fishermen, tourism operators in the vicinity and maritime authorities will need to be informed by EASSy and Alcatel (in coordination the national operators) in advance of cable laying operations to prevent potential entanglement of anchors, vessels and fishing nets with the cable. According to procedures articulated in the Phase I ESIA; this will be incorporated into the consultation process during Phase II ESIAs and cable laying. Risks to communities from terrestrial construction involves only minor and temporary detours to traffic while the trench is established and cable is being laid along roads. EASSy must ensure contractors control traffic and ensure dust levels are controlled through proper work procedures and posting of signal men as needed. The landing points will have security guards posted; it is not anticipated that any of these will be armed. Training will be provided to these guards in accordance with the requirements of PS4 and the need to take action appropriate to the scale of the potential threat posed. Due to the political situation in Somalia the safety of cable installation staff, as well as other workers involved in construction, is a potential concern. Dalkom (an international operator) as well as the relevant Somali Ministries and authorities will implement the recommendations of the Phase II national ESIA to ensure provision of a safe working conditions to employees, non-employee workers and security personnel contracted to safeguard its personnel and property.

- PS5: Land Acquisition and Involuntary Resettlement

No land acquisition from local communities is anticipated for any landing points. Land acquired is from the government and is currently unoccupied. The ROW from the beach/coastal manhole will follow existing ROW and impacts anticipated are minimal. There may be temporary impacts on fishermen in some shallow water locations resulting in minor economic displacement associated with shortened fishing access for a period of days. The Phase I ESIA defines a detailed framework for identifying, consulting and compensating these fishermen; these groups will be compensated according to the respective Phase II ESIAs. Compensation will be agreed with these groups in a transparent manner consistent with agreed market rates.

- PS6: Biodiversity Conservation and Sustainable Natural Resource Management

There is no permanent loss of coral reefs or sensitive habitats (e.g., sea grass beds, coastal dunes, vegetation) and no significant impacts on these habitats expected and, as detailed in the ESIA, offsets are not needed. All beach manholes and landing stations are in urban/peri-urban areas. Where habitat is disturbed by sediment, construction or human activity it will recover in a short period of time. Some of the landing points and ROW pass through protected areas, however impacts are not significant as discussed for each landing point below.

- South Africa:

Impacts are unlikely in the Mlalazi Nature Reserve as the EASSy cable will follow the existing SAFE cable route. In the ecologically sensitive dune area potential impacts may occur in the absence of appropriate construction methods and careful access control.

- Madagascar:

The proposed cable landing site lies within the Littoral de Toliara Biosphere Reserve, the landing point will have no significant impacts on the reserve (as also audited by WWF-Madagascar). Appropriate measures for cable burial have been defined and the ROW to the landing station will follow an existing road.

- Tanzania:

Shallow waters up to the 10 m bathymetric contours are protected and designated as a marine reserve. The main features of ecological importance are scattered reefs, which the proposed route avoids. Reef in the landing point area is reported dead.

- Kenya:

The landing site is located between Fort Jesus and the old Mombasa town. An old cable, manhole and duct already exists and only require renovation and excavation. Cable installation within the existing ducts is considered to have no significant impacts on the surrounding environment and will not have any negative impacts on the nearby Ft. Jesus.

- Somalia:

The manhole and landing station are located near the airport and there is no fringing reef in the area. A new ROW for the duct will be established, it is expected this will pass over sandy areas and not interfere with or cross any sensitive habitats or community areas.

- Djibouti:

The manhole and Terminal Station lie within the Djibouti urban area and it is unlikely that operations will affect sensitive habitats/wildlife as the site is located near existing residential areas and an army barracks. During cable laying Alcatel will ensure they avoid vessel movements near Haramous Island (Haramous-Loyada, 11°35''N 043°09''E), close to the landing site, which is a highly protected sanctuary for seabirds.

- Sudan:

The cable will follow the existing SAS-1 cable routing to Saudi Arabia and passes over a former fringing coral reef now reported dead due to the proximity to Port Sudan and past impact associated with dredging and reclamation.

Stakeholder Engagement

Consultation with national operators and national environmental authorities was completed by Axiom and EGS Ltd in 2006. Consultation with local communities is currently ongoing as part of Phase II ESIAs and will take place at least twice, once during the scoping of the ESIAs and a second time to present results of the ESIA to project affected people. Preliminary meetings in some landing point countries have been held with fishermen groups (e.g., Madagascar, Kenya and Tanzania) during 2006, none have voiced any objection to the proposed project. No objections to the project have been raised to date by any other stakeholders. As part of construction and operation impacts the company will, as necessary, inform fishing communities about potential risks associated with large vessels in shallow water and potential for entanglement with the cable during laying. In coordination with maritime authorities fishermen will be informed about construction schedules and safety procedures. The ESIA has been provided to the respective national level environmental authorities and will be made available locally, along with Phase II ESIAs, through these respective offices. Public announcements in country about the availability of the ESIAs at national environmental authority offices and the national telecom operators will be made in local newspapers. A copy of the Phase I and II ESIAs is also available through the contacts listed below.

For further information please contact:

EASSy SECRETARIAT OFFICE
c/o Telkom Kenya
Telposta Towers,Kenyatta Avenue
24th Floor, P.O. Box 30301-0100
Nairobi, Kenya

Mr. Simon Olawo
Telephone: + 254-20-316167
Fax: + 254-20-310104
Mobile: + 254-722-710099
E-mail: solawo@telkom.co.ke

The Phase I ESIA (and Phase II ESIAs when completed) can be accessed through this link:
www.eassy.org.

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

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