From the Monkey Park, to Farababanta, to the fishmeal factories and onshore sand mining operation disasters along the Kombo South and North coastline, the recent marine sand mining controversy and many other development projects up and down the country, Gambians are becoming increasingly concerned and agitated, and about time too, about the serious environmental issues these projects are raising in our communities, and the governments ( both national and subnational) perceived inability to address these concerns in a satisfactory and sustainable manner.
I spent 17 years ( 2002 to 2019) at the World Bank, resident in Washington DC, Bangkok and Dubai, working for a significant amount of my time and work program, on the environmental issues of major development projects in many countries in Africa, East Asia( including China) and the Pacific Islands, and South Asia, and at various times during this period, served as the Bank’s Environment Coordinator for South East Asia ( Thailand, Laos PDR, Cambodia and Myanmar), Indonesia and the Pacific Islands, and Afghanistan and Pakistan, so I am very familiar with these issues and the concerns being expressed. I say this only to give context for my interest in this area, and for no other reason.
Therefore, over the next few weeks and months, I will for the benefit of generating a constructive dialogue and a teachable moment for us all (myself included), be highlighting the systems, processes and mechanisms that can lend themselves useful to allowing development projects to be executed in a sustainable way, which simply means ensuring, inter alia, that environmental issues are addressed in the project design.
For clarification, when we talk about the environment, we are not only referring to the bio-physical environment, but include the social environment as well, which broadly means people and land tenure issues.
In this my first post, I will start with the Environmental Assessment, often referred to as the Environmental Impact Assessment (EIA) when dealing with development projects. I like to refer to it as the Environmental and Social Impact Assessment (ESIA). The ESIA is a very broad and comprehensive tool that involves many aspects over the life of the project. Subsequent posts will delve into other areas of environmental management and systems for development projects.
The main/fundamental purpose of the ESIA, is to inform the project design and overall decision making. It is very important that it be perceived in this way, and not just as a compliance/regulatory required document to tick a box in the process of obtaining a permit to start work on a development project. Most project owners miss this point at their peril, as we are witnessing in The Gambia today. And to buttress this point, it is the project owner/developer that prepares and takes ownership of the ESIA.
To keep this piece readable and not too long, as the ESIA tool can be very complex and complicated, I will try to deal with it in chunks over several pieces in the next few weeks. The first chunk of the ESIA I want to start with is with the Public Consultations process, which seems to be a major challenge project owners and the National Environmental Agency (NEA) are unable to deal with, which then leads to the public concerns we are seeing being expressed, when uninformed communities and the general public suddenly find themselves affected in some way, as development projects start construction and/or operations.
Public consultations are and must be an integral part of the ESIA and should be carried out continuously during the life of the project, or at a bare minimum, at least twice, before the project starts construction. The first time should be when the terms of reference of the ESIA are being developed and then, the second time can be at stage when a first acceptable draft version ESIA is available, which is when the impacts of the proposed project are identified and the management (i.e. the mitigation and monitoring measures) plan is available, which should be before it is submitted to the NEA for review and approval.
The benefit of public consultations is primarily to ensure the stakeholders, that is, those who may be directly affected by the project (aka project affected persons (PAPs)) and those who may have an interest in the project, have an opportunity to learn about the proposed project, how they may be affected and what plans the project owner has developed to address these potential impacts/effects on them, the stakeholders. This is in turn allows those consulted to express their opinion and concerns, about the proposed project, the potential impacts identified, and the management measures being proposed. This then allows the project to take these views and concerns into account in the final version of the ESIA report. This is important for many reasons. First, it potentially reduces the risk of the project because the project owner knows ahead of time and early in the project design stage, what the concerns of the stakeholders are and will be, early enough, so the project design can take into account these issues by adjusting the design if needs be, or by including other impacts that were not included in the first draft. Another benefit of consultations is that it can begin to build trust that can buy support for the project with local communities and other stakeholders, if done transparently and in a way known in the profession as meaningful and participatory consultations.
To ensure the consultations are meaningful and participatory, a stakeholder mapping exercise must be carried out at the start of the ESIA process, to identify the stakeholders of the project, who are categorized into two groups broadly, (i) those affected by the project ( ie those who may directly be impacted/affected by the project) e.g. local communities, land owners and users, etc and (ii) those who may have an interest in the project ( i.e. institutions such as government (national and subnational), the media ( print, electronic, social, TV news, etc), ngos, traditional representatives of communities, local politicians and parliamentarians, local businesses nearby, etc.
Identifying all the stakeholders is important, as one can clearly appreciate. But the methods used to consult both groups can vary widely. Generally, consulting the second group (ie those who may have an interest in the project) is more straightforward, as they can generally all together be invited to a workshop, in a nice location and venue and over a few hours, consulted.
However, consulting the first group, i.e. those affected by the project, the PAPs, in a meaningful and participatory way is far more complex. It involves using various participatory methods, to ensure PAPs understand the issues being discussed and can freely give their concerns and opinions. This can take the form of conducting the discussions in the local languages spoken by the PAPs, using Focus Group Discussions (FGDs) particularly where gender sensitivity is required for instance in culturally/traditional settings where women may not feel free to speak up, also, using appropriate 3D models and other representations of the project, the timing of the discussions so PAPs can attend, location of the discussions, etc, are all factors to be taken into account to ensure these consultations are meaningful and participatory. Getting this part right may involve the preparation of a specialized social assessment, which then becomes an integral part of the ESIA.
Finally, on this issue of public consultations of the ESIA, it is of paramount importance that (i) the discussions are appropriately recorded and thematically summarized in the ESIA report and this may require protecting names of who said what, so that those consulted are free to comment without fear of attribution, and then (ii) PUBLIC DISCLOSURE of the ESIA (including the draft and the final report) occurs, so that it is accessible to both groups of stakeholders. Just publishing the document in English on the web is not considered disclosed to PAPS who may not be able to read and write in English and who do not have access to the web. For these PAPs, the ESIA must be disclosed in the local language and physically, in areas where they and/or those who represent them, can access the hard copy of the report, like in the local chief/alkali’s house, local community center, school, etc.
In subsequent posts, I will delve into other parts of the ESIA, like the impacts, management plans sections, and environment management systems. I trust you will all find this useful and helpful as we as country begin to work to protect our environment as we pursue development and job creation. It is not a zero-sum game, we can develop and protect our environment and people, at the same time.
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